Protecting the National Wildlife Refuge System Law Enforcement Requirements for the 21st Century

              PROTECTING THE NATIONAL WILDLIFE
REFUGE SYSTEM
LAW ENFORCEMENT REQUIREMENTS FOR THE
21ST CENTURY
Prepared by
The International Association of Chiefs of Police
PROTECTING THE NATIONAL
WILDLIFE REFUGE SYSTEM
LAW ENFORCMENT REQUIREMENTS FOR
THE 21ST CENTURY
Prepared by
The International Association of Chiefs of Police
December 2000
Table of Contents
Executive Summary.....................................................................................................1
Chapter I: The Policing Environment
Section 1: NWRS Mission ...................................................................16
Section 2: Law Enforcement Powers ..................................................16
Section 3: The System ........................................................................16
Section 4: Visitors ...............................................................................19
Section 5: Serious Crime.....................................................................20
Section 6: Less Serious Crime ............................................................21
Section 7: Other Offenses ...................................................................23
Section 8: Law Enforcement Workload ...............................................23
Section 9: Crime Clearances...............................................................25
Section 10: Service Activities ..............................................................25
Section 11: Traffic Incidents ................................................................26
Section 12: Resources – Expenditures ...............................................27
Section 13: Resources – Staffing ........................................................27
Section 14: Resources – Staff Days....................................................28
Section 15: Resources – Work Distribution .........................................29
Section 16: Staff Profile.......................................................................30
Section 17: Line of Duty Deaths and Assaults ....................................35
Section 18: Observations ....................................................................35
Section 19: Summary..........................................................................40
Chapter II: The Law Enforcement Infrastructure
Section 1: The NWRS Law Enforcement Culture................................43
Section 2: Organization.......................................................................45
Section 3: Staffing ...............................................................................59
Section 4: Mission, Goals and Objectives ...........................................68
Section 5: Policies and Procedures.....................................................72
Section 6: Human Resources Management – Recruitment and
Selection and Promotion.....................................................84
Section 7: Training...............................................................................89
Section 8: Professional Standards ....................................................101
Section 9: Information Management .................................................109
Chapter III: The State of Refuge Law Enforcement – Workforce Perspectives
Section 1: Survey Population ............................................................115
Section 2: Survey Results .................................................................116
Section 3: Building Blocks .................................................................126
Section 4: Unmet Needs ...................................................................126
Section 5: The Change Culture – Observations on Class .................128
Section 6: Remedies and Opportunities............................................128
Chapter IV: Independent Voices.............................................................................132
Appendix 1: Refuge Law Enforcement Activity 1997-1999
Appendix 2: Law Enforcement Staff Days 1997-1999
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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INTRODUCTION
This report presents the findings and recommendations of a five-months IACP study of
the Refuge Law Enforcement function of the United States Fish and Wildlife Service.
Called for by the Director of the Fish and Wildlife Service and managed by the Office of
the Inspector General, Department of the Interior, the study achieves, in some measure,
the intent of a recommendation in Fulfilling the Promise, a 1999 issues and challenges
document prepared by a cross-section of National Wildlife Refuge System executives
and staff members:
Assess the status of public safety and resource protection provided by
refuge law enforcement officers, and make recommendations for the
future direction of law enforcement in the System.
SCOPE OF WORK
Eleven dimensions of the law enforcement function were selected for study:
q  Recruitment – effectiveness of current practices
q  Training – effectiveness of formal, on the job, and developmental training
q  Retention of law enforcement officers
q  Organization to conduct law enforcement operations
q  Staffing – effectiveness of utilizing collateral law enforcement officers at a
ratio of 9:1; adequacy of law enforcement staffing levels
q  Management accountability and the law enforcement program
q  Professional development of law enforcement managers
q  Policy and written directives – including compliance
q  Internal investigations – including the discipline process.
q  Equipment – adequacy, uniformity, and availability of law enforcement
equipment
q  Assaults on Refuge Law Enforcement Officers
The scope of work was distilled from discussions with the Inspector General, serving as
the representative of the Director of the Fish and Wildlife Service, the staff of the
Inspector General, and executives and managers of the Refuge System.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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STUDY APPROACH
Work was conducted in four phases. Phase 1, Project Organization and Design,
consisted of project scoping; design of an organizational culture/workforce survey;
construction of field interview guidelines; and collection of FWS/Refuge background
materials.
Phase 2 centered on Field Work/Site Visits. Twenty-seven (27) refuges were visited.
Region, geographical location, size, and special law enforcement requirements were the
principal criteria for constructing the site visit/refuge profile. We believe that the refuges
visited represent the full diversity of the System. Site visits featured closed, confidential,
and separate discussions with refuge managers and refuge officers. Strengths and
weaknesses of refuge law enforcement practices and recommendations for
improvement framed the dialogue. Several hundred managers and officers shared their
judgements, observations and recommendations.
Phase 3, Data Analysis and Report Preparation, entailed processing, formatting,
analyzing, and synthesizing all information gathered during earlier phases;
supplemental data gathering; and preparation of several drafts of our report. Discussion
of our field-generated observations with a NWRS management level work group
produced important feedback and insights.
Phase 4, Project Wrap-Up, consisted of presentation of the final draft of the report to an
FWS and NWRS executive group; discussion of findings and recommendations with the
group; review of the draft by FWS, NWRS, and DOI executives; and final modification to
the study report.
STUDY TEAM
The study was conducted by Jerome A. Needle, Director of Programs and Research,
IACP; Kim J. Kohlhepp, Manager, Center for Testing Services and Executive Search,
IACP; Phillip J. Lynn, Manager, Model Policy Center, IACP; Donald R. Shinnamon,
Manager, Community Policing Consortium, IACP; Bruce Richter, Captain, Anchorage,
Alaska Police Department; and Lieutenant Andrew Ellis, Prince Georges County,
Maryland, Police Department. Palmer J. Wilson, Associate Consultant, served as lead
consultant.
DOI AND FWS SUPPORT
The DOI and FWS supplied substantial support to the IACP staff, without which the
project would not have proceeded effectively. Singled out for leadership roles and
special contributions are:
q  Earl Devaney, Inspector General
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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q  Thomas R. Moyle, Chief, Special Inquiries Unit, Office of the Inspector
General
q  Jerry Olmsted, National Refuge Law Enforcement Coordinator, Region 9,
USFWS
q  Steven A. Knode, Project Leader, Crescent Lake/North Platte NWR
Complex, USFWS
q  Tom Goettel, Regional Refuge Law Enforcement Coordinator, Region 5,
USFWS
q  Jerry Kuykendall, National Refuge Law Enforcement Training Coordinator,
Region 9, USFWS
q  Bob Bartels, Regional Refuge Law Enforcement Coordinator, Region 3,
USFWS.
SPECIAL ACKNOWLEDGEMENT
Close to 550 refuge managers and officers invested considerable time to prepare and
submit reasoned and thoughtful responses to workforce surveys. Many FWS members
spent considerable time discussing issues with and proposing innovations to project
staff, forwarding information, e-mailing, telephoning, and otherwise helping to build the
rich information base in which this study is anchored. We acknowledge and thank each
of you.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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EXECUTIVE SUMMARY
The law enforcement demands of the NWRS are expanding. Refuge visitation is
increasing materially, over two million visitors annually. Growth is spawning increases
in serious crime, other offenses, law enforcement activity, traffic incidents, and staff day/
resource commitments to law enforcement. Vandalism increases are pronounced.
Commitment to proactive prevention and control of resource and ARPA violations
seems to be diminishing in priority, eroding, or is being passed on to other law
enforcement agencies. Drug abuse, drug cultivation, drug trafficking, drunkenness,
weapons violations, illegal alien activity, and liquor law violations are all increasing. A
shift toward public use generated law enforcement requirements promises to continue
to alter the preservation and protection environments.
To retain the excellent level of safety for System users and to intensify the proactive
capacity that is so central to achieving the core mission, NWRS leaders should enhance
the quantity and quality of law enforcement. The law enforcement complement of the
NWRS is modest, the FTE equivalent of 250 officers for a system composed of 530
refuges, 37 wetland management areas, and 93.5 million acres. Quantity enhancement
could come from the current complement of collaterals, by committing a greater degree
of their time to law enforcement, or from augmentation – new positions. Augmentation
does not seem to be achievable from current staff capacity without sacrifice to other
equally crucial NWRS functions. Quality enhancement is more likely to occur through
addition of full-time officers, who bring or develop greater law enforcement interest,
intensity, and experience, than through addition of collaterals.
The potential of an enhanced law enforcement function cannot be maximized within the
present organizational, cultural, and program framework. The framework is too studded
with management and operating flaws, in crucial areas such as objectives setting and
measurement, program evaluations, information management, and organization, to cite
several examples. Expansion should occur within the context of a New Vision of law
enforcement. In addition to increasing law enforcement staff capacity, quantitatively
and qualitatively, foundations of the New Vision should consist of:
q  A more powerful voice for law enforcement at the national level
q  Increasingly unified practices, achieved through greater clarity of common
objectives and more coherent policies and procedures
q  Innovation in refuge law enforcement organization and service delivery
q  Rational, data-driven law enforcement officer allocation and deployment
q  Technology, equipment, and information supplements for field officers
q  A comprehensive central support system for the law enforcement function
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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q  More professional and effective recruitment and selection
q  Intensified law enforcement training
q  Strengthened research, analysis, and planning support for refuges and
field officers
q  A management-tailored data system
q  A predictable and protected funding stream.
The Vision should reinforce the many strengths of the current law enforcement system
including decentralization, open and vibrant interpersonal communications, and an
impressive congruence of positive attitudes and perspectives among law enforcement
managers and officers.
THE LAW ENFORCEMENT ENVIRONMENT
The capacity of the National Wildlife Refuge System to meet its protection obligations is
conditioned by a complex mix of factors and trends. Among the most consequential are
number, size and dispersion of refuges to be policed; visitation; incidence of crime and
disorder; range and volume of non-crime protective services; and law enforcement
resources.
q  The System. The NWRS consists of 530 refuges and 37 wetland
management districts. The System manages over 90 million acres, in
every state in the Union and several territories. The breadth and diversity
of the System demand local, refuge-based management of and
accountability for the law enforcement function. The current Project
Leader-based authority and accountability structure is the proper model
for the NWRS and should be retained. Strengthened centralized efforts at
the national and regional levels are recommended.
q  Visitation. Population is a powerful correlate of law enforcement
requirements. Population growth, law enforcement workload, and law
enforcement resource requirements correlate positively. Visitation is the
NWRS equivalent of “population.” It is a primary service base.
Visitation is increasing at an annual average of 6.6%. Between 2.3 and
2.6 million additional visitors will have to be serviced by refuge officers for
the next several years. Visitation can be expected to reach 42,000,000 by
2002.
q  Visitor Safety. Refuges are very safe places for visitors. Approximately
two of every 100,000 visitors are victims of serious crime, and that crime is
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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far more likely to be a property crime than a violent crime. The
comparable victimization rate in the National Park Service, also a very
safe venue, is less than one visitor per 100,000. For cities and towns
throughout the country the comparable rate in 1999 was 4,619 crimes per
100,000 inhabitants.
q  Serious Crime. Fewer than 700 serious crimes are reported annually. A
majority of refuges do not experience even one violent crime during a
year, or do not report any. Serious crime has been trending upward,
attributable, fully, to increases in reported arsons. The limited number of
serious crimes notwithstanding, the increase is consistent with visitation
changes.
q  Less Serious Crime. Less serious crime is far more prevalent than
serious crime, but still marginal in rate of occurrence on many refuges.
Successive decreases in 1998 and 1999 are notable. Despite substantial
increases in visitation, the incidence of less serious crime in 1999
paralleled that of 1995.
In several offense categories trends appear to exist that law enforcement
managers should explore and explain. A precipitous decline in natural
resource violations in 1999, 35% lower than 1998, and 47% lower than in
1997, is compelling. A dramatic increase in vandalism, 132% in five
years, 27% higher in 1999 than in 1996, the previous peak, clearly
requires analysis and immediate response. Increases in weapons and
drug abuse violations promote questions. In each case, causation may lie
in more aggressive law enforcement work, an expanding problem, or both.
q  Other Offenses. Reported data reflects increasing incidence of offenses
in this class, which would be expected in view of visitation trends. The
trend is also characterized by extraordinary annual fluctuation, the
magnitude of which calls the reliability of data into question. The data are,
simply, too erratic to be believable.
q  Refuge Law Enforcement Activity. Total activity increased substantially
between 1997 and 1999, 36%. The pattern of refuge activity
demonstrates ever so clearly that the System is composed of refuges
where law enforcement events are highly episodic. Almost 400 refuges
record a law enforcement event 100 or fewer times each year, one every
three-to-four days. About 10% experience 100-500 per year, about one a
day. Only 14 refuges (3%) report 500 or more law enforcement events
annually. Based on reported activity alone, most refuges cannot cost-justify
full-time law enforcement officers. Collateral duty must remain a
prominent practice.
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The activity pattern also calls out for alternative forms of law enforcement
organization. Law enforcement officers, full-time and collateral, are now
assigned/restricted to one refuge. Ingrained refuge-by-refuge and full-time
or collateral staffing practices inhibit innovation. New refuge staffing
models should be designed. To create more useful designs, a rational,
data-driven refuge law enforcement officer allocation and deployment
scheme is needed, a crucial management tool which does not exist at this
time.
q  Clearances. Nationally, about one in five serious crimes is cleared. The
refuge system law enforcement program does less well, clearing 14%.
This is attributable in large measure to the transience of the refuge
population and the limited corps, geographical dispersion, and priorities of
investigative specialists – the staff of the Division of Law Enforcement.
Still, a detailed review of investigative practices is warranted, with a focus
toward improvement. Like residents of communities across the country,
visitors expect refuge law enforcement to close cases, bring offenders to
justice and return property.
q  Service Activities. NWRS law enforcement is not servicing clientele to
the degree it has in the very recent past. For the three-year period 1997
to 1999 service activities declined 43%. This phenomenon deserves
analysis and response. An examination of reporting practices is in order.
q  Traffic. Traffic incidents have increased almost 200% since 1995 and by
more than half since 1997. Off-road violations have exploded in number.
The magnitude of the increase, most of it in 1999, signals deliberate law
enforcement intervention and proactivity. Further detail on traffic activity
particularly number of crashes, substance abuse causation, and violator
profiles, would assist understanding and planning of further prevention
and control initiatives.
q  Law Enforcement Staffing. The NWRS and FWS tend to frame staffing
considerations on a base of 602, a number which misrepresents reality.
Staffing days data suggest that an FTE total of 244 is more accurate.
Framing considerations on a base of 244 illuminates and alters the focus.
An FTE law enforcement complement of 244 officers, 90% of whom spend
two-thirds of their time on other duties, seems quite modest. The staff
days calculation, a flat staffing trend, and visitation growth establish a
persuasive case for staffing supplements.
q  Expenditures. Absence of detail on expenditures precludes analysis of
and judgements about current funding levels and the significance of the
44% increase in expenditures between 1997 and 1999.
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q  Line-of-Duty Deaths and Assaults. Line of duty deaths and assaults are
minimal. Fourteen (14) refuge officers have been assaulted in 1996.
NWRS data show no line-of-duty killings. This positive statistic
notwithstanding, refuge officers are continually exposed to danger. Many
refuge users are armed, hunters in particular. Substance use and abuse
is part of the American culture. Back-up is a priority concern throughout
the System, properly so. Priority status must always be accorded to
officer safety.
q  Staff Profile. Overall, the staff profile bodes well for 21st Century
organizational transformation. Change occurs more effectively in mature
organizations with well educated and well experienced staff. Law
enforcement staff is highly educated. Managers have even higher levels of
education.
The spread of experience of law enforcement officers with the FWS is
normal. The same pattern does not prevail with regard to experience in
law enforcement positions. Almost 20% of law enforcement officers have
two years experience or less in their current positions. Another 22% have
four years of experience or less in current positions. The brevity of these
tenures becomes more problematic when the infrequency of law
enforcement events in most refuges is considered. Far too many law
enforcement officers simply do not accumulate “event experience” to the
degree required for confidence and safety. This situation calls for urgent
attention. Innovations in training and assignment practices are called for.
THE NWRS LAW ENFORCEMENT CULTURE
A series of attributes dominate the NWRS law enforcement culture. They go far to
explain current infrastructure conditions and practices and will heavily influence the
change environment. Some attributes bode well for successful organizational and
cultural transformation. Most do not.
q  Secondary Status. The FWS employs many means to protect wildlife
and natural resources. Law enforcement appears to be regarded as
necessary but less vital than a number of other functions. Although the
first wildlife officer had law enforcement powers, a reading of the
organization’s history suggests that law enforcement authority was
granted as an add-on, to be used only when needed. Current documents
reflect a continuing ambiguity. Secondary status is reinforced by a
“tolerance” for public use focus and activity.
q  An Unfinished System. The law enforcement function has evolved
somewhat by design, somewhat reactively, and very incrementally. It is
not the product of a comprehensive law enforcement design. This
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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explains the “functional holes” in the organization and absence of
compliance with best policies and practices in several areas. This
attribute, and the preceding, account for many negative conditions that
exist.
q  Law Enforcement Balkanization. The law enforcement function is
locally administered and controlled with too little guidance from the
national level and varying levels of guidance from the regions. This
produces inconsistent approaches to law enforcement service delivery
and insufficient monitoring and accountability.
q  Dominance of Collateral Duty. The System relies primarily on collateral
duty officers who concentrate on non-law enforcement preservation tasks
and conduct law enforcement functions when demand occurs. This model
exhibits distinct flaws:
-  The law enforcement competencies of collateral duty officers
degrade directly with lack of utilization of law enforcement skills
-  Officers who do not employ law enforcement skills with requisite
frequency are at greater risk for failure and possible injury when
attempting to employ the skills
-  Focus on law enforcement is diluted, reducing linkage to the core
mission.
At the same time, the collateral system is the only cost-justifiable
approach to law enforcement in the majority of refuges, as the NWRS is
presently organized for law enforcement.
q  Underserved Refuges. In refuges with the collateral duty officers only,
the majority, the law enforcement commitment is quite limited. At some
sites, law enforcement operations are not visible at all, due to the
demands of primary duty assignments. We have been made aware of
refuges that have no weekend law enforcement coverage.
q  Refuge-Bound Allocation and Deployment. The foregoing condition is
explained by absence of a governing, professionally rationalized staffing
allocation and deployment plan and further aggravated by the “refuge-bound”
nature of resource acquisition practices. The Service does not
tend to think beyond the zones of individual refuges. This is not
inconsistent with practices in any organization in which competition for
finite resources is prevalent.
q  Primitive MIS Capacity. Law enforcement management suffers from
failure to develop a comprehensive and credible database and a data
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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capture capability that is accessible at the refuge, regional, and national
level for crime and service analysis, resource allocation, and goals and
objectives measurement. This problem flourishes, in part, because of
minimal demands for data-justified evaluation of law enforcement success
or failure.
q  A Changing Refuge Environment. Only in recent years has an
organized public use and visitation marketing effort been undertaken. The
number of visitors is increasing measurably, bringing many problems
typically confronted by state and local law enforcement agencies, such as
drug use, alcohol-related incidents, including DUI, person-to-person crime,
homeless-related activity, and gang and sexually-deviant incidents. The
visitation trend should continue, further changing the refuge law
enforcement dynamic.
q  The Prime Asset. The law enforcement workforce – full-time and
collateral duty officers, refuge managers, and regional executives, is
genuinely dedicated to the FWS mission and regard the Service as their
career. As already noted, law enforcement managers and officers are
highly educated.
q  Readiness for Change. Field interviews with managers and officers
demonstrate institutional readiness to restructure law enforcement
conditions, including greater emphasis on employing full-time officers and
elevating the law enforcement function to equal status with other NWRS
service functions. Both classes express frustration with the secondary
status accorded to law enforcement.
THE LAW ENFORCEMENT INFRASTRUCTURE
Current organization, staffing, policies and practices vary in relation to current NWRS
needs, level of compliance with contemporary views of best policy and practice, and
professional law enforcement standards.
q  Organization. The organization of the NWRS law enforcement function
features significant assets. Employment of a decentralized model that
accords substantial empowerment, authority and responsibility to Refuge
Project Leaders is the supreme asset. The regional structure, which
apportions over 500 properties and hundreds of employees among seven
manageable clusters makes great sense. Placing law enforcement
specialists at regional level for coordination and problem-solving is a third
positive of the organization scheme.
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Despite these positives, law enforcement is not flourishing in the NWRS.
This condition is traceable to many causes, a number of them
organizational. Of greatest consequence are:
-  An insufficiently competitive organizational position in the
national structure
-  Passive central direction and control of the law enforcement
function
-  Organizational absence or impotence of crucial law
enforcement support functions throughout the System
-  Over-reliance on a refuge-by-refuge organizing and staffing
model.
q  Staffing. The NWRS is functioning with 602 law enforcement officers, 62
full-time and 540 collaterals, a ratio of 1 to 9. The law enforcement
commitment from this complement approximates that which would be
received from 244 full-time officers. Field interviews, field observations,
document research, and study-specific data collections reveal a series of
instructive staffing-relevant considerations:
-  Current Complement. The 62 full-time LEOs are the law
enforcement staffing baseline. They engage exclusively in
law enforcement activity. Collaterals distribute their time
among a range of competing and equally important activities.
-  Staffing Policies. Law enforcement staffing policies and
criteria do not exist. Unlike most police agencies, the
System has not set minimum staffing standards, even ones
as basic as 24-hour, seven days per week coverage.
-  Officer Safety Standards. The FWS/NWRS has not set
law enforcement safety standards, most notably back-up and
multiple officer response requirements.
-  Coverage Gaps. Many refuges are uncovered by full-time
or collateral law enforcement officers during evening hours,
on weekends and on some holidays, due to scheduled days
off, sick leave, and out-of-refuge professional activities.
-  Collaterals. An unquantifiable number of collateral duty
officers do not regard law enforcement as a primary duty,
are not as motivated about this aspect of activity as some
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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others, and may not exhibit the performance quality of full-time
officers. Overall, collaterals are not the base upon
which to build the law enforcement future. Nor are career
seasonals, another option.
-  Leveraging Capacity. The combination of refuge
dispersion and small staff complements at many refuges
inhibits leveraging capacity and flexibility. Refuges have
very limited ability to multiply staff for special events or to
confront special problems without sacrificing essential refuge
work of other kinds.
-  Staffing Trends. The NWRS has not been able to supply
reliable staffing trends data. One document in our collection
places 1993 staffing at 625 collateral duty officers, 40 full-time
officers and 30 seasonals, a total of 665 excluding the
seasonals. It seems reasonable to conclude that law
enforcement staff has not increased in recent years.
-  Service Population. In contrast to stable or declining staff,
visitation is increasing and is projected to continue to grow.
-  Refuge Profile. Also in contrast to stable or declining
staffing, the number of refuges has increased marginally, 13
since 1995, as has the number of acres to be protected,
almost one million since 1995.
The configuration of staffing-relevant attributes justifies an increase in law
enforcement staff. Augmentation should concentrate on addition of full-time
law enforcement officers. Augmentation should be paralleled by a
concerted effort to establish a defensible law enforcement staff allocation
and deployment methodology, a comprehensive resource leveraging
program, search for innovations in organization, and a focus on intensified
supervision, mentoring, and guidance.
q  Mission, Goals and Objectives. Every full-time or collateral law
enforcement officer should function with the guidance, direction, and
benefits of a carefully articulated and measurable set of law enforcement
outcomes that he or she is accountable for achieving. These should “tier
down” from refuge objectives which in turn should tier from regional,
System, and Service objectives. The FWS, NWRS, individual refuges,
and law enforcement officers are not even remotely positioned to satisfy
this standard. From top to bottom, from the Service level to the refuge
officer, measurable objectives are absent. Lacking these, the
management function is impaired in a variety of ways, direction and
guidance, planning and evaluation being most crucial.
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q  Policies and Procedures. The NWRS is aware that substantial work is
required to codify, streamline, and render more user-friendly, the
overpowering volume of directives. Recognizing the problem does not
justify, however, allowing the revision process to languish, as is the case;
to accord low priority to the effort, as seems to be the case; or to commit
only marginal resources to the task, as is the case. We find a series of
inadequacies ranging from policy gaps to redundancies and from
construction to language shortfalls. On the positive side, a satisfactory
and workable organizing structure and policy format has been developed.
q  Recruitment, Selection, and Promotion. The law enforcement officer
hiring process is characterized by a decentralized system and absence of
a coordinating mechanism to ensure that effective recruitment takes place
and that proper steps in selection are followed. Recent efforts to improve
the system are constructive. They also substantiate that the process
requires reconstruction to comply with professional standards. The
process should be revised and placed in the hands of a single entity,
responsible and accountable for its success.
Evaluation of candidates should be greatly intensified prior to selection of
finalists and conditional offers of employment. A broader base of
information will enhance the quality of the selection practices. In addition
to the Crediting Plan, a well-designed approach to structured evaluation of
job relevant KSAs, a valid written examination should be used to test
candidates. A carefully developed and standardized structured interview
should complement information obtained from the Crediting Plan and the
written examination. The medical, psychological, background, and PEB,
combined for pass/fail administration, should remain at the post-conditional
offer of employment stage.
q  Training. Primary measures of effectiveness of the training function
include: how well training initially prepares officers to perform duties; how
well officer skills are maintained; and how well officers are prepared to
assume greater responsibility in the future. The poor condition of NWRS
training records precludes application of primary measures and inhibits
definitive judgement of training. We are able to conclude that numerous
program and administrative deficiencies exist that should be addressed.
When corrected, the program will be strengthened considerably.
Improvements are available in organization; accountability; record-keeping;
curricula; training sequence; training scope; and leadership
development.
q  Professional Standards. Primary measures of appropriate officer
behavior and agency ethical standards are:
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- Number of and trends in citizen and supervisor-initiated
complaints
- Number of and trends in sustained citizen and supervisor-initiated
complaints
- Number of and trends in the most serious types of
complaints
- Citizen and supervisor satisfaction with agency response to
complaints and final outcomes.
Total absence of a professional standards statistical base prohibits
application of the primary measures. This management information gap
has to be closed. In addition to a professional standards database,
substantial work is required to give form to professional standards
practices. The most significant step is to fix authority for professional
standards. Disparately located policies and procedures must be
consolidated and issued in non-conflicting and user-friendly form.
THE STATE OF REFUGE LAW ENFORCEMENT – WORKFORCE PERSPECTIVES
To give every Refuge law enforcement manager and officer a voice in the study,
workforce surveys were conducted. The workforce has not delivered a vote of
confidence for the capacity of the NWRS to ensure safety of wildlife and visitors. In the
view of the workforce, perceived shortfalls and unmet needs surpass perceived assets.
In the job preparation and direction area, training is considered to be strong. Policies
and procedures and supervision fall short. Career conditions are poorly regarded, from
recruitment through performance evaluation. Management obligations are not being
met well is the collective view of officers.
Both officers and managers regard the following conditions and practices to be
unsatisfactory:
q  Capacity to safeguard natural resources
q  Capacity to safeguard visitors
q  Program evaluation
q  Accountability of directors and managers
q  Back-up availability
q  Communications systems and technology.
Officers regard the following conditions and practices to be unsatisfactory:
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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q  Collateral duty
q  Direction and guidance from regional managers
q  Promotion practices
q  Performance evaluation
q  Recruitment and selection.
Officers regard the following practices as marginally satisfactory:
q  Direction and guidance from refuge managers
q  Policies and procedures
q  Direction and guidance from regional law enforcement coordinators
q  Equipment, technology, and information.
Managers regard the refuge enforcement objectives situation quite negatively.
Both officers and managers are positive about two conditions: understanding of NWRS
enforcement objectives; law enforcement officer personal protection capacity. Officers
are highly positive about basic and in-service training and refuge law enforcement
objectives. Managers are positive about the level and quality of equipment, technology
and information accorded to the law enforcement function.
As the law enforcement function of the NWRS evolves or is re-engineered, workforce
perspectives deserve important consideration. The unanimity that exists among officers
and managers in six important areas of need can serve as a framework for cooperative
change.
PRIORITY RECOMMENDATIONS
This report offers 50 recommendations. While all are important, they vary with regard to
potential impact on law enforcement effectiveness, cost, and complexity of
implementation. Further, organizations have differing capacities to absorb change
without encountering dysfunction. With consideration of these factors, we single out 10
actions as paramount for successfully forging a New Vision for NWRS law enforcement.
1. Create a tiered structure of law enforcement goals and objectives,
consisting of measurable outcomes for the:
a. NWRS
b. Regions
c. Refuges
d. RLEOs.
2. Restructure NWRS law enforcement by:
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
13
a. Creating a Law Enforcement Branch, headed by a Branch
Chief.
b. Establishing three offices within the Branch: Operations;
Administration and Support; Professional Responsibility.
c. Creating new or enhancing current central support services:
Personnel and Training; Technology and Equipment; Planning
and Budgeting; Information Management; Inspectional
Services; Internal Affairs.
d. Strengthening law enforcement supervision and support
services in the regions.
3. Increase the current complement of 602 refuge law enforcement officers:
a. Prioritize addition of full-time law enforcement officers.
b. Depart from exclusive reliance on traditional refuge-by-refuge
staffing schemes in favor of innovative staffing schemes.
4. Develop a defensible law enforcement staffing allocation and deployment
model.
5. Accompany staff augmentation with new or intensified productivity and
resource leveraging strategies.
6. Accord sufficient priority and resources to re-energize and complete the
policy and procedures consolidation and renewal process.
7. Restructure the human resources acquisition program:
a. Establish a central authority to manage the human resources
function.
b. Design and implement an aggressive nationwide recruitment
process
c. Introduce additional diagnostic and selection steps including a
validated written law enforcement entrance examination and
an oral interview.
8. Appoint a central Manager of Law Enforcement Training. Priorities should
include:
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
14
a. Revising of the LMTP and ROBS curricula
b. Designing a Field Training Program
c. Developing a comprehensive law enforcement records system.
9. Establish a central Office of Professional Responsibility. Priorities should
include:
a. Restoring policy and program compliance audits of regions
and refuges.
b. Developing early warning systems to identify officers at-risk
for dysfunctional behavior.
10. Establish a central Office of Information Systems. Priorities should
include:
a. Developing an information base for System management.
b. Developing an information base for refuge law enforcement
operations.
INDEPENDENT VOICES
Five earlier audits and studies of the NWRS law enforcement function have been
examined. Vary in purpose, scope, and methodology, these studies offer findings and
recommendations for improving 25 aspects of NWRS law enforcement. Review
indicates that a range of NWRS law enforcement conditions singled out for attention in
this report have existed for many years and have been singled out for attention by
earlier analysts and auditors. Most consequential for law enforcement effectiveness
are:
q  An under-developed central direction and accountability structure
q  Policy and procedure inadequacies
q  Recruitment and selection issues
q  Cooperative agreement and MOU initiatives
q  Communications equipment shortfalls
q  The professional standards – inspections gap
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
15
q  Training gaps – FTO and leadership.
The reinforcing nature of successive audits accords credibility to observations and
recommendations set forth in this report. The import of the comparative analysis for
change expectations is of great significance also. Champions of change will have to
emerge to employ the recommendations of this audit more constructively than has been
the case with previous audits.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
16
CHAPTER I: THE POLICING ENVIRONMENT
The capacity of the National Wildlife Refuge System (NWRS) to meet its protection
obligations is conditioned by a complex mix of factors and trends. Among the most
consequential are number, size and dispersion of refuges to be policed; visitation;
incidence of crime and disorder; range and volume of non-crime protective services;
and law enforcement resources.
SECTION 1: NWRS MISSION
The National Wildlife Refuge System Improvement Act of 1997 sets forth the mission:
The mission of the 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.
SECTION 2: LAW ENFORCEMENT POWERS
Police authority is conveyed in the Fish and Wildlife Service Manual, which has
regulatory force and effect within the Service. Service Directive 036 FW1, Law
Enforcement Authority (March 4, 1993), specifies 14 federal fish and wildlife laws that
special agents and refuge law enforcement personnel are authorized to enforce.
Among these is the National Wildlife Refuge System Administration Act (16 USC
668dd), considered the fundamental act for the System.
With regard to law enforcement, 50 CFR, Chapter 1, Section 28.21 states that refuge
managers and others are authorized to “. . . protect fish and wildlife and their habitat
and prevent their disturbance, to protect Service lands, property, facilities, or interests
therein and to ensure the safety of the using public to the fullest degree possible.”
SECTION 3: THE SYSTEM
The first refuge, designated by President Theodore Roosevelt in 1903, consisted of
three acres. The System has experienced dramatic and continued growth since its
modest beginning. The Report of Lands Under Control of the U.S. Fish and Wildlife
Service lists 521 refuges (September 30, 1999.) The System manages over 90 million
acres, in every state in the union and in the Pacific Outlying Area, Puerto Rico and the
Virgin Islands. During Fiscal Year 1999 the System grew by 230,000 acres to a total of
90,644,775. Of 60 states/territories/possessions, 38 (63%) increased the number of
acres under System control. Only four (7%) lost acreage. (Table 1.) Every one of the
NWRS regions increased acreage in 1999, most quite marginally. (Table 2.)
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
17
Table 1
LANDS UNDER CONTROL OF THE NWRS 1998 – 1999(1)
Number of Refuges Acreage
State FY98 FY99 Change FY98 FY99 Change
Alabama 9 9 -- 57,806.35 57,866.47 +60.12
Alaska 16 16 -- 76,955,623.11 76,981,281.12 +25.658
Arizona 9 9 -- 1,711,366.29 1,711.366.29 --
Arkansas 10 10 -- 344,530.03 345,322.03 +802
California 37 37 -- 432,171.78 444,623.72 +12,451.94
Colorado 6 6 -- 79,482.95 79,424.95 -58
Connecticut 1 1 -- 774.73 774.73 --
Delaware 2 2 -- 26,720.51 26,720.51 --
Florida 29 29 -- 973,675.26 975,695.05 +2,019.79
Georgia 8 8 -- 479,013.30 479,013.30 --
Hawaii 9 9 -- 294,767.91 294,767.91 --
Idaho 6 6 -- 81,292.33 81,292.33 --
Illinois 7 7 -- 111,531.80 111,725.44 +193.64
Indiana 2 2 -- 10,957.59 12,035.10 +1,077.51
Iowa 4 4 -- 85,530.98 86,088.76 +557.78
Kansas 4 4 -- 58,523.50 58,523.50 --
Kentucky 2 2 -- 3,870.64 7,466.95 +3,596.31
Louisiana 20 20 -- 508,711.52 510,517.77 +1,806.25
Maine 8 9 +1 53,198.85 53,542.38 +343.53
Maryland 6 6 -- 43,045.39 44,070.30 +1,024.91
Massachusetts 10 10 -- 12,757.39 13,753.39 +996.00
Michigan 7 7 -- 115,119.23 115,328.12 +208.89
Minnesota 10 10 -- 206,116.93 207,410.81 +1,293.88
Mississippi 10 10 -- 220,954.91 223,499.58 +2,544.67
Missouri 7 7 -- 56,648.92 56,346.52 -302.40
Montana 21 22 +1 1,134,851.00 1,144,298.20 +9,447.20
Nebraska 5 5 -- 151,462.65 150,258.47 -1,204.18
Nevada 9 9 -- 2,318,982.40 2,320,592.57 +1,610.10
New Hampshire 4 4 -- 5,863.70 5,863.70 --
New Jersey 5 5 -- 66,506.11 68,717.22 +2,211.11
New Mexico 7 7 -- 384,223.86 384,232.61 +8.75
New York 9 10 +1 27,680.26 28,401.83 +721.57
North Carolina 11 11 -- 419,674.47 420,594.13 +919.66
North Dakota 64 63 -1 296,614.70 296,506.45 -108.25
Ohio 3 3 -- 8,323.18 8,353.18 _30
Oklahoma 9 9 -- 164,008.84 164,022.84 +14
Oregon 20 20 -- 587.373.66 589,412.04 +2,038.38
Pennsylvania 3 3 -- 9,829.29 9,829.29 --
Rhode Island 5 5 -- 1,707.41 1,707.41 --
South Carolina 7 7 -- 154,373.66 160,228.59 +5,259.37
South Dakota 7 7 -- 48,508.90 48,508.90 --
Tennessee 6 6 -- 114,129.03 114,446.73 +317.70
Texas 18 18 -- 465,202.01 496,447.64 +31,245.63
Utah 3 4 +1 104,056.70 104,457.70 +401
Vermont 1 1 -- 6,499.48 32,764.29 +26,264.81
Virginia 12 12 -- 126,561.74 128,645.19 +2,083.45
Washington 20 20 -- 178,272.37 179,273.11 +1,000.74
(1) Wetland Management Districts are not included in this table.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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Table 1
LANDS UNDER CONTROL OF THE NWRS 1998 – 1999(1)
Number of Refuges Acreage
State FY98 FY99 Change FY98 FY99 Change
West Virginia 1 1 -- 3,851.03 5,070.35 +1,219.32
Wisconsin 6 7 +1 162,792.65 162,815.90 +23.25
Wyoming 7 7 -- 80,918.57 80,921.14 +2.57
American Samoa 1 1 -- 39,066.00 39,066.00 --
Baker Island 1 1 -- 31,736.89 31,736.89 --
Guam 1 1 -- 23,228.10 23,228.10 --
Johnson Atoll 1 1 -- 100.00 100.00 --
Midway Island 1 1 -- 298,362.30 298,362.30 --
Puerto Rico 4 4 -- 3,556.64 4,826.64 +1,270.00
Virgin Island 3 3 -- 385.65 548.92 +163.27
Howland Island 1 1 -- 32,550.25 32,550.25 --
Jarvis Island 1 1 -- 37,519.17 37,519.17 --
Navassa Island 0 1 +1 0 92,000.00 +92,000.000
TOTALS 516 521 5 90,413,560.43 90,644,774.78 231,214.27
(.3%)
Table 2
REGIONAL INCREASES 1999
Region 1: Total increase 109,101.16 (3% of 3,768,049.20) (WA, OR, ID, CA, NV, HI, Pacific Outlying
Area)
Region 2: Total increase 31,268.38 (1.2% of 2,724,800.00) (AZ, NM, TX, OK)
Region 3: Total increase 3,082.55 (.4% of 757,021.28) (OH, IN, IL, MO, MI, MN, WI, IA)
Region 4: Total increase 18,759.14 (.6% of 3,282,709.90) (LA, FL, GA, SC, NC, KY, TN, AL, MS, AK,
PR, VI)
Region 5: Total increase 34,864.70 (9% of 384,995.89) (VT, VA, WV, MD, DE, NJ, PA, NY, MA, RI, NH,
ME, CT)
Region 6: Total increase 8,480.00 (.4% of 1,954,418.80) (MT, ND, SD, CO, WY, UT, NE, KS)
Region 7: Total increase 25,658.00 (.03% of 76,955.623.11)
The System continues to grow since September 30, 1999. At the end of 2000 Fiscal
Year there were 530 National Wildlife Reserves and acreage totaled 93.5 million.
(cont’d)
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
19
SECTION 4: VISITORS
Almost 35 million persons visited national wildlife refuges during Fiscal Year 1999. This
represented increases of:
q  1.5 million (5%) over Fiscal Year 1998
q  7.3 million (26%) over Fiscal Year 1995.
The average annual increase from FY95 to FY99 is 1.8 million visitors, 6.6%. The
System has grown continuously. Regional growth has fluctuated. One region (2) grew
at a rate that exceeds the system average. Two regions (3 & 4) grew at rates that
approximate the system average. Three regions (5, 6 & 7) experienced growth at a
lower rate than the System average and one (Region 1), experienced a decline. Region
4 is the only one that experienced an increase in visitation in each of the past three
years.
Table 3
REFUGE VISITATION 1995-1999
FY 1995 FY 1996 FY 1997 FY 1998 FY 1999
Change –
Number1
Change –
Percent1
Region 1 n/a 3,694,733 3,811,390 3,776,968 3,500,114 -194,619 -5%
Region 2 n/a 3,273,451 3,602,716 3,238,928 4,482,098 +1,208,647 +37%
Region 3 n/a 5,955,087 6,494,423 7,521,480 7,462,734 +1,507,647 +25%
Region 4 n/a 8,557,737 9,078,936 9,716,547 10,509,082 +1,951,345 +23%
Region 5 n/a 4,632,408 5,165,017 5,561,846 5,238,331 +606,923 +13%
Region 6 n/a 2,420,987 2,184,586 2,501,644 2,690,113 +269,126 +11%
Region 7 n/a 934,679 1,022,712 990,474 971,597 +36,918 +4%
Total 27,580,176 29,468,082 31,359,780 33,352,887 34,854,069 7,273,893 +26%
Change -
Number
n/a 1,887,906 1,891,698 1,993,107 1,501,182
Change –
Percent +7% +6% +6% +5%
1 Changes in Regional totals are for the years 1996-1999. Changes in System totals are for 1995-1999.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
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SECTION 5: SERIOUS CRIME
The Uniform Crime Reporting program (UCR) classifies crimes as Part I and Part II.
Part I crimes are divided into violent crimes against persons and property crimes.
Violent crimes include murder, rape, robbery and aggravated assault. Property crimes
include burglary, theft, motor vehicle theft and arson.
Table 4 profiles serious crime in the System for the five-year period 1995-1999. The
number reported ranged from a low of 526 in 1995 to a high of 655 in 1999, an increase
of 25%. Violent crime declined by one incident. Property crime increased 130 incidents
(26%).
The rate of serious crime in 1999 was 1.88 per 100,000 visitors, .07 per 100,000 visitors
for violent crime and 1.8 for property crime. Approximately two visitors per 100,000
experienced serious criminal victimization in 1999.
Table 4
SERIOUS CRIME 1995-1999
Offense 1995 1996 1997 1998 1999
Change -
Number
Change -
Percent
Homicide/Mans. 7 7 9 10 7 0 --
Rape/Atts. 0 3 1 1 2 -- --
Robbery 5 2 1 1 0 -- --
Aggravate Assault 14 11 8 27 16 +2 +14%
Violent Crime 26 23 19 39 25 -1 -4%
Burglary/Atts. 240 202 271 177 97 -143
Theft 118 349 187 217 197 +79 +67%
Motor Vehicle Theft 31 38 60 55 61 +30 +97%
Arson 111 24 101 100 275 +164 +148%
Property Crime 500 613 619 549 630 +130 +26%
Total Serious Crime 526 636 638 588 655 +129 +25%
Change – Number -- +111 +2 -50 +67 -- --
Change - Percent -- +21% +.01% -7% +11.4% -- --
Serious crime trends on refuges and nationwide are compared in Table 5. Total serious
crime declined nationally in each of the past two years, 12% in total. On refuges it
declined in 1998 and increased in 1999, a net increase for the past two-year period, 4%.
Nationally, violent crime declined each of the past two years. On refuges it increased in
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
21
1998 and declined in 1999. Nationally, serious property crime declined each of the past
two years. On refuges it declined in 1998 and increased in 1999.
Table 5
TRENDS 1998/1997 AND 1998/1999
(PERCENT CHANGE)
Refuges Nation
Offense 1997/1998 1998/1999 1997/1998 1998/1999
Murder +11 -30 -7 -8
Rape -- +100 -3 -7
Robbery -- -100 -10 -8
Aggravated Assault +238 -41 -5 -7
Violent Crime +105 -41 -5 -7
Burglary -35 -45 -5 -11
Theft -16 -9 -5 -6
Motor Vehicle Theft -8 +11 -8 -8
Arson -1 +175 -7 -5
Property Crime -11 +15 -5 -7
TOTAL SERIOUS CRIME -7 +11 -5 -7
SECTION 6: LESS SERIOUS CRIME
From a victim’s standpoint, every crime is serious. For UCR reporting purposes crimes
not classified as Part I, serious, are classified as Part II. These include: simple assault;
forgery and counterfeiting; fraud and embezzlement; stolen property offenses;
vandalism; weapons violations; drunkenness; disorderly conduct; suspicious persons;
curfews and juvenile runaways; and hate and bias crimes. In addition to the
conventional range of Part II crimes, refuges capture data on natural resource
violations, archaeological violations and endangered species violations. Part II crimes
recorded by the refuge system are displayed in Table 6.
Less serious crime increased 16% for the five-year period, 1995-1996. The number of
reported crimes ranged from 14,467 in 1995 to 21,532 in 1997. After peaking in 1997,
less serious crime decreased in both 1998 and 1999:
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
22
Year Change
q  1997 4,559 (+27%)
q  1998 -3,966 (-18%)
q  1999 -777 (-4%).
Table 6
LESS SERIOUS CRIMES 1995-1999
Offense 1995 1996 1997 1998 1999
Change
Number
Change
Percent
Assault 7 26 17 24 17 +10 +142%
Forgery/Counterfeit -- 0 0 5 1 -- --
Fraud/Embezzlement 5 10 1 1 4 -1 -20%
Stolen Property 23 42 58 38 87 +64 +278%
Vandalism 2,268 4,128 4,072 3,793 5,257 +2,989 +132%
Weapons 517 549 421 643 827 +310 +60%
Prostitution/Vice 0 4 2 4 4 -- --
Sex Offense 10 8 65 133 63 +53 +530%
Drug Abuse 289 469 516 624 530 +241 +83%
Gambling -- 3 2 4 5 -- --
DWI 69 106 136 90 110 +41 +59%
Liquor Laws -- 235 375 161 798 -- --
Drunkenness 101 404 95 251 133 +32 +32%
Disorderly Conduct 96 146 163 151 172 +76 +79%
ARPA Violation -- 2 111 57 53 -- --
Nat. Res. Violation1 11,078 10,747 13,898 11,243 7,255 -3823 -35%
Suspicious Person -- 38 240 115 448 -- --
Curfew/Runaways -- 46 863 117 181 -- --
Hate/Bias 4 10 6 6 29 +25 +625
Endangered Species -- -- 173 61 204 -- --
Illegal Aliens -- -- 318 45 611 -- --
TOTAL 14,467 16,973 21,532 17,566 16,789 +2,322 +16%
1 Includes: coal, oil, gas mineral; hazmat; timber theft; wild horse and burro; wildland arson; occupancy
trespass; trespass; hunting and fishing violations.
Natural resource violations are most prevalent, followed by vandalism. These two
categories account for 85% of less serious crime.
Resource and Vandalism Total Percent of Total
1995 13,346 93%
1996 14,875 88%
1997 17,970 84%
1998 15,036 86%
1999 12,512 75%
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
23
SECTION 7: OTHER OFFENSES
Other offenses consist of violations not classified and counted as Part I or Part II.
These include: abandoning/dumping property; camping/fee offenses; permitted/
authorized uses; fish, wildlife, plants and closure offenses. Table 7 displays other
offenses for the four-year period 1996-1999. Number of other offenses ranges from a
low of 4,728 in 1996 to a high of 12,811 in 1999. The profile exhibits extreme
fluctuation from year to year.
Table 7
OTHER OFFENSES 1996-1999
Year Number of Offenses Change: Number Change: Percent
1996 4,728 -- --
1997 10,132 5,404 114%
1998 4,875 -5,257 - 52%
1999 12,811 7,936 132%
SECTION 8: LAW ENFORCEMENT WORKLOAD
The primary measures of law enforcement field workload are calls-for-service and self-initiated
activity. The NWRS has not created a comprehensive and reliable workload
data capture system. Important workload components are captured, however, by the
Refuge Management Information System. RMIS activity categories are:
q  Incidents Documented. Number of incidents formally documented in
refuge files, excluding cases resulting in NOVs.
q  NOVs and State Citations. Number of notices of violations and state
citations issued by refuge officers.
q  Case Assists. Number of cases processed by FWS special agents, state
wildlife officers, and other law enforcement officers, where citations issued
were based solely or largely on the investigation by a refuge officer.
(Definitions from the RMIS Accomplishment Report.) RMIS data also supply a portrait of
dispersion of activity throughout the System.
Total activity for 446 refuges for the three-year period 1997 to 1999, and annual
changes, are:
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
24
Year Total
Change-
Number
Change -
Percent
q 1997 24,472 -- --
q 1998 28,778 4,306 17.6%
q 1999 33,175 4,397 15.3%
For the three-year period, refuge law enforcement activity increased by 8,703 events,
36%. Refuge specific statistics can be found in Appendix 1.
Four refuges, one percent of the total for which data are available, reported 27% of
activity in 1999. Nine others reported an additional 18%. The 13 refuges named below,
3% of the 446 reporting entities, account for half (45%) of the law enforcement activity.
Refuge Law Enforcement Activity -- 1999
q  Parker River 3,365
q  Wichita Mountains 2,029
q  Madison 1,888
q  Merritt Island 1,659
q  Crab Orchard 990
q  Arthur Marshall 868
q  Kenai 710
q  Lacassine 647
q  Imperial 644
q  DeSoto 604
q  Laguna Atascosa 590
q  Wheeler 520
q  Rachel Carson 510
Forty-seven (47) refuges reported between 100 and 500 activities. The remaining 385
recorded 100 activities or fewer.
Additional characteristics emerge from the activity profile:
q  18 refuges (4%) reported no law enforcement activity at all for the past
three years
q  209 refuges (47%) reported increases in activity
q  16 (4%) reported the same level of activity.
Comparisons could not be made for 95 refuges (21%) due to incomplete data.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
25
SECTION 9: CRIME CLEARANCES
A crime is considered cleared when a suspect is arrested and charged with an offense.
Crimes are also cleared by “exceptional” means. Example: sufficient evidence is
present to place charges against a suspect, however some element beyond the control
of the police precludes this from happening. Clearance data are not readily available
from the NWRS. The System is able to supply data for one year only, 1997. (Table 8.)
Clearance rate for serious (Part I) crimes was 14% in 1999. The national average was
21% in 1998. The violent crime clearance rate of 44% lagged behind the national rate of
49%. The property crime clearance rate of 13% was below the 17% rate nationwide.
The NWRS clearance rate exceeded the national rate in two categories, rape and
arson. Both rapes reported in 1999 were cleared as were 51 of the 275 arsons. The
NWRS clearance rate was below the national averages in the remaining categories.
Table 8
REFUGE CRIME CLEARANCE 1997
Category Total Cleared Rate
National Average
– 1998(1)
Murder 7 4 57% 69%
Rape 2 2 100% 50%
Robbery 0 N/A N/A 28%
Aggravated Assault 16 5 31% 59%
Violent Crime 25 11 44% 49%
Burglary 97 12 12% 14%
Theft 197 12 6% 19%
Motor Vehicle Theft 61 5 8% 14%
Arson 275 51 19% 16%
Property Crime 630 80 13% 17%
TOTAL 655 91 14% 21%
(1) Rates for “all agencies” (11,195)
SECTION 10: SERVICE ACTIVITIES
Refuge law enforcement officers render important services to visitors, including search
and rescue and emergency medical services. Table 9 profiles service activities for
1997-1999. The data reflect steady decline, 43% overall, attributable to a 59%
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
26
decrease in the “other” category. SAR, EMS and education activities increased
moderately in number.
“Other” service incidents predominate, accounting for 60-80% of the total. Education
activities rank second in volume, ranging from 20-40% in varying years. SAR and EMS
are quite marginal comparatively, accounting for 1.4% and 1.1% in 1999.
Table 9
SERVICE ACTIVITIES 1997-1999
Service 1997 1998 1999
Change
Number
Change
Percent
SAR 217 246 315 +98 +45%
EMS 122 63 237 +115 +94%
EDUC 7,490 4,573 8,819 +1,329 +18%
Fires (not arson) 183 -- 137 -46 -25%
Other Service Incident 31,562 21,429 12,954 -18,608 -59%
TOTAL 39,574 26,311 22,462 -17,113 -43
SECTION 11: TRAFFIC INCIDENTS
Refuge law enforcement entails a range of traffic activities. “Traffic,” in the refuge
setting, involves standard motor vehicles, boats, aircraft, and off-road vehicles. Table
10 displays number of traffic incidents for the five-year period 1995 to 1999.
For the three years for which complete data are available, 1997-1999, number of traffic
incidents increased, 4,856, 60%. The change was powered by an extraordinary
increase in Off-Road violations, 245%. During this period, Traffic activities declined
marginally. For the five-year period they increased measurably, 36%. Boat incidents
are on the increase. Aircraft incidents are decreasing. Annual fluctuations, extreme in
all cases, characterize each category of traffic incident.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
27
Table 10
TRAFFIC INCIDENTS 1995-1999
1995 1996 1997 1998 1999
Change -
Number
Change -
Percent
Traffic 3,423 3,798 4,804 3,423 4,642 +1,219 +36%
Boat 945 824 1,051 945 1,886 +941 +100%
Aircraft 220 195 409 1,435 208 -12 -5%
Off-Road -- -- 1,792 1,302 6,176 -- --
TOTAL 4,588 4,817 8,056 7,105 12,912 8,324 +181%
Change-Number +229 +3,239 -951 +5,807 -- --
Change-Percent 5% +67% -12% +82% -- --
SECTION 12: RESOURCES – EXPENDITURES
Expenditures for law enforcement for the three-year period 1997-1999 were:
Year Expenditures Change – Number Change – Percent
q FY 1997 $10,045,000 -- --
q FY 1998 $10,866,000 $ 821,000 8.1%
q FY 1999 $14,481,000 $3,615,000 33.3%
For the period, expenditures increased $4,436,000, 44%. These data include
expenditures for boundary posting materials and staff time for maintaining boundary
postings, which NWRS officials indicate skews the data (toward the high side).
Law enforcement is not segregated in national or refuge budgets. Expenditures are
covered from general refuge funds. The national budget includes two law enforcement
line items: $300,000 for applicant background investigations; and $500,000 from the
Office of National Drug Control Policy for drug programs. FLETC has a law
enforcement budget.
SECTION 13: RESOURCES – STAFFING
The NWRS employs 602 Refuge Officers, 62 full-time (10.3%) and 540 collaterals
89.7%). (Data as of October, 2000.) Full-time officers commit their entire work week to
law enforcement activity. Collaterals commit widely varying amounts of time. The
NWRS was not able to supply staffing trends data for recent years.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
28
SECTION 14: RESOURCES – STAFF DAYS
Staff days consumed in law enforcement provides another and a more precise measure
of law enforcement staffing. Total number of staff days committed to law enforcement
by both classes of refuge officers for the three-year period 1997-1999 were:
Year Total Staff Days Change – Number Change – Percent
q FY 1997 39,129 -- --
q FY 1998 41,276 2,147 5.5%
q FY 1999 48,842 7,566 18.3%
For the period, number of hours increased 9,713, 24.8%. Refuge-specific data can be
found in Appendix 2. As is the case with expenditures, NWRS officials indicate that
these data are skewed (again, toward the high side).
The 48,842 8-hour days committed to law enforcement in 1999 factors out to 244 full-time
equivalents (FTE’s). Using a law enforcement industry average of 1,600 on-duty
hours per year, about 200 8-hour workdays/shifts, the NWRS law enforcement workload
is being handled by the equivalent of 244 officers (48,842 ¸ 200). This work is
distributed among 62 full-time officers who devote their entire workday to law
enforcement and the equivalent of 182 collateral duty officers. The 62 officers are
investing 12,400 days (62 x 200), 25% of the total, leaving 36,442, 75%, to 540
collaterals, spread over 530 refuges. This calculation suggests that collaterals average
67 eight-hour shifts annually (36,442 ¸ 540), about one-third of their work year (an
estimate of 201 on-duty days and about 1.7 days per week (one-third of five days). We
do know from the data array in Appendix 2 that staff days are not distributed evenly
among refuges and officers.
Four refuges, less than one percent of the total for which data are available (446),
accounted for 11.3% of reported staff days in 1999. Twelve others, 2.7%, accounted for
an additional 16.2%. The 16 refuges named below account for 28% of total staff days
committed to law enforcement.
Refuge Staff Days – 1999
q  Rocky Mountain Arsenal 2,103
q  Kenai 1,277
q  Chincoteague 1,073
q  Crab Orchard 1,050
q  Edwin Forsythe 918
q  Devil’s Lake 863
q  Arthur Marshall 831
q  Wichita Mountains 830
q  Don Edward 671
q  Okefenokee 600
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
29
Refuge Staff Days – 1999
q  National Key Deer 600
q  Cache River 540
q  Parker River 538
q  Patuxent 535
q  Cabeza Prieta 509
q  Chase Lake WMD 500
One hundred twenty-one (121) refuges reported between 100 and 500 law enforcement
staff days. The remaining 309 reported 100 staff days or fewer.
SECTION 15: RESOURCES – WORK DISTRIBUTION
Officers’ own estimates of how much time the devote to law enforcement work are:
Time Committed Officers – Number Officers – Percent
q  0-20% 102 33.9%
q  21-40% 70 23.3%
q  41-60% 52 17.3%
q  61-80% 18 6.0%
q  81-100% 59 19.6%
301 100.0%
These estimates, from the Workforce Survey (see Chapter III), are disaggregated in
Table 11.
Table 11
TIME COMMITTED TO LAW ENFORCMENT
Class Time Commitment (%) Officers - Number Officers - Percent
q Full Time Officers q  0 – 20 0 0
q  21 – 40 1 2.4%
q  41 – 60 2 4.8%
q  61 – 80 3 7.1%
q  81 – 100 36 85.7%
q Refuge Operations Specialists q  0 – 20 44 40.7%
q  21 – 40 33 30.6%
q  41 – 60 18 16.7%
q  61 – 80 5 4.6%
q  81 – 100 8 7.4%
q All Others q  0 – 20 58 38.4%
q  21 – 40 36 23.8%
q  41 – 60 32 21.2%
q  61 – 80 10 6.6%
q  81 – 100 15 9.9%
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
30
SECTION 16: STAFF PROFILE
Tables 12, 13, 14 and 15 profile important characteristics of NWRS law enforcement
officers and managers. These data, culled from the workforce surveys, constitute a
large, self-selected sample.
NWRS law enforcement officers span the entire range of age categories. (Table 12.)
About 75% of law enforcement officers are in 31-50 age ranges. Two sizeable sets of
officers cluster in the ranges on either side of the 31-50 groupings. Full-time refuge
officers are marginally younger than the staff as a whole. Just over 60% are 40 or
under, compared to 50% for remaining classes. Managers are considerably older.
Close to 70% are in the 41-55 range. Ten percent (10%) are in the 56-60 age bracket.
Table 13 arrays the experience level of 307 law enforcement officers and 236
managers. Eighty-three percent (83%) of officers who conduct law enforcement work
have been with the FWS for six or more years. Almost half have 10 years of service or
more. At the front-end of the continuum are 11% of officers (10.7%) who have three
years of service or less. Almost 100% of managers have six or more years of service
with the FWS. Over 90% have 10 or more years of FWS service.
Table 14 displays the experience of 302 officers and 236 managers in current positions.
For officers, experience is distributed throughout the continuum with major clusterings at
the 1-2, 3-4, 10-14, and 20 or more brackets. Experience distribution within position
classes also reflect widespread dispersion. Experience of managers in current
positions clusters at the back-end of the continuum, especially in the 10-14 and 20 or
more brackets.
Managers have substantial law enforcement experience:
Years Number of Managers Percent of Managers
0 24 10.2%
1-2 7 3.0%
3-4 7 3.0%
5-9 28 11.9%
10-14 55 23.4%
15-19 44 18.7%
20+ 70 29.8%
235 100.0%
Over 80% of managers (83.8%) have five years of service or more as a refuge law
enforcement officer. Ten percent (10%) have none.
Table 15 profiles the education of 295 officers and 236 managers. Eighty-five percent
of officers have a bachelor’s degree or higher. Almost 21% have a graduate degree.
The educational credentials of managers are higher. Almost 100% have bachelors or
graduate degrees.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
31
Table 12
AGE PROFILE
20-25 26-30 31-35 36-40 41-45 46-50 51-55 56-60 61+ Total
Refuge LE Officer – FT 3 5 11 7 7 6 2 1 - 42
Refuge Operations Spec. 2 8 30 15 14 22 7 1 - 99
Outdoor Recreation Planner - - 1 14 1 5 1 1 - 23
Police Officer - 1 3 1 - 1 - - - 6
Maintenance Worker - 2 - 3 4 2 4 3 1 19
Park Ranger 1 2 3 2 - 2 2 1 - 13
Biological Technician - 4 2 2 1 1 2 1 - 13
Refuge Biologist - 4 4 2 2 8 4 - - 24
Other - 3 11 14 16 14 8 2 1 69
TOTALS 6
(2.0%)
29
(9.4%)
65
(21.2%)
60
(19.5%)
44
(14.3%)
61
(19.9%)
30
(9.8%)
10
(3.3%)
2
(0.1%)
307
Managers 0 2 11 29 40 71 55 24 4 236
(0.8%) (4.6%) (12.2%) (16.9%) (30.1%) (23.3%) (10.1%) (1.6%)
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
32
Table 13
EXPERIENCE PROFILE - 2000
YEARS WITH FWS
0-1 2-3 4-5 6-7 8-9 10-11 12-15 16-20 21-25 26-30 30+ TOTAL
S
Refuge LE Officer – FT 4 8 5 6 1 2 6 4 4 - - 40
Refuge Operations Spec. - 4 4 6 11 27 23 9 23 1 1 109
Outdoor Recreation Planner - 1 1 - 3 - - 1 4 - - 10
Police Officer 1 - 1 1 1 1 - - 1 - - 6
Maintenance Worker - 1 1 - 2 2 4 4 4 2 - 20
Park Ranger 3 - 3 - 1 2 1 - 3 - - 13
Biological Technician 1 4 - - 1 2 1 - - 1 2 12
Refuge Biologist - 3 3 1 - 3 2 - 6 4 - 22
Other __ 3 __ 6 12 8 7 11 22 5 1 75
TOTALS
9 24 18 20 32 47 44 29 67 13 4 307
(2.9%) (7.8%) (5.9%) (6.5%) (10.4%) (15.3%) (14.3%) (9.4%) (2.2%) (4.2%) (1.3%)
Managers 3 4 1 4 8 14 23 36 85 34 24 236
(1.2%) (1.6%) (0.4%) (1.7%) (3.4%) (6.0%) (9.8%) (15.1%) (36.1%) (14.3%) (10.1%)
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
33
Table 14
EXPERIENCE PROFILE – 2000
CURRENT POSITION
1-2 Years 3-4 Years 5-9 Years 10-14 Years 15-19 Years 20 or More TOTALS
Refuge Law Enforcement Officer FT 15 6 11 7 3 14 56
Refuge Operations Specialist 14 33 - 24 12 12 95
Outdoor Recreation Planner 1 3 1 1 1 3 10
Police Officer 1 3 - 1 - 1 6
Maintenance Worker 2 1 - 8 3 5 19
Park Ranger 3 3 3 2 1 1 13
Biological Technician 3 2 2 2 1 2 12
Refuge Biologist 5 3 6 5 1 2 22
Other 11 15 19 10 7 7 69
TOTALS 55 69 42 60 29 47 302
(18.2% (22.8%) (13.7%) (19.5%) (9.4%) (15.6%)
Managers 17 19 41 62 36 60 236
( 7.2%) ( 8.1%) (17.4%) (26.4%) (15.3%) (25.5%)
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
34
Table 15
EDUCATION
High
School
Some
College
Associate
Degree
Bachelors
Degree
Graduate
Work
Graduate
Degree TOTALS
Refuge LE Officer FT 3 14 4 19 2 - 42
Refuge Operations Specialist - - 1 75 3 30 109
Outdoor Recreation Planner - - - 8 1 1 10
Police Officer - 2 - 4 - - 6
Maintenance Worker 1 10 4 2 2 - 19
Park Ranger - - 1 7 2 3 13
Biological Technician - 2 4 5 1 - 12
Refuge Biologist - - - 14 - 8 22
Other - - __ 40 3 19 62
TOTALS 4 28 14 174 14 61 295
(1.4%) (9.5%) (4.7%) (60.0%) (4.7%) (20.7%)
Managers 0 1 3 128 36 68 236
(0.4%) (1.3%) (54.2%) (15.3%) (28.8%)
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
35
SECTION 17: LINE OF DUTY DEATHS AND ASSAULTS
Since 1996, at least 14 refuge law enforcement officers have been assaulted, 11 in
1996, none in 1997, and three in 1999. (No data are available for 1998.) (Table 16.) In
1999, there were 619 refuge officers. The officers assaulted rate was 0.5%.
Table 16
OFFICERS KILLED/ASSAULTED 1996-1999
1996 1997 1998 1999
Change
Number
Change
Percent
Killed 0 0 N/A 0 0 --
Assaulted 11 0 N/A 3 -8 -72%
SECTION 18: OBSERVATIONS
The foregoing factors and trends have important implications for policing the NWRS –
today and tomorrow. Combined with other study information they inform judgements
concerning the capacity of the law enforcement function to contribute to the core mission
of the FWS.
q  The System. The breadth and diversity of the System demand local,
refuge-based management of and accountability for the law enforcement
function. The current Project Leader-based authority and accountability
structure is the proper model for the NWRS and should be retained.
Strengthened centralized efforts at the national and regional levels are
recommended later in the report.
The sheer number of refuges, extreme variations in size and visitation,
geographical dispersion, long distances between refuges, and, in many
instances, isolation, complicate and challenge management of the law
enforcement function. This configuration of factors limits potential for
standardization, resource leveraging, interpersonal communication, and
management proximity.
q  Visitation. Population is a powerful correlate of law enforcement
requirements. Population growth, law enforcement workload, and resource
requirements correlate positively. Visitation is the NWRS equivalent of
“population.” It is a primary service base.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
36
Visitation is increasing at an annual average of 6.6%. Between 2.3 and 2.6
million additional visitors will have to be serviced by refuge officers for the
next several years. Visitation can be expected to reach 42,000,000 by
2002. Unused law enforcement capacity does not currently exist.
Accordingly, the visitation trend argues for staff augmentation.
Augmentation, if and when it occurs, must be cost-justified not only on
overall/ macro trends but on a refuge-by-refuge basis.
q  Visitor Safety. Refuges are very safe places for visitors. Approximately
two of every 100,000 visitors are victims of serious crime, and that crime is
far more likely to be a property crime than a violent (person) crime. The
comparable victimization rate for the National Park Service, also a very
safe place, is less than one visitor per 100,000 (serious crime). The
comparable rate nationally in 1999 (all cities and towns reporting Uniform
Crime Statistics) was 4,619 serious crimes per 100,000 inhabitants. Rate
of violent crimes was 568/100,000.
q  Serious Crime. Unacceptable rates of serious crime, crime that is
trending upward, and or unacceptable levels of specific crimes, especially
violent crimes, require intense and immediate response – program
initiatives, technology, staff increases, or a combination. None of the
foregoing conditions prevail in the NWRS policing environment. Fewer
than 700 serious crimes are reported annually. A majority of refuges do
not report even one violent crime a year. No individual offense type occurs
in number or a rate which is a basis for more than ordinary concern.
Serious crime has been trending upward, attributable, to increases in
reported arsons. Nothing in the NWRS serious crime profile suggests a
need for staffing augmentations, nor special intervention, except the trend
in arsons, a particularly threatening crime for many heavily forested
refuges. The increase in serious crime is consistent with visitation
changes.
q  Less Serious Crime. Less serious crime is far more prevalent than
serious crime, but still marginal in rate of occurrence on many refuges.
Successive decreases in 1998 and 1999 are notable. Despite substantial
increases in visitation, the incidence of less serious crime in 1999
paralleled that of 1995. This relationship is not consistent with visitation
trends, overall, but is in selected areas, vandalism being most evident.
Trends exist in several offense categories that FWS law enforcement
managers should explore and explain. The precipitous decline in natural
resource violations in 1999, 35% lower than 1998, and 47% lower than in
1997, is compelling. Being a product of proactive initiative, declines of this
nature can be attributable to deliberate reversal of law enforcement
emphasis, indifference, staffing/time shortfalls, or any combination thereof.
We do not believe that resource violations are declining in fact. This does
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
37
not seem plausible in view of recent historical incidence (reported) and
visitation trends.
The dramatic increase in vandalism, 132% in five years, 27% higher in
1999 than in 1996, the previous peak, clearly requires analysis,
exploration, and immediate response. Increases in weapons and drug
abuse violations promote questions. In each case, causation may lie in
more aggressive law enforcement work, expanding problems, or both.
NWRS speculate that trends may be due to decreased emphasis by
inexperienced refuge officers, extra funds for drug work, “sensationalism”
of weapons violations, and competing time demands with no incentives to
work on law enforcement reports. It is the responsibility of NWRS
managers to clarify and confirm causation in all categories.
With regard to all the four offense situations cited, if crime analysis
confirms a resource shortfall causation or a burgeoning problem, staffing
augmentation is indicated.
q  Other Offenses. Reported data reflects increasing incidence of offenses
in this class, which would be expected in view of visitation trends. The
trend is also characterized by extraordinary annual fluctuation, the
magnitude of which calls the reliability of data into question. The data are,
simply, too erratic to be believable.
The NWRS is advised to reconsider its reporting format for this class of
offenses. Issuing other offense data in aggregate form conceals specific
trends and problems which may exist and limits development of targeted
responses. If there is any validity whatsoever to the other offense data, the
increase would be consistent with refuge use/visitation trends.
Refuge Law Enforcement Activity. The increase in total activity between
1997 and 1999, 36%, is substantial. This increase is not consistent with or
explained by Part I and II crime patterns, which it should be to a degree.
The 8,703 event increase in total law enforcement activity from 1997 to
1999 has been paralleled by a 4,743 decline in Part II incidents, producing
a “gap” of 13,446 events.
Reliability concerns notwithstanding, law enforcement activity data are
instructive. The data demonstrate ever so clearly the degree to which the
System is composed of refuges where law enforcement events are highly
episodic. Almost 400 refuges record a law enforcement event 100 or fewer
times each year, one every three-to-four days. About 10% experience
moderate activity, 100-500 per year, about one a day. Only 14 refuges
(3%) report 500 or more law enforcement events annually. Based on
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
38
reported activity alone, most refuges cannot cost-justify full-time law
enforcement officers. Collateral duty must remain a prominent practice.
Simultaneously, the activity pattern calls for alternative forms of law
enforcement organization. Law enforcement officers, full-time and
collateral, are currently assigned/restricted to one refuge. Ingrained
refuge-by-refuge, full-time or collateral staffing practice inhibits innovation.
Multiple-refuge staffing models should be considered. To proceed
productively, the NWRS needs a rational, data-driven refuge law
enforcement officer allocation and deployment scheme, an asset it does
not possess at this time.
q  Clearances. Nationally, about one in five (21%) serious crimes is cleared.
The refuge system law enforcement program does less well, clearing 14%.
This is attributable in large measure to the transience of the refuge
population and the limited corps, geographical dispersion, and priorities of
investigative specialists – the staff of the Division of Law Enforcement. The
NWRS is simply not positioned to perform as well as many law
enforcement agencies. Still, a detailed review of investigative practices is
warranted, with a focus toward improvement. Like residents of
communities across the country, visitors expect refuge law enforcement to
close cases, bring offenders to justice and return property.
q  Service Activities. By conscious choice, absence of conscious choice, or
due to staff shortages and transcending refuge priorities, NWRS law
enforcement personnel are no longer servicing clientele to the degree they
did in the very recent past. For the three-year period 1997 to 1999 service
activities declined 43% (17,113 incidents), attributable in entirety to a 59%
decline in one category “other service incidents.” This phenomenon
deserves analysis, and perhaps response.
As with the “Other Offenses” category (Section 7), the absence of detail
concerning what “Other Service Incidents” comprise precludes examination
of the components of the decline. This is another database issue for the
NWRS to address. The overall decline, assuming reliability of reported
data, poses a series of questions which we cannot either analyze or
answer due to the aggregation of services.
q  Traffic. Traffic incidents have increased almost 200% since 1995 and by
more than half since 1997. Off-road violations have exploded in number.
The magnitude of the increase, most of it in 1999, signals deliberate law
enforcement intervention and proactivity.
Further detail on traffic activity, particularly number of crashes, substance
abuse causation, and violator profiles, would assist understanding and
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
39
planning of further interventions significantly. Each of these data areas
would supply valuable information for prevention and control.
As a workload component, traffic incidents are very meaningful, not rivaling
but distantly approaching less serious crimes in volume (13,000 vs. 17,000
in 1999).
q  Law Enforcement Staffing. The staff days calculation, coupled with
visitation trends establishes a prima facie case for staffing supplements.
An FTE law enforcement complement of 244 officers, 90% of whom spend
two-thirds of their time on other duties, seem quite modest. Our estimate
of 244 is for 1999. Equivalents for 1997 and 1998 would be substantially
lower.
The NWRS and FWS tend to frame staffing considerations – thinking and
perhaps, decisions, on a base of 602, most of whom are collaterals. This
number clearly misrepresents the reality. Staffing considerations should
proceed from a base of 244. This should alter focus, foster more
penetrating analysis, and produce more cogent staffing decisions.
q  Expenditures. The absence of expenditures detail and staffing trends
data precludes analysis of and judgements about funding levels generally
and historically, and the significance of the 44% increase in expenditures
between 1997 and 1999.
The $14.5 million expenditures for law enforcement in 1999 contrasts with
$94.5 spent by the National Park Service for law enforcement the same
year. The NWRS is policing 530 refuges. The NPS is policing 373 park
units. The NWRS is funding the equivalent of 244 law enforcement
officers. The NPS is funding 2,200 rangers, full-time and seasonal. NWRS
visitation was 35 million in 1999. NPS visitation was 436 million. NWRS
acreage is 93.5 million. NPS acreage is 92 million. Configurations and law
enforcement demands of the two systems differ in major ways, as do
current law enforcement cultures. The data do not suggest that NWRS law
enforcement expenditures are grossly out of balance, with those of the
NPS, either high or low. It is very significant to note that a recent IACP
study concluded that NPS law enforcement is “under-resourced.”
q  Line-of-Duty Deaths and Assaults. Line-of-duty deaths and assaults are
minimal. Three assaults occurred in 1999. NWRS data show no line-of-duty
killings. Positive statistics notwithstanding, refuge officers are
continually exposed to danger. Many refuge users are armed, hunters in
particular. Substance use and abuse is part of the American culture today.
Back-up is a priority concern throughout the System, properly so. Priority
must always be accorded to officer safety.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
40
q  Staff Profile. Overall, the staff profile bodes well for 21st Century
organizational transformation. Change occurs most effectively in mature
organizations with well-educated and experienced staffs. Law enforcement
staff is highly educated. The heaviest concentration of advanced education
are among refuge operations specialists, park rangers and biologists.
Managers have even higher levels of education.
Special initiatives are required when an agency has a substantial cadre of
young and/or modestly experienced law enforcement officers. These
include intense supervision and mentoring, more frequent performance
evaluation, and higher degrees of remedial in-service training. The NWRS
appears to be in this position. While the spread and blend of experience
among law enforcement officers with the FWS is normal (statistically), the
same pattern does not prevail with regard to experience in law enforcement
positions. Substantial clusters of short tenures exist. Almost 20% of law
enforcement officers have two years experience or less in their current
positions. Another 22% have four years of experience or less in current
positions.
The brevity of these experience tenures become more problematic when
the infrequency of law enforcement events in most refuges is considered.
Far too many law enforcement officers simply do not accumulate law
enforcement event experience to the degree required for confidence and
safety. Innovations in training and assignment practices are called for to
compensate for this condition.
SECTION 19: SUMMARY
We convey these summary judgements of the implications of factors and trends with a
sober wariness rooted in distrust of the completeness and reliability of NWRS data. Still,
we suggest that the factors and trends portray expanding law enforcement requirements.
Visitation is increasing materially, over two million visitors annually. Growth is spawning
increases in serious crime, other offenses, law enforcement activity, traffic incidents, and
staff day/resource commitments to law enforcement. Threat to the core objective of the
NWRS – conserving wildlife and their habitats, emerge from trends data. Vandalism
increases are pronounced. Proactive commitment to prevention of resource and ARPA
violations may be diminishing in priority, eroding, not being reported, or passed on to
other law enforcement agencies. The shift toward public use generated law enforcement
requirements commented upon by so many refuge managers and officers during our
field visits is in evidence, statistically. Drug abuse, marijuana cultivation, drug trafficking,
drunkenness, weapons violations, illegal alien activity, and liquor law violations are all on
the increase.
These conditions call for increased investment in law enforcement – for programs, staff,
and technology.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
41
To retain the currently excellent level of safety for System visitors/users and to intensify
the law enforcement proactivity that is so central to achieving the core mission, NRWS
leaders should enhance the quantity and quality of law enforcement. Quantity
enhancement could come from the current complement of collaterals, by committing a
greater degree of their time to law enforcement, or from augmentation – new positions.
The law enforcement complement of the NWRS is modest, the equivalent of 250 officers
for a System composed of 530 refuges, 37 wetland management areas, and 93.5 million
acres. Accordingly, augmentation does not seem to be achievable within current
capacity, by reordering duty priorities among collaterals, without sacrifice to other equally
crucial NWRS functions. New positions are in order. Quality enhancement is more likely
to occur through the addition of full-time officers who, for many reasons, bring or develop
greater law enforcement interest, intensity, and experience.
The potential of an enhanced law enforcement function cannot be maximized within the
current organizational, cultural, and program framework. The current framework is
studded with management and operational flaws. Expansion must occur within the
context of a New Vision of law enforcement. In addition to increasing law enforcement
staff capacity – quantitatively and qualitatively, foundations of the New Vision should
consist of:
q  A more powerful voice for law enforcement at the national FWS executive
level
q  Increasingly unified systemwide practices, achieved through greater clarity
of objectives and more coherent policies and procedures
q  Innovation in refuge law enforcement organization and service delivery
q  Rational, data-driven officer allocation and deployment
q  Technology, equipment, and information supplements for field personnel
q  A comprehensive central support system for the law enforcement function
q  More professional and effective recruitment and selection processes
q  Intensified law enforcement training
q  Strengthened research, analysis, and planning support for refuges and field
officers
q  A management-tailored data system
q  A predictable and protected funding stream.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
42
The Vision should include and reinforce the many strengths of the current law
enforcement program including decentralization, open and vibrant interpersonal
communications, and an impressive congruence of attitudes and perspectives among
System law enforcement managers and officers.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
43
CHAPTER II: THE LAW ENFORCEMENT INFRASTRUCTURE
The capacity of the NWRS to meet its protection and law enforcement obligation depends
upon the level and quality of resources committed and how resources are organized,
managed, programmed and controlled. This chapter examines a number of these
infrastructure considerations: organization; staffing; objectives; policies and procedures;
recruitment, selection and promotion; training; professional standards; and data systems.
The chapter also offers a lengthy series of recommendations that will help lay the
foundations for the new vision of the NWRS law enforcement sketched in the summary of
the preceding chapter.
SECTION 1: THE NWRS LAW ENFORCEMENT CULTURE
A series of attributes frame the NWRS law enforcement culture. They are correlates of
the infrastructure conditions and practices examined in this chapter and will heavily
influence the pace and success of implementation of recommendations made on the
pages that follow, should the NWRS wish to implement them. Some attributes bode well
for successful organizational and cultural transformation. Most do not – these are better
viewed as challenges.
q  The Prime Asset. The law enforcement workforce, both full-time and
collateral duty, is genuinely dedicated to the FWS mission. Full-time
personnel are well trained and deliver quality law enforcement services.
Collateral duty officers work to the best of their competencies, which relate
directly to the frequency with which they perform law enforcement duties.
All enforcement staff, managers, and officers are highly educated.
q  Readiness for Change. Field interviews with both managers and officers,
demonstrate an institutional readiness to change current law enforcement
conditions, including increased emphasis on the addition of full-time
officers and elevation to equal status with other NWRS service functions.
Both classes express frustration with secondary status accorded to law
enforcement by the FWS.
q  Secondary Status. The USFWS employs many means to protect wildlife
and natural resources. The law enforcement mission appears to be looked
upon as necessary but not as vital to FWS operations as number of other
functions. Although the first wildlife officer had law enforcement powers, a
reading of the organization’s history indicates that the law enforcement
authority was granted as an add-on or additional duty, to be used only in
rare cases when needed. Secondary status is reinforced and has been
historically, by a “tolerance,” of public use focus and activity.
q  A Changing Refuge Environment. Only in recent years has an organized
public use and visitation marketing effort been undertaken. The number of
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
44
visitors is increasing measurably. This increase is bringing many of the
problems typically confronted by state and local law enforcement agencies
such as drug use; alcohol-related incidents, including DUI; person-to-person
crime; homeless-related activity; and gang and sexually-deviant
incidents. This trend should continue, changing the refuge dynamic.
q  An Unfinished System. Not surprising in view of the preceding attribute,
we find an “evolved” law enforcement function rather than a carefully
considered and constructed system comprised of the full complement of
the essential components required to satisfy requirements of a law
enforcement system. We find randomness rather than design.
q  Law Enforcement Balkanization. The law enforcement function is locally
controlled and administered with marginal guidance from the national level.
This results in fragmented and inconsistent approaches to law enforcement
service delivery, with insufficient accountability for accomplishment or
monitoring, of all levels.
q  Underserved Refuges. The full-time and collateral duty law enforcement
mix is a problem in many areas, ranging from personnel to safety. In
refuges with the collateral duty officers only, the majority, the law
enforcement commitment is quite limited. In some sites visited, no law
enforcement operations are visible, due to the demands of primary duty
assignments. We have been made aware of refuges that have no
weekend law enforcement coverage.
q  Refuge-Bound Allocation and Deployment. The foregoing condition is
directly attributable to the absence of a governing, professionally
rationalized staffing allocation and deployment plan. The condition is
further aggravated by the “refuge-bound” nature of resource and
acquisition practices. Managers, perhaps as a result of extreme
decentralization of responsibility, do not tend to think beyond the zones of
their own refuge. This is not inconsistent with practices in any organization
in which competition for finite resources is prevalent.
q  Dominance of Collateral Duty. The Service relies primarily on collateral
duty officers whose primary activities concentrate on non-law enforcement
refuge preservation tasks. This system assumes and requires that an
employee with a mixed set of job requirements can conduct law
enforcement functions effectively whenever demand occurs. The system
exhibits distinct operational/performance flaws:
-  The law enforcement competencies of collateral duty officers
degrade directly with lack of utilization of law enforcement skills
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
45
-  Officers who do not employ law enforcement skills with requisite
frequency are at greater risk for failure and possible injury when
attempting to employ the skills
-  Focus on law enforcement is diluted, reducing funding potential and
appreciation for linkage to the core mission.
At the same time, the collateral system in the only cost-justifiable approach
to law enforcement in the majority of refuges, as the NWRS is presently
organized for law enforcement.
q  Primitive MIS Capacity. The law enforcement management function
suffers from the absence of a database and data capture capability that is
reliable and accessible at the refuge, regional, and national level for
effective crime analysis, resource deployment, and goal/objective
achievement. This problem flourishes, in part, by minimized demands from
headquarters for data-justified evaluation of law enforcement success or
failure.
SECTION 2: ORGANIZATION
The USFWS law enforcement authority, operations, and responsibilities are distributed
among executives and officers at three levels and locations:
q  FWS/NWRS executive level in Washington
q  Regions
q  Refuges.
System operations are highly decentralized and characterized by delegation of
substantial power to refuge managers.
USFWS/NWRS – Washington. Principal law enforcement executive/line officials
and support staff at the Washington headquarters level are: the Director of the Fish and
Wildlife Service; the Chief of the National Wildlife Refuge System; Visitor Services and
Communications Division Chief; the National Refuge Law Enforcement Coordinator; and
the National Refuge Training Coordinator.
The Director of the Fish and Wildlife Service, the chief executive officer, has ultimate
responsibility for refuge law enforcement – vision; goals; objectives; resources;
programming; performance; and control. The Director reports to the Assistant Secretary
for Fish, Wildlife, and Parks.
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46
Refuge protection/law enforcement is the responsibility of the Refuge Program, which is
located within the Division of Visitor Services and Communications, a component of the
National Wildlife Refuge System (NWRS). (See Figures 1 & 2.) The NWRS consists of
four divisions and two offices, each organized and staffed to supply essential central
services: Air Quality; Fire Management; Information Management; Outreach and Visitor
Services; Planning and Policy; Tactical Services; Wildlife Resources. An operational law
enforcement branch has not been established at the national level.
There are three positions in the Visitor Services and Communications Division that
provide law enforcement support services, the National Refuge Law Enforcement
Coordinator, the National Refuge Law Enforcement Training Coordinator and the
Administrative Technician. The National Refuge Law Enforcement Training Coordinator
and the Administrative Technician are located at the Federal Law Enforcement Training
Center in Glynco, Georgia.
The Law Enforcement Coordinator focuses on policy development, personnel issues,
planning, and special projects. The position has no direct control over Regional Refuge
Law Enforcement Coordinators or refuge LEOs. While assignments come from a variety
of persons at the headquarters level, the National Refuge Law Enforcement Coordinator
reports to the Division Chief, Visitor Services and Communications.
The National Refuge Law Enforcement Training Coordinator coordinates development,
scheduling, and delivery of entry-level and in-service training of refuge LEOs and
management and supervisory training. The liaison reviews in-service training which is
developed by regions and is responsible for issuing personal equipment to recruits
(including weapons, leather gear, ballistic vests, etc.).
The DOI Law Enforcement Administrator, organizationally sited in the Office of the
Secretary of the Interior, is responsible for law enforcement policy and policy compliance
of the five agencies of the DOI that conduct law enforcement operations: the U.S. Fish
and Wildlife Service; National Park Service; U.S. Park Police; Bureau of Land
Management; and the Bureau of Reclamation. This obligation is exercised through the
Office of Managing Risks and Public Safety (MRPS). MRPS is empowered to
promulgate law enforcement policy, procedures, and standards; coordinate and monitor
implementation of law enforcement programs, through a standardized inspections
program; and approve and clear candidates for bureau or law enforcement administrator
positions.
Regions. The regional law enforcement chain of command consists of the
Regional Director; a Regional Chief of NWRS; and a Chief of Refuge Operations or
equivalent. A Regional Law Enforcement Coordinator functions in a non-line capacity.
Each of the seven regions has a Director, who supervises a Regional Chief of the
National Wildlife Refuge System. A Regional Refuge Law Enforcement Coordinator
(RRLEC) reports directly or indirectly to the Regional Chief of Refuges. The role of the
RRLEC is to coordinate refuge law enforcement activities within the region. RRLEC
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
47
Figure 1
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
48
Figure 2
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
49
duties vary by region. In most, activities concern personnel, training, equipment
purchase, and allocation of drug funds. The RRLEC may coordinate development of
regional policy. The more proactive coordinators interact, inter-regionally, on training
and other issues. RRLECs have no direct command authority over LEOs. RRLECs
generally hold law enforcement commissions, however some have relinquished them to
conform to grade level limitations for commissions. There is a non-command channel
from the National Law Enforcement Coordinator, through Regional Refuge Law
Enforcement Coordinators, to the refuge level Project Leaders or to senior full-time or
collateral duty law enforcement personnel at the refuges.
Refuges. A variety of organization/staffing combinations exist in Refuges. The
titles Refuge Manager and Assistant Refuge Manager are held by refuge workers, but
refuge management and control is vested in the position of Project Leader. A Project
Leader, or at larger refuges or refuge complexes, a Deputy Project Leader or Assistant
Project Leader or Refuge Manager, supervises law enforcement. Project leaders
prepare the law enforcement portion of the budget and control disbursement of funds.
Project leaders may or may not have prior law enforcement experience and may or may
not hold law enforcement commissions. On refuges with a full-time commissioned
Refuge LEO, supervision of the law enforcement function may be delegated to the most
senior of these officers.
Refuge LEO cadres are composed of three types of officers:
q  Full-Time Law Enforcement Officers. FTLEOs perform law enforcement
functions only. They are generally in the 083 police officer classification.
They function at full performance level, GS-7/8. Recently developed
position descriptions will reclassify this position to the GS-0025 park ranger
series. No supervisory positions exist for this class of officer. However,
officers with position titles such as Refuge Manager and Operations
Specialist perform full-time law enforcement operations (at the GS-11 level)
and are considered by Project Leaders to be supervisors of the law
enforcement function. All are trained at FLETC.
q  Seasonal Law Enforcement Officers. SLEOs have the same authority as
FTLEOs, but only within the boundaries of the refuge. They cannot enforce
the Migratory Bird Act Treaty or attend the basic training course at FLETC.
They receive entry-level training through the NPS college-based seasonal
program. They do not attend in-service or specialized training courses.
SLEOs are hired on a season-by-season basis. Indications are that FWS
will eliminate this category of officers in the near future, relying instead on a
cadre of temporary-subject to furlough officers, which will eliminate many
hiring problems associated with the seasonal positions. While some SLEOs
are eventually hired to career FTLEO positions, no priority or preference
points are granted for prior experience.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
50
q  Collateral Duty Officers. CDLEOs are career employees with a job title in
other than the law enforcement series. These individuals, who may be
biologists, heavy equipment operators, recreation specialists, or small boat
operators, are commissioned at the same authority level as the full-time
officer and conduct law enforcement work as one sub-set of daily duties.
CDLEOs attend basic training at FLETC, receive in-service training, but
may receive additional specialized training if they have the interest.
EVALUATION
The current organization of the NWRS law enforcement function features significant
assets. Of greatest value is employment of a decentralized model that accords
substantial empowerment, authority and responsibility to Refuge Project Leaders. Our
arguments in favor of decentralization were introduced in Chapter I. The regional
structure, which apportions over 500 properties and hundreds of employees among
seven manageable clusters makes great sense. Placing law enforcement specialists at
both the national and regional levels for coordination and problem-solving is a third
positive of the current organization scheme.
Despite this positive, law enforcement is not flourishing in the NWRS. This condition is
traceable to many causes, a number of them organizational. Of greatest consequence
are:
q  An insufficiently competitive organizational position in the national structure
q  Passive central direction and control of the law enforcement function
q  Organizational absence or impotence of crucial law enforcement support
functions throughout the System
q  Over-reliance on a refuge-by-refuge organizing and staffing model.
Organizational Voice. In the NWRS scheme, law enforcement is a function, not
an organizational entity. Unlike Fire Management, also a line safety function, or Wildlife
Resources, or even an array of standard support functions including Information
Management and Planning and Policy, law enforcement has not been accorded Branch
status. The consequences of this condition can be measured in status, internal political
power, resources, and acquisition potential. The law enforcement function appears to be
limited in each area. We believe this condition to be firmly rooted in the historical NWRS
perception of law enforcement as an ancillary function. The changing nature of the
police environment supports reconsideration and reorientation of this historical
perspective, and including organizational upgrading. Law enforcement requires a more
prominent voice in the NWRS "board room."
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
51
Direction and Control. The organizational model employed by the USFWS to
manage its law enforcement function features decentralization to the lowest level, the
refuge. Paralleling benefits, the current model appears to have fostered a hands-off
attitude in Washington. We find little evidence of strong command and control of the
refuges from Washington, a condition, which echoes to a greater or lesser degree in the
regions. One result is a profusion of approaches commented upon earlier, varying in
appreciation for law enforcement. Another is absence of law enforcement altogether at
many sites. This is also attributable, in large measure, to predominant use of collateral
duty personnel, the interest of refuge project leaders in law enforcement, and to varying
demand.
An unexpected finding of our examination is the pervasively laissez-faire supervisory
style and complete inattention to formal evaluation of law enforcement performance.
Refuge project leaders (or delegated supervisors) prepare LEO performance
evaluations, but do not, as a rule, review daily work products or apply oversight to
ongoing law enforcement operations. LEOs state that they provide input to project
leaders or other supervisors, ad hoc or upon request, but generally conduct daily
operations according to self-determined priorities.
There are no supervisory LEOs directly above the officers working at the refuge level.
Regional LE Coordinators do not conduct supervisory review functions commensurate
with those performed, for example, by sergeants through captains in uniformed division
operations in state or local police organizations. One result is little or no comprehensive
monitoring of LEO performance and no measurement of law enforcement goal
attainment.
Integration. The law enforcement function is regarded as secondary compared to
other organizational elements of the FWS. The function is in desperate need of
considerable increase in visibility and respect. There are numerous examples of law
enforcement losing out to the more recognized and/or more vocal sectors of the agency
when in competition for funding and other resources, further generating the priority for
identification.
Law enforcement takes a back-seat role to other functions of the refuges. The NWRS
does not segregate or earmark funding for law enforcement. Project Leaders are
empowered to allocate resources for law enforcement or not to do so. Regardless of
initial programming for specific law enforcement expenditures, once funding is allocated,
there are no controls to ensure that funds are actually spent for that law enforcement
priority. Some funds are allocated and administered at the regional level (for drug
prevention or eradication, training, applicant processing), small percentages. Due to the
lack of procedure and control from Washington, these funds are managed inconsistently
from region-to-region.
Support Activities. The effectiveness of law enforcement executive and field
operations depend heavily upon a broad range of quality support services. Absence of
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
52
several of these services in the NWRS organization is glaring. Several that exist are
under-resourced or lack sufficient organizational foundation.
Internal affairs and inspections are critical law enforcement control components. Best
practice advises that these functions be located to report directly to the chief law
enforcement official in an agency. While some internal affairs issues are directed to the
Office of the Inspector General, these are the most serious allegations only. Middle and
lower grade cases are handled by refuges or regions in which they occur – with differing
procedures and results. To be consistent, objective and accepted as fair by the
members of the organization, this professional standards activity must have more formal
organizational status, at the highest level of the System.
An organized and effective inspections program does not exist. We found little evidence
of informal inspection practices, including periodic visitation by higher-level personnel of
the organization. Many LEOs and managers recall such visits occurring with some
frequency in the 1980’s, but not since. To ensure that the controls, directives and policy
are in place and are working efficiently and effectively, a strong inspectional services
program is needed. Like internal affairs, and for the same reasons, this function must be
sited, organizationally, at the executive level, and coordinated with internal affairs in a
Professional Standards unit.
The potential of the NWRS law enforcement function is measurably impaired by an
under-resourced and immature planning function. Absence of headquarters-driven long-range
planning is an NWRS organizational flaw. Crime and service analysis is episodic.
Data systems, specific to the law enforcement function, work largely in the hands of
some regions and individuals spotted throughout the System.
Refuge Law Enforcement Organization. The refuge is the dominant organizing
concept at the field level. Law enforcement is approached refuge-by-refuge. This
organizing concept, traditional and comfortable to the NWRS, bridles innovation and
experimentation. New forms of multi-refuge organization, programming, and resource
sharing and leveraging hold promise for the law enforcement function. New forms of
organization will open the way to allocate new, and perhaps reallocate current needs
driven allocation of law enforcement officers, a concept developed further in a later
section.
PROPOSED ORGANIZATION
To reposition law enforcement for greater contribution to the NWRS core mission,
organizational restructuring is advisable. The organization we recommend is premised
upon the need to remedy the shortfalls and exploit the opportunities referenced above,
specifically to:
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
53
q  Enhance the visibility and competitive position of the law enforcement
function at the headquarters level, through the regions, down to the refuge
level
q  Intensify central command and control to maximize the effectiveness of
ground operations
q  Strengthen support system capabilities to facilitate orderly growth and
change and to secure the ongoing effectiveness of law enforcement
management and operations
q  Fully integrate law enforcement as a partner in USFWS mission
accomplishment
q  Create a management environment that seeks and introduces
organizational experimentation
q  Establish a professional standards capability to the integrity of
management and operations.
In any set of circumstances, several organizations schemes can work equally well.
Indeed, organizational structure is often less important then how it is managed. Further,
structure must be dynamic, continually adapting to changing conditions. Qualified by
each of these considerations, we believe the organization portrayed in Figure 3 will go
far to enhance the law enforcement function of the NWRS.
Overview. The proposed organization raises law enforcement to the branch
level. The Refuge Law Enforcement Branch would consist of three offices:
q  Operations
q  Administration and Support
q  Professional Responsibility.
A Chief, who would report directly to the Chief, Division of Refuges, would head the
proposed branch.
Office of the Branch Chief. Within the framework of guidance, direction, and
limitations from the Chief of the NWRS, the Branch Chief would have full authority to and
be accountable for setting broad law enforcement goals and objectives, designing
strategies to achieve objectives, establishing and maintaining policy, and all other
essential CEO functions. It is presumed that all duties will be conducted with maximum
collaboration of all other Branch Chiefs in the Refuge Division. The role will be
conducted with full understanding that refuge leaders remain the principal source of
refuge law enforcement authority and accountability, as is presently the case.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
54
Office of Support Services. This office would house a number of the support
services that are currently not provided or are under-resourced. Component units would
include: Personnel and Training; Planning and Budgeting; Technology and Equipment;
and Information Systems. Primary functions of these service units are itemized in Figure
3.
q  Personnel and Training. Recruitment, selection, transfer, promotion and
related personnel activities are fragmented. Coherent career development
management and tracking does not appear to exist for FTLEOs or
CDLEOs. Training is segmented, with an FT officer at FLETC overseeing
entry-level training and, to some extent, specialized and in-service courses.
Personnel who perform other law enforcement duties in Refuges and
regions fill in with design and delivery of in-service training and firearms re-qualification.
The result is less than consistent training for all law
enforcement personnel and no follow-on training other than in-service for
CD personnel. The recommended unit would assume responsibility for
coordinating these functions to achieve national level policies and planning
goals and objectives. There is, also, a lingering and unfulfilled need for a
well-developed field training officer (FTO) program for new recruits. This
office should develop and manage this program, in conjunction with the FT
coordinator at FLETC.
q  Technology and Equipment. This would establish equipment standards;
procure and control equipment; coordinate radio communications system
development; establish protocols for alternative communications system
support options (use of state/local or other federal radio systems or
equipment to ensure adequate 24/7 capability).
No central control of personal or unit law enforcement equipment seems to
exist. Personal equipment is issued at graduation from the basic course at
FLETC. Once a LEO leaves his first assignment location, consistent
tracking of this equipment seems to break down. Unit equipment location
and status is not tracked at the national level, possibly resulting in less than
efficient utilization of equipment and increased costs. Site visits and
interviews reveal an inconsistent allocation of required vehicles and
specialized equipment. This is attributable to procurement at the refuge
level without benefit of structured national standards or funding. Non-existent/
appropriate radio communications for law enforcement operations
is self-evident upon observation at refuges and a source of complaints from
LEOs. This includes FWS supported 24/7 radio capability, forcing refuge
level LEOs to rely upon personal coordination and contact with state/local
law enforcement agencies for support and radio frequency assignments.
The establishment of this unit at the national level, with responsibility for
the procurement, distribution and tracking (inventory) of logistics items, will
greatly enhance the maximizing of available equipment resources.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
55
Figure 3
Proposed Law Enforcement and Command Structure
Revised Dec 19, 2000
Intelligence & Federal LE
Coordinator
US Attorneys
Courts Liasion
National Emergency
Mgt Opns
Deputy Branch Chief
Office of Operations
Personnel/Training
Recruitment,
selection, training,
career mgt
(transfers,
promotions)
Technology & Equipment
Personal equip, unit
equip, vehicles,
communications systems,
equip evaluations &
standards
Planning & Budgeting
Long range plan,
written directiives,
budgeting, research,
special projects
Information Management
Computer Systems,
crime stats, criminal
records, management
information
Deputy Branch Chief
Office of Support Services
Asst Branch Chief
Inspectional Services
Asst Branch Chief
Internal Affairs
Deputy Branch Chief
Office of Professional Responsibility
Branch Chief
Refuge LE
Chief
Division of Refuges
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
56
q  Planning and Budgeting. This unit would be responsible for long-range/
strategic planning; written directives consolidation and maintenance;
operations technology research; and special projects.
A strategic/long-range law enforcement operations plan does not seem to
exist. Despite NWRS requirements for annual updates to the refuge plans,
few were found. Those that were discovered are outdated or can better be
classified as an emergency response plans to critical incidents. They
contain no goals, objectives, strategies, or evaluation components.
There is no long-range plan to monitor attainment of goals and objectives.
Directives are not all consolidated and in some cases outdate and/or
inconsistent with law enforcement needs. The budgeting system and
subsequent distribution of funds is a matter of local control, by the refuge
project leader. Law enforcement receives support when project leaders are
so inclined. There is, however, a pattern of more adequate funding of law
enforcement operations on refuges where FTLEOs are present. Little is
done to associate law enforcement expenditures with established goals and
objectives. Establishing an office to manage these functions at the national
level will enhance and improve these critical systems, as well as provide a
central point for establishing service wide specifications for a coherent and
easily accessed written directive system geared to field use by LEOs, and
most importantly, a long-range plan for delivery of law enforcement services
over an extended period in the future.
q  Information Management. This unit would create and manage a
comprehensive law enforcement management information system to include
crime and service analysis.
References to data gaps and data reliability in the preceding chapter
demonstrate the poverty of current information capacity and practices. Law
enforcement analysis, management, and evaluation are the victims of this
condition. This more fundamental management flaw must be remedied
quickly.
Crime analysis is non-existent at any level (strategic or operational). The
reporting system is localized, not conducive to effective or frequent
sourcing, or user-friendly. In fact, the current computerized reporting
system is managed and designed on an ad-hoc basis by a FTLEO in a
refuge in Mississippi. The system has been implemented in local mode
only, on some refuges, despite being available to all refuges. It is used by
LEOs on a local option basis.
Office of Professional Standards. To establish a professional law enforcement
control capacity, two functions should be established, internal affairs and inspections.
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
57
q  Internal Affairs. IA would investigate all Class I complaints against refuge
law enforcement personnel; review all other investigations handled at the
regional and refuge levels; develop investigative guidelines, consistent with
DOI disciplinary policy and procedures; train regional and refuge personnel
designated by policy to conduct IA investigations; provide guidance to the
Branch Chief on disciplinary issues. The unit should coordinate with DOI
OIG on issues of interest to that office and prepare or coordinate
preparation of responses to congressional inquiries on IA issues. It should
participate on service-directed shooting teams to evaluate use of deadly
force.
q  Inspectional Services. This unit would conduct scheduled and special
inspections of refuge law enforcement units and sites; develop inspection
guidelines; develop and deliver training to regional and refuge personnel in
areas of interest and on conformance techniques; assist audit operating
units for policy and directives compliance; assist in developing compliance,
at all levels. It should review all operations for compliance with long and
short-range plans and coordinate refuge law enforcement inspections
program with those of the DOI/OIG and/or conduct them in conjunction with
that office. Regional LE Coordinators will also be utilized to assist with this
important function.
Office of Operations. Numerous instances were found where initiatives failed to
be achieved due to the absence of some level of national coordination or management.
These ranged from conflicts at the line level between federal agencies to lack of judicial
follow-up and adjudication of refuge level problem areas to needed assistance in both
personnel and equipment to handle large scale events at or near refuge areas. A review
of the national structure failed to identify key organizational components that should be
assigned these tasks.
Many of the identified functions/units would normally be found in a well-designed federal,
state or local police agency. They contribute to efficient and effective operations, as well
as command and control as needed. Given the decentralized model of the Service, the
placement of these agencies in a non-command authority position will compliment local
autonomy, where needed.
It is recommended that a Office of Operations, supervised by a Deputy Branch Chief, be
established reporting to the Branch Chief, Refuge Law Enforcement. Within that office
will be an Intelligence & Federal Law Enforcement Agency Coordinator, a US Attorney &
Courts Liaison, and a National Emergency Management Operations Unit. The latter unit
would have minimal full time staffing and be augmented with other personnel as
determined by the crisis at hand.
q  Intelligence & Federal Law Enforcement Agency Coordinator: This
individual would be the link between all other federal law enforcement
Protecting the National Wildlife Refuge System: Law Enforcement Requirements for the 21st Century
58
agencies and would be the central feed point for law enforcement
intelligence data collection. Additionally, he/she would participate at the
federal and state level in cooperative intelligence organizations, coordinate
development of memoranda of understanding between refuges and other
law enforcement agencies (to include being the repository for the same),
and provide information, guidance and intelligence down to the refuge as
necessary. This would enhance the quality and effectiveness of the
response to various