Perspectives
September 05, 2025 | By Richard Moore
Policy Issues
Accountable Government Environment

DNR Audit Confirms What We Already Knew: The DNR Diverts, Disguises, Deceives

The state’s Legislative Audit Bureau released last week its long-awaited audit of the state Department of Natural Resources’s Fish & Wildlife account, and, for those who bothered to read it, it was nothing short of eye-popping.

A wreckage of an agency

The state’s Legislative Audit Bureau released last week its long-awaited audit of the state Department of Natural Resources’s Fish & Wildlife account, and, for those who bothered to read it, it was nothing short of eye-popping.

Granted, progressives didn’t bother to read it—they and most corporate media simply announced that it gave the agency a clean bill of health, while others who should know better argued that it merely called attention to procedural matters.

Neither of those analyses came close to the truth. Indeed, a close reading of the audit bureau’s (LAB) report confirmed three things we have known beyond a shadow of a doubt: the Department of Natural Resources (DNR) diverts funds away from program purposes to fund pet projects and partisan pastimes, it uses smoke and mirrors in the estimates it uses for line-item allocations, and it buries the rest in sloppy, often inaccurate record-keeping.

In other words, the audit report exposes the DNR as a hopeless wreckage of an agency that cannot be redeemed. As state Rep. Chanz Green (R-Grand View) put it on Facebook after the audit report was released: “This is frustrating but not surprising. The DNR does not support our strong sporting heritage in Wisconsin. We need to gut the department and start over!”

Green is exactly right.

For years, sportsmen and women have accused the agency of raiding the account, which is funded by user fees, primarily hunting and fishing licenses and stamps, as well as federal funds. The camouflage has often been quite clever, so the actual amount of theft has been hard to pin down.

Now the numbers are in—and, quite frankly, they are astonishing. The big reveal: Less than half of all Fish and Wildlife expenditures supported by state revenue go to activities that “primarily” benefit Wisconsin’s sportsmen and women.

That’s not exactly what I would call loyalty to our sporting heritage.

According to the audit, in fiscal year 2023-24, Fish and Wildlife Account expenditures totaled $126.2 million. Of that, $92.9 million was supported by state revenue. However, only $46.3 million, or 49.8 percent, went to activities that primarily benefited hunters and anglers; another 39.5 percent benefited both sportsmen and the general public; and 10.3 percent—nearly $10 million—was swallowed up by administrative costs.

Here’s how state Sen. Rob Stafsholt (R-New Richmond), who requested the audit more than a year ago, put it: 

“I am concerned, however, by the fact that only around half of the expenditures by Fish and Wildlife are being put towards activities that ‘primarily’ benefit Wisconsin’s sportsmen. … It is my opinion that we should be closer to 90 percent of the account being devoted to expenditures that primarily benefit the sportsmen who pay these fees.”

State Rep. Calvin Callahan (R-Tomahawk) said sportsmen and women are paying their fair share, but the DNR isn’t holding up its end of the bargain.

“The Fish and Wildlife Account includes license fees, taxes, and revenues that come from Wisconsin’s outdoorsmen,” Callahan said. “It’s not a slush fund for bureaucracy and pet projects. Unfortunately, without a $25 million bailout from the Forestry Account, the DNR would have run the Fish and Wildlife Account into a nearly $10 million deficit. That’s fiscal mismanagement at the expense of the people who fund these programs, and I won’t stand for it.”

The Big Miss … allocation

Actually, Callahan’s is an understatement.

Underlining the importance of the paper trail of dollars is the fact that, as Stafsholt stated, the account has been running in the red. So the audit not only exposes the betrayal of sportsmen and women through the misallocation of their dollars, it also explains why the account has had a structural deficit necessitating transfers from the Forestry Account in the first place.

Astoundingly, the DNR was not only misspending Fish and Wildlife dollars, they were misspending money the account did not even have, all to subsidize projects that had little or nothing to do with hunting or fishing. So while the DNR and the Evers administration have used the deficit to argue for and actually propose higher license fees—they are still doing so—everyone now knows that using the fees for their intended purposes can significantly reduce, if not eliminate, the deficit altogether.

In 2006, for example—the last time before this year that the account was audited—57.3 percent of expenditures from the Fish and Wildlife Account were spent on activities primarily benefiting sportsmen. Today’s numbers represent a 56 percent decline in the amount of dollars directly benefiting those who fund the accounts, even though revenues have grown by 24 percent during the same time.

That is a decline in both priority and principle. Up in the Northwoods, Callahan didn’t mince words:

“The numbers don’t lie. The DNR is spending less and less of hunters’ and anglers’ money on the very activities it was meant to support. … Sportsmen and women are paying their fair share, but the DNR isn’t holding up its end of the bargain.”

This misallocation is not some harmless accounting maneuver. It is outright theft, striking at the heart of the sportsmen’s compact with the state. When sportsmen and women buy a hunting or fishing license, the state assures them that the money will be reinvested in wildlife and habitat management, fish stocking, and game law enforcement.

Instead, the DNR treats the account like a slush fund—dipping into it for customer service centers, property maintenance, debt service, and even programs for species that cannot be harvested. Specifically, the agency spent $303,100 on activities that did not directly benefit hunters and anglers at all, including research, monitoring, and response to wildlife nuisance that were specifically designated for non-game and protected species such as eagles, osprey, wolves, and bats, none of which can be hunted or harvested.

“We also included law enforcement activities unrelated to hunting or fishing, such as enforcement of ginseng and wild rice harvesting regulations,” the audit reported. “The $303,100 for these activities included $209,600 in shared expenditures allocated to the Fish and Wildlife Account.”

Of course, there was the more substantial $36.7 million (including $23.2 million in shared expenditures, or 39.5 percent of total account expenditures) that benefited the public engaging in other recreational activities, as well as anglers and hunters. They include customer service activities such as the staffing of DNR service centers; wildlife damage abatement and claims programs; maintenance of DNR properties and facilities such as state wildlife areas, state natural areas, and state parks; debt service related to the acquisition, improvement, and construction of such facilities; and land acquisition for public access that may be used for hunting or fishing but also for other recreational activities.

Fish and Wildlife dollars were also used for regulatory enforcement, project administration and planning, habitat improvement projects, and DNR education activities, which, according to the DNR, pertained to wildlife but not to a specific game species.

Where there’s smoke, there’s a mirror

The second major reveal in the audit is the DNR’s lack of transparency in how it calculates and allocates shared expenditures and staffing.

For example, $10.1 million in administrative costs were charged to the account based on a calculation that 37.7 percent of DNR staff support fish and wildlife activities in its wildlife management, fisheries management, and law enforcement bureaus. Those costs include legal services, finance, management and budget, human resources, technology services, as well as certain facilities and property management costs, the audit stated.

But there’s no presentation of how that is calculated. There is no precise measurement, just a bureaucratic best guess, and it’s not likely to change anytime soon, given a Democratic governor and the increasing strictures placed on the legislature’s ability to oversee and rein in the state bureaucracy by the courts.

In addition, the audit found that the DNR lacked written policies for changing its shared cost-allocation methodology. Very convenient for covering one’s tracks. It also means the department can change the rules at will, without oversight, and conveniently shift expenditures into the Fish and Wildlife Account to mask deficits elsewhere.

Then, too, the department allocated $2.4 million, or 55 percent, of its customer service costs to the Fish and Wildlife Account based on an estimate that customer service staff spend 55 percent of their time on fish and wildlife activities.

But that number came with a caveat, the auditors observed: “However, DNR indicated that it does not track customer service staff time specifically related to fish and wildlife activities,” the report stated.

So how do they know it’s 55 percent? They don’t. It’s a number picked out of thin air, and more, a funnel to steal money from fish and wildlife to put to other uses. Indeed, the audit report states, the DNR indicated it does not track in the state’s payroll system specific hours worked by staff in a manner that can be restricted only to staff hours supported by Fish and Wildlife Account funds.

“DNR further indicated that it does not typically track hours by account because it budgets and tracks staff time according to its projects and activities, many of which are partially supported by the Fish and Wildlife Account as well as other accounts in the Conservation Fund,” the audit stated. “As a result, we could not independently determine the number of staff hours supported by state Fish and Wildlife Account expenditures in FY 2023-24. Instead, DNR provided us an estimate of these staff hours and the equivalent number of FTE positions.”

In other words, the audit’s conclusions are tethered to what the DNR tells the auditors is the truth, whether it is or not. According to the DNR, as reported by the audit, the equivalent of 548.4 full-time equivalent positions were for Fish and Wildlife Account activities supported by state revenue in 2023-24.

But was it really that much? Given its track record, does anyone trust this agency to tell the truth? For now, we’ll have to take the DNR’s word for it, since they don’t actually supervise tracked time, or make any effort to scrutinize the reliability of reported staff time. The auditors did, though. They reviewed files and found suspicious examples, along the way showing they could track agency staff time better than the agency cares to. Here’s but one example:

“One warden charged 4 hours to deer enforcement on 76 days (compared to a median of 6 days for all wardens), 4 hours to fishing enforcement on 66 days (compared to a median of 7 days), and 4 hours to general wildlife regulations enforcement on 70 days (compared to a median of 4 days),” the report stated.

To be sure, the DNR does require staff to charge their time to federal and state accounts through timesheet reviews, but there does not seem to be any assessment of the accuracy of those claims. And that’s the central flaw, as the audit reported and as the above example demonstrates, the agency has no written policies requiring supervisors to assess whether the activities and the amounts of time charged on their timesheets are appropriate and reasonable. All of which allows the DNR staff to make it up as they go.

Callahan underscored the lack of accountability.

“The LAB made nine recommendations to improve transparency and accountability, but the DNR will likely sit on their hands and ignore them. You deserve better. The DNR needs to stop diverting dollars away from the woods, waters, and wildlife and actually support the hunters and anglers who have built Wisconsin’s outdoor heritage.”

The funky math of bureaucrats

And that’s not even the worst of it. Perhaps the most disturbing part of the audit—though not specifically pointed out—is the DNR’s sloppy and often inaccurate record-keeping. For instance, the audit found that in its 2023-24 financial report, the DNR understated both expenditures and revenues in the Fish and Wildlife Account by $5.1 million.

“For each fiscal year, DNR produces a financial report that it uses to summarize expenditures and revenues for each account within the Conservation Fund,” the audit stated. “This financial report is also used to produce information included in reports provided to the Legislature. In the financial report it provided to us, we found that DNR did not allocate all expenditures and revenues for the Fish and Wildlife Account in FY 2023-24 in accordance with its allocation methodology.”

Instead, the audit reported, the financial report showed expenditures and revenues associated with three appropriations separately from the Fish and Wildlife Account.

“As a result, the financial report understated expenditures allocated to the Fish and Wildlife Account by $5.1 million and also understated Fish and Wildlife Account revenues by $5.1 million for 2023-24,” the report stated. “DNR indicated that the $5.1 million in expenditures and revenues that should have been allocated to the Fish and Wildlife Account were shown separately due to an automated process it began using to produce the financial report beginning with FY 2023-24.”

Ah, an automated process error. The department promised to make a “manual adjustment.”

Does any of this sound familiar? It should. Just this year, the DNR admitted that its reported Stewardship land acquisition numbers were inflated by nearly 120,000 acres over a four-year period. In one stroke, tens of thousands of acres simply vanished from the records.

Specifically, if one compares the LFB Stewardship information paper from January 2021 to the January 2025 version, 117,721 acres of land acquired under the Stewardship program vanished in those four short years. For 2020, the agency listed total Stewardship land acquisitions at 722,237 acres; for 2024 the number had dropped astonishingly to 604,516. Easement acreages under the Stewardship program alone dropped by 12 percent over the four-year period.

In this instance, too, the DNR said it was just a glitch. Not an automated process error, just an accident, just mistakenly putting certain land acquisitions in the wrong category, and then neglecting to point out the error to anyone.

First, the acreage disappeared; now the dollars were misreported. Here’s the thing, both of those reports go to lawmakers to guide them in policymaking. But, as each of the incidents shows, the legislature simply cannot rely on anything the DNR submits to it. Whether it is the Stewardship Fund or the Fish and Wildlife Account, the DNR has shown a pattern: inaccurate numbers, unexplained discrepancies, and belated corrections only when caught with their hand in the cookie jar.

This is mismanagement, or perhaps we should call it dismanagement or malmanagement, but in any event, the DNR won’t be held accountable. Essentially, the audit simply recommends that they improve.

Feed me, feed me higher license fees

Meanwhile, in her response, DNR secretary Karen Hyun painted a rosy picture. She claimed 100 percent of the account’s expenditures comply with state statutes, and she pointed to successful Fish and Wildlife programs, from Lake Sturgeon assessments to a Brook Trout Reserves program to protect Wisconsin’s native brook trout populations.

The DNR also stocked five million fish and certified 22,291 hunter education students, Hyun gushed.

Everything was “picture perfect”—except for that “structural deficit,” which Hyun blamed on nasty Republicans in the legislature for rejecting the governor’s proposal to nearly double some hunting, fishing, and trapping license fees. The Joint Finance Committee scrapped those hikes, but, as Hyun made clear, the bureaucracy hasn’t given up.

“The fee structure that currently supports the Fish and Wildlife Account became inadequate several years ago, prompting the first transfer from the Forestry Account of $25 million,” Hyun wrote. “The subsequent lack of action on increasing license fees led to the necessary transfer of an additional $30 million. It is time to ensure that the conservation of fish, wildlife, and habitat is well funded into the future, and I look forward to the opportunity to continue to discuss solutions to the Fish and Wildlife Account deficit with members of the legislature.”

In other words, more money—never mind the hemorrhaging of funds diverted to non-program purposes.

To stress the point, it isn’t clear that a deficit would exist if expenditures were limited to their intended purposes. And even if there was one, the right fix would be to stop the misallocations first, then determine what, if any, fee increases were actually needed. That’s exactly how Sen. Eric Wimberger (R–Oconto) and Rep. Robert Wittke (R–Caledonia), the co-chairmen of the legislature’s Joint Audit Committee, framed it:

“Wisconsin is a world-renowned destination for hunters and anglers, and getting sportsmen to stay in Wisconsin directly funds the Fish and Wildlife Account. These funds come from license fees & taxes on sporting goods and are supposed to be used on projects that benefit fishing and hunting across the state. There is no reason that the Fish and Wildlife Account should be over $10 million in deficit, while also spending less than fifty percent of its funds on activities that primarily benefitted hunting and fishing. The DNR must provide reassurance that it will be more accountable with its own finances before it comes back to the Legislature asking us to pass its costs onto outdoor enthusiasts.”

Of course, you wouldn’t know any of this from the Milwaukee Journal Sentinel, whose outdoor writer Paul Smith ran with the headline: “Audit gives thumbs up to DNR’s use of Fish and Wildlife Account funds.”

Thumbs up? LOL.

Contrast that with the Dairyland Sentinel’s headline: “Audit exposes shortcomings, problems with Wisconsin DNR Fish and Wildlife account.”

One headline carries water for the bureaucracy; the other reports the audit.

The bottom line is clear: instead of raising fees, the DNR must stop spending on activities that don’t benefit the program’s purpose. That alone would likely erase the deficit. But since the administration has no incentive to demand accountability—because it benefits from the diversions—real change will only come with a new administration.

As Wisconsin heads into 2026, that reality looms large. And with justice Rebecca Bradley stepping aside from the state Supreme Court, the stakes for Wisconsin’s political future just got even higher.

Once a new administration is in place, Rep. Chaz Green’s advice should be the immediate and top priority: Gut it and start all over.

Again, he’s right. The DNR is a wreckage that cannot be reformed, and it has been for years. It needs to be razed and built anew, this time with oversight by the legislature and accountability to the constituencies it serves.

Nothing screams out that need better than the all-important new audit of the Fish and Wildlife Account.

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