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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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