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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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