Recommendation: FERC should use available information, such as reports by transmission pipeline operators on service interruptions, to identify and assess risks to the reliability of natural gas transmission service. (Recommendation 1)

Agency: Federal Energy Regulatory Commission
Status: Open

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

Recommendation: FERC should develop and document an approach to respond, as appropriate, to risks it identifies to the reliability of natural gas transmission service. (Recommendation 2)

Agency: Federal Energy Regulatory Commission
Status: Open

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

Recommendation: FERC should review its current interagency agreements that pertain to its onshore LNG permitting process, and implement any needed updates. FERC's review should include input from cooperating agencies and CEQ. (Recommendation 1)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: In FERC's comments on a draft of our report, the Chairman of the Commission agreed with our findings and recommendations and stated that he has directed FERC staff to develop appropriate steps to implement the recommendations.

Recommendation: Once FERC has completed the review and implemented any necessary updates to interagency agreements, FERC should establish a process to regularly conduct such reviews and, as necessary, update the agreements. (Recommendation 2)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: In FERC's comments on a draft of our report, the Chairman of the Commission agreed with our findings and recommendations and stated that he has directed FERC staff to develop appropriate steps to implement the recommendations.

Recommendation: FERC should review its LNG regulations and replace the reference to the outdated 1984 earthquake standard. (Recommendation 3)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: In FERC's comments on a draft of our report, the Chairman of the Commission agreed with our findings and recommendations and stated that he has directed FERC staff to develop appropriate steps to implement the recommendations.

Recommendation: FERC should establish a process to conduct a standards-specific review of regulations that incorporate standards every 3 to 5 years and to update the regulations, if necessary. (Recommendation 4)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: In FERC's comments on a draft of our report, the Chairman of the Commission agreed with our findings and recommendations and stated that he has directed FERC staff to develop appropriate steps to implement the recommendations.

Recommendation: The Administrator of PHMSA should conduct a standards-specific review of regulations that incorporate standards and, if necessary, update the regulations or document its decision for not updating them. (Recommendation 5)

Agency: Department of Transportation: Pipeline and Hazardous Materials Safety Administration
Status: Open

Comments: In the Department of Transportation's comments on a draft of our report, the department concurred with our recommendation and said that PHMSA is currently developing a proposed rule that would incorporate updated standards, as described in our report.

Recommendation: The Administrator of PHMSA should establish a process to conduct a standards-specific review of regulations that incorporate standards every 3 to 5 years and to update the regulations, if necessary. (Recommendation 6)

Agency: Department of Transportation: Pipeline and Hazardous Materials Safety Administration
Status: Open

Comments: In the Department of Transportation's comments on a draft of our report, the department concurred with our recommendation and said that PHMSA has established a timeline for conducting a standards-specific review of LNG facility regulations every 3 to 5 years. We plan to follow-up on the status of the recommendation.

Recommendation: The Commandant of the Coast Guard should conduct a standards-specific review of the Coast Guard's regulations that incorporate standards and, if necessary, update the regulations or document its decision for not updating them. (Recommendation 7)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: In the Department of Homeland Security's comments on a draft of our report, the department concurred with our recommendation and stated that it conducts such reviews as part of its ongoing public rulemaking process. We plan to follow-up on the status of the recommendation.

Recommendation: The Commandant of the Coast Guard should update the agency's process for conducting standards-specific reviews to include time frames for completing such reviews every 3 to 5 years. (Recommendation 8)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: In the Department of Homeland Security's comments on a draft of our report, the department concurred with our recommendation and stated that the Coast Guard is in the process of updating its policy, "Standards Program For Marine Safety, Security, and Environmental Protection Programs," with timeframes for completing standards-specific reviews. The department estimated this would be completed in September 2021.

Recommendation: The Commandant of the Coast Guard should develop and implement workforce planning for the Office of Operating and Environmental Standards that addresses the four remaining key principles for strategic workforce planning. (Recommendation 9)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: In the Department of Homeland Security's comments on a draft of our report, the department concurred with our recommendation and stated that it is in the process of updating its Manpower Requirements Plan to include timeframes and milestones for completing manpower requirements analyses and determinations for positions and units. The Coast Guard anticipates promulgating the updated plan in March 2022.

Recommendation: The PHMSA Administrator should analyze the factors affecting states' participation in underground natural gas storage inspections and analyze its workforce needs on an ongoing basis to guide its budget requests. (Recommendation 1)

Agency: Department of Transportation: Pipeline and Hazardous Materials Safety Administration
Status: Open

Comments: As of February 2020, the Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) is collaborating with an organization of state government oil and gas oversight officials to assess the factors affecting their participation in its underground natural gas storage inspections, according to DOT. PHMSA plans to use this information by December 2020 to assess whether additional measures can be undertaken to increase state participation for its use starting in Fiscal Year 2022.

Recommendation: The TSA Administrator should periodically review, and as appropriate, update the 2010 Pipeline Security and Incident Recovery Protocol Plan to ensure the plan reflects relevant changes in pipeline security threats, technology, federal law and policy, and any other factors relevant to the security of the nation's pipeline systems. (Recommendation 5)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open

Comments: DHS concurred with this recommendation and stated that TSA will periodically review, and as appropriate, update the 2010 Pipeline Security and Incident Recovery Protocol Plan to ensure the plan reflects relevant changes in pipeline security threats, technology, federal law and policy, and any other factors relevant to the security of the nation's pipeline systems. In October 2019, TSA officials reported that they were in the process of reviewing the 2010 Pipeline Security and Incident Recovery Protocol Plan and anticipated completing the review by December 2019. However, this review was delayed and we will continue to monitor TSA's efforts to implement this recommendation.

Recommendation: The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to clarify TSA's Pipeline Security Guidelines by defining key terms within its criteria for determining critical facilities. (Recommendation 2)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open

Comments: As of June 2020, TSA reported that it completed a review of the Pipeline Security Guideline criteria for determining critical facilities. TSA sought and received pipeline stakeholder comments following their review of the criteria. According to TSA officials, TSA is sharing draft criteria with federal stakeholders and anticipates completion of the review by December 31, 2020. We will continue to monitor the status of TSA's activities to determine whether our recommendation is fully implemented.

Recommendation: The TSA Administrator should develop a strategic workforce plan for its Security Policy and Industry Engagement's Surface Division, which could include determining the number of personnel necessary to meet the goals set for its Pipeline Security Branch, as well as the knowledge, skills, and abilities, including cybersecurity, that are needed to effectively conduct Corporate Security Reviews (CSR) and Critical Facility Security Reviews (CFSR). (Recommendation 3)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open
Priority recommendation

Comments: As of June 2020, TSA reported that officials, including TSA's Office of Human Capital Strategic Planning, began collaborating to draft a strategic workforce plan for the pipeline security section of TSA. According to the officials, while this effort was delayed as TSA's Office of Human Capital needed focus on protecting TSA's workforce in response to the COVID-19 public health emergency, progress has been made. Phase one of a four-phase process began the week of 6/8/2020, with a Manpower Study to be completed by October 2020. The second phase will be a job skills/competency analysis and the third and fourth phases are position management and classification, and plan development and approval, respectively. TSA estimated completion of the workforce plan by June 30, 2021. We will continue to monitor the status of these efforts to develop a strategic workforce plan in response to this recommendation.

Recommendation: The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to identify or develop other data sources relevant to threat, vulnerability, and consequence consistent with the National Infrastructure Protection Plan and DHS critical infrastructure risk mitigation priorities and incorporate that data into the Pipeline Relative Risk Ranking Tool to assess relative risk of critical pipeline systems, which could include data on prior attacks, natural hazards, feedback data on pipeline system performance, physical pipeline condition, and cross-sector interdependencies. (Recommendation 6)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open

Comments: As of June 2020, TSA officials reported meeting with representatives from the Department of Homeland Security (DHS) and the Federal Emergency Management Agency (FEMA) in February and March 2019 for their input on the identification of sources relevant to threat, vulnerability, and consequence consistent with the National Infrastructure Protection Plan and DHS critical infrastructure risk mitigation priorities. TSA officials also reported meeting with RAND personnel in March 2020 to discuss possible contract options for addressing this recommendation. Further action on this recommendation has been limited due to work on the COVID-19 response. We will continue to monitor the status of TSA's activities to determine whether our recommendation is fully implemented.

Recommendation: The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to take steps to coordinate an independent, external peer review of its Pipeline Relative Risk Ranking Tool, after the Pipeline Security Branch completes enhancements to its risk assessment approach. (Recommendation 7)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open

Comments: As of June 2020, DHS officials reported that TSA will take steps to coordinate an independent, external peer review of its Pipeline Relative Risk Ranking Tool after addressing recommendations 4,5, and 6 of this report. DHS estimated that this effort would be completed by April 30, 2021.

Recommendation: The Administrator of PHMSA should ensure that PHMSA uses other data and information about budgetary resources as they become available to inform and refine its performance goals. (Recommendation 2)

Agency: Department of Transportation: Pipeline and Hazardous Materials Safety Administration
Status: Open

Comments: As of May 2019, we are following up with PHMSA regarding this recommendation and will provide updated information when we confirm agency actions.

Recommendation: To help improve reporting of emissions data on the OGOR, the Secretary of the Interior should direct BLM to provide additional guidance on how to estimate natural gas emissions from federal oil and gas leases.

Agency: Department of the Interior
Status: Open

Comments: In November 2018, BLM's "Waste Prevention, Production Subject to Royalties, and Resource Conservation; Rescission or Revision of Certain Requirements" rule (43 C.F.R. 3179.301) took effect, revising the 2016 rule. According to BLM in July 2020, the revision satisfies the intent of the recommendation because the rule specifies the acceptable means of estimation or measurement of vented or flared gas. The rule says the operator may estimate or measure vented gas in accordance with applicable state or tribal regulatory agency rules or regulations, estimate using the gas to oil ratio (GOR) test (which, during GAO's review, some BLM officials said was not accurate), or to "measure" the volume of the flared gas. We do not believe the revised rule provides sufficient additional specificity on how natural gas emissions should be estimated by operators.

Recommendation: To help improve reporting of emissions data on the OGOR, the Secretary of the Interior should direct ONRR to provide additional guidance on how to differentiate between combusted and noncombusted lease use volumes reported on the OGOR, which could assist Interior in measuring its progress toward greenhouse gas reduction goals.

Agency: Department of the Interior
Status: Open

Comments: In July 2020, ONRR reported that it developed and implemented two disposition codes--one for the royalty-bearing flaring of gas and another for the royalty-bearing venting of gas volumes. ONRR did not develop additional disposition codes because, according to BLM, other disposition codes would not be required due to BLM's 2018 revision of the methane rule. However, we do not believe the measurement provisions in the revised methane rule contain any specific provisions requiring reporting for combusted and non-combusted lease use gas. Gas could be used on lease in pneumatic valves, which is released into the atmosphere as methane; or combusted to power up generators, where it's released as carbon dioxide. Knowing whether the emissions are in the form of methane or carbon dioxide is critical to helping Interior accurately estimate greenhouse gas emissions.

Recommendation: To further improve its production verification efforts and to provide greater assurance that BLM staff are consistently applying the new guidance to commingling agreement requests and determine whether the guidance corrected deficiencies and produced improvements, the Secretary should direct BLM to schedule and complete the internal review as expeditiously as possible.

Agency: Department of the Interior
Status: Open

Comments: In July 2019, Interior officials stated BLM will not be conducting a separate internal review of the guidance for commingling agreement requests issued in July 2013. However, officials stated they are committed to performing the internal review as part of the internal review on its inspection and enforcement program and believed their pending actions related to implementing the recommendations in the GAO report "Oil and Gas Development: Actions Needed to Improve Oversight of the Inspection and Enforcement Program" (GAO-19-7) would also address this recommendation. Interior officials stated the target date for implementing this recommendation is June 30, 2021.

Recommendation: The Secretary of the Interior should direct the Director of the Bureau of Land Management to take steps, including making changes to AFMSS, and in any new system that replaces AFMSS, to improve the ability of staff to identify wells that are a high priority for environmental inspection and to incorporate information on the inspection history of wells into the environmental inspection prioritization process.

Agency: Department of the Interior
Status: Open

Comments: BLM concurred with the recommendation and has initiated action to update its application for permit to drill (APD) permit processing system. This new system will be known as AFMSS II and, when fully implemented, may address GAO's recommendations. Currently, BLM's actions are insufficient to close this recommendation because they have not completed the updates to AFMISS. Specifically, BLM has not completed its update of AFMSS II to cover environmental inspections. We will continue to follow up with BLM as the agency continues to take action to improve its well tracking system. BLM said it intends to update AFMSS II to cover environmental issues and projects that the remaining AFMSS II related tasks ensuring the system's full deployment will be completed by March 2020. In October 2019, we requested an update on BLM's timeframes.

Recommendation: The Secretary of the Interior should direct the Director of the Bureau of Land Management to take steps to ensure that environmental violations or problems and enforcement actions are documented in a consistent manner.

Agency: Department of the Interior
Status: Open

Comments: In August 2018, BLM informed us that the agency has taken several corrective actions to address the implementation of the recommendation, which will be accomplished related to the redesign of its Automated Fluid Minerals Support System (AFMSS). However, the agency reported that this system will not be completed until March 2020. In October 2019, we requested an update on BLM's timeframes.

Recommendation: To enhance the safety of unregulated onshore hazardous liquid and gas gathering pipelines, the Secretary of Transportation should direct the PHMSA Administrator to collect data from operators of federally unregulated onshore hazardous liquid and gas gathering pipelines, subsequent to an analysis of the benefits and industry burdens associated with such data collection. Data collected should be comparable to what PHMSA collects annually from operators of regulated gathering pipelines (e.g., fatalities, injuries, property damage, location, mileage, size, operating pressure, maintenance history, and the causes of incidents and consequences).

Agency: Department of Transportation
Status: Open

Comments: PHMSA plans to collect data on previously unregulated hazardous liquid and natural gas gathering lines via rulemakings. PHMSA issued a final rule that covers data collection for hazardous liquid gathering pipelines in October 2019. As of May 2020, PHMSA anticipates issuing the final rule for natural gas pipelines by Fall, 2020.