This section provides information on BLM’s mission and organizational structure for management of oil and gas development, BLM’s process for overseeing the development of federal oil and gas resources and mitigating environmental impacts, and our prior work on BLM’s management of federal oil and gas resources. BLM’s mission is to maintain the health, diversity, and productivity of public land for present and future generations. As part of this mission, BLM manages more than 245 million surface acres of federal land for multiple uses, including recreation; range; timber; minerals; watershed; wildlife and fish; natural scenic, scientific, and historical values; and the sustained yield of renewable resources. BLM oversees onshore oil and gas development on and under BLM-managed federal land, under other federal agencies’ land, and under private land for which the federal government has retained mineral rights—a total of about 700 million subsurface acres. BLM manages these responsibilities through its headquarters office in Washington, D.C.; state offices; district offices; and field offices. BLM’s headquarters office develops guidance and regulations, and the state, district, and field offices manage and implement the bureau’s programs. BLM’s oversight of oil and gas development is led by field offices located primarily in the Mountain West, the center of much of BLM’s onshore oil and gas development. BLM’s process for overseeing federal oil and gas resource development consists of three phases, each of which includes opportunities to mitigate impacts of development on the environment. These phases—land use planning, leasing, and permitting—incorporate mitigation through, for example, lease and permit requirements, including best management practices. BLM can grant exceptions to these requirements, and it conducts environmental and monitoring inspections intended, respectively, to verify operators have implemented the requirements and to assess the effectiveness of the requirements in mitigating environmental impacts of development. The process is illustrated in figure 1. FLPMA requires the Secretary of the Interior to develop land use plans and, when appropriate, revise them. The plans identify, among other things, federal land and mineral resources that will be available for oil and gas development and other activities. As part of developing or revising land use plans, BLM is required under the National Environmental Policy Act of 1969 (NEPA), as amended, to evaluate likely environmental impacts of proposed actions in the plan, such as developing oil and gas resources in certain areas. Generally, BLM prepares an environmental impact statement—a detailed analysis of the likely environmental effects of a proposed action—in preparing a land use plan. However, depending on the anticipated level of public interest and potential for significant impacts, BLM may instead develop an environmental assessment—a more concise analysis developed for an amendment to the plan. BLM officials said the agency uses the land use plans and environmental impact statements to (1) help develop reasonably foreseeable development scenarios to estimate outcomes, such as the number of wells to be involved and the surface disturbance that may occur under the land use plan; (2) identify land open and closed to leasing; (3) identify resource protection measures, such as lease requirements and environmental best management practices; and (4) establish monitoring protocols. BLM develops land use plans over several years. During a plan’s development, BLM coordinates with state and local governments and collaborates with stakeholders, including oil and gas operators, nongovernmental organizations, and state wildlife agencies, and provides multiple opportunities for comment by the public. Comments can address such topics as criteria for granting exceptions to lease requirements and the appropriateness of best management practices. Once a land use plan is completed, BLM holds a lease sale. Operators may purchase a lease for land identified by the land use plan as available for oil and gas development. As part of this phase, BLM generally conducts an environmental assessment to determine whether the proposed development is likely to significantly impact the environment. In the assessment, BLM can propose applying lease requirements that were identified in the land use plan, where many of the requirements are intended to protect the environment. For example, a lease requirement may state that an operator cannot drill within a specified distance of a raptor’s nest during its breeding season. BLM allows the public to review and comment on draft environmental assessments for lease sales, including proposed lease requirements. In addition, the public may protest a lease before it is offered for sale. When a lease is offered for sale, the lease requirements identified through the environmental assessment are included as requirements for holding the lease. Operators that have obtained a lease must submit to BLM a drilling permit application and obtain BLM’s approval before drilling any new oil or gas wells. A complete drilling permit application must include, among other things, a “Surface Use Plan of Operations” that includes the operator’s plan for reclaiming disturbed land during production (known as interim reclamation) and upon final abandonment of the site (known as final reclamation). The reclamation plan outlines the specific steps the operator proposes to take to reclaim the well site, which may include recontouring the land to better match the surrounding landscape, redistributing the topsoil, and replanting the site with native plant species. As part of the permitting phase, BLM generally conducts a NEPA analysis—that is, an environmental impact statement or an environmental assessment—to identify any site-specific environmental impacts from the proposed oil and gas activity. On the basis of this analysis, BLM may identify certain requirements to attach to the permit. According to BLM officials, these permit requirements are generally attached to ensure environmental protection, safety, or conservation of mineral resources and may be based on environmental best management practices, described below. While BLM notifies the public that an operator has submitted a drilling permit application, BLM may or may not require public comment on the associated NEPA analysis. According to BLM’s NEPA Handbook, the type of public involvement required when an environmental assessment is prepared is at the discretion of the decision maker and can include public notification before or during preparation of the environmental assessment, among other types of involvement. After BLM approves a drilling permit, the operator generally has a 2-year window to drill the well and begin production, subject to any lease or permit requirements. However, BLM may extend the drilling permit for up to 2 additional years if an operator requests an extension in writing. In 2004, BLM issued its best management practices policy, which defines environmental best management practices as innovative mitigation measures applied on a site-specific basis to prevent or reduce adverse environmental or social impacts. BLM can include best management practices as lease and permit requirements or, in some cases, operators may apply them voluntarily. BLM’s policy identifies four key practices that should be considered as lease or permit requirements in nearly all circumstances: (1) painting of facilities to blend with the surrounding environment, (2) design and construction of roads in accordance with BLM guidance, (3) interim reclamation, and (4) final reclamation. There are numerous additional best management practices that, according to the policy, BLM field offices should consider on a site-specific basis. Such practices may include installing raptor perch avoidance structures, placing wellheads underground, drilling multiple wells from a single pad, and screening facilities from view. To help BLM manage resources based on current conditions, BLM’s regulations and policies allow it to grant operators’ requests for exceptions, waivers, or modifications to lease and permit requirements. Exceptions are one-time exemptions for a particular site within a lease; waivers are permanent exemptions from a lease requirement; and modifications are changes to the provisions of a lease requirement, either temporary or for the term of the lease. BLM issued a policy in November 2007 providing guidance on (1) including exception, waiver, and modification criteria in BLM land use plans and (2) reviewing and approving exceptions, waivers, and modifications to lease and permit requirements. Criteria for considering exception requests are generally developed through the NEPA process as BLM develops its land use plans. To help ensure operators’ compliance with all lease and permit requirements, as well as with certain laws and regulations, BLM has an inspection and enforcement program, which comprises a variety of inspection types. Among these are environmental inspections, intended to verify operators’ compliance with certain lease and permit requirements, and monitoring inspections, intended to assess the effectiveness of lease and permit requirements in mitigating environmental impacts of development. Environmental inspections are BLM’s primary mechanism to verify operators’ compliance with lease and permit requirements, including best management practices, related to the surface environment and to initiate enforcement actions, if needed. For example, BLM may perform environmental inspections to help ensure that operators are adhering to lease and permit requirements designed to mitigate the impact of oil and gas development on sensitive species and their habitat. Environmental inspections typically are performed by BLM staff, such as natural resource specialists, environmental protection specialists, or other resource program specialists. These staff document the inspections using hard copy forms and BLM’s electronic system for oil and gas management, the Automated Fluid Minerals Support System (AFMSS). In addition, BLM conducts monitoring inspections to collect quantitative or qualitative data for the purpose of assessing the effectiveness of lease and permit requirements in mitigating environmental impacts of development. BLM is required by Council on Environmental Quality (CEQ) regulations to establish a monitoring and enforcement program, where applicable, for any mitigation. To fulfill this requirement for oil and gas development, BLM issued a policy in 2009 to ensure adequate monitoring of oil and gas development and clarify how staff are to conduct and track monitoring inspections. Specifically, the policy requires that BLM field offices that have oil and gas programs conduct monitoring inspections to assess the effectiveness of lease and permit requirements in mitigating environmental impacts of development. BLM field offices are to independently track monitoring inspections and report via BLM’s PMDS the number of inspections completed.