Recommendation: The Director of BLM should evaluate its temporary royalty relief program, including the extent to which the policy met BLM's objectives—conserving oil and gas resources from becoming unrecoverable—and likely costs, such as forgone revenues—to inform any royalty relief decisions it may make in the future under the ongoing regulatory authority. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BLM should update BLM's 1995 royalty handbook to provide specific, consistent, and transparent policies and procedures for royalty relief. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Acting Director of BLM should develop a documented process to consistently implement the APD prioritization process outlined in Instruction Memorandum 2013-104 at all field offices. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The Department of the Interior, on behalf of BLM, did not concur with this recommendation. As of August 2020, BLM has not taken steps to address this recommendation.

Recommendation: The Acting Director of BLM should instruct agency staff to document formal change management processes for the rollout of future AFMSS II modules consistent with leading software development practices. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The Department of the Interior, on behalf of BLM, did not concur with this recommendation--although, it did state that it agreed with the premise of the need to further improve its formal change management procedures. As of August 2020, BLM has not taken actions to address this recommendation.

Recommendation: The Acting Director of BLM should document and implement an action plan that identifies potential corrective actions based on previous lessons learned to address any challenges with the rollout of future AFMSS II modules. (Recommendation 3)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The Department of the Interior, on behalf of BLM, agreed with this recommendation. In its agency comment letter, the Department said that the BLM AFMSS team would implement adjustments and improvement based on the collected lessons learned. They also stated that upon completion of the last Field Office implementation and conversion to AFMSS II, BLM will conduct a formal program review and an annual operational assessment, which will also present opportunities for annual corrective actions and additional lessons learned considerations. As of August 2020, BLM has not taken actions to address this recommendation.

Recommendation: The Director of BLM should establish outcome-oriented performance measures to assess the effectiveness of the reorganization. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The department neither agreed nor disagreed with our recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BLM should develop an implementation plan for the reorganization that includes milestones and deliverables to track and communicate implementation progress. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The department neither agreed nor disagreed with our recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BLM should complete a strategic workforce plan that addresses how it will recruit for and fill vacant positions resulting from the relocations. (Recommendation 3)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: The department neither agreed nor disagreed with our recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BLM should develop a plan to conduct all required facility security assessments agency-wide, taking into consideration the agency's organizational structure, available resources, and training needs. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM agreed with our recommendation and stated it intends to revise its policy and develop a plan to complete required facility security assessments. As of November 2019, BLM had not yet completed its plan.

Recommendation: The Director of BLM should develop a facility security assessment methodology that complies with requirements in the ISC Standard to assess all undesirable events and consider all three factors of risk for each undesirable event. (Recommendation 5)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM agreed with our recommendation and said it would revise its policy and develop a facility security assessment methodology that complies with requirements in the ISC Standard. As of November 2019, BLM had not yet developed its methodology.

Recommendation: The Director of BLM should take steps to adjust bond levels to more closely reflect expected reclamation costs, such as by increasing regulatory minimums to reflect inflation and incorporating consideration of the number of wells on each bond and their characteristics. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In a August 2019 letter to GAO, BLM noted Instruction Memorandum 2019-014, "Oil and Gas Bond Adequacy Reviews", related to the agency's response to this recommendation. The Instruction Memorandum does not increase regulatory minimums to reflect inflation or incorporate the consideration of the number of wells on each bond and their characteristics, but BLM is collecting data to determine the effectiveness of this Instruction Memorandum. BLM noted any further action will depend on the results of the data analysis, expected to be continued through the first quarter of Fiscal Year 2021. As of April 2020 this recommendation remains open.

Recommendation: The Director of the Bureau of Land Management (BLM) should create and implement a policy for standard posting requirements regarding comments and their identity information, particularly for duplicate comments, and should clearly communicate this policy to the public on the BLM website. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM concurred with the recommendation. In December 2019, BLM indicated that it will develop and issue policy for standard posting requirements regarding public comments and associated identity information as well as duplicative comments which will be available on BLM's website. BLM officials estimate that this will be completed in March 2020. Until these items are completed, our recommendation to BLM remains open.

Recommendation: 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)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: 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 by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook or Instruction Memorandum. BLM also 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 late August 2020, BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Director of BLM should develop and document procedures for implementing internal control reviews under the July 2012 oversight policy. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: 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 addition, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook, or Instruction Memorandum. In late August 2020. BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: 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)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: 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 by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook, or Instruction Memorandum. In addition, BLM noted that the guidance will help ensure that the bureau completes internal control reviews in a timely manner using a consistent risk-based approach. In late August 2020. BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Director of the BLM should determine whether new regulations governing timber export and substitution are appropriate. If the agency determines new regulations are appropriate, it should issue them in accordance with the 1997 act, in consultation with the Forest Service. Otherwise, the agency should seek legislative relief from the act's requirement. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In its April 9, 2020 correspondence, BLM stated that a proposed rule continues to be reviewed by Departmental officials. BLM identified December 31, 2020 as a new target date for completing this recommendation.

Recommendation: The Director of the BLM should review agency policies for continued relevance and effectiveness in addressing the risk of illegal timber export and substitution, and based on that review--and in accordance with applicable regulations--should issue new policies as necessary. (Recommendation 4)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In its April 9, 2020 correspondence, BLM stated that any action to address this recommendation is contingent upon the completion of Recommendation #2. Once BLM's response to that recommendation is completed, the agency will address this recommendation.

Recommendation: The Director of BLM should require cognizant officials in headquarters and state offices to conduct top-level reviews of field offices' monitoring of oil and gas lease suspensions, as well as of official lease files and databases to ensure they are current and complete. (Recommendation 3)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM concurred with this recommendation. However, the Bureau has yet to provide information concerning the current status of this recommendation. We will update the recommendation's status when we receive such information.

Recommendation: 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)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: 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. Also in July 2019, BLM officials stated that the agency will expand existing reporting capabilities to provide the ability to track orphaned and inactive well records over time. As of September 2020, we are working to confirm what actions BLM has taken to track the number of orphaned and inactive wells over time, and we will provide updated information when we obtain it.

Recommendation: 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)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: 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. However, as of September 2020, absent identification of funds needed to reclaim orphaned wells and where those funds will come from, BLM does not have a plan to reclaim wells that are currently orphaned.

Recommendation: The Director of the Bureau of Land Management should develop a policy to ensure that field offices consistently track exception data.

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In June 2019, BLM issued a memo called "Documentation and Tracking Requirements for Waiver, Exceptions, and Modifications for Fluid Mineral Exploration and Development Activities." The memo states that BLM is updating its guidance for tracking waivers, exceptions, and modifications of fluid minerals stipulations and Conditions of Approval (COA) to ensure that these requests are consistently processed and documented until BLM completes database enhancements to its Automated Fluid Minerals Support System 2 to perform this function. To ensure consistent documentation, BLM has developed an "Exceptions Tracking Sheet" that BLM staff are to use when making decisions. Information captured on the tracking sheet include: field office, state, U.S. well number, exception decision date, COA or lease stipulation (LS) , category of COA or LS (e.g. air, community, wildlife), and the specific COA or LS involved. Additionally, the associated environmental analyses, documents, and authorized officer's decision must be consistent with guidance found in Chapter IV of BLM's Planning for Fluid Mineral Resources Handbook (H-1624-1). In August 2019, GAO requested additional information to support the implementation of the recommendation. In December 2019, Interior officials stated that it would implement the recommendation by August 2020.

Recommendation: The Director of the Bureau of Land Management should develop bureau-wide written procedures for consistently considering and clearly documenting the information and processes used to make exception decisions.

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In June 2019, BLM issued a memo called "Documentation and Tracking Requirements for Waiver, Exceptions, and Modifications for Fluid Mineral Exploration and Development Activities." The memo states that BLM is updating its guidance for tracking waivers, exceptions, and modifications of fluid minerals stipulations and Conditions of Approval (COA) to ensure that these requests are consistently processed and documented until BLM completes database enhancements to its Automated Fluid Minerals Support System 2 to perform this function. To ensure consistent documentation, BLM has developed an "Exceptions Tracking Sheet" that BLM staff are to use when making decisions. Information captured on the tracking sheet include: field office, state, U.S. well number, exception decision date, COA or lease stipulation (LS) , category of COA or LS (e.g. air, community, wildlife), and the specific COA or LS involved. Additionally, the associated environmental analyses, documents, and authorized officer's decision must be consistent with guidance found in Chapter IV of BLM's Planning for Fluid Mineral Resources Handbook (H-1624-1). In August 2019, GAO requested additional information to support the implementation of the recommendation. In December 2019, Interior officials stated that it would implement the recommendation by August 2020.

Recommendation: The Director of the Bureau of Land Management should direct field offices to make the results of exception request decisions available to the public, such as on BLM's public website.

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In July 2019, Interior officials stated that the BLM does not intend to make an exception tracking spreadsheet available to the public. According to Interior officials, the regulations at 43 CFR 3101.1-4 do not require it, and public posting is only applicable to waivers and modifications, not exceptions. Interior's position has been that the public can ask for this information in a Freedom of Information Act (FOIA) request. Interior officials explained that the main concern in making an exception tracking spreadsheet available to the public is that a single consolidated tracking spreadsheet would require constant updates and posting to Interior's website. Since the numbers can change daily, any posted updates would only provide a brief snap shot which will not be meaningful. Interior officials stated that the BLM will aim to address this item in future database design enhancements in order to obtain a permanent tracking solution. We will update this recommendation when we have additional information from BLM.

Recommendation: The Director of the Bureau of Land Management should clarify guidance related to documentation of environmental inspections to ensure that inspections are documented in a manner that indicates whether all permit requirements were checked as part of the inspection.

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In August 2016, Interior officials stated that three of six corrective actions are substantially complete and that efforts are ongoing to clarify guidance related to documentation of environmental inspections with a target date for implementation of December 31, 2018. In May 2020, Interior officials stated the revised target date for implementation is September 30, 2020, at which time BLM will issue updated policies and procedures.

Recommendation: The Director of the Bureau of Land Management should provide additional guidance to field offices on how to collect and use data collected during monitoring inspections and, in doing so, determine and implement an approach for using the data to assess the effectiveness of the agency's mitigation efforts, including its best management practices.

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In August 2018, Interior officials stated that efforts to provide guidance to field offices on how to collect and use date are ongoing with correction actions 10 percent complete. In May 2020, officials stated that they have a target date for implementation of December 31, 2020.