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 

United States Government Accountability Office

GAO 
 United States Government Accountability Office 

Accountability • Integrity • Reliability 

Highlights of GAO-11-144, a 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 

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 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. 

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. 

View GAO-11-144 or key components. 

For more information, contact Anu K. Mittal at 

(202) 512-3841 or mittala@gao.gov. 
Page i GAO-11-144 Law Enforcement on Federal Lands 

Letter 1

Background 3 

A Wide Variety of Illegal Activities Occurs on Federal Lands, 

Damaging Natural and Cultural Resources and Threatening 

Public and Employee Safety 7 

Agencies Have Dedicated More Law Enforcement Resources to 

Responding to Illegal Activities on Federal Lands 22 

Agencies’ Determination of Law Enforcement Resource Needs and 

Distribution Does Not Systematically Assess the Risks Posed by 

Illegal Activities 29 

Conclusions 35 

Recommendation for Executive Action 35 

Agency Comments and Our Evaluation 35 

Appendix I Objectives, Scope, and Methodology 37 

Appendix II Comments from the Department of Agriculture, 

Forest Service 41 

Appendix III GAO Contact and Staff Acknowledgments 42 

Tables 

Table 1: Numbers of Permanent Law Enforcement Officers, by 

Land Management Agency, Fiscal Years 2000 through 2009 23 

Table 2: Bureau of Land Management, Fish and Wildlife Service, 

Forest Service, and National Park Service Field Units 

Visited or Contacted, by Location 38 

Figures 

Figure 1: Federal Lands Managed by the Forest Service, Bureau of 

Land Management, Fish and Wildlife Service, and National 

Park Service 5 

Figure 2: OHV-Related Damage at Sonoran Desert National 

Monument 11 

Contents 
Page ii GAO-11-144 Law Enforcement on Federal Lands 

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

Everglades National Park 13 

Figure 4: Civil War Artifacts Stolen from Fredericksburg and 

Spotsylvania National Military Park 17 

Figure 5: Damage Caused by Marijuana Cultivation 19 

Figure 6: Vegetation and Soil Damage and Garbage Resulting from 

Illegal Border Activity 21 

Abbreviations 

OHV off-highway vehicle 

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

United States. The published product 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-11-144 Law Enforcement on Federal Lands 

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 

 
 

Page 2 GAO-11-144 Law Enforcement on Federal Lands 

offices.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.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 

 

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. 
 

Page 3 GAO-11-144 Law Enforcement on Federal Lands 

identify federal requirements and best practices for incorporating risk 

management into agency decision making, we reviewed relevant guidance, 

including federal standards for internal control.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. 

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 fig. 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. 

 

3

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 

Background 
 

Page 4 GAO-11-144 Law Enforcement on Federal Lands 

• 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. 
 

Page 5 GAO-11-144 Law Enforcement on Federal Lands 

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

Park Service 

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

Bureau of Land Management

Forest Service

Fish and Wildlife Service

National Park Service
 

Page 6 GAO-11-144 Law Enforcement on Federal Lands 

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 decisionmaking 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.4

 In some 

locations, state and local law enforcement agencies have entered into 

agreements allowing federal land management agencies’ law enforcement 

 

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. 
 

Page 7 GAO-11-144 Law Enforcement on Federal Lands 

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. 

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. 

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.5

 These data, however, cannot be used to monitor trends in the 

 

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. 

A Wide Variety of 

Illegal Activities 

Occurs on Federal 

Lands, Damaging 

Natural and Cultural 

Resources and 

Threatening Public 

and Employee Safety 

The Full Extent and 

Effects of Illegal Activities 

Occurring on Federal 

Lands Are Unknown 
 

Page 8 GAO-11-144 Law Enforcement on Federal Lands 

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.6

 The system, known as the 

Incident Management Analysis and Reporting System, is being designed to 

 

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). 
 

Page 9 GAO-11-144 Law Enforcement on Federal Lands 

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. 

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. 

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 

Agencies Have Identified a 

Wide Range of Illegal 

Activities and Impacts on 

Federal Lands 

Traffic Violations 
 

Page 10 GAO-11-144 Law Enforcement on Federal Lands 

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 Gap7

 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. 

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. 

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 

 

7

Cumberland Gap National Park is located at the junction of Kentucky, Tennessee, and 

Virginia. 

Public Intoxication and 

Possession or Use of Illegal 

Drugs 

Unauthorized Use of Vehicles 

for Recreation 
 

Page 11 GAO-11-144 Law Enforcement on Federal Lands 

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 fig. 2). 

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

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.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 

 

8

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

Source: Bureau of Land Management. 
 

Page 12 GAO-11-144 Law Enforcement on Federal Lands 

touching the seafloor bottom, which is designated as wilderness.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 fig. 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. 

 

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. 
 

Page 13 GAO-11-144 Law Enforcement on Federal Lands 

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

Park 

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 

Unauthorized Construction, 

Waste Disposal, Trespass, and 

Commercial Activity 
 

Page 14 GAO-11-144 Law Enforcement on Federal Lands 

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. 

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: 

Theft of or Damage to Natural 

and Cultural Resources and 

Government and Private 

Property 
 

Page 15 GAO-11-144 Law Enforcement on Federal Lands 

• 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,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 

 

10Wild ginseng is relatively rare, and the official said that the healthiest populations are 

located mostly on federal lands. 
 

Page 16 GAO-11-144 Law Enforcement on Federal Lands 

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 fig. 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. 
 

Page 17 GAO-11-144 Law Enforcement on Federal Lands 

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

• 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.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.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. 

 

11In 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. 

12The 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, 

GAO-07-1093 (Washington, D.C.: Sept. 27, 2007). 

Source: National Park Service. 
 

Page 18 GAO-11-144 Law Enforcement on Federal Lands 

• 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. 

According to officials at several federal land units we visited and National 

Drug Intelligence Center reports, marijuana is increasingly grown on 

federal lands.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 drugtrafficking 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 

 

13The 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. 

Marijuana Cultivation 
 

Page 19 GAO-11-144 Law Enforcement on Federal Lands 

• 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 fig. 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 

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 

Source: National Park Service. 
 

Page 20 GAO-11-144 Law Enforcement on Federal Lands 

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. 

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.14 Officials at every unit we 

visited in Arizona reported substantial natural resource damage from 

illegal border activity (see fig. 6).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. 

 

14A 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, 

GAO-11-38 (Washington, D.C.: Oct. 19, 2010). 

15Illegal 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.

Illegal Border Activity
 

Page 21 GAO-11-144 Law Enforcement on Federal Lands 

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

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. 

According to law enforcement officials at the units we visited, the public 

and agency employees can also be the victims of violence, including 

Violent Crimes 

Source: Forest Service. 
 

Page 22 GAO-11-144 Law Enforcement on Federal Lands 

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. 

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. 

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 

Agencies Have 

Dedicated More Law 

Enforcement 

Resources to 

Responding to Illegal 

Activities on Federal 

Lands 

Three of the Four Agencies 

Have Increased Their Law 

Enforcement Presence to 

Respond to Illegal 

Activities Occurring on the 

Lands They Manage 
 

Page 23 GAO-11-144 Law Enforcement on Federal Lands 

performing law enforcement duties on a full-time basis.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 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Percentage 

change

Forest Service 630 680 660 697 692 663 627 687 751 742 17.78%

Bureau of Land Management 213 228 251 267 264 260 267 260 279 300 40.85

Fish and Wildlife Servicea,b – – – – – – 217 234 254 273 25.81

National Park Servicea,c – – – – – 1,658 1,555 1,470 1,418 1,450 –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. 

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 

 

16The 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. 
 

Page 24 GAO-11-144 Law Enforcement on Federal Lands 

using part-time law enforcement officers.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 

 

17Department 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). 
 

Page 25 GAO-11-144 Law Enforcement on Federal Lands 

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.18

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 

 

18The three forests are the Grand Mesa-Uncompahgre-Gunnison, the Rio Grande, and the 

San Juan national forests. 

The Agencies Have 

Directed Resources to 

Respond Specifically to 

Marijuana Cultivation and 

Illegal Border Activities 
 

Page 26 GAO-11-144 Law Enforcement on Federal Lands 

for a nationwide initiative to increase protection of national forest lands 

from drug-trafficking organizations.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. 

 

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

Page 27 GAO-11-144 Law Enforcement on Federal Lands 

• 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.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. 

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.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. 

 

20H.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). 

21Agency 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. 

Agencies Have Also 

Temporarily Assigned Law 

Enforcement Staff to 

Curtail Illegal Activities at 

Certain Locations as 

Needed 
 

Page 28 GAO-11-144 Law Enforcement on Federal Lands 

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.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.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 

 

22The 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. 

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

Agencies Have Increased 

the Training Required for 

Law Enforcement Officers 
 

Page 29 GAO-11-144 Law Enforcement on Federal Lands 

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 drugtrafficking 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. 

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.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 

 

24GAO/AIMD-00-21.3.1. 

Agencies’ 

Determination of Law 

Enforcement 

Resource Needs and 

Distribution Does Not 

Systematically Assess 

the Risks Posed by 

Illegal Activities 
 

Page 30 GAO-11-144 Law Enforcement on Federal Lands 

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 
 

Page 31 GAO-11-144 Law Enforcement on Federal Lands 

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 
 

Page 32 GAO-11-144 Law Enforcement on Federal Lands 

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.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 

 

25Department of the Interior, Threat Assessment for the U.S./Mexico Border, 2002-2003

(Tucson, Ariz., 2003). 
 

Page 33 GAO-11-144 Law Enforcement on Federal Lands 

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.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. 

 

26Department 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). 
 

Page 34 GAO-11-144 Law Enforcement on Federal Lands 

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.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.28 The agency has 

 

27GAO, Homeland Security: Actions Needed to Improve Security Practices at National 

Icons and Parks, GAO-09-983 (Washington, D.C.: Aug. 28, 2009). 

28Interior 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. 
 

Page 35 GAO-11-144 Law Enforcement on Federal Lands 

taken few steps, however, to identify and reduce risks to the other units of 

the National Park System. 

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. 

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. 

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 

Conclusions 

Recommendation for 

Executive Action 

Agency Comments 

and Our Evaluation 
 

Page 36 GAO-11-144 Law Enforcement on Federal Lands 

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 

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, 

Anu K. Mittal 

Director, Natural Resources and Environment 
Appendix I: Objectives, Scope, and 

Methodology 

Page 37 GAO-11-144 Law Enforcement on Federal Lands 

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).1

 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 

 

1

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. 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology 

Page 38 GAO-11-144 Law Enforcement on Federal Lands 

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 Agency Unit 

Arizona Bureau of Land Management Sonoran Desert National Monument 

Fish and Wildlife Service Buenos Aires National Wildlife Refuge 

Forest Service Coronado National Forest 

California Bureau of Land Management El Centro Field Officea

Bureau of Land Management Ukiah Field Officea

 Forest Service Sierra National Forest 

National Park Service Yosemite National Park 

Bureau of Land Management Monticello Field Office 

Forest Service San Juan National Forest 

National Park Service Arches National Park 

Four Corners 

(Colorado and Utah) 

National Park Service Canyonlands National Park 

Florida Fish and Wildlife Service Merritt Island National Wildlife Refuge 

Forest Service Ocala National Forest 

National Park Service Everglades National Park 

Forest Service Cherokee National Forest 

National Park Service Cumberland Gap National Park 

Appalachian Mountains 

(Kentucky, North Carolina, 

Tennessee, and Virginia) 

National Park Service Great Smoky Mountains National Park 

Fish and Wildlife Service Blackwater National Wildlife Refuge 

Fish and Wildlife Service Chincoteague National Wildlife Refuge 

Fish and Wildlife Service Eastern Neck National Wildlife Refuge 

Mid-Atlantic 

(Maryland and Virginia) 

National Park Service Fredericksburg and Spotsylvania National Military Park 

Minnesota Fish and Wildlife Service Detroit Lakes Wetland Management District 

Fish and Wildlife Service Tamarac National Wildlife Refuge 

Forest Service Superior National Forest 

Washington Forest Service Okanogan-Wenatchee National Forest 

National Park Service 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. 

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 
Appendix I: Objectives, Scope, and 

Methodology 

Page 39 GAO-11-144 Law Enforcement on Federal Lands 

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,

2

 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 

 

2

GAO/AIMD-00-21.3.1. 
Appendix I: Objectives, Scope, and 

Methodology 

Page 40 GAO-11-144 Law Enforcement on Federal Lands 

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. 
Appendix II: Comments from the Department 

of Agriculture, Forest Service 

Page 41 GAO-11-144 Law Enforcement on Federal Lands 

Appendix II: Comments from the Department 

of Agriculture, Forest Service 
Appendix III: GAO Contact and Staff 

Acknowledgments 

Page 42 GAO-11-144 Law Enforcement on Federal Lands 

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

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. 

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(361104) 
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help 

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost 

is through GAO’s Web site (www.gao.gov). Each weekday afternoon, GAO 

posts on its Web site newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.” 

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s Web site, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information. 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Ralph Dawn, Managing Director, dawnr@gao.gov, (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, DC 20548 

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

Please Print on Recycled Paper