Indian Energy Development: Additional Actions by Federal Agencies Are Needed to Overcome Factors Hindering Development
Published: 2016-11-10T00:00:00

Fast Facts:
Tribal nations hold considerable energy resources that—when developed—can improve tribal well-being and long-term economic success. However, a number of factors—including a complex federal regulatory framework that involves multiple agencies—have hampered development.
A collaborative federal approach to helping tribes achieve their energy goals is important. But we found that federal initiatives aimed at improving such collaboration lack sustained leadership, dedicated resources, and roles for key agencies—among other things. We made 10 recommendations towards addressing these and other problems.

Highlights:
section_title: Why GAO Did This Study
paragraphs: Indian tribes and their members hold considerable energy resources and may use these resources to provide economic benefits and improve the well-being of their communities. However, GAO and others have found that Indian energy development is hindered by several factors, such as a complex regulatory framework, BIA workforce challenges, and limited access to energy markets.
Tribes and their members determine how to use their energy resources. In doing so, they work with multiple federal agencies with various roles in the development process—including a regulatory role, a role as provider of technical and financial assistance, or as a purchaser of energy.
GAO was asked to evaluate issues related to Indian energy development. This report examines, among other things, (1) federal efforts to help overcome factors that hinder development, (2) BIA's efforts to address workforce challenges, and (3) federal efforts to implement a preference authority to purchase energy from tribes. GAO analyzed federal data and documents and interviewed tribal and federal officials.
section_title: What GAO Found
paragraphs: Two key federal initiatives led by the Department of the Interior (Interior)—the interagency White House Council on Native American Affairs’ Energy Subgroup (Energy Subgroup) and Interior’s Indian Energy Service Center (Service Center)—were implemented to help improve collaboration and the effectiveness of federal efforts to fulfill management responsibilities for Indian lands, assist tribes in developing their energy resources, and overcome any related challenges. However, the Energy Subgroup and the Service Center have not incorporated leading collaborative practices, which may limit the effectiveness of these initiatives to address the factors that hinder Indian energy development. For example, GAO found the following:
Energy Subgroup: Participating agencies have dedicated few staff and financial resources to the Subgroup and have not identified resources needed or a funding model—a leading practice to sustain collaborative efforts. Some participating agency officials noted that the effectiveness of the Subgroup is limited without dedicated resources. They also stated that key activities completed to date by the Subgroup are the result of agencies voluntarily applying budgetary resources to specific activities. Without dedicated resources and a funding model to support its activities, the extent to which the Energy Subgroup will be able to effectively accomplish its goals is unclear.
Service Center: Interior has recognized the need for collaboration in the regulatory process and described the Service Center as a central point of collaboration for permitting that will break down barriers between federal agencies. However, some regulatory agencies, such as the Fish and Wildlife Service, the Environmental Protection Agency, and the U.S. Army Corps of Engineers have not been included as participants. Without the involvement of key regulatory agencies, the Service Center will be limited in its ability to improve efficiencies in the regulatory process for Indian energy development.
GAO and others have previously reported that Interior’s Bureau of Indian Affairs (BIA) has longstanding workforce challenges that have hindered Indian energy development. In this review, GAO found that BIA has high vacancy rates at some agency offices and that the agency has not conducted key workforce planning activities, such as an assessment of work skills gaps. These workforce issues further contribute to BIA’s inability to effectively support Indian energy development. Federal internal control standards recommend agencies identify the key skills and competencies their workforces need to achieve their goals and assess any skills gaps. Until BIA undertakes such activities, it cannot ensure that it has a workforce with the right skills, appropriately aligned to meet the agency’s goals and tribal priorities.
A provision in the Energy Policy Act of 2005 authorizes the federal government, the largest single consumer of energy in the nation, to give preference to tribes for purchases of electricity or other energy products. However, the General Services Administration (GSA), the federal agency with primary responsibility for purchasing energy, has not developed guidance to implement this provision government-wide; doing so could help to increase tribal access to the federal government’s energy purchasing programs.
section_title: What GAO Recommends
paragraphs: GAO is making 10 recommendations, including that the Secretary of the Interior identify resources and a funding model for the Energy Subgroup, involve other agencies in the Service Center so it is a single point of contact for the regulatory process, and require BIA to undertake workforce planning activities. GAO is also recommending that the Administrator of the GSA develop implementing guidance relating to purchasing energy from tribes. Interior, DOE, and GSA concurred with GAO's recommendations.

section_title: Letter
paragraphs: Development of energy resources is vital for the livelihood, well-being,  and long-term economic sustenance of some Indian tribes and their  members, in part because energy development provides opportunities to  improve poor living conditions and decrease high levels of poverty.  Tribes and their members determine how to use Indian energy resources  to meet the needs of the community. However, if the resources are held  in trust or restricted status, the Department of the Interior’s (Interior)  Bureau of Indian Affairs (BIA)—through its 12 regional offices, 85 agency  offices, and other supporting offices—generally must review and approve  leases, permits, and other documents required for development. Other  federal agencies—such as the Bureau of Land Management (BLM), U.S.  Fish and Wildlife Service (FWS), and the Environmental Protection  Agency (EPA)—also have regulatory roles and involvement with energy  development.
Although tribes are pursuing a variety of opportunities to develop their  energy resources, federal mismanagement of Indian resources and other  factors hindering development of Indian energy resources have been  reported for nearly a decade by Interior’s Inspector General, us, and  others. For instance, in 2012, Interior’s Inspector General found that  weaknesses in BIA’s management of oil and gas resources contributed to  a general preference by industry to acquire oil and gas leases on non- Indian lands over Indian lands. In addition, in June 2015, we reported  that BIA staff limitations, a complex regulatory framework that involved  multiple agencies, tribes’ limited access to capital and energy markets,  and other factors also hindered Indian energy development. At that time,  we recommended that Interior take four actions to help address BIA’s  management shortcomings related to incomplete data and oversight of its  internal process for reviewing and approving energy-related documents.  BIA generally agreed with our recommendations and stated that it was  taking some actions in response to them. BIA also stated that the  formation of its Indian Energy Service Center (Service Center) would help  to increase coordination among the numerous regulatory federal agencies  involved with Indian energy development and would make the agency  more efficient in its management role.
In June 2013, Executive Order 13647 established the White House  Council on Native American Affairs (Council) to improve the coordination  of federal programs and the use of available resources, and to make the  federal government work more efficiently to find solutions to the  challenges facing tribes and their members. The Council established five  subgroups, including an Energy Subgroup, to discuss current initiatives  and identify interagency solutions. The Energy Subgroup is co-chaired by  the Secretaries of Energy and the Interior and comprises 11 key federal  agencies that could help tribes to achieve their energy goals. The General  Services Administration (GSA) is one of the agencies included in the  Energy Subgroup because it is responsible for purchasing energy for the  federal government—the largest consumer of energy in the United States.  To encourage the federal government to work with tribes to meet its  energy needs, the Energy Policy Act of 2005 included a provision  authorizing federal agencies to give preference to tribal entities when  purchasing electricity and energy products.
You asked us to review federal efforts to assist Indian energy  development. This report examines (1) whether the actions of the Energy  Subgroup and Service Center have helped to overcome long-standing  factors hindering development, (2) BIA’s efforts to address workforce  challenges that hinder Indian energy development, (3) the progress of  federal agencies to implement the preference authority to purchase  energy from tribes, and (4) any additional opportunities stakeholders  identified that federal agencies could take to help overcome factors  hindering Indian  energy development.
To examine actions taken by the Council and Service Center that may  overcome long-standing factors that have hindered Indian energy  development, we reviewed documentation and interviewed key officials  associated with these efforts. The factors that have hindered Indian  energy development are found in our prior work, as well as reports from  Interior’s Inspector General, the Commission on Indian Trust  Administration and Reform and congressional testimony. The factors  include shortcomings in BIA’s management of Indian energy development  as well as additional factors that are generally outside of BIA’s  management responsibilities, such as a complex regulatory framework  and infrastructure limitations. For the Council’s Energy Subgroup, we  reviewed the Subgroup’s enabling documentation relevant to our review,  which established policy goals and workgroups, as well as a document  that reported the Energy Subgroup’s key activities. We interviewed  federal officials representing key agencies participating in the Subgroup,  including the Department of Energy’s (DOE) Office of Indian Energy (IE),  Interior, GSA, and the U.S. Department of Agriculture (USDA); the  Executive Director of the Council; and the Special Assistant to the  President for Native American Affairs. We assessed the extent to which  these activities and processes met best practices for collaboration that we  have identified in our prior work. For the Service Center, we collected  and reviewed available documentation, including a memorandum of  understanding establishing the Service Center, Interior’s budget  justification reports, congressional testimony, a transcript of an Interior  tribal budget meeting, and documents that reported the Service Center’s  planned and completed tasks.
We also reviewed documents from an interagency planning meeting of  the Indian  Energy and Minerals Steering Committee that included  representatives from BIA, BLM, Interior’s Office of Natural Resources  Revenue (ONRR), Interior’s Office of the Special Trustee for American  Indians (OST), and Interior’s Office of Indian Energy and Economic  Development (IEED) at which updates related to the Service Center were  presented. We interviewed federal officials, including representatives from  BIA and IEED. We also interviewed 8 of the 12 BIA regional directors and  10 of the 85 BIA agency offices to understand their role establishing the  Service Center. The data we collected cannot be generalized to all BIA  regional and agency offices. We selected BIA regional and agency offices  that work directly with tribes that have a history of energy development or  expressed an interest in energy development and that represent different  geographic locations. Further, to obtain additional perspectives on the  Service Center, we interviewed officials representing 30 tribal nations and  representatives from two intertribal organizations. Because this was a  nonprobability sample, our findings are not generalizable to other tribal  nations. We assessed the extent to which Interior’s activities and  processes for developing and implementing the Service Center follow  Interior’s Departmental Manual, which identifies requirements for the  creation of a new office; best practices for modernizing the federal  permitting and review process identified by an interagency committee;  and leading practices for permitting, collaboration, and organizational  change that we have identified in our prior work.
To examine BIA’s efforts to address its workforce challenges, we  reviewed documentation from BIA on the status of its workforce and any  known gaps. We collected workforce data from 17 BIA agency offices that  work directly with tribes that have a history of energy development or  have expressed an interest in energy development. The data we collected  cannot be generalized to all BIA agency offices. To assess the reliability  of these data and this information, we (1) reviewed the data for obvious  errors in completeness and accuracy, (2) interviewed BIA  superintendents who were knowledgeable about the data, and (3) verified  the results of our work with agency officials. We found the data to be sufficiently reliable for our purposes. We interviewed 8 of the 12 BIA  regional directors, the BIA director, and other BIA officials identified by  BIA as relevant to workforce planning and management to identify actions  taken to determine the status of its workforce. We interviewed consultants  conducting a BIA workforce study to identify the scope and purpose of the  study. We assessed the extent to which BIA’s activities and processes  met Office of Personnel Management standards, federal internal control  standards, and leading practices for workforce planning that we have  identified in our prior work.
To identify the progress federal agencies have made to implement the  preference authority for tribal energy purchases, we reviewed the  provision contained in the Energy Policy Act of 2005, federal regulations,  and guidance documents and interviewed federal officials from GSA and  DOE. We spoke with GSA officials because the agency is involved with  energy purchases for most government agencies. In addition, GSA is a  member of the Federal Acquisition Regulatory Council. The Council helps  direct and coordinate government-wide procurement policy and maintains  the Federal Acquisition Regulation (FAR). We spoke with DOE officials  because DOE developed agency-specific guidance to implement the  preference authority.
To identify additional opportunities to address the factors that hinder  Indian energy development, we reviewed federal documents and  interviewed stakeholders, including tribal and federal officials. Specifically,  we interviewed federal officials from BIA, IEED, DOE, DOE’s Western  Area Power Administration, USDA, GSA, and the U.S. Department of  Housing and Urban Development (HUD) who may have a role associated  with Indian energy development. We also interviewed officials from 30  tribal nations. We selected these tribes on the basis of their experience  developing or planning to develop oil, gas, and renewable energy  resources and to obtain views from tribes located in different geographic  locations. Because this was a nonprobability sample, our findings are not  generalizable to stakeholders not included in our review. To characterize  stakeholders’ views, we define the modifier “several” to mean  representatives from six or more entities; “a few” means representatives  from three to five entities. We may not have identified all of the additional  opportunities to address the factors that hinder Indian energy  development, and as a result other opportunities may exist that we do not  report. Rather, the opportunities we present are examples identified  through stakeholder interviews and documentation provided in response  to interviews.
We conducted this performance audit from July 2015 to November 2016  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.
subsections: section_title: Background
paragraphs: The U.S. Census Bureau reported in 2013 that American Indians and  Alaska Natives were almost twice as likely to live in poverty as the rest of  the population. A 2014 Interior report estimated that between 43 and 47  percent of American Indian families in South Dakota earned incomes  below the poverty line, compared with a national average of about 23  percent for all Native American families. In addition, according to DOE  documents, Indian communities are more likely to live without access to  electricity and pay some of the highest energy rates in the country— hindering economic development and limiting the ability of tribes to  provide their members with basic needs, such as water and wastewater  services and adequate health care. Considerable energy resources,  including domestic mineral resources such as oil, gas, and coal, and  resources with significant potential for renewable energy development,  including wind, solar, hydroelectric power, geothermal, and biomass, exist  throughout Indian country. Tribes may seek opportunities to use these  resources as an option to create economic benefits that provide revenue  for government operations and social service programs, create high- quality jobs, and offset power costs by increasing access to reliable and  affordable energy for tribal buildings and individual homes. For instance,  in fiscal year 2015, the development of Indian-owned  oil and gas  resources generated more than $1 billion in revenue for tribes and  individual Indian mineral owners, according to Interior, making oil and gas  resources one of the largest revenue generators in Indian country. In  addition, tribes are taking advantage of renewable energy sources and  developing projects that range from facility- and community-scale  production, such as rooftop solar panels or a wind turbine to power a  community center, to utility-scale production of hundreds of megawatts of  electricity (see fig. 1).
However, the development of Indian energy resources can be a complex  process involving a range of stakeholders, including federal, tribal, and  state agencies. The specific role of federal agencies can vary on the  basis of multiple factors, such as the type of resource, location of  development, scale of development, ownership of the resource, and  Indian tribe involved. Figure 2 shows various roles federal agencies may  have in the development of Indian energy resources.
A short description of the agencies’ roles follows.
Resource Identification. To develop energy resources, developers and  operators must locate a suitable resource. To locate potential oil and gas  resources, most operators use seismic methods of exploration. For  renewable projects, developers conduct a feasibility assessment to  evaluate the potential of the resource for development and determine the  viability of the project, which may include evaluating market demand for  power and financing opportunities. Both IEED and IE help tribes identify  resource potential. For example, according to IE data, IE provided a tribe  $210,000 in 2012 to identify available solar and biomass energy  resources, characterize solar and biomass energy technologies, and  analyze the technical and potential economic viability of projects.
Technical and financial assistance. IE and IEED manage the federal  government’s financial and technical assistance programs dedicated to  Indian energy development. IE provides federally recognized tribes and  tribal entities financial and technical assistance to promote Indian energy  development and efficiency, reduce or stabilize energy costs, and bring  electrical power and service to tribal communities and the homes of tribal  members. For example, in 2015, IE awarded technical assistance to an  intertribal corporation for a survey of wind resources, a survey of  transmission and environmental constraints, and market analysis for 16  potential wind turbine deployment sites. According to a DOE report, IE  provided $48 million to assist more than 180 tribal energy projects from  2002 through 2014. IE also offers education through webinars, forums,  and workshops. IEED serves tribes and their members by providing  technical and financial assistance for the exploration, development, and  management of tribal energy resources. According to IEED officials, IEED  provided about $52 million to assist 340 tribal energy projects from 2002  through 2015. According to its data, IEED is assisting a tribal member to  develop a 5,000-acre solar project by helping secure transmission line  access with potential right-of-way landowners, and by meeting with  county commissioners to gain support for the project. In some instances, both IE and IEED provide assistance for a project. For  example, IE and IEED coordinated to help a tribal solar project. IEED  provided an engineering design grant, and IE provided an installation  grant and technical assistance.
For the past 6 years, IEED has also provided assistance on an as-needed  basis to BIA agency offices by assigning staff for a period of time— generally a year or longer—to perform such tasks as organizing oil and  gas records, clearing backlogs of energy-related documents, reviewing  leases, and helping BIA agencies fulfill requirements under the National  Environmental Policy Act (NEPA). For instance, according to a BIA  official, IEED helped a BIA agency office by conducting 1,584 NEPA and  right-of-way compliance inspections for energy-related activities involving  oil and gas well pads, access roads, and pipelines. In another example,  IEED helped a BIA agency office by reviewing environmental documents  and conducting site surveys for 77 proposed oil and gas well pads.
Other federal agencies, including USDA, HUD, Commerce’s Economic  Development Administration, and Treasury, can also provide financial  assistance to tribes to explore and develop their energy resources. For  example, according to its data, USDA awarded a $500,000 grant through  its Rural Energy for America Program in fiscal year 2015 to a tribal entity  seeking to develop a hydroelectric project. Also, HUD data shows that in  fiscal year 2015 a tribe used funds provided through HUD’s block grant  program to extend transmission lines to communities that lack basic  electrical service.
Regulate. Multiple federal agencies have a regulatory role associated  with Indian energy development. For example, BIA approves seismic  exploration permits for operators to identify oil and gas resources,  maintains surface and mineral ownership records, identifies and verifies  ownership of land and resources, and reviews and approves a number of  energy-related documents—such as surface leases, mineral leases for  the right to drill for oil and gas resources, and right-of-way agreements. In  addition, BLM issues drilling permits to operators developing Indian oil  and gas resources after receiving BIA concurrence to approve the  permits. Further, EPA issues permits for air emissions that may be  required for some oil and gas development, and FWS issues permits for  incidental deaths of certain wildlife species, which may be needed for a  wind project. If energy development affects navigable waters, the U.S.  Army Corps of Engineers may need to issue a permit.
Provide transmission access assistance. Utility-scale renewable  energy projects need to connect to the electric grid to transmit power  generated from the project, along transmission lines, to a destination.  DOE’s Western Area Power Administration, along with other power  administration agencies, is responsible for marketing and transmitting  electricity across the United States and can help tribes to better  understand transmission capacity, identify options for accessing available  capacity on transmission lines, and assist with interconnection  requirements. For example, according to officials from the Western Area  Power Administration, it partnered with a tribal utility authority to resolve  transmission congestion affecting a proposed 27-megawatt utility-scale  solar project.
Purchase power. To be economically feasible, utility-scale renewable  energy projects need a customer to purchase their power. The federal  government is the nation’s largest energy consumer. In fiscal year 2013,  the government spent about $6.8 billion on energy for over 3.1 billion  square feet of buildings and facilities—an area about the size of 50,000  football fields. GSA has general statutory authority to enter into utility  services contracts of up to 10 years for all federal agencies. GSA has  delegated the authority to enter into contracts for public utility services to  the Department of Defense (DOD) and to DOE for procurements by those  agencies. The Energy Policy Act of 2005 encourages federal agencies to  purchase electricity, energy products, and by-products from tribal entities.  Specifically, the act includes a provision authorizing federal agencies to  give preference to a tribe or tribal enterprise when purchasing electricity  or any other energy or energy by-product as long as federal agencies do  not pay more than the prevailing market prices or obtain less than  prevailing market terms and conditions.
subsections: section_title: White House Council on Native American Affairs Energy Subgroup
paragraphs: The Council was established by executive order in June 2013. The  executive order calls for the Secretary of the Interior to lead the Council,  the Council to meet at least three times per year, and Interior to provide  funding and administrative support to the Council. According to an Interior  document, the Council will improve efficiencies by coordinating work  across the federal government and use an “all-of-government approach”  to find solutions that address tribal needs. To accomplish its goals, the  Council includes five subgroups—(1) energy; (2) health; (3) education; (4)  economic development and infrastructure; and (5) environment, climate  change, and natural resources—to discuss current initiatives and identify  interagency solutions. The Energy Subgroup was formed in November  2013 with the Secretaries of Energy and the Interior as co-chairs. In May  2014, the Energy Subgroup identified nine additional federal agencies  that should be included as participants and established policy goals for  the Subgroup that, if accomplished, may help to overcome some of the  factors that we previously identified as hindering Indian  energy  development. For example, in June 2015, we reported that tribes’  limited access to capital had hindered development. One of the Energy  Subgroup’s goals is to evaluate, align and coordinate financial and  technical assistance programs to leverage agency resources, funding,  and expertise. Similarly, in June 2015, we found that the development of  Indian energy resources is sometimes governed by multiple federal, tribal,  and, in certain cases, state agencies and can involve significantly more  steps, cost more, and take more time than the development of private and  state resources. One of the Energy Subgroup’s goals is to evaluate  opportunities to streamline and accelerate regulatory processes.
According to DOE and Interior officials, since May 2014, the federal  agencies that formed the Energy Subgroup have taken the following  actions:  IE and IEED signed a memorandum of understanding in June 2016 as  a format for collaboration between the two agencies;  IE and IEED began to meet regularly in August 2015 to discuss  projects involving  both agencies and grant release dates, among  other things;  IE, with input from numerous other agencies, developed a web-based  tool that provides information about grant, loan, and technical  assistance programs available to support tribal energy projects;  IE hosted events to encourage tribal engagement, such as the  September 2015 National Tribal Energy Summit: A Path to Economic  Sovereignty; and  IE, Interior, USDA, GSA, DOD, and Treasury convened a meeting to  discuss opportunities to provide technical and financial assistance to a  planned 1-gigawatt wind and transmission infrastructure project.
section_title: Indian Energy Service Center
paragraphs: In response to tribal requests for increased coordination and more  efficient management of their resources from the numerous regulatory  federal agencies involved with Indian energy development, in 2014,  Interior took initial steps to form a new office, the Service Center,  composed of staff from four Interior agencies—BIA, BLM, ONRR, and  OST—with BIA as the lead agency. BIA’s fiscal year 2016 budget  included $4.5 million to form the Service Center in Lakewood, Colorado.  According to Interior’s fiscal year 2016 budget justification, the Service  Center is intended to, among other things, help expedite the leasing and  permitting processes associated with Indian energy development. Among  its accomplishments, the Service Center has (1) developed a  memorandum of understanding among BIA, BLM, ONRR, and OST  outlining the management and operation of the Service Center; (2)  developed and conducted a training course on oil and gas development  standard operating procedures for 462 Interior employees at eight  locations across the country; and (3) hired several positions, including a  Director and Deputy Director.
section_title: The Effectiveness of the Energy Subgroup and Service Center in Helping Overcome Factors Hindering Indian Energy Development May Be Limited by Several Factors
subsections: section_title: The Energy Subgroup Has Not Fully Incorporated Leading Practices for Collaboration, Which May Limit Its Effectiveness
paragraphs: The Energy Subgroup has not fully incorporated leading practices that  can help agencies enhance and sustain collaborative efforts, which may  limit its effectiveness in addressing long-standing factors that hinder  Indian energy development. Our prior work on issues that cut across  multiple agencies, as Indian energy development does, has shown that  collaborative approaches can increase the effectiveness of federal efforts.  Our prior work has also found that agencies face numerous challenges in  their efforts to collaborate. To overcome differences in agency missions,  cultures, and established ways of doing business, collaborative efforts,  such as the Energy Subgroup, can use leading practices that have been  shown to enhance and sustain these efforts. Specifically, in September  2012, we identified sustained leadership, dedicated resources and staff,  and active participation of all relevant stakeholders, among other things,  as leading practices for effective collaboration. Specific leading  practices the Energy Subgroup has not fully incorporated in its  implementation efforts following.
Sustained leadership is uncertain. DOE has not designated a career  employee of the federal government to serve as its co-chair of the Energy  Subgroup. Instead, DOE designated an appointed official to serve as the  co-chair, and that individual  may not remain in the position with the  upcoming presidential transition. According to agency officials, their focus  has been to complete more time-sensitive tasks, and selecting a long- term co-chair has not been a priority. Similarly, Interior originally  designated an appointed official to serve as its co-chair of the Energy  Subgroup, but in August 2016 Interior designated a senior-level career  employee of the federal government to serve as co-chair, according to  Interior officials. Interior officials also cited higher priorities as a reason for  not identifying  a career employee sooner, but these officials told us that  the upcoming presidential transition increased the urgency to identify a  long-term leader. The Executive Order establishing the Council allows for  senior-level officials to perform Council duties, which may include either  appointed or career employees. Our prior work has shown that turnover  of political leadership in the federal government has often made it difficult  to sustain attention to complete needed changes. Our prior work has  also shown that transitions and frequent changes in leadership weakened  the effectiveness of a collaborative effort and that a lack of leadership  further challenges an organization’s ability to function effectively and to  sustain focus on key initiatives. Designating a senior-level career  employee to lead the Subgroup can provide some assurance that  leadership will remain consistent beyond this administration.
Collaborating agencies dedicated few resources and have not  identified additional resources needed. Federal agencies have  dedicated few staff and financial resources to the Energy Subgroup, have  not identified the resources needed to accomplish its goals, and do not  have an agreed-upon funding model. Our prior work has shown that  collaborating mechanisms should identify the staff and financial resources  needed to initiate and sustain their collaborative effort. According to  DOE, Interior, and USDA officials, the Energy Subgroup has been staffed  on an “other duties as assigned” basis since its creation in November  2013. These officials said that this staffing model, which was also used by  the other subgroups, makes it difficult to ensure continued participation by  each federal agency because of competing demands for staff and  resources. In 2015, more than 2 years after the Council was established,  Interior hired a fulltime Executive Director—the only dedicated Council  staff—to manage activities of the Council and all subgroups. Beyond the  Executive Director position, participating agencies have not dedicated or  identified future financial resources for the Energy Subgroup. A few  federal officials told us the effectiveness of the Subgroup in  accomplishing tasks is limited without dedicated resources. For instance,  federal officials told us that the Energy Subgroup has not developed a 5- year strategic plan because no federal entity has dedicated the resources  for key planning activities, such as a facilitated planning session that can  define and articulate common outcomes. The executive order establishing  the Council directs Interior to provide funding and support for the Council.  However, according to Interior officials, dedicating resources to the  Energy Subgroup would take away from other programs and services that  directly support tribes and their activities.
Without dedicated resources, key activities completed to date are  generally the result of individual  federal agencies that voluntarily identified  and applied their own budgetary resources to specific work activities. For  example, DOE volunteered to use its own financial and information  technology resources to develop a web-based tool that provides  information about grant, loan, and technical assistance programs  available to support tribal energy projects. According to a DOE official, the  department voluntarily applied these resources because senior leadership  determined the web-based tool was an important information source that  could help tribes to identify federal financial assistance.
Our prior work has shown it is important for collaborative mechanisms to  identify and leverage sufficient funding to accomplish their objectives and  that funding models can vary. In some instances, specific congressional  authority or dedicated funding from Congress may be used for the  interagency funding for collaborative mechanisms. In other instances, we  found a collaborative mechanism can be supported by all participating  agencies contributing funds as well as in-kind support. Identifying  resources needed to accomplish its goals and establishing a funding  model agreed upon by participating agencies may provide opportunities  for the Energy Subgroup. If the Energy Subgroup does not identify  resources and a funding model, it is unclear to what extent the Energy  Subgroup’s collaborative efforts can be effectively sustained to  accomplish its stated policy goals.
The Energy Subgroup has not documented how participating  agencies will collaborate. Our prior work found that agencies that  articulate their agreements in formal documents strengthen their  commitment to working collaboratively. A formal written agreement that  includes goals, actions, responsible agencies, and time frames may be a  tool to enhance and sustain collaboration. According to federal officials,  the Energy Subgroup did not develop formal documentation because  developing such documentation would have taken time and resources  away from completing work deliverables. However, the lack of a formal  agreement may have limited collaboration and involvement of some  participating agencies. For example, federal officials told us that  numerous Energy Subgroup agencies were actively involved in the effort  to develop the web-based tool mentioned above but that after its  completion there has been less collaboration between the various federal  because there was no longer a clear reason to work together. The  Council, including the Energy Subgroup, was established to improve  efficiencies by coordinating work across the federal government and  using an “all-of-government approach” to find solutions that address tribal  needs. However, most of the activities completed to date have been the  result of collaboration between only IE and IEED—the only two agencies  focused exclusively on Indian energy and also the only two that have a  documented agreement to collaborate. The achievements of the  Subgroup do not reflect the efforts of the other nine federal agencies that  are its members. Without documenting how all members in the Subgroup  are expected to collaborate, it is unclear how participating agencies will  organize their individual and joint activities to address the factors that  hinder Indian energy development.
section_title: BIA Did Not Fully Incorporate Leading Practices or Adhere to Agency Guidance in Forming the Service Center, Which May Limit Its Potential to Overcome Factors That Hinder Indian Energy Development
paragraphs: BIA, the lead agency responsible for forming the Service Center, did not  follow some leading practices or adhere to agency guidance during early  stages of developing the Service Center—which may impact its  effectiveness in helping overcome the factors that have hindered Indian  energy development. An interagency plan created in response to  Executive Order 13604, Interior’s Departmental Manual, and our prior  work offer leading practices that have been shown to enhance the  effectiveness of collaborative efforts, improve permitting, and increase the  likelihood of success for organizational change. These practices include  (1) creation of a lead agency or single point of contact to coordinate  regulatory responsibilities by multiple agencies, (2) involvement by and  active participation with all relevant stakeholders, and (3) clear  identification and documentation of the rationale of key decisions. Specific  leading practices that BIA did not fully incorporate when implementing the  Service Center follow.
The Service Center has not been formed as a center point of  collaboration for all regulatory agencies involved with energy  development. In June 2015, we reported that the added complexity of  the federal process, which can include multiple regulatory agencies,  prevents many developers from pursuing Indian energy resources for  development. Interior has recognized the need for collaboration in the  regulatory process and described the Service Center as a center point of  collaboration for permitting that will break down barriers between federal  agencies. In addition, the memorandum of understanding establishing  the Service Center states that it will serve as a center point for  collaboration with other federal departments for expediting oil and gas  development and as a point of contact for other agencies to resolve  development issues. The Service Center may increase collaboration  between BIA and BLM on some permitting requirements associated with  oil and gas development. This is because, according to BIA officials, only  entities that participate in the Indian Energy and Minerals Steering Committee—BIA, BLM, ONRR, and OST—were included in the Service  Center. According to BIA officials, no other federal agencies were  included because of concerns that including them would delay  establishing the Service Center. BIA has neither included a regulatory  agency within Interior, FWS, as a partner in the Service Center nor  identified opportunities to incorporate other regulatory agencies outside of  Interior, such as EPA, USDA, and the Army Corps of Engineers, as  partners. As a result, the Service Center has not been formed as the  center point to collaborate with all federal regulatory partners generally  involved with energy development nor is it a single point of contact for  permitting requirements. According to a tribal chairman, issues raised by  FWS often create significant delays in permit approvals, and Interior’s  failure to include FWS as part of the Service Center is a great error.  Similarly, we reported in June 2015 that delays in the regulatory review  and approval process can result in lost revenue and missed development  opportunities.
Our prior work has shown that having a lead agency for permitting is a  management practice that helps increase efficiencies for the permitting  process. In addition, the Quadrennial Energy Review Task Force  recommended that, when possible, federal agencies should co-locate  dedicated cross-disciplinary energy infrastructure teams that consist of  environmental review and permitting staff from multiple federal  agencies. By not serving as a central point of contact or lead agency,  the Service Center will be limited in its ability to improve efficiencies in the  federal regulatory process to only those activities that can benefit from  increased coordination between BIA and BLM.
BIA did not involve key stakeholders in the development of the  Service Center. Interior’s fiscal year 2016 budget justification stated that  BIA was working with DOE to develop and implement the Service Center  and leverage and coordinate with DOE-funded programs to provide a full  suite of energy development-related services to tribes. Further, BIA  guidance states that it will seek the participation of agencies with special  expertise regarding proposed actions. However, BIA did not include  DOE in a participatory, advisory, or oversight role in the development of  the Service Center. Further, although IEED developed the initial concept  and proposal for the Service Center, BIA did not include IEED in the  memorandum of understanding establishing the Service Center. Our prior  work has shown that involvement by all relevant stakeholders improves  the likelihood  of success of interagency collaboration. DOE and IEED  possess significant energy expertise. By excluding these agencies from  the development and implementation of the Service Center effort, BIA has  missed an opportunity to incorporate their expertise into its efforts.
Moreover, BIA did not effectively involve employees to obtain their ideas  and gain their ownership for the transformation associated with  development of the Service Center—a leading practice for effective  organizational change. Most of the BIA agency officials we met with told  us they were not aware of implementation plans for the Service Center or  its intended purpose. BIA identified its agency offices as the primary  customers of the Service Center, yet BIA did not request their ideas or  thoughts or identify potential employee concerns. Several BIA and tribal  officials said they are concerned that the creation of a new office (the  Service Center) may add another layer of bureaucracy to the process of  reviewing and approving energy-related documents. We have previously  reported that, as a leading practice, successful change initiatives include  employee involvement to help create the opportunity to increase  employees’ understanding and acceptance of organizational goals and  objectives, and gain ownership for the changes that are occurring in the organization. Such involvement strengthens the transformation process  by allowing employees to share their experiences and shape policies.  By not involving its employees in the development of the Service Center,  BIA is missing an important opportunity to ensure the success of the  changes that it hopes to achieve.
BIA did not document its basis for key decisions. The process BIA  followed to develop the Service Center and the basis for key decisions it  made are unclear because BIA did not document the rationale for key  management decisions or the alternatives considered. According to  Interior’s Departmental Manual, agencies that propose a new office are to  document the rationale for selecting the proposed organizational structure  and to consider whether the new office contributes to fragmentation of the  organization. Our prior work has shown that effective organizational  change is based on a clearly presented business-case or cost-benefit  analysis and grounded in accurate and reliable data, both of which can  show stakeholders why a particular initiative  and alternatives are being  considered. BIA officials said they did not document the basis for key  decisions because they were not aware of the requirement. In addition, a  few Interior officials said that BIA did not present alternatives to the full  Indian Energy and Minerals Steering Committee, even though it was  making decisions about the structure and placement of the Service  Center. Without documentation to justify the rationale behind key  management decisions, it is unclear if the Service Center, as currently  designed, is the best way to address the identified problem. Further,  several tribal organizations and tribal leaders made recommendations  related to the creation of the Service Center that are not currently  reflected in BIA’s implementation of the Service Center. For example, the  Coalition of Large Tribes Resolution calls for the Service Center to be the  central location for permit review and approval support for Indian  energy  development. Without documentation of alternatives considered or key  management decisions, it is unclear whether these requests were  appropriately considered. Our prior work has shown that fixing the wrong  problems, or even worse, fixing the right problems poorly, could cause  more harm than good.
section_title: BIA Has Not Incorporated Key Workforce Management Practices
paragraphs: In June 2015, we reported that BIA’s long-standing workforce challenges,  such as inadequate staff resources and staff at some offices without the  skills needed to effectively review energy-related documents, were also  factors hindering Indian energy development. In this review, we found  that BIA also has high vacancy rates at some agency offices, and it has  not conducted key workforce planning activities that may be further  contributing to its long-standing workforce challenges. Federal internal  control standards, Office of Personnel Management standards, and our  prior work identify standards or leading practices for effective workforce  management. The standards and leading practices include the following:  (1) possessing and maintaining staff with a level of competence that  allows them to accomplish their assigned duties; (2) identifying the key  skills and competencies the workforce needs to achieve current and  future agency goals and missions, assessing any skills gaps, and  monitoring progress towards addressing gaps; and (3) conducting  resource planning to determine the appropriate geographic and  organizational deployment to support goals and strategies. BIA has not  taken steps to provide reasonable assurance it has staff with the skills  needed to accomplish their assigned duties and has not conducted  workforce planning activities consistent with these standards and leading  practices.
Some BIA offices have high vacancy rates and may not have staff  with the level of competence that allows them to review some  energy development documents. We found that some BIA offices have  high vacancy rates for key energy development positions, and some  offices reported not having staff with key skills to review energy-related  documents. For example, according to data we collected from 17 BIA  agency offices between November 2015 and January 2016, vacancy  rates ranged from less than 1 percent to 69 percent in those offices.  Vacancy rates for the realty position—a key position to process leases  and other energy-related documents—ranged from no vacancies in five  offices to 55 percent in one office. In some cases, these vacancies have  been long-standing. For example, at the BIA Uintah and Ouray Agency,  located in Utah, two of the six vacant realty positions have been vacant  since September 2014. According to BIA officials, the high vacancy rates  can be generally attributed to a number of factors, including: employee  early-out and buy-out retirements in 2013, difficulties hiring qualified staff  to work in geographically remote locations, and staff transfers to other  positions. For example, several realty positions in BIA agency offices  were vacated because staff transferred to positions in BIA’s Land Buy- Back Program. According to BIA officials, as of May 2016, the Land  Buy-Back Program had hired 15 realty staff, 12 whom were from BIA  regions and agency offices.
In addition to high vacancy rates at some offices, some BIA agency and  regional offices may lack the expertise needed to review and approve  energy-related documents. For example, BIA agency officials in an area  where tribes are considering developing wind farms told us that they  would not feel comfortable approving proposed wind leases because their  staff do not have the expertise to review such proposals. Consequently,  these officials told us that they would send a proposed wind lease to  higher ranking officials in the regional office for review. Similarly, an  official from the regional office stated that it does not have the required  expertise and would forward such a proposal to senior officials in  Interior’s Office of the Solicitor. The Director of BIA told us that BIA  agency offices generally do not have the expertise to help tribes with  solar and wind development because it is rare that such skills are  needed. In another example, a BIA agency office identified the need for a  petroleum engineer to conduct technical reviews of oil and gas  documents in a timely manner. However, the office has been unable to  hire a petroleum engineer because it cannot compete with private  industry salaries. According to BIA officials, additional staff resources and  key skills related to energy development will be provided through the  Service Center, once it is fully implemented.
BIA has not identified key skills needed or skill gaps. The extent to  which BIA does not have key skills throughout the bureau is unknown  because BIA has not identified the key skills it needs and the extent to  which it has skill gaps. BIA officials said that a skill gap assessment is not  needed at this time because of the additional staff being hired through the  Service Center. However, without key information on its workforce, as  called for by Office of Personnel Management standards and our prior  work, the agency risks hiring personnel that do not fill critical gaps, and  the extent to which the Service Center will be able to address these gaps  is unknown at this time. A BIA official also told us that in August 2015, the  Assistant Secretary for Indian Affairs contracted with a consultant to  develop a strategic workforce plan for BIA and the Bureau of Indian  Education. However, according to a BIA official, the Bureau of Indian  Education and BIA management are the primary focus of the work, and  the resulting plan will not include agency offices, the level at which tribes  generally interact with BIA for energy-related activities.
BIA does not have a documented process to provide reasonable  assurance that workforce resources are appropriately deployed in  the organization and align with goals. According to several BIA and  tribal officials, the workforce composition of agency offices is not regularly  reviewed to provide reasonable assurance it is consistent with BIA’s  mission and individual  tribes’ priorities and goals. BIA officials said that an  agency office’s workforce composition is routinely carried over from year  to year, and positions are filled based on the budget, without  consideration of existing workload needs or current tribal and agency  priorities. A BIA official told us that this practice can result in a surplus of  staff in some departments and staff shortages in others. In some of our  meetings with BIA agency and tribal officials, we were told that BIA  agency offices are not aware of tribal priorities, in part, because of poor  relations between BIA agency offices and tribal leadership. Officials from  one tribe said that because of concerns that BIA was not routinely  seeking tribal input on priorities and goals, the tribe created a position to  serve as a liaison between the BIA and tribal leadership. Among other  things, the liaison routinely meets with both tribal leaders and BIA officials  to ensure BIA is aware of tribal priorities and goals.
Without current workforce information on key skills needed for energy  development, tribal goals and priorities, and potential workforce resource  gaps, BIA may not have the right people with the right skills doing the  right jobs in the right place at the right time and cannot provide decision  makers with information on its staffing needs going forward.
section_title: DOE Developed Guidance for Giving Preference to Tribes When It Purchases Power, but Government-Wide Guidance Does Not Exist
paragraphs: In 2012 and 2013 respectively, DOE issued policy guidance and  procurement guidance to give preference to tribes when DOE facilities  contract to purchase renewable energy products or by- products,  including electricity, energy sources, and renewable energy credits, but  this guidance applies only to DOE, and GSA has not issued government- wide guidance. The purchase preference provision in the Energy Policy  Act of 2005 authorizes federal agencies to give preference to a tribe or  tribal enterprise when purchasing electricity or any other energy or energy  by-product as long as federal agencies do not pay more than the  prevailing market prices or obtain less than prevailing market terms and  conditions. According to DOE documentation, several tribes had  approached federal agencies to negotiate the sale of electricity from tribal  renewable energy generation facilities, but negotiations had not resulted  in federal purchases for a variety of reasons, including a lack of policy  support and implementing guidance for the tribal preference provision. In  response, DOE developed a policy to better enable the department to use  the tribal preference provision. Under DOE’s policy statement and  procurement guidance, DOE facilities can use a purchase preference  when a tribal nation holds a majority ownership position in a renewable  energy project, provided that the agency does not pay more than the  prevailing market price or obtain less than prevailing market terms and  conditions. The guidance provides for limiting competition to qualified  Indian tribes and tribal majority-owned organizations for the purchase of  renewable energy, renewable energy products, and renewable energy by- products.
In contrast, GSA, the federal entity with general statutory authority to  enter into utility service contracts of up to 10 years for all federal  agencies, has not developed implementing guidance for the tribal  preference provision contained in the Energy Policy Act of 2005,  according to GSA officials. During our review, we identified one instance  in which a tribe owned a majority position in a renewable energy project  and submitted a bid in response to a GSA solicitation for energy. In this  instance, GSA officials told us that they did not apply the tribal preference  provision because GSA lacked implementing guidance. In addition, GSA  officials said that the existence of the tribal preference provision and  corresponding lack of implementing guidance created uncertainty and  increased the time and costs associated with the solicitation review  process. GSA officials also told us that they do not need to issue separate  tribal preference provision guidance because DOE’s guidance is  comprehensive. However, the DOE guidance is intended only for DOE,  and GSA has not adopted the guidance for any GSA purchases of energy  products. Without GSA guidance on the tribal preference provision—even  if that guidance mirrors DOE’s guidance— it is unclear if GSA’s  procurement officials will have the information they need to apply the  preference to its purchases.
We discussed our findings with members of the FAR Council, which is the  regulatory body established to lead, direct, and coordinate government- wide procurement guidance and regulations in the federal government.  According to officials, in response to our finding, the FAR Council plans to  revisit the tribal preference provisions and survey agencies to seek their  input on whether government-wide guidance to implement the preference  should be included in the FAR. Officials said the FAR Council will  consider agencies’ input and determine if it should issue regulations  implementing the preference authority. Additionally,  the officials told us  the FAR Council will examine DOE’s guidance in this area, as well as  GSA’s plans to make other agencies aware of this preference and the  DOE guidance in all future delegations for renewable energies.
section_title: Stakeholders Identified Additional Actions That Could Overcome Some Factors Hindering Development
paragraphs: Numerous federal agencies offer programs that could be used to assist  tribes with energy development activities. However, a few stakeholders  said impediments may limit or restrict tribal participation in some of these  programs. Federal agencies could identify and seek to remove regulatory,  statutory, and procedural impediments that limit or restrict tribal  participation. For example, according to a 2016 DOE report, DOE’s Title  XVII  loan program provides loan guarantees to accelerate the  development of innovative  clean-energy technology and has more than  $24 billion in remaining loan authority to help finance clean-energy  projects. However, according to DOE officials, no tribes have applied to  DOE’s Title XVII  loan program because various program requirements  discourage tribal participation. For instance, according to officials, DOE  considers whether applicants have prior experience and knowledge to  execute the kind of project for which they are seeking a DOE loan  guarantee. The officials told us that because tribes have not had  significant development opportunities that would provide prior experience,  this consideration limits tribes’ abilities to compete with other applicants  seeking limited resources.
A few stakeholders also told us that extensive time and monetary  resources are required to apply for assistance from some federal  programs, making it difficult for some tribes to seek assistance. For  example, DOE requires an application fee of $50,000 for its Title XVII  loan program. According to DOE officials, high application fees  discourage some tribes from applying. Two other stakeholders told us  that tribes and tribal entities dedicate significant financial resources and  time to complete grant applications for federal programs. Because of this  extensive resource commitment, combined with the low probability of  receiving assistance, a few stakeholders said they are reluctant to seek  federal assistance in the future.
Several stakeholders said the typical size of awards from IEED limit the  type of projects that benefit from assistance. Projects that require  significant funds are generally not awarded because officials want to fund  numerous projects, according to Interior officials. For instance, according  to a 2015 Interior report, a tribe requested $321,000 from IEED to drill a  geothermal well, but the request was rejected because of the expense  relative to funds available. DOE and Interior officials told us they receive  significantly more requests for assistance with viable projects than they  can fund within existing budget levels. For instance, in 2015, IEED  received 22 requests for assistance through its Tribal Energy  Development Capacity Program and was able to fund 10 projects,  according to IEED officials. In 2014, IEED received requests for $27.5  million in assistance through its Energy and Mineral Development  Program and was able to award $9.5 million.
section_title: Conclusions
paragraphs: Recognizing the importance of a collaborative federal approach to help  Indian tribes achieve their energy goals and to more efficiently fulfill  regulatory responsibilities and manage some Indian energy resources,  the President and Interior undertook two key initiatives, in the form of the  Energy Subgroup and the Service Center. However, to be effective these  initiatives rely on collaboration among federal agencies and programs,  which can be difficult to achieve. Leading practices can help agencies  enhance and sustain their collaborative efforts; however, federal agencies  involved in both of these efforts have not incorporated some of these  practices. The Energy Subgroup has not identified the resources it needs  to achieve its goals or a funding model, and the roles of each partnering  agency have not been identified and documented. In addition, BIA, in  leading the creation of the Service Center, has not established a single  point of contact or lead agency for regulatory activities; has not sought or  fully considered input from key stakeholders, such as BIA agency office  employees; and has not documented the rationale for key decisions. By  following leading collaborative practices, both the Energy Subgroup and  the Service Center have the potential to more effectively assist tribes in  overcoming the factors that hinder Indian energy development.
In addition, through the Service Center, BIA plans to hire numerous new  staff over the next 2 years, which could resolve some of the long-standing  workforce challenges that have hindered Indian energy development.  However, BIA is hiring new staff without incorporating effective workforce  planning principles. Specifically, BIA has not assessed key skills needed  to fulfill its responsibilities related to energy development or identified skill  gaps, and does not have a documented process to provide reasonable  assurance its workforce composition at agency offices is consistent with  its mission, goals, and tribal priorities. As a result, BIA cannot provide  reasonable assurance it has the right people in place with the right skills  to effectively meet its responsibilities or whether new staff will fill skill  gaps.
The Energy Policy Act of 2005 authorization of a preference for tribal  entities has the potential to increase tribal access to the largest single  purchaser of energy in the United States—the federal government.  However, GSA—the primary entity responsible for purchasing power for  the federal government—has not developed guidance to implement the  authority to provide a tribal preference government-wide. By developing  such guidance, GSA would help ensure that contracting officials are  aware of when the authority for a tribal preference is applicable and how it  should be applied to future purchases of electricity and energy products.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretary of Energy, the Secretary of the  Interior, and the Administrator of the General Services Administration, as  appropriate, take the following 10 actions.
We recommend that the Secretary of Energy designate a career  senior-level federal government employee to serve as co-chair of the  White House Council on Native American Affairs’ Energy Subgroup.
We recommend that the Secretary of the Interior, as Chair of the  White House Council on Native American Affairs, direct the co-chairs  of the Council’s Energy Subgroup to take the following two actions:  (1) Identify appropriate resources needed for the Subgroup to  accomplish its goals, as well as a funding model.  (2) Establish formal agreements with all agencies identified for  inclusion in the Subgroup to encourage participation.
We recommend that the Secretary of the Interior direct the Director of  the Bureau of Indian Affairs to take the following six actions:  (1) Include the other regulatory agencies in the Service Center, such  as FWS, EPA, and the Army Corps of Engineers, so that the  Service Center can act as a single point of contact or a lead  agency to coordinate and navigate the regulatory process.  (2) Establish formal agreements with IEED and DOE that identify, at a  minimum, the advisory or support role of each office.  (3) Establish a documented process for seeking and obtaining input  from key stakeholders, such as BIA employees, on the Service  Center activities.  (4) Document the rationale for key decisions related to the  establishment of the Service Center, such as alternatives and  tribal requests that were considered.  (5) Incorporate effective workforce planning standards by assessing  critical skills and competencies needed to fulfill BIA’s  responsibilities related to energy development and by identifying  potential gaps.  (6) Establish a documented process for assessing BIA’s workforce  composition at agency offices taking into account BIA’s mission,  goals, and tribal priorities.
We recommend that the Administrator of the General Services  Administration develop implementing guidance to clarify how  contracting officials should implement and apply the statutory  authority to provide a tribal preference to future acquisitions of energy  products.
section_title: Agency Comments
paragraphs: We provided a draft of this report for review and comment to the  Secretary of the Interior, the Secretary of Energy, and the Administrator of  the General Services Administration. All three agencies provided written  comments. Interior agreed with all 8 recommendations directed to the  agency and described some actions it intends to take. Interior’s  comments are reprinted in appendix I. DOE agreed with the 1  recommendation directed to the agency and provided technical  comments. DOE’s comments are reprinted in appendix II.  GSA also  agreed with the 1 recommendation directed to the agency and described  the actions it intends to take. GSA’s comments are reprinted in appendix  III.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 7 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretaries of the Interior and Energy, the  Administrator of the General Services Administration, and other interested  parties. In addition, the report will be available at no charge on the GAO  website at http://www.gao.gov.
If you or your staff 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 major contributions to this report  are listed in appendix IV.
section_title: Appendix I: Comments from the Department of the Interior
section_title: Appendix II: Comments from the Department of Energy
section_title: Appendix III: Comments from the General Services Administration
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Christine Kehr (Assistant  Director), Patrick Bernard, Richard Burkard, Patricia Chen, Cindy Gilbert,  Alison O’Neill, Daniel Purdy, and Jay Spaan made key contributions to  this report.