Aviation Safety: Issues Related to Domestic Certification and Foreign Approval of U.S. Aviation Products
Released: 2015-01-21T00:00:00

Letter

Background

FAA is the key federal agency responsible for certification of U.S. aviation products to be used in the United States and has a significant role in supporting approvals of U.S. products in other countries. Located in FAA’s Office of Aviation Safety (Aviation Safety), the Aircraft Certification Service (Aircraft Certification) issues certificates, including type certificates and supplemental type certificates, for new aviation products to be used in the national airspace system. Certification projects, which involve the activities to determine compliance of a new product with applicable regulatory standards and to approve products for certificates, are typically managed by one of Aircraft Certification’s local offices (generally known as aircraft certification offices, or ACOs).illustrates the range of U.S.-manufactured aviation products—including aircraft, helicopters, propellers, and engines—for which Aircraft Certification issues type certificates and supplemental type certificates once all requirements are met.

FAA Has Made Progress in Addressing the Certification Process and Regulatory Consistency Committees’ Recommendations

FAA Reports that Most of the Initiatives to Improve Its Aircraft Certification Processes Have Been Implemented, but It Is Too Early to Assess Whether Expected Outcomes Will Be Achieved

Aircraft Certification is implementing and has set milestones for completing 14 initiatives in response to May 2012 recommendations of the Certification Process Committee. This Committee was chartered to make recommendations to Aircraft Certification to streamline and reengineer its certification process, improve efficiency and effectiveness within Aircraft Certification, and redirect resources for support of certification. Several of the initiatives were originally begun as part of earlier certification process improvement efforts. The initiatives range from developing a comprehensive road map for major change initiatives, to reorganizing the small aircraft certification regulations. Although we reported in 2013 that the Certification Process Committee’s recommendations were relevant, clear, and actionable, it is too soon for us to determine whether FAA’s 14 initiatives adequately address the recommendations.

According to an update prepared by FAA in January 2015, eight initiatives have been completed, and two are on track to be completed within 3 years. However, according to this update, one initiative was at risk of not meeting planned milestones, and three initiatives will not meet planned milestones, including the update to 14 C.F.R. Part 21—the regulations under which aircraft products and parts are certificated. We reported in July 2014 that this initiative was in danger of not meeting planned milestones because the October 2013 government shutdown delayed some actions FAA had planned to move it into the rulemaking process.In its January 2015 update, FAA indicated that the formal rulemaking project timeline has been delayed to late fiscal year 2015 to allow for additional work with industry on developing guidance material and new certificate holder requirements. Figure 4 illustrates the evolving status of the 14 initiatives based on the publically-available periodic updates reported by FAA.

We found in October 2013 that Aircraft Certification lacked performance measures for many of these initiatives. As of July 2014, FAA had developed metrics for measuring the progress of the implementation of 13 of the 14 initiatives. According to FAA officials, they plan to develop these metrics in three phases. For the first phase, which was documented in the July 2014 update of its implementation plan, FAA developed metrics to measure the progress of the implementation of the initiatives. For the second phase, FAA plans to develop metrics for measuring the outcomes of each initiative. For the third phase, working with the Aerospace Industries Association and General Aviation Manufacturers Association, FAA plans to develop metrics for measuring the global return on investment in implementing all of the initiatives, to the extent that such measurement is possible. FAA did not provide us a time frame for developing the second and third phase metrics. While we continue to believe that this plan for establishing performance measures is reasonable, and recognizing that FAA is in the early stages of implementation, it is critical for FAA to follow through with its plans for developing and utilizing metrics to evaluate improvements to the certification process. Without these metrics, FAA will be unable to fully determine whether its efforts have been successful in addressing the Certification Process Committee’s recommendations as intended, identify areas that may need more attention, and modify efforts to sufficiently address any gaps. In our previous work, we have reported on instances where the implementation and metrics related to FAA efforts have not achieved the intended outcomes as expected, e.g., modernizing the air traffic control system under the Next Generation Air Transportation System (NextGen) and the integration of unmanned aerial systems into the national airspace system.

FAA Has Developed Plans to Address Recommendations to Improve the Consistency of Its Regulatory Interpretations, but Progress Has Been Slow

Flight Standards has also developed initiatives in response to the six November 2012 recommendations of the Regulatory Consistency Committee, but the planned initiatives have not yet been released officially. This Committee was chartered to make recommendations to FAA to improve (1) the consistency in how regulations are applied in making certification decisions and (2) communications between FAA and industry stakeholders regarding such decisions. In late December 2014, FAA indicated that the draft plan to implement these recommendations was currently under review within FAA but the final plan is expected to be published by the end of January 2015, more than a year past the initial target publication date of December 2013. However, according to an October 2014 draft version of the plan that FAA provided to us, despite not having yet officially released the plan, FAA noted that it had closed 2 of the 6 recommendations and plans to complete the remaining four by July 1, 2016. FAA also noted that it had developed performance measures to measure the progress of the implementation of the remaining 4 recommendations. Table 1 provides a summary of the recommendations and FAA’s plans for addressing them, based on the October 2014 draft plan that FAA provided to us.

We reported in 2013 that the Regulatory Consistency Committee took a reasonable approach in identifying the root causes of inconsistent interpretation of regulations, and its recommendations are relevant to the root causes, actionable, and clear.determine whether FAA’s planned actions adequately address the recommendations. In addition, FAA’s draft plan stated that the resources required to implement the recommendations must be balanced with other important FAA activities, such as agency priorities and existing rulemaking initiatives, and that if future priorities change, it may be forced However, it is too soon for us to to modify elements of this implementation plan. As we reported in July 2014, it will be critically important for FAA to follow through with its initiatives aimed at improving the consistency of its regulatory interpretation as well as its plans for developing performance metrics to track the achievement of intended consistencies. We have previously reported that large-scale change management initiatives—like those recommended by the regulatory consistency committee—require the concentrated efforts of both leadership and employees to realize intended synergies and accomplish new organizational goals.

Further, industry representatives have continued to indicate a lack of communication with and involvement of stakeholders as a primary challenge for FAA in implementing the committees’ recommendations, particularly the regulatory consistency recommendations. FAA has noted that the processes for developing and updating its plans for addressing the certification process and regulatory consistency recommendations have been transparent and collaborative, and that FAA meets regularly with industry representatives to continuously update them on the status of the initiatives and for seeking their input. However, several industry —that representatives recently told us—and we reported in July 2014 FAA has not effectively collaborated with or sought input from industry stakeholders in the agency’s efforts to address the two sets of recommendations, especially the regulatory consistency recommendations. For instance, some stakeholders reported that FAA does not provide an opportunity for them to review and comment on the certification process implementation plan updates, and did not provide an opportunity for them to review and offer input on the regulatory consistency implementation plan. However, FAA did meet with various industry stakeholders in October 2014 to brief them on the general direction and high-level concepts of FAA’s planned actions to address each regulatory consistency recommendation.

GAO-14-728T.

Selected U.S. Companies Report Challenges in Obtaining Foreign Approvals, Which FAA Is Taking Steps to Address within Sovereignty Constraints

U.S. Companies Reported that they Experienced FCAA-Related Process, Communications, and Cost Challenges and FAA is Attempting to Address These Challenges

Representatives of the selected 15 U.S. aviation companies we interviewed, as part of our ongoing work on foreign approvals, reported that their companies faced challenges related to process, communications, and cost in obtaining approvals from FCAAs. The processes involved included FCAAs’ individual approval processes as well as the processes spelled out in the relevant BASAs. FAA is making some efforts to address these challenges, such as by holding regular meetings with some bilateral partners and setting up forums in anticipation of issues arising.

According to FAA data, from January 2012 through November 2014, U.S. companies submitted approximately 1,500 applications for foreign approvals to a total of 37 FCAAs. applications submitted to the top ten and other markets for foreign approvals from January 2012 through November 2014.

The total includes Hong Kong, which is counted separately from China.

Others include the following bilateral partners, in descending order of the number of applications submitted: South Korea, South Africa, Taiwan, New Zealand, Malaysia, Israel, and Singapore.

The percentages are based on an approximation of the total number of submitted applications by U.S. aviation companies. According to FAA, the number of applications may be undercounted because there is no formal requirement for U.S. aviation companies to submit applications to FAA for foreign approvals unless the country is a FAA bilateral partner. Thus, some applications may not have been entered into FAA’s tracking system.

Reported FCAA Process Challenges

Of the 15 companies we interviewed, representatives from 12 companies reported mixed or varied experiences with FCAAs’ approval processes, and 3 reported positive experiences. Thirteen companies reported challenges related to delays, 10 reported challenges with approval process length, and 6 reported challenges related to FCAA staffs’ lack of knowledge or uncertainty about the approval processes, including FCAA requests for data and information that, in the companies’ views, were not needed for approvals. Representatives of three companies stated that, in their opinion, the EU’s process is sometimes lengthy and burdensome, resulting in delays. Representatives of four companies noted examples of approval projects that, in their opinions, were expected to be granted within weeks or hours by FCAAs, in general, but instead took months or years. As an example, there were several media reports on the EU’s 4- year process for the approval of the Robinson R66 helicopter, which was reportedly awarded by EASA in May 2014. However, because we were not provided the relevant factors and circumstances that could have affected the delays in the specific examples provided, we did not assess whether the approvals took longer than necessary. Eight companies also noted that China often makes requests for data and detailed product design information that in their view is not necessary for an approval, and sometimes holds up approvals until those requests are fulfilled.

The 737 MAX is Boeing’s newest family of single-aisle airplanes. It can accommodate up to 200 seats, and the first flight is scheduled in 2016 with deliveries to customers beginning in 2017. approvals, and is expected to be completed in fiscal year 2015.According to FAA officials, this IPA is also expected to reduce the level of involvement of the Civil Aviation Administration of China (CAAC) in conducting approvals and prevent its certification staff from doing extensive research for each approval project.

Reported Issues Related to Some BASAs

Although representatives from 11 of the 15 U.S. companies and the 3 foreign companies we interviewed reported being satisfied with the overall effectiveness of having BASAs in place or with various aspects of the current BASAs, representatives of 10 U.S. companies reported challenges related to some BASAs lacking specificity and flexibility, 2 raised concerns that there is a lack of a formal dispute resolution process, and 1 noted a lack of a distinction between approvals of simple and complex aircraft. Companies suggested several ways to address these issues, including updating BASAs more often and making them clearer.

FAA has taken action to improve some BASAs to better streamline the approval process that those countries apply to imported U.S. aviation products. For instance, according to FAA officials, they meet regularly with bilateral partners to address approval process issues and are working with these partners on developing a common set of approval principles. FAA also noted that there are basic dispute resolution clauses in most of the IPAs, and FAA is working toward adding specific dispute resolution procedures as contained in the agreement with the EU. FAA aims to complete negotiations to add a dispute resolution clause to the BASA with China in fiscal year 2015. FAA officials also indicated that they are working with longstanding bilateral partners—such as Brazil, Canada, and the EU—to identify areas where mutual acceptance of approvals is possible.

Reported Challenges in Communicating with FCAAs

Representatives from twelve U.S. companies reported challenges in communicating with FCAAs. Representatives from six U.S. companies reported, for example, that interactions with developing countries can be confusing and difficult because of language and cultural issues. Representatives from two companies noted that they hire local representatives as consultants in China to help them better engage CAAC staff with their approval projects and to navigate the CAAC’s process. One company’s representative also reported having better progress in communications with FCAAs in some Asian countries, such as India Japan, and Vietnam, when a local “third-party agent” (consultant) is involved because it provides a better relationship with the FCAAs’ staff. They added this requires a lot of trust that the local agent will support the best interests of the company, and, at times, this arrangement becomes difficult because the company’s experts would prefer to be in charge of the communications with FCAAs during the approval processes. Representatives from three companies also reported that, in general, some FCAAs often do not respond to approval requests or have no back- ups for staff who are unavailable. They noted that potential mitigations could include a greater FAA effort to develop and nurture relationships with FCAAs. According to FAA officials, they are working with the U.S.- China Aviation Cooperation Program to further engage with industry and Chinese officials.

Reported Challenges Related to Foreign Approval Costs

Representatives from twelve of the 15 U.S. companies and 2 of the 3 foreign companies indicated challenges with regard to approval fees charged by FCAAs. They specifically cited EASA and the Federal Aviation Authority of Russia (FAAR). For example, they noted that EASA’s fees are significantly high (up to 95 percent of the cost of a domestic EASA certification)—especially relative to the amount levied by other FCAAs—are levied annually, and are unpredictable because of the unknown amount of time it takes for the approval to be granted. The fees are based on the type of product being reviewed for approval and can range from a few thousand dollars to more than a million dollars annually. Representatives from two companies also noted that EASA lacks transparency for how the work it conducts to grant approvals aligns with the fees it levies for recovering its costs. FAA officials indicated to us that a foreign approval should take significantly less time and work to conduct than the work required for an original certification effort—roughly about 20 percent—and that they have initiated discussions with EASA officials about making a significant reduction in the fees charged to U.S. companies.

Representatives of two companies also indicated that some FCAAs (e.g., China and Indonesia) routinely conduct site visits to the United States to, for example, review data and conduct test flights. According to the companies we interviewed, these visits are paid for by the U.S. companies seeking the approvals and the cost of these visits are unpredictable because the logistics and duration are determined by the FCAA. For example, representatives from one company told us that one FCAA typically conducts 2-week visits, but they only need one and a half days to provide information. Four companies’ representatives told us that they sometimes (1) offer to send their staff to the FCAA or another location because they can often do so less expensively or (2) schedule these site visits to better coincide with a more favorable budget environment for the company.

U.S. Companies Also Reported FAA-Related Challenges Which FAA Is Taking Actions to Address

Reported Challenges Related to FAA

As mentioned previously, FAA provides assistance to U.S. companies by facilitating the application process for foreign approvals of aviation products. U.S. companies seeking to export their aviation products to countries with BASAs in place submit application packages for foreign approvals to an appropriate ACO. ACO staff facilitates this process by reviewing the application package for completeness and to ensure that all country-specific requirements are met; and then forwarding the package along with an FAA cover letter to the applicable FCAA for review and approval. According to FAA officials, after the FCAA has reviewed the package, sometimes the authority will submit “certification review items”— which document issues related to the original certification of a product that requires an interpretation on how compliance was met or additional clarifications, or represents a major technical or administrative problem— to the responsible ACO for review and response. The assigned ACO staff reviews these items, determines whether a response is required from the applicant company, and coordinates the response to the FCAA. In some cases, ACO staff prepares issue papers which outline, among other things, the certification basis upon which the original type certification was issued. Also, according to FAA officials, FAA staff supports general and technical meetings between applicant companies and FCAAs for foreign approvals.

According to FAA officials, the agency strives to make its process in place to support foreign approvals of aviation products as efficient as possible. In an effort to measure progress toward this goal, FAA has centrally tracked since January 2012 data on foreign approvals, including: the total number of foreign approval applications received and processed, the dates that applications are received by FAA, the dates packages are sent by FAA to the FCAA, and the date when the FCAA ultimately approves or finalizes the application. This data can be broken down by export country, applicant company and product type. As will be discussed later, however, FAA’s data on foreign approvals has some limitations. According to FAA staff in two ACOs, each field office is responsible for setting its own time goals related to processing foreign approvals. Officials in three field offices told us that their goal is for each foreign approval package to be forwarded to the FCAA within 30 days of receipt by FAA. FAA also collects other information about foreign approvals in an effort to assess its bilateral relationships and the overall effectiveness of its process. For example, for some foreign approval projects, FAA field staff must complete a Bilateral Relationship Management (BRM) form to provide feedback on the interaction with a FCAA, which is submitted to FAA headquarters. As we will further discuss later, however, FAA officials acknowledged some issues with the BRM process which they plan to address.

Although FAA seeks to provide an efficient process, companies we interviewed reported challenges that they faced related to FAA’s role in the foreign approval process. FAA-related challenges cited by the companies we interviewed fell into three main categories:

Process for facilitating foreign approvals. Most of the U.S. companies in our selection (12 out of 15) reported challenges related to FAA’s process for handling foreign approvals. These included concerns about foreign approvals not being a high enough priority for FAA staff, a lack of performance measures for evaluating BASAs, and an insufficient use of FAA’s potential feedback mechanisms. For example, representatives of three companies told us that sometimes FAA is delayed in submitting application packets to FCAAs because other work takes priority; one of these companies indicated that sometimes FAA takes several months to submit packets to FCAAs. In another example, representatives of four companies cited concerns that BASAs do not include any performance measures, such as any expectations for the amount of time that it will take for a company’s foreign approval to be finalized. With regard to FAA using feedback mechanisms to improve its process for supporting foreign approvals, representatives of one company told us that applicant companies are not currently asked for post-approval feedback by FAA even though it would be helpful in identifying common issues occurring with foreign approvals.

Available resources. Most of the U.S. companies in our selection (10 out of 15) reported challenges related to the availability of FAA staff and other resources. These include limited FAA travel funds and limited FAA staff availability to process foreign approval applications. According to FAA officials, FAA is responsible for defending the original type certification and, more broadly, for handling any disputes that arise with FCAAs during the foreign approval process. In doing so, FAA is also responsible for working with a FCAA in an authority- to-authority capacity, and communications should flow through FAA to the applicant company. However, representatives of five companies noted that due to a lack of FAA travel funds, FAA staff is generally not able to attend key meetings between U.S. companies and FCAAs conducted at the beginning of the foreign approval process. These representatives noted that this can complicate the process for companies, which then have to take on a larger role in defending the original type certificate issued for a product. Representatives of two companies also noted that when there is limited FAA staff availability at the time a foreign approval application is received that it contributes to delays in obtaining their approvals. Industry stakeholders have continued to suggest that FAA should more thoroughly utilize its delegation authority in several areas to better utilize available FAA resources. In fact, the Certification Process Committee made recommendations to encourage FAA to include the expansion of delegation in its efforts for improving the efficiency of its certification process. FAA’s initiatives related to expanding the use of delegation appear to be moving in the right direction, but FAA’s efforts have been slower than industry would like and has expected.

Staff expertise. Some of the U.S. companies in our selection (7 out of 15) reported issues related to FAA staff expertise. These cited issues included limited experience on the part of FAA staff in dispute resolution as well as limited expertise related to intellectual property and export control laws. For example, representatives of three companies told us that FAA staff sometimes lack technical knowledge due to having little to no experience with some aviation products, while a representative of another company argued that increased training for FAA staff in dispute resolution could be very helpful, especially for disputes involving different cultural norms. In another example, representatives of two companies described situations in which FAA staff was ready to share information with a FCAA that the applicant company considered proprietary until the company objected and other solutions were found.

FAA Initiatives to Address Challenges

FAA has initiatives under way aimed at improving its process for supporting foreign approvals that may help address some of the challenges raised by the U.S. companies in our review. Specifically, FAA’s current efforts to increase the efficiency of its foreign approval process could help address reported challenges related to FAA’s process and its limited staff and financial resources. For example, FAA is planning to address its resource limitations by focusing on improving the efficiency of its process with such actions as increasing international activities to support U.S. interests in global aviation, and by implementing its 2018 strategic plan, which includes the possibility of allocating more resources to strengthening international relationships.

FAA has also initiated efforts to improve the robustness of its data on foreign approvals, to in turn further improve the efficiency of its process for supporting these approvals. With more complete data, FAA aims to track performance metrics such as average timeframes for foreign approvals and to better evaluate FAA’s relationships with bilateral partners. As previously mentioned, in 2012, FAA started tracking data on foreign approval packages received and processed. In addition, according to FAA officials, FAA currently tracks the time needed from initial receipt of a foreign approval application by an ACO to the date the application is forwarded to the FCAA. However, currently, there is no formal written requirement for FAA field staff to enter foreign approval application information into the central tracking system, so not all applications are captured. FAA officials told us in December 2014 that the agency is developing formal requirements for field staff to enter data into this system, in order to ensure the integrity of data within its control, but they did not provide an expected time frame for completion. According to FAA staff in one field office, Aircraft Certification’s International Policy Office— which manages the central data system—recently updated this system with additional data fields to capture more data on the number of foreign approval projects in process and data for tracking performance metrics.

As previously mentioned, FAA collects Bilateral Relationship Management (BRM) forms as a method for field staff to relay information on specific foreign approval projects—both positive and negative experiences—to headquarters. Based on discussions with us regarding policies related to BRM submissions, FAA officials told us that they plan to clarify BRM submission criteria and response policies for field and headquarters staff to enhance information gathered through this process.

According to FAA, collecting, sharing, and taking appropriate action on information in BRM forms is necessary for FAA to recognize and resolve issues. Initially, FAA officials indicated that field staff is required to submit BRM forms whenever an employee meets with an official from a FCAA or foreign company, but that other issues can trigger the submission of BRM forms, such as when the FCAA is not adhering to the BASA, or is not actively engaged in certification activities. FAA officials also said that designated headquarters officials are required to respond to all BRM forms received within 48 hours.

However, FAA officials at four ACOs we interviewed told us that field staff does not consistently submit BRM forms, and that when staff does submit BRM forms, field staff generally does not receive feedback from FAA headquarters about the information received in the form. For example, one ACO official indicated that his office’s staff is only likely to submit the BRM form when there is a significant issue regarding an ongoing foreign approval package, and not to report any positive outcomes or circumstances. Further, the official said that the Aircraft Certification’s International Policy Office does not provide feedback on issues raised in these forms. Two officials from a different ACO indicated that the submission of BRM forms varies greatly by project manager, with some managers submitting these routinely whereas others do not submit them at all; these officials also indicated that their staff do not typically receive feedback from headquarters on submitted forms. After hearing about these concerns about the BRM process raised by field staff, FAA headquarters officials indicated that they plan to clarify to field staff when BRM forms should be submitted and also clarify to designated headquarters staff that each BRM form requires feedback to the submitting field staff, but they did not provide an expected time frame for completion. These planned efforts should help improve the robustness and completeness of data shared in BRM forms.

Some current FAA efforts to collect additional data on foreign approvals are aimed at improving FAA’s ability to evaluate its relationships with its bilateral partners; such efforts could help to address domestic challenges raised by companies about FAA not having performance metrics to assess how well BASAs are working. For example, according to FAA officials, in November 2013, Aircraft Certification formally expanded its process for evaluating international partners to include risk-based evaluation methods. Officials noted that this evaluation process includes gathering quantitative and qualitative information about the effectiveness of bilateral partnerships. Officials explained that FAA uses a structured process to evaluate and to establish a risk factor for each foreign bilateral partner, based on information in the BRM forms, the number of foreign approval projects the respective authority has within FAA’s system, and the authority’s most recent ICAO airworthiness score, among other factors. FAA officials said that this evaluation system will continue to expand as FAA identifies new data sources.

In conclusion, to its credit, FAA has made some progress in addressing the Certification Process and Regulatory Consistency Committees’ recommendations, as well as in taking steps to address challenges faced by U.S. aviation companies in obtaining foreign approvals of their products. It will be critically important for FAA to follow through with its current and planned initiatives to increase the efficiency and consistency of its certification processes, and its efforts to address identified challenges faced by U.S. companies in obtaining foreign approvals. Given the importance of U.S. aviation exports to the overall U.S. economy, forecasts for continued growth of aviation exports, and the expected increase in FAA’s workload over the next decade, it is essential that FAA undertake these initiatives to ensure it can meet industry’s future needs. To demonstrate that it is making progress on these important initiatives, it is also important that FAA continue to develop and refine its outcome- based performance measures to determine what is actually being achieved through the current and future initiatives, and also through improvements to its data tracking for monitoring the effectiveness of its bilateral agreements and partnerships. Such outcome-based metrics will make it easier for FAA to determine the overall outcomes of its actions and relationships, hold field and headquarters staff accountable for the results, and demonstrate to industry stakeholders, congressional stakeholders, and others that progress is being made.

Going forward, we will continue to monitor FAA’s progress, highlight the key challenges that remain, and the steps FAA and industry can take to find a way forward on the issues covered in this statement as well as other issues facing the industry. As we noted in our October 2013 statement, however, some improvements to the certification processes will likely take years to implement and, therefore, will require a sustained We are hopeful that our commitment as well as congressional oversight.findings related to previous and ongoing work in these areas will continue to assist this Committee and its Subcommittee on Aviation as they develop the framework for the next FAA reauthorization act.

Chairman Shuster, Ranking Member DeFazio, and Members of the Committee, this completes my prepared statement. I would be pleased to respond to questions at this time.

GAO Contact and Staff Acknowledgements

For further information on this testimony, please contact Gerald L. Dillingham, Ph.D., at (202) 512-2834 or dillinghamg@gao.gov. In addition, contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement.

Individuals making key contributions to this testimony statement include Vashun Cole, Assistant Director; Jessica Bryant-Bertail, Jim Geibel, Josh Ormond, Amy Rosewarne, and Pamela Vines. Other contributors included Kim Gianopoulos, Director; Dave Hooper; Stuart Kaufman, and Sara Ann Moessbauer.

This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.