RAPID/Roadmap/5-FD-a
Bureau of Land Management Geothermal Drilling Application (5-FD-a)
Drilling operations include the performance of flow tests, producing geothermal fluids, and injecting fluids into a geothermal reservoir. 43 C.F.R. § 3200.1. An approved GDP may also cover subsequent well operations at the BLM’s discretion, which include the following:
- Permitting and operating procedures for drilling wells
- Conducting related activities for the purposes of:
- performing flow tests;
- producing geothermal fluids;
- injecting fluids into a geothermal reservoir.
- Subsequent Well Operations.
Subsequent Well Operations are defined as “those operations done to a well after it has been drilled.” Examples of subsequent well operations include:
- Redrilling;
- Deepening;
- Plugging back;
- Cleaning the well out;
- Surveying the well;
- Performing well tests;
- Chemical stimulation;
- Running a liner or another casing string;
- Repairing existing casing;
- Converting the well from a producer to an injector or vice versa
Bureau of Land Management Geothermal Drilling Application Process
5-FD-a.1 to 5-FD-a.2 – Is There a Geothermal Lease?
A geothermal drilling permit cannot be approved unless the land in question has an existing geothermal lease or if an exception to the general leasing rules apply. 30 U.S.C. § 1002. For more information on the leasing process, see:
Federal Geothermal Land Leasing:
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5-FD-a.3 – Geothermal Drilling Permit Application
The developer must submit a signed Geothermal Drilling Permit (Form 3260-2) to the BLM prior to conducting drilling operations or well pad construction. In addition to the application, the developer must submit the following:
Operations Plan The developer must submit a complete operations plan, which describes how the developer will drill and test for geothermal resources covered under the extant lease 43 C.F.R. § 3261.12. The operations plan is required before beginning any surface disturbance on a lease and must be in conformity with any conditions or stipulations related to the grant of the lease. 43 C.F.R. §§ 3261.12, 3261.14. The plan may be submitted either with the drilling program and Geothermal Drilling Permit (Form 3260-2) or on its own, provided that the plan is submitted prior to the drilling program and application form so that the BLM and any relevant Surface Management Agency may conduct a NEPA review on the proposed operations. 43 C.F.R. § 3261.15. The operations plan typically includes:
- Well pad layout and design;
- A description of existing and planned access roads;
- A description of any ancillary facilities;
- The source of drill pad and road building material;
- The water source;
- A statement describing surface ownership;
- A description of procedures to protect the environment and other resources;
- Plans for surface reclamation; and
- Any other information the BLM may require.
An operations plan can include more than one well; however, the developer must give the BLM adequate information for all well sites, and the BLM will combine the developer’s plan to cover those well sites that are in areas of similar geology and environment. 43 C.F.R. § 3261.16.
Drilling Program The developer must submit a complete drilling program that describes all operational aspects of the developer’s proposal to drill, complete, and test a well. 43 C.F.R. § 3261.13. The drilling program may include multiple proposed wells if the wells are to be drilled in the same manner under similar geologic and reservoir conditions. 43 C.F.R. § 3261.16. A complete drilling program includes the following information:
- A detailed description of the equipment, materials and procedures the operator intends to use;
- The proposed/anticipated depth of the well;
- If the operator proposes to directionally drill the well, the operator must also send the following:
- The proposed bottom hole location and distances from the nearest section or tract lines;
- The kick off point;
- The direction of deviation;
- The angle of build-up and maximum angle; and
- Plan and cross section maps indicating the surface and bottom hold locations.
- The casing and cementing program;
- The circulation media (mud, air, foam, etc.);
- A description and diagram of the blowout prevention equipment the operator will use during each phase of drilling;
- The expected depth and thickness of freshwater zones;
- Anticipated lost circulation zones;
- Anticipated reservoir temperature and pressure;
- Anticipated temperature gradient in the area;
- A plat certified by a licensed surveyor showing the surveyed surface location and distances from the nearest section or tract lines;
- Procedures and durations of well testing; and
- Any other information that the BLM requires.
Geothermal Drilling Bond The developer must post an acceptable bond to the BLM prior to the commencement of drilling operations. The developer may submit a bond for the specific project in an amount specified by the BLM, or by providing a rider to a statewide or nationwide bond specifically covering the project. 43 C.F.R. § 3261.18(c). The minimum bond amounts are as follows:
- $10,000 for a single lease;
- $50,000 for all of the developer’s operations within a state; or
- $150,000 for all of the developer’s operations nationwide
BLM may increase the bond amount above the minimums listed above when one or more of following is true:
- BLM determines that the operator has a history of noncompliance;
- BLM previously had to make a claim against a surety because any one person who is covered by the new bond failed to plug and abandon a well and reclaim the surface in a timely manner;
- MMS has notified BLM that a person covered by the bond owes uncollected royalties; or
- BLM determines that the bond amount will not cover the estimated reclamation cost.
The bond amounts can be set to any level that is lower than the total estimated costs of plugging wells, removing structures, and reclaiming the surface and other resources, plus any uncollected royalties due MMS or moneys owed to BLM due to previous violations.
NOTE: The operations plan and the drilling program may be combined by the developer to apply to more than one well, but a separate Geothermal Drilling Permit (Form 3260-2) is required for each well the developer intends to drill. 43 C.F.R. § 3261.16(c).
5-FD-a.4 – Assign Field Office Geothermal Specialist
The BLM assigns a Field Office Geothermal Specialist to serve as a point of contact for the developer and to lead the review of the application after the BLM receives it from the developer. 43 C.F.R. § 3261.20. The FO may be a geologist, engineer, natural resource specialist, or environmental protection specialist. 43 C.F.R. § 3261.20. The Field Office will work closely with the State Office of the BLM the project is located in for application review. 43 C.F.R. § 3261.20.
5-FD-a.5 to 5-FD-a.6 – Review Application Materials for Completeness
The Field and State Offices review the operations plan, lease application form, drilling program, and bonding documents for technical and administrative completeness. The BLM will suspend processing an incomplete application until the developer has provided the missing information 43 C.F.R. § 3261.20(f). After determining the application materials are complete, the Field Office conducts review of the Operations Plan and the State Office conducts review of the leasing and bonding documents, the drilling program, and the application form.
5-FD-a.7 – Review Operations Plan for Compliance
The Field Office Geothermal Specialist reviews the operations plan for compliance with lease terms, conditions, stipulations, and to confirm that any developer proposed environmental measures align with the mitigation hierarchy (avoid, minimize, and mitigate) and that the plan conforms with all applicable regulations. 43 C.F.R. § 3261.20.
5-FD-a.8 – Initiate NEPA Review
The Field Office initiates NEPA review once the compliance of the operations plan has been confirmed. If another federal surface management agency is involved, the Field Office will coordinate with that other agency and must come to a consensus before issuing a decision document. 43 C.F.R. § 3261.20. The United States Forest Service will utilize its mitigation methods regarding environmental impacts if it is the other surface management agency. For more information regarding the NEPA process, see:
Bureau of Land Management NEPA Process:
9-FD-a
5-FD-a.9 – Review Application Materials for Compliance and Adequacy
The State Office reviews the leasing and bonding documents, drilling program, and the application form for compliance and technical adequacy. 43 C.F.R. § 3261.20.
The State Office begins by reviewing the bond to ensure that is active and in good standing, and reviews the lease to ensure that it is current and in good standing, and that the well locations are covered by the lease. 43 C.F.R. § 3261.20.
The State Office Geologist then reviews the proposed action for subsurface geologic, hydrologic, and geothermal resource impacts, and adequate protection of resources. 43 C.F.R. § 3261.20. The State Office Geologist will conduct “downhole” (i.e. actions occurring in the well or borehole) review to ensure adequate protection of freshwater and mineral resources including review of the casing and cementing program, casing depths, and interaction with groundwater resources. 43 C.F.R. § 3261.20.
The State Office Engineer reviews the proposed action for technical adequacy, including well drilling and construction, casing and cementing, and surface operation 43 C.F.R. § 3261.20. The State Office Engineer conducts downhole review to ensure technical adequacy of downhole pressure management, casing integrity and cementing program, and blowout prevention equipment (BOPE). 43 C.F.R. § 3261.20.
5-FD-a.10 – Conduct Onsite Evaluation
The Field Office Geothermal Specialist conducts an onsite evaluation of the proposed wellsite. 43 C.F.R. § 3261.20. The onsite evaluation allows the Field Office to determine what recommendations for conditions on approval may be suitable. 43 C.F.R. § 3261.20. For more information on onsite evaluations, see:
Geothermal On-site Evaluation Overview:
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5-FD-a.11 – Prepare Conditions for Approval (If Applicable)
The Field Office will prepare Conditions for Approval (COA) for the project site after conducting the onsite evaluation. COA are requirements established by the BLM that apply to the design, construction, and operation of the well in addition to any natural and cultural resources present at the well site, and may reflect standard requirements or site-specific characteristics. 43 C.F.R. § 3250.13.
COA will not be issued for measures included in the well plan, lease stipulations, or regulations, and are not used to add stipulations not covered in the existing lease.
5-FD-a.12 – Is the Geothermal Drilling Permit Approved?
The BLM will make a decision to approve the developer’s GDP application once all other reviews have been conducted. Review times for approval are based on the complexity of the proposal, whether another SMA is involved with GDP review, and the degree of alignment with existing NEPA documents. 43 C.F.R. § 3261.20.
If the BLM approves the GDP, it transmits the approved GDP to the developer along with all associated COA.
5-FD-a.13 to 5-FD-a.14 – Geothermal Drilling Permit
The Developer may begin construction and carry out drilling operations once the BLM has approved the GDP. The developer must follow all stipulations of the lease, COA of the GDP, and all other applicable regulations while conducting geothermal drilling operations. 43 C.F.R. § 3262.10.
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