OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION 

January 25, 2008 

MEMORANDUM FOR COMMANDING GENERAL, MULTI-NATIONAL FORCE-IRAQ 

COMMANDING GENERAL, MULTI-NATIONAL Corps-Iraq 

U.S. AMBASSADOR TO IRAQ 

COORDINATOR, OFFICE of Provincial affairs 

SUBJECT: Commander’s Emergency Response Program in Iraq Funds Many Large-Scale 

Projects (SIGIR-08-006) 

We are providing this audit report for your information and use. We performed the audit in 

accordance with our statutory duties under Public Law 108-106, as amended. The law requires 

that we produce independent and objective audits of—as well as leadership, coordination, and 

recommendations on—policies designed to promote economy, efficiency, and effectiveness in 

the administration of programs and operations and to prevent and detect waste, fraud, and abuse. 

This review was conducted as SIGIR project 7019. 

We considered comments from the Multi-National Corps-Iraq when preparing the final report. 

The comments are addressed in the report, where applicable, and a copy is included in the 

Management Comments section of this report. 

We appreciate the courtesies extended to the staff. For additional information on this report, 

please contact Walt Keays (walt.keays@iraq.centcom.mil / 914-822-2796); or Glenn Furbish at 

glenn.furbish@sigir.mil /703-428-1058. 

 

Stuart W. Bowen, Jr. 

Inspector General 

 

 

400 Army Navy Drive • Arlington, Virginia 22202
Table of Contents 

Executive Summary i

Introduction

Background 1 

Objectives 5 

Findings 

High Percentage of CERP Funding Devoted to a Relatively Small 

Percentage of Projects 6 

Large Project Management Issues 8 

Issues and Lessons Learned Concerning Planning for Project Transfers 

and Long-term Sustainment 9 

Conclusion and Recommendations 11

Appendices 

A. Scope and Methodology 12 

B. CERP Related Public Laws 15 

C. Acronyms 16 

D. Audit Team Members 17 

Management Comments 

Multi-National Corps - Iraq 18 
Commander’s Emergency Response Program in Iraq 

Funds Many Large-Scale Projects 

SIGIR-08-006 January 25, 2008

Executive Summary 

Introduction 

In May 2003, the Coalition Provisional Authority (CPA) formalized the Commander’s 

Emergency Response Program (CERP) in Iraq, authorizing U.S. field commanders to use 

available funds to respond to urgent humanitarian, relief, and reconstruction requirements within 

a commander’s area of responsibility by executing programs that immediately assist indigenous 

populations and achieve “focused effects.” CERP guidance directs commanders to focus funds 

on projects that improve water and sanitation, electricity, and civic cleanup and that employ the 

most Iraqis over an extended period of time. Selection of a project is expected to be based on 

how quickly they can be executed, how many Iraqis would be employed, how many would 

benefit, and the “visibility” of the project. 

Initial funding for CERP came from seized Iraqi assets and the Development Fund for Iraq.1 By 

late 2003 the United States began to appropriate U.S. dollars to CERP and by the end of fiscal 

year 2007, Congress has appropriated over $2.3 billion for the CERP program in Iraq.

The Multi-National Corps-Iraq is the overall program coordinator for CERP. MNC-I publishes 

Money as a Weapon System (MAAWS), a policies and procedures manual that directs program 

execution and establishes the goals for CERP funding. 

This SIGIR report contrasts funding devoted to small-scale projects typically associated with the 

CERP program with funding devoted to more expensive, large-scale CERP projects; it also 

provides observations regarding the applicability of selected management issues identified in 

prior SIGIR reviews, and lessons learned noted in this review that could be important to 

managing such projects. 

Results in Brief 

Improved management controls over CERP projects, particularly those that are costly, will help 

ensure each project’s long-term benefit and viability, as well as the effective investment of U.S. 

funds. Since the inception of CERP in Iraq in 2003, more than 18,000 projects have been 

 

1

 The Development Fund for Iraq (DFI) was established May 2003 by the UNSC Resolution 1483 as a means to 

channel revenue from Iraqi oil sales, unencumbered Oil for Food deposits, and repatriated Iraqi assets to the relief 

and reconstruction efforts for Iraq. 

i
initiated and more than 14,000 have been completed. According to CERP guidelines, the 

program’s undertakings should primarily be small-scale, urgent humanitarian relief and 

reconstruction projects for the benefit of the Iraqi people—and to some extent that has been the 

case. For example, since Fiscal Year 2004 CERP projects estimated to cost2

 $25,000 or less 

have represented over 44 percent of total CERP projects in Iraq—but just four percent of total 

dollars obligated for the program. Conversely, since Fiscal Year 2004, CERP projects estimated 

to cost $500,000 or more have represented less than three percent of all CERP projects, but 

nearly 37 percent of total dollars obligated. Projects in the water sector have been the 

predominant large-scale CERP projects receiving about $567 million, more than 28 percent of all 

CERP obligated funds; electricity projects and transportation projects have also been heavily 

funded. 

In several prior reports on CERP program management, SIGIR has identified management 

weaknesses including 1) coordination of program activities, 2) maintenance of project folders, 

and 3) planning for the transition of completed projects to the Iraqi government. The third of 

those issues includes both the physical handover of completed projects and planning for their 

long-term maintenance and sustainment. We are including the issues in this report because of 

their importance to the long-term success of large-scale projects. 

SIGIR has previously reported that the Iraqi government is not yet fully prepared to take over the 

near- or long-term management and funding of many U.S. funded infrastructure projects and that 

additional efforts are needed to ensure their viability. Although MNC-I officials told us that they 

have increased their emphasis on transition and sustainment issues, SIGIR is concerned that the 

MAAWS guidance still contains little specific direction on unit responsibilities in these areas. 

These issues take on greater importance for Iraq reconstruction projects because most funding 

from the principal source of reconstruction funding, the Iraq Relief and Reconstruction Fund, has 

been obligated—now leaving CERP as a significant source. 

During the course of our review, CERP program officials told us of important lessons they have 

learned that, if adequately documented, could benefit future program managers. The lessons 

learned were particularly focused on giving greater emphasis to transfer and sustainment issues. 

However, at present MNC-I has no formal process for collecting and documenting these lessons. 

Recommendations 

We recommend that the Commanding General, Multi-National Corps-Iraq, direct that these 

actions be taken: 

1. Reinforce the importance of documenting project files, especially for large-scale, projects 

that are considered high cost, technologically complex, and maintenance intensive 

activities. 

2. Include more specific guidance in the MAAWS to address both transition and 

sustainment of CERP projects above an established value particularly those projects that 

 

2

 SIGIR uses funding obligations in this report to provide the basis for depicting trends in project and program costs 

involving both ongoing and completed projects. SIGIR refers to these obligated amounts as estimated project costs. 

ii
are considered high cost, technologically complex, and maintenance intensive activities 

as noted above. 

3. Develop an appropriate process for developing and disseminating lessons learned from 

the CERP program to assist future program officials as unit rotations occur to reduce 

learning curves and facilitate continuity in program management. 

Management Comments 

We received written comments on a draft of this report from MNC-I. The MNC-I Chief of Staff 

concurred with all recommendations and has identified corrective actions that have been initiated 

or planned. According to the comments, they have implemented a records 

recovery/reconstruction policy to remedy missing project files. MNC-I agreed that while lessons 

learned were captured and disseminated in various medium, a more formal process would be 

helpful. They agreed to explore more formal option to include the Center for Army Lessons 

Learned (CALL). The comments received were fully responsive and are included in the 

Management Comments section of this report. 

iii
Introduction 

Background 

In May 2003, the Coalition Provisional Authority (CPA) formalized the Commander’s 

Emergency Response Program (CERP) in Iraq, authorizing U.S. field commanders to use 

available funds to respond to urgent humanitarian, relief, and reconstruction requirements within 

the commander’s area of responsibility by executing programs that immediately assist 

indigenous populations and achieve “focused effects.” Initial funding for CERP came from 

seized Iraqi assets and the Development Fund for Iraq. By late 2003 the United States began to 

appropriate U.S. dollars to the CERP and since 2003, Congress has appropriated over $2.3 

billion for the program in Iraq.

The Multi-National Corps-Iraq (MNC-I) headquartered in Baghdad, Iraq, provides the overall 

program coordination for the CERP in Iraq.3 MNC-I currently consists of seven Major 

Subordinate Commands (MSCs) headquartered throughout Iraq--including its newest location, 

Multi-National Division-Center (MND-C), established in April 2007. The MSCs propose, 

initiate, and execute both reconstruction and non-construction projects in their areas of 

responsibility. In fiscal year 2007, the individual MSC areas of responsibilities were managed by 

the Coalition forces listed below: 

• Multi-National Division-Baghdad – U.S. Army forces 

• Multi-National Division-Center South – Coalition forces (Poland) 

• Multi-National Division-Center – U.S. Army forces 

• Multi-National Division-North – U.S. Army forces 

• Multi-National Division-Northeast – Coalition forces (Republic of Korea) 

• Multi-National Division-Southeast – Coalition forces (British and Australian) 

• Multi-National Force-West – U.S. Marine Corps forces 

Each of the MSCs is a division or force level command group further divided into brigades. The 

Brigade Combat Teams (BCTs) are located throughout the MSC area of responsibility and are 

responsible for much of the day-to-day management of CERP projects. MNC-I publishes Money 

as a Weapon System (MAAWS), a policies and procedures manual that directs program 

execution and establishes the goals for CERP funding. CERP guidelines authorize a variety of 

projects but direct commanders to focus funds on projects that improve water and sanitation, 

electricity, and civic cleanup and that employ the most Iraqis over an extended period of time. 

Also, purchasing officers are encouraged to use local Iraqi firms to conduct CERP projects. 

Table 1 depicts the range of authorized CERP projects.

 

3

 MNC-I is a subordinate command of the Multi-National Force-Iraq (MNF-I). MNF-I provides guidance, 

establishes priorities, and identifies focus areas for subordinate units in support of the strategic objectives of its 

Campaign Plan. 

1
Table 1—Range Of CERP Projects Authorized In Iraq 

1. Water and sanitation – projects to repair or 

reconstruct water or sewer infrastructure, including 

water wells. 

11. Irrigation – projects to repair or 

reconstruct irrigation systems. 

2. Food production and distribution – projects to 

increase food production or distribution processes. 

12. Civic cleanup activities – projects to 

remove trash, cleanup the community, or 

beautify the surroundings. 

3. Agriculture – projects to increase agricultural 

production or cooperative agricultural programs. 

13. Civic support vehicles – projects to 

purchase or lease vehicles to support civic and 

community activities. 

4. Electricity – projects to repair or reconstruct 

electrical power or distribution infrastructure, including 

generators. 

14. Repair of civic and cultural facilities – 

projects to repair or restore civic or cultural 

buildings or facilities. 

5. Healthcare – projects to repair or reconstruct 

hospitals or clinics or to provide urgent healthcare 

services, immunizations, medicine, medical supplies, or 

equipment. 

15. Repair of damage that results from U.S., 

Coalition, or supporting military operations and 

is not compensable under the Foreign Claims 

Act (repair of homes and businesses). 

6. Education – projects to repair or reconstruct 

schools, purchase school supplies or equipment. 

16. Condolence payments to individual 

civilians for death, injury, or property damage 

resulting from U.S. Coalition, or supporting 

military operations. 

7. Telecommunications – projects to repair or 

reconstruct telecommunications systems or 

infrastructure. 

17. Payment to individuals upon release 

from detention

18. Protective measures – such as fencing, 

lights, barrier materials, berming over 

pipelines, guard towers, temporary civiliancontractor guards, etc. to enhance the 

durability and survivability of critical 

infrastructure sites (e.g., oil pipelines and 

electrical lines.) 

8. Economic, financial, and management 

improvements – projects to improve economic or 

financial security. 

9. Transportation – projects to repair or reconstruct 

transportation systems, roads, bridges, or 

transportation infrastructure. 

19. Other urgent humanitarian or 

reconstruction projects – projects to repair 

collateral battle damage not otherwise 

compensable because of combat exclusions or 

condolence payments. 

10. Rule of law and governance – projects to repair 

or reconstruct such government buildings as 

administration offices, courthouses, or prisons. 

20. Micro-Grants – to provide assistance to 

disadvantaged small business and 

entrepreneurs. 

Source: CERP program guidance 

In addition to MNC-I’s role in executing CERP projects, the U.S. Army Corps of Engineers Gulf 

Regional Division (GRD), headquartered in Baghdad, provides planning, engineering, 

contracting, and project management expertise and services to MNF-I and other U.S. agencies. 

GRD executes larger reconstruction projects for MNC-I and/or the MSCs. GRD has three 

regional offices strategically located throughout Iraq—in the North (GRN), Central-Baghdad 

(GRC), and South (GRS). In addition, the Joint Contracting Command-Iraq/Afghanistan (JCC2
I/A) supports a small number of CERP projects for MNC-I and/or the MSCs in Iraq. JCC-I/A, 

headquartered in Baghdad, provides operational contracting support to MNF-I for the efficient 

acquisition of vital supplies, services, and construction. 

Further, the Multi-National Security Transition Command-Iraq (MNSTC-I), also a subordinate 

MNF-I command and headquartered in Baghdad, has proposed, initiated, and executed both 

reconstruction and non-construction CERP projects. MNSTC-I organizes, equips, and mentors 

the Iraqi Security Forces. MNSTC-I must adhere to MNC-Is standard operating procedures and 

guidance specified in the MAAWS regarding CERP funds and project execution. Since Fiscal 

Year (FY) 2004, MNSTC-I has managed over 150 CERP projects with a combined obligation of 

over $24.9 million (approximately 1.3% of the program’s total obligations).

Initially, funding for CERP came from seized Iraqi assets and the Development Fund for Iraq 

(DFI). In November 2003, the Congress passed the first appropriation for CERP as part of 

Public Law (P.L). 108-106, the “Emergency Supplemental Appropriations Act for Defense and 

for the Reconstruction of Iraq and Afghanistan, 2004.” Section 1110 of P.L. 108-106 

appropriated $180 million for CERP in Iraq and to fund a similar program in Afghanistan; of the 

total, $140 million was allocated to Iraq. 

Table 2 identifies each of the public laws that have established the appropriation level and 

authorization for CERP in each fiscal year. The appropriation level is generally a combination of 

an annual and supplemental appropriation, usually only available for obligation until the end of 

the affected fiscal year. FY2006 was an exception: the supplemental appropriation, P.L. 109-

234, allowed for the obligation of these funds until December 31, 2007. This allowed 

unobligated portions of the supplemental to be used in FY2007 and the first quarter of FY2008. 

3
Table 2—CERP Funds Provided For Fiscal Years 2004-2007 (dollars in millions)

Appropriations, Allocations, Obligations, Disbursements 

Fiscal 

Year 

Funds 

Public Laws 

Establishing 

Final 

Appropriation 

Funds 

Obligation 

Period End 

Date 

Total 

Appropriated 

(both Iraq & 

Afghanistan)

CERP Iraq 

Allocation 

Total 

Obligated 

Total 

Disbursed As of date 

FY04 P.L. 108-106 30-Sep-2004 $180.0 $140.0 $140.0 $46.4 2-Oct-04 

FY05 

P.L. 108-287 

P.L. 108-375 

P.L. 108-447 

 P.L. 109-13 

30-Sep-2005 $854.0 $718.0 $718.0 $333.2 2-Oct-05 

FY06 

P.L. 109-148 

P.L. 109-163 

P.L. 109-234 

30-Sep-2006

31-Dec-2007 

$923.0 $509.5 $509.5 $177.0 2-Oct-06 

FY06* P.L. 109-234 31-Dec-2007 $198.0 $198.0 $173.1 $87.6 20-Sep-07 

FY07 P.L. 109-289 

 P.L. 110-28 30-Sep-2007 $956.4 $750.4 $690.7 $332.7 20-Sep-07 

Total All Years $3,111.4 $2,315.9 $2,231.3 $976.9

Source: SIGIR analysis of Funding Data Provided by U.S. Army Central (ARCENT)

*Note: In FY06, P.L. 109-234 set the obligation period end date at December 31, 2007 which allowed for the carry over of $198 million in 

FY06 supplemental funding for use in FY07 or first quarter FY08. 

As noted in table 2, from fiscal years 2004-2007, over $2.3 billion in appropriations has been 

allocated to the CERP program in Iraq. 

SIGIR has issued four reports4

 on the management controls and accountability of CERP funds5

since the program’s inception in 2003. All four reports stated that generally, for projects 

reviewed, CERP appropriated funds were properly used for intended purposes; however, controls 

over CERP processes required improvements to ensure accountability of the projects. Our April 

2007 report identified a lack of formal coordination of CERP projects with other reconstruction 

programs that limited the effectiveness of CERP projects. Facility sustainment is another issue 

 

4 Management of the Commander’s Emergency Response Program for Fiscal Year 2004 (SIGIR-05-014, October 

13, 2005); Management of the Commander’s Emergency Response Program for Fiscal Year 2005 (SIGIR-05-025, 

January 23, 2006); Management of the Iraqi Interim Government Fund (SIGIR-06-031, October 27, 2006); and 

Management of the Commander’s Emergency Response Program in Iraq for Fiscal Year 2006 (SIGIR-07-006, April 

26, 2007). 

5

 The CERP family of funds consists of the Commander’s Emergency Response Program, the Commander’s 

Humanitarian Relief and Reconstruction Program, and the Interim Iraqi Government Fund. 

4
addressed in prior SIGIR reports; but as noted in our October 18, 2007 report on the Provincial 

Reconstruction Team Program, it remains an issue still in need of management attention.6

Objectives 

This report contrasts funding devoted to small-scale projects typically associated with the CERP 

program with funding devoted to more expensive, large-scale CERP projects. It also provides 

observations regarding the continued applicability of selected management issues identified in 

prior SIGIR reviews, and lessons learned noted in this review, that could be important to 

managing large CERP projects. 

For a discussion of the audit scope and methodology, see Appendix A. For a listing of CERP 

related public laws, see Appendix B. For definitions of acronyms used, see Appendix C. For a 

list of the audit team members, see Appendix D. 

 

6 Review of the Effectiveness of the Provincial Reconstruction Team Program in Iraq (SIGIR-07-015, October 18, 

2007). 

5
High Percentage of CERP Funding Devoted to a 

Relatively Small Percentage of Projects 

Since the inception of CERP in Iraq in 2003, over 18,000 projects have been initiated and over 

14,000 completed. CERP has often been viewed as intended primarily for small-scale, urgent, 

humanitarian relief and reconstruction projects for the benefit of the Iraqi people and that is 

accurate in terms of numbers of projects. However, a large portion of CERP funding has been 

devoted to projects with estimated costs of $500,000 or more. These high-cost projects include a 

mix of reconstruction and non-construction projects. While the average cost of all CERP projects 

has increased over time, those involving reconstruction are the most expensive. 

Since FY 2004 over 44 percent of CERP projects in Iraq have been relatively small in scale–with 

an estimated cost of $25,000 or less. Conversely, the number of projects estimated to cost 

$500,000 or more have represented a small percent of total CERP projects but, in most years 

have accounted for a large percentage of total CERP obligations.7

 In FY 2004, CERP projects 

with funding obligations at or above $500,000 represented less than one percent of all CERP 

projects that year, and eight percent of all funding obligations, but those percentages increased 

considerably in subsequent years. Table 3 shows the impact of these high-cost projects on the 

overall CERP program over time. 

Table 3—Obligations Associated With Large Dollar-Value CERP Projects 

From Fiscal Years 2004-2007

Fiscal Years Total CERP Projects 

Percent of Total 

CERP Projects 

With Obligations 

At Or Above 

$500,000 

Percent of Total 

Obligations for 

Projects with 

Obligations at or above 

$500,000 

2004 771 <1 8 

2005 7,423 2.5 26.9 

2006 3,886 3.8 48.1 

2007 6,301 2.8 40.1 

Total 18,381 2.8 36.8 

Source: SIGIR analysis of Iraq Reconstruction Management System (IRMS) data from MNC-I

Table 3 shows that overall, the number of CERP projects with obligations of $500,000 or more 

comprised less than three percent of all CERP projects between fiscal years 2004-2007, but 

nearly 37 percent of total CERP obligations. 

 

7

 SIGIR uses funding obligations in this report to provide the basis for depicting trends in project and program costs 

involving both ongoing and completed projects. SIGIR refers to these obligated amounts as estimated project costs. 

6
Over 79 percent of all CERP projects with obligations of $500,000 or more between fiscal years 

2004-2007 were for reconstruction projects. Those in the water sector have been the 

predominate large-scale CERP projects, receiving about $567 million dollars; electricity projects 

and transportation projects have also been heavily funded. Table 4 depicts the diversity of 

overall reconstruction and non-construction projects. 

Table 4—Examples of reconstruction and non-construction projects costing 

$500,000 or more 

Reconstruction Projects Non-construction Projects 

Electrical Distribution in Muhalla Purchase of Fallujah Telecom Equipment 

Rehabilitation of Two Biap Domestic Terminals Trash Trucks for North Babil 

Garbage Collection Through Mosul 

Al Arbar School Neighborhoods 

Basrah Airport Terminal Fire System Purchase of Ambulances for Diyala 

Paving New Rural Road From Showairej to 

Tak Harb Date Palm Planting (Abu Kaseeb) 

Fallujah Solar Street Lights Generators for Ramadi General Hospital 

Nasiriyah Sewerage Project Support of December Election 

Al Anbar Canal Clearing and Irrigation 

Mahavil City Water Treatment Plant Project Restoration 

Al Bitar Cardiac Hospital Purchase of Seed and Fertilizer 

Agricultural Restoration and Irrigation 

Jumharya Public Healthcare Center Canals Project 

Source: SIGIR analysis of IRMS data from MNC-I 

Finally, we determined that the average funding obligation for all CERP projects over the life of 

the program in Iraq through September 2007 has been approximately $109,000, but that average 

costs for FY 2007 were approximately $119,000. At the same time, the average obligation for 

reconstruction projects alone over the life of the CERP program in Iraq has been approximately 

$155,000, but for FY 2007 were nearly $173,000. Thus, both categories of projects show some 

growth in costs over time. 

7
Large Project Management Issues 

SIGIR’s prior CERP reviews identified a number of management control issues involving CERP 

projects that can be especially important to managing large, high-cost CERP projects, and this 

review reinforced the need for management attention to those issues.8

 Two key issues we 

previously identified were incomplete project folders; and inadequate attention to planning for 

transferring completed reconstruction projects to the Iraqi people, including emphasis on longterm maintenance and sustainment of the projects. Program officials who responded to a survey 

questionnaire used in this review cited some continuing weaknesses in these areas, including 

limited program guidance on transition planning. 

We reported in our April 2007 review of the CERP program for 2006 that we had consistently 

found that Coalition forces did not fully comply with the published guidance for maintaining the 

documentation required to ensure accountability and oversight of CERP projects. We noted 

during this review that CERP program guidance had been revised in November 2006 and 

included as a section in the MAAWS and provided more specific guidance regarding listing the 

required documentation for completed CERP files. This guidance was again revised in June 

2007 and is the current version. 

While the revised guidance is an improvement, cognizant program officials pointed to a 

continued absence of any required oversight regarding implementation of the guidance; the 

officials said they do not routinely check the files for adherence to the guidance. Project record 

documentation and retention continues to be of concern even to program officials. 

Program officials also cited some major factors affecting file maintenance: the periodic 

changeover of military personnel (especially at the contract officer level) as unit rotations occur; 

the relatively short time for transitioning from one unit to the next; and lack knowledge of CERP 

program requirements among transition teams and incoming units. Officials noted that when 

new units arrive, they are expected to pick up where others left off, including managing 

numerous project files, conducting on-site surveys, writing status reports, and processing project 

file documentation, with little or no prior knowledge or experience. 

While the above were cited as problems leading to inadequate CERP project file maintenance, 

we believe they also highlight the importance of maintaining up-to-date project files in order to 

reduce the learning curve for incoming personnel and improve ongoing project management. 

We plan further work to assess compliance with requirements for project file documentation. 

 

8 Management of the Commander’s Emergency Response Program for Fiscal Year 2004 (SIGIR-05-014, October 

13, 2005); Management of the Commander’s Emergency Response Program for Fiscal Year 2005 (SIGIR-05-025, 

January 23, 2006; Management of the Commander’s Emergency Response Program for Fiscal Year 2005 (SIGIR05-025, January 23, 2006); Management of the Iraqi Interim Government Fund (SIGIR-06-031, October 27, 2006); 

and Management of the Commander’s Emergency Response Program in Iraq for Fiscal Year 2006 (SIGIR-07-006, 

April 26, 2007). 

8
Issues and Lessons Learned Concerning Planning for 

Project Transfers and Long-term Sustainment 

SIGIR also received a number of lessons learned from program officials that are especially 

applicable to managing large-scale projects and ensuring effective transfer of completed projects 

to the Iraqi people. 

A number of our prior reports have highlighted the need for improved planning related to the 

transition of completed projects to the Iraqi people and provision for their long-term maintenance 

and sustainment. Historically, there has been minimal MNC-I guidance regarding the transfer 

and sustainment of CERP projects to the Government of Iraq (GoI). More recently, a June 2007 

update to the MAAWS guidance, under project identification, states that coordination with local 

officials is critical to ensure that the project meets a perceived need by the population, is 

appropriate to the culture, and will be maintained in the future. It recognizes that Coalition 

forces have built numerous projects that did not meet the projects’ intended purpose due to lack 

of coordination with local officials. Further, it recommends discussing operations, maintenance, 

and staffing before any project begins. While this language is an important addition to the 

guidance, it does not specifically require resolution of transfer and sustainment issues prior to 

project initiation and funding. 

During this review, information provided by MNC-I officials indicates that although increased 

emphasis has been given to transition and sustainment issues, further opportunities for 

improvement remain. Some MSCs indicated that they have, on their own initiative, initiated local 

policies and procedures to address the transition and sustainment issues, while others have not. 

Likewise, MNC-I noted that emphasis on planning for the transfer and sustainment of completed 

projects varies from project to project and among the major subordinate commands responsible 

for executing the program. 

At the same time, a number of CERP program officials cited important lessons learned that, if 

adequately documented for retention purposes, could benefit personnel taking their place as unit 

rotations occur. These lessons learned could also provide greater emphasis on transfer and longterm sustainment issues. For example, lessons learned information provided to us included: 

• It is important to ensure any sustainment issues are addressed at the time a project is 

being conceptualized so that the customer can understand the operating and sustainment 

costs to assist in selecting and prioritizing projects. 

• A GRN official noted that funding for sustainment costs often depends upon the 

knowledge level and political skill of the people in the chain of leadership who request 

funds for the projects in their area of responsibility. Conversely, a GRS official indicated 

that experience has varied by project and by the element of Iraqi government involved in 

the decision making process. 

• A GRN official noted that transition of CERP projects to the GoI have been successful 

when local GoI ministries have been involved throughout the lifecycle of the project. 

Also, it was noted that when GoI engineers are involved in a project throughout 

9
execution, they are more aware of the quality of construction and more willing to accept 

the final product. The GRS has given the Iraqis the opportunity to observe how it 

transparently performs all aspects of contracting and competition to obtain the best value.

• Another GRN official noted that transition to the GoI has been difficult when the GoI 

ministries do not appreciate the contractor that was awarded the project. He noted that as 

a stated lessons learned, the GRN works to include the ministries in developing bidders’ 

lists so that GoI officials feel they are involved in the award process. Although the GoI 

may still dislike the contractor selected, involving the GoI ministries allows them to 

better understand how the processes works and tends to make them more accepting of the 

results. 

• A GRN official also noted that in some cases, the GoI ministries have tried to be too 

involved in the projects and have directed the contractors to do work outside of the 

contract scope. To avoid this situation, a good practice is to invite all parties to the preconstruction conference and ensure that everyone knows their roles and responsibilities. 

The GRN thus identifies, at the pre-construction conference, the representatives who are 

allowed to make contract modifications and the process that must be adhered to should 

contract changes be required. 

• Another GRS official recommended as a best practice, ensuring that the agency 

understands the local culture and the labor skills available in the project area to sustain 

them. Consequently, they noted that it is not advisable to build a complex system if the 

user does not have the training or parts available to sustain them 

• Another official noted the great benefits of providing Iraqis with vocational training in 

building maintenance and repair; mechanical systems and operations; and teaching the 

Iraqis about logistics trail associated with preventive maintenance and ordering process. 

Such training is essential to ensure continued sustainment of completed projects and to 

prevent rapid deterioration due to a lack of preventive maintenance techniques. 

• A GRN official indicated that it is essential to include, as staff members, sustainment 

consultants who can work with end users of the projects for a defined period of time. This 

official suggested that these consultants be assigned to provincial reconstruction teams 

with the sole mission of supplying training in operations and facilities maintenance. 

Collectively, these represent some important lessons learned which, if effectively made available 

to incoming CERP program officials, as unit rotations occur, could minimize the learning curve 

for new personnel and enhance the management of ongoing as well as new CERP projects. 

However, at the present time, MNC-I does not have a process for capturing and disseminating 

CERP program management lessons learned. 

10
Conclusions and Recommendations 

While the CERP program guidance emphasizes small-scale, urgent humanitarian relief and 

reconstruction projects, the program devotes a major portion of its funding to larger-scale, more 

expensive projects, many estimated to cost over $500,000 in value. Although SIGIR has 

completed a number of reviews of the CERP program in recent years, it continues to find 

management weaknesses related to maintaining project files; and, despite some improvements, 

continuing challenges in planning for the transition of completed projects to the Iraqi people and 

in fostering long-term sustainment of completed facilities. Long-term sustainment may be 

affected by the limited amount of emphasis given to the transition issue in program guidance. 

The importance of such guidance and emphasis is heightened by the number of large-scale, 

relatively costly projects being implemented under the CERP program. Also, CERP program 

officials have identified a number of important lessons learned that, if documented and made 

available to all project personnel as unit rotations occur, could help ease the learning curve for 

incoming personnel and promote improved management practices for continuing and new CERP 

projects. 

SIGIR recognizes the management challenges faced by CERP program managers. This is 

particularly the case in a situation where program officials are periodically replaced by less 

experienced personnel as unit rotations occur. This condition places a greater importance on 

clear and comprehensive program guidance to help achieve program management continuity, 

effectiveness and efficiency. SIGIR believes improved program transition guidance will help to 

resolve the longstanding management issues we have identified. 

Recommendations 

We recommend that the Commanding General, Multi-National Corps-Iraq, direct that these 

actions be taken: 

1. Reinforce the importance of documenting project files, especially for large-scale, projects 

that are considered high cost, technologically complex, and maintenance intensive 

activities. 

2. Include more specific guidance in the MAAWS to address both transition and 

sustainment of CERP projects above an established value particularly those projects that 

are considered high cost, technologically complex, and maintenance intensive activities 

as noted above. 

3. Develop an appropriate process for developing and disseminating lessons learned from 

the CERP program to assist future program officials as unit rotations occur to reduce 

learning curves and facilitate continuity in program management. 

11
Management Comments 

We received written comments on a draft of this report from MNC-I. The MNC-I Chief of Staff 

concurred with all recommendations and has identified corrective actions that have been initiated 

or planned. According to the comments, they have implemented a records 

recovery/reconstruction policy to remedy missing project files. MNC-I agreed that while lessons 

learned were captured and disseminated in various medium, a more formal process would be 

helpful. They agreed to explore a more formal option to include the Center for Army Lessons 

Learned (CALL). 

12
Appendix A—Scope and Methodology 

The Special Inspector General for Iraq Reconstruction (SIGIR) initiated this audit in June 2007, 

(Project No. 7019) as a broad examination projects in Iraq undertaken by the Commander’s 

Emergency Response Program (CERP). While we focused on high-cost projects, we also 

contrasted the magnitude of those projects with lower-cost projects. The objectives of this report 

were therefore to (1) contrast funding devoted to small-scale projects typically associated with 

the CERP program with funding devoted to more expensive, large-scale CERP projects; and (2) 

provide observations regarding the applicability of selected issues from prior SIGIR reviews, as 

well as lessons learned identified in this current review that can help in managing large CERP 

projects. 

In gathering much of the data for this review we relied on the results of a structured 

questionnaire to solicit information from MNC-I and the MSCs. We submitted a similar 

questionnaire to solicit information from the U.S. Corps of Engineers-Gulf Region Division 

Headquarters (GRD), and its three regional offices: Gulf Region-North (GRN); Baghdad, or 

Central (GRC); and South (GRS). Collectively, we refer to the three regional offices and the 

headquarters division as one under the GRD. We compared the responses received to our 

questionnaire to the findings identified in our prior reviews as a basis for assessing whether 

similar problems were continuing to be experienced. 

To supplement the questionnaire, we also solicited and reviewed available documentation related 

to CERP standard operation procedures, the MNC-Is MAAWS manual, and fragmentary orders 

governing the CERP program from CJTF-7, MNF-I, and MNC-I. We also requested and 

reviewed available documentation on sustainment and transition of completed CERP projects to 

the Government of Iraq. 

To identify program management control issues we consulted prior SIGIR reports on CERP 

programs and solicited information from current program managers regarding the continued 

applicability of those issues. We also built upon other recent SIGIR work in this area. To 

augment that, we drew upon the knowledge and experience of CERP program officials within 

MNC-I and subordinate MSCs to identify what they viewed as key lessons learned that could 

help future program officials manage CERP projects. 

Regarding the issues of transitioning completed CERP projects to the Iraqi government and 

providing for long-term maintenance and sustainment of transferred facilities, we inquired about 

the existence of specific MNC-I or local MSC guidance related to the transfer of projects to the 

GoI; how were large CERP projects transferred to the GoI; and to what extent has the GoI or 

local governments been willing to accept large CERP reconstruction projects. Regarding 

sustainment, we focused on whether the commanders considered sustainment costs, and at what 

point in the selection process this had occurred. For large CERP reconstruction projects, we 

questioned how much value was placed on sustainment, and the extent to which local 

governments or the GoI consulted with in terms of their ability to provide continued sustainment 

once the project was turned over to their control. Just as important, we asked of the MSCs 

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whether their experience indicated willingness on the part of the local governments and/or the 

GoI to assume the sustainment costs of large CERP projects. 

We conducted this audit from June 2007 through November 2007, in accordance with generally 

accepted government auditing standards. 

Use of Computer-Processed Data 

We utilized data from the Army accounting system, the Standard Financial System 

(STANFINS); and the Iraq Reconstruction Management System (IRMS) to reconcile project data 

with financial data for all the funds provided by CERP. We therefore considered the data 

sufficient for purposes of this review. 

Prior Coverage 

The Office of the Special Inspector General for Iraq Reconstruction (SIGIR) issued the following 

related audit reports, accessible on its website at http://www.sigir.mil: 

• Management of the Commander’s Emergency Response Program for Fiscal Year 2004

(SIGIR-05-014, October 13, 2005)

• Management of the Commander’s Emergency Response Program for Fiscal Year 2005

(SIGIR-05-025, January 23, 2006) 

• Management of Iraq Relief and Reconstruction Fund Program: The Evolution of the 

Iraq Reconstruction Management System (SIGIR-06-001, April 24, 2006) 

• Review of Data Entry and General Controls in the Collecting and Reporting of the Iraq 

Relief and Reconstruction Fund (SIGIR-06-003, April 28, 2006) 

• Management of the Iraqi Interim Government Fund (SIGIR-06-31, October 27, 2006) 

• Management of the Commander’s Emergency Response Program in Iraq for Fiscal Year

2006 (SIGIR-07-006, April 26, 2007)

U.S. Army Audit Agency 

The U.S. Army Audit Agency conducted a series of audits—including the following—on the 

funds allocated to the Commander’s Emergency Response Program and Quick Response Fund 

(QRF): 

• Commander’s Emergency Response Program and Quick Response Fund (Report A2005-0173-ALE, May 2, 2005) 

• Follow-Up of Commander’s Emergency Response Fund and Quick Response Fund

(Report A-2005-0332-ALE, September 30, 2005) 

• Follow-Up II of Commander’s Emergency Response Program and Quick Response Fund

(Report A-2006-0090 ALE, March 31, 2006) 

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U.S. Government Accountability Office 

We identified two U.S. Government Accountability Office audits that include parts of the 

Commander’s Emergency Response Program: 

• MILITARY OPERATIONS - The Department of Defense’s Use of Solatia and Condolence 

Payments in Iraq and Afghanistan (GAO Report 07-699, May 2007) 

• REBUILDING IRAQ - Status of Funding and Reconstruction Efforts (GAO Report 05-

876, July 2005) 

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Appendix B—CERP Related Public Laws

Since its inception, in 2003, a number of public laws related to CERP have been enacted. Most 

of these have either authorized the program or appropriated funding for it, and have consistently 

described the program as having been created “for the purpose of enabling military commanders 

in Iraq and Afghanistan to respond to urgent humanitarian relief and reconstruction requirements 

within their areas of responsibility by carrying out programs that will immediately assist the Iraqi 

and Afghan people.” Listed below are some of the laws that have addressed CERP. 

CERP Related Public Laws 

Fiscal 

Year 

Funds Date Public Law Name Remarks 

End of 

Obligation 

Period Date 

FY04 6-Nov-2003 

P.L. 108-106, 

Title I, 

Sec 1110 

Emergency Supplemental 

Appropriations Act for Defense and for 

the Reconstruction of Iraq and 

Afghanistan, 2004. 

Sets NTE at $180 million 

(Total CERP) 30-Sep-2004 

FY05 5-Aug-2004 

P.L. 108-287, 

Title IX, 

Sec. 9007 

Department of Defense Appropriations 

Act, 2005. 

Sets NTE at $300 million 

(Total CERP) 30-Sep-2005 

FY05 28-Oct2004 

P.L. 108-

375,Title XII, 

Subtitle A, 

Sec. 1201 

Ronald W. Reagan National Defense 

Authorization Act for Fiscal Year 2005. 

Authorizes NTE $300 

million for FY2005 N/A 

FY05 8-Dec-2004 

P.L. 108-447, Div 

J, Title I, 

Sec. 102 

Consolidated Appropriations Act, 2005 

Increased NTE by $200 

million to $500 million 

(Total CERP) 

30-Sep-2005 

FY05 11-May2005 

P.L. 109-13, Title 

I, 

Sec. 1006 

Emergency Supplemental 

Appropriations Act for Defense, the 

Global War on Terror, and Tsunami 

Relief, 2005 

Increased NTE by $354 

million to $854 million 

(Total CERP) 

30-Sep-2005 

FY06 30-Dec2005 

P.L. 109-148, 

Title IX, 

Sec. 9007 

Department of Defense, Emergency 

Supplemental Appropriations to Address 

Hurricanes in the Gulf of Mexico, and 

Pandemic Influenza Act, 2006. 

Sets NTE at $500 million 

(Total CERP) 30-Sep-2006 

FY06 6-Jan-2006 

P.L. 109-163, 

Title XII, Subtitle 

A, 

Sec. 1202 

National Defense Authorization Act for 

Fiscal Year 2006. 

Authorizes NTE $500 

million for BOTH FY2006 & 

FY2007 

N/A 

FY06 15-Jun2006 

P.L. 109-234, 

Title I, 

Chp. 2, 

Sec. 1207 

Emergency Supplemental 

Appropriations Act for Defense, the 

Global War on Terror, and Hurricane 

Recovery, 2006 

Additional NTE $423 

million added (Total CERP) 31-Dec-2007 

FY07 29-Sep2006 

P.L. 109-289, 

Title IX, 4 

Sec. 9006 

Department of Defense Appropriations 

Act, 2007 

Sets NTE at $500 million 

(Total CERP) 30-Sep-2007 

FY07 25-May2007 

P.L. 110-28, Title 

I, 

Chp. 3, 

Sec. 1307 

U.S. Troop Readiness, Veterans’ Care, 

Katrina Recovery, and Iraq 

Accountability Appropriations Act, 2007 

Additional NTE $454 

million added (Total CERP) 30-Sep-2007 

Source: SIGIR

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Appendix C—Acronyms 

BCT Brigade Combat Team 

CERP Commander’s Emergency Response Program 

DFI Development Fund for Iraq 

DoD Department of Defense 

GoI Government of Iraq 

GRC Gulf Region Central-Baghdad 

GRD U.S. Army Corps of Engineers Gulf Region Division 

GRN Gulf Region North 

GRS Gulf Region South 

IRMO Iraq Reconstruction Management Office 

JCC-I/A Joint Contracting Command-Iraq/Afghanistan 

MAAWS Money as a Weapon System 

MNC-I Multi-National Corps-Iraq 

MNF-I Multi-National Force-Iraq 

MNSTC-I Multi-National Security Transition Command-Iraq 

MSC Major Subordinate Command 

SIGIR Special Inspector General for Iraq Reconstruction 

STANFINS Standard Financial System 

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Appendix D—Audit Team Members 

This report was prepared and the review was conducted under the direction of David Warren 

Assistant Inspector General for Audit, Office of the Special Inspector General for Iraq 

Reconstruction. 

The staff members who conducted the audit and contributed to the report include: 

Michael A. Bianco 

Ronald J. Bonfilio 

Frank W. Gulla 

Barry W. Holman 

Walt R. Keays 

18
Management Comments 

Multi-National Corps - Iraq 

19
20
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SIGIR’s Mission Regarding the U.S. reconstruction plans, programs, 

and operations in Iraq, the Special Inspector General 

for Iraq Reconstruction provides independent and 

objective: 

• oversight and review through comprehensive 

audits, inspections, and investigations 

• advice and recommendations on policies to 

promote economy, efficiency, and effectiveness 

• deterrence of malfeasance through the prevention 

and detection of fraud, waste, and abuse 

• information and analysis to the Secretary of 

State, the Secretary of Defense, the Congress, 

and the American people through Quarterly 

Reports 

Obtaining Copies of SIGIR 

Reports and Testimonies 

To obtain copies of SIGIR documents at no cost, go 

to SIGIR’s Web site (www.sigir.mil). 

To Report Fraud, Waste, and 

Abuse in Iraq Relief and 

Reconstruction Programs 

Help prevent fraud, waste, and abuse by reporting 

suspicious or illegal activities to the SIGIR Hotline: 

• Web: www.sigir.mil/submit_fraud.html 

• Phone: 703-602-4063 

• Toll Free: 866-301-2003 

Congressional Affairs Hillel Weinberg 

Assistant Inspector General for Congressional 

 Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1059 

Email: hillel.weinberg@sigir.mil 

Public Affairs Kristine Belisle 

Director, Public Affairs 

Mail: Office of the Special Inspector General 

 for Iraq Reconstruction 

 400 Army Navy Drive 

 Arlington, VA 22202-4704 

Phone: 703-428-1217 

Fax: 703-428-0818 

Email: Kristine.Belisle@sigir.mil 

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