OIL AND GAS

Interior Has Begun to 

Address Hiring and 

Retention Challenges 

but Needs to Do More

Report to Congressional Requesters

January 2014

GAO-14-205

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-205, a report to 

congressional requesters

January 2014

OIL AND GAS

Interior Has Begun to Address Hiring and Retention 

Challenges but Needs to Do More 

Why GAO Did This Study

Interior employs a wide range of 

highly-trained specialists and scientists 

with key skills to oversee oil and gas 

operations on leased federal lands and 

waters. GAO and others have reported 

that Interior has faced challenges 

hiring and retaining sufficient staff to 

carry out these responsibilities. In 

February 2011, GAO added Interior’s 

management of federal oil and gas 

resources to its list of programs at high 

risk of fraud, waste, abuse, and 

mismanagement in part because of 

Interior’s long-standing and continued 

human capital challenges. 

GAO was asked to update the status of 

Interior’s human capital challenges. 

This report examines: (1) the extent to 

which Interior continues to face 

challenges hiring and retaining key oil 

and gas staff and the causes of these 

challenges; (2) Interior’s efforts to 

address its hiring and retention 

challenges; and (3) the effects of hiring 

and retention challenges on Interior’s 

oversight of oil and gas activities. GAO 

surveyed 44 Interior offices that 

oversee oil and gas operations of 

which 40 responded; analyzed offshore 

inspection records and other 

documents; and interviewed agency 

officials.

What GAO Recommends

GAO recommends that the Department 

of the Interior explore the bureaus’ 

expanded use of recruitment, 

relocation, retention, and other 

incentives and systematically collect 

and analyze hiring data. In 

commenting on a draft of this report, 

Interior generally agreed with GAO’s 

recommendations.

What GAO Found

The Department of the Interior (Interior) continues to face challenges hiring and 

retaining staff with key skills needed to manage and oversee oil and gas 

operations on federal leases. Interior officials noted two major factors that 

contribute to challenges in hiring and retaining staff: lower salaries and a slow 

hiring process compared with similar positions in industry. In response to GAO’s 

survey, officials from a majority of the offices in the three Interior bureaus that 

manage oil and gas activities—the Bureau of Land Management (BLM), the 

Bureau of Ocean Energy Management (BOEM), and the Bureau of Safety and 

Environmental Enforcement (BSEE)—reported ongoing difficulties filling 

vacancies, particularly for petroleum engineers and geologists. Many of these 

officials also reported that retention is an ongoing concern as staff leave for 

positions in industry. Bureau of Labor Statistics data confirm a wide gap between 

industry and federal salaries for petroleum engineers and geologists. According 

to Office of Personnel Management (OPM) data, the fiscal year 2012 attrition rate 

for petroleum engineers at BLM was over 20 percent, or more than double the 

average federal attrition rate of 9.1 percent. However, the attrition rate for other 

key oil and gas staff during fiscal year 2012 was lower than the federal average. 

Nonetheless, field office officials stated that attrition is of concern because some 

field offices have only a few employees in any given position, and a single 

separation can significantly affect operations. Additionally, Interior records show 

that the average time required to hire petroleum engineers and inspectors in 

recent months generally exceeded 120 calendar days—much longer than OPM’s 

target of 80 calendar days.

Interior and the three bureaus—BLM, BOEM, and BSEE—have taken some 

actions to address their hiring and retention challenges but have not fully used 

their existing authorities to supplement salaries or collect and analyze hiring data 

to identify the causes of delays in the hiring process. For instance, BLM, BOEM, 

and BSEE officials said that recruitment, relocation, and retention incentives are 

key options to help hire and retain staff, but use of these incentives to attract and 

retain petroleum engineers and inspectors has been limited. Moreover, the 

department and bureaus have taken some steps to reduce hiring times, but they 

do not have complete and accurate data on hiring times. For instance, while 

BSEE and BOEM collect hiring data on a biweekly basis, the data are used 

primarily to track the progress of individual applicants as they move through the 

hiring process. Likewise, a BLM official stated that the bureau does not 

systematically analyze data on hiring times. Without reliable data on hiring times, 

Interior’s bureaus cannot identify how long it takes to complete individual stages 

in the hiring process or effectively implement changes to expedite the hiring 

process.

According to BLM, BOEM, and BSEE officials, hiring and retention challenges 

have made it more difficult to carry out oversight activities in some field offices. 

For example, many BLM and BSEE officials GAO surveyed reported that 

vacancies have resulted in a reduction in the number of inspections conducted. 

As a result of these challenges, bureau officials cited steps they have taken to 

address vacancies in key positions, such as borrowing staff from other offices or 

using overtime, but these solutions are not sustainable.

View GAO-14-205. For more information, 

contact Frank Rusco at (202) 512-3841 or 

ruscof@gao.gov. 
Page i GAO-14-205 Interior Human Capital

Letter 1

Background 5

Interior Continues to Face Challenges Hiring and Retaining Key 

Oil and Gas Staff Primarily Because of Higher Industry Salaries 

and the Lengthy Federal Hiring Process 14

Interior Has Taken Some Actions to Address Hiring and Retention 

Challenges 22

Hiring and Retention Challenges Have Made It More Difficult to 

Carry Out Some Oversight Activities 31

Conclusions 34

Recommendations for Executive Action 35

Agency Comments and Our Evaluation 35

Appendix I Objectives, Scope, and Methodology 37

Appendix II Survey of Interior’s Field Offices on the Challenges to Hire and 

Retain Staff to Oversee Oil and Gas Activities 40

Appendix III Analysis of Effects of Inspector Vacancies in the Gulf of Mexico 68

Appendix IV Comments from the Department of the Interior 77

Appendix V GAO Contact and Staff Acknowledgments 79

Tables

Table 1: Hiring Times for Petroleum Engineers and Inspectors at 

BOEM and BSEE Offices for Employees Reporting for 

Duty from October 1, 2012 to March 31, 2013 20

Table 2: Hiring Times for Petroleum Engineers and Inspectors at 

BLM Field Offices for Employees Reporting for Duty from 

October 1, 2011 to September 30, 2012 21

Contents
Page ii GAO-14-205 Interior Human Capital

Table 3: Interior’s Use of Recruitment, Relocation, and Retention 

Awards to Hire and Retain Petroleum Engineers, Fiscal 

Years 2010 through 2012 25

Table 4: Interior’s Use of Recruitment, Relocation, and Retention 

Awards to Hire and Retain Inspectors, Fiscal Years 2010 

through 2012 25

Table 5: Authorized Positions and Vacancies 44

Table 6: Ease or Difficulty in Hiring and Retaining Staff for Those 

Offices with Vacancies 44

Table 7: Extent to Which Factors Help or Hinder Ability to Hire Oil 

and Gas Oversight Staff for Those Offices with Vacancies 45

Table 8: Extent to Which Factors Help or Hinder Ability to Retain 

Oil and Gas Oversight Staff 47

Table 9: Average Reported Length of Vacancies, Calendar Year 

2012 48

Table 10: Effects of Vacancies on Oil and Gas Oversight 48

Table 11: Estimated Number of Production Facility Inspections 

Conducted under Three Staffing Scenarios 71

Table 12: Multiple Regression Model Estimating the Time 

Required to Inspect Production Facilities, Fiscal Year 

2012 74

Figures

Figure 1: Location of BLM Oil and Gas Field Offices 7

Figure 2: Location of BOEM and BSEE Regional and District 

Offices 9

Figure 3: Attrition Rates for Key Interior Oil and Gas Oversight 

Positions, Fiscal Year 2012 16

Figure 4: Retirement Eligibility by 2017 for Selected Key Interior 

Oil and Gas Positions 17

Figure 5: Mean Industry and Federal Government Salaries for 

Petroleum Engineers, Geologists, and Natural Resource 

Specialists from 2002 through 2012 (2012 Dollars) 19

Figure 6: Cause and Effect Diagram 43

Figure 7: Estimated Number of Production Facility Inspections 

Conducted under Three Staffing Scenarios 72
Page iii GAO-14-205 Interior Human Capital

Abbreviations

APD application for permit to drill

BOEM Bureau of Ocean Energy Management

BOEMRE Bureau of Ocean Energy Management, Regulation, and

Enforcement

BLM Bureau of Land Management

BSEE Bureau of Safety and Environmental Enforcement

EHRI Enterprise Human Resources Integration

FTE full-time equivalent

Interior Department of the Interior

MMS Minerals Management Service

OCSLA Outer Continental Shelf Lands Act

OIG Office of Inspector General

OMB Office of Management and Budget

OPM Office of Personnel Management

TIMS Technical Information Management System

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Page 1 GAO-14-205 Interior Human Capital

441 G St. N.W.

Washington, DC 20548

January 31, 2014

The Honorable Doc Hastings

Chairman

The Honorable Peter A. DeFazio

Ranking Member

Committee on Natural Resources

House of Representatives

The Honorable Doug Lamborn

Chairman

Subcommittee on Energy and Mineral Resources

Committee on Natural Resources

House of Representatives

Production of oil and natural gas on federal lands and waters is an 

important part of the nation’s energy portfolio and one of the largest 

sources of nontax revenue for the federal government. The Department of 

the Interior (Interior), which oversees the development of federal oil and 

gas resources, collecting nearly $10 billion in fiscal year 2012 in royalties 

and other payments from oil and gas companies. Onshore, Interior 

oversees about 700 million subsurface acres, including minerals beneath 

more than 245 million federally managed surface acres. Offshore, Interior 

oversees more than 1.7 billion acres in the waters of the Outer 

Continental Shelf, which includes submerged lands in federal waters off 

the coast of Alaska, the Gulf of Mexico, and the Atlantic and Pacific 

coasts.1 Interior’s responsibilities include administering leases; reviewing 

and approving oil and gas companies’ (operators) plans, and applications 

for permit to drill (APD); inspecting oil and gas operations, such as drilling 

rigs and production platforms, to ensure compliance with safety and 

environmental regulations; and determining how much oil and gas is 

produced from federal lands and waters to calculate royalties and other 

revenues due to the federal government.

 1

The Outer Continental Shelf refers to the submerged lands outside the territorial 

jurisdiction of all 50 states but within U.S. jurisdiction and control, and consists of 

submerged federal lands, generally extending seaward from 3 geographical miles to 200 

nautical miles off the coastline.
Page 2 GAO-14-205 Interior Human Capital

Three bureaus within Interior provide oversight of oil and gas activities on 

federal lands and waters: (1) the Bureau of Land Management (BLM), 

which oversees onshore federal oil and gas activities; (2) the Bureau of 

Ocean Energy Management (BOEM), which oversees offshore oil and 

gas leasing; and (3) the Bureau of Safety and Environmental 

Enforcement (BSEE), which reviews applications from operators and 

conducts inspections of offshore oil and gas activities. In addition, a fourth 

office, the Office of Natural Resources Revenue, is responsible for 

collecting revenues owed to the federal government by operators 

producing oil and gas on federal leases, both onshore and offshore. To 

do this work, Interior employs highly trained specialists and scientists 

such as archeologists, geologists, biologists, environmental protection 

specialists, inspectors, and petroleum engineers. In March 2010, we 

reported that Interior faced various human capital challenges, including 

hiring and retaining staff and, as a result, had difficulty meeting its 

responsibilities to oversee oil and gas activities on offshore federal 

leases.2

The April 2010 explosion and fire onboard the Deepwater Horizon drilling 

rig––which resulted in 11 deaths, serious injuries, and the largest marine 

oil spill in the history of the United States––highlighted the importance of 

effective oversight of oil and gas activities on federal lands and waters. 

Since that event, Interior’s management of federal oil and gas resources 

has faced additional scrutiny by us and others. In light of the problems 

that we and others have identified—including Interior’s ongoing human 

capital challenges—in February 2011, we added Interior’s management 

of federal oil and gas resources to our list of U.S. government programs 

at high risk of waste, fraud, abuse, and mismanagement or in need of 

broad reform.3 In July 2012, we reported, among other things, that BOEM 

and BSEE continued to face challenges hiring and retaining staff for 

oversight of oil and gas activities in the Gulf of Mexico and did not have a 

 2

GAO, Oil and Gas Management: Interior’s Oil and Gas Production Verification Efforts Do 

Not Provide Reasonable Assurance of Accurate Measurement of Production Volumes, 

GAO-10-313 (Washington, D.C.: Mar. 15, 2010). 

3

GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2011). 
Page 3 GAO-14-205 Interior Human Capital

strategic workforce plan in place to outline strategies to address its 

human capital challenges.4

Furthermore, increasing oil prices, along with advances in technologies, 

such as hydraulic fracturing and horizontal drilling in shale formations 

onshore and deepwater drilling offshore, have made it possible to develop 

substantially more oil and gas resources than ever before. These 

technological advances make it imperative that Interior be able to hire and 

retain sufficient staff with the skills and experience needed to oversee the 

changing oil and gas industry in an efficient and effective way. This report 

responds to your request that we review the current status of Interior’s 

human capital challenges. Accordingly, this report examines: (1) the 

extent to which Interior continues to face challenges hiring and retaining 

key oil and gas staff and the causes of these challenges; (2) Interior’s 

efforts to address its hiring and retention challenges; and (3) the effects, if 

any, of hiring and retention challenges on Interior’s oversight of oil and 

gas activities.

To conduct this work, we reviewed relevant laws and Interior’s guidance, 

as well as independent studies by Interior’s Office of Inspector General 

and others. We also interviewed officials from BLM, BOEM, and BSEE. 

Specifically, we interviewed BLM field office officials in Bakersfield, 

California, which oversees some of the highest producing federal onshore 

leases in the country, and Dickinson, North Dakota, which has 

experienced a rapid increase in industry activity in recent years. We 

interviewed BOEM and BSEE officials in the Gulf of Mexico, Alaska, and 

Pacific regional offices; and BSEE officials in all five Gulf of Mexico 

district offices. In addition, to determine the extent to which Interior 

continues to face hiring and retention challenges across the department 

and the possible effects of these challenges, we surveyed management 

officials representing all of Interior’s offices responsible for oil and gas 

oversight—3 BOEM regional offices, 5 BSEE district offices and 3 BSEE 

regional offices, and 33 BLM field offices and one BLM state office. We 

received responses from 40 of the 44 field offices (i.e., 30 of the 34 BLM 

offices, 7 of the 7 BSEE offices, and 3 of the 3 BOEM offices) for an 

overall response rate of 91 percent.

 4

GAO, Oil and Gas Management: Interior’s Reorganization Complete, but Challenges 

Remain in Implementing New Requirements, GAO-12-423 (Washington, D.C.: July 30, 

2012).
Page 4 GAO-14-205 Interior Human Capital

To examine the extent to which Interior continues to face challenges 

hiring and retaining key oil and gas personnel and the causes of these 

challenges, we analyzed statistical data on attrition and retirement 

eligibility from the Office of Personnel Management’s (OPM) Enterprise 

Human Resources Integration (EHRI) database of federal civilian 

employees and reviewed and analyzed Interior data on vacancies and 

hiring times.5 We also analyzed Bureau of Labor Statistics data to 

compare industry and federal government salaries for oil and gas 

positions. To identify key Interior oil and gas oversight positions, we 

interviewed Interior officials and reviewed Interior staffing data. We 

determined the following are the key BLM oil and gas oversight positions: 

petroleum engineers, petroleum engineering technicians (inspectors),6

natural resource specialists, environmental protection specialists, and 

geologists. Similarly, we determined that the key BOEM and BSEE oil 

and gas oversight positions are petroleum engineers, inspectors, 

biologists (natural resource specialists),

7 geophysicists, and geologists. 

To examine Interior’s efforts to address its hiring and retention 

challenges, we reviewed documents such as strategic workforce plans 

and other documents outlining steps Interior has taken with regard to 

hiring and retention and spoke with officials responsible for their 

implementation. We also discussed special salary rates for specific 

positions with officials from OPM, as well as BOEM, BSEE, and BLM. To 

examine the effects, if any, of hiring and retention challenges on Interior’s 

oversight of federal oil and gas activities, we surveyed BLM, BOEM, and 

BSEE field offices about the factors affecting their ability to hire and retain 

key oil and gas oversight staff and how vacancies of key positions have 

affected day-to-day operations. We also analyzed BSEE inspection data 

from the Gulf of Mexico and Pacific Regions—where nearly all federal 

offshore drilling has occurred—for fiscal years 2010 through 2012. 

Appendix I presents a more detailed description of our objectives, scope,

and methodology, appendix II presents more information about our 

survey, and appendix III presents more information about our analysis of 

BSEE inspection data.

 5

The EHRI database was formerly known as the Central Personnel Data File. 

6

For the purposes of this report, we refer to petroleum engineering technicians as 

“inspectors” because one of their primary duties is to conduct inspections for BLM.

7

For the purposes of this report, we refer to BOEM and BSEE biologists as “natural 

resource specialists” because BLM, BOEM, and BSEE use the same OPM occupational 

series designation for these positions. 
Page 5 GAO-14-205 Interior Human Capital

We conducted this performance audit from May 2012 to January 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Three Interior bureaus—BLM, BOEM, and BSEE—are responsible for 

regulating the processes that operators must follow when leasing, drilling, 

and producing oil and gas from federal lands and waters. BLM manages 

onshore oil and gas activities, and BOEM and BSEE manage offshore oil 

and gas activities.8

Onshore. BLM manages more than 245 million surface acres of federal 

land for multiple uses, including recreation; range; timber; minerals; 

watershed; wildlife and fish; natural scenic, scientific, and historical 

values; and for the sustained yield of renewable resources. BLM 

oversees onshore oil and gas development on and under BLM-managed 

federal lands, under other federal agencies’ lands, and under private 

lands for which the federal government has retained mineral rights—

totaling about 700 million subsurface acres.9 BLM manages these 

responsibilities through its headquarters office in Washington, D.C.; 12 

state offices; 38 district offices; and 127 field offices. BLM’s headquarters 

office develops guidance and regulations for the bureau, and the state, 

district, and field offices manage and implement the bureau’s programs. 

BLM’s oil and gas development oversight efforts are led by 33 field offices 

located primarily in the Mountain West—the center of much of Interior’s 

onshore oil and gas development and production—although some BLM 

 8

In May 2010, shortly after the Deepwater Horizon incident, in an effort to separate major 

functions of offshore oil and gas management, Interior announced the reorganization of 

the Minerals Management Service (MMS) into the Bureau of Ocean Energy Management, 

Regulation, and Enforcement (BOEMRE), responsible for offshore oil and gas 

management, and the Office of Natural Resources Revenue, responsible for revenue 

collections. Subsequently, on October 1, 2011, BOEMRE was separated into two 

bureaus—BOEM, which is responsible for leasing and resource management, and BSEE, 

which is responsible for permitting and inspections. For more information on Interior’s 

reorganization see GAO-12-423. 

9

Leasing of oil, gas, and other applicable minerals is generally governed by the Mineral 

Leasing Act of 1920 as amended. Pub. L. No. 66-146, 41 Stat. 437 (1920).

Background
Page 6 GAO-14-205 Interior Human Capital

offices in other locations have small oil and gas programs that are 

administered with the assistance of these 33 offices (see fig. 1). Across 

these offices, BLM employs petroleum engineers, natural resource 

specialists, geologists, and other scientists to carry out land-use planning 

efforts and review and approve APDs before operators can begin to drill 

any new oil or gas wells. Operators that obtain leases for oil and gas 

development are required to submit to BLM (onshore) or BSEE (offshore) 

an APD for approval before beginning to drill any new oil or gas wells. 

The APD contains a detailed set of forms and documents that specify 

requirements that the operator must follow when drilling. In addition, other 

specialists, including petroleum engineering technicians, carry out a 

variety of oil and gas inspections, including drilling inspections, production 

inspections, and environmental compliance inspections.
Page 7 GAO-14-205 Interior Human Capital

Figure 1: Location of BLM Oil and Gas Field Offices
Page 8 GAO-14-205 Interior Human Capital

Offshore. BOEM and BSEE oversee all offshore oil and gas activities on 

federal leases in the United States.10 Through its three regional offices—

in Alaska, the Gulf of Mexico, and the Pacific––Interior manages more 

than 1.7 billion offshore acres. The vast majority of Interior’s offshore oil 

and gas development and production occurs in the Gulf of Mexico; 

accordingly, the majority of BOEM’s and BSEE’s workforces are located 

in the Gulf of Mexico Outer Continental Shelf Region.11 BOEM and BSEE 

also have offices in the Pacific and Alaska Outer Continental Shelf 

Regions (see fig. 2). BOEM employs petroleum engineers, geoscientists, 

and other specialists who are responsible for leasing and resource 

management, and BSEE employs petroleum and other engineers, 

inspectors, and other specialists who are responsible for reviewing and 

approving APDs and conducting drilling and production inspections to 

ensure that operators comply with all regulatory requirements.

 10Under the Outer Continental Shelf Lands Act (OCSLA) of 1953, as amended, Interior is 

responsible for management and oversight of oil and gas development in federal waters 

on the outer continental shelf. Pub. L. No. 83-212, 67 Stat. 462 (May 22, 1953), (codified 

as amended at 43 U.S.C. §§1301-1356a).

11BOEM and BSEE manage the Atlantic Outer Continental Shelf Region through their 

respective Gulf of Mexico Regional Offices. There is currently no oil and gas development 

in the Atlantic Outer Continental Shelf Region. 
Page 9 GAO-14-205 Interior Human Capital

Figure 2: Location of BOEM and BSEE Regional and District Offices
Page 10 GAO-14-205 Interior Human Capital

Over the last decade, we have reported on Interior’s persistent challenges 

hiring and retaining sufficient staff to provide efficient and effective 

oversight of oil and gas activities on federal lands and waters, and we 

have made a number of recommendations to Interior to address these 

challenges.

• In June 2005, we reported that BLM did not have sufficient staff to 

manage the increasing demand for onshore oil and gas drilling 

permits while fulfilling its environmental protection responsibilities.12

We recommended that BLM ensure that its staffing needs are 

accurately reflected in its workforce plans. In response to this 

recommendation, BLM analyzed the staffing levels needed to process 

drilling permits and used this analysis to fill additional inspection and 

environmental monitoring positions.

• In March 2010, among other things, we reported that BLM field offices 

were unable to hire and retain sufficient numbers of staff to complete 

all required inspections.13 We reported that, according to BLM 

officials, low pay when compared with industry salaries and the high 

housing costs in energy boom towns were major factors affecting their 

ability to hire sufficient numbers of staff. We recommended that 

Interior determine what additional policies or incentives were 

necessary, if any, to attract and retain staff. Interior agreed with our 

recommendation, and we are evaluating the actions they have taken, 

including developing a workforce strategy and issuing guidance for 

the use of recruitment and retention incentives.

• In June 2012, we reported that salaries for some key oil and gas 

oversight positions—which are generally set by the federal salary 

schedule14—were significantly lower than salaries offered by industry 

for candidates with similar skills, and that top applicants are typically 

 12GAO, Oil and Gas Development: Increased Permitting Activity Has Lessened BLM’s 

Ability to Meet Its Environmental Protection Responsibilities, GAO-05-418 (Washington, 

D.C.: June 17, 2005).

13GAO-10-313.

14OPM administers the federal salary schedule for the majority of the approximately 1.5 

million federal employees in professional, technical, and administrative positions. 

Agencies establish a grade level for each job based on the level of difficulty, responsibility, 

and qualifications required, and each grade corresponds to a specific pay level. Unless 

otherwise authorized by law, agencies do not have the authority to set standard pay levels 

above that established by the federal salary schedule except, in rare cases, as approved 

by OPM. 

Hiring
Page 11 GAO-14-205 Interior Human Capital

hired by the petroleum industry, leaving Interior with less-skilled 

applicants.

15 To improve Interior’s oversight of oil and gas activities in 

the Gulf of Mexico, we recommended that Interior assess how the 

number of inspectors affects the agency’s ability to conduct monthly 

inspections and whether the monthly inspection goals were 

appropriate. Interior agreed with our recommendation but has not fully 

taken action to address it.

• In August 2013, we reported that BLM also faces challenges in 

retaining its oil and gas staff and in hiring new employees, including 

staff responsible for environmental inspections and enforcement. BLM 

officials told us that some environmental protection positions were 

unfilled for long periods, and new hires were often inexperienced and 

required greater supervision, limiting their effectiveness.16 We did not 

make any recommendations that directly addressed this concern.

• In March 2010,17 we reported that BLM had experienced high turnover 

rates in key oil and gas inspection and engineering positions from 

2004 through 2008, and that this high turnover resulted in a greater 

reliance on less-trained and less-experienced staff.

• In July 2012, we reported that Interior continued to face workforce 

planning challenges following a reorganization effort to improve its 

oversight of oil and gas activities in the wake of the April 2010 oil spill 

in the Gulf of Mexico.18 In particular, we found that Interior had not 

developed a strategic workforce plan that outlined specific strategies 

to help address recruitment and retention challenges. We 

recommended that BOEM and BSEE develop a strategic workforce 

plan that would determine the critical skills and competencies needed 

to achieve current and future programmatic results and develop 

strategies to address critical skills gaps. In response to this 

recommendation, BSEE completed its workforce plan in September 

2013, and BOEM officials told us that they will complete their plan in 

fiscal year 2014.

 15GAO-12-423. 

16GAO, Oil and Gas Development: BLM Needs Better Data to Track Permit Processing 

Times and Prioritize Inspections, GAO-13-572 (Washington, D.C.: Aug. 23, 2013).

17GAO-10-313.

18GAO-12-423.

Retention
Page 12 GAO-14-205 Interior Human Capital

In addition to our work, Interior’s Office of Inspector General (OIG) and 

others have reported on Interior’s challenges related to hiring and 

retention of key oil and gas oversight staff. With respect to hiring, in 

September 2010, Interior’s Outer Continental Shelf Safety Oversight 

Board reported that Interior did not have a formal program for recruiting 

the best candidates or well-defined career advancement and promotion 

opportunities for inspectors.19 A December 2010 report from Interior’s 

Inspector General echoed that finding and concluded that the Pacific 

Region faced considerable hiring challenges because of increased hiring 

by the oil and gas industry, citing the industry’s significant salary 

advantage over federal service.20 With respect to retention, the Outer 

Continental Shelf Safety Board also reported that Interior lacked a formal 

program for retaining the most-qualified inspectors. Moreover, the report 

found that in the Pacific Region, 8 out of 10 staff responsible for 

permitting were eligible for retirement within the next 3 years. In 

December 2010, Interior’s Inspector General reported that, in spite of the 

considerable investment in both time and money for inspector training, 

BLM’s inspection and enforcement program risked losing its inspectors 

once they were trained because trained inspectors were highly sought by 

industry.21 Interior’s Inspector General reported that oil and gas operators 

commonly recruit petroleum engineering technicians by offering high 

salaries during successful business periods, and recommended, among 

other things, that BLM consider developing and implementing a continued 

service agreement requiring newly certified inspectors to stay with the 

bureau for a specified period of time following certification. In February 

2013, BLM issued guidance that requires the use of a mandatory service 

agreement for inspectors as a condition of employment. According to the 

guidance, if an inspector voluntarily separates from BLM within 2 years of 

certification, the inspector will have to reimburse BLM the full cost of the 

training, which is estimated at $48,000 per certification.

 19Interior, Outer Continental Shelf Safety Oversight Board Report to Secretary of the 

Interior Ken Salazar (Sept. 1, 2010).

20U.S. Department of the Interior Office of Inspector General, A New Horizon: Looking to 

the Future of the Bureau of Ocean Energy Management, Regulation, and Enforcement, 

CR-EV-MMS-0015-2010 (Dec. 7, 2010). 

21U.S. Department of the Interior Office of Inspector General, Bureau of Land 

Management’s Oil and Gas inspection and Enforcement Program, CR-EV-BLM-0001-

2009 (Washington, D.C.: Dec. 2, 2010). 
Page 13 GAO-14-205 Interior Human Capital

In 2011, we added Interior’s management of federal oil and gas resources 

to our list of programs at high risk for waste, fraud, abuse, and 

mismanagement in part because Interior continued to experience 

problems hiring and retaining sufficient staff to provide oversight and 

management of oil gas operations on federal lands and waters.22 More 

broadly, in 2001 we added strategic human capital management across 

the federal government to our high-risk list. At that time, we highlighted 

various challenges the federal government faces, including strategic 

human capital planning, succession planning, and acquiring and 

developing staff sufficient to meet agencies’ needs. We concluded that 

these challenges may leave agencies unable to effectively, efficiently, and 

economically perform their missions.23 In addition, we have issued a 

series of reports highlighting human capital challenges at individual 

federal agencies—including the Department of Housing and Urban 

Development,24 the U.S. Patent and Trademark Office,25 the Food and 

Drug Administration,26 and the Department of State27—and these reports 

highlight problems similar to the problems at Interior.

The federal government has made substantial progress addressing its 

human capital challenges over the past 12 years. As we noted in 

September 2012, both Congress and OPM have taken several actions in 

this regard.28 For example, in 2002, Congress created a chief human 

capital officer position in 24 agencies to advise and assist the head of 

these agencies and other agency officials in their strategic human capital 

 22GAO-11-278. 

23GAO, High-Risk Series: An Update, GAO-01-263 (Washington, D.C.: January 2001).

24GAO, Housing and Urban Development: Strategic Human Capital and Workforce 

Planning Should be an Ongoing Priority, GAO-13-282 (Washington, D.C.: Mar. 15, 2013). 

25GAO, U.S. Patent and Trademark Office: Hiring Efforts Are Not Sufficient to Reduce the 

Patent Application Backlog, GAO-07-1102 (Washington, D.C.: Sept. 4, 2007). 

26GAO, Human Capital: Continued Opportunities Exist for FDA and OPM to Improve 

Oversight of Recruitment, Relocation, and Retention Incentives, GAO-10-226 

(Washington, D.C.: Jan. 22, 2010). 

27GAO, Department of State: Foreign Service Midlevel Staffing Gaps Persist Despite 

Significant Increases in Hiring, GAO-12-721 (Washington, D.C.: June 14, 2012). 

28GAO, Human Capital Management: Effectively Implementing Reforms and Closing 

Critical Skills Gaps Are Key to Addressing Federal Workforce Challenges, GAO-12-1023T 

(Washington, D.C.: Sept. 19, 2012).
Page 14 GAO-14-205 Interior Human Capital

efforts.29 In addition, in 2002 and 2004, Congress provided agencies with 

additional authorities and flexibilities to manage the federal workforce,

such as the authority to offer recruitment bonuses. In 2005, and again in 

2008, OPM issued guidance on the use of hiring authorities and 

flexibilities. In 2008, OPM launched an 80-day hiring model to help speed 

the hiring process. In 2012, OPM launched the Pathways Programs to 

recruit and hire students and recent graduates.30

Interior continues to face challenges hiring and retaining key oil and gas 

staff—particularly petroleum engineers, inspectors, and geologists. 

Interior officials told us that a number of factors affected their ability to 

hire and retain staff but cited two key factors—higher salaries in industry 

and the lengthy federal hiring process—and said that difficulties were 

especially prevalent at offices with an active industry presence that 

competes with Interior for employees.

BLM, BOEM, and BSEE offices continue to find it difficult to fill vacancies 

for key oil and gas oversight positions, including petroleum engineers, 

inspectors, geologists, natural resource specialists, and geophysicists. In 

responding to our survey, officials from a majority of BLM, BOEM, and 

BSEE offices that had vacancies in these key oversight positions reported 

that filling these vacancies was either somewhat or very difficult, with 

petroleum engineers and geologists identified as the most difficult to 

 29Chief Human Capital Officers Act of 2002, Title XIII of the Homeland Security Act of 

2002. Pub. L. No. 107-296 (Nov. 25, 2002).

3077 Fed. Reg. 28194 (May 11, 2012). The Pathways Programs were established by the 

President under Exec. Order No. 13562, Recruiting and Hiring Students and Recent 

Graduates, 75 Fed. Reg. 82585 (Dec. 27, 2010). Under the executive order, OPM was 

tasked with issuing implementing regulations. 

Interior Continues to 

Face Challenges

Hiring and Retaining 

Key Oil and Gas Staff 

Primarily Because of 

Higher Industry 

Salaries and the 

Lengthy Federal 

Hiring Process

Interior Continues to Face 

Challenges Hiring and 

Retaining Key Oil and Gas 

Staff
Page 15 GAO-14-205 Interior Human Capital

hire.31 In addition, many field offices reported difficulties retaining key oil 

and gas staff, and officials told us that they are concerned that key staff 

will leave for industry.32 (See app. II for information regarding survey 

responses.) With the exception of BLM’s petroleum engineers (21.7 

percent attrition) and BSEE inspectors (10.1 percent attrition), however, 

the attrition rate for other key oil and gas staff for fiscal year 2012 was 

less than the rest of the federal government, which had an average 9.1 

percent attrition rate for all federal positions.33 Nonetheless, field office 

officials told us that attrition raises concerns because it is not unusual for 

some field offices to have only one or two employees in any given 

position, meaning that a single retirement or resignation can significantly 

affect office operations. At BLM, the fiscal year 2012 attrition rate for 

petroleum engineers was over 20 percent, or more than double the 

average federal attrition (see fig. 3). Significantly, resignations rather than 

retirements, accounted for nearly half of BLM’s petroleum engineer 

attrition rate, suggesting that petroleum engineers sought employment 

opportunities outside the bureau.

 31Specifically, 11 of the 14 BLM offices, 2 of the 3 BOEM offices, and 6 of the 7 BSEE 

offices reporting petroleum engineer vacancies said that filling those vacancies were 

either somewhat or very difficult.

32For instance, 11 of 30 BLM offices, 3 of 3 BOEM offices, and 3 of 7 BSEE offices 

reported finding it somewhat or very difficult to retain petroleum engineers. 

33We calculated the attrition rates used in this report by dividing the number of separations 

during a particular fiscal year (which includes retirement, voluntary separations, transfers 

out of the agency or reassignments, involuntary separations, and deaths) by the average 

number of staff onboard at the beginning and end of the fiscal year. 
Page 16 GAO-14-205 Interior Human Capital

Figure 3: Attrition Rates for Key Interior Oil and Gas Oversight Positions, Fiscal 

Year 2012

Hiring and retention problems appear to be more acute at offices where 

industry activity is greatest. For example, attrition rates for BLM oil and 

gas oversight positions—especially petroleum engineers—appeared to be 

higher at field offices where industry submitted the highest number of 

APDs in recent years. From 2010 to 2012, at the five BLM field offices 

that received the highest number of APDs, the average attrition rate for 

petroleum engineers was 21.2 percent annually, while the average 

attrition rate for petroleum engineers at all other BLM field offices was

11.4 percent. At a BLM field office in North Dakota, which has 

experienced significant new industry activity in recent years, APDs have 

increased from 84 in fiscal year 2007 to 287 in fiscal year 2012. Office 

managers from this field office told us that they have been understaffed 
Page 17 GAO-14-205 Interior Human Capital

for the past few years and struggled to hire sufficient numbers of staff to 

meet the increased APD and inspection workload. Officials at BOEM’s 

Alaska Regional Office, where both BOEM and industry are preparing for 

potential development of offshore oil and gas, stated that they face 

challenges hiring and retaining staff because they are competing with 

industry for the same small group of geologists, geophysicists, and 

petroleum engineers.

Adding to Interior’s retention difficulties is the high proportion of staff in 

key oil and gas positions that will be eligible to retire within a few years 

(see fig. 4). For example, according to our analysis of OPM data on 

federal civilian personnel, more than half of BLM petroleum engineers 

and BOEM geologists will be eligible to retire by 2017 compared with a 

government-wide average of about 27.5 percent for all federal employees 

during the same period.

Figure 4: Retirement Eligibility by 2017 for Selected Key Interior Oil and Gas 

Positions
Page 18 GAO-14-205 Interior Human Capital

Interior officials widely agreed that two major factors contribute to 

difficulties in hiring and retention of oil and gas oversight staff—higher 

salaries in industry and the lengthy federal hiring process—but cited other 

factors as well, including not having qualified applicants in some areas 

and limited opportunities for career advancement and promotion.

BLM, BOEM, and BSEE officials overwhelmingly cited the difference 

between federal and industry salaries as a major factor contributing to 

difficulties in hiring and retaining staff. In response to our survey and in 

interviews with field offices, officials from all three bureaus reported that 

they have lost potential applicants and staff to industry because industry 

can pay higher salaries than Interior is able to pay under the federal 

salary schedule. In responding to our survey, a majority of the BLM, 

BOEM, and BSEE offices that reported vacant positions for petroleum 

engineers, inspectors, or geologists indicated that the difference in 

salaries between Interior and industry somewhat or greatly hindered their 

ability to hire qualified applicants in one or more of these positions.34

Bureau of Labor Statistics data on industry salaries confirm that there is a 

wide and growing gap between industry and federal government salaries 

for petroleum engineers and geologists (see fig. 5).35 Salaries for natural 

resource specialists were an exception. Bureau of Labor Statistics salary 

data for natural resource specialists do not show a significant difference 

between industry and federal government salaries. According to BLM 

officials, industry does not have a position equivalent to Interior’s natural 

resource specialist and has had less demand for staff with these skills 

and background. Consistent with this exception, our survey results 

showed that most BLM, BOEM, and BSEE oil and gas offices reported 

that salary differences did not hinder their ability to hire or retain natural 

resource specialists.36

 34For instance, 25 of the 30 BLM offices, 3 of the 3 BOEM offices, and 6 of the 7 of the 

BSEE offices reported that salary differences greatly hindered their ability hire petroleum 

engineers. 

35The data do not account for differences in nonsalary compensation or other benefits. 

36Specifically, 12 of the 30 BLM offices, 0 of the 3 BOEM offices, and 0 of 7 BSEE offices 

reported that salary differences greatly hindered their ability hire natural resource 

specialists. 

Two Major Factors Affect 

Hiring and Retention of 

Key Oil and Gas Staff

Higher Industry Salaries
Page 19 GAO-14-205 Interior Human Capital

Figure 5: Mean Industry and Federal Government Salaries for Petroleum Engineers, Geologists, and Natural Resource 

Specialists from 2002 through 2012 (2012 Dollars)

The difference in salaries between Interior and industry appears to be 

greater in areas with more oil and gas development. According to field 

office officials, in regions where both Interior and industry are hiring, the 

pool of eligible applicants is smaller, industry salaries are higher, and the 

difference in salaries is wider. BSEE officials told us that recent increases 

in oil and gas exploration and development in the Gulf of Mexico have 

increased industry salaries and signing bonuses for new hires. Officials 

from a BLM field office in North Dakota, where industry is actively 

developing shale oil, told us that starting salaries for engineers in industry 

are at least twice that of BLM midlevel engineers, and that applicants for 

inspector positions at BLM can earn 60 to 70 percent more if they work 

for industry.

Interior officials frequently cited the lengthy federal hiring process as a 

key factor contributing to difficulties hiring staff. Officials we interviewed 

from all three bureaus told us that the federal hiring process hurt their 

ability to fill key oil and gas positions. Similarly, for almost 90 percent of 

the vacancies in 2012, as reported by BLM, BOEM, and BSEE officials in 

response to our survey, the federal hiring process somewhat hindered or 

greatly hindered their ability to hire qualified candidates.37 BLM, BOEM, 

 37For example, 22 of the 30 BLM offices, 2 of the 3 BOEM offices, and 7 of the 7 BSEE 

offices reported that the speed of the hiring process greatly hindered or slightly hindered 

their ability hire petroleum engineers. 

Lengthy Federal Hiring 

Process
Page 20 GAO-14-205 Interior Human Capital

and BSEE officials we interviewed told us that the federal hiring process 

is lengthy because there are a number of required steps—including the 

preparation of a job description, formally announcing the vacancy, 

creating a list of qualified candidates, conducting interviews, and 

performing background and security checks. BLM, BOEM, and BSEE 

officials told us that this process often means that contacting qualified 

applicants is delayed by weeks or months, and by the time that they 

contact the applicant, the applicant has found other work.

According to our analysis of Interior hiring data, the average hiring time 

for petroleum engineers and inspectors at BOEM and BSEE in recent 

months exceeded 180 calendar days (see table 1), and the average hiring 

times for these positions at BLM in fiscal year 2012 exceeded 120 days 

(see table 2).38 These hiring times are much longer than OPM’s target of 

80 calendar days. For other key positions, such as natural resource 

specialists and geologists, bureau officials responding to our survey 

reported fewer overall vacancies—in part because there are fewer staff in 

these positions—but still reported lengthy hiring times.

Table 1: Hiring Times for Petroleum Engineers and Inspectors at BOEM and BSEE 

Offices for Employees Reporting for Duty from October 1, 2012 to March 31, 2013

Position

Total 

hired

Number of hires 

taking more than 

6 months

Average 

hiring time 

(in days)

Petroleum engineer (BOEM/BSEE) 23 9 197

Inspector (BSEE) 35 16 182 

Sources: GAO analysis of BOEM and BSEE hiring data.

 38Interior uses OPM’s definition of hiring times, which is the elapsed calendar time from 

the date the responsible manager identifies a need to the date when the employee reports 

for duty. In our survey, we asked officials about the time elapsed from the date the 

opening was announced—defined as when the job was posted as open to applicants—

and the date the employee reported for duty.
Page 21 GAO-14-205 Interior Human Capital

Table 2: Hiring Times for Petroleum Engineers and Inspectors at BLM Field Offices 

for Employees Reporting for Duty from October 1, 2011 to September 30, 2012

Position Total hired

Number of hires 

taking more 

than 6 months

Average hiring 

time (in days)

Petroleum engineer (BLM) 11 3 126

Inspector (BLM) 17 5 149

Source: GAO analysis of BLM hiring data.

Interior officials also identified other factors that contribute to difficulties in 

hiring and retention of oil and gas oversight staff, including not having 

qualified applicants in some areas and a limited career path or 

opportunities for advancement for some positions.

Not having qualified candidates in some areas. In responding to our 

survey about the availability of qualified candidates to fill vacancies, 

almost 70 percent of those who responded indicated that a lack of 

available applicants was a factor that somewhat or greatly hindered their 

ability to fill those vacancies. In particular, field offices located in remote 

areas or extreme climates often reported that it was difficult to fill oil and 

gas oversight positions. For example, an official from a BLM field office in 

rural Colorado reported that the office was located in an area where 

winter temperatures can fall to -40 degrees Fahrenheit, making it difficult 

to attract qualified applicants and fill positions. In addition, the high cost of 

living in many areas limited the pool of qualified applicants, according to 

officials. At one BLM field office in Wyoming, for instance, an official 

reported that local housing options were limited and expensive, reducing 

the number of potential qualified applicants willing to move to the area.

Limited career path. Officials from all three bureaus told us that limited 

opportunities for advancement, promotion, or changing responsibilities 

and activities over time, caused some staff to leave and take industry 

positions or other positions within Interior. Several Interior officials cited 

limited opportunities for growth, advancement, and promotion as factors 

that affected retention. For example, we have reported that, according to 

BLM field office officials, natural resource specialists assigned to oil and 

gas tasks such as reviewing APDs have left BLM to work at other federal 

agencies where they can make greater use of their education and areas 

Other Factors
Page 22 GAO-14-205 Interior Human Capital

of specialization, such as biology.39 A 2012 BLM report on BLM’s oil and 

gas inspection and enforcement workforce strategy recognized that the 

lack of a career ladder for petroleum engineering technicians could 

contribute to these employees leaving and said that the bureau is working 

on a strategy to create a career ladder for these employees. Overall, 

almost 60 percent of survey responses to our question regarding 

opportunities for advancement and promotion indicated that the limited 

nature of such opportunities somewhat or greatly hindered retention for 

these positions.

Interior and the three bureaus—BLM, BOEM, and BSEE—have taken 

some actions to address their hiring and retention challenges, such as 

actions to increase or supplement salaries to reduce the salary gap and 

streamline the hiring process to reduce hiring times. However, they have 

made limited use of their existing authorities to supplement salaries for 

key oil and gas oversight staff. Although the department has taken some 

steps to reduce hiring times, it does not have complete and accurate data 

on hiring times to identify the causes of delays in the hiring process and 

help identify further opportunities for reducing them. Also, Interior has 

taken some actions to improve recruiting. For example, Interior and its 

bureaus are working on workforce plans to, in part, help coordinate hiring 

and retention efforts, but these efforts are ongoing, and the extent to 

which these plans will help these efforts is uncertain.

Interior and the three bureaus have taken some actions to obtain special 

salary rates for key oil and gas positions and have used their existing 

authorities to supplement salaries; however, they have not fully used 

these funding authorities.

Interior obtained special salary rates from Congress for key oil and gas 

positions at BOEM and BSEE for fiscal years 2012 and 2013. Agencies 

may receive special salary rates by request to OPM or through the 

congressional appropriations process. In February 2011, Interior 

submitted a request to OPM for special salary rates for petroleum 

 39GAO-13-572. 

Interior Has Taken 

Some Actions to 

Address Hiring and 

Retention Challenges

Interior Has Taken Some 

Actions to Increase or 

Supplement Salaries and 

Benefits but Has Not Fully 

Used Existing Authorities

Interior Obtained Special 

Salary Rates for Some 

Employees
Page 23 GAO-14-205 Interior Human Capital

engineers, geologists, and geophysicists in the Gulf of Mexico Region.40

OPM initially declined the request, citing the federal salary freeze that 

limited special salary rates only to agencies experiencing extraordinary 

circumstances.41 However, OPM noted that Interior’s need to quickly fill 

new positions created by the reorganization of MMS, which was replaced 

first by the Bureau of Ocean Energy Management, Regulation, and 

Enforcement (BOEMRE) and then by BOEM and BSEE,42 could be 

considered an extraordinary circumstance and suggested that Interior 

suspend its request until Congress provides funding for the additional 

positions. Interior did not resubmit its request, however, because in its 

fiscal year 2012 appropriation, Congress provided a special 25 percent 

base pay increase for geologists, geophysicists, and petroleum engineers 

in the Gulf of Mexico applicable to fiscal years 2012 and 2013.43 BOEM 

and BSEE officials in the Gulf of Mexico Region noted that the actual pay 

increase is lower than 25 percent because it does not include locality 

pay.44 For example, staff in BSEE’s Lake Jackson District office in Texas 

 40OPM may establish higher rates of pay for an occupation or group of occupations 

nationwide, worldwide, or in a local area when it finds the federal government’s 

recruitment or retention efforts are, or would likely become, significantly handicapped 

without those higher rates. A special rate request must be submitted to OPM by an 

agency’s headquarters and must be coordinated with other federal agencies with 

employees in the same occupational group and geographic area. (5 U.S.C. §5305; 5 CFR 

part 530, subpart C).

41Section 147 of the Continuing Appropriations Act, 2011 (Pub. L. No. 111-242, 124 Stat. 

2607 (2010)), as amended by section 1(a) of the Continuing Appropriations and Surface 

Transportation Extensions Act, 2011 (Pub. L. No. 111-322, 124 Stat. 3518 (2010))

prohibited statutory pay adjustments for most Federal civilian employees beginning on 

January 1, 2011, and ending on December 31, 2012. Section 1112 of the Consolidated 

and Further Continuing Appropriations Act, 2013 (Pub. L. No. 113-6, 127 Stat. 198, 414 

(2013)), continued the freeze on statutory pay adjustments through December 31, 2013.

42Interior renamed MMS to BOEMRE as an interim step before eventually restructuring it 

into three separate bureaus—BOEM, responsible for leasing and resource management; 

BSEE, responsible for issuing oil and natural gas drilling permits and conducting 

inspections; and the Office of Natural Resources Revenue, responsible for revenue 

collection. This report focuses on BOEM and BSEE; it does not examine the Office of 

Natural Resources Revenue.

43Pub. L. No. 112-74, div. E, title I, § 121(c), 125 Stat. 786, 1012 (2011).

44The Federal Employees Pay Comparability Act of 1990 created annual locality-based 

pay adjustments for federal workers under the General Schedule (the pay system that 

covers most federal employees) to reduce reported gaps between federal and nonfederal 

pay in metropolitan areas. Pub. L. No. 101-509, title V, § 529, 104 Stat. 1389, 1427-1469 

(Nov. 5, 1990).
Page 24 GAO-14-205 Interior Human Capital

did not receive a pay increase because their locality rate is higher than 

the 25 percent provided by Congress. Nonetheless, BOEM and BSEE 

officials in the Gulf of Mexico Region stated that this special pay authority 

appears to have helped in the near term to retain some geologists, 

geophysicists, and petroleum engineers. BOEM and BSEE have 

requested an extension of this special pay authority though fiscal year 

2014 in their fiscal year 2014 budget request. According to Interior, all 

three bureaus are actively working to develop a department-wide request 

for special salary rates. Once complete, Interior will submit the request to 

OPM.

45

BLM officials said that their bureau is considering applying for special 

salary rates for some BLM oil and gas positions. BLM officials met with 

OPM in April 2012 to discuss special salary rates for petroleum engineers 

and petroleum engineering technicians in western North Dakota and 

eastern Montana, where a BLM official said disparities between federal 

and industry salaries are most acute. A BLM official told us that OPM 

requested that BLM provide more data to support its request and that 

BLM is currently compiling and analyzing human capital data to support a 

request to OPM in the near future. At the same time, according to this 

official, BLM recently submitted draft language to Congress requesting 

special salary rates through the congressional appropriations process.

Interior has not fully used its existing authorities to offer recruitment, 

relocation, and retention incentives to supplement salaries for key oil and 

gas positions. Interior’s bureaus have discretionary authority to pay 

incentives in the form of recruitment, relocation, and retention awards of 

up to 25 percent of basic pay in most circumstances and for as long as 

the use of these incentives is justified, in accordance with OPM guidance, 

such as in the event an employee is likely to leave federal service. OPM 

officials told us that use of these incentives was a factor they consider 

when evaluating agency requests for special salary rates. Although BLM, 

BOEM, and BSEE officials told us that the use of these recruitment, 

retention, and relocation awards were key options to address salary 

differences with industry, our review of OPM and Interior data indicated 

that they were not widely used by the three bureaus. For instance, our 

assessment of Interior data indicates that Interior’s use of recruitment, 

 45This special salary increase went into effect on April 22, 2012, for BOEM and BSEE’s 

offices in the Gulf of Mexico Region. 

Interior’s Use of Existing 

Authorities to Supplement 

Salaries Has Been Limited
Page 25 GAO-14-205 Interior Human Capital

relocation, and retention awards for petroleum engineers and 

inspectors—critical positions that the bureaus have had difficulty hiring 

and retaining in recent years—has been limited (see tables 3 and 4).

Table 3: Interior’s Use of Recruitment, Relocation, and Retention Awards to Hire and Retain Petroleum Engineers, Fiscal 

Years 2010 through 2012

Bureau Year

Number of 

petroleum 

engineers 

onboard

Number

of 

petroleum 

engineers hired a

Number of 

recruitment 

incentives 

awarded

Number of 

relocation 

incentives 

awarded

Number of 

retention 

incentives 

awarded

BLM 2010 79.0 2 1 1 1

2011 74.5 8 0 0 0

2012 69.0 6 1 2 3

MMS/BOEMRE/

BOEM-BSEE

2010 152.5 11 1 0 0

2011 159.0 18 1 0 0

2012 42 (BOEM)

136 (BSEE)

5 (BOEM)

16 (BSEE)

0 1 (BOEM)

1 (BSEE)

0

Sources: GAO analysis of Enterprise Human Resources Integration and Interior data.

a

Table 4: Interior’s Use of Recruitment, Relocation, and Retention Awards to Hire and Retain Inspectors, Fiscal Years 2010 

through 2012

The number of staff on board is the average number of staff in the current and past fiscal year.

Bureau Year

Number of 

inspectors 

onboarda

Number of 

inspectors 

hired

Number of 

recruitment 

incentives 

awarded

Number of 

relocation 

incentives 

awarded

Number of 

retention 

incentives 

awarded

BLM 2010 n/a 37 1 2 0

2011 n/a 36 0 0 0

2012 About 170 32 b 0 1 6

MMS/BOEMRE/

BSEE

2010 66.5 6 0 0 0

2011 74.5 28 0 0 0

2012 89.0 21 1 0 0

Sources: GAO analysis of Enterprise Human Resources Integration and Interior data.

a

The number of staff on board is the average number of staff in the current and past fiscal year.

b

We could not determine the number of BLM oil and gas facility inspectors from the EHRI data. BLM 

provided an approximate number of oil and gas facility inspectors as of August 2012.

BLM officials cited fiscal constraints as the primary reason why they did 

not use these incentives more often. A July 2011 memorandum from 
Page 26 GAO-14-205 Interior Human Capital

OPM and the Office of Management and Budget (OMB) directed federal 

agencies to limit the use of recruitment, retention, and relocation incentive 

awards to fiscal year 2010 levels. Our review of OPM data shows, 

however, that in 2011Interior paid about one-third less in such awards 

than it did in 2010. Specifically, in 2010, Interior paid just over $3 million 

for 401 recruiting, retention, and relocation incentive awards as opposed 

to 2011, when the department paid just under $2 million. As such, Interior 

had the discretion to spend another $1 million on these incentive awards 

in 2011 but chose not to do so even as it faced difficulty hiring and 

retaining key oil and gas oversight positions.

Other factors may have also contributed to the limited use of recruitment, 

retention, and relocation incentive awards. Specifically, a BLM official 

stated that there was confusion about OPM and OMB’s requirement to 

limit incentive awards to 2010 levels, and that some field office managers 

were uncertain about the extent to which they were allowed to use these 

incentive awards. A 2012 BLM report on BLM’s oil and gas inspection and 

enforcement workforce strategy reported that the process to request use 

of these incentive awards required the development of a justification on a 

case-by-case basis for each award. Therefore, it recommended 

developing a “bureau-wide blanket authorization” for a 25 percent 

recruitment and retention incentive for all petroleum engineers and 

inspectors. BSEE officials, however, also described situations where 

potential employees declined job offers even though they were offered 

these incentive awards. Without clear guidance outlining when these 

incentives are to be used and a means to measure their effectiveness, 

however, Interior will not be able to demonstrate that it has fully used its 

existing authorities to offer recruitment, relocation, and retention 

incentives to supplement salaries for key oil and gas positions.

To help reduce hiring times, Interior participated in an OPM-led, 

government-wide initiative to streamline the federal hiring process and 

has taken other actions. Specifically, under the OPM-led effort, an Interior 

official stated that, in 2009, Interior formed a team composed of hiring 

managers and human resources specialists representing all of Interior’s 

bureaus to examine the department’s hiring process. The team compared 

Interior’s hiring processes to OPM’s 80-day hiring model and identified 27 

action items to reduce hiring times, including standardizing position 

descriptions and reducing the number of managers involved in the hiring 

approval process. Interior and its bureaus have addressed many of these 

action items over the past few years and, according to Interior officials 

and agency records, made significant progress in reducing hiring times. 

Interior Has Taken Some 

Steps to Reduce Hiring 

Times but Does Not Have 

Complete and Accurate 

Data to Help Identify 

Further Opportunities
Page 27 GAO-14-205 Interior Human Capital

For example, in 2010, BLM developed and distributed guidance to 

streamline its hiring processes, including the use of standardized position 

descriptions and vacancy announcements. According to Interior officials, 

these steps reduced hiring times at Interior as a whole from an average of 

190 days in fiscal year 2009 to 80 days in fiscal year 2012, although, as 

discussed above, hiring times for some key oil and gas positions 

averaged over 120 days.

In addition, BLM, BOEM, and BSEE have taken other steps to expedite 

the hiring process. To respond to the hiring needs of BOEM and BSEE 

following the reorganization of BOEMRE in October 2011,46 BSEE hired 

additional human resources staff in the Gulf of Mexico Region. In August 

2012, BSEE implemented a new process that reduced the number of 

days from 90 to 30 for managers to select eligible applicants. Although 

this new guidance still exceeds OPM’s 80-day hiring model, which 

allocates 15 days for a manager to review and select eligible candidates.

BSEE’s analysis of its hiring data shows that this guidance has reduced 

hiring times at BSEE headquarters and two of the three BSEE regional 

offices.47 A BLM official told us that the bureau is working on additional 

initiatives to improve the efficiency of the hiring process such as 

automating vacancy announcements and streamlining administrative 

processes.

However, neither the department nor the three bureaus have complete 

and accurate data on hiring times that could help them identify and 

address the causes of delays in the hiring process. In 2011, Interior 

began reporting data on hiring times to OPM on a quarterly basis. A 

senior Interior official explained that the department calculates hiring 

times based on a combination of dates from Interior’s personnel and 

payroll databases. However, we identified instances where these data 

appear to be inaccurate—for example, in some cases, hiring times were 

recorded as 0 days or 1 day. An official from BLM stated that the bureau 

does not have a systematic approach to analyzing data on hiring times, 

and neither BOEM nor BSEE collects comprehensive data that could be 

used to identify delays in the hiring process so that problems can be 

 46Since the reorganization of BOEMRE in October 2011 into BOEM and BSEE, BSEE 

provides human resources support for BOEM under terms of a reimbursable service 

agreement. 

47BSEE did not have hiring data from its Alaska Regional Office.
Page 28 GAO-14-205 Interior Human Capital

systematically addressed. BSEE has begun taking some informal actions 

to identify the causes of delays. For example, BSEE human resources 

officials said that, in August 2012, they began collecting hiring data on a 

biweekly basis in a spreadsheet and tracking the status of each BOEM 

and BSEE job announcement to help track the progress of individual 

applicants as they move through the hiring process. To use these data to 

evaluate hiring times at various stages of the hiring process, however, 

BOEM and BSEE would have to manually sum how long it takes each 

applicant to complete each stage of the hiring process. Without reliable 

data on hiring times, Interior’s bureaus cannot identify how long it takes to 

complete individual stages in the hiring process, identify delays, and 

implement changes to expedite the hiring process.

Interior’s bureaus have taken the following actions to improve their 

recruiting efforts:

Developing a marketing strategy. In 2012, BOEM and BSEE contracted 

with a media strategy firm to study the competitive marketplace for 

qualified applicants and draft a strategy to attract and retain staff for key 

technical positions. BOEM and BSEE officials cited various advantages to 

employment at Interior as compared with industry, including more flexible 

work hours, better job satisfaction, and more employment security. For 

example, according to BSEE officials, many industry oil and gas jobs 

require staff to spend up to 2 consecutive weeks offshore, whereas BSEE 

inspectors or engineers rarely spend more than 2 to 5 nights offshore. 

One BSEE manager stated that some of its new hires are former industry 

employees who do not want to be away from their families for extended 

periods. A BLM planning document indicates that BLM is also considering 

contracting with a media strategy firm to review its recruiting strategy.

Broadening recruiting efforts. Some BLM and BSEE officials told us that 

they are making an effort to visit college campuses to recruit oil and gas 

staff. In addition, BSEE officials told us that, in late 2013, they plan to visit 

27 colleges and universities, as well as attend conferences, such as 

those sponsored by the Society of Petroleum Engineers and the 

American Association of Petroleum Geologists. The BSEE officials also 

described planning joint hiring activities with BLM and Interior. BOEM has 

sent staff to universities and conferences to recruit geoscientists. Officials 

from BLM’s Bakersfield Field Office told that they have a long-standing 

relationship with California State University, Bakersfield, and have hired 

students from that school.

Interior’s Bureaus Have 

Taken Some Actions to 

Improve Recruiting
Page 29 GAO-14-205 Interior Human Capital

Offering internships. BLM, BOEM, and BSEE have had some success 

offering positions to student interns and converting them to full-time 

positions. Currently, Interior conducts its internship program under the 

Pathways Program, which recently replaced the Student Career 

Experience Program and the Student Temporary Employment 

Programs.48 In summer 2013, BSEE hired 24 interns through the 

Pathways Program.

Interior and the three bureaus—BLM, BOEM, and BSEE—are 

participating in several workforce planning efforts, including governmentwide, department-wide, and bureau-level initiatives. Because these efforts 

are ongoing, however, it is too early to evaluate how they will affect hiring 

and retention challenges across BLM, BOEM, and BSEE. As we have 

previously reported,49 strategic workforce planning helps an organization 

align its human capital program with its current and emerging mission and 

programmatic goals, as well as develop long-term strategies for acquiring, 

developing, and retaining staff to achieve programmatic goals. We also 

previously reported on the importance of workforce planning to ensure 

that programs are implemented consistently across the department.

At the department level, Interior is currently participating in two efforts to 

improve its workforce planning. First, Interior is participating in a 

government-wide initiative led by OPM to identify and mitigate critical 

skills gaps across the federal government. Specifically, this effort aims to 

develop strategies to hire and retain staff possessing targeted skills to 

help address government-wide and department-specific mission-critical 

occupations and skill gaps. Second, in response to an OMB request, 

Interior issued Managing People and Programs – Department of the 

Interior Strategic Workforce Management Plan in March 2012, which 

provided an overview of workforce planning strategies that Interior can 

use to manage workforce levels in consideration of emerging needs, skills 

 48The Student Temporary Employment Program and the Student Career Experience 

Program were both programs that provided federal employment opportunities to students 

who were enrolled or accepted for enrollment as students seeking degrees taking at least 

a half-time academic, technical, or vocational course load in an accredited high school, 

technical, vocational, 2- or 4-year college or university, graduate, or professional school. 

Both of these programs were replaced by the Pathways Program in June 2012.

49GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003).

Interior and Its Bureaus 

Have Undertaken Various 

Workforce Planning Efforts
Page 30 GAO-14-205 Interior Human Capital

gaps, and constrained budgets. As part of the next phase of this effort, 

Interior has asked its bureaus and offices to begin developing detailed 

workforce plans using a standardized model based on best practices 

used at Interior. According to the March 2012 plan, these bureau-level 

plans are to include a risk assessment of funding, workload, personnel, 

and positions; an analysis of workforce demand and supply; a skills gap 

analysis; and an action plan to mitigate risks and address skills gaps. 

Because both of these initiatives are ongoing, however, it is too early to 

assess the effect of these efforts on Interior’s hiring and retention 

challenges for key oil and gas positions.

BLM, BOEM, and BSEE are also developing or implementing workforce 

plans, which are in various stages of completion. As previously 

mentioned, in July 2012, we reported that BOEM and BSEE did not have 

strategic workforce plans in place and recommended that each bureau 

develop such a plan.50 BSEE recently issued its Human Capital Strategic 

Plan, 2013-2018, in September 2013. BOEM officials told us that they 

expect to complete their strategic workforce plan in 2014. In March 2012, 

BLM issued its Workforce Planning Strategy, 2011 to 2015, which 

outlines broad, strategic objectives that addressed some key human

capital challenges but leaves the development of implementation 

strategies to BLM managers at other organizational levels, including the 

state office level.51 In addition, BLM’s plan did not address challenges 

with the hiring process or outline mechanisms to monitor, evaluate, or 

improve the hiring process. Although BLM’s plan discusses the use of 

relocation and other incentive awards, it does not indicate when the use 

of these incentive awards is warranted, how the effectiveness of their use 

will be assessed, or how BLM will balance priorities to budget for these 

incentives. It remains unclear whether these efforts will help BLM address 

its human capital challenges. In addition, BLM and BSEE have a number 

of planning teams working on various aspects of recruitment and 

retention. In particular, these teams make recommendations for bureau 

initiatives, including actions to improve the hiring process or to increase 

the use of recruitment and retention incentives. These efforts, however, 

do not appear to have been conducted as part of a workforce plan. 

 50GAO-12-423.

51BLM generally has four organizational levels: national, state, district, and field offices. 

BLM’s state offices generally oversee district and field offices that are within its 

jurisdiction. 
Page 31 GAO-14-205 Interior Human Capital

Therefore, these efforts do not appear to have been conducted in a 

coordinated and consistent manner across the bureaus or offices, and 

officials do not have a basis to assess the success of these efforts or 

determine whether and how these efforts should be adjusted over time.

Officials from BLM, BOEM, and BSEE reported that hiring and retention 

challenges have had numerous effects on some field offices’ operations, 

including making it more difficult for some field offices to carry out 

oversight activities because of position vacancies.

Officials we interviewed and surveyed at the three bureaus reported that 

their hiring and retention challenges have generally resulted in less time 

available for oversight activities. These officials stated that vacancies 

directly affect the number of oversight activities they can carry out—

including the number of inspections they can conduct and the amount of 

time they can spend processing APDs. Officials at some BLM field offices 

reported that they have not been able to meet their annual inspection and 

enforcement goals because of vacancies. Compounding these problems 

is the fact that new staff are less experienced and, thus, less efficient in 

carrying out oversight activities, according to BLM, BOEM, and BSEE 

officials. In addition, officials said that experienced staff are expected to 

help train and mentor new staff, which reduces the amount of time they 

can spend on their own oversight work. Interior officials also told us that 

retention challenges in particular have led to a loss of institutional 

knowledge and fewer staff available to mentor the less-experienced 

newcomers. For instance, a BOEM official in Alaska stated that the 

primary effect of hiring difficulties in Alaska is the lost mentoring 

opportunities for senior geologists and engineers to train new staff. He 

said the work BOEM does is highly specialized and technical and that the 

bureau is often not able to hire candidates with related experience, which 

exacerbates the lost mentoring opportunities. In response to our survey, 

officials from 13 of the 20 BLM and BSEE offices with inspector vacancies 

reported that they somewhat or greatly reduced the number of 

inspections conducted in 2012 compared with what they would have done 

if fully staffed,52 and officials from 9 of the 20 offices with inspector 

vacancies indicated that the thoroughness of inspections was somewhat 

 52Specifically, 10 of the 13 BLM offices and 3 of the 7 BSEE offices reporting inspector 

vacancies said they somewhat or greatly reduced the number of inspections conducted in 

2012 compared with what they would have done if fully staffed. 

Hiring and Retention 

Challenges Have 

Made It More Difficult 

to Carry Out Some 

Oversight Activities
Page 32 GAO-14-205 Interior Human Capital

or greatly reduced because of these vacancies.53 In addition, officials from 

8 of the 21 BLM and BSEE offices with petroleum engineer vacancies 

indicated that vacancies somewhat or greatly reduced the number of 

APDs reviewed in 2012 compared with what they would have done if fully 

staffed.54

The effects of vacancies can be difficult to quantify because so much 

depends on the circumstances of the office, including the type and scale 

of local industry activity, as well as the field office’s overall staffing levels 

and ability to adjust to vacancies. BSEE officials said, however, that fewer 

or less-thorough inspections may mean that some offices are less able to 

ensure operator compliance with applicable laws and regulations and, as 

a result, there is an increased risk to human health and safety due to a 

spill or accident. According to a BSEE official, the longer federal 

inspectors are away from a site, the more likely operators are to deviate 

from operating in accordance with laws and regulations. In responding to 

our survey, a few BLM field offices noted that hiring and retention 

difficulties have hindered the development of oil and gas resources in 

some cases. In particular, the survey respondents reported experiencing 

delays in conducting leasing reviews, conducting resource management 

plan amendment reviews, or approving seismic studies to locate oil and 

gas reservoirs. For instance, in May 2013, a BLM field office postponed 

all remaining oil and gas leasing activities in California for the remainder 

of the fiscal year due, in part, to the need to shift staff to permitting and 

inspections. In addition, according to some BSEE officials we interviewed, 

field offices are not always able to reassign staff to make up for staffing 

shortfalls as some positions are highly specialized.

Officials at the three bureaus cited steps they have taken to address 

vacancies in key oil and gas positions, including reassigning staff from 

lower-priority to higher-priority tasks, borrowing staff from other offices, or 

increasing overtime. However, each of these steps comes at a cost to the 

agency and are not sustainable solutions. Interior officials stated, for 

instance, that shifting staff from lower to higher priority work means that 

 53Specifically, 6 of the 13 BLM offices and 3 of the 7 BSEE offices reporting inspector 

vacancies said that the thoroughness of inspections was somewhat or greatly reduced 

because of these vacancies.

54Specifically, 6 of the 14 BLM offices and 2 of the 7 BSEE offices reporting petroleum 

engineer vacancies said that vacancies somewhat or greatly reduced the number of APDs 

reviewed in 2012 compared with what they would have done if fully staffed. 
Page 33 GAO-14-205 Interior Human Capital

the lower priority tasks—many of which are critical to the bureaus’

mission—are deferred or not conducted. For example, a BLM office in 

Utah reported in our survey that, while it was able to conduct all highpriority inspections, doing so delayed other priorities, such as processing 

APDs and planning for an oil or gas lease sale. Similarly, offices that 

borrow staff from other offices gain the ability to carry out their activities, 

but this comes at a cost to the office that loaned the staff. For example, 

officials from a BLM field office in North Dakota described how they 

borrowed staff from a field office in Montana to help process APDs and 

carry out inspections. As a result, the BLM officials in the North Dakota 

field office told us they were able to make some progress to address a 

backlog of APDs and complete required inspections; however, according 

to BLM survey respondents, the field office work in Montana has suffered. 

With regard to overtime, offices from BOEM reported in our survey that a 

heavy reliance on overtime was exhausting their staff.

Further, both BLM and BSEE are developing and implementing riskbased inspection strategies—long recommended by us and others—as 

they work to ensure their oversight resources are efficiently and 

effectively allocated; however, staffing shortfalls and turnover may 

adversely affect the bureaus’ ability to carry out these new strategies. 

Specifically, in 2010, we found that BLM routinely did not meet its goals 

for conducting key oil and gas facility inspections and recommended that 

the bureau consider an alternative inspection strategy that allows it to 

inspect all wells within a reasonable time frame, given available 

resources.55 In response to this recommendation, in fiscal year 2011, 

BLM implemented a risk-based inspection strategy whereby each field 

office inspects the highest risk wells first. Similarly, BSEE officials told us 

that they have contracted with Argonne National Laboratory to help 

develop a risk-based inspection strategy.

As part of this review, we analyzed the effect of staffing shortages on 

oversight of offshore oil and gas activities in the Gulf of Mexico Region 

and found that continued hiring difficulties could hinder implementation of 

a risk-based inspection strategy. Specifically, we estimated the number of 

inspections that could have been conducted in the Gulf of Mexico under 

three staffing scenarios: (1) a scenario where BSEE was unable to hire 

additional inspectors between fiscal years 2010 and 2012; (2) a scenario 

 55GAO-10-313. 
Page 34 GAO-14-205 Interior Human Capital

approximating the actual number of inspectors in fiscal year 2012; and 

(3) a scenario where BSEE was able to hire double the number of 

inspectors it hired between fiscal years 2010 and 2012. Based on our 

analysis, increasing the number of production inspectors by 14 provided 

the capacity to conduct annual inspections at all or almost all Gulf of 

Mexico production facilities in fiscal year 2012. If BSEE had increased the 

number of production inspectors by 28 before fiscal year 2012, our 

analysis indicates that it would have been able to conduct annual 

inspections at all production facilities and conduct additional inspections 

at some production facilities considered high risk. Even with these 

additional staff, however, BSEE would not have had the capacity to 

conduct additional inspections at every facility considered high risk. See 

appendix III for details on our analysis.

In recent years, Interior has navigated major challenges in its oversight of 

oil and gas activities on federal lands and waters—including a major 

reorganization of its oil and gas oversight activities amid a dramatic 

increase in domestic oil and gas development. These changes 

notwithstanding, effective oversight of oil and gas development on federal 

lands and waters is a challenging endeavor requiring experienced staff 

with highly specialized training and skills. Interior has faced long-standing 

challenges hiring and retaining these staff and, with the current energy 

boom and increased industry competition for skilled workers, these 

problems have been exacerbated.

Interior and its bureaus have made some progress to address the two 

major factors affecting hiring and retention of key oil and gas staff—higher 

salaries in industry and the lengthy federal hiring process—but difficulties 

persist. While federal salaries for key oil and gas positions may not match 

salaries in industry—particularly in periods and locations of rapid industry 

growth—Interior is not doing all that it can to bridge this gap. Interior has 

obtained special salary rates in certain regions, such as in the Gulf of 

Mexico, and for certain positions, such as petroleum engineers and 

geologists, but it has not made full use of its existing authorities to offer 

recruitment, retention, and relocation incentives. We recognize that the 

use of these incentives comes at a cost to other programmatic efforts, 

and Interior must balance these needs as it develops its workforce plans. 

However, in the event that Interior applies for special salary rates for key 

oil and gas positions in the future, whether from OPM or Congress, 

demonstrating that it has fully utilized its existing authorities can help 

support its request for such salary rates. Similarly, Interior’s hiring times 

for key oil and gas positions continue to lag behind hiring times for other 

Conclusions
Page 35 GAO-14-205 Interior Human Capital

positions at Interior and lag behind the federal government more broadly. 

However, because Interior does not systematically collect and analyze 

data on its hiring process, it cannot readily identify delays in the process 

or the causes of such delays. Without reliable data on hiring times, 

Interior’s bureaus cannot identify how long it takes to complete individual 

stages in the hiring process, identify delays, and implement changes to 

expedite the hiring process.

To ensure a consistent and comprehensive approach to addressing 

BLM’s, BOEM’s, and BSEE’s ongoing hiring and retention challenges, we 

recommend the Secretary of the Interior direct the following two actions:

• Explore the expanded use of existing authorities, including 

recruitment, relocation, and retention incentives to help bridge the 

salary gap for key oil and gas oversight positions such as petroleum 

engineers, geologists, and geophysicists, and develop clear guidance 

for when the use of these incentives are warranted and how the 

effectiveness of their use will be assessed.

• Systematically collect data on hiring times for key oil and gas 

positions, ensure the accuracy of the data, analyze the data to identify 

the causes of delays and expedite the hiring process.

We provided a draft of this report to the Department of the Interior for 

review and comment. Interior generally agreed with our findings and 

concurred with both recommendations. In its written comments, Interior 

agreed that its long-term human capital challenges will require the full use 

of available hiring and retention incentives to the extent that they can be 

supported by each bureau’s budget. Interior also stated that the bureaus 

have begun a more systematic collection and analysis of hiring data to 

identify the causes of delays and help expedite the hiring process. Interior 

noted, as described in our report, that it has taken a number of actions to 

address its hiring and retention challenges. Interior noted that the 

continuing resolutions and sequester in fiscal years 2013 and 2014 

reduced funds available for bureaus’ staffing. This required a hiring freeze 

as well as a reduction to the bureaus’ budget allocations for oil and gas 

activities. Interior also noted that, beginning in fiscal year 2012, the 

agency requested the authority to collect fees for BLM’s onshore 

inspection program. Interior stated that this would increase the certainty 

of available funding for staffing and help adequately fund the inspection 

program. In its written comments, Interior stated that it believed it has 

implemented one of our recommendations from GAO-12-423, Oil and 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 36 GAO-14-205 Interior Human Capital

Gas Management: Interior’s Reorganization Complete, but Challenges 

Remain in Implementing New Requirements, that BOEM and BSEE need 

to prepare strategic workforce plans. However, as discussed in this 

report, BSEE completed its plan in September 2013 and BOEM officials 

told us that they will complete their plan in fiscal year 2014. Finally, 

Interior stated that BSEE continues to be concerned that the analysis 

presented in appendix III is limited. We agree that our model, like all 

empirical models, has certain limitations. While these limitations affect our 

ability to make precise predictions about the effect of BSEE’s hiring 

difficulties, they do not, however, change our finding that these difficulties

could hinder implementation of a risk-based inspection strategy. In its 

response, Interior noted that it will consider our model, along with other 

factors, as it develops a new risk-based inspection strategy. Interior 

provided written technical comments, which we incorporated into the 

report, as appropriate. Appendix IV reproduces Interior’s comments.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Secretary of the Department of the Interior, the appropriate congressional 

committees, and other interested parties. In addition, this report will be

available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or ruscof@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix V.

Frank Rusco

Director, Natural Resources and Environment
Page 37 GAO-14-205 Interior Human Capital

This report examines (1) the extent to which Interior continues to face 

challenges hiring and retaining key oil and gas staff and the causes of 

these challenges; (2) Interior’s efforts to address its hiring and retention 

challenges; and (3) the effects, if any, of hiring and retention challenges 

on Interior’s oversight of oil and gas activities.

To conduct this work, we reviewed relevant laws and Interior guidance, as 

well as independent studies of Interior’s oil and gas oversight conducted 

by Interior’s Office of Inspector General and others. In addition, we 

reviewed reports evaluating Interior’s oil and gas oversight that were 

conducted in response to the BP Deepwater Horizon incident. We also 

interviewed officials from Interior’s bureaus responsible for oil and gas 

oversight—the Bureau of Land Management (BLM), the Bureau of Ocean 

Energy Management (BOEM), and the Bureau of Safety and 

Environmental Enforcement (BSEE). Specifically, we interviewed BLM 

headquarters officials as well as BLM officials in the Bakersfield, 

California, field office and Dickinson, North Dakota, field office; BOEM 

and BSEE headquarters officials, as well as BOEM and BSEE officials in 

the Gulf of Mexico, Alaska, and Pacific regional offices; and BSEE 

officials in all five Gulf of Mexico district offices—Houma District Office, 

Lafayette District Office, Lake Charles District Office, Lake Jackson 

District Office, and New Orleans District Office. In addition, we surveyed 

management officials from 3 BOEM regional offices, 7 BSEE district

offices, and 33 BLM field offices, and one BLM state office with oil and 

gas responsibilities (collectively referred to as field offices for the 

purposes of this report) to ask about the extent to which field offices 

experienced problems hiring and retaining oil and gas management and 

oversight staff, the factors that contribute to success or difficulty hiring 

and retaining staff, and the effects of staffing difficulties, if any, on the 

ability of the field offices to oversee oil and gas operations. Our survey 

had a 91 percent response rate. Appendix II presents more information 

about our survey.

To examine the extent to which Interior continues to face challenges 

hiring and retaining key oil and gas personal and the causes of these 

challenges, we analyzed statistical data from the Office of Personnel 

Management’s (OPM) Enterprise Human Resources Integration (EHRI) 

data on attrition and retirement eligibility and reviewed and analyzed 

Interior data on vacancies and hiring times.1 We compared attrition rates 

 1

The EHRI database was formerly known as the Central Personnel Data File. 

Appendix I: Objectives, Scope, and 

Methodology
Page 38 GAO-14-205 Interior Human Capital

for key oil and gas oversight positions with vacancy and attrition rates for 

Interior bureaus, Interior, other federal agencies, and the federal 

government. We also reviewed Interior and federal government data on 

retirement eligibility, and compared retirement eligibility for Interior oil and 

gas positions with positions at other federal agencies. We also analyzed 

Bureau of Labor Statistics data on federal and industry salary rates and 

compared the rates for key oil and gas oversight positions with analogous 

positions in industry. In addition, we reviewed OPM’s hiring reform 

initiative for the federal government, including standards for hiring time 

frames for federal employees and analyzed Interior’s data on hiring times 

for key oil and gas oversight positions.

To examine Interior’s efforts to address its hiring and retention 

challenges, we reviewed documents from Interior, BSEE, and BLM such 

as strategic workforce plans, implementation plans, guidance, and other 

documents outlining steps Interior has taken, or plans to take, to address 

hiring and retention problems, and we spoke with officials responsible for 

their implementation. We also discussed special salary rates for specific 

positions with officials from OPM and officials from BSEE and BLM who 

were responsible for working with OPM on these special pay rate issues. 

We reviewed bureaus’ use incentives such as recruitment, retention, and 

relocation payments data provided by Interior. We focused on the 

challenges reported by agency officials during interviews and in our 

survey.

To examine the effects, if any, of hiring and retention challenges on 

Interior’s oversight of oil and gas activities, we surveyed BLM, BOEM, 

and BSEE about the factors affecting their abilities to hire and retain oil 

and gas oversight staff and how vacancies in these positions have 

affected day-to-day operations. Based on interviews with Interior officials, 

reviews of Interior workforce planning reports, and a review of staffing 

data, we identified the following key BLM oil and gas oversight positions: 

petroleum engineers, petroleum engineering technicians (inspectors), 

natural resource specialists, environmental protection specialists, and 

geologists. Similarly, we identified petroleum engineers, inspectors, 

biologists (natural resource specialists), geophysicists, and geologists as 

key BOEM and BSEE oil and gas oversight positions. We also analyzed 

BSEE inspection data from the Gulf of Mexico and Pacific regions—

where nearly all federal offshore drilling has occurred—for fiscal years 

2010 through 2012. This data is held in Interior’s Technical Information 

Management System (TIMS) database. TIMS provides the foundational 

data for BOEM and BSEE, including data on lease sales, lease 

adjudication, wells and platforms, pipelines, and inspection records, 
Page 39 GAO-14-205 Interior Human Capital

among other things. We obtained TIMS data on offshore facilities, 

including facility characteristics; inspectors; and inspection records, 

including inspection duration and inspection results. We analyzed data 

from fiscal year 2010 through fiscal year 2012. We assessed the reliability 

of these data by (1) reviewing the data for obvious errors in accuracy and 

completeness; (2) reviewing existing documentation about the data and 

the TIMS database; (3) interviewing Interior officials knowledgeable about 

the data; and (4) verifying with agency officials a limited sample of some 

of our results. On the basis of our assessment, we determined that the 

data were sufficiently reliable for our purposes. Appendix III presents 

more information about our analysis of BSEE inspection data.

We conducted this performance audit from May 2012 to January 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 40 GAO-14-205 Interior Human Capital

As part of our assessment of the challenges that Interior’s field offices 

continue to face hiring and retaining key oil and gas oversight staff and 

the effects of these challenges on oversight, we surveyed officials from 44 

field offices that have oil and gas management responsibilities on (1) the 

extent of these challenges, (2) the factors affecting hiring and retention, 

and (3) the effects of hiring and retention challenges on oil and gas 

oversight. We received responses from 40 of the 44 field offices—

including 30 of the 33 Bureau of Land Management (BLM) field offices, 1 

BLM state office with oil and gas oversight responsibilities, 7 of the 7 

Bureau of Safety and Environmental Enforcement (BSEE) district offices, 

and 3 of the 3 Bureau of Ocean Energy Management (BOEM) regional 

offices—for a response rate of 88 percent from BLM and 100 percent 

from BSEE and BOEM, or a total response rate of 91 percent. We 

statistically analyzed the survey responses and found that officials 

reported almost 200 vacancies in 2012 in the six oil and gas occupations 

we asked about—petroleum engineers, inspectors, natural resource 

specialists, environmental protection specialists, geologists, and 

geophysicists—and officials indicated that almost 90 percent of these 

vacancies took more than three months to fill. Our analysis shows that the 

vacancies resulted in varied effects on field offices. Some field offices 

reported carrying out fewer inspections, or doing less-thorough 

inspections or delaying application for permit to drill (APD) approvals, and 

other field offices also reported delaying or forgoing tasks other than 

conducting inspections or reviewing APDs and increasing the amount of 

overtime staff worked. Survey respondents identified several factors that 

contributed to difficulties hiring and retaining staff, including differences in 

salaries between Interior and industry, the slow federal hiring process, 

and limited promotion opportunities. By contrast, survey respondents 

indicated more positive effects on hiring because of working conditions 

and benefits, which were identified as helping field offices hire and retain 

staff more often than other factors. However, based on our analysis, 

these factors did not prevent the agency from experiencing significant 

vacancies. Details about the survey methodology, results of our analysis, 

and detailed survey data are presented below.

We designed our survey to quantify the perceptions of field office 

managers regarding the extent of Interior’s vacancies in oil and gas 

oversight positions and the causes and effects of those vacancies. We 

asked respondents: (1) how many authorized staff and how many 

vacancies they had in selected positions; (2) whether they had difficulty 

hiring and retaining oil and gas oversight staff in 2012; (3) what factors 

contributed to any difficulty hiring and retaining these staff; and (4) how 

Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Survey Design
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 41 GAO-14-205 Interior Human Capital

hiring and retention difficulties, if any, affected oil and gas oversight 

activities at their field offices. To identify the potential causes and effects 

of oil and gas staff vacancies, we conducted one focus group with field 

office managers, interviewed bureau officials, and reviewed reports on 

Interior’s oil and gas oversight, including our reports and Interior’s 

Inspector General reports.

Based on our interviews and focus group, we identified: (1) potential 

factors affecting the agency’s ability to fill vacancies, including salaries, 

benefits, working conditions, and speed of the hiring process; (2) potential 

effects on oil and gas oversight, including reductions in the number of 

facilities inspected, reductions in the thoroughness of these inspections, 

and reductions in the number of APDs reviewed; and (3) potential effects 

on staff, including increases in the amount of overtime worked and 

increases in the number of other tasks left undone. We used this 

information to develop survey questions for completion by field office 

managers, which were simple enough to yield valid responses, and we 

designed our survey to maximize the reliability of our survey data.

To limit the scope of our survey to the most pertinent information, we 

asked questions about these topics for a small number of specific oil and 

gas oversight positions that were identified as critical to oil and gas 

oversight or as likely problematic to hire and retain, or both. To determine 

which oil and gas oversight positions to include in our survey, we 

interviewed agency officials, reviewed GAO and Inspector General 

reports on hiring and retention, reviewed Interior’s staffing data covering 

fiscal year 2009 through fiscal year 2012, and reviewed Interior’s list of 

mission-critical occupations as identified as part of its human capital highrisk initiative. From these inputs, we chose six occupations to include in 

our survey: petroleum engineers, inspectors, natural resource specialists, 

environmental protection specialists, geologists, and geophysicists. For 

BLM, we asked about petroleum engineers, petroleum engineering 

technicians, natural resource specialists, environmental protection 

specialists, and geologists. For BOEM and BSEE, we asked about 

petroleum engineers, inspectors, natural resource specialists, geologists, 

and geophysicists. To help ensure that survey respondents were able to 

recall the information, we asked about experiences with these staff in 

calendar year 2012. Our survey was sent to respondents in January 

2013.

Our survey was divided into five sections. In the first section, we asked 

field offices how many staff were authorized for each position and the 

number of vacancies during 2012. In the second section, we asked 
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 42 GAO-14-205 Interior Human Capital

general questions about the factors we identified as affecting hiring and 

retention. In the third section, we asked about the extent to which the field 

offices had difficulty hiring staff followed by a series of questions linking 

the factors to those hiring difficulties. In the fourth section, we asked 

about the extent to which the field offices had difficulty retaining staff 

followed by a series of questions linking the factors to retention 

difficulties. In the fifth section, we asked about the effect of vacancies on 

the ability of the field offices to carry out oil and gas oversight activities. In 

addition, we included a number of open-ended questions in the survey to 

allow respondents to elaborate on these topics. To view the survey as 

sent to field offices, see the end of this appendix.

To minimize the potential for errors in responses, we conducted three 

cognitive pretests with field office managers. During these pretests, we 

assessed whether the questions were clear, could be answered with 

available information, and did not pose an undue burden on field office 

managers. We modified the survey questions in response to these 

pretests, as appropriate.

We administered the survey to the managers of 44 field offices; 

specifically, 33 BLM field offices and 1 BLM state office, 3 BOEM regional 

offices, and 7 BSEE district offices. We implemented our survey as a 

Microsoft Word document that was disseminated to field offices via email. We sent the survey to senior field office officials, with instructions on 

how to open, complete, and save it, on January 10, 2013. We sent two 

reminders via e-mail in the following weeks before closing the survey in 

February 2013. We received responses from 30 of the 34 BLM field 

offices, and from each of the 3 BOEM regional offices and the 7 BSEE 

district offices, for an overall response rate of 91 percent.

To understand how the factors in our survey relate to vacancies and 

Interior’s ability to oversee oil and gas facilities, we arranged the survey 

data into a cause-and-effect diagram (see fig. 6). This diagram outlines 

the relationships between responses to questions about factors affecting 

hiring and retention, the level of difficulty respondents reported in hiring 

and retaining staff, and the reported effects of the resultant vacancies on 

staff time and oil and gas oversight. We first analyzed the factors affecting 

hiring and retention based on the extent to which they helped or hindered 

hiring and retention. We then analyzed the relationship between reported 

vacancies and the responses to our questions regarding effects on staff 

Survey Population

Data Analysis
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 43 GAO-14-205 Interior Human Capital

time and, ultimately, on the ability of Interior to manage oil and gas 

activities on federal leases.

Figure 6: Cause and Effect Diagram 

Four factors generally contribute to difficulties hiring and retaining staff 

and two factors generally help, according to our analysis. Complete 

survey results are presented in tables 5-11.

For each of the six positions we asked about in our survey, managers first 

indicated how many staff were authorized for each position at their field 

office and how many vacancies they had in calendar year 2012 for each 

position (see table 5). Managers also indicated the level of difficulty they 

had hiring and retaining staff during calendar year 2012. We found that a 

significant number of field offices indicated that it was somewhat or very 

difficult to hire and retain staff (see table 6).

Results
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 44 GAO-14-205 Interior Human Capital

Table 5: Authorized Positions and Vacancies

(a) Approximately how many oil and gas management staff does your field office (include satellite locations) currently have 

authorized in each of the following positions?

(b) In calendar year 2012, approximately how many vacancy announcements did your field office post for each of the 

following positions?

Position

Number of offices 

with that position

Total number of 

allocated staff

Total reported vacancy 

announcements in 2012

Petroleum engineer 36 177 66

Inspector 33 328 70

Natural resource specialist 31 199 34

Environmental protection specialist 12 22 7

Geologist 27 122 15

Geophysicist 4 52 6

Source: GAO analysis of survey results.

Table 6: Ease or Difficulty in Hiring and Retaining Staff for Those Offices with Vacancies

In calendar year 2012, how easy or difficult was it for your field office to fill vacancies in each of the following positions?

Position

Somewhat 

easy

Very 

easy

Neither easy

nor difficult

Somewhat 

difficult 

Very 

difficult

Petroleum engineer 1 1 3 4 16

Inspector 1 1 3 9 10

Natural resource specialist 1 4 4 4 4

Environmental protection specialist 1 0 1 1 1

Geologist 1 0 1 3 6

Geophysicist 0 0 0 0 3 

In calendar year 2012, how easy or difficult was it to retain staff in your field office for each of the following positions?

Position

Somewhat 

easy

Very 

easy

Neither easy

nor difficult

Somewhat 

difficult 

Very 

difficult

Petroleum engineer 2 5 9 11 5

Inspector 2 5 11 6 7

Natural resource specialist 1 8 7 5 6

Environmental protection specialist 2 2 5 1 1

Geologist 3 3 10 5 2

Geophysicist 0 1 1 1 1

Source: GAO analysis of survey results.

Subsequently, we asked about factors that help or hinder hiring and 

retention, and we found that a majority of managers cited the following 

factors as generally hindering their ability to hire and retain staff: higher 
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 45 GAO-14-205 Interior Human Capital

salaries in industry, the slower speed of the federal hiring process, the 

lack of qualified applicants in some areas, and greater opportunities for 

promotion in industry (see tables 7 and 8). By contrast, far fewer than half 

of the managers cited two factors—employment benefits and working 

conditions at field offices—as hindering their ability to hire and retain staff 

(see tables 7 and 8).

Table 7: Extent to Which Factors Help or Hinder Ability to Hire Oil and Gas Oversight Staff for Those Offices with Vacancies

Based on your experience hiring for each of the following positions, do you think that the difference in salaries (not 

including benefits) between your field office and the private sector helps or hinders your field office’s ability to hire qualified 

candidates?

Position

Greatly

helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 0 0 0 2 22

Inspector 0 0 0 7 13

Natural resource specialist 0 3 7 3 2

Environmental protection specialist 0 0 0 1 2

Geologist 0 0 0 3 5

Geophysicist 0 0 0 1 2

Based on your experience hiring for each of the following positions, do you think the speed of the hiring process helps or 

hinders your ability to hire qualified candidates?

Position

Greatly

helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 0 0 2 5 17

Inspector 0 0 0 8 12

Natural resource specialist 0 0 5 4 6

Environmental protection specialist 0 0 0 2 1

Geologist 0 0 2 2 4

Geophysicist 0 0 0 1 2

Based on your experience hiring for each of the following positions, to what extent does the availability of qualified

candidates in your geographical area help or hinder your ability to hire for each of the following positions?

Position

Greatly

helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 1 1 2 8 12

Inspector 2 2 5 7 4

Natural resource specialist 0 3 3 5 4

Environmental protection specialist 0 0 1 1 1

Geologist 0 0 2 3 3

Geophysicist 0 0 0 3 0
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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 46 GAO-14-205 Interior Human Capital

Based on your experience hiring for each of the following positions, do you think that differences in opportunities for career 

advancement and promotion between your field office and the private sector help or hinder your ability to hire qualified 

candidates for each of the following positions?

Position

Greatly

helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 0 2 3 7 8

Inspector 0 1 5 8 4

Natural resource specialist 0 2 7 4 1

Environmental protection specialist 0 0 2 1 0

Geologist 0 0 3 2 3

Geophysicist 0 0 2 0 1

Based on your experience hiring for each of the following positions, do you think that the difference in benefits (vacation 

time, sick leave, health insurance, retirement plan, student loan repayments, etc.) between your field office and the private 

sector helps or hinders your ability to hire qualified candidates?

Position

Greatly

helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 0 5 11 2 5

Inspector 0 5 8 2 2

Natural resource specialist 0 6 7 2 0

Environmental protection specialist 0 1 0 1 0

Geologist 0 1 1 4 2

Geophysicist 0 1 1 0 1

Based on your experience hiring for each of the following positions, do the differences in working conditions (including the 

types of tasks performed, the total hours worked, and flexibility in schedule) between your field office and the private sector 

help or hinder your ability to hire qualified candidates?

Position

Greatly

helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 1 14 6 1 1

Inspector 0 14 5 0 0

Natural resource specialist 1 8 5 1 0

Environmental protection specialist 1 2 0 0 0

Geologist 1 4 0 2 0

Geophysicist 0 2 0 1 0

Source: GAO analysis of survey results.
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 47 GAO-14-205 Interior Human Capital

Table 8: Extent to Which Factors Help or Hinder Ability to Retain Oil and Gas Oversight Staff

Based on your experience, do you think the difference in salaries (excluding benefits) between the agency and the private 

sector helps or hinders your field office’s ability to retain staff in the following positions?

Position Greatly helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 0 0 3 12 18

Inspector 0 0 6 12 13

Natural resource specialist 0 1 14 4 7

Environmental protection specialist 0 0 6 2 2

Geologist 0 0 6 7 10

Geophysicist 0 0 1 2 1

Based on your experience, do you think that differences in opportunities for career advancement and promotion between 

your bureau and the private sector help or hinder your field office’s ability to retain staff in the following positions

Position Greatly helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 0 1 5 14 8

Inspector 0 3 4 10 8

Natural resource specialist 0 7 9 3 2

Environmental protection specialist 0 2 4 2 0

Geologist 0 1 6 11 2

Geophysicist 0 0 2 1 0

Based on your experience, do you think that the difference in benefits (vacation time, sick leave, health insurance, 

retirement plan, student loan repayments, etc.) between your field office and the private sector helps or hinders your field 

office’s ability to retain staff in each of the following positions?

Position Greatly helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat 

hinders

Greatly 

hinders

Petroleum engineer 0 14 7 8 4

Inspector 1 13 11 4 1

Natural resource specialist 0 11 11 3 0

Environmental protection specialist 0 4 4 1 0

Geologist 0 10 7 4 2

Geophysicist 0 0 3 0 1

Based on your experience, do you think the differences in working conditions (including the types of tasks performed, the 

total hours worked, and flexibility in schedule) between your field office and the private sector help or hinder your field 

office’s ability to retain staff in each of the following positions?

Position Greatly helps 

Somewhat 

helps

Neither helps 

nor hinders

Somewhat

hinders

Greatly 

hinders

Petroleum engineer 2 20 7 3 2

Inspector 2 18 7 2 1

Natural resource specialist 3 11 8 2 2
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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 48 GAO-14-205 Interior Human Capital

Environmental protection specialist 2 4 3 1 0

Geologist 2 13 5 2 2

Geophysicist 0 2 1 1 0

Source: GAO analysis of survey results.

The majority of field offices that reported vacancies in these six positions 

reported that those vacancies were unfilled for 3 months or more (see 

table 9). These vacancies caused field offices to delay or forego tasks or 

require staff to work overtime (see table 10). Vacancies also led field 

offices to reduce the number of inspections conducted, the thoroughness 

of inspections, or the number of APDs reviewed than what they would 

have done if they were fully staffed (see table 10).

Table 9: Average Reported Length of Vacancies, Calendar Year 2012

On average, about how many months (from announcement to entrance-on-duty date) did it take to fill these vacancies?

Position

Less than three 

months

3 months to 

6 months

More than 

6 months

Petroleum engineer 3 6 16

Inspector 0 16 6

Natural resource specialist 3 8 4

Environmental protection specialist 1 2 0

Geologist 1 4 4

Geophysicist 0 0 3

Source: GAO analysis of survey results.

Table 10: Effects of Vacancies on Oil and Gas Oversight

In calendar year 2012, did vacancies in the following positions, if any, increase the amount of overtime worked by oil and 

gas management staff at your field office?

Position Greatly increased Somewhat increased Did not increase

Petroleum engineer 4 12 7

Inspector 6 9 5

Natural resource specialist 1 7 5

Environmental protection specialist 0 2 1

Geologist 1 4 2

Geophysicist 0 3 0

In calendar year 2012, did vacancies in the following positions, if any, cause oil and gas management staff to delay or forgo

other tasks at your field office? 

Position Regularly Occasionally Never

Petroleum engineer 5 14 5

Inspector 5 7 8
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Oversee Oil and Gas Activities

Page 49 GAO-14-205 Interior Human Capital

Natural resource specialist 3 8 4

Environmental protection specialist 1 1 1

Geologist 2 4 1

Geophysicist 1 1 1

In calendar year 2012, did vacancies in the following positions, if any, reduce the number of inspections of oil and gas 

facilities conducted by your field office?

Position Greatly reduced Somewhat reduced Did not reduce

Petroleum engineer 1 5 11

Inspector 6 7 6

Natural resource specialist 0 7 5

Environmental protection specialist 0 3 0

Geologist 0 0 4

Geophysicist 0 0 1

In calendar year 2012, did vacancies in the following positions, if any, reduce the thoroughness of inspections of oil and gas 

facilities by your field office?

Position Greatly reduced Somewhat reduced Did not reduce

Petroleum engineer 0 4 14

Inspector 2 7 10

Natural resource specialist 0 4 8

Environmental protection specialist 0 1 2

Geologist 0 2 2

Geophysicist 0 1 0

In calendar year 2012, did vacancies in the following positions, if any, reduce the number of applications for permit to drill 

(APDs) reviewed by your field office?

Position Greatly reduced Somewhat reduced Did not reduce

Petroleum engineer 1 7 12

Inspector 0 2 8

Natural resource specialist 3 5 4

Environmental protection specialist 0 1 1

Geologist 1 2 2

Geophysicist 0 0 1

Source: GAO analysis of survey results.

Although we believe the results of our analysis characterize the staffing 

challenges faced by Interior, our analysis is subject to certain limitations 

that prevent us from making precise quantitative estimates or causal 

statements. In particular, our survey data are based on the perceptions of 

field office managers. An analysis using data for conditions at field offices, 

vacancies for specific positions, and oil and gas oversight activities 

Limitations
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 50 GAO-14-205 Interior Human Capital

conducted might produce different results. In addition, our analysis was 

based on frequency counts of survey data, rather than on a statistical 

model or a research design that would isolate cause and effect. 

Therefore, although we believe that field office managers are in the best 

position to assess the effect of Interior’s staffing challenges, our results 

must be characterized as their perceptions.

Survey as Sent to Interior 

Field Offices
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

Page 51 GAO-14-205 Interior Human Capital

1

The survey sent to BLM field offices asked about petroleum engineering technicians 

while the survey sent to BOEM and BSEE field offices instead asked about inspectors. 

The survey sent to BLM field offices asked about environmental protection specialists 

while the survey sent to BOEM and BSEE field offices instead asked about geophysicists. 
Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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Appendix II: Survey of Interior’s Field Offices 

on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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on the Challenges to Hire and Retain Staff to 

Oversee Oil and Gas Activities

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Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

Page 68 GAO-14-205 Interior Human Capital

Following the Deepwater Horizon incident in April 2010, Congress 

increased funding to the Bureau of Safety and Environmental 

Enforcement (BSEE), which allowed the bureau to more than double the 

number of oil and gas inspector positions allocated to the Gulf of Mexico 

Region, from 52 nonsupervisory inspectors to 129 nonsupervisory 

inspectors. Since then, BSEE has had difficulty filling these allocated 

positions because of problems with both hiring and retention. As of 

October 2012, BSEE had filled about one-quarter of the new inspector 

positions, bringing the total number of nonsupervisory inspectors in the 

bureau’s Gulf of Mexico Region to 71.

To determine the effect of the remaining vacancies on the bureau’s 

capacity to oversee oil and gas operations in the Gulf of Mexico, we 

modeled the bureau’s capacity for conducting production facility 

inspections under three staffing scenarios. Specifically, we estimated the 

number of production inspections that the bureau could have conducted 

in fiscal year 2012 on the 2,498 production facilities in the Gulf of Mexico 

Region under three staffing scenarios. Based on our analysis, we found 

that the additional inspectors hired by BSEE in the past few years have 

given it the capacity to conduct annual inspections at all or nearly all of 

the production facilities in the Gulf of Mexico in fiscal year 2012, 

something it had not otherwise been able to do. However, at the 2012 

staffing levels, our model shows that the bureau did not have the capacity 

to conduct additional inspections at more than a small number of the 

1,409 facilities it had designated as high risk. Bureau officials told us that 

such a risk-based inspection strategy is critical to effectively managing 

the risks of oil and gas production. However, our analysis shows that 

Interior’s continued hiring difficulties may hinder the implementation of 

this strategy.

Our model estimated the bureau’s capacity to inspect oil and gas 

production facilities in the Gulf of Mexico in fiscal year 2012 under three 

staffing scenarios. Because the bureau did not formally distinguish 

production inspectors from other types of inspectors until fiscal year 2012, 

Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

Overview of Analysis

Staffing Scenarios
Appendix III: Analysis of Effects of Inspector

Vacancies in the Gulf of Mexico

Page 69 GAO-14-205 Interior Human Capital

we approximated the number of production inspectors for each of these 

scenarios for the purpose of our model as follows:1

• Scenario 1. In this scenario, we assumed that the bureau had 34 fulltime equivalent (FTE) production inspectors—the approximate 

number of production inspectors employed at the end of fiscal year 

2010 before the bureau was able to hire additional staff.

• Scenario 2. In this scenario, we assumed that the bureau had 48 FTE 

production inspectors—the approximate number of production 

inspectors employed during fiscal year 2012.

• Scenario 3. In this scenario, we assumed that the bureau hired double 

the number of production inspectors than it actually did between fiscal 

years 2010 and 2012, for a total of 62 FTE production inspectors—

significantly more inspectors than it actually hired, but fewer than its 

allocation.

For each of the three staffing scenarios, our model estimates the number 

of annual inspections and additional risk-based inspections that could 

have been conducted. We compared the first set of estimates with the 

total number of annual inspections that the bureau was required to 

perform in fiscal year 2012 under the Outer Continental Shelf Lands Act 

(OCSLA), which requires Interior to provide for the inspection of every 

outer continental shelf facility at least once annually, as well as periodic 

on-site inspections without advance notice.2 We compared the second set 

of estimates with the number of facilities that the bureau identified as high 

risk in fiscal year 2012. Our model operates in two stages. The first stage 

assumes that the bureau would conduct an annual inspection of each 

offshore facility as provided for by OCSLA. The second stage assumes, 

after annual inspections are completed, that inspectors would use the 

remaining time to conduct additional inspections at high-risk facilities. 

These additional inspections are not required by statute, but bureau 

officials told us they are necessary to more fully ensure compliance with 

regulations, and that additional staff hired prior to fiscal year 2012 would 

 1

In 2012, BSEE began dividing its inspectors by technical specialization, including 

production facility inspectors and drilling rig inspectors. Therefore, to approximate the 

number of FTE production inspectors in fiscal year 2012, we analyzed agency data for 

each of the inspectors that bureau officials told us were classified as production 

inspectors. To approximate the number of production inspectors in fiscal year 2010, we 

extrapolated the ratio of production inspectors to drilling inspectors from 2012 onto the 

2010 staff data. 

2

OCSLA, as amended (43 U.S.C. §1331 et seq.). 
Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

Page 70 GAO-14-205 Interior Human Capital

likely have been used to carry out these additional inspections. High-risk 

facilities include those that produce a lot of oil and gas, are staffed around 

the clock, or had poor inspection results or significant incidents in the 

past, among other characteristics. BSEE is currently developing a riskbased inspection methodology that BSEE officials told us will likely 

include reinspections of high-risk facilities, as well as more emphasis on 

important inspections that are currently not being carried out—such as 

inspections of construction activities and certain critical components.

According to our analysis of BSEE inspection records, by hiring new 

inspectors between fiscal years 2010 and 2012, the bureau gained the 

capacity to conduct annual inspections at all or nearly all of the production 

facilities in the Gulf of Mexico Region. Even with these additional 

inspectors, however, the bureau did not have the capacity in fiscal year 

2012 to conduct additional, risk-based inspections at more than a small 

number of high-risk facilities. Because every inspection takes a differing 

amount of time, and because each inspector spends a different amount of 

time each year conducting inspections, there is some uncertainty in 

predicting the number of inspections that would be conducted with a 

given number of staff. We account for this uncertainty by presenting 

ranges of estimates for each scenario. Our results are described below, 

presented in table 11, and illustrated in figure 7.

• Scenario 1. If the bureau had not hired additional inspectors with 

funds received from its fiscal year 2012 appropriations, it would not 

have been able to conduct the required annual inspections of all 

production facilities in fiscal year 2012, according to our estimates. 

Under its fiscal year 2010 staffing level of approximately 34 production 

inspectors, we estimate that the bureau had the capacity to inspect 

between 1,575 and 2,061 production facilities out of a total of 2,498 

existing production facilities in fiscal year 2012—enough to conduct 

the required annual inspections at between 63 percent and 83 percent 

of production facilities in that year. Because the bureau would not 

have been able to complete 100 percent of the required annual 

inspections under this scenario, we conclude that it would have not

have had the capacity to conduct any additional risk-based 

inspections in fiscal year 2012.

• Scenario 2. By hiring enough staff to have a net increase of 14 

production inspectors, the bureau gained the capacity to conduct the 

required annual inspections at all or almost all of the production 

facilities in fiscal year 2012. Specifically, we estimate that the bureau 

had the capacity to conduct between 2,263 and 2,788 production 

Results
Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

Page 71 GAO-14-205 Interior Human Capital

inspections in fiscal year 2012—enough to complete required annual 

inspections at between 91 percent and 100 percent of production 

facilities in fiscal year 2012. In addition, our model estimates that the 

bureau could have conducted additional risk-based inspections at 

between 0 and 290 facilities, or as few as zero or as many as 21 

percent of the high-risk production facilities in fiscal year 2012. This 

staffing level gave the bureau the capacity to typically conduct the 

required annual production inspections at approximately all production 

facilities but would not have given the bureau the capacity to 

consistently conduct a significant amount of additional risk-based 

inspections in fiscal year 2012.

• Scenario 3. If the bureau had been able to hire enough staff to have a 

net increase of 28 production inspectors—14 more inspectors than it 

actually hired but still significantly short of its allocation—it would have 

had the capacity to conduct annual inspections at all production 

facilities, as well as significantly more risk-based inspections. Under 

this scenario, the bureau would have had the capacity to conduct 

between 2,785 and 3,386 production inspections—enough to conduct 

the required annual inspections at 100 percent of production facilities 

in fiscal year 2012. In addition, this staffing level would have given the 

bureau the capacity to conduct additional, risk-based inspections at 

between 287 and 888 production facilities—approximately 20 to 63 

percent of the high-risk facilities in fiscal year 2012. Even with these 

additional staff, however, the bureau would still not have had the 

capacity to conduct additional inspections at all high-risk facilities. 

Without filling its additional vacancies, its ability to fully implement a 

risk-based inspection strategy could be hindered.

Table 11: Estimated Number of Production Facility Inspections Conducted under Three Staffing Scenarios

Number of annual inspections 

conducted

Number of additional 

inspections conducted

Total number of inspections 

conducted

Scenario

Lower 

bound Mean a Upper 

boundb Lower bound Mean a Upper boundb Lower bound Mean a Upper bound

Scenario 1

(34 inspectors)

b

1,575 1,813 2,061 0 0 0 1,575 1,813 2,061

Scenario 2

(48 inspectors) 2,263 2,457 2,498 0 74 290 2,263 2,531 2,788

Scenario 3

(62 inspectors) 2,498 2,498 2,498 287 568 888 2,785 3,066 3,386

Source: Estimates are based on GAO’s simulation model of oil and gas production facilities in the Gulf of Mexico during fiscal year 

2012.

a

This is the lower bound of the 95 percent confidence interval.

b

This is the upper bound of the 95 percent confidence interval.
Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

Page 72 GAO-14-205 Interior Human Capital

Figure 7: Estimated Number of Production Facility Inspections Conducted under 

Three Staffing Scenarios

a

This is the lower bound of the 95 percent confidence interval.

b

This is the upper bound of the 95 percent confidence interval.

In conducting our analysis, we used data from Interior’s Technical 

Information Management System (TIMS) database. We focused our 

analysis on production facilities inspected by production operations 

inspectors in the Gulf of Mexico in fiscal year 2012. These facilities 

account for nearly 30 percent of the nation’s domestic oil production and 

nearly 11 percent of domestic natural gas production. We limited our 

analysis to sample inspections, in which BSEE inspects a random subset 

of safety devices on a facility, and to complete inspections, in which it 

completes a full inspection of all paperwork, safety devices, and physical 

condition of the facility. These are the two types of scheduled inspections 

BSEE uses to fulfill its annual production facility inspection requirement.

Data
Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

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In fiscal year 2012, the nonsupervisory inspectors conducted 

approximately the same number of sample and complete production 

inspections as there were production facilities. In particular, there were 

2,498 production facilities in the Gulf of Mexico that were eligible for 

inspection, and nonsupervisory inspectors conducted 2,511 production 

inspections, including both sample inspections and complete inspections 

during this period. Some of the facilities were inspected more than once 

in this time period, while others were inspected not at all.

We examined the accuracy of Interior’s TIMS data and determined the 

data were sufficiently reliable for the purpose of estimating the effect of 

broad policy scenarios, although we detected some inaccuracies. In 

particular, data on the number of hours spent on an inspection are based 

on estimates made by individual inspectors when completing inspections. 

These data are subject to the ability of individual inspectors to properly 

estimate time spent on various inspection tasks. For example, if an 

inspector visits two facilities on a single day, the inspector would need to 

determine how to allocate travel time, waiting time, inspection time, and 

paperwork time to allot to multiple facilities.

Using the TIMS data described above, we developed a multiple 

regression model to estimate the number of staff hours required to 

conduct an inspection based on the characteristics of the facilities. We 

defined staff hours to include the total number of hours recorded by all 

nonsupervisory production inspectors on a given inspection. We tallied 

the time for all aspects of an inspection, including travel time, paperwork 

time, and waiting time, in addition to the time to conduct the inspection. 

Because the number of hours did not follow a normal statistical 

distribution, we transformed the variable into its natural logarithm for our 

analysis. In conducting our regression analysis, we used data for a 

random sample of 1,239 inspections that the bureau conducted in fiscal 

year 2012. To double-check the predictive accuracy of the model, we 

used data for an additional 1,238 inspections as a testing sample and 

calculated goodness of fit statistics.3

 3

An additional 34 inspections were missing data for inspection time, risk classification, or 

status as a major or minor facility. These inspections could not be included in our 

calculations.

Multiple Regression 

Model Estimating 

Time Required to 

Conduct an 

Inspection
Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

Page 74 GAO-14-205 Interior Human Capital

Our multiple regression model estimates the amount of time required to 

conduct an inspection based on two characteristics of a facility: (1) 

whether BSEE classifies the facility as major or minor and (2) whether it 

classifies the facility as high risk or low risk. BSEE defines a major facility 

as one that has at least six wells or more, as well as more than two 

pieces of production equipment, which are components that process oil, 

gas, or water, such as a separator. BSEE defines a high-risk facility by a 

number of characteristics, such as the amount of oil or gas the facility 

produces, whether the facility is staffed or unstaffed, and the history of the 

operator’s compliance with regulations. Of the inspections conducted in 

fiscal year 2012, 36.9 percent were classified as major and higher-risk, 

10.9 percent were classified as major and low-risk, 19.4 percent were 

classified as minor and high-risk, and 31.5 percent were classified as 

minor and low-risk. We included these variables in our analysis based on 

the premise that larger, riskier facilities would require more time to 

inspect.

The results of the multiple regression model are presented in table 12. 

Both variables were statistically significant predictors of the time required 

to inspect a facility and, correspondingly, we found that the time required 

to conduct an inspection varies widely by facility type. As expected, major 

and high-risk facilities require the most time to inspect. On average, 

inspections of such facilities require approximately 22.4 staff hours, 

according to our model. By contrast, minor, low-risk facilities require the 

least amount of time to inspect. On average, inspections of such facilities 

require approximately 4.0 staff hours, according to our model. Other types 

of facilities require a more moderate amount of time, with minor, high-risk 

facilities requiring an average of 5.8 hours to inspect and major, low-risk 

facilities requiring an average of 8.6 hours to inspect. To make these 

predictions, we transformed the estimates from the regression equation, 

which are on a logarithmic scale, to a linear scale.

Table 12: Multiple Regression Model Estimating the Time Required to Inspect Production Facilities, Fiscal Year 2012

Parameter

Parameter

estimate

Standard

error Z Value a Pr > |Z|

Intercept 0.925 0.077 12.09 <.0001

Whether facility is defined by the bureau as major 0.758 0.133 5.68 <.0001

Whether facility is defined by the bureau as high risk 0.365 0.073 4.97 <.0001

Whether the facility defined by the agency as both major and 

high risk

0.590 0.148 4.00 <.0001

Source: GAO analysis of BSEE’s TIMS data.
Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

Page 75 GAO-14-205 Interior Human Capital

Note: This model estimates the natural logarithm of the number of hours required to inspect oil and 

gas production facilities in the Gulf of Mexico in fiscal year 2012 based on a random sample of 1,239

inspections.

a

The model has a good fit based on the F statistic (p<.001) and predicts 37

percent of the variance in the time required to conduct an inspection 

(adjusted R2

=0.37). We checked to ensure that the residuals, which 

represent the difference between the predicted value and the actual value 

for a given facility, were normally distributed and on average, zero. We 

estimated robust standard errors accounting for the fact that facilities are 

clustered within operators.

These are robust standard errors that account for facilities being clustered within operators.

To estimate the number of inspections that the bureau would be able to 

conduct under each staffing scenario, we incorporated the results of our 

multiple regression analysis into a Monte Carlo simulation. A Monte Carlo 

simulation is a type of numerical analysis that produces a range of 

estimates to account for the random variability among inspections and the 

statistical uncertainty in the model’s equations. In this case, we used a 

Monte Carlo simulation to account for the variability in the number of 

hours necessary to inspect each facility and the number of inspections 

conducted by each inspector. For instance, BSEE officials told us that 

some facilities may take longer to inspect than others because of factors 

that are difficult to account for, such as the availability and ability of the 

operator’s onboard personnel on offshore facilities being inspected. 

Similarly, not all inspectors spend the same amount of time conducting 

inspections each year, so there is some variability in the total amount of 

time that a given number of inspectors would spend on production 

inspections.

The Monte Carlo simulation entailed several key steps. For each staffing 

scenario, the model estimates the amount of time that a given number of 

inspectors has available for conducting production inspections, taking into 

account the variation we found in our analysis of BSEE’s fiscal year 2012 

inspection records. On average, production inspectors spent 627 hours 

conducting production inspections, though some inspectors spent 

considerably more time, and others spent considerably less time. The 

model also estimates the number of hours required to inspect each facility 

for each staffing scenario, taking into account the variability in inspection 

times we found in the multiple regression model described above. The 

model then simulates facility inspections until the total number of hours 

available for inspections is reached. If all facilities are able to be 

inspected within the total number of available hours, the model uses the 

Monte Carlo 

Simulation Estimating 

the Number of 

Inspections That Can 

Be Conducted
Appendix III: Analysis of Effects of Inspector 

Vacancies in the Gulf of Mexico

Page 76 GAO-14-205 Interior Human Capital

remaining time to simulate additional inspections beginning with the highrisk facilities. When the total number of available hours is reached, the 

model stops simulating inspections and calculates the total number of 

facilities inspected. The model repeats each of these steps 1,000 times to 

produce 1,000 estimates of the total number of facilities inspected for a 

given number of inspectors. Collectively, these 1,000 estimates 

characterize the range of uncertainty in the bureau’s capacity to conduct 

inspections for each of the staffing scenarios. To further assess the 

accuracy of the model, we compared the number of inspections estimated 

by our model with the number of inspections conducted by BSEE in fiscal 

year 2012. The actual number of inspections—2,511—was within 1 

percent of our mean estimate of 2,531 and within the 95 percent 

confidence interval as shown in table 11.

To estimate the effect of various staffing scenarios, our analysis makes 

some simplifying assumptions. First, we assume that the time required to 

conduct annual inspections is a valid approximation of the time required 

to conduct additional, risk-based inspections. Because the bureau has 

seldom conducted such inspections, we did not have sufficient data to 

test this assumption. Second, because of the natural variability in 

inspections—such as variations in the amount of time that inspectors 

spend inspecting production facilities during a year and the number of 

hours required to inspect a given facility—it is difficult to make precise 

predictions about the outcomes of any given staffing scenario. Third, 

because our estimates are based on data from fiscal year 2012, our 

results may not apply to future years if future years differ significantly. For 

example, if weather conditions are more favorable in future years, 

inspectors may be able to fly to facilities on more days, leading to more 

inspections being conducted by the same number of inspectors. By 

contrast, if production inspectors are diverted to perform duties other than 

inspections of production facilities, the same number of inspectors may 

be able to conduct fewer inspections. Even with this difference, we 

believe our model is a valid approximation of the relative effects among 

different staffing scenarios.

Limitations
Appendix IV: Comments from the Department 

of the Interior

Page 77 GAO-14-205 Interior Human Capital

Appendix IV: Comments from the 

Department of the Interior
Appendix IV: Comments from the Department 

of the Interior

Page 78 GAO-14-205 Interior Human Capital
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 79 GAO-14-205 Interior Human Capital

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

In addition to the individual named above, Christine Kehr, Assistant 

Director; Mark Braza; Mitchell B. Karpman; Michael Kendix; Michael 

Krafve; Armetha Liles; Steven Lozano; Alison O’Neill; Kelly Rubin; 

Jerome T. Sandau; Rebecca Shea; Jeff Tessin; Kiki Theodoropoulos; 

Barbara Timmerman; and Arvin Wu made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361409)
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