Drug Control: Financial and Management Challenges Continue to Complicate Efforts to Reduce Illicit Drug Activities in Colombia
Published: 2003-06-03T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The United States has been providing assistance to Colombia since the early 1970s to help reduce illicit drugs. In 1999, the Colombian government introduced Plan Colombia--program that, among other things, proposed reducing illicit drug activities by 50 percent over 6 years. In fiscal years 2000-03 alone, the United States provided more than $2.5 billion in counternarcotics assistance. Despite this aid, Colombia remains the world's leading producer and distributor of cocaine and a major source of the heroin used in the United States. This testimony discusses the status of U.S. counternarcotics assistance to the Colombian Army and for a U.S.-supported Colombian police aerial eradication program. It also addresses challenges Colombia and the United States face in sustaining these programs.
section_title: What GAO Found
paragraphs: In fiscal years 2000-03, the United States provided about $640 million in assistance to train and equip a Colombian Army counternarcotics brigade and supply the army with 72 helicopters and related support. Most of this assistance has been delivered and is being used for counternarcotics operations. In recent years, the Colombian National Police aerial eradication program has had mixed results. Since 1995, coca cultivation rose in every year until 2002 and opium poppy cultivation remained relatively steady until 2001. But, for 2002, the U.S. Office of National Drug Control Policy reported that net coca cultivation in Colombia decreased 15 percent and net opium poppy cultivation decreased 25 percent--the second yearly decline in a row. U.S. officials attributed this success primarily to the Colombian government's willingness to eradicate coca and poppy plants without restriction. Although the U.S.-supported counternarcotics program in Colombia has recently begun to achieve some of the results envisioned in Plan Colombia, Colombia and the United States must continue to deal with financial and management challenges. Neither the Colombian Army nor the Colombian National Police can sustain ongoing counternarcotics programs without continued U.S. funding and contractor support for the foreseeable future. According to U.S. embassy officials, these programs alone may cost up to $230 million per year, and future costs for some other programs have not been determined. Because of overall poor economic conditions, the government of Colombia's ability to contribute more is limited, but the continuing violence from Colombia's long-standing insurgency limits the government's ability to institute economic, social, and political improvements. Moreover, Colombia faces continuing challenges associated with the need to ensure it complies with human rights standards and other requirements in order for U.S. assistance to continue. As GAO noted in 2000, the total costs of the counternarcotics programs in Colombia were unknown. Nearly 3 years later, the Departments of State and Defense have still not developed estimates of future program costs, defined their future roles in Colombia, identified a proposed end state, or determined how they plan to achieve it.

section_title: Letter
paragraphs: I am pleased to be here to discuss GAO’s work on U.S. counternarcotics  assistance to Colombia. Today we will highlight the preliminary findings  from our ongoing review of U.S. assistance to Colombia. Our draft report  is with the responsible agencies for comment; we expect to issue a final  report in mid-June. I will focus my comments on (1) the status of U.S.  counternarcotics assistance to the Colombian Army in fiscal years 2000-03  and how this assistance has been used, (2) what the U.S.-supported  Colombian National Police aerial eradication program has accomplished  in recent years, and (3) what challenges Colombia and the United States  face in sustaining these programs.
In 1999, the Colombian government introduced Plan Colombiaa  $7.5 billion program that, among other things, proposed reducing the  cultivation, processing, and distribution of illegal narcotics by 50 percent  over 6 years. A key component of the Colombian-U.S. counternarcotics  strategy was the creation of a Colombian Army 2,285-man  counternarcotics brigade, for which the United States agreed to provide  helicopters to help it move around southern Colombia to reduce cocaine  production and trafficking. Closely allied with this objective was U.S.  support for the Colombian National Police’s aerial eradication program to  significantly reduce, if not eliminate, coca and opium poppy cultivation.
subsections: section_title: Background
paragraphs: The United States has provided assistance to help reduce illegal drug  production and trafficking activities in Colombia since the 1970s. Yet,  Colombia is still the world’s leading cocaine producer and distributor and  a major source of the heroin used in the United States. According to State,  Colombia provides 90 percent of the cocaine and about 40 percent of the  heroin entering the United States. The Drug Enforcement Administration  reports that several billion dollars flow into Colombia each year from the  cocaine trade alone, and this vast amount of drug money has helped the  country’s two largest insurgency groupsthe Revolutionary Armed Forces  of Colombia and the National Liberation Armygain unprecedented  economic, political, and social power and influence. The insurgents  exercise some degree of control over 40 percent of Colombia’s territory  east and south of the Andes where much of the coca is grown.
In an effort to address the influx of cocaine and heroin from Colombia, the  United States has funded a counternarcotics strategy in Colombia that  includes programs for interdiction, eradication, and alternative  development, which must be carefully coordinated to achieve mutually  reinforcing results. Besides assistance for the Colombian Army  counternarcotics brigade and the Colombian National Police aerial  eradication program, the United States has supported Colombian efforts to  interdict illicit-drug trafficking along rivers and in the air as well as  alternative development, judicial sector reform, and internally displaced  persons programs. The Departments of Defense and State have provided  most of the funding and State, through its Bureau for International  Narcotics and Law Enforcement Affairs and Narcotics Affairs Section in  the U.S. Embassy Bogotá, oversees the program. In fiscal years 2000  through 2003, the United States provided more than $2.5 billion to  Colombia for counternarcotics assistance. (See table 1.) For fiscal year  2004, the administration has proposed an additional $700 million in aid.
Following increased violence in Colombia during early 2002, the Congress  provided “expanded authority” for the use of U.S. assistance to Colombia,  which enabled the Colombian government to use the U.S.-trained and - equipped counternarcotics brigade, U.S.–provided helicopters, and other  U.S. counternarcotics assistance to fight groups designated as terrorist  organizations as well as to fight drug trafficking. Similar authority was  provided for fiscal year 2003 and is being sought for fiscal year 2004.
section_title: Assistance to the Colombian Army Has Been Delivered, but Problems Were Encountered
paragraphs: U.S. assistance to the Colombian Army during fiscal years 2000- 03$640 million for the counternarcotics brigade, 72 helicopters, and  related supporthas, for the most part, been delivered and is being used  for counternarcotics operations. However, both the United States and the  Colombian Army experienced some unanticipated problems that delayed  the operational use of the helicopters. In addition, U.S. support will be  needed for the foreseeable future to sustain operations.
subsections: section_title: Status of the Brigade
paragraphs: The United States initially agreed to train and equip a Colombian Army  counternarcotics brigade of three battalions and a total of about 2,285  professional and conscripted soldiers. The United States provided the  counternarcotics brigade with about $45 million in training and  equipment—from weapons and ammunition to rations, uniforms, and  canteens. The brigade’s primary mission was to plan and conduct  interdiction operations against drug-trafficking activities, including  destroying illicit drug-producing facilities, and, when called upon, to  provide security in insurgent-controlled areas where aerial eradication  operations were planned. According to U.S. and Colombian officials, the  brigade was highly effective in 2001for example, it destroyed 25 cocaine  hydrochloride laboratoriesbut was less successful in 2002, when it  destroyed only 4 such labs. U.S. embassy officials stated that the brigade  became less effective because the insurgents moved their drug-producing  activities, such as the laboratories, beyond the brigade’s reach. In addition,  according to these officials, the brigade became more involved in  protecting infrastructure, such as bridges and power stations, and  performing base security. Moreover, the aerial eradication program did not  call on the brigade to provide ground security on very many occasions,  essentially planning spray missions in the less threatening areas.
In August 2002, U.S. embassy and Colombian military officials agreed to  restructure the brigade to make it a rapid reaction force capable of making  quick, tactical strikes on a few days’ notice. As part of this restructuring,  the Colombian Army designated the brigade a national asset capable of  operating anywhere in Colombia rather than just in its prior area of  responsibility in southern Colombia. The newly restructured brigade  consists of three combat battalions and a support battalion with a total of  about 1,900 soldiers, all of whom are professional. Two of the combat  battalions have been retrained. The third combat battalion should be  retrained by mid-June 2003. This change, according to U.S. embassy and  Colombian Army officials, will improve the brigade’s ability to conduct  operations against high-value, drug-trafficking targets, such as laboratories  containing cocaine and the leadership of insurgent groups involved in  drug-trafficking activities. One of the retrained battalions has been  operating in Narino department since early May 2003.
section_title: Status of the Helicopters
paragraphs: A key component of U.S. assistance for Plan Colombia was enhancing the  brigade’s air mobility. To do this, the United States provided the  Colombian Army with 33 UH-1N helicopters, 14 UH-60 Black Hawk  helicopters, and 25 UH-II helicopters.
The 33 UH-1N helicopters were supposed to serve as interim aircraft until  the UH-60 and UH-II helicopters funded under Plan Colombia were  delivered. The UH-1Ns were delivered in stages between November 1999  and March 2001. Since flying their first mission in December 2000, the  helicopters have logged 19,500 hours in combat and have supported more  than 430 counternarcotics brigade operations. Colombian Army personnel  are qualified as pilots and mechanics, but many of the experienced pilots  and mechanics who operate and maintain the aircraft are provided  through a U.S. contractor.
The UH-60 Black Hawk helicopters were delivered between July and  December 2001 but did not begin support operations for the brigade until  November 2002 because of a shortage of fully qualified Colombian Army  pilots. Forty-two Colombian Army personnel have completed the  minimum UH-60 pilot training, of which 13 have qualified as pilot-in- command. U.S.-funded contract pilots fill in as pilots-in-command. In  addition, a U.S.-funded contractor continues to maintain the helicopters  and provide maintenance training.
State procured 25 UH-II helicopters under Plan Colombia and planned to  deliver them to the Colombian Army between November 2001 and June  2002. However, they were delivered between March and November 2002  instead because the Colombian military was considering whether to use a  more powerful engine in the helicopters than the one usually installed.  Ultimately it decided to use the more common engine. According to NAS  officials, although some of the UH-II helicopters are being used for  missions, all the helicopters will not be operational until June 2003. As of  January 2003, 25 Colombian Army pilots had completed their initial  training and 21 of these pilots are completing the training needed to  qualify for operational missions. However, contractor pilots continue to  supplement Colombian Army pilots and a U.S.-funded contractor  continues to provide maintenance support.
section_title: Problems with Pilot and Mechanic Training
paragraphs: Although all the U.S.-provided helicopters are in Colombia, a number of  unanticipated problems in training Colombian Army pilots and mechanics  to operate and maintain the helicopters were encountered. Some of these  problems continue to limit the Colombian Army’s ability to operate and  maintain the aircraft. Primarily, the Colombian Army will have to continue  to rely on contractor support because it will not have enough trained  pilots-in-command and senior mechanics for the foreseeable future.
When the United States agreed to provide the UH-60 and UH-II helicopters  for the Colombian Army in July 2000, the assistance for Plan Colombia did  not include any funds to train the Colombian pilots and mechanics needed  to operate and maintain the helicopters. About 6 months after passage of  U.S. assistance for Plan Colombia, Defense agreed to provide the training  and reported that it would transfer up to $20 million from other  counternarcotics projects in Colombia to pay for it.
A training plan was approved in mid-2001. Although the plan provided  training for Colombian Army personnel to meet the minimum  qualifications for a pilot and mechanic, it did not include the additional  training necessary to fly missions in a unit or to become a senior  mechanic. Basic training for 117 helicopter pilots—known as initial entry  rotary wing training—began in November 2001 and is projected to be  completed by December 2004. This training is intended to provide a pool  or pipeline of pilots for more advanced training to fly specific helicopters.  In addition, according to U.S. embassy officials, a new pilot takes an  average of 2 to 3 years to progress to pilot-in-command.
According to U.S. embassy and contractor officials, 105 out of 159  Colombian Army personnel have completed the basic UH-60 and UH-II  maintenance training and are taking more advanced training to qualify as  senior mechanics. These officials told us that the remaining 54 personnel  will receive the contractor-provided basic training in the near future, but  they did not know when it would begin. Moreover, these officials also told  us that it typically takes 3 to 5 years for mechanics to gain the experience  necessary to become fully qualified on specific helicopter systems, in  particular the UH-60 Black Hawks.
The Colombian Army Aviation Battalion is responsible for providing  helicopters and other aircraft and personnel for all Colombian Army  missions with an aviation component, including counternarcotics and  counterinsurgency operations throughout Colombia. Information provided  by the Colombian Aviation Battalion shows that it is staffed at only 80  percent of its required levels and that, over the past several years, it has  received between 60 percent to 70 percent of its requested budget for  logistics and maintenance. The Colombian military’s decision to continue  using the UH-1N helicopters in addition to the UH-60 and UH-II helicopters  will also make it more difficult for the Aviation Battalion to provide the  numbers of personnel needed to operate and maintain the helicopters.  State originally intended that the UH-1N helicopters would not be used  after the UH-60 and UH-II helicopters were available to support  operations.
According to bilateral agreements between Colombia and the United  States, the Colombian Army must ensure that pilots and mechanics who  receive U.S. training be assigned to positions using their training for a  minimum of 2 years. This has not always been the case. For example,  although 19 Colombian Army personnel were qualified to serve as pilots- in-command on UH-1N helicopters, only 1 pilot was assigned to serve in  this position. The remaining pilots-in-command were provided by a U.S.  contractor.
Of the funds appropriated for fiscal year 2002, $140 million was used to  support Colombian Army counternarcotics efforts. Most of this amount  was used for U.S.- provided helicopter operations and maintenance,  logistical, and training support. However, not all the funding could be  released until the Secretary of State certified, in two separate reports to  appropriate congressional committees, that the Colombian military was  making progress meeting certain human rights conditions. Because State  was late in providing these reports, the U.S. embassy could not use this  funding for operations and training on two occasions for a total of about  5 months during 2002. These delays resulted in fewer counternarcotics  operations and limited the training and experience Colombian Army pilots  could obtain to qualify as pilots-in-command.
section_title: Continued U.S. Support Needed to Sustain Operations
paragraphs: U.S. assistance to support the helicopters provided as part of Plan  Colombia was originally planned to end in 2006 with the Colombian Army  taking over these responsibilities. However, U.S. embassy and Colombian  Army officials stated that a continued level of U.S. contractor presence  will be needed beyond this date because the Aviation Battalion is not  expected to have the personnel trained or the resources necessary.  Although the embassy officials stated that they have not officially  estimated what this assistance level will be, they tentatively projected that  it would cost between $100 million and $150 million annually to sustain  the U.S.-supported counternarcotics programs. Moreover, other recently  initiated U.S. programs will likely require U.S. assistance and contractor  support, but the long-term costs of sustaining such programs are not  known.
section_title: Colombia’s Aerial Eradication Program Has Had Mixed Results
paragraphs: Since the early 1990s, State’s Bureau for International Narcotics and Law  Enforcement Affairs (through the U.S. Embassy’s Narcotics Affairs Section  (NAS) and the Office of Aviation) has supported the Colombian National  Police’s efforts to significantly reduce, if not eliminate, the cultivation of  coca and opium poppy. However, for the most part, the net hectares of  coca under cultivation in Colombia continued to rise until 2002, and the  net hectares of opium poppy under cultivation remained relatively steady  until 2001-02. In addition, the U.S. embassy has made little progress in  having the Colombian National Police assume more responsibility for the  aerial eradication program, which requires costly U.S. contractor  assistance to carry out.
subsections: section_title: Recent Progress in Reducing Net Cultivation of Coca and Poppy
paragraphs: As shown in figure 1, the number of hectares under coca cultivation rose  more than threefold from 1995 to 2001—from 50,900 hectares to 169,800  hectares—despite substantially increased eradication efforts. But in 2002,  the Office of Aviation estimated that the program eradicated 102,225  hectares of coca—a record high. In March 2003, the Office of National  Drug Control Policy reported for the first time since before 1995 a net  reduction in coca cultivation in Colombia—from 169,800 hectares to  144,450 hectaresa 15 percent decline.
As shown in figure 2, the net hectares of opium poppy under cultivation  varied between 6,100 and 6,600 for the period 1995-98 but rose to 7,500  hectares in 1999 and 2000. In 2001, the net hectares of poppy estimated  under cultivation declined to 6,500 and, in 2002, further declined to 4,900— nearly a 35 percent reduction in net cultivation over the past 2 years.
U.S. embassy officials attributed the recent unprecedented reductions in  both coca and poppy cultivation primarily to the current Colombian  government’s willingness to allow the aerial eradication program to  operate in all areas of the country. They also noted that  the number of spray aircraft had increased from 10 in July 2001 to 17 in  January 2003; recently acquired spray aircraft can carry up to twice the herbicide as the  older aircraft; and   as of January 2003, aircraft were flying spray missions from three forward  operating locations—a first for the program.
The ability to keep an increased number of spray aircraft operating out of  three bases was made possible, at least in part, because the U.S. embassy  hired a contractor to work with the Colombian National Police to, among  other things, help maintain their aircraft. As a result, the availability of  police aircraft for the spray program increased. Moreover, in August 2002,  the Colombian government allowed the police to return to a higher  strength herbicide mixture that, according to embassy officials, improved  the spray’s effectiveness. These officials project that the aerial eradication  program can reduce the amount of coca and poppy cultivation to 30,000  hectares and 5,000 hectares, respectively, by 2005 or 2006, assuming the  police continue the current pace and can spray in all areas of Colombia.
section_title: Colombian National Police Have Not Assumed Control over Aerial Eradication Operations
paragraphs: As we reported in 2000, beginning in 1998, U.S. embassy officials became  concerned with the rising U.S. presence in Colombia and the associated  costs of the aerial eradication program. At the time, the embassy began  developing a 3-year plan to have the Colombian National Police assume  increased operational control over the program. But for various reasons,  the police did not agree to the plan. Since then, contractor involvement  and the associated costs have continued to rise and the Colombian  National Police are not yet able to assume more control of the aerial  eradication program.
As shown in table 2, in fiscal year 1998, the Office of Aviation reported that  the direct cost for a U.S. contractor providing aircraft maintenance and  logistical support and many of the pilots was $37.8 million. In addition,  NAS provided $10.7 million for fuel, herbicide, and related support, for a  total of $48.5 million. For fiscal year 2003, the comparable estimates for  contractor and NAS-provided support were $41.5 million and $44.8 million,  respectively, for a total of $86.3 million. Most of this increase occurred  between fiscal years 2002 and 2003 and is for the most part to support the  additional spray aircraft, multiple operating locations, and the anticipated  continuation of spray operations throughout Colombia. According to NAS  and Office of Aviation officials, these costs are expected to remain  relatively constant for the next several years.
The Colombian National Police do not provide funding per se for the aerial  eradication program and, therefore, the value of its contributions is more  difficult to quantify. In recent years, the police have provided helicopters  and fixed-wing aircraft for spray mission support and the use of many of  its facilities throughout Colombia. In addition, the police have about 3,600  personnel assigned to counternarcotics missions and estimate that 84 are  directly supporting the aerial eradication program.
section_title: U.S. Efforts to Improve Police Capacity for Aerial Eradication
paragraphs: To help the Colombian National Police increase its capacity to assume  more responsibility for the aerial eradication program, NAS has initiated  several efforts.
In February and March 2002, the Office of Aviation conducted an Aviation  Resource Management Survey of the Colombian National Police Aviation  Service. According to Office of Aviation officials, these surveys are  intended to provide a stringent on-site assessment of flight operations  from management and safety to logistics and maintenance. The survey  team made a number of critical observations. For example,    The Aviation Service’s organizational structure, lines of authority, and  levels of responsibility were not clear. Relying on an overly centralized  command structure resulted in unnecessary delays and the cancellation of  some planned aerial eradication missions because the commanding  general could not be reached.
The Aviation Service did not have a formal flying hour program to help  forecast its budgetary requirements and enhance maintenance scheduling.
About 35 percent of the maintenance staff were inexperienced. According  to the survey team, this could result in improper maintenance procedures  being performed, which could adversely affect flight safety and endanger  lives.
Management of items needing repair and control of spare parts were  deficient. The survey team found 230 items awaiting repair—some from  August 1998—and more than $4 million in UH-1H helicopter blades and  parts stored outside and unprotected.
As a result of the survey, in July 2002, a NAS contractor (a $38.8 million,  1-year contract with options for 4 additional years) began providing  on-the-job maintenance and logistical training to the Aviation Service and  helping the police address many of the issues raised by the Aviation  Resource Management Survey team. Embassy officials noted that a more  formal flying hour program has improved the availability rates of many of  the Aviation Service’s aircraft. For example, the availability rate of the  Aviation Service’s UH-II helicopters—often used to support aerial  eradication missions—increased from 67 percent in January 2002 to  87 percent in December 2002. According to these officials, improved  availability rates made it easier to schedule and conduct spray missions.
In addition, NAS has begun a program for training pilots to fly T-65 spray  planes and plans to start training for search and rescue personnel who  accompany the planes. U.S. officials stated that the contractor presence  should decline and the police should be able to take over more of the  eradication program by 2006, when NAS estimates that coca and poppy  cultivation will be reduced to “maintenance levels”—30,000 hectares and  5,000 hectares, respectively.
section_title: Financial and Management Challenges Continue to Complicate Efforts to Reduce Illicit Drug Activities
paragraphs: The U.S.-supported counternarcotics program in Colombia has recently  begun to achieve some of the results envisioned in 1999-2000. However,  Colombia and the United States must continue to deal with financial and  management challenges.
Under the original concept of Plan Colombia, the Colombian government  had pledged $4 billion and called on the international community to  provide $3.5 billion. Until recently, Colombia had not provided any  significant new funding for Plan Colombia and, according to U.S. embassy  and Colombian government officials, anticipated international assistance  for Plan Colombia—apart from that provided by the United States—did  not materialize as envisioned. But because of overall poor economic  conditions, the government of Colombia’s ability to contribute more is  limited.
The Colombian government has stated that ending the civil conflict is  central to solving Colombia’s problems—from improving economic  conditions to stemming illicit drug activities. A peaceful resolution to the  long-standing insurgency would help stabilize the nation, speed economic  recovery, help ensure the protection of human rights, and restore the  authority and control of the Colombian government in the coca-growing  regions. The continuing violence limits the government’s ability to institute  economic, social, and political improvements.
For U.S. assistance to continue, Colombia faces continuing challenges  associated with the need to ensure that the army and police comply with  human rights standards, that the aerial eradication program meets certain  environmental conditions, and that alternative development is provided in  areas subject to aerial eradication.
Overall, neither the Colombian Army nor the Colombian National Police  can sustain ongoing counternarcotics programs without continued U.S.  funding and contractor support for the foreseeable future. According to  U.S. embassy officials, these programs alone may cost up to $230 million  per year, and future costs for some recently initiated programs have not  been determined. In addition, we note that this estimate does not include  future funding needed for other U.S. programs in Colombia, including  other aerial and ground interdiction efforts; the police Aviation Service’s  U.S.-funded contractor; and alternative development, judicial sector  reform, and internally displaced persons programs.
In recent years, world events—from the global war on terrorism to the  wars in Afghanistan and Iraq—have diverted scarce U.S. resources and  made it paramount that the United States fully consider the resources  committed to its overseas assistance programs. As we noted in 2000, the  total costs of the counternarcotics programs in Colombia were unknown.  Nearly 3 years later, the Departments of State and Defense have still not  developed estimates of future program costs, defined their future roles in  Colombia, identified a proposed end state, or determined how they plan to  achieve it.
section_title: Scope and Methodology
paragraphs: In conducting our work, we reviewed pertinent planning, implementation,  and related documentation and met with cognizant U.S. officials at the  Departments of State and Defense, Washington, D.C.; the U.S. Southern  Command headquarters, Miami, Florida; and the U.S. Embassy in Bogotá,  Colombia. In Colombia, we interviewed Colombian military, police, and  government officials and visited the Colombian Army bases at Larandia,  Tolemaida, and Tres Esquinas and other sites in the primary coca-growing  regions of Colombia. In addition, we observed a Colombian Army  counternarcotics brigade airlift operation and several aerial eradication  missions.
We also discussed this testimony with cognizant officials from State’s  Bureau for International Narcotics and Law Enforcement Affairs and its  Office of Aviation and State’s Bureau for Western Hemisphere Affairs.  They generally concurred with our treatment of the issues presented.
We conducted our work between July 2002 and May 2003 in accordance  with generally accepted government auditing standards.
Mr. Chairman and Members of the Subcommittee, this concludes my  prepared statement. I will be happy to answer any questions you may have.
section_title: Contacts and Acknowledgments
paragraphs: For future contacts regarding this testimony, please call Jess Ford at (202)  512-4268 or Albert H. Huntington, III, at (202) 512-4140. Individuals making  key contributions to this testimony included Jocelyn Cortese, Allen  Fleener, Ronald Hughes, Jose Pena, George Taylor, Kaya Taylor, and Janey  Cohen. Rick Barrett and Ernie Jackson provided technical assistance.
This is a work of the U.S. government and is not subject to copyright protection in the  United States. It may be reproduced and distributed in its entirety without further  permission from GAO. However, because this work may contain copyrighted images or  other material, permission from the copyright holder may be necessary if you wish to  reproduce this material separately.