Capitol Visitor Center: Update on Status of Project's Schedule
and Cost as of September 21, 2006 (21-SEP-06, GAO-06-1058T).
This testimony's aim is to assist the Senate Committee on
Appropriations, Subcommittee on the Legislative Branch in
monitoring progress on the Capitol Visitor Center (CVC) project.
Our remarks will focus on (1) the Architect of the Capitol's
(AOC) progress in achieving selected project milestones and in
managing the project's schedule since the Subcommittee's August
2, 2006, hearing on the project; (2) our assessment of the
project's currently scheduled completion date; and (3) an update
on the project's expected cost at completion and funding
situation. As part of this discussion, we will address a number
of key challenges and risks that continue to face the project, as
well as actions we believe that AOC will need to take to meet its
currently scheduled completion date. This testimony is based on
our review of schedules and financial reports for the CVC project
and related records maintained by the AOC and its construction
management contractor, Gilbane Building Company; our observations
on the progress of work at the CVC construction site; and our
discussions with the CVC team (AOC and its major CVC
contractors), AOC's Chief Fire Marshal, and representatives from
the U.S. Capitol Police. We also reviewed AOC's construction
management contractor's periodic schedule assessments, potential
change order log, and daily reports on the progress of interior
wall and floor stonework. We retained a mechanical consulting
engineering firm (Kincaid/Bryant) to help us assess the CVC
team's progress in completing the project's heating, ventilation,
and air-conditioning (HVAC) system. In addition, we reviewed the
contract modifications made to date and the estimates of cost
increases provided by AOC and its construction management
contractor, including their estimates of the costs related to
delays, and their preliminary cost estimates for recent changes
to the CVC's fire protection and security systems. Our assessment
was somewhat constrained because the CVC team is still analyzing
the impact on the project's schedule and cost of the recently
identified changes required for certain components of the fire
protection and security systems. The team expects to have firmer
schedule and cost information around mid-October, at which time
we may have to revise our estimates if this later information
differs significantly from the current information.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-06-1058T
ACCNO: A61265
TITLE: Capitol Visitor Center: Update on Status of Project's
Schedule and Cost as of September 21, 2006
DATE: 09/21/2006
SUBJECT: Construction contracts
Contract administration
Cost analysis
Cost overruns
Facility construction
Federal facilities
Federal funds
Future budget projections
Public visitor-centers
Risk management
Schedule slippages
Cost estimates
Capitol Visitor Center Project
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GAO-06-1058T
* Construction Has Progressed, but the Scheduled Completion Da
* AOC's Scheduled Completion Dates Have Slipped
* Construction Work Is Progressing
* Schedule Slippages in Critical and Key Near-Critical Paths H
* Indicators of Construction Progress Do Not Instill Confidenc
* Project's Schedule Remains Vulnerable to Challenges, Risks,
* New Project Schedule Appears Achievable Only under Certain C
* Recommendation
* Project's Estimated Cost and Funding
* Contacts and Acknowledgments
* Appendix I: Capitol Visitor Center Critical Construction Mil
* Order by Mail or Phone
Testimony
Before the Subcommittee on the Legislative Branch, Committee on
Appropriations, U.S. Senate
United States Government Accountability Office
GAO
For Release on Delivery Expected at 10:30 a.m. EDT
Thursday, September 21, 2006
CAPITOL VISITOR CENTER
Update on Status of Project's Schedule and Cost As of September 21, 2006
Statement of Terrell Dorn, Director
Bernard L. Ungar, Director Physical Infrastructure Issues
GAO-06-1058T
Mr. Chairman and Members of the Subcommittee:
We are pleased to be here today to assist the Subcommittee in monitoring
progress on the Capitol Visitor Center (CVC) project. Our remarks will
focus on (1) the Architect of the Capitol's (AOC) progress in achieving
selected project milestones and in managing the project's schedule since
the Subcommittee's August 2, 2006, hearing on the project; (2) our
assessment of the project's currently scheduled completion date; and (3)
an update on the project's expected cost at completion and funding
situation.1 As part of this discussion, we will address a number of key
challenges and risks that continue to face the project, as well as actions
we believe that AOC will need to take to meet its currently scheduled
completion date.
Our remarks today are based on our review of schedules and financial
reports for the CVC project and related records maintained by AOC and its
construction management contractor, Gilbane Building Company; our
observations on the progress of work at the CVC construction site; and our
discussions with the CVC team (AOC and its major CVC contractors), AOC's
Chief Fire Marshal, and representatives from the U.S. Capitol Police. We
also reviewed AOC's construction management contractor's periodic schedule
assessments, potential change order log, and daily reports on the progress
of interior wall and floor stonework. We retained a mechanical consulting
engineering firm (Kincaid/Bryant) to help us assess the CVC team's
progress in completing the project's heating, ventilation, and
air-conditioning (HVAC) system. In addition, we reviewed the contract
modifications made to date and the estimates of cost increases provided by
AOC and its construction management contractor, including their estimates
of the costs related to delays,2 and their preliminary cost estimates for
recent changes to the CVC's fire protection and security systems. Our
assessment was somewhat constrained because the CVC team is still
analyzing the impact on the project's schedule and cost of the recently
identified changes required for certain components of the fire protection
and security systems. The team expects to have firmer schedule and cost
information around mid-October, at which time we may have to revise our
estimates if this later information differs significantly from the current
information.
1GAO, Capitol Visitor Center: Update on Status of Project's Schedule and
Cost as of August 2, 2006, GA0-06-828T (Washington, D.C.: Aug. 2, 2006).
2The estimates for most of the delay-related costs were provided by AOC
and its construction management contractor for budgetary purposes only and
do not reflect any judgments by GAO of the validity of any potential
contractor claims.
In summary:
o Since the Subcommittee's August 2 CVC hearing, the CVC team has
continued to move the project's construction forward, but the
project's overall targeted completion date has slipped
significantly. The schedule for the project's most critical
activity-the fire protection system-has slipped about 4 months,
bringing the new targeted overall completion date to mid-September
2007, and other important activities have also been significantly
delayed. Unlike the previous CVC schedule, the new schedule (1)
does not allow any time to address problems that may arise or to
prepare for operations after a certificate of occupancy has been
issued; (2) assumes that AOC will be able to bring exhibits into
the CVC before a certificate of occupancy has been issued; and (3)
provides for opening the CVC and the House and Senate expansion
spaces at the same time. It is not yet clear to us whether the
need for time to prepare for operations or for a certificate of
occupancy to receive the exhibits will affect the facility's
opening date, but these factors should not delay the completion of
construction.
o During the past month, work on the project has progressed in a
number of areas. For example, the sequence 2 contractor expects to
have dehumidified air in the exhibit gallery by around
mid-October. In addition, critical interior floor stone
installation has continued, together with other interior and
exterior construction work. Almost all of the interior wall stone
for the CVC itself (excluding the East Front and the tunnels) is
now installed.
o A number of problems have developed in connection with the
CVC's fire protection system, which is the principal cause of the
completion date's slippage and continues to be the single greatest
source of risk to meeting the project's new scheduled completion
dates. Although the CVC team has worked closely with AOC's Chief
Fire Marshal and has made substantial progress in resolving
issues, the resolution, along with necessary changes to certain
security system-related components, has resulted in a need for
significant additional work. The CVC team based its mid-September
2007 project completion date on its preliminary estimate of the
time needed to do this additional work. Although the team believes
that the time it added to the schedule should be sufficient, it
will not make a definitive determination until it completes its
analysis of the required changes, which it expects to do by
mid-October.
o Several other activities important to the CVC's completion,
such as the HVAC system's installation and East Front work, have
been delayed since the Subcommittee's last CVC hearing-an outcome
anticipated by our assessment of the CVC team's performance
against the indicators of progress that we and the Subcommittee
have been tracking. For example, during the last 7 weeks, the
sequence 2 contractor did not meet its overall target for interior
floor stone installation and continued to experience delays in
installing wall stone in the East Front. In addition, the sequence
2 contractor met only 2 of the 17 milestones that we have been
tracking for this hearing. The project continues to face risks and
uncertainties, such as getting its complex building systems to
function together as well as separately and trade stacking.3
According to our assessment of the project's new schedule, the
revised completion date is achievable if the CVC team confirms
that it has added enough time to the schedule to make the
necessary changes to the fire protection and security system
components and if, and only if, the team promptly makes
significant improvements in its execution of the project and its
schedule. To facilitate such changes, we are recommending that AOC
develop and submit to Congress an action plan as soon as possible,
but no later than mid-October 2006, setting forth the specific
steps it will take to meet its scheduled completion dates. We are
identifying specific actions that we believe AOC should consider
in developing this plan, including, for example, (1) making more
aggressive, visible, and focused efforts to keep the work on
schedule, with particular emphasis on critical and key
near-critical activities; (2) making sure sufficient work is
performed to meet the scheduled dates and quickly identifying and
addressing problems that arise; and (3) promptly responding to
design questions and concerns and requests for design instructions
and clarifications. AOC generally agreed with our recommendation.
AOC's prompt development and effective implementation of this
action plan is critical because the construction work that has to
be done in the next 3 to 4 months is a prerequisite to other work
that is essential to the CVC's completion, including the CVC
team's pretesting of the fire protection system and the Chief Fire
Marshal final acceptance testing of the CVC. In addition, Congress
can use this plan as a mechanism for holding AOC accountable for
managing the project and as a vehicle for working closely with AOC
to ensure that the schedule implications of all proposed scope or
design changes are quickly determined and considered by all
appropriate stakeholders before final decisions on the proposed
changes are made.
We previously estimated that the total cost to complete the entire
CVC project would be about $556 million without an allowance for
risks and uncertainties and $584 million with such an allowance.
Our updated assessment indicates that the estimated cost of the
entire CVC project at completion is likely to be about $584
million without an allowance for risks and uncertainties and about
$596 million with such an allowance-increases of $28 million and
$12 million, respectively. Delay-related costs (which AOC and its
construction management contractor have estimated for budgetary
purposes only) are the largest component of the increase, followed
by the additional costs estimated by the CVC team for changes to
the fire protection and security systems and additional
contingency funds for future changes. Our estimate could change if
the additional costs turn out to be significantly different from
the preliminary estimates. To date, about $531 million4 has been
provided for CVC construction. For fiscal year 2007, AOC has
requested $26 million in CVC construction appropriations, plus
$950,000 in AOC general administration appropriations for
contractual support to complete acceptance testing of the CVC's
fire protection system on schedule. During fiscal year 2007, AOC
is also likely to need, but has not yet requested, some additional
funds to pay for changes. Although AOC agrees that it will likely
need additional funds, it does not believe that it will need as
much as we have estimated. We believe our estimate is reasonable.
In addition, AOC notes that it may be able to cover at least part
of the increased costs from funding sources other than new
appropriations after obtaining the necessary congressional
approvals.
Construction Has Progressed, but the Scheduled Completion Date Has
Slipped Further, and Several Actions Are Needed to Meet the Current
Schedule
Work on the CVC project has continued, but the scheduled
completion date has slipped about 4 months beyond the date
discussed at the Subcommittee's August 2 CVC hearing. At that
hearing, we said that despite some improvement in the indicators
of progress we have been tracking, we were losing confidence in
the ability of the CVC team to meet its scheduled completion
dates, given the delays experienced thus far and the risks and
uncertainties facing the project. Unfortunately, our concerns
materialized. For example, certain important work related to the
CVC's fire protection and HVAC systems and the East Front was not
completed on time, and further delays occurred in the schedules
for these areas-all of which are important to the project's timely
completion. Although AOC significantly enhanced its management
control over the design of the CVC's fire protection system, as we
had recommended, the team determined that it will take more time
than previously expected to install certain components of the fire
protection and security systems to meet life safety and security
requirements. The CVC team is still determining the precise impact
of this additional work on the schedule, but has developed
preliminary time estimates that it believes it can achieve and may
even be able to shorten after its analysis is done. Recognizing
these uncertainties, the team has established a mid-September 2007
date for completion and possible occupancy for both the CVC and
the House and Senate expansion spaces.5 Our discussions with CVC
team managers and staff, analysis of the project's current
schedule, and observations, together with the results of our
mechanical consultant's work, indicate that this September 2007
time frame is reasonable and achievable, pending the completion of
the team's analysis, if and only if meaningful and significant
changes occur in the project's execution from this point forward.
We will discuss the necessary actions shortly.
AOC�s Scheduled Completion Dates Have Slipped
According to the June 2006 project schedule-the schedule in effect
at the Subcommittee's last CVC hearing-the base CVC project was to
be completed in May 2007 (except for the exhibit gallery), and the
House and Senate expansion spaces were to be completed in August
2007, although their physical construction work was to be
substantially completed in January 2007. The project's current
schedule (August 2006) shows both the base CVC project and the
expansion spaces completed on September 17, 2007, although the
physical construction work in the expansion spaces is now
scheduled to be substantially completed in March 2007. However,
this schedule is based on a preliminary estimate and provides no
time for additional delays. Specifically, the sequence 2
subcontractor responsible for the installation of certain fire
protection and security system components is still analyzing the
impact on the schedule of changes needed to meet life safety and
security requirements. This subcontractor has made a preliminary
estimate that it believes is reasonable and achievable pending the
completion of its analysis, but it will not commit to a date until
its analysis is completed, which it believes will be around
mid-October. In addition, unlike the June and July schedules, the
current schedule for completing the base project allows no time
for additional delays, for starting up operations, and for
delivering exhibits to the exhibit gallery after a certificate of
occupancy is issued. Although the sequence 2 contractor believes
it may be able to shorten the time in the current schedule for
making changes to the fire protection and security system
components, this possibility has not been confirmed, and it is
uncertain whether the elimination of schedule time for the three
items discussed above will be problematic.
As we have previously testified, most of the physical construction
work in the CVC, the East Front, and the expansion spaces is
scheduled to be completed by December 31, 2006; however, some work
extends into 2007-as far as May 2007 for the exhibit gallery and
certain East Front work, April 2007 for the gift shops, and March
2007 for the installation of wayfinding signage and turnover of
audio-visual equipment in the orientation theaters. Certain other
construction work, such as the completion of space for the Capitol
guide service and the installation of seats in the auditorium,
also extends into 2007. Neither the CVC nor the expansion spaces
can be opened until the Chief Fire Marshal has completed
acceptance testing for the fire protection and life safety
systems, now scheduled for September 2007 for the CVC and the
expansion spaces. However, unlike the previous project schedules,
the current schedule shows that AOC's Chief Fire Marshal plans to
begin testing the expansion spaces before he completes his testing
of the base CVC building so that some of the testing will be done
concurrently. Previous project schedules showed that the expansion
space testing would not start until the base building testing was
complete. According to the CVC team and the Chief Fire Marshal,
this change should eliminate the need for temporary construction
measures and a temporary certificate of occupancy for the base
building and for limited retesting of the base building after the
expansion spaces have been tested. Also, according to AOC's Chief
Fire Marshal, AOC may be able to open certain parts of the
expansion spaces earlier than mid-September 2007. As we have
discussed in previous CVC testimonies, AOC is continuing to
explore this possibility.
Construction Work Is Progressing
According to information provided by AOC and its construction
management contractor and our observations, work on the project
has advanced, in terms of both the dollar value of the work in
place and individual project elements. In dollar terms, AOC's
construction management contractor reported that, as of August 31,
the overall CVC project was about 86 percent complete and the
sequence 2 work was about 77 percent complete-up from about 84
percent and 74 percent, respectively, as of the Subcommittee's
last CVC hearing. Progress on individual project elements includes
the following:
o Interior CVC work has moved forward, according to AOC's
construction management and sequence 2 contractors. For example, 9
of the CVC's 21 air-handling units were reportedly capable of
providing cool air to certain parts of the building. In addition,
the sequence 2 contractor is expecting to charge the CVC's entire
HVAC system with chilled water this week and to start providing
dehumidified air to the CVC soon. The sequence 2 contractor has
also installed all of the floor stone in the exhibit gallery and
inside the great hall. The installation of wood ceiling panels is
essentially complete in one of the two orientation theaters; the
installation of ceiling drywall is complete in the food service
area; and ceiling framing has been ongoing in the assembly rooms,
auditorium, and great hall lobby.
o Surface work continued, including the installation of stone
pavers above the CVC and seat wall stone around the great hall
skylights. Work on the House connector tunnel and on linking the
Library of Congress tunnel with the Jefferson Building has also
continued.
o Wall stone has now been fully installed in the food service
area, upper level west lobby, East Front basement and ground
levels, and atrium areas. As of last week, only about 130 pieces
of wall stone had not been installed in the CVC itself, excluding
the upper two levels of the East Front and the tunnels.
o In the House and Senate expansion spaces, preparations for wall
and ceiling close-in inspections have continued.
Schedule Slippages in Critical and Key Near-Critical Paths Have
Worsened, Significantly Extending the Project�s Completion Dates
and Complicating Project Management
During the Subcommittee's last CVC hearing, we expressed
considerable concern about the risk of delay in work on the CVC's
fire protection system, as well as on other important areas, such
as the CVC's HVAC system, the East Front, and ceiling close-ins in
the upper level security lobby. Together, delays in these areas,
according to AOC's construction management contractor, have
extended the CVC's completion date by 95 workdays, from May 2007,
as projected for the Subcommittee's last CVC hearing, to September
2007, as shown in the project's August 2006 schedule. This delay
was primarily driven by slippages in the schedule for completing
the CVC's fire protection system, which constitutes the CVC
project's critical path-the single longest path through the
project's schedule, meaning that each day the system's completion
is delayed, the CVC's completion could also be delayed. AOC has
significantly improved its control over the design of the
facility's fire protection system, and the CVC team has been
working closely with AOC's Chief Fire Marshal and U.S. Capitol
Police representatives. We believe that these steps have resulted
in improved coordination and communication and facilitated quicker
resolution of problems and issues than previously occurred.
However, the changes that have to be made to certain fire
protection and security system components to address life safety
and security issues have added considerable time to the schedule.
These include (1) changes to the fire alarm system's programming;
(2) architectural changes in a number of locations to enhance
their fire protection capability; (3) wiring changes associated
with having to add a major new fire alarm system control panel,
enhance the fire damper monitoring system, use a different testing
method, and link a security system component with a fire
protection system component; and (4) changes associated with
adding fire alarm system control panels to meet security
requirements. According to the CVC team, the amount of time added
to the August schedule to make these changes reflects the team's
best thinking but is preliminary pending the team's receipt of all
the detailed information it needs to estimate the impact of these
changes on the schedule. The team has received much of this
information and expects to receive the rest within the next
several days. The needed information consists largely of shop
drawings being prepared by the sequence 2 fire alarm
subcontractor, which reflect the changes required for life safety
and security. The team believes that it will be able to make a
firm estimate by around mid-October.
As we have pointed out in our previous CVC testimonies, this
project has many near-critical paths that can also affect its
completion date, some with relatively small slippages. Such a
situation greatly complicates project management because problems
arising in multiple areas can adversely affect the completion
date, and the team must focus on a number of important areas
simultaneously to avoid delaying the project's overall completion.
AOC's construction management contractor identified 21
near-critical paths in the August schedule, 5 of which the CVC
team considers particularly important because of their potential
impact on the project's completion. These are the CVC's HVAC
system, ceiling close-ins in the upper level security lobby, and
three East Front paths. According to the CVC team, further delays
in these areas could postpone testing of the CVC's fire alarm
system, which, in turn, could delay the project's completion.
According to AOC's construction management contractor, these areas
have slipped by 74, 68, and over 100 workdays, respectively,
compared with the schedule in effect at the Subcommittee's last
CVC hearing. According to this contractor, these slippages
occurred because of an electrical problem and problems with steam
condensate that affected the HVAC system; problematic sequence 1
and preceding work that complicated the ceiling close-ins; and
multiple issues that limited progress on the 3 East Front
near-critical paths, including lead abatement requirements;
electrical, ductwork, and structural conflicts; competition for
space for workers; and a need to redesign and order new stone for
the archway above the stair and escalators on the East Front.
Because the CVC's HVAC system affects many activities, has had a
number of problems, and poses significant risks to the project's
successful completion, we asked our mechanical engineering
consultant to assess the status of the CVC's 21 air-handling
units. He observed the status of the units on August 11, and
September 6, 2006, and compared their actual and scheduled
mechanical readiness to provide conditioned air to the CVC. On the
basis of his observations at the CVC site on those 2 days, he
reported the following:
o The units' actual and scheduled stage of completion did not
always match; some units were ahead of and some were behind
schedule.
o The scheduled completion dates for the units did not always
match those for work in the spaces where the units have to be
balanced or where the space has to be clean for the units to
operate safely, suggesting a possible misalignment of priorities
for finishing the spaces and finishing the units.
o Only limited progress was made between his visits to the site.
Remaining work included insulating pipe, wiring control units, and
cleaning the units and ducts.
o On both visits, he saw relatively few workers near the units,
and little work was being performed on them.
We discussed these observations with AOC's sequence 2 and
construction management contractors, as well as the sequence 2
subcontractor responsible for the work. The construction
management contractor confirmed that efforts to finish the units
had been limited, and the sequence 2 contractor and the
subcontractor committed to completing all the work necessary for
all 21 units be operational by December 31, 2006, except for the
final commissioning of some units. The sequence 2 contractor said
that it would ensure the alignment of the schedules and priorities
for finishing the units and the spaces they are to serve. Last
Friday, AOC's construction management contractor said that
finishing the scheduled work for the CVC's air-handling units in a
timely manner is important, and completing the work necessary to
get steam and chilled water to all the units over the next 3 weeks
is critical to meeting the project's revised completion schedule.
Accordingly, we have arranged for our mechanical engineering
consultant to reassess the status of this work in October.
The construction management contractor reported slippages in all
of the remaining near-critical paths since the Subcommittee's last
CVC hearing. In the 2-month period covered by the schedules
between this hearing and the last one, 5 near-critical paths lost
at least 100 workdays and 11 lost at least 40 workdays. For
example, the exhibit gallery path slipped 105 workdays; the bronze
door path slipped 43 workdays; the auditorium path slipped 98
workdays; and the orientation theater path slipped 85 workdays, as
reported by AOC's construction management contractor. Slippages
occurred for various reasons. For instance, according to the
construction management contractor, the orientation theater path
slipped because of slow progress in installing wood ceiling panels
and in the sequence 2 contractor's resequencing of work; the
exhibit gallery path slipped because of problems in finishing the
ceiling and schedule logic changes; and the bronze door path
slipped because of production problems at the fabricator's plant.
Several activities important to completing the House and Senate
expansion spaces have also been delayed since the Subcommittee's
last CVC hearing. For example, AOC's construction management
contractor reported a 23-workday delay in completing the circular
stairs in the atrium areas. This delay occurred because the spaces
housing the stairs were not available while sequence 2-related
work was being done in those areas. Also delayed were ceiling
close-ins that had to wait for approval of the fire alarm system,
a special fire suppression system that was not installed because
it had not been approved, and millwork that was not installed in
the Senate lower level because of delays in getting approved shop
drawings. Furthermore, the sequence 2 subcontractor doing the
expansion work identified a number of concerns that could affect
the project's completion. For example, the subcontractor reported
that ceiling close-in delays could postpone testing and balancing
of the HVAC system; a lack of conditioned air could adversely
affect certain casework and ceiling tile work; and changes being
considered in the design of the expansion spaces could delay their
completion, including work that could affect the testing and
balancing of the HVAC system.
Finally, although not critical to the CVC's opening, work being
done to connect the Library of Congress's Jefferson building to
the tunnel linking it with the CVC has fallen about a month behind
because of an asbestos problem. This delay was shorter than
initially estimated. Overall, the project's schedule today,
compared with the schedule in effect at the Subcommittee's
September 15, 2005, CVC hearing, reflects an average loss of about
3 out of every 4 weeks due to schedule slippages.
Indicators of Construction Progress Do Not Instill Confidence in
the CVC Team�s Ability to Meet Scheduled Completion Dates
The four indicators of construction progress that we have been
tracking for the Subcommittee support extension of the project's
schedule and suggest that changes in the project's execution will
be necessary to achieve the scheduled dates. An update on these
indicators follows:
Sequence 2 contractor has continued to miss most milestones.
Starting with the Subcommittee's June 2005 CVC hearing, at the
Subcommittee's request, we and AOC have been selecting and
tracking sequence 2 milestones to help the Subcommittee monitor
construction progress. These milestones include activities that
were either on the project's critical path or that we and AOC
believe are critical to the project's timely completion. As figure
1 shows, the sequence 2 contractor has generally missed these
milestones. For today's hearing, the contractor met 2 of the 17
milestones that were due to be completed, according to the
project's June 2006 schedule, and for both, the work was completed
ahead of schedule. However, the contractor was late in completing
work for 2 other milestones and had not completed the work for the
remaining 13 milestones as of September 15, 2006. (See app. I.)
The sequence 2 contractor attributed the slippages to a number of
factors, including the need to replace water-damaged insulation,
necessary preceding work taking longer than expected, and a
resequencing of work by the contractor.
Figure 1: Sequence 2 Contractor's Progress in Meeting Selected
Milestones as of CVC Hearing Dates
Value of completed work has increased since the last hearing, but
trend reflects the sequence 2 contractor's difficulties in meeting
scheduled completion dates. Another indicator of construction
progress that we and AOC's construction management contractor have
been tracking is the value of the completed construction work
billed to the government each month. Overall, the sequence 2
contractor's monthly billings, including the bills for March
through August 2006, indicate that AOC is more likely to finish
closer to its new scheduled completion dates than its previously
scheduled completion dates. While this indicator has some
limitations (for example, billings lag behind construction), it is
generally regarded in the construction industry as a useful
measure of how likely a project is to be completed on time. Figure
2 compares the sequence 2 contractor's billings since May 2003
with the billings needed to complete construction work on schedule
and indicates that a late summer 2007 completion date is
reasonable.
3Trade stacking can occur when workers from different trades, such as
stone masons, electricians, plumbers, or plasterers, have to work in the
same area at the same time to meet a schedule, sometimes making it
difficult to ensure sufficient space and resources for concurrent work.
4Since we last updated information on the amount of funding provided for
CVC construction, the House and Senate Committees on Appropriations
approved an AOC request to reprogram about $1 million from CVC operations
funding to CVC construction.
5AOC's June and July schedules provided time between the base project's
completion and the CVC facility's opening to prepare for operations and to
install the exhibits in the exhibit gallery because the CVC team believed
that a certificate of occupancy was required before the exhibits could be
brought into the building. The team now believes that it may be able to
fully prepare for opening and install the exhibits before it has a
certificate of occupancy. As of September 15, it was not clear to us that
these assumptions had been validated.
Construction Work Is Progressing
Schedule Slippages in Critical and Key Near-Critical Paths Have Worsened,
Significantly Extending the Project's Completion Dates and Complicating Project
Management
Indicators of Construction Progress Do Not Instill Confidence in the CVC Team's
Ability to Meet Scheduled Completion Dates
Figure 2: Total Billings by the Sequence 2 Contractor for the Entire CVC
Project Compared with the Billings Needed to Finish Construction Work on
Schedule
Notes:
1. The early and late lines on this figure reflect the cumulative billings
that would be required to complete the project through contract
modification number 126 ($232.5 million total contact value) by the early
and late finish dates shown in the sequence 2 contractor's schedule, which
is based on the September 2006 contractual completion date.
2. The actual line reflects the sequence 2 contractor's actual monthly
billings.
3. Although bills are typically submitted for payment after work is
completed, it is often likely that construction work will be completed on
schedule when the actual billing line falls between the early and the late
lines in the figure. With respect to the CVC, the actual billing line has
been trending below, and in March 2006 went below, the late finish line,
where it remained through August 2006. Even with the lag in billings, this
trend indicates that the amount of work being completed each month is not
sufficient to keep the project on schedule.
Installation of interior wall and floor stone is taking longer than
expected. Overall, about 86 percent of the CVC's interior wall stone has
been installed (in the CVC, East Front, atrium areas, and tunnels),
according to AOC's construction management contractor, and the sequence 2
contractor installed 1,325 pieces of interior wall stone during the last 7
weeks. Although the sequence 2 contractor has installed almost all of the
wall stone in the CVC itself and all of the wall stone in the atrium
areas, wall stone installation in the East Front is significantly behind
schedule. According to the sequence 2 contractor's January 2006 wall stone
installation schedule, the East Front wall stone was to be completely
installed by July 10, 2006. As of September 15, about 4,700 pieces of wall
stone remained to be installed in the East Front. During the same 7-week
period, the sequence 2 contractor installed about 24,040 square feet of
interior floor stone, or about 73 percent of the 33,000 square feet
specified in the floor stone installation plan that the contractor
provided to AOC. According to the construction management contractor, the
sequence 2 contractor installed the floor stone inside the great hall
sooner than planned, but work has been impeded in other areas by the lack
of available space.
Figure 3 shows the sequence 2 contractor's progress in installing interior
floor stone since February 13, 2006.6
6We have discontinued presenting the figure we previously included in our
testimonies comparing actual to targeted wall stone installation because
all targeted quantities were to have been installed by August 7, 2006,
according to the sequence 2 contractor's January 2006 installation plan.
Figure 3: Progress of CVC Interior Floor Stone Installation Compared with
Preliminary Targets Set by the Sequence 2 Contractor
Project's Schedule Remains Vulnerable to Challenges, Risks, and Uncertainties
As we have indicated during the Subcommittee's previous CVC hearings, we
believe that the CVC team continues to face challenges, risks, and
uncertainties in completing the project. Given the project's history of
delays, the difficulties the CVC team has encountered in resolving
problems that arise quickly, and the large number of near-critical
activities that can affect the project's overall completion, the CVC's
efforts to identify potential problems early and resolve issues quickly
will be even more important from this point forward, since AOC has left no
"slack" in the schedule for contingencies. In our view, the remaining work
associated with the fire protection system poses the greatest single risk
to meeting AOC's mid-September 2007 completion date. The steps AOC has
taken to mitigate this risk have been helpful, but much work remains to be
done on the CVC's fire protection system and its linkages with other
building systems. In addition, the project continues to face risks and
uncertainties associated with other work important to its completion, such
as the CVC's HVAC system, the East Front, and ceiling close-ins. AOC's
current project schedule does not provide the 2 to 3 months that its
previous schedule allowed for addressing the ongoing challenges, risks,
and uncertainties. Accordingly, we plan to continue to monitor the CVC
team's efforts to meet its schedule for the fire protection system and
other key near-critical activities as well as the timeliness of the
actions taken by the CVC team to address problems, concerns, and questions
that arise. A brief update follows on the challenges, risks, and
uncertainties the CVC team continues to face and the team's plans for
addressing them:
o Complex building systems remain a significant risk. The CVC
will house complex building systems, including HVAC, fire
protection, and security systems. These systems not only have to
perform well individually, but their operation also has to be
integrated. If the CVC team encounters any significant problems
with them, either separately or together, during the resolution of
design issues, installation, commissioning, or testing, the
project could be seriously delayed. The unanticipated problems
that emerged in reviewing the design of the fire alarm system and
in programming it illustrate the impact such problems can have on
the project's schedule. Additional delays could occur if the team
takes longer than expected to get approved shop drawings, if the
proposed system does not meet the project's design specifications
or the life safety code, or if the fire protection system does not
work effectively with the security or other building systems.7
Additionally, the Chief Fire Marshal noted that delays could occur
if the CVC team does not adequately pretest the system and correct
any problems found during the pretesting. On March 23, AOC's
commissioning contractor submitted its plan to the CVC team for
testing the performance of the CVC's smoke control system, which
is a critical component of the CVC's fire protection system and
must work properly before the CVC can be opened to the public. As
of September 13, this plan had not yet been submitted to or
approved by the Fire Marshal Division. Moreover, as we have
previously noted, the Chief Fire Marshal's timely completion of
the fire protection system's acceptance testing depends on his
ability to obtain sufficient funding for a contractor to help
perform the tests.
o Trade stacking could delay completion. As we discussed during
the Subcommittee's previous CVC hearings, trade stacking could
hold up finish work, such as drywall or ceiling installation,
electrical and plumbing work, plastering, or floor stone
installation. This work could be stacked because of delays in wall
stone installation. Trade stacking could also increase the risk of
accidents and injuries. Hence, it remains important, as we said at
previous CVC hearings, for the CVC team to closely monitor
construction to identify potential trade stacking and promptly
take steps to address it. The CVC team has also identified trade
stacking as a high risk. The sequence 2 contractor has developed
plans that show when various subcontractors will be working in
each area of the CVC except the East Front. According to the
sequence 2 contractor, it intends to continue meeting regularly
with its subcontractors to review and update the area plans. The
CVC team identified one recent instance of trade stacking that
occurred in an effort to expedite certain East Front work. In
transmitting the team's monthly progress report for August, AOC
noted that the compressed time frame for bringing all of the
air-handling units on line will require bringing more technicians
and mechanics to complete the work and may result in trade
stacking.
o Building design and work scope continue to evolve. The CVC has
undergone a number of design and work scope changes. Since the
Subcommittee's August 2 CVC hearing, AOC's architectural
contractor has issued nine design changes or clarifications. As of
September 14, 2006, this contractor reported, another six were in
process. In addition, since the project began, AOC has executed
over 100 sequence 2 contract modifications for work that was not
anticipated.8 Some of these changes, such as changes in the
exhibit gallery and in the East Front, have resulted in delays.
Furthermore, although shop drawings have been approved for almost
all project elements except the fire protection system, according
to AOC, further design or scope changes in various project
elements are likely, given the project's experience to date. In
fact, in reporting on the August schedule, AOC's construction
management contractor noted that anticipated changes to the House
expansion space could affect ceiling close-ins. Project design and
scope changes are typically reflected in the development of
potential change orders (PCO), many of which result in contract
modifications. Figure 4 shows the PCOs submitted for consideration
for sequences 1 and 2 since September 2003. Although PCOs are not
always approved, they are often regarded as a reasonably good
indicator of likely future design or scope changes that can affect
a project's cost and schedule. Even more important, the adverse
impact of scope and design changes on a project's schedule is
likely to increase as the project moves toward completion.
7According to the sequence 2 subcontractor that is fitting out the House
and Senate expansion spaces, the delays in getting approved shop drawings
for the fire protection system have already postponed ceiling close-ins in
the expansion spaces, and AOC believes that further such delays, along
with possible requests for design changes, pose the greatest risks to the
completion schedule for the expansion spaces.
8These data exclude sequence 2 contract modifications for work that was
planned but not included in the sequence 2 base contract. Examples include
the fit-out of the House and Senate expansion spaces, the construction of
the utility tunnel, and the purchase and installation of food service
equipment.
Figure 4: Cumulative Number of Potential Change Orders Submitted for CVC
Sequences 1 and 2 between September 2003 and August 2006
As the figure indicates, new PCOs for sequence 1 were submitted until
shortly before, and even for several months after, November 2004, when AOC
determined that the sequence 1 contract work was substantially complete.
Similarly, PCOs for sequence 2 are still being submitted, and we have seen
no indication that their submission is likely to stop soon. It therefore
appears likely to us that some of the design or scope changes indicated in
PCOs could lead to contract modifications that will affect the project's
schedule. AOC agrees that it is important to minimize the impact of
proposed design and scope changes.
Additional delays associated with the CVC's new utility tunnel have
resulted, or could result, in additional work or slippages. As we have
previously testified, the delay in starting up the utility tunnel's
operations has necessitated the use of temporary humidity control
equipment for the orientation theaters to avoid damage to finish work and
ceiling tile. Moreover, delays in getting conditioned air inside the CVC
have resulted in the sequence 2 contractor's bringing additional temporary
equipment into the auditorium area. Such delays may subject certain work
to the risk of damage or delay finish or ceiling work in areas not
suitable for the use of temporary humidity and temperature control
equipment. For example, the CVC team installed ceiling tile in portions of
the great hall to take advantage of the scaffolding in place, even though
neither the temperature nor the humidity was controlled in that area.
According to the CVC team, the installed tile could be damaged if the
temperature or humidity is not within the specified levels. The CVC team
has been providing cool air to the food service area and on the service
level, but planned to turn off the chilled water supply to the CVC this
week so that it can charge the entire CVC system with chilled water. At
the Subcommittee's last CVC hearing, we reported that the CVC team had
expected to have steam running to the CVC and to be providing dehumidified
air to the exhibit gallery by mid-August. However, as we discussed
earlier, the team experienced problems. The CVC began receiving steam
earlier this week and now expects to be able to provide dehumidified air
to the CVC by mid-October. Remaining risks involve having sufficient
manpower to meet the scheduled dates for getting the HVAC system fully
operational and being able to quickly overcome any problems that may arise
in getting the system properly balanced, controlled, and commissioned.
o Late identification or slow resolution of problems or issues
could delay completion. Historically, the project has experienced
or been at risk of experiencing some delays resulting from slow
decision-making. In addition, some CVC team members believe that
some of the problems that have resulted in delays, such as certain
problems associated with the East Front or with problematic
sequence 1 concrete work could have been identified and addressed
earlier than they were. In responding to these comments, the
sequence 2 contractor said that although earlier identification of
these types of problems is conceptually possible, it is difficult
in practice. Looking forward, we do not believe that the team will
be able to meet its scheduled completion date if it does not
quickly decide on issues; respond to concerns, questions, and
submittals; or resolve problems. Last week, AOC told the CVC team
that starting October 1, the architectural contractor will be
decreasing its staffing support to the project. In our opinion,
this increases the risk of slow responses to design questions or
requests for design instructions at a very critical time,
particularly since we have not seen evidence of a decrease in
potential change orders. AOC believes that it will be able to
provide its CVC construction contractors with sufficient
architectural support to respond to appropriate questions or
requests in time to avoid delays. We believe that this situation
needs close monitoring, as well as corrective action if problems
arise.
o Risks from insufficient stone deliveries appear to be
diminishing. Although wall stone shortages have caused delays in
the past, they have not recently been a problem. All of the wall
stone for the base project and atrium areas has been delivered,
and AOC does not anticipate a problem with the remaining wall
stone deliveries. According to the construction management
contractor, about 2,400 pieces of wall stone for the East Front
and all of the wall stone for the tunnels still have to be
delivered. For a time, the sequence 2 contractor did have a
problem with the delivery of floor stone for the exhibit gallery,
but that problem has been resolved, and the contractor does not
anticipate problems with floor stone deliveries for other areas.
The sequence 2 subcontractor doing the House and Senate expansion
space work said that some wall stone for the expansion spaces has
been delivered and at this time he does not anticipate a delivery
problem with the remaining wall stone.
Finally, as we have said in previous discussions with AOC, its
construction management contractor, and the Subcommittee, it will
be important for AOC to have adequate analysis and documentation
of the reasons and responsibilities for delays.9 On April 11,
2006, AOC executed a contract modification authorizing its
construction management contractor to have one of its managers who
has not been involved in the CVC project assess the adequacy of
this type of information. The manager submitted his report to AOC
in early June. He reported generally positive findings but also
identified desired improvements. He made several recommendations
to AOC, which AOC has generally agreed with and plans to implement
consistent with the availability of resources. As we have
previously stated, we believe it is important for AOC to complete
its analysis of delays expeditiously given the September 15, 2006,
sequence 2 contract completion date and the impact this analysis
is likely to have on delay-related costs. AOC has been working
with the sequence 2 contractor to address this issue.
New Project Schedule Appears Achievable Only under Certain Conditions
Last week, the CVC team completed the development of a new project
schedule-the August 2006 schedule-that reflects the results of its
preliminary analysis of the impact on the schedule of recent
changes to certain components of the fire protection and security
systems. While the team believes that its preliminary estimate is
likely to provide sufficient time to accomplish the needed work,
it does not believe it can make a definitive determination until
after it has had a chance to fully analyze the changes to these
systems. Although the team was striving to have all the necessary
submittals approved by October 1, this is not likely. However, the
sequence 2 contractor and its subcontractor responsible for most
of the related work believe that they expect to have enough of the
needed information in the next several days and will be able to
make a definitive determination on the amount of time needed by
around mid-October. The team plans to reflect any changes
necessary in the September project schedule, which it expects to
issue at about that same time.
The August project schedule shows that all physical construction
work on the CVC, the East Front, and the expansion spaces will be
completed by spring 2007 and that the pretesting and final testing
of all of fire protection, life safety, and related systems for
these areas will be carried out between then and mid-September
2007. The schedule reflects the amount of time that AOC's Chief
Fire Marshal said he would need to perform his acceptance testing,
although the team is working with him to see if certain aspects of
the testing can be done differently to achieve some time savings.
Unlike the previous project schedule, the new schedule does not
allow any time for addressing problems, risks, or uncertainties or
for preparing for operations; it also assumes that the exhibits
can be delivered and set up before the final acceptance testing of
the facility has been completed. The team assumes that it will be
able to arrange for the delivery and set up of the exhibits and to
prepare adequately for operations before it receives a certificate
of occupancy, but had not confirmed this assumption as of
September 15, 2006.
Accordingly, we are focusing the results of our schedule
assessment on the completion of the CVC's construction, including
the facility's acceptance testing but excluding preparations for
operations and the delivery and setup of the exhibits. Although we
would feel more comfortable if the schedule did contain some time
for addressing problems, risks, and uncertainties, our analysis of
the schedule; observations of the team's progress; discussions
with CVC team managers and members, U.S. Capitol Police
representatives, and AOC's Chief Fire Marshal; and the results of
our mechanical engineering consultant's work indicate that the
mid-September time frame for completing the project is achievable
subject to two conditions:
o The team's remaining analysis of the impact of the fire
protection and security system changes shows that the team can
finish the necessary work within the scheduled time.
o The team promptly makes significant changes in its execution of
the schedule and project.
Recommendation
Given the magnitude of the recent schedule slippages and the
consequences of the risks that have materialized, the time it has
taken the team to identify and resolve problems, the team's
performance relative to the indicators of progress that we and the
Subcommittee have been tracking, and the risks and uncertainties
that continue to face the project, we are convinced that the team
will not be able to meet the new schedule or any schedule with
completion dates close to mid-September 2007 unless it quickly and
substantively changes its execution of the project and schedule.
We are recommending that the Architect of the Capitol promptly
develop an action plan setting forth specific steps that AOC and
the CVC team will take to enhance AOC's execution of the schedule
and project. Types of actions the team should consider are as
follows:
o Make more visible, aggressive, and focused efforts to manage
activities in the project's critical and key near-critical paths
according to the schedule, making sure that priority activities
receive priority attention.
o See that sufficient effort is applied to meet important dates.
The CVC team may wish to consider including the use of targeted
acceleration when it is justified and will save time without
adversely affecting worker safety, work quality, or facility
functionality or causing trade stacking. In addition, any
consideration of acceleration should balance its impact on the
schedule against its potential impact on cost.
o Ensure that mechanisms are in place to identify and quickly
resolve problems, issues, risks, questions, and concerns raised by
construction contractors or others; provide needed design guidance
and instructions; and respond to submittals effectively and
quickly, including closely monitoring the turnaround time for
architectural support from this point forward.
o Continuously ensure the effective operation of mechanisms put
in place to coordinate work among the many contractors and
subcontractors constructing the building and to coordinate with
AOC's Chief Fire Marshal, U.S. Capitol Police, and the Capitol
Power Plant.
o Continue to see that requests for discretionary changes to the
project's scope or design are promptly brought to the attention of
the Capitol Preservation Commission, along with the impact of such
requested changes on the project's schedule.
AOC agreed that additional actions are needed to improve the
extent to which the CVC team meets its scheduled dates and said
that it would identify and take such actions. To help put the CVC
team in a better position to meet the project's scheduled
completion date, after considering the actions we have identified,
the Architect of the Capitol should promptly provide the Capitol
Preservation Commission, the House and Senate Committees on
Appropriations, and the Senate Committee on Rules and
Administration and the Committee on House Administration with a
plan setting forth the actions it and the CVC team will take to
enhance their execution of the project and its schedule -
particularly to accomplish all of the critical work that needs to
get done in the next 3 to 4 months. AOC should submit the plan as
soon as possible, but no later than mid-October 2006. Congress can
then use this plan to hold AOC accountable for managing the
project and to work closely with AOC to ensure that the schedule
implications of all proposed scope or design changes are quickly
determined and considered by all appropriate stakeholders before
final decisions on the proposed changes are made.
Project�s Estimated Cost and Funding
Relying on cost estimates provided by AOC and its construction
management contractor, we now estimate that the total cost to
complete the entire CVC project will be about $584 million without
an allowance for risks and uncertainties and could be as much as
about $596 million with such an allowance. This updated $584
million estimate is about $28 million greater than our previous
estimate of $556 million, which did not include an allowance for
risks and uncertainties, and matches our previous estimate of $584
million, which did include an allowance for risks and
uncertainties. The $28 million increase consists of estimated
costs related primarily to additional delays and, to a lesser
extent, the recently identified changes to the CVC's fire
protection and security systems and provision for future changes.
(AOC estimated the additional delay-related costs for budgetary
purposes only and did not provide for possible concurrent
delays.).Moreover, with additional risks and uncertainties, we
believe the entire project could cost another $12 million at
completion ($596 million minus $584 million). The mounting costs
of delays are a major reason for our emphasis on the need for AOC
and its other CVC team members to make significant changes in
their project management.
To date, about $531 million has been provided for CVC
construction. This amount includes about $3.9 million that was
made available for either CVC construction or operations10 and has
been approved for CVC construction by the House and Senate
Committees on Appropriations. Our previous cost-to-complete
estimate showed that another $26 million in construction funds
would be necessary without an allowance for risks and
uncertainties to reach the previous cost estimate of $556 million.
AOC has requested this additional $26 million in its fiscal year
2007 budget for CVC construction. AOC has also requested $950,000
in fiscal year 2007 general administration appropriation funds to
provide contractual support for the Chief Fire Marshal's final
acceptance testing of the CVC. Given the new cost-to-complete
estimate, AOC will likely need some additional funding for changes
during fiscal year 2007.
AOC agreed that it would likely need additional funds but did not
believe it would need quite as much as we had estimated for future
changes and contingencies. Given the project's experience with
cost growth and the trends in the number of potential change
orders submitted, we believe our estimate is reasonable. In
addition, AOC noted that it could possibly use some funds that
have been slated for covering sequence 2 delay-related costs for
other CVC-related costs during fiscal year 2007, assuming that
some of this delay-related funding may not be needed for some
time. AOC recognized, however, that it may need additional funding
for potential delay-related costs if it were to do this. AOC also
noted that it may be able to cover some portion of the increased
costs by reprogramming funds from other sources after obtaining
the necessary congressional approvals.
Mr. Chairman, this completes our prepared statement. We would be
pleased to answer any questions that you or Members of the
Subcommittee may have.
Contacts and Acknowledgments
For further information about this testimony, please contact
Bernard Ungar at (202) 512-4232 or Terrell Dorn at (202) 512-6923.
Other key contributors to this testimony include Shirley Abel,
John Craig, Maria Edelstein, Elizabeth Eisenstadt, Jeanette
Franzel, Jackie Hamilton, Bradley James, Joshua Ormond, and Scott
Riback.
Source: AOC's June 2006 CVC sequence 2 construction schedule for
the scheduled completion dates, AOC and its construction
management and sequence 2 contractors for the actual completion
dates, and the sequence 2 contractor or subcontractors for reasons
for delay
aWork is substantially complete.
bAssembly of the upper level air-handling units has been slowed
during replacement of water-damaged insulation.
cBronze door installation has been resequenced to make upper level
security doors the highest priority.
dInstallation has been slowed while coordinating with the
audio-visual contractor on the installation of above-ceiling
equipment.
eTest could not be done because preceding work had not been
completed.
fInstallation of wood doors has been resequenced; a template was
developed to prevent delays of follow-on work.
gInstallation of principal level wall stone has been affected by
ductwork revisions and metal stud design issues.
hAspiration wall-stone installation has been delayed because
preceding work took longer than expected.
Appendix I: Capitol Visitor Center Critical Construction Milestones,
July-September 2006
Scheduled Actual
Activity Location completion completion
Lower level - Hang VP drywall Congressional 7/20/2006 9/9/2006a
ceiling auditorium
Wall stone Area #6 Congressional 7/20/2006 9/11/2006a
auditorium
Install AHU-EF-1/AHU-EF-2 Mechanical system 8/1/2006 b
Install bronze doors Food service 8/3/2006 c
Grid for wood ceiling Orientation 8/8/2006 d
theater
Pre FPT controls test SF fans 8/15/2006 e
Wood doors and frames Food service 8/21/2006 f
Finish paint West lobby 8/21/2006
assembly
Install wood ceiling panels Orientation 8/22/2006 d
theater
Wall stone Area #1 East Front 8/28/2006 g
principal
Ceiling fabric Congressional 8/28/2006
auditorium
Install stone Exhibit gallery 8/31/2006 h
Plaster ceiling East Front 9/5/2006
Basement
Controls Pt. to PT. check AHU-01 9/8/2006 8/5/2006
Wall stone Area #2 East Front 9/12/2006 g
principal
Ceiling panels Orientation lobby 9/12/2006
Floor stone Food service 9/19/2006 9/4/2006
9See, for example, GAO, Capitol Visitor Center: Effective Schedule
Management and Updated Cost Information Are Important, GAO-05-811T
(Washington, D.C.: June 14, 2005).
10Public Law 108-447, enacted on December 8, 2004, provided that up to
$10.6 million (reduced to $10.5 million by a subsequent budget recission
of $84,000) could be transferred from AOC's Capitol Building appropriation
account for the use of the CVC project. The use of the amount transferred
is subject to the approval of the House and Senate Committees on
Appropriations. AOC has now received approval to obligate the entire $10.5
million.
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