GAO-03-23, Endangered Species: Research Strategy and Long-Term Monitoring Needed for the Mojave Desert Tortoise Recovery Program


This is the accessible text file for GAO report number GAO-03-23 
entitled 'Endangered Species: Research Strategy and Long-Term 
Monitoring Needed for the Mojave Desert Tortoise Recovery Program' 
which was released on December 19, 2002.



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Report to Congressional Requesters:



United States General Accounting Office:



GAO:



December 2002:



ENDANGERED SPECIES:



Research Strategy and Long-Term Monitoring Needed for the Mojave Desert 

Tortoise Recovery Program:



GAO-03-23:



GAO Highlights:

Highlights of GAO-03-23, a report to the Chairman, Committee on 

Resources, 

House of Representatives, and Senator Robert Bennett:



ENDANGERED SPECIES

Research Strategy and Long-Term Monitoring Needed for the Mojave 

Desert Tortoise Recovery Program:



Why GAO Did this Study:

Since the 1980s, biologists have been concerned about declines in the 

Mojave 

Desert Tortoise, which ranges through millions of acres in the western 

United States. The tortoise was first listed as a threatened species 

under 

the Endangered Species Act in Utah in 1980; it was later listed as 

threatened 

rangewide in 1990. The listing and designation of critical habitat 

for the 

tortoise, as well as recommendations in the tortoise recovery plan, 

have been 

controversial. In our report, we evaluate—assisted by scientists 

identified 

by the National Academy of Sciences—the scientific basis for key 

decisions 

related to the tortoise, assess the effectiveness of actions taken to 

conserve 

desert tortoises, determine the status of the population, and 

identify 

costs and benefits associated with desert tortoise recovery actions.



What GAO Found:

The 1990 listing of the desert tortoise, the critical habitat 

designation, 

and recommendations in the recovery plan for the tortoise were 

reasonable, 

given the information available at the time. Under the Endangered 

Species 

Act, listing and critical habitat decisions must be based on the 

best 

available scientific and commercial data. These decisions and the 

recovery 

plan recommendations were based on sources that reflected existing 

knowledge 

about desert tortoises. To protect the tortoise, government 

agencies have 

restricted grazing and off-road vehicle use and taken other protective 

actions 

in desert tortoise habitat, but the effectiveness of these actions is 

unknown. 

Research is underway in several areas, including tortoise disease, 

predation, 

and nutrition, but the research has not assessed the effectiveness 

of the 

protective actions. Furthermore, the status of desert tortoise 

populations 

is unclear because data are unavailable to demonstrate population 

trends. 

Before the tortoise may be delisted, populations must increase or 

remain 

stable for at least 25 years—one generation of desert tortoises. 

Determining 

the trends will cost an estimated $7.5 million in the first 5 

years, plus 

additional monitoring every 3 to 5 years at a cost of about $1.5

million per 

year of monitoring. The Fish and Wildlife Service depends on other 

agencies 

and organizations to assist with funding and monitoring, but these 

agencies 

and organizations cannot guarantee assistance from year to year 

because of 

other priorities. Expenditures on desert tortoise recovery since 

the species’ 

first listing in 1980 exceed $100 million, but the exact 

investment is 

unknown. The investment includes $92 million in “reasonably 

identifiable” 

expenditures for the tortoise, plus staff time valued at about 

$10.6 million. 

The overall economic impact of the tortoise recovery program—

including 

benefits as well as the costs incurred by local governments, 

landowners, 

and developers as a result of restrictions—is unknown.



[See PDF for Image]

[End of Figure]



What GAO Recommends:

To ensure that the most effective actions are taken to protect 

the tortoise, 

we recommend that the Fish and Wildlife Service develop and 

implement a 

coordinated research strategy for linking land management 

decisions with 

research results and periodically reassess the recovery plan 

for the tortoise. 

We also recommend that the Secretary of the Interior identify 

and assess 

options for funding long-term rangewide population monitoring. 

The department 

concurred with our recommendations.



To view the full report, including the scope

and methodology, click on the link above.

For more information, contact Barry T. Hill at (202) 512-3841,

hillb@gao.gov.



Contents:



Letter:



Results in Brief:



Background:



Listing, Critical Habitat Designation, and Recommendations 

for Recovery Were Reasonable:



Actions Have Been Taken to Protect the Desert Tortoise, but Their 

Effectiveness Is Unknown:



Data Are Insufficient to Determine the Status of the Desert Tortoise 

Rangewide, and Continued Funding for Monitoring Is Uncertain:



Expenditures for Desert Tortoise Recovery Exceed $100 Million, but the 

Total Economic Impact Has Not Been Quantified:



Conclusions:



Recommendations for Executive Action:



Agency Comments and Our Evaluation:



Appendix I: Actions on Behalf of the Mojave Desert Tortoise:



Appendix II: Objectives, Scope, and Methodology:



Appendix III: Comments from the Department of the Interior:



Appendix IV: GAO Contact and Staff Acknowledgments:



Tables:



Table 1: Acres Designated as Critical Habitat, by Landowner and State:



Table 2: Federal and State Agencies’ Expenditures on the Desert 

Tortoise, Fiscal Years 1989 through 1998:



Figures:



Figure 1: Mojave Desert Tortoise:



Figure 2: Map of Mojave Desert Tortoise’s Range:



Figure 3: Shells of Juvenile Desert Tortoises Likely Killed by Ravens:



Figure 4: Percentage of Threat Related Topics Presented at Desert 

Tortoise Council Symposia, by Topic, 1989 through 2001:



Figure 5: Reported Expenditures on the Desert Tortoise, Fiscal Years 

1989 through 1998:



Figure 6: Total Expenditures, Including Land Acquisition, for Species 

with the Highest Expenditures, Fiscal Years 1989 through 1998:



Figure 7: Trend in Five Agencies’ Staff-Time Investment in Tortoise 

Work, Fiscal Years 1980 through 2001:



Abbreviations:



BLM: Bureau of Land Management:



DFG: Department of Fish and Game:



ERS: Economic Research Service:



OMB: Office of Management and Budget:



United States General Accounting Office:



Washington, DC 20548:



December 9, 2002:



The Honorable James V. Hansen

Chairman, Committee on Resources

House of Representatives:



The Honorable Robert Bennett

United States Senate:



Since the 1980s, biologists have been concerned about apparent declines 

in populations of the Mojave desert tortoise, a species that is 

considered to be an indicator of the health of the desert environment. 

The desert tortoise ranges through millions of acres in Arizona, 

California, Nevada and Utah.[Footnote 1] Population declines in the 

species may be caused in part by a contagious, and sometimes fatal, 

upper respiratory tract disease and by other factors such as drought, 

predation, illegal collection, and habitat degradation or loss 

associated with human activities such as development, livestock 

grazing, and recreation. Together, these conditions led the Department 

of the Interior’s Fish and Wildlife Service (Service) to protect the 

desert tortoise under the Endangered Species Act.[Footnote 2] In 1980, 

the Service designated, or “listed,” a portion of the desert tortoise 

population in Utah as “threatened.” In 1989, the Service temporarily 

listed the rest of the Mojave population of desert tortoises as 

“endangered” on an emergency basis because of an outbreak of upper 

respiratory tract disease. In 1990, the Service issued its final 

determination that the Mojave population of desert tortoises was 

“threatened” throughout its range.



The goal of the Endangered Species Act is to restore species that are 

at risk of extinction so that they can live in self-sustaining 

populations. At the time a species is listed, the act generally 

requires the Service to designate critical habitat essential to the 

conservation of the species. In 1994, the Service designated critical 

habitat covering 6.4 million acres in the desert tortoise’s range. The 

critical habitat encompasses federal land managed by the Department of 

the Interior’s Bureau of Land Management (BLM) and National Park 

Service, as well as Department of Defense installations, and state-and 

privately-owned land. Shortly after designating critical habitat, the 

Service published a recovery plan for the desert tortoise. To protect 

desert tortoises, the plan recommends restrictions, among other things, 

on off-road vehicle access, military maneuvers that destroy habitat, 

clearing for agriculture and development, and livestock grazing. Some 

of these restrictions have been controversial, and some users question 

whether the restrictions are necessary to the desert tortoise’s 

recovery. The plan also recommends monitoring to determine the status 

of desert tortoise populations and track their population trends. Under 

the act, when a population is considered stable and no longer needs the 

act’s protection, the species may be removed from the threatened or 

endangered list.



In this report, we (1) evaluate the scientific basis for the 1990 

listing, the critical habitat designation, and the recovery plan 

recommendations for the desert tortoise; (2) assess the effectiveness 

of actions taken by federal agencies and others to conserve desert 

tortoises; (3) describe what is known about trends in tortoise 

populations; and (4) identify costs and benefits associated with desert 

tortoise recovery actions since the desert tortoise was first listed in 

1980, to the extent that data were available.



To evaluate the scientific basis for the listing decision, critical 

habitat designation, and recovery plan recommendations, we contracted 

with the National Academy of Sciences to identify and assist in the 

selection of scientists with expertise in relevant areas, such as 

conservation biology and desert ecology, to provide technical 

assistance in reviewing the reasonableness of those key decisions in 

light of the scientific information on which they were based. The 

scientists we consulted and other details on the scope and methodology 

of our review are presented in appendix II.



Results in Brief:



The scientists we consulted agreed that the 1990 listing, the critical 

habitat designation, and the recommendations in the recovery plan for 

the desert tortoise were reasonable, given the information available at 

the time. The Endangered Species Act requires that listing decisions 

and critical habitat designations be based on the best available 

scientific and commercial data (i.e., biological or trade data such as 

that obtained from scientific or commercial publications), and that 

recovery plans be developed and implemented if doing so would conserve 

the species. The listing decision, critical habitat designation, and 

recovery plan recommendations for the tortoise were based on diverse 

sources; as is often the case with an at-risk species, limited 

published research was available, and the Service also relied on 

unpublished research and government reports.



Federal agencies and others, including BLM, the National Park Service, 

military installations, and state and local governments, have taken a 

variety of actions to benefit desert tortoises, but the effectiveness 

of these actions is unknown because the necessary analyses have not 

been done. In response to recommendations in the recovery plan, 

agencies have restricted off-road motorized vehicle use, livestock 

grazing, and other activities in tortoise habitat; closed illegal 

garbage dumps to reduce feeding opportunities for ravens that prey on 

young desert tortoises; fenced highways to keep tortoises from being 

run over; and implemented educational programs to inform the public 

about tortoise conservation. Some of the actions are controversial, 

such as restrictions on livestock grazing. As also recommended in the 

recovery plan, research efforts are underway in tortoise health and 

life history, disease, predation by ravens, and effects of livestock 

grazing and off-road vehicles, among other areas, but most research has 

not been directed to assessing the effectiveness of land use 

restrictions and other protective actions. Without knowing how 

effective the protective actions are, the Service and land managers 

cannot ensure that their limited resources are focused on the most 

effective actions. Furthermore, the recovery plan recommends 

reassessment of its findings and recommendations every 3 to 5 years in 

light of ongoing research. However, the Service has not reassessed the 

plan for a number of reasons, such as other pressing needs for limited 

resources. Given the controversy surrounding some of the recommended 

restrictions and the large number of acres and land users affected, we 

believe that it is important to ensure that management decisions are 

supported by research. Accordingly, we are recommending that the 

Service and land management agencies develop and implement a 

coordinated research strategy to link land management decisions and 

research results, and that the Service reassess the recovery plan and 

revise it as necessary.



Data are not available to demonstrate population trends so despite 

actions taken to benefit tortoises, the status of desert tortoise 

populations is unclear. Under the recovery plan, before the tortoise 

may be considered for removal from the list of threatened and 

endangered species, a scientifically credible monitoring plan must show 

that the population has increased or remained stable for at least 

25 years (one generation of desert tortoises). For decades, researchers 

have gathered data on the health and status of desert tortoise 

populations in certain study areas, but these data cannot be reliably 

extrapolated to the entire population. In 2001, the Fish and Wildlife 

Service began a monitoring effort to develop a baseline estimate of 

desert tortoise populations rangewide. Developing the baseline will 

require a total of 5 years to complete at an estimated total cost of 

approximately $7.5 million. Determining population trends will require 

additional monitoring every 3 to 5 years and will cost approximately 

$1.5 million per year of monitoring. To assist with funding and 

conducting the monitoring, the Service depends on other agencies and 

organizations. However, because these agencies and organizations have 

other priorities, they cannot guarantee assistance from year to year. 

Because population trend monitoring is essential to understanding how 

desert tortoises are faring and to ultimately delist the species, we 

are recommending that the Secretary of the Interior work with the 

Secretary of Defense to identify and consider alternative ways to 

ensure continued funding, such as through memorandums of agreement.



Expenditures on desert tortoise recovery exceed $100 million (in 

constant 2001 dollars) since the species’ first listing in 1980, but 

the exact investment to date is not known. Only since fiscal year 1989 

has the Service been required to annually compile and report to the 

Congress federal and state expenditures on a species-by-species basis. 

These expenditures are only those that are “reasonably identifiable” 

for a listed species, such as expenditures for land acquisitions, 

project materials, or staff time spent on activities to protect the 

species. For fiscal years 1989 through 1998, the Service reported that 

federal agencies and states spent a total of about $92 million (in 

constant 2001 dollars) on behalf of the desert tortoise. The 

$92 million spent on the desert tortoise represented about 2.8 percent 

of the $3.3 billion that agencies reported spending on all threatened 

and endangered species from fiscal years 1989 through 1998. 

Comprehensive data on reported expenditures since 1998 were not 

available because the Service has not compiled and issued to the 

Congress an annual expenditure report, as required. According to the 

Service, timely issuance of the report has been hampered by some 

agencies’ tardiness in submitting the requested data, among other 

things. To augment the reported expenditure data, we requested 

estimates of the time that staff from five key agencies spent on 

tortoise-related activities since 1980. During the years not covered by 

the annual expenditures report (i.e., 1980 through 1988 and 1999 

through 2001), these five agencies reported spending staff time valued 

at about $10.6 million on tortoise-related activities. Aside from the 

federal and state expenditures, the overall economic impact (e.g., 

benefits as well as the costs incurred by local governments, 

landowners, and developers as a result of restrictions) associated with 

the tortoise recovery effort is unknown, although some limited analyses 

have been done. To improve reporting of expenditures for threatened and 

endangered species, we are making recommendations intended to ensure 

the timeliness of the Service’s report to the Congress.



We provided the Departments of Defense and the Interior with a draft of 

this report for review and comment. The Department of the Interior 

concurred with all of our recommendations and provided several 

technical clarifications that we have made as appropriate. The 

department’s letter is presented in appendix III. The Department of 

Defense provided oral comments consisting of technical clarifications 

that we have made as appropriate.



Background:



The Mojave Desert tortoise is a relatively large reptile, with adults 

measuring up to 15 inches in shell length (see fig. 1). Desert 

tortoises live in creosote bush and Joshua tree habitats in valleys, 

plains, and washes at elevations generally ranging up to 4,000 feet 

above sea level. In these habitats, desert tortoises construct and live 

in burrows and spend a majority of their life below ground. Desert 

tortoises may live for 50 years or more in the wild, and females do not 

breed until they are at least 15 years old. They usually lay one or 

more clutches of about 6 to 8 eggs between mid-April and the first week 

of July. Although desert tortoises can withstand prolonged periods of 

drought, females may not lay eggs if forage is unavailable. Survival of 

juveniles is thought to be low; some researchers estimate that only 2 

to 3 per 100 hatched may live to become adults.



Figure 1: Mojave Desert Tortoise:



[See PDF for Image]

[End of Figure]



The Mojave Desert tortoise’s range lies north and west of the Colorado 

River in California, southern Nevada, southwestern Utah, and 

northwestern Arizona (see fig. 2).



Figure 2: Map of Mojave Desert Tortoise’s Range:



[See PDF for Image]

[End of Figure]



Apparent declines in tortoise populations have been attributed to many 

factors including habitat loss or degradation, drought, and predation 

on juvenile tortoises by ravens, coyotes, domestic dogs, and other 

animals (see fig. 3). According to the Service, habitat loss has 

occurred as a result of increasing amounts of urban development, 

military operations, and recreational uses such as off-road vehicle 

use, in the tortoise’s range. Habitat degradation has been attributed 

to domestic livestock grazing, particularly in livestock watering and 

loading areas. Other factors that may have caused population declines 

include mortality through vandalism or accidental road kill and removal 

of tortoises from their habitat for pets, food, or commercial purposes. 

Respiratory and shell diseases have also been observed in desert 

tortoise populations.



Figure 3: Shells of Juvenile Desert Tortoises Likely Killed by Ravens 

(quarter dollar shows scale):



[See PDF for Image]

[End of Figure]



Before a species, such as the desert tortoise, can receive protection 

under the Endangered Species Act, the Secretary of the Interior, 

through the Fish and Wildlife Service, is required to use the best 

available scientific and commercial data (e.g., biological or trade 

data obtained from scientific or commercial publications, 

administrative reports, maps or other graphic materials, or experts on 

the subject) to decide whether the species is at risk of extinction. 

The Endangered Species Act specifies the following five factors for 

identifying at-risk species, any one of which is sufficient to 

determine that a species qualifies for the act’s protections:



* present or threatened destruction, modification, or curtailment of a 

species habitat or range;



* overuse for commercial, recreational, scientific, or educational 

purposes;



* disease or predation;



* inadequacy of existing regulatory mechanisms; or:



* other natural or manmade factors affecting a species’ continued 

existence.



Once the Service determines that a species should receive the act’s 

protection, it can list the species as threatened or endangered. As of 

July 2002, 517 animal species and 744 plant species were listed as 

threatened or endangered in the United States.



The act prohibits the “taking” of any listed species of animal and 

defines “take” as to harass, harm, pursue, shoot, wound, kill, trap, 

capture, or collect, or to attempt to engage in any such conduct. 

However, under the act the Service may issue permits that allow the 

taking of a listed species if the taking is incidental to, rather than 

the purpose of, an otherwise legal activity. In most cases, the Service 

must develop a recovery plan for listed species that specifies actions 

needed to recover the species so that it can be removed from the list 

of protected species under the act, or “delisted.”[Footnote 3]



Federal agencies must comply with prohibitions against taking a 

threatened or endangered species and must consult with the Service to 

determine the effect, if any, that their activities may have on listed 

species. In particular, federal agencies must ensure that their 

activities do not jeopardize the continued existence of any endangered 

or threatened species, or result in destruction or adverse modification 

of critical habitat.[Footnote 4] If any proposed activities will 

jeopardize a species or adversely modify its critical habitat, the 

Service will identify reasonable and prudent alternative activities. In 

addition, federal agencies have a broader directive under the act to 

use their authorities to carry out programs to conserve threatened and 

endangered species.



Listing, Critical Habitat Designation, and Recommendations 

for Recovery Were Reasonable:



Scientists we consulted agreed that the listing of the desert tortoise 

in 1990, the critical habitat designation, and the recommendations in 

the recovery plan were reasonable, based on the limited data available 

on the desert tortoise when the relevant decisions were made. These 

decisions were made on the basis of a variety of information, including 

published and unpublished research and government studies. The 

scientists we consulted recognized that, as is often the case when 

making such decisions, little published data on the species were 

available. However, they agreed that the Service’s decisions were 

appropriate and consistent with their understanding of the agency’s 

responsibilities under the act.



Listing and Critical Habitat Decisions Were Based on the Best Science 

Available at the Time:



The Endangered Species Act requires that listing decisions be based 

solely on the best scientific and commercial data available without 

taking into account economic factors. Although the Service is required 

to seek out the best data available at the time, it is not required to 

generate additional data. The listing decision for the desert tortoise 

was based on a variety of information, including published research, 

meeting and symposium proceedings, and government reports. Generally, 

published, peer-reviewed research is considered the most reliable 

information source because the research methods and conclusions have 

been reviewed by other scientists before publication. However, other 

sources such as unpublished research, meeting proceedings, and 

government reports can provide important information for making listing 

and other decisions. Moreover, several scientists said that listing 

decisions are often necessarily based on limited data, because funding 

for research on a species is typically scarce until after that species 

is listed.



The listing decision describes how each of the five listing criteria 

that make a species eligible for protection under the act applies to 

the desert tortoise, with habitat loss and disease cited as threatening 

the tortoise’s continued existence. The scientists we consulted agreed 

that, despite the limited amount of quantitative data on the desert 

tortoise that was available at the time of its listing, the decision to 

list it as threatened was reasonable. In particular, they cited 

increases in threats such as diseases and habitat loss as important 

factors making listing necessary. In addition, researches noted 

declines in numbers. For example, in the western Mojave Desert in 

California, researchers found that some populations decreased by as 

much as 90 percent between the 1970s and the mid-1990s; in Nevada, 

study plots also generally showed declines ranging from 10 to 

39 percent since the late 1970s. The scientists we consulted also noted 

that desert tortoise populations appear to continue to decline. Some 

said that the listing of the desert tortoise was an unusual step by the 

Service because, at the time of the listing, there were still desert 

tortoises occurring across a large range; yet they recognized that 

listing it as threatened was consistent with their understanding of the 

act’s intent to protect species whose numbers are declining and are at 

risk of becoming endangered.



When designating critical habitat, the Service must also use the best 

scientific and commercial information available. Unlike for listings, 

however, the Service must also consider the economic impact of the 

critical habitat designation. The primary source of information for the 

designation was a draft of the recovery plan for the tortoise that 

recommended protection for 14 separate areas of habitat. The Service 

adjusted the boundaries for these 14 areas to generally follow legal 

property boundaries and elevation contours in order to remove as much 

unsuitable habitat as possible and to reflect additional biological 

information. Some areas that were already protected, such as Joshua 

Tree National Monument and the Desert National Wildlife Range, were 

intended to be excluded from critical habitat because the habitat 

within them was already receiving protection as desert tortoise 

habitat.[Footnote 5] After making these adjustments, the Service 

identified 12 areas in its final critical habitat designation--seven in 

California, one in Nevada, one in Utah, and three that span more than 

one state--that total about 6.4 million acres (see table 1).[Footnote 

6]



Table 1: Acres Designated as Critical Habitat, by Landowner and State:



Landowner: Arizona: [Empty]; California: [Empty]; Nevada: 

[Empty]; Utah: [Empty]; Total acres: [Empty].



Landowner: Federal; BLM[A]; Arizona: 286,800; California: 2,375,807; 
Nevada: 

1,085,000; Utah: 89,400; Total acres: 3,837,007.



Landowner: Federal; Military; Arizona: 0; California: 242,200; Nevada: 
0; Utah: 

0; Total acres: 242,200.



Landowner: Federal; National Park Service[A]; Arizona: 41,600; 
California: 

955,313; Nevada: 103,600; Utah: 0; Total acres: 1,100,513.



Landowner: State; Arizona: 5,700; California: 132,900; Nevada: 0; Utah: 

27,600; Total acres: 166,200.



Landowner: Private[B]; Arizona: 600; California: 1,051,500; Nevada: 

35,800; Utah: 12,100; Total acres: 1,100,000.



Landowner: Total acres; Arizona: 334,700; California: 4,757,720; 

Nevada: 1,224,400; Utah: 129,100; Total acres: 6,445,920.



Source: GAO’s analysis of data from the U.S. Fish and Wildlife Service 

and the National Park Service.



[A] BLM in California originally had 3,327,400 acres of critical 

habitat, but the total was reduced to 2,375,807 acres after 

179,130 acres of critical habitat were transferred to Joshua Tree 

National Park under the California Desert Protection Act of 1994; 

another 772,463 acres of critical habitat became part of the Mojave 

National Preserve, which was created under the 1994 act.



[B] Includes 1,600 acres owned by the Paiute Indian Tribe in Utah.



[End of table]



The scientists we consulted said the size and number of the areas 

designated as critical habitat were reasonable given the available 

data, but found that the rationales for drawing the specific boundaries 

were not well explained in the decision documents. The size of the 

areas was determined based on estimates of how dense a desert tortoise 

population should be to ensure the population’s continued existence--

estimates that the scientists noted were based on limited quantitative 

research. Several of the scientists we consulted observed that the 

critical habitat areas appear to have been designated where desert 

tortoise populations were found at the time. One scientist suggested 

that the designation of the areas of critical habitat may have been 

conservative, and that if the designation was done today, the protected 

areas might be even larger.



The Recovery Plan’s Recommendations Reflected Available Scientific 

Information:



In contrast with the requirements for listing and critical habitat, the 

Endangered Species Act does not specify the type of information that 

should be used to develop recovery plans. Instead, the act requires 

that recovery plans contain three specific elements: (1) a description 

of site-specific management actions necessary for the conservation and 

survival of the species; (2) objective, measurable criteria that, when 

met, would result in the removal of the species from the threatened or 

endangered species list, or delisting; and (3) estimates of the time 

and cost required to carry out the plan. However, Service policy 

dictates that recovery plans should seek the best information to 

achieve recovery of a species. While not in effect at the time the 

tortoise recovery team was founded, Service policy is that teams 

developing recovery plans should have diverse areas of expertise and 

may include personnel from many different organizations, including 

officials from other federal agencies and states, and other recognized 

experts.[Footnote 7] According to the Service, recovery plans impose no 

obligations on any agency, entity, or persons to implement the various 

tasks contained within them.



The recovery plan for the desert tortoise addresses each of the three 

required elements. The plan describes site-specific management actions 

for the 14 separate areas that it recommends be established such as 

discontinuing livestock grazing, constructing fencing along highways to 

reduce tortoise road kill, monitoring the health of desert tortoises 

within the areas, eliminating raven nest and perch sites, constructing 

signs to delineate the boundaries of the protected areas, and 

restricting off-road vehicle use. The plan also recommends that 

agencies develop programs and facilities to educate the public about 

the status and management needs of the desert tortoise and its habitat, 

and that research be conducted to monitor and guide recovery efforts. 

In addition, the plan includes estimates of the time frame and costs 

for implementation. Lastly, as the act requires, the plan describes the 

criteria that must be met before the desert tortoise population may be 

considered for delisting. The criteria are:



* as determined by a scientifically credible monitoring plan, the 

population within a recovery unit must exhibit a statistically 

significant upward trend or remain stationary for at least 25 years 

(one desert tortoise generation);



* enough habitat must be protected within a recovery unit, or the 

habitat and desert tortoise populations must be managed intensively 

enough to ensure long-term population viability;



* provisions must be made for population management within each 

recovery unit so that population growth rates are stable or increasing;



* regulatory mechanisms or land management commitments must be 

implemented that provide for long-term protection of desert tortoises 

and their habitat; and:



* the population in a recovery unit is unlikely to need protection 

under the Endangered Species Act in the foreseeable future.



The scientists we consulted agreed that the recommendations in the 

recovery plan describing site-specific management actions are 

reasonable, and reflect the best information available at the time. 

They observed that because much was still unknown about the severity of 

specific threats to desert tortoises at the time the plan was 

developed, its recommendations were made without establishing 

priorities that would reflect differences in the seriousness of the 

threats. For example, the plan does not differentiate among the 

seriousness of the threats from uncontrolled vehicle use off designated 

roads as compared to livestock grazing or dumping and littering. 

Nonetheless, the scientists commented that the plan was a significant, 

resource-intensive effort; indeed, one scientist commented that the 

expertise of the scientists comprising the recovery team was 

unprecedented. The team included experts in reptile and tortoise 

biology, desert ecosystems, population analyses, and conservation 

biology. The team also coordinated with numerous people and 

organizations, including federal and state agencies and officials, and 

others with expertise in desert tortoise and land management issues.



Actions Have Been Taken to Protect the Desert Tortoise, but Their 

Effectiveness Is Unknown:



Federal agencies and others have taken a variety of actions to benefit 

desert tortoises, reflecting recommendations in the recovery plan or 

efforts to minimize the effects of potentially harmful activities, but 

the effectiveness of those actions is not known because the necessary 

analyses to measure their effectiveness have not been done. Federal, 

state, and local agencies and others have acquired habitat, restricted 

certain uses, and promote education programs about the species, and 

research has been conducted or is underway on such topics as the causes 

of disease in tortoises, their nutritional needs, and the effects of 

human activities on tortoises. However, no process has been established 

for integrating agencies’ management decisions regarding the desert 

tortoise with research results. As a result, Service and land managers 

cannot be certain that they are focusing their limited resources on the 

most effective actions. In addition, the recovery plan recommends that 

its recommendations be reassessed every 3 to 5 years, but the plan has 

not been reassessed since its 1994 issuance. Such a reassessment would 

allow the Service to evaluate whether the plan’s recommendations are 

still sound or should be revised in light of more recent research.



Many Actions Have Been Taken or Are Underway to Protect Tortoises:



The recovery plan recommends securing habitat to aid in the recovery 

and continued existence of the desert tortoise. In addition to managing 

land they already own, federal and state agencies--which collectively 

manage over 80 percent of tortoise critical habitat--and private groups 

have made efforts to acquire privately owned land for desert tortoise 

habitat through land exchanges, purchases, or donations. Much of the 

acquired land is surrounded by or adjacent to federally or state-owned 

tortoise habitat, and its acquisition makes management easier by 

consolidating acres needing protection. These land acquisitions have 

occurred primarily in California and Utah, as almost all tortoise 

critical habitat in Nevada and Arizona is already federally owned. For 

example, from 1995 through 2001, BLM acquired approximately 

337,000 acres in California, valued at almost $38 million, primarily 

for the benefit of the desert tortoise. Land acquisition has also been 

an important feature in Utah, where BLM and the State of Utah have 

acquired, through purchase and exchange, more than 7,700 acres of 

nonfederal land valued at almost $62 million, for the benefit of the 

tortoise. In addition to these acquisitions, the Desert Tortoise 

Preserve Committee, a nonprofit organization, acquired more than 

175 acres of privately owned lands within the 39.5-square-mile Desert 

Tortoise Natural Area in California. The Committee, in cooperation with 

another conservation organization, also purchased 1,360 acres of 

privately owned land in desert tortoise critical habitat in the central 

Mojave Desert. The Committee has historically donated or sold land it 

acquires to the federal government or the state of California.



The recovery plan for the desert tortoise also recommends specific land 

use restrictions such as restricting livestock grazing, harmful 

military maneuvers, and excessive and destructive recreational uses. 

The responsibility for implementing many of these actions falls to the 

entities that manage land in desert tortoise habitat, including the 

Bureau of Land Management, the National Park Service, the Department of 

Defense, and state agencies. These agencies have restricted some 

permitted uses on lands with tortoise habitat and taken protective 

steps to aid in the species’ recovery. For example, Washington County, 

Utah, purchased permits allowing livestock grazing on 30,725 acres of 

federal land in tortoise habitat in Utah at a cost of $114,000 from 

ranchers who were willing to sell their land. BLM then retired these 

permits from use. In addition, since 1991, BLM has prohibited sheep 

grazing on more than 800,000 acres of tortoise habitat in California; 

the agency has also restricted cattle grazing in all or part of several 

other grazing allotments in California either entirely or seasonally 

when tortoises are active, as part of a settlement agreement with 

conservation groups.[Footnote 8] The recovery plan’s recommended 

restrictions on livestock grazing are controversial because they affect 

a large number of acres and were recommended on the basis of limited 

published data. Other significant restrictions that benefit the 

tortoise include those addressing off-highway vehicles. For example, 

BLM’s off-highway vehicle management plan limits off-highway vehicle 

use to existing approved areas, specific courses for competitive 

events, or designated roads and trails to protect sensitive habitats, 

species, and cultural resources. However, officials note that enforcing 

compliance among individual users has proven to be difficult.



Agencies have also undertaken projects on their lands to control random 

events such as road kill on highways and human vandalism, and other 

threats that are associated with human development, such as disease 

(which may be spread when captive tortoises are released into the wild) 

and predation by ravens and other animals (which are aggravated by 

humans through the presence of landfills and other sources of food and 

water). For example, agencies and others have installed hundreds of 

miles of fencing to keep tortoises away from roads and other hazardous 

areas. Joshua Tree National Park installed breaks, or “tortoise cuts,” 

in the curbs along more than 5 miles of newly constructed park roads in 

2001 to avoid trapping desert tortoises in roads. To reduce raven 

populations and thus discourage predation on juvenile tortoises, Mojave 

National Preserve has cleaned up approximately 50 acres of illegal 

garbage dumps, and Joshua Tree National Park has removed a total of 

almost 550,000 pounds of garbage from 23 sites. The Army’s National 

Training Center at Fort Irwin also tries to reduce raven populations by 

covering its landfill with three times as much dirt as it would 

otherwise in order to reduce its attractiveness to the birds. In 2000 

and 2001, Edwards Air Force Base closed 42 “pitfalls” (such as mine 

shafts, wells, and irrigation pipes) in critical habitat that were 

potentially hazardous to desert tortoises.



Protective actions may also be required to offset, or mitigate, the 

effects of potentially harmful activities. For example, development may 

occur on nonfederal lands with desert tortoises, but before the Service 

will issue a permit allowing tortoises to be taken or habitat to be 

disturbed, the applicant must develop a plan describing mitigating 

actions--such as timing a project to minimize the likelihood of 

disturbing tortoises, acquiring replacement habitat to compensate for 

the disturbed acreage, or the payment of fees to be used for tortoise 

conservation. Some local governments have obtained permits that allow 

tortoises to be taken so that habitat within their jurisdictions can be 

developed. For example, Clark County, Nevada--which includes Las Vegas-

-has obtained a 30-year permit from the Fish and Wildlife Service that 

allows listed species, including tortoises, to be taken incidental to 

development in the county. The permit allows development of up to 

145,000 acres of desert tortoise habitat on nonfederal land and 

requires that land developers pay $550 to a mitigation fund for every 

acre developed within the county. The mitigation fees are used to pay 

for conservation projects in the county to offset the effects of 

development on desert tortoises and other species. Similarly, 

Washington County, Utah, has a 20-year permit authorizing the take of 

1,169 tortoises incidental to land development in the county. 

Washington County’s primary means of mitigating the effects of 

development on desert tortoises was to establish the 61,000-acre Red 

Cliffs Reserve in which no development is allowed; approximately 

39,000 acres are occupied desert tortoise habitat. BLM and the state of 

Utah manage most of the land within the reserve. Elsewhere in the 

county, development is allowed on approximately 12,000 acres of 

nonfederal land. Developers pay $250 plus 0.2 percent of the 

development costs for each acre they develop; the fees are used to 

manage the reserve.



Agencies and others also rely on education to reduce threats to 

tortoises. For example:



* Department of Defense installations in tortoise habitat require all 

soldiers to attend training that raises their awareness about the 

status of the tortoise and teaches them what to do if they encounter a 

tortoise,



* BLM’s Statewide Desert Tortoise Management Policy includes a detailed 

public education program,



* Joshua Tree National Park and the Mojave National Preserve have 

developed educational kits for use in schools, and:



* Clark County, Nevada, uses radio and newspaper announcements to 

target desert users, reminding them to deposit garbage only at garbage 

dumps in order to control raven populations, shoot responsibly, and 

drive on roads.



Appendix I discusses specific actions agencies have taken in more 

detail.



Effectiveness of Recovery and Mitigation Actions Is Unclear Because 

Research and Management Decisions Are Not Integrated:



The recovery plan recommends that research be conducted to guide and 

monitor desert tortoise recovery efforts and states that as new 

information continues to become available, these new data should 

influence management practices. The recovery plan recommends research 

on threats to tortoises including diseases and other sources of 

mortality, the long-term effects of road density and activities like 

livestock grazing on desert tortoise populations, and the effectiveness 

of protective measures in reducing human-caused desert tortoise 

mortality; it also recommends that a comprehensive model of the life 

history of the desert tortoise be developed, as such information is 

helpful in understanding how various factors influence a species’ 

survival. The scientists we consulted emphasized the importance of 

research for assessing the effectiveness of recovery actions, not only 

for determining whether delisting is appropriate, but also for 

allocating scarce resources to those actions with the most positive 

effects on desert tortoise populations.



Research is underway in several of the recommended areas, including 

diseases and how they are transmitted, desert tortoise habitat and 

health, nutrition, predation, the effects of climate variability on 

tortoises, and survival of juvenile desert tortoises. Scientists from 

many different organizations, including the U.S. Geological Survey, the 

Service, the National Park Service, military installations, military 

laboratories, states, universities, and private consulting groups, 

perform this research. According to information compiled by researchers 

at the Redlands Institute at the University of Redlands, research 

presented since 1989 at the Desert Tortoise Council’s annual symposia-

-where scientists, land managers, and others gather to share 

information on desert tortoise issues--has covered more than 20 areas, 

with disease, livestock grazing, roads, and off-highway vehicle use 

emerging as the four most commonly presented topics (see 

fig. 4).[Footnote 9]



Figure 4: Percentage of Threat Related Topics Presented at Desert 

Tortoise Council Symposia, by Topic, 1989 through 2001:



[See PDF for Image]

[End of Figure]



Note: The Other category represents 17 other areas, and includes 

construction, toxicants, military activities, fire, mining, ravens/

predation, and drought. Each represents less than 5 percent of the 

symposium presentations.



Despite the relatively extensive desert tortoise research efforts, 

there is no overall coordination of the research to ensure that 

questions about the effectiveness of protective actions are answered. 

Such a coordinated program would direct research to address management 

needs and ensure that managers are aware of current research as they 

make decisions. More importantly, such a program would allow managers 

to adapt land management decisions on the basis of science. Unless 

research is focused on determining if restrictions and other protective 

actions are effective, managers cannot demonstrate a scientific basis 

for deciding whether restrictions should remain unchanged, be 

strengthened, or if other actions would be more appropriate. For 

example, since the Bureau of Land Management eliminated sheep grazing 

on more than 800,000 acres in California, neither the Bureau nor the 

Service has assessed whether this action has benefited desert tortoises 

or their habitat. Despite ongoing research into how livestock grazing 

affects the soils and plants upon which desert tortoises depend, few 

data are available to show the extent of its impacts and the 

effectiveness of restrictions in reducing adverse effects. One 

scientist discussed recent research that could influence future 

priorities for protective actions. Specifically, this research suggests 

that tortoise fencing may be more effective along roads with 

intermittent traffic than along highways, as the heavier highway 

traffic may itself deter tortoises from attempting to cross. However, 

we recognize that in some cases obtaining definitive data regarding 

management actions may take many years for long-lived species like the 

desert tortoise.



While no overall process exists for integrating research and management 

decisions, several efforts are underway to aggregate scientific 

information about tortoises and the desert ecosystem and identify 

information gaps.



* The Desert Tortoise Management Oversight Group was established in 

1988 to coordinate agency planning and management activities affecting 

the desert tortoise, and to implement the management actions called for 

in BLM’s Desert Tortoise Rangewide Plan. The group consists of BLM’s 

state-office directors from Arizona, California, Nevada, and Utah and a 

Washington office representative; the four states’ fish and game 

directors; regional directors of the three Fish and Wildlife Service 

offices with desert tortoise management responsibilities; it also 

includes representatives of the National Park Service, the U. S. 

Geological Survey, and the military installations with desert tortoise 

habitat. The Management Oversight Group is intended to provide 

leadership in implementation of the recovery plan, consider funding and 

research priorities, help ensure data analysis procedures are 

standardized, and review plans related to the desert tortoise. In 1990, 

a Technical Advisory Committee was formed to provide technical 

assistance to the group. The Desert Tortoise Research Project, a group 

of U.S. Geological Survey biologists conducting research on the desert 

tortoise, works with the Technical Advisory Committee to help establish 

research priorities.



* The Mojave Desert Ecosystem Program, a cooperative effort among 

several agencies that is led by the Department of Defense, has 

aggregated large amounts of data on elevation, geology, climate, and 

vegetation in the Mojave Desert ecosystem and has made them available 

as a shared scientific database through the Internet. This shared 

database is intended to allow land managers to make data-driven land 

management decisions.



* The California Desert Managers Group, comprised of managers from 

agencies of the Departments of Defense and Interior and the State of 

California, is chartered to develop and integrate the databases and 

scientific studies needed for effective resource management and 

planning for the California desert. Currently, the group is compiling a 

list of the major ongoing scientific activities in the Mojave Desert to 

identify significant research gaps, opportunities to collaborate, and 

opportunities to solicit support for scientific research needed to fill 

those gaps.



* The Redlands Institute at the University of Redlands has begun a 

project, funded by the Department of Defense, to compile, organize, and 

store desert tortoise monitoring information and develop a database of 

desert tortoise-specific research, which the Institute will make 

available to land managers.



In addition, during our review, the Service official with lead 

responsibility for the desert tortoise program made a proposal to the 

Service’s regional office to establish a science office and a permanent 

science advisory committee that would work with managers to ensure that 

future desert tortoise research is responsive to the managers’ needs 

for information. The proposed science office would coordinate research 

and would work with the Mojave Desert Ecosystem Program, the University 

of Redlands, and others to establish and centralize data and 

procedures. The proposed science committee, which would be composed of 

unbiased, recognized experts in disciplines relevant to tortoise 

recovery, would work with the science office and land managers to set 

priorities for desert tortoise recovery actions and review agencies’ 

documents for their scientific soundness. The official anticipates that 

the proposed committee would provide a scientific context to support 

decisions that are, in some cases, difficult and controversial.



The Service Has Not Reassessed the Recovery Plan in Light of Recent 

Research:



The recovery plan recognizes that few of the data available at the time 

the plan was developed were useful for recovery planning; accordingly, 

it recommends that the plan be reassessed every 3 to 5 years in light 

of newer findings. Service guidance also recommends that recovery plans 

be reviewed periodically to determine if updates or revisions are 

needed. Recovery team members and the scientists we consulted agreed 

that the Service should assess new research and determine if the 

recovery plan needs to be revised or updated to accommodate new or 

different findings.



However, although the plan was issued 8 years ago, the Service has not 

yet reassessed it for several reasons. First, because the Service has 

limited resources for meeting its continuing obligations to designate 

critical habitat and develop recovery plans for other listed species, 

resources are not readily available for recovery plan revisions. In 

addition, some Service officials believe that new research has not 

indicated that significant changes are needed in the tortoise recovery 

plan. Finally, some Service officials believe that as new information 

is developed, it can be and sometimes is incorporated into ongoing land 

management decisions.



Given the controversy surrounding some of the recovery plan’s 

recommendations and the resulting management actions, periodic 

reassessment of the plan in view of ongoing research could provide 

evidence for either retaining or revising the existing recommendations. 

For example, according to a recent review of scientific literature on 

threats to desert tortoise populations, research has shown that heavy, 

uncontrolled off-road vehicle use severely damages vegetation that 

desert tortoises rely on for food and reduces population densities, a 

finding that supports restrictions on such use.[Footnote 10] In 

contrast, the effects of livestock grazing on desert tortoises--effects 

that the recovery team identified as a significant threat--are still 

hotly debated, and research has not yet established that livestock 

grazing has caused declines in desert tortoise populations. In 

addition, reassessing the plan based on new research could also 

indicate whether or not the critical habitat boundaries--which were 

based on a draft of the recovery plan--should be revised.[Footnote 11]



Data Are Insufficient to Determine the Status of the Desert Tortoise 

Rangewide, and Continued Funding for Monitoring Is Uncertain:



Data on trends in tortoise populations that would indicate whether or 

not the species is recovering and can be delisted are not available 

because population monitoring efforts have only recently begun and will 

need to continue for at least 25 years (one generation of desert 

tortoises). Although data on desert tortoise populations have been 

collected from study plots in specific areas, these data cannot be 

extrapolated across the desert tortoise’s range. Obtaining the 

necessary trend information has proved difficult because monitoring is 

costly and resource intensive, and continued funding for population 

monitoring efforts is uncertain.



Data Are Insufficient to Determine the Status of the Desert Tortoise 

Rangewide:



According to the desert tortoise recovery plan, identifying trends in 

desert tortoise populations is the only defensible way to evaluate 

whether populations are recovering. Under the plan, before the desert 

tortoise can be delisted, tortoise populations must become stable or 

increase, as shown by at least 25 years of population monitoring. In 

order to monitor population trends, it is necessary to have baseline 

population data. While land managers have been concerned about the 

desert tortoise for over 2 decades, such baseline data are not 

available rangewide because most population monitoring has been done in 

specific areas for other purposes and cannot be extrapolated to the 

entire population. For example, information on the health and status of 

desert tortoise populations in certain areas--primarily in California-

-has been collected from permanent study plots, some since the 1970s. 

These study plots were established to provide data on attributes of 

tortoise populations and their relationships to the condition of the 

habitat and land-use patterns. However, the locations of these plots 

were judgmentally selected and are therefore insufficient to allow 

scientists to project their status to that of the entire desert 

tortoise population.



Development of a baseline population estimate has been delayed in part 

by difficulty in determining an acceptable methodology. The recovery 

plan recommended a technique for estimating desert tortoise 

populations, but that technique was discarded after federal land 

managers agreed in 1998 to a different, more suitable population 

monitoring technique that they believed would provide more reliable 

data on the population rangewide. However, efforts to implement the 

agreed-upon rangewide monitoring technique were hampered by a lack of 

funding and the absence of a designated coordinator. In 2001, the Fish 

and Wildlife Service began coordinating the collection of population 

data throughout the desert tortoise’s range using the agreed-upon 

technique. Establishing a complete baseline population estimate is 

expected to take 5 years. Service officials estimate that after the 

baseline is established, additional monitoring will need to occur every 

3 to 5 years to determine how populations are changing over time. 

According to land managers and tortoise experts, counting tortoises is 

difficult because populations are widespread and spend much of their 

time underground. In addition, there are differences in peoples’ 

abilities to locate individual desert tortoises, especially juveniles, 

which can be as small as a silver dollar coin.



Continued Funding for Population Monitoring Is Uncertain:



A major concern for the tortoise recovery effort is continued funding 

for rangewide population monitoring. A Service official estimates that 

population monitoring will cost more than $1.5 million each year it is 

conducted. The Service depends on agreements with several entities to 

fund monitoring. For example, in 2002, funding for monitoring was 

provided by the Department of Defense, National Park Service, the Fish 

and Wildlife Service, the University of Redlands, Clark County, Nevada, 

and Washington County, Utah.



However, the agencies that have provided funding for monitoring in the 

past have other priorities and legal mandates to which they must 

respond; thus, they cannot guarantee that they will provide funding for 

the population sampling from year to year. For example, a Bureau of 

Land Management official in California made an informal commitment to 

provide $200,000 for monitoring in fiscal year 2002, anticipating that 

the Bureau would continue to receive funding for management in the 

California Desert as it had in previous years. However, the funding did 

not materialize, and the Bureau determined that because of budget 

constraints it would be unable to fund the effort. Service staff are 

frustrated by this situation, because they cannot know in advance 

whether the funding required for sampling will be available, and thus 

cannot effectively plan a population monitoring effort that must span 

at least 25 years.



Expenditures for Desert Tortoise Recovery Exceed $100 Million, but the 

Total Economic Impact Has Not Been Quantified:



Since the desert tortoise was first listed in 1980, more than 

$100 million has been spent on its conservation and recovery, but the 

total economic impact of the recovery effort is unknown. (Throughout 

this section, monetary amounts are expressed in constant 2001 dollars.) 

From fiscal years 1989 through 1998, agencies reported spending a total 

of about $92 million on behalf of the desert tortoise, including about 

$37 million for land acquisition. Comprehensive expenditure data do not 

exist for fiscal years 1980 through 1988, because the reporting 

requirement had not yet been enacted, or for 1999 through 2001, because 

of delays issuing the report. However, staff time estimates by five key 

agencies for these periods account for an additional $10.6 million in 

expenditures on tortoise-related activities. Aside from such 

expenditures, the overall economic impact--benefits as well as indirect 

costs incurred by local governments, landowners, and developers as a 

result of restrictions--associated with the tortoise recovery effort is 

unknown, although some limited analyses have been done.



Expenditures on the Desert Tortoise Exceed $100 Million:



A 1988 amendment to the Endangered Species Act requires that the 

Service submit to the Congress an annual report on or before January 15 

that accounts for, on a species-by-species basis, all reasonably 

identifiable federal and state expenditures during the preceding fiscal 

year that were made primarily for the conservation of threatened and 

endangered species.[Footnote 12] These expenditures cover a myriad of 

activities related to the conservation and recovery of threatened and 

endangered species, such as funding and conducting research, 

maintaining species’ habitats, surveying species’ populations, 

developing plans, and implementing conservation measures. Expenditures 

for land acquisition are also reported, although they were not reported 

as a separate category until fiscal year 1993.



The purpose of the reporting requirement, according to the Service, was 

to obtain information with which to assess claims that a 

disproportionate effort was being made to conserve a few, highly 

visible species at the expense of numerous, less well-known species. 

Through discussions with congressional staff and language contained in 

the conference report for the 1988 amendment, the Service determined 

that it and other federal and state agencies were expected to cooperate 

and to make a “good faith effort” to collect and report expenditure 

data that are “reasonably identifiable” to species. The reporting 

provision, however, was not to become unduly burdensome. That is, 

agencies were not expected to undertake extensive or extraordinary 

measures, such as creating species-specific cost accounting systems, to 

develop exceptionally precise data; nor were agencies expected to pro-

rate staff salaries and other normal operational and maintenance costs 

not directed toward a particular species. According to the Service, a 

significant portion of conservation activities benefiting threatened 

and endangered species are not easily identified to individual species 

such as law enforcement, consultation, and recovery coordination, and 

are, therefore, not included in the annual report.



Based on its understanding of the reporting purpose, the Service issues 

guidance to federal and state agencies each year on the types of 

expenditures to report, which include research, habitat management, 

recovery plan development or implementation, mitigation, status 

surveys, and habitat acquisition, as well as the salary costs of 

employees who work full-time on a single species or whose time devoted 

to a particular species can be readily identified. The guidance states 

that salary costs of staff that are not assigned to work on particular 

species, expenditures on unlisted species or state-listed species 

(unless they are also federally listed), and expenditures on formal 

consultations dealing with multiple species should not be reported. The 

Service also does not include agencies’ unrealized revenues from unsold 

water, timber, power, or other resources resulting from actions taken 

to conserve threatened or endangered species.



Reported federal and state expenditures on behalf of the desert 

tortoise totaled about $92 million, including about $37 million for 

land acquisition, from fiscal years 1989 through 1998--the latest year 

for which comprehensive data were available.[Footnote 13] Of all the 

agencies reporting desert tortoise expenditures, the Bureau of Land 

Management spent the most by far--about 5 times more than the Service 

spent (see table 2).[Footnote 14]



Table 2: Federal and State Agencies’ Expenditures on the Desert 

Tortoise, Fiscal Years 1989 through 1998:



In constant 2001 dollars.



Bureau of Land Management; Expenditures: $48,598,000.



Fish and Wildlife Service; Expenditures: 9,785,000.



Air Force; Expenditures: 7,299,000.



Federal Highway Administration; Expenditures: 6,063,000.



Army; Expenditures: 4,460,000.



U.S. Geological Survey (formerly National Biological Survey); 

Expenditures: 3,821,000.



Corps of Engineers; Expenditures: 3,655,000.



Marine Corps; Expenditures: 2,129,000.



States; Expenditures: 1,402,000.



Wildlife Services (Animal and Plant Health Inspection Service, USDA); 

Expenditures: 1,059,000.



National Park Service; Expenditures: 988,000.



Department of Defense (not broken out by service); Expenditures: 

793,000.



Navy; Expenditures: 584,000.



Bureau of Mines; Expenditures: 582,000.



Smithsonian Institution; Expenditures: 301,000.



Bureau of Indian Affairs; Expenditures: 221,000.



Bureau of Reclamation; Expenditures: 157,000.



Environmental Protection Agency; Expenditures: 138,000.



Forest Service; Expenditures: 113,000.



Natural Resources Conservation Service; Expenditures: 45,000.



Federal Energy Regulatory Commission; Expenditures: 8,000.



Federal Aviation Administration; Expenditures: 6,000.



Total; Expenditures: $92,000,000.



Note: The annual expenditure reports do not summarize information on an 

agency-by-agency basis. Accordingly, we obtained and summarized the 

expenditures that the individual agencies submitted to the Service.



Source: GAO’s analysis of agency data.



[End of table]



Over the 10-year fiscal period from 1989 through 1998, federal and 

state expenditures on the desert tortoise increased more than 40-fold, 

from about $719,000 in fiscal year 1989 to nearly $31.7 million in 

fiscal year 1998 (see fig. 5).



Figure 5: Reported Expenditures on the Desert Tortoise, Fiscal Years 

1989 through 1998 (in constant 2001 dollars):



[See PDF for Image]

[End of Figure]



The sharp increases in tortoise expenditures in fiscal years 1997 and 

1998 are associated with significant expenditures for land acquisition. 

In fiscal year 1997, nearly $8 million--or 56 percent of the 

$14 million in expenditures on the tortoise that year--was for land 

acquisition. Similarly, in fiscal year 1998, about $26.5 million--or 

84 percent of the $31.7 million spent on the tortoise--was for land. 

All of the land acquisition expenditures for the tortoise in 1998 were 

made by the Bureau of Land Management, as was all but about $800,000 of 

the 1997 land acquisition expenditures (the Service made the 

remainder).



The $92 million that federal and state agencies reported spending on 

the desert tortoise accounted for about 2.8 percent of the total 

$3.3 billion they reported spending on all threatened and endangered 

species from fiscal years 1989 through 1998.[Footnote 15] During this 

period, 13 species, including the desert tortoise, each had total 

expenditures of more than $50 million; these species accounted for 

about 43 percent of total expenditures during this period (see fig. 6).



Figure 6: Total Expenditures, Including Land Acquisition, for Species 

with the Highest Expenditures, Fiscal Years 1989 through 1998 (in 

constant 2001 dollars):



[See PDF for Image]

[End of Figure]



Comprehensive data on expenditures on endangered species have not been 

available since fiscal year 1998 because the Service has not been 

issuing its reports annually, as required. The latest report was 

published on August 30, 1999, and was for expenditures in fiscal year 

1997. Service officials also provided us a draft of the report on the 

fiscal year 1998 expenditures, which we included in our analysis. Also, 

although comprehensive expenditure data were not available since fiscal 

year 1999, the Service shared with us the data it had received as 

August 19, 2002. By that date, all but a few agencies had reported 

their 1999 expenditures. Five agencies and the states, however, had not 

reported their 2000 expenditures, and only two agencies had reported 

their 2001 expenditures. For these 3 fiscal years, federal and state 

agencies had reported a total of about $12.4 million in additional 

desert tortoise expenditures. (This amount is not included in the 

$92 million in reported tortoise expenditures.):



The Service official responsible for the report admitted that the 

agency has not been complying with the annual reporting requirement for 

several reasons. First, the Service has not always been timely in 

requesting the needed information from federal and state agencies. 

Second, several agencies have not submitted their information on time, 

and the Service has chosen to wait to issue the report until all 

agencies have done so. In some cases, agencies have been more than a 

year late in providing information to the Service. And third, competing 

priorities within the Service have delayed the report’s preparation. 

For example, the staff responsible for preparing the expenditures 

report had concurrent responsibilities such as outreach, interagency 

coordination, Endangered Species Act listings, and critical habitat 

determinations. For future reports, the Service plans to develop a web-

based reporting system and use an intern to compile the data in order 

to issue its report more timely.



Without timely issuance of the annual reports, decision makers and the 

public have an incomplete picture of the expenditures made on 

threatened and endangered species, both individually and in total. 

These reports constitute the only readily available, consolidated 

source of federal and state expenditures on a species-by-species basis. 

Accordingly, they can serve as a valuable tool--for the Congress, 

agency officials, and other interested parties--for assessing trends in 

spending over time, whether for all species or for any one species of 

interest. For example, the reports allow the Congress to assess whether 

a few species are receiving a disproportionate amount of funding at the 

expense of numerous other species. Additionally, the reports allow one 

to discern spending patterns that could, in turn, indicate regions or 

ecosystems that may be receiving more or less attention.



Because the Service’s annual report does not account for many years 

during which tortoise work was being done, we requested staff-time 

estimates from five key agencies involved in desert tortoise 

activities--the Bureau of Land Management, the Department of Defense, 

the National Park Service, the Fish and Wildlife Service, and the U.S. 

Geological Survey.[Footnote 16] These agencies estimated that they 

spent the equivalent of 471 staff years, worth about $29.6 million (in 

2001 dollars), on tortoise activities from fiscal years 1980 through 

2001.[Footnote 17] Agencies developed their staff-time estimates based 

on staff memory, judgment, and anecdotal evidence, supplemented by 

personnel records reviews. These estimates cannot be combined with the 

annual expenditures that are reported because some agencies include 

staff time in their reports and others do not. We can, however, add to 

the reported expenditures the value of the five agencies’ staff-time 

estimates for the 9-year period for which annual expenditure data have 

not been compiled (fiscal years prior to 1989 and after 1998). The five 

agencies’ total staff-time estimate for these pre-and post-reporting 

periods is valued at about $10.6 million (in addition to the $92 

million in expenditures reported by federal and state agencies).



Of the five agencies estimating staff time devoted to tortoise-related 

activities over the 22-year fiscal period from 1980 through 2001, the 

Bureau of Land Management reported the greatest staff-time investment-

-about $16.2 million, more than the four other agencies combined. The 

Service was a distant second, with a staff-time investment of about 

$5.5 million--about a third that of the Bureau’s. Overall, the 

agencies’ staff-time investment steadily increased from 1980 through 

1989, and then rose sharply following the tortoise’s rangewide listing 

as a threatened species (see fig. 7).



Figure 7: Trend in Five Agencies’ Staff-Time Investment in Tortoise 

Work, Fiscal Years 1980 through 2001 (in constant 2001 dollars):



[See PDF for Image]

[End of Figure]



The Overall Economic Impact Associated with Tortoise Recovery Is 

Unknown:



Aside from the reported expenditures and staff-time cost estimates, the 

overall economic impact associated with the tortoise recovery effort is 

unknown, although some limited analyses have been done. For example, 

while it is known that restrictions on residential and commercial 

development in tortoise habitat have resulted in foregone 

opportunities, the extent and economic value of such lost opportunities 

has not been quantified. City and county governments, individual 

landowners, developers, and recreationists have incurred costs to 

comply with the requirements to protect tortoises, but no consolidated 

source of information exists to determine the full extent of such 

costs, and some are difficult to quantify. These requirements include 

training employees to correctly handle tortoises they encounter, facing 

project or event delays or restrictions associated with tortoise 

conservation, and preparing mitigation plans.



Although various publications have estimated some costs and discussed 

benefits, none provides a comprehensive analysis of the economic impact 

of restrictions on land use to protect the desert tortoise. The most 

comprehensive analysis we reviewed was prepared by the Service in 

conjunction with its 1994 designation of critical habitat for the 

desert tortoise. This analysis evaluated the impact of potential 

restrictions on federal land use in the seven counties that would be 

affected by the designation of critical habitat for the 

tortoise.[Footnote 18] The analysis concluded that the restrictions 

stemming from the designation could significantly affect small rural 

communities, but they would have little effect on the regional or 

national economy. According to the economic analysis, the critical 

habitat designation would primarily affect three activities: ranching, 

mineral extraction, and recreation. For example, the analysis estimated 

a loss of no more than 425 jobs in the seven affected counties, with 

340 of those in the ranching industry. Ranching profits were expected 

to be the hardest hit, with a reduction of about $4.5 million. About 51 

permits--covering about 1.7 percent of all grazing units allowed on 

federal land in Arizona, California, Nevada, and Utah--would be 

affected.



It is important to note that the Service’s analysis considered only the 

effects of restrictions on federal land. The analysis recognized that 

many restrictions had already been put in place on federal and 

nonfederal land as a result of the tortoise’s listing. For example, it 

cited restrictions on grazing and off-road vehicle use in California 

and Nevada and indicated that the critical habitat designation could 

result in additional restrictions in those areas. For Utah, however, 

the report stated that little or no additional restrictions would 

likely be associated with the designation, as critical habitat had 

previously been designated for the small portion of the population of 

the tortoise in the state.



An analysis conducted by the Department of Agriculture’s Economic 

Research Service substantiated some of the results of the Service’s 

economic analysis for the critical habitat designation. This analysis 

estimated the direct and total economic effects of different levels of 

reductions in grazing rights in counties with known populations of 

desert tortoises and in counties with designated habitat areas. The 

estimated effects of grazing restrictions on federal land ranged from 

$3 million to $9 million.[Footnote 19] This analysis also concluded 

that grazing restrictions may have a significant impact on individual 

ranchers, but their impact on regional economies was not as 

significant. Under every scenario, the relative cost of total impacts 

from restrictions was less than 0.08 percent of the gross domestic 

product of the economic region. Lost livestock sales were the single 

largest cost associated with grazing restrictions; however, grazing 

restrictions were not likely to affect national livestock production or 

prices. Other kinds of restrictions can similarly have an economic 

cost. For example, restrictions on development, mining, and off-road 

vehicle use can result in foregone revenue and recreation 

opportunities. Such costs, however, have not been quantified.



An analysis prepared by Washington County, Utah, in 1995 examined the 

costs and benefits associated with protective actions for the desert 

tortoise. Specifically, the county analyzed the costs and benefits of 

obtaining a permit from the Service that would allow the county to 

approve development projects in desert tortoise habitat. Under this 

permit, the county would establish a 61,000-acre reserve for desert 

tortoises to mitigate potential harm to tortoises from the projects. 

The analysis concluded that the benefits of establishing the reserve 

would be more than the benefits associated with having individual 

developers obtain permits and carry out their own mitigation actions. 

Property tax revenue were estimated at about $48 million more with the 

county obtaining the permit because if individual developers had to 

obtain their own permits, they would not likely develop as much 

land.[Footnote 20] Creating the reserve was expected to have little 

effect on mining and no effect on farmland. The analysis did not 

quantify the reserve’s economic impact on livestock grazing, although 

it noted that the county would extend purchase offers to holders of 

grazing permits on reserve land. Finally, the analysis concluded that 

the reserve would result in many benefits. These benefits include the 

aesthetic value of the open space within the reserve, the increased 

value of private property adjacent to the reserve (and the associated 

increase in property taxes), and annual expenditures of about 

$17.5 million a year by local and regional visitors to the reserve and 

its associated education center.



Clark County, Nevada, also analyzed, in 2000, costs and benefits for a 

permit that would allow development similar to that in Washington 

County. However, Clark County’s permit addresses potential impacts to 

79 species including the desert tortoise, and the economic impact 

associated with the tortoise cannot be identified separately. In 

addition to the county’s analysis, agencies that manage land in Clark 

County have prepared their own economic analyses, as part of 

environmental impact statements for their individual management plans. 

For example, BLM identified negative fiscal impacts from restrictions 

on cattle grazing in desert tortoise habitats in Clark County. As a 

result, the county has obtained grazing and water rights from willing 

sellers rather than restricting grazing outright. In contrast, the 

Forest Service found positive socioeconomic impacts from tortoise 

protections included in its management plan for the Spring Mountains 

National Recreation Area.[Footnote 21] These positive impacts were 

associated with increased recreation that could provide business 

opportunities for the surrounding communities.



As the Washington County and Spring Mountains analyses indicate, 

tortoise recovery efforts can lead to measurable economic benefits. 

Other economic benefits clearly derive from efforts to protect the 

desert tortoise, but generally have not been estimated. These benefits 

are intangible and include such things as aesthetic values associated 

with protected areas, the knowledge that the tortoise continues to 

exist and may be available for future generations, and the corollary 

benefits that other species enjoy as a result of protections extended 

to the tortoise. Also, according to agency officials, the tortoise 

recovery effort has resulted in improved communication and coordination 

among federal, state, and local government officials, as well as 

private groups such as environmental advocates and off-highway vehicle 

clubs. Agency officials believe that education and communication 

efforts ultimately achieve greater protections for not only the 

tortoise but for the desert ecosystem as a whole.



Conclusions:



Many scientists consider the desert tortoise to be an indicator of the 

health of the desert ecosystem, and to date, over $100 million has been 

spent on efforts to protect and recover the species. Despite the 

significant expenditures made and actions taken to conserve the 

tortoise, land managers and the Service lack critical management tools 

and measures needed to assess the status of the species and to 

determine the effectiveness of protections and restrictions that have 

been taken. Specifically, the lack of a strategy for integrating 

research with management decisions prevents the Service and land 

managers from ensuring that research is conducted to evaluate the 

effectiveness of protective actions taken and to identify additional 

actions that could assist in the recovery effort. While several efforts 

are underway to consolidate scientific information about the tortoise 

and its habitat, and a recent proposal has been made for integrating 

science with management, it is unclear how and to what extent these 

efforts will be used to direct research and management actions, and the 

efforts may be duplicative if not properly coordinated. In addition, 

the original recovery plan for the tortoise has not been reviewed to 

determine whether recommended actions are still valid or whether recent 

scientific information would suggest more effective recovery actions. 

Such a review is important given the continued uncertainties 

surrounding some of the plan’s original recommendations. Also, a lack 

of funding assurances may hamper efforts to collect rangewide 

population monitoring information needed to assess the current status 

of the desert tortoise and to track the future growth or decline in the 

species. Finally, late and incomplete expenditure reporting precludes 

the Congress and the public from knowing the type and extent of 

expenditures involved in the desert tortoise recovery effort. Unless 

these shortcomings are addressed, questions will persist about whether 

the current protection and recovery efforts and actions are working and 

are necessary, and even whether the species continues to be threatened 

with extinction.



Recommendations for Executive Action:



To ensure that the most effective steps are taken to protect the 

tortoise, we recommend that the Secretary of the Interior direct the 

Director of the Fish and Wildlife Service to take the following steps:



* Develop and implement a coordinated research strategy that would link 

land management decisions with research results. To develop such a 

strategy, the Director should evaluate current efforts to consolidate 

scientific information and existing proposals for integrating 

scientific information into land management decisions.



* Periodically reassess the desert tortoise recovery plan to determine 

whether scientific information developed since its publication could 

alter implementation actions or allay some of the uncertainties about 

its recommendations.



* To ensure that needed long-term monitoring of the desert tortoise is 

sustained, we recommend that the Secretary of the Interior work with 

the Secretary of Defense and other agencies and organizations involved 

in tortoise recovery, to identify and assess options for securing 

continued funding for rangewide population monitoring, such as 

developing memorandums of understanding between organizations.



* To provide for more timely reporting of expenditures for endangered 

species, we recommend that the Secretary of the Interior direct the 

Director of the Fish and Wildlife Service to issue the annual 

expenditure reports as required by the law, and to advise the Congress 

if reports are incomplete because not all agencies have provided the 

information requested.



Agency Comments and Our Evaluation:



We provided copies of our draft report to the Departments of the 

Interior and Defense. The Department of the Interior concurred with our 

findings and recommendations. The department also provided technical 

clarifications from the Fish and Wildlife Service, Bureau of Land 

Management, National Park Service, and U. S. Geological Survey, which 

we incorporated as appropriate. The Fish and Wildlife Service also 

provided details on actions planned or underway to implement our 

recommendations. The Department of the Interior’s comment letter is in 

appendix III. The Department of Defense provided oral comments 

consisting of technical clarifications, which we also incorporated as 

appropriate.



As agreed with your office, unless you publicly announce the contents 

of this report earlier, we plan no further distribution until 10 days 

from the report date. At that time, we will send copies of this report 

to the Secretary of the Interior, the Secretary of Defense, and other 

interested parties. We also will make copies available to others upon 

request. In addition, the report will be available at no charge on the 

GAO Web site at http://www.gao.gov. If you or your staffs have any 

questions, please call me at (202) 512-3841. Key contributors to this 

report are listed in appendix V.



Barry T. Hill:



Director, Natural Resources and Environment:

Signed by Barry T. Hill:



[End of section]



Appendix I: Actions on Behalf of the Mojave Desert Tortoise:



Federal agencies and others have taken a variety of actions to benefit 

desert tortoises, reflecting recommendations in the recovery plan or 

efforts to minimize the effects of potentially harmful activities. 

These actions include acquiring habitat, restricting certain uses, 

promoting education programs about the species, and funding or 

conducting research on such topics as the causes of disease in 

tortoises, their nutritional needs, and the effects of human activities 

on tortoises. The Management Oversight Group’s Technical Advisory 

Committee surveyed agencies about the actions they have taken to date; 

what follows is a list of some of the actions reported in that survey 

and to us during our review.



Bureau of Land Management:



Arizona:



* In June 2002, the Bureau of Land Management (BLM) acquired 240 acres 

of private property in Arizona, along with an associated 34,722-acre 

livestock grazing allotment. While grazing has not been permanently 

eliminated from this allotment, there is no current livestock use. 

About 10 percent of the allotment lies within a desert wildlife 

management area.



* BLM has closed some existing roads and posted these as closed, signed 

others, and has built some tortoise fencing.



* Competitive events are banned in areas of critical environmental 

concern.



* BLM amended the existing land use plan in 1997 chiefly to implement 

the Desert Tortoise Recovery Plan. Following the amendment of the land 

use plan, the BLM issued approximately 18 grazing decisions to modify 

livestock grazing seasons in order to protect the desert tortoise.



* In 2002, BLM removed 61 burros from desert tortoise habitat and plans 

to remove 10 more in 2003.



* Establishment of new roads is tightly restricted. No off-road vehicle 

use is allowed, and law enforcement staffing has been increased to 

enforce the restrictions.



* BLM has funded tortoise-monitoring studies for several years, 

typically by contracting through Arizona’s Game and Fish Department. In 

addition, a study plot was established in 1980 to research the effects 

of excluding cattle grazing. Other studies have been conducted over the 

years, and the U.S. Geological Survey continues to study such issues as 

fire and its relationship to invasive plants.



California:



* All routes are closed in the Desert Tortoise Natural Area, except to 

owners of private land within the area’s boundary.



* Almost 200 closed routes throughout several management areas have 

been rehabilitated.



* Competitive vehicle events in tortoise habitat are allowed only 

within existing off-highway vehicle open (play) areas or on 

specifically identified courses.



* In 1991, sheep grazing was removed from more than 800,000 acres of 

desert tortoise critical habitat in California, pursuant to a jeopardy 

biological opinion from the Service. All or portions of several cattle-

grazing allotments totaling almost 350,000 acres have been restricted 

or eliminated. Temporary restrictions are in place until bioregional 

plans are completed; specifically, sheep allotments covering more than 

135,000 acres in non-critical habitat cannot be grazed and cattle-

grazing is not authorized on all or part of allotments covering almost 

250,000 acres, and is seasonally restricted in portions of 11 

allotments covering almost 500,000 acres.



* From 1981 through 2002, more than 7,600 burros were removed from 

several areas, some of which were within desert tortoise habitat.



* Since the mid-1990s, BLM has cleaned up several illegal dumps within 

desert tortoise management areas, and community dumps are being closed 

in favor of regional landfills.



* An 18-mile fence was constructed along one boundary of a management 

area to restrict vehicle access from private lands into tortoise 

critical habitat.



* BLM’s information and visitor centers provide information on tortoise 

conservation.



* Since 1989, between 55 and 60 ravens have been removed, most from a 

proposed desert wildlife management area, as part of a pilot raven 

control program.



* In 2001, all BLM lands in selected critical habitat units were 

closed, on an interim basis, to all shooting except hunting and paper-

target practice.



Nevada:



* In 1998, the Las Vegas Field Office’s Resource Management Plan 

established four Areas of Critical Environmental Concern to protect 

critical desert tortoise habitat encompassing a total of 743,209 acres.



* Approximately 54 miles of road have been restored:



* All competitive events involving mechanized and motorized vehicles 

are limited to designated roads and trails within areas of critical 

environmental concern.



* Rights-of-way and utility corridors are restricted, and new landfills 

are prohibited.



* Two dump sites were cleaned up in one area of critical environmental 

concern, and through off-site mitigation fees collected from sand and 

gravel community pit sales, BLM has provided $12,000 and 40 people-

hours to clean up another large dump site.



* BLM, in cooperation with Clark County, has developed a brochure 

depicting the locations of approved routes of travel and provides 

information on use restrictions.



* BLM has issued a number of trespass violations and required 

reimbursement for damaged vegetation for off road activities. Money 

collected from these violations is used toward restoring these areas.



* Several areas have been restored: 8 trespass sites, 117 road sites, 

15 gravel/corral sites, and 4 dumpsites.



* Through off-site mitigation fees collected from sand and gravel 

community pit sales, BLM has provided more than $1 million in funding 

for nutritional research on desert tortoises since 1995.



Utah:



* BLM has acquired almost 6,600 acres within the Red Cliffs Reserve.



* BLM has rehabilitated approximately 3.5 miles of closed road and has 

closed more than 25 trails and many other roads to non-motorized 

travelers.



* Red Cliffs Reserve is closed to fuel wood and mineral material sale 

and withdrawn from mineral entry; BLM prohibits surface disturbance 

during oil and gas exploration and limits access for rights-of-way. 

Compensation is required where permanent loss of desert tortoise 

habitat has occurred. Vegetation may not be harvested in the Reserve 

except by permit for scientific purposes.



* The BLM retired grazing on 30,725 acres of land within the Red Cliffs 

Reserve that had previously been under grazing permits.



* One illegal dump was cleaned up with 28 tons of material removed.



* Uncontrolled dogs are prohibited in the Reserve.



* Approximately 10 acres of disturbed habitat in the Reserve have been 

reseeded or rehabilitated.



* BLM offers public lectures and brochures about the Red Cliffs Reserve 

and management of desert tortoises in Washington County.



National Park Service:



Joshua Tree National Park:



* “Tortoise breaks” in curbs allow passage of desert tortoises and 

other wildlife from one side of the road to another. These are also 

used in parking lots to keep tortoises from being trapped.



* More than 400 miles of jeep trails, historic roads, and recent roads 

are closed. Portions have been rehabilitated and re-vegetated.



* A Navy overflight exercise route that passed through portions of the 

park was rerouted because it was thought to potentially harass or 

affect the natural behavior of the desert tortoise and other sensitive 

species.



* The park is working to prevent a proposed landfill from being placed 

outside the park near one of its densest desert tortoise populations.



* Livestock use limited to horses and mules and is restricted to 

designated equestrian trails and corridors.



* The park has cleaned up 23 dumpsites, removing a total of 

547,704 pounds of garbage.



* Tortoises removed from the park are given to the tortoise rescue 

center or tortoise adoption agency where they receive a physical 

inspection and U.S. Fish and Wildlife Service permit tags. Tortoises 

showing symptoms of upper respiratory tract disease are given to a 

researcher for a health inspection.



* Temporary tortoise fencing has been installed at construction staging 

areas for ongoing road construction project. Areas with high tortoise 

densities are fenced off and monitored by park biologists on-site 

during construction.



* Approximately 45 acres of disturbance associated with federal highway 

construction has been rehabilitated.



* Open mine shafts have been fenced and plugged to prevent tortoises 

from falling in.



* The park has developed educational kits and a curriculum unit for 

schools. Park biological technicians train volunteers, construction 

workers, and park staff about desert tortoises.



* The Park has established five study plots; each is visited at least 

10 times per season. More than 400 tortoises have been marked and their 

age, sex, weight, and location have been recorded. Desert tortoise 

sightings reported by park staff and visitors are collected through 

wildlife observation cards; the information is analyzed, recorded, and 

incorporated into a database.



* Research has been initiated on raven populations and upper 

respiratory tract disease. Ravens are monitored and nests are removed 

in areas where they have been seen predating on tortoises.



Mojave National Preserve:



* Mojave National Preserve actively manages all preserve lands 

(1.6 million acres) for desert tortoises. Approximately 772,000 acres 

are federally designated critical habitat for desert tortoise.



* Nearly 100,000 acres--most of which is desert tortoise critical 

habitat--have been acquired within the preserve from private owners or 

from the state of California since 1994.



* Permits for more than 768,000 acres once designated for grazing have 

been retired. Permits for approximately 311,000 additional acres are 

pending retirement. Once that retirement is complete, grazing--and more 

than 4,000 cows--will have been removed from about 564,000 acres of 

desert tortoise critical habitat.



* More than 3,000 burros have been non-lethally removed since 1997.



* The preserve has posted signs and information kiosks to increase 

awareness of travelers of potential tortoise and other wildlife 

encounters.



* Vehicles are permitted only on existing roads, and in camping and 

parking areas. No off road driving is allowed anywhere in the preserve.



* Competitive motorized events are prohibited. Other organized events 

may be allowed on existing roads, outside of the desert tortoise active 

periods, with appropriate restrictions.



* No existing or new landfills are allowed anywhere in the preserve, 

which is also closing and cleaning up old, informal trash dumps. 

Approximately 50 acres of illegal dumps have been cleaned up in the 

preserve.



* Any surface disturbance on preserve lands must be balanced with 

appropriate restoration or acquisition of replacement lands for 

mitigation.



* Permits for vegetation harvest are authorized only for scientific 

collection; the National Park Service requires special stipulations to 

ensure desert tortoises are protected.



* To prevent the spread of disease from captive tortoises, the preserve 

prohibits the reintroduction of tortoises.



* Interpretive staff have developed school programs and created a 

poster and a brochure about the desert tortoise and responsible 

recreational behavior in tortoise habitat. The staff has placed warning 

stickers in preserve vehicles reminding drivers to check under their 

cars before driving.



* In 2001, population density monitoring began in the preserve.



* The preserve manages trash and litter to avoid subsidizing ravens. 

Raven-proof trash containers are being installed throughout the 

preserve.



Lake Mead National Recreation Area:



* Cattle grazing has been removed from desert tortoise habitat in Lake 

Mead National Recreation Area.



* Hard-rock mining in 30,000 acres of desert tortoise habitat is 

prohibited at Lake Mead National Recreation Area.



* Lake Mead National Recreation Area requires that vehicles stay on 

designated roads.



* Lake Mead National Recreation area decided to abandon a proposal to 

build a boat launch and marina because it would have required a road 

through desert tortoise habitat.



Department of Defense:



Army National Training Center at Fort Irwin:



* Fort Irwin has piloted a “head start” program to attempt to conduct 

research on the biology of neonate desert tortoises. Under this 

program, females are removed from the wild and lay their eggs in 

captivity, where the eggs can be protected. In the future, the young 

could potentially be moved into areas where tortoise numbers have been 

severely decreased or where they have been extirpated, if considered 

appropriate.



* Fort Irwin has installed 7.5 miles of tortoise fencing.



* Fort Irwin has funded the population-monitoring program in two 

proposed desert wildlife management areas since 2000. The National 

Training Center has funded many research programs of behavior, disease 

and other topics on the desert tortoise.



* Fort Irwin has predator control programs, which include removing and 

excluding ravens, controlling coyotes, and educating the public to 

limit or eliminate food and water sources for predators:



Marine Corps Air Ground Combat Center at Twentynine Palms:



* The Marine Corps supports an environmental education program; more 

than 50,000 Marines and family members are given an environmental 

briefing annually.



* The Marine Corps provides a portion of the funding required for 

population monitoring efforts.



* Since the early 1980s, the Marine Corps has conducted or cooperated 

with numerous desert tortoise studies and research projects. Research 

projects were recently completed in juvenile survivorship and tortoise 

ecology, and recently initiated projects include tortoise health 

assessments and population monitoring.



* Marine Corps’ Natural Resources staff work closely with the 

installation’s law enforcement to control free-roaming dogs.



* The Marine Corps surveyed 23 areas, comprising 935 square miles, to 

assess the impacts of training on the desert tortoise and its habitat.



Edwards Air Force Base:



* Edwards closed 42 pitfalls (prospect pits, mine shafts, wells, and 

irrigation pipes) in critical habitat that were potentially hazardous 

to tortoises.



* Edwards prohibits competitive and organized events in critical 

habitat.



* Edwards educates personnel on the deposition of captive and displaced 

tortoises. A desert tortoise adoption program has been in place since 

1994; it was established to prevent captive desert tortoises from being 

returned to the wild, prevent wild tortoises from being taken, and 

provide a means of tracking captive tortoises.



* Edwards built 22.7 miles of tortoise fencing in critical habitat to 

keep tortoises from entering hazardous areas (precision bombing 

targets) and from crossing well-traveled paved roads, and installed 48 

miles of four-strand barbed-wire fence in critical habitat.



* Edwards revegetated 155.2 acres in critical habitat.



* Edwards presents an environmental education program on Mojave Desert 

ecosystem to local schools on base and in surrounding towns and during 

public events:



* Edwards funds or conducts population monitoring in critical habitat 

and other areas on base. Other research includes vegetation and habitat 

studies, evaluation of species diversity over time, analysis of soil 

and vegetation samples for presence of toxic metals, and adaptive 

management under the base’s resource management plan.



State of California:



* The Department of Fish and Game (DFG) has acquired and manages more 

than 12,000 acres.



* DFG reviews proposed actions on public lands and makes 

recommendations to BLM; it also reviews and makes recommendations on 

Integrated Natural Resource Management Plans for military bases.



* DFG prohibits and issues citations to people for collecting tortoises 

from the wild.



* DFG has fenced some lands to keep vehicles out. Though DFG has not 

installed fencing along roads, it has been a requirement for many 

projects. Because of large numbers of tortoises on a particular road, 

along with increased traffic associated with a solar energy plant, 

fencing was required and was installed by the Desert Tortoise Preserve 

Committee; a culvert will also be placed under the road.



* DFG provides funding for signs, brochures, and kiosk information.



* DFG provides funding for monitoring of long-term study plots. It is 

co-hosting a workshop on diseases to consolidate known information, 

foster discussion between experts, and solicit management 

recommendations.



* California’s Department of Transportation has purchased 618 acres 

from San Bernardino County and will transfer them to DFG to mitigate 

the effects of a highway expansion on desert tortoises; it also 

installed about 6.5 miles of permanent tortoise fence on I-15.



State of Arizona:



* The Department of Game and Fish prohibits the release of wildlife, 

including desert tortoises, without a special permit.



* The department monitors tortoises on several study plots (largely 

funded by BLM) since 1996; it partially funded population monitoring in 

one area in 2001 and 2002.



* The department conducts or funds research on tortoises in the Sonoran 

Desert (in such areas as life history and disease), which may provide 

comparative insight for Mojave Desert tortoise recovery efforts.



Washington County, Utah:



* The county’s habitat conservation plan designated the 62,000-acre 

(100 square-mile) Red Cliffs Desert Reserve.



* The county is working with BLM and the state of Utah to acquire 

privately owned properties located within the boundaries of the 

reserve; BLM and the state have acquired through purchase and exchange 

more than 7,700 acres of privately owned land within the reserve since 

1996.



* Of the estimated 40 dirt roads in the Reserve, 5 remain open for 

public travel. Service roads are gated and locked. As resources allow, 

closed roads are being rehabilitated. The county has reseeded an 

estimated 5 acres of old roads within the reserve.



* The county compensated willing sellers for loss of grazing within the 

reserve, for a total of 1,517 animal unit months at a cost of 

$113,775.[Footnote 22]



* The county worked with St. George City, Utah, and BLM to clean up the 

old city dump, which was located within high-density tortoise habitat 

in the reserve. At least 30 illegal dumpsites have been cleaned up by 

the county with the help of volunteer groups.



* Wild, displaced desert tortoises that test negative for upper 

respiratory disease are moved, or translocated, to a designated area of 

the reserve.



* The county has installed or funded the installation of 40 miles of 

tortoise fencing. The reserve boundary is being fenced incrementally as 

development occurs nearby.



* The county has posted boundary signs to inform people when they are 

entering the reserve and advise of vehicle, pet, and target shooting 

restrictions.



* The county has funded 5 years’ population monitoring (conducted by 

the Utah Division of Wildlife Resources) at $115,000 per year.



* The county controls ravens that are identified as threats to 

tortoises, and maintains a database of known raptor and raven nest 

sites, which enables monitoring of predation on hatchling tortoises.



Clark County, Nevada:



* Under its multiple-species habitat conservation plan, through the 

Nature Conservancy, the county has purchased grazing preferences from 

ranchers (on a willing-seller basis) on more than 1,000,000†acres of 

public land and eliminated grazing on those lands.



* The county has fenced almost 130 miles of highway, at a cost of about 

$580,000, to keep desert tortoises from being run over.



* The county funds research in such areas as desert tortoise nutrition 

and population monitoring, predation by ravens, translocation.



* The habitat conservation plan funds two BLM law enforcement rangers, 

one National Park Service ranger, and one Nevada Division of Wildlife 

ranger.



* Clark County provides funding for the operation and management of the 

Clark County Desert Tortoise Conservation Center.



* The habitat conservation plan provides funding for a desert tortoise 

pick-up service.



* The county educates the public about tortoises; for example, it has 

hosted contests in which school children estimate when a desert 

tortoise named Mojave Max will first exit his burrow. This event has 

resulted in thousands of studentsí researching Mojave Desert 

temperatures and desert tortoise habits.



* The county funds radio and newspaper announcements targeted to desert 

users, reminding them to drive on roads, shoot responsibly, and deposit 

garbage only at garbage dumps in order to keep raven populations down.



Desert Tortoise Preserve Committee:



* In 1995, the committee acquired 1,360 acres of private property, 

which was the base property for a grazing allotment; since 1994, it has 

acquired more than 175 acres within the Desert Tortoise Natural Area 

and has acquired or is in the process of acquiring more than 

1,200 acres to buffer the natural area and other critical habitat. It 

generally sells or donates land it acquires to BLM or the State of 

California.



* The committee has rehabilitated 2 miles of road and removed 

approximately 3 tons of trash from a grazing allotment to date.



* A naturalist is staffed at the Desert Tortoise Natural Area every 

spring; the naturalist provides interpretive and educational services 

to visitors, routinely intercepts releases of tortoises and other 

turtles, and provides contact information for safe deposition/ 

placement of captive tortoises. A resident host/interpreter at a 

grazing allotment educates visitors to reduce release or take of 

tortoises:



* Dogs are prohibited inside the Desert Tortoise Natural Area; the 

naturalist monitors compliance during the peak visitation period.



* The committee installed 8 miles of tortoise fencing and commissioned 

the design and installation of a tortoise culvert along a busy road.



* The committee has restored habitat at the site of an old toilet block 

at the Desert Tortoise Natural Area; work is ongoing to camouflage 

impacts of illegal off-road vehicle activity along entrance route into 

the area.



* The committee hosts twice-yearly work parties to replace lost/stolen/

vandalized signs and fences at the area.



* The committee installed multimedia interactive kiosk at the 

California Welcome Center in Barstow, California, to provide desert 

environmental education to the general public.



* The committee is evaluating the protective effects of fencing.



[End of section]



Appendix II: Objectives, Scope, and Methodology:



This report examines (1) the scientific basis for the 1990 listing, 

critical habitat designation, and recovery plan recommendations for the 

desert tortoise; (2) the effectiveness of actions taken by federal 

agencies and others to conserve desert tortoises; (3) what is known 

about trends in tortoise populations; and (4) costs and benefits 

associated with tortoise recovery actions since 1980, when one 

population of the tortoise was listed, to the extent that data were 

available.



To evaluate the scientific basis for the listing decision, critical 

habitat designation, and recovery plan (known collectively as “key 

decisions”), we contracted with the National Academy of Sciences to 

identify and assist in the selection of scientists to provide technical 

assistance. The persons we selected have recognized expertise in the 

areas of conservation biology, herpetology, desert ecosystems, and 

federal land management policy, and collectively represent a range of 

perspectives and views on the conservation of threatened and endangered 

species. The selection involved a two-step process. First, the academy 

identified, and provided to GAO, an extensive candidate pool of 

individuals for possible participation. We selected a smaller pool of 

scientists from which the final selections were made, based on the 

scientists’ availability to participate. The academy’s staff 

administered a questionnaire to identify potential conflicts of 

interest; no disqualifying conflicts of interest were identified. The 

scientists participating in the discussion were:



Dr. Roy C. Averill-Murray

Amphibians and Reptiles Program Manager

Nongame Branch, Arizona Game and Fish Department

Phoenix, Arizona:



Dr. Perry R. Hagenstein

Institute for Forest Analysis, Planning, and Policy

Wayland, Massachusetts:



Dr. Jay D. Johnson 

University Animal Hospital

Tempe, Arizona:



Dr. James A. MacMahon

Professor of Biology 

Utah State University

Logan, Utah:



Dr. Dennis D. Murphy:



Research Professor, Department of Biology 

University of Nevada:



Reno, Nevada:



Dr. Patrick Y. O’Brien

Senior Research Scientist:



Chevron Texaco Energy Research and Technology Company

Richmond, California:



Dr. Frederic H. Wagner

Professor of Wildlife and Fisheries:



Utah State University

Logan, Utah:



GAO provided the scientists with the listing decision, the critical 

habitat designation, the recovery plan, and key supporting documents. 

GAO also provided access to other materials referenced in the key 

decision documents. In a 2-day, facilitated discussion, the scientists 

provided their views on five questions:



* Overall, do the listing decision and critical habitat designation 

seem reasonable, given the scientific studies and other information 

that were considered? Where do you agree and what concerns, if any, do 

you have?



* Do the recommended numbers, sizes, and configurations of recovery 

areas and desert wildlife management areas seem reasonable? What are 

the strengths and weaknesses of the population viability analysis?



* Do the recovery plan’s recommendations about activities that should 

be prohibited within protected areas (e.g., grazing, mining, off-road 

vehicle use) and mitigative actions that should be taken (e.g., fencing 

or installing culverts underneath heavily traveled roads) seem 

supported by the scientific studies? Where do you agree and what 

concerns, if any, do you have?



* To what extent do the decision documents acknowledge and accommodate 

uncertainties in the scientific studies? Do the accommodations seem 

reasonable?



* Do any of the issues addressed in the recovery plan need to be 

reassessed from time to time? If so, describe. How often do you think 

such issues should be reassessed, and under what conditions?



To further our understanding of the process used to develop listing 

decisions, critical habitat designations, and recovery plan 

recommendations for the desert tortoise, we interviewed officials and 

collected pertinent documentation from numerous federal agencies, 

including the U.S. Fish and Wildlife Service, the U.S. Geological 

Survey, the Bureau of Land Management, the National Park Service, and 

military installations of the Department of Defense; state and local 

governments in California, Nevada, and Utah; nongovernmental 

organizations, such as the Desert Tortoise Preserve Committee, the High 

Desert Multiple Use Coalition, and the QuadState Coalition; academic 

scientists; and six of the eight members of the desert tortoise 

recovery team.



To assess the effectiveness of actions taken by federal agencies and 

others to conserve the desert tortoise and to assess what is known 

about trends in tortoise populations, we collected relevant land use 

planning documents, habitat conservation plans, and other official 

documents, published and unpublished scientific studies, desert 

tortoise population monitoring reports, survey data collected and 

compiled by the Management Oversight Groups’ Technical Advisory 

Committee regarding recovery actions, and other reports. We interviewed 

officials from federal and state agencies and other organizations 

involved with the tortoise, and conducted several site visits to 

observe tortoise habitat and implementation of conservation actions. 

Specifically, we made site visits to the Desert Tortoise Conservation 

Center in Las Vegas, Nevada; the Desert Tortoise Natural Area in 

California; Joshua Tree National Park; the Marine Corps Air Ground 

Combat Center at Twentynine Palms, California; the Army’s National 

Training Center at Fort Irwin, California; and the Red Cliffs Reserve 

in Washington County, Utah. We also attended the annual symposium of 

the Desert Tortoise Council in Palm Springs, California, which featured 

presentations on actions taken to conserve the desert tortoise and 

results of tortoise recovery efforts and research projects.



To identify costs and benefits associated with desert tortoise recovery 

actions since the tortoise was first listed in 1980, we examined the 

annual expenditure reports the Service is required to submit to the 

Congress; these reports compile and summarize federal and state 

agencies’ annual expenditures on threatened and endangered species, by 

species. The reports contain expenditure data for land acquisition and 

for general activities (e.g., conducting research, monitoring species’ 

populations, developing and implementing recovery plans, and 

constructing fences). The reporting requirement began for expenditures 

made in fiscal year 1989, and the last report the Service submitted to 

the Congress was for expenditures made in fiscal year 1997. We obtained 

all nine of these reports, as well as the draft report for fiscal year 

1998 and the more recent expenditure data (for fiscal years 1999 

through 2001) that the Service had compiled as of August 19, 2002, but 

had not published.



Although the Service summarizes and reports data on a species-by-

species basis, it does not summarize and report data on an agency-by-

agency basis. Rather, the Service reports, in addition to its own 

expenditures, one lump sum for expenditures by other federal agencies. 

Accordingly, we reviewed and analyzed the agencies’ individual 

expenditure reports, which are reproduced in an appendix in each 

report. We were thus able to compare and report information, year by 

year and in total, on individual agencies’ expenditures on the tortoise 

and on other species.[Footnote 23] We excluded from the agencies’ data 

those expenditures that clearly did not meet the intent of the report, 

such as expenditures that could not be broken out by species, 

expenditures made on behalf of sensitive or candidate species (species 

in need of protection but not listed as threatened or endangered), and 

power purchases and revenue foregone as a result of actions taken to 

protect listed species. Nevertheless, our sums did not always match 

those in the reports because the Service also excluded from its sums 

expenditures made on certain species, including species that were state 

listed but not federally listed, species that were listed after the 

fiscal year for which the expenditures were reported, and species that 

were in need of protection but were not listed. Although a few of the 

reports showed which expenditures the Service had excluded from its 

sums, most did not. In such cases, the total expenditures shown in the 

report for “other federal agencies” were less than the totals we 

calculated. Further, because the Service sometimes included land 

acquisition expenditures in its reported totals and sometimes excluded 

them, we recalculated the totals to consistently include land 

acquisition expenditures. We were thus able to consistently depict 

trends in total expenditures, whether by species, by agency, or by 

year.



We did not verify the accuracy of the expenditures reported by the 

individual agencies or by the Service, but we checked the consistency 

of the information we were given, to the extent possible. We reviewed 

the guidance the Service provides to agencies on the types of 

expenditure data to submit, and we discussed with Service officials the 

criteria and methods by which the expenditure data are reviewed and 

edited. Additionally, we discussed with several agency officials the 

type of expenditure data they submit and the methods by which they 

estimate their expenditures. We adjusted all the expenditures to 

constant 2001 dollars.



Because tortoise-related expenditures were not collected prior to the 

1989 annual report, and because comprehensive and current expenditure 

data were not available for the years since 1998, we requested 

estimates of staff time devoted to the tortoise from the five key 

federal agencies involved in the tortoise’s recovery: the Bureau of 

Land Management, Department of Defense, Fish and Wildlife Service, 

National Park Service, and U.S. Geological Survey. We asked these 

agencies to provide, for each employee who worked on tortoise-related 

activities, the employee’s name, grade level, area of expertise, 

and percent of time devoted to tortoise-related activities during each 

fiscal year from 1980 through 2001. Through discussions with various 

agency officials, we determined that the request was reasonable and 

that the agencies would be able to provide us with fairly reliable 

staff-time estimates by consulting various staff members, personnel 

records, and historical data. Based on these discussions, we provided 

each of the five agencies with instructions, guidance, and examples of 

the information sought. We received staff-time estimates from all but 

two of the pertinent agency offices (e.g., those offices likely to have 

extensive experience and involvement in desert tortoise issues). We did 

not receive estimates from Nellis Air Force Base, Nevada, or the 

Chocolate Mountain Aerial Gunnery Range, California.



To analyze the estimates, we used the Office of Personnel Management’s 

historical salary tables to calculate the salary for each grade level 

in each year. In accordance with guidance contained in Circular A-

76,[Footnote 24] issued by the Office of Management and Budget (OMB), 

we used step 5 of each grade level to calculate salaries, except when 

the agency’s data included the step. For staff that were members of the 

military, we asked the installation to convert the military pay grade 

to the equivalent general schedule grade. Finally, based on A-76 

guidance and our discussions with officials of OMB and MEVATEC 

Corporation (a contractor that advises and assists the Department of 

Defense with A-76 cost comparisons), we determined, for each year, the 

salary percentage that represented the value of the federal benefits 

package (i.e., health insurance, life insurance, pension plans, and 

workman’s compensation). We adjusted the staff-time values to constant 

2001 dollars.



We obtained staff-time estimates from the following federal agencies 

and offices.



* Bureau of Land Management--California Desert District (District 

Office and five field offices: Ridgecrest, Palm Springs, El Centro, 

Barstow, and Needles); Las Vegas Field Office; St. George Field Office; 

Utah State Office; and Cedar City District Office.



* Department of Defense--National Training Center, Fort Irwin; Marine 

Corps Air Ground Combat Center, Twentynine Palms; Edwards Air Force 

Base; and Naval Air Weapons Station, China Lake.



* U.S. Geological Survey--Mid Continent Ecological Science Center, Fort 

Collins; Northern Rocky Mountain Science Center; Western Ecological 

Research Center Field Stations in Las Vegas, Nevada; Riverside, 

California; and St. George, Utah (this field station no longer exists).



* Fish and Wildlife Service--Laguna Niguel/Carlsbad Field Office, 

Ventura Field Office, Barstow Field Office, Salt Lake City Office, 

Phoenix Office, Reno Office, Las Vegas Office, and Portland Regional 

Office.



* National Park Service--Joshua Tree National Park, Mojave National 

Preserve, Lake Mead National Recreation Area, and Zion National Park.



To obtain a perspective on potential economic effects associated with 

the tortoise recovery effort, we reviewed the economic analyses 

contained in various documents, such as the critical habitat 

designation for the tortoise, environmental impact statements prepared 

by federal agencies, and habitat conservation plans. To gauge the 

potential economic effects of grazing restrictions in tortoise habitat, 

we requested that the U.S. Department of Agriculture’s Economic 

Research Service (ERS) calculate county-level economic effects, using a 

recently published analytical method.[Footnote 25] The authors had 

developed this method to estimate both the direct and indirect effects 

of grazing restrictions. Estimates of the direct (ranch-level) effects 

were based on the value of county cattle and sheep sales that would be 

lost if grazing restrictions were imposed. Estimates of the indirect 

(and induced) effects of grazing restrictions were then derived from an 

input-output model, using the estimates of the direct effects. The 

indirect effects include the effects in all industries that supply 

inputs to cattle and sheep producers; the induced effects include 

changes in farm purchases due to changes in farm income.



At our request, the Economic Research Service estimated hypothetical 

10-and 20-percent reductions in grazing owing to restrictions imposed 

to protect the desert tortoise. Such levels of reduction were deemed 

reasonable by the ERS researchers, given that not all land in the 

counties evaluated was federally owned or within critical habitat for 

the tortoise. (These hypothetical reduction levels are similar to those 

used in the authors’ original analysis.) The counties included in the 

study were those with known populations of desert tortoises and those 

with critical habitat for the species. Other counties were also 

included as part of a regional economic analysis. The study included 

Mohave County in Arizona; Kern, Los Angeles, Riverside, San Bernardino, 

and Inyo Counties in California; Clark, Esmeralda, Nye, and Lincoln 

Counties in Nevada; and Washington County in Utah. It relied on data on 

grazing activity from the National Agricultural Statistical Service’s 

Census of Agriculture, the Department of Agriculture’s Forest Service, 

and the Bureau of Land Management. General economic data and regional 

economic data were supplied through IMPLAN--the input-output modeling 

framework, software, and database developed by the authors and 

discussed in the referenced article.



We performed our work from November 2001 through September 2002 in 

accordance with generally accepted government auditing standards.



[End of section]



Appendix III: Comments from the Department of the Interior:



United States Department of the Interior:



OFFICE OF THE SECRETARY Washington, D.C. 20240:



DEC 2 2002:



Mr. Barry T. Hill:



Director, Natural Resources and Environment Team U.S. General 

Accounting Office:



441 G Street, N.W. Washington, D.C. 20548:



Dear Mr. Hill:



Thank you for providing the Department of the Interior the opportunity 

to review and comment on the draft U.S. General Accounting Office 

report entitled, “Endangered Species: Research Strategy and Long-Term 

Monitoring Needed for the Mojave Desert Tortoise Recovery Program,” 

(GAO-03-23) dated October 30, 2002. In general, we agree with the 

findings and the recommendations in the report.



In general, the report appears to be accurate and represents a 

substantial effort on the part of GAO staff involved in the review. The 

report provides a summary of two decades of information on the desert 

tortoise and associated actions undertaken by Federal and State 

agencies and non-governmental organizations to recover the desert 

tortoise. The findings of the report related to the listing of the 

species, the designation of Critical Habitat, and the development of 

the 1994 Recovery Plan support the U.S. Fish and Wildlife Service’s 

conclusion that these actions were based on the best available 

scientific and commercial information at the time.



The enclosure provides specific comments from the U.S. Fish and 

Wildlife Service, Bureau of Land Management, National Park Service, and 

U.S. Geological Survey. We hope our comments will assist you in 

preparing the final report.



Sincerely,



P. Lynn Scarlett Assistant Secretary - Policy, Management and Budget:

Signed by P. Lynn Scarlett:



Enclosure:



[End of section]



Appendix IV: GAO Contact and Staff Acknowledgments:



GAO Contact:



Trish McClure (202) 512-6318:



Acknowledgments:



In addition, Carol Bray, Jennifer Duncan, Kathleen Gilhooly, Tim 

Guinane, Jaelith Hall-Rivera, Cynthia Norris, Judy Pagano, and Pamela 

Tumler made key contributions to this report.



GAO’s Mission:



The General Accounting Office, the investigative arm of Congress, 

exists to support Congress in meeting its constitutional 

responsibilities and to help improve the performance and accountability 

of the federal government for the American people. GAO examines the use 

of public funds; evaluates federal programs and policies; and provides 

analyses, recommendations, and other assistance to help Congress make 

informed oversight, policy, and funding decisions. GAO’s commitment to 

good government is reflected in its core values of accountability, 

integrity, and reliability.

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Of the three areas spanning more than one state, one is in Arizona and 

Nevada, one is in Arizona, Nevada, and Utah, and one is in California 

and Nevada.



FOOTNOTES



[1] All desert tortoises discussed in this report belong to the Mojave 

population. Other desert tortoises found in the United States belong to 

the Sonoran population.



[2] 16 U.S.C. 1531 et seq. Species are designated as endangered or 

threatened, depending on their risk of extinction: an endangered 

species is at risk of extinction in all or a significant portion of its 

range, and a threatened species is likely to become endangered in the 

foreseeable future.



[3] A recovery plan is required unless the Secretary finds that such a 

plan will not promote the conservation of the species.



[4] The act’s protections against take extend to any area where the 

species occurs, not just in its critical habitat.



[5] However, according to a National Park Service official, 3,720 acres 

of critical habitat were originally included in the boundary of Joshua 

Tree National Park, possibly due to a mapping error.



[6] 59 Fed. Reg. 126, p. 34272 (Jul. 1, 1994).



[7] These restrictions are required by a settlement agreement with 

environmental groups that sued BLM because it did not consult with the 

Fish and Wildlife Service about the effects of its land use plans for 

the California Desert on endangered species. The restrictions will 

remain in place until BLM receives a biological opinion from the 

Service on the effects of its California Desert Conservation Area Plan, 

and then finalizes and implements amendments to the plan.



[8] Heaton, J.S., A. Martek, R. Inman, and J. Lesch. 2002. Trends in 

desert tortoise research: DTC Proceedings 1976-2001. Proceedings of the 

2002 Symposium of the Desert Tortoise Council, Palm Springs, 

California.



[9] Boarman, William I., Threats to Desert Tortoise Populations: A 

Critical Review of the Literature. U. S. Geological Survey, Western 

Ecological Research Center. Aug. 9, 2002.



[10] Critical habitat boundaries may be revised at any time if new 

information indicates that changes are warranted.



[11] This annual reporting requirement took effect for expenditures 

made in fiscal year 1989; there is no similar reporting requirement for 

prior years.



[12] As of October 1, 2002, the Service had not issued the fiscal year 

1998 expenditure report, but had provided us with a complete draft.



[13] In most of the 10 years, 11 to 15 federal agencies reported 

tortoise expenditures; state expenditures were reported as one lump 

sum.



[14] The total $3.3 billion in expenditures reported for the fiscal 

period 1989 through 1998 does not include about $907 million of 

expenditures reported by federal agencies and states. Among the 

expenditures the Service excluded from its reports were (1) more than 

$240 million in expenditures that, although made to protect listed 

species, could not be accounted for on a species-by-species basis; (2) 

more than $105 million in expenditures that were for species that were 

not federally listed (e.g., state-listed species), species that were 

not listed until after the end of the fiscal year during which the 

expenditures were made, or species considered in need of protection but 

not federally listed (e.g., sensitive or candidate species); and (3) 

about $561 million in net power purchases or power revenues foregone as 

a result of activities taken to protect threatened and 

endangered species.



[15] Specifically, we received staff time estimates from these 

agencies’ offices located in or near the Mojave desert--Arizona, 

California, Nevada, and Utah. We did not receive estimates from Nellis 

Air Force Base, in Nevada, or the Marine Corps’ Chocolate Mountain 

Aerial Gunnery Range, in California.



[16] To calculate the value of the estimated staff-time investment, we 

identified the historical salary level for each employee for each year, 

added the value of federal benefits that year, multiplied the result by 

the percent of time reported as having been spent on tortoise-related 

activities, and adjusted the value to constant 2001 dollars.



[17] These seven counties are: Mohave County, Arizona; Imperial, 

Riverside, and San Bernardino Counties, California; Clark and Lincoln 

Counties, Nevada; and Washington County, Utah.



[18] Monetary values in this analysis were expressed in constant 1993 

dollars.



[19] Monetary values in this analysis were expressed in constant 1996 

dollars.



[20] The Forest Service found these positive socioeconomic impacts in a 

1996 environmental impact statement.



[21] An animal unit month is defined as the amount of forage needed to 

sustain one cow, one horse, or five sheep for 1 month.



[22] We could not similarly analyze individual states’ expenditures, 

because such information was neither included in the reports nor sought 

by the Service.



[23] Circular A-76 provides guidance on calculating the cost of federal 

personnel. The circular provides the policies and procedures agencies 

are to use in comparing the costs of conducting a function in-house and 

contracting it out.



[24] Lewandrowski, Jan and Kevin Ingram, “Restricting Grazing on 

Federal Lands in the West to Protect Threatened and Endangered Species: 

Ranch and Livestock Sector Impacts,” Review of Agricultural Economics, 

Vol. 24, Number 1, Spring/Summer 2002, pp. 78-107.



[25]



GAO’s Mission:



The General Accounting Office, the investigative arm of Congress, 

exists to support Congress in meeting its constitutional 

responsibilities and to help improve the performance and accountability 

of the federal government for the American people. GAO examines the use 

of public funds; evaluates federal programs and policies; and provides 

analyses, recommendations, and other assistance to help Congress make 

informed oversight, policy, and funding decisions. GAO’s commitment to 

good government is reflected in its core values of accountability, 

integrity, and reliability.



Obtaining Copies of GAO Reports and Testimony:



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expanding archive of older products. The Web site features a search 

engine to help you locate documents using key words and phrases. You 

can print these documents in their entirety, including charts and other 

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Each day, GAO issues a list of newly released reports, testimony, and 

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20548: