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

Report No. 99-i-959

Title: Audit Report on Deferred Maintenance,  National Park Service



Date:  September 30, 1999




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U.S. Department of the Interior
Office of Inspector General


AUDIT REPORT
DEFERRED MAINTENANCE,
NATIONAL PARK SERVICE


REPORT NO. 99-I-959

SEPTEMBER 1999



                                                  E-IN-NPS-003-98
AUDIT REPORT

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, 
          National Park Service (No. 99-i-959)

INTRODUCTION

This audit report presents the results of our review of the
fiscal year 1998 deferred maintenance cost estimates prepared by
the National Park Service.  The initial objective of the audit
was to determine whether the (1) the Park Service's estimate of
deferred maintenance as reported in the note to its fiscal year
1998 financial statements was reasonable and (2) the note
included the minimum information required by Statement of Federal
Financial Accounting Standards No. 6, "Accounting for Property,
Plant and Equipment."  Because the Office of Management and
Budget determined, after initiation of our fieldwork, that
deferred maintenance cost estimates reported in agency fiscal
year 1998 financial statements were not subject to audit, we
revised our objective.  As revised, our objective was to
determine whether actions were needed to ensure that Park Service
deferred maintenance accounting and budgetary information was
current, complete, and verifiable.

BACKGROUND

According to the Park Service's Office of Facility Management,
the Park Service has about 16,000 permanent structures, 8,000
miles of roads, 1,500 bridges, 5,385 housing units, approximately
1,500 water and wastewater systems, 200 radio systems, more than
400 dams, and more than 200 solid waste operations.  The Park
Service said that these facilities include numerous cultural
historic buildings and structures, complex utility systems, and
an extensive network of roads and trails that must be maintained
at an operational level that ensures continued protection,
preservation, and serviceability.  The Park Service estimated
that, as of September 30, 1998, the total cost of deferred
maintenance for these assets ranged from $2.5 billion to $5
billion.

In November 1995, the Office of Management and Budget and the
General Accounting Office issued Statement of Federal Financial
Accounting Standards No. 6.   Chapter 3 of the Statement defined
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" and defined
maintenance as "the act of keeping fixed assets in acceptable
condition" and "activities needed to preserve the asset so that
it continues to provide acceptable services and achieves its
expected life."  Standard No. 6 imposed certain financial
reporting requirements on Federal agencies, including the
requirement that estimated deferred maintenance costs should be
disclosed in the agencies' financial statements "for fiscal years
beginning after September 30, 1997."   

In May 1998, the Assistant Secretary for Policy, Management and
Budget issued Department of the Interior deferred maintenance
guidance in Attachment G to the document "2000 Budget Request
Formulation." The guidance provided directions to the bureaus for
preparing 5-year maintenance and capital improvement plans,
complying with Standard No. 6, and reviewing facilities-related
information systems requirements.  The guidance directed the
bureaus to use the condition assessment method to identify their
deferred maintenance needs.  The guidance stated that condition
assessments are "a complete inventory of their constructed assets
[to] identify the cost of correcting the deferred maintenance
needs associated with those assets" and that condition
assessments should be conducted by "competent and qualified
personnel using uniform, comprehensive . . .  criteria."
Regarding the assessments, the guidance stated, "It is understood
that it will take a multi-year effort for the bureaus to
accomplish complete condition assessments on all of their
constructed assets."  The guidance also defined deferred
maintenance 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." 

The Departmental guidance also discussed the information systems
used to record maintenance information and described a
"continuing Department-wide facilities management improvement
effort" that would include a "review of maintenance data
requirements, systems, and applications."  The guidance further
stated that the bureaus did not have "consistent levels of
deferred maintenance data in their facility management systems";
that the maintenance systems were "of varying quality"; and that
deferred maintenance data systems "in some cases, need functional
improvement."  

In June 1998, the Park Service distributed the Departmental
guidance to all parks and attached the document "Servicewide
Project Call to Support the FY [fiscal year] 2000 Budget Request,
Including Identification of Projects to Support the Five-Year
Maintenance and Capital  Improvement Plan and Deferred
Maintenance Requirement."  This document required parks to submit
deferred maintenance estimates by July 15, 1998, and provided
guidance on the Project Management Information System (PMIS),
which is one of the automated systems that maintain data on the
Park Service's deferred maintenance needs.  On October 30, 1998,
the Park Service provided the Office of Inspector General
information on its fiscal year 1998 estimated deferred
maintenance costs ($3.6 billion), which it reported in four asset
categories: roads and bridges, employee housing, dams, and PMIS
projects.  The categories are described as follows:

-  The roads and bridges estimate was prepared by the Department
of Transportation's Federal Highway Administration, which
performs condition assessments for roads and bridges and
maintains documentation on the assessments.  

-  The employee housing estimate was prepared by the Park Service
using the Department of the Interior's quarters management
information system.  This system contains information from park
personnel on park housing conditions.  

-  The dams estimate was prepared by the Park Service from the
current inventory and from inspection reports that field
personnel had submitted to the dam safety officer.  

-  The PMIS estimate, according to the Park Service, contained
information on the Park Service's unfunded needs that were not
recorded in the other three categories. 

In January 1999, the Office of Management and Budget issued a
statement that agencies were required to report their fiscal year
1998 estimated deferred maintenance costs in their financial
statements but for that fiscal year, the estimates would not be
subject to audit.  The Park Service subsequently revised its
deferred maintenance estimate to between $2.5 billion and $5
billion.  

SCOPE OF AUDIT

We reviewed the Park Service's deferred maintenance cost estimate
for fiscal year 1998 as reported by the Park Service in October
1998.  We conducted the audit at the locations listed in Appendix
1.  To accomplish our objective, we reviewed applicable
Department of the Interior, Federal Accounting Standards Advisory
Board, and Park Service guidance, policies, and procedures;
planning and budget documents; PMIS reports; dam project
databases; information provided by the Federal Highway
Administration; and available condition description and cost
documentation for deferred maintenance projects reported by the
Park Service.  

Of the Park Service's fiscal year 1998 estimated deferred
maintenance cost of $3.6 billion, we reviewed costs of $185.5
million.  We selected for review a sample of 61 of the 4,183
deferred maintenance projects in the Park Service's PMIS
database, 20 of the 131 deferred maintenance projects in its
database on dams, and 61 of the 1,184 deferred maintenance
projects in its database on bridges.  We reviewed documentation
on roads and employee housing projects, but specific road and
housing projects with specific costs were not available for our
review.  Our review of the cost estimates is as follows:


-------------------------------------------------------
Original                           Deferred Maintenance
Asset Category            Amount              Estimated
Costs                      Reported            Reviewed
-------------------------------------------------------
Roads           $2,144,000,000  01
-------------------------------------------------------
Housing         114,000,000     02
-------------------------------------------------------
Dams             72,000,000                 $41,400,000
-------------------------------------------------------
Bridges          56,000,000                   8,400,000
-------------------------------------------------------
PMIS            $1,239,874,500              135,693,000
-------------------------------------------------------
Total  $3,625,874,500                     $ 185,493,000
-------------------------------------------------------
                                  _____________________
-------------------------------------------------------
1 The Park Service did not provide specific road
projects with project costs for review.
2 The Park Service did not provide specific housing
projects with project costs for review.
-------------------------------------------------------

Of the 61 PMIS projects reviewed, we statistically sampled 40
projects.   The remaining 21 projects were judgmentally sampled
because the projects were included in the Park Service's
Five-Year Plan or were significant projects and 18 of the 40
statistically sampled projects were in the Five-Year Plan.  Also,
we conducted interviews and obtained and analyzed documentation
from Park Service program personnel responsible for producing the
deferred maintenance cost estimates for housing and dams and from
Federal Highway Administration officials who produced the Park
Service's deferred maintenance cost estimates for roads and
bridges.  We also visited or contacted the parks listed in
Appendix 1 to review deferred maintenance projects and related
documentation.

Our review was made, as applicable, 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.  As part of the
audit, we evaluated the system of internal controls over the
development of the Park Service's estimated deferred maintenance
cost to the extent we considered necessary to accomplish the
objective.  We found internal control weaknesses in the Park
Service's preparation, review, and approval of deferred
maintenance estimates.  Our recommendations, if implemented,
should improve the internal controls in these areas.

In addition, we reviewed the Departmental Report on
Accountability for fiscal year 1998, which included information
required by the Federal Managers' Financial Integrity Act of
1982, and the Park Service's annual assurance statement on
management controls for fiscal year 1998.  We determined that
although the Park Service reported no weaknesses within the scope
of our review, the Department reported that inadequate
Departmentwide 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 has
issued three reports and the  General Accounting Office has
issued two reports regarding the Park Service's deferred
maintenance.  These reports are summarized in Appendix 2.

RESULTS OF AUDIT

We found that the National Park Service's deferred maintenance
cost estimates were not developed in accordance with Federal
accounting standards and Department of the Interior guidance and
thus the Park Service had little assurance that its deferred
maintenance accounting and budget data were current, complete,
and verifiable.  This condition occurred because the Park Service
did not (1) conduct all needed assessments to identify asset
conditions, (2) document its estimated deferred maintenance
costs, and (3) establish adequate controls to ensure compliance
with Federal and Departmental deferred maintenance guidance.  As
a result, the Park Service may not be able to meet Federal
financial accounting standards in future years, when deferred
maintenance data must be reliable for financial statements
reporting purposes, and it did not have reliable data to support
its fiscal year 2000 budget request for deferred maintenance
funding. 

Condition Assessments

The Department's fiscal year 2000 budget guidance required
bureaus to conduct condition assessments to identify their
deferred maintenance needs "to assure that the most critical
needs are being addressed with priority in the Plan [the
Department's 5-year maintenance and capital improvement plan]."
To achieve Departmentwide consistency in determining the physical
condition of assets, the guidance stated that a "uniform
methodology and a core data set" for condition assessments were
needed; the assessments should be conducted by "competent and
qualified personnel using uniform, comprehensive . . . criteria";
automated systems should be developed to "accurately document
facilities' needs"; system data should be capable of being
"easily reviewed and updated by field and regional staffs"; data
should be based on documentation that includes "standard need
descriptions and associated cost estimating procedures"; and
bureaus should establish a "cyclic/recurring condition assessment
process where on-site inspections are conducted at a minimum
every five years."

Despite the Departmental guidance, we found that the Park Service
had not fully conducted condition assessments or documented that
they had been completed.  Of the 61 PMIS projects reviewed, we
found that 30 were not supported with condition assessments, 12
of the 20 dam projects included in the Park Service's listing of
deferred maintenance projects were not supported with condition
assessments, and none of the housing projects or road projects
included in Park Service deferred maintenance project listings
were supported with condition assessments.  For example: 

- The PMIS included a deferred maintenance project at the
Petrified Forest National Park in Arizona that provided for the
replacement of a water line at an estimated cost of $6,166,000.
The Park, in its response to our questionnaire, stated that a
"formal condition assessment was not completed for this project." 

- The PMIS included a deferred maintenance project for the George
Washington Memorial Parkway in Virginia that provided for the
rehabilitation of the Parkway at an estimated cost of
$85,516,000.  The Park Service, however, had no detailed
information on the locations at which maintenance was needed or
documentation on the current conditions of the Parkway, although
it provided a 10-year old engineering study of the Parkway as
support for this project (with an estimated rehabilitation cost
of $95 million).  Park Service officials said that some of the
work included in that study had been completed but could not
identify the completed work or the work that needed to be done.
According to Park Service officials, the Park Service will base
its estimated cost of this project on data received through the
roads and bridges inventory program that is conducted by
professional engineers at the Department of Transportation's
Federal Highway Administration, and the project will not be
included in future PMIS project listings.

- The PMIS included deferred maintenance projects to rehabilitate
84 campsites at  Sequoia and Kings Canyon National Parks in
California at an estimated cost of $472,500.  During our site
visit to the parks, park personnel stated that there was no
documented condition assessments of the work needed at the
campgrounds.  

For its fiscal year 1998 deferred maintenance estimate, the Park
Service had not developed a condition assessment program to
systematically evaluate its capital assets to determine its
project repair, renewal, or replacement needs.  The Park Service
also had not established a standard set of criteria for
evaluating asset condition, and the quality and content of its
assessments varied considerably from park to park.  For example,
some deferred maintenance projects were documented with
engineering studies and detailed industry-accepted cost
estimates, while other projects had informal or no documented
condition assessments.

Deferred Maintenance Cost Estimates

The Park Service did not always document the method used or the
basis for its deferred maintenance estimates.  As a result, we
could not determine whether the estimates were current or
complete or were based on reliable cost data.  About 50 percent
of the PMIS projects reviewed (31 of 61 projects reviewed, with
estimated costs totaling $116,571,190) were not supported with
cost estimates that included detailed labor, materials, and
overhead estimates; information on the sources for cost data; or
the method used to develop the cost estimates.  In addition, of
the 20 dams projects included in the Park Service's deferred
maintenance listing, we found that 17 projects, with estimated
costs totaling $41,400,000, were not supported with cost
estimates that could be verified. 

We found that the Park Service had not documented its cost
estimates because (1) park personnel were not given sufficient
time to compile the estimates and (2) it had not issued detailed
guidance on how to document the estimates.  Specifically, the
Park Service Director  issued guidance on deferred maintenance
cost estimates to park managers in a June 10, 1998, memorandum,
which stated that "all projects meeting these three requirements
[fee demonstration projects, 5-year maintenance and capital
improvement plan projects, and deferred maintenance projects] be
identified and entered by July 15, 1998."  No additional
implementing guidance on computing or documenting cost estimates
was issued, such as guidance on whether or which direct or
indirect costs should be included in the estimates and what types
of supporting documentation were needed.  Park managers stated
that the memorandum was not issued in sufficient time to develop
cost estimates because the months of June and July were their
highest visitation periods and they did not have the resources to
meet the requirement in such a short period of time.

Also, according to the Park Service, the reliability of the cost
estimates was related to the availability of engineering,
architectural, and maintenance staff in the parks.  Specifically,
Park Service officials said that parks with personnel in these
specialties prepared more detailed and verifiable estimates than
parks without these personnel.  We found that 22 of the 30
supported cost estimates in the PMIS were prepared by Park
Service resident engineers/ architects, by architectural and
engineering firms, or by the Federal Highway Administration.

Because the Park Service did not always prepare reliable cost
estimates or document the estimated costs of its deferred
maintenance projects, it did not have adequate support for all
projects for which funding was requested.  For example, 35 of our
sample items were for projects that the Park Service had included
in its 5-year budget submission to the Congress.  We found that
the cost estimates for 19 of these projects (total cost of
$8,775,800) could not be verified because documentation was
insufficient or was not provided to support these estimates.

Compliance Controls

The Park Service did not implement sufficient controls to ensure
that its estimated deferred maintenance costs were determined in
accordance with Federal accounting standards or Departmental and
Park Service guidance.  Specifically, controls were not
implemented to ensure that deferred maintenance estimates were
complete and accurate and that projects met the definition of
deferred maintenance.  For example, in its estimate for dams, the
Park Service included deferred maintenance only for those dams
that were considered to be the most seriously deficient in terms
of maintenance.  According to the Park Service's dam safety
officer, the estimate did not include all dams that were in need
of deferred maintenance.  In addition, Park Service officials at
the Western and National Capital Regions stated that deferred
maintenance projects of about $200 million submitted by field
personnel were not included in the estimate because the officials
had insufficient time to review the projects.  

The Park Service also did not ensure that project costs were not
duplicated.  For example, the park superintendent at Cumberland
Island National Seashore in Georgia stated that he had entered
into PMIS a deferred maintenance project for the rehabilitation
of multiple park buildings and that he had also entered separate
projects for components of this rehabilitation project.  The park
superintendent said that he had made these duplicate entries to
increase the chances of receiving funding for the project.

The Park Service also included projects in its deferred
maintenance estimate that did not meet the definition of deferred
maintenance as stated in Standard No. 6 or Departmental and Park
Service guidance.  For example:

- At Minuteman National Historic Park in Massachusetts, the Park
Service included, as a deferred maintenance  project, the
replacement of a septic system at an estimated cost of $147,800.
The Park's Chief of Maintenance said that the system had
exhausted its useful life, and the project description for this
project indicated that the new system would be a  significant
upgrade.  Because both Standard No. 6 and Departmental guidance
define deferred maintenance as maintenance performed during the
"expected life" of an asset and exclude projects that
significantly upgrade or expand an asset's use, we believe that
this project should not have been included in the deferred
maintenance listing.   

- At Indiana Dunes National Lakeshore, the Park Service included
an estimate of $75,000 for a deferred maintenance project that
involved the removal of storage tanks which are not used by the
Service and that presented an environmental hazard.  This
project, in our opinion, does not meet the standard for deferred
maintenance because the work does not preserve the asset so that
it continues to provide acceptable services and achieve its
expected life.

We also found that the Park Service did not have controls to
ensure that deferred maintenance cost estimates were accurate.
For example, a spreadsheet from the Federal Highway
Administration's Federal Lands Highway Office reportedly
contained summary information on the Park Service's road and
bridge deferred maintenance projects.  From the spreadsheet, we
selected for review 61 bridge repair projects at eight parks.
These projects had a total estimated cost of $8,400,00.  Based on
a review of detailed condition assessments from the Federal
Highway Administration's Eastern Federal Lands Highway Division
(the organization  responsible for preparing the condition
assessments of the bridges), we found that there were 70 bridges,
which had estimated deferred maintenance costs totaling
$3,125,300, at the eight parks.  Thus, for these items, the Park
Service's deferred maintenance costs, which were based on Federal
Highway Administration estimates, were overstated by about $5.2
million.  The Federal Highway Administration stated that for
fiscal year 2000, it would validate deferred maintenance data on
its roads and bridges to ensure that the data were reliable.

Need for Deferred Maintenance Data

We believe that the Park Service needs reliable deferred
maintenance data to ensure that it (1) can comply with financial
statements reporting requirements for future years, (2) can
support budget requests for deferred maintenance project funding
submitted to the Congress, and (3) has the information necessary
to prioritize and properly manage its projects.  The General
Accounting Office stated in its March 1999 report "Recreation
Fees Demonstration Has Increased Revenues, but Impact on Park
Service Backlog is Uncertain" (No. GAO/T-RCED-99-101) that the
Park Service had not developed accurate and reliable information
on its total deferred maintenance needs.  The report also stated
that "given the substantial increase in funding that the Park
Service will receive under the demonstration fee program, now
more than ever the agency will have to be accountable for
demonstrating its accomplishments in improving the maintenance of
. . . facilities with these [the fee demonstration program]
additional resources."  The report added that the Park Service
"will need to develop more accurate and reliable information on
its deferred maintenance needs and to track progress in
addressing them." 

Park Service Efforts

Park Service officials stated that actions are planned to provide
more comprehensive condition assessments in future years.  For
example, according to Park Service officials, "The Park Service
has since developed and tested methodology and procedures for
conducting condition assessments on employee housing units.  A
standard set of criteria has also been established and tested on
two prototype park housing condition assessment reviews.  It is
anticipated that these methods and criteria will be further
developed for use on all National Park Service assets."
Regarding funding, the Park Service, in its budget request for
fiscal year 2000, requested $2.5 million to "initiate a
multi-year inventory and condition assessment [program] totaling
$25 million."  Also, in addition to its appropriated funds, the
Park Service has other funding that may be used for deferred
maintenance.  For example, in its fiscal year 2000 budget
request, the Park Service stated that "funding to address
maintenance needs as well as enhanced resource management and
improved visitor services will also be available from the
Recreation Fee Demonstration Program [which the Park Service
estimated would generate fees of $137.3 million]." Moreover,
according to the Park Service,  the  Federal Highway
Administration  will  provide the  Park Service  funding of $165
million for road and bridge construction and maintenance in
fiscal year 2000.

Recommendations

We recommend that the Director, National Park Service:

1.  Establish a plan for the timely completion of condition
assessments on all Park Service assets subject to deferred
maintenance reporting.  The plan should establish a standard set
of criteria for evaluating asset condition and require that
documentation on the assessments be maintained. 

2.  Require qualified Park Service personnel to prepare
documentation to support deferred maintenance cost estimates
which includes details on the material, labor, and overhead costs
needed to complete the projects; the bases for these costs; and
the methodology used in arriving at the cost estimates.

3.  Establish a review and approval process which will ensure
that all deferred maintenance estimates are complete, accurate,
and current and do not contain duplicate projects.

National Park Service Response and Office of Inspector General
Reply

In the September 16, 1999, response (Appendix 2) to the draft
report from the Director, National Park Service, the Park Service
concurred with the report's three recommendations. However,
specific information on actions taken or planned, including
target dates and titles of the officials responsible for
implementation, was not provided (see Appendix 4).

In its response, the Park Service said that it was taking and
planned to take actions to improve the reliability of its
deferred maintenance data.  For example, the Park Service said
that its data collection and analysis process has improved with
"built-in quality checks to ensure roll-ups are anchored to and
based on the raw data collected at the actual road segment or
bridge."  Further, the Park Service said that the Federal Highway
Administration is completing a review "to validate the quality of
the collected data and the cost multipliers used to develop the
costs at the project level." The Park Service also made general
and specific comments on the report, which we considered and
incorporated into the report as appropriate.  The Park Service's
comments and our replies to these comments are in the paragraphs
that follow.  

National Park Service Comment.   The Park Service said that the
"tone" of the report "tends to make it sound like the National
Park Service has been reporting deferred maintenance for a number
of years and is just not getting it right."  The Park Service
said  that the report should "provide more emphasis on the fact
that completion of condition assessments on the Service's
constructed assets will be a long-term effort" because of the
extensive size of the Park Service's facility inventory.

Office of Inspector General Reply.   The report stated that the
audit reviewed the deferred maintenance cost estimate prepared by
the Park Service for fiscal year 1998.  We also said that Federal
agencies were first required to prepare deferred maintenance cost
estimates for their fiscal year 1998 financial statements and
that the requirement for an audit of the estimate was deferred
until fiscal year 1999.   As such, we did not state or imply that
the Park Service had prepared unreliable deferred maintenance
cost estimates for financial statement reporting purposes "for a
number of years."  However, we did cite General Accounting Office
and Office of Inspector General audit reports issued during the
past 5 years (see Appendix 2) in which auditors stated that the
Park Service had not prepared or maintained reliable deferred
maintenance data that were needed for budgeting and operational
purposes.  Regarding the Park Service's request that we emphasize
that condition assessments are a "long-term effort," we believe
that our report, in describing the actions needed to improve the
reliability of deferred maintenance data, recognizes that the
condition assessment and cost estimation process involves
considerable effort (see page 9).

National Park Service Comment.   The Park Service said that we
were "incorrect" in our statement that "`park personnel were not
given sufficient time to compile estimates.'"  The Park Service
also said, "Where this information [deferred maintenance data]
resides in electronic format, it was imported into the PMIS
database, thereby minimizing the efforts of park personnel."

Office of Inspector General Reply.   Our comments on the
timeliness of preparing deferred maintenance data were unrelated
to the efficiency with which the Park Service recorded or entered
information in its databases.  Rather, our discussion of
timeliness was based on comments made by personnel at the parks
visited who said that they did not have sufficient time to
compile detailed estimates because they were asked to provide the
data during the summer months, a time during which visitation to
the parks is high and staff in general are unavailable to perform
additional duties. 

National Park Service Comment.  The Park Service recommended that
the report define "an acceptable cost estimate" and the
"reliability of cost estimates."

Office of Inspector General Reply.  Although Standard No. 6 and
Departmental guidance do not define an acceptable cost estimate
or the reliability of cost estimates, we used the following
standard in evaluating cost estimates and data reliability: (1)
the estimate was prepared by a technically competent staff
member, (2) documentation was prepared and retained to show the
basis or method used to estimate deferred maintenance costs, and
(3) documentation was prepared and retained to show that a
condition assessment had been performed. 

National Park Service Comment.  The Park Service stated that we
were "incorrect" in our statement that the Park Service "`did not
ensure that project costs were not duplicated.'"  It further said
that "a limited number of duplicate projects were missed."

Office of Inspector General Reply.  Our report did not discuss
the "limited number" of projects that may have been "missed"
during a review of items in each of the Park Service's databases.
Rather, we discussed duplicate entries that were intentionally
made so that projects would more likely receive funding (based on
the statement of a Park Service official who made the duplicate
entries) and those that were made because the projects were
inadvertently included in more than one database (for example, in
PMIS and in the roads databases).  To detect these types of
duplicate entries, the Park Service needs to perform more than a
cursory review of its deferred maintenance data.

In accordance with the Departmental Manual (360 DM 5.3), we are
requesting a written response to this report by October 29, 1999.
The response should include the information requested in Appendix
4.

Section 5(a) of the Inspector General Act (Public Law 95-542), as
amended) requires the Office of Inspector General to list this
report in its semiannual report to the Congress.

We appreciate the assistance of Park Service personnel in the
conduct of our audit.


APPENDIX 1
Page 1 of 2

LOCATIONS VISITED OR CONTACTED

BUREAU                                   LOCATION 

National Park Service

Park Operations and Education,
Facilities Management Washington, D.C.

Parks:
George Washington Memorial Parkway       McLean, Virginia
Chesapeake and Ohio Canal National Historical Park 
Sharpsburg, Maryland
Harpers Ferry National Historical Park   Harpers Ferry,
West Virginia
Shenandoah National Park                 Luray, Virginia
Blue Ridge Parkway                       Asheville, North
Carolina
Cumberland Island National Seashore      Saint Marys, Georgia
Indiana Dunes National Lakeshore         Porter, Indiana
Cuyahoga Valley National Recreation Area Brecksville, Ohio
Gateway National Recreation Area         Brooklyn, New York
Boston National Historical Park          Boston, Massachusetts
Minute Man National Historical Park      Concord, Massachusetts
Golden Gate National Recreation Area     San Francisco,
California
Point Reyes National Seashore            Point Reyes, California
Sequoia and Kings Canyon National Parks  Three Rivers, California
Biscayne National Park*                  Homestead, Florida
Death Valley National Park*              Death Valley, California
Lincoln Home National Historic Site*     Springfield, Illinois
White Sands National Monument*           Holloman Air Force Base,
New Mexico
Yellowstone National Park*               Yellowstone, Wyoming
Petrified Forest National Park*          Petrified Forest,
Arizona
Glen Canyon National Recreation Area*    Page, Arizona
Theodore Roosevelt National Park*        Medora, North Dakota
Dinosaur National Monument*              Dinosaur, Colorado
Lava Beds National Monument*             Tulelake, California
Lake Mead National Recreation Area*      Boulder City, Nevada
Denali National Park and Preserve*       Denali Park, Alaska
Grand Teton National Park*               Moose, Wyoming
Vicksburg National Military Park*        Vicksburg, Mississippi
Natchez National Historical Park*        Natchez, Mississippi
Sleeping Bear Dunes National Lakeshore*  Empire, Michigan
Ozark National Scenic Riverway*          Van Buren, Missouri
Wupatki National Monument*               Flagstaff, Arizona
Harry S. Truman National Historic Site*  Independence, Missouri
Joshua Tree National Park*               Twentynine Palms,
California
Hagerman Fossil Beds National Monument*  Hagerman, Idaho
Mount Rainier National Park*             Ashford, Washington

*Parks contacted but not visited.

APPENDIX 1
Page 2 of 2

Department of Transportation

Federal Highway Administration, Federal 
Lands Highway Office                    Washington, D.C.

Eastern Federal Lands Highway Division   Sterling, Virginia

APPENDIX 2
Page 1 of 2

PRIOR AUDIT COVERAGE

During the past 5 years, the Office of Inspector General has
issued three reports and the General Accounting Office has issued
two reports on the National Park Service's deferred maintenance.

The Office of Inspector General reports are as follows:

-  The audit 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" (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 the Department nor any of the bureaus could
adequately support deferred maintenance cost estimates,  which
were reported to total between $8.3 billion and $14.4 billion as
of September 30, 1998.

- The audit report "National Park Service Financial Statements
for Fiscal Years 1997 and 1998" (99-I-916), issued in September
1999, identified an internal control weakness considered to be a
reportable condition related to deferred maintenance.  The report
stated that formal policies and procedures for conducting
periodic condition assessments and computing deferred maintenance
funding estimates needed to be established to promote consistent
and reliable deferred maintenance data.

- The March 1998 audit report "Followup of Maintenance
Activities, National Park Service" (No. 98-I-344) addressed
several maintenance issues, including the Park Service's
discontinued use of its standardized maintenance management
system, which adversely impacted the Park Service's ability to
track and monitor deferred maintenance performance. The report
contained four recommendations, of which one was considered
resolved and  three were considered unresolved.  The unresolved
recommendation pertaining to the Park Service's reporting its
lack of a standardized maintenance management system as a
material weakness may be considered resolved as a result of the
Office of Policy, Management and Budget's decision to classify
the lack of standardized maintenance management systems as a
Departmentwide material weakness.

APPENDIX 2
Page 2 of 2

The General Accounting Office reports are as follows:

- The March 1999 report "Recreation Fees Demonstration Has
Increased Revenues, but Impact on Park Service Backlog is
Uncertain" (No. GAO/T-RCED-99-101) presented the testimony of the
General Accounting Office on the Park Service's Fee Demonstration
Program.  The report stated that the Program "appears to be
working well and meeting many of the law's intended objectives"
and that the Program will provide the Park Service with a 
"substantial increase in funding."  However, the report noted
that the Park Service needed "to develop more accurate and
reliable information on its deferred maintenance needs" and that
the Park Service "should be held accountable for demonstrating
its accomplishments in improving the maintenance of Park Service
facilities with [the Fee Demonstration Program funds]."

- The May 1998 report "National Park Service Efforts To Identify
and Manage the Maintenance Backlog" (No. GAO/RCED-98-143) stated
that the Park Service's most recent maintenance backlog cost
estimate did not accurately reflect the scope of the Park
Service's maintenance needs.    According to the  report,  $5.6
billion of the Park Service's  reported $6.1 billion maintenance
backlog was for construction projects, and $1.2 billion, or 21
percent, of the $5.6 billion was for expenditures "that expand or
upgrade park facilities" which "go beyond what could reasonably
be viewed as maintenance."  The report also stated that "the
absence of a common definition of what should be included in the
maintenance backlog contributed to an inaccurate and out-of-date
estimate" of the Park Service's maintenance needs.  The report
stated that to address its maintenance backlog, the Park Service
needed to develop more accurate estimates of its total
maintenance needs. 

APPENDIX 4

STATUS OF AUDIT REPORT RECOMMENDATIONS

Recommendations
Status
Actions Required

Management concurs; additional information needed.

1
Provide an action plan for the timely completion of condition
assessments and the establishment of a standard set of criteria
for evaluating asset condition.  The plan should  include the
target date and the title of the official responsible for
implementation.
2
Management concurs; additional information needed.
Provide an action plan on the issuance of a requirement that
documentation should be prepared to support deferred maintenance
cost estimates.  The plan should include the target date and the
title of the official responsible for implementation.
3
Management concurs; additional information needed.
Provide an action plan on the establishment of a review and
approval process for deferred maintenance data.  The plan should
include the target date and the title of the official responsible
for implementation.




ILLEGAL OR WASTEFUL ACTIVITIES SHOULD BE REPORTED

TO THE OFFICE OF INSPECTOR GENERAL BY:

Sending written documents to:



Within the Continental United States

U.S. Department of the Interior
Office of Inspector General
1849 C Street,N.W.
Mail Stop 5341
Washington, D.C. 20240

Calling:

Our 24 hour
Telephone HOTLINE
1-800-424-5081 or
(202) 208-5300

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1-800-354-0996



Outside the Continental United States


Caribbean Region

U.S. Department of the Interior
Office of Inspector General
Eastern Division- Investigations
1550 Wilson Boulevard
Suite 410
Arlington, Virginia 22209

Calling:
(703) 235-9221


North Pacific Region

U.S. Department of the Interior
Office of Inspector General
North Pacific Region
238 Archbishop F.C. F'lores Street
Suite 807, PDN Building
Agana, Guam 96910


Calling:
(700) 550-7428 or
COMM 9-011-671-472-7279