Oil and Gas Leasing
Past Work Identifies Numerous Challenges with Interior's Oversight
Gao ID: GAO-11-487T March 17, 2011
The Department of the Interior oversees oil and gas activities on leased federal lands and waters. Revenue generated from federal oil and gas production is one of the largest nontax sources of federal government funds, accounting for about $9 billion in fiscal year 2009. For onshore leases, Interior's Bureau of Land Management (BLM) has oversight responsibilities. For offshore leases, the newly created Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE), has oversight responsibilities. Prior to BOEMRE, the Minerals Management Service's (MMS) Offshore Energy and Minerals Management Office oversaw offshore oil and gas activities, while MMS's Minerals Revenue Management Office collected revenues from all oil and gas produced on federal leases. Over the past several years, GAO has issued numerous recommendations to the Secretary of the Interior to improve the agency's management of oil and gas resources. In 2011, GAO identified Interior's management of oil and gas resources as a high risk issue. GAO's work in this area identified challenges in five areas: (1) reorganization, (2) balancing responsibilities, (3) human capital, (4) revenue collection, and (5) development of existing leases.
Reorganization: Interior's reorganization of activities previously overseen by MMS will require time and resources and may pose new challenges. Interior began a reorganization in May 2010 that will divide MMS into three separate bureaus--one focusing on revenue collection, another on leasing and environmental reviews, and yet another on permitting and inspections. While this reorganization may eventually lead to more effective operations, GAO has reported that organizational transformations are not simple endeavors. GAO is concerned with Interior's ability to undertake this reorganization while meeting its revenue collection and oil and gas oversight responsibilities. Balancing Responsibilities: GAO has reported that Interior has experienced several challenges with meeting its responsibilities for providing for the development of oil and gas resources while managing public lands for other uses, including wildlife habitat. In January 2010, GAO reported that, while BLM requires oil and gas operators to reclaim the land they disturb and post a bond to help ensure they do so, not all operators perform reclamation. For fiscal years 1988 through 2009, BLM spent about $3.8 million to reclaim 295 so-called "orphaned" wells--because reclamation had not been done, and other resources, including the bond, were insufficient to pay for it. Human Capital: GAO has reported that BLM and MMS have encountered persistent problems in hiring, training, and retaining sufficient staff to meet their oversight and management responsibilities for oil and gas operations. For example, in March 2010, GAO reported that BLM and MMS experienced high turnover rates in key oil and gas inspection and engineering positions responsible for production verification activities. As a result, Interior faces challenges meeting its responsibilities to oversee oil and gas development on federal leases, potentially placing both the environment and royalties at risk. Revenue Collection: While federal oil and gas resources generate billions of dollars in annual revenues, past GAO work has found that Interior may not be properly assessing and collecting these revenues. In September 2008, GAO reported that Interior collected lower levels of revenues for oil and gas production in the deep water of the U.S. Gulf of Mexico than all but 11 of 104 oil and gas resource owners whose revenue collection systems were evaluated in a comprehensive industry study. Nonetheless, Interior has not completed a comprehensive assessment of its revenue collection policies and processes in over 25 years. Additionally, in March 2010, GAO reported that Interior was not consistently completing inspections to verify volumes of oil and gas produced from federal leases. Development of Existing Leases: In October 2008, GAO reported that Interior could do more to encourage the development of existing oil and gas leases. Federal leases contain one provision--increasing rental rates over time for offshore 5-year leases and onshore leases--to encourage development. In addition to escalating rental rates, states undertake additional efforts to encourage lessees to develop oil and gas leases more quickly, including shorter lease terms and graduated royalty rates.
GAO-11-487T, Oil and Gas Leasing: Past Work Identifies Numerous Challenges with Interior's Oversight
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United States Government Accountability Office:
GAO:
Testimony:
Before the Committee on Natural Resources, House of Representatives:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
March 17, 2011:
Oil And Gas Leasing:
Past Work Identifies Numerous Challenges with Interior's Oversight:
Statement of Frank Rusco, Director:
Natural Resources and Environment:
GAO-11-487T:
GAO Highlights:
Highlights of GAO-11-487T, a testimony before the Committee on Natural
Resources, House of Representatives.
Why GAO Did This Study:
The Department of the Interior oversees oil and gas activities on
leased federal lands and waters. Revenue generated from federal oil
and gas production is one of the largest nontax sources of federal
government funds, accounting for about $9 billion in fiscal year 2009.
For onshore leases, Interior‘s Bureau of Land Management (BLM) has
oversight responsibilities. For offshore leases, the newly created
Bureau of Ocean Energy Management, Regulation, and Enforcement
(BOEMRE), has oversight responsibilities. Prior to BOEMRE, the
Minerals Management Service‘s (MMS) Offshore Energy and Minerals
Management Office oversaw offshore oil and gas activities, while MMS‘s
Minerals Revenue Management Office collected revenues from all oil and
gas produced on federal leases.
Over the past several years, GAO has issued numerous recommendations
to the Secretary of the Interior to improve the agency‘s management of
oil and gas resources. In 2011, GAO identified Interior‘s management
of oil and gas resources as a high risk issue. GAO‘s work in this area
identified challenges in five areas: (1) reorganization, (2) balancing
responsibilities, (3) human capital, (4) revenue collection, and (5)
development of existing leases.
What GAO Found:
Reorganization: Interior‘s reorganization of activities previously
overseen by MMS will require time and resources and may pose new
challenges. Interior began a reorganization in May 2010 that will
divide MMS into three separate bureaus”one focusing on revenue
collection, another on leasing and environmental reviews, and yet
another on permitting and inspections. While this reorganization may
eventually lead to more effective operations, GAO has reported that
organizational transformations are not simple endeavors. GAO is
concerned with Interior‘s ability to undertake this reorganization
while meeting its revenue collection and oil and gas oversight
responsibilities.
Balancing Responsibilities: GAO has reported that Interior has
experienced several challenges with meeting its responsibilities for
providing for the development of oil and gas resources while managing
public lands for other uses, including wildlife habitat. In January
2010, GAO reported that, while BLM requires oil and gas operators to
reclaim the land they disturb and post a bond to help ensure they do
so, not all operators perform reclamation. For fiscal years 1988
through 2009, BLM spent about $3.8 million to reclaim 295 so-called
’orphaned“ wells”because reclamation had not been done, and other
resources, including the bond, were insufficient to pay for it.
Human Capital: GAO has reported that BLM and MMS have encountered
persistent problems in hiring, training, and retaining sufficient
staff to meet their oversight and management responsibilities for oil
and gas operations. For example, in March 2010, GAO reported that BLM
and MMS experienced high turnover rates in key oil and gas inspection
and engineering positions responsible for production verification
activities. As a result, Interior faces challenges meeting its
responsibilities to oversee oil and gas development on federal leases,
potentially placing both the environment and royalties at risk.
Revenue Collection: While federal oil and gas resources generate
billions of dollars in annual revenues, past GAO work has found that
Interior may not be properly assessing and collecting these revenues.
In September 2008, GAO reported that Interior collected lower levels
of revenues for oil and gas production in the deep water of the U.S.
Gulf of Mexico than all but 11 of 104 oil and gas resource owners
whose revenue collection systems were evaluated in a comprehensive
industry study. Nonetheless, Interior has not completed a
comprehensive assessment of its revenue collection policies and
processes in over 25 years. Additionally, in March 2010, GAO reported
that Interior was not consistently completing inspections to verify
volumes of oil and gas produced from federal leases.
Development of Existing Leases: In October 2008, GAO reported that
Interior could do more to encourage the development of existing oil
and gas leases. Federal leases contain one provision”increasing rental
rates over time for offshore 5-year leases and onshore leases”to
encourage development. In addition to escalating rental rates, states
undertake additional efforts to encourage lessees to develop oil and
gas leases more quickly, including shorter lease terms and graduated
royalty rates.
View [hyperlink, http://www.gao.gov/products/GAO-11-487T] or key
components. For more information, contact Frank Rusco at (202) 512-
3841, or ruscof@gao.gov.
[End of section]
Chairman Hastings, Ranking Member Markey, and Members of the Committee:
We appreciate the opportunity to participate in this hearing to
discuss domestic oil and gas production in light of rising gas prices
and the country's continued employment challenges. American families,
communities, and businesses all depend on reliable and affordable
energy for their health, safety, and livelihoods. Energy--including
oil and gas--is crucial to many aspects of peoples' daily lives,
including transportation, communication, food production, medical
services, and heating and air-conditioning. Since December 2010, oil
prices have been increasing, topping $100 per barrel in recent weeks.
The most recent spike in oil prices has been attributed to political
unrest in the Middle East--a major exporter of oil. In part because
the United States currently imports approximately 51 percent of its
oil each year for domestic consumption, many have called for
increasing domestic production of oil and gas, including from
resources located on leased federal lands and waters. Currently, oil
produced from federal offshore leases accounts for approximately 30
percent of all domestic production, while oil produced from federal
onshore leases accounts for approximately 6 percent. Oil and gas
produced from federal leases is also an important source of revenue
for the federal government. In fiscal year 2009, the federal
government collected more than $9 billion in revenues from oil and gas
produced from federal lands and waters, purchase bids for new oil and
gas leases, and annual rents on existing leases. This makes revenues
from federal oil and gas one of the largest nontax sources of federal
government funds.
The U.S. Department of the Interior plays an important role in
managing and providing oversight of federal oil and gas resources. The
explosion onboard the Deepwater Horizon drilling rig and subsequent
fire and catastrophic oil spill in the Gulf of Mexico in April 2010
further emphasized the importance of Interior's management of
permitting and inspection processes to ensure operational and
environmental safety. Under its current organizational structure,
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. The bureaus are also
responsible for ensuring that companies comply with all applicable
requirements. Specifically, Interior's Bureau of Land Management (BLM)
oversees onshore federal oil and gas activities; the Bureau of Ocean
Energy Management, Regulation, and Enforcement (BOEMRE)--created in
May 2010--oversees offshore oil and gas activities; and the newly
established Office of Natural Resources Revenue (ONRR) is responsible
for collecting royalties on oil and gas produced from both onshore and
offshore federal leases. Prior to the creation of BOEMRE, the now-
abolished Minerals Management Service's (MMS) was charged with
administering offshore federal leases and managing the collection of
royalties for onshore and offshore leases; MMS's Offshore Energy and
Minerals Management (OEMM) oversaw offshore oil and gas activities,
while its Minerals Revenue Management (MRM) was responsible for
royalty collections from both onshore and offshore federal leases.
Interior's management of federal oil and gas activities is critically
important and has been a focus of a large body of our work that has
found numerous weaknesses and challenges that need to be addressed. In
response to our recommendations, Interior has taken steps to address
material weaknesses and modify its practices for managing oil and gas
resources, but as of December 2010, many recommendations remained
unimplemented. Accordingly, we designated Interior's management of
federal oil and gas resources as a high risk issue in February 2011.
[Footnote 1]
In this context, my testimony today discusses findings from our past
work on five broad areas: (1) the ongoing reorganization of Interior's
bureaus dealing with oil and gas functions, (2) the challenges
Interior faces balancing timely and efficient oil and gas development
with environmental stewardship responsibilities, (3) Interior's
management of human capital, (4) Interior's collection of oil and gas
revenues, and (5) Interior's role in the development of existing
leases. This statement is based on our extensive body of work on
Interior's oil and gas leasing and royalty collection programs issued
from September 2008 through February 2011. 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.
Additional information on our scope and methodology is available in
each issued product.
Potential Challenges with Reorganization of Oil and Gas Functions:
Interior's ongoing reorganization of bureaus with oil and gas
functions will require time and resources, and undertaking such an
endeavor while continuing to meet ongoing responsibilities may pose
new challenges. Historically, BLM managed onshore federal oil and gas
activities, while MMS managed offshore activities and collected
royalties for all leases. In May 2010, the Secretary of the Interior
announced plans to reorganize MMS into three separate bureaus. The
Secretary stated that dividing MMS's responsibilities among separate
bureaus would help ensure that each of the three newly established
bureaus have a distinct and independent mission. Interior recently
began implementing this restructuring effort, transferring offshore
oversight responsibilities to the newly created BOEMRE and revenue
collection to ONRR. Interior plans to continue restructuring BOEMRE to
establish two additional separate bureaus--the Bureau of Ocean and
Energy Management, which will focus on leasing and environmental
reviews, and the Bureau of Safety and Environmental Enforcement, which
will focus on permitting and inspection functions.
While this reorganization may eventually lead to more effective
operations, we have reported that organizational transformations are
not simple endeavors and require the concentrated efforts of both
leaders and employees to realize intended synergies and accomplish new
organizational goals.[Footnote 2] In that report, we stated that for
effective organizational transformation, top leaders must balance
continued delivery of services with transformational activities. Given
that, as of December 2010, Interior had not implemented many
recommendations we made to address numerous weaknesses and challenges,
we are concerned about Interior's ability to undertake this
reorganization while (1) providing reasonable assurance that billions
of dollars of revenues owed to the public are being properly assessed
and collected and (2) maintaining focus on its oil and gas oversight
responsibilities.
Challenges of Balancing Oil and Gas Development with Environmental
Stewardship:
We have reported that Interior has experienced several challenges in
meeting its obligations to make federal oil and gas resources
available for leasing and development while simultaneously meeting its
responsibilities for managing public lands for other uses, including
wildlife habitat, recreation, and wilderness. In January 2010, we
reported that while BLM requires oil and gas operators to reclaim the
land they disturb and post a bond to help ensure they do so, not all
operators perform such reclamation.[Footnote 3] In general, the goal
is to plug the well and reclaim the site so that it matches the
surrounding natural environment to the extent possible, allowing the
land to be used for purposes other than oil and gas production, such
as wildlife habitat. If the bond is not sufficient to cover well
plugging and surface reclamation, and there are no responsible or
liable parties, the well is considered "orphaned," and BLM uses
federal dollars to fund reclamation. For fiscal years 1988 through
2009, BLM spent about $3.8 million to reclaim 295 orphaned wells, and
BLM has identified another 144 wells yet to be reclaimed.
In addition, in a July 2010 report on federal oil and gas lease sale
decisions in the Mountain West, we found that the extent to which BLM
tracked and made available to the public information related to
protests filed during the leasing process varied by state and was
generally limited in scope.[Footnote 4] We also found that
stakeholders--including environmental and hunting interests, and state
and local governments protesting BLM lease offerings--wanted
additional time to participate in the leasing process and more
information from BLM about its leasing decisions. Moreover, we found
that BLM had been unable to manage an increased workload associated
with public protests and had missed deadlines for issuing leases. In
May 2010, the Secretary of the Interior announced several
departmentwide leasing reforms that are to take place at BLM that may
address these concerns, such as providing additional public review and
comment opportunity during the leasing process.
Further, in March 2010, we found that Interior faced challenges in
ensuring consistent implementation of environmental requirements, both
within and across MMS's regional offices, leaving it vulnerable with
regard to litigation and allegations of scientific
misconduct.[Footnote 5] We recommended that Interior develop
comprehensive environmental guidance materials for MMS staff. Interior
concurred with this recommendation and is currently developing such
guidance.
Finally, in September 2009, we reported that BLM's use of categorical
exclusions under Section 390 of the Energy Policy Act of 2005--which
authorized BLM, for certain oil and gas activities, to approve
projects without preparing new environmental analyses that would
normally be required in accordance with the National Environmental
Policy Act--was frequently out of compliance with the law and BLM's
internal guidance.[Footnote 6] As a result, we recommended that BLM
take steps to improve the implementation of Section 390 categorical
exclusions through clarification of its guidance, standardizing
decision documents, and increasing oversight.
Human Capital Challenges:
We have reported that BLM and MMS have encountered persistent problems
in hiring, training, and retaining sufficient staff to meet Interior's
oversight and management responsibilities for oil and gas operations
on federal lands and waters. For example, in March 2010, we reported
that BLM and MMS experienced high turnover rates in key oil and gas
inspection and engineering positions responsible for production
verification activities.[Footnote 7] As a result, Interior faces
challenges meeting its responsibilities to oversee oil and gas
development on federal leases, potentially placing both the
environment and royalties at risk. We made a number of recommendations
to address these issues. While Interior's reorganization of MMS
includes plans to hire additional staff with expertise in oil and gas
inspections and engineering, these plans have not been fully
implemented, and it remains unclear whether Interior will be fully
successful in hiring, training, and retaining these additional staff.
Moreover, the human capital issues we identified with BLM's management
of onshore oil and gas continue, and these issues have not yet been
addressed in Interior's reorganization plans.
Concerns over Revenue Collection:
Federal oil and gas resources generate billions of dollars annually in
revenues that are shared among federal, state, and tribal governments;
however, we found Interior may not be properly assessing and
collecting these revenues. In September 2008, we reported that
Interior collected lower levels of revenues for oil and gas production
in the deep water of the U.S. Gulf of Mexico than all but 11 of 104
oil and gas resource owners whose revenue collection systems were
evaluated in a comprehensive industry study--these resource owners
included other countries as well as some states.[Footnote 8] However,
despite significant changes in the oil and gas industry over the past
several decades, we found that Interior had not systematically re-
examined how the U.S. government is compensated for extraction of oil
and gas for over 25 years. GAO recommended Interior conduct a
comprehensive review of the federal oil and gas system using an
independent panel. After Interior initially disagreed with our
recommendations, we recommended that Congress consider directing the
Secretary of the Interior to convene an independent panel to perform a
comprehensive review of the federal system for collecting oil and gas
revenue. More recently, in response to our report, Interior has
commissioned a study that will include such a reassessment, which,
according to officials, the department expects will be complete in
2011. The results of the study may reveal the potential for greater
revenues to the federal government.
We also reported in March 2010 that Interior was not taking the steps
needed to ensure that oil and gas produced from federal lands was
accurately measured.[Footnote 9] For example, we found that neither
BLM nor MMS had consistently met their agency goals for oil and gas
production verification inspections. Without such verification,
Interior cannot provide reasonable assurance that the public is
collecting its share of revenue from oil and gas development on
federal lands and waters. As a result of this work, we identified 19
recommendations for specific improvements to oversight of production
verification activities. Interior generally agreed with our
recommendations and has begun implementing some of them.
Additionally, we reported in October 2010 that Interior's data likely
underestimated the amount of natural gas produced on federal leases,
because some unquantified amount of gas is released directly to the
atmosphere (vented) or is burned (flared).[Footnote 10] This vented
and flared gas contributes to greenhouse gases and represents lost
royalties. We recommended that Interior improve its data and address
limitations in its regulations and guidance to reduce this lost gas.
Interior generally agreed with our recommendations and is taking
initial steps to implement these recommendations.
Furthermore, we reported in July 2009 on numerous problems with
Interior's efforts to collect data on oil and gas produced on federal
lands, including missing data, errors in company-reported data on oil
and gas production, and sales data that did not reflect prevailing
market prices for oil and gas.[Footnote 11] As a result of Interior's
lack of consistent and reliable data on the production and sale of oil
and gas from federal lands, Interior could not provide reasonable
assurance that it was assessing and collecting the appropriate amount
of royalties on this production. We made a number of recommendations
to Interior to improve controls on the accuracy and reliability of
royalty data. Interior generally agreed with our recommendations and
is working to implement many of them, but these efforts are not
complete, and it is uncertain at this time if the efforts will fully
address our concerns.
Development of Existing Leases:
In October 2008, we reported that Interior could do more do encourage
the development of existing oil and gas leases.[Footnote 12] Our
review of Interior oil and gas leasing data from 1987 through 2006
found that the number of leases issued had generally increased toward
the end of this period, but that offshore and onshore leasing had
followed different historical patterns. Offshore leases issued peaked
in 1988 and in 1997, and generally rose from 1999 through 2006.
Onshore leases issued peaked in 1988, then rapidly declined until
about 1992, and remained at a consistently low level until about 2003,
when they began to increase moderately. We also analyzed 55,000
offshore and onshore leases issued from 1987 through 1996 to determine
how development occurred on leases that had expired or been extended
beyond their primary terms. Our analysis identified three key
findings. First, a majority of leases expired without being drilled or
reaching production. Second, shorter leases were generally developed
more quickly than longer leases but not necessarily at comparable
rates. Third, a substantial percentage of leases were drilled after
the initial primary term following a lease extension or suspension.
We also compared Interior's efforts to encourage development of
federal oil and gas leases to states' and private landowners' efforts.
We found that Interior does less to encourage development of federal
leases than some states and private landowners. Federal leases contain
one provision--increasing rental rates over time for offshore 5-year
leases and onshore leases--to encourage development. In addition to
using increasing rental rates, some states undertake additional
efforts to encourage lessees to develop oil and gas leases more
quickly, including shorter lease terms and graduated royalty rates--
royalty rates that rise over the life of the lease. In addition,
compared to limited federal efforts, some states do more to structure
leases to reflect the likelihood of oil and gas production, which may
also encourage faster development. Based on the limited information
available on private leases, private landowners also use tools similar
to states to encourage development.
In conclusion, as concerns rise over the recent increase in oil prices
and as demands are made for additional drilling on federal lands and
waters, it is important that Interior meet its current oversight
responsibilities. Interior is now in the midst of a major
reorganization, which makes balancing delivery of services with
transformational activities challenging for an organization. Managing
this change in a fiscally constrained environment only exacerbates the
challenge. If steps are not taken to improve Interior's oversight of
oil and gas leasing, we are concerned about the department'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.
Chairman Hastings, Ranking Member Markey, and Members of the
Committee, this concludes our prepared statement. We would be pleased
to answer any questions that you or other Members of the Committee may
have at this time.
Contact and Staff Acknowledgments:
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, Jeffrey Barron, Glenn C. Fischer, Jon
Ludwigson, Alison O'Neil, Kiki Theodoropoulos, and Barbara Timmerman.
[End of section]
Footnotes:
[1] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: February
2011).
[2] GAO, Results-Oriented Cultures: Implementation Steps to Assist
Mergers and Organizational Transformations, [hyperlink,
http://www.gao.gov/products/GAO-03-669] (Washington, D.C.: July 2,
2003).
[3] GAO, Oil and Gas Bonds: Bonding Requirements and BLM Expenditures
to Reclaim Orphaned Wells, [hyperlink,
http://www.gao.gov/products/GAO-10-245] (Washington, D.C.: Jan. 27,
2010).
[4] GAO, Onshore Oil and Gas: BLM's Management of Public Protests to
Its Lease Sales Needs Improvement, [hyperlink,
http://www.gao.gov/products/GAO-10-670] (Washington, D.C.: July 30,
2010).
[5] 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).
[6] 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.16,
2009).
[7] 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).
[8] 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).
[9] 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).
[10] GAO, Federal Oil and Gas Leases: Opportunities Exist to Capture
Vented and Flared Natural Gas, Which Would Increase Royalty Payments
and Reduce Greenhouse Gases, [hyperlink,
http://www.gao.gov/products/GAO-11-34] (Washington, D.C.: Oct. 29,
2010).
[11] GAO, 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).
[12] 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).
[End of section]
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