Combating Wildlife Trafficking: Agencies Are Taking Action to Reduce Demand but Could Improve Collaboration in Southeast Asia
Released: 2017-10-12T00:00:00

Letter

Background

The National Strategy for Combating Wildlife Trafficking and Reducing Demand

The 2014 National Strategy defines wildlife trafficking as including all aspects of the trade, from poaching and transit through consumer use. The National Strategy outlines the guiding principles and strategic priorities for U.S. efforts to stem illegal trade in wildlife, and one of the top three priorities identified is to “Reduce Demand for Illegally Traded Wildlife.” Specifically, the National Strategy states that, as a strategic priority, reducing demand for illegally traded wildlife calls for raising public awareness of the harms done by wildlife trafficking through outreach in the United States and public diplomacy abroad. The National Strategy also states that the Task Force will seek to enlist individual consumers in this fight through education and outreach to reduce demand for these products and change consumption patterns that drive wildlife trafficking.

While the Implementation Plan outlines a unique set of activities to reduce demand, other activities under the plan’s objectives may indirectly affect demand. For example, one of the objectives under “Reduce Demand for Illegally Traded Wildlife” is to raise public awareness and recognition of wildlife trafficking and its negative impacts and associated risks of prosecution (emphasis added) as a means to change harmful consumption patterns. Implementing robust legal frameworks and effective enforcement increases the risk of prosecution, which may deter not only wildlife traffickers but also consumers, who may risk legal penalties. For the purposes of this report, we consider efforts to reduce consumption of wildlife and law enforcement efforts to prevent illegal use of wildlife as demand reduction-related activities.

The Implementation Plan designates various U.S. agencies to lead or participate in achieving the strategic priority of reducing demand for illegally traded wildlife, which are outlined in table 1.

In fiscal years 2014 through 2017, Congress directed that not less than certain specified amounts, totaling $271 million over the 4 fiscal years, be made available to combat wildlife trafficking (see fig. 1).

Global Efforts to Reduce Wildlife Trafficking

Since September 2016, U.S. agencies and global stakeholders have taken a range of actions to address CWT issues (see fig. 2). For example, in October 2016, Congress passed the Eliminate, Neutralize, and Disrupt (END) Wildlife Trafficking Act of 2016. Among other things, the act calls for the Secretary of State, in consultation with the Secretaries of the Interior and Commerce, to submit an annual report that lists each country determined by the Secretary of State to be a focus country and a country of concern. The act also directs the Task Force to submit an annual strategic assessment of its work and provide a briefing to Congress. Additionally, the 17th Meeting of the Conference of the Parties for the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) took place September 24, 2016, to October 5, 2016. In December 2016, China announced that it would close its domestic ivory market by the end of 2017, and in March 2017, China announced closure of 67 ivory carving entities and retail outlets across the country.

Estimates of the Illegal Wildlife Trade

As reported by the United Nations, the International Criminal Police Organization (INTERPOL), and other sources, wildlife trafficking networks span the globe. Although sources have attempted to measure trade flows, there is no precise estimate of illegally traded wildlife, and available estimates are subject to uncertainty. In 2014, the United Nations Environment Programme (UNEP) reported that various sources estimate the global scale of illegal wildlife trade is between $7 billion and $23 billion annually. In 2016, UNEP and INTERPOL estimated that the scale of wildlife crime may have increased, based on a rise in environmental crime. They estimate that environmental crime increased by 26 percent since 2014 and continues to increase by 5 to 7 percent annually. Illegal, unreported, and unregulated (IUU) fishing often are not included in these estimates since discussion of wildlife trafficking, as it relates to marine species, focuses on those species protected under CITES and under statutes such as the Endangered Species Act and the Marine Mammal Protection Act, according to NOAA. While IUU fishing targets commercially harvested marine species, as the Implementation Plan outlines, the trafficking of fisheries products is a form of wildlife trafficking. In 2016, UNEP and INTERPOL estimated that the global scale of IUU fishing ranges from $11 billion to $24 billion annually.

Demand for Illegal Wildlife and Wildlife Products Is Difficult to Measure, but Data and Reports Indicate Range of Species and Products Is Diverse

The United States, China, and countries in Southeast Asia consume many types of legal and illegal wildlife for diverse purposes. It is difficult to measure demand for illegal wildlife and wildlife products due to the illicit nature of the trade, but various data sources and reports provide examples of the range of wildlife demand by illustrating types of wildlife that are seized by governments and purchased by consumers.

Illegal Wildlife Demand and Trade Are Diverse in the United States

U.S. trade in wildlife and wildlife products includes a variety of wildlife such as live reptiles, birds, mammals, and elephant ivory, according to law enforcement information, reports, and government and NGO officials. FWS and NOAA data on wildlife products seized at U.S. ports provide examples of the diversity of illegally traded wildlife in the United States. FWS and NOAA may seize wildlife products for a variety of reasons that include import, export, or sale of endangered or threatened species protected under U.S. laws and regulations. For example, FWS may seize a shipment due to invalid documentation needed to clear the shipment. From 2007 to 2016, the top 10 wildlife shipments—by species or species group—seized nationally by FWS were coral, crocodile, conch, deer, python, sea turtle, mollusks, ginseng, clam, and seahorse. These seized wildlife were in a variety of forms when confiscated, as shown in table 2. For example, more than half of seized seahorse shipments were dead whole animals, and a smaller percentage were medicinal parts or products. During the past 10 years, more than one-third of the wildlife shipments seized by FWS were confiscated while being imported from or exported to Mexico (13.6 percent), China (13 percent), Canada (8.6 percent). Additional examples of wildlife seized by FWS are shown in figure 3 and in appendix II.

Seizure data from NOAA Fisheries’ Office of Law Enforcement show that it has also seized a variety of marine wildlife products. From 2007 to 2016, confiscated shipments have included whale teeth and meat, seal oil pills, shark fins, and seal fur products like mittens and boots, according to NOAA’s seizure data. Seizure data from FWS and NOAA provide a helpful illustration of wildlife that has been confiscated at U.S. ports but may not be fully reflective of the illegal wildlife trade and consumption.

Seizure data show the types of wildlife confiscated at ports of entry in a country, but there are limits to what these data can tell us about the demand for products like illegally traded wildlife. Various factors influence the number of seizures at any given time or in any location such as the level of illicit trade and the level and efficacy of enforcement efforts. For example, as part of their enforcement, both NOAA and FWS conduct inspections of shipments at U.S. ports. In some cases, they conduct targeted inspections that may be based on information they have about a particular species or market, which may influence detection and seizures of illegal products. NOAA and FWS officials indicated that they can increase their enforcement efforts by targeting investigations on specific species or products. This additional effort may result in the seizure of more shipments than would be made using routine inspection processes.

In 2016, the NGO WildAid published a baseline survey conducted by KRC Research to inform a public awareness campaign effort with FWS. The survey reported that roughly 1 in 10 respondents in the United States indicated that they had purchased or knew someone who had purchased live animals such as iguanas, parrots, parakeets, or tortoises. A smaller proportion of those that responded (roughly 1 in 20) reported that they had purchased or knew someone who had purchased ivory. Reporting by the International Fund for Animal Welfare in 2013 also identifies the United States as a key end market for reptiles such as crocodiles, pythons, and caimans and for wildlife products such as ivory.

Based on reporting and discussions with U.S. government officials, there may be varying reasons for the demand for wildlife and wildlife products. Potential drivers of demand in the United States—in particular demand for illegal wildlife from Latin America— may include a desire for rare and exotic plants and animals, according to reporting by Defenders of Wildlife. FWS officials in Miami told us that some of the wildlife products they confiscate—such as products from cruise passengers— were purchased by travelers who were unaware of the restrictions on the wildlife product. FWS and U.S. Customs and Border Protection (CBP) officials told us that consumers use wildlife for many different purposes, including as pets, trophies, jewelry, food, religious items, and for medicinal purposes. For example, FWS officials in Miami told us that coral is often smuggled as part of the pet trade for use in aquariums. At the Port of Miami, an FWS official told us that FWS has also seized queen conch meat, which is exported from the Caribbean as a delicacy, according to FWS. During investigations, FWS has found wildlife intended to be used as art or trophies. During the course of their investigations, FWS officials in Miami have found a rhino bust being sold for $80,000 and a giraffe bust being sold for $100,000. FWS has also seized scarlet macaw feathers being used in jewelry, elephant ivory carved as decorative pieces, and taxidermy big cats seized as hunting trophies.

Illegal Wildlife Demand and Trade Are Diverse in China and Countries in Southeast Asia

Demand for illegally traded wildlife in China and countries in Southeast Asia includes many wildlife species and end uses, according to reports and government and NGO officials in the region. For example, iconic wildlife such as elephants and rhinos are often cited in reports and by officials in the field as examples of wildlife consumption in China and Southeast Asia, but other wildlife, such as pangolins, bears, sharks, and sea turtles are also named among the wildlife being consumed.

China is a consumption country for illegal wildlife, while Hong Kong, Thailand, and Vietnam are consumption and transit locations, according to officials we spoke with from the U.S. government, foreign governments, international organizations, and NGOs in these locations. Thailand often serves as a transshipment point for illegal wildlife due to its land borders with China, Laos, and Cambodia, according to government of Thailand officials. Government officials in Vietnam stated a similar claim, explaining that the country is often a transshipment point due to its land borders with China and Laos. Table 3 displays examples of wildlife consumed and trafficked in China, Hong Kong, Thailand, and Vietnam, according to U.S. government, foreign government, and NGO officials in-location and at DOI Headquarters.

The International Fund for Animal Welfare has reported that China is the world’s largest consumer of illegal wildlife products due to its demand for ivory, rhino horn, pangolin scales, bear bile, tiger bone, and shark fin soup. According to analysis by the United Nations Office on Drugs and Crime (UNODC) of seizure data from the World Wildlife Seizure database, China was the destination for about 40 percent of the ivory shipments that had reported destinations from 2006 to 2015.

Reports also identify Thailand as a part of the illegal ivory trade. INTERPOL’s 2015 investigation, Operation Worthy II, resulted in seizures of several tons of elephant ivory in Thailand and Singapore. TRAFFIC, the wildlife trade monitoring network, visited retail outlets in Bangkok, Thailand, during certain periods in 2013 and 2014 and, through covert surveys of vendors, found bangles, rings, toothpicks, hairpins, chopsticks, sculptures, and other products made of ivory for sale. TRAFFIC reports that for seven consecutive months, from November 2013 to May 2014, their surveys found more than 10,000 ivory items openly on display for sale in Bangkok.

An NGO official we spoke with in China told us that part of the NGO’s efforts includes targeting Chinese tourists traveling to Africa and Southeast Asia to prevent purchasing of ivory as well as rhino horn. UNODC has reported that more than two-thirds of rhino horns seized from 2006 to 2015 were destined for China or Vietnam.

Government officials in Hong Kong told us that they have also seized a variety of wildlife products such as pangolin scales and turtles. Examples of wildlife products seized by the government of Hong Kong are shown in figure 4 and in appendix II. Hong Kong’s government has also seized elephant ivory, though as of March 2017, certain registered ivory can be legally traded in Hong Kong under a license.

The Organisation for Economic Co-operation and Development reports that high economic growth may fuel consumer demand for status goods such as art from elephant ivory and traditional medicine using rhino horn. According to NGO officials we met with in Vietnam and China, consumers purchase illegal wildlife products as a status symbol or to demonstrate wealth. Wildlife is considered to be expensive and exotic in these countries, and there is conspicuous consumption in some areas, according to State officials in Vietnam and an FWS attaché. UNODC reports that a survey of 18 restaurants— identified as high end by UNODC— in Vietnam found that all of these restaurants sold pangolin meat. UNEP and INTERPOL describe a similar phenomenon of a culture of conspicuous consumption for wildlife products that indicate wealth. These organizations report that buyers place higher value on illegal wildlife products when they are considered rare and uncommon and thus drive up prices for illegal wildlife. Higher prices and the perception of luxury associated with products such as tiger pelts and shark fin soup may attract consumers who want to display their wealth, according to Global Financial Integrity.

Another end use of illegally traded wildlife is in traditional medicine in China and Vietnam, according to State and NGO officials in these countries. They stated that there are beliefs that certain wildlife provide health benefits; for example, pangolin scales are believed to help lactating mothers produce milk. State and NGO officials noted that traditional Chinese medicine has a long history of using various wildlife products. For example, American ginseng root is often consumed as a medicinal ingredient in China, according to FWS. While export of American ginseng is permitted, there are restrictions based on factors such as the age of the root. FWS has seized American ginseng root being exported from the United States to China, and the Hong Kong government has seized American ginseng being smuggled into Hong Kong. For additional examples of how wildlife is consumed, see the side bar for results from surveys conducted by USAID’s Asia’s Regional Response to Endangered Species Trafficking (ARREST) program.

Agencies Are Implementing Demand Reduction Efforts, but Opportunities Exist to Improve Collaboration in Southeast Asia FWS Raises Awareness and Enforces Laws in the United States and Builds Capacity Abroad

State Contributes to CWT- Related Diplomacy, Training, and Outreach

State has led diplomacy efforts and implemented training and outreach programs in Southeast Asia and China.

Diplomacy: State’s diplomatic CWT efforts have included coordinating discussions between the U.S. and Chinese presidents in 2015 that, according to State, contributed to China and the United States jointly committing to further restrict ivory exports and imports. In June 2016, State and China’s State Forestry Administration also led the breakout session on wildlife trafficking during the eighth round of the U.S.-China Strategic and Economic Dialogue in Beijing. In December 2016, China announced that it would implement a domestic ivory ban, and in March 2017, China announced the closure of approximately one-third of the country’s licensed ivory stores and carvers.

Training programs: State’s INL works to build law enforcement capacity abroad by supporting various trainings and workshops. For example, in 2015, Thailand INL funded training in wildlife trafficking and environmental crimes for 179 participants. In 2016, ILEA Bangkok sponsored two FWS-led CWT training courses and one environmental crimes course led by officials of the U.S. Environmental Protection Agency. During our field visit to Bangkok, we observed an ILEA course on combating wildlife trafficking for law enforcement officers, which is shown in figure 7. Through the United Nations Office on Drugs and Crime, INL funds Border Liaison Offices in Burma, Cambodia, Laos, Thailand, and Vietnam, intended to enhance interdiction and investigation capacity at land borders to prevent illicit trafficking. At these offices, INL has supported training for officials on wildlife trafficking detection and investigations.

Outreach efforts: State has supported and implemented activities to raise awareness about wildlife trafficking in Southeast Asia and China.

For example, State collaborated with USAID and the government of Vietnam to implement Operation Game Change, a 2015 awareness- raising effort designed to inform the Vietnamese public about wildlife trafficking issues such as the trade in rhino horn. In 2016, for World Wildlife Day, State’s Acting Assistant Secretary of State for Oceans and International Environmental and Scientific Affairs published an opinion editorial for the South China Post in Hong Kong to raise awareness about the illegal trade in elephant ivory.

Four Major Initiatives Frame USAID CWT Efforts in Asia

USAID conducts a range of CWT activities that are part of biodiversity, conservation, or other initiatives, but it has four major initiatives explicitly dedicated to CWT in Asia.

Asia’s Regional Response to Endangered Species Trafficking: ARREST was a multiyear program completed in 2016. The program was designed to curb wildlife trafficking by reducing consumer demand, strengthening law enforcement capacity, and boosting regional learning networks. As part of ARREST’s demand reduction objective, the program implemented various awareness-raising efforts such as the iThink campaign, which developed and displayed public service announcements in airports and subways in China, Thailand, and Vietnam and on television stations in China and Vietnam. Through the initiative dubbed “Wildlife Friendly Skies,” the ARREST program raised awareness among airline and airport staff in transport hubs identified as hotspots for wildlife trafficking, which included Bangkok, Thailand; Guangzhou, China; Hanoi, Vietnam; Nairobi, Kenya; and Nanning, China. The ARREST program also held various courses aimed at strengthening capacity across Asia. For example, the program held 14 courses for 195 trainees who were from Cambodia, Indonesia, Lao People’s Democratic Republic, Thailand, and Vietnam to train participants on completing wildlife crime investigations.

Saving Species: This USAID project began in 2016 and is a 5-year, $9.9 million effort to combat wildlife trafficking in Vietnam. The project specifically aims to reduce consumer demand for and consumption of illegal wildlife and wildlife products, strengthen wildlife law enforcement and prosecution, and improve and harmonize the legal framework for prosecuting wildlife crimes in Vietnam. Some of the project’s planned activities for the first year include market surveys focused on demand for wildlife such as elephant ivory, rhinos, pangolins, and tigers. The project plans to use the survey results to inform its awareness campaign messaging. The project also plans to conduct capacity assessments of enforcement agencies in Vietnam to inform development of targeted training curricula, modules, and materials.

Wildlife Asia: This USAID activity, in collaboration with the Association of Southeast Asian Nations, aims to reduce the demand for wildlife products and to improve regional action to end wildlife crime in Southeast Asia and China. As of August 2016, USAID has issued one contract, with an estimated value of $22.9 million, to implement this activity.

Protect Wildlife: This USAID project began in 2016 and is a 5-year, $24.5 million effort to reduce threats to biodiversity in the Philippines such as poaching and the illegal trade of wildlife and wildlife products as well as to sustain healthy ecosystems. USAID is working with public and private partners in the Philippines to strengthen conservation policies and improve habitat management and on-site and off-site enforcement systems.

USAID also conducts biodiversity and conservation initiatives that have CWT-related objectives but are not dedicated solely to CWT. For example, USAID implemented the Ecosystems Improved for Sustainable Fisheries project in the Philippines, designed to conserve marine biodiversity, enhance ecosystem productivity, and improve law enforcement at fisheries to combat illegal, unreported, and unregulated fishing.

Other Agencies Also Contribute to CWT

DOJ, NOAA, and Homeland Security also support efforts to combat wildlife trafficking in the United States and Asia. DOJ prosecutes criminals and publicizes through press releases the results of criminal convictions to encourage public awareness of this issue. DOJ also has participated in capacity-building workshops in Burma, Laos, Thailand, and Vietnam and CWT events such as the 2016 Hanoi Conference on Illegal Wildlife Trade and the annual U.S.–China Joint Liaison Group on law enforcement, in which DOJ, State’s INL, and other agencies participate in the Anti- smuggling Working Group. According to DOJ officials, DOJ also regularly advocates the use of the United Nations Transnational Organized Crime Convention as a legal basis for international cooperation to combat wildlife trafficking.

Domestically, NOAA inspects and seizes shipments at U.S. ports, investigates cases of wildlife trafficking, and raises awareness about wildlife crimes. NOAA has a liaison at Homeland Security’s CTAC and, according to NOAA officials, the CTAC has allowed NOAA to more proactively target shipments and improve coordination with FWS and CBP through daily interaction and more information sharing. As part of their efforts to raise awareness about wildlife trafficking, NOAA also works with DOJ, FWS, and State’s Bureau of Public Affairs to publicly report information on and raise awareness about law enforcement efforts such as seizures. Internationally, NOAA provides technical assistance, conducts capacity-building, and serves as a resource in international policy discussions. For example, in collaboration with USAID, an analysis unit from NOAA assisted the Philippines in developing an intelligence assessment of illegal trade and trafficking in marine species. In November 2015, NOAA Office of Law Enforcement officers participated in the Association of Southeast Asian Nations Trade and Environmental Dialogue in Malaysia, providing presentations on illegal, unreported, and unregulated (IUU) fishing and ways to combat the trade in IUU fish and fish products.

DHS’s CBP supports and coordinates with FWS and NOAA to interdict illegal wildlife shipments at U.S. ports. ICE HSI investigates wildlife crime in the United States, and in Asia it supports foreign government CWT efforts through capacity building and information sharing. For example, in Vietnam, ICE HSI regularly shares information on wildlife seizures with the host government to support investigations. In 2015, in Thailand, ICE HSI conducted a 5-day workshop on advanced wildlife trafficking investigations for officials across the government.

Disagreement on Roles and Responsibilities Hindered Some CWT Activities in Southeast Asia

Although agencies have worked together to combat wildlife trafficking, disagreement on roles and responsibilities has hindered some CWT activities in Southeast Asia, according to some officials. In prior work, we defined collaboration broadly as any joint activity that is intended to produce more public value than could be produced when the organizations act alone. We also identified practices that can enhance and sustain collaborative efforts, including establishing mutually reinforcing or joint strategies, defining and articulating a common outcome, and agreeing on roles and responsibilities.

We found that agencies applied some collaboration mechanisms but also have an opportunity to improve on agreeing on roles and responsibilities. For example, the White House established a joint strategy, the National Strategy for Combating Wildlife Trafficking, in 2014. The strategy lays out guiding principles and strategic priorities for U.S. efforts to stem illegal trade in wildlife. In Southeast Asia, the U.S. embassy in Malaysia’s Integrated Country Strategy articulates mission goals and objectives for a coordinated effort among all U.S. agencies and includes prevention of illegal wildlife trafficking as a key activity, according to officials. In addition, U.S. missions in Bangladesh, Cambodia, India, Laos, Nepal, Thailand, and Vietnam are developing CWT-specific country strategies, according to officials.

Agencies also defined and articulated a common outcome, outlined in the National Strategy for Combating Wildlife Trafficking Implementation Plan (Implementation Plan). The Implementation Plan states that success relies on agencies working in concert to carry out the objectives, which include strengthening enforcement, reducing demand for illegally traded wildlife, and building international cooperation. Under three strategic priorities, the Implementation Plan identifies 24 objectives and ways to measure progress for each. In Southeast Asia, State and USAID officials told us that they work toward those shared outcomes. In particular, they stated that to achieve the shared outcome of reducing demand for wildlife products, they cooperated on raising public awareness. For example, State collaborated with USAID in Vietnam to implement Operation Game Change, a 2015 awareness-raising effort designed to inform the Vietnamese public about wildlife trafficking issues. In addition, to achieve the common outcome of strengthening law enforcement capacity, USAID is partnering with State, FWS, and DHS and other nongovernmental actors to implement the Reducing Opportunities for Unlawful Transport of Endangered Species program, which aims to increase enforcement capacity at ports of entry in Vietnam and other countries.

The Implementation Plan designates various U.S. agencies to lead or participate in achieving CWT strategic priorities, so it provides high-level direction on agency roles. However, the Implementation Plan does not define specific roles and responsibilities at the working level for mission staff implementing programs and activities. Officials at some missions reported that agreement on roles, responsibilities, and priorities facilitated collaboration on CWT activities in some instances. For example, an FWS attaché in the region told us that there has been effective collaboration between FWS, State, and ICE HSI due to agreement on roles and a shared understanding of key law enforcement terms and responsibilities. In Thailand, FWS and ICE HSI officials told us that they share information on cases, and FWS and State officials indicated that they have jointly conducted a variety of capacity-building activities across the region. State officials at ILEA in Bangkok attributed their successful regional collaboration with FWS to a mutual understanding that CWT capacity building is a responsibility that should be prioritized. State officials in Cambodia indicated that their Embassy CWT Interagency Working Group has been a forum for discussion among agencies in Cambodia to collaborate on CWT roles and activities. The working group has a designated lead agency and provides a forum to prevent or resolve potential differences in points of view among the agencies.

However, some officials also reported instances of disagreement on roles and responsibilities that they said led to bad outcomes. For example, at the mission in Bangkok, Thailand, which coordinates CWT activities across the Southeast Asia region, agencies’ disagreements on roles and responsibilities have resulted in the delivery of inappropriate training activities and interference with U.S. efforts to cooperate with a foreign government, according to some officials. Specifically, FWS, State, and ICE HSI have disagreed with USAID on the roles and responsibilities that USAID implementing partners play with regard to law enforcement activities. USAID officials stated that they entrust their implementing partners to conduct law enforcement training and believe they sufficiently involve their U.S. agency counterparts. However, FWS, State, and ICE HSI officials believe that due to their law enforcement responsibilities specifically related to strengthening host countries’ antiwildlife trafficking enforcement efforts, they should be consulted and involved to a greater degree on activities directly related to such efforts.

In Thailand, a USAID implementing partner’s lack of collaboration with U.S. law enforcement entities resulted in inappropriate training activities, according to some officials. Officials from FWS, ICE HSI, and an NGO told us that a CWT course conducted by a USAID implementing partner in Thailand was inappropriate due to a focus on ambush and military tactics, which are not suitable for the park rangers that received the training. In addition, another training course conducted in Thailand was not tailored for that country’s landscape, according to a U.S. official, who explained that the Thai officers receiving the training would be unable to apply its lessons locally due to differences in terrain. FWS and ICE HSI officials stated that they were not sufficiently consulted prior to the training and, although they have provided feedback to USAID about these issues, they expressed concern that USAID had not fully considered the feedback. USAID officials indicated that training on ambush or military tactics would not have been allowed, and they have no evidence it occurred. USAID officials also stated that they were unaware of training that was not properly tailored and that host countries generally praised training that was provided by its implementing partner.

FWS and State officials in Thailand also told us that agencies’ and implementing partners’ efforts to share information on wildlife crime with foreign governments have been fragmented due to disagreements about roles. For example, USAID’s implementing partners and FWS separately approached foreign government entities to provide information or support during a recent law enforcement seizure of wildlife products. According to State and FWS officials in Thailand, while USAID’s implementing partner has a role in providing information that can support CWT activities, U.S. agencies in-country are responsible for official engagement on law enforcement matters and, therefore, should take the lead in communicating with host governments, particularly in criminal investigations.

According to USAID officials, USAID and its implementing partners share this responsibility and have a role to play. USAID officials told us that they were aware of the difference in views and acknowledged that there may have been instances in which an implementing partner overstepped. USAID officials further explained that they have made an effort to address this particular issue by changing its implementing partner as well as changing their CWT program structure from a cooperative agreement to a contract so that USAID has more oversight and control. The new implementing partner also brought in a law enforcement expert to help ensure that training and related activities will be appropriate, according to USAID officials. In addition, the new USAID program specifies that coordination with other agencies is required, and USAID conducted a regional workshop in March 2017 to serve as a mechanism for coordination.

However, even after this conference, officials indicated that some agencies still had not agreed on the appropriate balance for how implementing partners should collaborate with U.S. law enforcement on criminal investigations. According to State and FWS officials, differences in agency views of their roles have hindered U.S. efforts to cooperate with a foreign government and confuse foreign government officials who may not realize that an implementing partner is not a U.S. government agency and thus does not have the same authority. USAID officials indicated that they were unaware of instances where its implementing partner interfered with U.S. efforts to cooperate with a foreign government.

Our work has shown that although collaborative mechanisms differ in complexity and scope, they all benefit from certain key features, including clarity of roles and responsibilities. For example, our work also notes that agreement on roles and responsibilities helped agencies determine who will lead a collaborative effort, clarify who will perform specific tasks, organize joint and individual efforts, and facilitate decision making. In addition, we have previously reported that key issues agencies should consider whether participating agencies have clarified the roles and responsibilities of participants in collaborative efforts and whether participating agencies have agreed to a process for making and enforcing decisions. Some U.S. missions in Southeast Asia are developing CWT- specific country strategies, which could provide a platform for the Task Force to give additional guidance on roles and responsibilities of mission staff engaged in CWT efforts in the region. Doing so would help clarify which agency will do what and facilitate maximum use of resources.

FWS, State, and USAID Have Taken Steps to Assess CWT Activities

FWS, State, and USAID Monitor CWT Activities

FWS uses a range of measures to track the progress of its partners and grantees. For example, FWS has established standard indicators for CWT, which include the following: the number of arrests of large-scale wildlife traffickers resulting from a project’s investigations, operations support, or both; and the number of wildlife traffickers who have been arrested who are successfully prosecuted.

Specifically for public relations efforts, the guidance calls for applicants to identify the desired behavior that the campaign is intended to encourage. In addition, FWS required 2017 CWT project proposals to identify all expected outputs or products of key project activities. This may include management plans, brochures, posters, training manuals, number of people trained, workshops held, hours of training provided, and equipment purchased.

One FWS-funded program designed to counter pangolin trafficking to China by laying the foundations for reducing consumer demand provides an illustrative example of how it applied FWS monitoring guidance. Among other activities, the program proposed developing and piloting strategies to change behavior, with the goal of eliminating the market for illegally traded wildlife in key areas. The proposal identifies outputs, such as reports on consumer demand, and states that key components of developing a demand reduction strategy include identification of target audiences and the specific behaviors that the campaign aims to change. Quarterly reports as of April 2017 have described progress toward goals, outlining methodological details on how motivation and potential barriers for desired behavior will be measured. The program is scheduled to conclude in September 2017.

The FWS Office of Law Enforcement Strategic Plan 2016 – 2020 identifies a set of CWT-related metrics for CWT, such as interdictions, penalties, fines, and value of illegal activities. FWS reports this information publicly. For example, Operation Crash, an ongoing nationwide criminal investigation led by FWS that focuses on the illegal trade in rhinoceros horn and elephant ivory, has resulted in 32 individuals sentenced and approximately 34 years of total prison sentences, $2 million in fines, and $6 million in forfeitures as of February 2017.

Regarding U.S.-based partnerships, FWS monitored the U.S. Illegal Wildlife Demand Reduction Campaign by tracking the estimated number of people who see the ads (reach) and the number of times content is displayed (impressions). From launch through the middle of the second quarter of fiscal year 2017, FWS reported the following:

Billboards: Monthly, about 5 million travelers are estimated to pass by the airport billboards at the international airports of Atlanta, Georgia; Chicago, Illinois; Los Angeles, California; and Miami, Florida. To date, an estimated total of about 45 million travelers have passed through these airports and may have seen the messages.

Social media: On September 7, 2016, FWS and its implementing partner, WildAid, launched the campaign with joint press conferences held at the Atlanta International Airport and at the Los Angeles International Airport. This resulted in more than 1 million impressions on Twitter, engagement of more than 236,000 friends on Facebook, and 5,000 new followers on Instagram.

In addition, at the beginning of the campaign, WildAid completed a public survey to assess what percentage of the U.S. general public was aware of wildlife trafficking. At the conclusion of the 3-year campaign, WildAid intends to facilitate another public survey to evaluate the effectiveness of the campaign, with results expected in late 2018.

State

INL’s Guide to Developing a Performance Measurement Plan states that program teams are to monitor project activities and results in order to identify project successes and challenges, guide resource allocations, and facilitate improved performance. According to a State official, INL requires every CWT program implementer to provide quarterly progress and financial reports and final programmatic and financial reports. Quarterly reports must provide a quantitative and qualitative analysis of work performed and include, among other things, results achieved, challenges encountered, and action taken. At the end of a program, INL extracts best practices and lessons learned for future planning, according to a State official.

We examined monitoring documentation related to three INL CWT programs as illustrative examples, described below.

From February to March 2016, State’s ILEA in Thailand provided a Wildlife Trafficking Investigators course designed to cover a range of topics, including case management, corruption, and wildlife identification. The report covering the first quarter of calendar year 2016 for this program describes progress made toward objectives and identifies challenges and corrective action. For example, the report states that students participated in crime scene processing, surveillance, undercover operations, interviewing, raid planning, and case presentation exercises – all reflective of a specific performance measurement objective. The report also identifies challenges such as securing role players for exercises and proposes using FWS instructors and ILEA staff as a solution.

State provided an approximately $2 million grant, running from September 2015 to September 2017, to the Wildlife Conservation Society (WCS) aimed at strengthening the capacity of government and law enforcement officials on wildlife trafficking across key countries in Latin America and Asia. The report covering the first quarter of calendar year 2017 for this program describes progress and activities related to objectives. For example, one activity is intended to strengthen legislative frameworks to combat wildlife trafficking, and the report states that in Vietnam, WCS has been providing inputs to articles of the penal code relevant to wildlife protection.

State provided approximately $400,000 to UNODC and the University of Washington for a program running from September 2015 to September 2017 to facilitate forensic DNA analysis of ivory seizures in Africa and Asia. The most recent quarterly report for the program provides information on results associated with objectives. For example, one objective is to conduct DNA analysis on 175 African elephant reference samples, and the report indicates that over 100 samples had been analyzed from countries in Africa.

USAID’s Evaluation Policy states that performance monitoring reveals whether implementation is on track and that project managers will ensure that implementing partners collect relevant monitoring data. To monitor ARREST, USAID’s implementing partner collected and self-reported data on activities and progress against main goals. For example, the implementing partner reported in 2016 that to strengthen law enforcement, ARREST trained approximately 2,300 people. To reduce consumption of endangered species, ARREST’s iThink campaign at its peak reached more than 40 million people per day, according to the partner’s report. In addition, a contractor analyzed ARREST’s iThink demand reduction campaign results. According to its report, 62 percent of the audience in China had received the message after 6 months. In Thailand, 63 percent of the audience had received the message, while in Vietnam, 75 percent of the audience had received the message. The report also provided suggestions for future work based on lessons learned, such as segmenting the market, incorporating social norms, and increasing the emphasis on social media.

USAID designed monitoring elements into and developed plans for its recently initiated programs in Southeast Asia. For example, USAID’s request for proposal (RFP) for Saving Species Vietnam, issued in January 2016 prior to the contract award, identifies key results and illustrative indicators for the main tasks. Specifically, the RFP suggests metrics for reducing consumer demand, such as percentage of target audience that receives the intended message and percentage change in purchases of targeted illegal wildlife products. In addition, the RFP calls for quarterly reports that must include, among other things, performance indicator results against targets. USAID’s RFP for Wildlife Asia also designed monitoring into the program from the start by including similar elements.

In May 2017, USAID produced an Activity Monitoring, Evaluation and Learning Plan for Saving Species (MEL Plan), which includes a Results Framework that identifies the purpose of the program and details associated tasks and key results. According to the MEL Plan, the Results Framework was developed based on a range of inputs, including USAID’s Measuring Efforts to Combating Wildlife Crime – A Toolkit for Improving Action and Accountability. The MEL Plan also provides a mix of output and outcome performance indicators with baselines and targets, to be used for communication and decision making. In addition, the MEL Plan calls for Pause and Reflect Sessions, Annual Strategic Reviews, work planning sessions, and other key learning events to reflect on progress and use that knowledge to adapt accordingly. In May 2017, USAID also produced a draft MEL Plan for Wildlife Asia, which provides performance indicators with baselines and targets. In addition, the April 2017 draft MEL Plan for the Philippines Protect Wildlife program contains similar information and, according to USAID officials, the MEL Plan used the action and accountability toolkit to inform the development of CWT metrics.

One Evaluation of CWT Activities Has Been Conducted by USAID

One USAID CWT program in Asia conducted a midterm evaluation, but State and FWS have not conducted any evaluations. State has not conducted any evaluations of INL CWT activities because none meet State’s criteria for completing an evaluation, including funding and duration thresholds, according to a State official. FWS has not conducted any evaluations of its CWT activities in Asia but has established a new CWT-focused branch, which is developing a strategic plan, a framework, and indicators to measure progress and success for CWT efforts. In March 2016, the Task Force released an annual progress report that describes U.S. government accomplishments; however, according to an official, the Task Force does not plan to issue a progress report in 2017 due to vacancies in leadership and because agencies are working on a similar report planned for completion sometime in 2017, in response to the Eliminate, Neutralize, and Disrupt Wildlife Trafficking Act of 2016.

USAID’s Evaluation Policy states that for each project, consideration will be given during the design phase to the performance evaluation that will be undertaken. The ARREST program conducted a midterm evaluation, and we assessed it against key elements to determine the quality of the evaluation. We have previously reported that addressing or requiring certain elements provides the basis for a high-quality evaluation. For this analysis, we considered a range of criteria, including the following:

Evaluation questions align with program goals.

Target population and sampling method are appropriate, given the scope and nature of the evaluation questions.

Data collection is appropriate for answering the evaluation questions.

Data analysis is appropriate to answer the evaluation questions.

We found that overall, the midterm evaluation was acceptable in quality, although it fell short of fully addressing all the key elements. For example, the evaluation generally met the first two elements above. However, the evaluation only partially met the element for data collection and data analysis. For example, the evaluation did not clearly specify how survey recipients had been selected and did not provide precise details about how qualitative data from in-person interviews had been analyzed. USAID did not conduct a final evaluation of ARREST because, according to officials, the timing of a late midterm evaluation was such that its findings were used in the development of the new Wildlife Asia program, and it would not have been cost-effective to conduct a final evaluation, among other reasons.

The draft Wildlife Asia MEL Plan identifies plans to prepare for a midterm and final performance evaluation at the middle and end of the program time line, and USAID officials confirmed that they intend to conduct evaluations of the program. The Saving Species MEL Plan indicates that program officials will work in collaboration with USAID to conduct a midterm evaluation and that one objective will be to provide recommendations in order to improve effectiveness and evaluate factors that help or hinder the achievement of expected outcomes and objectives. The MEL Plan also calls for a third-party firm, identified by USAID through a competitive process, to conduct the evaluation in the third year of the program. The draft Philippines Protect Wildlife MEL Plan indicates that the program will conduct a midterm and final evaluation.

FWS, State, and USAID Have Identified and Applied Some Lessons Learned

FWS, State, and USAID guidance states that agencies should learn from monitoring and evaluation efforts so they can identify what works, what does not work, and why. For example, from monitoring the first year of implementation, FWS learned from its domestic campaign that most Americans consider themselves wildlife lovers, but most know little about wildlife trafficking, indicating the need for outreach and education efforts.

State officials told us that they took stock of regional CWT activities in Asia to improve program planning. As a result, before launching the next set of CWT courses, INL is conducting a needs assessment to clarify skill gaps, impact potential, and alignment with other activities. In addition, INL is examining approaches to strengthen sustainability such as adding train-the-trainer courses.

USAID and implementing partner officials told us that they learned lessons during the implementation of ARREST and applied or plan to apply them to new programs. For example, in response to ARREST’s midterm evaluation recommendation to focus demand reduction efforts increasingly on behavior change communication, officials stated that they adjusted the message of their campaign advertisements to target behavior change and worked to recruit a range of key opinion leaders to maximize reach and impact. USAID intends to carry this lesson over to its new regional program, according to 2016 plans that call for the use of behavior change communication methodologies, as opposed to one-off public relations campaigns, in demand reduction activities. Officials told us that in practice this means future campaigns will focus on specific species, such as pangolins, and target Chinese and Vietnamese consumers who believe pangolin scales can help with lactation. USAID’s implementing partner for Saving Species also identified possible ways to improve the impact and sustainability of CWT training. For example, instead of providing traditional, onetime classroom training, officials plan to establish mentoring and on-the-job training programs in which officials in similar roles teach one another. This facilitates learning and may help identify CWT champions, enhancing sustainability and effectiveness, according to program officials.

Conclusions

Wildlife trafficking, worth at least an estimated $7 billion annually, continues to push some protected and endangered animal species to the brink of extinction. Although agencies have worked together to combat wildlife trafficking, as outlined in the National Strategy for Combating Wildlife Trafficking Implementation Plan, disagreement on roles and responsibilities has hindered some CWT activities in Southeast Asia. We have previously reported that key issues agencies should consider include whether participating agencies have clarified the roles and responsibilities of participants in collaborative efforts and whether participating agencies have agreed to a process for making and enforcing decisions. Agencies have collaborated on a range of CWT activities, including building law enforcement capacity, raising awareness, and helping spur partner-nation action on CWT. While agencies have applied some practices that can enhance and sustain collaborative efforts, such as establishing joint strategies and defining a common outcome, some officials in Southeast Asia reported a level of disagreement on roles and responsibilities, resulting in the delivery of inappropriate training activities and in the hindering of U.S. efforts to cooperate with a foreign government. DOI, State, and USAID are members of the Presidential Task Force on Wildlife Trafficking that is charged with coordinating among agencies combating wildlife trafficking efforts. By ensuring that all relevant member agencies have agreed on and clearly defined roles and responsibilities, agencies will have more reasonable assurance that they can effectively marshal the contributions of all agencies to take full advantage of their expertise and resources in addressing CWT issues. Taking steps to clarify specific roles and responsibilities, for example by including them in a CWT country strategy or other document, could help improve coordination, help ensure activities are mutually reinforcing, reduce the risk of fragmented efforts, and maximize the impact of CWT activities in Southeast Asia.

Recommendations for Executive Action

GAO is making the following three recommendations:

The Secretary of the Interior should work with the Task Force to clarify roles and responsibilities of mission staff engaged in collaborative efforts on combating wildlife trafficking in Southeast Asia. (Recommendation 1)

The Secretary of State should work with the Task Force to clarify roles and responsibilities of mission staff engaged in collaborative efforts on combating wildlife trafficking in Southeast Asia. (Recommendation 2)

The Administrator of the U.S. Agency for International Development should work with the Task Force to clarify roles and responsibilities of mission staff engaged in collaborative efforts on combating wildlife trafficking in Southeast Asia. (Recommendation 3)

Agency Comments and Our Evaluation

We provided a draft of this report for review and comment to the Departments of Commerce, Homeland Security, the Interior, Justice, State, and the Treasury, and USAID. The Departments of the Interior and State and USAID agreed with our recommendations, and their comments are reproduced in appendixes III, IV, and V, respectively. The Departments of Commerce, the Interior, Justice, and State and USAID provided us with technical comments, which we incorporated as appropriate.

In its comments, USAID indicated that it objects to the phrase “bad outcomes”, the word “inappropriate,” and the description related to an implementing partner that may have “overstepped” as used in our discussion of agency collaboration. We attribute that language specifically to certain agency officials, acknowledge differences in agency views, and include perspectives from USAID officials for balance.

In its comments, DOI notes that that the content in the report that most directly substantiates the recommendations occasionally reads as disagreements involving a few specific activities among a small number of U. S. government personnel. Our findings focus on a limited set of people and activities but reflect a clear opportunity to clarify roles and responsibilities. Moreover, as we mention, the mission in Bangkok coordinates CWT activities across the Southeast Asia region, so efforts to improve collaboration potentially would have a broad effect and benefit.

We are sending copies of this report to the appropriate congressional committees and to the Secretaries of Commerce, Homeland Security, the Interior, State, and the Treasury; the Attorney General of the United States; the Administrator of USAID. In addition, the report is available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-8612, or gianopoulosk@gao.gov. Contact points for our Offices of Congressional Relations and of Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix VI.

Appendix I: Objectives, Scope, and Methodology

This report examines (1) what is known about the demand for illegal wildlife and wildlife products in the United States and in Asia, (2) actions agencies are taking to reduce demand for illegal wildlife products in the United States and Asia, and (3) the extent to which the U.S. Fish and Wildlife Service (FWS) within the Department of the Interior (DOI), the U.S. Department of State (State), and the U.S. Agency for International Development (USAID) are assessing the effectiveness of their combating wildlife trafficking (CWT) activities.

We limited the scope of this review to the United States and Asia— identified as major markets for the illegal wildlife demand—to complement our 2016 report and to provide geographical diversity in our work. We selected these geographic areas based on our review of reports on demand for illegally traded wildlife and discussions with U.S. government agencies.

To address our objectives, we analyzed agency documentation and met with officials from DOI, State, USAID, the Department of Justice, and the Department of Commerce’s National Oceanic and Atmospheric Administration, which have designated roles in the National Strategy for Combating Wildlife Trafficking Implementation Plan to lead or participate in efforts to reduce illegal wildlife demand; the Department of Homeland Security, which has a role in enforcement and capacity-building efforts; and nongovernmental organizations (NGO) that focus on combating wildlife trafficking. We conducted fieldwork in Miami, Florida; China; Hong Kong; Thailand; and Vietnam. We selected these locations using a combination of criteria: (1) Since fiscal year 2014, the location has received at least $1 million in U.S. government funding for efforts related to CWT; (2) CWT activities are under way in the location; and (3) the location has the presence of at least two U.S. government agencies conducting CWT work. This sample is not generalizable to all the locations in which the United States has CWT-related programs.

While in each location in Asia, we interviewed officials who played a role in CWT activities, which included officials from State, USAID, and the Departments of Homeland Security and the Interior. We also interviewed officials from host governments responsible for the management of natural resources and parks and representatives from NGOs, some of which were involved in implementing U.S. government programs related to awareness raising, law enforcement, and other CWT objectives.

To describe what is known about the demand for illegal wildlife and wildlife products in the United States and in Asia, we reviewed reports on wildlife trafficking produced by United Nations organizations, the Organisation for Economic Co-operation and Development, and NGOs about the demand for these products in our locations of interest. We also reviewed surveys conducted for programs partially or fully funded by U.S. agencies that asked questions about purchasing behaviors for these products in the United States, China, Vietnam, and Thailand. These reports were either recommended to us by officials we interviewed or had been identified during our prior work on the supply of wildlife products. We reviewed the methodologies described in the reports and surveys and determined they were sufficiently reasonable for providing examples of wildlife and wildlife products traded and consumed and drivers for consumption in China and countries in Southeast Asia. However, it was beyond the scope of this review to determine the reliability of the underlying data. Many of these reports depend heavily on seizure data, which have limitations. The amount and location of seizures depend on law enforcement efforts, efficacy of law enforcement efforts, presence of illicit trade, and other factors, which are difficult to isolate.

Additionally, we analyzed national seizure data from the FWS’s Law Enforcement Management Information System to report on wildlife confiscated in the United States. To assess the reliability of these data, we interviewed agency officials, reviewed documentation about the data, and conducted basic logical tests. We reviewed the 42,100 seizure records that FWS provided for logical consistency and removed a few hundred records for which we found duplicative, unknown, or blank values. Overall, we determined the data are sufficiently reliable for the purposes of identifying wildlife products seized between fiscal years 2007 and 2016. Data on seizures may not be indicative of underlying trends in trade and consumption, as they are dependent upon factors such as enforcement and techniques used by those importing the goods. To gather perspectives on demand for illegally traded wildlife in China and Southeast Asia, during our field visits to China, Hong Kong, Thailand, and Vietnam, we interviewed officials from DOI, State, USAID, the Department of Homeland Security, and officials at foreign ministries, NGOs that are implementing partners for U.S. agencies or have cooperated with U.S. agencies on CWT activities, and one company. We interviewed the company for illustrative purposes.

To examine actions agencies are taking to reduce demand for illegal wildlife products in the United States and Asia, we interviewed relevant officials and reviewed information, including agency and implementing partner documentation of CWT-related projects, programs, and grants. We also analyzed how agencies combating wildlife trafficking in Southeast Asia are applying selected practices that can enhance and sustain collaborative efforts. As we have previously reported, such practices include establishing mutually reinforcing or joint strategies, defining and articulating a common outcome, and agreeing on roles and responsibilities. In addition, we conducted fieldwork at the Port of Miami and interviewed U.S. government officials at this location to obtain insights on U.S. government activities. We selected the Port of Miami because it has been the site of large-scale CWT operations, and agency officials identified Miami as a hub for wildlife trade and an illustrative example of U.S. government CWT operations. We also conducted fieldwork in China and Vietnam, where we visited rescue centers and interviewed host government officials and NGO representatives.

To examine the extent to which FWS, State, and USAID are assessing the effectiveness of their CWT activities, we selected programs to analyze, spoke with agency officials, and reviewed documentation from the programs selected. We included programs that had started, finished, or been ongoing from the beginning of fiscal year 2015 to the end of fiscal year 2016 and that are or were solely dedicated to CWT. Specifically for State, programs must have been identified by its Bureau of International Narcotics and Law Enforcement Affairs as a discrete activity that contributed to CWT and must have been at least 3 months into implementation. Specifically for USAID, programs must have (or have had) funding greater than $1 million. To assess agency monitoring practices, we analyzed agency guidance on monitoring and examined selected programs as illustrative examples of how agencies applied their own guidance. To assess evaluation practices, we assessed a USAID midterm evaluation against key elements to determine quality. Two social science analysts independently assessed this evaluation using the same criteria, methods, and procedures that we developed for GAO-17-316. The analysts met and reconciled any initial differences in their assessments.

We conducted this performance audit from October 2016 to October 2017 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Photographs Related to Combating Wildlife Trafficking in the United States and Asia

The following photographs (see fig. 8-26) were taken by GAO staff during field visits to Miami, Florida; Beijing, China; Hong Kong; Bangkok, Thailand; and Hanoi, Vietnam. GAO observed and photographed the following: shipment inspections conducted by U.S. Fish and Wildlife Service inspectors at the Port of Miami; examples of wildlife that are traded in the United States; examples of wildlife and wildlife products that have been seized by the U.S. Fish and Wildlife Service; examples of wildlife and wildlife products that have been seized in antiwildlife trafficking awareness campaigns at the Hartsfield–Jackson Atlanta International Airport; Beijing Capital International Airport; Hong Kong International Airport; Suvarnabhumi Airport, Bangkok, Thailand; Chatuchak Market in Bangkok, Thailand; and a highway in Hanoi, Vietnam; wildlife at the Beijing Rescue and Rehabilitation Center; the Endangered Primate Rescue Center, Cuc Phuong National Park, Vietnam; and the Carnivore and Pangolin Rescue Center, Cuc Phuong National Park, Vietnam; and shops that sell ivory products in Hong Kong.

To view these photographs online, please click on this hyperlink.

Appendix III: Comments from the Department of the Interior

Appendix IV: Comments from the Department of State

Appendix V: Comments from the U.S. Agency for International Development

Appendix VI: GAO Contact and Staff Acknowledgments

GAO Contact

Kimberly M. Gianopoulos, (202) 512-8612, or gianopoulosk@gao.gov.

Staff Acknowledgments

In addition to the individual named above, Judith Williams (Assistant Director), Marc Castellano (Analyst-in-Charge), David Dayton, Martin De Alteriis, Neil Doherty, Mark Dowling, Michael Hoffman, and Jasmine Senior made key contributions to this report.