The Bureau of Land Management’s Procedures for Addressing Forced-Pooling Requests and Mineral Trespass

During recent investigations into allegations of private companies (producers) accessing and producing unleased Federal minerals, we uncovered programmatic vulnerabilities that undermine the Bureau of Land Management’s (BLM’s) oversight of Federal mineral production and limit the U.S. Government’s ability to address mineral trespass violations.The BLM did not respond to producers’ proposed drilling plans and forced-pooling participation requests based on State forced-pooling statutes for proposed units containing unleased Federal minerals. Subsequently, the producers improperly proceeded with drilling operations and initiated production from the wells without first obtaining Federal leases, resulting in Federal mineral trespasses.Additionally, we learned that one BLM office waited years to refer mineral trespass matters to our office, and in a separate matter, U.S. Department of the Interior (DOI) personnel addressed trespass violations without a referral to our office.We make three recommendations to help the BLM avert future mineral trespass violations, improve compliance with the BLM’s mineral leasing process, and improve the Government’s ability to recover lost revenues that result from mineral trespass violations.