[Audit Report on Deferred Maintenance, U.S. Fish and Wildlife Service]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 00-I-226

Title: Audit Report on Deferred Maintenance, U.S. Fish and Wildlife
       Service 

 
  Date: March 10, 2000
  
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  ****************************** 
  
  March 10, 2000
  
  Memorandum
  
  To:  Assistant Secretary for Fish and Wildlife and Parks
  
  From:  Robert J. Williams
  Assistant Inspector General for Audits
  
  Subject:  Audit Report on Deferred Maintenance, U.S. Fish and Wildlife Service
  (No. 00-I-226)
  
  This report presents the results of our audit of the U.S. Fish and Wildlife Service's deferred
  maintenance.
  
  In accordance with the Departmental Manual (360 DM 5.3), we are requesting a written
  response to this report by March 13, 2000.  The response should provide the information
  requested in Appendix 3.
  
  Section 5(a) of the Inspector General Act (Public Law 95-452, as amended) requires the
  Office of Inspector General to list this report in its semiannual report to the Congress.  In
  addition, the Office of Inspector General provides audit reports to the Congress.   U.S. Department of the Interior
  Office of Inspector General
  
  
  EXECUTIVE SUMMARY
  
  Deferred Maintenance,
  U.S. Fish and Wildlife Service 
  Report (No. 00-I-226)
  March 2000                     
  
  BACKGROUND
  
  The mission of the U.S. Fish and Wildlife Service (FWS) is "to work with others to conserve,
  protect, and enhance fish and wildlife and their habitats for the continuing benefit of the
  American people."  FWS accomplishes this mission through the management of 516 national
  wildlife refuges, 79 ecological services field stations, 66 national fish hatcheries, 48 wetland
  management districts with waterfowl production areas, and 50 coordination areas.  FWS also
  operates 56 fishery resource offices, 9 fish health centers, and 7 fish technology centers.  At
  these sites and facilities, FWS maintains buildings, roads, dikes, water control structures, and
  the equipment to support its wildlife management and fishery programs.  In support of its
  maintenance program, FWS operates two types of automated systems, one of which is used
  to manage routine maintenance activities.  The other system, established in 1982 "to enhance
  the Service-wide efforts in planning and budgeting for maintenance activities" (as stated in
  "Refuge Management Information System - MMS [maintenance management system]
  instructions") provides information on FWS's deferred maintenance.  In fiscal years 1996
  through 1998, FWS received total maintenance funding of $93.2 million for deferred
  maintenance, of which $72.9 million was for refuges and $20.3 million was for hatcheries. 
  
  OBJECTIVE
  
  The objective of the  audit was to determine whether FWS (1) managed its deferred
  maintenance program in accordance with laws, regulations, and guidance and (2) maintained
  and used a maintenance management system that provided useful and reliable data.
  
  RESULTS IN BRIEF
  
  We found that FWS did not spend deferred maintenance funding solely on deferred
  maintenance projects and did not allocate deferred maintenance funds in accordance with its
  Maintenance Management System Handbook, which states that FWS should establish
  priorities for projects to "optimize" the use of funds made available to correct maintenance
  deficiencies.  Instead, FWS allocated $9.6 million of $33.4 million of fiscal year 1998
  deferred maintenance funding for costs that were not directly related to the priority of
  deferred maintenance projects, including expenses such as regional administrative and 
  engineering (unrelated to deferred maintenance projects) support, small maintenance
  projects, and contingencies such as cost overruns. Also, FWS spent $4.8 million of its
  deferred maintenance funding for fiscal years 1996 through 1998 on nonmaintenance
  expenses such as equipment replacement, administrative functions, and routine maintenance
  work.
  
  We also found that FWS's information on its deferred maintenance needs and its estimates
  of its deferred maintenance costs were not reliable and/or prepared  in accordance with
  Federal accounting standards and Department of Interior (DOI) guidance.  Deferred
  maintenance information was not reliable because FWS had not (1) fully surveyed  its assets
  to identify asset condition and thereby determine its deferred maintenance needs; (2) fully
  documented its estimated deferred maintenance costs; (3) established adequate controls to
  ensure compliance with Federal, DOI, and FWS deferred maintenance guidance; and (4)
  implemented adequate controls to ensure the reliability of deferred maintenance data.  As a
  result, FWS may be unable to support its budget requests for deferred maintenance funding
  with reliable data.
  
  RECOMMENDATIONS
  
  We recommended that FWS establish a process for allocating deferred maintenance funds
  to field offices on the basis of national priorities and that the field offices discontinue the
  practice of allocating a fixed amount or percentage of funds for regional and engineering
  support, small deferred maintenance projects, and contingencies unless these projects  can
  be justified on the basis of their relative contribution to deferred maintenance activities.  In
  addition, we recommended that FWS establish and implement controls to ensure that
  deferred maintenance funding is used for its intended purpose.  We also recommended that
  FWS implement controls to ensure that (1) condition assessments and deferred maintenance
  cost estimates are documented; (2) FWS complies with Federal, DOI, and its own guidance
  on the identification of deferred maintenance needs and the estimation of deferred
  maintenance costs; and (3) deferred maintenance data entered into FWS's maintenance
  management system are complete, current, and accurate. 
  
  AUDITEE COMMENTS AND OFFICE OF INSPECTOR GENERAL EVALUATION
  
  In its response to the draft report, FWS concurred with five of the report's six
  recommendations.  Based on the response, we considered Recommendation A.1 resolved and
  implemented and Recommendations A.3, B.1, B.2, and B.3 resolved but not implemented. 
  Accordingly, the four unimplemented recommendations will be referred to the Assistant
  Secretary for Policy, Management and Budget for tracking of implementation.  
  
  In its response, FWS did  not concur with Recommendation A.2.  Specifically, FWS agreed
  to use or allocate deferred maintenance funds for activities such as regional and engineering
  support on a project-specific basis and not to allocate a fixed amount of deferred
  maintenance funding to these activities.   FWS, however, did not agree to discontinue
  allocating a fixed amount to the regions to finance small deferred maintenance projects, as
  we had recommended.  In our comments on  FWS's response to the draft report, we said that 
  FWS needs to ensure that the highest priority deferred maintenance projects are funded
  before it finances less expensive and possibly lower priority projects.  We requested that
  FWS reconsider its response to this recommendation, which is unresolved.
  
  
  CONTENTS
  
  
  
                                                       Page
  
  EXECUTIVE SUMMARY. . . . . . . . . . . . . . . . . . . . . .1
  
  INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . .5
  
  BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . .5
  OBJECTIVE AND SCOPE. . . . . . . . . . . . . . . . . . . . .5
  PRIOR AUDIT COVERAGE . . . . . . . . . . . . . . . . . . . .6
  
  FINDINGS AND RECOMMENDATIONS . . . . . . . . . . . . . . . .8
  
  A   ALLOCATION AND USE OF DEFERRED MAINTENANCE FUNDS . . . .8
  B.  DEFERRED MAINTENANCE DATA. . . . . . . . . . . . . . . 15
  
  APPENDICES
                                                         
  1.  REFUGES AND HATCHERIES VISITED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23
  2.  U.S. FISH AND WILDLIFE SERVICE RESPONSE . . . . . . . . . . . . . . . . . . . . . . . 25
  3.  STATUS OF AUDIT REPORT RECOMMENDATIONS . . . . . . . . . . . . . . . . . .32
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
              INTRODUCTION
  
                      
  BACKGROUND
  
  The mission of the U.S. Fish and Wildlife Service (FWS) is "to work with others to
  conserve, protect, and enhance fish and wildlife and their habitats for the continuing
  benefit of the American people."  FWS accomplishes this mission through the
  management of 516 national wildlife refuges, 79 ecological services field stations, 66
  national fish hatcheries, 38 wetland management districts with waterfowl production
  areas, and 50 coordination areas.  FWS also operates 56 fishery resource offices, 9 fish
  health centers, and 7 fish technology centers.  At these sites and facilities, FWS maintains
  buildings, roads, dikes, water control structures, and the equipment to support its wildlife
  management and fishery programs.  As of  September  30, 1998,  the  replacement value
  of these structures and equipment exceeded $4.5 billion for refuges and $800 million for
  hatcheries, according to FWS's budget justifications. 
  
  FWS officials at headquarters, regional, and field locations are responsible for
  maintaining  FWS's structures and equipment.  In support of its maintenance program, 
  FWS operates two types of automated systems, one of which is used to manage routine
  maintenance activities.  The other system, established in 1982 "to enhance Service-wide
  efforts in planning and budgeting for maintenance activities" (as stated in "Refuge
  Management Information System - MMS [maintenance management system]
  Instructions") provides information on FWS's  deferred maintenance.  According to
  Statement of Federal Financial Accounting Standards No. 6, "Accounting for Property,
  Plant, and Equipment," deferred maintenance is "maintenance that was not performed
  when it should have been or was scheduled to be and which, therefore, is put off or
  delayed for a future period."
  
  In fiscal years 1996 through 1998, FWS received total maintenance funding of $93.2
  million  for deferred maintenance, of which $72.9 million was for refuges and $20.3
  million was for hatcheries.  In addition, during this 3-year period, FWS received total
  construction funding of $20.9 million for specific deferred maintenance projects.  In its
  financial statements for fiscal year 1998, FWS reported a deferred  maintenance backlog
  of about $750 million as of September 30, 1998, with a range of plus or minus 15 percent
  of this amount.  This estimate excluded equipment replacements.
  
  OBJECTIVE AND SCOPE
  
  The objective of the audit was to determine whether FWS (1) managed its deferred
  maintenance program in accordance with established laws, regulations, and guidance and
  (2) maintained and used a maintenance management system that provided useful and
  reliable data.  The scope of our audit generally included the deferred maintenance
  activities of FWS that occurred during fiscal years 1996 through 1999.  
  
  Our scope included deferred maintenance projects that were reported in FWS's
  maintenance management system in fiscal years 1996 through 1999.  To accomplish our
  objective, we reviewed applicable Department of the Interior (DOI) and FWS guidance,
  policies, and procedures; planning, budget and expenditure documents; and maintenance
  management system reports.  We also interviewed FWS personnel responsible for
  deferred maintenance activities and conducted sites visits to the FWS locations and sites
  identified in Appendix 1.  At 25 refuge complexes and 9 hatchery complexes, which we
  selected primarily on the basis of the relative number and dollar value of deferred
  maintenance projects, we reviewed all deferred maintenance projects (1,965 refuge and
  262 hatchery deferred maintenance projects), which had an estimated cost of $198.7
  million.
  
  We conducted our audit in accordance with the "Government Auditing Standards," issued
  by the Comptroller General of the United States.  Accordingly, we included such tests of
  records and other auditing procedures that were considered necessary under the
  circumstances.  We also evaluated the systems of internal controls over deferred
  maintenance to the extent we considered necessary to accomplish our audit objective. 
  We found internal control weaknesses in the procedures and systems for identifying,
  estimating the costs of, and documenting deferred maintenance projects and project costs. 
  Our recommendations, if implemented, should improve the internal controls in these
  areas.
  
  We also reviewed the Departmental Reports on Accountability for fiscal years 1997 and
  1998, which include information required by the Federal Managers' Financial Integrity
  Act of 1982, and FWS's annual assurance statement on management controls for fiscal
  year 1998 and determined that no reported weaknesses were within the objective and
  scope of our audit.  Although FWS reported no weaknesses related to deferred
  maintenance, DOI reported for fiscal year 1998 that inadequate maintenance management
  capability was a material weakness which impacted "most bureaus" and was a "mission
  critical weakness."
  
  PRIOR AUDIT COVERAGE
  
  During the past 5 years, the Office of Inspector General (OIG) has issued two reports and
  the General Accounting Office has issued one report on FWS's maintenance activities as
  follows:
  
  -  The OIG report "Deferred Maintenance, National Park Service, U.S. Fish and Wildlife
  Service, U.S. Geological Survey, Bureau of Indian Affairs, Bureau of Land Management,
  and Bureau of Reclamation" (No. 99-I-874), issued in September 1999, stated that the
  National Park Service, the U.S. Fish and Wildlife Service, the U.S. Geological Survey,
  the Bureau of Indian Affairs, the Bureau of Land Management, and the Bureau of
  Reclamation needed to implement actions to ensure that deferred maintenance
  information was reliable for budgetary and accounting purposes and that neither DOI nor
  any of the bureaus could adequately support their fiscal year 1998 deferred maintenance
  cost estimates (based on our review of $542.5 million of estimated deferred maintenance
  costs).        
  
  - The OIG's "Testimony of Robert J. Williams, Acting Inspector General, U.S.
  Department of the Interior, on Facilities Maintenance at the Bureau of Land Management
  and the U.S. Fish and Wildlife Service Before the Subcommittee on Interior and Related
  Agencies, Committee on Appropriations, U.S. House of Representatives" (No. 98-T-350),
  dated February 1998, presented OIG's review of the two bureaus' maintenance backlogs. 
  The testimony specifically discussed (1) estimated deferred maintenance costs and the
  composition of maintenance backlogs, (2) procedures used to develop backlog estimates,
  (3) the reliability of the backlog data, and (4) procedures used to manage backlogs.  The
  testimony stated that both bureaus needed to take actions to improve the reliability of
  their backlog data.
  
  - The General Accounting Office's report "Deferred Maintenance Reporting, Challenges
  to Implementation" (No. GAO/AIMD-98-42), dated January 1998, discussed deferred
  maintenance activities at 11 Governmental agencies, including DOI, and the
  implementation of the requirements for reporting on deferred maintenance in agency
  financial statements.  The report stated that "most agencies do not have experience
  generating agencywide estimates of deferred maintenance because historically they have
  not been required to do so."  The report also stated that at the 11 agencies reviewed, some
  "initial steps have been taken, [but] significant work remains to be done for all agencies
  to effectively implement the deferred maintenance requirements promptly."
     FINDINGS AND RECOMMENDATIONS
  
  
  A.  ALLOCATION AND USE OF DEFERRED MAINTENANCE
  FUNDS
  
  FWS did not allocate or use deferred maintenance funds in accordance with FWS
  guidance. FWS's Maintenance Management System Handbook states that FWS should
  establish priorities for projects included in its maintenance management system and that it
  should "optimize" the use of funds made available for the correction of maintenance
  deficiencies.  The FWS Handbook also states that deferred maintenance funds should be
  used only for maintenance related to existing facilities and should not be used for routine
  maintenance activities or for work or projects that are funded from operations or
  construction appropriations.  However, FWS did not allocate all funding for deferred
  maintenance projects on the basis of project priorities and did not ensure that available
  funding for deferred maintenance projects was used for its designated purposes.  As a
  result, FWS's most critical deferred maintenance projects may not have been funded, and
  available deferred maintenance funding may not have been used to reduce the backlog. 
  Of $93.2 million of maintenance funding made available for FWS's deferred maintenance
  projects in fiscal years 1996 through 1998, we identified funding of $14.4 million that
  was allocated for or spent on nonmaintenance items or activities such as equipment
  replacement, administrative functions, or routine maintenance work that should have been
  funded by other appropriations.
  
  Allocation of Resource Management Funds
  
  Chapter 1, Section 1.2, of the FWS Handbook states that the primary objectives of FWS's
  maintenance management system are to (1) optimize the use of available funds,
  personnel, and facilities through effective maintenance management methods; (2) provide
  accurate data for maintenance program decision-making; (3) identify maintenance
  needs/deficiencies at all field stations; and (4) establish regional and national
  maintenance project priorities.  Although FWS's maintenance management system
  enabled personnel to record the priority of maintenance projects, we found that the
  priority ranking of all maintenance projects had not been entered into the system. 
  Moreover, FWS generally allocated funding on the basis of each region's relative
  deferred maintenance backlog rather than on the priority ranking of each region's deferred
  maintenance projects. 
  
  FWS also did not allocate deferred maintenance funds in a manner that, in our opinion,
  would ensure that the highest priority deferred maintenance projects were funded. 
  Specifically, of $33.4 million of fiscal year 1998 maintenance appropriations allocated to
  the regions  for deferred maintenance that was included in our  review,  we found that
  funds of $9.6 million were provided for (1) regional administrative costs, (2) engineering
  support that was not based on services rendered on deferred maintenance projects, (3)
  small deferred maintenance projects, and (4) contingencies.  These four areas of
  allocation are discussed in the paragraphs that follow.
  
  Regional Administrative Costs.  The five regions reviewed allocated $2.2 million of
  their deferred maintenance funding to support regional operational activities.  For
  example, Region 1 retained 8 percent of the Region's deferred maintenance funding
  allocation in fiscal years 1997 and 1998 to pay administrative, public relations, and
  contracting expenses.  Thus, in fiscal year 1997, the Region retained $271,000 of the
  deferred maintenance funding allocation, and in fiscal year 1998, when the funding
  allocation doubled, the Region retained  $565,000.  The other four regional offices
  retained deferred maintenance funding allocations to pay for "shared costs" ($1.1 million)
  such as administrative expenses or for specific equipment replacement items ($415,500)
  such as computers and vehicles for regional office activities.  In two regions, deferred
  maintenance funds were retained and used for expenses that were not related to deferred
  maintenance.  For example, in fiscal year 1998, Region 4 retained deferred maintenance
  funds of $128,800 to pay part of the routine operational costs of the Region's Youth
  Conservation Corps Program at its field stations.
  
  Engineering Support.  A portion of FWS's deferred maintenance funding was allocated
  to regional engineering offices that provided support for deferred maintenance projects. 
  Specifically, in fiscal year 1998, the engineering offices were allocated $2.9 million of the
  deferred maintenance funding for refuges and  hatcheries.  However, the allocation of
  deferred maintenance funds for regional engineering support was not based on the level
  of effort or the amount of time spent on deferred maintenance projects.  Instead, deferred
  maintenance funds were allocated on the basis of the construction costs of projects
  assigned to the engineers during the previous fiscal year.  Thus, if regional engineers
  worked on the same construction project during 2 consecutive fiscal years, the
  engineering offices would receive deferred maintenance funding for that project in both
  years regardless of the amount of engineering work on the project. 
  
        "Small" Deferred Maintenance Projects.  In fiscal year 1998, Region 3
  allocated 52 percent of its deferred maintenance funding allocation ($2.7 million) to
  refuges for small deferred maintenance projects, and Region 5 allocated 27 percent of its
  funding allocation ($1.2 million) to refuges so that station managers could "select small
  [maintenance] projects to accomplish from the backlog list."  In providing funds for small
  deferred maintenance projects, FWS did not ensure that the highest priority projects
  received funding.  For example, Region 5 calculated each station's percentage of the
  Region's total backlog in determining the amount of deferred maintenance funds that
  would be allocated to each station.  However, in calculating the funding distribution, the
  Region established a minimum amount, $7,500 for a staffed field station and $5,000 for
  field biologists, that would be distributed to each refuge.  By establishing this minimum
  amount of funds for distribution, FWS provided some refuges with greater or lesser
  amounts of funding in relation to their share  of  the total deferred maintenance backlogs.  
  For example,  FWS officials at the Silvio O. Conte National Fish and Wildlife Refuge in
  Massachusetts reported that they did not have a backlog.  However, under the Region's
  funding distribution plan, the Refuge received the minimum funding allocation of $7,500. 
  
  Under the regional plan to distribute funds for small deferred maintenance projects, FWS
  also provided for a funding allocation to "minimize extra large increases for big stations
  to accommodate small stations." As such, some refuges with relatively large deferred
  maintenance backlogs did not receive funding commensurate with their needs.  For
  example, the Patuxent National Research Wildlife Refuge in Maryland reported a
  deferred maintenance backlog of $6.6 million, which, as a percentage of the Region's
  total funding allocation, would have resulted in a deferred maintenance funding allocation
  of $108,100.  However, because the Region limited the amount of funding provided to
  "big stations," the Refuge was allocated only $40,000.  In total, we found that 10 stations
  received $126,800 less than their relative share of the total deferred maintenance backlog
  and that 21 stations received $161,900 more than their relative share of the backlog.  We
  also found that at eight refuges visited in Regions 3 and 5, where funding of $373,100
  was provided for small deferred maintenance projects, five refuges did not complete their
  highest priority maintenance projects.  For example, one refuge in Region 5 listed a
  $67,000 project to rehabilitate work space as its fiscal year 1998 highest priority deferred
  maintenance project.  The project was not completed, even though the refuge received
  $85,000 in fiscal year 1998 to finance small deferred maintenance projects. 
  
  Contingency and Routine Maintenance Costs.  At three of the regions reviewed, FWS
  reserved deferred maintenance funds of $395,700 for contingencies such as cost overruns
  and/or emergency use and for annual and/or routine maintenance.  We found that these
  funds generally were  used to pay expenses other than those related to deferred
  maintenance projects.  For example, Region 5 allocated deferred maintenance funds of
  $134,000 to pay for recurring or annual maintenance costs at several of its fish hatcheries
  such as rehabilitating generators and wells, and Region 3 used deferred maintenance
  funds of $249,600 for items such as astroturf, microscopes, and test tubes, which, in our
  opinion, do not represent deferred maintenance costs.  
  
  Use of Deferred Maintenance Funds
  
  Chapter 1 (Sections 1.3, 1.6, and 1.7) of the FWS Handbook states that deferred
  maintenance funds should be used only on maintenance related to existing facilities and
  should not be used for routine maintenance activities or for projects or work that are
  funded from operations or construction appropriations.  Also, Statement of Federal
  Accounting Standards No. 6 states that deferred maintenance does not include "activities
  aimed at expanding the capacity of an asset or otherwise upgrading it to serve needs
  different from, or significantly greater than, those originally intended." 
  
  However, we found that deferred maintenance funding in some cases was not spent on
  activities associated with deferred maintenance projects.  Instead, the funds were used to
  finance routine maintenance activities, to acquire needed physical assets, and to
  supplement operating budgets.  We also found that deferred maintenance funding was
  allocated and spent on projects which, in our opinion, did not qualify as deferred
  maintenance items.  For example:
  
  - One station spent deferred maintenance funds of $3,158 for brochures for the refuge,
  and another station used $1,471 to make office repairs that had not been identified as
  deferred maintenance needs.
  
  - During fiscal year 1996, FWS allocated $300,000 to the Warm Springs National Fish
  Hatchery in Georgia for the rehabilitation of its administration building.  The original
  intent, according to the station manager, was to add office space to the existing laboratory
  building and to convert the existing office space to laboratory facilities.  The station
  manager stated that the plan was rejected by the Region's engineering division.  However,
  the Region did not revoke the deferred maintenance funds that had been provided to the
  Hatchery for this project.  In June 1997, Regional officials approved the use of the
  deferred maintenance funds to finance a new office building that was to be situated across
  the street from the existing structure, and in September 1997, a contract was awarded to
  construct the new building. 
  
  -  Region 4 officials funded two projects, at a cost of $52,391, from the Region's deferred
  maintenance allotment to replace furniture, "outfit" a new office building, and 
  replace/upgrade various equipment items. 
  
  -  FWS used deferred maintenance funds to acquire replacement equipment such as
  computers and vehicles totaling $2.1 million.  Because the replaced items had exceeded
  their useful lives, these expenditures did not qualify as deferred maintenance needs.
  
  We also found that at 17 of the 34 field stations reviewed, managers did not use the funds
  remaining after a deferred maintenance project was completed to pay for other deferred
  maintenance projects.  Instead, they used the surplus funds to pay for operational and/or
  routine maintenance expenses such as salaries of permanent employees; materials and
  supplies; and transportation equipment repairs, fuel, and parts.  For example:
  
  - The station manager at the White River National Wildlife Refuge in Arkansas used the
  funds remaining after completion of a bridge replacement project to purchase equipment,
  including a circular saw, a drill, a jigsaw, and a utility trailer.  The station manager also
  used  $27,218 of surplus funds from a $45,000 project to purchase a new pickup truck,
  which was an "addition to fleet" and not a replacement for an existing vehicle. 
  
  - The station manager at the Wheeler National Wildlife Refuge in Alabama used deferred
  maintenance funds remaining after completion of a $25,000 road repair project to pay for
  part of the cost of a used tractor trailer vehicle. 
  
  We also found that eight station managers used deferred maintenance funds to pay the
  salaries of permanent employees who worked on deferred maintenance projects, even
  though FWS officials stated that it was FWS policy to pay managers salaries from
  operating rather than from deferred maintenance funds.  In addition, in 325 cases, FWS
  provided deferred maintenance funds of $8.6 million to refuges and hatcheries based on
  station managers' requests for funding.  Because the station managers did not specify
  which deferred maintenance projects were to be funded, we could not determine whether
  the allocated funds were spent on deferred maintenance work, particularly at the 97
  locations at which the funds were commingled with operating funds.
  
  Field personnel were able to use the deferred maintenance funds for other purposes
  because FWS did not have specific reporting requirements and did not conduct
  management control reviews to detect and prevent the improper use of deferred
  maintenance funds.  As a result, we found that of the $9.7 million of deferred
  maintenance funds obligated during fiscal years 1996  through  1998  by  the  34 stations
  reviewed, $4.8 million was spent as follows: (1) $2.3 million for nonmaintenance
  activities such as the purchase of a fee collection unit, exhibit replacements, and Youth
  Conservation Corps activities; (2) $2.1 million for equipment replacement; and (3)
  $351,935 for operational or routine maintenance work.  
  
  Recommendations
  
  We recommend that the Director, FWS :
  
  1.  Establish a process for allocating deferred maintenance funds to field offices on the
  basis of national project priorities.
  
  2.  Discontinue the practice of allocating a fixed amount or percentage of deferred
  maintenance funds for regional management, engineering support, small deferred
  maintenance projects, and contingencies unless such expenses can be justified on the
  basis of their relative contribution to deferred maintenance activities.
  
  3.  Establish and implement controls to ensure that deferred maintenance funding is used
  for its designated purpose.
                           
  FWS Response and OIG Reply
  
  In the December 17, 1999, response (Appendix 2) to the draft report from the Deputy
  Director, FWS concurred with Recommendations 1 and 3 and did not concur with
  Recommendation 2.  Based on the response, we consider Recommendation 1 resolved
  and implemented, Recommendation 2 unresolved, and  Recommendation 3 resolved but
  not implemented (see Appendix 3).  Accordingly, Recommendation 3 will be referred to
  the Assistant Secretary for Policy, Management and Budget for tracking of
  implementation.
  
  Regarding Recommendation 2, FWS stated that beginning in fiscal year 2000, "annual
  maintenance funding will be allocated to the regions to provide needed funds for small
  maintenance projects" and that it would issue instructions stating that "any funds needed
  for activities such as regional support, engineering support, or IRM [information
  resources management] support are to be funded and managed on a project by project
  basis."  FWS further said that regional offices "are not authorized to use deferred
  maintenance funds for general overhead or contingencies."
  
  We consider Recommendation 2 unresolved because FWS indicated that it would
  continue the practice of allocating a fixed amount or a percentage of deferred
  maintenance funding for small deferred maintenance projects.  In our opinion, to achieve
  the most cost-effective use of funds, FWS needs to ensure that the highest priority
  deferred maintenance projects are funded before funds are provided for less expensive
  and possibly lower priority projects.  Therefore,  we  request that FWS reconsider its
  response to Recommendation 2 (see Appendix 3). 
  
  General Comments on Finding
  
  FWS also provided additional comments on the finding.  FWS's comments and our
  replies are as follows:
  
  Objectives and Scope
  
  FWS Comments.  FWS said that our statement that "inadequate maintenance
  management capability was a 'mission critical weakness' which impacted 'most bureaus'
  implies that FWS was among those critically impacted bureaus."  FWS further noted that
  neither the OIG nor the General Accounting Office had identified FWS as one of the
  bureaus having such a "mission critical" weakness. 
  
  OIG Reply.  We revised the report to state that FWS was not reported to have a mission
  critical weakness in its maintenance management capability.  However, deficiencies
  identified in our audit of FWS's deferred maintenance were the same as those that
  contributed to mission-critical maintenance weaknesses in other bureaus.
  
  Allocation and Use of Deferred Maintenance Funds
  
  FWS Comments.  FWS said that without information on the specific projects on which
  deferred maintenance funds of $14.4 million reportedly were inappropriately spent or
  allocated, "it is difficult for us to identify or evaluate these projects as having been funded
  inappropriately."
  
  OIG Reply.  We will provide FWS with detailed information on the projects.
  
  Use of Deferred Maintenance Funds
  
  FWS Comments.  FWS stated that under guidance in effect during fiscal years 1996
  through 1998, the deferred maintenance funding of  $2.1 million for computer and vehicle
  replacements was "appropriate."  FWS also said that although it had interpreted Federal
  accounting standards as providing for equipment and vehicles to be included as deferred
  maintenance items, it has requested clarifying guidance from DOI on whether equipment
  and equipment replacement are reportable deferred maintenance costs.  FWS further
  stated that deferred maintenance standards are changing in their application and definition
  and that the report should be "clarified to give the reader a full appreciation of the
  changing nature of standards guiding deferred maintenance reporting and auditing."  FWS
  noted that the required level of audit review of deferred maintenance data in Federal
  agencies' financial statements was amended in April 1999.
  
  OIG Reply.  We agree that additional guidance on deferred maintenance, including a
  clarification of replacement costs, is needed.  However, FWS is the only bureau in DOI to
  include the replacement of equipment and vehicles as deferred maintenance items. 
  Further, Statement of Federal Financial Accounting Standards No. 6 states that
  maintenance "includes preventative maintenance, normal repairs, replacement of parts
  and structural components, and other activities needed to preserve the asset so that it
  continues to provide acceptable services and achieves its expected life."  We interpret this
  definition to mean that deferred maintenance enables an item to reach its useful life and
  does not mean that deferred maintenance provides for the replacement of items that have
  reached or surpassed their useful lives. Although the level of audit review of deferred
  maintenance data for fiscal year 1998 financial statements was changed, the Federal
  standard applicable to the types of items that should be reported as deferred maintenance
  in fiscal year 1998 did not change. 
  
     B.  DEFERRED MAINTENANCE  DATA
  
  FWS did not always produce or maintain reliable information on its deferred maintenance
  needs and/or estimate its deferred maintenance costs in accordance with Federal
  accounting standards and DOI guidance.  Deferred maintenance information was not
  reliable because FWS had not (1) conducted surveys of all of its assets to identify asset
  condition and thereby determine deferred maintenance needs; (2) fully documented its
  estimated deferred maintenance costs; (3) established adequate controls to ensure
  compliance with Federal, DOI, and FWS deferred maintenance guidance; and (4)
  implemented adequate controls to ensure the reliability of deferred maintenance data.  As
  a result, FWS may not produce reliable deferred maintenance data for inclusion in its
  financial statements and did not have sufficient reliable data to fully support its fiscal year
  2000 budget requests for deferred maintenance funding.
  
  Deferred Maintenance Guidance
  
  The Governmentwide standard for deferred maintenance was established in November
  1995, when the Federal Accounting Standards Advisory Board issued Statement of
  Federal Accounting Standards No. 6.  Chapter 3, "Deferred Maintenance," of the
  Standard defines deferred maintenance as "maintenance that was not performed when it
  should have been or was scheduled to be and which, therefore, is put off or delayed for a
  future period"; as "the act of keeping fixed assets in acceptable condition"; and as
  "activities needed to preserve the asset so that it continues to provide acceptable services
  and achieves its expected life."  Chapter 3 also states that Federal agencies are required to
  identify and measure their deferred maintenance for financial statement reporting
  purposes.
  
  DOI issued guidance in 1998 on deferred maintenance in Attachment G to DOI's "Fiscal
  Year 2000 Budget Request Formulation Guidance."  This guidance directed the bureaus
  to use the condition assessment method to identify their deferred maintenance needs and
  described condition assessments as "a complete inventory of their constructed assets [to]
  identify the cost of correcting the deferred maintenance needs associated with those
  assets."  The guidance also stated that a condition code (good, fair, or poor) should be
  assigned to inspected assets and defined the deferred maintenance backlog as the
  "unfunded or otherwise delayed work required to bring a facility or item of equipment to
  a condition that meets accepted codes, laws, and standards and preserves the facility or
  equipment so that it continues to provide acceptable services and achieves its expected
  life."
  
  Appendix B of the FWS Handbook defines the maintenance backlog as "those items of
  maintenance and repair which cannot be corrected within 12 months from the time the
  deficiency was detected."  Chapter 4 of the FWS Handbook further states, "Standardized
  inspections are necessary to determine the condition of facilities and equipment and to
  identify and document maintenance needs."  These inspections also are to be conducted
  periodically.
  
  
  Reliability of Data
  
  We found that FWS's deferred maintenance data for fiscal year 1998 were unreliable
  because the items included in FWS's deferred maintenance listings in some cases were
  not supported with documentation to show that the required condition assessments had
  been conducted, were not supported with documented estimates of deferred maintenance
  costs, and did not meet the Federal or DOI definition of deferred maintenance. 
  Specifically, we found that although FWS was required to conduct condition assessments
  to identify its deferred maintenance needs and to inventory asset condition, none of the 34
  field stations we visited had conducted condition assessments for all of the assets in their
  deferred maintenance backlog.  Station managers said that the only projects with detailed
  condition assessments, including documented cost estimates, were bridge repair or
  replacement projects.  In fieldwork related to an audit of the deferred maintenance cost
  estimates of six DOI bureaus (Report No. 99-I-874), we found that only 41 of 119 FWS
  projects reviewed had documented condition assessments and that 73 of these 119
  projects did not have documented cost estimates.
  
  We also found that FWS included items in its deferred maintenance listing that did not
  meet Federal accounting standard, DOI, and/or FWS definitions of deferred maintenance,
  as described in the paragraphs that follow:
  
  Habitat Rehabilitation Projects.  Although Appendix D of the FWS Handbook states
  that habitat maintenance projects should not be included in FWS's deferred maintenance
  listings, we found that 33 of the 2,227 deferred maintenance projects reviewed (with a
  total estimated cost of $8.8 million) were habitat maintenance or restoration projects
  which did not involve the maintenance of existing structures or facilities.  For example:
  
  - A deferred maintenance project at the Okefenokee National Wildlife Refuge in Georgia
  provided for the repair of two water structures (low hazard dams), at an estimated cost of
  $6.9 million.  During fiscal year 1998, Refuge managers reduced the cost estimate by
  $1.9 million, to a new total of $5.0 million, and redefined the project.  As redefined, the
  project did not entail the repair of the water structures.  Instead, the objective of the
  project was to establish a "4-year monitoring plan" in partnership with the U.S.
  Geological Survey, to remove two water structures, and to "breach the dike in numerous
  locations to simulate the natural riverine system."  
  
  - In Texas, the Anahuac National Wildlife Refuge's deferred maintenance backlog
  included five habitat rehabilitation projects that provided for the removal of oil facilities,
  drill pads, and roads from the Roberts Mueller Tract ($1.2 million); old structures in
  Onion Bayou ($45,000); old structures and trailers from the Middleton Tract ($95,000);
  old cattle shelters from Jackson/White and Old Anahuac ($30,000); and old oil pads and
  roads from Old Anahuac, Gator Marsh ($60,000).
  
  - In Virginia, the Mason Neck National Wildlife Refuge's deferred maintenance backlog
  included two habitat rehabilitation projects, with an estimated cost of $1.2 million, that
  provided for the removal of military buildings on property being transferred to the
  Refuge.  
  
  Exhibit Updates.  Although deferred maintenance, as defined in Federal accounting
  standards and DOI guidance, includes the rehabilitation or repair of equipment, it does
  not include the modernization of  items that have exceeded their useful lives or that are
  obsolete.  At six of the field stations reviewed, we identified 12 projects, with cost
  estimates totaling about $2.3 million, that provided for the replacement of assets that had
  exceeded their useful lives or were obsolete.  For example:
  
  - A deferred maintenance project at the Okefenokee National Wildlife Refuge in Georgia
  included a project that was described as "[r]eplace/update worn or inaccurate public use
  displays" at the visitor center (estimated cost of $1,390,000).  Refuge management stated
  that the existing displays were outdated and in some cases needed to be updated with new
  technology.
  
  - Three deferred maintenance projects at the Patuxent Wildlife Research Refuge in
  Maryland provided for the refurbishing of visitor center exhibits.  Descriptions for two of
  the projects (estimated cost of $260,000) stated, "Rehabilitate several exhibit panels at the
  National Wildlife Visitor Center to educate the public about wildlife program activities
  and to explain the Service mission and its role in research."  Refuge managers said that
  the project would entail updating old exhibits using current technology.  A description for
  the third project stated, "Rehabilitate animal exhibits by having a taxidermist check
  animal items for bugs."
  
  Projects for New or Upgraded Structures.  Deferred maintenance guidance does not
  provide for projects to be classified as deferred maintenance if they significantly increase
  facility size (according to the FWS Handbook, deferred maintenance projects can increase
  an existing building's size by up to 10 percent) or if they represent a major upgrade or
  serve needs different from, or significantly greater than, those originally intended. 
  However, we found that the backlog listings for the 25 refuge stations reviewed included
  39 projects, with an estimated deferred maintenance cost of $13.8 million, which
  provided for new facilities, the significant expansion of existing facilities, or a facility
  upgrade that served needs other than those of the original structure.  For example:
  
  - A deferred maintenance project at the Genoa National Fish Hatchery in Wisconsin, with
  an estimated cost of $1 million, provided for the replacement of a deteriorated office,
  outreach, and education facility.  The justification for the project stated, "Current office
  building is over 60 years old and inadequate to meet the needs of the hatchery staff and
  the visitor load the hatchery has annually."  The justification also stated that the project
  would provide for a "new office . . . equipped with aquariums, and visitor displays
  depicting the hatchery's programs, and the Service's mission," features that were not
  included in the original facility.
  
  -  A deferred maintenance project at the Attwater Prairie Chicken National Wildlife
  Refuge in Texas, with an estimated cost of $1 million, provided for the replacement of an
  "old, energy inefficient, and insect infested visitor center."  We found that the visitor
  center was a house that had not been constructed  to serve as a visitor center. 
  
  -  A deferred maintenance project at the Sacramento National Wildlife Refuge in
  California provided for the replacement of "dilapidated unsafe mobile trailer residence for
  fire crew, interns, volunteers, researchers, and temporary employees with [a] five-
  bedroom bunkhouse.  Dilapidated wiring and lack of hard-wired fire alarm or sprinkler
  system pose [a safety hazard]."  Refuge managers estimated that it would cost $225,000
  to build the bunkhouse to replace the trailers.
  
  Completed Projects.  After our site visits, station managers eliminated from their
  deferred maintenance backlog 515 projects, with an estimated cost of $28.5 million, that
  we had identified as completed or not appropriately classified as deferred maintenance
  projects.  For example:
  
  - Managers at the Wichita Mountains Wildlife Refuge in Oklahoma, after our site visit,
  eliminated from their deferred maintenance listing 41 projects, with cost estimates
  totaling $2.1 million, that had been completed in prior years.  Likewise, managers at the
  Patuxent Research Refuge in  Maryland eliminated 72 projects,  with an estimated cost of
  $3 million, from the Refuge's deferred maintenance backlog.  The eliminated projects
  included work that had been completed in prior years and other projects that were the
  responsibility of the Refuge's tenant, the U.S. Geological Survey's Biological Research
  Division.  The Refuge deleted 60 projects, with an estimated cost of $2.5 million, that
  also were reported as deferred maintenance needs by the Geological Survey. 
  
  - During our review, managers at the Yazoo National Wildlife Refuge Complex in
  Mississippi deleted from their deferred maintenance listing 19 projects, having an
  estimated cost of $2.7 million.  One of these projects, the replacement of the office/visitor
  facility, had an estimated cost of $2 million.  The project is not deferred maintenance, in
  our opinion, because the replaced facility is a 40-year old converted shop building and the
  replacement structure will have features, including interpretive facilities, a conference
  room, and an auditorium, that are not part of the original structure.
  
  Support for Data
  
  We found that FWS's deferred maintenance data were not reliable because FWS's field
  stations had not performed or documented the performance of condition assessments to
  determine the status (good, fair, or poor condition) of all of FWS's assets and to identify
  FWS's deferred maintenance needs.  Also, FWS had not required that documentation be
  prepared to support its estimated deferred maintenance costs; therefore, supporting
  documentation was not always available to determine whether estimated deferred
  maintenance costs were reliable.  FWS also had not established adequate controls to
  ensure that its personnel complied with Federal accounting standard, DOI, and FWS
  deferred maintenance guidance.  Also, although FWS's maintenance management system
  provided for the recording of useful data, FWS had not implemented adequate controls to
  ensure that deferred maintenance data were accurate, current, and complete and
  safeguarded against unauthorized revision.
  
  We also found that the field offices did  not always comply with the FWS Handbook 
  (372 FW 2), which states, "Regional Offices/field stations are responsible for data
  integrity, project priorities, and meeting system update schedules."  Chapter 5, Section
  5.1, of the FWS Handbook further requires that cost estimates entered into the
  maintenance management systems be adjusted for inflation.  However, we found that
  carryover projects were not always adjusted for inflation by station management.  For
  example, at the 25 wildlife refuges reviewed, we identified 1,282 deferred maintenance
  projects that were carried forward from fiscal years 1998 to 1999.  However, we found
  that 893 (about 70 percent) of these projects were not adjusted for inflation.  Although
  FWS has issued guidance on developing cost estimates and requires that backlog data be
  reviewed by all organizational levels at least once a year, we found that cost estimates,
  except for bridge repair and replacement projects, generally were not documented and
  that backlog data reviews had not detected the inclusion of inappropriate deferred
  maintenance items in the backlog listings.
  
  Use of Data
  
  FWS needs to improve the reliability of its deferred maintenance data so that it can
  prepare a reliable estimate of its deferred maintenance costs for financial reporting
  purposes.  In January 1999, the Office of Management and Budget issued guidance to
  Federal agencies, "Amendments to OMB Bulletin No. 98-08, 'Audit Requirements for
  Federal Financial Statements,'" which states that for fiscal year 1998, the Office had
  reduced the scope of audit of deferred maintenance data reported in Federal financial
  statements but that it "expects to increase the level of audit assurance relating to deferred
  maintenance . . . in future years as the standards and criteria for reporting such
  information are developed."
  
  Also, FWS needs reliable deferred maintenance cost estimates to support its budget
  requests for deferred maintenance funding.  In budget documents for fiscal years 1997
  through 2000, FWS requested total funding of $152.6 million for 154 deferred
  maintenance construction projects.  During our audit, we reviewed 17 of these projects to
  determine whether the supporting deferred maintenance cost estimates were reliable.  We
  found that for 13 projects, FWS did not provide  sufficient documentation to support the
  need for the projects (that is, documentation to show that condition assessments had been
  performed) and/or documentation on the basis for the estimated costs of these deferred
  maintenance projects.
  
  Recommendations
  
  We recommend that the Director, FWS:
  
  1.  Require that adequate documentation on condition assessments and deferred
  maintenance cost estimates be prepared.
  
  2.  Implement controls to ensure FWS compliance with Federal, DOI, and FWS guidance
  on the identification of deferred maintenance needs and the estimation of deferred
  maintenance costs.
  
  3.  Implement controls to ensure that deferred maintenance data entered into FWS's
  maintenance management system are complete, current, and accurate. 
  
  FWS Response and OIG Reply
  
  In the December 17, 1999, response (Appendix 2) to the draft report from the Deputy
  Director, FWS concurred with all three recommendations.  Based on the response, we
  consider the recommendations resolved but not implemented (see Appendix 3). 
  Accordingly, the unimplemented recommendations will be referred to the Assistant
  Secretary for Policy, Management and Budget for tracking of implementation.
  
  General Comments on Finding
  
  FWS provided additional comments on the finding.  FWS's comments and our replies are
  as follows:
  
  Deferred Maintenance Data and Guidance
  
  FWS Comments.  FWS said that it disagreed with our conclusion that FWS "may not
  produce reliable deferred maintenance data for inclusion in its financial statements."  It
  also said that there is a difference between Federal accounting guidance and DOI
  guidance on deferred maintenance and that deferred maintenance cost estimates based on
  the two "are significantly different in their use and purpose and in the data sets that
  contribute to each estimate." According to FWS, DOI guidance provides for deferred
  maintenance cost estimates of future funding needs that are developed in support of the
  budget package.  FWS said that the Federal accounting standards require estimates of
  total costs, including all labor costs, that may not be included in DOI's deferred
  maintenance cost estimates.  FWS also said that the report "introduces" budget estimates
  for fiscal year 2000, which "should be excluded from the scope of this audit as it [the
  audit] was to cover fiscal years 1996 through 1998."
  
  OIG Reply.   This finding pertained to FWS's deferred maintenance data that were
  developed for inclusion in its financial statements for fiscal year 1998.  As such, we
  applied the applicable, Federal accounting criteria in determining whether the cost
  estimates were reliable.  We also discussed DOI guidance on deferred maintenance, 
  including Attachment G to DOI's "Fiscal Year 2000 Budget Request Formulation
  Guidance," which defines deferred maintenance and instructed the bureaus to use the
  condition assessment method to identify their deferred maintenance needs.  We did not
  apply the guidance contained in other attachments, which directed the bureaus to exclude
  certain project costs in developing deferred maintenance cost estimates for budget
  formulation purposes.  We believe that FWS may have prepared inaccurate financial
  statement deferred maintenance cost estimates in part by inappropriately using the project
  cost estimating criteria in the budget formulation guidance.  Also, we referred to "budget
  documents for fiscal years 1997 through 2000" to quantify the amount of deferred
  maintenance funding that FWS reported as a budgetary requirement and to illustrate the
  importance of developing reliable data to support funding requests for such significant
  expenses.
  
  Reliability of Data
  
  FWS Comments.  FWS stated that the use of condition assessments as the basis for
  developing reliable deferred maintenance cost estimates has not been a long-term
  accepted procedure.  Specifically, FWS said that "the concept of 'condition assessments'
  as a formal documented procedure was not uniformly applied in other fiscal years, except
  as the concept was defined" in the FWS's Maintenance Management System Handbook.
  
  OIG Reply.  The use of assessments to determine whether assets need repair or
  maintenance was a required FWS procedure for several years before fiscal year 1998
  deferred maintenance cost estimates were developed.  For example, Chapter 4 of the FWS
  Manual, which was last revised in 1992, states, "Standardized inspections are necessary
  to determine the condition of the facilities and equipment to identify and document
  maintenance needs."  Although the term "condition assessment" may not have been used,
  FWS nonetheless recognized the need to identify and to document the condition of
  facilities and equipment on a periodic basis, actions that are essential to a condition
  assessment. Despite the guidance contained in FWS's Manual, we found that none of the
  34 field stations we visited conducted  "periodic inspections" to document the condition
  of all of the assets in their deferred maintenance backlog.
  
  Habitat Rehabilitation Projects
  
  FWS Comments.  FWS said that "habitat rehabilitation is not an appropriate use of
  deferred maintenance funds; however, all of the projects cited involved modification or
  demolition of facilities."  Discussing the Okefenokee sill project, FWS said that this
  project was revised to include a 2-year monitoring effort "as a precursor to a decision on
  partial rehabilitation of water control structures" and that two other projects cited in the
  report were not habitat rehabilitation but the removal of unneeded facilities that were
  "creating a health and safety risk for employees and visitors."  Regarding these projects,
  FWS said that "[w]ithout the ability to use deferred maintenance funds to correct these
  sometimes sizeable health and safety liabilities," it will be "severely hampered in taking
  timely corrective actions."
  
  OIG Reply.  The three projects discussed in the report provided for the modification or
  removal of structures that were no longer needed (in one case) or were undesirable
  structures that had conveyed to FWS when the property was acquired (two cases).  These
  projects did not involve maintenance work that had been deferred.  Although funding may
  be needed to dismantle unsafe or unused facilities, we do not consider such projects to be
  deferred maintenance projects as defined in Federal accounting standards.  Thus, we do
  not consider the habitat rehabilitation project costs to be appropriate for inclusion in
  FWS's financial statements  for fiscal year 1998 as deferred maintenance items.  We
  consider the need for funding of rehabilitation projects to be an issue separate from the
  financial reporting of estimated deferred maintenance costs. 
  
  Support for Data
  
  FWS Comments.  FWS said that our report implies that FWS's deferred maintenance
  data were "not reliable" because FWS "had not performed or documented the
  performance of condition assessments."  FWS said that it conducted periodic inspections
  of its assets but may not have documented the assessments or labeled the inspections as 
  "condition assessments."
  
  OIG Reply.  The FWS Manual requires field managers to document the condition of
  their facilities, and as such, FWS has established the need for documentary support for its
  evaluation of maintenance needs. However, FWS did not have sufficient documentation
  to show that any type of inspection, assessment, or review had been conducted  to
  determine the condition of its assets and the estimated cost to repair the assets.  Although
  not referred to in the report, the General Accounting Office's "Standards for Internal
  Control in the Federal Government" requires Federal agencies to clearly document "all
  transactions and other significant events" and states that "the documentation should be
  readily available for examination."  Thus, we do not believe that we are making FWS
  adhere to a standard higher than it and the General Accounting Office have established.