Land Management Systems: Actions Needed in Completing the Automated Land and Mineral Record System Development
Released: 1998-05-15T00:00:00

Letter

Background

BLM’s mission is to sustain the health, diversity, and productivity of the public lands for the use and enjoyment of present and future generations. It manages approximately 264 million acres of public land in 28 states—about one-eighth of the land in the United States. It also manages the subsurface mineral resources on another 300 million acres of lands administered by other government agencies or owned by private interests. Public resources managed by BLM include rangelands, timber, minerals, watersheds, wildlife habitats, wilderness and recreation areas, and archaeological and historical resources. The bureau has 210 state, district, and resource area offices that manage over 1 billion paper documents, including land surveys and surveyor notes, records of land ownership, mining claims, and oil and gas leases. According to BLM, most of the paper documents are deteriorating and becoming increasingly difficult to read.

During the energy boom in the early 1980s, BLM found that it could not handle the case processing workload associated with a peak in the number of applications for oil and gas leases. It recognized that to keep up with increased demand, it needed to automate its manual records and case processing activities. Thus, in the mid-1980s, the bureau began planning to acquire an automated land and mineral case processing system. The scope and functionality of the planned system changed over the years, ranging from a system to automate paper documents and records and case processing activities to a system that would provide improved efficiency for recording, maintaining, and retrieving land description, ownership, and use information and provide geographic information system (GIS)capabilities.

In 1993, BLM decided on the scope and functionality of the ALMRS/Modernization. The bureau designated it a critical system for (1) automating land and mineral records and case processing activities and (2) providing information to support land and resource management activities. The ALMRS/Modernization is expected to more efficiently record, maintain, and retrieve land description, ownership, and use information to support BLM, other federal programs, and interested parties. It is to do this by establishing a common information technology platform, integrating multiple databases into a single geographically referenced database, shortening the time to complete case processing activities, and replacing costly manual records with automated ones.

The ALMRS/Modernization consists of the ALMRS IOC, geographic coordinate database (GCDB), and modernization of BLM’s computer and telecommunications infrastructure and rehosting of selected management and administrative systems. These components are described more fully below.

The ALMRS IOC is the flagship of the ALMRS/Modernization. With new software and upgraded hardware, it is to provide (1) support for case processing activities, including leasing oil and gas reserves, recording valid mining claims, processing mineral patents, and granting rights-of-way for roads and power corridors and (2) information for land and resource management activities, including timber sales and grazing leases. ALMRS IOC is to replace various manual and ad hoc automated BLM systems currently operating on older mainframe computers.

GCDB is the database that is to contain geographic coordinates and survey information for land parcels. Other databases, such as those containing land and mineral records, are to be integrated with GCDB. ALMRS IOC will tie BLM’s records and land and mineral resource data to the legal descriptions of specific land parcels.

The information technology modernization and rehost component consists of installing computer and telecommunications equipment and office automation applications, and converting selected management and administrative systems to a relational database system to be used throughout BLM.

Some elements of the ALMRS/Modernization, such as new computer and telecommunications equipment, e-mail, and office automation, were installed at BLM offices from fiscal years 1994 through 1996. The 12 administrative applications have been rehosted and are operational. According to BLM’s latest estimates, the ALMRS/Modernization is expected to cost about $594 million through fiscal year 2002, about 47 percent more than the $403 million estimate provided to the Office of Management and Budget in 1993. According to the Assistant Director for Information Resources Management (IRM), the increase is largely due to costs that were not included in the original agreement with OMB, including almost $105 million for technology refreshment.

Concerned that BLM might deploy the system prematurely, the House and Senate appropriations committees in fiscal year 1996 directed BLM to (1) test, verify, and validate that ALMRS operates as specified and (2) certify to them that it performs accurately and effectively and provides the expected capabilities prior to deployment. BLM retained a contractor to conduct the independent verification and validation testing and an operational assessment, testing, and evaluation and expects to base its certification to the committees on these tests. In our March 1997 report,we stated that BLM would not be ready to deploy ALMRS until it has completed essential management plans, policies, or procedures to help ensure a successful transition and operating environment.

BLM Has Not Fully Implemented Our Recommendations to Reduce Risks

As of February 20, 1998, BLM had not fully implemented the recommendations contained in our March 1997 report. BLM’s efforts to develop a security plan and an architecture, transition plans, and operations and maintenance plans were incomplete. BLM had taken substantial action to establish a configuration management program, but it had not yet produced a credible project schedule. These management tools are essential to manage the remainder of the project, help ensure system availability and performance, and avoid security and operational problems.

Security Planning Is Incomplete

Security focuses on the ability to ensure the confidentiality, integrity, and availability of stored and processed data. Unsecured or poorly secured systems are highly vulnerable to external and internal attacks and unauthorized use. Security planning includes the identification of high-level security requirements, including mission, management, and technical security requirements; functional security requirements that cover users’ security needs; data-sensitivity analysis to identify data requiring special protection; and a security architecture that describes the security controls and relationships among the various system components. The ALMRS/Modernization security plan should define the policies and procedures for operating and maintaining a secure environment. In our March 1997 report, we recommended that before deploying ALMRS IOC, BLM develop a system security architecture and plan, including security policies and procedures; disaster and recovery plans; and security test, evaluation, and certification plans to reduce risks to the availability and integrity of stored and processed data.

BLM has not yet developed a security architecture. It has developed a security plan, finalized some policies—such as those governing user access to ALMRS/Modernization components—and has been working to complete contingency plans for the state offices and their subordinate district and area offices. Also, in October 1997, BLM conducted a risk assessment for the planned deployment of ALMRS IOC to the New Mexico State Office. In January 1998, ALMRS IOC was certified for operation in New Mexico by the Department of the Interior’s Information Technology Security Manager.

Our review of BLM’s security plan and related documents shows that the plan is not based on a documented risk assessment of ALMRS and does not provide sufficient detail to manage the security of ALMRS and its databases. Because BLM has no documented risk assessment of the ALMRS, it has no basis for asserting that the system is secure or the plan adequately addresses the various vulnerabilities and risks attendant to a nationwide client-server system. Also, the risk assessment performed at the New Mexico State Office focused on policies, procedures, and conditions at that office but did not deal with the security of, or assess the vulnerabilities of and risks to, ALMRS.

Transition Plans Do Not Fully Address Key Issues

The process of deploying a major information system that people will use to do their jobs requires careful planning. Many of the 210 BLM offices nationwide that will receive ALMRS/Modernization—designed to automate many manual functions—have little or no experience implementing client-server systems. The transition from automated capabilities provided by a centrally managed mainframe system to a locally managed client-server environment requires changes in organizational roles, responsibilities, and interrelationships among the units and people using the system. A transition plan should address these issues and guide BLM in defining new operational procedures. In our March 1997 report, we recommended that before deploying ALMRS IOC, BLM develop transition plans outlining the changes in organizational roles, responsibilities, and interrelationships among the units and people using the ALMRS/Modernization system to reduce the risk associated with those changes.

BLM’s National Information Resources Management Center developed the ALMRS Transition/Deployment Plan, dated September 2, 1997, to be used as a guide for deploying the needed upgrades for the hardware and software and transitioning to the ALMRS/Modernization platform and ALMRS IOC.

According to a senior program analyst for the ALMRS project, 4 of the 12 state offices have prepared transition plans for their operations and the offices under their jurisdictions. BLM provided a copy of the 4 state offices’ plans.

Our review of the ALMRS Transition/Deployment Plan showed that while the plan generally addresses transition, its primary focus is on deployment activities. BLM notes that subsequent versions of the plan will provide more transition information to help each state office make use of ALMRS in the most effective and efficient way. The Assistant Director for IRM told us that the ALMRS Transition/Deployment Plan will be updated to incorporate the recent work of user advisory teams and lessons from final ALMRS testing. Our review of the 4 state offices’ plans showed that only 1 of them identified and addressed transition issues, such as how the state and subordinate offices will deal with oil and gas, mining, and solid mineral business process changes resulting from the implementation of ALMRS. Unless BLM ensures that the revised plans adequately address transition issues, BLM faces increased risks of disruptions to its work processes and impairments to its ability to (1) conduct its land and mineral management business and (2) use ALMRS most effectively.

Overall Operations and Maintenance Plan Does Not Address Site Functions

Operations and maintenance of information systems based on a client-server architecture require a large number of highly skilled people. Unlike the centrally managed legacy mainframe systems that have been supporting BLM operations, the ALMRS/Modernization will require management and technical support at each major BLM site. This support includes UNIX system managers, database administrators, user support and telecommunication specialists, and security officers. In our March 1997 report, we recommended that before deploying ALMRS IOC, BLM develop operations and maintenance plans addressing the acquisition, management, and maintenance of managerial and technical support for the ALMRS/Modernization to help ensure successful operations.

BLM has developed a draft operations and maintenance plan for the National Information Resources Management Center. This plan describes the (1) routine operations and maintenance services that the National Information Resources Management Center will provide and (2) approach that will be used to provide management and technical guidance necessary for the operations and maintenance of ALMRS. The plan, however, does not address how BLM will provide for operations and maintenance functions at the major BLM sites that will be responsible for operating and maintaining ALMRS on a daily basis. This is critical because BLM will be relying on ALMRS to conduct its business and maintain its official records. The Assistant Director for IRM stated that the state offices are being contacted to ascertain whether they need additional or more specific guidance to meet these responsibilities. Due to the many sites involved and the complexities of the systems, sites will need operations and maintenance plans that clearly describe how they are to fulfill their responsibilities and how these responsibilities will be handled when there are unexpected shortages of qualified staff.

Configuration Management Program Is Being Implemented

Configuration management plans, policies, and procedures are a set of management controls over the composition of and changes to computer and network systems components and documentation, including software code documentation. Configuration management is essential to successfully manage complex information systems and ensure integrity throughout their life cycles. System modifications without the safeguards imposed by the discipline of configuration management could lead to undesirable consequences. For example, they could cause system failures, endanger system integrity, increase security risks, and degrade system performance. In our March 1997 report, we recommended that before deploying ALMRS IOC, BLM establish a robust configuration management plan and related policies and procedures for establishing a program focused on managing the components of and all changes to all BLM information systems, including systems not related to the ALMRS/Modernization, to ensure successful management and integrity of the ALMRS/Modernization.

Our review of the latest configuration management guidance and discussions with project officials show that BLM has taken action to establish a configuration management program. BLM has developed a draft configuration management plan and associated policies and procedures and has taken action to implement them. BLM’s configuration manager estimated that implementation of the configuration management program is about 85 percent complete. Since BLM’s plan is still in draft and actions are not fully completed, we have not yet reviewed the configuration management program.

ALMRS Project Schedule Risks Continue

In March 1997, we reported that in its latest schedule, BLM planned to deploy ALMRS IOC in its Arizona, Idaho, and New Mexico offices by the end of fiscal year 1997 and complete the deployment to the remaining states in fiscal year 1998. We stated that BLM might not be able to maintain this schedule because it continued to allow insufficient time between critical milestones to deal with problems that were likely to arise. At that time, BLM’s own project management plans cited concern that milestones were overly optimistic, listed them as a major risk, and stated that the short time frames were influenced by BLM’s desire to begin deploying the system in fiscal year 1997. We recommended that BLM fully update the project schedule, including analyzing human resource usage and task relationships to establish reliable milestones and a critical path to complete the project.

Although a complete, current, and accurate project schedule is essential to adequately manage and control the hundreds of tasks remaining to complete the project, BLM has not linked available staff resources to those tasks in developing the ALMRS project schedule. BLM revised the project schedule again in September 1997 without implementing our recommendation and was not able to meet critical milestones. BLM is again revising its plans and milestones, but although it is planning to analyze human resource usage and task relationships in establishing milestones for deployment activities, it is not planning to do so for its schedule to complete, test, and certify ALMRS.

Table 1 shows the acceptance testing and deployment milestones BLM is anticipating pending formal revision of its plans and schedule. According to the anticipated milestones, initiation of deployment will be about 9 months behind the schedule in place at the time of our March 1997 report. This represents more than a 2-year delay from the schedule delivered to OMB when the project was approved in 1993.

Status of the ALMRS/ Modernization Project

BLM expected to certify to the Appropriations Committees in December 1997 that ALMRS performs accurately and effectively and provides expected capabilities after completing beta testing in November 1997 and operational assessment test and evaluation (OAT&E) in December 1997.

However, this milestone was not met because numerous problems were encountered during beta testing that required correction before BLM could begin OAT&E. Also, shortly after beta testing, BLM discovered that data converted from its legacy systems for ALMRS were not reliable because of errors in the conversion software. Since then, BLM has been making corrections to resolve the software and other problems and revising final testing plans and milestones. Continuing delays in implementing ALMRS may place BLM at risk of losing information technology support for core business processes because of the imminent Year 2000 computer problem.

Problems Encountered During Beta Testing

The following problems emerged during the beta test of ALMRS.

BLM encountered unexpected workstation failures and slowdowns caused by insufficient workstation memory and by problems discovered in two BLM-developed software applications that had not been sufficiently tested.

BLM had not yet determined with sufficient certainty how BLM staff will use ALMRS and the expected workload that they will generate in performing their day-to-day duties. A realistic operational usage definition of ALMRS workstations is essential for the design and conduct of OAT&E.

After beta testing, BLM converted data from legacy systems in the New Mexico State Office’s jurisdiction to the database management system used in the ALMRS/Modernization and expanded the sample size for testing and validating the data. BLM discovered that some of the data were being converted incorrectly. BLM identified 43 software errors that resulted in missing land descriptions, incorrect associations, incomplete conversions to designated data elements, and accurate conversions being written into error files. BLM estimated that some of these errors will take up to 4 months to correct.

According to the project comanager, BLM is analyzing the data conversion problems, performing further testing and validation, identifying those problems that must be corrected prior to performing OAT&E, and correcting the data conversion software. BLM also plans to reconvert and update the New Mexico database and analyze and validate the new database prior to deployment.

BLM Plans to Correct Problems

As a result of problems found during and after beta testing, BLM slipped its schedule to allow time to correct and revise its strategy and milestones for OAT&E and independent verification and validation. In conjunction with its OAT&E and independent verification and validation contractor, BLM agreed that 12 conditions need to be satisfied before OAT&E can begin. The conditions include the completion of training manuals and aids for BLM-developed software establishment of data sharing procedures and a public room plan; establishment of a national help desk; development of a maintenance plan that delineates necessary activities for maintaining the contractor- and BLM-developed software components of ALMRS IOC; and identification of automated access and training requirements for the Mineral Management Service, another part of the Department of the Interior that uses BLM land and mineral data.

At the end of our field work, most of the conditions had not been met and BLM had not made the requisite database corrections for OAT&E. BLM expected to conduct the OAT&E in March 1998, certify ALMRS IOC in April 1998, and deploy ALMRS IOC to the first state office jurisdiction in June 1998. However, the schedule estimates remain unreliable because BLM had not provided for unexpected problems or analyzed human resource usage and task relationships in establishing critical milestones in revising the project schedule, as we recommended in our March 1997 report.

Year 2000 Risks Are Appearing

The recent and potential future delays in the ALMRS/Modernization program introduce the risk that BLM will lose information technology support for its core business processes because of the looming Year 2000 problem. The Year 2000 problem is rooted in the way dates are recorded and computed in many computer systems. For the past several decades, systems have typically used two digits to represent the year, such as “98” representing 1998, in order to conserve electronic data storage and reduce operating costs. With this two-digit format, the year 2000 is indistinguishable from 1900, 2001 from 1901, and so on. As a result of this ambiguity, computer systems or application programs that use dates to perform calculations, comparisons, or sorting may generate incorrect results when working with years after 1999.

BLM has identified two legacy systems supporting its core business processes that are subject to the Year 2000 computer problem. These two mission-critical systems, the Case Recordation System and the Mining Claim Recordation System, are to be replaced with ALMRS IOC implementation. BLM presently uses these two systems to create and manage land and mineral case files. They capture and provide information on case type, customer, authorizations, and legal descriptions. Without these systems, BLM cannot create and record new cases, such as mining claims, or update case data. BLM’s initial assessment of the two mission-critical systems shows that the older computer mainframes on which these systems run are date-dependent and may malfunction in the year 2000.

These two systems are to be replaced by ALMRS before the year 2000. However, the delays in implementing ALMRS introduce the risk that BLM will be forced to continue using these two systems beyond 2000. To mitigate this risk, BLM is considering upgrading the mainframes on which these two systems run. However, BLM has not yet completed an assessment to determine what this upgrading would entail or developed a contingency plan for key business processes to be supported by these systems in the event that ALMRS is not fully deployed by the year 2000. The BLM Year 2000 Program Coordinator expects the assessment of this and the resulting contingency plan to be completed in the near future, although we were told that no deadline has been established for these actions.

Conclusions

BLM has not fully implemented the recommendations we made in our March 1997 report. It has not yet completed essential plans for system security, transition, operations and maintenance, and configuration management, exacerbating risks that ALMRS/Modernization will not be successfully implemented and meet operational needs. BLM understands the importance of these essential tools and has been working to develop them. However, until our prior recommendations have been implemented and necessary plans have been completed, approved, and put into place, BLM will not be ready to deploy the system. Continuing delays with the ALMRS/Modernization and the looming Year 2000 computer problem place BLM at risk that core business processes will not be supported beyond January 1, 2000.

Recommendation

To reduce the risk that BLM will lose information technology support for core business processes, we recommend that the Director of the Bureau of Land Management (1) direct that the two mission-critical systems ALMRS is to replace be fully assessed to determine what actions are needed to ensure the continued use of these systems after January 1, 2000, and (2) develop a contingency plan to take those actions in the event that ALMRS is not fully deployed by that time.

Agency Comments

In comments on a draft of this report, the BLM Director stated that he generally agrees with our observations and provided some updated information. BLM agreed with our recommendation to perform a full assessment of the two mission-critical systems to be replaced by ALMRS and develop a contingency plan to take the needed actions in the event that ALMRS is not fully deployed by the year 2000. BLM stated that it (1) has taken significant steps to implement the six recommendations in our March 1997 report and (2) will implement them before deploying the system. BLM also described some efforts that it believes are indicative of progress to date.

We are sending copies of this report to the Secretary of the Interior, the Director of the Bureau of Land Management, the Director of the Office of Management and Budget, and interested congressional committees. We will also make copies available to others upon request.

Should you or your staff have any questions concerning this report, please contact me at (202) 512-6253. I can also be reached by e-mail at willemssenj.aimd@gao.gov. Major contributors to this report are listed in appendix III.

Objectives, Scope, and Methodology

Our objectives were to assess BLM’s actions to address the recommendations contained in our March 1997 report and identify the status of BLM’s efforts to test, deploy, and implement ALMRS initial operating capability (IOC).

To review BLM’s actions to address our recommendations (develop a credible project schedule, configuration management plan, security architecture and security plan, complete transition plans, and complete operations and maintenance plans), we reviewed the ALMRS Project Office’s project management and scheduling procedures; BLM’s National Configuration Management Board’s draft configuration management plan; BLM information technology security plans, ALMRS application security plan, and other security documentation; BLM’s Operations and Maintenance plan for the National IRM Center; and BLM’s Version 2.0 Transition and Deployment Plan and site-specific transition/deployment plans for New Mexico, Idaho, Arizona, and Colorado. We compared revised project milestones with past milestones and remaining project risks. We also reviewed Carnegie Mellon University’s Capability Maturity Model for Software and site readiness review results.

To ascertain BLM’s efforts to test, deploy, and implement ALMRS IOC, we reviewed ALMRS/Modernization project documents, weekly activity reports and assessments by the independent verification and validation contractor, system integration meeting minutes, BLM’s exit criteria for system certification, software problem reports, and project management schedules. We also reviewed BLM’s submission to the Department of Interior’s Year 2000 Master Plan and status reports on BLM’s Year 2000 efforts. We attended the Department of the Interior’s October 1997 quarterly review of the development project at the ALMRS/Modernization project office in Lakewood, Colorado, and observed alpha IV testing at the ALMRS/Modernization pilot site offices in Santa Fe, Albuquerque, Farmington, and Taos, New Mexico and beta testing at the ALMRS/Modernization pilot site offices in Santa Fe, Albuquerque, and Taos, New Mexico. We also reviewed the results of alpha IV and beta testing.

We discussed the project with prime contractor officials; contractor officials responsible for independent verification and validation and operational assessment testing and evaluation; a senior technical analyst and the Acting Chief Information Officer at the Department of the Interior; BLM’s Assistant Director and Deputy Assistant Director for IRM, and BLM’s ALMRS budget analyst. We further discussed the essential management plans with ALMRS project officials responsible for project management and scheduling, configuration management, security, deployment, transition, and operations and maintenance planning; and discussed software development risks, performance problems, planned system capabilities, software problem reports, system testing, and technical complexity with project officials responsible for systems engineering, software development, and testing. We discussed BLM’s Year 2000 efforts with the Bureau’s Year 2000 Program Coordinator.

We performed our work at Interior’s information resources management headquarters in Washington, D.C.; BLM headquarters in Washington, D.C.; the ALMRS/Modernization project office in Lakewood, Colorado; the prime contractor’s office in Golden, Colorado; ALMRS pilot site offices in Santa Fe, Albuquerque, Farmington, and Taos, New Mexico; and the independent verification and validation contractor’s office in the ALMRS/Modernization project office in Lakewood, Colorado.

Comments From the Bureau of Land Management

The following are GAO’s comments on BLM’s April 13, 1998, letter.

GAO Comments

1. This information is summarized in the “Agency Comments” section of the report. 2. In discussing BLM’s comments, the Assistant Director for IRM told us that a primary reason for the increased estimated cost from $403 million to $594 million is that $105 million of technology refreshment costs were not included in the estimate provided to OMB. We revised the report to clarify this point. We also note that technology refreshment costs, as well as the other costs BLM mentioned, are properly a part of life-cycle costs and should have been included in the initially approved $403 million life-cycle estimate provided to OMB. 3. In BLM’s comments on the ALMRS project schedule, it stated that GAO staff has supported placing emphasis on completing a successful pilot as opposed to meeting an artificially derived schedule. We agree that emphasis should be placed on successfully completing all testing, including the pilot test. Testing is an essential part of developing and deploying an efficient and effective system.

We also agree that BLM should not try to meet artificially derived milestones. A complete, current, and accurate schedule with tasks linked to available resources is an essential tool to manage and control a large-scale project. This is the primary reason why we have addressed the project schedule in this report and in our two prior reports on ALMRS. The project schedule should have been based on tasks to be completed, resources associated with task completion, and a critical path with sufficient time allotted to deal with unanticipated problems. BLM has not done this. 4. BLM noted that the Configuration Management Plan and program were fully implemented about a month after we completed our fieldwork. As we note in the report, we did not assess the configuration management program during our review because the plan had not been completed and the program had not yet been fully implemented before the end of our fieldwork. 5. As we discuss in the report, the risk assessment performed at the New Mexico State Office focused on policies, procedures, and conditions at that office. The risk assessment did not deal with the security of, or assess the vulnerabilities of and risks to, ALMRS. In addition, until a full risk assessment of ALMRS is completed and documented, BLM has no basis for asserting that the system is secure or that the plan adequately addresses the vulnerabilities and risks attendant to a nationwide client-server system. 6. Our review of BLM’s updated transition plans showed that only one of the four plans identified and addressed transition issues. As we discuss in the report, the transition from automated capabilities provided by centrally managed mainframe legacy systems to the locally-managed client server environment of ALMRS will require changes in organizational roles, responsibilities, and interrelationships among the units and people using the system. A transition plan should address these issues and guide BLM in defining new operational procedures. Our concern is that with the complexity of ALMRS and the business process changes it will require, BLM needs to ensure that its transition plans provide the necessary guidance for successful transitions in its 210 state, district, and resource area offices. 7. Operations and maintenance plans are essential for operating and maintaining ALMRS on a daily basis. BLM noted that the states will update the operations and maintenance plans for their sites. In updating their plans, the state offices will need specific information that clearly describes how they are to fulfill their day-to-day responsibilities and how these responsibilities will be fulfilled when there are unexpected shortages of qualified staff. 8. We agree. Beta testing is testing of a prerelease version of software by selected cooperating users in order to uncover problems that were not discovered during laboratory testing. According to BLM, the beta test served that purpose. As we note in our report, these problems along with data conversion errors required correction before OAT&E could begin. Beta testing was conducted in November 1997 and OAT&E was scheduled to be completed in December 1997.

Major Contributors to This Report

Accounting and Information Management Division, Washington, D.C.

David G. Gill, Assistant Director Mirko J. Dolak, Technical Assistant Director Keith Rhodes, Technical Director Marcia C. Washington, Evaluator-in-Charge The first copy of each GAO report and testimony is free. Additional copies are $2 each. Orders should be sent to the following address, accompanied by a check or money order made out to the Superintendent of Documents, when necessary. VISA and MasterCard credit cards are accepted, also. Orders for 100 or more copies to be mailed to a single address are discounted 25 percent.

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