Drinking Water: The District of Columbia and Communities Nationwide Face Serious Challenges in Their Efforts to Safeguard Water Supplies
Published: 2008-04-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The discovery in 2004 of lead contamination in the District of Columbia's drinking water resulted in an administrative order between the Environmental Protection Agency (EPA) and the District's Water and Sewer Authority (WASA), requiring WASA to take a number of corrective actions. WASA also took additional, longer-term measures, most notably a roughly $400 million program to replace what may be 35,000 lead service lines in public space within its service area. As in WASA's case, water utilities nationwide are under increasing pressure to make significant investments to upgrade aging and deteriorating infrastructures, improve security, serve a growing population, and meet new regulatory requirements. In this context, GAO's testimony presents observations on (1) WASA's efforts to address lead contamination in light of its other pressing water infrastructure needs, and (2) the extent to which WASA's challenges are indicative of those facing water utilities nationwide. To address these issues, GAO relied primarily on its 2005 and 2006 reports on lead contamination in drinking water, as well as other recent GAO reports examining the nation's water infrastructure needs and strategies to address these needs.
section_title: What GAO Found
paragraphs: With the introduction of orthophosphate to its drinking water WASA has consistently tested below the federal action level for lead. However, WASA is reevaluating its roughly $400 million, longer-term solution for replacement of what may be 35,000 lead service lines within its jurisdiction. In addition to the program's high cost, a key problem WASA faces is that, by law, it may only replace the portion of the service line that it owns; replacing the portion on private property is at the homeowner's discretion. Accordingly, WASA has been encouraging homeowners to participate in the program by replacing their own portion of the lead lines. Despite these efforts, however, homeowner replacement of lead service lines remains limited. Of the 14,260 lead service lines WASA replaced through the first quarter of fiscal year 2008, there were only 2,128 instances in which the homeowner participated in private side replacement. Many questions remain about the benefits of partial lead service line replacement. In fact, some research to date suggests that partial service line replacement results in (1) short-term spikes in lead levels immediately after partial replacement and (2) little long-term reduction in lead levels. WASA's dilemma over this program is taking place within the context of its other staggering infrastructure needs. Most notably, WASA is undertaking a $2.2 billion effort to meet the terms of a consent decree with EPA requiring the utility to control its sewer overflow problems. WASA's challenges in addressing its lead contamination problems and other infrastructure demands are mirrored across the country, where infrastructure needs are estimated to range from $485 billion to nearly $1.2 trillion nationwide over the next 20 years. In particular, many utilities have had difficulty in raising funds to repair, replace, or upgrade aging capital assets; comply with regulatory requirements; and expand capacity to meet increased demand. For example, based on a nationwide survey of several thousand drinking water and wastewater utilities, GAO reported in 2002 that 29 percent of the drinking water utilities and 41 percent of the wastewater utilities were not generating enough revenue from user rates and other local sources to cover their full cost of service. GAO also found that about one-third of the utilities (1) deferred maintenance because of insufficient funding, (2) had 20 percent or more of their pipelines nearing the end of their useful life, and (3) lacked basic plans for managing their capital assets. Other GAO work suggests that the nation's water utilities could more effectively manage their infrastructure at a time when huge investments are needed. In 2004, for example, GAO cited "comprehensive asset management" as one approach that could help utilities better identify and manage their infrastructure needs. While by no means a panacea to their fundamental fiscal challenges, water utilities can use comprehensive asset management to minimize the total cost of designing, acquiring, operating, maintaining, replacing, and disposing of capital assets over their useful lives, while achieving desired service levels.

section_title: Letter
paragraphs: We are pleased to be here to testify on the infrastructure challenges facing  the District of Columbia’s Water and Sewer Authority (WASA),  highlighting its efforts to reduce lead exposure. In doing so, we will also  put our comments in the context of the many fiscal challenges and  competing demands facing all water utilities, including WASA.
Media reports in early 2004 about lead contamination of the District’s  drinking water raised serious concerns about the health risks posed to its  residents from existing lead service lines, and about how local and federal  agencies were carrying out their responsibilities. WASA’s lack of timely  disclosure of this problem, and the subsequent confused effort by  government agencies to inform the public on steps to protect itself, led to  numerous congressional hearings and a June 2004 administrative consent  order between the Environmental Protection Agency (EPA) and WASA.  WASA agreed to take a number of corrective actions, including improving  its water sampling procedures and subsequent reporting of these results to  EPA; enhancing its public education efforts; and developing a plan to  identify additional lead service lines. In addition, orthophosphate was  added to WASA’s water supply in August 2004 to form a protective coating  inside lead service lines and fixtures to prevent lead from leaching into  drinking water.
To address the problem in the long-term, WASA decided to undertake  what it estimates to be at least a $400 million program to replace the  public portions of all its customers’ lead service lines (roughly 35,000  lines) by 2016 and to also provide various incentives to encourage the  replacement of lead service lines in private space. In the District of  Columbia, homeowners are responsible for the portion of the service line  that runs from the property line to the home. Homeowners may replace  this portion of the line if they choose, but this replacement is not required.
The lead problem in the District of Columbia also prompted EPA to review  the adequacy of federal regulations on lead in drinking water. In October  2007, EPA made several changes to the monitoring and public notice  provisions of the Safe Drinking Water Act’s Lead and Copper Rule, the  principal federal regulation protecting public water system consumers  from exposure to lead and copper in drinking water.
As important as the lead contamination problem has been to WASA and its  customers, it is not the only issue with which the utility must grapple. Like  many other large water utilities, WASA is also responsible for wastewater  collection and transmission, including operation and maintenance of its  wastewater treatment facility and sanitary sewer system. While the utility  has sought to modernize many parts of its wastewater facilities, some  components date back to the early 19th century. Like most utilities, WASA  must provide for replacement or rehabilitation of its existing system, and  construct extensions to this system for development and growth as  needed.
The federal government has had a significant impact on the nation’s  drinking water and wastewater infrastructure by (1) providing financial  assistance to build new facilities or upgrade existing ones and (2)  establishing regulatory requirements that affect the technology, operation,  and maintenance of utility infrastructure. As the agency that regulates  drinking water and surface water quality, EPA provides a significant  amount of financial assistance for facilities that supply drinking water and  treat wastewater. This assistance is primarily in the form of grants to the  states to capitalize revolving loan funds, which are used to finance  improvements to drinking water and wastewater treatment facilities. In  addition to its financial investment, EPA has promulgated regulations to  implement the Safe Drinking Water Act and Clean Water Act, which have  been key factors in shaping water systems’ capital needs and management  practices.
In my testimony today I will present observations on (1) WASA’s efforts to  address lead contamination in light of its other pressing water  infrastructure needs, and (2) the extent to which WASA’s challenges are  indicative of those facing other water utilities across the nation.
To address these questions, we are summarizing and updating reports we  issued in 2005 and in 2006 on the lead contamination problem in the  District of Columbia’s drinking water supplies, and on the status of  WASA’s effort to address this problem. We are also highlighting some of  the work we have recently completed that addresses the magnitude of the  nation’s water infrastructure needs, the problems utilities face in  addressing them, and the strategies utilities can employ to help them best  meet their needs. We prepared this testimony in April 2008, based on work  performed over the last three years, in accordance with generally accepted  government auditing standards. Those standards require that we plan and  perform the audit to obtain sufficient, appropriate evidence to provide a  reasonable basis for our findings and conclusions based on our audit  objectives. We believe that the evidence obtained provides a reasonable  basis for our findings and conclusions based on our audit objectives.
The introduction of orthophosphate to its water supply has enabled WASA  to consistently test below the federal action level for lead in drinking  water, but the Authority is reevaluating its longer-term roughly $400  million program to replace what may be 35,000 lead service lines in public  space. Importantly, this program only addresses the replacement of the  public portion of customers’ lead lines. Customers would need to finance  replacement of their private portion of the lead lines (at a cost that could  reach $2,500) on their own. Yet despite WASA’s efforts to encourage  homeowner participation, private side replacement of lead service lines  remains limited. Of the 14,260 lead service lines WASA replaced through  the first quarter of fiscal year 2008, there were only 2,128 instances in  which the homeowner participated in the private side replacement.  Importantly, many questions remain about the benefits of partial lead  service line replacement. Research suggests that short-term spikes in lead  levels occur immediately after partial replacement, and little long-term  reduction in lead levels may be achieved. WASA’s reevaluation of this  program is taking place within the context of its staggering infrastructure  needs, most notably a $2.2 billion effort to meet the terms of a consent  decree with EPA to address sewer overflow problems.
WASA’s difficulties in meeting myriad fiscal demands are mirrored across  the country: water infrastructure needs nationwide are estimated to range  from $485 billion to nearly $1.2 trillion over the next 20 years. In  particular, many utilities have had difficulty raising funds to repair,  replace, or upgrade aging capital assets; comply with regulatory  requirements; and expand capacity to meet increased demand. For  example, based on a survey of several thousand drinking water and  wastewater utilities, we reported in 2002 that 29 percent of the drinking  water utilities, and 41 percent of the wastewater utilities, were not  generating enough revenue from user rates and other local sources to  cover their full cost of service. We also found that about one-third of the  utilities (1) deferred maintenance because of insufficient funding, (2) had  20 percent or more of their pipelines nearing the end of their useful life,  and (3) lacked basic plans for managing their capital assets. Other GAO  work suggests that the nation’s water utilities could more effectively  manage their infrastructure at a time when huge investments are needed.  In 2004, for example, we cited “comprehensive asset management” as one  approach that can help utilities better identify and manage their  infrastructure needs. Though by no means a panacea for their profound  fiscal challenges, comprehensive asset management can help water  utilities minimize the total cost of designing, acquiring, operating,  maintaining, replacing, and disposing of capital assets over their life cycle,  and can do so in a way that achieves the level of service customers desire.
subsections: section_title: Background
paragraphs: Lead contamination of drinking water is difficult and expensive to control.  It seldom occurs naturally in source water supplies like rivers and lakes;  therefore it cannot be treated at a centralized treatment facility. Rather,  lead enters drinking water primarily from the corrosion of materials  containing lead in the water distribution system and in household  plumbing. These materials include lead service lines that connect a house  to the water main, lead-based solder used in a house to join copper pipe,  and brass faucets and other plumbing fixtures.
The Safe Drinking Water Act is the key federal law protecting public water  supplies from harmful contaminants. EPA’s 1991 Lead and Copper Rule,  promulgated pursuant to the Act, requires water systems to protect  consumers against exposure to elevated levels of lead in drinking water by  chemically treating water to reduce its corrosiveness and by collecting  water samples from consumer taps and testing them for evidence of lead  corrosion. EPA considers lead to be elevated (known as the “action  level”) when lead levels are higher than 15 parts per billion in over 10  percent of tap water samples taken. Because lead contamination generally  occurs after water leaves the treatment plant, the Lead and Copper Rule  requires testing for lead at consumers’ taps. If elevated lead levels are  found and persist after treatment to minimize the water’s corrosiveness,  the water system must annually replace 7 percent of the lead service lines  that it owns.
Implementation and enforcement of the Lead and Copper Rule in the  District of Columbia is complicated because of the number and nature of  the entities involved. The Washington Aqueduct, owned and operated by  the U.S. Army Corps of Engineers, is responsible for water treatment  (including corrosion control). WASA purchases water from the  Washington Aqueduct and delivers it to District residents, and is  responsible for monitoring tap water samples for lead. EPA Region III in  Philadelphia has oversight and enforcement authority for the District’s  public water systems.
Similar to many of the other approximately 400 largest drinking water  systems in the United States (i.e., serving populations greater than  100,000), WASA is also responsible for wastewater collection and  transmission, including operation and maintenance of its wastewater  treatment facility and sanitary sewer system. This water infrastructure in  the District of Columbia, like in many older cities, is aging and will require  substantial funding over the next several years for replacement or  rehabilitation.
section_title: WASA Has Reduced Lead in Drinking Water But Faces Many Other Challenges to its Water and Wastewater Infrastructure
paragraphs: A June 17, 2004, administrative order for compliance on consent between  EPA and WASA required WASA to take a number of corrective actions  that, by necessity, enhanced its coordination with EPA and the D.C.  Department of Health. Among these actions were developing a plan to  identify additional lead service lines, improving the selection of sampling  locations and reporting of water testing results to EPA, developing a  strategy to improve WASA’s public education efforts, and collaborating  with the D.C. Department of Health to set priorities for replacing lead  service lines. Most importantly, with the introduction of orthophosphate to  the drinking water supply, WASA met, and has continued to meet, federal  standards for lead in drinking water. WASA’s most recent report on lead  levels in D.C. drinking water was delivered to EPA in January 2008. WASA  reported that 90 percent of the samples had lead levels of 11 parts per  billion (ppb) or less, which is below EPA’s lead action level of 15 ppb. This  is the sixth monitoring period in a row that WASA has met the lead action  level.
To resolve its lead problem in the long-term, however, WASA decided that  it needed to undertake a program to replace the public portions of all its  customers’ lead service lines (roughly 35,000 lines) by 2016. WASA  estimates that its program to replace all the District’s lead service lines  will cost at least $400 million. Importantly, this figure reflects only the cost  to replace the public portion of customers’ lead lines. Customers would  need to finance replacement of their private portion of the lead lines (at a  cost that could reach $2,500) on their own. Through the first quarter of  fiscal year 2008, WASA has spent $105 million on the program, and expects  to spend roughly another $300 million by 2016.
Perhaps the most important complication facing WASA’s lead service line  replacement program is that ownership of lead service lines in the District  of Columbia is shared—WASA owns the portion from the water main to  the property line, and homeowners own the portion from the property line  to the home. Homeowners may pay to replace their portion of the lead  service line at the same time as WASA replaces its portion, but are not  required to do so. Figure 1 shows the configuration of a service line from  the water main to a customer’s home.
WASA established a program to encourage homeowners to replace their  portion of lead service lines. This program included:    a low-interest loan program for low-income residents, offered through a    grants of up to $5,000 for low-income residents, offered by the District of  Columbia Department of Housing and Community Development; and:   a fixed-fee structure for line replacement of $100 per linear foot plus $500  to connect through the wall of the home, to make pricing easier for  homeowners to understand.
Despite these incentives, D.C. homeowners have been reluctant to replace  the private side of the lead service line. Through the length of WASA’s lead  service line replacement program, beginning in fiscal year 2003 and  running through the first quarter of fiscal year 2008, of the 14,260 lead  service lines replaced in public space, only 2,128 homeowners replaced  the private portion of their lead service line.
These totals are particularly troublesome given the lack of information  about the benefits of partial lead service line replacement. Indeed, experts  disagree about the effectiveness of removing only part of a lead service  line. Studies that EPA cited in the Lead and Copper Rule suggest that long- term exposure to lead from drinking water decreases when a service line  is only partially replaced. However, after partial replacement of a lead  service line, exposure to lead in drinking water is likely to increase in the  short term because cutting or moving the pipe can dislodge lead particles  and disturb any protective coating on the inside of the pipe. Some experts  believe that lead exposure can increase after partial service line  replacement because of galvanic corrosion where the dissimilar metals of  the old and new pipes meet.
A study presented at the 2006 American Water Works Annual Conference  summarizing the experience of partial lead service line replacement by the  Greater Cincinnati Water Works found that partial replacements of lead  lines resulted in much higher lead levels in the water for up to 1 month  after replacement, even though the system was optimized for corrosion  control. Even after this initial period, the sites with partial replacements  had similar water lead concentrations as the sites in which the entire lead  line was left in place—indicating there would be little, if any, benefit of  partial lead line replacement. In the study, only completely replacing the  lead service line resulted in both short- and long-term water quality  improvements in all of the sites tested. The authors also noted that the use  of a Teflon sleeve, or some other method of treating the portion of the line  remaining in service, may help to protect water quality, but that more  needs to be done in this area. Recognizing the need for more research,  EPA has partnered with the American Water Works Association Research  Foundation on a study of the relative contributions of service lines and  plumbing fixtures to lead levels at the tap. The projected completion of the  study is November 2008.
In light of these problems, WASA is now considering whether its current  lead line replacement program should be restructured, particularly given  its high cost and the competing demands on its budget. As a water utility  serving a large metropolitan area, the lead problem has posed only one of  several major infrastructure challenges for the utility and its customers.  For example, approximately one-third of the District (by acreage) is  served by combined sewers, which carry both sanitary waste from homes  and businesses and storm water drainage. During storms this untreated  sewage is discharged directly into the Anacostia and Potomac Rivers,  adversely impacting the quality of these waters. To meet federal water  quality standards, WASA will need to spend considerable sums of money  to deal with the problem. Specifically, a March 2005 consent decree  between WASA and EPA requires WASA, by 2025, to implement WASA’s  long-term control plan, including construction of large underground  tunnels to temporarily store excess flows until they can be treated at the  Blue Plains Wastewater Treatment Plant and other measures, to  significantly reduce combined sever overflows into the Anacostia River  and other area waterways. WASA has estimated the cost of this effort to  reach $2.2 billion dollars.
section_title: WASA’s Water Infrastructure Problems Mirror the Challenges Water Utilities Face Nationwide
paragraphs: WASA’s challenges are mirrored across the country, where projected  needs for investment in drinking water and wastewater infrastructure  range from $485 billion to nearly $1.2 trillion over 20 years. The variation  in these estimates reflects alternative assumptions about the nature of  existing capital stock, replacement rates, and financing costs. EPA  reported in its most recent Drinking Water Infrastructure Needs Survey  (issued in June 2005) that drinking water utilities alone will need an  estimated $276.8 billion for the 20-year period ending in December 2022.  EPA’s new estimate exceeds those from prior surveys by more than 60  percent, largely as a result of an increased emphasis on capturing  previously underreported needs for infrastructure rehabilitation and  replacement. According to EPA’s report, current needs increased by about  50 percent, but future needs rose by over 100 percent. EPA attributes the  difference to a more complete assessment of the longer-term needs for  addressing “aging infrastructure that is currently adequate, but will require  replacement or significant rehabilitation over the next 20 years.”
Pipeline rehabilitation and replacement represents a significant portion of  the projected infrastructure needs for water utilities. EPA estimates that  underground pipelines account for about 75 percent of the nation’s  existing capital investment in drinking water and wastewater  infrastructure. According to the American Society of Civil Engineers, U.S.  drinking water and wastewater utilities are responsible for an estimated  800,000 miles of water delivery pipelines and between 600,000 and 800,000  miles of sewer pipelines, respectively. However, several recent studies  have raised concerns about the condition of the existing pipeline network.  For example, in August 2002, based on a nationwide survey of large  drinking water and wastewater utilities, we reported that more than one- third of the utilities had 20 percent or more of their pipelines nearing the  end of their useful life. In the case of one in 10 utilities, 50 percent or more  of the utility’s pipelines were nearing the end of their useful life. Citing a  “huge wave of aging pipe infrastructure,” the American Water Works  Association in 2001 predicted a significant increase in pipe breaks and  repair costs over the next 30 years—even if utilities increase their  investment in pipe infrastructure several fold. Other studies make similar  predictions for the pipelines owned by wastewater utilities.
Despite the looming problems facing utility pipelines, our nationwide  survey found that pipeline rehabilitation and replacement was not  occurring as desired, with over two-thirds of the utilities reporting that  they have fallen short of their desired pace of rehabilitation and  replacement. Specifically, we found that roughly half of the utilities  actually rehabilitated or replaced one percent or less of their pipelines  annually, even though an estimated 89 percent of drinking water utilities  and 76 percent of wastewater utilities believed that a higher level of  rehabilitation and replacement should be occurring. More generally, we  found that many utilities had deferred maintenance, minor capital  improvements, and/or major capital improvements due to insufficient  funding. About one-third of the utilities deferred maintenance  expenditures, and similar percentages of utilities deferred expenditures in  the other categories. According to EPA’s June 2005 Drinking Water  Infrastructure Needs Survey, the largest category of need is the installation  and maintenance of transmission and distribution systems—accounting  for $183.6 billion, or about 66 percent of the needs projected through 2022.  For wastewater systems, EPA’s 2004 Clean Watersheds Needs Survey  projected infrastructure-related needs for publicly-owned wastewater  systems of $202.5 billion through 2024.
Several factors have contributed to the nation’s deteriorating water  infrastructure over the years. The adequacy of the available funding, in  particular, has been a key determinant of how well utility infrastructure  has been maintained. However, according to our nationwide survey, a  significant percentage of the utilities serving populations of 10,000 or  more—29 percent of the drinking water utilities and 41 percent of the  wastewater utilities—were not generating enough revenue from user  charges and other local sources to cover their full cost of service. In  addition, when asked about the frequency of rate increases during the  period from 1992 to 2001, more than half the utilities reported raising their  rates infrequently: once, twice, or not at all over the 10-year period.
Our survey also raised questions about whether utility managers have  enough information about their capital assets to effectively plan their  future investment needs. We found that many utilities either did not have  plans for managing their assets, or had plans that may not be adequate in  scope or content. Specifically, more than one-fourth of the utilities did not  have plans for managing their existing capital assets. Moreover, for the  utilities that did have such plans, the plans in many instances did not cover  all assets or did not contain one or more key elements, such as an  inventory of assets, assessment criteria, information on the assets’  condition, and the planned and actual expenditures to maintain the assets.
Citing communities’ funding difficulties, many have looked to the federal  government for financial assistance. However, if budgetary trends over the  past few years serve as any indication, federal funding will not close the  gap. The key federal programs supporting water infrastructure financing  include the Clean Water State Revolving Fund (CWSRF) for wastewater  facilities, and the Drinking Water State Revolving Fund (DWSRF) for  drinking water facilities. Under each of these programs, the federal  government provides seed money to states, which the states in turn use to  support revolving funds that loan money to qualifying localities within  their jurisdictions for new construction and upgrades. However, the trends  and overall funding levels associated with these programs, suggest that  they will only have a marginal impact in closing the long-term water  infrastructure funding gap. Federal appropriations for the CWSRF in  particular have decreased by nearly 50 percent during the past five years— from $1.34 billion enacted for fiscal year 2004 to $689 million enacted for  fiscal year 2008. Funding for the DWSRF has remained virtually flat during  the same period.
subsections: section_title: Comprehensive Asset Management Can Be an Effective Tool for Managing Infrastructure and Optimizing Investments When Resources Are Constrained
paragraphs: Growing infrastructure needs, combined with local pressure to keep user  rates low, make it imperative that utilities manage their resources as cost  effectively as possible. While hardly a “silver bullet” for the water  industry’s massive shortfall in infrastructure funding, comprehensive asset  management is one approach that has shown promise in helping utilities  better identify their needs, set priorities, and plan future investments.  Basic elements of comprehensive asset management include: collecting  and organizing detailed information on assets; analyzing data to set  priorities and make better decisions about assets; integrating data and  decision making across the organization; and linking the strategy for  addressing infrastructure needs to service goals, operating budgets, and  capital improvement plans. At its most basic level, asset management gives  utility managers the information they need to make sound decisions about  maintaining, rehabilitating, and replacing capital assets—and to make a  sound case for rate increases and proposed projects to their customers  and governing bodies.
Our 2004 report identified a number of asset management practices that  could help water utilities better manage their infrastructure and target  their investments to achieve the maximum benefit. Among other things,  we found that collecting, analyzing, and sharing data across the  organization helped utilities make informed decisions about which assets  to purchase, optimize their maintenance practices, and determine how  long to repair an asset before replacement becomes more cost-effective.  Some utility managers, for example, have used risk assessments to  determine how critical certain assets (such as pipelines) are to their  operations, considering both the likelihood and consequences of their  failure. This systematic evaluation has helped them to target their  resources accordingly, with the most critical assets receiving preventive  maintenance while other, less critical assets received attention on an as  needed basis.
Having better information on utility assets has not only allowed managers  to identify and prioritize investment needs, but has also helped them  justify periodic rate increases to their customers and governing boards to  pay for needed improvements. In one case, for example, utility managers  modeled information on pipe performance history and replacement costs  and predicted the approximate number of pipe breaks at various levels of  funding. By understanding the trade-offs between lower rates and higher  numbers of pipe breaks, the governing board was able to make an  informed decision about the level of service that was appropriate for its  community.
Whether the problem is replacing lead service lines, as is the case for  WASA, meeting new regulatory requirements, or paying the price for years  of deferred maintenance, many utilities are facing huge investments to add  new capital assets and replace others that are reaching the end of their  useful life. Comprehensive asset management is one approach that shows  real promise as a tool to help drinking water and wastewater utilities  effectively target limited resources and, ultimately, ensure a sustainable  water infrastructure for the future. Accordingly, our report recommended  that the Environmental Protection Agency take steps to strengthen the  agency’s existing initiatives on asset management and ensure that relevant  information is accessible to those that need it.
Mr. Chairman, this completes my prepared statement. I would be happy to  respond to any questions you or other Members of this Subcommittee may  have at this time.
section_title: Contact and Acknowledgements
paragraphs: For further information, please contact John B. Stephenson at (202) 512- 3841. Individuals making key contributions to this testimony included  Elizabeth Beardsley, Ellen Crocker, Steve Elstein, Tim Minelli, Nathan  Morris, Alison O’Neill, and Lisa Turner.
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