Oil and Gas Development: Actions Needed to Improve Oversight of the Inspection and Enforcement Program
Private companies operate over 140,000 oil and gas wells on federal and Indian lands. The Bureau of Land Management's (BLM) inspection program ensures that these operators are complying with laws and regulations that protect public safety and the environment. Inspectors also ensure that operators are making accurate royalty payments to the federal government.
We reviewed BLM's inspection program and found that the agency wasn't effectively allocating its workforce. BLM's 6 busiest field offices handled 58% of the inspection workload between FYs 2012-2016—but had only 44% of the inspection staff. We recommended that BLM address this issue.
Picture of four oil pump jacks and oil storage tanks.
What GAO Found
Based on GAO's analysis of Bureau of Land Management (BLM) data, the distribution of BLM's oil and gas Inspection and Enforcement program's workload and workforce showed an imbalance among BLM's 33 field offices in fiscal years 2012 through 2016. GAO analyzed BLM data on the overall percentage of the workload and workforce distributed at each field office (i.e., activity level) and grouped similar activity level field offices together into highest, medium and lowest activity categories. GAO found that the program distributed the majority of its workload to 6 highest activity offices and distributed the majority of the workforce to 21 medium activity offices (see fig.). Based on GAO's review of BLM documentation and interviews with agency officials, BLM took both short- and long-term actions in fiscal years 2012 through 2016 to address this imbalance, such as temporarily re-assigning inspectors from some medium activity offices to some of the highest activity offices.
Distribution of Workload and Workforce across the BLM Oil and Gas Inspection and Enforcement Program's 33 Field Offices, Fiscal Years 2012 through 2016
BLM has not completed all required internal control reviews of its field offices. BLM's July 2012 oversight policy instructs its state offices to periodically conduct internal control reviews of field offices, which are to, among other things, identify staffing needs. BLM state offices completed internal control reviews at 6 of 33 field offices from 2013 through 2017, and 5 more are scheduled from 2018 through 2020. Officials from BLM state offices told GAO that some human capital and workload challenges hindered their ability to complete reviews, including long-term vacancies in some state offices positions. However, a senior BLM official said that headquarters did not consistently track and monitor the extent to which state offices completed field office internal control reviews, and headquarters officials said they were not aware that so few reviews had been completed. Under federal standards for internal control, management should design control activities to achieve objectives and respond to risks, such as by comparing actual performance to expected results and analyzing significant differences. Identifying the reasons it did not complete internal control reviews, developing and implementing a plan to address those challenges, and monitoring state offices' progress toward completing required reviews will better position BLM to ensure that its state offices are completing all required internal control reviews as called for by its July 2012 oversight policy.
Why GAO Did This Study
BLM has primary responsibility for managing oil and gas development on federal and Indian lands. To help ensure operator compliance with laws and regulations, BLM administers the Inspection and Enforcement program. Under the program, BLM inspects operators' drilling, production, and plugging activities and can issue various enforcement actions, such as monetary assessments, for violations. GAO was asked to examine key aspects of the Inspection and Enforcement program.
This report (1) describes the distribution of BLM's oil and gas Inspection and Enforcement program's workload and workforce among agency field offices for the most recent 5 years for which such data were available (fiscal years 2012 through 2016) and (2) examines the extent to which BLM conducted internal control reviews in accordance with its July 2012 oversight policy for fiscal years 2013 through 2018, the most recent period for which such data were available. GAO examined BLM policies, data, and documents; interviewed BLM headquarters, state and field office officials; visited six BLM field offices selected based on their level of resource development activity; and toured oil and gas drilling, production, and plugging sites at three of these six field offices.
Recommendations
GAO is making three recommendations to BLM, including taking actions to increase monitoring of state offices' progress toward completing internal control reviews. BLM concurred with all three recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Bureau of Land Management | The Director of BLM should identify the reasons internal control reviews were not completed (e.g., human capital and workforce), develop and implement a plan to address those reasons, and monitor state offices' progress toward completing required reviews. (Recommendation 1) |
In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. Specifically, BLM wrote that it is establishing teams to conduct internal control reviews, monitoring the status of any past-due reviews and actively engaging across its multiple state offices to ensure timely resolution. In October 2021, an official within the Department of Interior's Audit Management Division provided GAO with documentation stating that (1) by late December 2021 BLM plans to issue a revised oversight policy, develop supporting materials to implement the revised policy, and conduct a pilot state office internal control review and (2) by May 2022 BLM plans to complete all corrective actions related to this recommendation.
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| Bureau of Land Management | The Director of BLM should develop and document procedures for implementing internal control reviews under the July 2012 oversight policy. (Recommendation 2) |
In responding to our report, BLM stated that its July 2012 oversight policy, which expired in September 2013, should not have been allowed to lapse and given the importance of internal control reviews, the bureau will continue to use the July 2012 policy to conduct future reviews. In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. In October 2021, an official within the Department of Interior's Audit Management Division provided GAO with documentation stating that (1) by late December 2021 BLM plans to issue a revised oversight policy, develop supporting materials to implement the revised policy, and conduct a pilot state office internal control review and (2) by May 2022 BLM plans to complete all corrective actions related to this recommendation.
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| Bureau of Land Management | The Director of BLM should implement a risk-informed approach to scheduling and conducting internal control reviews that takes into account the risks to BLM's mission, such as those inherent in field offices' workload and workforce. (Recommendation 3) |
In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. Specifically, BLM wrote that the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance will help ensure that the bureau completes internal control reviews in a timely manner using a consistent risk-based approach. In October 2021, an official within the Department of Interior's Audit Management Division provided GAO with documentation stating that (1) by late December 2021 BLM plans to issue a revised oversight policy, develop supporting materials to implement the revised policy, and conduct a pilot state office internal control review and (2) by May 2022 BLM plans to complete all corrective actions related to this recommendation.
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