Oil and Gas Wells: Bureau of Land Management Needs to Improve Its Data and Oversight of Its Potential Liabilities
Fast Facts
Oil and gas companies operating wells on federal and Indian lands are required to reclaim sites after wells are no longer used—plug wells, remove structures, and replant. Companies provide bonds up front to cover reclamation, but if they don't reclaim the site, or if it costs more than expected, the Bureau of Land Management may be liable.
Reclamation costs and potential liabilities likely increased since 2010, but we couldn't determine how much because BLM does not systematically track this data.
We made 7 recommendations to help BLM better manage its risk, including improving the way it tracks reclamation costs and potential liabilities.
Example of an active well that is currently producing
This photo shows an active well.
Highlights
What GAO Found
GAO's analysis indicates that the Bureau of Land Management's (BLM) actual costs incurred and potential liabilities for reclaiming oil and gas wells have likely increased for fiscal years 2010 through 2017. However, the full extent of the increase is not known because BLM does not systematically track needed data. Based on GAO's analysis of data obtained from 13 of BLM's 33 field offices that manage oil and gas programs, the average annual reclamation cost was $267,600, an increase compared to the $171,500 annual average across all BLM offices that GAO reported in 2010. Similarly, GAO's analysis of BLM data found that the number of known orphaned wells, those that generally have no responsible or liable parties, for all field offices has increased from 144 in 2010 to 219 as of 2017. However, BLM's database that contains information on oil and gas wells on federal and Indian lands does not collect information on costs incurred or on potential liabilities that might result from an increase in the number of orphaned wells. Under federal internal control standards, management should use quality information to achieve the entity's objectives. Without systematically tracking such information, BLM does not have assurance that it has sufficient bonds or financial assurances to cover the costs of reclaiming orphaned wells.
Lifecycle of Oil and Gas Wells Overseen by the Bureau of Land Management (BLM)
GAO was unable to fully assess the extent to which BLM field and state offices have implemented the agency's policies on reviewing wells and bond adequacy in part because of deficiencies in BLM's monitoring approach. For example, reports BLM headquarters used to monitor field offices' implementation of the policies have limitations. GAO identified discrepancies between the well and bond adequacy review reports that BLM state offices submitted to headquarters and the national summary consolidating states' information. Out of 10 state offices, 3 reported a different number of reviews completed in fiscal year 2016 than what BLM reported in its fiscal year 2016 national summary. Leading practices for monitoring the implementation of agency policies call for taking steps such as collecting and analyzing data on performance indicators. Without strengthening BLM's approach to monitoring, its ability to assess field offices' reviews of all inactive wells and determine the adequacy of all bonds is limited.
Why GAO Did This Study
In fiscal year 2016, private entities operated about 94,000 oil and gas wells on federal lands overseen by BLM. Once wells cease production, they can become inactive and potentially orphaned if an operator does not perform required reclamation and if an operator's bond is insufficient to cover the expenses. BLM considers oil and gas wells on federal and Indian lands and the associated leased lands as potential liabilities for the federal government because BLM may have to cover the costs of reclaiming well sites. To better manage its potential liabilities, BLM issued well and bond adequacy review policies in 2012 and 2013, respectively.
GAO was asked to review how BLM manages its potential oil and gas well liabilities. This report examines, among other things: (1) how BLM's actual costs and potential oil and gas well liabilities have changed for fiscal years 2010 through 2017 and (2) the extent to which BLM has implemented its well and bond review policies. GAO analyzed BLM's policies and data and interviewed BLM officials and representatives from stakeholder organizations.
Recommendations
GAO is making seven recommendations, including that BLM systematically track the agency's actual reclamation costs and potential liabilities and strengthen its approach to monitoring field offices' implementation of the well review and bond adequacy review policies. BLM agreed with GAO's recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Bureau of Land Management | The Director of BLM should systematically and comprehensively track the actual costs BLM incurs when reclaiming orphaned wells and the information, including the number of orphaned wells and inactive wells over time, necessary to determine the agency's potential liabilities. (Recommendation 1) |
BLM concurred with this recommendation and, in July 2019, the agency developed a new funding code to track the costs incurred when reclaiming orphaned wells and issued written guidance to state and field offices in order to implement the bureau-wide use of the code. BLM also issued two instruction memoranda that provide direction to its field offices on how to track the number of inactive and orphaned wells. Specifically, BLM's December 2019 instruction memorandum 2020-006 gives instructions to field offices on how to annually identify and correct discrepancies between the number of inactive wells in BLM's AFMSS system and ONRR's OGOR system. In addition, BLM's July 2021 instruction memorandum 2021-039 provides instructions to field offices on how to identify and track the number of orphaned wells in AFMSS, prepare cost estimates to reclaim the wells, and track actual costs incurred using a designated orphaned well funding code. These actions meet the intent of our recommendation.
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| Bureau of Land Management | The Director of BLM should develop and communicate specific instructions on what actions constitute a well review for annual-reporting purposes. (Recommendation 2) |
BLM concurred with this recommendation and in December 2019 issued Instruction Memorandum (IM) 2020-006 entitled, "Idled Well Reviews and Data Entry" which replaced IM 2012-181. The revised policy provides instructions for conducting and documenting annual well reviews, which meets the intent of our recommendation.
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| Bureau of Land Management | The Director of BLM should take steps to improve the Automated Fluid Minerals Support System data quality, for example, by conducting more edit checks and by having data stewards certify the quality of the data. (Recommendation 3) |
BLM concurred with this recommendation and in December 2019 issued Instruction Memorandum (IM) 2020-006 entitled, "Idled Well Reviews and Data Entry" which replaced IM 2012-181. The revised policy provides instructions for data entry for well reviews into the Automated Fluid Minerals Support System and provides instructions for data validation and certification, which meets the intent of our recommendation.
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| Bureau of Land Management | The Director of BLM should strengthen its approach to monitoring field offices' implementation of the well review and bond adequacy review policies, such as by collecting and analyzing data on performance indicators and ensuring the quality of those data. (Recommendation 4) |
BLM concurred with this recommendation and in December 2019 issued Instruction Memorandum (IM) 2020-006 entitled, "Idled Well Reviews and Data Entry" which replaced IM 2012-181. In addition, in November 2018, BLM issued Instruction Memorandum (IM) 2019-14 entitled, "Oil and Gas Bond Adequacy Reviews" which replaced IM 2013-151. Both revised policies include monitoring procedures to ensure field offices conduct the reviews and accurately enter data, which meets the intent of our recommendation.
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| Bureau of Land Management | The Director of BLM should provide greater specificity in current policy or supplemental guidance to all BLM field offices on how to identify and manage all shut-in wells. (Recommendation 5) |
BLM concurred with this recommendation and in December 2019 issued Instruction Memorandum (IM) 2020-006 entitled, "Idled Well Reviews and Data Entry" which replaced IM 2012-181. The revised policy includes a section on how BLM offices should identify shut-in wells and update well status. The policy also requires a mechanical integrity or production testing for wells that have been shut-in for more than three years. These actions meet the intent of our recommendation.
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| Bureau of Land Management | The Director of BLM should develop a resource management plan addressing resources needed for conducting well and bond adequacy reviews and reclaiming orphaned wells. (Recommendation 6) |
BLM officials stated that the agency conducts annual work planning processes which facilitates the decisions regarding the allocation of agency resources. In July 2019, BLM included additional language in its annual work plan that underscores the importance and relevance of well and bond adequacy reviews. The agency also developed a new fund code to track the actual reclamation costs incurred from reclaiming orphaned wells. The annual work plan also lists identifying and cataloging orphaned wells as a performance goal and the plan states that BLM is working with state regulatory agencies to plug wells within funding levels and state agreements. In addition, in July 2021, BLM issued instruction memorandum 2021-039, which provides instructions to field offices on how to identify and prioritize orphaned wells as well as how to prepare and submit reclamation cost estimates to BLM headquarters. The instruction memorandum states that BLM headquarters is to consider field offices' reclamation priorities when preparing annual budget requests and distributing available funds for orphaned well reclamation. These actions meet the intent of our recommendation.
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| Bureau of Land Management | The Director of BLM should, in revising the bond adequacy review policy, ensure that the reviews of nationwide and statewide bonds reflect the overall risk presented by operators. (Recommendation 7) |
BLM concurred with this recommendation and in November 2018 issued Instruction Memorandum (IM) 2019-14 entitled, "Oil and Gas Bond Adequacy Reviews" which replaced IM 2013-151. The revised policy requires additional coordination between BLM headquarters, state offices, and field offices to combine input from all relevant field offices when reviewing nationwide and statewide bonds, which meets the intent of our recommendation.
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