a

GAO

United States Government Accountability Office

Report to the Chairman, Committee on 

Resources, House of Representatives

April 2005 ENDANGERED 

SPECIES

Fish and Wildlife 

Service Generally 

Focuses Recovery 

Funding on 

High-Priority Species, 

but Needs to 

Periodically Assess Its 

Funding Decisions

GAO-05-211
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-211.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robin Nazzaro 

at (202) 512-3841 or nazzaror@gao.gov. 

Highlights of GAO-05-211, a report to the 

Chairman, Committee on Resources, 

House of Representatives 

April 2005

ENDANGERED SPECIES 

Fish and Wildlife Service Generally 

Focuses Recovery Funding on HighPriority Species, but Needs to 

Periodically Assess Its Funding 

Decisions 

The Service spent its recovery funds in a manner generally consistent with 

species priority in fiscal years 2000 through 2003, spending almost half (44 

percent) of the $127 million on the highest priority species (see figure 

below). Species in the next two highest priority groups received almost all 

of the remaining recovery funds (51 percent). Species in the three lowest 

priority groups received very little funding (6 percent). Most listed species 

(92 percent) are in the top three priority groups. 

When Service officials allocate recovery funds, they base their decisions to a 

significant extent on factors other than a species’ priority ranking. At the 

headquarters level, a formula that focuses on each region’s workload 

determines how recovery funds are allocated to regional offices. Each 

regional office allocates its recovery funds to their field offices differently, 

but in no case is priority ranking the driving factor. Instead, regional 

officials focus primarily on opportunities for partnerships, though they told 

us that they also focus on species facing the gravest threats. Field office 

staff we spoke with emphasized the importance of pursuing funding 

partnerships in order to maximize their scarce recovery funds. The Service 

does not know the effect of these disparate allocation systems because it 

does not have a process to routinely measure the extent to which it is 

spending its recovery funds on higher priority species. While we found that 

for fiscal years 2000 through 2003 the Service spent a majority of its recovery 

funds on high priority species, without periodically assessing its funding 

decisions, the Service cannot ensure that it spends its recovery funds on the 

species that are of the greatest priority and, in cases where it does not, 

determine whether its funding decisions are appropriate. 

Recovery Funds Spent on Species by Priority, Fiscal Years 2000-2003 

Recovery dollars in millions

Source: GAO analysis of Fish and Wildlife Service data.

High Low Priority

5%

1% 0%

28%

23%

44%

0

10

20

30

40

50

60

Note: Percentages add to more than 100 percent due to rounding. 

Currently there are more than 1,260 

species listed as endangered or 

threatened under the Endangered 

Species Act of 1973. While few 

species have gone extinct since 

1973, only 9 have been “recovered” 

or removed from the list because 

they no longer need the act’s 

protection. This has raised 

questions about how the U.S. Fish 

and Wildlife Service (Service) 

allocates its recovery funds. 

Proponents of the act believe that 

the Service’s recovery funds are 

only a small fraction of what is 

needed to make greater recovery 

progress. 

The act and agency guidelines 

require the Service to prioritize 

species to guide recovery fund 

allocation. In fiscal year 2000 

through 2003, the Service spent 

$127 million dollars in recovery 

funds attributable to individual 

species. In this report, GAO 

analyzed (1) the extent to which 

the Service’s allocation of recovery 

funds compares with its recovery 

priority guidelines and (2) what 

factors influence the Service’s 

recovery allocation decisions. 

What GAO Recommends

To help ensure that the Service is 

making the best use of available 

recovery resources, GAO is 

recommending that the Service 

periodically assess the extent to 

which higher priority species 

receive recovery funds and report 

this information publicly. The 

Department of the Interior agreed 

with GAO’s findings and 

recommendations.
Page i GAO-05-211 Prioritizing Recovery Funds

Contents

Letter 1

Results in Brief 3

Background 5

The Service Spends a Significant Portion of Recovery Funds on the 

Highest Priority Species 13

The Service Considers Factors Besides Species Priority When 

Allocating Recovery Funds but Does Not Assess the Results of Its 

Funding Decisions 19

Conclusions 30

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 31

Appendixes

Appendix I: Scope and Methodology 33

Appendix II: Comments from the Department of the Interior 38

GAO Comments 40

Appendix III: GAO Contact and Staff Acknowledgments 42

GAO Contact 42

Staff Acknowledgments 42

Tables Table 1: Total Reported Expenditures for All Endangered Species 

Activities and Fish and Wildlife Recovery Expenditures by 

Year for Fiscal Years 2000-2003 9

Table 2: Fish and Wildlife Service’s Recovery Priority Ranking 

Schedule 10

Table 3: Total Reported Expenditures for All Endangered Species 

Activities Compared to Fish and Wildlife Service’s 

Recovery Expenditures During Fiscal Year 2003—for Top 

20 Species 27

Table 4: Fish and Wildlife Service’s Recovery Expenditures 

Compared to Total Reported Expenditures on All 

Endangered Species Activities During Fiscal Year 2003—

for Top 20 Species 29

Table 5: GAO Groupings of Priority Numbers 35

Table 6: Number of Species in Each Priority Group, by Year 36
Contents

Page ii GAO-05-211 Prioritizing Recovery Funds

Figures Figure 1: Recovery Expenditures by Priority, Fiscal Years 

2000-2003 4

Figure 2: The Fish and Wildlife Service’s Fiscal Year 2003 Budget 8

Figure 3: Location of Fish and Wildlife Service’s Seven Regions 12

Figure 4: Recovery Expenditures by Priority Ranking, Fiscal Years 

2000-2003 14

Figure 5: Distribution of Species by Priority Ranking as of 

September 2003 15

Figure 6: Weighted Average Per Species Expenditure, by Priority 

Ranking, Fiscal Years 2000-2003 16

Figure 7: Distribution of Endangered and Threatened Species by 

Priority Ranking as of September 2003 17

Figure 8: Weighted Average Per Species Expenditures, by 

Taxonomic Classification, Fiscal Years 2000-2003 18

Figure 9: The California Red-Legged Frog Is Important to a 

California Community Due to Its Prominence in a Famous 

Mark Twain Story 25

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-05-211 Prioritizing Recovery Funds

United States Government Accountability Office

Washington, D.C. 20548

A

April 6, 2005 Letr

The Honorable Richard W. Pombo

Chairman, Committee on Resources

House of Representatives 

The Endangered Species Act of 1973 protects more than 1,260 species 

facing extinction or likely to face extinction (referred to as endangered and 

threatened species, respectively). The purpose of the act is to conserve 

endangered and threatened species and the ecosystems upon which they 

depend. Critics of the act are concerned that this goal is not being met 

because only 9 species have been “recovered”—brought to the point where 

they no longer need the act’s protection—since the act’s inception in 1973.1

 

However, proponents of the act counter that because of the act’s 

protections only 9 species have gone extinct. Proponents also point out 

that funding available to recover species is only a small fraction of what 

federal scientists believe is needed, making greater recovery progress a 

practical impossibility. 

The U.S. Fish and Wildlife Service (Service) is responsible for 

implementing the act for freshwater and land species.2

 To recover species, 

the Service develops recovery plans, which include site-specific recovery 

tasks such as identifying the size of a population or restoring habitat. 

Recovery plans can take years or decades to fully implement, depending on 

the needs of the species covered by the plan. In 1979, Congress amended 

the act, in part, to require the Service to establish guidelines for prioritizing 

the development and implementation of recovery plans. The Service 

established guidelines that, among other things, prioritize species based on 

factors such as the degree of threat the species faces and its potential to be 

recovered.3

 Under these guidelines, therefore, species facing a high degree 

of threat and having a high potential for recovery are to be afforded the 

highest priority. Species in this category include the northern spotted owl, 

1

As of September 30, 2004.

2

The Department of the Interior has delegated its responsibility for freshwater and land 

species to the U.S. Fish and Wildlife Service, which established an endangered species 

program to implement the requirements of the act. Responsibility for implementing the act 

for anadromous fish and most marine species resides with the Department of Commerce, 

which has delegated its responsibilities to the National Marine Fisheries Service. This report 

does not address the National Marine Fisheries Service program. 

3

48 Fed. Reg. 43098 (Sept. 21, 1983).
Page 2 GAO-05-211 Prioritizing Recovery Funds

the grizzly bear, and the American crocodile as well as lesser-known highpriority species such as Fender’s blue butterfly, Texas wild rice, and the 

Hawaiian dark-rumped petrel (a sea bird). The recovery guidelines 

emphasize that they should be used only as a guide, not as an inflexible 

framework for determining funding allocations.

During fiscal years 2000 through 2003, the Service allocated $245 million—

between $56 million and $65 million per year—to develop and implement 

plans under its recovery program.4

 Biologists inside the Service and 

elsewhere believe these funds are a small fraction of what is needed in the 

face of the daunting recovery challenge. As a result, the Service 

increasingly relies on partnerships with other federal agencies, the states, 

and private organizations to help implement recovery plans and has 

cultivated relationships with many of them by jointly funding projects. For 

example, the Service’s Hawaii field office is jointly funding a project with 

other federal agencies, local governments, and The Nature Conservancy to 

revitalize watersheds to help recover the endangered Hawaiian duck, 

among other species. Although the Service is required to report annually on 

all federal and some state expenditures on listed species,5

 it does not 

separately report on how it spent its recovery funds by species.6

You asked us to assess how the Service allocates its recovery funds among 

endangered and threatened species. In this report, we (1) analyze how the 

Service’s allocation of recovery funds compares with its recovery priority 

guidelines and (2) determine what factors influence the Service’s recovery 

funding allocation decisions. Since most of the Service’s recovery funding 

was spent on salaries that are not allocated on a per species basis, we 

asked each of the Service’s regional offices to identify, to the extent 

possible, the spending on individual species for fiscal years 2000 through 

2003. Collectively, the regions were able to attribute to individual species 

$127 million (52 percent) of the $245 million the Service allocated to the 

recovery program. We also obtained the individual species’ priority ranking 

based on the recovery priority guidelines for those years. We then 

4

All dollars in this report are in current year dollars.

5

The act requires the Service to submit to Congress by January 15th an annual report 

covering the preceding fiscal year containing an accounting of a species by species basis for 

all reasonably identifiable expenditures made primarily for the conservation of endangered 

or threatened species pursuant to the act. 

6

In this report, the term “spent” refers to budget outlays or expenditures.
Page 3 GAO-05-211 Prioritizing Recovery Funds

compared the recovery expenditures for individual species with those 

species’ priority rankings for fiscal years 2000 through 2003. In addition, we 

interviewed Service recovery officials in headquarters, all seven regional 

offices, and several field offices throughout the country. (See App. I for a 

more detailed description of the scope and methodology of our review). 

We did not make a judgment about the adequacy or accuracy of the 

Service’s recovery priority system. In this report we analyzed only Fish and 

Wildlife Service’s recovery expenditures, not expenditures on other 

endangered and threatened species activities (which are reported, in 

combination with recovery expenditures, in Fish and Wildlife Service’s 

annual expenditure report to Congress) or expenditures from other 

entities. We performed our work between February 2004 and January 2005 

in accordance with generally accepted government auditing standards. 

Results in Brief The Fish and Wildlife Service has spent its recovery funds in a manner 

generally consistent with its recovery priority guidelines. For fiscal years 

2000 through 2003, the Service spent nearly half (44 percent) of the 

recovery funds attributable to individual species on species with both a 

high degree of threat and a high potential for recovery (see fig. 1). These 

species constitute one-third of all endangered and threatened species, and 

they received, on average, more funding than species that were lower 

priority. Of the remaining recovery funds, almost all (51 percent) was spent 

on species in the next two highest priority groups—species with a high 

threat assessment but a low potential for recovery, and species with a 

moderate threat assessment but a high potential for recovery. Very little (6 

percent) was spent on species in the remaining three lowest priority groups 

and most of this is attributable to spending on two species: the Bald Eagle 

(which is nearing delisting) and the Canada Lynx (which was embroiled in 

controversy). 
Page 4 GAO-05-211 Prioritizing Recovery Funds

Figure 1: Recovery Expenditures by Priority, Fiscal Years 2000-2003

Note: Percentages add to more than 100 percent due to rounding. 

When Service officials allocate recovery funds, they base their decisions to 

a significant extent on factors other than those contained in the recovery 

priority guidelines, including workload and partnerships with other 

organizations. Headquarters allocates most of its recovery budget among 

the Service’s seven regional offices using a formula to estimate each 

region’s workload based on the number of species that the region is 

responsible for and a relative estimate of the cost to recover each species. 

This formula does not necessarily reflect the threats facing a species or its 

recoverability. Service officials told us that they use this formula because it 

provides relatively stable funding to each region—an important 

consideration because most of a region’s recovery budget supports staff 

salaries for recovery biologists. These biologists work on a variety of 

recovery activities including helping to develop recovery plans, 

coordinating recovery tasks and developing recovery partnerships. After 

headquarters allocates funds to the regional offices, the regional offices 

then allocate funds to the field offices, relying extensively on factors such 

as long-standing arrangements to work with partners to recover specific 

0

10

20

30

40

50

60

Recovery dollars in millions

Threat

Recoverability

Source: GAO analysis of Fish and Wildlife Service data.

High

High Low

Moderate

High Low

Low

High Low

High Low Priority

5%

1% 0%

28%

23%

44%
Page 5 GAO-05-211 Prioritizing Recovery Funds

species and other opportunities to have partners bring funding and 

resources to the recovery program. Officials throughout the Service told us 

that, in allocating funding, it is crucial to have flexibility to stray from the 

recovery priority guidelines to maximize recovery resources contributed 

through partnerships. However, the Service does not have a process to 

routinely measure the extent to which it is spending its recovery funds on 

high-priority species. As a result, the Service cannot be certain that it will 

continue to spend its recovery funds on the highest priority species as it 

attempts to maximize its partners’ contributions. In addition, because the 

Service does not separately report on how it spent its recovery funds by 

species, it cannot show Congress or the public the extent to which it is 

focusing its resources on the highest priority species, or explain, in cases 

where it is not, that its resource decisions are still appropriate. To make its 

allocation process more systematic and transparent, we recommend that 

the Service periodically assess the extent to which it is following its 

recovery priority guidelines, identify how factors other than those in the 

guidelines are affecting its funding allocation decisions, and report this 

information publicly. 

We provided the Department of the Interior with a draft of this report for 

review and comment. In general, the Department agreed with our findings 

and recommendations. The Department’s letter and our response to it is 

presented in appendix II. 

Background The purpose of the Endangered Species Act of 1973 is to conserve 

endangered and threatened species and the ecosystems upon which they 

depend. The act defines “conservation” as the recovery of endangered and 

threatened species so that they no longer need the protective measures 

afforded by the Act. The act defines as endangered any species facing 

extinction throughout all or a significant portion of its range and defines as 

threatened any species likely to become endangered in the foreseeable 

future. The act requires the Secretary of the Interior to publish a list of 

species it determines are endangered or threatened in the Federal Register 

and specify any critical habitat of the species with in its range—habitat 

essential to a species’ conservation. Loss of habitat is often the principal 

cause of species decline. Additionally, the act establishes a process for 

federal agencies to consult with the Service about their activities that may 

affect listed species. Federal agencies must ensure that their activities, or 

any activities they fund, permit or license, do not jeopardize the continued 

existence of a listed species or result in the destruction or adverse 

modification of its critical habitat. 
Page 6 GAO-05-211 Prioritizing Recovery Funds

There were 1,264 species in the United States listed as endangered or 

threatened as of September 30, 2004.7

 The Service has responsibility for 

1252 of these species. Thirty-two species have been removed from the list: 

9 species as a result of recovery efforts, 9 because they have been declared 

extinct, and 14 species for other reasons, mostly because new information 

showed that listing was no longer warranted.8

 

The Service develops and implements recovery plans, among other things, 

to reverse the decline of each listed species and ensure its long-term 

survival. A recovery plan may include a variety of methods and procedures 

to recover listed species, such as protective measures to prevent extinction 

or further decline, habitat acquisition and restoration, and other on-theground activities for managing and monitoring endangered and threatened 

species. According to Service officials, it is their policy to issue a recovery 

plan within two and a half years of the species’ date of listing. The Service 

exempts species from the plan requirement when it is determined a plan 

will not promote their conservation.9

 For example, the ivory-billed 

woodpecker is exempt because the Service thinks it is extirpated from the 

wild throughout its range. 

Recovery plans aim to identify the problems threatening the species and 

the actions needed to resolve them. The act directs the Service, to the 

maximum extent practicable, to incorporate into each recovery plan (1) a 

description of site-specific recovery tasks necessary to achieve the plan’s 

goal for the conservation and survival of the species; (2) objective 

measurable criteria that will result in a determination that the species can 

be removed from the list of endangered and threatened species (delisted); 

and (3) an implementation schedule that estimates the time and cost 

required to carry out the recovery tasks described in the recovery plan. 

Service employees, independent scientists, species experts, or a mix of 

7

This does not include foreign species—species whose current and historic range occurs 

entirely under the jurisdiction of other countries. 

8

Some species were delisted because new information showed the species to be more 

widespread or abundant than believed at the time the species was listed. Other species were 

delisted for taxonomic reasons, meaning that additional analysis found the species was not 

unique; for example, it was simply a population of another common species making it 

ineligible for listing. One species, the Hoover’s woolly-star, was delisted as a result of 

recovery actions and because of the availability of new information—specifically, a new 

population was discovered. We counted this species as one of the 9 species delisted as a 

result of recovery efforts. 

9

The Service does not require recovery plans for foreign species. 
Page 7 GAO-05-211 Prioritizing Recovery Funds

these people can develop recovery plans. According to Service officials, as 

of September 2004, the Fish and Wildlife Service had 551 approved 

recovery plans covering more than 1025 species (more than 80 percent of 

all listed species). 

The act also requires the Service to report biennially to certain 

Congressional committees on efforts to develop and implement recovery 

plans, and on the status of listed species for which plans have been 

developed. The Service implements this requirement through its biennial 

Recovery Report to Congress.

10 Additionally, the act requires the Service to 

submit an annual report to the Congress on federal expenditures for the 

conservation of endangered or threatened species, as well as expenditures 

by states receiving federal financial assistance for such conservation 

activities.11 As part of its efforts to compile data for this report, the Service 

collects data on recovery fund expenditures on a species-specific basis, 

although these data have not been reported separately in published 

expenditure reports. 

With regard to Service funds, the Endangered Species program is a small 

portion of the Service’s overall budget ($132 million of $1.9 billion in fiscal 

year 2003). Of this amount, about one-half is devoted to the recovery 

program, $65 million (see fig. 2). This is similar to previous fiscal years.12 

The funds spent on the recovery program, however, are only a portion of 

the total money spent to recover species. Some of the Service’s other 

programs, including refuges, contribute funds and staff to species recovery. 

In addition, according to the Service, other federal and non-federal entities 

contribute substantial funds to species recovery. 

10The latest report is Recovery Report to Congress, Fiscal Years 2001-2002; U.S. Fish and 

Wildlife Service.

11See, for example, Federal and State Endangered and Threatened Species Expenditures, 

Fiscal Year 2003, U.S. Fish and Wildlife Service. This is the most recent report available. 

12In fiscal years 2000, 2001 and 2002 the Service allocated, respectively, $56 million, $60 

million and $64 million in recovery funds. 
Page 8 GAO-05-211 Prioritizing Recovery Funds

Figure 2: The Fish and Wildlife Service’s Fiscal Year 2003 Budget

Note: Candidate species are plants and animals for which the Service has sufficient information on 

their biological status and threats to propose them as endangered or threatened under the 

Endangered Species Act, but for which development of a listing regulation is precluded by other higher 

priority listing activities. The Candidate Conservation Program provides a means for conserving these 

species.

In addition to the Service’s Endangered Species Program expenditures to 

recover species, other programs in the Service as well as other federal and 

state agencies spend substantial funds on endangered species activities, 

including land acquisition (see table 1). 

7%

Endangered Species 

Program

66

$132 million

Source: Fish and Wildlife Service and Department of the Interior budget information.

Total Service budget

0

30

60

90

120

150

Recovery - $65 million

Consultation - $47 million

3.5%

3.5%

Candidate conservation - 

$10 million

Listing - $9 million

Dollars in millions

$1.9 billion 
Page 9 GAO-05-211 Prioritizing Recovery Funds

Table 1: Total Reported Expenditures for All Endangered Species Activities and Fish 

and Wildlife Recovery Expenditures by Year for Fiscal Years 2000-2003

Source: Fish and Wildlife Service. 

Note: The source of data for the row “Total Reported Federal and State Expenditures on All 

Endangered Species Activities (including land acquisition)” is the Service’s fiscal year 2003 

expenditure report (Federal and State Endangered and Threatened Species Expenditures, Fiscal Year 

2003, U.S. Fish and Wildlife Service). In this report, the Service identifies a number of differences in 

reporting methods that make it difficult to compare expenditure data from different years. For example, 

prior to the fiscal year 2001 report, the Service did not include cost data that could not be attributed to 

a specific individual species. These data are now included, and partially explains the notable difference 

between the fiscal year 2000 and the fiscal year 2001 totals. The data contained in this row also 

include Service recovery fund expenditures. The source of data for the row “Service Recovery 

Expenditures” is unpublished data that the Service collected for its expenditure reports. The Fiscal 

year 2000 data does not include cost data that could not be attributed to a specific individual species 

while the fiscal year 2001-2003 data does. 

Congress amended the Endangered Species Act in 1979 to require the 

Secretaries of the Interior and Commerce to establish, and publish in the 

Federal Register, agency guidelines that include a priority system for 

developing and implementing recovery plans. The Service adopted 

recovery priority guidelines in 1980 and amended them in 1983.13 The 

guidelines consist of two parts:

In thousands of dollars

FY 2000 FY 2001 FY 2002 FY 2003

Total reported Federal and State 

Expenditures for All Endangered Species 

Activities (including land acquisition) 610,286 2,442,356 1,191,752 1,201,166

Service Recovery Expenditures 37,905 27,814 39,021 48,418

1348 Fed. Reg. 43098 (Sept. 21, 1983).
Page 10 GAO-05-211 Prioritizing Recovery Funds

• Species are assigned a priority ranking between 1 and 18 on the basis of 

(in descending order of importance) (1) the degree of threat confronting 

the species, (2) recovery potential (the likelihood for successfully 

recovering the species),14 and (3) taxonomy (genetic distinctiveness).15 

(See table 2.) Additionally, a “c” is added to the ranking if there is 

conflict with economic activities, like development; this gives the 

species priority over other species with the same ranking but without a 

“c”. Thus, the highest possible priority ranking is a “1c”. The Service 

sometimes changes a species’ priority ranking when warranted by a 

change in the species’ situation. 

Table 2: Fish and Wildlife Service’s Recovery Priority Ranking Schedule 

14According to the Service’s priority guidelines, the criteria used to determine recovery 

potential are how well the ecological processes and threats that affect the species are 

understood, how easily the threats can be alleviated, and whether intensive management is 

needed to recover the species. 

15According to the Service’s priority guidelines, the criterion related to taxonomy (genetic 

distinctiveness) is intended to devote resources on a priority basis to those species 

representing highly distinctive or isolated gene pools, as reflected by the taxonomic level at 

which they are recognized. 

Priority 

rank Degree of threat

Recoverability 

potential Taxonomy

1 High High Monotypic genus

2 High High Species

3 High High Subspecies

4 High Low Monotypic genus

5 High Low Species

6 High Low Subspecies

7 Moderate High Monotypic genus

8 Moderate High Species

9 Moderate High Subspecies

10 Moderate Low Monotypic genus

11 Moderate Low Species

12 Moderate Low Subspecies

13 Low High Monotypic genus

14 Low High Species

15 Low High Subspecies
Page 11 GAO-05-211 Prioritizing Recovery Funds

Source: Fish and Wildlife Service Endangered and Threatened Species Listing and Recovery Priority Guidelines.

Note: A species that is a monotypic genus is the only remaining species representing the entire genus.

• The second part of the priority system ranks the recovery tasks within 

each recovery plan. Each task is assigned a priority number from 1 to 3, 

with 1 being the highest. A priority 1 task is “an action that must be 

taken to prevent extinction or to prevent the species from declining 

irreversibly.” A priority 2 task is “an action that must be taken to prevent 

a significant decline in species population/habitat quality or some other 

significant negative impact short of extinction”, and a priority 3 task is 

“all other actions necessary to provide for full recovery of the species.”16

The recovery guidelines emphasize that they should be used only as a 

guide, not as an inflexible framework for determining funding allocations.

Within the Service, responsibility for implementing the act is divided 

among its three administrative levels: headquarters, regions and field 

offices. Headquarters officials develop policy and guidance and allocate 

funding to the regions. Regional directors in the seven regions (shown in 

figure 3) make most decisions on how to spend endangered species 

program funds and are responsible for managing their field offices’ 

program activities. Field offices are responsible for implementing program 

activities and setting priorities for projects they will undertake.

16 Low Low Monotypic genus

17 Low Low Species

18 Low Low Subspecies

16We did not assess how the Service’s allocation of recovery funds compares with task 

priority.

(Continued From Previous Page)

Priority 

rank Degree of threat

Recoverability 

potential Taxonomy
Page 12 GAO-05-211 Prioritizing Recovery Funds

Figure 3: Location of Fish and Wildlife Service’s Seven Regions 

Note: The U.S. Virgin Islands (not shown) is also part of the Southeast Region. 

Source: GAO's representation of information provided by the U.S. Fish and Wildlife Service.

Portland, Ore.

Denver, Colo.

Albuquerque, 

New Mexico

Anchorage, 

Alaska

Twin Cities, 

Minnesota

Atlanta, 

Georgia

Hadley, 

Massachusetts

Hawaii

Puerto Rico

Alaska

Pacific

Southwest Southeast

Northeast

Mountain - Prairie

Great Lakes - 

Big Rivers

Pacific

Southeast

Regional offices
Page 13 GAO-05-211 Prioritizing Recovery Funds

The Service Spends a 

Significant Portion of 

Recovery Funds on the 

Highest Priority 

Species

The Fish and Wildlife Service spent its recovery funds in a manner 

generally consistent with species priority in fiscal years 2000 through 2003. 

From fiscal years 2000 to 2003, the Service spent 44 percent of its recovery 

funds attributable to individual species on those species with the highest 

priority, the 415 species ranked 1 through 3 on the 18-point priority ranking 

scale (see fig. 4).17 However, 25 of these species received no recovery 

funding at all during fiscal years 2000 through 2003.18 Additionally, two 

species with low priority rankings, the bald eagle (with a priority ranking of 

14c) and the Canada lynx (with a ranking of 15), received substantial 

recovery funding during fiscal years 2000-2003. 

17There were 415 species ranked 1 through 3 at the end of fiscal year 2003. In fiscal years 

2000 through 2002 there were 395, 408 and 416 species ranked 1 through 3, respectively. Our 

analysis of species priority rankings considered species, subspecies and populations of 

species, as appropriate. For example, different wolf populations have different priority 

rankings. 

18Twenty-five of the 415 species ranked 1 through 3 in fiscal year 2003 received no funding 

attributable to individual species during fiscal years 2000-2003.
Page 14 GAO-05-211 Prioritizing Recovery Funds

Figure 4: Recovery Expenditures by Priority Ranking, Fiscal Years 2000-2003

Note: Percentages add to more than 100 percent due to rounding. Recovery expenditures on species 

with priority numbers 16-18 are less than one percent. 

0

10

20

30

40

50

60

Recovery dollars in millions

5%

1% 0%

28%

23%

44%

Recoverability

Threat

Priority ranking

Source: GAO analysis of Fish and Wildlife Service data.

High

High Low

Moderate

High Low

Low

High Low

1-3 4-6 7-9 10-12 13-15 16-18
Page 15 GAO-05-211 Prioritizing Recovery Funds

One reason the Service spent 44 percent of its recovery funds attributable 

to individual species on the highest priority species is that this group 

accounts for a significant portion of all listed species—one-third (see fig. 

5). Similarly, the Service spent almost all (94 percent) of its attributable 

recovery funds on species ranked 1 through 9 on the 18-point scale, which 

account for 92 percent of all listed species.

Figure 5: Distribution of Species by Priority Ranking as of September 2003

Note: The distribution of species by priority ranking in fiscal years 2000, 2001 and 2002 is not 

substantially different from the distribution in fiscal year 2003, see app I. 

35.9%

22.8%

33.3%

Ranking 13-15 (48 species)

3.8%

Ranking 16-18 (6 species)

0.5%

Ranking 10-12 (47 species)

3.8%

Ranking 1-3 (415 species)

Priority ranking:

Source: GAO analysis of Fish and Wildlife Service data.

Ranking 7-9 (284 species)

Ranking 4-6 (448 species)
Page 16 GAO-05-211 Prioritizing Recovery Funds

As shown in figure 6, analysis of average spending on a per species basis 

also reveals that more expenditures are made on higher priority species. 

Additionally, the analysis shows the emphasis the Service placed on species 

with a high degree of recoverability. The relatively large amount of funding 

spent on species with low priority rankings (13 through 15) is greatly 

influenced by spending on the bald eagle (with a priority ranking of 14c) 

and the Canada lynx (with a ranking of 15). The bald eagle is nearing 

delisting and the funding was spent on delisting activities. The Canada lynx 

was embroiled in controversy that required recovery staff to respond to 

litigation. When spending on these two species is removed, the average 

amount spent on species in this priority group is significantly lower.

Figure 6: Weighted Average Per Species Expenditure, by Priority Ranking, Fiscal 

Years 2000-2003

Recoverability

Threat

Priority ranking

Source: GAO analysis of Fish and Wildlife Service data.

High

High Low

Moderate

High Low

Low

High Low

1-3 4-6 7-9 10-12 13-15 16-18

Recovery dollars in thousands

Funding for 

Canada lynx 

and bald eagle

0

5

10

15

20

25

30

35
Page 17 GAO-05-211 Prioritizing Recovery Funds

In addition to species priority ranking, another obvious measure of priority 

is whether a species is endangered or threatened. Over three-quarters (78 

percent) of species protected under the act are listed as endangered, and 

most of these have high priority rankings (see fig. 7). We analyzed spending 

by species status (endangered or threatened) and found that the Service 

spent a majority (64 percent) of its recovery funds on endangered species 

during fiscal years 2000 through 2003.19

Figure 7: Distribution of Endangered and Threatened Species by Priority Ranking as 

of September 2003 

19This analysis compares spending in fiscal years 2000 through 2003 with species status as of 

September 30, 2003. Between fiscal years 2000 and 2003, the Service changed the status of 

only two domestic species, both from endangered to threatened. The species were the largeflowered skullcap and two populations of the gray wolf.

Recoverability

Endangered

Threatened

Threat

Priority ranking

Source: GAO analysis of Fish and Wildlife Service data.

High

High Low

Moderate

High Low

Low

High Low

1-3 4-6 7-9 10-12 13-15 16-18

Number of species

0

100

200

300

400

500
Page 18 GAO-05-211 Prioritizing Recovery Funds

Finally, we analyzed spending by the three taxonomic classifications 

included in the Service’s recovery priority guidelines—monotypic genus, 

species, and subspecies. As shown in figure 8, an analysis of average 

spending on a per species basis reveals that more expenditures are made 

on listed entities classified as monotypic genus. A species that is a 

monotypic genus is the only remaining species representing the entire 

genus. 

Figure 8: Weighted Average Per Species Expenditures, by Taxonomic Classification, 

Fiscal Years 2000-2003 

0

10

20

30

40

50

60

70

80

Recovery dollars in thousands

Source: GAO analysis of Fish and Wildlife Service data.

Monotypic 

genus

Species Sub-species

Priority 

ranking

1, 4, 7, 10, 

13, 16

2, 5, 8, 11, 

14, 17

3, 6, 9, 12, 

15, 18
Page 19 GAO-05-211 Prioritizing Recovery Funds

The Service Considers 

Factors Besides 

Species Priority When 

Allocating Recovery 

Funds but Does Not 

Assess the Results of 

Its Funding Decisions 

When Service officials allocate recovery funds, they base these decisions to 

a significant extent on factors other than a species’ priority ranking. At the 

headquarters level, a formula that accounts for each region’s workload, but 

not species’ priority rankings, determines how recovery funds are 

allocated. Each regional office allocates recovery funds to their field 

offices differently, but in no case is priority ranking the driving factor. 

Instead, regional officials focus primarily on partnership opportunities, 

though regional officials told us they do try to provide funds to species that 

have a high degree of threat. Although field office staff we spoke with use 

priority rankings, they also emphasized the importance of having flexibility 

to allocate funds to develop partnerships. The Service does not know the 

extent to which these disparate allocation systems yield results consistent 

with the Service’s priority guidelines because the Service does not have a 

process to routinely measure the extent to which it is spending its recovery 

funds on higher priority species. 

Headquarters Allocates 

Funds to the Regions Based 

on Workload

In making allocation decisions, headquarters does not consider a species’ 

priority ranking or any of the factors that go into determining priority 

rankings. Instead, it allocates recovery funds to its seven regions based 

primarily on a formula that estimates each region’s workload.20 The 

formula estimates the recovery workload for each region by assigning each 

species a score of between 2 and 7 points, based on the type of species and 

its habitat needs. Higher points are assigned to those species whose 

recovery requires higher levels of funding or effort—factors that are not 

clearly related to a species’ priority ranking. For example, animals are 

assigned 2 points while plants are assigned 1. Species that occupy habitats 

larger than 1 million acres or are migratory or aquatic are assigned 5 points 

whereas species that occupy less than 1,000 acres are assigned 1 point. 

Recovery funds are then allocated to the regions based on the number of 

species occurring in each region and the points assigned to those species. 

Additionally, headquarters uses a workload-based formula to allocate funds 

to regions to develop recovery plans. Funds are allocated to each region 

based on the number of species that it is responsible for that have not been 

20Some funds are not allocated according to this formula. For example, headquarters sets 

aside approximately $1,000,000 for delisting and downlisting activities and approximately 

$1,000,000 for “capability funding” annually. Capability funding is used to help staff in each 

region maintain a basic competency in recovery-related tasks. Additionally, the Service 

allocates some funds based on direction provided it by Congress, for example, through 

appropriation committee conference reports. 
Page 20 GAO-05-211 Prioritizing Recovery Funds

exempted from the plan requirement and that have been listed for 4 years 

or less. If after 4 years there is still no plan, then the region no longer 

receives recovery-planning money for that species, though the region is still 

responsible for completing that species’ recovery plan. 

Service officials in headquarters told us that they use an allocation system 

based on workload rather than the priority guidelines for a number of 

reasons. First, this system provides relatively stable funding to each region 

from year to year. In contrast, priority rankings can change over time, 

which would add an element of unpredictability to the annual allocations. 

Stability is important, according to Service officials, because most of a 

region’s recovery budget supports staff salaries for recovery biologists. 

These biologists work on a wide variety of recovery activities including 

helping to develop recovery plans, conducting as well as coordinating onthe-ground actions to implement recovery plans, conducting periodic 

species status reviews, developing recovery partnerships, and litigation 

support. Second, although priority rankings indicate which species are 

higher priority, they do not reflect how much money a species needs. 

Service officials pointed out that higher priority species are not necessarily 

more costly to recover than lower priority species. Lastly, Service officials 

told us that a system based on workload is more objective, and they 

expressed concern that the subjective nature of priority rankings could 

create conflict between the regions if allocations were based on these 

rankings. While Service officials at headquarters told us that recovery 

funds should be spent according to priority rankings, they believe those 

decisions should be made at the regional level. 

Almost all of the regional officials we talked to agreed that the allocation 

system used by headquarters works well and is fair and equitable, although 

some of them suggested changes. For example, some regional and field 

office officials noted that a species’ priority ranking, particularly its degree 

of threat, could be included, along with the existing workload factors, in 

headquarters’ formula for allocating recovery funds. 

Regional Offices Focus on 

Opportunities for 

Partnerships When Making 

Funding Decisions

While each region allocates recovery funds to its field offices differently, 

we found that the most important consideration among the regions is to 

maintain and develop recovery partnerships, either by funding longstanding arrangements to work with partners to recover specific species or 

by taking advantage of opportunities to develop new partnerships. For 

example, officials at the Southwest region told us that for the last 10 years 

the region has allocated its discretionary recovery funds primarily to four 
Page 21 GAO-05-211 Prioritizing Recovery Funds

species for which it has long-standing partnerships with other entities—the 

Kemp’s Ridley sea turtle, the whooping crane, the Mexican wolf and the 

Attwater’s prairie chicken.21 The financial support from long-term partners, 

in concert with expenditures from the Service, provides a stable funding 

source for recovery projects from year to year, helping to create viable 

recovery programs for these four species. For example, the Kemp’s Ridley 

sea turtle population has increased from a low of 270 females to several 

thousand females in the course of this long-term partnership. 

Service officials told us that it is important to maintain their yearly 

contributions to long-standing partnerships, regardless of the species’ 

priority ranking, because the funds these partners contribute are critical to 

species’ recovery and the partners could lose interest without the Service’s 

contributions. Officials at all levels of the Service reported to us that they 

have insufficient recovery funds. Although it is difficult to develop an 

accurate estimate of the full cost to recover all listed species (and it is 

unlikely that some species will ever be recovered), we analyzed the cost 

data contained in 120 recovery plans covering an estimated 189 listed 

species.22 Based on the Service’s estimated recovery costs in these plans, 

we found that it would cost approximately $98 million dollars to fully fund 

these plans—plans that cover just 15 percent of listed species—for a single 

year.23 This amount is well above the $65 million the Service allocated in 

fiscal year 2003 to develop and implement recovery plans and does not 

account for the recovery needs of the remaining 1000 listed species. Even 

implementing only the highest priority recovery plan tasks for those 120 

plans—recovery plan tasks “necessary to avoid extinction,” would cost 

approximately $57 million, nearly 90 percent of the Services’ total recovery 

budget in fiscal year 2003. Consequently, the Service is dependent on 

monetary contributions from partners to facilitate species recovery. 

Regional officials not only fund long-standing partnerships, but look for 

opportunities to develop new ones as well. Service officials expressed 

concern that if they were confined to allocating funds strictly by the 

21Discretionary recovery funds are those funds left after the region covers salaries, benefits, 

directives from headquarters, including items funded at the direction of Congress. 

22These 120 plans were the ones for which the Service provided us with electronic versions 

of the plans’ implementation schedules, which enabled us to complete this analysis. 

23We calculated this number by determining the average cost to implement each plan based 

on the cost data in the plan and then summed the averages. This figure does not include all 

estimated recovery costs, particularly land acquisition costs, which can be expensive.

Source: U.S. Fish and Wildlife Service.

Source: U.S. Fish and Wildlife Service.

Source: Bill Reaves, Texas Parks and Wildlife.
Page 22 GAO-05-211 Prioritizing Recovery Funds

priority system, they could alienate potential recovery partners. For 

example, some regional officials pointed out that land acquisition can take 

many years, so if willing sellers present themselves, the region will take 

advantage of that opportunity by allocating recovery funds to acquire those 

lands even if they do not benefit a species of the highest priority. In another 

example, officials in a field office in the Pacific region told us they were 

able to leverage its $20,000 investment into a $60,000 project by developing 

an agreement with the U.S. Forest Service to jointly fund a study to identify 

how the California red-legged frog was using suitable habitat. Fish and 

Wildlife Service officials in the Pacific region also leverage funds with nonfederal partners. In 2002, a $10,000 investment in desert tortoise monitoring 

from the Fish and Wildlife Service was matched by $16,540 from Clark 

County, Nevada and $5,000 from the Arizona Game and Fish Department. 

Almost all of the Service officials we talked with stressed the importance of 

having the flexibility to develop partnerships for recovery, particularly to 

leverage the Service’s scarce recovery funds.24 Finding partners and other 

sources of funds to implement recovery actions is also strongly emphasized 

in the Service’s course on recovery implementation, which is offered at the 

National Conservation Training Center in West Virginia and other locations 

around the country. 

While a species’ priority ranking is not a primary factor for determining 

how regions distribute recovery funds, regions do consider priority 

rankings when making recovery allocations. The two regions responsible 

for the most species, the Southeast region and the Pacific region, 

specifically incorporate the priority system into their funding allocations. 

In the Southeast, field offices and other divisions of the Service, like 

Refuges,25 submit proposals to obtain recovery funding to implement 

recovery plan tasks. Once the regional office receives all the proposals, 

officials determine which ones to fund that year. In doing so, they consider 

a number of factors, including the species’ priority ranking. Similarly, the 

Pacific regional office reserves a portion of the recovery funds it receives 

and uses them to fund proposals submitted by its field offices to implement 

recovery plan tasks. One of the factors the region considers when 

determining which proposals to fund is the species’ priority ranking. Most 

of the other regions we talked to told us that they consider some aspects of 

24We were not able to quantify all funds provided by federal and non-federal partners in 

implementing recovery actions because they do not maintain expenditure data in this way.

25Refuges are a division of the Service that is responsible for managing National Wildlife 

Refuges. 

Source: U.S. Fish and Wildlife Service.
Page 23 GAO-05-211 Prioritizing Recovery Funds

the priority system when making funding decisions, particularly the 

species’ degree of threat, although they do not directly consider a species’ 

priority ranking. 

Sometimes regions will also target funds to lower--priority species if they 

are nearing recovery.26 For example, the bald eagle ranked 20th among 

those species with the highest recovery expenditures from fiscal year 2000 

to fiscal year 2003, despite having a priority ranking of 14c. A Service 

official attributed most of these expenditures to delisting activities for the 

bald eagle. Many Service officials pointed out that the priority system does 

not contain a mechanism for funding species that are nearing recovery. 

Because a species’ priority will decrease as its threats are alleviated and it 

moves closer to recovery, the priority system would dictate that other more 

imperiled species be funded before those that are close to delisting. 

Consequently, species close to recovery might never be delisted because 

funds would not be allocated to complete the tasks required for delisting. 

Service officials told us they need flexibility to provide funds that will help 

get species off the list. Headquarters officials have also recognized this 

issue and, beginning in fiscal year 2004, created a special fund that directs 

funding to species close to delisting (as well as those close to extinction) in 

its “Showing Success, Preventing Extinction” initiative. 

Field Offices We Talked to 

Use the Priority System 

When Making Funding 

Allocations

In the field offices we contacted, we found that species’ priority rankings 

play an important role in recovery allocations. Service personnel in four of 

the ten field offices we spoke with told us that a species’ priority ranking is 

one of the key factors they use to allocate recovery funds.27 For example, in 

the Pacific Islands field office, which is responsible for the recovery of over 

300 species, officials use the recovery priority system as a “first step,” then 

overlay other factors, like opportunities to leverage funding. Staff in five of 

the remaining six offices we spoke with told us that while they do not 

specifically use the priority system when making recovery allocations, they 

do consider a species’ degree of threat. Staff in the last field office said they 

did not use the priority system because most of their funds were spent 

according to direction provided by the region. 

26These funds may come from the $1,000,000 headquarters sets aside for delisting and 

downlisting or they may come from the region’s recovery budget.

27According to Service officials, there are approximately 70 field offices that have lead 

responsibility for recovering species.
Page 24 GAO-05-211 Prioritizing Recovery Funds

Despite their use of the priority system, most of the field office staff we 

contacted also stressed the importance of having the flexibility to allocate 

funds to take advantage of unique opportunities when they arise. For 

example, officials in a field office in California told us they took advantage 

of an opportunity to leverage recovery funding for the California red-legged 

frog. A population of this frog was recently discovered in Calaveras County, 

site of Mark Twain’s famous story The Celebrated Jumping Frog of 

Calaveras County, which featured the California red-legged frog. The 

landowner where the population was discovered was eager to work with 

the Service to build a stock pond to provide habitat for the red-legged frog 

and eradicate bullfrogs (red-legged frog competitors). The discovery of the 

frog population was momentous because the species is important to local 

lore, and a population of the frog had not been found in Calaveras County 

since the late 1800s (see fig. 9). Even though the field office has 65 species 

with higher priority rankings than the red-legged frog,28 officials decided to 

address this recovery opportunity because of the frog’s importance to the 

local community. Other unique events also require funding flexibility. In a 

Utah field office last year, for example, a road expansion threatened the 

existence of the clay phacelia, an endangered plant. The field office staff 

responded to this threat by working with partners to collect seeds for 

future propagation. 

28This California field office has the lead responsibility for 104 species.
Page 25 GAO-05-211 Prioritizing Recovery Funds

Figure 9: The California Red-Legged Frog Is Important to a California Community 

Due to Its Prominence in a Famous Mark Twain Story 

The Service Does Not 

Assess and Report on Its 

Recovery Fund 

Expenditures 

The Service does not know the extent to which recovery fund expenditures 

are consistent with its priority guidelines. All of the Service’s organizational 

levels participate in funding decisions, often relying on factors other than 

species priority. Although our analysis shows that the Service generally 

spent its recovery resources on higher priority species during fiscal years 

2000 through 2003, we found that the Service has no process to routinely 

measure the extent to which it is spending its recovery funds on higher 

priority species. Without this information, the Service cannot ensure that it 

is spending its recovery funds on such species, and in cases where it is not, 

Source: U.S. Fish and Wildlife Service.
Page 26 GAO-05-211 Prioritizing Recovery Funds

determine whether the funding decisions are appropriate. This is especially 

problematic as circumstances change—for example, when species are 

added to the list or priority rankings change for already-listed species.

Although the Service is required to report all federal and some state 

expenditures on listed species,29 it does not separately report how it spent 

its recovery funds by species. This lack of separate reporting can make it 

difficult for Congress and others to determine whether the Service is 

focusing its recovery resources on the highest-priority species. For 

example, the species that received the greatest total federal and state 

expenditures in fiscal year 2003 are substantially different from those we 

identified as having received the greatest portion of the Service’s recovery 

fund expenditures. Of the 47 species that the Service reported as having 

received the greatest total expenditures in fiscal year 2003,30 the Service 

has joint or lead responsibility for 20 of them. The list of 20 species is 

radically different from the list that we identified as having received the 

greatest portion of the Service’s recovery fund expenditures (see table 3). 

In the case of the Southwestern willow flycatcher, the Service reported that 

more funds were expended on the flycatcher in fiscal year 2003 than for all 

but three other species for which the Service has lead responsibility. 

However, the information the Service provided to us shows that it spent 

relatively few recovery funds on the Southwestern willow flycatcher in 

fiscal year 2003—it ranked 84th in the Service’s recovery expenditures. 

29The act requires the Service to submit to Congress by January 15th an annual report 

covering the preceding fiscal year containing an accounting on a species by species basis of 

all reasonably identifiable federal expenditures made primarily for the conservation on 

endangered or threatened species pursuant to the act. The act also requires the Service to 

report similar expenditure information for states receiving grants under section 6 of the act. 

30See Federal and State Endangered and Threatened Species Expenditures, Fiscal Year 

2003. This is the most recent report available. 
Page 27 GAO-05-211 Prioritizing Recovery Funds

Table 3: Total Reported Expenditures for All Endangered Species Activities Compared to Fish and Wildlife Service’s Recovery 

Expenditures During Fiscal Year 2003—for Top 20 Species

Source: GAO analysis of Fish and Wildlife Service data.

Note: The source of data for the column “Total Reported Federal and State Expenditures on All 

Endangered Species Activities” is the Service’s fiscal year 2003 expenditure report (Federal and State 

Endangered and Threatened Species Expenditures, Fiscal Year 2003, U.S. Fish and Wildlife Service). 

We excluded species for which the National Marine Fisheries Service has sole responsibility. We 

combined expenditures for experimental and non-experimental populations when a listed entity had 

both. The data include Service recovery fund expenditures. The source of data for the column “Service 

Recovery Fund Expenditures” is data reported to us by each of the Service’s regional offices. We did 

not determine the extent to which recovery fund expenditures reported to us correspond with those 

included in the Service’s published expenditure report. 

Species name 

Priority

ranking

Total reported federal

and state

expenditures on all

endangered species

activities

Rank by total reported

federal and state

expenditures on all

endangered species

activities

Service recovery fund

expenditures

Rank by service

recovery fund

expenditures

Bull trout 9c $29,295,633 1 $2,063,748 2

Rio Grande silvery 

minnow

2c 11,300,700 2 220,000 37

Red-cockaded 

woodpecker

8c 11,069,069 3 505,676 18

Southwestern willow 

flycatcher

3c 9,909,284 4 54,160 84

West Indian manatee 5c 9,798,514 5 996,457 4

Bald eagle 14c 7,831,531 6 239,866 31

Colorado pikeminnow 

(=squawfish)

8c 7,262,592 7 225,009 35

Razorback sucker 1c 7,127,470 8 242,733 30

Desert tortoise 8c 6,522,281 9 223,064 36

Florida panther 6c 6,301,276 10 135,869 50

Atlantic salmon 6c 5,832,648 11 9,350 202

Louisiana black bear 9 5,613,874 12 193,107 42

Grizzly bear 3c 5,469,681 13 571,461 15

Mexican spotted owl 9c 5,443,009 14 40,000 110

Indiana bat 8 5,218,103 15 256,750 28

White sturgeon 3c 5,197,021 16 21,900 148

Humpback chub 2c 5,072,205 17 234,270 33

Northern spotted owl 3c 5,053,263 18 845,418 7

Whooping crane 2c 5,029,588 19 589,912 14

Loggerhead sea turtle 7c $4,767,416 20 $270,623 26
Page 28 GAO-05-211 Prioritizing Recovery Funds

Total reported expenditures and Service recovery fund expenditures differ 

substantially because the Service’s recovery priority guidelines do not 

apply to most of the reported funds—those funds provided by other federal 

agencies and some funds reported by state agencies.31 The Service has little 

control over how other organizations spend their funds. The reported 

expenditures also include Service expenditures in addition to recovery 

funds, such as expenditures on listing and consultation, which are also not 

subject to the Service’s recovery guidelines. In fact, in many instances, the 

Service does not have discretion over which species should receive these 

funds. For example, the Service spends consultation funds largely based on 

projects submitted to it by other federal agencies.

Not unexpectedly, the list of 20 species receiving the greatest portion of the 

Service’s recovery fund expenditures in fiscal year 2003 is also different 

from the list of species receiving the greatest portion of total federal and 

state expenditures in fiscal year 2003 (see table 4). For example, the 

California condor and the Western population of the gray wolf ranked first 

and third, respectively in recovery fund expenditures but are ranked 25th

and 29th, respectively in overall federal and state expenditures. 

31One exception is grants made to states. The act authorizes the Service to provide financial 

assistance to states to assist in the development of programs for the conservation of 

endangered and threatened species and for other reasons. The Service considers recovery 

priority rankings when awarding these grants. 
Page 29 GAO-05-211 Prioritizing Recovery Funds

Table 4: Fish and Wildlife Service’s Recovery Expenditures Compared to Total Reported Expenditures on All Endangered 

Species Activities During Fiscal Year 2003—for Top 20 Species

Soure: GAO analysis of Fish and Wildlife Service data.

Note: The source of data for the column “Total Reported Federal and State Expenditures on All 

Endangered Species Activities” is the Service’s fiscal year 2003 expenditure report (Federal and State 

Endangered and Threatened Species Expenditures, Fiscal Year 2003, U.S. Fish and Wildlife Service). 

We excluded species for which the National Marine Fisheries Service has sole responsibility. We 

combined expenditures for experimental and non-experimental populations when a listed entity had 

both. The data include Service recovery fund expenditures. The source of data for the column “Service 

Recovery Fund Expenditures” is data reported to us by each of the Service’s regional offices. We did 

not determine the extent to which recovery fund expenditures reported to us correspond with those 

included in the Service’s published expenditure report. 

Species name

Priority

ranking

Service recovery fund

expenditures

Rank by service

recovery fund

expenditures

Total reported federal

and state

expenditures on all

endangered species

activities

Rank by total reported

federal and state

expenditures on all

endangered species

activities

California condor 4c $2,810,000 1 $3,526,183 25

Bull trout 9c 2,063,748 2 29,295,633 1

Gray Wolf, Western 

Distinct Population 

Segment 3c 1,789,940 3 3,261,662 29

West Indian Manatee 5c 996,457 4 9,798,514 5

Red wolf 5c 951,345 5 993,080 63

Puerto Rican parrot 2 900,000 6 1,419,800 50

Northern spotted owl 3c 845,418 7 5,053,263 18

Gray Wolf, 

Southwestern Distinct 

Population Segment 

(Mexican wolf) 3c 800,000 8 934,170 66

Steller’s eider 9 799,600 9 1,062,836 60

Giant garter snake 2c 724,038 10 1,561,474 46

Marbled murrelet 3 677,739 11 4,754,652 21

Bog turtle 6c 655,880 12 1,542,655 47

Virgin River chub 2c 631,751 13 462,136 96

Whooping crane 2c 589,912 14 5,029,588 19

Grizzly bear 3c 571,461 15 5,469,681 13

Karner blue butterfly 5 533,080 16 1,179,941 57

Spectacled eider 5 520,900 17 574,980 86

Red-cockaded 

woodpecker 8c 505,676 18 11,069,069 3

Black-footed ferret 2 451,859 19 2,360,970 40

Western snowy plover 3c $451,786 20 $2,824,184 35
Page 30 GAO-05-211 Prioritizing Recovery Funds

Without a process to measure the extent to which it is spending its 

recovery funds on the highest-priority species, the Service lacks valuable 

information that would aid it in making management decisions. For 

example, while maintaining partnerships to fund certain species may be 

reasonable, many of these partnerships have been in place for many years, 

and changes to the species’ status or threat level, as well as changes to the 

threat level of other species and the addition of newly listed species, could 

have occurred in that time. As such, perhaps the reasons for creating some 

of these partnerships may have been superseded by other needs and it may 

no longer be appropriate for particular species to garner so much funding 

from the region. Officials in the Southwest region, for instance, told us that 

most of the region’s discretionary recovery funds are spent on four species 

(Kemp’s Ridley sea turtle, Whooping crane, Mexican wolf, and Attwater’s 

prairie chicken). These officials stated that they did not know these 

species’ recovery priority rankings until after we scheduled a meeting with 

them, although they did believe the species to be highly ranked. While these 

four species all have high priority rankings—2c, 2c, 3 and 3c, respectively—

the region has lead responsibility for about 80 other species with a priority 

ranking between 1 and 3. Although many of these species also received 

funding during fiscal years 2000-2003, more than one-quarter (20 species) 

had no Service recovery fund expenditures attributable to them.

Conclusions The Service faces a very difficult task—recovering more than 1,200 

endangered and threatened species to the point that they no longer need 

the protection of the Endangered Species Act. Many of these species face 

grave threats and have been imperiled for years. There are few easy 

solutions. Like many other federal agencies, the Service has limited funds 

with which to address these challenges. Fortunately, many other 

organizations contribute resources to help species. The Service maintains 

that its ability to be flexible in allocating its scarce recovery resources is 

the key to maximizing those contributions from other organizations. We 

agree that exercising flexibility in allocating recovery funds under its 

priority guidelines is important, but this needs to occur within the bounds 

of a systematic and transparent process. The Service, however, does not 

have such a process. While the Service acknowledges that it strays from its 

priority guidelines, it does not routinely analyze its allocation decisions to 

determine whether it is focusing on the highest priority species and, if not, 

why. Such an analysis is important to ensure that the Service continues to 

spend its recovery funds on the highest priority species over the long term. 

Without this information, the Service cannot show Congress or the public 

the extent that it is focusing its resources on the highest priority species, or 
Page 31 GAO-05-211 Prioritizing Recovery Funds

explain, in cases where it is not, that its resource decisions are still 

appropriate. 

To this end, we believe the Service’s priority guidelines provide it with the 

means to create a systematic and transparent allocation process while still 

allowing it needed flexibility. Because the Service already collects data, on 

a species by species basis, on how it spends its recovery funds, it would be 

a simple task to measure the extent to which it is spending its recovery 

funds on high-priority species. It could then make this information publicly 

available, thus providing the Congress and the public a yardstick with 

which to judge the efficacy of the Service’s resource allocation decisions. 

Recommendations for 

Executive Action

To help ensure that the Service allocates recovery resources consistent 

with the priority guidelines over the long term and in a transparent fashion, 

we recommend that the Secretary of the Interior require the Service to take 

the following two actions: (1) periodically assess the extent to which it is 

following its recovery priority guidelines and identify how factors other 

than those in the guidelines are affecting its funding allocation decisions, 

and (2) report this information publicly, for example, in its biennial 

recovery report to Congress.

Agency Comments and 

Our Evaluation

We received written comments on a draft of this report from the 

Department of the Interior. In general, the Department agreed with our 

findings and recommendations but believes that we underestimated the 

extent to which the Service’s funding decisions are consistent with its 

recovery priority guidelines. Because we found that the Service spent its 

recovery funds in a manner generally consistent with species priority, we 

do not believe this is a significant issue. See appendix II for the 

Department’s letter and our response to it. Additionally, the Department 

provided technical comments that we have incorporated into the report, as 

appropriate. 

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

this report earlier, we plan no further distribution until 30 days from the 

report date. At the time, we will send copies of this report to the Secretary 

of the Interior and other interested parties. We also will make copies 

available to others upon request. In addition, the report will be available at 

no charge on the GAO web site at http://www.gao.gov. 
Page 32 GAO-05-211 Prioritizing Recovery Funds

If you or your staff have any questions, please call me at (202) 512-3841. 

Key contributors to this report are listed in appendix III. 

Robin M. Nazzaro

Director, Natural Resources

and Environment
Page 33 GAO-05-211 Prioritizing Recovery Funds

Appendix I

Scope and Methodology ApApenednxidexiIs

In response to a request from the Chairman, House Committee on 

Resources, we (1) analyzed how the U.S. Fish and Wildlife Service’s 

allocation of recovery funds compares with its recovery priority guidelines 

and (2) determined what factors influence the Service’s recovery funding 

allocation decisions. As agreed with the Chairman’s staff, we evaluated 

only those funds specifically spent by the Service to implement its recovery 

program. 

To address our first objective, we requested recovery expenditure data, on 

a per species basis, from each of the Service’s seven regions for fiscal years 

2000-2003.1

 Because the Service spends most of its recovery funds on 

salaries that are not allocated on a per species basis, we asked officials in 

each region to attribute salaries to specific species to the best of their 

abilities. To assess the reliability of these data, we compared the total 

estimated expenditures we received from each region for each year to 

budget documentation provided by headquarters officials, the Department 

of the Interior’s Budget for fiscal years 2000-2003, and House and Senate 

committee reports for Department of the Interior appropriations for fiscal 

years 2000-2003. We also asked the regional officials who provided these 

data a series of data reliability questions covering issues such as data entry, 

access, quality control procedures, and the accuracy and completeness of 

the data, as well as any limitations of the data. All responded that the data 

were generally accurate, and all but one performed some form of data 

review to ensure its accuracy. Additionally, officials from all but one region 

noted, as a limitation to the data, that it is sometimes difficult to link 

expenditures on activities to specific species. We determined that the 

expenditure data received from each of the Service’s seven regions were 

sufficiently reliable for the purposes of this report.

We also obtained from the Service data on each species’ priority number 

for fiscal years 2000 through 2003, as well as other information about each 

species, such as whether it is threatened or endangered and whether it has 

a recovery plan. We did not make a judgment about the adequacy or 

accuracy of the Service’s recovery priority system. The Service also 

provided us with information on the estimated costs to implement 

approximately 120 recovery plans. We assessed the reliability of these data 

by (1) electronically testing required data elements, (2) reviewing existing 

1

Similar data collected by the Service for its fiscal year 2001, 2002, and 2003 expenditure 

reports became available in January 2005—too late to be used for most of the analyses in 

this report. 
Appendix I

Scope and Methodology

Page 34 GAO-05-211 Prioritizing Recovery Funds

information about the data and the system that produced them, and (3) 

interviewing agency officials knowledgeable about the data. In addition, we 

compared the data set sent to us by the Service to the Service’s publicly 

available (online) Threatened and Endangered Species System (TESS), 

which contains data on listed species similar to that we received from the 

Service. When we identified any difference between these two data sets, we 

independently corroborated, to the extent possible, which data set was 

correct by obtaining documentary evidence, either from the Federal 

Register or the appropriate recovery plan. When appropriate according to 

this documentary evidence, we made changes to the data sent to us by the 

Service. For example, the spineless hedgehog cactus was listed in the data 

set sent to us by the Service but was not found when we compared it to 

online TESS. We checked the Federal Register and found that this species 

was removed from the endangered species list in 1993, so we removed it 

from the data set sent to us by the Service because our time frame of 

interest is 2000 through 2003. In another instance, the data set sent to us by 

the Service contained the Berkeley kangaroo rat, but this species was not 

in TESS. We checked the recovery plan and found that this is a “species of 

concern,” not an endangered or threatened species. The status field in the 

data sent to us by the Service was blank, so we re-coded it as a species of 

concern and then removed it from the data set because species of concern 

are not part of our review. We also made changes to records that contained 

errors. For example, the green sea turtle has two different populations. 

However, the Fish and Wildlife Service reported the total recovery 

expenditures for these two populations together. When expenditures were 

merged with species lists, this expenditure total was shown twice. To 

address that error we removed one expenditure total. All of these types of 

changes, 5 records with factual errors (or 0.4 percent of the records) and 9 

with missing information (0.7 percent of the records), were reviewed and 

agreed to by all team analysts and supervisors. We also found and removed 

14 duplicates and 27 records that were outside our scope (e.g., outside our 

date range or species managed by the National Marine Fisheries Service, 

not the Fish and Wildlife Service). On the basis of all of this work, we 

determined that the data on species and recovery plans we received from 

Fish and Wildlife Service were sufficiently reliable for the purposes of this 

report. 

We then compared the expenditures on each species with the species’ 

priority ranking for fiscal year 2000 through 2003. We grouped together 

species with similar rankings to deemphasize minor differences in species’ 

rankings. Grouping species this way had the effect of eliminating the 
Appendix I

Scope and Methodology

Page 35 GAO-05-211 Prioritizing Recovery Funds

taxonomic distinction among species found in the recovery priority 

guidelines. Table 5 shows the groupings.

Table 5: GAO Groupings of Priority Numbers

Source: GAO.

We also assumed that the average cost to implement recovery plans in each 

group was the same. We made this assumption explicitly because the cost 

to implement individual recovery plans can vary substantially among 

species. For example, we analyzed the cost to implement 120 recovery 

plans (the only plans with these data available electronically) covering an 

estimated 189 species (or 15 percent of listed species) and found that some 

plans are very costly—$107,516,000—and some are not—$18,000. However, 

many plans fall between these two extremes, costing between $1 million 

and $6 million. We discussed this assumption with the Service, and they 

agreed to its reasonableness. 

GAO group Priority number

1, 1c

GAO group 1 2, 2c

3, 3c

4, 4c

GAO group 2 5, 5c

6, 6c

7, 7c

GAO group 3 8, 8c

9, 9c

10, 10c

GAO group 4 11, 11c

12, 12c

13, 13c

GAO group 5 14, 14c

15, 15c

16, 16c

GAO group 6 17, 17c

18, 18c
Appendix I

Scope and Methodology

Page 36 GAO-05-211 Prioritizing Recovery Funds

The number of species in each priority group varied by year (see table 6).

Table 6: Number of Species in Each Priority Group, by Year

Source: GAO analysis of Fish and Wildlife Service data.

In order to analyze overall average spending on a per species bases, we 

calculated weighted average expenditures per species by priority ranking. 

To do this we weighted the average expenditure per species for a specific 

priority group and fiscal year by the proportion: (Number of species in a 

particular priority group and fiscal year)/ (Number of species in same 

priority group over all fiscal years). 

In addressing our second objective, to determine what factors influence the 

Service’s recovery funding allocation decisions, we interviewed managers 

and recovery biologists in the Service’s recovery division in headquarters, 

all seven regions and a nonprobability sample of 10 field offices.2

 We 

selected at least one field office from each region and selected a second 

field office from the two regions that collectively have lead responsibility 

for more than 50 percent of the endangered and threatened species in the 

United States. Within each region, we selected field offices that have lead 

responsibility for a high number of species relative to other field offices in 

that region. The region responsible for the largest number of species, the 

Pacific region, is operated as two divisions, and we selected a field office 

from each division. The field office locations in our nonprobability sample 

were:

Number of species in each priority group

Priority group FY 2000 FY 2001 FY 2002 FY 2003

1 395 408 416 415

2 432 436 444 448

3 290 285 286 284

4 47 47 46 47

5 45 46 47 48

6 7666

2

Results from nonprobability samples cannot be used to make inferences about a population 

because in a nonprobability sample some elements of the population being studied have no 

chance or an unknown chance of being selected as part of the sample.
Appendix I

Scope and Methodology

Page 37 GAO-05-211 Prioritizing Recovery Funds

• Hawaii (Pacific Region)

• Sacramento, California (Pacific Region)

• Arizona (Southwest Region)

• Columbia, Missouri (Great Lakes Region)

• Cookeville, Tennessee (Southeast Region)

• Vero Beach, Florida (Southeast Region)

• Virginia (Northeast Region)

• Utah (Mountain-Prairie Region)

• Anchorage, Alaska (Alaska Region)

• Fairbanks, Alaska (Alaska Region)

Through our interviews we obtained information on how recovery funds 

are allocated, the role of the recovery priority system, and suggested 

improvements to the recovery priority system. We compared the answers 

we received in these interviews to documents or expenditure data provided 

by the Service, to the extent this corroborating evidence was available. 

In addressing both objectives, we reviewed publicly available documents 

and other information obtained from the Fish and Wildlife Service’s 

Website. We also reviewed articles in academic and scientific literature 

related to recovery planning and recovery prioritization, including an 

extensive study of recovery plans conducted by the Society for 

Conservation Biology and funded by the Fish and Wildlife Service. 

We performed our work from February 2004 to January 2005, in 

accordance with generally accepted government auditing standards.
Page 38 GAO-05-211 Prioritizing Recovery Funds

Appendix II

Comments from the Department of the 

Interior ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.

See comment 2.
Appendix II

Comments from the Department of the 

Interior 

Page 39 GAO-05-211 Prioritizing Recovery Funds

See comment 3.
Appendix II

Comments from the Department of the 

Interior 

Page 40 GAO-05-211 Prioritizing Recovery Funds

The following are GAO’s comments on the Department of the Interior’s 

letter dated March 11, 2005. 

GAO Comments 1. We agree that some of the recovery funds included in our analysis of 

how recovery fund allocations compare with the Service’s recovery 

guidelines include funds for which Congress has provided direction 

that they be spent on particular projects or species. However, we do not 

believe that by including these funds we have underestimated the 

degree to which the Service’s funding decisions are consistent with its 

recovery priority guidelines. First, we found that the Service spent its 

recovery funds in a manner generally consistent with species priority. 

Second, we analyzed a list, provided to us by the Service, of 

congressionally directed funds and associated projects for fiscal years 

2000 through 2003. We compared this list with the priority rankings of 

the species associated with the projects in a way similar to how we 

compared species’ expenditures and priority rankings in our report. We 

found that the list of congressionally directed funds resulted in a 

spending pattern similar to what we identified when we compared 

species’ expenditures and priority rankings in our report. Thus, by 

including these funds in our analysis of how recovery funds allocations 

compare with the Service’s recovery guidelines, we do not believe that 

we have underestimated the degree to which the Service’s funding 

decisions are consistent with its recovery priority guidelines.

2. We agree that the Endangered Species Act does not require it to report 

separately on how it spent its recovery funds by species. However, 

reporting this information could be part of an effective strategy to help 

ensure that the Service allocates recovery resources consistent with 

the priority guidelines over the long term and in a transparent fashion.

3. In our report, we use the term “imperiled” instead of “threatened” to 

avoid confusion with the distinction the act makes between 

“threatened species” and “endangered species.” We agree that the act 

does not state that the purpose for requiring the Service to establish 

guidelines for prioritizing the development and implementation of 

recovery plans was to address concerns that recovery funds were not 

being directed at the most imperiled species. We have modified the 

report accordingly. 

However, we disagree with the Department’s contention that its 

recovery priority guidelines do not provide that funding should be 
Appendix II

Comments from the Department of the 

Interior 

Page 41 GAO-05-211 Prioritizing Recovery Funds

allocated preferentially to species with the highest priority ranking as 

depicted in table 2 of our report. The Department relies on a table in the 

guidelines that is virtually identical to table 2 in our report to describe 

its priority system. Section 4(h)(4) of the act specifically directs the 

Service to establish guidelines that shall include “a system for 

developing and implementing, on a priority basis, recovery plans under 

subsection (f) of this section.” Further, the guidelines state that “the 

species with the highest degree of threat have the highest priority for 

preparing and implementing recovery plans.” In addition, the guidelines 

state that they are to “aid in determining how to make the most 

appropriate use of resources available to implement the act.” 

The Department also contends that allocating funding preferentially to 

species with the highest priority ranking is contrary to section 

4(f)(1)(A) of the act. This provision, which was added in a 1982 

amendment to the act, states that recovery plans shall, to the maximum 

extent practicable, give priority to species most likely to benefit from 

such plans, particularly those that are, or may be, in conflict with 

construction or other development projects, or other forms of 

economic activity. The guidelines specifically state that the priority 

system established by the guidelines “is intended to satisfy the 

requirements of the amended Act.” Accordingly, the guidelines include 

likelihood to benefit from recovery plans and conflict as factors. 

We agree with the Department that focusing on opportunities for 

partnerships where multiple parties will work to the benefit of the 

species is consistent with section 4(f)(1)(A) of the act. In fact, we 

conclude in our report that the Service’s ability to be flexible in 

allocating its scarce recovery resources is the key to maximizing 

contributions from other organizations. However, we believe that this 

flexibility needs to occur within the bounds of a systematic and 

transparent process and make recommendations to this effect.
Page 42 GAO-05-211 Prioritizing Recovery Funds

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contact Trish McClure (202) 512-6318

Staff 

Acknowledgments

In addition to the individual named above, Charles Egan, Jaelith HallRivera, Barry T. Hill, Summer Pachman, Paula Bonin, Judy Pagano, and 

Cynthia Norris made key contributions to this report. 

(360427)
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