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    Subject Term: "Environmental enforcement"

    1 publication with a total of 8 open recommendations
    Director: Frank Rusco
    Phone: (202) 512-3841

    8 open recommendations
    Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To address risks to the effectiveness of its investigations, environmental compliance, and enforcement capabilities, BSEE should complete policies outlining the responsibilities of its the Safety and Incident Investigations Division (SIID), Environmental Compliance Division, and Safety Enforcement Division and update and develop procedures to guide them.

    Agency: Department of the Interior
    Status: Open

    Comments: According to BSEE documentation, SIID, the Environmental Compliance Division, and the Safety Enforcement Division continue work to complete foundational policies for their respective areas. The target date has been extended to June 30, 2018, due to the need to align policy development with BSEE's new Directives System outlined in Bureau Manual Chapter 380.1, signed on May 18, 2017.
    Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its investigative capabilities, BSEE should establish a capability to review investigation policy and collect and analyze incidents to identify trends in safety and environmental hazards.

    Agency: Department of the Interior
    Status: Open

    Comments: According to BSEE documentation, the Safety and Incident Investigations Division (SIID) is working closely with the Office of Policy and Analysis and the Records, Delegations, and Directives Team to implement the requirements specified in the BSEE Directives System Manual Chapter and to convert a number of Bureau Interim Directives into Bureau Manual Chapters. An internal control review was initiated in fiscal year 2017 to assess compliance with the tiering process outlined in the National Investigations Handbook. SIID staff are currently reviewing the Handbook to assess the need for updates and are working with District staff to review District level investigations to determine what needs to be included in the narrative portion of District Form 2010. We anticipate completion of these actions by December 31, 2017.
    Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its investigative capabilities, BSEE should clearly communicate the purpose of the Investigations and Review Unit, as it will be assumed by the SIID, to industry operators.

    Agency: Department of the Interior
    Status: Open

    Comments: According to BSEE documentation, SIID, the Office of Public Affairs, the Office of Policy and Analysis, and regional offices will consult with the new BSEE Director to solicit input and discuss potential mechanisms for communicating the purpose of SIID to industry operators. Actions to implement this recommendation are expected to be completed by December 31, 2017.
    Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its investigative capabilities, BSEE should clarify policies and procedures for assigning panel investigation membership and referring cases of suspected criminal wrongdoing to the Interior's Office of Inspector General.

    Agency: Department of the Interior
    Status: Open

    Comments: In March 2016, BSEE issued two Bureau Interim Directives (BID) regarding the assignment of panel investigation membership and referral to Interior's Office of the Inspector General. However, the BID regarding panel investigation membership is not clear regarding how disagreements between regional management and headquarters investigation management are to be adjudicated. According to BSEE documentation, BID No. 2016-003N (Designation of Panel Chair and Panel Members) is being revised to clarify how disagreements between regional management and headquarters investigation management will be adjudicated. BSEE did not provide a time frame for completion.
    Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its environmental compliance capabilities, BSEE should conduct and document a risk analysis of the regional-based reporting structure of the Environmental Compliance Division, including actions to mitigate any identified risk.

    Agency: Department of the Interior
    Status: Open

    Comments: According to BSEE documentation, a risk analysis of the regional-based reporting structure of the Environmental Compliance Division was initiated in fiscal year 2017 using the Department of Interior's Integrated Risk Rating Tool (IRRT). The results of the analysis are currently being reviewed to assess whether the IRRT's design and methodology actually addressed the intent of the recommendation. BSEE did not provide a time frame for completion.
    Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its environmental compliance capabilities, BSEE should coordinate with the Administrator of the Environmental Protection Agency to consider the relevance of existing interagency agreements for monitoring operator compliance with National Pollutant Discharge Elimination System permits on the Outer Continental Shelf and, if necessary, update them to reflect current oversight needs.

    Agency: Department of the Interior
    Status: Open

    Comments: According to BSEE documentation, BSEE, in coordination with EPA, has been reviewing the agreements. Given new leadership in both agencies, this effort has been delayed. BSEE did not provide a time frame for completion.
    Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its environmental compliance capabilities, BSEE should develop a plan to address documented environmental oversight staffing needs.

    Agency: Department of the Interior
    Status: Open

    Comments: According to BSEE documentation, the BSEE Director has ordered an assessment. In the meantime, inspectors are being trained to assist with environmental oversight responsibilities as appropriate. BSEE did not provide a time frame for completion.
    Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its enforcement capabilities, BSEE should develop a mechanism to ensure that it reviews the maximum daily civil penalty and adjust it to reflect increases in the Consumer Price Index within the time frame as directed by statute.

    Agency: Department of the Interior
    Status: Open

    Comments: In April 2016, BSEE issued a bureau manual chapter regarding the review and adjustment of civil penalty amounts but has not developed business practices to implement it. According to BSEE documentation, a Bureau Interim Directive, aligned with OMB guidance on Implementation of the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, is currently being drafted to define business practices that include specific bureau roles, responsibilities, and timelines. This action is expected to be completed by December 31, 2017.