Oil and Gas Management
Key Elements to Consider for Providing Assurance of Effective Independent Oversight Gao ID: GAO-10-852T June 17, 2010The catastrophic oil spill in the Gulf of Mexico has drawn national attention to the exploration and production of oil and gas from leases on federal lands and waters. The Department of the Interior's Bureau of Land Management (BLM) oversees onshore oil and gas activities, the Minerals Management Service's (MMS) Offshore Energy and Minerals Management oversees offshore oil and gas activities, and MMS's Minerals Revenue Management collects revenues from oil and gas produced. Interior's oil and gas oversight has long been the subject of audits and investigations by GAO, Interior's Office of Inspector General (OIG), and others. In response to the recent oil spill, the Secretary of the Interior has proposed reorganizing MMS. Over the past 5 years, GAO has issued numerous recommendations to the Secretary of the Interior to improve the agency's management of oil and gas resources--most recently resulting in two reports in March 2010. Overall, GAO's work in this area can be useful in evaluating key aspects of the Secretary's plans to reorganize MMS. In particular, GAO's findings and recommendations can provide guidance on how to achieve effective oversight of federal oil and gas management by improving (1) technical expertise in the agency, (2) performance of analyses and reviews, (3) enforcement of laws and regulations, (4) public access to information, and (5) the degree of independence in the agency.
Technical Expertise. Oil and gas production methods on federal lands and waters have become increasingly sophisticated over the past decade. GAO found in a March 2010 report that Interior had challenges in hiring, training, and retaining key staff, leading to questions about the technical capacity of Interior staff overseeing oil and gas activities. Interior's challenges partly stem from competition with the oil and gas industry, which can pay staff higher salaries. Moreover, key technical positions responsible for oversight of oil and gas activities have experienced high turnover rates, which, according to Interior officials, impede their capacity to oversee oil and gas activities. Ability to perform reviews and require that findings be addressed. In several recent reports, GAO found that Interior was unable to complete necessary reviews, including environmental and oil and gas production verification inspections, and had an ill-defined process for conducting certain offshore environmental analyses. For example, GAO reported in March 2010 that MMS faced challenges in Alaska conducting required environmental reviews, because although Interior policy directed MMS to prepare a handbook providing guidance on how to conduct these reviews, MMS lacked such a handbook. This lack of guidance also left unclear MMS's policy on what constitutes a significant environmental impact. Enforcement Authority. In a March 2010 review, GAO determined that in some instances, Interior was uncertain about its legal authority for undertaking potential necessary enforcement actions, and that Interior may be inconsistently using its enforcement authority. For example, staff from one BLM office told us that they were not issuing enforcement actions for unauthorized devices intended to modify gas flow upstream of the measurement meter--which may result in inaccurate measurement of gas production volumes. These staff explained that this was due to measurement regulations that were out of date. Public Access. In its preliminary results from ongoing work on public challenges to BLM's federal onshore oil and gas lease sale decisions in the four Mountain West states responsible for most federal oil and gas development, GAO found state-by-state variation in what protest-related information was made publicly available across BLM state offices. GAO also found that stakeholders, including industry groups and nongovernmental organizations representing environmental, recreational, and hunting interests, expressed frustration with the transparency and timeliness of the information. Independence. During GAO's work in 2009 and in Interior OIG reports in 2008 and 2010, several instances were identified where Interior staff had inappropriate relationships with oil and gas industry personnel, raising questions about whether Interior's oversight efforts were sufficient. The OIG found numerous instances of inappropriate contact between industry and Interior staff, including staff receipt of gifts.
GAO-10-852T, Oil and Gas Management: Key Elements to Consider for Providing Assurance of Effective Independent Oversight
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Testimony:
Before the Subcommittee on Energy and Mineral Resources, Committee on
Natural Resources, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
Thursday, June 17, 2010:
Oil And Gas Management:
Key Elements to Consider for Providing Assurance of Effective
Independent Oversight:
Statement of Frank Rusco, Director:
Natural Resources and the Environment:
GAO-10-852T:
GAO Highlights:
Highlights of GAO-10-852T, a testimony before the Subcommittee on
Energy and Mineral Resources, Committee on Natural Resources, House of
Representatives.
Why GAO Did This Study:
The catastrophic oil spill in the Gulf of Mexico has drawn national
attention to the exploration and production of oil and gas from leases
on federal lands and waters. The Department of the Interior‘s Bureau
of Land Management (BLM) oversees onshore oil and gas activities, the
Minerals Management Service‘s (MMS) Offshore Energy and Minerals
Management oversees offshore oil and gas activities, and MMS‘s
Minerals Revenue Management collects revenues from oil and gas
produced. Interior‘s oil and gas oversight has long been the subject
of audits and investigations by GAO, Interior‘s Office of Inspector
General (OIG), and others. In response to the recent oil spill, the
Secretary of the Interior has proposed reorganizing MMS.
Over the past 5 years, GAO has issued numerous recommendations to the
Secretary of the Interior to improve the agency‘s management of oil
and gas resources”most recently resulting in two reports in March 2010
(see appendix II for a list of GAO reports). Overall, GAO‘s work in
this area can be useful in evaluating key aspects of the Secretary‘s
plans to reorganize MMS. In particular, GAO‘s findings and
recommendations can provide guidance on how to achieve effective
oversight of federal oil and gas management by improving (1) technical
expertise in the agency, (2) performance of analyses and reviews, (3)
enforcement of laws and regulations, (4) public access to information,
and (5) the degree of independence in the agency.
What GAO Found:
Technical Expertise. Oil and gas production methods on federal lands
and waters have become increasingly sophisticated over the past
decade. GAO found in a March 2010 report that Interior had challenges
in hiring, training, and retaining key staff, leading to questions
about the technical capacity of Interior staff overseeing oil and gas
activities. Interior‘s challenges partly stem from competition with
the oil and gas industry, which can pay staff higher salaries.
Moreover, key technical positions responsible for oversight of oil and
gas activities have experienced high turnover rates, which, according
to Interior officials, impede their capacity to oversee oil and gas
activities.
Ability to perform reviews and require that findings be addressed. In
several recent reports, GAO found that Interior was unable to complete
necessary reviews, including environmental and oil and gas production
verification inspections, and had an ill-defined process for
conducting certain offshore environmental analyses. For example, GAO
reported in March 2010 that MMS faced challenges in Alaska conducting
required environmental reviews, because although Interior policy
directed MMS to prepare a handbook providing guidance on how to
conduct these reviews, MMS lacked such a handbook. This lack of
guidance also left unclear MMS‘s policy on what constitutes a
significant environmental impact.
Enforcement Authority. In a March 2010 review, GAO determined that in
some instances, Interior was uncertain about its legal authority for
undertaking potential necessary enforcement actions, and that Interior
may be inconsistently using its enforcement authority. For example,
staff from one BLM office told us that they were not issuing
enforcement actions for unauthorized devices intended to modify gas
flow upstream of the measurement meter”which may result in inaccurate
measurement of gas production volumes. These staff explained that this
was due to measurement regulations that were out of date.
Public Access. In its preliminary results from ongoing work on public
challenges to BLM‘s federal onshore oil and gas lease sale decisions
in the four Mountain West states responsible for most federal oil and
gas development, GAO found state-by-state variation in what protest-
related information was made publicly available across BLM state
offices. GAO also found that stakeholders, including industry groups
and nongovernmental organizations representing environmental,
recreational, and hunting interests, expressed frustration with the
transparency and timeliness of the information.
Independence. During GAO‘s work in 2009 and in Interior OIG reports in
2008 and 2010, several instances were identified where Interior staff
had inappropriate relationships with oil and gas industry personnel,
raising questions about whether Interior‘s oversight efforts were
sufficient. The OIG found numerous instances of inappropriate contact
between industry and Interior staff, including staff receipt of gifts.
View GAO-10-852T or key components. For more information, contact
Frank Rusco, 202-512-3841, Ruscof@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
We appreciate the opportunity to participate in this hearing to
discuss the Secretary of the Interior's proposal to reorganize the
Minerals Management Service (MMS) in response to the Deepwater Horizon
drilling rig disaster. The tragic loss of life, damage to natural
resources, loss of livelihoods, and harm to local economies that
resulted from the explosion, fire, and catastrophic oil spill in the
Gulf of Mexico have again drawn national attention to federal
oversight of exploration and production of oil and gas from federal
land and waters. Under the current organizational structure, the
Department of the Interior's bureaus are responsible for regulating
the processes that oil and gas companies must follow when leasing,
drilling, and producing oil and gas from federal leases as well as
ensuring that companies comply with all applicable requirements.
Specifically, the Bureau of Land Management (BLM) oversees onshore
federal oil and gas activities, and MMS's Offshore Energy and Minerals
Management (OEMM) oversees offshore oil and gas activities.
Additionally, MMS's Minerals Revenue Management (MRM) is responsible
for collecting royalties on oil and gas produced from both onshore and
offshore federal leases. In fiscal year 2009, Interior reported
collecting over $9 billion in royalties for oil and gas produced on
federal lands and waters, purchase bids for new oil and gas leases,
and annual rents on existing leases, making revenues from federal oil
and gas one of the largest nontax sources of federal government funds.
In recent years, we and others, including Interior's Office of
Inspector General (OIG) have conducted numerous evaluations of federal
oil and gas management and revenue collection processes and practices
and have found many material weaknesses (see app. II for related GAO
reports). Our work included reviews of Interior's oversight practices,
operations, and rules, and our conclusions have been remarkably
consistent: the agency has not done enough to meet the challenges it
faces. Others, including the Interior OIG and a panel of experts
convened by Interior have drawn similar conclusions. As a result,
Interior staff are in the midst of attempting to implement over 100
recommendations spanning the scope of the department's operations. We
acknowledge Interior's efforts to reassess key oil and gas policies
addressing revenue collection and rates of development on federal
lands and waters as an important first step to address material
weaknesses. In addition, the Secretary of the Interior announced
several changes to BLM's leasing process in May 2010.
Because of the recent announcement of the Secretary's proposed
reorganization, we have not conducted a detailed analysis of these
reorganization plans. However, our recent work on oil and gas
management as well as work in the area of strengthening independent
oversight of nuclear facilities and operations can be useful in
evaluating key aspects of the Secretary's plans to reorganize MMS. In
a 2008 report,[Footnote 1] we identified the following key elements
that any nuclear safety oversight organization should possess in order
to provide effective independent oversight:
* Technical expertise: The organization should have sufficient staff
with the expertise to perform sound safety assessments.
* Ability to perform reviews and require that findings be addressed:
The organization should have the working knowledge necessary to review
compliance with requirements, developed through periodic reviews, and
should also have sufficient authority to require the program offices
to effectively address its review findings and recommendations.
* Enforcement authority: The organization should have sufficient
authority to achieve compliance with requirements.
* Public access: The organization should provide public access to its
reports so that those most affected by operations can get information.
* Independence: The organization conducting oversight should be
structurally distinct and separate from the entities it oversees.
When coupled with findings and recommendations about the management of
federal oil and gas leases from our prior and ongoing work, these key
elements may provide the Secretary and Congress with a useful
framework for evaluating proposed reorganizations. While nuclear
safety differs from safety associated with offshore oil and gas
development, we believe there are similarities that make the key
elements applicable. Specifically, as has been made clear by the
recent oil spill disaster in the Gulf of Mexico, Interior is
responsible for overseeing an industry with potentially significant
impacts on workers, the environment, and vast areas of our oceans.
Further, as with nuclear safety, even small probability adverse events
can have significant and far-reaching effects.
My testimony today uses the five key elements for effective
independent oversight to broadly frame examples from our prior work on
the management of federal oil and gas activities issued from June 2005
through March 2010, as well as preliminary results from our ongoing
review on public challenges to federal onshore oil and gas leasing
decisions, to assist the committee as it considers changes to
Interior's oversight. We developed these preliminary results from June
2009 through June 2010 by reviewing federal laws, regulations, and
guidance; analyzing data from Interior on the four Mountain West
states (Colorado, New Mexico, Utah, and Wyoming) responsible for 69
percent of the oil and 94 percent of the natural gas produced on
federal lands during fiscal years 2007 to 2009;[Footnote 2] and
interviewing BLM officials and stakeholder groups--including
representatives from the energy industry, state government, and
nongovernmental organizations representing environmental, hunting,
fishing, and recreational interests. We conducted the performance
audit work that supports this statement in accordance with generally
accepted government auditing standards. Those standards require that
we plan and perform the audit to obtain sufficient, appropriate
evidence to produce a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the
evidence obtained provides a reasonable basis for our statement today.
Technical Expertise:
Agencies should have sufficient staff with the technical expertise to
oversee the activities under their authority. Oil and gas production
methods on federal lands and waters have become increasingly
sophisticated over the past decade. Additionally, oil and gas
companies now rely on information technology to manage and oversee
their operations. In a March 2010 review, we found that Interior had
challenges in hiring, training, and retaining staff in critical oil
and gas oversight roles, leading to questions about the technical
capacity of Interior staff overseeing oil and gas activities.
[Footnote 3]
* We found that Interior has faced difficulties in hiring, retaining,
and training staff in key oil and gas oversight positions.
Specifically, we found that staff within Interior's program for
verifying that oil and gas produced from federal leases are correctly
measured--including petroleum engineers and inspectors--lacked
critical skills because, according to agency officials, Interior 1)
has had difficulty in hiring experienced staff, 2) has struggled to
retain staff, and 3) has not consistently provided the appropriate
training for staff. Interior's challenges in hiring and retaining
staff stem, in part, from competition with the oil and gas industry,
which generally pays significantly more than the federal government.
Moreover, key technical positions responsible for oversight of oil and
gas activities have experienced high turnover rates, which, according
to Interior officials, impede these employees' capacity to oversee oil
and gas activities. These positions included petroleum engineers, who
process drilling permits and review oil and gas metering systems, and
inspection staff--including BLM's petroleum engineer technicians and
production accountability technicians onshore--who conduct drilling,
safety and oil and gas production verification inspections (see
appendix I). For example, we found that turnover rates for OEMM
inspectors at the four district offices we reviewed between 2004 and
2008 ranged from 27 to 44 percent. Furthermore, Interior has not
consistently provided training to the staff it has been able to hire
and retain. For example, neither onshore nor offshore petroleum
engineers had a requirement for training on the measurement of oil and
gas, which is critical to accurate royalty collections and can be
challenging at times because of such factors as the type of meter
used, the specific qualities of the gas or oil being measured, and the
rate of production. Additionally, although BLM offers a core
curriculum for its petroleum engineer technicians and requires that
they obtain official BLM certification and then be recertified once
every 5 years to demonstrate continued proficiency, the agency has not
offered a recertification course since 2002, negatively impacting its
ability to conduct inspections. It is important to note that BLM's
petroleum engineer technicians are the eyes and ears for the agency--
performing key functions and also perhaps the only Interior staff with
direct contact with the onshore lease property itself.
* We also found that Interior's efforts to provide its inspection
staff with mobile computing capabilities for use in the field are
moving slowly and are years from full implementation. Interior
inspectors continue to rely on documenting inspection results on
paper, and later reentering these results into Interior databases.
Specifically, Interior's BLM and OEMM are independently developing the
capacity for inspection staff to (1) electronically document
inspection results and (2) access reference documents, such as
American Petroleum Institute standards and measurement regulations,
via laptops while in the field. BLM initiated work on developing this
capacity in 2001, whereas OEMM is now in the preliminary planning
stages of a similar effort. According to Interior officials,
widespread implementation of a mobile computing tool to assist with
production verification and other types of inspections, potentially
including drilling and safety, are still several years away. Interior
officials said having such a tool would allow inspection staff to not
only easily reference technical documents while conducting inspections
to verify compliance with regulations but also to document the results
of those inspections while in the field and subsequently upload them
to Interior databases.
Ability to Perform Reviews and Require that Findings Be Addressed:
An effective oversight program should include a component for
systematic inspections and reviews, whose findings should be
documented and subsequently addressed. In several recent reviews, we
found that Interior had been unable to complete its necessary reviews,
including both environmental and oil and gas production verification
inspections and certain offshore environmental analyses.
* We found that Interior was unable to meet its goals for conducting
environmental and oil and gas production verification oversight
inspections because of a management focus on drilling. For example, in
June 2005,[Footnote 4] we reported that Interior devoted fewer
resources to completing onshore environmental inspections--inspections
to ensure that oil and gas companies are complying with various
environmental laws and lease stipulations. According to Interior
staff, one of the principal reasons was that management shifted
available resources to processing drilling permits. More recently, in
March 2010,[Footnote 5] we reported that Interior had only been able
to complete approximately one-third of the required onshore oil and
gas production verification inspections, raising concerns about the
accuracy of the oil and gas volumes reported to MRM.
* In another March 2010 report,[Footnote 6] we found that MMS faces
challenges in the Alaska Outer Continental Shelf (OCS) Region in
conducting reviews of oil and gas development under the National
Environmental Protection Act (NEPA), which requires MMS to evaluate
the likely environmental effects of proposed actions, including oil
and gas development.[Footnote 7] Although Interior policy directed its
agencies to prepare handbooks providing guidance on how to implement
NEPA, we found that MMS lacked such a handbook. The lack of
comprehensive guidance in a handbook, combined with high staff
turnover in recent years, left the process for meeting NEPA
requirements ill defined for the analysts charged with developing NEPA
documents. It also left unclear MMS's policy on what constitutes a
significant environmental impact as well as its procedures for
conducting and documenting NEPA-required analyses to address
environmental and cultural sensitivities, which have often been the
topic of litigation over Alaskan offshore oil and gas development. We
also found that the Alaska OCS Region shared information selectively,
a practice that was inconsistent with agency policy, which directed
that information, including proprietary data from industry, be shared
with all staff involved in environmental reviews. According to
regional MMS staff, this practice has hindered their ability to
complete sound environmental analyses under NEPA.
* In an August 2009 report examining Interior's royalty-in-kind (RIK)
program,[Footnote 8] we found that although MRM staff had made
progress in conducting reviews of gas imbalances--instances where
Interior may not be receiving the total amount of royalties due from
gas production--they were unable to determine the exact amount the
agency was owed for imbalances because it lacked certain key
information. For example, MRM did not verify production data to ensure
it received its entitled percentage of RIK gas from leases taken in
kind. Without these and other data, MRM staff were unable to quantify
revenues from imbalances, leading to forgone revenues and uncertainty
about how much gas the government is owed.
* Until recently, Interior has left key functions it oversees without
review for long periods. In two reports issued in 2008, we noted that
Interior received less in royalties and other payments for development
of its oil and gas resources than many other countries and that
Interior did less than other landowners to encourage development of
resources it leased for development. In a September 2008 report on
royalties and other payments,[Footnote 9] we found that Interior had
not done a comprehensive analysis of its royalty and other revenue
structure in over 25 years, and we recommended that it do so. In an
October 2008 report,[Footnote 10] we found that Interior had done less
than selected states and private landowners to encourage development
of oil and gas leases, and we recommended that it develop a strategy
to evaluate options to encourage faster development on federal lands.
Just this year, Secretary Salazar directed Interior to conduct studies
examining these issues. We are encouraged that Interior is undertaking
these efforts and hopeful that the findings of the studies will
identify opportunities to improve Interior's oversight of oil and gas
development.
Enforcement Authority:
Oversight entities must have the authority to ensure that all
regulated entities fully comply with the law and applicable
regulations. In our March 2010 report,[Footnote 11] we determined that
in some instances Interior is uncertain about its legal authority for
undertaking necessary enforcement actions and may be using its
enforcement authority inconsistently.
* We found that Interior had not determined the extent of its
authority over key elements of oil and gas production infrastructure
necessary for ensuring accurate measurement. This infrastructure
includes meters in (or after) gas plants, which may include the meter
where oil and gas are measured for royalties and meters owned by
pipeline companies. These companies frequently own, operate, and
maintain the meter used at the official measurement point on federal
leases and own the production data the meter generates. Because it did
not know the extent of its authority, Interior did not know what steps
it could take to enforce its standards and regulations for meters.
Thus it lacked assurances that royalty-bearing volumes of oil and gas
were correctly measured.
* We also found that Interior inspection staff were not, in all cases,
pursuing enforcement actions when they identified oil and gas
production activities not in compliance with its regulations.
Specifically, we found that some Interior staff were not issuing
incidents of non-compliance--a type of enforcement action--when they
identified certain measurement devices during the course of their
inspections, as they believe the current measurement regulations were
out of date. If staff do not uniformly ensure compliance with
regulations through specified procedures and document their findings,
Interior is at risk of not capturing data to know the full extent of
particular violations.
Public Access:
Organizations should make relevant information widely available to
ensure that those most affected by operations, including the public,
can fully participate in decision-making processes that can,
ultimately, have significant impacts. We recently found that Interior
has been providing inconsistent and limited information with respect
to its use of categorical exclusions in approving onshore oil and gas
activities. Also, in preliminary results from our ongoing work on
public challenges to BLM's federal onshore oil and gas lease sale
decisions, we found that BLM state offices provide limited and varying
amounts of information to the public on their leasing decisions.
* In September 2009, we found that BLM's use of categorical exclusions
was not fully transparent.[Footnote 12] In addressing long-term energy
challenges, Congress enacted the Energy Policy Act of 2005, in part to
expedite oil and gas development within the United States.[Footnote
13] This law authorizes BLM, for certain oil and gas activities, to
approve projects without preparing new environmental analyses that
would normally be required by NEPA. Section 390 of the Energy Policy
Act of 2005 does not specify procedures for involving or informing
either the public or other government agencies when section 390
categorical exclusions are used. According to Interior and BLM
officials, there is no requirement to publicly disclose that BLM used
a section 390 categorical exclusion to approve a project or to
disclose approved section 390 categorical exclusion decision
documents. Instead, the public depends on the discretion of each field
office for such disclosure. We found that BLM field offices had
different degrees and methods of disclosing information related to
decisions on section 390 categorical exclusions. For example, some
field offices, such as White River and Glenwood Springs, Colorado,
publicly disclosed online which Applications for Permit to Drill they
approved with section 390 categorical exclusions. In contrast, other
field offices, such as Price/Moab, Utah, and Pinedale, Wyoming, did
not publicly disclose their decisions to use section 390 categorical
exclusions and, in fact, required the public to file Freedom of
Information Act requests to identify which projects BLM approved using
section 390 categorical exclusions and to obtain copies of approved
section 390 categorical exclusion decision documents. In some cases,
it was difficult for other governmental agencies--including state
environmental agencies--and the public to determine whether BLM had
used a section 390 categorical exclusion until it was too late to
comment on or challenge BLM's action. When the public and other
federal and state agencies do not have a reliable or consistent way of
determining which projects have been approved with section 390
categorical exclusions, they lack a fundamental piece of information
needed to hold BLM accountable for their use.
* In preliminary results from our ongoing work on public challenges to
BLM's federal oil and gas lease sale decisions in the four Mountain
West states responsible for most onshore federal oil and gas
development, we found the extent to which BLM made publicly available
information related to public protests filed during the leasing
process varied by state and was generally limited in scope. We also
found that stakeholders--nongovernmental organizations representing
environmental, recreational, and hunting interests that filed protests
to BLM lease offerings--wanted additional time to participate in the
leasing process and more information from BLM about its leasing
decisions. In May 2010, the Secretary of the Interior announced
several agencywide leasing reforms that are to take place at BLM, some
of which may address concerns raised by these stakeholder groups. For
instance, BLM state offices are to provide an additional public review
and comment opportunity during the leasing process. They are also
required to post on their Web sites their responses to letters filed
in protest of state office decisions to offer specific parcels of land
for oil and gas development.
Independence:
The agency should be free from the direct and indirect influence of
the oil and gas industry. Our past work, as well as that of Interior's
OIG, has identified several instances where Interior staff had
inappropriate relationships with oil and gas industry personnel,
raising questions about whether Interior's oversight efforts were
sufficient.
* During the course of our audit work for our report on Interior's use
of categorical exclusions,[Footnote 14] allegations were made about
inappropriate relationships between Interior management and the oil
and gas industry. We referred these allegations to Interior's OIG,
which initiated an investigation. The results of the investigation
substantiated these inappropriate contacts, the details of which are
included in an Interior OIG investigative report.
* Additional reports by Interior's OIG have also identified instances
that call into question the independence of key staff working in
Interior's oil and gas program. In August 2008, Interior's OIG
reported on inappropriate relationships between staff working in
Interior's RIK program and the oil and gas industry.[Footnote 15]
Specifically, the OIG found that between 2002 and 2006 nearly one-
third of the RIK program staff socialized with and received a wide
array of gifts and gratuities from oil and gas companies with whom the
program was conducting official business. Most recently, in May 2010,
the OIG reported on inappropriate relationships between Interior's
offshore inspection staff and certain oil and gas companies operating
in the Gulf of Mexico.[Footnote 16] Interior's Acting Inspector
General stated that her greatest concern is the environment in which
these inspectors operate, particularly the ease with which they move
between industry and government.
In conclusion, over the past several years, we and others have found
Interior to be in need of fundamental reform. This past work has found
weaknesses across a wide range of Interior's oversight of onshore and
off shore oil and gas development. Secretary Salazar has taken notable
steps to begin comprehensive evaluations of leasing rules and
practices as well as the amount and ways in which the federal
government collects revenues. Interior is also currently implementing
a number of our recommendations aimed at making improvements within
the existing organization of Interior's functions.
As the Secretary and Congress consider what fundamental changes are
needed in how Interior structures its oversight of oil and gas
programs, we believe that our and others' past work provides a strong
rationale for broad reform of the agency's oil and gas oversight
functions--at MMS to be sure, but also across other parts of Interior,
including those responsible for oversight of onshore areas. If steps
are not taken to ensure effective independent oversight, we are
concerned about the agency's ability to manage the nation's oil and
gas resources, ensure the safe operation of onshore and offshore
leases, provide adequate environmental protection, and provide
reasonable assurance that the U.S. government is collecting the
revenue to which it is entitled. Reorganization and fundamental change
can be very difficult for an organization. Although we have not
conducted a detailed evaluation of Secretary Salazar's proposals for
reforming MMS, we believe that regardless of how MMS is ultimately
reorganized, Interior's top leadership must also address the wide
range of outstanding recommendations for any reorganization effort to
be effective.
Mr. Chairman, this completes my prepared statement. I would be happy
to respond to any questions that you or other Members of the
Subcommittee may have at this time.
GAO Contact and Staff Acknowledgment:
For further information on this statement, please contact Frank Rusco
at (202) 512-3841 or ruscof@gao.gov. Contact points for our
Congressional Relations and Public Affairs offices may be found on the
last page of this statement. Other staff that made key contributions
to this testimony include, Ron Belak, Dan Feehan, Glenn C. Fischer,
Jon Ludwigson, Ben Shouse, Kiki Theodoropoulos, and Barbara Timmerman.
[End of section]
Appendix I: Data on Turnover of Key Department of the Interior
Inspection Staff:
Table 1: Total Turnover Rates for Bureau of Land Management (BLM)
Petroleum Engineers, Fiscal Years 2004-2008:
Field office: Buffalo;
Turnover percentage FY2004-08: 80%;
Total number of employees in position, FY2004-08: 5;
Total employees leaving position, FY2004-08: 4;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 3;
2005: 1 of 2;
2006: 1 of 2;
2007: 0 of 2;
2008: 1 of 2;
Average number of employees in position, FY2004-08: 2.
Field office: Carlsbad;
Turnover percentage FY2004-08: 75%;
Total number of employees in position, FY2004-08: 4;
Total employees leaving position, FY2004-08: 3;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 1;
2005: 0 of 0;
2006: 1 of 1;
2007: 0 of 3;
2008: 1 of 3;
Average number of employees in position, FY2004-08: 2.
Field office: Farmington;
Turnover percentage FY2004-08: 50%;
Total number of employees in position, FY2004-08: 8;
Total employees leaving position, FY2004-08: 4;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 6;
2005: 0 of 6;
2006: 2 of 6;
2007: 0 of 5;
2008: 1 of 5;
Average number of employees in position, FY2004-08: 6.
Field office: Glenwood Springs;
Turnover percentage FY2004-08: 50%;
Total number of employees in position, FY2004-08: 2;
Total employees leaving position, FY2004-08: 1;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 0;
2005: 0 of 0;
2006: 0 of 1;
2007: 0 of 1;
2008: 1 of 1;
Average number of employees in position, FY2004-08: 1.
Field office: White River;
Turnover percentage FY2004-08: 100%;
Total number of employees in position, FY2004-08: 2;
Total employees leaving position, FY2004-08: 2;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 1;
2005: 1 of 1;
2006: 0 of 1;
2007: 0 of 1;
2008: 1 of 1;
Average number of employees in position, FY2004-08: 1.
Field office: Pinedale;
Turnover percentage FY2004-08: 100%;
Total number of employees in position, FY2004-08: 2;
Total employees leaving position, FY2004-08: 2;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 1;
2005: 0 of 1;
2006: 0 of 1;
2007: 1 of 2;
2008: 1 of 1;
Average number of employees in position, FY2004-08: 1.
Field office: Roswell;
Turnover percentage FY2004-08: 80%;
Total number of employees in position, FY2004-08: 5;
Total employees leaving position, FY2004-08: 4;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 5;
2005: 0 of 5;
2006: 2 of 5;
2007: 0 of 3;
2008: 2 of 3;
Average number of employees in position, FY2004-08: 4.
Field office: Vernal;
Turnover percentage FY2004-08: 33%;
Total number of employees in position, FY2004-08: 6;
Total employees leaving position, FY2004-08: 2;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 2;
2005: 2 of 3;
2006: 0 of 2;
2007: 0 of 2;
2008: 0 of 4;
Average number of employees in position, FY2004-08: 3.
Source: GAO analysis of Interior data.
Note: We calculated the total turnover rate by (1) counting the number
of individual petroleum engineers who separated from BLM, plus those
who changed locations, plus those who changed from the petroleum
engineer position to another position within that office; (2) dividing
that by the number of individual petroleum engineers employed in each
BLM office from fiscal years 2004 through 2008. For those individuals
who changed jobs or locations, we did not determine whether they
changed jobs or locations because of a management decision, as opposed
to the employees' own decision.
[End of table]
Table 2: Total Turnover Rates for BLM Petroleum Engineer Technicians,
Fiscal Years 2004-2008:
Field office: Buffalo;
Turnover percentage FY2004-08: 30%;
Total number of employees in position, FY2004-08: 20;
Total employees leaving position, FY2004-08: 6;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 12;
2005: 0 of 12;
2006: 2 of 13;
2007: 2 of 14;
2008: 1 of 15;
Average number of employees in position, FY2004-08: 13.
Field office: Carlsbad;
Turnover percentage FY2004-08: 47%;
Total number of employees in position, FY2004-08: 19;
Total employees leaving position, FY2004-08: 9;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 10;
2005: 1 of 9;
2006: 4 of 9;
2007: 1 of 10;
2008: 2 of 12;
Average number of employees in position, FY2004-08: 10.
Field office: Farmington;
Turnover percentage FY2004-08: 54%;
Total number of employees in position, FY2004-08: 37;
Total employees leaving position, FY2004-08: 20;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 22;
2005: 3 of 25;
2006: 7 of 24;
2007: 3 of 21;
2008: 6 of 22;
Average number of employees in position, FY2004-08: 23.
Field office: Glenwood Springs;
Turnover percentage FY2004-08: 67%;
Total number of employees in position, FY2004-08: 3;
Total employees leaving position, FY2004-08: 2;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 0;
2005: 0 of 0;
2006: 0 of 0;
2007: 0 of 2;
2008: 2 of 3;
Average number of employees in position, FY2004-08: 3.
Field office: Hobbs;
Turnover percentage FY2004-08: 22%;
Total number of employees in position, FY2004-08: 9;
Total employees leaving position, FY2004-08: 2;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 2 of 8;
2005: 0 of 6;
2006: 0 of 6;
2007: 0 of 6;
2008: 0 of 6;
Average number of employees in position, FY2004-08: 6.
Field office: White River;
Turnover percentage FY2004-08: 55%;
Total number of employees in position, FY2004-08: 11;
Total employees leaving position, FY2004-08: 6;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 2;
2005: 2 of 3;
2006: 0 of 1;
2007: 1 of 2;
2008: 2 of 7;
Average number of employees in position, FY2004-08: 3.
Field office: Pinedale;
Turnover percentage FY2004-08: 83%;
Total number of employees in position, FY2004-08: 12;
Total employees leaving position, FY2004-08: 10;
2004: 1 of 2;
2005: 1 of 6;
2006: 2 of 6;
2007: 3 of 5;
2008: 3 of 5;
Average number of employees in position, FY2004-08: 5.
Field office: Roswell;
Turnover percentage FY2004-08: 57%;
Total number of employees in position, FY2004-08: 7;
Total employees leaving position, FY2004-08: 4;
2004: 0 of 4;
2005: 0 of 4;
2006: 1 of 4;
2007: 1 of 4;
2008: 2 of 5;
Average number of employees in position, FY2004-08: 4.
Field office: Vernal;
Turnover percentage FY2004-08: 17%;
Total number of employees in position, FY2004-08: 18;
Total employees leaving position, FY2004-08: 3;
2004: 1 of 13;
2005: 1 of 14;
2006: 1 of 13;
2007: 0 of 15;
2008: 0 of 15;
Average number of employees in position, FY2004-08: 14.
Source: GAO analysis of Interior data.
Note: We calculated the total turnover rate by (1) counting the number
of individual petroleum engineer technicians who separated from BLM,
plus those who changed locations, plus those who changed from the
petroleum engineer technician position to another position within that
office; (2) dividing that by the number of individual petroleum
engineer technicians employed in each BLM office from fiscal years
2004 through 2008. For those individuals who changed jobs or
locations, we did not determine whether they changed jobs or locations
because of a management decision, as opposed to the employees' own
decision.
[End of table]
Table 3: Total Turnover Rates for BLM Production Accountability
Technicians, Fiscal Years 2004-2008:
Field office: Buffalo;
Turnover percentage FY2004-08: 75%;
Total number of employees in position, FY2004-08: 8;
Total employees leaving position, FY2004-08: 6;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 2;
2005: 0 of 2;
2006: 0 of 2;
2007: 3 of 4;
2008: 3 of 5;
Average number of employees in position, FY2004-08: 3.
Field office: Carlsbad;
Turnover percentage FY2004-08: 67%;
Total number of employees in position, FY2004-08: 3;
Total employees leaving position, FY2004-08: 2;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 1;
2005: 0 of 0;
2006: 0 of 0;
2007: 0 of 0;
2008: 1 of 2;
Average number of employees in position, FY2004-08: 2.
Field office: Farmington;
Turnover percentage FY2004-08: 63%;
Total number of employees in position, FY2004-08: 8;
Total employees leaving position, FY2004-08: 5;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 3;
2005: 1 of 4;
2006: 0 of 3;
2007: 2 of 5;
2008: 2 of 5;
Average number of employees in position, FY2004-08: 4.
Field office: Glenwood Springs;
Turnover percentage FY2004-08: 0;
Total number of employees in position, FY2004-08: 1;
Total employees leaving position, FY2004-08: 0;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 0;
2005: 0 of 0;
2006: 0 of 0;
2007: 0 of 1;
2008: 0 of 1;
Average number of employees in position, FY2004-08: 1.
Field office: Hobbs;
Turnover percentage FY2004-08: 50%;
Total number of employees in position, FY2004-08: 4;
Total employees leaving position, FY2004-08: 2;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 1;
2005: 0 of 2;
2006: 0 of 2;
2007: 2 of 4;
2008: 0 of 2;
Average number of employees in position, FY2004-08: 2.
Field office: White River;
Turnover percentage FY2004-08: 50%;
Total number of employees in position, FY2004-08: 2;
Total employees leaving position, FY2004-08: 1;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 0;
2005: 0 of 0;
2006: 0 of 0;
2007: 1 of 2;
2008: 0 of 1;
Average number of employees in position, FY2004-08: 2.
Field office: Pinedale;
Turnover percentage FY2004-08: 100%;
Total number of employees in position, FY2004-08: 3;
Total employees leaving position, FY2004-08: 3;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 0;
2005: 0 of 1;
2006: 0 of 1;
2007: 1 of 1;
2008: 2 of 2;
Average number of employees in position, FY2004-08: 1.
Field office: Roswell;
Turnover percentage FY2004-08: 100%;
Total number of employees in position, FY2004-08: 1;
Total employees leaving position, FY2004-08: 1;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 1;
2005: 0 of 0;
2006: 0 of 0;
2007: 0 of 0;
2008: 0 of 0;
Average number of employees in position, FY2004-08: 1.
Field office: Vernal;
Turnover percentage FY2004-08: 50%;
Total number of employees in position, FY2004-08: 2;
Total employees leaving position, FY2004-08: 1;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 1;
2005: 0 of 1;
2006: 0 of 1;
2007: 0 of 2;
2008: 0 of 2;
Average number of employees in position, FY2004-08: 1.
Source: GAO analysis of Interior data.
Note: We calculated the total turnover rate by (1) counting the number
of individual production accountability technicians who separated from
BLM, plus those who changed locations, plus those who changed from the
production accountability technicians to another position within that
office; (2) dividing that by the number of individual production
accountability technicians employed in each BLM office from fiscal
years 2004 through 2008. For those individuals who changed jobs or
locations, we did not determine whether they changed jobs or locations
because of a management decision, as opposed to the employees' own
decision.
[End of table]
Table 4: Total Turnover Rates for Offshore Energy and Minerals
Management (OEMM) Petroleum Engineers who Approve Measurement, Fiscal
Years 2004-2008:
Regional office: Gulf of Mexico region;
Turnover percentage FY2004-08: 30%;
Total number of employees in position, FY2004-08: 10;
Total employees leaving position, FY2004-08: 3;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 8;
2005: 1 of 7;
2006: 2 of 6;
2007: 0 of 7;
2008: 0 of 7;
Average number of employees in position, FY2004-08: 7.
Regional office: Pacific region;
Turnover percentage FY2004-08: 0;
Total number of employees in position, FY2004-08: 1;
Total employees leaving position, FY2004-08: 0;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 1;
2005: 0 of 1;
2006: 0 of 1;
2007: 0 of 1;
2008: 0 of 1;
Average number of employees in position, FY2004-08: 1.
Source: GAO analysis of Interior data.
Note: We calculated the total turnover rate by (1) counting the number
of individual petroleum engineers who separated from OEMM, plus those
who changed locations, plus those who changed from the petroleum
engineers to another position within that office; (2) dividing that by
the number of individual petroleum engineers employed in each OEMM
office from fiscal years 2004 through 2008. For those individuals who
changed jobs or locations, we did not determine whether they changed
jobs or locations because of a management decision, as opposed to the
employees' own decision.
[End of table]
Table 5: Total Turnover Rates for OEMM Inspectors, Fiscal Years 2004-
2008:
District office: New Orleans;
Turnover percentage FY2004-08: 42%;
Total number of employees in position, FY2004-08: 19;
Total employees leaving position, FY2004-08: 8;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 1 of 13;
2005: 0 of 13;
2006: 2 of 13;
2007: 3 of 14;
2008: 2 of 13;
Average number of employees in position, FY2004-08: 13.
District office: Lake Jackson;
Turnover percentage FY2004-08: 27%;
Total number of employees in position, FY2004-08: 11;
Total employees leaving position, FY2004-08: 3;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 9;
2005: 0 of 11;
2006: 2 of 11;
2007: 0 of 9;
2008: 1 of 9;
Average number of employees in position, FY2004-08: 10.
District office: Lake Charles;
Turnover percentage FY2004-08: 41%;
Total number of employees in position, FY2004-08: 17;
Total employees leaving position, FY2004-08: 7;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 2 of 15;
2005: 0 of 13;
2006: 0 of 13;
2007: 1 of 13;
2008: 4 of 14;
Average number of employees in position, FY2004-08: 14.
District office: California;
Turnover percentage FY2004-08: 44%;
Total number of employees in position, FY2004-08: 9;
Total employees leaving position, FY2004-08: 4;
Total employees leaving position, FY2004-08 (of the number employed in
that fiscal year):
2004: 0 of 7;
2005: 2 of 9;
2006: 0 of 7;
2007: 1 of 7;
2008: 1 of 6;
Average number of employees in position, FY2004-08: 7.
Source: GAO analysis of Interior data.
Note: We calculated the total turnover rate by (1) counting the number
of individual inspectors who separated from OEMM, plus those who
changed locations, plus those who changed from the inspectors to
another position within that office; (2) dividing that by the number
of individual inspectors employed in each OEMM office from fiscal
years 2004 through 2008. For those individuals who changed jobs or
locations, we did not determine whether they changed jobs or locations
because of a management decision, as opposed to the employees' own
decision.
[End of table]
[End of section]
Appendix II: Related Prior GAO Reports:
Oil and Gas Management: Interior's Oil and Gas Production Verification
Efforts Do Not Provide Reasonable Assurance of Accurate Measurement of
Production Volumes, [hyperlink,
http://www.gao.gov/products/GAO-10-313], (Washington, D.C.: Mar. 15,
2010).
Offshore Oil and Gas Development: Additional Guidance Would Help
Strengthen the Minerals Management Service's Assessment of
Environmental Impacts in the North Aleutian Basin, [hyperlink,
http://www.gao.gov/products/GAO-10-276], (Washington, D.C.: Mar. 8,
2010).
Energy Policy Act of 2005: Greater Clarity Needed to Address Concerns
with Categorical Exclusions for Oil and Gas Development under Section
390 of the Act, [hyperlink, http://www.gao.gov/products/GAO-09-872],
(Washington, D.C.: Sept. 26, 2009).
Federal Oil And Gas Management: Opportunities Exist to Improve
Oversight, [hyperlink, http://www.gao.gov/products/GAO-09-1014T],
(Washington, D.C.: Sept. 16, 2009).
Royalty-In-Kind Program: MMS Does Not Provide Reasonable Assurance It
Receives Its Share of Gas, Resulting in Millions in Forgone Revenue,
[hyperlink, http://www.gao.gov/products/GAO-09-744], (Washington,
D.C.: Aug. 14, 2009).
Mineral Revenues: MMS Could Do More to Improve the Accuracy of Key
Data Used to Collect and Verify Oil and Gas Royalties, [hyperlink,
http://www.gao.gov/products/GAO-09-549], (Washington, D.C.: July 15,
2009).
Strategic Petroleum Reserve: Issues Regarding the Inclusion of Refined
Petroleum Products as Part of the Strategic Petroleum Reserve,
[hyperlink, http://www.gao.gov/products/GAO-09-695T], (Washington,
D.C.: May 12, 2009).
Oil and Gas Management: Federal Oil and Gas Resource Management and
Revenue Collection In Need of Stronger Oversight and Comprehensive
Reassessment, [hyperlink, http://www.gao.gov/products/GAO-09-556T],
(Washington, D.C.: Apr. 2, 2009).
Oil and Gas Leasing: Federal Oil and Gas Resource Management and
Revenue Collection in Need of Comprehensive Reassessment, [hyperlink,
http://www.gao.gov/products/GAO-09-506T], (Washington, D.C.: Mar. 17,
2009).
Department of the Interior, Minerals Management Service: Royalty
Relief for Deepwater Outer Continental Shelf Oil and Gas Leases--
Conforming Regulations to Court Decision, [hyperlink,
http://www.gao.gov/products/GAO-09-102R], (Washington, D.C.: Oct. 21,
2008).
Oil and Gas Leasing: Interior Could Do More to Encourage Diligent
Development, [hyperlink, http://www.gao.gov/products/GAO-09-74],
(Washington, D.C.: Oct. 3, 2008).
Oil and Gas Royalties: MMS's Oversight of Its Royalty-in-Kind Program
Can Be Improved through Additional Use of Production Verification Data
and Enhanced Reporting of Financial Benefits and Costs, [hyperlink,
http://www.gao.gov/products/GAO-08-942R], (Washington, D.C.: Sept. 26,
2008).
Mineral Revenues: Data Management Problems and Reliance on Self-
Reported Data for Compliance Efforts Put MMS Royalty Collections at
Risk, [hyperlink, http://www.gao.gov/products/GAO-08-893R],
(Washington, D.C.: Sept. 12, 2008).
Oil and Gas Royalties: The Federal System for Collecting Oil and Gas
Revenues Needs Comprehensive Reassessment, [hyperlink,
http://www.gao.gov/products/GAO-08-691], (Washington, D.C.: Sept. 3,
2008).
Oil and Gas Royalties: Litigation over Royalty Relief Could Cost the
Federal Government Billions of Dollars, [hyperlink,
http://www.gao.gov/products/GAO-08-792R], (Washington, D.C.: June 5,
2008).
Strategic Petroleum Reserve: Improving the Cost-Effectiveness of
Filling the Reserve, [hyperlink,
http://www.gao.gov/products/GAO-08-726T], (Washington, D.C.: Apr. 24,
2008).
Mineral Revenues: Data Management Problems and Reliance on Self-
Reported Data for Compliance Efforts Put MMS Royalty Collections at
Risk, [hyperlink, http://www.gao.gov/products/GAO-08-560T],
(Washington, D.C.: Mar. 11, 2008).
Strategic Petroleum Reserve: Options to Improve the Cost-Effectiveness
of Filling the Reserve, [hyperlink,
http://www.gao.gov/products/GAO-08-521T], (Washington, D.C.: Feb. 26,
2008).
Oil and Gas Royalties: A Comparison of the Share of Revenue Received
from Oil and Gas Production by the Federal Government and Other
Resource Owners, [hyperlink, http://www.gao.gov/products/GAO-07-676R],
(Washington, D.C.: May 1, 2007).
Oil and Gas Royalties: Royalty Relief Will Cost the Government
Billions of Dollars but Uncertainty Over Future Energy Prices and
Production Levels Make Precise Estimates Impossible at this Time,
[hyperlink, http://www.gao.gov/products/GAO-07-590R], (Washington,
D.C.: Apr. 12, 2007).
Royalties Collection: Ongoing Problems with Interior's Efforts to
Ensure A Fair Return for Taxpayers Require Attention, [hyperlink,
http://www.gao.gov/products/GAO-07-682T], (Washington, D.C.: Mar. 28,
2007).
Oil and Gas Royalties: Royalty Relief Will Likely Cost the Government
Billions, but the Final Costs Have Yet to Be Determined, [hyperlink,
http://www.gao.gov/products/GAO-07-369T], (Washington, D.C.: Jan. 18,
2007).
Strategic Petroleum Reserve: Available Oil Can Provide Significant
Benefits, but Many Factors Should Influence Future Decisions about
Fill, Use, and Expansion, [hyperlink,
http://www.gao.gov/products/GAO-06-872], (Washington, D.C.: Aug. 24,
2006).
Royalty Revenues: Total Revenues Have Not Increased at the Same Pace
as Rising Oil and Natural Gas Prices due to Decreasing Production
Sold, [hyperlink, http://www.gao.gov/products/GAO-06-786R],
(Washington, D.C.: June 21, 2006).
Oil and Gas Development: Increased Permitting Activity Has Lessened
BLM's Ability to Meet Its Environmental Protection Responsibilities,
[hyperlink, http://www.gao.gov/products/GAO-05-418], (Washington,
D.C.: June 17, 2005).
Mineral Revenues: Cost and Revenue Information Needed to Compare
Different Approaches for Collecting Federal Oil and Gas Royalties,
[hyperlink, http://www.gao.gov/products/GAO-04-448], (Washington,
D.C.: Apr. 16, 2004).
[End of section]
Footnotes:
[1] GAO, Nuclear Safety: Department of Energy Needs to Strengthen Its
Independent Oversight of Nuclear Facilities and Operations,
[hyperlink, http://www.gao.gov/products/GAO-09-61] (Washington, D.C.:
Oct. 23, 2008). We developed these elements based on a long history of
reviewing nuclear safety at DOE and supporting independent oversight
and through our work with outside nuclear safety experts.
[2] We assessed the reliability of these data and found them to be
sufficiently reliable for our purposes.
[3] GAO, Oil and Gas Management: Interior's Oil and Gas Production
Verification Efforts Do Not Provide Reasonable Assurance of Accurate
Measurement of Production Volumes, [hyperlink,
http://www.gao.gov/products/GAO-10-313] (Washington, D.C.: Mar. 15,
2010).
[4] GAO, Oil and Gas Development: Increased Permitting Activity Has
Lessened BLM's Ability to Meet Its Environmental Protection
Responsibilities, [hyperlink, http://www.gao.gov/products/GAO-05-418],
(Washington, D.C.: June 17, 2005).
[5] [hyperlink, http://www.gao.gov/products/GAO-10-313].
[6] GAO, Offshore Oil and Gas Development: Additional Guidance Would
Help Strengthen the Minerals Management Service's Assessment of
Environmental Impacts in the North Aleutian Basin, [hyperlink,
http://www.gao.gov/products/GAO-10-276], (Washington, D.C.: Mar. 8,
2010).
[7] Pub. L. No. 91-190, 83 Stat. 852 (1970).
[8] GAO, Royalty-in-Kind Program: MMS Does Not Provide Reasonable
Assurance It Receives Its Share of Gas, Resulting in Millions in
Forgone Revenue, [hyperlink, http://www.gao.gov/products/GAO-09-744],
(Washington, D.C.: Aug. 14, 2009).
[9] GAO, Oil and Gas Royalties: The Federal System for Collecting Oil
and Gas Revenues Needs Comprehensive Reassessment, [hyperlink,
http://www.gao.gov/products/GAO-08-691], (Washington, D.C.: Sept. 3,
2008).
[10] GAO, Oil and Gas Leasing: Interior Could Do More to Encourage
Diligent Development, [hyperlink,
http://www.gao.gov/products/GAO-09-74], (Washington, D.C.: Oct. 3,
2008).
[11] [hyperlink, http://www.gao.gov/products/GAO-10-313].
[12] GAO, Energy Policy Act of 2005: Greater Clarity Needed to Address
Concerns with Categorical Exclusions for Oil and Gas Development under
Section 390 of the Act, [hyperlink,
http://www.gao.gov/products/GAO-09-872], (Washington, D.C.: Sept. 26,
2009).
[13] Pub. L. No. 109-58, 119 Stat. 594 (2005).
[14] [hyperlink, http://www.gao.gov/products/GAO-09-872].
[15] Interior OIG, Investigative Report: Oil Marketing Group -
Lakewood (Washington, D.C.: Aug. 19, 2008).
[16] Interior OIG, Investigative Report: Island Operating Company et
al (Washington, D.C.: Mar. 31, 2010).
[End of section]
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