Depot Maintenance: Some Funds Intended for Maintenance Are Used for Other
Purposes (Letter Report, 07/06/95, GAO/NSIAD-95-124).

GAO reviewed the military services' depot maintenance operations,
focusing on: (1) the services' processes for deciding which end items of
equipment will be overhauled; (2) a comparison of the services' depot
maintenance funding levels and their use of these funds; and (3) the
services' management of maintenance backlogs and the impact of these
backlogs on readiness.

GAO found that: (1) the services use the same general process to
identify end items for depot maintenance and to determine their
maintenance budget requests, which includes hours of usage/operations,
mileage, engineered standards, historical data, inspection results, the
depots' ability to handle the maintenance, and funding availability; (2)
the Army and Navy use a process of inspection to determine whether
equipment overhauls are needed, which significantly reduces their
maintenance costs; (3) from fiscal year (FY) 1993 through FY 1995, the
Army and the Navy received about $591 million more and the Air Force
about $75 million less than they requested for depot maintenance; (4)
from FY 1993 through FY 1994, the services completed about $485 million
less of depot maintenance work than the amount requested and about $832
million less than the amount received; (5) the services diverted depot
maintenance funds to military contingencies and other operation and
maintenance expenditures to replace budget reductions in other accounts;
(6) depot maintenance backlogs that exist at the time of budget requests
tend to decrease during the year of budget execution mainly due to the
services' reducing the requirements for items needing depot maintenance;
and (7) the services believe that depot maintenance backlogs are
manageable and have not adversely affected operational readiness due to
depot funding and execution levels and the surplus of equipment
generated through force reductions.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  NSIAD-95-124
     TITLE:  Depot Maintenance: Some Funds Intended for Maintenance Are 
             Used for Other Purposes
      DATE:  07/06/95
   SUBJECT:  Combat readiness
             Equipment maintenance
             Military operations
             Military appropriations
             Reprogramming of appropriated funds
             Budget obligations
             Maintenance costs
             Budget authority
             Budget administration
             Military budgets
IDENTIFIER:  Army Aviation Restructuring Initiative
             
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Cover
================================================================ COVER


Report to Congressional Committees

July 1995

DEPOT MAINTENANCE - SOME FUNDS
INTENDED FOR MAINTENANCE ARE USED
FOR OTHER PURPOSES

GAO/NSIAD-95-124

Depot Maintenance


Abbreviations
=============================================================== ABBREV

  DOD - Department of Defense
  O&M - operation and maintenance

Letter
=============================================================== LETTER


B-259382

July 6, 1995

Congressional Committees

During the past several years, the Congress and officials from the
Department of Defense (DOD) and military services have expressed
concerns about the adequacy of the depot maintenance funding levels
and the adverse effect on readiness as a result of growing
maintenance backlogs.\1

The objectives of our review were to (1) determine the services'
processes for deciding which end items of equipment will be
overhauled, (2) compare the depot maintenance funding received by the
services from the Congress to the amounts requested by the services
and to the use of these funds, and (3) assess the services'
management of maintenance backlogs and the impact of depot
maintenance backlogs on readiness. 


--------------------
\1 Maintenance backlog is defined as the difference between the total
depot maintenance requirement and that part of the requirement for
which funds are provided.  Another name for maintenance backlog is
unfunded requirements. 


   BACKGROUND
------------------------------------------------------------ Letter :1

The Army, the Navy, and the Air Force operate 24 major depot
maintenance facilities to repair equipment that cannot or should not
be repaired by field units.  The types of maintenance and repair work
performed at the depots include

  repair and overhaul of major end items (tanks, personnel carriers,
     aircraft, trucks, etc.) that are paid for with operation and
     maintenance (O&M) funds;

  repair of components and major assemblies that are initially paid
     for with stock funds and that are returned to the supply system
     for issue to customers who reimburse the stock fund with O&M
     funds; and

  modernization and conversion programs that are paid for with
     procurement funds. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

The services use such measurements as hours of usage/operations,
mileage, engineered standards, historical data, and inspection
results to identify end items of equipment that qualify for depot
maintenance (so-called depot maintenance candidates).  They then
assess the candidates in terms of the depots' ability to perform the
maintenance and the anticipated availability of funds.  This process
results in the depot maintenance requirements that are reflected in
the services' budget requests.  After funding levels are determined,
adjustments may be made to the number and type of end items to be
overhauled. 

From fiscal years 1993 through 1995, the Army and the Navy received
about $591 million more and the Air Force about $75 million less than
requested for depot maintenance.  A comparison of the amount of depot
maintenance work executed to the amount of funds requested and
received shows that for fiscal years 1993 and 1994, the amount of
depot maintenance work accomplished by the services was about $485
million less than the amount requested and about $832 million less
than the amount received.  The depot maintenance funds not used for
depot maintenance were used for military contingencies and other O&M
expenditures such as real property maintenance and base operations. 

The depot maintenance backlogs at the time the services submit their
budget requests to the Congress tend to decrease during the year of
budget execution.  These decreases are a result of the services'
reducing the requirements for items requiring depot maintenance, not
because more depot maintenance was performed. 

According to service officials, the depot maintenance backlogs are
manageable, represent an acceptable minimal level of risk, and have
not yet adversely affected equipment operational readiness rates. 
They attribute the lack of adverse effect to the funding levels; the
levels of depot maintenance execution; and the reductions to the
force levels, which have made more equipment available to the
remaining forces. 


   SERVICES GENERALLY USE SAME
   PROCESS TO DETERMINE
   MAINTENANCE REQUIREMENTS
------------------------------------------------------------ Letter :3

Each of the services use the same general process for identifying its
depot maintenance requirements.  The first step is to identify those
end items of equipment that meet the criteria as depot maintenance
candidates.  Then, based on inputs such as force structure, fielding
schedules, and operating tempo, initial depot maintenance
requirements are determined.  These requirements are reviewed and
adjusted to reflect the capability and capacity of the depots to
accomplish the repairs.  The product of this process is referred to
as executable requirements.  The cost of the executable requirements
is then determined and the services decide what portion of the total
requirement can be funded.  This amount then becomes the basis for
the services' depot maintenance budget requests. 

Once the budget process is completed and the funds are provided,
adjustments may be made to the number and type of end items to be
overhauled.  This amount then becomes the funded depot maintenance
requirements.  The difference between the funded requirements and the
total executable requirements is the maintenance backlog. 

Although the services use similar processes to develop their depot
maintenance requirements, the Army and the Navy vary significantly
from the Air Force in the way they determine whether an aircraft will
be sent to the depot for overhaul. 

The Army and the Navy identify notional requirements for budget
purposes based on historical experiences.  As the budget execution
year proceeds, the notional requirements are replaced with firm,
actual requirements that are the result of the Army and the Navy
inspecting the candidates to determine whether overhauls are needed. 
If an aircraft does not need to be overhauled, a waiver is granted
for a year.  This process is repeated each year until the aircraft
fails inspection and is scheduled for overhaul.  The Air Force, on
the other hand, does not have an inspection and waiver process.  It
adheres to maintenance cycles based on flying hours, engineered
requirements, and historical usage data.  When one of these criteria
is met, the aircraft is overhauled. 

According to Navy officials, the inspection and waiver process has
enabled them to reduce the number of aircraft to be overhauled by 38
percent and resulted in cost avoidances of $300 million a year.  The
Army has reported similar experiences by using this process.  It
reported a 60-percent reduction in the number of aircraft to be
overhauled and cost avoidances of about $4 billion over the past 5
years. 

In commenting on a draft of this report, DOD pointed out that the
Army's estimated savings were somewhat overstated because the
estimate did not consider the cost of maintaining the aircraft that
would otherwise have been overhauled. 


   INCREASED DEPOT MAINTENANCE
   FUNDS ARE NOT NECESSARILY USED
   FOR DEPOT MAINTENANCE WORK
------------------------------------------------------------ Letter :4

Although the services received more funds than requested for depot
maintenance, the services do not always use these funds for that
purpose.  As shown in table 1, between fiscal years 1993 and 1995,
the services received about $15.3 billion for depot maintenance. 
This represents about $516 million more than the services requested. 



                                      Table 1
                      
                      Funds Requested and Received for Fiscal
                              Years 1993 Through 1995

                               (Dollars in millions)


Se
rv
ic  Request  Receive  Request  Receive  Request  Receive  Request  Receiv  Differen
e        ed        d       ed        d       ed        d       ed      ed        ce
--  -------  -------  -------  -------  -------  -------  -------  ------  --------
Ar     $773     $995     $721     $796   $1,037   $1,169   $2,531  $2,960      $429
 my
Na
 v      576      567      554      604      660      683    1,790   1,854        64
 y    2,399    2,395    2,003    2,089    2,337    2,353    6,739   6,837        98
 :
 A
 i
 r
 S
 h
 i
 p
 s
Ai    1,234    1,149    1,062    1,074    1,387    1,385    3,683   3,608      (75)
 r
 F
 o
 r
 c
 e
===================================================================================
To   $4,982   $5,106   $4,340   $4,563   $5,421   $5,590  $14,743  $15,25      $516
 t                                                                      9
 a
 l
-----------------------------------------------------------------------------------
For fiscal years 1993 and 1994, the amount of depot maintenance work
executed was about $8.8 billion, as compared to $9.3 billion
requested and $9.7 billion received.  Table 2 shows the depot
maintenance funding level and the depot maintenance work executed by
service for fiscal years 1993 and 1994. 



                           Table 2
           
           Funding and Execution Levels by Service
                for Fiscal Years 1993 and 1994

                    (Dollars in millions)


          Receiv  Execut  Differen  Receiv  Execut  Differen
Service       ed      ed        ce      ed      ed        ce
--------  ------  ------  --------  ------  ------  --------
Army        $995    $917       $78    $796    $694      $102
Navy:
 Air         567     492        75     604     477       127
 Ships     2,395   2,287       108   2,089   1,741       348
Air        1,149   1,152       (3)   1,074   1,077     (3)\a
 Force
============================================================
Total     $5,106  $4,848      $258  $4,563  $3,989      $574
------------------------------------------------------------
\a The amount of depot maintenance executed exceeded the amount of
depot maintenance funds received because funds from other O&M
accounts were transferred into the depot maintenance account. 

Army and Navy officials acknowledge that all the funds received for
depot maintenance are not necessarily used for that purpose.  The
funds may be used for military contingencies, other O&M programs, or
to compensate for other congressional and service-level budget
reductions as the following examples illustrate. 

  In fiscal year 1994, the Navy's depot maintenance program for ships
     and aircraft was $475 million less than the amount the Navy
     provided for these purposes.  This amount was moved to the
     flying hour program, Haiti/Cuba operations, base operations,
     real property maintenance, and other O&M accounts.  In fiscal
     year 1995, about $14.3 million of depot maintenance funds were
     moved to nondepot maintenance activities such as contractor and
     consulting services and information technology.  The Navy
     determined that the $14.3 million represented depot
     maintenance's share of the congressional reductions in these
     areas. 

  In fiscal year 1994, the Army used $75 million of its depot
     maintenance funds for base closure costs and for voluntary
     separation of personnel.  Thus far, in fiscal year 1995, the
     Army has transferred $12 million of its depot maintenance funds
     to pay for temporary duty and information management costs. 
     Army officials said that this transfer represented depot
     maintenance's share of a congressional reduction to these areas. 

Service officials said that if they had not received the depot
maintenance funding levels that they did, they would have had to
either find other sources to pay for the nondepot maintenance
activities or reduce the amount of depot maintenance work to be
performed. 


   MAINTENANCE BACKLOGS TEND TO
   DECREASE DURING THE YEAR OF
   BUDGET EXECUTION
------------------------------------------------------------ Letter :5

The maintenance backlogs at the time the services submit their budget
requests to the Congress have often been reduced or eliminated during
the year of budget execution.  The reduction or elimination has
occurred primarily because the funded depot maintenance requirements
were reduced as end items of equipment were removed from the
services' inventories.  As a result, the services can reduce their
backlogs by transferring end items from the unfunded (backlog
category) to the funded category.  The maintenance backlogs at the
time of budget submission and at the end of the year of execution are
shown in table 3. 



                           Table 3
           
            Maintenance Backlogs at Time of Budget
           Submission and End of Fiscal Years 1993
                           to 1995

                    (Dollars in millions)


            Budget          Budget          Budget       End
          submissi        submissi        submissi  (estimat
Service         on   End      on\a   End      on\a       ed)
--------  --------  ----  --------  ----  --------  --------
Army          $637  $494      $551  $577      $637    $122\b
                      \b              \b
Navy:
 Air           153    83       254   125       186       163
 Ships           0     0       129     0         0         0
Air            185   110       275   231       338       146
 Force
============================================================
Total         $975  $687    $1,209  $933    $1,161      $431
------------------------------------------------------------
\a The backlog at the end of a fiscal year does not become the
beginning backlog for the next fiscal year.  The reason for this is
that depot maintenance candidates are determined anew each year and
the new backlog is a function of the expected funding level. 

\b The Army does not compute an end-of-year backlog.  The figures
shown in the table represent the difference between the total
requirement at budget submission and the amount of depot maintenance
funds obligated during the year.  The other services do compute an
end-of-year backlog based on the difference between the total
requirements adjusted for changes during the year and the depot
maintenance funds obligated during the year. 

One reason for backlog reductions after the budget requests are
submitted to the Congress can be the implementation of new
initiatives.  For example, the fiscal year 1995 Army budget request
included depot maintenance requirements for the Army Aviation and
Troop Command of $539 million and a maintenance backlog of $253
million.  After the budget was submitted, the requirements and
backlog were reduced to $307 million and $16 million, respectively. 
According to Army officials, at the time the budget was submitted,
the Aviation Restructuring Initiative had not been approved.  After
budget submission, the restructuring initiative was approved to
eliminate older helicopters (AH-1, UH-1, and OH-58) from the Army
inventory.  The effect of eliminating these helicopters was to
eliminate the associated depot maintenance requirements and, in turn,
reduce the overall depot maintenance backlog. 

Other reasons are including depot work in the current year's
requirements that has been previously funded and included in the
carryover and reducing requirements because of inadequate depot
capability.  For example, at the beginning of fiscal year 1994, the
Air Force's Air Combat Command's backlog was $130 million.  Later,
the depot maintenance requirements for engines were reduced when the
San Antonio depot informed the command that the depot did not have
the capability to execute the total engine repair requirements.  The
repair requirements were also reduced because they included depot
work that had already been funded in a prior fiscal year and was
included as part of the depot maintenance carryover.  As a result,
the backlog was reduced to $60 million.  By the end of the fiscal
year, the Air Force had reduced the number of B-52s and F-111s in the
force.  This reduction decreased the depot maintenance requirements
for these aircraft, which, in turn, enabled the command to fund all
previously unfunded requirements and eliminate the backlog. 

Maintenance backlogs may also be eliminated if the funds provided
exceed the amount requested.  For example, when the Navy submitted
its budget request for fiscal year 1994, it estimated a ship
maintenance backlog of $129 million.  The Navy received $86 million
more than it requested for ship depot maintenance.  The increased
funds, coupled with an overall reduction of depot maintenance
requirements, enabled the Navy to eliminate its backlog and transfer
$390 million to other O&M programs. 


   DEPOT MAINTENANCE BACKLOG HAS
   NOT AFFECTED READINESS
------------------------------------------------------------ Letter :6

Depot maintenance backlog consists of equipment items that meet the
criteria for overhaul or repair but for which funds are not available
to overhaul them.  Generally, if an item that was categorized as part
of the backlog becomes inoperable, it is sent to a depot for repair
and displaces an item that has been scheduled for overhaul.  The
displaced equipment item will then be moved from the funded to the
unfunded category. 

In testimonies before the Congress and internal studies, service
officials at the chief of staff level and officials responsible for
the depot maintenance program have stated that depot maintenance
backlogs have not yet affected equipment operational readiness rates. 
The officials attribute the lack of adverse effect on readiness to
the funding levels, the levels of depot maintenance execution, and
the reductions to the force levels which, have made more equipment
available to the remaining forces.  Their position is best
illustrated by the following comments from service officials. 

  The Air Force does not consider depot maintenance backlog as a
     readiness issue.  Aircraft and engine maintenance backlogs have
     not caused any aircraft to be grounded, and the Air Force
     believes that it can continue to defer some depot maintenance
     over the Future Years Defense Plan (a 6-year plan) without any
     serious impact. 

  The Army's depot maintenance backlog has not directly affected the
     operational readiness of Army units.  It has been shown that
     funding streams and backlogs cannot be tied to readiness. 

  The Navy's position is that no impact on readiness can be
     attributed to maintenance backlogs and that the existing
     backlogs are manageable.  Furthermore, the readiness risks
     associated with maintenance backlogs are minimal. 

Service officials, however, agree that there could be some long-term
effect on sustainability and modernization.  If depot maintenance
funding levels are reduced to a point where the services cannot
repair needed inoperable items, readiness could be affected. 
Sustainability could also be affected if, rather than making needed
repairs, inventory levels of major components and assemblies are
reduced. 


   MATTERS FOR CONGRESSIONAL
   CONSIDERATION
------------------------------------------------------------ Letter :7

To enhance its oversight of DOD's depot maintenance program, the
Congress may wish to require the services to include the following
types of information as part of their budget requests. 

  The amount of funds received for depot maintenance that was not
     used for that purpose.  If funds were used for other than depot
     maintenance, the other uses should be identified and the reasons
     for and the amounts of the funds transferred should be
     explained. 

We recognize that section 361 of the National Defense Authorization
Act for Fiscal Year 1995 addresses the essence of the above suggested
reporting requirement.  However, the reporting requirement should be
revised to include identification of the other uses for which the
funds were transferred in addition to the amount and the reasons for
the transfers. 

  The maintenance backlogs at the (1) beginning and end of the most
     recently completed fiscal year and (2) beginning of the current
     fiscal year and at the time of the budget submission.  Any
     changes to the beginning of the year backlog should be explained
     in terms of the reasons for the changes (i.e., increased or
     decreased maintenance efforts or changes to the depot
     maintenance requirements). 

  An assessment of the effect maintenance backlogs are having on
     readiness.  If readiness is being adversely affected,
     information concerning the extent of the adverse effects and
     plans to correct the situation should be provided. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :8

In commenting on a draft of this report, DOD concurred with most of
the report.  (See app.  II for a copy of DOD's comments.) However,
DOD felt that (1) one section of the report implied that there was no
relationship between depot maintenance funding and readiness and (2)
our suggested reporting requirements identified in the Matters for
Congressional Consideration would largely duplicate reporting
requirements already set forth in existing DOD procedures. 

Our report does not imply a lack of relationship between depot
maintenance funding and readiness.  It cites service officials'
testimonies and internal military studies that state that the
existing depot maintenance backlog has not yet affected the readiness
of the forces because of (1) funding that the services have been
receiving and (2) the drawdown in the forces that resulted in the
redistribution of more and better equipment to the remaining forces. 
Moreover, our report also points out that there could be some impact
on readiness if the depot maintenance funding levels were reduced to
the point where the services could not repair needed inoperable
equipment.  It should also be remembered that the services have been
able to maintain their readiness level while at the same time
transferring hundreds of millions of dollars appropriated for depot
maintenance to other O&M programs. 

We agree that much of our suggested reporting requirement dealing
with the transfer of funds from depot maintenance for other uses is
included in the congressionally mandated reporting requirement. 
However, our suggested DOD reporting requirement would link the
amount and reason for the transfer as currently required to the
specific use for which the transfers were made.  We believe that a
combination of this additional information together with the
information already required is needed so that the Congress can
readily discern what the funds were used for and can decide whether
these other uses should be funded at a higher level. 

In the current reporting requirement, DOD is not required to address
changes in maintenance backlog that occurred after the budget request
was submitted.  Without the more current data, the Congress has no
way of discerning whether backlogs are increasing or decreasing or
the reasons for the changes. 

Based on comments received from DOD, we deleted our discussion and
the proposed reporting requirement dealing with the amount of depot
maintenance work carried forward from one fiscal year to the next. 
We have included a new Matter for Congressional Consideration, which
would build on the backlog reporting requirement, previously
discussed, by requiring DOD to report the impact of the maintenance
backlogs on readiness.  Because this reporting requirement was added
after the draft was sent to DOD for official comment, DOD comments do
not address this change.  We advised DOD officials of the change and
they told us that rather than delaying the issuance of our report,
they would respond to that suggestion after our report was issued. 


---------------------------------------------------------- Letter :8.1

The scope and methodology of our review are discussed in appendix I. 

We are sending copies of this report to the Secretaries of Defense,
the Army, the Navy, and the Air Force; the Director of the Office of
Management and Budget; and the Chairmen of the House Committee on
Government Reform and Oversight, Senate Committee on Governmental
Affairs, and House and Senate Committees on Appropriations, Senate
Committee on Armed Services, and House Committee on National
Security. 

Please contact me on (202) 512-5140 if you have any questions
concerning this report.  Major contributors to this report are listed
in appendix III. 

Mark E.  Gebicke
Director, Military Operations
 and Capabilities Issues


List of Congressional Committees

The Honorable Ted Stevens
Chairman, Subcommittee on Defense
Committee on Appropriations
United States Senate

The Honorable John McCain
Chairman, Subcommittee on Readiness
Committee on Armed Services
United States Senate

The Honorable John R.  Kasich
Chairman, Committee on the Budget
House of Representatives

The Honorable C.W.  Bill Young
Chairman, Subcommittee on National Security
Committee on Appropriations
House of Representatives

The Honorable Bill Zeliff
Chairman, Subcommittee on National Security,
 International Affairs, and Criminal Justice
Committee on Government Reform and Oversight
House of Representatives


SCOPE AND METHODOLOGY
=========================================================== Appendix I

We reviewed studies and regulations and held discussions with depot
maintenance officials to determine how the services identify their
depot maintenance requirements.  In addition, we compared the funding
levels requested by the services to the amounts received for fiscal
years 1993 to 1995.  When the amounts received exceeded the amounts
requested, we held discussions with service officials and reviewed
budget documents to determine whether the additional funds were used
for depot maintenance or for other purposes.  We also compared the
amount of funds received for depot maintenance to the amount of funds
used for depot maintenance.  When the amount of funds used for depot
maintenance was less than the amount received, we held discussions
with budget and program officials to identify how the remaining funds
were used and why the funds were not used for depot maintenance. 

To evaluate the impact of depot maintenance backlogs on readiness, we
reviewed internal studies on the subject and held discussions with
service headquarters officials who manage depot maintenance programs. 
We also reviewed testimonies by service officials before the
Congress. 

Our review was performed at the following locations: 


      DEPARTMENT OF THE ARMY
------------------------------------------------------- Appendix I:0.1

  Office of the Deputy Chief of Staff for Logistics, U.S.  Army
     Headquarters, Washington, D.C.;

  U.S.  Army Materiel Command, Alexandria, Virginia;

  U.S.  Army Depot Systems Command, Chambersburg, Pennsylvania;

  U.S.  Army Tank-Automotive and Armaments Command, Warren, Michigan;
     and

  U.S.  Army Aviation and Troop Command, St.  Louis, Missouri. 


      DEPARTMENT OF THE AIR FORCE
------------------------------------------------------- Appendix I:0.2

  Office of the Deputy Chief of Staff for Logistics, U.S.  Air Force
     Headquarters, Washington, D.C.;

  Air Force Materiel Command, Dayton, Ohio; and

  Air Combat Command, Langley Air Force Base, Virginia. 


      DEPARTMENT OF THE NAVY
------------------------------------------------------- Appendix I:0.3

  Office of the Chief of Naval Operations, Washington, D.C.;

  Office of the Comptroller of the Navy, Washington, D.C.;

  Naval Air Systems Command, Washington, D.C.; and

  Naval Sea Systems Command, Washington, D.C. 

We performed our review from October 1994 to March 1995 in accordance
with generally accepted government auditing standards. 




(See figure in printed edition.)Appendix II
COMMENTS FROM THE DEPARTMENT OF
DEFENSE
=========================================================== Appendix I



(See figure in printed edition.)

Now on pp.  2-3. 



(See figure in printed edition.)

Now on pp.  3-5. 



(See figure in printed edition.)

Now on pp.  5-7. 

Now on pp.  7-8. 



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)

Now on p.  8. 



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III

NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C. 

Robert J.  Lane

DALLAS REGIONAL OFFICE

Kimberly S.  Carson
Bonnie S.  Carter

NORFOLK REGIONAL OFFICE

Norman L.  Jessup, Jr.
Vincent C.  Truett
Jeanett H.  Reid
