President's Justification of the High Performance Computer	 
Control Threshold Does Not Fully Address National Defense	 
Authorization Act of 1998 Requirements (30-JUN-06, GAO-06-754R). 
                                                                 
The United States controls the export of high performance	 
computers for national security and foreign policy reasons. High 
performance computers have both civilian and military		 
applications and operate at or above a defined performance	 
threshold (which was formerly measured in millions of theoretical
operations per second [MTOPS], but is now measured in Weighted	 
TeraFlops [WT]). The U.S. export control policy currently	 
organizes countries into "tiers," with tier 3 representing a	 
higher level of concern related to U.S. national security	 
interests than tiers 1 and 2. A license is required to export	 
computers above a specific performance level to countries such as
China, India, Israel, Pakistan, and Russia. Policy objectives of 
U.S. computer export controls are to (1) limit the acquisition of
highest-end, high performance computer systems by potential	 
adversaries and countries of proliferation concern and (2) ensure
that U.S. domestic industries supporting important national	 
security computer capabilities can compete in markets where there
are limited security or proliferation risks. Over the last few	 
years, the effectiveness of U.S. export controls in meeting these
policy objectives has been challenged by market and technological
changes in the computer and microprocessor industries. The	 
National Defense Authorization Act of 1998 requires that the	 
President provide a justification to Congress for changing the	 
control threshold for exports of high performance computers to	 
certain sensitive countries. The President's report must, at a	 
minimum, (1) address the extent to which high performance	 
computers with capabilities between the established level and the
newly proposed level of performance are available from foreign	 
countries, (2) address all potential uses of military		 
significance to which high performance computers at the newly	 
proposed level could be applied, and (3) assess the impact of	 
such uses on U.S. national security interests. In February 2006, 
the President set a new control threshold for high performance	 
computers and a new formula for calculating computer performance.
GAO is required by law to assess the executive branch's proposed 
changes to the current control thresholds related to foreign	 
availability and the national security risks of exporting high	 
performance computers between the previous and proposed 	 
thresholds.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-754R					        
    ACCNO:   A56205						        
  TITLE:     President's Justification of the High Performance	      
Computer Control Threshold Does Not Fully Address National	 
Defense Authorization Act of 1998 Requirements			 
     DATE:   06/30/2006 
  SUBJECT:   Export regulation					 
	     Foreign trade policies				 
	     Homeland security					 
	     International trade regulation			 
	     National policies					 
	     Restrictive trade practices			 
	     Supercomputers					 

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GAO-06-754R

United States Government Accountability Office Washington, DC 20548

June 30, 2006

Congressional Committees

Subject: President's Justification of the High Performance Computer
Control Threshold Does Not Fully Address National Defense Authorization
Act of 1998 Requirements

The United States controls the export of high performance computers for
national security and foreign policy reasons. High performance computers
have both civilian and military applications and operate at or above a
defined performance threshold (which was formerly measured in millions of
theoretical operations per second [MTOPS], but is now measured in Weighted
TeraFlops [WT]).1 The U.S. export control policy currently organizes
countries into "tiers," with tier 3 representing a higher level of concern
related to U.S. national security interests than tiers 1 and 2. A license
is required to export computers above a specific performance level to
countries such as China, India, Israel, Pakistan, and Russia.

Policy objectives of U.S. computer export controls are to (1) limit the
acquisition of highest-end, high performance computer systems by potential
adversaries and countries of proliferation concern and (2) ensure that
U.S. domestic industries supporting important national security computer
capabilities can compete in markets where there are limited security or
proliferation risks. Over the last few years, the effectiveness of U.S.
export controls in meeting these policy objectives has been challenged by
market and technological changes in the computer and microprocessor
industries.

The National Defense Authorization Act of 19982 requires that the
President provide a justification to Congress for changing the control
threshold for exports of high performance computers to certain sensitive
countries.3 The President's report must, at a minimum, (1) address the
extent to which high performance computers with capabilities between the
established level and the newly proposed level of performance are
available from foreign countries, (2) address all potential uses of
military significance to which high performance computers at the newly
proposed

1

A TeraFlop is a measure of the mathematical computing power of a machine
in floating point operations per second. A floating point operation is
meant to be an elementary operation, such as a sum, subtraction,
multiplication, or division. This measure is used to express the speed of
a processor.

2

Public Law 105-85, sec. 1211(d), 111 stat. 1933.

3

The Departments of Defense, Commerce, State, and Energy prepare the
President's report under the coordination of the National Security
Council.

GAO-06-754R Export Controls and High Performance Computers

level could be applied, and (3) assess the impact of such uses on U.S.
national security interests. In February 2006, the President set a new
control threshold for high performance computers and a new formula for
calculating computer performance.4

GAO is required by law5 to assess the executive branch's proposed changes
to the current control thresholds related to foreign availability and the
national security risks of exporting high performance computers between
the previous and proposed thresholds. To comply with the statutory
requirement, we reviewed the three statutory requirements for the
justification, the documentation used by executive branch officials to
support the conclusions in the President's February 2006 report, and
export control regulations pertaining to high performance computers. We
also interviewed officials from the Departments of Commerce and Defense
who were responsible for producing the President's report. We addressed
this report to relevant congressional committees of jurisdiction for this
mandate. We conducted this review from February 2006 to May 2006 in
accordance with generally accepted government auditing standards.

                                   Background

The United States controls the export of high performance computers and
related components (e.g., microelectronics) through the Export
Administration Act of 1979 and the implementing Export Administration
Regulations.6 The act authorizes Commerce to require firms to obtain
licenses for the export of sensitive items that may be a national security
or foreign policy concern. The Departments of Defense, Energy, and State
assist Commerce, which administers the act, by reviewing export
applications and supporting Commerce in its reviews of export control
policy.

Beginning in 1996, the executive branch organized countries into four
computer tiers, with each tier above tier 1 representing a successively
higher level of concern related to U.S. national security interests. In
2001, tiers 1 and 2 were merged. Current U.S. export control policy places
no hardware license requirements on tier-1 or tier-2 countries, primarily
those in Africa, Asia, Central and Eastern Europe, Japan, Latin America,
and Western Europe. Exports of computers above a specific performance
level to tier-3 countries, such as China, India, Israel, Pakistan, and
Russia, require a license. Exports of high performance computers to tier-4
countries, such as Iran, North Korea, and Syria, are essentially
prohibited. This report refers to tier-3 countries as ``countries of
concern.''

4

The White House, Summary of Findings with Respect to Criteria Set Forth in
Subsections 1211(d) and (e) of the National Defense Authorization Act for
Fiscal Year 1998 (Washington, D.C.: Feb. 3, 2006).

5

Public Law 106-554, app. B, sec. 314, 114 stat. 2763A-123.

6

50 U.S.C. app. 2401 et seq., and 15 C.F.R., sec. 730. The authorities
provided by this legislation expired on August 20, 2001. However, acting
pursuant to the International Emergency Economic Powers Act (codified at
50 U.S.C. 1702), the President extended application of the act and the
implementing regulation by Executive Order 13222 (66 Fed. Reg. 44025).

Page 2 GAO-06-754R Export Controls and High Performance Computers

The President has periodically changed, on the basis of technological
advances, the threshold above which export licenses are required. He last
raised the threshold in 2002 to 190,000 MTOPS. In a February 3, 2006,
report to Congress, the President reported that he was replacing the
formula for calculating computer performance current at the time with a
new formula derived from industry standards that is more accurate and
easier to calculate than MTOPS. He also set a new threshold for high
performance computer exports on the basis of the new formula.

The President's report stated that the new formula, Adjusted Peak
Performance (APP),7 as expressed in weighted TeraFlops, more accurately
differentiates between high-end, special-order, high performance computers
and commercial, readily available systems. It also stated that APP places
more weight on vector systems than nonvector systems.8 Finally, the report
stated that the 0.75 WT control level takes into consideration the
widespread foreign availability of computing capacity.

We reviewed prior justifications for changing the export control
thresholds on high performance computers and found that the changes were
not adequately justified. For example, previous President reports failed
to address all uses of military significance to which high performance
computers could be applied at the new thresholds and the impact of such
uses on national security, as required by law.

We recommended in previous GAO reports that (1) Commerce convene a panel
of experts to conduct a comprehensive assessment of possible options to
safeguard U.S. national security interests related to computer exports,
such as replacing the MTOPS performance metric;9 (2) Commerce, Defense,
and State assess the national security threat and proliferation risks of
U.S. exports of high performance computers to countries of concern;10 and
(3) Defense determine what countermeasures are necessary, if any, to
respond to enhancements of the military or proliferation capabilities of
countries of concern derived from high performance computing.11 In 2002,
we recommended that Congress should consider requiring the executive
branch to fully comply with existing statutes before the executive branch
alters or eliminates the export control threshold for high performance
computers.12 This would include assessing the national security and
military uses of computers at the higher threshold.

7

The metric addresses our past recommendation to assess ways to address the
shortcomings of high performance computer export controls based on MTOPS.
See our report titled Export Controls: System for Controlling Exports of
High Performance Computing Is Ineffective, GAO-01-10 (Washington, D.C.:
Dec. 18, 2000). However, we did not assess whether APP is the most
appropriate alternative to MTOPS.

8

A vector system is a computer with built-in instructions that performs
multiple calculations on vectors (one-dimensional arrays) simultaneously.

9GAO-01-10.

10GAO, Export Controls: More Thorough Analysis Needed to Justify Changes
in High Performance Computer Controls, GAO-02-892 (Washington, D.C.: Aug.
2, 2002); and Export Controls: Information on the Decision to Revise High
Performance Computer Controls, GAO/NSIAD-98-196 (Washington, D.C.: Sept.
16, 1998).

11GAO-01-10.

12GAO-02-892.

Page 3 GAO-06-754R Export Controls and High Performance Computers

In 2004, Commerce implemented the first recommendation to convene a panel
of experts, which agreed to replace the MTOPS metric with a new APP
formula. The executive branch has not implemented our other two
recommendations. A list of GAO products related to this review is shown at
the end of this report.

                                    Summary

The President's February 2006 report did not fully address the three
requirements of the National Defense Authorization Act of 1998. Therefore,
the report did not present the full implications of the threshold change
to Congress.

Worldwide Computer Availability Was Not Adequately Documented

Although the President's report indicated that foreign computing capacity
below the new control level is currently widely available, agency
officials (1) did not adequately document how they established the new
export control threshold at 0.75 WT on the basis of their assessment of
worldwide availability and (2) could not document that they verified key
information used in their decision. Defense said that a High Performance
Computer Working Group, established by Commerce and comprised of

U.S. government and industry representatives, evaluated and compared
information on computer systems and performance levels from government,
industry, academia, and intelligence sources. Officials said they also
held informal meetings and discussions with the computer industry on
technology developments. We reviewed the information the agencies
collected but could not determine the basis for selecting the new
threshold compared with other possible thresholds assessed because the
agencies did not document the steps leading to their decision.

Furthermore, officials said that they relied on a Top500 Supercomputer
List maintained by the University of Tennessee and the University of
Mannheim in Germany to help establish worldwide computer availability.
However, the information on the Top500 List is not verified by the U.S.
government; is self-reported by respondents13 to a questionnaire; and may
not be error-free despite their efforts to verify it, according to the
list's producers. Defense said in its comments that the Working Group
calculated the APP levels for the Top500 List computers, compared these
levels with Defense testing data on comparable systems, and found
consistent results. However, Defense did not disclose and document how
many systems from the Top500 List it reviewed when it made these
comparisons or whether these systems were in countries of concern.
Accordingly, the U.S. government determined the worldwide availability of
high performance computers on the basis of information that might not be
accurate and reliable.

Although not required by law, Commerce could have conducted a foreign
availability assessment, which is the principal mechanism identified in
the U.S. Export Administration Regulations for determining the
availability of controlled items. This assessment determines whether items
of comparable quality and quantity are

Respondents include high performance computer experts, computational
scientists, manufacturers, and the Internet community, according to the
Top500 List's producers.

available from non-U.S. sources that would render U.S. export controls on
the item ineffective.14

All Potential Military Uses of Computers Were Not Adequately Assessed

The President's report also did not adequately assess the potential
military uses of computers with performance capabilities at the new
threshold (0.75 WT). First, the report could have disclosed, but did not,
that U.S. government officials had identified 15 high performance
computing platforms15 that would no longer need to be reviewed for a
license at the new control threshold.16 Second, the report could have
discussed, but did not, how the new threshold would impact 29 computers
that Commerce licensed with extensive conditions for export since the
executive branch last raised the threshold in 2002 to 190,000 MTOPS. As a
result of the decision to move to the new level, all but 1 of those 29
computers would now be eligible for export without a license and without
conditions to countries of concern, such as China, India, and Russia.17
Rather than address all potential uses of military significance for these
computers, as required by law, the report provided selected examples of
computer applications, such as the design, development, and production of
weapon systems; military operations; and nuclear weapons design and
simulation. The report stated that the majority of computers used for
these purposes fall below the new and old thresholds for tier-3 countries.
It also provided some examples of national security applications that
require computer performance levels above the new threshold. Defense
officials stated that a strategic assessment of selected applications and
computing power at a given threshold would be more useful to Congress than
the assessment in the current reporting requirement, which they said is
too narrowly focused. However, the report did not provide this assessment,
either.

National Security Impact of Militarily Significant Computer Uses Was Not
Assessed

Since the President's report did not adequately assess the potential
military uses of computers at the proposed new threshold of 0.75 WT, it
did not assess the impact that militarily significant uses of those
computers would have on U.S. national security. Instead, the report
discussed how the new threshold would allow the United States to maintain
a technological lead by controlling the less widely available, most
advanced computer systems best suited for innovative national security
applications above the new threshold. In addition, Defense officials
stated that assessing the national security impact on computers between
the old and new thresholds would be very time-consuming and
resource-intensive.

1415 C.F.R. 768.

15

Computing platforms can operate at various performance levels based on the
number of processors available.

16

Licenses will continue to be required for some of these high performance
computers operating with a larger configuration of processors, according
to Commerce.

17

Since December 31, 2005, Commerce stated that it approved licenses to
export 2 additional computers above the new threshold of 0.75 WT to
countries of concern, such as China, India, and Russia.

Page 5 GAO-06-754R Export Controls and High Performance Computers

                       Agency Comments and Our Evaluation

We received written comments on a draft of this report from Commerce and
Defense, which are reprinted in enclosures I and II. Commerce and Defense
disagreed with our finding that the executive branch did not have a
rigorous process to establish the new computer control threshold. The
agencies stated that an interagency group compared information on computer
systems and performance levels from government, industry, academia, and
intelligence sources, and discussed the new threshold with foreign
governments. The agencies also said that the U.S. government verified
information on the Top500 List upon which they relied to evaluate
state-of-the-art systems and to help calculate the APP levels for high
performance computers. Accordingly, Commerce stated there is no basis to
assert that worldwide availability was determined on information that
might not be accurate and reliable.

Defense also disagreed with our finding that the President's report did
not adequately assess the potential military uses of computers with
performance capabilities at the new threshold or the impact such
militarily significant uses would have on U.S. national security. It
stated that Defense did not provide an exhaustive list of all potential
military applications because the number and diversity of military
applications and the rate of change in high performance computing make
comprehensive analysis of all potential applications, their national
security impact, and appropriate responses impractical. In addition,
Defense stated that we did not recognize the pace of technology
developments in computing and stated that systems have an average lifespan
of 3 to 6 years. Thus, according to Defense, many of the computers
exported during that time are or are becoming obsolete.

In response, we added some additional information to this report to more
fully describe the process and sources of information that Commerce used
to establish the new export control threshold. Although the interagency
group collected and analyzed a large amount of raw data on computer
performance levels, the documentation that the agencies provided did not
demonstrate how they met the requirements of the law or provide a
step-by-step approach that an outside reviewer could verify. For example,
we could not confirm that the U.S. government verified information on the
Top500 List. Commerce stated that agencies verified the list by comparing
the APP performance level of computers on the Top500 List with benchmark
data on comparable U.S. systems. However, Commerce did not provide
documentation on how many Top500 List computers Defense reviewed or
whether the systems assessed included those manufactured by countries of
concern. Moreover, Defense officials said in interviews that they did not
adequately document how they established the new export control threshold
at 0.75 WT on the basis of their assessment of worldwide availability.

We do recognize the rapid pace of technological change in the computing
industry. However, it is important to note that because certain computer
systems are no longer as useful to the U.S. government as newer systems
does not mean that these computers would not have some militarily
significant use for a country of concern.

Defense's assertion that it was impractical to provide an exhaustive list
of all potential military applications to meet the requirements of the law
is not noted in the

Page 6 GAO-06-754R Export Controls and High Performance Computers

President's report to Congress nor did the report indicate that the
executive branch sought legislative relief from this mandated requirement.

                             Scope and Methodology

To address the requirements of the National Defense Authorization Act of
1998, we reviewed the statutory requirements for the justification, the
documentation that executive branch officials said they used to support
the conclusions presented in the President's report, and the export
control regulations pertaining to high performance computers. We also
interviewed officials from the Departments of Commerce and Defense who
were responsible for producing the report.

We are sending this report to interested congressional committees and to
the Secretaries of Commerce and Defense. We will also make copies
available to other interested parties on request. In addition, the report
will be available at no charge on the GAO Web site at http://www.gao.gov.

Please contact me at (202) 512-8979 if you or your staff have any
questions concerning this report. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. Key contributors to this report include Stephen M. Lord,
Jeffrey D. Phillips, Ian Ferguson, Lynn Cothern, Hai Tran, and Mark
Speight.

Joseph A. Christoff Director, International Affairs and Trade

List of Congressional Committees

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

The Honorable Richard C. Shelby Chairman The Honorable Paul S. Sarbanes
Ranking Minority Member Committee on Banking, Housing, and Urban Affairs
United States Senate

The Honorable Duncan L. Hunter Chairman The Honorable Ike Skelton Ranking
Minority Member Committee on Armed Services House of Representatives

The Honorable Henry J. Hyde Chairman The Honorable Tom Lantos Ranking
Minority Member Committee on International Relations House of
Representatives The following are GAO's comments on the Department of
Commerce letter dated June 9, 2006.

                                  GAO Comments

1. We added additional information to this report to more fully describe
       the administration's review of U.S. export controls on high
       performance computers and sources of information that Commerce used to
       establish the new export control threshold and the role of the High
       Performance Computer Working Group.
2. Commerce stated that a company representative or individual who wants
       to enter his or her machine on the Top500 Supercomputer List must
       provide the results of testing and submit the results to random
       verification by the list's organizer. However, Commerce did not
       provide any documentation on how many or which systems the list's
       organizer randomly verified. Moreover, the list's producers
       acknowledged that information on the list is self-reported by
       respondents to a questionnaire and may not be error-free. Commerce
       also stated in its comments that agencies compared the Adjusted Peak
       Performance (APP) level of computers on the Top500 List with
       Department of Defense benchmark data on comparable systems and found
       comparable results. However, Commerce did not state or provide
       documentation on how many or which Top500 List computers Defense
       reviewed that were comparable to U.S. government systems. This would
       be important information to determine how many of the 500 systems the
       U.S. government reviewed and whether they included systems in or
       manufactured by countries of concern. Finally, Commerce stated that
       the Top500 List was verified by the U.S. government. On the basis of
       the documentation that the agencies provided, we cannot confirm that
       the U.S. government verified information on the Top500 List. In our
       original audit work, Defense and Commerce officials stated that they
       did not perform an independent analysis of computers produced by tier3
       countries, but that they relied on other sources of information to
       estimate the performance of such computers.
3. We disagree that conducting a formal foreign availability assessment
       would have resulted in a similar interagency review process. The
       President's report provided only anecdotal examples of the
       availability of high performance computers in countries of concern,
       such as China, India, and Russia, even though the report asserted that
       the new control threshold was based on the widespread foreign
       availability of computing capacity. A foreign availability assessment
       is the principal mechanism identified in the U.S. Export
       Administration Regulations for determining the availability of
       controlled items. This assessment would determine whether items of
       comparable quality and quantity are available from non-U.S. sources,
       thus rendering U.S. export controls on the item ineffective.
4. We disagree with Commerce's statement that the President's report was
       based on a rigorous, well-founded review to set the new control
       threshold and determine worldwide availability of high performance
       computers. Although the Working Group collected a large amount of
       information and raw data on computer performance levels, we found in
       interviews with Defense officials and our review of their data that
       agencies did not document their methodology or the steps leading to
       the new threshold of 0.75 Weighted TeraFlops (WT). The

Page 12 GAO-06-754R Export Controls and High Performance Computers

documentation that the agencies provided did not demonstrate a
step-by-step approach that an outside reviewer could follow to verify how
they reached their threshold decision.

5. We acknowledge these technical comments and modified our report to
address both points.

             Enclosure II: Comments from the Department of Defense

The following are GAO's comments on the Department of Defense letter dated
May 31, 2006.

                                  GAO Comments

1. We added additional information to our report to more fully describe
       the process and sources of information that Commerce used to establish
       the new export control threshold, and the role of the High Performance
       Computer Working Group. This group was not cited in the President's
       report. Although the Working Group collected and analyzed a large
       amount of information and raw data on computer performance levels,
       Defense officials said in interviews that they did not document their
       methodology or how they set the new threshold at the 0.75 WT level.
       The documentation that the agencies provided did not demonstrate a
       step-by-step approach that an outside reviewer could follow to verify
       how they reached their threshold decision.
2. Defense stated in its comments that agencies compared the APP level of
       computers on the Top500 List with Defense benchmark data on comparable
       systems and found consistent results. However, Defense did not state
       or provide documentation on how many or which Top500 List computers
       agencies reviewed that were comparable to U.S. government systems.
       This would be important information to determine how many of the 500
       systems the U.S. government reviewed and whether they included systems
       in or manufactured by countries of concern.
3. We recognize the rapid pace of technological change in the computing
       industry. However, because certain computer systems are no longer as
       useful to the U.S. government as newer systems does not mean that
       these computers would not have some militarily significant use for a
       country of concern. Moreover, the President's report does not identify
       the estimated numbers of computers available at a specific computing
       level in countries of concern. Thus, the report does not adequately
       assess the potential military uses or impact on U.S. national security
       that availability of these computer systems to countries of concern
       without a license would have.
4. Defense stated that it did not provide an exhaustive list of all
       potential military applications because the number and diversity of
       military applications and the rate of change in high performance
       computing make comprehensive analysis of all potential applications,
       national security impacts, and appropriate responses impractical.
       Defense officials said that to generate a list of applications to be
       used on certain levels of computers would require reviewing and
       analyzing an extensive amount of information. However, the President's
       report did not state the Defense view that the requirement is
       impractical, nor did the agencies indicate that they appealed for
       legislative relief.
5. The National Defense Authorization Act of 1998 requires the agencies
       to assess the potential military uses of computers at the new
       threshold and, therefore, the impact that changes in the control
       threshold will have on U.S. national security. Merely stating that
       Defense conducts national security-related work on computers at all
       performance levels does not respond to the requirement of the act to
       assess

Page 17 GAO-06-754R Export Controls and High Performance Computers

the national security uses that computers at the new performance threshold
can have. Thus, we believe it would be useful for the executive branch to
conduct this assessment and provide the results to Congress.

                              Related GAO Products

Export Controls: More Thorough Analysis Needed to Justify Changes in High
Performance Computer Controls. GAO-02-892. Washington, D.C.: August 2,
2002.

Export Controls: Inadequate Justification for Relaxation of Computer
Controls Demonstrates Need for Comprehensive Study. GAO-01-534T.
Washington, D.C.: March 15, 2001.

Export Controls: System for Controlling Exports of High Performance
Computing Is Ineffective. GAO-01-10. Washington, D.C.: December 18, 2000.

Export Controls: Challenges and Changes for Controls on Computer Exports.
GAO/T-NSIAD-00-187. Washington, D.C.: May 26, 2000.

Export Controls: National Security Risks and Revisions to Controls on
Computers.

GAO/T-NSIAD-00-104. Washington, D.C.: February 28, 2000.

Export Controls: Statutory Reporting Requirements for Computers Not Fully
Addressed. GAO/NSIAD-00-45. Washington, D.C.: November 5, 1999.

Export Controls: Implementation of the 1998 Legislative Mandate for High
Performance Computers. GAO/T-NSIAD-00-53. Washington, D.C.: October 28,
1999.

Export Controls: Information on the Decision to Revise High Performance
Computer Controls. GAO/NSIAD-98-196. Washington, D.C.: September 16, 1998.

Export Controls: Changes in Controls Applied to the Export of High
Performance Computers. GAO/T-NSIAD-98-250. Washington, D.C.: September 16,
1998.

Export Controls: National Security Issues and Foreign Availability for
High Performance Computer Exports. GAO/NSIAD-98-200. Washington, D.C.:
September 16, 1998.

(320413)

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