Iraq Drawdown
Opportunities Exist to Improve Equipment Visibility, Contractor Demobilization, and Clarity of Post-2011 DOD Role Gao ID: GAO-11-774 September 16, 2011In Process
DOD has robust plans and processes for determining the sequence of actions and associated resources necessary to achieve the drawdown from Iraq, which is well underway with a significant amount of equipment removed from Iraq and bases transitioned, among other things. However, several factors contribute to making this phase more challenging than the previous drawdown phase. First, DOD will have less operational flexibility in this phase of the drawdown, yet will need to move a greater amount of equipment than in prior drawdown phases. Second, DOD is closing the largest bases with fewer available resources left on site, which creates a set of challenges and risks greater than what DOD faced during the prior drawdown phase. Although DOD's plans and processes create flexibility and mitigate risk, it has limited visibility over some equipment remaining in Iraq and does not track equipment found on transitioning bases that is not listed on any property accountability record. Without addressing these issues, DOD may miss opportunities to make the drawdown more efficient. DOD has taken action to improve its management of contracts in Iraq, such as enhancing contract oversight and assigning Contracting Officer's Representative responsibilities as a primary duty, although concerns, such as lack of experience among contract oversight personnel, remain. As the drawdown progresses, DOD may face further challenges in ensuring that major contracts transition without gaps in key services. To ensure the continuity of key services while continuing to reduce these services, some units are exploring the option of using local contractors to provide certain services since local contractors do not require extensive support, such as housing, and will not have to be repatriated to their country of origin at the end of the contract, although GAO has previously reported on challenges associated with hiring such firms resulting in the need for greater oversight. Some units also intend to replace contractor personnel with servicemembers to ensure continuity of certain services, such as guard security and generator maintenance. Despite various steps to ease contractor demobilization, DOD faces challenges in demobilizing its contractors, including operational security-driven limits on exchanging information such as base closure dates and ensuring accurate contractor planning. Without taking additional steps to address these challenges, DOD may be unable to effectively implement its demobilization guidance and ensure the effective reduction of contract services to appropriate levels and ultimate demobilization of all its contractors. As the U.S. presence in Iraq transitions to a civilian-led presence, although DOD and State interagency coordination for the transition began late, both agencies have now coordinated extensively and begun to execute the transfer or loan to State of a wide range of DOD equipment, while DOD has taken steps to minimize any impact on unit readiness of such transfers. DOD also has agreed to potentially provide State with extensive contracted services, including base and life support, food and fuel, and maintenance, but State may not have the capacity to fund and oversee these services. GAO recommends that DOD take further action to (1) acquire and maintain real-time visibility over contractor-managed government- owned equipment; (2) collect data on unaccounted-for equipment found during base transitions; (3) work with contractors to gather and distribute information needed to demobilize their workforces; and (4) officially clarify the scope of DOD's role in post-2011 Iraq, to include the privileges and immunities to be afforded all DOD government personnel. DOD concurred with all of GAO's recommendations.
GAO-11-774, Iraq Drawdown: Opportunities Exist to Improve Equipment Visibility, Contractor Demobilization, and Clarity of Post-2011 DOD Role
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United States Government Accountability Office:
GAO:
Report to Congressional Addressees:
September 2011:
Iraq Drawdown:
Opportunities Exist to Improve Equipment Visibility, Contractor
Demobilization, and Clarity of Post-2011 DOD Role:
GAO-11-774:
GAO Highlights:
Highlights of GAO-11-774, a report to congressional addressees.
Why GAO Did This Study:
The drawdown of U.S. forces in Iraq and the transition from a U.S.
military to a civilian-led presence after December 2011 continue amid
an uncertain security and political environment. This report is one in
a series of reviews regarding the planning and execution of the
drawdown. Specifically, this report assesses the extent to which DOD
has planned for, begun to execute, and mitigated risk associated with
(1) transferring and removing personnel and equipment from remaining
bases in Iraq; (2) curtailing unneeded contract services,
transitioning expiring contracts, and providing adequate contract
oversight; and (3) facilitating and supporting the transition to a
civilian-led presence in Iraq. GAO examined relevant DOD planning
documents, attended drawdown-related conferences, interviewed State
officials and DOD officials throughout the chain of command in the
United States, Kuwait, and Iraq, and visited several locations in
Kuwait and Iraq to observe drawdown operations.
What GAO Found:
DOD has robust plans and processes for determining the sequence of
actions and associated resources necessary to achieve the drawdown
from Iraq, which is well underway with a significant amount of
equipment removed from Iraq and bases transitioned, among other
things. However, several factors contribute to making this phase more
challenging than the previous drawdown phase. First, DOD will have
less operational flexibility in this phase of the drawdown, yet will
need to move a greater amount of equipment than in prior drawdown
phases. Second, DOD is closing the largest bases with fewer available
resources left on site, which creates a set of challenges and risks
greater than what DOD faced during the prior drawdown phase. Although
DOD's plans and processes create flexibility and mitigate risk, it has
limited visibility over some equipment remaining in Iraq and does not
track equipment found on transitioning bases that is not listed on any
property accountability record. Without addressing these issues, DOD
may miss opportunities to make the drawdown more efficient.
DOD has taken action to improve its management of contracts in Iraq,
such as enhancing contract oversight and assigning Contracting
Officer's Representative responsibilities as a primary duty, although
concerns, such as lack of experience among contract oversight
personnel, remain. As the drawdown progresses, DOD may face further
challenges in ensuring that major contracts transition without gaps in
key services. To ensure the continuity of key services while
continuing to reduce these services, some units are exploring the
option of using local contractors to provide certain services since
local contractors do not require extensive support, such as housing,
and will not have to be repatriated to their country of origin at the
end of the contract, although GAO has previously reported on
challenges associated with hiring such firms resulting in the need for
greater oversight. Some units also intend to replace contractor
personnel with servicemembers to ensure continuity of certain
services, such as guard security and generator maintenance. Despite
various steps to ease contractor demobilization, DOD faces challenges
in demobilizing its contractors, including operational security-driven
limits on exchanging information such as base closure dates and
ensuring accurate contractor planning. Without taking additional steps
to address these challenges, DOD may be unable to effectively
implement its demobilization guidance and ensure the effective
reduction of contract services to appropriate levels and ultimate
demobilization of all its contractors.
As the U.S. presence in Iraq transitions to a civilian-led presence,
although DOD and State interagency coordination for the transition
began late, both agencies have now coordinated extensively and begun
to execute the transfer or loan to State of a wide range of DOD
equipment, while DOD has taken steps to minimize any impact on unit
readiness of such transfers. DOD also has agreed to potentially
provide State with extensive contracted services, including base and
life support, food and fuel, and maintenance, but State may not have
the capacity to fund and oversee these services. Further, DOD plans a
robust post-2011 presence as part of an Office of Security Cooperation
operating under Chief of Mission authority. However, the scope of DOD‘
s activities in post-2011 Iraq and associated issues, including
privileges and immunities to be afforded DOD personnel, may not be
well understood by various DOD officials and organizations, thereby
risking an uncoordinated approach.
What GAO Recommends:
GAO recommends that DOD take further action to (1) acquire and
maintain real-time visibility over contractor-managed government-
owned equipment; (2) collect data on unaccounted-for equipment found
during base transitions; (3) work with contractors to gather and
distribute information needed to demobilize their workforces; and (4)
officially clarify the scope of DOD‘s role in post-2011 Iraq, to
include the privileges and immunities to be afforded all DOD
government personnel. DOD concurred with all of GAO‘s recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-11-774] or key
components. For more information, contact William M. Solis at (202)
512-8365 or solisw@gao.gov.
[End of section]
Contents:
Letter:
Background:
DOD Has Conducted Robust Planning for the Current Drawdown Phase and
Execution Is Under Way, but Visibility and Tracking of Some Equipment
Remain a Challenge:
DOD Has Taken Steps to Improve Contract Management and Oversight in
Iraq, but Challenges Remain:
DOD and State Are Coordinating to Establish and Support the Post-2011
U.S. Government Presence in Iraq, but Key Elements of This Presence
May Not Be Well Understood throughout DOD:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Defense:
Appendix III: GAO Contact and Staff Acknowledgments7:
Figure:
Figure 1. Drawdown Progress Since May 2009 and What Remains to Be
Drawn Down through December 31, 2011:
Abbreviations:
ARCENT: U.S. Army Central:
CAP: Contractor Acquired Property:
CENTCOM: U.S. Central Command:
CMGO: Contractor-Managed Government-Owned:
COR: Contracting Officer's Representative:
DCAA: Defense Contract Audit Agency:
DCMA: Defense Contract Management Agency:
DFARS: Defense Federal Acquisition Regulation Supplement:
DOD: Department of Defense:
FAR: Federal Acquisition Regulation:
LOGCAP: Logistics Civil Augmentation Program:
MRAP: Mine Resistant Ambush Protected:
OPORD: Operations Order:
OSC-I: Office of Security Cooperation - Iraq:
RPAT: Redistribution Property Assistance Team:
SCO-I: Senior Contracting Official - Iraq:
SOFA: Status of Forces Agreement:
State: Department of State:
USF-I: U.S. Forces - Iraq:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 16, 2011:
Congressional Addressees:
The drawdown of all military forces and equipment from Iraq, which DOD
must complete by December 31, 2011 in accordance with the Security
Agreement between the United States and the Government of Iraq,
[Footnote 1] is an operation of unprecedented magnitude. Over the
course of several months, DOD must redeploy from Iraq about 46,000
military and at least 57,000 contractor personnel, remove or transfer
at least four times as much theater provided equipment as it has
during prior drawdown phases,[Footnote 2] and transition to the
Government of Iraq all remaining bases in Iraq,[Footnote 3] including
every large installation. This will be the culmination of a logistics
operation that, according to senior DOD officials, is the largest in
scope since the Second World War. In preparing for the current phase
of the drawdown, U.S. Forces-Iraq (USF-I) reduced the number of U.S.
forces in Iraq from about 82,000 in June 2010 to 50,000 ahead of the
August 31 timetable established by the President.[Footnote 4] In
addition, USF-I formally ended its combat mission and transitioned to
Operation New Dawn on September 1, 2010. Under Operation New Dawn, the
mission of U.S. forces includes advising, assisting, and training
Iraqi security forces, partnering with Iraqi forces to conduct counter-
terrorism operations, executing the current phase of USF-I's drawdown
plan, and supporting the transition to a civilian-led presence in Iraq.
The drawdown of U.S. forces, the execution of Operation New Dawn, and
the transition from a U.S. military to a civilian-led presence
continue amidst an uncertain security and political environment. In
particular, although DOD reported that attack levels have decreased
since the height of the violence in June 2007, enemy attacks persist
and insurgents and terrorists continue to operate in Iraq. During the
past months, al Qaeda in Iraq has conducted numerous high-profile
attacks against Iraqi government targets throughout the country. In
addition, according to the Department of State (State), a number of
other groups have attacked U.S. government personnel, including
several Shia extremist groups responsible for the recent and frequent
attacks on the U.S. Embassy, and in June 2011, 15 U.S. troops were
killed in Iraq, the highest number in 2 years, according to DOD.
Further, senior U.S. officials have expressed concerns about the Iraqi
government's ability to provide for its internal security and external
defense, citing weaknesses in its logistics, intelligence, and air
defense capabilities. Should the Government of Iraq request that some
U.S. forces stay after December 2011, this would dramatically alter
current plans; senior U.S. officials continue to state the U.S.
government would be willing to entertain such a request.
This report is a continuation of our efforts to review the planning
and execution of the drawdown of U.S. forces and equipment from Iraq,
and builds upon our prior reports and testimony. Specifically, this
report evaluates the execution of the current phase of the U.S.
military withdrawal from Iraq, which began on September 1, 2010, and
will end on December 31, 2011. Our specific objectives were to
determine the extent to which DOD has planned for, begun to execute,
and mitigated risk associated with (1) transferring and removing
personnel and equipment from remaining bases in Iraq; (2) curtailing
unneeded contract services, transitioning expiring contracts, and
providing adequate contract oversight; and (3) facilitating and
supporting the transition to a civilian-led presence in Iraq. To meet
our objectives, we examined relevant DOD planning documents, including
USF-I and U.S. Army Central (ARCENT) operations orders, attended
drawdown-related conferences, spoke with DOD officials throughout the
chain of command in the United States, Kuwait, and Iraq, and visited
several locations in Kuwait and Iraq to observe drawdown operations.
In the U.S. and Iraq, we also spoke with Department of State officials
involved with the Iraq transition. A more detailed discussion of our
scope and methodology is included in appendix I. We conducted this
performance audit from April 2010 through September 2011 in accordance
with generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings
and conclusions based on our audit objectives. We believe that the
evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Background:
The Security Agreement between the United States and the Government of
Iraq clearly states the objectives for the drawdown from Iraq, and DOD
has further defined the conditions necessary to achieve these
objectives. Time lines for the drawdown were established by the
Security Agreement and further defined by the President of the United
States. The Security Agreement provides that all U.S. forces,[Footnote
5] a term that includes personnel and equipment, shall withdraw from
Iraqi territory no later than December 31, 2011.[Footnote 6] In
addition, the U.S. government must transition all remaining bases
where it maintains a presence to the Government of Iraq upon
withdrawal. In regards to the retrograde[Footnote 7] of equipment and
base transitions, the high-level conditions DOD has identified as
important to the achievement of these objectives include the orderly
and efficient movement or transfer, as appropriate, of equipment out
of Iraq by the time lines established by the Security Agreement.
Further conditions include the establishment of a mission capable
[Footnote 8] civilian-led presence in Iraq by October 1, 2011, which
is necessary to enable DOD to focus on achieving the redeployment of
personnel, retrograde of equipment, and base transition goals by the
end of the year.
DOD anticipates that after December 31, 2011, all U.S. personnel
remaining in Iraq, including DOD military personnel and civilians,
will operate under the authority of the Chief of Mission for execution
of security assistance activities.[Footnote 9] The United States
government intends to stand up a regional diplomatic presence, a large-
scale police training program, and an office of security cooperation
(under the Chief of Mission's authority) to continue training and
equipping the Iraqi security forces.[Footnote 10] According to the
State Department Iraq Transition Coordinator, as of June 2011, the
plans for the U.S. government presence in Iraq after 2011 include
about 16,000 personnel. This official stated that these personnel will
perform a wide range of functions in addition to diplomacy and
security assistance/cooperation, with the majority of personnel likely
comprised of contractor personnel responsible for security and life
support (such as facility operation, food service, laundry, etc.).
Besides meeting requirements for security and life support, other
major aspects of the transition include acquiring the use of property
through land use agreements, repurposing or constructing new
facilities, and defining requirements for and implementing solutions
in the areas of logistics, aviation, equipment, information
technology, and contracting/contract oversight.
The logistics infrastructure supporting the redeployment and
retrograde effort in the Iraqi theater of operations is large and
complex, consisting of military organizations operating in both Iraq
and Kuwait. It is through Kuwait's three seaports and two airports
that the majority of U.S. forces and all of DOD's sensitive equipment,
such as combat vehicles, flow from the theater of operations. DOD also
uses commercial shipping firms to retrograde units' nonsensitive
material and equipment, such as individual equipment and spare parts,
through ports in Jordan and Iraq, and uses an airport in Iraq in
addition to airports in Kuwait to facilitate the redeployment of
military personnel. Myriad logistics organizations in both Iraq and
Kuwait support these operations, including elements of U.S. Central
Command (CENTCOM), USF-I, U.S. Army Central (ARCENT), U.S.
Transportation Command, U.S. Special Operations Command, the Defense
Logistics Agency, the 1st Theater Sustainment Command, Army Materiel
Command, and U.S. Air Forces Central Command. Many of these
organizations have command relationships with each other, and their
activities are synchronized through the issuance of written orders
that define each organization's drawdown tasks, among many other
things. In the case of the drawdown from Iraq, such orders and
associated activities comprise DOD's plans.
U.S. forces in Iraq rely on contractor personnel to provide a wide
range of services including managing dining facilities, repairing
military vehicles, providing trucks and drivers for transporting
supplies, and maintaining airfields. Military units, such as the
"mayors" who oversee base operations, communicate their needs for
contracted services to the appropriate contracting personnel, who in
turn seek to fulfill these "requirements" through contracting vehicles
such as orders, modifications, or new contracts. According to DOD
data, as of May 30, 2011, there were approximately 61,000 contractor
personnel in Iraq. Approximately 52 percent of these contractor
personnel are working under the Logistics Civil Augmentation Program
(LOGCAP), the largest single contract supporting operations in Iraq
and Kuwait.[Footnote 11] The day-to-day activities of LOGCAP
contractor personnel in Iraq are overseen by contracting officers'
representatives (COR) managed by the Defense Contract Management
Agency (DCMA), which administers the contract in Iraq on behalf of the
LOGCAP Program Office, U.S. Army. The remainder of the contractor
personnel primarily work under contracts awarded by CENTCOM-Joint
Theater Support Contracting Command and perform a range of services.
Although contracting officers are responsible for providing contract
oversight, day-to-day oversight of contractors is generally the
responsibility of CORs, who ensure that the government receives the
agreed-upon services at the agreed-upon quality, avoids poor outcomes,
and minimizes fraudulent practices.[Footnote 12] CORs typically come
from military units and perform their duties as an added
responsibility.
Prior GAO Work:
GAO has issued several reports over the past 3 years addressing the
drawdown of forces and equipment from Iraq. In September 2008, we
reported on the progress of drawdown planning, and concluded that DOD
had not adequately defined roles and responsibilities for executing
the drawdown, resulting in multiple teams engaged in retrograde
operations without a unified or coordinated chain of command.[Footnote
13] We recommended that the Secretary of Defense, in consultation with
CENTCOM and the military departments, take steps to clarify the chain
of command over logistical operations in support of the retrograde
effort. Since that time, a number of DOD organizations have issued
plans outlining a phased drawdown from Iraq that meet time frames set
forth in the Security Agreement and presidential guidance while being
responsive to security conditions on the ground. Furthermore,
partially in response to our recommendation, DOD has created several
organizations to achieve unity of effort over retrograde operations.
After the publication of our September 2008 report, we continued to
monitor DOD's progress in planning for and executing the drawdown. In
November 2009, we testified before the Commission on Wartime
Contracting in Iraq and Afghanistan outlining several unresolved
issues that had the potential to impede the effective execution of the
drawdown.[Footnote 14] Following that testimony, we issued a report in
April 2010 that went into greater detail on the progress of the
drawdown and identified challenges that could impact its efficient
execution.[Footnote 15] We recommended that the Secretary of Defense
direct the appropriate authorities to take action in regards to
planning for achieving unity of effort in operational contract
support, mitigating the risks of contract transitions[Footnote 16] and
insufficient contract oversight personnel, and clarifying the capacity
of Kuwait as a temporary staging location for equipment. DOD concurred
with all of our recommendations and stated that it is taking steps to
address each one. For example, since our April 2010 report, DOD
conducted an analysis of the benefits and costs of a prior planned
transition to a new LOGCAP contract and decided not to make the
transition based on its findings.
DOD Has Conducted Robust Planning for the Current Drawdown Phase and
Execution Is Under Way, but Visibility and Tracking of Some Equipment
Remain a Challenge:
DOD has robust plans and processes for determining the sequence of
actions and associated resources necessary to achieve its objectives
for the drawdown from Iraq. The current phase of the drawdown is well
under way with a significant amount of equipment removed from Iraq and
bases transitioned, among other things. Further, DOD successfully
completed the previous drawdown phase, demonstrating the ability to
plan and execute complex drawdown operations. However, several
factors, including limited operational flexibility and the need to
move a greater amount of equipment and close the largest bases with
fewer available resources create a set of challenges and risks greater
than what DOD faced during the prior drawdown phase. DOD's existing
plans and processes create flexibility and mitigate risk, but DOD
continues to face challenges maintaining real-time visibility over
some equipment and tracking unaccounted for equipment remaining after
bases undergo the transition process.
DOD's Planning Processes Facilitated the Successful Execution of the
Previous Drawdown Phase, but Completing the Current Phase Will Be More
Challenging:
Successful Execution of Previous Drawdown Phase:
The completion of the prior drawdown phase, conducted between June and
August 2010, demonstrated DOD's ability to plan and execute complex
drawdown operations. Several contributing factors enabled the
successful reduction of military forces to 50,000 in accordance with
the August 31, 2010 time line and removal of non-mission-essential
equipment from Iraq.
* Use of modeling tools and metrics. The models and projections run by
the Army's Responsible Reset Task Force,[Footnote 17] ARCENT
Comptroller staff, and the CENTCOM Deployment Distribution Operations
Center helped to more accurately predict the personnel and cargo flows
out of Iraq, enabling the positioning of necessary resources and as a
whole ensuring that sufficient capacity was in place to meet logistics
requirements. Based on the known amount of equipment in Iraq, USF-I,
in conjunction with other DOD organizations, set monthly targets for
the reduction of rolling and containerized nonrolling stock,[Footnote
18] and DOD organizations in Kuwait created and refined a set of tools
to track the activities conducted to meet these targets and provide
the visibility necessary to make adjustments. For example, Army field
support brigade and Responsible Reset Task Force personnel worked
together to refine the flow chart used to track the movement of
equipment through the critical nodes associated with the retrograde of
equipment through Kuwait, such as wash racks, that could become
limiting factors if stressed beyond capacity.
* Emphasis on end-to-end equipment movements. DOD took steps to ensure
that non-mission-essential equipment removed from Iraq to Kuwait
received rapid disposition. When we visited Kuwait soon after the
completion of this prior phase, the equipment lots were orderly and
largely empty because equipment had been shipped to its final
destination, such as Afghanistan or the United States, with the
exception of the lot dedicated to the storage of Mine Resistant Ambush
Protected vehicles. Further, ARCENT was actively reducing the backlog
of containers at the lot reserved for unserviceable equipment
unloading and sorting. Further, by the time of our visit in March
2011, DOD had resolved the problems that had resulted in nearly 60
frustrated[Footnote 19] containers languishing in one lot we found
during our visit to Kuwait in September 2010. The frustration was
primarily due to lack of customs documentation and poor container
packing practices associated with a pilot program to send
unserviceable equipment directly to a depot in the United States.
* Employment of commercial shipping and alternative air ports for the
removal of equipment and redeployment of personnel. DOD's use of
commercial "door-to-door"[Footnote 20] shipping through Jordan and, to
a lesser extent, Iraq itself, for the majority of nonsensitive unit
equipment, and the use of Al Asad Air Base in Iraq for unit
redeployments directly to the United States successfully alleviated
pressure on the Kuwait-based redeployment and retrograde
infrastructure. For example, DOD officials we spoke with in September
2010 after the previous phase of the drawdown noted that approximately
30 percent of containerized cargo went through the Jordanian port of
Aqaba, while 20 percent went through the Iraqi port of Umm Qasr.
* Successful pilot of the partial self-redeployment concept. Partial
self-redeployment of equipment and personnel consists of a military
unit "road marching" from its location in Iraq to camps in Kuwait.
During the road march, which is conducted as a military operation, the
unit drives its own vehicles and provides for its own security, rather
than scheduling movements for these vehicles via contracted
transportation. As usual, the unit arranges for the shipment of its
non-sensitive equipment via door-to-door moves through ports in Jordan
and Iraq. DOD employed this concept with the 4th Stryker Brigade, 2nd
Infantry Division, which departed Iraq in August 2010, just prior to
the change of mission. According to DOD officials, partial self-
redeployment reduces demand on critical transportation assets and will
be employed during the current drawdown of forces.
Current Drawdown Plans and Execution Status:
DOD has conducted robust planning for the sequence of actions
necessary to achieve its objectives for the drawdown. As they have for
prior drawdown phases, the major commands involved in conducting the
drawdown have issued extensive written plans. In particular, USF-I
issued its Operations Order (OPORD) 11-01 and ARCENT issued its
supporting OPORD 11-01. These plans include many annexes, appendixes,
and tabs that provide a high level of detail. For the first time USF-
I's operations order includes an annex W that addresses the
operational contract support issues specific to the drawdown, such as
contract descoping and contractor demobilization.[Footnote 21] Among
many other things, these plans include detailed roles,
responsibilities, and tasks for military units and logistics staffs
that pertain to completing the retrograde and transfer of equipment
and necessary base transitions by the established dates. For example,
these plans and their supporting documentation set forth the order of
base closures and time lines that must be met to achieve operational
objectives. Other planning materials go into further details on the
ways DOD plans to achieve its objectives for the drawdown. For
example, USF-I's "Base Closure Smart Book" provides a series of
templates, instructions, and operating procedures that cover the
entire base transition process.
DOD continues to use the war-gaming process to further refine the
sequence of drawdown actions and to identify and mitigate associated
resource shortfalls. In particular, DOD employs "rehearsal of concept"
drills, synchronization conferences, and focused "deep dive" analyses
to round out its drawdown planning activities. For example, DOD has
held several rehearsal of concept drills in Kuwait and Iraq that focus
on the logistics aspects of the current drawdown phase, which are
attended by senior leadership and planning officials from USF-I,
ARCENT, other Army staff and components, as well as various elements
within the Office of the Secretary of Defense, and State Department
personnel, among others. During these conferences, attendees study all
the steps the various commands will have to take to meet the drawdown
objectives to reveal any outstanding issues and unmitigated risks and
determine solutions. For example, during the ARCENT-hosted rehearsal
of concept drill held in March 2011, participants analyzed the amount
of equipment that will have to be moved every week between March and
December 2011 and matched these requirements with available capacity.
Such conferences provide a process by which planners are able to
reschedule equipment movements to less demanding periods should
requirements exceed available resources and capacity at a particular
time and set the stage for ongoing monitoring of key indicators such
as Redistribution Property Assistance Team (RPAT) capacity.[Footnote
22] Under the process, should key resources such as transportation
assets still be deemed insufficient, participants can set decision
points for acquiring additional capacity. In addition, participants
can take steps to synchronize key activities, including ensuring that
services like those provided by Defense Logistics Agency-Disposition
Services, which conducts disposal, demilitarization, and re-
utilization of unserviceable equipment, do not end before or while
they are still needed to facilitate the drawdown.
DOD has made substantial progress in executing the drawdown since our
April 2010 report and the current phase of the drawdown is well under
way. In terms of military personnel and contractors, 46,000 and 61,000
continue to conduct operations or work under DOD contracts out of pre-
drawdown levels of 134,100 and 125,163 respectively, as of June 2011.
In regards to equipment, as of May 2011 DOD had retrograded 2.36
million pieces since May 2009, or approximately 69 percent of the
amount of equipment that was in Iraq in May 2009. Of the total number
of bases, DOD had closed or transitioned 452, leaving 53. According to
senior DOD officials, base transition activities are proceeding ahead
of schedule and U.S. forces are proactively removing nonmission
essential equipment and materiel such as excess ammunition, although
the level of effort required to complete the transition of the
remaining bases will be higher than it has been for the smaller bases
that have closed to date. In addition to the retrograde of equipment,
DOD continues to make progress in transferring equipment to the
Government of Iraq, with over 38 percent of about 48,000 items of
equipment provided to Iraq as of May 2011 under the United States
Equipment Transfer to Iraq program.[Footnote 23] DOD intends to
complete all of its planned transfers, excluding Foreign Excess
Personal Property, by December 2011. For the category of non-excess
equipment for which DOD obtained special statutory authority to
transfer, on which we have previously reported,[Footnote 24] senior
DOD officials state that the department has requested an extension of
the relevant authority as part of its fiscal year 2012 legislative
proposals, which they state will help ensure the completion of these
transfers as planned. Figure 1 shows the personnel and equipment that
has been retrograded during all prior drawdown phases, as well as what
remains for DOD to redeploy, retrograde, or transfer, as appropriate,
prior to December 31, 2011.
Figure 1. Drawdown Progress Since May 2009 and What Remains to Be
Drawn Down through December 31, 2011:
[Refer to PDF for image: stacked horizontal bar graph]
Bases[A]:
Drawn down since May 2009: 288 (84%);
To be drawn down through Dec. 31, 2011: 53 (16%).
Non-rolling stock[B]:
Drawn down since May 2009: 2,376.125 (70%);
To be drawn down through Dec. 31, 2011: 1,023,875 (30%).
Rolling Stock[C]:
Drawn down since May 2009: 24,663 (60%);
To be drawn down through Dec. 31, 2011: 16,125 (40%).
DOD Contractor Personnel[D]:
Drawn down since May 2009: 64,163 (51%);
To be drawn down through Dec. 31, 2011: 57,000 (49%).
U.S. Forces[E]:
Drawn down since May 2009: 88,100 (66%);
To be drawn down through Dec. 31, 2011: 46,000 (34%).
Source: GAO analysis based on DOD data.
[A] Assumes that all USF-I run bases will transition by December 31,
2011. Data current as of July 2011. (Note: While plans for the post-
2011 U.S. Government presence in Iraq call for DOD and State personnel
to continue operating at some of the current USF-I base locations,
these bases will still need to transition to the Government of Iraq.)
[B] Assumes that all non-rolling stock intended for retrograde will be
removed from Iraq by December 31, 2011. Data current as of March 2011.
[C] Assumes that all military rolling stock will be removed from Iraq
by December 31, 2011. Data current as of March 2011. (Note: Military
rolling stock that State is planning to use in support of its post-
2011 Iraq presence, such as MRAPs, are not included.)
[D] Assumes that the number of contractor personnel supporting DOD
contracts in Iraq will reduce to approximately 4,000 by December 31,
2011. Data current as of June 2011.
[E] Assumes that all military personnel, excluding the number
identified by DOD as intended to remain to fulfill Office of Security
Cooperation-Iraq (OSC-I) tasks, will leave Iraq by December 31, 2011.
Data current as of June 2011.
[End of figure]
Logistical Challenges Characteristic of the Current Drawdown Phase:
Beyond the uncertain security environment and potential for increased
violence as indicated earlier, which could affect DOD's retrograde
operations and base transitions, DOD will face greater risks and
challenges to its ability to complete the current drawdown phase than
it faced earlier at least in part due to three primary factors:
* DOD will have less operational flexibility. Like the prior drawdown
phase, the current phase will peak during the final months before DOD
intends to achieve its operational objectives. During the prior
drawdown phase, DOD set monthly equipment retrograde targets to
achieve a notional goal for amount of equipment remaining in Iraq by
August 31, 2010, but had the ability to address any unanticipated
requirements after that date. However, in this final phase, DOD must
now achieve its equipment retrograde goals by a specific date and, as
a result, cannot leave United States forces' equipment in Iraq to be
dealt with after December 31, 2011. DOD therefore lacks the
flexibility it was able to draw upon in retrograding equipment during
the prior drawdown phase in case unexpected challenges arise.
* Equipment retrograde and base transition requirements are greater
than during prior drawdown phases. DOD will need to move and transfer
a larger amount of equipment during the current phase of the drawdown
than in the prior drawdown phase. For example, the unit responsible
for processing theater-provided equipment for retrograde estimated
that it will have to process an amount of this equipment four times
greater than the amount associated with the prior drawdown phase.
Further, DOD has yet to complete the transition of any of its large
bases.[Footnote 25] Of the 53 bases remaining to be transferred in
Iraq, 11 are considered large bases. All of these transitions are
projected to occur prior to December 31, 2011, after which the current
Security Agreement ends. According to DOD officials, each of these
remaining base transitions will be more complex, time consuming, and
likely ripe for unanticipated challenges than such transitions have
been to date due to the scope of activities necessary to complete the
transitions.
* DOD will have fewer available resources. DOD's infrastructure in
Iraq that supports its equipment retrograde and base transition
efforts, such as materiel handling equipment and military personnel,
will simultaneously decrease as USF-I exits Iraq. Base-level personnel
with whom we met expressed serious concerns with the sufficiency of
military, civilian, and contractor personnel to set the conditions for
transitioning the base according to the schedules required by USF-I's
plan. For example, officials were concerned that as living standards
decrease on bases in Iraq and new job opportunities open elsewhere,
contractors will be unable to remain fully staffed and thus less
likely to complete their work and demobilize by the required date. In
addition, DOD officials cite the collapsing support infrastructure in
Iraq as a challenge for the current phase, noting concerns regarding
the availability of key transportation resources, such as aviation
assets, flatbed trucks, and heavy equipment transporters.
DOD's Drawdown Plans and Processes Reduce Risk, but DOD Faces
Challenges Associated with Limited Visibility and Data Pertaining to
Some Equipment:
Because DOD has fewer resources with which to meet a higher level of
requirements amidst less operational flexibility, existing challenges
associated with unanticipated requirements may be magnified. However,
according to DOD officials, flexibility inherent to the plans and
planning processes discussed earlier in this report mitigate the lack
of operational flexibility and challenges inherent to doing more with
less. For example, according to these officials, written modifications
to plans through fragmentary orders and an adjustable requirements
projection process allow for continual updates and adjustments
necessary as conditions change. In addition, USF-I officials cite
further risk mitigation built into current planning, such as 30 days
of additional time added to each of the remaining bases' transition
schedules to account for unanticipated delays. In addition, senior DOD
officials cite as risk mitigation the raising of the dollar value
limit, from $15 million to $30 million per installation,[Footnote 26]
of certain equipment that can be transferred to the Government of Iraq
as Foreign Excess Personal Property in conjunction with a base closure
or return, in accordance with DOD's prioritized excess equipment
disposition process.[Footnote 27] In these ways, DOD accounts for the
fluid nature of the operational environment and unforeseen operational
requirements associated with the current drawdown phase. Notably,
however, last-minute adjustments, such as those made in response to
initially unanticipated retrograde requirements and associated
transportation needs, may increase costs since buying contracted
transportation could be more expensive in the short-term. On the
whole, DOD officials assert the department will meet its objectives
for removing or transferring all equipment by December 31, 2011.
DOD also has been responsive to risks identified via our continued
oversight. For example, during the course of our work, we found that
Army guidance did not make clear whether units can turn unserviceable
equipment in to RPAT yards as opposed to Defense Logistics Agency-
Disposition Services sites. Because redeploying units are typically
very busy, especially if they are leaving a transitioning base, we
found that they were turning such equipment in to RPAT yards because
it is more convenient, according to RPAT officials. However, officials
noted that because units sometimes turn in such equipment without
paperwork and have even removed identifying markings such as serial
numbers to avoid retribution, determining disposition for these items
has been a time consuming and unanticipated challenge for the RPAT
yards. In response to our findings, the Army rapidly issued guidance
to clarify and reinforce the equipment disposition processes for the
drawdown from Iraq, including the turn-in of unserviceable equipment.
[Footnote 28] In addition, according to the Defense Logistics Agency,
Expeditionary Disposal Remediation Teams were established in April
2011 and started traveling with RPAT teams to process unserviceable
assets and train the Army on filling out paperwork for unserviceable
turn-ins. In regards to containers, which is a category of equipment
for which we have previously reported DOD lacked full
visibility,[Footnote 29] USF-I reports that a recent audit in Iraq
found that the container system of record was significantly more
accurate than previously reported to us. Given the reasons for the
poor initial accuracy, including lack of discipline in recording
containers' status as they changed locations, the challenge for USF-I
will be to maintain this level of accuracy as the pace of the drawdown
increases.
Additional Risk Factors:
DOD has taken numerous and robust actions to mitigate the risk to
completing an efficient and orderly drawdown of forces, but continues
to lack real time visibility over contractor-managed, government-owned
(CMGO) equipment[Footnote 30] and does not collect complete data on
the amount of previously unaccounted-for equipment being found as
bases transition, which may increase the likelihood that unanticipated
requirements for retrograding or transferring this equipment will
emerge. Joint doctrine[Footnote 31] cites the importance of joint
logistics environmentwide visibility over logistics resources
(including equipment), describing that visibility as a desired
attribute of logistics information systems, in part, because it
provides the knowledge necessary to make effective decisions. In this
vein, DOD drawdown-related orders highlight such visibility as a
priority for effectively and efficiently achieving drawdown
objectives. For example, one drawdown order identifies the maintenance
of asset visibility as a key task to ensure accountability and to help
reduce cases of fraud, waste, and abuse.[Footnote 32]
Limited Real-Time Visibility over Contractor-Managed Government-Owned
Equipment:
As we previously reported, over time DOD has improved accountability
and visibility for much of its equipment in Iraq but, as of April
2010, continued to face challenges with CMGO equipment.[Footnote 33]
Specifically, officials responsible for property accountability cited
the Federal Acquisition Regulation (FAR) requirement that contractors
track equipment through their own systems as a limiting factor to
these officials' ability to maintain real-time visibility.[Footnote
34] Because these systems are not linked to government systems,
government personnel have been required to periodically request
contractor-tracked information and rely on regular government-
conducted physical inventories to ensure accurate visibility, which
limits such visibility to points in time. Subsequent to our April 2010
review, Headquarters, Department of the Army, Logistics continued to
raise this as a challenge from a drawdown planning and execution
perspective. However, according to officials in the Office of the
Undersecretary of Defense for Acquisition, Technology, and Logistics
responsible for DOD equipment accountability policy, allowing
contractors to track CMGO equipment using government systems as well
as their own systems would remove critical checks and balances, thus
heightening the potential for fraud, and a DOD memorandum suggests
that the establishment of separate accountable property records by DOD
components for contractor-acquired property could increase the
likelihood of double-counting.[Footnote 35] As a result, CMGO
equipment can still only be tracked in real time by government
personnel, such as those responsible for executing the drawdown, after
the equipment has been "delivered" to the government, which often may
not occur until contract performance ends. Therefore, real-time
visibility over this category of equipment during the drawdown remains
an issue.[Footnote 36] For example, USF-I estimated that its
confidence in its total equipment visibility was only 80 percent as of
June 2011, primarily due to shortfalls in its visibility over CMGO
equipment, according to DOD officials. According to Army data, such
equipment comprises over a third of the Army equipment remaining in
Iraq.
To facilitate the drawdown, DOD has taken near-term actions to
mitigate the lack of real-time visibility over CGMO equipment and
improve the management of this property.[Footnote 37] First, USF-I
coordinated with contractors to conduct full property inventories and
submit a property re-allocation plan at least 120 days prior to the
end of the contract performance period. According to senior DOD
officials, all contractors overseen by DCMA have submitted these
plans. These officials stated that the plans provide a starting point
inventory by location and contract of all CMGO property and, according
to DOD, illustrate DOD's ongoing efforts to address CMGO issues.
However, the information on equipment provided by the re-allocation
plans still represents a "point in time" and does not provide real-
time visibility while the assets are re-allocated. Similarly, while
senior DOD officials expect that the results of the latest USF-I-
performed wall-to-wall property inventory, scheduled to complete by
the end of June 2011, will increase the level of confidence in CMGO
visibility beyond the current 80 percent primarily by ensuring that
all similar items, such as fire trucks, are consistently recorded,
such visibility will only be an accurate snapshot as of that date--
before much of this equipment will be leaving Iraq. Second, USF-I's
Contracting Fusion Cell, which was established in March 2011 to
centralize the reporting of contractor demobilization milestones from
all bases within Iraq, manages a new database that tracks contractor
personnel and equipment. According to USF-I officials, the intent is
for the database to provide real-time data so that USF-I can track
over time how much CMGO equipment needs to leave Iraq. However, DOD
officials have expressed concern that the new database faces similar
data reliability and completeness challenges as other systems being
used in Iraq to track contractor information face, as discussed in
more detail later in this report.
DOD's continued need to rely on the results of physical inventories to
obtain accurate planning data may increase the likelihood that
unanticipated requirements associated with the retrograde or transfer
of CMGO equipment will emerge. In particular, as the CMGO equipment re-
allocation, transfer, and retrograde processes continue, previously
unaccounted-for property may be brought to record in a contractor's
accountability system--yet remain invisible to the government unless
it conducts further inventories. According to a senior DOD official,
officials in Iraq recently discovered that one contractor had been
using 200 CMGO trucks it had obtained from another contractor, yet had
never transferred these vehicles to its own property record. Because
these trucks were not on the contractor's list of equipment, they had
not been included in prior inventories. As a result, these trucks were
not factored into DOD's drawdown plans until they were properly added
to the contractor's equipment tracking system and checked by USF-I.
According to DOD officials, USF-I is developing a standard operating
procedure to address abandoned property that contractors might leave
behind and decrease the time to obtain disposition instructions for
such property from months to days, which may help mitigate the risk
posed by unanticipated requirements. Nevertheless, as the number of
forces in Iraq continues to decline, USF-I's ability to conduct
regular equipment inventories may become more limited, and, as a
result, this kind of property may not become visible to drawdown
planners until late in the drawdown process. Senior Army officials
responsible for property accountability expressed concerns that CMGO
equipment that contractors may deliver to the government and abandoned
contractor equipment will comprise the greatest proportion of
unaccounted equipment DOD will need to rapidly address during the
drawdown, likely at the last minute. Some common CMGO items, such as
materiel handling equipment, are expensive, in high demand in
Afghanistan, and take a relatively large amount of resources, such as
transportation assets, to move. DOD officials acknowledge that
accountability and visibility of CMGO equipment needs to be re-
examined and have noted that additional steps, likely in the form of
policy and training, will be required. Without developing a means to
achieve and maintain real-time visibility over critical CMGO property
that retains the important checks and balances inherent to DOD's
current accountability processes, DOD will continue to face challenges
ensuring the efficient retrograde and transfer of such property as it
completes the drawdown in Iraq and begins the drawdown in Afghanistan.
Lack of Complete Data for Found-on-Installation Equipment:
The transition of large bases in Iraq will likely exacerbate the
challenges posed by the lack of real time visibility over CMGO
property. In particular, DOD officials in Iraq remain concerned that
the total amount of previously unaccounted-for equipment that DOD will
need to address will likely increase. For example, after the
completion of one of the largest base transitions to date, USF-I
officials said that they were surprised at the amount of unaccounted-
for equipment that was left over at the end of the transition process.
Beyond CMGO equipment, Army data demonstrates that the increase over
the past 2 years apparent in "found-on-installation"[Footnote 38]
equipment rates is at least partially attributable to base closures in
Iraq, but other factors, including the implementation of the Army's
Property Accountability Campaign,[Footnote 39] have also likely
contributed, according to Army officials. Although Army officials view
this increase positively because the Army can now account for this
equipment, they also told us that Army-tracked found-on-installation
data cannot be used as the sole indicator for leftover unaccounted-for
equipment because such property may also represent equipment that was
not properly entered into the Army's property accountability system of
record due to a lack of proper accompanying documentation. According
to Army officials, USF-I has in the past tracked the amount of
unaccounted-for equipment that was found remaining on bases that
closed. For example, these officials previously identified such
equipment as amounting to between 3 percent and 5 percent of all
equipment on a base. However, based on their communication with USF-I,
these officials now say that USF-I no longer tracks these data. As a
result, DOD drawdown planners may lack an accurate planning factor for
unaccounted-for government equipment and abandoned contractor
equipment left over after the remaining bases in Iraq transition.
Without continuing to track these data, DOD may therefore miss an
opportunity to enhance the fidelity of its drawdown projections and
improve its processes to reduce the amount of such property.
DOD Has Taken Steps to Improve Contract Management and Oversight in
Iraq, but Challenges Remain:
DOD has taken action to improve its management of contracts in Iraq,
such as enhancing contract oversight through command emphasis and
assigning COR responsibilities as a primary duty in certain instances.
However, other concerns, such as lack of experience among contract
oversight personnel, remain. As the drawdown progresses, DOD may face
further challenges in ensuring that major contracts transition without
gaps in key services, and in effectively implementing its guidance for
descoping contracts and demobilizing contractor personnel and
infrastructure. Specific challenges for DOD include providing certain
information, such as base closure dates, to contractors, obtaining
information from contractors such as accurate personnel headcounts,
and ensuring sufficient resources to facilitate full contractor
demobilization.
DOD Has Taken Steps to Improve Contract Management and Oversight but
Some Concerns Remain:
Contract Requirements Management:
DOD has taken steps to address several of our findings related to
issues affecting contract management for the drawdown.[Footnote 40]
For example, we reported in April 2010 that USF-I guidance may not
allow sufficient time for all contracted services needed during the
drawdown to be put on contract in a responsible manner, which could
lead to potential waste and service delays.[Footnote 41] Specifically,
we found that standard operating procedures for requirements
validation in Iraq only stated that personnel should submit
requirements for contracted services at least 90 days prior to the
date that funding is needed. However, this may not allow for
sufficient time to obtain new contracted services and could lead to
inefficient contracting practices. In March 2011, USF-I revised its
financial management guidance to clarify time lines for submitting
packages to the command's requirement validation process.[Footnote 42]
Specifically, the guidance informs units that, for requirements over a
certain dollar threshold, they should consider the time it could take
to obtain bids for new contracts, mobilize contractors, and perform
other tasks associated with validating requirements, and adjust their
submittal plans to USF-I accordingly, potentially 150 to 180 days
before the start of the contract's period of performance. In addition,
USF-I issued an order that informed units to submit requirements to
the Contract Review Board at least 90 days prior to the end of the
contract's period of performance for units with existing contract
options or 120 to 135 days prior to the start of the period of
performance for new contracts.[Footnote 43] Further, by requiring
paperwork for late submissions explaining failure to comply, the order
provides an additional incentive for units to submit their
requirements for contracted services within the specified time frames.
As a result, DOD has taken steps that could reduce the risks of poor
outcomes that may follow from a lack of timely planning for contracted
services, such as undefinitized contract actions,[Footnote 44]
increased costs, lengthened schedules, underperformance, and service
delays.
In addition, we reported in April 2010 that USF-I's predecessor,
Multinational Force-Iraq, had in its drawdown plans delegated the
responsibility for determining contract support requirements to
contracting agencies, such as Joint Contracting Command-Iraq/
Afghanistan (CENTCOM-Joint Theater Support Contracting Command's
predecessor), rather than to operational personnel such as combat
force commanders, base commanders, and logistics personnel, among
others.[Footnote 45] Further, we reported that, in accordance with
joint doctrine and Army guidance,[Footnote 46] when planning for
contractor support, planners must be aware of the operational
principle of centralized contracting management to achieve unity of
effort. We reported that centralized management can be achieved
through means intended to synchronize and coordinate all contracting
support actions being planned and executed in the operational area.
USF-I has taken steps to ensure inclusion and coordination in
determining contract support requirements for contract descoping and
contractor demobilization between contracting support organizations
and operational units. For example, USF-I, in preparation for the
drawdown, issued an order requiring the senior tactical commander at
each base to control and manage the accountability and drawdown of
contracted support on their base.[Footnote 47] The order requires that
these commanders, in conjunction with requiring activities and in
coordination with contracting organizations, identify every service
contract, task order, or service function operating within their base
and determine a cessation date for each service and establish
demobilization milestones. In a different order, USF-I instructed
units to work with contracting organizations to identify and eliminate
duplicate contracted services and to work with the Regional
Contracting Center chief and other contract support organizations to
determine the best contracting approach going forward.[Footnote 48]
Such steps may help DOD improve its unity of effort in contract
management as the drawdown progresses and ultimately concludes.
Contract Oversight:
DOD has also taken steps to improve contract oversight for the
drawdown. For example, DOD has taken some steps to provide a
sufficient number of trained contract oversight personnel to oversee
contracts supporting the drawdown. We previously reported that DOD has
had difficulties providing enough contract oversight personnel to
deployed locations and training military personnel on how to work
effectively with contractors in operations.[Footnote 49] In Iraq, we
spoke with contracting officials from CENTCOM-Joint Theater Support
Contracting Command and several Regional Contracting Centers, as well
as officials from DCMA, LOGCAP, and the Air Force Contract
Augmentation Program, and none reported experiencing contract
oversight personnel shortfalls. DCMA employs a risk-based approach to
contract oversight, allocating oversight personnel, such as CORs, and
more frequent audits for contracts depending on the risk of mission
failure and contractor problems. For example, according to DOD
officials, DCMA has required monthly audits and assigned oversight
personnel to contracts deemed medium to high risk, and depending on
the contract, may conduct an audit every other month for those deemed
low risk. Further, according to senior contracting officials, USF-I
has taken steps to ensure that commanders and other senior leaders
within the chain of command understand the importance of having CORs
available and sufficiently trained to provide oversight during the
drawdown. Several contracting officials said that they have seen an
overall improvement in the following areas:
* Assignment of oversight functions as a primary duty: According to
contracting officials in Iraq, many units recognize the need to have
CORs perform their oversight duties in a full-time capacity.[Footnote
50] For instance, contracting officers responsible for contracts at
Victory Base Complex and Joint Base Balad, a major air base north of
Baghdad, said that units have CORs who work full time on overseeing
contracts, such as the contract to provide bottled water to U.S. bases
in Iraq. We also met with CORs from Air Force and Army units who
stated that their primary roles were to provide contract oversight.
* Command emphasis on oversight: Several contracting officials
attributed improvements in contract oversight to efforts by senior
leaders to place a greater focus on issues involving operational
contract support.[Footnote 51] For example, in October 2010, the USF-I
Commanding General issued a memorandum describing the importance of
the COR's oversight function and the need to ensure that CORs have the
necessary training, time, and experience to perform their duties,
citing our prior work.[Footnote 52]
* Improved training: CENTCOM-Joint Theater Support Contracting Command
(through Regional Contracting Centers) has held regularly scheduled
training in Iraq and Kuwait to ensure that CORs and other contracting
personnel have the training and certification necessary to perform
their contract-related responsibilities. Several CORs told us that
they received a combination of classroom and online instruction, while
others only received online instruction. However, several CORs told us
that they did not find the online instruction to be effective in
preparing them to perform their oversight responsibilities[Footnote
53]. Some were also provided training before they deployed to Iraq.
Senior contracting officials said that they have a surplus of
personnel trained as CORs in Kuwait and Iraq in case additional
oversight personnel are necessary.
* Contractor demobilization preparation: In February 2011, the
Regional Contracting Centers began holding demobilization
orientations, developed by CENTCOM-Joint Theater Support Contracting
Command in conjunction with DCMA, during which contract oversight
personnel can discuss issues affecting contract demobilization, such
as the need to obtain decisions from commanders on which contracts to
descope and when to conduct such actions.
Nevertheless, DOD continues to experience some challenges ensuring
full contract oversight. Army guidance states that CORs usually serve
in their position as an extra duty, depending upon the circumstances,
[Footnote 54] and senior DOD officials told us that assigning COR
responsibilities as an extra duty is desirable because the government
can take advantage of the individual COR's expertise associated with
his or her primary duties. However, Army guidance also recognizes that
it is a key duty that cannot be ignored without creating risk to the
government.[Footnote 55] In addition, USF-I's drawdown guidance states
that units should make every effort to ensure that contracts
considered critical to their mission, or contracts with exceptionally
large footprints, have dedicated COR oversight and, accordingly,
requires units to provide full-time COR support for such
contracts.[Footnote 56] In Iraq during the drawdown, contract
oversight has been hindered in at least some instances in which CORs'
primary duties have limited their ability to concentrate fully on
their contract oversight duties. For example, contractors have
reported to contracting officials instances in which CORs were not
available on site during some of the previous base closures, and their
absence hindered the resolution of certain contractor demobilization
issues. According to an October 2010 Center for Army Lessons Learned
document,[Footnote 57] the quality of inputs from CORs declined during
the previous drawdown as CORs refocused on their primary duties.
However, senior DOD officials noted that the other duties CORs
typically perform, such as force protection, may at times trump their
COR duties.
DOD Faces Challenges in Conducting Major Contract Transitions and
Ensuring Orderly Contractor Demobilization:
Ensuring Continuity of Services during Upcoming Major Contract
Transitions May Be Challenging:
As the drawdown progresses, units may encounter challenges when
transitioning one contract to another. We have previously reported on
contract transition issues as challenges, and one of the major lessons
learned from the prior drawdown phase is the need to synchronize such
transitions with ongoing operations to mitigate the risk of service
disruption.[Footnote 58] In 2010 an Army battalion stationed in
Kuwait, responsible for providing theater sustainment-level
maintenance, experienced a labor strike, service disruptions,
accidents that resulted in deaths, and other challenges that unit
leadership attributed in large part to the transition of a major
maintenance contract. Also contributing to these challenges was the
intensity of operational activities at the time, which included the
peak of efforts needed to complete the prior drawdown phase, the build-
up of forces in Afghanistan, and the reconstitution of the Army's
prepositioned equipment in Kuwait. These challenges added to the unit
missing some required delivery dates for equipment intended for use in
Afghanistan. The extent to which the unit meets required delivery
dates is a key measure of mission success, according to unit
personnel. During our March 2011 visit, several senior military
officials in Kuwait expressed concerns with the transition of the
major line haul (trucking) contract in Kuwait. According to these
officials and DOD data, this contract, which is critical for
transporting equipment between Iraq and Kuwait, is expected to
complete its transition during a period of heightened operational
activity.
The LOGCAP transition in Iraq will also be challenging. In April 2010
we recommended that DOD analyze the benefits, costs, and risks of
transitioning from LOGCAP III to LOGCAP IV and other service contracts
in Iraq to determine the most effective and efficient means for
providing essential services during the drawdown, recognizing that the
department was not required to make the transition.[Footnote 59] DOD
concurred with our recommendation, conducted the analysis, and decided
not to conduct the transition to LOGCAP IV. Unlike during the prior
drawdown phase, however, DOD's only option for maintaining LOGCAP
services in Iraq after December 2011 is to transition to LOGCAP IV and
DOD has approved an internal Action Memorandum to potentially allow
State to use LOGCAP at its sites after 2011 as appropriate and
feasible. Altogether, LOGCAP IV support is planned for 12 sites that
are currently LOGCAP-supported and seven sites, including locations in
Erbil and Basrah, that do not currently have LOGCAP services. After a
projected task order award date of July 31, 2011, the transition will
occur in two phases, with base and life support functions, such as
dining facilities and laundry services, expected to transition first
during a projected 100-day period, followed by transportation and
materiel handling functions.[Footnote 60] The Army projects LOGCAP IV
to have initial operating capability (base and life support) by
October 1, 2011, and full operating capability by December 31, 2011.
Although the circumstances are different, like we found in our April
2010 report, the transition will carry risks. For example, a base in
Iraq is expected to lose its bulk fuel and airfield operations
capabilities needed during the transition until the new LOGCAP
services are in place due to the length of time needed to complete
transition tasks. In addition, because of the amount of work necessary
to prepare sites DOD and State anticipate to be used after December
31, 2011, the existing contractor risks not completing its
construction projects before the transition, according to senior
LOGCAP program management officials. The transition will be made even
more complex by the need to maintain base life support and
transportation services to within days of base closures, according to
LOGCAP program management documentation. Transitioning the
transportation component of LOGCAP will have its own unique
challenges, including a complex and time-consuming property
disposition process and uncertain requirements to support State. To
mitigate such risks, LOGCAP program management is taking steps, such
as working with CENTCOM-Joint Theater Support Contracting Command and
the Contracting Fusion Cell to validate property and material
requirements on a location-by-location basis, according to LOGCAP
program officials. In addition, according to LOGCAP documentation and
a senior DOD official, LOGCAP is projected to transition first at the
seven post-2011 locations where its services are currently not
provided to account for additional complexity associated with standing
up LOGCAP at the new sites. Finally, according to DOD officials,
contractual actions such as period of performance extensions, where
feasible, may help mitigate any potential service gaps.
DOD Has Taken Steps to Descope Contracts and Plan for Contractor
Demobilization, but May Face Challenges in Implementing Its Guidance:
Steps to Plan for Contract Descoping and Contractor Demobilization:
To facilitate the drawdown, DOD has taken steps to plan contract
"descoping," which, for the purposes of this report, we define as a
reduction in services commensurate with declining needs, and
contractor demobilization, which, in the context of the drawdown, we
define as the contractor's actions to reduce and ultimately end its
presence and footprint if not needed to support the U.S. government's
presence in Iraq after 2011. At the theater level, CENTCOM-Joint
Theater Support Contracting Command, under the direction of USF-I,
established the "Contracting Fusion Cell" in March 2011, and USF-I
issued a fragmentary order directing the Cell to centralize the
reporting of contractor demobilization milestones from all bases
within Iraq; measure, assess, and report contractor demobilization
milestones; and provide guidance and assistance to units, staff
elements, and contracting activities as required. Since its
establishment, the Contracting Fusion Cell has participated in a
Rehearsal of Concept drill and a contracting summit to review and
analyze issues affecting contractor demobilization. We attended the
contracting summit and observed USF-I staff, units from across Iraq,
and other stakeholders review major issues concerning contract
requirements and demobilization for participating units and bases. As
mentioned in the previous section, the Contracting Fusion Cell also
employs a database in which division commanders input data on each of
their active contracts, including counts of contractor personnel and
equipment. Several senior military officials said that this database
has been useful in providing data to plan the movements of personnel
and equipment for the drawdown. However, some contracting officials
noted that the same issues that have affected other efforts to capture
accurate and reliable data on the contractor population in Iraq, such
as the general lack of available data for personnel on firm fixed
price contracts and challenges counting contractors that are on leave
or out of the country on emergencies, are likely to affect the
Contracting Fusion Cell's database as well.
Steps to Plan for Contractor Demobilization:
DOD has also improved contractor demobilization planning based on
lessons learned from the prior drawdown phase. According to an October
2010 Center for Army Lessons Learned document, one lesson learned from
the Senior Contracting Official-Iraq was that contractors needed more
guidance regarding closing contractor camps (referred to as
"mancamps") during the prior drawdown phase.[Footnote 61] This
document stated that there were occasions when contractors left Iraq
mancamps and associated facilities without proper close out, abandoned
equipment, failed to repatriate personnel (especially third country
nationals), failed to obtain proper Iraq exit visas, did not return
government furnished equipment, did not close out in the appropriate
contractor accountability system, and did not return badges. Since at
least November 2010, CENTCOM has required all contracts and
solicitations in Iraq to include a templated contractor demobilization
clause that addresses the above-listed issues. CENTCOM-Joint Theater
Support Contracting Command has also developed a template for CORs to
ensure that contractor demobilization plans adhere to certain time
frames. Moreover, USF-I has included in its guidance examples of
cessation of services and contract demobilization schedules and a
demobilization worksheet. However, according to senior contracting
officials, there is no standard demobilization plan that contractors
can submit. To address this shortfall, a senior contracting official
stated in April 2011 that the office of the Senior Contracting
Official-Iraq planned to develop a demobilization plan template for
contractors.
At the unit level, mayor cells[Footnote 62] are working with units,
DOD contracting activities (such as Regional Contracting Centers,
LOGCAP, and DCMA), and contractors performing work on their respective
bases to identify and determine when certain contract requirements can
be reduced and ultimately terminated. For example, the mayor cell for
Joint Base Balad has established a set of milestones and time lines to
descope contracts and demobilize contractors performing work on the
base. One contract planned for descoping involves airfield sweepers.
Joint Base Balad officials said that they plan on reducing the number
of contracted airfield sweepers after the base's fighter (F-16
squadron) mission ends and have also identified a date after which the
services will no longer be needed. Additionally, senior officials in
charge of Contingency Operating Base Marez, a U.S. base in northern
Iraq, are planning to end their contract for security personnel to
coincide with their base transition plans. The Contracting Fusion
Cell, DCMA, and Regional Contracting Centers monitor the progress of
contract descoping and demobilization through tools that track
milestones and time lines for each of their respective contracts. For
instance, these organizations are tracking the submission of
contractor demobilization plans, which are required by a CENTCOM-Joint
Theater Support Contracting Command clause.
Units are taking further steps to ensure the continuity of key
services while continuing to descope contracts. For example, as bases
begin descoping contracts and demobilizing contractor personnel in
preparation for base transition, some units are exploring the option
of using local contractors to provide certain services. According to
senior military officials, since local contractors do not require
extensive base life support, such as housing, and will not have to be
repatriated to their country of origin at the end of the contract,
they can be employed to provide certain services that would otherwise
have to be discontinued. However, we have previously reported on
challenges hiring local national contractors, including the need for
greater oversight due to Iraqi firms' relative lack of experience,
limited capacity and capability, unfamiliarity with U.S. quality
standards and expectations, and lack of quality control processes that
U.S. firms have in place.[Footnote 63] Some units also intend to
replace contractor personnel with servicemembers to ensure continuity
of certain services, such as guard security, airfield vegetation
removal, and generator maintenance and are conducting "troop-to-task"
analysis to determine which servicemembers will perform these tasks
and how many will be needed. For example, the mayor cell at Joint Base
Balad has developed plans to reduce contractor personnel for the
base's incinerator operations and eventually replace them with
servicemembers. Officials from one mayor cell noted that these
additional tasks may further tax unit personnel who are in short
supply and busy meeting other priorities.
Challenges Implementing Contractor Demobilization Guidance:
Although major contractor demobilizations have yet to occur, early
indications suggest that DOD faces several challenges as it implements
its contractor drawdown guidance. DOD has guidance in place to
facilitate the descoping of contract services and contractor
demobilization. In particular, USF-I's drawdown guidance states that
contracting organizations in Iraq are to work with the requiring
activities (typically military units) and base leadership to ensure
all contracts and task orders are adequately scoped to meet mission
requirements and are scheduled to cease or terminate when no longer
required. It also provides time frames by which contractors must be
notified to complete key tasks and cease providing services.[Footnote
64] However, without taking additional steps to address the challenges
discussed below, DOD may be unable to effectively implement its
guidance and ensure the effective reduction of contract services to
appropriate levels and ultimate demobilization of all its contractors.
* Providing information to contractors. Guidance in a USF-I
fragmentary order requires senior tactical commanders at each base to
notify all contractors with the base closure or transition date no
later than 180 days prior to the base closure or transition so the
contractors can start preparing their personnel and equipment for
redeployment. However, LOGCAP program officials were unable to provide
base transition dates to subcontractors because base closure dates and
other information relevant to demobilization are classified, which
limited the contractors' ability to plan their demobilization tasks
such as replacing third country national personnel with local national
personnel to ensure continuity of service while downsizing their
infrastructure. An annex to USF-I's drawdown guidance also states that
in most cases contractors must be notified in writing 45 to 120 days
in advance of the service cessation date. Nevertheless, according to
senior contracting officials, contractors have expressed concerns
about the lack of clarity on when to reduce services and which
contracted services will be needed as USF-I proceeds with the
drawdown. According to senior contracting officials, some contractors
reported instances in which they were notified only a few weeks in
advance to transition to a new location, affecting their ability to
plan. Fluid base transition dates may exacerbate this challenge. For
example, according to a senior contracting official, the date for the
transfer of a U.S. base to the Government of Iraq changed eight times
within 3 weeks, which made it difficult to plan for the termination of
contracts at the base and contractor demobilization.
* Obtaining accurate and sufficient information from contractors.
According to DOD officials, as part of demobilization planning,
contractors submit property re-allocation plans that list property in-
use and excess to the contractors' needs as well as contractors' plans
for re-allocating the property, among other things. Contractors submit
these plans in conjunction with joint government/contractor
inventories conducted 120 days prior to base transition. However,
according to several contracting officials, some contractors had
provided mayor cells with draft or incomplete plans, some of which
contained inaccurate information and incorrect assumptions, on how
they intend to redistribute their property in preparation for base
transitions. USF-I drawdown guidance also requires senior tactical
commanders at every base in Iraq to account for all task orders,
contracts, and service functions on their bases, to include contractor
employee headcount data and report such information on a regular basis
to the Contracting Fusion Cell.[Footnote 65] However, several base
management officials told us that because they do not have direct
contact with or visibility over subcontractors, they cannot ensure
that contractor personnel are not being undercounted during contractor
headcounts, which may hinder planning for the resources needed to
complete contractor demobilization.[Footnote 66]
* Sufficiency of resources to complete contractor demobilization.
According to USF-I guidance, in addition to preparing a demobilization
plan, key tasks that contractors need to perform to complete
demobilization include participating in joint property inventories of
CMGO property at least 120 days prior to base transition, as well as
scheduling and coordinating transportation, among other things.
[Footnote 67] In regards to coordinating transportation, USF-I is
working to include contractor personnel requirements in its planning
but, according to senior contracting officials, contractors have
expressed concerns about the availability of resources to redeploy
their personnel and move their equipment as the drawdown progresses.
Contractors have also expressed concern about their ability to
communicate with government personnel during demobilization, according
to these officials.
DOD and State Are Coordinating to Establish and Support the Post-2011
U.S. Government Presence in Iraq, but Key Elements of This Presence
May Not Be Well Understood throughout DOD:
DOD and State interagency coordination for the transition began late,
but both agencies have now coordinated extensively to plan for the
transfer or loan to State of a wide range of DOD equipment, and DOD
has taken steps to minimize any impact on unit readiness of such
transfers. DOD also has approved an internal Action Memorandum to
potentially allow State to use DOD contracts to obtain services such
as base and life support, food and fuel, and maintenance, as
appropriate and feasible within funding constraints, but agreements
between State and DOD have not been finalized and State may not have
sufficient funding or capacity to oversee these contracted services.
Further, State is taking steps to replace services that DOD will no
longer provide, but these services will be different because State's
mission in Iraq will be different than DOD's mission. In terms of
scope, DOD plans a robust post-2011 presence as part of an Office of
Security Cooperation operating under Chief of Mission authority.
However, the extent to which DOD's personnel would receive status
protections such as privileges and immunities and the limited nature
of the anticipated engagement model with Iraq may not be fully
understood throughout the department.
DOD Has Coordinated Extensively with State to Plan for the Provision
of Equipment and Contracted Services to Support the Post-2011 U.S.
Government Presence in Iraq:
DOD and State Have Conducted Extensive Interagency Coordination for
the Transition, Although Such Coordination Occurred Late:
In addition to redeploying its military personnel and retrograding or
transferring its remaining equipment, during the drawdown DOD aims to
facilitate the transition to a civilian-led presence in Iraq, and, to
that end, has engaged in formal interagency coordination with State at
various levels within the two departments. One of the principle
objectives of this coordination has been to define State's needs for
external support and determine how DOD can best meet those needs. For
example, DOD and State established the "Ad Hoc Senior Executive
Steering Group on the DOD to State Transition" in September 2010 to
assess State's needs in the logistics and sustainment areas, define
requirements, and manage solutions, in particular those anticipated to
be provided by DOD. Co-chaired by the Deputy Assistant Secretary of
Defense for Program Support and the Deputy Assistant Secretary of
State for Logistics Management, this group meets biweekly. According
to these two officials, the meetings greatly facilitated State's
ability to develop its requirements for DOD support, including
equipment. In addition, both State and, according to DOD officials,
DOD, have designated a senior-level official responsible for the
transition. For example, the State Department Iraq Transition
Coordinator coordinates State's aspects of the transition from
military to civilian operations in Iraq. On the ground in Iraq,
multiple USF-I personnel, including planners and logisticians, are
embedded as liaisons within Embassy Baghdad's Management Cell for
Transition, and interagency transition cells are in place at all sites
that are anticipated to transition to State throughout Iraq. Finally,
USF-I stood up separate working groups for transitioning operations
and base-level sustainment, which include State participation.
Coordination at these multiple levels helped facilitate, for example,
the identification and planning for the 310 out of the more than 1,000
Joint USF-I/U.S. Embassy Baghdad Joint Campaign Plan-specified tasks
DOD currently performs in Iraq that State anticipates assuming after
the transition.[Footnote 68]
The coordination outlined here occurred late in the process and the
delays have made the transition more challenging than it otherwise
could have been, compounding State's relatively limited capacity to
plan, as noted by senior DOD officials and acknowledged by senior
State officials. As a result, for example, State's Inspector General
found that the initial lack of senior level DOD and State officials in
Washington, D.C. dedicated to the Iraq transition process contributed
to the inability of operational level DOD and State officials to
obtain timely decisions on key transition issues.[Footnote 69] During
our travel to Iraq, numerous officials at numerous levels cited the
critical importance of planning early to minimize challenges in
conducting future similar transitions, such as will be necessary in
Afghanistan.
DOD Plans to Provide Military Equipment to State and Has Taken Steps
to Mitigate Impact on Readiness:
DOD and State interagency coordination has facilitated the
identification of State's requirements for DOD equipment and
identified efficient solutions to meet these needs. In an April 2010
memo to DOD, State presented its assessment that it lacked the
resources and capability to provide technology, vehicles, and aircraft
to adequately meet the extreme security challenges in Iraq. The
justification for DOD equipment transfer accompanying the memo
suggested that, without the transfer of DOD military equipment, the
security of State personnel in Iraq would be degraded significantly
and one could expect increased casualties. To that end, according to
State officials, State initially requested about 23,000 individual
pieces of equipment encompassing a wide range of items. To meet these
needs, DOD established an "Equipping Board" with members from the
Office of the Secretary of Defense, Joint Staff, and military
services. According to Equipping Board participants, State's initial
request did not fully reflect the actual capabilities State needed.
These officials said that DOD subject matter experts in areas such as
medical and airfield logistics assisted State officials in defining
State's requirements in these areas, reducing the request to around
3,800 individual pieces of mostly standard military equipment worth
approximately $209 million. In addition to cutting potential costs to
State by reducing the overall number of items requested, the board
also created efficiencies by, for example, substituting requests for
expensive equipment such as new CT scan machines and night vision
goggles for older versions already in Iraq that, while less capable,
will nevertheless meet State's needs, according to DOD officials.
[Footnote 70] In addition to DOD military equipment, State has also
expressed needs for nonstandard[Footnote 71] equipment in Iraq. Aside
from 60 Mine Resistant Ambush Protected (MRAP) vehicles, this
equipment includes mainly low-value items, such as containerized
housing units, desk chairs and other office equipment, which USF-I
plans to transfer after screening the items for USF-I, CENTCOM, and
service requirements. In terms of the number of total items, the scope
of non-standard equipment transfers is projected to be much larger
than the transfer of standard DOD military equipment.
DOD plans to provide military equipment to State through various
means, and for non-excess equipment has taken steps to mitigate any
impact on readiness. According to DOD documentation, 32 percent of the
total State request will be comprised of excess defense articles
provided at no cost, such as collapsible fabric fuel tanks, 7.5-ton
cranes, and speakers; and about 6 percent will be items loaned,
including the MRAPs and biometric equipment; and about 62 percent will
be non-excess equipment provided to State through sales from stock,
including items such as aircraft flares, radios, and medical
equipment. According to DOD officials involved in the process, the non-
excess equipment items for State were assigned a risk level to
determine their potential impact on readiness if transferred. For
example, 101 out of 185 medical item types were deemed to be at high
risk of affecting readiness. According to DOD officials, for the high-
risk items, State intends to pay full acquisition value to facilitate
rapid replacement, versus the low-risk items, for which State plans to
pay depreciated value. In addition, according to DOD officials, DOD
has taken steps to accelerate the procurement of some of the high-risk
items to be transferred to State. Finally, the MRAPs DOD intends to
loan to State are coming out of requirements for Army Prepositioned
Stocks[Footnote 72] rather than unit stocks. According to DOD, these
factors will minimize any impact on unit readiness of transferring or
loaning equipment to State. Remaining issues to be resolved include
determining how to replace loaned equipment that is destroyed or
severely damaged during the course of its use, since, according to DOD
officials, State will likely have to request additional procurement
funding if it determines that a replacement is necessary.
DOD Plans to Provide Contracted Services to State Amidst Concerns
about State's Capacity to Fund and Oversee Them:
In addition to equipment transfers and loans, through the interagency
coordination process, DOD has approved an internal Action Memorandum
to potentially support State's post-2011 presence in Iraq by allowing
State to use DOD contracts to obtain needed services as appropriate
and feasible, but agreements between State and DOD have not been
finalized. First, State anticipates obtaining base and life support
such as dining facility and laundry operations through an order on the
Army's LOGCAP contract. The Army projects that between 4,500 and 5,500
contractor personnel will be necessary to provide these services to
State. Second, State anticipates relying on a DOD contract to provide
100 DOD contractor personnel to maintain some of the equipment
transferred and loaned by DOD, including major items such as vehicles,
under a contract DOD already plans to have in place to support its own
personnel in Iraq. Third, State anticipates obtaining food and fuel
through Defense Logistics Agency contractors. Finally, DOD intends to
provide various capabilities such as information technology support
and the contracted capability to detect incoming rocket or mortar fire
and provide warnings. According to DOD and State officials, using
DOD's existing contracting mechanisms for these services would be more
efficient than if State were to award its own contracts. Documentation
including DOD's initial estimates valued the support requested by
State at about $575 million per year, for which, under the proposed
terms of a draft interagency agreement, State would reimburse DOD.
However, DOD's documentation raised concerns about State's ability to
fund these services, given the amounts designated for these purposes
in State's budget requests.[Footnote 73] According to State, the time
frame for LOGCAP support is subject to negotiation with DOD, after
which it may either award its own contract or use local supply options
if conditions permit.[Footnote 74]
According to State documentation, State currently faces shortfalls in
personnel with sufficient experience and expertise to perform
necessary contract oversight. As a result, State plans to use DOD
support for certain contract management and oversight functions.
[Footnote 75] In particular, the Defense Contract Management Agency
(DCMA) and Defense Contract Audit Agency (DCAA) intend to provide
contract pricing, administration, and audit services for the LOGCAP
contract, and, according to DOD officials, Army Materiel Command has
agreed to provide management functions for the maintenance contract.
Projected requirements for these functions include 47 DCMA personnel
supporting State operations, as well as 3 DCAA and 3 Army Materiel
Command civilians. State would provide CORs to oversee the DOD
contractors. According to State, the COR function is one that is
normally part of the duties of a Foreign Service officer or specialist
position at embassies abroad and CORs are identified as part of the
normal assignment cycle. As of early July 2011, State documentation
identified 35 individuals to perform COR duties associated with 136
LOGCAP oversight areas across locations in Iraq, such as dining
facilities operation and firefighting services. COR positions for 31
oversight areas remained to be filled, including air operations
throughout Iraq.
In addition to receiving contract support through DOD, in some cases
State intends to directly contract for services that it currently
receives through DOD, particularly in the medical, aviation,
information technology, and security areas. For example, State
recently awarded a contract that State documentation indicates will
provide for seven health units, one large Diplomatic Support Hospital,
and three small Diplomatic Support Hospitals in large part to replace
medical services that DOD has provided to date in Iraq. In addition,
State's Bureau of Diplomatic Security will conduct static security
activities at U.S. facilities with only a State presence remaining in
Iraq past December 31, 2011. According to DOD and State officials,
DOD, through CENTCOM, would be responsible for security on the Office
of Security Cooperation-Iraq (OSC-I) sites under the proposed terms of
a draft Memorandum of Understanding between DOD and State.[Footnote
76] According to testimony from the Under Secretary of State for
Management before the Wartime Contracting Commission, static and
movement security for State's Embassy in Baghdad alone will cost
nearly $2.5 billion over the next 5 years. Even with the increase in
such capacity, the drawdown of military forces will result in lost
protective security capabilities for State because State's mission in
Iraq is significantly different than DOD's mission. As a result, State
will rely to a greater extent on the Government of Iraq for certain
types of security activities. For example, State will deploy a "sense
and warn" platform that will allow for advance warning in case of
incoming fire such as rockets and mortars, but will not include the
capability to fire back at the attackers, as DOD currently fields at
its bases--which will become an Iraqi responsibility.
DOD Is Currently Negotiating for Authority for Its Continued Presence
in Iraq, but the Scope of the Proposed Mission and Protections for DOD
Personnel Are Not Well Understood within DOD:
According to DOD and State officials, the scale of the combined DOD
and State presence in Iraq after December 2011 will be unprecedented.
A June 2011 DOD report to congressional committees projected nearly
20,000 DOD contractor personnel to be spread across all post-December
2011 sites in Iraq. However, DOD and State now expect this number to
be lower, and state that current plans call for an estimated total
number of U.S. government direct hires and contractors in the range of
16,000 to 17,000 personnel. As stated recently by a Department of
State official before the House Armed Services Committee, about 14,000
of those personnel will likely be contractor personnel operating under
both DOD and State. According to DOD and State, the expected number of
personnel has changed from the earlier projection due to the fact that
plans are continually being refined and because contracts have since
been awarded. DOD and State expect that the exact number of personnel
in Iraq after December 2011 will continue to change as contracts are
put in place and requirements are further refined. In addition to
providing contract support services to State as discussed earlier, DOD
personnel intend to operate an Office of Security Cooperation-Iraq
(OSC-I), which would be funded by both DOD and State. As of June 2011,
DOD planning documents called for DOD personnel to remain at 10 sites
countrywide.[Footnote 77] Six of these sites would be OSC-I only sites
staffed by DOD personnel and contractors. DOD and State personnel,
including those implementing the police training program under State's
Bureau of International Narcotics and Law Enforcement Affairs, would
be colocated at the four remaining sites. DOD's activities under OSC-I
will include the fielding, administration, and oversight of an
estimated 157 military or civilian personnel and Security Assistance
Teams comprised of 763 military, civilian, or contractor personnel.
According to a report from the State Department's Office of Inspector
General[Footnote 78] and senior DOD officials, OSC-I's mission would
include advising, training, and equipping Iraqi forces, supporting
professional military education; planning joint military exercises;
and managing foreign military sales programs involving $6.1 billion in
Iraqi funds and $2 billion in U.S. funds through the Iraqi Security
Forces Fund. Under this mission, DOD's planned activities include
Security Force Assistance, which is a new subset of security
cooperation described in the 2010 Quadrennial Defense Review as
encompassing activities to train, equip, advise, and assist host
countries' forces in becoming more proficient at providing security to
their populations and protecting their resources and
territories.[Footnote 79] DOD also intends to provide for the
management, security, and sustainment of its sites and some
construction DOD officials refer to as "site improvements" to enhance
the sites' suitability. According to senior DOD officials, with the
exception of one site near the U.S. Embassy in Baghdad, the OSC-I
presence in Iraq will not remain longer than 3 years.
According to senior DOD officials, in the absence of an Iraqi request
for an extended U.S. military presence, the U.S. government is not
attempting to negotiate a Status of Forces Agreement[Footnote 80] with
the Government of Iraq in regards to the post-December 2011 U.S.
presence. Rather than negotiating a Status of Forces Agreement, DOD is
preparing to stand up OSC-I, though it does not yet have final
approval from the Government of Iraq to establish such a presence.
According to State officials, this leaves the Strategic Framework
Agreement as the overarching basis for OSC-I's activities.[Footnote
81] Nevertheless, DOD is proceeding with preparations for the OSC-I
sites, including construction, absent land use agreements with the
Government of Iraq with the assumption that these agreements will be
forthcoming. This carries some risk; for example, State officials
noted that approximately $18 million was obligated to prepare an
Embassy Branch Office in Mosul that was subsequently "indefinitely
postponed" as an enduring site due in part to a lack of buy-in from
the Iraqi government. According to State officials, while State is
working to recoup some of those funds from the contractor, State
officials stated that they expected to recoup only about $8 to $10
million, although the exact amount had not yet been determined.
According to State documentation and senior State officials, as of
June 2011, the Government of Iraq had not formally signed any
agreements for the OSC-I-only sites. According to DOD and State
officials, delays associated with forming a government after Iraq's
March 2010 parliamentary elections have hindered the negotiation of
these agreements. In particular, Iraq continues to lack both a
Minister of Defense and a Minister of Interior with whom to negotiate
these agreements and others.
The scope of DOD's proposed mission in Iraq after 2011 and the extent
to which DOD personnel conducting these activities will be ensured
protections may not be not well understood throughout the department.
According to senior DOD officials and State officials, without a
request from the Government of Iraq for a follow-on U.S. military
presence, all U.S. government activities in Iraq, including those
performed by DOD military, civilian, and contractor personnel, will
occur under Chief of Mission authority, as approved by the National
Security Deputies Committee in May 2010. Additionally, according to
senior DOD and State officials and DOD documentation, DOD and State
anticipate that direct-hire, full-time DOD military and civilian
personnel working under OSC-I can be accredited to the diplomatic
mission as administrative and technical staff, with some status
protections such as privileges and immunities provided under the
Vienna Convention on Diplomatic Relations.[Footnote 82]
Notwithstanding DOD's intent to operate under Chief of Mission
authority, a CENTCOM information paper dated February 2011,
coordinated with DOD's Office of the General Counsel, makes the
assumption that, absent clarification from the Secretary of Defense,
the 157 DOD personnel would operate under the direction of the CENTCOM
commander, rather than the Chief of Mission. The information paper
also raised some questions regarding the feasibility of notifying OSC-
I personnel to the Government of Iraq as part of the administrative
and technical staff. This apparent incongruity has contributed to a
lack of understanding within the Department of the precise scope of
DOD's mission in post-2011 Iraq and the status protections that will
be afforded to DOD personnel. For example, senior DOD officials stated
that a variety of organizations within DOD continue to push for a role
in post-2011 Iraq even though these organizations' activities are not
part of the anticipated engagement model based on Chief of Mission
authority, which, according to those officials, could limit the range
of activities DOD can perform in Iraq. Similarly, due to uncertainty
regarding status protections, Army officials expressed concern that
DOD would be unable to prevent one of its military or civilian
personnel from languishing in an Iraqi jail if, for example, he or she
were to be involved in an accident in which an Iraqi dies. Further,
senior USF-I officials have expressed frustration with differing legal
opinions on such issues. Without officially clarifying these issues or
without a status of forces or other agreement that includes such
details, DOD personnel may lack clarity as to the scope of DOD's
mission in Iraq after December 31, 2011, and the department may be
less able to ensure unity of effort[Footnote 83] among its
organizations and with State in completing the transition to a
civilian-led presence in Iraq. DOD may therefore risk an uncoordinated
approach in defining and implementing the range of activities its OSC-
I personnel will perform.
Conclusions:
The drawdown of U.S. military forces and equipment from Iraq, an
operation governed by the time line set forth in the Security
Agreement, is an operation of unprecedented magnitude, and will occur
amidst an uncertain political and security environment as well as the
ongoing transition to a civilian-led U.S. government presence in Iraq.
Much has been done to facilitate the drawdown. DOD has conducted
detailed planning for the sequence of actions and associated resources
necessary to mitigate risk and to achieve its goals of transferring
and removing personnel and equipment from the remaining bases in Iraq.
In addition, DOD has taken steps to improve its management and
oversight of contracts in Iraq by issuing new guidance, developing
metrics and milestones for tracking key dates and progress,
establishing a cell to provide a common operating picture for all
contracts in Iraq, and working to ensure a sufficient number of CORs
are available to conduct oversight. To help facilitate the transition
to a civilian-led presence in Iraq, DOD has engaged in interagency
coordination with State at various levels, and both agencies are
working closely to coordinate the provision of equipment and services
needed to support the transition. However, without taking further
action in regards to its visibility over CMGO equipment and in
tracking equipment that is brought to record during the completion of
base transitions, DOD may not be able to take advantage of further
opportunities to reduce the likelihood of unanticipated requirements
and to refine its drawdown projections. Further, challenges DOD faces
in implementing its contractor demobilization guidance, including
providing key information to contractors and ensuring robust
contractor demobilization planning, may hinder the base transition
process if contractors miss key dates or demobilize in a less than
orderly fashion. Finally, DOD and State's ability to ensure a timely,
coordinated approach to defining and implementing OSC-I may suffer
absent an official clarification on the scope of DOD's activities in
post-2011 Iraq in accordance with the anticipated engagement model and
the extent to which all DOD government personnel will receive status
protections such as privileges and immunities, since DOD may lack a
status of forces or other agreement after December 31, 2011.
Recommendations for Executive Action:
We recommend that the Secretary of Defense take the following four
actions.
To help ensure that DOD will be able to complete the orderly and
efficient retrograde and transfer of its equipment and transition of
its bases in Iraq by minimizing unanticipated requirements,
* direct the Under Secretary of Defense for Acquisition, Technology,
and Logistics, in conjunction with the Secretary of the Army and the
Commander, U.S. Central Command, to approve and implement, as
appropriate, a process, to include associated policy and training, for
acquiring and maintaining real-time visibility of CMGO equipment
before it is delivered to the U.S. government that meets the needs of
operational forces while retaining oversight features inherent to
DOD's current accountability processes; and:
* direct the Commander, U.S. Forces-Iraq take steps to collect
accurate data on equipment that is found during the large base closure
process but not recorded in any property book, and, as appropriate,
refine the projection for equipment needing to be retrograded and
transferred based on these data.
To maximize its ability to achieve an orderly and efficient drawdown
of contracted services in Iraq, direct the Commander, U.S. Forces-
Iraq, to (1) assess the risk of providing all contractors, including
their subcontractors, with the information--such as base transition
dates--required to descope services and demobilize their workforces,
against the risk of contractors' inability to meet milestones without
it and take the appropriate actions based on this assessment; (2) take
appropriate measures, such as enforcement of guidance laid out in the
template to be developed by the office of the Senior Contracting
Official-Iraq, to ensure robust contractor planning associated with
demobilization; and (3) engage contractors to ensure that total
personnel headcounts accurately reflect all personnel, including those
working under subcontracts.
To ensure that the U.S. government activities in Iraq after December
2011 reflect the appropriate unity of effort and focus DOD and State's
efforts on implementing a coordinated approach to defining and
implementing the activities to be undertaken by OSC-I, issue a
memorandum clarifying the command structure of any DOD elements
remaining in Iraq post-2011 and the scope of DOD activities authorized
in post-2011 Iraq in accordance with an approved engagement model,
including guidance regarding actions or decisions that will be taken
in the event adequate privileges, exemptions, and immunities are not
obtained for such DOD elements.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, DOD concurred with our
four recommendations listed above, but asked that our last
recommendation be reworded to clarify the timing of our
recommendation. We agreed to modify the recommendation to specify that
the guidance should be completed once the engagement model is
finalized. The Department of State also provided a number of informal
technical comments that we considered and incorporated, as
appropriate. The Department of State did not provide formal written
comments.
In its comments regarding our first recommendation, DOD stated that it
agrees that accountability of contractor-managed government-owned
equipment is important. DOD further commented that USF-I has developed
a Base Transition Smart Book that defines CMGO procedures and provides
a series of templates, instructions, and operating procedures that
cover the entire base transition process. While the Base Transition
Smart Book may define CMGO procedures, as we note in our report, these
procedures do not provide real-time visibility over this category of
equipment and we continue to believe that DOD needs to develop a
process which will allow real-time visibility of CMGO equipment before
it is delivered to the U.S. government. Regarding our second
recommendation, DOD commented that it agrees that the collection of
accurate data of found equipment is necessary to refine projections
for equipment retrograde, and noted that the Base Transition Smart
Book provides guidance on how to manage found equipment and update
projections for closure. However, as we note in our report, USF-I no
longer tracks unaccounted-for equipment that was found remaining on
bases that closed. As a result, DOD drawdown planners may lack an
accurate planning factor for unaccounted-for government equipment and
abandoned contractor equipment left over after the remaining bases in
Iraq transition. Therefore we continue to believe that USF-I should
take additional steps to collect data on equipment that is found
during the base closure process, and use this data to refine the
projection for equipment needing to be retrograded and transferred. In
response to our third recommendation, DOD commented that it
acknowledges the risks associated with providing any contractor
critical transition information about base closures and timelines. DOD
said that it will address this risk using a vigorous vetting process
and security background checks. DOD also commented that it will make
certain that demobilization planning captures the associated
requirements concerning contractors and their materiel and it further
noted that the accountability of all contractor personnel, both prime
contractors and their subcontractors, will be maintained through
continued Synchronized Predeployment Operational Tracker (SPOT)
compliance and the periodic contractor census conducted under the
purview of the Commander, U.S. Forces-Iraq. As we have noted in
previous reports, however, agency-reported data in SPOT and the census
should not be used to identify trends or draw conclusions about the
number of contractor personnel due to limitations such as incomplete
and inaccurate data.[Footnote 84] As a result, DOD cannot ensure that
contractor personnel are not being undercounted during contractor
headcounts, and we continue to believe that additional action to
engage with contractors is necessary. Regarding our last
recommendation, DOD concurred with the intent of our recommendation
but asked that we modify the wording of the recommendation to clarify
that the guidance should be developed after the engagement model has
been finalized. We agree with DOD's suggested change and therefore
modified our recommendation accordingly.
The department also provided an informal technical comment that we
considered and incorporated, as appropriate. A complete copy of DOD's
written comments is included in appendix II.
We are sending copies of this report to the appropriate congressional
committees; the Secretary of Defense; the Secretary of State; the
Chairman of the Joint Chiefs of Staff; and the Secretary of the Army.
This report also is available at no charge on our Web site at
[hyperlink, http://www.gao.gov].
Should you or your staffs have any questions concerning this report,
please contact me at (202) 512-8365 or solisw@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix III.
Signed by:
William M. Solis:
Director, Defense Capabilities and Management:
List of Addressees:
The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate:
The Honorable John F. Kerry:
Chairman:
The Honorable Richard Lugar:
Ranking Member:
Committee on Foreign Relations:
United States Senate:
The Honorable Joseph Lieberman:
Chairman:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Howard P. McKeon:
Chairman:
The Honorable Adam Smith:
Ranking Member:
Committee on Armed Services:
House of Representatives:
The Honorable Ileana Ros-Lehtinen:
Chairman:
The Honorable Howard L. Berman:
Ranking Member:
Committee on Foreign Affairs:
House of Representatives:
The Honorable John Tierney:
Ranking Member:
Subcommittee on National Security, Homeland Defense and Foreign
Operations:
Committee on Oversight and Government Reform:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To determine the extent to which the Department of Defense (DOD) has
planned for, begun to execute, and identified and mitigated risks
associated with transferring and removing personnel and equipment from
the bases remaining open past August 31, 2010, we reviewed and
analyzed the major plans that guide the execution of the drawdown,
including those published by U.S. Forces-Iraq (USF-I) and U.S. Army
Central (ARCENT). We also reviewed other relevant documents, including
command briefings, the Security Agreement between the United States
and the Republic of Iraq, as well as DOD joint doctrine. Additionally,
we obtained data and documentation and spoke with officials at many
organizations and levels involved in the preparation and execution of
drawdown plans to include: the Office of the Secretary of Defense, USF-
I, and ARCENT. We also spoke with officials and obtained data and
documentation from a range of supporting commands, including
Headquarters, Department of the Army, Logistics; Army Materiel
Command; Army Sustainment Command; Defense Logistics Agency; Surface
Deployment and Distribution Command; CENTCOM Deployment Distribution
Operations Center; CENTCOM-Joint Theater Support Contracting Command;
Defense Contract Management Agency; Air Force Contract Augmentation
Program; and the Logistics Civil Augmentation Program Office. In
support of this effort, we traveled to Kuwait in September 2010 and
March 2011. We also traveled to Iraq in April 2011. During these trips
we spoke with officials, attended planning conferences, obtained data
and documentation, and observed the processes instituted to facilitate
the drawdown. We also traveled to Sierra Army Depot to observe the
culmination of retrograde operations, as well as to U.S. Army Combined
Arms Support Command to discuss the institutionalization of lessons
learned from the drawdown. To address Department of State issues
impacting the drawdown of forces from Iraq, we obtained documentation
and spoke with officials at the U.S. Department of State as well as
Embassy Baghdad. Throughout the engagement, the team relied upon staff
working from our Baghdad Field Office to conduct interviews with
officials in theater, attend planning conferences, and to periodically
refresh key information.
To determine the extent to which DOD has planned for, begun to
execute, and identified and mitigated risks associated with curtailing
unneeded contract services, transitioning expiring contracts, and
providing adequate contract oversight, we reviewed contracting-
specific planning documents, memoranda, and other sources of guidance
issued by DOD and subordinate organizations. We also met with
contracting officials in Kuwait and Iraq to discuss how military units
in Iraq intended to terminate contracted services and demobilize the
contractor workforce, while maintaining sufficient oversight on
contracts supporting military operations in theater. In addition, we
visited three military bases in Iraq and met with the mayor cells to
obtain information on contract descoping and demobilization issues
specific to those bases and the impact those issues have on the base
transition process. We selected these locations because they are all
large bases and because travel was possible during the time frame of
our visit. We also met with contracting officers' representatives
(COR) from one base to discuss the challenges that they have
encountered in the performance of their contract oversight duties. To
supplement our analysis, we observed several contracted services, such
as debris removal from Camp Victory and incinerator management at
Joint Base Balad, and reviewed plans on how bases intended to end
contracted services and demobilize the contractor work force in
keeping with base transition plans. Further, we observed ARCENT and
USF-I rehearsal of concept drills, a contracting summit organized by
USF-I and CENTCOM-Joint Theater Support Contracting Command, and a
demobilization orientation session to collect information on
contracting issues relevant to the U.S. military withdrawal from Iraq
and the transition to a civilian-led presence in Iraq after December
2011.
To determine the extent to which DOD has planned for, begun to
execute, and mitigated risk associated with facilitating and
supporting the transition to a civilian-led presence in Iraq, we
reviewed transition-specific planning documents, briefings, and
memoranda. We also met with DOD and State officials involved in
transition efforts to discuss how DOD and State were coordinating
efforts, as well as to discuss the status of activities underway in
support of the transition to a civilian-led presence in Iraq. For
example, we met with a team of State officials and military liaisons
at the Embassy in Baghdad responsible for managing the transition. We
also held meetings with the DOD team of officials responsible for
coordinating the provision of DOD equipment to State. In addition, we
discussed transition efforts during our meetings with officials from a
myriad of military commands and DOD organizations, including USF-I,
ARCENT, Army Sustainment Command, Defense Logistics Agency, CENTCOM-
Joint Theater Support Contracting Command, Defense Contract Management
Agency, and the LOGCAP Program Office, among others. To supplement our
analysis, we also met with DOD and State officials involved with
transition work at a large base in Iraq to observe construction status
and to discuss issues associated with the transition. We selected this
location based on its status as a large base and because travel was
possible during the timeframe of our visit. The team also relied on
staff working from the Baghdad Field Office to conduct interviews with
officials in theater involved in transition efforts, as well as to
attend periodic update meetings, and to regularly update key
information.
[End of section]
Appendix II: Comments from the Department of Defense:
Assistant Secretary Of Defense:
Logistics And Materiel Readiness:
3500 Defense Pentagon:
Washington, DC 20301-3500:
September 2, 2011:
Mr. William J. Solis:
Director, Defense Capabilities and Management:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Mr. Solis:
This is the Department of Defense (DoD) response to the GAO Draft
Report 11-774, "Iraq Drawdown: Opportunities Exist to Improve
Equipment Visibility, Contractor Demobilization, and Clarity of Post-
2011 DoD Role," dated August 2011 (GAO Code 351476).
We concur with all recommendations subject to enclosed comments.
The Department appreciates the opportunity to respond to your draft
report and we look forward to working with you to ensure an efficient
drawdown in Iraq. Should you have any questions, please contact Mr.
Kevin Doxey, Kevin.doxey@osd.mil, (703) 693-1685.
Sincerely,
Signed by:
Alan F. Estevez:
Enclosure: As stated:
[End of letter]
GAO Draft Report Dated August 2011:
GAO-11-774 (GAO Code 351476):
"Iraq Drawdown: Opportunities Exist To Improve Equipment Visibility,
Contractor Demobilization, And Clarity Of Post-2011 DOD Role"
Department Of Defense Comments To The GAO Recommendations:
To help ensure that DOD will be able to complete the orderly and
efficient retrograde and transfer of its equipment and transition of
its bases in Iraq by minimizing unanticipated requirements.
RECOMMENDATION 1: Direct the Under Secretary of Defense for Acquisition,
Technology, and Logistics, in conjunction with the Secretary of the
Army and the Commander, U.S. Central Command, to approve and
implement, as appropriate, a process, to include associated policy and
training, for acquiring and maintaining real-time visibility of CMGO
equipment before it is delivered to the U.S. government that meets the
needs of operational forces while retaining oversight features
inherent to DOD's current accountability processes.
DOD Response: Concur. The Department of Defense agrees that
accountability of Contractor-Managed Government-Owned (CMGO) equipment
is important. USF-I has developed the Base Transition Smart Book that
defines CMGO procedures and provides a series of templates,
instructions, and operating procedures that cover the entire base
transition process.
Recommendation 2: Direct the Commander, U.S Forces-Iraq take steps to
collect accurate data on equipment that is found during the large base
closure process but not recorded in the property book, and, as
appropriate, refine the projection for equipment needing to be
retrograded and transferred based on these data.
DOD Response: Concur. The Department of Defense agrees that the
collection of accurate data of found equipment is necessary to refine
projections for equipment retrograde. The Base Transition Smart Book
provides guidance on how to manage found equipment and update
projections for closure.
Recommendation 3: To maximize its ability to achieve an orderly and
efficient drawdown of contracted services in Iraq, direct the
Commander, U.S. Forces-Iraq, to (1) assess the risk of providing all
contractors, including their subcontractors, with the information”such
as base transition dates”required to descope services and demobilize
their workforces, against the risk of contractors' inability to meet
milestones without it and take the appropriate actions based on this
assessment; (2) take appropriate measures, such as enforcement of
guidance laid out in the template to be developed by the office of the
Senior Contracting Official-Iraq, to ensure robust contractor planning
associated with demobilization; and (3) engage contractors to ensure
that total personnel headcounts accurately reflect all personnel,
including those working under subcontracts.
DOD Response: Concur. The Department of Defense acknowledges the risks
associated with providing any contractor critical transition
information about base closures and timelines. The Department of
Defense will address this risk using a vigorous vetting process and
security background checks. Furthermore, the Department of Defense
will make certain that demobilization planning captures the associated
requirements concerning contractors and their materiel. Lastly, the
accountability of all contractor personnel, both prime contractors and
their subcontractors, will be maintained through continued
Synchronized Predeployment Operational Tracker (SPOT) compliance and
the periodic contractor census conducted under the purview of the
Commander, U.S. Forces-Iraq.
Recommendation 4: To ensure that the U.S. government activities in
Iraq after December 2011 reflect the appropriate unity of effort and
focus DOD and State's efforts on implementing a coordinated approach
to defining and implementing the activities to be undertaken by OSC-I,
issue a memorandum clarifying the scope of DOD activities permitted in
post-2011 Iraq in accordance with the approved engagement model, to
include a statement on any limitations on these activities absent a
Status of Forces Agreement and an opinion form DOD's Office of General
Counsel on the extent to which all DOD government personnel will
receive status protections such as privileges and immunities.
DOD Response: Concur. Provided the inclusion of the following
substitution (in quotations): To ensure that the U.S. Government
activities in Iraq after December 2011 reflect the appropriate unity
of effort and focus DOD and State's efforts on implementing a
coordinated approach to defining and implementing the activities to be
undertaken by
OSC-I, "... issue a memorandum clarifying the command structure of DoD
elements remaining in Iraq post-2011, and the scope of DoD activities
authorized in post-2011 Iraq in accordance with the approved
engagement model, including guidance regarding actions or decisions
that will be taken in the event adequate privileges, exemptions, and
immunities are not obtained for such DoD elements."
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO contact:
William M. Solis, (202) 512-8365 or solisw@gao.gov:
Acknowledgments:
In addition to the contact named above, individuals who made key
contributions to this report include Carole F. Coffey, Grace A.
Coleman, Gilbert H. Kim, Anne M. McDonough-Hughes, Jason M. Pogacnik,
David A. Schmitt, Michael Shaughnessy, Michael Willems, and Matthew R.
Young.
[End of section]
Footnotes:
[1] See Agreement on the Withdrawal of United States Forces from Iraq
and the Organization of Their Activities during Their Temporary
Presence in Iraq, U.S.-Iraq, art. 24, ¶ 1, Nov. 17, 2008, Temp. State
Dep't No. 09-6. (Hereinafter Security Agreement.) The Security
Agreement was signed on November 17, 2008 and entered into force on
January 1, 2009. The agreement includes a basic timeline and
requirements for the drawdown of U.S. forces from Iraq. Sometimes
referred to as the Status of Forces Agreement (SOFA), the Security
Agreement is referenced in the Strategic Framework Agreement between
the United States and the Republic of Iraq. See Strategic Framework
Agreement for a Relationship of Friendship and Cooperation, U.S.-Iraq,
§ III, Nov. 17, 2008, Temp. State Dep't No. 09-7.
[2] To date, theater provided equipment has referred to a pool of stay-
behind equipment that has accumulated in Iraq since combat operations
began in 2003. This equipment will need to be removed from Iraq or
transferred before December 31, 2011, like all other DOD equipment.
[3] We use the term "transition" to refer to all activities associated
with turning facilities previously occupied by U.S. forces over to the
Government of Iraq.
[4] On February 27, 2009, President Obama announced that by August 31,
2010, the U.S. mission in Iraq would change from combat to supporting
the Iraqi government and its security forces.
[5] The Security Agreement defines "United States forces" as the
"entity comprising the members of the United States Armed Forces,
their associated civilian component, and all property, equipment, and
materiel of the United States Armed Forces present in the territory of
Iraq." See Security Agreement, art. 2, ¶ 2.
[6] See Security Agreement, art. 24, ¶ 1. Current DOD plans do,
however, anticipate a limited number of military personnel in Iraq
beyond 2011 as part of the planned Office of Security Cooperation-Iraq
(OSC-I). According to DOD officials, these personnel would operate
under the authority of the Chief of Mission pursuant to 22 U.S.C. §
3927, rather than the CENTCOM combatant commander.
[7] We use the term "retrograde" to indicate the removal of military
equipment from Iraq.
[8] Mission capable, as defined by the Department of State, includes
ensuring that all enduring Consulates, International Narcotics and Law
Enforcement sites, and aviation and logistics hubs in Iraq have the
following: secure and protected facilities; secure ground and air
movement; quick reaction capability; communications (to include secure
and unsecure voice and data); access to medical facilities and medical
evacuation; and basic infrastructure and life support.
[9] Section 3927 of Title 22 of the United States Code provides that
the chief of mission to a foreign country shall have full
responsibility for the direction, coordination, and supervision of all
government executive branch employees in the country, except for
certain employees, including those under the command of a U.S. area
military commander. See 22 U.S.C. § 3927(a). The USF-I Operations
Order relating to OSC-I provides for execution of certain functions
pursuant to chief of mission authority for security assistance
activities and command direction from CENTCOM in matters that are not
functions or responsibilities of the ambassador. USF-I Operations
Order No. 11-01, Annex V, Appendix 4 (Jan. 6, 2011).
[10] We are currently conducting a separate assessment of the
transition to a civilian-led presence in Iraq, the scope of which will
include some of these activities.
[11] LOGCAP is a program that provides worldwide logistics and base
and life support services in contingency environments, and is
currently providing most base and life support in Iraq.
[12] Contracting officers' representatives assist in the technical
monitoring or administration of a contract, performing duties
authorized by the contracting officer. See 48 C.F.R. § 1.604. However,
they have no authority to make any commitments or changes that affect
price, quality, quantity, delivery, or other terms and conditions of
the contract. See 48 C.F.R. § 1.602-2(d)(5); § 201.602-2(2)(iv).
[13] GAO, Operation Iraqi Freedom: Actions Needed to Enhance DOD
Planning for Reposturing of U.S. Forces from Iraq, [hyperlink,
http://www.gao.gov/products/GAO-08-930] (Washington, D.C.: Sep.10,
2008).
[14] GAO, Operation Iraqi Freedom: Preliminary Observations on DOD
Planning for the Drawdown of U.S. Forces from Iraq, [hyperlink,
http://www.gao.gov/products/GAO-10-179] (Washington, D.C.: Nov. 2,
2009).
[15] GAO, Operation Iraqi Freedom: Actions Needed to Facilitate the
Efficient Drawdown of U.S. Forces and Equipment from Iraq, [hyperlink,
http://www.gao.gov/products/GAO-10-376] (Washington, D.C.: Apr. 19,
2010).
[16] Contract transition is a general term we use to describe the
process in which the contractor or contract vehicle for a given
contracted service or capability is replaced by another contractor
and/or contract vehicle. For example, contract transition might occur
when contracted services are still needed, but the existing contract
expires and is not extended; the transition might be to a new contract
with the same contractor or a new contract with a different contractor.
[17] The Responsible Reset Task Force assists with the provision of
disposition instructions for materiel retrograding out of Iraq and
synchronizes those instructions with the reset of Army equipment.
Reset refers to the repair, recapitalization, and replacement of
military equipment in order to restore units' equipment to a desired
level of combat capability commensurate with mission requirements and
availability of resources.
[18] Rolling stock is a subset of major end items (Class VII
equipment) and includes wheeled vehicles, tracked combat vehicles,
wheeled/tracked construction equipment, trailers, semi-trailers, and
standard trailer-mounted equipment such as generators.
[19] Frustration, with respect to equipment, refers to a delay in
movement which can be a result of plan changes, missing paperwork, or
a lack of disposition instructions, among other causes.
[20] A door-to-door movement in international transport logistics is
commonly understood to mean the movement of cargo from its point of
origin to its destination. Door-to-door movements involve the intact
movement of a particular cargo and are often associated with a single
transaction in which a commercial logistics service provider
transports the cargo for the whole journey.
[21] Contract "descoping" refers to a reduction in services
commensurate with declining needs. Contractor demobilization, in the
context of the drawdown, refers to a contractor reducing and
ultimately ending its presence and footprint if not needed to support
any U.S. government enduring presence in Iraq.
[22] The Redistribution Property Assistance Team mission is to
facilitate the expedient turn-in of all excess major end items
(theater provided equipment), improve property accountability, and
enable asset visibility of the received equipment.
[23] Under this program DOD transfers equipment to the Government of
Iraq using four authorities; Foreign Excess Personal Property (such as
generators and mattresses), excess equipment (such as older versions
of weapons, vehicles, and body armor), sales from stock (such as spare
parts and ammunition), and non-excess equipment provided under special
statutory authority (811 pieces of equipment such as High Mobility
Multi-Purpose Wheeled Vehicles and trailers).
[24] Among other things, section 1234 of the National Defense
Authorization Act for Fiscal Year 2010 authorized the Secretary of
Defense, with the concurrence of the Secretary of State, to provide
non-excess equipment to the Government of Iraq in certain
circumstances and following notification to certain congressional
committees. See Pub. L. No. 111-84, § 1234 (2009). This authority was
extended in the Ike Skelton National Defense Authorization Act for
Fiscal Year 2011. See Pub. L. No. 111-383, § 1214(a) (2011).
[25] DOD defines its largest bases in Iraq, referred to as Contingency
Operating Bases, as follows. A Contingency Operating Base is usually
occupied by an element larger than Brigade Combat Team size, from a
single service or joint services, and is generally a command and
control hub or a regional logistics hub; characterized by advanced
infrastructure for facilities and communications for the expected
duration of the operations. A Contingency Operating Base may include
an airfield that is C-130 capable or larger. However, according to USF-
I, not all of the bases it considers to be large bases are Contingency
Operating Bases. According to USF-I, they are simply large in relation
to other bases in Iraq.
[26] Memorandum from the Deputy Under Secretary of Defense for
Logistics and Materiel Readiness, Authority to Transfer Foreign Excess
Personal Property In Iraq (Oct. 9, 2009). The authority applies to
property transfers at Forward Operating Bases.
[27] Personal property excess to unit requirements is to be screened
through the chain of command for redistribution opportunities. USF-I
then screens the property across all military organizations, U.S.
contractors supporting the military in Iraq, other U.S. government
organizations in Iraq, CENTCOM requirements, the Department of State,
and the National Association of State Agencies for Surplus Property.
Requirements for property are prioritized in accordance with CENTCOM
priorities as follows: 1. U.S. Forces in support of Iraq; 2. U.S.
Forces in support of Afghanistan; 3. U.S. Department of State in Iraq;
4. National Association of State Agencies for Surplus Property; 5.
U.S. Equipment Transfer to Iraq. Property is not eligible for transfer
to the Government of Iraq as Foreign Excess Personal Property unless
it is excess to all U.S. government requirements, U.S. military
requirements in the CENTCOM area of operations, and any specific
requirements identified by the military services. If there is no U.S.
requirement, then the property is eligible for transfer as Foreign
Excess Personal Property to Iraqi recipients as approved by the
Department of State.
[28] Headquarters Department of the Army Message, Reinforcement and
Clarification of Disposition Instructions in Support of the Iraq
Responsible Drawdown, June 24, 2011.
[29] See [hyperlink, http://www.gao.gov/products/GAO-10-376].
[30] For simplicity, we use the term "contractor-managed government-
owned (CMGO) equipment" to include all items owned or leased by the
government that the contractor manages expressly to perform the
contract, including items given to the contractor by the U.S.
government for performance (government furnished property) and items
acquired, fabricated, or otherwise provided by the contractor for
performance and to which the government has title (contractor acquired
property).
[31] See Joint Chiefs of Staff, Joint Pub. 4-0, Joint Logistics (July
18, 2008).
[32] United States Army Central Operation Order No. 11-01 (Feb. 8,
2011).
[33] [hyperlink, http://www.gao.gov/products/GAO-10-376].
[34] Under FAR clause 52.245-1, where included in the contract, the
contractor must have a system to manage (control, use, preserve,
protect, repair, and maintain) government property in its possession.
See 48 C.F.R. § 52.245-1(b). Generally, the contractor must initiate
and maintain the processes, systems, procedures, records, and
methodologies necessary for effective control of the property,
consistent with voluntary consensus standards and/or industry-leading
practices and standards. See id. The clause specifies a number of
descriptors to be used in its systems and information to be collected.
See § 52.245-1(f). A related provision in the Defense Federal
Acquisition Regulation Supplement (DFARS) suggests a role for the
contracting officer in determining the acceptability of the system and
approving or disapproving of it. See 48 C.F.R. § 245.105(b). However,
according to officials, there is no standardized process for
contractors to maintain accountability over government-owned property.
[35] Memorandum from the Office of the Undersecretary of Defense for
Acquisition, Technology and Logistics, Contractor Acquired Property
(CAP) under Cost Reimbursement Contracts and Line Items (Jan. 11,
2010).
[36] CENTCOM-Joint Theater Support Contracting Command asserted that
USF-I has addressed CMGO property accountability issues by requiring
vendors to conduct a 100 percent inventory of CMGO property. However,
physical inventories do not provide real-time visibility over CMGO
property, as discussed above.
[37] USF-I's Base Closure Smart Book contains guidance on conducting
property inventories of CMGO equipment and the use of property
reallocation plans.
[38] Found-on-installation equipment refers to nonexpendable equipment
that is on-hand and that is not on an accountable record.
[39] The intent of the Property Accountability Campaign is to account
for all Army property and to recover and reintegrate excess equipment
back into the Army supply system for disposition or redistribution. It
includes initiatives such as the fielding of a Property Accountability
Task Force to identify and fill gaps in policy, training, and
resources; command inspections; and the establishment of excess
equipment turn-in programs at Army installations. It also requires
deployed units to accurately record equipment and supplies in their
property books and prevent the return of unauthorized excess property
to home station, and institutes a compliance reporting mechanism for
unit commanders, among other things.
[40] [hyperlink, http://www.gao.gov/products/GAO-10-376]. We have
reported extensively on the use of contractor personnel for combat and
logistics support and the need for improving various aspects of
contract management and oversight. See GAO, Military Operations: High-
Level DOD Action Needed to Address Long-standing Problems with
Management and Oversight of Contractors Supporting Deployed Forces,
[hyperlink, http://www.gao.gov/products/GAO-07-145] (Washington, D.C.:
Dec. 18, 2006); and Military Operations: Contractors Provide Vital
Services to Deployed Forces but Are Not Adequately Addressed in DOD
Plans, [hyperlink, http://www.gao.gov/products/GAO-03-695]
(Washington, D.C.: June 24, 2003).
[41] [hyperlink, http://www.gao.gov/products/GAO-10-376].
[42] USF-I, Money As A Weapons System Theater Financial Management
Policy (Baghdad, Iraq: March 1, 2011).
[43] The Contract Review Board is a USF-I organization that is
intended to review contracts up for renewal with annualized costs
greater than $3 million, new requirements with annualized costs over
$1 million, and construction requirements greater than $750,000.
According to USF-I guidance, this board complements the Joint
Facilities and Acquisition Review Board by providing additional
scrutiny and reporting requirements.
[44] Undefinitized contract actions, where permitted, allow
contractors to begin work before reaching a final agreement on
contract terms and conditions, including price.
[45] As we reported, in Iraq and Kuwait these operational personnel
are responsible for determining the best approach to accomplish their
assigned tasks and, if the approach includes contractors, identifying
the types and levels of contracted support needed.
[46] Joint Chiefs of Staff, Joint Pub. 4-10, Operational Contract
Support (Oct. 17, 2008); Army Field Manual 3-100.21, Contractors on
the Battlefield (Jan. 3, 2003). The field manual has since been deemed
obsolete and has been replaced with Army Tactics, Techniques, and
Procedures No. 4-10 (FM 3-100.21), Operational Contract Support
Tactics, Techniques, and Procedures (June 2011).
[47] USF-I Fragmentary Order No. 2676, Contractor Drawdown Operational
Controls (Feb. 4, 2011).
[48] USF-I Fragmentary Order No. 1056, Contract Right Sizing for RDOF
(Apr. 23, 2010). Although this fragmentary order implemented the
previous drawdown guidance, DOD officials indicated that it was still
in effect.
[49] For more details, see [hyperlink,
http://www.gao.gov/products/GAO-10-376] and GAO, Warfighter Support:
Continued Actions Needed by DOD to Improve Contractor Support in
Contingency Operations, [hyperlink,
http://www.gao.gov/products/GAO-10-551T] (Washington, D.C.: March 17,
2010).
[50] We previously reported that contract oversight personnel often
had difficulties performing their contract-related duties because of
competing duties. See [hyperlink,
http://www.gao.gov/products/GAO-10-551T].
[51] DOD defines operational contract support as the process of
planning for and obtaining supplies, services, and construction from
commercial sources in support of joint operations along with the
associated contractor management functions.
[52] Memorandum from the USF-I Commanding General, Contracting
Officer's Representatives (COR) Vigilance During Operation New Dawn
(Oct. 18, 2010).
[53] For additional information on COR training, please see GAO,
Operational Contract Support: Actions Needed to Address Contract
Oversight and Vetting of Non-U.S. Vendors in Afghanistan, [hyperlink,
http://www.gao.gov/products/GAO-11-771T] (Washington, D.C.: June 30,
2011).
[54] See Army Tactics, Techniques, and Procedures No. 4-10 (FM 3-
100.21), Operational Contract Support Tactics, Techniques, and
Procedures (June 20, 2011).
[55] Army Tactics, Techniques, and Procedures No. 4-10.
[56] See USF-I Operations Order No. 11-01, Annex W: Operational
Contract Support (May 15, 2011).
[57] Center for Army Lessons Learned, CALL Lesson of the Day: Senior
Contracting Official-Iraq (SCO-I), CENTCOM Contracting Command Lessons
Learned, October 16, 2010.
[58] See [hyperlink, http://www.gao.gov/products/GAO-10-376] for
information on the challenges we found associated with transitioning
major contracts during ongoing operations and our recommendations.
[59] [hyperlink, http://www.gao.gov/products/GAO-10-376].
[60] While a draft copy of this report was at DOD and State for
comment, a task order was awarded under LOGCAP, but the award was
protested and has yet to be resolved, as of September 1, 2011.
[61] CALL, CALL Lesson of the Day: Senior Contracting Official-Iraq
(SCO-I), CENTCOM Contracting Command Lessons Learned (Oct. 16, 2010).
[62] Mayor cells are comprised of military unit personnel with the
responsibility for managing and maintaining installations.
[63] [hyperlink, http://www.gao.gov/products/GAO-10-376].
[64] USF-I OPORD 11-01 Annex W, Operational Contract Support (Jan. 6,
2011).
[65] USF-I FRAGO 2676; USF-I OPORD 11-01 Annex W, Operational Contract
Support (Jan. 6, 2011).
[66] As a further example of the challenge of accounting for
contractor personnel, when closing Forward Operating Base Sykes, a
medium-sized base in Iraq, CENTCOM-Joint Theater Support Contracting
Command said that it found 392 third country nationals when they were
only expecting to find 381. According to CENTCOM-Joint Theater Support
Contracting Command, this was due to a database not being updated by
vendors when they reassigned their workers to other locations during
the course of employment. CENTCOM-Joint Theater Support Contracting
Command said that this issue was being addressed with a new
demobilization clause that was being inserted in contracts with its
vendors. CENTCOM-Joint Theater Support Contracting Command also stated
that it was conducting face-to-face interviews with all of its
contractors to help them understand what is expected with respect to
accounting for contractor personnel.
[67] USF-I FRAGO 2676.
[68] The 2010 Joint Campaign Plan for Iraq is a classified strategic
document composed and approved by top DOD and State officials in Iraq.
The plan includes short-term and longer term objectives in four
specific areas--political, security, economic and energy, and rule-of-
law--and is updated periodically to reflect changes in the environment
in Iraq. GAO has reviewed this plan and its previous versions since
2005, issuing several classified reports.
[69] United States Department of State Middle East Regional Office,
Department of State Planning for the Transition to a Civilian-led
Mission in Iraq, MERO-I-11-08 (Washington, D.C.: May 2011).
[70] According to congressional testimony, the substitution of the
older CT machines saved State $8 million.
[71] Standard equipment refers to those items authorized on a military
unit's modified table of organization and equipment, which documents
the specific types and amounts of equipment Army units are authorized
to have. Nonstandard equipment refers to equipment issued to units
that is not authorized on their modified table of organization and
equipment, and includes a wide range of items such as construction
equipment, materiel handling equipment, flat screen televisions,
certain types of radios, and Mine Resistant Ambush Protected vehicles.
[72] Through their individual programs, each of the military services
maintains preconfigured groups of combat and logistics equipment on
ships and ashore at locations around the world. These equipment "sets"
are intended to speed response times of U.S. forces to operating
locations and reduce the strain on scarce airlift or slower sealift
assets. The Army stores sets of combat brigade equipment, supporting
supplies, and other stocks at land sites in several countries and
aboard prepositioning ships in the Pacific and Indian Oceans.
[73] In the documentation, DOD suggested that if State is unable to
obtain the necessary funding to reimburse DOD for the requested
support, DOD would need to seek new statutory authority and associated
funds.
[74] The Commission on Wartime Contracting in Iraq and Afghanistan has
expressed concerns about State's capacity to effectively manage the
acquisition of services in Iraq moving forward. In our ongoing work
GAO is assessing State's capacity for acquiring services in conflict
environments, such as Iraq, Afghanistan, and Pakistan, where it has a
sustained presence.
[75] As discussed later in this report, according to DOD and State
officials, the scale of the proposed combined DOD and State presence
in Iraq after December 2011 would be unprecedented. In light of this
unprecedented challenge, in a justification and request accompanying
an April 2010 memorandum, State noted that without life support
provided through the Logistics Civil Augmentation Program (LOGCAP)
managed by the Army Sustainment Command, State would be forced to
redirect its resources towards developing, implementing, and
overseeing a massive new life support infrastructure in Iraq. Thus,
recognizing the expertise of DOD, State requested to continue to
receive contract management and oversight support from DOD and to
remain on LOGCAP for the short term, until either local conditions
improved to permit supply and support through more traditional means,
or until State could establish its own life support infrastructure
through its own contractors.
[76] According to State officials, this Memorandum of Understanding
has not yet been finalized.
[77] As acknowledged in DOD documents, operations after 2011 would
require consent from the Government of Iraq.
[78] MERO-I-11-08.
[79] According to DOD documentation, the department may currently lack
authority to fund these activities, as well as those of the 763
contractor personnel comprising the Security Assistance Teams.
[80] Although individual Status of Forces Agreements may differ
greatly, such an agreement generally provides for the status of U.S.
forces in a foreign state. Status of Forces Agreements often describe
the rights and privileges of covered individuals, addressing issues
such as the applicability of the foreign state's criminal and civil
jurisdiction over U.S. armed forces personnel, DOD civilian employees,
and/or contractor personnel working for the DOD. These agreements may
also cover a variety of other topics including entry and exit, arming,
customs, and the applicability of taxes and duties. According to a
Congressional Research Service report, the U.S. Government has
agreements that may be considered status of forces agreements with 126
countries in the world. See Congressional Research Service, Status of
Forces Agreement (SOFA): What Is It, and How Has It Been Utilized?
(Washington, D.C.: Jan. 5, 2011).
[81] The Strategic Framework Agreement for a Relationship of
Friendship and Cooperation between the United States of America and
the Republic of Iraq contains general agreements between the two
countries on a variety of issues, broadly establishing the course of
the future relationship between Iraq and the United States. The
preamble to the agreement affirmed the desire of the two countries to
establish a long-term relationship of cooperation and friendship. See
Strategic Framework Agreement for a Relationship of Friendship and
Cooperation, U.S.-Iraq, Nov. 17, 2008, Temp. State Dep't No. 09-7.
With respect to defense and security cooperation, the Strategic
Framework provides that such cooperation shall be undertaken pursuant
to the Security Agreement. See id. at § III. The Strategic Framework
is not a status of forces agreement, and unlike the Security
Agreement, it does not address topics such as the applicability of
criminal and civil jurisdiction to U.S. armed forces or the
application of Iraqi law.
[82] Generally, the Vienna Convention addresses the operation of
diplomatic missions within receiving states, including the privileges
and immunities afforded various classes of members of the mission
staff. See Vienna Convention on Diplomatic Relations, Apr. 18, 1961,
22 U.S.T. 3227, 500 U.N.T.S. 95 (entered into force with respect to
the U.S. Dec. 13, 1972). Under the Vienna Convention, administrative
and technical staff of the mission enjoy several privileges and
immunities, including: freedom from arrest or detention; inviolability
of person, papers, and property; immunity from the receiving State's
criminal jurisdiction; immunity from the receiving State's civil and
administrative jurisdiction, except for acts performed outside the
course of their duties; and exemption from certain dues and taxes. See
id., art. 37, ¶ 2, arts. 29-35. Under article 10, the receiving state
must be notified of the appointment of members of the mission. See
id., art. 10. Senior DOD officials suggested that the only thing the
Vienna Convention does not guarantee is the right of military
personnel to carry a gun or wear their uniforms. State maintained
that, if permitted by Iraqi law, OSC-I personnel may wear uniforms
and, as appropriate, carry weapons.
[83] Unity of effort requires coordination and cooperation among all
forces toward a commonly recognized objective, although they are not
necessarily part of the same command structure. Joint Publication 1,
Doctrine for the Armed Forces of the United States (Mar. 20, 2009).
[84] GAO, Iraq and Afghanistan: DOD, State, and USAID Cannot Fully
Account for Contracts, Assistance Instruments, and Associated
Personnel, [hyperlink, http://www.gao.gov/products/GAO-11-886]
(Washington, D.C.: Sep. 15, 2011).
[End of section]
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