Internet Protocol Version 6: Federal Agencies Need to Plan for	 
Transition and Manage Security Risks (29-JUN-05, GAO-05-845T).	 
                                                                 
The Internet protocol (IP) provides the addressing mechanism that
defines how and where information such as text, voice, and video 
moves across interconnected networks. Internet protocol version 4
(IPv4), which is widely used today, may not be able to		 
accommodate the increasing number of global users and devices	 
that are connecting to the Internet. As a result, IP version 6	 
(IPv6) was developed to increase the amount of available IP	 
address space. The new protocol is gaining increased attention	 
from regions with limited IP addresses. For its testimony, GAO	 
was asked to discuss the findings and recommendations of its	 
recent study of IPv6 (GAO-05-471). In this study, GAO was asked  
to (1) describe the key characteristics of IPv6; (2) identify the
key planning considerations for federal agencies in transitioning
to IPv6; and (3) determine the progress made by the Department of
Defense (DOD) and other major agencies in the transition to IPv6.
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-845T					        
    ACCNO:   A28400						        
  TITLE:     Internet Protocol Version 6: Federal Agencies Need to    
Plan for Transition and Manage Security Risks			 
     DATE:   06/29/2005 
  SUBJECT:   Computer network protocols 			 
	     Computer networks					 
	     Computer security					 
	     Computer software					 
	     Evaluation 					 
	     Information technology				 
	     Internet						 
	     Strategic information systems planning		 

******************************************************************
** 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-05-845T

                 United States Government Accountability Office

GAO Testimony

Before the House Committee on Government Reform

For Release on Delivery Expected at 2 p.m. EDT Wednesday, June 29, 2005

INTERNET PROTOCOL VERSION 6

     Federal Agencies Need to Plan for Transition and Manage Security Risks

Statement of David A. Powner
Director, Information Technology Management Issues

Keith Rhodes, Chief Technologist
Director, Center for Technology and Engineering

GAO-05-845T

[IMG]

June 29, 2005

INTERNET PROTOCOL VERSION 6

Federal Agencies Need to Plan for Transition and Manage Security Risks

                                 What GAO Found

The key characteristics of IPv6 are designed to increase address space,
promote flexibility and functionality, and enhance security. For example,
by using 128-bit addresses rather than 32-bit addresses, IPv6 dramatically
increases the available Internet address space from approximately 4.3
billion in IPv4 to approximately 3.4  * 1038 in IPv6 (see figure).

Figure: Comparison of IPv4 and IPv6 Address Space

Key planning considerations for federal agencies include recognizing that
the transition is already under way, because agency networks already
include IPv6-capable software and equipment. Other important agency
planning considerations include developing inventories and assessing
risks; creating business cases that identify organizational needs and
goals; establishing policies and enforcement mechanisms; determining
costs; and identifying timelines and methods for transition. Managing the
security aspects of transition is also an important consideration because
poorly managed IPv6 capabilities can put agency information and systems at
risk.

DOD has made progress in developing a business case, policies, timelines,
and processes for transitioning to IPv6. Unlike DOD, the majority of other
major federal agencies reported that they have not yet initiated key
planning efforts for IPv6.

In its report, GAO recommended, among other things, that the Director of
the Office of Management and Budget (OMB) instruct agencies to begin to
address key planning considerations for the IPv6 transition and that
agencies act to mitigate near-term IPv6 security risks. Officials from
OMB, DOD, and Commerce generally agreed with the contents of the report.

                 United States Government Accountability Office

Mr. Chairman and Members of the Committee:

Thank you for this opportunity to participate in the Committee's hearing
on Internet protocol version 6 (IPv6). In 2003, the President's National
Strategy to Secure Cyberspace1 identified the development of secure and
robust Internet mechanisms as important goals because of the nation's
growing dependence on cyberspace. The Internet protocol (IP) is one of the
primary mechanisms that define how and where information such as text,
voice, and video moves across networks. Internet protocol version 4
(IPv4), which is widely used today, may not be able to accommodate the
increasing number of global users and devices that are connecting to the
Internet. As a result, IP version 6 (IPv6) was developed to increase the
amount of available IP address space. There is increasing interest in this
new version of IP because its characteristics could allow for new
products, services, and applications.

At your request, we performed a review and recently issued a report2 that
(1) described the key characteristics of IPv6; (2) identified the key
planning considerations for federal agencies in transitioning to IPv6; and
(3) determined the progress made by the Department of Defense (DOD) and
other major federal agencies to transition to IPv6. This testimony
summarizes the results of our recently issued report. All work related to
this testimony was conducted in accordance with generally accepted
government auditing standards.

  Results in Brief

The key characteristics of IPv6 are designed to increase address space,
promote flexibility and functionality, and enhance security. For example,
using 128-bit addresses rather than 32-bit addresses dramatically
increases the available Internet address space from

1President George W. Bush, The National Strategy to Secure Cyberspace
(Washington, D.C.: February 2003).

2GAO, Information Technology: Federal Agencies Need to Plan for Transition
and Manage Security Risks, GAO-05-471 (Washington, D.C.: May 20, 2005).

approximately 4.3 billion in IPv4 to approximately 3.4  * 1038 in IPv6.
Other characteristics increase flexibility and functionality, including
improved routing of data, enhanced mobility features for wireless,
configuration capabilities to ease network administration, and improved
quality of service. Further, IPv6 integrates Internet protocol security to
improve authentication and confidentiality of information being
transmitted. These characteristics offer various enhancements relative to
IPv4 and are expected to enable advanced Internet communications and
foster new software applications.

Key planning considerations for federal agencies include recognizing that
an IPv6 transition is already under way because agency networks currently
include IPv6-capable software and equipment. Other important agency
planning considerations include developing inventories and assessing
risks; creating business cases that identify organizational needs and
goals; establishing policies and enforcement mechanisms; determining
costs; and identifying timelines and methods for transition. As we have
previously reported,3 planning for system migration and security is often
problematic in federal agencies. However, proactive integration of IPv6
requirements into federal contracts may reduce the costs and complexity of
transition by ensuring that federal applications can operate in an IPv6
environment without costly upgrades. Managing the security aspects of
transition is another consideration, since IPv6 can introduce additional
security risks to agency information. For example, attackers of federal
networks could abuse features to allow unauthorized traffic or make agency
computers directly accessible from the Internet.

Recognizing the importance of planning, the Department of Defense (DOD)
has made progress in developing a business case, policies, timelines, and
methods for transitioning to IPv6. These efforts

3GAO, Business Systems Modernization: Internal Revenue Service Needs to
Further Strengthen Program Management, GAO-04-438T (Washington, D.C.: Feb.
12, 2004); Information Technology: DOD's Acquisition Policies and Guidance
Need to Incorporate Additional Best Practices and Controls, GAO-04-722
(Washington, D.C.: July 30, 2004); DOD Business Systems Modernization:
Longstanding Management and Oversight Weaknesses Continue to Put
Investments at Risk, GAO-03-553T (Washington, D.C.: Mar. 31, 2003).

include creating a Transition Office, developing guidance and policies,
drafting transition plans, and fielding a pilot. Despite these
accomplishments, challenges remain, including finalizing plans, enforcing
policy, and monitoring for unauthorized IPv6 traffic. We also identified
the efforts undertaken by the other 23 Chief Financial Officer (CFO) Act
agencies,4 and most report little progress in planning for an IPv6
transition. For example, 22 agencies lack business cases; 21 lack
transition plans; 19 have not inventoried IPv6 software and equipment; and
22 have not developed cost estimates.

Transitioning to IPv6 is a pervasive and significant crosscutting
challenge for federal agencies that could result in significant benefits
to agency services. But such benefits may not be realized if action is not
taken to ensure that agencies are addressing key planning considerations
and security issues. In our report, we recommended, among other things,
that the Director of the Office of Management and Budget (OMB) instruct
agencies to begin addressing key planning considerations for IPv6
transition, and that agencies act to mitigate near-term IPv6 security
risks. Officials from OMB, DOD, and Commerce generally agreed with the
contents of the report.

Background

The Internet is a worldwide network of networks made up of servers,
routers, and backbone networks. To send a communication from one computer
to another, a series of addresses is attached to information sent from the
first computer to route the information to its final destination. The
protocol that guides the administration of

4The 24 CFO departments and agencies are the Departments of Agriculture,
Commerce, Defense, Education, Energy, Health and Human Services, Homeland
Security, Housing and Urban Development, the Interior, Justice, Labor,
State, Transportation, the Treasury, and Veterans Affairs; the
Environmental Protection Agency; General Services Administration; National
Aeronautics and Space Administration; National Science Foundation; Nuclear
Regulatory Commission; Office of Personnel Management; Small Business
Administration; Social Security Administration; and U.S. Agency for
International Development.

the routing addresses is the Internet protocol. The most widely deployed
version of IP is version 4 (IPv4).

Internet Protocol Transmits Information across Interconnected Networks

The two basic functions of IP include (1) addressing and (2) fragmentation
of data, so that information can move across networks. An IP address
consists of a fixed sequence of numbers. IPv4 uses a 32-bit address
format, which provides approximately 4.3 billion unique IP addresses.

By providing a numerical description of the location of networked
computers, addresses distinguish one computer from another on the
Internet. In some ways, an IP address is like a physical street address.
For example, if a letter is going to be sent from one location to another,
the contents of the letter must be placed in an envelope that provides
addresses for the sender and receiver. Similarly, if data are to be
transmitted across the Internet from a source to a destination, IP
addresses must be placed in an IP header. Figure 1 is a simplified
illustration of this concept. In addition to containing the addresses of
sender and receiver, the header also contains a series of fields that
provide information about what is being transmitted.

Figure 1: An Internet Protocol Header Contains IP Addresses for the Source
and Destination of Information Transmitted across the Internet

Source: GAO analysis.

Limited IPv4 address space prompted organizations that need large numbers
of IP addresses to implement technical solutions to compensate. For
example, network administrators began to use one unique IP address to
represent a large number of users. In other words, to the outside world,
all computers behind a device known as a network address translation
router appear to have the same address. While this method has enabled
organizations to compensate for the limited number of globally unique IP
addresses available with IPv4, the resulting network structure has
eliminated the original end-to-end communications model of the Internet.

Because of the limitations of IPv4, in 1994 the Internet Engineering Task
Force (IETF)5 began reviewing proposals for a successor to IPv4 that would
increase IP address space and simplify routing. The IETF established a
working group to be specifically responsible for developing the
specifications and standardization of IPv6. Over the

5 The IETF is the principal body engaged in the development of Internet
standards. It is composed of working groups that are organized by topic
into several areas (e.g., routing, transport, security, etc.).

past 10 years, IPv6 has evolved into a mature standard. A complete

6

list of the IPv6 documents can be found at the IETF Web site.

IPv6 Is Gaining Momentum Globally

Interest in IPv6 is gaining momentum around the world, particularly in
parts of the world that have limited IPv4 address space to meet their
industry and consumer communications needs. Regions that have limited IPv4
address space, such as Asia and Europe, have undertaken efforts to
develop, test, and implement IPv6 deployments.

Asia

As a region, Asia controls only about 9 percent of the allocated IPv4
addresses, and yet has more than half of the world's population. As a
result, the region is investing in IPv6 development, testing, and
implementation. For example, the Japanese government's e-Japan Priority
Policy Program mandated the incorporation of IPv6 and set a deadline of
2005 to upgrade existing systems in both the public and private sectors.
The government has helped to support the establishment of an IPv6
Promotion Council to facilitate issues related to development and
deployment and is providing tax incentives to promote deployment. In
addition, major Japanese corporations in the communications and consumer
electronics sectors are also developing IPv6 networks and products.
Further, the Chinese government has reportedly set aside approximately
$170 million to develop an IPv6-capable infrastructure.

Europe

The European Commission initiated a task force in April 2001 to design an
IPv6 Roadmap. The Roadmap serves as an update and plan of action for
development and future perspectives. It also serves as a way to coordinate
European efforts for developing, testing, and deploying IPv6. Europe
currently has a task force that has the dual mandate of initiating
country/regional IPv6 task forces

6The Web site for IETF is http://www.ietf.org/iesg/1rfc_index.txt Page 6
GAO-05-845T

across European states and seeking global cooperation around the world.
Europe's Task Force and the Japanese IPv6 Promotion Council forged an
alliance to foster worldwide deployment.

  IPv6 Key Characteristics Increase Address Space, Improve

Functionality, Ease Network Administration, and Enhance Security The key
characteristics of IPv6 are designed to increase address space, promote
flexibility and functionality, and enhance security. For example, IPv6
dramatically increases the amount of IP address space available from the
approximately 4.3 billion in IPv4 to approximately 3.4  * 1038. Because
IPv6 uses a 128-bit address scheme rather than the 32-bit address scheme
used in IPv4, it is able to allow many more possible addresses. The
increase in the actual bits in the address and the immense number of
possible combinations of numbers make this dramatic number of unique
addresses a possibility. Figure 2 shows a comparison between the address
spaces of IPv6 and IPv4.

Figure 2: Comparison of IPv6 and IPv4 Address Scheme

                             Source: GAO analysis.

This large number of IPv6 addresses means that almost any electronic
device can have its own address. While IP addresses are commonly
associated with computers, they are increasingly being assigned to other
items such as cellular phones, consumer electronics, and automobiles.

In contrast to IPv4, the massive address space available in IPv6 will
allow virtually any device to be assigned a globally reachable address.
This change fosters greater end-to-end communications between devices with
unique IP addresses and can better support the delivery of data-rich
content such as voice and video.

In addition to the increased number of addresses, IPv6 improves the
routing of data, provides mobility features for wireless, and eases
automatic configuration capabilities for network administration, quality
of service, and security. These characteristics are expected to enable
advanced Internet communications and foster new software applications.
While applications that fully exploit IPv6 are still in development,
industry experts have identified various federal functions that might
benefit from IPv6-enabled applications, such as border security, first
responders, public health, and information sharing.

  IPv6 Considerations Include Significant Planning Efforts and

Immediate Actions to Ensure Security The transition to IPv6 is under way
for many federal agencies because their networks already contain
IPv6-capable software and equipment. For example, most major operating
systems, printers, and routers currently support IPv6. Therefore, it is
important for agencies to note that the transition to IPv6 is different
from a software upgrade because, when it is installed, its capability is
also being integrated into the software and hardware.

Besides recognizing that an IPv6 transition is already under way, other
key considerations for federal agencies to address in an IPv6 transition
include significant IT planning efforts and immediate actions to ensure
the security of agency information and networks.

Important planning considerations include the following:

0M	Developing inventories and assessing risks-An inventory of equipment
(software and hardware) provides management with an understanding of the
scope of an IPv6 transition and assists in focusing agency risk
assessments. These assessments are essential steps in determining what
controls are required to protect a network and what level of resources
should be expended on controls.

0M	Creating business cases for an IPv6 transition-A business case usually
identifies the organizational need for the system and provides a clear
statement of the high-level system goals. One key aspect to consider while
drafting the business case for IPv6 is to understand how many devices an
agency wants to connect to the Internet. This will help in determining how
much IPv6 address space is needed for the agency. Within the business
case, it is crucial to include how the new technology will integrate with
the agency's existing enterprise architecture.

0M	Establishing policies and enforcement mechanisms-Developing and
establishing IPv6 transition policies and enforcement mechanisms are
important considerations for ensuring an efficient and effective
transition. Furthermore, because of the scope, complexities, and costs
involved in an IPv6 transition, effective enforcement of agency IPv6
policies is an important consideration for management officials.

0M	Determining the costs-Cost benefit analyses and return-oninvestment
calculations can be used to justify investments. During the year 2000
(Y2K) technology challenge, the federal government amended the Federal
Acquisition Regulation and mandated that all contracts for information
technology include a clause requiring the delivered systems or service to
be ready for the Y2K date change.7 This helped prevent the federal
government from procuring systems and services that might have been
obsolete or that required costly upgrades. Similarly, proactive
integration of IPv6 requirements into federal acquisition requirements can
reduce the costs and complexity of the IPv6 transition of federal agencies
and ensure that federal applications are able to operate in an IPv6
environment without costly upgrades.

748 C.F.R. 39.106. Page 9 GAO-05-845T

0M	Identifying timelines and methods for the transition-Timelines and
process management can assist a federal agency in determining when to
authorize its various component organizations to allow IPv6 traffic and
features. Additionally, agencies can benefit from understanding the
different types of transition methods or approaches that can allow them to
use both IPv4 and IPv6 without causing significant interruptions in
network services.

If Not Managed, IPv6 Features Can Be Abused

As IPv6-capable software and devices accumulate in agency networks, they
could be abused by attackers if not managed properly. For example, IPv6 is
included in most computer operating systems and, if not enabled by
default, is easy for administrators to enable either intentionally or as
an unintentional byproduct of running a program. We tested IPv6 features
and found that, if firewalls and intrusion detection systems are not
appropriately configured, IPv6 traffic may not be detected or controlled,
leaving systems vulnerable to attacks by malicious hackers.

Further, in April 2005, the United States Computer Emergency Response Team
(US-CERT), located at the Department of Homeland Security (DHS), issued an
IPv6 cyber security alert to federal agencies based on our IPv6 test
scenarios and discussions with DHS officials. The alert warned federal
agencies that unmanaged or rogue implementations of IPv6 present network
management security risks. Specifically, the US-CERT notice informed
agencies that some firewalls and network intrusion detection systems do
not provide IPv6 detection or filtering capability and that malicious
users might be able to tunnel IPv6 traffic through these security devices
undetected. Further, one feature of IPv6, known as automatic configuration
(where a device that is IPv6 enabled will derive its own IP address from
neighboring routers without an administrator's intervention), could allow
devices to automatically configure themselves with an IPv6 address without
authorization. US-CERT provided agencies with a series of short-term
solutions including

0M	determining if firewalls and intrusion detection system products
support IPv6 and implement additional IPv6 security measures and

0M identifying IPv6 devices and disabling if not necessary.8

  Progress Has Been Made at Defense but Is Lacking at Other Federal

Agencies The Department of Defense's transition to IPv6 is a key component
of its business case to improve interoperability among many information
and weapons systems, known as the Global Information Grid (GIG). The IPv6
component of GIG facilitates DOD's goal of achieving network-centric
operations by exploiting the key characteristics of IPv6, including

0M increased address space, 0M enhanced mobility features, 0M enhanced
configuration features, 0M enhanced quality of service, and 0M enhanced
security features.

The department's efforts to develop policies, timelines, and methods for
transitioning to IPv6 are progressing. In 2004, Defense established an
IPv6 Transition Office to provide the overall coordination, common
engineering solutions, and technical guidance across the department to
support an integrated and coherent transition to IPv6. The Transition
Office is in the early stages of its work and has developed a set of
products, including a draft system engineering management plan, risk
management planning documentation, budgetary documentation, requirements
criteria, and a master schedule. The management schedule includes a set of
implementation milestones that include DOD's goal of transitioning to IPv6
by fiscal year 2008.

In parallel with the Transition Office's efforts, the Office of the DOD
Chief Information Officer has created an IPv6 transition plan. The

8http://www.us-cert.gov/federal/archive/infoNotices/FIN05-095.html (April
5, 2005). Page 11 GAO-05-845T

Chief Information Officer has responsibility for ensuring a coherent and
timely transition and for establishing and maintaining the overall
departmental transition plan, and is the final approval authority for any
IPv6 transition waivers.

Although DOD has made substantial progress in developing a planning
framework for transitioning to IPv6, the department still faces several
challenges, including developing a full inventory of IPv6-capable software
and hardware, finalizing its IPv6 systems engineering management plan,
monitoring its operational networks for unauthorized IPv6 traffic, and
developing a comprehensive enforcement strategy, including using its
existing budgetary and acquisition review process.

Unlike DOD, the majority of other federal agencies reporting have not yet
initiated transition planning efforts for IPv6. For example, of the 22
agencies that responded to our survey, 4 agencies reported having
established a date or goal for transitioning to IPv6. The majority of
agencies have not addressed key planning considerations. For example,

0M 22 agencies reported not having developed a business case,

0M 21 agencies reported not having plans,

0M	19 agencies reported not having inventoried their IPv6-capable
equipment, and

0M 22 agencies reported not having estimated costs.

Agency responses demonstrate that few efforts outside DOD have been
initiated to address IPv6. If agency planning is not carefully monitored,
it could result in significant and unexpected costs for the federal
government.

  Recommendations for Addressing Federal IPv6 Challenges

To address the challenges IPv6 presents to federal networks, in our report
we recommended that federal agencies begin addressing key IPv6 planning
considerations. Specifically, we recommended that the Director of OMB
instruct agencies to begin developing

inventories and assessing risks, creating business cases for the IPv6
transition, establishing policies and enforcement mechanisms, determining
the costs, and identifying timelines and methods for transition, as
appropriate. To help ensure that IPv6 would not result in unexpected costs
for the federal agencies, we recommended that the Director consider
amending the Federal Acquisition Regulation with specific language that
requires that all information technology systems and applications
purchased by the federal government be able to operate in an IPv6
environment. Finally, because poorly configured and unmanaged IPv6
capabilities present immediate risks to federal agency networks, we
recommended that agency heads take immediate action to address the
near-term security risks. Such actions could include determining what IPv6
capabilities they may have and initiating steps to ensure that they can
control and monitor IPv6 traffic to prevent unauthorized access.

In summary, transitioning to IPv6 is a pervasive, crosscutting challenge
for federal agencies that could result in significant benefits to agency
services and operations. But such benefits may be diminished if action is
not taken to ensure that agencies are addressing the attendant challenges,
including addressing key planning considerations and acting to ensure the
security of agency information and networks. If agencies do not address
these key planning issues and do not seek to understand the potential
scope and complexities of IPv6 issues-whether agencies plan to transition
immediately or not-they will face potentially increased costs and security
risks.

Mr. Chairman, this completes our prepared statement. We would be happy to
respond to any questions you or other Members of the Committee may have at
this time.

  Contacts and Staff Acknowledgments

For further information, please contact David Powner at (202)-5129286 or
Keith Rhodes at (202)-512-6412. We can also be reached by e-mail at
[email protected] and [email protected] respectively.

Key contributors to this testimony were Scott Borre, Lon Chin, West Coile,
Camille Chaires, John Dale, Neil Doherty, Nancy Glover, Richard Hung, Hal
Lewis, George Kovachick, J. Paul Nicholas, Christopher Owens, Eric Trout,
and Eric Winter.

(310491)

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.

    GAO's Mission

Obtaining Copies of GAO Reports and Testimony

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.

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 posts newly
released reports, testimony, and correspondence on its Web site. To 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

Gloria Jarmon, Managing Director, [email protected] (202)
512-4400Congressional 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

                           PRINTED ON RECYCLED PAPER
*** End of document. ***