GAO

United States General Accounting Office

Report to Congressional Requesters

May 2001 LICENSING 

HYDROPOWER 

PROJECTS

Better Time and Cost 

Data Needed to Reach 

Informed Decisions 

About Process 

Reforms

GAO-01-499

Page i GAO-01-499 Licensing Hydropower Projects

Letter 1

Appendix I FERC’s Traditional Licensing Process 19

Appendix II FERC’s Alternative Licensing Process 20

Appendix III Objectives, Scope, and Methodology 21

Appendix IV Comments From the Federal Energy Regulatory

Commission 23

Appendix V GAO Contacts and Staff Acknowledgments 34

Contents
Page 1 GAO-01-499 Licensing Hydropower Projects

May 2, 2001

The Honorable Joe Skeen

Chairman, Subcommittee on Interior

 and Related Agencies

Committee on Appropriations

House of Representatives

The Honorable Ralph Regula

House of Representatives

About 10 percent of all electricity production in the United States is

generated by hydroelectric power (hydropower) projects. Federally

owned and operated hydropower projects generate approximately half of

this amount, while about 1,000 nonfederally owned and operated

hydropower projects, which are licensed by the federal government,

generate nearly all of the rest.1

 Hydropower projects can include dams,

reservoirs, stream diversion structures, powerhouses containing waterdriven turbines, and transmission lines.

Hydropower is an important part of the nation’s energy mix. It offers the

benefits of a comparatively inexpensive, emission-free, renewable energy

source, the quantity of which can be increased quickly in periods of peak

demand. In addition, the reservoirs behind hydropower dams often

provide other benefits, including recreation, flood control, irrigation, and a

municipal water supply. However, hydropower projects can also have

adverse effects on ecosystems and resources, including fish and wildlife.

They can change the fundamental chemical, physical, and biological

processes of river ecosystems by (1) fluctuating river levels and altering

the timing of flows, (2) blocking the downstream flow of nutrients and

sediments, (3) changing water temperatures and oxygen levels, (4)

impeding fish from migrating up and down streams or killing them as they

pass through turbines used to generate power, and (5) drying out sections

of streams.

 1

 About 600 additional small generating capacity hydropower projects are exempted from

the federal licensing requirement. “Projects” in this report refers to the large, licensed

hydropower projects.

United States General Accounting Office

Washington, DC 20548
Page 2 GAO-01-499 Licensing Hydropower Projects

The Federal Power Act (FPA) authorizes the Federal Energy Regulatory

Commission (FERC) to issue licenses to construct and to operate

nonfederal hydropower projects. FERC—an independent five-member

commission appointed by the President and confirmed by the Senate—

issues licenses valid for periods up to 50 years, after which the projects

must be relicensed in order to continue operations.

FERC issued original licenses for most of the about 1,000 nonfederal

hydropower projects decades ago. Between January 1, 1993, and

December 31, 2000, the licenses for 395 of these projects expired. Many of

these were small projects that do not generate much power. According to

FERC, over the next 15 years, the licenses for another 238 projects will

expire. The 238 projects, many of which are large, combine to generate

over half of the nation’s nonfederal hydropower.

In recent years, some licensees and other participants in the licensing

process have expressed concern that obtaining a license now takes too

long and costs too much. Responding to these concerns, FERC established

an alternative licensing process, and other federal agencies have

introduced reforms intended to make the licensing process more efficient

and less costly. However, these reforms did not quell the concerns. As a

result, in November 2000, the Congress directed FERC to conduct a

comprehensive review of the policies, procedures, and regulations relating

to the licensing of nonfederal hydropower projects to determine how to

reduce the time and costs associated with obtaining a license. FERC is

required to report its findings in 6 months, or by May 8, 2001.

Prior to the enactment of the statute requiring FERC to review its licensing

process, you asked us to identify and assess significant issues related to

the process. As agreed, this report discusses (1) why the licensing process

now takes longer and costs more than it did when FERC issued most

original licenses several decades ago; (2) whether participants in the

licensing process agree on the need for, and type of, further reforms to the

process to reduce time and costs; and (3) whether available time and cost

data are sufficient to reach informed decisions on the effectiveness of

recent reforms and the need for further reforms to the process.

The Federal Energy Regulatory Commission, federal and state land and

resource agencies, licensees, environmental groups, and other participants

in the licensing process acknowledge that the process is far more

complex, time-consuming, and costly today than it was when the

Commission issued the approximately 1,000 original hydropower licenses

Results in Brief
Page 3 GAO-01-499 Licensing Hydropower Projects

30 to 50 years ago. Since 1986, the Commission has been required to give

“equal consideration” to, and make tradeoffs among, hydropower

generation and other competing resource needs, including protecting and

enhancing fish and wildlife. Moreover, environmental and land

management laws—enacted primarily during the 1960s and 1970s—have

placed additional requirements on other federal and state agencies

participating in the licensing process to address specific resource needs,

including protecting endangered species, achieving clean water, and

preserving wild and scenic rivers. Public values toward hydropower have

also changed and now reflect a growing concern about the environmental

impacts of hydropower projects. Attempts to balance and make tradeoffs

among competing economic and environmental interests and to improve

the environmental performance of projects, while preserving hydropower

as an economically viable energy source, have lengthened the process and

made it more costly.

The Federal Energy Regulatory Commission, federal and state land and

resource agencies, licensees, environmental groups, and other participants

in the licensing process do not agree on whether further reforms are

needed to reduce process-related time and costs. Some within and among

these diverse parties believe that the time and money spent on licensing a

project reflect the level of complexity of the issues involved and that

recent reforms will likely reduce the time and costs needed to obtain a

license. Conversely, others believe that recent reforms will do little to

reduce time and costs. However, they cannot agree on what further

reforms are needed to shorten the process and make it less costly.

To reach informed decisions on the effectiveness of recent reforms to the

licensing process as well as the need for further reforms to the process,

the Federal Energy Regulatory Commission must accomplish two tasks.

First, it needs complete and accurate data on process-related time and

costs by participant, project, and process step. Currently, the Commission

does not systematically collect much of these data. Second, it needs to

identify (1) why certain projects or groups of projects displaying similar

characteristics take longer and cost more to license than others do and (2)

why the time and costs to complete certain process steps vary by project

or group of similar projects. However, the Commission has yet to link the

time and cost data that it has collected to projects displaying similar

characteristics. Similar characteristics may be project-related, such as

whether the project is on federal land; process-related, such as whether

the Commission had to resolve a dispute during the process between the

licensee and a federal or state agency; or outcome-related, such as

whether the terms and conditions of a new license compromise the
Page 4 GAO-01-499 Licensing Hydropower Projects

project’s economic viability or environmental performance. Instead, the

Commission is relying, in part, on observations and suggestions by parties

involved or interested in the licensing process. However, without complete

and accurate time and cost data and the ability to link time and costs to

projects, processes, and outcomes, the Commission cannot assess the

extent to which the observations and suggestions—or any recommended

administrative reforms or legislative changes—might reduce the length

and costs of the process. This report contains recommendations that, if

implemented, would allow informed decisions on the effectiveness of

recent reforms to the licensing process as well as the need for further

reforms to the process.

We obtained written comments on a draft of our report from the Federal

Energy Regulatory Commission. The Commission generally agreed with

our characterization of the licensing process and the primary issues that

affect time and costs. It also agreed that it does not systematically collect

complete and accurate data on process-related time and costs by

participant, project, and process step. However, the Commission believes

that these data are not needed to reach informed decisions on the

effectiveness of recent reforms to the licensing process as well as the need

for further reforms to the process. Rather, it thinks that it can address the

salient issues by developing “targeted analyses” to determine major factors

affecting licensing time and costs based, in part, on its “years of

experience” with the licensing process. However, we continue to believe

that good data are needed to reach good decisions. Moreover, without

complete and accurate time and cost data and the ability to link time and

costs to projects, processes, and outcomes, the Commission increases the

risk that any reforms that it recommends may not only not reduce processrelated time and costs, but also result in unintended consequences to the

outcomes of the process.

FERC now issues few licenses to construct and operate new hydropower

projects. Therefore, most of FERC’s licensing activities relate to the

relicensing of projects with licenses currently nearing their expiration

dates.

FERC recognizes two licensing processes—a traditional process and an

alternative process. In addition, some licensees use a combination of the

two processes—informally referred to as a “hybrid” process. All three

processes begin between 5 and 5-1⁄2 years before a project’s license

expires, when the licensee notifies FERC of its intent to seek relicensing.

Each process ends when FERC either issues a new license or denies the

Background
Page 5 GAO-01-499 Licensing Hydropower Projects

license application. However, FPA provides for subsequent administrative

and judicial reviews of a FERC license decision. If a license expires while

a project is undergoing relicensing, FERC issues an annual license,

allowing a project to continue to operate under the conditions found in the

original license until the relicensing process is complete. Currently, more

than 60 projects are operating under annual licenses, including several that

have been operating under annual licenses for over a decade.

FERC’s newly issued licenses include a standard “reserved authority” that

allows FERC to “reopen” a license to modify its terms and conditions to

meet fish and wildlife needs. New licenses may also include “reopener

articles” that allow federal and state agencies, nongovernmental

organizations, and individuals to petition FERC to reopen a license for

other issues, including minimum streamflows and water quality. Federal

fish and wildlife agencies may also ask FERC to reconsider the impacts of

a project when an affected species is listed as endangered or threatened

under the Endangered Species Act.

FERC divides the traditional licensing process into two phases—a preapplication consultation phase and a post-application analysis phase. Each

phase consists of stages and individual steps defined by “windows of time”

rather than by specific dates. (See app. I.) For example, FERC requires at

least 30 days to review a licensee’s initial consultation package, and a

meeting between the licensee and federal and state agencies typically

takes place between 30 and 60 days after the initial consultation package is

prepared.

During the pre-application consultation phase, the licensee must consult

with officials at federal and state land and resource agencies, as well as

those representing affected Indian tribes, who identify studies the licensee

should undertake to determine the project’s impacts on fish and wildlife,

recreation, water, and other resources. If the licensee disagrees with the

need for a study, FERC may be asked to resolve the dispute. After

completing the agreed-upon studies, the licensee prepares a draft

application and obtains comments from, and attempts to resolve any

disagreements on needed actions with, the relevant federal and state

agencies.

The post-application analysis phase begins when the licensee files a formal

application to obtain a new license. This filing must occur at least 2 years

before the license expires. The application is a comprehensive, detailed

document specifying the project’s proposed operations, its anticipated

The Traditional Licensing

Process
Page 6 GAO-01-499 Licensing Hydropower Projects

impact on resources and other land uses, and proposed actions to mitigate

adverse effects. FERC reviews the application to ensure that it meets all

requirements and then asks relevant federal and state land and resource

agencies to formally comment on it.

Depending on the comments and its own independent analysis of the

application, FERC may ask the licensee to provide additional data and

studies. When FERC is satisfied that these are sufficient, it conducts an

environmental analysis under the National Environmental Policy Act of

1969 (NEPA) and an economic analysis of the project’s benefits and costs.

In addition to using FERC’s NEPA analysis, affected federal land and

resource agencies frequently conduct separate environmental analyses

under NEPA, or assessments under other laws, to determine the license

terms and conditions to be prescribed or recommended to protect or

enhance fish, wildlife, and other resources. FERC reviews these terms and

conditions and, if necessary, negotiates with the relevant federal and state

land and resource agencies or affected Indian tribes on the license’s terms

and conditions.

In October 1997, FERC issued an order codifying an alternative licensing

process. Similar to the traditional licensing process, the alternative

licensing process is divided into pre-application and post-application

phases. (See app. II.) The licensee may choose the alternative licensing

process, if it can demonstrate that all the participants agree on its use,

subject to final approval by FERC.

The alternative licensing process shortens the process by combining many

of the earlier consultations and studies with the later analyses in the preapplication phase. For example, the licensee begins a preliminary NEPA

analysis during the pre-application phase rather than having FERC begin

the NEPA analysis during the post-application phase. The alternative

licensing process also seeks to improve communication and collaboration

among the participants in the process and often results in a “settlement

agreement” at the end of the pre-application phase. This agreement, signed

by all the participants in the process, includes the conditions to protect

and enhance resources. Beginning the NEPA analysis and reaching

agreement on license conditions in the pre-application phase are intended

to shorten the post-application analysis phase.

The Alternative Licensing

Process
Page 7 GAO-01-499 Licensing Hydropower Projects

Some licensees use a hybrid licensing process that often combines the

structured sequence of the traditional licensing process with the improved

earlier consultation and collaboration of the alternative licensing process.

Under this process, a licensee may try during the pre-application phase to

achieve a settlement agreement among participants, but reserve the option

to use the traditional process in instances when agreement cannot be

reached. A further difference is that FERC conducts the NEPA analysis

during the post-application phase rather than having the licensee begin the

analysis during the pre-application phase as under the alternative licensing

process.

The licensing process is complete when FERC either issues a license or

denies the license application. However, FPA provides for subsequent

administrative and judicial reviews of a FERC license decision. Any party

to the licensing process may file an application for a rehearing with FERC

within 30 days of FERC’s licensing decision. FERC subsequently issues an

order (decision) on the application for a rehearing. Any party to the

licensing process may also obtain a judicial review of FERC’s decision in

the relevant federal appeals court within 60 days after FERC’s order on the

application for a rehearing. FERC often delays implementation of

contested license conditions until the reconsideration phase is completed.

FERC and other participants in the licensing process acknowledge that the

process is far more complex, time-consuming, and costly today than it was

when FERC issued the approximately 1,000 original hydropower licenses

30 to 50 years ago. FERC must now attempt to balance and make tradeoffs

among competing economic and environmental interests and to improve

the environmental performance of projects while preserving hydropower

as an economically viable energy source. Balancing these interests and

making the necessary tradeoffs lengthen the process and make it more

costly.

FPA remains the basic statutory authority governing the licensing of

hydropower projects. However, the Electric Consumers Protection Act of

1986 amended section 4(e) of FPA to require FERC to give “equal

consideration” to water power development and other resource needs,

including protecting and enhancing fish and wildlife, in deciding whether

to issue an original or a renewed license.

In addition, environmental and land management laws—enacted primarily

during the 1960s and 1970s—require other participating federal and state

The Hybrid Licensing

Process

Administrative and

Judicial Reviews of FERC

License Decisions

The Licensing Process

Is More Complex,

Lengthy, and Costly

Than It Was 30 to 50

Years Ago
Page 8 GAO-01-499 Licensing Hydropower Projects

agencies to address specific resource needs, including protecting

endangered species, achieving clean water, and preserving wild and scenic

rivers. For example, section 7 of the Endangered Species Act of 1973

represents a congressional design to give greater priority to the protection

of endangered species than to the primary missions of FERC and other

federal agencies.2

 FERC, like all other federal agencies, must ensure that

its actions, including licensing decisions, are not likely to jeopardize the

existence of endangered and threatened species. Moreover, NEPA requires

each federal agency, including FERC, to assess the environmental impact

of proposed actions—which can include licensing decisions—that may

significantly affect the environment. NEPA is designed to compel federal

agencies to consider the environmental impacts of their actions and to

inform the public that these impacts have been taken into account prior to

reaching decisions.

FPA authorizes federal and state agencies other than FERC to influence

license terms and conditions, and in some instances, precludes FERC from

altering license conditions imposed by other agencies. For instance,

section 4(e) of FPA makes licenses for projects on federal lands reserved

by the Congress for other purposes—such as national forests—or that use

surplus water from federal dams subject to mandatory conditions imposed

by the head of the federal agency responsible for managing the lands or

facilities. Today, these agencies include the Forest Service, U.S.

Department of Agriculture, and the Department of the Interior’s Bureau of

Land Management, Fish and Wildlife Service, Bureau of Indian Affairs, and

Bureau of Reclamation.

Similarly, section 18 of FPA requires FERC to include license conditions

for fish passage prescribed by federal fish and wildlife agencies. These

agencies now include Interior’s Fish and Wildlife Service and the National

Marine Fisheries Service in the Department of Commerce. In addition, the

Electric Consumers Protection Act of 1986 added section 10(j) to FPA.

This section authorizes federal and state fish and wildlife agencies to

recommend license conditions to benefit fish and wildlife that FERC must

include in the license unless it (1) finds them to be inconsistent with law

and (2) has already established license conditions that adequately protect

fish and wildlife.

 2 TVA v. Hill, 437 U.S. 153, 185 (1978).
Page 9 GAO-01-499 Licensing Hydropower Projects

Moreover, section 401 of the Clean Water Act—added in 1972—requires

anyone seeking a license or permit for a project that may affect water

quality to seek approval from the relevant state water quality agency.

States have begun to use section 401 to influence license terms and

conditions.

The regulations adopted by FERC under FPA require FERC to involve the

public in the licensing process. Members of the public may express their

views on resource needs that they believe need to be addressed in an

application to obtain a license. They may also submit comments and

recommendations, request scientific studies, and formally intervene in the

licensing process. As an intervenor, a member of the public is entitled,

among other things, to request a rehearing of a license decision by FERC

or to obtain judicial review of FERC’s decision in the relevant federal

appeals court.

Public values have changed over the past 30 to 50 years and now reflect a

growing concern about the environmental impacts of hydropower

projects. Environmental groups and others view the licensing of a

hydropower project as a once-in-a-lifetime opportunity to have these

values and concerns considered.

Changing public values, coupled with requirements to give equal or greater

consideration to environmental concerns than to hydropower generation,

have resulted in new license conditions intended to protect and enhance

fish, wildlife, and other resources. For example, in an effort to reduce the

risk to fish resources, new licenses may include conditions that require

licensees to change minimum streamflows, construct fish-passage

facilities, install screens and other devices to prevent fish from being

injured or killed, limit the amount or timing of reservoir drawdowns, or

purchase or restore lands affected by a project.

FERC, federal and state land and resource agencies, licensees,

environmental groups, and other participants in the licensing process do

not agree on whether further reforms are needed to reduce processrelated time and costs. Some within and among these diverse parties

believe that the time and money spent on licensing a project reflect the

level of complexity of the issues involved and that recent reforms will

likely reduce the time and cost needed to obtain a license. Conversely,

others believe that recent reforms will do little to reduce time and costs.

However, they cannot agree on what further reforms are needed to

shorten the process and make it less costly.

Participants Cannot

Agree on the Need for,

and Type of, Reforms

to the Licensing

Process
Page 10 GAO-01-499 Licensing Hydropower Projects

Some participants believe that the time and money spent on project

licensing reflect the level of complexity of the issues involved. They

consider the process to be worthwhile as long as it results in a new license

that is legally defensible, scientifically credible, and more likely to protect

resources over the term of the license.

Some of these participants also believe that recent reforms will likely

reduce the time and costs associated with obtaining a new license and that

additional reforms may not be necessary. For example, they believe that,

when compared with projects using the traditional licensing process,

projects using FERC’s relatively new alternative licensing process are

more likely to obtain licenses before their old ones expire and less likely

to have their license decisions delayed as a result of administrative and

judicial reviews.

Other recent reforms that these participants believe might shorten the

licensing process or make it less costly include the following:

• A January 2001 policy by the departments of the Interior and Commerce

that would, for the first time, (1) standardize the way that the two

departments consider input and comments on mandatory license

conditions and (2) ensure that public participation does not delay the

licensing process.

• A series of recently issued reports by an interagency task force—

established in the winter of 1998 by FERC and other federal agencies

involved in the licensing process—that addresses practical ways to

improve the process and make it more efficient.

• A February 2000 report by a national review group convened by the

Electric Power Research Institute—a research consortium created by the

nation’s electric utilities.3

 In the report, licensees, federal and state

agencies, tribes, and nongovernmental organizations (1) share their

licensing experiences and “lessons learned” and (2) provide participants in

licensings with reasonable solutions and alternative approaches to “tough”

licensing issues.

 3 Hydro Relicensing Forum: Relicensing Strategies, Interim Report, National Review

Group Publication, Electric Power Research Institute (Feb. 2000).

Some Licensing

Participants Are Satisfied

With the Current Process
Page 11 GAO-01-499 Licensing Hydropower Projects

Other participants in the licensing process believe that recent reforms will

do little to reduce the time and costs to obtain a new license. For example,

they believe that licensees and other participants will not use FERC’s

alternative licensing process for projects that involve contentious issues or

when participants have conflicting values and concerns. They also believe

that, while the alternative licensing process may shorten the time required

to obtain a new license, it may also be more costly than the traditional

licensing process. Therefore, they believe that further administrative

reforms or legislative changes are needed to shorten the process and make

it less costly.

However, these participants cannot agree on what further reforms are

needed to shorten the process and make it less costly. For instance, some

environmental groups believe that certain licensees deliberately prolong

the licensing process to delay the sometimes substantial costs of

complying with new license conditions. Conversely, some licensees

believe that federal and state land and resource agencies prolong the

process and increase the costs to obtain a new license by (1) requesting

unnecessary studies; (2) not reviewing licensing applications in a timely

manner; (3) analyzing or reanalyzing issues at different steps in the

process without any clear sequence leading to their timely resolution; and

(4) insisting on unreasonable, and sometimes conflicting, license

conditions. Federal and state land and resource agencies, however,

counter these claims, saying that licensings are sometimes delayed

because, until FERC requires them to, licensees are unwilling to conduct

studies or to provide additional information required for the agencies to

fulfill their statutorily mandated missions and responsibilities. In addition,

many licensees, federal and state agencies, and environmental groups

believe that FERC has not provided necessary leadership and direction,

especially during the pre-application consultation phase, when much of

their process-related time and costs can be incurred.

In addition to blaming each other, these proponents of further reforms to

reduce the time and costs to obtain a new license cannot agree on what

reforms are needed to shorten the process and make it less costly. Some

believe that additional administrative reforms can improve the process

and make it more efficient. Others, however, believe that new legislation

will be required.

Other Participants Favor

Further Reforms to the

Licensing Process
Page 12 GAO-01-499 Licensing Hydropower Projects

To reach informed decisions on the effectiveness of recent reforms to the

licensing process and the need for further reforms, FERC must complete

two tasks. First, it needs complete and accurate data on process-related

time and costs by participant, project, and process step. Currently, FERC

does not systematically collect much of these data. Second, FERC needs

to identify why certain projects or groups of projects displaying similar

characteristics take longer and cost more to license than others and why

the time and costs required to complete certain process steps vary by

project or group of similar projects. FERC has yet to link the time and cost

data that it has collected to projects displaying similar characteristics, and

instead is relying, in part, on observations and suggestions of parties

involved or interested in the licensing process. However, without complete

and accurate time and cost data and the ability to link time and costs to

projects, processes, and outcomes, FERC cannot assess the extent to

which the observations and suggestions—or any recommended

administrative reforms or legislative changes—might shorten the process

or make it less costly.

Data on where in the process costs are incurred and by whom are needed

to reach informed decisions about the effectiveness of recent reforms to

the licensing process and the need for further reforms to reduce the

process-related costs of obtaining a hydropower license. However, FERC

lacks much of the required data for itself, other federal and state agencies,

and licensees.

For example, FERC cannot systematically separate its process-related

licensing costs from other hydropower-program-related costs or link the

costs to specific projects or steps in the licensing process. FERC also

cannot identify other federal agencies’ actual costs to participate in the

licensing process. Each year FERC requests federal agencies to report

their hydropower-program-related costs for the prior fiscal year; however,

it does not provided clear guidance to the other agencies on what costs

they should report. As a result, federal agencies do not report millions of

dollars of process-related costs.4

 Moreover, FERC does not request federal

agencies to break down their costs by project or by step in the licensing

process. As a result, it cannot link the hydropower-program-related costs

reported by other federal agencies to either specific projects or to the

 4 Hydropower Relicensing: Federal Costs Are Not Being Recovered (GAO/RCED-00-107,

June 30, 2000).

FERC Needs Better

Time and Cost Data to

Reach Informed

Decisions on the

Effectiveness of

Recent Reforms and

the Need for Further

Reforms to the

Licensing Process

Cost Data for Most

Participants Are Not

Available
Page 13 GAO-01-499 Licensing Hydropower Projects

various steps in the process. In addition, FERC does not request, and

states generally do not report, their process-related licensing costs.

Similarly, FERC does not request licensees to report their process-related

licensing costs. Some licensees have, however, voluntarily reported these

costs to FERC so that FERC can include them—together with estimated

mitigation costs, annual charges, and the value of power generation lost at

relicensing—in its economic analysis of the projects’ benefits and costs.

As of February 2001, FERC had compiled data on licensees’ processrelated licensing costs for 83—or about 20 percent—of the 395 projects

with licenses pending or issued between January 1, 1993, and December

31, 2000. However, because FERC did not provide licensees with guidance

on what costs they should report, it has no assurance that the reported

costs are consistent and comparable. Moreover, since the 83 projects did

not represent a randomly selected sample, FERC cannot use these data to

project the costs incurred by the universe of 395 projects. Moreover, FERC

often could not link the costs to the various steps in the licensing process

to identify which steps were the most costly. Finally, licensees reported

only those costs that they incurred before they filed a formal application

to FERC to obtain a new license and, thus, FERC has no data on any of

their costs associated with the post-application analysis phase of the

licensing process.

Because a project proceeds through sequential phases, stages, and steps in

the licensing process, process-related time data are more readily available

than process-related cost data, which vary by participant. However, the

time data that FERC has collected are incomplete and limited almost

entirely to the post-application analysis phase of the process.

FERC collected time data for the 180 projects with licenses expiring

between January 1, 1994, and December 31, 2000. However, it collected

data for only one step in the pre-application consultation phase of the

licensing process. According to FERC, this phase generally requires 3

years or more to complete and constitutes, on average, more than 60

percent of the total time required to obtain a license. Moreover, FERC

notes that the collected data on the one step in the pre-application

consultation phase are incomplete because FERC did not request

licensees to report when they completed the step.

In addition, FERC is not collecting time data for administrative and

judicial reviews of its license decisions, although FERC often delays the

implementation of contested license conditions until these reviews are

Time Data Are Incomplete
Page 14 GAO-01-499 Licensing Hydropower Projects

completed. Therefore, the time associated with administrative and judicial

reviews should be included in the time required to obtain a license,

according to many participants in the licensing process.

When FERC completes its data collection efforts, it will have some

process-related cost data (mostly from the pre-application consultation

phase), and some process-related time data (mostly from the postapplication analysis phase). However, FERC will not know why certain

projects or groups of projects that display similar characteristics take

longer and cost more to license than others or why the time and costs to

complete certain steps in the process vary by project or group of similar

projects.

FERC needs to link time and costs to project, process, and outcome

characteristics in order to reach informed decisions on the effectiveness of

recent reforms to the licensing process, as well as the need for further

reforms to the process. Project characteristics might include whether the

project has considerable generating capacity, is operated for peak power

production, is on federal land, or affects the habitat of one or more

endangered or threatened species. Process-related characteristics might

include (1) whether FERC had to resolve a dispute between the licensee

and a federal or state agency, (2) whether federal and state agencies

prescribed new mandatory license conditions, (3) whether FERC rejected

or modified new license conditions recommended by federal and state

agencies, or (4) whether parties formally intervened in a licensing.

Outcome-related characteristics might include whether power generation

was lost at relicensing or whether the terms and conditions of a new

license compromise the project’s economic viability or environmental

performance.

As part of its mandated review of its licensing process, FERC held public

meetings in six different cities. It also asked for written comments and

distributed a questionnaire. In their oral and written comments and in

their responses to the questionnaire, parties offered their observations and

suggestions on how the process might be shortened or made less costly.

However, without complete and accurate time and cost data and the

ability to link time and costs to projects, processes, and outcomes, FERC

will not be able to assess the extent that any of these observations and

suggestions—or any administrative reforms or legislative changes that

they may recommend—might (1) reduce the time and costs to obtain a

license or (2) change the outcomes of the process. Thus, FERC will not be

Available Time and Cost

Data Will Not Be Linked to

Project, Process, and

Outcome Characteristics

FERC Cannot Adequately

Assess Public

Observations and

Suggestions on How the

Licensing Process Might

Be Shortened or Made

Less Costly
Page 15 GAO-01-499 Licensing Hydropower Projects

able to adequately assess the tradeoffs between efficiency and

effectiveness, quickness and quality.

FERC recognizes the importance of collecting complete, accurate, and

timely data on which to base informed decisions.5

 However, it has not

established a schedule with firm deadlines for developing a system that

tracks process-related time and costs, nor has it developed a process to

share these data with other parties involved or interested in the process.

Currently, FERC’s data on the licensing process are widely dispersed

throughout FERC, often not comparable, and time-consuming and

resource-intensive to collect. For example, to respond to its mandate to

review its licensing process, FERC gathered time data from (1) various

external and internal information and tracking systems, (2) independent

databases and spreadsheets, (3) document storage and retrieval systems,

(4) project-specific documents, (5) staff files, (6) various studies

conducted for various purposes during the past several years, and (7)

other data sources. These data were often not comparable, and FERC staff

often had to link them manually to one another.

To address its information technology needs, in 1999, FERC completed a

review of its existing information and tracking systems. Subsequently,

FERC performed a needs assessment that showed, on a macro level, how

it planned to receive, generate, organize, and present information to users.

In February 2001, FERC prepared a preliminary draft of its long-term

vision for its hydropower-program-related data and information

technology needs.

FERC officials told us that their future plans include the release of a

detailed document that will define needed enhancements to FERC’s

information and tracking systems. However, FERC has not established a

schedule with firm deadlines to implement the long-term vision of its

hydropower-program-related data and information technology needs. It

also has not determined what, if any, cost data to include.

Lastly, the Congress directed FERC to conduct the review of its licensing

process “in consultation with other appropriate agencies.” However,

despite repeated requests by federal land and resource agencies, as of

 5 Strategic Plan for Fiscal Years 2000–2005, FERC (Sept. 2000).

FERC Does Not Have a

Schedule for Developing a

System to Track ProcessRelated Time and Costs
Page 16 GAO-01-499 Licensing Hydropower Projects

April 20, 2001, FERC had not provided them with a draft of its report or

with any of the process-related time and cost data that it had collected and

analyzed. As a result, Interior had to independently collect and analyze

data from FERC’s information and tracking systems.

On the basis of its analysis, Interior observed that it could not “determine

why processing times are what they are, let alone whether these time

periods are excessive or necessary for deliberative decision-making.”

6

 It

continued that the “parties are engaged in numerous activities during the

licensing process, and to determine the extent to which each activity

contributes to the processing time calls for a more elaborate type of

analysis.” Therefore, Interior recommended that it join with FERC to build

a data set for all projects licensed by FERC and that the data be used to

identify what, if any, further reforms are needed to shorten the process.

FERC, federal and state land and resource agencies, licensees,

environmental groups, and other participants in the licensing process

acknowledge that the process to obtain a license is far more complex,

time-consuming, and costly today than it was 30 to 50 years ago when

FERC issued the approximately 1,000 original hydropower licenses.

Today, FERC faces a formidable challenge in issuing a license that is

legally defensible, scientifically credible, and likely to protect fish, wildlife,

and resources while still preserving hydropower as an economically viable

energy source.

Participants in the licensing process do not agree on the effectiveness of

recent reforms to the process or on the need for further reforms to shorten

the process or make it less costly. To resolve this disagreement and to

reach informed decisions on the effectiveness of recent reforms and the

need for further administrative reforms or legislative changes, FERC needs

(1) a system that collects complete and accurate data on process-related

time and costs by participant, project, and process step and (2) the ability

to link time and costs to projects displaying similar characteristics. To

date, FERC has been reluctant to work with other process participants to

(1) develop a system to collect and share process-related time and cost

data and (2) link the data to projects displaying similar characteristics in

order to identify those project, process, and outcome characteristics that

 6 Hydropower Licensing Policies, Procedures, and Regulations—Comprehensive Review,

Department of the Interior (Docket No. PL01-1-000, April 16, 2001).

Conclusions
Page 17 GAO-01-499 Licensing Hydropower Projects

can increase the time and costs to obtain a license. As a result, FERC will

not be able to reach informed decisions on the need for further

administrative reforms or legislative changes to the licensing process.

We recommend that the Federal Energy Regulatory Commission inform

the Congress of the extent that time and cost data limitations restrict its

ability to reach informed decisions on whether further administrative

reforms or legislative changes are needed to shorten the hydropower

licensing process or make it less costly. We also recommend that the

Commission work with other federal and state agencies and licensees to

(1) collect complete and accurate data on process-related time and costs

by participant, project, and process step and (2) link time and costs to

projects displaying similar characteristics in order to identify those

project, process, and outcome characteristics that can increase the time

and costs to obtain a license. In addition, we recommend that the

Commission (1) establish a schedule and firm deadlines for implementing

the necessary enhancements to its management information systems that

are required to track and analyze process-related time and costs and (2)

share these data with other parties involved or interested in the process.

We provided a draft of this report to the Chairman of FERC for his review

and comment. FERC generally agreed with our characterization of the

licensing process and the primary issues that affect time and costs. It also

agreed that it does not systematically collect complete and accurate data

on process-related time and costs by participant, project, and process step.

However, FERC believes that these data are not needed to reach informed

decisions on the effectiveness of recent reforms to the licensing process as

well as the need for further reforms to the process. Rather, it thinks that it

can address the salient issues by developing “targeted analyses” to

determine major factors affecting licensing time and costs based, in part,

on its “years of experience” with the licensing process. However, we

continue to believe that good time and cost data are needed to reach good

decisions. Without such data, it will not be possible for the Commission to

determine how much either can be reduced. Moreover, without these data

and the ability to link time and costs to projects, processes, and outcomes,

FERC increases the risk that any reforms that it recommends may not only

not reduce process-related time and costs but also result in unintended

consequences to the outcomes of the process.

FERC’s comments and our responses appear in appendix IV.

Recommendations to

the Federal Energy

Regulatory

Commission

Agency Comments

and Our Evaluation
Page 18 GAO-01-499 Licensing Hydropower Projects

We conducted our work from August 2000 through April 2001 in

accordance with generally accepted government auditing standards.

Appendix III contains the details of our scope and methodology.

We are sending copies of this report to the Honorable Norm Dicks,

Ranking Minority Member, Subcommittee on Interior and Related

Agencies, House Committee on Appropriations, and the Honorable Curt

Hebert, Jr., Chairman, Federal Energy Regulatory Commission. The report

is also available on GAO’s home page at http://www.gao.gov. If you have

any questions about this report, please call Charles S. Cotton or me at

(202) 512-3841. Key contributors to this report are listed in appendix V.

Barry T. Hill

Director, Natural Resources

 and Environment
Appendix I: FERC’s Traditional Licensing

Process

Page 19 GAO-01-499 Licensing Hydropower Projects

Appendix I: FERC’s Traditional Licensing

Process

3-Stage Consultation Phase 

Traditional Licensing Process

Federal Energy Regulatory 

Commission dispute resolution

Notice of Intent

First Stage

Initial Consultation 

Package and Joint meeting

Comments and 

decision on studies

Second Stage

Comment on 

draft application

Third Stage 

Application Filed

Pre-application 

process begins

Study completion

Draft application

Request for 401 Water 

Quality Certification

Public notice of 

application (tendering)

Additional study 

request, if any

Adequacy review

Public notice (acceptance)

Comments and intervention

Scoping notice and first scoping document

Additional Information Requests 

and response to additional studies

Scoping meeting

Scoping comments

Second scoping document and 

Additional Information Requests

Ready for Environmental Analysis

Recommendations, 

mandatory conditions

Draft Environmental 

Assessment or Environmental 

Impact Statement

Comments on draft 

Environmental Assessment

or Environmental Impact

Statement

10(j) meeting

Final 

Environmental 

Assessment or

Environmental 

Impact Statement

Post-Application Analysis Phase

License 

decision
Appendix II: FERC’s Alternative Licensing

Process

Page 20 GAO-01-499 Licensing Hydropower Projects

Appendix II: FERC’s Alternative Licensing

Process

Pre-Application Phase

Alternative Licensing Process

Post-Application Phase

Initial meeting (Initial Information Package/Scoping)

Scoping comments, study request

Conduct studies, issue results

Study comments, 

additional studies (if needed)

Preliminary Draft 

Environmental 

Assessment or

Environmental Impact 

Statement

Recommendations, 

draft conditions, 

settlement agreement

Application Filed

Draft Environmental Assessment

or Environmental Impact Statement

Final Environmental Assessment

or Environmental Impact Statement

License Decision

Alternative Licensing Process begins
Appendix III: Objectives, Scope, and

Methodology

Page 21 GAO-01-499 Licensing Hydropower Projects

Concerned about the licensing of nonfederal hydropower projects,

Representative Ralph Regula, former Chairman, Subcommittee on Interior

and Related Agencies, House Committee on Appropriations, asked us to

identify and assess significant issues related to the licensing process. As

agreed, this report discusses (1) why the licensing process now takes

longer and costs more than it did when FERC issued most original licenses

several decades ago; (2) whether participants in the licensing process

agree on the need for, and type of, further reforms to the process to reduce

time and costs; and (3) whether available time and cost data are sufficient

to reach informed decisions on the effectiveness of recent reforms and the

need for further reforms to the process.

To identify how the licensing process has changed since FERC issued

most of its original licenses several decades ago, we reviewed relevant

laws, regulations, court decisions, and guidance affecting hydropower

licensing. We interviewed officials from FERC, federal land and resource

agencies, states, industry, and nongovernmental organizations involved in

the licensing process. We also reviewed pertinent documents from these

sources as well as other independent analyses from academia and the

private sector.

To identify the extent of agreement among participants in the licensing

process on the need for, and type of, reforms to the process, we (1)

attended all six of the public meetings that FERC held in January 2001 and

(2) reviewed the formal written comments provided to FERC by February

1, 2001, as part of its statutorily required review of the licensing process.

We also met with and obtained data from federal and state agencies,

licensees, industry, nongovernmental organizations, and academia. In

addition, we reviewed pertinent documents, including congressional

testimonies. We also visited two hydropower projects currently involved

in the licensing process, and interviewed participants involved in several

other recent or ongoing licensing processes.

To identify the availability of time and cost data on which to base FERC’s

May 8, 2001, report on reducing process-related time and costs, we

reviewed FERC databases as well as those of other federal agencies and

nongovernmental organizations involved in the process. We also

interviewed officials from FERC, federal and state land and resource

agencies, industry, and nongovernmental organizations. We assessed the

adequacy of FERC’s data and information systems by examining the scope

and content of its project files and databases. We then held interviews

with FERC project managers, information specialists, and analysts to

determine the availability of project and step-specific data on processing

Appendix III: Objectives, Scope, and

Methodology
Appendix III: Objectives, Scope, and

Methodology

Page 22 GAO-01-499 Licensing Hydropower Projects

time and costs. In addition, we examined a survey instrument developed

by FERC to gather information on licensing time and costs from

participants at the public meetings. We also reviewed FERC’s strategic

plan for fiscal years 2000 through 2005 prepared under Government

Performance and Results Act of 1993 as well as its plans to enhance its

existing information and tracking systems. We also interviewed FERC

officials concerning their future information and technology plans.

We conducted our work from August 2000 through April 2001 in

accordance with generally accepted government auditing standards.
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 23 GAO-01-499 Licensing Hydropower Projects

Appendix IV: Comments From the Federal

Energy Regulatory Commission

See comment 1.
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 24 GAO-01-499 Licensing Hydropower Projects

See comment 2.

See comment 1.

See comment 1.

See comment 1.
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 25 GAO-01-499 Licensing Hydropower Projects

See comment 10.

See comment 9.

See comment 8.

See comment 7.

See comment 6.

See comment 5.

See comment 4.

See comment 3.
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 26 GAO-01-499 Licensing Hydropower Projects

See comment 1.

See comment 15.

See comment 14.

See comment 13.

See comment 12.

See comment 11.
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 27 GAO-01-499 Licensing Hydropower Projects

See comment 19.

See comment 18.

See comment 17.

See comment 16.

See comment 1.
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 28 GAO-01-499 Licensing Hydropower Projects

See comment 22.

See comment 22.

See comment 1.

See comment 21.

See comment 20.

See comment 19.
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 29 GAO-01-499 Licensing Hydropower Projects

Comment 1: FERC states that our audit work concluded almost 3 months

ago and suggests that our conclusions are premature. However, nothing

has changed during the intervening 3 months. FERC still does not have the

data needed to reach informed decisions on the effectiveness of recent

reforms to the licensing process or on the need for further reforms to the

process. As reflected in their comments below, FERC’s position has not

changed. It does not believe that it needs to systematically collect

complete and accurate data on process-related time and costs by

participant, project, and process step to reach informed decisions on the

effectiveness of recent reforms to the licensing process as well as the need

for further reforms to the process. Rather, it thinks that it can address the

salient issues by developing “targeted analyses” to determine major factors

affecting licensing time and costs based, in part, on its “years of

experience” with the licensing process. However, we continue to believe

that good data are needed to reach good decisions. Moreover, without

complete and accurate time and cost data and the ability to link time and

costs to projects, processes, and outcomes, FERC increases the risk that

any reforms that it recommends may not only not reduce process-related

time and costs but also result in unintended consequences to the

outcomes of the process.

Comment 2: According to FERC, systematically collecting complete and

accurate data on process-related time and costs by participant, project,

and process step would “divert money and staff away from the licensing

process.” Conversely, we believe that the money would be well spent, if it

resulted in informed decisions on the need for further reforms to the

licensing process to reduce time and costs. In fact, FERC’s comment

seems inconsistent with its own strategic plan. In its Strategic Plan for

Fiscal Years 2000-2005, FERC states that “accurate and timely information

is essential for external customers and staff alike.” Therefore, we did not

make any changes to the report on the basis of this comment.

Comment 3: We disagree with this comment. FERC states that requiring or

requesting that licensees, federal and state agencies, tribes, nongovernment organizations, and members of the public provide additional

time and cost data would “burden these entities unduly.” FERC also

asserts that it cannot compel federal agencies to submit additional time

and cost data. We recognize that providing the data will take time and cost

money. However, we fail to see how doing so would unduly burden

participants in the licensing process. Obtaining a license is not a yearly

event. Rather, it occurs once every 30 to 50 years. Moreover, we never

recommended or suggested that FERC collect time and cost data from

tribes, non-government organizations, and members of the public. In

GAO Comments
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 30 GAO-01-499 Licensing Hydropower Projects

addition, while FERC cannot compel federal agencies to submit additional

time and cost data, it is not prohibited from requesting that the agencies

provide this information and federal agencies appear willing to do so. For

instance, in responding to our June 2000 report on recovering federal

hydropower licensing costs,1

 federal agencies agreed to ensure that their

financial management and reporting systems were capable of producing

accurate, timely, and reliable information on hydropower-program-related

administrative costs.

Comment 4: We did not make any changes to the report on the basis of this

comment. FERC observes that “it has always been charged under FPA

section 10(a)(1) with balancing all relevant public interest considerations.”

While this statement is true, congressional dissatisfaction with FERC’s

efforts to carry out this responsibility led to a 1986 amendment to FPA,

which required FERC to give “equal consideration” to water power

development and other resource needs, including protecting and

enhancing fish and wildlife, when deciding whether to issue an original or

a renewed license. This amendment was one of a series of statutes enacted

subsequent to the passage of FPA that specifically required FERC and

other federal agencies to consider resource needs in addition to water

power development. We used the 1986 amendment to illustrate the

increasing complexity of the licensing process.

Comment 5: We agree that FERC is not charged with assuring that

hydropower projects it licenses are economically viable. However, as

stated in its September 2000 strategic plan, FERC does attempt to

“optimize hydropower benefits by improving the environmental

performance of projects while preserving hydropower as an economically

viable energy source.”

2

 Since the language in our report is consistent with

the language in FERC’s strategic plan, we did not make any changes to the

report on the basis of FERC’s comment.

Comment 6: We revised the report to state that FERC does not

systematically collect much of the needed time and cost data.

Comment 7: We revised the report to make clear that, if a license expires

while a project is undergoing relicensing, FERC issues an annual license,

 1 Hydropower Relicensing: Federal Costs Are Not Being Recovered (GAO/RCED-00-107,

June 30, 2000).

2 Strategic Plan for Fiscal Years 2000-2005, FERC (Sept. 2000).
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 31 GAO-01-499 Licensing Hydropower Projects

allowing a project to continue to operate under the conditions found in the

original license until the relicensing process is complete.

Comment 8: We revised the report to add “affected Indian tribes.”

Comment 9: We agree with FERC that only parties to the licensing process

may (1) file an application for a rehearing with FERC within 30 days of

FERC’s licensing decision and (2) obtain a judicial review of FERC’s

decision in the relevant federal appeals court within 60 days after FERC’s

order on the application for a rehearing. Therefore, we revised the report

accordingly.

Comment 10: We revised the report to state that FPA authorizes federal

and state agencies, other than FERC, to influence license terms and

conditions, and in some instances, precludes FERC from altering license

conditions imposed by other agencies.

Comment 11: We revised the report to state that section 4(e) of FPA makes

licenses for projects on federal lands reserved by the Congress for other

purposes—such as national forests—or that use surplus water from

federal dams subject to mandatory conditions imposed by the head of the

federal agency responsible for managing the lands or facilities.

Comment 12: We mentioned section 10(j) to emphasize the increased role

of federal and state fish and wildlife agencies in the licensing process sine

enactment of the Electric Consumers Protection Act of 1986. We revised

the report to more clearly reflect this.

Comment 13: We revised the report to delete “adversely.”

Comment 14: We revised the report to state that participants who believe

that further reforms are needed to reduce the time and costs to obtain a

new license cannot agree on what further reforms are needed to shorten

the process and make it less costly.

Comment 15: FERC notes that our report states that many licensees,

federal and state agencies, and environmental groups believe that FERC

has not provided necessary leadership and direction; however, we do not

cite what is lacking. FERC then provides examples of recent actions that it

has taken that it believes provide leadership and direction. We recognize

that FERC has taken actions intended to shorten the licensing process or

make it less costly and provide examples of these actions under the

subcaption “Some Licensing Participants Are Satisfied With the Current
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 32 GAO-01-499 Licensing Hydropower Projects

Process.” We also cite one of the most often mentioned concerns about

FERC; that is, its lack of leadership and direction during the preapplication consultation phase when much of their process-related time

and costs can be incurred. Moreover, FERC is aware of these concerns

since they were raised at the public meetings that FERC held as part of its

mandated review of its licensing process.

Comment 16: We revised the report to state that, as of February 2001,

FERC had compiled data on licensees’ process-related licensing costs for

83—or about 20 percent—of the 395 projects with licenses pending or

issued between January 1, 1993, and December 31, 2000. FERC did not

provide us with any new data subsequent to February 2001.

Comment 17: We revised the report to make a clearer the link between

data and outcomes. Specifically, we state that without complete and

accurate time and cost data and the ability to link time and costs to

projects, processes, and outcomes, FERC will not be able to assess the

extent to which the observations and suggestions—or any administrative

reforms or legislative changes that it may recommend—might (1) reduce

the time and costs to obtain a license or (2) change the outcomes of the

process.

Comment 18: We did not make any changes to the report on the basis of

this comment. Rather, FERC’s comment, which does not identify any

completion dates for either phase of its system development, supports our

finding that it has not established a schedule with firm deadlines for

developing a system to track process-related time and costs.

Comment 19: We revised the report to delete the two sentences in

question. The one-time difficulties incurred in shifting from an old tracking

system to a new one are not germane to our finding that FERC has not

established a schedule with firm deadlines for developing a system to

track process-related time and costs.

Comment 20: FERC states that it is not aware of its staff’s refusal to share

data with other agencies. However, documentation that we obtained from

the Department of the Interior shows that Interior asked for, but was not

provided, the process-related time and cost data that FERC had collected.
Appendix IV: Comments From the Federal

Energy Regulatory Commission

Page 33 GAO-01-499 Licensing Hydropower Projects

As a result, Interior had to independently collect and analyze processrelated time data from FERC’s information and tracking systems.3

Comment 21: According to FERC, at a February 13, 2001, meeting, it

requested that other federal agencies provide it with their process-related

time and cost data. FERC states that it did not receive the data. However,

as we reported in June 2000, FERC has not provided these agencies with

guidance on what and how process-related costs should be reported4

 and

continues to decline to do so. Therefore, we did not make any changes to

the report on the basis of this comment.

Comment 22: Appendixes I and II correspond exactly to the sequence of

steps in the handouts and viewgraphs presented by FERC at the public

meetings held in six cities in January 2001 as part of its mandated review

of the licensing process. Therefore, we did not make any changes to the

report on the basis of these comments.

 3 Hydropower Licensing Policies, Procedures, and Regulations – Comprehensive Review,

Department of the Interior (Docket No. PL01-1-000, April 16, 2001).

4 Hydropower Relicensing: Federal Costs Are Not Being Recovered (GAO/RCED-00-107,

June 30, 2000).
Appendix V: GAO Contacts and Staff

Acknowledgments

Page 34 GAO-01-499 Licensing Hydropower Projects

Barry T. Hill, (202) 512-3841

Charles S. Cotton, (202) 512-3841

In addition to those named above, Jerry Aiken, Paul Aussendorf, Erin

Barlow, David Goldstein, Richard Johnson, Chester Joy, and Arvin Wu

made key contributions to this report.

Appendix V: GAO Contacts and Staff

Acknowledgments

GAO Contacts

Acknowledgments

(141463)
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