NASA's Space Vision: Business Case for Prometheus 1 Needed to	 
Ensure Requirements Match Available Resources (28-FEB-05,	 
GAO-05-242).							 
                                                                 
In 2003, the National Aeronautics and Space Administration (NASA)
initiated the Prometheus 1 project to explore the outer reaches  
of the Solar System. The Prometheus 1 spacecraft is being	 
designed to harness nuclear energy that will increase available  
electrical power from about 1,000 watts to over 100,000 watts and
enable the use of electric propulsion thrusters. Historically,	 
NASA has had difficulty implementing some initiatives. NASA's	 
failure to adequately define requirements and quantify the	 
resources needed to meet those requirements has resulted in some 
projects costing more, taking longer, and achieving less than	 
originally planned. Prometheus 1 will need to compete for NASA	 
resources with other space missions--including efforts to return 
the shuttle safely to flight and complete the International Space
Station. GAO was asked to determine (1) whether NASA is 	 
establishing initial justification for its investment in the	 
Prometheus 1 project and (2) how the agency plans to ensure that 
critical technologies will be sufficiently mature at key	 
milestones.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-242 					        
    ACCNO:   A18336						        
  TITLE:     NASA's Space Vision: Business Case for Prometheus 1      
Needed to Ensure Requirements Match Available Resources 	 
     DATE:   02/28/2005 
  SUBJECT:   Aerospace research 				 
	     Cost analysis					 
	     Federal procurement				 
	     Mission budgeting					 
	     Program evaluation 				 
	     Program management 				 
	     Research and development				 
	     Space exploration					 
	     Strategic planning 				 
	     Systems design					 
	     Future budget projections				 
	     Research and development costs			 
	     Budgeting						 
	     Space operations					 
	     Mars Exploration Spacecraft			 
	     Mars Pathfinder Spacecraft 			 
	     NASA Jupiter Icy Moons Mission			 
	     NASA Prometheus 1 Project				 
	     NASA Prometheus Nuclear Systems and		 
	     Technology Program 				 
                                                                 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Product.                                                 **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
GAO-05-242

United States Government Accountability Office

GAO

                       Report to Congressional Requesters

February 2005

NASA'S SPACE VISION

  Business Case for Prometheus 1 Needed to Ensure Requirements Match Available
                                   Resources

GAO-05-242

[IMG]

February 2005

NASA'S SPACE VISION

Business Case for Prometheus 1 Needed to Ensure Requirements Match Available
Resources

  What GAO Found

NASA is in the process of establishing initial justification for its
investment in the Prometheus 1 project but faces challenges establishing
preliminary requirements and developing accurate cost estimates. Decision
makers will not get their first comprehensive picture of the project's
requirements and the resources needed to meet those requirements until the
preliminary mission and systems review, scheduled for summer 2005.
Defining the project's requirements and developing life-cycle cost
estimates by then could be challenging, given the short time frames. The
fidelity of this information should improve by the preliminary design
review scheduled for 2008. At that time, NASA has the opportunity to use
these more refined requirements and cost estimates to establish a sound
business case for its investment in the Prometheus 1 project. According to
Prometheus 1 project management, a flat funding profile is inadequate to
ramp up for the planned 2015 launch of Prometheus 1, the project's first
spacecraft to its original destination of Jupiter's Icy Moons. By matching
requirements to resources a sound business case would allow NASA to
determine whether trade-offs in the design of the spacecraft or the
agency's expectations are needed to avoid outstripping available
resources. Significant program cost and schedule increases in past
programs can be traced to not matching requirements with resources at
preliminary design review.

While development of the Prometheus 1 technologies is under way, each will
require extensive advancement before they are mature enough to support
reliable cost estimates. NASA is preparing technology development plans
that include measurable criteria to ensure the Prometheus 1 technologies
are on track for meeting NASA's maturity requirements through the end of
the preliminary design phase.

GAO's best practices work has shown, however, that establishing a formal
business case based on a knowledge-based approach that includes matching
requirements and available resources-which include technical and
engineering knowledge, time, and funding-and controls to ensure that
sufficient knowledge has been attained at critical junctures within the
product development process is an essential part of any product
development justification. NASA's current policy does not require projects
to develop knowledge-based business cases that match requirements to
available resources and include controls to ensure that sufficient
knowledge has been attained. Therefore, the agency had not planned to
develop such a business case for Prometheus 1.

Since GAO provided our draft report to NASA for comment, the agency
released its fiscal year 2006 budget request that includes changes to
Prometheus 1. If properly implemented, these changes could be positive
steps in addressing the findings and recommendations in this report.

                 United States Government Accountability Office

Contents

  Letter

Results in Brief
Background
Initial Justification for Prometheus 1 Project Could Form the Basis

of a Sound Business Case
NASA's Plans to Ensure Mature Technologies Rely on Prototype

Demonstrations
Conclusions
Recommendations for Executive Action
Agency Comments
Scope and Methodology

                                       1

                                      2 4

                                       7

12 14 15 16 17

Appendix I Technology Readiness Levels Definitions

Appendix II

Prometheus 1 Critical Technologies

Nuclear Reactor
Power Conversion
Heat Rejection
Nuclear Electric Propulsion
Radiation Hardening
High Power Communications
Autonomous Rendezvous and Docking

21

21 21 21 22 22 22 23

Appendix III	Comments from the National Aeronautics and Space
Administration

Appendix IV GAO Contact and Staff Acknowledgments 28

GAO Contact 28
Acknowledgments 28

GAO Related Products 29

Figures

Figure 1: Prometheus 1 Spacecraft 5

Figure 2: NASA Prometheus 1 Fiscal Year 2005 Budget Request

Profile 8 Figure 3: Prometheus 1 Milestone Reviews 11 Figure 4: Technology
Maturity Levels for Product Development 13

Abbreviations

AR&D autonomous rendezvous and docking
JIMO Jupiter Icy Moons Orbiter
JPL Jet Propulsion Laboratory
MCT maturity criteria tables
NASA National Aeronautics and Space Administration
PDR preliminary design review
PMSR preliminary mission and systems review
SLI Space Launch Initiative
TRL technology readiness levels

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It 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.

United States Government Accountability Office Washington, DC 20548

February 28, 2005

The Honorable Daniel K. Inouye
Co-Chairman
Committee on Commerce, Science, and Transportation
United States Senate

The Honorable John McCain
United States Senate

In 2003, the National Aeronautics and Space Administration (NASA)
initiated the Prometheus 1 project to explore the outer reaches of the
Solar System in the hopes of finding answers to some of humankind's most
profound questions about life and its origins. The Prometheus 1 spacecraft
is being designed to harness nuclear energy that will efficiently increase
available electrical power from about 1,000 watts to over 100,000 watts
and enable the use of electric propulsion thrusters. The availability of
nuclear power at this magnitude will fundamentally change NASA's
capability to explore deep space.

While NASA has been successful in missions such as Mars Pathfinder and
Exploration rovers, the agency has had difficulty implementing a number
of other costly initiatives because it was overly optimistic in what could
be
achieved within available resources. NASA's failure to adequately define
requirements and quantify the resources needed to meet those
requirements has resulted in some projects costing more, taking longer,
and achieving less than originally planned. Prometheus 1 will compete for
NASA resources with other space missions-including, in the near term,
efforts to return the shuttle safely to flight and completing the
International Space Station.

Cognizant of the outlook for a constrained federal budget for the
foreseeable future and NASA's difficulty in implementing some major
programs within projected resources, you asked us to review the
Prometheus 1 project to determine (1) whether NASA is establishing initial
justification for its investment in the Prometheus 1 project and (2) how
the
agency plans to ensure that critical technologies will be sufficiently
mature
at key milestones.

To address our objectives, we obtained and reviewed Prometheus 1 plans,
schedules, risk assessments, budget documentation, technology maturity

Results in Brief

assessments, and technology development plans. We conducted further
qualitative and quantitative analyses of these documents and compared them
to criteria established in NASA and Jet Propulsion Laboratory (JPL)
policies governing development programs and in GAO's best practices body
of work (see GAO Related Products). Our work was conducted between April
2004 and January 2005 in accordance with generally accepted government
auditing standards.

Since our draft report was provided to NASA for comment, a significant
change has been made to the Prometheus 1 project. NASA's fiscal year 2006
budget request includes changes to the Prometheus 1 project that directly
address the findings and recommendations of this report. These changes are
briefly outlined in the Agency Comments section of this report.

NASA is in the process of establishing initial justification for its
investment in the Prometheus 1 project but faces challenges preparing
preliminary requirements and cost estimates. NASA wants to have a defined
set of preliminary system requirements and an initial estimate of the
life-cycle cost for Prometheus 1 by summer 2005-when the project enters
into the preliminary design phase. While the project office has drafted
cost guidelines and a technical baseline for use in developing an initial
lifecycle cost estimate, due to the early nature of the project, the
development of this estimate is just under way. Before Prometheus 1 can
move forward into the preliminary design phase, NASA must make funding
decisions. At this time, however, the level of funding NASA needs to
execute the project is not fully defined. NASA requested $438 million for
fiscal year 2005, but according to project officials, the "flat line"
estimate for the next few years would need to be increased to reflect
project needs of a mission to Jupiter's Icy Moons. A business case
providing an understanding of the potential return on such investment
would be helpful to decision makers for determining whether continued
investment-currently estimated by the Congressional Budget Office at about
$10 billion1-is warranted. Developing a sound business case that includes
matching requirements with expected resources, would enable NASA to make
early trade-offs either in the preliminary design of the spacecraft or in
the agency's expectations to avoid outstripping available resources. While
NASA will

1This estimate is based on conducting the Jupiter Icy Moons Orbiter
Mission. The Congressional Budget Office did not consult with NASA to
develop this estimate.

have information available to match preliminary requirements to expected
resources, the fidelity of this information is not expected to be
completely defined until the preliminary design review (PDR), currently
scheduled for 2008.

NASA plans to ensure critical technologies are mature by demonstrating
subsystem prototypes before the end of the preliminary design phase. There
are several technologies, however, whose maturity will influence NASA's
ability to develop initial requirements and reliable resource estimates.
The Prometheus 1 design conceived for the mission to Jupiter's Icy Moons
relied on advancements in several breakthrough technologies, including
nuclear electric power and propulsion, high power communications,
radiation-hardened electronics, and autonomous rendezvous and docking
(AR&D). NASA is preparing technology development plans that include
measurable criteria to ensure each technology is on track for meeting the
maturity requirements through the end of the preliminary design phase.
While development of these technologies is under way, each will require
extensive advancement before they are mature enough to provide the
revolutionary capabilities of the Prometheus 1 spacecraft.

Our past work on the best practices of product developers in government
and industry has found that development of a sound business case based on
matching requirements to resources is a key factor in successfully
addressing such challenges. Despite the fact that the Prometheus 1 project
is in the very early stages of development, the use of a sound business
case that includes well-defined requirements, realistic cost estimates,
and mature technology is an essential part of any product development
investment justification. NASA's current policy does not require projects
to develop formal knowledge-based business cases that match requirements
to available resources and include controls to ensure that sufficient
knowledge has been attained. NASA had not planned to develop such a
business case. Subsequent to our draft being provided to NASA for comment,
the agency announced in its fiscal year 2006 budget request that it was
conducting an analysis of alternatives to identify a new mission with
reduced technical, schedule, and operational risk. As NASA will be
establishing a new justification for the Prometheus 1 project, we are
recommending that the NASA Administrator establish a sound business case
for the Prometheus 1 project wherein resources are matched to requirements
and controls are in place to ensure that sufficient knowledge has been
attained at critical phases of the product development process.

Background

The Prometheus 1 project is part of NASA's Prometheus Nuclear Systems and
Technology program2 to develop nuclear power technologies capable of
providing power and propulsion for a new generation of missions. The
Prometheus 1 spacecraft is being designed to use nuclear power and
electric propulsion technologies to explore the outer reaches of the solar
system. The Jupiter Icy Moons Orbiter (JIMO) mission-a 4 to 6-year study
of three of Jupiter's moons: Callisto, Europa, and Ganymede-was the
original destination identified by NASA.3 The JIMO mission's overarching
science objectives were to (1) investigate the origin and evolution of the
three moons; (2) scout their potential for sustaining life; and (3)
determine the current rate of movement of surface ice and the rates at
which the moons are weathered. With an unprecedented level of power,
Prometheus 1, the first in a potential series of spacecraft, is expected
to support the use of high capability science instruments and high power
communications systems to provide scientists with an a unprecedented
amount of scientific information. Figure 1 depicts the notional Prometheus
1 spacecraft.

2The Prometheus Nuclear Systems and Technology program stems from the
former Nuclear Systems Initiative to develop nuclear power for deep space
exploration.

3Subsequent to being provided a draft of this report for comment, NASA
announced that it was conducting an analysis of alternatives to identify a
new mission.

Figure 1: Prometheus 1 Spacecraft

Source: NASA.

NASA contracted with the Jet Propulsion Laboratory (JPL) to manage the
Prometheus 1 project and to manage development of the science mission
payload. In turn, JPL awarded a $400-million contract for the initial
development of the Prometheus 1 spacecraft to Northrop Grumman Space
Technology in September 2004. NASA is collaborating with the Department of
Energy's Office of Naval Reactors to develop and handle all issues related
to the spacecraft's nuclear reactor.

The Prometheus 1 project will have to compete for funding with other NASA
programs. In January 2004, the President charged NASA with implementing a
new strategy for space exploration-which includes the Prometheus 1
project-while simultaneously returning the shuttle to flight status and
completing the International Space Station. NASA laid out its

plan for implementing the strategy in its fiscal year 2005 budget request.
In essence, NASA's implementation plan holds aeronautics, science, and
other activities at near constant levels and transitions funding levels
currently dedicated to the Space Station and shuttle programs to the space
exploration strategy as the Space Station and shuttle programs phase out.
This plan was predicated upon NASA's annual funding level receiving
increases to about $18 billion a year by fiscal year 2008 and then
remaining near that level, except for inflation, through at least 2020.

Best Practices Reveal Elements of a Sound Business Case for Product
Development

In the last several years, we have undertaken a best practices body of
work on how leading developers in industry and government use a
knowledge-based approach to develop products that reduces risks and
increases the likelihood of successful outcomes. Development of a sound
business case based on this best practices model enables decision makers
to be reasonably certain about their products at critical junctures during
development and helps them make informed investment decisions.

Our best practice work has shown that developing a sound business case
based on matching requirements to resources is essential to implementing a
knowledge-based approach. A sound business case includes the following
elements

o  well-defined requirements,

o  preliminary design,

o  realistic cost estimates, and

o  mature technology.

A knowledge-based business case also involves the use of controls or exit
criteria to ensure that the required knowledge has been attained at each
critical juncture. It ensures that managers will (1) conduct activities to
capture relevant product development knowledge, (2) provide evidence that
knowledge was captured, and (3) hold decision reviews to determine that
appropriate knowledge was captured to allow a move to the next phase. If
the knowledge attained at each juncture does not confirm the business case
on which the effort was originally justified, the program does not go
forward.

Use of this approach has enabled leading organizations to deliver high
quality products on time and within budget. Product development efforts
that have not followed a knowledge-based business case approach can be
frequently characterized by poor cost, schedule, and performance outcomes.

Although NASA does not require projects to develop a formal business case
based on matching requirements to resources, JPL project implementation
policy,4 which establishes JPL's institutional structure for
implementation and management of JPL flight projects in accordance with
NASA policies, does require projects to develop documentation that
includes elements essential to a sound business case. For example, before
entering the preliminary design phase, JPL projects are required to
develop preliminary requirements, a conceptual design, realistic cost
estimates, and technology development plans. JPL projects are required to
update and improve the fidelity of information in these documents by PDR.
The information in these documents could provide NASA decision makers with
the information necessary to support sound business case decisions based
on matching requirements to resources at preliminary mission and systems
review (PMSR) and PDR.

In September 2004, the Congressional Budget Office reported that if NASA's
costs for implementing the strategy were similar to prior analogous NASA
programs-such as Apollo, Viking, and Mars Exploration Rover-NASA's funding
needs could increase by 15 to 23 percent-or $40 billion to $61
billion-over the 16-year estimate. The Congressional Budget Office
concluded that if funding were held constant, NASA would likely have to
either eliminate mission content or delay schedules.

NASA is still in the process of preparing initial justification for the
Prometheus 1 project to enter the preliminary design phase. Consequently,
at this time the level of funding NASA needs to execute the project is not
fully defined. According to project officials, however, funding levels
would need to be increased to support the planned launch of Prometheus 1
to Jupiter's Icy Moons. While NASA plans to have defined preliminary
system requirements and an initial estimate of the life-cycle cost for
Prometheus 1 by summer 2005-when the project enters the preliminary design
phase- the agency faces significant challenges in doing so.

Initial Justification for Prometheus 1 Project Could Form the Basis of a
Sound Business Case

4JPL's Project Implementation Policy establishes JPL's institutional
structure for implementation and management of JPL flight projects in
accordance with NASA Procedural Requirements 7120.5B, NASA Program and
Project Management Processes and Requirements, which governs all NASA
development programs and projects.

Project Management Believes Current Funding Is Insufficient to Support
Launch of Prometheus 1

According to Prometheus 1 project management, current funding is
inadequate to support a 2015 launch of Prometheus 1 as initially planned.
Following small funding increases from fiscal years 2005 through 2007, the
budget profile5 becomes relatively flat through fiscal year 2009 (see fig.
2). Project officials believe that the current profile would need to be
increased beginning in fiscal year 2007 to reflect project needs of a
Jupiter Icy Moons mission. Decision makers will not get their first
comprehensive picture of the project's requirements and the resources
needed to meet those requirements-the first basis for funding
decisions-until PMSR scheduled for summer 2005. While the fiscal year 2006
request includes an updated Prometheus 1 funding profile, a funding
profile based on life-cycle cost estimates-which NASA plans to have when
it enters the preliminary design phase-will not be included until NASA's
fiscal year 2007 request.

Figure 2: NASA Prometheus 1 Fiscal Year 2005 Budget Request Profile

Dollars in millions

                                      550

                                      500

                                      450

                                      400

                                      350

                                      300

                                      250

2005 2006 2007 2008 Fiscal year

Source: GAO.

5Between 10 and 15% of the budget shown is allocated to Advanced Systems
and Technology Development activities supporting current and future
missions.

Short Time Frames and History Foretell Difficulty in Defining Requirements
and Developing Life-Cycle Cost Estimates

The Prometheus 1 project office is required to develop preliminary
requirements by PMSR. Defining the project's requirements and developing
life-cycle cost estimates by then could be challenging, given the short
time frames and NASA's past difficulties developing requirements and
estimates. While it is not unusual for a project at this stage in
acquisition to still be defining requirements, several factors could make
it difficult for NASA to develop preliminary requirements by PMSR. The
contractor, Northrop Grumman, was only recently selected, and according to
project officials, input from both the contractor and Office of Naval
Reactors is needed to finalize the preliminary ground, space, and launch
systems requirements mandatory for PMSR. In addition, NASA continues to
refine its requirements. For example, Prometheus 1 project management
increased requirements for reactor lifetime, reactor power, and propellant
tank capacity to ensure that the Prometheus 1 spacecraft and reactor
designs could be used to support follow-on missions. Currently, project
managers are working with broad NASA requirements for deep space
exploration and more refined project requirements specific to the
Prometheus 1 ground, space, and launch systems.

NASA is also required to have an initial life-cycle cost estimate for
Prometheus 1 at PMSR.6 However, because the estimate is based on a
conceptual design, preliminary system requirements, and detailed
technology development plans that are not yet complete, it will be
difficult for NASA to develop an estimate in the short time available by
PMSR.

The project office is working with Northrop Grumman to merge and finalize
the conceptual design. Once the conceptual design is finalized, the
project office will update the work breakdown structure7 and develop a
"grass roots" estimate of the spacecraft cost. However, project officials
do not expect to receive cost estimates from the Office of Naval Reactors
and Northrop Grumman, which are also needed to develop the estimate, until
the end of February 2005. The JPL Costing Office will prepare a separate
cost estimate based on its experiences with prior programs, and both JPL
and NASA will contract for additional independent cost estimates.

6NASA guidance requires that life-cycle costs be estimated, assessed, and
controlled throughout a program's life cycle. The estimates are to be
prepared to support major program reviews and the development of budget
submissions.

7A work breakdown structure is a product oriented division of hardware,
software, services and project unique tasks that organizes and defines the
product to be developed and serves as the basis for estimating both cost
and schedule.

Adding to these complexities, NASA has historically had difficulty
establishing life-cycle cost estimates. In May 2004, we reported that
NASA's basic cost-estimating processes-an important tool for managing
programs-lack the discipline needed to ensure that program estimates are
reasonable.8 Specifically, we found that 10 NASA programs that we reviewed
in detail did not meet all of our cost-estimating criteria-based on
criteria developed by Carnegie Mellon University's Software Engineering
Institute. Moreover, none of the 10 programs fully met certain key
criteria-including clearly defining the program's life cycle to establish
program commitment and manage program costs, as required by NASA. In
addition, only three programs provided a breakdown of the work to be
performed. Without this knowledge, we reported that the programs'
estimated costs may be understated and thereby subject to underfunding and
cost overruns, putting programs at risk of being reduced in scope or
requiring additional funding to meet their objectives. In this report we
recommended that NASA take a number of actions to improve its cost
estimating practices. NASA concurred noting that our recommendations
validated and reinforced the importance of activities underway at NASA.

Business Case Allows Match of Needs to Resources and Facilitates Informed
Decision Making

By PDR-which occurs at end of the preliminary design phase and is
scheduled for 2008-the fidelity of the information is expected to improve
and could allow NASA to develop a business case that would match
requirements with resources and provide decision makers with the
information needed to determine whether continued investment in the
project is warranted. However, in the past NASA has had difficulties
developing the realistic requirements and cost estimates needed to develop
a sound business case.

To help ensure program requirements do not outstrip resources, leading
commercial firms obtain the right knowledge about a new product's
technology, design, and production at the right time. We have issued a
series of reports9 on the success these firms have had in estimating the
time and money to develop new and more sophisticated products-the kinds of
results that NASA seeks. Our best practice work has shown that developing
business cases based on matching requirements to resources

8GAO, NASA: Lack Of Disciplined Cost Estimating Processes Hinders
Effective Program Management, GAO-04-642 (Washington, D.C.: May 28, 2004).

9GAO, Best Practices: Better Matching of Needs and Resources Will Lead to
Better Weapon System Outcomes, GAO-01-288 (Washington, D.C.: Mar. 8,
2001).

before program start leads to more predictable program outcomes-that is,
programs are more likely to be successfully completed within cost and
schedule estimates and deliver anticipated system performance.

Figure 3: Prometheus 1 Milestone Reviews

The decision whether
or not to fund the
preliminary design A clear business
phase is based on case is needed for

this review. this review.

                     Preliminary mission and system review

o  Preliminary requirements

o  Preliminary life-cycle cost estimate

Source: GAO.

Preliminary design review

o  Final requirements

o  Final life-cycle cost estimate

A sound business case includes the following elements-well-defined
requirements, a preliminary design, realistic cost estimates, and mature
technology. While NASA does not require projects to develop a formal
business case based on matching requirements to resources, JPL policy,
which implements NASA policy, does require projects to develop
documentation that could support formulation of a sound business case.
Before a JPL project enters the preliminary design phase, JPL project
implementation policy requires that the project develop preliminary
requirements, a conceptual design, realistic cost estimates, and
technology development plans. This policy also requires that the fidelity
of information in these documents improve by PDR.

The requirements and resource estimates NASA is developing for PMSR could
form the basis for an initial business case based on matching Prometheus 1
requirements to available resources. However, Prometheus 1 project
management plans to continue directing requirements changes to accommodate
follow-on missions. While our work shows that the preliminary design phase
is the appropriate place to conduct systems engineering to support
requirement/cost trade-off decisions, NASA needs to remain cognizant that
adding requirements could increase cost and risk. In addition, NASA has
had past difficulty developing the realistic requirements and cost
estimates needed to develop a sound business case. These difficulties have
resulted in the termination of several major efforts

after significant investment of resources. For example, in 2002 NASA
terminated the Space Launch Initiative (SLI) program-a $4.8 billion,
5-year program to build a new generation of space vehicles to replace its
aging space shuttle. SLI was a complex and challenging endeavor for NASA,
both technically and from a business standpoint. The SLI program faced
some of the same challenges that Prometheus 1 is struggling with today,
such as the need to develop and advance new airframe and propulsion
technologies. SLI did not achieve its goals, in part, because NASA did not
develop realistic requirements and cost estimates.

Leading firms make an important distinction between technology development
and product development. Technologies that are not mature continue to be
developed in the technology base-they are not included in a product
development. Our best practices work has also shown that there is a direct
relationship between the maturity of technologies and the accuracy of cost
and schedule estimates. NASA's Prometheus 1 technologies are currently
immature. The Prometheus 1 project office is preparing technology
development plans to guide the development of each key technology during
the preliminary design phase.

NASA's Plans to Ensure Mature Technologies Rely on Prototype
Demonstrations

Mature Technologies Are Key to Minimizing Risk

Maturing technologies during the preliminary design phase is a key element
of matching needs to resources before entering the product development
phase. Our best practices work has shown that technology readiness
levels10 (TRL)-a concept developed by NASA-can be used to gauge the
maturity of individual technologies (see fig. 4).11 (See app. I for
detailed definition of TRLs.) Specifically, TRL 6-demonstrating a
technology as a fully integrated prototype in a realistic environment-is
the level of maturity needed to minimize risks for space systems entering
product development.

10Technology readiness levels characterize the readiness of technologies
for handoff to project implementers. Nine levels are defined representing
concepts from fundamental research level through technologies fully
qualified and demonstrated in flight.

11GAO, Best Practices: Using a Knowledge-Based Approach to Improve Weapon
Acquisition, GAO-04-386SP (Washington D.C.: January 2004).

Figure 4: Technology Maturity Levels for Product Development

Readiness level Risk level

Low High

                        8 9 High Technology unproven Low

Source: GAO.

While development of Prometheus 1 critical technologies is under way, the
technologies will require extensive advancement before they are mature
enough to provide the revolutionary capabilities of the Prometheus 1
spacecraft. The overall technology objective for Prometheus 1 is to safely
develop and operate a spacecraft with a nuclear-reactor-powered electric
propulsion system. To achieve this objective, the spacecraft will require
advancement in several technology areas, including, nuclear electric
power, power conversion and heat rejection systems, nuclear electric
propulsion, high power communications, radiation-hardened electronics, and
AR&D. (See app. II for a more detailed explanation of these technologies.)
NASA's fiscal year 2005 budget request indicates that these technologies
are either at TRL 3 (individual technologies have been demonstrated in a
laboratory environment) or TRL 4 (system components have been demonstrated
in a laboratory environment). Before NASA conducts the PDR in 2008, it
will need to mature the technologies-each of which comes with a unique set
of engineering challenges.

To gauge the maturation of the Prometheus 1 technologies, the Prometheus 1
project office is preparing technology development plans, which rely on
the use of maturity criteria tables (MCT), a concept similar

to TRLs.12 The specific maturation criteria for each technology vary
greatly, but all technologies are to be matured by PDR to the point that

o  developmental models are complete,

o  all major risks to each technology are retired,

o  all major manufacturing issues are resolved, and

o  	plans for obtaining life data that will provide confidence that the
hardware will meet the mission lifetime requirements are in hand.

Prometheus 1 project officials believe these criteria roughly correspond
to a TRL 5 (component and/or breadboard validation in a relevant
environment) or a TRL 6 (system/subsystem model or prototype demonstration
in a relevant environment). The program office's position is that using
MCTs that are equivalent to TRL 5 and TRL 6 at PDR is appropriate because
the program office is both the technology developer and product developer
and, as such, has a thorough understanding of how mature the technologies
need to be at certain points in time as the program progresses.
Nevertheless, the dual role of project office as both technology and
product developer is not unique, and our best practices body of work shows
that a TRL 6 is the level of maturity needed to minimize risks for space
systems entering product development.

                                  Conclusions

NASA is quickly approaching one of the most critical phases in its
acquisition of Prometheus 1-the preliminary design phase. While the
impetus for the changes made to the program-subsequent to our providing a
draft of this report to NASA for comment-recognize the technical,
schedule, and operational risk of this program, there is still much work
to be done. Based on the information presented at PMSR, now scheduled for
summer 2005, NASA will need to decide at what level to fund the project.
However, NASA will be challenged to develop the information required at
PMSR, given the compressed time frames. Although PDR is still several
years out, NASA will face significant challenges in meeting this
milestone, given the immaturity of the revolutionary technologies that
NASA anticipates will be needed to

12According to the Prometheus project office, the MCT [system], [also
developed by NASA], is an improvement over the TRL [system] because MCT
definitions are more detailed and quantifiable and, therefore, provide
more clarity to technology developers, managers, and independent
reviewers. Project office officials also note that the criteria in the
tables have been reviewed through an independent peer assessment to
validate that they provide the comprehensive set of measurements that need
to be made to verify that a particular maturity has been met in a specific
technology.

successfully launch Prometheus 1. While NASA is developing well-defined
criteria tables for maturing Prometheus 1 technologies, the many inherent
unknowns in developing technologies frequently results in unanticipated
difficulties and delays. NASA's current policy does not require projects
to develop knowledge-based business cases that match requirements to
available resources and include controls to ensure that sufficient
knowledge has been attained and therefore the agency had not planned to
develop such a business case for Prometheus 1. We have found, however,
that establishing a formal business case based on a knowledge-based
approach that includes matching requirements and available resources-
which include technical and engineering knowledge, time and funding- and
controls to ensure that sufficient knowledge has been attained at critical
junctures within the product development process is an essential part of
any product development justification. The risk associated with failing to
meet these challenges is considerable. If NASA decides to move forward
without adequate information at PMSR-that matches requirements and
available resources and provides NASA decision makers with a clear
understanding of Prometheus 1's potential return on investment-Prometheus
1 may be unable to compete for funding within NASA. Ultimately, NASA could
find, as it has in the past, that the program must be cancelled after
having invested millions of dollars.

Recommendations for 	We recommend that the NASA Administrator take the
following two actions:

Executive Action

o

o

identify at PMSR the level of resources the agency is committing to the
project and direct project officials to develop project requirements based
on this resource constraint and

ensure that prior to proceeding beyond PDR (currently planned for 2008) a
sound business case is established which includes confirmation that (1)
critical technologies have been successfully demonstrated as mature, (2)
systems engineering has been conducted to support requirements/cost
trade-off decisions, (3) requirements and resource estimates have been
updated based on the results of the preliminary design phase, (4)
knowledge based criteria are established at each critical juncture to
ensure that relevant product development knowledge is captured, and (5)
decision reviews are held to determine that appropriate knowledge was
captured to allow a move to the next phase.

Agency Comments

In written comments on a draft of this report, NASA's Deputy Administrator
stated that the agency concurs with the recommendations, adding that the
recommendations validate and reinforce the importance of activities
underway at NASA to improve NASA's management of complex technical
programs.

Subsequent to our draft report being provided to NASA for comment,
significant changes were made to the Prometheus 1 project. NASA's fiscal
year 2006 budget request includes changes to the Prometheus 1 project that
directly address the recommendations in this report. According to NASA's
budget justification, the agency is planning a less complex mission than
the original JIMO mission. According to program officials who we consulted
with following the release of the budget, eliminating the long reactor
lifetime, stringent radiation hardening, multiple launches, and AR&D
required for the JIMO mission will allow NASA "to walk before it runs" and
significantly reduce cost and technical risks. As a result, NASA has
delayed PMSR until summer 2005 and is conducting an analysis of
alternatives to identify a relevant mission with reduced technical,
schedule, and operational risk. The fiscal year 2006 budget request also
reshapes the Prometheus 1 funding profile to provide an orderly increase
in developmental activities.

Notwithstanding agreement with our recommendations, the Deputy
Administrator stated that NPR 7120.5B requires projects to develop a
business case. As we noted in this draft report, we recognize that NASA
policy requires the development of elements that could support the
formulation of a knowledge-based business case. However, we found no
explicit requirement within NPR 7120.5B for NASA projects to develop a
business case of any kind. More importantly, while NPR 7120.5B does
require that projects establish controls to monitor performance against
cost, schedule, and performance baselines and to conduct reviews
throughout the project's lifecycle, it does not establish specific
knowledgebased controls to ensure that the knowledge necessary to match
resources to requirements is in hand before moving forward. For example,
whereas NPR 7120.5B requires projects to conduct a preliminary design
review before entering NASA's implementation phase, i.e., product
development, it does not establish knowledge-based criteria to ensure that
technologies needed to meet essential product requirements have been
demonstrated to work in a realistic environment. Likewise, NASA policy
requires a critical design review during a project's implementation phase
but does not include knowledge-based criteria to ensure the design is
stable. We have found that such knowledge-based criteria, when tied to
major events on a program's schedule, can disclose whether gaps or
shortfalls exist in

demonstrated knowledge, which can presage future cost, schedule and
performance problems.

In his comments, the Deputy Administrator also noted that the Exploration
Systems Mission Directorate is in the process of initiating a number of
reforms to its project management policies and specified formulation dates
in the coming months. He outlined these reforms and explained how they
will allow NASA to address the recommendations in our report. We are
encouraged by these planned changes. If properly implemented, they could
be positive steps toward implementing a knowledge-based approach to
project management.

The Deputy Administrator also requested that the relationship between JPL
and NASA project management requirements be explicitly stated in the
report. We moved the information from a footnote into the body of the
report to clarify that relationship. We also addressed NASA's technical
comments as appropriate throughout the report.

To determine whether NASA is establishing justification for the project
and ensuring critical technologies are mature, we conducted interviews
with NASA Exploration Systems Mission Directorate and Prometheus 1 project
officials at NASA Headquarters, Washington, D.C.; Marshall Space Flight
Center, Huntsville, Ala.; and the Jet Propulsion Laboratory, Pasadena,
Calif. We obtained and reviewed pertinent documents from the agency. We
conducted quantitative and qualitative analyses of project schedules, risk
assessments, budget documentation, technology maturity assessments and
technology development plans. We compared these documents to criteria
established in JPL and NASA policies governing developmental programs and
to criteria for a knowledge based approach to acquisition described in
GAO's best practices body of work. We discussed key project challenges
with Prometheus 1 project officials, and conducted GAO team meetings to
discuss analyses and developing issues. Our audit work was completed
between April 2004 and January 2005.

Scope and

                                  Methodology

As agreed with your office, unless you announce its contents earlier, we
will not distribute this report further until 30 days from its issuance
date. At that time, we will send copies to the NASA Administrator and
interested congressional committees. We will make copies available to
others upon request. In addition, the report will be available at no
charge on the GAO web site at http://www.gao.gov.

If you or your staff have any questions concerning this report, please
contact me at (202) 512-4841 or [email protected]. Key contributors to this
report are acknowledged in appendix IV.

Allen Li
Director
Acquisition and Sourcing Management

Appendix I: Technology Readiness Levels Definitions

Hardware and Demonstration Technology readiness level Description software
environment

1. Basic principles observed and Lowest level of technology readiness.
None None

reported. Scientific research begins to be translated (Paper studies and
into applied research and development. analysis) Examples might include
paper studies of a technology's basic properties.

2. Technology concept Invention begins. Once basic None               None 
and/or                              principles are                    
application           observed, practical          (Paper studies and 
formulated.           applications can be                             
                         invented. The application is analysis)          
                         speculative                                     
                             and there is no proof or                    
                                 detailed analysis to                    
                         support the assumption.                         
                         Examples are still                              
                         limited to paper studies.                       

3. Analytical and        Active research and            Analytical studies 
experimental             development is                            and Lab 
critical function and/or initiated. This includes    demonstration of      
                            analytical studies          nonscale              
characteristic proof of  and laboratory studies to   individual components 
concept.                 physically                  
                            validate analytical         (pieces of            
                            predictions of separate     subsystem).           
                            elements of the technology. 
                            Examples                    
                            include components that are 
                            not yet                     
                            integrated or               
                            representative.             

4. Component and/or Basic technological components are Low fidelity
breadboard. Lab breadboard. Validation in integrated to establish that the
pieces will Integration of nonscale laboratory environment. work together.
This is relatively "low fidelity" components to show

compared to the eventual system. pieces will work together. Examples
include integration of "ad hoc" Not fully functional or form hardware in a
laboratory. or fit but representative of

technically feasible approach suitable for flight articles.

5. Component and/or breadboard validation in relevant environment.

Fidelity of breadboard technology increases significantly. The basic
technological components are integrated with reasonably realistic
supporting elements so that the technology can be tested in a simulated
environment. Examples include "high fidelity" laboratory integration of
components.

High fidelity breadboard. Functionally equivalent but not necessarily form
and/or fit (size weight, materials, etc.). Should be approaching
appropriate scale. May include integration of several components with
reasonably realistic support elements/ subsystems to demonstrate
functionality.

Lab demonstrating functionality but not form and fit. May include flight
demonstrating breadboard in surrogate aircraft. Technology ready for
detailed design studies.

              Appendix I: Technology Readiness Levels Definitions

Hardware and Demonstration Technology readiness level Description software
environment

6. System/subsystem model or Representative model or prototype system,
Prototype-Should be High-fidelity lab prototype demonstration in a which
is well beyond the breadboard tested very close to form, fit and
demonstration or relevant environment. for TRL 5, is tested in a relevant
function. Probably limited/restricted flight

environment. Represents a major step up includes the integration of
demonstration for a in a technology's demonstrated readiness. many new
components relevant environment. Examples include testing a prototype in a
and realistic supporting Integration of technology high fidelity
laboratory environment or in elements/subsystems if is well defined.
simulated operational environment. needed to demonstrate

full functionality of the subsystem.

7. System prototype Prototype near or at planned operational Prototype.
Flight demonstration in demonstration in an operational system. Represents
a major step up from Should be form, fit and representative operational
environment. TRL 6, requiring the demonstration of an function integrated
with environment such as

actual system prototype in an operational other key supporting flying test
bed or environment, such as in an aircraft, vehicle elements/subsystems to
demonstrator aircraft. or space. Examples include testing the demonstrate
full Technology is well prototype in a test bed aircraft. functionality of
subsystem. substantiated with test

data.

8. Actual system completed and Technology has been proven to work in its
Flight qualified hardware DT&E in the actual "flight qualified" through
test and final form and under expected conditions. system application
demonstration. In almost all cases, this TRL represents the

end of true system development. Examples include developmental test and
evaluation of the system in its intended weapon system to determine if it
meets design specifications.

    9. Actual system  Actual application of the    Actual system      OT&E in 
    "flight proven"   technology in its            in final form  operational 
through successful final form and under                         mission    
        mission       mission conditions,                         conditions  
      operations.     such as those encountered                  
                      in operational                             
                        test and evaluation. In                  
                           almost all cases,                     
                      this is the end of the last                
                             "bug fixing"                        
                        aspects of true system                   
                             development.                        
                      Examples include using the                 
                      system under                               
                          operational mission                    
                              conditions.                        

                                  Source: GAO.

Appendix II: Prometheus 1 Critical Technologies

Nuclear Reactor

Power Conversion

Heat Rejection

The nuclear reactor is the key element of the Prometheus 1 spacecraft.
Without the power levels supplied by the reactor, the proposed propulsion,
science, and communication systems are not feasible. Designing,
constructing, and utilizing highly reliable, safe, portable nuclear
reactors is not new-nuclear reactors have been used in submarines for
almost 50 years. However, the United States has very little experience
operating nuclear reactors in a space environment and tackling space
unique nuclear application issues. The Office of Naval Reactors, the
organizational unit in the Department of Energy responsible for developing
nuclear reactors for the Navy, will be responsible for all portions of the
Prometheus 1 reactor development effort.

The space environment places significant weight constraints on the reactor
design and requires semi-autonomous control. Unlike submarines and
aircraft carriers, all spacecraft have serious weight constraints driven
by the cost of launching payloads into orbit. Consequently, spacecraft
designers put great effort into eliminating weight. Further, where
conventional reactors have hands on operators, the Prometheus 1 reactor
must be remotely controlled. NASA estimates that control communications
will take about 40 minutes to travel one way between Earth and the Jovian
system.

A power conversion system accepts the thermal energy from the reactor and
converts it to useful electrical power for the spacecraft. Power
conversion is an integral part of any power generation system taking the
form of steam turbine generators in terrestrial utility plants and nuclear
submarines. NASA is considering two types of power conversion
systems-dynamic and static. According to NASA, the dynamic systems under
consideration offer the benefits of increased efficiency, reduced weight
and mass, and decreased nuclear fuel requirements. The static systems,
however, have a technology heritage in prior spacecraft and could offer
increased reliability because they have no moving parts.

Since the conversion process in a fission reactor is never 100 percent
efficient, heat rejection is required to dissipate waste energy. This is
usually accomplished with large pumped-water cooling systems on earth.
Space based power conversion would require a large radiator system to
dissipate the waste heat in the vacuum of space. The requirement to fold
the large radiator system into the launch vehicle fairing and deploy it
after launch complicates the radiator system design. (See fig. 1.)

                Appendix II: Prometheus 1 Critical Technologies

Nuclear Electric Propulsion

Radiation Hardening

High Power Communications

Operating electric propulsion systems in space applications, including
deep space, is not new. There is extensive experience with electric
propulsion systems on satellites. In addition, NASA's Deep Space 1
spacecraft was propelled using an electric propulsion ion thruster,
similar in nature to the concept being developed for Prometheus 1. The
thruster power levels required by Prometheus 1 have been demonstrated in a
laboratory environment. The lifetime required by Prometheus 1, however,
has not been demonstrated. Furthermore, lifetime testing of existing ion
thrusters has demonstrated that these thrusters were approaching "wear out
failure"1 after 30,352 hours. The Prometheus 1 thrusters will need to be
qualified for operational durations approaching 120,000 hours. NASA
recognizes that they will have to develop models and accelerated aging
techniques to demonstrate the lifetime requirement.

All electronic components of the Prometheus 1 spacecraft must be radiation
hardened or shielded from radiation produced by the onboard nuclear
reactor and the harsh radiation environment of the Jovian system.
Shielding electronics and the science packages, requires a heavy metal or
some other material, which may not yet be developed, and increases the
weight and mass of the spacecraft. The additional weight used to shield
the spacecraft lessens the science payload package that can be taken
onboard for scientific data collection and research and increases the size
and power of the launch vehicle required to launch Prometheus 1 into earth
orbit

The nuclear reactor will provide increased electrical power for
communications. This translates to increased bandwidth and data rates. The
high power communications system onboard the Prometheus 1 spacecraft, will
provide tens of compact disks full of data back to earth. Analogous
missions such as Cassini provide only a couple of floppy disks full of
data. (A floppy disk typically holds about 1.44 MB of data. A compact disk
typically holds about 700 MB of data.) According to project officials, the
higher power communications system on the Prometheus 1 spacecraft will
require upgrades to the Deep Space Network, which are out of the purview
of the Prometheus 1 project.

1 Wear out failure is the point at which a system stops operating because
its mechanical or physical parts are worn to the point they will no longer
function.

Appendix II: Prometheus 1 Critical Technologies

Autonomous Rendezvous and Docking

There is no launch vehicle in the present or proposed U.S. inventory
capable of launching the Prometheus 1 spacecraft, conceived for a mission
to Jupiter's Icy Moons, into orbit in one piece. The conceptual design
currently shows the Prometheus 1 spacecraft to weigh between 29 and 36
metric tons and be about 58 meters in length. The current concept is to
use multiple launches, 2 to 5, to place the spacecraft components in orbit
and to use AR&D technology to assemble the spacecraft in orbit. Prometheus
1 is relying on NASA's Demonstration Autonomous Rendezvous Technology and
Hubble Robotic Servicing Mission, and the Defense Advanced Research
Projects Agency's Orbital Express programs for AR&D technology. These
programs use different sensors and approaches to AR&D thereby providing
Prometheus 1 with various options for consideration.

Appendix III: Comments from the National Aeronautics and Space
Administration

Appendix III: Comments from the National Aeronautics and Space
Administration

Appendix III: Comments from the National Aeronautics and Space
Administration

Appendix III: Comments from the National Aeronautics and Space
Administration

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact Allen Li, (202) 512-4841

Acknowledgments 	In addition to the contact named above, James Morrison,
Jerry Herley, John Warren, Tom Gordon, Ruthie Williamson, Karen Sloan and
Sylvia Schatz made key contributions to this report.

GAO Related Products

Best Practices: Using a Knowledge-Based Approach to Improve Weapon
Acquisition, GAO-04-386SP. Washington, D.C.: January 2004.

Best Practices: Setting Requirements Differently Could Reduce Weapon
Systems' Total Ownership Costs. GAO-03-57. Washington, D.C.:
February 11, 2003.

Defense Acquisitions: DOD's Revised Policy Emphasizes Best Practices,
but More Controls Are Needed. GAO-04-53. Washington, D.C.:
November 10, 2003.

Best Practices: Capturing Design and Manufacturing Knowledge
Early Improves Acquisition Outcomes. GAO-02-701. Washington, D.C.:
July 15, 2002.

Defense Acquisitions: DOD Faces Challenges in Implementing Best
Practices. GAO-02-469T. Washington, D.C.: February 27, 2002.

Best Practices: Better Matching of Needs and Resources Will Lead to
Better Weapon System Outcomes. GAO-01-288. Washington, D.C.:
March 8, 2001.

Best Practices: A More Constructive Test Approach Is Key to Better
Weapon System Outcomes. GAO/NSIAD-00-199. Washington, D.C.:
July 31, 2000.

Defense Acquisition: Employing Best Practices Can Shape Better
Weapon System Decisions. GAO/T-NSIAD-00-137. Washington, D.C.:
April 26, 2000.

Best Practices: DOD Training Can Do More to Help Weapon
System Program Implement Best Practices. GAO/NSIAD-99-206.
Washington, D.C.: August 16, 1999.

Best Practices: Better Management of Technology Development
Can Improve Weapon System Outcomes. GAO/NSIAD-99-162.
Washington, D.C.: July 30, 1999.

Defense Acquisitions: Best Commercial Practices Can Improve Program
Outcomes. GAO/T-NSIAD-99-116. Washington, D.C.: March 17, 1999.

Defense Acquisition: Improved Program Outcomes Are Possible.
GAO/T-NSIAD-98-123. Washington, D.C.: March 18, 1998.

GAO Related Products

Best Practices: DOD Can Help Suppliers Contribute More to Weapon System
Programs. GAO/NSIAD-98-87. Washington, D.C.: March 17, 1998.

Best Practices: Successful Application to Weapon Acquisition Requires
Changes in DOD's Environment. GAO/NSIAD-98-56. Washington, D.C.: February
24, 1998.

Major Acquisitions: Significant Changes Underway in DOD's Earned Value
Management Process. GAO/NSIAD-97-108. Washington, D.C.: May 5, 1997.

Best Practices: Commercial Quality Assurance Practices Offer Improvements
for DOD. GAO/NSIAD-96-162. Washington, D.C.: August 26, 1996.

GAO's Mission	The Government Accountability Office, the audit, evaluation
and investigative arm of Congress, exists to support Congress in meeting
its constitutional responsibilities and to help improve the performance
and accountability of the federal government for the American people. GAO
examines the use of public funds; evaluates federal programs and policies;
and provides analyses, recommendations, and other assistance to help
Congress make informed oversight, policy, and funding decisions. GAO's
commitment to good government is reflected in its core values of
accountability, integrity, and reliability.

Obtaining Copies of The fastest and easiest way to obtain copies of GAO
documents at no cost

is through GAO's Web site (www.gao.gov). Each weekday, GAO postsGAO
Reports and newly released reports, testimony, and correspondence on its
Web site. To Testimony have GAO e-mail you a list of newly posted products
every afternoon, go to

www.gao.gov and select "Subscribe to Updates."

Order by Mail or Phone	The first copy of each printed report is free.
Additional copies are $2 each. A check or money order should be made out
to the Superintendent of Documents. GAO also accepts VISA and Mastercard.
Orders for 100 or more copies mailed to a single address are discounted 25
percent. Orders should be sent to:

U.S. Government Accountability Office 441 G Street NW, Room LM Washington,
D.C. 20548

To order by Phone:	Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202)
512-6061

To Report Fraud, Contact:
Waste, and Abuse in Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: [email protected] Programs Automated answering system: (800)
424-5454 or (202) 512-7470

Congressional	Gloria Jarmon, Managing Director, [email protected] (202)
512-4400 U.S. Government Accountability Office, 441 G Street NW, Room 7125

Relations Washington, D.C. 20548

Public Affairs	Paul Anderson, Managing Director, [email protected] (202)
512-4800 U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, D.C. 20548
*** End of document. ***