Western National Forests: Nearby Communities Are Increasingly Threatened By Catastrophic Wildfires

Published by the Government Accountability Office on 1999-02-09.

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

                          United States General Accounting Office

GAO                       Testimony
                          Before the Subcommittee on Forests and
                          Forest Health, Committee on Resources,
                          House of Representatives

For release on Delivery
Expected at
2:00 p.m., EST
                          WESTERN NATIONAL
February 9, 1999          FORESTS

                          Nearby Communities Are
                          Increasingly Threatened by
                          Catastrophic Wildfires
                          Statement of Barry T. Hill,
                          Associate Director,
                          Energy, Resources, and Science Issues,
                          Resources, Community, and Economic
                          Development Division

    Madame Chairman and Members of the Subcommittee:

    We are here today to discuss the results of our work to date for you on the
    wildfire hazards faced by communities located adjacent to national forests
    in the dry, inland portion of the western United States (hereafter referred
    to as the “interior West”). About 60 percent of all national forests
    managed by the Department of Agriculture’s Forest Service are located in
    this region of the country, which generally extends north and south from
    the Canadian to the Mexican borders and east and west from the Black
    Hills in South Dakota to the Cascade mountain range in Washington and
    Oregon, the Coastal range in California, and the southwestern deserts.
    (See app. I.)

    Historically, the tree stands in many forests of this region developed
    distinctive characteristics in response to frequent low-intensity fires and a
    lack of rainfall, which slows the decomposition of dead and downed trees.
    However, human activities over the last century and a half have
    introduced changes in the structure and composition of these tree stands.
    These changes have raised concerns about the resulting potential for more
    large, intense wildfires on national forests and about the threats that they
    may pose.

    My testimony today presents our observations to date on (1) the extent
    and seriousness of threats posed by national forest wildfires to nearby
    communities in the interior West, (2) agency efforts to address them, and
    (3) barriers to successfully implementing these efforts. Our work draws on
    visits over the last year and a half to several Forest Service field locations,
    as well as interviews with and review of data provided by, agency and
    outside experts. We will complete our work and issue a report to you on
    this, as well as wildfire threats to national forest resources, in the spring of
    this year.

    In summary, Madame Chairman, the information that we have gathered to
    date suggests the following:

•   During this century, two major changes have occurred in the national
    forests of the interior West. First, the Forest Service’s decades-old policy
    of putting out fires in the national forests has resulted in increased
    undergrowth and density of trees creating high levels of fuels for
    catastrophic wildfires. (See appendixes III and IV.) This has transformed
    as many as 39 million acres of the interior West’s national forests into a
    tinderbox. Second, the number of people living along the boundaries of

    Page 1                                                         GAO/T-RCED-99-79
                             national forests has grown significantly. As a result, the increasing number
                             of large wildfires, and of acres burned by them, pose increasingly grave
                             risks to human health, safety, property, and infrastructure in these areas
                             which are commonly referred to as “wildland/urban interface” areas.
                         •   During the 1990s, the Forest Service began to address this problem by
                             (1) establishing an objective of increasing the number of acres on which
                             excessive fuel levels are reduced, (2) announcing a priority for such
                             reductions in wildland/urban interface areas, (3) restructuring its budget
                             to better ensure that funds are available for such reductions, and
                             (4) proposing demonstration projects to test innovative approaches for
                             reducing fuels. The Congress has supported these efforts by increasing
                             funding for fuels reduction, authorizing demonstration projects, and
                             authorizing a multi-year research program to better assess problems and
                             solutions. However, these efforts are in a race against time and may fall
                         •   These efforts may fall short because the Forest Service lacks a cohesive
                             strategy for overcoming several barriers to effectively and efficiently
                             reducing fuels on national forests. These barriers include (1) potential
                             conflicts between fuel reduction efforts and other agency stewardship
                             responsibilities, including protecting air quality, watersheds, and wildlife
                             habitat; (2) program incentives that tend to focus efforts on areas that may
                             not represent the highest fire hazards; (3) agency contracting procedures
                             that are not designed for removing large amounts of materials with little or
                             no commercial value; and (4) the high costs of such removals, which may
                             be as much as several hundred million dollars annually.

                             The most common type of forested lands in the national forests of the
Catastrophic Wildfires       interior West are at warm, dry, lower elevations and are generally
on National Forests          dominated by ponderosa pine. These are known as “frequent fire interval”
Increasingly Threaten        forests because, before pioneers settled in these areas, fire historically
                             occurred in them about every 5 to 30 years. (See app. II.) Because frequent
Nearby Communities           fires kept these forests clear of undergrowth, fuels seldom accumulated
                             and the fires were generally of low intensity, largely consuming grasses
                             and undergrowth and not igniting the highly combustible crowns, or tops,
                             of large trees. However, various human activities, but primarily the
                             decades-old policy of suppressing fire in the national forests, have
                             generally prevented fire from playing its historical role of limiting the
                             forests’ density and clearing undergrowth and downed material.

                             Without frequent fires, vegetation has accumulated, many tree stands have
                             become denser, and less fire tolerant tree species have become more

                             Page 2                                                      GAO/T-RCED-99-79
prevalent. (See apps. III and IV.) In these currently denser stands in the
national forests of the interior West, many smaller dead and dying trees
now form fuel “ladders” that conduct fire into the crowns of larger trees.
Under these conditions, large, intense, and catastrophic wildfires have
become increasingly numerous. For example, over the last decade, the
number of acres of national forest lands burned by wildfires, more than 90
percent of which were in the interior West, has increased, reversing the
trend of the previous three-quarters of a century. (See app. V.) Moreover,
since 1984, the average number of fires annually on national forests that
burn 1,000 acres or more has increased from 25 to 80, and the total number
of acres burned (including nearby lands) by these fires has more than
quadrupled, from 164,000 to 765,000. (See app. VI.) Since 1990, 91 percent
of these large fires and 96 percent of the acres burned by them were in the
interior West. According to the Forest Service, 39 million acres on national
forests are now at high risk of catastrophic wildfire, and virtually all of
these lands are located in the lower-elevation, frequent-fire forests of the
interior West that are dominated by ponderosa pine. (See app. VII.)

In recent years, the number of people living along the boundaries of the
national forests has grown rapidly. (See app. VIII.) As a result, the
increasing numbers of larger, more intense fires pose grave hazards to
human health, safety, property, and infrastructure. Not only have lives
been lost, but because smoke from such fires contains substantial
amounts of fine particulate matter and other hazardous pollutants, the
fires can pose substantial health risks to people living in this
wildland/urban interface. Catastrophic wildfires threaten not only human
health, lives, and property, but also infrastructure vital to nearby
communities. For example, the 1996 Buffalo Creek fire, which burned
several thousand acres and threatened private property in the
wildland/urban interface southwest of Denver, left forest soils subject to
extreme erosion. Subsequent repeated rainstorms washed what ordinarily
would have been several years’ worth of sediment into a reservoir that
supplies Denver with water. As a result, the Denver Water Board has
estimated that it will incur several million dollars of ongoing expenses for
dredging the reservoir and treating water—an amount that is several times
the cost of fighting the fire.

Finally, the growing number of large wildfires and acres burned—coupled
with the increasing complexity of fire suppression in the wildland/urban
interface—has greatly increased the costs of suppressing fires. From fiscal
year 1986 through fiscal year 1994, the 10-year rolling average of annual
costs for fighting fires grew from $134 million to $335 million, or by 150

Page 3                                                      GAO/T-RCED-99-79
                        percent, in constant 1994 dollars. (See app. IX.) Since 1990, 95 percent of
                        these costs were incurred in the interior West. Moreover, the costs
                        associated with preparedness, including the costs of keeping equipment
                        and personnel ready to fight fires, are also increasing. For the 6 fiscal
                        years from 1992 through 1997, these costs increased from $189 million to
                        $326 million, or by 72 percent.1 (See app. X.)

                        In recent years, the Forest Service has taken steps to address the
The Forest Service Is   increasing threat of catastrophic wildfires on national forests. In 1995, it
Attempting to Address   announced its intention to refocus its fire management program on
Wildfire Threats        reducing accumulated fuels. Specifically, a 1995 internal agency report
                        recommended increasing the number of acres on which accumulated fuels
                        are reduced annually from about 570,000 to about 3 million by fiscal year
                        2005.2 In 1997, the Chief of the Forest Service said the agency intended to
                        implement this recommendation and that the agency planned to continue
                        reducing fuels on 3 million-acres per year through fiscal year 2015. By that
                        time, the agency believes that it will have adequately resolved the problem
                        of national forest lands being at high risk of uncontrollable, highly
                        destructive wildfires.

                        To implement its increased emphasis on reducing accumulated fuels, the
                        Forest Service restructured and redefined its fiscal year 1998 budget for
                        wildland fire management to better ensure that funds are available for
                        these activities.3 In fiscal year 1998, it announced that the funds
                        appropriated for reducing fuels would be allocated to emphasize
                        protecting communities at high-risk in wildland/urban interface areas. The
                        agency has also (1) revised its wildland fire management policy to more
                        clearly spell out its responsibilities and reimbursable costs so that
                        nonfederal parties can understand the consequences of not working with
                        the agency to reduce the risk of wildfire on their adjacent lands and
                        (2) proposed a number of pilot projects in collaboration with willing
                        nonfederal partners to demonstrate the role of mechanical methods
                        (including timber harvesting) of removing materials to reduce
                        accumulated fuels.

                         Federal Lands: Information About Land Management Agencies’ Wildfire Preparedness Activities
                        (GAO/RCED-98-48R, Dec. 18, 1997) and Federal Lands: Wildfire Preparedness and Suppression
                        Expenditures for Fiscal Years 1993 Through 1997 (GAO/T-RCED-98-247, Aug. 4, 1998).
                         Course to the Future: Positioning Fire and Aviation Management, U.S. Department of Agriculture,
                        Forest Service (Washington, D.C., 1995).
                        FY 1998 Budget Explanatory Notes for the Committee on Appropriations, U.S. Department of
                        Agriculture, Forest Service (Feb. 1997).

                        Page 4                                                                         GAO/T-RCED-99-79
The Congress has supported the Forest Service’s efforts to reduce
accumulated fuels by, among other things, increasing the funding for these
activities in recent years. In addition, in acting on the agency’s fiscal year
1998 budget, the House and Senate appropriations committees approved a
restructuring of the Forest Service’s budget to better ensure that funds are
available for reducing accumulated fuels. The committees also earmarked
$8 million in fiscal year 1998 for the agency and the Department of the
Interior to begin a multiyear program, called the Joint Fire Science
Program, to gather consistent information on accumulated fuels, methods
of reducing them, the potential effects on other resources of these
different methods, and their relative cost-effectiveness. The agencies
currently lack adequate data in all of these areas and, in January 1998, the
agencies issued a plan for conducting this research program.4 Moreover, as
requested by the Forest Service, the Congress also authorized, in the
agency’s fiscal year 1999 appropriations act, demonstration projects for
reducing accumulated fuels.

Many experts believe that these efforts by the Forest Service and the
Congress are in a race against time. A 1993 assessment of forest health in
the interior West, published in 1994, concluded that only a “brief window
of opportunity” of perhaps 15 to 30 years exists for management
intervention before damage from uncontrollable wildfires becomes
widespread, setting the stage for a repeat of the current problems far into
the 21st century.5 More than five of those years have already passed.
Furthermore, the Forest Service’s current plans may significantly
underestimate the number of acres on which fuels must be reduced
annually to adequately reduce fire hazards. Specifically, the agency’s
current and planned allocations of appropriated fuels reduction funding
largely emphasize maintaining satisfactory conditions on lands in other
regions of the country which currently have low levels of accumulated
fuels so that conditions on these lands do not also become hazardous.
Because maintaining current satisfactory conditions on these lands will
require continued fuels reduction on about 1 million acres per year, only
about two-thirds of the planned 3 million acre per year annual national
fuels reduction effort will take place each year in the interior West, where
virtually all of the most serious problems are located. As a result, as many
as 10 million acres in the interior West may still have excessive fuel levels
and may remain at risk of uncontrollable, catastrophic wildfire at the end
of fiscal year 2015.

 Joint Fire Science Plan, Department of the Interior and U.S. Department of Agriculture, Forest Service
(Washington, D.C., 1998).
 Assessing Forest Ecosystem Health in the Inland West, Forest Policy Center (Washington D.C., 1994).

Page 5                                                                           GAO/T-RCED-99-79
                        The Forest Service, however, may be able to substantially reduce fire
                        hazards without reducing fuels on all 39 million acres currently at high risk
                        of catastrophic fire. For example, it may be able to construct
                        fuelbreaks—i.e., areas where excessive fuels have been removed—in
                        strategic locations to isolate areas with excessive fuels and thus limit the
                        spread of large fires. However, the Forest Service has not yet developed a
                        strategy for constructing fuelbreaks or implementing any alternative
                        strategy to accomplish the same purpose. Thus, until the agency develops
                        such a strategy, it will not have a basis for eliminating any current
                        high-risk areas from its fuels reduction efforts or for assuring the Congress
                        and the public that hazards to nearby communities will be adequately

                        Several significant barriers must be overcome in developing a cohesive
The Agency Lacks a      strategy to reduce wildfire hazards on the national forests of the interior
Cohesive Strategy for   West. The first of these barriers is that methods for reducing accumulated
Overcoming Several      fuels can sometimes be difficult to reconcile with other legislatively
                        mandated stewardship objectives, including meeting clean air and water
Barriers to Reducing    quality standards and protecting threatened and endangered species. For
Accumulated Fuels       instance, many agency and outside experts believe that, ultimately,
                        avoiding catastrophic wildfires and restoring forest health in the interior
                        West will require reintroducing fire through burning under controlled
                        conditions to reduce fuels. However, winter snows limit the time available
                        for burning, and dry summer weather creates a high risk that, given the
                        massive levels of accumulated fuels, controlled fires will escape and
                        become uncontrollable, catastrophic wildfires. Moreover, several officials
                        and experts we spoke with believe that emissions from controlled fires on
                        the scale needed to adequately reduced accumulated fuels would violate
                        federal air quality standards under the Clean Air Act and that the act
                        would thus not permit the desired level of burning either immediately or
                        possibly even in the long term. The Forest Service and the Environmental
                        Protection Agency, which administers the Clean Air Act, are currently
                        conducting a 3-year experiment to better determine the impact of
                        emissions from controlled fires.

                        For these reasons, many experts agree that fuels must be reduced in most
                        areas of the interior West, at least initially, by mechanical means, including
                        commercial timber harvesting, in conjunction with controlled burning. The
                        Forest Service currently uses its timber sales management program to

                        Page 6                                                       GAO/T-RCED-99-79
reduce accumulated fuels.6 However, the use of timber harvesting to
reduce fuels has been limited by concerns about its adverse effects on
other stewardship objectives, including wildlife habitat and watershed
conditions. Specifically, in fiscal year 1997, timber harvesting was used to
reduce fuels on only about 95,000 acres, or less than 5 percent of the acres
that are projected to need fuel reduction annually to achieve the agency’s
long-term goal. Forest Service officials told us that it was not likely that
commercial timber harvesting could be increased enough to adequately
reduce fuels on the vast amount of acreage needing such reductions.

A second significant barrier that must be overcome in developing a
cohesive strategy is that both the timber sales management program and
the fuels reduction program funded by appropriations currently contain
incentives which tend to focus efforts on areas that may not present the
greatest fire hazards. For example, under its fuel reduction program, the
Forest Service’s lone performance indicator measures the number of acres
treated. Agency field staff told us that funding for forests often depends on
their ability to contribute to the agency’s annual acreage target. As a result,
in order to reduce fuels on more acres, they often focus treatments on
areas where the costs of reducing fuels are low, rather than on areas with
the highest fire hazards, including especially wildland/urban interface
areas. These areas often have significantly higher per-acre fuel reduction
costs because greater care must be taken to avoid fire and smoke hazards
of controlled burning, raising costs.

Additionally, while timber harvesting may make useful contributions to
reducing accumulated fuels in many circumstances, reducing fuels with
the funds allocated for timber sales management also results in an
incentive for forests to focus on less critical areas. The Forest Service
stresses that its timber sales management program is increasingly being
used for efforts to improve forest health, including efforts to prevent
catastrophic fires.7 However, the agency continues to rely on timber
production to fund many of its programs and activities, and all three of its
budget allocation criteria for timber activities relate solely to the volume
of timber produced or offered. As a result, as forest officials told us, they
tend to focus on areas with high-value commercial timber rather than on
areas with high fire hazards.

FY 1999 Budget Explanatory Notes for the Committee on Appropriations, U.S. Department of
Agriculture, Forest Service (Feb. 1998).
National Summary: Forest Management Program Report for Fiscal Year1997, U.S. Department of
Agriculture, Forest Service, FS-627 (July 1998).

Page 7                                                                      GAO/T-RCED-99-79
A third barrier is that the Forest Service’s contracting procedures do not
facilitate the removal of the large volumes of low-value material as is
necessary to reduce accumulated fuels. Most of the trees that need to be
removed to reduce accumulated fuels are small in diameter and have little
or no commercial value. For example, to return experimental forest plots
near Flagstaff, Arizona to historical conditions, 37 tons per acre of
nonmarketable materials had to be disposed of by placing them in a pit
and burning them. However, the agency’s contracting procedures for
commercial timber sales—as well as for service contracts that do not
involve selling timber but are let simply for the service of removing excess
fuels—were not designed to (1) facilitate the systematic removal of large
volumes of low-value material over a number of years, (2) readily combine
funds for conducting timber sales with funds for reducing accumulated
fuels, or (3) allow contractors to retain this low-value material to partially
offset the costs of its removal. In 1998, for instance, Agriculture’s Office of
General Counsel determined that only 6 of 23 contracting demonstration
projects proposed by the Forest Service to demonstrate the role of timber
harvesting in reducing accumulated fuels could proceed under the
agency’s existing statutory authority. This was because remaining projects
would have involved removing more material of minor commercial value
than is allowed under service contracts or letting contractors keep some
material in exchange for removing it. In the fiscal year 1999 Omnibus
Consolidated Appropriations Act, the Congress authorized the Forest
Service, through fiscal year 2002, to enter into 28 individual project
contracts under which (1) the value of the material removed may be used
by the contractor to offset the costs of removal, and (2) there is no
limitation on the value of the material to be removed. However, more
general authority temporarily granted to the agency in the early 1990s to
enter into “land stewardship contracts”—under which contractors were
allowed to retain material they removed in exchange for achieving desired
conditions in the national forests—has not been renewed.8

The fourth barrier that must be overcome in developing a cohesive
strategy for undertaking effective fuel reduction efforts is their high cost.
Revenue generated by the sale of many excess fuel materials will not cover
the costs of their removal. Agency officials and outside analysts agree that
reducing accumulated fuels in the interior West may require hundreds of
millions of dollars a year in appropriated funds. Our preliminary analysis
of the Forest Service’s fuels reduction costs—which, according to the

  See Forest Service Timber Sale Practices and Procedures: Analysis of Alternative Systems,
Congressional Research Service (95-1077 ENR, Washington, D.C., 1995) and M. Mitsos, Improving
Administrative Flexibility and Efficiency in the National Forest Timber Sale Program: Scoping Session
Summary, Pinchot Institute (Washington, D.C., 1996).

Page 8                                                                          GAO/T-RCED-99-79
agency’s data, average about $320 per acre for the combination of burning
and mechanical removal that is necessary in the interior West—indicates
that as much as $12 billion, or about $725 million a year, may be needed to
treat the 39 million acres at high risk of uncontrollable wildfire by the end
of fiscal year 2015. These costs might be less if the agency reduced current
hazards on the 39 million acres selectively, in accordance with a strategy
or set of priorities. Currently, however, the agency is planning to spend
only $65 million for fiscal year 1999 to reduce accumulated fuels—or less
than one-tenth of the annual level that may be needed to accomplish the
agency’s goal—and it has not developed an identifiable strategy or
priorities for applying these funds, nor has it even identified the interface
areas that are at high risk.

In conclusion, Madame Chairman, the increasing number of
uncontrollable and often catastrophic wildfires in the interior West, as
well as the significant costs to resolve the problem of increasing hazards
to human health, safety, property, and infrastructure present difficult
policy decisions for the Forest Service and the Congress: Does the agency
request, and does the Congress appropriate, the hundreds of millions of
dollars a year that may be required to fund an aggressive fuel reduction
program? If enough funding is not appropriated, what priorities should be
established? How can the need for reintroducing fire into frequent fire
forests and conducting mechanical removals best be reconciled with the
requirement to maintain air quality standards and fulfill other stewardship
objectives? What changes in incentives and contracting procedures are
needed to facilitate the mechanical removal of low-value materials?

Such decisions should be based on a sound strategy. However, the Forest
Service has not yet developed a cohesive strategy for addressing several
difficult barriers to improving the health of the national forests by
reducing fuels. Developing a strategy will depend in large part on data
being gathered under the Forest Service and Interior’s Joint Fire Science
Program which, as noted earlier, are directed at correcting these
deficiencies. However, a Forest Service official involved in implementing
the program told us that the agency may need a decade to complete many
of the research projects under the program. It may also take another
decade or longer to revise or amend forest plans to incorporate the
program’s findings and begin implementing individual fuels reduction
activities. Many experts argue that the tinderbox that is now the interior
West cannot wait that long. They also believe that inaction—or simply
allowing nature to take its inevitable course—will cost more not only in
funds for fire suppression but also in lives and damage to human health,

Page 9                                                       GAO/T-RCED-99-79
property, and infrastructure than would undertaking strategic actions

Madam Chairman, this concludes our prepared statement. We will be
pleased to respond to any questions that you or Members of the
Subcommittee may have.

Page 10                                                   GAO/T-RCED-99-79
Page 11   GAO/T-RCED-99-79
Appendix I

The Interior West


               Source: Forest Service.

               Page 12                   GAO/T-RCED-99-79
Appendix II

Location of Frequent Fire Forests in the
Interior West

               Source: Forest Service.

               Page 13                   GAO/T-RCED-99-79
Appendix III

1909 Photograph of Typical Open Ponderosa
Pine Stand in the Bitterroot National Forest
in Idaho

               Source: Forest Service.

               Page 14                   GAO/T-RCED-99-79
Appendix IV

1989 Photograph Taken From the Same Spot
in the Bitterroot National Forest in the Same

               Source: Forest Service.

               Page 15                   GAO/T-RCED-99-79
Appendix V

Number of National Forest Acres Burned by
Fire, 1910-97








              1935                1955                         1975                         1995
                                  Fiscal year

                     Notes: 1. The number of acres represents the 10-year rolling average at each point.

                     2. Since 1990, 90 percent of national forest acres burned by fire were in the interior West.

                     Source: GAO’s presentation of data from the Forest Service.

                     Page 16                                                                           GAO/T-RCED-99-79
Appendix VI

Number of and Total Acres Burned by Large
Wildfires on All National Forests, 1984-95

Fires                                                                                                        Acres
100                                                                                                      1,000,000

 80                                                                                                      800,000

 60                                                                                                      600,000

 40                                                                                                      400,000

 20                                                                                                      200,000

  0                                                                                                      0
      '84     '85   '86   '87   '88     '89     '90         '91       '92       '93      '94       '95
                                        Fiscal year

                                            Fires Acres

                                      Note: Since 1990, 91 percent of large fires, >1000 acres, and 96 percent of the acres burned
                                      were in the interior West.

                                      Source: GAO’s presentation of latest data available from the Forest Service.

                                      Page 17                                                                        GAO/T-RCED-99-79
Appendix VII

National Forest Lands at Medium and High
Risk of Catastrophic Fire

          Medium Risk

          High Risk

                        Source: American Forests.

                        Page 18                     GAO/T-RCED-99-79
Appendix VIII

Population Growth in Relation to National
Forests (1980-96)

                                 National forests
                                 Counties in interior west with above average population growth (>25%)

                Source: GAO’s presentation of data from the Forest Service and the Bureau of the Census.

                Page 19                                                                        GAO/T-RCED-99-79
Appendix IX

Forest Service’s Expenditures for Fire
Fighting, Fiscal Years 1986-94

Dollars in millions





      1986     1987   1988   1989       1990            1991          1992          1993           1994
                                     Fiscal year

                               Notes: 1. The expenditures for each year represent the 10-year rolling average expressed in 1994

                               2. Since 1990, 95 percent of these expenditures have been in the interior West.

                               Source: GAO’s presentation of latest data available from the Forest Service.

                               Page 20                                                                           GAO/T-RCED-99-79
Appendix X

Forest Service’s Expenditures for Wildfire
Preparedness, Fiscal Years 1992-97

Dollars in millions








      1992            1993   1994                  1995                   1996                    1997
                                    Fiscal year

                             Note: For 1994, the last year figures by region were available, over 90 percent of these
                             expenditures were in the interior West.

                             Source: GAO.

(141070)                     Page 21                                                                         GAO/T-RCED-99-79
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