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EMD-80-116 1 (1980-09-25)

handle is hein.gao/gaobabbbu0001 and id is 1 raw text is:                                                       /IqU
                    COMPTROLLER GENERAL OF THE UNITED STATES
 i     ..WASHINGTON D.C. 20548



 B-196523                                 SEPTEMBER 25, 1980



The Honorable Cecil D. Andrus
Secretary of the Interior

Dear Mr. Secretary:

     Subject: CGAO's Basis for Its Analysis of S.1637J
               (END-80-116)

     This is in response to your letter of June 16, 1980,
taking issue with our March 14, 1980, report Impact of Mak-
ing the Onshore Oil and Gas Leasing System More Competitive
(EMD-80-60). Following is a point-by-point analysis of the
issues raised in your letter, along with some restatement or
amplification of the basis for the positions taken in our
report.

CHANGE FROM PRIOR GAO POSITIONS

     It is true that we did advocate competitive onshore oil
and gas leasing in 1970 on the grounds that many tracts
apparently could have generated greater revenues if leased
competitively. We would reiterate, however, the point made
in our report as well as in recent testimony before the House
Interior Committee's Subcommittee on Mines and Mining--that
changing world and national circumstances during the past
decade call for some change in emphasis. Domestic energy
production is much more vital now than then, and we were
unable to satisfy ourselves--nor did Interior offer any
evidence--that S.1637 would not have a detrimental effect on
production. Moreover, we did not find that it would even
necessarily increase revenues to the Government or ensure
receipt of fair market value.

     The point should also be made that we are not irrevo-
cably committed to non-competitive leasing; our position is
only that major changes should not be made to the present
system if the uncertainty of their effect is too great, and
particularly if the problems cited can be solved through
less drastic administrative or regulatory changes.





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