Wildland Fire Suppression: Better Guidance Needed to Clarify Sharing of Costs between Federal and Nonfederal Entities
Published: 2006-06-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Wildland fires can burn or threaten both federal and nonfederal lands and resources, including homes in or near wildlands, an area commonly called the wildland-urban interface. Agreements between federal and nonfederal firefighting entities provide the framework for working together and sharing the costs of fire suppression efforts. GAO was asked to (1) review how federal and nonfederal entities share the costs of suppressing fires that burn or threaten both of their lands and resources and (2) identify any concerns that these entities may have with the existing cost-sharing framework. This testimony is based on GAO's May 2006 report Wildland Fire Suppression: Lack of Clear Guidance Raises Concerns about Cost Sharing between Federal and Nonfederal Entities (GAO-06-570).
section_title: What GAO Found
paragraphs: Federal and nonfederal entities used a variety of methods to share the costs of fighting wildland fires affecting both of their lands and resources. Cooperative agreements between federal and nonfederal firefighting entities--which are developed and agreed to by the entities involved--provide the framework for cost sharing and typically list several cost-sharing methods available to the entities. The agreements GAO reviewed, however, often lacked clear guidance for federal and nonfederal officials to use in deciding which method to apply to a specific fire. As a result, cost-sharing methods were applied inconsistently within and among states, even for fires with similar characteristics. For example, GAO found that in one state, the costs for suppressing a large fire that threatened homes were shared solely according to the proportion of acres burned within each entity's area of fire protection responsibility, a method that traditionally has been used. Yet, costs for a similar fire within the same state were shared differently. For this fire, the state agreed to pay for certain aircraft and fire engines used to protect the wildland-urban interface, while the remaining costs were shared on the basis of acres burned. In contrast to the two methods used in this state, officials in another state used yet a different cost-sharing method for two similar large fires that threatened homes, apportioning costs each day for personnel, aircraft, and equipment deployed on particular lands, such as the wildland-urban interface. The type of cost-sharing method ultimately used is important because it can have significant financial consequences for the entities involved, potentially amounting to millions of dollars. Both federal and nonfederal agency officials raised a number of concerns about the current cost-sharing framework. First, some federal officials were concerned that because guidance is unclear about which cost-sharing methods are most appropriate in particular circumstances, it can be difficult to reach agreement with nonfederal officials on a method that all parties believe distributes suppression costs equitably. Second, some nonfederal officials expressed concerns that the emergence of alternative cost-sharing methods is causing nonfederal entities to bear a greater share of fire suppression costs than in the past. In addition, both federal and nonfederal officials believed that the inconsistent application of these cost-sharing methods has led to inequities among states in the proportion of costs borne by federal and nonfederal entities. Finally, some federal officials also expressed concern that the current framework for sharing costs insulates state and local governments from the increasing costs of protecting the wildland-urban interface. Therefore, nonfederal entities may have a reduced incentive to take steps that could help mitigate fire risks, such as requiring homeowners to use fire-resistant materials and landscaping. On the basis of a review of previous federal reports and interviews with federal and nonfederal officials, GAO believes that these concerns may reflect a more fundamental issue--that federal and nonfederal entities have not clearly defined their basic financial responsibilities for wildland fire suppression, particularly those for protecting the wildland-urban interface.

section_title: Letter
paragraphs: I am pleased to be here today to discuss how federal and nonfederal  entities share the costs of suppressing wildland fires that burn or threaten  both federal and nonfederal lands and resources. As you know, fighting  wildland fires—which can burn across federal, state, and local  jurisdictions—requires significant investments of firefighting personnel,  aircraft, equipment, and supplies, resulting in substantial and increasing  fire suppression expenditures. Since 2000, federal suppression  expenditures alone have averaged more than $1 billion annually.  Firefighting efforts are mobilized through an interagency incident  management system, which depends on the close cooperation and  coordination of federal, state, tribal, and local fire protection entities. At  the federal level, five principal agencies are involved in firefighting  efforts—the Forest Service within the Department of Agriculture and the  Bureau of Indian Affairs, Bureau of Land Management, Fish and Wildlife  Service, and National Park Service within the Department of the Interior.  Federal and nonfederal firefighting entities share their personnel,  equipment, and supplies and work together to fight fires, regardless of  which entity has jurisdiction over the burning lands. Agreements between  cooperating entities, commonly referred to as master agreements, govern  these cooperative fire protection efforts and include general provisions for  sharing firefighting costs.
My testimony today summarizes the findings of our report released on  June 13, 2006, which discusses (1) how federal and nonfederal entities  share the costs of suppressing wildland fires that burn or threaten both of  their lands and resources and (2) concerns federal and nonfederal entities  have with the existing cost-sharing framework. To address these  objectives, we reviewed applicable federal statutes, policies, and  procedures; and federal and nonfederal studies related to wildland fire  suppression costs. We reviewed master agreements between federal and  nonfederal entities governing cooperative fire protection in 12 western  states that frequently experience wildland fires. We also reviewed fire  records and interviewed federal and nonfederal firefighting officials to  discuss methods chosen to share suppression costs for eight recent fires— two each in Arizona, California, Colorado, and Utah—which burned or  threatened both federal and nonfederal lands and resources.
subsections: section_title: Background
paragraphs: Although wildland fires triggered by lightning are a natural, inevitable, and  in many cases a necessary ecological process, past federal fire suppression  policies have led to an accumulation of fuels and contributed to larger and  more severe wildland fires. In recent years, both the number of acres  burned by wildland fires and the costs to suppress fires have been  increasing. From 1995 through 1999, wildland fires burned an average of  4.1 million acres each year; from 2000 through 2004, the fires burned an  average of 6.1 million acres each year—an increase of almost 50 percent.  During the same periods, the costs incurred by federal firefighting entities  to suppress wildland fires more than doubled, from an average of  $500 million annually to about $1.3 billion annually. Although efforts to  fight these larger, more severe fires have accounted for much of the  increase in suppression costs, the continuing development of homes and  communities in areas at risk from wildland fires and the efforts to protect  these structures also contribute to the increasing costs. Forest Service and  university researchers estimate that about 44 million homes in the lower  48 states are located in the wildland-urban interface. When fire threatens  the wildland-urban interface, firefighting entities often need to use  substantial resources—including firefighters, fire engines, and aircraft to  drop retardant—to fight the fire and protect homes.
As wildland fire suppression costs have continued to rise, increasing  attention has focused on how suppression costs for multijurisdictional  fires are shared. To share suppression costs for a specific fire, local  representatives of federal and nonfederal firefighting entities responsible  for protecting lands and resources affected by the fire—guided by the  terms of the master agreement—decide which costs will be shared and for  what period. They document their decisions in a cost-sharing agreement  for that fire. According to federal officials, cooperating entities  traditionally shared suppression costs on the basis of the proportion of  acres burned in each entity’s protection area because the method was  relatively easy to apply and works well when the lands affected by a  wildland fire are similar. Officials said that the use of alternative cost- sharing methods has been increasing in recent years.
section_title: Unclear Guidance and Inconsistent Application of Cost- Sharing Methods Can Have Significant Financial Consequences for Entities Involved
paragraphs: Federal and nonfederal entities included in our review used a variety of  methods to share the costs of fighting fires that burned or threatened both  federal and nonfederal lands and resources. Although master agreements  between federal and nonfederal entities typically listed several cost- sharing methods, the agreements often lacked clear guidance for officials  to follow in deciding which cost-sharing method to apply to a specific fire.  Consequently, for eight fires we reviewed in four states, we found varied  cost-sharing methods used and an inconsistent application of these  methods within and among states, although the fires had similar  characteristics. The type of cost-sharing method chosen is important  because it can have significant financial consequences for the federal and  nonfederal entities involved.
subsections: section_title: Master Agreements Provided Cost-Sharing Framework, but Those We Reviewed Lacked Clear Guidance
paragraphs: Master agreements provide the framework for federal and nonfederal  entities to work together and share the costs of fighting wildland fires. The  master agreements we reviewed for 12 western states all directed federal  and nonfederal entities to develop a separate agreement, documenting  how costs were to be shared for each fire that burned—or, in some cases,  threatened to burn—across multiple jurisdictions. The master agreements  varied in the cost-sharing methods specified:    The master agreement for 1 state (Idaho) did not identify any specific cost- sharing method to use.
The master agreements for 3 states (Alaska, Arizona, New Mexico) listed  the acres-burned method as the primary or only method to be used.  Although two of these agreements allowed the use of alternative cost- sharing methods, they did not explicitly state under what circumstances  an alternative method would be appropriate.
The master agreements for 8 remaining states listed multiple, alternative  cost-sharing methods but did not provide clear guidance on when each  method should be used.
section_title: Cost-Sharing Methods Were Inconsistently Applied for the Eight Fires We Reviewed
paragraphs: Federal and nonfederal entities used varied cost-sharing methods for the  eight fires we reviewed, although the fires had similar characteristics. As  shown in figure 1, the cost-sharing methods used sometimes varied within  a state or from state to state.
The costs for the two fires that we reviewed in Utah were shared using  two different methods, although both fires had similar characteristics.
For the Blue Springs Fire, federal and nonfederal officials agreed that  aircraft and engine costs of protecting an area in the wildland-urban  interface during a 2-day period would be assigned to the state and the  remaining costs would be shared on the basis of acres burned. Federal and  state officials explained that, because the Blue Springs Fire qualified for  assistance from the Federal Emergency Management Agency (FEMA),  state officials agreed to bear a larger portion of the total fire suppression  costs.
For the Sunrise Complex of fires, in contrast, state officials were reluctant  to share costs in the same manner. Although these fires also threatened  the wildland-urban interface, they did not meet the eligibility requirements  for FEMA reimbursement of nonfederal costs. Consequently, federal and  nonfederal officials agreed to share costs for the Sunrise Complex on the  basis of acres burned.
The costs for the two fires we reviewed in Arizona were also treated  differently from each other.
For the Cave Creek Complex of fires, federal and state officials agreed to  share suppression costs using an acres-burned method for the southern  portion of the complex, which encompassed federal, state, and city lands  and required substantial efforts to protect the wildland-urban interface.  The federal government paid the full costs for the northern portion of the  fire.
For the Florida Fire, federal and nonfederal officials were unable to reach  an agreement on how to share costs. Officials from the affected national  forest proposed a cost-sharing agreement, whereby the state would pay  the costs of firefighting personnel, equipment, and aircraft used to protect  the wildland-urban interface, and all other fire suppression costs would be  paid by the federal government. The state official, however, did not agree  with this proposal. He believed that the Forest Service, not the state, was  responsible for protecting areas of the wildland-urban interface threatened  by the Florida Fire and that he was not authorized to agree to the terms of  the proposed agreement.
Methods used to share suppression costs for fires with similar  characteristics also varied among states. For example, costs for the fires  we reviewed in California and Colorado were shared using methods  different from those used for similar fires we reviewed in Arizona and  Utah.
In California, federal and nonfederal officials agreed to share the costs of  two fires using the cost-apportionment method—that is, costs were  apportioned on the basis of where firefighting personnel and equipment  were deployed. Officials said that they had often used this method since  the mid-1980s because they believed that the benefit it provides in more  equitable cost sharing among affected firefighting entities outweighs the  additional time required to apportion the costs.
In Colorado, federal and nonfederal officials agreed to share suppression  costs for both of the fires we reviewed in that state using guidance they  had developed and officially adopted in 2005, called “fire cost share  principles.” Under these principles, aviation costs for fires burning in the  wildland-urban interface are shared equally for 72 hours, and other fire  suppression costs, such as firefighting personnel and equipment, are  shared on the basis of acres burned.
section_title: The Cost-Sharing Method Used Can Lead to Significantly Different Financial Outcomes
paragraphs: Having clear guidance as to when particular cost-sharing methods should  be used is important because the type of method ultimately agreed upon  for any particular fire can have significant financial consequences for the  firefighting entities involved. To illustrate the effect of the method chosen,  we compared the distribution of federal and nonfederal costs for the five  fires we reviewed in which the actual cost-sharing method used was not  acres burned with what the distribution would have been if the method  used had been acres burned. We found that the distribution of costs  between federal and nonfederal entities differed, sometimes substantially,  depending on the cost-sharing method used. The largest differences  occurred in California, which used the cost apportionment method.
For the Deep Fire, using the cost-apportionment method, federal entities  paid $6.2 million, and nonfederal entities paid $2.2 million. Had the costs  been shared on the basis of acres burned, federal entities would have paid  an additional $1.7 million, and nonfederal entities would have paid that  much less because most of the acres burned were on federal land.  According to federal and state officials, the nonfederal entities bore a  larger share of the cost than they would have under an acres-burned  method because of the efforts to protect nonfederal lands and resources.
For the Pine Fire, using cost apportionment, federal entities paid $5.2  million, and nonfederal entities paid $8.1 million. Had an acres-burned  method been used, federal entities would have paid about $2 million less,  and nonfederal entities would have paid that much more. According to a  federal official who worked on apportioning costs for that fire, the higher  costs that the federal entities paid under cost apportionment were largely  due to extensive firefighting efforts on federal land to ensure that the fire  was extinguished.
In Colorado and Utah, the differences in federal and state entities’ shares  between the methods used and the acres-burned method were less  pronounced, likely because the cost-sharing methods used still relied  heavily on acres burned. In each case, federal entities’ shares would have  been more and nonfederal shares less had an acres-burned method been  used, due to the efforts to protect the wildland-urban interface. For  example, the federal share of costs for the Blue Springs Fire in Utah would  have been about $400,000 more and the nonfederal share that much less if  an acres-burned method had been used for the whole fire. In Colorado, we  estimated that the federal share of costs for the Mason Gulch Fire would  have been about $200,000 more and the nonfederal share that much less  under an acres-burned method.
section_title: Current Cost-Sharing Framework Raises Several Concerns
paragraphs: Federal and nonfederal agency officials we interviewed raised a number of  concerns about the current cost-sharing framework. First, some federal  officials said that because master agreements and other policies do not  provide clear guidance about which cost-sharing methods to use, it has  sometimes been difficult to obtain a cost-sharing agreement that they  believe shares suppression costs equitably. Second, nonfederal officials  were concerned that the emergence of alternative cost-sharing methods  has caused nonfederal entities to bear a greater share of fire suppression  costs than in the past. Finally, some federal officials expressed concern  that the current framework for sharing costs insulates state and local  governments from the cost of protecting the wildland-urban interface,  thereby reducing their incentive to take steps that could help mitigate fire  risks and reduce suppression costs in the wildland-urban interface. We  believe these concerns may reflect a more fundamental issue—that is, that  federal and nonfederal entities have not clearly defined their financial  responsibilities for wildland fire suppression, particularly for the wildland- urban interface.
subsections: section_title: Lack of Clear Guidance Can Lead to Difficulties in Sharing Costs
paragraphs: Some federal officials said that the lack of clear guidance can make it  difficult to agree to use a cost-sharing method that they believe equitably  distributes suppression costs between federal and nonfederal entities,  particularly for fires that threaten the wildland-urban interface. As  discussed, different cost-sharing methods were used for the two fires we  reviewed in Utah, even though both fires required substantial suppression  efforts to protect the wildland-urban interface. A federal official said that  because of the state officials’ unwillingness to use a method other than  acres burned on one of the fires and because of the lack of clear guidance  about which cost-sharing method should be used, he agreed to use an  acres-burned method and did not seek a cost-sharing agreement that  would have assigned more of the costs to the nonfederal entities. Some  federal officials in Arizona expressed similar views, saying that the lack of  clear guidance on sharing costs can make it difficult to reach agreement  with nonfederal officials. For example, federal and state officials in  Arizona did not agree on whether to share costs for one fire we reviewed  in that state.
Officials from the Forest Service’s and the Department of the Interior’s  national offices agreed that interagency policies for cost sharing could be  clarified to indicate under what circumstances particular cost-sharing  methods are most appropriate. They said that the acres-burned method,  for example, is likely not the most equitable method to share costs in cases  where fires threaten the wildland-urban interface. Officials noted that the  National Fire and Aviation Executive Board—made up of the fire directors  from the five federal land management agencies and a representative from  the National Association of State Foresters—was developing a template  for both master and cost-sharing agreements. As of May 2006, this  template had not been finalized, but our review of a draft version indicated  that the template might not provide additional clarity about when each  cost-sharing method should be used.
section_title: Nonfederal Officials Were Concerned about Increased Costs and Equity among States
paragraphs: While federal officials expressed the need for further guidance on how to  share costs, nonfederal officials were concerned that the emergence of  alternative cost-sharing methods was leading state and local entities to  bear a greater share of suppression costs than in the past, and they  questioned whether such an increase was appropriate. Nonfederal officials  also said that wildland fire suppression costs already posed budgetary  challenges for state and local entities and that using alternative cost- sharing methods more often could exacerbate the situation. State officials  said that if a state’s suppression costs in a given year exceed the funds  budgeted, they must seek additional state funds, which can be difficult.  Moreover, they said, in many states, protecting structures is primarily a  local responsibility, and many local entities are unable to pay the costs of  fighting a large fire that threatens the wildland-urban interface. Although  clarifying guidance about which cost-sharing methods are most  appropriate for particular circumstances could cause nonfederal entities  to bear more wildland fire suppression costs, over the long term, such  clarification would also allow each entity to better determine its budgetary  needs and take steps to meet them.
In addition to their concerns about increased costs, nonfederal as well as  federal officials were concerned that the federal government was treating  nonfederal entities in different states differently, thereby creating  inequities. Federal and nonfederal officials said that because some states  use particular cost-sharing methods more often than other states, the  proportion of costs borne by federal and nonfederal entities likely varies  from state to state, resulting in nonfederal entities’ paying a higher  proportion of costs in some states and a lower proportion in other states.  Clarifying which cost-sharing methods should be used in particular  situations could increase nonfederal officials’ assurance that the federal  government is treating them equitably relative to other states.
section_title: Cost-Sharing Framework May Reduce Incentives to Mitigate Fire Risks in the Wildland-Urban Interface
paragraphs: Federal officials said that the current cost-sharing framework insulates  state and local governments from the cost of protecting the wildland- urban interface. As we have previously reported, a variety of protective  measures are available to help protect structures from wildland fire  including (1) reducing vegetation and flammable objects within an area of  30 to 100 feet around a structure and (2) using fire-resistant roofing  materials and covering attic vents with mesh screens. However, some  homeowners and homebuilders resist using these protective measures  because they are concerned about aesthetics, time, or cost. As a result,  federal and nonfederal officials said, it can be politically difficult for state  and local governments to adopt—and enforce—laws requiring such  measures, and many at-risk areas have not done so. The states and  communities we visited exhibited various degrees of progress in adopting  laws requiring protective measures. For example, California requires  homeowners in the wildland-urban interface to maintain 100 feet of  defensible space and, in areas at particularly high risk from wildland fires,  also requires new structures to be constructed with fire-resistant roofing  materials and vents. The other states we visited do not have such  statewide requirements, but they are taking a variety of steps to require or  encourage protective measures. For example, Utah passed a law in 2004  requiring its counties to adopt standards for landscaping and building  materials if they want to be eligible to receive state funds to assist with fire  suppression costs. Other counties had efforts underway to educate  homeowners about measures they could use to reduce their risk without  requiring that such measures be used.
Federal officials expressed concern—and some nonfederal officials  acknowledged—that the use of cost-sharing methods that assign more  costs to federal entities, and the availability of federal emergency  assistance, insulate state and local governments from the cost of providing  wildland fire protection. These federal officials pointed out that wildland  fires threatening structures often require added suppression efforts. Under  some cost-sharing methods, such as acres burned, federal entities often  end up paying a large proportion of the costs for these efforts. Some  federal and nonfederal officials also noted that the availability of FEMA  assistance to nonfederal entities—which can amount to 75 percent of  allowable fire suppression costs for eligible fires—further insulates state  and local governments from the cost of protecting the wildland-urban  interface. Of the eight fires included in our review, nonfederal officials  were seeking reimbursement for the allowable costs of the five fires that  FEMA determined met eligibility requirements. Federal officials suggested  that to the extent that state and local governments are insulated from the  cost of protecting the wildland-urban interface, these governments may  have a reduced incentive to adopt laws requiring homeowners and  homebuilders to use protective measures that could help mitigate fire  risks. Some officials said that by requiring homeowners and homebuilders  to take such measures, more of the cost of protecting the wildland-urban  interface would then be borne by those who chose to live there.
section_title: Officials’ Concerns May Reflect Ambiguity over Financial Responsibilities
paragraphs: On the basis of our review of previous federal reports and interviews with  federal and nonfederal officials, we believe that the concerns we identified  may reflect a more fundamental issue—that federal and nonfederal  firefighting entities have not clearly defined their fundamental financial  responsibilities for wildland fire suppression, particularly those for  protecting the wildland-urban interface. Federal officials said that the  continuing expansion of the wildland-urban interface and rising fire  suppression costs for protecting these areas have increased the  importance of resolving these issues. Federal wildland fire management  policy states that protecting structures is the responsibility of state, tribal,  and local entities; but the policy also says that, under a formal fire  protection agreement specifying the financial responsibilities of each  entity, federal agencies can assist nonfederal entities in protecting the  exterior of structures threatened by wildland fire. Federal and nonfederal  officials agreed that federal agencies can assist with such actions, but they  did not agree on which entities are responsible for bearing the costs of  these actions. Federal officials told us that the purpose of this policy is to  allow federal agencies to use their personnel and equipment to help  protect homes but not to bear the financial responsibility of providing that  protection. Nonfederal officials, however, said that these actions are  intended to keep a wildland fire from reaching structures, and financial  responsibility should therefore be shared between both federal and  nonfederal entities.
Further, the presence of structures adjacent to federal lands can  substantially alter fire suppression strategies and raise costs. A previous  federal report and federal officials have questioned which entities are  financially responsible for suppression actions taken on federal lands but  intended primarily or exclusively to protect adjacent wildland-urban  interface. Fire managers typically use existing roads and geographic  features, such as rivers and ridgelines, as firebreaks to help contain  wildland fires. If, however, homes and other structures are located  between a fire and such natural firebreaks, firefighters may have to  construct other firebreaks and rely more than they otherwise would on  aircraft to drop fire retardant to protect the structures, thereby increasing  suppression costs. Nonfederal officials in several states, however,  questioned the appropriateness of assigning to nonfederal entities the  costs for suppression actions taken on federal lands. These officials, as  well as officials from the National Association of State Foresters, said that  accumulated fuels on federal lands is resulting in more severe wildland  fires and contributing to the increased cost of fire suppression. They also  said that federal agencies are responsible for keeping wildland fires from  burning off federal land and should, therefore, bear the costs of doing so.  Federal officials in the states we visited recognized this responsibility, but  some also said that with the growing awareness that wildland fires are  inevitable in many parts of the country, policy should recognize that  wildland fires will occur and are likely to burn across jurisdictional  boundaries. In their view, those who own property in areas at risk of  wildland fires share a portion of the financial responsibility for protecting  it. Previous federal agency reports also have recognized this issue and  have called for clarifying financial responsibility for such actions.
section_title: Conclusions
paragraphs: Wildland fires are inevitable and will continue to affect both federal and  nonfederal lands and resources. Federal, state, and local firefighting  entities have taken great strides to develop a cooperative fire protection  system so that these entities can effectively work together to respond to  these fires. Efforts are now needed to address how to best share the costs  of these cooperative fire protection efforts when the fires burn or threaten  multiple jurisdictions, particularly when suppression efforts may focus  more heavily on one entity’s lands and resources. The need for clear  guidance on when to use a particular cost-sharing method is becoming  more acute as the wildland-urban interface continues to grow and  wildland fire suppression costs continue to increase. Before such guidance  can be developed, however, federal and nonfederal entities must agree on  which entity is responsible for the costs of protecting areas where federal  and nonfederal lands and resources are adjacent or intermingled,  particularly in the wildland-urban interface. Without explicit delineation of  financial responsibilities, federal and nonfederal entities’ concerns about  how these costs are shared are likely to continue.
Thus, to strengthen the framework for sharing wildland fire suppression  costs, we recommended that the Secretaries of Agriculture and the  Interior, working in conjunction with relevant state entities, provide more  specific guidance as to when particular cost-sharing methods should be  used and clarify the financial responsibilities for suppressing fires that  burn, or threaten to burn, across multiple jurisdictions.
In responding to our report, the Forest Service and the Department of the  Interior generally agreed with the findings and recommendations. The  National Association of State Foresters did not agree, stating that  developing national guidance would not provide the flexibility needed to  address the variability in local circumstances and state laws. Although we  agree that a certain amount of flexibility is needed, without more explicit  guidance to assist local federal and nonfederal officials responsible for  developing cost-sharing agreements for individual fires, the  inconsistencies in how suppression costs are shared within and among  states are likely to continue, along with concerns about perceived  inequities.
Mr. Chairman, this concludes my prepared statement. I would be pleased  to answer any questions that you or other Members of the Subcommittee  may have at this time.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: For further information about this testimony, please contact me at (202)  512-3841 or robinsonr@gao.gov, or Robin M. Nazzaro at (202) 512-3841 or  nazzaror@gao.gov. David P. Bixler, Assistant Director; Jonathan Dent;  Janet Frisch; and Richard Johnson made key contributions to this  statement.
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