The Mineral Leasing Act of 1920 charges Interior with responsibility for oil and gas leasing on federal lands and on private lands where the federal government has retained mineral rights. Several other statutes and regulations also affect oil and gas leasing and development on federal lands. For instance, the protection of resources that may be affected by oil and gas activity is governed by resource-specific laws, such as the Clean Air Act, the Clean Water Act, and the Endangered Species Act. Under the National Environmental Policy Act (NEPA), federal agencies are to evaluate the likely environmental effects of proposed projects, including oil and gas lease sales, through an environmental assessment or, if projects are likely to significantly affect the environment, a more detailed environmental impact statement. In addition, under the Federal Land Policy and Management Act, BLM manages federal lands for multiple uses, including recreation; range; timber; minerals; watershed; wildlife and fish; and natural scenic, scientific, and historical values, as well as for the sustained yield of renewable resources. BLM manages oil and gas development on federal lands using a three-step process. First, BLM develops areawide land use plans, called resource management plans, specifying what areas will be open to oil and gas development and the conditions to be placed on such development. Second, BLM may issue leases for the development of specific sites within an area, subject to requirements in the plans. Finally, a lessee may file an application for a permit to drill, which requires BLM review and approval. BLM’s lease sale process includes several key steps: Nomination of lands for sale. Interested members of the public and industry can nominate lands for competitive lease by sending to a particular BLM state office letters expressing interest in specific tracts of land desired for lease. BLM itself may also identify parcels for potential lease, although the majority of parcels leased in recent years have been nominated by the oil and gas industry. Parcels nominated for lease can vary in size; in the contiguous 48 states, the maximum size of a parcel nominated for competitive lease is 2,560 acres. Review of parcels. Parcels nominated for lease are evaluated by BLM field staff to determine whether the proposed land is available to be leased and whether it conforms with BLM policies, regulations, and land use plans. If the parcel is determined to be available, the potential impacts of oil and gas leasing on the environment are then evaluated as required under NEPA. If required, leasing restrictions (called stipulations) are added to the proposed parcel to mitigate potential impacts of leasing. Notice of lease sale. Once BLM has completed its reviews of nominated parcels, it identifies those parcels it has determined may be offered at the lease sale. These eligible parcels are included in a public “notice of competitive lease sale,” which is to be published at least 45 days before the lease sale. BLM may, however, withdraw, or defer, parcels included in the lease sale notice at any time before the lease sale takes place. Such parcels may be subsequently offered in a future lease sale if the agency conducts further review and determines the parcels’ suitability for leasing. Public protest period. The publication of a lease sale notice starts the public protest period, in which concerned entities can file a protest to BLM’s inclusion of any or all parcels in that lease sale notice. Included in the lease sale notice is guidance to the public on the process to follow for protesting BLM’s decision to offer lands identified in the notice. Under BLM guidance, the agency considers only protests received at least 15 calendar days before the date of the lease sale, generally providing 30 days for the public to submit protests. BLM dismisses a protest if the protest lacks a statement of reasons to support it. Although BLM aims to review and resolve protests before lease sales, if it cannot do so, it may elect to include protested parcels in a lease sale. In such cases, BLM resolves the protests before issuing leases for those parcels. If BLM finds a protest to have merit, the agency does not issue leases for the affected parcels, and it refunds any payments made. Competitive lease sale. The lease sale itself is a public auction, with leases sold to the highest qualified bidder. Federal oil and gas leases operate under a system in which the lessee receives the right to develop and produce oil and gas resources under a specified time frame and conditions in exchange for certain payments, including a lump-sum payment called a bonus bid. Under the Mineral Leasing Act, “leases shall be issued within 60 days following payment by the successful bidder of the remainder of the bonus bid, if any, and the annual rental for the first lease year,” thus completing the lease transaction. BLM policy also directs agency staff to resolve any protests related to a parcel before issuing the lease on that parcel. The company pays annual rent on the leased parcel until it begins to produce oil or gas (at which time, the lease owner or operator pays royalties on the volume of oil and gas produced) or until the lease expires or ends. Parcels that do not receive competitive bids are available noncompetitively the day after the sale and remain available for leasing for up to 2 years after the competitive lease sale date. The Energy Policy Act of 1992 requires BLM to offer all competitive and noncompetitive leases at 10-year primary terms. Over the past two decades, the number of federal onshore oil and gas leases BLM has issued, as well as the number of acres, have varied. Leasing activity was highest at the beginning of the period, with more than 9,000 leases and over 12 million acres leased in fiscal year 1988. Both the number of leases and area leased then fell sharply for several years, and in recent years the number has fluctuated between 2,000 and about 4,500 leases, and the area did not exceed 5 million acres leased (see fig. 1). The issuance of a lease starts a series of steps toward exploring for and producing oil, gas, or both on the leased land. Along the way, variables such as the market price of oil and gas and the costs of infrastructure influence industry’s estimates of the economic viability of pursuing development on leased lands. Lease owners may analyze available geologic information and conduct seismic or other testing to ascertain the land’s oil or gas potential and find the resource. Companies may also try to acquire leases for surrounding parcels to ensure they have sufficient acreage to make exploration and production worthwhile. If companies believe that economically viable reserves exist on their leased lands, they may begin preparing for drilling, including completing environmental studies required to apply for drilling permits. Before an oil and gas company can drill on federally leased lands, it must submit to BLM an application for a permit to drill. Once such permits are approved, companies may begin exploration or development activities, including building roads to well sites, drilling wells, and constructing pipelines and pipeline facilities needed to transport the oil and gas to market. This entire process can take as little as a few years or as long as 10 years, and ultimately, leased areas may not necessarily contain oil and gas in commercial quantities. Although BLM has taken steps to collect information related to protests to its lease sales, we found that the information it maintained and made available publicly was incomplete and inconsistent across the four state offices we reviewed. In addition, protester groups have raised concerns about the timing and extent of publicly available information. In May 2010, the Secretary of the Interior announced several agencywide leasing reforms that are to take place at BLM, some of which may address concerns raised by protester groups, by providing the public with earlier and more consistent data on which parcels may become available for leasing, thereby giving these groups longer to consider or prepare protests. Although BLM has taken steps to collect agencywide protest data, we found that these data were incomplete, inaccurate, inconsistent or ambiguous, and therefore of limited utility. To better track protests, BLM in 2007 required its staff to begin using a new module, which it had added as a component of its LR2000 lease record-keeping system specifically to capture, among other things, information related to lease sale protests. All parcels included in a lease sale notice are to be entered into LR2000, each with an assigned serial number and other basic information, including location and acreage. In addition, for each protested parcel, staff are to enter into the LR2000 module who filed the protest; reasons for the protest; and the outcome, or status, of the protest. The module should therefore contain complete information on every parcel listed in lease sale notices that was protested during the lease sale process. These parcels include parcels deferred before a competitive lease sale, parcels sold at a competitive lease sale, and parcels that did not receive a bid at a competitive lease sale. Concerning the completeness of the data, we found that some data identifying parcels that had been protested were missing from the module, particularly in the case of parcels that were deferred. We compared the module’s data with protest records obtained from BLM state offices for a random sample of 12 of the 53 lease sales held in Colorado, New Mexico, Utah, and Wyoming during fiscal years 2007 through 2009. For this sample, we found that the four state offices varied in the extent to which data identifying protested parcels had been entered into the module, ranging from fully complete to missing information on deferred parcels, and potentially missing information on parcels that had not been sold at a competitive lease sale (see table 1). Specifically, data obtained from BLM state offices in our sample showed that 68 parcels were protested and deferred. When we looked for these same data in the module, however, we found that 28 of the parcels—over 40 percent of deferred and protested parcels in our sample—were missing.