Renewable Energy: BLM Has Limited Assurance That Wind and Solar Projects Are Adequately Bonded
Published: 2015-06-24T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Renewable energy projects can affect thousands of acres of federal land and involve significant infrastructure. BLM directs renewable energy developers to obtain bonds to cover the costs of returning the land to its pre-developed condition when the project terminates, a process called reclamation. Reclamation can cost millions and take years to complete.
This testimony addresses (1) BLM’s policies for the bonding of wind and solar projects on federal land; (2) the amount and types of bonds held by BLM for the reclamation of these projects, and how BLM tracks the bonds; and (3) the extent to which BLM ensures that bonds for wind and solar rights-of-way are adequate to cover reclamation costs. It is based on a June 2014 report, for which GAO conducted a file review of all 45 wind and solar development project rights-of-way with a bond as of April 15, 2014; analyzed data from BLM data systems; reviewed relevant federal laws, regulations, and BLM policies and procedures; and interviewed agency officials.
section_title: What GAO Found
paragraphs: The Department of the Interior’s Bureau of Land Management (BLM) has different policies for the bonding of wind and solar projects on federal land. For example, BLM’s 2008 wind policy established minimum bond amounts, but BLM’s 2010 solar policy set no minimum. However, the agency has issued a proposed rule that would establish consistent requirements for the bonding of the two types of projects in several areas, including minimum bond amounts.
BLM has about $100 million in bonds for the reclamation of wind and solar projects on federal land. These bonds are primarily letters of credit and surety bonds. BLM has two data systems for tracking bonds, but GAO found that neither system is reliable for this purpose. Specifically, GAO found instances in both systems where information was missing or inaccurate, or had not been updated. Further, the agency does not have a timeliness standard for wind and solar data entry, contrary to having such a standard for its mining program. Without accurate or complete information, BLM has limited assurance that its data systems are reliable for tracking wind and solar bonds to ensure that bonding policies are being followed and that projects have the required bonds.
BLM has limited assurance that bonds for wind and solar rights-of-way will cover reclamation costs, leaving the federal government potentially at financial risk if developers do not complete reclamation. GAO found about one-third of the wind and solar rights-of-way were underbonded by as much as $15 million in total. Also, BLM did not clearly document how it made its bond decisions, contrary to government standards that call for documentation of significant events. Specifically, GAO found that for about two-thirds of the wind rights-of-way, there was little or no documentation to support the bond amount. In addition, BLM does not adequately ensure that wind and solar bond instruments are properly secured, handled, and stored and does not have policies related to this. In one BLM field office, a staff member told GAO that someone mistakenly shredded several bonds. BLM also does not consistently adhere to its policies calling for periodic review of wind and solar bond amounts to verify their adequacy. GAO found about half of the bonds were at least 4 months overdue for review. BLM officials acknowledged that automatic notifications could be established in their data system as to when reviews are due. Without policies to document decisions and properly secure bonds, and steps to ensure bond adequacy reviews, BLM has limited assurance that bonds in place will be adequate to cover reclamation.
section_title: What GAO Recommends
paragraphs: In its June 2014 report, GAO recommended, among other things, that BLM develop policies on documenting bonding decisions, the proper handling and storage of bonds, and timely data entry. GAO also recommends that BLM take steps to ensure projects are periodically reviewed to ensure bond adequacy. Interior generally concurred with GAO’s recommendations.

section_title: Letter
paragraphs: I am pleased to be here today to discuss our June 2015 report on the  Bureau of Land Management’s (BLM) policies and practices for bonding  renewable energy development on federal land, which was released June  23, 2015. The Department of the Interior’s (Interior) BLM manages more  federal land than any other agency—more than 245 million surface  acres—and this land is increasingly being tapped to meet the nation’s  growing demand for energy. BLM plays a key role in managing energy  produced on these lands, including energy from renewable resources.  Through the Energy Policy Act of 2005, Congress encouraged the  Secretary of the Interior to approve non-hydropower renewable energy  projects, including wind and solar projects, with a total capacity to  generate at least 10,000 megawatts of electricity on federal lands by  2015. In June 2013, the President proposed an expansion in renewable  energy construction projects and set a new goal for Interior to approve a  renewable energy capacity of at least 20,000 megawatts of electricity  from projects on federal land, which would be enough capacity to power  more than 6 million homes by 2020. Currently, about 1 percent of the  nation’s electricity generated from wind and solar energy comes from  resources on federal land.
Projects to produce energy from renewable resources can affect  thousands of acres of federal land and involve significant infrastructure.  The projects may require developers to alter the land’s topography or  remove vegetation, physically or through the use of herbicides, and these  actions may affect the site itself or have potential downstream or off-site  effects. As a condition of BLM’s authorization for renewable energy  projects, the developer must agree to remove infrastructure elements and  return the land to its predeveloped condition when the project terminates,  a process called reclamation. To ensure compliance with applicable  requirements, including requirements to reclaim project sites, BLM  requires operators of wind and solar energy projects on federal lands to  obtain bonds. If an operator fails to return the land to its predeveloped  state, the bond can be used to cover any reclamation costs the federal  government may incur. If the bonds are inadequate to cover reclamation  costs and the federal government is unable to recover additional costs  from the developer, the federal government may have to pay the  reclamation costs.
Wind and solar projects on BLM land are subject to federal laws and  regulations, as well as BLM policy. The Federal Land Policy and  Management Act of 1976 authorizes BLM to issue rights-of-way on  federal land for a variety of purposes, including systems for generating,  transmitting, and distributing electric energy. Right-of-way holders are  required to restore, revegetate, and stabilize the land disturbed by wind  and solar projects within a reasonable time, to a condition satisfactory to  BLM, as approved by BLM in its Plan of Development. For projects that  may have a significant impact on the environment, the act requires  applicants to submit a plan of construction, operation, and rehabilitation  for the right-of-way that complies with applicable laws and regulations and  the agency’s stipulations. Federal regulations authorize BLM to require a  right-of-way holder to provide a bond to secure the obligations imposed  by the right-of-way. According to BLM policy, a bond is required for each  wind and solar facility on federal land. BLM may require an increase or  decrease in the value of an existing bond at any time during the term of  the right-of-way, according to federal regulations.
BLM manages and oversees wind and solar projects in part by  maintaining data on each project electronically in two data systems—the  Legacy Rehost 2000 System (LR2000) and the Bond and Surety System.  LR2000 is BLM’s electronic case recordation system that is used to  capture information on the agency’s land and mineral projects. In the  case of wind and solar projects, BLM captures information such as the  date the right-of-way was issued, acres authorized, project location, case  status (e.g., authorized, expired, or closed), and the actions that have  taken place. The system also contains bond information for wind and  solar projects, including bond numbers, amounts, and bond actions, such  as the date when a bond was filed, accepted, or returned. For wind  projects, LR2000 contains the number of authorized turbines and towers.  The Bond and Surety System contains bond information, such as the type  and amount of bond, as well as actions taken, including the date when a   BLM staff enter data about wind  bond was filed, accepted, or returned.and solar projects into LR2000, as well as information about bonds into  the Bond and Surety System.
My testimony today highlights the key findings of our June 2015 report on  BLM’s policies and practices for bonding renewable energy development  on federal land. Accordingly, this testimony discusses (1) BLM’s policies  for the bonding of wind and solar projects on federal land; (2) the amount  and types of bonds held by BLM for the reclamation of wind and solar  projects, and how BLM tracks these bonds; and (3) the extent to which  BLM ensures that bonds for wind and solar rights-of-way are adequate to  cover reclamation costs.
To address these objectives, we reviewed the agency’s policies regarding  bonding, the reclamation activities that the bonds are to cover, and the  frequency with which bonds are to be reviewed. We also reviewed BLM’s  Notice of Proposed Rulemaking—issued in September 2014—that would  revise and codify the agency’s current bonding policies for wind and solar  projects. In addition, we obtained wind and solar project data, as of April  15, 2014, from BLM’s LR2000 and its Bond and Surety System. We  worked with BLM officials to resolve data discrepancies between the two  systems and then analyzed the data to identify the bond amounts and  types for each right-of-way. To determine how BLM tracks these bonds  and understand how LR2000 and the Bond and Surety System are used,  the frequency of updates, and the reliability of the data in each system,  we interviewed officials in BLM headquarters and all 9 BLM state and 11  field offices with wind or solar energy development projects.
To determine the extent to which BLM ensures that bonds for wind and  solar rights-of-way are adequate to cover reclamation costs, we  conducted an in-depth file review of all wind and solar energy  development projects—45 in total—for which BLM held a bond on April  15, 2014, and interviewed BLM officials and other stakeholders. We  compared the bond held with what is specified in BLM’s wind and solar  policies, as well as reclamation cost estimates in the project files, and we  then determined the extent to which documentation of the bond decision  is consistent with government standards for internal control. We also  interviewed BLM officials to determine compliance with existing BLM  policies, the depth and detail of reclamation cost estimates, the extent of  documentation supporting bond amounts, and the types of staff involved  in determining bond amounts. In addition, we analyzed whether BLM was  conducting reviews to ensure that bonds are in place, as is called for in  BLM policies. Our June 2015 report includes a detailed explanation of the  methods used to conduct our work. The work on which this testimony is  based was performed 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: BLM Has Different Policies for Bonding Wind and Solar Projects, but a Proposed Rule Would Establish Consistent Requirements
paragraphs: As detailed in our report, in 2008, BLM issued a wind energy  development policy that includes provisions for bonding wind energy  projects on federal land. Among other things, the policy established a  minimum bond amount of $2,000 per meteorological tower for site- specific and project area testing rights-of-way and $10,000 per wind  turbine for wind energy development rights-of-way. BLM is to determine  the bond amount for all wind energy development projects during the  right-of-way authorization process “on the basis of site-specific and  project-specific factors,” but the policy provides no further details on these  factors or how to calculate the costs. BLM is to review all bonds for wind  development rights-of-way at least once every 5 years to ensure that the  bond amount is adequate.
In 2010, BLM issued a solar energy development policy that includes  provisions for bonding solar energy projects on federal land that differ  from the bonding provisions of the wind policy. Specifically, in contrast  to the wind policy, the solar policy sets no minimum bond amount for  solar energy development rights-of-way.BLM is to base the bond amount on a reclamation cost estimate provided  by the right-of-way applicant that consists of three components: (1)  environmental liabilities; (2) decommissioning, removal, and disposal of  improvements and facilities; and (3) reclamation, revegetation,  restoration, and soil stabilization. A reclamation cost estimate is an   Rather, the policy states that  estimate of what it would cost a third party to reclaim the site.states that the applicant is to submit the estimate as part of the  decommissioning and site reclamation plan—which defines the  reclamation, revegetation, restoration, and soil stabilization requirements  for the project area—and the overall Plan of Development. In addition, in  contrast to the wind policy, BLM staff are to review annually all bonds for  solar development rights-of-way to ensure that the bond amount is  adequate to ensure compliance with the right-of-way authorization,  including requirements to reclaim the disturbed land.
To help ensure compliance with provisions of the wind and solar bonding  policies, BLM has two additional policies that direct BLM state directors to  certify annually that all wind and solar energy rights-of-way within their  respective states have the required bonds and that the bond data are  entered into the Bond and Surety System. assess whether the amount of the bond would be sufficient to cover  expected reclamation costs. Rather, the annual certification is intended to  ensure that a bond has been provided or requested for each wind and  solar right-of-way. The certification is to be submitted to BLM  headquarters within 30 days after the end of the fiscal year. In addition,  field office staff are to enter all bonds received for renewable energy  projects into LR2000 and the Bonds and Surety System.
See Bureau of Land Management, IM 2011-096, Certification of Bonding—Wind Energy  Site Testing and Wind Energy Development Authorizations (Apr. 7, 2011), and IM 2013- 034, Oversight and Implementation Plan—Renewable Energy Coordination Office (Dec.  20, 2012).
Competitive Processes, Terms, and Conditions for Leasing Public Lands for Solar and  Wind Energy Development and Technical Changes and Corrections, 79 Fed. Reg. 59,022  (Sept. 30, 2014) (to be codified at 43 C.F.R. pts. 2800 and 2880). projects were located in certain preferred areas—called designated  leasing areas.
Projects outside designated leasing areas. The proposed rule  would establish a minimum bond amount per turbine of $20,000 for  wind energy development projects—a doubling of the minimum  amount currently set in BLM policy—and establish a minimum bond  amount of $10,000 per acre for solar energy development projects.  The minimum bond amount for wind energy site-specific or project  area testing projects would remain at the amount currently set in BLM  policy, that is, $2000 per meteorological tower. The proposed rule  would require both wind and solar right-of-way applicants to submit a  reclamation cost estimate to help BLM to determine the bond amount,  and it would outline specific bond components that must be  addressed when determining the estimated costs. The proposed rule  would not require BLM to conduct periodic reviews to assess whether  the bonds remain adequate to cover potential reclamation costs, as is  specified in the current wind and solar policies.
Projects inside designated leasing areas. The proposed rule would  establish a standard bond amount for wind energy development of  $20,000 per turbine and $2,000 per meteorological tower, as well as a  standard bond amount for solar energy development of $10,000 per  acre. BLM proposed a standard bond amount because these areas  would be identified by BLM as areas with lesser and fewer  environmental and cultural resource conflicts. According to BLM  officials, when a project terminates inside a designated leasing area,  the agency would potentially reoffer the site for new wind or solar  energy development. As a result, these sites would require less  reclamation than if they needed to be fully reclaimed to their  predeveloped condition and the bond amount required would be  lower. Under the proposed rule, right-of-way holders would not be  required to submit a reclamation cost estimate.
A BLM official told us that the agency expects the proposed rule to be  finalized by the end of 2015. Once finalized, the official said BLM plans to  rescind the current wind and solar policies and replace them with policies  that would address, among other things, the bonding process and  adequacy reviews not covered in the proposed rule.
section_title: BLM Has About $100 Million in Bonds for Wind and Solar Projects, but the Systems for Tracking These Bonds Are Not Reliable
paragraphs: We found that BLM has about $100 million in bonds—primarily in the form  of letters of credit and surety bonds—to cover reclamation costs  associated with 12 solar rights-of-way and 108 wind rights-of-way on  federal land in nine western states, according to our analysis of BLM  data. See table 1 for further detail on the values of bond held and table 2  for further detail on the types of bonds held.
BLM tracks bonds through LR2000 and the Bond and Surety System, but  we found that neither system was reliable for this purpose. Specifically,  we found multiple instances in each system where information was  missing, inaccurate, or had not been updated as follows:
Missing information. BLM’s oversight and implementation plan for  solar and wind energy policies directs field offices to enter all bonds  received for renewable energy projects into LR2000 and the Bond and  Surety System, but we found instances where bonds had been  entered into LR2000, but not into the Bond and Surety System. We  also found instances where staff did not always enter in the remarks  section of LR2000 the number of wind turbines or meteorological  towers authorized and located on federal land, as directed by BLM’s  wind policy.
Inaccurate information. We found instances in LR2000 and the  Bond and Surety System where the type of right-of-way entered for  the project was incorrect. For example, one wind development  project’s right-of-way had been incorrectly entered in both systems as  a road right-of-way. As a result, the bond had not been included in  the annual state bond certification. When BLM reviewed the bond, the  agency determined that the bond amount was approximately $90,000  less than the minimum set by BLM’s wind policy.
Information had not been updated. We found instances where a  bond’s status or amount had not been updated in one or both  systems. In some cases, the data were several years out of date. For  example, in one case, LR2000 showed that a bond had been  accepted for $40,000 in 1994, and an additional bond for the same  right-of-way had been accepted for $160,000 in 2011, for a total bond  amount of $200,000. However, BLM had not updated the Bond and  Surety System to show that the $160,000 bond had been accepted,  and the system contained no information on the $40,000 bond.
The LR2000 data standards for BLM’s mining program state that all data  must be routinely entered within 5 business days of each action taking  place. However, there is no such standard for entering wind and solar  project data into LR2000. Furthermore, BLM has not issued data  standards for the Bond and Surety System. Because information in these  two data systems was missing, inaccurate, or out of date, BLM has  limited assurance that either system is reliable for tracking wind and solar  bonds to ensure that bonding policies are being followed and that all  projects have the required bonds.
BLM has taken some limited steps to improve its bonding data.  Specifically, to reduce potential errors or omissions in the bonding data in  LR2000 and the Bond and Surety System, BLM made changes to link  certain data in the two systems. Starting in late September 2014, when an  action code showing that a bond has been filed, accepted, or returned is  entered into the Bond and Surety System for a particular right-of-way, the  same information is automatically entered into LR2000. However, when a  bond action code is entered into LR2000, the same information must still  be entered manually into the Bond and Surety System. In addition, these  changes only apply to data entered into the Bond and Surety System  starting in September 2014, so all previously entered data will not be  added to LR2000 unless manually entered.
section_title: BLM Has Limited Assurance That Bonds for Wind and Solar Rights-of-Way Will Cover Reclamation Costs
paragraphs: BLM has limited assurance that bonds for wind and solar rights-of-way  will cover reclamation costs. Specifically, we found that 14 wind and solar  development rights-of-way were underbonded by as much as $15 million  in total. In addition, we found wide variation in how BLM staff documented  bond decisions for wind and solar project rights-of-way. Further, BLM  does not adequately ensure that wind and solar bond instruments are  properly secured, handled, and stored. BLM also inconsistently adheres  to its policies for the periodic review of the amounts of wind and solar  bonds to verify their adequacy.
Underbonding of wind and solar development projects. We found  that 14 out of 45 wind and solar development rights-of-way were  underbonded by as much as $15 million in total—approximately $5.5  million for wind rights-of-way and as much as $9 million for solar rights-of- way—according to our review of BLM project files and data.we identified 10 wind rights-of-way where the bond amount was lower  than the $10,000-per-turbine minimum established in BLM’s 2008 wind  policy. These 10 rights-of-way were underbonded by a total of   Specifically,  approximately $5.5 million. Nine of those rights-of-way were authorized  prior to the 2008 policy; however, for rights-of-way that were authorized  before the policy took effect, BLM officials told us they directed staff to  obtain bonds that meet the $10,000-per-turbine minimum. BLM officials  told us that they are in the process of obtaining bonds for these 9 rights- of-way. One right-of-way was reauthorized in 2012 at about $1,500 per  turbine. BLM’s files show that the bond amount for the right-of-way was  determined using salvage values of the equipment. While salvage values  may be considered in estimating reclamation costs, BLM officials told us  the 2008 policy does not permit salvage values to be used to reduce the  bond below the $10,000-per-turbine minimum.are currently developing a reclamation cost estimate for this right-of-way,  which will help them develop a revised bond.
BLM officials told us they  We also found four solar rights-of-way that may be underbonded by as  much as $9 million. These rights-of-way were part of a single solar project  with a total estimated reclamation cost of approximately $27.5 million. This figure includes $18.5 million for decommissioning and removal of  project structures and equipment and $9 million for revegetation and  restoration. However, the project is currently bonded at $18.5 million, an  amount that may only cover the decommissioning and removal of  structures. BLM officials explained that because the project is in  California—where recycling of materials is required—the $9 million  estimated for revegetation and restoration would be covered by the  salvage value of project structures. While the salvage value presented in  the documents we reviewed may be sufficient to cover those costs, the  project’s documentation did not indicate that BLM officials included these  costs when setting the total bond amount.
Unclear documentation of bond decisions. We found wide variation in  how BLM staff documented bond decisions for wind and solar project  rights-of-way. Specifically, for 21 of the 33 wind rights-of-way we  reviewed, there was little or no documentation to support the bond  amount. For some of these rights-of-way, there was no documentation  because BLM staff defaulted to the minimum amount set by BLM’s wind  policy without conducting any site- or project-specific analysis. For the  remaining 12 wind rights-of-way, the project files contained  documentation that BLM officials used to support their bond decisions;  however, this documentation varied widely. For example, for 1 right-of- way, the holder developed a reclamation cost estimate, but the estimate  did not reflect the current state of the project and the estimated costs  were greater than the bond that BLM required. And for 6 rights-of-way,  the documentation outlined the cost of decommissioning and removal of  structures, but it did not include cost estimates for revegetation of the  project site. We also found that BLM inconsistently documented bonding  decisions for 2 solar rights-of-way. Specifically, for 1 right-of-way, the  holder did not develop a reclamation cost estimate, as directed by BLM’s  2010 solar policy. As a result, it was not clear from the project files what  BLM considered in determining the amount of the bond that was in place.  In another case, BLM allowed the right-of-way holder to provide the bond  in phases as the project was constructed, but there was no  documentation demonstrating how each phase’s reclamation costs were  estimated, or what the payment schedule and amounts of future bonds  would be.
We also found discrepancies between information in the project files and  what was recorded in LR2000 or the Bond and Surety System in 13 of the  45 wind and solar rights-of way. For example, for 1 wind right-of-way, the  files indicated the applicant’s initial plan to build 24 turbines, but LR2000  showed the project had 20 turbines. A BLM official told us that since the  right-of-way’s original authorization in the 1980s, the type and number of  turbines had changed over time. However, there was no documentation  of these changes in the files, and the BLM official told us that, as a result  of our inquiry, he had to go and physically inspect the right-of-way to  confirm the type and number of turbines. Federal standards for internal  control call for transactions and other significant events to be clearly  documented and that the documentation should be readily available for  examination. BLM has not issued policies that direct BLM staff to document information related to bond decisions in the project files.  According to BLM officials, they will develop these policies once the  proposed rule is finalized.
Inadequate handling and storing of bonds. BLM also does not  adequately ensure that wind and solar bond instruments are properly  secured, handled, and stored. BLM staff in two field offices told us bonds  were stored in the files for the rights-of-way, rather than in a locked  cabinet or safe. In one of these offices, a staff member told us that about  20 percent of the bond instruments were stored in the project files, and  the remaining bond instruments were stored in a safe. However, in that  office, that staff member told us that someone had mistakenly shredded  the bond instruments kept in the safe because the individual did not know  what they were. According to BLM’s manual regarding records  administration, offices should ensure that appropriate internal controls  and safeguards are in place to prevent the loss of official documentation.  BLM has general guidance on records retention and storage, and at least  one office within BLM’s Energy, Minerals, and Realty Management  Directorate has detailed guidance on the acceptance, assessment, and  storage of bond instruments.Coordination Office, which oversees wind and solar energy projects, does  not have policies or guidance related to the proper handling and storage  of bond instruments. As a result, BLM cannot assure that all bonds are  properly maintained and secured, leaving the federal government  potentially at risk financially if reclamation costs are not covered by the  right-of-way holders.
However, the National Renewable Energy  Inconsistent adherence to periodic review policies. BLM  inconsistently adheres to its policies for the periodic review of wind and  solar bonds to verify their adequacy. BLM’s wind and solar policies direct  officials to review the adequacy of wind bonds every 5 years and solar  bonds every year. Of the 45 wind and solar rights-of-way we reviewed, 23  had bonds that were at least 4 months overdue for an adequacy review.  Some BLM officials responsible for these reviews told us that they were  not aware that bonds were supposed to be reviewed. Others told us they  were aware that bonds were to be reviewed but had not completed the  reviews due to workload and staffing constraints. BLM officials told us that  LR2000 contains information such as the authorization date that can be  used to determine when a right-of-way is due for review. However,  LR2000 does not automatically notify BLM officials that a right-of-way is  due for its periodic review. Several BLM officials told us that it would be  possible to set up an action code in LR2000 to provide such automatic  notification. If reviews of bond amounts are not conducted in a timely  manner, BLM officials cannot be sure that bonds in place are adequate to  cover reclamation costs.
BLM does not have detailed policies to ensure that all bonds are properly  maintained and secured and bond decisions accurately documented in  project files. In addition, BLM has no standard for the timely entering of  data of wind and solar project data into LR2000 and no data standards for  the Bond and Surety System. As a result, BLM may not have accurate  and complete information with which to track wind and solar bonds, and  BLM has limited assurance that the bonds in place will be adequate to  cover reclamation costs if the right-of-way holder does not meet its  obligations. As a result of these findings and to help ensure that bonds  are adequate to cover reclamation costs for wind and solar projects on  federal land, we made five recommendations to the Secretary of the  Interior in our June 2015 report. Specifically, we recommended that the  Secretary direct the Director of the Bureau of Land Management to develop detailed policies for processing wind and solar bonds to  ensure bonds are properly secured, handled, and stored; develop policies that detail how information related to bonding  decisions should be documented in project files; develop a policy that all data for wind and solar energy projects be  entered in LR2000 and the Bond and Surety System within 10  business days; establish data standards for the Bond and Surety System; and develop an LR2000 action code to automatically notify BLM staff that  a right-of-way is due for a bond adequacy review.
In its comments on a draft report, the agency concurred with each of  these recommendations.
Chairman Gohmert, Ranking Member Dingell, and Members of the  Subcommittee, this completes my prepared statement. I would be  pleased to answer any questions that you may have at this time.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: If you or your staff members have any questions about this testimony,  please contact me at (202) 512-3841 or fennella@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this statement. Other individuals who made  key contributions to this testimony include Elizabeth Erdmann (Assistant  Director), Morgan Jones, Jessica Lewis, Susan Malone, and Jarrod West.  Cheryl Arvidson, Antoinette Capaccio, Kirsten B. Lauber, and Dan Royer  also made important contributions.
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