THE DRUG ENFORCEMENT ADMINISTRATION'SDOMESTIC CANNABIS ERADICATION/SUPPRESSION PROGRAM

Audit Report 95-20, (4/95)

 

 

TABLE OF CONTENTS

 

EXECUTIVE DIGEST

INTRODUCTION

I. OBJECTIVES

II. SCOPE AND METHODOLOGY

III. BACKGROUND

> 
A.Cannabis Usage

B.The Cannabis Program

C.Applicable Legislation

D.National Drug Strategy/Departmental Streamlining    Strategy

E.Program Management

F.Program Participation

G.Bureau of Justice Assistance Funded Programs

H.Prior Reviews

FINDINGS AND RECOMMENDATIONS

I.COMMUNICATION OF PROGRAM REQUIREMENTS

> 
A.Incorrect Program Statistics

B.Program Expenditures 

Recommendations/Actions Taken 

II.COMMUNICATIONOF FUNDING DECISIONS 

> 
Recommendation/Action Taken 

STATEMENT ON INTERNAL CONTROL STRUCTURE 

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS 

APPENDIX I -SCOPE AND METHODOLOGY 

APPENDIX II -FEDERAL, STATE, AND LOCALAGENCIES 

> 
REVIEWED/CONTACTED 

APPENDIX III -DOMESTIC CANNABISERADICATION/SUPPRESSION

> 
LETTERS OF AGREEMENT

APPENDIX IV -BUREAU OF JUSTICEASSISTANCE 

> 
FORMULA GRANT PROGRAM AWARDS FOR

MARIJUANA ERADICATION

APPENDIX V -BUREAU OF JUSTICE ASSISTANCE'S COMMENTS

TO THE DRAFT REPORT 

* * *

THE DRUG ENFORCEMENT ADMINISTRATION'S

DOMESTIC CANNABIS ERADICATION/SUPPRESSIONPROGRAM

 

EXECUTIVE DIGEST

The Office of the Inspector General (OIG), Audit Division, hascompleted an audit of the Drug Enforcement Administration'sDomestic Cannabis Eradication/Suppression Program. The audit wasinitiated at the request of the Drug Enforcement Administration(DEA) management. The Program has been successful; for arelatively modest investment of $10 million in FYs 1993 and 1994,DEA supported state and local law enforcement agencies' effortsto eradicate cannabis and suppress its use. Specifically, in1993, four of the ten states audited reported the following:72,635,036 plants eradicated, $16,417,232 assets seized, 1,409weapons seized, and 2,679 offenders arrested. The remaining sixstates included the activities of non-participating agencies intheir reports to DEA, resulting in data being overstated. Inaddition, DEA realized the indirect benefit of developing andnurturing excellent relationships with state and local lawenforcement agencies throughout the country. DEA operationalpersonnel in Headquarters and in the field, as well as state andlocal officials in the ten states audited, strongly supported theProgram. 

This report presents the audit results and providesrecommendations for: (1) identifying areas where DEA can moreeffectively monitor the Program and communicate Programrequirements to state and local participants; and (2) increasingcoordination between the DEA Program and the cannabis eradicationefforts funded through the Office of Justice Programs (OJP),Bureau of Justice Assistance (BJA) grant program. 

Overall, we found that DEA funds were expended by state andlocal agencies for allowable purposes in accordance withestablished guidelines. Our review did not reveal weaknesses withthe internal controls involving the destruction of cannabis.

Prior to preparing the audit report, the OIG consulted withboth DEA and BJA management about the audit findings and jointlydeveloped appropriate recommendations. In some cases, correctiveaction has been undertaken. This cooperative effort maximized thepositive impact of the audit, and will facilitate theimplementation of the recommendations to achieve the desiredresults. 

Both DEA and BJA reviewed and commented on the draft report,which was revised accordingly. However, BJA management asked thatthe full text of their comments be appended to the final report(see Appendix V). 

 

INTRODUCTION

The Office of the Inspector General (OIG), Audit Division, hascompleted an audit of the Drug Enforcement Administration's (DEA)Domestic Cannabis Eradication/Suppression Program (the Program).The audit was initiated at the request of DEA management. 

I. OBJECTIVES

The objectives of the audit were to determine: 

Whether DEA funds were expended by state and local agenciesfor allowable purposes in accordance with established guidelines,

The adequacy and accuracy of program measurements,

Whether DEA has established adequate internal controls overthe destruction of cannabis,

The extent of DEA's oversight of the Program at theHeadquarters and field levels, and

The extent of coordination between DEA's Domestic CannabisEradication/Suppression Program and the Office of JusticePrograms (OJP), Bureau of Justice Assistance's (BJA) fundedefforts in this area.

II. SCOPE ANDMETHODOLOGY

The audit was performed in accordance with generally acceptedgovernment auditing standards and included tests and proceduresnecessary to accomplish the audit objectives. Applicable Federallaws and regulations, as well as DEA policies, procedures, andplanning documents, were reviewed.

The audit concentrated on the period September 1, 1992 throughAugust 31, 1994, and focused primarily on the Programadministered by the DEA Office of Investigative Support, SpecialInvestigative Support Section. In addition, weperformed a limitedreview of the cannabis eradication efforts funded by BJA. Furtherdetails on the scope and methodology can be found in Appendix I.

As the audit progressed, the audit team verbally provided DEAProgram management with detailed results of the audit. DEA usedthe information to train Program Coordinators at a conferenceheld in December 1994.

Prior to issuing the report, we consulted with DEA and BJAmanagement to reach agreement on our findings andrecommendations. As a result, DEA managers have begun thenecessary improvements to the Program. 

III. BACKGROUND

A. Cannabis Usage

According to DEA, cannabis, commonly known as marijuana, isthe most widely used illegal drug in the United States.Domestically grown cannabis accounted for 10 percent of allmarijuana consumed in 1980, and increased to about 25 percent in1992, despite the efforts of the Program. The potency ofcultivated marijuana has also increased significantly as a resultof modern agricultural methods and techniques. DEA indicated thatthe average strength of the main hallucinogen in cannabis(Delta-9 tetrahydrocannabinol) had increased from about 6 percentin 1982 to about 15 percent in 1992, with a record high of almost30 percent.

The production and marketing of marijuana can be verylucrative. On average, the usable yield from one marijuana plantis approximately one pound. DEA statistics indicated that theretail price of high quality domestic marijuana had risen from$4,800 per pound in 1988 to $7,200 per pound in 1991 (the mostrecent data available from DEA). As a result, there may beincreased potential for cultivating marijuana as a cash producingcrop.

The use of marijuana by young people continues to be anational problem. As highlighted by the national media, arecently issued study by the National Parents' ResourceInstitution for Drug Education revealed that teenage use ofmarijuana increased significantly during the 1993-1994 academicyear. More specifically, the number of high school students usingmarijuana at least once a month increased from approximately 11percent to 16 percent.

B.The Cannabis Program

DEA's primary mission is to enforce the Nation's drug laws.Under that umbrella, DEA established the Program to deter thecultivation of marijuana in the United States. The main thrust ofthe Program was to provide direct support to state and localcannabis eradication efforts and to integrate the variousactivities into a comprehensive national campaign. DEA formalizedthe Program in the early 1980's by initiating support to 7states. In FY 1994, all 50 states were involved in the Program. 

C.Applicable Legislation

The Controlled Substances Act of the Comprehensive Drug AbusePrevention and Control Act of 1970 directs the Attorney Generalto cooperate with Federal, state, and local agencies concerningthe trafficking of controlled substances. This Act furtherauthorized the Attorney General to conduct programs oferadication aimed at destroying wild or illicit growth of plantspecies from which controlled substances may be extracted.

D.National Drug Control Strategy/Departmental StreamliningStrategy

The White House issued a National Drug Control Strategy inFebruary 1994. This document stated the need to better define thesize and scope of the drug problem and work aggressively tosuppress domestic marijuana production and trafficking.

However, in the Department of Justice's (DOJ) StreamliningStrategy of October 1994, DEA identified potential streamliningactions to be implemented from 1996 through 1999. These actionsinclude: "eliminating duplicate functions or organizationalelements that are not central to DEA's mission, such as themarijuana eradication and demand reduction programs." DEAofficials were unable to provide us with a clear perspective onthe future of the Program. However, they informed us that theProgram was funded for FY 1995.

E.Program Management

At the Headquarters level, the Program was administered by theDEA's Special Investigative Support Section. The Program wasstaffed with one section chief, two special agents serving asstaff coordinators, one program assistant who was primarilyresponsible for maintaining financial and programmatic data, oneprogram analyst, and a National Guard representative.

In each state, DEA designated a special agent to serve asprogram coordinator. DEA Coordinators' duties included: (1)coordinating statewide Program efforts, (2) maintaining andreporting Program statistics, and (3) keeping Division managementinformed as appropriate. Oversight of the Program at the statelevel varied depending on whether DEA Coordinators were on afull-time or collateral basis. 

Each state also had a state Coordinator who was designated bythe primary agency receiving funding. State Coordinators'responsibilities included monitoring the Program's financialaspects and tracking the Program's results. 

F. Program Participation

According to DOJ budget staff, DEA reprogrammed $843,340within its appropriation to establish the Program in 1982. Thisamount increased to $3.8 million annually and remained unchangeduntil 1991, when Congress appropriated an additional $10 millionfor the Program. However, for the period 1992 through 1994, theProgram was funded exclusively by Congress at $10 million,annually. 

DEA utilized Letters of Agreement with state and localagencies to provide funding to help defray the cost of statemarijuana eradication efforts. In FY 1993, DEA entered into 64Letters of Agreement throughout the 50 states (See Appendix III).

To receive funding, each state had to prepare an annualOperation Plan in coordination with the designated DEACoordinator for that state. These plans delineate the strategythe states propose to use for the Program. Specifically, anOperation Plan should outline: (1) the cannabis cultivationsituation in the state; (2) DEA Resident Office and state andlocal resources available; (3) the nature of the state's cannabiseradication/suppression activities; and (4) a quantitativerequest for funding, training, and other resource support neededfrom DEA Headquarters.

Operation Plans were to be submitted to DEA Headquarters forapproval. Upon approval, individual Letters of Agreement wereentered into with the state agency receiving funding. This agencywas responsible for the overall execution of the Program andcould, in coordination with other state or local agencies,distribute Program funds further within the state. When multipleagencies within a state received money, the state agencyreceiving the funding from DEA would remain responsible for thegeneral oversight of the Program.

G. Bureau of Justice Assistance Funded Programs

The states' cannabis eradication efforts were not limited toparticipation in DEA's Program. States may undertake their ownoperations or create cannabis eradication groups, independent ofDEA, using grant funds provided by BJA. These grants were a partof a broad program of criminal justice system improvements. Thesegrants focused particularly on state and local anti-drug systemand anti-violence initiatives, and were supported in part withFederal funding. The states could use grant funds for 26statutory purposes.

Specifically, the BJA Director was authorized, under Section3751(b)(3) of Title 42 USC, Grants to State and units of localgovernment (The Edward Byrne Memorial State and Local LawEnforcement Assistance Programs), to make drug enforcementgrants, for use by the states and local governments within thestate, for:

"programs designed to target the domestic sources ofcontrolled and illegal substances, such as precursor chemicals,diverted pharmaceutical, clandestine laboratories, and cannabiscultivations."

These BJA funded efforts were not a part of the DEA Programnor any other established program. In FY 1993, the states electedto spend approximately $3.3 million of BJA funds for cannabiseradication activities. (See Appendix IV).

H.Prior Reviews

In November 1985, the Audit Staff of the Justice ManagementDivision, a predecessor of the OIG, Audit Division, conducted areview of DEA's Program in the Western United States. The reportdisclosed that the Program had achieved progress in assisting lawenforcement agencies to eradicate domestically grown marijuanawith a limited budget. The report made several recommendationsfor improvement concerning operational procedures and priority.At the time of our audit, the report was formally resolved andclosed because of efforts taken by DEA. 

The Program was subject to review under Office of Managementand Budget Circular A-128, which established requirements forstates pursuant to the Single Audit Act of 1984. Review of theseaudit reports for the states audited generally showed that theProgram did not meet the minimum funding threshold required forreview. 

We also examined DEA Inspections Reports in which nodeficiencies were identified. Finally, we reviewed stategenerated reports, when available and found one report whichidentified potential deficiencies and is referred to in FindingI.

FINDINGS ANDRECOMMENDATIONS

I.COMMUNICATIONOF PROGRAM REQUIREMENTS

The DEA Domestic Cannabis Eradication/Suppression Program wasprimarily implemented through state and local agencies. Thus far,with limited Federal funds, DEA successfully assisted in thesuppression of marijuana through eradication, asset and weaponseizures, and arrests. Specifically, in 1993, four of the tenstates audited reported: 72,635,036 plants eradicated,$16,417,232 assets seized, 1,409 weapons seized, and 2,679offenders arrested. The remaining six states' reports includedthe activities of non-participating agencies, resulting ininflated and therefore unusable data. Through this Program, DEAalso pushed marijuana growers indoors, making it more difficultand costly for the offenders.

We reviewed internal controls over the destruction of cannabisin 10 states and localities within each state. We alsoparticipated in a multi-agency cannabis eradication effort duringwhich we observed the destruction of thousands of cannabisplants. Our testing revealed no discrepancies or weaknesses inthe destruction of cannabis. Participating agencies stored anddestroyed eradicated marijuana according to each jurisdiction'sprocedures concerning evidence in criminal cases. 

However, we did find that Program requirements had not beenadequately communicated to participating agencies and DEAofficials did not request Program-specific information availablefrom participants. As a result, DEA had to rely on inadequateinformation to measure Program success and track relatedexpenditures. In addition, DEA could not accurately assess theimpact of the Program, and could not ensure that the Program wasbeing executed as efficiently as possible. 

DEA developed and distributed a "CoordinatorsHandbook" to DEA Coordinators, providing them withbackground and guidance on the Program. This handbook provides asynopsis of DEA Coordinators responsibilities, samples andexplanations of various documents, and funding requirements andprocedures. It also contains applicable legislation governing theProgram, as well as contact points of Federal agencies which haveagreed to assist in the Program. 

State level participants were not provided with similarreference material. Although DEA conducted annual conferences todiscuss operational and administrative aspects of the Programwith participants, information distributed at these conferenceswas informal. Therefore, participants were not always aware ofall Programguidelines. State officials could administer theProgram in a more effective and efficient manner if they werebetter informed of DEA's requirements. A written manual wouldprovide these officials a reference point to research issues andquestions that arise during the operation of the Program. The OIGdiscussed this issue with DEA Program managers who have agreedthat such a manual would be beneficial to the state Coordinatorsand have begun compiling a handbook.

We identified areas which should be addressed by the manualincluding instructions on how to report on Program statistics andthe disbursement and use of funds. 

A.Incorrect Program Statistics

Program accomplishments reported by DEA did not accuratelyrepresent the results of the participants' activities. Thisoccurred because DEA requested the states to report Programaccomplishments on a statewide basis. As a result, DEA did nothave accurate information to adequately assess the impact of theProgram.

Participation in DEA's marijuana eradication program requiredthe DEA Coordinator in each state to prepare and submit MonthlyStatistical Reports with input from the appropriate state agency.According to the DEA Coordinator's Handbook, "it isessential that eradication efforts in each state be reported in atimely and accurate manner..." and that the reports containthe required information. However, the Handbook did not conveythat each state was to separately report activity resulting fromagencies funded through this Program.

The Monthly Statistical Reports measure Program results usingseveral categories. The participating agencies report eradicatedmarijuana in the following categories: 

Processed Marijuana - Actual dry smokeable marijuana inthe drying process, loose, or packaged.

Outdoor Cultivated Plants - Hand tended, watered,individually pruned, grafted, or cloned marijuana plants. 

Indoor Cultivated Plants - Marijuana plants grownindoors.

Ditchweed Plants - Scattered marijuana plants which arenaturally wild growing and are not normally tended to by anyindividuals.

According to Program officials in six of the ten statesaudited, statistics reported to DEA Headquarters included theeradication efforts of non-participating agencies. As a result,the data used by DEA Headquarters to report on the Program wasinflated. Testing in four of these states was inconclusive,because we could not trace supporting documentation used by thesestates in compiling the statistics. Therefore, we could notdetermine the extent of the error in these locations. The resultsof the review in the remaining two states appear below: 

The DEA and state Coordinators in this state requested andreported to DEA eradication statistics from agencies which didnot receive Program funds, but had expressed interest inparticipating in the Program. In addition, the data includedseveral reporting and mathematical errors. The following tabledemonstrates the extent of the overstatement for this state for a2 month period in 1993.

| A
Category                           | B
Amount Reported | C
Non-Funded Agency Data | D
Recording Errors | E
(C + D)

Overstatement | F
(B - E)

Amount Directly

Realized From

DEA Program |
|--------------------------------------|-------------------|--------------------------|--------------------|--------------------------|--------------------------------------------------------|
| Processed
Marijuana (pounds)         | 866               | 215.5                    | 250.5              | 466                      | 400                                                    |
| Outdoor Cultivated Plants Eradicated | 74,768            | 0                        | 25,468             | 25,468                   | 49,300                                                 |
| Ditchweed Eradicated                 | 68,943,548        | 0                        | 1,136,148          | 1,136,148                | 67,807,400                                             |
| Assets Seized                        | $1,149,865        | $97,500                  | 0                  | $97,500                  | $1,052,365                                             |

Program officials in the second state reported eradicationstatistics for the entire state, although much of the activitywas not funded by the Program. Overstatements for this state,during calendar year 1993, are shown in the following table.

| A
Category                           | B
Amount 

Reported | C
Non-Funded

Agency Data | D
(D=C)

Overstatement | E
(B - D)

Amount Directly

Realized From

DEA Program |
|--------------------------------------|---------------------|---------------------------|------------------------|--------------------------------------------------------|
| Plots Eradicated                     | 340                 | 249                       | 249                    | 91                                                     |
| Outdoor Cultivated Plants Eradicated | 32,861              | 21,353                    | 21,353                 | 11,508                                                 |
| Ditchweed Eradicated                 | 565,885             | 556,878                   | 556,878                | 9,007                                                  |
| Indoor Grows                         | 22                  | 13                        | 13                     | 9                                                      |
| Indoor Plants Eradicated             | 4,949               | 959                       | 959                    | 3,990                                                  |
| Arrests                              | 66                  | 37                        | 37                     | 29                                                     |
| Assets Seized                        | $277,234            | $59,509                   | $59,509                | $217,725                                               |

DEA's national statistics on Program results were compiledusing statistical reports submitted by the states. Thesestatistics were published in an annual report for the Program, aswell as in other DEA promotion material. In its 1992 DomesticCannabis Eradication/Suppression Program Report (the latestreport available from DEA), DEA published the final 1992statistics for all 50 states. The report specifically stated:"these data do not include non Domestic CannabisEradication/Suppression Program information..." However, asstated above, participating agencies in 6 of the 10 states testedreported non-program activity to DEA. 

Specific information on the DEA funded Program wasparticularly important, because, as DEA officials advised us, thenumber of eradicated plants, asset and weapon seizures, andarrests were used as a way to judge the effectiveness of theindividual Programs in the 50 states. The officials also told usthat this information could affect the amount of funds that astate receives. 

DEA did not receive the necessary information to accuratelymeasure Program success, because, as previously stated, DEArequested the states to report Program accomplishments on astatewide basis. As a result, national statistics maybeoverstated. According to state officials, they were not awarethat DEA required that statistics for the Program be separatedfrom total state statistics. Therefore, the distribution of clearProgram guidance to state officials would help provide DEA withmore useful statistical information. 

B.Program Expenditures

DEA utilized Letters of Agreement with state and localagencies to provide funding to help defray the cost of marijuanaeradication efforts. The Letters of Agreement provided the stateswith general guidelines concerning Program expenditures. DEAallowed the states discretion over how eradication funds werespent, because the cannabis situation in each state varied.Although DEA did not systematically monitor the use of allProgram funds, it retained approval rights for certain types ofexpenditures. The audit revealed that improved communication ofDEA requirements would have enhanced the process of approvingexpenditures and funding local agencies.

To determine whether state and local agencies expended DEAfunds for allowable purposes and in accordance with guidelinesfor FYs 1993 and 1994, we tested a total of $1,907,331 (39percent) of the $4,871,912 expended in ten states. In general, wefound that expenditures were supported and within Programguidelines. However, a review of $452,088 (78 percent) of$579,677 expended by the ten states for the purchase ofequipment, during the test period, revealed the following minorweaknesses which have been related to DEA. DEA officials informedus that this information was very important to them, as itidentified issues which they feel could affect the efficientoperation of the Program. 

Equipment Usage - In some cases, although purchases ofequipment were properly approved, the equipment was not primarilyutilized for marijuana eradication. While information detailingprobable equipment usage was not required by DEA, funds could bemore effectively utilized if DEA officials were fully aware ofthe use of the equipment. 

For example, review of expenditures in one state included thepurchase of a computer and printer costing approximately $3,000.State officials told us that computer equipment was used lessthan 50 percent of the time for cannabis eradication. In casessuch as this, Program funds would be more effectively used ifonly a prorated portion of the cost was paid by DEA. We discussedthis idea with DEA officials who agreed that it would result in amore efficient use of Federal funds. 

Approval Process - Program policy required states toobtain DEA approval for the purchase of non-expendable equipment,which was defined as having a useful life of more than 1 year,and a cost of $300 or more per unit. Examples of these purchasesincluded the acquisition of surveillance equipment, computers andprinters. Our review indicated that state authorities generallyrequested approval from DEA for these purchases. 

Once DEA officials approved an expenditure, they did notrequire notification of significant differences from the approvedamount. As a result, the approval of an expenditure could be veryineffective. To illustrate, in one location, state officialsreceived approval for the purchase of two helicopter cable cutterkits for $8,600. The actual purchase price of these kits totaled$46,968, resulting in a $38,368 difference. This total isolatesthe cost of the kits only and does not include costs incurred forother related equipment nor the cost of installation. At the timeof the audit, Program guidelines did not require state officialsto notify DEA of such variances. DEA officials agreed that morespecific guidelines requiring the state to immediately reportthis information would permit them to make more informeddecisions.

At the time of the audit, participants were able to expendProgram funds on inexpensive non-expendable items withoutnotifying DEA. There was no limit on the aggregate purchaseamount; the limit was only on unit cost. Thus, at any given time,an agency could spend thousands of dollars on small items withoutDEA being aware of the purchases. To illustrate, a state auditreport identified the following purchases, which were madewithout DEA's knowledge: 

| **Purchase** |               |         | **Unit** |      |
|--------------|--------------------|--------------|----------|-----------|
| **Order**    | **Item**           | **Quantity** | **Cost** | **Total** |
| A            | Dictating Machines | 20           | $294     | $5,880    |
| B            | Tape Recorders     | 15           | 98       | 1,470     |
| C            | Filing Cabinets    | 15           | 50       | 750       |

The state was not required to receive DEA's approval for thesepurchases, as all of the items had a unit cost under $300 andapproval applied only to unit cost. However, when informed of theabove by the audit team, DEA officials expressed concern over thetype and extent of items being purchased and agreed that anaggregate purchase limit should be established. The audit furtherrevealed that in one state DEA funds were used to pay for the useof helicopters, accruing daily rental costs whether or not theywere used. We tested the use of the helicopters in two locationswithin the state for approximately a 2-month period. Thehelicopters were retained at a cost of $500 and $600 per day, andwere not utilized for at least 29 days in each location. As aresult, $31,900 ($14,500 + $17,400) could have been used moreefficiently.

In addition, seven of the ten state agencies audited haddistributed some of their DEA Program funds to other agencieswithin the states. However, the Letters of Agreement were notspecific to how this distribution should be executed. In five ofthese states, funds were distributed on a reimbursable basis andwere subject to review. 

In contrast, the two remaining state agencies were notutilizing a reimbursable basis which would have allowed them toreview individual local expenditures. As a result, DEA funds weresusceptible to potential misuse by local agencies. When advisedof this situation, DEA officials expressed their desire to haveall states who plan to distribute funds to do so on areimbursable basis. 

DEA did not receive all necessary information to ensure thatfunds were used as efficiently as possible. This occurred becauseProgram guidance was not effectively communicated toparticipants. State agencies involved in the Program had fewwritten guidelines concerning Program execution andadministration and some indicated that more formal guidance wouldbe beneficial. More detailed instructions would assist stateparticipants in effective execution of financial aspects of theProgram. 

The following details the recommendations which were developedjointly by the OIG and DEA.

RECOMMENDATIONS/ACTIONS TAKEN

We recommend the DEA Administrator:

1.Issue a Handbook to state and local Coordinators describingthe execution of the Program.

**Resolved.** DEA is in the process of revising andupdating the current Handbook. They anticipate issuing theHandbook to DEA and state and local Coordinators by August 30,1995.

2.Instruct state and local Coordinators to report statisticsthat clearly delineate the results of this Program from theoverall state results.

**Resolved.** DEA officials told us that they held aconference with state and local Coordinators in March of 1995during which the Coordinators were instructed to separate outstatistics that directly result from Program funding effectiveApril 1, 1995. In addition, this requirement will be addressed inthe revised Handbook. 

3.Require state and local Coordinators to obtain approval fromDEA when expending Program funds for non-expendable items thatexceed $300 per unit or $1,000 in aggregate.

**Resolved.** DEA officials told us that, at the conferenceheld in March of 1995, they informed state and local Coordinatorsof the requirement to obtain approval. In addition, the revisedHandbook will clearly address this requirement. 

4.Advise state and local Coordinators to develop an allocationplan estimating the percentage of use for eradication efforts,when requesting approval for the purchase of non-expendableequipment. 

**Resolved.** DEA officials told us that, at the conferenceheld in March of 1995, they informed state and local Coordinatorsof the requirement to develop an allocation plan. In addition,the revised Handbook will clearly address this requirement. 

5.Require state and local Coordinators to notify DEA prior tospending funds, when actual expenditures will exceed approvedcosts by 10 percent or $300 whichever is less.

**Resolved.** DEA officials told us that, at the March 1995conference, they re-emphasized to state and local Coordinatorsthe necessity to notify DEA when actual expenditures exceedapproved costs by 10 percent or $300 both and that they willre-emphasize this point in the Handbook. 6.Advise state and localCoordinators to enter into reimbursable agreements, when fundingsecondary agencies, to allow them to review expenditures. 

**Resolved.** DEA officials told us that, at the conferenceheld in March of 1995, they informed state and local Coordinatorsof the requirement to enter into reimbursable agreements and thatthey will include this requirement in the Handbook to bedistributed by August 30, 1995. 

To close recommendations 1 through 6, please provide a copy ofthe Handbook when it becomes available.

II. COMMUNICATIONOF FUNDING DECISIONS

The DOJ funded cannabis eradication efforts directly throughDEA and indirectly through BJA grants. Although the Department isinvolved in funding both cannabis eradication efforts, financialinformation was not exchanged at the Headquarter's level. DEAofficials advised us that knowledge of which state agencies wereallocating BJA funds for cannabis eradication could haveinfluenced how they distribute their resources and therebymaximized the use of the $13.3 million in Federal funds.

The BJA staff used a database to help monitor their grantprograms. This database listed the name of the state and localagencies receiving cannabis eradication funds, along with thecontact name and telephone number of the coordinating agencyofficial. Although DEA designated a Special Agent as a liaisonwith BJA, information as to which states elected to fund cannabiseradication was not communicated. The DEA information may not beas important to BJA because as a grantor agency, the Bureau ofJustice Administration's role differs significantly from DEA'sdirect role in funding cannabis eradication efforts. However, theBJA's information could be critical to DEA officials who havediscretion as to how funds are distributed among state agencies. 

The audit team obtained the necessary information from BJA andpresented it to DEA Program officials who indicated theinformation was important and could have impacted their fundingdecisions. For example, in FY 1993, the same agency within onestate elected to spend $530,813 of BJA grant funds for cannabiseradication and additionally received $185,000 from DEA. DEAmanagement informed us that they may have re-directed some oftheir limited funds, if they were aware of the other Federalfunding. 

Prior to the conclusion of the audit, DEA obtained somefunding information from BJA which they have found helpful. DEAand BJA officials should continue to coordinate their efforts anddecide on a mutually agreeable time when financial grantinformation can be shared in the future.

The following details the recommendation developed jointly bythe OIG, DEA, and BJA and action taken by these agencies.

RECOMMENDATION/ACTION TAKEN

We recommend the DEA Administrator:

7.Continue to obtain from BJA, at a mutually agreeable time, alisting of cannabis eradication efforts which are funded throughgrants by that agency. 

Resolved: DEA officials have obtained fundinginformation from BJA and have begun to utilize it to helpdetermine the distribution of their funds. 

To close this recommendation, please provide documentation ofa mutual agreement to continue to furnish this information in thefuture.

STATEMENT ON INTERNAL CONTROL STRUCTURE

In planning and performing the audit of DEA's DomesticCannabis Eradication/Suppression Program, we considered theinternal control structure for the Program. At the participatingagencies, we focused on the internal controls related to thecounting and destruction of cannabis and reviewed accounting andinventory practices, as well as the management of funds.

We did not review internal controls in order to express anopinion on DEA's internal control structure, nor that of theindividual states participating in the Program. However, thereare certain matters involving the internal control structure thatwe consider to be reportable conditions under generally acceptedgovernment auditing standards. Reportable conditions involvematters coming to our attention relating to significantdeficiencies in the design or operation of the internal controlstructure that, in our judgment, could adversely affect theability of DEA to use funds more efficiently and effectively. Wefound there was a lack of communication among Federal, state, andlocal agencies, which had an effect on the use of funds and DEA'soversight of the Program (Findings I and II). However, in ouropinion, these conditions did not have a material effect on theProgram.

We are not expressing an opinion on DEA's internal controlstructure. This statement is intended solely for the informationand use of DEA management in monitoring the Program. Thisrestriction is not intended to limit the distribution of thisreport, which is a matter of public record.

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS

The OIG, Audit Division, has audited the operation of DEA'sDomestic Cannabis Eradication/Suppression Program. The reviewcovered the period September 1, 1992 through August 31, 1994 andincluded a review of selected activities and transactions asdeemed necessary. The audit was conducted in accordance withgenerally accepted Government auditing standards. 

In connection with the audit, and as required by thestandards, we tested transactions and records to obtainreasonable assurance concerning the agency's compliance with lawsand regulations that, if not complied with, we believe would havea material effect on Program operations. Compliance with laws andregulations applicable to this Program is the responsibility ofDEA management. 

An audit includes examining, on a test basis, evidence aboutlaws and regulations. The specific laws and regulations for whichwe conducted tests are contained in:

Controlled Substance Act of the Comprehensive Drug AbusePrevention and Control Act of 1970; and 3751(b)(3) of Title 42USC, Grants to State and units of local government; purposes ofgrants, also known as the Edward Byrne Memorial State and LocalLaw Enforcement Assistance Programs.

Test results indicated that, for the items tested, weidentified no material instances of noncompliance with the abovelaws and regulations.

With respect to those transactions not tested, nothing came toour attention that caused us to believe that DEA management wasnot in compliance with the laws and regulations cited above.

APPENDIX I

SCOPE AND METHODOLOGY

The audit was conducted at DEA Headquarters and at severalstate and local agencies dealing with cannabis eradication. Weinterviewed DEA, BJA, and Departmental officials. Thesediscussions included the monitoring of and accounting forcannabis eradication funds. In each state, we interviewed DEApersonnel, along with state and local officials participating inthe Program, and reviewed state audit reports on this Program.When applicable, state and local officials involved with BJAfunded cannabis eradication efforts were also interviewed.Overall, we interviewed about 120 individuals. 

The audit included reviews of selected Program activities inten states (see Appendix II). These states were among thosereceiving the largest amount of Program funds, with the agenciesreviewed accounting for approximately 41 percent of the amountdisbursed to participants in 1993. 

Pursuant to DEA's request, at the state level the reviewfocused on whether states were spending Program funds forallowable purposes and in accordance with DEA guidelines. To thatend, the audit team tested selected financial transactions ineach state for FY 1993, and when documentation was available, FY1994. This testing primarily focused on whether state and localexpenditures were: (1) incurred in support of the DEA Program;(2) traceable to supporting documentation; and (3) approved byDEA officials, if required. The audit team also determinedwhether Program statistics reported to DEA by the state agencieswere supportable. In addition, the audit team observed a DEAorganized multi-agency cannabis eradication effort. Thisexperience gave the audit staff an operational perspective of theextensive planning and execution requirements of largeeradication operations. 

DEA officials indicated they spent approximately 7 percent ofthe Program funds to support their own activities in the Program.Specifically, in FY 1993, DEA expended approximately $722,000;these expenditures were excluded from the scope of this audit.

APPENDIX II -FEDERAL, STATE AND LOCAL AGENCIES REVIEWED/CONTACTED 

| AGENCY                                                                                                                                           | LOCATION                                                      |
|--------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------|
| DEA Headquarters                                                                                                                                 | Arlington, VA                                                 |
| California                                                                                                                                       |                                                          |
| DEA San Francisco Division
DEA Sacramento Resident        Office 

California Department of Justice - CAMP                                       | San Francisco, CA
Sacramento, CA

Rancho Cordova, CA          |
| Humboldt County Sheriff's Department                                                                                                             | Eureka, CA                                                    |
| Mendocino County Sheriff's Department                                                                                                            | Ukiah, CA                                                     |
| Office of Criminal Justice Planning                                                                                                              | Sacramento, CA                                                |
| San Diego County Sheriff's Department                                                                                                            | San Diego, CA                                                 |
| San Diego Police Department                                                                                                                      | San Diego, CA                                                 |
| Georgia                                                                                                                                          |                                                          |
| DEA Atlanta Division
Georgia Bureau of        Investigation                                                                                      | Atlanta, GA
Decatur, GA                                       |
| Georgia National Guard                                                                                                                           | Decatur, GA                                                   |
| Georgia State Patrol                                                                                                                             | Decatur, GA                                                   |
| Illinois                                                                                                                                         |                                                          |
| DEA Chicago Division
Central Illinois Enforcement        Group                                                                                   | Chicago, IL
Springfield, IL                                   |
| Illinois National Guard                                                                                                                          | Springfield, IL                                               |
| Illinois State Police                                                                                                                            | Springfield, IL, 
Lockport, IL, 

Effingham, IL               |
| Metropolitan Area Narcotics Squad                                                                                                                | Joliet, IL                                                    |
| Indiana                                                                                                                                          |                                                          |
| DEA Indianapolis Resident Office
Benton County        Sheriff's Department                                                                       | Indianapolis, IN
Fowler, IN                                   |
| Indiana National Guard                                                                                                                           | Indianapolis, IN                                              |
| Indiana State Police                                                                                                                             | Indianapolis, IN                                              |
| Lawrence County Sheriff's Department                                                                                                             | Bedford, IN                                                   |
| Kansas                                                                                                                                           |                                                          |
| DEA Wichita Resident Office
Kansas Bureau of        Investigation                                                                                | Wichita, KS
Topeka, KS                                        |
| Missouri                                                                                                                                         |                                                          |
| DEA St. Louis Division
Missouri Highway Patrol                                                                                                   | St. Louis, MO
Jefferson City, MO                              |
| Oklahoma                                                                                                                                         |                                                          |
| DEA Tulsa Resident Office
DEA McAlester Post of        Duty

DEA Oklahoma City Resident Office

Oklahoma Bureau of Narcotics and Dangerous Drugs | Tulsa, OK
McAlester, OK

Oklahoma City, OK

Oklahoma City, OK |
| Oklahoma Highway Patrol                                                                                                                          | Oklahoma City, OK                                             |
| Tennessee                                                                                                                                        |                                                          |
| DEA Nashville Resident Office
Tennessee Alcoholic        Beverage Commission                                                                     | Nashville, TN
Nashville, TN                                   |
| Tennessee Army National Guard                                                                                                                    | Nashville, TN                                                 |
| Tennessee Bureau of Investigation                                                                                                                | Nashville, TN                                                 |
| Tennessee State Highway Patrol                                                                                                                   | Nashville, TN                                                 |
| Texas                                                                                                                                            |                                                          |
| DEA Houston Division 
Texas Department of Public        Safety                                                                                   | Houston, TX
Austin, TX                                        |
| Washington                                                                                                                                       |                                                          |
| DEA Seattle Division
Clark County Sheriff's        Department                                                                                    | Seattle, WA
Vancouver, WA                                     |
| Grays Harbor County Sheriff's Department                                                                                                         | Aberdeen, WA                                                  |
| Washington State National Guard                                                                                                                  | Olympia, WA                                                   |
| Washington State Patrol                                                                                                                          | Olympia, WA                                                   |

APPENDIX III -DOMESTIC CANNABIS ERADICATION/SUPPRESSION LETTERS OF AGREEMENT 

| AGENCIES RECEIVING LOA FUNDS                                                                                                                                     | 1993 LOA
AMOUNT                        | 1994 LOA
AMOUNT                        |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------|----------------------------------------|
| Alabama
Department of Public Safety                                                                                                                              | $ 294,000                              | $ 321,689                              |
| Alaska
State Troopers                                                                                                                                            | 120,000                                | 122,000                                |
| Arizona
Pima County Sheriff's Department

Gila County Sheriff's Department

Mohave County Sheriff's Office                                                       | 37,500
37,500

37,500                  | 39,000
39,000

39,000                  |
| Arkansas
State Police                                                                                                                                            | 315,000                                | 320,000                                |
| California
Office of Criminal Justice        Programs

Bureau of Narcotic Enforcement/CAMP                                                                       | 400,000
355,000                        | 465,000
295,000                        |
| Colorado
County Sheriff's of Colorado

Police Chief's Association                                                                                                | 61,865
15,000                          | 65,000
13,000                          |
| Connecticut
State Police                                                                                                                                         | 42,000                                 | 45,000                                 |
| Delaware
State Police                                                                                                                                            | 7,900                                  | 7,900                                  |
| Florida
Department of Law Enforcement                                                                                                                            | 310,500                                | 290,000                                |
| Georgia
Bureau of Investigations                                                                                                                                 | 400,000                                | 395,000                                |
| Hawaii
Hawaii County Police

Honolulu Police Department

Maui County police Department

Kauai County Police Department

Department of Land and Natural Resources | 180,000
30,000

90,000

90,000

87,000 | 181,133
30,188

90,566

90,566

87,547 |
| Idaho
Bureau of Narcotics                                                                                                                                        | 50,500                                 | 52,000                                 |
| Illinois
State Police                                                                                                                                            | 406,000                                | 425,000                                |
| Indiana
State Police                                                                                                                                             | 330,000                                | 350,000                                |
| Iowa
Division of Narcotic Enforcement                                                                                                                            | 58,900                                 | 68,000                                 |
| Kansas
Bureau of Investigation                                                                                                                                   | 185,000                                | 138,750                                |
| Highway Patrol                                                                                                                                                   | 33,290                                 | 26,250                                 |
| Kentucky
State Police                                                                                                                                            | 480,000                                | 510,000                                |
| Louisiana
State Police                                                                                                                                           | 249,000                                | 278,000                                |
| Maine
Department of Public Safety/Bureau of        Intergovernmental Drug Enforcement                                                                            | $ 75,000                               | 77,500                                 |
| Maryland
State Police                                                                                                                                            | 75,000                                 | 75,000                                 |
| Massachusetts
State Police                                                                                                                                       | 55,000                                 | 57,000                                 |
| Michigan
State Police

Saginaw County                                                                                                                            | 121,000
20,000                         | 130,000
20,000                         |
| Minnesota
Bureau of Criminal Apprehension                                                                                                                        | 79,000                                 | 95,000                                 |
| Mississippi
Bureau of Narcotics                                                                                                                                  | 160,000                                | 170,000                                |
| Missouri
Highway Patrol                                                                                                                                          | 378,500                                | 378,500                                |
| Sheriff's Association                                                                                                                                            | 116,000                                | 116,500                                |
| Montana
Criminal Investigation Bureau                                                                                                                            | 67,000                                 | 65,000                                 |
| Nebraska
State Police                                                                                                                                            | 52,000                                 | 53,000                                 |
| Nevada
Division of Investigation                                                                                                                                 | 38,500                                 | 31,000                                 |
| New Hampshire
State Police                                                                                                                                       | 50,000                                 | 45,000                                 |
| New Jersey
State Police                                                                                                                                          | 80,000                                 | 75,000                                 |
| New Mexico
Sheriff's and Police Association                                                                                                                      | 40,000                                 | 50,000                                 |
| New York
State Police                                                                                                                                            | 125,000                                | 120,000                                |
| North Carolina
Bureau of Investigations                                                                                                                          | 118,000                                | 120,000                                |
| North Dakota
Office of Attorney General/Drug        Enforcement Unit                                                                                             | 37,000                                 | 40,000                                 |
| Ohio
Bureau of Criminal Identification and        Investigation                                                                                                  | 180,000                                | 209,500                                |
| Oklahoma
Bureau of Narcotics and Dangerous        Drugs                                                                                                          | 460,000                                | 251,000                                |
| Oregon
Sheriff's Association

Department of Justice                                                                                                              | 25,500
260,000                         | 25,500
260,000                         |
| Pennsylvania
State Police                                                                                                                                        | 88,000                                 | 90,000                                 |
| Rhode Island
Chiefs of Police Association                                                                                                                        | 15,200                                 | 16,000                                 |
| South Carolina
Law Enforcement Division                                                                                                                          | 104,400                                | 106,000                                |
| South Dakota
Division of Investigations                                                                                                                          | 79,500                                 | 99,000                                 |
| Tennessee
Bureau of Investigations                                                                                                                               | 469,000                                | 426,000                                |
| Memphis Police Department Organized Crime Unit                                                                                                                   | 21,500                                 | 19,000                                 |
| Texas
Department of Public Safety                                                                                                                                | 450,000                                | 380,000                                |
| Utah
Division of Investigations                                                                                                                                  | 60,000                                 | 65,000                                 |
| Vermont
State Police

Vermont Sheriff's Association                                                                                                              | 18,000
7,100                           | 20,000
7,500                           |
| Virginia
State Police                                                                                                                                            | 94,400                                 | 115,000                                |
| Washington
State Patrol                                                                                                                                          | 300,000                                | 335,000                                |
| West Virginia
Department of Public Safety                                                                                                                        | 75,000                                 | 107,000                                |
| Wisconsin
Division of Narcotics Enforcement                                                                                                                      | 168,800                                | 190,000                                |
| Wyoming
Office of Attorney General/Division        of Criminal Investigation                                                                                     | 11,000                                 | 12,000                                 |
| TOTALS
Number of LOA's64                                                                                                                                         | $ 9,277,855                            | $ 9,236,910                            |
| Number of LOA's Reviewed11                                                                                                                                       | $ 4,133,500                            | $ 3,839,750                            |

APPENDIX IV - BUREAUOF JUSTICE ASSISTANCE 

FORMULA GRANT PROGRAM AWARDS FOR MARIJUANAERADICATION 

| AGENCIES RECEIVING BJA FUNDS                             | 1993 BJA
GRANT |
|----------------------------------------------------------|----------------|
| California                                               |           |
| Butte County Sheriff's Department                        | $ 151,358      |
| County of Del Norte Sheriff's Department                 | 161,358        |
| El Dorado County District Attorney                       | 234,358        |
| Fresno County Sheriff Department                         | 166,358        |
| Humboldt County Sheriff's Department                     | 286,358        |
| County of Lake Sheriff's Department                      | 64,945         |
| County of Mendocino Sheriff's Department                 | 286,358        |
| Monterey Sheriff Department                              | 166,358        |
| County of Placer Sheriff's Department                    | 105,494        |
| Santa Cruz Sheriff Department                            | 211,358        |
| Shasta County Sheriff's Department                       | 189,945        |
| Siskiyou County Sheriff's Department                     | 196,048        |
| Sonoma County Sheriff's Office                           | 206,358        |
| Trinity County Sheriff's Department                      | 205,346        |
| Kansas                                                   |           |
| Kansas Bureau of Investigations                          | 530,813        |
| Louisiana                                                |           |
| East Baton Rouge Parish Sheriff's Department             | 35,000         |
| Tennessee                                                |           |
| Tennessee Alcoholic Beverage Commission                  | 56,250         |
| TOTALS
Number of BJA Grants for

Marijuana Eradication17 | $ 3,254,063    |
| Number of BJA Grantees
Interviewed 4                     | $ 1,159,779    |

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