    U.S. Fish and Wildlife Service: Additional Flexibility Needed to
    Deal with Farmlands Received from the Department of Agriculture
    (18-SEP-07, GAO-07-1092).

    Over the past two decades, provisions of the Food Security Act of
    1985, among others, have allowed the Department of Agriculture's
    Farm Service Agency in partnership with the Department of the
    Interior's U.S. Fish and Wildlife Service (Service) to add
    farmlands found to have important resources to the National
    Wildlife Refuge System. The Farm Service Agency transferred such
    farmlands to the Service through outright ownership ("fee
    simple") or through conservation easements. Individual farmlands
    are managed by the nearest refuge office. GAO was asked to
    examine (1) the extent of farmland received by the Service, (2)
    the extent to which the Service is currently managing its
    farmlands, and (3) alternatives for managing these lands. To
    answer these objectives, GAO visited five refuges and surveyed
    managers responsible for a random sample of 98 farmlands.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-07-1092
        ACCNO:   A76389
      TITLE:     U.S. Fish and Wildlife Service: Additional Flexibility
    Needed to Deal with Farmlands Received from the Department of
    Agriculture
         DATE:   09/18/2007
      SUBJECT:   Conservation
    	     Easements
    	     Federal agencies
    	     Federal property management
    	     Land management
    	     Land use
    	     Land use law
    	     Program management
    	     Public lands
    	     Wildlife
    	     Wildlife conservation
    	     Interagency relations
    	     Records management
    	     Farmland
    	     National Wildlife Refuge System

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    GAO-07-1092

         * [1]Results in Brief
         * [2]Background
         * [3]The Service Has Received at Least 1,400 Farmlands Covering 1

              * [4]Since 1986, the Service Has Received Mostly Small Farmlands
              * [5]The Service's Farmland Records Are Incomplete

         * [6]The Service Is Generally Not Managing the Majority of Its Fa

              * [7]The Service Performs Limited to No Management Activities on
              * [8]Several Factors Affect the Extent of the Service's Managemen
              * [9]Farmlands That Align Closely with Refuges' Goals Receive Mor

         * [10]The Service Has Limited Alternatives for Managing Its Farmla
         * [11]Conclusions
         * [12]Recommendations for Executive Action
         * [13]Agency Comments
         * [14]Appendix I: Scope and Methodology
         * [15]Appendix II: Survey of the U.S. Fish and Wildlife Service's
         * [16]Appendix III: Comments from the Department of the Interior
         * [17]Appendix IV: GAO Contact and Staff Acknowledgments

              * [18]GAO Contact
              * [19]Staff Acknowledgments

                   * [20]Order by Mail or Phone

    Report to the Subcommittee on Interior, Environment, and Related Agencies,
    Committee on Appropriations, House of Representatives

    United States Government Accountability Office

    GAO

    September 2007

    U.S. FISH AND WILDLIFE SERVICE

    Additional Flexibility Needed to Deal with Farmlands Received from the
    Department of Agriculture

    GAO-07-1092

    Contents

    Letter 1

    Results in Brief 6
    Background 9
    The Service Has Received at Least 1,400 Farmlands Covering 132,000 Acres,
    but the Actual Number Is Unknown 15
    The Service Is Generally Not Managing the Majority of Its Farmlands 20
    The Service Has Limited Alternatives for Managing Its Farmlands 30
    Conclusions 35
    Recommendations for Executive Action 36
    Agency Comments 37
    Appendix I Scope and Methodology 38
    Appendix II Survey of the U.S. Fish and Wildlife Service's Farmland
    Management 40
    Appendix III Comments from the Department of the Interior 49
    Appendix IV GAO Contact and Staff Acknowledgments 51

    Tables

    Table 1: Executive Orders and Legislation Relevant to the Farm Service
    Agency's Inventory Program 13
    Table 2: Size of Farmlands Received by the Service 16
    Table 3: Estimated Travel Times between the Managing Refuge Offices and
    Their Farmlands 27
    Table 4: Selected Survey Questions 42
    Table 5: Numbers and Percentages of Properties Inspected and Not Inspected
    in the Past 2 Years, by Size, Distance, and Number of Properties, and Odds
    and Odds Ratios Derived from Them 44
    Table 6: Confidence Intervals Associated with the Estimated Percentage of
    Properties Inspected, by Size, Distance, and Number of Properties 46

    Figures

    Figure 1: U.S. Fish and Wildlife Service Regions 11
    Figure 2: Example of an Easement Placed on Farm Property 15
    Figure 3: Concentration of Service Farmlands by State 17
    Figure 4: Number of Farmlands Received by the Service, by Calendar Year 19
    Figure 5: Estimated Frequency of Inspections from Calendar Year 2002
    through 2006 22
    Figure 6: Farming Activities in Violation of a Wetland Easement, April
    2007 23
    Figure 7: Location of the Farmlands That Michigan's Shiawassee National
    Wildlife Refuge Is Responsible for Managing 26
    Figure 8: Old Farmhouse in New York, Renovated to Serve as a Refuge
    Office, April 2007 30

    This is a work of the U.S. government and is not subject to copyright
    protection in the United States. The published product 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.

    United States Government Accountability Office
    Washington, DC 20548

    September 18, 2007

    The Honorable Norman D. Dicks
    Chairman
    The Honorable Todd Tiahrt
    Ranking Member
    Subcommittee on Interior, Environment, and Related Agencies
    Committee on Appropriations
    House of Representatives

    Since the early 1900s, public lands have been set aside to protect natural
    ecosystems, provide habitat for wildlife, and offer Americans recreational
    opportunities. In the mid-1960s, Congress consolidated many of these lands
    into the National Wildlife Refuge System, a vast, ecologically diverse and
    valuable network of lands administered by the Department of the Interior's
    U.S. Fish and Wildlife Service (Service). Today, this system comprises 548
    wildlife refuges covering 96 million acres, of which more than 17 million
    acres are located in the continental United States.^1 The mission of the
    refuge system is to "administer a national network of lands and waters for
    the conservation, management, and where appropriate, restoration of the
    fish, wildlife, and plant resources and their habitats within the United
    States for the benefit of present and future generations of Americans."^2
    The system includes land that has always been federally owned, as well as
    land that has been acquired from other parties, including state
    governments and private entities.

    Through the Food Security Act of 1985 (Farm Bill) and subsequent
    legislation, some land was added to the refuge system through a
    partnership with the Department of Agriculture's Farm Service Agency.^3
    This agency was established in part to provide loans to farmers who were
    otherwise unable to secure enough funding to operate their farms. If a
    farmer was unable to repay such a loan, however, the Farm Service Agency
    sometimes foreclosed on the loan and acquired the farm property.
    Properties thus acquired went into the Farm Service Agency's inventory,
    with the goal that they would eventually be sold back into private
    ownership. Because of a distressed farm economy at the time, the Farm
    Service Agency had over a million acres of inventory properties when the
    1985 Farm Bill became law. Provisions of the Farm Bill and subsequent
    legislation authorized the Farm Service Agency to acquire land or
    interests in land for conservation purposes. Under these authorities, the
    Farm Service Agency placed conservation protections on its inventory
    properties that contained important resources, which it defined as
    wetlands, riparian zones,^4 floodplains, coastal barriers, and other areas
    of high ecological quality or important fish and wildlife habitat. In
    carrying out these authorities, the Farm Service Agency generally
    consulted with the Service to determine, among other things, which
    properties should be protected. A memorandum of understanding signed in
    1987 implements this and other environmental management responsibilities
    of the two agencies. Given the significant number of inventory properties
    in the mid-1980s, the Service reviewed thousands of these properties over
    the following decade and if important resources were identified on any
    portion of a property, the Service recommended that the Farm Service
    Agency protect that portion.

    ^1Refuge lands in Alaska account for almost 77 million acres, and more
    than 2 million acres are spread across American Samoa, Guam, Hawaii,
    Puerto Rico, the U.S. Virgin Islands, and minor outlying islands of the
    United States.

    ^2The National Wildlife Refuge System Improvement Act of 1997, Pub. L. No.
    105-57, 111 Stat. 1254 (1997), codified at 16 U.S.C. S 668dd(a)(2).

    The Service recommended placement of conservation protections on certain
    lands, but the Farm Service Agency made the final decision, often
    negotiating with the Service on the specific number and location of acres
    on a property that would be protected. Such protections usually consisted
    of placing a perpetual easement on the property before selling it back
    into private ownership or, in certain cases, transferring outright
    ownership in fee simple to another federal or state agency, although
    preference was given to the Service. An easement is a nonpossessory
    interest in land. With an easement, the original landowner retains
    possession of the land, but, depending on which resources are being
    protected, the easement places restrictions on the land's use. All of the
    easements prohibit landowners from further developing the land subject to
    the easement, and many do not allow any agricultural activities or
    alteration of the habitat. Not all of the properties that the Service
    recommended for protection were of equivalent ecological value, however.
    In some cases, for example, the Service recommended protecting a site
    whose soil or other characteristics indicated that it once was or could
    again become a wetland, even if the site was no longer a wetland at the
    time because of alteration of the habitat from farming practices, such as
    draining or leveling the land. In addition, the 1990 and 1996 Farm Bills
    restricted the agency's authority to establish easements under the
    program.^5

    ^3Food Security Act of 1985, Pub. L. No. 99-198, title XIII, S 1318(a), 99
    Stat. 1354, 1530-1 (1985); Agricultural Credit Act of 1987, Pub. L. No.
    100-233, title VI, SS 612 and 616, 101 Stat. 1568, 1674 and 1682 (1988);
    Food, Agriculture, Conservation, and Trade Act of 1990, Pub. L. No.
    101-624, title XVIII, subtitle A, SS 1813(h) and 1815; and title XXIII, S
    2388(j), 104 Stat. 3359, 3823-4, 3825-6, 4053 (1990); and Federal
    Agriculture Improvement and Reform Act of 1996, Pub. L. No. 104-127, title
    VI, subtitle D, SS 639, 642, and 646, 110 Stat. 888, 1097, 1102-4 (1996).

    ^4A riparian zone is the bank or corridor adjacent to rivers, streams, or
    other water bodies. A vegetated riparian zone can act as a protective
    buffer between land and water.

    In addition to helping the Farm Service Agency assess inventory properties
    for important resources, in most instances the Service agreed to serve as
    the manager of the easement properties. Other federal or state agencies
    and private nonprofit organizations could also assume this duty,^6 but the
    Farm Service Agency gave priority to the Service. Moreover, Service policy
    held that it would become the easement manager of farmlands^7 it had
    recommended for protection, unless another federal or state easement
    manager had been identified. It was not uncommon for a federal or state
    agency, including the U.S. Forest Service, Bureau of Land Management, or a
    state land management agency, to receive fee-simple lands or easement
    management responsibilities, although the majority of the farmlands were
    accepted by the Service. All farmlands received by the Service from the
    Farm Service Agency--whether through an easement or fee-simple
    ownership--were to be administered as part of the National Wildlife Refuge
    System, with management responsibility for each farmland generally falling
    to the nearest refuge office. Service guidance stipulates that refuge
    offices are responsible for management activities, including regularly
    inspecting farmlands to check for violations, determining whether
    landowners are complying with all the easement restrictions, and taking
    enforcement actions on violations. Because the lands, or the interests in
    the lands, are government property, the Service may take civil or criminal
    action against violators for the "destruction" of government property.^8
    Refuge offices are also responsible for maintaining contact with
    landowners, particularly new landowners; conducting maintenance, including
    marking easement boundaries and sometimes installing or maintaining
    fencing; and in some cases doing ecological restoration, such as restoring
    wetlands.

    ^5Food, Agriculture, Conservation, and Trade Act of 1990, Pub. L. No.
    101-624, title XVIII, subtitle A, S 1813(h)(2)-(3), 104 Stat. 3359, 3823
    (1990); Federal Agriculture Improvement and Reform Act of 1996, Pub. L.
    No. 104-127, title VI, subtitle D, S 639, 110 Stat. 888, 1097 (1996).

    ^6See the Food Security Act of 1985, Pub. L. No. 99-198, title XIII, S
    1314(a)(2)(B), 99 Stat. 1354, 1526-7 (1985), for the authority regarding
    private nonprofit organizations.

    ^7For the purposes of this report, we use the term "farmland" to mean the
    property interests and ownership in properties the Service received from
    the Farm Service Agency. We recognize that some of these properties are no
    longer used for farming.

    After enactment of the 1985 Farm Bill, the Service accepted management
    responsibilities for farmlands that were sometimes situated miles from the
    nearest refuge and others that, after years of being farmed, were
    ecologically degraded. From the outset, some refuge offices had concerns
    about receiving certain farmlands. Refuge officials were often not
    involved in the initial assessment of the inventory properties or in the
    decision to accept management responsibility as part of the refuge system.
    Particularly in cases where the farmlands were widely scattered or a long
    way from the nearest refuge office, refuge officials were concerned
    because of the potential costs of managing such far-flung parcels. Service
    policy, however, held that the relative size of a farmland or its
    proximity to an existing refuge should not be an overriding consideration
    in recommending a property for an easement or fee-simple acquisition;
    rather, according to a memorandum from the Director of the Service in
    1988, the Service should make every effort to protect all lands identified
    as having important resources, regardless of acreage. In addition, some
    procedural and coordination problems between the two agencies were never
    fully resolved. For example, the Service was not always notified of the
    Farm Service Agency's final decision on its recommendations for
    protection, and in some cases it was several years after a recommendation
    was made that the property was removed from inventory and an easement
    placed on the land. Also, in many cases the Farm Service Agency did not
    legally survey the land to outline precise boundaries.

    ^816 U.S.C. S 668dd(c) states that "no person shall disturb, injure, cut,
    burn, remove, destroy, or possess any real or personal property of the
    United States, including natural growth, in any area of the System . . .
    unless such activities are performed by persons authorized to manage such
    area, or unless such activities are permitted . . . by express provision
    of the law, proclamation, Executive order, or public land order
    establishing the area, or amendment thereof." 18 U.S.C. S 41 states that
    "whoever . . . willfully injures, molests, or destroys any property of the
    United States on any [refuge] lands or waters shall be fined under this
    title or imprisoned not more than six months, or both."

    In contrast, in the Prairie Pothole Region of the United States, which
    comprises portions of the states of Iowa, Minnesota, Montana, North
    Dakota, and South Dakota, farmlands received from the Farm Service Agency
    have been managed much like other easements the Service has acquired
    there. The Service has had a long-standing easement program in this region
    to protect wetlands and grasslands for the benefit of migratory waterfowl.
    It has run a regular program to manage all of its easement acquisitions in
    the region, including farmlands received from the Farm Service Agency,
    largely through routine aerial surveillance and on-the-ground inspections
    of suspected violations. Today the Service has more than 28,000 perpetual
    easements in the Prairie Pothole Region, covering more than 2.3 million
    acres, including more than 68,000 acres of easements from the Farm Service
    Agency. Because of the unique nature of this program, we excluded the
    farmlands found in the Prairie Pothole Region from our review. Concurrent
    with this report, we are reporting separately on the Service's land
    acquisitions in this region.

    For this report, outside of the Prairie Pothole Region, we examined (1)
    the extent of farmland received by the Service from the Farm Service
    Agency, (2) the extent to which the Service is currently managing its
    farmlands, and (3) alternatives for managing these lands.

    To address the objectives of this report, we visited and collected
    documentation from five refuges located in five different regions. We also
    interviewed officials at and collected documentation from the Service's
    headquarters and eight regional offices, as well as the Farm Service
    Agency's headquarters and four of its state offices. Additionally, we drew
    a random sample of 98 farmlands, obtained from a list provided by the
    Service, and conducted a telephone survey with the 51 refuge office
    managers responsible for these lands about the management activities they
    have undertaken on the lands during the years 2002 through 2006. We
    received responses from 100 percent of our sample, and the results can be
    projected to the population of documented farmlands, with an overall
    margin of error of +-10 percentage points at the 95 percent confidence
    level unless otherwise noted. Specifically, to determine the extent of the
    Service's acquisition of farmlands, we obtained and reviewed property
    records from the Service's headquarters and regional offices and the
    refuge offices that we visited. We assessed the reliability of the data
    and found it to be sufficiently reliable for the purposes of this report.
    We were informed by some regional realty officials, however, that the
    database was probably incomplete. Consequently, we contacted each regional
    office to determine if the offices maintained additional farmland records
    outside of the centralized database. Three Service regions provided us
    with additional farmland records that were not contained in the database.
    To determine the extent to which the Service is currently managing its
    farmlands, we reviewed relevant agency guidance for managing easement and
    fee-simple lands. Through our site visits and survey, we collected
    information on the Service's management activities, including information
    on inspections, enforcement, contacts with landowners, maintenance, and
    restoration, and on factors affecting their management of farmlands.
    Finally, to determine alternatives for managing these lands, we examined
    the Service's management challenges and discussed them with Department of
    the Interior officials, including officials from the Service's Realty and
    Refuge Offices, and the Department of the Interior's Office of the
    Solicitor. We performed our work from September 2006 through July 2007 in
    accordance with generally accepted government auditing standards.
    Appendixes I and II present a more detailed discussion of our scope and
    methodology.

    Results in Brief

    The Service's records indicate that it has received at least 1,400
    easement and fee-simple farmlands from the Farm Service Agency since 1986,
    but the actual number is unknown because the Service's farmland records
    are incomplete. According to the Service's records, the farmlands are
    scattered across 38 states and range in size from less than 1 acre to more
    than 2,200 acres, although most are smaller than 50 acres. The majority of
    the lands were acquired between 1986 and the mid-1990s; acquisitions over
    the past 10 years have been minimal. The Service is responsible for
    managing more than 132,000 farmland acres, of which about half are
    included in the Service's centralized land records database. We learned of
    the remaining half from three regional offices, because the lands had not
    been entered into this centralized database. Roughly 90 percent of the
    lands have easements on them, and about 10 percent are owned in fee
    simple. Most of the lands were received to protect wetlands, but some were
    meant to protect other resources, including floodplains or specific
    wildlife habitats. In addition, we identified farmlands that were not in
    the Service's database or reported to us by the regional offices, and we
    therefore conclude that the figures we report represent a conservative
    estimate of the total farmland acreage received from the Farm Service
    Agency. Specifically, at several refuges we visited, we found that the
    refuge office kept files on additional easement farmlands. At one of the
    refuges we visited, for example, we identified 5 additional easements and
    another 31 potential, or unconfirmed, easements. Moreover, in some
    instances, because of incomplete records, the Service may be unaware of
    certain farmlands that it is in fact responsible for managing. For
    example, in one region, a realty official told us that a landowner
    recently called the Service with concerns about an easement on his land,
    but the Service was unaware of the easement because no record of it
    existed with the Service. After reviewing records at the county courthouse
    in which the land was located, the official was able to confirm that an
    easement had indeed been placed on the land.

    The Service is generally not managing the majority of the farmlands it
    received from the Farm Service Agency. Specifically, it has inspected only
    an estimated 13 percent of its farmlands annually, on average, over the
    last 5 years and, as a result, may be unaware of violations and unable to
    ensure compliance with the restrictions on its easement lands. At four of
    the five refuges we visited, we observed violations on at least one of the
    refuge's easement lands, such as farming encroachment, grazing, or removal
    of vegetation. Few refuge offices have tracked changes in land ownership
    to ensure that new landowners are aware of easements, and very little
    maintenance or restoration work has been completed on the farmlands.
    Often, not even basic maintenance, such as maintaining fencing, has been
    completed; yet when easement restrictions prohibit activities such as
    grazing, fencing may be critical to ensure cattle do not enter and graze
    the area. We found that the Service's management activities on its
    farmlands are hindered by the following several factors:

               o First, devoting significant management attention to many of the
               farmlands has not been emphasized by the refuge offices. Refuge
               officials do not believe that these lands contribute significantly
               to the refuges' goals or mission, largely because the farmlands
               are too small, isolated, or located great distances from the
               managing refuge office. For example, over 75 percent of the
               farmlands are smaller than 100 acres. Several refuge managers
               commented that they would consider 100 acres the minimum size
               needed to support ecological viability, especially given the
               lands' often isolated nature. Additionally, 83 percent of the
               farmlands are located an hour or more away from their respective
               refuges, making it difficult for managers to visit them. Because
               managing the farmlands has not been a high priority, the lands may
               not be achieving the conservation purpose for which they were
               acquired.
               o Second, management of easement lands may be difficult because of
               uncertainty surrounding the scope and extent of the easements. For
               example, boundaries are not clear to many refuge managers because
               detailed surveys were not done when the easements were established
               on these lands. When easement boundaries are not well defined,
               refuge managers may not be able to determine if a violation is
               occurring on the land.
               o Third, the Service is operating with constrained resources and
               declining refuge staff, and therefore the staff are not able to
               complete all the activities they believe are necessary to manage
               the farmlands. Over the past several years, refuge staff have been
               reduced significantly, and the Service plans to further reduce the
               refuges' workforce in the next 3 years under current
               workforce-planning efforts aimed at cutting expenses. For an
               estimated 88 percent of farmlands, the responsible refuge managers
               believe that they have not had enough resources over the past 5
               years to manage their farmlands.

    While the Service is generally not managing the majority of its farmlands,
    in some instances we identified farmlands to which the refuges are
    devoting resources and paying a significant amount of management
    attention, largely because the lands more closely align with the refuges'
    goals. For example, we visited one easement land that provided an
    important connection between the refuge boundary and a critical river
    running through the area, and the refuge had completed extensive
    restoration work.

    The Service possesses limited alternatives for managing the farmlands it
    has received from the Farm Service Agency because the lands became part of
    the National Wildlife Refuge System. The alternatives the Service has had
    at its disposal generally include (1) resetting refuge priorities to
    ensure that farmlands are given management attention, (2) requesting
    additional resources, and (3) paying little or no management attention to
    the farmlands. Over the past 20 years, in the rare instances where
    farmlands significantly contributed to the refuges' goals and mission,
    individual refuges made them a priority and obtained the necessary
    resources to manage them. These well-managed farmlands have been the
    exception rather than the rule, however. The majority of the farmlands are
    neglected because they do not contribute significantly to the goals of the
    refuges or because they are costly to manage relative to their real or
    perceived ecological value. On these lands, the Service is not meeting its
    management responsibilities and, in some cases, may be permitting the
    destruction of government property. Although some of these farmlands may
    have little or no value to the Service, they are now subject to the
    National Wildlife Refuge System's restrictions on land disposal, so the
    Service generally cannot dispose of unwanted farmlands. Other federal land
    management agencies have authorities that give them more flexibility in
    managing their lands, which could serve as models for legislation
    providing similar authority to the Service on a limited or short-term
    basis to resolve the issue of unwanted farmlands. For example, the
    Department of Agriculture's Forest Service has the authority to sell
    certain small, isolated, low-market-value parcels of its landholdings
    under specific conditions.

    To ensure that the Service is able to provide an accurate accounting of
    its farmlands and has an accurate assessment of its overall farmland
    management responsibilities, we are recommending that the Secretary of the
    Interior direct the Director of the U.S. Fish and Wildlife Service to take
    the necessary steps to ensure that the Service's records of its farmlands
    are accurate and complete. In addition, we are recommending that the
    Service develop a proposal to Congress seeking authority for additional
    flexibility to deal with farmlands that it deems not in the best interest
    to continue to include as part of the National Wildlife Refuge System.
    Factors affecting how significantly individual farmlands contribute to the
    mission of the refuge system, along with current and long-term management
    costs, will be important considerations for determining which farmlands
    may not be in the best long-term interest of the system. Once such
    considerations are weighed, the Service can determine an appropriate
    proposal for congressional consideration. Since it could take years for
    the Service to develop a proposal and have the proposal acted on by
    Congress, as well as for the Service to exercise any new authority that
    may be provided, we are not making a recommendation at this time
    concerning the current level of management occurring on its farmlands.
    Nevertheless, we believe that the Service should be mindful of ensuring a
    minimum level of management attention to the farmlands it ultimately
    retains. In commenting on a draft of this report, the Department of the
    Interior concurred with our recommendations and provided several technical
    clarifications, which we have made as appropriate. Appendix III presents
    the Department of the Interior's comment letter. The Department of
    Agriculture did not provide comments.

    Background

    The National Wildlife Refuge System provides habitat for more than 5,000
    species of birds, mammals, and fish, and these refuges protect unique
    wildlife habitats and species. Under the National Wildlife Refuge System
    Administration Act of 1966, as amended, the Service is responsible for
    managing each refuge to fulfill the mission of the system as a whole, as
    well as to fulfill the specific purposes for which the individual refuge
    was established.^9 Therefore, refuges often have additional conservation
    goals tailored to a specific purpose, such as protecting the habitat of
    particular endangered or threatened species. Individual refuges may
    consist of contiguous tracts of land--ranging from less than 1 acre to
    more than 19 million acres--or separate tracts of land scattered over one
    or more states. Each refuge may encompass land that is (1) completely
    federally owned; (2) primarily federally owned, with isolated tracts of
    nonfederal land; or (3) in a few refuges, primarily nonfederally owned,
    with isolated tracts of federal land. Each refuge is managed by a refuge
    manager and other refuge staff, including biologists, law enforcement
    officers, and other specialized staff.^10 One of the Service's eight
    regional offices oversees the activities of each refuge;^11 each region
    reports to Service headquarters in Washington, D.C. (see fig. 1).

    ^916 U.S.C. S 668dd(a).

    ^10Some refuges are managed as refuge complexes, where a group of refuges
    in geographic proximity and with similar purposes are managed by one set
    of refuge staff.

    ^11In this report, we refer to the California-Nevada Office as a regional
    office (region 8).

    Figure 1: U.S. Fish and Wildlife Service Regions

    The Service has a process for adding lands to the refuge system: it may
    acquire land by purchasing the land itself or purchasing interests in the
    land, by accepting donations of land from nonfederal entities, by
    accepting land transfers from other federal agencies, or by requesting a
    transfer of land from the public domain into the refuge system.^12 The
    Service can also exchange tracts of land with nonfederal entities, such as
    state agencies or private landowners, although the tracts of land must be
    comparably valued. With few exceptions, all lands that become part of the
    refuge system continue to be included in the system until otherwise
    specified by an act of Congress.^13 Typically, when evaluating lands for
    inclusion in the refuge system, the Service conducts an assessment of the
    land, which includes an in-depth biological evaluation and opportunities
    for public participation and also requires approval by the Service
    Director or one of the regional directors. The Service keeps an inventory
    of acquired lands, or interests in lands, in a centralized database
    maintained by realty offices in Service headquarters and regions.

    ^12Public domain means that the title to the land has always remained with
    the federal government. Almost 90 percent of the lands in the refuge
    system came from the public domain.

    ^1316 U.S.C. SS 668dd(a).

    The Service has also added lands to the refuge system through the
    partnership it developed with the U.S. Department of Agriculture's Farm
    Service Agency to help it implement provisions of the 1985 Farm Bill and
    subsequent legislation. Even before the 1985 Farm Bill was passed, the
    Farm Service Agency had an affirmative responsibility to protect any of
    its inventory properties that had wetland or floodplain values. Two
    executive orders issued in 1977 called on all federal agencies to minimize
    the destruction, loss, or degradation of wetlands and to restore and
    preserve the natural and beneficial values supported by floodplains.^14 In
    carrying out their responsibilities, including acquiring, managing, and
    disposing of federal lands, federal agencies were to preserve and enhance
    the natural and beneficial values of wetlands.^15 The 1985 Farm Bill and
    subsequent legislation provided the Farm Service Agency the authority to
    protect any of its land that contained wetlands and floodplains, in
    addition to other important resources. Specifically, the Farm Service
    Agency had the authority to place perpetual conservation easements on
    inventory properties that contained important resources or to transfer
    lands in fee simple to other entities, such as federal, state, or local
    government agencies.^16 Since the 1985 Farm Bill was enacted, subsequent
    legislation substantially changed the amount and type of lands available
    for protection. Notably, the 1990 and 1996 Farm Bills restricted the
    agency's authority to establish easements under the program. For example,
    the 1990 Farm Bill limited authorized easements on certain parcels of
    lands to no more than 20 percent of the parcel available for agricultural
    production. The 1996 Farm Bill removed these restrictions but imposed
    strict procedural requirements for establishing an easement. Table 1
    summarizes the major executive orders and legislation affecting the
    protection of farmlands.

    ^14Executive Order 11990, Protection of Wetlands, and Executive Order
    11988, Floodplain Management, both issued on May 24, 1977.

    ^15Executive Order 11990 also directs the executive branch agencies "to
    avoid to the extent possible the long- and short-term adverse impacts
    associated with the destruction or modification of wetlands and to avoid
    direct or indirect support of new construction in wetlands wherever there
    is a practicable alternative."

    ^16The 1985 Farm Bill also authorized the Farm Service Agency to develop
    the Debt for Nature Program. This program allows the Farm Service Agency
    to cancel a portion of delinquent borrowers' debt in exchange for the
    borrowers' voluntarily establishing conservation easements on their lands.

    Table 1: Executive Orders and Legislation Relevant to the Farm Service
    Agency's Inventory Program

    Executive orders and
    legislation           Date         Major provisions
    Executive Order 11988 May 24, 1977 Ordered federal agencies, in carrying
    on Floodplain                      out their responsibilities, to "take
    Management^a                       action to reduce the risk of flood
                                          loss; to minimize the impact of floods
                                          on human safety, health, and welfare;
                                          and to restore and preserve the natural
                                          and beneficial values served by
                                          floodplains."
    Executive Order 11990 May 24, 1977 Ordered federal agencies, in carrying
    on Protection of                   out their responsibilities, to "take
    Wetlands^b                         action to minimize the destruction,
                                          loss, or degradation of wetlands, and
                                          to preserve and enhance the natural and
                                          beneficial values of wetlands."
    Food Security Act of  Dec. 23,     Authorized the Secretary of Agriculture
    1985 (1985 Farm       1985         to acquire easements in real property
    Bill)^c                            for conservation, recreational, and
                                          wildlife purposes as part of farm loan
                                          debt restructuring. A portion of a
                                          farmer's outstanding farm loan(s) was
                                          canceled when an easement was acquired
                                          by the United States. The Secretary, or
                                          any person or federal, state, or local
                                          governmental entity, could be
                                          designated as the party responsible for
                                          enforcing the easement. The act also
                                          authorized the Secretary to grant or
                                          sell an easement, restriction,
                                          development rights, or equivalent
                                          thereof to a unit of local or state
                                          government or to a private nonprofit
                                          organization for conservation purposes.
    Agricultural Credit   Jan. 6, 1988 Authorized the Secretary of
    Act of 1987^d                      Agriculture, under certain
                                          circumstances, to transfer without
                                          reimbursement to any federal or state
                                          agency for conservation purposes any
                                          real property or interest in real
                                          property (i.e., an easement).
    Food, Agriculture,    Nov. 28,     Imposed a number of restrictions on the
    Conservation, and     1990         Secretary of Agriculture when
    Trade Act of 1990                  establishing perpetual wetland
    (1990 Farm Bill)^e                 conservation easements. In establishing
                                          easements, the Secretary was directed
                                          to "avoid, to the extent practicable,
                                          an adverse impact on the productivity
                                          of the croplands." For example, in
                                          certain cases, easement acreage was
                                          limited to 10 or 20 percent of the
                                          existing cropland, and the buffer area
                                          adjacent to a wetland was generally not
                                          to exceed 100 feet in average width.
    Federal Agriculture   Apr. 4, 1996 Modified the restrictions added by the
    Improvement and                    1990 Farm Bill and imposed new
    Reform Act of 1996                 procedural requirements for the
    (1996 Farm Bill)^f                 transfer authority authorized by the
                                          Agricultural Credit Act of 1987. The
                                          limitations on percentage of acreage in
                                          the 1990 Farm Bill were replaced with
                                          the limitation that the Secretary of
                                          Agriculture should not establish a
                                          wetland conservation easement on an
                                          inventoried property that was cropland
                                          on the date the property entered
                                          inventory or was used for farming at
                                          any time within 5 years of entering
                                          inventory. The new procedural
                                          requirements on the transfer authority
                                          included public notices; consultations
                                          with the applicable governor and at
                                          least one elected county official; and
                                          the possibility of at least one public
                                          meeting, if requested.

    Source: GAO analysis of executive orders and legislation.

    Note: The provisions for the Farm Service Agency's farmlands easement
    programs are codified at 7 U.S.C. SS 1985(g), 1997, and 2002.

    a42 Fed. Reg. 26951, May 25, 1977.

    b42 Fed. Reg. 26961, May 25, 1977.

    cPub. L. No. 99-198, title XIII, SS 1314(a)(2)(B) and 1318(a), 99 Stat.
    1354, 1530-1 (1985).

    dPub. L. No. 100-233, title VI, SS 612 and 616, 101 Stat. 1568, 1674 and
    1682 (1988).

    ePub. L. No. 101-624, title XVIII, subtitle A, SS 1813(h) and 1815, and
    title XXIII, S 2388(j), 104 Stat. 3359, 3823-4, 3825-6, and 4053 (1990).

    fPub. L. No. 104-127, title VI, subtitle D, SS 639, 642, and 646, 110
    Stat. 888, 1097, 1102, and 1103-4, (1996).

    In establishing easements, the Farm Service Agency generally used
    boilerplate language that it developed in coordination with the Service.
    Largely, it placed very restrictive easements on those portions of the
    property that contained important resources. Easement restrictions
    prevented the landowner from developing the land, conducting agricultural
    practices, altering the vegetation or hydrology of the land in any way, or
    otherwise disturbing the land. In some cases, if the purpose of the
    easement was to protect a floodplain, then less-restrictive easement
    language was used. On these easements, most agricultural practices were
    allowed, and the landowner was restricted primarily from developing the
    land.

    In delineating easement boundaries on a property, the Farm Service Agency
    generally established easement areas embedded within noneasement farmland
    because the agency was protecting only those portions of the property
    encompassing important resources. For example, on a 150-acre farm, an
    easement might have protected only the 23 acres that constituted a buffer
    to a stream running through the property. Or if several wetlands were
    identified on a 320-acre field, only those wetlands, possibly along with a
    buffer, might have received protection, while the remainder of the field
    could still have been farmed (see fig. 2). As a result, easement areas
    might consist of multiple, noncontiguous parcels on the larger farm
    property.

    Figure 2: Example of an Easement Placed on Farm Property

    The Service Has Received at Least 1,400 Farmlands Covering 132,000 Acres, but
    the Actual Number Is Unknown

    The Service's records indicate that it has received at least 1,400
    easement and fee-simple farmlands from the Farm Service Agency since 1986,
    but the actual number is unknown. According to its records, the Service is
    responsible for managing over 132,000 acres of mostly small farmlands
    scattered across 38 states. In addition, we identified farmlands besides
    those in the Service's centralized database or reported to us by the
    regional offices. Consequently, we conclude that the figures we report
    represent a conservative estimate for the total amount of the Service's
    farmlands.

    Since 1986, the Service Has Received Mostly Small Farmlands Scattered across 38
    States

    According to its records, the Service has received at least 1,400
    farmlands from the Farm Service Agency.^17 About 90 percent of the lands
    are privately owned, with easements on them; the Service owns the
    remaining 10 percent in fee simple. The farmlands cover more than 132,000
    acres and range in size from less than 1 acre to more than 2,200 acres.
    Most of the farmlands, however, are small. Specifically, more than half
    the farmlands are smaller than 50 acres, and only about 1 percent are
    larger than 1,000 acres (see table 2).

    Table 2: Size of Farmlands Received by the Service

    Size in acres Number Percentage
                        197        14%
    10-49            606         43
    50-99            301         21
    100-999          292         21
    1,000+            16          1
    Total          1,412       100%

    Source: GAO analysis of U.S. Fish and Wildlife Service data.

    Farmlands owned by the Service in fee simple are generally larger than
    farmlands with easements. While more than 60 percent of its fee-simple
    lands are larger than 100 acres, less than 20 percent of the easement
    lands exceed 100 acres. Accordingly, in terms of acreage, the Service owns
    about 37,000 acres (28 percent) of its farmlands in fee simple, and nearly
    95,000 acres (72 percent) are in the form of easements. The Service's
    farmlands are scattered across more than 500 counties in 38 states within
    the continental United States, with the highest concentration of farmlands
    located in the Midwest (see fig. 3).^18

    ^17In most cases, the number of farmlands represents the original number of
    properties the Service received from the Farm Service Agency, either
    through fee simple or an easement. That is, each farmland corresponds to a
    legal deed placed on all or a portion of a property that was under single
    ownership at the time the realty transaction was legally finalized. In
    some instances, however, easement restrictions that were placed on
    separate portions of a single property may have been tracked separately,
    and thus the lands would be counted separately here even though they were
    under single ownership at the time of the realty transaction. In addition,
    if an owner subsequently sold a portion of a property covered by the
    easement, both ownerships would still be covered by the easement
    restrictions. In other words, through land sales, one easement land with
    one landowner could turn into two or more easement lands, with two or more
    landowners. These types of changes would not be reflected in the numbers
    reported here, however.

    Figure 3: Concentration of Service Farmlands by State

    The most common purpose for establishing easements or accepting fee-simple
    ownership was to protect wetlands. Specifically, the results of our survey
    show that about 80 percent of the farmlands were received to protect
    wetlands. Farmlands were also received for other conservation purposes,
    such as protection of riparian zones; floodplains; or the habitats of
    endangered or threatened species, including the bald eagle and San Joaquin
    kit fox.^19

    ^18The Service manages more than 650 additional farmlands--more than 68,000
    acres in easements and 7,000 acres in fee simple--within the Prairie
    Pothole Region of the United States. These farmlands are not included
    within the scope of this review.

    The majority of the farmlands were acquired between 1986 and the
    mid-1990s; acquisitions over the past 10 years have been minimal (see fig.
    4). According to Farm Service Agency officials, acquisitions have declined
    because significantly fewer farm properties have entered the Farm Service
    Agency's inventory since the mid-1990s. This is largely a result of the
    improving farm economy and additional financing options farmers now have
    besides loan foreclosure, according to the officials. Also, the
    restrictions included in the 1990 and 1996 Farm Bills significantly
    reduced the type of inventory farmlands available for protection.

    ^19Effective August 8, 2007, the bald eagle was removed from the federal
    list of endangered and threatened wildlife.

    Figure 4: Number of Farmlands Received by the Service, by Calendar Year

    Note: We were unable to obtain an acquisition date for four farmland
    records and therefore did not include those farmlands in this analysis.
    Also, the years graphed here represent the year that an easement was
    placed on a farmland or the land was transferred to the Service in fee
    simple, which in many instances occurred several years after the Service
    reviewed the property and made a recommendation for protection. For
    example, one of the properties received in 2004 was initially placed in
    the Farm Service Agency's inventory in 1994, but it took 10 years to
    remove the land from inventory and formally place an easement it.

    About half the farmlands reported here are included in the Service's
    centralized database. We learned about the remaining half of the farmlands
    from three regional realty offices. These regions, for various
    administrative reasons, have not entered their records into the database,
    according to Service officials. For example, in one region most easements
    were not entered into the database because final legal reviews had not
    been completed.

    The Service's Farmland Records Are Incomplete

    We identified farmlands that were not in the Service's centralized
    database or reported to us by the regional realty offices and therefore
    conclude that the Service has an incomplete account of its farmlands.
    Specifically, through our site visits and contacts with refuge managers,
    we found multiple instances in which individual refuge offices had files
    for farmland easements that were not otherwise reported in the centralized
    database or by the regional realty office. For example, one refuge manager
    we spoke with said he was responsible for 29 additional farmlands not
    included in the centralized database or reported to us by the regional
    realty office. These farmlands equate to over 80 percent (more than 900
    acres) of the farmlands that this refuge is responsible for managing. In
    other instances, the Service had made a recommendation to the Farm Service
    Agency to establish an easement, but the refuge office lacked a final deed
    confirming the easement's establishment. As a result, some questions exist
    as to whether the Service had received management responsibility for an
    easement that was established on the land. At one of the refuge offices we
    visited, for example, we identified 31 potential, or unconfirmed,
    easements in addition to 5 confirmed easements, comprising over 1,500
    acres, that had not been reported to us. The refuge office's files for the
    31 unconfirmed easements contained documentation, such as maps and records
    of site visits, but did not contain a final deed to confirm that the
    easement was official. Farm Service Agency and Service officials we spoke
    with in this state explained that the Farm Service Agency did not
    generally send a copy of the final deed to the Service when an easement
    was established. Thus, for these 31 unconfirmed farmlands, it is probable
    that an easement was established and the Service received management
    responsibility, but a copy of the final deed was simply not included in
    the file.

    Because of the Service's incomplete records, even the refuge offices may
    be unaware of all of the farmlands that they are in fact responsible for
    managing. For example, in one region, a realty official told us that a
    landowner had recently called the Service with a concern about an easement
    on his land. The Service, however, was unaware that it was responsible for
    managing the easement because it had no record of the farmland. After the
    call from the landowner, the Service confirmed that an easement had been
    established on the property by reviewing records at the courthouse in the
    county in which the farmland is located. In contrast, we identified a
    couple of instances where the refuge office maintained a file for a
    farmland, or assumed it was responsible for managing a farmland, when in
    fact the Service never received management responsibility, or an easement
    had not been established.

    The Service Is Generally Not Managing the Majority of Its Farmlands

    The Service is generally not managing the majority of its farmlands.
    Management activities the refuge offices are responsible for include
    regularly inspecting their farmlands to check for violations; taking
    enforcement actions on violations; maintaining contact with the landowners
    of easement lands; conducting limited maintenance activities including
    marking easement boundaries; and, in some cases, doing ecological
    restoration. Overall, however, we found that most refuge offices are
    carrying out these management activities on a very limited basis. Several
    factors affect the extent to which refuge offices devote management
    attention to their farmlands. First, devoting significant management
    attention to many of the farmlands has not been a priority because refuge
    officials do not believe that the lands contribute significantly to the
    refuges' goals or mission. Second, management of easement lands may be
    difficult because of uncertainty surrounding the scope and extent of the
    easements. Third, the Service is operating with constrained resources and
    declining refuge staff and therefore the staff are not able to complete
    all the activities they believe are necessary to manage the farmlands. In
    some instances, however, we identified farmlands that the refuges are
    actively managing, largely because the lands more closely align with the
    refuges' goals.

    The Service Performs Limited to No Management Activities on Most of Its
    Farmlands

    The Service's refuge offices have carried out very limited management
    activities on the majority of their farmlands. Through site visits to five
    refuge offices and our survey of the refuge offices' management of their
    farmlands (which covered 2002 through 2006), we found that most management
    activities, including inspections, contacts with landowners, and
    maintenance and restoration activities, are carried out on only a very
    limited basis. For an estimated 91 percent of farmlands, the refuge
    managers believe that over the past 5 years they were able to accomplish
    only half or less than half of the activities they believed were necessary
    to manage these lands. In general, we also found that the Service's
    fee-simple farmlands tend to receive more management attention,
    particularly inspections and completed restoration work, than its easement
    lands.

    While Service guidance calls for each farmland to be inspected at least
    once every year, very few farmlands are inspected annually. On-the-ground
    inspections are important to determine whether the landowners are
    complying with easement restrictions and to check for violations. From our
    survey, however, we estimate that only 13 percent of the farmlands, on
    average, have been annually inspected (see fig. 5). Additionally, on
    almost one-third of the farmlands, refuge managers did not believe (and
    were unable to provide documentation to show) that the farmlands had been
    visited by refuge staff at any point over the 10-year period from 1997
    through 2006.

    Figure 5: Estimated Frequency of Inspections from Calendar Year 2002
    through 2006

    Note: Percentages do not add to 100 percent because of rounding.

    Because the majority of farmlands are rarely inspected, refuge officials
    may not know the extent to which violations may be taking place on their
    farmlands. The farmlands, or the interests in them, are government
    property, so the Service may take civil or criminal action against
    violators for the destruction of government property. Through our survey,
    we found that of the properties that were inspected at least once in the
    last 5 years, the most recent inspection found violations on 26 percent of
    the farmlands.^20 Common violations included some agricultural practices
    such as grazing or haying, trespassing, dumping trash, hunting illegally,
    or removing signs (see fig. 6). At four of the five refuges we visited, we
    identified a violation on at least one easement land. For example, we
    visited one easement where the landowner had recently cleared much of the
    natural vegetation with a bulldozer and burned the land; at a different
    site, we saw where the landowner had built a driveway and shed through the
    middle of the easement area. At still another refuge, the refuge manager
    stated that of the 34 easement lands he has personally visited in the last
    3 years, 90 to 95 percent exhibit some kind of violation, most of which
    degrade the ecological value of the land. At the fifth refuge, violations
    appeared to be present on a few farmlands, but we could not confirm them
    because of a lack of clear easement boundaries.

    ^20The 95 percent confidence interval for this percentage is from 15
    percent to 40 percent.

    Figure 6: Farming Activities in Violation of a Wetland Easement, April
    2007

    Note: Violations on this 10-acre easement include tilling the land and
    clearing some of the wooded area for farming.

    One way the Service can help prevent violations is by maintaining regular
    contact with landowners and ensuring that landowners, particularly new
    landowners, clearly understand the easement terms; yet despite Service
    guidance to this effect, refuge managers rarely keep up with such
    contacts. For instance, only 13 of the 51 refuge managers we surveyed
    reported that they tracked land ownership changes on their easement
    lands--for example, by checking land sales records at county
    courthouses--and only 11 reported that they notified new landowners about
    the easement on their property. Several refuge managers said that
    farmlands changed ownership frequently, making it difficult for them to
    keep up with the current landowners for all their easement lands. For
    example, one refuge manager stated that at least 70 percent of his 80
    easement lands had changed ownership in the past several years.
    Compounding these difficulties, if a landowner divides and sells a portion
    of the farmland covered by an easement, the Service must then track all
    landowners to ensure that all portions of the easement area are in
    compliance. Through our survey, we found that multiple ownerships under
    one easement are fairly common; in one case, eight current landowners had
    a portion of a single easement on their property.

    Additionally, refuge offices have conducted very little maintenance on
    their farmlands. On the basis of our survey, we estimate that
    approximately 22 percent of the Service's farmlands have received
    maintenance over the past 5 years. While limited maintenance activities
    are required, particularly on easement lands, certain basic activities are
    called for. Specifically, Service guidance calls for all farmland
    boundaries to be marked, or posted, in a manner that is clear to
    landowners and the refuge officials responsible for managing them. During
    our site visits, however, we found that the farmlands were often not
    posted. At two of the refuges we visited, none of the easements were
    posted. At the other three refuges, while some farmlands had a few
    postings, others did not. In some cases, we also found that important
    fencing had not been installed or maintained. For example, we visited one
    easement that was being improperly grazed because the fencing that had
    been put up years ago was no longer able to keep cattle from entering and
    grazing the easement land.

    Similarly, refuge offices have completed only limited restoration
    activities on their farmlands. When the farmlands were initially received
    from the Farm Service Agency, the Service expected that restoring
    wetlands, planting uplands, and other rehabilitation would be an important
    component of the program, and in some cases a significant early investment
    was made to restore some lands. From our survey, however, we estimate that
    over the last 5 years, about 9 percent of the farmlands have had
    restoration work done, such as planting trees or altering water flow.
    Overall, since the farmlands were initially received by the Service,
    refuge officials whom we surveyed were aware of restoration work on only
    24 percent of their farmlands.^21 Service officials in one region told us
    that although considerable funding was initially made available for
    restoration projects, subsequent funding has not kept pace with
    restoration or maintenance needs. For example, one of the refuge managers
    in that region said that his office was given, on average, more than
    $225,000 per year for restoration over the first 5 years of receiving
    farmlands from the Farm Service Agency. This funding enabled completion of
    all necessary restoration projects initially, he said, but later funding
    to maintain the projects was not provided. In contrast, a number of refuge
    managers said that restoration work is unnecessary on some farmlands
    because the lands adequately achieve the conservation purpose for which
    they were acquired if they are simply left in their natural state.

    ^21The 95 percent confidence interval for this percentage is from 15 to 36
    percent.

    Several Factors Affect the Extent of the Service's Management Activities

    We found that several factors affect the extent to which the Service's
    refuge offices conduct management activities on their farmlands. First,
    managing the farmlands has not been a high priority because refuge
    officials do not believe that the lands contribute significantly to the
    refuges' goals or mission, because they are too small, isolated, and
    distant. While the size of the farmlands varies considerably--of the more
    than 1,400 farmlands nationwide, size ranges from less than 1 acre to more
    than 2,200 acres--over 75 percent of the farmlands are less than 100
    acres. Several refuge managers commented that they consider 100 acres a
    minimum size to support ecological viability, especially given the lands'
    fragmented nature. Often the farmlands are fragmented among active
    agricultural lands, have little or no connectivity to other wildlife
    habitat, or are widely scattered over a vast area. The farmlands are also
    often located many miles from the managing refuge office. At one refuge we
    visited, for example, the office is responsible for managing more than 100
    scattered farmlands, many of which are located more than 60 miles away
    (see fig. 7).

    Figure 7: Location of the Farmlands That Michigan's Shiawassee National
    Wildlife Refuge Is Responsible for Managing

    Through our survey, we estimate that about 83 percent of the Service's
    farmlands are located an hour or more away from their respective refuges,
    making it difficult for managers to visit them (see table 3). From a
    statistical analysis of our survey results, we found that both larger
    farmlands and those that are closer to the managing refuge were
    significantly more likely to have been inspected in the past 2 years than
    smaller or more distant farmlands.^22

    ^22See appendix II for a more detailed discussion of our analysis.

    Table 3: Estimated Travel Times between the Managing Refuge Offices and
    Their Farmlands

    Time (in hours)                    Percentage of farmlands
    Less than 1                                            18%
    One hour or more, but less than 2                       40
    Two hours or more, but less than 3                      27
    Three or more hours                                     16

    Source: GAO survey of the U.S. Fish and Wildlife Service's farmland
    management.

    Note: The data in this table represent the responses from refuge managers
    to the following question, "How much time, in minutes, does it typically
    take to drive from the refuge office to this property?" Percentages do not
    add to 100 percent because of rounding.

    Further, because managing the farmlands has not been a high priority, the
    lands may not be achieving the conservation purpose for which they were
    acquired. For example, we visited one farmland where an easement had been
    acquired for wetland purposes, but over time, the area had been filled in
    and become overgrown with dense vegetation and trees. The refuge manager
    said that in that state, the land exhibited no wetland characteristics and
    thus provided no value to any waterfowl species. He said it would take a
    significant amount of restoration work and subsequent continued
    maintenance to restore and sustain any wetland values on the land. We
    found that refuge managers believe that about 23 percent of the farmlands
    are currently meeting their conservation purpose to a great or very great
    extent. We also noted instances where the Service's assessment determined
    that the land did not contain important resources worthy of protecting,
    and the Service therefore did not request an easement on the land; the
    Farm Service Agency nevertheless established an easement on the land and
    named the Service the easement manager. In still other cases, the specific
    acres protected did not match the areas the Service had identified as
    containing important resources. For example, we reviewed one case where
    the Service received a farmland in fee simple and also received an
    additional parcel of land containing a potentially contaminated concrete
    building left over from former farming operations.

    Second, managing easement lands may be difficult because of uncertainty
    surrounding the easements' scope and extent. For instance, because legal
    surveys often were not completed on the farmlands when the easements were
    first established, precise boundaries may not be available. Few of the
    property files we reviewed on our site visits contained evidence that the
    land had been legally surveyed to establish precise boundaries. Through
    our survey, we found that about 49 percent of the farmlands' boundaries
    were clear to refuge managers. The lack of clear boundaries has made it
    difficult for some refuge officials to identify the location of all their
    easement lands and has also made it difficult to identify violations, such
    as farming encroachment or removal of vegetation, and to enforce
    restrictions. For example, we visited an easement where the refuge manager
    said the landowner moved the easement posting a few feet every year so as
    to expand his farming operations onto the easement land. Because the
    easement had not been legally surveyed, however, the refuge manager said
    it would be very difficult to insist that the farmer move the posting back
    to its original boundaries. The refuge manager said he was not even sure
    where the posting should officially be, given the lack of clear
    boundaries. In addition to unclear boundaries, some easement restrictions
    have been difficult for refuge managers to fully interpret and, in some
    cases, enforce. At one of the refuge offices we visited, for example, the
    refuge manager explained that while the easement allows "normal farming
    practices," it also prohibits altering the land's hydrology. He said that
    one of the easement landowners used farming equipment to level his land.
    According to the refuge manager, this leveling did alter the hydrology but
    could also be considered part of "normal farming practices." Thus, what
    constitutes a violation may sometimes be unclear because of ambiguity in
    the language of some easement restrictions.

    Third, the Service is operating with constrained resources and declining
    refuge staff, and therefore the refuge offices are not able to complete
    all the activities they believe are necessary to manage the farmlands.
    Over the past several years, refuge staff have been reduced significantly,
    and the Service plans to further reduce the refuges' workforce in the next
    3 years under current workforce-planning efforts aimed at cutting
    expenses. Currently, nearly 200 refuges are unstaffed, with this number
    likely to increase in the future. Senior headquarters and regional
    officials explained that the refuges have done what they can to manage
    their farmlands, given the limited resources they have at their disposal.
    For an estimated 88 percent of farmlands, the refuge managers believe that
    they have not had enough resources to manage their farmlands over the past
    5 years. A number of refuge officials also specifically cited the lack of
    law enforcement capabilities as a resource constraint. At two of the
    refuges we visited, the offices did not have any kind of permanent law
    enforcement staff; at two others, the law enforcement officer split his
    time between refuge offices. Several managers pointed out that they simply
    would not have the law enforcement capability to spend significant time
    taking enforcement actions for violations on farmlands. Our survey results
    suggest that the number of farmlands any one refuge office is responsible
    for varies greatly (from 1 to over 100) and that the more farmlands a
    refuge office is responsible for, the less likely the office is to have
    inspected a property in the past 2 years.^23

    Farmlands That Align Closely with Refuges' Goals Receive More Management
    Attention

    While the Service is generally not managing the majority of its farmlands,
    in some instances we identified farmlands that refuge offices are devoting
    significant management attention to, largely because these farmlands more
    closely align with the refuges' goals. Service officials explained that
    farmlands that are or have the potential to be more ecologically valuable
    generally receive more attention than those with less potential. For
    example, the Service's largest documented farmland is a fee-simple
    acquisition 2,263 acres in size. When this land was acquired by the
    Service, it was severely degraded by agricultural practices. At present,
    however, because of significant restoration work done by refuge staff, the
    land encompasses over 1,000 acres of native hardwood trees and abundant,
    varied wildlife, including significant populations of marsh and water
    birds, shorebirds, and other waterfowl. Although the land is located more
    than an hour away from the refuge office responsible for managing it, the
    refuge manager said that refuge staff visit the property multiple times
    per year for restoration and maintenance activities. Funding was allocated
    for restoration of this farmland before fiscal year 2002, but since then,
    the refuge office has used routine refuge operations-and-maintenance
    funding to manage it.

    In other instances, farmlands are located in areas the refuge offices are
    already focusing on, and these lands therefore receive more management
    attention. For example, we visited one refuge office responsible for
    managing a 606-acre easement adjacent to the refuge boundary that provided
    a critical connection between the refuge and a river running through the
    area. On this easement, the Service developed a management plan to
    maintain and enhance wetland ecosystems, riparian zones, and wildlife
    habitats while also allowing limited grazing on certain portions of the
    land. In the last few years, the refuge office received grant funding to
    conduct restoration work to increase the wetlands and address
    channelization and erosion problems. Currently, two landowners each own a
    parcel of the easement, and according to the refuge manager, they have
    both supported the refuge's efforts to restore the land. Overall, he
    suggested, the situation is a good example of how Farm Service Agency
    easement lands can successfully contribute to the mission of the National
    Wildlife Refuge System.

    ^23See appendix II for a more detailed discussion of our analysis.

    In another instance, we visited a farmland of 361 acres owned in fee
    simple by the Service that, because of its location, was turned into the
    headquarters of a wetland management district. In this district, the
    Service is working to acquire more wetland and upland habitat for
    waterfowl, migratory birds, and other wildlife. The Service conducted
    wetlands restoration work on the property and turned the old, dilapidated
    farmhouse into the refuge office (see fig. 8). Fishing access, a nature
    trail, and other environmental education activities now complement the
    farmland's restored wetlands.

    Figure 8: Old Farmhouse in New York, Renovated to Serve as a Refuge
    Office, April 2007

    The Service Has Limited Alternatives for Managing Its Farmlands

    Since the Service first started receiving farmlands from the Farm Service
    Agency more than two decades ago, it has had limited alternatives for
    managing them because the lands became part of the National Wildlife
    Refuge System. The alternatives include (1) resetting refuge priorities to
    ensure that farmlands are given management attention, (2) requesting
    additional resources, and (3) paying little or no management attention to
    the farmlands. Generally, when a farmland has significantly contributed to
    the goals and mission of the responsible refuge, the Service has either
    adjusted its refuge priorities to ensure farmland management or found the
    resources necessary to actively manage the property. These instances have
    been rare, however. For most farmlands, the Service has chosen the third
    alternative--paying little or no management attention to its
    farmlands--and it is unlikely to increase its management attention. Refuge
    officials we spoke with said that they were unlikely to raise the priority
    of farmland management activities in the future unless additional refuge
    funding was provided or regional or national officials directed them to do
    so. They explained that because of the nature of the farmlands, it simply
    does not make sense to reset refuge priorities to increase management
    attention to them. Refuge managers said that they would also be highly
    unlikely to ask for additional resources to manage farmlands, except in
    rare instances, because of the continuing shortfall in resources to
    complete even their core refuge activities, such as protecting critical
    habitat. Service headquarters and regional officials agreed that as staff
    and budgets continue to be downsized, further management attention to the
    farmlands is unlikely. By paying little or no management attention to its
    farmlands, however, the Service risks allowing habitats to be degraded;
    violations to go unchecked; and, in some cases, government property to be
    damaged.

    Because these farmlands are now part of the National Wildlife Refuge
    System, the Service has limited options--restricted by federal law and
    executive orders--for relinquishing management responsibilities for
    unwanted farmlands or farmlands it deems not in the best interest to
    retain in the refuge system. Under provisions of the National Wildlife
    Refuge Administration Act of 1966, as amended, lands that are part of the
    National Wildlife Refuge System cannot be transferred or otherwise
    disposed of (except by exchange) unless the Secretary of the Interior
    determines, with the concurrence of the Migratory Bird Conservation
    Commission,^24 that the land or interest in lands is no longer needed for
    the purposes for which the refuge system was established. Refuge lands
    have never been transferred or disposed of in this manner, however. In
    addition, the Service is required to abide by the provisions of Executive
    Order 11990, covering wetland protection, and Executive Order 11988,
    covering floodplain management, which require protection and preservation
    of these resources. It has also been the policy of the federal government
    since 1989 to achieve "no net loss" of wetlands in carrying out the
    government's land management activities.^25

    ^24The Migratory Bird Conservation Commission considers and acts on
    recommendations of the Secretary of the Interior for the purchase or
    rental of land, water, or both for the conservation of migratory bird
    habitat. The commission consists of the Secretary of the Interior, the
    Administrator of the Environmental Protection Agency, the Secretary of
    Agriculture, and two members from each house of Congress.

    In a few isolated instances, the Service has successfully exchanged
    farmlands for private lands under existing authorities. According to
    Service officials, fee-simple farmlands were generally exchanged for
    private lands to acquire lands nearer existing refuges, and easement
    exchanges were done mainly to acquire land that was more ecologically
    valuable or to enable landowners to accomplish their land use objectives.
    Service officials told us, however, that the possibilities for further
    land exchanges are limited, especially for easement lands. On fee-simple
    lands, the main difficulty is finding private entities that are interested
    in obtaining the Service's isolated parcels and also own lands the Service
    is interested in acquiring. For easement lands, the only parties
    interested in acquiring easement rights are usually the underlying
    landowners, and rarely do they own other lands that would make sense to
    exchange. In addition, for both fee-simple and easement properties, the
    administrative and procedural aspects of accomplishing land exchanges are
    often extremely costly and burdensome. For instance, we reviewed one
    exchange, involving an easement, that took more than 3 years to complete
    and required costly survey and appraisal work in addition to significant
    time and effort on the part of Service realty and refuge staff.

    In addition to exchanges, the Service can look to third parties, such as
    state agencies or nonprofit organizations, to establish cooperative
    agreements to manage its farmlands. For example, one refuge has an
    agreement with a state agency to manage one of its farmlands because the
    land is located near a state-owned natural area. Service officials
    indicated that such situations are rare, however, and it is unlikely that
    many additional cooperative agreements will be established, given the
    location, size, and ecological value of the lands and the management costs
    to these groups--the very reasons the Service does not itself accord the
    lands significant management attention.

    In contrast, other federal land management agencies have authorities that
    provide them flexibility to dispose of lands found not in their best
    interest to retain. These authorities may provide models for addressing
    farmlands that the Service determines no longer serve the purposes of the
    refuge system. For example, under the Southern Nevada Public Land
    Management Act of 1998, the Department of the Interior's Bureau of Land
    Management has the authority to sell or exchange public land within a
    specific area around Las Vegas, Nevada.^26 A portion of the proceeds from
    the sale of such lands is put into a fund that is then used for a variety
    of purposes, including conservation initiatives and certain land
    acquisitions. The account is also available for the reimbursement of costs
    incurred by the local offices of the Bureau of Land Management in
    arranging sales or exchanges under this act.

    ^25Given the value of wetlands, the administration set a national goal in
    1989 of balancing losses and gains to achieve no net loss of wetlands.
    Each subsequent President has reaffirmed and expanded this goal of
    achieving net gains of wetlands over the long term.

    Similarly, the Small Tracts Act gives the Department of Agriculture's
    Forest Service the authority to sell certain small, isolated parcels of
    its landholdings under specific conditions.^27 Specifically, eligible
    parcels may be sold if they have a market value of less than $150,000, are
    smaller than 40 acres, are not efficiently administered because of their
    location and size, and cannot be sold under any other authority. The Small
    Tracts Act authorizes the Forest Service to exchange lands or interests in
    lands of approximately equal value without need of formal appraisals. This
    authority can greatly facilitate land transactions where the cost of the
    appraisals is significant enough to diminish the likelihood of the
    transaction. Pending legislation would, among other provisions, increase
    the acreage from 40 to 100 acres.^28

    Additionally, the Federal Property and Administrative Services Act of
    1949, as amended, governs the disposal of most federal property that a
    federal agency no longer needs to carry out its mission, programs, and
    activities.^29 Such property is reported as excess to the General Services
    Administration and offered first to other federal agencies for their use
    and then to state or local governments or to certain tax-exempt nonprofit
    organizations through such mechanisms as negotiated or public sales. If
    these entities do not wish to acquire the property, the General Services
    Administration can then dispose of it through a competitive sale to the
    public, generally via sealed bid or auction.

    ^26Pub. L. No. 105-263, 112 Stat. 2343 (1998).

    ^27Pub. L. No. 97-465, 96 Stat. 2535 (1983), codified at 16 U.S.C. S
    521c-i.

    ^28H.R. 485, 110th Congress (2007). A similar bill, H.R. 1905, was not
    enacted in 109th Congress.

    ^2940 U.S.C. SS 521-9, 541-59. See also GAO, Federal Real Property: Most
    Public Benefit Conveyances Used as Intended, but Opportunities Exist to
    Enhance Federal Oversight, [21]GAO-06-511 (Washington, D.C.: June 21,
    2006).

    If the Service had authority for its farmlands similar to the above
    examples, it could consolidate some of its unwanted farmlands through an
    arrangement where it sold fee-simple farmlands or the easement rights and
    then directed the proceeds to the purchase of lands that were more closely
    aligned with the goals and mission of the refuge system. Considerations
    such as the time frame for allowing such sales and purchases, and whether
    such activities could occur on a nationwide scale or whether purchases
    would be limited to the states or region in which the sale took place,
    would be important. An advantage to such an arrangement would be that the
    Service could, at a minimum, offset the loss of any wetlands and
    floodplains. According to Service officials, however, a significant
    obstacle to this option would be that although farmlands owned in fee
    simple can have considerable market value, many of the easements have
    little or no tangible market value, and easement sales may therefore be
    difficult or impossible. Therefore, granting the Service authority
    specific to its farmlands similar to that granted under the Southern
    Nevada Public Land Management Act, the Small Tracts Act, or the Federal
    Property and Administrative Services Act, while useful, would not likely
    be sufficient to address most of the Service's unwanted farmlands.

    Further, the Service recently developed a proposal to divest some of its
    limited-interest refuges in North Dakota.^30 The divestiture proposal was
    developed to help ensure that future resources are expended on lands that
    support the mission and goals of the refuge system. Under the proposal,
    refuge lands were selected for divestiture on the basis of specific
    criteria, including how well the lands achieved one or more of the goals
    of the National Wildlife Refuge System, whether the lands met their
    intended purpose, whether the lands had biological integrity, and whether
    it was possible to restore them. This divestiture proposal would require
    congressional authorization for the properties recommended for divestment.
    The Service could expand this model and adapt the criteria to address
    management limitations specific to the farmlands, such as property size,
    distance from the refuge office, number of refuge staff available, as well
    as ecological considerations. Using such criteria, the Service could
    propose to Congress a list of specific farmlands to be divested, along
    with written justification outlining the Service's judgments.

    ^30Limited-interest refuges are lands with a defined refuge boundary but
    where the Service does not own the land in fee simple and instead retains
    limited easement rights, largely the right to flood or maintain an
    artificial lake for promotion of water conservation or wildlife habitat.
    The underlying property remains in private ownership.

    We encountered a wide array of perspectives with regard to the value the
    farmlands bring to the refuge system, the costs of their management, and
    what should be done with those lands that are not significantly
    contributing to the refuge systems' goals and mission. For instance, some
    refuge managers and regional officials we spoke with believed that the
    ecological value of the farmlands is not calculable--especially from a
    long-term viewpoint, such as 50 years hence--and therefore all the
    farmlands should be retained. Some refuge managers spoke of the low-risk
    nature of many of the farmlands--lands where threats of violations are
    low, where maintenance needs are minimal, and where the undisturbed
    natural state maintains ecological value. These types of farmlands do not
    require active restoration, and management, namely regular inspections and
    contacts with landowners, would take only minimal effort. Other
    headquarters, regional, and refuge officials, however, spoke of
    operational efficiencies in the face of continually constrained budgets.
    These officials were apt to suggest balancing resource constraints against
    the ecological value of the farmlands in comparison with the value of
    refuge lands; they argued that in this context, it does not make sense to
    expend any resources on some of the farmlands. When asked, most refuge
    officials were generally able to identify farmlands that they believed
    would not have ecological value sufficient for continued inclusion in the
    refuge system, even with significantly increased resources or refuge
    staff. Some officials were reluctant to suggest that the Service should
    attempt to relinquish its management responsibilities on those lands,
    however, for fear of opening the door to potential divestiture of other,
    more critical refuge lands, which could bring about a significant
    ecological loss to the refuge system.

    Conclusions

    The 1985 Farm Bill and subsequent legislation provided the Service, in
    partnership with the Farm Service Agency, a mechanism to protect, as part
    of the National Wildlife Refuge System, farmlands that encompassed
    wetlands or other important natural resources. The Service is now
    responsible for managing a significant number of both conservation
    easement and fee-simple farmlands across most of the continental United
    States. The Service does not have a complete accounting of all of its
    farmlands, however, so the actual scope of its responsibilities is not
    certain. As a result, it may be unable to accurately assess its management
    needs. Given the farmlands' wide variation in size, location, and other
    characteristics, a complete accounting is needed to best determine how
    these lands should be managed in the future.

    Since its first farmland acquisition more than 20 years ago, the Service
    has generally used the tools at its disposal to deal with these lands as
    best it could. We agree with the Service that its main priority, and its
    limited resources, should be directed at managing and sustaining its core
    refuge lands. However, by not conducting at least a minimum level of
    management activities on the farmlands it has acquired, including
    inspecting the lands on a regular basis, posting the lands, and ensuring
    that landowners are aware of restrictions, the Service could ultimately
    see the loss or degradation of the resources it was given the
    responsibility to protect. Under current law, the Service has very few
    alternatives for reducing or removing management responsibilities for
    lands received from the Farm Service Agency that are not significantly
    contributing to the mission and goals of the National Wildlife Refuge
    System. Therefore, we believe the Service needs additional flexibility to
    better align the farmlands it is responsible for with the goals and
    mission of the refuge system.

    Other federal land management agencies have authorities to dispose of
    lands found not in their best interest to retain, and these authorities
    could serve as a starting point for the possible development of a
    legislative solution for farmlands the Service received from the Farm
    Service Agency. Existing authorities have largely been applied to
    fee-simple lands, and their applicability to easements may be limited,
    largely because of the relatively low market value of many of the
    easements. Partly for this reason, a variety of approaches may be
    warranted and tailored to the specific farmlands that the Service
    determines should no longer be included in the refuge system. In any
    approach the Service takes to alter its current farmland management
    responsibilities, to the extent possible, it should strive to maintain a
    conservation focus. For example, the Service could seek authority to
    invest the proceeds from the sale of any farmlands into conserving other
    lands or to offer farmlands to state agencies or nonprofits for
    conservation purposes. Additionally, because any federal land divestment
    proposal raises significant concerns, crucial variables to consider
    include a time limit to identify potential farmlands for divestment and
    narrowly limiting the scope of any divestment proposal to only those
    farmlands the Service identifies as unwanted.

    Recommendations for Executive Action

    To improve the effectiveness and efficiency of the Service's management of
    its farmlands, we recommend that the Secretary of the Interior direct the
    Director of the Service to take the following two actions:

               o ensure that the Service's records for all of its farmlands are
               accurate and complete by reconciling regional and refuge office
               records and property records to determine which farmlands were
               transferred from the Farm Service Agency, and
               o develop a proposal to Congress seeking the authority for
               additional flexibility with regard to the farmlands the Service
               determines may not be in the best interest to continue to include
               as part of the National Wildlife Refuge System.

    Agency Comments

    We provided copies of our draft report to the Department of the Interior
    and the Department of Agriculture. The Department of the Interior
    concurred with our recommendations and agreed to take action on both
    recommendations by the end of calendar year 2009. In addition, the
    department provided several technical clarifications, which we
    incorporated as appropriate. Appendix III contains the Department of the
    Interior's comment letter. The Department of Agriculture provided no
    comments.

    We are sending copies of this report to interested congressional
    committees, the Secretary of the Interior, the Secretary of Agriculture,
    the Director of the Service, the Administrator of the Farm Service Agency,
    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 has any questions about this report, please contact
    me at (202) 512-3841 or nazzaror@gao.gov. Contact points for our Offices
    of Congressional Relations and Public Affairs may be found on the last
    page of this report. GAO staff who made major contributions to this report
    are listed in appendix IV.

    Robin M. Nazzaro
    Director, Natural Resources and Environment

    Appendix I: Scope and Methodology

    To examine the extent of farmland received by the Department of the
    Interior's U.S. Fish and Wildlife Service (Service) from the Department of
    Agriculture's Farm Service Agency, we interviewed officials at and
    reviewed documentation from the Service's headquarters and regional
    offices. Specifically, we requested all farmland acquisition data from the
    Service's centralized land records system--its database for tracking
    lands, including interests in lands, under its control. To assess the
    reliability of the data we received from this database, we interviewed
    officials most knowledgeable about the collection and management of these
    data, and we reviewed relevant data controls. On the basis of our review,
    we concluded that the database records were sufficiently reliable for us
    to report on what information the database contained. We were informed by
    some regional realty officials, however, that the database was likely
    incomplete. Consequently, we contacted each regional office to determine
    if the offices maintained additional farmland records outside the
    centralized database. Three Service regions provided us with additional
    farmland records that were not contained in the database. We also visited
    and collected additional farmland records from five refuge offices in five
    different regions.^1 At each site, we completed a detailed review of the
    available files on farmlands and compared this information with the
    information we received from the Service's centralized database, regional
    offices, or both, as applicable. We selected the sites to visit using the
    data we were given from the Service's headquarters and three regional
    offices to identify the refuge office responsible for managing the largest
    number of farmlands in each Service region. The five refuge offices we
    visited were Tishomingo National Wildlife Refuge near Tishomingo, Oklahoma
    (region 2); Shiawassee National Wildlife Refuge near Saginaw, Michigan
    (region 3); North Mississippi Refuge Complex near Grenada, Mississippi
    (region 4); Montezuma National Wildlife Refuge near Seneca Falls, New York
    (region 5); and Modoc National Wildlife Refuge near Alturas, California
    (region 8). In addition, we also interviewed the Farm Service Agency
    officials at its headquarters and four of its state offices to determine
    the availability of records it may have maintained on farmlands it
    transferred, either in fee simple or through an easement, to the Service.
    We found that the Farm Service Agency generally did not maintain organized
    historical records of all its transfers to the Service.

    ^1Early in our review, we also visited a Service field office located in
    the Prairie Pothole Region of the Service's region 6. Partly on the basis
    of this visit, we decided to omit Prairie Pothole Region farmlands from
    this review because these farmlands are managed very differently from
    those outside this unique region.

    To examine the extent to which the Service is currently managing its
    farmlands, we identified and analyzed applicable laws, policies, and
    procedures governing the Service's farmland management, and we interviewed
    officials at the Service's headquarters, regional offices, and the five
    refuge offices we visited. During our site visits, we reviewed the files
    for each farmland in detail, including inspection records; records of
    landowner contacts; records of completed restoration and maintenance work;
    and general information about the farmland, including the easement
    restrictions, boundary demarcations, and other legal documentation. During
    these site visits, we also saw a sample of farmlands that the refuge
    office was responsible for managing and learned what inspection activities
    entailed. We also observed the condition of each farmland, whether
    easement signs were clearly visible, and whether there were any signs of
    easement violations or other problems. We also designed and conducted a
    survey, through structured telephone interviews, of refuge managers from
    across the United States about the extent to which they are managing their
    farmlands. We received a 100 percent response rate from the simple random
    sample of 98 farmlands we selected from the population of 1,423 farmland
    records that were provided to us by the Service's headquarters and
    regional offices. Appendix II discusses our survey methodology in greater
    detail.

    To examine the Service's alternatives for managing its farmlands, we
    interviewed headquarters and regional officials from the Service's Realty
    and Refuge Offices in addition to the refuge office managers contacted
    through our site visits and telephone survey. We also interviewed the
    Department of the Interior's Office of the Solicitor. Further, we analyzed
    relevant federal laws and Service policies governing options for managing
    lands within the National Wildlife Refuge System, and we reviewed federal
    laws governing land management in other federal agencies, including the
    Department of the Interior's Bureau of Land Management and the Department
    of Agriculture's Forest Service.

    We performed our work between September 2006 and July 2007 in accordance
    with generally accepted government auditing standards.

    Appendix II: Survey of the U.S. Fish and Wildlife Service's Farmland
    Management

    To further examine the extent to which the Department of the Interior's
    U.S. Fish and Wildlife Service (Service) is currently managing the
    farmlands it received from the Farm Service Agency, we designed and
    conducted a survey, through structured telephone interviews, of refuge
    managers from across the United States about the extent to which they are
    managing their farmlands. The questions were designed to obtain
    information on the number of farmlands each refuge is responsible for and
    on the nature and quantity of inspections, violations, landowner contact,
    maintenance, and restoration activity that occur on each farmland. In
    addition, the structured interviews solicited information on factors that
    may hinder the refuge offices' ability to manage their farmlands. The
    interview questions focused primarily on management activities that took
    place over the 5-year period from 2002 through 2006. We selected a simple
    random sample of 106 farmlands from the population of 1,423 farmland
    records that were provided to us by the Service's headquarters and
    regional offices as of February 22, 2007. After we selected our sample, we
    determined that 8 of the farmlands were not under the management
    jurisdiction of the Service, so our final sample consisted of 98
    farmlands. We conducted structured telephone interviews with the 51 refuge
    offices^1 responsible for managing these 98 farmlands, which included both
    fee-simple and easement lands located in 24 states across the nation.

    We developed a structured interview guide with the assistance of a GAO
    survey specialist and pretested it over the telephone with refuge managers
    and staff from 17 refuge offices; we then revised the structured interview
    guide, as appropriate, on the basis of the pretest results. A second GAO
    survey specialist independently reviewed our interview guide to ensure
    that the questions followed general principles of survey research. To
    conduct our survey, we e-mailed each refuge manager responsible for one or
    more of the 98 farmlands in our sample and requested a telephone
    interview. We held our structured telephone interviews from March 22,
    2007, through May 1, 2007, with the person whom the refuge identified as
    most knowledgeable about managing the farmlands in question--usually the
    refuge manager--along with other refuge staff familiar with sample
    farmlands. At the end of each telephone interview, we requested that the
    refuge manager send us all documentation available to support the
    information provided in the interview, such as records indicating when
    inspections or restoration activities occurred. On receiving the
    documentation, we compared it with the information given in the interview.
    Reviewing this documentation gave us additional confidence in the data we
    collected during our structured telephone interviews. We did not encounter
    any significant discrepancies between the information collected during the
    interviews and the documentation supplied by refuge officials.

    ^1In a number of cases, one refuge office managed two or more of the
    farmlands in our random sample. When a refuge office was responsible for
    more than one farmland in our sample, we asked the same set of questions
    for each farmland.

    Our interview response rate was 100 percent,^2 and the results can be
    projected to the population of documented farmlands.^3 The results cannot
    be projected, however, to the additional undocumented farmlands we became
    aware of during our audit work because data for these lands were not
    available at the time our random sample was chosen and were therefore not
    represented in our sample. Percentage estimates based on our sample have
    margins of error of +-10 percentage points at the 95 percent confidence
    level unless otherwise noted. We also asked a few questions that were not
    specific to a sampled farmland but, rather, applied to the refuge office's
    management of all its farmlands. Responses to these officewide questions
    cannot be projected to a population of wildlife refuges and are not
    presented as such. We also analyzed responses to open-ended interview
    questions to identify common themes and to provide context for the
    responses to our specific questions.

    During the telephone survey, we took steps to ensure data quality. Because
    of the practicalities of conducting structured telephone interviews,
    interviewees' responses may reflect errors; interviewees may misinterpret
    a question, for example. We took steps in developing and conducting the
    survey to reduce such errors. First, we conducted the interviews in a
    standardized manner to ensure that each respondent was asked the same
    questions, each with precise wording, and in the same order. Second,
    during the interviews, we annotated responses with notes about
    respondent's hesitations, inconclusiveness, inconsistencies, or inability
    to answer the question directly or succinctly. We reviewed these notes
    before data analyses to ensure response accuracy. Third, for some
    questions, we asked respondents directly about their level of certainty
    regarding a response, for example, whether their response was "precise" or
    "approximate." Finally, we validated responses obtained from the
    structured interviews with documentation from the refuges. For example, we
    verified such items as inspection dates, acreage amounts, and violations
    against the interview responses. All survey data were entered into a
    statistical analysis program and verified for accuracy. The results were
    then summarized and tabulated.

    ^2Interviews were completed for all 98 of the randomly sampled farmlands.

    ^3This population consists of all farmlands documented in the Service's
    centralized database, as well as additional farmland records provided by
    three regions (regions 1, 2, and 3). Later in our audit work, we
    identified additional (undocumented) farmlands that were not included in
    the Service's centralized database or in records maintained by the regions
    and provided to us.

    Table 4 summarizes the key questions we are reporting on that we asked
    during the structured interviews about the management of each sampled
    farmland. We also asked other questions that we do not specifically report
    on to supply further context for interviewees' responses. For example,
    after asking whether a certain management activity had occurred, such as
    an inspection, we asked the respondent during which season and year the
    activity took place and to describe the activity.

    Table 4: Selected Survey Questions

    Refuge-level questions
    How many fee-simple properties is your refuge office responsible for
    managing?
    How many properties with easements is your refuge office responsible for
    managing?
    Does your refuge office identify and track land ownership changes on any
    of your Farm Service Agency properties with easements? If so, what process
    does your office use?
    Property-specific questions
    General
    How many sub-tracts does this property consist of?
    Do you know when the last time you or someone from your refuge staff
    visited the property?
    At the time of its acquisition, was the property acquired in order to
    protect wetlands; a riparian zone; a floodplain; a coastal barrier;
    threatened or endangered species habitat; fish and wildlife habitat of
    local, regional, state, or national importance; an aquifer recharge area;
    an area of high water quality; an area of high scenic value; or any other
    conservation purpose?
    In its current condition, to what extent is this property meeting its
    conservation purpose? Would you say it is meeting this purpose to a very
    great extent, to a great extent, to a moderate extent, to some extent, or
    to little or no extent?
    Maintenance and restoration
    At any time during calendar years 2002 through 2006, have you or has
    someone else from your refuge conducted any maintenance or restoration
    work on this property? If yes, what type of maintenance or restoration
    work was conducted on the property?
    To the best of your knowledge, has any other restoration work ever been
    completed on this property since it was acquired by the Service? If yes,
    what type of restoration work was conducted on the property?

    Inspecting for violations
    At any time during calendar years 2002 through 2006, have you or has
    someone from your refuge inspected this property for violations?
    Approximately how many times have you or has someone from your refuge
    inspected this property for violations during calendar years 2002 through
    2006?
    On your most recent inspection, did you identify any violations? If yes,
    what types of violations did you identify?
    Factors that hinder management
    Would you say that all of the terms (restrictions) of the easement are
    clear, or are there terms that are unclear? If terms are unclear, have
    unclear terms hindered your ability to manage this property?
    Would you say that all of the boundary segments of this property are
    clear, or are there some boundary segments that are not clear? If some
    boundary segments are not clear, have unclear boundaries hindered your
    ability to manage this property?
    How many miles is it from the refuge office to this property?
    How much time, in minutes, does it typically take to drive from the refuge
    office to this property?
    Has the time required to travel to this property hindered your ability to
    manage this property?
    Has the level of resources that your refuge office received over the past
    5 years been more than enough, about enough, or less than enough to manage
    this property? If less than enough, has this lack of resources hindered
    your ability to manage this property?
    On balance, would you say that over the past 5 years, your office has been
    able to accomplish more than half of the activities necessary to manage
    the property, about half of these activities, or less than half of these
    activities?

    Source: GAO.

    In addition, to further analyze our survey responses, we applied certain
    statistical transformations to the data, which we then analyzed for
    statistically significant patterns. Specifically, using responses about
    when the farmlands were inspected with specific farmland characteristics
    as discussed below, we created new variables to assess correlations.
    During our site visits, interviews, and telephone survey, refuge managers
    mentioned several reasons that some farmlands are inspected while other
    farmlands are not. These reasons included farmland size; distance between
    a farmland and the refuge office; and refuge workload, including the
    number of other properties managed by the refuge office. To corroborate
    these explanations, we performed a statistical procedure known as logistic
    regression analysis. Logistic regression can be used to determine whether
    farmlands that are inspected have different characteristics, on average,
    from farmlands that are not inspected. We used logistic regression to
    assess the size and the significance of the effects of the following three
    factors: property size, distance to refuge office, and the number of
    properties managed by a refuge.

    We estimated the effects of these three different factors on the
    likelihood of properties' being inspected, using straightforward
    contingency-table methods (i.e., bivariate cross-tabulations) and using
    bivariate and multivariate logistic regression models. The three sections
    of table 5 show the bivariate relationships between inspection status
    (i.e., whether the property had been inspected in the previous 2 years)
    and each of the three factors: (1) property size (top section), (2)
    distance from the property to the managing refuge (middle section), and
    (3) the number of properties managed by the refuge (bottom section). When
    we considered each of these relationships independently (i.e., one at a
    time), we found that whether a property had been inspected in the
    preceding 2 years was significantly associated with each of the three
    factors:

               o Larger properties were more likely to have been inspected in the
               preceding 2 years than smaller ones. Although 67 percent of the
               properties larger than 100 acres were inspected, only 45 percent
               of the properties between 11 and 100 acres in size were inspected,
               and only 7 percent of those properties 10 acres or smaller were
               inspected.
               o Properties that were closer to the managing refuge were more apt
               to have been inspected than those farther away. Eighty-four
               percent of the properties closer than 50 miles from the managing
               refuge were inspected, but only 37 percent of the properties
               between 50 and 100 miles from the refuge, and 27 percent of the
               properties farther than 100 miles from the refuge, were inspected.
               o Properties managed by refuges with more properties to manage
               were less likely to have been inspected than properties managed by
               refuges with fewer properties to manage. Sixty-two percent of the
               properties managed by refuges that managed fewer than 20
               properties were inspected, while only 41 percent and 13 percent of
               the properties managed by refuges that managed 20 to 49 and 50
               properties or more, respectively, were inspected.

    Table 5: Numbers and Percentages of Properties Inspected and Not Inspected
    in the Past 2 Years, by Size, Distance, and Number of Properties, and Odds
    and Odds Ratios Derived from Them

                                    Inspected in preceding 2 years?
                                                         Observed     Odds ratios
                                                 Odds on     odds         (linear
                           No     Yes    Total inspected ratios^a        model)^a
    Size
    10 acres or         14   1(7%) 15(100%)      0.07
    smaller          (93%)
    11-100 acres   32 (55)  26(45)  58(100)      0.81    11.38            4.00
    Larger than     6 (33)  12(67)  18(100)      2.00     2.47            4.00
    100 acres
    Total               52 39(43%) 91(100%)
                        (57%)
    Distance
    Closer than    3 (16%) 16(84%) 19(100%)      5.33
    50 miles
    50-100 miles   24 (63)  14(37)  38(100)      0.58     0.11            0.31
    Farther than   24 (73)   9(27)  33(100)      0.38     0.64            0.31
    100 miles
    Total               51 39(43%) 90(100%)
                        (57%)
    Number of
    properties
    Fewer than 20       14 23(62%) 37(100%)      1.64
                        (38%)
    20-49          17 (59)  12(41)  29(100)      0.71     0.43            0.32
    50 or more     21 (88)   3(12)  24(100)      0.14     0.20            0.32
    Total               52 38(42%) 90(100%)
                        (58%)

    Source: GAO.

    Note: The likelihood-ratio chi-square values testing the hypothesis of
    independence in the three subtables for size, distance, and number of
    properties are 14.24, 17.90, and 16.08, respectively, with two degrees of
    freedom in each case. These values are large enough for us to reject the
    hypothesis of independence with greater than 99 percent confidence. The
    odds ratio for the linear model implies that there are linear differences
    between the categories for acreage, miles, and properties, not that the
    effects of actual acreage, miles, or properties are linear.

    aThe observed odds ratios, and the odds ratios for the linear model, were
    calculated by dividing the odds on being inspected for the second category
    by the corresponding odds for the first, and then dividing the odds for
    the third category by the odds for the second.

    While sizable confidence intervals are associated with each of these
    estimates of the percentage of inspected properties (see table 6), all of
    these bivariate associations were statistically significant (at the p =
    0.05 level or better). Moreover, when we used bivariate logistic
    regression models to estimate these associations, we found that each
    association was well described by simple models that constrained the
    associations to be linear. To understand these models, it is helpful to
    consider the three right-hand columns of table 5, which show for each
    category of property size, distance from the refuge, and number of
    properties managed by the refuge the observed odds on being inspected,
    observed odds ratios, and odds ratios under a linear model.

    Table 6: Confidence Intervals Associated with the Estimated Percentage of
    Properties Inspected, by Size, Distance, and Number of Properties

                                                     95% confidence interval
                               Percentage inspected  Lower limit Upper limit
    Size
    10 acres or smaller                       7%           0%         32%
    11-100 acres                              45           32          57
    Larger than 100 acres                     67           41          87
    Total                                    43%          33%         53%
    Distance
    Closer than 50 miles                     84%          60%         97%
    50-100 miles                              37           22          54
    Farther than 100 miles                    27           13          46
    Total                                    43%          33%         53%
    Number of properties
    Fewer than 20                            62%          45%         78%
    20-49                                     41           24          61
    50 or more                                13            3          32
    Total                                    42%          32%         52%

    Source: GAO.

    The observed odds are obtained by dividing, for each group of properties,
    the number (or percentage) of properties inspected by the number (or
    percentage) of properties not inspected. For properties 10 acres or
    smaller, the odds on being inspected were 1/14 = 0.07, whereas for
    properties 11-100 acres in size and larger than 100 acres, the odds on
    being inspected were 26/32 = 0.81 and 12/6 = 2.00, respectively. The
    observed odds ratios are obtained by dividing the odds for any given
    category by the odds for the next lower category. In these data, we find
    that properties in the middle acreage category were more likely to have
    been inspected than those in the lowest acreage category (by a factor of
    0.81/0.07 = 11.38) and that properties in the highest acreage category
    were more likely to have been inspected than those in the middle category
    (by a factor of 2.00/0.81 = 2.47). Like the percentages already mentioned,
    these observed odds and odds ratios, derived directly from the sample
    data, involve considerable error and sizable confidence intervals, and a
    simple linear model estimating differences among size categories fits
    acceptably. Under this model, the odds on being inspected were greater for
    properties 11 to 100 acres in size than for properties 10 acres or
    smaller, and greater for properties larger than 100 acres than for
    properties 11 to 100 acres in size, in both cases by a factor of 4.0.
    These ratios are shown in the right-hand column of table 5. This column
    also shows that the effect of distance yields a linear odds ratio of 0.31
    (properties farther away than 50 to 100 miles were less likely to have
    been inspected than properties closer than 50 miles, by a factor of 0.31,
    and properties farther away than 100 miles were less likely to have been
    inspected than properties 50 to 100 miles away by that same factor). A
    similar odds ratio of 0.32 estimates the linear effect of the number of
    properties managed by the refuge responsible for each.

    We also used multivariate logistic regression models to simultaneously
    estimate the effects of these three factors on the likelihood of
    properties' being inspected. These models allowed us to isolate the
    independent effect of each factor by adjusting for the effects of the
    other two factors. We also used robust procedures to account for the lack
    of independence across the observations (i.e., properties), that is, the
    clustering of properties within refuges. We obtained the following
    results:

               o The effect of size remained pronounced and significant even
               after adjusting for the effects of distance and number of other
               properties managed by the responsible refuge. The adjusted odds on
               properties' being inspected were 3.5 times higher for properties
               11 to 100 acres in size than for properties 10 acres or smaller,
               and they were 3.5 times higher for properties larger than 100
               acres than for properties 11 to 100 acres in size. In other words,
               properties between 11 and 100 acres were 3.5 times more likely to
               be inspected than properties 10 acres or smaller. Similarly,
               properties larger than 100 acres were 3.5 times more likely to be
               inspected than properties between 11 and 100 acres.

               o The effect of distance remained pronounced and significant even
               after adjusting for the effects of size and number of properties
               managed. The adjusted odds on properties being inspected were
               lower for properties 50 to 100 miles from the responsible refuge
               than for properties closer than 50 miles, and lower for properties
               farther than 100 miles away than for properties 50 to 100 miles
               away, in both cases by a factor of 0.34. (Because odds ratios are
               symmetric, this result implies that the odds on being inspected
               were about 2.9 times higher for properties closer than 50 miles
               than for properties 50 to 100 miles away, and about 3.4 times
               higher for properties 50 to 100 miles away than for properties
               farther than 100 miles away.)

               o The effect of the number of properties managed was not
               statistically significant when size and distance were taken into
               account. Our sample of properties is small for detecting any but
               fairly sizable effects, however, especially in a multivariate
               context, and the net effect of number of properties, while
               statistically insignificant, is sizable enough to warrant further
               attention (the adjusted linear odds ratio is 0.54).

    Appendix III: Comments from the Department of the Interior

    Note: Interior's technical comments are not included.

    Appendix IV: GAO Contact and Staff Acknowledgments

    GAO Contact

    Robin M. Nazzaro, (202) 512-3841, nazzaror@gao.gov

    Staff Acknowledgments

    In addition to the individual named above, Jeffery D. Malcolm, Assistant
    Director; Mark A. Braza; Ellen W. Chu; Richard P. Johnson; Alyssa M.
    Hundrup; Michael Krafve; Gretchen Snoey; and Arvin Wu make key
    contributions to this report. Also contributing to the report were
    Antoinette Capaccio, George H. Quinn Jr., Mark Ramage, Jena Y. Sinkfield,
    and Douglas M. Sloane.

    (360757)

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    [28]www.gao.gov/cgi-bin/getrpt?GAO-07-1092 .

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    Highlights of [29]GAO-07-1092 , a report to the Subcommittee on Interior,
    Environment, and Related Agencies, Committee on Appropriations, House of
    Representatives

    September 2007

    U.S. FISH AND WILDLIFE SERVICE

    Additional Flexibility Needed to Deal with Farmlands Received from the
    Department of Agriculture

    Over the past two decades, provisions of the Food Security Act of 1985,
    among others, have allowed the Department of Agriculture's Farm Service
    Agency in partnership with the Department of the Interior's U.S. Fish and
    Wildlife Service (Service) to add farmlands found to have important
    resources to the National Wildlife Refuge System. The Farm Service Agency
    transferred such farmlands to the Service through outright ownership ("fee
    simple") or through conservation easements. Individual farmlands are
    managed by the nearest refuge office.

    GAO was asked to examine (1) the extent of farmland received by the
    Service, (2) the extent to which the Service is currently managing its
    farmlands, and (3) alternatives for managing these lands. To answer these
    objectives, GAO visited five refuges and surveyed managers responsible for
    a random sample of 98 farmlands.

    [30]What GAO Recommends

    GAO recommends that the Service ensure that its records for all its
    farmlands are accurate and complete and that it develop a proposal to
    Congress seeking authority for additional flexibility in dealing with
    farmlands the Service determines may not be in the best interest of the
    National Wildlife Refuge System. In commenting on a draft of this report,
    the Department of the Interior concurred with GAO's recommendations.

    Since 1986, the Service reports that it has received at least 1,400
    conservation easement and fee-simple farmlands covering 132,000 acres, but
    the actual number is unknown because the Service's records are incomplete.
    Scattered across 38 states, these farmlands range in size from less than 1
    acre to more than 2,200 acres; most are smaller than 50 acres. In
    addition, GAO identified farmlands that were not reported by the Service
    headquarters or regional offices. Therefore, the numbers reported here
    represent a conservative estimate of the total acreage received from the
    Farm Service Agency.

    The Service is generally not managing a majority of its farmlands. In the
    past 5 years, only 13 percent have been inspected annually, on average.
    The Service is thus not adequately ensuring landowners' compliance with
    easement restrictions. GAO observed ongoing easement violations, including
    farming encroachment (see photo below). Few refuge offices track changes
    in land ownership, and basic maintenance has seldom been completed.
    Several factors have hindered the Service's farmland management. First,
    refuge officials do not emphasize managing most of the lands because they
    do not believe they contribute to the refuges' mission. Second,
    uncertainty about the extent or scope of some easements makes management
    activity difficult. Third, constrained resources and declining staff
    hinder completion of management activities. Nevertheless, GAO found that
    farmlands most closely aligned with refuge goals receive considerably more
    attention.

    The Service possesses limited alternatives for managing its farmlands.
    Alternatives include (1) resetting refuge priorities to ensure that
    farmlands are given management attention, (2) requesting additional
    resources, and (3) paying little or no management attention to the
    farmlands. The Service has in most cases chosen the third alternative, and
    refuge officials indicated that this approach is unlikely to change.
    Because these lands are part of the National Wildlife Refuge System, under
    current law the Service cannot dispose of unwanted farmlands, regardless
    of their value to the refuge system's mission. Consequently, the Service
    may need additional flexibility on a limited and short-term basis to
    resolve the issue of unwanted farmlands.

    Farming Encroachment in Violation of a Wetland Easement, April 2007

    References

    Visible links
      21. http://www.gao.gov/cgi-bin/getrpt?GAO-06-511
      22. http://www.gao.gov/
      23. http://www.gao.gov/
      24. http://www.gao.gov/fraudnet/fraudnet.htm
      25. mailto:fraudnet@gao.gov
      26. mailto:JarmonG@gao.gov
      27. mailto:BeckerS@gao.gov
      28. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1092
      29. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1092
    *** End of document. ***