Message to my Mom III

My mother sent me a link to an article in the Chronicle entitles Shallow water, deep anxiety . It discussed the de facto moratorium on new drilling in the Gulf even by shallow platforms, Lots of new paperwork was preventing rig operators from starting new wells in the Gulf. Lots of ‘this government delay is costing me money” sorts of quotes. It was written to really support the idea that the government is purposefully preventing any new oil rigs from being built, presumably for some nefarious reason.

I did a little checking and believe I have an explanation that is not nearly as nefarious and one which the actual data, rather than anecdotes, seems to support. Here is my reply to my mother, with some editing to make it a little more coherent.


Well, I call confirmation bias ;-) The article appears to presents facts in a misleading way to keep angry those that already are. Here is an alternative view that I got from reading his article and doing a little research.

The article buries the lede in a big way – the new regulations apply to ALL rigs, new and existing. [That is how I read the new rules. Existing wells have to supply an Application for Permit to Modify (APM). Maybe someone who is a real expert can help me. The fact remains that a lot of APMs have to be dealt with. RBG]

“Officials with the Bureau of Ocean Energy Management say they have issued many permits for work on existing shallow-water wells since April. They deny any effort to stall the approval of permits for new wells under drilling rules, called notices to lessees, issued in June.”

Catch that – existing wells.

The agency – BOEMRE, a brand new one by the way as the MMS is no longer – has to approve all of them. There are 45 new ones, from the article and almost 4000 active ones, which many if not all have to send in new forms (mostly one called NTL-05 which certifies the blowout preventer or NTL-06, which deals with blowout scenarios):


oil rigs gulf from NOAA

So, a new agency, whose rules did not even exist until the middle of June, has to deal with the approval of thousands of new forms. If there are 4000 existing wells and 45 new ones then one out a hundred of those forms will be for new wells. 99 out of a hundred will be for existing wells. And the author spends his time on the 1, not the 99.

Finally according to the agency’s website, – which is updated every business day – only 4 new shallow well requests have been pending since June 8 and one has been approved. So where are the other 40? The agency has approved 68 modified permits in shallow water since June 8 with only 3 pending.

The narrative of the article feels a little biased to me. I see no evidence of stalling or slowing down the approval process to prevent new wells.

I would call this another misleading MSM article. It presents information in a misleading way to keep people angry who already are angry, not to inform them.


I am not 100% sure just how many wells have to get new permits but it seems to me that the number is substantially greater than the number of new rigs. It makes sense that the agency is swamped with a lot of new permits that have to be examined. But there does not seem to be a huge number pending permits for shallow wells backed up in the system.
That is the real question I have. Why have so few new well permits even been submitted? The agency’s data does not show a backlog of submitted forms. The article implies it is the agency that is slowing stuff down but how can the agency approve permits that have not even been submitted?
I understand how government bureaucracy can slow stuff down. But in this case there was a horrible accident that killed 11 people, injured 17 and spilled a huge amount of oil into the Gulf doing billions in damage. A little bit of caution should be called for. Asking news wells to get the BOP certified and to provide a realistic scenario of how they would deal with a catastrophic failure seems like a reasonable thing to ask.

2 thoughts on “Message to my Mom III

  1. Not all of the permits are for NEW wells. Most os the trouble lies with permits for old wells. The main complaint is the permits for shallow wells that are in the Gulf. Some of them completed. All wells need to get new and/or different permits all of the time. That is why the process is backed up when the feds are demanding new and different permits all of the time for all wells. For example, most of the shallow wells have the BOPs on the deck of the rig. Therefore, they shouldn’t have to have the same permit that a deep rig makes. I thought the article made that clear. The government has so many layers of bureaucrats who don’t understand the difference.

    1. The permit that deals with BOP – NTL-05 – requires a one time certification that the operators are up to speed on current procedures for BOP operations, that they have reviewed all their equipment to make sure it is properly maintained, reviewed all their emergency procedures and properly trained everyone for the new standards. This matters for any BOP, whether deep ocean or not. I should think documentation that all BOP on the Gulf are actually properly maintained and up to spec would be a worthwhile government oversight. NTL-06 is for Exploration Plans and requires them to have a much more detailed description of how they would deal with blowout and worst-case scenarios.

      Both of those seem very reasonable to me, considering how unrealistic the scenarios were for the Deepwater Horizon and how poorly maintained the BOP was. When a bad player in an industry screws up, causing death and destruction, I think it is a reasonable thing not to take the word of all the other players but to get documentation that every single one of them specifically vouches for their veracity. It makes the lawsuits much clearer if they happen.

      The blame all seems to be on the government here when BP has a large part of the blame. If they had not been so incompetent, none of this would be going on. Making sure there are not any other bad players out there seems to be a good thing and something that should not be rushed.

      It does not appear that the agency is shutting down existing wells while waiting for approval. Is there any reason why applications for new wells – TL-06 – should get priority over existing wells? I would think that, if anything, the priority should be for existing.

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