User Fees: DOD Fees for Providing Information Not Current and	 
Consistent (12-OCT-01, GAO-02-34).				 
								 
The National Defense Authorization Act for 2001 authorized the	 
military department secretaries to (1)charge fees to persons	 
requesting information from the military archives and (2) retain 
collected fees to help defray costs of providing the information.
The military archives also have authority under the User Charge  
Statute and the Freedom of Information Act (FOIA) to charge for  
general information provided to the public. With the act	 
authorizing, but not requiring, action by the four primary	 
military archives, the archives have responded differently.	 
Although none has yet implemented a fee pursuant to the act, one 
archive plans to do so by October 2001. The Department of	 
Defense's (DOD) archives and other offices are also authorized	 
under both the User Charge Statute and FOIA to charge for	 
information provided to the public. However, neither of these	 
statutes authorizes an agency to retain the fees collected for	 
providing general information to the public. The four designated 
archives are charging fees to public requesters but are not using
the fee schedule mandated by the DOD regulation implementing the 
User Charge Statute. Similarly, DOD's fee schedules for charges  
under FOIA are outdated. DOD's inconsistent use of the authority 
to charge fees and the use of outdated DOD fees schedules result 
in uncollected fees of a million dollars or more annually and	 
inconsistent handling of public requests for historical 	 
information.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-34						        
    ACCNO:   A02290						        
  TITLE:     User Fees: DOD Fees for Providing Information Not Current
and Consistent							 
     DATE:   10/12/2001 
  SUBJECT:   Fees						 
	     Freedom of information				 
	     Military cost control				 
	     Archives						 

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GAO-02-34
     
A

Report to Congressional Committees

October 2001 USER FEES DOD Fees for Providing Information Not Current and
Consistent

GAO- 02- 34

a

GAO United States General Accounting Office

Page 1 GAO- 02- 34 DOD User Fees

October 12, 2001 The Honorable Carl Levin Chairman The Honorable John Warner
Ranking Minority Member Committee on Armed Services United States Senate

The Honorable Bob Stump Chairman The Honorable Ike Skelton Ranking Minority
Member Committee on Armed Services House of Representatives

Section 1085 of the National Defense Authorization Act for Fiscal Year 2001
authorized the military department secretaries to (1) charge fees to persons
requesting information from the primary military archives and (2) retain
collected fees to help defray costs associated with providing the
information. The military archives also have authority under the User Charge
Statute (31 U. S. C. sect. 9701) and the Freedom of Information Act (FOIA) (5 U.
S. C. sect. 552) to charge for general information provided to the public. A
major distinction, however, is that the fees collected under these two
provisions are to be deposited with the Department of the Treasury.

The Conference Report on the National Defense Authorization Act for Fiscal
Year 2001 directs the Comptroller General to provide a report 1 year after
implementation of Section 1085 of the act on the fees collected and the
associated costs of providing historical information. In preliminary work
directed to that reporting requirement, we identified Section 1085
implementation issues and other issues related to Department of Defense
(DOD) fees under the User Charge Statute and FOIA. As requested, this report
(1) presents the status of Section 1085 implementation by the primary
military archives, (2) identifies the fees charged by the archives under
existing authorities, and (3) discusses other issues relating to DOD fees
for providing information to the public. As agreed with your offices, we
plan to follow up on these matters about 1 year after the first archive
implements Section 1085.

In meeting our objectives, we obtained information on the status of
implementation of Section 1085 and on the fees being charged by the

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 02- 34 DOD User Fees

archives under the User Charge Statute and FOIA. We compared the provisions
of the Section 1085, User Charge Statute, and FOIA in such areas as basis
for fees and retention of collected funds. We obtained information on when
fee schedules for the User Charge Statute and FOIA were established and
revised, and compared the User Charge Statute fee schedule with a fee
schedule being developed by the Army Military History Institute to be used
under Section 1085. We did not independently review the basis for any of the
established or proposed fees. We obtained information by interviewing DOD
officials in the Office of the Under Secretary of Defense (Comptroller);
Directorate for Freedom of Information and Security Review; Legislative
Reference Service, Office of General Counsel; four primary military
archives; and other offices providing historical information. Also, we
reviewed (1) laws, regulations, and documents related to DOD providing
information to public requesters and (2) documentation from the military
archives and their Web sites. We visited two of the four designated military
archives.

Our work was performed from April through July 2001 in accordance with U. S.
generally accepted government auditing standards. We requested comments on a
draft of this report from the Secretary of Defense or his designated
representative. Written comments from the Deputy Chief Financial Officer,
Office of the Under Secretary of Defense (Comptroller), are discussed in the
Agency Comments and Our Evaluation section of this report and are reprinted
in the appendix. Technical suggestions have been incorporated in the report
as appropriate.

With Section 1085 authorizing, but not requiring, action by the four primary
military archives, the archives have responded differently. Although none of
the primary military archives has yet implemented a fee system pursuant to
Section 1085, the Army Military History Institute plans to implement the
Section by October 2001. The Air Force Historical Research Agency is
studying possible fee structures, and officials of the Naval Historical
Center and the Marine Corps Historical Center told us that they have not
taken any implementation actions and are undecided about implementing
Section 1085.

DOD?s archives and other offices are also authorized under both the User
Charge Statute and FOIA to charge for information provided to the public.
However, neither of these statutes authorizes an agency to retain the fees
collected for providing general information to the public. The authority to
retain such collected fees to defray costs is a significant distinction
between Section 1085 and the other two statutes. Results in Brief

Page 3 GAO- 02- 34 DOD User Fees

The four designated archives are charging fees to public requesters but are
not using the fee schedule mandated by the DOD regulation implementing the
User Charge Statute. The fees vary significantly among the archives and
rarely are research fees and minimum charges, which are key elements of the
fees under DOD?s regulation, imposed. Even if the archives were using the
mandated fee schedule, they would not be recovering full cost (both direct
and indirect costs) required under the User Charge Statute and regulations
because DOD has not updated the fees to reflect current costs since the fee
schedule was established in 1986.

The $81,000 that the four primary archives reported collecting in fiscal
year 2000 is likely much less than would be collected if an updated fee
schedule were to be effectively implemented. For example, based on an early
draft of the Army Military History Institute?s fee schedule planned to be
used under Section 1085, recovery of full costs could require fees, in some
cases, that are three to four times those in the DOD schedule. DOD
Comptroller officials said that they had no basis to estimate the increased
collections that could result from the use of an updated fee schedule by the
numerous DOD offices and organizations responding to public requests to
search for and copy records.

Similarly, DOD?s fee schedules for charges under FOIA are outdated. The FOIA
fee schedule for general information, which is to be based on direct costs,
and the FOIA fee schedule for technical information, which is to be based on
full cost (both direct and indirect costs), have not been updated since
1986. DOD?s reported $670,000 of FOIA collections in fiscal year 2000 is
likely much less than could be collected under updated schedules.

DOD?s inconsistent use of the authority to charge fees and the use of
outdated DOD fee schedules could have resulted in uncollected fees of a
million dollars or more annually and inconsistent handling of public
requests for historical information. As the four primary military archives
consider implementing Section 1085, DOD needs to ensure that fees charged to
public requesters for information throughout DOD are current and
consistently applied. Accordingly, we are recommending actions to update fee
schedules and ensure that such schedules are consistently implemented
throughout DOD.

DOD concurred with the recommendations in this report and commented on
actions that have been or are to be taken. These actions substantially
address our recommendations; however, we believe that additional efforts are
necessary to ensure that involved DOD organizations are aware of and
properly use updated fee schedules.

Page 4 GAO- 02- 34 DOD User Fees

In the mid- 1990s, the Army Military History Institute began developing
proposed legislation for charging and retaining fees to defray costs of
providing historical information to the public. The Institute, whose mission
is to preserve the Army?s history and ensure access to historical research
material, was experiencing a significant increase in requests from the
public while resources available to respond were decreasing. For example,
the Institute reported that the annual number of requests increased from
about 13,000 in 1987 to 20,600 in 1995 and to 35,800 in 2000. During the
same period, the number of staff members decreased from over 40 to 33. As a
result, backlogs and waiting times increased. The Institute developed and
submitted legislative proposals that authorized it to charge and retain
fees.

In response, Congress enacted Section 1085 of the National Defense
Authorization Act for Fiscal Year 2001, which authorizes the charging and
retaining of fees by one designated primary archive in each of the four
military departments. The four designated archives are the

 Air Force Historical Research Agency 1 at Maxwell AFB, Alabama;

 Army Military History Institute at Carlisle Barracks, Pennsylvania;

 Marine Corps Historical Center at Washington Navy Yard, D. C.; and

 Naval Historical Center at Washington Navy Yard, D. C. Section 1085 does
not specify a fee structure or the fees that are to be charged, but states
that fees are not to exceed the costs of providing the information. The
Section also states that fees are not to be charged for information that is
requested (1) to carry out a duty as a member of the armed forces or
employee of the United States or (2) under FOIA, which has a separate fee
structure.

Prior to the authority granted under Section 1085, DOD, including the
military archives, was authorized to charge fees for responding to requests
for information under the User Charge Statute and FOIA. Because Section 1085
does not apply to the DOD offices, organizations, museums, and archives
other than the four designated archives, the User Charge Statute and FOIA
will continue to be the basic authority for these activities to charge fees
for providing information.

1 Section 1085 refers to this as the Air Force Military History Institute.
Background

Page 5 GAO- 02- 34 DOD User Fees

The User Charge Statute is implemented by Office of Management and Budget
(OMB) Circular No. A- 25, and DOD Financial Management Regulation (FMR),
Volume 11A, Chapter 4. DOD?s policy, as stated in Chapter 4, is that when a
service is provided that conveys special benefits to recipients, above and
beyond those accruing to the public at large, a reasonable charge shall be
made to each identifiable recipient. The policy provides that a charge shall
be imposed to recover the full cost to the federal government of rendering a
service or the fair market value of such service, whichever is higher.
Appendix 1 of Chapter 4 lists benefits for which no charge is to be made
such as services requested by members of the U. S. Armed Forces in their
capacity as service members. Appendix 2,

?Schedule of Fees and Rates for Copying, Certifying, and Searching Records
Rendered to the Public,? is mandated for use throughout DOD. The Under
Secretary of Defense (Comptroller) is responsible for additions or revisions
to Chapter 4.

FOIA, which specifies processes and procedures for making information
available to the public, is implemented in DOD by DOD Regulation 5400.7- R.
In accordance with FOIA, DOD Regulation 5400.7- R contains a fee schedule
for responding to FOIA requests. For general information, the fees for
search, review, and duplication of documents are to be based on direct
costs. For technical information, 2 the fees are to be based on all
reasonable costs, which is defined as the full costs to the federal
government of rendering the service, or fair market value of the service,
whichever is higher. The regulation also provides that

 the first 2 hours of search time and the first 100 pages of duplication
shall be provided without charge unless requesters are seeking documents for
commercial use,

 fees will be waived or reduced when the information is likely to
contribute significantly to public understanding of DOD, and

 fees shall be automatically waived when assessable fees total $15 or less.
The Directorate for Freedom of Information and Security Review is
responsible for the FOIA regulation.

2 Provisions for technical information were added in response to 10 U. S. C.
sect. 2328, which requires requesters to pay the costs of search, review, and
duplication. FOIA officials said that the term ?technical information? has
only been generally defined and that technical information fees are rarely
used.

Page 6 GAO- 02- 34 DOD User Fees

FOIA requests are specifically excluded under Section 1085 and the DOD
regulations implementing the User Charge Statute. Accordingly, the
provisions of Regulation 5400.7- R would determine fees for any FOIA
request. However, if a request is not identified as a FOIA request, the fees
should be determined under the User Charge Statute as specified in FMR,
Volume 11A, Chapter 4.

None of the four designated archives has changed its fee structure pursuant
to Section 1085. At the time of our work, two of the four archives were
taking actions to implement the Section. Officials at the Army Military
History Institute were developing fee schedules and planning to implement
the Section by October 2001. Officials at the Air Force Historical Research
Agency had tasked key stakeholders with determining a fee structure.
However, they have not established a target date for implementing the
Section. Section 1085 permits each of the four archives to develop its own
fee schedule provided that the fees charged do not exceed the costs of
providing the information.

Officials at the Naval Historical Center and the Marine Corps Historical
Center have not decided whether to implement a fee system based on Section
1085 provisions. They have taken no specific actions toward implementation
and have received no implementation guidance from their headquarters.

One of the factors affecting Section 1085 implementation decisions by the
four archives is that they were already authorized under both the User
Charge Statute and FOIA to charge for information provided to the public.
Based on the statute and regulations, the archives should charge for
information provided to public requesters under the User Charge Statute
unless the request is identified as a FOIA request. If identified as a FOIA
request, any charges should be based on FOIA implementing regulations.

However, neither of these statutes authorizes the military archives to
retain fees collected in providing general information to the public to
defray costs. Fees collected under both the User Charge Statute and FOIA for
general information must be deposited in the Treasury as Miscellaneous
Receipts. Accordingly, the authority to retain collected fees to defray
incurred costs is one significant distinction between Section 1085 and the
other two statutes. The Army Military History Institute identified the
ability to use collected fees to improve service to the public as the
primary reason it developed the legislative proposals that led to Section
1085. Status of Section 1085

Implementation

Page 7 GAO- 02- 34 DOD User Fees

Increasing numbers of public requests at a time when budgetary resources
were decreasing resulted in the archives developing arrangements to minimize
the cost impact of public requests on the archives? budgets. For example,
the Army Military History Institute arranged for a contract, through a
nonappropriated fund account, to reproduce requested photographs with fees
collected for the photographs reimbursing the fund. The Naval Historical
Center refers those requesting its photographs to the Naval Historical
Foundation, a nonprofit foundation, which reproduces the photographs and
charges the customer. Without such arrangements, the costs of reproducing
photographs and responding to requesters would come from the archive?s
budget, and the fees collected from the customer would be deposited in
Treasury?s Miscellaneous Receipts and would not be available to offset the
costs. 3 These arrangements, by reducing budgetary pressures, have lessened
the benefits that an archive could achieve from implementing Section 1085.

All of the four primary archives charge fees for providing historical
information to requesters. However, none of the fees were in accordance with
the mandated DOD user fee schedule specified in Appendix 2 of DOD FMR,
Volume 11A, Chapter 4. In fact, archive officials told us that they were
unaware of the mandated fee schedule.

The ?Schedule of Fees and Rates for Copying, Certifying, and Searching
Records Rendered to the Public? in Appendix 2 establishes a minimum fee of
$3.50 for any chargeable case and additional fees for searching and
providing copies of various records, photographs, forms, etc. For office
copy reproductions, a minimum fee of $3.50 per request (six pages or less)
is specified with a charge of $0.10 for each additional page. For
photography, the Appendix?s schedule of prices per print is based on the
size, type, and quantity ordered. For example, the price per print for an 8-
by 10- inch print ranges from $4.50 for one to nine prints to $1.75 for each
print in quantities of over 50. The specified charge for clerical search and
processing is $13. 25 per hour with a minimum charge of $8.30.

3 We have approved arrangements under which agencies contract with private
firms for processing, storing, and retrieving information and those firms
charge and retain the fees for providing the information. See 61 Comp. Gen.
285 (1982) and B- 166506, October 20, 1975. We have not reviewed whether the
archives? arrangements would meet the approval requirements or raise other
issues. Archives? Fees Not in

Accordance With DOD Mandated Fees

Page 8 GAO- 02- 34 DOD User Fees

Existing fees vary significantly among the archives. For example, the
charges for a paper copy made by archive staff ranged from

 no charge by the Air Force Historical Research Agency, to

 no charge by the Marine Corps Historical Center for the first 100 pages
and a charge of $0.15 for each page thereafter, to

 a charge by the Army Military History Institute of $0. 25 per page, to

 a charge by the Naval Historical Center of $0.30 per page. In general, the
archives do not impose a minimum charge for providing information. This
could result in requesters receiving copies of documents free or for less
than a dollar as opposed to the $3.50 minimum specified in the DOD?s User
Charge fee schedule. The Marine Corps fees, which are based on FOIA,
resulted in any requester receiving up to 2 hours of search time and 100
pages without a charge. With the exception of the Marine Corps, the archives
did not have a clearly identified basis for their fee schedules.

The archives also appear to have different practices regarding which
requesters are charged and under what circumstances fees will be waived.
Archives officials told us that, in many cases, fees are not charged when
the request is from military personnel, veterans, or government employees.
Under the User Charge regulation, only members of the U. S. Armed Forces, in
their capacity as Service members, are exempt from charges. Archive
officials also said that fee waivers were used extensively for FOIA
requests. DOD?s FOIA regulations provide that the first 100 reproduced
images and 2 hours of research are free per request and that fees shall be
waived for all requesters when assessable costs for a FOIA request total $15
or less. Further, the regulations provide that documents shall be provided
without charge or at reduced charge when a DOD component determines that a
waiver or reduction of fees is in the public interest and likely to
contribute significantly to public understanding of DOD.

DOD last revised its User Charge Statute fee schedule for copying,
certifying, and searching records in March 1986. At that time, DOD revised
its user fees instruction and added a schedule of fees and rates for
services related to copying, certifying, and searching records. The
instruction stated that this schedule was to be used for such services
throughout DOD. The same fees were included in the DOD FMR, Volume 11A,
Chapter 4, Appendix 2, issued in March 1997. Although the Chief Financial
Officers Act of 1990 and OMB Circular A- 25 require a biennial review of
charges for services, DOD Comptroller officials were not aware of any
reviews having DOD User Charge and

FOIA Fees Not Current

Page 9 GAO- 02- 34 DOD User Fees

been done and had no documentation of reviews of the fee schedule for
copying, certifying, and searching records.

Fees being developed by the Army Military History Institute indicate that
the fees mandated in Appendix 2 might be significantly understated. For
example, the Institute?s early proposal, based on total direct and indirect
costs, shows a total fee of $10.50 for mailing a requester 10 paper copies
of an item, itemized as follows.

Pull- fee per item $5.00 $0.25 per page for paper to paper copies by staff
times 10 pages 2. 50 Minimum charge for mailing 10 copies or less 3.00

The total fee under Appendix 2 for the same order would be $3.90, itemized
as follows.

Minimum fee including 6 pages or less $3.50 4 additional pages at $0. 10 per
page for paper to paper copies by staff .40

In this case, the fee under Appendix 2 appears to be about one- third of the
Institute?s proposal. Comptroller officials noted that Appendix 2 provided
for a minimum clerical search and processing charge of $8.30 and that
including this minimum clerical charge in the above comparison would result
in a higher fee under Appendix 2 than under the Army Military History
Institute?s proposal. However, the officials had no information as to
whether the minimum clerical charge had been or would be included in a fee
involving a request for paper copies of an item. Further, if a search charge
is appropriate, the Institute?s proposal includes a $25 hourly research
charge as opposed to the $13.25 hourly charge for clerical search and
processing under Appendix 2.

The Institute?s proposal for five copies of an 8- x 10- inch photograph
shows a total fee of $105 (pull fee per item of $5 and $20 for each copy).
The total fee under Appendix 2 would be $22.50 ($ 4.50 per copy) or less
than one- fourth of the Institute?s proposal.

As with User Charges, DOD fee schedules for charges under FOIA are not
current. The FOIA fee schedule for general information, which is to be based
on direct cost, has not been updated since 1986. The FOIA fee schedule for
technical information, which is to be based on full cost (both

Page 10 GAO- 02- 34 DOD User Fees

direct and indirect costs), was last issued in 1998, but is the same as the
schedule first issued in 1986.

The collections reported by the four primary military archives are not
indicative of potential future collections under updated fee schedules.
Military archive officials reported collecting about $81,000 during fiscal
year 2000 with the Air Force reporting the most collections (about $46,000)
and the Marine Corps reporting the least (about $2,000). However, these
amounts are probably much less than amounts that should be collected if
updated fee schedules are established and effectively implemented because of
the following.

 Fees charged by the archives are generally less than those in DOD fee
schedules even though the fees in the DOD schedules are outdated and could
be understated by a factor of three or four.

 Archives officials said that fees are often waived for military personnel,
veterans, government employees, and others although such waivers are not
addressed by DOD?s regulations implementing the User Charge Statute.

 Archive officials state that search fees are not usually charged, which
can be a significant element of cost that should be recovered.

 Arrangements that the archives have used to lessen budgetary impacts, such
as the Naval Historical Foundation collecting fees for Naval Historical
Center photographs, have reduced reported collections.

Further, there are many additional organizations that would have increased
collections resulting from updated fee schedules under the User Charge
Statute and FOIA. DOD Comptroller officials had no information as to the
amount of funds collected throughout DOD using the fee structure mandated in
the DOD FMR, Volume 11A, Chapter 4, Appendix 2. They agreed that numerous
offices and organizations throughout DOD- some of which have significant
numbers of requesters- should use the fee schedule.

With regard to FOIA, DOD reported that about $670, 000 was recovered through
assessed fees in fiscal year 2000, less than 2 percent of the reported $36.5
million in costs associated with providing information under FOIA. If FOIA
fees are understated by a significant amount, as appears possible, increases
in collections from updated FOIA fee schedules could be significant.
Benefits of Updated

Schedules and Consistent Implementation Would Be Significant

Page 11 GAO- 02- 34 DOD User Fees

Because of DOD?s inconsistent use of authority to charge fees and use of
outdated fees schedules, the archives and other providers of public
information throughout DOD have not collected a million dollars or more
annually in user fees and have treated public requesters inconsistently.

DOD, in conjunction with considering implementation of Section 1085, needs
to ensure that fees charged to public requesters for information throughout
DOD are current and consistent. This is not the situation now because (1)
DOD has not revised its fee schedules under the User Charge Statute and FOIA
since 1986, (2) the primary military archives are not using the mandated fee
schedules, and (3) fees being charged to public requesters vary
significantly across these archives. Accordingly, a first step that would
precede implementation of Section 1085 is updating the User Charge Statute
and FOIA fee schedules. This would assist archives in determining whether to
implement Section 1085 and whether an archive that implements Section 1085
needs a separate fee schedule. To provide consistency throughout DOD, an
archive implementing Section 1085 could use DOD?s user fee schedule in lieu
of establishing a new fee schedule unless specific justification exists for
the new schedule.

Further, after fee schedules are updated for the User Charge Statute and
FOIA, they need to be implemented consistently throughout DOD by all offices
and organizations responding to public requesters. Such implementation is
necessary for the fair and equitable treatment of the public.

We recommend that the Under Secretary of Defense (Comptroller), and the
Director, Freedom of Information and Security Review, in conjunction with
the secretaries of the military departments and other DOD officials, as
appropriate,

 review and update fee schedules under the User Charge Statute and FOIA;

 for each archive implementing Section 1085, establish fee schedules that
are consistent with the updated fee schedules unless a determination is made
that a different fee schedule is justified; and

 undertake a notification, training, and follow- up effort to ensure that
all DOD offices and organizations responding to requesters for information
are properly using the updated fee schedules. Conclusions

Recommendations for Executive Action

Page 12 GAO- 02- 34 DOD User Fees

In written comments on a draft of this report, DOD concurred with the
recommendations and commented on actions that have been or are to be taken.

With regard to the recommendation to review and update fee schedules under
the User Charge Statute, DOD commented that the Office of the Under
Secretary of Defense (Comptroller) will work with other organizations to
update, as appropriate, and publish a revised fee schedule periodically.
With regard to FOIA fee schedules, DOD commented that the Directorate for
Freedom of Information and Security Review, which is responsible for those
schedules, did not provide comments on the recommendations.

With regard to the recommendation that the fee schedule for each archive
implementing Section 1085 be consistent with updated user charge fee
schedule, DOD commented that fee schedules authorized by Section 1085 are
optional. DOD said that the Army Military History Institute, the only
archive developing a schedule of charges under Section 1085, would consider,
where appropriate, the changes in a revised user charge schedule.

With regard to the recommendation to undertake a notification, training, and
follow- up effort, DOD commented that the Office of the Under Secretary of
Defense (Comptroller) has an established process for making changes to the
DOD FMR. It added that DOD audit organizations will be requested to include
user fee schedule compliance as a part of their standard reviews, where
applicable. Because archive officials were unaware of the FMR fee schedule,
we continue to believe that the more substantive actions that we recommended
are warranted.

We are sending copies of this report to the Office of the Under Secretary of
Defense (Comptroller); the Director, Freedom of Information and Security
Review; and interested congressional committees. Copies of this report will
also be made available to others upon request. Agency Comments

and Our Evaluation

Page 13 GAO- 02- 34 DOD User Fees

Please contact me at (202) 512- 9505 if you have any questions. Major
contributors to this report were David Childress, Mary Jo Lewnard, and Edda
Emmanuelli- Perez.

Gregory D. Kutz Director Financial Management and Assurance

Appendix I: Comments From the Department of Defense

Page 14 GAO- 02- 34 DOD User Fees

Appendix I: Comments From the Department of Defense

Appendix I: Comments From the Department of Defense

Page 15 GAO- 02- 34 DOD User Fees

Appendix I: Comments From the Department of Defense

Page 16 GAO- 02- 34 DOD User Fees (192029)

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