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[GAO-02-64R ] U.S. Fish and Wildlife Service: Information on Oil and Gas Activities in the National Wildlife Refuge System

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U.S. Fish and Wildlife Service: Information on Oil and Gas
Activities in the National Wildlife Refuge System (31-OCT-01,
GAO-02-64R).

This report provides information on oil and gas activities in the
National Wildlife Refuge System. Specifically,it focuses on (1)
how many units produced or had oil or gas activities on their
lands in 2000, (2) why these activities took place in these
units, (3) in how many of these units the federal government
owned the oil and gas mineral rights, (4) resources available to
these units to manage oil and gas activities, and (5) the effects
of the National Wildlife Refuge System Administration Act of 1966
on leases for oil and gas activities.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-02-64R
ACCNO: A02361
TITLE: U.S. Fish and Wildlife Service: Information on Oil and
Gas Activities in the National Wildlife Refuge System
DATE: 10/31/2001
SUBJECT: Conservation
Crude oil
Environmental policies
Land management
Natural gas
Natural resources
Bitter Lake National Wildlife Refuge
(NM)

Bowdoin Wetland Management Refuge (MT)
Delta National Wildlife Refuge (MS)
Hewitt Lake National Wildlife Refuge
(MT)

J. Clark Salyer National Wildlife Refuge
(ND)

Medicine Lake National Wildlife Refuge
(MT)

National Wildlife Refuge System
Salt Plains National Wildlife Refuge
(OK)

Upper Souris National Wildlife Refuge
(ND)

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GAO-02-64R

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity United States General
Accounting Office

Washington, DC 20548

October 31, 2001 The Honorable Edward J. Markey House of Representatives

Subject: U. S. Fish and Wildlife Service: Information on Oil and Gas
Activities in the National Wildlife Refuge System

Dear Mr. Markey: This letter responds to your request for specific
information on activities related to oil and gas development and production
that occurs in the U. S. Fish and Wildlife Service?s National Wildlife
Refuge System. The first national wildlife refuge was created in 1903 when
President Theodore Roosevelt set aside a tiny island off the east coast of
Florida for the protection of pelicans and other species of birds. Since
then, the National Wildlife Refuge System has grown to encompass more than
93 million acres of land and more than 560 national wildlife refuges and
wetland management districts. At least one of these units can be found in
every state and U. S. territory. 1 You asked that we provide answers to
seven specific questions. Those questions and our answers follow.

1. How many units of the National Wildlife Refuge System had oil or gas
activities on their lands in calendar year 2000?

Seventy- seven of the 567 units-- about 14 percent-- of the National
Wildlife Refuge System had oil or gas activities on their land in calendar
year 2000. These units are located in 22 states and distributed through all
seven regions of the Fish and Wildlife Service. The states of Louisiana,
with 19 units, and Texas, with 11 units, had the most units with oil or gas
activity.

We used the Fish and Wildlife Service?s criteria for determining whether a
unit of the National Wildlife Refuge System had oil or gas activity in
calendar year 2000.

1 For the purposes of this letter, the National Wildlife Refuge System
consists of 567 units including 530 refuges and 37 wetland management
districts that contain waterfowl production areas. Units of the National
Wildlife Refuge System, as defined in 50 CFR 25.12, include wildlife
refuges, wildlife ranges, wildlife management areas, and waterfowl
production areas. Wetland Management Districts are a management entity
created to administer the waterfowl production areas. We did not consider
any of the 50 coordination areas that are in the refuge system in our study
because state fish and wildlife agencies generally manage these areas.

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 2 Specifically, a unit was
considered to have oil or gas activity if one or more of the

following occurred or existed on its land:

Surface geological studies--- such studies examine the distribution and
position of surface rocks to help determine the characteristics of an area
and the likelihood of its having oil or gas resources. This type of activity
is usually performed with very little surface disturbance.

Geophysical surveys--- such surveys gather subsurface geological information
on such things as differences in the densities of various types of rock and
the location of subsurface rock structures. Geophysical surveys include
seismic surveys, which provide the most reliable information on an area?s
likelihood of having oil or gas reserves. Seismic surveys gather subsurface
geological information through the generation and receipt of impulses from
artificially generated shock waves. According to the Fish and Wildlife
Service, the vehicular traffic associated with seismic surveys is
potentially the most environmentally damaging aspect of seismic activities.

Exploration or development wells

Producing wells

Production facilities

Natural gas or oil pipeline Enclosure I contains a complete list of the 77
units by Fish and Wildlife Service region and state as well as the type of
oil or gas activity that occurred in the unit in calendar year 2000.

2. Under what circumstances did oil or gas activities occur in these units
of the National Wildlife Refuge System?

Oil and gas activities were allowed to take place in these 77 units of the
National Wildlife Refuge System for a variety of reasons. In the majority of
the units-- 41 out of 77-- oil or gas activity occurred where private
entities, states, or native corporations, rather than the federal
government, own the mineral rights. Owners of these mineral rights have the
right to develop, produce, and transport the oil and gas resources located
within a refuge. However, the Department of the Interior?s regulations
require mineral owners to the greatest extent practicable to conduct these
activities in a way that prevents damage, erosion, pollution, or
contamination to the lands, waters, facilities, and vegetation of the
refuge.

In 27 units, a pipeline constituted the only oil or gas activity within a
refuge, and these pipelines either were present before the Fish and Wildlife
Service acquired the land or were constructed under a right- of- way permit
issued by the Fish and Wildlife Service after the land was acquired.

In eight units the federal government owned the mineral rights and leased
the refuge land for oil and gas development. Details on how these oil or gas
activities were initiated are provided in our response to question 5.

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 3 Finally, in one
additional refuge, a surface geological study was conducted during the

year 2000 under a Fish and Wildlife Service special use permit. Special use
permits can authorize commercial activities on national wildlife refuges
when the federal government owns the mineral rights. The specific refuge on
which the activity takes place issues these permits.

3. In how many units of the National Wildlife Refuge System was oil or gas
produced in calendar year 2000?

Oil or gas was produced in 45 of the 567 units-- about 8 percent-- of the
National Wildlife Refuge System in calendar year 2000. These 45 units are
located in 15 states, with 19 units (about 42 percent) in Texas and
Louisiana. The number of producing wells in these 45 units ranges from 1 in
the Canaan Valley National Wildlife Refuge in West Virginia to over 300 in
the Upper Ouachita National Wildlife Refuge in Louisiana. Oil and gas
production in some of these units, such as Louisiana?s Black Bayou Lake
National Wildlife Refuge and D?Arbonne National Wildlife Refuge, began as
early as the 1920s. Enclosure II lists the 45 units that had a producing
well in calendar year 2000.

4. In how many units with oil or gas production in calendar year 2000 did
the federal government own the oil and gas mineral rights?

We identified eight units (seven national wildlife refuges and one wetland
management district) with oil or gas production in calendar year 2000 in
which the federal government owned the oil and gas mineral rights (see table
1).

Table 1: National Wildlife Refuge System Units With Oil or Gas Production in
Calendar Year 2000 in Which the Federal Government Owned the Oil and Gas
Mineral Rights

Unit State

Bitter Lake National Wildlife Refuge New Mexico Bowdoin Wetland Management
District Montana Delta National Wildlife Refuge Louisiana Hewitt Lake
National Wildlife Refuge Montana J. Clark Salyer National Wildlife Refuge
North Dakota Medicine Lake National Wildlife Refuge Montana Salt Plains
National Wildlife Refuge Oklahoma Upper Souris National Wildlife Refuge
North Dakota

Source: GAO analysis of Fish and Wildlife Service data.

5. Under what circumstances were oil or gas production activities allowed to
take place in units of the National Wildlife Refuge System in which the
federal government owns the oil and gas mineral rights?

In two of the eight units, oil or gas was already being produced on the land
when the Fish and Wildlife Service acquired it for inclusion in the National
Wildlife Refuge System. In four units, the federal government leased the
refuge land for oil and gas development to protect its interest in oil or
gas resources that were being drained from refuge land by wells of another
owner operating on adjacent land. In one of the

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 4 two remaining units, the
executive order establishing the refuge in 1938 opened its

land to oil and gas leasing because it was located on a known producing gas
field and, at the time, oil and gas development on refuge land was not
prohibited by Interior?s regulations. In the other refuge, leasing was
allowed under an exception to Interior?s 1947 regulations that prohibited
oil and gas leasing on refuge land. This exception, which no longer exists,
allowed leasing if the lessees had an approved unit agreement plan that
stipulated how the oil and gas field would be developed and operated.

The Secretary of the Interior, through the Bureau of Land Management, issues
oil and gas leases on federal lands under various authorities. As originally
enacted, the Mineral Leasing Act of 1920 authorized the Secretary of the
Interior to issue leases for oil and gas development on public domain lands
including lands reserved for wildlife refuges. 2 The only exceptions were
cases in which the executive order establishing the refuge restricted or
prohibited such activity. In 1947, the Mineral Leasing Act for Acquired
Lands authorized the Secretary of the Interior to lease for oil and gas
development on Fish and Wildlife Service lands that the federal government
had acquired. 3

In addition to these legislative authorities, the Secretary of the Interior
has the right to lease lands where drainage is occurring. 4 Drainage is the
depletion of publicly owned minerals without compensation through an
extraction operation on adjacent land of another owner. Once the Bureau of
Land Management determines that drainage is occurring on refuge land, it
requests the Fish and Wildlife Service?s consent to lease the land. Leasing
allows the federal government to collect a compensatory royalty for the oil
and gas loss from drainage. Before agreeing to lease the land, the Fish and
Wildlife Service must determine that the proposed activity is compatible
with the purpose for which the refuge was established and provide the Bureau
with recommendations for lease stipulations. The Bureau of Land Management
is then responsible for competitively leasing the land and issuing and
managing the lease.

Since at least 1947, however, Department of the Interior regulations have
prohibited oil and gas leasing of refuge lands outside of Alaska with a few
exceptions, such as drainage. Leasing of refuge lands can be done only with
the consent of the Fish and Wildlife Service under stipulations that specify
the time, place, and nature of the operations that may occur. When a
drainage lease is issued, it generally contains a

?no surface occupancy? stipulation, that prohibits the occupancy and use of
refuge land for the extraction of resources. As a result, operators who
obtain such a lease

2 The public domain refers to lands or interests in lands that have never
left the ownership of the United States, that were obtained by the United
States in exchange for public lands or for timber on such lands, and lands
that have reverted to the ownership of the United States through operation
of the public land laws. 3 Acquired lands are lands that the United States
obtained by deed through purchase, gift, or

condemnation proceedings, including lands previously disposed of under the
public land or mining laws. 4 This general authority was defined by an
Attorney General?s Opinion of Apr. 2, 1941 (Vol. 40 Op. Atty.

Gen. 41).

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 5 must extract the oil and
gas from land located outside the boundaries of the refuge.

This can be accomplished through the use of directional drilling. However,
the Fish and Wildlife Service?s consent would be required before the Bureau
of Land Management could approve any well that drilled under refuge lands.

Table 2 summarizes the reasons why oil or gas production was allowed in
eight units of the National Wildlife Refuge System in which the federal
government owned the oil and gas mineral rights.

Table 2: Reasons for Allowing Oil or Gas Production in Units of the National
Wildlife Refuge System in Which the Federal Government Owned the Oil and Gas
Mineral Rights

Reasons for allowing oil or gas production Unit

Pre- existing production Drainage

occurring Regulations did

not prohibit activity a

Exception to regulations prohibiting activity b 1. Bitter Lake National
Wildlife Refuge

X X 2. Bowdoin Wetland Management District X 3. Delta National Wildlife
Refuge

X 4. Hewitt Lake National Wildlife Refuge X 5. J. Clark Salyer National
Wildlife Refuge

X 6. Medicine Lake National Wildlife Refuge

X 7. Salt Plains National Wildlife Refuge

X 8. Upper Souris National Wildlife Refuge

X a Before 1947, Department of the Interior regulations did not prohibit oil
and gas leasing on refuge lands. b In 1947, the Department of the Interior
issued regulations prohibiting oil and gas leasing on refuge lands with a

few exceptions. As discussed below, the Delta refuge allowed oil and gas
development under one of these exceptions.

Source: GAO analysis of data from the Fish and Wildlife Service and Bureau
of Land Management.

The following discussion presents detailed information on the circumstances
under which oil or gas production occurred in each of the eight units of the
National Wildlife Refuge System in which the federal government owned the
oil and gas mineral rights.

Bitter Lake National Wildlife Refuge The Bitter Lake National Wildlife
Refuge was established in 1937 and is located in New Mexico. According to
officials at the Bureau of Land Management, the refuge boundary was expanded
in 1968 under a public land order. The federal government already owned the
mineral rights on the land acquired in the expansion, and in the

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 6 1950s, the Bureau of
Land Management had issued two leases for oil and gas

development on it under the Mineral Leasing Act of 1920. Subsequently,
producing oil wells were developed on the land under these leases. As a
result, when the Bitter Lake refuge acquired this land, the refuge became a
unit that has producing oil wells whose mineral rights are owned by the
federal government. In April 1994, the Bureau of Land Management issued
another oil and gas lease on the refuge. This lease was issued to protect
the government?s interest in gas resources being drained from the Bitter
Lake refuge. The lease contained a ?no surface occupancy? stipulation that
prohibits the occupancy or use of the refuge land to extract the resource.

Bowdoin Wetland Management District The Bowdoin Wetland Management District
was created in 1958 to administer the waterfowl production areas in northern
Montana. According to officials at the Bureau of Land Management, portions
of the Bowdoin Wetland Management District sit atop a very large gas field
that has been producing since the 1940s. In 1991, the Fish and Wildlife
Service acquired over 2,000 acres of land from Aetna Insurance Company to be
managed as part of the Bowdoin Wetland Management District. Some of this
acquired land had producing gas wells. Although private entities owned the
mineral rights for most of these wells, the federal government owned the
rights for two of them. As a result, when the service acquired this land,
the Bowdoin Wetland Management District became an area that had gas
production on refuge system land for which the federal government owned the
mineral rights.

Delta National Wildlife Refuge The Delta National Wildlife Refuge,
established in 1935, is located at the mouth of the Mississippi River in
Louisiana. Over 50 percent of the refuge?s land has some sort of oil or gas
activity. This activity was initiated in 1949 when the Department of the
Interior issued a total of six oil and gas leases on the land of the refuge.
The federal government owned the mineral rights for these leased lands. At
that time, although Interior?s regulations generally prohibited oil and gas
leases on refuge land, there were exceptions. One of these exceptions was in
cases where a group of lessees would develop a unit agreement plan that
would stipulate how they planned to develop and operate an oil or gas field
in a refuge. If the Secretary of the Interior, with the consent of the Fish
and Wildlife Service, approved the plan, oil and gas leases could be
permitted on a refuge. This exception was used to initiate oil and gas
leasing in the Delta refuge.

Hewitt Lake National Wildlife Refuge The Hewitt Lake National Wildlife
Refuge, located in northeastern Montana, was established in 1938. The refuge
contains a large gas field in which the federal government owns much of the
mineral rights. The executive order establishing the refuge permitted oil
and gas leasing. Specifically, the order noted that the refuge land was
within the known geologic structure of a producing gas field and stated that
nothing should affect the disposition of its oil and gas deposits under the
Mineral

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 7 Leasing Act of 1920. In
addition, at that time, Interior?s regulations did not prohibit

oil and gas leasing on refuge land. Accordingly, in the early 1940s, the
Department of the Interior issued seven leases for gas exploration and
development within the refuge under the Mineral Leasing Act of 1920.
Currently, the refuge has a total of eight producing gas wells.

J. Clark Salyer National Wildlife Refuge The J. Clark Salyer National
Wildlife Refuge is located in North Dakota and was established in 1935.
Currently, the refuge has seven producing oil wells. These wells were
drilled as part of four leases issued in the 1960s by the Secretary of the
Interior under the Mineral Leasing Act for Acquired Lands of 1947 when it
was determined that drainage was occurring on refuge land. The Fish and
Wildlife Service has also issued subsequent leases for oil and gas
development within the J. Clark Salyer refuge. Specifically, in the early
1990s, the Bureau of Land Management determined that oil wells operating
outside the boundaries of the refuge were draining oil resources from refuge
land to which the federal government owned the mineral rights. In order to
protect the federal government?s interest in these resources, the Bureau
recommended that the Fish and Wildlife Service allow oil and gas leasing on
two tracts of refuge land. The Fish and Wildlife Service agreed to allow a
lease for the tracts if it contained a ?no surface occupancy? stipulation.
In May 1992, the Bureau issued such a lease for the land.

Medicine Lake National Wildlife Refuge The Medicine Lake National Wildlife
Refuge, located in northeastern Montana, was established in 1935. Oil
development on the refuge was initiated in the mid- 1980s, when the Bureau
of Land Management determined that a well located on land adjacent to the
refuge was draining the oil owned by the federal government. To protect the
government?s interest in this resource, the Fish and Wildlife Service
allowed the Bureau of Land Management to issue an oil and gas lease. The
lease resulted in two wells being drilled on refuge land. In January 1999,
the Fish and Wildlife Service again allowed leasing on refuge land to
protect the government?s resources against drainage. The lease, however,
contains a ? no surface occupancy? stipulation.

Salt Plains National Wildlife Refuge The Salt Plains National Wildlife
Refuge, established in 1930 and located in Oklahoma, currently has a total
of nine oil and gas leases. Oil and gas development was initiated in this
refuge in 1965, when the Bureau of Land Management issued six leases because
of drainage. These leases were issued under the Mineral Leasing Act of 1920
for refuge land that was in the public domain and under the Mineral Leasing
Act for Acquired Lands of 1947 for refuge land that was acquired. The Bureau
issued two additional leases in 1981 and 1982, when the federal government
determined that oil and gas resources that it owned were again being drained
from the refuge. In

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 8 2000, the Bureau issued
the ninth oil and gas lease when another determination of

drainage was made on refuge land. Upper Souris National Wildlife Refuge The
Upper Souris National Wildlife Refuge was established in North Dakota in
1935. The refuge currently has oil production activities on its land as a
result of six oil and gas leases. Five of the six leases were issued in the
mid- 1970s, after the Bureau of Land Management determined that oil
resources owned by the federal government were being drained from the refuge
by oil wells located on private land outside the refuge boundary. The Bureau
issued an additional lease in 1990 when it determined that further drainage
was occurring from refuge land. The 1990 lease, however, contains a ?no
surface occupancy? stipulation.

6. Since the passage of the National Wildlife Refuge System Administration
Act of 1966, have leases for oil or gas activities on refuges been issued
for reasons other than drainage?

No leases have been issued for reasons other than drainage since the
Congress enacted the National Wildlife Refuge System Administration Act of
1966. The act defines the refuge system as it is known today. Specifically,
the act consolidated the various categories of lands administered by the
Secretary of the Interior and other agencies for the conservation of fish
and wildlife into a single National Wildlife Refuge System managed by the
Fish and Wildlife Service. The act also established wildlife conservation as
a unifying mission for the refuge system and set up a process for
determining compatible uses of refuge lands.

Since passage of this legislation, the Fish and Wildlife Service has
approved the issuance of 13 leases on five of the eight refuges that had oil
or gas production in 2000 and for which the federal government owned the
mineral rights. In each case, the leases were issued because operators on
land adjacent to the refuge boundaries were draining oil or gas resources
owned by the federal government from refuge land without compensation. Table
3 identifies the five refuges and the number and year in which the leases
were issued.

Table 3: Units of the National Wildlife Refuge System With Leases Issued
after 1966 Because of Drainage

Unit Year lease issued (number of leases) Bitter Lake National Wildlife
Refuge 1994 (1) J. Clark Salyer National Wildlife Refuge 1992 (1) Medicine
Lake National Wildlife Refuge 1985 (1); 1999 (1) Salt Plains National
Wildlife Refuge 1981 (1); 1982 (1); 2000 (1) Upper Souris National Wildlife
Refuge 1974 (2); 1975 (1); 1976 (2); 1990 (1)

Source: GAO analysis of data from the Fish and Wildlife Service and Bureau
of Land Management.

In July 1993, the Fish and Wildlife Service formally issued guidance to
further protect fish and wildlife habitat in cases of oil and gas leasing
due to drainage. Specifically,

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 9 the new guidance stated
that any oil or gas lease issued because of drainage should

stipulate a ?no surface occupancy? requirement where possible. Since the
issuance of this requirement, three new oil and gas leases have been
approved by the Fish and Wildlife Service in the five refuges, each with the
?no surface occupancy? stipulation.

7. What funding and staff resources does the Fish and Wildlife Service
provide its refuge units to manage oil and gas activities?

The Fish and Wildlife Service does not have a line item in its budget to
fund the management of oil and gas activities that occur in the National
Wildlife Refuge System. As a result, units that have individuals assigned to
the management of oil and gas activities usually use funds from their unit
budget or find alternative sources of funds for this function. According to
the Fish and Wildlife Service, the only person assigned at headquarters to
monitor all oil and gas activities in the National Wildlife Refuge System
performs this task as a collateral duty. Further, only one unit of refuge
system-- the Sabine National Wildlife Refuge in Louisiana-- has a full- time
person assigned to these duties.

The Sabine National Wildlife Refuge established an oil and gas specialist
position in September 2000. Prior to this, the refuge did not have a
dedicated person to manage oil and gas activities. The position is funded
from a damage fund account, which contains monies collected from oil and gas
operators for site- specific damage to refuge land. The person assigned to
this position is responsible for managing all aspects of oil and gas
activities in the Southwest Louisiana Refuge Complex, which includes the
Sabine and Cameron Prairie National Wildlife Refuges.

According to the Service, other units of the refuge system use individuals
who were hired and trained to perform other functions to help manage oil and
gas activities. For example, for the past 4 years, at the Arctic National
Wildlife Refuge a refuge operation specialist who is responsible for aquatic
and coastal resource issues has also managed oil and gas activities. For the
last 2 years, however, managing oil and gas activities has taken most of
his/ her time. The position is funded from the unit?s base fund that pays
for all permanent full- time staff.

The Kenai National Wildlife Refuge in Alaska also has had a person
designated to spend half his/ her time on managing oil and gas activities in
the refuge for the past 6 years. Currently, the person responsible for
managing oil and gas activities is also in charge of maintenance on this 2
million- acre refuge. These duties include maintaining the facilities,
recreation sites, and vehicles, as well as other duties. The oil and gas
portion of this person?s duties are currently funded from a revenuesharing
account that collects a portion of concession fees as well as monies derived
from timber cutting, fur trapping, and oil and gas activities.

Scope and Methodology

To determine the number of units within the National Wildlife Refuge System
that had oil and gas activity on their lands in calendar year 2000, we used
the Fish and

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 10 Wildlife Service?s
Refuge Management Information System database as of July 2001.

To ensure that the database information was accurate and complete, we
contacted the Fish and Wildlife Service regional offices and had them verify
our list. We then contacted each of the identified refuges and wetland
management districts to determine under what circumstances oil and gas
activities were allowed to begin and whether the unit had oil or gas
production in calendar year 2000.

For each refuge or wetland management district that had oil or gas
production in calendar year 2000, we contacted the unit to determine whether
the federal government owned the mineral rights to the land where production
was occurring. If the government owned the mineral rights, we then
determined under what conditions the unit allowed oil and gas production. We
also contacted officials of the Bureau of Land Management who are
responsible for issuing oil and gas leases on refuge land to obtain copies
of the leases and determine the circumstances under which leasing occurred.

To determine whether any oil and gas leases had been issued for reasons
other than drainage since the passage of the National Refuge System
Administration Act of 1966, we first determined whether any oil or gas
leases had been issued since 1966 by any of the eight refuges that had oil
or gas production in 2000 and in which the federal government owned the
mineral rights. We identified five refuges that met those criteria. From
each of those five refuges, we then obtained copies of all oil and gas
leases issued after 1966 and determined the reasons for the issuance of each
lease.

To determine the type and amount of resources the Fish and Wildlife Service
provides its refuge units to manage oil and gas activities, we discussed
this issue with key headquarters officials and selected individual refuge
managers.

We conducted our work from August through October 2001 in accordance with
generally accepted government auditing standards.

Agency Comments

We provided copies of a draft of this letter to the Department of the
Interior for review and comment. The Department of the Interior generally
agreed with the findings in the letter. The Department also attached
comments from its Fish and Wildlife Service and the Bureau of Land
Management. The Fish and Wildlife Service commented that the Refuge
Management Information System database, which it provided to us to identify
refuges with oil and gas activity, does not include a comprehensive listing
of refuges with pipelines. The Service commented that it lacks a full
accounting of all refuges that have pipelines or are vulnerable to spills
from pipelines but it knows the data it provided to us is not inclusive. For
example, the Service stated that in February 2000, about 180,000 gallons of
crude oil leaked from a pipeline that crosses the John Heinz National
Wildlife Refuge at Tinicum in Pennsylvania. However, this refuge is not in
the Service?s database. We added the John Heinz refuge to our listing of
refuges with oil or gas activities. The Fish and

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 11 Wildlife Service and
the Bureau of Land Management also provided several technical

clarifications, which we incorporated into the letter as appropriate. - - -
- As

agreed with your office, unless you publicly announce its contents earlier,
we plan no further distribution of this letter until 30 days after the date
of this letter. At that time, we will send copies to the Secretary of the
Interior, the Director of the U. S. Fish and Wildlife Service, the Director
of the Bureau of Land Management, and other interested parties. This letter
will also be available on GAO?s home page at http:// www. gao. gov.

If you or your staff have any questions about this letter, please call me at
(202) 512- 3841. Key contributors to this letter were Jos Alfredo Gmez,
Ben Mills, Cheryl Pilatzke, and Jim Yeager.

Sincerely yours, Barry T. Hill Director, Natural Resources

and Environment

Enclosure I

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 12

National Wildlife Refuge System Units With Oil or Gas Activities in Calendar
Year 2000

Fish and Wildlife Service region Unit State

Surface geological study

Geophysical survey (e. g., seismic)

Exploration or development well

Producing well

Production facility Pipeline

1 Hopper Mountain NWR CA

1 Sacramento River NWR

CA

1 Seal Beach NWR CA

1 Sutter NWR CA

2 Bitter Lake NWR NM

2 Deep Fork NWR OK

2 Optima NWR OK

2 Salt Plains NWR OK

2 Washita NWR OK

2 Anahuac NWR TX

2 Aransas NWR TX

2 Big Boggy NWRTX

2 Brazoria NWR TX

2 Hagerman NWR TX

2 Lower Rio Grande Valley NWR

TX

2 Matagorda Island NWR

TX

2 McFaddin NWR TX

2 San Bernard NWR

TX

2 Texas Point NWR

TX

2 Trinity River NWR

TX

3 Mark Twain NWR

IL

3 Patoka River NWR& MA

IN

3 Kirtlands Warbler WMA a MI

3 Detroit Lakes WMD

MN

3 Litchfield WMDMN

3 Minnesota Valley NWR MN

3 Sherburne NWR MN

3 Leopold WMD WI

3 Upper Mississippi River NW and Fish Refuge- Complex

WI, MN IL, IA

4 Choctaw NWR AL

4 Wheeler NWR AL

4 Bald Knob NWR AR

4 Cache River NWR

AR

Enclosure I

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 13

Fish and Wildlife Service region Unit State

Surface geological study

Geophysical survey (e. g., seismic)

Exploration or development well Producing

well Production facility Pipeline

4 Felsenthal NWR AR

4 Overflow NWR AR

4 Pond Creek NWR

AR

4 White River NWR

AR

4 Atchafalaya NWR

LA

4 Bayou Cocodrie NWR LA

4 Bayou Sauvage NWR

LA

4 Big Branch Marsh NWR LA

4 Black Bayou Lake NWR

LA

4 Breton NWR LA

4 Cameron Prairie NWR LA

4 Catahoula NWR LA

4 D?Arbonne NWR LA

4 Delta NWR LA

4 Grand Cote NWR

LA

4 Handy Brake NWR

LA

4 Lacassine NWR LA

4 Lake Ophelia NWR LA

4 Louisiana WMD LA

4 Mandalay NWR LA

4 Sabine NWR LA

4 Tensas River NWR

LA

4 Upper Ouachita NWR LA

4 Grand Bay NWR MS

4 Mississippi Sandhill Crane NWR

MS

4 St. Catherine Creek NWR

MS

4 Carolina Sandhills NWR SC

4 Hatchie NWRTN

5 John Heinz NWR at Tinicum

PA

5 Canaan Valley NWR WV

6 Quivira NWRKS

6 Benton Lake NWR

MT

6 Benton Lake WMD MT

6 Bowdoin WMD MT

Enclosure I

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 14

Fish and Wildlife Service region Unit State

Surface geological study

Geophysical survey (e. g., seismic)

Exploration or development well Producing

well Production facility Pipeline

6 Hewitt Lake NWR

MT

6 Lake Thibadeau NWR MT

6 Medicine Lake NWR

MT

6 Medicine Lake WMD MT

6 Crosby WMDND

6 J. Clark Salyer NWR

ND

6 J. Clark Salyer WMD

ND

6 Upper Souris NWR

ND

7 Arctic NWRAK

7 Kenai NWR AK

a A wildlife management area (WMA) is a unit in the refuge category of the
National Wildlife Refuge System. Note: National Wildlife Refuge (NWR).

Wetland Management District (WMD). Source: GAO analysis of U. S. Fish and
Wildlife Service data.

Enclosure II

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 15

National Wildlife Refuge System Units With Oil- or Gas- Producing Wells in
Calendar Year 2000

Fish and Wildlife Service region Unit State

1 Hopper Mountain National Wildlife Refuge CA 1 Sacramento River

National Wildlife Refuge CA 1 Seal Beach National Wildlife Refuge CA 1
Sutter National Wildlife Refuge CA 2 Bitter Lake National Wildlife Refuge NM
2 Optima National Wildlife Refuge OK 2 Salt Plains National Wildlife Refuge
OK 2 Washita National Wildlife Refuge OK 2 Anahuac National Wildlife Refuge
TX 2 Aransas National Wildlife Refuge TX 2 Brazoria National Wildlife Refuge
TX 2 Hagerman National Wildlife Refuge TX 2 Lower Rio Grande Valley National
Wildlife Refuge TX 2 Matagorda Island National Wildlife Refuge TX 2 McFaddin
National Wildlife Refuge TX 2 San Bernard National Wildlife Refuge TX 3
Patoka River National Wildlife Refuge & Management Area IN 3 Kirtlands
Warbler Wildlife Management Area a MI 4 Choctaw National Wildlife Refuge AL
4 Felsenthal National Wildlife Refuge AR 4 Atchafalaya National Wildlife
Refuge LA 4 Black Bayou Lake National Wildlife Refuge LA 4 Catahoula
National Wildlife Refuge LA 4 D'Arbonne National Wildlife Refuge LA 4 Delta
National Wildlife Refuge LA 4 Lacassine National Wildlife Refuge LA 4 Lake
Ophelia National Wildlife Refuge LA 4 Mandalay National Wildlife Refuge LA 4
Sabine National Wildlife Refuge LA 4 Tensas River National Wildlife Refuge
LA 4 Upper Ouachita National Wildlife Refuge LA 4 St. Catherine Creek
National Wildlife Refuge MS 5 Canaan Valley National Wildlife Refuge WV 6
Quivira National Wildlife Refuge KS 6 Benton Lake Wetland Management
District MT 6 Bowdoin Wetland Management District MT 6 Hewitt Lake National
Wildlife Refuge MT 6 Lake Thibadeau National Wildlife Refuge MT 6 Medicine
Lake National Wildlife Refuge MT 6 Medicine Lake Wetland Management District
MT 6 Crosby Wetland Management District ND 6 J. Clark Salyer National
Wildlife Refuge ND

Enclosure II

GAO- 02- 64R Wildlife Refuge Oil and Gas Activity 16

Fish and Wildlife Service region Unit State

6 J. Clark Salyer Wetland Management District ND 6 Upper Souris National
Wildlife Refuge ND 7 Kenai National Wildlife Refuge AK

a A wildlife management area is a unit in the refuge category of the
National Wildlife Refuge System. Source: GAO analysis of U. S. Fish and
Wildlife Service data.

(360136)
*** End of document. ***

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