ONRR Needs To Consistently Enforce Compliance and Timely Revenue Collection

We recommend that ONRR update its policies and procedures to establish conditions that warrant or require a referral to ONRR Enforcement, such as the maximum number of informal compliance attempts or maximum number of days since an effort to obtain compliance was initiated, to provide sufficient time to resolve the case before expiration of the statute of limitations.

We recommend that ONRR update policies and procedures with clear instructions on the steps necessary to ensure that companies have achieved full compliance, including searching for collateral violations and coordination with other ONRR divisions for verification that there are no other related violations prior to closing the case.

We recommend that ONRR update its policies and procedures to prioritize referring cases related to unpaid royalties to the Office of Enforcement based on defined conditions, to include dollar thresholds, material significance, or when companies are repeat offenders.

We recommend that ONRR establish procedures to identify unpaid royalties related to missing reporting cases and issue Immediate Liability Civil Penalties unless an exception is warranted and adequately documented.

We recommend that ONRR provide training on updated procedures to ensure all investigators consistently pursue issuing penalties when warranted or document any exceptions.

We recommend that ONRR update the Office of Enforcement's policies and procedures to ensure coordination with the surface management agency to verify well status or well shut-in requests prior to closure of unenforceable cases or archiving referrals.

We recommend that ONRR evaluate and report on the compliance of the responsible parties associated with the six closed reporting cases to ensure each company submitted all the required reports and payments or pursue appropriate enforcement actions.