1” United States Genera1 Accounting Office Report to Congressional Requesters GAO June 1990 FEDERAL LAND MANAGEMENT Better Oil and Gas Information Needed to Support Land Use Decisions RESTRICTED --Not to be &eased outside the General Accounting OfIice unless specifically approved by the Office of Congressional Relations. GAO/RCED-90-71 Resources, Community, and Economic Development Division B-233482 June 27,199O The Honorable Dale Bumpers Chairman, Subcommittee on Public Lands, National Parks and Forests Committee on Energy and Natural Resources United States Senate The Honorable Nick J. Rahall, II Chairman, Subcommittee on Mining and Natural Resources Committee on Interior and Insular Affairs House of Representatives Section 5111 of the Federal Onshore Oil and Gas Leasing Reform Act of 1987 (P.L. 100-203, Dec. 22, 1987) and your March 2, 1988, letter directed GAO and the National Academy of Sciences to study the manner in which oil and gas resources are considered in Bureau of Land Management and Forest Service land use plans and recommend any improvements that may be necessary to ensure that (1) potential oil and gas resources are adequately addressed in planning documents; (2) the social, economic, and environmental consequences of exploration and development of oil and gas resources are determined; and (3) any stipulations to be applied to oil and gas leases are clearly identified. This report analyzes how Bureau of Land Management and Forest Service land use plans address the oil and gas issues and social, economic, and environmental impacts of oil and gas development; and it analyzes stipulations used to reduce impacts. The National Academy of Sciences completed a separate report in September 1989. As agreed with your offices, unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days from the date of this letter. At that time, we will send copies to interested congressional committees, the Secretary of the Interior, the Secretary of Agriculture, the Director of the Bureau of Land Management, and the Chief of the Forest Service. This work was performed under the direction of James Duffus III, Director of Natural Resources Management Issues. He may be reached at (202) 275-7756. Other major contributors are listed in appendix X. I/ Assistant Comptroller General - Executive Summq Federal onshore leases produced oil and gas valued at about $3.3 billion Purpose in 1988. The federal government, states, and Indians share a percentage of the revenues from these leases. In making leasing decisions, the Department of the Interior’s Bureau of Land Management (BLM) and the Department of Agriculture’s Forest Service must weigh the benefits of oil and gas development against potentially adverse impacts on other resources. The Federal Onshore Oil and Gas Leasing Reform Act of 1987 required GAO to study how oil and gas development is considered in BLM and Forest Service land use plans and to recommend any necessary improve- ments. GAO addressed (1) whether land use plans include adequate infor- mation on oil and gas activities in areas with high oil and gas potential, (2) whether appropriate mitigating measures (stipulations or conditions of approval) are imposed on leases and drilling permits to minimize the adverse environmental consequences of oil and gas development, and (3) what it will cost to improve oil and gas information in land use plans. The Federal Land Policy and Management Act and the National Forest Background Management Act, both enacted in 1976, require Interior (through BLM) and Agriculture (through the Forest Service) to develop land use plans. These plans are to clearly identify the area’s resources, such as min- erals, wildlife, recreation, and timber, and encourage management of those resources to meet present and future public needs. Both agencies have determined that they must comply with the National Environ- mental Policy Act (NEPA) when developing land use plans and use the environmental impact statement process NEPA requires as the principal analysis in developing the plans. BIN and the Forest Service also have determined that they must comply with WA at two subsequent points when making oil and gas leasing and development decisions: (1) issuing a lease and (2) approving a drilling permit. In preparing the NEPA anal- yses to support issuing leases or approving drilling permits, both agen- cies draw on and/or tier to previous analyses, including land use plans, and supplement them as necessary. GAO identified five key elements required by NEPA, BLM, and Forest Ser- vice regulations and/or guidance that are essential to assess the environ- mental impacts of oil and gas leasing and development decisions. These elements are (1) oil and gas potential, (2) reasonably foreseeable devel- opment scenario(s), (3) indirect impacts, (4) cumulative impacts, and (5) lease stipulations. Page 2 GAO/RCED-90-71Oil and Gas Decisions Executive Summary Most plans and related environmental impact statements covering BLM Results in Brief and Forest Service lands with high oil and gas potential do not contain adequate information on one or more of the five elements essential for assessing the environmental impacts of oil and gas leasing and develop- ment decisions. Moreover, at the four BLM resource areas and four Forest Service forests visited, GAO found that only one BLM resource area had supplemented its plan with the additional studies necessary to address all five elements before making oil and gas leasing or development deci- sions. Both agencies also have issued leases and approved permits without including appropriate mitigating measures, even approving some drilling permits without first completing the environmental studies they identified as necessary. Such actions have led to delayed or sus- pended oil and gas activity. As a result, federal revenues have been delayed or lost. Although the total cost is unknown at this time, infor- mation GAO reviewed indicates that estimated foregone and delayed rev- enues resulting from inadequate environmental studies far exceed any reasonable estimated cost to improve them. Both BLM and the Forest Service have identified many resource areas and forests where oil and gas information is insufficient and have begun to complete additional environmental studies. However, both agencies still must clarify guidance for their field offices and institute more effec- tive oversight. Principal Findings Inadequate Environmental In examining 82 land use plans and related environmental impact state- ments covering BLM and Forest Service lands having high oil and gas Studies Used to Make Oil potential, GAO found that 76 either did not identify, and/or only par- and Gas Decisions tially addressed 1 or more of the 5 elements essential for assessing the environmental impacts of oil and gas activities. Only six BLM plans and one Forest Service plan met GAO'S criteria for all five elements. Recognizing that NEPA regulations permit the agencies to supplement the plans with additional environmental studies before issuing leases or approving permits to drill, GAO looked at other environmental studies relating to oil and gas activities at four BIN resource area offices and four Forest Service offices. At the four BLM resource area offices and two Forest Service offices that used other existing environmental studies to supplement their plans, GAO found that, when taken together Page 3 GAO/iZCEBoO-71Oil and GM Decisions Executive Summary with the land use plans, only one BLM resource area met GAO'S criteria for addressing all five essential elements. SomePermits to Drill Three of the four BLM resource areas and three of the four Forest Service Approved Without forests visited also approved some drilling permits without including all the conditions of approval required by the land use plans, environ- Appropriate Mitigating mental studies, and/or resource specialists. GAO reviewed all or a sample Measures of permits approved in fiscal year 1988 and estimates that 10 percent of all permits approved in those resource areas and forests were approved without all of the conditions of approval identified as necessary to pro- tect other resources. Potential RevenuesAppear Inadequate land use plans and/or environmental studies have resulted in leasing being suspended, primarily on Forest Service lands. These to Exceed Cost to Develop actions result in lost or delayed federal revenues. The total cost associ- Additional Oil and Gas ated with developing improved information on the environmental Information impacts of oil and gas leasing and development decisions cannot be esti- mated with any degree of certainty at this time. However, it appears that estimated foregone and delayed revenues far exceed any reason- able estimated cost to develop such information for resource areas and forests with high oil and gas potential. For example, the Forest Service estimates that it will cost about $620,000 to complete the environmental studies for the Custer National Forest-including the Little Missouri National Grasslands. GAO estimates that about $22 million in bonus bids alone (payments made to acquire leases) will be generated when leasing resumes in the grasslands. Agencies’ Initiatives BLM has chosen to develop the needed oil and gas information by amending existing plans or preparing new ones. The Forest Service will decide on a case-by-case basis whether to amend or revise its plans, and/ or complete additional environmental studies, as appropriate. On the basis of its review, GAO believes that studies may be required for addi- tional resource areas and forests. Management Controls If Bud and Forest Service initiatives to improve information on the envi- ronmental impacts of oil and gas leasing and development decisions are to be successful, they must be accompanied by improved internal man- agement controls. Existing BLM and Forest Service guidance is unclear on how to address cumulative impacts, and the Forest Service needs to Page 4 GAO/WED-W71 Oil and Gas Decisions Executive Summary clarify guidance on what types of environmental studies will be required. Moreover, both agencies need more effective oversight of their field offices to ensure compliance with applicable regulations and guidance. GAO recommends, among other things, that the Secretaries of the Interior Recommendationsto and Agriculture direct the BLM Director and the Forest Service Chief, the Secretaries of the respectively, to Interior and . establish management controls to ensure that (1) NEPA requirements are Agriculture adequately addressed, whether in land use plans and/or other environ- mental studies, before issuing leases or approving permits to drill and (2) appropriate stipulations and conditions of approval are attached to leases and permits; and l determine which resource areas or forests will yield the most revenues and give priority to developing adequate information for those areas so oil and gas development can proceed expeditiously, with the least pos- sible damage to the environment. Interior and the Forest Service agreed with GAO'S two major recommen- Agency Comments dations and have indicated actions they are taking in response to the draft report. Interior had no significant disagreements with the draft report; however, it offered technical clarifications that have been incor- porated into the report. The Forest Service noted that its plans are not intended to be used for making oil and gas leasing or development deci- sions, and asked that the report make clear the Forest Service’s phased approach for complying with NEPA. The report has been clarified to make clear that there are alternative ways of complying with NEPA; how- ever, it should be noted that in the four forests GAO visited, none of the land use plans or other environmental studies used to make leasing or development decisions adequately addressed the five elements. Page S GAO/‘lKED-90-71Oil and Gas Decisions Contents Executive Summary 2 Chapter 1 10 Introduction Laws Affecting Oil and Gas Leasing and Development 10 BLM and Forest Service Organization 14 Land Use Planning Process 14 Land Use Planning Policies 18 Procedures for Oil and Gas Development 18 Objectives, Scope, and Methodology 19 Chapter 2 25 Oil and Gas Leasing Five Key Elements Should Be Adequately Addressed at Three Decision Points 25 and Development Inadequate Environmental Studies Used to Support 26 Continue Without Leasing and Development Decisions Adequate Information Conditions of Approval Not Always Included in Drilling 30 Permits And/Or Mitigating Some Leasing and Development Decisions Have Been 32 Stipulations Contested Conclusions 33 Chapter 3 35 Status of BLM and BLM Plans to Improve Oil and Gas Information but Underestimates the Number of Resource Areas 35 Forest Service Forest Service Plans to Improve Oil and Gas Information 36 Initiatives to Improve but Approach Unclear An Accurate Estimate of the Total Cost to Develop 37 Information and Additional Oil and Gas Information Is Not Possible Related Cost Estimates Now Improving Oil and Gas Information Appears to Be Cost- 38 Effective Conclusions 39 Recommendations 39 Agency Comments and GAO’s Evaluation 39 Page 6 GAO/XXD-B@71 Oil and Gas Lhxisions Contents Chapter 4 40 Improved Internal Better Agency Guidance Needed on Addressing Cumulative Impacts 40 Management Controls Forest Service Needs Clear Guidance on What Types of 41 Must Accompany Environmental Studies Will Be Required Agency Initiatives More Direct Oversight and Evaluation of Field Offices 41 Needed Conclusions 44 Recommendations 45 Agency Comments and GAO’s Evaluation 45 Appendixes Appendix I: List of Elements Reviewed and Associated 48 NEPA and/or Agency Regulatory or Guidance Citations Appendix II: Results of BLM Land Use Plan Review 50 Appendix III: Results of Forest Service Land Use Plan 52 Review Appendix IV: Results of BLM and Forest Service Land 54 Use Plan Review for Socioeconomic Impacts Appendix V: Extent to Which BLM and Forest Service 55 Land Use Plans Met the Criteria by Element Appendix VI: BLM and Forest Service Land Use Plans and 57 Areawide Environmental Assessments for Four Resource Areas and Four Forests Visited Appendix VII: BLM and Forest Service Resource Areas 58 and Forests That May Need Additional Oil and Gas Information as Identified by GAO and/or the Agencies Appendix VIII: Comments From the Department of the 63 Interior Appendix IX: Comments From the Forest Service 70 Appendix X: Major Contributors to This Report 75 Tables Table 1.1: BLM and Forest Service Planning Process 17 Table 2.1: Extent to Which Key Elements Were Fully 27 Addressed in 82 BLM and Forest Service Plans Table 2.2: Fiscal Year 1988 Drilling Permits Issued 31 Without One or More Appropriate Conditions of Approval Table IV. 1: Extent to Which Plans Identify Socioeconomic 54 Consequences Page 7 GAO/RCED9O-71Oil and Gas Decisions .- Contents Table V.l: Extent to Which Plans Addressed Oil and Gas 55 Potential Table V.2: Extent to Which Plans Projected Reasonably 55 Foreseeable Development Scenarios Table V.3: Extent to Which Plans Addressed Indirect 55 Impacts Table V.4: Extent to Which Plans Cited Cumulative 55 Impacts Table V.5: Extent to Which Plans Addressed Lease 56 Stipulations Table VI. 1: Extent to Which Areawide Environmental 57 Assessments And/Or Applicable Land Use Plans Do Not Meet the Criteria for Each of the Five Elements Table VII.l: BLM Resource Areas With Actions 58 Completed, Underway, or Proposed Table VII.2: Additional Resource Areas Identified by GAO 59 Where More Oil and Gas Information May Be Needed Table VII.3: Forest Service Forests With Actions 60 Completed, Underway, or Proposed Table VII.4: Additional Forests Identified by GAO Where 62 More Oil and Gas Information May Be Needed Figure Figure 1.1: BLM and Forest Service Roles in the Land Use 16 Planning Process Abbreviations BLM Bureau of Land Management EIS environmental impact statement EISS environmental impact statements FLPMA Federal Land Policy and Management Act of 1976 IBLA Interior Board of Land Appeals NEPA National Environmental Policy Act of 1969 Page8 GAO/RCTED~71 Oil and Gas Decisions Page 9 GAO/WED-9iS71 Oil and Gas Decisions Chapter 1 - Introduction More than 925 million acres of subsurface mineral estate are adminis- tered by the Department of the Interior’s (Interior) Bureau of Land Man- agement (BLM) and the U.S. Department of Agriculture’s (Agriculture) Forest Service. Approximately 76 million of these acres are leased for the development of oil and gas. Oil and gas valued at about $3.3 billion was produced from onshore leases in 1988, and the government col- lected over $600 million in revenues.’ Decisions to issue oil and gas leases on federal lands often generate con- troversy. Oil and gas development may significantly affect other uses of these lands-wildlife habitat, vegetation, grazing, range, and recrea- tion-if steps are not taken to minimize the impacts of development. Federal laws encourage the domestic production of oil and gas as well as the environmental preservation of other resources that may be affected by that development. BLM and the Forest Service are required to manage their lands under the principles of multiple use and sustained yield to ensure that resources are used in the combination that best meets demands, yet are protected and preserved for future generations.” To this end, BLM and the Forest Service are required to develop land use plans that clearly identify how the resources will be managed. These plans should, among other things, identify the resources present in an area; encourage the domestic development of minerals, including oil and gas; and reflect a multiple-use/sustained-yield philosophy for managing the land. Several laws govern oil and gas leasing and development. The objectives Laws Affecting Oil of these laws vary, from promoting domestic oil and gas development to and Gas Leasing and ensuring consideration of the environmental impacts of oil and gas Development development on other resources. Taken together, these laws reflect an attempt to balance the often competing interests of developers and environmentalists. ‘These revenues include bonus payments for the right to acquire leases, annual rent paid to hold nonproducing leases, and royalties paid as a percentage of the value of the oil and gas produced. 2Multiple use requires management of public lands and their various resource values, such as fish and wildlife, range, recreation, timber, and watenhed, so that they are used in the combination that will best meet the present and future needs of the public. Sustained yield requires that the lands’ condi- tion be maintained so that future generations will have access to the multiple uses associated wrth land resources. Page10 GAO/RCED90-71Oil and Gas Decisions Chapter 1 Introduction Legislation Promoting and The Mineral Leasing Act of 1920, (30 U.S.C. 181 et seq.), as amended, is Regulating Oil and Gas intended to promote and regulate the development of minerals, including oil and gas, on public lands.3 The act provides a framework Development under which public lands can be leased and developed for valuable min- eral deposits. The act also outlines a fee structure, including rents, bonuses, and royalties, for monies due the government for the use of the land and minerals, and authorizes Interior to issue and administer onshore oil and gas leases on federal land.* In the Mining and Minerals Policy Act of 1970 (P.L. 91-631), the Con- gress declared that the continuing policy of the federal government is to encourage the development of domestic minerals, including oil and gas. While it did not specifically mention federal lands, the act is referenced in legislation applicable to federal land management. The Federal Onshore Oil and Gas Leasing Reform Act of 1987 (P.L. 100- 203, the “reform act”) amended several provisions in the Minerals Leasing Act. A major purpose of the reform act is to require competitive bidding initially for all oil and gas leases, rather than allowing leases to be purchased noncompetitively. The Congress expects to generate more revenue through a competitive bidding process. In addition, although BLM will still offer Forest Service lands along with other federal lands for lease, the reform act gives the Forest Service the authority to approve leasing on its public domain lands6 and designate surface use stipulations and conditions of approval6 that are applicable to all its lands. Environmental Legislation Oil and gas decisionmaking must be consistent with the National Envi- ronmental Policy Act of 1969 (NEFA) (42 U.S.C. 4321 et seq.) and other environmental legislation such as the Endangered Species Act of 1973 as 3The Mineral Leasing Act for Acquired Lands provides similar approval authority for the Forest Service’s acquired lands. For purposes of this report, public and acquired lands are referred to as federal lands. *Offshore leasing is covered primarily under the Outer Continental Shelf Lands Act (67 Stat. 462), as amended. %blic domain lands are lands owned by the federal government that have never been in private or state ownership; acquired lands are lands purchased by, condemned by, or donated to the federal government. 6Stipulations are restrictions on operations that are included on leases; conditions of approval are n&rktions on drilhng permits. Both are designed to mitigate adverse environmental impacts. Page 11 GAO/RCRD!W71 Oil and Gas Lkcisiona - Chapter 1 Introduction amended (16 USC. 1531 et seq.). NEPA requires that the applicable fed- eral agency prepare a detailed environmental impact statement (EIS) for every major federal action that may significantly affect the quality of the human environment. The EIS is designed to ensure that important environmental impacts will not be overlooked or underestimated before the government makes a commitment to a proposed action. The Council on Environmental Quality, established by NEPA, developed regulations implementing NEPA on a governmentwide basis. These regu- lations provide agencies with a process for determining whether or not to prepare an Ers. When an agency is not sure if an EIS is necessary, it prepares an environmental assessment that should provide sufficient information to permit the agency to determine whether to prepare an EIS. If the environmental assessment determines that the proposed action will not significantly affect the environment, and therefore an EIS is not necessary, the agency prepares a “finding of no significant impact.” This finding explains why the proposed action will have no sig- nificant impact on the environment. According to the regulations, an EIS must address the following five issues: (1) the environmental impacts of the proposed action (including the direct, indirect, and cumulative impacts); (2) any adverse environ- mental impacts that cannot be avoided should the proposed action be implemented; (3) alternatives to the proposed action; (4) the relation- ship between local short-term uses of the environment and the mainte- nance and enhancement of long-term productivity; and (5) any irreversible and irretrievable commitments of resources that would occur should the proposed action be implemented. In addition, before making a decision, the responsible agency must solicit comments from the public and other government agencies that may have jurisdiction by law or expertise with respect to any environmental impacts. If an agency believes that a class of actions will not individually or cumula- tively have a significant effect on the environment, NEPA regulations allow that agency to exclude these actions from environmental analysis. With regard to oil and gas leasing and development, there are three key points at which NEPA requirements must be met: (1) developing a land use plan, (2) issuing an oil and gas lease, and (3) approving a drilling permit. At each of these points, the agencies must assess whether they have adequately disclosed, to the extent possible, the impacts of oil and gas development. Implementing regulations provide flexibility and a variety of options regarding the type of study that may be done to meet NEPA requirements. To avoid duplicating efforts, the regulations Page 12 GAO/RCEDW71 Oil and Gas Decisions Chapter 1 IllWOdllCti0n encourage drawing on and/or tiering to existing studies when possible and supplementing them as appropriate. To the extent that a land use plan makes oil and gas leasing and/or development decisions, the EIS should address the five elements in the detail necessary to assess the environmental impact of the proposed action. If the land use plan does not make such decisions, oil and gas issues should be more generally discussed in the EISaccompanying the plan. Such an EIS should, in broad terms, discuss the environmental con- sequences of the possible uses of the lands. Subsequently, more specific environmental analysis concerning oil and gas activities should be pre- pared before issuing leases or drilling permits. Land Use Planning In the mid-1970s, the Congress required Interior and Agriculture to Legislation develop land use plans that provide for the management, protection, development, and enhancement of public lands. The 1976 Federal Land Policy and Management Act (FXPMA)(P.L. 94-579) applies to Interior, and the 1974 Forest and Rangeland Renewable Resources Act (P.L. 93- 378), as amended by the 1976 National Forest Management Act (P.L. 94- 588), applies to Agriculture. Except for some differences discussed below, the acts contain similar requirements for land use planning. In developing land use plans, both agencies are required to consider the principles of multiple use and sustained yield. Agencies must also (1) use a systematic, interdisciplinary approach; (2) consider present and potential uses of the public lands; (3) consider the relative scarcity of the values involved; (4) weigh long-term benefits against short-term benefits to the public; (5) comply with pollution control laws; and (6) to the extent practicable, coordinate with state and local plans. The acts also stipulate that the general public play an integral role in developing land use plans through a public participation process described in the legislation. In addition, both agencies must establish requirements that are consis- tent with NEPA analysis requirements for EISS.For example, both agen- cies’ land use planning legislation requires that present and potential alternative uses of public lands be considered. This requirement is sim- ilar to the NEPA requirement that an EISanalyze alternatives to the pro- posed action. Also, both NEPA and land use planning laws require public participation in the development and analysis of alternatives. Page 13 GAO,‘RCED-90-71 Oil and Gas Decisions Chapter 1 Introduction The two land use planning laws differ in some areas. Interior is required to develop land use plans for both renewable resources (surface resources, such as timber and wildlife) and nonrenewable resources (subsurface resources, such as oil and gas). Agriculture is required to develop land use plans for renewable resources only. However, the Forest Service’s guidance and regulations require that nonrenewable resources also be considered in preparing land use plans. and the Forest Service are organized similarly, both having four BLM and Forest BLM levels of management. The BLM Director and Forest Service Chief head Service Organization their respective agencies. Roth agencies’ headquarters consist of a variety of program offices that issue policy and guidance for their respective programs. Each agency has three levels of management in field operations. BIJA field operations consist of state offices, district offices, and resource area offices. Its 12 state offices, each managed by a state director, are responsible for providing statewide program direction, oversight, and coordination of resource programs for federal lands under BLM’S jurisdic- tion. Each state office has several district offices, each headed by a dis- trict manager. Each district office is responsible for two or more resource areas. District offices provide oversight and support to their resource area offices. Resource area offices, each headed by a resource area manager, are the primary field locations for public contact and information on the use of BLM lands. Forest Service field operations consist of regional, forest, and ranger dis- trict offices that manage the nation’s forests. The Forest Service has nine regional offices, each managed by a regional forester. A regional office has several forest offices, managed by a forest supervisor. A forest office is responsible for two or more ranger district offices. Ranger district offices, managed by district rangers, consist of a portion of a forest. and the Forest Service follow a decentralized approach to land use Land Use Planning BLM planning and oil and gas leasing and development. BLN state and Forest Process Service regional offices develop their own planning policies and proce- dures and have the flexibility to conduct their planning processes on the basis of individual needs and priorities. However, both agencies’ expect resource areas and forests with high oil and gas potential to have sim- ilar oil and gas information in their land use plans. Page 14 GAO/RCRIMO-71Oil and Gas Decisions Chapter 1 introduction BLM and the Forest Service develop their land use plans for a resource area or forest by using resource specialists who provide input to the plan on the basis of their fields of expertise, such as wildlife biology, geology, range conservation, or forestry. BLM state offices and Forest Service regional offices oversee the development of and have the authority to approve the land use plans. Both agencies’ headquarters provide national guidance on how to develop land use plans; however, they do not approve completed plans. Figure 1.1 identifies the roles of BLM and Forest Service personnel in the land use planning process. Page 15 GAO/WED-90.71 Oil and Gas Decisions Chapter 1 Introduction Figure 1.1: BLM and Forest Service Roles in the Land Use Planning Process Assumes overall responsibility . -‘- Establishes agency wide policy BLM for the land use planning for regional planning and Director system. Issues national approves regional guide. guidance. Develops procedures and sets budget priorities. L Approves the land use plan. Publishes the proposed plan and Develops regional guide Reglonal files the related environmental setting regional standards and Forester impact statement with the guidelines for forest plans. Environmental Protection Approves individual forest plans. Agency. Gives statewide guidance and controls quality. i. - I Directly supervises the land use plan Selects and supervises the Forest District and provides quality control at team that prepares, implements Supervlsor Manager -4 the district level. Provides and monitors the forest plan. I budget and staff support for the resource area offices. /j-Y&- BLM and the Forest Service have developed a land use planning process that is intended to meet the requirements of land use planning legisla- tion and comply with NEPA. Both agencies have determined that, under NEPA, the development of a land use plan constitutes a major federal action, and thus requires an EIS. The EXSthen becomes the major analysis used in developing a land use plan. Both agencies are required by NEPA to examine alternative combinations of resource uses, including oil and gas development, and estimate the physical, biological, economic, and Page 16 GAO/RCED-W71 Oil and Gas Decisions chapter 1 introduction social effects of implementing each alternative. The land use plan is developed from the selected alternative or combination of alternatives in the EIS that best meets the agency’s management objectives for the area. A land use plan may incorporate one or more resource area(s) or forest(s). Nine separate planning steps occur during the development of a BLM or Forest Service land use plan and related EL% Table 1.1 provides a brief explanation of each of these steps. Table 1.1: BLM and Forest Service Planning Process Action Description Identify issues Solicit information from the public, industry, and government to identify issues or land use problems. Develop plannrng State the limits of what will or will not be considered during the criteria planning process. Collect inventory data Gather existing inventories and other information and develop other and information needed information. Analyze the Describe the physical and biological characteristics of the land and management situation its resource potential. Formulate alternatives identify a range of reasonable combinations of resource uses and management practices that respond to the planning issues Estimate effects of Compare, evaluate, and analyze the impacts of each alternative on alternatives the environment. Select the preferred Recommend the alternative that best resolves planning issues and alternative promotes balanced multiple-use and sustained-yield objectives. De&elop the land use Choose or modify the preferred alternative after analyzing public comments. Monitor and evaluate Track changes and trends in the environment caused by planning the land use plan decisions and evaluate compliance with the plan, laws, and policies. During the land use planning process, mineral specialists develop infor- mation on oil and gas activity, including available data on the area’s geology and oil and gas exploration and production in written summa- ries, tables, or maps. This information should describe previous oil and gas exploration and production in the area or forest, assess the potential for finding oil and gas, estimate the amount of oil and gas that might be discovered, and describe the facilities necessary to produce the oil and gas. Other resource specialists should identify the potential impacts of development on the land’s other resources. The resource area manager or regional forester then makes preliminary decisions about lands to be open or closed to oil and gas development, including stipulations on development to mitigate impacts. The draft land use plan is then made available to the public for comment. Page 17 GAO/RCED9@71Oil and Gae Decisions Chapter 1 Introduction BLM and Forest Service procedures for internal review and approval of plans are different. Authority to approve plans generally rests at a com- parable level in each agency-the Regional Forester in the Forest Ser- vice, and the State Director in BLM. However, in the Forest Service each plan must be routed through Forest Service headquarters for review to ensure that its format is consistent with national standards. BLM head- quarters staff, on the other hand, do not routinely review plans and have delegated this responsibility to the state offices. and Forest Service headquarters issue land use planning regulations Land Use Planning BLM and policies and procedures in manuals, handbooks, and other guidance Policies documents. BLM’S Director issues this information to all state offices, which, in turn, distribute them to their district and resource area offices. Similarly, the Forest Service Chief issues this information to all regional offices, which distribute them to their forest and ranger district offices. In November 1986 BLM issued supplemental program guidance that spec- ified the type of oil and gas information that must be included in land use plans and related EIS.5. This guidance notes that all plans are expected to identify areas that are open and closed to leasing and the conditions under which stipulations will be attached to leases. In addi- tion, for areas considered to have high potential for oil and gas develop- ment, the guidance directs that land use plans identify (1) the amount of oil and gas potential, (2) the projected level of development-called a reasonably foreseeable development scenario, and (3) the projected cumulative impacts of that development. These elements are discussed in greater detail below. Until October 1989, the Forest Service’s requirements for how oil and gas issues are to be considered in land use plans were contained throughout the agency’s planning regulations, manuals, and handbooks. In an October 11, 1989, memorandum, the Forest Service Chief issued guidance similar to BLM’S supplemental program guidance. In order to develop oil and gas on federal lands, an operator must have a Procedures for Oil and lease and a drilling permit. A lease usually gives an operator the right to Gas Development drill and to perform other necessary development activities, such as Page 18 GAO/RCED-90.71Oil and Gas Decisions chapter 1 Introduction road building. However, before operators can undertake any surface-dis- turbing activities, they must obtain approval for those actions by sub- mitting an application for a permit to drill to BLM, and in the case of forest lands, to the Forest Service. A drilling permit contains an operator’s plan of operations and is divided into two parts: a surface-use plan describing surface-disturbing activities and a drilling plan describing subsurface activities. For forest lands, the Forest Service approves the surface-use plan. BLM approves the surface-use plan for BLM lands, and approves the drilling plan for all federal lands, including Forest Service lands. The Federal Onshore Oil and Gas Leasing Reform Act of 1987 requires Objectives, Scope,and GAO and the National Academy of Sciences to (1) study BIN’S and the Methodology Forest Service’s consideration of oil and gas development in their land use plans and (2) make recommendations for improvement to ensure that oil and gas resources are adequately addressed; the social, eco- nomic, and environmental consequences of exploration and development are determined; and any stipulations to be applied to oil and gas leases are clearly identified. The Chairman, Subcommittee on Public Lands, National Parks and For- ests, Senate Committee on Energy and Natural Resources, and the Chairman, Subcommittee on Mining and Natural Resources, House Com- mittee on Interior and Insular Affairs, authored bills that ultimately led to the reform act. In a March 2, 1988, letter, the Chairmen elaborated on the issues that they wanted us and the Academy to address in response to the legislation. As a result of the letter and discussions with their offices, we agreed to focus our review on the following issues: (1) whether land use plans include adequate information on oil and gas in areas of high oil and gas potential, (2) whether BLM and the Forest Ser- vice impose appropriate mitigating measures (stipulations or conditions of approval) on leases and drilling permits to minimize the adverse envi- ronmental consequences of oil and gas development, and (3) what it will cost to improve oil and gas information in land use plans. In addition, we also identified the extent of oil and gas activities on BLM and Forest Ser- vice lands in a separate report7 7Federal Land Man ement: The Extent of Oil and Gas Activities on BLM and Forest Service Lands GAO/-Q@1 %‘S , Apr. 11,lQQO). Page 19 GAO/RCED-99-71Oil and Gas Decisions Chapter 1 Introduction As agreed with the Chairmen’s offices, we and the Academy conducted independent studies8 We did, however, coordinate our review with Academy officials and kept them advised of our progress. The Academy’s report addressed, among other things, the interrelation between oil and gas leasing decisions and other resource planning decisions. We performed our evaluation in four BLM state offices and three Forest Service regional offices covering four states-California, Colorado, New Mexico, and Wyoming. Additionally, we visited Forest Service officials in region 1 in Missoula, Montana, where all oil and gas leasing activities have been suspended. The four states were selected because they had the highest level of oil and gas activity as measured by the number of producing and exploratory oil and gas wells drilled. Within each state, we visited officials from the applicable BLM state office, one resource area office, and applicable district office staff. Similarly, for the Forest Service, we met with Forest Service officials in region 2 in Lakewood, Colorado; region 3 in Albuquerque, New Mexico; and region 5 in San Francisco, California; and visited one forest, district, and ranger district office in each state. We selected resource areas and forests that were identified as having the most oil and gas activity in each state. Resource areas visited were Caliente, in California; White River, in Colorado; Farmington, in New Mexico; and Platte River, in Wyoming. Forests visited included Los Padres, in California; San Juan, in Colorado; Carson, in New Mexico; and Medicine Bow, in Wyoming. We interviewed environmental, planning, and minerals staff in BIN and Forest Service headquarters and state and local offices. We obtained pol- icies and procedures on the development of land use plans and the oil and gas leasing program, and information on the cost to amend plans, the process used to lease lands for oil and gas exploration, and how stip- ulations and conditions of approval are imposed on leases and drilling permits, respectively. To address the adequacy of oil and gas information in land use plans, we conducted a two-phased approach. First, because neither BLM nor the Forest Service had information on a nationwide basis, our staff geologist identified resource areas and forests located in productive or potentially %Xe Academy’s report, entitled Land Use Planning and Oil and Gas Leasing on Onshore Federal Lands was issued in Sept. 1989. Page 20 GAO/RCEIMO-71Oil and Gas Decisions Chapter 1 Introduction productive oil and gas provinces.g The geologist mapped current and previous oil and gas production locations by provinces using a variety of government and petroleum industry maps, reports, and professional journals. Using maps obtained from BLM that identified resource areas, and a map from the Forest Service that identified all forests, our geolo- gist determined which of the 141 BLM resource areas and 156 national forests were located in productive or potentially productive oil and gas provinces.1o The geologist determined that 62 BLM resource areas and 56 forests are located in productive or potentially productive oil and gas provinces. Because of time constraints, the geologist did not verify whether the federal lands within the provinces were currently productive. We reviewed 40 BLM plans and related EISScovering 41 of the 62 BLM resource areas; the remaining 21 resource areas are generally covered by different types of plans and, therefore, not included in our detailed review.ll We reviewed 42 Forest Service land use plans and related EISs covering all 56 forests located in high oil and gas potential areas. A total of 82 plans and related EISSwere reviewed, covering 97 BLM and Forest Service lands. We did not review any BLM plans covered by the Alaska or the Eastern States Offices, which do not have resource areas. Their planning efforts are different than those of the other state offices. The Alaska State Office plans by district; and the Eastern States Office plans by state. In addition, the Eastern States Office is not completing land use plans as provided for by FLPMA;rather, it is completing less detailed documents called “planning analyses” provided for in BLM’S implementing regula- tions. Among the most significant differences between a land use plan and a planning analysis is that the former requires an EIS, while the Eastern States Office is completing its planning analyses with environ- mental assessments. Second, we identified five key elements required by NEPA regulations or BLM and Forest Service regulations and/or guidance (including BLM’S sup- plemental program guidance) as essential for the agencies to assess the environmental impacts of oil and gas development in resource areas and QForpurposes of this report, we will consider these areas high potential oil and gas areas. “Alaska was not included in this determination. “These areas are generally covered by “management framework plans.” These plans generally do not meet FLPMA or NEPA requirements and are sometimes unpublished documents It is not unusual for several of these documents to etit for one resource area. Page 21 GAO/RCEDBO-71Oil and Gas Decisions chapter 1 Introduction forests with high oil and gas potential. These elements are (1) oil and gas potential, (2) reasonably foreseeable development scenario(s), (3) indirect impacts, (4) cumulative impacts, and (5) lease stipulations. Offi- cials from BLM and the Forest Service as well as officials from environ- mental and industry groups concurred that these elements are necessary to address the environmental impacts of oil and gas development. We then developed criteria to assess each element on the basis of infor- mation in NEPA regulations, BLM’S supplemental program guidance, Forest Service regulations and guidance, and discussions with BLM and Forest Service officials. We developed our criteria to serve as a baseline for minimal requirements that, we believe, must be met to address each element. Because these elements and criteria are not necessarily all- inclusive, the EISS and other environmental studies that meet our criteria for all five elements cannot be automatically assumed to fully comply with NEPA, Appendix I describes the five elements and their associated criteria. Appendixes II and III contain the results of our review of the 82 land use plans using the criteria. In addition, because the reform act specifically asked us, we reviewed the land use plans and related EISS to determine how social and economic consequences were addressed. After reviewing NEPA, BIN, and Forest Service regulations and guidance, and discussing the issue with agency officials, we developed criteria to assess how social and economic conse- quences were addressed in the land use plans. In order to fully address this element, our criteria were that the land use plan and related EIS contain a narrative or table assessing the future impacts of oil and gas development on the local economy, in terms of jobs and/or actual dol- lars. See appendix IV for a summary of our findings regarding this issue. To determine whether BLM and the Forest Service impose appropriate stipulations on leases, we reviewed recent lease sale protests that have occurred nationwide. To determine if conditions of approval identified in approving oil and gas drilling activity were attached to the permits, we focused our examination on recent drilling permits for two reasons: (1) most of the leases for the resource areas and national forests visited were issued before land use plans were required or completed, and, in many instances, before NEPA was passed, and (2) the approval of a drilling permit represents the third and final key decision point for the development of oil and gas resources. To determine whether appropriate conditions of approval are included on drilling permits, we reviewed all or a sample of permits approved in fiscal year 1988 at the four resource Page 22 GAO/ECED-B&71Oil and Gas Decisions Chapter 1 Introduction areas and four forests we visited. For each approved permit, we identi- fied the resources present in the affected area and the conditions of approval that should be included in the permit; and determined if the identified conditions were actually included in the approved permit. We reviewed agency files, including the permit application documentation, and interviewed resource specialists to determine whether required con- ditions were attached to the permits. If conditions of approval were not included, we attempted to determine through discussions with agency officials why they were missing. Because we sampled drilling permits, our estimates of the percentage of permits approved without applicable conditions are subject to sampling error. The sampling error is the maximum amount by which results obtained from a statistical sample can be expected to differ from the true universe characteristic (value) we are estimating. At the 95-percent confidence level, this means that the chances are 19 out of 20 that if we reviewed all permits, the results would differ from the estimates we obtained by less than the sampling error of these estimates. The two sampling errors for the estimates in this report were calculated at the 95-percent confidence level and do not exceed 2 percent. To determine BLM and Forest Service cost and schedule estimates for developing oil and gas information in land use plans and the basis for those estimates, we: (1) determined the agencies’ strategy to revise land use plans, including cost and schedule estimates; (2) determined the basis for those estimates; and (3) assessed the reasonableness of the estimates. In addition, in one Forest Service region that has suspended leasing until necessary environmental studies are completed, we com- pared the cost of completing the necessary environmental studies with the revenue that has been lost because of leasing delays. For this comparison, we obtained cost estimates from the Forest Ser- vice’s region 1 office to complete environmental studies in that region’s forests, and estimated lost and foregone rent, and royalty revenues. Spe- cifically, the Forest Service estimated that one-third of all acreage offered in the region would be leased, and we calculated the amount of rental revenue that is lost annually because lands are not being leased in the region. The Forest Service estimated that 100 percent of the Little Missouri National Grasslands would be leased. On the basis of that assumption and after considering the bonus bids received from seven sales of state leases that occurred from April 1987 to May 1989 in the same area, we estimated foregone bonus bid revenue. To complete our Page 23 GAO/RCED-9@71Oil and Gas Decisions Chapter 1 Introduction analysis, we accepted Forest Service estimates of the amount of fore- gone royalty revenue for the Little Missouri National Grassland. We also met with special interest groups in Washington, D.C., and in the states we visited: the Colorado Environmental Coalition, Burlington Northern Inc.,‘2 the National Wildlife Federation, the New Mexico Oil and Gas Association, the Rocky Mountain Oil and Gas Association, and the Sierra Club Legal Defense Fund. We obtained these interest groups’ comments regarding BLM and Forest Service land use plans and the oil and gas leasing program. Our work was performed primarily from May 1988 through October 1989 in accordance with generally accepted government auditing standards. The Department of the Interior and the Forest Service provided written comments on a draft of this report. Interior’s comments are presented and evaluated in appendix VIII and the Forest Service’s comments are presented and evaluated in appendix IX. 12This company is the holding company for Meridian Oil and El Paso Pipeline Co. Page 24 GAO/RCED-90-71Oil and Gas Lkcisiona Chapter 2 Oil and Gas Leasingand DevelopmentContinue Without Adequate Information And/Or Mitigating Stipulations The management decisions made in a land use plan-such as whether to allow leasing in a given resource area or national forest-represent the first of three key decision points for the development of oil and gas resources. However, our examination of 82 land use plans and related EXSS showed that most plans did not address or only partially addressed one or more of the five key elements essential to assess the environ- mental impacts of oil and gas leasing and development decisions. To the extent that these plans and related EL%are used to make such decisions, more information is needed. In addition, at the other two subsequent decision points-issuance of a lease and approval of a drilling permit-we found that the four BIN offices and the four Forest Service offices we visited (1) rely on environ- mental studies that lack the necessary oil and gas information to make informed decisions concerning environmental impacts;1 (2) continue to approve some drilling permits even though additional environmental studies, identified as needed by the agencies, have not been completed; and/or (3) do not always include mitigating measures (stipulations or conditions of approval) required in the leases or permits to minimize the environmental impact of oil and gas development. Consequently, some leasing and development decisions have been contested in administra- tive and judicial actions, suspending or delaying oil and gas development activities. In resource areas and forests with high oil and gas potential, decisions Five Key Elements relating to oil and gas activities and compliance with environmental Should Be Adequately requirements converge at three key points: (1) developing a land use Addressed at Three plan, (2) issuing oil and gas leases, and (3) approving drilling permits. At each point, the responsible agency must assess whether it has ade- Decision Points quately disclosed information on such essential elements as (1) oil and gas potential, (2) reasonably foreseeable development scenario(s), (3) indirect impacts, (4) cumulative impacts, and (5) lease stipulations. When adequate information is not available on one or more of the ele- ments to make leasing and/or development decisions, the agency must complete the additional environmental studies, and/or draw on existing studies, to reach an informed decision. ‘For purposes of this report, environmental studies encompass the El& prepared as part of the land use planning process as well as areawide environmental assesments and other EISs and environ- mental assessmentsdeveloped to support leasing and development decisions. Page 26 GAO/WED-S&71 Oil and Gas Decisions Chapter2 Oil and Gas Leasing and Development Continue Without Adequate Information AndjOr Mitigating Stipulations A judgment about the adequacy of available information on a particular element is subjective. However, we believe that the criteria we devel- oped to assess whether an element is fully or only partially addressed in land use plans, related EISS, and other environmental studies represent minimal requirements that must be met. As we cautioned previously, these elements and criteria are not necessarily all-inclusive, and land use plans, related EISS, and other environmental studies that meet our cri- teria for all five elements cannot be automatically assumed to be in full compliance with NEPA. To the extent that BLM and the Forest Service rely on land use plans Inadequate and/or related environmental studies to support leasing and/or develop- Environmental Studies ment decisions, they must ensure that these plans and/or related studies Used to Support contain sufficient information to meet NEPA requirements. However, most of the BLM and Forest Service land use plans that we reviewed did Leasing and not fully address one or more of the key elements essential to ade- Development quately assess the impacts of oil and gas development. Additionally, for Decisions three of the four resource areas and all four of the forests we visited, other environmental studies used to meet NEPA requirements for oil and gas leasing and development decisions did not adequately address one or more of the key elements. Yet, the agencies continue to rely on these documents to support their leasing and development decisions, Most Land Use Plans Do We found that 75 of 82 land use plans and related EISS covering BLM and Forest Service lands having high oil and gas potential did not fully Not Contain Essential Oil address one or more of the 5 key elements. Table 2.1 shows the extent to and Gas Information which the elements were fully addressed for the plans. In all, only 7 of the 82 plans met our criteria for all 5 elements-6 plans in BLM and 1 plan in the Forest Service. (See apps. II and III for the extent to which each of the 5 elements was addressed.) Page 28 GAO/RCED9@71OilandGas Decisions Chapter 2 Oil and Gas Len&g and Development Continue Without Adequate Information And/or Mitlgatlug stipulatIoM Table 2.1: Extent to Which Key Elements Were Fully Addressed in 82 BLM and Number of elements BLM Forest Service Total plans Forest Service Plan8 fully addressed Number Percent Number Percent Number Percent None 3 8 4 10 7 9 One 6 15 14 33 20 24 Two 37 Three 6 15 4 10 10 12 Four 5 13 3 7 8 IO Five 2 9 TOW 40 42 82 The extent to which the 82 land use plans addressedeach of the five elements varied greatly by element. For example, 71 of the 82 plans did not cite the cumulative impacts of a reasonably foreseeabledevelopment scenario. The following is a brief summary of how the plans addressed each element.2 Oil and gas potential. Sixty plans met the criteria by identifying in a map, narrative, or table areas of high, medium, low, unknown, or no oil and gas potential. An additional 17 plans partially addressedthis element. Reasonably foreseeabledevelopment scenarios.Twentyone plans met the criteria by projecting the number of wells that BLM or the Forest Ser- vice expects to be drilled during the life of the plan. Forty-five plans partially addressedthis element. Indirect impacts. Forty-nine of the plans met the criteria by discussing the anticipated impacts of oil and gas development on other resourcesin the area. An additional 20 plans partially addressedthis element. Cumulative impacts. We could not develop criteria to assessthe ade- quacy of these plans’ treatment of cumulative impacts becauseneither BLM nor the Forest Service had issued applicable guidance at the time of our review. However, in order to address cumulative impacts of oil and gas development, land use plans must first project a reasonably foresee- able development scenario. Of the 21 plans that projected a development scenario, only 11 specifically cited the cumulative impacts of such a sce- nario in discussing impacts on other resources. . Leasestipulatiok Thirty-five plans met the criteria by identifying applicable stipulations through a map, narrative, or table for all areas within a resource area or forest. An additional 44 plans partially addressedthis element. 2App. V provides a detailed breakdown by element of the number of plans that met the criteria, parthlly met the criteria, or did not identify the element. Page 27 GAO/RCED9&71011 and GM De&ions Chapter 2 Oil and GM Leasing and Development Continue Without Adequate Information And/Or Mitigating Stipulations The NEPA regulations permit agencies to supplement their land use plans and related EISS with other studies before issuing leases or approving drilling permits. The four BLM resource area offices and the four national forest offices we visited often based leasing and development decisions on the EISSprepared as part of the land use planning process and/or areawide oil and gas environmental assessments. However, these studies either did not identify or only partially addressed one or more of the key elements. (See app. VI for the results of our review of the land use plans and applicable areawide environmental assessments covering the four resource areas and four forests.) Two of the eight offices referred solely to the land use plan in approving leases and/or drilling permits. The other six offices referenced the areawide oil and gas environmental assessments and/or the land use plans. In seven of the eight offices, the land use plans and/or areawide environmental assessments, when taken together, did not fully address all of the five key elements. For example, at three offices the applicable environmental studies did not identify or only partially addressed a reasonably foreseeable development scenario. As a result, these resource areas and forests also could not address the cumulative impacts of projected oil and gas development. Drilling Permits Approv -ed If BJ..Mand the Forest Service determine that the information in land use Before Needed Studies plans or environmental assessments is inadequate, NEPA regulations require them to develop additional information before deciding to issue Completed a lease or approve a drilling permit. At two of the four resource area offices and two of the four forest offices visited, the agencies had identi- fied the need for more comprehensive environmental studies. However, three of these four offices continued to approve drilling permits even though the additional studies had not been completed. Although two of the three studies are now complete, our review shows that neither study fully addresses the five key elements essential to assess the environ- mental impacts of oil and gas development. Although the needed study was completed at the fourth office before development activities were allowed to begin, it did not fully address the five key elements. J3-wironmentalImpacts of In 1988, at two resource area offices and one forest office we visited, the Producing MethaneGasFrom a existing plans and/or environmental studies were inadequate because coal seam they did not analyze the environmental impacts of producing methane gas from a coal seam called the Fruitland Formation. Drilling for coal- bed methane gas was initiated in BLM'S Farmington resource area and the Forest Service’s Carson National Forest, both in New Mexico, and the San Juan National Forest in Colorado as a result of a tax credit offered for developing nonconventional fuel sources. Under the law, Page 28 GAO/RCEIMO-71Oil and Gas Decisiona Chapter 2 Oil and Gas Leamingand Development Continue Without Adequate hformation And/Or Mitigating Stipulatious wells had to be drilled by December 31, 1989, (since extended to Dec. 3 1, 1990) to qualify for the credit. All three areas determined that additional studies were required. For example, Farmington resource area officials stated that coal-gas devel- opment requires larger drill pads than conventional development and acknowledged potentially greater impacts on surface resources. More- over, many of these wells may produce large quantities of water, cre- ating a potential disposal problem. The following identifies the status of these studies as of May 1990: l The Farmington resource area issued its environmental assessment in November 1988. The assessment projected that 600 wells would be drilled in the Fruitland Formation by December 31, 1989. This projec- tion included almost 100 wells already drilled before November 1988. The environmental assessment concluded that the coal-gas development would not result in significant impacts to the human environment as long as conditions of approval were added to drilling permits. . The Carson forest completed its environmental assessment in April 1989, concluding that there would be no significant impacts from coal- gas production. . The San Juan forest is in the process of preparing an EIS to determine the impacts of coal-gas production in its portion of the Fruitland Forma- tion and expects to have a draft of the study by July 1990. Prior to completing these additional environmental studies, Farmington and the two forests issued 97 leases and approved over 210 gas wells through fiscal year 1988. Approximately 70 of these leases and about 190 of these approved wells were within the Farmington resource area. Although two of the three additional studies are now complete, they do not fully address all five of our key elements. For example, although the Farmington study concludes that there will be no significant impacts associated with coal-gas development, it did not adequately address cumulative impacts. Also, the study for the Carson forest only partially addressed indirect impacts and lease stipulations. Environmental Impacts of Oil The White River resource area in Colorado completed an environmental and GasDevelopmentin a assessment in April 1988 for approving oil and gas development in the ColoradoResourceArea Douglas Creek area. The study projected that 28 wells would be drilled in that area. Officials told us that if more wells are drilled than pro- jected, they will complete an additional environmental study. In our Page 29 GAO/RCED-9@71Oil and Gas Decisions Chapter 2 Oil and Gas Leasing aud Development Continue Without Adequate Information And/Or Mitigating Stipulations review of the April environmental assessment, we found that the ele- ments of oil and gas potential, reasonably foreseeable development sce- narios, and indirect impacts met our criteria. However, we did not find a specific citation of cumulative impacts. Conditions of approval also were included-although the assessment does not clearly show which condi- tions of approval apply to which well sites. The assessment concludes that the environmental impact of the projected level of oil and gas devel- opment is not significant. Nevertheless, no wells were allowed to be drilled before the environmental assessment was completed. Before issuing a lease, the BLM resource area offices and national forests Conditions of we visited identified stipulations from land use plans and/or other envi- Approval Not Always ronmental studies as well as in-house maps and records. Before Included in Drilling approving drilling permits, these offices conducted on-the-ground inspections of the areas to approve the location of surface-disturbing Permits activities, such as roads and well pads, and to identify conditions of approval needed to protect resources identified at the sites. Resource specialists in the offices were also consulted to identify the resources present in the areas and to help identify any necessary conditions of approval. We estimate that 96 percent of the oil and gas drilling permits we sam- pled at the resource areas and national forests visited were for leases issued before applicable land use plans were completed, and, in many instances, before NEPA was passed. Consequently, these leases do not include certain stipulations that resulted from subsequent land use plans. In these instances, however, BLM and Forest Service officials said that they have been able to include appropriate conditions of approval in the drilling permits to mitigate the adverse impacts of oil and gas development. To determine whether appropriate conditions of approval were attached to drilling permits, we reviewed all or a sample of permits approved in fiscal year 1988 at the four resource areas and four forests we visited. We identified the resources located in the affected area; and the condi- tions of approval the agencies believed were necessary to protect those resources,3 and determined whether those conditions of approval were actually included in the permit. 3We identified these conditions by reviewing the environmenkxl studies the agencies provided us as well as discussing the permits with appropriate resource specialists Unlike the land use plans, how- ever, we did not assessthe adequacy of the environmental studies; we merely extracted the condi- tions of approval from them. Page 30 GAO/RCJXHJ@71Oil and Gas Decisions Chapter 2 Oil and Gas Leasing and Development Continue Without Adequate Information And/Or Mitigating Stipulations We estimate that an average of 10 percent of drilling permits in the offices we visited were approved without one or more of the required conditions of approval. The actual number of permits reviewed at these BLM resource area and Forest Service offices is shown in table 2.2. Table 2.2: Fiscal Year 1988 Drilling Permits Issued Without One or More Permits Appropriate Conditions of Approval Drilling Permits missing Area permits reviewed conditionsa BLM Caliente, California 85 85 26 White River, Colorado 44 29 Ob Farmington, New Mexico 279 80 3b Platte River, Wyoming 104 53 3b BLM Total 512 247 b Forest Service Los Padres, California 5 5 0 San Juan, Colorado 6 6 2 Carson, New Mexico 16 16 11 Medicine Bow, Wyoming 10 10 2 Forest Service Total 37 37 15 We discussed our findings with BLM resource area offices and Forest Service ranger distnct offices because these offices have primary responsibility for including conditions of approval in permrts. bThese data are for information purposes only. They should not be used to estimate the total number of permits missing conditions of approval in the individual offices visited. The type of missing conditions of approval varied. For example, cul- tural/archaeological requirements, such as suspending work in the event of the discovery of any historic or prehistoric ruin, monument, or site, were missing from 25 BLM drilling permits. Also, standard conditions of approval, such as measures to protect soil and watersheds, were not attached to eight BLM permits. And specific conditions of approval, such as certain wildlife restrictions, were missing from 11 Forest Service drilling permits. Page 31 GAO/ECED-9&71Oil and Gas Decisions Chapter 2 Oil and Gas Leasing and Development Continue Without Adequate Information And/Or Mitigating Stipulations Over the past several years, environmental groups have challenged SomeLeasing and some BLM and Forest Service leasing and development decisions, either Development through BLM’S internal administrative protest procedures or through the Decisions Have Been courts. Recent lease sale protests have generally focused on two con- cerns:4 (1) the stipulations attached to a lease were not adequate and (2) Contested the cumulative impacts of oil and gas development were not adequately addressed in developing an EISor other environmental study. As of May 1989, lease sales had been protested in Colorado, Montana, Utah, and Wyoming. Additionally, since June of 1987, an environmental group has been appealing the adequacy of the environmental study cov- ering portions of four forests in California. Several groups have pro- tested recent lease sales, in part, because stipulations were (1) not identified in the land use plans; (2) when identified, were not attached to the leases involved in the sales; or (3) challenged as not being effec- tive. BLM generally upheld these protests and either retroactively attached the required stipulations to the leases or suspended the sales. Although both agencies have been subjected to administrative protests, the Forest Service has borne the brunt of the litigation. The Forest Ser- vice has faced intensive scrutiny by environmental groups because, it is generally agreed, the Forest Service has more environmentally sensitive lands. Three recent circuit court decisions involving Forest Service lands have addressed the level of information necessary to make adequate leasing and development decisions and meet NEPA requirements. Two decisions involved cases in which BIB issued leases on over 1 mil- lion acres of Forest Service lands. The District of Columbia Circuit Court6 and the 9th Circuit Court in California6 found that unless leases are issued with no-surface-occupancy stipulations, leasing constitutes an “irretrievable and irreversible commitment of resources.” As such, under NEPA, the environmental impacts of the proposed actions must be assessed in EISS before leases are issued. The courts held that leases lacking no-surface-occupancy stipulations only give the government the right to impose reasonable conditions on the development, not the right to prevent development. Therefore, the courts have held that the envi- ronmental impacts of the proposed actions must be assessed before 4Since BJA issues the leases for federal lands, lease sales are challengedthrough the BLM adminis- trative protest process. If Forest Service lands are involved, the Forest Service assists in resolving the protest. 5Sierra Club v. Peterson, 717 F2d 1409, D.C. Circuit, 1983. ‘Conner v. Burford, 848 F2d 1441,Qth Circuit, 1988. Page 32 GAO/RCEMO-71 Oil and Gas Decisions Chapter 2 Oil and Gas Leasing and Development Continue Without Adequate Inf’ormation And/Or Mitigating Stipulations issuing the leases. The courts held that the agencies could issue leases with no-surface-occupancy stipulations without first completing EISS because they reserved to the government the absolute right to preclude all surface-disturbing activity. In another case, challenging the issuance of one lease, the 10th Circuit in Colorado ruled that the Forest Service’s environmental assessment, which concluded that the issuance of oil and gas leases in the Shoshone National Forest would have no significant impact on the environment, was adequate.’ The court held that the Forest Service did not have to prepare an EIS because (1) it had prepared an extensive environmental assessment, (2) the lessee’s development plans were too speculative to trigger the need for an EIS, and (3) the lease subjected all development proposals to continuing NEPA review. Industry groups believe the Conner and Park County decisions are inconsistent and petitioned the Supreme Court to review the Conner decision. Industry argued that under Conner leasing will always require preparing an EIS, while under Park County leasing did not have to be preceded by an EIS. The Supreme Court denied the petition for review on February 21, 1989. These administrative or judicial actions have delayed oil and gas devel- opment activities. To date, the Forest Service has formally suspended leasing on about 35 million acres of land, pending completion of environ- mental studies that adequately assess the cumulative impacts of devel- opment, and BLM has done the same for several thousand acres of its lands. A number of administrative protests and lawsuits have occurred Conclusions because leasing and development decisions were based on inadequate information about the environmental impacts of oil and gas activities, and because leases were issued and drilling permits approved without including all of the required stipulations or conditions of approval. Some of these protests and court decisions have resulted in leasing and devel- opment being suspended on about 35 million acres of Forest Service land and on several thousand acres of BLM land. The agencies have resolved other protests by retroactively attaching the required stipulations to the leases. 7Park County Resource Council, Inc. v. US. Department of Agriculture, 817 F2d 609, 10th Circuit, 1987. Page 33 GAO/RCED9&71 Oil and GM Decisions Chapter2 Oil and Gas Leasing and Development Continue Without Adequate Information And/Or hiit&ating Stipulations Most BLM and Forest Service land use plans and related environ- mental studies for resource areas and forests with high oil and gas potential do not contain adequate information necessary to make informed decisions about the environmental impacts of oil and gas leasing and development. Although the plans and studies are often deficient, BLM and the Forest Service often relied on these plans and studies when issuing leases and approving drilling permits. We recognize that the expiration of the tax credit for nonconventional fuel sources placed added pressure on BIN and the Forest Service to con- tinue approving drilling permits in the Fruitland Formation while the necessary environmental studies were still ongoing. However, these agencies recognized that they did not meet NEPA requirements. Regard- less of the final outcome, we believe that approving permits to drill without having first completed the environmental studies required by WA regulations does not meet the spirit of a multiple-use philosophy because it places oil and gas development ahead of the use of other resources, and does not comply with NEPA. Page34 GAO/RCED-9@7lOilandGas Decisions Status of BLM and Forest Service Initiatives to Improve Information and Related Cost Estimates BLM and the Forest Service have begun to improve their information on the environmental impacts of oil and gas activities. However, we believe that more needs to be done. BLM plans to develop the needed information by amending land use plans or completing new ones. Towards this end, it has identified resource areas with high oil and gas potential and/or high industry interest and plans to amend existing plans or prepare new ones for many of these areas. The Forest Service’s approach to devel- oping the needed information is less clear, but it appears that the regional offices will have the option of amending existing land use plans, supplementing the plans with additional environmental studies before issuing leases or approving drilling permits, or clarifying infor- mation already contained in the plans. As a first step, regional offices have identified those forests that they believe need more detailed oil and gas information. We believe, however, that both BLM and the Forest Service may have underestimated the number of resource areas and forests, respectively, that need additional information on the environmental impacts of oil and gas activities before issuing leases or approving permits to drill. Until BLM and the Forest Service accurately determine the total number of plans and studies that need to be amended or prepared, the total cost to improve oil and gas information will be unknown. However, we believe that developing this information may be cost-effective for resource areas and forests with high oil and gas potential because fore- gone and delayed revenues resulting from suspended leasing activities appear to far exceed any reasonable estimated cost to develop such information. After the reform act was passed in 1987, BLM increased its efforts to BLM Plans to Improve incorporate more oil and gas information into its land use plans. How- Oil and Gas ever, we believe that to the extent that land use plans are used to make Information but leasing and development decisions, more resource areas than currently identified and scheduled by BLM may require additional oil and gas Underestimates the information. Number of Resource Information provided to us by BLM in March 1990 and supplemented in Areas an April 18, 1990, Federal Register notice, indicates that BLM has identi- fied 49 resource areas with high oil and gas potential and/or high interest to industry that need improved oil and gas information. BLM officials told us that 2 new plans have been completed, and 24 new plans and 13 amendments covering the 49 resource areas are tentatively Page 36 GAO/RCED9@71Oil and Gas kisions Chapter 3 Statue of BLBf and Forest Service Initiativea to Improve Information and Belated Cost Jzalmatea scheduled to be completed by fiscal year 1996. (See table VII.1 in app. VII, for BLM’S schedule.) Generally, BLM is preparing new plans for those resource areas currently operating under a management framework plan. Management frame- work plans are planning documents usually completed prior to the enactment of FLPMA;they do not have EISSand/or meet current require- ments for public involvement. BLM has determined that these plans do not meet its supplemental program guidance. It believes that when these scheduled efforts are completed, virtually all of BLM’S land use plans for identified oil and gas priority areas will comply with its supplemental program guidance. BLM plans to develop new plans or amendments for 45 of the 55 resource areas that we identified as having both high oil and gas potential and inadequate land use plans for making well-informed oil and gas leasing and/or development decisions.’ We believe that improved oil and gas information may be required for the remaining 10 resource areas. (See table VII.2 in app. VII for a list of these resource areas.) A 1988 internal assessment by the Forest Service concluded that almost Forest Service Plans to all of its land use plans and accompanying EISS would not meet existing Improve Oil and Gas oil and gas planning requirements. The Forest Service has begun to Information but improve its oil and gas information. Responding to our September 1989 testimony that addressed inadequacies in the Forest Service’s land use Approach Unclear pla.n~,~the Forest Service Chief issued an October 11, 1989, directive to the regional foresters that land use plans must provide a good basis for oil and gas leasing decisions when there is oil and gas potential or interest in leasing. Offices were instructed to prioritize forests and com- plete additional environmental studies, including amending land use plans when appropriate. As of March 1990, the Forest Service had iden- tified 46 forests on the basis of industry interest for oil and gas leasing that need improved oil and gas information. Fifteen of these forests were not identified by us as high oil and gas potential areas. As of ‘Of the 49 resource areas identified by BLM, 4 were not included on our list of plans that may require additional information. We reviewed plans for two of these areas-the Cody resource area plan in Wyoming and the Book Cliffs resource area plan in Utah-and found that both met our criteria for all five elements. We did not evaluate the Border resource area plan in Oregon or the Lahontan resource area plan in Nevadabecause they were not on our list of oil and gas resource areas with high potential. 21mplementation of the Federal Onshore Oil and Gas Leasing Reform Act of 1987, (GAO/T- RcEbs9-69, Sep. 28, 1989). Page 36 GAO/RcED-go-71Oil and Gas Decisions Chapter 3 Statns of BLM and Forest Service Initiatives to Improve Information and Related cost Bstimates March 1990, the Forest Service had completed additional studies for five forests; the remaining studies are expected to be completed by fiscal year 1994.” (See table VII.3 in app. VII for the Forest Service’s tentative schedule.) In addition to the 46 forests the Forest Service identified (31 of which we also identified), we identified another 24 forests with high oil and gas potential that had limited information on oil and gas in their land use plans. We believe that many of these 24 forests may require improved oil and gas information prior to making leasing and develop- ment decisions. (See table VII.4 in app. VII for a list of these forests.) Until BLM and the Forest Service determine the total number of land use An Accurate Estimate plans and environmental studies that need to be completed or amended, of the Total Cost to the total cost cannot be estimated with any degree of certainty. How- Develop Additional Oil ever, we computed rough cost estimates for BLM to develop 24 new plans and to amend 13 existing plans by using costs provided by BLM head- and Gas Information Is quarters to develop new plans or amendments. According to BLM head- Not Possible Now quarters planning officials, a state office is normally allocated $300,000 to develop a new plan and $100,000 to amend an existing plan. Applying these amounts to the 37 plans to be developed or amended, we estimate that revisions would cost about $8.5 million. Adding the 10 additional resource areas that we believe may require new plans or amendments would increase the cost even further. BLM officials generally agree that the amount allocated by headquarters to prepare or amend a plan are less than the total cost incurred. BLM’S Chief of Planning and Environmental Coordination stated that the agency does not know the actual cost of preparing a land use plan or the cost of amending an existing plan to improve oil and gas information. Although $300,000 is an estimate of the costs needed to prepare a new plan, he said this estimate does not generally include funding for resource specialists who participate in preparing the plan. BLM’S Colo- rado state office officials estimated that the actual cost of preparing a land use plan may be $400,000. Because the Forest Service is still not sure how many of the 46 forests identified as needing improved oil and gas information will require amended land use plans, supplemental environmental studies, or clarifi- cations to the plans, and has no agencywide estimates of the costs to %me of these studies will cover portions of the forests, not the entire forest. Page 37 GAO/RCEIMO-71 Oil and Gas Decisions Chapter 3 Status of BLM and Forest 8ervic.eInitiatives to Improve Information and Related cost Bstimates complete these different analyses, no accurate estimate of total cost is possible at this time. However, we believe that whatever cost estimate the Forest Service finally develops should include the costs needed to improve the oil and gas information in the additional 24 forests we iden- tified as having high oil and gas potential. In areas where industry interest is high because of oil and gas potential, Improving Oil and Gas foregone and delayed revenues resulting from suspending leasing activi- Information Appears ties are likely to exceed the costs associated with developing adequate to Be Cost-Effective environmental information. Until these resource areas and forests have adequate environmental documentation to support leasing decisions, the federal government will continue to lose rental revenue, and receipt of bonus bid and royalty revenue will be delayed. For example, the Forest Service’s Region 1, which covers 24 million acres and includes 15 forests in northern Idaho, Montana, North Dakota, and northwest South Dakota, suspended leasing in 1985 following a dis- trict court decision that the Forest Service had not adequately assessed the environmental impacts of its leasing decisions4 We estimate that about $9.6 million in rental revenue is lost annually on the 5.4 million acres that the Forest Service believes would be leased in the region and on leases that have been suspended because existing environmental studies do not comply with NEPA. By comparison, the Forest Service esti- mates that it will cost between $140,000 and $620,000 to complete addi- tional environmental studies for each of the six forests with high oil and gas potential in Region 1, or a total of about $1.9 million. In addition to foregone rental revenue, bonus bids and additional roy- alty revenues cannot be generated until leasing resumes. For example, in fiscal year 1987, Region 1 suspended leasing in the Little Missouri National Grasslands in the Custer National Forest. The Forest Service estimates that it will cost $620,000 to complete the environmental studies for the Custer National Forest-a portion of which will directly relate to the Little Missouri National Grasslands. The Forest Service esti- mates that about 336,000 acres will be leased in the Little Missouri National Grasslands. We estimate that this will generate about $22 mil- lion in bonus bids. The Forest Service estimates that about $1.1 million in royalties would have been generated annually in the Little Missouri National Grasslands had companies been allowed to lease the land and 4Conner v. Burford, 605 F Supp. 107 (D.Mont. 1986). Page 38 GAO/RcEDso-71 Oil and Gas Decisions Chapter 3 Status of BLM and Forest Service Lnitiatives to Improve Information and Related cost Estimates drill wells. In addition, about $500,000 of the $9.6 million in rental rev- enue identified above is lost annually. Although BLM and the Forest Service recognize the importance of Conclusions improving information on the environmental impacts of oil and gas leasing and development, it will be many years before they complete or amend all plans and/or environmental studies for resource areas and forests with high oil and gas potential to include such information. Overall estimates of the cost to develop this information to meet NEPA requirements cannot be determined until both agencies have a better understanding of how many plans and studies are deficient and what it will take to improve them. However, available cost estimates for indi- vidual projects indicate that it may be cost-effective to improve oil and gas information for resource areas and forests with high oil and gas potential. Estimated foregone and delayed revenues resulting from sus- pended leasing activities far exceed any reasonable estimated cost to develop such information. To ensure that resources available to improve oil and gas information Recommendations are used efficiently, we recommend that the Secretaries of the Interior and Agriculture direct the BLM Director and Forest Service Chief, respec- tively, to determine which resource areas or forests will yield the most revenues and give priority to revising plans or studies for those areas so oil and gas development can proceed expeditiously, with the least pos- sible damage to the environment. Both Interior and the Forest Service generally agreed with the facts in Agency Comments and this chapter and support this recommendation. Interior added that it GAO’s Evaluation believes the recommended approach would help refine the schedule for land use planning. Although Interior believes that it has already identi- fied its resource areas with high oil and gas potential, we continue to recommend that it determine which resource areas are likely to yield the most revenues and give priority to revising those plans. Page 39 GAO/RCED9O-71Oil andGas Decisions Improved Internal ManagementControls Must Accompany Agency Initiatives If BLM and Forest Service initiatives to improve information on the envi- ronmental impacts of oil and gas leasing and development are to be suc- cessful, improvements to existing management controls must also take place. Specifically, (1) BLM and the Forest Service need to improve their guidance on how to address cumulative impacts in land use plans and environmental studies, (2) the Forest Service needs to clarify its recently issued guidance on what types of environmental studies will be required, and (3) both agencies need to institute more effective over- sight to ensure compliance with land use planning and environmental regulations and guidance. The key element most often missing from land use plans and related Better Agency environmental studies is cumulative impacts. NEPA requires that cumula- Guidance Needed on tive impacts be disclosed in land use plans; however, the agencies did Addressing not provide clear guidance on how to develop this information. While both agencies have improved their guidance, it is still inadequate for Cumulative Impacts assessing the cumulative impacts of oil and gas leasing and development. BLM Guidance BLM’S November 1986 supplemental program guidance identified the type of oil and gas information that should be included in land use plans and related EISS.To address cumulative impacts, this guidance states only that such impacts should be assessed for each alternative presented in the land use plan. In 1987 BLM concluded that its guidance for assessing cumulative impacts was both unclear and inadequate. In October 1988, responding to the need for more detailed guidance, BLM issued a handbook providing instructions for complying with NEPA. This was followed in February 1989 by a draft fluid minerals handbook that provided even more detailed guidance on how to develop oil and gas information. However, neither BLM’S NEPA handbook nor its draft fluid minerals handbook provide adequate guidance for analyzing cumulative impacts. Forest Service Guidance The guidance in effect during the development of the Forest Service’s land use plans was diffused throughout the agency’s planning regula- tions, manuals, and handbooks, and did not provide adequate informa- tion on how to develop a reasonably foreseeable development scenario or assess cumulative impacts. In a May 1988 memorandum, the Forest Service Chief agreed to consolidate the Forest Service’s planning gui- dance, incorporating the major elements of BLM’S supplemental program Page 40 GAO/RCED9@71Oil and Gas Decisions Chapter 4 Improved Internal Management C4mtrola Mnst Accompany Agency Initiatives guidance. This consolidated guidance was issued on October 11, 1989. The revised guidance defined the reasonably foreseeable development scenario, and like BLM’S draft fluid minerals handbook, listed the factors to be considered when projecting such a scenario. However, it does not provide clear direction on developing cumulative impacts analyses. The Forest Service’s revised guidance is also unclear about what types Forest Service Needs of environmental studies will be required to support oil and gas leasing Clear Guidance on and development decisions. It provides several options for meeting its What Types of requirements: (1) amending existing land use plans and completing appropriate environmental studies; (2) tiering additional environmental Environmental Studies studies to existing land use plans before issuing leases or approving Will Be Required drilling permits; or (3) supplementing land use plans with “additional clarification” that may or may not require additional environmental studies. However, there is no further discussion in the guidance as to when each of these options may be appropriate. We believe that further clarification is needed because the level of detail in the studies required to be completed under each of these options varies significantly. Although both BLM and the Forest Service are improving their guidance More Direct Oversight on land use planning and environmental studies, the decentralized and Evaluation of nature of the two agencies provides no assurance that the improved gui- Field Offices Needed dance will be followed. Neither agency has the necessary oversight and evaluation in place to ensure that field offices adhere to their national policies and guidance. Under BLM’S and the Forest Service’s decentralized management philos- ophy, effective program oversight and evaluation are needed to provide management with feedback to measure performance and, when neces- sary, to correct performance problems. However, this oversight and evaluation has not accompanied devolution of responsibility for oil and gas leasing and development decisions. Neither agency can ensure that land use plans and related environmental studies comply with land use planning and environmental regulations and guidance. In addition, neither agency has the necessary internal management controls in place to ensure that leases and drilling permits include all the necessary stipu- lations As a result, resource area and forest offices lack uniformity in (1) their interpretation and implementation of land use planning and environmental regulations and guidance and (2) the extent to which all required stipulations and conditions of approval are attached to leases and drilling permits. Page 41 GAO/RCEIh9@71Oil and Gas Decisions Chapter 4 Improved Intemal Management Conlz-ols Must Accompany Agency Initiatives Compliance With Planning Although BLM and Forest Service field offices are responsible for devel- Regulations and Guidance oping land use plans, neither agency has adequate systems in place to ensure that applicable regulations and guidance are followed. As a Varies Among Field result, the extent to which land use plans contained the necessary infor- Offices mation varied among BLM state and Forest Service regional offices. For example, six of the eight plans we reviewed from BLhI'S Utah state office met our criteria for at least four of the five elements, whereas the four plans we reviewed from BL.M'S Nevada state office met our criteria for only two or fewer of the elements. Similarly, the six plans we reviewed from the Forest Service’s Region 1 generally met our criteria for two or more of the five elements, whereas the three plans we reviewed from the Forest Service’s Region 3 met our criteria for only one or none of the elements. BIN headquarters issued a memorandum in May 1988 reiterating the importance of the supplemental program guidance and the requirement that it be incorporated into land use plans. For areas of high oil and gas potential, the guidance directs that the plans contain more detailed information. Officials at the four BLM state offices we visited said that although they did not incorporate the supplemental program guidance into their land use plans, they believe the plans they have approved comply with both FLPMAand NEPA requirements. BIN Wyoming State Office officials, for example, stated that they view the supplemental program guidance as optional guidance, not policy, that does not neces- sarily have to be complied with. According to officials of the three Forest Service regional offices we vis- ited, the resource specialists who prepare the plans in the local forest offices often lack the oil and gas expertise needed to develop the neces- sary information. Additionally, although the regional offices are respon- sible for approving land use plans, some regions also lack the necessary oil and gas expertise. This lack of knowledge, coupled -with the lack of agencywide guidance, make it difficult to reach informed decisions on the environmental impacts of oil and gas activities. BLM and Forest Service headquarters officials told us that they have lim- ited control over the quality of the land use plans developed by resource area and forest offices and approved by state and regional offices, respectively. Under the agencies’ decentralization philosophies, these officials view their role as being primarily responsible for providing gui- dance, training, and technical assistance to their respective state and regional offices. They look to their state and regional offices to provide the necessary systems or controls needed to ensure adherence to land Page 42 GAO/ECJZD90-71Oil and Gas Decisions Chapter 4 Improved Internal Management Controls Must Accompany Agency Initiativives use planning and NEPA policies and procedures. And, although all Forest Service plans must be routed through Forest Service headquarters, review at this level is limited primarily to format rather than content. Incorporating Required The extent to which BLM resource area offices and Forest Service forest Stipulations or Conditions offices included all needed stipulations and conditions of approval in leases and permits also varied. For example, 26 (or 31 percent) of the 85 of Approval Into Leases permits reviewed at BLM'S Caliente resource area, in California, did not and Permits Varies Among have 1 or more of the conditions of approval required by the land use Field Offices plans and/or other environmental studies, while only 3 (or 4 percent) of the 80 permits reviewed at the Farmington, New Mexico, resource area had been approved without the appropriate condition(s). Similarly, 11 (or 69 percent) of the 16 permits reviewed at the Carson National Forest, in New Mexico, were missing 1 or more conditions, while 2 (or 20 percent) of the 10 permits reviewed at the Medicine Bow National Forest, Wyoming, had been approved without the appropriate condi- tion(s) included. BLM and Forest Service officials explained that stipulations are missing from some leases because the responsible BLM state office or Forest Ser- vice regional office did not ensure that it had the most current informa- tion from the affected resource area or forest. Colorado BLM officials also said stipulations are missing from some leases because the wording in the applicable land use plans is vague or inconsistent with other studies. Moreover, these officials believe that drilling permits have missing conditions of approval because resource specialists responsible for identifying the potential impacts of oil and gas development on other resources did not properly review the permits to ensure all conditions were included. The Rocky Mountain Regional Coordinating Committee, with the sup- port of the BLM Director and Forest Service Chief, has issued guidance that is intended to standardize language for lease stipulations identified in land use plans, making it clearer when and what stipulations are applicable. However, without effective oversight, BLiM and the Forest Service will not know the extent to which field officials are complying with this guidance. Moreover, there is no system to ensure communica- tion and coordination among the responsible BLM state, district, and resource area offices, or between the responsible Forest Service regional office and the affected forest office to ensure that stipulations are attached to leases on the basis of the most current information avail- able. There is a need for similar coordination and communication among Page 43 GAO/RCEDS@71Oil and Gas Decisions Chapter 4 Improved Internal Management Controls Must Accompany Agency Initiatives resource specialists before a drilling permit is approved by a resource area or forest office. BLM and the Forest In its 1987 NEPA evaluation report, BLM concluded that program manage- Service Recognizea Need ment and quality control (oversight) improvements were needed at both the headquarters and state office levels. BLM state offices generally for Management Controls agreed with the evaluation report’s recommendation and made a com- mitment to improving their program management and oversight strate- gies. In addition, in commenting on a draft of our report, Interior stated that BLM is planning to review its planning and NEPA compliance processes to improve its performance and is reorganizing its fluid min- erals group in headquarters to improve efficiency. BLM also plans to issue additional guidance on its oil and gas program, including draft gui- dance on how to develop cumulative impact analysis. The Forest Service has recognized the need to improve management con- trols to ensure that NEFJArequirements are adequately addressed before making leasing or development decisions and to ensure appropriate stip- ulations or conditions of approval are attached to leases or drilling per- mits, respectively. In commenting on a draft of our report, the Forest Service stated that it has recently established an advisory group with expertise drawn from minerals, environmental, and planning staffs. Among other things, this group will coordinate with Agriculture’s Office of General Counsel and provide advice to the Forest Service manage- ment team on how to prepare environmental studies. It will also periodi- cally review the environmental studies in process. In the last few years, BLM and the Forest Service have improved their Conclusions guidance on the oil and gas information to be included in land use plans and related environmental studies. In particular, the Forest Service’s recently issued guidance on analyzing oil and gas environmental impacts is an improvement over earlier guidance that was diffused throughout the agency’s planning regulations, manuals, and handbooks. However, as recognized by the agencies, clearer guidance is still needed on how to address cumulative impacts. In addition, the Forest Service guidance provides several options for meeting the guidance but does not provide clear direction on how to decide when each option is appropriate. Both BLM and the Forest Service are improving their guidance for land use planning and environmental studies, as well as their guidance on when and where stipulations or conditions of approval are applicable. Page 44 GAO/RCED-90-71Oil and Gas Decisions Chapter 4 Improved Internal Management Controls Must Accompany Agency Initiatives However, the decentralized nature of the two agencies, coupled with the lack of effective management controls and program oversight and evalu- ation, provides no assurance that the improved guidance will be adhered to. Delegation of responsibility for approving land use plans and for making leasing and development decisions that affect other resources carries with it an implied accountability. Yet, neither BLM nor the Forest Service has instituted the necessary internal management controls to ensure that in taking these actions, its field offices will comply with applicable planning regulations and guidance. To better ensure that the environmental impacts of oil and gas leasing Recommendations and development on federal lands are adequately considered in land use plans and at subsequent key decision points and that available’ resources are used efficiently, we recommend that the Secretaries of the Interior and Agriculture direct the BLM Director and the Forest Service Chief, respectively, to l provide clear guidance on how to address cumulative impacts in land use plans and related environmental studies. In addition, the Forest Ser- vice Chief should be directed to clarify when the recently issued gui- dance can be met by amending the land use plan, completing additional environmental studies, or supplementing the plan with additional information. l establish an oversight and evaluation program to ensure that (1) NEPA requirements are adequately addressed, whether in land use plans and/ or other environmental studies, before leases are issued or permits to drill are approved; and (2) appropriate stipulations or conditions of approval are attached to leases and permits. As part of this program, the BLM Director and the Forest Service Chief should establish measur- able goals and target dates to correct identified problems. Both Interior and the Forest Service generally agreed with the facts in Agency Comments and this chapter and supported our recommendations. Although Interior did GAO’s Evaluation not specifically address our recommendation regarding the need for additional guidance on cumulative impacts, it indicated that it plans to issue such draft guidance. The Forest Service disagreed with us regarding missing conditions of approval from drilling permits and, in most cases, considered such conditions standard operating procedures, and therefore did not believe these conditions needed to be included. Page 48 GAO/RCED90-71Oil and Gas Decisions Chapter 4 Improved Internal Management C4mtrola Must Accompany Agency Initiadves However, we identified several types of conditions missing from the per- mits including cultural, wildlife, and road restrictions that are not con- sidered standard operating procedures in every forest. We have summarized the actions BLM and the Forest Service are taking in this chapter. Page 40 GAO/WED90-71 Oil and Gas Decisions Page 47 GAO/RCEDBO-71Oil and Gas Decisions Appendix I List of ElementsReviewedAnd Associated NEF?AAnd/Or Agency Regulatory Or GuidanceCitations Elements Requirements GAO criteria identification of areas open BLM Supplemental Program Guidance (SPG) 1624.21 Full response to leasing and applicable stipulations Identify areas open and closed to development. For A map, narrative, or table identifying areas that are (1) land open to development, identify areas subject to open subject to standard lease terms and conditions; standard lease terms and conditions, areas subject to (2) open subject to moderate protection (such as seasonal or other minor constraints, areas subject to restricted seasonable use stipulations; (3) open no-surface-occupancy and similar major constraints. subject to maximum protection (such as no-surface- The boundaries of these areas are to be portrayed on occupancy stipulations); and (4) closed to leaslng. maps. Partial response Forest Service planning regulations, 36 CFR 219.22(f) A narrative discussing acreage or percentage of areas Recognize the probable effect of renewable resource with appropriate stipulations without identifying prescriptions and management direction on oil and specific areas. gas exploration and development (resource prescriptions are translated into stipulations). A narrative or table listing stipulations that will apply in given certain circumstances without identifying National Environment Policy Act (NEPA) regulations, 40 specific areas (e.g., if wildlife exists, apply wlldlife 14(t) protection stipulation). Include appropriate mitigation measures (stipulations) A map, narrative or table identifying one or more of the not already included in the proposed action or required stipulations, but not all of them. alternatives. Oil and gas potential BLM SPG 1624.22(A) Full response The potential for fluid mineral occurrence should be A map, narrative, or table identifying areas of high, assessed using BLM’s classification system as well as medium, low, unknown, or no potential for oil and gas. public interest that has been shown in an area. Should be in a table format with low, moderate, high and Partial response unknown potential. A narrative or table discussing acreage or percentage Forest Service planning regulations, 36 CFR 219.22(c) of potential, but not identifying specific areas. Recognize the probable occurrence of leasable A map, narrative or table discussing drilling and minerals (oil and gas); the potential for future mineral production activity, without a discussion of other development. potential in the area. NEPA regulations, 40 CFR 1502.15 Succinctly describe the environment of the area(s) to be affected or created by the alternatives under consideration. (Oil and gas potential is one aspect of the environment.) - Reasonably foreseeable BLM SPG 1624.22(B) Full response development scenarios Reasonably foreseeable development scenario A map, narrative, or table projecting the anticipated projections should usually be expressed in terms of level of oil and gas development in terms of number of the number of wells and fields. Such projections wells over the life of the plan. These projections should should vary depending on the potential for fluid be based on mineral potential and development mineral occurrence and which areas are open to history. development. Partial response Forest Service planning regulations, 36 CFR 219.22(e) A general narrative of future oil and gas development Recognize the access requirements for mineral in the area. exploration and development. (continued) Page 48 GAO/RCEXNO-71Oil and Gas Decisions Appendix I List of Elements Reviewed And Associated NEPAAnd/Or Agency Regulatory Or Guidance Citations Elements Requirements GAO criteria A narrative or table of the number of expected leases Forest Service Manual 2806.4 However, no discussion on posstble development of these leases. An activity forecast should be in the plans, projecting the most probable types of oil and gas activities A narrative of strpulations that will be imposed and expected to occur and where the actrvity IS most likely their effect on oil and gas development to occur. A map or narrative on currently producing fields and NEPA regulations 40 CFR 1502.16 their life expectancy. The agency must disclose reasonably foreseeable future actions in order to assess cumulative impacts. Indirect impacts BLM planning guidance 1600 series, 1616.62 Full response Discuss the indirect impacts In estimating the effects A map, narrative, or table of the types of impacts to of alternatives. other resources expected from surface and subsurface activities such as clearing land, drilling, Forest Service planning regulatrons, 36 CFR 219.12(g) building roads, and/or installing pipelines. This discussion must address significant resources such as The estimated effects of the alternatives will be wildlife, cultural values, soil, vegetation, air and water considered in detail according to NEPA procedures quality. We did not require the plan to disclose the (Includes indirect impacts). magnitude of indirect impacts associated with different levels of development; therefore, we NEPA regulations 40 CFR 1502.16(b) and 1508.8 accepted indirect impact discussions without disclosure of a reasonably foreseeable development Discuss the environmental impacts of alternatives scenarto. including indirect effects and their significance. Indirect effects, which are caused by the action (i.e., Partial response oil and gas exploration and development) and are later in time or farther removed In distance, but are still A narrative or table on the impact(s) of 011and gas reasonably foreseeable. Indirect effects may include development to some, but not all resources In the related effects on air and water and other natural area. systems, including ecosystems. A narrative or table that identifies resources that will be affected by oil and gas development; however, does not describe how they will be affected Cumulative impacts of BLM SPG 1624.22(B) Full response reasonably foreseeable development scenarios The cumulative impacts of reasonable foreseeable For those plans containing a reasonably foreseeable development scenarios should be analyzed in detail. development scenario, a narrative specrfically ctting the term “cumulative impacts”. Webid not evaluate Forest Service planning regulations, 36 CFR 219.12(g) the adequacy of these citations because at the time of our review neither agency had criteria for developrng The estimated effects of alternatives WIII be cumulative impacts as they relate to oil and gas considered in detail according to NEPA procedures. development. Reasonably foreseeable development scenarios were required to be fully addressed In order NEPA regulations 40 CFR 1502.16(b) and 1508.7 to receive a complete response for cumulative impacts because cumulative impacts are the incremental Discuss the environmental impacts of the alternatives impacts of the proposed actions, which cannot be including the cumulative impacts. Cumulative impact assessed without the expected level of development. is the impact on the environment, which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. Page 49 GAO/WED-W71 Oil and Gas Decisions Amendix II Resultsof BLM Land Use Plan Review Reasonably Lease stips Oil and gas foreseeable Indirect Cumulative Resource area identified potetiial dev.scenario impacts --___impacts California California Desert P Y P Y N Caliente Y Y N Y N Hollister P Y P P N Colorado ..____~ Glenwood Sonnas Y P N P N Grand Junction Y Y Y Y Y Kremmling P Y P P N Little Snake Y Y N Y N Northeast Y Y N Y N San Juan Y Y P P t2 Uncompahare Y Y Y Y Y White River P Y P Y N Montana ___. Billings P Y P Y N Garnet P Y P Y N Great Falls, Havre Y Y Y Y Y Headwaters Y P P Y N North Dakota P P P Y N Powder River Y Y P N - N South Dakota P Y N Y N Nevada ___- Egan P Y N N N Elko Y Y P P N Eureka, Shoshone N Y N N N Wells P N P P N New Mexico Carlsbad Y Y P Y N Farmington P P N N N Rio Puerto P P P N ~-____ N Taos Y Y P N N Wenatchee (Spokane District) Y N Utah Bear River P N Book Cliffs Y Y Grand Y -- .____ N San Juan Y N (contrnued) Page 60 GAO/RCJD9l%71Oil and Gas Decisions Appendix II Resulta of BLM Land Use Plan Review Reasonably Lease stips Oil and gas foreseeable Indirect Cumulative identified potential dev.scenario impacts impacts Y Y Y P N Wvomina Y Buffalo P Y Y Y Y Cody Y Y Y Y N Great Divide P Y Y P (Formerly Medicine Bow and Divide) Kemmerer P Y N Y N Lander Y Y Y Y N Pinedale Y Y Y Y Y Platte River Y Y Y Y N Washakie Y Y Y Y N Daft plan was revlewed Legend Y = Yes, element fully addressed P = Partial, element partially addressed N = No, element not addressed Page 51 GAO/RCED-9@71Oil and Gas Decisions Appendix III Resultsof Forest ServiceLand Use Plan Review Reasonably Lease stips. Oil and gas foreseeable Indirect Cumulative Forest Region identified potential dev.scenario imPacts imoacts Alabama Conecuh, Bankhead, 8 P N P Y N Talladega” and Tuskaqeea Arkansas Oauchita 8 P Y P P N Ozark and St. Franci 8 P P P P N California Angeles 5 P N P N N Los Padres 5 P Y N P N Colorado Arapaho and Roosevelt 2 Y Y Y Y N Grand Mesa, Gunnison and Uncompahgre 2 P N N Y N Pike and San Isabela 2 P Y P P N Routte 2 P Y P N N San Juan 2 P P Y Y N White River 2 P Y P P N Kentucky Daniel Boone 8 P P P Y N Louisiana Kisatchie 8 Y Y Y P Y Michigan Huron and Manistee 9 P Y P N N Mississippi Bienville, Delta, 8 N P P Y N De Soto. Holly Springs” . Homochitto and Tombigbee Montana Custer 1 Y P P Y N Flathead 1 P Y N Y N Lewis and Clark 1 Y Y Y Y Y Lolo 1 Y Y Y P Y Beaverhead 1 P Y P Y N Gallatin 1 Y Y P P N (continued) Page 62 GAO/RCEMJO-71Oil and Caa Decisions Appendix III Results of Forest Service Land Use Plan Review Reasonably Lease stips. Oil and gas foreseeable Indirect Cumulative Forest Region identified potential devscenario impacts impacts Nebraska 2 P Y P Y N Nevada Humboldt 4 P Y P Y N Toiyabe 4 P Y N Y N New Mexico Carson 3 P P P N N Cibola 3 Y P P P N Santa Fe 3 Y P N N N Wayne 9 P Y P Y N Pennsvlvania Alleahenv 9 P P P Y N Texas An elina, Davy 8 N Y Y Y N 2 rockett, E;;Fo;nd Sam Utah Ashley 4 P Y P Y N Cache and Wasatch 4 Y P P Y N Dixie 4 P Y P Y N Manti Lasalle 4 P Y Y Y N Uinta 4 Y Y P N N Virginia Georae Washinaton 8 Y Y P N N Jefferson 8 P Y P P N West Virginia Monongahela 9 P N P P N Wyoming Biahorn 2 P Y P Y N Bridaer-Tetonb 4 P P Y Y Y Medicine Bow 2 Y P P Y N Shoshane 2 P Y P Y N =This forest is not located In a high oil and gas potential area; however, it was Included In a land use plan that covers at least one forest wrth high 011and gas potentral. bDraft plan was revrewed. Legend Y = Yes, element fully addressed P = Partral, element partially addressed N = No, element not addressed Page 63 GAO/WED-SO-71Oil and GasDecisions Appendix IV Resultsof BLM and Forest ServiceLand Use - Plan Review for SocioeconomicImpacts In addition to the 5 elements required in the land use plans, we reviewed the 82 plans located in oil and gas provinces to determine whether the plans addressed the socioeconomic consequences of oil and gas explora- tion and development. We looked for a narrative or table assessing the future impacts of oil and gas on the local economy. These effects may be expressed in terms of jobs and/or actual dollars. Table IV.1 shows the number of plans that identify socioeconomic consequences: Table IV.l: Extent to Which Plans Identify Socioeconomic Consequences Extent element Forest addressed ELM Percent Service Percent Total Percent Socioeconomic consequences identified in jobs and dollars to the local economv 24 60 27 64 51 62 Socioeconomic consequencesnot addressed 16 40 15 36 31 38 Total 40 42 82 Fifty-one plans discussed the socioeconomic consequences of oil and gas development. These plans discussed the number of jobs created and dol- lars generated for the local economy as a result of oil and gas explora- tion and development- although the length and quality of the discussion varied among the plans. For example, one BLM resource area plan projected the employment and annual salaries and wages that could be expected as a result of oil and gas activity. Thirty-one plans did not discuss socioeconomic consequences specifically in terms of jobs and dollars generated. Page 64 GAO/RCEDsO-71Oil and Gas Decisions ADDendiX V Extent to Which BLM and Forest ServiceLand Use Plans Met the Criteria by Element Tables V.l through V.5 list the number of land use plans that met, partially addressed, or did not address each of the five key elements. Table V.l: Extent to Which Plans Addressed Oil and Gas Potential BLM Forest Service Total plans Extent element addressed Number Percent Number Percent Number Percent Plan meets the criteria 34 85 26 62 60 73 -.---~___ Plan partially meets the criteria 5 13 12 29 17 ~__- 21 Element not Identified in plan 1 3 4 10 5 6 Total 40 42 82------^ Table V.2: Extent to Which Plans Projected Reasonably Foreseeable Development Scenarios ELM Forest Service Total plans Extent element addressed Number Percent Number Percent Number Percent Plan meets the criteria 13 33 8 19 21 26 -___ Plan partially meets the criteria 16 40 29 69 45-____ 55 Element not identified in plan 11 28 5 12 16 20 Total 40 42 82 Table V.3: Extent to Which Plans Addressed Indirect Impacts BLM Forest Service Total plans Extent element addressed Number Percent Number Percent Number Percent Plan meets the criteria 25 63 24 57 49 60 Plan partially meets the criteria 9 23 11 26 20 24 Element not Identified in plan 6 15 7 17 13 16 Total 40 42 82 Table V.4: Extent to Which Plans Cited Cumulative Impacts BLM Forest Service Total plans Extent element addressed Number Percent Number Percent Number Percent Plans meet the crIteriaa 7 18 4 10 11 13 Element not identified in plan 33 83 38 90 71 87 Total 40 42 82 - aPlans that meet the cnteria for projecting reasonably foreseeable development scenanos and cite “cumulative impacts” Page 55 GAO/RCED-91571 Oil and Gas Decisions Appendix V Extent to Which BLM and Forest Service Land Use Plans Met the Criteria by Element Table V.5: Extent to Which Plans Addressed Lease Stimulations -tiLM Forest Service Total plans Extent element addressed Number Percent Number Percent Number Percent Plan meets the criteria 23 58 12 29 35 43 Plan partially meets the criteria 16 40 28 67 44 54 Element not identified in plan 1 3 2 5 3 4 Total 40 42 82 Page 66 GAO/lUXDsO-71011 and Gas Decisions Appendix VI I&M and Forest ServiceLand Use Plans and Areatide Environmental Assessmentsfor Four ResourceAreas and Four ForestsVisited Table Vl.1: Extent to Which Areawide Environmental Assessments And/Or Lease Oil/gas Development Impacts Applicable Land Use Plans Do Not Meet Location stips. potential scenario Indirect Cumulative ___- the Criteria for Each of the Five Elements BLM resource area Caliente, California N N White River, Colorado P Farmington, New Mexico P Platte River, Wyoming National forest Los Padres, California P P N San Juan, Colorado P P N Carson, New Mexico P P P N N Medicine Bow, Wvomina P P N Legend: P = partial N = not ldentlfled Page 57 GAO/RCEINO-71Oil and Gas Decisions Appendix VII BLM and Forest ServiceResourceAreas and ForestsThat May Need Additional Oil and Gas Information as Identified by GAO And/Or the Agencies Table VII.1: ELM Resource Areas With Actions Completed, Underway, or State Resource area Type of action Complete in FY: Proposed California Caliente New plan 1992 Clear Lakea New plan 1994 Folsoma New plan 1992 Hollister Amendment 1991 lndio New plan 1992 Reddinga New plan 1992 Colorado Glenwood Sprinasb Amendment 1991 Kremmlinob Amendment 1991 Little Snakeb Amendment 1991 Northeastb Amendment 1991 Royal Gorge New plan 1993 San Juanb Amendment 1991 White River New plan 1992 Montana Big Dryc Amendment 1991 BillingsC Amendment 1991 Dillona New plan 1993 Judithd New plan 1993 Phillipsd New plan 1993 Valleyd New plan 1993 Powder Rivef Amendment 1991 South DakotaC Amendment 1991 Nevada Caliente” New plan 1996 Eqan Amendment 1991 Elko Amendment 1992 Lahontana,e Amendment 1992 Shoshone-Eureka Amendment 1994 SchelP New plan 1994 Tonopah New plan 1992 Wellsa Amendment 1994 New Mexico Farmington’ Amendment 1991 Rio Puercoa.’ Amendment 1991 Roswell New plan 1993 Tao@’ Amendment 1991 Carlsbad Amendment 1993 Oregon BordeP 9 Amendment 1991 Tillamooka New plan 1993 Wenatcheeg Amendment 1991 Utah Bear River Amendment 1990 Book Cliffsh Amendment 1994 Diamond Mountain New plan 1992 (contrnued) Page 58 GAO/RCED9O-71Oil and Gas Decisions Appendix M BLM and Forest Service ResourceAreas and Forests That May NeedAdditional oil and GM Information as Identified by GAO And/ Or the Agencies State Resource area Type of action Complete in FY: Dixiea New elan 1990 Escalantea New plan 1994 Price Rivera New plan 1995 Wyoming Buffalo New plan 1994 Codvh New elan Completed Grass Creek New plan 1993 Great Divide New plan Completed Green River New plan 1991 Newcastle New elan 1992 Note: ELM also identified the states of Kansas, Oklahoma, and Texas as needing new plans to address oil and gas issues tn the plans. Thuslist rdentifres only resource areas. %onsrdered lower priority by BLM. bThese five plans are being amended In a srngle statewide plan amendment. CThese four plans are being amended in a srngie districtwide amendment dAll part of the same land use plan. eNot identified as a hrgh potential oil and gas area by GAO ‘Albuquerque districtwide amendment covers these three resource areas s0ne land use plan covers both these areas. that plan will be amended. hPlans were reviewed by GAO and met our criteria for all 5 elements Table Vll.2: Additional Resource Areas Identified by GAO Where More Oil and State Resource area Gas Information May Be Needed Montana Dickinson District (North Dakota) Garnet Headwaters Utah Grand San Juan San Rafael Wvomina Kemmerer Lander Platte River Washakie Page 69 GAO/RCEIML71 Oil and GasDecisions 1661 iv3ei-ww Z661 ww!j 266 1 a!va ,uolsnoH LueS sexal eUlO=J!l OO!XEIwMaN ,,peuaiacl 166 1 wauw E66 c fmsno Z66C peaqJaheag eueiuoyy 1661 .Ja!SOOH eue!pul 066 1 auheM 0lU-l PaWwoo ,UOJnH ue6!43!w 1661 ,aauMegS s!ou!III P661 eaaq6Jel 2661 o w.ues 1661 dww3 wwi 1661 Jan!ki ai!4M 1661 ww 266 1 eapuw w 0661 ,~,iawi ues 066 1 .ay!d Z661 ,aJ6gedwomn 1661 ,uosiuung 266 1 ,esam pueJg 166 1 3t1ahas00b 2661 ,OqedeJy opeJolo3 1661 q ,sJaA!ki X!S 1661 q ehu!~l-eww Z661 a F3OPOW 166 1 q d4www 166 1 SaJped so1 eluJojye3 066 1 etic(3eng sesueyJy :Aj &SeJOb l6UO!$8N was pe6OdOJd u! weldwo3 JO ‘r(6MJepun ‘pevqdwo3 SUO!pv lJ&!M 6)WJO j W!tUeS )66JOj :E’III\ elq6l
Federal Land Management: Better Oil and Gas Information Needed to Support Land Use Decisions
Published by the Government Accountability Office on 1990-06-27.
Below is a raw (and likely hideous) rendition of the original report. (PDF)