BLM is responsible for managing, as of July 2008, approximately 700 million acres of subsurface mineral resources: 655.5 million of these acres are not affected by oil and gas production and 44.5 million acres are leased for oil and gas operations. Of these 44.5 million acres, 11.7 million acres are in oil and gas producing status and 472,000 acres have surface disturbance related to oil and gas production. To manage BLM programs and land, the agency maintains a network of state offices, which generally conforms to the boundary of one or more states. The state offices are Alaska, Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Wyoming, and Eastern States. BLM has little land in the eastern half of the United States, consequently, the Eastern States state office, in Springfield, Virginia, is responsible for managing land in 31 states. Figure 1 shows the boundaries of the 12 BLM state offices. When operators drill oil and gas wells, they typically remove topsoil from the well site and lay a well pad, where the drilling rig is located. Other equipment on site can include generators and fuel tanks. In addition, reserve pits are often constructed to store or dispose of water, mud, and other materials that are generated during drilling operations, and roads and access ways are often built to move equipment to and from the wells. Generally, these activities can degrade the environment in three ways: Air quality. Newly graded roads can produce dust, impairing air quality and visibility in the immediate area and downwind. Nitrogen oxides from diesel engines and compressors used at drilling sites can also degrade air quality. Water quality. Water draining off newly graded surfaces and roads or oil or water accidentally discharged during oil and gas production can increase the amount of sediment, salt, and pollutants discharged into rivers and streams, thereby degrading them. In addition, shallow aquifers can be polluted if required protective measures are not in place, and the production of methane gas from coal beds can deplete shallow aquifers that serve as domestic water sources. Habitat. A high density of drilling and production equipment can, in extreme situations, change the appearance of the landscape from a natural setting to an industrial zone. In addition, the noises, smells, and lights from trucks, drilling and construction equipment, and production facilities can disturb wildlife and people living nearby. Under FLPMA, BLM must manage federal lands for multiple uses, including recreation and mineral extraction, as well as for sustained yield. To that end, FLPMA requires BLM to develop resource management plans, known as land use plans. In developing its land use plans, BLM determines, among other things, which parcels of land will be available for oil and gas development. According to BLM officials, parties interested in leasing federal minerals submit an Expression of Interest or pre-sale offer on those lands they are interested in leasing. These are then reviewed and if the lands are eligible to be leased, are placed up for competitive oil and gas lease sale. Leases can vary in size reaching 2,560 acres for lands in the lower 48 states and 5,760 acres for lands in Alaska. Operators that have obtained a lease must submit an application for a permit to drill to BLM before beginning to prepare land or drilling any new oil or gas wells. The complete permit application package is a lengthy and detailed set of forms and documents, which, among other things, must include proof of bond coverage and a surface use plan of operations; this surface use plan must include a reclamation plan that details the steps operators propose to take to reclaim the site. However, operators generally do not have to submit cost estimates for completing the reclamation. The Mineral Leasing Act of 1920, as amended, requires that federal regulations ensure that an adequate bond or surety is established before operators begin to prepare land for drilling. The bond is intended to ensure complete and timely reclamation. Accordingly, federal regulations require the operator to submit a surety or personal bond to BLM, which is intended to ensure compliance with all of the lease’s terms and conditions, including reclamation requirements. Surety bonds are a third-party guarantee that an operator purchases from a private insurance company approved by the Department of the Treasury, and personal bonds must be accompanied by one of the following five financial instruments: certificates of deposit issued by a financial institution whose deposits are cashier’s checks; negotiable Treasury securities, including U.S. Treasury notes or bonds, with conveyance to the Secretary of the Interior to sell the security in case of default in the performance of the lease’s terms and conditions; and irrevocable letters of credit that are issued for a specific term by a financial institution whose deposits are federally insured, and meet certain conditions. In reviewing the application for a permit to drill, BLM (1) evaluates the operator’s proposal to ensure that the proposed drilling plan conforms to the land use plan and applicable laws and regulations and (2) inspects the proposed drilling site to determine if additional site-specific conditions must be addressed before the operator can begin drilling. After BLM approves a drilling permit, the operator can drill the well and commence production. After drilling the well, the operator may perform interim reclamation—the practice of reclaiming surfaces that were disturbed to prepare a well for drilling but that are no longer needed. For example, operators may need a 10-acre drill pad to safely drill a series of wells. However, once the wells are drilled, operators may only need 4 acres to safely service the wells over their lifetime. In this case, the operator could reseed and regrade the 6 acres of the initial pad that are no longer needed. While BLM does not generally require interim reclamation in all permits it issues, it may decide to add interim reclamation as a requirement in drilling permits for specific oil and gas developments. Final reclamation occurs when an operator determines, and BLM agrees, that a well has no economic value. The terms of final reclamation are included in the lease and the drilling permit. The operator must follow the agreed-upon final reclamation plan, including plugging the wells, removing all visual evidence of the well and drill pad, recontouring the affected land, and revegetating the site with native plant species. In general, the goal is to reclaim the well site so that it matches the surrounding natural environment to the extent possible. BLM then inspects the site to monitor the success of the reclamation, a process that typically takes several years. Once BLM determines that reclamation efforts have been successful, it approves a Final Abandonment Notice. However, in some circumstances, the operator may delay performing reclamation and instead allow the well to remain idle for various reasons. For example, expected higher oil and gas prices may once again make the well economically viable to operate, or the operator may decide to use the well for enhanced recovery operations, for example using the well to inject water into the oil reservoir and push any remaining oil to operating wells. Under BLM policy, the agency must periodically review the status of these idle wells to ensure that the operator has legitimate reasons for allowing the wells to remain idle. According to BLM officials, the primary purpose of idle-well reviews is to ensure that these wells do not become orphaned—that is, they lack a bond sufficient to cover reclamation costs and there are no responsible or liable parties to perform reclamation. States have adopted laws and regulations governing oil and gas development on state and private lands, including bond and reclamation requirements. In addition, other Interior programs and offices that are responsible for managing the extraction of other federally owned resources have bond and reclamation requirements. Specifically, those programs and offices are: BLM Geothermal Resource Leasing. BLM issues leases for the development of geothermal resources on federal lands; these resources are used to develop electricity by capturing the geothermal heat generated in the earth’s core. BLM Hardrock Minerals Claims. BLM oversees the process for staking claims and extracting hardrock minerals on the lands it manages. These minerals are also referred to as locatable minerals and include gold, silver, and copper, among others. BLM Mineral Materials Sales. BLM oversees the sale of these minerals, such as sand and gravel, from federal lands. These minerals are also sometimes referred to as salable minerals. BLM Solid Minerals Leasing. BLM issues leases for the extraction of these minerals on federal lands; solid minerals are minerals other than coal and oil shale, and include silicates, potash, and phosphate. Solid minerals are also sometimes referred to as leasable minerals. Minerals Management Service (MMS) Offshore Oil and Gas Leasing. MMS issues leases to develop offshore oil and gas resources in the Gulf of Mexico, off the Atlantic coast, and off the Pacific coast states of California, Oregon, Washington, and Hawaii. Office of Surface Mining Reclamation and Enforcement (OSM) Coal Leasing. OSM regulates the surface mining of coal. States can choose to develop their own programs to regulate surface mining if that program is in accordance with federal law and approved by OSM. OSM is charged with enforcing states’ adherence to their approved programs or implementing a federal program if the state fails to submit, implement, or enforce its program. As of December 2008, oil and gas operators had provided 3,879 surety and personal bonds, valued at approximately $162 million, to ensure compliance with all lease terms and conditions for 88,357 wells, according to our analysis of BLM data. BLM officials told us that the bond amounts are generally not based on the full reclamation costs for a site that would be incurred by the government if an operator were to fail to complete the required reclamation.