State and field offices manage and implement the bureau’s programs. Our Analysis of BLM Data Shows the Distribution of BLM’s Inspection and Enforcement Program’s Workload and Workforce Was out of Balance in Fiscal Years 2012 through 2016

In fiscal years 2012 through 2016, the distribution of the oil and gas  Inspection and Enforcement program’s workload and the workforce  among the 33 BLM field offices with ongoing oil and gas development  activities showed an imbalance, based on our analysis of BLM data. BLM  took both short- and long-term actions in fiscal years 2012 through 2016  to address this imbalance, such as temporarily re-assigning inspectors  from some medium activity offices to some of the highest activity offices. The Distribution of the BLM Inspection and Enforcement Program’s Workload and Workforce Was Out of Balance Based on Our Analysis of BLM’s Data

From fiscal years 2012 through 2016, the distribution of the workload and  workforce of BLM’s oil and gas Inspection and Enforcement Program was  out of balance across the 33 BLM field offices with ongoing oil and gas  development activities, based on our analysis of BLM data. From fiscal years 2012 through 2016, based on our review of BLM  documentation and interviews with agency officials, BLM took both short  and long-term actions to address this imbalance, such as temporarily re- assigning inspectors from some medium activity field offices to some  highest activity offices. Officials, however, said that their  ability to complete more high-priority production inspections increases  during times of reduced industry drilling activity. From fiscal years 2012 through 2016, the Carlsbad and Dickinson field  offices were responsible for about 30 percent of all wells drilled on federal  and Indian lands, according to BLM data. BLM Has Not Completed All Required Internal Control Reviews of Its Field Offices and Does Not Employ a Risk-Informed Oversight Strategy

BLM state offices did not complete internal control reviews at 27 of 33  field offices—including 5 of the 6 highest activity offices we identified. According to the July 2012 oversight policy, state offices are to  periodically conduct internal control reviews of their field offices to, among  other things, (1) review whether inspections and enforcement actions are  accurate, complete, and conducted in accordance with policy, (2) review  staffing and training needs, and (3) identify areas where program  guidance can be improved. BLM state offices completed  internal control reviews at 6 of the 33 field offices from 2013 through 2017  and scheduled reviews for 5 others from 2018 through 2020, as shown in  table 5. Specifically, the Inspection and Enforcement  program manager said that BLM headquarters did not consistently track  and monitor the extent to which state offices completed field office  internal control reviews. BLM  headquarters officials we spoke with were not aware that so few reviews  had been completed in fiscal years 2013 and 2015. Federal standards for internal control state that management should  design control activities to achieve objectives and respond to risks, such  as by comparing actual performance to planned or expected results and  analyzing significant differences. In this context,  BLM’s July 2012 oversight policy calls for its state offices to conduct  periodic internal control reviews of field offices. Identifying the reasons it did not complete internal control reviews (e.g.,  human capital and workload), developing and implementing a plan to  address those challenges, and monitoring state offices’ progress toward  completing required reviews will better position BLM to ensure that its  state offices are completing all required internal control reviews as called  for by its July 2012 oversight policy.
Why GAO Did This Study

BLM has primary responsibility for managing oil and gas development on federal and Indian lands. To help ensure operator compliance with laws and regulations, BLM administers the Inspection and Enforcement program. Under the program, BLM inspects operators' drilling, production, and plugging activities and can issue various enforcement actions, such as monetary assessments, for violations. GAO was asked to examine key aspects of the Inspection and Enforcement program.
This report (1) describes the distribution of BLM's oil and gas Inspection and Enforcement program's workload and workforce among agency field offices for the most recent 5 years for which such data were available (fiscal years 2012 through 2016) and (2) examines the extent to which BLM conducted internal control reviews in accordance with its July 2012 oversight policy for fiscal years 2013 through 2018, the most recent period for which such data were available. GAO examined BLM policies, data, and documents; interviewed BLM headquarters, state and field office officials; visited six BLM field offices selected based on their level of resource development activity; and toured oil and gas drilling, production, and plugging sites at three of these six field offices.

What GAO Found

Based on GAO's analysis of Bureau of Land Management (BLM) data, the distribution of BLM's oil and gas Inspection and Enforcement program's workload and workforce showed an imbalance among BLM's 33 field offices in fiscal years 2012 through 2016. GAO analyzed BLM data on the overall percentage of the workload and workforce distributed at each field office (i.e., activity level) and grouped similar activity level field offices together into highest, medium and lowest activity categories. GAO found that the program distributed the majority of its workload to 6 highest activity offices and distributed the majority of the workforce to 21 medium activity offices (see fig.). Based on GAO's review of BLM documentation and interviews with agency officials, BLM took both short- and long-term actions in fiscal years 2012 through 2016 to address this imbalance, such as temporarily re-assigning inspectors from some medium activity offices to some of the highest activity offices.
BLM has not completed all required internal control reviews of its field offices. BLM's July 2012 oversight policy instructs its state offices to periodically conduct internal control reviews of field offices, which are to, among other things, identify staffing needs. BLM state offices completed internal control reviews at 6 of 33 field offices from 2013 through 2017, and 5 more are scheduled from 2018 through 2020. Officials from BLM state offices told GAO that some human capital and workload challenges hindered their ability to complete reviews, including long-term vacancies in some state offices positions. However, a senior BLM official said that headquarters did not consistently track and monitor the extent to which state offices completed field office internal control reviews, and headquarters officials said they were not aware that so few reviews had been completed. Under federal standards for internal control, management should design control activities to achieve objectives and respond to risks, such as by comparing actual performance to expected results and analyzing significant differences. Identifying the reasons it did not complete internal control reviews, developing and implementing a plan to address those challenges, and monitoring state offices' progress toward completing required reviews will better position BLM to ensure that its state offices are completing all required internal control reviews as called for by its July 2012 oversight policy.

What GAO Recommends

GAO is making three recommendations to BLM, including taking actions to increase monitoring of state offices' progress toward completing internal control reviews. BLM concurred with all three recommendations.