Considerations for the Recombination of BOEM & BSEE Overview On May 19, 2010, through Secretary’s Order 3299 (SO 3299), the Secretary of the Interior (Secretary) ordered the reorganization of the Minerals Management Service (MMS)1, an agency with approximately 1,800 employees and an operating budget of approximately $377 million, into three separate bureaus with distinct missions. The purpose of SO 3299 was to address “real and perceived conflicts between the resource management, safety and environmental oversight and enforcement, and revenue collection responsibilities,”2 and improprieties reported by the Office of the Inspector General (OIG). The restructuring was accomplished with the assistance of an independent consulting firm under contract for approximately $7.8 million. By October 2011, the Office of Natural Resources Revenue (ONRR), the Bureau of Ocean Energy Management (BOEM), and the Bureau of Safety and Environmental Enforcement (BSEE) were in existence. New ethics standards were established as a deterrent to conflicts of interest and behavioral improprieties.3 After careful review, it is apparent that the reorganization resulted in challenges that BOEM and BSEE continue to confront to this day. Recombining the two bureaus could increase efficiencies and reduce costs in managing the OCS program, but will also cause implementation challenges. This memorandum reviews the issues associated with both the past reorganization and the potential recombination of BOEM and BSEE. Background The Secretary is responsible for the administration of mineral exploration and development of the U.S. Outer Continental Shelf (OCS) in accordance with the OCS Lands Act of 1953. The Act empowers the Secretary to perform a number of duties to carry out the policy objectives, which include: • • 1 providing for “expeditious and orderly development, subject to environmental safeguards, in a manner which is consistent with the maintenance of competition and other national needs;” and ensuring that “operations in the [OCS are] conducted in a safe manner by well-trained personnel using technology, precautions, and techniques sufficient to prevent or minimize U.S. DOI, Secretary’s Order 3299, Establishment of the Bureau of Ocean Energy Management, the Bureau of Safety and Environmental Enforcement, and the Office of Natural Resources Revenue. May 19, 2010. 2 Implementation Plan in Response to the Outer Continental Shelf Safety Oversight Board’s September 1, 2010 Report to the Secretary of the Interior. September 4, 2010 (page 3). 3 Ethics Guide for DOI Employees, January 2009. the likelihood of blowouts, loss of well control, fires, spillage, physical obstruction to other users of the waters or subsoil and seabed, or other occurrences which may cause damage to the environment or to property, or endanger life or health.”4 Within DOI, the MMS was created by Secretary’s Order 3071 on January 19, 1982, with responsibility for managing the nation’s natural gas, oil and other mineral resources on the OCS and collecting revenue generated from mineral development5. From its inception through 2015, MMS and its successor agencies collected over $260 billion in revenues and distributed them to States, Tribes, counties, and the federal treasury. MMS activities were carried out from a headquarters office in Washington, DC, and regional offices in New Orleans, LA (Gulf of Mexico), Camarillo, CA (Pacific) and Anchorage, AK (Alaska). District offices in New Orleans, Houma, Lafayette and Lake Charles in Louisiana, and Lake Jackson, TX were and continue to be subunits of the Gulf of Mexico Region. Revenue and royalty collection and distribution were managed primarily from an office in Denver, CO, with audit offices at various locations. In 2006, the OIG initiated an inquiry into allegations of misconduct by personnel in the Denver office responsible for the Royalty in Kind (RIK) program. The inquiry led to three separate investigations into allegations against more than a dozen employees that concluded in September 2008. One individual pled guilty to a criminal charge and the cases for two individuals were referred to the Department of Justice, which declined to prosecute. The OIG summarized the situation as “a culture of ethical failure”.6 The OIG report contained four recommendations directed at the RIK program: (1) Take appropriate administrative and corrective action; (2) Develop an enhanced ethics program designed specifically for the RIK program; (3) Develop a clear, strict code of conduct for the RIK program; and (4) Consider changing the reporting structure of RIK. This was followed by a separate investigation in 2008 into allegations of MMS employees in the Lake Charles, LA, district office accepting gifts from oil and gas production company representatives. One individual was terminated following the investigation.7 On April 20, 2010, the worst oil spill in U.S. history occurred following the blowout of the Macondo well and the explosion and sinking of the Deepwater Horizon rig. In response to this event and the OIG reports identifying the ethical issues mentioned above, then-Secretary of the Interior Ken Salazar issued Secretary’s Order 3299 on May 19, 2010, which dissolved MMS and initiated the process for creating ONRR to manage royalty and revenue, BSEE to regulate offshore energy development, and BOEM to manage resource evaluation, planning and leasing.8 4 OCS Lands Act 43 U.S.C. 1332 U.S. DOI Secretary’s Order No. 3071, January 19, 1982. 6 Memo from DOI Inspector General to Secretary DOI, Subject: OIG Investigations of MMS Employees, September 10, 2008. 7 Memo from DOI Inspector General to Secretary DOI, Subject: Investigative Report -Island Operating Company, et. al. May 24, 2010. 8 Implementation Report: Reorganization of the Minerals Management Service. Department of the Interior. July 14, 2010. 5 2 The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) was named as an interim organization for the offshore bureaus after ONNR was created in October 2010. 9 SO 3299 directed the restructuring of MMS into three separate entities with independent missions: • Bureau of Ocean Energy Management: A new bureau under the supervision of the Assistant Secretary for Land and Minerals Management responsible for the sustainable development of OCS conventional and renewable energy resources, including resource evaluation, planning, and other activities related to leasing and resource management. • Bureau of Safety and Environmental Enforcement: A new bureau under the supervision of the Assistant Secretary for Land and Minerals Management responsible for ensuring comprehensive oversight, safety, and environmental protection in all offshore energy activities. • Office of Natural Resources Revenue: An office under the supervision of the Assistant Secretary for Policy, Management, and Budget responsible for the royalty and revenue management function, including the collection and distribution of revenue, auditing and compliance, and asset management. In the wake of the Deepwater Horizon tragedy, Secretary Salazar identified a need for creation of a separate and independent safety and environmental enforcement entity. DOI listed the following as the objectives of the restructuring10: • • • • • • Eliminate real and perceived conflicts within the existing organization by creating separate entities focused on each of the critical elements of MMS’s current mission, namely responsible resource development; safety and environmental protection and enforcement; and effective and appropriate revenue collection; Provide each organization with the structure and necessary resources to successfully achieve its individual mission and objectives; Establish necessary checks and balances in the relationship among the three new entities, so stakeholders can be assured that all mission elements are appropriately addressed; Maintain critical linkages among the three organizations to provide a predictably administered offshore energy and minerals development and regulatory program; Support enhanced offshore renewable energy production; and Provide effective and appropriate administrative support for each new entity without creating unnecessary redundancy. Certain reforms were emphasized as accompanying the reorganization: 9 U.S. DOI Secretary’s Order No. 3302, June 18, 2010. Implementation Report: Reorganization of the Minerals Management Service, July 14, 2010 10 3 • Separating resource management from safety oversight to allow permitting engineers and inspectors greater independence, more budgetary autonomy and clearer senior leadership focus. • Providing a structure that ensures that robust environmental analyses are conducted and that the potential environmental effects of proposed operations are given appropriate weight during decision-making related to resource management. • Strengthening the role of environmental review and analysis in both organizations. • Increasing the inspection and engineering workforce to allow for more thorough review of permits, and more analysis to ensure compliance with enhanced standards. The National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling made a similar recommendation. Specifically, it recommended creation of “an independent agency within the Department of the Interior with enforcement authority to oversee all aspects of offshore drilling safety (operational and occupational), as well as the structural and operational integrity of offshore energy production facilities….” The Commission’s report identified the Macondo well failure as turning “a harsh spotlight on [MMS’s] bureaucratic inadequacies and shortcomings,” which they listed as the lack of “a clearly articulated mission or adequate guidance for balancing its different missions, … inefficient management and a tendency to defer to industry,… an outdated organizational structure, a chronic shortage of resources, a lack of sufficient technological expertise, and the inherent difficulty of coordinating with all the other government agencies that had a statutory responsibility for some aspect of offshore oil and gas activities.”11 While the Commission recommended reorganization, none of the problems it identified required a reorganization to be addressed. Furthermore, none of the technical investigations of the cause of the Macondo failure identified the MMS organizational structure as contributing to the failure of the well. The creation of BOEM and BSEE as separate bureaus went beyond what was needed to correct existing ethics and behavioral problems or real and perceived conflicts of interest. By 2017, the combined number of people employed to carry out the mission of the former MMS had increased to 2,122 (a 20.5% increase when compared to MMS in 2010) and the combined budget for the three bureaus grew to over $500 million (a 32.7% increase over MMS) (Table 1, attached). The increase can be attributed to not only a need for more personnel to perform critical operations such as inspections (e.g., the increase in personnel in district offices is primarily a result of hiring more inspectors (Table 2, attached)) and an incentive pay program for mission critical occupations such as petroleum engineers and geoscientists, but also a redundancy of functions needed to manage headquarters and regional offices in separate bureaus. 11 Deep Water: The Gulf Oil Disaster and the Future of Offshore Drilling; Report to the President, National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, January 2011 4 During that same period, the number of personnel in all of DOI declined about 7% and the enacted budget for the department increased about 1.3% (Table 1). Almost six years after the establishment of BOEM and BSEE, there is now a track record on which to consider the effectiveness of the reorganization. The Government Accountability Office (GAO) has been critical of the reorganization of MMS. In February 2011, GAO placed DOI’s management of federal oil and gas resources on a “high risk list” for three reasons including a broad reorganization of offshore oil and gas management. GAO specifically mentioned inadequate plans to address human capital issues. 12 The reorganization was removed from the high risk list in 2013, but reinstated in 2017 because “Interior's restructuring of the [BSEE] has made limited progress addressing long-standing deficiencies in the bureau's investigative, environmental compliance, and enforcement capabilities,”13 one of the three critical functions of the new bureau. In March 2017, GAO reported that action was needed to address leadership commitment deficiencies in oil and gas oversight within BSEE.14 A Congressional Research Service (CRS) report in July 2012 was less critical of the reorganization.15 Another organization, the National Academy of Public Administration (NAPA), was hired by BSEE in 2016 at a cost of $500,000 to conduct a review and prepare a report in anticipation of adverse findings from an ongoing GAO review. NAPA assessed the Bureau’s organizational progress during its first five years of existence. The NAPA report was published in March 2017 to coincide with the release of GAO’s report and counter GAO’s findings.16 NAPA stated that the reorganization was justified in part by “troubling patterns where managers seemed to prioritize the dominant mission of meeting development targets at the expense of regulatory compliance functions” as reported by the OIG and others; however, the preparers provided no specific evidence to support this conclusion. NAPA found that over the course of five years, “BSEE has developed and strengthened programs and capacities to fulfill its mission.” NAPA recommended that “BSEE should remain a separate entity with high levels of coordination with BOEM and ONRR.” Benefits of Recombination 12 High-Risk Series. An Update. GAO 11-278 Report to Congressional Committees. February 2011 (page 37). High-Risk Series. Progress on Many High-Risk Areas, While Substantial Efforts Needed on Others. GAO 17-317 Report to Congress. February 2017 (page 136). 14 Oil and Gas Management: Stronger Leadership Commitment Needed at Interior to Improve Offshore Oversight and Internal Management. GAO 17-293 Report to Congressional Addressees. March 2017. 15 Congressional Research Service, Department of the Interior (DOI) Reorganization of Ocean Energy Programs. July 11, 2012. 16 A Report by a Study Team of the National Academy of Public Administration for the Bureau of Safety and Environmental Enforcement. Bureau of Safety and Environmental Enforcement: Strategic Organizational Assessment, March 2017. 13 5 • • • Combining BOEM and BSEE would restore full life-cycle resource management, oversight and stewardship into a single bureau with a common, coherent management philosophy. While the two bureaus make a considerable effort to coordinate on crosscutting issues, differing priorities and cultures make resolution of some issues challenging. For example, decisions on suspensions and unitization in one bureau can impact the leasing program in the other. Both would benefit from a common strategy for the long-term management of OCS resources and infrastructure. A combined bureau would provide a single focal point for stakeholder engagement across the entire OCS program. Stakeholders, both external and within DOI, continue to have difficulty identifying which bureau to contact for specific issues. The split into BOEM and BSEE divided some critical processes that make the work flow less efficient and effective. To mitigate this problem, BOEM and BSEE signed six Memoranda of Agreement, with 43 underlying Standard Operating Procedure (SOP) documents at the beginning of October 2011. The SOPs identified staff to ensure that the documents would be revised as the bureaus evolved, and the bureaus agreed to develop additional documents as needed. Nevertheless, none of the original documents have been updated, and only one additional MOA and SOP were signed. In addition, not all of the SOPs are still being followed. As a result, BOEM and BSEE continue to experience disruptions of workflow, duplication of effort, communication errors, and a lack of knowledge of processes in the other bureau. Industry has also reported inefficiencies in processing requests when coordination and collaboration between personnel in separate bureaus is needed to complete certain transactions. Realigning BOEM and BSEE in a more efficient manner would rectify these problems. This issue is reflected in the fact that, after almost six years, BOEM and BSEE are still working to resolve ongoing coordination issues between the two bureaus. Examples include: o NEPA: BOEM is responsible for NEPA for both BOEM and BSEE. The purpose of this structure is to have a single NEPA analysis cover both agencies’ actions, ensuring consistency of conclusions and mitigation measures. However BSEE cannot use BOEM’s NEPA analysis directly for its decisions and must take the additional step of determining whether BOEM’s NEPA analysis is adequate for BSEE’s purposes. This has led to disagreements about whether NEPA analyses need supplementing for BSEE decisions, and reflects tension regarding whether BOEM should be a service provider for such analyses, or the subject matter expert advising BSEE on NEPA matters. o Financial assurance, decommissioning, and bankruptcies: Responsibilities for managing risks related to decommissioning liabilities are spread across the two bureaus. BOEM is responsible for financial assurance and BSEE is responsible for calculating decommissioning costs, overseeing decommissioning activities, and 6 determining if a well or facility has been decommissioned. Proactively managing financial assurance for these liabilities requires substantial coordination between the bureaus, from the initial decisions on supplemental assurance, through allocation of resources for decommissioning in bankruptcy cases, to release of bonds once all obligations are met. There is a critical need to work together more effectively and to improve bankruptcy related coordination, communication and management to protect the taxpayer's interests. Addressing decommissioning as a life-cycle issue would facilitate discussions of alternate solutions to manage this risk. • • The employees remained in the same buildings in the same geographic locations once the reorganization was complete. The renewable energy function continued to perform all actions within a single bureau despite being identified for split responsibilities in SO 3299. In addition, administrative functions including human resources, finance, procurement, and information technology remained as shared services in support of both bureaus. These facts highlight the strong interdependencies between the two bureaus and suggest that the reorganization had little to no bearing on the need to separate the bureaus to resolve “real and perceived conflicts of interest.” Combining the two bureaus will create moderate savings from reduced overhead, which will allow resources to be transferred to the field or put to other priority purposes. Because BSEE provides BOEM with most of its administrative services (e.g., human resources, finance, procurement, information technology) through a reimbursable services agreement, duplicative services are limited. However, there is some duplication, including executive offices in each headquarters and regional directorate, and congressional, public affairs, budget, and a number of smaller administrative functions. The extent of such savings would be determined as the bureaus work through the details of the reorganization. Challenges in Recombination • Any reorganization requires focused attention from management and the engagement of employees. Several employees would need to be pulled from their usual jobs to help design and plan for the new organization, and most other employees would be distracted throughout the planning process and initial implementation. Thus, a reorganization would divert resources and attention from accomplishing important policy/program objectives (e.g., developing and implementing a new 5 Year Program; regulatory reform). While these objectives would remain as priorities, they would compete for resources with the reorganization, and thus likely not occur as quickly as they otherwise would. • The new bureau would need to establish a new organizational culture, which could impede productivity as the reorganization is implemented. BOEM and BSEE have developed separate cultures reflecting their different missions. BOEM focuses on 7 resource management and science and BSEE on safety, oversight and compliance, and these missions will be important to maintain in a new organization. A substantial portion of the workforce never worked for MMS/BOEMRE (40% of BOEM employees; over 50% of BSEE employees are new to the bureaus since the split). They have no experience with the combined bureau or its culture. This issue could hamper collaboration in trying to develop a new, efficient organization. • There likely will be public criticism, especially from those who recommended the breakup of MMS or who otherwise oppose offshore oil and gas activities. A recent Bloomberg article (https://www.bloomberg.com/politics/articles/2017-06-08/trump-said-to-mullcombining-agencies-separated-after-gulf-spill) included quotes from two members of the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling criticizing the possibility of recombining BOEM and BSEE. This opposition may not be offset by strong public support from others. The same article quoted an industry leader as saying this action is not among industry’s priorities. Some have already expressed concern that reorganization could slow down approvals of industry actions. Additional Considerations Atlantic Region For some time, BOEM staff have argued that the time is right for an Atlantic Regional office. The Atlantic is the only geographic area that spans multiple BOEM responsibilities but has no single office coordinating all of these activities. Currently, Atlantic-based field activities are distributed among three of BOEM’s headquarters offices (Office of Renewable Energy Programs, Office of Strategic Resources, Office of Environmental Programs) and the Gulf of Mexico Region. This separation of functions makes overarching coordination on Atlantic activities challenging. BOEM’s Atlantic OCS-related activities, specifically renewable energy, marine minerals, and oil and gas geological and geophysical permitting, have significantly increased over the past few years. As BOEM’s Atlantic OCS presence increases, so does the need to develop strong, consistent, and cross-cutting Atlantic OCS policies that better integrate programmatic needs, workforce expertise, scientific studies programs, and stakeholder outreach strategies. With this increase in program activities, the need for a single office dedicated to the regional interests of the Atlantic OCS has become critical. This need exists regardless of whether the Administration chooses to have oil and gas lease sales in the Atlantic OCS, though such a program would add to the need for a regional office. Creation of such an office would more clearly separate headquarters and field functions and allow an opportunity to locate this work outside of the immediate Washington D.C. area. Organic Act 8 MMS, BOEM and BSEE were all established by Secretarial Order. Their authorities come from statutes that assign responsibility to the Secretary; the bureaus themselves do not have organic legislation. While the lack of an organic act gives the Secretary the discretion to reorganize these bureaus at will, it also makes it difficult to institutionalize any reorganization. Once the reorganization proposal is complete, the Department could seek to institutionalize it by proposing organic legislation. An organic act has been proposed at various times in the past. While no one voiced any significant opposition to the concept, it also lacked the active support that would have been needed to move a bill forward. Pro • Institutionalizes the new organization in legislation. • Provides stability going forward for the new bureau and its programs. • Provides an avenue for addressing other statutory changes, for example: o Expanding OCSLA to cover US territories and possessions. o Transfer ocean thermal energy conversion and deep seabed mining authorities from NOAA to the new bureau, where they are a better fit with the mission. Cons • Reduces Secretarial flexibility in the future. • Past Congressional proposals have often added provisions to draft organic legislation that may not be consistent with the proposed reorganization or Administration policy. • The Bureau Director would likely become subject to Senate confirmation. Given the controversial nature of the offshore oil and gas program, Senators might put holds on confirmation votes to negotiate commitments regarding access (or lack thereof) to certain parts of the OCS. Options for how to proceed BOEM and BSEE (as well as MMS) were created by Secretarial Order, so any reorganization can be accomplished in the same manner. However, the Department would need the approval of the appropriations committees since all options would include reprogramming funds. This memorandum assumes that ONRR will remain within the Assistant Secretariat for Policy, Management and Budget, and therefore, only considers options for the scope of recombining BOEM and BSEE. 9 First and foremost, if there is a decision to proceed with reorganization, it needs to be made quickly, especially if the goal is to implement on October 1, 2018 (the first day of Fiscal Year 2019). The bureaus will need to conduct employee engagement, make decisions on organizational structure and personnel, develop a new budget structure and FY 19 budget proposal, and handle a myriad of time-consuming administrative matters that will have to be in effect on day one. The sooner this work can get started, the smoother the transition will be. Three options are considered below: I. “Light” Option – Combine HQ functions The reorganization would be directed at headquarters structure and functions. Specifically, there would be a single Directorate for the new bureau, and certain BOEM/BSEE offices (e.g., Congressional Affairs, Public Affairs, Budget, and administrative functions not already covered by the shared service agreement) would be combined with an overall reduction in the workforce among those offices. No changes would be proposed for mission functions and structure, nor for Regional offices, though this could be revisited on a case-by-case basis after the new bureau is established. Pros: • Consistent with goal of reallocating resources from headquarters to front line offices. • Minimizes impact on front-line and mission offices, thus causing the least disruption to delivery of services and implementation of Administration initiatives. • Of all the options, this would take the least time to implement. A realistic goal would be to include the proposal in the FY 2019 President’s budget. • Preserves some of the major elements of the reforms o Maintains increased resources for safety and enforcement o Maintains the role of environmental review and analysis Cons: • Retains a bifurcated organization at the regional level (i.e., two regional directorates) • Does not include any process streamlining or efficiencies, though these can be addressed separately through regulatory reform and other initiatives. 10 II. “Moderate” Option – Combine HQ functions and management of regional offices At the headquarters level, the changes would be identical to those in Option I. In addition, these changes would be mirrored at the regional level, including: establishing a single Regional Director in each region and combining certain functions from the respective Regional Directorates (e.g., budget execution). Mission functions and structure would not be changed at either the national or regional level as part of the initial reorganization, though some changes would be made on a case-by-case basis after the new bureau is established. These later changes would focus on those functions where BOEM and BSEE currently work together to ensure efficient processes. Pros • Consistent with goal of reallocating resources from headquarters to front line offices. • Relatively small impact on front-line and mission offices, thus limiting disruption to delivery of services and implementation of Administration initiatives. • Although more time would be needed to address regional management issues, including the proposal in the FY 2019 President’s budget would still be feasible. • Preserves some of the major elements of the reforms o Maintains increased resources for safety and enforcement o Maintains the role of environmental review and analysis 11 Cons • III. Does not initially include any process streamlining or efficiencies, though these can be addressed separately through regulatory reform and other initiatives. “Heavy” Option – Top-to-bottom organizational assessment In addition to the changes discussed in Options I and II, DOI would undertake an in-depth organizational assessment of both BOEM and BSEE with the intent of examining structure at all levels of the bureaus and, potentially, streamlining processes. The outcome of such an assessment would be a comprehensive restructuring plan that both addresses the structure of the new bureau and recommends changes to business processes. This option could also be accomplished in a phased approach – implement Option II promptly and have the new bureau’s management oversee the organizational assessment after the new bureau is established. Pros • Allows for the reorganization to tackle any and all issues that exist, or are perceived to exist, throughout the offshore program. Cons • Such a comprehensive approach would require most of management’s attention for at least two years, resulting in less attention to other Administration initiatives. An organizational assessment would also require substantial input from bureau subject matter experts, who would be pulled away from mission delivery. • May be viewed as going beyond any issues that need addressing. Most stakeholder concerns with the bureaus are with policy decisions, and any regulatory uncertainty such decisions may cause. The core business processes – regular lease sales, lease administration, review of exploration and development plans, review of drilling and other permits, inspections – provide timely and efficient responses to the regulated community, and the need for reengineering them across the board is not apparent. However, certain processes may benefit from further examination, which can be addressed on a case-bycase basis. • This approach would have a major impact on employee morale and productivity. Undertaking a top-to-bottom assessment sends the message that the front-line offices and functions are “part of the problem” and need to be “fixed.” Having completed a major reorganization almost six years ago, this will likely create some negative reaction among the workforce. 12 • This comprehensive approach would be: (1) time-consuming – likely FY 2020 for implementation; and (2) expensive – requiring a contractor to conduct a comprehensive organizational assessment. • Until such time as the assessment is complete, this approach would likely create a public reaction that we are undoing the post-Deepwater Horizon safety reforms. 13 Table 1: Budget and Personnel for DOI, MMS, BOEM, BSEE, and for 2010 and 2016 and the Percentage Chan Between Those Years. Or anization Personnel Personnel Budget Budget 2010 2016 Chane 2_ Change? DOI 53,460 *49,671 $18.296.000.000 $18.527.000.000 1.26% 5 MMS 1,761 - 1 BOEM - 585 - - $169,560,000 - BSEE - 875 - - $204,671,000 - ONRR - 662 - - $126,487,000 - TOTAL - 2,122 20.5% - $500,718,000 32.7% *Source: 0PM. Sizing Up the Executive Branch. Fiscal Year 2016 (page 7. Table 3). Table 2: Number of personnel in different geographic locations for MMS in 2010 and BSEE, BOEM and ONRR in 2016 and percentage change bv location. 2010 2016 Location MMS BSEE BOEM ONRR TOTAL Change Washington. DC 76 43 37 80 5.3% Sterling. VA 304 229 162 391 28.6% Jefferson. LA 474 286 280 566 19.4% Denver. CO 487 6 668 37.2% New Orleans Dist. 26 53 53 103.9% Houma District 22 44 44 100.00% Lafayette Distiict 24 45 45 87.5% Lake Charles Dist. 21 34 34 61.9% Lake Jackson Dist. 19 34 34 79.0% Paci?c 60 39 32 71 18.3% Alaska Houston 73 17 17 -76.7% Other 87 23 9 32 -63.2% All Sites 1.761 875 585 *662 2.122 20.5% *Note: 2016 ONRR numbers are not broken out by geographic location. This signi?cantly impacts the percent changes in Washington. DC. Denver. Houston. and other sites. but does not affect the overall percent change. 14