OIL AND GAS 

DEVELOPMENT

BLM Needs Better 

Data to Track Permit 

Processing Times and 

Prioritize Inspections

Report to Congressional Requesters

August 2013

GAO-13-572

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-572, a report to

congressional requesters

August 2013

OIL AND GAS DEVELOPMENT 

BLM Needs Better Data to Track Permit Processing 

Times and Prioritize Inspections

Why GAO Did This Study

BLM has key responsibilities for the 

development of federal oil and gas 

resources, including processing APDs. 

In 2005, GAO reported that the total 

number of APDs approved by BLM had 

increased, and as a result, BLM staff 

had less time for activities such as 

environmental inspections. 

GAO was asked to review BLM’s 

processing of APDs and efforts to 

protect the environment since then. 

This report examines, from fiscal years 

2007 to 2012, (1) changes in BLM’s 

permitting workload; (2) actions BLM 

has taken to manage its oil and gas 

permitting workload and challenges, if 

any, that remain; and (3) actions BLM 

has taken to mitigate the 

environmental impact of developing 

federal oil and gas resources, and 

challenges, if any, that remain. GAO 

analyzed BLM data on APDs and 

environmental inspections, from fiscal 

years 2007 to 2012, and interviewed 

officials at 11 BLM field offices 

selected to reflect a range of 

characteristics, including geographic 

representation.

What GAO Recommends

GAO recommends, among other 

things, that BLM should report to 

Congress on the results of a pilot 

project to improve APD processing and 

recommend whether it should be 

implemented throughout the United 

States; improve the completeness and 

accuracy of data on processing of 

APDs; and take steps to improve its 

ability to identify wells that are a high 

priority for environmental inspection. In 

commenting on a draft of this report, 

the Department of the Interior generally 

agreed with GAO’s recommendations.

What GAO Found

Bureau of Land Management (BLM) data indicate that BLM received about half 

as many applications for permit to drill (APD) for federal oil and gas resources in 

fiscal year 2012 as it had in fiscal year 2007. The decline in APDs since 2007 

was driven by declines in natural gas and coalbed methane APDs on federal 

lands even while oil development on federal lands increased significantly. The 

reasons BLM officials and industry representatives cited for these changes in 

APDs include, among other things, a general industry move toward developing 

gas in shale formations using horizontal drilling and hydraulic fracturing; shale 

development has largely occurred on state and private lands, where shale 

resources are predominately located. However, the number of APDs has varied 

by BLM location, with 23 of 33 BLM offices seeing declines, 9 offices seeing 

increases, and 1 office seeing no change in APDs.

BLM has taken actions to improve management of its oil and gas permitting 

workload, including revising its permitting rule in 2007 and implementing a pilot 

project to improve APD processing that increased funding and staff in seven BLM 

offices. It is unclear whether the pilot project has met its goals as BLM has 

neither completed an assessment of the project in the past 5 years, nor reported 

to Congress, as required by the Energy Policy Act of 2005, on the results of the 

project along with a recommendation about implementing the project throughout 

the United States. Further, in a 2013 internal memorandum, BLM reported that it 

has been unable to consistently process completed APDs within the 30-day 

deadline required by the act. GAO found that BLM’s central oil and gas database 

was missing certain data needed to assess compliance with this deadline and 

contained other inaccurate APD processing data. Without complete data on 

approved APDs, GAO could not perform a comprehensive assessment of the 

amount of time it took BLM to process APDs from their date of receipt to date of 

approval. Without accurate data on the amount of time it takes to process APDs, 

BLM does not have the information it needs to make adjustments that could 

improve its operations.

To mitigate the environmental impact of oil and gas development, BLM increased 

the number of environmental inspections it conducted of federal oil and gas wells 

and facilities from 10,941 in fiscal year 2007 to 17,866 in fiscal year 2012. BLM 

attributed the increase to revised guidance, performance targets for staff, 

additional staff in some offices, and technological changes in the oil and gas 

industry that result in more wells on a single well pad, allowing for multiple 

inspections at one site. Nevertheless, BLM’s environmental inspection 

prioritization process may not identify oil and gas wells that pose the greatest 

environmental risk because the agency’s central oil and gas database does not 

include data on the environmental inspection history of many wells, and 

environmental inspection history is not one of the criteria that BLM staff use in 

prioritizing inspections. GAO’s review of data on approximately 60,330 federal oil 

and gas wells found no record in BLM’s database of 24,840 wells ever having 

received an environmental inspection. In addition, GAO found inconsistent 

documentation of inspections and enforcement actions across BLM offices. View GAO-13-572. For more information, 

contact Frank Rusco at (202) 512-3841 or 

ruscof@gao.gov.
Page i GAO-13-572 BLM Oil and Gas Development

Letter 1 

Background 6

BLM’s Permitting Workload Has Changed in Number, Type, and 

Location of APDs 13

BLM Has Taken Actions to Better Manage Its Oil and Gas 

Permitting Workload, but Challenges Remain 19

BLM Has Taken Actions to Better Mitigate the Environmental 

Impact of Oil and Gas Development, but Challenges Remain 30

Conclusions 38

Recommendations for Executive Action 40

Agency Comments and Our Evaluation 40

Appendix I Objectives, Scope, and Methodology 43

Appendix II Comments from the Department of the Interior 49

Appendix III GAO Contact and Staff Acknowledgments 51

Tables

Table 1: Change in the Number of Applications for Permit to Drill 

Received by BLM Offices from Fiscal Years 2007 to 2012 16

Table 2: Change in the Number of Environmental Inspections 

Performed by BLM Offices from Fiscal Years 2007 to 2012 30

Figures

Figure 1: BLM’s Lead Offices for Oil and Gas Development and the 

Number of Wells They Manage 7

Figure 2: BLM’s Common Environmental Inspection Activities at 

Different Stages in the Life Cycle of a Well 12

Figure 3: Number of Applications for Permit to Drill Received by 

BLM by Source, Fiscal Years 2007-2012 14

Figure 4: Overview of Selected Key Dates, Steps, and Requirements 

in BLM’s Review Process for Applications for Permit to 

Drill 25

Contents 
Page ii GAO-13-572 BLM Oil and Gas Development

Abbreviations

AFMSS Automated Fluid Minerals Support System

APD application for permit to drill

BLM Bureau of Land Management

COA conditions of approval

FLPMA Federal Land Policy and Management Act of 1976

FOGRMA Federal Oil and Gas Royalty Management Act of 1982

INC Incident of Noncompliance

IT information technology

NEPA National Environmental Policy Act of 1969

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Page 1 GAO-13-572 BLM Oil and Gas Development

441 G St. N.W.

Washington, DC 20548

August 23, 2013

The Honorable Peter DeFazio

Ranking Member

Committee on Natural Resources

House of Representatives

The Honorable Edward J. Markey

United States Senate

Over the past decade, the development of the nation’s domestic sources 

of oil and natural gas—including on state, private, and federal lands—has 

intensified. At the same time, several changes have occurred in the oil 

and gas sector, such as shifts in oil and natural gas prices and 

technological advancements in horizontal drilling techniques combined 

with hydraulic fracturing.1 For example, horizontal drilling combined with 

hydraulic fracturing has resulted in the substantial growth of domestic 

onshore shale oil and shale gas production from 2007 to 2011.2

 

1

Hydraulic fracturing is a process in which water, sand, and chemical additives are 

injected under high pressure to create and maintain fractures in underground formations in 

order to extract oil and gas resources. When combined with horizontal drilling, hydraulic 

fracturing allows operators to fracture the rock formation along the entire horizontal portion 

of a well, increasing the number of pathways through which oil or gas can flow.

The 

changing dynamics of the onshore oil and gas sector contribute to 

challenges faced by the Department of the Interior’s Bureau of Land 

Management (BLM), which manages onshore federal oil and gas 

resources. Specifically the Federal Land Policy and Management Act of 

1976 (FLPMA), as amended, directs Interior to manage federal land for 

multiple uses, such as recreation and mineral extraction, while also taking 

any action required to prevent the “unnecessary or undue degradation” of 

federal land, including federal land that has been leased for oil and gas 

operations. The challenges BLM faces in managing the development of 

federal oil and gas resources while also mitigating the environmental 

impacts of this development have generated concern among some 

federal and state government officials, conservationists, and oil and gas 

companies about the balance between oil and gas development and the 

use of these federal lands for other purposes.

2

See GAO, Oil and Gas: Information on Shale Resources, Development, and 

Environmental and Public Health Risks, GAO-12-732 (Washington, D.C.: Sept. 5, 2012).

 
 

Page 2 GAO-13-572 BLM Oil and Gas Development

Under the Mineral Leasing Act of 1920, as amended, and other statutes, 

BLM issues leases for the development of oil and gas resources where 

authorized on and under BLM-managed federal land, under other federal 

agencies’ lands, and under private land for which the federal government 

holds mineral rights—amounting to roughly 700 million subsurface acres. 

Companies or individuals (referred to in this report as operators) holding 

leases for oil and gas development must submit an application for permit 

to drill (APD) to BLM and obtain approval before preparing land or drilling 

new oil or gas wells. After receiving an APD, BLM generally 

communicates with operators until they provide all of the required 

documents. The Energy Policy Act of 2005,3 among other things, requires 

BLM to approve or defer the APD within 30 days after the operator has 

submitted a complete APD. BLM’s process for reviewing an APD includes 

several key steps. For example, BLM generally reviews the APD to 

mitigate or avoid adverse impacts on the land, air, water, vegetation, and 

wildlife. Additionally, under its regulations, BLM is to ensure that the 

operator’s plans comply with relevant laws and regulations under BLM’s 

jurisdiction.4

BLM is responsible for requiring that operators comply with the terms of 

APDs, including COAs, during the entire life cycle of every well, and can 

take enforcement action if operators do not comply. Under the Federal Oil 

and Gas Royalty Management Act of 1982 (FOGRMA), as amended,

In addition, BLM is to review lease requirements, known as 

stipulations. BLM staff also are to review the APD to determine if any 

conditions of approval (COA)—such as protections for wildlife habitat, 

management of invasive species, or testing of well control equipment—

should be included in the APD. Once BLM approves the APD, and 

operators have obtained any necessary state permits or approvals, 

operators may drill, subject to the conditions of the APD.

5

 

3

Pub. L. No. 109-58, 119 Stat. 594 (2005).

4

BLM officials said that they generally review APDs for compliance with laws that are 

relevant to BLM’s jurisdiction, but not for laws that fall under the jurisdiction of other 

agencies, such as the Environmental Protection Agency, or for state laws and regulations. 

In some cases, BLM and states may regulate similar activities; in such cases, operators 

must comply with the more stringent regulation. For additional information on selected 

state requirements, see, GAO, Unconventional Oil and Gas Development: Key 

Environmental and Public Health Requirements, GAO-12-874 (Washington, D.C.: Sept. 5, 

2012).

5

Pub. L. No. 97–451, 96 Stat. 2447 (1993), codified as amended at 30 U.S.C. §§ 1701 et 

seq. (2013).
 

Page 3 GAO-13-572 BLM Oil and Gas Development

BLM has the authority to inspect federal oil and gas sites, including well 

pads and production facilities. According to the agency’s handbook for its 

inspection and enforcement program, BLM must ensure that oil and gas 

operations on federal lands are prudently conducted in a manner that 

ensures protection of the surface and subsurface environment.6

In 2005, we reported on aspects of BLM’s responsibilities for onshore oil 

and gas development.

Among 

the inspections conducted by BLM are environmental inspections that, 

among other things, ensure that (1) sensitive species are not disturbed 

during the construction of a well pad, (2) pits designed to hold the waste 

by-products of drilling activities are appropriately constructed and 

maintained, (3) significant erosion is not occurring on the well site, and (4) 

disturbed lands are properly reclaimed to as close to original condition as 

practical. If BLM determines through an inspection that a violation of a 

restriction or requirement of the APD occurred or is occurring, the agency 

can, depending on the violation, issue assessments or civil penalties or 

take other enforcement action.

7

You asked us to review BLM actions taken after our 2005 report with 

respect to processing APDs for oil and gas resources on federal lands 

and mitigating environmental impacts. The objectives of this review were 

to determine, from fiscal years 2007 to 2012, (1) what changes have 

occurred in BLM’s oil and gas permitting workload; (2) what actions BLM 

has taken to manage its oil and gas permitting workload and what 

challenges, if any, remain; and (3) what actions BLM has taken to 

mitigate the surface environmental impact of developing federal oil and 

Specifically, we reported that an increase in oil 

and gas operations on federal lands had lessened BLM’s ability to meet 

its responsibilities for mitigating the environmental impacts of oil and gas 

development. We found that from fiscal year 1999 to fiscal year 2004, the 

total number of APDs approved by BLM more than tripled—from 1,803 to 

6,399—and BLM officials in five out of eight field offices that we visited 

said that staff had to devote more time to processing APDs, leaving less 

time for conducting environmental inspections.

 

6

U.S. Department o the Interior, BLM, 2009 Inspection and Enforcement Documentation 

and Strategy Development Handbook (Washington, D.C., 2009).

7

GAO, Increased Permitting Activity Has Lessened BLM’s Ability to Meet Its 

Environmental Protection Responsibilities, GAO-05-418 (Washington, D.C.: June 17, 

2005).
 

Page 4 GAO-13-572 BLM Oil and Gas Development

gas resources and what challenges, if any, remain. We focused on 

actions BLM has taken to mitigate surface environmental impacts. We did 

not analyze other areas of BLM’s environmental efforts including land use 

planning, lease decisions, and inspections of subsurface activity.

To conduct this work, we reviewed federal laws and regulations regarding 

BLM’s management of onshore oil and gas resources owned by the 

federal government. In addition, we obtained data from BLM’s Automated 

Fluid Minerals Support System (AFMSS)—the central database that BLM 

uses to track oil and gas information on public land—including data on 

APDs received or approved and environmental inspections performed 

since fiscal year 2005. Since BLM’s information technology (IT) systems 

for tracking data on oil and gas development on Indian Trust lands were 

shut down for various periods from 2001 to 2008 because of a lawsuit, we 

did not review data on APDs or environmental inspections for nonfederal 

wells located on Indian Trust lands. Consequently, the data on APDs 

presented in this report refer exclusively to APDs for federal oil and gas 

resources, and the data presented on environmental inspections refer 

exclusively to inspections that were performed on federal wells and 

facilities. To determine how BLM’s permitting workload has changed, we 

analyzed the data on APDs received by BLM. We also analyzed BLM’s 

data on approved APDs to assess the time it takes to process APDs from 

the date of receipt to the date of approval. To assess the reliability of the 

APD data, we performed electronic testing of the data and interviewed 

agency officials about the data. We determined that the APD data were 

sufficiently reliable to present results on the number of APDs received by 

BLM from fiscal years 2007 to 2012 and the average number of days it 

took BLM to process APDs from the date of receipt to the date of 

approval in fiscal year 2012. We determined that BLM’s data on approved 

APDs were not sufficiently reliable to assess BLM’s compliance with the 

required 30-day deadline to approve or defer completed APDs or to 

assess the number of days it took BLM to process APDs prior to fiscal 

year 2012. To evaluate BLM’s efforts to mitigate the surface 

environmental impacts of oil and gas development, we analyzed BLM’s 

data on environmental inspections performed on federal oil and gas wells 

and facilities. To assess the reliability of the environmental inspection 

data, we performed electronic testing and interviewed agency officials 

about the data. We determined that the environmental inspection data for 

fiscal years 2005 and 2006 were not sufficiently reliable for our purposes; 

as a result, we limited the scope of the environmental inspections 

analysis to fiscal years 2007 through 2012. We believe the AFMSS data 

for those years are sufficiently reliable for the purposes presented in this 

report. To be consistent with our presentation of the environmental 
 

Page 5 GAO-13-572 BLM Oil and Gas Development

inspection data, we also limited the scope of the APD data presented in 

this report to fiscal years 2007 to 2012.To identify actions BLM has taken 

to manage its permitting workload and to mitigate the environmental 

impact of oil and gas development on federal lands, we reviewed BLM 

guidance and documentation and interviewed officials in BLM’s 

Washington, D.C., headquarters office. We selected a nonprobability 

sample of 11 BLM field offices that manage oil and gas development to 

contact and collect information about how each office manages its oil and 

gas program, including how the office reviews APDs for environmental 

mitigation purposes and inspects oil and gas activity on federal lands.8

We conducted this performance audit from May 2012 to August 2013 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.

We selected the 11 offices to reflect different geographical locations and 

types of oil and gas resources managed. In fiscal year 2012, these offices 

accounted for about 68 percent of all APDs received by BLM for federal 

oil and gas resources and for about 52 percent of all environmental 

inspections performed by BLM. In addition, we interviewed officials from 

four BLM state offices, selected on the basis of their jurisdiction over 

some of the field offices we contacted. We also interviewed 

representatives from environmental organizations and energy industry 

organizations to obtain their perspectives on BLM’s management of 

federal oil and gas resources. Appendix I describes our scope and 

methodology in more detail.

 

8

Because this was a nonprobability sample, observations from interviews with these 

offices, taken alone, do not support generalizations about other offices. However, such 

observations provide illustrative examples of the types of challenges BLM faces in 

managing its permitting workload and mitigating the environmental impact of oil and gas 

development. We visited and interviewed officials in eight BLM field offices (Colorado 

River Valley, Little Snake, and White River in Colorado; Moab, Price, and Vernal in Utah; 

and Pinedale and Rock Springs in Wyoming) and interviewed officials by telephone in 

three additional field offices (Carlsbad and Farmington in New Mexico, and the North 

Dakota Field Office). During our site visits to the Colorado River Valley, Vernal, and 

Pinedale Field Offices, we observed BLM officials conduct environmental inspections of oil 

or gas wells and related facilities.
 

Page 6 GAO-13-572 BLM Oil and Gas Development

This section discusses BLM’s organizational structure for managing oil 

and gas development, provides an overview of the process for developing 

federal oil and gas resources, and describes BLM’s inspection and 

enforcement program.

Implementation of BLM’s oil and gas program, including processing APDs 

and performing environmental inspections, primarily occurs at the field 

office level and is led by 33 BLM offices located primarily in the Mountain 

West.9 BLM’s headquarters, state, and district offices oversee and 

provide guidance and support to the field offices that implement BLM’s oil 

and gas program. As of December 2012, BLM offices were responsible 

for managing nearly 92,600 wells involved in developing federal onshore 

oil and gas resources. BLM offices in two states—New Mexico and 

Wyoming—accounted for about 67 percent of the total wells and BLM 

offices in three other states—California, Colorado, and Utah—accounted 

for about 24 percent. BLM’s remaining offices collectively accounted for 

about 9 percent of the total (see fig. 1).10

 

9

These 33 offices consist of 30 field offices, 1 field station—located in Hobbs (NM), which 

works closely with the Carlsbad (NM) Field Office—and 2 state offices, the BLM Alaska 

State Office and the BLM Nevada State Office, which oversee the development of federal 

oil and gas resources throughout their respective states. Some BLM offices in other 

locations have small oil and gas programs that are administered with the assistance of the 

33 lead offices.

Overall, the number of wells 

managed by BLM has increased since fiscal year 2007, when BLM 

reported managing about 79,970 wells.

10The number of wells presented here does not include federal wells that have been 

abandoned by operators or nonfederal wells that are located on Indian Trust lands. 

Background 

BLM’s Organizational 

Structure for Managing Oil 

and Gas Development
 

Page 7 GAO-13-572 BLM Oil and Gas Development

Figure 1: BLM’s Lead Offices for Oil and Gas Development and the Number of Wells They Manage

Note: The data presented in this figure include (1) wells that were located on lands whose surface is 

managed by BLM and that were in a producible or service status (i.e., wells that were physically and 

mechanically capable of producing oil or gas or that were used to support oil and gas operations 

through activities such as water disposal) as of December 18, 2012, and (2) wells that were located 

on lands whose surface is managed by other federal, state, or private entities, but which have mineral 
 

Page 8 GAO-13-572 BLM Oil and Gas Development

rights that are controlled by the federal government and that were in a producible or service status as 

of November 30, 2012. This figure does not include data on federal wells that have been abandoned 

or nonfederal wells located on Indian Trust lands. Some BLM field offices in other locations also have 

small oil and gas programs that are administered with the assistance of the 33 lead offices, and their 

well numbers are included in the totals presented in this figure for their respective lead office.

a

Staff from the Carlsbad Field Office provide support to the Hobbs Field Station on some oil and gas 

activities, including processing APDs and performing environmental inspections.

b

BLM also manages 14 additional federal wells that are not included in the total presented in this 

figure due to their database records listing multiple field offices for the same well.

FLPMA requires the Secretary of the Interior to develop land use plans 

that are evaluated for potential revision at least every 5 years. These 

plans identify federal lands and mineral resources that will be available for 

oil and gas development and other activities.11 As part of developing or 

revising land use plans, BLM is required under the National 

Environmental Policy Act of 1969 (NEPA), as amended, to evaluate likely 

environmental effects of decisions in the plan, such as selecting areas for 

oil and gas development. Generally, Interior prepares an environmental 

impact statement—a detailed statement of the likely environmental effects 

of the proposed action—in preparing land use plans, but it may use an 

environmental assessment––a more concise analysis developed if the 

environmental effect of the proposed action is unknown in association 

with other actions to determine whether the action is likely to affect the 

environment significantly.12

 

11Revisions to land use plans are necessary if monitoring and evaluation findings, new 

data, new or revised policy, or changes in circumstances indicate that decisions for an 

entire plan or a major portion of a plan no longer serves as a useful guide for resource 

management. BLM, Land Use Planning Handbook H-1601-1, p. 46 (Washington, D.C.: 

2005).

BLM officials said the agency uses the land 

use plans and environmental impact statements to (1) help develop 

“reasonably foreseeable development scenarios” to estimate outcomes, 

such as the number of wells and likely surface disturbance that may occur 

under the land use plan; (2) identify lands open and closed to leasing; (3) 

identify resource protection measures such as lease stipulations and

environmental best management practices; and (4) to establish 

monitoring protocols. Consistent with a completed land use plan and its 

associated environmental impact statement, BLM can offer for lease 

those mineral rights identified in the plan and hence deemed available for 

leasing.

12Pub. L. No. 91-190, 83 Stat. 852 (1970), codified as amended at 42 U.S.C. §§ 4321-

4347 (2013); see § 4332(2)(C)(i).

Overview of the Process 

for Developing Federal Oil 

and Gas Resources
 

Page 9 GAO-13-572 BLM Oil and Gas Development

Operators that have obtained a lease must submit an APD to BLM and 

obtain BLM’s approval before drilling any new oil or gas wells. Beginning 

in fiscal year 2008, Congress authorized BLM to collect a $4,000 

processing fee from operators for each new oil and gas APD. This 

processing fee was increased by Congress to $6,500 per APD in fiscal 

year 2010; any fees collected are used by BLM and offset the agency’s 

general fund appropriation. A complete APD must include, among other 

things, a Surface Use Plan of Operations with the operator’s plan for 

reclaiming disturbed lands during production (known as interim 

reclamation) and upon final abandonment of the well site (known as final 

reclamation). The reclamation plan covers both interim and final 

reclamation, and it outlines the steps the operator proposes to take to 

reclaim the well site. Those steps may include recontouring the 

topography to better match the surrounding landscape, redistributing 

topsoil, and revegetating the site with native plant species.

Once BLM determines the APD is complete, it decides whether to 

approve the APD. BLM may approve the APD as submitted or approve it 

subject to certain COAs. According to BLM officials, COAs are generally 

attached to ensure environmental protection, safety, or conservation of 

mineral resources, and may be based on environmental best 

management practices. These environmental best management practices 

emphasize, among other things, the importance of interim steps to 

reclaim land during oil and gas production and the benefits of reclamation 

activities for mitigating the environmental impacts of oil and gas 

development.13 The COAs can be general in nature or site-specific. 

Typically, a field office develops COAs over a number of years of active 

management of oil and gas development. They can address such topics 

as interim and final reclamation, protection of wildlife habitat or 

archeological and paleontological sites, noise reduction, wildfire 

suppression, or management of invasive species. After BLM approves an 

APD, the operator generally has a 2-year window before the APD expires 

during which the operator can drill the well and begin production, subject 

to any lease stipulations or COAs.14

 

13U.S. Department of the Interior, BLM, Surface Operating Standards and Guidelines for 

Oil and Gas Exploration and Development (Washington, D.C., 2007).

However, upon a written request 

from the operator, BLM may extend the APD for up to 2 years.

14Oil and gas development on federal lands also must comply with applicable state laws.
 

Page 10 GAO-13-572 BLM Oil and Gas Development

When an operator determines, and BLM agrees, that a well has no further 

economic value, the operator must plug the well and complete final 

reclamation by following the original or an amended reclamation plan for 

the well. BLM is then responsible for inspecting the site to ensure 

reclamation actions have taken place and for monitoring the success of 

the reclamation, a process that typically occurs over several years. Once 

BLM determines that reclamation has been completed, it approves a Final 

Abandonment Notice.15 As we reported in February 2011, all operators 

are required to complete reclamation, but they do not always do so.16

As we reported in February 2011, BLM is also concerned with the status 

of idle wells.

In 

these circumstances, BLM may use the bond the operator posted for the 

well to help defray some of the cost of completing reclamation. If the bond 

is not sufficient to cover well plugging and surface reclamation and there 

are no responsible or liable parties, the well is considered “orphaned,”

and BLM uses federal dollars to fund reclamation.

17 Under the Energy Policy Act of 2005, an idle well is defined 

as a well that has been nonoperational for at least 7 years and has no 

anticipated beneficial use. These are previously operating wells that an 

operator has decided not to operate for a period of time. In some 

instances, this may be because the operator is waiting for oil and gas 

prices to rise. In our February 2011 report, we found that idle wells have 

the potential to create environmental, safety, and public health hazards if 

they fall into disrepair, and that they are at greater risk than other wells of 

becoming orphan wells.18 Following our February 2011 report, BLM 

issued revised guidance on its reviews of idle wells in September 2012.19

 

15In circumstances where the surface land is managed by another federal agency, BLM 

generally is to obtain the approval of the surface management agency prior to approving 

the Final Abandonment Notice. Where the surface land is owned by a state or private 

entity, BLM generally may consider the surface owner’s views respecting the 

abandonment plan.

16GAO, Oil and Gas Bonds: BLM Needs a Comprehensive Strategy to Better Manage 

Potential Oil and Gas Well Liability, GAO-11-292 (Washington, D.C.: Feb. 25, 2011).

17GAO-11-292. 

18GAO-11-292. 

19As BLM was just beginning to implement this revised guidance during the course of our 

review, we did not include BLM’s environmental mitigation efforts related to idle wells in 

this report.
 

Page 11 GAO-13-572 BLM Oil and Gas Development

To help ensure operators’ compliance with all stipulations in the lease and 

COAs in the APD, as well as certain laws and regulations, BLM has an 

inspection and enforcement program. BLM’s authority for inspecting wells 

is derived from FOGRMA, which requires the Secretary of the Interior to 

develop guidelines that specify the coverage and frequency of 

inspections. BLM’s AFMSS database tracks data on federal oil and gas 

wells, including data on environmental inspections.

Environmental inspections are BLM’s primary mechanism to ensure 

operators’ compliance with lease stipulations, and COAs related to the 

surface environment, and to initiate enforcement actions if needed. For 

example, BLM may perform environmental inspections to help ensure that 

operators are adhering to COAs designed to mitigate the impact of oil and 

gas development on sensitive species and their habitat. BLM guidance 

does not require environmental inspection of all wells, or specify when a 

well should have an environmental inspection. Instead, BLM guidance 

instructs field offices to conduct environmental inspections annually on all 

wells rated high priority due to environmental concerns. BLM’s inspection 

and enforcement handbook instructs offices to determine high-priority 

environmental inspections based on criteria including whether (1) 

operations on a well or facility are in or adjacent to an area of special 

environmental sensitivity, such as near threatened or endangered species 

habitat; (2) operations occur in an area where noncompliance with lease 

stipulations or COAs could have a significant adverse impact on the 

environment; (3) the operator has a history of noncompliance with 

environmental requirements; (4) 6 months have elapsed since a new well 

was completed or since a well has been abandoned, to ensure that 

earthwork for reclamation has been completed; and (5) an operator has 

submitted a Final Abandonment Notice. Based on these criteria, BLM’s 

33 lead oil and gas offices are to develop annual targets for the number of 

high-priority environmental inspections they plan to conduct for (1) wells 

expected to be drilled, (2) wells already producing oil or gas, and (3) wells 

expected to be plugged and abandoned.

Environmental inspections typically are performed by BLM staff—such as 

natural resource specialists, environmental protection specialists, or other 

resource program specialists—with specific training in environmental 

issues. For the purpose of this report, we will refer to all BLM staff who 

perform environmental inspections as environmental staff. As shown in 

figure 2, environmental inspections can occur during any stage in the life 

cycle of a well.

BLM’s Inspection and 

Enforcement Program
 

Page 12 GAO-13-572 BLM Oil and Gas Development

Figure 2: BLM’s Common Environmental Inspection Activities at Different Stages in the Life Cycle of a Well

a

BLM may also perform other types of inspections during this stage that are not specifically related to 

the surface environment, such as inspections to witness tests of the well’s blowout prevention 

equipment or to examine the cementing or casing of the well.

b

BLM may also perform other types of inspections of a well when it is producing oil or gas, such as 

inspections to verify that the well equipment is working properly and that the production meters are 

accurately measuring and accounting for the full volume of oil and gas being produced by the well.

c

During this stage, BLM staff may also perform inspections to observe and examine the plugging of 

the well hole. BLM does not track these inspections as environmental inspections.

BLM’s inspection and enforcement handbook defines a violation as a 

noncompliance with a specific requirement outlined in federal regulations, 

onshore orders, or COAs, among other things, and a problem as a 

concern or issue identified during an inspection that is not covered by a 

specific regulatory requirement. If BLM staff determine that a violation has 
 

Page 13 GAO-13-572 BLM Oil and Gas Development

occurred, they can issue a formal Incident of Noncompliance (INC) 

violation notice. Depending on the severity of a violation, INCs can result 

in the operator being fined. For example, if BLM discovers that an 

operator has begun construction of a well pad on federal or Indian surface 

without having approval to do so, BLM is authorized to assess the

operator $500 for each day that the violation existed, up to a maximum of 

$5,000. If BLM staff determine that a problem occurred or is occurring, 

they can issue a verbal warning or a written order. The handbook also 

instructs BLM staff to document any enforcement actions in AFMSS.

BLM’s permitting workload has changed from fiscal year 2007 to fiscal 

year 2012 in terms of the (1) number and type of APDs received and (2) 

their location.

Our analysis of BLM data found that BLM received about half as many 

APDs for federal oil and gas resources in fiscal year 2012 (4,303) as in 

fiscal year 2007 (8,573). Nonetheless, the number of APDs received in 

fiscal year 2012 represented about a 4 percent increase over fiscal year 

2010, which was the year during our review that BLM received the fewest 

APDs (4,121). The general decline in APDs since 2007 was most evident 

in the number of APDs BLM received for new natural gas and coalbed 

methane wells, which dropped by approximately 52 percent and 99 

percent, respectively, from fiscal year 2007 to fiscal year 2012. In 

contrast, the number of APDs received for oil wells increased by 

approximately 70 percent, with about 1,300 APDs received in fiscal year 

2007 to about 2,200 APDs received in fiscal year 2012.20

 

20Oil, gas, and coalbed methane APDs, collectively, represent at least 96 percent of all 

APDs that BLM received each fiscal year from 2007 through 2012. In addition, BLM 

received a small number of APDs for monitoring wells, injection wells, and other types of 

wells that are used to support oil and gas operations. Together, these well types 

represented from about 2 to 4 percent of the total number of APDs BLM received each 

year.

Figure 3 shows 

the total number of APDs for federal oil and gas resources received by 

BLM each fiscal year from 2007 through 2012 and breaks down the 

BLM’s Permitting 

Workload Has 

Changed in Number, 

Type, and Location of 

APDs

Natural Gas and Coalbed 

Methane APDs Have 

Decreased from Fiscal 

Year 2007 to Fiscal Year 

2012 and APDs for Oil 

Wells Have Increased
 

Page 14 GAO-13-572 BLM Oil and Gas Development

numbers of APDs received for coalbed methane, natural gas, oil, and 

other types of wells.

Figure 3: Number of Applications for Permit to Drill Received by BLM by Source, 

Fiscal Years 2007-2012

Note: This figure presents data by fiscal year (FY) on applications for permit to drill (APD) for federal 

oil and gas resources and does not include APDs received by BLM for nonfederal oil and gas 

resources on Indian Trust lands. According to BLM officials, APDs for nonfederal oil and gas 

resources on Indian Trust lands are a sizeable portion of some BLM offices’ permitting workload.

a

Other includes, among other things, injection wells, which can be used to support oil and gas

operations by injecting water or other fluids into oil- or gas-producing formations to increase the 

pressure in the formation and force additional oil or gas out of nearby producing wells.

BLM officials and oil and gas industry representatives we interviewed 

identified a variety of factors that can influence an operator’s decision to 

develop oil and gas resources and that may provide context to the 

changes in BLM’s permitting workload since fiscal year 2007. These 

factors include the following:
 

Page 15 GAO-13-572 BLM Oil and Gas Development

• The price of oil and natural gas. Officials from the 11 BLM field offices 

we contacted said they consider the price of oil and natural gas to be 

a factor contributing to changes in their offices’ permitting workload. 

For example, officials in 6 offices we contacted said that lower prices 

for natural gas have contributed to the decline in the number of 

natural gas and coalbed methane APDs their offices have received in 

recent years. In addition, officials from 5 offices located in areas 

where oil is being developed said that higher prices for oil have 

contributed to an increase in the number of oil APDs their offices have 

received. This is consistent with what we found in July 2010, when we 

reported on the relationship between fluctuations in oil and gas prices 

and development activities and found that changes in the prices of oil 

and gas closely paralleled changes in development activities from 

1990 through 2009.21

• Increased development of shale oil and shale gas. BLM officials and 

industry representatives cited the growth in development of oil and 

natural gas from shale formations (shale oil and shale gas) as a 

significant change in the oil and gas sector that has influenced where 

oil and gas resources are developed. This growth was made possible 

in part due to technological advancements in combining horizontal 

drilling techniques and hydraulic fracturing. According to BLM officials 

and industry representatives, the increase in the development of shale 

oil and shale gas has largely occurred on state and private lands. This 

is consistent with our finding from September 2012, when we reported 

that the location of shale formations appears to be predominately on 

nonfederal lands, according to an official from the Energy Information 

Administration.

Specifically, we reported that the peaks and 

troughs in prices and development activities, measured by the number 

of oil and gas wells drilled, largely overlapped, strongly suggesting 

that development activities reacted quickly and proportionally to 

changes in the prices of oil and gas.

22

 

21GAO, Onshore Oil and Gas: BLM’s Management of Public Protests to Its Lease Sales 

Needs Improvement, 

Also, an oil and gas industry representative we 

interviewed said the economics have become more attractive for 

developing oil and gas from shale formations than from other onshore 

sources. For example, the industry representative said that shale gas 

wells have, in general, become more profitable than coalbed methane 

wells in recent years. This is due in part to the fact that shale gas 

GAO-10-670 (Washington, D.C.: July 30, 2010).

22GAO-12-732. 
 

Page 16 GAO-13-572 BLM Oil and Gas Development

wells often produce more natural gas than coalbed methane wells and 

also because coalbed methane wells generally involve additional 

costs associated with the disposal of large quantities of water they 

produce.

• Differences between federal and state permitting processes. Oil and 

gas industry representatives said there is a perception in the industry 

that the permitting process and regulatory environment associated 

with developing federal oil and gas resources is more complex and 

time-consuming than for oil and gas resources located on state or 

private lands. According to these representatives, delays in obtaining 

permits are costly for operators and may prompt operators to seek to 

develop oil and gas on state and private lands rather than on federal 

lands. BLM officials said that BLM must consider multiple uses of the 

land and that the environmental standards and legal requirements 

they must follow when managing oil and gas development may differ 

from the requirements for state or private lands.

Permitting activity since 2007 has varied among BLM offices, as shown in 

table 1. For instance, 23 of BLM’s 33 lead oil and gas offices received 

fewer APDs for federal oil and gas resources in fiscal year 2012 than in 

fiscal year 2007; 9 offices received more APDs; and 1 office did not 

experience any change in APDs received.

Table 1: Change in the Number of Applications for Permit to Drill Received by BLM 

Offices from Fiscal Years 2007 to 2012

Office name (state)

Number of 

APDs received 

(FY 07)

Number of 

APDs received 

(FY 12)

Change in number 

of APDs received 

(FY 07 to FY 12 )

Buffalo FO (WY) 2,673 127 -2,546

Farmington FO (NM) 825 96 -729

Pinedale FO (WY) 814 326 -488

Rawlins FO (WY) 372 126 -246

Colorado River Valley FO 

(CO) 383 182 -201

Great Falls Oil and Gas FO 

(MT) 103 1 -102

White River FO (CO) 199 106 -93

Miles City FO (MT) 122 43 -79

Rock Springs FO (WY) 149 73 -76

Kemmerer FO (WY) 87 16 -71

APD Activity Has Varied by 

Location 
 

Page 17 GAO-13-572 BLM Oil and Gas Development

Office name (state)

Number of 

APDs received 

(FY 07)

Number of 

APDs received 

(FY 12)

Change in number 

of APDs received 

(FY 07 to FY 12 )

Southeastern States FO (MS) 93 24 -69

Roswell FO (NM) 68 7 -61

Lander FO (WY) 81 24 -57

Worland FO (WY) 78 22 -56

Royal Gorge FO (CO) 81 30 -51

Moab FO (UT) 56 13 -43

Tres Rios FO (CO) 41 10 -31

Little Snake FO (CO) 50 21 -29

Northeastern States FO (WI) 16 1 -15

Salt Lake FO (UT) 9 0 -9 

Nevada State Office (NV) 17 10 -7 

Rio Puerco FO (NM) 9 5 -4 

Alaska State Office (AK) 4 2 -2 

Newcastle FO (WY) 52 52 0 

Grand Junction FO (CO) 48 49 1 

Bakersfield FO (CA) 279 287 8 

Price FO (UT) 77 92 15

Oklahoma FO (OK) 48 79 31

Casper FO (WY) 90 158 68

Vernal FO (UT) 946 1072 126

Hobbs Field Station (NM) 145 283 138

North Dakota FO (ND) 84 287 203

Carlsbad FO (NM) 474 679 205

Total 8,573 4,303 -4,270

Legend: FY = fiscal year; FO = Field Office.

Source: GAO analysis of BLM data.

Note: The names of offices participating in the Federal Permit Streamlining Pilot Project, which was 

established in section 365 of the Energy Policy Act of 2005 to improve oil and gas permitting, are 

presented in bold. This table presents data on applications for permit to drill (APD) for federal oil and 

gas resources and does not include APDs received by BLM for nonfederal oil and gas resources on 

Indian Trust lands. According to BLM officials, APDs for nonfederal oil and gas resources on Indian 

Trust lands are a sizeable portion of some BLM offices’ permitting workload.

Variations in the level of permitting activity in different locations from fiscal 

year 2007 to fiscal year 2012 reflect the general shift in the types of APDs 

submitted to BLM that occurred over the same time period. For example, 

in fiscal year 2007, the Buffalo Field Office in Wyoming received more 

APDs than any other office, and nearly 98 percent of the APDs received 

were for coalbed methane wells. However, as the number of APDs for 
 

Page 18 GAO-13-572 BLM Oil and Gas Development

coalbed methane has declined in recent years, the Buffalo Field Office 

has experienced a significant drop in the number of new APDs it 

received, declining from 2,673 APDs in fiscal year 2007 down to 127 

APDs in fiscal year 2012. As a result of this decline, the Buffalo Field 

Office transitioned from receiving more than 30 percent of all APDs for 

federal oil and gas resources in fiscal year 2007 to receiving about 3 

percent of all APDs by fiscal year 2012.23

In contrast, BLM’s North Dakota Field Office experienced more than a 

240 percent increase in the number of APDs it received, from 84 in fiscal 

year 2007 to 287 in fiscal year 2012, and all of the APDs were for oil 

wells.24 The North Dakota Field Office, which was the seventeenth most 

active BLM office for APDs received in fiscal year 2007, ranked as the 

fourth most active BLM office in fiscal year 2012.25 In response to the 

increase in APDs at the North Dakota Field Office, BLM officials said the 

agency created two special response strike teams in 2012 that consisted 

of 10 to 12 oil and gas staff from field offices across BLM. These teams 

helped process pending APDs for about 3 weeks and, according to BLM 

officials, the strike teams assisted in approving more than 200 APDs for 

federal and Indian Trust wells. BLM officials also said that they may 

consider using the strike team concept again under certain 

circumstances, such as when a field office experiences a large increase 

in APDs.

 

23The Buffalo Field Office is responsible for managing the second largest number of 

federal oil and gas wells of all BLM offices (see fig. 1 in the Background of this report). In 

fiscal year 2012, this office accounted for 10 of the 19 (about 53 percent) coalbed 

methane APDs received by BLM.

24These numbers represent APDs for federal oil and gas resources that the North Dakota 

Field Office received. According to BLM officials, Indian Trust APDs represent a significant 

part of the North Dakota Field Office’s overall permitting workload, but those APDs were 

not included in our analysis.

25The North Dakota Field Office was tied with the Bakersfield Field Office for the fourth 

most active BLM office in terms of APDs for federal oil and gas resources received in 

fiscal year 2012.
 

Page 19 GAO-13-572 BLM Oil and Gas Development

BLM has taken actions to improve its management of its oil and gas 

permitting workload since we last reported on this issue in 2005, including 

revising its permitting rule in 2007, developing plans for a new APD 

processing system, and implementing a pilot project that increased 

funding and staff for APD processing. Even with the actions taken to 

address its permitting workload, BLM continues to face challenges with 

APD processing.

Since we reported on BLM’s oil and gas permitting workload in 2005, 

BLM has implemented a number of actions to manage its changing 

permitting workload and implement provisions of the Energy Policy Act of 

2005. These actions include (1) revising its oil and gas permitting rule, (2) 

developing plans for a new APD processing system, and (3) 

implementing a pilot project in some field offices to streamline APD 

processing. The impact of some of these actions on BLM’s performance 

and effectiveness is not yet known because BLM has not completed fully 

implemented or fully evaluated the actions.

In March 2007, BLM issued its revised rule for oil and gas permitting, 

known as Onshore Oil and Gas Order Number 1 (the order), which 

specifies the requirements necessary for the approval of proposed oil and 

gas wells on areas covered by federal onshore oil and gas leases.26

 

2672 Fed. Reg. 10,308 (March 7, 2007).

The 

order incorporated changes in law, policy, procedures, and requirements 

that had been implemented since the previous rule for oil and gas 

permitting was published in 1983. These changes include the Federal 

Onshore Oil and Gas Leasing Reform Act of 1987 and the Energy Policy 

Act of 2005. The order includes several changes that could affect BLM’s 

permitting workload, the content of the APDs submitted by operators, and 

the procedures BLM uses to process those APDs. Among other things, 

the order:

BLM Has Taken 

Actions to Better 

Manage Its Oil and 

Gas Permitting 

Workload, but 

Challenges Remain

BLM Revised Its 

Permitting Rule, 

Developed Plans for a New 

APD Processing System, 

and Implemented a Pilot 

Permitting Project

Revisions to BLM’s Permitting 

Rule
 

Page 20 GAO-13-572 BLM Oil and Gas Development

• Clarified what operators must include in an APD for it to be 

considered complete.27 Key components include (1) a completed 

application form, (2) a well plat depicting the proposed location and 

boundaries of the proposed development, (3) a Drilling Plan 

containing technical information such as the operator’s minimum 

specifications for blowout prevention equipment, (4) a Surface Use 

Plan of Operations, (5) evidence of bond coverage,28

• Incorporated the required deadlines for APD processing established 

by the Energy Policy Act of 2005 which, among other things, requires 

BLM to (1) notify the operator within 10 days of receiving an APD as 

to whether or not the APD is complete and (2) approve or defer the

APD within 30 days after the operator has submitted a complete

APD.

and (6) operator 

certification that the information it has provided in the APD is correct 

and that the operator will develop the proposed site in conformity with 

the terms and conditions of the APD.

29

• Established a new approval process for Master Development Plans, 

which allows operators to submit multiple APDs together for wells that 

share a common Drilling Plan and Surface Use Plan of Operations. 

According to BLM officials, a Master Development Plan increases 

processing efficiency and enables BLM to consider the cumulative 

effects of development early in the process of developing an oil and 

gas field to minimize adverse environmental impacts.

• Encouraged operators to voluntarily use environmental best 

management practices when developing their APDs and stated that 

BLM may incorporate these practices as required COAs based on the 

 

27Before an APD is considered complete, BLM must also perform an on-site inspection of 

the proposed well site to help determine if the materials submitted in the APD package are 

accurate and whether any COAs are necessary. The operator must correct any 

deficiencies identified during this on-site inspection. The on-site inspections that occur 

during the permitting phase are not included in our analysis of BLM’s environmental 

inspection activities.

28These bonds are intended to ensure that operators perform the required reclamation, as 

well as the lease’s other terms and conditions, such as the payment of federal royalties. 

29The order also provides that, under certain conditions, BLM may deny an APD within 30 

days.
 

Page 21 GAO-13-572 BLM Oil and Gas Development

results of the NEPA analysis or other analyses performed during the 

APD review process.30

In 2012, BLM announced plans to implement a new automated APD 

processing and tracking system in 2013. According to information

provided by BLM, this new system is intended to help BLM process APDs 

faster and more efficiently and improve the quality of data on APDs 

tracked by the agency. Specifically, the new system is expected to 

improve APD processing and data quality by:

• Promoting the use of online submissions of APDs and automatically 

preventing the submission of an APD if any required fields are 

incomplete. Currently, operators can submit APDs to BLM in hard 

copy format or electronically. According to information provided by 

BLM, operators will be able to input APD data directly into BLM’s new 

system and will be automatically alerted if any information is missing.

• Improving BLM’s workflow by automatically generating the letters BLM 

sends to operators about their APDs and the results of BLM’s review 

process, thus reducing the time it takes staff to prepare these letters. 

Also, according to BLM officials, the new system will improve the 

routing of different parts of the APD package to various BLM 

specialists (e.g., petroleum engineers or geologists) for their review.

• Allowing operators to electronically track the progress of their 

submitted APDs and identify delays so that they can proactively 

resolve issues with BLM. Under current practice, operators must 

either wait for BLM to contact them about problems with APDs or 

contact staff in BLM offices to identify any deficiencies that need 

resolution.

• Allowing BLM to better track and evaluate its progress in processing 

APDs and to identify common sources of delays. According to BLM 

officials, the new system will support more advanced analyses of 

BLM’s processing performance and improve the quality of BLM’s data 

by, for example, automatically recording some dates associated with 

the processing of APDs.

 

30As we reported in June 2005, BLM established its agency policy on the use of 

environmental best management practices in 2004, but officials from some field offices 

said they had already been using these practices prior to the issuance of the agency 

policy. See GAO-05-418. 

Development and Planned 

Implementation of a New APD 

Processing and Tracking 

System 
 

Page 22 GAO-13-572 BLM Oil and Gas Development

According to BLM officials, a similar APD processing and tracking system 

used by the Carlsbad Field Office since 2007 has helped reduce the time 

it takes to process APDs in that office. BLM officials said they expect to 

implement the new APD processing and tracking system agency-wide 

within calendar year 2013. According to BLM officials, the new APD 

processing and tracking system is one step in a broader effort to upgrade 

its oil and gas IT systems and replace AFMSS in the future.

As prescribed by section 365 of the Energy Policy Act of 2005, BLM 

implemented the Federal Permit Streamlining Pilot Project. According to a 

Memorandum of Understanding signed by the Departments of 

Agriculture, the Army, and the Interior, as well as the Environmental 

Protection Agency, the project was aimed at improving the processing of 

APDs and coordination among BLM and other federal and state agencies 

on oil and gas permitting issues. The Energy Policy Act of 2005 required 

the Secretary of the Interior to increase staff in seven BLM field offices as 

necessary to ensure the effective implementation of the Pilot Project and 

other programs administered by the field offices, such as their oil and gas 

inspection and enforcement programs. The seven pilot offices are 

Rawlins and Buffalo, Wyoming; Miles City, Montana; Farmington and 

Carlsbad, New Mexico; Grand Junction/Glenwood Springs, Colorado 

(now called the Colorado River Valley Field Office); and Vernal, Utah.

To help implement the Pilot Project, the Energy Policy Act of 2005 

established a Permit Processing Improvement Fund to provide funds that 

BLM can use or transfer to other agencies, such as Interior’s Fish and 

Wildlife Service. With some of these funds, BLM hired additional staff to 

assist with APD processing and inspection and enforcement efforts in the 

seven pilot offices. According to a 2008 report assessing the Pilot Project 

that was prepared for BLM, the agency had hired more than 140 new staff 

members for the seven pilot offices by the end of fiscal year 2007.31

 

31Booz Allen Hamilton, Section 365 of the Energy Policy Act of 2005: Year Two Report for 

the Pilot Project to Improve Federal Permit Coordination, a report prepared for the 

Department of the Interior’s Bureau of Land Management (Washington, D.C.: February 

2008).

This 

report assessed the overall impact and results of the Pilot Project in its 

first 2 years of implementation—fiscal years 2006 and 2007—and 

analyzed a variety of performance measures established by BLM for the 

project, including APD workloads and the average number of days it took 

the pilot offices to process APDs from date of receipt to date of approval. 

BLM Implemented a Pilot 

Project to Streamline Permit 

Processing
 

Page 23 GAO-13-572 BLM Oil and Gas Development

According to the report, the total number of APDs processed by the seven 

pilot offices increased by more than 10 percent from fiscal year 2005 (the 

year before the Pilot Project began) to fiscal year 2007, but the average 

number of days it took to process the APDs from date of receipt to date of 

approval increased by more than 40 percent during the same period.

The Energy Policy Act of 2005 required Interior to issue a report to 

Congress by August 2008 that outlined the results of the Pilot Project to 

date and also make a recommendation to the President on whether the 

Pilot Project should be implemented throughout the United States, such 

as by expanding to all field offices. BLM, however, has not met this 

requirement. The 2008 assessment covered fiscal years 2006 and 2007, 

but it did not contain a recommendation on the future of the Pilot Project. 

Instead, the report stated that BLM would issue a separate report that 

would outline the results of the project and make a recommendation on 

whether it should be implemented in BLM’s nonpilot offices as well. BLM 

officials prepared a draft report dated August 2009 but, as of April 2013, 

BLM officials said there was no date set for its completion. As of June 

2013, this report had not been finalized or released. The 2009 draft report 

contained an analysis of the results of the Pilot Project through fiscal year 

2008 and also included recommendations.32

Since BLM has not completed an assessment of the Pilot Project since 

2008, it is unclear whether the project has met its goals or whether 

changes would improve its performance and effectiveness. Nevertheless, 

in its fiscal year 2014 budget request, BLM proposed changes to the Pilot 

Project and the Permit Processing Improvement Fund portion of the Pilot 

Project. Specifically, BLM is seeking flexibility to change which of its 

offices are pilot offices as needed based on changing permitting 

demands. BLM has also proposed that Congress eliminate the Permit 

Processing Improvement Fund and the annual APD fees beginning in 

2015 and replace them by authorizing BLM to establish cost recovery 

According to a BLM official, 

the report was not finalized or cleared by Interior or the Office of 

Management and Budget and therefore was not submitted to Congress. 

We asked BLM for supporting documentation of why the report was not 

finalized or submitted to Congress, but BLM did not provide any additional 

information.

 

32In a letter transmitting the draft report to us, BLM indicated the report contains outdated 

information, including obsolete budgetary and legislative information, and does not 

represent departmental policy.
 

Page 24 GAO-13-572 BLM Oil and Gas Development

fees for APDs that would finance BLM’s labor and other expenses in 

processing the APDs. As of May 2013, Congress had not acted on these 

proposals. We asked for more details about how the proposed changes in 

funding would affect BLM’s ability to carry out its operations under the 

Pilot Project, but BLM did not provide additional information, such as the 

amount of funds anticipated to be generated by the proposed change 

compared with the funds BLM is currently receiving. Instead, BLM officials 

said that the amount of funding BLM would receive through the APD cost 

recovery fees would vary based on the number of APDs submitted in a 

given year and thus may be subject to peaks and valleys based on 

fluctuations in permitting levels. It is uncertain what impact these or other 

changes would have on the Pilot Project and BLM’s ability to process 

APDs.

In a 2013 internal memorandum, BLM reported that it had not been able 

to meet the 30-day deadline required by the Energy Policy Act of 2005 to 

process (either approve or defer) completed APDs, and that it has 

struggled to consistently track the amount of time it takes to process 

APDs due to data gaps in AFMSS. Specifically, BLM reported that the 

APD data in AFMSS were incomplete and missing critical processing 

dates, making it difficult to reliably track and make adjustments to any 

steps in the APD review process to improve its operations.

Similarly, our analysis of BLM’s APD data from fiscal years 2007 to 2012 

identified challenges with the completeness and accuracy of the data on 

APDs’ completion dates. We found that the data in AFMSS were missing 

completion dates for some APDs and contained potential inaccurate 

entries for the completion dates for other APDs. An APD’s completion 

date is important because it is needed to determine whether BLM 

complied with the required 30-day deadline to approve or defer completed 

APDs, and because it helps BLM track how much time is spent in the two 

periods of the APD review process—Period 1, which is the time from 

initial submission of an APD until the time BLM determines an APD is 

complete, and Period 2, which is the time from when an APD is 

designated as complete until the time BLM makes a decision to approve, 

or in limited instances deny, the completed APD. Without accurate data 

on the amount of time spent in each period, it is difficult to determine 

whether any actions could be taken to improve the efficiency of the APD 

review process. Figure 4 depicts the steps that occur in each period of the 

review process, as well as key dates and requirements, including the 

requirement for BLM to approve or defer completed APDs within 30 days.

BLM Faces Challenges 

Meeting and Assessing Its 

Compliance with the 

Required Processing 

Deadline for Completed 

APDs and Does Not 

Consistently Track Key 

APD Data
 

Page 25 GAO-13-572 BLM Oil and Gas Development

Figure 4: Overview of Selected Key Dates, Steps, and Requirements in BLM’s Review Process for Applications for Permit to 

Drill

Note: This figure focuses on the review process for APDs that are approved by BLM, but in limited 

instances BLM may also deny APDs if its review finds there are no actions the operator could take 

that would enable BLM to issue the permit. The steps described in this figure apply to APDs for all 

well types, including oil, natural gas, and coalbed methane wells.

We reviewed BLM’s data on nearly 27,400 APDs approved from fiscal 

year 2007 to fiscal year 2012 and found that approximately 5,160 (about 

19 percent) of the APDs did not have a completion date entered in 

AFMSS.33

 

33The nearly 27,400 approved APDs for which we reviewed data represented 

approximately 89 percent of all APDs for federal oil and gas resources that BLM has 

reported it approved from fiscal years 2007 to 2012. We were unable to obtain sufficient 

data on the remaining 11 percent of APDs that BLM has reported it approved during this 

time period to include them in our analysis.

Furthermore, even when the APD data we reviewed included a 
 

Page 26 GAO-13-572 BLM Oil and Gas Development

completion date, we identified differences among BLM offices in how the 

data were entered; this suggests that inaccurate completion dates may 

have been recorded for some APDs. In particular, the data on more than 

5,560 of the nearly 27,400 approved APDs (about 20 percent) we 

reviewed listed the same date for when the APD was completed as for its 

approval. In other words, the data for these APDs indicate that it took 

BLM zero additional days to process the APDs once the agency 

determined the APDs were complete, thus suggesting the entire 

processing of these APDs occurred in Period 1. BLM officials said there 

are some limited instances in which an office could approve an APD on 

the same day that it was determined to be complete. However, they said 

many of the cases we identified were more likely the result of staff from 

some offices following different practices for entering APD completion 

dates into AFMSS and misinterpreting BLM’s guidance on this matter. 

Consequently, we cannot confirm the accuracy of the completion dates 

listed in AFMSS for these APDs.34 Also, because of these different 

practices in entering APD completion dates into AFMSS, we have 

concerns about the accuracy and reliability of the completion dates listed 

for the remaining 61 percent of the APDs for which we reviewed data.35

On April 15, 2013, BLM issued new guidance on APD processing and 

data entry that states, among other things, that BLM staff are required to 

enter the APD completion date into AFMSS and clarifies how BLM staff 

should determine this date. BLM officials said they expect the new 

guidance to help improve the reliability of BLM’s APD data.

As a result of these problems with the data on APD completion dates, we 

were unable to assess the extent to which BLM has complied with the 

required 30-day deadline for approving or deferring completed APDs 

established in the Energy Policy Act of 2005.

We also analyzed BLM data on approved APDs to assess the average 

number of days it took BLM to process APDs from date of receipt to date 

 

34Our concern about the reliability of the data on these 5,160 APDs is focused on their 

listed completion date in AFMSS and does not extend to their received and approved 

dates listed in the database. Consequently, we included these APDs in our analysis of 

data on the average number of days it took BLM to process APDs from date of receipt to 

date of approval discussed below.

35As a result of the concerns about the reliability of the listed completion dates for these 

APDs, we were unable to quantify how much of the processing time for these APDs was 

spent in each of the two review periods.
 

Page 27 GAO-13-572 BLM Oil and Gas Development

of approval, and the extent to which this may have changed from fiscal 

year 2007 to fiscal year 2012. We found that the number of days from 

date of receipt to date of approval averaged 229 days in fiscal year 2012. 

However, due to the incompleteness of data in AFMSS, we were unable 

to determine how this average changed from fiscal year 2007 to fiscal 

year 2012. Without information on how the average number of days has 

changed, it is difficult to determine whether actions could be taken to 

improve BLM’s APD review process. Specifically, we were unable to 

obtain data on the approval date for APDs that BLM reported were 

approved during fiscal years 2007 to 2012 but later had expired or were 

rescinded, cancelled, or withdrawn without a well having been drilled. 

Once an APD has expired or been rescinded, cancelled, or withdrawn, 

AFMSS stops retaining data on the approval date for that APD. Since 

approved APDs can potentially remain valid for up to 4 years, APDs 

approved in the earlier years of the period we analyzed were more likely 

to have expired and be missing an approval date than APDs that were 

approved more recently. For example, the data we obtained from AFMSS 

did not include the approval dates for about 23 percent of the APDs that 

BLM reported were approved in fiscal year 2007. In contrast, less than 1 

percent of the APDs that BLM reported were approved in fiscal year 2012 

were missing approval dates.36

BLM officials and industry representatives we interviewed identified a 

variety of factors that may contribute to the amount of time it takes BLM to 

Further, BLM officials confirmed that they 

also cannot accurately determine how the average number of days to 

process APDs from date of receipt to date of approval has changed over 

time for individual offices due to the problem of approval dates not being 

retained in AFMSS for APDs that have expired or have been rescinded, 

cancelled, or withdrawn. According to BLM officials, BLM intends to 

address this problem with data retention as it replaces AFMSS in the 

future. BLM officials did not estimate when changes to improve the 

tracking of APD approval dates would occur, but they did not expect this 

change to be part of the new APD processing and tracking system that is 

expected to be implemented within calendar year 2013. 

 

36The data we obtained from BLM on APDs approved in fiscal years 2009 to 2011 were 

more complete than the data from fiscal years 2007 and 2008 but were less complete in 

some years than the data from fiscal year 2012. As a result of the variation in the 

completeness of the data on APDs approved from fiscal years 2007 to 2012 and 

uncertainty about the impact of the missing data, we limited our reporting of the average 

number of days to process an APD from date of receipt to date of approval to fiscal year 

2012.
 

Page 28 GAO-13-572 BLM Oil and Gas Development

process an APD from its date of receipt to its date of approval. For 

example, BLM officials we spoke with identified several factors, including:

• The level of complexity of the APDs being submitted by operators. In 

its 2014 budget justification report, BLM reported that the time it takes 

to process APDs has increased or remained high due to the increased 

complexity of issues analyzed in environmental documents associated 

with new APDs.37

• The use of Master Development Plans. BLM officials said that Master 

Development Plans—in which operators submit multiple APDs 

together that share a common Drilling Plan and Surface Use Plan of 

Operations—are beneficial for the environment because they allow 

BLM to assess the cumulative environmental impacts of proposed 

development on a project-level scale rather than on a well-by-well 

basis. However, officials said it generally takes BLM more time to 

process these plans given their larger scope. According to BLM 

officials, AFMSS does not currently track whether an APD was 

approved as part of a Master Development Plan, but this information 

will be tracked under the new APD processing and tracking system 

once it has been implemented.

According to BLM officials, some of the new areas 

being developed may have unique challenges that are encountered 

during the permitting phase, such as operators seeking to drill in new 

locations that involve more challenging terrain or habitat for sensitive 

species, which can increase the complexity of the APDs.

• Operators submitting incomplete APDs and taking longer to correct 

deficiencies. In its 2014 budget justification report, BLM reported that 

due to turnover in operators’ permitting staff, the agency often 

receives inconsistent and incomplete APDs. BLM reported this has 

contributed to longer times to process APDs. According to BLM 

officials, since an operator’s new employees may not be familiar with 

the APD process and BLM’s requirements, they may be more likely to 

submit incomplete APDs and take longer to correct deficiencies.

• The use of categorical exclusions. BLM officials also said it is possible 

that changes in how frequently categorical exclusions are used to 

approve oil and gas APDs could influence the amount of time it takes 

 

37Department of the Interior, Budget Justifications and Performance Information Fiscal 

Year 2014: Bureau of Land Management (Washington, D.C.: 2013).
 

Page 29 GAO-13-572 BLM Oil and Gas Development

BLM to process APDs.38

Industry representatives we interviewed also cited the level of complexity 

of an APD as one factor that contributes to the amount of time it takes 

BLM to process an APD from date of receipt to date of approval. 

However, industry representatives cited other factors specific to BLM that 

could affect the time it takes to process APDs. For example, industry 

representatives stated that, in their experience, the amount of time it 

takes BLM to process APDs is noticeably longer in some offices than in 

others. They attributed the differences to inadequate BLM staffing in 

some offices with large APD workloads, inconsistent standards for 

processing APDs, and their opinion that some BLM offices place less 

urgency on processing APDs than other offices do. Industry 

representatives we spoke with also said that the amount of time it takes 

BLM to process APDs may make the development of federal oil and gas 

resources less attractive to oil and gas operators in some situations.

The Energy Policy Act of 2005 established 

several categorical exclusions under which, if conditions are met, BLM 

need not prepare any new environmental impact analysis, such as an 

environmental assessment or environmental impact statement, which 

would ordinarily be required for oil and gas projects. However, since, 

according to BLM officials, the agency has not maintained data on the 

use of categorical exclusions in recent years, it is unclear to what 

extent this issue has impacted the amount of time it took BLM to 

process APDs since 2007.

 

38Under certain circumstances established in section 390 of the Energy Policy Act of 

2005, BLM can approve an APD relying on a categorical exclusion rather than preparing 

the environmental impact statement or environmental assessment that is normally 

required under NEPA for an APD. See GAO, Energy Policy Act of 2005: BLM’s Use of 

Section 390 Categorical Exclusions for Oil and Gas Development, GAO-11-941T 

(Washington, D.C.: Sept. 9, 2011).
 

Page 30 GAO-13-572 BLM Oil and Gas Development

To mitigate the environmental impact of oil and gas development, BLM 

has increased the number of environmental inspections completed on 

federal oil and gas wells and facilities from fiscal year 2007 to fiscal year 

2012. Nevertheless, BLM continues to face challenges in mitigating the 

environmental impact of oil and gas development due to insufficient 

information and inconsistent documentation of its inspection and 

enforcement actions and staffing challenges.

BLM increased the number of environmental inspections it performed on 

federal oil and gas wells and facilities by approximately 63 percent, from 

10,941 in fiscal year 2007 to 17,866 in fiscal year 2012. The number of 

environmental inspections performed in fiscal year 2012 was about 1 

percent lower than the peak reached in fiscal year 2011, when BLM 

performed 18,110 environmental inspections.39

Table 2: Change in the Number of Environmental Inspections Performed by BLM 

Offices from Fiscal Years 2007 to 2012

Table 2 shows the change 

in environmental inspections from fiscal year 2007 to fiscal year 2012 

among BLM offices.

Office name (state)

Number of 

environmental 

inspections 

(FY 07)

Number of 

environmental 

inspections 

(FY 12)

Change in number of 

environmental 

inspections

(FY 07 to FY 12)

Pinedale FO (WY) 604 2,320 1,716

Buffalo FO (WY) 1,826 3,461 1,635

Vernal FO (UT) 318 1,752 1,434

Colorado River Valley 

FO (CO) 376 1,417 1,041

Farmington FO (NM) 386 965 579

Carlsbad FO (NM) 1,104 1,590 486

White River FO (CO) 48 402 354

 

39Prior to the slight decline in fiscal year 2012, BLM had increased the number of 

environmental inspections it performed on federal oil and gas wells and facilities every 

year from fiscal year 2007 to fiscal year 2011.

BLM Has Taken 

Actions to Better 

Mitigate the 

Environmental Impact 

of Oil and Gas 

Development, but 

Challenges Remain

BLM Has Increased the 

Number of Environmental 

Inspections to Better 

Mitigate the 

Environmental Impact of 

Oil and Gas Development
 

Page 31 GAO-13-572 BLM Oil and Gas Development

Office name (state)

Number of 

environmental 

inspections 

(FY 07)

Number of 

environmental 

inspections 

(FY 12)

Change in number of 

environmental 

inspections

(FY 07 to FY 12)

Kemmerer FO (WY) 36 376 340

Great Falls Oil and Gas 

FO (MT) 108 438 330

Bakersfield FO (CA) 232 503 271

Newcastle FO (WY) 3 211 208

Oklahoma FO (OK) 47 187 140

Alaska State Office 

(AK) 12 116 104

Lander FO (WY) 4 104 100

Tres Rios FO (CO) 57 151 94

Northeastern States 

FO (WI) 162 250 88

Moab FO (UT) 26 99 73

Salt Lake FO (UT) 0 27 27

Casper FO (WY) 107 120 13

Price FO (UT) 98 102 4 

Rawlins FO (WY) 514 491 -23

Royal Gorge FO (CO) 55 24 -31

Miles City FO (MT) 361 329 -32

Rio Puerco FO (NM) 52 19 -33

Hobbs Field Station 

(NM) 867 833 -34

North Dakota FO (ND) 239 192 -47

Nevada State Office 

(NV) 87 15 -72

Southeastern States 

FO (MS) 247 142 -105

Little Snake FO (CO) 247 92 -155

Grand Junction FO 

(CO) 361 175 -186

Rock Springs FO (WY) 779 392 -387

Roswell FO (NM) 664 171 -493

Worland FO (WY) 914 400 -514

Total 10,941 17,866 6,925

Legend: FY = fiscal year; FO = Field Office.

Source: GAO analysis of BLM data.

Note: This table presents data on environmental inspection performed on federal oil and gas wells 

and facilities and does not include information on environmental inspections performed by BLM on 
 

Page 32 GAO-13-572 BLM Oil and Gas Development

nonfederal oil and gas wells or facilities located on Indian Trust lands. In addition, the table excludes 

results from more than 580 environmental inspections recorded in BLM’s Automated Fluid Minerals 

Support System database in fiscal year 2012 and more than 160 environmental inspections recorded 

in fiscal year 2007 due to concerns about the accuracy of the data. The names of offices participating 

in the Federal Permit Streamlining Pilot Project, which was established in section 365 of the Energy 

Policy Act of 2005 to improve oil and gas permitting, are in bold.

BLM offices with the greatest increases in environmental inspections from 

fiscal year 2007 to fiscal year 2012 were generally those responsible for 

managing the most federal oil and gas wells. The three offices with the 

greatest increase in environmental inspections from fiscal year 2007 to 

fiscal year 2012 were the Pinedale and Buffalo Field Offices in Wyoming, 

and the Vernal Field Office, in Utah. As of December 2012, these three 

offices also managed nearly 27 percent of all federal oil and gas wells. 

Similarly, BLM’s Farmington Field Office, in New Mexico, managed the 

largest number of federal wells as of December 2012 and increased the 

environmental inspections it performed, from 386 in fiscal year 2007 to 

965 in fiscal year 2012.

BLM management officials at three field offices said that having fewer 

APDs to process has allowed their environmental staff, who also help 

process APDs, to spend more time on enforcement activities, including 

environmental inspections. For example, the number of APDs received by 

the Pinedale Field Office dropped from 814 in fiscal year 2007 to 326 in 

fiscal year 2012, and the number of environmental inspections it 

performed increased from 604 to 2,320 during that period. In contrast, 

some offices that experienced an increase in APDs during the period 

conducted fewer environmental inspections. For example, the North 

Dakota Field Office, which experienced a 240 percent increase in the 

number of APDs received from fiscal years 2007 to 2012, going from 84 

APDs in fiscal year 2007 to 287 APDs in fiscal year 2012, performed 

nearly 20 percent fewer environmental inspections during the same 

period, going from 239 environmental inspections in fiscal year 2007 to 

192 in fiscal year 2012.

BLM officials attributed the overall increase in environmental inspections 

to the following actions:

• BLM revised its guidance for documenting environmental inspection 

activities, particularly interim reclamation inspections. In 2005, we 

recommended that BLM track interim reclamation inspections in its 
 

Page 33 GAO-13-572 BLM Oil and Gas Development

centralized database.40

• BLM increased the focus on environmental inspections by 

establishing targets for managers and staff and including those 

targets in annual staff performance plans and expectations. For 

example, metrics are included in the annual performance plans for 

certain BLM state directors who oversee offices involved in oil and 

gas development. These metrics generally specify that the state 

directors should ensure that their offices conduct all high-priority 

environmental inspections identified during the inspection prioritization 

process. Also, BLM field office management staff said that their 

annual performance plans include meeting their office’s high-priority 

environmental inspections targets. In addition, environmental staff 

said that they had targets for the number of environmental inspections 

they were expected to complete in a given fiscal year.

In response, BLM required field office staff to 

enter those data into AFMSS. BLM also developed a new inspection 

form to ensure that data gathered during reclamation inspections were 

standardized. These actions improved tracking of BLM’s 

environmental inspection workload, according to BLM officials.

• BLM increased environmental inspections as a result of the Pilot 

Project that enabled some field offices to hire additional staff and 

designate some environmental staff to work primarily on 

environmental inspections. At the four pilot offices we contacted,41

• BLM field offices increased the planned amount of work time devoted 

to environmental inspections. In fiscal year 2007, BLM offices 

reported planning to spend about 131 workmonths (a workmonth is 

about 172 hours) on environmental inspections. In fiscal year 2012, 

some environmental staff reported working only on environmental 

inspections. In contrast, staff at other field offices we visited reported 

that environmental staff usually conduct environmental inspections 

and process APDs.

 

40GAO-05-418. 

41The pilot offices we contacted were Colorado River Valley in Colorado, Carlsbad and 

Farmington in New Mexico, and Vernal in Utah.
 

Page 34 GAO-13-572 BLM Oil and Gas Development

BLM offices planned to spend 182 workmonths on environmental 

inspections.42

• In some cases, environmental staff can perform more inspections due 

to efficiencies created when the average number of wells per well pad 

increases, and when new wells are drilled in closer proximity to other 

wells, according to BLM officials. Some field offices reported that 

technology such as directional drilling has enabled operators to place 

more wells on a given well pad. This allows BLM inspectors to review 

more wells in a given time frame.43

BLM’s environmental mitigation efforts are hampered by (1) an 

environmental inspection prioritization process that does not have 

sufficient information to ensure that wells receiving inspections are those 

that pose the greatest environmental risk, (2) inconsistent documentation 

of inspections and enforcement actions, and (3) challenges with retaining 

and hiring environmental staff in some offices.

BLM’s environmental inspection prioritization process does not effectively 

ensure that the wells posing the greatest environment risk are identified 

as high-priority for environmental inspections conducted each year. In 

particular, BLM staff face challenges obtaining information from AFMSS 

to prioritize wells for environmental inspections, and BLM staff do not 

have sufficient information on the environmental condition of wells that 

have never received an environmental inspection.

Environmental staff in some BLM field offices reported challenges using 

AFMSS to identify which wells should be considered high-priority for 

environmental inspections each year because AFMSS does not have the 

capability to flag individual wells as high priority for environmental 

concerns. Consequently, some BLM environmental staff said that they 

must rely on their own knowledge and memory of wells to determine 

which ones meet prioritization criteria. Also, some environmental staff 

 

42We did not analyze the extent to which the actual number of workmonths BLM spent on 

environmental inspections for these years matched or differed from the number of planned 

environmental inspection workmonths recorded in BLM’s planning documents.

43BLM officials noted that the placing of more wells on a given pad reduces habitat 

fragmentation (the breaking up a large area of habitat into smaller areas) and thus 

provides additional benefits to wildlife.

BLM’s Environmental 

Mitigation Efforts Are 

Hampered by Insufficient 

Information, Inconsistent 

Documentation, and 

Staffing Challenges

BLM’s Inspection Prioritization 

Process Does Not Have 

Information to Ensure Wells 

Receiving Inspections Pose 

Greatest Environmental Risk
 

Page 35 GAO-13-572 BLM Oil and Gas Development

said they sometimes selected wells to inspect based on convenience, 

including selecting some that were close to each other. BLM officials said 

that the agency is planning to replace AFMSS with a new system that, 

among other things, can be used by staff to prioritize and develop targets 

for environmental inspections. However, the officials said that due to 

budget uncertainties they could not say when this will occur.

BLM also does not have information on the environmental condition of 

many wells. We analyzed data on approximately 60,330 federal oil and 

gas wells on lands managed by BLM and found no record for about 

24,840, or 41 percent, in AFMSS of those wells ever having received an 

environmental inspection as of December 2012. At least 75 percent of the 

wells with no environmental inspection record in AFMSS became capable 

of production in fiscal year 2007 or earlier. Since there is no 

environmental inspection history for these wells in AFMSS, BLM does not 

have the information to assess whether the wells pose any current 

environmental risks or whether sufficient environmental mitigation has 

occurred. BLM environmental staff said that wells with no record of an 

environmental inspection could have environmental problems that go 

undetected.

According to BLM officials, it is possible that some of these wells may 

have been inspected for environmental issues, but that the inspections 

were not recorded in AFMSS. Nevertheless, it would still be difficult for 

BLM staff attempting to prioritize environmental inspections to determine 

the environmental condition of wells under these circumstances, since the 

information on their previous environmental inspections is not in AFMSS. 

For example, BLM officials said some environmental inspections of 

federal oil and gas wells performed in fiscal years 2005 and 2006 were 

likely never entered into AFMSS because the database was shut down 

for several months in 2005 as a result of a court order. BLM officials also 

said that it is possible that some wells could have been inspected prior to 

the development of AFMSS in 1997, and that information was not entered 

into AFMSS. In addition, BLM officials said that when ownership of an oil 

and gas lease on federal lands changes through sale, trade, or transfer, 

AFMSS deletes certain inspection dates.

BLM officials also said that some of the wells we identified with no record 

of an environmental inspection in AFMSS may have received other types 

of inspections, such as production inspections, that would have identified 

any significant environmental issues. We did not determine whether the 

wells we identified as having no environmental inspection records had 

received other types of inspections. However, in 2011, a BLM internal 
 

Page 36 GAO-13-572 BLM Oil and Gas Development

assessment of inspection and enforcement activities in several field 

offices found examples of wells that had not received an inspection of any 

kind despite being in production for 10 to 12 years.44

BLM officials said that the agency is considering making changes to its 

approach for prioritizing wells for environmental inspections. BLM’s 

current criteria for prioritizing environmental inspections do not take into 

account when a well last received an environmental inspection, if ever. 

This approach differs from BLM’s approach to production inspections, 

which considers the last inspection date in prioritizing production 

inspections.

Furthermore, 

according to BLM officials, the other types of inspections would typically 

be conducted by staff who do not have the same training as the 

environmental inspection staff. For example, environmental staff are 

generally trained in such areas as interim reclamation and environmental 

best management practices and can assess the adequacy of interim 

reclamation efforts and identify surface environmental concerns such as 

erosion and invasive species. As a result, BLM officials said some 

aspects of environmental protection might not be addressed during other 

types of inspections.

45

 

44U.S. Department of the Interior, BLM, 2011 Inspection and Enforcement Internal Control 

Review of Documentation of Inspections and Review of Drilling, Environmental, and 

Production Inspections (Washington, D.C., 2011).

The officials said that whether a well has received an 

environmental inspection in the last 5 years is being considered as a new 

prioritization factor for environmental inspections. BLM officials said they 

expect to complete updates to their approach for prioritizing 

environmental inspections by 2015. 

45Production inspections are performed on wells that produce oil or gas to ensure that 

equipment, practices, and procedures adhere to the regulations, orders, and any 

applicable approval documents. Generally, specially trained petroleum engineering 

technicians, petroleum accountability technicians, or petroleum engineers conduct these 

inspections.
 

Page 37 GAO-13-572 BLM Oil and Gas Development

BLM’s 2011 internal assessment also found that some environmental 

inspections of oil and gas wells and any resulting enforcement actions did 

not have adequate documentation in accordance with BLM’s inspection 

and enforcement handbook.46

In some locations, BLM also faces challenges in retaining its oil and gas 

staff and in hiring new employees, including staff responsible for 

environmental inspections and enforcement. For example, management 

officials at the 11 field offices we contacted reported having some 

difficulty in hiring or retaining environmental protection staff. Difficulties 

reported included some environmental protection positions going unfilled 

for long periods and new staff hired often being inexperienced and 

requiring greater supervision, limiting their effectiveness. Field office 

management attributed the difficulties in hiring and retention to a variety 

of factors including a high cost of living in some areas, limited cultural 

opportunities, the remote locations of some field offices, and competition 

from industry. Also, according to BLM officials, some environmental staff 

Our site visits and interviews with BLM staff 

found similar problems. For example, we found that staff in some field 

offices do not document in AFMSS verbal warnings to operators to 

address environmental violations or problems. According to BLM’s 

inspection and enforcement handbook, a verbal warning is a nonwritten 

communication to an operator for a violation or problem that will be 

corrected immediately prior to the inspector leaving the location and must 

be documented in AFMSS. However, some environmental staff said they 

prefer to handle environmental violations or problems informally, and that 

documenting all environmental violations or problems in AFMSS would be 

difficult given competing demands on their time. BLM officials 

acknowledged that such practices are not consistent with current agency 

policy. As a result of BLM’s inconsistent documentation of violations or 

problems, it is difficult for BLM to (1) determine the extent to which they 

have occurred and whether the level of violations or problems has 

changed over time; (2) track whether corrective actions were taken; or (3) 

identify trends in an individual operator’s history of environmental 

violations or problems and use this information to help prioritize 

environmental inspections.

 

46BLM’s 2011 Inspection and Enforcement Internal Control Review of Documentation of 

Inspections and Review of Drilling, Environmental, and Production Inspections also found 

similar problems with nonenvironmental inspections, such as production inspections, and 

nonenvironmental enforcement actions. Our review did not cover these types of 

inspections or enforcement actions.

Inconsistent Documentation of 

Inspections and Enforcement 

Actions

BLM Faces Staffing Challenges 
 

Page 38 GAO-13-572 BLM Oil and Gas Development

prefer to be specialists in fields such as biology or botany rather than 

generalists, so they take other positions in BLM when they become 

available. BLM officials said that staff turnover and staff inexperience 

impact both the number of environmental inspections that can be 

conducted and the quality of environmental inspections and enforcement 

actions that are taken. For example, BLM officials said that it may take 

years for newly hired environmental staff members to complete training 

and be able to function without additional supervision, and once fully 

trained, they are frequently offered higher salaries in industry than BLM 

can pay.

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

to our high-risk list based, in part, on BLM’s persistent problems in hiring, 

training, and retaining sufficient staff to meet its oversight and 

management of oil and gas operations on federal lands.47 For example, in 

2010, we found that BLM experienced high turnover rates in key oil and 

gas inspection and engineering positions, potentially affecting their 

oversight of oil and gas development on federal leases. In 2013, we 

updated our high-risk list and reported that the bureaus responsible for 

oversight and management of federal oil and gas resources on federal 

lands and in federal waters—including BLM—have encountered 

persistent problems in hiring, training, and retaining staff.48 49

BLM has taken or initiated various actions in recent years to improve its 

processing of APDs, including implementing the Federal Permit 

Streamlining Pilot Project established under section 365 of the Energy 

Policy Act of 2005. BLM reported in 2008 that additional staff provided by 

the Pilot Project helped some offices improve their processing of APDs, 

but BLM has not finalized an updated assessment of the results of the 

Pilot Project since that time. The act required BLM to submit to Congress 

by 2008 a report that included a recommendation to the President on 

 

47GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2011).

48 GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: February 2013).

49We are currently reviewing the extent to which BLM, the Bureau of Ocean Energy 

Management, and the Bureau of Safety and Environmental Enforcement continue to face 

problems hiring, training, and retaining staff to provide oversight and management of oil 

and gas, including whether the bureaus have identified the causes of their human capital 

challenges, the actions taken in response, and how they plan to measure the 

effectiveness of such actions.

Conclusions 
 

Page 39 GAO-13-572 BLM Oil and Gas Development

whether the Pilot Project should be implemented throughout the United 

States, such as by expanding to all field offices, but BLM has not done so. 

In its 2014 budget justification report, Interior proposed several changes 

to the Pilot Project’s statutory provisions and its funding mechanism; as of 

May 2013, Congress had not acted on this proposal, and the Pilot 

Project’s future is uncertain. Without additional information from BLM on 

the Pilot Project, including a recommendation from the agency and 

updated information on the project’s results, Congress may not have the 

information it needs as it considers the future of the project and its related 

funding.

The Energy Policy Act of 2005 also established a deadline for BLM to 

approve or defer completed APDs, but problems with the completeness 

and accuracy of BLM’s data prevent an assessment of the agency’s 

compliance with the deadline. Without such data, BLM also cannot 

accurately determine how much time it spends during the first period of 

the APD review process where BLM works with operators to provide 

necessary information to complete the APD, or during the second period 

where BLM reviews the completed APD. In April 2013, BLM issued new 

guidance regarding APD data entry, but it is unclear at this time what 

impact the guidance will have on the quality of BLM’s APD data. In 

addition, AFMSS stops tracking some data for approved APDs when they 

expire or are rescinded, cancelled, or withdrawn. BLM would be in a 

better position to evaluate its performance and find ways of improving the 

efficiency of the permitting process or reducing the time it takes to 

process APDs if its APD data were more completely and accurately 

entered and retained in AFMSS, as well as in any new system that 

replaces AFMSS.

BLM increased the number of environmental inspections it performed on 

federal oil and gas wells and facilities from fiscal years 2007 to 2012, but 

the agency’s environmental inspection prioritization process does not 

effectively ensure that the wells posing the greatest environmental risk 

are identified as high priority for environmental inspections. In part, this is 

due to challenges that BLM staff face obtaining information from AFMSS 

to prioritize wells for environmental inspections and because BLM staff do 

not have sufficient information on wells that have never received an 

environmental inspection. Further, BLM’s process for prioritizing wells for 

environmental inspections does not consider when, or if, a well last 

received an environmental inspection. BLM would be in a better position 

to ensure that wells posing the greatest environmental risk are prioritized 

for environmental inspections if its staff were better able to obtain the 

information they need to do so from AFMSS, and from any new system 
 

Page 40 GAO-13-572 BLM Oil and Gas Development

that replaces AFMSS, and if information on the environmental inspection 

history of wells were included in the prioritization process. Furthermore, 

BLM is not consistently documenting environmental violations or 

problems found during the inspections that are conducted. Inconsistent 

documentation of environmental violations or problems and related 

enforcement actions makes it difficult to determine whether environmental 

compliance by operators is improving and limits the ability of BLM offices 

to find the information they need to prioritize future environmental 

inspections.

We recommend that the Secretary of the Interior direct the Director of the 

Bureau of Land Management to take the following four actions:

• Complete and submit to Congress a final report that outlines the 

results of the Federal Permit Streamlining Pilot Project to date, and 

makes a recommendation on whether the Pilot Project should be 

implemented throughout the United States, to meet the mandate of 

section 365 of the Energy Policy Act of 2005.

• Ensure that all key dates associated with the processing of APDs are 

completely and accurately entered and retained in AFMSS, and in any 

new system that replaces AFMSS, to help BLM assess compliance 

with required deadlines and identify ways to improve the efficiency of 

the APD review process.

• Take steps, including making changes to AFMSS, and in any new 

system that replaces AFMSS, to improve the ability of staff to identify 

wells that are a high priority for environmental inspection and to 

incorporate information on the inspection history of wells into the 

environmental inspection prioritization process.

• Take steps to ensure that environmental violations or problems and 

enforcement actions are documented in a consistent manner.

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

review and comment, and Interior provided written comments, which are 

summarized below and reprinted in appendix II. In its comments, Interior 

generally agreed with our report’s recommendations. However, the 

agency stated that it noted some technical errors and incomplete 

information within the report relative to the oil and gas data that BLM 

maintains and its identification of high-priority environmental inspections. 

We incorporated BLM’s technical comments as appropriate.

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 41 GAO-13-572 BLM Oil and Gas Development

BLM had no comments concerning our first two recommendations. In 

regard to our third recommendation that BLM take steps, including 

making changes to AFMSS, and in any new system that replaces 

AFMSS, to improve the ability of staff to identify wells that are a high 

priority for environmental inspection and to incorporate information on the 

inspection history of wells into the environmental inspection prioritization 

process, Interior stated that it recognized that the inspection history of a 

well is an important factor to consider when assessing risk related to 

environmental compliance. Further, the department stated that in fiscal 

year 2011, it developed a new risk-based strategy for its oil and gas 

inspection and enforcement program in which risk factors are assigned to 

each type of inspection that BLM performs. For environmental 

inspections, one of the risk factors that field offices must consider is when 

an environmental inspection was last conducted on a well and that under 

the strategy, higher risk ratings are given to wells that have never had an 

environmental inspection or have not had an inspection for an extended 

period of time. However, the department said the environmental 

inspections component of the risk-based strategy has not yet been 

implemented because of limitations with the current AFMSS database 

and that the department is planning to transition to a new database 

system that will, among other things, have the ability to support the riskbased strategy for environmental inspections. According to Interior, the 

first phase of the new database system (related to APD processing and 

tracking) is expected to be implemented by the end of calendar year 

2013, but the department did not specify when additional phases of the 

new system will be implemented to be able to support the risk-based 

strategy for environmental inspections. We appreciate the department’s 

effort and mention in the report that it is considering making changes to 

its approach for prioritizing wells for environmental inspections. However, 

delays to the implementation of the new database system hinder staff’s

ability to identify wells that are a high priority for environmental inspection 

and to incorporate information on the inspection history of wells into the 

environmental inspection prioritization process.

In regard to our recommendation that BLM take steps to ensure that 

environmental violations or problems and enforcement actions are 

documented in a consistent manner, Interior stated that incomplete 

documentation of environmental inspections was included in the findings 

of an Internal Control Review of 10 field offices with major oil and gas 

responsibilities conducted by BLM in fiscal year 2011. The Internal 

Control Review report made recommendations regarding documentation 

of enforcement actions and inspections that Interior said the 10 field 

offices are in the process of implementing. In addition, the department 
 

Page 42 GAO-13-572 BLM Oil and Gas Development

stated the Internal Control Review report has been shared with all BLM 

State Directors. As our findings are consistent with those of the Internal 

Control Review, we reiterate the importance of BLM taking steps to 

ensure that environmental violations or problems and enforcement 

actions are documented in a consistent manner. We look forward to 

seeing how BLM addresses our recommendation. 

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 to the Secretary 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 III.

Frank Rusco

Director, Natural Resources and Environment.
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-13-572 BLM Oil and Gas Development

This appendix details the methods we used to assess the Department of 

the Interior’s Bureau of Land Management’s (BLM) management of the 

development of federal oil and gas resources. Specifically, the objectives 

of this report were to determine, from fiscal years 2007 to 2012, (1) what 

changes have occurred in BLM’s oil and gas permitting workload; (2) 

what actions BLM has taken to manage its oil and gas permitting 

workload and what challenges, if any, remain; and (3) what actions BLM 

has taken to mitigate the surface environmental impact of developing 

federal oil and gas resources and what challenges, if any, remain.

To conduct our work, we reviewed relevant laws, regulations, and BLM 

guidance. We also interviewed officials in BLM headquarters and officials 

from a nonprobability sample of 11 BLM field offices and 4 BLM state 

offices.1 We selected field offices based on their different geographical 

locations and the different types of oil and gas resources they manage, 

and to reflect varied levels of oil and gas permitting and environmental 

inspection activity and a mix of offices that are or are not participating in 

the Federal Permit Streamlining Pilot Project. Specifically, we visited and 

interviewed officials in 8 BLM field offices (Colorado River Valley, Little 

Snake, and White River in Colorado; Moab, Price, and Vernal in Utah; 

and Pinedale and Rock Springs in Wyoming) and interviewed officials by 

telephone in 3 additional field offices (Carlsbad and Farmington in New 

Mexico, and the North Dakota Field Office). In fiscal year 2012, these 

offices accounted for about 68 percent of all APDs received by BLM for 

federal oil and gas resources and for about 52 percent of all 

environmental inspections performed by BLM. During our site visits to the 

Colorado River Valley, Vernal, and Pinedale Field Offices, we observed 

BLM officials conduct environmental inspections of oil or gas wells and 

related facilities. In addition, we interviewed officials by telephone in 4 

BLM state offices (Colorado, New Mexico, Utah, and Wyoming), which 

were selected based on their jurisdiction over 10 of the 11 field offices we 

contacted.2

 

1 Because this was a nonprobability sample, observations from interviews with these 

offices, taken alone, do not support generalizations about other offices. However, such 

observations provide illustrative examples of the types of challenges BLM faces in 

managing its permitting workload and mitigating the environmental impact of oil and gas 

development.

We also interviewed representatives from environmental 

organizations—the Western Organization of Resource Councils and the 

2

We did not interview officials from the BLM Montana State Office, which has jurisdiction 

over the North Dakota Field Office.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-13-572 BLM Oil and Gas Development

Upper Green River Alliance—and energy industry organizations—the 

American Petroleum Institute, the American Exploration and Production 

Council, and the Western Energy Alliance—to obtain their perspective on 

BLM’s management of the oil and gas permitting process and on the 

implementation of BLM’s environmental inspection and enforcement 

program.

In addition, we requested and analyzed electronic BLM data from 

Automated Fluid Minerals Support System (AFMSS) on federal oil and 

gas wells. We obtained data on applications for permit to drill (APD) 

received by BLM from fiscal years 2005 through 2012, environmental 

inspections performed from fiscal years 2005 through 2012, and data on 

all federal wells managed by BLM, including information on their last 

environmental inspection, if any, recorded in AFMSS. We assessed the 

reliability of these data by (1) performing electronic testing for obvious 

errors in accuracy and completeness; (2) reviewing existing 

documentation about the data and AFMSS; (3) interviewing BLM 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 we obtained were sufficiently reliable for our 

purposes to determine the number of federal wells managed by BLM. 

However, a BLM official knowledgeable about AFMSS said that BLM’s 

environmental inspection data in AFMSS were not entirely reliable for 

fiscal years 2005 and 2006, primarily due to issues stemming from the 

Cobell Indian Trust lawsuit that resulted in the temporary shutdown of

BLM’s information technology (IT) systems.3

 

3

In the Cobell class-action lawsuit, which concerned the government’s management of 

Native American trust funds, a U.S. District Court Judge on December 5, 2001, ordered 

Interior to disconnect from the internet all IT systems that house or provide access to 

individual Indian Trust data. Specifically, Interior’s IT systems were impacted multiple 

times starting in 2001, and were shut down for several months in 2005 for federal data 

and until 2008 for Indian Trust data.

As a result, BLM officials 

said they were unable to enter information into AFMSS on federal oil and 

gas wells, including information on APDs and environmental inspections, 

for several months in 2005. According to the officials, BLM field offices 

entered much of the backlogged information into AFMSS after the 

shutdown ended, but some data from fiscal years 2005 and 2006, 

particularly data on environmental inspections, were never entered into 

AFMSS due to the shutdown and the subsequent backlog of data entry 

the field offices faced in 2006.
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-13-572 BLM Oil and Gas Development

We preliminarily analyzed the environmental inspection data for fiscal 

years 2005 and 2006 and shared the results with some of the field office 

staff we interviewed, who confirmed that the data for their offices 

appeared to be incomplete, but they did not know what the correct 

numbers should have been. Consequently, we determined that the 

environmental inspection data for fiscal years 2005 and 2006 were not 

sufficiently reliable for our purposes, and we limited the scope of our data 

analysis on environmental inspections to fiscal years 2007 through 2012. 

We similarly limited the scope of our data analysis on APDs to fiscal 

years 2007 through 2012 to be consistent with our presentation of the 

environmental inspection data, and to focus this analysis on the years in 

which BLM’s revised permitting rule was used. In addition, since the 

shutdown of BLM’s IT systems for tracking data on oil and gas 

development on Indian Trust lands lasted until 2008, we limited the scope 

of our data analysis to federal oil and gas activities, and we did not 

include Indian Trust oil and gas information in any of the well, APD, or 

environmental inspection data presented in this report. In some offices, 

such as the North Dakota Field Office, activities related to Indian Trust 

wells can represent a sizeable portion of the office’s overall oil and gas 

workload.

To determine how BLM’s permitting workload has changed, we analyzed 

the electronic data obtained from AFMSS to count the number of APDs 

for federal oil and gas resources with a received date listed from the start 

of fiscal year 2007 to the end of fiscal year 2012. Based on the results of 

our electronic testing of the APD data and interviews with agency officials 

about the data, we determined that the data were sufficiently reliable for 

this purpose. As part of our analysis, we reviewed summary data that 

BLM had provided us on received APDs to see how they compared with 

our results and to corroborate our results when possible. We identified 

differences between the numbers we calculated and BLM’s summary 

data on received APDs for some offices, but since BLM could not provide 

us with additional information on its summary numbers, we were unable 

to determine why those differences exist. We present the results of our 

analysis on the total number of APDs received by BLM by fiscal year from 

2007 to 2012 in figure 3, and our results for the number of APDs received 

by BLM’s 33 lead oil and gas offices in fiscal years 2007 and 2012 are 

presented in table 1. To identify potential factors that may have 

contributed to changes in BLM’s permitting workload, we interviewed BLM 

headquarters officials and representatives of energy industry 

organizations to obtain their views.
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-13-572 BLM Oil and Gas Development

To identify actions BLM has taken to better manage its oil and gas 

permitting workload, we reviewed BLM guidance and documentation and 

interviewed officials in BLM headquarters to discuss policy, procedural, 

and other changes that BLM has implemented. To examine the impact of 

these actions and to determine if BLM continues to face any challenges in 

managing its permitting workload, we interviewed officials in 11 BLM field 

offices that manage oil and gas development, including staff at the 

managerial and nonmanagerial levels. We also analyzed electronic data 

from AFMSS on approved APDs to assess the average number of days it 

took BLM to process APDs from the date of receipt to the date of 

approval. To calculate the average number of days in fiscal year 2012, we 

obtained and analyzed data on 4,228 APDs approved in fiscal year 2012, 

representing more than 99 percent of the 4,256 APDs for federal oil and 

gas resources that BLM reported were approved that year. The data we 

obtained from BLM did not contain sufficient information on the 28 other 

APDs approved in fiscal year 2012 to include them in our analysis, and it 

is unclear how the average number of days it took BLM to process these 

APDs compared with the average number of days we calculated for fiscal 

year 2012. Based on our electronic testing of BLM’s data on approved 

APDs and interviews with agency officials about the data, we found that 

the data were not sufficiently reliable to determine the number of days it 

took BLM to process APDs prior to fiscal year 2012. To determine 

whether BLM maintains the data necessary to assess its compliance with 

the required deadline to approve or defer completed APDs, we analyzed 

data on nearly 27,400 approved APDs that listed an approval date in 

AFMSS from fiscal year 2007 to fiscal year 2012. Based on a review of 

BLM documentation, we determined that our analysis included 

approximately 89 percent of all APDs for federal oil and gas resources 

that BLM reported were approved from fiscal year 2007 to fiscal year 

2012. We found that BLM’s data were not sufficiently reliable to assess 

the agency’s compliance with the required deadline due to problems with 

the completeness and accuracy of the data. To identify potential factors 

that may impact the amount of time it takes BLM to process APDs, we 

interviewed BLM headquarters officials and representatives of energy 

industry organizations to obtain their perspectives.

Our examination of actions BLM has taken to better mitigate the 

environmental impact of oil and gas development on federal lands 

focused on actions in BLM’s oil and gas inspection and enforcement 

program. We reviewed BLM guidance and documentation and 

interviewed BLM headquarters officials to discuss key policy and 

procedural changes that BLM has implemented. To examine how these 

changes have impacted BLM’s oil and gas environmental mitigation 
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-13-572 BLM Oil and Gas Development

efforts and to determine if any challenges remain, we interviewed officials 

in 11 BLM field offices, including staff at the management level, natural 

resource specialists, and other specialists responsible for conducting 

environmental inspections. In three of these offices, we observed BLM 

staff conduct environmental inspections of federal oil and gas wells to 

better understand the role of environmental inspections in BLM’s 

mitigation efforts and to identify the challenges BLM staff face in 

performing these inspections.

We also analyzed electronic data obtained from AFMSS to quantify the 

change in the number of environmental inspections performed by BLM 

from fiscal year 2007 to fiscal year 2012. To measure this change, we 

analyzed AFMSS data on environmental inspections performed on 

federal oil and gas wells and facilities that listed an inspection completion 

date from fiscal year 2007 to fiscal year 2012. We present data on the 

change in environmental inspections from fiscal year 2007 to fiscal year 

2012, broken down by BLM’s 33 lead oil and gas offices, in table 2. 

Based on information provided by a BLM official knowledgeable about the 

AFMSS data, we excluded some environmental inspections listed in 

AFMSS from this analysis due to concerns about the accuracy of the 

AFMSS inspection records. In most cases, the environmental inspection 

records we excluded indicated that the inspections had been performed 

on well sites where no surface disturbance had occurred as of the date of 

inspection. According to the BLM official, some of these records may 

represent on-site inspections that occurred during the APD review 

process and were incorrectly recorded in AFMSS as environmental 

inspections. In total, we identified and excluded from our analysis more 

than 2,800 environmental inspections listed in AFMSS as having 

completion dates from fiscal years 2007 to 2012 due to the data not being 

sufficiently reliable for our purposes. This included excluding more than 

160 environmental inspection records from the 2007 totals presented in 

table 2 and more than 580 environmental inspection records from the 

2012 totals presented in the same table.

In addition, we obtained and analyzed electronic data from AFMSS on all 

wells involved in developing federal onshore oil and gas resources, 

including data on each well’s most recent environmental inspection 

recorded in AFMSS, if any, and data on when each well was originally 

drilled. The data we analyzed from AFMSS included wells that were in a 

producible or service status (i.e., wells that were physically and 

mechanically capable of producing oil or gas or that were used to support 

oil and gas operations through activities such as water disposal) and were 

located either on lands with surfaces managed directly by BLM (data 
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-13-572 BLM Oil and Gas Development

current as of December 18, 2012) or on lands with surfaces managed by 

other federal, state, or private entities, but with mineral rights controlled 

by the federal government (data current as of November 30, 2012).4

We conducted this performance audit from May 2012 to August 2013 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.

We 

identified wells using the well’s unique 10-digit American Petroleum 

Institute number. We analyzed these data to determine the number of 

federal wells managed by BLM offices, which is presented in figure 1. We 

also analyzed these data to assess how many federal wells had no record 

in AFMSS of ever receiving an environmental inspection. We limited the 

scope of our analysis of wells with no environmental inspection records in 

AFMSS to approximately 60,330 federal wells located on lands with 

surfaces managed directly by BLM. However, we excluded some other 

wells located on federal lands managed by BLM due to challenges we 

encountered analyzing their data, and we also excluded wells that were 

located on lands whose surface are managed by other federal, state, or 

private entities, but which have mineral rights that are controlled by the 

federal government. In total, about 32,270 wells in these categories were 

not included in this analysis.

 

4

The results we present from our analysis of these data do not include federal wells that 

had been abandoned or nonfederal wells that were located on Indian Trust lands.
Appendix II: Comments from the Department 

of the Interior

Page 49 GAO-13-572 BLM Oil and Gas Development

Appendix II: Comments from the Department 

of the Interior
Appendix II: Comments from the Department 

of the Interior

Page 50 GAO-13-572 BLM Oil and Gas Development
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 51 GAO-13-572 BLM Oil and Gas Development

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

In addition to the individual named above, key contributors to this report 

included Kimberly Brooks (Assistant Director); Cheryl Arvidson; Elizabeth 

Beardsley; David Bennett; Cindy Gilbert; Michael Kendix; Dan Royer; 

Christine San; Kiki Theodoropoulos; and Joshua Wiener.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(361403)
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