OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

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Special Inspector General for IRAQ Reconstruction

SIGIR

For more information, contact SIGIR Public Affairs at 

(703) 428-1100 or PublicAffairs@sigir.mil Special Inspector General for Iraq Reconstruction

Summary of Report: SIGIR 12-007

Why SIGIR Did This Study

The Falluja Waste Water Treatment System was 

one of the largest and most expensive 

construction projects in Iraq. It was part of a 

broad strategy to improve Iraq’s infrastructure

so as to win the hearts and minds of the Iraqi 

people. This report discusses the history and 

outcomes of the Falluja Waste Water Treatment 

System and examines the lessons learned from 

this difficult reconstruction experience as 

applied to wartime contracting. 

Lessons Learned

A successful reconstruction program requires a 

balancing of security, political, and economic 

interests. Reconstruction cannot proceed on a 

large scale without the requisite security to 

protect those carrying out the projects and those 

overseeing them. In Iraq, the scope of 

reconstruction was too often insupportable by 

available security resources. To this day, Iraq’s 

reconstruction environment has never been truly 

“post-conflict.” Endlessly resuming rebuilding 

in the wake of sustained attacks on 

reconstruction personnel and critical 

infrastructure proved to be a demoralizing and 

wasteful strategy. In future stabilization and 

reconstruction operations, the U.S. government 

should analyze whether and at what costs 

security risks can be mitigated before 

proceeding with large-scale rebuilding projects. 

Such projects should begin only when senior 

leaders determine that the strategic objective 

they could fulfill outweighs the risk of failure 

and the costs of mitigating security risks.

Management Comments and Audit 

Response

The Department of State and the U.S. Army 

Corps of Engineers provided comments on a 

draft of this report. The comments are printed 

in their entirety in Appendices F and G. The 

U.S. Central Command provided technical 

comments that we also incorporated as 

appropriate in the report.

October 30, 2011

FALLUJA WASTE WATER TREATMENT SYSTEM: A CASE STUDY IN 

WARTIME CONTRACTING

What SIGIR Found

Heavy fighting in Falluja, poor planning, unrealistic cost estimates, and 

inadequate funding led to significant cost-overruns and delays in 

constructing the city’s new wastewater treatment system. After seven years 

and the expenditure of over $100 million dollars, the backbone of a 

wastewater treatment system is now in place, which is currently servicing

approximately 38,400 residents. But this is far short of the 100,000 residents 

originally intended to benefit from the system. Despite this shortfall, the 

facility is expandable and, with additional investment by the Iraqi 

government, tens of thousands of additional residents could be connected to 

it. SIGIR notes that the Iraqi government is now supporting the system’s 

current operation and its future expansion. But completion of the existing 

backbone system was years late and millions of dollars over budget, leaving 

Falluja’s streets torn up and in disrepair for years. Many people, including 

U.S. State Department personnel, died while working in support of this 

project. 

Assessing the Falluja Waste Water Treatment System solely on its excessive 

costs and limited results may not fully realize the nature of its secondary 

goals and objectives. Wartime projects generally have secondary goals that 

shape management decisions made along the way. This project had the 

secondary goals of enhancing local citizens’ faith in their government’s 

ability to deliver essential services, building a service capacity within the 

local government, winning the hearts and minds of a critical segment of the 

Iraqi populace, and stimulating the economy by boosting employment 

(particularly for young men who were potentially recruitable by the 

insurgency). 

This project was taken on in 2004 in a city wracked by violence. Little 

planning went into the project, and there was minimal understanding of site 

conditions, no skilled workforce available, and no clear idea about how 

much the new system would cost. Very early in the project, security 

conditions rapidly deteriorated such that the trenches and pipes laid by the 

U.S. contractor were regularly being blown up, and construction workers 

were subject to continual attacks. On several occasions, U.S. combatant 

commanders had to direct the contractor to stop construction until security 

improved. So many adverse conditions faced this project from the outset; 

thus, it is hard to understand why it was initiated and continued. 

The absence of information or analysis on whether progress was made 

toward achieving any of the secondary goals makes an assessment of this 

project’s worth or wisdom quite difficult. In the end, it would be dubious to 

conclude that this project helped stabilize the city, enhanced the local 

citizenry’s faith in government, built local service capacity, won hearts or 

minds, or stimulated the economy. Coupled with the fact that the outcome 

achieved was a wastewater treatment system operating at levels far below 

what was anticipated, it is difficult to conclude that the project was worth the 

$100 million investment and the many lives lost.
SPECIAL INSPECTOR GENERAL FOR IRAQ RECONSTRUCTION

2530 Crystal Drive • Arlington, Virginia 22202

October 30, 2011

MEMORANDUM FOR U.S. SECRETARY OF STATE

U.S. AMBASSADOR TO IRAQ

U.S. SECRETARY OF DEFENSE

COMMANDING GENERAL, U.S. CENTRAL COMMAND

COMMANDING GENERAL, U.S. ARMY CORPS OF ENGINEERS

SUBJECT: Falluja Waste Water Treatment System: A Case Study in Wartime Contracting

(SIGIR 12-007)

We are providing this audit report for your information and use. The report discusses the history 

of the Falluja Waste Water Treatment System construction project and it provides some lessons 

learned in wartime contracting. We performed this audit in accordance with our statutory 

responsibilities contained in Public Law 108-106, as amended, which also incorporates the duties 

and responsibilities of inspectors general under the Inspector General Act of 1978. This law 

provides for independent and objective audits of programs and operations funded with amounts 

appropriated or otherwise made available for the reconstruction of Iraq, and for 

recommendations on related policies designed to promote economy, efficiency, and effectiveness 

and to prevent and detect fraud, waste, and abuse. This audit was conducted as Project 1018.

The Department of State provided written comments on a draft of this report that we addressed 

as appropriate. Those comments are printed in their entirety in Appendix F. The U.S Central 

Command provided technical comments that were also included in the report where appropriate.

We appreciate the courtesies extended to the SIGIR staff. For additional information on the 

report, please contact Glenn D. Furbish, Assistant Inspector General for Audits (Washington, 

DC), (703) 604-1388/ glenn.furbish@sigir.mil, or Jim Shafer, Principal Deputy Assistant 

Inspector General for Audits (Washington, DC), (703) 604-0894/ james.shafer@sigir.mil.

Stuart W. Bowen, Jr.

Inspector General

cc: Commanding General, United States Forces–Iraq

Commanding General, Joint Contracting Command–Iraq/Afghanistan

Sil ItGl fIRtti
Table of Contents

Introduction 1

Background 1

Key Government Agency Roles 6

After Seven Years, the Falluja Project Remains Incomplete 8

Volatile Security Environment 8

Unrealistic Project Cost Estimates and Completion Time Frames 17

Funding Varied 18

Lack of Adequate Funding 19

Changed Contracting Strategies Further Delayed and Increased Construction Costs 21

Final Project Scope and Cost Decisions Delayed 23

Lack of Communication with Appropriate GOI Reconstruction Officials 23

Falluja’s Tribal Customs Further Delayed Construction 24

Major Changes in Project Direction Occurred in 2008 25

Project Impact Is Unknown 28

Conclusions and Lessons Learned 29

Conclusion 29

Lessons Learned 29

Management Comments and Audit Response 31

Appendix A—Scope and Methodology 32

Appendix B—Key Events for the Falluja Wastewater Treatment System 

Project 34

Appendix C—List of Contracts Associated with the Falluja Wastewater 

Treatment System Project 36

Appendix D—Acronyms 40

Appendix E—Audit Team Members 41

Appendix F—Management Comments 42
Appendix G—Management Comments 44

Appendix H—SIGIR Mission and Contact Information 45
1

Falluja Waste Water Treatment System:

A Case Study in Wartime Contracting

SIGIR 12-007 October 30, 2011

Introduction 

This report provides information on one of the largest reconstruction projects undertaken in Iraq; the 

Falluja Waste Water Treatment System.

1

As of September 2011, the treatment facility had an estimated cost of $107.9 million and is servicing

6,000 homes

 The project was initiated in June 2004 after U.S. officials 

approached the Government of Iraq (GOI) and asked what could be done in Falluja to help rebuild the 

city. The U.S. military had completed a major operation there earlier that year, and the city had 

sustained heavy damage. The GOI offered a list of projects for the city, including a request for a 

sewer network system. GOI officials wanted this system to service the residents of the city of Falluja. 

At the time, Falluja did not have a comprehensive sewage system. 

2 (or approximately 38,400 residents).3

Background

To complete the system the GOI will need to 

spend at least $87 million more and the entire network collection system is not estimated to be 

completed until at least 2014. This report examines the Falluja Waste Water Treatment System 

project and the reasons for its current partially complete status. 

The Coalition Provisional Authority (CPA) was created in May 2003 as the interim managing body for 

governance and reconstruction activities in Iraq following the U.S. invasion in March 2003. The CPA 

represented a multinational effort led by the United States to rebuild Iraq, restore stability, and aid in 

establishing an interim Iraqi government. The CPA’s ultimate goal for post-war Iraq was “a unified 

and stable, democratic Iraq that provides effective and representative government for the Iraqi people;

is underpinned by new and protected freedoms and a growing market economy; is able to defend itself 

but no longer poses a threat to its neighbors or international security.”4

 1 The Falluja Waste Water Treatment System project is also referred to in various documents as the Falluja Sewerage 

Network project, Falluja Sewer Distribution Network project, and Falluja Sewer Network. For consistency within this 

report, unless used in a quotation, SIGIR refers to it as the Falluja Waste Water Treatment System.

 

2 The total estimated cost of $107.9 million includes costs for connecting 9,116 homes to the wastewater treatment plant, of 

which 6,000 are connected as of September 2011.

3 In order to determine the number of residents currently served by this project, SIGIR used the 2007 World Health 

Organization/Republic of Iraq “Iraq Family Health Survey Report,” average of 6.4 people per Iraqi household. 

Consequently, 6,000 homes equals approximately 38,400 residents. 4 Coalition Provisional Authority, Baghdad, Iraq, Achieving the Vision to Restore Full Sovereignty to the Iraqi People 

(Strategic Plan), 10/1/2003.
2

The CPA’s strategy for accomplishing this goal consisted of four principle objectives or “core 

foundations”5

• Security–establishing a secure and safe environment

:

• Essential services–restoring basic services to help stabilize Iraq

• Economy–creating the conditions for economic growth

• Governance–enabling the transition to transparent and inclusive democratic 

governance

The CPA issued the “Program/Integration Management Plan for Recovery, Reconstruction and 

Redevelopment of Iraq,” with the stated objective to “assist in restoring the stability of Iraq and the 

Iraqi economy by means of infrastructure and development.”6

The Administration, in seeking supplemental funding for Iraq’s reconstruction, stated: 

 

This budget request will support our commitment to helping the Iraqi and Afghan 

people rebuild their own nations, after decades of oppression and mismanagement. We 

will provide funds to help them improve security. And we will help them to restore 

basic services, such as electricity and water, and to build new schools, roads, and 

medical clinics. This effort is essential to the stability of those nations, and therefore, 

to our own security. 7

To restore essential services in electricity, potable water, sewage, education, and health, the U.S. 

government’s top priority was large-scale infrastructure projects.8

 Through the Iraq Relief and 

Reconstruction Fund (IRRF), the U.S. government programmed $4.2 billion for electricity, 

$2.1 billion for the water sector, $1.7 billion for oil, $739 million for health services, and $99 million 

for education.9 Approximately 67% of the funds were aimed at improvements in infrastructure—

including electricity, oil production, water and sewerage, transportation, and telecommunications—in 

order to stabilize the country by creating jobs and stimulating the economy.10

Project Origins

In March 2004, the western Iraq city of Falluja was a hotbed of Sunni insurgent activity, with 

increasing numbers of attacks against U.S. and Coalition Forces, contractors, and civilians. On 

March 31, 2004, insurgents ambushed and killed four U.S. private security contractors in the city,

dragged the charred bodies through the streets, and hung the bodies from the Old Bridge11

 5 Ibid.

spanning 

6 SIGIR, Hard Lessons: The Iraq Reconstruction Experience, Washington D.C., 2/2009. 7 The White House President George W. Bush, ed. Office of the Press Secretary, “President Addresses the Nation,” 

9/7/2003, http://georgewbush-whitehouse.archives.gov/news/releases/2003/09/print/20030907-1.html, accessed 

10/25/2011.

8 United States Department of State, Rebuilding Iraq: U.S. Achievements through the Iraq Relief and Reconstruction Fund,

2/2006.

9 Report to Congress, Submitted pursuant to U.S. Policy in Iraq Act, Section 1227 of the National Defense Authorization 

Act for Fiscal Year 2006 (PL 109-163), 4/6/2006. 10 Congressional Research Service Report for Congress, Iraq: Recent Developments in Reconstruction Assistance, Updated 

12/20/2004.

11 In April 2006, the GOI refurbished and re-dedicated the bridge as the “King Faisal” bridge.
3

the Euphrates River.12 In response to this incident, U.S. Marines initiated Operation Vigilant Resolve

to apprehend the assailants and attack insurgent positions throughout the city.13 The operation resulted 

in an estimated 600 Iraqi civilian deaths14, 1,250 wounded15

As a result, Falluja was one of the 10 strategic cities that the CPA identified—Baghdad, Ba’quba, 

Mosul, Ramadi, Samarra, Tikrit, Najaf, Diwaniyah, and Kerbala were the others—to fund “highimpact, high-visibility projects” aimed to improve access to potable water, sanitation, health, 

education, and transportation. According to a government study, the strategy was to “focus

reconstruction efforts on rapidly rehabilitating areas, such as Falluja, which had been the scene of 

intense military operations against insurgent forces. U.S. officials argued that the post-battle 

reconstruction effort was as important as the military effort to insure long-term Iraqi government 

control of these strategic cities.”

, and left the city in shambles. 

16

In planning these projects in 2004, U.S. officials asked the GOI what could be done in Falluja to help 

rebuild the city. The GOI requested a comprehensive sewage system because the city did not have 

one. At the time, residents used either buried holding tanks to collect and store waste, with the septic 

holding tanks being vacuumed out by a tank truck and disposed of off-site; or connected their home 

septic holding tanks to the storm water collection system, which resulted in the disposal of waste 

directly into the Euphrates River. The discharge of raw sewage into the Euphrates River contaminated 

the river water that the public used for several purposes, including as a source of drinking water. Due 

to insurgent activity throughout the city, the septic tank trucks were not operating, and holding tanks 

overflowed, which resulted in sewage running through city streets (see Figure 1). These conditions 

posed a serious health risk to children, who often played in the streets.

 

 12 Department of the Navy, United States Marine Corps, U.S. Marines in Iraq, 2004-2005: Into the Fray, History Division,

U.S. Marine Corps, Washington, D.C., 2011.

13 Matt M. Matthews, Operation AL FAJR: A Study in Army and Marine Corps Joint Operations, Combat Studies Institute 

Press, Fort Leavenworth, Kansas, 2006.

14 United States House of Representatives, Committee on Oversight and Government Reform, Majority Staff, Private 

Military Contractors in Iraq: An Examination of Blackwater’s Actions in Fallujah, 9/2007. 15 Tao-Hung Chang, The Battle of Fallujah: Lessons Learned on Military Operations on Urbanized Terrain (MOUT) in 

the 21st Century, Department of Naval Science, Rochester, 2007. 16 Congressional Research Service Report for Congress, Iraq: Recent Developments in Reconstruction Assistance, updated 

12/20/2004.
4

Figure 1—Raw Sewage in Falluja Streets

Source: Sewage flowing throughout Falluja city streets (Photo courtesy of the U.S. Army Corps of Engineers, circa 2004).

According to a UNICEF report, by 2003, “diseases associated with poor sanitation, unsafe water, and 

unhygienic practices increased at alarming rates, contributing to a fast-growing problem of 

malnutrition, morbidity, and mortality of infants and under-five-year-old children.” In that year alone, 

“diseases associated with poor water and sanitation were the cause of 25% of all child deaths in Iraq.” 

For example, “under-five mortality rates per 1,000 live births rose from 56 between 1984 and 1989, to 

92 between 1989 and 1994, and as high as 131 during the 1994 to 1999 period. Infant mortality rates 

per 1,000 live births increased from 47 between 1984 and 1989 to 79 between 1989 and 1994, and as 

high as 108 in the 1994 to 1999 period.”17

The GOI had requested a sewer network system that would consist of a wastewater treatment plant, 

collection areas (including house connections), trunk lines, and associated pump stations that would 

provide service to most of Falluja’s residents. 

 17 Brendan Doyle, Iraq Watching Briefs–Water and Environmental Sanitation, UNICEF, 7/2003.
5

Figure 2—March 2004 Falluja Site Plan

Source: The CPA’s original scope for the Falluja WWTS project (courtesy of USACE).

Project Goals

According to CPA documents, the intent of the project was to provide a sewage treatment facility for 

100,000 residents. However, a task order scope of work stated that the intent of the project was to 

“reduce the contamination effects on the receiving waters in Nahr al-Furat.”18

In addition, this project addressed the CPA goal of focusing on large infrastructure projects that would 

provide stability by increasing essential services, such as sewage treatment. At the time the project 

was initiated, Falluja was widely considered the most dangerous place in Iraq. The CPA awarded this 

project as a “carrot” to stabilize the local population by providing an essential service and jobs to 

Falluja residents. 

 Specifically, the project 

would effectively collect and treat most sewage for the city of Falluja, thereby, removing sewage from 

the city streets and depositing treated wastewater into the Euphrates River. This was expected to result 

in a decline in diseases associated with poor sanitation and unsafe water and an improved standard of 

living.

 18 Nahr al-Furat is the Arabic word for the Euphrates River.
6

One administration argument for the November 2003 supplemental appropriation was the urgent need 

to demonstrate progress so as to employ Iraqis and win their hearts and minds.19

Funding Sources

 In order to 

accomplish this, the CPA required FluorAMEC to employ a large number of Iraqis while completing 

the project within 18 months. 

Although originally funded through IRRF, the government incrementally used other funding sources

including the Development Fund for Iraq (DFI), the Commander’s Emergency Response Program 

(CERP), and the Economic Support Fund (ESF). Table 1 shows the current estimated cost of the 

project and the amounts of money allocated from each fund type. As shown in the chart, $100 million 

had been disbursed through July 8, 2011, and the U.S. government plans to spend an additional 

$7.8 million on the project. 

Table 1—Total Project Costs by Funding Category, as of 7/8/2011

Fund Type

Number of 

Contracts Costs

IRRF 23 $79,338,971.95

CERP 9 $11,326,731.52

DFI 7 $8,037,706.10

ESF 3 $1,320,425.00

Subtotal 42 $100,023,834.57

Expected Remaining Costs

(ESF grant) $6,839,000

Future Cost (O&M Training 

Grant) (ESF contracts) $1,000,000

Total 42 $107,862,834.57

Source: ISPO as of July 8, 2011.

Key Government Agency Roles

Several agencies were involved in program and project management and contracting, for the design 

and construction of the Falluja Waste Water Treatment System.

Program Management

The Coalition Provisional Authority (CPA) created the Program Management Office (PMO), which

was responsible for program management, project management, and contracting for the reconstruction 

effort in Iraq. On June 28, 2004, when power transferred to the sovereign Iraqi Interim Government, 

the CPA was officially dissolved. The PMO split into two organizations: the Iraq Reconstruction 

Management Office (IRMO) was responsible for coordinating the reconstruction effort, and the 

Project and Contracting Office assumed PMO’s project construction and execution responsibilities. 

 19 Congressional Research Service Report for Congress, Iraq: Recent Developments in Reconstruction Assistance, updated 

12/20/2004.
7

IRMO’s responsibilities included strategic planning, prioritizing requirements, monitoring spending, 

and coordinating with the military commander. IRMO was succeeded by the Iraq Transition 

Assistance Office (ITAO), another temporary office established to “perform the specific project of 

supporting executive departments and agencies in concluding remaining large infrastructure projects 

expeditiously in Iraq, in facilitating Iraq’s transition to self-sufficiency, and in maintaining an effective 

diplomatic presence in Iraq.” Finally, ITAO was succeeded by the Iraq Strategic Partnership Office 

(ISPO), which was established to support executive departments and agencies in facilitating the 

strategic partnership between the U.S. government and the GOI, in further securing and stabilizing the

country, and in continuing an effective diplomatic presence in Iraq. 

In this report, we collectively refer to CPA, PMO, IRMO, ITAO, and ISPO as the program office.

Project Management and Contracting

PCO facilitated acquisition and project management support for U.S. government-funded 

reconstruction projects. The office’s responsibilities included contracting for and delivering 

infrastructure, related services, and supplies. The U.S. Army Corps of Engineers (USACE) activated 

the Gulf Region District. For efficiency, the Gulf Region District and the Project and Contracting 

Office merged on December 4, 2005. On October 14, 2006, the Project and Contracting Office’s 

mission officially ended, and the Gulf Region District was appointed as its successor. In this report 

SIGIR refers to USACE and the Gulf Region Division collectively as the Corps.

The Joint Contracting Command–Iraq/Afghanistan also provided contracting support of vital supplies, 

services, and construction to the Chief of Mission and the U.S. military. Fragmentary Order 09-668, 

Contracting and Organizational Changes, created the Command on November 12, 2004, to provide 

services in support of Iraq relief and reconstruction. 
8

After Seven Years, the Falluja Project Remains 

Incomplete

As noted, at the time of this report, the U.S. government had invested, or planned to invest, $107.9 

million to construct the Falluja Sewerage Network System and connect it to 9,116 homes.

20

• appreciate the volatile security environment

 The GOI 

has committed to spend at least $87 million more to complete the project as originally conceived. 

However, the entire network collection system will not be completed until at least 2014. SIGIR 

identified multiple reasons for the current status of the project, including that the program or project 

management offices failed to:

• realistically estimate total project costs and completion time frames

• identify adequate funding

• apply a consistent contracting strategy

• communicate with the appropriate GOI reconstruction officials

• recognize Falluja’s tribal customs

Volatile Security Environment

Initial reports indicated that Falluja was receptive to Coalition Forces when they entered Iraq in 

March 2003.21 However, on April 28, 2003, Saddam Hussein’s birthday, several hundred local Falluja 

residents marched to a schoolhouse in the center of the city to protest the presence of the U.S. military 

in the city. As the protestors approached the school, unidentified shots were fired. U.S. troops 

believed they were being fired upon and opened fire on the large crowd of angry Iraqis22, killing 13 

people and injuring 75 others.23 According to a research center on international issues, the Anbar 

province is a traditional tribal area subscribing to strict tribal laws. Because Falluja residents believed 

that the U.S. military had killed some of their own, they were then honor-bound to exact revenge.

24 

Some credit this event as the birth of the Iraqi insurgency.25

Blackwater Incident and Operation Vigilant Resolve

 

By September 2003, Falluja had a broken economy, tribal war, and was considered by some as the 

“most hostile place in Iraq.”26

 20 As of September 18, 2011, 6,000 homes were connected to the waste water treatment plant. A grant was in place to 

connect a total of 9,116 homes to the system. GOI’s Ministry of Municipalities and Public Works was overseeing 

completion of connections to all 9,116 homes.

 On November 2, 2003, in the single deadliest strike on U.S. forces 

since the war began, insurgents shot down an American Chinook helicopter near Falluja, killing 

21 Institute for Defense Analyses, The Battle for Fallujah: Al-Fajr–the Myth-buster, 9/2009. 22 Time Magazine, “In Fallujah, Where the Dead Have Become Martyrs,” 10/8/2010. 23 Colonel John A. Weil, The Battle for Fallujah: One Soldier’s Memoir, Arizona Attorney, July/August 2005. 24 Institute for Defense Analyses, The Battle for Fallujah: Al-Fajr–the Myth-buster, 9/2009. 25 Ibid. 26 Tao-Hung Chang, The Battle of Fallujah: Lessons Learned on Military Operations on Urbanized Terrain (MOUT) in

the 21st Century, Department of Naval Science, Rochester, 2007.
9

16 U.S. soldiers and injuring 21 others.27

A flashpoint of insurgent attacks occurred on March 31, 2004, when insurgents ambushed four 

Blackwater security contractors who had taken a shortcut through Falluja during a supply run for a 

United Nations food contractor.

 Throughout the remainder of the year and into the following 

year, Falluja continued to be a hotbed of insurgent activity against Coalition Forces, civilians, and 

contractors. 

28 The contractors died amid a volley of hand grenades. A mob 

gathered, desecrated the bodies, and set them afire. Crowds then dragged the charred bodies through 

the streets and hung them from the nearby Old Bridge spanning the Euphrates River.29 A sign read, 

“Fallujah [sic] is the graveyard for Americans.”30 In the aftermath, local universities reportedly 

endorsed the violence and Falluja imams refused to explicitly condemn the killings.31

In response to this event, on April 5, 2004, the U.S. Marines launched Operation Vigilant Resolve with 

the intent of apprehending the assailants. Two Marine battalions began a series of deliberate attacks 

against insurgent positions throughout the city.

 

32 Under pressure from the Iraqi Governing Council 

and the CPA, on April 9, 2004, a ceasefire was ordered.33 The operation ended with an agreement that 

the Marines would leave the city and transfer the security responsibility to a local force, the “Falluja 

Brigade”34 to collect weapons from insurgents. By the end of the operation, an estimated 600 Iraqi 

civilian were killed35, 1,250 were wounded36

 27 Center for Strategic and International Studies, Low Intensity Conflict and Nation-Building in Iraq: A Chronology, 

10/19/2005.

, and the city was in shambles. 

28 Tao-Hung Chang, The Battle of Fallujah: Lessons Learned on Military Operations on Urbanized Terrain (MOUT) in 

the 21st Century, Department of Naval Science, Rochester, 2007.

29 Department of the Navy, United States Marine Corps, U.S. Marines in Iraq, 2004-2005: Into the Fray, History Division, 

U.S. Marine Corps, Washington, D.C., 2011. 30 Center for Strategic and International Studies, Low Intensity Conflict and Nation-Building in Iraq: A Chronology,

10/19/2005.

31 Carter Malkasian, Center for Naval Analyses, “Signaling Resolve, Democratization, and the First Battle of Fallujah,” 

The Journal of Strategic Studies, Volume 29, No. 3, 423-452, 6/2006. 32 Matt M. Matthews, Operation AL FAJR: A Study in Army and Marine Corps Joint Operations, Combat Studies Institute 

Press, Fort Leavenworth, Kansas, 2006.

33 Department of the Navy, United States Marine Corps, U.S. Marines in Iraq, 2004-2005: Into the Fray, History Division, 

U.S. Marine Corps, Washington, D.C., 2011.

34 The Falluja Brigade was established in April 2004. The Marines withdrew to the outskirts of Falluja, and the Falluja 

Brigade, consisting of Saddam-era Iraqi military leaders, Falluja residents, and former insurgents, was tasked with bringing 

peace to the city and meeting several demands, such as collecting weapons from insurgents. 

35 United States House of Representatives, Committee on Oversight and Government Reform, Majority Staff, Private 

Military Contractors in Iraq: An Examination of Blackwater’s Actions in Fallujah, 9/2007. 36 Tao-Hung Chang, The Battle of Fallujah: Lessons Learned on Military Operations on Urbanized Terrain (MOUT) in 

the 21st Century, Department of Naval Science, Rochester, 2007.
10

According to The Journal of Strategic Studies, the local perception was that insurgents in Falluja had 

forced an embarrassing withdrawal upon the U.S. military. In addition, the insurgents’ point of view 

was that they attained their major military objective of keeping Coalition Forces out of Falluja. 

Further, in the minds of many Sunnis, the death and destruction resulting from this offensive now 

justified ordering a jihad against the Coalition.37

Most disturbing was the fact that this offensive did not clear Falluja of extremists and insurgents.38 

After the Marines pulled out of Falluja, the Falluja Brigade was not able to disarm all insurgents. By 

the end of April 2004, Falluja had become a lawless, chaotic place with insurgents in complete control 

of the city. Al-Qaeda leader, Abu Musab Al-Zarqawi, and local insurgent leaders, Abdullah Janabi 

and Omar Hadid, had turned Falluja into the supply center for terrorist and suicide bombers across 

Iraq.39

Amid this chaos, on June 26, 2004, the CPA awarded FluorAMEC a $28.6 million task order (Task 

Order 0008) to design, procure, construct, and commission the Falluja Sewerage Network System by 

February 2006. To initiate the design phase, FluorAMEC and its subcontractor needed to perform site 

surveys of the entire city, which was impossible. There were no Coalition Forces in the city, and the 

members of the only GOI security group then present, the Falluja Brigade, had either deserted or 

joined the insurgency.

 

40 Falluja had become an “insurgent sanctuary.”41

Operation Al Fajr (Phantom Fury)

Over the next several months, security within Falluja continued to deteriorate amid intensifying 

violence. The lack of a central government authority and Coalition Force presence allowed insurgents 

to establish in-depth fighting positions and obstacles throughout the city.42 U.S. military documented 

considerable insurgent activities, including an estimated 3,000 to 4,500 insurgents in the city43, the use 

of mosques, hospitals, and cemeteries as fighting and defensive positions, 306 identified defense 

positions, 203 major weapons storage areas, 11 improvised explosive device (IED) factories, and 3 

slaughterhouse/torture chambers.

44 Figure 3 shows U.S. military photographs of a weapons cache and 

torture chamber found in Falluja. The city had become a major insurgent command and control node 

and staging ground45 for an increasing number of attacks against Coalition Forces, civilians, and 

contractors. 

 37 Carter Malkasian, Center for Naval Analyses, “Signaling Resolve, Democratization, and the First Battle of Fallujah,” 

The Journal of Strategic Studies, Volume 29, No. 3, 423-452, 6/2006. 38 Ibid. 

39 Tao-Hung Chang, The Battle of Fallujah: Lessons Learned on Military Operations on Urbanized Terrain (MOUT) in 

the 21st Century, Department of Naval Science, Rochester, 2007. 40 Matt M. Matthews, Operation AL FAJR: A Study in Army and Marine Corps Joint Operations, Combat Studies Institute 

Press, Fort Leavenworth, Kansas, 2006.

41 Institute for Defense Analyses, The Battle for Fallujah: Al-Fajr–the Myth-buster, 9/2009. 42 Ibid. 43 Tao-Hung Chang, The Battle of Fallujah: Lessons Learned on Military Operations on Urbanized Terrain (MOUT) in 

the 21st Century, Department of Naval Science, Rochester, 2007. 44 IMEF and MNC-I Effects Exploitation Team, Telling the Fallujah Story to the World (Third Cut), 11/20/2004. 45 Carter Malkasian, Center for Naval Analyses, “Signaling Resolve, Democratization, and the First Battle of Fallujah,” 

The Journal of Strategic Studies, Volume 29, No. 3, 423-452, 6/2006.
11

Figure 3—Site Photograph of Weapons Storage and a Torture Chamber

Weapons cache found in a local mosque, November 2004. Blood stained walls of a torture chamber, November 2004.

Source: Photos courtesy of Multi-National Corps–Iraq, November 2004.

Table 2 shows the number of mosques, hospitals, and other facilities occupied by insurgents. 

Table 2—Major Insurgent-occupied Facilities in Falluja

Type of Facility Total Number

Mosques in Falluja 100

Mosques used as fighting positions/weapons caches 60

Hospitals used as defensive positions 3

Improvised explosive device (IED) factories 11

Slaughterhouse/torture chambers 3

Number of major weapons storage areas 203

Evidence of foreign fighter involvement 2

Source: Multi-National Corps–Iraq, November 2004. 

By October 2004, the security situation in Falluja was so hostile that the U.S. Marines put the Falluja

Waste Water Treatment System project on hold. The Marines wanted FluorAMEC to wait until after 

an upcoming operation before continuing with the project. In November 2004, Coalition Forces 

launched a second offensive, Operation Al Fajr, with the intent to eliminate Falluja as an insurgent 

sanctuary by destroying anti-Iraqi forces in order to establish legitimate local control.46

 46 Institute for Defense Analyses, The Battle for Fallujah: Al-Fajr–the Myth-buster, 9/2009.

 This operation 

saw intense fighting between Coalition Forces and insurgents. By the end of this operation, more than 
12

1,200 insurgents were killed and 1,000 captured47, while 70 American troops were killed and 

609 injured. 48 In addition, the Marines utilized tank gun fire, heavy machine guns, and air-delivered 

ordnance to root out insurgents. This left the city’s infrastructure in shambles as sewer and water lines 

were ruptured, storm-drain pumping stations were destroyed, electrical lines were cut, and 

transformers were blown.

49

Figure 4—Photograph of Falluja in November 2004

Figure 4 shows how Falluja looked in November 2004.

Source: Photo courtesy of USACE, November 2004.

December 2004–September 2007

While largely viewed as successful, Operation Al Fajr did not eliminate all terrorists from Falluja; 

pockets of insurgent strongholds remained throughout the city. In addition, insurgents who fled 

Falluja prior to the start of Operation Al Fajr returned later to continue the fight against Coalition 

Forces. According to a Marine colonel stationed in Falluja in December 2004, the city was largely a 

deserted, dark, and haunted place and the “smell of death was everywhere.”50

Yet, in the face of continued violence, the U.S. government pressed ahead with this major 

infrastructure project to improve the provision of an essential service. The hope was that the 

enhancement of essential services would help sustain military successes in the fight against the 

 47 American Forces Press Service, Fallujah Secure, but Not Yet Safe, Marine Commander Says, 11/18/2004. 48 Tao-Hung Chang, The Battle of Fallujah: Lessons Learned on Military Operations on Urbanized Terrain (MOUT) in 

the 21st Century, Department of Naval Science, Rochester, 2007.

49 William F. Mullen III, “Turning Fallujah,” Small Wars Journal, 2009. 50 Ibid.
13

insurgency.51 However, violence against Coalition Forces, Iraqi security forces, civilians, and 

contractors increased from late 2004 through mid-2007. Figure 5 indicates the number of total 

security incidents52 within Anbar province from 2004 through 2010. 53

As was seen throughout the rest of Iraq, violence soared in Anbar province after the February 2006 

bombing of the al-Askari Mosque golden dome, setting off a period of extreme sectarian violence. 

Violence in the province reached its peak in late 2006, with almost 4,500 security incidents occurring 

within a 90-day period. 

Figure 5—Total Security Incidents in Anbar Province between 2004 and 201054

Source: USF-I, 1/4/2011. 

Security Environment Caused Project Delays

While the project’s program office still wanted FluorAMEC to complete the plant within 18 months, it 

also advised the contractor that the U.S. military’s mission did not include providing security 

protection for civilians assigned to U.S. government agencies and contractors. Program office

officials expected FluorAMEC and its subcontractors to provide their own security to protect their 

 51 SIGIR, Hard Lessons: The Iraq Reconstruction Experience, Washington, DC: Government Printing Office, 2009. 52 USF-I, the author of the total security incidents information, included the following as total security incidents: attacks 

against Iraqi infrastructure and government organizations, found and cleared bombs, detonated bombs, sniper, ambush,

grenade, and other small arms attacks, mortar, rocket, and surface to air attacks.

53 USF-I provided SIGIR security incidents data based only on provinces, not individual districts within provinces. 54 USF-I provided the raw data for this figure in response to SIGIR’s data call on January 4, 2011.

0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

2004 Q12004 Q22004 Q32004 Q42005 Q12005 Q22005 Q32005 Q42006 Q12006 Q22006 Q32006 Q42007 Q12007 Q22007 Q32007 Q42008 Q12008 Q22008 Q32008 Q42009 Q12009 Q22009 Q32009 Q42010 Q12010 Q22010 Q32010 Q4
14

staffs against an insurgency that, between April and December 2004, had killed 151 U.S. troops and 

wounded more than a thousand.55

Notwithstanding a virtual flash flood of adverse circumstances across Iraq in 2004, the U.S. 

government retained its objective to quickly build large-scale infrastructure projects to improve 

conditions and win Iraqi support. In Falluja, the U.S. government wanted to provide sewage treatment 

in the hopes it would win over the population and increase stability in a broader area. Given this, it is 

clear that U.S. officials did not fully appreciate Falluja’s security environment and the impact it would 

have on FluorAMEC’s ability to design and construct the wastewater treatment system. Figure 6 

provides a military threat overview of Falluja in late 2004 and illustrates the magnitude of insurgent 

activities and strongholds. 

Falluja’s Highway 10 runs east to west, bisecting the city. Because the majority of the construction 

materials would be driven from Baghdad, on Highway 10, FluorAMEC and its subcontractors would 

have to navigate through an endless maze of insurgent concentration areas, insurgent defensive 

positions, weapons caches, checkpoints, roadblocks, sniper fire positions, small arms positions, and 

berms to deliver materials and equipment to project sites throughout the city. In addition, 

FluorAMEC’s task order required initial construction in Collection Area A which, according to the 

military threat overview, included a portion of an insurgent concentration, countless insurgent 

defensive positions, weapons caches, and roadblocks. In SIGIR’s view, the program office was 

unrealistic in expecting FluorAMEC and its subcontractors to maneuver throughout the city in support 

of this project without encountering significant resistance and hostilities from local insurgents.

 55 Tao-Hung Chang, The Battle of Fallujah: Lessons Learned on Military Operations on Urbanized Terrain (MOUT) in 

the 21st Century, Department of Naval Science, Rochester, 2007.
15

Figure 6—Falluja Threat Overview, 2004

Source: Institute for Defense Analysis, 9/2009.

Attacks against the Waste Water Treatment System Project

The Falluja Waste Water Treatment System project was not immune from the violence swirling 

around it. To the contrary, from the start, the project was plagued by security incidents, such as 

kidnappings of staff and their family members, hijackings of project materials, contractor intimidation 

and extortion, theft, equipment damage, small arms fire, injury, and death. Subcontractors attempting 

to conduct geo-technical and survey work were consistently hampered by confrontations with 

squatters, and one member of the survey party received a gunshot wound. Once construction began, 

one contractor’s senior managers were kidnapped and one was severely beaten. Several contractors 

left the country out of fear for their lives. In addition, one contractor was forced to share 10% of his 

earnings with terror groups.

2004–2007

56

 56 USACE, Summary Report, SS-016 Fallujah Waste Water System Project Update, 7/15/2008. 

 
16

The project suffered additional delays as contractors and the U.S. military had to deal with unexploded 

ordnance and IEDs throughout the city. According to a U.S. representative, insurgents planted 

unexploded ordnance at the planned site for the treatment facility, which required coordination with 

the military to clear before FluorAMEC could break ground. In addition, after subcontractors began 

trenching and installing pipes, insurgents planted IEDs in the trenches, which collapsed trenches and 

ruined pipes. Because trenching is a labor-intensive and time-consuming process, having to clear the 

trenches and then trench again added considerable time to the overall project. 

Throughout the greater part of this project’s first four years, the military had locked down the city for 

security purposes. For example, in April 2007, the U.S. Marines issued an order to suspend almost all 

trench work due to concerns over IEDs implanted in the trench area. This three-month security 

suspension on trenching affected work on the construction of four trunk lines, as well as the collection 

networks in Areas A, B, and C, which resulted in additional costs and extending overall project 

completion. And, for a period of time, the U.S. Marines did not allow movement of large equipment 

within the city. In instances where trucks were allowed into the city, Marines thoroughly searched 

them. For example, Marines required trucks hauling construction materials to the project sites, such as 

sand and gravel, to empty their contents onto the ground and then reload the contents back onto the 

trucks after being searched for explosives. According to a former U.S. official, this was a routine 

procedure in 2004 and 2005 and added considerable delays.

Anbar Awakening and the Surge

According to an international research group, Sunni insurgents from Anbar and foreign Sunni alQaeda fighters formed a strategic and tactical alliance against what was perceived as a U.S. military

occupation. Anbar residents provided local knowledge, logistics, and personnel to al-Qaeda leaders 

attacking Coalition Forces. However, opposition to al-Qaeda grew as the group increasingly targeted

Sunni tribal leaders for assassination and began taking control of money-making activities traditionally 

held by local tribes.57

It is difficult to identify the exact date or event that precipitated a change, but as early as 2005, local 

tribal leaders began establishing alliances with the U.S. military against al-Qaeda. In September 2006, 

an Iraqi-led coalition of Sunni tribal leaders publicly acknowledged their split from al-Qaeda and 

began working with the U.S. military to drive the insurgents out of Anbar province.

 

58

In January 2007, the U.S. military increased its forces in Iraq. A series of offensive operations focused 

on expanding the gains achieved in the preceding months in Anbar province. As Figure 5 indicates, by 

mid-2007, the number of attacks in the province was at its lowest point since 2004. 

 

Yet, while violence as a whole was down considerably in Anbar province, violent incidents against 

this project did not let up. In 2007, a Corps briefing chart identified growing security concerns in the 

area. Specifically, the briefing chart stated, “local security situation – contractors threatened/

ambushed/murdered, Title II Contractor offices ransacked, PSD [personal security detail] staff 

murdered on mission, Vendors refuse to deliver to Falluja...” During 2007, at least five of 17 

contractors stopped work due to security concerns. 

 57 John A. McCary, “The Anbar Awakening: An Alliance of Incentives,” The Washington Quarterly (Center for Strategic 

and International Studies), 1/2009. 58 Ibid. 
17

2008–Present

Security vastly improved in all of Anbar province, including Falluja, in 2008. However, the area is 

still very dangerous. In May 2009, three U.S. reconstruction officials returning from the Falluja 

wastewater treatment plant were killed by an IED. 

Even though security has improved since mid-2007, contractors continue to face intimidation and 

threats, and U.S. reconstruction officials cannot visit project sites with the frequency and duration 

needed to fully manage a project of this magnitude and importance.

Unrealistic Project Cost Estimates and Completion Time Frames

According to U.S. officials, extremely poor security conditions prevented them from visiting the 

proposed wastewater treatment plant site prior to awarding the contract. However, at least one, if not 

several, site visits are critical to adequately assess site conditions for construction. At the time of the 

contract award, the program office knew only that sewage was flowing in Falluja’s streets. 

The inability to visit the project site led to unforeseen construction issues that, in turn, caused delays 

and higher costs. To illustrate, the contractor’s network design included areas of deep trenching but

U.S. officials were not aware of the high water table, which should have been considered in the 

project’s design. Nevertheless, the designs were approved. When construction began, excavated areas 

throughout the city would flood overnight and have to be pumped out before construction could 

resume. Due to possible cave-ins at excavation sites, expanded excavation was required. 

Additionally, because there were no early site visits, FluorAMEC was unaware that the site contained 

unexploded ordnance until it arrived at the location. This resulted in construction delays as the 

Marines had to first clear the site before the contractor could start construction. 

U.S. officials stated that internal pressures led to unrealistic total project cost estimates and completion 

time frames. According to one official, the U.S. government wanted to quickly rebuild Iraq; 

consequently, the program office was told to obligate money quickly. However, from the time PMO 

arrived in Iraq, it was behind schedule in obligating reconstruction funding. PMO officials stated the 

emphasis became obligating money quickly. As a result, PMO did not prepare comprehensive project 

cost estimates. On June 25, 2004, the day before the contracting office awarded the task order to 

FluorAMEC, it prepared a total project cost estimate of $35,385,868—an amount almost identical to 

the $35 million in funding available for this project. U.S. officials said that the $35.3 million total 

project cost estimate was done to justify FluorAMEC’s task order. 

One U.S. official stated that if “you take all the original PIFs [Project Identification Forms] for 

projects in Iraq and look at them now, they will all be way off.” A September 2005 GAO report 

confirmed this. GAO reported that the CPA’s initial assessments for the water sector had 

underestimated water-project costs by 25% to 50%.59

 59 GAO Report GAO-05-872, Rebuilding Iraq: U.S. Water and Sanitation Efforts Need Improved Measures for Assessing 

Impact and Sustained Resources for Maintaining Facilities, 9/2005.

 In the case of the Falluja Waste Water 

Treatment System project, the discrepancy was even larger. For example, in March 2005, 

FluorAMEC estimated that the project would cost at least $51.3 million, and that amount would fund 

only a limited portion of the project.
18

In addition, former U.S. officials stated that completion time frames were similarly unrealistic. The 

original task order required FluorAMEC to complete the entire system within 31⁄2 years. However, as 

previously mentioned, the U.S. government wanted to quickly rebuild Iraq, so prior to issuing the task

order, it accelerated the required completion time to 18 months (February 2006). Yet, because

Falluja’s security conditions did not allow for starting construction until early 2005, FluorAMEC had 

less than one year to complete the project. 

Funding Varied

From June 2004 through September 2011, the projected cost of this project increased based upon the 

amount of funding available and the associated changes in project scope. Figure 7 shows the 

relationship between the funding available and the project’s cost growth.

Figure 7—Graph Comparing Funding to Cost Growth ($ in millions)

Note: 

By September 2011, the U.S. government had utilized four funding sources to award 42 individual contracts and grants, worth approximately 

$107.9 million (see Table 1). 

Source: SIGIR review of Corps briefing charts 2006-2009 and ISPO documentation. 

SIGIR found that the projected completion costs varied significantly over time without explanation. 

For example, the Corps’ April 2006 briefing charts provided four options for completing the project. 

Each option contained specific features (such as the number of collection lines, trunk lines, pump 

stations, and wastewater trains) and the associated cost. Full build-out was estimated to cost 

$112.2 million and would require the construction of all collection lines, trunk lines, pump stations, 

$0.0

$20.0

$40.0

$60.0

$80.0

$100.0

$120.0

2004 2005 2006 2007 2008 2009 2010 2011

Cost

Funding
19

and a four-train facility (that is, the original project scope),. However, three months later, the Corps 

stated that full build-out would cost $140 million. The Corps’ briefing charts provided no rationale for 

the $27.8 million increase in just three months. In July 2006, the U.S. government favored the 

“Baseline Plus” option, which was listed at $76.3 million. Yet, in August 2006, the project costs 

increased to $84.24 million.

SIGIR requested the underlying support for these completion estimates from the Corps; however, at 

the time of this report, SIGIR had not received this information. 

Lack of Adequate Funding

On June 21, 2004, the PCO Director requested that the Department of the Army release $35 million to 

execute the Falluja project. Former U.S. officials involved with this project stated that, from their past 

experiences with the CPA, the CPA often married individual projects with available funding and, in 

their opinion, this project was no exception. Awarding this type of project based on available funding,

instead of a comprehensive project cost estimate meant that the CPA started the project without 

knowing if there was adequate funding to complete it. A comprehensive, detailed total project cost 

estimate, based on actual field conditions, would have alerted the program office that this project 

would require considerable additional funding to complete even a portion of the work. However, the 

PMO’s cost estimate significantly underestimated project costs, which led the CPA to not seek 

additional funding for the project or limit the project’s scope. 

In March 2005, FluorAMEC notified the program office that it would not be possible to construct a 

sewer network system within the budgeted amount of $35 million. Instead, FluorAMEC 

recommended constructing only a fraction of the project at almost double the cost ($51.3 million). By 

this time, however, the program office did not have additional funding in place to cover the increased 

project cost. In 2005, a strategic review cut $2.2 billion from the water sector, which further limited 

the amount of funding available to complete existing water sector projects.60

The lack of adequate project funding required the program office to de-scope a significant portion of 

this project while trying to fund the approved work piecemeal and only as limited funding became 

available. 

 

Additional Funding Sources

By mid-2005, IRMO decided to continue the project but recognized that the U.S. government would 

not be able to fund the entire sewer network system. During the second half of 2005 and early 2006, 

IRMO identified additional funding to complete a portion of the project. The funding included 

$18 million from the DFI, $9 million from CERP, and additional IRRF funds reprogrammed within 

the IRRF water sector budget. By August 2006, the program office had allocated a total of 

$84.4 million to the project.

DFI Issues

In December 2005, then-Minister of Finance, Allawi, authorized the program office to allocate 

$18 million in DFI funding for the Falluja project and extended the original DFI program to the end of 

 60 SIGIR, Hard Lessons: The Iraq Reconstruction Experience, Washington, DC: Government Printing Office, 2009.
20

2006. Between February and August 2006, the program office awarded 11 contracts, in the amount of 

approximately $15.6 million, in support of the project. 

Originally envisioned as a major financial resource for this project, the DFI funding ultimately became 

a significant obstacle. By August 2006, the Ministry of Finance was not paying DFI contractors for 

work performed. The ministry rejected invoice packages for payment, according to program office 

representatives, regardless of the content or presentation of those packages. Further aggravating the 

problem was that the ministry would not identify exactly what was required for payment. This had a 

direct impact on project status. 

By October 2006, the Corps’ field representatives reported that “2 more contractors in Falluja...have 

stopped work” because they had not been paid. As a result, some of the DFI-funded construction work 

ceased, and some of the equipment procurement contractors refused to execute their contracts. The 

subsequent work stoppages and lack of equipment affected progress on the IRRF- and CERP-funded 

contracts. 

By mid-2007, the situation with the DFI-funded contracts became untenable. Four construction 

contractors had outstanding invoices in excess of $3 million. In December 2007, the contracting office

terminated the DFI contracts and awarded new contracts for the remaining work using additional IRRF 

funding. However, the IRRF funding could not be used to pay outstanding invoices. As of 

August 2008, five DFI contracts had outstanding balances of $2,331,532.61

Constantly Evolving Scope of Work

 From the summer of 2006 

through 2009, this project experienced significant construction delays due to the ministry’s nonpayment of DFI-funded contracts. 

The lack of adequate initial funding resulted in program office officials trying to accomplish as much 

of the original project scope as possible with the amount of available funding. The program office 

constantly adjusted the project’s scope to match the funding available at the time. 

In March 2005, the program office realized it did not have the funding to complete the original project 

scope. Over the next 32 months, program office officials created countless briefing charts and 

memoranda documenting alternative project scope and cost proposals. For example, in April 2006, the 

Corps provided four project scope options: Baseline, Option 1, Option 2, and Full Build Out. The 

costs associated for each option ranged from $55.5 million to $112.2 million. Yet, a way forward was 

not selected because the program office was constantly chasing additional funding sources to complete 

the largest amount of project scope possible. To illustrate, in April 2006, the program office had 

$55.3 million in available funding. This amount was sufficient to select and implement the Baseline 

option. Rather than doing so, the program office focused on finding additional funding sources to 

increase the project’s scope. As a result, it did not agree to a project scope until November 2007. 

The program office encountered multiple challenges attempting to complete the November 2007 

project scope—contractor underperformance, difficult site conditions, limited access to sites, and 

complexity of house connections. In an October 2008 inspection, SIGIR identified several shortfalls 

of the current project scope, including a lack of house connections, consumables, and training.62

 61 SIGIR PA-08-144-148, Falluja Waste Water Treatment System, Falluja, Iraq, 10/27/2008.

 The 

62 SIGIR PA-08-144-148, Falluja Waste Water Treatment System, Falluja, Iraq, 10/27/2008.
21

program office changed the project scope in 2009 to complete an expandable “back-bone” system, 

which decreased the number of homes within the three collection areas and reduced the number of 

trunk lines. In 2010, the program office utilized a fourth funding source, the ESF, to provide 9,116 

house connections and fund a future operations and maintenance training program. 

Changed Contracting Strategies Further Delayed and Increased 

Construction Costs

In 2004, the CPA contracting strategy was to enter into very large open-ended contracts called 

design/build contracts. Design/build contractors were awarded indefinite delivery/indefinite quantity 

cost-plus contracts for design, engineering, and construction work in sectors, such as water, electricity, 

and oil. The original design/build contracts were broad contract documents with large spending caps. 

For example, FluorAMEC’s design/build contract for public works/water projects in the north had a 

$600 million ceiling. As projects were approved, the CPA awarded task orders against these broad 

contracts for the construction of specific facilities. The CPA awarded the Falluja Waste Water 

Treatment System project as a task order against FluorAMEC’s larger design/build contract. Over 

time, this strategy changed to address the problems associated with huge and costly design/build 

contracts. In so doing, however, new problems were created.

New Execution Strategy—Iraqi First

In mid-2005, the U.S. government moved away from large design-build contracts because most

projects ended up over budget and behind schedule.63

In support of the Iraqi First program, the program office decided to break up the project into separate 

components and award a large number of contracts to Iraqi contractors capable of working in Falluja. 

Eventually, the program office awarded 42 contracts for engineering design support, construction, and 

equipment procurement. Breaking down the project into a large number of small- and mid-sized 

contracts was proposed for several reasons. First, the project office was uncertain how much of the 

planned project could actually be constructed with the available funding. As such, the project was 

divided into a set of severable components that, as funding became available, were purchased. In 

addition, in 2006, the program office was utilizing three separate funding sources—the IRRF, CERP, 

and DFI— that could not be mixed. Because each funding source varied in size, the components 

needed to be severable and of varying sizes. Finally, because the DFI funds were authorized for only 

2006, all DFI-funded activities had to be completed that year. 

 Consequently, the program office de-scoped the 

FluorAMEC task order in July 2005. In place of the design-build model, the program office initiated 

the “Iraqi First” program, which sought to encourage Iraqi economic expansion, entrepreneurship, and 

individual development. The hope was that Iraqi contractors would rebuild the country by procuring 

supplies and services locally. 

Even though there was rationale for dividing the project into a number of components for execution, 

the segmentation of the project created complex interdependencies. Some of the contracts, such as the 

earthworks at the wastewater treatment facility, needed to be completed before construction of the 

plant could commence. In addition, some of the key equipment for the project was purchased 

separately from the construction contracts. As a result, failure to execute certain contracts adversely 

 63 SIGIR, Hard Lessons: the Iraq Reconstruction Experience, Washington, DC: Government Printing Office, 2009.
22

impacted other contracts and then eventually the project overall. For example, the Ministry of 

Finance’s refusal to pay DFI-funded contract invoices in late 2006 resulted in work stoppages of 

critical path construction contracts. Specifically, the earthworks contractor left the project site over 

the non-payment of more than $1.3 million in invoices, which delayed the start of the construction of 

the facility.

Figure 8 illustrates the complexity of this project in terms of interdependence between only the 

construction contracts while also identifying the multiple types of funding sources (as of 

October 2008). 

Figure 8—General Layout, Project Components, and Funding Sources

Source: From USACE briefing chart, 2008.

Limited Oversight of Contractors

In addition to creating complex interdependencies, the segmentation of the project and the award of 

individual contracts required construction throughout the still very dangerous city. A former Gulf 

Region District commander stated that it made no sense to award a contract and require the contractor 

to begin construction throughout a city that was not secure. In addition, the program and contracting 

offices did not have sufficient numbers of staff to provide the necessary oversight of inexperienced 
23

Iraqi contractors. To illustrate, because of security and an insufficient number of staff, the program 

and contracting offices did not visit specific areas of Falluja, so they provided no oversight of the 

construction activities occurring in those locations. The former Gulf Region District commander 

stated it would have made more sense to concentrate efforts in completing one portion of the project at 

a time. For example, the contracting office could have awarded the contract for the wastewater

treatment facility first. It would have been easier to provide security for one specific area in order to 

complete construction, rather than worrying about dozens of construction projects at a single time. 

Final Project Scope and Cost Decisions Delayed

From August 2006 through March 2007, U.S. officials discussed several different funding proposals 

and alternative options for the overall system. Between January 2007 and October 2007, at least 

20 separate briefing charts, information memoranda, decision briefs, and emails were created to 

provide four potential courses of action. But the program office still had not made a decision. The 

ITAO Senior Consultant for Water expressed her frustration by stating the “decision is in fact long 

overdue and I don’t think it should languish any longer.” 

In November 2007, more than 31⁄2 years after the contracting office awarded the design/build task 

order to FluorAMEC, and two years after agreeing to the type of system to be built, the program office 

secured enough funding to define the ultimate project scope. With approximately $97 million from 

various funding sources, the program office decided to construct a “back-bone” system, which 

included a four-train wastewater treatment facility, three pump stations, three trunk lines, and three 

collection areas (with no house connections). 

Lack of Communication with Appropriate GOI Reconstruction Officials 

According to the Ministry of Municipalities and Public Works64

FluorAMEC’s task order included a requirement to meet with Falluja engineers, local government 

public works officials, and consultants “familiar with the city’s needs.” However, according to a 

former program office official, a significant problem was that “you couldn’t always identify who 

[within the GOI] was in charge.” The two most prominent players for this project were the Falluja 

representatives, the GOI’s original 

request for a sewer network system included a mechanical sludge process wastewater treatment 

facility. During the Oil for Food program, the GOI purchased 10 compact mechanical sludge units,

intending to utilize those units for newly constructed wastewater treatment plants around the country. 

However, from the start of this project, the CPA wanted a different type of treatment system—known 

as a lagoon system—because it was less expensive to construct, required less power to operate, had 

lower operation and maintenance costs, and required minimal labor. Consequently, FluorAMEC’s 

task order identified the type of system to be built as an “oxidation lagoon”-style wastewater treatment 

facility. The CPA advised FluorAMEC that, in the 1980s, a local Iraqi consulting firm conducted a 

geotechnical investigation of Falluja and prepared a wastewater treatment plant and sewer network 

design for the city. In an effort to reduce costs, the CPA recommended that FluorAMEC use this 

information for the preliminary design. The local Iraqi consulting firm’s design included a lagoonsystem treatment plant, which FluorAMEC incorporated into its design. 

 64 The Ministry of Municipalities and Public Works is responsible for the delivery of safe drinking water, environmental 

sanitation (wastewater and solid waste) services, urban development, municipal road work, and public land management.
24

Reconstruction Council, with Sunni representatives, and the Ministry of Municipalities and Public 

Works, with Shia representatives from Baghdad. The former program office official stated there was 

deep-rooted animosity between the local council representatives and ministry officials because of their 

different religious affiliations that led to major disagreements about the project. 

Project file documentation included emails in late 2004 between U.S Marine units stationed in Falluja 

and program office personnel. One email stated “Go with the oxidation pond [lagoon system]. That is 

what the locals have asked for.” While not explicitly stated, it appears the “locals” referred to in the 

email was the Falluja Reconstruction Council. The Falluja Reconstruction Council was responsible 

for assessing and addressing the city’s needs and proposing potential projects, while the ministry was 

responsible for approving the design and construction of all new water and sanitation projects in 

Falluja. 

Ministry representatives stated that U.S. officials never identified the type of sewage treatment plant to 

be constructed. Because the GOI requested the project, the ministry assumed it would be a mechanical

sludge-process system. According to a former program office official, the program office “probably 

did not consult with” the ministry prior to deciding upon the lagoon system. As a result, the ministry 

did not become aware that FluorAMEC was designing a lagoon system until August 2005, more than 

14 months after the start of this project. The ministry immediately rejected the lagoon system, instead 

proposing the use of four compact mechanical sludge units. SIGIR asked ministry representatives why 

they rejected a lagoon system since it was based upon an existing Iraqi design. Ministry 

representatives stated the GOI never approved the local Iraqi consulting firm’s original design due to 

“significant design problems.” The program office ultimately agreed to change the design to a 

mechanical sludge system, however, this required a comprehensive redesign of the system, which 

significantly increased the cost of the project and extended the completion time frame. 

Falluja’s Tribal Customs Further Delayed Construction

According to a Department of Defense study, “Tribes are perhaps the oldest, most enduring and 

controversial social entities in the Middle East...A tribe is a social structure consisting of a number of 

families, clans, or other groups who share a common ancestry (real or perceived) and culture...The 

tribe provides protection, representation, and a sense of identity for its members...Tribes have played 

a central role in the history of Iraq for thousands of years and continue to do so today.”65 The 

population of Anbar province, and its two largest cities, Ramadi and Falluja, is known for its strong 

tribal and religious traditions.66

Fallujans did not easily accept or allow outsiders to come in. This attitude is not only directed at 

Coalition Forces, but also at any Iraqis who are not specifically from Falluja.

 

67

 65 Global Resources Group, Iraq Tribal Study–Al-Anbar Governorate: The Albu Fahd Tribe, The Albu Mahal Tribe and 

the Albu Issa Tribe, 6/18/2006.

 This project witnessed 

the volatile tensions that exist between residents of Falluja and “outsiders.” The program office 

awarded a contract to construct a pump station to a Baghdad-based contractor. While departing from a 

Pre-Construction Meeting in Falluja, three of the company’s engineers were ambushed; two engineers 

were killed and the third was seriously wounded. The message was that outsiders were not welcome 

66 Department of the Navy, United States Marine Corps, U.S. Marines in Iraq, 2004-2005: Into the Fray, History Division, 

U.S. Marine Corps, Washington, D.C., 2011.

67 William F. Mullen III, “Turning Fallujah,” Small Wars Journal, 2009.
25

to work in the city—even if they were attempting to help construct a wastewater treatment system for 

the city’s residents. 

As a result, the program office was left with few options other than to award all of the contracts to 

local contractors and subcontractors. However, the CPA noted in its original project justification that 

the city of Falluja had never had a comprehensive sewer system; therefore, it was unrealistic to expect 

to find local contractors capable of building such a system. The program office found a very limited 

pool of inexperienced contractors capable of working in Falluja from which to select. Former Corps 

officials stated there were continuous quality issues due to “cheap and inexperienced subcontractors 

and general inexperience on structures of this size and complexity.” Each quality issue added to 

construction delays. Further, former Corps officials stated that most contractors and subcontractors 

associated with this project did not have the required technical capabilities to perform complex and 

dangerous work, such as excavation and shoring. This placed a great burden upon Corps officials to 

mentor and monitor the safe use of equipment and other safety practices unknown to the contractors 

and subcontractors of Falluja. During the course of this project, there were four fatalities due to 

construction activities. Each fatality increased construction delays as the program office issued a Stop 

Work Order and ordered an investigation to determine the cause of the accident and the necessary 

corrective actions.

Major Changes in Project Direction Occurred in 2008 

In 2008, the Ambassador became “extremely concerned” that the Falluja Waste Water Treatment 

System had “gone so far off track and for so long.”68 The Ambassador was concerned not only with 

the costs, timeliness, and extent of the project, but also with the adequacy of progress reporting. In 

July 2008, the Ambassador requested SIGIR perform an audit and inspection of the project. In 

October 2008, SIGIR’s audit report addressed the adequacy of progress reporting69, while the 

inspection report addressed the project’s costs, timeliness, and the extent of construction.70

SIGIR’s audit report identified shortcomings in the Department of State’s communication avenues for 

ensuring the Chief of Mission receives information critical for decision-making on reconstruction 

projects and made recommendations to correct the shortcomings. In a SIGIR inspection report we 

raised significant sustainability issues for both the U.S. government and GOI. Specifically, the 

Ministry of Municipalities and Public Works did not have funding to complete the house connections; 

provide fuel for generators at the wastewater treatment plant and pump stations; provide essential 

consumables, such as polymer and chlorine; and several DFI-funded contractors had outstanding 

balances. SIGIR recommended the U.S. government coordinate with the GOI to resolve these issues 

in order to protect the U.S. government’s investment in the project. The U.S. Embassy-Iraq concurred 

with the recommendations of SIGIR’s audit and inspections reports. In the words of one program 

official, the SIGIR reports “were critical to this project’s turnaround because they shined a bright light 

on the problems that needed to be addressed.” The SIGIR reports resulted in additional resources, 

both monetary and personnel, being made to the project.

 

 68 SIGIR PA-08-144-148, Falluja Waste Water Treatment System, Falluja, Iraq, 10/27/2008. 69 SIGIR Audit 09-007, Improvements Needed in Reporting Status of Reconstruction Projects to Chief of Mission, 

10/29/2008.

70 SIGIR PA-08-144-148, Falluja Waste Water Treatment System, Falluja, Iraq,” 10/27/2008.
26

Completion of a Back-bone System

In 2009, this project languished to the point where the U.S. officials held serious discussions about the 

desire to complete the project or simply turn the project over to the GOI to complete. At the time, the 

wastewater treatment plant was still under construction, deep excavation holes still existed throughout 

the city and another contractor was hired to dig more holes, and the GOI did not appear to have the 

capacity to either complete or sustain the project.

In an effort to turn this project around, the Corps advocated a two-phase approach. First, the Corps 

Gulf Region District commander did not understand the decision to put more holes in the city instead 

of completing the existing work to make the project operational. The commander terminated the 

contract for new excavation; instead he focused on completing the existing work. In addition, the 

Corps advocated completing an expandable “back-bone” system, consisting of the wastewater

treatment facility, three pump stations, two trunk lines, Collection Areas A, B, and C, and house 

connections to approximately 9,000 homes. The Corps believed this reduction of scope provided the 

best likelihood of completing the project and providing the GOI with the backbone of the system on 

which they could expand to cover more areas in the future. 

Further, the Corps worked with the Department of State and the GOI about the issue of house

connections. The Corps believed house connections were critical to the success of this project; 

without house connections, everything else built would be useless. The Corps did not believe it could 

provide the necessary oversight of connecting the houses to the system, because that would require it 

to go deep inside neighborhoods and into individual homes. Even though security had improved 

considerably by 2009, Falluja still had some very dangerous areas. Instead, the Corps recommended 

that the Department of State award a grant to the GOI for the house connections. This would make the 

GOI responsible for overseeing the contractor’s work. On March 19, 2010, the Department of State 

awarded the grant in the amount of $4,558,000, to connect 9,116 houses in Collection Areas A, B, and 

C. As of September 2011, about 6,000 houses were connected. 

The Waste Water Treatment Plant Grand Opening

On May 2, 2011, the city of Falluja held a ribbon-cutting ceremony for the wastewater treatment 

facility. Several Iraqi dignitaries and local leaders attended the ceremony, which was covered by at 

least 10 Iraqi television and radio channels (see Figure 9). According to a Corps representative, the 

opening of the plant was considered an important milestone for the city of Falluja. Ministry 

representatives stated that a functioning sewer network is a status factor for cities in Iraq. 

Further, ISPO officials met with ministry officials regarding a solution to the fuel problem for the 

wastewater treatment plant and pump stations. In July 2011, the Ministry of Electricity connected the 

wastewater treatment plant to the Anbar essential services line, which provides the plant with 

approximately 20 hours of electricity per day.

After the grand opening, the facility began processing the first wastewater from the connected homes. 

Due to the limited number of houses connected to the facility, only one of the four sewage treatment 

lines is currently needed. However, the plant operators are not properly treating the sewage because 

they have not been trained in using the required consumables, such as polymer and chlorine. The 

Department of State recently awarded a contract to train the plant’s operators in using such products, 

as well as to provide on-the-job training on the plant’s equipment and routine maintenance. The 
27

Department of State hopes that this contract will help in developing the GOI’s capacity to operate 

wastewater treatment plants throughout Iraq.

Figure 9—Ribbon-cutting ceremony

Source: USACE photograph May 2011.

GOI To Expand the System

As recommended in the SIGIR inspections report, ISPO officials engaged its ministry counterparts and 

encouraged them to not only plan to sustain the project, but to complete the entire project as originally 

intended. According to program officials, the CPA helped establish this ministry in 2004, but in the 

beginning, the ministry was not very effective. According to officials, the ministry has improved over 

the years. In addition, the GOI has significantly increased the ministry’s funding for both operations 

and new projects. As a result, the ministry has grown in capacity to provide the consumables 

necessary to properly operate the wastewater treatment plant. 

Further, in October 2010, the Ministry of Municipalities and Public Works proposed to the 

Department of State that if it funded the completion of two trunk lines at a cost of $3.03 million, the 

ministry would fund the remainder of the network system (full build-out). The Department of State 

agreed to the ministry’s cost-sharing proposal and awarded a modification to the existing house 

connections grant to cover the cost of the two trunk lines. Ministry representatives said that the GOI 

has committed $87 million to complete the remainder of the project, which they anticipate will be 

completed in 2014. 
28

Project Impact Is Unknown

The primary purpose of this project was to provide Falluja with a wastewater treatment system that 

would service 100,000 residents. However, the project also had multiple secondary goals including 

building the capacity to deliver essential services, winning the hearts and minds of the people, and 

stimulating the economy by boosting employment (particularly for young men). SIGIR’s review 

found that, at present, about 6,000 homes have been connected to the system71

Secondary Impacts of Project Not Measured

, and a structure has 

been put in place that will allow expansion of the system to thousands of other homes. However, 

measures of success were not established for the secondary goals and it is not clear if they have been

met. 

SIGIR found no evidence that anyone has attempted to measure the impact of this project against its 

secondary goals. This project was identified as a “carrot” to stabilize the local population, and several 

program office and Corps officials stated that this project was awarded to “win the hearts and minds” 

of the Iraqis. However, its actual impact remains largely unknown.

What is known is that for the first two years of this project, violent incidents within Anbar province 

increased dramatically. At the start of the project, Anbar province experienced 719 violent incidents 

(per quarter); however, this number continually increased to a peak of 4,365 (per quarter) in late 2006. 

The incidents between 2006-2007 included hijackings, kidnappings, murder, theft, and extortion. In 

late 2007, security began to improve, and the number of violent incidents dipped below the early 2004 

levels. The cause or causes of the dramatic reduction in violent incidents post-2007 are varied and 

debatable. The Anbar Awakening and the “surge” of additional U.S. troops to the province are largely 

credited with the increase in security. While this project did provide employment for local Fallujans, 

it also provided insurgents and criminals with targets for attack. 

Similarly, SIGIR found no information on whether the project has impacted local residents’ feelings 

towards their government, either local or national. From a local perspective, this project was to show 

Falluja residents its government had the capability to provide an essential service, while from a 

national perspective, this project was identified as a “national reconciliation” project meant to ease 

tensions between Sunnis and Shi’as. At this time, it is unknown whether Falluja residents feel better 

about their local government’s capability to provide an essential service. 

 71 According to the International Organization for Migration, the average Iraqi household is estimated to have about 6.4 

people. Thus, 6,000 homes would be about 38,400 residents.
29

Conclusions and Lessons Learned

Conclusion

After seven years and the expenditure of over $100 million dollars, the backbone of a wastewater

treatment system is now in place, which is currently servicing approximately 38,400 residents. But 

this is far short of the 100,000 residents originally intended to benefit from the system. Despite this 

shortfall, the wastewater treatment plant has been completed and has the capacity to provide service to 

200,000 residents; the network system is expandable, and with additional investment by the Iraqi 

government, tens of thousands of additional residents could be connected to it. SIGIR notes that the 

Iraqi government is now supporting the system’s current operation and its future expansion. But 

completion of the existing backbone system was years late and millions of dollars over budget, leaving 

Falluja’s streets torn up and in disrepair for years. Many people, including U.S. State Department 

personnel, died while working in support of this project. 

Assessing the Falluja Waste Water Treatment System solely on its excessive costs and limited results 

may not fully realize the nature of its secondary goals and objectives. Wartime projects generally have 

secondary goals that shape management decisions made along the way. This project had the 

secondary goals of enhancing local citizens’ faith in their government’s ability to deliver essential 

services, building a service capacity within the local government, winning the hearts and minds of a 

critical segment of the Iraqi populace, and stimulating the economy by boosting employment 

(particularly for young men who were potentially recruitable by the insurgency). 

This project was taken on in 2004 in a city wracked by violence. Little planning went into the project, 

and there was minimal understanding of site conditions, no skilled workforce available, and no clear 

idea about how much the new system would cost. Very early in the project, security conditions 

rapidly deteriorated such that the trenches and pipes laid by the U.S. contractor were regularly being 

blown up and construction workers were subject to continual attacks. On several occasions, U.S. 

combatant commanders had to direct the contractor to stop construction until security improved. So 

many adverse conditions faced this project from the outset; thus, it is hard to understand why it was 

initiated and continued. 

The absence of information or analysis on whether progress was made toward achieving any of the 

secondary goals makes an assessment of this project’s worth or wisdom quite difficult. In the end, it 

would be dubious to conclude that this project helped stabilize the city, enhanced the local citizenry’s 

faith in government, built local service capacity, won hearts or minds, or stimulated the economy. 

Coupled with the fact that the outcome achieved was a wastewater treatment system operating at levels 

far below what was anticipated, it is difficult to conclude that the project was worth the $100 million 

investment and the many lives lost.

Lessons Learned

A lesson learned identified in the book Hard Lessons: The Story of Iraq Reconstruction, is appropriate

to the Falluja project. 
30

A successful reconstruction program requires a balancing of security, political, and economic interests. 

Reconstruction cannot proceed on a large scale without the requisite security to protect those carrying 

out the projects and those overseeing them. In Iraq, the scope of reconstruction was too often 

unsupportable by available security resources. To this day, Iraq’s reconstruction environment has 

never been truly “post-conflict.” Endlessly resuming rebuilding in the wake of sustained attacks on 

reconstruction personnel and critical infrastructure, proved to be a demoralizing and wasteful strategy. 

In future stabilization and reconstruction operations, the U.S. government should analyze whether and 

at what costs security risks can be mitigated before proceeding with large-scale rebuilding projects. 

Such projects should begin only when senior leaders determine that the strategic objective they could 

fulfill outweighs the risk of failure and the costs of mitigating security risks.

Large-scale reconstruction projects often have secondary goals that could enhance their value.

However, under these circumstances, managers need to be cautious that pursuing secondary goals does

not cloud decision making about the efficacy of continuing these projects. When projects exceed their 

expected timelines by years, it is doubtful that the citizens awaiting the project will recognize any 

benefits beyond the project’s completion and, in fact, may see the prolonged delays as evidence of 

incompetence or malfeasance on the part of the donor.

In addition, this case study demonstrates that for contingency operations involving a reconstruction 

program, the emphasis should not be on the obligation and expenditure of reconstruction funding; 

instead the emphasis should be placed on project planning, including performing regular risk 

assessments to determine the desirability of continuing construction of a particular project.
31

Management Comments and Audit Response

Because this report did not contain recommendations, neither the Department of State nor the U.S. 

Army Corps of Engineers was required to respond. However, both provided official comments on the 

draft report. The U.S. Army Central Command and U.S. Forces-Iraq also provided technical 

comments.

DoS concurred that the project faced many difficulties, but maintains that the Fallujah Waste Water 

Treatment Plant has made progress. According to DoS, in 2008 the project turned a corner, in no 

small part due to SIGIR’s October 27, 2008 report. DoS worked collaboratively with USACE, 

developed a plan that was appropriate and achievable and forged ahead-with the firm objective of 

making the taxpayer’s investment and the efforts of those who worked so diligently on this project 

worthwhile. SIGIR agrees with DoS’s comments. However, SIGIR makes two points in this report. 

First, unquestionably the final outcome of this project fell far short of plans raising questions about 

initiating such large-scale projects during a conflict. If the project had strategic goals that overrode the 

goal of constructing a sewage treatment plant, those goals were neither identified nor tracked and thus 

the value of this $107 million dollar investment is questionable. 

The second point is whether large-scale infrastructure projects are appropriate vehicles for pursuing 

secondary goals. Managers need to be cautious that the pursuit of secondary goals does not cloud 

decision making about the efficacy of continuing these projects. As SIGIR said in the report, when 

projects exceed their expected timelines by years, it is doubtful that the citizens will recognize any 

secondary benefits and, in fact, may see the prolonged delays as evidence of incompetence or 

malfeasance on the part of the donor.

USACE concurred with the report and provided technical comments that we included in the report as 

appropriate.
32

Appendix A—Scope and Methodology 

Scope and Methodology 

In August 2010, the Special Inspector General for Iraq Reconstruction (SIGIR) initiated Project 1018

to examine the Falluja Waste Water Treatment System project. SIGIR’s objectives for this report were 

to determine why the Waste Water Treatment System project took seven years and cost $107.9 million 

to partially complete, and whether the project achieved its construction goals. This report was 

performed by SIGIR under the authority of Public Law 108-106, as amended, which also incorporates 

the duties and responsibilities of inspectors general under the Inspector General Act of 1978. SIGIR 

conducted its work during the period April through October 2011 in Baghdad, Iraq and Arlington, 

Virginia.

To determine why the Waste Water Treatment System project took seven years and cost $107.9 

million to partially complete, we requested documentation from program and project management, 

including contract listings with obligations and disbursements, cost estimates and underlying support, 

periodic briefing presentations, descriptions of the project scope, estimates to complete and various 

other project documentation including emails, memoranda, and letters from project files. We 

reviewed this documentation to understand the scope and estimated cost of the original project, major 

events that occurred over the life of the project, changes in scope, the current status and the operational 

viability of the project going forward. 

We also interviewed current and former program and project management officials, as well as 

representatives from the Government of Iraq (GOI), to gain an understanding of how this project was 

initiated, the scope of the project, events that caused delays, the outcome of the project, availability of 

electricity and consumables, and GOI’s commitment to operate and maintain the project. 

To determine whether the project achieved construction goals, we compared the original scope of the 

project to the project as completed. Through interviews with key program officials, we inquired about 

other strategic goals of the project and whether any analysis or studies were done to determine whether 

the project met strategic objectives. 

We conducted the audit in accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings and conclusions based on our 

audit objectives.

Use of Computer-processed Data 

We did not use computer-processed data in this report. 
33

Internal Controls 

Because we did not review any individual contract, but rather a group of contracts over the life of the 

Waste Water Treatment System project, we reviewed the adequacy of program and project 

management. 

Prior Coverage 

We reviewed the following reports and publications by SIGIR and the U.S. Government 

Accountability Office. 

Special Inspector General for Iraq Reconstruction

Improvements Needed in Reporting Status of Reconstruction Projects to Chief of Mission, SIGIR-09-

007, 10/29/2008.

Fallujah Waste Water Treatment System Fallujah, Iraq, SIGIR –PA-08-144-148, 10/272008.

Key Recurring Management Issues Identified in Audits of Iraq Reconstruction Efforts, SIGIR- 08-020, 

6/27/2008.

Hard Lessons: The Iraq Reconstruction Experience, 2/2009.

U.S. Government Accountability Office

Rebuilding Iraq, U.S. Water and Sanitation Efforts Need Improved Measures for Assessing Impact and 

Sustained Resources for Maintaining Facilities, GAO-05-872, September 2005.
34

Appendix B—Key Events for the Falluja Waste Water 

Treatment System Project 

Month Year Description of Event

March 2004 Security contractors are attacked in Falluja. Four contractors are killed 

and their bodies hung from a local bridge spanning the Euphrates River. 

April 2004 US Military launches Operation Vigilante Response to apprehend 

assailants and attack insurgent positions.

April 2004 GOI objects to the military efforts in Falluja. Reconstruction is developed 

as a strategy to stabilize Falluja. 

June 2004 A Funding Request is approved for $35 million for the Falluja Waste

Water Treatment System.

June 2004 An Independent Government Estimate is prepared indicating the cost for 

the entire Waste Water Treatment System will be $35.4 million. 

June 2004 CPA Awards a $28.6 million contract to FluorAMEC for design and 

construction of the Falluja Waste Water Treatment System. Term for 

design and construction is 3.5 years. The term is later changed to 18 

months (no explanation as to why time frame was accelerated or who 

authorized it).

April–October 2004 Insurgents control Falluja. The US Marines suspend FluorAMEC’s work.

November 2004 US Military launches Operation Al Fajr (Phantom Fury) to regain control of 

Falluja.

January 2005 FluorAMEC receives a Notice To Proceed for construction.

March 2005 FluorAMEC submits $51.3 million cost estimate for a partial lagoon-based 

waste treatment system.

July 2005 FluorAMEC’s task order is de-scoped by program office.

August 2005 MMPW rejects a lagoon-based treatment process system.

November 2005 USG agrees to a mechanical waste treatment system, which required the 

re-design of the WWTP facility.

December 2005 GOI agrees to contribute $18 million in DFI funds toward the construction 

of the WWTS.

April 2006 USACE proposes four options for completion of a mechanical waste 

treatment system with cost estimates ranging from $55.5 million for a 

“baseline” build-out to $112.2 million for a “full” build-out. A new 

execution strategy is adopted of awarding contracts to Falluja-based 

contractors.

May 2006–2009 GOI failure to make payments on DFI-funded contracts causes 

construction delays and work stoppages.

October 2007 USG decides to terminate some DFI-funded contracts and re-award with 

CERP or IRRF.

November 2007 USG decides upon a final project scope.

October 2008 SIGIR report identifies DFI payment and GOI sustainability issues.

August 2009 USG proposes project scope reduction (completion of an “expandable” 

backbone system).
35

Month Year Description of Event

March 2010 USG provides a $4.6 million grant to GOI for the connection of 9,116 

homes to the WWTS.

October 2010 GOI proposes to fund build-out of remaining collection areas, pump 

stations, and home connections estimated at $87 million if the USG 

completes two additional trunk lines (T1 & T2).

March 2011 USG provides an additional $3 million grant to GOI to complete trunk lines 

T1 & T2. 

May 2011 Ribbon-cutting ceremony for opening of the WWTP—wastewater 

collection lines are completed in 3 of 8 areas, and approximately 4,500 

homes are connected to the system. 

December 2011 Connections to another 4616 homes are completed/in process.

Source: SIGIR analysis of DoS and USF-I documents. 
36

Appendix C—List of Contracts Associated with the 

Falluja Waste Water Treatment System Project

Iraq Relief and Reconstruction Fund (IRRF)

Contract 

Number Contract Description

Costs 

through 

July 8, 2011

Estimate 

to 

Complete

Total 

Estimated 

Costs

W917BG-08-C-0062 Construction of 4,500 meters of trunk 

main to connect pump stations and 

collection systems to the plant. 96,963 96,963

W91GET-08-M-1215 Procurement of operations and 

maintenance equipment and tools 

necessary to run the FWWTS. 

106,571 106,571

W917BG-06-D-0021 Construction of two bathroom 

buildings, one dining facility, a chlorine 

and polymer storage facility, and a 

workshop, including sidewalks and 

parking areas. 

108,308 108,308

W91GET-08-M-1217 Procurement of operations and 

maintenance equipment and tools 

necessary to run the FWWTS. 185,000 185,000

W91GET-08-M-1216 Procurement of operations and 

maintenance equipment and tools 

necessary to run the FWWTS. 486,836 486,836

W917BG-06-C-0048 Construction of a 200m x 200m 

laydown yard for the receipt and 

storage of sewer piping and other 

materials for construction of the 

FWWTS. 

572,125 572,125

W917BG-08-C-0037 Engineering, inspection, and reporting 

services during construction of the 

FWWTS. 

1,582,073 1,582,073

W917BG-06-C-0213 Engineering, inspection, and reporting 

services during construction of the 

FWWTS. 1,589,654 1,589,654

W91GY1-06-C-0049 Construction of 4,500m of trunk mains 

connecting multiple pump stations and 

5 collection systems to trunk main T0. 1,607,653 1,607,653
37

W917BG-10-C-0002 Construction of trunk main T0 from 

pump station F1 to manhole TO-17 

and trunk main T3 to serve collection 

area A. 

1,877,200 1,877,200

W91GY1-06-C-0005 Construction of collection system 

sewer lines in Area B. 2,634,888 2,634,888

W91GY1-06-C-0048 Construction of collection system 

sewer line repairs in Area A. 2,906,420 2,906,420

W91GY1-06-C-0003 Construction of trunk main T0 from 

pump station F1 to manhole TO-17 

and trunk main T3 to serve collection 

area A. 

3,169,977 3,169,977

W917BG-08-C-0083 Construction of collection system 

sewer lines in Area B. 3,201,494 3,201,494

W91GY1-06-C-0004 Construction of collection system 

sewer lines in Area C1. 3,400,777 3,400,777

W91GY1-06-C-0050 Construction and commissioning of 

pump station F5. 4,923,210 4,923,210

W914NS-04-D-0008 This is the original contract for the 

design and construction of the 

FWWTS based on a treatment method 

using oxidation lagoons. This contract 

was ultimately used for the design of 

the entire system and construction of 

the collection network in Areas A, B, 

and C1. 

18,678,375 18,678,375

W91GY1-06-C-0047 Design, construct, and commission, a 

wastewater treatment plant consisting 

of four packaged wastewater treatment 

plants, pre-purchased by the MMPW, 

for the City of Fallujah. 

29,554,766 29,554,766

W914NS-04-D-0007 Engineering and design services. 500,000 500,000

W914NS-04-D-0007 Engineering and design services. 899,902 899,902

W914NS-04-D-0007 Engineering and design services. 98 98

W91GDW-08-M-4015 Engineering and design services. 906,682 906,682

W917BG-06-D-0017 350,000 350,000

Subtotal $79,338,972 $79,338,9722
38

Commander’s Emergency Response Program (CERP)

Contract 

Number Contract Description Costs Estimate 

to 

Complete

Total 

Estimated 

Costs

W917BG-05-A-0022 Material supply including 41,728m of 

100mm PVC pipe. $207,540 $207,540

W917BG-05-A-0020 Material supply. 325,644 325,644

W917BG-05-A-0007 Material supply. 334,845 334,845

W917BG-05-A-0024 Material supply including 29,100 m of 

200mm PVC pipe. 407,400 407,400

W917BG-05-A-0026 Material supply. 455,000 455,000

W917BG-05-A-0005 Material supply. 481,070 481,070

W917BG-05-A-0009 Material supply. 497,280 497,280

W917BG-07-C-0108 Material supply. 1,156,344 1,156,344

W917BG-06-C-0125 Construction and commissioning of 

pump stations F1 and F2. 7,461,609 7,461,609

Subtotal $11,326,732 $11,326,732

Development Fund for Iraq (DFI)

DFIWAT-06-C-0003 Survey and geotechnical services. $32,500 $32,500

W91GY1-06-M-0004 Phase II engineering services. 458,995 458,995

DFIWAT-06-C-0021 Material supply including 100mm to 

800mm PVC pipe, 1100mm to 

1400mm Glass Reinforced Pipe 

(GRP), manhole covers and fittings. 

668,556 668,556

DFIWAT-06-C-0017 Construction of the FWWTP and pump 

station F1 11 kv feeder lines 

(electrical). 802,419 802,419

DFIWAT-06-C-0023 Construction of the FWWTS Force 

Main from the F1 pump station to the 

FWWTP. 

1,886,349 1,886,349

DFIWAT-06-C-0024 Construction of a 1,000 mm GRP 

outfall pipeline between the FWWTP 

and the Euphrates River. 

1,420,000 1,420,000

DFIWAT-06-C-0027 Construction of the FWWTP 

earthwork. The project includes the 

importation of over 300,000 cubic 

meters of soil backfill.

2,768,887 2,768,887

Subtotal $8,037,706 $8,037,706
39

Source: SIGIR’s analysis of USACE and JCC-I contracts. 

Economic Support Fun (ESF)

Contract 

Number Contract Description

Costs 

through

July 8, 2011

Estimate to 

Complete

Total 

Estimated 

Costs

W91GDW-10-P-4000 Engineering and design support 

services during construction of the 

FWWTS. $390,425 $390,425

SNEAIR-10-CA-130 Construction to connect 9,000 homes 

to the FWWTS. 750,000 6,839,000 7,589,000

W91GDW-09-M-4045 

TO SS-016 Engineering services. 180,000 180,000

Subtotal $1,320,425 $6,839,000 $8,159,425

Estimated Costs for Operations and Maintenance training contract $1,000,000 $1,000,000

Total $100,023,835 $7,839,000 $107,862,835
40

Appendix D—Acronyms 

Acronym Description

CERP Commander’s Emergency Response Program

Corps U.S. Army Corps of Engineers and its Gulf Region District

CPA Coalition Provisional Authority

DFI Development Fund for Iraq

ESF Economic Support Fund

IED Improvised explosive device

IRMO Iraq Reconstruction Management Office

IRRF Iraq Relief and Reconstruction Fund

ISPO Iraq Strategic Partnership Office

ITAO Iraq Transition Assistance Office

GOI Government of Iraq

PCO Project and Contracting Office

PMO Project Management Office

SIGIR Special Inspector General for Iraq Reconstruction

U.S. United States

USACE U.S. Army Corps of Engineers

USF-I United States Forces–Iraq
41

Appendix E—Audit Team Members 

This report was prepared and the audit conducted under the direction of Glenn D. Furbish, Assistant 

Inspector General for Audits, Office of the Special Inspector General for Iraq Reconstruction.

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

Richard Kusman

Kevin O’Connor

James Shafer
42

Appendix F—Management Comments 
43
44

Appendix G—Management Comments 
45

Appendix H—SIGIR Mission and Contact Information

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:

1. oversight and review through comprehensive audits, 

inspections, and investigations

2. advice and recommendations on policies to promote 

economy, efficiency, and effectiveness

3. deterrence of malfeasance through the prevention and 

detection of fraud, waste, and abuse

4. 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:

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

2 Phone: 703-602-4063

3 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

2530 Crystal Drive

Arlington, VA 22202-3940

Phone 703-428-1059

Email hillel.weinberg@sigir.mil

Public Affairs Deborah Horan

Director of Public Affairs

Mail: Office of the Special Inspector General 

for Iraq Reconstruction

2530 Crystal Drive

Arlington, VA 22202-3940

Phone: 703-428-1217 

Fax: 703-428-0817

Email: PublicAffairs@sigir.mil