The national park system has 376 units. These units have, among other things, over 16,000 permanent structures, 8,000 miles of roads, 1,500 bridges and tunnels, 5,000 housing units, about 1,500 water and waste systems, 200 radio systems, and over 400 dams. According to the Park Service, these facilities are valued at over $35 billion. The proper care and maintenance of the national parks and their supporting infrastructure are essential to the continued use and enjoyment of our great national treasures by this and future generations. However, for years Park Service officials have highlighted the agency’s inability to keep up with its maintenance needs. In this connection, Park Service officials and others have often cited a continuing buildup of unmet maintenance needs as evidence of deteriorating conditions throughout the national park system. The accumulation of these unmet needs has become commonly referred to by the Park Service as its “maintenance backlog.” The reported maintenance backlog has increased significantly over the past 10 years—from $1.9 billion in 1987 to about $6.1 billion in 1997. Recently, concerns about the maintenance backlog within the National Park Service, as well as other federal land management agencies, have led the Congress to provide significant new sources of funding. These additional sources of funding are, in part, aimed at helping the agencies address their maintenance problems. For example, it is anticipated that new revenues from the 3-year recreational fee demonstration program will provide the Park Service over $100 million annually. In some cases, the new revenues will as much as double the amount of money available for operating individual park units. In addition, $10 million from a special one-time appropriation from the Land and Water Conservation Fund has been made available for use by the Park Service in fiscal year 1998 to address the maintenance backlog. These new revenue sources are in addition to the $300 million in annual operating appropriations that are used for maintenance activities within the agency. In 1997, the Park Service estimated that its maintenance backlog was about $6.1 billion. Maintenance is generally considered to be work done to keep assets—property, plant, and equipment—in acceptable condition. Maintenance includes normal repairs and the replacement of parts and structural components needed to preserve assets. However, the composition of the maintenance backlog estimate provided by the Park Service includes activities that go beyond what could be considered maintenance. Specifically, the Park Service’s estimate of its maintenance backlog includes not only repair and rehabilitation projects for existing facilities but also projects for the construction of new facilities or upgrades of present facilities. Of the estimated $6.1 billion maintenance backlog, most of it—about $5.6 billion, or about 92 percent—is for construction projects. These projects, such as building roads and utility systems, are relatively large, normally exceed $500,000 each, and involve multiyear planning and construction activities. According to the Park Service, the projects are intended to meet the following objectives: (1) repair and rehabilitation; (2) resource protection, involving such things as constructing or rehabilitating historic structures and trails and erosion protection activities; (3) health and safety, involving such things as upgrading water and sewer systems; (4) new facilities in older existing parks; and (5) new facilities in new and developing parks. Table 1 shows the dollar amounts and percentage of funds pertaining to each of the objectives. The Park Service’s list of projects in the construction portion of the maintenance backlog reveals that over 21 percent, or $1.2 billion, of the $5.6 billion is for new facilities. We visited four parks to review the projects listed in the Park Service’s maintenance backlog and found that the estimates included new construction projects as part of the backlog estimate. For example: Acadia National Park’s estimate included $16.6 million to replace a visitor center and construct a park entrance. Colonial National Historical Park’s estimate included $24 million to build a bicycle and walking trail along the Colonial Parkway. Delaware Water Gap National Recreation Area’s estimate included $19.2 million to build a visitor center and rehabilitate facilities. Rocky Mountain National Park’s estimate included $2.4 million to upgrade entrance facilities. While we do not question the need for any of these facilities, the projects are directed at adding new facilities or modifying and improving existing facilities to meet the objectives that park managers wish to achieve for their parks. These projects are not aimed at addressing the maintenance of existing facilities within the parks. For example, Colonial National Historical Park proposed to construct a new bicycle and walking trail on the 23-mile route along the Colonial Parkway between Jamestown and Yorktown, Virginia. The reason for the trail is to enhance bikers’, joggers’, and walkers’ experience in the park and to increase safety for motorists and nonmotorists. The proposed project to upgrade facilities at Rocky Mountain National Park consists of constructing four new employee housing units and a 5,000-square-foot visitor center to provide information on park facilities and resources. According to the park’s records, half of the 2.8 million visitors to the park enter via Fall River, an entrance road with no established information station or visitor center until visitors reach Fall River Pass, a distance of 21 miles. Including these types of enhancement projects in the maintenance backlog contributes to confusion about the actual maintenance needs of the national park system. While a portion of the projects listed as part of the Park Service’s maintenance backlog are not maintenance items, it is clear from documentation and physical evidence that we noted at the parks that we visited that the Park Service does have a host of maintenance needs. For example, Acadia National Park proposed to spend over $2 million to rehabilitate historic bridges along the carriage road system that have been saturated by water and exhibit cracks, open joints, and waterborne deposits. Also, Rocky Mountain National Park proposed to spend $14.5 million to rehabilitate and replace park roads. On one road, we observed that the road bank was eroding and in need of rocks to rebuild the eroded area. (See fig. 1.) In addition to projects clearly listed as new construction, other projects on the $5.6 billion list that are not identified as new construction, such as the repair and rehabilitation of existing facilities, include amounts for new construction. Our review of the project proposals for the four parks that we visited showed that each of the proposals included large repair and rehabilitation projects containing tasks that would not be considered maintenance. These projects include new construction for adding, expanding, and upgrading facilities. For example, at Colonial National Historical Park, an $18 million project to protect Jamestown Island and other locations from erosion included about $4.7 million primarily for the construction of new items such as buildings, boardwalks, wayside exhibits, and an audio exhibit. Beyond construction items, the remaining part of the $6.1 billion backlog estimate—about 8 percent, or about $500 million—is for smaller maintenance projects, such as rehabilitating campgrounds and trails and repairing bridges, and other items that recur on a cyclic basis, for example reroofing or repainting buildings. The Park Service excluded daily, routine park-based operational maintenance, such as janitorial and custodial services, groundskeeping, and minor repairs, from the maintenance backlog figures. The Park Service has a maintenance management system that park managers can use to plan and manage these routine activities. However, recent Department of the Interior Inspector General report notes that this system is not uniformly used by park managers. The Park Service compiles its maintenance backlog estimates on an ad hoc basis in response to requests from the Congress or others; it does not have a routine, systematic process for determining its maintenance backlog. The January 1997 estimate of the maintenance backlog—the most recent estimate—was based largely on information that was compiled over 4 years ago. This fact, as well as the absence of a common definition of what should be included in the maintenance backlog, contributed to an inaccurate and out-of-date estimate. The $6.1 billion estimate, dated January 1997, was for the most part, compiled on the basis of information received from the individual parks in December 1993. A Park Service official said that the 1993 data were updated by headquarters to reflect projects that had been subsequently funded during the intervening years. However, we found that the Service’s most recent maintenance backlog estimate for each of the parks we visited was neither accurate nor current. The four parks’ estimates of their maintenance needs ranged from about $40 million at Rocky Mountain National Park to $120 million at Delaware Water Gap National Recreation Area. Our analysis of these estimates showed that they varied from the headquarters estimates by about $3 million and $21 million, respectively. The differences occurred because the estimates from headquarters were based primarily on 4-year-old data. Officials from the four parks told us that they had not been asked to provide specific updated data to develop the 1997 estimate. The parks’ estimates, which were based on current information, included such things as recent projects, modified scopes, and more up-to-date cost estimates. For example, Acadia’s estimate to replace the visitor center and construct a park entrance has been reduced from $16.6 million to $11.6 million; the Delaware Water Gap’s estimate of $19.2 million to build a visitor center and rehabilitate facilities has been reduced to $8 million; and Rocky Mountain’s $2.4 million project to upgrade an entrance facility is no longer a funding need because it is being paid for through private means. In addition, one of the projects on the headquarters list has been completed. The Park Service has no common definition as to what items should be included in an estimate of the maintenance backlog. As a result, the Park Service oficials that we spoke with in headquarters, two regional offices, and four parks had different interpretations of what should be included in the backlog. In determining the maintenance backlog estimate, some of these officials would exclude new construction; some would include routine, park-based maintenance; and some would include natural and cultural resource management and land acquisition activities. In addition, when headquarters developed the maintenance backlog estimate, it included both new construction and maintenance items. For example, nonmaintenance items, such as adding a bike path to a park where none now exists or building a new visitor center, are included. The net result is that the estimate is not a reliable measure of the maintenance needs of the national park system. In order to begin addressing its maintenance backlog, the Park Service needs (1) an accurate estimate of its total maintenance backlog and (2) a means for tracking progress so that it can determine the extent to which its needs are being met. Currently, the agency has neither of these things. Yet the need for an accurate estimate and a tracking system is more important now than ever before because in fiscal year 1998, over $100 million in additional funding is being made available for the Park Service, which it could use to address its maintenance needs. This additional funding comes from the recreational fee demonstration program and the Land and Water Conservation Fund. Furthermore, the Park Service requested an increase in funding for maintenance activities in fiscal year 1999. Park Service officials told us that they have not developed a precise estimate of the total maintenance backlog because the needs far exceed the funding resources available to address them. In their view, the limited funds available to address the agency’s maintenance backlog dictate that managers focus their attention on identifying only the highest-priority projects on a year-to-year basis. Because the agency does not focus on the total needs but only on priorities for a particular year, it cannot determine whether the maintenance conditions of park facilities are improving or worsening. Furthermore, without information on the total maintenance backlog, it is difficult to measure what progress is being made with available resources. The recent actions by the Congress to provide the Park Service with substantial additional funding, which could be used to address its maintenance backlog, underscore the need to ensure that available funds are being used to address priority needs and to show progress in improving the conditions of the national park system. The Park Service estimates that the recreational fee demonstration program could provide over $100 million a year to address the parks’ maintenance and other operational needs. For some parks, revenues from new and increased fees will as much as double the amount of money that has been previously available for operating individual park units. In addition to the fee demonstration program, the Park Service was allocated $10 million from the Land and Water Conservation Fund appropriations in fiscal year 1998 to help address the maintenance needs of the national park system. Furthermore, additional funds may be available for maintenance if the Congress appropriates the additional $62 million that the Park Service requested for maintenance activities in its fiscal year 1999 budget request. Several new requirements that have been imposed on the Park Service, and other federal agencies, can help the agency to address its maintenance backlog. These new requirements involve (1) changes in federal accounting standards, (2) the Government Performance and Results Act (the Results Act), (3) determining the need for some Park Service employee housing, and (4) a review of the Park Service’s construction practices. In addition, the Department of the Interior and the Park Service are currently taking a number of steps to better manage the maintenance and construction program, including developing a 5-year plan for prioritizing maintenance and construction projects to be funded and evaluating alternative methods for maintaining historic structures. These requirements and actions should, if implemented properly, help the agency to better manage its maintenance backlog. Recent changes in federal accounting standards require federal agencies, including the Park Service, to develop better data on their maintenance needs. The standards define deferred maintenance and require that it be disclosed in agencies’ financial statements beginning with fiscal year 1998. To implement these standards, the Park Service is part of a facilities maintenance study team established within Interior to provide the agency with information on deferred maintenance as well as guidance on standard definitions and methodologies for improving the ongoing accumulation of this information. In addition, as part of this initiative, the Park Service is doing an assessment of its assets to show whether they are in poor, fair, or good condition. This information is essential and will provide the Park Service with better data on its overall maintenance needs and help the Park Service prioritize its maintenance expenditures. Furthermore, it is important to point out that as part of the agency’s financial statements, the Park Service’s estimates of deferred maintenance will be subject to annual audits. As a result, Interior is reporting information on deferred maintenance in its fiscal year 1997 financial statements. This audit scrutiny is particularly important given the long-standing concerns reported by us and others about the validity of the Park Service’s maintenance backlog estimates. The Results Act should also help the Park Service to better address its maintenance backlog. In carrying out the Results Act, the Park Service requires its park managers to measure progress in meeting a number of key goals, including whether and to what degree the condition of park facilities is being improved. In accordance with the Results Act, in February 1998, the Park Service has developed an annual performance plan for fiscal year 1999 that includes a number of goals to address the maintenance and construction backlog. For example, by September 30, 1999, 10 percent of employee housing units, classified as being in poor or fair condition in 1997, will be removed, replaced, or upgraded to good condition. If properly implemented, the Results Act should make the Park Service as a whole, as well as individual park managers, more accountable for how it spends maintenance funds to improve the condition of park facilities. Once in place, this process should permit the Park Service to better demonstrate what is being accomplished with its funding resources. This is an important step in the right direction, since our past work has shown that the Park Service could not hold park managers accountable for their spending decisions because they did not have a good system for tracking progress and measuring results in terms of how money was being spent at the park level. The other two requirements stem from congressional concerns regarding the number of employee housing units that the Park Service maintains as well as the extremely high costs to construct some new facilities. In September 1993 and August 1994, we recommended that the Park Service assess the need to retain all of its existing housing. In line with this and other recommendations, the Congress passed the Omnibus Parks and Public Lands Management Act of 1996, which contains a provision requiring the Park Service to conduct such a study. The Park Service awarded a contract in November 1997 to identify the need for park housing and the condition of the housing and assess the availability and affordability of housing in nearby communities. The study, which is expected to be completed in October 1998, may result in the elimination of some housing units and related maintenance costs. Concerns were expressed in an October 1997 hearing before the Subcommittee on Interior and Related Agencies, House Committee on Appropriations, regarding the high cost of constructing new facilities in light of the Park Service’s $6.1 billion backlog of maintenance needs. Recent projects, such as new housing at Yosemite and Grand Canyon national parks and a high-cost outhouse at the Delaware Water Gap National Recreation Area, raised questions about the reasonableness of costs for construction projects. During the hearing, Interior’s Inspector General testified that private sector construction of housing near Yosemite would be at least $334,000 less than the Park Service’s $584,000 cost per house and at least $158,000 less than the Service’s $390,000 cost per house at the Grand Canyon. Also during the hearing, Subcommittee members raised a number of questions regarding the $330,000 outhouse at the Delaware Water Gap National Recreation Area that cost more than 3 times the average cost of a new 2,000-square-foot home with three bedrooms and two baths in the same area. (See fig. 2.) In light of the above construction costs, the Conference Committee for Interior’s fiscal year 1998 appropriations directed that an independent study of the Park Service’s construction program be conducted. This study is being performed by the National Academy of Public Administration (NAPA). The NAPA study is examining the Park Service’s construction program and practices, with the goal of identifying and recommending a comprehensive remedy for the causes of cost control problems. The study’s tasks include determining the (1) effectiveness of the Park Service’s decision-making process for constructing facilities; (2) adequacy of constraints on the scope and cost of housing and other projects; (3) appropriate role of the Denver Service Center in the design and oversight of construction projects, including repairing and rehabilitating facilities; and (4) potential for cost-saving incentives at the park and Denver Service Center levels. The study is expected to be completed by mid-June 1998. In addition to new requirements being imposed on the Park Service, Interior, including the Park Service, is currently taking a number of initiatives to better manage its maintenance and construction program. These initiatives include (1) developing a 5-year plan to prioritize maintenance and construction projects and (2) evaluating alternative methods for maintaining its historic structures. During recent congressional hearings focusing on maintenance issues within Interior, the Assistant Secretary for Policy, Management, and Budget acknowledged that the Department needs to improve the management and accountability of the maintenance and construction program and outlined a 5-year priority maintenance and construction program for the Park Service and other Interior agencies. The 5-year plan addresses the deferred maintenance, construction, and natural and cultural resource backlogs and will list priority maintenance and construction projects for the fiscal year 2000 budget. The criteria for selecting these projects involve (1) remedying maintenance deficiencies critical to health and safety and (2) pursuing natural and cultural resource protection. According to the Park Service’s fiscal year 1999 annual performance plan, it expects to identify, by September 30, 1999, priority maintenance and construction projects amounting to $500 million and plans to allocate funds to address at least 20 percent of the high-priority needs. The Park Service is currently evaluating alternative methods for maintaining its historic structures. The cost to maintain its historic structures is a significant component of the maintenance backlog estimate. As of December 1997, the Park Service estimated that the cost for maintaining about 20,000 structures was about $1 billion. However, on the basis of identified maintenance, rehabilitation, and development needs, the Park Service recognizes that it does not have and likely never will have enough funds and staff to take care of all of its historic structures. Accordingly, the Park Service identified alternative methods for preserving many of its historic structures, such as public-private partnerships. Specifically, the alternatives include cooperative agreements, leasing, conveyance of historic structures, as well as philanthropic support. These proposed alternatives should help the Park Service reduce its maintenance backlog. The Park Service also classified its inventory of historic structures by level of significance and by whether the structures must, should, or may be preserved or may be disposed of or altered. Such classification can help park officials assess priority maintenance needs and whether some structures should be maintained. At the time of our review, the Park Service had not taken any actions with respect to the alternative methods for maintaining its historic structures. Appendix I provides additional information on the Park Service’s inventory of historic structures. Given the substantial increase in funding that the Park Service will receive to address its maintenance backlog, now more than ever, the agency must be prepared to demonstrate what is being accomplished with these resources. To do so will require the Park Service to develop more accurate data on its maintenance backlog and to track the progress in addressing it. The new requirements being imposed on the Park Service and current initiatives being undertaken by Interior and the Park Service should, if implemented properly, help the agency to better manage this backlog. These efforts should also go a long way in addressing the concerns about the maintenance backlog that have been expressed by the Congress and others over the years. We provided a draft of this report to the Department of the Interior for review and comment. Interior said that it is in general agreement with the report’s conclusion that new requirements and initiatives undertaken by Interior and the National Park Service should help the Service to better define and manage its maintenance backlog. (See app. III.) To respond to your request, we met with officials from the Park Service’s headquarters office and the Philadelphia and Denver Park Service regional offices and from Acadia National Park, Colonial National Historical Park, Delaware Water Gap National Recreation Area, and Rocky Mountain National Park. We also obtained and reviewed pertinent documentation from these officials. Although the particular park units that were selected may not be representative of the entire national park system, the selection covers the various types, sizes, and geographical locations of park units to show problems relating to the maintenance backlog issues. We conducted our review from July 1997 through March 1998 in accordance with generally accepted government auditing standards. Appendix II provides a more detailed discussion of our objectives, scope, and methodology. As arranged with you office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days from the issue date. At that time, we will send copies of this report to the appropriate Senate and House committees. We will also make copies available to others on request. Please call me at (202) 512-3841 if you have any questions about this report. Major contributors to this report are listed in appendix IV. The National Park Service maintains an inventory of historic structures that is classified by management category and level of significance. These classifications were developed based on a compilation of legislative mandates and policy considerations indicating significance, use, condition, and location of the historic structures. According to the Park Service, this information was developed to reexamine management practices and to provide guidance to headquarters, regional, and park managers on how to set priorities in allocating resources to preserve historic structures. May be disposed of or altered The Park Service defines management category as follows: (1) Structures that must be preserved and maintained include structures that meet any one of the following criteria: preservation is specifically legislated, structure is related to the park’s legislated significance, structure is significant as defined by the National Historic Landmark criteria, structure contributes to the park’s national significance, or is a prehistoric structure. (2) Structures that should be preserved and maintained must meet all of the following criteria: may meet National Register criteria, is not incompatible with the park’s legislated significance, and has a continuing or potential use based upon design and location. (3) Structures that may be preserved or maintained meet either of the following conditions: structure may meet the National Register criteria but because of condition, location, or other factors does not qualify for (2) above; structure does not meet National Register criteria but through the planning process, it is decided to manage the structure as a cultural resource. (4) Structures that may be disposed of or altered meet any one of several criteria: structure is an irreparable hazard to public health and safety; is a physical or visual intrusion on the park’s legislated significance; or has lost its historical integrity. The Park Service defines significance as follows: National: structure is listed in the National Register as nationally significant or possess national significance by act of Congress or executive order. Contributing: structure does not possess national significance on an individual basis but contributes to the national significance of a park or historic district. State: structure qualifies for the National Register and possess significance at the state level. Local: structure qualifies for the National Register and possess significance at the local level. Not evaluated: structure known through direct observation, survey, testing, or inventory but does not have National Register documentation indicating significance. Not significant: structure known not to be significant but is managed as a cultural resource. Unknown: Data element not completed. The objectives of our review were to determine (1) the National Park Service’s estimate of the maintenance backlog and its composition, (2) how the agency determined the maintenance backlog estimate and whether it is reliable, (3) how the agency manages the backlog, and (4) recent requirements that have been placed on the Park Service and other federal agencies that may have a positive impact on what is being done in this area and current initiatives being taken by the Park Service to deal with the backlog issues. To identify the estimate and composition of the maintenance backlog at national parks, we obtained agency reports, press releases, budget documents, and other relevant Park Service data citing unmet maintenance and repair needs. We also interviewed agency headquarters officials responsible for compiling and reporting the backlog estimate. We did not develop an independent overall maintenance backlog estimate but used the estimate and the composition reported by the Park Service. For information on how the Park Service determined its maintenance backlog estimate and on whether it is reliable, we obtained and analyzed the documentation used by the agency to compile the backlog estimate. We also interviewed officials at headquarters and at two Park Service regional offices and met with maintenance and other personnel at four park units—the Acadia National Park, Maine; Colonial National Historical Park, Virginia; Delaware Water Gap National Recreation Area, Pennsylvania; and Rocky Mountain National Park, Colorado. The parks were judgmentally selected to covers the various types, sizes, and geographical locations of park units. The Intermountain Region in Denver and the Northeast Region in Philadelphia were selected because they have jurisdiction over the parks we visited. To determine the reliability of the backlog estimate, we reviewed whether the agency has a common definition of “maintenance backlog” and whether the estimate was current. We did not question the validity of the maintenance needs reported by individual parks or by headquarters. To obtain information on how the Park Service manages its maintenance backlog, we interviewed headquarter officials to determine whether the agency has identified its total maintenance backlog needs and has tracked the progress in meeting those needs. We also reviewed Park Service documents to determine how the agency plans to handle increased funding resources that may be used to reduce the maintenance backlog. Finally, to identify new requirements that affect the reporting of agency maintenance needs, we reviewed (1) changes in federal accounting standards, (2) the Government Performance and Results Act, (3) the Park Service’s study on employee housing needs, and (4) a study of the Park Service’s construction practices. We also interviewed headquarters officials to identify actions currently underway by the Department of the Interior and the Park Service to better manage the maintenance and construction program. We performed our work from May 1997 through March 1998 in accordance with generally accepted government auditing standards. William Temmler 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. 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Summary: Pursuant to a congressional request, GAO reviewed the National Park Service's (NPS) efforts to identify and manage the maintenance backlog, focusing on: (1) NPS' estimate of the maintenance backlog and its composition; (2) how NPS determined the maintenance backlog estimate and whether it is reliable; (3) how NPS manages the backlog; and (4) what, if any, recent requirements or initiatives are being implemented by the NPS to help address its maintenance backlog problem. GAO noted that: (1) NPS' most recent estimate of its maintenance backlog does not accurately reflect the scope of the maintenance needs of the park system; (2) NPS estimated, as of January 1997, that its maintenance backlog was about $6.1 billion; (3) most of this amount--about $5.6 billion, or about 92 percent--was for construction projects, which, for the most part, are aimed at correcting maintenance problems at existing facilities; (4) however, over 21 percent of the $5.6 billion in construction projects, or $1.2 billion, was for the construction of new facilities, such as $24 million for a bike path at the Colonial National Historical Park in Virginia and $16.6 million to replace a visitor center and construct a park entrance at Acadia National Park in Maine; (5) while GAO does not question the need for these facilities, including these kinds of new construction projects or projects that expand or upgrade park facilities in an estimate of the maintenance backlog is not appropriate because such projects go beyond what could reasonably be viewed as maintenance; (6) including them in the maintenance backlog contributes to confusion about the park system's actual maintenance needs; (7) NPS estimates of its maintenance backlog are compiled on an ad hoc basis in response to requests from Congress or others; the agency does not have a routine, systematic process for determining its maintenance backlog; (8) the most recent estimate, as of January 1997, was based largely on information that was compiled by NPS in 1993 and has not been updated to reflect changing conditions in individual park units; (9) this fact, as well as the absence of a common definition of what should be included in the maintenance backlog, contributed to an inaccurate and out-of-date estimate; (10) NPS does not use the estimated backlog in managing park maintenance operations; (11) as such, it has not specifically identified its total maintenance backlog; (12) because the identified backlog far exceeds the funding resources being made available to address it, NPS has focused its efforts on identifying its highest-priority maintenance needs; (13) however, given that substantial additional funding resources are being made available--over $100 million starting in fiscal year 1998--NPS needs to more accurately determine its total maintenance needs so that it can better track progress in meeting them; and (14) NPS is taking actions to help address the maintenance backlog problem in response to several requirements.