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.
