GAO

United States General Accounting Office

A

Testimony

Before the Subcommittee on the District of Columbia, 

Committee on Appropriations, U.S. Senate

For Release on Delivery

Expected at 10 a.m. EDT

Tuesday, June 22, 2004

DISTRICT OF COLUMBIA

Structural Imbalance And 

Management Issues

Statement of Patricia A. Dalton, Director,

Strategic Issues

GAO-04-908T
GAO used a multifaceted approach to measure structural imbalance, which 

involves comparing a fiscal system’s ability to fund an average level of public 

services with revenues that it could raise with an average level of taxation, plus 

the federal aid it receives. This approach compared the District’s circumstances 

to a benchmark based on the average spending and tax policies of the 50 state 

fiscal systems (each state and its local governments). GAO also reviewed key 

programs as well as infrastructure and outstanding debt. GAO found: 

• The cost of delivering an average level of services per capita in the District 

far exceeds that of the average state fiscal system due to factors such as 

high poverty, crime, and a high cost of living. 

• The District’s per capita total revenue capacity is higher than all state fiscal 

systems but not to the same extent that its costs are higher. In addition, its 

revenue capacity would be larger without constraints on its taxing authority, 

such as its inability to tax federal property or the income of nonresidents. 

• The District faces a substantial structural deficit in that the cost of providing 

an average level of public services exceeds the amount of revenue it could 

raise by applying average tax rates. Data limitations and uncertainties 

surrounding key assumptions in our analysis made it difficult to determine 

the exact size of the District’s structural deficit, though it likely exceeds 

$470 million annually. Consequently, even though the District’s tax burden 

is among the highest in the nation, the resulting revenues plus federal grants 

are only sufficient to fund an average level of public services, if those 

services were delivered with average efficiency. 

• The District’s significant, long-standing management problems in key 

programs waste resources and make it difficult to provide even an average 

level of services. Examples include inadequate financial management, 

billing systems, and internal controls, resulting in tens of millions of dollars 

being wasted, and hindering its ability to receive federal funding. 

Addressing management problems would not offset the District’s underlying 

structural imbalance because this imbalance is determined by factors 

beyond the District’s direct control. Addressing these management 

problems would help offset its current budget gap or increase service levels.

• The District continues to defer major infrastructure projects and capital 

investment because of its structural imbalance and its high debt level. 

If this imbalance is to be addressed in the near term, it is a policy issue for the 

Congress to determine if it should change federal policies to expand the 

District’s tax base or provide additional support. However, given the existence 

of structural imbalances in other jurisdictions and the District’s significant 

management problems and the federal government’s own fiscal challenges, 

federal policymakers face difficult choices regarding what changes, if any, they 

should make in their financial relationship with the District. If the District were 

to receive additional federal support to compensate for its structural imbalance 

and enhance its ability to fund capital investments, it is important that the 

District follow sound practices to avoid the costly management inefficiencies it 

has experienced in the past. These practices include evaluating and selecting 

capital assets using an investment approach, integrating organizational goals 

into the capital decision-making process, and providing transparency and 

accountability over the use of federal funds. 

District of Columbia officials have 

reported both a current services 

budget gap and a more permanent 

structural imbalance between costs 

and revenue-raising capacity. They 

maintain that the structural 

imbalance largely stems from the 

federal government’s presence and 

restrictions on the District’s tax 

base. Accordingly, at various times 

District officials have asked the 

Congress for additional funds and 

other measures to enhance 

revenues. In that context, the 

Subcommittee has asked GAO to 

discuss its May 2003 report, 

District of Columbia: Structural 

Imbalance and Management 

Issues (GAO-03-666). This 

testimony addresses the key 

findings and concluding 

observations of the May 2003 

report. Specifically, this testimony 

discusses: (1) whether, or to what 

extent, the District faces a 

structural imbalance between its 

revenue capacity and the cost of 

providing residents with average 

levels of public services by using a 

representative services approach; 

(2) any significant constraints on 

the District’s revenue capacity; 

(3) cost conditions and 

management problems in key 

program areas; and (4) the effects 

of the District’s fiscal situation on 

its ability to fund infrastructure 

projects and repay related debt. 

 

www.gao.gov/cgi-bin/getrpt?GAO-04-908T 

To view the full product, click on the link 

above. For more information, contact Patricia 

A. Dalton at (202) 512-6806 or 

daltonp@gao.gov. 

Highlights of GAO-04-908T, testimony 

before the Subcommittee on the District of 

Columbia, Committee on Appropriations, 

U. S. Senate 

June 2004

DISTRICT OF COLUMBIA 

Structural Imbalance and Management 

Issues 
Page 1 GAO-04-908T 

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss our report, District of Columbia: 

Structural Imbalance and Management Issues.

1

 Though our report was 

released a year ago, its focus on fundamental aspects of the District’s 

financial structure continues to be relevant. In recent years, District of 

Columbia (District) officials have reported that a continuation of the 

District’s current spending and taxing policies would result in ongoing 

current services budget imbalances. While District officials have 

demonstrated their resolve to maintain fiscal discipline by taking the steps 

needed to balance their budgets for fiscal years 2004 and 2005, those 

officials claim that the District faces a more permanent structural 

imbalance between its revenue-raising capacity and the cost of meeting its 

public service responsibilities that are the result of many factors, several 

stemming from the federal government’s presence in the District and the 

restrictions on the District’s tax base.

Although there is no uniform definition of structural imbalance, there are 

two concepts that can be used to measure it—current services and 

representative services imbalances. A current services imbalance answers 

the question: If a jurisdiction were to maintain its current level of services 

into the future, would it be able to raise the revenues necessary to maintain 

that level of service under its current taxing policies? This type of 

longitudinal analysis compares a jurisdiction’s projected fiscal position 

with its current position and is independent of other similarly situated 

jurisdictions. In contrast, a representative services imbalance answers the 

question: If a jurisdiction were to provide a representative basket of public 

services with average efficiency, would it be able to generate sufficient 

revenues from its own taxable resources and federal grants to fund the 

representative basket of services if its resources were taxed at 

representative rates? This type of analysis uses a basket of services and 

tax structure typical of other jurisdictions with similar public service 

responsibilities as a benchmark against which to compare imbalances 

between the cost of public services and revenue-raising capacity. The 

approach attempts to compare differences in jurisdictions’ fiscal positions 

under a common set of policies regarding levels of services and taxation. 

The District has reported both a current services and a more permanent 

structural imbalance between its costs and revenue-raising capacity.

1

 U.S. General Accounting Office, District of Columbia: Structural Imbalance and 

Management Issues, GAO-03-666 (Washington, D.C.: May 2003). 
Page 2 GAO-04-908T 

My statement today will discuss (1) whether, and to what extent, the 

District faces a structural imbalance between its revenue capacity and the 

cost of providing residents and visitors with average levels of public 

services by using a representative services approach; (2) any significant 

constraints on the District’s revenue capacity; (3) cost conditions and 

management problems in key program areas; and (4) the effects of the 

District’s fiscal situation on its ability to fund infrastructure projects and 

repay related debt.2

 We performed our work assessing the structural 

imbalance and management issues from August 2002 through May 2003 in 

accordance with generally accepted government auditing standards, and in 

June 2004 we obtained updated budget information.

GAO’s Methodology for 

Assessing Structural 

Imbalance

We used a representative services analysis to conduct our work on whether 

and to what extent the District has a structural imbalance. This approach 

allows us to compare the District’s fiscal circumstances against a 

benchmark based on services and taxation that is typical of jurisdictions 

with similar fiscal responsibilities, which is different from a current 

services approach, which would be based on the District’s historical 

spending and tax choices. 

When analyzing a representative service imbalance, the choice of a 

benchmark for a representative level of public services and taxation is a 

critical decision. In fact, the appropriate level of services and taxation is a 

matter of perennial debate in every jurisdiction in the nation. For this 

reason, we used as a benchmark national average levels of spending and 

taxation because they are independent of individual jurisdictions’ 

particular preferences, policy choices, and efficiency of service provision. 

National averages provide benchmarks that are “representative” of the 

level of services that a typical state fiscal system (the collections of a state, 

counties, cities, and a myriad of special purpose district governments) 

employs. A fiscal system is said to have a structural imbalance if it is 

unable to finance an average (or representative) level of services by taxing 

its funding capacity at average (or representative) rates. Because we 

defined structural imbalance in terms of comparisons to national averages, 

for any given time period a significant proportion of all fiscal systems will 

have structural deficits. 

2

 Prior to our May 2003 report, we issued a preliminary report on these issues in September 

2002. See U.S. General Accounting Office, District of Columbia: Fiscal Structural Balance 

Issues, GAO-02-1001 (Washington, D.C.: September 2002).
Page 3 GAO-04-908T 

Determining empirically whether the District has a structural imbalance is 

a complex task that involves making judgments about: (1) the appropriate 

set of governments to use when developing benchmarks for the District’s 

spending and revenue capacity; (2) the influence that various workload and 

cost factors, such as the number of school age children and number of 

vehicle miles traveled, have on the cost of public services; and (3) the best 

way to measure revenue capacity.

Using economic modeling, we were unable to provide a single, precise 

point estimate of structural imbalance, but provided a range instead. Given 

the lack of professional consensus and a limited empirical basis for many 

of the decisions underlying our methodology, which was vetted with key 

experts, we performed several sensitivity analyses to show how our 

estimates changed as we varied key assumptions. In addition, the precision 

of our estimates is adversely affected by data limitations for various cost 

and tax bases. Nevertheless, we believe that the consistency of our basic 

result over a broad range of alternative assumptions and approaches 

provides sufficient support for the conclusions offered in this report. 

Moreover, we supplemented our quantitative analysis with a programmatic 

review of the District’s three highest cost program areas to provide 

additional insights into the level of services, costs, management, and 

financing.

For our cost analysis, we computed two separate sets of benchmarks: one 

based on a “state” services basket, the mix of services typically provided by 

state fiscal systems (each state and all of its local governments), and a 

second based on an “urban” services basket, the mix of services that are 

typically provided by governments in more densely populated areas. The 

scope of services included is the same for both baskets; what differs is the 

proportion of total spending that is allocated to each service. For example, 

the “urban” basket of services gives greater weight to public safety 

functions and less weight to higher education than does the state basket of 

services.

To estimate total revenue capacity of each state fiscal system, we combined 

estimates for the two principal sources from which those systems finance 

their expenditures: (1) revenues that could be raised from each system’s 

own economic base (own-source revenue), and (2) the federal grants that 

each system would receive if it provided an average basket of services. 

Two basic methodologies have been employed to estimate the own-source 

revenue capacity of states: (1) the total taxable resources (TTR), which 

uses income to measure the ability of governments to fund public services; 
Page 4 GAO-04-908T 

and (2) the representative tax system (RTS), which measures the amount 

of revenue that could be raised in each state if an average set of tax rates 

were applied to a specified set of statutory tax bases “typically” used to 

fund public services. Because experts disagree as to which approach is 

superior, we computed separate results using both methodologies.

We estimated the size of the District’s structural imbalance as the 

difference between its cost of providing an average level of services and its 

total revenue capacity—the amount of revenue the District would have 

(including federal grants) if it applied average tax rates to its taxable 

resources. 

The District’s Public 

Service Costs Are the 

Highest in the Nation

Using other state fiscal systems as a benchmark, our analysis indicated that 

the cost of delivering an average level of services per capita in the District 

exceeds that of the average state fiscal system by approximately 75 percent 

(or a total of $2.3 billion more annually than if it faced average costs 

circumstances) and is over a third more than the second highest-cost state 

system, New York. If state fiscal systems were to provide a basket of 

services typically provided in more densely populated urban areas, we 

estimated that the District would have to spend over 85 percent more (or a 

total of $2.6 billion more annually) than average to fund an average level of 

services.

The District faces high-cost circumstances, largely beyond its control, in 

key program areas including Medicaid, elementary and secondary 

education, and police and fire services that increase the fiscal burdens on 

the District’s budget. For example, regarding Medicaid, we estimated that 

high-cost circumstances, such as its large low-income population, would 

require the District to spend well over twice the national average per 

capita. Consequently, to provide an average level of services the District 

would have to spend a total of $437 million more than if it faced average 

cost circumstances. Similarly, we estimated that the District’s per capita 

cost of elementary and secondary education is 18 percent above the 

average state fiscal system due to circumstances such as a 

disproportionately high percentage of low-income children. As a result, to 

provide an average level of services the District would have to spend a total 

of about $136 million more than if it faced average cost circumstances. 

Likewise, for police and fire services, the District’s per capita costs of 

providing an average level of services are well over twice the national 

average due to circumstances such as its relatively young population, 

especially high crime rates, and its dense living conditions. As a result, to 
Page 5 GAO-04-908T 

provide an average level of services the District would have to spend about 

$480 million more than if it faced average cost circumstances. Further, our 

cost estimates do not explicitly account for the various public safety 

demands and costs associated with the federal government’s presence.

The District’s Revenue 

Capacity Is Among the 

Highest in the Nation, 

Despite Some 

Constraints on Its 

Taxing Authority

Our analysis indicated that the District’s per capita total revenue and ownsource revenue capacities are higher than those of all but a few state fiscal 

systems. Its capacity is high even though the District faces some 

significant constraints on its taxing authority, such as the inability to tax 

federal property or the income of nonresidents who work in the District. 

The two estimation approaches we used to measure the District’s revenue 

capacity yielded the same basic result: The District’s own-source revenue 

capacity per capita ranked among the top five when compared to those of 

the 50 state fiscal systems. This high own-source revenue capacity, 

combined with the fact that its per capita federal grant funding is over two 

and one-half times the national average, gives it a higher total revenue 

capacity than any other state fiscal system. Depending on which 

estimation approach we used, the District’s total revenue capacity ranged 

from 47 percent above the national average (based on a conservative 

version of the RTS approach) to 60 percent above (based on the TTR 

approach). 

The District Faces a 

Structural Deficit

We concluded that the District does have a substantial structural deficit in 

the sense that the cost of providing an average level of public services 

exceeds the amount of revenue it could raise by applying average tax rates, 

although considerable uncertainty exists regarding its exact size. We 

obtained our lowest deficit estimate of about $470 million per year by 

combining the lowest estimate of the District’s costs (the one based on the 

state basket of services) with the highest estimate of the District’s total 

revenue capacity (TTR). In contrast, we obtained the highest deficit 

estimate of over $1.1 billion per year by combining the highest estimate of 

the District’s costs (the one based on the urban basket of services) with the 

lowest estimate of the District’s total revenue capacity (RTS). Among the 

contributing factors to the structural imbalance are high-cost conditions 

largely beyond the District’s control, such as high poverty rates, large 

concentrations of low-income children and the elderly, and high crime 

rates. Figure 1 shows how the District’s structural deficit per capita 

compares to the state fiscal systems with the largest structural deficits.
Page 6 GAO-04-908T 

Figure 1: Fiscal Systems with the Largest Structural Deficits Per Capita

Despite a High Tax 

Burden, the District’s 

Revenues Are Only 

Sufficient to Fund an 

Average Level of 

Services

In addition to having high revenue capacity, the District also imposes above 

average tax rates; however, high taxes are only sufficient to fund an 

average level of services. Figure 2 shows the District’s tax burden and costadjusted spending. Because of its high tax rates, actual revenues collected 

by the District exceeded our lower estimate of its own-source revenue 

capacity at an average tax burden by 33 percent and exceeded our higher 

estimate of that capacity by 18 percent (see the first two bars of fig. 2). 

However, the District’s actual fiscal year 2000 spending was only equal to 

the cost of an average level of public services, based on the basket of 

services provided by the average state fiscal system. Using the basket of 

services typically provided by urban governments as a benchmark, the 

District’s spending is 5 percent below that needed to fund an average level 

of services (see the last two bars of fig. 2). Our estimates of the cost of 

delivering an average level of services presume that they are provided with 

average efficiency. To the extent that the District does not deliver services 

with average efficiency, its actual level of services may be below average. 

0

500

1000

1500

2000

2500 Deficit per capita (national average = 0)

State services, TTR capacity

Urban services, RTS “Low” capacity

District of

Columbia

Alabama Arizona Arkansas California Georgia Louisiana Mississippi New Mexico New York Oklahoma Texas

Source: GAO.
Page 7 GAO-04-908T 

Figure 2: District’s Tax Burden and Cost-adjusted Spending

Management Problems 

Result in Unnecessary 

Spending That 

Compromises the 

District’s Ability to 

Provide an Average 

Level of Public 

Services. 

The District’s long-standing management problems waste resources that it 

cannot afford to lose and draw resources away from providing even an 

average level of services. In three key program areas (Medicaid, 

elementary and secondary education, and police and fire services), our 

original report identified significant management problems, such as 

inadequate financial management, billing systems, and internal controls. 

While the District has taken some actions to correct management 

inefficiencies, more improvements are needed. In the case of Medicaid, in 

fiscal year 2001 the District wrote off over $78 million for several years 

worth of unreimbursed claims for federal Medicaid matching funds. The 

District was not able to claim this reimbursement because of late 

submission of reimbursement requests, incomplete documentation, 

inadequate computerized billing systems, providing services to individuals 

not eligible for Medicaid at the time of delivery, and billing for services not 

allowable under Medicaid. The independent auditor of the District’s 

financial statements continued to report Medicaid accounting and claims 

processing as a material weakness in fiscal year 2003. The extent of these 

0

20

40

60

80

Low capacity

estimate

High capacity

estimate

State service

basket

Urban service

basket

Percentage of U.S. average

U.S. average

Tax

burden 

Cost-adjusted

spending

Source: GAO.

100

120

140

160
Page 8 GAO-04-908T 

management problems suggests that the District continues to bear more of 

the burden of Medicaid costs than necessary. 

In the case of education, in the recent past District public school officials 

were not able to track either the total number of employees or whether 

particular positions were still available or had been filled. For example, in 

March 2003, District officials announced that the school system had hired 

640 more employees than its budget authorized, resulting in the District 

exceeding its personnel budget by a projected amount of $31.5 million over 

the entire fiscal year. In another example, the District’s lack of internal 

control for procurement practices in its public school system resulted in 

$10 million in unauthorized purchases. While our cost analysis shows that 

the District is spending an amount that could provide an average level of 

services, the extent of these management problems suggests that the 

District provides less than the national average of education services. 

In the case of police and fire services, the District historically has not 

adequately tracked the costs it incurs to support the federal presence, in 

areas such as providing protection to federal officials and key dignitaries 

and dealing with an array of special events and demonstrations. This 

hinders its ability to make a case for additional federal reimbursement, 

requiring it to spend more of its own resources to support the federal 

presence.

The District Continues 

to Defer Improvements 

to Its Infrastructure 

While Debt Pressures 

Remain

Although the District is making some attempts to address its backlog of 

infrastructure needs, it has nonetheless continued to defer significant 

amounts of infrastructure projects because of constraints in its operating 

budget. Most of the District’s infrastructure and capital improvement 

projects are financed by using general obligation bonds. The interest and 

principal payments (debt service) on those bonds are paid from the 

District’s operating budget. Although the District is not close to its legal 

debt limit, it cannot accommodate additional debt without cutting services 

or raising taxes that are already higher than those of other jurisdictions. 

Contributing to the District’s difficulties is its legacy of deteriorated 

infrastructure and its 40 percent share of funding the metropolitan area’s 

costly mass transit system. However, the District is attempting to address 

its backlog of infrastructure needs through increased capital expenditures 

(estimated at roughly $371 million in fiscal year 2003). Nevertheless, the 

reality is that the District continues to defer major infrastructure and 

capital investment in part because of its structural imbalance. 
Page 9 GAO-04-908T 

From 1995 to 2002, the District’s outstanding general obligation debt 

changed little, totaling slightly over $2.67 billion as of September 30, 2002, 

and debt per capita has remained fairly constant. The District’s total 

outstanding general obligation debt as of September 30, 2003, was $3.25 

billion. As a percentage of local general fund revenues, debt service costs, 

which were 7.5 percent of revenue for fiscal year 2003, are expected to 

climb to approximately 10 percent by 2006. The District’s projections 

assume that debt service costs will increase at a higher rate than local 

revenues. Furthermore, when compared to combined state and local debt 

across the 50 states, the District’s debt, both per capita and as a percentage 

of own-source revenue, ranks among the highest in the nation. Despite the 

challenges it faces, the District has been successful in having its bond 

rating upgraded by all the major rating agencies in part due to the 

improving economy and improved financial management.

Concluding 

Observations

Due to a combination of its substantial structural deficit and significant 

management problems, the District is likely providing a below-average 

level of services even though its tax burden is among the highest in the 

nation. By addressing its management problems, in the long term the 

District could reduce future budget shortfalls. However, management 

improvements will not offset the underlying structural imbalance because 

it is caused by factors beyond the direct control of District officials. As a 

consequence, District officials may face more difficult policy choices than 

most other jurisdictions in addressing a budget gap between spending and 

revenues based on current policies. Since the District may not be providing 

an average level of services, it would also be difficult to cut services further 

and the tax burden it imposes is among the highest in the nation. An 

alternative option to raising taxes or cutting services would be for District 

officials to continue deferring improvements to its capital infrastructure. 

This strategy also is not viable in the long run in that deteriorating 

infrastructure would of necessity lead to further reductions in the levels 

and types of services provided and ultimately would necessitate either 

higher taxes or cuts in services. 

Although it would be difficult, District officials could address a budget gap 

by taking actions such as cutting spending, raising taxes, and improving 

management inefficiencies. However, a structural imbalance is beyond the 

direct control of local officials. Without changes in the underlying factors 

driving expenses and revenue capacity, the structural imbalance will 

remain. If this imbalance is to be addressed, in the near term it may be 

necessary to change federal policies to expand the District’s tax base or to 
Page 10 GAO-04-908T 

provide additional financial support. However, given the existence of 

structural imbalances in other jurisdictions and the District’s significant 

management problems, federal policymakers face difficult choices 

regarding what changes, if any, they should make in their financial 

relationship with the District. Further, another consideration for the 

Congress is that the federal government faces its own long-term fiscal 

challenges with the prospect of large, persistent deficits. Nevertheless, by 

virtue of the District being the nation’s capital, justification may exist for a 

greater role by the federal government to help the District maintain fiscal 

balance. At the same time, the District must achieve basic management 

performance and accountability standards to ensure an efficient use of any 

resources.

Accordingly, if the District were to receive additional federal assistance to 

compensate for its structural imbalance and enhance its ability to fund 

capital investments—as is proposed in the District of Columbia Fair 

Federal Compensation Act of 2004 (H.R. 4269)—it is important that the 

District follow sound practices in order to avoid the costly management 

inefficiencies it has experienced in the past. The Congress needs 

assurance that any federal assistance to the District would be spent 

effectively and efficiently. It is critical to have clear, transparent reporting 

and accountability mechanisms in place to ensure the proper use of federal 

funds. Also, the Congress might want to consider incentives to encourage 

the effective utilization of any federal funds. 

Specifically, we have issued detailed guidance—based on best practices of 

public and private entities— for the planning, budgeting, acquisition, and 

management of capital assets, including infrastructure projects and 

technology upgrades.3

 Key elements of this guidance are to closely link any 

planned capital investments to a government or agency’s strategic goals 

and objectives, ensure that effective information systems are in place to 

support sound decision making and management, and for city leaders to 

clearly communicate their vision and goals to project managers. In 

addition, our past work has shown that it is useful to make capital 

decisions based on the following five basic principles and to follow related 

practices.

3

 U.S. General Accounting Office, Executive Guide: Leading Practices in Capital DecisionMaking GAO/AIMD-99-32 (Washington, D.C.: December 1998).
Page 11 GAO-04-908T 

• Integrate organizational goals into the capital decision-making process, 

such as conducting comprehensive assessments of needs in relation to 

the current inventory of assets, and evaluating alternative approaches to 

meeting needs.

• Evaluate and select capital assets using an investment approach, 

meaning that a clear project approval framework should be established, 

projects should be ranked based on established criteria, and long-term 

capital plans should be developed.

• Balance budgetary control and managerial flexibility when funding 

capital projects, which entails budgeting for the projects in segments 

and considering full, upfront funding.

• Use project management techniques to optimize project success, such 

as monitoring project performance, establishing incentives for 

accountability, and using cross-functional teams to manage the projects.

• Evaluate results to make sure goals and objectives are being met and 

incorporate lessons learned into the decision-making process, including 

occasional reappraisals of decision-making and management processes.

We have not examined the District’s capital planning and management 

functions. District officials may already be following these principles and 

practices. Nevertheless, all of them are important to consider in order to 

maximize investment. 

Mr. Chairman, this concludes my prepared statement. I would be pleased 

to answer any questions you or the other members of the Subcommittee 

may have at this time. 

For future contacts regarding this testimony, please call Patricia A. Dalton, 

Director, Strategic Issues, at (202) 512-6806. Other individuals who made 

key contributions to this testimony were Thomas Yatsco, Eric Mader, 

Jeanette Franzel, Norma Samuel, Ann Calvaresi Barr, Jerry Fastrup, and 

James Wozny.

(450337)
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