Regulatory Reform: Comments on S. 981--The Regulatory Improvement Act of 1997

Published by the Government Accountability Office on 1997-09-12.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                        United States General Accounting Office

GAO                     Testimony
                        Before the Committee on Governmental Affairs
                        U.S. Senate

Not to Be Released
Before 9:00 a.m. EDT
                        REGULATORY REFORM
September 12, 1997

                        Comments on S. 981—
                        The Regulatory
                        Improvement Act of 1997
                        Statement of L. Nye Stevens
                        Director, Federal Management and Workforce Issues
                        General Government Division


Regulatory Reform: Comments on S. 981—
the Regulatory Improvement Act of 1997

                    Mr. Chairman and Members of the Committee:

                    I am pleased to be here today to assist in your consideration of S. 981, the
                    “Regulatory Improvement Act of 1997.” The bill thoughtfully addresses
                    many issues in regulatory management that have long been the subject of
                    controversy. We have issued reports and have ongoing assignments on a
                    number of those issues, including peer review, cost-benefit analysis,
                    reviews of existing regulations, and the transparency of the regulatory
                    process. My statement discusses our findings in these areas.

                    S. 981 represents a continuation of efforts that have been made by both the
                    legislative and executive branches to improve the rulemaking process and,
                    as a result, produce better regulations. During the past 20 years, Congress
                    has enacted a series of statutory requirements intended to, among other
                    things, reduce paperwork, lessen regulatory burden on small entities, and
                    curb mandates imposed on state, local, and tribal governments and the
                    private sector.1 In the same vein, each of the last six presidents has issued
                    executive orders or taken other actions intended to improve the regulatory
                    process. Executive Order 12866, issued in September 1993, is the Clinton
                    administration’s statement of policy on regulatory planning and review.
                    The executive order makes the Office of Management and Budget (OMB)
                    responsible for carrying out regulatory reviews and, to the extent
                    permitted by law, for providing guidance to agencies.

                    S. 981 addresses many of the same issues as Executive Order 12866,
                    including cost-benefit analysis, agency reviews of existing regulations,
                    interagency coordination, and transparency in the regulatory review
                    process. The bill goes beyond the order’s requirements on these issues and
                    adds some new elements to the rulemaking process.

                    As I will discuss in more detail, our work indicates that some of the
                    executive order’s requirements have not always been met. Enactment of S.
                    981 would help ensure that the underlying purposes of the order’s
                    requirements are more consistently achieved by OMB and regulatory
                    agencies and provide a sound basis for congressional oversight of
                    regulatory management issues.

                    One part of S. 981 involves public disclosure or “transparency”
Public Disclosure   requirements. Specifically, section 643(b) requires agencies to include in

                     These include the Paperwork Reduction Acts of 1980 and 1995, the Regulatory Flexibility Act of 1980,
                    the Unfunded Mandates Reform Act, and the Small Business Regulatory Enforcement Fairness Act.

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the Regulatory Improvement Act of 1997

the rulemaking record before publication of any proposed or final rule a
document clearly identifying the changes made to the draft submitted to
OMB’s Office of Information and Regulatory Affairs (OIRA), including and
separately identifying the changes made at the suggestion or
recommendation of OIRA. These requirements are intended to permit the
public to understand the source of changes to proposed rules, and are very
similar to requirements in section 6 of the executive order. However,
whereas the bill requires that the changes be recorded in a single
document in the rulemaking record, the order does not specify how
agencies must identify the changes for the public.

Mr. Chairman, at your and Senator Glenn’s request, we have been
reviewing the implementation of these executive order provisions at four
major regulatory agencies—the Departments of Housing and Urban
Development (HUD) and Transportation (DOT), the Department of Labor’s
Occupational Safety and Health Administration (OSHA), and the
Environmental Protection Agency (EPA). Of the 129 regulatory actions that
we reviewed in those agencies, fewer than 25 percent had a clear and
simple document in the rulemaking docket illustrating the changes made
to the rules while at OIRA for review or the changes made at OIRA’s
recommendation. Where we found documentation, it was either a
“redline/strikeout” version of the rule showing the changes made, a memo
to the file listing the changes, or a memo certifying that there were no such
changes. While some dockets for the other rules had indications of
changes made during OIRA’s review and by OIRA, it was not clear that all
changes had been recorded. Most commonly, however, the rulemaking
dockets simply had no information on whether changes had been made to
the rules. In those cases it was impossible for us to know whether changes
had not been made to the rules, or whether documentation of the changes
was missing.

In some cases the agencies had clear documents that delineated the
changes made to their rules while at or by OIRA, but those documents were
not available to the public. For example, the U.S. Coast Guard (USCG) in
DOT often prepared detailed summaries of these kinds of changes, but USCG
officials said that these summaries were internal communications that
were not available to the public. OSHA had comprehensive documentation
of their interactions with OIRA, but the information was maintained in files
separate from the public docket. OSHA officials said that they would make
this information available to the public upon request. However, in order
for individuals to request the information they must first know that the
documents exist.

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Also, the dockets varied in the degree to which they could be used by the
public to find the information required by the executive order. First, it is
important to realize that the docket for a single rule can be extremely
voluminous. For example, the docket for one of the rules we reviewed at
DOT’s Federal Railroad Administration (FRA) contained 17 folders of
material, some of which were nearly a foot thick. However, the docket for
this rule and all of the others that we examined at FRA, HUD, and some
other agencies had no indexes. Therefore, the public would have to review
the entire docket to find any documentation of changes made at the
suggestion of OIRA or changes in the draft submitted to OIRA. In contrast,
the Office of Air and Radiation’s docket at EPA had a consistently
structured index for all its rules, with specific sections in which
information related to OIRA’s reviews could be found. At the time of our
review, the Office of the Secretary of DOT was automating its dockets so
that both indexes and eventually the entire rule making record could be
accessed on-line.

In testimony last September before this Committee, the OIRA
Administrator, acknowledged that agencies had not “been scrupulously
attentive” to the executive order’s requirement that they document the
changes made at OIRA’s suggestion or recommendation. She also said,
however, that the executive order had “created a more open and
accountable review process” and that she had heard “no complaints about
accountability and transparency.”

We believe that these public disclosure requirements in the executive
order, combined with the administration’s assertion of their effectiveness,
have resulted in a public perception that changes made to a regulation
while at OIRA and by OIRA are readily identifiable. However, our review
indicated that this was usually not the case.

Enactment of the public disclosure requirements in S. 981 would provide a
statutory foundation for the public’s right to regulatory review
information. In particular, we believe that the bill’s requirement that these
rule changes be described in a single document would make
understanding regulatory changes much easier for the public.

Whether or not a statute is enacted, OIRA could provide the agencies with
guidance on how to improve the transparency of the regulatory review
process. OIRA could point to existing “best practices” in how to both
document changes made while rules are under review by OIRA or at the

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                  Regulatory Reform: Comments on S. 981—
                  the Regulatory Improvement Act of 1997

                  suggestion of OIRA, and how agencies could organize their dockets to best
                  facilitate public access and disclosure.

                  We have also done work relevant to Subchapter III of S. 981, which
Review of Rules   requires agencies to review existing rules identified by an advisory
                  committee representing a balanced cross section of public and private
                  interests. The agencies must then decide whether to retain, amend, or
                  repeal the rules it reviews. There have been several previous requirements
                  by both Congress and previous presidents that federal agencies review
                  their existing regulations.2

                  Most recently, section 5 of Executive Order 12866 required agencies to
                  submit a program to OIRA by December 31, 1993, under which they would
                  periodically review their existing significant regulations to determine
                  whether any should be modified or eliminated. According to the order, the
                  purpose of the review was to make the agencies’ regulatory programs
                  more effective, less burdensome, or better aligned with the President’s
                  priorities and the principles in the order. On June 12, 1995, the President
                  announced that a page-by-page review of the CFR had resulted in
                  commitments to eliminate 16,000 pages from the 140,000 page CFR and
                  modify another 31,000 pages either through administrative or legislative

                  Last year we testified before this Committee that most of the
                  administration’s efforts to eliminate pages from the CFR did not appear to
                  reduce substantive regulatory burden.3 Most of these actions were being
                  taken to eliminate obsolete regulations, many of which did not appear to
                  have been enforced for some time. As for the effort to revise the
                  regulations, we could not determine whether burden was likely to be
                  reduced as a result of most of the revisions because the agencies’
                  descriptions of those actions were vague. At the same hearing, the
                  Administrator of OIRA testified that she had not expected the page
                  elimination effort to reduce burden. However, she said that “the real

                   For example, in 1979, President Carter issued Executive Order 12044 (“Improving Government
                  Regulations”), which required agencies to review their existing rules “periodically.” The Regulatory
                  Flexibility Act of 1980 required agencies to publish in the Federal Register a plan for the periodic
                  review of rules that “have or will have a significant economic impact upon a substantial number of
                  small entities.” In 1992, President Bush sent a memorandum to all federal departments and agencies
                  calling for a 90-day moratorium on new proposed or final rules during which agencies were “to
                  evaluate existing regulations and programs and to identify and accelerate action on initiatives that will
                  eliminate an unnecessary regulatory burden or otherwise promote economic growth.”
                   Regulatory Reform: Implementation of the Regulatory Review Executive Order (GAO/T-GGD-96-185,
                  Sept. 25, 1996.)

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    savings, the reduction of burden,” would come from the CFR pages that
    were being revised.

    Mr. Chairman, at your request we have been further examining the
    administration’s page elimination and revision effort. We found that the
    four agencies that we reviewed (HUD, DOT, OSHA, and EPA) were adding
    pages to the CFR at the same time that pages were being deleted. As a
    result, although the four agencies reported to OMB that they eliminated
    5,500 pages from the CFR during this initiative, as of April 30 of this year
    the agencies’ net reduction in CFR pages when page additions are taken
    into consideration was about 900 pages. Two of the four agencies’ CFR
    parts actually grew during their page elimination effort—DOT by about 300
    pages and EPA by nearly 1,000 pages. The four agencies pointed out that
    pages are often added to the CFR because of statutory requirements or to
    clarify requirements placed on regulated entities, and that pages are
    sometimes retained at the request of those entities.

    Our review of 422 CFR revision efforts in the 4 agencies indicated that
    about 40 percent should reduce the burden felt by regulated entities, and
    another 15 percent should make regulations easier to find or to
    understand. For example,

•   one EPA action that appeared to reduce regulatory burden involved
    changing the frequency with which states must submit information related
    to state water quality standards under section 303(d) of the Clean Water
    Act from every 2 years to every 5 years. Lessening the frequency with
    which this information must be submitted should reduce the paperwork
    burden imposed on the states.
•   one OSHA action that appeared to be a minor burden reduction proposed to
    “eliminate the complexity, duplicative nature, and obsolescence” of
    certain standards and “write them in plain language.”

    However, about 8 percent of the actions appeared to increase the burden
    felt by those being regulated, and another 27 percent did not appear to
    affect regulatory burden at all. For example,

•   OSHA proposed revising its general industry safety standard for training
    powered industrial truck operators and to add equivalent training
    requirements for the maritime industries. OSHA estimated that the first year
    cost of compliance with the proposed standard would be $34.9 million,
    with annual costs thereafter of $19.4 million.

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                          Regulatory Reform: Comments on S. 981—
                          the Regulatory Improvement Act of 1997

                      •   one DOT action that did not appear to affect regulatory burden proposed
                          amending the Transportation Acquisition Regulations to change
                          organizational names and renumber and rename certain sections of the

                          We could not determine what effect about 9 percent of the actions would
                          have on regulatory burden, either because the information available
                          describing the actions contained elements of both burden reduction and
                          burden increase that could be offsetting or because the information was

                          We recognize that directly measuring changes in regulatory burden is
                          extremely difficult. However, we also believe that the administration’s
                          chosen metric of pages in the CFR that are eliminated or revised is a poor
                          proxy for changes in regulatory burden. Eliminating or changing hundreds
                          of pages that are obsolete or rarely enforced can have little practical effect
                          on regulatory burden, whereas slight changes in wording of a single
                          sentence can have a tremendous effect.

                          Enactment of the review requirements in S. 981 would provide a statutory
                          basis for periodic examinations of existing rules. We believe that such
                          examinations are a good idea in that they can determine the continued
                          relevance of regulatory requirements and help ensure that the
                          requirements impose as little burden as possible. Identification of rules for
                          review by the advisory committee that would be established by the bill
                          may lead to more substantive changes than have heretofore been made by
                          the agencies on their own.

                          Although both S. 981 and Executive Order 12866 require agencies to
Regulatory Analysis       conduct cost-benefit analyses for major rules and to make the results
                          available to the public, the bill goes farther than the order in requiring
                          disclosure of how those analyses are conducted. For example, one of the
                          bill’s “findings” states that cost-benefit analyses and risk assessments
                          “should be presented with a clear statement of the analytical assumptions
                          and uncertainties including an explanation of what is known and not
                          known and what the implications of alternative assumptions might be.”
                          Section 623 of the bill requires agencies to include an executive summary
                          of the regulatory analyses, including the benefits and costs of reasonable
                          alternatives and “the key assumptions and scientific or economic
                          information upon which the agency relied.”

                          Page 6                                                  GAO/T-GGD/RCED-97-250
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In January 1996, OMB issued guidance to executive agencies on preparing
the economic analyses called for in Executive Order 12866. Although the
OMB guidance provided agencies with substantial flexibility in how such
analyses should be conducted, the guidance sounded some of the same
themes as S. 981.

“Analysis of the risks, benefits, and costs associated with regulation must be guided by the
principles of full disclosure and transparency. Data, models, inferences, and assumptions
should be identified and evaluated explicitly, together with adequate justifications of
choices made, and assessments of the effects of these choices on the analysis. The
existence of plausible alternative models or assumptions, and their implications, should be

Our previous work examining agencies’ cost-benefit analyses indicated
that the studies are often not as transparent as either the bill or the OMB
guidance contemplates. For example, in our report earlier this year on
EPA’s analyses that support air quality regulations, we found that certain
key economic assumptions—such as discount rates and assumed values of
human life—were often not identified.4 Even in those cases in which the
assumptions were identified, the reasons for the values used were not
always explained. For example, one analysis assumed a value of life that
ranged from $1.6 million to $8.5 million while another—prepared in the
same year—assumed a value of life that ranged from $3 million to
$12 million. In neither case did the analyses clearly explain why the values
were used. We also found that about one-quarter of the analyses that we
reviewed examined only one alternative—the regulatory action being

S. 981’s call for executive summaries in the cost-benefit analyses echoes a
recommendation we made 13 years ago. In a 1984 report, we
recommended that EPA’s cost-benefit analyses include executive
summaries that identify (1) all benefits and costs—even those that cannot
be quantified; (2) the range of uncertainties associated with the benefits
and costs; and (3) a comparison of feasible alternatives.5 However, about
one-half of the 23 EPA analyses supporting air quality regulations that we
reviewed last year did not have executive summaries.

 Air Pollution: Information Contained in EPA’s Regulatory Impact Analyses Can Be Made Clearer
(GAO/RCED-97-38, April 14, 1997). A discount rate used in these analyses represents the interest rate
used to determine the present value of future benefits and costs.
 Cost-Benefit Analysis Can Be Useful in Assessing Environmental Regulations, Despite Limitations
(GAO/RCED-84-62, Apr. 6, 1984).

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Mr. Chairman, at your and Senator Glenn’s request we are currently
evaluating executive agencies’ preparation and use of regulatory analyses.
Although our work to date has focused primarily on EPA and DOT, we are
finding some significant variations both between and within the two
agencies’ analyses and their presentation of these key components. For
example, the base-case discount rates used in the 11 analyses we have
reviewed ranged from 2.1 to 7 percent. The reasons for the rate chosen
were frequently not explained nor were the implications of using
alternative rates discussed in the analyses. As a result, agency
decisionmakers, Congress, and the public may not be aware that the
results of these analyses could have been significantly different if different
assumptions had been used.

In several of the analyses we reviewed, various key components were
either missing altogether, difficult to find, or located in documents other
than the analyses themselves. Some of the analyses consisted of several
separate documents that were never consolidated in a clear manner. For
example, agency officials told us that one of the economic analyses was
actually 12 separate memoranda.

We are also finding that many of the analyses are actually
cost-effectiveness studies rather than cost-benefit analyses.
Cost-effectiveness analyses generally look for ways to meet a given goal at
the least cost, while cost-benefit analyses usually involve a systematic
identification of all costs and benefits associated with the proposed
regulation and alternative approaches. Although cost-effectiveness
analyses permit comparison of the costs of regulatory options relative to a
given objective, these analyses generally do not address the merits of the
objective itself. Agency officials explained that they often prepare
cost-effectiveness analyses in cases where Congress has mandated the
development of specific regulations—such as new emission standards for
locomotives. According to the officials, in such cases it makes more sense
to look for the most cost-effective approach to achieve that result rather
than assessing all of the benefits and costs of alternative approaches.

In some cases, despite relatively specific statutory mandates that even
prohibit the agency from considering costs in developing regulations, the
agency determined that a more systematic cost-benefit analysis was
warranted. For example, even though the Clean Air Act, as interpreted by
the courts, prohibits EPA from considering costs in promulgating National
Ambient Air Quality Standards (NAAQS), the agency prepared fairly
comprehensive cost-benefit analyses for its recent proposed and final

Page 8                                                  GAO/T-GGD/RCED-97-250
Regulatory Reform: Comments on S. 981—
the Regulatory Improvement Act of 1997

ozone and particulate matter standards. According to the agency, the more
systematic cost-benefit analyses will aid EPA and the states when the
standards are implemented—at which time costs can be considered. In
addition, the more systematic analyses provide important information to
the Congress and the public on the likely costs and benefits of mandates
where the agencies are limited in their regulatory decisions.

Our findings are similar to those of others who have recently examined
cost-benefit studies. In its March 1997 report on economic analyses, the
Congressional Budget Office concluded that there is no such thing as a
typical analysis, and that even determining what constitutes an economic
analysis is difficult.6 In its July 1997 draft report on governmentwide costs
and benefits, OMB said that it found “a wide variety in the type, form, and
format” of the information generated and used by the agencies, including
“enormous data gaps in the information available on regulatory benefits
and costs,” problems with establishing baselines, and a lack of consensus
on how to value items or qualities not generally traded in the marketplace.7
 OMB concluded that “we need to ensure that the quality of data and
analysis used by the agencies improves, [and] that standardized
assumptions and methodologies are applied more uniformly across
regulatory programs and agencies...” A diverse panel of renowned
economists made a similar recommendation in a 1996 paper prepared
under the auspices of the American Enterprise Institute, the Annapolis
Center, and Resources for the Future.8 Among other things, the panel
recommended that agencies present their results using a standard format
that summarizes the key results and highlights major uncertainties.

Enactment of the analytical transparency and executive summary
requirements in S. 981 would extend and underscore Congress’ previous
statutory requirements that agencies identify how regulatory decisions are
made. We believe that Congress and the public have a right to know what
alternatives the agencies considered and what assumptions they made in
deciding how to regulate. Although those assumptions may legitimately
vary from one analysis to another, the agencies should explain those

Regulatory Impact Analysis: Costs at Selected Agencies and Implications for the Legislative Process,
Congressional Budget Office, Mar. 1997.
 Draft Report to Congress on the Costs and Benefits of Federal Regulations, OMB, July 22, 1997. See 62
Fed. Reg. 39352 (1997).
Benefit-Cost Analysis in Environmental, Health, and Safety Regulation: A Statement of Principles,
Arrow, Cropper, et. al., 1996.

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              Regulatory Reform: Comments on S. 981—
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              S. 981 also requires agencies to provide for peer review of all required
Peer Review   cost-benefit analyses and risk assessments. Peer review is the critical
              evaluation of scientific technical work products by independent experts.
              The bill states that the peer review panels should be “broadly
              representative and balanced,” and that the results of the reviews should be
              made available to the public.

              We believe that important economic analyses should be peer reviewed. In
              response to questions raised at a March 1997 hearing on peer review at
              EPA, we said that, given the uncertainties associated with predicting the
              future economic impacts of various regulatory alternatives, the rigorous,
              independent review of economic analyses should help enhance the
              products’—and the associated agency decisions’—quality, credibility, and

              However, in our 1996 review of peer review at EPA, whose own policies
              and procedures call for such reviews, we concluded that implementation
              of these policies and procedures had been uneven.10 In some cases
              important aspects of the agency’s peer review policy were not followed or
              peer review was not conducted at all. Our current work examining
              regulatory analyses at executive branch agencies is yielding similar
              evidence. None of the nine EPA analyses that we have reviewed thus far
              have been peer reviewed, even though all of the associated rules have an
              estimated annual impact on the economy of at least $100 million.

              Some agency officials acknowledged that although peer review could
              enhance the quality and credibility of some economic analyses, statutory
              or court-imposed time constraints limit their ability to conduct them. In a
              recent article co-authored by EPA’s Associate Assistant Administrator for
              Policy, Planning, and Evaluation (currently a visiting scholar at Resources
              for the Future), the authors stressed the importance of conducting
              economic analyses in a more open manner, involving outside experts and
              stakeholders. They also suggested that, time constraints notwithstanding,

               The previously mentioned panel of noted economists also concluded that peer review of economic
              analyses should be used for regulations with potentially large economic impacts and recommended
              that the reviewers be selected on the basis of their demonstrated expertise and reputation. The
              importance of peer review of key economic documents was also raised in a recent report by The
              Presidential/Congressional Commission on Risk Assessment and Risk Management. The Commission
              found that the quality and interpretation of economic analyses did not receive enough attention by
              agencies and recommended that they receive adequate peer review.
                  Peer Review: EPA’s Implementation Remains Uneven (GAO/RCED-96-236, Sept. 24, 1996).

              Page 10                                                                GAO/T-GGD/RCED-97-250
              Regulatory Reform: Comments on S. 981—
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              this could be done more often if economic analyses were initiated at the
              beginning of the rulemaking process.11

              The peer review requirements in S. 981 provide agencies with substantial
              flexibility. Agency heads may certify that adequate peer review has already
              been conducted, and avoid the bill’s requirements. However, agencies will
              need to carefully plan for such reviews given the bill’s requirement that
              they be done for each cost-benefit analysis and risk assessment, which
              must be done at both proposed and final rulemaking. Agencies will also
              need to ensure that all affected parties are represented on the panels and
              that panel reports reflect the diversity of opinions that exist.

              Mr. Chairman, our work has demonstrated that, although there is broad
              consensus about the value of conducting peer reviews of cost-benefit
              analyses used in the regulatory process, such reviews are often not done.
              In our view, systematic peer review as mandated by S. 981 would go a long
              way toward improving the quality of agencies’ cost-benefit analyses.

              S. 981 contains a number of provisions to improve regulatory
Conclusions   management. Requiring agencies to clearly describe in a single document
              changes made at the suggestion of OIRA or while under OIRA review can
              improve the transparency of the review process. Establishing advisory
              committees to identify rules for review could result in the elimination or
              revision of burdensome requirements. Improving the transparency and
              understandability of cost-benefit analyses by using executive summaries
              and other devices will help the public comprehend why regulatory
              decisions are made. Peer reviews of those analyses can help ensure that
              regulatory proposals are scientifically grounded. Although other
              provisions in the bill, such as comparative risk assessment and
              interagency coordination, may have similarly beneficial results, we have
              not done specific work in those areas.

              Passage of S. 981 would provide a statutory foundation for such principles
              as openness, accountability, and sound science in rulemaking. The key to
              achieving those principles is successful implementation, which will require
              strong guidance from OIRA and oversight from this and other Committees
              in Congress. Enactment of S. 981 would provide a sound basis for that

               “Economic Analysis: Benefits, Costs, Implications” in Economic Analyses at EPA: Assessing
              Regulatory Impact, 1997.

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                  Mr. Chairman, this completes my prepared statement. I would be pleased
                  to answer any questions.

(410116/160388)   Page 12                                            GAO/T-GGD/RCED-97-250
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