GAO-13-230R Homeland Defense 

United States Government Accountability Office 

Washington, DC 20548

February 28, 2013

The Honorable Robert Wittman

Chairman

The Honorable Madeleine Z. Bordallo

Ranking Member

Subcommittee on Readiness

Committee on Armed Services

House of Representatives

The Honorable J. Randy Forbes

House of Representatives

Subject: Homeland Defense: DOD’s Aerospace Control Alert Basing Decision Was Informed 

by Various Analyses

Since the September 11, 2001, terrorist attacks, the federal government has undertaken 

extensive efforts to protect U.S. airspace. As a part of the federal government’s overall 

efforts to protect U.S. airspace, the Department of Defense (DOD) performs Operation 

Noble Eagle, which consists of several missions, including aerospace control alert (ACA).

1

The ACA mission includes aerospace control forces arrayed in a rapid response posture to 

conduct both air sovereignty and air defense operations against airborne threats.2

Our prior work has highlighted improvements and challenges in the planning and 

management of the ACA operation, including challenges related to the North American 

Aerospace Defense Command’s (NORAD) and DOD’s ability to balance risks, costs, and 

benefits when making decisions about the ACA operation. Specifically, in January 2009 we 

Among 

other things, this includes fighter aircraft and trained personnel on alert 24-hours a day, 365 

days a year, at 16 alert basing locations across the contiguous United States and one each 

in Alaska and Hawaii to deter, respond to, and if necessary defeat airborne threats over the 

United States and Canada. These fighter aircraft and trained personnel can be the last line 

of multiple layers of the air defense of the United States.

 

1

DOD formerly referred to the ACA operation as “air sovereignty alert (ASA).” 

2

Air sovereignty refers to a nation’s inherent right to exercise absolute control and authority over the airspace 

above its territory. Air defense refers to defensive measures designed to destroy attacking enemy aircraft or 

missiles in the atmosphere, or to nullify or reduce the effectiveness of such attack. See Joint Chiefs of Staff, Joint 

Pub. 1-02, Department of Defense Dictionary of Military and Associated Terms (Nov. 8, 2010; as amended 

through Nov.15, 2012).
Page 2 GAO-13-230R Homeland Defense 

reported on shortcomings in DOD’s management approach to the ACA operation.3 Among 

other things, we reported that NORAD faced difficulty determining the appropriate levels and 

types of units, personnel, and aircraft for the ACA operation. We made five

recommendations to DOD to improve management of the ACA operation, including 

conducting routine risk assessments as part of a risk-based management approach. DOD 

fully or partially agreed with all our recommendations. In January 2012, we reported that the 

Air Force had taken steps to implement one recommendation and partially implement the 

other four recommendations.4

In 2012, based on the desire to find savings in the ACA operation that did not impede 

operational effectiveness, DOD determined that two ACA basing locations could be taken off 

24-hour alert. The two locations are Duluth, Minnesota and Langley, Virginia.

We also reported on strengths and limitations of the computer 

model NORAD used for assessing domestic air defense operations, and we reported that 

NORAD had not considered cost in its analysis of the ACA basing strategy. NORAD and 

DOD had taken some action to improve their risk-based management approach; however, 

we made seven additional recommendations in January 2012 for NORAD and DOD to 

implement a more complete risk-based management approach that balances risk and cost

for the ACA operation. DOD agreed with one recommendation, partially agreed with the 

other six, and highlighted actions it would take to implement the intent of the 

recommendations.

You asked us to review DOD’s analyses regarding its decision to change the alert status for 

those two ACA locations. This report assesses (1) the analyses NORAD and DOD 

conducted in support of the decision to change the alert status at two NORAD ACA basing 

locations, and (2) the extent to which DOD estimated costs or cost savings resulting from its 

decision.

Scope and Methodology

To assess NORAD’s and DOD’s analyses used in their decision to change the alert status at 

two NORAD ACA basing locations, we reviewed and analyzed applicable documentation 

and interviewed relevant officials at NORAD, the Office of the Assistant Secretary of 

Homeland Defense and Americas’ Security Affairs, the Office of the Secretary of Defense 

Office of Cost Assessment and Program Evaluation (CAPE), the U.S. Air Force, the National 

Guard Bureau, and the Air National Guard. We also reviewed prior GAO reports that 

recommended NORAD and DOD use a risk-based management approach to the ACA 

operation.5

 

3

GAO, Homeland Defense: Actions Needed to Improve Management of Air Sovereignty Alert Operations to 

Protect U.S. Airspace, 

Drawing from our previous assessments to understand NORAD’s ACA model, 

we interviewed NORAD officials who were familiar with the model to update our 

understanding of the model’s current assumptions and structure and reviewed its results 

under various scenarios. We reviewed changes or improvements to the model and risk 

assessment and compared NORAD’s and DOD’s risk assessment methodologies to GAO 

and federal government best practices and DOD criteria for risk-based management, all of 

GAO-09-184 (Washington, D.C.: Jan. 27, 2009).

4

GAO, Homeland Defense: Continued Actions Needed to Improve Management of Air Sovereignty Alert 

Operations, GAO-12-311 (Washington, D.C.: Jan. 31, 2012).

5

GAO-09-184 and GAO-12-311. 
Page 3 GAO-13-230R Homeland Defense 

which remain relevant and are described in our previous reports.6

To assess the extent to which DOD estimated the costs or cost savings as part of its 

decision to reduce two ACA basing locations from 24-hour alert status, we reviewed 

documents such as the Air Force’s budget exhibit and cost-savings estimate and 

interviewed NORAD, the Air Force, and other DOD officials. To assess the Air Force’s costsavings estimate, we used key principles we derived from cost estimating, budgeting, and 

related guidance.

In addition, we assessed 

the assumptions and structure of another computer simulation model created by CAPE to 

assess the risk of various ACA basing strategies. We observed a demonstration of the 

model using multiple assumptions, reviewed its results under the various assumptions, and 

interviewed the CAPE official who developed it. This allowed us to understand how CAPE’s 

model assessed risk in its analyses of ACA basing locations. On the basis of our 

understanding of both computer models, the results of NORAD’s and DOD’s analyses, and 

discussions with relevant officials, we assessed the reasonableness and reliability of the 

analyses that NORAD and DOD performed to change the alert status at two ACA basing 

locations.

7

We conducted this performance audit from August 2012 through February 2013 in 

accordance with generally accepted government auditing standards. Those standards 

require that we plan and perform the audit and 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.

We reviewed the Air Force’s estimate and discussed with Air Force 

officials the detailed documentation; significant cost assumptions and other key 

assumptions; reliability of the data; and the accuracy, Air Force review of, and Air Force 

validation of its cost-saving estimate.

Results in Brief

DOD’s decision to change the alert status at two ACA basing locations was informed by 

various analyses, which assessed the impact on operational effectiveness to the ACA 

operation. DOD’s analyses were based on a NORAD assessment—which included a 

computer model—a CAPE computer model, and an analysis by NORAD’s Continental U.S. 

NORAD Region. NORAD’s analyses, informed by a model developed in response to a 

recommendation in our 2009 report and bolstered by additional NORAD analysis, identified 

two basing locations that could be removed from 24-hour alert status with little impact on 

ACA capabilities overall. In our January 2012 report, we noted limitations to NORAD’s 

 

6

GAO-09-184 and GAO-12-311. 

7

We reviewed federal guidance documents related to cost estimating, accounting standards, economic analysis, 

and budgeting and identified broad themes that we believe can be applied to evaluating cost analyses and 

estimates, including those of cost savings. The guidance documents we reviewed include: GAO Cost Estimating 

and Assessment Guide, GAO-09-3SP; Office of Management and Budget Circular No. A-11, Preparation, 

Submission and Execution of the Budget (Aug. 2011, superseded by an August 2012 issuance); Federal 

Accounting Standards Advisory Board, Statement of Federal Financial Accounting Standards 4 (June 2011); 

Department of Defense Instruction 7041.3, Economic Analysis for Decisionmaking (Nov. 7, 1995); and 

Department of Defense Financial Management Regulation 7000.14-R, Volume 4, Chapter 22, Cost Funding 

(May 2010). Although each of these documents may not apply to these circumstances as a legal matter, we 

believe that these documents collectively contain broad themes that can be applied to evaluating cost analyses.
Page 4 GAO-13-230R Homeland Defense 

computer model. For example, we found that it did not include a prioritized list of 

metropolitan areas and critical infrastructure locations that NORAD should protect and that it 

did not incorporate assumptions associated with all three elements of risk: threat, 

vulnerability, and consequence. Since our January 2012 report, NORAD has strengthened 

its risk-based management approach of the ACA operation by improving its risk analyses, 

including to change some of the assumptions used to address vulnerability and 

consequence in its model. With regard to the CAPE model, the CAPE office separately 

identified a point below which the number of ACA basing locations on 24-hour alert could 

not be further reduced without materially increasing risk. Both NORAD’s and CAPE’s 

analyses identified the Duluth, Minnesota and Langley, Virginia ACA locations as the best 

candidates to take off 24-hour alert status. In addition to these two models, the Continental 

U.S. NORAD Region convened a panel of subject matter experts to discuss and analyze the 

ACA basing strategy. These experts’ analysis and conclusions were consistent with the 

results of the analysis using NORAD’s model. The Deputy’s Management Action Group—

which includes DOD senior leaders who monitor DOD’s efforts to improve its defense 

business operations—approved the decision to change the ACA alert status at the two 

basing locations.

The Air Force estimated cost savings from reducing the alert status at the two ACA basing 

locations of about $73 million over fiscal years 2013 through 2017. In our January 2012 

report, we noted that NORAD had not identified potential cost savings that could result from 

eliminating a given number of ACA basing locations on 24-hour alert. After DOD made the 

decision to remove the Duluth and Langley ACA basing locations from 24-hour alert, the Air 

Force calculated estimated cost savings. Air Force officials told us that the estimated cost 

savings are mostly from personnel who will no longer be required to fully maintain 24-hour 

alert status—by shifting from full-time to part-time status. We did not independently verify the 

Air Force’s estimated cost savings. However, we discussed with Air Force officials their level 

of review and validation of the cost-savings estimate and determined that the Air Force’s 

categories of savings were consistent with key principles of cost-savings estimates. GAO is 

not making recommendations in this report.

Background

As a component of Operation Noble Eagle,8

 

8

Operation Noble Eagle, which was initiated after the terrorist attacks of September 11, 2001, is DOD’s umbrella 

homeland defense mission for North America and Hawaii. There are a variety of operations that could be 

conducted underneath this umbrella mission. For example, NORAD could conduct irregular air patrols above 

major metropolitan areas and critical infrastructure facilities (as opposed to more regular—and predictable—

patrols) as well as maintain an alert force of fighter, tanker, and command & control aircraft. Aircraft and alert 

commitments are based on a tiered response system. As threat levels intensify, the number of aircraft on alert 

and on patrol increases.

the ACA operation is conducted by several 

DOD components under the command of NORAD for the airspace over North America, 

which includes Alaska and the contiguous United States, and under the command of U.S. 

Pacific Command for the airspace over the state of Hawaii and U.S. territories in the Pacific. 

The Joint Chiefs of Staff have directed the Air Force (among other services) to provide 

support for the ACA operation. Generally, Air National Guard aircraft and personnel are 

used for alert, consistent with the Air National Guard’s homeland defense mission. Both the 

Air Force’s Air Combat Command and the National Guard Bureau believe that Air National 

Guard units can conduct alert duty with less effect on overseas missions and at a lower cost 
Page 5 GAO-13-230R Homeland Defense 

than active-duty Air Force units.9

The ACA operation consists of ground operations that take place before fighter aircraft take 

off, including such activities as maintaining the fighter aircraft. This operation also includes 

those activities that may take place after a unit receives an alert from NORAD but before the 

aircraft are airborne. For example, pilots and maintenance personnel may rush from their 

nearby lodging facility to the alert aircraft facility, where maintenance personnel conduct final 

preparations while the pilots sit in their aircraft awaiting further instruction (battle stations). 

Alternatively, pilots may taxi the aircraft to the end of the runway and await further 

instruction (runway alert) or take off in response to the alert (scramble). Once aircraft take 

off, Air National Guard pilots in Title 32 status under the command and control of the state 

governor, automatically convert to federal Title 10 status under the command and control of 

NORAD.

The units at all ACA locations (i.e., both Air National Guard 

and active-duty personnel) are dual-tasked to conduct expeditionary missions, such as 

Operation Enduring Freedom in Afghanistan, as well as the ACA operation.

10

In response to one of the recommendations in our 2009 report—to conduct routine risk 

assessments to determine ACA requirements, including the appropriate numbers of ACA 

basing locations, personnel, and aircraft to support the ACA operation—NORAD officials 

developed a quantitative computer simulation model to study basing locations that were part 

of the ACA operation.

Within limits, NORAD can increase personnel, aircraft, and the number of ACA 

basing locations on the basis of changes in the threat conditions.

11 NORAD’s computer model provides DOD with data to assess risk of 

the ACA operation, which helps decision makers identify and evaluate potential risks 

associated with various allocations of resources. The model allows NORAD to analyze how 

changing the number and location of ACA basing locations would affect its ability to defend 

the homeland from commercial aviation attacks. The model uses real-world data on the 

opportunity for attacks from within the commercial aviation system and on NORAD’s 

operational capabilities, along with assumptions about the randomness of these factors in 

practice, to generate numerous simulated Operation Noble Eagle-related events and assess 

NORAD’s capability to defeat them.12

In 2010, NORAD used the model to analyze the pre-existing 16 ACA basing locations in the 

contiguous United States, in order to identify the potential operational performance and 

efficiencies of alternative ACA basing locations. According to NORAD officials, the results of 

By assessing ACA operational capabilities for various 

combinations of basing locations, the model helps NORAD quantify how risk would change 

if certain locations were removed from 24-hour alert status.

 

9

The National Guard Bureau is a joint function within DOD that, among other things, participates with staff from 

the Department of the Army and the Department of the Air Force in the formulation, development, and 

coordination of all programs, policies, concepts, and plans pertaining to or affecting the National Guard, the Army 

National Guard of the United States, and the Air National Guard of the United States. The Air National Guard of 

the United States is a reserve component of the U.S. Air Force.

10According to Air National Guard Instruction 10-203: Air National Guard (ANG) Alert Resource Management

(February 22, 2012), provisions will be made to ensure members automatically convert to Title 10, if a specific 

Title 10 trigger is included in higher headquarters guidance. Title 32 and Title 10 refer to sections of the United 

States Code.

11Referred to in NORAD documents as the Operation Noble Eagle Fighter Basing Location Model. 

12The algorithms that calculate different scenarios or events to determine probability of certain outcomes are 

referred to as Monte Carlo simulations.
Page 6 GAO-13-230R Homeland Defense 

this analysis led DOD officials to direct NORAD to determine which locations, if any, might 

be removed from 24-hour alert. In 2011, after DOD began to plan for the reduction of ACA 

basing locations on 24-hour alert, NORAD performed additional analyses, using both the 

NORAD model and a less complex calculation, to determine the specific ACA basing 

locations that could be taken off 24-hour alert. The analyses sought to identify the two 

locations where alert status could be reduced with the smallest impact on NORAD’s ACA 

capabilities.

In our prior reports,13

DOD’s ACA Decision Was Informed by Various Analyses that Produced 

Similar Conclusions

we stated that, as part of an overall risk-based management 

framework, routine risk assessments—which the NORAD model and related analyses help 

to address—should contain three key elements: an analysis of threat, an estimation of 

vulnerability, and identification of consequences. In our 2012 report, we noted that NORAD’s 

model was limited because it was designed to assess the ability of its aircraft to respond to a 

single type of threat regardless of its location in the United States and that it did not include 

a prioritized list of metropolitan areas and critical infrastructure NORAD should protect.

DOD’s decision to change the alert status at two ACA basing locations was informed by 

various analyses that assessed the impact on operational effectiveness to the ACA 

operation. These DOD analyses were based on a NORAD assessment—which included a 

computer model—a CAPE computer model, and a Continental U.S. NORAD Region14

DOD used the various analyses by NORAD, CAPE, and the Continental U.S. NORAD 

Region, which produced similar results, to inform its decision to reduce the alert status at 

Duluth, Minnesota and Langley, Virginia. NORAD’s analysis used criteria, such as historical 

data on the number of actual responses by each ACA basing location, and was informed by 

NORAD’s computer model. NORAD officials told us that its model’s assumptions about 

threat had not changed since our last report and that the model could not be used to 

consider some types of airborne threats. Therefore, NORAD used additional calculations of 

such things as basic fighter response times to help inform its broader analysis. We found 

that NORAD improved its risk-based management approach of the ACA operation by 

improving its risk analyses, specifically by changing some of the assumptions used to 

address vulnerability and consequence. For example, NORAD officials stated that, although 

the list of metropolitan areas and critical infrastructure had not been updated since DOD 

assessment. We assessed the analytical and methodological basis for the NORAD and 

CAPE computer simulation models and found them to be reasonable based on our 

understanding of the structure, algorithms, and outputs of these models. Although the 

methodology used in the three analyses differed, they reached similar conclusions. Based 

on the analytical conclusions, the Deputy’s Management Action Group—which includes 

DOD senior leaders who monitor DOD’s efforts to improve its defense business 

operations—approved the decision to change the ACA alert status at the two basing 

locations.

 

13GAO-12-311 and GAO-09-184. 

14A component of NORAD, the Continental U.S. NORAD Region provides airspace surveillance and control and 

directs aerospace control activities for the contiguous United States.
Page 7 GAO-13-230R Homeland Defense 

developed it after the September 11, 2001, attacks, NORAD prioritized the assets to protect, 

and its model used those priorities in its current analyses of ACA basing locations. NORAD’s 

analysis indicated that two basing locations could be removed from 24-hour alert status with 

little impact on ACA capabilities overall.

We found that DOD’s CAPE office developed its own computer model that could analyze the 

basing locations of Operation Noble Eagle, specifically, the ACA operation. CAPE’s model 

calculated population and infrastructure coverage for all combinations of ACA basing 

locations. The model used various assumptions about NORAD’s operational capabilities—

such as flight times and aircraft velocity—with a goal of optimizing the number and 

placement of the ACA basing locations that existed in the United States. In contrast to 

NORAD’s model, CAPE’s analyses made no assumptions about where threats would 

emerge and calculated NORAD’s ACA capabilities at any geographic point. CAPE’s results 

identified a point below which the number of ACA basing locations on 24-hour alert could 

not be further reduced without materially increasing risk. CAPE officials stated that their 

model could analyze numerous alternative ACA basing location scenarios more quickly than 

NORAD’s model. Although CAPE’s model was developed independently of NORAD, both 

CAPE and NORAD officials told us that they discussed the CAPE model’s assumptions with 

one another to ensure their accuracy in such areas as realistic fighter scramble times and 

operational range.

In addition to its quantitative analysis, NORAD asked its Continental U.S. NORAD Region to 

conduct a separate analysis regarding the operational efficiencies and capabilities of the 

ACA operation. This analysis relied on Continental U.S. NORAD Region subject matter 

experts on strategy, planning, logistics, and tactics for the ACA operation, rather than a

computer simulation model. According to these experts, they used criteria such as time, 

distance, major population areas, and proximity to international flight routes in measuring 

the overlapping coverage of select ACA basing locations, considering various terrorist threat 

scenarios. These experts’ analysis and conclusion were consistent with the results of 

NORAD headquarters’ analysis. NORAD officials told us that the results of the NORAD and 

Continental U.S. NORAD Region analyses were approved by the NORAD Commander and 

provided in a briefing to congressional staff.

Although the specific methods used in the various analyses of the ACA operation differed, 

we found that NORAD’s and DOD’s use of various analytical methods comprised a 

reasonable approach to evaluating changes in ACA basing locations. The NORAD model 

and response time analysis, the Continental U.S. NORAD Region analysis, and the CAPE’s 

model used different methods to evaluate the ACA operation and the risk of various ACA 

basing options. For example, the model that contributed to NORAD’s analysis uses realworld data on the opportunity for attacks from within the commercial aviation system and on 

NORAD’s operational capabilities, along with assumptions about the randomness of these 

factors in practice, and it estimated how response times would change if various ACA 

basing locations were taken off 24-hour alert. NORAD used various criteria, including 

historical data on ACA basing location responses, to determine which ACA locations could 

be taken off 24-hour alert. The Continental U.S. NORAD Region convened a panel of 

subject matter experts to analyze the ACA operation. In contrast to NORAD’s model, 

CAPE’s model made no assumptions about where threats would emerge, and calculated 

NORAD’s ACA capabilities to reach maximal populations at any geographic point. Each 

analysis concluded that taking the Duluth, Minnesota, and Langley, Virginia, ACA locations 
Page 8 GAO-13-230R Homeland Defense 

off 24-hour alert status would result in the smallest impact on ACA capabilities and not 

materially increase risk.

The results of CAPE’s independent model-driven analyses regarding the reduction of ACA 

basing locations on 24-hour alert was brought to the Deputy’s Management Action Group, 

which includes DOD senior leaders, led by the Deputy Secretary of Defense, who monitor 

DOD’s efforts to improve its defense business operations. CAPE officials stated that after 

discussing the ACA basing location options, the Deputy’s Management Action Group 

approved the decision to change the ACA alert status at the two ACA basing locations— 

Duluth, Minnesota and Langley, Virginia.

The Air Force Estimated Cost Savings to the ACA Operation

NORAD and Air Force officials told us that the Air Force estimated cost savings of $73 

million over five years after DOD made the final decision to reduce the alert status at the two 

ACA basing locations, as part of the Secretary of Defense’s efficiency initiative,15

Table 1: Estimated Cost Savings of the ACA Operation for Fiscal 

Years 2013 – 2017 

not as an 

effort to conduct a complete cost-benefit assessment of ACA basing options. In our January 

2012 report, we noted that NORAD’s 2010 analysis did not identify potential cost savings 

that could result from eliminating a given number of ACA basing locations. As noted in that 

report, an analysis that balances both risk and costs would enable NORAD, DOD, and 

Congress to make more fully-informed decisions about the number and location of ACA 

bases. According to Air Force officials, the cost-savings estimate was calculated for the 

fiscal year 2013 budget submission and included annual cost-savings estimates that ranged 

from about $9.2 million to $16.6 million for fiscal years 2013 through 2017, as shown in 

Table 1.

(in millions)

Fiscal Year Savings

2013 $9.2

2014 15.4

2015 15.8

2016 16.1

2017 16.6

Total $73.1

Source: GAO analysis of DOD data.

Air Force officials told us that the majority of the cost savings were from personnel who 

would shift from full-time to part-time status. Other areas from which the Air Force identified 

savings included decreases to operations and maintenance costs at the basing locations. 

 

15In May 2010, the Secretary of Defense publicly announced that DOD was to undertake a department-wide 

initiative to assess how the department is staffed, organized, and operated with the goal of reducing costs and 

modernizing, among others, its weapons portfolio. The Secretary’s initiative targeted both short- and long-term 

improvements and set specific goals and targets for achieving cost savings and efficiencies, which are expected 

to be achieved between fiscal years 2012 and 2016.
Page 9 GAO-13-230R Homeland Defense 

We did not independently verify the Air Force’s estimated cost savings. However, we 

compared the Air Force’s estimate to key principles we derived from cost estimating, 

budgeting, and related guidance. For example, a cost-savings estimate should have an 

appropriate level of detailed documentation, all significant costs and key assumptions 

should be included, the reliability of the data to develop the estimate should be assessed, 

and the accuracy of the calculations should be verified or validated. According to Air Force 

officials, the cost-savings estimate was reviewed and verified by knowledgeable high-level 

Air Force, National Guard Bureau, and CAPE officials to ensure that costs were valid, key 

assumptions were included, and the calculations were accurate and reliable. Therefore, we 

determined that the Air Force’s categories of savings were consistent with the key principles 

of preparing cost-savings estimates.

Agency Comments

NORAD and DOD reviewed a draft of this report and provided technical comments, which 

we incorporated as appropriate.

We are sending copies of this report to appropriate congressional committees, the Secretary 

of Defense, the Commander of NORAD, the Secretary of the Air Force, and the Chief of the 

National Guard Bureau. This report also is available at no charge on our Web site at 

http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me at (202) 512-

6912 or gamblerr@gao.gov. Contact points for our Offices of Congressional Relations and 

Public Affairs may be found on the last page of this report. GAO staff who made major 

contributions to this report are listed in the enclosure.

Rebecca Gambler

Director

Defense Capabilities and Management

Enclosure
Page 10 GAO-13-230R Homeland Defense 

Enclosure: GAO Contact and Staff Acknowledgments

GAO Contact

Rebecca Gambler, (202) 512-6912 or gamblerr@gao.gov

Staff Acknowledgments

In addition to the contact named above, Joseph Kirschbaum, Assistant Director; Pat L 

Bohan; Susan Ditto; Gregory Marchand; Charles Perdue; Carol Petersen; Amie Steele; Jeff 

Tessin; and Ed Yuen made significant contributions to the report.

(351767) 
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