GAO

United States General Accounting Office

Report to the Ranking Minority Member, 

Subcommittee on Agriculture, Rural 

Development and Related Agencies, 

Committee on Appropriations, House of 

Representatives

March 2000 FOREIGN 

ASSISTANCE

Donation of U.S. 

Planting Seed to 

Russia in 1999 Had 

Weaknesses

GAO/NSIAD-00-91

Page 1 GAO/NSIAD-00-91 Donation of Seed to Russia

Contents

Letter 3

Appendix Appendix I: Distribution of U.S. Planting Seed in Russia 24

Tables Table 1: Price of Seed in United States and Russia and Deposits of 

Seed Proceeds 16

Table 2: Disbursement of Seed Proceeds to Credit Fund and Seed

Institutes as of December 1999 19

Table 3: Distribution of Corn Seed by Region According to the Food

Aid Agreement, the Workplan, and the Travel Matrix 25

Table 4: Distribution of Pea Seed by Region According to the Food

Aid Agreement, the Workplan, and the Travel Matrix 26

Table 5: Distribution of Carrot, Beet, and Onion Seed by Region 

According to the Food Aid Agreement and Russian Distributing 

Agent 27

Abbreviations

USDA U.S. Department of Agriculture
Page 2 GAO/NSIAD-00-91 Donation of Seed to Russia
Page 3 GAO/NSIAD-00-91 Donation of Seed to Russia

United States General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-284700 Letr

March 9, 2000

The Honorable Marcy Kaptur

Ranking Minority Member 

Subcommittee on Agriculture, Rural Development

 and Related Agencies

Committee on Appropriations

House of Representatives

Dear Madam Kaptur:

In 1999, the United States donated 15,000 metric tons of planting seed 

(mainly corn and pea seed) to Russia under the Food for Progress 

agreement.1

 The seed donation (with commodity and transportation costs 

of $21.7 million) was part of a $1.2 billion program of concessional sales 

and donations of agricultural commodities to Russia. The seed donation 

represented 2 percent of the overall program cost and was the first time 

that the U.S. Department of Agriculture had provided planting seed in a 

food aid agreement to any country. Under the Food for Progress program 

agreement, the donated seeds were to be sold in Russia at market prices, 

and the proceeds were to be deposited in a special account and then 

disbursed to selected Russian seed institutes and a rural credit cooperative. 

The inclusion of planting seed in the agreement was supported by the U.S. 

Department of Agriculture’s Foreign Agricultural Service and others as a 

means to aid Russian farmers faced with seed shortages, improve Russian 

agricultural productivity, and promote market development for U.S. 

planting seed in Russia. The program was also viewed as an opportunity for 

the U.S. Department of Agriculture to test the viability of including planting 

seed in food aid programs.

1

 The Food for Progress Act, 7 U.S.C. 1736o, authorizes the U.S. Department of Agriculture’s 

Commodity Credit Corporation to finance the sale and exportation of agricultural 

commodities on credit terms, or on a grant basis, to support developing countries and 

countries that are emerging democracies and have made commitments to introduce or 

expand free enterprise elements in their agricultural economies. The act was amended in 

1992 to include the independent states of the former Soviet Union as eligible countries 

under the program.
B-284700

Page 4 GAO/NSIAD-00-91 Donation of Seed to Russia

As part of your request to review the overall food aid agreement, you asked 

a series of questions regarding the design and implementation of the seed 

donation program. To address these questions, we examined (1) how the 

seed was procured in the United States, (2) how seeds were distributed and 

monitored in Russia, and (3) what the process was for selling the seed and 

distributing the proceeds to agricultural development institutions.

Results in Brief Under time pressure to buy and ship the seed to Russia to meet planting 

dates, U.S. Department of Agriculture officials procured the seed through a 

noncompetitive, sole source contract for $21.7 million. This decision forced 

the United States to donate the seed to Russia rather than finance its sale 

with a concessional loan. Procurement officials in the U.S. Department of 

Agriculture did not have time to develop expertise on the technical aspects 

of international seed shipments nor did they have access to independent 

sources of price information before entering into negotiations with the sole 

source contractor. 

Seed distribution in Russia did not follow the original plans, and reasons 

for changes were not fully documented. Some deliveries of corn and pea 

seed were verified by U.S. government monitors, but the regional 

distribution of the other vegetable seeds was not confirmed, and there is 

conflicting information about what happened to these seeds. Also, some 

seed arrived in the regions too late to be planted. Monitoring reports show 

that two common complaints from Russian producers were a lack of 

technical information on seed types and delivery of seed that was not 

appropriate for local growing conditions.

The sale of the donated seed to regional wholesalers and government 

agencies in Russia raised about $2.6 million (about one-eighth of what was 

paid to the sole source contractor that procured and shipped the seed to 

Russian ports). According to Department of Agriculture officials, they used 

a methodology for determining fair, wholesale market prices for U.S. food 

aid commodities in Russia, but we found scant documentation of how this 

methodology was used to set prices for the donated U.S. planting seed. 

Also, the prices for the donated U.S. seed were substantially lower than 

prices for corn and vegetable seed reported by some private companies in 

Russia. The distribution of the proceeds from the sale of seeds generally 

followed the original plan. While there were some delays in the payment for 

seeds, all the expected proceeds have been deposited into a special 

account in Russia, and most of the funds were distributed to four seed 

research institutions and a rural credit cooperative fund. 
B-284700

Page 5 GAO/NSIAD-00-91 Donation of Seed to Russia

This report contains recommendations to the Secretary of Agriculture for 

improving future seed donations through (1) increased communication and 

planning by the U.S. Department of Agriculture, (2) changes in the 

implementation and monitoring of seed distribution to regions in Russia, 

(3) better documentation of pricing decisions, and (4) an evaluation of U.S. 

seed performance in Russia.

Background In 1999, the United States provided Russia, through a combination of 

donations and concessional sales, with over 3 million tons of grains, meats, 

oilseeds, and other U.S. farm commodities with a total cost (including 

freight) of over $1.2 billion. The U.S. food assistance package was 

designed, in part, to respond to one of the worst Russian grain harvests in 

over 40 years combined with the effects of a severe financial crisis in 

August 1998. At the same time, U.S. Department of Agriculture (USDA) 

officials pointed out that government support of the export of large 

amounts of agricultural commodities was a means of helping U.S. farmers 

in a period of surplus and low prices. 

U.S. food aid to Russia was provided through three programs: Public Law 

480 Title I, Section 416(b), and Food for Progress.2

 Agreements under these 

programs are negotiated and administered by USDA’s Foreign Agricultural 

Service. Another agency of USDA, the Farm Service Agency, is responsible 

for supplying commodities for the Section 416(b) and Food for Progress 

programs. The Title I program regulations require that purchases of 

commodities for the program be made through a publicly advertised, 

competitive bid process,3

 while Food for Progress regulations permit, 

under certain circumstances, procurement of commodities through a sole 

source contract.4

2

 The Title I program makes U.S. agricultural commodities available through long-term 

credit at low interest rates. Section 416(b) provides for overseas donations of surplus 

commodities owned by USDA’s Commodity Credit Corporation. The Food for Progress 

program provides agricultural commodities on credit terms or on a grant basis to countries 

that are emerging democracies and have made commitments to introduce or expand free 

enterprise elements into their agricultural economies.

3

 7 U.S.C. 1736a(a)(2), 7 C.F.R. 17.5.

4

 See 41 U.S.C. 253(c), 48 C.F.R. 6.3.
B-284700

Page 6 GAO/NSIAD-00-91 Donation of Seed to Russia

The seed donation to Russia was part of a Food for Progress agreement 

that included donations of pork and dried milk powder. The seed program 

was significant in that it was the first time that planting seed was included 

in any U.S. food aid agreement. Unlike the bulk commodities that generally 

make up food aid programs, planting seed is not a homogeneous 

commodity that can be used in any country. To perform well, planting seed 

must be of high quality in terms of seed purity and adequate germination 

rates, but most importantly, the seed must be appropriate for the growing 

conditions where it is planted. Corn seed in particular varies by the Food 

and Agriculture Organization’s maturity group,5

 which determines when 

seed should be planted and when it can be harvested for grain. Corn that 

does not fully mature into grain can be harvested to be processed into 

silage and used as animal feed.6

Under the Food for Progress program agreement, the donated seeds were 

to be sold in Russia at prices agreed upon by the two governments, taking 

into account factors such as prevailing market prices in Russia. The 

proceeds from the sale of the seed were to be deposited in a special 

account administered by the Russian Ministry of Agriculture. The 

agreement sets out the disbursement of funds to special projects—

50 percent to fund a rural credit cooperative and 50 percent distributed 

among five Russian seed research institutes. All proceeds from the sale of 

other food aid commodities were to be used to support the Russian pension 

fund.

The Food for Progress agreement also required that the government of 

Russia develop a “workplan” indicating, among other things, the projected 

distribution, estimated time lines, projected point of sale, and buyers of the 

commodities, including seeds. The agreement includes provisions for 

monitoring the arrival and distribution of seeds and documentation of the 

deposit and disbursement of sales proceeds. A bilateral working group7

5

 “The maturity group” is the Food and Agriculture Organization’s internationally recognized 

classification of corn seed by the length of the growing season needed for corn to produce 

grain.

6

 The feeding value of silage from immature corn depends partly on the degree of maturity at 

harvest. Also, corn hybrids that have high grain yields do not necessarily produce the 

highest quality silage. 

7

 The working group consisted of four U.S. officials, including the U.S. Minister Counselor 

for Agricultural Affairs, and representatives from various Russian ministries and 

representatives of the distributing agents.
B-284700

Page 7 GAO/NSIAD-00-91 Donation of Seed to Russia

was established to meet on a regular basis to coordinate, resolve issues, 

and recommend changes to the workplans and establish the selling prices 

for the food aid commodities. 

Procurement of 

Planting Seed in the 

United States

The availability of planting seed in the United States influenced the 

amounts and varieties of seed sent to Russia. The seed was procured in the 

United States through a noncompetitive, sole source contract. When 

entering into negotiations with the sole source contractor, procurement 

officials did not have independent sources of price information or technical 

expertise. USDA paid the contractor a price that included freight and other 

costs; therefore, procurement officials can only estimate the average price 

paid for the seed.

Types and Quantities of 

Seed Donated to Russia

In a letter dated November 4, 1998, the Russian government requested a 

large donation of seed—almost 100,000 tons of corn, sunflower, and other 

seeds.8

 Also, due to the short Russian growing season, Russian officials 

requested that corn seeds be early maturing varieties. Foreign Agricultural 

Service officials, in consultation with the American Seed Trade 

Association, determined that this request was too large for the United 

States to supply. Also, estimates of the availability of early maturing corn 

seed varieties were much smaller than the amount of corn seed requested 

by Russia. After discussions, the two governments reached an 

understanding in December 1998 on a 15,000-ton package; the request for 

corn and vegetable seed closely adhered to the trade association’s 

estimates of planting seed stocks in the United States—14,000 tons of corn 

seed and 1,000 tons of vegetable seed. Due to the large proportion of late 

maturing corn seed varieties included in the donation, the expectation was 

that the corn seed would not produce grain but rather be grown for silage. 

8

 The request listed some seeds by variety and, in the case of corn seed, maturity and 

company name of hybrid. The request required that all imported seed be officially 

registered. 
B-284700

Page 8 GAO/NSIAD-00-91 Donation of Seed to Russia

Given the need to import seed immediately, Russia effectively waived the 

requirement that all seed varieties imported be registered (a process that 

can take up to 3 years). To overcome a Russian phytosanitary quarantine, 

the United States agreed to procure corn seed that was from the 1997 or 

earlier crop cycle.9

 These agreements facilitated the importation of the 

donated seed but did not apply to commercial imports of U.S. corn seed, 

which were and still are subject to quarantine and registration 

requirements. 

The donation of vegetable seed (pea, carrot, beet, and onion seed) totaled 

1,000 tons. The quantity of pea seed supplied was 960 tons. USDA also 

planned to send 10 tons of onion, 10 tons of beet, and 20 tons of carrot 

seed. However, the seed brokerage contracted to procure the seed 

discovered that it could supply just over 2 tons of onion seed. USDA 

documents show that the U.S. agricultural counselor in Moscow 

communicated with Russian officials and they agreed that the shortfall 

should be made up with additional carrot seed.

Time Frame Limited 

Options for Procurement

In December 1998, while the United States was negotiating the types and 

amounts of seed to be sent to Russia, the Foreign Agricultural Service 

received an unsolicited proposal from an international seed brokerage that 

outlined various cost scenarios for the exportation of seed to Russia. The 

seed brokerage, based in the United States, had commercial ties to a 

Russian seed importer, and through this contact the brokerage became 

aware of the Russian request for seed and of the need to import the seed 

quickly. According to Foreign Agricultural Service officials, they consulted 

with seed industry officials to identify other potential suppliers but found 

no alternatives.

9

 Phytosanitary measures pertain to protecting plants from pests and diseases. Russia 

quarantines corn seed of U.S. origin to prevent the spread of Stewart’s Wilt, a bacterial 

disease affecting corn in the United States. While transmission of Stewart’s Wilt via seed is 

extremely rare, the Russian authorities believed that this risk would be further reduced by 

using seed that had been stored for at least 1 year.
B-284700

Page 9 GAO/NSIAD-00-91 Donation of Seed to Russia

By the end of December 1998, time had already become a limiting factor in 

the seed procurement and shipment process. Ideally, according to seed 

industry officials, the seed should have been procured and sent to Russia 

by the beginning of 1999 to permit timely distribution to producers.10 USDA 

procurement officials stated that they generally need at least 4 to 6 weeks 

to prepare and carry out a competitive bid process to procure and transport 

a commodity to the point of export. Also, since USDA had never procured 

seeds for a food aid program, officials stated that they would have needed 

additional time in order to develop a set of procedures taking into account 

the special technical requirements for international seed shipments. Given 

these circumstances, USDA decided to procure the seed through a sole 

source contract with the seed brokerage. 

Procurement Decision 

Necessitated Program 

Change

Initially the seed program was planned as a sale of seed to Russia under the 

Title I program. However, since the Title I program requires that the 

commodity be procured through a competitive bidding process by U.S. 

suppliers, the decision to procure the seed through a sole source contract 

meant that the seed had to be provided under the Food for Progress 

program. Thus, instead of selling the seed to Russia, the United States 

donated the seed. Procurement officials informed us that this was the first 

time that a sole source contract had been used to procure agricultural 

commodities under the Food for Progress program. 

USDA Unprepared for 

Negotiations With Sole 

Source Contractor

Procurement officials at the Farm Service Agency were not well prepared 

to negotiate with the sole source contractor. They had no independent 

sources of prices and were unaware how technical specifications could 

impact the value of seed.11 Procurement officials generally carry out a price 

discovery process and market analysis of available supplies to prepare 

solicitations for bids to procure commodities through a competitive 

process. However, in the case of planting seed for Russia in 1999, officials 

say they only had time to call one agricultural supply dealer and inquire 

10 According to Foreign Agricultural Service officials, farmers in Russia need to have their 

pea seed planted no later than March and their corn seed planted no later than April. 

11 For example, procurement officials were unaware during negotiations that Russia had 

requested seed from 1997 and earlier and that the price for corn seed generally declines in 

price the older the production year. Also, they were unaware that prices for vegetable seed 

vary substantially depending on whether the seed is a hybrid or an open-pollinating variety.
B-284700

Page 10 GAO/NSIAD-00-91 Donation of Seed to Russia

about wholesale corn seed prices; they did not gather information on the 

prices of vegetable seed. 

The contract with the seed brokerage established a maximum price of 

$1,625 per metric ton of corn seed,12 the same price suggested in its 

unsolicited proposal. Procurement officials informed us that they accepted 

the brokerage’s price for corn seed because they had had little time to 

gather independent price information. In the case of vegetable seed, the 

contract did not specify a maximum price, but in the justification for sole 

source procurement, the Farm Service Agency estimated the expected cost 

of vegetable seed to be about $5,000 per ton. 

USDA Gained Limited 

Experience From the 1999 

Seed Donation

In justifying the use of sole source procurement, USDA officials 

emphasized that the seed donation was to be used as a test to determine 

the effectiveness of providing seed under foreign aid programs in the future 

and to develop expertise to conduct future procurement.13 Procurement 

officials worked with the contractor to learn about the special technical 

requirements of international seed shipments and developed procedures to 

procure seeds through competitive bids in the future. 

USDA failed to use the procurement process to learn more about the prices 

of corn and vegetable seed. The sole source contract did not require that 

the contractor provide a breakout of the price charged to USDA into the 

cost of seed and other costs. USDA does not know the price at which the 

contractor procured the seed from U.S. suppliers. 

12 The price included germination testing, transportation to port in Russia, and an $80 

contracting fee.

13 USDA officials have stressed that the sole source procurement of planting seed was due to 

special circumstances and is unlikely to be repeated. USDA has implemented a competitive 

bid process for the procurement of seed for export to Russia in the year 2000. 
B-284700

Page 11 GAO/NSIAD-00-91 Donation of Seed to Russia

While procurement officers from USDA’s Farm Service Agency observed 

the solicitation and reception of bids for corn seed (but not for vegetable 

seed) by the sole source contractor, they did not take advantage of the 

experience to gather detailed information on prices for the corn seed.14

Procurement officials did not observe if prices varied depending on 

maturity, year of production, or size of bid. This information could have 

been valuable for estimating and planning for future procurement of seed. 

The contractor did not share price information with us, citing the 

confidentiality of proprietary information.

Distribution and 

Monitoring of Seed in 

Russia 

The distribution of U.S. planting seed did not follow the original plan; 

distributing agents changed, regions received different amounts of seed 

than scheduled, and some seed arrived too late to be planted. While 

changes were permitted under the program, documentation for the reasons 

for changes is not complete. Some deliveries of corn and pea seed were 

verified by U.S. government monitors, but they did not observe the regional 

distribution of any of the carrot, onion, and beet seed. There is conflicting 

information about the status of these vegetable seeds. Monitors reported 

that regional recipients complained about the large number of corn 

varieties included in deliveries and the absence of detailed labeling and 

technical guidelines for the seed. There was no formal evaluation of the 

performance of the U.S. planting seed, as required by the Food for Progress 

agreement.

Seed Distributing Agents 

Changed

The criteria used to choose distributing agents in Russia were unclear. 

Initially, the Russian government selected a seed import firm to receive the 

seed, transport it to regions, and sell it to regional recipients. No explicit 

reason was given for the choice of this distributor, but according to the 

Foreign Agricultural Service, the company was an experienced seed 

importer in Russia. Also, representatives of the American Seed Trade 

Association said that the firm had the technical knowledge and distribution 

infrastructure to successfully distribute seed.

14 Because seeds are a commercially available product, the Truth in Negotiations Act does 

not require suppliers to share price information with the government (41 U.S.C. 254b 

(b)(1)(B)). However, USDA could have required such information as a condition of its 

contract with the broker. 18 U.S.C. 1905 prohibits federal employees from disclosing such 

confidential proprietary information, except as authorized by law.
B-284700

Page 12 GAO/NSIAD-00-91 Donation of Seed to Russia

Just prior to the arrival of the first seed shipment, the Russian government 

changed agents, and all of the corn and pea seed was distributed and sold 

by the same former state agency (Roskhleboproduct) that distributed the 

food and feed grain commodities sent by the United States. The carrot, 

beet, and onion seed was sold to a state agency (Rossortsemovosch) that 

was then made responsible for distributing it to the regions.15 Foreign 

Agricultural Service officials noted that the nomination of the agent and 

internal distribution was the responsibility of the government of Russia, 

not of the U.S. government. According to these officials, the original agent 

did not want to comply with certain requirements to participate in the 

program, and the agent voluntarily withdrew from participating.

The Food for Progress agreement stated that in order to promote the 

participation of the private sector in the seed program, an organization of 

private farmers would receive 3,000 tons of corn seed to sell to members. 

According to Foreign Agricultural Service officials, the farmer cooperative 

voluntarily withdrew from the seed program before the seed arrived in 

Russia because it did not have adequate transportation to distribute the 

seed.

Corn and Pea Seed 

Distribution to Regions 

Differed From Plans

According to the Food for Progress agreement, the U.S. planting seed was 

to be sent to regions identified as needy, which were listed in an attachment 

to the agreement. The Russian distributing agent submitted a “workplan,” 

approved by the bilateral working group, which contained some changes in 

the original delivery locations and seed amounts. Foreign Agricultural 

Service officials then tracked each shipment’s arrival to port, planned 

delivery to regions, regional buyers, and which arrivals and deliveries were 

checked by a Foreign Agricultural Service monitor. (See app. I for a 

comparison of distribution according to the original distribution plan, the 

workplan, and delivery documentation.)

15 The distributing agents’ documents show that all of the seed was sold to public food 

processors, state agencies, and private seed companies. These entities resold the seed or 

used it for production, but there is no documentation of the final recipients of the seed. 
B-284700

Page 13 GAO/NSIAD-00-91 Donation of Seed to Russia

For corn seed, deliveries to the regions differed from both the original 

distribution plan and the workplan. We could not find documentation in the 

bilateral working group minutes showing discussion and approval of most 

of these changes. Foreign Agricultural Service monitoring reports16 confirm 

the delivery of 72 percent of the corn seed in the regions. One delivery to 

Tartarstan arrived too late for planting and, according to Foreign 

Agricultural Service officials in Moscow, 700 metric tons are being stored in 

the region for planting in the spring of the year 2000. 

Pea seed deliveries were also different from plans, but discussion and 

approval of these changes are documented in official correspondence from 

the Russian distributing agent to U.S. embassy officials in Moscow. 

Vegetable Seed Deliveries 

Not Confirmed

Over 40 tons of carrot, beet, and onion seed were delivered to Moscow and 

sold to a state agency, Rossortsemovosch, that, according to the workplan, 

would sell the seed to regions with the approval of Russia’s Ministry of 

Agriculture. The bilateral working group minutes contained no record of 

further discussions concerning the distribution plan for these seeds nor did 

the Foreign Agricultural Service monitor the arrival or verify the 

distribution or sale of this seed. 

The importing agent, Roskhleboproduct, informed a representative of the 

seed brokerage that procured and shipped the seed that the vegetable seed 

had arrived too late for planting. However, Rossortsemovosch submitted a 

report that shows only a small amount of seed remains unplanted and 

stored in the regions (tables 3 to 5 in app. I show the reported distribution 

of this seed). The information in Rossortsemovosch’s report on the delivery 

and status of the seed has not been verified.

Performance of U.S. 

Planting Seed in Russia

The Food for Progress agreement included a provision that USDA and 

Russian officials carry out an assessment of the performance of the 

planting seed, including germination and yields. A formal report has not 

been produced, and there has been no attempt to systematically gather 

16 Foreign Agricultural Service monitors tracked commodity shipments and produced 

Compliance Review Reports as a result of selected monitoring visits to Russian ports or 

regions (oblasts). When they conducted monitoring visits in the regions, they were 

supposed to verify the recipient, the kind and amounts of commodities received, and the 

commodity selling price and buyer. Monitors did not necessarily see the commodity, but 

verified distribution data through examination of shipping documents and receipts.
B-284700

Page 14 GAO/NSIAD-00-91 Donation of Seed to Russia

information on yields or other performance measures. However, all seed 

was tested for germination rates prior to shipment. Only seed meeting 

international standards was sent to Russia. In addition, USDA partially 

funded travel expenses of representatives of the American Seed Trade 

Association and the U.S. contractor that visited Russian pea farms, 

canneries, and a few farms producing silage using U.S. corn seed. The trip 

reports submitted to USDA reported generally favorable results. We found 

no reports on the performance of the vegetable seed. 

Foreign Agricultural Service monitors in Russia reported widespread 

complaints about the delivery of too many corn seed varieties and the 

absence of labels giving technical guidance for planting or cultivation. For 

example, one regional buyer in Omsk had received 463 metric tons of corn 

seed with 25 to 30 different hybrids. None of the bags contained written 

technical specifications of the corn seed or explanations of the seed 

treatment. 

Several recipients visited by representatives from the U.S. seed industry 

complained about the inclusion of late maturing corn hybrids that are 

inappropriate for growing conditions in their region. Also, producers 

requested that subsequent programs include other types of seeds. 

USDA sent a team to Russia in September of 1999 to assess Russian food 

needs for the coming year. No assessment was made of the need for seed, 

but USDA did report that the Russian Ministry of Agriculture was 

estimating a 1-million ton deficit of planting seed for the year 2000. We 

could not find estimates of the regions where seed deficits are highest or 

the types of seed in critical shortage.
B-284700

Page 15 GAO/NSIAD-00-91 Donation of Seed to Russia

Sale of U.S. Seeds in 

Russia and Distribution 

of Proceeds

The sale of the donated seed to regional wholesalers and government 

agencies in Russia raised about $2.6 million (about one-eighth of what was 

paid to the sole source contractor that procured and shipped the seed to 

Russian ports). The Food for Progress agreement required the bilateral 

working group to establish prices for U.S. commodities shipped to Russia, 

including seeds.17 However, we found scant documentation of the process 

used to determine the price of U.S. seed in Russia. While USDA officials 

said that the low price at which U.S. planting seed was sold was due to 

special factors in Russia, we found that prices charged for the donated U.S. 

seed were substantially lower than prices reported for corn and vegetable 

seed by some private companies in Russia. By January 2000, all regions had 

paid for the seed they received. However, some payments were made with 

substantial delays. Similarly, disbursements of the proceeds from the sale 

of seeds to a rural credit cooperative and five seed institutes were also 

delayed. About 80 percent of the funds have been disbursed.

Prices Paid for Donated U.S. 

Planting Seed in Russia

The prices at which the U.S. planting seed were sold varied between 

one-ninth and one-half of the per ton cost of procuring and shipping the 

seed to Russia (see table 1 for a comparison of procurement and shipping 

costs in the United States versus the selling price in Russia). Foreign 

Agricultural Service officials established a methodology for determining 

prices of U.S. food aid commodities that consisted of (1) an initial proposal 

by Russian authorities,18 (2) a check by U.S. officials of price information 

available from other sources, and (3) a discussion and a final determination 

of the prices approved by the bilateral working group. However, scant 

documentation can be found for the use of this methodology for setting the 

price of corn, pea, and vegetable seed.

17 The agreement specified that factors to be considered in the price determination were to 

include world price levels, prevailing market prices in the regions where the seeds were to 

be sold, and commodity quality specifications. The price estimates made by the working 

group were to be finalized only after approval by the Minister-Counselor for Agricultural 

Affairs at the U.S. embassy in Moscow.

18 According to a senior Russian official, the goal in establishing a price was to identify a 

“golden middle”—a price low enough so that the U.S. commodities would be sold quickly, 

but high enough so that it would not undercut domestic prices and hurt domestic producers.
B-284700

Page 16 GAO/NSIAD-00-91 Donation of Seed to Russia

Table 1: Price of Seed in United States and Russia and Deposits of Seed Proceeds

a

 U.S. price includes various costs, including transportation to St. Petersburg, Russia.

b

 Exchange rate of 25 rubles per U.S. dollar.

 Source: USDA’s Foreign Agricultural Service. 

In February 1999, the distributing agent submitted a workplan for seed, 

including suggested prices for the U.S. planting seed. However, some of the 

prices actually charged to regional buyers for the various types of seed 

differ substantially from those suggested prices. In the minutes of the 

bilateral working group, there are references to U.S. counterproposals for 

seed prices, but no supporting documentation has been provided by the 

Foreign Agricultural Service. Other documents indicate that U.S. officials 

tried to raise the price of pea seed 33 percent, from $240 per ton to $320 per 

ton, but the distributor said that the proposed change came too late. There 

was no documentation of why U.S. officials wanted to change the price. 

Accounting documents show that $240 per ton of pea seed was deposited in 

the special account. 

Price of Donated U.S. Seed 

Substantially Lower Than 

Commercial Prices

It is difficult to establish a market price for U.S. corn seed in Russia, since 

commercial imports from the United States are prohibited due to 

quarantine rules. However, we found that private seed firms reported 

substantially higher sale prices for corn seed, both Russian and imported 

seed from Europe. The multinational firms that import corn seed into 

Russia reported prices for western European seed between $1,300 and 

$1,500 per metric ton, including taxes. These same firms said that imported 

corn seed from neighboring countries such as Hungary and Yugoslavia 

costs approximately $500 to $600 per metric ton. They also estimated that 

domestic Russian corn seed, generally of lower quality, costs 

approximately $300 to $400 per ton after taxes and other fees. 

Seed type

U.S. procurement

costs (dollars per

metric ton)a

Sale price

In Russia (dollars

per metric ton)b

Price ratio

U.S.: Russia

Total procurement

Cost (dollars in

thousands)

Total deposit to special

account (dollars in

thousands)b

Corn $1,442 $160 9:1 $20,218 $2, 243

Pea 1,023 240 5:1 982 230

Carrot 14,214 2,800 5:1 392 78

Beet 5,825 3,200 2:1 58 32

Onion 21,800 4,000 5:1 52 10

Total $21,702 $2,593
B-284700

Page 17 GAO/NSIAD-00-91 Donation of Seed to Russia

The donated U.S. corn seed was sold at the ruble equivalent of $160 per 

metric ton to regional recipients. USDA monitors reported that after 

including taxes and distribution costs, the corn seed price paid by Russian 

agricultural producers for the U.S. seed was about $220 per metric ton. 

Thus, the sale price for U.S. corn seed is below the price range for corn 

seed reported to us by private firms. 

In addition, a representative from a Russian association of private 

vegetable and flower seed producers said that the selling prices of U.S. 

vegetable seed were substantially lower than prices for similar seed in 

Russia.

U.S. Officials Said That 

Market Conditions Dictated 

Low Selling Prices

USDA officials who participated in the bilateral working group said that 

market conditions justified the low selling price of U.S. corn and vegetable 

seeds. According to these officials, Russian farmers had no access to credit 

and thus did not have cash available to buy expensive production inputs 

like imported seed and fertilizer.

The contractor that procured the seed pointed out that additional factors 

affected the price of corn seed in Russia. Although the U.S. corn seed was 

of extremely high quality and similar to seed imported from Europe in 

terms of germination rates and technological investment, the U.S. seed was 

not destined for grain production. Because most of the U.S. corn seed was 

not appropriate for growing grain in Russia’s colder and drier conditions, it 

was used to produce silage, a product of lower value than grain. This 

lowered the value of U.S. seed in Russia. In addition, Foreign Agricultural 

Service officials said that U.S. corn seed was sent to augment low Russian 

domestic stocks, not to compete with imported seed and thus was priced 

closer to the price of Russian corn seed.

Multinational firms selling corn seed in Russia confirmed that the sale of 

U.S.-donated corn seed did not adversely affect their sales, in part because 

sales of high-quality corn seed from Western Europe had already dwindled 

to near zero due to the economic crisis in Russia. However, a 

representative of the Association of Russian Independent Seed Companies 

said that the sale of cheap vegetable seed adversely affected Russian 

vegetable seed firms because the U.S. seed was cheaper and nearly 

identical to seed produced in Russia.
B-284700

Page 18 GAO/NSIAD-00-91 Donation of Seed to Russia

Deposits to the Special 

Account Delayed

The regional recipients that purchased the seed from the distributing agent 

were required to make full payment no later than 120 days after delivery to 

port in Russia, which meant that the first deposits should have been made 

by June 14 and the last completed by July 31.19 However, by August 11, 

1999, only $1 million of the expected $2.6 million had been transferred to 

the special account. According to documents, the Russian Ministry of 

Agriculture suspended other food aid shipments and federal financing to 

two regions that had not paid in full for seed by the end of September 1999. 

In December 1999, one region still owed $212,016 for corn seed. Payments 

for the U.S. seed by all regions were completed by January 2000.

Disbursements of Funds to 

Seed Institutes and Rural 

Credit Fund Also Delayed

The disbursements of funds to seed institutes and the rural credit fund 

were also delayed. The first disbursements of proceeds from the sale of 

seeds took place in July 1999, but as of October 1999, only 40 percent of the 

expected funds had been disbursed. By December 8, 78 percent of the 

funds had been disbursed. 

By the end of 1999, three of the four regional seed institutes had received 

funds (see table 2 for a breakdown of disbursements). According to the 

U.S. Agricultural Counselor in Moscow, disbursements to the seed 

institutes, including the Rice Seed Institute, will be completed pending final 

approval from Washington, but no date for disbursement has been set.

19 U.S. seed arrived in port beginning in March and ending in April.
B-284700

Page 19 GAO/NSIAD-00-91 Donation of Seed to Russia

Table 2: Disbursement of Seed Proceeds to Credit Fund and Seed Institutes as of 

December 1999

a

Totals may not add up due to rounding.

Source: USDA’s Foreign Agricultural Service.

Documents show that three of the seed institutes planned to use the funds 

to pay for tractors, machinery parts, infrastructure repair, and 

modernization. When we interviewed officials from the Vavilov Institute 

and Williams Feed Institute, both of which are seed breeding and research 

centers, they said that the money would be used at the institutes for 

purchasing farm equipment. The Rural Credit Cooperative Development 

Fund has used the funds to extend loans to private farmer cooperatives 

through a program called the Russian-American Lending Program.

Conclusions Officials in the Farm Service Agency were not well prepared to enter into 

negotiations to procure seed. As a result, there is little assurance that the 

price paid was the lowest possible. Whether buying through a sole source 

contract or a competitive bidding process, procurement officials must 

develop expertise on the technical aspects of supplying seed and have 

access to independent sources of available supply and price information 

for the type of seed to be purchased.

USDA did not provide Russian farmers with adequate and timely technical 

information about the donated U.S. seed, reducing potential performance 

of the seed. Also, improper matching of seed type to local growing 

conditions may have diminished the contribution of the program to Russian 

agricultural productivity. Although the bilateral working group had 

established procedures for setting the prices of food aid commodities in 

Dollars in thousands

Institute

Planned

disbursement Received Balance

Rural Credit Fund $1,296 $1,017 $278

Vavilov Institute 1,036 814 223

Seed Breeding Institute 65 55 10

Williams Feed Institute 65 55 10

Corn Institute 65 55 10

Rice Institute 65 0 65

Totala $2,592 $1,995 $596
B-284700

Page 20 GAO/NSIAD-00-91 Donation of Seed to Russia

Russia, we found inadequate documentation of the price determination 

process for seeds, making it difficult to conclude if the prices charged were 

reasonable. Evaluation of seed performance can provide information to be 

used in the design of future seed donation programs. 

Recommendations In order to more effectively prepare for future government sales or 

donations of U.S. planting seed, we recommend that the Secretary of 

Agriculture

• direct the Foreign Agricultural Service to share information on bilateral 

discussions of seed sales or donations in a timely manner with the Farm 

Service Agency in order to facilitate open and competitive procurement 

of seed and

• direct the Farm Service Agency to identify independent and reliable 

sources of technical expertise to provide assistance in evaluating seed 

varieties, and testing, and to provide information on the U.S. seed 

industry. 

Furthermore, to improve the management of the distribution and sale of 

future donations of seed to Russia, we recommend that the Secretary of 

Agriculture direct the Foreign Agricultural Service to 

• establish an effective monitoring system to verify receipt of seed to the 

regions and the status of unplanted seed (to ensure it is stored in 

appropriate conditions to maintain its quality),

• establish methods of distributing U.S. seed to match (to the extent 

possible) the growing conditions in the recipient regions in Russia, 

• put Russian language labels on seed packages and include more 

information about the seed to producers at the time of distribution,

• fully document the price discovery process for U.S. seed in Russia, and

• carry out an evaluation of seed performance with the goal of analyzing 

the results to improve future seed donation programs.

Agency Comments We obtained oral comments on a draft of this report from USDA’s Foreign 

Agricultural Service and Farm Service Agency. Officials from both agencies 

said that they thought the report was generally fair, accurate, and 

constructive. While both agencies regard the seed donation program as 

successful, they generally agreed with our recommendations and are in the 

process of implementing these changes to the year 2000 program. 
B-284700

Page 21 GAO/NSIAD-00-91 Donation of Seed to Russia

However, Foreign Agricultural Service officials disagreed with the 

recommendation that a more effective monitoring system needs to be 

implemented for future programs since, in their opinion, the monitoring 

system for the 1999 program was extremely effective—over 70 percent of 

deliveries were monitored, and no seed was reexported. They noted that 

this system was never intended to monitor the distribution of seed beyond 

the first buyer, and, in the case of carrot, onion, and beet seed, to the 

purchasing agent in Moscow. 

We agree that Foreign Agricultural Service monitors collected 

documentation of the deliveries of a majority of the corn and pea seed to 

the regions. However, this system does not guarantee that the seed was not 

reexported. Also, the monitoring system was supposed to verify workplans 

and any amendments to the plans but in practice rarely did so. In addition, 

the monitoring system did not confirm that unplanted seed would be 

properly stored for later distribution. While we agree that the monitoring 

system was designed only to follow distribution to the first buyer in the 

regions, the first buyer of carrot, onion, and beet seed was changed. Instead 

of going to multiple regions, the seed was delivered to one state agency, 

Rossortsemovosch, in Moscow. This meant that since the Foreign 

Agricultural Service only verified delivery to the first buyer, it did not 

independently confirm the delivery of carrot, beet, and onion seed to 

regions. As a result, we feel our recommendation is appropriate.

Officials also said that our report did not fully describe the context 

surrounding the procurement of seed in the United States. First, Farm 

Service Agency procurement officials agreed that time limitations reduced 

their ability to undertake market research on seed prices in the United 

States. However, they emphasized that, even with more time, they would 

not have conducted extensive inquiries, in part, out of concern that this 

might increase the cost of the seeds to be procured. Second, a Foreign 

Agricultural Service official stated that the decision to procure the seed 

through a sole source contract was not the only factor influencing the 

decision to donate, rather than sell, the seed to Russia. This official said 

that there was also concern about the impact of an additional $23 million 

loan on Russia’s already large external debt obligations.

We agree that extensive market inquiries by government procurement 

officials could lead to speculation in commodity markets and price 

changes. However, we note that contacting one corn seed dealer did not 

provide the minimum information necessary for effective negotiation with 

the sole source contractor. We also agree that officials may have 
B-284700

Page 22 GAO/NSIAD-00-91 Donation of Seed to Russia

considered the impact of the sale of seed on Russia’s debt, but food aid 

program restrictions on the use of sole source procurement required USDA 

to donate the seed. 

The Foreign Agricultural Service and the Farm Service Agency also 

provided some technical comments and additional information with regard 

to distribution of seed, monitoring, and deposits to the special account. 

Where appropriate, we have incorporated these comments and that 

information into our report. 

Scope and 

Methodology

To examine how the seed sent to Russia was procured, we reviewed 

documentation provided by the Foreign Agricultural Service and also 

interviewed senior Foreign Agricultural Service officials who participated 

in the food aid agreement negotiation process. We examined the process 

used to procure seeds donated to Russia in 1999 by reviewing documents 

provided to us by the Farm Service Agency and interviewing officials 

responsible for procurement of food aid commodities. We also interviewed 

the sole source contractor that procured and shipped the seed and 

representatives from the American Seed Trade Association. 

To examine how seeds were distributed and monitored in Russia, we 

reviewed the distribution plans included in the Food for Progress 

agreement, the workplan provided by the distributing agent, and 

documents used by the Foreign Agricultural Service to track and monitor 

deliveries. Our staff interviewed the principal distributing agent in Russia 

and reviewed documents submitted by the distributing agents in Russia. To 

examine how the seed was monitored and evaluated, we reviewed the 

minutes of the bilateral working group, reports produced by Foreign 

Agricultural Service monitors, and reports submitted to USDA by officials 

from the U.S. seed industry and the contractor. We also interviewed 

officials from the American Seed Trade Association and the sole source 

contractor that visited Russia.

To examine the process for selling the U.S. seed in Russia, we interviewed 

Foreign Agricultural Service officials that participated in the bilateral 

working group in Russia (including the current and former General Sales 

Managers of the Foreign Agricultural Service and the current and former 

U.S. Agricultural Minister Counselors in Moscow). We also reviewed the 

minutes of the bilateral working group and correspondence between U.S. 

and Russian government officials. In addition, we interviewed officials 

from several multinational seed companies that sell corn and vegetable 
B-284700

Page 23 GAO/NSIAD-00-91 Donation of Seed to Russia

seed in Russia, and representatives of a private Russian seed importer and 

of an association of vegetable seed producers in Russia. 

To examine how the proceeds from the sale of seed were distributed to 

agricultural development institutions, we reviewed documentation 

provided by the Foreign Agricultural Service, the government of Russia, the 

Vavilov Seed Institute, and administrators of the Rural Credit Cooperative 

Fund. We interviewed officials from the Foreign Agricultural Service and 

the government of Russia who provided additional detailed information. 

We also visited and interviewed officials at the Vavilov Seed Institute and 

the Williams Feed Institute and also interviewed officials administering the 

Rural Credit Cooperative Fund in Russia.

We conducted our review from November 1999 to February 2000 in 

accordance with generally accepted government auditing standards.

As arranged with your office, unless you publicly announce the contents 

earlier, we plan no further distribution of this report until 30 days after its 

issue date. At that time we will send copies to interested congressional 

committees and the Honorable Dan Glickman, the Secretary of Agriculture. 

We will also make copies available to other interested parties upon request. 

Please contact me at (202) 512-4128 if you or your staff have any questions 

regarding this report. Phillip Thomas and Samantha Roberts made 

significant contributions to this report.

Sincerely yours,

Susan S. Westin, Associate Director

International Relations and Trade Issues
Page 24 GAO/NSIAD-00-91 Donation of Seed to Russia

Appendix I

Distribution of U.S. Planting Seed in Russia ApendxiI

A distribution plan for corn and vegetable seed was included as an 

attachment to the Food for Progress agreement signed in February 1999. 

The distributing agent, Roskhleboproduct, a former state agency, 

developed a workplan for the distribution of the seed according to region. 

The workplan also identified the “first-buyer” (the firm or government 

agency in the region that was to receive and pay for the seed). According to 

the agreement, any changes to this workplan had first to be requested by 

the bilateral working group and approved by the U.S. Minister-Counselor 

for Agricultural Affairs. 

A third document, a travel matrix, tracked the arrival in port and expected 

delivery to regions for all commodity shipments. Tables 3 to 5 summarize 

the distribution of the seed according to the distribution plan included in 

the agreement, the workplan and the travel matrix. Some seed arrived too 

late to be planted. Those amounts are found in the column “stored.”
Appendix I

Distribution of U.S. Planting Seed in Russia

Page 25 GAO/NSIAD-00-91 Donation of Seed to Russia

Table 3: Distribution of Corn Seed by Region According to the Food Aid Agreement, 

the Workplan, and the Travel Matrix

Sources: U.S. Department of Agriculture’s (USDA) Foreign Agricultural Service, government of Russia, 

and Roskhleboproduct.

Corn Seed (metric tons)

Region Agreement Workplan

Travel matrix

delivery

amount Stored

Bryansk oblsat 300 124

Chelyabinsk oblast 1,600 3,000 2,986

Chuvashiya oblast 100

Kaluga oblast 200

Khakassiya Republic 780 782

Kemerovo oblast 289

Kurgan oblast 283

Mari El Republic 100 60 59

Mordovia Republic 1,000 1,020 1,001

Moscow oblast 500

Nizhniy Novgorod 1,000

Novosibirsk oblast 1,053

Omsk oblast 1,520 1,585

Orel oblast 1,000

Ryazansk oblast 2,000 480 457

Smolensk oblast 200

Tartarstan Republic 4,000 5,000 4,703 700

Tula oblast 1,200 480 516

Tyumen oblast 600

Vladimir oblast 200 180 174

Total 14,000 12,520 14,014 700
Appendix I

Distribution of U.S. Planting Seed in Russia

Page 26 GAO/NSIAD-00-91 Donation of Seed to Russia

Table 4: Distribution of Pea Seed by Region According to the Food Aid Agreement, 

the Workplan, and the Travel Matrix

Sources: USDA’s Foreign Agricultural Service, government of Russia, and Roskhleboproduct.

Carrot, Onion, and 

Beet Seed

There was no separate workplan outlining the regional distribution of 

carrot, onion, and beet seed. According to the workplan, Roskhleboproduct 

was to sell all the carrot, onion, and beet seed to Rossortsemovosch, a state 

agency located in Moscow charged with the distribution and sale of the 

seed to firms and producers in the Moscow region and other regions in 

Russia. Rossortsemovosch provided information on distribution to the 

regions and storage of seeds.

Pea Seed (metric tons)

Region Agreement Workplan

Travel matrix

delivery amount

Belgorod oblast 100 100 120

Kabardino-Balkaria 120

Krasnodar Kray 510 560 480

Mordovia Republic 200 200 180

Ryazansk oblast 50 50

Yaroslavl oblast 50 50

Tartarstan Republic 50

Severnaya Ossatia 60

Total 960 960 960
Appendix I

Distribution of U.S. Planting Seed in Russia

Page 27 GAO/NSIAD-00-91 Donation of Seed to Russia

Table 5: Distribution of Carrot, Beet, and Onion Seed by Region According to the Food Aid Agreement and Russian Distributing 

Agent

Carrot Beet Onion

Region Agreement Delivered Stored Agreement Delivered Stored Agreement Delivered Stored

Altay Kray 0.3 0.3 0.1

Amur oblast 0.4 0.5 0.2 0.5 0.1

Arkhangelsk 

oblast 0.2

Astrakhan 0.2 0.5

Bashkortostan 1.0 0.3 0.5

Belgorod oblast 0.5 0.1 0.5 0.2 0.3

Bryansk oblast 0.5 1.0 0.5 0.4

Buryatiya 

Republic 0.2

Chita oblast 0.2 0.5 0.2 0.1

Chelyabinsk 

oblast 1.0

Chuvashiya 

oblast 2.7 2.4

Dagestan 

Republic 0.3 1.5 0.4 0.5 0.1

Irkustsk oblast 0.5

Ivanovsk oblast 0.4 0.5 0.1

KabardinoBalkaria 0.4

Kaliningrad 

oblast 0.5 0.1 0.5 0.1

Kemerovo oblast 0.4 1.0

Khabarovsk 

Kray 0.4

Kostroma oblast 0.4 0.2

Krasnodar Kray 0.5

Krasnoyarsk 

Kray 0.4 1.0 0.4 0.2 0.5

Kurgan oblast 0.4 0.5 0.2

Kurskaya 0.4 0.1 0.5

Leningrad oblast 1.5 0.5

Lipetsk oblast 0.4

Mordovia 

Republic 0.4 0.4

Continued
Appendix I

Distribution of U.S. Planting Seed in Russia

Page 28 GAO/NSIAD-00-91 Donation of Seed to Russia

Moscow oblast 1.0 12.8 1.5 0.5 2.2 1.0

Nizhniy 

Novgorod 0.4 0.5 0.4

Novograd oblast 0.4

Novosibirsk 

oblast 0.4 1.0

Omsk oblast 0.4 2.0 0.3 0.5 1.0 0.3

Orenburg oblast 0.4

Penza oblast 0.4 1.0

Perm oblast 0.4 0.3 0.6

Primorskiy Kray 0.4 0.3

Pskov oblast 0.3 0.1 0.1

Rostov oblast 0.5

Ryazan oblast 0.4 0.1

Sakhalin oblast 0.2

Samara oblast 0.3

Saratov oblast 0.5 0.5

Smolensk oblast 0.4

Sverdlovsk 

oblast 1.0 1.0 0.4 2.0 0.6 0.3

Tambov oblast 0.6 0.6

Tartarstan 

Republic 0.6

Tula oblast 0.4 0.5

Vladimir oblast 0.4

Volgogrod oblast 0.6 2.0 0.4 1.0 0.4

Vologod oblast 0.3 1.5 0.2 1.1

Yakutia 0.2

Uliyanovsk 

oblast 0.5 0.6

Totala 19.0 27.6 4.8 10.0 8.9 1.0 10.0 2.4 0

a Totals may not add up due to rounding.

Sources: USDA’s Foreign Agricultural Service, government of Russia, and Rossortsemovosch.

Carrot Beet Onion

Region Agreement Delivered Stored Agreement Delivered Stored Agreement Delivered Stored

Continued from Previous Page

(711471) Letr
Ordering Information The first copy of each GAO report is free. Additional copies of 

reports are $2 each. A check or money order should be made out to 

the Superintendent of Documents. VISA and MasterCard credit 

cards are accepted, also.

Orders for 100 or more copies to be mailed to a single address are 

discounted 25 percent.

Orders by mail:

U.S. General Accounting Office

P.O. Box 37050

Washington, DC 20013

Orders by visiting:

Room 1100

700 4th St. NW (corner of 4th and G Sts. NW)

U.S. General Accounting Office

Washington, DC

Orders by phone:

(202) 512-6000

fax: (202) 512-6061

TDD (202) 512-2537

Each day, GAO issues a list of newly available reports and 

testimony. To receive facsimile copies of the daily list or any list 

from the past 30 days, please call (202) 512-6000 using a touchtone 

phone. A recorded menu will provide information on how to obtain 

these lists.

Orders by Internet:

For information on how to access GAO reports on the Internet, 

send an e-mail message with “info” in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web home page at: 

http://www.gao.gov

To Report Fraud, 

Waste, or Abuse in 

Federal Programs

Contact one:

• Web site: http://www.gao.gov/fraudnet/fraudnet.htm

• e-mail: fraudnet@gao.gov

• 1-800-424-5454 (automated answering system)


United States

General Accounting Office

Washington, D.C. 20548-0001

Official Business

Penalty for Private Use $300

Address Correction Requested

Bulk Rate

Postage & Fees Paid

GAO

Permit No. GI00