OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OFTHE INTERIOR 

The U.S. Department of the 

Interior Needs To Strengthen 

Governance Practices To Improve 

Its Management of Geospatial 

Data 

EVALUATION 

In recognition of Secretarial Order No. 3380, we are providing estimated costs 

associated with certain work products. Applying a formula involving prior salary and

benefit expenses, we estimate the cost of preparing this report to be $212,000. 

Report No.: 2020-ITA-020 October 2020 

This is a revised version of the report prepared for public release.
 

 

 

 

 

 

 

 

 

 

 

 

OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: William E. Vajda 

Chief Information Officer 

From: Mark Lee Greenblatt 

Inspector General 

Subject: Final Evaluation Report – The U.S. Department of the Interior Needs To Strengthen 

Governance Practices To Improve Its Management of Geospatial Data 

Report No. 2020-ITA-020 

This memorandum transmits our evaluation report on the U.S. Department of the 

Interior’s (DOI’s) progress implementing the objectives of the Geospatial Data Act of 2018. We 

found the DOI has made progress in meeting 11 of the 13 Geospatial Data Act requirements we 

evaluated. We also found, however, that the DOI did not implement Departmentwide controls to 

ensure that geospatial data purchased from third parties met quality standards and did not ensure 

that bureaus regularly searched the GeoPlatform before expending Federal funds to purchase 

geospatial data from a third party. 

In response to our draft report, the DOI concurred with our two recommendations and 

provided information on actions taken and planned, responsible officials, and target dates for 

completion. Based on the DOI’s response, we consider both recommendations resolved but not 

implemented. We will refer both recommendations to the Office of Policy, Management and 

Budget for implementation tracking. 

If you have any questions about this report, please call me at 202-208-5745. 

The legislation creating the Office of Inspector General requires that we report to 

Congress semiannually on all audit, inspection, and evaluation reports issued; actions taken to 

implement our recommendations; and recommendations that have not been implemented. 

Office of Inspector General | Washington, DC 
 

Contents 

Results in Brief ............................................................................................................................... 1 

Introduction..................................................................................................................................... 3 

Objective ....................................................................................................................................3 

Scope Limitation ............................................................................................................ 4 

Background................................................................................................................................4 

Findings........................................................................................................................................... 7 

The DOI Must Ensure It Receives High-Quality Geospatial Data Purchased From Third 

Parties.........................................................................................................................................7 

The DOI Risks Expending Funds on Geospatial Data That May Already Exist on the 

GeoPlatform...............................................................................................................................9 

The DOI’s Status in Meeting Other Requirements of the Geospatial Data Act of 2018.........10 

Conclusion and Recommendations............................................................................................... 11 

Conclusion ...............................................................................................................................11 

Recommendations Summary ...................................................................................................11 

DOI Response ..........................................................................................................................11 

Appendix 1: Scope and Methodology........................................................................................... 12 

Scope........................................................................................................................................12 

Scope Limitation......................................................................................................................12 

Methodology............................................................................................................................12 

Appendix 2: Description of the U.S. Department of the Interior’s National Geospatial Data Asset 

(NGDA) Themes........................................................................................................................... 15 

Appendix 3: The U.S. Department of the Interior’s Status in Meeting the Requirements of the 

Geospatial Data Act of 2018......................................................................................................... 16 

Appendix 4: Response to Draft Report......................................................................................... 22 

Appendix 5: Status of Recommendations..................................................................................... 25 
 

 

 

 

 

 

 

 

 

Results in Brief 

The U.S. Department of the Interior (DOI) uses geospatial data—data linked to specific 

geographic locations—to support its varied missions. For example, the DOI’s bureaus use 

geospatial data to make decisions and direct resources when responding to wildland fires and 

hurricanes, to track the habitat of endangered species, and to promote the health and welfare of 

tribal communities. 

The DOI is a major producer of geospatial data, leading more than half of the geospatial data 

themes for the Federal Government and spending over $100 million a year purchasing geospatial 

data and services from third-party contractors. The DOI also operates the GeoPlatform 

(geoplatform.gov)—a searchable clearinghouse of geospatial data available from Federal and 

non-Federal sources. We assessed whether the DOI’s management of its geospatial data 

programs complied with the Geospatial Data Act of 2018. 

The Geospatial Data Act of 2018 was signed on October 5, 2018, and requires that not less than 

once every 2 years the Inspector General submit to Congress a report of the DOI’s compliance 

with the Act. For this inaugural review, we conducted a broad evaluation of the DOI’s progress 

toward complying with the Act to serve as a baseline for future reviews (see Appendix 1). 

We found the DOI is working toward meeting 11 of the 13 Geospatial Data Act requirements we 

evaluated. For example, in 2016, the DOI assigned an executive to manage Departmentwide 

collection, acquisition, maintenance, and dissemination of its geospatial data, and is currently 

implementing strategy for advancing geospatial data and related activities to support bureau 

missions. We also found evidence that the DOI readily shares geospatial data through the 

GeoPlatform with other Federal agencies and non-Federal users. In addition, the DOI is working 

on: 

• Promoting the integration of geospatial data from all sources 

• Allocating resources for geospatial data collection, production, and stewardship 

• Documenting geospatial data on the GeoPlatform using the relevant data and metadata 

standards 

• Assuring that bureau geospatial data and activities are included on agency record 

schedules that have been approved by the National Archives and Records Administration 

• Coordinating with Federal and non-Federal entities to effectively manage geospatial data 

• Using geospatial data to enhance operations, support decision making, and enhance 

reporting to Congress 

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• Protecting personally identifiable information stored on the GeoPlatform from 

unauthorized access in accordance with Federal policy and law 

• Making declassified data, as appropriate, available as part of the National Spatial Data 

Infrastructure 

We found, however, that the DOI did not implement Departmentwide controls to ensure that 

geospatial data purchased from third-party contractors met quality standards endorsed by the 

Federal Geographic Data Committee and did not ensure that bureaus regularly searched the 

GeoPlatform before expending Federal funds to purchase geospatial data. As a result, the DOI 

risks using poor-quality data to support decision making and resource allocation, with the 

potential to adversely affect mission outcomes. These adverse effects could be greatly magnified 

if the DOI makes this poor-quality data accessible through the GeoPlatform, and the data is then 

relied on by Federal and non-Federal users for decision making and resource allocation. In 

addition, by not consistently searching the GeoPlatform, the DOI risks expending funds for 

geospatial data that may already be available at no cost. 

We found these deficiencies occurred because the DOI had not established an effective oversight 

program to satisfy all the Act’s requirements. We make two recommendations to strengthen the 

DOI’s governance practices for its geospatial data program. In response to our draft report, the 

DOI concurred with both recommendations and stated it is working to implement them. We 

consider both recommendations resolved but not implemented. We will refer the 

recommendations to the Office of Policy, Management and Budget for tracking implementation. 

2 
1. Complying with the standard for geospatial data, including information about geospatial 

data sets, also known as metadata, as established under Section 757 (We did not assess 

this requirement in fiscal year (FY) 2020. See Appendix 1 for additional details.) 

2. Preparing, maintaining, publishing, and implementing a strategy for advancing 

geographic information and related geospatial data and activities appropriate to the 

mission of the DOI, in support of the strategic plan for the National Spatial Data 

Infrastructure (NSDI) prepared under Section 755(c) 

3. Collecting, maintaining, disseminating, and preserving geospatial data, such that the 

resulting data, information, or products can be readily shared with other Federal agencies 

and non-Federal users 

 

4. Promoting the integration of geospatial data from all sources 

 

5. Ensuring that data information products and other records created in geospatial data and 

activities are included on agency record schedules that have been approved by the 

National Archives and Records Administration (NARA) 

 

6. Allocating resources to fulfill the responsibilities of effective geospatial data collection, 

production, and stewardship regarding related activities of the DOI, and as necessary to 

support the activities of the Federal Geographic Data Committee (FGDC) 

 

7. Using the geospatial data standards, including those for metadata, and other appropriate 

standards, including documenting geospatial data with the relevant metadata and making 

metadata available through the GeoPlatform 

 

8. Coordinating and working with other Federal agencies; agencies of State, tribal, and local 

governments; institutions of higher education; and the private sector to efficiently and 

cost effectively collect, integrate, maintain, disseminate, and preserve geospatial data, 

building on existing non-Federal geospatial data to the extent possible 

 

Introduction 

Objective 

We evaluated the status of the U.S. Department of the Interior’s (DOI’s) compliance with 

geospatial data management as defined by the Geospatial Data Act of 2018. 

Specifically, the Act mandates that not less than once every 2 years the Inspector General submit 

to Congress a report of the agency’s collection, production, acquisition, maintenance, 

distribution, use, and preservation of geospatial data that reviews agency responsibilities based 

on 15 specific requirements: 

3 
 

 

9. Using geospatial information to make Federal geospatial information and services more 

useful to the public, enhance operations, support decision making, and enhance reporting 

to the public and to Congress 

 

10. Protecting personal privacy and maintaining confidentiality according to Federal policy 

and law 

 

11. Determining, when applicable, whether declassified data can contribute to and become a 

part of the NSDI 

 

12. Searching all sources, including the GeoPlatform, to determine if existing Federal, State, 

local, or private geospatial data meets DOI needs before expending funds for geospatial 

data collection 

 

13, Assuring, to the maximum extent practicable, that a person receiving Federal funds for 

geospatial data collection provides high-quality data 

 

14, Appointing a contact to coordinate with the lead covered agencies for collection, 

acquisition, maintenance, and dissemination of the National Geospatial Data Asset 

(NGDA) data themes used by the DOI 

 

15. Complying with the limitation on the use of Federal funds under Section 759a (We did 

not assess this requirement in FY 2020. See Appendix 1 for additional details.) 

Scope Limitation 

We did not evaluate requirements 1 and 15 because they were excluded from the evaluation 

scope. Appendix 1 provides further details regarding our scope and methodology. 

Background 

Geospatial data plays a critical role in decision making and ensures the United States can quickly 

and effectively respond to the Nation’s priorities, including disaster and national security events; 

lead the world in global spatial infrastructure; and provide transparency and accountability to its 

citizens. 

Today, geospatial data and technology represent major investments on the part of the Federal 

Government because nearly everything that happens in the public realm happens in the context 

of geography. Federal sources have estimated that more than 80 percent of the data produced by 

Federal agencies have a geospatial component. 

In addition, multiple Federal agencies provide services at the same geographic locations and may 

independently collect similar geospatial data about those locations, raising the question of how 

well the Federal Government coordinates its investments in geospatial data. As such, in 1994, the 

President issued Executive Order 12906 to address wasteful duplication and incompatibility of 

geospatial data and develop the NSDI. 

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The NSDI provides a structure to facilitate the efficient collection, sharing, and dissemination of 

geospatial data among all levels of government, the private sector, and the public. The 

NSDI consists of data themes, standards, metadata, a clearinghouse, and partnerships. In 2002, 

the U.S. Office of Management and Budget (OMB) revised OMB Circular A-16 to further 

describe the components of the NSDI and agency responsibilities for acquiring, maintaining, 

distributing, using, and preserving geospatial data. The Circular describes the following five 

components of the NSDI: 

• Data themes: Topics of national significance as listed in OMB Circular A-16, which 

identified 34 data themes and the lead agency or agencies for each theme. Each data 

theme consists of one or more electronic data records, known as datasets. 

• Standards: Provide common and repeatable rules or guidelines for the development, 

documentation, and exchange of geospatial datasets. 

• Metadata: Information about datasets, such as content, source, accuracy, method of 

collection, and point of contact. Metadata are used to facilitate the search of and access to 

datasets within a data library or clearinghouse and enable potential users to determine the 

data’s applicability for their use. 

• National Spatial Data Clearinghouse (referred to as the GeoPlatform, 

geoplatform.gov): Provides a searchable catalog of geospatial data and related artifacts 

that are available from Federal and non-Federal sources. By searching the GeoPlatform, 

Federal agencies can determine if suitable geospatial data are available before expending 

funds on data. Moreover, Executive Order 12906 and OMB Circular A-16 require 

Federal agencies to identify their existing and planned geospatial investments and to 

search the GeoPlatform for cost-saving opportunities before expending funds on new 

geospatial data. 

• Partnerships: All stakeholders (e.g., Federal, tribal, State, and local governments, as 

well as academic institutions) should be involved in the development of the NSDI. 

In 2010, the OMB provided supplemental guidance that further defined and clarified Circular 

A-16 and focused on managing geospatial data as a capital asset. The guidance established the 

concept of NGDAs, which are the most significant data themes and datasets. The guidance 

sought to create a Governmentwide NGDA portfolio by encouraging agencies to adopt and 

implement a portfolio management approach for their geospatial data investments. According to 

the FGDC, as of July 2020, there are 17 data themes and more than 176 NGDA datasets that 

compose the NGDA portfolio. 

The DOI’s U.S. Geological Survey (USGS) plays a leading role in the Federal collection, 

maintenance, and management of geospatial data by housing the FGDC—a 32-member 

interagency committee composed of representatives from the Executive Office of the President 

and Cabinet-level and independent Federal agencies that is responsible for coordinating 

geospatial data activities. For more than two decades, the FGDC has worked to reduce 

duplication and increase the interoperability of federally sourced geospatial data. The FGDC has 

5 
also established common standards across the Federal Government so agencies can share and use 

all data collected and has determined authoritative sources for a set of geospatial data themes, 

ensuring that agencies do not produce the same data. 

Geospatial data supports critical missions across the DOI, including: 

I. Overseeing wildland fire and post-fire Burned Area Emergency response 

2. Monitoring hurricane recovery and land changes 

3. Conducting computational modeling of topography-influenced volcano hazards, such as 

lahars (volcanic mudflows), that can travel downstream and affect nearby populated areas 

4. Completing emergency management planning for dam-break scenarios 

5. Providing habitat information in support of the Endangered Species Act 

6. Locating and recording historic properties, such as archeological sites and historic 

structures 

7. Generating maps for studies and special projects, such as reservoir operations pilots, 

feasibility studies, and planning studies 

Of the 17 total data themes, the DOI is responsible for 9 data themes, representing more than 50 

percent of the Federal Government’s NGDA portfolio (see Appendix 2). From FYs 2018 through 

2020, the DOI has spent at least $100 million purchasing geospatial data from third-party 

contractors. 

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Findings 

The DOI has begun to implement many of the requirements of the Geospatial Data Act of 2018. 

For example, it has promoted the integration of geospatial data from all sources; allocated 

resources for geospatial data collection, production, and stewardship; and coordinated with 

Federal and non-Federal entities to effectively manage geospatial data. 

We found, however, that the DOI risks using poor-quality data to support decision making and 

resource allocation because the chief data officer did not ensure that all bureaus performed 

quality checks on geospatial data purchased from third parties. Those bureaus that did perform 

quality-control tests of purchased data could not provide evidence that the testing performed 

conformed with data quality standards endorsed by the FGDC. 

We also found that the DOI risks expending funds to purchase geospatial data that may be freely 

available because the bureaus did not consistently search the GeoPlatform to check whether 

existing Federal, State, local, or private geospatial data met their needs before purchasing 

geospatial data. 

The DOI Must Ensure It Receives High-Quality Geospatial 

Data Purchased From Third Parties 

The Act requires agencies to assure, to the maximum extent practicable, that those receiving 

Federal funds for geospatial data collection provides high-quality data. Data quality standards 

help ensure that geospatial data are complete, accurate, and precise, but the DOI did not require 

bureaus to perform quality-control tests to ensure geospatial data purchased from third parties 

met quality standards approved by the FGDC, as required by the Geospatial Data Act of 2018. 

Specifically, the DOI’s chief data officer had not implemented policies and procedures for the 

bureaus to follow when purchasing geospatial data from third parties. We found that the bureaus’ 

contracts with data providers did not always include requirements to ensure that applicable data 

quality standards were met. 

Documenting geospatial data resources according to data standards results in records that 

enhance the effectiveness of search results from Data.gov and the GeoPlatform. OMB Circular 

A-16 requires the FGDC to promulgate standards for geospatial data. In 2016, the FGDC 

endorsed International Organization for Standardization (ISO) metadata and data quality 

standards: ISO 19115-1:2014, Geographic Information — Metadata — Part: 1 Fundamentals 

and ISO 19157:2013 Geographic information — Data quality, which agencies publishing to 

Data.gov and the GeoPlatform are expected to follow. Moreover, the Geospatial Data Act of 

2018 requires the DOI to ensure that anyone who receives Federal funds for geospatial data 

collection provide high-quality data that is complete, accurate, and precise. In September 2013, 

the Office of the Chief Information Officer (OCIO) issued OCIO Directive 2013-002, which 

states that the senior agency official for geospatial information must implement, monitor, and 

administer the Directive and ensure the DOI complies with the data-quality requirements under 

the Act and OMB Circular A-16. 

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We reviewed all nine of DOI’s bureaus that have geospatial data responsibilities. During our 

review, we found that two bureaus—the Bureau of Indian Affairs (BIA) and the Office of 

Surface Mining Reclamation and Enforcement (OSMRE)—have not purchased geospatial data 

from third parties. Of the seven bureaus that do purchase geospatial data (Bureau of Land 

Management (BLM), Bureau of Ocean Energy Management (BOEM), Bureau of Reclamation 

(BOR), Bureau of Safety and Environmental Enforcement (BSEE), National Park Service (NPS) 

U.S. Fish and Wildlife Service (FWS), and USGS), we found that one (NPS) does not have 

procedures in place to ensure data quality. The remaining six bureaus performed quality control 

checks on the data purchased. For example, the USGS’ quality controls for the 3D Elevation 

Program contract data involve a series of steps to validate data, including the use of software 

programs that check the geospatial data and metadata before it can be used in national maps. 

Further, these checks are specific to each data type and include meeting required picture 

resolutions and scientific measurements, in addition to running automated validation tools to 

ensure the accuracy of the data. These checks are imperative to ensure that the data can be used 

in national maps and provide foundational elevation information for earth science studies and 

mapping applications. 

The bureaus did not provide evidence that the data quality checks performed conformed with 

meta and data quality standards endorsed by the FGDC. DOI’s chief data officer had not 

approved the current bureau-specific approach to data quality control nor verified that the 

approach conforms with FGDC data and meta data quality standards. As such, the DOI risks 

acquiring data that does not meet quality standards. 

The DOI uses geospatial data for decision making and for directing resources to accomplish its 

varied missions. If the data used are incomplete, inaccurate, or imprecise, decisions made based 

on poor-quality data may result in the misdirection of resources with the potential to adversely 

affect mission outcomes. The problem is greatly amplified if poor-quality data is then made 

available on the GeoPlatform, where Federal and non-Federal users may rely on it. While most 

bureaus have taken the initiative to ensure data quality, a Departmentwide approach would help 

ensure all bureaus use consistent contract language related to quality standards and protect more 

than $100 million a year in Federal funds spent on this data. 

Recommendation 

We recommend that the DOI’s chief data officer: 

1. Ensure that bureau contracts with third-party providers of geospatial data meet 

FGDC-endorsed data and metadata quality standards 

8 
 

 

 

 

 

 

 

 

 

 

 

The DOI Risks Expending Funds on Geospatial Data That 

May Already Exist on the GeoPlatform 

The Act requires agencies to search all sources, including the GeoPlatform, to determine if 

existing Federal, State, local, or private geospatial data meets agency needs before expending 

funds for geospatial data collection. We determined that the DOI has not ensured its bureaus 

search the GeoPlatform, the recognized clearinghouse for geospatial data, for existing data 

before expending Federal funds on data collection. According to the DOI senior agency official 

for geospatial information, the DOI performs these searches at the bureau level, through system 

searches and the contracting process. We asked the bureaus to describe how they search all 

sources, including the GeoPlatform, to determine if existing Federal, State, local, or private 

geospatial data meets the bureau’s needs before expending funds for geospatial data 

collection. Although the seven bureaus that purchase data stated they search sources before 

purchasing data, only two specifically stated they search the GeoPlatform. 

The GeoPlatform contains a searchable catalog of geospatial data and related content available 

from Federal and non-Federal sources. For example, searching the GeoPlatform for weatherrelated geospatial data using the keywords “weather map” returns links to weather maps 

provided by the National Oceanic and Atmospheric Administration, Weather Underground, and 

other sources. The GeoPlatform provides a robust sorting and searching capability allowing users 

to access geospatial data and related content by keywords, dataset, publisher organization, 

geographic extent, data themes, community association, date ranges, and other descriptors. 

OMB Circular A-16 requires Federal agencies to identify their existing and planned geospatial 

investments and to search the GeoPlatform for cost-saving opportunities before acquiring new 

geospatial data to reduce duplicated effort and enhance sharing of geospatial data. In addition, 

OCIO Directive 2013-002 requires bureaus to ensure that existing data or acquisitions planned 

by other organizations will meet their requirements before expending funds to collect or 

purchase new geospatial data. 

By not using the GeoPlatform’s search capabilities, the DOI risks spending Federal funds on 

geospatial data that already exists. In addition, the GeoPlatform is meant to serve as a central 

clearinghouse to reduce duplication of effort and cost and increase return on existing geospatial 

investments by promoting the reuse of data. During fieldwork, the DOI’s chief data officer stated 

that, at that time, he did not plan to implement controls to ensure bureaus meet Federal and DOI 

requirements to prevent duplicative spending until at least FY 2021. 

Recommendation 

We recommend that the DOI’s chief data officer: 

2. Ensure that all bureaus and offices search the GeoPlatform to determine if 

existing Federal, State, local, or private data meets the DOI’s needs before 

expending funds for data collection 

9 
The DOI’s Status in Meeting Other Requirements of the 

Geospatial Data Act of 2018 

The Act requires the Inspector General to report to Congress on all 15 requirements related to 

geospatial data. We found that the DOI is working toward meeting 11 of the 13 Geospatial Data 

Act requirements we evaluated. For example, in 2016, the DOI assigned an executive to manage 

Departmentwide collection, acquisition, maintenance, and dissemination of its geospatial data, 

and is currently implementing strategy for advancing geospatial data and related activities to 

support bureau missions. The DOI made declassified data from the NSDI available pursuant to 

Executive Order 12951. We also found evidence that the DOI readily shares geospatial data 

through the GeoPlatform with other Federal agencies and non-Federal users. In addition, the DOI 

is working on: 

• Promoting the integration of geospatial data from all sources 

• Allocating resources for geospatial data collection, production, and stewardship 

• Documenting geospatial data on the GeoPlatform using the relevant data and metadata 

standards 

• Ensuring that bureau geospatial data and activities are included on agency record 

schedules that have been approved by the National Archives and Records Administration 

• Coordinating with Federal and non-Federal entities to effectively manage geospatial data 

• Using geospatial data to enhance operations, support decision making, and enhance 

reporting to Congress 

• Protecting personally identifiable information stored on the GeoPlatform from 

unauthorized access in accordance with Federal policy and law 

Appendix 3 provides a summary of the DOI’s progress toward meeting the requirements. 

10 
 

 

 

 

1. Ensure that bureau contracts with third-party providers of geospatial data meet FGDCendorsed data and metadata quality standards 

2. Ensure that all bureaus and offices search the GeoPlatform to determine if existing 

Federal, State, local, or private data meets the DOI’s needs before expending funds for 

data collection 

Conclusion and Recommendations 

Conclusion 

The DOI is a major user, producer, provider, and buyer of geospatial data, and its bureaus rely on 

geospatial data to accomplish their varied missions. The DOI operates the GeoPlatform, a widely 

used Federal clearinghouse for geospatial data from Federal and non-Federal sources. In addition 

to producing this data, the DOI has also spent over $100 million a year purchasing geospatial 

data and services from third parties. 

While we found that the DOI is working to satisfy 11 of the 13 geospatial data requirements we 

reviewed, the DOI must ensure it receives high-quality geospatial data purchased from third 

parties and that it does not spend Federal funds on duplicative geospatial data. 

Recommendations Summary 

We recommend that the DOI’s chief data officer: 

DOI Response 

In response to our draft report, the Acting Assistant Secretary for Policy, Management and 

Budget concurred with both recommendations and stated the DOI is working to implement them 

(see Appendix 4). The DOI stated it will issue guidance to bureaus and offices requiring them to 

consider during the acquisition process whether geospatial data will be collected. If so, the 

guidance will require the bureaus and offices to include relevant language in the contract. The 

DOI stated it will also issue policy to ensure that all bureaus and offices search the GeoPlatform 

to determine whether existing Federal, State, local, or private data meets the DOI’s needs before 

expending funds for data collection. The DOI provided a November 1, 2020 target date for 

completion of this policy. Based on the DOI’s response, we consider both recommendations 

resolved but not implemented. We will refer the recommendations to the Office of Policy, 

Management and Budget for tracking implementation (see Appendix 5). 

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Appendix 1: Scope and Methodology 

Scope 

We evaluated the status of the U.S. Department of the Interior’s (DOI’s) compliance with the 

management of geospatial data as defined by the Geospatial Data Act of 2018. This Act requires 

the Office of Inspector General (OIG) to report on the agency’s collection, production, 

acquisition, maintenance, distribution, use, and preservation of geospatial data according to 15 

requirements (see “Background”). 

Scope Limitation 

In March 2020, the Council of the Inspectors General on Integrity and Efficiency (CIGIE) issued 

a letter to the U.S. Congress narrowing the scope of the fiscal year (FY) 2020 report to exclude 2 

of the 15 requirements (requirements 1 and 15). CIGIE excluded covered agency compliance 

with data standards and limitation on using public funds for geospatial data management 

activities because the standards the reports should use to evaluate compliance are unclear and 

because Federal law establishes a 5-year implementation period before limiting the use of public 

funds for noncompliant activities. Further, CIGIE’s unified approach allows for latitude for the 

OIG to define audit procedures. For the current year’s report, we performed an evaluation of the 

DOI’s compliance with the Geospatial Data Act of 2018 under the CIGIE Blue Book Quality 

Standards for Inspection and Evaluation. 

Methodology 

To evaluate the DOI’s geospatial data management, we interviewed the DOI’s chief data officer 

and reviewed documentation related to the DOI’s oversight of geospatial data. Because this 

evaluation is the first review completed under our biannual obligation, we sought to establish a 

baseline of the activities occurring at the DOI to comply with the Act’s requirements. As such, 

we selected a sample of nine DOI bureaus, which all have responsibilities for geospatial data, to 

evaluate the DOI’s oversight: 

• Bureau of Indian Affairs 

• Bureau of Land Management 

• Bureau of Ocean Energy Management 

• Bureau of Reclamation 

• Bureau of Safety and Environmental Enforcement 

• National Park Service 

12 
• U.S. Fish and Wildlife Service 

• U.S. Geological Survey 

We relied on the chief data officer and the bureaus to provide written responses and evidence of 

t

w

heir performance with the objectives we evaluated. To accomplish our evaluation objectives, 

e: 

• Reviewed relevant criteria, such as the Geospatial Data Act of 2018, Office of 

Management and Budget Circular A-16, and Executive Order 12951 

• Reviewed Federal Geographic Data Committee (FGDC) guidance published at fgdc.gov 

• Reviewed DOI and bureau policies and memoranda related to the management and 

oversight of geospatial data 

• Searched geospatial data on the GeoPlatform (geoplatform.gov) and Data.gov 

• Reviewed the position description and nomination documentation for the chief data 

officer as the DOI’s senior agency official for geospatial information 

• Inspected evidence of meetings to coordinate geospatial data collaboration activities, 

such as meeting minutes and agendas 

• Examined privacy impact assessments 

• Reviewed screenshots and documentation citing examples of the DOI’s use of geospatial 

data 

• Inspected agency and bureau budget data and resource allocations related to geospatial 

data collection, production, and stewardship 

• Interviewed the executive director of the FGDC to better understand data quality 

standards 

• Asked bureau records officers how geospatial data is included on National Archives and 

Records Administration approved record schedules 

• Reviewed data checks and contract clauses for geospatial data obtained by the DOI 

through third-party contracts 

• Office of Surface Mining Reclamation and Enforcement 

13 
 

Audits and evaluations seek answers to the same basic questions as part of examining a program: 

• What is current program performance? 

• Does current performance meet required standards? 

• If current performance materially departs from standards, what corrective action is 

needed to improve performance? 

As part of our evaluation, we collected and evaluated sufficient, competent evidence for each 

objective through inquiry and inspection. We independently evaluated the evidence to determine 

the DOI’s compliance with the requirements of the Act. When the DOI’s performance did not 

meet the standard, we made recommendations to address deficiencies. 

We conducted our evaluation in accordance with the Quality Standards for Inspection and 

Evaluation as put forth by CIGIE. We believe that the work performed provides a reasonable 

basis for our conclusions and recommendations. 

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NGDA Theme NGDA Theme Description Theme Leads 

Biodiversity and 

Ecosystems 

Pertains to or describes the dynamic processes, 

interactions, distributions, and relationships 

between and among organisms and their 

environments 

U.S. Geological 

Survey (USGS) 

Cadastre 

Past, current, and future rights and interests in 

real property, including the spatial information 

necessary to describe geographic extents 

Bureau of Land 

Management 

Cultural 

Resources 

Features and characteristics of a collection of 

places of significance in history, architecture, 

engineering, or society (includes national 

monuments and icons) 

National Park 

Service 

Elevation 

The measured vertical position of the earth’s 

surface, other landscape, or underwater depth of 

ocean floors or lake floor 

USGS 

Geology 

Geographically referenced data pertaining to the 

origin, history, composition, structure, features, 

and processes of the solid earth, both onshore and 

offshore 

Bureau of 

Ocean Energy 

Management 

and USGS 

Imagery 

Land Use-Land 

Cover 

Utilities 

Georeferenced images of the earth's surface, 

which have been collected via aerial photography 

or satellite data 

Natural and manmade surface features that cover 

the land (land cover) and to the primary ways in 

which land cover is used by humans (land use) 

Means, aids, and use of facilities for producing, 

conveying, distributing, processing, or disposing of 

public and private commodities including power, 

energy, communications, natural gas, and water 

(includes subthemes for energy, drinking water 

and water treatment, and communications) 

USGS 

USGS 

Bureau of 

Safety and 

Environmental 

Enforcement 

Water – Inland 

Interior hydrologic features and characteristics, 

including classification, measurements, location, 

and extent (includes aquifers, watersheds, 

wetlands, navigation, water quality, water 

quantity, and groundwater information) 

U.S. Fish and 

Wildlife Service 

and USGS 

Appendix 2: Description of the U.S. 

Department of the Interior’s National 

Geospatial Data Asset (NGDA) Themes 

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Requirement Status 

Requirement 1: Complying with 

the standard for geospatial data, 

including information about 

geospatial data sets, also known 

as metadata, as established 

under Section 757 

We did not evaluate this objective because the Council 

of the Inspectors General for Integrity and Efficiency 

(CIGIE) excluded it from the scope for fiscal year (FY) 

2020 (see Appendix 1: Scope and Methodology, “Scope 

Limitation”). 

Requirement 2: Preparing, 

maintaining, publishing, and 

implementing a strategy for 

advancing geographic information 

and related geospatial data and 

activities appropriate to the 

mission of the U.S. Department of 

the Interior (DOI), in support of 

the strategic plan for the National 

Spatial Data Infrastructure 

(NSDI) prepared under Section 

755(c) 

Although the DOI and its bureaus have made progress 

in publishing draft strategic plans for geospatial data 

and activities, it has not finalized these plans due to 

dependency on the Federal Geographic Data 

Committee’s (FGDC’s) actions, such as publishing its 

own plan and providing reporting requirements for 

Federal agencies. Further, the deadline to submit these 

strategic plans is not until December 2020. 

Requirement 3: Collecting, 

maintaining, disseminating, and 

preserving geospatial data, such 

that the resulting data, 

information, or products can be 

readily shared with other Federal 

agencies and non-Federal users 

The policies and procedures used to share and publish 

geospatial information varies across the bureaus and 

data type. Office of the Chief Information Officer (OCIO) 

Directive 2013-002 contained requirements for bureaus 

to share geospatial information in accordance with 

Office of Management and Budget (OMB) Circular A-16 

and for the senior agency official for geospatial 

information to issue guidance and procedures to be 

followed for carrying out these requirements. 

Although the senior agency official for geospatial 

information has not issued policies and procedures to 

instruct the bureaus on how to implement the policy, 

the DOI’s bureaus share information with the public and 

other Federal agencies by publishing information on the 

GeoPlatform or their own agency websites and 

geographic information systems (GIS) services. 

The DOI promotes the integration of geospatial data 

Requirement 4: Promoting the from Federal agencies; agencies of State, tribal, or local 

integration of geospatial data governments; institutions of higher education; and 

from all sources private-sector entities. The DOI’s Interior Geospatial 

Emergency Management System web application 

Appendix 3: The U.S. Department of the 

Interior’s Status in Meeting the 

Requirements of the Geospatial Data Act 

of 2018 

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Requirement Status 

Requirement 5: Ensuring that 

data information products and 

other records created in 

geospatial data and activities are 

included on agency record 

schedules that have been 

approved by the National 

Archives and Records 

Administration (NARA) 

integrates many data sources, including the Office of 

Emergency Management, Office of Wildland Fire, the 

Bureau of Land Management (BLM), and the OCIO. The 

DOI provided evidence of data integration from other 

Federal agencies, such as the U.S. Department of 

Transportation and NASA, and tribal governments, local 

governments, and institutions of higher education, such 

as Alaskan local governments, Pacific local 

governments, and the University of California. 

Further, the DOI has established an enterprise license 

agreement with the Environmental Systems Research 

Institute (ESRI) to procure GIS technology for all DOI 

bureaus and offices to promote data integration. To 

reduce the need for unique solutions for individual 

bureaus, the DOI implemented the Open Geospatial 

Consortium standard on all geospatial data for easier 

integration. 

NARA establishes standards for the retention of 

permanent records and assists Federal agencies in 

applying the standards to records in their custody. 

Record schedules detail which Federal records have 

temporary value and may be destroyed, and which 

Federal records have permanent value and must be 

transferred to NARA (36 C.F.R. § 1220.12). Record 

schedules must be approved by NARA before 

implementation. The DOI chief data officer stated that 

he does not oversee record schedules. 

We asked each bureau records officer to determine 

whether the bureaus currently have NARA-approved 

record schedules in place for geospatial data. Eight of 

the nine bureaus reported having a schedule in place 

that covers geospatial data. 

We did not validate the record schedules or the 

bureau’s compliance with transferring data according to 

these schedules. Bureaus stated challenges related to 

transferring data to NARA, such as issues with 

acceptable formats when transferring data via the 

Electronic Records Archives system (BLM), legal holds 

and freezes on records (Bureau of Safety and 

Environmental Enforcement (BSEE)), program issues 

(BSEE), and out-of-date record schedules (U.S. 

Geological Survey (USGS)). 

Requirement 6: Allocating 

resources to fulfill the 

responsibilities of effective 

geospatial data collection, 

production, and stewardship 

The DOI has a chief data officer/geospatial information 

officer who supervises three full time employees 

supporting geospatial enterprise contracts, enterprise 

geospatial systems management and geospatial data 

management/stewardship, and enterprise data 

17 
Requirement Status 

regarding related activities of the 

DOI, and as necessary to support 

the activities of the FGDC 

management and governance, which includes geospatial 

data. 

We determined that the following lead agencies have 

budget documentation that included resource 

allocations to fulfill the requirements as theme leads: 

Biodiversity and Ecosystems (USGS), Cadastre (BLM), 

Cultural Resources (National Park Service ( NPS)), 

Elevation (USGS), Geo logy (Bureau of Ocean Energy 

Management and USGS), Imagery (USGS), Land Use -

Land Cover (USGS), Utilities (BSEE), and Water Inland 

Data (U.S. Fish and Wildlife Service and USGS). 

Requirement 7: Using the 

geospatial data standards, 

including those for metadata, and 

other appropriate standards, 

including documenting geospatial 

data with the relevant metadata 

and making metadata available 

through the GeoPlatform 

Per review of the GeoPlatform, 6 of 9 bureaus are 

named as the lead agency for 9 data themes covering 

75 datasets. We reviewed two datasets per data theme 

where a DOI bureau was the lead agency and found 

that the DOI provides geospatial data through the 

GeoPlatform. 

Requirement 8: Coordinating 

and working with other Federal 

agencies; agencies of State, 

tribal, and local governments; 

institutions of higher education; 

and the private sector to 

efficiently and cost effectively 

collect, integrate, maintain, 

disseminate, and preserve 

geospatial data, building on 

existing non-Federal geospatial 

data to the extent possible 

The DOI provided meeting minutes and memorand a of 

understanding demonstrating its coordination with other 

Federal agencies; agencies of State, tribal, and local 

governments; institutions of higher education ; and the 

private sector. For example: 

• The BLM maintains two publicly available geospatial 

data publication sites, hosts data and geospatial 

products on the ESRI ArcGIS system, participates 

on the Federal Lands Working Group and other 

multiagency groups, and leads the FGDC’s 

Cadastral Subcommittee. 

• The NPS has projects with the National Boundaries 

Group, the FGDC, the National Geospatial Advisory 

Committee, several universities, and the 

Cooperative Ecosystems Studies Unit. 

• The USGS participates in the Consortium of 

Universities for the Advancement of Hydrologic 

Studies and works with the National Geospatial 

Advisory Committee’s Landsat Advisory Group 

subcommittee, the AmericaView Consortium, 

satellite business partners, commercial data 

providers, the International Charter on Space and 

Major Disasters, the International Group on Earth 

Observations, the U.S. Group o n Earth 

Observations, the Committee on Earth Observation 

Satellites, the European Commission, the E uropean 

Space Agency, and other foreign remote sensing 

18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  

  

 

 

 

 

 

 

 

 

Requirement Status 

Requirement 9: Using geospatial 

information to make Federal 

geospatial information and 

services more useful to the 

public, enhance operations, 

support decision making, and 

enhance reporting to the public 

and to Congress 

system cooperators on the USGS National Land 

Imaging Program. 

• Further, the DOI sponsors the National Geospatial 

Advisory Group, which provides advice and 

recommendations relating to the management of 

Federal and national geospatial programs, the 

development of the NSDI, and implementation of 

the Geospatial Data Act. The group also reviews 

and comments on geospatial policy and 

management issues and ensures the views of 

representatives of non-Federal interested parties 

involved in national geospatial activities are 

conveyed to the FGDC. 

• The DOI coordinates geospatial data with the 

private sector and other Federal agencies through 

the FGDC Homeland Infrastructure Foundation Level 

Data Subcommittee. The DOI also serves on the 

Civil Agency Committee to facilitate the appropriate 

civil use of overhead remote sensing technologies 

and data collected by the military and intelligence 

overhead capabilities. 

The DOI stated it uses geospatial information in many 

ways to ensure it is useful to the public and enhances 

operations, decision making, and reporting to the public 

and Congress. For example, the DOI uses this data to: 

• Create interactive maps with geospatial information 

about visiting BLM-managed public lands, 

including recreation sites, mountain biking trails, 

and climbing opportunities 

• Focus geospatial strategy on collecting, organizing, 

and using baseline resource management 

data, such as fenceline and transportation data for 

enhancing predictions based on geospatial data

• Develop a National Sand Inventory to support 

oversight of requests for sand and mixed sediment 

from Federal waters and provide beach nourishment 

and coastal restoration projects 

• Approve or decommission pipeline processes 

• Analyze hurricane impacts of offshore infrastructure 

and production 

• Write land acquisition proposals for both the Land 

and Water Conservation Fund and the Migratory 

19 
Requirement Status 

•

•

•

•

•

Bird Conservation Commission 

Develop a web mapping tool called NPMap Live , 

which allows national parks to provide real -time 

information of road closures or other events on 

maps 

Support search and rescue operations and 

automated incident notifications through ESRI 

Survey123 

Conduct partial inspections and cont inuous 

monitoring of mines with web-mapping systems and 

satellite imagery 

Create comprehensive, digital topographic base 

maps for all 50 States that are used for a variety of 

applications ranging from scientific and engineering 

projects to recreational use 

Continuously monitor the earth by maintaining a 

readily available record of information displaying 

the status of the Nation’s resources and 

environment 

Requirement 10: Protecting 

personal privacy and maintaining 

confidentiality according to 

Federal policy and law 

We reviewed privacy impact assessments (PIAs) to 

determine the current state of the DOI’s compliance 

with the standard for geospatial data, including whether 

the DOI protects personal privacy and maintains 

confidentiality according t o Federal policy and whether 

law complies with the Geospatial Data Act of 2018. We 

found that the DOI has two systems that contain 

records of personally identifiable information (PII) 

related to geospatial data: ArcGIS and the GeoPlatform. 

The PII for thes e systems is mostly related to the 

creation and management of user accounts, including 

data such as email addresses (personal or work), the 

full names of the users, and user workplaces. We also 

confirmed through inspection of the PIAs that mitigating 

controls to protect privacy were documented for each 

system. 

Requirement 11: Determining, 

when applicable, whether 

declassified data can contribute to 

and become a part of the NSDI 

OMB Circular A-16 requires Federal agencies to 

determine, when applicable, data declassified pursuant 

to Executive Order 12951 that can contribute to and 

become a part of the NSDI. On February 24, 1995, 

Executive Order 12951 directed the declassification o f 

intelligence imagery acquired by the first generation of 

United States photo -reconnaissance satellites from 1959 

– 1980, including the systems code -named CORONA, 

ARGON, and LANYARD. Under this order, the 

declassified imagery was transferred to the USGS to 

20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Requirement Status 

Requirement 12: Searching all 

sources, including the 

GeoPlatform, to determine if 

existing Federal, State, local, or 

private geospatial data meets 

DOI needs before expending 

funds for geospatial data 

collection 

ensure the public had access to this data. We reviewed 

Data.gov (part of the NSDI) and noted that the USGS 

released 883,150 images from the CORONA, ARGON, 

and LANYARD systems as part of the NSDI, and the 

images are available for public use. 

We found that the DOI risks expending Federal funds on 

data that is already available because it has not defined 

procedures to ensure that all bureaus collecting 

geospatial data are searching the GeoPlatform before 

purchasing data. 

Requirement 13: Assuring, to 

the maximum extent practicable, 

that a person receiving Federal 

funds for geospatial data 

collection provides high-quality 

data 

We found that the DOI does not have policies, 

procedures, or controls to monitor the bureaus to 

ensure that third parties receiving Federal funds for 

geospatial data collection provide high-quality data. 

Requirement 14: Appointing a 

contact to coordinate with the 

lead covered agencies for 

collection, acquisition, 

maintenance, and dissemination 

of the National Geospatial Data 

Asset data themes used by the 

DOI 

We reviewed the OCIO’s 2016 memorandum 

designating the chief data officer as the DOI’s senior 

agency official for geospatial information. Pursuant to 

the OCIO’s designation, the senior agency official for 

geospatial information oversees, coordinates, and 

facilitates the DOI’s implementation of geospatialrelated requirements, policies, activities, and 

investments. The senior agency official for geospatial 

information also serves as the DOI’s representative on 

the FGDC, pursuant to OMB Circular A-16. 

We also reviewed the chief data officer’s position 

description and determined that the chief data officer 

oversees and coordinates geospatial responsibilities. 

Further, the position description states that the chief 

data officer coordinates and works in partnership with 

Federal, State, tribal, and local government agencies; 

academia; and the private sector to efficiently and costeffectively collect, integrate, maintain, disseminate, and 

preserve geospatial data. 

Requirement 15: Complying We did not evaluate this objective because CIGIE 

with the limitation on the use of excluded it from the scope for FY 2020 (see Appendix 1: 

Federal funds under Section 759a Scope and Methodology, “Scope Limitation”). 

21 
 

 

Appendix 4: Response to Draft Report 

The U.S. Department of the Interior’s response to our draft report follows on page 23. 

22 
United States Department of the Interior 

OFFICE OF THE SECRETARY 

Washington, DC 20240 

September 30, 2020 

Memorandum 

To: Mark Lee Greenblatt 

Inspector General Digitally signed by SCOTT 

CAMERON 

Date: 2020 09 30 12:58:41 -04'00' From: Scott J. Cameron 

Acting Assistant Secretaiy for Policy, Management and Budget 

Subject: Draft Evaluation Repo1t- The U.S. Depa1tment of the Interior Needs to 

Strengthen Governance Practices to Improve Its Management of Geospatial Data 

Repo1t No. 2020-ITA-020 

We appreciate the work represented within this repo1t, and we are pleased to concur with the 

recommendations given within the repo1t. 

Please find attached the U.S. Depaitment of the Interior's (DOI) management response, which 

includes our coITective action, tai·get completion date, and the title of the official responsible for 

implementing recommendation. 

If your team members have any questions, please direct them to Richard Westmai·k, Chief, 

Compliance and Audit Management Officer, @ios.doi.gov. 

Attachment: 

Management Response to Office of Inspector General 2020-ITA-020 Draft Geospatial Data 

Act 2018 Report 

cc: William E. Vajda, Chief Infonnation Officer, Office of the Chief Infonnation Officer 

(OCIO) 

Andrea Brandon, Deputy Assistant Secreta1y for Budget, Finance, Grants and 

Acquisition 

Cara Whitehead, Director, Office of Grants Management 

Megan Olsen, Senior Procurement Executive and Director, Office of Acquisition and 

Prope1ty Management 

Thomas 0. Dabolt, Chief Data Officer, OCIO 

Richai·d Westmark, Chief, Compliance and Audit Management Officer, OCIO 

Dr. Chadrick Minnifield, Chief, Internal Control and Audit Follow-up, Office of 

Financial Management 

23 
 

Management Response to Office of Inspector General 2020-ITA-020 

Draft Geospatial Act 2018 Report 

We agree that as the Federal Geographic Data Committee (FGDC) continues to implement the 

Geospatial Data Act (GDA) of 2018, the DOI will continue to improve policies and internal 

controls. We are generally very pleased with this first bi-annual audit of the law’s 

implementation, and we look forward to the next bi-annual audit report in Fiscal Year 2022. 

Please find our management response below to each report recommendation that includes our 

corrective action, target completion date, and the title of the official responsible for 

implementing recommendation. 

OIG Recommendation 1. Ensure that bureau contracts with third-party providers of 

geospatial data meet FGDC-endorsed data and metadata quality standards. 

Management concurs with the recommendation and will issue policy to implement this 

requirement. Specifically, the DOI will issue guidance to bureaus and offices requiring 

consideration during the acquisition planning process of whether geospatial data may be 

collected or acquired during the performance of the contract. If there will or might be 

geospatial data collected or acquired, then bureaus and offices shall include relevant 

language regarding FGDC standards in the contract. 

The DOI will remind bureaus that the existing DOI Financial Assistance Interior 

Regulation (FAIR) guidance requires assistance recipients to submit to the DOI a copy of 

any geospatial data produced or collected when requested by the DOI. 

Responsible Officials: Chief Data Officer and Deputy Assistant Secretary for Budget, Finance, 

Grants, and Acquisition 

Target Completion Date: December 31, 2020 

OIG Recommendation 2. Ensure that all bureaus and offices search the GeoPlatform to 

determine if existing Federal, State, local, or private data meets the DOI’s needs before 

expending funds for data collection. 

Management concurs with the recommendation and plans to issue policy to implement this 

requirement. 

Responsible Officials: Chief Data Officer and Deputy Assistant Secretary for Budget, Finance, 

Grants and Acquisition 

Target Completion Date: November 1, 2020 

24
 

 

 

 

 

 

 

 

1 

2 

Appendix 5: Status of Recommendations 

Recommendation Status Action Required 

We will refer this 

recommendation to the 

Resolved but not implemented Assistant Secretary for Policy, 

Management and Budget to 

track implementation. 

We will refer this 

recommendation to the 

Resolved but not implemented Assistant Secretary for Policy, 

Management and Budget to 

track implementation. 

25 
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