The operator may submit the Operations Plan (a.k.a. surface use plan): (1) as part of the GDP application; or (2) by itself, prior to submitting a GDP application, by using a Sundry Notice (NEPA analysis and approval required before starting surface operations (see 43 CFR 3261 - Drilling Operations: Getting a Permit). This will allow the operator to begin the NEPA approval process earlier and begin surface preparations while the rest of the GDP application is prepared. Plan describes access to well location(s), size of drilling pad(s), environmental mitigation measures, etc.