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United States Government Accountability Office: 
GAO: 

Report to the Chairman, Committee on Natural Resources, House of 
Representatives: 

December 2010: 

Federal Lands: 

Adopting a Formal, Risk-Based Approach Could Help Land Management 
Agencies Better Manage Their Law Enforcement Resources: 

GAO-11-144: 

GAO Highlights: 

Highlights of GAO-11-144, a report to the Chairman, Committee on 
Natural Resources, House of Representatives. 

Why GAO Did This Study: 

Four federal agencies—the Forest Service in the Department of 
Agriculture and the Bureau of Land Management, Fish and Wildlife 
Service, and National Park Service in the Department of the Interior—
are responsible for managing federal lands, enforcing federal laws 
governing the lands and their resources, and ensuring visitor safety. 
Illegal activities occurring on these lands have raised concerns that 
the four agencies are becoming less able to protect our natural and 
cultural resources and ensure public safety. 

GAO examined (1) the types of illegal activities occurring on federal 
lands and the effects of those activities on natural and cultural 
resources, the public, and agency employees; (2) how the agencies have 
used their law enforcement resources to respond to these illegal 
activities; and (3) how the agencies determine their law enforcement 
resource needs and distribute these resources. GAO reviewed agency 
documents, interviewed agency officials, and visited or contacted 26 
selected agency units. 

What GAO Found: 

A wide variety of illegal activities occurs on federal lands, damaging 
natural and cultural resources and threatening the safety of the 
public and agency employees. These activities can range from traffic 
violations to theft of natural and cultural resources to violent 
crimes. The frequency with which these illegal activities occur is 
unknown, as agency data do not fully capture the occurrence of such 
activities; similarly, the extent of resource damage and threats to 
public and agency employee safety is also unknown. These activities 
can have overlapping effects on natural, cultural, and historical 
resources; public access and safety; and the safety of agency 
employees. For example, illegal hunting results in the loss of 
wildlife and may also reduce opportunities for legal hunting. Also, 
cultivation of marijuana not only increases the availability of 
illegal drugs but fouls ecosystems and can endanger public and agency 
employee safety. And theft or vandalism of archaeological and 
paleontological resources can result in the loss or destruction of 
irreplaceable artifacts, diminishing sites for future visitors and 
depriving scientists of important sources of knowledge. 

In response to illegal activities occurring on federal lands, agencies 
have taken a number of actions. For example, three of the four 
agencies have increased their number of permanent law enforcement 
officers in recent years. The Bureau of Land Management increased its 
number of law enforcement officers by about 40 percent since fiscal 
year 2000, the Forest Service by almost 18 percent during the same 
period, and the Fish and Wildlife Service by about 26 percent since 
fiscal year 2006. The agencies have also directed officers to respond 
specifically to marijuana cultivation and illegal border activities, 
assigned officers temporarily to areas needing a greater law 
enforcement presence during certain events and law enforcement 
operations, and increased the training required for new officers. 

Although land management agencies consider varied information on the 
occurrence and effects of illegal activities on federal lands, the 
agencies do not systematically assess the risks posed by such 
activities when determining their needs for resources and where to 
distribute them. While available information helps the agencies to 
identify many of the risks that illegal activities pose to natural and 
cultural resources, the public, and agency employees, limitations in 
this information do not allow officials to fully assess either the 
magnitude of those risks or the likelihood of their occurrence. As a 
result, the agencies cannot systematically assess the relative risks 
faced by the hundreds of individual land management units across the 
country when making decisions about needed law enforcement resources 
and how to distribute those resources. Without systematic approaches 
to assess the risks they face, the agencies may have limited assurance 
that they are allocating scarce resources in a manner that effectively 
addresses the risk of illegal activities on our nation’s federal lands. 

What GAO Recommends: 

GAO recommends that the agencies adopt a risk management approach to 
systematically assess and address threats and vulnerabilities 
presented by illegal activities on federal lands. In commenting on a 
draft of this report, the Forest Service and Interior concurred with 
GAO’s recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-11-144] or key 
components. For more information, contact Anu K. Mittal at (202) 512-
3841 or mittala@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

A Wide Variety of Illegal Activities Occurs on Federal Lands, Damaging 
Natural and Cultural Resources and Threatening Public and Employee 
Safety: 

Agencies Have Dedicated More Law Enforcement Resources to Responding 
to Illegal Activities on Federal Lands: 

Agencies' Determination of Law Enforcement Resource Needs and 
Distribution Does Not Systematically Assess the Risks Posed by Illegal 
Activities: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Department of Agriculture, Forest 
Service: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Numbers of Permanent Law Enforcement Officers, by Land 
Management Agency, Fiscal Years 2000 through 2009: 

Table 2: Bureau of Land Management, Fish and Wildlife Service, Forest 
Service, and National Park Service Field Units Visited or Contacted, 
by Location: 

Figures: 

Figure 1: Federal Lands Managed by the Forest Service, Bureau of Land 
Management, Fish and Wildlife Service, and National Park Service: 

Figure 2: OHV-Related Damage at Sonoran Desert National Monument: 

Figure 3: Scarring Created by Boat Propellers in Florida Bay, 
Everglades National Park: 

Figure 4: Civil War Artifacts Stolen from Fredericksburg and 
Spotsylvania National Military Park: 

Figure 5: Damage Caused by Marijuana Cultivation: 

Figure 6: Vegetation and Soil Damage and Garbage Resulting from 
Illegal Border Activity: 

Abbreviations: 

OHV: off-highway vehicle: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

December 17, 2010: 

The Honorable Nick J. Rahall, II: 
Chairman: 
Committee on Natural Resources: 
House of Representatives: 

Dear Mr. Chairman: 

Our nation has set aside millions of acres as national forests, 
wildlife refuges, national parks, and other federal lands to provide 
and protect important natural resources, preserve our historical and 
cultural heritage, and offer recreational opportunities. Four federal 
land management agencies--the Forest Service in the Department of 
Agriculture and the Bureau of Land Management, Fish and Wildlife 
Service, and National Park Service in the Department of the Interior-- 
are responsible for managing these federal lands; enforcing federal 
laws governing the lands and their resources; and, often in 
conjunction with other federal, state, and local law enforcement 
agencies, ensuring visitor safety. The agencies' law enforcement 
programs together employ more than 3,000 uniformed law enforcement 
officers and investigative special agents to respond to and 
investigate illegal activities occurring on lands managed by the 
agencies. In recent years, an increase in certain high-profile illegal 
activities on federal lands, such as marijuana cultivation and 
smuggling of drugs and people into the United States, has raised 
concerns that the land management agencies are becoming less able to 
protect our nation's natural and cultural resources and ensure public 
safety. 

To better understand the effects of illegal activities occurring on 
federal lands and how land management agencies have responded to these 
activities, you asked us to review the law enforcement programs at the 
four federal land management agencies. Accordingly, this report 
examines (1) the types of illegal activities occurring on federal 
lands and the effects of those activities on natural and cultural 
resources, the public, and agency employees; (2) how the agencies have 
used their law enforcement resources to respond to these illegal 
activities; and (3) how the agencies determine their law enforcement 
resource needs and distribute these resources. 

To determine the types and effects of illegal activities occurring on 
federal lands, we reviewed documents and interviewed law enforcement 
officials from the land management agencies' headquarters and regional 
or state offices.[Footnote 1] We also collected and analyzed agency 
data on the recorded frequency and effects of different types of 
illegal activities. In addition, to determine the occurrence of 
different types of illegal activities in different areas of the 
country, we interviewed agency law enforcement officials at 
headquarters and in each regional or state office, using a 
standardized set of questions. To observe the effects of illegal 
activities, and to better understand any regional or agency variation 
in the occurrence and effects of different types of illegal 
activities, we visited or contacted 26 selected agency units in eight 
geographic areas throughout the United States.[Footnote 2] Units were 
selected on the basis of our interviews with regional and state office 
officials and to include a range of the types of illegal activities 
occurring on federal lands. Although the information we obtained is 
not generalizable to all federal lands, it represents a broad spectrum 
of the types and effects of illegal activities the agencies have 
identified as occurring on federal lands. To determine how the 
agencies have used law enforcement resources to respond to different 
types of illegal activities, we analyzed agency law enforcement 
staffing data to identify overall staffing trends, reviewed funding 
and direction provided in various laws and accompanying congressional 
committee reports, reviewed agency documents, and interviewed 
officials in headquarters and selected field locations. We assessed 
the reliability of each agency's staffing data and found them to be 
sufficiently reliable for purposes of our report. We also reviewed 
agency documentation on training requirements for law enforcement 
officers and interviewed headquarters and selected field officials to 
obtain their perspectives on the sufficiency of training in preparing 
law enforcement officers to respond effectively and safely to illegal 
activities. To determine how land management agencies identify their 
law enforcement resource needs and distribute those resources, we 
asked agency law enforcement officials at headquarters and at selected 
regional or state offices to identify the information they consider 
and the processes they use to make law enforcement staffing decisions. 
To identify federal requirements and best practices for incorporating 
risk management into agency decision making, we reviewed relevant 
guidance, including federal standards for internal control.[Footnote 
3] To evaluate the extent to which the agencies met risk management 
requirements and incorporated best practices, we reviewed examples of 
the types of information officials consider in making resource 
decisions. Appendix I describes our scope and methodology in more 
detail, including the locations of the agency units we contacted. 

We conducted this performance audit from July 2009 through December 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

The Forest Service, Bureau of Land Management, Fish and Wildlife 
Service, and National Park Service manage more than 670 million acres 
of federal lands across the country (see figure 1). Each agency has a 
unique mission, focused on priorities that shape how it manages these 
lands. Specifically: 

* The Forest Service manages land for multiple uses, including timber, 
recreation, and watershed management and to sustain the health, 
diversity, and productivity of the nation's forests and grasslands to 
meet the needs of present and future generations. The Forest Service 
manages lands under its jurisdiction through nine regional offices and 
155 national forests and 20 grasslands. 

* The Bureau of Land Management also manages land for multiple uses, 
including recreation; range; timber; minerals; watershed; wildlife and 
fish; natural scenic, scientific, and historical values; and the 
sustained yield of renewable resources. The agency manages public 
lands under its jurisdiction through 12 state offices; each state 
office has several subsidiary district and field offices. 

* The Fish and Wildlife Service manages the National Wildlife Refuge 
System, a network of lands and waters that provides for the 
conservation of fish, wildlife, and plants and their habitats, as well 
as opportunities for wildlife-dependent recreation, including hunting, 
fishing, and wildlife observation. The refuge system includes about 
585 refuges. Individual refuges known as stand-alone refuges report 
directly to one of eight regional offices, or refuges may be grouped 
with others into a complex under a common manager, who in turn reports 
to a regional office. 

* The National Park Service manages the 393 units of the National Park 
System to conserve the scenery, natural and historic objects, and 
wildlife of the system so that they will remain unimpaired for the 
enjoyment of this and future generations. Individual park units have 
varied designations corresponding to the natural or cultural features 
they are to conserve, including national parks, monuments, lakeshores, 
seashores, recreation areas, preserves, and historic sites. The agency 
has established seven regional offices. 

Figure 1: Federal Lands Managed by the Forest Service, Bureau of Land 
Management, Fish and Wildlife Service, and National Park Service: 

[Refer to PDF for image: illustrated U.S. map] 

The map depicts lands managed by the following agencies: 
Bureau of Land Management; 
Forest Service; 
Fish and Wildlife Service; 
National Park Service. 

Source: GAO analysis of U.S Geological Survey’s National Atlas Web 
site data. 

[End of figure] 

To respond to and investigate illegal activities occurring on the 
lands they manage, the agencies employ uniformed law enforcement 
officers who patrol federal lands, respond to illegal activities, and 
conduct routine investigations. In addition, the agencies have 
investigative special agents who investigate serious crimes in more 
detail. In this report we use the term "law enforcement officer" to 
include both uniformed law enforcement officers and investigative 
special agents, unless noted otherwise. In each of the four agencies, 
different officials make decisions about law enforcement resource 
needs. The Forest Service's law enforcement and investigations program 
is "straightlined," meaning that law enforcement officers in the field 
report to law enforcement officials at a regional office, who in turn 
report to law enforcement officials at agency headquarters in 
Washington, D.C. The Forest Service has a budget line item for law 
enforcement, and within budget constraints, its Director of Law 
Enforcement and Investigations has authority to make decisions about 
the number of uniformed officers and investigative agents to employ 
and where to assign them. In contrast, for the three Interior 
agencies, law enforcement officials and unit or regional land managers 
share decision-making authority for the law enforcement programs: in 
general, law enforcement officials make decisions about the number and 
location of agents, while land managers--such as a Bureau of Land 
Management state director, a refuge manager, or a park superintendent--
make decisions about uniformed officers for their specific land units. 
Land managers determine how much of their overall budget they want to 
allocate to law enforcement activities. This budget must cover each 
unit's expenditures for law enforcement, maintenance, visitor 
services, resource management, and other operations. 

State and local law enforcement agencies, as well as other federal 
agencies, may also play a role in responding to illegal activities 
occurring on lands managed by the four land management agencies. For 
example, on some federal lands, state and local law enforcement 
officers have sole responsibility for responding to certain crimes, 
such as violent crimes, and on other federal lands, the responsibility 
for responding to most crimes is shared among federal, state, and 
local law enforcement officers.[Footnote 4] In some locations, state 
and local law enforcement agencies have entered into agreements 
allowing federal land management agencies' law enforcement officers to 
act as state and local law enforcement officers on federal lands. 
Specifically, such agreements may allow the land management agencies' 
law enforcement officers to enforce state laws, such as traffic laws. 
Other agreements may allow local law enforcement officers to enforce 
certain federal laws and regulations, such as fishing and hunting 
restrictions, on federal lands. And other federal agencies also 
enforce laws and respond to illegal activities on federal lands. For 
example, Border Patrol--an office within the Department of Homeland 
Security--is responsible for controlling and guarding the borders of 
the United States against the illegal entry and smuggling of people, 
drugs, or other contraband, and the Drug Enforcement Administration in 
the Department of Justice enforces federal laws regarding controlled 
substances. 

A Wide Variety of Illegal Activities Occurs on Federal Lands, Damaging 
Natural and Cultural Resources and Threatening Public and Employee 
Safety: 

As in America's cities, suburbs, and rural areas, a wide variety of 
illegal activities occurs on federal lands around the nation, damaging 
natural and cultural resources and threatening the safety of the 
public and agency employees. But it is unknown how often these illegal 
activities occur because agency data do not fully capture the 
occurrence and magnitude of such activities; similarly, the extent of 
resource damage and threats to public and agency employee safety is 
also unknown. Although agency data are insufficient to quantify the 
extent of illegal activities or their effects, the data identify a 
variety of illegal activities occurring on federal lands, ranging from 
traffic violations to theft of natural and cultural resources to 
violent crimes. These activities may have overlapping effects on 
natural, cultural, and historical resources; public access and safety; 
and the safety of agency employees. 

The Full Extent and Effects of Illegal Activities Occurring on Federal 
Lands Are Unknown: 

Available information does not allow land management agencies to fully 
identify either the occurrence of illegal activities on federal lands 
or the effects of those activities on resources, the public, and 
agency employees. The agencies maintain data on law enforcement 
incidents, including information such as the type of crime, 
characteristics of victims and offenders, and types and value of 
resources or property damaged or stolen.[Footnote 5] These data, 
however, cannot be used to monitor trends in the occurrence of illegal 
activities on federal lands. Agency law enforcement officials told us 
that an inherent limitation in using these data to assess trends is 
that a change from one time period to another more likely reflects a 
change in law enforcement staffing levels or an agency's emphasis on 
responding to particular types of crime than an actual change in the 
occurrence of crimes committed. For example, Bureau of Land Management 
officials told us that the lands they manage in southwestern Colorado 
are infrequently patrolled by law enforcement personnel and that if 
the agency increased the number of officers patrolling the area, the 
number of reported incidents would be likely to increase as well. 
According to these officials, the increase would most likely be due 
not to an actual rise in crime but simply to a rise in reported 
incidents because of the increased law enforcement presence. Moreover, 
for some illegal activities, such as violent crimes, state and local 
law enforcement agencies may have primary responsibility for 
responding even if the illegal activity occurs on federal lands, and 
the land management agencies may have no record that a crime occurred. 

Compounding these inherent shortcomings in incident data, two 
agencies--the National Park Service and the Fish and Wildlife Service--
do not consistently collect or systematically maintain such data. 
Specifically, law enforcement officials said, of the National Park 
Service's 393 units, about 100 units have adopted standardized 
incident-reporting systems, while the rest rely on ad hoc systems that 
the units have developed themselves. Similarly, although the Fish and 
Wildlife Service has developed an incident management system, 
according to the official responsible for managing law enforcement 
data, the agency does not require refuges to use it, and many refuges 
continue to use either a legacy data system or paper records to 
maintain incident data. As a result, National Park Service and Fish 
and Wildlife Service officials said, it is difficult for them to track 
regional or national trends in illegal activities. 

To help remedy these shortcomings in incident data, Interior, in 
conjunction with its component agencies, is developing a new law 
enforcement data system, in part to respond to a 2002 report from its 
Office of Inspector General, which recommended that Interior develop a 
departmentwide law enforcement data system.[Footnote 6] The system, 
known as the Incident Management Analysis and Reporting System, is 
being designed to improve the agencies' ability to analyze incident 
data to identify trends in occurrence of illegal activities--for 
example, by ensuring that senior agency officials have access to 
similar information for all units across the country and by allowing 
officials to analyze incidents across agency boundaries. In addition, 
the system will be compatible with geographic information systems, 
giving law enforcement officials the ability to analyze geographic 
trends in illegal activities. When complete, the system has the 
potential to provide better information on the types of illegal 
activities occurring at different Interior units across the country. 
According to Interior's program manager, the agencies began field- 
testing the new system in November 2010 and expect to deploy it fully 
by the end of 2012. 

Like the extent of illegal activities occurring on federal lands, the 
effects of such illegal activities on resources, the public, and 
agency employees are also not fully known. Agency law enforcement 
officials reported that their agencies do not systematically collect 
information on the effects of illegal activities, except in certain 
cases--for example, when needed as evidence in criminal 
investigations. At units we visited, for example, officials said they 
had documented damage to specific locations resulting from illegal 
activities, such as dumping of trash and hazardous materials, 
marijuana cultivation, timber theft, and unauthorized off-highway 
vehicle (OHV) use. Senior agency law enforcement officials said that 
while available information--such as quantities of trash dumped or 
acres of vegetation damaged to cultivate marijuana--helps them 
understand the effects of illegal activities on resources at specific 
locations, they did not believe it is feasible to quantify the effects 
of all illegal activities across the country. 

Agencies Have Identified a Wide Range of Illegal Activities and 
Impacts on Federal Lands: 

Although the four land management agencies did not have comprehensive 
information to determine the level of and trends in illegal activities 
occurring on the federal lands they manage, law enforcement officials 
and land managers we interviewed at 26 geographically dispersed agency 
units identified a variety of illegal activities that have occurred on 
their units. These officials also identified a variety of impacts that 
these activities can have on natural and cultural resources and public 
and employee safety. These illegal activities, described below, can be 
grouped into eight categories--roughly in order of severity--from 
least severe, such as traffic violations, to most severe, such as 
violent crimes. 

Traffic Violations: 

Agency law enforcement officials at several units we visited 
identified speeding, reckless driving, driving under the influence, 
and other traffic violations as a set of illegal activities that they 
encounter frequently on public lands. According to these officials, 
traffic violations on federal lands pose safety risks to park visitors 
and wildlife. For example, the Chief Ranger at Great Smoky Mountains 
National Park (located along the North Carolina-Tennessee border) 
estimated that park law enforcement officers spend about 70 to 80 
percent of their time enforcing traffic laws. He said that about 300 
accidents happen each year in the park and that park law enforcement 
officers arrest about 40 to 50 people annually for driving under the 
influence. Officials at several units also told us that the need to 
patrol roads may sometimes hinder their ability to protect important 
resources on their units. For example, the chief rangers for Great 
Smoky Mountains and Cumberland Gap[Footnote 7] national parks said 
that enforcing traffic laws left little time for law enforcement 
officers to patrol those parks' backcountry areas--areas that are home 
to important plant and animal species. 

Public Intoxication and Possession or Use of Illegal Drugs: 

Agency law enforcement officials told us that the presence of 
individuals on federal lands who are publicly intoxicated or who 
possess or are under the influence of illegal drugs is another kind of 
illegal activity that they encounter frequently on their units. This 
activity threatens the safety of other visitors, as well as law 
enforcement officers. The officials told us that when an area on 
federal land develops a reputation as a place where people drink or 
use illegal drugs, the general public sometimes avoids these areas. 
For example, officials at the Cherokee National Forest in Tennessee 
said that several of the national forest's campgrounds had developed 
such reputations. They said that in an effort to reduce problems 
related to alcohol and drug use and to increase public confidence in 
the safety of being in the forest, they added law enforcement patrols 
and prohibited alcohol use in certain campgrounds--efforts they 
believed had been successful. 

Unauthorized Use of Vehicles for Recreation: 

The unauthorized use of recreational vehicles, such as bicycles, 
boats, OHVs, and snowmobiles, is another type of illegal activity that 
occurs at many of the federal land units we visited. Law enforcement 
officials noted that when agency regulations and policies governing 
the use of such vehicles are violated, damage to natural or cultural 
resources and conflicts with other members of the public may arise. 
Agency officials at many units we visited reported that unauthorized 
use of OHVs was harming resources by causing soil erosion; damaging 
vegetation, including in streamside areas; fragmenting wildlife 
habitat; and damaging archaeological or historical sites. For example, 
soil and vegetation damage from unauthorized OHV use at Sonoran Desert 
National Monument in Arizona was severe enough that in 2007 the Bureau 
of Land Management closed about 55,000 acres of the monument to all 
motorized vehicles (see figure 2). 

Figure 2: OHV-Related Damage at Sonoran Desert National Monument: 

[Refer to PDF for image: 2 photographs] 

Source: Bureau of Land Management. 

[End of figure] 

Unauthorized use of boats and snowmobiles can also damage resources 
and create public conflicts, according to officials at other units we 
visited. For example, Merritt Island National Wildlife Refuge in 
Florida has established "manatee zones"--prohibiting motorized boat 
traffic in some manatee zones and imposing speed limits in others--in 
an effort to reduce collisions between boats and manatees.[Footnote 8] 
Although manatee zones have helped reduce collisions, according to 
refuge officials, some boaters enter closed areas or exceed speed 
limits, and collisions still occur. Similarly, at Everglades National 
Park in Florida, officials reported damage to seagrass in Florida Bay 
from unauthorized boat traffic. The officials said that motorized 
boats are allowed in Florida Bay but are prohibited from touching the 
seafloor bottom, which is designated as wilderness.[Footnote 9] Much 
of Florida Bay, however, is less than 2 feet deep, and boats can run 
aground, or propellers can scrape seagrass growing on the bay floor, 
causing damage known as "prop scars" (see figure 3). In addition, 
officials at the Superior National Forest in Minnesota said that 
unauthorized use of motorized boats and snowmobiles in closed areas 
diminishes the wilderness experience for visitors to the Boundary 
Waters Canoe Area, the nation's most visited wilderness area. 

Figure 3: Scarring Created by Boat Propellers in Florida Bay, 
Everglades National Park: 

[Refer to PDF for image: photograph] 

Source: National Park Service. 

[End of figure] 

Unauthorized Construction, Waste Disposal, Trespass, and Commercial 
Activity: 

Officials at many units we visited also reported that people use 
federal lands for a broad range of other unauthorized purposes. For 
example, landowners whose property borders federal lands have 
constructed access roads; outbuildings; and, in some cases, houses on 
federal lands. In addition, hunters have built unauthorized platforms 
or shelters in trees to hunt from, and these structures are often 
accompanied by a network of OHV trails, cutting of vegetation to 
improve sightlines, and garbage. Other officials noted that their 
lands are often used for illegal dumping of household and commercial 
waste--including toxic or otherwise dangerous waste. According to 
these officials, such illegal activities can harm ecosystems, damage 
vegetation, reduce wildlife habitat, introduce dangerous materials 
into the environment, diminish public safety, and have other negative 
effects on natural resources and the public. For example, Sonoran 
Desert National Monument officials reported that dumping cases have 
included several dump-truck-loads of tires, more than 500 gallons of 
motor oil, and cyanide and explosives from mining operations. 

Several units we visited also reported problems with people staying in 
an area longer than permissible, known as illegal occupancy. In some 
cases, the people were in essence living on federal lands. Illegal 
occupancy can damage vegetation, generate garbage and human waste, 
affect wildlife behavior, and curtail public access to federal lands, 
according to agency officials. Some officials also said that some of 
the violators pose threats to the public. In Florida, for example, 
Ocala National Forest officials estimated that several hundred people 
lived illegally in the forest in 2006 and that these people committed 
other crimes, including illegal drug use, assault, and rape. 
Subsequently, forest officials initiated a "Reshaping the Ocala" 
campaign intended to deter such crimes. Officials said they increased 
law enforcement staff, strengthened length-of-stay orders to make them 
easier to enforce, and raised fines--efforts they say have reduced the 
effect of these types of illegal activities. 

Several units also reported problems with unauthorized commercial 
activities--such as guided hunting, rafting, and sightseeing trips--on 
federal lands. Officials said that commercial activities conducted 
without permits can take customers away from authorized businesses; 
detract from the experience of customers using authorized guides; and 
may pose safety risks to the public, since guides operating illegally 
may not take safety precautions or have the insurance an agency may 
require of operators. Moreover, since the number of permits an agency 
issues may be based on an assessment of cumulative effects on natural 
resources (e.g., permitting a certain number of commercial hunting 
guides to operate in an area on the basis of predicted effects on 
wildlife), unauthorized guides can increase pressure on those 
resources. 

Theft of or Damage to Natural and Cultural Resources and Government 
and Private Property: 

Officials at many of the sites we visited reported that natural and 
cultural resources and government and personal property on federal 
lands have been stolen or damaged by illegal activities. Such theft or 
damage not only harms the resources--including rare species and 
species of commercial value--but also adds costs to the agencies and 
the public and diminishes the public's enjoyment of federal lands, 
according to these officials. In addition, theft or vandalism of 
archaeological and paleontological resources can lead to the loss or 
destruction of irreplaceable artifacts and deprive scientists of 
important sources of knowledge. Some examples of these kinds of 
illegal activities include the following: 

* Timber theft occurs on federal lands when a business cuts more trees 
than allowed under its contract with an agency or when neighboring 
landowners illegally remove trees from federal lands. In addition, 
individual trees with high commercial value may also be stolen from 
federal lands. For example, a law enforcement officer responsible for 
several national forests in Washington said that large cedar and 
bigleaf maple trees, often hundreds of years old, are stolen from the 
national forests. She estimated that a single bigleaf maple tree could 
be sold for about $20,000 because the wood is highly valued for making 
musical instruments. 

* Theft of other forest products, including medicinal plants such as 
ginseng, mushrooms, ornamental landscaping plants, and greenery for 
floral arrangements, also occurs on federal lands. For example, 
officials at Cumberland Gap and Great Smoky Mountains national parks 
and the Cherokee National Forest said that while they do not know 
exactly how often ginseng theft occurs because these thefts are 
difficult to identify, they believe it occurs frequently. One official 
said he was concerned that such thefts could substantially reduce 
ginseng populations on federal lands,[Footnote 10] which could in turn 
lead to listing of the plant as threatened or endangered under the 
Endangered Species Act. 

* Illegal hunting of bear, elk, waterfowl, and other wildlife and 
illegal fishing are common on federal lands. Hunting and fishing 
restrictions are typically designed to achieve desired population 
levels of the animals, and illegal hunting and fishing can reduce the 
population below desired levels. It can also decrease the likelihood 
of success for people who are hunting or fishing legally and, in some 
cases, can result in the closure of an area. Everglades National Park 
officials, for example, told us that they closed part of the park to 
all public access because of illegal hunting of American crocodiles, 
designated as threatened in Florida under the Endangered Species Act, 
and officials at the Cherokee National Forest said that the state of 
Tennessee has closed several areas in the forest to hunting to make it 
harder to illegally hunt black bears. 

* Archaeological artifacts have been stolen and sites vandalized on 
federal lands. Officials admitted that they do not know the extent of 
the problem, in part because many archaeological sites are 
undocumented and others are in remote areas where monitoring is 
difficult. In some cases, the damage from any one incident may be 
small, but officials said that the cumulative effect can diminish the 
site for future visitors and sometimes compromise scientific 
understanding. In addition, officials identified theft of significant 
artifacts, including the systematic looting of archaeological sites, 
as an important concern. For example, Bureau of Land Management 
officials reported that a 2009 investigation into the theft and 
trafficking of more than 250 Indian artifacts, valued at more than 
$330,000, from tribal and federal lands in the Southwest--the largest 
such case in the United States--led to the indictment of 28 people and 
nine felony convictions as of October 2010 and that additional 
indictments are expected. Some of the artifacts stolen, and later 
recovered by law enforcement officers during this investigation, 
included burial and ceremonial masks, pottery, and a buffalo 
headdress. Archaeological sites can also be vandalized: for example, 
several Indian pictographs have been vandalized at Arches and 
Canyonlands national parks in Utah. 

* Historical artifacts have also been stolen or damaged on federal 
lands. Theft of Civil War artifacts is a major concern at 
Fredericksburg and Spotsylvania National Military Park in Virginia, 
according to agency officials. About 200 artifacts were stolen in 
2007, for example, causing an estimated $57,000 in damaged or lost 
resources (see figure 4). Moreover, officials said that historical 
resources such as Civil War earthworks or trenches have been damaged 
by unauthorized activities, including climbing or walking on them, 
riding on or over them with bicycles and OHVs, and unauthorized 
development on adjacent properties. 

Figure 4: Civil War Artifacts Stolen from Fredericksburg and 
Spotsylvania National Military Park: 

[Refer to PDF for image: 2 photographs] 

Source: National Park Service. 

[End of figure] 

* Officials at the Fish and Wildlife Service's Detroit Lakes Wetland 
Management District in Minnesota reported that some property owners 
violate the conditions of minimally restrictive easements purchased by 
the federal government to protect wetlands and grasslands--actions 
that hinder the agency's efforts to protect breeding habitat for more 
than 60 percent of key migratory bird species in the United States. 
[Footnote 11] These easements are managed by the Fish and Wildlife 
Service to provide habitat for migratory birds, particularly 
waterfowl, in the Prairie Pothole Region of the north-central United 
States.[Footnote 12] Fish and Wildlife Service officials reported that 
some property owners have drained protected wetlands to expand their 
land under cultivation or have grazed livestock on protected 
grasslands during migratory birds' nesting periods. 

* Government and private property can be stolen or damaged on federal 
lands. Theft or damage of government property, such as equipment, road 
signs, gates, and structures, can result in costs to the agencies and 
detract from the public's experience, for example, when restrooms or 
information kiosks are vandalized. Similarly, theft or damage of 
private property--for example, when valuables are stolen from parked 
vehicles--can impose costs on the visiting public. 

Marijuana Cultivation: 

According to officials at several federal land units we visited and 
National Drug Intelligence Center reports, marijuana is increasingly 
grown on federal lands.[Footnote 13] Law enforcement officials told us 
that although most such marijuana cultivation has historically 
occurred on the West Coast, intensive cultivation--in many cases by 
large-scale international drug-trafficking organizations--has spread 
to other regions of the country in recent years. The National Drug 
Intelligence Center reported that more than 4 million plants were 
eradicated from federal lands in 2008--about half of all outdoor-grown 
marijuana eradicated in the United States. 

Marijuana cultivation on federal lands not only increases the 
availability of illegal drugs but also harms ecosystems, according to 
the federal land managers we spoke with. Specifically, these officials 
identified the following resource impacts of marijuana cultivation on 
federal lands: 

* removal of natural vegetation and the application of pesticides, 
herbicides, fertilizers, and other chemicals, including chemicals that 
may be banned in the United States; 

* diversion of water from streams, which has reduced downstream 
waterflows and has harmed fish and amphibians; 

* killing of wildlife, including bear and deer, to keep the animals 
from eating or trampling marijuana plants or to supplement growers' 
food stocks; 

* deposits of large amounts of trash and human waste; and: 

* setting of wildland fires, either intentionally or accidentally, 
which have also degraded the natural resources on federal lands. 

Cleaning up cultivation sites is important, not only to restore 
damaged areas, but also to make it less likely that growers will 
return, agency officials told us. In 2008, the National Park Service 
restored 14 marijuana cultivation sites in its Pacific West Region. To 
clean up these sites, the National Park Service removed more than 10 
miles of irrigation hose, about 10,000 pounds of trash, and more than 
3,700 pounds of fertilizer, as well as pounds of hazardous chemicals 
such as pesticides (see figure 5). Cleaning up marijuana cultivation 
sites costs an estimated $10,000 to $15,000 an acre and reduces the 
agencies' ability to accomplish other planned work, according to 
agency officials. 

Figure 5: Damage Caused by Marijuana Cultivation: 

[Refer to PDF for image: 2 photographs] 

Source: National Park Service. 

[End of figure] 

Moreover, marijuana growers are typically armed, posing a threat to 
public safety and agency employees, according to agency law 
enforcement officials. Hunters, hikers, and other members of the 
public, as well as agency employees, have been shot, shot at, 
kidnapped, and threatened with violence. Although such violent 
encounters are rare, law enforcement officials at several units we 
visited said that marijuana growers have become more violent in recent 
years. Law enforcement officials also said that the public is 
increasingly aware of the danger and that some people avoid areas 
where marijuana cultivation is likely. In some areas, the threat posed 
by marijuana growers has also affected the agencies' ability to work 
in remote areas. A regional Forest Service law enforcement official in 
California told us that the agency had to remove three crews of 
wildland firefighters during an 8-week period in 2009 because of 
encounters with marijuana growers. 

Illegal Border Activity: 

Law enforcement officials told us that some remote federal lands along 
the U.S. border are often used to smuggle drugs or humans into the 
country. According to these officials, such illegal activities can 
damage sensitive wildlife habitat and threaten public safety.[Footnote 
14] Officials at every unit we visited in Arizona reported substantial 
natural resource damage from illegal border activity (see figure 6). 
[Footnote 15] In 2006, for example, the Refuge Manager of Buenos Aires 
National Wildlife Refuge testified before the House of 
Representative's Subcommittee on Interior, Environment, and Related 
Agencies of the Committee on Appropriations that an estimated 235,000 
people entered the United States illegally across refuge lands in 
2005. He reported that illegal border crossers had disturbed wildlife 
and created more than 1,300 miles of illegal trails, causing the loss 
of vegetation and severe erosion. He also estimated that each year 
illegal border crossers leave more than 500 tons of trash and more 
than 100 abandoned vehicles on the refuge. Further, officials at 
several units we visited reported that illegal border crossers have 
started wildland fires, either by accident (e.g., from a cooking fire 
that escaped) or on purpose (e.g., to divert law enforcement resources 
away from certain areas). Officials at Buenos Aires National Wildlife 
Refuge told us that illegal border activity was damaging sensitive 
desert ecosystems--including habitat for several threatened or 
endangered species, such as the masked bobwhite quail and Sonoran 
pronghorn--although the officials were unable to quantify the effects 
of illegal activity on these populations. 

Figure 6: Vegetation and Soil Damage and Garbage Resulting from 
Illegal Border Activity: 

[Refer to PDF for image: 2 photographs] 

Source: Forest Service. 

[End of figure] 

Illegal border activities also affect the safety of the public and 
agency employees. For example, officials at the three units we visited 
in Arizona--Buenos Aires National Wildlife Refuge, Coronado National 
Forest, and Sonoran Desert National Monument--observed that smugglers 
are often armed and pose a risk to public and employee safety. The 
officials said that, while few violent encounters between smugglers 
and the public have occurred to date, many illegal immigrants or 
smugglers have been murdered or raped on federal lands. Officials also 
reported that illegal border crossers have stolen vehicles (both 
private and government owned), broken into agency employee housing, 
and stolen food and water. Officials also said that visitors to 
federal lands in these areas are concerned about their safety and that 
some visitors have said they no longer go to certain areas because of 
the illegal activities. In some cases, the agencies have determined 
that the risk to public safety is high enough to warrant closing areas 
to public use. Buenos Aires National Wildlife Refuge, for example, has 
closed a portion of the refuge adjacent to the border to reduce the 
risk to the public. Similarly, the National Park Service closed most 
of Organ Pipe Cactus National Monument, a popular location for bird-
watching, after a park law enforcement officer was murdered in 2002 by 
a member of a drug-trafficking organization. 

Violent Crimes: 

According to law enforcement officials at the units we visited, the 
public and agency employees can also be the victims of violence, 
including assault, rape, and homicide, on federal lands. Although land 
management officials stressed that this kind of violence remains rare, 
several units we visited reported some violent incidents. For example, 
Ocala National Forest officials reported that two college students 
were murdered in the forest in 2006. Similarly, Bureau of Land 
Management officials in California reported examples of violence, 
including rape and severe assaults, in the Imperial Sand Dunes 
Recreation Area--a popular OHV location that can attract 150,000 or 
more people on holiday weekends. Agency employees, including law 
enforcement officers, may also fall victim to violence. For example, a 
Forest Service law enforcement officer in Washington was murdered 
during a traffic stop in 2008. Beyond the immediate impact on victims, 
some officials told us, such violent crimes also have an effect on the 
public because after such incidents happen, the public is more likely 
to avoid areas they suspect may be prone to violence. 

Agencies Have Dedicated More Law Enforcement Resources to Responding 
to Illegal Activities on Federal Lands: 

In recent years, federal land management agencies have responded to 
illegal activities occurring on federal lands in several ways. They 
have generally increased the number of law enforcement officers, 
directed officers to respond to marijuana cultivation and illegal 
border activities, assigned officers temporarily to areas needing a 
greater law enforcement presence, and increased the training required 
for new law enforcement officers. 

Three of the Four Agencies Have Increased Their Law Enforcement 
Presence to Respond to Illegal Activities Occurring on the Lands They 
Manage: 

In response to illegal activities occurring on federal lands, three of 
the four agencies have increased the number of their permanent law 
enforcement officers in recent years (see table 1). For example, the 
Bureau of Land Management has increased the number of its permanent 
law enforcement officers by about 40 percent since fiscal year 2000, 
and the Forest Service increased the number of its officers by almost 
18 percent over the same period. Similarly, since fiscal year 2006, 
the Fish and Wildlife Service increased by about 26 percent the number 
of its permanent officers performing law enforcement duties on a full-
time basis.[Footnote 16] The National Park Service, in contrast, 
decreased its permanent law enforcement officers by more than 12 
percent since fiscal year 2005, although the agency partially 
compensated for this loss by increasing the number of law enforcement 
officers it hired on a seasonal, rather than permanent, basis. 

Table 1: Numbers of Permanent Law Enforcement Officers, by Land 
Management Agency, Fiscal Years 2000 through 2009: 

Agency: Forest Service; 
2000: 630; 
2001: 680; 
2002: 660; 
2003: 697; 
2004: 692; 
2005: 663; 
2006: 627; 
2007: 687; 
2008: 751; 
2009: 742; 
Percentage change: 17.78%. 

Agency: Bureau of Land Management; 
2000: 213; 
2001: 228; 
2002: 251; 
2003: 267; 
2004: 264; 
2005: 260; 
2006: 267; 
2007: 260; 
2008: 279; 
2009: 300; 
Percentage change: 40.85%. 

Agency: Fish and Wildlife Service[A,B]; 
2000: [Empty]; 
2001: [Empty]; 
2002: [Empty]; 
2003: [Empty]; 
2004: [Empty]; 
2005: [Empty]; 
2006: 217; 
2007: 234; 
2008: 254; 
2009: 273; 
Percentage change: 25.81%. 

Agency: National Park Service[A,C]; 
2000: [Empty]; 
2001: [Empty]; 
2002: [Empty]; 
2003: [Empty]; 
2004: [Empty]; 
2005: 1,658; 
2006: 1,555; 
2007: 1,470; 
2008: 1,418; 
2009: 1,450; 
Percentage change: -12.55%. 

Source: GAO analysis of agency data. 

Note: Numbers represent permanent law enforcement staff, including law 
enforcement officers and investigative special agents, as of August or 
September of each fiscal year. 

[A] The Fish and Wildlife Service and National Park Service were 
unable to provide sufficiently reliable data for fiscal years 2000 
through 2005 and 2000 through 2004, respectively. 

[B] Numbers for the Fish and Wildlife Service exclude permanent 
officers who perform predominantly non-law enforcement duties, as well 
as investigative special agents because Fish and Wildlife Service 
investigative special agents investigate primarily illegal activities--
such as violations of the Endangered Species Act or Migratory Bird 
Treaty Act--occurring primarily on nonfederal lands. 

[C] Numbers for the National Park Service exclude the United States 
Park Police, which was outside the scope of our review. 

[End of table] 

At the Fish and Wildlife Service, however, the potential benefits of 
the overall increase in the number of law enforcement officers may 
have been partially offset: Although the Fish and Wildlife Service 
substantially increased the number of its full-time law enforcement 
officers, it also reduced the number of part-time officers by more 
than 34 percent. According to the Chief of the Division of Refuge Law 
Enforcement, this reduction came in response to a 2002 review by 
Interior's Office of Inspector General, which reported that law 
enforcement on federal lands was becoming more dangerous and raised 
concerns about the safety of using part-time law enforcement officers. 
[Footnote 17] In response to the Inspector General's concern, the 
refuge law enforcement division chief told us, the agency made a 
concerted effort to reduce the number of part-time officers and also 
required all of its part-time law enforcement officers to spend at 
least 25 percent of their time performing law enforcement duties. 
Still, the refuge law enforcement division chief recognized that the 
reduction in part-time officers meant the loss of a number of officers 
who, in past years, would have been available to respond to illegal 
activities. 

Although the National Park Service, in contrast to the other agencies, 
decreased the number of its permanent law enforcement officers, this 
decline has been accompanied by about a 25 percent increase since 2006 
in the number of officers employed on a seasonal basis. The National 
Park Service uses seasonal officers--those employed for less than 6 
months per year--to respond to seasonal changes in national park 
visitation. National Park Service officials reported that seasonal 
officers do not receive the same training as permanent officers. 
Moreover, echoing concerns it raised about the use of part-time 
officers, Interior's Inspector General also raised concerns about the 
use of seasonal officers, recommending that the Interior agencies also 
reduce their dependence on such officers. A senior National Park 
Service official told us that the agency recognizes the Inspector 
General's concerns about using seasonal officers, but that units with 
large seasonal variations in visitation may not have sufficient work 
to warrant hiring additional permanent officers. 

Despite the general increase in the agencies' law enforcement 
staffing, agency officials at several units we visited said that law 
enforcement resources in some areas have remained thin. For example, 
in southeastern Utah, one Bureau of Land Management officer is 
responsible for patrolling about 1.8 million acres of land rich in 
archaeological resources--including lands from which archaeological 
artifacts have been stolen in recent years. According to this officer, 
when she has been on leave, at training, or temporarily assigned to 
assist other units, the area has been left without law enforcement 
coverage. Likewise, Fish and Wildlife Service officials told us that 
the Merritt Island National Wildlife Refuge Complex--which includes 
six refuges spread across five counties--has had 2 full-time officers 
and 2 part-time officers. As a result, the officials said, some of the 
refuges have little to no regular law enforcement coverage. Similarly, 
the Chesapeake Marshlands National Wildlife Refuge Complex--which 
includes four refuges in Maryland and Virginia--has had 1 full-time 
officer and 1 part-time officer. Additionally, a Forest Service 
official said that there were 12 law enforcement officers to patrol 
three national forests in southwestern Colorado, totaling about 7.5 
million acres, and that certain areas of those forests are rarely 
patrolled by law enforcement officers.[Footnote 18] 

The Agencies Have Directed Resources to Respond Specifically to 
Marijuana Cultivation and Illegal Border Activities: 

Agency documents indicate that the agencies have directed additional 
law enforcement resources to certain areas of the country in a 
specific effort to deter cultivation of marijuana on federal lands and 
illegal activities occurring on federal lands along the United States-
Mexico border. Agency law enforcement officials told us that the 
agencies have placed high priority on distributing law enforcement 
resources to areas where these illegal activities are most prevalent--
in part responding to direction from congressional committees and to 
the high risk posed by these activities to visitors, employees, and 
resources. To deter marijuana cultivation on federal lands, for 
example, the agencies have taken numerous steps, including the 
following: 

* Interior began its marijuana eradication initiative in fiscal year 
2009, intended to provide a coordinated, interagency strategy 
involving Interior and its bureaus, the Forest Service, and other 
federal law enforcement agencies to improve eradication of marijuana 
and drug interdiction and to measurably increase the protection of 
public lands, employees, and visitors. 

* The Bureau of Land Management reported using $5.1 million in fiscal 
year 2009 to hire 10 more law enforcement officers in six western 
states; fund marijuana detection, investigation, and eradication 
operations on its lands; purchase and upgrade communications and law 
enforcement equipment; fund cooperative agreements with state and 
local law enforcement agencies; and rehabilitate and restore former 
cultivation sites. 

* The Forest Service reported that it hired 29 law enforcement 
officers in California, using a portion of $12 million appropriated in 
fiscal year 2007 for a nationwide initiative to increase protection of 
national forest lands from drug-trafficking organizations.[Footnote 19] 

* The National Park Service reported that it directed about $2.7 
million to several national parks in California and Washington to help 
the parks respond to marijuana cultivation in fiscal year 2009; 
similarly, the agency reported directing $448,000 to Sequoia and Kings 
Canyon national parks and $316,000 to Whiskeytown National Recreation 
Area in California in fiscal year 2006. 

* The National Park Service also reported that in fiscal year 2009 it 
created a marijuana investigation and response team, which the agency 
deploys to carry out marijuana prevention, detection, eradication, and 
restoration operations in park units affected by marijuana 
cultivation. For example, according to the National Park Service's 
Chief Ranger of the Pacific West Region, officers from the team; the 
Forest Service; and 14 other federal, state, and local law enforcement 
agencies jointly conducted Operation Save Our Sierra in 2009. This 
operation eradicated more than 400,000 marijuana plants from 71 
cultivation sites across Fresno County, California. 

The agencies have also directed resources to deter illegal activity 
along the United States-Mexico border. For example: 

* In fiscal year 2009, Interior established its Safe Borderlands 
initiative, intended to "provide a safe environment for people and 
protect resources through the focused deployment of personnel, 
restoration of ecosystems, and integrated partnerships along the 
southwest border." 

* The Fish and Wildlife Service reported that it added six new law 
enforcement officers to four refuges along the border in 2009. 

* The Bureau of Land Management reported that in 2008 it hired nine 
law enforcement officers in Arizona, California, and New Mexico. In 
fiscal year 2009, the agency also directed $350,000 to purchase new 
radios for law enforcement officers working along the border. 

* In 2007, the Forest Service added eight law enforcement officers at 
the Coronado National Forest to deter illegal cross-border activity, 
according to agency officials. 

* The National Park Service reported that it constructed a vehicle 
barrier along the border at Organ Pipe Cactus National Monument in 
response to direction in committee reports accompanying the agency's 
fiscal year 2003, 2004, and 2005 appropriations.[Footnote 20] The 
agency also reported that in recent years it added more than 30 law 
enforcement officers to five parks along the border in Arizona and 
Texas. 

Agencies Have Also Temporarily Assigned Law Enforcement Staff to 
Curtail Illegal Activities at Certain Locations as Needed: 

The agencies have also temporarily assigned, or detailed, law 
enforcement officers to areas where more officers have been needed to 
anticipate increases in visitation, carry out planned operations such 
as patrolling the border or eradicating marijuana, or assist other law 
enforcement agencies outside federal lands.[Footnote 21] For example, 
Bureau of Land Management officials told us, 40 officers are detailed 
to the Imperial Sand Dunes Recreation Area on four major holiday 
weekends each year to protect resources and ensure visitor safety 
during large gatherings of OHV enthusiasts. Similarly, officials at 
the Okanogan-Wenatchee National Forest in Washington and Merritt 
Island National Wildlife Refuge told us that detailees have been used 
during hunting seasons and large fishing tournaments to discourage 
hunting and fishing violations. National Park Service officials 
reported that the agency temporarily deployed 7 to 11 officers on 
multiple occasions to Organ Pipe Cactus National Monument to assist 
with the interdiction of drug and human smuggling. In addition, Bureau 
of Land Management officials told us that the agency has identified 
officers with expertise in marijuana investigations and organized them 
into regional pools to provide additional investigative support on a 
case-by-case basis in areas where significant marijuana cultivation 
sites have been discovered. Headquarters officials for all four 
agencies said that temporarily detailing staff allows them to augment 
their law enforcement presence when and where needed, but they also 
said they recognized that doing so reduces the law enforcement 
presence at other locations. 

Agencies Have Increased the Training Required for Law Enforcement 
Officers: 

To better prepare their law enforcement officers to respond safely to 
illegal activities occurring on federal lands, the agencies have 
increased the training new officers are required to complete. 
Specifically, each of the agencies now require new law enforcement 
officers to complete similar three-part training curriculums. First, 
new officers are required to pass the land management police training 
program, a 16-week course developed in 2005 by the Federal Law 
Enforcement Training Center in conjunction with federal land 
management agencies.[Footnote 22] A description of the training 
indicates that the course covers law enforcement skills and knowledge 
that officers for all federal land management agencies need to perform 
their duties effectively. Second, the agencies require new officers to 
receive training about the laws, regulations, and policies specific to 
each agency. The Interior agencies have established 1-to 3-week 
classroom courses covering agency-specific information, and the Forest 
Service has integrated this information into its field officer-
training program. Third, the agencies have established field officer-
training programs, varying in length from 9 to 12 weeks, which allow 
new officers to apply the knowledge and skills learned in the 
classroom to law enforcement duties in the field under the supervision 
of experienced officers. The land management police-training and field 
officer-training programs were established over the past decade, in 
part in response to shortcomings identified by Interior's Inspector 
General.[Footnote 23] Law enforcement officials at most federal land 
units we visited said that the training required for new officers 
generally prepared them well for performing their duties effectively 
and safely. 

Some officials at units we visited also said that responding to 
marijuana cultivation and illegal border activities pose certain risks 
and that additional specialized training would help officers better 
respond to those activities. The Forest Service requires its law 
enforcement officers to complete a 2-week course on drug enforcement 
before they are allowed to do substantial work investigating drug- 
trafficking operations. This course trains officers to identify 
marijuana cultivation sites, understand the hazards of investigating 
these sites, and practice special surveillance and tactics. Law 
enforcement officers at one national forest we visited said that 
although this training was useful, more emphasis on special tactics 
would improve the effectiveness and safety of marijuana eradication 
operations. In contrast, the Interior agencies do not require officers 
to complete specialized drug enforcement training. Bureau of Land 
Management law enforcement officers in California said that more 
tactical training would help them better respond to the challenges 
posed by drug-trafficking organizations. Similarly, a Bureau of Land 
Management law enforcement officer in Arizona said that additional 
tactical training would help officers better respond to illegal border 
activities. A senior law enforcement official for the Bureau of Land 
Management told us that the agency recognizes the need for additional 
tactical training for law enforcement personnel who respond to these 
types of illegal activities and plans to incorporate 8 hours of such 
training into its 2011 training curriculum. A National Park Service 
official also told us the agency plans to hold a 2-week course in 2011 
on special operations and tactics for law enforcement officers who 
work along the border. 

Agencies' Determination of Law Enforcement Resource Needs and 
Distribution Does Not Systematically Assess the Risks Posed by Illegal 
Activities: 

Although land management agencies consider varied information on the 
occurrence and effects of illegal activities on federal lands, the 
agencies do not systematically assess the risks posed by such 
activities when determining their needs for resources and where to 
distribute them. Because of limitations in the information they 
consider, officials cannot fully assess either the magnitude of the 
risks posed by illegal activities or the likelihood of their 
occurrence. As a result, when making decisions about needed law 
enforcement resources and how to distribute those resources, the 
agencies cannot systematically assess the relative risks faced by the 
hundreds of individual land management units across the country. 

To better achieve their missions and improve accountability, federal 
agencies are required to employ certain internal controls, including 
assessing the risks agencies face from both external and internal 
sources.[Footnote 24] Applying the federal risk assessment standard to 
illegal activities occurring on federal lands therefore suggests that--
to respond effectively to these activities and reduce their effect on 
natural and cultural resources, the public, and agency employees--land 
management agencies should, at a minimum, (1) comprehensively identify 
the risks posed by illegal activities on their lands, (2) assess 
identified risks to determine their magnitude and the likelihood of 
their occurrence, and (3) use information from these assessments in 
determining the law enforcement resources they need and how to 
distribute those resources. The risk assessment standard recognizes 
that the specific risk analysis methodology used can vary by agency 
because of differences in agencies' missions and the difficulty in 
qualitatively and quantitatively assigning risk levels. Nevertheless, 
without a systematic process that incorporates all of these elements, 
the agencies may have limited assurance that they are using their law 
enforcement resources in a manner that effectively addresses the risk 
of illegal activities, and they are limited in their ability to meet 
the federal risk assessment standard. 

In determining their law enforcement resource needs and how to 
distribute these resources, law enforcement officials told us they 
consider various types of information on the occurrence and effects of 
illegal activities on their federal land units. Because of limitations 
in the information they consider, however, land management agency 
officials are unable to fully assess either the magnitude of the risks 
related to illegal activities on federal lands or the likelihood of 
their occurrence. Moreover, law enforcement officials identified 
various approaches that their respective agencies use to determine 
resource needs, but limitations in these approaches also hinder the 
agencies' ability to systematically assess the relative risks faced by 
the hundreds of individual land management units across the country or 
the agencies as a whole. 

According to law enforcement officials and land managers we spoke 
with, they consider the available information on the occurrence and 
effects of illegal activities on federal lands and use various 
approaches in managing their law enforcement resources, including the 
following: 

* Incident data on illegal activities occurring on federal lands. Land 
management agencies maintain some data on law enforcement incidents, 
including the type of crime, characteristics of victims and offenders, 
and types and value of resources or property damaged or stolen. 
Incident data allow officials at a unit, regional or state office, or 
headquarters to identify different types of illegal activities 
occurring on particular federal lands. But, as discussed earlier, the 
incident data the agencies rely on are limited for a variety of 
reasons and cannot be used to accurately indicate or monitor the 
trends in occurrence of illegal activities on federal lands. 

* Information on the effects of illegal activities. Agencies collect 
some information on the effects of illegal activities on natural and 
cultural resources and on public and employee safety. As mentioned 
earlier, at several units we visited, officials said they had 
documented damage to specific locations from dumping of trash and 
hazardous materials, marijuana cultivation, timber theft, and 
unauthorized OHV use. But according to agency officials, information 
on effects is not systematically collected and is instead collected 
mainly for specific reasons, as when it is needed as evidence in 
criminal investigations. As a result, the agencies generally lack 
consistent quantitative or qualitative information on the effects of 
illegal activities. Senior agency law enforcement officials said that 
while available information--such as quantities of trash dumped or 
acres of vegetation damaged to cultivate marijuana--helps them 
understand the effects of illegal activities on resources at specific 
locations, they do not believe it is feasible to quantify the effects 
of all illegal activities across the country. 

* Law enforcement plans for individual units and for regions or 
states. Two agencies--the Bureau of Land Management and the Forest 
Service--require their units and their state or regional offices to 
develop law enforcement plans. For example, the Bureau of Land 
Management manual, which contains policy and program direction, 
directs the agency's state offices to develop law enforcement plans 
annually and says that plans are to identify and rank (1) the most 
pressing law enforcement issues facing units in that state, (2) 
specific agency lands that are most important to protect, and (3) 
locations needing additional law enforcement officers. Most of the 10 
state office plans we reviewed contained these elements, although some 
lacked critical components. For example, the plan for the Bureau of 
Land Management's Arizona State Office lists the illegal activities 
identified as important by each field office in the state, but the 
plan neither identifies the activities most important statewide, nor 
ranks those activities according to importance. Even in cases where 
state offices have identified and ranked the most pressing law 
enforcement issues and lands to protect, the plans provide little 
information on the frequency or effects of illegal activities; nor do 
they identify lands where illegal activities are most likely to occur. 
In addition, a senior Bureau of Land Management law enforcement 
official reported that at least two state offices--including 
California, the state office with the largest law enforcement program 
in the agency--have not updated their plans in more than 5 years. 

We found a similar variety in the content of law enforcement plans 
developed by Forest Service regional offices. For example, the plan 
for the Rocky Mountain Region identified three issues--motorized and 
nonmotorized vehicle use, including OHVs; unauthorized commercial 
activities, including guided hunting, rafting, and sightseeing trips, 
and other recreational activities; and theft of timber and other 
forest products--as the biggest challenges to its law enforcement 
program. The plan detailed the nature and scale of the risks posed by 
these activities, locations at greatest risk, and strategies to 
mitigate those risks. In contrast, the plan for the Forest Service's 
Eastern Region identified 11 illegal activities as the most important 
regionwide, but provided little information on the magnitude of the 
activities' effects, the locations most affected, or law enforcement 
strategies the region could use to mitigate those effects. Moreover, 
according to the Forest Service's Director of Law Enforcement and 
Investigations, two regions--the Pacific Northwest and Southern--have 
not developed regionwide law enforcement plans; rather, the plans for 
these two regions simply compile the plans for each forest in the 
region. As a result, the plans identify neither regional priorities 
nor strategies for how to use law enforcement resources to respond to 
those priorities. 

* Risk assessments for specific issues. In some cases, the agencies 
have undertaken efforts to assess risks arising from certain types of 
illegal activities, such as illegal border activities or cultivation 
of marijuana on federal lands. For example, a recent National Park 
Service assessment found that marijuana cultivation has led to 
significant degradation of natural resources, including removal of 
trees and vegetation, introduction of nonnative and invasive species, 
pollution from the extensive use of pesticides and fertilizers, 
alteration of streambeds, and poaching of wildlife. Similarly, in 
2003, Interior, in conjunction with some of its component agencies, 
assessed the risks facing units along the U.S. border with 
Mexico.[Footnote 25] This assessment identified different risks, 
ranging from dumping of trash to violence against the public or law 
enforcement officers to international terrorism--illegal activities 
that all posed risks to natural resources, the public, and agency 
employees along the border. In addition, in 2007 and 2008, the 
National Park Service's Intermountain Region completed similar 
assessments for five national parks along the border in Arizona and 
Texas. The agency reported that on the basis of these assessments, it 
added more than 30 law enforcement officers to the five parks and 
constructed new infrastructure, such as fences and vehicle barriers 
along the borders, to deter illegal entry. But these assessments 
provide no information on the importance of the risks from the 
assessed activities relative to the risks posed by other illegal 
activities. As a result, individual assessments like these cannot help 
officials determine which illegal activities pose the greatest risks 
to resources, the public, and agency employees or help them identify 
which units are in greatest need of more law enforcement resources. 

* Formal decision-support tools. In an effort to help them more 
systematically analyze their law enforcement programs, two of the 
agencies--the Fish and Wildlife Service and the National Park Service--
have developed decision-support tools that estimate the number of law 
enforcement resources needed at individual units. These tools 
incorporate a number of variables, such as geographic characteristics, 
sensitive natural and cultural resources, and visitation patterns, 
when analyzing law enforcement needs for a refuge or park. 
Nevertheless, we identified a number of shortcomings with these tools 
that limit their effectiveness in assessing the relative risks of 
illegal activities. For example, the Fish and Wildlife Service has 
used a staffing deployment model developed for it in 2005 by the 
International Association of Chiefs of Police to help determine its 
overall staffing needs and to assign new law enforcement officers to 
specific refuges. Despite initial plans to integrate risk assessments 
of certain illegal activities for each refuge into the model, the 
assessments were never conducted and were not included in the model's 
final analysis. The Chief of the Division of Refuge Law Enforcement 
said the agency would like to update the model to account for the 
expansion of the refuge system and to reevaluate the weights placed on 
the variables included in the model--as well as to include the risk 
assessment components omitted from the initial analysis--but he said 
the agency had no specific plans to do so. Similarly, the National 
Park Service has used its staffing model to help officials determine 
law enforcement resource needs. However, Interior's Inspector General 
has criticized the model because it has never been validated, its 
methodology has not been supported, and there is no certainty that its 
main assumptions are correct.[Footnote 26] Law enforcement officials 
at several national parks we visited told us that they did not believe 
the model accurately estimated the number of officers a particular 
unit needed. Senior National Park Service law enforcement officials 
told us they recognized the model's shortcomings and were evaluating 
options for improving it. 

Without consistent information on the relative risks illegal 
activities pose to resources, the public, and agency employees at 
federal land units across the country, or a systematic approach to use 
this information to make decisions about how law enforcement resources 
should be distributed, the agencies have limited assurance that they 
are accurately determining their law enforcement needs and 
distributing their law enforcement resources effectively. As stated 
earlier, the land management agencies should, at a minimum, (1) 
comprehensively identify the risks posed by illegal activities on 
their lands, (2) assess identified risks to determine their magnitude 
and the likelihood of their occurrence, and (3) use this information 
in determining the law enforcement resources they need and how to 
distribute those resources. Without such information and processes, 
the agencies are not adhering to federal internal control standards. 
As a result, land management agencies may not be able to ensure that 
their current decisions on allocating law enforcement resources are 
effective, nor can they know whether resources would be more effective 
if distributed to different units or, if additional resources are 
needed, where these new resources should go. 

Senior law enforcement officials at each agency told us they believed 
that a more systematic approach to assessing risks would help the 
agencies make more-informed decisions about law enforcement resources. 
They said such an approach would also help them better explain their 
law enforcement resource allocation decisions, both within their law 
enforcement programs--so that officials in the field understood why 
some units gained law enforcement staff while others stayed the same 
or declined--and to outside parties, including overall agency 
leadership. In 2009, we recommended that the National Park Service 
develop such an approach--specifically that it develop a more 
comprehensive, routine risk management approach for security.[Footnote 
27] In response to our recommendation, the National Park Service has 
taken and continues to take actions--such as improving protective 
infrastructure and surveillance equipment--designed to reduce the 
risks to historical structures and the public at the five units that 
have been designated as national icons.[Footnote 28] The agency has 
taken few steps, however, to identify and reduce risks to the other 
units of the National Park System. 

Conclusions: 

In an environment of constrained budgets, land management agencies 
will likely continue to face challenges in protecting natural and 
cultural resources, the public, and agency employees from the effects 
of illegal activities on federal lands. The limitations of available 
information on illegal activities on federal lands, and the agencies' 
lack of systematic approaches to identifying law enforcement resource 
needs and distributing those resources, hamper the agencies' efforts 
to target their resources effectively. Without a more systematic 
method to assess the risks posed by illegal activities and a stronger 
framework for managing them, the agencies cannot be assured that they 
are allocating scarce resources in a manner that effectively addresses 
the risk of illegal activities on our nation's federal lands. 

Recommendation for Executive Action: 

To help the agencies identify the law enforcement resources they need 
and how to distribute these resources effectively, we recommend that 
the Secretaries of Agriculture and the Interior direct the Chief of 
the Forest Service and the Directors of the Bureau of Land Management, 
Fish and Wildlife Service, and National Park Service, respectively, to 
each take the following action: Adopt a risk management approach to 
systematically assess and address threats and vulnerabilities 
presented by illegal activities on federal lands. The approach can 
vary among the agencies but should be consistent within each agency 
and should include (1) conducting periodic risk assessments to 
identify and rank threats and assess agency vulnerabilities and (2) 
establishing a structured process for using the results of these 
assessments to set priorities for and distribute law enforcement 
resources to best protect natural and cultural resources, as well as 
public and agency employee safety. 

In developing a risk management approach, the agencies should consider 
conducting the risk assessments at regional or state levels and using 
those assessments to inform decisions about law enforcement resource 
needs and how to distribute those resources across the country. 

Agency Comments and Our Evaluation: 

We provided a draft of this report for review and comment to the 
Departments of Agriculture and the Interior. The Forest Service, 
responding on behalf of Agriculture, agreed with our report's findings 
and recommendation; the agency's written comments are reprinted in 
appendix II. Interior--in an e-mail through its liaison to GAO on 
November 15, 2010--agreed with our report's recommendation and also 
provided technical comments, which we incorporated into the report as 
appropriate. 

In its written comments, the Forest Service stated that it is 
developing a template for its regional offices to use in preparing 
annual regional law enforcement plans that will assist the agency in 
setting priorities for allocating law enforcement resources. We 
commend the agency for taking this action and believe that such a 
template has the potential to improve the consistency of information 
available to senior agency leaders making decisions about law 
enforcement resources. However, it is unclear from the agency's 
written response whether the template it is developing incorporates 
risk management elements. As our report notes, an effective risk 
management approach would include (1) comprehensively identifying the 
risks posed by illegal activities on federal lands, (2) assessing 
identified risks to determine their magnitude and the likelihood of 
their occurrence, and (3) using this information in determining the 
law enforcement resources the agencies need and how to distribute 
those resources. 

We are sending copies of this report to the appropriate congressional 
committees; Secretaries of Agriculture and the Interior; Chief of the 
Forest Service; Directors of the Bureau of Land Management, Fish and 
Wildlife Service, and National Park Service; and other interested 
parties. In addition, this report will be available at no charge on 
the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have questions about this report, please contact 
me at (202) 512-3841 or mittala@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Key contributors to this report are 
listed in appendix III. 

Sincerely yours, 

Signed by: 

Anu K. Mittal: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

The objectives of our review were to determine (1) the types of 
illegal activities occurring on federal lands and the effects of those 
activities on natural and cultural resources, the public, and agency 
staff; (2) how the agencies have used their law enforcement resources 
to respond to these illegal activities; and (3) how the agencies 
determine their law enforcement resource needs and distribute these 
resources. 

To determine the types of illegal activities occurring on federal 
lands, we reviewed documents and interviewed officials from the 
headquarters and regional or state offices of four federal land 
management agencies: the Forest Service in the Department of 
Agriculture and the Bureau of Land Management, Fish and Wildlife 
Service, and National Park Service in the Department of the Interior. 
We also collected and analyzed agency data on the recorded frequency 
of different types of illegal activities. Using this information, we 
identified about 20 categories of illegal activities occurring on 
federal lands and interviewed agency officials at headquarters and at 
regional and state offices to corroborate and refine these categories. 
To determine the occurrence of different types of illegal activities 
in different areas of the country, we interviewed agency law 
enforcement officials at headquarters and in each regional or state 
office and, using a standardized set of questions, asked them to 
identify which types of illegal activities placed the greatest demands 
on their law enforcement resources. To determine the effects of 
illegal activities on natural and cultural resources, the public, and 
agency staff, we interviewed agency officials at headquarters and 
selected units, who described the effects that can result from 
different types of illegal activities. Because the agencies lack 
nationwide information on these effects, and to better understand any 
regional or agency variation in the occurrence and effects of 
different types of illegal activities, we visited or contacted 26 
selected agency units in eight geographic areas throughout the United 
States (see table 2).[Footnote 29] Units were selected on the basis of 
our interviews with regional and state office officials and to broadly 
represent the types of illegal activities occurring on federal lands. 
For each unit, we (1) reviewed documents, including assessments or 
reports describing the effects of illegal activities; (2) interviewed 
law enforcement and, at some units, land management officials about 
the occurrence and effects of illegal activities; and (3) observed 
locations in the field that have been damaged by illegal activities. 

Table 2: Bureau of Land Management, Fish and Wildlife Service, Forest 
Service, and National Park Service Field Units Visited or Contacted, 
by Location: 

Location: Arizona; 
Agency: Bureau of Land Management; 
Unit: Sonoran Desert National Monument. 

Location: Arizona; 
Agency: Fish and Wildlife Service; 
Unit: Buenos Aires National Wildlife Refuge. 

Location: Arizona; 
Agency: Forest Service; 
Unit: Coronado National Forest. 

Location: California; 
Agency: Bureau of Land Management; 
Unit: El Centro Field Office[A]. 

Location: California; 
Agency: Bureau of Land Management; 
Unit: Ukiah Field Office[A]. 

Location: California; 
Agency: Forest Service; 
Unit: Sierra National Forest. 

Location: California; 
Agency: National Park Service; 
Unit: Yosemite National Park. 

Location: Four Corners (Colorado and Utah); 
Agency: Bureau of Land Management; 
Unit: Monticello Field Office. 

Location: Four Corners (Colorado and Utah); 
Agency: Forest Service; 
Unit: San Juan National Forest. 

Location: Four Corners (Colorado and Utah); 
Agency: National Park Service; 
Unit: Arches National Park. 

Location: Four Corners (Colorado and Utah); 
Agency: National Park Service; 
Unit: Canyonlands National Park. 

Location: Florida; 
Agency: Fish and Wildlife Service; 
Unit: Merritt Island National Wildlife Refuge. 

Location: Florida; 
Agency: Forest Service; 
Unit: Ocala National Forest. 

Location: Florida; 
Agency: National Park Service; 
Unit: Everglades National Park. 

Location: Appalachian Mountains (Kentucky, North Carolina, Tennessee, 
and Virginia); 
Agency: Forest Service; 
Unit: Cherokee National Forest. 

Location: Appalachian Mountains (Kentucky, North Carolina, Tennessee, 
and Virginia); 
Agency: National Park Service; 
Unit: Cumberland Gap National Park. 

Location: Appalachian Mountains (Kentucky, North Carolina, Tennessee, 
and Virginia); 
Agency: National Park Service; 
Unit: Great Smoky Mountains National Park. 

Location: Mid-Atlantic (Maryland and Virginia); 
Agency: Fish and Wildlife Service; 
Unit: Blackwater National Wildlife Refuge. 

Location: Mid-Atlantic (Maryland and Virginia); 
Agency: Fish and Wildlife Service; 
Unit: Chincoteague National Wildlife Refuge. 

Location: Mid-Atlantic (Maryland and Virginia); 
Agency: Fish and Wildlife Service; 
Unit: Eastern Neck National Wildlife Refuge. 

Location: Mid-Atlantic (Maryland and Virginia); 
Agency: National Park Service; 
Unit: Fredericksburg and Spotsylvania National Military Park. 

Location: Minnesota; 
Agency: Fish and Wildlife Service; 
Unit: Detroit Lakes Wetland Management District. 

Location: Minnesota; 
Agency: Fish and Wildlife Service; 
Unit: Tamarac National Wildlife Refuge. 

Location: Minnesota; 
Agency: Forest Service; 
Unit: Superior National Forest. 

Location: Washington; 
Agency: Forest Service; 
Unit: Okanogan-Wenatchee National Forest. 

Location: Washington; 
Agency: National Park Service; 
Unit: North Cascades National Park. 

Source: GAO. 

[A] We did not visit this unit in person but interviewed unit 
officials at the Bureau of Land Management's state office in 
Sacramento, California. 

[End of table] 

To determine how the agencies have used their law enforcement 
resources to respond to illegal activities, we analyzed available data 
on law enforcement staffing for each agency. We assessed the 
reliability of each agency's data and, on the basis of our audit 
objectives, determined that the data were sufficiently reliable to 
report. In addition, we reviewed congressional appropriations to the 
agencies for responding to specific types of illegal activities, such 
as illegal crossings of the U.S. border with Mexico or marijuana 
production on federal lands; congressional committee direction to the 
agencies to direct law enforcement resources toward responding to 
specific illegal activities; and agency documents describing how they 
used law enforcement resources to respond to these specific 
activities. We also reviewed agency guidance, analyzed available data, 
and interviewed agency officials at headquarters and selected units to 
determine how the agencies temporarily assign staff to areas needing 
additional law enforcement resources. Finally, we reviewed agency 
documentation on training requirements for law enforcement officers 
and interviewed agency officials at headquarters and the units we 
visited to obtain their perspectives on the sufficiency of training in 
preparing officers to respond effectively and safely to illegal 
activities. 

To determine how land management agencies identify their law 
enforcement resource needs and distribute those resources, we asked 
agency law enforcement officials at headquarters and at regional or 
state offices to identify the information they consider and the 
processes they use to make law enforcement staffing decisions. To 
identify federal requirements and best practices for incorporating 
risk management into agency decision making, we reviewed relevant 
guidance, including GAO's Standards for Internal Control in the 
Federal Government,[Footnote 30] as well as other GAO reports on using 
risk management to inform agency decisions about how to distribute 
agency resources. To evaluate the extent to which the agencies met 
risk management requirements and incorporated best practices, we 
reviewed examples of the types of information officials consider in 
making resource decisions, including (1) agency data on the occurrence 
of illegal activities; (2) agency information on the effects of 
illegal activities on natural and cultural resources, the public, and 
agency staff; (3) agency law enforcement plans for individual units 
and regions or states; (4) risk assessments the agencies have 
conducted for specific types of illegal activities; and (5) 
descriptions of formal decision-support tools some of the agencies use 
to analyze their resource needs, examples of how these tools have been 
used to inform decision making, and available assessments of these 
tools. To obtain their perspectives on information and processes used 
to determine their resource needs and distribution, we also 
interviewed agency officials at headquarters, at regional or state 
offices, and at the units we visited. 

We conducted this performance audit from July 2009 through December 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Department of Agriculture, Forest 
Service: 

USDA: 
United States Department of Agriculture: 
Forest Service
Washington Office: 
1400 Independence Avenue, SW: 
Washington, DC 20250: 

File Code: 1420: 

Date: November 22, 2010: 

Anu K. Mittal: 
Director, Natural Resources and Environment: 
Government Accountability Office: 
441 G. Street, N.W. 
Washington, DC 20548: 

Dear Ms. Mittal: 

Thank you for the opportunity to review and provide comment on the 
draft U.S. Government Accountability Office (GAO) Report on "Federal 
Lands: Adopting a Formal, Risk-Based Approach Could Help Land 
Management Agencies Better Manage Their Law Enforcement Resources (GA0-
11-144)." The Forest Service has reviewed the report and generally 
concurs with the report's observations and recommendations. 

The Washington Office (WO) Law Enforcement and Investigations (LEI) 
staff is currently developing a Regional Law Enforcement Plan template 
that will assist the Forest Service with setting priorities for 
allocating LEI resources. The Regional Special Agents-in-Charge will 
update the Regional Law Enforcement Plans each year. The WO LEI staff 
will conduct annual reviews of the regional plans for consistency. The 
Regional Law Enforcement Plans will assist the agency with 
distributing LEI resources, including staffing and budget needs, 
effectively throughout the Forest Service. 

If you have any questions, please contact Donna M. Cannical, Chief 
Financial Officer, at (202) 205-1321 or dcarmical@fs.fed.us. 

Sincerely, 

Signed by: 

[Illegible] for: 
Thomas L. Tidwell: 
Chief: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Anu K. Mittal, (202) 512-3841 or mittala@gao.gov: 

Staff Acknowledgments: 

In addition to the contact person named above, David P. Bixler, 
Assistant Director; Ellen W. Chu; Jonathan Dent; Christy Feehan; Alma 
Laris; Michael Lenington; Micah McMillan; Rebecca Shea; and Jeanette 
Soares made key contributions to this report. Also contributing to 
this report were Melinda L. Cordero, Richard M. Stana, and Kiki 
Theodoropoulos. 

[End of section] 

Footnotes: 

[1] The National Park Service has two separate law enforcement 
programs: a park ranger program, which provides law enforcement 
services at most national park units, and the United States Park 
Police, which provides law enforcement services at designated units, 
primarily in the Washington, D.C.; New York; and San Francisco 
metropolitan areas. Because many of the challenges facing these urban 
units differ from those facing other federal land management units, we 
excluded the United States Park Police from this review. 

[2] Of the 26 selected sites, we visited 24 in person and, for the 
other 2 sites, interviewed law enforcement officials of the Bureau of 
Land Management's El Centro and Ukiah field offices in the agency's 
California State Office. 

[3] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[4] The federal government does not always have jurisdiction to 
prosecute those engaging in illegal activities on federal lands. The 
federal government's authority to prosecute depends on a variety of 
factors, including the type of illegal activity and the precise 
location where the activity occurred. 

[5] All federal departments and agencies that routinely investigate 
complaints of criminal activity, including the land management 
agencies, are required under the Uniform Federal Crime Reporting Act 
of 1988 to report to the U.S. Attorney General certain details about 
crimes within their respective jurisdictions. The data collected 
include information about the type of offense, the offender(s), and 
the victim(s) involved. 

[6] Department of the Interior, Office of Inspector General, 
Assessment of the Department of Interior's Law Enforcement Activities, 
No. 2002-I-0014 (Washington, D.C., Jan. 14, 2002). 

[7] Cumberland Gap National Park is located at the junction of 
Kentucky, Tennessee, and Virginia. 

[8] The West Indian manatee is listed as endangered under the 
Endangered Species Act. 

[9] Federal lands designated by Congress as wilderness areas under the 
Wilderness Act of 1964 are to be administered in such a manner as will 
leave them unimpaired for future use and enjoyment as wilderness and 
to provide for their protection and the preservation of their 
wilderness character, among other goals. The act defines wilderness as 
areas of undeveloped federal land retaining their primeval character, 
without permanent improvements or human habitation. The act generally 
prohibits the construction of roads or structures, as well as the use 
of motor vehicles, motorized equipment, and other forms of mechanical 
transport in wilderness areas. Under the act, Congress has established 
about 759 wilderness areas, totaling nearly 110 million acres. 

[10] Wild ginseng is relatively rare, and the official said that the 
healthiest populations are located mostly on federal lands. 

[11] In exchange for a one-time, lump-sum payment from the federal 
government, private owners of wetlands agreed not to drain, fill, or 
level them. Similarly, private owners of grasslands agreed not to 
destroy the vegetative cover by tilling, haying, or other means during 
the annual migratory bird nesting season. 

[12] The Secretary of the Interior is authorized to use the Migratory 
Bird Conservation Fund to purchase both fee-simple lands and easements 
to acquire waterfowl production areas that provide necessary habitat 
for waterfowl and other migratory birds. Easements, although private 
property, are considered part of the National Wildlife Refuge System. 
See GAO, Prairie Pothole Region: At the Current Pace of Acquisitions, 
the U.S. Fish and Wildlife Service Is Unlikely to Achieve Its Habitat 
Protection Goals for Migratory Birds, [hyperlink, 
http://www.gao.gov/products/GAO-07-1093] (Washington, D.C.: Sept. 27, 
2007). 

[13] The National Drug Intelligence Center was established by the 
Department of Defense Appropriations Act for fiscal year 1993 (Pub. L. 
No. 102-396 (1992)) to coordinate and consolidate drug intelligence 
from all national security and law enforcement agencies and to produce 
information regarding the structure, membership, finances, 
communications, and activities of drug-trafficking organizations. The 
center is under the direction and control of the U.S. Attorney General. 

[14] A recent GAO report discusses illegal border activities and their 
effects in more detail. See GAO, Southwest Border: More Timely Border 
Patrol Access and Training Could Improve Security Operations and 
Natural Resource Protection on Federal Lands, [hyperlink, 
http://www.gao.gov/products/GAO-11-38] (Washington, D.C.: Oct. 19, 
2010). 

[15] Illegal border activities also took place at the three units we 
visited on the northern border with Canada, although, unlike units we 
visited along the southwestern border, officials at the northern units 
did not report significant impacts on resources or the public. 
Nonetheless, officials at all three northern border units observed 
that both drugs and humans have been smuggled into the United States 
across their lands and that violent encounters between smugglers and 
the public could occur. 

[16] The Fish and Wildlife Service also employs permanent officers who 
perform law enforcement duties on a part-time basis. Part-time law 
enforcement officers (known as dual-function officers) are employed 
full-time by the agency, but their primary duties are unrelated to law 
enforcement. Part-time officers are held to the same standards and 
training as permanent officers but spend only 25 to 50 percent of 
their time performing law enforcement duties. 

[17] Department of the Interior, Office of Inspector General, 
Disquieting State of Disorder: An Assessment of Department of the 
Interior Law Enforcement, Report No. 2002-I-0014 (Washington, D.C., 
2002). 

[18] The three forests are the Grand Mesa-Uncompahgre-Gunnison, the 
Rio Grande, and the San Juan national forests. 

[19] Pub. L. No. 110-28, 121 Stat. 112, 165 (2007). 

[20] H.R. Rep. No. 108-10, at 990 (2003) (Conf. Rep.) (fencing); H.R. 
Rep. No. 108-330, at 103 (2003) (Conf. Rep.) (vehicle barrier); H.R. 
Rep. No. 108-792, at 1049 (2004) (Conf. Rep.) (vehicle barrier). 

[21] Agency officials report that the land management agencies assist 
one another by providing additional officers and other resources when 
requested by another agency. In addition, land management agencies and 
other federal, state, and local law enforcement agencies assist one 
another as needed. 

[22] The Federal Law Enforcement Training Center is a component of the 
Department of Homeland Security. The land management police training 
course was developed by the training center in conjunction with the 
U.S. Park Police, National Park Service, Fish and Wildlife Service, 
Forest Service, Bureau of Land Management, Tennessee Valley Authority, 
and National Marine Fisheries Service. 

[23] Department of the Interior, Office of Inspector General, 
Disquieting State of Disorder. 

[24] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[25] Department of the Interior, Threat Assessment for the U.S./Mexico 
Border, 2002-2003 (Tucson, Ariz., 2003). 

[26] Department of the Interior, Office of Inspector General, Progress 
Report on the Secretary's Directives for Implementing Law Enforcement 
Reform, No. PI-EV-MOI-0001-2006 (Washington, D.C., 2006), and Third 
Progress Report on the Implementation of the Secretary's Directives 
for Law Enforcement Reform, No. PI-AT-MOA-0001-2008 (Washington, D.C., 
2009). 

[27] GAO, Homeland Security: Actions Needed to Improve Security 
Practices at National Icons and Parks, [hyperlink, 
http://www.gao.gov/products/GAO-09-983] (Washington, D.C.: Aug. 28, 
2009). 

[28] Interior has designated five National Park Service units as 
national icons: (1) the Statue of Liberty National Monument in New 
York City; (2) Independence National Historical Park in Philadelphia; 
(3) the Jefferson National Expansion Memorial in St. Louis; (4) Mount 
Rushmore National Memorial in South Dakota; and (5) the national mall 
icons (the Washington Monument National Memorial, Thomas Jefferson 
National Memorial, and Lincoln National Memorial) in Washington, D.C. 

[29] Of the 26 selected sites, we visited 24 in person and, for the 
other 2 sites, interviewed law enforcement officials of the Bureau of 
Land Management's El Centro and Ukiah field offices in the agency's 
California State Office. 

[30] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[End of section] 

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