ARMY CORPS OF 

ENGINEERS

Additional Steps 

Needed for Review 

and Revision of Water 

Control Manuals

Report to Congressional Committees

July 2016

GAO-16-685

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-685, a report to 

congressional committees

July 2016

ARMY CORPS OF ENGINEERS

Additional Steps Needed for Review and 

Revision of Water Control Manuals

What GAO Found

According to U.S. Army Corps of Engineers (Corps) officials, the agency 

conducts ongoing, informal reviews of selected water control manuals and has 

revised some of them, but the extent of the reviews and revisions is unclear 

because they are not documented or tracked, respectively. The Corps’ engineer 

regulations state that water control manuals should be reviewed no less than 

every 10 years so that they can be revised as necessary. However, officials from 

all 15 districts GAO interviewed said they do not document informal reviews of 

water control manuals because they consider such reviews part of the daily 

routine of operating projects. The Corps does not have guidance, consistent with 

federal standards for internal control, on what activities constitute a review or 

how to document the results of reviews. Without such guidance, the Corps does 

not have reasonable assurance that it will consistently conduct reviews and 

document them to provide a means to retain organizational knowledge. The 

Corps’ engineer regulations also state that water control manuals shall be 

revised as needed, but the extent to which manuals have been revised or need 

revision remains unknown because the Corps’ divisions do not track consistent

information about manuals. For example, based on GAO’s review of the Corps’

documents, one of the eight divisions tracked whether the water control plans in 

its water control manuals reflected actual operations of a project, but the 

remaining seven did not. While the Corps has revised certain water control 

manuals as called for by its regulations, district officials GAO interviewed said 

additional manuals need revision. However, the Corps does not track consistent 

information on manuals needing revision, in accordance with federal internal

control standards. Without tracking which manuals need revision, it is difficult for 

the Corps to know the universe of projects that may not be operating in a way 

that reflects current conditions as called for in the Corps’ engineer regulations.

The Corps has efforts under way to improve its ability to respond to extreme 

weather, including developing a strategy to revise drought contingency plans and

studying the use of forecasting to make decisions on project operations. To 

better respond to drought, the Corps is developing a strategy to analyze drought 

contingency plans in its water control manuals to account for a changing climate. 

As of May 2016, the Corps was conducting, as a pilot, updates of five projects’ 

drought contingency plans to help test methods and tools for future use in other 

plans. The Corps is also studying the use of forecasting tools to improve water 

supply and flood control operations at two projects in California by evaluating if 

they can retain storm water for future supply as long as the retained water can 

safely be released, if necessary, prior to the next storm. Knowledgeable 

stakeholders GAO interviewed said it is important for the Corps to consider 

forecast-based operations at its projects to help ensure efficient operations and 

to be able to respond to changing patterns of precipitation. Corps officials said 

the agency may consider doing so once the two California projects are 

completed in 2017. 

View GAO-16-685. For more information, 

contact Anne-Marie Fennell at (202) 512-3841

or fennella@gao.gov.

Why GAO Did This Study

The Corps owns and operates water 

resource projects, including more than 

700 dams and their associated 

reservoirs across the country, for such 

purposes as flood control, hydropower, 

and water supply. To manage and 

operate each project, the Corps’

districts use water control manuals to 

guide project operations. These 

manuals include water control plans 

that describe the policies and 

procedures for deciding how much 

water to release from reservoirs. 

However, many of the Corps’ projects

were built more than 50 years ago, and 

stakeholders have raised concerns that 

these manuals have not been revised 

to account for changing conditions.

The Water Resources Reform and 

Development Act of 2014 included a 

provision for GAO to study the Corps’ 

reviews of project operations, including 

whether practices could better prepare 

the agency for extreme weather. This 

report (1) examines the extent to which 

the Corps has reviewed or revised

selected water control manuals and (2) 

describes the Corps’ efforts to improve 

its ability to respond to extreme 

weather. GAO reviewed the Corps’

guidance on project operations; 

examined agency practices; and 

interviewed Corps officials from 

headquarters, all 8 divisions, and 15 

districts—selected, in part, on regional 

differences in weather conditions.

What GAO Recommends

GAO recommends that the Corps 

develop guidance on what constitutes

a water control manual’s review and 

how to document it and track which 

manuals need revision. The agency

concurred with the recommendations.
Page i GAO-16-685 Army Corps of Engineers

Letter 1

Background 5

The Extent to Which the Corps Has Reviewed or Revised Water 

Control Manuals Is Unclear Because It Did Not Document 

Reviews or Track Revisions 11

The Corps Has Efforts Under Way to Improve Its Ability to 

Respond to Extreme Weather 18

Conclusions 23

Recommendations for Executive Action 24

Agency Comments 24

Appendix I Comments from the Department of Defense 26

Appendix II GAO Contact and Staff Acknowledgments 28

Figures

Figure 1: Locations of the U.S. Army Corps of Engineers’ Civil 

Works Divisions and Districts 6

Figure 2: Illustration of a U.S. Army Corps of Engineers’ 

Reservoir, with Pools Allocated for Different Uses 9

Abbreviations

Corps U.S. Army Corps of Engineers

NOAA National Oceanic and Atmospheric Administration

O&M operations and maintenance

USGS U.S. Geological Survey

Contents

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Page 1 GAO-16-685 Army Corps of Engineers

441 G St. N.W.

Washington, DC 20548

July 26, 2016

The Honorable James Inhofe

Chairman

The Honorable Barbara Boxer

Ranking Member

Committee on Environment and Public Works

United States Senate

The Honorable Bill Shuster

Chairman

The Honorable Peter DeFazio

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

The U.S. Army Corps of Engineers (Corps) is the world’s largest public 

engineering agency, with water resources projects across the United 

States, including more than 700 dams that it owns and operates for a 

variety of purposes including navigation, flood control, irrigation, 

hydropower, water supply, recreation, and fish and wildlife conservation. 

However, much of the Corps’ infrastructure for these dams and their 

associated reservoirs was built more than 50 years ago. To manage and 

operate each water resources project, the Corps’ 38 district offices 

develop water control manuals to guide project operations. These 

manuals describe the project’s dams, reservoirs, and any affected rivers; 

historic floods and storms in the project area; and data from other 

agencies, such as the Department of Commerce’s National Oceanic and 

Atmospheric Administration (NOAA) and the Department of the Interior’s 

U.S. Geological Survey (USGS), that the Corps uses in operating the 

projects. The manuals also, among other things, describe methods for 

forecasting the amount of runoff flowing to the dams’ reservoirs,1

document policies and procedures for deciding how much water to 

release from the reservoirs, and generally have an associated drought 

contingency plan that provides guidance for district actions in response to 

periods of water shortages. Stakeholders, such as local governments and 

 1

Runoff flows over the land surface, going downhill into rivers and streams.

Letter
Page 2 GAO-16-685 Army Corps of Engineers

advocacy groups, have raised concerns that some water control manuals 

have not been revised since projects were built decades ago and may not 

reflect advances in science, such as in weather forecasting or changes in 

weather patterns.

In addition, the Corps’ projects may be affected by extreme weather 

events, such as flood and drought. According to the U.S. Global Change 

Research Program’s May 2014 National Climate Assessment and a 2010 

National Research Council’s report, precipitation patterns are changing, 

and the frequency and intensity of some extreme weather events are 

increasing.2 In addition, a 2009 USGS report found that changes in the 

climate could affect water resources management and require changed 

operational assumptions about resource supplies, system demands or 

performance requirements, and operational constraints.

3 For example, 

according to the report, a shift in precipitation from snow to rain, 

combined with earlier melting of mountain snowpack, has been 

documented in western states. These two reported actions change the 

timing of runoff, affecting the Corps’ operational decisions about when to 

release water from reservoirs.

Section 1046 of the Water Resources Reform and Development Act of 

2014 includes a provision for us to audit the Corps’ reviews of project 

operations, including an assessment of whether the Corps’ practices 

could result in greater efficiencies to better prepare for extreme weather.

According to a 1992 Corps’ report,4 project operations are defined as 

 2

Jerry M. Melillo, Terese (T.C.) Richmond, and Gary W. Yohe, eds., 2014: Climate 

Change Impacts in the United States: The Third National Climate Assessment,

(Washington, D.C.: U.S. Global Change Research Program, May 2014) and National 

Research Council, Board on Atmospheric Sciences and Climate, Advancing the Science 

of Climate Change (Washington, D.C.: National Academies Press, 2010). The U.S. Global 

Change Research Program coordinates and integrates the activities of 13 federal 

agencies that conduct research on changes in the global environment and their 

implications for society. The National Research Council is now known as the National 

Academies of Sciences, Engineering, and Medicine.

3

L.D. Brekke, J.E. Kiang, J.R. Olsen, R.S. Pulwarty, D.A. Raff, D.P. Turnipseed, R.S. 

Webb, and K.D. White, Climate Change and Water Resources Management—A Federal 

Perspective: USGS Circular 1331 (2009).

4

Army Corps of Engineers, Authorized and Operating Purposes of Corps of Engineers 

Reservoirs (Washington, D.C.: July 1992). This report excludes water control structures

that do not routinely impound water, such as river diversion structures and pumping 

stations.
Page 3 GAO-16-685 Army Corps of Engineers

water control management that is routinely required to control either water 

level or flow, or both. Our report (1) examines the extent to which the 

Corps has reviewed or revised selected water control manuals and (2) 

describes the Corps’ efforts, if any, to improve its ability to respond to 

extreme weather. Section 1046 of the Water Resources Reform and 

Development Act of 2014 also required the Corps to update its 1992 

report about authorized and operating purposes of its reservoirs by June 

10, 2016. The updated report is, among other things, to include a plan for 

reviewing the operations of individual projects that meet specified 

requirements.5 The act also includes a provision for us to review the plan 

in the updated report. However, according to officials from the Corps and 

from the office of the Assistant Secretary of the Army for Civil Works, the 

Corps did not update the report as required by the statutory deadline 

because of funding constraints; therefore, we were unable to review the 

updated report.

To address both objectives, we reviewed relevant laws and executive 

orders, as well as our past reports on Corps operations and preparation 

for extreme weather. We interviewed officials who are responsible for 

project operations at headquarters and all eight Corps divisions. In 

addition, we interviewed officials from a nonprobability sample of 15 of the 

38 Corps districts responsible for water control management.6 We 

selected these districts based on criteria such as the Corps division 

where the district resides, regional differences in weather conditions, and 

a range in the number of projects operating within the district. Because 

this was a nonprobability sample, our findings cannot be generalized to all 

Corps districts but provide illustrative examples of the Corps’ actions and 

strategies. We also visited two district offices (Los Angeles and 

Sacramento Districts) from our sample, where we reviewed documents, 

interviewed agency officials, and observed some of the Corps’ efforts to 

help prepare its operations for extreme weather. We selected these 

offices based on available resources and proximity to a GAO field office, 

 5

Pub. L. No. 113-121, § 1046(a)(2)(B)(ii)(I)(dd) (2014). 

6

We interviewed Corps officials from the following districts: Anchorage, Alaska; 

Philadelphia, Pennsylvania; Jacksonville, Florida; Walla Walla, Washington; St. Louis, 

Missouri; Los Angeles, California; Sacramento, California; Kansas City, Missouri; Fort 

Worth, Texas; Concord, Massachusetts; St. Paul, Minnesota; Louisville, Kentucky; Tulsa, 

Oklahoma; Pittsburgh, Pennsylvania; and Mobile, Alabama. 
Page 4 GAO-16-685 Army Corps of Engineers

in addition to the criteria used to select the nonprobability sample of 

districts. The results from these visits are also not generalizable.

To examine the extent to which the Corps has reviewed and revised 

selected water control manuals, we reviewed relevant Corps guidance 

and other documents, and information on water control manual reviews or 

revisions, such as engineer regulations, circulars, and manuals. We 

compared agency practices with federal standards for internal control.7

We focused on steps taken since 1990 because of enacted legislation 

that changed the Corps’ process to revise water control manuals and 

because 1990 was the last time the Corps systematically prepared 

drought contingency plans for water control manuals.8 In addition, we 

examined the Corps’ relevant documents and information on water 

control manual reviews and revisions from each of the eight divisions and 

our nongeneralizable sample of districts.

To examine the Corps’ efforts, if any, for improving its ability to respond to 

extreme weather, we examined the Corps’ relevant guidance, documents, 

and information on project operations and efforts to prepare for or 

respond to extreme weather. We interviewed cognizant Corps officials to 

discuss what, if any, guidance is being drafted or implemented 

responding to extreme weather events at the Corps’ projects. We also 

interviewed five knowledgeable stakeholders from academia, a consulting 

firm, and a federal science agency to obtain their views on leading 

practices in preparing operations for extreme weather. Knowledgeable 

stakeholders were selected based on their knowledge of reservoir 

operations, modeling precipitation patterns, and Corps operational 

decisions. Views from these knowledgeable stakeholders are not 

generalizable to those with whom we did not speak.

We conducted this performance audit from August 2015 to July 2016 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

 7

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999). GAO has revised and reissued Standards for Internal 

Control in the Federal Government, with the new revision effective as of October 1, 2015. 

GAO-14-704G (Washington, D.C.: September 2014).

8

Pub. L. No. 101-640, tit. III, § 310 (1990) (codified as amended at 33 U.S.C. § 2319).
Page 5 GAO-16-685 Army Corps of Engineers

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

This section provides information on the Corps’ organizational structure, 

its project operations and water control manuals, and the process for 

formulating its operations and maintenance budget.

Located within the Department of Defense, the Corps has both military 

and civilian responsibilities.9 The Corps’ civil works program is organized 

into three tiers: a national headquarters in Washington, D.C.; eight 

regional divisions that were established generally according to watershed 

boundaries; and 38 districts nationwide (see fig. 1).

 9

The Corps’ military program provides, among other things, engineering and construction 

services to other U.S. government agencies and to foreign governments. This report 

focuses only on the Corps’ civil works program.

Background

Corps’ Organizational 

Structure
Page 6 GAO-16-685 Army Corps of Engineers

Figure 1: Locations of the U.S. Army Corps of Engineers’ Civil Works Divisions and Districts

Corps headquarters primarily develops policies and provides oversight. 

The Assistant Secretary of the Army for Civil Works, appointed by the 

President, establishes the policy direction for the civil works program. The 

Chief of Engineers, a military officer, oversees the Corps’ civil works 
Page 7 GAO-16-685 Army Corps of Engineers

operations and reports on civil works matters to the Assistant Secretary of 

the Army for Civil Works. The eight divisions, commanded by military 

officers, coordinate civil works projects in the districts within their 

respective divisions. Corps districts, also commanded by military officers, 

are responsible for planning, engineering, constructing, and managing 

water-resources infrastructure projects in their districts. Districts are also 

responsible for coordinating with projects’ nonfederal sponsors, which 

may be state, tribal, county, or local governments or agencies.10

In 1969, the Corps formed the Institute for Water Resources—which is a 

field-operating activity outside of the headquarters, division, and district 

structure—to provide forward-looking analysis and research in developing 

planning methodologies to aid the civil works program. Specifically, the 

institute fulfills its mission, in part, by providing an analysis of emerging 

water resources trends and issues and state-of-the-art planning and 

hydrologic-engineering methods, models, and training. In 2009, the Corps 

established the Responses to Climate Change program under the lead of 

Institute for Water Resources to develop and implement practical, 

nationally consistent, and cost-effective approaches and policies to 

reduce potential vulnerabilities to the nation’s water infrastructure 

resulting from climate change and variability.

The Corps is responsible for operations at 707 dams that it owns at 557 

projects across the country, as well as flood control operations at 134 

dams constructed or operated by other federal, nonfederal, or private 

agencies. Each of these projects may have a single authorized purpose 

or serve multiple purposes such as those identified in the original project 

authorization, revisions within the discretionary authority of the Chief of 

Engineers, or project modifications permitted under laws enacted 

subsequent to the original authorization. For example, the Blackwater 

Dam in New Hampshire has the single purpose of flood control, whereas 

the Libby Dam in Montana has multiple purposes, including hydropower, 

flood control, and recreation.

 10Nonfederal sponsors are those entities that share the cost of planning and implementing 

Corps projects. The division of federal and nonfederal cost-sharing required varies by 

project purpose.

Project Operations and 

Water Control Manuals
Page 8 GAO-16-685 Army Corps of Engineers

These 841 dams and their reservoirs are operated according to water 

control manuals and their associated water control plans, which Corps 

regulations require to be developed.11 A water control manual may outline 

operations for a single project or a system of projects. For example, the 

Missouri River Mainstem Reservoir System Master Water Control Manual 

outlines the operations at six dams and their associated reservoirs, and 

the Folsom Dam Water Control Manual applies to one dam and its 

reservoir. Water control manuals include a variety of information the 

Corps uses in operating the dams, including protocols for coordinating 

with and collecting data from federal agencies, such as NOAA’s National 

Weather Service and USGS, as well as water control plans. The water 

control plans, sometimes referred to as chapter 7 of the water control 

manuals, outline how each reservoir is to be operated and include 

relevant criteria, guidelines, and rule curves defining the seasonal and 

monthly limits of storage and guide water storage and releases at a 

project. According to the Corps’ engineer regulations, the Corps develops 

water control plans to ensure that project operations conform to 

objectives and specific provisions of authorizing legislation. Water control 

plans also generally describe how a reservoir will be managed, including 

how water is to be allocated between a flood control storage pool and a 

conservation storage pool, which is used to meet project purposes during 

normal and drought conditions.12 The bottom of a conservation storage 

pool is considered inactive and is designed for collecting sediment (see 

fig.2). Water levels in the pools are defined based on a statistical analysis 

of historical rain events. For those projects that have multiple authorized 

purposes, water control plans attempt to balance water storage for all 

purposes.

 1133 C.F.R. § 222.5(f)(1).

12The flood storage pool captures intense rainfall and provides flood risk reduction for 

downstream areas. The conservation storage pool may be used for hydropower 

generation, water supply, recreation, fish and wildlife habitat enhancement, and 

navigation, among other uses.
Page 9 GAO-16-685 Army Corps of Engineers

Figure 2: Illustration of a U.S. Army Corps of Engineers’ Reservoir, with Pools 

Allocated for Different Uses

The conservation storage pool may be used for hydropower generation, water supply, recreation, and 

navigation, among other uses, and the inactive storage pool collects sediment.

Corps engineer regulations require that all water control manuals—except 

manuals for dry reservoirs that do not fill with water unless floodwaters 

must be contained—have an associated drought contingency plan to 

provide guidance for water management decisions and responses to a 

water shortage due to climatological drought.13 These plans, which can 

cover more than one project: (1) outline the process for identifying and 

monitoring drought at a project, (2) inform decisions taken to mitigate 

drought effects, and (3) define the coordination needed with stakeholders 

 13U.S. Army Corps of Engineers, Engineering and Design: Water Control Management, 

Engineer Regulation 1110-2-240 (Washington, D.C.: June 30, 2014) and Engineering and 

Design: Drought Contingency Plans, Engineer Regulation 1110-2-1941 (Washington, 

D.C.: Sept. 15, 1981). The Corps updated Engineer Regulation 1110-2-240 on May 30, 

2016.
Page 10 GAO-16-685 Army Corps of Engineers

and local interests to help manage water resources so they are used in a 

manner consistent with the needs that develop, among other things.

According to a 2014 Corps engineer regulation,14 water control manuals 

may be revised for reasons such as land use development in the project 

area and downstream from it, improvements in technology used to 

operate projects, reallocation of the water supply,15 new regional 

priorities, or changes in environmental conditions. The Corps’ engineer 

regulation also directs districts to include in water control manuals a 

provision allowing temporary deviations from a project’s approved water 

control plan to alleviate critical situations, such as a flood or drought, or to 

realize additional efficiencies without significantly affecting the project’s 

authorized purposes. Districts are to perform a risk and uncertainty 

analysis to determine the potential consequences of such a deviation. 

Division commanders are responsible for reviewing and approving any 

proposed deviations. According to the engineer regulation, deviations are 

meant to be temporary and, if a deviation lasts longer than 3 years, the 

water control manual must be revised.

Our prior work has found that the Corps’ headquarters, divisions, and 

districts are all involved in developing the President’s budget request for 

the Corps.16 The development process spans 2 years; for example, 

development of the fiscal year 2018 budget began in fiscal year 2016. 

After receiving budget guidance from the Office of Management and 

Budget as well as the Assistant Secretary of the Army for Civil Works, 

district staff compile a list of operations and maintenance (O&M) projects 

necessary in their districts and submit their needs to the relevant division. 

O&M projects may include, among other things, water control manual 

revisions, dredging, replacement of dam parts, dam safety measures, or 

 14Engineer Regulation 1110-2-240.

15Reallocation of water supply storage occurs when the storage is changed from one

authorized purpose to a different authorized use. For example, to meet increased demand 

for water by cities, water storage within a reservoir may be reallocated from hydropower to 

municipal and industrial use.

16GAO, Army Corps of Engineers: Budget Formulation Process Emphasizes Agencywide 

Priorities, but Transparency of Budget Presentation Could Be Improved, GAO-10-453 

(Washington, D.C.: Apr. 2, 2010). 

Corps’ Operations and 

Maintenance Budget 

Formulation Process
Page 11 GAO-16-685 Army Corps of Engineers

adding capacity at hydropower projects. Division staff then rank the O&M 

projects from all districts in the division and submit those rankings to 

Corps headquarters staff for review. Headquarters staff review the 

rankings to help ensure they are consistent with Corps-wide guidance 

and result in decisions that emphasize agency-wide priorities. 

Headquarters staff consolidate the O&M requests across business lines 

and divisions into a highest-priority grouping. Once the Corps completes 

its internal review of the budget request, the Assistant Secretary of the 

Army for Civil Works approves and submits its budget to the Office of 

Management and Budget for review. The Office of Management and 

Budget recommends to the President whether to support or change the 

Corps’ budget request, and the President’s budget request is transmitted 

to Congress.

According to agency officials, the Corps conducts ongoing, informal 

reviews of selected water control manuals and has revised some of them, 

but the extent of the reviews and revisions is unclear because they were 

not documented or tracked. More specifically, district officials said that the 

Corps reviews the manuals as part of daily operations but does not 

document the reviews, and there is no guidance on what constitutes a 

review or how to document it. Further, the Corps does not track 

consistent information across divisions on the status of manuals to 

indicate revisions that were made or are needed.

The Extent to Which 

the Corps Has 

Reviewed or Revised 

Water Control 

Manuals Is Unclear 

Because It Did Not 

Document Reviews or 

Track Revisions
Page 12 GAO-16-685 Army Corps of Engineers

It is unclear to what extent the Corps has reviewed its water control 

manuals because district officials did not document these reviews, which,

according to district officials, are informal and conducted on an ongoing 

basis through daily operations. A 2014 Corps engineer regulation states 

that water control manuals should be reviewed no less than every 10 

years, so that they can be revised as necessary.17 Most district officials 

we interviewed said that they informally review the water control plan 

because this portion of the manual describes how projects are to be 

operated under different conditions to meet their authorized purposes. 

However, officials we interviewed from all 15 districts said they do not 

document these informal reviews because they consider such reviews to 

be part of the daily routine of operating projects. Because these informal 

reviews are not documented, knowledge of these reviews and their 

results may be limited to personnel directly involved with them. Officials 

we interviewed from four districts said that the loss of institutional 

knowledge posed a challenge to conducting efficient reviews of manuals. 

For example, officials from one district said that no Corps officials 

currently employed at the district had worked on developing the manual 

for a project and had no supporting documentation of the process, so the 

officials did not know why prior Corps officials wrote the manual in a 

particular way. As a result, the officials said it took them longer to review 

the manual.

One Corps district we reviewed had previously documented informal 

reviews of water control manuals. Specifically, officials we interviewed in 

this district said that they documented reviews of some water control 

manuals in 2005 as part of a district-wide effort to ensure these manuals 

were adequate to meet the projects’ authorized purposes since they had 

not been revised in a long time. According to these officials, as part of this 

effort, if they determined that all of the operating conditions in a manual 

were still current, they submitted a memorandum to their division that 

revalidated the manual’s water control plan. Officials from that district said 

they have not documented reviews of water control manuals since 2005 

because they chose to focus only on those manuals they knew needed 

revision. However, the Corps does not have guidance on what activities 

constitute a review or how officials should document the results of their 

reviews. Under federal standards for internal control, internal control and 

 17Engineer Regulation 1110-2-240.

The Extent to Which the 

Corps Has Reviewed Its 

Water Control Manuals Is 

Unclear Because the 

Reviews Were Informal, 

According to Agency 

Officials, and Not 

Documented
Page 13 GAO-16-685 Army Corps of Engineers

other significant events are to be clearly documented in a manner that 

allows the documentation to be readily available for examination, such as 

in management directives, administrative policies, or operating manuals.18

Without developing guidance on what activities constitute a review of a 

water control manual and how to document that review, the Corps does 

not have reasonable assurance that its districts will consistently conduct 

reviews and document them to provide a means to retain organizational 

knowledge and mitigate the risk of having that knowledge limited to 

personnel directly involved with these reviews.

The Corps has revised some water control manuals; however, divisions 

and districts do not track consistent information about revisions to 

manuals, and the extent to which they have been revised—or need 

revision—is unclear. Corps engineer regulations state that manuals are to 

be revised as needed, in accordance with the regulations.19 Districts have 

revised some water control manuals for a variety of reasons, such as in 

response to infrastructure modifications and weather events, according to 

the Corps’ documents and its headquarters, division, and district officials 

we interviewed. For example, officials we interviewed in one district said 

they revised a water control manual after a flood highlighted a need to 

change the seasonal and monthly limits of reservoir storage when water 

recedes. Officials we interviewed from other districts said they revised a 

manual based on vulnerabilities identified through the periodic inspections 

they conduct of projects through the Corps’ dam safety program.20

District officials we interviewed said that the time and resources needed 

to revise manuals vary greatly, depending on the nature of the revisions 

 18GAO/AIMD-00-21.3.1. 

19Engineer Regulation 1110-2-240; U.S. Army Corps of Engineers, Engineering and 

Design: Management of Water Control Systems, Engineer Manual 1110-2-3600

(Washington, D.C.: Nov. 30, 1987). 

20The Corps is required by law to carry out a national program of inspection of dams for 

the purpose of protecting human life and property. 33 U.S.C. § 467a. Through this 

program, the Corps conducts: (1) annual inspections to ensure that a dam is being 

properly operated and maintained; (2) periodic inspections every 5 years, including a more 

detailed, comprehensive evaluation of the condition of the dam; and (3) risk assessments 

every 10 years, including the probability of failure and resulting potential consequences 

due to failure.

The Corps Has Revised 

Some Water Control 

Manuals but Does Not 

Track Consistent 

Information on Which 

Have Been Revised or 

Need Revision
Page 14 GAO-16-685 Army Corps of Engineers

and the complexity of the project, among other things. For instance, 

according to a Corps 2012 engineer regulation,21 all revisions to a water 

control manual are to undergo a quality control review of the science and 

engineering work by district leadership. Depending on the revisions 

made, manuals may also undergo a technical review by division 

leadership and an independent external peer review by a panel of 

experts. For example, according to a Corps engineer regulation and 

division and district officials we interviewed,

22 if the districts make 

substantial revisions to a manual’s water control plan, they are to 

complete environmental analyses required by the National Environmental 

Policy Act of 1969,23 which they said involves considerable time and 

coordination with other federal agencies and opportunity for public 

comment. District officials told us that making such substantive revisions 

to a manual takes more time and resources than making an 

administrative revision because of the additional requirements for 

review.24

Moreover, some district officials noted that the longer they defer making 

revisions to a manual, the more extensive and complex the changes may 

become, changes that may add time and increase costs to revise the 

manual. Officials in one district said that it cost about $100,000 to revise 

one section of a manual’s water control plan, which did not significantly 

affect other aspects of the plan. In contrast, officials in another district 

said that it cost over $10 million and took over 25 years to revise a 

manual that included a water control plan for several projects, primarily 

because of litigation over the revisions.

Our review of division documents indicates that all eight divisions we 

reviewed tracked the date a manual was last revised, but officials told us 

that the length of time since the last revision is not necessarily indicative 

 21U.S. Army Corps of Engineers, Water Resources Policies and Authorities: Civil Works 

Review, Engineer Circular 1165-2-214 (Washington, D.C.: Dec. 15, 2012).

22Engineer Regulation 1110-2-240.

23Pub. L. No. 91-190, 83 Stat. 852 (1970) (codified as amended at 42 U.S.C. §§ 4321-

4347).

24Revisions to water control manuals can be administrative, such as updating contact 

information, or substantive, which would change the water control plan of the project, 

according to Corps documents.
Page 15 GAO-16-685 Army Corps of Engineers

of whether manuals need to be revised. According to headquarters and 

district officials we interviewed, water control manuals are designed to 

provide flexibility for a broad variety of runoff and climatic conditions. For 

example, headquarters officials said the rule curve25 in one water control 

manual provided guidelines for how much water operators should take 

out of the reservoir during October and November to meet its flood risk 

management target, while at the same time holding enough water to, 

among other things, meet its authorized purposes of hydropower and 

providing water flow for an endangered fish species. However, two 

knowledgeable stakeholders we interviewed said that many of the Corps’

rule curves assume that the chances of an extreme event are equally 

likely for any given year, which may not reflect actual conditions. These 

stakeholders said that the Corps should consider revising water control 

manuals with dynamic rule curves to account for potential changes to 

climate conditions,26 but a Corps official said that the science behind 

dynamic rule curves is still being developed.

In addition, Corps officials said that the provisions in water control 

manuals that allow temporary deviations from water control plans, if 

necessary, provide districts with flexibility in operating projects. For 

example, in response to drought conditions, the Corps approved a 

deviation from the water control plan in December 2014 at a project in 

California, a deviation that allowed the Corps to temporarily retain water 

captured behind the dam following a rainstorm. According to officials in 

that district, this temporary deviation allowed them to respond to the 

immediate stakeholder interests in conserving water during the drought, 

so they did not need to revise the water control manual. Given the 

flexibilities provided by rule curves and temporary deviations, not all 

manuals need to be revised, according to Corps officials we interviewed 

at headquarters, divisions, and districts.

However, the extent to which water control manuals have been 

substantively revised, if at all, remains unknown because the divisions 

and districts we reviewed did not track consistent information about 

 25Rule curves define the seasonal and monthly limits of water storage and guide water 

storage and releases at a project.

26Dynamic rule curves change based on the present state of a system, such as storage

levels, current inflow, or forecasted conditions. 
Page 16 GAO-16-685 Army Corps of Engineers

revisions to water control manuals to help ensure that manuals are 

revised in accordance with engineer regulations. For example, based on 

our review of Corps documents, one of eight divisions tracked whether 

the water control plans in its water control manuals reflected actual 

operations of the project, but the remaining seven divisions did not. In 

addition, another division tracked information about when the water 

control manuals in five out of six of its districts had been revised. Officials 

whom we interviewed from this division said they were not sure if any of 

the manuals in the sixth district had been reviewed because information 

had not been submitted by the district. Corps headquarters officials said 

that the Corps does not track the status of water control manual revisions 

agency-wide because two people in headquarters oversee all of the 

Corps’ water resources operational issues, among other duties, and, 

therefore, divisions and districts were given responsibility for tracking 

revisions. However, these officials said the agency is compiling 

information to create a central repository of water control manuals, among 

other things, to respond to activities set forth in an action plan for the 

President’s Memorandum on drought resilience.27 They said the 

repository could be used to track the status of revisions or needed 

revisions of manuals, but they do not currently plan to do so.

Furthermore, district officials we interviewed told us they have identified 

certain manuals needing revision, but they have not received the O&M 

funds they requested to revise these manuals and documentation shows 

that they do not track consistent information on these manuals. A Corps 

engineer manual states that there may be reasons—such as new 

hydrologic data or a reevaluation of water control requirements—to revise 

water control manuals to reflect current operating conditions.28 Divisions 

are responsible for prioritizing the O&M funding requests they receive 

from all of their districts. Corps budget documents describe factors to 

consider for agency-wide prioritization—such as whether an item is 

required to meet legal mandates or would help ensure project safety (e.g., 

by paving a project access road)—but headquarters officials said each

 27The White House, Long-Term Drought Resilience: Federal Action Plan of the National 

Drought Resilience Partnership (Washington, D.C.: March 2016). The President’s 

Memorandum on Building National Capabilities for Long-Term Drought Resilience 

establishes federal drought resilience goals, among other things.

28Engineer Manual 1110-2-3600.
Page 17 GAO-16-685 Army Corps of Engineers

division may add other factors for consideration. According to our 

document review, one of the eight divisions tracked the priority that 

districts assigned to revising water control manuals when requesting 

O&M funds during the budgeting process, and four divisions tracked the 

fiscal year they proposed revising certain manuals, pending available 

funding. However, most district officials we interviewed said revisions to 

water control manuals are often a lower priority than other O&M activities, 

such as equipment repairs, sediment removal, or levee repairs. As a 

result, districts may not get funding to revise water control manuals.

Moreover, Corps headquarters officials said that each division and district 

varies in the resources and staff it has available to conduct water control 

manual reviews and make revisions. For example, officials we 

interviewed from two districts in the same division said they do not have 

staff available to review water control manuals, and they have not 

received the funding they requested to revise their water control manuals. 

Corps headquarters officials said they do not track which manuals the 

districts have requested funds to revise—and therefore cannot prioritize 

these requests—because they have limited staff to accomplish water 

resources management activities. However, internal control standards in 

the federal government call for agencies to clearly and promptly 

document transactions and other significant events from authorization to 

completion.29 Without tracking which manuals need revision, it is difficult 

for the Corps to know the universe of projects that may not be operating 

in a way that reflects current conditions as called for in the Corps’

engineer manual and prioritize revisions as needed.

District officials whom we interviewed said that not revising water control 

manuals regularly could lead projects to operate inefficiently under 

changing conditions. For example, farmers downstream from one project 

wanted the Corps to consider changing operations so that their fields 

would not flood when it rained. However, officials in that district said they 

requested but did not receive the funds to revise the manual and could 

not fully address the farmers’ concerns. Officials in another district said 

they have requested funds to revise several manuals that they described 

as outdated, but because they have not received funds, they noted they 

were operating those projects in a way that differed from some aspects of 

 29GAO/AIMD-00-21.3.1.
Page 18 GAO-16-685 Army Corps of Engineers

the approved water control plans and they did not request deviations. 

Instead, they said they referred to handwritten notes and institutional 

knowledge to operate those projects. For example, officials said that due 

to sedimentation build up in the reservoir of one project, they are 

operating that project 22 feet higher than the approved plan. According to 

a Corps engineer regulation, the Corps develops water control plans to 

ensure that project operations conform to objectives and specific 

provisions of authorizing legislation.30 However, because some manuals 

that need revision have not been revised and, as some district officials 

noted, operations for certain projects differ from aspects of the approved 

water control plans in those manuals, the Corps lacks assurance that 

project operations are conforming to the objectives and specific 

provisions of authorizing legislation.

The Corps has efforts under way to improve its ability to help respond to 

extreme weather events. These efforts include developing a strategy to 

revise its drought contingency plans and studying the use of forecasts to 

make decisions on project operations. The Corps is also conducting 

research on how to better prepare operations for extreme weather.

To better respond to drought, the Corps is developing a strategy to 

analyze drought contingency plans in its manuals and devise methods for 

those plans to account for a changing climate. According to a 2015 Corps 

report on drought contingency planning, the Corps is developing the 

strategy because climate change has been and is anticipated to continue 

to affect the frequency and duration of drought in the United States.31 The 

Corps last systematically prepared drought contingency plans in the 

1980s through the early 1990s, before climate change information was 

widely available. These plans assumed that historic patterns of 

temperature, precipitation, and drought provided a reasonably accurate 

 30Engineer Regulation 1110-2-240.

31U.S. Army Corps of Engineers, USACE Drought Contingency Planning in the Context of 

Climate Change, Civil Works Technical Report, CWTS 2015-15, (Washington, D.C.: Sept. 

2015).

The Corps Has 

Efforts Under Way to 

Improve Its Ability to 

Respond to Extreme 

Weather

The Corps Is Developing a 

Strategy to Revise 

Drought Contingency 

Plans and Is Studying the 

Use of Forecasts to Make 

Operations Decisions at 

Two Projects
Page 19 GAO-16-685 Army Corps of Engineers

model of future conditions. According to the Corps’ 2015 report, the 

agency subsequently identified and reviewed all of its drought 

contingency plans. The Corps’ review found (1) that none of the plans 

contained information on drought projections under future climate change 

and (2) that it was unlikely that the plans provided an adequate guide for 

preparing for future droughts.

As of May 2016, the Corps was conducting pilot updates of drought 

contingency plans at five high-priority projects to help test methods and 

tools for those plans to account for a changing climate. According to the 

Corps’ 2015 report, these pilot projects will help the agency develop a 

framework for a systematic update of drought contingency plans. Corps 

officials said these pilots are to be largely completed by the end of 

calendar year 2016. The Corps has created an internal website available 

to all Corps officials to disseminate the results of the drought contingency 

plan analysis, pilot project results, and other drought-related information. 

In addition to completing the pilot projects, Corps officials said the agency 

plans to compile a list of drought contingency plan priorities by the middle 

of fiscal year 2017 for inclusion in the fiscal year 2018 budget.

In addition to its efforts related to drought contingency plans, the Corps is 

studying the use of forecasting tools to determine whether water control 

manuals can be adjusted to improve water-supply and flood-control 

operations at two projects in California—Folsom Dam and Lake 

Mendocino.32 The Corps has historically used forecasts to some degree 

in its operations, largely by using models that create a single forecast 

based on the existing hydrologic data. According to Corps officials, the 

Folsom Dam and Lake Mendocino projects are evaluating the potential to 

incorporate forecasts into their operational rules, by using statistical 

techniques to simulate multiple, slightly different initial conditions and 

identify a range of potential outcomes and their probability. The use of 

forecasts at these projects will depend on whether the skill of the 

forecasts is improved to the point where they are viable in informing 

 32The Corps is undertaking this effort at Folsom Dam because the Water Resources 

Development Act of 1999 requires the Secretary of the Army to update the Dam’s flood 

management plan to reflect improved weather forecasts, among other things. Pub. L. No. 

106-53, §101(a)(6)(E), 113 Stat. 269, 274 (1999). According to Corps officials, the Lake 

Mendocino effort began at the request of the County of Sonoma.
Page 20 GAO-16-685 Army Corps of Engineers

reservoir operations.33 Corps officials told us that the forecasts must be 

accurate in terms of space and time to allow the reservoirs to retain some 

water for future supply as long as the retained water can be safely 

released, if necessary, prior to the next storm.

At the first project, Folsom Dam, the Corps and the Department of the 

Interior’s Bureau of Reclamation are constructing an auxiliary spillway 

project to improve the safety of the dam and reduce the flood risk for the 

Sacramento area.34 Officials also said the water control manual must be 

updated to reflect the physical changes to the project, but the Corps is 

also considering incorporating forecasting into its operating rules so that 

prior to storm events, water can be released earlier than without 

forecasting capabilities. Corps officials said the revisions to the Folsom 

Dam water control manual, outlining the forecast-based operations, are 

estimated to be completed in April 2017. For the second project, Lake 

Mendocino, an interagency steering committee was formed to explore 

methods for better balancing water supply needs and flood control by 

using modern forecasting observation and prediction technology. Corps 

officials told us the interagency committee expects to complete a 

preliminary viability study on the project by the end of calendar year 2017.

Corps headquarters officials said that once they determine how 

forecasting can be incorporated into these projects, the agency may 

consider using forecast-based operations at other projects. Four of the 

five knowledgeable stakeholders we interviewed said that it would be 

important for the Corps to consider using such operations to help ensure 

efficiency and to be able to respond to changing patterns of precipitation. 

These views are consistent with our 2014 report on the Missouri River 

flood and drought of 2011 to 2013, in which we recommended that the 

 33Forecasting skill is the statistical evaluation of the accuracy of forecasts or the 

effectiveness of detection techniques.

34The Bureau of Reclamation has carried out its mission to manage, develop, and protect 

water and related resources in 17 western states since 1902. The agency has led or 

provided assistance in constructing most of the large dams and water diversion structures 

in the West for the purpose of developing water supplies for irrigation, as well as for other 

purposes, including hydroelectric power generation, municipal and industrial water 

supplies, recreation, flood control, and fish and wildlife enhancement. For more 

information, see GAO, Bureau of Reclamation: Availability of Information on Repayment of 

Water Project Construction Costs Could Be Better Promoted, GAO-14-764 (Washington, 

D.C.: Sept. 8, 2014).
Page 21 GAO-16-685 Army Corps of Engineers

Corps evaluate forecasting techniques that could improve its ability to 

anticipate weather developments for certain projects.35 However, Corps 

officials and knowledgeable stakeholders also said that the Corps faces 

two key challenges in implementing forecast-based operations at its 

reservoirs. First, four of the five knowledgeable stakeholders we 

interviewed said that the Corps’ primary mission of flood control makes it 

difficult for the agency to accept the uncertainty that is involved with 

forecasting. Second, forecasting may be more complex in certain regions 

of the country, because according to one knowledgeable stakeholder and 

Corps officials, much of the rain in California is a result of atmospheric 

rivers,36 which produce rainfall that is more predictable than the 

convection rains that are experienced in the Midwest.37

The Corps’ Responses to Climate Change program is conducting 

research on adaptation measures through vulnerability assessments for 

inland projects and sedimentation surveys.38 In 2012, the Corps initiated 

an initial vulnerability assessment that focused on how hydrologic 

changes due to climate change may impact freshwater runoff in some 

watersheds. This assessment identified the top 20 percent of watersheds 

most vulnerable to climate change for each of the Corps’ business lines.39

According to Corps officials, this assessment was conducted for 

watersheds, because actionable science was not currently available to 

conduct such an assessment at the project level. However, the Corps is 

working with an expert consortium of federal and academic 

 35GAO, Missouri River Flood and Drought: Experts Agree the Corps Took Appropriate 

Action, Given the Circumstances, but Should Examine New Forecasting Techniques, 

GAO-14-741 (Washington, D.C.: Sept. 12, 2014). The Department of Defense agreed with 

our recommendation to evaluate the pros and cons of forecasting techniques.

36Atmospheric rivers are relatively narrow regions in the atmosphere that are responsible 

for most of the horizontal transport of water vapor outside of the tropics.

37In meteorology, the term convection is used specifically to describe vertical transport of 

heat and moisture in the atmosphere, especially by updrafts and downdrafts in an 

unstable atmosphere.

38Vulnerability assessments identify, quantify, and prioritize the vulnerabilities in a system. 

Sedimentation surveys determine the amount of sediment that is in a reservoir.

39U.S. Army Corps of Engineers’ business lines include flood risk reduction, navigation, 

ecosystem restoration, hydropower, recreation, regulatory, water supply, and emergency 

management.

The Corps Is Conducting 

Research on How to 

Better Prepare Operations 

for Extreme Weather
Page 22 GAO-16-685 Army Corps of Engineers

organizations—including NOAA, the Bureau of Reclamation, USGS, the 

University of Washington, and the University of Alaska—to develop future 

projected climatology and hydrology at finer scales. This project is 

intended to provide the Corps and its partners and stakeholders with a 

consistent, 50-state strategy to further assess vulnerabilities, a strategy 

that will also support planning and evaluation of different adaptation 

measures to increase resilience to specific climate threats. According to 

the Corps, this consortium holds monthly meetings to review progress 

made by the various members. According to Corps officials, the 

consortium plans to release reports in 2016 and 2017 that will enable the 

Corps to improve tools, methods, and guidance for finer-resolution 

analyses using climate-impacted hydrology.

The Corps has also begun to evaluate reservoir vulnerabilities to altered 

sedimentation rates resulting from extreme weather and land use 

changes. In 2012, the Corps began conducting 15 pilot studies at various 

districts to test different methods and serve as a framework for adapting 

to climate change. Two of these pilots predicted changes in the amount of 

sediment in a reservoir because of changes in hydrologic variables as a 

result of climate change. Additionally, according to the Corps’ website, 

reservoirs in areas with drought conditions have experienced lower-thannormal levels of water in their conservation storage pools. These lower 

levels have revealed additional and unexpected sedimentation in 

reservoirs that could reduce the space available to store water. In 2013, 

the Corps developed a program to deploy airborne laser scanning 

systems to measure and collect data on the reservoirs in drought-affected 

areas. In 2015, this system was tested in California to refine the process 

to collect sedimentation data and modify the system for specific aircraft. 

According to a Corps official we interviewed in the Responses to Climate 

Change program, the agency plans to further refine the data collected 

and evaluate how these data change over time. This effort, the official told 

us, is also expected to provide indicators to support the analysis of future 

sedimentation rates based on climate changes for use in the Corps’

climate vulnerability analysis. The official said a baseline report on the 

Corps’ reservoir sedimentation status is expected by the end of fiscal year 

2016. This effort was highlighted in the action plan for the President’s 

Memorandum on Building National Capabilities for Long-Term Drought 
Page 23 GAO-16-685 Army Corps of Engineers

Resilience, which lays out a series of activities to fulfill the President’s 

drought-resilience goals.40

The Corps has revised some of the water control manuals used to 

operate its water resources projects, which serve important public 

purposes such as flood control, irrigation, and water supply. But district 

officials told us there are manuals that do not reflect the changing 

conditions in the areas surrounding the projects. A Corps engineer 

regulation states that the water control manuals should be reviewed no 

less than every 10 years and revised as needed. However, there is no 

Corps guidance on what activities constitute a review, and while district 

officials said they informally reviewed selected water control manuals 

through daily operations, they also said they do not document these 

reviews. Without developing guidance on what activities constitute a 

review of a water control manual and how to document that review, the 

Corps does not have reasonable assurance that its districts will 

consistently conduct reviews and document them to provide a means to 

retain organizational knowledge and mitigate the risk of having that 

knowledge limited to personnel directly involved with these reviews.

In addition, while the Corps has revised certain water control manuals in 

accordance with its engineer regulation, it does not track consistent 

information on revisions to its manuals. Furthermore, district officials said 

that they have requested funds to revise additional water control manuals 

as needed to reflect changing conditions, but they have not received 

those funds, and have not tracked consistent information about manuals 

needing revisions. However, internal control standards in the federal 

government call for agencies to clearly and promptly document 

transactions and other significant events from authorization to completion.

Without tracking which manuals need revision, it is difficult for the Corps 

to know the universe of projects that may not be operating in a way that 

reflects current conditions as called for in the Corps’ engineer manual and 

to prioritize revisions as needed. Because some manuals that need 

revision have not been revised and some district officials noted that 

operations for certain projects differ from aspects of the approved water 

 40The White House, Long-Term Drought Resilience: Federal Action Plan of the National 

Drought Resilience Partnership, (Washington, D.C.: March 2016).

Conclusions
Page 24 GAO-16-685 Army Corps of Engineers

control plans in those manuals, the Corps lacks assurance that project 

operations are conforming to the objectives of authorizing legislation.

To help improve the efficiency of Corps operations at reservoir projects 

and to assist the Corps in meeting the requirement of the Water 

Resources Reform and Development Act of 2014 to update the Corps’

1992 reservoir report, we recommend that the Secretary of Defense direct 

the Secretary of the Army to direct the Chief of Engineers and 

Commanding General of the U.S. Army Corps of Engineers to take the 

following two actions:

• develop guidance on what activities constitute a review of a water 

control manual and how to document that review; and

• track consistent information on the status of water control manuals, 

including whether they need revisions, and prioritize revisions as 

needed.

We provided a draft of this report for review and comment to the 

Department of Defense. In its written comments, reprinted in appendix I, 

the department concurred with our recommendations and noted that it will 

take steps to address these recommendations as it updates its guidance.

In its comments, the department also stated that, as of May 2016, it had

updated its Engineer Regulation 1110-2-240, Engineering and Design: 

Water Control Management. We incorporated this information into the 

report.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, and other interested parties. In 

addition, the report is available at no charge on the GAO website at 

http://www.gao.gov. 

Recommendations for 

Executive Action

Agency Comments
Page 25 GAO-16-685 Army Corps of Engineers

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or fennella@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix II.

Anne-Marie Fennell

Director, Natural Resources and Environment
Appendix I: Comments from the Department of

Defense

Page 26 GAO-16-685 Army Corps of Engineers

Appendix I: Comments from the Department 

of Defense
Appendix I: Comments from the Department of 

Defense

Page 27 GAO-16-685 Army Corps of Engineers
Appendix II: GAO Contact and

Staff Acknowledgments

Page 28 GAO-16-685 Army Corps of Engineers

Anne-Marie Fennell, (202) 512-3841 or fennella@gao.gov

In addition to the individual named above, key contributors to this report 

included Vondalee R. Hunt (Assistant Director), Cindy Gilbert, Richard 

Johnson, Cynthia Norris, Dan Royer, Holly Sasso, Jeanette Soares, and 

Michelle R. Wong.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100281)
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