[ Oil and gas companies have been cheating the leasing and
drilling system for years, but the Biden administration has the tools
to hold them accountable.]
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HOW THE FEDERAL GOVERNMENT CAN HOLD THE OIL AND GAS INDUSTRY
ACCOUNTABLE  
[[link removed]]


 

Mariel Lutz and Jenny Rowland-Shea
September 19, 2023
Center for American Progress
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_ Oil and gas companies have been cheating the leasing and drilling
system for years, but the Biden administration has the tools to hold
them accountable. _

Williston, North Dakota Oil Field Oil Rig, Photo: Lindsey Gira,
licensed under the Creative Commons Attribution 2.0 Generic license.

 

The oil and gas industry has long taken advantage of the leasing and
drilling system on America’s public lands and waters. For years,
some of the top leaseholders have faced minimal consequences for
repeatedly violating environmental and labor standards, dodging
payments, and shedding liabilities. Indeed, these bad actors are still
allowed to operate and buy new leases on public lands and waters. The
Center for American Progress finds that more than 50 percent of the
top oil and gas companies have exhibited one or more bad-actor
behaviors, such as abandoning wells, shedding liabilities, dodging
royalty payments, or committing environmental or labor violations.
(see Methodology) As the Biden administration reforms the federal oil
and gas program and aims to hold oil and gas companies accountable, it
has an opportunity to create strong limits for bad actors through
rulemakings at the U.S. Department of the Interior. Implementing such
limits would help prevent the middle class from falling victim, yet
again, to oil and gas industry greed.

The current state of leasing and drilling on public lands and waters

Public lands and waters are shared resources that the federal
government manages on behalf of all Americans. The federal government
manages these public lands and waters in a variety of ways, including
for conservation, recreation, grazing, and oil and gas production. The
Bureau of Land Management (BLM) manages public land, or onshore,
leasing, and the Bureau of Ocean Energy Management (BOEM) manages
public water, or offshore, leasing. As of 2022, the oil and gas
industry held more than 34,000 leases on public lands, covering more
than 23.7 million acres.1 In public waters, the oil and gas industry
has more than 12 million acres under lease.2

While many companies participate in federal oil and gas leasing, a
small number hold many of the leases. The top 20 companies, and their
subsidiaries, operating onshore account for more than 40 percent of
leases, covering more than 3 million acres.3 The top 20 companies
offshore account for more than two-thirds of leased acres, covering
more than 9 million acres.4 Many of the biggest companies have
multiple subsidiaries that operate under the company’s original
name, making it difficult to determine who is responsible for various
oil and gas resources and the associated liabilities.5 Data on oil
and gas industry leases are inconsistent and hard to find, further
enabling the damaging behaviors of many companies.

 

The federal oil and gas leasing system has long been criticized by
taxpayer, public land, and ocean advocates as being out of date and
catering to the industry.6 A November 2021 Department of the Interior
report found that “the program falls short of serving the public
interest in a number of important respects,” including causing
damage to taxpayers, the environment, recreation, and cultures.7 This
is in addition to the fact that the federal government already heavily
subsidizes fossil fuels, with billions of dollars in direct and
indirect subsidies every year.8 All of this has augmented massive
profits, with oil and gas companies making more than $200 billion in
profits last year alone.9

Together, the top 20 companies onshore and offshore have had more than
3,000 penalties since 2000, according to Good Jobs First’s Violation
Tracker.10 This corporate misconduct database “covers banking,
consumer protection, false claims, environmental, wage & hour, safety,
discrimination, price-fixing, and other cases” from federal, state,
and local regulators.11 It likely provides an underestimation of the
number of penalties, since the tracker does not cover every company in
the top 20. Whether counted or uncounted, however, companies are
currently able to continue taking advantage of public lands and waters
despite histories of violations that suggest they should not be
trusted with public resources.

Common bad-actor practices in the U.S. oil and gas industry

Bad-actor practices involve taking advantage of the leasing and
drilling system to the detriment of others. For the oil and gas
industry, this involves cheating taxpayers out of their fair share of
payments, putting employees at risk, damaging the environment, and
leaving others to, quite literally, clean up the mess. And these
damaging practices occur on federal lands and waters without affecting
companies’ ability to acquire additional leases or permits.12 If
these companies do not face accountability for bad behavior, they have
no incentive for good behavior. Below are some of the most common
examples of bad behavior for which companies that operate on public
lands and waters should be held accountable.

Shedding liabilities

Abandoning wells

When companies are done extracting fuel from a well, they are supposed
to properly plug the well so it does not pollute the surrounding
area.13 But some companies abandon their wells to avoid paying to
clean up damage.14 Abandoned wells have been piling up for decades,
with more than 3 million dotting the United States.15 In federal
waters, supermajor oil and gas companies—such as BP, Shell, Chevron,
ExxonMobil, ConocoPhillips, TotalEnergies, and Eni—are the current
or former owners of 88 percent of wells with plugging and abandoning
liability.16 Carbon Tracker estimates it would cost $280 billion to
plug all existing documented wells, both active and idle, on U.S.
land.17 Taxpayers should not have to foot that bill. As of April
2021, evidence existed that Chevron, EOG Resources, and Occidental
Petroleum all got new leases after they presumably orphaned some of
their wells on federal land.18

Selling old assets

Some companies sell aging assets, such as old oil wells, and avoid the
costs of cleaning up and properly retiring the associated
infrastructure.19 In 2014, Occidental Petroleum created the spinoff
company California Resources Corp., which absorbed Occidental’s
California assets and the associated liabilities.20 In 2020,
California Resources had more than 17,000 wells and held up to $2
billion in environmental liability—35 percent of all environmental
liability in the state—and declared bankruptcy.21

Some companies have been selling their assets for reasons other than
avoiding cleanup costs. According to a 2022 ProPublica piece, “Shell
has been shedding assets in part to hand off associated greenhouse gas
emissions.”22 This is part of a larger pattern in the oil and gas
industry, as companies sell polluting assets to try to meet
environmental goals.23 More and more frequently, those polluting
assets are being sold to companies that have less stringent
environmental goals than the previous owner.24

Bankruptcies

In the past 10 years, 60 coal companies have declared bankruptcy,
leaving communities with pollution and cleanup costs and former
employees without health care or pensions.25 But coal is not the only
industry that has seemingly utilized bankruptcy to avoid cleaning up
its mess; it would seem that some oil and gas companies are now
following a similar playbook.26 One of the largest oil and gas
bankruptcies from 2018–2020 was that of Chesapeake Energy, which had
$11.8 billion of debt.27 Because of the bankruptcy, Chesapeake was
able to settle with the Environmental Protection Agency (EPA) for $1.2
million, even though the EPA estimated Chesapeake could have been
liable for more than $25 million of alleged violations.28 From
2018–2020, the 25 largest oil and gas bankruptcies paid almost $200
million to executives while laying off more than 10,000 people.29 In
2020, Diamond Offshore Drilling, despite receiving millions of dollars
from a COVID-19 relief bill and paying its executives millions of
dollars, laid off more than 100 employees.30 This was the largest
bankruptcy in the oil industry from 2018–2020.31

Insufficient bonds

When operating on public lands, oil and gas companies must post bonds
to ensure that there is money for cleanup set aside from the outset.
Current federal bond requirements, however, are far too low to cover
the cost of reclamation, leaving taxpayers to either foot the bill or
suffer from pollution. Current bonding standards, which have been
proposed to be changed via a proposed rule, only require companies to
set aside $10,000 for a single lease, $25,000 for a statewide bond
covering all their wells in one state, and $150,000 for a nationwide
bond covering all their wells in the United States.32 The biggest
companies, however, can have thousands of wells, and the estimated
cost for complete reclamation of one well is $76,000.33

Not only are bonds too low, but companies can also use accounting
methods to discount estimated cleanup costs.34 Public Citizen looked
at 11 companies with more than 57,000 wells and $1.5 billion of
environmental liabilities total, based on the companies’ Securities
and Exchange Commission records, and found those companies only have
$281 million total in bonds.35 Furthermore, based on Carbon Tracker
estimates, the combined environmental liabilities for those 11
companies could be more than $10 billion.36 One of those 11 companies
is Chesapeake Energy, which Carbon Tracker estimates is up to $2
billion short on bonds for the cleanup of more than 11,000 wells.37
 

Dodging royalty payments

Oil and gas companies pay royalties, or a percentage of the profits
from sales, on the fuel they extract from public, private, and Tribal
lands and waters to those respective groups. But there are numerous
examples of companies avoiding proper payment of royalties, the
consequence of which is that people do not end up receiving their fair
share of royalties. According to Accountable US, of the top 20 onshore
companies in 2021, 12 had records that show that they have repeatedly
and purposefully underpaid the owners of their mineral leases,
including the American public.38 For example, that year, Devon Energy
agreed to pay more than $6 million to resolve allegations that it
“knowingly underreported and underpaid royalties” to the American
public, through the Department of the Interior.39 Since 2000, Chevron
has been fined more than $213 million for False Claims Act or related
offenses.40 EOG Resources, a former subsidiary of Enron,  was even
investigated by the Department of Interior for “alleged unauthorized
drilling, extraction and sale of federal minerals”; it settled for
hundreds of thousands of dollars.41

Repeated environmental violations

According to Good Jobs First’s Violation Tracker, the top 20 onshore
and offshore oil and gas companies have more than 2,200 environmental
violations, or more than one violation every fourth day for more than
two decades.42 (see Table 1) This totals more than $44 billion since
2000.43 ExxonMobil has the most environmental penalties:
442.44 BP—the fourth-largest operator offshore—has been fined the
most money, more than $36 billion, largely because of the Deepwater
Horizon oil spill, which resulted in a $20.8 billion environmental
fine, the largest in history.45 Since Deepwater Horizon, BP has been
fined more than $1 billion, with 94 offshore leak events in 2021
alone.46 BP was only outdone by Shell, which had 120 leak events
offshore the same year, according to the Bureau of Safety and
Environmental Enforcement (BSEE).47 Not only was BP allowed to
continue profiting from the use of public resources after the
Deepwater Horizon accident, but it also has not significantly changed
its practices.

On land, there were at least 2,449 spills last year, totaling more
than 7.5 million gallons, just in Colorado, New Mexico and
Wyoming.48 Occidental Petroleum spilled almost double the volume in
2022 that it did in 2021.49 Almost 18 million people live within 1
mile of active oil and gas wells; a disproportionately high number of
these people are part of historically marginalized communities, such
as Black, Hispanic, Asian, and Native American communities and those
living below the poverty line, so pollution from those wells will
affect them first.50

Poor labor standards

The oil and gas industry treats not only the environment poorly, but
also its own employees. For example, since 2000, Marathon Petroleum
Corp. has had more than 50 labor-related violations that have meant
more than $67 million in fines.51 Fieldwood Energy has received
almost 1,800 “shut-in incidents of noncompliance,” according to
the BSEE, which occur when a violation threatens human health or
safety or is otherwise severe.52 A 2023 survey of oil and gas workers
showed that companies have cut pay and staff, and one-third of workers
say they have been instructed to break safety protocols.53 It’s
likely that fatalities, based on BSEE data, and other worker safety
incidents are insufficiently reported, further skewing the
understanding of labor violations.54 Furthermore, only 4
[[link removed]] percent of workers in the U.S. oil and gas
extraction industry were in a union last year, leaving most workers
vulnerable to exploitation.55

Policy recommendations

The bad-actor practices that oil and gas companies have demonstrated
on U.S. public lands and waters can be solved through strong
regulations that hold the industry accountable. The Department of the
Interior has the authority to make companies pay their fair share,
clean up the environment, protect individuals and communities at risk
from oil and gas extraction, and limit who is allowed to extract
resources from shared U.S. lands.

Finalize a strong BLM oil and gas rule

The BLM recently released a draft rule to reform the outdated oil and
gas leasing system on public lands.56 Many provisions in the draft
would help ensure that the companies profiting off public resources
act as responsible stewards of those resources. The BLM must finalize
a strong rule that requires companies to pay their fair share and
helps decrease industry speculation and abuse.

The BLM should finalize components of the draft rule, including
provisions to:

* Increase minimum bonds to $150,000 per lease and $500,000 for
statewide bonds, as well as eliminate nationwide bonds. Higher bonds
will help ensure that taxpayers are protected from pollution and
cleanup costs.
* Raise rates for royalties, rents, and bids to ensure that
taxpayers see a fair return for the extraction of public resources.
Higher rates will help reduce speculation by those who do not intend
to produce oil and gas but simply sell the lease at a later date for
profit.
* Eliminate anonymous expressions of interest and implement a fee
for those expressions to help reduce speculative leasing and increase
transparency. The rule would also eliminate the practice of
noncompetitive leasing, whereby parcels of land unsold at auction are
available with the bonus bid requirement waived, allowing lessees to
pay only an administrative fee and $1.50 per acre.57
* Implement a prioritization system that takes into account oil and
gas resources and existing oil and gas infrastructure, as well as
cultural, historical, recreational, and wildlife features, to help
reduce speculative leasing and ensure that BLM lands are put to their
best use for the public good.
* Crack down on idle wells by requiring companies to provide
rationale and seek approval to leave wells idle. The draft rule
specifies that nonproducing, or idle, wells should be permanently
closed within four years of being shut in, barring justification for
improper retirement. Idle wells are a high liability for the public,
and this regulation would help prevent pollution and taxpayer
liability, while holding the industry accountable.
* Formalize leasing as discretionary and affirm that leasing—or
lack thereof—can and should be done in the public interest.

Strengthen bad-actor provisions in the BLM oil and gas rule

The draft BLM oil and gas rule is a solid start, but strengthening
certain aspects of the rule would help ensure a fair oil and gas
leasing program for everyone. The draft rule newly defines
“responsible bidders and lessees” as companies that have a record
of compliance, that have not defaulted on past bids, and that can
fulfill the other leasing requirements. But the rule should include
stronger language about what defines a bad actor and what disqualifies
parties from leasing and drilling America’s public resources. Such
disqualifications should include:

* Repeated or ongoing environmental violations that may be damaging
to the natural environment and/or human health
* Repeated or ongoing labor violations that may be related to
compensation and/or safety
* Repeated or ongoing financial violations, such as dodging royalty
payments or failing to make timely payments
* Operation of a significant number of inactive or nonproducing
wells and/or leases
* Violation of federal or state reclamation requirements

Such bad actors should not be eligible for new leases or permits until
they have resolved all outstanding issues and demonstrated that they
are capable of changing their practices. Further, leases of companies
found not to be a qualified or responsible lessee should be subject to
cancellation. This will prevent them from not properly compensating,
polluting the lands and waters of, and jeopardizing the health of the
American public. Further, the Department of the Interior should create
a public registry of individuals and companies currently identified as
not being a “responsible bidder” or “responsible
lessee.”58 This could include, but is not limited to, maintaining
and making publicly available the list of entities in noncompliance
with reclamation requirements of Section 17(g) of the Mineral Leasing
Act.59

Additionally, the BLM can strengthen the draft rule by:

* Continuing to review and adjust new royalty, rent, and bids in line
with larger economic trends
* Providing further direction as to how lease prioritization
criteria should guide the selection of lands that will be offered for
lease

Strengthen BOEM’s proposed financial assurance rule

BOEM currently has a draft rule that would update how the agency
determines what companies are required to provide bonds when leasing
in federal waters, based on the companies’ financial
reliability.60 The rule makes some progress toward ensuring that
companies are held responsible for decommissioning costs but can and
should be strengthened before it is finalized. In the absence of
getting rid of all waivers for financial assurance, BOEM should:

* Maintain a potential lessee’s record of compliance as a criteria
for leasing.
* Disqualify companies from leasing if they have existing
decommissioning obligations for idle or abandoned wells.
* Require higher credit ratings than currently proposed.
* Remove valuation of proven reserves as a factor for bonding
requirements.
* Increase the assurance standard for proper reclamation from 70
percent to 90 percent, so that the public has the best chance of not
being saddled with pollution or cleanup costs.

Release and finalize a strong offshore fitness-to-operate standard

The Department of the Interior identified the need for and committed
to developing a “fitness to operate” standard in a November 2021
report.61 A rule defining responsible bidders and lessees would help
cut down on the number of bad actors in the offshore leasing program
by limiting the leasing and permitting eligibility of companies with
unresolved violations. Similar to the recommendations for the BLM, a
rule on a fitness-to-operate standard could limit companies with poor
environmental, safety, or reclamation histories in obtaining new
leases and permits.

Improve data collection

In addition to the draft rule’s components, the Department of the
Interior should require improved data collection and public access to
data to enforce these rules and hold industry accountable. As it
currently stands, it can be difficult to determine which companies are
causing damage, and how much, because of incomplete or ineffective
records.62 For example, there is no comprehensive database to
identify to what level companies are bonded and how far below the
estimated total cleanup cost the bonds are. Where possible, the burden
of collecting and publishing data should be on companies, not
agencies.

Conclusion

Wealthy oil and gas companies have been taking advantage of loopholes
in the federal leasing program for far too long, to the detriment of
the nation’s revenue, workforce, and natural resources. The proposed
BLM oil and gas rule would build a fairer system and ensure that the
oil and gas industry actually pays its bills and cleans up after
itself when it uses shared public lands. The proposed BOEM rule on
financial assurance, if appropriately strengthened, and the suggested
fitness-to-operate standard, could similarly help protect U.S. public
waters. The American public knows that actions have consequences, and
it’s time for the oil and gas industry to be held to a fair
standard.

Methodology

To determine how many of the top companies have exhibited bad-actor
behavior, the authors started with the list of the top 20 companies
operating on public lands and the top 20 operating offshore by number
of leases (Table 1), which totaled 38 companies. Any company with at
least one example of bad-actor behavior included in this brief or one
violation listed in the Good Jobs First Violation Tracker was
considered to have exhibited bad-actor behavior. Bad-actor behaviors
include: abandoning wells; shedding liabilities through bankruptcy or
selling old assets; dodging royalty payments; or committing
environmental- or labor-related offenses.

When citing statistics from the Good Jobs First Violation Tracker,
statistics that encompass all the companies from Table 1 are
calculated by combining the appropriate value for all the companies
from Table 1 that are listed in the tracker. Statistics for specific
companies are based on the summary statistics provided on the parent
company summary page of the Good Jobs First’ Violation Tracker.

Acknowledgments

The authors would like to thank Nicole Gentile, Shanée Simhoni,
Meghan Miller, Keenan Alexander, and Beatrice Aronson for their
contributions to this brief.

_[MARIEL LUTZ is a Research Associate, Conservation Policy at The
Center for American Progress._

_JENNY ROWLAND-SHEA is Director, Public Lands at The Center for
American Progress.]_

_The Center for American Progress [[link removed]]
is an independent nonpartisan policy institute that is dedicated to
improving the lives of all Americans through bold, progressive ideas,
as well as strong leadership and concerted action. Our aim is not just
to change the conversation, but to change the country._

Endnotes

* U.S. Bureau of Land Management, “Oil and Gas Statistics: Fiscal
Year 2022 Statistics,” available
at [link removed] (last
accessed August 2023).
* U.S. Department of the Interior, “Interior Department Outlines
Next Steps in Fossil Fuels Program Review,” Press release, March 9,
2021, available
at [link removed].
* Chris Marshall, research manager, Accountable US, personal
communication with authors via email based on data from the U.S.
Bureau of Land Management, June 29, 2023, on file with author.
* U.S. Department of the Interior, “Interior Department Outlines
Next Steps in Fossil Fuels Program Review”; Sean O’Donnell, “Top
50 Company Report: Gulf of Mexico Outer Continental Shelf” (New
Orleans: U.S. Bureau of Ocean Energy Management Office of Resource
Evaluation, 2022), available
at [link removed]
[[link removed]].
* Chris Marshall, research manager, Accountable US, personal
communication with authors via email based on data from the U.S.
Bureau of Land Management, June 29, 2023, on file with author; Shelby
Webb, “Big Oil holds more federal leases than previously known —
report,” Energywire, August 7, 2023, available
at [link removed].
* Jenny Rowland-Shea and Zainab Mirza, “How Oil Lobbyists Use a
Rigged System to Hamstring Biden’s Climate Agenda,” Center for
American Progress, September 30, 2021, available
at [link removed].
* U.S. Department of the Interior, “Report on the Federal Oil and
Gas Leasing Program” (Washington: 2021), available
at [link removed].
* Janet Redman, “Dirty Energy Dominance: Dependent on Denial: How
the U.S. Fossil Fuel Industry Depends on Subsidies and Climate
Denial” (Washington: Oil Change International, 2022), available
at [link removed];
David Coady and others, “How Large Are Global Energy Subsidies?”
(Washington: International Monetary Fund, 2015), available
at [link removed].
* Ron Bousso, “Big Oil doubles profits in blockbuster 2022,”
Reuters, February 8, 2023, available
at [link removed].
* Good Jobs First, “Violation Tracker,” available
at [link removed] (last accessed August
2023). Methodology: combined total of the total number of violation
records for each company from Table 1 listed in the tracker.
* Ibid.
* Mineral Leasing Act of 1920 as amended (MLA), 30 U.S.C. §
226(b)(1)(A) (August 16, 2022), available
at [link removed];
U.S. Bureau of Land Management, “Fluid Mineral Leases and Leasing
Process,” _Federal Register_ 88 (140) (2023): 47562–47648,
available
at [link removed].
* Carbon Tracker, “ARO Portal FAQs,” available
at [link removed] (last
accessed September 2023).
* Nick Cunningham, “Taxpayers Are Footing The Bill For 100-Year
Old Oil Wells,” OilPrice.com, June 21, 2020, available
at [link removed].
* U.S. Environmental Protection Agency, “Inventory of U.S.
Greenhouse Gas Emissions and Sinks 1990-2016: Abandoned Oil and Gas
Wells” (Washington: 2018), available
at [link removed].
* Mark Agerton and others, “Financial liabilities and
environmental implications of unplugged wells for the Gulf of Mexico
and coastal waters,” _Nature Energy_ 8 (2023): 536–547,
available at [link removed].
* Robert Schuwerk and Greg Rogers, “Billion Dollar Orphans: Why
millions of oil and gas wells could become wards of the state”
(London: Carbon Tracker, 2020), available
at [link removed].
* Mark Allison, “Potential Violations of Federal Laws, Rules, and
Policies Concerning Inactive Wells” (Albuquerque, NM: New Mexico
Wild, 2022), available
at [link removed].
* Mark Olalde, “Big Oil Companies Are Selling Their Wells. Some
Worry Taxpayers Will Pay to Clean Them Up,” ProPublica, October 27,
2022, available
at [link removed].
* Business Wire, “Occidental Petroleum Completes Spin-off of
California Resources Corporation,” December 1, 2014, available
at [link removed];
Alan Zibel and Kelly Mitchell, “Fueling Failure: How Execs at
Bankrupt Fossil Fuel Companies Fleeced Sharholders and Laid off
Workers” (Washington: Public Citizen, 2021), available
at [link removed].
* Carbon Tracker, “State Profiles,” available
at [link removed] (last
accessed August 2023); Alexander Gladstone, “California Resources,
State’s Largest Driller, Files for Bankruptcy,” _The Wall Street
Journal_, July 15, 2020, available
at [link removed].
* Olalde, “Big Oil Companies Are Selling Their Wells. Some Worry
Taxpayers Will Pay to Clean Them Up.”
* Andrew Baxter and Gabriel Malek, “Why we need leadership to
close the transferred emissions loophole: Oil and gas companies,
investors, and policymakers all have important roles to play to solve
the problem of transferred emissions,” EDF+Business, November 30,
2021, available
at [link removed].
* Gabriel Malek and others, “Transferred Emissions: How Risks in
Oil and Gas M&A Could Hamper the Energy Transition” (New York:
Environmental Defense Fund, 2022), available
at [link removed].
* Ken Ward Jr., Alex Mierjeski, and Scott Pham, “In the Game of
Musical Mines, Environmental Damage Takes a Back Seat,” Mountain
State Spotlight and ProPublica, April 26, 2023, available
at [link removed];
Erin Savage, “Repairing the Damage: The costs of delaying
reclamation at modern-era mines” (Boone, NC: Appalachian Voices,
2021), available
at [link removed].
* Ward Jr., Mierjeski, and Pham, “In the Game of Musical Mines,
Environmental Damage Takes a Back Seat.”
* Zibel and Mitchell, “Fueling Failure.”
* Chesapeake Energy Corp., et al., Debtors, Case No. 20-33233 (DRJ),
U.S. Bankruptcy Court, Southern District of Texas, Houston Division,
Document 2785, available
at [link removed].
* Zibel and Mitchell, “Fueling Failure.”
* U.S. Securities and Exchange Commission, “Form 10-Q for Diamond
Offshore Drilling, Inc.,” March 31, 2020, available
at [link removed].
Executive compensation information from “2020 Summary Compensation
Table” in U.S. Securities and Exchange Commission, “Form 10-K/A
for Diamond Offshore Drilling, Inc., Commission File Number:
1-13926,” December 31, 2020, available
at [link removed];
Zibel and Mitchell, “Fueling Failure.”
* Zibel and Mitchell, “Fueling Failure.”
* U.S. Bureau of Land Management, “Fluid Mineral Leases and
Leasing Process”; U.S. Bureau of Land Management, “Bonding,”
available
at [link removed] (last
accessed August 2023).
* Chris Marshall, research manager, Accountable US, personal
communication with authors via email based on data from the U.S.
Bureau of Land Management, June 29, 2023, on file with author; Daniel
Raimi and others, “Decommissioning Orphaned and Abandoned Oil and
Gas Wells: New Estimates and Cost Drivers,” _Environmental Science
& Technology_ 55 (15) (2021): 10224–10230, available
at [link removed]. 
* CFI Team, “Asset Retirement Obligation (ARO),” Corporate
Finance Institute, June 7 2020, available
at [link removed];
Zibel and Mitchell, “Fueling Failure.”
* Zibel and Mitchell, “Fueling Failure.”
* Ibid.
* Ibid., Appendix Table 2: Environmental Liabilities.
* Accountable US, “Research On The Top Public Lands Oil And Gas
Leasers: The Big Oil Corporations That Benefit From Interior’s Lax
Leasing Program Include Major Polluters, Royalty Dodgers, And Wealthy
Corporations That Can Afford To Pay Their Fair Share” (Washington:
2021), available
at [link removed].
* U.S. Department of Justice Office of Public Affairs, “Devon
Energy Companies Agree to Pay $6.15 Million to Settle False Claims Act
Allegations for Underpaying Royalties on Gas from Federal Lands,”
Press release, September 27, 2021, available
at [link removed](Oklahoma)%20and%20Devon%20Energy%20Production,in%20Wyoming%20and%20New%20Mexico.
* Good Jobs First, “Violation Tracker Current Parent Company
Summary: Chevron,” available
at [link removed] (last
accessed August 2023). Methodology: total dollar value of False Claims
Act and related offenses.
* Bradley Olson, “How EOG, An Enron Castaway, Became the ‘Apple
of Oil’,” _Bloomberg_, November 5, 2014, available
at [link removed];
U.S. Attorney’s Office, Western District of Oklahoma, “Texas Oil
and Gas Company Pays Over $240,000 to Settle Trespass Allegations
Arising From the Unauthorized Drilling, Extraction, and Sale of
Federal Minerals,” Press release, March 1, 2023, available
at [link removed](%22EOG%22)%2C%20a,Well%20(%22Spitfire%22).
* Good Jobs First, “Violation Tracker.” Methodology: combined
total of the total number of environmental-related offenses for each
company from Table 1 listed in the tracker.
* Ibid. Methodology: combined total of the fines associated with
environmental-related offenses for each company from Table 1 listed in
the tracker.
* Good Jobs First, “Violation Tracker Current Parent Company
Summary: Exxon Mobil,” available
at [link removed] (last
accessed August 2023). Methodology: total number of
environmental-related offenses.
* Good Jobs First, “Violation Tracker Current Parent Company
Summary: BP,” available
at [link removed] (last
accessed August 2023). Methodology: total dollar amount of the fines
associated with environmental-related offenses. Matt Farmer, “The
five most-fined companies in US oil and gas history,” Offshore
Technology, February 17, 2021, available
at [link removed].
* Good Jobs First, “Violation Tracker Current Parent Company
Summary: BP.” Methodology: total of the fines associated with
offenses after and excluding those related to the Deepwater Horizon
accident. U.S. Bureau of Safety and Environmental Enforcement,
“Offshore Incident Statistics: 2021,” available
at [link removed] (last
accessed August 2023).
* U.S. Bureau of Safety and Environmental Enforcement, “Offshore
Incident Statistics: 2021.”
* Center for Western Priorities, “2022 Spills Tracker,” April
10, 2023, available
at [link removed].
* Ibid.
* Jeremy Proville and others, “The demographic characteristics of
populations living near oil and gas wells in the USA,” _Population
and Environment_ 44 (2022): 1–14, available
at [link removed].
* Good Jobs First, “Violation Tracker Current Parent Company
Summary: Marathon Petroleum,” available
at [link removed] (last
accessed August 2023). Methodology: total number and dollar value of
fines from workplace safety or health violations and wage and hour
violations.
* Naveena Sadasivam, “How bankruptcy lets oil and gas companies
evade cleanup rules,” Grist, June 7, 2021, available
at [link removed].
* Megan Milliken Biven and Leo Lindner, “The Future of Energy and
Work in the United States: The American Oil and Gas Worker Survey”
(True Transition, 2023), available
at [link removed].
* Sara Sneath, “Offshore oil and gas worker fatalities are
underreported by federal safety agency,” Southerly, August 18, 2021,
available
at [link removed].
* Barry Hirsch, David Macpherson, and William Even, “Union
Membership, Coverage, and Earnings from the CPS,” Union Stats,
available at [link removed] (last accessed September 2023).
* U.S. Bureau of Land Management, “Fluid Mineral Leases and
Leasing Process.”
* Kate Kelly, Jenny Rowland-Shea, and Nicole Gentile, “Backroom
Deals: The Hidden World of Noncompetitive Oil and Gas Leasing”
(Washington: Center for American Progress, 2019), available
at [link removed].
* U.S. Bureau of Land Management, “Fluid Mineral Leases and
Leasing Process.”
* Section 17(g) of the Mineral Leasing Act of 1920 as amended (MLA).
* Coalition of ocean and climate organizations, comment letter in
response to Docket No. BOEM–2023–0027, on file with author; U.S.
Bureau of Ocean Energy Management, “Risk Management and Financial
Assurance for OCS Lease and Grant Obligations,” _Federal
Register_ 88 (124) (2023): 42136–42176, available
at [link removed].
* U.S. Department of the Interior, “Report on the Federal Oil and
Gas Leasing Program.”
* Chris Marshall, research manager, Accountable US, personal
communication with authors via email based on data from the U.S.
Bureau of Land Management, June 29, 2023, on file with author; Webb,
“Big Oil holds more federal leases than previously known —
report.”

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