Electronic Rulemaking: Progress Made in Developing Centralized	 
E-Rulemaking System (09-SEP-05, GAO-05-777).			 
                                                                 
The E-Government Act of 2002 requires regulatory agencies, to the
extent practicable, to ensure there is a Web site the public can 
use to comment on the numerous proposed regulations that affect  
them. To accomplish this, the Office of Management and Budget	 
named the Environmental Protection Agency (EPA) as the managing  
partner for developing a governmentwide e-Rulemaking system that 
the public can use for these purposes. Issues GAO was asked to	 
address include: (1) EPA's basis for selecting a centralized	 
system, (2) how EPA collaborated with other agencies and agency  
views of that collaboration, and (3) whether EPA used key	 
management practices when developing the system.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-777 					        
    ACCNO:   A36200						        
  TITLE:     Electronic Rulemaking: Progress Made in Developing       
Centralized E-Rulemaking System 				 
     DATE:   09/09/2005 
  SUBJECT:   Centralization					 
	     Cost effectiveness analysis			 
	     E-government					 
	     Federal regulations				 
	     Interagency relations				 
	     Policy evaluation					 
	     Proposed legislation				 
	     Public relations					 
	     Regulatory agencies				 
	     Systems design					 
	     Websites						 
	     Cost estimates					 

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GAO-05-777

United States Government Accountability Office

GAO	Report to the Chairman and Ranking Minority Member, Committee on

            Homeland Security and Governmental Affairs, U.S. Senate

September 2005

                                   ELECTRONIC
                                   RULEMAKING

          Progress Made in Developing Centralized E-Rulemaking System

                                       a

GAO-05-777

[IMG]

September 2005

ELECTRONIC RULEMAKING

Progress Made in Developing Centralized E-Rulemaking System

                                 What GAO Found

E-Rulemaking officials and the e-Rulemaking Initiative Executive Committee
considered three alternative designs and chose to implement a centralized
e-Rulemaking system based on cost savings, risks, and security. Officials
relied on an analysis of the three alternatives using two cost and risk
assessment models and a comparison of the alternatives to industry best
practices. Prior to completing this analysis, officials estimated the
centralized approach would save about $94 million over 3 years. They said
when they developed this estimate, there was a lack of published
information about costs related to paper or electronic rulemaking systems.
They used their professional judgment and information about costs for
developing and operating EPA's paper and electronic systems, among other
things, to develop the estimate.

E-Rulemaking officials extensively collaborated with rulemaking agencies
and most officials at the agencies we contacted thought the collaboration
was effective. E-Rulemaking officials created a governance structure that
included an executive committee, advisory board, and individual work
groups that discussed how to develop the e-Rulemaking system. We contacted
14 of the 27 agencies serving on the advisory board and most felt their
suggestions affected the system development process. Agency officials
offered several examples to support their views, such as how their
recommendations for changes to the system's design were incorporated.

While managing the development of the centralized system, e-Rulemaking
officials followed all but a few of the key practices for successfully
managing an initiative. For example, officials did not have written
agreements with participating agencies that included system performance
measures. The first agencies began migrating to the centralized system in
May 2005 with the public scheduled to have access in September 2005.
Eventually, all rulemaking agencies will migrate to the centralized
system; however, the schedule is tentative due in part to funding issues.
As agencies migrate, e-Rulemaking officials are planning changes to the
system including adding capabilities that exist in electronic systems
operated by some agencies.

Centralized e-Rulemaking Process United States Government Accountability Office

Contents

    Letter                                                                  1 
                                  Results in Brief                          3 
                                     Background                             5 
              Officials Considered Three E-Rulemaking Designs and Chose a 

Single, Centralized Design Based on Cost, Deployment Risks, and Security 8
Agencies Generally Expressed Satisfaction with E-Rulemaking Officials'
Efforts to Solicit Their Input 13 Work Conducted Mostly Consistent with
Key Practices but Written

Agreements Did Not Include Performance Measures 15 Conclusions 21
Recommendation 21 Agency Comments 22

Appendixes

Appendix I: Objectives, Scope, and Methodology 23 Appendix II: List of GAO
           Reports Related to E-Rulemaking 26 Appendix III: Comments from the
                                           Environmental Protection Agency 28

Table Table 1:	Key Practices E-Rulemaking Officials Followed or Did Not
Follow When Managing the Development of the Centralized E-Rulemaking
System

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separately.

A

United States Government Accountability Office Washington, D.C. 20548

September 9, 2005

The Honorable Susan M. Collins
Chairman
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Joseph I. Lieberman
Ranking Minority Member
Committee on Homeland Security and Governmental Affairs
United States Senate

Each year, federal agencies publish thousands of regulations that affect
many aspects of citizens' lives. The regulatory process allows the public
to
play a role in the promulgation of rules, primarily by requiring agencies
to
publish proposed rules for public comment in accordance with the
Administrative Procedure Act of 1946, as amended. However, in order to
be effectively involved, the public needs to know whether a proposed rule
is open for comment. Modern information technology holds the potential
to make it easier than ever before to inform the public whether proposed
rules are open for comment. Technology can also improve the federal
government's ability to analyze and respond to those comments.

Since 2001, several legislative and executive branch initiatives have
encouraged public participation in rulemaking. Notably, the E-Government
Act of 20021 included provisions designed to encourage electronic
rulemaking and the administration identified electronic rulemaking as one
of many electronic government initiatives. The first module of the
e-Rulemaking initiative resulted in a governmentwide Web site at
www.regulations.gov, which enables the public to find and submit
comments on federal rules that are open for comment and published in the
Federal Register.2 The goal of the second module of the e-Rulemaking
initiative is to establish a governmentwide electronic docket management
system into which all relevant regulatory supporting materials and public
comments will be placed.

1Pub. L. No. 107-347, 116 Stat. 2899 (Dec. 17, 2002).

2GAO, Electronic Rulemaking: Efforts to Facilitate Public Participation
Can Be Improved, GAO-03-901 (Washington, D.C.: Sept. 17, 2003).

While the Office of Management and Budget (OMB) oversees the e-Rulemaking
initiative, it named the Environmental Protection Agency (EPA) managing
partner for the initiative.3 As managing partner, EPA heads the Program
Management Office (PMO), which is staffed by officials from several
rulemaking agencies participating in this initiative. The PMO staff
manages the day-to-day activities of the e-Rulemaking initiative while the
e-Rulemaking Initiative Executive Committee oversees the initiative's
strategy, resources, and timetable.4 Hereafter, we refer to PMO officials
as e-Rulemaking officials.

In response to your request that we continue to monitor the status of the
second module of the e-Rulemaking initiative, this report focuses on:

o 	the approach EPA used to identify alternative designs for the
e-Rulemaking system, and how the decision to proceed with a single,
centralized e-Rulemaking system rather than another alternative design was
made;

o 	how EPA collaborated with other rulemaking agencies to obtain input
about the e-Rulemaking system and those agencies' views regarding the
collaboration; and

o 	whether key practices for successfully managing a project have been
utilized by EPA and EPA's future plans for developing and implementing the
centralized e-Rulemaking system.

To address our objectives, we reviewed relevant federal legislation;
capital asset and business cases developed for the e-Rulemaking
initiative; contractor assessments regarding the capabilities of existing
electronic rulemaking systems and the three alternative designs considered
for the e-Rulemaking system; and documents related to the roles and
responsibilities of OMB, e-Rulemaking officials, the Executive Committee,
and federal rulemaking agencies for the design and implementation of the
e-Rulemaking initiative. We also interviewed OMB, e-Rulemaking officials,
and officials from several rulemaking agencies involved in the

3OMB originally named the Department of Transportation as managing
partner, but transferred managing partner responsibilities to EPA in late
2002. Details about the transfer are provided in the background section of
this report.

4Details about the e-Rulemaking Initiative Executive Committee are
provided in this report in the section discussing collaboration.

e-Rulemaking initiative. To identify key practices for successfully
managing a project we reviewed previous GAO work related to the
e-government initiatives, which was based in part upon reviews of
government, private sector, and academic research. We compared information
provided by e-Rulemaking officials to these key practices to determine
what practices they appeared to have engaged in as part of managing the
e-Rulemaking initiative. Our analysis was limited to a determination
concerning the presence of the practice. We did not assess how well or
extensively the practice was followed. We performed our work from December
2003 through June 2005 in accordance with generally accepted government
auditing standards. Our scope and methodology are described in more detail
in appendix I.

Results in Brief	E-Rulemaking officials and the e-Rulemaking Initiative
Executive Committee considered three alternative designs for its
electronic docket management system and ultimately chose to develop and
implement a single, centralized e-Rulemaking system based on potential
cost savings, deployment risks, and security. The other two alternative
designs considered were a tiered design and a distributed design.5 In
making the decision, officials relied on an analysis of the three
alternatives prepared by a contractor using two cost and risk assessment
models and a comparison of the three alternatives to industry best
practices. This analysis showed that one major advantage of the
centralized design is that it uses a minimal number of governmentwide
e-Rulemaking system components in the same location to provide consistent
access and services for citizens and agency staff across all dockets.
Prior to the completion of the analysis of the three alternatives,
e-Rulemaking officials estimated that the centralized approach would save
about $94 million over 3 years by eliminating duplicate systems and annual
maintenance fees. Officials said that at the time they developed this
estimate, there was a lack of published information about how much it cost
to develop or operate paper or electronic rulemaking systems. They
primarily used their professional judgment, information about costs for
developing and operating EPA's

5The centralized design has system components in the same location for
delivery of services to agencies and the public. The tiered design is a
combination of the centralized and distributed designs-some components are
centrally located and some components are located elsewhere. The
distributed design has standard centralized components integrated with
agency-specific electronic docket systems. The three designs are described
in more detail in another section of this report.

paper and electronic rulemaking systems, and information provided by OMB
about the number of rulemaking entities to develop the estimate.

E-Rulemaking officials extensively collaborated with rulemaking agencies,
and most officials at the agencies we contacted described the
collaboration as effective. E-Rulemaking officials established a
governance structure that included an executive committee, an advisory
board with representatives of 27 agencies, and smaller work groups, all of
which met to develop recommendations about how the system should be
developed and implemented. We contacted 14 of the 27 agencies serving on
the advisory board and most said their suggestions were taken into account
in the development and implementation of the e-Rulemaking system. Agency
officials we interviewed offered examples of how their recommendations for
changes to the system's design were incorporated. For example, changes
were made to the system after one agency expressed concerns related to
interim rules. E-Rulemaking officials also held public forums to obtain
perspectives from potential users of the e-Rulemaking system regarding its
design to ensure their needs were also considered.

While managing the development of the centralized e-Rulemaking system,
e-Rulemaking officials, for the most part, have followed key practices for
managing a project; however, there are a few practices they did not
incorporate into their management of the initiative. Examples of key
practices they followed include preparing a complete business case;
developing a strategy for determining the amount of financial assistance
agencies should provide; establishing criteria for cost, schedule, and
performance; and preparing plans that address collaboration, obtaining
user input, and methods for keeping those affected by the initiative
informed about new developments. On the other hand, officials did not
document completely how they identified alternative designs for the
e-Rulemaking system and did not have written agreements with participating
agencies that include system performance measures. The first agencies
began migrating to the e-Rulemaking system in May 2005 and the public is
scheduled to be able to access the system in September 2005. Eventually,
all rulemaking agencies will migrate to the system; however, the migration
schedule for the remaining agencies is tentative at this point, due in
part to

funding issues.6 As agencies migrate, officials said they plan to make
changes to the system based on issues identified by the agencies and the
public. Although officials have indicated that they intend to build
additional capabilities into the system to address the needs of agencies
whose existing systems have capabilities not found in the current version
of the e-Rulemaking system, a couple of agencies expressed concerns about
whether the capabilities they have in their current electronic systems
will be included.

To learn from this initiative and to build on the success of it, we
recommend the Administrator of EPA, as managing partner of the initiative,
take steps to ensure that written agreements between EPA and the
participating agencies include performance measures that address issues
such as system performance, maintenance, and cost savings. These measures
are necessary to provide criteria for evaluating the effectiveness of the
e-Rulemaking initiative as well as for determining if the initiative is
operating in the most efficient and economical manner. The Administrator
of EPA was provided a draft of this report for his review and comment. The
EPA Assistant Administrator and Chief Information Officer responded that
e-Rulemaking officials appreciated GAO's recommendation to ensure the
effectiveness of the initiative and e-Rulemaking officials said they agree
with GAO's recommendation and plan to implement it.

Background 	For many years, federal agencies have been encouraged to use
information technology to improve their communications with the public and
to increase participation in the rulemaking process. One of the
recommendations of the National Performance Review in September 1993 was
to "[u]se information technology and other techniques to increase
opportunities for early, frequent, and interactive public participation
during the rulemaking process ..."7 The Paperwork Reduction Act of 1995
states that the Director of OMB should promote the use of IT "to improve
the

6For a more in-depth analysis of funding issues related to the
e-Rulemaking initiative, see GAO, Electronic Government: Funding of the
Office of Management and Budget's Initiatives, GAO-05-420 (Washington,
D.C.: Apr. 25, 2005).

7From Red Tape to Results: Creating a Government That Works Better and
Costs Less, Report of the National Performance Review, September 7, 1993.

productivity, efficiency, and effectiveness of Federal programs..."8
Similarly, a December 17, 1999, presidential memorandum on "Electronic
Government" noted that "as public awareness and Internet usage increase,
the demand for online Government interaction and simplified, standardized
ways to access Government information and services becomes increasingly
important."9

Between June 2000 and February 2001, as information technology began to
play an increasingly important role in agencies' regulatory management and
the facilitation of public participation in federal rulemaking, we
reported on a number of associated opportunities and challenges.10 We
pointed out that the use of information technology could reduce regulatory
burden, improve the transparency of regulatory processes, and, ultimately,
facilitate the accomplishment of regulatory objectives. We reported on
innovative uses of information technology that representatives of federal
or state agencies and nongovernmental organizations believed could be more
widely used by federal regulatory agencies, and we recommended actions
that could facilitate innovation, avoid duplication of effort, and
potentially result in a broader and more consistent approach across
federal agencies.

The President, through the President's Management Agenda, has advanced
greater use of information technology across a range of government
functions, including rulemaking. In July 2001, the President identified
the expansion of e-government as one of the five priorities of his
management agenda. To support this, OMB has developed an implementation
strategy and identified 25 e-government initiatives, one of which is
e-Rulemaking. In May 2002, the Director of OMB issued a memorandum to the
heads of executive departments and agencies advising them of "our
intention to consolidate redundant IT systems relating to the President's
on-line rulemaking initiative."11 Citing OMB's authority under the
Clinger-Cohen

844 U.S.C. S: 3504(h)(5).

9Presidential Memorandum on Electronic Government (Dec. 17, 1999).

10See, for example, GAO, Federal Rulemaking: Agencies' Use of Information
Technology to Facilitate Public Participation, GAO/GGD-00-135R
(Washington, D.C.: June 30, 2000); Electronic Government: Government
Paperwork Elimination Act Presents Challenges for Agencies,
GAO/AIMD-00-282 (Washington, D.C.: Sept. 15, 2000); and Regulatory
Management: Communication About Technology-Based Innovations Can Be
Improved, GAO-01-232 (Washington, D.C.: Feb. 12, 2001).

11OMB Memorandum No. M-02-08, Redundant Information Systems Relating to
On-Line Rulemaking Initiative (Washington, D.C.: May 6, 2002).

Act of 1996, the Director said OMB had identified "several potentially
redundant systems across the federal government that relate to the
rulemaking process," and indicated that consolidation of those systems
could save millions of dollars. The administration said e-Rulemaking would
"democratize an often closed process."

In late 2002, the President signed into law the E-Government Act of
2002.12 The act requires agencies, to the extent practicable, to accept
public comments on proposed rules "by electronic means" and to ensure that
a publicly accessible federal Web site contains "electronic dockets" for
their proposed rules.13 The act also established an Office of Electronic
Government within OMB, headed by an Administrator appointed by the
President and required to work with the Administrator of OMB's Office of
Information and Regulatory Affairs in establishing the strategic direction
of the e-government program and to oversee its implementation.14

Initially, OMB named the Department of Transportation (DOT) as the lead
agency, or managing partner, for the e-Rulemaking effort, entrusting DOT
with the day-to-day management of the project as well as collaboration
with other e-Rulemaking agencies. In a previous report, we noted that "DOT
had the most developed electronic docket system of the agencies that we
contacted, covering every rulemaking action in the department and
including all public comments received regardless of medium."15 DOT served
as managing partner until an independent consultant's assessment concluded
in August 2002 that the system operated by EPA was the optimal platform to
serve as the consolidated electronic docket platform for the entire
federal government. As a result of this assessment, OMB transferred
managing partner responsibilities from DOT to EPA in late 2002.

12Pub. L. No. 107-347, 116 Stat. 2899 (Dec. 17, 2002).

13Id. at S: 206(d). As used in this report, a rulemaking "docket" is the
official repository for documents or information related to an agency's
rulemaking activities, and may include any public comments received and
other information used by agency decision makers.

1444 U.S.C. S: 3602. For a general discussion of the various e-Government
initiatives, including e-Rulemaking, see GAO-03-229, Electronic
Government: Selection and Implementation of the Office of Management and
Budget's 24 Initiatives (Washington, D.C.: Nov. 22, 2002).

15For more information on DOT's electronic docket system, see GAO, Federal
Rulemaking: Agencies' Use of Information Technology to Facilitate Public
Participation, GAO/GGD-00135R (Washington, D.C.: June 30, 2000).

The e-Rulemaking initiative provides a single portal for businesses and
citizens to access the federal rulemaking process and comment on proposed
rules. It is composed of three modules. The first module was completed in
January 2003 with the launch of the www.regulations.gov Web site.16 The
second module, which is the focus of this report, will move beyond rule
identification and a comment mechanism by establishing a governmentwide
electronic docket management system into which all relevant regulatory
supporting materials and public comments will be placed. The third and
final module will create an electronic regulatory desktop to facilitate
the rule development process.17

  Officials Considered Three E-Rulemaking Designs and Chose a Single,
  Centralized Design Based on Cost, Deployment Risks, and Security

E-Rulemaking officials and the e-Rulemaking Initiative Executive Committee
considered three alternative designs for the federal e-Rulemaking system
and ultimately chose to develop and implement a single, centralized
design. This decision was based upon studies that examined the costs,
deployment risks, and security aspects of the three designs. Throughout
the management of the e-Rulemaking initiative, e-Rulemaking officials have
estimated that the centralized design would save money; the latest
estimate is that it would save approximately $94 million over 3 years.
Officials said they used their best professional judgment and information
about the costs to develop and operate paper and electronic rulemaking
systems.

    Centralized, Tiered, and Distributed Designs Considered

E-Rulemaking officials and the e-Rulemaking Initiative Executive Committee
considered three designs for the system architecture of the governmentwide
e-Rulemaking system. These were a centralized, tiered, or a distributed
design. The key characteristics of the governmentwide e-Rulemaking system
architecture would:

o 	enable agencies to manage content and workflow processes using variable
access controls and role definitions;

o 	provide a robust and scaleable Web-based solution that supports the
capture, conversion, and dissemination of high volumes of information;

16For a more in-depth discussion of the www.regulations.gov Web site (the
first module of the e-Rulemaking initiative), see GAO-03-901.

17For a list of GAO reports related to e-Rulemaking, see app. II.

o 	provide the public and stakeholders with the ability to perform
electronic docket searching, viewing, and commenting across multiple
agencies; and

o 	minimize the total cost of system ownership and management while
delivering responsive service to agencies/subagencies, businesses, and
citizens.

Anyone with the ability to connect to the Internet with a standard
industry browser would be able to access the e-Rulemaking system.

Centralized design. The centralized design uses a minimal number of
governmentwide e-Rulemaking system components in the same location to
provide consistent access and services for citizens and agency staff
across all dockets. Under this design, the features and functions of the
governmentwide e-Rulemaking system are provided by component-based
application architecture and all standard components are centrally
located. These application components would reside on servers in a single
location for delivery of services to the public and the agencies. Unlike
the tiered and distributed designs, which are discussed in the next
sections, the centralized design will not support existing agency docket
systems nor will it distribute components of the governmentwide
e-Rulemaking system in agency facilities.

Tiered design. The tiered design utilizes a centralized governmentwide
e-Rulemaking system to deliver all agency and citizen services, but is
different from the centralized design because common hardware and software
components installed in the governmentwide e-Rulemaking system are also
installed at different agency sites to enhance system performance. For
example, components like the database management or document management
system may be placed on separate servers in the same or different
locations to process information more efficiently to boost system
performance, and the responsibility for the data is dispersed across
multiple entities or agency sites and would be maintained locally at each
site. Because the tiered design is based on the use of common hardware and
software components, the governmentwide e-Rulemaking system is not linked
to any existing agency specific docket system with its unique hardware and
software. As a result, no customized software interfaces are needed.

Distributed design. The distributed design integrates a centralized
governmentwide e-Rulemaking system with existing agency-specific

electronic docket systems while satisfying all governmentwide e-Rulemaking
system requirements. This design links agencies with existing docket
systems to the governmentwide e-Rulemaking system using customized
software (middleware) to allow interconnectivity between agencies' systems
and the governmentwide e-Rulemaking system. This design provides the
public with a means of searching across agency dockets and establishes the
governmentwide e-Rulemaking system as an access point to the public and
agencies for searching, reviewing, and commenting on dockets that reside
on the agencies' existing docket systems. In addition, agencies with
docket systems will continue to perform their own workflow/business/docket
life-cycle processing.

    Officials Used Contractor's Analysis When Preparing Business Case
    Recommending Centralized Design

In 2002, DOT, which was the managing partner for the e-Rulemaking
initiative, contracted with a consulting firm to assess the capabilities
of seven existing agency e-Rulemaking systems and prepare a business case
describing alternative designs for the system and the recommended design.
The firm was to provide advice to DOT about the best technical approach
for the initiative, along with a full analysis of alternatives that
leverage the use of existing technology to meet the vision, goals, and
objectives of the initiative. Based on its assessment, the consulting
firm's August 2002 report recommended that EPA's eDocket system would be
the optimal platform for a governmentwide centralized e-Rulemaking system.
The business case discussed two other alternative designs as well. DOT
submitted this business case to OMB in September 2002.

Based on the recommendation to use EPA's e-Rulemaking system as the
platform for a centralized system, OMB transferred managing partner
responsibilities for the e-Rulemaking initiative from DOT to EPA. After
EPA became the managing partner in late 2002, EPA submitted three
additional business cases to OMB-in December 2002, September 2003, and
September 2004-and recommended the centralized design. During this time
period, e-Rulemaking officials also hired a contractor to refine the three
alternative designs, summarize the costs and risks for each alternative,
and recommend one alternative for implementation. E-Rulemaking officials
used the contractor's January 2004 report recommending the centralized
alternative when preparing the last of the three business cases that was
submitted to OMB.

    Three Assessments Favored Centralized Design

E-Rulemaking officials and the e-Rulemaking Initiative Executive Committee
based the decision to select the centralized design over the tiered and
distributed designs on three assessments that generally found that the
centralized design was most cost effective, had the lowest risk for
deployment and support instability, was the most secure, and was most
likely to deliver the breadth and functionality sought by agencies and the
public. E-Rulemaking officials hired a contractor to conduct two analyses
based on cost18 and risk models, and the contractor obtained from a
consulting firm a third assessment that was based on industry best
practices and experiences in assessing similar architectures.

The first assessment used a cost-analysis modeling tool used by the
private sector and government agencies to analyze and estimate the costs
associated with software application development. Using this model, the
cost estimates to deliver and operate the three designs were $18.7 million
for the centralized design, $21.1 million for the tiered design, and $87.2
million for the distributed design (assuming 10 agencies were integrated
with the centralized governmentwide e-Rulemaking system). The model
predicted it would take 1 year to deliver the centralized design and
almost 3 years to deliver the distributed design. Also, according to the
model, the complexity of the distributed design would present a high risk
of instability to the overall operation and maintenance of the systems.

The second assessment used a model19 that estimates the total cost of
implementing and supporting a specific application within a commercial
enterprise and assesses the expected risk of successful deployment and the
benefit to the organization of adopting the new capability. Using this
model, the cost to deliver and operate the three designs was $20.1 million
for the centralized design, $22.8 million for the tiered design, and $94.9
million for the distributed design (assuming 10 agencies were integrated

18The costs evaluated are those that are normally associated with the
selection of architectural options during the analysis of system solutions
at the beginning of their life cycles. The evaluation was not intended to
be a fully detailed agency-specific cost-benefit analysis associated with
developing the governmentwide e-Rulemaking system and migrating specific
agencies to that system.

19This model is an enterprise application cost and risk assessment model
that provides a framework for analyzing and developing technology
portfolios. It uses a business collaborative engine that allows larger
organizations to measure and improve alignment of business objectives with
information technology initiatives. The company that developed the model
based it on 10 years of collaboration with Fortune 500 Chief Information
Officers to determine viability, business risk, and business value.

with the centralized governmentwide e-Rulemaking system). The model
estimated that there was a 50 to 60 percent greater likelihood of
unsuccessful deployment of the distributed design when compared to the
other designs. The most significant risk factor accounting for this
increased likelihood of failure is system complexity, resulting in major
integration, infrastructure, and change management issues that tend to be
difficult to resolve.

The third assessment was done by a leading information technology firm
with the intent of predicting the cost, risk, security, and supportability
of the three designs based on industry best practices and the firm's
experience in assessing similar architectures. The firm recommended the
centralized design because it provided for a consistent implementation
across the government and was the lowest cost and least risky design. The
firm rated the tiered design as "feasible but not recommended" for various
reasons including the following. First, the firm said it would be
difficult to maintain consistent data quality in a tiered design because
the responsibility for data would be spread across multiple entities.
Second, consistent security and business continuity policies could not be
implemented because each agency would most likely manage its data
according to its security policies and business continuity models. Third,
data retrieval could be complex because data would be maintained locally
at each agency. The firm did not recommend the distributed design for
several reasons, including the highly complex implementation and high
delivery risk and higher cost for maintenance and support due to the large
number of disparate systems involved in the design.

    Officials Used Professional Judgment to Develop Estimated Savings

E-Rulemaking officials estimated that the federal government would save
approximately $94 million over 3 years by deploying the e-Rulemaking
system-$56 million in savings from eliminating duplication of systems and
$38 million in savings from annual maintenance fees. Officials said that
they developed this estimate prior to completing the three assessments
previously described and that at the time they developed this estimate,
there was a lack of published information about how much it cost to
develop or operate paper or electronic rulemaking systems. They primarily
used their professional judgment, information about costs for developing
and operating EPA's paper and electronic rulemaking systems, and
information provided by OMB about the number of rulemaking entities to
develop the estimate. The estimate assumes, among other things, that all
rulemaking entities would either develop an electronic rulemaking system

or, if they already had an electronic rulemaking system, they would
continue to operate those systems.

Agencies Generally E-Rulemaking officials extensively collaborated with
rulemaking agencies

and used several methods to solicit the participation of those
agenciesExpressed Satisfaction during the e-Rulemaking effort, notably the
use of interagency workingwith E-Rulemaking groups. Most officials at
these other rulemaking agencies said they had Officials' Efforts to
adequate opportunity to collaborate on the initiative and described the

process as effective. They provided us with examples that supported
theirSolicit Their Input opinions.

    Officials' Collaborative Efforts Included Three Levels of Panels with Broad
    Representation

E-Rulemaking officials have successfully used a variety of collaboration
tools to encourage participation and arrive at consensus among the
participating agencies, particularly the use of interagency working
groups. Two core working groups facilitate discussion and decision making
for the project: (1) the e-Rulemaking Advisory Board, composed primarily
of technical and policy staff from the participating agencies; and (2) the
e-Rulemaking Initiative Executive Committee, composed of upper-level
agency managers such as Chief Information Officers and individuals at the
Assistant Secretary level, which was added after the project had begun to
obtain upper management support from participating agencies-especially
those that already have an electronic system in place. Additionally,
e-Rulemaking officials have convened specialized working groups to tackle
unique areas of concern, such as system design, project funding, or legal
issues. These specialized working groups are open forums designed to
foster consensus on decisions made on the e-Rulemaking initiative.

Under e-Rulemaking officials' guidance, specialized working groups are
charged with developing specific proposals for the project and
transmitting these proposals to the Advisory Board for discussion. The
Advisory Board may consider revisions to the proposal before reaching a
decision that represents a consensus of the participants. This decision is
then sent to the Executive Committee, which makes a final decision on the
proposals and recommends a course of action to OMB. Agency officials we
spoke with noted that representatives of all agencies are free to
participate on the Executive Committee, the Advisory Board, or any working
group.

The three levels of panels are supplemented by a variety of other
collaborative tools and methods, including: one-on-one meetings with

agency officials, surveys, e-mail communication, teleconferencing, and an
online library of documents related to the initiative. EPA also provided
public notice of its work in the Federal Register and held public forums
on the East and West coasts to obtain the views of businesses, citizens,
and interest groups regarding the design of the e-Rulemaking system.

    Officials Praised for Their Collaboration, Responsiveness to Unique Agency
    Needs, and Explanations for Suggestions That Were Rejected

The tenor of our discussions with officials of 14 of the 27 agencies
serving on the Advisory Board was that they were satisfied with the level
of collaboration. Participating agencies indicated that they had adequate
opportunity to provide input and described the collaboration of
e-Rulemaking officials as effective. Officials from a few agencies even
said that in terms of the e-government initiatives, the e-Rulemaking
initiative was one of the better collaborative efforts in which they have
participated.

Agencies often praised e-Rulemaking officials' concern for the unique
needs of their agency. For example, one agency communicated its concern
that it was not clear how the e-Rulemaking system would accommodate
interim rules. While most rules are not effective until after the
rulemaking process is concluded, some interim rules are effective
immediately, for example, due to emergency conditions or other concerns
related to health and safety. After receiving this comment, e-Rulemaking
officials recognized the need to be clear about how interim rules would be
processed and how comments on such rules would be addressed. The system
was revised in accordance with the agency's suggestions.

In another instance, one agency disagreed with the implementation schedule
it was given for its transition to the e-Rulemaking system. The agency's
officials anticipated that the transition date would overlap with a
critical stage in their annual rulemaking cycle and expressed concern that
any errors in processing and adopting rules during that time would be
particularly harmful. E-Rulemaking officials readily agreed to change the
schedule to account for this timing problem.

Even when an agency's suggestion was not incorporated into the system
design, they acknowledged that e-Rulemaking officials treated their
concerns fairly, completely, and they understood why the suggestion was
rejected. Agencies frequently deferred to the needs of the group after
expressing their individual preferences during the collaborative process.

The opinions expressed by these officials are consistent with our prior
work. We noted in a recent report that e-Rulemaking initiative officials

have successfully used collaboration strategies to achieve consensus with
partner agencies on funding contributions to the e-Rulemaking initiative
based on agency-specific characteristics.20

  Work Conducted Mostly Consistent with Key Practices but Written Agreements Did
  Not Include Performance Measures

While managing the development of the centralized e-Rulemaking system,
e-Rulemaking officials have, for the most part, followed key practices for
successfully managing a project. However, there are a few practices that
officials did not incorporate into the management of the e-Rulemaking
initiative, such as including system performance measures in written
agreements with agencies. The first agencies began migrating to the
centralized e-Rulemaking system in May 2005 and the public is scheduled to
have access to the system in September 2005. While all agencies will
eventually migrate to the centralized system, the schedule for doing so
may change, due in part to funding issues. E-Rulemaking officials have
also created a process for approving changes to the system based on
concerns or issues identified by agencies or the public.

    Officials Mostly Followed Key Practices during System Development

E-Rulemaking officials, for the most part, followed key practices for
successfully managing a project while developing the centralized
e-Rulemaking system; however, there are a few practices that they did not
follow. Table 1 summarizes the key practices they followed and those that
they did not follow when developing the centralized e-Rulemaking system.
This table does not indicate how well they followed each practice, but
rather, indicates if the steps they took to manage the e-Rulemaking
initiative reflected the presence of the practice.

20For additional information see GAO: Electronic Government: Initiatives
Sponsored by the Office of Management and Budget Have Made Mixed Progress,
GAO-04-561T (Washington, D.C.: Mar. 24, 2004).

Table 1: Key Practices E-Rulemaking Officials Followed or Did Not Follow
When

Managing the Development of the Centralized E-Rulemaking System

General management E-Rulemaking initiative areas Key practices
incorporated key practice

Information included in Problem situation or Yes business case condition

Concept for an improved Yes future situation or process

Assumptions that predict, Yes
simplify, or clarify future
conditions

Benefits of implementing the Yes initiative

How the initiative is linked to Yes strategic objectives

Risks and how they will be Yes mitigated

How the initiative is driven by Yes customer needs or the plans to
identify customer needs

Strategy for collaboration Yes with other entities

                Project funding   Strategy for determining   Yes 
                                    amount of financial      
                                assistance to be provided by 
                                           others            

Agreements regarding Yes resource commitments and contributions

Financial managers provided Yes
information on project status
and needs on a continuing
basis

Written agreements on Agreement reached on Yes key dimensions expected
outcomes

Agreement reached on No
system performance
measures

Agreement reached on roles Yes and responsibilities

Agreement reached on Yes resource commitments and contributions Cost,
schedule, and Cost, schedule, and Yes performance performance plans

(Continued From Previous Page)

General management areas Key practices E-Rulemaking initiative
incorporated key practice

Monitoring costs, schedules, and performance

                                      Yes

                 Planning         Collaboration plan         Yes 
                                  developed and used        
                             Plan for soliciting user input  Yes 
                                on a continuing basis       
                                  developed and used        
                             Plan for soliciting rulemaking  Yes 
                                 agency input developed and 
                                         used               
                             Plan to solicit information as  Yes 
                                  the system is implemented 
                               Plan to solicit feedback      Yes 
                                information from the public 
                                  developed and used        

Planned outreach programs Yes
to keep system users
informed of new
developments developed

Mechanism for obtaining Yes
feedback and answering
questions developed

                 Transparency       Project management        No 
                                   decisions related to     
                                 approach used to identify  
                                    alternative designs     
                                        documented          

Project management Yes
decisions related to selecting
the centralized system as the
preferred alternative
documented

Project management Yes decisions related to changes made to the system
based on discussions with agencies documented

Project management Yes decisions related to changes made to the system
based on public input documented

Project management Yes
decisions related to changes
made to the system based
on system testing
documented

(Continued From Previous Page)

General management E-Rulemaking initiative areas Key practices
incorporated key practice

Project management N/Aa
decisions related to changes
made to the system based
on actual use of the system
by agencies or the public
documented

Sources: GAO reports, interviews with e-Rulemaking officials, and
e-Rulemaking initiative documents.

Note: GAO analysis of e-Rulemaking initiative information.

aN/A: Since the first agencies began migrating to the centralized
e-Rulemaking system in May 2005, e-Rulemaking officials have not reached
any decisions related to changes that should be made based on actual use
of the system.

E-Rulemaking officials followed all of the key practices except two. They
did not document completely decisions related to the approach they used to
identify alternative designs. Also, EPA, as managing partner, does not
have written agreements that address system performance measures with
agencies participating in the e-Rulemaking initiative. Although the
written agreements do not include performance measures, e-Rulemaking
officials do have performance goals that they are measuring. For example,
one goal is to have the centralized e-Rulemaking system available to the
public and agency rule writers and managers 99.99 percent of the time.
Officials also said they are developing a postimplementation review plan.

EPA, as managing partner, signed written agreements with 15 agencies
during fiscal years 2003 or 2004 that indicated EPA would establish
performance measures, but the agreements did not include any details about
them. These agreements did include expected outcomes, roles and
responsibilities, and resource commitments. These 15 agencies-which
committed to providing financial assistance or in-kind resources to the
initiative-included the 5 agencies, or parts of agencies, that are
migrating to the centralized e-Rulemaking system during the first
migration phase.21 During fiscal year 2005, EPA plans to sign similar
agreements with 20 additional agencies that include these three items. The
additional agencies are those to whom OMB has issued budget guidance for
2005 regarding providing funding to EPA for the e-Rulemaking initiative.
As additional

21The written agreement with one agency was signed in fiscal year 2004.
The agreement did not include a financial commitment for fiscal year 2004,
but did include a financial commitment for fiscal year 2005.

agencies become involved in funding the initiative, e-Rulemaking officials
said they plan to sign similar agreements with them.

    Officials Have Process for Approving Changes to the System Based on Agency
    and Public Input as More Agencies Migrate to It

In May 2005, the agencies included in phase I of the migration schedule-
EPA, the Department of Housing and Urban Development, the Animal and Plant
Health Inspection Service within the Department of Agriculture, a portion
of the Department of Homeland Security, and the National Archives and
Records Administration-began migrating to the centralized e-Rulemaking
system. Current plans are for 18 additional departments or agencies to
begin using the system in fiscal year 2006, resources permitting. The
remaining rulemaking departments or agencies are scheduled to begin using
the system at different times during fiscal year 2007 and beyond.
According to e-Rulemaking officials, the schedule may change depending on
funding. They originally planned to migrate 10 agencies to the new system
during phase I, but had to cut back due to funding shortfalls and late
contributions, specifically in fiscal year 2004.22

When an agency is scheduled to migrate to the new system, it will go
through a multistep process tailored to meet its needs. E-Rulemaking
officials will sign an agreement that outlines the steps the agency will
go through to migrate to the centralized system. Upon request, prior to
initiating the implementation process, e-Rulemaking officials will meet
with a department or agency to brief them on the initiative and
demonstrate the system. The implementation steps, in chronological order,
are:

1. implementation kick-off;

2. site survey (i.e., identify and analyze agency-specific technical and
functional needs);

3. data preparation (i.e., develop agency-specific implementation);

4.	agency configuration (i.e., develop technical and functional
engineering requirements to support agency-unique implementation);

5. training (i.e., develop plans and conduct training);

22 GAO-05-420.

6.	usability testing (i.e., allow agency users to become familiar with the
e-Rulemaking system);

7. data migration (i.e., migrate data to the system);

8. moving to production (i.e., agency goes "live" using the system); and

9. postproduction support.

Five of the nine steps are high-level checkpoints at which the agency and
e-Rulemaking officials agree that conditions are acceptable to move
forward. These steps are the kick-off meeting, data preparation, training,
usability testing, and moving to production.

The centralized e-Rulemaking system will not remain static as additional
agencies migrate to it, according to e-Rulemaking officials. They said
that changes to the system will be made when valid concerns or issues are
identified. Such concerns or issues could be raised by agencies that have
already migrated to the system, agencies that will be migrating to the
system, or public users of the system. E-Rulemaking officials are already
planning changes to the system before phase II of the migration schedule
begins. These changes are based on issues identified during beta testing
by the agencies and usability testing by the public. According to
e-Rulemaking officials, they have created a Change Control Board that will
review and determine which requests for changes to the system will be
granted. This board will also prioritize the changes that are to be made
and obtain an estimate of the cost to implement them from the contractor
assisting in the design and implementation of the system.

A couple of agencies said they had concerns about whether the centralized
system would include all the capabilities of their current electronic
systems. For example, one agency said that their system tracks hearings as
well as regulatory dockets. E-Rulemaking officials told these agencies
that any such capabilities will be incorporated into future versions of
the centralized e-Rulemaking system, provided adequate funding is
provided. Moreover, they noted that because each agency signs an agreement
with the e-Rulemaking Program Office before migrating to the centralized
system, the agency can assure itself that the system has the capabilities
it needs before signing the agreement and moving forward with migration.

Conclusions 	The process e-Rulemaking officials and the e-Rulemaking
Initiative Executive Committee used to decide which of the three designs-
centralized, tiered, or distributed-to develop and implement as well as
the basis for that decision, was reasonable and adequately supported.
Using two cost and risk models and comparing the three designs to industry
best practices was a sound approach to use in order to select which design
should be implemented. In addition, because there was a lack of published
information about the costs to develop or operate either a paper or
electronic rulemaking system, e-Rulemaking officials used their
professional judgment and own experiences to estimate how much the
centralized e-Rulemaking system could save the federal government.

E-Rulemaking officials established a governance structure to collaborate
with other agencies to obtain input on developing and implementing the
centralized e-Rulemaking system and its collaboration efforts with other
agencies have been extensive and well-received. Most of the agencies we
contacted were very satisfied with the collaboration efforts and thought
that e-Rulemaking officials listened to their ideas and used them when
developing and implementing the system. Officials from a few agencies we
interviewed even said that in terms of the e-government initiatives, the
e-Rulemaking initiative was one of the better collaborative efforts in
which they have participated.

While managing the development of the centralized e-Rulemaking system,
e-Rulemaking officials followed most of the key practices for successfully
managing a project. E-Rulemaking officials could, however, improve their
management of the e-Rulemaking initiative by including system performance
measures in written agreements with agencies. Having such agreements would
provide criteria for determining if the e-Rulemaking initiative is
operating in the most effective, efficient, and economic manner possible.

Recommendation	E-Rulemaking officials established a governance structure
that allowed it to successfully collaborate with other agencies about how
to develop and implement the centralized e-Rulemaking system and used most
of the key practices included in this report for managing an initiative.
To learn from how it managed this initiative and to build on the success
of it, we recommend that the Administrator of EPA, as managing partner of
this initiative, take steps to ensure that the written agreements between
EPA and the participating agencies include performance measures that
address

issues such as system performance, maintenance, and cost savings. These
measures are necessary to provide criteria for evaluating the
effectiveness of the e-Rulemaking initiative as well as for determining if
the initiative is operating in the most efficient and economical manner.

Agency Comments	The Administrator of EPA was provided a draft of this
report for his review and comment. The EPA Assistant Administrator and
Chief Information Officer provided written comments on the draft in an
August 17, 2005, letter, which is reprinted in appendix III. The Assistant
Administrator agreed that the report accurately describes the e-Rulemaking
Initiative. She added that e-Rulemaking officials appreciated GAO's
recommendation to ensure the effectiveness of the initiative and they look
forward to continuing to work with GAO for the continued success of the
project. E-Rulemaking officials said they agree with GAO's recommendation
and they plan to implement it.

As agreed with your office, unless you publicly announce the contents of
this report earlier, we will not distribute it until 30 days from the date
of this letter. At that time we will send copies of this report to the
Chair and Ranking Minority Member of the House Committee on Government
Reform, the Administrator of EPA, and the Director of OMB. We will make
copies available to others on request. In addition, the report will be
available at no charge on the GAO Web site at http://www.gao.gov.

If you have any questions regarding this report, please contact me at
(202) 512-5837 or at [email protected]. Contact points for our Office of
Congressional Relations and Public Affairs may be found on the last page
of this report. Key contributors to this report were Thomas Beall, Boris
Kachura, Steven Law, Joseph Santiago, Shellee Soliday, and Grant Turner.

Orice M. Williams Director Strategic Issues

Appendix I

                       Objectives, Scope, and Methodology

While the Office of Management and Budget (OMB) oversees the e-Rulemaking
initiative, it named the Environmental Protection Agency (EPA) managing
partner for the initiative. As managing partner, EPA heads the Program
Management Office (PMO), which is staffed by officials from several
rulemaking agencies participating in this initiative. The PMO staff
manages the day-to-day activities of the e-Rulemaking initiative while the
e-Rulemaking Initiative Executive Committee makes the final decisions
about the initiative's strategy, resources, and timetable. Hereafter, we
refer to PMO officials as e-Rulemaking officials.

Our first objective was to describe the approach EPA used to identify
alternative designs for the e-Rulemaking system and how the decision to
proceed with a single, centralized system design was made. To address this
objective, we reviewed the Capital Asset Plan and Business Cases submitted
by the Environmental Protection Agency (EPA) and the Department of
Transportation (DOT).1 We also reviewed a contractor's analysis of the
capabilities of current e-Rulemaking systems, a contractor's summary of
assessments of the three identified alternative designs including analyses
of operational risks and security vulnerabilities, and documentation
related to the basis for e-Rulemaking officials' and the e-Rulemaking
Initiative Executive Committee's recommendation about which design
alternative to implement. We also interviewed OMB, e-Rulemaking, and DOT
officials involved with developing information about the design
alternatives, the selection of the centralized system design, and the
development of the estimated cost savings associated with the centralized
design alternative.

Our second objective was to describe how EPA collaborated with other
rulemaking agencies to obtain input about the e-Rulemaking system and
those agencies' views regarding the collaboration. To address this
objective, we interviewed e-Rulemaking officials and reviewed
documentation related to collaboration efforts such as those describing
the purpose and composition of various committees and work groups and
written agreements between agencies and EPA regarding funding of the
system. To acquire agency views on the collaboration that has occurred, we
randomly selected 12 of the 27 agencies that serve on the e-Rulemaking

1DOT was the managing partner for the e-Rulemaking initiative prior to
EPA. DOT submitted the first business case, dated September 10, 2002, to
OMB. EPA submitted the subsequent business cases dated December 28, 2002,
September 8, 2003, and September 13, 2004.

Appendix I
Objectives, Scope, and Methodology

Initiative Advisory Board and interviewed officials from those agencies
about their experiences with the collaboration efforts. Included in this
set of selected agencies were (1) agencies that serve on the e-Rulemaking
Executive Committee, (2) agencies that currently have an e-Rulemaking
system, and (3) agencies that are heavily involved in rulemaking. We
analyzed the agency officials' responses to our questions on collaboration
and identified those views that were most frequently expressed by
officials from multiple agencies as a means of gauging the overall quality
of the collaboration.2

In addition to the agencies included in the sample, we discussed
collaboration with two additional agencies that serve on the Advisory
Board. The first was DOT. Since we contacted DOT officials in relation to
the first objective, we also discussed collaboration issues with them. We
contacted the second agency, the National Archives and Records
Administration (NARA), because many officials included in the original
sample suggested that we talk to that agency since an official from NARA
was heavily involved in meeting with all agencies to discuss the
development of the e-Rulemaking system. We also discussed the methods used
to obtain information from the public about the development of the
e-Rulemaking system with PMO officials and reviewed related documents.

Our third objective was to (1) determine whether EPA used key practices
for successfully managing a project when managing the e-Rulemaking
initiative and (2) describe EPA's future plans for developing and
implementing the centralized e-Rulemaking system. To determine whether
e-Rulemaking officials followed key practices, we identified key practices
for successfully managing a project by reviewing previous GAO work related
to the e-government initiatives. The key practices included in prior GAO
reports were based in part on studies done by federal, state, and local
agencies, international agencies, and the private sector and on guidance
provided by the federal government, state, local and international
governments, private research groups, national associations, and
educational institutions. GAO information technology staff agreed with the
list of key practices we identified. After developing the list of key
practices, we compared the list to the information we had gathered about

2Although these randomly selected agencies are a representative set of the
agencies serving on the Advisory Board, the qualitative analysis of
descriptive responses provided by agency officials does not provide a
sufficiently reliable or quantifiable basis for generalizing our
observations to all agencies involved in the e-Rulemaking initiative.

Appendix I
Objectives, Scope, and Methodology

e-Rulemaking officials' management of the e-Rulemaking initiative. When
making the comparison, we did not assess how well each key practice was
followed, but rather we determined if the steps they took to manage the
e-Rulemaking initiative reflected the presence of the practice. We did not
attempt to assess the quality or extent of each practice's implementation.
In order to describe future plans for the initiative, we reviewed
documents that addressed future plans such as the business cases and
implementation schedules and interviewed e-Rulemaking officials. We did
not assess the quality of these plans.

Although we report cost and related data from contractor assessments of
the three governmentwide e-Rulemaking system design alternatives, we did
not examine the reliability of that data since our first objective was to
describe how e-Rulemaking officials selected one of the three alternatives
rather than to determine if the appropriate alternative was selected. We
performed our work from December 2003 through June 2005 in accordance with
generally accepted government auditing standards.

Appendix II

                  List of GAO Reports Related to E-Rulemaking

Federal Rulemaking: Agencies' Use of Information Technology to Facilitate
Public Participation. GAO/GGD-00-135R. Washington, D.C.: June 30, 2000.

Electronic Government: Government Paperwork Elimination Act Presents
Challenges for Agencies. GAO/AIMD-00-282. Washington, D.C.: September 15,
2000.

Electronic Government: Better Information Needed on Agencies'
Implementation of the Government Paperwork Elimination Act. GAO-011100.
Washington, D.C.: September 28, 2001.

Regulatory Management: Communication About Technology-Based Innovations
Can Be Improved. GAO-01-232. Washington, D.C.: February 12, 2001.

Information Technology: OMB Leadership Critical to Making Needed
Enterprise Architecture and E-government Progress. GAO-02-389T.
Washington, D.C.: March 21, 2002.

Electronic Government: Selection and Implementation of the Office of
Management and Budget's 24 Initiatives. GAO-03-229. Washington, D.C.:
November 22, 2002.

Electronic Government: Success of the Office of Management and Budget's 25
Initiatives Depends on Effective Management and Oversight. GAO-03-495T.
March 13, 2003.

Electronic Rulemaking: Efforts to Facilitate Public Participation Can Be
Improved. GAO-03-901. Washington, D.C.: September 17, 2003.

Electronic Government: Potential Exists for Enhancing Collaboration on
Four Initiatives. GAO-04-6. Washington, D.C.: October 10, 2003.

Electronic Government: Initiatives Sponsored by the Office of Management
and Budget Have Made Mixed Progress. GAO-04-561T. Washington, D.C.: March
24, 2004.

Electronic Government: Federal Agencies Have Made Progress Implementing
the E-Government Act of 2002. GAO-05-12. Washington, D.C.: December 10,
2004.

Appendix II
List of GAO Reports Related toE-Rulemaking

Electronic Government: Funding of the Office of Management and Budget's
Initiatives. GAO-05-420. Washington, D.C.: April 25, 2005.

Appendix III

Comments from the Environmental Protection Agency

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