```
                                                                 
Endangered Species: Research Strategy and Long-Term Monitoring	 
Needed for the Mojave Desert Tortoise Recovery Program		 
(09-DEC-02, GAO-03-23). 					 
                                                                 
Since the 1980s, biologists have been concerned about declines in
the Mojave Desert Tortoise, which ranges through millions of	 
acres in the western United States. The tortoise was first listed
as a threatened species under the Endangered Species Act in Utah 
in 1980; it was later listed as threatened rangewide in 1990. The
listing and designation of critical habitat for the tortoise, as 
well as recommendations in the tortoise recovery plan, have been 
controversial. In our report, we evaluate--assisted by scientists
identified by the National Academy of Sciences--the scientific	 
basis for key decisions related to the tortoise, assess the	 
effectiveness of actions taken to conserve desert tortoises,	 
determine the status of the population, and identify costs and	 
benefits associated with desert tortoise recovery actions.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-23						        
    ACCNO:   A05698						        
  TITLE:     Endangered Species: Research Strategy and Long-Term      
Monitoring Needed for the Mojave Desert Tortoise Recovery Program
     DATE:   12/09/2002 
  SUBJECT:   Endangered species 				 
	     Wildlife						 
	     Wildlife conservation				 
	     Land management					 
	     Cost analysis					 
	     Arizona						 
	     California 					 
	     Nevada						 
	     Utah						 

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GAO-03-23

Report to Congressional Requesters

United States General Accounting Office

GAO

December 2002 ENDANGERED SPECIES Research Strategy and Long- Term
Monitoring Needed for the Mojave Desert Tortoise Recovery Program

GAO- 03- 23

The 1990 listing of the desert tortoise, the critical habitat designation,
and recommendations in the recovery plan for the tortoise were reasonable,
given the information available at the time. Under the Endangered Species
Act, listing and critical habitat decisions must be based on the best
available scientific and commercial data. These decisions and the recovery
plan recommendations were based on sources that reflected existing
knowledge about desert tortoises.

To protect the tortoise, government agencies have restricted grazing and
off- road vehicle use and taken other protective actions in desert
tortoise habitat, but the effectiveness of these actions is unknown.
Research is underway in several areas, including tortoise disease,
predation, and nutrition, but the research has not assessed the
effectiveness of the protective actions. Furthermore, the status of desert
tortoise populations is unclear because data are unavailable to
demonstrate population trends. Before the tortoise may be delisted,
populations must increase or remain stable for at least 25 years* one
generation of desert tortoises. Determining the trends will cost an
estimated $7.5 million in the first 5 years, plus additional monitoring
every 3 to 5 years at a cost of about $1.5 million per year of monitoring.
The Fish and Wildlife Service depends on other agencies and organizations
to assist with funding and monitoring, but these agencies and
organizations cannot guarantee assistance from year to year because of
other priorities.

Expenditures on desert tortoise recovery since the species* first listing
in 1980 exceed $100 million, but the exact investment is unknown. The
investment includes $92 million in *reasonably identifiable* expenditures
for the tortoise, plus staff time valued at about $10.6 million. The
overall economic impact of the tortoise recovery program* including
benefits as well as the costs incurred by local governments, landowners,
and developers as a result of restrictions* is unknown.

Left to right: desert tortoise; researcher weighing desert tortoise.

ENDANGERED SPECIES

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

www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 23. To view the full report,
including the scope and methodology, click on the link above. For more
information, contact Barry T. Hill at (202) 512- 3841, hillb@ gao. gov.
Highlights of GAO- 03- 23, a report to the

Chairman, Committee on Resources, House of Representatives, and Senator
Robert Bennett

December 2002

Since the 1980s, biologists have been concerned about declines in the
Mojave Desert Tortoise, which ranges through millions of acres in the
western United States. The tortoise was first listed as a threatened
species under the Endangered Species Act in Utah in 1980; it was later
listed as threatened rangewide in 1990. The listing and designation of
critical habitat for the tortoise, as well as recommendations in the
tortoise recovery plan, have been controversial. In our report, we
evaluate* assisted by scientists identified by the National Academy of
Sciences* the scientific basis for key decisions related to the tortoise,
assess the effectiveness of actions taken to conserve desert tortoises,
determine the status of the population, and identify costs and benefits
associated with desert tortoise recovery actions.

To ensure that the most effective actions are taken to protect the
tortoise, we recommend that the Fish and Wildlife Service develop and
implement a coordinated research strategy for linking land management
decisions with research results and periodically reassess the recovery
plan for the tortoise. We also recommend that the Secretary of the
Interior identify and assess options for funding long- term rangewide
population monitoring. The department concurred with our recommendations.

Page i GAO- 03- 23 Mojave Desert Tortoise Letter 1

Results in Brief 2 Background 5 Listing, Critical Habitat Designation, and
Recommendations

for Recovery Were Reasonable 8 Actions Have Been Taken to Protect the
Desert Tortoise, but Their

Effectiveness Is Unknown 12 Data Are Insufficient to Determine the Status
of the Desert

Tortoise Rangewide, and Continued Funding for Monitoring Is Uncertain 20
Expenditures for Desert Tortoise Recovery Exceed $100 Million,

but the Total Economic Impact Has Not Been Quantified 22 Conclusions 32
Recommendations for Executive Action 33 Agency Comments and Our Evaluation
34

Appendix I Actions on Behalf of the Mojave Desert Tortoise 35

Appendix II Objectives, Scope, and Methodology 45

Appendix III Comments from the Department of the Interior 52

Appendix IV GAO Contact and Staff Acknowledgments 53

Tables

Table 1: Acres Designated as Critical Habitat, by Landowner and State 10
Table 2: Federal and State Agencies* Expenditures on the Desert

Tortoise, Fiscal Years 1989 through 1998 24

Figures

Figure 1: Mojave Desert Tortoise 5 Figure 2: Map of Mojave Desert
Tortoise*s Range 6 Contents

Page ii GAO- 03- 23 Mojave Desert Tortoise

Figure 3: Shells of Juvenile Desert Tortoises Likely Killed by Ravens 7
Figure 4: Percentage of Threat Related Topics Presented at Desert

Tortoise Council Symposia, by Topic, 1989 through 2001 17 Figure 5:
Reported Expenditures on the Desert Tortoise, Fiscal

Years 1989 through 1998 25 Figure 6: Total Expenditures, Including Land
Acquisition, for

Species with the Highest Expenditures, Fiscal Years 1989 through 1998 26
Figure 7: Trend in Five Agencies* Staff- Time Investment in Tortoise

Work, Fiscal Years 1980 through 2001 29

Abbreviations

BLM Bureau of Land Management DFG Department of Fish and Game ERS Economic
Research Service OMB Office of Management and Budget

Page 1 GAO- 03- 23 Mojave Desert Tortoise

December 9, 2002 The Honorable James V. Hansen Chairman, Committee on
Resources House of Representatives

The Honorable Robert Bennett United States Senate

Since the 1980s, biologists have been concerned about apparent declines in
populations of the Mojave desert tortoise, a species that is considered to
be an indicator of the health of the desert environment. The desert
tortoise ranges through millions of acres in Arizona, California, Nevada
and Utah. 1 Population declines in the species may be caused in part by a
contagious, and sometimes fatal, upper respiratory tract disease and by
other factors such as drought, predation, illegal collection, and habitat
degradation or loss associated with human activities such as development,
livestock grazing, and recreation. Together, these conditions led the
Department of the Interior*s Fish and Wildlife Service (Service) to
protect the desert tortoise under the Endangered Species Act. 2 In 1980,
the Service designated, or *listed,* a portion of the desert tortoise
population in Utah as *threatened.* In 1989, the Service temporarily
listed the rest of the Mojave population of desert tortoises as
*endangered* on an emergency basis because of an outbreak of upper
respiratory tract disease. In 1990, the Service issued its final
determination that the Mojave population of desert tortoises was
*threatened* throughout its range.

The goal of the Endangered Species Act is to restore species that are at
risk of extinction so that they can live in self- sustaining populations.
At the time a species is listed, the act generally requires the Service to
designate critical habitat essential to the conservation of the species.
In 1994, the Service designated critical habitat covering 6.4 million
acres in the desert tortoise*s range. The critical habitat encompasses
federal land managed by the Department of the Interior*s Bureau of Land
Management (BLM) and National Park Service, as well as Department of
Defense installations, and

1 All desert tortoises discussed in this report belong to the Mojave
population. Other desert tortoises found in the United States belong to
the Sonoran population. 2 16 U. S. C. 1531 et seq. Species are designated
as endangered or threatened, depending on their risk of extinction: an
endangered species is at risk of extinction in all or a significant
portion of its range, and a threatened species is likely to become
endangered in the foreseeable future.

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 03- 23 Mojave Desert Tortoise

state- and privately- owned land. Shortly after designating critical
habitat, the Service published a recovery plan for the desert tortoise. To
protect desert tortoises, the plan recommends restrictions, among other
things, on off- road vehicle access, military maneuvers that destroy
habitat, clearing for agriculture and development, and livestock grazing.
Some of these restrictions have been controversial, and some users
question whether the restrictions are necessary to the desert tortoise*s
recovery. The plan also recommends monitoring to determine the status of
desert tortoise populations and track their population trends. Under the
act, when a population is considered stable and no longer needs the act*s
protection, the species may be removed from the threatened or endangered
list.

In this report, we (1) evaluate the scientific basis for the 1990 listing,
the critical habitat designation, and the recovery plan recommendations
for the desert tortoise; (2) assess the effectiveness of actions taken by
federal agencies and others to conserve desert tortoises; (3) describe
what is known about trends in tortoise populations; and (4) identify costs
and benefits associated with desert tortoise recovery actions since the
desert tortoise was first listed in 1980, to the extent that data were
available.

To evaluate the scientific basis for the listing decision, critical
habitat designation, and recovery plan recommendations, we contracted with
the National Academy of Sciences to identify and assist in the selection
of scientists with expertise in relevant areas, such as conservation
biology and desert ecology, to provide technical assistance in reviewing
the reasonableness of those key decisions in light of the scientific
information on which they were based. The scientists we consulted and
other details on the scope and methodology of our review are presented in
appendix II.

The scientists we consulted agreed that the 1990 listing, the critical
habitat designation, and the recommendations in the recovery plan for the
desert tortoise were reasonable, given the information available at the
time. The Endangered Species Act requires that listing decisions and
critical habitat designations be based on the best available scientific
and commercial data (i. e., biological or trade data such as that obtained
from scientific or commercial publications), and that recovery plans be
developed and implemented if doing so would conserve the species. The
listing decision, critical habitat designation, and recovery plan
recommendations for the tortoise were based on diverse sources; as is
often the case with an at- risk species, limited published research was
available, and the Service also relied on unpublished research and
government reports. Results in Brief

Page 3 GAO- 03- 23 Mojave Desert Tortoise

Federal agencies and others, including BLM, the National Park Service,
military installations, and state and local governments, have taken a
variety of actions to benefit desert tortoises, but the effectiveness of
these actions is unknown because the necessary analyses have not been
done. In response to recommendations in the recovery plan, agencies have
restricted off- road motorized vehicle use, livestock grazing, and other
activities in tortoise habitat; closed illegal garbage dumps to reduce
feeding opportunities for ravens that prey on young desert tortoises;
fenced highways to keep tortoises from being run over; and implemented
educational programs to inform the public about tortoise conservation.
Some of the actions are controversial, such as restrictions on livestock
grazing. As also recommended in the recovery plan, research efforts are
underway in tortoise health and life history, disease, predation by
ravens, and effects of livestock grazing and off- road vehicles, among
other areas, but most research has not been directed to assessing the
effectiveness of land use restrictions and other protective actions.
Without knowing how effective the protective actions are, the Service and
land managers cannot ensure that their limited resources are focused on
the most effective actions. Furthermore, the recovery plan recommends
reassessment of its findings and recommendations every 3 to 5 years in
light of ongoing research. However, the Service has not reassessed the
plan for a number of reasons, such as other pressing needs for limited
resources. Given the controversy surrounding some of the recommended
restrictions and the large number of acres and land users affected, we
believe that it is important to ensure that management decisions are
supported by research. Accordingly, we are recommending that the Service
and land management agencies develop and implement a coordinated research
strategy to link land management decisions and research results, and that
the Service reassess the recovery plan and revise it as necessary.

Data are not available to demonstrate population trends so despite actions
taken to benefit tortoises, the status of desert tortoise populations is
unclear. Under the recovery plan, before the tortoise may be considered
for removal from the list of threatened and endangered species, a
scientifically credible monitoring plan must show that the population has
increased or remained stable for at least 25 years (one generation of
desert tortoises). For decades, researchers have gathered data on the
health and status of desert tortoise populations in certain study areas,
but these data cannot be reliably extrapolated to the entire population.
In 2001, the Fish and Wildlife Service began a monitoring effort to
develop a baseline estimate of desert tortoise populations rangewide.
Developing the baseline will require a total of 5 years to complete at an
estimated total cost of approximately $7.5 million. Determining population
trends will require additional monitoring every 3 to 5 years and will cost
approximately

Page 4 GAO- 03- 23 Mojave Desert Tortoise

$1.5 million per year of monitoring. To assist with funding and conducting
the monitoring, the Service depends on other agencies and organizations.
However, because these agencies and organizations have other priorities,
they cannot guarantee assistance from year to year. Because population
trend monitoring is essential to understanding how desert tortoises are
faring and to ultimately delist the species, we are recommending that the
Secretary of the Interior work with the Secretary of Defense to identify
and consider alternative ways to ensure continued funding, such as through
memorandums of agreement.

Expenditures on desert tortoise recovery exceed $100 million (in constant
2001 dollars) since the species* first listing in 1980, but the exact
investment to date is not known. Only since fiscal year 1989 has the
Service been required to annually compile and report to the Congress
federal and state expenditures on a species- by- species basis. These
expenditures are only those that are *reasonably identifiable* for a
listed species, such as expenditures for land acquisitions, project
materials, or staff time spent on activities to protect the species. For
fiscal years 1989 through 1998, the Service reported that federal agencies
and states spent a total of about $92 million (in constant 2001 dollars)
on behalf of the desert tortoise. The $92 million spent on the desert
tortoise represented about 2.8 percent of the $3.3 billion that agencies
reported spending on all threatened and endangered species from fiscal
years 1989 through 1998. Comprehensive data on reported expenditures since
1998 were not available because the Service has not compiled and issued to
the Congress an annual expenditure report, as required. According to the
Service, timely issuance of the report has been hampered by some agencies*
tardiness in submitting the requested data, among other things. To augment
the reported expenditure data, we requested estimates of the time that
staff from five key agencies spent on tortoise- related activities since
1980. During the years not covered by the annual expenditures report (i.
e., 1980 through 1988 and 1999 through 2001), these five agencies reported
spending staff time valued at about $10.6 million on tortoise- related
activities. Aside from the federal and state expenditures, the overall
economic impact (e. g., benefits as well as the costs incurred by local
governments, landowners, and developers as a result of restrictions)
associated with the tortoise recovery effort is unknown, although some
limited analyses have been done. To improve reporting of expenditures for
threatened and endangered species, we are making recommendations intended
to ensure the timeliness of the Service*s report to the Congress.

We provided the Departments of Defense and the Interior with a draft of
this report for review and comment. The Department of the Interior
concurred with all of our recommendations and provided several technical

Page 5 GAO- 03- 23 Mojave Desert Tortoise

clarifications that we have made as appropriate. The department*s letter
is presented in appendix III. The Department of Defense provided oral
comments consisting of technical clarifications that we have made as
appropriate.

The Mojave Desert tortoise is a relatively large reptile, with adults
measuring up to 15 inches in shell length (see fig. 1). Desert tortoises
live in creosote bush and Joshua tree habitats in valleys, plains, and
washes at elevations generally ranging up to 4,000 feet above sea level.
In these habitats, desert tortoises construct and live in burrows and
spend a majority of their life below ground. Desert tortoises may live for
50 years or more in the wild, and females do not breed until they are at
least 15 years old. They usually lay one or more clutches of about 6 to 8
eggs between mid- April and the first week of July. Although desert
tortoises can withstand prolonged periods of drought, females may not lay
eggs if forage is unavailable. Survival of juveniles is thought to be low;
some researchers estimate that only 2 to 3 per 100 hatched may live to
become adults.

Figure 1: Mojave Desert Tortoise

Background

Page 6 GAO- 03- 23 Mojave Desert Tortoise

The Mojave Desert tortoise*s range lies north and west of the Colorado
River in California, southern Nevada, southwestern Utah, and northwestern
Arizona (see fig. 2).

Figure 2: Map of Mojave Desert Tortoise*s Range

Apparent declines in tortoise populations have been attributed to many
factors including habitat loss or degradation, drought, and predation on
juvenile tortoises by ravens, coyotes, domestic dogs, and other animals
(see fig. 3). According to the Service, habitat loss has occurred as a
result of increasing amounts of urban development, military operations,
and recreational uses such as off- road vehicle use, in the tortoise*s
range. Habitat degradation has been attributed to domestic livestock
grazing, particularly in livestock watering and loading areas. Other
factors that may have caused population declines include mortality through
vandalism or accidental road kill and removal of tortoises from their
habitat for pets, food, or commercial purposes. Respiratory and shell
diseases have also been observed in desert tortoise populations.

Page 7 GAO- 03- 23 Mojave Desert Tortoise

Figure 3: Shells of Juvenile Desert Tortoises Likely Killed by Ravens
(quarter dollar shows scale)

Before a species, such as the desert tortoise, can receive protection
under the Endangered Species Act, the Secretary of the Interior, through
the Fish and Wildlife Service, is required to use the best available
scientific and commercial data (e. g., biological or trade data obtained
from scientific or commercial publications, administrative reports, maps
or other graphic materials, or experts on the subject) to decide whether
the species is at risk of extinction. The Endangered Species Act specifies
the following five factors for identifying at- risk species, any one of
which is sufficient to determine that a species qualifies for the act*s
protections:

 present or threatened destruction, modification, or curtailment of a
species habitat or range;  overuse for commercial, recreational,
scientific, or educational purposes;  disease or predation;  inadequacy
of existing regulatory mechanisms; or  other natural or manmade factors
affecting a species* continued existence.

Once the Service determines that a species should receive the act*s
protection, it can list the species as threatened or endangered. As of
July 2002, 517 animal species and 744 plant species were listed as
threatened or endangered in the United States.

The act prohibits the *taking* of any listed species of animal and defines
*take* as to harass, harm, pursue, shoot, wound, kill, trap, capture, or

Page 8 GAO- 03- 23 Mojave Desert Tortoise

collect, or to attempt to engage in any such conduct. However, under the
act the Service may issue permits that allow the taking of a listed
species if the taking is incidental to, rather than the purpose of, an
otherwise legal activity. In most cases, the Service must develop a
recovery plan for listed species that specifies actions needed to recover
the species so that it can be removed from the list of protected species
under the act, or *delisted.* 3

Federal agencies must comply with prohibitions against taking a threatened
or endangered species and must consult with the Service to determine the
effect, if any, that their activities may have on listed species. In
particular, federal agencies must ensure that their activities do not
jeopardize the continued existence of any endangered or threatened
species, or result in destruction or adverse modification of critical
habitat. 4 If any proposed activities will jeopardize a species or
adversely modify its critical habitat, the Service will identify
reasonable and prudent alternative activities. In addition, federal
agencies have a broader directive under the act to use their authorities
to carry out programs to conserve threatened and endangered species.

Scientists we consulted agreed that the listing of the desert tortoise in
1990, the critical habitat designation, and the recommendations in the
recovery plan were reasonable, based on the limited data available on the
desert tortoise when the relevant decisions were made. These decisions
were made on the basis of a variety of information, including published
and unpublished research and government studies. The scientists we
consulted recognized that, as is often the case when making such
decisions, little published data on the species were available. However,
they agreed that the Service*s decisions were appropriate and consistent
with their understanding of the agency*s responsibilities under the act.

The Endangered Species Act requires that listing decisions be based solely
on the best scientific and commercial data available without taking into
account economic factors. Although the Service is required to seek out the
best data available at the time, it is not required to generate additional
data. The listing decision for the desert tortoise was based on a variety
of

3 A recovery plan is required unless the Secretary finds that such a plan
will not promote the conservation of the species. 4 The act*s protections
against take extend to any area where the species occurs, not just in its
critical habitat. Listing,

Critical Habitat Designation, and Recommendations for Recovery Were
Reasonable

Listing and Critical Habitat Decisions Were Based on the Best Science
Available at the Time

Page 9 GAO- 03- 23 Mojave Desert Tortoise

information, including published research, meeting and symposium
proceedings, and government reports. Generally, published, peer- reviewed
research is considered the most reliable information source because the
research methods and conclusions have been reviewed by other scientists
before publication. However, other sources such as unpublished research,
meeting proceedings, and government reports can provide important
information for making listing and other decisions. Moreover, several
scientists said that listing decisions are often necessarily based on
limited data, because funding for research on a species is typically
scarce until after that species is listed.

The listing decision describes how each of the five listing criteria that
make a species eligible for protection under the act applies to the desert
tortoise, with habitat loss and disease cited as threatening the
tortoise*s continued existence. The scientists we consulted agreed that,
despite the limited amount of quantitative data on the desert tortoise
that was available at the time of its listing, the decision to list it as
threatened was reasonable. In particular, they cited increases in threats
such as diseases and habitat loss as important factors making listing
necessary. In addition, researches noted declines in numbers. For example,
in the western Mojave Desert in California, researchers found that some
populations decreased by as much as 90 percent between the 1970s and the
mid- 1990s; in Nevada, study plots also generally showed declines ranging
from 10 to 39 percent since the late 1970s. The scientists we consulted
also noted that desert tortoise populations appear to continue to decline.
Some said that the listing of the desert tortoise was an unusual step by
the Service because, at the time of the listing, there were still desert
tortoises occurring across a large range; yet they recognized that listing
it as threatened was consistent with their understanding of the act*s
intent to protect species whose numbers are declining and are at risk of
becoming endangered.

When designating critical habitat, the Service must also use the best
scientific and commercial information available. Unlike for listings,
however, the Service must also consider the economic impact of the
critical habitat designation. The primary source of information for the
designation was a draft of the recovery plan for the tortoise that
recommended protection for 14 separate areas of habitat. The Service
adjusted the boundaries for these 14 areas to generally follow legal
property boundaries and elevation contours in order to remove as much
unsuitable habitat as possible and to reflect additional biological
information. Some areas that were already protected, such as Joshua Tree
National Monument and the Desert National Wildlife Range, were intended

Page 10 GAO- 03- 23 Mojave Desert Tortoise

to be excluded from critical habitat because the habitat within them was
already receiving protection as desert tortoise habitat. 5 After making
these adjustments, the Service identified 12 areas in its final critical
habitat designation* seven in California, one in Nevada, one in Utah, and
three that span more than one state* that total about 6.4 million acres
(see table 1). 6

Table 1: Acres Designated as Critical Habitat, by Landowner and State
Landowner Arizona California Nevada Utah Total acres

Federal BLM a 286,800 2, 375,807 1, 085,000 89,400 3, 837,007 Military 0
242,200 0 0 242,200 National Park Service a 41,600 955,313 103,600 0
1,100,513 State 5, 700 132,900 0 27,600 166,200 Private b 600 1,051,500
35,800 12,100 1, 100,000

Total acres 334,700 4, 757,720 1, 224,400 129,100 6, 445,920

Source: GAO*s analysis of data from the U. S. Fish and Wildlife Service
and the National Park Service. a BLM in California originally had
3,327,400 acres of critical habitat, but the total was reduced to

2,375,807 acres after 179,130 acres of critical habitat were transferred
to Joshua Tree National Park under the California Desert Protection Act of
1994; another 772,463 acres of critical habitat became part of the Mojave
National Preserve, which was created under the 1994 act. b Includes 1,600
acres owned by the Paiute Indian Tribe in Utah.

The scientists we consulted said the size and number of the areas
designated as critical habitat were reasonable given the available data,
but found that the rationales for drawing the specific boundaries were not
well explained in the decision documents. The size of the areas was
determined based on estimates of how dense a desert tortoise population
should be to ensure the population*s continued existence* estimates that
the scientists noted were based on limited quantitative research. Several
of the scientists we consulted observed that the critical habitat areas
appear to have been designated where desert tortoise populations were
found at the time. One scientist suggested that the designation of the
areas of

5 However, according to a National Park Service official, 3, 720 acres of
critical habitat were originally included in the boundary of Joshua Tree
National Park, possibly due to a mapping error.

6 Of the three areas spanning more than one state, one is in Arizona and
Nevada, one is in Arizona, Nevada, and Utah, and one is in California and
Nevada.

Page 11 GAO- 03- 23 Mojave Desert Tortoise

critical habitat may have been conservative, and that if the designation
was done today, the protected areas might be even larger.

In contrast with the requirements for listing and critical habitat, the
Endangered Species Act does not specify the type of information that
should be used to develop recovery plans. Instead, the act requires that
recovery plans contain three specific elements: (1) a description of
sitespecific management actions necessary for the conservation and
survival of the species; (2) objective, measurable criteria that, when
met, would result in the removal of the species from the threatened or
endangered species list, or delisting; and (3) estimates of the time and
cost required to carry out the plan. However, Service policy dictates that
recovery plans should seek the best information to achieve recovery of a
species. While not in effect at the time the tortoise recovery team was
founded, Service policy is that teams developing recovery plans should
have diverse areas of expertise and may include personnel from many
different organizations, including officials from other federal agencies
and states, and other recognized experts. 7 According to the Service,
recovery plans impose no obligations on any agency, entity, or persons to
implement the various tasks contained within them.

The recovery plan for the desert tortoise addresses each of the three
required elements. The plan describes site- specific management actions
for the 14 separate areas that it recommends be established such as
discontinuing livestock grazing, constructing fencing along highways to
reduce tortoise road kill, monitoring the health of desert tortoises
within the areas, eliminating raven nest and perch sites, constructing
signs to delineate the boundaries of the protected areas, and restricting
off- road vehicle use. The plan also recommends that agencies develop
programs and facilities to educate the public about the status and
management needs of the desert tortoise and its habitat, and that research
be conducted to monitor and guide recovery efforts. In addition, the plan
includes estimates of the time frame and costs for implementation. Lastly,
as the act requires, the plan describes the criteria that must be met
before the desert tortoise population may be considered for delisting. The
criteria are:

7 59 Fed. Reg. 126, p. 34272 (Jul. 1, 1994). The Recovery Plan*s

Recommendations Reflected Available Scientific Information

Page 12 GAO- 03- 23 Mojave Desert Tortoise

 as determined by a scientifically credible monitoring plan, the
population within a recovery unit must exhibit a statistically significant
upward trend or remain stationary for at least 25 years (one desert
tortoise generation);  enough habitat must be protected within a recovery
unit, or the habitat

and desert tortoise populations must be managed intensively enough to
ensure long- term population viability;  provisions must be made for
population management within each recovery

unit so that population growth rates are stable or increasing; 
regulatory mechanisms or land management commitments must be

implemented that provide for long- term protection of desert tortoises and
their habitat; and  the population in a recovery unit is unlikely to need
protection under the

Endangered Species Act in the foreseeable future. The scientists we
consulted agreed that the recommendations in the recovery plan describing
site- specific management actions are reasonable, and reflect the best
information available at the time. They observed that because much was
still unknown about the severity of specific threats to desert tortoises
at the time the plan was developed, its recommendations were made without
establishing priorities that would reflect differences in the seriousness
of the threats. For example, the plan does not differentiate among the
seriousness of the threats from uncontrolled vehicle use off designated
roads as compared to livestock grazing or dumping and littering.
Nonetheless, the scientists commented that the plan was a significant,
resource- intensive effort; indeed, one scientist commented that the
expertise of the scientists comprising the recovery team was
unprecedented. The team included experts in reptile and tortoise biology,
desert ecosystems, population analyses, and conservation biology. The team
also coordinated with numerous people and organizations, including federal
and state agencies and officials, and others with expertise in desert
tortoise and land management issues.

Federal agencies and others have taken a variety of actions to benefit
desert tortoises, reflecting recommendations in the recovery plan or
efforts to minimize the effects of potentially harmful activities, but the
effectiveness of those actions is not known because the necessary analyses
to measure their effectiveness have not been done. Federal, state, and
local agencies and others have acquired habitat, restricted certain uses,
and promote education programs about the species, and research has been
conducted or is underway on such topics as the causes of disease in
tortoises, their nutritional needs, and the effects of human activities on
tortoises. However, no process has been established for integrating
agencies* management decisions regarding the desert tortoise with Actions
Have Been

Taken to Protect the Desert Tortoise, but Their Effectiveness Is Unknown

Page 13 GAO- 03- 23 Mojave Desert Tortoise

research results. As a result, Service and land managers cannot be certain
that they are focusing their limited resources on the most effective
actions. In addition, the recovery plan recommends that its
recommendations be reassessed every 3 to 5 years, but the plan has not
been reassessed since its 1994 issuance. Such a reassessment would allow
the Service to evaluate whether the plan*s recommendations are still sound
or should be revised in light of more recent research.

The recovery plan recommends securing habitat to aid in the recovery and
continued existence of the desert tortoise. In addition to managing land
they already own, federal and state agencies* which collectively manage
over 80 percent of tortoise critical habitat* and private groups have made
efforts to acquire privately owned land for desert tortoise habitat
through land exchanges, purchases, or donations. Much of the acquired land
is surrounded by or adjacent to federally or state- owned tortoise
habitat, and its acquisition makes management easier by consolidating
acres needing protection. These land acquisitions have occurred primarily
in California and Utah, as almost all tortoise critical habitat in Nevada
and Arizona is already federally owned. For example, from 1995 through
2001, BLM acquired approximately 337,000 acres in California, valued at
almost $38 million, primarily for the benefit of the desert tortoise. Land
acquisition has also been an important feature in Utah, where BLM and the
State of Utah have acquired, through purchase and exchange, more than
7,700 acres of nonfederal land valued at almost $62 million, for the
benefit of the tortoise. In addition to these acquisitions, the Desert
Tortoise Preserve Committee, a nonprofit organization, acquired more than
175 acres of privately owned lands within the 39.5- square- mile Desert
Tortoise Natural Area in California. The Committee, in cooperation with
another conservation organization, also purchased 1,360 acres of privately
owned land in desert tortoise critical habitat in the central Mojave
Desert. The Committee has historically donated or sold land it acquires to
the federal government or the state of California.

The recovery plan for the desert tortoise also recommends specific land
use restrictions such as restricting livestock grazing, harmful military
maneuvers, and excessive and destructive recreational uses. The
responsibility for implementing many of these actions falls to the
entities that manage land in desert tortoise habitat, including the Bureau
of Land Management, the National Park Service, the Department of Defense,
and state agencies. These agencies have restricted some permitted uses on
lands with tortoise habitat and taken protective steps to aid in the
species* recovery. For example, Washington County, Utah, purchased permits
allowing livestock grazing on 30,725 acres of federal land in tortoise
Many Actions Have Been

Taken or Are Underway to Protect Tortoises

Page 14 GAO- 03- 23 Mojave Desert Tortoise

habitat in Utah at a cost of $114,000 from ranchers who were willing to
sell their land. BLM then retired these permits from use. In addition,
since 1991, BLM has prohibited sheep grazing on more than 800, 000 acres
of tortoise habitat in California; the agency has also restricted cattle
grazing in all or part of several other grazing allotments in California
either entirely or seasonally when tortoises are active, as part of a
settlement agreement with conservation groups. 8 The recovery plan*s
recommended restrictions on livestock grazing are controversial because
they affect a large number of acres and were recommended on the basis of
limited published data. Other significant restrictions that benefit the
tortoise include those addressing off- highway vehicles. For example,
BLM*s offhighway vehicle management plan limits off- highway vehicle use
to existing approved areas, specific courses for competitive events, or
designated roads and trails to protect sensitive habitats, species, and
cultural resources. However, officials note that enforcing compliance
among individual users has proven to be difficult.

Agencies have also undertaken projects on their lands to control random
events such as road kill on highways and human vandalism, and other
threats that are associated with human development, such as disease (which
may be spread when captive tortoises are released into the wild) and
predation by ravens and other animals (which are aggravated by humans
through the presence of landfills and other sources of food and water).
For example, agencies and others have installed hundreds of miles of
fencing to keep tortoises away from roads and other hazardous areas.
Joshua Tree National Park installed breaks, or *tortoise cuts,* in the
curbs along more than 5 miles of newly constructed park roads in 2001 to
avoid trapping desert tortoises in roads. To reduce raven populations and
thus discourage predation on juvenile tortoises, Mojave National Preserve
has cleaned up approximately 50 acres of illegal garbage dumps, and Joshua
Tree National Park has removed a total of almost 550,000 pounds of garbage
from 23 sites. The Army*s National Training Center at Fort Irwin also
tries to reduce raven populations by covering its landfill with three
times as much dirt as it would otherwise in order to reduce its
attractiveness to the birds. In 2000 and 2001, Edwards Air Force Base

8 These restrictions are required by a settlement agreement with
environmental groups that sued BLM because it did not consult with the
Fish and Wildlife Service about the effects of its land use plans for the
California Desert on endangered species. The restrictions will remain in
place until BLM receives a biological opinion from the Service on the
effects of its California Desert Conservation Area Plan, and then
finalizes and implements amendments to the plan.

Page 15 GAO- 03- 23 Mojave Desert Tortoise

closed 42 *pitfalls* (such as mine shafts, wells, and irrigation pipes) in
critical habitat that were potentially hazardous to desert tortoises.

Protective actions may also be required to offset, or mitigate, the
effects of potentially harmful activities. For example, development may
occur on nonfederal lands with desert tortoises, but before the Service
will issue a permit allowing tortoises to be taken or habitat to be
disturbed, the applicant must develop a plan describing mitigating
actions* such as timing a project to minimize the likelihood of disturbing
tortoises, acquiring replacement habitat to compensate for the disturbed
acreage, or the payment of fees to be used for tortoise conservation. Some
local governments have obtained permits that allow tortoises to be taken
so that habitat within their jurisdictions can be developed. For example,
Clark County, Nevada* which includes Las Vegas* has obtained a 30* year
permit from the Fish and Wildlife Service that allows listed species,
including tortoises, to be taken incidental to development in the county.
The permit allows development of up to 145,000 acres of desert tortoise
habitat on nonfederal land and requires that land developers pay $550 to a
mitigation fund for every acre developed within the county. The mitigation
fees are used to pay for conservation projects in the county to offset the
effects of development on desert tortoises and other species. Similarly,
Washington County, Utah, has a 20- year permit authorizing the take of
1,169 tortoises incidental to land development in the county. Washington
County*s primary means of mitigating the effects of development on desert
tortoises was to establish the 61,000- acre Red Cliffs Reserve in which no
development is allowed; approximately 39,000 acres are occupied desert
tortoise habitat. BLM and the state of Utah manage most of the land within
the reserve. Elsewhere in the county, development is allowed on
approximately 12,000 acres of nonfederal land. Developers pay $250 plus
0.2 percent of the development costs for each acre they develop; the fees
are used to manage the reserve.

Agencies and others also rely on education to reduce threats to tortoises.
For example:

 Department of Defense installations in tortoise habitat require all
soldiers to attend training that raises their awareness about the status
of the tortoise and teaches them what to do if they encounter a tortoise,
 BLM*s Statewide Desert Tortoise Management Policy includes a detailed

public education program,  Joshua Tree National Park and the Mojave
National Preserve have

developed educational kits for use in schools, and

Page 16 GAO- 03- 23 Mojave Desert Tortoise

 Clark County, Nevada, uses radio and newspaper announcements to target
desert users, reminding them to deposit garbage only at garbage dumps in
order to control raven populations, shoot responsibly, and drive on roads.

Appendix I discusses specific actions agencies have taken in more detail.
The recovery plan recommends that research be conducted to guide and
monitor desert tortoise recovery efforts and states that as new
information continues to become available, these new data should influence
management practices. The recovery plan recommends research on threats to
tortoises including diseases and other sources of mortality, the long-
term effects of road density and activities like livestock grazing on
desert tortoise populations, and the effectiveness of protective measures
in reducing human- caused desert tortoise mortality; it also recommends
that a comprehensive model of the life history of the desert tortoise be
developed, as such information is helpful in understanding how various
factors influence a species* survival. The scientists we consulted
emphasized the importance of research for assessing the effectiveness of
recovery actions, not only for determining whether delisting is
appropriate, but also for allocating scarce resources to those actions
with the most positive effects on desert tortoise populations.

Research is underway in several of the recommended areas, including
diseases and how they are transmitted, desert tortoise habitat and health,
nutrition, predation, the effects of climate variability on tortoises, and
survival of juvenile desert tortoises. Scientists from many different
organizations, including the U. S. Geological Survey, the Service, the
National Park Service, military installations, military laboratories,
states, universities, and private consulting groups, perform this
research. According to information compiled by researchers at the Redlands
Institute at the University of Redlands, research presented since 1989 at
the Desert Tortoise Council*s annual symposia* where scientists, land
managers, and others gather to share information on desert tortoise
issues* has covered more than 20 areas, with disease, livestock grazing,
roads, and off- highway vehicle use emerging as the four most commonly
presented topics (see fig. 4). 9

9 Heaton, J. S., A. Martek, R. Inman, and J. Lesch. 2002. Trends in desert
tortoise research: DTC Proceedings 1976- 2001. Proceedings of the 2002
Symposium of the Desert Tortoise Council, Palm Springs, California.
Effectiveness of Recovery

and Mitigation Actions Is Unclear Because Research and Management
Decisions Are Not Integrated

Page 17 GAO- 03- 23 Mojave Desert Tortoise

Figure 4: Percentage of Threat Related Topics Presented at Desert Tortoise
Council Symposia, by Topic, 1989 through 2001

Note: The Other category represents 17 other areas, and includes
construction, toxicants, military activities, fire, mining, ravens/
predation, and drought. Each represents less than 5 percent of the
symposium presentations.

Despite the relatively extensive desert tortoise research efforts, there
is no overall coordination of the research to ensure that questions about
the effectiveness of protective actions are answered. Such a coordinated
program would direct research to address management needs and ensure that
managers are aware of current research as they make decisions. More
importantly, such a program would allow managers to adapt land management
decisions on the basis of science. Unless research is focused on
determining if restrictions and other protective actions are effective,
managers cannot demonstrate a scientific basis for deciding whether
restrictions should remain unchanged, be strengthened, or if other actions
would be more appropriate. For example, since the Bureau of Land
Management eliminated sheep grazing on more than 800,000 acres in
California, neither the Bureau nor the Service has assessed whether this
action has benefited desert tortoises or their habitat. Despite ongoing
research into how livestock grazing affects the soils and plants upon
which desert tortoises depend, few data are available to show the extent
of its impacts and the effectiveness of restrictions in reducing adverse
effects. One scientist discussed recent research that could influence
future priorities for protective actions. Specifically, this research
suggests that tortoise fencing may be more effective along roads with
intermittent traffic than along highways, as the heavier highway traffic
may itself deter

Page 18 GAO- 03- 23 Mojave Desert Tortoise

tortoises from attempting to cross. However, we recognize that in some
cases obtaining definitive data regarding management actions may take many
years for long- lived species like the desert tortoise.

While no overall process exists for integrating research and management
decisions, several efforts are underway to aggregate scientific
information about tortoises and the desert ecosystem and identify
information gaps.

 The Desert Tortoise Management Oversight Group was established in 1988
to coordinate agency planning and management activities affecting the
desert tortoise, and to implement the management actions called for in
BLM's Desert Tortoise Rangewide Plan. The group consists of BLM's
stateoffice directors from Arizona, California, Nevada, and Utah and a
Washington office representative; the four states' fish and game
directors; regional directors of the three Fish and Wildlife Service
offices with desert tortoise management responsibilities; it also includes
representatives of the National Park Service, the U. S. Geological Survey,
and the military installations with desert tortoise habitat. The
Management Oversight Group is intended to provide leadership in
implementation of the recovery plan, consider funding and research
priorities, help ensure data analysis procedures are standardized, and
review plans related to the desert tortoise. In 1990, a Technical Advisory
Committee was formed to provide technical assistance to the group. The
Desert Tortoise Research Project, a group of U. S. Geological Survey
biologists conducting research on the desert tortoise, works with the
Technical Advisory Committee to help establish research priorities.  The
Mojave Desert Ecosystem Program, a cooperative effort among

several agencies that is led by the Department of Defense, has aggregated
large amounts of data on elevation, geology, climate, and vegetation in
the Mojave Desert ecosystem and has made them available as a shared
scientific database through the Internet. This shared database is intended
to allow land managers to make data- driven land management decisions. 
The California Desert Managers Group, comprised of managers from

agencies of the Departments of Defense and Interior and the State of
California, is chartered to develop and integrate the databases and
scientific studies needed for effective resource management and planning
for the California desert. Currently, the group is compiling a list of the
major ongoing scientific activities in the Mojave Desert to identify
significant research gaps, opportunities to collaborate, and opportunities
to solicit support for scientific research needed to fill those gaps. 
The Redlands Institute at the University of Redlands has begun a project,

funded by the Department of Defense, to compile, organize, and store
desert tortoise monitoring information and develop a database of desert

Page 19 GAO- 03- 23 Mojave Desert Tortoise

tortoise- specific research, which the Institute will make available to
land managers.

In addition, during our review, the Service official with lead
responsibility for the desert tortoise program made a proposal to the
Service*s regional office to establish a science office and a permanent
science advisory committee that would work with managers to ensure that
future desert tortoise research is responsive to the managers* needs for
information. The proposed science office would coordinate research and
would work with the Mojave Desert Ecosystem Program, the University of
Redlands, and others to establish and centralize data and procedures. The
proposed science committee, which would be composed of unbiased,
recognized experts in disciplines relevant to tortoise recovery, would
work with the science office and land managers to set priorities for
desert tortoise recovery actions and review agencies* documents for their
scientific soundness. The official anticipates that the proposed committee
would provide a scientific context to support decisions that are, in some
cases, difficult and controversial.

The recovery plan recognizes that few of the data available at the time
the plan was developed were useful for recovery planning; accordingly, it
recommends that the plan be reassessed every 3 to 5 years in light of
newer findings. Service guidance also recommends that recovery plans be
reviewed periodically to determine if updates or revisions are needed.
Recovery team members and the scientists we consulted agreed that the
Service should assess new research and determine if the recovery plan
needs to be revised or updated to accommodate new or different findings.

However, although the plan was issued 8 years ago, the Service has not yet
reassessed it for several reasons. First, because the Service has limited
resources for meeting its continuing obligations to designate critical
habitat and develop recovery plans for other listed species, resources are
not readily available for recovery plan revisions. In addition, some
Service officials believe that new research has not indicated that
significant changes are needed in the tortoise recovery plan. Finally,
some Service officials believe that as new information is developed, it
can be and sometimes is incorporated into ongoing land management
decisions.

Given the controversy surrounding some of the recovery plan*s
recommendations and the resulting management actions, periodic
reassessment of the plan in view of ongoing research could provide
evidence for either retaining or revising the existing recommendations.
For example, according to a recent review of scientific literature on The
Service Has Not

Reassessed the Recovery Plan in Light of Recent Research

Page 20 GAO- 03- 23 Mojave Desert Tortoise

threats to desert tortoise populations, research has shown that heavy,
uncontrolled off- road vehicle use severely damages vegetation that desert
tortoises rely on for food and reduces population densities, a finding
that supports restrictions on such use. 10 In contrast, the effects of
livestock grazing on desert tortoises* effects that the recovery team
identified as a significant threat* are still hotly debated, and research
has not yet established that livestock grazing has caused declines in
desert tortoise populations. In addition, reassessing the plan based on
new research could also indicate whether or not the critical habitat
boundaries* which were based on a draft of the recovery plan* should be
revised. 11

Data on trends in tortoise populations that would indicate whether or not
the species is recovering and can be delisted are not available because
population monitoring efforts have only recently begun and will need to
continue for at least 25 years (one generation of desert tortoises).
Although data on desert tortoise populations have been collected from
study plots in specific areas, these data cannot be extrapolated across
the desert tortoise*s range. Obtaining the necessary trend information has
proved difficult because monitoring is costly and resource intensive, and
continued funding for population monitoring efforts is uncertain.

According to the desert tortoise recovery plan, identifying trends in
desert tortoise populations is the only defensible way to evaluate whether
populations are recovering. Under the plan, before the desert tortoise can
be delisted, tortoise populations must become stable or increase, as shown
by at least 25 years of population monitoring. In order to monitor
population trends, it is necessary to have baseline population data. While
land managers have been concerned about the desert tortoise for over 2
decades, such baseline data are not available rangewide because most
population monitoring has been done in specific areas for other purposes
and cannot be extrapolated to the entire population. For example,
information on the health and status of desert tortoise populations in

10 Boarman, William I., Threats to Desert Tortoise Populations: A Critical
Review of the Literature. U. S. Geological Survey, Western Ecological
Research Center. Aug. 9, 2002. 11 Critical habitat boundaries may be
revised at any time if new information indicates that changes are
warranted. Data Are Insufficient

to Determine the Status of the Desert Tortoise Rangewide, and Continued
Funding for Monitoring Is Uncertain

Data Are Insufficient to Determine the Status of the Desert Tortoise
Rangewide

Page 21 GAO- 03- 23 Mojave Desert Tortoise

certain areas* primarily in California* has been collected from permanent
study plots, some since the 1970s. These study plots were established to
provide data on attributes of tortoise populations and their relationships
to the condition of the habitat and land- use patterns. However, the
locations of these plots were judgmentally selected and are therefore
insufficient to allow scientists to project their status to that of the
entire desert tortoise population.

Development of a baseline population estimate has been delayed in part by
difficulty in determining an acceptable methodology. The recovery plan
recommended a technique for estimating desert tortoise populations, but
that technique was discarded after federal land managers agreed in 1998 to
a different, more suitable population monitoring technique that they
believed would provide more reliable data on the population rangewide.
However, efforts to implement the agreed- upon rangewide monitoring
technique were hampered by a lack of funding and the absence of a
designated coordinator. In 2001, the Fish and Wildlife Service began
coordinating the collection of population data throughout the desert
tortoise*s range using the agreed- upon technique. Establishing a complete
baseline population estimate is expected to take 5 years. Service
officials estimate that after the baseline is established, additional
monitoring will need to occur every 3 to 5 years to determine how
populations are changing over time. According to land managers and
tortoise experts, counting tortoises is difficult because populations are
widespread and spend much of their time underground. In addition, there
are differences in peoples* abilities to locate individual desert
tortoises, especially juveniles, which can be as small as a silver dollar
coin.

A major concern for the tortoise recovery effort is continued funding for
rangewide population monitoring. A Service official estimates that
population monitoring will cost more than $1.5 million each year it is
conducted. The Service depends on agreements with several entities to fund
monitoring. For example, in 2002, funding for monitoring was provided by
the Department of Defense, National Park Service, the Fish and Wildlife
Service, the University of Redlands, Clark County, Nevada, and Washington
County, Utah.

However, the agencies that have provided funding for monitoring in the
past have other priorities and legal mandates to which they must respond;
thus, they cannot guarantee that they will provide funding for the
population sampling from year to year. For example, a Bureau of Land
Management official in California made an informal commitment to provide
$200,000 for monitoring in fiscal year 2002, anticipating that the
Continued Funding for

Population Monitoring Is Uncertain

Page 22 GAO- 03- 23 Mojave Desert Tortoise

Bureau would continue to receive funding for management in the California
Desert as it had in previous years. However, the funding did not
materialize, and the Bureau determined that because of budget constraints
it would be unable to fund the effort. Service staff are frustrated by
this situation, because they cannot know in advance whether the funding
required for sampling will be available, and thus cannot effectively plan
a population monitoring effort that must span at least 25 years.

Since the desert tortoise was first listed in 1980, more than $100 million
has been spent on its conservation and recovery, but the total economic
impact of the recovery effort is unknown. (Throughout this section,
monetary amounts are expressed in constant 2001 dollars.) From fiscal
years 1989 through 1998, agencies reported spending a total of about $92
million on behalf of the desert tortoise, including about $37 million for
land acquisition. Comprehensive expenditure data do not exist for fiscal
years 1980 through 1988, because the reporting requirement had not yet
been enacted, or for 1999 through 2001, because of delays issuing the
report. However, staff time estimates by five key agencies for these
periods account for an additional $10.6 million in expenditures on
tortoiserelated activities. Aside from such expenditures, the overall
economic impact* benefits as well as indirect costs incurred by local
governments, landowners, and developers as a result of restrictions*
associated with the tortoise recovery effort is unknown, although some
limited analyses have been done.

A 1988 amendment to the Endangered Species Act requires that the Service
submit to the Congress an annual report on or before January 15 that
accounts for, on a species- by- species basis, all reasonably identifiable
federal and state expenditures during the preceding fiscal year that were
made primarily for the conservation of threatened and endangered species.
12 These expenditures cover a myriad of activities related to the
conservation and recovery of threatened and endangered species, such as
funding and conducting research, maintaining species* habitats, surveying
species* populations, developing plans, and implementing conservation
measures. Expenditures for land acquisition are also reported, although
they were not reported as a separate category until fiscal year 1993.

12 This annual reporting requirement took effect for expenditures made in
fiscal year 1989; there is no similar reporting requirement for prior
years. Expenditures for

Desert Tortoise Recovery Exceed $100 Million, but the Total Economic
Impact Has Not Been Quantified

Expenditures on the Desert Tortoise Exceed $100 Million

Page 23 GAO- 03- 23 Mojave Desert Tortoise

The purpose of the reporting requirement, according to the Service, was to
obtain information with which to assess claims that a disproportionate
effort was being made to conserve a few, highly visible species at the
expense of numerous, less well- known species. Through discussions with
congressional staff and language contained in the conference report for
the 1988 amendment, the Service determined that it and other federal and
state agencies were expected to cooperate and to make a *good faith
effort* to collect and report expenditure data that are *reasonably
identifiable* to species. The reporting provision, however, was not to
become unduly burdensome. That is, agencies were not expected to undertake
extensive or extraordinary measures, such as creating speciesspecific cost
accounting systems, to develop exceptionally precise data; nor were
agencies expected to pro- rate staff salaries and other normal operational
and maintenance costs not directed toward a particular species. According
to the Service, a significant portion of conservation activities
benefiting threatened and endangered species are not easily identified to
individual species such as law enforcement, consultation, and recovery
coordination, and are, therefore, not included in the annual report.

Based on its understanding of the reporting purpose, the Service issues
guidance to federal and state agencies each year on the types of
expenditures to report, which include research, habitat management,
recovery plan development or implementation, mitigation, status surveys,
and habitat acquisition, as well as the salary costs of employees who work
full- time on a single species or whose time devoted to a particular
species can be readily identified. The guidance states that salary costs
of staff that are not assigned to work on particular species, expenditures
on unlisted species or state- listed species (unless they are also
federally listed), and expenditures on formal consultations dealing with
multiple species should not be reported. The Service also does not include
agencies* unrealized revenues from unsold water, timber, power, or other
resources resulting from actions taken to conserve threatened or
endangered species.

Reported federal and state expenditures on behalf of the desert tortoise
totaled about $92 million, including about $37 million for land
acquisition, from fiscal years 1989 through 1998* the latest year for
which comprehensive data were available. 13 Of all the agencies reporting
desert

13 As of October 1, 2002, the Service had not issued the fiscal year 1998
expenditure report, but had provided us with a complete draft.

Page 24 GAO- 03- 23 Mojave Desert Tortoise

tortoise expenditures, the Bureau of Land Management spent the most by
far* about 5 times more than the Service spent (see table 2). 14

Table 2: Federal and State Agencies* Expenditures on the Desert Tortoise,
Fiscal Years 1989 through 1998

In constant 2001 dollars

Agency Expenditures

Bureau of Land Management $48,598,000 Fish and Wildlife Service 9, 785,000
Air Force 7, 299,000 Federal Highway Administration 6,063,000 Army
4,460,000 U. S. Geological Survey (formerly National Biological Survey) 3,
821,000 Corps of Engineers 3, 655,000 Marine Corps 2, 129,000 States
1,402,000 Wildlife Services (Animal and Plant Health Inspection Service,
USDA) 1, 059,000 National Park Service 988,000 Department of Defense (not
broken out by service) 793,000 Navy 584,000 Bureau of Mines 582,000
Smithsonian Institution 301,000 Bureau of Indian Affairs 221,000 Bureau of
Reclamation 157,000 Environmental Protection Agency 138,000 Forest Service
113,000 Natural Resources Conservation Service 45,000 Federal Energy
Regulatory Commission 8,000 Federal Aviation Administration 6,000

Total $92,000,000

Note: The annual expenditure reports do not summarize information on an
agency- by- agency basis. Accordingly, we obtained and summarized the
expenditures that the individual agencies submitted to the Service.

Source: GAO*s analysis of agency data.

14 In most of the 10 years, 11 to 15 federal agencies reported tortoise
expenditures; state expenditures were reported as one lump sum.

Page 25 GAO- 03- 23 Mojave Desert Tortoise

Over the 10- year fiscal period from 1989 through 1998, federal and state
expenditures on the desert tortoise increased more than 40- fold, from
about $719,000 in fiscal year 1989 to nearly $31.7 million in fiscal year
1998 (see fig. 5).

Figure 5: Reported Expenditures on the Desert Tortoise, Fiscal Years 1989
through 1998 (in constant 2001 dollars)

The sharp increases in tortoise expenditures in fiscal years 1997 and 1998
are associated with significant expenditures for land acquisition. In
fiscal year 1997, nearly $8 million* or 56 percent of the $14 million in
expenditures on the tortoise that year* was for land acquisition.
Similarly, in fiscal year 1998, about $26.5 million* or 84 percent of the
$31.7 million spent on the tortoise* was for land. All of the land
acquisition expenditures for the tortoise in 1998 were made by the Bureau
of Land Management, as was all but about $800,000 of the 1997 land
acquisition expenditures (the Service made the remainder).

Page 26 GAO- 03- 23 Mojave Desert Tortoise

The $92 million that federal and state agencies reported spending on the
desert tortoise accounted for about 2.8 percent of the total $3.3 billion
they reported spending on all threatened and endangered species from
fiscal years 1989 through 1998. 15 During this period, 13 species,
including the desert tortoise, each had total expenditures of more than
$50 million; these species accounted for about 43 percent of total
expenditures during this period (see fig. 6).

Figure 6: Total Expenditures, Including Land Acquisition, for Species with
the Highest Expenditures, Fiscal Years 1989 through 1998 (in constant 2001
dollars)

15 The total $3.3 billion in expenditures reported for the fiscal period
1989 through 1998 does not include about $907 million of expenditures
reported by federal agencies and states. Among the expenditures the
Service excluded from its reports were (1) more than $240 million in
expenditures that, although made to protect listed species, could not be
accounted for on a species- by- species basis; (2) more than $105 million
in expenditures that were for species that were not federally listed (e.
g., state- listed species), species that were not listed until after the
end of the fiscal year during which the expenditures were made, or species
considered in need of protection but not federally listed (e. g.,
sensitive or candidate species); and (3) about $561 million in net power
purchases or power revenues foregone as a result of activities taken to
protect threatened and endangered species.

Page 27 GAO- 03- 23 Mojave Desert Tortoise

Comprehensive data on expenditures on endangered species have not been
available since fiscal year 1998 because the Service has not been issuing
its reports annually, as required. The latest report was published on
August 30, 1999, and was for expenditures in fiscal year 1997. Service
officials also provided us a draft of the report on the fiscal year 1998
expenditures, which we included in our analysis. Also, although
comprehensive expenditure data were not available since fiscal year 1999,
the Service shared with us the data it had received as August 19, 2002. By
that date, all but a few agencies had reported their 1999 expenditures.
Five agencies and the states, however, had not reported their 2000
expenditures, and only two agencies had reported their 2001 expenditures.
For these 3 fiscal years, federal and state agencies had reported a total
of about $12.4 million in additional desert tortoise expenditures. (This
amount is not included in the $92 million in reported tortoise
expenditures.)

The Service official responsible for the report admitted that the agency
has not been complying with the annual reporting requirement for several
reasons. First, the Service has not always been timely in requesting the
needed information from federal and state agencies. Second, several
agencies have not submitted their information on time, and the Service has
chosen to wait to issue the report until all agencies have done so. In
some cases, agencies have been more than a year late in providing
information to the Service. And third, competing priorities within the
Service have delayed the report*s preparation. For example, the staff
responsible for preparing the expenditures report had concurrent
responsibilities such as outreach, interagency coordination, Endangered
Species Act listings, and critical habitat determinations. For future
reports, the Service plans to develop a web- based reporting system and
use an intern to compile the data in order to issue its report more
timely.

Without timely issuance of the annual reports, decision makers and the
public have an incomplete picture of the expenditures made on threatened
and endangered species, both individually and in total. These reports
constitute the only readily available, consolidated source of federal and
state expenditures on a species- by- species basis. Accordingly, they can
serve as a valuable tool* for the Congress, agency officials, and other
interested parties* for assessing trends in spending over time, whether
for all species or for any one species of interest. For example, the
reports allow the Congress to assess whether a few species are receiving a
disproportionate amount of funding at the expense of numerous other
species. Additionally, the reports allow one to discern spending patterns
that could, in turn, indicate regions or ecosystems that may be receiving
more or less attention.

Page 28 GAO- 03- 23 Mojave Desert Tortoise

Because the Service*s annual report does not account for many years during
which tortoise work was being done, we requested staff- time estimates
from five key agencies involved in desert tortoise activities* the Bureau
of Land Management, the Department of Defense, the National Park Service,
the Fish and Wildlife Service, and the U. S. Geological Survey. 16 These
agencies estimated that they spent the equivalent of 471 staff years,
worth about $29.6 million (in 2001 dollars), on tortoise activities from
fiscal years 1980 through 2001. 17 Agencies developed their staff- time
estimates based on staff memory, judgment, and anecdotal evidence,
supplemented by personnel records reviews. These estimates cannot be
combined with the annual expenditures that are reported because some
agencies include staff time in their reports and others do not. We can,
however, add to the reported expenditures the value of the five agencies*
staff- time estimates for the 9- year period for which annual expenditure
data have not been compiled (fiscal years prior to 1989 and after 1998).
The five agencies* total staff- time estimate for these pre- and post-
reporting periods is valued at about $10.6 million (in addition to the $92
million in expenditures reported by federal and state agencies).

Of the five agencies estimating staff time devoted to tortoise- related
activities over the 22- year fiscal period from 1980 through 2001, the
Bureau of Land Management reported the greatest staff- time investment*
about $16.2 million, more than the four other agencies combined. The
Service was a distant second, with a staff- time investment of about $5.5
million* about a third that of the Bureau*s. Overall, the agencies* staff-
time investment steadily increased from 1980 through 1989, and then rose
sharply following the tortoise*s rangewide listing as a threatened species
(see fig. 7).

16 Specifically, we received staff time estimates from these agencies*
offices located in or near the Mojave desert* Arizona, California, Nevada,
and Utah. We did not receive estimates from Nellis Air Force Base, in
Nevada, or the Marine Corps* Chocolate Mountain Aerial Gunnery Range, in
California.

17 To calculate the value of the estimated staff- time investment, we
identified the historical salary level for each employee for each year,
added the value of federal benefits that year, multiplied the result by
the percent of time reported as having been spent on tortoiserelated
activities, and adjusted the value to constant 2001 dollars.

Page 29 GAO- 03- 23 Mojave Desert Tortoise

Figure 7: Trend in Five Agencies* Staff- Time Investment in Tortoise Work,
Fiscal Years 1980 through 2001 (in constant 2001 dollars)

Aside from the reported expenditures and staff- time cost estimates, the
overall economic impact associated with the tortoise recovery effort is
unknown, although some limited analyses have been done. For example, while
it is known that restrictions on residential and commercial development in
tortoise habitat have resulted in foregone opportunities, the extent and
economic value of such lost opportunities has not been quantified. City
and county governments, individual landowners, developers, and
recreationists have incurred costs to comply with the requirements to
protect tortoises, but no consolidated source of information exists to
determine the full extent of such costs, and some are difficult to
quantify. These requirements include training employees to correctly
handle tortoises they encounter, facing project or event delays or
restrictions associated with tortoise conservation, and preparing
mitigation plans.

Although various publications have estimated some costs and discussed
benefits, none provides a comprehensive analysis of the economic impact of
restrictions on land use to protect the desert tortoise. The most
comprehensive analysis we reviewed was prepared by the Service in
conjunction with its 1994 designation of critical habitat for the desert
The Overall Economic

Impact Associated with Tortoise Recovery Is Unknown

Page 30 GAO- 03- 23 Mojave Desert Tortoise

tortoise. This analysis evaluated the impact of potential restrictions on
federal land use in the seven counties that would be affected by the
designation of critical habitat for the tortoise. 18 The analysis
concluded that the restrictions stemming from the designation could
significantly affect small rural communities, but they would have little
effect on the regional or national economy. According to the economic
analysis, the critical habitat designation would primarily affect three
activities: ranching, mineral extraction, and recreation. For example, the
analysis estimated a loss of no more than 425 jobs in the seven affected
counties, with 340 of those in the ranching industry. Ranching profits
were expected to be the hardest hit, with a reduction of about $4.5
million. About 51 permits* covering about 1.7 percent of all grazing units
allowed on federal land in Arizona, California, Nevada, and Utah* would be
affected.

It is important to note that the Service*s analysis considered only the
effects of restrictions on federal land. The analysis recognized that many
restrictions had already been put in place on federal and nonfederal land
as a result of the tortoise*s listing. For example, it cited restrictions
on grazing and off- road vehicle use in California and Nevada and
indicated that the critical habitat designation could result in additional
restrictions in those areas. For Utah, however, the report stated that
little or no additional restrictions would likely be associated with the
designation, as critical habitat had previously been designated for the
small portion of the population of the tortoise in the state.

An analysis conducted by the Department of Agriculture*s Economic Research
Service substantiated some of the results of the Service*s economic
analysis for the critical habitat designation. This analysis estimated the
direct and total economic effects of different levels of reductions in
grazing rights in counties with known populations of desert tortoises and
in counties with designated habitat areas. The estimated effects of
grazing restrictions on federal land ranged from $3 million to $9 million.
19 This analysis also concluded that grazing restrictions may have a
significant impact on individual ranchers, but their impact on regional
economies was not as significant. Under every scenario, the relative cost
of total impacts from restrictions was less than 0.08 percent of the gross
domestic product of the economic region. Lost livestock sales

18 These seven counties are: Mohave County, Arizona; Imperial, Riverside,
and San Bernardino Counties, California; Clark and Lincoln Counties,
Nevada; and Washington County, Utah.

19 Monetary values in this analysis were expressed in constant 1993
dollars.

Page 31 GAO- 03- 23 Mojave Desert Tortoise

were the single largest cost associated with grazing restrictions;
however, grazing restrictions were not likely to affect national livestock
production or prices. Other kinds of restrictions can similarly have an
economic cost. For example, restrictions on development, mining, and off-
road vehicle use can result in foregone revenue and recreation
opportunities. Such costs, however, have not been quantified.

An analysis prepared by Washington County, Utah, in 1995 examined the
costs and benefits associated with protective actions for the desert
tortoise. Specifically, the county analyzed the costs and benefits of
obtaining a permit from the Service that would allow the county to approve
development projects in desert tortoise habitat. Under this permit, the
county would establish a 61,000- acre reserve for desert tortoises to
mitigate potential harm to tortoises from the projects. The analysis
concluded that the benefits of establishing the reserve would be more than
the benefits associated with having individual developers obtain permits
and carry out their own mitigation actions. Property tax revenue were
estimated at about $48 million more with the county obtaining the permit
because if individual developers had to obtain their own permits, they
would not likely develop as much land. 20 Creating the reserve was
expected to have little effect on mining and no effect on farmland. The
analysis did not quantify the reserve*s economic impact on livestock
grazing, although it noted that the county would extend purchase offers to
holders of grazing permits on reserve land. Finally, the analysis
concluded that the reserve would result in many benefits. These benefits
include the aesthetic value of the open space within the reserve, the
increased value of private property adjacent to the reserve (and the
associated increase in property taxes), and annual expenditures of about
$17.5 million a year by local and regional visitors to the reserve and its
associated education center.

Clark County, Nevada, also analyzed, in 2000, costs and benefits for a
permit that would allow development similar to that in Washington County.
However, Clark County*s permit addresses potential impacts to 79 species
including the desert tortoise, and the economic impact associated with the
tortoise cannot be identified separately. In addition to the county*s
analysis, agencies that manage land in Clark County have prepared their
own economic analyses, as part of environmental impact statements for
their individual management plans. For example, BLM identified negative
fiscal impacts from restrictions on cattle grazing in

20 Monetary values in this analysis were expressed in constant 1996
dollars.

Page 32 GAO- 03- 23 Mojave Desert Tortoise

desert tortoise habitats in Clark County. As a result, the county has
obtained grazing and water rights from willing sellers rather than
restricting grazing outright. In contrast, the Forest Service found
positive socioeconomic impacts from tortoise protections included in its
management plan for the Spring Mountains National Recreation Area. 21
These positive impacts were associated with increased recreation that
could provide business opportunities for the surrounding communities.

As the Washington County and Spring Mountains analyses indicate, tortoise
recovery efforts can lead to measurable economic benefits. Other economic
benefits clearly derive from efforts to protect the desert tortoise, but
generally have not been estimated. These benefits are intangible and
include such things as aesthetic values associated with protected areas,
the knowledge that the tortoise continues to exist and may be available
for future generations, and the corollary benefits that other species
enjoy as a result of protections extended to the tortoise. Also, according
to agency officials, the tortoise recovery effort has resulted in improved
communication and coordination among federal, state, and local government
officials, as well as private groups such as environmental advocates and
off- highway vehicle clubs. Agency officials believe that education and
communication efforts ultimately achieve greater protections for not only
the tortoise but for the desert ecosystem as a whole.

Many scientists consider the desert tortoise to be an indicator of the
health of the desert ecosystem, and to date, over $100 million has been
spent on efforts to protect and recover the species. Despite the
significant expenditures made and actions taken to conserve the tortoise,
land managers and the Service lack critical management tools and measures
needed to assess the status of the species and to determine the
effectiveness of protections and restrictions that have been taken.
Specifically, the lack of a strategy for integrating research with
management decisions prevents the Service and land managers from ensuring
that research is conducted to evaluate the effectiveness of protective
actions taken and to identify additional actions that could assist in the
recovery effort. While several efforts are underway to consolidate
scientific information about the tortoise and its habitat, and a recent
proposal has been made for integrating science with management, it is
unclear how and to what extent these efforts will be used to direct

21 The Forest Service found these positive socioeconomic impacts in a 1996
environmental impact statement. Conclusions

Page 33 GAO- 03- 23 Mojave Desert Tortoise

research and management actions, and the efforts may be duplicative if not
properly coordinated. In addition, the original recovery plan for the
tortoise has not been reviewed to determine whether recommended actions
are still valid or whether recent scientific information would suggest
more effective recovery actions. Such a review is important given the
continued uncertainties surrounding some of the plan's original
recommendations. Also, a lack of funding assurances may hamper efforts to
collect rangewide population monitoring information needed to assess the
current status of the desert tortoise and to track the future growth or
decline in the species. Finally, late and incomplete expenditure reporting
precludes the Congress and the public from knowing the type and extent of
expenditures involved in the desert tortoise recovery effort. Unless these
shortcomings are addressed, questions will persist about whether the
current protection and recovery efforts and actions are working and are
necessary, and even whether the species continues to be threatened with
extinction.

To ensure that the most effective steps are taken to protect the tortoise,
we recommend that the Secretary of the Interior direct the Director of the
Fish and Wildlife Service to take the following steps:

 Develop and implement a coordinated research strategy that would link
land management decisions with research results. To develop such a
strategy, the Director should evaluate current efforts to consolidate
scientific information and existing proposals for integrating scientific
information into land management decisions.  Periodically reassess the
desert tortoise recovery plan to determine

whether scientific information developed since its publication could alter
implementation actions or allay some of the uncertainties about its
recommendations.  To ensure that needed long- term monitoring of the
desert tortoise is

sustained, we recommend that the Secretary of the Interior work with the
Secretary of Defense and other agencies and organizations involved in
tortoise recovery, to identify and assess options for securing continued
funding for rangewide population monitoring, such as developing
memorandums of understanding between organizations.  To provide for more
timely reporting of expenditures for endangered

species, we recommend that the Secretary of the Interior direct the
Director of the Fish and Wildlife Service to issue the annual expenditure
reports as required by the law, and to advise the Congress if reports are
incomplete because not all agencies have provided the information
requested. Recommendations for

Executive Action

Page 34 GAO- 03- 23 Mojave Desert Tortoise

We provided copies of our draft report to the Departments of the Interior
and Defense. The Department of the Interior concurred with our findings
and recommendations. The department also provided technical clarifications
from the Fish and Wildlife Service, Bureau of Land Management, National
Park Service, and U. S. Geological Survey, which we incorporated as
appropriate. The Fish and Wildlife Service also provided details on
actions planned or underway to implement our recommendations. The
Department of the Interior's comment letter is in appendix III. The
Department of Defense provided oral comments consisting of technical
clarifications, which we also incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 10 days from
the report date. At that time, we will send copies of this report to the
Secretary of the Interior, the Secretary of Defense, and other interested
parties. We also will make copies available to others upon request. In
addition, the report will be available at no charge on the GAO Web site at
http:// www. gao. gov. If you or your staffs have any questions, please
call me at (202) 512- 3841. Key contributors to this report are listed in
appendix V.

Barry T. Hill Director, Natural Resources

and Environment Agency Comments

and Our Evaluation

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 35 GAO- 03- 23 Mojave Desert Tortoise

Federal agencies and others have taken a variety of actions to benefit
desert tortoises, reflecting recommendations in the recovery plan or
efforts to minimize the effects of potentially harmful activities. These
actions include acquiring habitat, restricting certain uses, promoting
education programs about the species, and funding or conducting research
on such topics as the causes of disease in tortoises, their nutritional
needs, and the effects of human activities on tortoises. The Management
Oversight Group*s Technical Advisory Committee surveyed agencies about the
actions they have taken to date; what follows is a list of some of the
actions reported in that survey and to us during our review.

 In June 2002, the Bureau of Land Management (BLM) acquired 240 acres of
private property in Arizona, along with an associated 34,722- acre
livestock grazing allotment. While grazing has not been permanently
eliminated from this allotment, there is no current livestock use. About
10 percent of the allotment lies within a desert wildlife management area.
 BLM has closed some existing roads and posted these as closed, signed

others, and has built some tortoise fencing.  Competitive events are
banned in areas of critical environmental concern.  BLM amended the
existing land use plan in 1997 chiefly to implement the

Desert Tortoise Recovery Plan. Following the amendment of the land use
plan, the BLM issued approximately 18 grazing decisions to modify
livestock grazing seasons in order to protect the desert tortoise.  In
2002, BLM removed 61 burros from desert tortoise habitat and plans to

remove 10 more in 2003.  Establishment of new roads is tightly
restricted. No off- road vehicle use is

allowed, and law enforcement staffing has been increased to enforce the
restrictions.  BLM has funded tortoise- monitoring studies for several
years, typically by

contracting through Arizona*s Game and Fish Department. In addition, a
study plot was established in 1980 to research the effects of excluding
cattle grazing. Other studies have been conducted over the years, and the
U. S. Geological Survey continues to study such issues as fire and its
relationship to invasive plants. Appendix I: Actions on Behalf of the
Mojave

Desert Tortoise Bureau of Land Management

Arizona

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 36 GAO- 03- 23 Mojave Desert Tortoise

 All routes are closed in the Desert Tortoise Natural Area, except to
owners of private land within the area*s boundary.  Almost 200 closed
routes throughout several management areas have been

rehabilitated.  Competitive vehicle events in tortoise habitat are
allowed only within

existing off- highway vehicle open (play) areas or on specifically
identified courses.  In 1991, sheep grazing was removed from more than
800,000 acres of

desert tortoise critical habitat in California, pursuant to a jeopardy
biological opinion from the Service. All or portions of several
cattlegrazing allotments totaling almost 350,000 acres have been
restricted or eliminated. Temporary restrictions are in place until
bioregional plans are completed; specifically, sheep allotments covering
more than 135,000 acres in non- critical habitat cannot be grazed and
cattle- grazing is not authorized on all or part of allotments covering
almost 250,000 acres, and is seasonally restricted in portions of 11
allotments covering almost 500,000 acres.  From 1981 through 2002, more
than 7, 600 burros were removed from

several areas, some of which were within desert tortoise habitat.  Since
the mid- 1990s, BLM has cleaned up several illegal dumps within

desert tortoise management areas, and community dumps are being closed in
favor of regional landfills.  An 18- mile fence was constructed along one
boundary of a management

area to restrict vehicle access from private lands into tortoise critical
habitat.  BLM*s information and visitor centers provide information on
tortoise

conservation.  Since 1989, between 55 and 60 ravens have been removed,
most from a

proposed desert wildlife management area, as part of a pilot raven control
program.  In 2001, all BLM lands in selected critical habitat units were
closed, on an

interim basis, to all shooting except hunting and paper- target practice.
 In 1998, the Las Vegas Field Office*s Resource Management Plan

established four Areas of Critical Environmental Concern to protect
critical desert tortoise habitat encompassing a total of 743,209 acres. 
Approximately 54 miles of road have been restored  All competitive events
involving mechanized and motorized vehicles are

limited to designated roads and trails within areas of critical
environmental concern.  Rights- of- way and utility corridors are
restricted, and new landfills are

prohibited.  Two dump sites were cleaned up in one area of critical
environmental

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

Nevada

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 37 GAO- 03- 23 Mojave Desert Tortoise

gravel community pit sales, BLM has provided $12,000 and 40 peoplehours to
clean up another large dump site.  BLM, in cooperation with Clark County,
has developed a brochure

depicting the locations of approved routes of travel and provides
information on use restrictions.  BLM has issued a number of trespass
violations and required

reimbursement for damaged vegetation for off road activities. Money
collected from these violations is used toward restoring these areas. 
Several areas have been restored: 8 trespass sites, 117 road sites,

15 gravel/ corral sites, and 4 dumpsites.  Through off- site mitigation
fees collected from sand and gravel community

pit sales, BLM has provided more than $1 million in funding for
nutritional research on desert tortoises since 1995.

 BLM has acquired almost 6,600 acres within the Red Cliffs Reserve.  BLM
has rehabilitated approximately 3.5 miles of closed road and has

closed more than 25 trails and many other roads to non- motorized
travelers.  Red Cliffs Reserve is closed to fuel wood and mineral
material sale and

withdrawn from mineral entry; BLM prohibits surface disturbance during oil
and gas exploration and limits access for rights- of- way. Compensation is
required where permanent loss of desert tortoise habitat has occurred.
Vegetation may not be harvested in the Reserve except by permit for
scientific purposes.  The BLM retired grazing on 30,725 acres of land
within the Red Cliffs

Reserve that had previously been under grazing permits.  One illegal dump
was cleaned up with 28 tons of material removed.  Uncontrolled dogs are
prohibited in the Reserve.  Approximately 10 acres of disturbed habitat
in the Reserve have been

reseeded or rehabilitated.  BLM offers public lectures and brochures
about the Red Cliffs Reserve and

management of desert tortoises in Washington County. Utah

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 38 GAO- 03- 23 Mojave Desert Tortoise

 *Tortoise breaks* in curbs allow passage of desert tortoises and other
wildlife from one side of the road to another. These are also used in
parking lots to keep tortoises from being trapped.  More than 400 miles
of jeep trails, historic roads, and recent roads are

closed. Portions have been rehabilitated and re- vegetated.  A Navy
overflight exercise route that passed through portions of the park

was rerouted because it was thought to potentially harass or affect the
natural behavior of the desert tortoise and other sensitive species.  The
park is working to prevent a proposed landfill from being placed

outside the park near one of its densest desert tortoise populations. 
Livestock use limited to horses and mules and is restricted to designated

equestrian trails and corridors.  The park has cleaned up 23 dumpsites,
removing a total of 547,704 pounds

of garbage.  Tortoises removed from the park are given to the tortoise
rescue center or

tortoise adoption agency where they receive a physical inspection and U.
S. Fish and Wildlife Service permit tags. Tortoises showing symptoms of
upper respiratory tract disease are given to a researcher for a health
inspection.  Temporary tortoise fencing has been installed at
construction staging

areas for ongoing road construction project. Areas with high tortoise
densities are fenced off and monitored by park biologists on- site during
construction.  Approximately 45 acres of disturbance associated with
federal highway

construction has been rehabilitated.  Open mine shafts have been fenced
and plugged to prevent tortoises from

falling in.  The park has developed educational kits and a curriculum
unit for schools.

Park biological technicians train volunteers, construction workers, and
park staff about desert tortoises.  The Park has established five study
plots; each is visited at least 10 times

per season. More than 400 tortoises have been marked and their age, sex,
weight, and location have been recorded. Desert tortoise sightings
reported by park staff and visitors are collected through wildlife
observation cards; the information is analyzed, recorded, and incorporated
into a database.  Research has been initiated on raven populations and
upper respiratory

tract disease. Ravens are monitored and nests are removed in areas where
they have been seen predating on tortoises. National Park Service

Joshua Tree National Park

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 39 GAO- 03- 23 Mojave Desert Tortoise

 Mojave National Preserve actively manages all preserve lands (1.6
million acres) for desert tortoises. Approximately 772,000 acres are
federally designated critical habitat for desert tortoise.  Nearly
100,000 acres* most of which is desert tortoise critical habitat- have
been acquired within the preserve from private owners or from the

state of California since 1994.  Permits for more than 768,000 acres once
designated for grazing have been

retired. Permits for approximately 311,000 additional acres are pending
retirement. Once that retirement is complete, grazing* and more than 4,000
cows* will have been removed from about 564,000 acres of desert tortoise
critical habitat.  More than 3,000 burros have been non- lethally removed
since 1997.  The preserve has posted signs and information kiosks to
increase

awareness of travelers of potential tortoise and other wildlife
encounters.  Vehicles are permitted only on existing roads, and in
camping and parking

areas. No off road driving is allowed anywhere in the preserve. 
Competitive motorized events are prohibited. Other organized events may

be allowed on existing roads, outside of the desert tortoise active
periods, with appropriate restrictions.  No existing or new landfills are
allowed anywhere in the preserve, which

is also closing and cleaning up old, informal trash dumps. Approximately
50 acres of illegal dumps have been cleaned up in the preserve.  Any
surface disturbance on preserve lands must be balanced with

appropriate restoration or acquisition of replacement lands for
mitigation.  Permits for vegetation harvest are authorized only for
scientific collection;

the National Park Service requires special stipulations to ensure desert
tortoises are protected.  To prevent the spread of disease from captive
tortoises, the preserve

prohibits the reintroduction of tortoises.  Interpretive staff have
developed school programs and created a poster

and a brochure about the desert tortoise and responsible recreational
behavior in tortoise habitat. The staff has placed warning stickers in
preserve vehicles reminding drivers to check under their cars before
driving.  In 2001, population density monitoring began in the preserve. 
The preserve manages trash and litter to avoid subsidizing ravens.
Ravenproof trash containers are being installed throughout the preserve.

 Cattle grazing has been removed from desert tortoise habitat in Lake
Mead National Recreation Area.  Hard- rock mining in 30,000 acres of
desert tortoise habitat is prohibited at

Lake Mead National Recreation Area.  Lake Mead National Recreation Area
requires that vehicles stay on

designated roads. Mojave National Preserve

Lake Mead National Recreation Area

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 40 GAO- 03- 23 Mojave Desert Tortoise

 Lake Mead National Recreation area decided to abandon a proposal to
build a boat launch and marina because it would have required a road
through desert tortoise habitat.

 Fort Irwin has piloted a *head start* program to attempt to conduct
research on the biology of neonate desert tortoises. Under this program,
females are removed from the wild and lay their eggs in captivity, where
the eggs can be protected. In the future, the young could potentially be
moved into areas where tortoise numbers have been severely decreased or
where they have been extirpated, if considered appropriate.  Fort Irwin
has installed 7.5 miles of tortoise fencing.  Fort Irwin has funded the
population- monitoring program in two proposed

desert wildlife management areas since 2000. The National Training Center
has funded many research programs of behavior, disease and other topics on
the desert tortoise.  Fort Irwin has predator control programs, which
include removing and

excluding ravens, controlling coyotes, and educating the public to limit
or eliminate food and water sources for predators

 The Marine Corps supports an environmental education program; more than
50,000 Marines and family members are given an environmental briefing
annually.  The Marine Corps provides a portion of the funding required
for

population monitoring efforts.  Since the early 1980s, the Marine Corps
has conducted or cooperated with

numerous desert tortoise studies and research projects. Research projects
were recently completed in juvenile survivorship and tortoise ecology, and
recently initiated projects include tortoise health assessments and
population monitoring.  Marine Corps* Natural Resources staff work
closely with the installation*s

law enforcement to control free- roaming dogs.  The Marine Corps surveyed
23 areas, comprising 935 square miles, to

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

Defense Army National Training Center at Fort Irwin

Marine Corps Air Ground Combat Center at Twent yni ne Pal ms

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 41 GAO- 03- 23 Mojave Desert Tortoise

 Edwards closed 42 pitfalls (prospect pits, mine shafts, wells, and
irrigation pipes) in critical habitat that were potentially hazardous to
tortoises.  Edwards prohibits competitive and organized events in
critical habitat.  Edwards educates personnel on the deposition of
captive and displaced

tortoises. A desert tortoise adoption program has been in place since
1994; it was established to prevent captive desert tortoises from being
returned to the wild, prevent wild tortoises from being taken, and provide
a means of tracking captive tortoises.  Edwards built 22.7 miles of
tortoise fencing in critical habitat to keep

tortoises from entering hazardous areas (precision bombing targets) and
from crossing well- traveled paved roads, and installed 48 miles of
fourstrand barbed- wire fence in critical habitat.  Edwards revegetated
155.2 acres in critical habitat.  Edwards presents an environmental
education program on Mojave Desert

ecosystem to local schools on base and in surrounding towns and during
public events  Edwards funds or conducts population monitoring in
critical habitat and

other areas on base. Other research includes vegetation and habitat
studies, evaluation of species diversity over time, analysis of soil and
vegetation samples for presence of toxic metals, and adaptive management
under the base*s resource management plan.

 The Department of Fish and Game (DFG) has acquired and manages more than
12,000 acres.  DFG reviews proposed actions on public lands and makes

recommendations to BLM; it also reviews and makes recommendations on
Integrated Natural Resource Management Plans for military bases.  DFG
prohibits and issues citations to people for collecting tortoises from

the wild.  DFG has fenced some lands to keep vehicles out. Though DFG has
not

installed fencing along roads, it has been a requirement for many
projects. Because of large numbers of tortoises on a particular road,
along with increased traffic associated with a solar energy plant, fencing
was required and was installed by the Desert Tortoise Preserve Committee;
a culvert will also be placed under the road.  DFG provides funding for
signs, brochures, and kiosk information.  DFG provides funding for
monitoring of long- term study plots. It is cohosting a workshop on
diseases to consolidate known information, foster

discussion between experts, and solicit management recommendations. 
California*s Department of Transportation has purchased 618 acres from

San Bernardino County and will transfer them to DFG to mitigate the
effects of a highway expansion on desert tortoises; it also installed
about 6.5 miles of permanent tortoise fence on I- 15. Edwards Air Force
Base

State of California

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 42 GAO- 03- 23 Mojave Desert Tortoise

 The Department of Game and Fish prohibits the release of wildlife,
including desert tortoises, without a special permit.  The department
monitors tortoises on several study plots (largely funded

by BLM) since 1996; it partially funded population monitoring in one area
in 2001 and 2002.  The department conducts or funds research on tortoises
in the Sonoran

Desert (in such areas as life history and disease), which may provide
comparative insight for Mojave Desert tortoise recovery efforts.

 The county*s habitat conservation plan designated the 62,000- acre (100
square- mile) Red Cliffs Desert Reserve.  The county is working with BLM
and the state of Utah to acquire privately

owned properties located within the boundaries of the reserve; BLM and the
state have acquired through purchase and exchange more than 7,700 acres of
privately owned land within the reserve since 1996.  Of the estimated 40
dirt roads in the Reserve, 5 remain open for public

travel. Service roads are gated and locked. As resources allow, closed
roads are being rehabilitated. The county has reseeded an estimated 5
acres of old roads within the reserve.  The county compensated willing
sellers for loss of grazing within the

reserve, for a total of 1,517 animal unit months at a cost of $113,775. 1
 The county worked with St. George City, Utah, and BLM to clean up the

old city dump, which was located within high- density tortoise habitat in
the reserve. At least 30 illegal dumpsites have been cleaned up by the
county with the help of volunteer groups.  Wild, displaced desert
tortoises that test negative for upper respiratory

disease are moved, or translocated, to a designated area of the reserve. 
The county has installed or funded the installation of 40 miles of
tortoise

fencing. The reserve boundary is being fenced incrementally as development
occurs nearby.  The county has posted boundary signs to inform people
when they are

entering the reserve and advise of vehicle, pet, and target shooting
restrictions.  The county has funded 5 years* population monitoring
(conducted by the

Utah Division of Wildlife Resources) at $115,000 per year.  The county
controls ravens that are identified as threats to tortoises, and

maintains a database of known raptor and raven nest sites, which enables
monitoring of predation on hatchling tortoises.

1 An animal unit month is defined as the amount of forage needed to
sustain one cow, one horse, or five sheep for 1 month. State of Arizona

Washington County, Utah

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 43 GAO- 03- 23 Mojave Desert Tortoise

 Under its multiple- species habitat conservation plan, through the
Nature Conservancy, the county has purchased grazing preferences from
ranchers (on a willing- seller basis) on more than 1,000,000 acres of
public land and eliminated grazing on those lands.  The county has fenced
almost 130 miles of highway, at a cost of about

$580, 000, to keep desert tortoises from being run over.  The county
funds research in such areas as desert tortoise nutrition and

population monitoring, predation by ravens, translocation.  The habitat
conservation plan funds two BLM law enforcement rangers,

one National Park Service ranger, and one Nevada Division of Wildlife
ranger.  Clark County provides funding for the operation and management
of the

Clark County Desert Tortoise Conservation Center.  The habitat
conservation plan provides funding for a desert tortoise pickup service. 
The county educates the public about tortoises; for example, it has hosted

contests in which school children estimate when a desert tortoise named
Mojave Max will first exit his burrow. This event has resulted in
thousands of students* researching Mojave Desert temperatures and desert
tortoise habits.  The county funds radio and newspaper announcements
targeted to desert

users, reminding them to drive on roads, shoot responsibly, and deposit
garbage only at garbage dumps in order to keep raven populations down.

 In 1995, the committee acquired 1,360 acres of private property, which
was the base property for a grazing allotment; since 1994, it has acquired
more than 175 acres within the Desert Tortoise Natural Area and has
acquired or is in the process of acquiring more than 1,200 acres to buffer
the natural area and other critical habitat. It generally sells or donates
land it acquires to BLM or the State of California.  The committee has
rehabilitated 2 miles of road and removed

approximately 3 tons of trash from a grazing allotment to date.  A
naturalist is staffed at the Desert Tortoise Natural Area every spring;
the

naturalist provides interpretive and educational services to visitors,
routinely intercepts releases of tortoises and other turtles, and provides
contact information for safe deposition/ placement of captive tortoises. A
resident host/ interpreter at a grazing allotment educates visitors to
reduce release or take of tortoises  Dogs are prohibited inside the
Desert Tortoise Natural Area; the naturalist

monitors compliance during the peak visitation period.  The committee
installed 8 miles of tortoise fencing and commissioned the

design and installation of a tortoise culvert along a busy road. Clark
County, Nevada

Desert Tortoise Preserve Committee

Appendix I: Actions on Behalf of the Mojave Desert Tortoise

Page 44 GAO- 03- 23 Mojave Desert Tortoise

 The committee has restored habitat at the site of an old toilet block at
the Desert Tortoise Natural Area; work is ongoing to camouflage impacts of
illegal off- road vehicle activity along entrance route into the area. 
The committee hosts twice- yearly work parties to replace

lost/ stolen/ vandalized signs and fences at the area.  The committee
installed multimedia interactive kiosk at the California

Welcome Center in Barstow, California, to provide desert environmental
education to the general public.  The committee is evaluating the
protective effects of fencing.

Appendix II: Objectives, Scope, and Methodology

Page 45 GAO- 03- 23 Mojave Desert Tortoise

This report examines (1) the scientific basis for the 1990 listing,
critical habitat designation, and recovery plan recommendations for the
desert tortoise; (2) the effectiveness of actions taken by federal
agencies and others to conserve desert tortoises; (3) what is known about
trends in tortoise populations; and (4) costs and benefits associated with
tortoise recovery actions since 1980, when one population of the tortoise
was listed, to the extent that data were available.

To evaluate the scientific basis for the listing decision, critical
habitat designation, and recovery plan (known collectively as *key
decisions*), we contracted with the National Academy of Sciences to
identify and assist in the selection of scientists to provide technical
assistance. The persons we selected have recognized expertise in the areas
of conservation biology, herpetology, desert ecosystems, and federal land
management policy, and collectively represent a range of perspectives and
views on the conservation of threatened and endangered species. The
selection involved a two- step process. First, the academy identified, and
provided to GAO, an extensive candidate pool of individuals for possible
participation. We selected a smaller pool of scientists from which the
final selections were made, based on the scientists* availability to
participate. The academy*s staff administered a questionnaire to identify
potential conflicts of interest; no disqualifying conflicts of interest
were identified. The scientists participating in the discussion were:

Dr. Roy C. Averill- Murray Amphibians and Reptiles Program Manager Nongame
Branch, Arizona Game and Fish Department Phoenix, Arizona

Dr. Perry R. Hagenstein Institute for Forest Analysis, Planning, and
Policy Wayland, Massachusetts

Dr. Jay D. Johnson University Animal Hospital Tempe, Arizona

Dr. James A. MacMahon Professor of Biology Utah State University Logan,
Utah Appendix II: Objectives, Scope, and

Methodology

Appendix II: Objectives, Scope, and Methodology

Page 46 GAO- 03- 23 Mojave Desert Tortoise

Dr. Dennis D. Murphy Research Professor, Department of Biology University
of Nevada Reno, Nevada

Dr. Patrick Y. O*Brien Senior Research Scientist Chevron Texaco Energy
Research and Technology Company Richmond, California

Dr. Frederic H. Wagner Professor of Wildlife and Fisheries Utah State
University Logan, Utah

GAO provided the scientists with the listing decision, the critical
habitat designation, the recovery plan, and key supporting documents. GAO
also provided access to other materials referenced in the key decision
documents. In a 2- day, facilitated discussion, the scientists provided
their views on five questions:

 Overall, do the listing decision and critical habitat designation seem
reasonable, given the scientific studies and other information that were
considered? Where do you agree and what concerns, if any, do you have? 
Do the recommended numbers, sizes, and configurations of recovery areas

and desert wildlife management areas seem reasonable? What are the
strengths and weaknesses of the population viability analysis?  Do the
recovery plan*s recommendations about activities that should be

prohibited within protected areas (e. g., grazing, mining, off- road
vehicle use) and mitigative actions that should be taken (e. g., fencing
or installing culverts underneath heavily traveled roads) seem supported
by the scientific studies? Where do you agree and what concerns, if any,
do you have?  To what extent do the decision documents acknowledge

and accommodate uncertainties in the scientific studies? Do the
accommodations seem reasonable?  Do any of the issues addressed in the
recovery plan need to be reassessed

from time to time? If so, describe. How often do you think such issues
should be reassessed, and under what conditions?

To further our understanding of the process used to develop listing
decisions, critical habitat designations, and recovery plan
recommendations for the desert tortoise, we interviewed officials and
collected pertinent documentation from numerous federal agencies,

Appendix II: Objectives, Scope, and Methodology

Page 47 GAO- 03- 23 Mojave Desert Tortoise

including the U. S. Fish and Wildlife Service, the U. S. Geological
Survey, the Bureau of Land Management, the National Park Service, and
military installations of the Department of Defense; state and local
governments in California, Nevada, and Utah; nongovernmental
organizations, such as the Desert Tortoise Preserve Committee, the High
Desert Multiple Use Coalition, and the QuadState Coalition; academic
scientists; and six of the eight members of the desert tortoise recovery
team.

To assess the effectiveness of actions taken by federal agencies and
others to conserve the desert tortoise and to assess what is known about
trends in tortoise populations, we collected relevant land use planning
documents, habitat conservation plans, and other official documents,
published and unpublished scientific studies, desert tortoise population
monitoring reports, survey data collected and compiled by the Management
Oversight Groups* Technical Advisory Committee regarding recovery actions,
and other reports. We interviewed officials from federal and state
agencies and other organizations involved with the tortoise, and conducted
several site visits to observe tortoise habitat and implementation of
conservation actions. Specifically, we made site visits to the Desert
Tortoise Conservation Center in Las Vegas, Nevada; the Desert Tortoise
Natural Area in California; Joshua Tree National Park; the Marine Corps
Air Ground Combat Center at Twentynine Palms, California; the Army*s
National Training Center at Fort Irwin, California; and the Red Cliffs
Reserve in Washington County, Utah. We also attended the annual symposium
of the Desert Tortoise Council in Palm Springs, California, which featured
presentations on actions taken to conserve the desert tortoise and results
of tortoise recovery efforts and research projects.

To identify costs and benefits associated with desert tortoise recovery
actions since the tortoise was first listed in 1980, we examined the
annual expenditure reports the Service is required to submit to the
Congress; these reports compile and summarize federal and state agencies*
annual expenditures on threatened and endangered species, by species. The
reports contain expenditure data for land acquisition and for general
activities (e. g., conducting research, monitoring species* populations,
developing and implementing recovery plans, and constructing fences). The
reporting requirement began for expenditures made in fiscal year 1989, and
the last report the Service submitted to the Congress was for expenditures
made in fiscal year 1997. We obtained all nine of these reports, as well
as the draft report for fiscal year 1998 and the more recent expenditure
data (for fiscal years 1999 through 2001) that the Service had compiled as
of August 19, 2002, but had not published.

Appendix II: Objectives, Scope, and Methodology

Page 48 GAO- 03- 23 Mojave Desert Tortoise

Although the Service summarizes and reports data on a species- by- species
basis, it does not summarize and report data on an agency- by- agency
basis. Rather, the Service reports, in addition to its own expenditures,
one lump sum for expenditures by other federal agencies. Accordingly, we
reviewed and analyzed the agencies* individual expenditure reports, which
are reproduced in an appendix in each report. We were thus able to compare
and report information, year by year and in total, on individual agencies*
expenditures on the tortoise and on other species. 1 We excluded from the
agencies* data those expenditures that clearly did not meet the intent of
the report, such as expenditures that could not be broken out by species,
expenditures made on behalf of sensitive or candidate species (species in
need of protection but not listed as threatened or endangered), and power
purchases and revenue foregone as a result of actions taken to protect
listed species. Nevertheless, our sums did not always match those in the
reports because the Service also excluded from its sums expenditures made
on certain species, including species that were state listed but not
federally listed, species that were listed after the fiscal year for which
the expenditures were reported, and species that were in need of
protection but were not listed. Although a few of the reports showed which
expenditures the Service had excluded from its sums, most did not. In such
cases, the total expenditures shown in the report for *other federal
agencies* were less than the totals we calculated. Further, because the
Service sometimes included land acquisition expenditures in its reported
totals and sometimes excluded them, we recalculated the totals to
consistently include land acquisition expenditures. We were thus able to
consistently depict trends in total expenditures, whether by species, by
agency, or by year.

We did not verify the accuracy of the expenditures reported by the
individual agencies or by the Service, but we checked the consistency of
the information we were given, to the extent possible. We reviewed the
guidance the Service provides to agencies on the types of expenditure data
to submit, and we discussed with Service officials the criteria and
methods by which the expenditure data are reviewed and edited.
Additionally, we discussed with several agency officials the type of
expenditure data they submit and the methods by which they estimate their
expenditures. We adjusted all the expenditures to constant 2001 dollars.

Because tortoise- related expenditures were not collected prior to the
1989 annual report, and because comprehensive and current expenditure

1 We could not similarly analyze individual states* expenditures, because
such information was neither included in the reports nor sought by the
Service.

Appendix II: Objectives, Scope, and Methodology

Page 49 GAO- 03- 23 Mojave Desert Tortoise

data were not available for the years since 1998, we requested estimates
of staff time devoted to the tortoise from the five key federal agencies
involved in the tortoise*s recovery: the Bureau of Land Management,
Department of Defense, Fish and Wildlife Service, National Park Service,
and U. S. Geological Survey. We asked these agencies to provide, for each
employee who worked on tortoise- related activities, the employee*s name,
grade level, area of expertise, and percent of time devoted to
tortoiserelated activities during each fiscal year from 1980 through 2001.
Through discussions with various agency officials, we determined that the
request was reasonable and that the agencies would be able to provide us
with fairly reliable staff- time estimates by consulting various staff
members, personnel records, and historical data. Based on these
discussions, we provided each of the five agencies with instructions,
guidance, and examples of the information sought. We received staff- time
estimates from all but two of the pertinent agency offices (e. g., those
offices likely to have extensive experience and involvement in desert
tortoise issues). We did not receive estimates from Nellis Air Force Base,
Nevada, or the Chocolate Mountain Aerial Gunnery Range, California.

To analyze the estimates, we used the Office of Personnel Management*s
historical salary tables to calculate the salary for each grade level in
each year. In accordance with guidance contained in Circular A- 76, 2
issued by the Office of Management and Budget (OMB), we used step 5 of
each grade level to calculate salaries, except when the agency*s data
included the step. For staff that were members of the military, we asked
the installation to convert the military pay grade to the equivalent
general schedule grade. Finally, based on A- 76 guidance and our
discussions with officials of OMB and MEVATEC Corporation (a contractor
that advises and assists the Department of Defense with A- 76 cost
comparisons), we determined, for each year, the salary percentage that
represented the value of the federal benefits package (i. e., health
insurance, life insurance, pension plans, and workman*s compensation). We
adjusted the staff- time values to constant 2001 dollars.

2 Circular A- 76 provides guidance on calculating the cost of federal
personnel. The circular provides the policies and procedures agencies are
to use in comparing the costs of conducting a function in- house and
contracting it out.

Appendix II: Objectives, Scope, and Methodology

Page 50 GAO- 03- 23 Mojave Desert Tortoise

We obtained staff- time estimates from the following federal agencies and
offices.

 Bureau of Land Management* California Desert District (District Office
and five field offices: Ridgecrest, Palm Springs, El Centro, Barstow, and
Needles); Las Vegas Field Office; St. George Field Office; Utah State
Office; and Cedar City District Office.  Department of Defense* National
Training Center, Fort Irwin; Marine

Corps Air Ground Combat Center, Twentynine Palms; Edwards Air Force Base;
and Naval Air Weapons Station, China Lake.  U. S. Geological Survey* Mid
Continent Ecological Science Center, Fort

Collins; Northern Rocky Mountain Science Center; Western Ecological
Research Center Field Stations in Las Vegas, Nevada; Riverside,
California; and St. George, Utah (this field station no longer exists). 
Fish and Wildlife Service* Laguna Niguel/ Carlsbad Field Office, Ventura

Field Office, Barstow Field Office, Salt Lake City Office, Phoenix Office,
Reno Office, Las Vegas Office, and Portland Regional Office.  National
Park Service* Joshua Tree National Park, Mojave National

Preserve, Lake Mead National Recreation Area, and Zion National Park. To
obtain a perspective on potential economic effects associated with the
tortoise recovery effort, we reviewed the economic analyses contained in
various documents, such as the critical habitat designation for the
tortoise, environmental impact statements prepared by federal agencies,
and habitat conservation plans. To gauge the potential economic effects of
grazing restrictions in tortoise habitat, we requested that the U. S.
Department of Agriculture*s Economic Research Service (ERS) calculate
county- level economic effects, using a recently published analytical
method. 3 The authors had developed this method to estimate both the
direct and indirect effects of grazing restrictions. Estimates of the
direct (ranch- level) effects were based on the value of county cattle and
sheep sales that would be lost if grazing restrictions were imposed.
Estimates of the indirect (and induced) effects of grazing restrictions
were then derived from an input- output model, using the estimates of the
direct effects. The indirect effects include the effects in all industries
that supply inputs to cattle and sheep producers; the induced effects
include changes in farm purchases due to changes in farm income.

3 Lewandrowski, Jan and Kevin Ingram, *Restricting Grazing on Federal
Lands in the West to Protect Threatened and Endangered Species: Ranch and
Livestock Sector Impacts,*

Review of Agricultural Economics, Vol. 24, Number 1, Spring/ Summer 2002,
pp. 78- 107.

Appendix II: Objectives, Scope, and Methodology

Page 51 GAO- 03- 23 Mojave Desert Tortoise

At our request, the Economic Research Service estimated hypothetical 10-
and 20- percent reductions in grazing owing to restrictions imposed to
protect the desert tortoise. Such levels of reduction were deemed
reasonable by the ERS researchers, given that not all land in the counties
evaluated was federally owned or within critical habitat for the tortoise.
(These hypothetical reduction levels are similar to those used in the
authors* original analysis.) The counties included in the study were those
with known populations of desert tortoises and those with critical habitat
for the species. Other counties were also included as part of a regional
economic analysis. The study included Mohave County in Arizona; Kern, Los
Angeles, Riverside, San Bernardino, and Inyo Counties in California;
Clark, Esmeralda, Nye, and Lincoln Counties in Nevada; and Washington
County in Utah. It relied on data on grazing activity from the National
Agricultural Statistical Service*s Census of Agriculture, the Department
of Agriculture*s Forest Service, and the Bureau of Land Management.
General economic data and regional economic data were supplied through
IMPLAN* the input- output modeling framework, software, and database
developed by the authors and discussed in the referenced article.

We performed our work from November 2001 through September 2002 in
accordance with generally accepted government auditing standards.

Page 52 GAO- 03- 23 Mojave Desert Tortoise

Appendix III: Comments from the Department of the Interior

Page 53 GAO- 03- 23 Mojave Desert Tortoise

Trish McClure (202) 512- 6318 In addition, Carol Bray, Jennifer Duncan,
Kathleen Gilhooly, Tim Guinane, Jaelith Hall- Rivera, Cynthia Norris, Judy
Pagano, and Pamela Tumler made key contributions to this report. Appendix
IV: GAO Contact and Staff

Acknowledgments GAO Contact Acknowledgments

(360149)

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