Corps Of Engineers: Improved Analysis of Costs and Benefits Needed for Sacramento Flood Protection Project
Published: 2003-10-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 1996 and 1999, Congress authorized the U.S. Army Corps of Engineers (the Corps) to strengthen sections of the American River and Natomas Basin levees that provide flood protection for Sacramento, California. In 2002, the Corps reported that the cost of this work, known as the Common Features Project, had increased significantly. GAO was asked to determine why costs increased, the extent to which the Corps analyzed and reported the potential cost increases to Congress in a timely manner, and whether the Corps correctly estimated economic benefits.
section_title: What GAO Found
paragraphs: Estimated costs for the Common Features Project rose from $57 million in 1996 to between $270 million and $370 million in 2002--primarily because of design changes. For the American River, costs more than tripled from $44 million to $158 million in 2002, primarily due to changes such as deepening the walls built in the levees (cut-off walls) to prevent seepage and closing gaps in the walls at bridge crossings. Cost estimates for the Natomas Basin--still in planning--increased from $13 million in 1996 to between $112 million and $212 million in 2002. The Corps has yet to analyze alternative flood protection approaches for the Natomas Basin that might be more cost-effective. Furthermore, it has not analyzed its exposure to potentially significant cost increases for the Natomas Basin work. The Corps did not fully analyze, or report to Congress in a timely manner, the potential for significant cost increases for the American River levee improvements authorized in 1996. Specifically, a severe storm in the Sacramento area in January 1997 indicated some cut-off walls would need to be much deeper and therefore would be more costly. Corps guidance generally directs the Corps to seek new spending authority from Congress if it determines, before issuing the first contract, that it cannot complete the project without exceeding its spending limit. However, the Corps began construction in 1998 without analyzing or reporting potential cost increases. By 2003, it had committed most of the funding authorized for the entire Common Features Project to the 1996 American River work, leaving the additional 1999 work and the Natomas Basin improvements without funding. In 1996, the Corps incorrectly estimated the economic benefits for the American River levee improvements by overcounting the residential properties to be protected. In 2002, it incorrectly estimated benefits for the 1999 improvements by, among other things, miscalculating the size of the area that the improvements would protect. The Corps' quality control process was ineffective in identifying and correcting these mistakes.

section_title: Letter
paragraphs: The city of Sacramento, California, located where the American and  Sacramento Rivers meet, has faced significant risks of major flooding since  its founding in the 1840s. A major flood in the Sacramento area could cause  loss of lives; toxic and hazardous waste contamination; disruptions to the  city’s downtown business and government areas, including the state  capitol; and billions of dollars in property damage. To help protect against  these risks, in 1991 and again in 1996, the U.S. Army Corps of Engineers  (the Corps) identified several alternatives for long-term flood protection.  On both occasions, the Corps recommended building a new dam on the  American River near Auburn, California. Concerns were raised about the  proposed dam’s high cost and environmental impacts, and Congress did not  authorize its construction.
In light of the decision not to proceed with the new dam, the Corps  recommended improving the existing levees on the American and  Sacramento Rivers to increase the level of flood protection for the greater  Sacramento area. Levees provide flood protection by raising the height of  river banks, which helps prevent rivers from overflowing during storms.  The Corps primarily proposed constructing “cut-off” walls in the center of  the existing levees. These walls, composed primarily of soil, cement, and  clay, become impermeable when they harden and prevent water from  passing through the levees. These levee improvements were common to all  of the alternatives that the Corps had considered for Sacramento flood  protection in 1996 and became known as the Common Features Project.
The Water Resources Development Act (WRDA) of 1996 authorized $57  million for the project.
The Common Features Project consists of two related but separate  components—the American River levee improvements and the Natomas  Basin levee improvements. The levees on the American River protect  downtown Sacramento, while the levees on the Sacramento River protect  the Natomas Basin, a largely agricultural area just north of downtown  Sacramento where new development is occurring at a rapid rate. Figure 1  shows the greater Sacramento area and the location of the Common  Features Project.
The WRDA of 1999 authorized additional work for the Common Features  Project, directing the Corps to raise or strengthen some American River  levee sections and raise some levees in the Natomas Basin; it also  increased project authorization to $92 million. Several years after this  authorization, however, the Corps stated that project costs would go  significantly higher.
In the context of these issues, in response to your request, this report  addresses (1) why the costs have increased for the Common Features  Project, (2) the extent to which the Corps analyzed the likelihood of  significant cost increases for the project and reported this information to  Congress in a timely manner, and (3) whether the Corps correctly  estimated the economic benefits of the American River levee  improvements. Our scope and methodology in addressing these questions  can be found in appendix I.
subsections: section_title: Background
paragraphs: Sacramento, California, was established at the confluence of the American  and Sacramento Rivers shortly after gold was discovered upstream at  Sutter’s Mill in 1848. Frequent flooding has been a problem in Sacramento  since its founding. To help reduce flooding, over time a complex system of  levees, dams, and other related facilities were built. Levees line both sides  of the American River from where it meets the Sacramento River upstream  for a distance of about 17 miles, and the Natomas Basin is completely  surrounded by levees. In addition, the Folsom Dam, completed in 1956 and  located upstream from Sacramento on the American River, uses a portion  of its storage capacity for flood protection.
The Sacramento area flood protection system was designed on the basis of  records of rainfall during the first half of the 20th century. However, since  1950, the American River watershed has experienced five floods that were  larger than any recorded in the pre-1950 period, although downtown  Sacramento was not flooded during any of these events. Nonetheless, the  Sacramento area has less protection than the designers of the original flood  protection system realized. In fact, much of urbanized Sacramento is  located in areas where a flood has a 1 percent chance of occurring every  year—known as the 100-year floodplain. Because of this limited level of  protection, the Corps estimates that a very large flood—one with a 0.25  percent chance of occurring every year—would flood the 400-year  floodplain, resulting in residential, commercial, industrial, and public  property damage of about $15.5 billion as well as loss of lives. According to  the Corps, about 305,000 people live in more than 100,000 residential  properties located within the American River floodplain. A major flood also  would cause toxic and hazardous waste contamination; disrupt the city’s  downtown business and government areas, including the state capitol; and interfere with the transportation system, including two  interstate highways.
A major flood in 1986, the largest one ever recorded on the American and  Sacramento Rivers, severely strained the levee system protecting  Sacramento. Although the levees held and downtown Sacramento was not  flooded, the event spurred efforts by federal, state, and local entities to  identify measures to increase Sacramento’s level of flood protection. In  1987, the Corps began work on a comprehensive study of flood protection  alternatives for Sacramento. In its 1991 report, the Corps’ Sacramento  district office considered six flood protection options and recommended  building a new dam on the American River at Auburn, California, but  Congress did not approve the dam’s construction. Subsequently, in  response to the Department of Defense Appropriations Act of 1993, the  Corps reevaluated three alternatives for increasing flood protection. In its  1996 report, the Corps examined (1) building a new dam near Auburn,  California; (2) modifying the existing Folsom Dam; and (3) increasing the  amount of water released from Folsom Dam during a flood, coupled with  other flood protection measures. The Corps again recommended building a  dam at Auburn, but, again, Congress did not approve its construction.
Recognizing the magnitude of the opposition to the proposed Auburn Dam,  in June 1996, the Corps recommended the Common Features Project,  which included improving sections of the American and Sacramento  Rivers’ levees, primarily by constructing cut-off walls, to provide small- scale improvements to flood protection for the Sacramento area while the  options for more extensive improvements continued to be considered. The  WRDA of 1996 authorized $57 million for the Common Features Project,  which included 24 miles of levee improvements on the American River and  12 miles on the Sacramento River along the western border of the Natomas  Basin. Subsequently, the Corps concluded that it could provide the same  level of flood protection on the American River by modifying only about 21  miles of levees. Figure 2 shows how a cut-off wall, which is composed  primarily of a soil, cement, and clay mixture that forms an impermeable  barrier when it hardens, can prevent water from seeping under or through a  levee.
In January 1997, numerous rivers in northern California flooded causing  extensive damages, although not in the Natomas Basin or downtown  Sacramento. This flood, which was nearly as large as the 1986 flood,  highlighted the continuing vulnerabilities of the existing flood protection  system. In response, the WRDA of 1999 (1) modified the Common Features  Project by adding about 3.8 miles of additional levee modifications along  the American River and 10 miles on the Natomas Cross Canal, located on  the northern border of the Natomas Basin, and (2) increased the project’s  authorization from $57 million to $92 million.
When Congress approves a flood protection project, it authorizes a specific  amount of money for the project, which provides the basis for the  maximum project cost. According to section 902 of the Water Resources  Development Act of 1986, as amended, the maximum project cost is the  sum of (1) the original authorized amount, with the costs of unconstructed  project features adjusted for inflation; (2) the costs of modifications that do  not materially alter the scope of the project, up to 20 percent of the original  authorized amount (without adjustment for inflation); and (3) the cost of  additional studies, modifications, and actions authorized by the 1986 Act or  any later law. As a result of these provisions, the $92 million that Congress  authorized for the Common Features Project in 1999 translates to an  allowable maximum project cost of about $120 million in 2003.
When Congress authorized the Common Features Project in 1996, federal  law required that nonfederal partners pay 25 percent of the cost of flood  protection projects. For the Common Features Project, these partners are  the State of California Reclamation Board and the Sacramento Area Flood  Control Agency. In this report, when we refer to project costs, including the  maximum allowable project cost, we are referring to the combined federal  and nonfederal expenditures.
section_title: Design Modifications Have Greatly Raised Costs for the Common Features Project
paragraphs: Estimated costs for the Common Features Project grew from $57 million in  1996, when the project was first authorized, to between $270 million and  $370 million in 2002, primarily because the Corps changed the design of the  levee improvements. For the American River levee improvements  authorized in 1996, estimated costs more than tripled, due largely to  changes in the design of the cut-off walls. New work authorized in 1999  added another $15 million to the cost increase. The Corps has completed  much of the American River work authorized in 1996, but it has not begun  construction on the work authorized in 1999. Regarding the Natomas Basin  component, estimated costs increased from $13 million to between $112  million and $212 million. Costs rose primarily because the Corps changed  the design of the levee improvements and proposed adding other  improvements to this component. The Natomas Basin work is in the early  planning stages, and the Corps has not begun construction. As of July 2003,  the Corps had spent or made plans to spend nearly all of the money  authorized for the Common Features Project. It therefore will not be able  to finish constructing the American River work authorized in 1996, begin  constructing the American River work authorized in 1999, or complete  planning for the Natomas Basin work unless Congress increases the  project’s authorized funding.
subsections: section_title: Estimated Costs for the American River Levee Improvements Authorized in 1996 Have More Than Tripled Because of Design Changes
paragraphs: The Corps’ cost estimate for the American River levee improvements  authorized in 1996 has more than tripled, from $44 million in 1996 to about  $143 million in July 2002, as shown in table 1.
As table 1 shows, costs rose primarily because of the increased costs of the  cut-off walls. The Corps’ original design called for building cut-off walls to  a depth of between 20 and 30 feet to prevent water from seeping through  the levees and for allowing gaps in the cut-off walls at bridge and utility  crossings. However, after the 1997 flood, the Corps realized it also needed  to address the problem of water seeping under levees. It therefore  increased the depth of the cut-off walls to between 60 and 80 feet and  closed the gaps in the cut-off walls at bridge and utility crossings. For some  sections of the levees, the Corps could not close the gaps using its standard  approach for cut-off walls because of problems accessing the sites. As a  result, the Corps employed a new and more expensive approach—known  as jet grouting—to build cut-off walls by drilling and injecting concrete  material into areas that were difficult to access. Closing the gaps in the cut- off walls by jet grouting raised estimated costs by $52 million and  increasing their depth raised costs by $24 million, according to the Corps’  July 2002 cost estimate. However, in September 2002, the Corps  determined that fewer gaps needed to be closed using jet grouting, which  should reduce costs to some extent. As of June 2003, however, the Corps  had not incorporated these potential cost reductions into an official project  cost update.
As table 1 also shows, the Corps’ response to accidents that occurred  during construction of the 1996 authorized work added $11 million to  project costs. On three occasions, liquid material from the cut-off walls  accidentally leaked into either the American River or the backyards of  homes that are built against the levees. As a result, the Corps incurred costs  cleaning up these spills and responding to new work requirements  mandated by the Environmental Protection Agency to help prevent future  leaks.
Lastly, in addition to the cost increases related to the 1996 authorized work,  new flood protection measures authorized in 1999 added about $15 million  in costs to the American River component of the project. These measures  include raising levee banks at two locations, installing gates and pumps at  an existing drain, and installing cut-off walls in two additional levee  segments.
Of the American River work authorized in 1996, the Corps has completed  about 90 percent and must still close gaps in the cut-off walls at some  remaining bridge and utility crossings to complete this work. For the levee  improvements authorized in 1999, the Corps has done some planning but  has not begun any construction. However, as of July 2003, the Corps had  spent or had plans to spend $116 million of the $120 million authorized for  the entire Common Features Project. The Corps could not give an exact  accounting of how much of the $116 million it had spent on the 1996  American River work. However, on the basis of the information that the  Corps provided, we estimate the Corps has spent, or made plans to spend,  at least $103 million for planning and constructing the 1996 American River  work. Because the Corps has spent or made plans to spend most of the  project’s authorized funds, it will not be able to complete the 1996 and 1999  work on the American River unless Congress increases the project’s  authorized funding.
section_title: Natomas Basin Costs Are Expected to Increase Significantly, and Lack of Funds Has Halted Planning and Cost Estimating Efforts
paragraphs: The Corps’ preliminary cost estimates for the Natomas Basin component of  the project increased from $13 million in 1996 to between $112 million and  $212 million in 2002, as shown in table 2.
As table 2 shows, the Corps estimates that the costs for the original levee  improvements will increase by between $47 million and $88 million due to  design changes to add cut-off walls or provide other methods of flood  protection to control seepage under levees. The Corps proposed new work  in 2002 that will increase costs by between $37 million and $84 million. This  work is located in an area of the levee where the Corps previously had  constructed a cut-off wall to stop water from seeping through the levee.  However, the Corps later determined that the cut-off wall was not deep  enough to prevent water from seeping under the levee, and the proposed  new work will address this problem. Finally, the Corps estimates that the  additional work authorized in 1999 to modify levees along the Natomas  Cross Canal, which empties into the Sacramento River at the north end of  the Natomas Basin, will add between $14 million and $26 million to the cost  of this component of the project.
The Natomas Basin work—authorized in 1996 and 1999 and the additional  work the Corps identified—is in the planning stages and no construction  has yet begun. The Corps has been updating information on the extent of  the levee problems and the costs of the improvements identified in the  original plan and intends to submit a more precise cost estimate to  Congress when it completes its planning. However, the Corps halted its  Natomas Basin planning work in June 2003 because it had spent or made  plans to spend nearly all of the money authorized for the entire Common  Features Project.
Given that the Natomas Basin levee improvements will cost significantly  more than originally estimated and no construction has yet begun,  identifying and evaluating alternative flood protection measures could  result in cost savings. For example, one possible alternative method for  flood protection identified by the Sacramento Area Flood Control Agency,  as well as the Corps, involves lowering the water level in the Sacramento  River during floods by diverting water through the Fremont Weir and into  the Yolo Bypass, which is located at a point just before where the  Sacramento River flows past the Natomas Basin.  The Fremont Weir is a  low dam that controls the movement of large volumes of floodwater from  the Sacramento River by diverting it into the Yolo Bypass. The Yolo Bypass  is a continuous, 40-mile open space corridor that is protected from urban  development pressure by flood easements. (See fig. 3.)
Lowering the water level in the Sacramento River as it passes the Natomas  Basin could, among other things, improve the reliability of the Natomas  Basin levees and may provide more cost-effective flood protection than the  current Natomas Basin levee improvement plan. However, as of June 2003,  the Corps had not yet analyzed the costs and benefits of modifying the weir  and the bypass or any other alternative method for Natomas Basin flood  protection.
section_title: The Corps Did Not Adequately Analyze Likely Cost Increases for the Common Features Project or Communicate Them to Congress in a Timely Manner
paragraphs: After the 1997 storm demonstrated vulnerabilities in the American River  levees, the Corps significantly changed the design of the levee  improvements but did not analyze the likelihood of cost increases for the  Common Features Project. The Corps then began constructing the  American River levee improvements without informing Congress that the  changes could greatly increase the overall costs of the project. By the time  that the Corps reported the significant cost increases in 2002, it had already  spent or made plans to spend more than double its original estimate for the  American River levee improvements authorized in 1996. Furthermore, as  previously discussed, the Corps estimates that it will spend more than  three times its original estimate by the time it completes this work. The  Corps has been able to pay for these levee improvements by spending  funds originally planned for the Natomas Basin and the additional  American River improvements authorized in 1999.
subsections: section_title: The Corps Did Not Adequately Analyze Likely Cost Increases for the American River Levee Improvements
paragraphs: The Corps did not analyze the risk of cost increases after changing the  design of the American River levee improvements in 1997 and, therefore,  did not provide Congress with information on the project’s exposure to  significant cost increases. A storm in January 1997 demonstrated that the  American River levees were vulnerable to floodwaters seeping under them,  which could cause them to fail. On the basis of this information, the Corps  significantly changed the design of the levee improvements but did not  conduct a cost risk analysis, or any other type of analysis, to determine the  extent to which these changes would increase the costs for the Common  Features Project.
According to the Corps’ policy, project management teams should consider  conducting a cost risk analysis when developing cost estimates for projects  with considerable uncertainties. A cost risk analysis identifies the areas of  a project that are subject to significant uncertainty about costs and  provides decision makers with a range of potential costs for a project and  the probability that these costs will be exceeded. For example, a cost risk  analysis might determine that there is a 50 percent chance that costs for a  particular project will exceed $5 million but only a 20 percent chance that  costs will exceed $8 million. According to a report from the Corps’ Institute  for Water Resources, this type of estimate is more accurate than a single  point cost estimate and provides decision makers with better and more  complete information.
However, the Corps did not analyze the risk of cost increases after  changing the design of the American River levee improvements even  though it had identified several factors that could lead to significant cost  increases. For example, by July 1997 the Corps recognized that it had to  close the gaps in the cut-off walls at bridges and other areas and extend the  depth of some walls from about 20 to about 60 feet, although the Corps had  not developed a final design for these improvements. By identifying a  project element with significant cost uncertainty—the design and depth of  the cut-off walls—the Corps essentially performed the first step of cost risk  analysis. However, the Corps did not follow through by quantifying this  uncertainty and determining a range of potential costs for the cut-off walls  or the likelihood that the potential costs within that range would be  exceeded—the second and third steps of the cost risk analysis. Given that  the Corps’ original cost estimate for the American River work was nearly  equal to its estimates of the benefits, if the Corps had conducted a cost risk  analysis, it would have shown whether there was a significant likelihood  that project costs would be greater than the economic benefits.
Furthermore, despite experiencing significant cost increases for the 1996  work, the Corps did not conduct a cost risk analysis to determine its  exposure to potentially significant cost increases for the 1999 work. In  addition, the Corps is not planning to conduct a cost risk analysis for the  Natomas Basin improvements. According to Sacramento district officials,  the Corps did not conduct a cost risk analysis because it did not believe  such an analysis was necessary to account for uncertainties in the project.
section_title: The Corps Did Not Provide Congress with Timely Information about Significant Potential Cost Increases for the American River Levee Improvements
paragraphs: The Corps’ planning guidance generally directs the Corps to seek new  spending authority from Congress if it determines that a project’s estimated  costs exceed the maximum project cost before it has awarded a project’s  initial contract. However, after making significant changes to the project’s  design in 1997, the Corps did not reevaluate its cost estimate to determine  if it could still implement the project without exceeding the maximum  project cost. For example, the Corps did not estimate the potential for cost  increases due to tripling the depth of some cut-off walls, which eventually  added $24 million in estimated costs to the project. In addition, the Corps  did not estimate the potential for cost increases due to closing the gaps in  the cut-off walls at bridges and other areas. This expense was not  considered in the Corps’ original 1996 cost estimate and potentially  involved the use of jet grouting—a technology the Corps had not previously  used to construct cut-off walls. Closing the gaps in the cut-off walls  eventually added $52 million in estimated costs to the project.
In spite of significantly changing the project’s design, the Corps awarded  the project’s first contract without updating its cost estimate to determine  whether it would need additional spending authority to complete the  project. In June 1998, the Corps issued the first Common Features Project  solicitation for bids to construct about 1.6 miles of the redesigned cut-off  wall on the north bank of the American River. These levee improvements  represented only about 8 percent of the total miles of planned American  River levee improvements, but the bid that the Corps selected amounted to  24 percent of the estimated cost for all of the American River levee work.  We believe that this difference should have (1) alerted the Corps to the  possibility that costs were likely to be much higher than it had originally  estimated and (2) warranted an update of the Corps’ cost estimate before it  awarded the initial contract.
According to a headquarters official, the Corps issued the first contract  without updating its total project cost estimate because it would have been  impractical to delay the project while the agency revisited cost estimates.  Furthermore, according to the Corps, the first contract was expected to be  more costly than future contracts because, among other reasons, it  involved work on only a small stretch of the levee, which limited possible  cost efficiencies. However, because the Corps did not analyze the potential  for cost increases for the remainder of the American River levee  improvements, it did not determine the likelihood that it would need  additional spending authority to complete the project before it awarded the  first contract.
The Corps has paid for the significantly increased costs of the American  River levee improvements by using funds planned for the Natomas Basin  and for the additional American River work authorized in 1999. Although  the Common Features Project has two separate components, and Congress  approved parts of the project in 2 different years, the project is subject to a  single maximum project cost. The Corps has the flexibility to spend  Common Features Project funds as it sees fit and is not required to allocate  funds in proportion to its original cost estimates for each component.
Following project authorization in 1996, the Corps began to construct the  American River levee improvements before the Natomas Basin  improvements. Although the Corps exhausted the funds it had originally  estimated that it would need to construct the American River levee  improvements, it was able to continue implementing the American River  work by spending funds it had originally planned to use for the Natomas  Basin work. With the authorization of additional work in 1999, effectively  raising the project’s maximum cost to about $120 million, the Corps also  was able to use funds planned for this work to pay for the increased costs  of the American River work authorized in 1996.
After it awarded the first Common Features Project contract, the Corps  was not required to inform Congress of project cost increases until it could  not contract for additional work without exceeding the maximum project  cost. According to the Corps, in March 2001 it briefed a number of  Members of Congress on its intention to prepare a report that would  evaluate the potential for the cost of the Common Features Project to  exceed the project’s maximum cost. However, it was not until February  2002, more than 4 years after it significantly modified the design of the  American River levee improvements, that the Corps reported to Congress  for the first time that due to significant cost increases, it could not  complete the project without exceeding the maximum project cost. By this  time, the Corps had spent or awarded contracts for more than twice the  amount it originally planned to spend on the American River levee  improvements authorized in 1996 and had completed about 90 percent of  the work. Furthermore, the Corps estimates that it will spend more than  three times its original estimate by the time it completes this work.  Because the Corps did not update its cost estimate or report the significant  cost increases to Congress until most of the 1996 American River work was  complete, Congress did not have the opportunity to determine whether the  significantly more expensive levee improvements were still the most  appropriate means of providing flood protection for Sacramento.
section_title: Corps’ Benefit Estimates for the American River Levee Improvements Are Incorrect
paragraphs: The Corps made mistakes in estimating the benefits for the American River  levee improvements because it incorrectly counted and valued the  properties that the levee improvements would protect and used an  inappropriate methodology to determine the amount of flood damages they  would prevent. Seven years after Congress authorized the project, the  Corps has not yet prepared an accurate assessment of the benefits of the  American River levee improvements. In addition, contrary to its guidance,  the benefit estimate the Corps prepared in 2002 did not describe the range  of possible benefits and the likelihood that the values in this range would  be realized. This additional information, describing the uncertainty of the  benefit estimate, would have provided decision makers with information  on the likelihood that the project’s benefits would be greater than its costs.  Furthermore, the Corps’ three-tiered quality control process did not  identify the mistakes that we found during the course of our review.
subsections: section_title: The Corps Made Mistakes in Counting and Valuing Properties and Determining Flood Damages When Estimating Project Benefits
paragraphs: In its original 1996 analysis of the benefits and costs of the American River  levee improvements, the Corps incorrectly counted the residential  properties that the proposed levee improvements would protect. As a  result, the Corps incorrectly calculated the benefits that these  improvements would provide. According to the Corps, the methodology it  used to count the number of residential properties in 1996 was “accepted  practice and consistent with Corps guidance and technology applicable at  the time.”  In 2002, the Corps used a different methodology that  incorporated new technologies and provided a more precise estimate of the  number of properties protected. Using this new approach, the Corps  determined that the actual number of residential properties protected by  the levee improvements is about 20 percent less than its original estimate.  The Corps did not calculate the amount that benefits would decrease due  to this change. However, given the small difference between the original  estimated annual benefits ($5.6 million) and the annual costs ($5.5 million)  of the American River levee improvements, if the Corps had incorporated a  more accurate estimate of the property inventory in its 1996 analysis, the  benefits of these improvements may have been less than the costs.
For flood protection projects, such as the Common Features Project, the  Corps calculates benefits as the dollar value of the physical damages to  residential, commercial, industrial, and public properties and  infrastructure that the levee improvements prevent. To calculate the  reduction in flood damage to properties, the Corps counts the number of  properties located in the potential flood area—known as the floodplain— and then assesses the monetary value of the structures and their contents.  The Corps uses this information to determine the property damage that  would result from floods of various depths and to estimate the impact that  the levee improvements would have in preventing this damage.
It is important to remember that, in addition to the economic benefits from  preventing property damage, levee improvements may reduce the risk of  loss of human lives, which is a benefit that is not included in the Corps’  calculations. According to the Corps, about 305,000 people live within the  American River floodplain and the number of lives lost because of levee  failure would depend on a variety of factors, such as the size of the flood,  warning time, time of day, and availability of evacuation routes. Because of  the many factors involved and the lack of historical data, the Corps was not  able to estimate the number of lives that would be lost as a result of levee  failure and flooding in the Sacramento area.
Although the Corps updated its benefit estimate in 2002 to incorporate the  benefits from the new levee improvements authorized in 1999, a  Sacramento district official acknowledged that the Corps again made  mistakes in estimating the number of properties the levee improvements  would protect. For the American River levee improvements authorized in  1999, the Corps identified an area that was larger than the area the levee  improvements would actually protect. As a result, the Corps overestimated  the number of properties protected and the benefits provided by the work  authorized in 1999. According to a Sacramento district official, the Corps  currently does not have the information it needs to determine the correct  area the levee improvements would protect and therefore is unable, at this  time, to provide a reliable estimate of the benefits from the 1999 work.
In addition, the Corps made mistakes in its 2002 analysis in estimating the  value of the residential properties the American River levee improvements  would protect. The Corps’ policy calls for calculating a property’s value as  the cost of replacing the structure less any depreciation, which accounts  for a reduction in a structure’s value due to deterioration prior to flooding.   Because the Corps had more than 100,000 residential properties to assess  and a limited amount of time and resources, it determined depreciated  replacement values for a small sample of 365 properties and then used the  results to estimate the depreciated replacement values for all properties.  However, the Corps did not correctly select the sample of properties.  According to members of both the Appraisal Institute and The Appraisal  Foundation, to accurately appraise a large number of properties by  sampling requires a separate sample for each residential property type,  such as single-family homes, condominiums, and apartment buildings.   Instead of conducting a separate sample for each type of property, the  Corps sampled all property types together and calculated an average  depreciated replacement value for all property types. As a result, it is  unclear whether the Corps accurately calculated depreciation, which in  turn raises questions about its estimates of the value of the residential  properties the American River levee improvements would protect.
Moreover, the Corps did not use a consistent, objective appraisal  methodology to calculate depreciation for the properties in the sample.  Instead, the Corps subjectively determined depreciation. For example, if  the Corps determined a structure was in “very good” condition it was  assigned a zero percent, 5 percent, or 10 percent level of depreciation.  However, the Corps could not provide us with its criteria for assigning the  level of depreciation. Furthermore, the Corps’ economists who made these  subjective decisions did not consult with the professional appraisers in the  Corps’ Sacramento district office to identify alternative appraisal  methodologies that may have been more appropriate. According to the  Corps, the methods it used to determine depreciation are “standard  practice at the Corps and are consistent with prior and existing guidance.”   Nonetheless, we believe that the shortcomings identified above raise  questions about the accuracy of the Corps’ property value estimates and, in  turn, the project benefit estimates that are, in part, based on them. The  Corps said it recognizes the need to strengthen its methodologies and is  currently developing a new tool to estimate property values.
Finally, the Corps’ 2002 analysis did not use the methodology described in  Corps guidance to determine the number of properties that are located in  the 100-year floodplain and the damages they would sustain in a 100-year  flood.  The 100-year floodplain is the land area that may be affected during  a flood that has a 1 percent chance of occurring every year. Instead of  following Corps guidance by directly counting the properties located in the  100-year floodplain and calculating the damages they would sustain in a  100-year flood, the Corps estimated the damages using a methodology that  relied on the results from its incorrect 1996 count of properties. The Corps’  use of this alternative methodology further calls into question the accuracy  of its benefit estimate for the American River levee improvements  authorized in both 1996 and 1999, which is based in part on this flood  damage assessment. The Corps told us that it could have directly counted  the properties in the 100-year floodplain but the necessary information was  not available in a “user friendly” format, and that the additional effort  needed to collect more accurate information was not expected to change  the results. As a result, the Corps did not believe this was an effective use  of resources. However, the Corps did not provide us with any evidence to  support the validity of calculating the 100-year flood damages as it did or to  validate its contention that the results would not change if it had used the  methodology prescribed in its guidance.
section_title: The Corps Has Not Provided Congress with Information on the Range of Possible Benefits from the Levee Improvement Work or the Likelihood They Will Be Realized
paragraphs: The Corps has not followed its policy to provide Congress with an estimate  of the range of possible benefits from the American River and Natomas  Basin levee improvements and the likelihood that these benefits will  actually be realized. In 1996, the Corps established a policy calling for  benefit estimates and benefit-cost comparisons for flood protection  projects to be reported with their associated probabilities. For example,  rather than reporting that the benefits for a particular project are exactly  $1.5 million, the Corps could report that it is 80 percent confident that  project benefits will be at least $1 million but it is only 30 percent confident  that benefits will reach $2 million. The Corps recognizes that this  information can assist Congress in understanding the uncertainty involved  in achieving various levels of benefits and in determining whether those  risks justify funding the project.  According to the Corps, it did not estimate  a range of benefits for the Common Features Project in 1996 because the  computer software used to assess the project’s benefits and costs was  developed prior to the 1996 guidance and did not have the capability to  calculate a range of values.
However, in its 2002 reanalysis of project benefits, when a new version of  the software capable of calculating benefit ranges and probabilities was  available and costs for the American River work had significantly  increased, the Corps chose not to calculate a range of benefits and instead  continued to report a single estimate. Because the Corps’ 2002 estimates of  benefits and costs for the American River work were so close in value (1.1  to 1), an analysis of the potential range of benefits would have revealed  whether there was a significant probability that project benefits could be  lower than the single estimate the Corps reported and perhaps lower than  project costs. According to a Sacramento district official, the Corps did  not use the new version of its software that could have calculated the range  of benefits to maintain consistency with information on flood protection it  had previously released to the public. For example, the Corps has reported  to the public that the American River levees have about a 1 percent chance  of being breached by floodwaters in any given year. This estimate of flood  protection could be different if calculated using the newer version of the  software. The Corps was concerned that using the newer software would  require it to report a different, and perhaps slightly lower, level of flood  protection, which would confuse the public. However, by taking this  approach, the Corps did not provide Congress with important information  about the uncertainty surrounding the amount of benefits the project  would provide.
section_title: The Corps’ Quality Control Process Did Not Identify Flaws in Its Benefit Analyses
paragraphs: Three organizational levels within the Corps—district, division, and  headquarters—reviewed and approved the 1996 and 2002 benefit analyses  for the American River component of the Common Features Project, but  these reviews did not identify the mistakes that we found. This issue raises  questions about the adequacy and effectiveness of the Corps’ review  process. We raised similar concerns about the Corps’ review process in our  report on the Delaware River Deepening Project, which found significant  miscalculations and invalid assumptions in the project’s economic analysis  that the Corps did not find during its reviews.
For the Common Features Project, the Corps’ Sacramento district office  conducted the 1996 study that analyzed the technical and economic aspects  of the proposed project and the 2002 report updating that information. The  Corps’ Los Angeles district office reviewed the 2002 economic analysis for  technical accuracy. Next, the Corps’ South Pacific division reviewed the  analysis; although, following the Corps’ policy, it did not review the  district’s work for technical accuracy or verify the underlying analysis.  Rather, the division checked that the district’s reports had undergone a  technical review, and that the district had issued a quality control  certification report with the necessary district office-level approvals. The  division then forwarded the project to headquarters. Corps headquarters  also did not conduct a technical review of the analysis. Rather,  headquarters checked that the district’s report adhered to Corps policies  for conducting a benefit-cost analysis and addressed any concerns  headquarters had raised.
These review processes, however, were ineffective in detecting and  correcting the mistakes in the benefit analyses we identified. For example,  for the 2002 study, we found no indication that the mistakes made in  calculating the number and the value of residential properties or the  mistake made in calculating flood damages were detected during the  Corps’ review process. For the 2002 analysis of the American River levee  improvements, a Corps economist from another district independently  reviewed the benefits analysis. However, the review was not  comprehensive enough to sufficiently identify methodological problems.  The review primarily focused on process-oriented issues, such as assessing  whether the Sacramento district conducted certain analyses, rather than  examining the technical aspects of how the analyses should have been and  were conducted.
section_title: Conclusions
paragraphs: It is critical that decision making and priority setting be informed by  accurate information and credible analysis. Reliable information from the  Corps about the costs and benefits for the American River component of  the Common Features Project has not been present to this point. The  analysis on which Congress has relied contained significant mistakes. And  of most relevance today, the analyses for the remaining work do not  provide a reliable economic basis upon which to make decisions  concerning the American River levee improvements authorized in the  WRDA of 1999. To provide a reliable economic basis for determining  whether these improvements are a sound investment, the Corps’ analysis  needs to adequately account for the risk that project costs could increase  substantially, correctly count and value the properties the project would  protect, and include information on the range of potential project costs and  benefits.
Moreover, because the Corps has not made some critical decisions  regarding the Natomas Basin work, it is not yet known whether the Corps  will be able to identify cost-effective flood protection options for this area.  Specifically, the Corps has not determined whether it will (1) conduct a  cost risk analysis of its current plan to identify its exposure to potentially  significant cost increases or (2) evaluate the costs and benefits of  alternatives to the current levee improvement plan to identify the most  cost-effective flood protection option. In addition, identifying cost-effective  flood protection involves reporting the range of potential project benefits  and the probability of achieving them, which the Corps has not done for the  Natomas Basin work. If the Corps begins implementing the authorized  Natomas Basin work before it completes a comprehensive, accurate cost- benefit analysis, significant unanticipated cost increases could materialize,  as they did with the American River work. Finally, for Congress to have  confidence that the Corps’ economic analyses have been prepared  accurately, the Corps’ quality control process would need to be sufficiently  independent and detailed to identify the types of mistakes that our review  revealed.
section_title: Recommendations for Executive Action
paragraphs: For the American River levee improvements authorized in 1999 and for the  planned Natomas Basin work, we recommend that the Secretary of the  Army direct the Corps of Engineers to   determine whether it is appropriate to conduct risk analyses of project  costs and document the basis for that decision in its project files;  report information to Congress on the range of potential project benefits  and the probability of achieving those benefits, as called for in the  Corps’ guidance, in future benefit-cost analyses; and  arrange for a credible, independent review of the completeness and  accuracy of the revised benefit-cost analyses.
For the American River project component, we also recommend that the  Secretary of the Army direct the Corps of Engineers to reanalyze the  benefits of the improvements authorized in the WRDA of 1999, correcting  for the mistakes made in counting and valuing properties and the  inappropriate methodology used to calculate flood damages.
Additionally, for the Natomas Basin project component, we recommend  that the Secretary of the Army direct the Corps of Engineers to   analyze the costs and benefits of alternatives to the current levee  improvement plan and identify the flood protection plan that provides  the greatest net benefits and  submit a report to Congress that includes a cost estimate for all of the  planned Natomas Basin work, and wait until Congress authorizes  funding that is based on the report before beginning construction of any  Natomas Basin levee improvements.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Secretary of the Army for review  and comment. In commenting on the draft report, the Army concurred with  all of our recommendations. Perhaps most significantly, the Army  acknowledged that on the basis of the Corps’ experience in constructing  the American River levee improvements, there is a potential for substantial  cost increases for the Natomas Basin levee improvements, and therefore  the Corps needs to investigate a wider array of alternatives for providing  flood protection for the Natomas Basin. In addition, although the Army  concurred with our recommendation to reanalyze the benefits of the  improvements added to the American River component of the project in  1999, it contended that the Corps has already completed the reanalysis. We  disagree. In 2002, the Corps prepared an analysis of the economic benefits  for the work added to the project in 1999. However, our review found  several mistakes in this analysis, including mistakes in counting and  valuing properties and using an inappropriate methodology to calculate  flood damages. We continue to believe that before the Corps begins  construction of the work added to the American River project component  in 1999, it should reanalyze this work to ensure it is cost beneficial.
The Army stated that the report does not recognize the significant role  Congress played in 1999 by adding additional work to the project and  providing funds for construction before the Corps had developed reliable  cost estimates, which created the situation of which our report is critical.  By focusing its comment on the relatively small amount of work added in  1999, the Army avoided the main issues regarding the American River levee  improvements discussed in our report. Specifically, that (1) the costs for  the American River component of the project approved in 1996 are more  than triple the original estimate; (2) the Corps had information, before  construction began, that should have alerted it that costs would likely  increase greatly; and (3) the Corps should have communicated this  information to Congress at that time, but it did not. Furthermore, the  additional funding provided by Congress for the work authorized in 1999  has not been used for that purpose, but rather has been used to fund the  cost overruns for the work authorized in 1996. The full text of the Army’s  comments, and our responses to them, are presented in appendix III.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  date of this letter. At that time, we will send copies of this report to the  appropriate congressional committees, other interested Members of  Congress, and the Secretary of the Army. We also will make copies  available to others upon request. In addition, the report will be available at  no charge on the GAO Web site at http://www.gao.gov.
If you, or your staff, have any questions about this report, please contact  me at (202) 512-3841. Key contributors to this report are listed in appendix  IV.
section_title: Scope and Methodology
paragraphs: To determine the reasons for the cost increases for the Common Features  Project, we obtained the key cost estimation documents prepared by the  U.S. Army Corps of Engineers’ (the Corps) Sacramento district office.  Specifically, we obtained the Corps’ 1996 Supplemental Information  Report, American River Watershed Project; the 1997 Addendum to the  Supplemental Information Report; the 2002 Second Addendum to the  Supplemental Information Report; and other related documents. We  reviewed the Supplemental Information Report, which examined a  number of different flood protection alternatives, because it provided the  foundation, including cost estimates, for the project elements that the  Corps later grouped together as the Common Features Project. The  Addendum to this report documented the Corps’ first cost estimate that  specifically and exclusively addressed the Common Features Project and  included separate costs for both the American River component and the  Natomas Basin component of the project. We reviewed the Second  Addendum, the Corps’ most current official cost estimate, to establish the  amount of and the reasons for the increased costs. We also analyzed  construction contracts to determine the cost of responding to accidents  constructing the levee improvements authorized in 1996. We calculated the  extent of inflation for both components of the project, using the Corps’  Civil Works Construction Cost Index System and a cost index from the  Office of Management and Budget. Finally, we discussed the reasons for  the cost increases with economists, cost estimators, project managers,  engineers, and other staff from the engineering, constructions operations,  and planning divisions of the Corps’ Sacramento district office.
To determine whether the Corps analyzed the likelihood of significant cost  increases for the project and reported them to Congress in a timely manner,  we reviewed the Corps’ (1) policy regarding the use of cost risk analysis in  estimating costs for civil works projects (Engineer Regulation 1110-2-1302)  and (2) requirements for updating project cost estimates and informing  Congress of cost increases (Engineer Regulation 1105-2-100). We also  reviewed a document from the Corps’ Institute for Water Resources on  incorporating risk and uncertainty into cost estimation. We examined the  American River levee improvement construction contracts to determine  when the Corps became aware of cost increases for this component of the  project. In addition, we reviewed the Corps’ annual budget documents  related to the Common Features Project, which contained information on  the project’s status and any changes or cost increases. We examined the  Corps’ cost estimates from 1996, 1997, and 2002 for compliance with  relevant Corps cost estimating guidance and to determine if the Corps  provided Congress with accurate information about significant expected  cost increases. Finally, we discussed the Corps’ cost estimating procedures  and awareness of likely cost increases with cost estimators, project  managers, and other staff from Corps headquarters and the Sacramento  district office.
To determine whether the Corps correctly estimated the economic benefits  of the American River levee improvements, we reviewed the extent to  which the Corps followed accepted economics practices and whether the  major assumptions used in the analysis were reasonable and well  supported. We obtained the Corps’ 1996, 1997, and 2002 economic analyses  for the Common Features Project and discussed the sources of these data  and conduct of the analyses with the Corps economists responsible for  preparing them. We also discussed the basis for the hydrologic and  engineering assumptions used in the economic analysis with the Corps  specialists who provided this information. In addition, we obtained the  Corps’ guidance (Engineer Regulations 1105-2-100 and 1105-2-101 and  Engineer Manual 1110-2-1619) on the accepted economic and engineering  methodologies for incorporating risk and uncertainty into benefit  estimation. To verify and supplement the information we received from  officials in the Corps’ Sacramento district office, we spoke with, among  others, Corps officials at the Hydrologic Engineering Center and the  Institute for Water Resources and experts in real estate appraisal from the  Appraisal Foundation and the The Appraisal Institute. Where we identified  problems that affected the accuracy of the benefit analysis, we discussed  them with the responsible Corps staff and considered any new data or  revisions that they provided. Finally, we identified the roles and  responsibilities of the Sacramento district office, South Pacific division,  and headquarters in the Corps’ internal quality control process for the  Common Features Project. We also obtained copies of the quality control  reviews and the reviewers’ comments on the economic analysis and  discussed the comments and their resolution with Corps officials.
We conducted our review from September 2002 through September 2003 in  accordance with generally accepted government auditing standards.
section_title: Conversion of Costs to Constant Dollars
paragraphs: In this report, unless otherwise noted, we present costs in the dollar values  for the years in which they were estimated, not in constant dollars. For  example, the Corps estimated the original cost of the project as $57 million  in 1996, and that is how we present it in this report. We did not adjust the  costs to constant dollars to account for inflation to maintain consistency  with the figures in published Corps reports on the Common Features  Project. However, table 3 shows the Corps’ 1996 cost estimates for key  components of the Common Features Project and also shows the same  estimates adjusted to 2002 constant dollars to account for inflation.
section_title: Comments from the Department of the Army
subsections: section_title: GAO Comments
paragraphs: The following are GAO’s comments on the Department of the Army’s letter  dated September 22, 2003. 1. Although the Army asserted that we made some factual errors, its  subsequent comments failed to identify any specific factual errors.  2. The Army believes that the report does not recognize the significant  role Congress played in 1999 when it added additional work to the  project and authorized funds for construction before the Corps had  developed reliable cost estimates. While the Congress did add work to  the Common Features Project in the Water Resources Development Act  (WRDA) of 1999 without a Corps report, the cost of this work is  relatively small in comparison to the work authorized in 1996. We  believe the Army’s comment is not relevant to the main focus of our  report, which is the significant cost increases for the work the Corps  recommended and the Congress authorized in 1996. For example, the  costs for the work the Corps recommended on the American River  more than tripled from $44 million in 1996 to $143 million in 2002. In  contrast, the estimated cost for the work on the American River levees  the Congress added in 1999 is about $15 million. We believe our report  accurately reflects the limited impact the addition of work in 1999 had  on the American River component of the project’s overall cost.  Furthermore, the additional funding provided by Congress for the work  authorized in 1999 has not been used for that purpose, but rather has  been used to fund the cost overruns for the work authorized in 1996.    3. The Army stated that the consistent provision of funds to the Corps by  Congress, at or exceeding the Corps’ budget request, created the  situation of which our report is critical. We do not agree. Two of the  main issues in our report are that the costs of the American River  component of the project nearly tripled due to design changes, and that  the Corps began construction of the American River levee  improvements without analyzing the likelihood of these cost increases  or reporting the potential cost increases to Congress. The fact that  Congress provided funding for the project does not absolve the Corps  of its responsibility to communicate project cost increases in a timely  manner.  4. The Army implied that Congress was informed of potential cost  increases for the Common Features Project during the yearly  appropriations process. This is not the case on the basis of our review  of all of the Corps’ submissions for the annual appropriations process  from 1997 through 2001. As our report states, it was not until February  2002, more than 4 years after it had significantly modified the design of  the American River levee improvements, that the Corps informed  Congress for the first time of the significant cost increases for the  American River component of the project. 5. The Army stated that the levee improvements were not originally  designed to withstand the destructive effect of seepage and that this  design was not an error. Rather, an unknown condition (i.e., the  potential for destructive seepage under the levees) resulted in design  changes and increased costs. Our report does not criticize the Corps for  not anticipating the need for a levee improvement design that would  stop seepage under the levees. We acknowledge that the flood of  January 1997 caused the Corps to change the design of its levee  improvements. However, as our report notes, the Corps did not develop  new cost estimates after making these design changes and did not  communicate the resulting significant cost increases to Congress in a  timely manner.  6. We do not consider the separable elements of the Common Features  Project as separate projects. This report makes clear that there is one  Common Features Project comprised of an American River component  and a Natomas Basin component.    7. We agree with the Army that, in 1996, the Corps was not aware of any  significant areas of cost uncertainty for the proposed American River  levee improvements. However, as the Army recognizes, the flood of  January 1997 showed that the Corps’ design for the levee improvements  should be significantly modified. After making these design changes,  though, the Corps did not estimate the potential for cost increases due  to tripling the depth of some cut-off walls or closing the gaps in cut-off  walls at bridges and other areas. These design changes eventually  added $76 million to the cost of the project.  8. The Army stated that the Corps believes that its review process results  in decision documents that form the basis for sound recommendations.  However, in two recent cases, we found that the process did not serve  its intended purpose.  As this report documents, the Corps’ review  process was ineffective in detecting and correcting the mistakes in the  benefit analyses we identified. We raised similar concerns about the  review process in our June 2002 report on the Delaware River  Deepening Project.  9. We did not recommend that the Corps reanalyze the costs and benefits  of the work authorized in 1996. We agree that a reanalysis of this work,  which is nearly complete, would be of little value. However, we  continue to believe that a reanalysis of the economic benefits from the  work authorized in 1999 is necessary because the Corps’ initial analysis  contained significant mistakes and construction of the work has not yet  begun. Before beginning construction of this work, the Corps should  verify that the work is in fact cost beneficial. In addition, the Corps  should arrange for a credible, independent review of the completeness  and accuracy of its reanalysis.  10. The Army contends that the Corps has already completed the  reanalysis we recommended of the work added to the American River  component of the project in 1999. We disagree. The Corps analyzed the  economic benefits for the 1999 work added to the project for the first  and only time in 2002. Our review found several problems with the  Corps’ 2002 analysis of the benefits from this work. For example, we  found that the Corps had made mistakes in how it counted and valued  properties and had used an inappropriate methodology to calculate  flood damages. As a result, the Corps has not yet prepared an accurate  assessment of the benefits resulting from the 1999 work. The Corps has  not begun any construction for the work authorized in 1999, and it is  not currently known if the benefits provided by this work are greater  than the costs. Consequently, we recommend a reanalysis of these  benefits in order to correct the mistakes that we identified.  11. The Army stated that the Corps does not conduct individual real estate  appraisals to determine the value of each property that could be  damaged in a flood. Our report does not suggest that the Corps should  conduct such appraisals. Rather, we identified weaknesses in the  sample the Corps used to estimate property values and its methodology  for calculating depreciation for the properties in the sample. For  example, to accurately appraise a large number of properties by  sampling requires a separate sample for each residential property type,  such as single-family homes and apartment buildings. However, the  Corps sampled all property types together. In addition, the Corps did  not use a consistent objective appraisal methodology to calculate  depreciation for the properties in the sample. These weaknesses raise  questions about the accuracy of the Corps’ property value estimates  and the project benefit estimates that are, in part, based on them.  12. The Army claims that there are approximately 163,000 residential  structures in the 400-year floodplain. This is not correct on the basis of  the Corps’ most current analysis. The estimate of 163,000 residential  structures comes from the Corps’ 1996 economic analysis. However, in  2002, the Corps updated its analysis and found that it had  overestimated the number of residential structures in 1996. The Corps’  2002 analysis estimated that there were 115,347 residential structures in  the 400-year floodplain.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual above, Jeff Arkin, Chuck Barchok, Judy  Hoovler, Richard Johnson, Mark Metcalfe, Ryan Petitte, and Stephen  Secrist made key contributions to this report.
section_title: GAO’s Mission
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subsections: section_title: Order by Mail or Phone
section_title: To Report Fraud, Waste, and Abuse in Federal Programs
section_title: Public Affairs