[Audit Report on Cultural Resource Management, Bureau of Land Management]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 99-i-808

Title: Audit Report on Cultural Resource Management, Bureau of
       Land Management


Date:  September 03, 1999



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U.S. Department of the Interior
Office of Inspector General



AUDIT REPORT
CULTURAL RESOURCE MANAGEMENT,
BUREAU OF LAND MANAGEMENT



REPORT NO. 99-I-808

SEPTEMBER  1999




MEMORANDUM

             TO:  The Secretary

           FROM:  Earl E. Devaney
                  Inspector General

SUBJECT SUMMARY:  Final Audit Report - "Cultural 
                  Resource Management, Bureau of Land 
                  Management" (No. 99-i-808)

Attached for your information is a copy of the subject final
audit report.  The original audit objective was to determine
whether the Bureau of Land Management managed its cultural
properties and museum collections in accordance with applicable
laws, regulations, and policies.  However, because of the results
of the audit survey, we changed the audit objectives to evaluate
the status of cultural site surveys and to determine whether
museum collections were managed adequately.  This audit report is
the first report of two audit reports on the Bureau's  Cultural
Resource Management Program.

We concluded that the Bureau did not adequately survey the public
lands to determine the location and condition of cultural
resources and the Bureau therefore did not have the information
needed to protect undisclosed culturally significant sites on
public lands.  Also,  the Bureau did not adequately control and
account for its museum collections.  The ownership and the
location of artifacts and historical items were not determined,
new collections were not deposited timely with repositories,
required inventories were not completed, and agreements with
non-Federal museums regarding collection responsibilities were
not established.  Consequently, the Bureau had little assurance
that its museum collections were intact and safeguarded.

We made four recommendations to correct these weaknesses, and the
Bureau agreed with all of the recommendations.  Based on the
Bureau's response, we considered the four recommendations
resolved but not implemented.

If you have any questions concerning this matter, please contact
me at (202) 208-5745.


Attachment

cc: Chief of Staff
Assistant Secretary for Land and Minerals Management
Director, Office of Communications




                                                C-IN-BLM-003-98-D
Memorandum

     To:  Assistant Secretary for Land and Minerals Management

   From:  Robert J. Williams
          Assistant Inspector General for Audits

Subject:  Audit Report on Cultural Resource Management,
          Bureau of Land Management (No. 99-i-808)

This report presents the results of our audit of the Bureau of
Land Management's Cultural Resource Management Program.  The
original audit objective was to determine whether the Bureau
managed its cultural properties and museum collections in
accordance with applicable laws, regulations, and policies.
However, because of the results of the audit survey, we changed
the audit objectives to evaluate the status of cultural site
surveys and to determine whether museum collections were managed
adequately.  This audit report is the first report of two audit
reports on the Bureau's  Cultural Resource Management Program.

We found that the Bureau did not adequately survey the public
lands to determine the location, nature, and extent of culturally
significant sites.  Since 1970, the Bureau has comprehensively
surveyed less than 5 percent of its public lands for the presence
of cultural sites.  As a result, the Bureau does not know the
locations or the conditions of culturally significant sites on
public lands; therefore, the Bureau does not have the information
needed to protect these undisclosed cultural resources.

We also found that the Bureau did not adequately control and
account for its museum collections.  The ownership of artifacts
and historical items was not determined, new collected objects
were not deposited timely with repositories, required inventories
were not completed, and collection agreements were not
established with non-Federal repositories.  Consequently, the
Bureau had little assurance that its museum collections were
adequately managed.

In the July 20, 1999, response (Appendix 4) to the draft report
from the Acting Director, Bureau of Land Management, the Bureau
concurred with Recommendations A.1, B.1, and B.2 but did not
express specific concurrence or nonconcurrence with
Recommendation B.3.  Additionally, the Bureau provided
alternative approaches to Recommendations B.2 and B.3, which we
have revised to recognize the Bureau's suggested alternatives.
Based on the response and additional discussions and information
provided by Bureau officials on August 4, 1999, we considered all
four of the report's recommendations resolved but not
implemented.  Accordingly, the unimplemented recommendations will
be referred to the Assistant Secretary for Policy, Management and
Budget for tracking of implementation.

Since the report's recommendations are considered resolved, no
further response to the Office of Inspector General is required
(see Appendix 5).

The legislation, as amended, creating the Office of Inspector
General requires semiannual reporting to the Congress on all
audit reports issued, actions taken to implement audit
recommendations, and identification of each significant
recommendation on which corrective action has not been taken.

We appreciate the assistance of Bureau personnel in the conduct
of our audit.

CONTENTS

Page

INTRODUCTION..........................................1
BACKGROUND............................................1
OBJECTIVE AND SCOPE...................................2
PRIOR AUDIT COVERAGE..................................3

FINDINGS AND RECOMMENDATIONS..........................4

A.  CULTURAL SITE SURVEYS.............................4
B.  COLLECTIONS MANAGEMENT............................9

APPENDICES

1.  OFFICES AND SITES VISITED........................14
2.  ACRES SURVEYED AND CULTURAL SITE DENSITY.........16
3.  AUDIT REPORTS ISSUED RELATED TO THE BUREAU'S
     CULTURAL RESOURCE MANAGEMENT PROGRAM............17
4.  BUREAU OF LAND MANAGEMENT RESPONSE...............19
5.  STATUS OF AUDIT REPORT RECOMMENDATIONS...........23

INTRODUCTION

BACKGROUND

According to the Bureau of Land Management's "1998 Annual
Report," the Bureau is "steward for the federal government's
largest, most varied, and scientifically most important body of
archaeological and historical resources."  The Archaeological
Resources Protection Act of 1979 (16 U.S.C. 470aa) states that
"archaeological resources on public lands and Indian lands are an
accessible and irreplaceable part of the Nation's heritage" and
that archaeological resources and sites which are on public lands
should be protected for the present and future benefit of the
American people.  The Act requires that plans for surveying the
public lands be developed to determine the nature and extent of
archaeological resources on those lands and that a schedule for
surveying lands which are likely to contain the most
scientifically valuable archaeological resources be prepared for
the purpose of assessing the significance of the sites and
determining the measures needed to protect or preserve the
cultural resource.  According to the Bureau Manual (Bureau Manual
8100, "Cultural Resource Management"), a survey is "the
application of professional methods and techniques for field
inventory, used to locate and identify cultural properties."

The Bureau has surveyed about 13 million of the 264 million acres
of public lands it manages, primarily in 11 western states and
Alaska (see Table 1), for the presence of significant cultural
sites.  Approximately 221,000 cultural sites that have
archaeological and historical significance have been discovered
and recorded as of September 1998 out of an "estimated 4 to 4.5
million cultural properties"[1] existing on the public lands.
The Bureau is responsible for protecting,  preserving, and
holding in public trust cultural artifacts[2] derived from these
areas whether the items are excavated and removed from the sites
or remain undisturbed on the land.

As part of its stewardship of the public lands, the Bureau also
issues, in accordance with the Archaeological Resources
Protection Act of 1979 (16 U.S.C. 470cc and 470ee), permits[3] to
museums, universities, research institutions, and accredited
individuals to survey the public lands for artifacts and
significant cultural sites.  Permits for cultural site surveys
may also be issued to private archaeological consultants to
survey and discover any cultural resources that may be disturbed
by activities such as drilling operations or access road
construction by oil and gas companies on Bureau-managed lands.
According to the Bureau Manual (Section 8130), permits require
that the permit holders have an agreement with a Bureau- approved
repository,[4] such as a university or a museum, to accept and
curate all artifacts found as a result of any activities on
Bureau-managed land.  Bureau archaeologists perform similar work
by surveying Bureau lands prior to any (Federal) undertaking[5]
where the land will be disturbed and cultural sites could be
degraded or destroyed.  Bureau archaeologists also perform
proactive self-initiated surveys of Bureau-managed lands in areas
potentially rich in cultural resources to document the discovery
and the status of previously unknown cultural sites.

According to Bureau officials, the Bureau and its predecessor
organization, the General Land Office, authorized the
transportation over the past 186 years of more than 20 million
objects[6] collected from the public lands to about 189
professional non-Federal repositories, including museums,
universities, and historical societies located in 34 states and
Canada.  Additionally, the Bureau maintains about 3.5 million
museum objects located primarily in two Bureau museum facilities:
the Anasazi Heritage Center in Dolores, Colorado, and the
Billings Curation Center in Billings, Montana.

Artifacts and objects at these museums are to be inventoried,
cataloged, evaluated, and stored by the museums for purposes of
research, instruction, and exhibit.  The Code of Federal
Regulations (36 CFR 79.5) requires agency officials to be
"responsible for the long-term management and preservation" of
these museum collections.  Additionally, the Departmental Manual
(411 DM, "Policies and Standards for Managing Museum
Collections") requires the Bureau to inventory annually  both
Federal and non-Federal repository museum collections.  According
to Departmental and Bureau officials, inventory completion has
been hampered because the historical records for many collections
were found to be incomplete or "not well documented."

OBJECTIVE AND SCOPE

The original objective of the audit was to determine whether the
Bureau of Land Management managed its cultural properties and
museum collections in accordance with applicable laws,
regulations, and policies.  Based on the results of our audit
survey, we changed the audit objectives to evaluate the status of
cultural site surveys and to determine whether museum collections
were managed adequately.  This audit report is the first report
of two audit reports on the Bureau's  Cultural Resource
Management Program.

To accomplish our objective, we visited the Bureau's
Headquarters, the Bureau's National Curator, 3 Bureau state
offices, 16 Bureau field offices, 10 museums or exhibits, a
national park, and a state historic preservation office.
Additionally, we visited officials in the Department's Office of
Acquisition and Property Management regarding the Departmental
Interior Museum Program, and we contacted other offices and
officials as needed to accomplish the revised objective (offices
and sites visited are in Appendix 1).  During these visits and
contacts, we interviewed Bureau officials and field-level staff
responsible for operating the Cultural Resource Management
Program, and we observed cultural sites or museum collections at
or near these locations.

Our audit, which was conducted from June 1998 through January
1999,  was made, as applicable, in accordance with the
"Government Auditing Standards," issued by the Comptroller
General of the United States.  Accordingly, we included such
tests of records and other auditing procedures that were
considered necessary to accomplish our audit objectives.  As part
of our review, we evaluated the system of internal controls to
the extent that we considered necessary.  We found internal
control weaknesses in the Bureau's procedures for surveying the
public lands and for controlling and accounting for its museum
collections.  These internal control weaknesses are discussed in
the Findings and Recommendations section of this report.  Our
recommendations, if implemented, should improve the internal
controls in these areas. 

We also reviewed the Departmental Report on Accountability for
fiscal year 1998, which includes information required by the
Federal Managers' Financial Integrity Act of 1982, and the
Bureau's 1998 Annual Report to determine whether any reported
weaknesses were within the objective and scope of our review.
Neither report identified weaknesses in the Bureau's Cultural
Resource Management Program.  However, the Departmental Report
cited the "lack of accountability and control over artwork and
artifacts" as a Departmentwide mission critical material
weakness, which is directly related to the issues discussed in
this report.

PRIOR AUDIT COVERAGE

Neither the Office of Inspector General nor the General
Accounting Office has issued any audit  reports during the past 5
years concerning the Bureau's Cultural Resource Management
Program.  However, the Office of  Inspector General issued four
reports in 1990 and 1991 and the General Accounting Office issued
a report in 1987 that related to the Bureau's Cultural Resource
Management Program (see Appendix 3).

**FOOTNOTES**

[1]:Reported in the Bureau of Land Management's 1998 Annual
Report.

[2]:According to Bureau Manual 8100, a cultural artifact is "any
object that shows evidence of human manufacture, modification, or
use." 

[3]:Section 6(a) of the Archaeological Resources Protection Act
of 1979 states, "No person may excavate, remove, damage, or
otherwise alter or deface any archaeological resource located on
public lands or Indian lands unless such activity is pursuant to
a permit."

[4]:The Code of Federal Regulations (36 CFR 79.4) defines a
repository as "a facility such as a museum, archeological center,
laboratory or storage facility managed by a university, college,
museum, other educational or scientific institution, a Federal,
State of [or] local Government agency or Indian tribe that can
provide professional, systematic and accountable curatorial
services on a long-term basis." 

[5]:Bureau Manual 8100 defines an undertaking as "Bureau
[initiated] direct actions or non-Bureau actions carried out
under the sanction of Bureau licenses, leases, permits, or other
authorization" that may cause disturbance to the land which could
adversely impact cultural resources, such as construction of a
stock pond for wildlife management purposes in an area of known
archaeological resource sites.

[6]:The Bureau's budget justification for fiscal year 1997 stated
that "more than 3 million objects are curated in BLM [Bureau of
Land Management] facilities, and approximately 21 million are
housed in . . . non-Federal repositories."

FINDINGS AND RECOMMENDATIONS

A.  CULTURAL SITE SURVEYS

The Bureau of Land Management did not adequately determine the
location, nature, and extent of culturally significant sites on
Bureau-managed public lands.  Specifically, since 1970, the
Bureau has comprehensively surveyed less than 5 percent of its
public lands for the presence of cultural sites.  Surveying
public lands for cultural sites to determine the nature and
extent of archaeological resources on those lands is mandated by
the Archaeological Resources Protection Act (16 U.S.C. 470ii), as
amended, and Executive Order No. 11593, Protection and
Enhancement of the Cultural Environment.  These deficiencies
occurred because Bureau managers did not allocate the staffing
and funding necessary to adequately plan, prioritize, schedule,
or ensure completion of a Bureauwide surveying effort.  As a
result, the Bureau did not know the locations or the conditions
of an  estimated 3.8 million (4 million estimated less .2 million
recorded) culturally significant sites on public lands (see
Appendix 2).  Therefore, the Bureau did not have the information
needed to protect these undisclosed cultural resources.

Prior Conditions

During 1990 and 1991, the Office of Inspector General issued four
reports on selected Bureau programs, including the Cultural
Resource Management Programs, in four states (Alaska, California,
Colorado, and New Mexico) that identified the lack of adequate
cultural site surveys as a deficiency.  This condition was also
reported to the Bureau by the General Accounting Office in its
1987 report.  In responses to these reports, the Bureau generally
stated that it would develop an overall strategy and plans to
identify significant cultural sites, seek funding to accomplish
the work, and give added priority to the Program.

During our current audit, we found that the Bureau had not
implemented an overall strategy for ensuring the completion of
surveys of the public lands for cultural resources.  In addition,
the Bureau needed to improve its efforts when completing cultural
site surveys of public lands.  For example, the Four Corners
area[7] has a high density of important and culturally
significant resources.  However, over a 28-year period,[8] the
Bureau had surveyed less than 6 percent (1.3 million of 22.9
million acres) of the public land in the State of Utah for the
presence of cultural sites.  Similarly, in Arizona, the Bureau
had surveyed less than 5  percent of its public lands for
cultural sites.  The status of cultural site surveys of
Bureau-managed public lands is in Table 1.

**FOOTNOTES**

[7]:The common corner of Utah, Colorado, Arizona, and New Mexico,
which is an area where "the surrounding  BLM [Bureau of Land
Management] managed lands contain thousands of other significant
[cultural] sites." ("Four Corners Cultural Resource Proposal,"
Bureau of Land Management, 1990)

[8]:Fiscal years 1970 through 1997.

Table 1.   Public Lands Surveyed
(As of September 1997)

State               Public Land   Acres Surveyed*Public Land
Surveyed
(Acres)                       (Percent)

Alaska  86,908,060          76,910             0.1
Arizona 14,252,778         634,447             4.5
California14,556,074     1,509,764            10.4
Colorado 8,296,512       1,154,526            13.9
Eastern States1,531,548     10,225             0.1
Idaho   11,847,328       1,610,352            13.6
Montana  8,060,382       1,104,340            13.7
Nevada  47,840,569       1,591,575             3.3
New Mexico12,770,569     1,050,182             8.2
Oregon**16,603,849       1,138,424             6.9
Utah    22,877,663       1,307,412             5.7
Wyoming 18,383,926       1,735,780             9.4

Bureauwide263,929,258   12,923,937   (Average) 4.9

*Annual and summary data of surveys completed by state during
1970 through 1997 were provided by the Bureau.

**State of Oregon data include Bureau-managed lands in the State
of Washington.

We found that the work (ranging from 70 to 99 percent of the work
load) of Bureau archaeologists in the offices we visited involved
administrative actions required prior to beginning Federal
undertakings, such as road construction, or involved providing
oversight of permit holders that are using the public lands.
Bureau officials at the offices we visited consistently stated
that minimal time was devoted to identifying and protecting
cultural sites  on the many acres of unsurveyed land that the
Bureau manages.  In that regard, we found that proactive
self-initiated surveys of the public lands were seldom conducted
because of the substantial work load related to Federal
undertakings.  For example, in areas such as the Cedar City
(Utah) Field Office and the Little Snake (Colorado) Field Office,
Bureau officials stated that no self-initiated surveys had been
accomplished during the past 15 years.

According to Bureau personnel, surveys were not conducted because
of inadequate Program staffing assigned to Cultural Resource
Management activities.  A comparison of programmatic data related
to Cultural Resource Management activities for the Bureau of Land
Management, the National Park Service, and the U.S. Department of
Agriculture's U.S. Forest Service is in Figure 1.







Figure 1.   Budget Data for Similar Agencies

(For Cultural Resource Management Activities* in Fiscal Year
1998)

*Excludes the National Park Service's Cultural Resources Applied
Research, National Register, and Center for Preservation
Technology and Training Programs, as well as grants issued
pursuant to the United States Code (25 U.S.C. 3001).

As shown in Figure 1, although the Bureau of Land Management has
significantly more acreage to oversee, fewer resources were
allocated, both staffing and funding, to accomplish the Cultural
Resource Management mission.  Further, at the field offices
visited, archaeologists said that cultural sites on the public
lands were adversely[9] affected by activities such as theft,
vandalism, destruction, deterioration, and overuse.  However, the
Bureau continued to issue land-use authorizations, such as
easements, leases, permits, or rights-of-way, for specific
commercial and recreational purposes or allowed mostly
unrestricted access to lands that contain sensitive cultural
resource sites. 

For example, officials at the Moab (Utah) Field Office estimated
that only 63,000 (3 percent) of its 2.1 million acres had been
surveyed for cultural sites, and the Kanab Utah Field Office
estimated that only 135,000 (5 percent) of its 2.7 million
acres[10] had been surveyed.  Archaeologists in these field
offices estimated that about 157,000 archaeological sites were
present but were undiscovered and unrecorded because the site
surveys had not been accomplished.  Officials in these field
offices also attributed the lack of surveys to the substantial
work load related to Federal undertakings and inadequate
allocation of staffing and funding, both of which prevented the
Bureau archaeologists from conducting the needed surveys.

Although we recognize the difficulty in trying to both identify
and protect sensitive cultural sites while also attempting to
promote multiple uses[11] of the public lands, we believe that
the Bureau should devote the necessary staffing and funding to
determine the location and the significance of the important
cultural, archaeological, and historic sites on the public lands.

Recommendation

We recommend that the Director, Bureau of Land Management,
develop and implement a Bureauwide long-range surveying plan for
cultural sites which prioritizes those areas that have the most
cultural significance.  Once the plan is established, the Bureau
should seek funding needed to systematically complete the surveys
of the prioritized public land areas.

Bureau of Land Management Response and Office of Inspector Reply

In the July 20, 1999, response (Appendix 4) to the draft report
from the Acting Director, Bureau of Land Management, the Bureau
concurred with the recommendation.  Based on the response, we
consider the recommendation resolved but not implemented (see
Appendix 5).

In its response, the Bureau also stated that it had surveyed more
than 13 million acres and recorded more than 220,000 cultural
properties and that "[g]iven funding and personnel restrictions
this would appear to be substantial progress."  The Bureau also
stated, "The finding does not make clear what [cultural survey]
standard is being employed to determine what is adequate."

Although we agree that the number of surveyed acres and recorded
properties appears to be substantial, the report states that the
Bureau has surveyed only 5 percent of its lands since the
requirement to survey the public lands was established about 28
years ago.  Furthermore, the Bureau has not planned and
prioritized its surveying efforts in areas known to have a high
density of significant cultural sites.  Most of the completed
surveys were conducted pursuant to Federal undertakings and were
not the result of proactive survey planning efforts.  We
recognize that the Bureau's limited funding and staffing
allocations have affected its ability to perform public land
surveys.  However, these resource constraints are further
indications of the need for the Bureau to plan and schedule on a
prioritized basis a Bureauwide surveying effort to locate the
estimated 3.8 million cultural sites on the public lands.
Accordingly, we believe that the Bureau should devote the
necessary staffing and funds needed to determine the location and
the significance of cultural, archaeological, and historic sites
on the public lands (prioritized by the Bureau's standard).

**FOOTNOTES**

[9]:Bureau Manual 8100 defines an adverse effect as an
"alteration of the characteristics of a cultural property that
may qualify it for the National Register [of Historic Places],
thereby reducing or eliminating the resource's use potential,
diminishing its integrity, or disqualifying it from Register
eligibility."  

[10]:The 2.7 million acres include 1.7 million acres within the
boundaries of the Grand Staircase-Escalante National Monument.  

[11]:The Federal Land Policy and Management Act of 1976, Public
Law 94-579, defines multiple use as "the management of the public
lands and their various resource values so that they are utilized
in the combination that will best meet the present and future
needs of the American people."  

B.  COLLECTIONS MANAGEMENT

The Bureau did not adequately control and account for its
collections of museum artifacts and historical items.
Specifically, ownership of artifacts was not adequately
determined, collected artifacts were not deposited timely with
repositories, required annual inventories were not conducted, and
written repository collection agreements were not established.
Requirements, guidance, and procedures for the management of
museum collections are contained in the Code of Federal
Regulations (36 CFR 79, "Curation of Federally-Owned and
Administered Archeological Collections") and the Departmental
Manual (Part 411, "Policies and Standards for Managing Museum
Collections").  These conditions occurred because the Bureau had
not finalized and implemented a Bureauwide museum Collections
Management Plan that met the requirements of the Departmental
Manual.  As a result, the Bureau had little assurance that its
museum collections were adequately maintained for future use.

Control and Accountability

At three of the five non-Federal repositories visited (see
Appendix 1), we found that the ownership of collected objects
could not be adequately determined.  Museum officials stated that
there frequently was no clear record of the source (such as
public land) of the collected items and that items coming from
public lands were not always identified as property originating
from public lands.  Also, items collected from public lands were
not always sent to the designated repositories, and artifacts
collected from public lands were not turned in for curation at
museums in a timely manner.  For example, use permits issued for
cultural purposes by the Bureau's Colorado State Office require
the permittee (archaeologist or collector) to submit, within 180
days of the completion of fieldwork, a final report to Bureau
officials of field activities.  The permit also requires the
permitee to deposit all artifacts, samples, and collections and
copies of all records, data, photographs, and other documents
resulting from work conducted under the permit with an acceptable
(to the Bureau) curatorial facility within 90 days after the
final report is submitted to the Bureau (270 total days).
However, Bureau personnel stated that compliance with these
procedures was not monitored or enforced and that some
collections had not been deposited with a repository for up to 6
years after fieldwork was completed.  

Additionally, the Code of Federal Regulations (36 CFR 79) and the
Departmental Manual (411 DM 3.4C, "Inventory Standards") specify
the type and scope of required inventories of museum property and
provide for exceptions and alternative methods for completing the
inventories.  Specifically, Chapter 3.4C states, "Annual
Inventories.  Bureaus must physically verify, or verify in
writing through appropriate instruments, the presence and
condition of museum property listed in the inventory for property
located in both Federal and non-Federal repositories."  However,
the Bureau did not have a museum inventory procedure; thus,
annual inventories were not conducted.

We also found that the Bureau had established written repository
collection agreements with only 24 (21 percent) of the 115
museums we reviewed.  The non-Federal repositories used by the
Bureau in 11 western states and Alaska and the repositories that
had a written agreement with the Bureau regarding their
responsibilities with respect to items originating from
Bureau-managed public lands are listed in Table 2.

Table 2.  Non-Federal Repository Agreements by State
(as of September 1998)

Number of        Number of
State          Repositories      Agreements

Alaska               5               3
Arizona              7               0
California          41               0
Colorado            15               1
Idaho                4               4
Montana              8               6*
Nevada               8               1
New Mexico           8               1
Oregon **            5               3
Utah                10               3
Wyoming              4               2

Totals             115              24

*Agreements are for specific objects managed by the Bureau's
Billings Curation Center.

**State of Oregon data includes data for the State of Washington.


The Code of Federal Regulations (36 CFR 79.8) provides guidelines
for the terms and conditions that Federal agencies may include in
any contracts, memoranda, agreements, or other written
instruments with repositories for curatorial services, such as
(1) identification of the collection or group of collections; (2)
statement that identifies ownership or jurisdiction over the
collection; (3) statement of work to be performed by the
repository; (4) Federal agency responsibilities; (5) duration of
the agreement and procedures for modification, suspension,
extension, and termination; (6) costs associated with the
agreement; and (7) statement that specifies the frequency of and
methods for conducting and documenting inspections and
inventories as stipulated in the Code of Federal Regulations (36
CFR 79.11).  The Code (36 CFR 79, Appendix 2) also contains an
example of a memorandum of understanding between a Federal agency
and a repository for long-term curatorial services for a
Federally owned collection.

Repository agreements should be used as a basis for any actions a
museum takes with respect to the management of the collections it
holds.  We believe that executing and following the terms of
written repository agreements with all non-Federal repositories
that have Bureau collections would improve collections management
efforts Bureauwide.

Departmentwide Material Weakness

Since 1990, the Department of the Interior has categorized the
"lack of accountability and control over artwork and artifacts"
as a Departmentwide mission critical material weakness in its
annual Reports on Accountability.  Accordingly, the Department
has initiated actions to establish organizational
responsibilities and time frames to ensure that the weakness is
corrected throughout the Department.  However, officials in the
Department's Office of Acquisition and Property Management stated
that the Bureau of Land Management had been attempting for about
6 years to develop a Collections Management Plan to help ensure
control over museum collections.  During our review, Departmental
officials said that the current plan is still unacceptable to the
Department because it is not in compliance with criteria
contained in the Departmental Manual (DM 411)[12] related to
overall strategies and priorities for achieving the stated goals,
such as assessing the size and status of collections and defining
lines of authority and personnel needs.  We believe that the
timely issuance and implementation of a Collections Management
Plan that meets Departmental requirements will assist the Bureau
in gaining control of and providing better accountability for its
museum collections.

Bureau Actions

During our audit, we noted that the Bureau of Land Management had
taken actions to improve the efficiency of its Cultural Resource
Management Program.  For example,  it ratified a National
Programmatic Agreement with the National Conference of State
Historic Preservation Officers and the Advisory Council on
Historic Preservation, and it participated in a Cultural Resource
Data Sharing Project with states and other agencies.

National Programmatic Agreement.  The National Programmatic
Agreement streamlines the Bureau's process for complying with the
National Historic Preservation Act (primarily Section 106).  The
Agreement authorizes, within specific stipulations,  Bureau
officials to proceed with Section 106 clearance actions and
approvals of Federal undertakings without specific review by the
applicable state Historic Preservation Officer and the Advisory
Council on Historic Preservation.  This process results in
Federal undertakings being approved faster than under previous
procedures.  Since these types of actions (Section 106
clearances) are a significant portion of the archaeologists' work
load at the field-office level, we believe that implementation of
the National Programmatic Agreement should allow Bureau staff
more time for other Cultural Resource Program responsibilities,
such as resource protection efforts or proactive site surveys of
the public lands.

Data Sharing Project.  The Bureau and the state Historic
Preservation Officers in 11 western states and Alaska have
initiated long-term cooperative agreements to improve the use of
automation for compiling and maintaining cultural site inventory
data.  These agreements provide for sharing goals, resources, and
expertise, with the objective of developing automated cultural
resources databases and electronic mapping systems that can be
used to better identify and help to preserve the Nation's
cultural resources.  This overall effort includes many related
initiatives among the various states, such as development of data
standards, data and map accessability via Internet connectivity,
and cooperative data entry support.  The benefits of the Data
Sharing Project include improved data quantity and quality;
streamlined work-flow processes; and cooperative use of
technological advances, such as geographic information systems
and spatial database concepts.

Recommendations

We recommend that the Director, Bureau of Land Management:

1. Ensure that the Bureau develops and implements in a timely
manner a Collections Management Plan which is in compliance with
Departmental property management requirements.

2. Ensure that the Bureau's revised Collections Management Plan
includes procedures for permittee and repository confirmation to
the Bureau of receipt of Federal (Bureau) collections, including
a brief description of the collected objects.  Also, both Federal
(Bureau) and non-Federal repositories should be requested to
identify, in accordance with the repositories' capabilities, the
Federal (Bureau) collections.  Thereafter, the reported inventory
information should be validated periodically.

3. Contact all Bureau Museum Partnership Program repositories to
determine the feasibility of initiating repository agreements
regarding the management of Federal (Bureau) collections.  Also,
written repository agreements should be developed and executed
with those non-Federal repositories willing to participate in a
repository agreement process.

Bureau of Land Management Response and Office of Inspector Reply

In the July 20, 1999, response (Appendix 4) to the draft report
from the Acting Director, Bureau of Land Management, the Bureau
concurred with Recommendation 1, stated both concurrence and
partial concurrence with Recommendation 2, and did not
specifically concur or express nonconcurrence with Recommendation
3.  Additionally, the Bureau provided an alternative approach to
Recommendations 2 and 3.

The Bureau's suggested approach to Recommendation 2 involves (1)
requiring that permittees and repositories report the receipt of
newly accepted Federally owned collections to the Bureau and (2)
requesting repositories to identify (inventory) their collections
and periodically conduct Bureau validations of the reported
inventories.  We believe that these suggested changes to the
recommendation, if made, will correct the weaknesses in the
Bureau's inventory and control of its museum collections.  The
Bureau's suggested approach to Recommendation 3 involves
initiating repository agreements only with those non-Federal
repositories that voluntarily agree to participate in a
repository agreement process.  We believe that this approach, if
implemented, can be effective in improving accountability over
the Bureau-managed museum collections.  

Based on the Bureau's suggested alternatives, we have revised
Recommendations 2 and 3 in the final report and consider the
alternatives to be fully responsive to the finding and the
recommendations.  Further, Bureau officials provided additional
information on August 4, 1999, which indicated their concurrence
with the revised recommendations and identified the official
responsible for implementation.  The Bureau also stated that the
finalized Collections Management Plan would include target dates
for implementation of the recommendations.  Therefore, we
consider Recommendations 1, 2, and 3 resolved but not implemented
(see Appendix 5).

**FOOTNOTES**

[12]:The Departmental Manual (411 DM 2) requires bureau-level
planning to address the needs of all bureaus' museum property,
including identifying priorities, strategies, and policies for
managing museum property.  Required documentation includes a
Collection Management Plan that identifies problems with
collections management, corrective actions and respective
priority, responsible officials, and cost estimates for the
corrective actions.

APPENDIX 1
Page 1 of 2

OFFICES AND SITES VISITED

Offices and Sites Visited or Contacted   Location

Department of the Interior Assistant Secretary for Policy,
Management and Budget
Office of Acquisition and Property
Management                         Washington, D.C.

Bureau of Land Management
Headquarters
Cultural Resource Management Office..Washington, D.C.
National Curator                Sacramento, California
Alaska State Office*            Anchorage, Alaska
Arizona State Office*           Phoenix, Arizona
California State Office*        Sacramento, California
Colorado State Office           Lakewood, Colorado
Anasazi Heritage Center         Dolores, Colorado
Kremmling Field Office          Kremmling, Colorado
Glenwood Springs Field Office   Glenwood Springs, Colorado
Gunnison Basin Field Office     Gunnison, Colorado
Little Snake Field Office       Craig, Colorado
Royal Gorge Field Office        Canon City, Colorado
San Juan Field Office           Durango, Colorado
San Luis Field Office           Alamosa, Colorado
Saguache Field Office**         Saguache, Colorado
Uncompahgre Basin Field Office  Montrose, Colorado
White River Field Office*       Meeker, Colorado
Idaho State Office*             Boise, Idaho
Cascade Field Office*           Boise, Idaho 
Jarbidge Field Office*          Twin Falls, Idaho
New Mexico State Office*        Santa Fe, New Mexico 
Farmington Field Office         Farmington, New Mexico
Montana State Office            Billings, Montana
Billings Curation Center        Billings, Montana
Billings Field Office           Billings, Montana 
Pompeys Pillar National Historic
Landmark                        Custer, Montana
Powder River Field Office       Miles City, Montana
Nevada State Office*            Reno Nevada
________________________

*Office contacted.

**"Service First" office shared with U.S. Forest Service.


APPENDIX 1
Page 2 of 2

Offices and Sites Visited (Continued)      Location 

Oregon State Office*                Portland, Oregon
Spokane Field Office*               Spokane, Washington
Utah State Office                   Salt Lake City, Utah
Cedar City Field Office             Cedar City, Utah
Grand Staircase-Escalante           National Monument Cedar City, 
                                    Utah
Kanab Field Office                  Kanab, Utah
Moab Field Office                   Moab, Utah
San Juan Field Office               Monticello, Utah
Wyoming State Office*               Cheyenne, Wyoming

National Park Service
Mesa Verde National Park            Colorado

U.S. Army Corps of Engineers
Mandatory Center of Expertise for
Archaeological Curation and 
Collections Management*             St. Louis, Missouri
U.S. General Accounting Office*     Denver, Colorado

State of Colorado
State Historic Preservation Office  Denver, Colorado

State of Wyoming                    State Historic
 Preservation                       Office* Cheyenne, Wyoming

Non-Federal Repositories:
Colorado State University           Fort Collins, Colorado
Denver Museum of Natural History*   Denver, Colorado
Museum of Western Colorado          Grand Junction, Colorado
Pioneer Museum                      Colorado Springs, Colorado
University of Denver                Denver, Colorado
University of Southern Colorado     Pueblo, Colorado

Museums/Exhibits With Collections Borrowed
From the Bureau of Land Management
First Interstate Bank of Billings  Billings, Montana
Prairie County Museum              Terry, Montana

ACRES SURVEYED AND CULTURAL SITE DENSITY[1]
(For selected field office acreage) 

Public Number of Archaeological Sites   
Land Percent Sites Per  Resource Area/Field Office     Acres
Surveyed Square Mile In Area Recorded Unrecorded

Big Dry, Montana
1,703,730        5      4        9,750         650      9,100

Billings, Montana
402,064          6      14      8,500         581       7,919

Cedar City, Utah
2,500,000        5      12       46,875       2,500     44,375

Grand Staircase-Escalante National Monument, Utah
1,700,000        5      202      53,125       1,082     52,043

Jarbidge, Idaho
1,550,000       14       9       18,900       3,000     15,900

Kanab, Utah
1,000,000        5    20[2]      31,250         579     30,671

Kremmling, Colorado
398,275          3       5        6,130       3,000      3,130

Little Snake, Colorado
1,300,000        3      17       34,500       5,000     29,500

Moab, Utah
2,100,000        3      24       80,000       5,000     75,000

Powder River, Montana 
1,080,675        5      25       42,000       4,500     37,500

San Juan, Colorado 
994,000          12   100[3]     173,000      20,740    152,260

San Juan, Utah
1,800,000        10      89      250,000      21,410    228,590

Uncompahgre Basin, Colorado
919,000          10      55       75,000       9,000     66,000

Bureauwide (all states)
263,929,258      4.9     9.7 4,000,000[4]    221,000  3,779,000


**FOOTNOTES**

[1]:All field office figures are "best estimates" by Bureau
officials.

[2]:"Best estimate" was reported as 20 to 50.

[3]:"Best estimate" was reported as 100 to 200.

[4]:Reported as 4 million to 4.5 million in the Bureau of Land
Management's 1998 Annual Report.


APPENDIX 3
Page 1 of 2

PRIOR REPORTS ISSUED RELATED TO THE
BUREAU'S CULTURAL RESOURCE MANAGEMENT PROGRAM

The Office of Inspector General has issued four prior reports on
the Bureau of Land Management's Cultural Resource Management
Program as follows:

- "Survey of Selected Programs of the Colorado State Office,
Bureau of Land Management" (No. 90-64), issued in April 1990,
stated that five Bureau resource areas did not perform surveys to
determine what cultural resources needed management oversight and
that the Bureau had not allocated sufficient personnel and
financial resources to comply with the existing priority mandates
in a timely manner.  The report recommended that the Bureau
develop an overall management strategy for identifying,
protecting, and managing cultural resources.

- "Survey of Selected Programs of the Alaska State Office, Bureau
of Land Management" (No. 90-84), issued in July 1990, stated that
three Bureau district offices had not performed the required
inventories to identify cultural resources on public lands and
that the Bureau had not allocated sufficient personnel and
financial resources to comply with the existing mandates.  The
report recommended that the Bureau develop an overall strategy
for identifying, protecting, and managing cultural resources in
Alaska. 

- "Survey of Selected Programs of the New Mexico State Office,
Bureau of Land Management" (No. 91-I-198), issued in November
1990, stated that lands had not been inventoried, cultural
resource sites had not been adequately protected, and artifacts
removed from cultural resource sites had not been accounted for.
Furthermore, the report stated that the Bureau had not allocated
sufficient personnel and financial resources to comply with
existing mandates.  The report recommended that the Bureau
develop and implement an overall strategy that provides for
inventorying, protecting, and accounting for cultural resources. 

- "Survey of Selected Activities of the California State Office,
Bureau of Land Management" (No. 91-I-654), issued in March 1991,
stated that 10 resource areas had not completed required
inventories to identify cultural resources and that the Bureau
had only partially accounted for artifacts removed from cultural
resource sites.  The report also stated that the Bureau had not
allocated sufficient personnel and financial resources to comply
with existing mandates.  The report recommended that the Bureau
develop and implement a strategy for cultural resources in
California.


APPENDIX 3
Page 2 of 2

The General Accounting Office, in December 1987, issued the
report "Cultural Resources, Problems Protecting and Preserving
Federal Archeological Resources" (No. GAO/RCED-88-3).  The report
stated that agencies could make more efficient and effective use
of the funds and staff resources which were available for
protecting their archeological sites if they had more information
on the number, location, and relative significance of these
sites.  The report also stated that most of the surveys
undertaken to identify sites were conducted to obtain clearances
for development projects and that they therefore were not
necessarily directed to those areas which had the greatest
potential for having important archeological resources.  The
report recommended that the respective agencies develop plans for
surveying those areas which were not scheduled for project
development and ensure that a "reasonable number" of these
surveys are performed each year.

APPENDIX 4
Page 1 of 4

APPENDIX 4
Page 2 of 4

APPENDIX 4
Page 3 of 4

APPENDIX 4
Page 4 of 4

APPENDIX 5

STATUS OF AUDIT REPORT RECOMMENDATIONS

Finding/Recommendation
Reference
Status
Actions Required

A.1Resolved; not implemented.
No further response to the Office of Inspector General is
required.  The recommendation will be referred to the Assistant
Secretary for Policy, Management and Budget for tracking of
implementation.

B.1, B.2, and B.3Resolved; not implemented. No further response
to the Office of Inspector General is required.  The
recommendations will be referred to the Assistant Secretary for
Policy, Management and Budget for tracking  of implementation.




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TO THE OFFICE OF INSPECTOR GENERAL BY:

Sending written documents to:



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