Endangered Species: Fish and Wildlife Service Generally Focuses  
Recovery Funding on High-Priority Species, but Needs to 	 
Periodically Assess Its Funding Decisions (06-APR-05,		 
GAO-05-211).							 
                                                                 
Currently there are more than 1,260 species listed as endangered 
or threatened under the Endangered Species Act of 1973. While few
species have gone extinct since 1973, only 9 have been		 
"recovered" or removed from the list because they no longer need 
the act's protection. This has raised questions about how the	 
U.S. Fish and Wildlife Service (Service) allocates its recovery  
funds. Proponents of the act believe that the Service's recovery 
funds are only a small fraction of what is needed to make greater
recovery progress. The act and agency guidelines require the	 
Service to prioritize species to guide recovery fund allocation. 
In fiscal year 2000 through 2003, the Service spent $127 million 
dollars in recovery funds attributable to individual species. In 
this report, GAO analyzed (1) the extent to which the Service's  
allocation of recovery funds compares with its recovery priority 
guidelines and (2) what factors influence the Service's recovery 
allocation decisions.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-211 					        
    ACCNO:   A20857						        
  TITLE:     Endangered Species: Fish and Wildlife Service Generally  
Focuses Recovery Funding on High-Priority Species, but Needs to  
Periodically Assess Its Funding Decisions			 
     DATE:   04/06/2005 
  SUBJECT:   Allocation (Budget Act)				 
	     Budget administration				 
	     Endangered species 				 
	     Environmental monitoring				 
	     Federal funds					 
	     Funds management					 
	     Wildlife conservation				 
	     Conservation					 
	     Natural resources					 
	     Wilderness areas					 
	     Policies and procedures				 
	     Endangered Species Program 			 

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GAO-05-211

United States Government Accountability Office

  GAO	Report to the Chairman, Committee on Resources, House of Representatives

April 2005

ENDANGERED SPECIES

 Fish and Wildlife Service Generally Focuses Recovery Funding on High-Priority
        Species, but Needs to Periodically Assess Its Funding Decisions

                                       a

GAO-05-211

[IMG]

April 2005

ENDANGERED SPECIES

Fish and Wildlife Service Generally Focuses Recovery Funding on High-Priority
Species, but Needs to Periodically Assess Its Funding Decisions

                                 What GAO Found

The Service spent its recovery funds in a manner generally consistent with
species priority in fiscal years 2000 through 2003, spending almost half
(44 percent) of the $127 million on the highest priority species (see
figure below). Species in the next two highest priority groups received
almost all of the remaining recovery funds (51 percent). Species in the
three lowest priority groups received very little funding (6 percent).
Most listed species (92 percent) are in the top three priority groups.

When Service officials allocate recovery funds, they base their decisions
to a significant extent on factors other than a species' priority ranking.
At the headquarters level, a formula that focuses on each region's
workload determines how recovery funds are allocated to regional offices.
Each regional office allocates its recovery funds to their field offices
differently, but in no case is priority ranking the driving factor.
Instead, regional officials focus primarily on opportunities for
partnerships, though they told us that they also focus on species facing
the gravest threats. Field office staff we spoke with emphasized the
importance of pursuing funding partnerships in order to maximize their
scarce recovery funds. The Service does not know the effect of these
disparate allocation systems because it does not have a process to
routinely measure the extent to which it is spending its recovery funds on
higher priority species. While we found that for fiscal years 2000 through
2003 the Service spent a majority of its recovery funds on high priority
species, without periodically assessing its funding decisions, the Service
cannot ensure that it spends its recovery funds on the species that are of
the greatest priority and, in cases where it does not, determine whether
its funding decisions are appropriate.

Recovery Funds Spent on Species by Priority, Fiscal Years 2000-2003
Recovery dollars in millions 60

44%

50 40 30 20 10

0

High Priority Low Source: GAO analysis of Fish and Wildlife Service data.

Note: Percentages add to more than 100 percent due to rounding.

                 United States Government Accountability Office

Contents

  Letter

Results in Brief
Background
The Service Spends a Significant Portion of Recovery Funds on the

Highest Priority Species

The Service Considers Factors Besides Species Priority When Allocating
Recovery Funds but Does Not Assess the Results of Its Funding Decisions

Conclusions
Recommendations for Executive Action
Agency Comments and Our Evaluation

1 3 5

13

19 30 31 31

  Appendixes

Appendix I: Scope and Methodology 33

Appendix II:	Comments from the Department of the Interior 38 GAO Comments
40

Appendix III:	GAO Contact and Staff Acknowledgments 42 GAO Contact 42
Staff Acknowledgments 42

Tables Table 1:

Table 2: Table 3:

Table 4:

Table 5: Table 6:

Total Reported Expenditures for All Endangered Species
Activities and Fish and Wildlife Recovery Expenditures by
Year for Fiscal Years 2000-2003 9
Fish and Wildlife Service's Recovery Priority Ranking
Schedule 10
Total Reported Expenditures for All Endangered Species
Activities Compared to Fish and Wildlife Service's
Recovery Expenditures During Fiscal Year 2003-for Top
20 Species 27
Fish and Wildlife Service's Recovery Expenditures
Compared to Total Reported Expenditures on All
Endangered Species Activities During Fiscal Year 2003-
for Top 20 Species 29
GAO Groupings of Priority Numbers 35
Number of Species in Each Priority Group, by Year 36

                                    Contents

Figures Figure 1:

Figure 2: Figure 3: Figure 4:

Figure 5:

Figure 6:

Figure 7:

Figure 8:

Figure 9:

Recovery Expenditures by Priority, Fiscal Years
2000-2003 4
The Fish and Wildlife Service's Fiscal Year 2003 Budget 8
Location of Fish and Wildlife Service's Seven Regions 12
Recovery Expenditures by Priority Ranking, Fiscal Years
2000-2003 14
Distribution of Species by Priority Ranking as of
September 2003 15
Weighted Average Per Species Expenditure, by Priority
Ranking, Fiscal Years 2000-2003 16
Distribution of Endangered and Threatened Species by
Priority Ranking as of September 2003 17
Weighted Average Per Species Expenditures, by
Taxonomic Classification, Fiscal Years 2000-2003 18
The California Red-Legged Frog Is Important to a
California Community Dueto Its Prominence in a Famous
Mark Twain Story 25

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.

A

United States Government Accountability Office Washington, D.C. 20548

April 6, 2005

The Honorable Richard W. Pombo Chairman, Committee on Resources House of
Representatives

The Endangered Species Act of 1973 protects more than 1,260 species facing
extinction or likely to face extinction (referred to as endangered and
threatened species, respectively). The purpose of the act is to conserve
endangered and threatened species and the ecosystems upon which they
depend. Critics of the act are concerned that this goal is not being met
because only 9 species have been "recovered"-brought to the point where
they no longer need the act's protection-since the act's inception in
1973.1 However, proponents of the act counter that because of the act's
protections only 9 species have gone extinct. Proponents also point out
that funding available to recover species is only a small fraction of what
federal scientists believe is needed, making greater recovery progress a
practical impossibility.

The U.S. Fish and Wildlife Service (Service) is responsible for
implementing the act for freshwater and land species.2 To recover species,
the Service develops recovery plans, which include site-specific recovery
tasks such as identifying the size of a population or restoring habitat.
Recovery plans can take years or decades to fully implement, depending on
the needs of the species covered by the plan. In 1979, Congress amended
the act, in part, to require the Service to establish guidelines for
prioritizing the development and implementation of recovery plans. The
Service established guidelines that, among other things, prioritize
species based on factors such as the degree of threat the species faces
and its potential to be recovered.3 Under these guidelines, therefore,
species facing a high degree of threat and having a high potential for
recovery are to be afforded the highest priority. Species in this category
include the northern spotted owl,

1As of September 30, 2004.

2The Department of the Interior has delegated its responsibility for
freshwater and land species to the U.S. Fish and Wildlife Service, which
established an endangered species program to implement the requirements of
the act. Responsibility for implementing the act for anadromous fish and
most marine species resides with the Department of Commerce, which has
delegated its responsibilities to the National Marine Fisheries Service.
This report does not address the National Marine Fisheries Service
program.

348 Fed. Reg. 43098 (Sept. 21, 1983).

the grizzly bear, and the American crocodile as well as lesser-known
highpriority species such as Fender's blue butterfly, Texas wild rice, and
the Hawaiian dark-rumped petrel (a sea bird). The recovery guidelines
emphasize that they should be used only as a guide, not as an inflexible
framework for determining funding allocations.

During fiscal years 2000 through 2003, the Service allocated $245 million-
between $56 million and $65 million per year-to develop and implement
plans under its recovery program.4 Biologists inside the Service and
elsewhere believe these funds are a small fraction of what is needed in
the face of the daunting recovery challenge. As a result, the Service
increasingly relies on partnerships with other federal agencies, the
states, and private organizations to help implement recovery plans and has
cultivated relationships with many of them by jointly funding projects.
For example, the Service's Hawaii field office is jointly funding a
project with other federal agencies, local governments, and The Nature
Conservancy to revitalize watersheds to help recover the endangered
Hawaiian duck, among other species. Although the Service is required to
report annually on all federal and some state expenditures on listed
species,5 it does not separately report on how it spent its recovery funds
by species.6

You asked us to assess how the Service allocates its recovery funds among
endangered and threatened species. In this report, we (1) analyze how the
Service's allocation of recovery funds compares with its recovery priority
guidelines and (2) determine what factors influence the Service's recovery
funding allocation decisions. Since most of the Service's recovery funding
was spent on salaries that are not allocated on a per species basis, we
asked each of the Service's regional offices to identify, to the extent
possible, the spending on individual species for fiscal years 2000 through
2003. Collectively, the regions were able to attribute to individual
species $127 million (52 percent) of the $245 million the Service
allocated to the recovery program. We also obtained the individual
species' priority ranking based on the recovery priority guidelines for
those years. We then

4All dollars in this report are in current year dollars.

5The act requires the Service to submit to Congress by January 15th an
annual report covering the preceding fiscal year containing an accounting
of a species by species basis for all reasonably identifiable expenditures
made primarily for the conservation of endangered or threatened species
pursuant to the act.

6In this report, the term "spent" refers to budget outlays or
expenditures.

compared the recovery expenditures for individual species with those
species' priority rankings for fiscal years 2000 through 2003. In
addition, we interviewed Service recovery officials in headquarters, all
seven regional offices, and several field offices throughout the country.
(See App. I for a more detailed description of the scope and methodology
of our review). We did not make a judgment about the adequacy or accuracy
of the Service's recovery priority system. In this report we analyzed only
Fish and Wildlife Service's recovery expenditures, not expenditures on
other endangered and threatened species activities (which are reported, in
combination with recovery expenditures, in Fish and Wildlife Service's
annual expenditure report to Congress) or expenditures from other
entities. We performed our work between February 2004 and January 2005 in
accordance with generally accepted government auditing standards.

Results in Brief	The Fish and Wildlife Service has spent its recovery
funds in a manner generally consistent with its recovery priority
guidelines. For fiscal years 2000 through 2003, the Service spent nearly
half (44 percent) of the recovery funds attributable to individual species
on species with both a high degree of threat and a high potential for
recovery (see fig. 1). These species constitute one-third of all
endangered and threatened species, and they received, on average, more
funding than species that were lower priority. Of the remaining recovery
funds, almost all (51 percent) was spent on species in the next two
highest priority groups-species with a high threat assessment but a low
potential for recovery, and species with a moderate threat assessment but
a high potential for recovery. Very little (6 percent) was spent on
species in the remaining three lowest priority groups and most of this is
attributable to spending on two species: the Bald Eagle (which is nearing
delisting) and the Canada Lynx (which was embroiled in controversy).

Figure 1: Recovery Expenditures by Priority, Fiscal Years 2000-2003

Recovery dollars in millions

60

44%

50

40

30

20

10

0

Threat

Recoverability

High Priority Low

Source: GAO analysis of Fish and Wildlife Service data.

Note: Percentages add to more than 100 percent due to rounding.

When Service officials allocate recovery funds, they base their decisions
to a significant extent on factors other than those contained in the
recovery priority guidelines, including workload and partnerships with
other organizations. Headquarters allocates most of its recovery budget
among the Service's seven regional offices using a formula to estimate
each region's workload based on the number of species that the region is
responsible for and a relative estimate of the cost to recover each
species. This formula does not necessarily reflect the threats facing a
species or its recoverability. Service officials told us that they use
this formula because it provides relatively stable funding to each
region-an important consideration because most of a region's recovery
budget supports staff salaries for recovery biologists. These biologists
work on a variety of recovery activities including helping to develop
recovery plans, coordinating recovery tasks and developing recovery
partnerships. After headquarters allocates funds to the regional offices,
the regional offices then allocate funds to the field offices, relying
extensively on factors such as long-standing arrangements to work with
partners to recover specific

species and other opportunities to have partners bring funding and
resources to the recovery program. Officials throughout the Service told
us that, in allocating funding, it is crucial to have flexibility to stray
from the recovery priority guidelines to maximize recovery resources
contributed through partnerships. However, the Service does not have a
process to routinely measure the extent to which it is spending its
recovery funds on high-priority species. As a result, the Service cannot
be certain that it will continue to spend its recovery funds on the
highest priority species as it attempts to maximize its partners'
contributions. In addition, because the Service does not separately report
on how it spent its recovery funds by species, it cannot show Congress or
the public the extent to which it is focusing its resources on the highest
priority species, or explain, in cases where it is not, that its resource
decisions are still appropriate. To make its allocation process more
systematic and transparent, we recommend that the Service periodically
assess the extent to which it is following its recovery priority
guidelines, identify how factors other than those in the guidelines are
affecting its funding allocation decisions, and report this information
publicly.

We provided the Department of the Interior with a draft of this report for
review and comment. In general, the Department agreed with our findings
and recommendations. The Department's letter and our response to it is
presented in appendix II.

Background	The purpose of the Endangered Species Act of 1973 is to
conserve endangered and threatened species and the ecosystems upon which
they depend. The act defines "conservation" as the recovery of endangered
and threatened species so that they no longer need the protective measures
afforded by the Act. The act defines as endangered any species facing
extinction throughout all or a significant portion of its range and
defines as threatened any species likely to become endangered in the
foreseeable future. The act requires the Secretary of the Interior to
publish a list of species it determines are endangered or threatened in
the Federal Register and specify any critical habitat of the species with
in its range-habitat essential to a species' conservation. Loss of habitat
is often the principal cause of species decline. Additionally, the act
establishes a process for federal agencies to consult with the Service
about their activities that may affect listed species. Federal agencies
must ensure that their activities, or any activities they fund, permit or
license, do not jeopardize the continued existence of a listed species or
result in the destruction or adverse modification of its critical habitat.

There were 1,264 species in the United States listed as endangered or
threatened as of September 30, 2004.7 The Service has responsibility for
1252 of these species. Thirty-two species have been removed from the list:
9 species as a result of recovery efforts, 9 because they have been
declared extinct, and 14 species for other reasons, mostly because new
information showed that listing was no longer warranted.8

The Service develops and implements recovery plans, among other things, to
reverse the decline of each listed species and ensure its long-term
survival. A recovery plan may include a variety of methods and procedures
to recover listed species, such as protective measures to prevent
extinction or further decline, habitat acquisition and restoration, and
other on-theground activities for managing and monitoring endangered and
threatened species. According to Service officials, it is their policy to
issue a recovery plan within two and a half years of the species' date of
listing. The Service exempts species from the plan requirement when it is
determined a plan will not promote their conservation.9 For example, the
ivory-billed woodpecker is exempt because the Service thinks it is
extirpated from the wild throughout its range.

Recovery plans aim to identify the problems threatening the species and
the actions needed to resolve them. The act directs the Service, to the
maximum extent practicable, to incorporate into each recovery plan (1) a
description of site-specific recovery tasks necessary to achieve the
plan's goal for the conservation and survival of the species; (2)
objective measurable criteria that will result in a determination that the
species can be removed from the list of endangered and threatened species
(delisted); and (3) an implementation schedule that estimates the time and
cost required to carry out the recovery tasks described in the recovery
plan. Service employees, independent scientists, species experts, or a mix
of

7This does not include foreign species-species whose current and historic
range occurs entirely under the jurisdiction of other countries.

8Some species were delisted because new information showed the species to
be more widespread or abundant than believed at the time the species was
listed. Other species were delisted for taxonomic reasons, meaning that
additional analysis found the species was not unique; for example, it was
simply a population of another common species making it ineligible for
listing. One species, the Hoover's woolly-star, was delisted as a result
of recovery actions and because of the availability of new
information-specifically, a new population was discovered. We counted this
species as one of the 9 species delisted as a result of recovery efforts.

9The Service does not require recovery plans for foreign species.

these people can develop recovery plans. According to Service officials,
as of September 2004, the Fish and Wildlife Service had 551 approved
recovery plans covering more than 1025 species (more than 80 percent of
all listed species).

The act also requires the Service to report biennially to certain
Congressional committees on efforts to develop and implement recovery
plans, and on the status of listed species for which plans have been
developed. The Service implements this requirement through its biennial
Recovery Report to Congress.10 Additionally, the act requires the Service
to submit an annual report to the Congress on federal expenditures for the
conservation of endangered or threatened species, as well as expenditures
by states receiving federal financial assistance for such conservation
activities.11 As part of its efforts to compile data for this report, the
Service collects data on recovery fund expenditures on a species-specific
basis, although these data have not been reported separately in published
expenditure reports.

With regard to Service funds, the Endangered Species program is a small
portion of the Service's overall budget ($132 million of $1.9 billion in
fiscal year 2003). Of this amount, about one-half is devoted to the
recovery program, $65 million (see fig. 2). This is similar to previous
fiscal years.12 The funds spent on the recovery program, however, are only
a portion of the total money spent to recover species. Some of the
Service's other programs, including refuges, contribute funds and staff to
species recovery. In addition, according to the Service, other federal and
non-federal entities contribute substantial funds to species recovery.

10The latest report is Recovery Report to Congress, Fiscal Years
2001-2002; U.S. Fish and Wildlife Service.

11See, for example, Federal and State Endangered and Threatened Species
Expenditures, Fiscal Year 2003, U.S. Fish and Wildlife Service. This is
the most recent report available.

12In fiscal years 2000, 2001 and 2002 the Service allocated, respectively,
$56 million, $60 million and $64 million in recovery funds.

Figure 2: The Fish and Wildlife Service's Fiscal Year 2003 Budget

Source: Fish and Wildlife Service and Department of the Interior budget
information.

Note: Candidate species are plants and animals for which the Service has
sufficient information on their biological status and threats to propose
them as endangered or threatened under the Endangered Species Act, but for
which development of a listing regulation is precluded by other higher
priority listing activities. The Candidate Conservation Program provides a
means for conserving these species.

In addition to the Service's Endangered Species Program expenditures to
recover species, other programs in the Service as well as other federal
and state agencies spend substantial funds on endangered species
activities, including land acquisition (see table 1).

Table 1: Total Reported Expenditures for All Endangered Species Activities
and Fish and Wildlife Recovery Expenditures by Year for Fiscal Years
2000-2003

                            In thousands of dollars

                        FY 2000 FY 2001 FY 2002 FY 2003

Total reported Federal and State
Expenditures for All Endangered Species
Activities (including land acquisition) 610,286 2,442,356 1,191,752
1,201,166

Service Recovery Expenditures 37,905 27,814 39,021 48,418

Source: Fish and Wildlife Service.

Note: The source of data for the row "Total Reported Federal and State
Expenditures on All Endangered Species Activities (including land
acquisition)" is the Service's fiscal year 2003 expenditure report
(Federal and State Endangered and Threatened Species Expenditures, Fiscal
Year 2003, U.S. Fish and Wildlife Service). In this report, the Service
identifies a number of differences in reporting methods that make it
difficult to compare expenditure data from different years. For example,
prior to the fiscal year 2001 report, the Service did not include cost
data that could not be attributed to a specific individual species. These
data are now included, and partially explains the notable difference
between the fiscal year 2000 and the fiscal year 2001 totals. The data
contained in this row also include Service recovery fund expenditures. The
source of data for the row "Service Recovery Expenditures" is unpublished
data that the Service collected for its expenditure reports. The Fiscal
year 2000 data does not include cost data that could not be attributed to
a specific individual species while the fiscal year 2001-2003 data does.

Congress amended the Endangered Species Act in 1979 to require the
Secretaries of the Interior and Commerce to establish, and publish in the
Federal Register, agency guidelines that include a priority system for
developing and implementing recovery plans. The Service adopted recovery
priority guidelines in 1980 and amended them in 1983.13 The guidelines
consist of two parts:

1348 Fed. Reg. 43098 (Sept. 21, 1983).

o 	Species are assigned a priority ranking between 1 and 18 on the basis
of (in descending order of importance) (1) the degree of threat
confronting the species, (2) recovery potential (the likelihood for
successfully recovering the species),14 and (3) taxonomy (genetic
distinctiveness).15 (See table 2.) Additionally, a "c" is added to the
ranking if there is conflict with economic activities, like development;
this gives the species priority over other species with the same ranking
but without a "c". Thus, the highest possible priority ranking is a "1c".
The Service sometimes changes a species' priority ranking when warranted
by a change in the species' situation.

Table 2: Fish and Wildlife Service's Recovery Priority Ranking Schedule

                  Priority                   Recoverability  
                      rank Degree of threat        potential     Taxonomy     
                                        High            High  Monotypic genus 
                                        High            High     Species      
                                        High            High    Subspecies    
                                        High             Low  Monotypic genus 
                                        High             Low     Species      
                                        High             Low    Subspecies    
                                    Moderate            High  Monotypic genus 
                                    Moderate            High     Species      
                                    Moderate            High    Subspecies    
                                    Moderate             Low  Monotypic genus 
                                    Moderate             Low     Species      
                                    Moderate             Low    Subspecies    
                                         Low            High  Monotypic genus 
                                         Low            High     Species      
                                         Low            High    Subspecies    

14According to the Service's priority guidelines, the criteria used to
determine recovery potential are how well the ecological processes and
threats that affect the species are understood, how easily the threats can
be alleviated, and whether intensive management is needed to recover the
species.

15According to the Service's priority guidelines, the criterion related to
taxonomy (genetic distinctiveness) is intended to devote resources on a
priority basis to those species representing highly distinctive or
isolated gene pools, as reflected by the taxonomic level at which they are
recognized.

(Continued From Previous Page)

                  Priority                   Recoverability  
                      rank Degree of threat        potential     Taxonomy     
                                         Low             Low  Monotypic genus 
                                         Low             Low     Species      
                                         Low             Low    Subspecies    

Source: Fish and Wildlife Service Endangered and Threatened Species
Listing and Recovery Priority Guidelines.

Note: A species that is a monotypic genus is the only remaining species
representing the entire genus.

o 	The second part of the priority system ranks the recovery tasks within
each recovery plan. Each task is assigned a priority number from 1 to 3,
with 1 being the highest. A priority 1 task is "an action that must be
taken to prevent extinction or to prevent the species from declining
irreversibly." A priority 2 task is "an action that must be taken to
prevent a significant decline in species population/habitat quality or
some other significant negative impact short of extinction", and a
priority 3 task is "all other actions necessary to provide for full
recovery of the species."16

The recovery guidelines emphasize that they should be used only as a
guide, not as an inflexible framework for determining funding allocations.

Within the Service, responsibility for implementing the act is divided
among its three administrative levels: headquarters, regions and field
offices. Headquarters officials develop policy and guidance and allocate
funding to the regions. Regional directors in the seven regions (shown in
figure 3) make most decisions on how to spend endangered species program
funds and are responsible for managing their field offices' program
activities. Field offices are responsible for implementing program
activities and setting priorities for projects they will undertake.

16We did not assess how the Service's allocation of recovery funds
compares with task priority.

The Service Spends a Significant Portion of Recovery Funds on the Highest
Priority Species

The Fish and Wildlife Service spent its recovery funds in a manner
generally consistent with species priority in fiscal years 2000 through
2003. From fiscal years 2000 to 2003, the Service spent 44 percent of its
recovery funds attributable to individual species on those species with
the highest priority, the 415 species ranked 1 through 3 on the 18-point
priority ranking scale (see fig. 4).17 However, 25 of these species
received no recovery funding at all during fiscal years 2000 through
2003.18 Additionally, two species with low priority rankings, the bald
eagle (with a priority ranking of 14c) and the Canada lynx (with a ranking
of 15), received substantial recovery funding during fiscal years
2000-2003.

17There were 415 species ranked 1 through 3 at the end of fiscal year
2003. In fiscal years 2000 through 2002 there were 395, 408 and 416
species ranked 1 through 3, respectively. Our analysis of species priority
rankings considered species, subspecies and populations of species, as
appropriate. For example, different wolf populations have different
priority rankings.

18Twenty-five of the 415 species ranked 1 through 3 in fiscal year 2003
received no funding attributable to individual species during fiscal years
2000-2003.

Figure 4: Recovery Expenditures by Priority Ranking, Fiscal Years
2000-2003

Recovery dollars in millions 60

44%

50

40

30

20

10

0

                                       Threat Recoverability Priority ranking

Source: GAO analysis of Fish and Wildlife Service data.

Note: Percentages add to more than 100 percent due to rounding. Recovery
expenditures on species with priority numbers 16-18 are less than one
percent.

One reason the Service spent 44 percent of its recovery funds attributable
to individual species on the highest priority species is that this group
accounts for a significant portion of all listed species-one-third (see
fig. 5). Similarly, the Service spent almost all (94 percent) of its
attributable recovery funds on species ranked 1 through 9 on the 18-point
scale, which account for 92 percent of all listed species.

Figure 5: Distribution of Species by Priority Ranking as of September 2003

Priority ranking:

Ranking 1-3 (415 species)

Ranking 4-6 (448 species)

Ranking 7-9 (284 species)

3.8%

Ranking 10-12 (47 species)

3.8%

Ranking 13-15 (48 species)

0.5%

Ranking 16-18 (6 species)

Source: GAO analysis of Fish and Wildlife Service data.

Note: The distribution of species by priority ranking in fiscal years
2000, 2001 and 2002 is not substantially different from the distribution
in fiscal year 2003, see app I.

As shown in figure 6, analysis of average spending on a per species basis
also reveals that more expenditures are made on higher priority species.
Additionally, the analysis shows the emphasis the Service placed on
species with a high degree of recoverability. The relatively large amount
of funding spent on species with low priority rankings (13 through 15) is
greatly influenced by spending on the bald eagle (with a priority ranking
of 14c) and the Canada lynx (with a ranking of 15). The bald eagle is
nearing delisting and the funding was spent on delisting activities. The
Canada lynx was embroiled in controversy that required recovery staff to
respond to litigation. When spending on these two species is removed, the
average amount spent on species in this priority group is significantly
lower.

Figure 6: Weighted Average Per Species Expenditure, by Priority Ranking,
Fiscal

Years 2000-2003

Recovery dollars in thousands 35

30

25

20

15

10

5

0 Threat Recoverability

Priority ranking

Source: GAO analysis of Fish and Wildlife Service data.

In addition to species priority ranking, another obvious measure of
priority is whether a species is endangered or threatened. Over
three-quarters (78 percent) of species protected under the act are listed
as endangered, and most of these have high priority rankings (see fig. 7).
We analyzed spending by species status (endangered or threatened) and
found that the Service spent a majority (64 percent) of its recovery funds
on endangered species during fiscal years 2000 through 2003.19

Figure 7: Distribution of Endangered and Threatened Species by Priority
Ranking as of September 2003

Number of species

500

400

300

200

100

0 Threat

Recoverability

Priority ranking

Endangered Threatened Source: GAO analysis of Fish and Wildlife Service
data.

19This analysis compares spending in fiscal years 2000 through 2003 with
species status as of September 30, 2003. Between fiscal years 2000 and
2003, the Service changed the status of only two domestic species, both
from endangered to threatened. The species were the largeflowered skullcap
and two populations of the gray wolf.

Finally, we analyzed spending by the three taxonomic classifications
included in the Service's recovery priority guidelines-monotypic genus,
species, and subspecies. As shown in figure 8, an analysis of average
spending on a per species basis reveals that more expenditures are made on
listed entities classified as monotypic genus. A species that is a
monotypic genus is the only remaining species representing the entire
genus.

Figure 8: Weighted Average Per Species Expenditures, by Taxonomic
Classification, Fiscal Years 2000-2003

Recovery dollars in thousands

80

70

60

50

40

30

20

10

0                     
      Monotypic Species   Sub-species 
          genus          
Priority 1,  2, 5, 8,              
4, 7, 10,      11,    3, 6, 9, 12,
ranking 13,   14, 17     15, 18    
16                    

Source: GAO analysis of Fish and Wildlife Service data.

The Service Considers Factors Besides Species Priority When Allocating
Recovery Funds but Does Not Assess the Results of Its Funding Decisions

When Service officials allocate recovery funds, they base these decisions
to a significant extent on factors other than a species' priority ranking.
At the headquarters level, a formula that accounts for each region's
workload, but not species' priority rankings, determines how recovery
funds are allocated. Each regional office allocates recovery funds to
their field offices differently, but in no case is priority ranking the
driving factor. Instead, regional officials focus primarily on partnership
opportunities, though regional officials told us they do try to provide
funds to species that have a high degree of threat. Although field office
staff we spoke with use priority rankings, they also emphasized the
importance of having flexibility to allocate funds to develop
partnerships. The Service does not know the extent to which these
disparate allocation systems yield results consistent with the Service's
priority guidelines because the Service does not have a process to
routinely measure the extent to which it is spending its recovery funds on
higher priority species.

Headquarters Allocates Funds to the Regions Based on Workload

In making allocation decisions, headquarters does not consider a species'
priority ranking or any of the factors that go into determining priority
rankings. Instead, it allocates recovery funds to its seven regions based
primarily on a formula that estimates each region's workload.20 The
formula estimates the recovery workload for each region by assigning each
species a score of between 2 and 7 points, based on the type of species
and its habitat needs. Higher points are assigned to those species whose
recovery requires higher levels of funding or effort-factors that are not
clearly related to a species' priority ranking. For example, animals are
assigned 2 points while plants are assigned 1. Species that occupy
habitats larger than 1 million acres or are migratory or aquatic are
assigned 5 points whereas species that occupy less than 1,000 acres are
assigned 1 point. Recovery funds are then allocated to the regions based
on the number of species occurring in each region and the points assigned
to those species. Additionally, headquarters uses a workload-based formula
to allocate funds to regions to develop recovery plans. Funds are
allocated to each region based on the number of species that it is
responsible for that have not been

20Some funds are not allocated according to this formula. For example,
headquarters sets aside approximately $1,000,000 for delisting and
downlisting activities and approximately $1,000,000 for "capability
funding" annually. Capability funding is used to help staff in each region
maintain a basic competency in recovery-related tasks. Additionally, the
Service allocates some funds based on direction provided it by Congress,
for example, through appropriation committee conference reports.

exempted from the plan requirement and that have been listed for 4 years
or less. If after 4 years there is still no plan, then the region no
longer receives recovery-planning money for that species, though the
region is still responsible for completing that species' recovery plan.

Service officials in headquarters told us that they use an allocation
system based on workload rather than the priority guidelines for a number
of reasons. First, this system provides relatively stable funding to each
region from year to year. In contrast, priority rankings can change over
time, which would add an element of unpredictability to the annual
allocations. Stability is important, according to Service officials,
because most of a region's recovery budget supports staff salaries for
recovery biologists. These biologists work on a wide variety of recovery
activities including helping to develop recovery plans, conducting as well
as coordinating onthe-ground actions to implement recovery plans,
conducting periodic species status reviews, developing recovery
partnerships, and litigation support. Second, although priority rankings
indicate which species are higher priority, they do not reflect how much
money a species needs. Service officials pointed out that higher priority
species are not necessarily more costly to recover than lower priority
species. Lastly, Service officials told us that a system based on workload
is more objective, and they expressed concern that the subjective nature
of priority rankings could create conflict between the regions if
allocations were based on these rankings. While Service officials at
headquarters told us that recovery funds should be spent according to
priority rankings, they believe those decisions should be made at the
regional level.

Almost all of the regional officials we talked to agreed that the
allocation system used by headquarters works well and is fair and
equitable, although some of them suggested changes. For example, some
regional and field office officials noted that a species' priority
ranking, particularly its degree of threat, could be included, along with
the existing workload factors, in headquarters' formula for allocating
recovery funds.

Regional Offices Focus on While each region allocates recovery funds to
its field offices differently, Opportunities for we found that the most
important consideration among the regions is to Partnerships When Making
maintain and develop recovery partnerships, either by funding long

standing arrangements to work with partners to recover specific species or

Funding Decisions	by taking advantage of opportunities to develop new
partnerships. For example, officials at the Southwest region told us that
for the last 10 years the region has allocated its discretionary recovery
funds primarily to four

species for which it has long-standing partnerships with other
entities-the Kemp's Ridley sea turtle, the whooping crane, the Mexican
wolf and the Attwater's prairie chicken.21 The financial support from
long-term partners, in concert with expenditures from the Service,
provides a stable funding source for recovery projects from year to year,
helping to create viable recovery programs for these four species. For
example, the Kemp's Ridley sea turtle population has increased from a low
of 270 females to several thousand females in the course of this long-term
partnership.

Source: Bill Reaves, Texas Parks and Wildlife.	Service officials told us
that it is important to maintain their yearly contributions to
long-standing partnerships, regardless of the species' priority ranking,
because the funds these partners contribute are critical to species'
recovery and the partners could lose interest without the Service's
contributions. Officials at all levels of the Service reported to us that
they have insufficient recovery funds. Although it is difficult to develop
an accurate estimate of the full cost to recover all listed species (and
it is unlikely that some species will ever be recovered), we analyzed the
cost data contained in 120 recovery plans covering an estimated 189 listed
species.22 Based on the Service's estimated recovery costs in these plans,
we found that it would cost approximately $98 million dollars to fully
fund these plans-plans that cover just 15 percent of listed species-for a
single year.23 This amount is well above the $65 million the Service
allocated in

Source: U.S. Fish and Wildlife Service.	fiscal year 2003 to develop and
implement recovery plans and does not account for the recovery needs of
the remaining 1000 listed species. Even implementing only the highest
priority recovery plan tasks for those 120 plans-recovery plan tasks
"necessary to avoid extinction," would cost approximately $57 million,
nearly 90 percent of the Services' total recovery budget in fiscal year
2003. Consequently, the Service is dependent on monetary contributions
from partners to facilitate species recovery.

Regional officials not only fund long-standing partnerships, but look for

opportunities to develop new ones as well. Service officials expressed

concern that if they were confined to allocating funds strictly by the

Source: U.S. Fish and Wildlife Service.

21Discretionary recovery funds are those funds left after the region
covers salaries, benefits, directives from headquarters, including items
funded at the direction of Congress.

22These 120 plans were the ones for which the Service provided us with
electronic versions of the plans' implementation schedules, which enabled
us to complete this analysis.

23We calculated this number by determining the average cost to implement
each plan based on the cost data in the plan and then summed the averages.
This figure does not include all estimated recovery costs, particularly
land acquisition costs, which can be expensive.

priority system, they could alienate potential recovery partners. For
example, some regional officials pointed out that land acquisition can
take many years, so if willing sellers present themselves, the region will
take advantage of that opportunity by allocating recovery funds to acquire
those lands even if they do not benefit a species of the highest priority.
In another example, officials in a field office in the Pacific region told
us they were able to leverage its $20,000 investment into a $60,000
project by developing an agreement with the U.S. Forest Service to jointly
fund a study to identify how the California red-legged frog was using
suitable habitat. Fish and Wildlife Service officials in the Pacific
region also leverage funds with non-

                    Source: U.S. Fish and Wildlife Service.

federal partners. In 2002, a $10,000 investment in desert tortoise
monitoring from the Fish and Wildlife Service was matched by $16,540 from
Clark County, Nevada and $5,000 from the Arizona Game and Fish Department.
Almost all of the Service officials we talked with stressed the importance
of having the flexibility to develop partnerships for recovery,
particularly to leverage the Service's scarce recovery funds.24 Finding
partners and other sources of funds to implement recovery actions is also
strongly emphasized in the Service's course on recovery implementation,
which is offered at the National Conservation Training Center in West
Virginia and other locations around the country.

While a species' priority ranking is not a primary factor for determining
how regions distribute recovery funds, regions do consider priority
rankings when making recovery allocations. The two regions responsible for
the most species, the Southeast region and the Pacific region,
specifically incorporate the priority system into their funding
allocations. In the Southeast, field offices and other divisions of the
Service, like Refuges,25 submit proposals to obtain recovery funding to
implement recovery plan tasks. Once the regional office receives all the
proposals, officials determine which ones to fund that year. In doing so,
they consider a number of factors, including the species' priority
ranking. Similarly, the Pacific regional office reserves a portion of the
recovery funds it receives and uses them to fund proposals submitted by
its field offices to implement recovery plan tasks. One of the factors the
region considers when determining which proposals to fund is the species'
priority ranking. Most of the other regions we talked to told us that they
consider some aspects of

24We were not able to quantify all funds provided by federal and
non-federal partners in implementing recovery actions because they do not
maintain expenditure data in this way.

25Refuges are a division of the Service that is responsible for managing
National Wildlife Refuges.

the priority system when making funding decisions, particularly the
species' degree of threat, although they do not directly consider a
species' priority ranking.

Sometimes regions will also target funds to lower--priority species if
they are nearing recovery.26 For example, the bald eagle ranked 20th among
those species with the highest recovery expenditures from fiscal year 2000
to fiscal year 2003, despite having a priority ranking of 14c. A Service
official attributed most of these expenditures to delisting activities for
the bald eagle. Many Service officials pointed out that the priority
system does not contain a mechanism for funding species that are nearing
recovery. Because a species' priority will decrease as its threats are
alleviated and it moves closer to recovery, the priority system would
dictate that other more imperiled species be funded before those that are
close to delisting. Consequently, species close to recovery might never be
delisted because funds would not be allocated to complete the tasks
required for delisting. Service officials told us they need flexibility to
provide funds that will help get species off the list. Headquarters
officials have also recognized this issue and, beginning in fiscal year
2004, created a special fund that directs funding to species close to
delisting (as well as those close to extinction) in its "Showing Success,
Preventing Extinction" initiative.

Field Offices We Talked to Use the Priority System When Making Funding
Allocations

In the field offices we contacted, we found that species' priority
rankings play an important role in recovery allocations. Service personnel
in four of the ten field offices we spoke with told us that a species'
priority ranking is one of the key factors they use to allocate recovery
funds.27 For example, in the Pacific Islands field office, which is
responsible for the recovery of over 300 species, officials use the
recovery priority system as a "first step," then overlay other factors,
like opportunities to leverage funding. Staff in five of the remaining six
offices we spoke with told us that while they do not specifically use the
priority system when making recovery allocations, they do consider a
species' degree of threat. Staff in the last field office said they did
not use the priority system because most of their funds were spent
according to direction provided by the region.

26These funds may come from the $1,000,000 headquarters sets aside for
delisting and downlisting or they may come from the region's recovery
budget.

27According to Service officials, there are approximately 70 field offices
that have lead responsibility for recovering species.

Despite their use of the priority system, most of the field office staff
we contacted also stressed the importance of having the flexibility to
allocate funds to take advantage of unique opportunities when they arise.
For example, officials in a field office in California told us they took
advantage of an opportunity to leverage recovery funding for the
California red-legged frog. A population of this frog was recently
discovered in Calaveras County, site of Mark Twain's famous story The
Celebrated Jumping Frog of Calaveras County, which featured the California
red-legged frog. The landowner where the population was discovered was
eager to work with the Service to build a stock pond to provide habitat
for the red-legged frog and eradicate bullfrogs (red-legged frog
competitors). The discovery of the frog population was momentous because
the species is important to local lore, and a population of the frog had
not been found in Calaveras County since the late 1800s (see fig. 9). Even
though the field office has 65 species with higher priority rankings than
the red-legged frog,28 officials decided to address this recovery
opportunity because of the frog's importance to the local community. Other
unique events also require funding flexibility. In a Utah field office
last year, for example, a road expansion threatened the existence of the
clay phacelia, an endangered plant. The field office staff responded to
this threat by working with partners to collect seeds for future
propagation.

28This California field office has the lead responsibility for 104
species.

Figure 9: The California Red-Legged Frog Is Important to a California
Community Due to Its Prominence in a Famous Mark Twain Story

Source: U.S. Fish and Wildlife Service.

The Service Does Not Assess and Report on Its Recovery Fund Expenditures

The Service does not know the extent to which recovery fund expenditures
are consistent with its priority guidelines. All of the Service's
organizational levels participate in funding decisions, often relying on
factors other than species priority. Although our analysis shows that the
Service generally spent its recovery resources on higher priority species
during fiscal years 2000 through 2003, we found that the Service has no
process to routinely measure the extent to which it is spending its
recovery funds on higher priority species. Without this information, the
Service cannot ensure that it is spending its recovery funds on such
species, and in cases where it is not,

determine whether the funding decisions are appropriate. This is
especially problematic as circumstances change-for example, when species
are added to the list or priority rankings change for already-listed
species.

Although the Service is required to report all federal and some state
expenditures on listed species,29 it does not separately report how it
spent its recovery funds by species. This lack of separate reporting can
make it difficult for Congress and others to determine whether the Service
is focusing its recovery resources on the highest-priority species. For
example, the species that received the greatest total federal and state
expenditures in fiscal year 2003 are substantially different from those we
identified as having received the greatest portion of the Service's
recovery fund expenditures. Of the 47 species that the Service reported as
having received the greatest total expenditures in fiscal year 2003,30 the
Service has joint or lead responsibility for 20 of them. The list of 20
species is radically different from the list that we identified as having
received the greatest portion of the Service's recovery fund expenditures
(see table 3). In the case of the Southwestern willow flycatcher, the
Service reported that more funds were expended on the flycatcher in fiscal
year 2003 than for all but three other species for which the Service has
lead responsibility. However, the information the Service provided to us
shows that it spent relatively few recovery funds on the Southwestern
willow flycatcher in fiscal year 2003-it ranked 84th in the Service's
recovery expenditures.

29The act requires the Service to submit to Congress by January 15th an
annual report covering the preceding fiscal year containing an accounting
on a species by species basis of all reasonably identifiable federal
expenditures made primarily for the conservation on endangered or
threatened species pursuant to the act. The act also requires the Service
to report similar expenditure information for states receiving grants
under section 6 of the act.

30See Federal and State Endangered and Threatened Species Expenditures,
Fiscal Year 2003. This is the most recent report available.

Table 3: Total Reported Expenditures for All Endangered Species Activities
Compared to Fish and Wildlife Service's Recovery Expenditures During
Fiscal Year 2003-for Top 20 Species

                    Total reported  Rank by total               
                    federal         reported                    
                          and state   federal and               
                                            state               
                    expenditures on  expenditures                     Rank by 
                                all        on all                     service 
           Priority      endangered    endangered    Service    recovery fund 
                            species       species recovery fund 
Species               activities    activities                             
    name    ranking                                expenditures  expenditures

Bull trout 9c $29,295,633 1 $2,063,748

Rio Grande silvery 2c 11,300,700 2 220,000 minnow

Red-cockaded 8c 11,069,069 3 505,676 woodpecker

Southwestern willow 3c 9,909,284 4 54,160 flycatcher

West Indian manatee 5c 9,798,514 5 996,457

Bald eagle 14c 7,831,531 6 239,866

Colorado pikeminnow 8c 7,262,592 7 225,009 (=squawfish)

Razorback sucker 1c 7,127,470 8 242,733

Desert tortoise 8c 6,522,281 9 223,064

Florida panther 6c 6,301,276 10 135,869

Atlantic salmon 6c 5,832,648 11 9,350

Louisiana black bear 9 5,613,874 12 193,107

Grizzly bear 3c 5,469,681 13 571,461

Mexican spotted owl 9c 5,443,009 14 40,000

Indiana bat 8 5,218,103 15 256,750

White sturgeon 3c 5,197,021 16 21,900

Humpback chub 2c 5,072,205 17 234,270

Northern spotted owl  3c             5,053,263 18              845,418   7 
      Whooping crane     2c             5,029,588 19              589,912  14 
Loggerhead sea turtle 7c             $4,767,416 20             $270,623 26 
                              Source: GAO analysis of Fish and             
                                   Wildlife Service data.                  

Note: The source of data for the column "Total Reported Federal and State
Expenditures on All Endangered Species Activities" is the Service's fiscal
year 2003 expenditure report (Federal and State Endangered and Threatened
Species Expenditures, Fiscal Year 2003, U.S. Fish and Wildlife Service).
We excluded species for which the National Marine Fisheries Service has
sole responsibility. We combined expenditures for experimental and
non-experimental populations when a listed entity had both. The data
include Service recovery fund expenditures. The source of data for the
column "Service Recovery Fund Expenditures" is data reported to us by each
of the Service's regional offices. We did not determine the extent to
which recovery fund expenditures reported to us correspond with those
included in the Service's published expenditure report.

Total reported expenditures and Service recovery fund expenditures differ
substantially because the Service's recovery priority guidelines do not
apply to most of the reported funds-those funds provided by other federal
agencies and some funds reported by state agencies.31 The Service has
little control over how other organizations spend their funds. The
reported expenditures also include Service expenditures in addition to
recovery funds, such as expenditures on listing and consultation, which
are also not subject to the Service's recovery guidelines. In fact, in
many instances, the Service does not have discretion over which species
should receive these funds. For example, the Service spends consultation
funds largely based on projects submitted to it by other federal agencies.

Not unexpectedly, the list of 20 species receiving the greatest portion of
the Service's recovery fund expenditures in fiscal year 2003 is also
different from the list of species receiving the greatest portion of total
federal and state expenditures in fiscal year 2003 (see table 4). For
example, the California condor and the Western population of the gray wolf
ranked first and third, respectively in recovery fund expenditures but are
ranked 25th and 29th, respectively in overall federal and state
expenditures.

31One exception is grants made to states. The act authorizes the Service
to provide financial assistance to states to assist in the development of
programs for the conservation of endangered and threatened species and for
other reasons. The Service considers recovery priority rankings when
awarding these grants.

Table 4: Fish and Wildlife Service's Recovery Expenditures Compared to
Total Reported Expenditures on All Endangered Species Activities During
Fiscal Year 2003-for Top 20 Species

                                                 Total reported Rank by total 
                                                 federal             reported 
                                                      and state   federal and 
                                                                        state 
                                         Rank by   expenditures  expenditures 
                                         service         on all        on all 
                Priority Service   recovery fund     endangered    endangered 
                recovery fund                           species       species 
Species name ranking             expenditures     activities    activities 
                expenditures                                    
    California       4c $2,810,000             1     $3,526,183 
      condor                                                    
    Bull trout        9c 2,063,748             2     29,295,633 
    Gray Wolf,                                                  
     Western                                                    
     Distinct                                                   
    Population                                                  
     Segment          3c 1,789,940             3      3,261,662 
West Indian          5c 996,457             4      9,798,514 
     Manatee                                                    
     Red wolf           5c 951,345             5        993,080 
Puerto Rican          2 900,000             6      1,419,800 
      parrot                                                    
     Northern                                  7                
spotted owl          3c 845,418                    5,053,263 

Gray Wolf, 	Southwestern Distinct	Population Segment	(Mexican wolf) 3c
800,000 8 934,170	

         Steller's eider          9        799,600       9       1,062,836    
       Giant garter snake         2c       724,038       10      1,561,474    
        Marbled murrelet          3        677,739       11      4,754,652    
           Bog turtle             6c       655,880       12      1,542,655    
        Virgin River chub         2c       631,751       13       462,136     
         Whooping crane           2c       589,912       14      5,029,588    
          Grizzly bear            3c       571,461       15      5,469,681    
      Karner blue butterfly       5        533,080       16      1,179,941    
        Spectacled eider          5        520,900       17       574,980     

       Red-cockaded                                                        
        woodpecker      8c              505,676 18              11,069,069  3 
Black-footed ferret  2               451,859 19              2,360,970  40 
Western snowy plover 3c             $451,786 20              $2,824,184 35 
                             Soure: GAO analysis of Fish and               
                                  Wildlife Service data.                   

Note: The source of data for the column "Total Reported Federal and State
Expenditures on All Endangered Species Activities" is the Service's fiscal
year 2003 expenditure report (Federal and State Endangered and Threatened
Species Expenditures, Fiscal Year 2003, U.S. Fish and Wildlife Service).
We excluded species for which the National Marine Fisheries Service has
sole responsibility. We combined expenditures for experimental and
non-experimental populations when a listed entity had both. The data
include Service recovery fund expenditures. The source of data for the
column "Service Recovery Fund Expenditures" is data reported to us by each
of the Service's regional offices. We did not determine the extent to
which recovery fund expenditures reported to us correspond with those
included in the Service's published expenditure report.

Without a process to measure the extent to which it is spending its
recovery funds on the highest-priority species, the Service lacks valuable
information that would aid it in making management decisions. For example,
while maintaining partnerships to fund certain species may be reasonable,
many of these partnerships have been in place for many years, and changes
to the species' status or threat level, as well as changes to the threat
level of other species and the addition of newly listed species, could
have occurred in that time. As such, perhaps the reasons for creating some
of these partnerships may have been superseded by other needs and it may
no longer be appropriate for particular species to garner so much funding
from the region. Officials in the Southwest region, for instance, told us
that most of the region's discretionary recovery funds are spent on four
species (Kemp's Ridley sea turtle, Whooping crane, Mexican wolf, and
Attwater's prairie chicken). These officials stated that they did not know
these species' recovery priority rankings until after we scheduled a
meeting with them, although they did believe the species to be highly
ranked. While these four species all have high priority rankings-2c, 2c, 3
and 3c, respectively- the region has lead responsibility for about 80
other species with a priority ranking between 1 and 3. Although many of
these species also received funding during fiscal years 2000-2003, more
than one-quarter (20 species) had no Service recovery fund expenditures
attributable to them.

Conclusions	The Service faces a very difficult task-recovering more than
1,200 endangered and threatened species to the point that they no longer
need the protection of the Endangered Species Act. Many of these species
face grave threats and have been imperiled for years. There are few easy
solutions. Like many other federal agencies, the Service has limited funds
with which to address these challenges. Fortunately, many other
organizations contribute resources to help species. The Service maintains
that its ability to be flexible in allocating its scarce recovery
resources is the key to maximizing those contributions from other
organizations. We agree that exercising flexibility in allocating recovery
funds under its priority guidelines is important, but this needs to occur
within the bounds of a systematic and transparent process. The Service,
however, does not have such a process. While the Service acknowledges that
it strays from its priority guidelines, it does not routinely analyze its
allocation decisions to determine whether it is focusing on the highest
priority species and, if not, why. Such an analysis is important to ensure
that the Service continues to spend its recovery funds on the highest
priority species over the long term. Without this information, the Service
cannot show Congress or the public the extent that it is focusing its
resources on the highest priority species, or

explain, in cases where it is not, that its resource decisions are still
appropriate.

To this end, we believe the Service's priority guidelines provide it with
the means to create a systematic and transparent allocation process while
still allowing it needed flexibility. Because the Service already collects
data, on a species by species basis, on how it spends its recovery funds,
it would be a simple task to measure the extent to which it is spending
its recovery funds on high-priority species. It could then make this
information publicly available, thus providing the Congress and the public
a yardstick with which to judge the efficacy of the Service's resource
allocation decisions.

Recommendations for Executive Action

To help ensure that the Service allocates recovery resources consistent
with the priority guidelines over the long term and in a transparent
fashion, we recommend that the Secretary of the Interior require the
Service to take the following two actions: (1) periodically assess the
extent to which it is following its recovery priority guidelines and
identify how factors other than those in the guidelines are affecting its
funding allocation decisions, and (2) report this information publicly,
for example, in its biennial recovery report to Congress.

Agency Comments and Our Evaluation

We received written comments on a draft of this report from the Department
of the Interior. In general, the Department agreed with our findings and
recommendations but believes that we underestimated the extent to which
the Service's funding decisions are consistent with its recovery priority
guidelines. Because we found that the Service spent its recovery funds in
a manner generally consistent with species priority, we do not believe
this is a significant issue. See appendix II for the Department's letter
and our response to it. Additionally, the Department provided technical
comments that we have incorporated into the report, as appropriate.

As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from
the report date. At the time, we will send copies of this report to the
Secretary of the Interior 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 staff have any questions, please call me at (202) 512-3841.
Key contributors to this report are listed in appendix III.

Robin M. Nazzaro Director, Natural Resources and Environment

Appendix I

Scope and Methodology

In response to a request from the Chairman, House Committee on Resources,
we (1) analyzed how the U.S. Fish and Wildlife Service's allocation of
recovery funds compares with its recovery priority guidelines and (2)
determined what factors influence the Service's recovery funding
allocation decisions. As agreed with the Chairman's staff, we evaluated
only those funds specifically spent by the Service to implement its
recovery program.

To address our first objective, we requested recovery expenditure data, on
a per species basis, from each of the Service's seven regions for fiscal
years 2000-2003.1 Because the Service spends most of its recovery funds on
salaries that are not allocated on a per species basis, we asked officials
in each region to attribute salaries to specific species to the best of
their abilities. To assess the reliability of these data, we compared the
total estimated expenditures we received from each region for each year to
budget documentation provided by headquarters officials, the Department of
the Interior's Budget for fiscal years 2000-2003, and House and Senate
committee reports for Department of the Interior appropriations for fiscal
years 2000-2003. We also asked the regional officials who provided these
data a series of data reliability questions covering issues such as data
entry, access, quality control procedures, and the accuracy and
completeness of the data, as well as any limitations of the data. All
responded that the data were generally accurate, and all but one performed
some form of data review to ensure its accuracy. Additionally, officials
from all but one region noted, as a limitation to the data, that it is
sometimes difficult to link expenditures on activities to specific
species. We determined that the expenditure data received from each of the
Service's seven regions were sufficiently reliable for the purposes of
this report.

We also obtained from the Service data on each species' priority number
for fiscal years 2000 through 2003, as well as other information about
each species, such as whether it is threatened or endangered and whether
it has a recovery plan. We did not make a judgment about the adequacy or
accuracy of the Service's recovery priority system. The Service also
provided us with information on the estimated costs to implement
approximately 120 recovery plans. We assessed the reliability of these
data by (1) electronically testing required data elements, (2) reviewing
existing

1Similar data collected by the Service for its fiscal year 2001, 2002, and
2003 expenditure reports became available in January 2005-too late to be
used for most of the analyses in this report.

Appendix I Scope and Methodology

information about the data and the system that produced them, and (3)
interviewing agency officials knowledgeable about the data. In addition,
we compared the data set sent to us by the Service to the Service's
publicly available (online) Threatened and Endangered Species System
(TESS), which contains data on listed species similar to that we received
from the Service. When we identified any difference between these two data
sets, we independently corroborated, to the extent possible, which data
set was correct by obtaining documentary evidence, either from the Federal
Register or the appropriate recovery plan. When appropriate according to
this documentary evidence, we made changes to the data sent to us by the
Service. For example, the spineless hedgehog cactus was listed in the data
set sent to us by the Service but was not found when we compared it to
online TESS. We checked the Federal Register and found that this species
was removed from the endangered species list in 1993, so we removed it
from the data set sent to us by the Service because our time frame of
interest is 2000 through 2003. In another instance, the data set sent to
us by the Service contained the Berkeley kangaroo rat, but this species
was not in TESS. We checked the recovery plan and found that this is a
"species of concern," not an endangered or threatened species. The status
field in the data sent to us by the Service was blank, so we re-coded it
as a species of concern and then removed it from the data set because
species of concern are not part of our review. We also made changes to
records that contained errors. For example, the green sea turtle has two
different populations. However, the Fish and Wildlife Service reported the
total recovery expenditures for these two populations together. When
expenditures were merged with species lists, this expenditure total was
shown twice. To address that error we removed one expenditure total. All
of these types of changes, 5 records with factual errors (or 0.4 percent
of the records) and 9 with missing information (0.7 percent of the
records), were reviewed and agreed to by all team analysts and
supervisors. We also found and removed 14 duplicates and 27 records that
were outside our scope (e.g., outside our date range or species managed by
the National Marine Fisheries Service, not the Fish and Wildlife Service).
On the basis of all of this work, we determined that the data on species
and recovery plans we received from Fish and Wildlife Service were
sufficiently reliable for the purposes of this report.

We then compared the expenditures on each species with the species'
priority ranking for fiscal year 2000 through 2003. We grouped together
species with similar rankings to deemphasize minor differences in species'
rankings. Grouping species this way had the effect of eliminating the

Appendix I Scope and Methodology

taxonomic distinction among species found in the recovery priority
guidelines. Table 5 shows the groupings.

Table 5: GAO Groupings of Priority Numbers

                        GAO group Priority number 1, 1c

GAO group 12, 2c 3, 3c

                                     4, 4c

GAO group 25, 5c 6, 6c

                                     7, 7c

GAO group 38, 8c 9, 9c

                                    10, 10c

GAO group 411, 11c 12, 12c

                                    13, 13c

GAO group 514, 14c 15, 15c

                                    16, 16c

GAO group 617, 17c 18, 18c

Source: GAO.

We also assumed that the average cost to implement recovery plans in each
group was the same. We made this assumption explicitly because the cost to
implement individual recovery plans can vary substantially among species.
For example, we analyzed the cost to implement 120 recovery plans (the
only plans with these data available electronically) covering an estimated
189 species (or 15 percent of listed species) and found that some plans
are very costly-$107,516,000-and some are not-$18,000. However, many plans
fall between these two extremes, costing between $1 million and $6
million. We discussed this assumption with the Service, and they agreed to
its reasonableness.

                        Appendix I Scope and Methodology

The number of species in each priority group varied by year (see table 6).

Table 6: Number of Species in Each Priority Group, by Year Number of species in
                              each priority group

      Priority group       FY 2000       FY 2001      FY 2002         FY 2003 
            1                     395      408          416               415 
            2                     432      436          444               448 
            3                     290      285          286               284 
            4                      47      47            46                47 
            5                      45      46            47                48 
            6                       7       6            6                  6 

Source: GAO analysis of Fish and Wildlife Service data.

In order to analyze overall average spending on a per species bases, we
calculated weighted average expenditures per species by priority ranking.
To do this we weighted the average expenditure per species for a specific
priority group and fiscal year by the proportion: (Number of species in a
particular priority group and fiscal year)/ (Number of species in same
priority group over all fiscal years).

In addressing our second objective, to determine what factors influence
the Service's recovery funding allocation decisions, we interviewed
managers and recovery biologists in the Service's recovery division in
headquarters, all seven regions and a nonprobability sample of 10 field
offices.2 We selected at least one field office from each region and
selected a second field office from the two regions that collectively have
lead responsibility for more than 50 percent of the endangered and
threatened species in the United States. Within each region, we selected
field offices that have lead responsibility for a high number of species
relative to other field offices in that region. The region responsible for
the largest number of species, the Pacific region, is operated as two
divisions, and we selected a field office from each division. The field
office locations in our nonprobability sample were:

2Results from nonprobability samples cannot be used to make inferences
about a population because in a nonprobability sample some elements of the
population being studied have no chance or an unknown chance of being
selected as part of the sample.

Appendix I Scope and Methodology

o  Hawaii (Pacific Region)

o  Sacramento, California (Pacific Region)

o  Arizona (Southwest Region)

o  Columbia, Missouri (Great Lakes Region)

o  Cookeville, Tennessee (Southeast Region)

o  Vero Beach, Florida (Southeast Region)

o  Virginia (Northeast Region)

o  Utah (Mountain-Prairie Region)

o  Anchorage, Alaska (Alaska Region)

o  Fairbanks, Alaska (Alaska Region)

Through our interviews we obtained information on how recovery funds are
allocated, the role of the recovery priority system, and suggested
improvements to the recovery priority system. We compared the answers we
received in these interviews to documents or expenditure data provided by
the Service, to the extent this corroborating evidence was available.

In addressing both objectives, we reviewed publicly available documents
and other information obtained from the Fish and Wildlife Service's
Website. We also reviewed articles in academic and scientific literature
related to recovery planning and recovery prioritization, including an
extensive study of recovery plans conducted by the Society for
Conservation Biology and funded by the Fish and Wildlife Service.

We performed our work from February 2004 to January 2005, in accordance
with generally accepted government auditing standards.

Appendix II

Comments from the Department of the Interior

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

See comment 1.

See comment 2.

Appendix II
Comments from the Department of the
Interior

                                 See comment 3.

                                  Appendix II
                      Comments from the Department of the
                                    Interior

The following are GAO's comments on the Department of the Interior's
letter dated March 11, 2005.

GAO Comments 1.

2.

3.

We agree that some of the recovery funds included in our analysis of how
recovery fund allocations compare with the Service's recovery guidelines
include funds for which Congress has provided direction that they be spent
on particular projects or species. However, we do not believe that by
including these funds we have underestimated the degree to which the
Service's funding decisions are consistent with its recovery priority
guidelines. First, we found that the Service spent its recovery funds in a
manner generally consistent with species priority. Second, we analyzed a
list, provided to us by the Service, of congressionally directed funds and
associated projects for fiscal years 2000 through 2003. We compared this
list with the priority rankings of the species associated with the
projects in a way similar to how we compared species' expenditures and
priority rankings in our report. We found that the list of congressionally
directed funds resulted in a spending pattern similar to what we
identified when we compared species' expenditures and priority rankings in
our report. Thus, by including these funds in our analysis of how recovery
funds allocations compare with the Service's recovery guidelines, we do
not believe that we have underestimated the degree to which the Service's
funding decisions are consistent with its recovery priority guidelines.

We agree that the Endangered Species Act does not require it to report
separately on how it spent its recovery funds by species. However,
reporting this information could be part of an effective strategy to help
ensure that the Service allocates recovery resources consistent with the
priority guidelines over the long term and in a transparent fashion.

In our report, we use the term "imperiled" instead of "threatened" to
avoid confusion with the distinction the act makes between "threatened
species" and "endangered species." We agree that the act does not state
that the purpose for requiring the Service to establish guidelines for
prioritizing the development and implementation of recovery plans was to
address concerns that recovery funds were not being directed at the most
imperiled species. We have modified the report accordingly.

However, we disagree with the Department's contention that its recovery
priority guidelines do not provide that funding should be

Appendix II
Comments from the Department of the
Interior

allocated preferentially to species with the highest priority ranking as
depicted in table 2 of our report. The Department relies on a table in the
guidelines that is virtually identical to table 2 in our report to
describe its priority system. Section 4(h)(4) of the act specifically
directs the Service to establish guidelines that shall include "a system
for developing and implementing, on a priority basis, recovery plans under
subsection (f) of this section." Further, the guidelines state that "the
species with the highest degree of threat have the highest priority for
preparing and implementing recovery plans." In addition, the guidelines
state that they are to "aid in determining how to make the most
appropriate use of resources available to implement the act."

The Department also contends that allocating funding preferentially to
species with the highest priority ranking is contrary to section
4(f)(1)(A) of the act. This provision, which was added in a 1982 amendment
to the act, states that recovery plans shall, to the maximum extent
practicable, give priority to species most likely to benefit from such
plans, particularly those that are, or may be, in conflict with
construction or other development projects, or other forms of economic
activity. The guidelines specifically state that the priority system
established by the guidelines "is intended to satisfy the requirements of
the amended Act." Accordingly, the guidelines include likelihood to
benefit from recovery plans and conflict as factors.

We agree with the Department that focusing on opportunities for
partnerships where multiple parties will work to the benefit of the
species is consistent with section 4(f)(1)(A) of the act. In fact, we
conclude in our report that the Service's ability to be flexible in
allocating its scarce recovery resources is the key to maximizing
contributions from other organizations. However, we believe that this
flexibility needs to occur within the bounds of a systematic and
transparent process and make recommendations to this effect.

Appendix III

                     GAO Contact and Staff Acknowledgments

                    GAO Contact Trish McClure (202) 512-6318

Staff 	In addition to the individual named above, Charles Egan, Jaelith
Hall-Rivera, Barry T. Hill, Summer Pachman, Paula Bonin, Judy Pagano, and

Acknowledgments Cynthia Norris made key contributions to this report.

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