Federal Lands:

Adopting a Formal, Risk-Based Approach Could Help Land Management Agencies Better Manage Their Law Enforcement Resources

GAO-11-144: Published: Dec 17, 2010. Publicly Released: Dec 17, 2010.

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Four federal agencies--the Forest Service in the Department of Agriculture and the Bureau of Land Management, Fish and Wildlife Service, and National Park Service in the Department of the Interior--are responsible for managing federal lands, enforcing federal laws governing the lands and their resources, and ensuring visitor safety. Illegal activities occurring on these lands have raised concerns that the four agencies are becoming less able to protect our natural and cultural resources and ensure public safety. GAO examined (1) the types of illegal activities occurring on federal lands and the effects of those activities on natural and cultural resources, the public, and agency employees; (2) how the agencies have used their law enforcement resources to respond to these illegal activities; and (3) how the agencies determine their law enforcement resource needs and distribute these resources. GAO reviewed agency documents, interviewed agency officials, and visited or contacted 26 selected agency units.

A wide variety of illegal activities occurs on federal lands, damaging natural and cultural resources and threatening the safety of the public and agency employees. These activities can range from traffic violations to theft of natural and cultural resources to violent crimes. The frequency with which these illegal activities occur is unknown, as agency data do not fully capture the occurrence of such activities; similarly, the extent of resource damage and threats to public and agency employee safety is also unknown. These activities can have overlapping effects on natural, cultural, and historical resources; public access and safety; and the safety of agency employees. For example, illegal hunting results in the loss of wildlife and may also reduce opportunities for legal hunting. Also, cultivation of marijuana not only increases the availability of illegal drugs but fouls ecosystems and can endanger public and agency employee safety. And theft or vandalism of archaeological and paleontological resources can result in the loss or destruction of irreplaceable artifacts, diminishing sites for future visitors and depriving scientists of important sources of knowledge. In response to illegal activities occurring on federal lands, agencies have taken a number of actions. For example, three of the four agencies have increased their number of permanent law enforcement officers in recent years. The Bureau of Land Management increased its number of law enforcement officers by about 40 percent since fiscal year 2000, the Forest Service by almost 18 percent during the same period, and the Fish and Wildlife Service by about 26 percent since fiscal year 2006. The agencies have also directed officers to respond specifically to marijuana cultivation and illegal border activities, assigned officers temporarily to areas needing a greater law enforcement presence during certain events and law enforcement operations, and increased the training required for new officers. Although land management agencies consider varied information on the occurrence and effects of illegal activities on federal lands, the agencies do not systematically assess the risks posed by such activities when determining their needs for resources and where to distribute them. While available information helps the agencies to identify many of the risks that illegal activities pose to natural and cultural resources, the public, and agency employees, limitations in this information do not allow officials to fully assess either the magnitude of those risks or the likelihood of their occurrence. As a result, the agencies cannot systematically assess the relative risks faced by the hundreds of individual land management units across the country when making decisions about needed law enforcement resources and how to distribute those resources. Without systematic approaches to assess the risks they face, the agencies may have limited assurance that they are allocating scarce resources in a manner that effectively addresses the risk of illegal activities on our nation's federal lands. GAO recommends that the agencies adopt a risk management approach to systematically assess and address threats and vulnerabilities presented by illegal activities on federal lands. In commenting on a draft of this report, the Forest Service and Interior concurred with GAO's recommendation.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: Based in part on our recommendations, the National Park Service, the Bureau of Land Management, and the Fish and Wildlife Service took several steps to strengthen their law enforcement programs. In November 2009, the National Park Service contracted with ICF International to evaluate the Visitor Management and Resource Protection Assessment Program (VRAP), a tool which guided staffing allocation for various park protection positions including law enforcement. In April 2011, an ICF report identified several weaknesses in VRAP and made recommendations on how VRAP could be improved. To address VRAP's weaknesses, the National Park Service released a new tool developed by ICF called the Staffing Analysis and Risk Reduction Tool (STARTT). Among other improvements, superintendents can use STARTT to identify potential risks to law enforcement, safety, resource protection and infrastructure protection if planned staffing levels are below STARTT's estimated staffing needs. Prior to STARTT's release, NPS developed a user's handbook to assist with training and implementation, and piloted the tool in 25 parks. In March 2012, the Bureau of Land Management issued a memorandum to all law enforcement field officials requiring that risk management be incorporated into state and field office Law Enforcement Plans. To implement this requirement, the Bureau of Land Management developed the Law Enforcement Integrated Risk Rating Tool (LEIRRT), developed a user guide for the tool, and trained law enforcement staff and managers on how to complete the tool and use it for decisionmaking. The LEIRRT assigns risk scores for nine risk factors--including fire, drug production, and illegal border activities--and weighs and aggregates the scores to develop a final risk determination for each factor. The resulting scores can be used to incorporate risk into state and field office Law Enforcement Plans including law enforcement staffing. In fiscal year 2013, all Bureau of Land Management all state and field offices were required to upload completed LEIRRTs to the Bureau's Office of Law Enforcement and Security. In addition, starting in 2011, the Fish and Wildlife Service began developing a risk-based approach deployment and staffing model. As part of this, the Fish and Wildlife Service has been working on a risk intelligence staffing calculator (RISC) that will, among other things, identify risks that illegal and legal activities pose to natural and cultural resources, assess the magnitude of those risks and likelihood of occurrence, prioritize risks for preventative control actions, and restructure and strengthen the staffing and deployment model to integrate risk assessment requirements. This calculator is being fined tuned using data supplied by officers in all eight Fish and Wildlife Service regions. These efforts will ultimately culminate with a new staffing model for law enforcement.

    Recommendation: To help the agencies identify the law enforcement resources they need and how to distribute these resources effectively, the Secretaries of Agriculture and the Interior should direct the Chief of the Forest Service and the Directors of the Bureau of Land Management, Fish and Wildlife Service, and National Park Service, respectively, to each take the following action: Adopt a risk management approach to systematically assess and address threats and vulnerabilities presented by illegal activities on federal lands. The approach can vary among the agencies but should be consistent within each agency and should include (1) conducting periodic risk assessments to identify and rank threats and assess agency vulnerabilities and (2) establishing a structured process for using the results of these assessments to set priorities for and distribute law enforcement resources to best protect natural and cultural resources, as well as public and agency employee safety. In developing a risk management approach, the agencies should consider conducting the risk assessments at regional or state levels and using those assessments to inform decisions about law enforcement resource needs and how to distribute those resources across the country.

    Agency Affected: Department of the Interior

  2. Status: Closed - Implemented

    Comments: Based in part on our recommendations, the Forest Service took several steps to strengthen its law enforcement program. First, in November 2013, Forest Service updated the template that its regional offices use for law enforcement planning. The template includes sections on identifying and ranking risks and vulnerabilities. Regions are required to assess circumstances in their region using the template and are expected to review the plans annually and update them as needed. As of July 2014, at least four of the agency's nine regions had submitted plans based on the template. Second, the agency also strengthened the process it uses for the Washington Office to determine if shifts in resource allocation are needed. In August 2014, a senior law enforcement official told us that this process relied on regular meetings (approximately every two weeks) by the Law Enforcement and Investigations leadership team, which is composed of key officials in the Washington Office and the Special Agent in Charge from each region, as well as on the information in the law enforcement plans submitted by the regions.

    Recommendation: To help the agencies identify the law enforcement resources they need and how to distribute these resources effectively, the Secretaries of Agriculture and the Interior should direct the Chief of the Forest Service and the Directors of the Bureau of Land Management, Fish and Wildlife Service, and National Park Service, respectively, to each take the following action: Adopt a risk management approach to systematically assess and address threats and vulnerabilities presented by illegal activities on federal lands. The approach can vary among the agencies but should be consistent within each agency and should include (1) conducting periodic risk assessments to identify and rank threats and assess agency vulnerabilities and (2) establishing a structured process for using the results of these assessments to set priorities for and distribute law enforcement resources to best protect natural and cultural resources, as well as public and agency employee safety. In developing a risk management approach, the agencies should consider conducting the risk assessments at regional or state levels and using those assessments to inform decisions about law enforcement resource needs and how to distribute those resources across the country.

    Agency Affected: Department of Agriculture

 

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