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Acquisition Reform: The Government's Market Research Efforts (Letter Report, 10/11/96, GAO/NSIAD-97-3).

Pursuant to a legislative requirement, GAO reviewed the government's use
of market research, focusing on its review of 21 contracts and the
awarding agencies' use of market research.

GAO found that: (1) prior to enactment of the Federal Acquisition
Streamlining Act of 1994 (FASA), the Department of Defense emphasized
the use of market research in its acquisition of commercial and
nondevelopmental items; (2) after FASA enactment, civilian agencies
increased their emphasis on market research; (3) dollar value, nature,
and industry and technology factors influence the extent of federal
market research efforts; (4) agencies' efforts to implement FASA include
improving training for acquisition personnel, compiling commercial terms
and conditions used in industry, and changing acquisition guidance; (5)
most agencies did not follow requirements to include in their
solicitation notices a note regarding a final check on the government's
market research efforts; (6) some agencies expressed concerns over the
use of the note, while others stated that they had overlooked it and
would emphasize the use of the note to contracting staff; (7) most
government and industry officials opposed the creation of a
governmentwide database for storing, retrieving, and analyzing market
data, citing an enormous funding and staff burden to maintain current
information; and (8) several federal initiatives are under way to use
the Internet to facilitate market research.

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

 REPORTNUM:  NSIAD-97-3
     TITLE:  Acquisition Reform: The Government's Market Research Efforts
      DATE:  10/11/96
   SUBJECT:  Federal procurement policies
             Advertised procurement
             Industry
             Marketing
             Procurement regulation
             Commercial products
             Data bases

             
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Cover
================================================================ COVER


Report to Congressional Committees

October 1996

ACQUISITION REFORM - THE
GOVERNMENT'S MARKET RESEARCH
EFFORTS

GAO/NSIAD-97-3

Acquisition Reform

(705114)


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

  CBD - Commerce Business Daily
  DOD - Department of Defense
  EPA - Environmental Protection Agency
  FAR - Federal Acquisition Regulation
  FASA - Federal Acquisition Steamlining Act of 1994
  GSA - General Services Administration
  NASA - National Aeronautics and Space Administration
  NDI - nondevelopmental item
  OFPP - Office of Federal Procurement Policy

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


B-272645

October 11, 1996

Congressional Committees

In accordance with section 8305 of the Federal Acquisition
Streamlining Act of 1994 (FASA, P.L.  103-355), we reviewed the
government's use of market research.  Market research is the process
used to collect and analyze data about capabilities in the market
that could satisfy an agency's procurement needs.  Specifically, we
were required to (1) review existing federal government market
research efforts regarding commercial items and nondevelopmental
items (NDI) and (2) review the feasibility of creating a
governmentwide database for storing, retrieving, and analyzing market
data.\1

For purposes of our review, the term "existing market research
efforts" includes (1) efforts/practices used for selected contracts
awarded during our review and for associated acquisition
requirements, which often occurred a year or more earlier and (2)
efforts/practices used to implement FASA requirements.  As such, the
term includes market research done both prior to and after the
regulations implementing FASA's market research requirements became
mandatory for use, December 1, 1995 (referred to as pre-FASA and
post-FASA practices, respectively).  To determine market research
efforts, we reviewed 21 contracts that were awarded by some of the
major federal buying agencies identified in the Federal Procurement
Data System.\2 These contracts are not intended to represent a
scientific sample.  For each contract, we also reviewed available
market research information on the acquisition requirements. 

We also obtained from government procurement officials and industry
procurement officials their views on the feasibility of creating a
governmentwide database for storing, retrieving, and analyzing market
data. 


--------------------
\1 FASA, section 8001 (a), and the Federal Acquisition Regulation
(FAR) define commercial items more broadly than this term had been
defined.  Also, the FAR defines NDI to include any previously
developed item of supply used exclusively for governmental purposes
by a federal agency, a state or local government, or a foreign
government with which the United States has a mutual defense
cooperation agreement.  Unlike FASA, the FAR does not specifically
include all commercial items as a subset of NDI.  (See app.  I for
the FAR definitions of commercial items and NDI.)

\2 The Federal Procurement Data System contains governmentwide data
on agencies' contract awards.  Each executive agency is required to
collect and report to this system selected data on contract awards
exceeding $25,000. 


   BACKGROUND
------------------------------------------------------------ Letter :1

Market research has been a statutory requirement for over 10 years,
since the passage of the Competition in Contracting Act of 1984,
which required the use of market research and procurement planning to
promote the use of competitive procedures in federal contracting. 
The FAR implemented those market research provisions and essentially
established market research as a tool for identifying (1) sources to
ensure competition and (2) commercial products to meet an agency's
needs.  Emphasis on the use of market research to identify commercial
items has evolved, however, since the 1984 act was enacted.  For
example, in November 1990, Congress reemphasized market research for
the Department of Defense (DOD) in the National Defense Authorization
Act for Fiscal Year 1991 (P.L.  101-510).  This act sought to
encourage DOD to save money and reduce acquisition cycle time by
buying products that were commercially available or had already been
developed. 

FASA, which was enacted on October 13, 1994, reiterated some existing
requirements and stipulated additional ones for market research for
all federal executive agencies.  It requires federal executive
agencies to conduct market research before developing new
specifications for a procurement and before soliciting bids or
proposals for a contract exceeding $100,000.  FASA also requires
agencies to use market research results to determine whether
commercial items/NDI could meet their needs if either the item or the
requirement were modified to some extent.  These provisions seek to
ensure that agencies' requirements definition and contracting
communities are involved in market research and that cost/performance
tradeoffs are evaluated up front to encourage the use of commercial
items or NDI. 

All FASA provisions were to apply no later than October 1, 1995.  The
officials responsible for incorporating FASA's market research
provisions into the FAR, however, made such revisions optional for
solicitations issued from October 1 through November 30, 1995, and
mandatory for solicitations issued on or after December 1, 1995.  The
officials explained that the 2-month delay allowed more time for
agency officials to be trained and familiarize themselves with the
changes in the regulations.  Such regulatory changes included (1) the
use of note 26 in Commerce Business Daily (CBD) preaward notices as a
final check on the government's market research effort\3 and (2) the
requirement to identify, via market research, customary commercial
practices regarding customizing, modifying, or tailoring of items to
meet customer needs and associated costs. 

The FAR lists some market research techniques, including (1)
contacting knowledgeable individuals in the government and industry
regarding market capabilities to meet the acquisition requirements,
(2) publishing formal requests for information in appropriate
technical journals or business publications, and (3) involving
potential offerors in interchange meetings or holding presolicitation
conferences early in the acquisition process. 


--------------------
\3 Note 26 provides that, based on market research results, the
government does not plan to solicit the described supplies or
services using the FAR's commercial item procedures.  As a
contracting officer's final check on the ability of the commercial
marketplace to respond, the note asks interested parties to identify,
within 15 days, their capability to fulfill the government's
requirement with a commercial item. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

Our review of 21 selected contracts and discussions with DOD and
civilian agency officials showed that the government's market
research efforts varied widely, but the variances appeared to be
appropriate.  For example, for pre-FASA efforts, DOD emphasized the
use of market research for commercial items and NDI more than the
civilian agencies did, primarily because of statutory requirements
that applied to DOD.  However, post-FASA, the civilian agencies we
visited have increased their emphasis on market research.  In
addition, the type and extent of market research varied for the 21
contracts we reviewed.  Overall, the agencies (1) obtained commercial
items or NDI in 16 of the 21 contracts, although for 3 of the 16,
market research was, for legitimate reasons, not performed and (2)
used market research to obtain government unique items or services in
5 of the 21 contracts. 

At the time of our review, implementation of FASA's market research
requirements was underway, but government and industry officials said
it would take well over a year after the December 1, 1995,
implementation date before the impact of the changes could be
realized.  For example, in our review of CBD notices published from
October 1995 to May 1996, we found that the final check on the
government's market research, which the FAR required, generally was
not being used.  Although officials at most of the activities we
contacted said they were not aware of the requirement and would send
out policy letters to increase compliance, the Director of Defense
Procurement and the General Services Administration's (GSA) Associate
Administrator for Acquisition Policy took issue with an
across-the-board application of the requirement.  They stated that
they would take actions to amend the FAR to exempt certain contracts
from this requirement. 

There is strong opposition to creating a governmentwide,
government-maintained database for storing, analyzing, and retrieving
market data.  Most government and industry officials said that such a
database would be too costly to maintain, be hard to keep current,
and provide few benefits.  They said using the tools available on the
Internet appears to be a more practical alternative.  For example,
some officials stated that powerful search engines are becoming
available on the Internet that will likely facilitate market research
of private sector and government electronic catalogs.  In addition,
interactive forums have been placed on the Internet, such as DOD's
newly developed Commercial Advocates Forum, that provide useful
market research tools and information.  Based on our discussions with
government and industry officials, and in light of new developments
on the Internet, we do not believe that federal agencies should be
required, at this time, to create a government-maintained database to
store, retrieve, and analyze market data. 


   EXISTING MARKET RESEARCH
   VARIED:  BENEFITS FROM FASA
   CHANGES EXPECTED LATER
------------------------------------------------------------ Letter :3

In general, existing market research efforts and practices relating
to commercial items and NDI varied greatly.  For example, we found
variances in the emphasis DOD and civilian agencies placed on
pre-FASA market research.  Additionally, our review of selected
acquisition requirements and contract awards showed variances in the
type and extent of existing market research practices, primarily due
to the circumstances surrounding the buy.  Such circumstances
included the dollar value; nature of the buy (whether it was a new or
recurring requirement); and the industry sector or pace of technology
changes for the item involved.  Variances were also apparent in the
use of the results of such research. 

Efforts to implement FASA's market research changes are underway. 
Government and industry officials stated, however, that it will
probably take well over a year after the December 1, 1995,
implementation of FASA in governmentwide regulations for significant
effects of these changes to be apparent.  For example, our review of
the use of CBD note 26--the government's final check on their market
research--showed that it is early in the implementation phase. 
Specifically, due to a lack of awareness of the FAR requirement,
federal agencies and procuring activities were generally not using
note 26. 


      DOD AND CIVILIAN AGENCIES'
      MARKET RESEARCH REQUIREMENTS
      AND GUIDANCE VARIED IN
      EMPHASIS
---------------------------------------------------------- Letter :3.1

DOD emphasized market research for commercial items and NDI more than
the civilian agency locations we visited.  Such emphasis is partly
due to additional statutory requirements related to commercial
items/NDI and associated market research that have applied to DOD for
several years--before FASA made them applicable governmentwide. 
These included the National Defense Authorization Act for Fiscal Year
1991
(P.L.  101-510).  Section 810 of this act required DOD to conduct
market research to determine whether an NDI, including a commercial
item, was available or could be modified to meet the agency's need
before developing a new specification for a developmental item. 

As a result of such statutory requirements, DOD, before FASA, had (1)
written guidance for its market research process; (2) conducted
market research training for specification writers and program
managers and their staffs (but not necessarily including contracting
officials); (3) established NDI advocates to promote the acquisition
of more commercial items and NDI through, among other things, the use
of market research; and (4) collected data to measure trends in the
procurement of such items. 

We did not find as much pre-FASA emphasis on market research within
the civilian agencies we visited as in DOD.  For example, most did
not have separate guidance for commercial/NDI market research, or
provide training to their acquisition officials that focused on
market research.\4 However, post-FASA, some of the civilian agencies
have written market research guidance, developed market research
training, and adopted many of DOD's procedures. 


--------------------
\4 The exception was the Federal Aviation Administration.  Pre-FASA,
it had provided DOD's NDI guidance, which includes a chapter on
market research, as part of its policy order on the use of NDI and,
according to agency officials, had provided some training to selected
managers and product teams.  They did not, however, collect data to
measure trends in the procurement of commercial items and NDI. 


      THE TYPE, EXTENT, AND USE OF
      MARKET RESEARCH VARIED
---------------------------------------------------------- Letter :3.2

Market research was performed for 18 of the 21 contracts we reviewed. 
The three contracts for which such research was not performed were
awarded under exceptions to full and open competition.\5 The market
research performed in the 18 remaining contracts varied, primarily
based on the complexity of the buy; its nature (whether the buy was
to fulfill a new or recurring requirement); the dollar value of the
buy; and the industry sector involved. 

For example, the Air Force Electronic Systems Center used a number of
market research techniques before finalizing the specification and
soliciting offers for one contract totaling $7.6 million.  This
contract is for a handheld thermal imager to assist security
personnel in assessing the cause of alarms emanating from intrusion
detection sensors deployed under the Tactical Automated Security
System.  Specifically, the Air Force tasked the Sandia National
Laboratory to conduct a market survey, which was completed in January
1992.  Also, the system program office performed an acquisition
requirements tradeoff study in 1993 before establishing the
requirement.  In addition, program officials regularly used industry
trade shows, DOD association meetings, and joint service briefings to
assess improvements in handheld thermal imagers.  They said that the
concentration of industry equipment demonstrations and technical
personnel at these meetings afforded ideal conditions to determine
the state of the art of thermal imagers and identify industry
research and development efforts to address this new operational
requirement.  Notices seeking sources for the thermal imagers were
published in the CBD in April and August 1995, and face-to-face
meetings were held with several of the vendors who responded to these
notices.  A solicitation was issued in September 1995 and a contract
was awarded in March 1996 for a modified commercial item. 

On the other hand, less complex market research was performed for a
new requirement that involved a simpler, lower dollar value
procurement.  Specifically, this Army Communications and Electronic
Command contract was for a commercially available off-the-shelf
Asynchronous Transfer Mode Network Analyzer that would be used to
test computer network operations.  According to program officials,
the users were aware of what was available commercially and contacted
a number of companies to determine prices and capabilities.  The list
of companies was provided to the contracting officer, who published a
CBD notice for additional sources.  The requirement was identified in
November 1994 and a $118,900-contract was awarded for a commercial
item in March 1996. 

Table II.1 in appendix II presents the results of our review of the
21 contracts by agency or military service command, including a
description of the item bought, the dollar value of the contract, the
type of requirement (or the nature of the buy), and the types of
market research conducted before requirements development and
solicitation of offers. 

DOD and industry officials have repeatedly stated that DOD's
acquisition system must evolve not only to meet national security
needs, but also to take advantage of rapid technological changes in
industry.  Critical items such as computers and electronic components
are examples of such rapidly changing technology.  Officials from the
Army's Communications and Electronic Command and the Air Force's
Electronic Systems Center stated that they keep abreast of such
changes by holding frequent briefings with industry representatives
to exchange information on new developments.  At such meetings,
industry participants inform participants from the military
activities what they are developing and the military services tell
industry what they may need.  The Electronic Systems Center officials
told us that their market research efforts for specific buys do not
have to be--and are not--that extensive now because they have kept up
with changes in industry and are relying primarily on industry to
supply electronic solutions to their needs since most of what they
buy are integrated commercial items.  They also stated that their
solicitations and awards for new items require contractors to use
commercial items and components to the maximum extent practical. 

Regarding the use of the results of market research in the contracts
reviewed, we found evidence that such research was used in 13 of the
21 contracts to obtain commercial items and NDI\6 and in 5 of the
21 contracts to obtain government-unique items or services.  In 6 of
the
13 contracts, market research identified commercial items/NDI, which
ultimately were bought as is.  In the other seven contracts, the
agencies bought a modified commercial item/NDI.  In addition, cost
and/or performance tradeoffs were made and acquisition requirements
were modified in 6 of the 13 contracts.  Table II.2 in appendix II
presents the results of the use of market research in these contracts
and information regarding tradeoffs on acquisition requirements for
the 21 contract actions. 


--------------------
\5 Full and open competition was not required for one contract
because of unusual and compelling urgency and for the remaining two
contracts because directed sources had been specified in
international agreements.  The FAR does not require publication of
CBD notices in such circumstances. 

\6 There were three other contracts where commercial items were
obtained; however, market research was not conducted because the
contracts were awarded under an exception to full and open
competition, as previously discussed. 


      POST-FASA IMPLEMENTATION
      UNDERWAY, BUT RESULTS NOT
      EXPECTED IMMEDIATELY
---------------------------------------------------------- Letter :3.3

FASA's enactment has spurred DOD and civilian agencies to make a
number of changes relative to market research.  For example,
post-FASA efforts to implement the new market research requirements
have included (1) the Defense Acquisition University's development of
a governmentwide satellite training program, for the acquisition
workforce, that included modules on market research; (2) the Office
of Federal Procurement Policy's (OFPP) efforts to compile a list of
available commercial training courses for market research; (3) the
Federal Acquisition Institute's revisions and development of online
training materials relating to market research; (4) GSA's compilation
of commercial terms and conditions used by 100 of the top Fortune 500
companies; and (5) DOD's issuance of its 1996 5000.1 and 5000.2
acquisition guidance, incorporating FASA's market research changes. 

Regarding the development of specifications for a procurement,
officials in DOD and the civilian agencies we visited pointed out two
significant post-FASA changes (1) a much stronger preference for
commercial items and (2) a requirement to determine whether the
agency's acquisition requirements should be modified, to a reasonable
extent.  Aside from this, the only other significant market
research-related changes noted by these officials that resulted from
the implementation of FASA related to customary commercial practices
and use of CBD note 26.  These officials stated that market research
for developing specifications, as envisioned by FASA, has been
performed for years by the technical community, which includes
program management officials and specification writers.  They further
stated that they do not expect a lot of changes to the current market
research process or practices they perform as a result of FASA and
FAR market research requirements. 

Focusing specifically on contracting, as opposed to acquisition
requirements and specifications, the contracting officials within DOD
and civilian agencies noted that the market research they normally
perform will not be just a product/sources search as in the past. 
Instead, FAR now states that the contracting officer should identify
the customary

  -- commercial terms and conditions for the item being bought;

  -- practices regarding customizing, modifying, or tailoring of
     items to meet customer needs;

  -- practices regarding buyer financing and warranty terms; and

  -- practices of the commercial sector, in general, so that the
     contracting officer can tailor the FAR clauses to be consistent
     with commercial practices. 

Most of the procurement officials we spoke with did not believe there
were any standard terms, conditions, or practices industrywide. 
Although early efforts were being made to identify customary
commercial practices, and terms and conditions associated with
particular items, officials we spoke with stated, for the most part,
vendors' proposals and subsequent negotiations with offerors will
probably continue to be used to determine such information. 

Most of the acquisition and procurement officials we contacted in
DOD, the civilian agencies, and the industry were unable to provide
us with examples of any significant effects of the FASA market
research changes.  These officials stated that the significant
effects of such changes will not be apparent for at least a year
after governmentwide regulatory implementation.  They also noted
that, during the first year of implementation, training will be
needed and, once that training is conducted, the benefits of such
training will not show up for quite sometime thereafter. 


      CBD NOTE 26 IS GENERALLY NOT
      BEING USED
---------------------------------------------------------- Letter :3.4

Numbered note 26 states that: 

     "Based upon market research, the Government is not using the
     policies contained in Part 12,\7 Acquisition of Commercial
     Items, in its solicitation for the described supplies or
     services.  However, interested persons may identify to the
     contracting officer their interest and capability to satisfy the
     Government's requirement with a commercial item within
     15 days of this notice."

From October 1, 1995, through May 7, 1996, only 58 of over 2,500 DOD
and civilian contracting activities used numbered note 26 in a total
of 151 CBD notices of solicitations.  The 151 notices represented
only a small fraction of the total number of solicitation notices
that were published during that 7-month period.  Appendix III lists
the DOD and civilian contracting activities that used the note and
the number of CBD announcements with note 26. 

We contacted four activities--the Army's Communications and
Electronics Command, the Navy's Naval Sea Systems Command, and the
Air Force's Electronic Systems Center and Wright-Patterson Air Force
Base--to find out why they were not using the note.  They told us,
essentially, that (1) this requirement had been overlooked and (2)
they would emphasize it to their contracting staff in future policy
letters.  We brought this to the attention of officials in OFPP, GSA,
and DOD.  Although these officials acknowledged that the regulation
writers may have intended for note 26 to be used as a final check on
the government's market research, some DOD and GSA officials objected
to an across-the-board use of the note as such a check. 

DOD officials stated that because a number of their items are
military-unique, the note would have to go into hundreds of thousands
of their notices of solicitation and that this may not be practical. 
GSA officials stated that certain services, such as construction and
architecture and engineering are already covered under a different
part of the FAR that reflects current commercial practices in these
areas.  These officials said that use of the note in all
acquisitions, including construction and architecture and engineering
services, would place an unnecessary burden on contracting officials,
who would have to evaluate all responses to the note.  Both the DOD
and GSA officials stated that they would take actions to exempt these
types of contracts from the note 26 requirement.\8

Although some DOD officials have expressed concern over the use of
numbered note 26, DOD, when commenting on a draft of this report,
stated that it does not currently plan to change its market research
process or practices that have been implemented under FASA, unless
its process measurements in this area indicate a need to do so.  GSA,
in its comments on our draft report, stated that the issue of an
across-the-board application of number note 26 is being reviewed by
the FAR Commercial Contracting Drafting Team as part of its efforts
to address related questions that have arisen.  The Environmental
Protection Agency (EPA), in its comments on our draft report, stated
it had reminded its contracting staff of the requirement to use
numbered note 26. 


--------------------
\7 FAR part 12 contains policies and procedures unique to the
acquisition of commercial items.  It includes (1) standard provisions
and clauses for use in such buys, (2) a list of laws inapplicable to
executive agency prime contracts for commercial item buys, and (3)
streamlined procedures for soliciting offers and awarding contracts
for commercial items. 

\8 A regulatory drafting team is currently considering additional
commercial item issues not addressed in the implementation of FASA. 
Among other things, the team is looking at the relationship between
FAR Part 12, Acquisition of Commercial Items and FAR Part 36,
Construction and Architect-Engineer Contracts. 


   BROAD CONSENSUS AGAINST A
   GOVERNMENT-MAINTAINED DATABASE,
   BUT OTHER IDEAS MIGHT BE
   HELPFUL
------------------------------------------------------------ Letter :4

Government and industry officials have provided varied opinions on
the possibility of creating a governmentwide database for storing,
retrieving, and analyzing market data.  However, most of them opposed
the creation of a comprehensive, governmentwide, and
government-maintained database.  They said it would (1) be too costly
for such a database to contain information comprehensive enough to
cover the spectrum of potential federal government procurements, (2)
take enormous amounts of funding and staffing resources to maintain,
(3) not likely be kept current, and (4) provide few benefits. 
In addition, there were varied opinions on what such a database
should contain that would truly facilitate market research.  Some
officials indicated that information on the following would be
helpful (1) products available in industry and previously developed
for other agencies; (2) past acquisitions made by the government,
such as the data that is currently included in the Federal
Procurement Data System; and/or (3) commercial terms and conditions
associated with a particular item. 

We found that the Army's Communication and Electronics Command had
used a self-developed commercial and NDI product database for
approximately 6 years.  However, the Command eventually terminated
the system because it was never current, due to rapid advances in
electronic technology and cost too much to maintain--about $500,000
annually.  According to Command officials, the activity decided to
use DATAPRO--an industry firm that provides some of the same
information they were trying to maintain, but in a more up-to-date
manner. 

We also talked with officials from selected private sector firms
about their market research efforts, companywide databases that would
facilitate market research, and their views on the feasibility of a
governmentwide, government-maintained database to facilitate market
research.  They said such a database is feasible but would be
difficult to maintain and would be costly.  They noted that their
companies have or are generating companywide databases to provide
prior procurement information, which is similar to the data in the
Federal Procurement Data System and in individual government buying
activities. 

In contrast to the reaction against a government-maintained database,
many of the government and industry officials we spoke with favored
other technology-related ideas to facilitate market research.  In
fact, some officials stated that private industry through the
Internet--a global "network of networks," which in 1995 linked over
59,000 networks, 2.2 million computer systems, and 15 million users
in 92 countries--should be the vehicle used to provide market
research information.  They also stated that any of the previously
suggested types of information (product data, terms and conditions,
or data on past acquisitions) could be accessed from the Internet. 
These officials noted that the Internet is becoming a popular forum
for providing federal acquisition information, and that private
industry has started to use the Internet to list their products and
services and, in some cases, to provide extensive commercial
catalogs. 

For example, OFPP officials and others pointed out that powerful
"search engines" are becoming available on the Internet that will
facilitate market research of private sector and government
electronic catalogs.  In commenting on a draft of this report, OFPP
officials noted that they had provided guidance for the major
procuring agencies to promote the use of the Internet for market
research.  In addition, DOD officials said the Internet could
facilitate greater use of common databases across military service
lines as agencies place such information on their Internet home
pages. 

Currently, there are a number of federal initiatives related to the
Internet and its use to facilitate market research.  These include

  -- DOD's Commercial Advocates Forum, which was created as an
     interactive forum to provide tools for searching government and
     private sector catalogs, assist DOD officials in identifying
     commercial terms and conditions, and provide other market
     research information--such as lessons learned and best
     practices;

  -- the Interagency Acquisition Internet Council, which seeks, among
     other things, to promote federal agencies' use of the Internet
     as a virtual marketplace and its use as a market research
     tool;\9 and

  -- various agencies' use of the Internet to publicize their future
     acquisition plans. 

The DOD Commercial Advocates Forum, for example, contains a market
research "icon" where DOD officials can access DOD regulations
related to market research, best practices in this area, and a
"toolbox" of aids to assist in market research.  Specifically, the
toolbox contains a number of items such as (1) the Thomas Register of
American Manufacturers, which provides sourcing information on nearly
52,000 industrial products and services as well as specifications and
availability information from thousands of manufacturers; (2) the
Dunn and Bradstreet Catalog, which identifies and assists in
evaluating potential suppliers based on purchasing needs; and (3) the
Frost and Sullivan Report, a large market research consulting firm
that provides market research information and reports on over 20 key
industries.  According to the developers of the commercial advocates'
forum, the listings in the toolbox are of organizations that provide
information on suppliers and linkages to those suppliers' catalogs. 
These tools can all be utilized by the contracting and requirement
officials in performing market research. 

In light of these Internet initiatives and the strong consensus
against the database, we do not believe that federal agencies should
be required, at this time, to create a comprehensive, governmentwide,
and government-maintained database to store, retrieve, and analyze
market data. 


--------------------
\9 The Interagency Acquisition Internet Council has just begun its
efforts.  Although not a priority item, Council officials told us
they plan to review market research at a later date. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :5

We performed our work in agencies that were listed in the Federal
Procurement Data System as large buyers of goods and services.  These
included DOD, GSA, the National Aeronautics and Space Administration
(NASA), EPA, and the Department of Transportation (the Federal
Aviation Administration and the Coast Guard).  More specifically, we
interviewed officials from (1) the Naval Sea Systems Command and the
Space and Naval Warfare Systems Command; (2) the Office of the
Assistant Secretary of the Army for Acquisition, Research, and
Development, the Army Contract Support Office, and Communications and
Electronics Command; (3) the Air Force's headquarters Office of the
Deputy Assistant Secretary for Contracting--the FAR Systems,
Wright-Patterson Air Force Base, and Hanscom's Electronic Systems
Center; (4) the Defense Logistics Agency's Defense Fuel Supply
Center, Defense Electronics Supply Center, Defense General Supply
Center, Defense Personnel Support Center, Defense Construction Supply
Center, and Defense Industrial Supply Center; and (5) NASA's Goddard
Space Center.  We interviewed officials from these organizations
regarding (1) pre-FASA market research practices; (2) planned changes
under FASA and the new FAR; and (3) the feasibility of creating a
governmentwide database to store, retrieve, and analyze market data. 

We also reviewed a judgmental sample of contracts awarded during our
audit work (October 1995 through July 1996) by some of the major
buying activities listed above.  We selected, from these activities,
contracts that varied in dollar amount, complexity, and industry
sector to provide descriptive market research information for a
variety of procurements.  This sample was not intended to be a
scientific sample. 

In addition, we interviewed officials from OFPP, as well as industry
officials about (1) the changes related to market research and the
procurement of commercial items and (2) the feasibility of creating a
governmentwide database for market data.  Industry officials were
from Lockheed Martin; McDonnell Douglas Corporation; International
Business Machines Corporation; INPUT--a market research organization;
the Computer and Communications Industry Association; the Computer
Business and Equipment Manufacturers' Association; the Aerospace
Industries Association; and the Electronics Industry Association.  In
addition, we reviewed prior reports, hearings, studies, and selected
market surveys/investigations relating to the government's efforts to
identify commercial items and NDI. 

We also reviewed (1) the draft and final versions of the new market
research provisions in the FAR, along with comments provided by the
various federal agencies and industry organizations and (2) agency
guidance related to market research, such as the new DOD series
5000.1, entitled "Defense Acquisition" and 5000.2-R, entitled
"Mandatory Procedures for Major Defense Acquisition Programs and
Major Automated Information System Acquisition Programs," both dated
March 15, 1996.  We also observed several demonstrations by agency
officials of market research tools on the Internet and obtained
various market research documentation from the Internet. 

Section 8305 of FASA also required us to make ".  .  .  any
recommendations for changes in law or regulations that the
Comptroller General considers appropriate." Since it is early in the
implementation of the FAR market research changes and the results
from such changes are not expected until a year after implementation,
we have no changes to recommend at this time.  We conducted our
review between October 1995 and July 1996 in accordance with
generally accepted government auditing standards. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :6

In commenting on a draft of this report, DOD, EPA, GSA, NASA, and
OFPP generally agreed with the information in the report.  Each made
some suggestions to improve the clarity and technical accuracy of the
report and we have incorporated them in the text where appropriate. 
DOD and NASA submitted written comments, and the other agencies
submitted theirs orally.  DOD's and NASA's comments are reprinted in
appendixes IV and V, respectively. 


---------------------------------------------------------- Letter :6.1

We are sending copies of this report to the Director, Office of
Management and Budget; the Secretary of Defense; the Administrator of
OFPP; the Administrator of NASA; the Administrator of GSA; the
Administrator of EPA; and other interested congressional committees. 
We will also make copies available to others upon request. 

Please contact me or my Associate Director, David E.  Cooper, at
(202) 512-4841 if you or your staff have any questions concerning
this report.  Major contributors to this report are listed in
appendix VI. 

Louis J.  Rodrigues
Director, Defense Acquisitions Issues

List of Congressional Committees

The Honorable Ted Stevens
Chairman
The Honorable John Glenn
Ranking Minority Member
Committee on Governmental Affairs
United States Senate

The Honorable Strom Thurmond
Chairman
The Honorable Sam Nunn
Ranking Minority Member
Committee on Armed Services
United States Senate

The Honorable Christopher S.  Bond
Chairman
The Honorable Dale L.  Bumpers
Ranking Minority Member
Committee on Small Business
United States Senate

The Honorable William F.  Clinger, Jr.
Chairman
The Honorable Cardiss Collins
Ranking Minority Member
Committee on Government Reform and Oversight
House of Representatives

The Honorable Floyd D.  Spence
Chairman
The Honorable Ronald Dellums
Ranking Minority Member
Committee on National Security
House of Representatives

The Honorable Jan Meyers
Chairwoman
The Honorable John J.  LaFalce
Ranking Minority Member
Committee on Small Business
House of Representatives


FEDERAL ACQUISITION REGULATION'S
DEFINITION FOR COMMERCIAL ITEMS
AND NONDEVELOPMENTAL ITEMS
=========================================================== Appendix I

In accordance with the Federal Acquisition Regulation (FAR) part
2.101, "Commercial item" means: 

     (a) "Any item, other than real property, that is of a type
     customarily used for nongovernmental purposes and that· (1) Has
     been sold, leased, or licensed to the general public; or, (2)
     Has been offered for sale, lease, or license to the general
     public;

     (b) "Any item that evolved from an item described in paragraph
     (a) of this definition through advances in technology or
     performance and that is not yet available in the commercial
     marketplace, but will be available in the commercial marketplace
     in time to satisfy the delivery requirements under a Government
     solicitation;

     (c) "Any item that would satisfy a criterion expressed in
     paragraphs (a) or (b) of this definition, but for· (1)
     Modifications of a type customarily available in the commercial
     marketplace; or (2) Minor modifications of a type not
     customarily available in the commercial marketplace made to meet
     Federal Government requirements.  "Minor" modifications means
     modifications that do not significantly alter the
     nongovernmental function or essential physical characteristics
     of an item or component, or change the purpose of a process. 
     Factors to be considered in determining whether a modification
     is minor include the value and size of the modification and the
     comparative value and size of the final product.  Dollar values
     and percentages may be used as guideposts, but are not
     conclusive evidence that a modification is minor;

     (d) "Any combination of items meeting the requirements of
     paragraphs (a), (b), (c), or (e) of this definition that are of
     a type customarily combined and sold in combination to the
     general public;

     (e) "Installation services, maintenance services, repair
     services, training services, and other services if such services
     are procured for support of an item referred to in paragraphs
     (a), (b), (c), or (d) of this definition, and if the source of
     such services· (1) Offers such services to the general public
     and the Federal Government contemporaneously and under similar
     terms and conditions; and (2) Offers to use the same work force
     for providing the Federal Government with such services as the
     source uses for providing such services to the general public;

     (f) "Services of a type offered and sold competitively in
     substantial quantities in the commercial marketplace based on
     established catalog or market prices for specific tasks
     performed under standard commercial terms and conditions.  This
     does not include services that are sold based on hourly rates
     without an established catalog or market price for a specific
     service performed;

     (g) "Any item, combination of items, or service referred to in
     paragraphs (a) through (f), notwithstanding the fact that the
     item, combination of items, or service is transferred between or
     among separate divisions, subsidiaries, or affiliates of a
     contractor; or

     (h) "A nondevelopmental item, if the procuring agency determines
     the item was developed exclusively at private expense and sold
     in substantial quantities, on a competitive basis, to multiple
     State and local governments."

FAR 2.101 defines "nondevelopmental items" to mean: 

     (a) "Any previously developed item of supply used exclusively
     for governmental purposes by a Federal agency, a State or local
     government, or a foreign government with which the United States
     has a mutual defense cooperation agreement;

     (b) "Any item described in paragraph (a) of this definition that
     requires only minor modification or modifications of a type
     customarily available in the commercial market place in order to
     meet the requirements of the procuring department or agency; or

     (c) "Any item of supply being produced that does not meet the
     requirements of paragraph (a) or (b) solely because the item is
     not yet in use."


MARKET RESEARCH EFFORTS AND
RESULTS FOR THE 21 CONTRACTS
REVIEWED
========================================================== Appendix II

Table II.1 shows the market research efforts in developing
requirements and increasing competition.  Table II.2 shows the
results of the market research efforts for the 21 contracts we
reviewed. 



                                    Table II.1
                     
                      Market Research Efforts in Developing
                     Requirements and Increasing Competition

                              (Dollars in thousands)

                                                Market
                                                research
                                                conducted
                                                prior to
                                                finalizing the  Market research
                                                specification   conducted to
                                                for the         identify sources
Contract           Contract     Type of         current         for
description         amount      requirement     contract        competition\a
--------------  --------------  --------------  --------------  ----------------
U.S. Army Communication and Electronic Command
--------------------------------------------------------------------------------
Near-term         $10,700.0     Enhancement\b   Draft RFP,      CBD notice\
digital radio                                   face-to-face
                                                meetings with
                                                vendors, broad
                                                agency
                                                announcement,
                                                technical
                                                demonstration,
                                                and
                                                presolicitatio
                                                n conferences

Family of          1,787.1      Enhancement     Market          CBD notice
loudspeakers                                    investigation
                                                reports, draft
                                                RFP, informal
                                                discussions
                                                with industry,
                                                and
                                                presolicitatio
                                                n conferences

Asynchronous        118.9       New             Product         CBD notice
transfer mode                                   literature
test system

Radiosonde set      240.0       Recurring       None            CBD notice

SINCGARS           5,165.8      Enhancement     Draft RFP,      CBD notice
handheld                                        sample
remote control                                  testing,
                                                market survey,
                                                and informal
                                                discussions

Night vision       26,013.6     Enhancement     Trade           CBD notice,
goggles                                         journals,       preproposal
                                                sources sought  conference, and
                                                CBD notice,     sample hardware
                                                draft RFP,
                                                face-to-face
                                                meetings with
                                                vendors, and
                                                prototypes
                                                testing


U.S. Army Aviation and Troop Command
--------------------------------------------------------------------------------
Diesel engine      8,010.2      Recurring       None            Procurement
                                                                history, CBD
                                                                notice, and
                                                                competition
                                                                advocates
                                                                shopping list

Modular base       4,467.8      Enhancement     Literature      Procurement
petroleum                                       search,         history and CBD
laboratory                                      contacting      notice
                                                industry
                                                officials, and
                                                market
                                                investigation

Hydraulic           397.0       Recurring       None            Procurement
impact wrench                                                   history and CBD
                                                                notice


Naval Sea Systems Command
--------------------------------------------------------------------------------
Trident            1,879.5      Recurring       None            CBD notice
battery

AN/SRQ-4 radio     5,519.5      Recurring       Sources sought  CBD notice and
                                                and             procurement
                                                presolicitatio  history
                                                n conferences


U.S. Air Force Electronic Systems Center
--------------------------------------------------------------------------------
Research and        $900.0      New             Broad agency    None\c
development                                     announcement
services for
information
warfare

Mission            7,556.1      New             None\d          None\d
planning
workstations

Transmission        163.0       Recurring       None            None\e
and receive
stations

Handheld           7,629.7      New             Market          CBD and EBB
thermal imager                                  surveys,        notices
                                                symposiums and
                                                trade shows,
                                                sources sought
                                                notices, and
                                                face-to-face
                                                meetings with
                                                industry

Research and       1,611.9      New             Broad agency    None
development on                                  announcement
computer
network high
speed
potential

Landsat            1,700.0      Enhancement     None\f          None\f
upgrade


NASA Goddard Space Center
--------------------------------------------------------------------------------
Medium-light      167,568.7     New             Industry        CBD notice
expendable                                      symposium,
launch vehicle                                  one-on-one
services                                        meetings with
                                                vendors, draft
                                                RFP

Digital matrix     10,000.0     New             Trade           Procurement
switches                                        journals,       history and past
                                                keeping         performance
                                                abreast of      history\g
                                                technology

Optical             220.0       New             Face-to-face    CBD notice
detector                                        meetings,
                                                reviewing
                                                catalogs, and
                                                contacting
                                                industry for
                                                informal
                                                proposals


Environmental Protection Agency
--------------------------------------------------------------------------------
Technical          1,905.5      Recurring       None            CBD notice
support
services
--------------------------------------------------------------------------------
Note:  CBD is the Commerce Business Daily.
RFP is request for proposals.
EBB is electronic bulletin board.
SINCGARS is Single Channel Ground Airborne Radio System.
NASA is National Aeronautics and Space Administration.

\a The CBD notices identified in this column publicized solicitations
of bids and proposals for property or services over $25,000 and are
required by 41 U.S.C.  416. 

\b Enhancement means an upgrade to an already existing requirement. 

\c This contract is a research effort by the Defense Advanced
Research Project Agency to advance computer simulation technologies. 
A broad agency announcement was published in February 1995, and a
contract was awarded based on information submitted in response to
that announcement. 

\d Market research was not conducted at the requirements stage of the
acquisition, and no solicitation was published because this was an
international agreement and such actions are not required by 10
U.S.C.  2304(c)(4).  Sources were directed in a letter of offer and
acceptance. 

\e This contract was for commercial communications equipment for use
in support of Operation Joint Endeavor in Bosnia.  The buy was made
under other than full and open competition due to unusual and
compelling urgency by 10 U.S.C.  2304(c)(2). 

\f A market survey was done on the prior system to determine the
availability of ground station for receiving multispectral satellite
imagery from the French satellite.  An international agreement was
subsequently written, and no market research was done for the
enhancement. 

\g This contract was awarded under section 8(a) of the Small Business
Act. 




                                    Table II.2
                     
                        Results of Market Research Efforts

                              (Dollars in thousands)


                                            Commercia
Contract              Type of               l item/               Government-
descripti  Contract   requireme  Tradeoffs  service               unique item/
on          amount    nt         made       obtained   NDI        service
---------  ---------  ---------  ---------  ---------  ---------  --------------
U.S. Army Communications-Electronics Command
--------------------------------------------------------------------------------
Near-      $10,700.0  Enhanceme  Yes                   X\a(modif
term                  nt                               ied)
digital
radio

Family of   1,787.1   Enhanceme  Yes        X\b
loudspeak             nt                    (modified
ers                                         )

Asynchron    118.9    New        No         X
ous
transfer
mode test
system

Radiosond    240.0    Recurring  No         X
e set

SINCGARS    5,165.8   Enhanceme  No                    X\c(modif
handheld              nt                               ied)
remote
control

Night      26,013.6   Enhanceme  Yes                   X\d(modif
vision                nt                               ied)
goggles


U.S. Army Aviation and Troop Command
--------------------------------------------------------------------------------
Diesel      8,010.2   Recurring  Yes        X
engine                                      (modified
                                            )

Modular     4,467.8   Enhanceme  No                    X\(modifi
base                  nt                               ed)
petroleum
laborator
y

Hydraulic    397.0    Recurring  No         X
impact
wrench


Naval Sea Systems Command
--------------------------------------------------------------------------------
Trident     1,879.5   Recurring  No                    X
battery

AN/SRQ-4    5,519.5   Recurring  No                    X\e
radio


U.S. Air Force Electronic Systems Center
--------------------------------------------------------------------------------
Research     900.0    New        No                               Research\f
and
developme
nt
services
for
informati
on
warfare

Mission     7,556.1   New        No         X\\g(modi
planning                                    fied)\
workstati
ons

Transmiss    163.0    Recurring  No         X
ion and                                     (modified
receive                                     )
stations

Handheld    7,629.7   New        Yes        X
thermal                                     (modified
imager                                      )

Research    1,611.9   New        No                               Research\h
and
developme
nt on
computer
network
high
speed
potential

Landsat     1,700.0   Enhanceme  No         X
upgrade               nt                    (modified
                                            )


NASA Goddard Space Center
--------------------------------------------------------------------------------
Medium-    $167,568.  New        No                               X (government-
light          7                                                  unique service
expendabl                                                         and
e launch                                                          development
vehicle                                                           required)
services

Digital    10,000.0   New        Yes        X
matrix
switches

Optical      220.0    New        No                               X (new
detector                                                          development)


Environmental Protection Agency
--------------------------------------------------------------------------------
Technical   1,905.5   Recurring  No                               X
support
services
--------------------------------------------------------------------------------
\a According to program officials, the near-term digital radio was
derived from the Enhanced Position Location Reporting System and
upgraded to include the current communication technology and open
architecture.  It is considered a modified nondevelopmental item
(NDI) by program officials.  Also, according to program officials, it
is 95 percent commercial software and 60 percent commercial hardware. 
It has embedded communication security, however, which no other
product in the industry has. 

\b Most of the components in the family of loudspeakers, per program
officials, are commercially available products but are packaged and
integrated to meet military requirements. 

\c Program officials stated that 90 percent of the electronics in the
handset are commercial and that the effort to integrate commercial
components into the existing system is considered to be part of the
development phase. 

\d Program officials stated that this buy includes (1) night vision
goggles and imaging systems that have been bought for 10 years with a
new/enhanced "image intensifier" from industry and (2) a commercial
off-the-shelf monocular device that had minor modifications. 

\e The AN/SRQ was originally bought in 1975 for the Light Airborne
Multi-Purpose System III helicopter.  It was required in this
procurement for the DDG-51 and was classified as an NDI by program
officials. 

\f This contract is for research only into computer simulation
technology. 

\g The software was modified in this contract to talk with the
Egyptian F16. 

\h This is for a research and development action, not a supply
contract.  The only physical deliverables are prototypes of advance
computer network devices. 


DOD AND CIVILIAN AGENCIES THAT
USED NUMBERED NOTE 26
========================================================= Appendix III

Table III.1 shows the Department of Defense (DOD) contracting
activities that used numbered note 26 and the number of CBD
announcements with note 26.  Table III.2 provides the same
information for the civilian activities. 



                              Table III.1
                
                  DOD Contracting Activities That Used
                 Note 26 (Oct. 1, 1995, through May 7,
                                 1996)

                                                             Number of
                                                                   CBD
                                                          announcement
Contracting activity                                                 s
--------------------------------------------------------  ------------
Randolph Air Force Base, Texas                                       1
Air Logistics Command, Kelly Air Force Base, Texas                   1
C-17 Aircraft Contracting Division, Kelly Air Force                  1
 Base, Texas
Eglin Air Force Base, Florida                                        1
U.S. Army Engineering District, Sacramento, California               1
Army Training and Doctrine Command, Fort Eustis,                     1
 Virginia
Army Aviation and Troop Command, St. Louis, Missouri                32
Army Missile Command, Redstone Arsenal, Alabama                      1
Army Engineering & Support Center, Huntsville, Alabama               1
Army White Sands Missile Range, New Mexico                           5
Fort Campbell, Kentucky                                              1
U.S. Army Intelligence and Security Command, Fort                    1
 Belvoir, Virginia
Letterkenny Army Depot, Chambersburg, Pennsylvania                   1
Defense Information Systems Agency, Arlington, Virginia              1
Defense Advance Research Project Agency, Arlington,                  1
 Virginia
Fleet and Industrial Supply Center Norfolk, Washington,              4
 D.C.
Fleet and Industrial Supply Center Norfolk,                          3
 Philadelphia, Pennsylvania
Fleet and Industrial Supply Center, San Diego,                       8
 California
Naval Air Warfare Center Training Systems Division,                  1
 Orlando, Florida
Naval Medical Logistics Command, Fort Detrick,                       1
 Frederick, Maryland
Naval Research Laboratory, Washington, D.C.                          8
Naval Surface Warfare Center, Crane, Indiana                         1
Coastal Systems Station, Dahlgren Division, Panama,                  1
 Florida
Naval Command, Control and Ocean Surveillance Command,
 Research, Development, Test and Evaluation Division,                1
 San Diego, California
======================================================================
Total                                                               78
----------------------------------------------------------------------


                              Table III.2
                
                  Civilian Contracting Activities That
                            Used CBD Note 26
                  (Oct. 1, 1995, through May 7, 1996)

                                                             Number of
                                                                   CBD
                                                          announcement
Civilian contracting activity                                        s
--------------------------------------------------------  ------------
American Embassies (nine different locations)\a                      9
Bureau of Land Management, Denver, Colorado                          2
Bureau of Reclamation, Boise, Idaho                                  4
Federal Aviation Administration, Washington, D.C.                    1
GSA, Ft. Worth, Texas                                                2
NASA Langley Research Center, Hampton, Virginia.                     1
NASA Stennis Space Center, Mississippi                               1
National Institute of Health, Bethesda, Maryland                     9
National Institute of Standards and Technology,                      3
 Gaithersburg, Maryland
National Library of Medicine, Bethesda, Maryland                     1
Social Security Administration, Philadelphia,                        1
 Pennsylvania
U.S. Coast Guard Academy, New London, Connecticut                    2
U.S. Coast Guard Aircraft Repair & Supply Center,                    2
 Elizabeth City, North Carolina
U.S. Coast Guard Maintenance and Logistics Command
 Pacific, Alameda, California                                        5
U.S. Coast Guard Supply Center Curtis Bay, Baltimore,                8
 Maryland
U.S. Coast Guard Supply Center Baltimore, Baltimore,                 4
 Maryland
U.S. Department of Agriculture, Forest Service, Umpqua
 National Forest, Roseburg, Oregon                                   3
U.S. Department of Agriculture, Forest Service, Kootenai
 National Forest, Libby, Montana                                     5
U.S. Department of Commerce, Boulder, Colorado                       1
U.S. Department of Interior, Office of Aircraft                      1
 Services, Boise, Idaho
U.S. Department of Labor, Washington, D.C.                           1
U.S. Geological Survey, Denver, Colorado                             1
U.S. Geological Survey, Reston, Virginia                             2
U.S. Secret Service, Washington, D.C.                                2
U.S. Department of Veterans' Affairs, Medical Center,                1
 Dublin, Georgia
U.S. Department of Veterans' Affairs, Medical Center,                1
 Poplar Bluff, Missouri
======================================================================
Total                                                               73
----------------------------------------------------------------------
\a One CBD announcement was published from each of the following
American embassy locations:  Lagos, Nigeria; Panama City, Panama;
Buenos Aires, Argentina; Santo Domingo, Dominican Republic; Manila,
Philippines; Papua New Guinea; Kinshasa, Zaire; Copenhagen, Denmark;
and The Hague, The Netherlands. 




(See figure in printed edition.)Appendix IV
COMMENTS FROM THE DEPARTMENT OF
DEFENSE
========================================================= Appendix III




(See figure in printed edition.)Appendix V
COMMENTS FROM THE NATIONAL
AERONAUTICS AND SPACE
ADMINISTRATION
========================================================= Appendix III


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI

NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C. 

Kevin Tansey
David Childress
Marion Gatling
Russell Reiter
Shirley Johnson

OFFICE OF THE GENERAL COUNSEL

John Brosnan
William T.  Woods
Maureen A.  Murphy

BOSTON REGIONAL OFFICE

Thorton Harvey


*** End of document. ***