Rangeland Management: BLM Efforts to Prevent Unauthorized Livestock Grazing Need Strengthening

Published by the Government Accountability Office on 1990-12-07.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

       ~hv’4~llltM~I’ I!)!10
                                    BLM Efforts to
                                    Prevent Unauthorized
                                    Livestock Grazing
                                    Need Strengthening


                                                      Not to be release outside the
                                    General Accounting Offlce unless specifically
                                    approved by the OffIce of Congressional

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                   United States
GAO                General Accounting Office
                   Washington, D.C. 20648

                   Resources, Community, and
                   Economic Development Division


                   December 7, 1990

                   The Honorable Bruce F. Vento
                   Chairman, Subcommittee on National
                      Parks and Public Lands
                   Committee on Interior and
                      Insular Affairs
                   IIouse of Representatives

                   Dear Mr. Chairman:

                   This report responds to your February 28,1989, request that we
                   examine the efforts of the Department of the Interior’s Bureau of Land
                   Management (BLM) to detect and deter unauthorized livestock grazing on
                   public rangelands. Unauthorized grazing-referred to by BLM as grazing
                   trespass-can take several forms, including grazing more livestock than
                   allowed by permit, grazing in areas that are closed to livestock, or
                   grazing during unauthorized times of the year.

                   An effective trespass enforcement program must offer reasonable assur-
Results in Brief   ance that offendeks, especially willful ones, (1) will be detected and (2)
                   when detected, will be assessed an appropriate penalty not only to
                   penalize them but also to deter others from trespassing. BLM’S trespass
                   enforcement efforts do not meet either of these requirements.

                   Because many grazing areas are inspected infrequently or not at all
                   during the year, offenders are not likely to be detected. When offenders
                   are detected, BLM frequently exacts no penalties’ and, for the more
                   serious violations, seldom assessesthe minimum penalties its own regu-
                   lations require. As a result, grazing trespass is not adequately deterred,
                   which can lead to degradation of public rangelands, among other things.

                   BLM staff attribute the shortfalls in trespass detection and deterrence
                   primarily to insufficient staff resources. While additional staff would
                   undoubtedly enable improved performance, more effective and aggres-
                   sive detection and deterrent efforts could be made within existing
                   staffing levels.

                   ‘The term “penalties” is used to include both the assessmentof damages and costs for violations, as
                   well as civil penalties such as suspension of a grazing permit.

                   Page 1                                      GAO/RCED-91-17     BLM Trespass Enforcement      Efforts

             Before 1934, livestock grazing on public rangelands was uncontrolled,
Background   and the lands were damaged by decades of overgrazing. W ith the pas-
             sage of the Tayior Grazing Act in I934 (43 USC. 315 et seq.), grazing
             became a regulated activity. However, because it was assumed that the
             lands would ultimately be transferred to private ownership, BLM'S
             approach to public lands management was relatively passive or

             In the face of continued rangelands deterioration, the Congress passed
             the Federal Land Policy and Management Act of 1976 (43 U.S.C. 1701 et
             seq.). The act established a federal commitment to (1) retain ownership
             of public lands, (2) improve deteriorated lands, and.(3) manage the
             lands in a manner that would ensure their productive capacity in
             perpetuity. The Public Rangelands Improvement Act of 1978 (43 U.S.C.
             1901 et seq.) reaffirmed the national policy to manage, maintain, and
             improve the condition of the public rangelands so that they become as
             productive as possible for all users.

             BLM manages nearly 162 million acres of rangelands in 16 western states
             and, among other duties, monitors vegetation and land conditions and
             oversees grazing operations. The rangelands are divided into about
             22,000 separate grazing units, generally referred to as allotments. The
             allotments are largely managed through renewable permits and leases to
             about 19,600 livestock operators. The permits and leases specify the
             number and type of livestock allowed on the allotments, the time and
             duration of use for grazing, and special conditions or use restrictions.
             BLM issues permits for up to 10 years, but it may alter, suspend, or
             cancel them if range conditions are being degraded or permit conditions
             are violated. In 1989, BLM charged operators $1.81 per animal unit
             month (AUM)~ to graze their livestock on public rangelands, which was
             considerably less than the commercial value of the forage.3

             In its range management guidance, BLM recognizes the importance of
             protecting against grazing trespass. Its Handbook on Unauthorized
             Grazing Use states that officials “must give priority to preventing and
             detecting unauthorized grazing use on the public lands.” BLM'S grazing
             regulations (43 C.F.R. 4100), establish three levels of grazing trespass-
             non-willful, willful, and repeated-willful-with   progressively harsher

             2An AUM is defined as the amount of forage neededto suppbrt a 1,000 pound cow, a horse, or five
             sheep for 1 month.

             3The commercial value for forage is determined annually by the U.S. Department of Agriculture and
             was established at $8.49 per AUM for 1989.

             Page 2                                     GAO/RCED-91-17 BLM Trespass Enforcement         Efforts

                             penalties for each level. For each non-willful trespass, the offender must
                             pay the commercial value of the forage consumed. For willful trespass,
                             the penalty increases to twice the commercial value of the forage con-
                             sumed plus charges for any damages to the land and BLM expenses
                             incurred to detect, investigate, and resolve the violation. In addition, for
                             either type of trespass, BLM may suspend or cancel all or portions of the
                             grazing permit. For repeated-willful trespass, the required penalty is
                             three times the commercial value of the forage consumed plus compen-
                             sation for applicable BLM violation-related expenses. BLM must also sus-
                             pend or cancel all or portions of the grazing permit.

                             Grazing trespass is occurring, but BLM'S detection efforts are not suffi-
Trespass Detection           cient to identify the extent of the problem. Management does not have a
Efforts Are Minimal          systematic method for detecting violations, and it does not allocate
                             resources specifically for trespass detection or categorize detection
                             efforts as a reportable accomplishment for field staff. Consequently,
                             many allotments are rarely or never visited during the year. This situa-
                             tion is made worse by staffing shortfalls, Even though BLM'S range staff
                             is too small for the amount of work to be done, we believe that BLM can
                             improve its detection efforts within current staffing levels.

Extent of Grazing Trespass   While the full extent of grazing trespass on BLM grazing allotments is not
                             known, it does occur, and GAO has documented-during this and other
Is Unknown                   reviews-grazing violations that BLM has not detected. For example, in a
                             1988 report on BLM'S management of riparian areas,4we noted several
                             instances of cattle trespass in these ecologically critical zones. During an
                             October 1987 BLM tour of a “showcase” riparian project in Nevada, for
                             example, we noted that a large number of cattle had broken a fence and
                             grazed the area to a “desert-like” condition. This trespass had not been
                             detected by BLM officials until our visit, and the officials stated that such
                             events are common.

                             We found another example of undetected grazing trespass in BLM files in
                             Oregon. A permittee’s grazing-use report indicated a higher grazing
                             level, different dates of use, and different types of livestock than
                             authorized by the permit. However, BLM staff had not compared the
                             grazing-use report with the grazing permit and were unaware of this

                             41’ublic Ran elands: Some Riparian Areas Restored but Widespread Improvement Will Be Slow
                             CeAO/ReEf5 _88_106 , June 30, 1988). Riparian areas are the narrow bands of green vegetation along
                             the banks of rivers and streams and around springs, bogs, lakes, and ponds that are crucial to the
                             overall ecological health of western rangelands.

                             Page 3                                     GAO/RCED-91-17    BLM Trespass Enforcement      Efforta

                             permit violation until we pointed it out. The BLM range supervisor
                             agreed that grazing trespass had occurred.

Staffing Shortfalls          According to BLM managers, the agency does not have enough range
Identified as a Major        staff to conduct a serious trespass detection program. Between 1981 and
                             1990, BLM range staff decreased by 25 percent, from 551 to 413. The BLM
Obstacle                     range management budget for fiscal year 1991 increased nearly $3.8
                             million over the previous year. However, at the time of our report, deci-
                             sions had not been made about how much, if any, of the additional
                             money would be used to increase the number of range management
                             staff. On average, each range staff member is now responsible for 47
                             permits and 392,000 acres of public rangelands. In our discussions with
                         b   range staff, we found that at least 26 were responsible for more than 1
                             million acres each, or an area about the size of Delaware.

                             Insufficient staffing has been identified as a problem in previous
                             reviews of BLM'S rangelands management. A 1986 report by Interior’s
                             Inspector General,6 as well as several previous GAO reports, have cited
                             the insufficient number of staff as a factor contributing to BLM'S difficul-
                             ties in fulfilling its grazing program objectives. (A list of related GAO
                             reports appears on the last page of this report.) Also, almost 60 percent
                             of the range staff we questioned said that more staff would greatly
                             improve grazing trespass detection.6

BLM Has No Systematic        While additional staff would undoubtedly be helpful, significant
Approach for Detecting       resource increases for trespass detection are not likely under today’s
                             budget limitations. Most improvements in trespass detection will depend
Grazing Trespass             on BLM’S more effectively using the resources it already has.

                             Currently, BLM has no systematic method for detecting grazing trespass,
                             such as visiting randomly selected allotments or targeting operators
                             with a history of noncompliance. Permittees and lessees,therefore,
                             operate essentially under an honor system, with little threat of compli-
                             ance checks. In many instances, allotments with grazing activity receive
                             few visits during the year or are not visited at all. For example, from

                             5Review of BLM’s Grazing Management and Range Improvement Programs, U.S. Department of the
                             Interior, Office of the Inspector General, Mar. 1986.
                             6BLM identified 414 range staff who could have direct responsibility for grazing trespass detection.
                             Our questionnaire was sent to a randomly selected sample of 201 of these staff, responseswere
                             received from 200, and 155 said they had direct responsibility for detecting grazing trespass.

                             Page 4                                      GAO/RCED-91-17      BLM Trespass Enforcement      Efforts

                          our survey of BLM range staff, we estimate that about 319 (+/- 19)
                          range staff have direct responsibility for detecting grazing trespass and
                          about 119 of them did not visit half or more of their grazing allotments
                          during fiscal year 1989. When range staff visit their allotments, it is
                          usually for a different purpose, and they generally make no concerted
                          effort to count the number of livestock or take other specific steps to
                          detect trespass. Given this level of effort devoted to trespass detection,
                          BLM is not in a position to gauge the full extent of trespass activity.

                          While BLM’S handbook says that preventing and detecting grazing tres-
                          pass on public rangelands is to be given priority, it receives much less
                          attention than other rangeland tasks and responsibilities, BLM has not
                          established trespass detection as a work-load measure for which field
                          office managers are held accountable, and the results of detection
                          efforts are not categorized as a reportable accomplishment. Conse-
                          quently, resources are not allocated specifically for grazing trespass
                          detection and range staff have very little incentive to conduct such

                          When detection efforts are or can be expected to be minimal, a strong
Penalties Applied by      deterrent can provide incentive for those being regulated to voluntarily
BLM Do Not Serve as       comply with regulations. Those who might consider willfully violating
an Adequate Deterrent     rules and regulations must believe that penalties outweigh the benefits
                          of violating grazing requirements. B&s trespass enforcement program
                          does little to instill such a belief. Most detected grazing trespass goes
                          unpunished and, for the more serious violations, BLM seldom assesses
                          even the minimum penalties required by its regulations. In a 1986
                          report, Interior’s Inspector General concluded that BLM field offices were
                          not diligent in pursuing and recovering all agency costs incurred for
                          trespass cases, as required by BLM regulations. That same year BLM'S
                          acting chief for the Division of Rangelands Resources reached the same
                          conclusion.7 However, we found this condition still prevalent during our

Most Trespass Incidents   In fiscal year 1989, BLM closed 345 formal trespass cases with penal-
Are ProcessedInformally   ties-259 non-willful, 77 willful, and 9 repeated-willful, However, on
                          the basis of our questionnaire results, we estimate that approximately
and Without Penalties     1,300 to 1,900 additional trespass incidents occurred in fiscal year 1989

                          7Fiscal Year 86 Alternative Internal Control Review, memorandum to BLM Internal Controls Coordi-
                          nator from Acting Chief, Division of RangelandsResources,July 30, 1986.

                          Page 6                                    GAO/RCED-91-17     BLM Trespass Enforcement     Efforts

                             that were judged to be non-willful and were handled informally by a
                             telephone call or a visit to the trespasser.RFines were not imposed for
                             any of these incidents. For example, a permittee in Oregon who was
                             grazing more and different types of livestock than authorized by his
                            ’permit and during unauthorized times of the year was not assessed a
                             penalty. Rather, he was warned that if he was found to be in violation of
                             his permit in the future, a portion of his permit might be suspended.

                            BLM’S regulations do not provide BLM range staff with the flexibility to
                            resolve trespass incidents informally. However, BLM range staff told us
                            that, as a practical matter, the administrative time and expense incurred
                            to formally investigate and process minor non-willful violations would
                            far outweigh any benefits derived from the resulting fines. Additionally,
                            they said that if the violation is minor and non-willful, and the operator
                            is cooperative in correcting the problem, more is gained by maintaining
                            good agency-operator working relationships than by taking punitive
                            action against the offender.

BLM Did Not Assess          In addition to informally resolving most trespass incidents it considered
Required Penalties in the   minor, BLM did not assess required penalties for the more serious viola-
                            tions that were formally processed. In 71 of the 86 willful and repeated-
Most Serious Trespass       willful cases where penalties were assessedin fiscal year 1989, we
Cases                       found that BLM did not collect the costs incurred to detect, investigate,
                            and resolve violations, even though its regulations required it to do so.

                            Lesser penalties can reduce the deterrent value of BLM'S enforcement
                            efforts and can lead livestock operators to compare the costs of com-
                            plying with permit requirements with the penalties likely to be assessed
                            if a violation is detected and then make compliance decisions on the
                            basis of the cheaper alternative. A BLM manager stated that one tres-
                            passer in his area paid less in BLM'S willful trespass penalties than it
                            would have cost him to buy hay for his livestock.

                            In addition to monetary penalties, BLM regulations state that a grazing
                            permit may be suspended or cancelled for non-willful and willful tres-
                            pass events and shall be suspended or cancelled, in whole or in part, for
                            repeated-willful trespass. In fiscal year 1989, BLM did not penalize any
                            of the 77 willful trespassers. Moreover, six of the nine repeated-willful

                            “This figure is baaedon a projection of responsesto a questionnaire sent to BLM’s 140 resource area
                            offices. Responseswere received from each office. We are 96 percent confident that there were
                            between 1,311 and 1,897 unreported violations during the year. Resourcearea offices are the primary
                            field locations for public contact and information on the use of BLM lands.

                            Page 6                                     GAO/RCEDQl-17      BLM Trespass Enforcement      Efforts

                            offenders had BLM grazing permits, but only one permit was partially
                            suspended and no permits were cancelled. This partial suspension con-
                            sisted of a reduction of about 30 percent in the grazing season-the tres-
                            passer was required to remove his livestock from public rangelands 6
                            weeks before the end of the 21-week grazing season. Some BLM range
                            staff told us that they seldom assessedthe minimum required penalties
                            because they were not aware of the requirement to collect all reasonable
                            costs incurred; others believed that including such costs, as well as sus-
                            pending or cancelling the permits of repeated-willful trespassers, was
                            optional or discretionary, rather than mandatory, on their part.

                            BLM'S management philosophy emphasizes decentralized control, with as
Greater BLM                 much authority and responsibility as possible delegated to lower oper-
Oversight Neededfor         ating levels. Under this philosophy, large numbers of geographically dis-
Trespass Enforcement        persed managers must interpret and implement agency regulations and
                            policies; for grazing trespass, 140 resource area managers are involved.
Program                     A system for effective internal controls and oversight must be in place
                            to assure management that the program is operating as intended. In
                            1986, Interior’s Inspector General concluded that BLM did not have an
                            effective program to detect and prevent grazing trespass. In the same
                            year, BLM identified its rangelands program as an area for potential
                            fraud, waste, and abuse. During our review, we found that BLM'S tres-
                            pass enforcement program still contains serious weaknesses that require
                            greater management oversight. For internal controls and oversight to be
                            effective, BLM managers must have more comprehensive and timely
                            information about all known or suspected trespass cases.

Adequate Management         BLM'S reporting systems do not provide its top management with com-
                            prehensive data by which to judge the effectiveness of trespass enforce-
Information System Is Not   ment by field offices. Currently, BLM'S summary data include only closed
                            trespass cases where penalties were collected. Data are not routinely
                            collected, analyzed, and reported to provide information on cases that
                            are (1) handled informally, (2) open or being appealed, or (3) dismissed
                            or closed without penalty. Moreover, information is not compiled on the
                            level of grazing trespass (non-willful, willful, and repeated-willful), or
                            whether the violator was or was not a permittee. Finally, summary data
                            are not compiled for permits that are suspended or cancelled or for pen-
                            alties that are assessedfor resource damage. BLM managers need timely
                            and reliable information on grazing trespass detection and penalty
                            assessment to evaluate trespass activity from year to year and make
                            appropriate staffing or program adjustments.

                            Page 7                          GAO/RCED-91-17   BLM Trespass Enforcement   Efforts

Trespass Case Files Are   Proper documentation of enforcement actions is crucial to determining
Not Adequately            patterns of abuse-which is necessary for identifying repeated-willful
                          trespass. According to our review of agency permit files and discussions
Documented                with range staff at selected BLM resource area offices, detected trespass
                          incidents are not consistently documented. Moreover, trespass incidents
                          deemed relatively minor by BLM staff and handled informally by a tele-
                          phone call or a visit to the trespasser are generally not recorded in the
                          trespass record and are not documented in the permittee’s file. Without
                          a record of these incidents, BLM staff cannot demonstrate a historical
                          pattern of violations, and BLM management does not have an accurate
                          picture of trespass activity.

                          BLM has no systematic method for detecting grazing trespass. The rela-
Conclusions               tively low priority accorded grazing trespass detection is evidenced by
                          several management actions: detection has not been established as a
                          work-load measure for field office managers, results of detection efforts
                          are not categorized as reportable accomplishments, resources are not
                          allocated specifically for detection, and range staff are not asked to rou-
                          tinely visit grazing allotments for detection purposes or target operators
                          with a history of noncompliance. Permittees and lessees operate essen-
                          tially under an honor system with little threat of compliance checks by

                          Moreover, penalties for violations are rarely assessed. Even though BLM
                          regulations do not provide the flexibility to resolve trespass incidents
                          informally, an estimated 84 to 88 percent of non-willful incidents were
                          handled informally in fiscal year 1989. BLM range staff told us they do
                          not consider it an efficient use of resources to incur the expenses associ-
                          ated with detecting, investigating, and resolving most minor, non-willful
                          violations. In addition, BLM did not assess penalties required by its regu-
                          lations for most of the willful and repeated-willful trespass violations
                          detected during fiscal year 1989. BLM range staff did not adhere to
                          existing BLM regulations in assessing penalties for these offenses.

                          BLM'S reporting systems do not provide its top management with com-
                          prehensive data they can use to judge the effectiveness of trespass
                          enforcement by field offices. As a result, BLM management does not
                          know how often grazing trespass is searched for, identified, handled, or

                          Page 8                           GAO/RCED-91-17   BLM Trespass Enforcement   Efforts

                           To improve the effectiveness of BLM'S grazing trespass detection and
Recommendationsto          deterrence efforts, we recommend that the Secretary of the Interior
the Secretary of the       direct the Director of BLM to
                       9 develop a grazing trespass detection strategy that will (1) establish
                         detection as a work-load measure and a reportable accomplishment for
                         which managers are held accountable, (2) use visits to randomly
                         selected allotments to provide systematic compliance coverage, and (3)
                         target additional follow-up visits for those livestock operators who have
                         a history of repeated violations;
                       l either (1) ensure that penalties are assessedfor all non-willful trespass
                         violations as provided for in BLM regulations or (2) amend BLM regula-
                         tions to establish a procedure for the informal resolution of non-willful
                         trespass violations at the local level;
                       l require that all trespass incidents- including those now handled infor-
                         mally-be documented and made part of the permanent trespass file;
                       . ensure that field staff impose the penalties required under BLM regula-
                         tions for willful and repeated-willful grazing trespass; and
                       l develop a management information system to provide timely, reliable,
                         and adequate information on such things as (1) the number of compli-
                         ance visits conducted, (2) the number and level of violations identified,
                         and (3) how each violation is resolved, including those resolved

                           In its written comments on a draft of this report, the Department of the
Agency Comments            Interior stated that it agreed with the report’s recommendations. These
                           comments are included in appendix I.

                           In conducting this review, we found that summary data were not avail-
Scopeand                   able on the extent of grazing trespass occurring throughout BLM range-
Methodology                lands. Therefore, we asked BLM'S 140 resource area offices to provide
                           information on grazing trespass cases closed in fiscal year 1989. In addi-
                           tion, we sent a questionnaire to 201 of 414 randomly selected range staff
                           directly responsible for detecting grazing trespass on BLM rangelands.
                           We asked for their views on detecting and recording livestock trespass.
                           As with all sample surveys, the two surveys for this review are subject
                           to sampling errors. Sampling errors define the upper and lower limits of
                           the estimates made from the survey. Sampling errors for the estimates
                           in this report were calculated at the 95 percent confidence level.

                           Page 9                          GAO/RCED-91-17   BLM Trespass Enforcement   Efforts

We also interviewed and obtained information from officials at BLM
headquarters and visited ten resource area offices in four states where
public land grazing is widespread (Arizona, Idaho, Oregon, and Wyo-
ming) to examine BLM'S procedures and practices for identifying and
pursuing grazing trespass. We (1) examined allotment, permit, and tres-
pass records and files and (2) interviewed BLM officials who administer
the grazing program. We conducted our review between June 1989 and
October 1990 in accordance with generally accepted government
auditing standards.

Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days from the date of this letter. At
that time, we will send copies to the appropriate congressional commit-
tees; the Director, BLM; and the Secretary of the Interior. We will also
make copies available to others upon request.

This work was performed under the direction of James Duffus III,
Director for Natural Resources Management Issues, who can be reached
at (202) 276-7766. Other major contributors are listed in appendix II.

J. Dexter Peach
Assistant Comptroller General

Page 10                          GAO/RCED-91-17   BLM Trespass Enforcement   JSfforta
Page 11   GAO/RCED-91-17   BLM Txspass   Enforcement   Efforts

Letter                                                                                                     1

Appendix I                                                                                            14
Comments From the
Department of the
Appendix II                                                                                           15
Major Contributors to
This Report
Related GAO Products                                                                                  16


                        AUM       animal unit month
                        BLM       Bureau of Land Management

                        Page 12                      GAO/RCED-91-17   BLM Trespass Enforcement   Efforts
Page 13   GAO/RCED-91-17   BLM Trespass Enforcement   Efforts
Appendix I

CommentsFrom the Department of the Interior

                               United States Department of the Interior
                                              OFFICE OF THE SECRETARY
                                               WASHINGTON,  D.C. 20240

                                                      OCT :!I     1999

             Honorable James Duffus III
             Director,   Natural  Resources
                Management Ieaues
             General Aaaounting Office
             Waehington,   D.C.   20548

             Dear Mr. Duffue:

             Thank you for the opportunity     to review and comment on the draft proposed
             report entitled    Rangeland Management:    BLM Efforts  to Prevent Unauthorized
             Livestock   Grazing Need Strengthening    (GAO/RCED-91-17).

             After retiewing the report,   we agree with the General Accounting        Office’8
             recommendations for improving    the effectiveness     of the Bureau of Land
             Management’s unauthorized   grazing detection      and deterrent efforts.


                                                      FOR vatid    C. O’Neal
                                                           Aasiatant   Secretary,  Laud and
                                                             Minerals   Management

                     Page 14                               GAO/RCED-91-17   BLM Trespass Enforcement   Efforts
Major Contributorsto This Report

                          Bob Robinson, Assistant Director
Resources,                Ronald Owens, Assignment Manager
Community, and            Alice Feldesman, Social Science Analyst
Development Division,
Washington, DC.

                          Laurence L. Feltz, Regional Assignment Manager
Seattle Regional Office   Robert A. Higgins, Evaluator-in-Charge
                          Keith C. Martensen, Senior Evaluator
                          Stan Stenersen, Senior Evaluator
                          Janet L. George, Staff Evaluator

                          Page 16                         GAO/RCED-91-17   BLM ‘l’respaes Enforcement   Effort-9
RelatedGAO Products

             California Desert: Planned Wildlife Protection and Enhancement Objec-
             tives Not Achieved (GAOIRCED-89-171,June 23, 1989).

             Public Rangelands: Some Riparian Areas Restored but Widespread
             Improvement Will Be Slow (GAO/RCED-88-106,
                                                      June 30, 1988).

             Rangelands Management: More Emphasis Needed on Declining and
             Overstocked Grazing Allotments (GAOIRCED-88-80,
                                                         June 10, 1988).

             Changes in Public Land Management Required to Achieve Congressional
             Expectations (~~-80-82, July 16, 1980).

             Public Rangelands Continue to Deteriorate (CED-77-88,
                                                                July 12, 1977).

(140624)     Page 16                       GAO/RCED-91-17   BLM Trespass Enforcement   Efforts
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