Airport Competition: Essential Air Service Slots at O'Hare International
Airport (Fact Sheet, 03/04/94, GAO/RCED-94-118FS).

This fact sheet provides information on the availability of air travel
between small airports in the Midwest and Chicago's O'Hare International
Airport. Some small communities in the Midwest contend that service to
O'Hare is vital to attracting new industry and maintaining healthy local
economies. Although the Essential Air Service program guarantees a
minimum level of service from most small airports, these communities
believe that maintaining frequent and convenient service to O'Hare has
become increasingly difficult as the limited number of takeoff and
landing slots at that airport have become controlled by a few large
airlines. This fact sheet discusses (1) changes in service between small
Midwestern towns and O'Hare since 1978 and since the Essential Air
Service program was modified and extended in 1987; (2) the level of
concentration of commuter aviation services in the Midwest; (3)
differences in fares between small communities in the Midwest and those
in other regions; (4) trends in slot utilization and capacity at O'Hare;
and (5) the impact of airport improvements on O'Hare's capacity.

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

 REPORTNUM:  RCED-94-118FS
     TITLE:  Airport Competition: Essential Air Service Slots at O'Hare 
             International Airport
      DATE:  03/04/94
   SUBJECT:  Airline industry
             Competition
             Transportation rates
             Airports
             Commercial aviation
             Airline regulation
             Statistical data
IDENTIFIER:  Chicago-O'Hare International Airport (Chicago, IL)
             DOT Essential Air Service Subsidy Program
             Chicago-O'Hare International Airport Development Plan
             FAA Aviation System Capacity Plan
             Illinois
             Indiana
             Iowa
             Ohio
             Michigan
             Wisconsin
             
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Cover
================================================================ COVER


Fact Sheet for Congressional Requesters

March 1994

AIRPORT COMPETITION - ESSENTIAL
AIR SERVICE SLOTS AT O'HARE
INTERNATIONAL AIRPORT

GAO/RCED-94-118FS

Airport Competition


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

  ADP - Airport Development Plan
  DOT - Department of Transportation
  EAS - essential air service
  FAA - Federal Aviation Administration
  GAO - General Accounting Office
  OAG - Official Airline Guide

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


B-256330

March 4, 1994

Congressional Requesters

This fact sheet responds to your June 11, 1993, request that we
provide you with information on the availability of air travel
between small airports in the Midwest and Chicago's O'Hare
International Airport.  The Essential Air Service (EAS) program was
established in 1978 to guarantee continued service from small
airports following deregulation.  The program maintains a link
between small airports with insufficient enplanements to support
service to hub airports,\1 guaranteeing residents of small
communities access to the national air travel network. 

Under the program, the U.S.  Department of Transportation (DOT) is
authorized to declare a community eligible for essential air service. 
DOT also specifies the frequency of service and the hub(s) to which
service will be provided.  Typically, a community is guaranteed two
round-trip flights per day, 6 days per week, to a medium or large
hub.  If revenues from the service do not cover costs, the carriers
providing the service can apply for a subsidy. 

Subsidies are provided directly to carriers applying to DOT and
agreeing to offer service to the designated communities.  In fiscal
year 1993, the program provided a total of $38.6 million in
subsidies.  However, most essential air service operations are not
subsidized.  Of the 503 communities in the United States and Puerto
Rico that were designated as eligible to receive essential air
service in 1993, only 128 communities actually received federally
subsidized commuter air service. 

Some small communities in the Midwest contend that service to O'Hare
is vital for attracting new industry and maintaining healthy local
economies.  Although the EAS program guarantees a certain minimum
level of service from most small airports, these communities believe
that maintaining frequent and convenient service to O'Hare has become
increasingly difficult as the limited number of takeoff and landing
slots at that airport have become controlled by a few large airlines. 

Following discussions with representatives from your offices, we
agreed to provide you with information on the following:  (1) changes
in service between small Midwestern communities and O'Hare since 1978
and since the 1987 amendment to section 419 of the Federal Aviation
Act, which modified and extended the EAS program, (2) the level of
concentration of commuter aviation services in the Midwest, (3)
differences in fares between small communities in the Midwest and
those in other regions, (4) trends in slot utilization and capacity
at O'Hare, and (5) the impact of airport improvements on O'Hare's
capacity. 

In summary, we found the following: 

  The number of both nonstop and direct flights available between the
     41 Midwestern essential air service communities addressed in our
     analysis and O'Hare Airport has decreased since the start of the
     EAS program.  However, 17 communities have actually gained
     service, while 24 have lost service or have seen their service
     remain unchanged.  (See sec.  1.)

  Since the implementation of the buy-sell rule in 1986, commuter
     slot holdings at O'Hare Airport have become increasingly
     concentrated.  Currently, all commuter slots are held by only
     three airlines.  (See sec.  2.)

  While the concentration of slot holdings has increased, the average
     yield (revenues per passenger mile) for operating between small
     airports and O'Hare does not appear to be substantially above
     that at other major hub airports, and, in fact, the yield is
     roughly in the middle of the distribution of yields at major
     hubs.  For example, the average yield adjusted for differences
     in the passenger miles traveled between essential air service
     airports and O'Hare is 52.42 cents per passenger mile; the
     average yields between essential air service airports and
     Atlanta is 73.09 cents and between essential air service
     airports and Boston is 35.21 cents per passenger mile.  (See
     sec.  3.)

  Airport operators and airline representatives told us that O'Hare
     could accommodate more traffic through more efficient slot
     allocation.  Data indicate some excess capacity among general
     aviation/military slots.  However, Federal Aviation
     Administration (FAA) and O'Hare Airport officials believe that
     the number of additional slots in that category, if any are
     available, would be minimal.  (See sec.  4.)

  Since 1983, improvements undertaken as part of the O'Hare Airport
     Development Plan have increased the airport's overall capacity. 
     FAA is responding to the increases in O'Hare's capacity with a
     complete review of the regulations controlling the number of
     O'Hare slots and a program of air traffic and ground control
     improvement projects.  (See sec.  5.)


--------------------
\1 A hub airport, as defined by the Federal Aviation Administration,
enplanes at least 0.05 percent or more of the total enplaned
passengers in the United States.  A large hub airport accounts for 1
percent or more of the total domestic enplanements, and a medium hub
airport accounts for 0.25 to 0.99 percent of the total domestic
enplanements. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :1

We conducted our review from July to December 1993, focusing on 41
small airports in Illinois, Indiana, Iowa, Ohio, Michigan, and
Wisconsin, each of which has had guaranteed service to O'Hare and/or
other Midwestern hubs since 1978.\2

To obtain information on the EAS program, we spoke with officials
from FAA and DOT's Office of Aviation Analysis.  We obtained
information on flight availability from the "Official Airline Guide"
covering the years 1978 to 1993.  We interviewed managers of
essential air service airports in the following communities to obtain
information on their access to O'Hare:  Danville and Coles County,
Illinois; Terre Haute and Bloomington, Indiana; Oshkosh, Wisconsin;
Dubuque, Iowa; and Manistee, Michigan.  About 10.6 percent of the air
service subsidy payments, approximately $3.9 million, was paid to
carriers serving communities in the six states addressed in our
analysis.  We spoke with airline representatives to find out about
their experiences operating between small airports and O'Hare.  The
Office of the Chief Counsel, FAA, provided us with data on slot
holdings and usage at O'Hare.  Finally, to obtain further information
on O'Hare's capacity, we interviewed officials at O'Hare Airport. 


--------------------
\2 The DOT and Related Agencies Appropriation Act of 1994 contains
restrictions that could affect service to 4 of the 41 communities: 
Galesburg, Illinois, and Terre Haute, Muncie/Anderson/New Castle, and
Bloomington, Indiana.  Nationwide, 11 essential air service airports
are affected.  The act prohibits the use of funds for airports in the
contiguous 48 states within 70 highway miles of a hub airport or
airports that receive passenger subsidies greater than $200 per
passenger and that are less than 210 miles from the nearest hub. 
While the act does not specifically remove EAS eligibility, the loss
of subsidy could lead to a loss of the service for these communities. 


---------------------------------------------------------- Letter :1.1

We are sending copies to the Secretary of Transportation and the
Administrator, FAA.  Copies are available to others on request. 

Please contact me on (202) 512-6001 if you or your staff have any
questions.  Major contributors to this fact sheet are listed in
appendix I. 

Kenneth M.  Mead
Director, Transportation Issues

List of Requesters

The Honorable Herb Kohl
The Honorable Russ Feingold
The Honorable Carl Levin
The Honorable Paul Simon
United States Senate

The Honorable Tom Petri
The Honorable Glenn Poshard
The Honorable Marcy Kaptur
The Honorable James L.  Oberstar
The Honorable David Obey
The Honorable Steve Gunderson
House of Representatives


OVERALL SERVICE TO O'HARE HAS
DECLINED, BUT SOME COMMUNITIES
HAVE EXPERIENCED INCREASED SERVICE
============================================================ Chapter 1

Our analysis of the "Official Airline Guide," which lists all
scheduled flights, shows that the number of nonstop and direct
flights available between the 41 Midwestern essential air service
(EAS) communities and O'Hare International Airport has decreased
since the start of the EAS program.\1 However, 17 communities have
actually gained service, while 24 have lost service or their service
has remained unchanged. 


--------------------
\1 A direct flight could include one or more stops but does not
require a change of aircraft. 


   NONSTOP ESSENTIAL AIR SERVICE
   TO O'HARE
---------------------------------------------------------- Chapter 1:1

By 1993, airports serving the 41 communities had lost over 19 percent
of the nonstop service they had in 1978, declining from 125 daily
flights in September 1978 to 104 in September 1993.  However, while 6
airports have fewer nonstop flights to O'Hare and 7 airports have
lost nonstop service altogether since 1978, 17 airports have gained
some nonstop service; 1 airport has maintained the same number of
nonstop flights; and 10 airports never had nonstop service.  Table
1.1 compares daily nonstop flight availability from each of the 41
airports in September 1978, 1987, and 1993 to O'Hare Airport. 



                          Table 1.1
           
               Daily Nonstop Flights to O'Hare

                           September   September   September
Airport                         1978        1987        1993
------------------------  ----------  ----------  ----------
Akron/Canton, OH                   4           5           3
Appleton, WI                      15           7           5
Bloomington, IL                   11           2           5
Bloomington, IN                    5           1           0
Burlington, IA                     3           1           4
Champaign, IL                      5           6           6
Danville, IL                       6           4           0
Decatur, IL                        1           4           0
Dubuque, IA                        4           7           5
Escanaba, MI                       0           0           3
Flint, MI                          2           1           3
Fort Dodge, IA                     0           0           0
Galesburg, IL                      7           3           0
Green Bay, WI                      7          11          10
Hancock/Houghton, MI               0           0           0
Iron Mountain/                     0           0           2
 Kingsford, MI
Ironwood, MI/Ashland, WI           0           0           0
Kalamazoo, MI                      5          11          10
LaCrosse, WI                       7           2           4
Lafayette, IN                     11           6           2
Manistee/Ludington, MI             0           0           1
Marinette/Menominee, WI            0           0           1
Marquette, MI                      0           0           0
Mason City, IA                     1           0           1
Mattoon, IL                        0           0           0
Mount Vernon, IL                   0           0           0
Muncie, IN                         5           2           0
Muskegon, MI                       2           5           4
Oshkosh, WI                        3           2           0
Ottumwa, IA                        0           0           0
Pellston, MI                       0           0           0
Quincy, IL                         0           0           0
Rhinelander, WI                    0           0           3
Rockford, IL                       2           0           8
Springfield, IL                    3           7           7
Sterling, IL                       7           2           2
Terre Haute, IN                    8           2           0
Traverse City, MI                  0           4           3
Waterloo, IA                       1           0           4
Wausau, WI                         1           3           8
Youngstown, OH                     3           0           0
============================================================
Total                            129          98         104
Average                            3           2           3
------------------------------------------------------------
Source:  The "Official Airline Guide."


   DIRECT ESSENTIAL AIR SERVICE TO
   O'HARE
---------------------------------------------------------- Chapter 1:2

By 1993, airports serving the 41 communities had lost over 25 percent
of the direct service that they had in 1978.  In September 1978,
airlines serving these airports provided 211 direct flights daily to
O'Hare.  This number fell to 157 in September 1993.\2 Today, 21
communities have fewer direct flights to O'Hare than in 1978. 
However, 16 communities now have more frequent direct service, and 4
communities have the same number of flights as in 1978.  Of the 21
communities that have less frequent direct service, 8 have lost
service to O'Hare completely and now connect to the national air
travel network through other Midwestern hubs.  Table 1.2 compares
daily direct flight availability from each of the 41 airports in
September 1978, 1987, and 1993. 



                          Table 1.2
           
                Daily Direct Flights to O'Hare

                           September   September   September
Airport                         1978        1987        1993
------------------------  ----------  ----------  ----------
Akron/Canton, OH                   6           6           3
Appleton, WI                      15           7           6
Bloomington, IL                   11           6           5
Bloomington, IN                    8           3           0
Burlington, IA                     3           4           8
Champaign, IL                      5           6           6
Danville, IL                       6           4           0
Decatur, IL                        6           6           3
Dubuque, IA                        9           7           6
Escanaba, MI                       0           2           8
Flint, MI                          3           4           6
Fort Dodge, IA                     1           2           2
Galesburg, IL                      7           4           0
Green Bay, WI                     13          13          10
Hancock/Houghton, MI               2           0           0
Iron Mountain/                     3           2           4
 Kingsford, MI
Ironwood, MI/Ashland, WI           2           0           1
Kalamazoo, MI                      8          11          10
LaCrosse, WI                      12           5           5
Lafayette, IN                     11           6           2
Manistee/Ludington, MI             1           2           2
Marinette/Menominee, WI            2           0           3
Marquette, MI                      1           4           7
Mason City, IA                     3           0           3
Mattoon, IL                        2           4           0
Mount Vernon, IL                   2           0           0
Muncie,IN                          5           3           0
Muskegon, MI                       6           5           4
Oshkosh, WI                        7           3           2
Ottumwa, IA                        2           2           2
Pellston, MI                       2           4           2
Quincy, IL                         3           3           3
Rhinelander, WI                    2           2           3
Rockford, IL                       2           0           8
Springfield, IL                    7          15           9
Sterling, IL                       7           2           2
Terre Haute, IN                    9           5           0
Traverse City, MI                  2           9           4
Waterloo, IA                       6           7           8
Wausau, WI                         6           8           8
Youngstown, OH                     3           2           2
============================================================
Total                            211         178         157
Average                            5           4           4
------------------------------------------------------------
Source:  The "Official Airline Guide."


--------------------
\2 Daily flights refer to those available for a majority of weekdays. 
Flights available only on weekends were eliminated for this analysis. 


   EAS AIRPORT MANAGERS' COMMENTS
   ON THE DECLINE OF O'HARE
   SERVICE
---------------------------------------------------------- Chapter 1:3

Managers of EAS airports we talked with told us that service to
O'Hare requires much effort to maintain.  Changes in factors such as
flight frequencies, numbers of available seats, and actual numbers of
air carriers providing service to O'Hare make it difficult to achieve
and maintain profitable enplanement levels, and that some carriers
have discontinued even profitable service.  Although the EAS program
guarantees a certain minimum level of service, the managers told us
that the program does not necessarily guarantee service of sufficient
frequency or convenience to maintain adequate traffic levels. 

Even though the EAS program has guaranteed that communities losing
service to O'Hare are able to make connections through Midway Airport
in Chicago and other Midwestern hubs, managers told us that other
large airports, including Chicago's Midway, are not, in their
opinion, adequate substitutes for O'Hare because they do not offer as
many connecting opportunities.  Therefore, the small airports have
difficulty attracting passengers who require flights that connect
through O'Hare. 

This claim is consistent with our analysis of DOT data, which showed
that of the 10 communities requiring subsidies in 1993, only 3 had
flights to O'Hare, with 6 connecting to Midway and 1 connecting to
St.  Louis.  Our analysis also showed that 84 percent of passengers
flying between the 41 EAS airports and O'Hare are connecting to other
destinations. 


COMMUTER AVIATION SERVICES IN THE
MIDWEST ARE BECOMING INCREASINGLY
CONCENTRATED
============================================================ Chapter 2

Not only do fewer flights arrive at O'Hare from small Midwestern
regional airports, but fewer commuter air carriers, the typical
providers of essential air services, hold O'Hare slots.\1

Since implementation of the buy-sell rule in 1986, commuter slot
holdings have become increasingly concentrated. 

DOT has determined that, under the EAS program, service to O'Hare is
to be maintained from each of the 41 essential air service airports. 
Service must be provided between the small airport and O'Hare or, in
some cases, between the small airport, another Midwestern hub, and
O'Hare.  However, O'Hare is one of four airports in the United States
subject to FAA's slot controls.\2 FAA restricts the number of
takeoffs and landings O'Hare may accommodate to 155 per hour, with 25
per hour dedicated to commuter air carriers.  In addition, in 1986
FAA promulgated the buy-sell rule, which allows airlines to buy and
sell slots, in effect creating an asset for the airline that held the
slots at that time. 

As a result, slots have become a valuable commodity at O'Hare to any
air carriers seeking to expand their operations.  According to the
airport operators we interviewed, the value of slots has increased
significantly over the last few years.  At present, slot prices at
O'Hare are estimated to be as high as $2 million. 

In 1986, eight airlines held commuter slots at O'Hare.  Currently,
only three airlines hold commuter slots:  American Airlines Eagle (65
percent), Air Wisconsin (27 percent), and Great Lakes Aviation (8
percent).  Because Air Wisconsin and Great Lakes are United Express
carriers, commuter slots are essentially controlled by the two
dominant major airlines at O'Hare--American and United. 

A comparison of the commuter slot holdings at each of the
slot-controlled airports shows that O'Hare is the most concentrated. 
Table 2.1 lists the number of carriers and the percent of slots held
by the leading slot holder at the four slot-controlled airports. 



                          Table 2.1
           
           Commuter Slot Concentration at Domestic
                   Slot-Controlled Airports

                                               Percentage of
                                               slots held by
                                 Number of      carrier with
Airport                           carriers        most slots
------------------------  ----------------  ----------------
O'Hare                                   3                65
Washington National                      7                49
John F. Kennedy                          5                49
La Guardia                               6                47
------------------------------------------------------------
Source:  Federal Aviation Administration. 


--------------------
\1 Each take-off and landing is considered to be a "slot."

\2 The four domestic slot-controlled airports are:  Washington
National, John F.  Kennedy, La Guardia, and O'Hare. 


FARES BETWEEN SMALL MIDWESTERN
AIRPORTS AND O'HARE GENERALLY ARE
NOT HIGHER THAN THOSE TO OTHER
HUBS
============================================================ Chapter 3

While concentration has increased, yields (revenues per passenger
mile) for operating between small airports and O'Hare generally are
not higher than those for flights between small airports and other
hubs.  Yields are generally lower for flights from small airports to
O'Hare, but part of the reason is that flights from small airports to
O'Hare are somewhat longer than for most of the other hubs.\1 The
average distance traveled between small airports and O'Hare, when
adjusted for differences in traffic, is 229.7 miles.  This is
exceeded only by miles traveled between small airports and two other
major hubs, Atlanta (320.2 miles) and Dallas/Fort Worth (262.4
miles). 

Correspondingly, yields for operating between small airports and
O'Hare are lower than at Atlanta and Dallas/Fort Worth, slightly
above St.  Paul, and higher than the four other hubs, Pittsburgh, St. 
Louis, Denver, and Boston.  These findings are consistent with those
from our earlier studies of fares at hub airports.\2 Table 3.1 lists
1992 fare yields between small airports served by the EAS program and
their hubs. 



                          Table 3.1
           
            1992 Fare Yields Between EAS Airports
                           and Hubs

                  (Cents per passenger mile)

                                       Average      Adjusted
Airport                                  Yield         yield
--------------------------------  ------------  ------------
Dallas/Fort Worth                        33.36         59.88
O'Hare                                   41.59         52.42
Atlanta                                  41.59         73.09
Denver                                   44.42         40.76
Minneapolis/St. Paul                     55.18         49.69
Pittsburgh                               59.10         44.49
Boston                                   60.72         35.21
St. Louis                                61.42         41.84
------------------------------------------------------------
Source:  U.S.  Department of Transportation. 


--------------------
\1 Yields tend to decline as distance increases and as costs are
spread out over more miles.  The yields calculated for this analysis
are for flights from essential air service airports to hub cities
that terminate at the hub cities.  The yields do not include the
fares for flights that connect at the hub with flights destined for
points beyond the hub. 

\2 Airline Competition:  Higher Fares and Reduced Competition at
Concentrated Airports (GAO/RCED-90-102, July 11, 1990); Airline
Competition:  Higher Fares and Less Competition Continue at
Concentrated Airports (GAO/RCED-93-171, July 15, 1993). 


AIRPORT AND AIRLINE OFFICIALS
BELIEVE O'HARE COULD ACCOMMODATE
MORE AIR TRAFFIC THROUGH MORE
EFFICIENT SLOT ALLOCATION
============================================================ Chapter 4

Most of the airport operators and airline representatives we talked
with said that O'Hare could accommodate more traffic.  Some believe
that, within current slot restrictions, the slots could be more
efficiently allocated to handle more flights.  Several operators and
representatives mentioned improvements in procedures and facilities
that have increased the airport's capacity. 

According to FAA data on daily general aviation traffic, some excess
capacity exists at O'Hare, although at certain times of the day most
slot allocation to general aviation aircraft are used.  Figure 4.1
shows that peak slot utilization occurs in the morning and the
mid-afternoon hours.  However, the critical factor for improving
access to O'Hare through better slot utilization is the time of day
that slots are not used.  Unused slots are only useful if they occur
at times EAS flights could use for making connections.  Nevertheless,
airport officials told us that service to EAS communities could be
enhanced by adding slots and scheduling flights at the off-peak
times. 

   Figure 4.1:  Average
   Half-Hourly General
   Aviation/Military Slot Usage at
   O'Hare Airport, November 1993

   (See figure in printed
   edition.)

Notes:  FAA regulations under instrument flight rules allow a maximum
of five general aviation/military operations in each half-hour
period.  Operations each use one slot.

Operations are averaged over the daily instrument flight rules
general aviation/military totals for the weekdays of November 1993,
excluding operations over the Thanksgiving holiday. 

Source:  Federal Aviation Administration. 

Although slots allocated to general aviation, which includes
military, might be a source for additional EAS operations, an O'Hare
Airport official told us that he believed that the number of slots
available from that source would be minimal.  He also pointed out
that relatively few military air operations are conducted at O'Hare,
and if military operations were to be eliminated completely, less
than one slot per hour would be recovered. 


IMPROVEMENTS AT O'HARE ARE
YIELDING CAPACITY INCREASES
============================================================ Chapter 5

Since 1983, improvements undertaken as part of the O'Hare Airport
Development Plan (ADP) have increased the airport's overall capacity. 
Terminal capacity, for example, has been significantly expanded by 2
million square feet to approximately 3.6 million square feet of area,
and 60 domestic gates have been added.  A new 1.2 million-square-foot
international terminal with 20 gates has also been added. 
Approximately $139 million has been spent by the city of Chicago on
taxiway and runway improvements, with an additional $50 million
raised through a 1992 bond issue for additional airfield capital
projects. 

In response to the ADP projects, FAA is planning a complete review of
the High Density Rule, under which FAA controls O'Hare slots, to
explore whether these capacity increases might affect the number of
operators that O'Hare and the other slot-controlled airports can
safely accommodate.  This review is expected to be completed in 1994. 
FAA has also started or has plans to start air traffic and ground
control projects that may also affect O'Hare's capacity. 
Construction has begun on a new control tower that would be more than
twice the size of the present tower.  A new ground control radar will
be installed, and FAA has begun construction on a new $91.5 million
terminal radar approach control facility at Elgin, Illinois,
replacing the current O'Hare terminal approach facility. 

As part of an overall Aviation System Capacity Plan developed in 1991
and 1992, FAA has recommended additional improvements to O'Hare
airfield operations which may also affect its capacity.  These
improvements include runway extensions and relocations, air traffic
control improvements, and several new technology improvements that
will result in maintaining safety while reducing a number of
operating restrictions. 


MAJOR CONTRIBUTORS TO THIS FACT
SHEET
=========================================================== Appendix I


   RESOURCES, COMMUNITY, AND
   ECONOMIC DEVELOPMENT DIVISION,
   WASHINGTON, D.C. 
--------------------------------------------------------- Appendix I:1

Allen Li, Associate Director, Transportation Issues
Francis P.  Mulvey, Assistant Director
Peter J.  Espada, Evaluator-in-Charge
Kristen Burnham, Evaluator


   CHICAGO REGIONAL OFFICE
--------------------------------------------------------- Appendix I:2

Robert M.  Ciszewski, Senior Evaluator

