    Military Construction: Observations on Mismanagement of the
    Kaiserslautern Military Community Center (28-JUN-07,
    GAO-07-1039T).

    According to the Air Force, the Kaiserslautern Military Community
    Center (KMCC), an over 800,000 square-foot facility, is currently
    the Department of Defense's largest single-facility project under
    construction. It is intended to provide lodging, dining,
    shopping, and entertainment for thousands of U.S. military and
    civilian personnel and their families in the Kaiserslautern,
    Germany, area. Initial costs for the KMCC were estimated at about
    $150 million, with funding coming from a variety of appropriated
    and nonappropriated fund sources. The construction for the
    project, which began in late 2003, was originally scheduled to be
    completed in early 2006. This testimony discusses GAO findings to
    date related to the KMCC. The testimony describes (1) current
    problems facing the KMCC, (2) causes for identified problems, and
    (3) the effect of problems identified and their implications for
    future projects in Germany. To address our objectives, we
    interviewed officials from the U.S. Air Force, Army and Air Force
    Exchange Service, U.S. Army Corps of Engineers, and German
    government. We also conducted a site visit and reviewed relevant
    KMCC documents. We plan to continue our work and make
    recommendations to the Air Force as appropriate.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-07-1039T
        ACCNO:   A71613
      TITLE:     Military Construction: Observations on Mismanagement of
    the Kaiserslautern Military Community Center
         DATE:   06/28/2007
      SUBJECT:   Air Force facilities
    	     Construction contracts
    	     Contract administration
    	     Contract performance
    	     Contractor payments
    	     Cost analysis
    	     Cost overruns
    	     Internal controls
    	     International agreements
    	     Military cost control
    	     Military forces
    	     Performance management
    	     Program evaluation
    	     Risk management
    	     Schedule slippages

    ******************************************************************
    ** This file contains an ASCII representation of the text of a  **
    ** GAO Product.                                                 **
    **                                                              **
    ** No attempt has been made to display graphic images, although **
    ** figure captions are reproduced.  Tables are included, but    **
    ** may not resemble those in the printed version.               **
    **                                                              **
    ** Please see the PDF (Portable Document Format) file, when     **
    ** available, for a complete electronic file of the printed     **
    ** document's contents.                                         **
    **                                                              **
    ******************************************************************
    GAO-07-1039T

         * [1]Summary
         * [2]KMCC Currently Experiencing Substantial Cost, Schedule, and
         * [3]KMCC Problems Caused by Overseas Construction Risks, LBB-Kai

              * [4]Overseas Construction Risks
              * [5]LBB-Kaiserslautern Did Not Effectively Perform Required Duti

                   * [6]Flawed Project Design and Implementation
                   * [7]Ineffective Project Management

              * [8]Air Force Did Not Appropriately Minimize Risks

                   * [9]Air Force Lacked Necessary Staffing and Expertise for
                     Adequa
                   * [10]Air Force Policies and Control Procedures were
                     Inadequate

         * [11]KMCC Problems May Adversely Affect Military Members and Futu
         * [12]Concluding Comments
         * [13]GAO Contacts
         * [14]Appendix I: Scope and Methodology

              * [15]Order by Mail or Phone

    Testimony

    Before the Committee on Oversight and Government Reform, House of
    Representatives

    United States Government Accountability Office
    GAO

    For Release on Delivery
    Expected at 10:00 a.m. EDT
    Thursday, June 28, 2007

    MILITARY CONSTRUCTION

    Observations on Mismanagement of the Kaiserslautern Military Community
    Center

    Statement of Gregory D. Kutz, Managing Director
    Forensic Audits and Special Investigations

    Bruce A. Causseaux, Senior Level Specialist
    Forensic Audits and Special Investigations

    Terrell G. Dorn, Director
    Physical Infrastructure

    GAO-07-1039T

    Mr. Chairman and Members of the Committee:

    Thank you for the opportunity to discuss our initial findings related to
    our audit of the Kaiserslautern Military Community Center (KMCC). The KMCC
    is one of many projects that were initiated at Ramstein Air Base to
    upgrade the capabilities of the base as a result of the consolidation of
    military bases in Europe. According to the Air Force, the KMCC, an
    844,000-square-foot facility, is currently the Department of Defense's
    largest single-facility project. Funding for the project was provided from
    a variety of sources including nonappropriated funds from the Army and Air
    Force Exchange Service (AAFES) and Air Force Services Agency,1 military
    construction appropriations, and Rhein Main Transition Program funds.2 The
    KMCC is intended to provide lodging, dining, shopping, and entertainment
    for over 50,000 U.S. military and civilian personnel and their families in
    the Kaiserslautern, Germany, area. The KMCC won the Air Force 2006 Design
    Award for an outstanding design concept for its environmentally-friendly
    "green" roof,3 glass domes, and facades allowing maximum light into the
    facility, and its amenities to the Kaiserslautern military community.
    Project highlights include a 350-room visiting quarters, sports bar, name
    brand restaurant, food court, slot machines, and numerous retail
    businesses. Construction on the KMCC began in November 2003 and the
    building was planned to be completed in early 2006. This represented an
    expedited schedule developed to accommodate the need for additional
    visiting quarters resources resulting from the closure of Rhein Main Air
    Base in 2005.

    1AAFES is a joint military activity providing merchandise and services to
    active duty, guard and reserve members, military retirees, and their
    families. AAFES utilizes earnings to improve troops' quality of life and
    to support morale, welfare, and recreation programs. Air Force Services
    Agency provides combat support and community service programs that enhance
    the quality of life for Air Force members and their families. Air Force
    Service Agency programs include lodging, youth programs, and sports and
    fitness programs

    2The closure of the Rhein Main Air base is part of the Rhein Main
    Transition Program where the United States and Germany agreed to return
    the base to Germany. In return, Germany allowed the relocation of the
    base's key airlift capability to Ramstein and Spangdahlem Air Bases. As
    part of the agreement, the Federal Republic of Germany, federal states of
    Rheinland-Palatinate and Hessen, city of Frankfurt, and Fraport AG
    Frankfurt Airport Services Worldwide agreed to provide funds to upgrade
    the facilities at Ramstein and Spangdahlem Air Bases, including about 14
    million euros for KMCC.

    3According to a USAFE official, for KMMC, green roof refers to an
    environmentally engineered roof whereby soil and vegetation are placed on
    the roof of a structure in order to provide a reduction in energy costs,
    reduce water runoff, and offset the forest area cleared for a project.

    The activities of U.S. forces personnel in Germany are to be carried out
    in accordance with the provisions of the North Atlantic Treaty
    Organization's (NATO) Status of Forces Agreement (SOFA), the German
    Supplementary Agreement (SA) to the NATO SOFA, and the various
    administrative agreements that implement these two agreements. The KMCC,
    like other military projects constructed in Germany, is governed by one
    such agreement, the Auftragsbaugrundsaetze 1975 (ABG-75) Administrative
    Agreement. ABG-75 establishes specific procedures for construction of
    military projects, including the KMCC, in Germany. AGB-75 provides that
    U.S. forces are to coordinate construction planning with the German
    government to ensure the optimum use of German design and construction
    capacities. For the KMCC, the responsibility for construction resided with
    the Landesbetrieb Liegenschafts- und Baubetreuung office in Kaiserslautern
    (LBB-Kaiserslautern), a German government construction agency.

    As requested, this testimony highlights the findings to date from our
    audit of the KMCC. Specifically, the testimony will describe (1) the
    current problems facing the KMCC, (2) the causes for identified problems,
    and (3) the effect of problems identified and their implications for
    future projects in Germany.

    To address our objectives, we conducted interviews with officials from the
    U.S. Air Force, including U.S. Air Forces in Europe (USAFE) personnel
    responsible for the KMCC project and Air Force Services Agency. In
    addition, we interviewed officials from LBB-Kaiserslautern, AAFES, and the
    U.S. Army Corps of Engineers (USACE). We also obtained and reviewed
    project plans, cost estimates, and other relevant documents related to the
    design and construction of the KMCC. We physically inspected the KMCC and
    viewed the current status of the project. Our audit work was performed
    between May and June 2007 in accordance with generally accepted government
    auditing standards.

    Summary

    The KMCC project has encountered cost, schedule, and performance problems.
    Factors contributing to problems facing the KMCC include construction
    flaws, vandalism of property, contractor work stoppages and slowdowns
    resulting from delays in payments, and an ongoing fraud investigation.
    Originally scheduled to be completed over a year ago, continuing KMCC
    construction and financing problems are likely to delay its completion. In
    fact, problems are so severe that neither officials from
    LBB-Kaiserslautern nor the Air Force can now forecast the completion date
    of the project. Original cost estimates for the project totaled
    approximately $150 million. However current cost estimates total
    approximately $200 million and will likely increase in the future. Cost
    increases have been compounded because of the significant appreciation of
    the euro versus the U.S. dollar since inception of the project. The KMCC
    is also experiencing numerous performance problems resulting from design
    flaws, ineffective construction management, and substandard workmanship.
    For example, the KMCC's multimillion dollar roof is experiencing water
    leaks, which according to Air Force officials will likely require its
    replacement at a cost of millions of dollars. In addition, the Air Force
    delayed payments to some contractors because contractor invoices were for
    contracts which had already reached their contract cost ceiling. Because
    of the delay in payments, contractors drastically decreased their
    workforce from several hundred workers per day to about 50.

    Finally, project management of both LBB-Kaiserslautern and the Air Force
    have experienced significant changes including: (1) replacement of
    LBB-Kaiserslautern project managers, (2) firing of LBB-Kaiserslautern's
    construction management contractor, and (3) resignation of a senior Air
    Force civilian working on the project. In addition, several Air Force and
    LBB-Kaiserslautern personnel involved in the management of the KMCC are
    currently under investigation by Air Force Office of Special
    Investigations (AFOSI) and German police.

    The causes for the current problems facing the KMCC stem from risks
    associated with overseas construction, failures by LBB-Kaiserslautern to
    effectively perform its construction management duties, and failures by
    the Air Force to institute effective controls to mitigate project risks.
    Overseas construction projects pose additional risk due to differences in
    languages, laws, construction standards, and currency fluctuations when
    costs are denominated in the host country's currency. Almost all U.S.
    military construction in Germany must be done within the framework of
    ABG-75. ABG-75 largely gives the German government contracting agency
    control over projects and contractors while financial risks are borne by,
    in this case, the Air Force and its funding partners. ABG-75 generally
    gives the German government the authority to contract and manage
    construction of most U.S. facilities in Germany through what is called
    indirect contracting.4 In addition, ABG-75 requires the U.S. government to
    pay the German government construction agency a percentage fee based on
    the cost of the contract.5 As a result, German government construction
    agencies do not have an incentive to control costs because each dollar
    increase in the project costs results in increased fees for the German
    government construction agents.6

    4According to ABG-75, indirect contracting means the planning, execution,
    and administration of construction works are performed by the German
    government on behalf of the U.S. forces.

    In addition, LBB-Kaiserslautern did not effectively manage the KMCC
    project. The failures included LBB-Kaiserslautern's inability to maintain
    and implement a valid, updated construction schedule and to effectively
    coordinate work between multiple contractors. LBB-Kaiserslautern, and its
    architect-engineer contractor JSK, also did not adequately design the
    project prior to construction. Because of the poor design, Air Force
    officials estimate that millions of dollars of changes and rework were
    necessary as of June 2007. For example, the Air Force noted in the design
    review phase that KMCC's kitchen exhaust ducts as designed did not meet
    U.S. fire safety standards. However, because the Air Force design comment
    was not incorporated by LBB-Kaiserslautern, hundreds of thousands of
    dollars of rework on the KMCC's exhaust ducts will be necessary. In
    addition, LBB-Kaiserslautern acknowledged that it was vastly understaffed
    to effectively manage a project the size of the KMCC. This understaffing
    resulted in LBB-Kaiserslautern being unable to process the large number of
    change orders that arose from the project. According to Air Force
    officials, this resulted in work related to more than 400 contract changes
    being billed to the Air Force without supporting documentation.7

    Despite the high risks surrounding the KMCC, Air Force officials failed to
    institute effective management oversight and controls in order to mitigate
    the high risk from the project. Had LBB-Kaiserslautern done an effective
    job of managing the project, the lack of Air Force controls would have
    been mitigated. Unfortunately, as stated above, LBB-Kaiserslautern did not
    manage the project effectively and therefore increased the importance of
    effective Air Force controls. Normally the Air Force hires USACE to
    oversee projects in Germany to provide assurance that construction,
    procurement, and financial controls are in place and U.S. interests are
    protected. However, for the KMCC, the Air Force elected not to use USACE,8
    and subsequently did not institute sufficient controls of their own to
    mitigate the project risks. The Air Force did not have sufficient staffing
    to oversee the project, given its complexity. According to Air Force
    officials, they initially had about 8 personnel on the project but have
    recently increased staff to 17 personnel. However, the Air Force still
    does not have experts, such as contracting officers or certifying
    officials, on-site to provide assurance that all requirements of the
    contract are met. As a result, the Air Force did not properly review many
    invoices prior to payment--tasks that a contracting officer or certifying
    official would be expected to perform. In addition, because of internal
    demands to complete the project on an expedited basis to accommodate needs
    rising from the closure of Rhein Main Air Base, the Air Force instituted
    processes that circumvent its main controls for monitoring costs
    associated with the project. Although ABG-75 allows all U.S. forces the
    right to reject invoices for which the contract or change order were not
    previously approved, Air Force project management instructed its staff to
    approve invoices that included items listed on certain change orders that
    had not been submitted to or approved by the Air Force. In addition, the
    Air Force instructed its staff to approve invoices where quantity
    limitations specified in the contracts were exceeded as long as
    LBB-Kaiserslautern provided a form letter stating the price was fair and
    the work was necessary. Therefore, despite risks associated with the KMCC,
    the Air Force elected to reduce controls instead of increasing their
    oversight of the project.

    5Thus, the total cost for the KMCC is the cost of the contracts that the
    German government construction agent negotiated with contractors for
    constructing the building plus the fee for the German government
    construction agent.

    6LBB-Kaiserslautern for the KMCC is reimbursed 5.6 percent of the total
    cost of the project as its fee for managing the construction on behalf of
    the U.S. forces.

    7The 400 contract changes refer to changes in the project that were
    approved by LBB-Kaiserslautern, but have not been submitted to the Air
    Force. The extent of documentation provided to the Air Force justifying
    the need for the changes has been limited to a one-line description.
    Although requested, LBB-Kaiserslautern did not provide any additional
    documentation to us to substantiate the existence or justification for
    these changes.

    Cost increases and schedule delays will most significantly affect AAFES
    and the Air Force Services Agency, the primary funding sources for the
    project. For example, according to an AAFES official, recent estimates by
    AAFES, the largest contributor to the KMCC, forecast its portion of the
    total KMCC cost will end up doubling its original cost estimate. As a
    result, the reduction in AAFES return on investment from the KMCC caused
    by escalating costs may reduce profits and thus may diminish future
    funding of morale, welfare, and recreational activities for U.S. service
    members. In addition, as a result of the higher KMCC costs, AAFES and the
    Air Force Services Agency are also likely to have less funding for their
    other planned capital projects, such as the construction or renovation of
    their stores. Also, because of the delay in the completion of the visiting
    quarters portion of the KMCC, which was needed to accommodate the
    additional quarters requirements arising from the closure of Rhein Main
    Air Base, service members in transit to and from other locations, such as
    Iraq and Afghanistan, may also be forced to stay off-base, at additional
    cost to the government. Finally, Air Force officials estimate there is at
    least $400 million in additional operations and maintenance projects and
    military construction projects planned in Germany over the next 5 fiscal
    years. Absent better Air Force controls, these projects may experience the
    same types of heightened risks associated with KMCC.

    8Air Force officials stated that they did not use USACE because of the
    limited amount of military construction funds associated with the KMCC
    project and additional costs associated with using USACE.

    KMCC Currently Experiencing Substantial Cost, Schedule, and Performance Problems

    The KMCC currently faces significant cost, schedule, and performance
    problems, and it is unclear as to when the project will be completed and
    at what cost. Despite being originally scheduled to open in early 2006,
    neither LBB-Kaiserslautern nor the Air Force can estimate a completion
    date for the project because of the widespread construction management
    problems. In addition, estimated costs associated with the KMCC have
    already exceeded original estimates and will continue to grow.
    LBB-Kaiserslautern mismanagement has caused numerous problems with the
    KMCC. Examples include poor designs, substandard workmanship on key
    building components, and a significant reduction in the number of workers
    on-site. Furthermore, there may be fraud within the project, which is
    supported by the fact that there are ongoing criminal and civil
    investigations by AFOSI and German police.

    The latest official design schedule completed by LBB-Kaiserslautern and
    provided to the Air Force in September 2006 indicated that the KMCC would
    be completed by April 2007. However, during our visit to the KMCC in May
    2007, LBB-Kaiserslautern and Air Force officials stated that key milestone
    dates from the most recent design schedule had obviously slipped. In fact,
    neither LBB-Kaiserslautern nor Air Force officials could provide a new
    estimated project completion date during our audit of the project. Also,
    both LBB-Kaiserslautern and the Air Force provided us current cost
    estimates of about $200 million, which have already exceeded the original
    estimate of about $150 million. We found that these cost estimates did not
    include substantial costs related to the expected roof repair and
    replacement discussed later, as well as hindrance claims associated with
    the project.9 Furthermore, the Air Force contract with LBB-Kaiserslautern
    is denominated in euros and therefore the U.S. cost equivalent varies with
    the exchange rate. For example, the original cost estimate of about $150
    million was developed in 2003 when 1 dollar was able to purchase
    significantly more in euros than 1 dollar can currently purchase. Figure 1
    below shows the trend in the strengthening of the euro against the U.S.
    dollar over the past several years.

    Figure 1: Currency Exchange Rates for Euros since 2003

    The schedule delays associated with the KMCC have compounded cost problems
    because of the appreciation of the euro versus the U.S. dollar. Given the
    substantial costs associated with repairs to the roof, schedule delays,
    and potential hindrance claims by contractors, assuming currency rates
    remain higher than they were for the original project budget, the
    appreciation of euros versus the U.S. dollar compounds the effect of cost
    overruns on this project.

    9Hindrance claims refer to claims against the United States for additional
    costs contractors incurred due to interruption of contractor work.

    Since the start of construction in 2003, the KMCC has experienced numerous
    problems including poor design, substandard workmanship, poor coordination
    of the different contractors, and a reduction of workers on the site. Some
    of the more notable problems associated with this project include the
    following:

               o Roof: The roof is experiencing water leaks causing considerable
               damage to the walls and the floors of the complex. According to
               Air Force officials, since the contractor responsible for roof
               construction went bankrupt, KMCC funding sources from the United
               States (AAFES, Air Force Services Agency, and Military
               Construction funds) will likely be used to pay the estimated
               millions of dollars in costs required to repair or replace the
               entire roof along with any internal damage. Figure 2 shows some
               damage in the KMCC resulting from the leak in its roof.

               Figure 2: KMCC Damage from Leaks in Roof

               o Exhaust ducts: The kitchen exhaust ducts installed in the KMCC
               do not comply with fire code standards established by the National
               Fire Protection Association.10 According to Air Force officials,
               it will take several months to make the exhaust ducts compliant
               with the fire codes at a cost of hundreds of thousands of dollars.

               o Bathroom faucets: Design plans called for some of the bathroom
               faucets in the KMCC to be automatic where water would turn on when
               a motion sensor indicated the presence of a person. However
               faucets and walls were installed prior to the electrical
               contractor installing wires needed to power the automated faucets.

               o Vandalism: In April 2006, vandalism occurred in over 200 rooms
               inside the KMCC. The cost to repair damage caused by the vandalism
               is estimated to be over $1 million. To make matters worse, as
               shown in figure 3, due to poor project coordination, a German
               contractor installed light fixtures on top of the vandalized
               walls. These lights will need to be removed to enable wall repairs
               to be made and then reinstalled.

    10National Fire Protection Association 96: Standards for Ventilation
    Control and Fire Protection of Commercial Cooking Operations.

               Figure 3: Light Fixture Installed on Top of Vandalized Wall

               o Reduction of construction workers: In the past several months,
               the KMCC has faced a drastic reduction of the number of workers
               on-site. LBB-Kaiserslautern officials attributed this decrease to
               slow payment for services and reduced payment amounts from the Air
               Force due to increased scrutiny of invoices by the Air Force. The
               Air Force has delayed the payments to certain contractors because
               the total amount of charges billed to the Air Force has already
               risen to the contract cost ceiling for the specific contractor.
               Therefore, the Air Force has been unable to pay those contractors
               for work performed without a contract change order to increase the
               contract ceiling. As a result, many of the contractors either
               reduced the number of workers or have quit working altogether on
               the project. Prior to September 2006, the number of workers on the
               site was normally several hundred. Currently, the number of
               workers on the site is routinely less than 50.

               In addition to the construction problems faced by the KMCC, there
               have been a number of personnel who have been removed or have
               resigned from the project. In the past year, project management
               officials from LBB-Kaiserslautern have been replaced. Also, JSK,
               the firm hired by LBB-Kaiserslautern to manage the KMCC, was
               fired. Finally, a senior Air Force civilian in charge of the
               project resigned from the position and left the Air Force in 2006.
               On top of those personnel changes, both the AFOSI and the German
               Police have ongoing investigations into the project. The
               investigations span a variety of issues, both criminal and civil,
               including the investigations of Air Force project management
               officials as well as German government officials. In the past
               year, both Air Force and LBB-Kaiserslautern offices have been
               searched and documentation seized by both AFOSI and German police
               in relation to these investigations.

    			  KMCC Problems Caused by Overseas Construction Risks,
    			  LBB-Kaiserslautern Management Deficiencies, and Lack of Air Force
    			  Controls

               Current problems facing the KMCC have been caused by the
               additional risks associated with overseas construction, project
               management deficiencies by LBB-Kaiserslautern, and the Air Force's
               lack of effective controls to mitigate project risks. Guidelines
               set forth in ABG-75 add risk to the contract management process
               for U.S. forces construction in Germany. In addition, during the
               design and construction of the KMCC, the German government
               construction agent, LBB-Kaiserslautern, did not effectively carry
               out its project design and construction management duties.
               Finally, the Air Force failed to recognize risks associated with
               the KMCC and develop control procedures to minimize project risks.
               Because the most significant control that the United States can
               exercise over construction projects in Germany is financial
               control, the Air Force should have increased the project oversight
               controls to identify any invalid, unsupported, or inaccurate costs
               before money was spent. Instead, the Air Force did not have basic
               oversight and in some cases has circumvented controls in order to
               expedite payments.

    			  Overseas Construction Risks

               The KMCC presented increased risk from the beginning because U.S.
               forces are not in direct control of construction projects in
               Germany. Under the terms of ABG-75, most U.S. military
               construction projects are required to be executed by German
               government construction agencies, in this case LBB-Kaiserslautern,
               in accordance with German laws. This includes all contractual
               authority for design, bid tender and award, project execution,
               construction supervision, and inspection for all military projects
               within Germany. As such, the German government construction agency
               contracts directly with the design and construction companies
               responsible for a given project. As a result, the United States is
               required to work through this indirect contracting method, and
               does not have any direct legal relationship with the contractors
               for construction projects that are to be built on their behalf.

               According to Air Force officials, because ABG-75 gives the German
               government such broad powers in the construction of military
               projects, the United States has limited influence on how
               construction projects are built. For example, Air Force officials
               stated that they were initially resistant to use a trade lots11
               acquisition strategy for the construction of the KMCC because of
               the complexity involved with coordinating and managing the
               contractors associated with this strategy. Air Force officials
               stated that they relented to German government demands for trade
               lots after it was pointed out that the method of contracting was
               clearly within the German government's prerogative under ABG-75.
               ABG-75 stipulates that the U.S. government pay German government
               construction agencies (e.g., LBB-Kaiserslautern) between 5 and 7
               percent of the project cost for administering the contract
               regardless of the total project costs with no incentives for early
               completion. As a result, no incentive exists to minimize costs or
               encourage early completion.

               Despite additional risks associated with ABG-75, U.S. forces do
               have some leverage in managing construction projects in Germany.
               Specifically, under ABG-75, the United States is granted the
               authority to approve designs and provide prior consent to any
               modifications to the construction contract (also known as "change
               orders") that affect the scope, quality, or cost of the project.
               Any excess costs must be approved in advance by U.S. forces, and
               the forces are not liable for costs proved to be the fault of
               German officials or contractors. Thus, U.S. forces do have the
               "power of the purse" which can be used to pay only for costs
               within the scope of the contract. According to Air Force
               officials, the Air Force has the ability to cut off funding for
               its projects. However, since the projects are needed for base
               operations, such a step would only be used as a last resort.

               Finally, general risks associated with overseas construction
               projects add to an already risky situation. Increased complexities
               of overseas projects include differences in languages, culture,
               construction laws, safety regulations, and exposure to changes in
               currency exchange rates. Changes in currency exchange rates can
               pose a significant risk when project costs must be paid in the
               host country's currency, especially when projects take
               substantially longer to complete than originally planned. Despite
               risks associated with overseas construction, the Air Force did not
               institute sufficient controls to manage the project.

    11The use of trade lot contracts refers to the practice of contracting
    directly with individual companies for specific sections of work on a
    larger project instead of contracting with one general contractor who then
    subcontracts out the specific tasks.

               LBB-Kaiserslautern Did Not Effectively Perform Required Duties for
    			  the KMCC

               During the design and construction of the KMCC, LBB-Kaiserslautern
               did not effectively carry out its project design and construction
               management duties. LBB-Kaiserslautern's deficiencies in these
               areas have contributed to additional costs, schedule delays, and
               increased financial risk to the U.S. government for the KMCC
               project.

    			    Flawed Project Design and Implementation

               The design of the KMCC was inadequate and resulted in numerous
               instances of rework costing millions of dollars to fix.
               LBB-Kaiserslautern hired an architect-engineer firm, JSK, to draft
               plans for the KMCC, and subsequently contracted with JSK to be the
               construction manager. According to Air Force and AAFES officials,
               numerous design flaws were identified by the Air Force in the
               initial design review of the KMCC and were communicated to both
               LBB-Kaiserslautern and JSK. However, according to these U.S.
               officials, neither LBB-Kaiserslautern nor JSK incorporated many of
               their comments into the final design, which later resulted in
               additional work and costs. Air Force officials stated that, as of
               June 2007, they have identified millions of dollars of additional
               work required because of identifiable design flaws, which the Air
               Force plans to pay for in order to keep construction work moving
               forward.

               The following are some examples of design and construction flaws
               for the KMCC project:

               o Exhaust ducts: During review of the initial KMCC design, Air
               Force identified and commented to LBB-Kaiserslautern and JSK that
               the exhaust ducts used in the restaurant kitchens did not meet
               U.S. fire safety standards. However, LBB-Kaiserslautern and JSK
               failed to ensure the change was addressed by contractors
               responsible for duct construction. As a result, the exhaust ducts
               installed at the KMCC were not compliant with U.S. fire safety
               standards. In addition, when we toured the KMCC, an Air Force
               official showed us the material used to seal the exhaust ducts.
               According to the official, this material was flammable and, as
               such, posed a safety risk when hot gasses are vented through the
               exhaust ducts. Because of the poor design of the exhaust ducts,
               the Air Force has recently approved a change order for hundreds of
               thousands of dollars to fix the problem. Figure 4 below is a
               picture of the flammable sealant used in the kitchen exhaust
               ducts.

               Figure 4: Flammable Sealant Inappropriately Used in Kitchen
               Exhaust Ducts

               o Retail space ceiling: The design of the ceiling in the AAFES
               retail area was not adequate to support light fixtures. The design
               detailed an open-grid suspended ceiling (not fitted with tiles)
               with light fixtures fitted into some of the openings. However,
               during installation, workers discovered that the ceiling grid was
               not strong enough to support the light fixtures. Ceiling tiles
               stabilize the grid to keep it from shifting, so omitting the tiles
               weakened the grid to the point where the light fixtures could not
               be supported. As a result of this design error, a contract change
               was necessary in order to provide additional steel supports for
               the ceiling grid.

               o Escalator/escalator pit: Poor design and construction
               coordination caused problems with installation of the building's
               escalator. The escalator pit was initially built as part of the
               contract to construct the building's concrete floor. A subsequent
               contract was issued for installation of the escalator itself.
               However, the contract specifications for the escalator
               installation did not sufficiently detail the size and location of
               the escalator pit, and the escalator provided by the contractor
               did not fit in the previously-built pit. As a result, rework was
               necessary to build a new pit in the proper location.

    			    Ineffective Project Management

               LBB-Kaiserslautern did not effectively manage the KMCC project.
               Instead of using a general contractor who would be contractually
               responsible to build the project, LBB-Kaiserslautern attempted to
               execute the project by managing more than 30 separate trade lot
               contracts by itself. Each trade lot contractor was only
               responsible for its section of work, and no one party, other than
               LBB-Kaiserslautern, was responsible for the overall completion of
               the project. In addition, the LBB-Kaiserslautern's decision to use
               trade lot contracts also meant that LBB-Kaiserslautern would be
               required to properly coordinate the effort of all the contractors,
               adequately staff the project, and appropriately monitor
               construction schedule and costs, so that work could progress. As
               described below, LBB-Kaiserslautern did not carry out its
               requirements in the following areas:

               o Poor project coordination: LBB-Kaiserslautern did not
               effectively coordinate the work of the more than 30 construction
               contractors on-site. This resulted in inefficiencies in
               construction as well as damage to finished work. For example, one
               contractor responsible for installing a tile floor was forced to
               delay work while the contractor responsible for installing the
               ceiling finished work over the area where the floor was to be
               installed. In another case, the contractor responsible for laying
               the paving stones outside the building was allowed to finish its
               work before major exterior construction was completed. This
               resulted in damage to the paving stones when heavy cranes were
               subsequently used on top of the stones to install exterior bracing
               to the building.

               o Inadequate staffing: In our interviews, LBB-Kaiserslautern
               officials told us that their office was understaffed.
               LBB-Kaiserslautern officials stated that this lack of staffing
               hindered LBB-Kaiserslautern's ability to provide assurance that
               the project design was adequate and improve contractor
               coordination discussed previously. In part, as a result of the
               above listed design and coordination problems, numerous contract
               change orders were necessary. Again, the lack of staffing hindered
               LBB-Kaiserslautern's ability to process necessary change orders as
               required by ABG-75.12 According to Air Force officials, there are
               hundreds of change orders that LBB-Kaiserslautern has approved,
               yet has not submitted documentation to the United States for
               approval. Many of these change orders also had corresponding
               invoices submitted and certified by LBB-Kaiserslautern that the
               Air Force subsequently paid. LBB-Kaiserslautern was only able to
               provide us a listing of the change orders involved. This was far
               less than the detailed specifications required for review by the
               Air Force prior to the approval of the change and payment.

               Air Force officials also stated that this failure to process
               change orders was a major problem because this processing serves
               as the basis for increasing the obligation authority for the
               contract. In addition, LBB-Kaiserslautern officials stated they
               had approved the work for most of these change orders and thus the
               contractors performed the work and were expecting payment.
               According to Air Force officials, in some cases when the Air Force
               refused to make payment on the unapproved changes, contractors
               halted work and sent notices to the LBB-Kaiserslautern that they
               would be liable for any costs associated with delays in payment.
               In many cases, the Air Force chose to reduce controls and make
               payments on these items despite not having appropriate change
               order documents in an attempt to keep the work on the project
               progressing.

               The lack of staff also hindered LBB-Kaiserslautern's ability to
               sufficiently monitor the quality of the contractors work. For
               example, as stated previously, the KMCC roof is leaking
               substantially because LBB-Kaiserslautern did not properly monitor
               the contractor's work. Because of this, the Air Force is facing
               potentially millions of dollars in additional costs to replace the
               poorly built roof.

               o Unreliable construction schedule and cost estimates:
               LBB-Kaiserslautern is responsible for providing the Air Force with
               up-to-date detailed construction schedules and cost estimates.
               According to Air Force officials, the latest official construction
               schedule provided by LBB-Kaiserslautern was in September 2006 and
               showed a completion date of March 2007 for the visiting quarters
               and April 2007 for the mall portion of the KMCC. During our visit
               in May 2007, LBB-Kaiserslautern officials stated that they do not
               have a current construction schedule or completion date
               established for the project. Despite the lack of an estimated
               completion date, LBB-Kaiserslautern officials had developed an
               estimate of the total KMCC cost at completion. This estimate
               currently projects that costs will be higher than original
               estimates of approximately $150 million. According to
               LBB-Kaiserslautern officials, this cost estimate does not include
               certain expected costs, which we consider significant. For
               example, as stated earlier, the roof on the facility is
               continually leaking and likely will need to be replaced. Air Force
               and AAFES officials estimate that the cost to replace the roof
               will be in the millions of dollars. In addition to roof estimates,
               there are additional costs associated with hindrance claims that
               were not included in the cost estimate. In fact, in May of 2007,
               LBB-Kaiserslautern officials stated they received a single claim
               for several million dollars, which has not been substantiated,
               from just one of the more than 30 contractors. Finally,
               LBB-Kaiserslautern cost estimates do not include adjustments for
               future cost increases on existing contracts. Although past
               experience on this project has shown that many of the contract
               amounts have increased due to change orders or quantity increases,
               LBB-Kaiserslautern did not include any estimates for these
               expected future increases.

    12During normal construction work done under the ABG-75 agreement,
    contractors perform work as specified in the original contract. When
    changes to the original contract are necessary, U.S. forces are to be
    given advance notice of any change and must give their approval before
    work can begin. This notice and approval process would be accomplished by
    LBB-Kaiserslautern through development of a contract change order document
    which specifies the details of the change, cost, and other related
    information. Once documents are approved by the U.S. forces, work can be
    initiated.

               Air Force Did Not Appropriately Minimize Risks

               The Air Force did not incorporate sufficient controls to minimize
               the significant project risks involved with the KMCC. Control
               deficiencies included inadequate staffing, poor policies, and a
               lack of effective control processes in place. By not utilizing
               controls that were available to them through the ABG-75 agreement,
               the Air Force has given up any leverage it had on keeping project
               costs within budget. These control weaknesses contributed to
               schedule and performance problems without a sufficient reaction
               from the Air Force. In addition, after problems were identified,
               the Air Force did not take appropriate corrective actions.

    			    Air Force Lacked Necessary Staffing and Expertise for Adequate
    				 Oversight

               Air Force officials did not have adequate staff with appropriate
               expertise needed to oversee the KMCC. In 2002, the Air Force
               elected not to use the USACE as the servicing agent for the KMCC
               project. According to the Air Force officials, they were not
               required to use the USACE on this project because only a small
               percentage of the KMCC funds were based on appropriated military
               construction funding. However, in foregoing USACE oversight, the
               Air Force did not establish adequate staffing or contracting and
               construction management expertise needed for a project as complex
               as the KMCC. According to Air Force officials, at the inception of
               the project, there were approximately eight full time personnel
               assigned to the KMCC from the Air Force. In addition, the limited
               number of Air Force staff did not have adequate expertise in the
               areas of contracting or construction management. As of May 2007,
               no contracting officers or certifying officials have been assigned
               to the KMCC. 13 These experts are trained and certified to
               obligate and spend funds on behalf of the U.S. government and
               would typically be found in any military construction-funded
               project.14

               As a result of the lack of staffing with adequate contracting and
               construction management expertise, many invoices came into the Air
               Force office, overwhelming the ability of the staff to adequately
               review invoices prior to payment. According to Air Force
               officials, no invoices were disputed prior to September 2006.
               However, after September 2006 when significant problems with the
               KMCC were recognized, some staffing improvements were made. For
               example, the Air Force increased the number of personnel to
               approximately 17 full time personnel currently on site, because it
               became apparent that they did not have sufficient personnel to
               conduct adequate reviews of invoices. Since the increase in staff,
               the Air Force has been able to review invoices more thoroughly,
               and according to Air Force officials, the percentage of recent
               invoices disputed increased to 75 percent.

    			    Air Force Policies and Control Procedures were Inadequate

               The Air Force did not have adequate policies and control
               procedures in place for the management of the KMCC. At the
               beginning of the project, project management officers lacked a
               standard operating procedure to follow. According to Air Force
               officials, the only written process in place was a simple one-page
               process flow chart to delineate how the entire process was
               supposed to work. Since the recognition of numerous problems
               associated with the KMCC, the Air Force has instituted additional
               control procedures, such as increased invoice reviews, but has not
               formalized those procedures into a written operating procedure.

               We were unable to determine if there were any specific procedures
               in place prior to September 2006. However, the project schedule
               slippage and lack of disputes of invoices by the Air Force
               indicates that the controls in place were not fully effective.
               When we asked the Air Force officials about control procedures in
               place prior to September 2006, several officials, who were working
               on the project during the time in question, stated they were
               unable to answer questions based on advice from their legal
               counsel. The same officials who declined to answer questions
               stated that the project was under investigation by AFOSI. In
               addition, a senior Air Force civilian on the project prior to
               September 2006 had resigned and was therefore unable to answer
               questions. Without written procedures or explanations from Air
               Force staff, we could not determine what controls, if any, existed
               prior to September 2006.

    13For example, a German national employed by the Air Force has been
    obligating and expensing millions of dollars spent on the KMCC. This
    official is neither a contracting officer nor a certifying official but
    rather what the Air Force calls their ABG-75 specialist.

    14According to a USACE official, the USACE makes it a standard practice to
    have a contracting officer involved in all of their projects.

               In September 2006, Air Force officials recognized that significant
               problems faced the project. One problem specifically recognized
               was that numerous payments were made on invoices for work that had
               been billed on the 400 contract changes, which lacked
               documentation and had not been previously approved by the Air
               Force. Upon this recognition, the Air Force attempted to institute
               controls going forward. For example, the Air Force instituted a
               closer review of invoices to identify items that were billed but
               were not approved by the United States through change orders.
               However, under pressure to keep the project moving forward to
               completion, the Air Force subsequently relinquished much of this
               control by expediting the payment of invoices upon receipt from
               LBB-Kaiserslautern including charges for unapproved work. Examples
               of the relaxing of these controls include:

               o paying invoices submitted after September 2006 on work billed to
               the Air Force related to the 400 contract changes which had not
               been submitted by LBB-Kaiserslautern, and

               o approving invoices even though the line item quantities greatly
               exceed contracted amounts.

               The Air Force stated the decision to relax the controls was made
               so that construction proceeded as expeditiously as possible on the
               KMCC.15 Despite the removal of these controls, the number of
               workers on-site has still decreased significantly. In addition,
               Air Force officials stated that they viewed these payments on
               unapproved work as "partial payments" of expenses, and that any
               disputes in payments could be recouped upon project completion.
               However, we have reported in the past that such "pay and chase"
               strategies are not effective and increase risks substantially to
               recover the unapproved amounts. The Air Force was unable to
               provide any examples were the United States had successfully
               recouped overpayments in German courts.

    15The Air Force continues to look for ways to relax controls to expedite
    payment. For example, the Air Force is studying whether to approve change
    orders based on contractor's initial offer instead of negotiated amount,
    as is typically required.

               KMCC Problems May Adversely Affect Military Members and Future
    			  Construction Projects

               The substantial schedule and cost overruns of the KMCC may affect
               military personnel and have major implications for future projects
               in Germany. The effects of these cost increases are likely to be
               shouldered by our men and women in the military. AAFES, the
               largest financial contributor to the KMCC, has stated that cost
               overruns have reduced the return of investment (e.g., the amount
               of profit they plan to receive from the project). As a result,
               AAFES and Air Force Services Agency funding of morale, welfare,
               and recreational activities for U.S. military members may be
               reduced. In addition, the escalation in costs may also affect the
               ability of AAFES and the Air Force Services Agency to finance
               future capital projects from its nonappropriated funds. Further,
               because of the delay in the completion of the visiting quarters
               portion of the KMCC, service members on travel to other locations,
               including Iraq and Afghanistan, may have to stay off-base. In
               addition to the inconvenience that this places on service members,
               the Department of Defense--and thus taxpayers--must fund the
               additional cost of any required temporary lodging off-base, which
               the Air Force estimates to be approximately $10,000 per day or
               $300,000 per month.

               In addition to the effect on military members and their families,
               the current Air Force project management weaknesses may have
               implications for future Air Force construction in Germany. The Air
               Force planned construction within the Federal Republic of Germany
               for the next 5 fiscal years totals more than $400 million. These
               construction projects include small operations and maintenance
               projects (such as school renovations and road repairs) and major
               military construction projects (such as a $50 million clinic and a
               $50 million base exchange and commissary). Absent better Air Force
               controls, these projects may experience the same types of
               heightened risks associated with KMCC.

    			  Concluding Comments

               Although one of the major problems with KMCC related to
               ineffective project management by LBB-Kaiserslautern, the Air
               Force did not effectively institute oversight to mitigate the
               high-risk nature of the entire project. By the time the Air Force
               started making an attempt at oversight, the project was already
               several months past the original construction deadline of early
               2006. With mounting problems including contractors walking off the
               job, the Air Force faces the dilemma of instituting controls far
               too late in the process and further extending the completion of
               the project versus paying whatever it costs to get the job done as
               quickly as possible. The likely substantial cost overruns and
               potential years of schedule slippage will negatively affect
               morale, welfare, and recreation programs for DOD service members,
               civilians, and their families for years. The Air Force needs to
               seriously consider substantial changes in oversight management
               capabilities for the hundreds of millions of dollars of planned
               construction projects planned in Germany over the next several
               years.

               Mr. Chairman and Members of the committee, this concludes our
               statement. We would be pleased to answer any questions that you or
               other members of the committee may have at this time.

    			  GAO Contacts

               For further information about this testimony, please contact
               Gregory Kutz at (202) 512-7455 or kutzg@gao.gov or Terrell Dorn at
               (202) 512-6293 or [16]dornt@gao.gov . Contacts points for our
               Offices of Congressional Relations and Public Affairs may be found
               on the last page of this testimony.

    			  Appendix I: Scope and Methodology

               To assess the current problems facing Kaiserslautern Military
               Community Center (KMCC), we interviewed agency officials from the
               Air Force at Ramstein Air Force Base in Germany. We physically
               inspected the KMCC facility with an Air Force project manager and
               documented construction problems. We also reviewed financial
               records and statements in the form of contracts, change orders,
               and invoices to the extent that they were available.

               To examine the effect the Auftragsbaugrundsaetze 1975 (ABG-75) had
               on the management of the KMCC project, we reviewed the ABG-75
               agreement, which outlines construction requirements for U.S.
               forces stationed in Germany. In addition, we conducted interviews
               with officials from the Air Force, Landesbetrieb Liegenschafts-
               und Baubetreuung (LBB) the German government construction agency,
               and the U.S. Army Corps of Engineers.

               In order to determine the management weaknesses of LBB and the Air
               Force, we interviewed officials from both organizations, conducted
               interviews with other organizations affected by the KMCC project
               including the Air Force Office of Special Investigations (AFOSI),
               Air Force Audit Agency, Air Force Services Agency, and the Army
               and Air Force Exchange Service. We also reviewed applicable
               Department of Defense Financial Management Regulations as well as
               the National Fire Protection Association standards.

               To assess the effect that control weaknesses found in the KMCC
               project could have on future the Air Force projects in Germany, we
               obtained information from the Air Force on future construction
               plans in Germany. We also interviewed Air Force officials to
               determine what changes in processes had been made that would
               affect future construction projects.

               We performed our audit work from May 2007 through June 2007. Audit
               work was conducted in accordance with generally accepted
               government auditing standards.

    			  GAO's Mission

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

    			  Obtaining Copies of GAO Reports and Testimony

               The fastest and easiest way to obtain copies of GAO documents at
               no cost is through GAO's Web site ( [17]www.gao.gov ). Each
               weekday, GAO posts newly released reports, testimony, and
               correspondence on its Web site. To have GAO e-mail you a list of
               newly posted products every afternoon, go to [18]www.gao.gov and
               select "Subscribe to Updates."

    			  Order by Mail or Phone

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

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

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

    			  To Report Fraud, Waste, and Abuse in Federal Programs

               Contact:

               Web site: [19]www.gao.gov/fraudnet/fraudnet.htm E-mail:
               [20]fraudnet@gao.gov Automated answering system: (800) 424-5454 or
               (202) 512-7470

    			  Congressional Relations

               Gloria Jarmon, Managing Director, [21]JarmonG@gao.gov (202)
               512-4400 U.S. Government Accountability Office, 441 G Street NW,
               Room 7125 Washington, D.C. 20548

    			  Public Affairs

               Paul Anderson, Managing Director, [22]AndersonP1@gao.gov (202)
               512-4800 U.S. Government Accountability Office, 441 G Street NW,
               Room 7149 Washington, D.C. 20548

    (192247)

    This is a work of the U.S. government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. However, because this
    work may contain copyrighted images or other material, permission from the
    copyright holder may be necessary if you wish to reproduce this material
    separately.

    [23]www.gao.gov/cgi-bin/getrpt?GAO-07-1039T .

    To view the full product, including the scope
    and methodology, click on the link above.

    For more information, contact Gregory Kutz at (202) 512-7455 or
    kutzg@gao.gov or Terrell Dorn at (202)-512-6923 or dornt@gao.gov.

    Highlights of [24]GAO-07-1039T , a testimony before the Committee on
    Oversight and Government Reform, House of Representatives

    June 28, 2007

    MILITARY CONSTRUCTION

    Observations on Mismanagement of the Kaiserslautern Military Community
    Center

    According to the Air Force, the Kaiserslautern Military Community Center
    (KMCC), an over 800,000 square-foot facility, is currently the Department
    of Defense's largest single-facility project under construction. It is
    intended to provide lodging, dining, shopping, and entertainment for
    thousands of U.S. military and civilian personnel and their families in
    the Kaiserslautern, Germany, area. Initial costs for the KMCC were
    estimated at about $150 million, with funding coming from a variety of
    appropriated and nonappropriated fund sources. The construction for the
    project, which began in late 2003, was originally scheduled to be
    completed in early 2006.

    This testimony discusses GAO findings to date related to the KMCC. The
    testimony describes (1) current problems facing the KMCC, (2) causes for
    identified problems, and (3) the effect of problems identified and their
    implications for future projects in Germany.

    To address our objectives, we interviewed officials from the U.S. Air
    Force, Army and Air Force Exchange Service, U.S. Army Corps of Engineers,
    and German government. We also conducted a site visit and reviewed
    relevant KMCC documents. We plan to continue our work and make
    recommendations to the Air Force as appropriate.

    The KMCC project has encounteredcost, schedule, and performance problems.
    Currently neither Landesbetrieb Liegenschafts- und baubetreuung's office
    in Kaiserslautern (LBB-Kaiserslautern), the German government construction
    agency in charge of the project, nor the Air Force have a reliable
    estimated completion date or final cost for the project.

    Problems facing KMCC include construction flaws, vandalism of property,
    repeated work stoppages and slowdowns by contractors, and ongoing criminal
    investigations. Because of financial problems facing the project, the
    number of workers on-site has dwindled from several hundred to less than
    50, which will likely further delay completion of the project. In
    addition, the KMCC's multimillion dollar "green" roof is experiencing
    water leaks, and will likely require the Air Force to spend millions of
    dollars for its replacement. Below is a picture of damage caused to the
    building interior from the roof leak.

    The KMCC faced a high level of risk from its inception, which was not
    effectively mitigated by the Air Force. Increased risks included an
    overseas project controlled by LBB-Kaiserslautern with financial risks
    borne by the Air Force and its funding partners. Unfortunately,
    LBB-Kaiserslautern did not effectively manage the design and construction
    of the project. Rather than increase controls to mitigate project risks,
    the Air Force provided minimal oversight and in some cases circumvented
    controls to expedite the invoice payment process in an attempt to complete
    the project.

    Because this project is funded primarily with nonappropriated funds, the
    likely substantial cost increases in the project will be borne by military
    servicemembers, civilians and their families. Further, absent better Air
    Force controls, future projects may experience the same types of
    heightened risks associated with KMCC.

    References

    Visible links
      16. mailto:dornt@gao.gov
      17. http://www.gao.gov/
      18. http://www.gao.gov/
      19. http://www.gao.gov/fraudnet/fraudnet.htm
      20. mailto:fraudnet@gao.gov
      21. mailto:JarmonG@gao.gov
      22. mailto:AndersonP1@gao.gov
      23. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1039T
      24. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1039T
    *** End of document. ***