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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

July 2009: 

Electronic Records Archive: 

The National Archives and Records Administration's Fiscal Year 2009 
Expenditure Plan: 

GAO-09-733: 

GAO Highlights: 

Highlights of GAO-09-733, a report to congressional committees. 

Why GAO Did This Study: 

Since 2001, the National Archives and Records Administration (NARA) has 
been developing an Electronic Records Archive (ERA) to preserve and 
provide access to massive volumes of electronic records independent of 
their original hardware and software. The ERA system is to include a 
base system for federal records and a separate system for presidential 
records, known as the Executive Office of the President (EOP) system. 
The 2009 Omnibus Appropriations Act requires NARA to submit an 
expenditure plan for ERA to congressional appropriation committees. GAO’
s objectives were to (1) determine whether NARA’s fiscal year 2009 plan 
meets the legislative conditions set forth in the 2009 Omnibus 
Appropriations Act, (2) provide an update on NARA’s progress in 
implementing recommendations made in GAO’s review of NARA’s 2008 
expenditure plan, and (3) provide any other observations about the 
expenditure plan and the ERA acquisition. To do this, GAO reviewed the 
expenditure plan, interviewed NARA officials, and reviewed program data 
and documentation. 

What GAO Found: 

NARA’s fiscal year 2009 expenditure plan satisfies the six legislative 
conditions in the 2009 Omnibus Appropriations Act. 

NARA implemented one of GAO’s prior recommendations and partially 
implemented the other. Specifically, NARA developed a risk mitigation 
plan for the EOP system in the event that it was not ready in time for 
the presidential transition in January 2009. In addition, NARA began 
including summaries of performance against ERA cost and schedule 
estimates in its monthly reports to Congress. However, during its 
review, GAO found methodological weaknesses that could limit NARA’s 
ability to accurately report on program cost, schedule, and performance 
(see below). 

GAO made four observations on NARA’s expenditure plan and the ERA 
acquisition: 

* The expenditure plan does not specifically identify whether completed 
system increments include all planned functionality or what 
functionality will be included in future increments, including the 
outcomes NARA expects from the remainder of its fiscal year 2009 
funding. Until NARA fully describes the outcomes expected from this 
funding, Congress will lack important information for evaluating the 
agency’s requests for funds. 

* The expenditure plan states that it relies on Earned Value Management 
(EVM), a tool for project management intended to provide objective 
reports of program status. However, NARA is not fully implementing 
practices necessary to make effective use of EVM, limiting the 
reliability of its progress reports. Without consistently following 
these best practices, NARA will be hindered in accurately monitoring 
and reporting on the cost, schedule, and performance of the ERA system. 

* Although NARA certified initial operating capability for the EOP 
system in December 2008, less than 3 percent of the electronic records 
from the Bush Administration had been ingested into the system at the 
time of GAO’s review, and NARA did not expect the remainder to be 
ingested until October 2009. In the interim, NARA is using systems 
developed in accordance with its risk mitigation plan to support the 
search, processing, and retrieval of presidential records. These 
systems cost less than $600,000, compared with the $40 million NARA has 
obligated for the EOP system. Until NARA completely ingests the Bush 
Administration records into EOP, it will be unable to use the system 
for its intended purpose. 

* NARA lacks a contingency plan for the ERA system in the event of a 
failure or disruption. While NARA identified 11 security weaknesses 
related to contingency planning during system testing and planned 
actions to address them, it has completed only 1 of the 11 planned 
actions. Further, NARA does not have a fully functional backup and 
restore process for ERA, a key component for ensuring system 
availability. Until NARA fully develops and tests a contingency plan, 
it risks prolonged unavailability of the ERA system in the event of a 
failure or disruption. 

What GAO Recommends: 

GAO is recommending, among other things, that NARA take steps to 
improve the information in its expenditure plan and progress reports. 
In comments on a draft of this report, the Acting Archivist agreed with 
four of the five recommendations and outlined steps NARA was taking to 
address them. 

View [hyperlink, http://www.gao.gov/products/GAO-09-733] or key 
components. For more information, contact David A. Powner at (202) 512-
9286 or pownerd@gao.gov. 

[End of section] 

Contents: 

Letter: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Briefing to Staff of Congressional Committees on NARA's 
Fiscal Year 2009 Expenditure Plan: 

Appendix II: Comments from the National Archives and Records 
Administration: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Abbreviations: 

EAC: estimate at completion: 

EOP: Executive Office of the President: 

ERA: Electronic Records Archive: 

EVM: Earned Value Management: 

FISMA: Federal Information Security Management Act: 

IOC: initial operating capability: 

NARA: National Archives and Records Administration: 

NIST: National Institute of Standards and Technology: 

OMB: Office of Management and Budget: 

SA-CMM: Software Acquisition-Capability Maturity Model: 

SEI: Software Engineering Institute: 

WBS: work breakdown structure: 

[End of section] 

United States Government Accountability Office: Washington, DC 20548: 

July 24, 2009: 

The Honorable Richard J. Durbin: 
Chairman: 
The Honorable Susan M. Collins: 
Ranking Member: 
Subcommittee on Financial Services and General Government: 
Committee on Appropriations: 
United States Senate: 

The Honorable José E. Serrano: 
Chairman: 
The Honorable Jo Ann Emerson: 
Ranking Member: 
Subcommittee on Financial Services and General Government: 
Committee on Appropriations: 
House of Representatives: 

Since 2001, the National Archives and Records Administration (NARA) has 
been developing an Electronic Records Archive (ERA) to preserve and 
provide access to massive volumes of electronic records independent of 
their original hardware or software. NARA plans for the system to 
manage the entire life cycle of electronic records, from their 
ingestion through preservation and dissemination to customers. 

The system is being deployed in phases, or increments, and is to 
include a "base" system for federal records and a separate system for 
presidential records, referred to as the Executive Office of the 
President (EOP) system. According to NARA, the first increment of the 
base system achieved initial operating capability (IOC) in June 2008. 
NARA certified IOC for the EOP system in December 2008. 

As mandated by the 2009 Omnibus Appropriations Act,[Footnote 1] NARA is 
required to submit an expenditure plan to congressional appropriations 
committees before obligating multi-year funds for the ERA program. In 
March 2009, NARA finalized the expenditure plan to support its request 
for $67 million in ERA funding for fiscal year 2009, which is comprised 
of $45.8 million in multi-year funds and $21.2 million in single-year 
funds.[Footnote 2] As in the previous year, the plan must satisfy six 
legislative conditions, including a review by GAO. Our objectives in 
reviewing the plan were to (1) determine whether NARA's fiscal year 
2009 expenditure plan satisfies the applicable legislative conditions, 
(2) provide an update on NARA's progress in implementing our prior 
expenditure plan review recommendations, and (3) provide any other 
observations about the expenditure plan and the ERA acquisition. 

To assess compliance with the legislative conditions, we analyzed the 
expenditure plan submitted by NARA in March 2009 and reviewed its 
budget submission to the Office of Management and Budget (OMB), along 
with other program data and documentation. To determine whether NARA 
had implemented our prior recommendations, we obtained and reviewed the 
agency's mitigation plan for the EOP system and its monthly reports to 
Congress. To develop observations on the ERA expenditure plan and 
acquisition, we analyzed the expenditure plan; reviewed agency and 
contractor documents, agency data, and federal guidance; and 
interviewed NARA officials. 

To assess the reliability of computer-generated data used in the 
development of this report, we conducted an on-site review of the ERA 
systems, reviewed Inspector General reports on NARA's financial systems 
and computer controls, interviewed NARA officials about data 
reliability controls, and compared the data to previously reported 
data. Based on these reviews, we believe the data are sufficiently 
reliable for the purposes of this engagement. 

We conducted this performance audit from March 2009 to July 2009 at 
NARA's College Park, Maryland, location and at the Allegany Ballistics 
Laboratory at Rocket Center, West Virginia, 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. 

On May 13, 2009, we briefed your staffs on the results of our review. 
This report transmits the material we used at the briefing and provides 
the recommendations that we made to the Acting Archivist of the United 
States. The full briefing materials, including details on our scope and 
methodology, are reprinted as appendix I. 

In summary, we made the following major points: 

* NARA's fiscal year 2009 expenditure plan satisfies the six 
legislative conditions contained in the 2009 Omnibus Appropriations 
Act. 

* NARA implemented one of the recommendations we made last year and 
partially implemented the other: 

- We recommended that NARA develop a risk mitigation plan to ensure 
indexing and searching of records from the Bush Administration in the 
event that the EOP system was not complete in time for the January 2009 
presidential transition. NARA finalized its plan in November 2008. It 
stated that, in the event that records could not be ingested into EOP 
in a timely manner, NARA intended to acquire hardware and software to 
replicate the systems containing the data and use them to retrieve 
requested records. 

- We recommended that, to improve the utility of information provided 
to Congress, NARA include summary measures of project performance 
against ERA cost and schedule estimates in its monthly reports. In July 
2008, NARA began including this information as an appendix to its 
monthly reports to Congress. However, during our review, we found 
methodological weaknesses that could limit NARA's ability to accurately 
report on program cost, schedule, and performance. 

* We made four observations related to the ERA program and fiscal year 
2009 expenditure plan: 

- Cost, schedule, and performance data in the expenditure plan do not 
provide a clear picture of ERA system progress. The plan does not 
specifically identify whether completed increments included all 
previously planned functionality or what functionality will be provided 
in future increments. For example, the plan does not specify what 
outcomes NARA expects to achieve with the remainder of its fiscal year 
2009 funding. NARA officials attributed the plan's lack of specificity 
to ongoing negotiations with its contractor. Until NARA fully describes 
the outcomes expected for the remainder of the year, congressional 
appropriators will lack information important for evaluating the 
agency's request for ERA funds. 

- NARA's expenditure plan states that it relies on Earned Value 
Management (EVM),[Footnote 3] an important tool for project management 
and control that is intended to provide, among other things, objective 
reports of program status. However, NARA is fully addressing only 5 of 
the 13 practices required to effectively implement EVM, which limits 
the reliability of its progress reports. NARA officials attributed 
these weaknesses, in part, to documentation that did not accurately 
reflect the program's current status. Without consistently following 
these best practices, NARA will be hindered in accurately monitoring 
and reporting on the cost, schedule, and performance of the ERA system. 

- Although NARA certified initial operating capability for the EOP 
system in December 2008, the system is not currently fulfilling its 
intended purpose. At the time of our briefing, less than 3 percent of 
the Bush Administration electronic records NARA received had been 
successfully ingested into the system. NARA officials estimated that 
the records would not be fully ingested until October 2009. Agency 
officials attributed delays in part to unexpected difficulties, such as 
data not being extracted in expected formats and incomplete replication 
of one type of data. In the interim, NARA is primarily supporting 
search, processing, and retrieval of presidential records using the 
replicated systems described in the risk mitigation plan that we 
recommended the agency develop last year, which cost less than $600,000 
to put in place, compared to the nearly $40 million NARA has obligated 
for EOP. Until NARA completely and accurately ingests the Bush 
Administration presidential records into the EOP system, it will be 
unable to use the system for its intended purpose and will incur 
additional costs maintaining the systems it is now using to support 
requests for these records. 

- NARA lacks a contingency plan for the ERA system in the event of a 
system failure or disruption. While NARA identified 11 security 
weaknesses related to contingency planning during acceptance testing 
and listed actions planned to address them, NARA has completed only 1 
of the 11 planned actions. Further, NARA does not have a fully 
functional backup and restore process for the ERA system, a key 
component of planning for system availability in the event of a failure 
or disruption. According to NARA officials, a full system contingency 
plan is under development. However, until such a plan is tested and 
implemented, NARA risks prolonged unavailability of the ERA system in 
the event of a failure or disruption. 

Conclusions: 

While NARA has continued to make progress on the ERA system, that 
progress cannot be fully quantified because NARA's expenditure plan 
does not clearly identify what functions have already been delivered, 
how much was spent to provide each function, or how much is required to 
maintain the delivered increments. NARA's current plan similarly lacks 
details on the functions to be provided in future increments and the 
costs associated with them, including development efforts scheduled to 
take place in the remainder of this year. In addition, although NARA 
has been using Earned Value Management to track program cost, schedule, 
and performance, weaknesses in its EVM data limit NARA's ability to 
accurately report on the project's progress. Without more specific and 
accurate information on the immediate and long-term goals of the 
program and the outcomes expected from its resulting efforts, NARA will 
be hindered in effectively monitoring and reporting on the cost, 
schedule, and performance of the ERA system, and congressional 
appropriators will lack information necessary to evaluate the agency's 
requests for funds. 

Although NARA certified that the EOP portion of the ERA system had 
achieved initial operating capability as planned in December 2008, the 
system has been of limited use because of delays in ingesting 
electronic records into the system. Further, even though it has 
obligated nearly $40 million on EOP, NARA has instead answered requests 
for Bush electronic records by using existing systems or replicating 
White House systems that cost less than $600,000. Under its current 
schedule, the Bush Administration records will not be fully ingested 
into the system until October 2009. However, even when the data are 
fully ingested, the system's lack of a complete, fully tested 
contingency plan increases the risk that a system failure or disruption 
will result in the system being unavailable for several days or more. 

Recommendations for Executive Action: 

We recommend that the Archivist of the United States take the following 
actions: 

* Report to Congress on the specific outcomes to be achieved by ERA 
program funding for the remainder of fiscal year 2009. 

* Provide detailed information in future expenditure plans on what was 
spent and delivered for deployed increments of the ERA system and cost 
and functional delivery plans for future increments. 

* Strengthen the earned value process so that it follows the practices 
described in GAO's guide and more reliable cost, schedule, and 
performance information can be included in future expenditure plans and 
monthly reports. 

* Include in NARA's next expenditure plan an analysis of the costs and 
benefits of using the EOP system to respond to presidential records 
requests compared to other existing systems currently being used to 
respond to such requests. 

* Develop and implement a system contingency plan for ERA that follows 
contingency guidance for federal systems. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, which are reprinted in 
appendix II, the Acting Archivist of the United States stated that she 
appreciated the insight into the expenditure plan observations 
addressed in the report. She stated that she was pleased to note our 
recognition that the Fiscal Year 2009 ERA Expenditure Plan met the 
legislative conditions. In addition, the Acting Archivist summarized 
actions taken or planned in response to four of our five 
recommendations. Specifically, she stated that NARA provided a briefing 
to Congress on the specific outcomes to be achieved by the ERA program 
on April 27, 2009, and that further detail will be added to the next 
expenditure plan to address costs and functions delivered to date and 
what is planned for future increments. She further stated that NARA is 
in the process of upgrading its EVM system and will strive to comply 
with all 13 best practices. Finally, the Acting Archivist stated that 
an ERA Contingency Plan has been developed and is in final review. 

The Acting Archivist disagreed with our observation that the EOP system 
is not currently fulfilling its intended purpose. She stated that this 
observation failed to differentiate between what the system is capable 
of doing and the work currently being done on the system. She added 
that the system does provide required functionality--including 
searching any records ingested in the system--and that all the 
remaining data from the Bush Administration will be ingested by the end 
of the fiscal year. The Acting Archivist also stated that the problem 
was with the copies of the records that NARA received from the White 
House, not with the EOP system, and that the data issues have been 
resolved. We disagree with the Acting Archivist's statements because 
the EOP system still lacks the capability to search and retrieve all 
Bush Administration records in NARA's possession. Specifically, as we 
reported in our briefing, NARA used the EOP system to satisfy one 
request for presidential records during the first 3 months of the 
transition, but used the less expensive replicated systems to answer 
another 24 requests. In addition, before the transition, NARA estimated 
that it would not complete ingesting data until May 2009, limiting the 
capability of the system in the transition's early months regardless of 
the replication errors that ultimately occurred. Finally, the Acting 
Archivist's estimate that the Bush data will not be fully ingested 
until the end of the fiscal year further highlights the fact that NARA 
still possesses Bush Administration electronic records that cannot be 
searched using EOP. Until all the Bush Administration records are 
ingested, the EOP system will not be performing its stated function. 

Regarding our recommendation that NARA include in its next expenditure 
plan an analysis of the costs and benefits of using the EOP system to 
respond to presidential records requests compared to the systems 
currently being used, the Acting Archivist stated that it did not seem 
cost-effective to conduct a retrospective analysis as to whether there 
might have been technology solutions for systems that have already been 
retired. However, NARA has not yet provided evidence that the 
mitigation plan systems have been retired. In addition, we are not 
recommending a study of past alternatives, but a study of the ongoing 
costs and benefits of using the EOP system compared with the technology 
used under NARA's risk mitigation plan. This would provide the agency 
with useful information in planning future spending, given that NARA 
was able to respond to requests for Bush Administration records using 
systems costing significantly less than what has been spent to date on 
the EOP system. Such an analysis could also inform the contingency plan 
the Acting Archivist said is being finalized in response to our 
recommendation. 

We are sending copies of this report to the Archivist of the United 
States. The report will also be available at no charge on the GAO Web 
site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions concerning this report, please 
contact me at (202) 512-9286 or by e-mail at pownerd@gao.gov. Contact 
points for our Office 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. 

David A. Powner Director, Information Technology Management Issues: 

[End of section] 

Appendix I: Briefing to Staff of Congressional Committees on NARA's 
Fiscal Year 2009 Expenditure Plan: Slide presentation: 

Review of NARA’s Fiscal Year 2009 Electronic Records Archive 
Expenditure Plan: 

Briefing for Staff Members of the: 

* Subcommittee on Financial Services and General Government, Senate 
Committee on Appropriations, and; 

* Subcommittee on Financial Services and General Government, House 
Committee on Appropriations: 

May 13, 2009. 

Contents: 
Introduction: 
Objectives, Scope, and Methodology: 
Results in Brief: 
Background: 
Results: 
Conclusions: 
Recommendations for Executive Action: 
Agency Comments and our Evaluation: 
Attachments: 
1. Details on NARA’s EVM Compared with Best Practices. 
2. Comments from the Acting Archivist of the United States. 

[End of section] 

Introduction: 

Since 2001, the National Archives and Records Administration (NARA or 
the Archives) has been working to develop a modern Electronic Records 
Archive (ERA). This major information system is estimated to cost more 
than $550 million and is intended to preserve and provide access to 
massive volumes of all types and formats of electronic records, 
including presidential records, independent of their original hardware 
or software. NARA plans for the system to manage the entire life cycle 
of electronic records, from their ingestion through preservation and 
dissemination to customers. It is to consist of: 

* infrastructure elements, including hardware and operating systems; 

* business applications that will support the transfer, preservation, 
dissemination, and management of all types of records; and; 

* a means for public access via the Internet. 

Because of the system’s complexity, NARA awarded a contract to Lockheed 
Martin to develop ERA in phases, or increments, the first of which was 
originally scheduled to achieve initial operating capability (IOC) in 
September 2007. However, the contractor did not meet the original cost 
and schedule milestones due, in part, to productivity issues with its 
initial development team. 

In response, NARA and Lockheed Martin agreed to a revised schedule and 
strategy, consisting of a two-pronged development approach. 

* First, they agreed to continue development of the original system but 
delayed capabilities to later increments. According to NARA, IOC for 
this system, now referred to as the “base” ERA system, was achieved in 
June 2008 as planned under the revised schedule. 

* Second, NARA conducted parallel development of a separate system 
dedicated initially to receiving electronic records from the outgoing 
Bush Administration in January 2009. This system, referred to as the 
Executive Office of the President (EOP) system, uses a different 
architecture from that of the ERA base: it was built on a commercial 
product that was to provide the basic requirements for processing 
presidential electronic records, such as rapid ingestion of records and 
the ability to search content. NARA believed that if it could not 
ingest the Bush records in a way that supported search and retrieval 
immediately after the transition, it risked not being able to 
effectively respond to requests from Congress, the new administration, 
and the courts for these records—a critical agency mission. NARA 
certified the EOP system for IOC in December 2008. 

As mandated by the Omnibus Appropriations Act,[Footnote 4] NARA is 
required to submit an expenditure plan before obligating multiyear 
funds for the ERA program. As in the previous year, the plan must 
satisfy the following legislative conditions: 

* meet the capital planning and investment control review requirements 
established by the Office of Management and Budget (OMB), including 
Circular A-11; 

* comply with the agency’s enterprise architecture; 

* conform to the agency’s enterprise life-cycle methodology; 

* comply with the acquisition rules, requirements, guidelines, and 
system acquisition management practices of the federal government; 

* be approved by the agency and OMB; and; 

* be reviewed by GAO. 

On March 6, 2009, the agency finalized the 2009 expenditure plan that 
was submitted to the House and Senate appropriations committees to 
support its request for $67 million in ERA funding for fiscal year 
2009, which is comprised of $45.8 million in multi-year funds and $21.2 
million in single-year funds.[Footnote 5] 

[End of introduction] 

Objectives, Scope, and Methodology: 

Our objectives were to: 

* determine whether NARA’s fiscal year 2009 expenditure plan satisfies 
the applicable legislative conditions, 

* provide an update on NARA’s progress in implementing our prior 
expenditure plan review recommendations, and, 

* provide any other observations about the expenditure plan and the ERA 
acquisition. 

To assess compliance with the legislative conditions, we: 

* reviewed NARA’s fiscal year 2009 exhibit 300 submission[Footnote 6] 
to OMB to determine the extent to which the agency has complied with 
OMB’s capital planning and investment control requirements; 

* obtained and reviewed data on NARA’s enterprise architecture to 
determine the status of the agency’s enterprise architecture efforts; 

* reviewed NARA’s enterprise systems development life cycle methodology 
that includes processes for managing system investments, configuration 
management, and risks, and reviewed related documentation concerning 
how these processes were implemented for the ERA project, such as 
minutes of oversight boards and the risk management plan; 

* reviewed internal assessments of ERA; 

* obtained and reviewed OMB’s approval of the expenditure plan; and; 

* reviewed and analyzed the fiscal year 2009 expenditure plan submitted 
by the agency in March 2009. 

To determine the status of our two prior recommendations, we obtained 
and reviewed monthly congressional reports and the EOP mitigation plan. 
We reviewed these documents to determine whether NARA (1) developed a 
risk mitigation plan to ensure indexing and searching of records from 
the Bush Administration in the event that the EOP system was not 
complete in time for the January 2009 presidential transition and (2) 
included earned value data in its monthly reports to Congress. 

To develop observations on the ERA expenditure plan and acquisition, we 
analyzed the cost and schedule information contained in the expenditure 
plan, reviewed agency and contractor documents such as EOP test results—
including acceptance tests and security and risk assessments—and cost 
and schedule reports, and performed analysis of Earned Value Management 
(EVM)[Footnote 7] data and key processes used in NARA’s EVM system. We 
also reviewed federal requirements for contingency planning and NARA 
plans for corrective action on issues identified. In addition, we 
interviewed NARA officials. We did not evaluate the controls over the 
procedures used to transfer records from the White House to NARA or 
controls over processes used to determine which records were 
presidential records. 

To assess the reliability of the cost and schedule information 
contained in the expenditure plan, we interviewed NARA officials in 
order to gain an understanding of the data and discuss our use of the 
data in this briefing. In addition, we compared schedule information in 
the fiscal year 2009 plan with information in the fiscal year 2008 plan 
and the ERA integrated schedule. We did not, however, assess the 
accuracy and reliability of the information reported in these 
documents. 

We conducted this performance audit from March 2009 to May 2009 at 
NARA’s College Park, Maryland, location 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. 

[End of Objectives, Scope, and Methodology] 

Results in Brief: 

NARA’s fiscal year 2009 plan satisfies the six legislative conditions 
contained in the 2009 Omnibus Appropriations Act. 

NARA implemented one of the recommendations we made last year, and 
partially implemented the other: 

* We recommended that NARA develop a risk mitigation plan to ensure 
indexing and searching of records from the Bush Administration in the 
event that the EOP system was not complete in time for the January 2009 
presidential transition. NARA finalized its plan in November 2008. It 
stated that, in the event that records could not be ingested into EOP 
in a timely manner, NARA intended to acquire hardware and software to 
replicate the systems containing the data and use them to retrieve 
requested records. 

* We recommended that, to improve the utility of information provided 
to Congress, NARA include summary measures of project performance 
against ERA cost and schedule estimates in its monthly reports. In July 
2008, NARA began including an Earned Value Summary as an appendix to 
its monthly reports to Congress. However, after reviewing NARA’s earned 
value data, we found methodological weaknesses that could limit NARA’s 
ability to accurately report on program cost, schedule, and performance 
(these weaknesses are discussed further below). 

We have four observations related to the ERA program and fiscal year 
2009 expenditure plan: 

* Cost, schedule, and performance data in the expenditure plan do not 
provide a clear picture of ERA system progress. The plan does not 
specifically identify whether completed increments included all 
previously planned functionality or what functionality will be provided 
in future increments. For example, the plan does not specify what 
outcomes NARA expects to achieve with the remainder of its fiscal year 
2009 funding. NARA officials attributed the plan’s lack of specificity 
to ongoing negotiations with its contractor. Until NARA fully describes 
the outcomes expected for the remainder of the year, congressional 
appropriators will lack information important for evaluating the 
agency’s request for ERA funds. 

* NARA’s expenditure plan states that it relies on Earned Value 
Management (EVM), an important tool for project management and control 
that is intended to provide, among other things, objective reports of 
program status. However, NARA is fully addressing only 5 of the 13 
practices required to effectively implement EVM, which limits the 
reliability of its progress reports. NARA officials attributed these 
weaknesses, in part, to documentation that did not accurately reflect 
the program’s current status. Without consistently following these best 
practices, NARA will be hindered in accurately monitoring and reporting 
on the cost, schedule, and performance of the ERA system. 

* Although NARA certified initial operating capability for the EOP 
system in December 2008, the system is not currently fulfilling its 
intended purpose. Less than 3 percent of the Bush Administration 
electronic records NARA received have been successfully ingested into 
the system. NARA officials estimate that the records will not be fully 
ingested until October 2009. Agency officials attributed delays in part 
to unexpected difficulties, such as data not being extracted in 
expected formats and incomplete replication of one type of data. In the 
interim, NARA is primarily supporting search, processing, and retrieval 
of presidential records using the replicated systems described in the 
risk mitigation plan we recommended the agency develop last year, which 
cost less than $600,000 to put in place, compared to nearly $40 million 
it has obligated for EOP. Until NARA completely and accurately ingests 
the Bush Administration presidential records into EOP, it will be 
unable to use the system for its intended purpose and will incur 
additional costs maintaining the systems it is now using to support 
requests for these records. 

* NARA lacks a contingency plan for the ERA system in the event of a 
system failure or disruption. While NARA identified 11 security 
weaknesses related to contingency planning during acceptance testing 
and listed actions planned to address them, NARA has completed only one 
of the 11 planned actions. Further, NARA does not have a fully 
functional backup and restore process for the ERA system, a key 
component of planning for system availability in the event of a failure 
or disruption. According to NARA officials, a full system contingency 
plan is under development. However, until such a plan is tested and 
implemented, NARA risks prolonged unavailability of the ERA system in 
the event of a failure or disruption. 

We are recommending that the Archivist of the United States take the 
following actions: 

* Report to Congress on the specific outcomes to be achieved by ERA 
program funding for the remainder of fiscal year 2009. 

* Provide detailed information in future expenditure plans on what was 
spent and delivered for deployed increments of the ERA system and cost 
and functional delivery plans for future increments. 

* Strengthen the earned value process so that it follows the practices 
described in GAO’s guide and more reliable cost, schedule, and 
performance information can be included in future expenditure plans and 
monthly reports. 

* Include in NARA’s next expenditure plan an analysis of the costs and 
benefits of using the EOP system to respond to presidential records 
requests compared to other existing systems currently being used to 
respond to such requests. 

* Develop and implement a system contingency plan for ERA that follows 
contingency guidance for federal systems. 

In written comments on a draft of this briefing, the Acting Archivist 
of the United States agreed with 4 of our 5 recommendations. Regarding 
our recommendation that NARA report on the costs and benefits of using 
the EOP system to answer requests for presidential records compared to 
other systems, the Acting archivist stated that such a comparison would 
not be valid because of the differing capabilities of the systems and 
that the EOP system has accomplished enormous amounts of work. We 
disagree that a comparison of the costs and benefits of EOP and other 
systems would be invalid, because a valid analysis should account for 
the differences in capabilities. In addition, we noted that the 
replicated systems currently used to answer requests include nearly 
half of the records transferred to NARA and have been used to answer 
most of the requests received to date. 

[End of Results in Brief] 

Background: 

The ability to find, organize, use, share, appropriately dispose of, 
and save records—-the essence of records management-—is vital for the 
effective functioning of the federal government. In the wake of the 
transition from paper-based to electronic processes, records are 
increasingly electronic, and the volumes of electronic records produced 
by federal agencies are vast and rapidly growing, providing challenges 
to NARA as the nation’s record keeper and archivist. 

Besides sheer volume, other factors contributing to the challenge of 
electronic records include their complexity and their dependence on 
software and hardware. Specifically, the computer operating systems and 
the hardware and software that are used to create electronic documents 
can become obsolete. If they do, they may leave behind records that 
cannot be read without the original hardware and software. Further, the 
storage media for these records are affected by both obsolescence and 
decay. Media may be fragile, have limited shelf life, and become 
obsolete in a few years. For example, few computers today have disk 
drives that can read information stored on 8- or 5¼-inch diskettes, 
even if the diskettes themselves remain readable. 

Another challenge is the growth in electronic presidential records. The 
Presidential Records Act gives the Archivist of the United States 
responsibility for the custody, control, and preservation of 
presidential records upon the conclusion of a President’s term of 
office.[Footnote 8] The act states that the Archivist has an 
affirmative duty to make such records available to the public as 
rapidly and completely as possible consistent with the provisions of 
the act. 

In response to widely recognized challenges, the Archives began a 
research and development program to develop a modern archive for 
electronic records. In 2001, NARA hired a contractor to develop 
policies and plans to guide the overall acquisition of an electronic 
records system. In December 2003, the agency released a request for 
proposals for the design of ERA. In August 2004, NARA awarded two firm-
fixed-price[Footnote 9] contracts for the design phase, totaling about 
$20 million—one to Harris Corporation and the other to Lockheed Martin 
Corporation. On September 8, 2005, NARA announced the selection of 
Lockheed Martin Corporation to build the ERA system. 

The total value of the cost plus award fee[Footnote 10] contract with 
Lockheed through 2012 is about $317 million. As of fiscal year 2008, 
NARA has paid Lockheed $111.9 million for system development. 

The purpose of ERA is to ensure that the records of the federal 
government are preserved for as long as needed, independent of the 
original hardware or software that created them. ERA is to provide the 
technology to ensure that anyone, anywhere, anytime can access NARA’s 
electronic records holdings with the current technology that will be in 
use. 

The system is to enable the general public, federal agencies, and NARA 
staff to search and access information about all types of federal 
records, whether in NARA custody or not, as well as to search for and 
access electronic records stored in the system. Using various search 
engines, the system is to provide the ability to create and execute 
searches, view search results, and select assets for output or 
presentation. 

Figure 1 provides a simplified depiction of the system’s business 
concept. 

Figure 1: Overview of ERA Business Concept: 

[Refer to PDF for image: illustration] 

Business positions: 

Records appraisers: 
* Disposition agreements; 
* Templates. 

Transferring entities: 
* Transfer agreements; 
* Transfer packages. 

Records processors: 
* Arrangements; 
* Descriptions; 
* Access rights. 

Records preservers: 
* Preservation planning; 
* Processing. 

NARA managers: 
* Task approvals; 
* Business processes. 

All of the above entities interact with the ERA system and its' 
components: 

* Ingest; 
* Preservation; 
* Dissemination; 
* Records management; 
* Archival storage; 
* Local services and control. 

Outside of the ERA system, but interacting with it are: 

* Access reviewers; 
* Financial systems; 
* Researchers, general public, and NARA staff; 
* System administrators; 
* Space/inventory management. 

Source: NARA data. 

[End of figure] 

As currently planned, the ERA system is to consist of six major 
components. 

* Ingest will enable the transfer of electronic records from federal 
agencies. 

* Archival Storage will enable stored records to be managed in a way 
that guarantees their integrity and availability. 

* Dissemination will enable users to search descriptions and business 
data about all types of records, and to search the content of 
electronic records and retrieve them. 

* Records Management will support scheduling,[Footnote 11] appraisal, 
[Footnote 12] description, and requests to transfer custody of all 
types of records, as well as ingesting and managing electronic records, 
including the capture of selected records data (such as origination 
date, format, and disposition). 

* Preservation will enable secure and reliable storage of files in 
formats in which they were received, as well as creating backup copies 
for off-site storage. 

* Local Services & Control will regulate how the ERA components 
communicate with each other, manage internal security, and enable 
telecommunications and system network management. 

NARA currently plans to deliver these components in five separate 
increments: 

* Increment 1 was deployed in two releases. Release 1 established the 
ERA base system—the hardware, software, and communications needed to 
deploy the system. Release 2 enabled functional archives with the 
ability to preserve electronic data in their original format, enable 
disposition agreements and scheduling, and receive unclassified and 
sensitive data from four federal agencies; according to NARA officials, 
this increment was completed in June 2008. 

* Increment 2 includes the EOP system, which was designed to handle 
records from the Executive Office of the President.[Footnote 13] The 
EOP system uses an architecture based on a commercial off-the-shelf 
product that supplies basic requirements, including rapid ingest of 
records and immediate and flexible search of content. Increment 2 
includes basic case management for special access requests.[Footnote 
14] This release was certified for initial operating capability (IOC) 
in December 2008. 

* The second release of Increment 2 and Increments 3 through 5 are to 
provide additional ERA functionality, such as public access. 

Figure 2 shows the current incremental timetable for deploying ERA and 
the functionality planned for each increment. 

Figure 2: ERA Acquisition Approach: 

[Refer to PDF for image: timeline] 

August 2004: 
NARA awarded two design contracts to Harris Corporation and to Lockheed 
Martin Corporation. 

March 2012:
Full Operating Capability: Full use of the ERA system. 

Increment 1: September 2005 through June 2008: 
September 2005:	
NARA selected Lockheed Martin Corporation to develop the ERA system. 

Release 1: 
* Foundational system for ERA. 
Release 2: 
* Functional archives with the ability to preserve electronic data in 
original format; 
* Disposition agreements and scheduling; 
* Unclassified and sensitive data. 

June 2008: 
Initial Operating Capability: First use of the ERA system. 

Increment 2: November 2007 through September 2009: 
* EOP system: 
- Content search; 
- Basic case management for special access requests; 
- Ingest and transformation of data; 
- Extract/transform and load data. 

June 2008: 
Initial Operating Capability: First use of the ERA system. 

Increment 3: September 2009 through September 2010: 
* Preservation processing; 
* Description of records; 
* Authenticity check[A]; 
* Preservation assessment[A]; 
* Public access. 

Increment 4: September 2010 through September 2011: 
* Redaction[A]; 
* Expanded preservation and capacity; 
* Full appraisal and preservation plans[A]; 	
* FOIA processing. 

Increment 5: September 2011 through September 2012: 
* Expanded preservation and capacity; 
* Collaboration with agencies[B]. 

March 2012:
Full Operating Capability: Full use of the ERA system. 
						
[A] Functionality moved forward from previous increment. 

[B] Functionality moved from Increment 2. 

Source: NARA data. 

[End of figure] 

Since 2002, we have issued several reports on ERA and its development. 
[Footnote 15] In May 2008,[Footnote 16] we testified that the 
development of the ERA base was proceeding according to the revised 
schedule, although it faced challenges in meeting several testing 
deadlines. We also testified that the timely completion of the EOP 
system was uncertain, in part, due to ongoing negotiations between NARA 
and Lockheed Martin on system capabilities, timframes, and limited 
information about the nature of the records to be delivered. 

In September 2008[Footnote 17] we reported that NARA did not fully 
comply with its enterprise life-cycle methodology because it had not 
yet developed a mitigation plan to process the outgoing administration’
s records into the ERA system at the time of the January 2009 
presidential transition. NARA intended to develop a mitigation plan at 
the end of 2008, when it expected to know more about the types and 
volume of the presidential records that it would receive. We reported 
that this proposed schedule would leave NARA little time to prepare for 
and implement the plan. 

As of April 2009, the life-cycle cost for ERA through March 2012 was 
estimated at $551.4 million; the total life-cycle cost includes not 
only the development contract costs, but also program management, 
research and development, and program office support, among other 
things. 

Table 1 shows the amount spent for ERA in fiscal year 2008. Table 2 
shows the reported spending from the program’s inception to the end of 
fiscal year 2008. 

Table 1: Summary of Fiscal Year 2008 ERA Spending: 

Project category: Development Contract—Lockheed Martin[A]; 
Fiscal year 2008 spending: $41.6 million. 

Project category: Program Management; 
Fiscal year 2008 spending: $7.4 million. 

Project category: Program Office Support Team; 
Fiscal year 2008 spending: $4.8 million. 

Project category: Research and Development; 
Fiscal year 2008 spending: $4.0 million. 

Project category: Integrated Deployment and Support; 
Fiscal year 2008 spending: $3.1 million. 

Project category: Independent Verification and Validation; 
Fiscal year 2008 spending: $1.6 million. 

Project category: Net Adjustments; 
Fiscal year 2008 spending: -$0.9 million[B]. 

Project category: Total[C]; 
Fiscal year 2008 spending: $61.6 million. 

Source: GAO analysis of NARA data. 

[A] Amount includes Operations and Maintenance. 

[B] End of Year Recoveries. 

[C] Total may not equal the sum of individual items due to rounding. 

Note: NARA spent $30,231 towards security, but this is equal to zero 
when converted into millions and rounded to one decimal place. 

[End of table] 

Table 2: Summary of ERA Spending from Fiscal Year 2002 through Fiscal 
Year 2008: 

Project category: Development Contract—Lockheed Martin; 
Spending: $111.9 million. 

Project category: System Analysis and Design Contracts—Lockheed Martin 
and Harris Corporation; 
Spending: $40.8 million. 

Project category: Program Management; 
Spending: $31.2 million. 

Project category: Program Office Support Team; 
Spending: $22.8 million. 

Project category: Research and Development; 
Spending: $18.3 million. 

Project category: Integrated Deployment and Support; 
Spending: $8.9 million. 

Project category: Independent Verification and Validation; 
Spending: $5.6 million. 

Project category: Security; 
Spending: $0.2 million. 

Project category: Net Adjustments; 
Spending: -$2.4 million[A]. 

Project category: Total; 
Spending: $237.4 million[B]. 

Source: GAO analysis of NARA data. 

[A] Recoveries of prior year funds, adjustments to obligations 
incurred, obligations against prior years, and carryover funds expiring 
at the end of fiscal year 2009. 

[B] Total number may not equal the sum of individual items due to 
rounding. 

[End of table] 

In March 2009, NARA submitted a fiscal year 2009 expenditure plan as 
required to obtain the release of multiyear funds for ERA. The Omnibus 
Appropriations Act states that the agency could not obligate these 
funds until the appropriations committees reviewed and approved the 
expenditure plan. As of March 31, 2009, the appropriations committees 
have released $28.5 million of fiscal year 2009 multi-year funds with 
$17.3 million remaining to be released. Single-year funds appropriated 
for fiscal year 2009 totaled $21.2 million. 

NARA’s estimated ERA obligations for fiscal year 2009, including both 
single-year and multi-year funds, are $67.6 million. NARA plans to 
spend $11.1 million of this amount on EOP, and the remainder on the ERA 
base system and ERA program. As of March 31, 2009, NARA had obligated 
$23.9 million. Table 3 shows how NARA planned to distribute funds 
across the ERA program in fiscal year 2009. 

Table 3: Summary of NARA’s Fiscal Year 2009 Estimated Obligations for 
ERA: 

Project category: Development Contract; 
Description: Activities performed under the ERA system acquisition 
contract with Lockheed Martin (includes EOP); 
Estimated obligations: $44.4 million. 

Project category: Program Management; 
Description: Salaries and benefits, supplies, equipment, and 
telecommunications; 
Estimated obligations: $9.0 million. 

Project category: Research and Development; 
Description: Research performed with other agencies; 
Estimated obligations: $4.5 million. 

Project category: Program Office Support Team; 
Description: Labor, contracts, and materials to support ERA program 
management; 
Estimated obligations: $5.0 million. 

Project category: Integrated Deployment and Support; 
Description: Interagency agreements for ERA facilities[A]; 
Estimated obligations: $2.8 million. 

Project category: Independent Verification and Validation[B]; 
Description: Verification and validation activities; 
Estimated obligations: $1.9 million. 

Project Total; 
Estimated obligations: $67.6 million.[C] 

Source: GAO analysis of NARA data. 

[A] ERA facilities include Allegany Ballistics Lab at Rocket Center, 
West Virginia, and the Naval Meteorology and Oceanography Command at 
Stennis, Mississippi. 

[B] NARA contracted with Northrop Grumman to perform independent 
verification and validation on policies and plans produced by the ERA 
program and contract deliverables produced by Lockheed Martin. 

[C] Total may not equal the sum of individual items due to rounding. 

Note: NARA estimated obligations of $30,000 towards security, but this 
is not shown in the table because the amount is equal to zero when 
converted into millions and rounded to one decimal place. 

[End of table] 

[End of Background] 

Results: Legislative Conditions: 

Objective 1: NARA’s expenditure plan satisfies the fiscal year 2009 
legislative conditions. 

Table 4: Fiscal Year 2009 Expenditure Plan Provisions for Satisfying 
Legislative Conditions: 

Legislative condition: 1. Meets OMB capital planning and investment 
control review requirements; 
Expenditure plan provisions: OMB requires agencies to develop capital 
planning and investment control review processes that help ensure that 
projects are being implemented at acceptable cost and within reasonable 
and expected time frames, and that they are contributing to observable 
improvements in mission performance. NARA meets this condition; it 
provides control over cost, schedule, and performance through the 
activities of the ERA Oversight Group, which meets weekly to review ERA 
progress, and the Information Technology Executive Committee. These 
committees, which meet regularly, include senior agency leadership and 
other agency stakeholders. NARA has also implemented a policy and 
process for semiannual reviews of ongoing information technology 
investments, including interdependencies with ERA, through an 
agencywide capital planning and investment control process. 

Legislative condition: 2. Complies with NARA’s enterprise architecture; 
Expenditure plan provisions: OMB requires NARA to include ERA in its 
agency-level enterprise architecture, which is updated on a yearly 
basis. NARA has developed an agency-wide enterprise architecture that 
includes ERA. The current agency enterprise architecture—version 5.0—
includes ERA and consists of several component architectures, including 
business, data, systems, application, operations, and information 
technology security architectures. According to NARA officials, the 
agency is in the process of drafting the next version of its enterprise 
architecture—version 5.5—and plans to submit it to OMB for review in 
late May 2009. In addition, OMB requires that any major IT investment 
be mapped to and support the Federal Enterprise Architecture. The 
business case for the investment must also demonstrate the relationship 
between the investment and the business, performance, data, services, 
application, and technology layers of the agency’s architecture. NARA’s 
budget submission business case for the ERA system certifies compliance 
with these requirements and was approved by OMB. 

Legislative condition: 3. Conforms with NARA’s enterprise life cycle 
methodology; 
Expenditure plan provisions: The ERA project conforms to NARA’s life 
cycle methodology. For example, the expenditure plan includes 
descriptions of the incremental approach the agency has adopted for 
acquiring ERA and its management of program risks. In particular, the 
risk management methodology calls for the agency to identify and 
categorize risks, qualify the probabilities and consequences of the 
risks, specify a strategy to mitigate each risk, communicate risk 
status, and formulate actions needed to mitigate the risk. NARA manages 
risks using an agency-level risk review board, a program-level risk 
review board, and a technical risk review team. In addition, the ERA 
program office produces monthly reports that include top identified 
risks and specify associated mitigation strategies. The office also 
generates reports of pending or active risks from its risk management 
database that specify the probability and consequences of identified 
risks. Further, risk status is communicated to the ERA Executive 
Oversight Group, OMB, and Congress on a monthly basis. The monthly 
reports also identify executive actions needed to mitigate risks. 

Legislative condition: 4. Complies with the acquisition rules, 
requirements, guidelines, and systems acquisition management practices 
of the federal government[A]; 
Expenditure plan provisions: The quality of software is governed 
largely by the quality of the processes involved in developing or 
acquiring it and maintaining it. Carnegie Mellon University’s Software 
Engineering Institute (SEI),[B] recognized for its expertise in 
software processes, has developed models and methods that define and 
determine organizations’ software process maturity. NARA satisfied this 
provision. Specifically, NARA (1) conducted internal assessments in 
2002 and 2004 that used the institute’s SA-CMM[C] methods to determine 
the maturity of ERA’s system policies, processes, and practices and (2) 
implemented a process to address the assessment’s recommendations. NARA 
also conducted internal quality audits on its processes in late 2008. 
In December 2008, NARA’s quality management team conducted an 
assessment of the Communications and Risk Management components of the 
ERA system. The audits revealed that the teams responsible for managing 
these components of the program were utilizing current communication 
and risk management plans in the management of their respective areas. 

Legislative condition: 5. Approved by NARA and OMB; 
Expenditure plan provisions: 
* NARA—March 2009; 
* OMB—March 2009. 

Legislative condition: 6. Reviewed by GAO; 
Expenditure plan provisions: GAO—May 15, 2009, briefing to 
congressional appropriations subcommittees. 

Sources: GAO analysis of NARA data and the Omnibus Appropriations Act, 
2009. 

[A] We did not review the program’s compliance with the Federal 
Acquisition Regulation or other federal requirements beyond those 
encompassed by the Software Engineering Institute’s Capability Maturity 
Model. 

[B]SEI is a federally funded research and development center operated 
by Carnegie Mellon University and sponsored by the Department of 
Defense. Its objective is to provide leadership in software engineering 
and in the transition of new software engineering technology into 
practice. 

[C] The Software Acquisition-Capability Maturity Model (SA-CMM) 
identifies key process areas that are essential to effectively managing 
software-intensive system acquisitions. 

[End of table] 

Results: Prior Recommendation Status: 

Objective 2: NARA has partially implemented our previous 
recommendations: 

In July 2008, we made two recommendations to NARA—developing a 
mitigation plan and enhancing ERA project oversight. NARA implemented 
one of our recommendations and partially implemented the other. 

Table 5: Status of NARA’s Progress in Implementing Prior GAO 
Recommendations: 

Prior GAO recommendation: Mitigation Plan—Develop a mitigation plan for 
indexing and searching the electronic records from the outgoing Bush 
Administration in the event that the EOP system is not complete. The 
plan should be completed in time to be fully implemented for the 
January presidential transition. 
Implementation status: Implemented; 
Status as of fiscal year 2009 plan: In November 2008, NARA finalized 
its mitigation plan to assure acceptance and ingestion of presidential 
electronic records. For two high-priority EOP data sets, the plan 
stated that NARA would obtain copies of the proprietary software used 
by the Bush White House and use those programs to answer related 
requests until those data could be successfully ingested into EOP. 

Prior GAO recommendation: Oversight of the ERA Project—Ensure that 
summary measures of project performance against ERA cost and schedule 
estimates are included in future monthly reports to Congress. 
Implementation status: Partially implemented; 
Status as of fiscal year 2009 plan: In July 2008, NARA began including 
an Earned Value Summary as an appendix to its monthly reports to 
Congress. Summary data included ERA’s schedule and cost performance 
status. Similar data were included in subsequent reports. However, our 
review of NARA’s earned value methodology, discussed further below, 
raises questions about NARA’s ability to accurately report on project 
cost, schedule, and performance. 

Source: GAO analysis of NARA data. 

[End of table] 

Results: Observations: 

Objective 3: Observations about NARA’s ERA Acquisition and Expenditure 
Plan: 

Observation 1: Cost, schedule, and performance data in the expenditure 
plan do not provide a clear picture of system progress. 

NARA’s expenditure plan should include a sufficient level and scope of 
information for Congress to understand what system capabilities and 
benefits are to be delivered, by when, and at what costs, and what 
progress is being made against the commitments that were made in prior 
expenditure plans. However, NARA’s plan does not clearly show what 
functions have been delivered to date or what functions will be 
included in future increments and at what cost. 

As of fiscal year 2008, NARA has spent $237.4 million for ERA, or about 
43 percent of the program’s estimated life-cycle costs through 2012. 
NARA’s expenditure plan describes the results achieved with ERA funding 
at a high level. For example, as described in the plan, Increment 1, 
also known as the ERA base, includes the system hardware and software 
as well as some capability to preserve electronic data in their 
original format. Also, according to the plan, Increment 2, the EOP 
system, includes the capability to perform content searching and basic 
case management for presidential records. However, the plan does not 
provide a complete picture of what capabilities were delivered in these 
increments. In addition, even though NARA reported that planned 
functionality in both of these increments had been deferred to future 
increments, the plan does not provide cost estimates for the deferred 
functionality. As a result, it is not possible to fully identify what 
functionality has been delivered to date and at what cost. 

Additionally, NARA states it will spend $21.3 million to continue 
development of Increment 3, including implementing a common 
architecture, extending storage capabilities, and providing public 
access and preservation capabilities. However, NARA’s fiscal year 2009 
plan lacks specifics about the scope of these improvements. For 
example, it does not quantify by how much it will extend storage 
capacity. Also, NARA’s plan does not specify when these functions will 
be completed or how much will be spent on each one. 

Finally, while NARA’s plan reports that fiscal year 2009 funds will be 
used to support operations and maintenance of the completed base and 
EOP increments, it does not specify how much will be needed to address 
issues deferred when the systems were accepted. For example, the plan 
does not specify the funding required during the fiscal year to address 
issues in the EOP system that were identified but deferred when the 
system was certified for initial operating capability in December 2008. 
NARA officials subsequently estimated that such efforts will cost $1.1 
million. 

NARA officials attributed the plan’s lack of specificity to ongoing 
negotiations with Lockheed Martin. NARA provided broad descriptions of 
tasks for future development to Lockheed and is currently working with 
the contractor to refine them, and expects Lockheed to provide a 
proposal for accomplishing these tasks in May 2009. It is also in 
negotiations over the costs of addressing issues that were deferred at 
IOC. 

Without more specific information on what functionality has been and 
will be delivered and the costs associated with those functions, NARA 
and other interested parties will have limited abilities to measure 
overall program progress. In addition, until NARA specifies how it will 
use funds requested for the remainder of the year, congressional 
appropriators will lack information important for evaluating NARA’s 
request. 

Observation 2: NARA is not consistently following best practices in 
Earned Value Management. 

NARA’s expenditure plan states that, in managing ERA, the agency uses 
Earned Value Management (EVM) tools and requires the same of its 
contractors. EVM, if implemented appropriately, can provide objective 
reports of project status, produce early warning signs of impending 
schedule delays and cost overruns, and provide unbiased estimates of a 
program’s total costs. We recently published a set of best practices on 
cost estimation that addresses the use of EVM.[Footnote 18] Comparing 
NARA’s EVM data to those practices, we determined that NARA fully 
addressed only 5 of the 13 practices. For example, we found weaknesses 
within the EVM performance reports, including contractor reports of 
funds spent without work scheduled or completed, and work completed and 
funds spent where no work was planned. 

In addition, the program has not recently performed an integrated cost-
schedule risk analysis. This type of analysis provides an estimate of 
the how much the program will cost upon completion and can be compared 
to the estimate derived from EVM data to determine if it is likely to 
be sound. NARA officials attributed these weaknesses, in part, to 
documentation that did not accurately reflect the program’s current 
status. By not consistently adhering to identified best practices, NARA’
s program management data may be unreliable, likely hindering NARA’s 
ability to accurately monitor and report on program costs, schedule, 
and performance. Further detail on these best practices and our 
assessment can be found in attachment 1. 

Observation 3: Although NARA certified initial operating capability for 
EOP, the system is not currently fulfilling its intended purpose. 

NARA designed and developed the EOP system to support the transfer of 
electronic records at the end of the George W. Bush Administration as 
required by the Presidential Records Act. In fiscal year 2008, NARA 
obligated $27.9 million for the planning and development of EOP in 
order for the system to be ready for the presidential transition. The 
system was to ingest the electronic records and to support search, 
processing, and retrieval of records—particularly for “special access” 
requests[Footnote 19] for the ongoing business of Congress and the next 
administration—immediately after the presidential transition on January 
20, 2009. Responding to special access requests from the current 
administration, Congress, and the courts is a critical part of NARA’s 
mission and one of the major capabilities intended for the EOP system. 

In December 2008, NARA certified IOC for the EOP system, based on 
successful completion of acceptance and security testing. In January 
2009, NARA took custody of approximately 78.4 terabytes[Footnote 20] of 
unclassified Bush Administration electronic records, which agency 
officials characterized as all such records. Before the transition, 
NARA had estimated that it was going to receive almost 124 terabytes of 
presidential records. According to NARA officials, the difference 
between the estimated volume of records and the actual records received 
is due to inaccurate information provided by the previous 
administration. 

NARA copied the records data to large storage arrays, which were 
initially stored in the Washington, D.C. area, then moved to the ERA 
facility in West Virginia, where ingestion of records into EOP takes 
place. As of April 27, only 2.3 terabytes of data have been fully 
ingested from the first storage array into the EOP system, where they 
are available for search and retrieval. This constitutes about 3 
percent of all Bush Administration unclassified electronic records. 
NARA currently estimates that ingest of all 78.4 terabytes of 
unclassified records will not be complete until October 2009. Before 
the transition, NARA has estimated that ingest would be completed by 
May 2009. 

NARA officials attributed delays, in part, to unexpected difficulties. 
For example, according to NARA officials, once they started using the 
EOP system, they discovered that records from certain White House 
systems were not being extracted in the expected format. As a result, 
it had to develop additional software tools to facilitate the full 
extraction of data from White House systems prior to ingest into EOP. 
In addition, in April 2009, NARA discovered that 31 terabytes of 
priority data that had been partially ingested between December 2008 
and January 2009 was neither complete nor accurate because it was taken 
from an incomplete copy of the source system. NARA has started to re-
copy data from what it believes to be a complete version of the source 
data. 

Because the records had not been ingested into the EOP system, NARA had 
to use other systems to respond to requests for presidential records. 
As of April 24, 2009, NARA had received 43 special access requests for 
information on the Bush Administration. Only one of these requests used 
EOP for search, and no responsive records were found. To respond to 24 
of these requests, NARA used the replicated White House systems 
described in its risk mitigation plan, which called for acquiring the 
software and related hardware used by the White House to manage a 
records management system and an image database. According to NARA 
officials, these replicated systems cost $570,000 to put into service. 
The sources used to respond to the 42 requests that did not use EOP are 
listed in table 6 below. 

Table 6: Sources Used by NARA to Respond to Special Access Requests: 

Source used to respond to requests: Replicated records management 
system; 
Number of requests: 22. 

Source used to respond to requests: Replicated image database; 
Number of requests: 2. 

Source used to respond to requests: Classified electronic records 
system; 
Number of requests: 8. 

Source used to respond to requests: Copies of original electronic 
records; 
Number of requests: 3. 

Source used to respond to requests: Hand search of hard copy records; 
Number of requests: 5. 

Source used to respond to requests: Other[A]; 
Number of requests: 5. 

Source: GAO analysis of NARA data. 

[A] Other includes requests where no search was required to locate 
paper records, a request forwarded to another agency, and a request 
that was put on hold. 

Note: Three requests were answered using both the replicated records 
management system and the classified electronic records system. 

[End of table] 

Until NARA completely and accurately ingests the Bush presidential 
records into EOP, it will be unable to use the system for its intended 
purpose and will incur additional costs in maintaining the systems it 
is now using to support requests for Bush presidential records. 

Observation 4: NARA lacks a contingency plan for ensuring continuity of 
the ERA system. 

Contingency planning is a critical component of information protection. 
If normal operations are interrupted, network managers must be able to 
detect, mitigate, and recover from service disruptions while preserving 
access to vital information. Therefore, a contingency plan details 
emergency response, backup operations, and disaster recovery for 
information systems. It is important that these plans be clearly 
documented, communicated to potentially affected staff, updated to 
reflect current operations, and regularly tested. 

The Federal Information Security Management Act[Footnote 21] (FISMA) 
requires each agency to develop, document, and implement an information 
security program that includes plans and procedures to ensure 
continuity of operations for information systems that support the 
agency’s operations and assets. The National Institute of Standards and 
Technology (NIST) requires that agencies’ systems have contingency 
plans and that the plans address, at a minimum, identification and 
notification of key personnel, plan activation, system recovery, and 
system reconstitution. Specifically, NIST identifies 10 security 
control activities related to contingency planning, including 
developing a formal contingency plan, training employees on their 
contingency roles and responsibilities, and identifying a 
geographically separate alternative processing site to support critical 
business functions in the event of a system failure or disruption. 
[Footnote 22] 

NARA has not developed a contingency plan for the ERA system to ensure 
availability in the event of a system failure or disruption. In 
December 2008, NARA issued an assessment that detailed the results of 
an evaluation of the security features associated with the ERA system. 
This assessment identified weaknesses related to all 10 of the 
contingency planning control activities, which were attributed to the 
system not having the required contingency plans. OMB guidance[Footnote 
23] requires that when an agency identifies security weaknesses, it 
must also develop a plan of action to address the identified 
weaknesses, including the resources required to fix the weaknesses, the 
scheduled completion date of each fix, and the current status of the 
mitigation. Accordingly, NARA developed a plan of action and milestone 
document which was to detail all the primary risk elements present in 
the system and the corresponding plan of actions to mitigate or correct 
identified deficiencies before the ERA system reached IOC. However, 
while the initial plan of action and milestones discussed fixes for 
eight contingency planning control activities, it did not address two 
others—contingency planning policies and procedures and 
telecommunications services. For those eight control activities 
mentioned in the document, no timetable was provided for completion to 
address the identified issues. A subsequent planning document was 
developed that provided further detail on the identified risks. 

The revised plan of action and milestones document provided the 
scheduled dates of completion as well as the current status of the 
mitigation activities. However, this version did not mention the 
various risk categories (i.e., “low,” “medium,” “high”) and used a 
variety of terms to describe the status of each weakness (e.g., 
“pending,” “planned,” “ongoing”) without providing clear definitions of 
their meaning. Further, 10 of 11 items in the plan of action to address 
contingency planning weaknesses remain open as of April 2009. 

In addition, NIST standards require that agencies back up information 
contained within a system and employ a mechanism that would restore the 
system after a disruption or failure. Following product acceptance 
tests for EOP, NARA reported that the backup and restore functions for 
the commercial off-the-shelf archiving product used at the ERA facility 
in West Virginia tested successfully, but there were concerns about the 
amount of time required to execute the process. In lab tests, the 
restore process took about 56 hours for 11 million files.[Footnote 24] 
This is significant because, while the backup is being performed, the 
replication of data must be stopped; otherwise it could bring the 
system to a halt. Subsequently, NARA officials stated that they have 
conducted two successful backups, but the restore process had not been 
fully tested to ensure that the combined backup and restore capability 
can be successfully implemented. The most recent backup, conducted at 
Rocket Center on March 20, 2009, took 95 hours and 38 minutes for 11.25 
terabytes of data, but NARA could not provide any documentation to 
substantiate the success of the backups or information on the length of 
time needed to perform the restore function. 

NARA considered the initial backup and restore test a success because 
it met the requirements set for the contractor. According to NARA’s 
requirements documentation, among other things, the Backup and Recovery 
service was supposed to “provide the capability to recover EOP ERA 
records as required to re-establish the system,” and “provide the 
capability to recover application files to re-establish the EOP ERA 
system.” However, as in the examples cited, none of the backup/restore 
requirements specified how long the backup and restore process should 
take. According to NARA officials, a full system contingency plan is 
currently under development. 

Without a complete and successfully tested contingency plan, there is 
an increased risk that, in the event of a major system failure or 
disruption, NARA would not be able to effectively restore its 
information and ensure system availability. Such a significant risk 
severely limits the reliability of the system. 

[End of Results] 

Conclusions: 

While NARA has continued to make progress on the ERA system, that 
progress cannot be fully quantified because NARA’s expenditure plan 
does not clearly identify what functions have already been delivered, 
how much was spent to provide each function, or how much is required to 
maintain the delivered increments. NARA’s current plan similarly lacks 
details on the functions to be provided in future increments and the 
costs associated with them, including development efforts scheduled to 
take place in the remainder of this year. In addition, although NARA 
has been using Earned Value Management to track program cost, schedule, 
and performance, weaknesses in its EVM data limit NARA’s ability to 
accurately report on the project’s progress. Without more specific and 
accurate information on the immediate and long-term goals of the 
program and the outcomes expected from its resulting efforts, NARA will 
be hindered in effectively monitoring and reporting on the cost, 
schedule, and performance of the ERA system and congressional 
appropriators will lack information necessary to evaluate the agency’s 
requests for funds. 

Although NARA certified that the EOP portion of the ERA system had 
achieved initial operating capability as planned in December 2008, the 
system has been of limited use because of delays in ingesting 
electronic records into the system. Further, even though it has 
obligated nearly $40 million on EOP, NARA has instead answered requests 
for Bush electronic records using existing systems or replicated White 
House systems that cost less than $600,000. Under its current schedule, 
the Bush Administration records will not be fully ingested into the 
system until October 2009. However, even when the data are fully 
ingested, the system’s lack of a complete, fully tested contingency 
plan increases the risk that a system failure or disruption will result 
in the system being unavailable for several days or more. 

[End of Conclusions] 

Recommendations for Executive Action: 

We recommend that the Archivist of the United States take the following 
actions: 

* Report to Congress on the specific outcomes to be achieved by ERA 
program funding for the remainder of fiscal year 2009. 

* Provide detailed information in future expenditure plans on what was 
spent and delivered for deployed increments of the ERA system and cost 
and functional delivery plans for future increments. 

* Strengthen the earned value process so that it follows the practices 
described in GAO’s guide and more reliable cost, schedule, and 
performance information can be included in future expenditure plans and 
monthly reports. 

* Include in NARA’s next expenditure plan an analysis of the costs and 
benefits of using the EOP system to respond to presidential records 
requests compared to other existing systems currently being used to 
respond to such requests. 

* Develop and implement a system contingency plan for ERA that follows 
contingency guidance for federal systems. 

[End of Recommendations for Executive Action] 

Agency Comments and Our Evaluation: 

In written comments on a draft of this briefing, the Acting Archivist 
of the United States agreed with 4 of our 5 recommendations. 
Specifically, in response to our recommendation that NARA report to 
Congress on the specific outcomes to be achieved during the remainder 
of the year, she indicated that a briefing on that subject was provided 
on April 27, 2009. In addition, she agreed to: 

* ensure that future expenditure plans include more details on the 
costs and functions of future increments, 

* strive to comply with EVM best practices, and, 

* complete the ERA system contingency plan. 

Regarding our recommendation that NARA report on the costs and benefits 
of using the EOP system to answer requests for presidential records 
compared to other systems, the Acting Archivist raised several points. 
First she wrote that the EOP system is accomplishing an enormous amount 
of work at exceptional speed, and that the system has the capability to 
transfer and ingest records as they became available. However, as 
indicated in our briefing, the EOP system has been of limited use to 
answering the requests received to date. Further, the ingest of 
presidential records into the system required the use of additional 
software tools and is now scheduled to take 5 months longer than NARA 
estimated before the transition, even though NARA received a 
significantly lower volume of records than anticipated. The Acting 
Archivist also wrote that EOP supports functions other than the search 
of presidential records, such as the lifecycle management of 
presidential records, and that comparisons between the replicated 
systems and EOP are not valid. While we acknowledge that EOP was 
designed to perform functions other than search, we disagree that a 
comparison between EOP and other systems would not be valid. Instead, 
we believe that an appropriate analysis of the costs and benefits of 
using the various systems should account for the need to satisfy non-
search requirements, such as lifecycle management of records, using 
systems other than EOP. 

Finally, the Acting Archivist wrote that the replicated systems were 
being used for a small subset of records. However, these systems 
include nearly half of the records NARA received, by volume. In 
addition, these same records have been the subject of most of the 
requests received to date. We also addressed the Acting Archivist’s 
technical comments, as appropriate. 

[End of Agency Comments and Our Evaluation] 

Attachment 1: Details on NARA’s EVM Compared with Best Practices: 

NARA’s EVM processes only partially adhere to the thirteen practices 
that GAO has identified as necessary in developing a reliable EVM 
process.[Footnote 25] Specifically, NARA fully adhered to 5 of the 13 
best practices in implementing EVM, partially adhered to 6, and did not 
adhere to 2. While NARA’s EVM data indicate that the project is meeting 
cost and some schedule targets, not adhering to best practices does not 
allow NARA to effectively measure progress or forecast cost overruns. 
See table 7 for details. 

Table 7: NARA Earned Value Management Compared with Best Practices: 

Best practice: Define the Scope with a Work Breakdown Structure (WBS); 
Explanation: The WBS, a critical component of EVM that defines the work 
to be performed, should be the basis of the cost estimate and the 
project schedule (i.e. the baseline). The WBS progressively 
deconstructs the deliverables of the entire effort through lower-level 
WBS elements and control accounts. 
GAO assessment: Partially met; We were unable to trace business 
functionality to the WBS. As such there is no certainty that the 
baseline is comprehensive. 

Best practice: Identify Who Will Do the Work; 
Explanation: To ensure that someone is accountable for every WBS 
element, it is useful to determine levels of accountability within the 
EVM system. 
GAO assessment: Met. 

Best practice: Schedule the Work to a Timeline; 
Explanation: Developing a schedule provides a time sequence for the 
duration of the program’s activities and helps everyone understand both 
the dates for major milestones and the activities that drive the 
schedule. 
GAO assessment: Partially met; The Defense Contract Management Agency 
has identified areas of concern with the integrated schedule. For 
example, no resources are assigned within the schedule, there are 
several instances of broken logic, and there are actual dates that are 
recorded as being in the future. 

Best practice: Estimate Resources and Authorize Budgets; 
Explanation: Budgets should be authorized as part of the EVM process, 
and they must authorize the resources needed to do the work. 
GAO assessment: Partially met; We found multiple types of data 
anomalies within the EVM performance reports. Specifically, the 
contractor reported: 
* Dollars were spent, but no work was scheduled or completed. 
* Work was scheduled and accomplished, but no dollars were spent. 
* Work was completed and dollars spent, but no work planned. 
In addition, the contractor did not explain key variances in these 
reports. For example, 
* the contractor performed $5.9M worth of work for $1.4M, and, 
* the contractor performed $2.7M worth of work at a cost of $1.9M. 

Best practice: Determine an Objective Measure for Earned Value; 
Explanation: Performance measurement is key to earned value because 
performance represents the value of work accomplished. These measures 
are used to report progress in achieving milestones and should be 
integrated with technical performance measures. 
GAO assessment: Partially met; Initially there was a large amount of 
work not being measured objectively. The program has requested that the 
contractor turn some of these into objective measures. For example, all 
quality assurance work was changed after the December 2008 integrated 
baseline review. However, there still are several examples of non-
discrete work such as all the annual program execution costs. 

Best practice: Develop the Performance Measurement Baseline; 
Explanation: The performance measurement baseline represents the 
cumulative value of the planned work overtime. It takes into account 
that program activities occur in a sequenced order, based on finite 
resources, with budgets representing those resources spread over time. 
GAO assessment: Partially met; Not all increments are included in the 
EVM baseline. Specifically, the baseline includes Increments 1 and 2, 
but does not include Increments 3 through 5. 

Best practice: Execute the Work Plan and Record All Costs; 
Explanation: Actual costs are recorded by the accounting system and are 
reconciled with the value of the work performed so that effective 
performance measurement can occur. 
GAO assessment: Met. 

Best practice: Analyze EVM Performance Data and Record Variances from 
the Performance Measurement Baseline Plan; 
Explanation: Because programs all carry some degree of risk and 
uncertainty, cost and schedule variances are normal. EVM guidelines 
provide for examining cost and schedule variances at the control 
account level at least monthly and for focusing management attention on 
variances with the most risk to the program. 
GAO assessment: Met. 

Best practice: Forecast Estimates at Completion (EAC) Using EVM; 
Explanation: Managers should rely on EVM data to generate EACs at least 
monthly. A best practice is to continually reassess the EAC, obviating 
the need for periodic bottom-up estimating. 
GAO assessment: Met. 

Best practice: Conduct an Integrated Cost-Schedule Risk Analysis; 
Explanation: An integrated schedule can be used, in combination with 
risk analysis data (often including traditional 3-point estimates of 
duration) and Monte Carlo simulation software, to estimate schedule 
risk and the EAC. 
GAO assessment: Not met. The program has not performed an integrated 
cost-schedule risk analysis. Program officials stated that they plan on 
doing this with Increment 3. 

Best practice: Compare EACs from EVM with EAC from Risk Analysis; 
Explanation: The integrated cost-schedule risk analysis produces a 
cumulative probability distribution for the program’s cost. This 
estimate can be compared to the estimate using EVM extrapolation 
techniques. If their results are in general agreement, their 
conclusions are probably sound. If not, one or the other method (or 
both) should be reviewed for changes and revisions. 
GAO assessment: Not met. Since the program has not performed an 
integrated cost-schedule risk analysis, they are not able to calculate 
a risk-adjusted EAC. 

Best practice: Take Management Action to Mitigate Risk; 
Explanation: Management should focus on corrective actions and identify 
ways to manage cost, schedule, and technical scope to meet program 
objectives. It should also keep track of all risks and analyze EVM data 
trends to identify future problems. 
GAO assessment: Partially met: 
* Multiple risk lists exist but are not consistent (e.g. implementation 
of an e-mail application was identified on only two of the three risk 
lists). 
* The program was providing quarterly reviews of high risk issues. 
However, these have stopped since the change of presidential 
administrations. 

Best practice: Update the Performance Measurement Baseline as Changes 
Occur; 
Explanation: Because changes are normal, guidelines allow for 
incorporating changes—unless it is a retroactive change to the 
performance data (with the exception of error correction). However, it 
is imperative that changes be incorporated into the EVM system as soon 
as possible to maintain the validity of the performance measurement 
baseline. 
GAO assessment: Met. 

Source: GAO analysis of agency data. 

[End of table] 

[End of Attachment 1] 

Attachment 2: Comments from the Acting Archivist of the United States: 

National Archives and Records Administration: 
8601 Adelphi Road: 
College Park, Maryland 20740-6001: 

May 11, 2009: 

Mr. David A. Powner: 
Director
Information Technology Management Issues: 
Government Accountability Office (GAO): 
441 G Street NW: 
Washington DC, 20548: 

Dear Mr. Powner: 

Thank you for the opportunity to review and comment on the draft 
presentation titled Review of NARA's Fiscal Year 2009 Electronic 
Records Archives Expenditure Plan before it is briefed to the staff 
members of the Subcommittee on Financial Services and General 
Government, Senate Appropriations Committee and the Subcommittee on 
Financial Services and General Government, House Appropriations 
Committee. We are pleased to note the recognition of the progress made 
towards implementing the Electronics Records Archives (ERA) Program. 

We also appreciate the insight into the Expenditure Plan observations 
addressed in GAO's presentation. We would like to take this opportunity 
to address the recommendations in your presentation. 

Regarding your recommendation that the agency provide a report to 
Congress on the specific outcomes Tube achieved by ERA program, a 
briefing on that topic was provided by the Chief Information Office, on 
April 27, 2009. 

We note your recommendation that future Expenditure Plans include more 
detailed information on what was spent and delivered for deployed 
increments of the ERA system and cost and functional delivery plans for 
future increments. We will ensure that future Expenditure Plans include 
more details for increments to be deployed both from a functional and 
cost basis. In addition, we will work with our contacts at the Office 
of Management and Budget in an effort to make the ERA Expenditure Plan 
available at an earlier date. We believe it would be extremely helpful 
to NARA that, if specific guidance exists on what detailed information 
should appear in the Expenditure Plan, it be provided. 

We appreciate GAO's guidance on Earned Value Management (EVM) and the 
information provided in its recently released Cast Estimating and 
Assessment Guide dated March 2009. While this Guide was not available 
during the period covered by this review, NARA fully adheres to 5 of 
the 13 best practices in implementing EVM, and partially adheres to 6. 
We are in the process of upgrading our EVM system and will strive to 
comply with all 13 best practices both internally and on our contracts 
that require EVM. 

The finding that the EOP system is not currently fulfilling its 
intended purpose neglects to differentiate between what the system is 
capable of doing and the work being done an the system. The system does 
provide required functionality and is in fact accomplishing an enormous 
amount of work at exceptional speed It assist be noted that the ability 
to search EOP records is only one aspect of the functions Lobe 
performed by LOP system, and that equally important are the fundamental 
requirements for quality assurance over transfer and ingest and 
comprehensive and detailed lifecycle management of the ingested 
records. The existing systems now being used to bridge the gap for 
searching records until all the EOP data is ingested into the system 
will not address those areas. The system has provided the required 
functionality to transfer and ingest COP records as those retards 
became available. As stated in the report, transfer and ingest 
challenges have included such problems as data not being extracted in 
expected formats and incomplete replication of one type of data. 

The comparison of costs of the ERA EOP system and the technology used 
under the contingency plan is not valid. The contingency plan was 
constructed and executed as a short term solution to specific problems 
in the transfer of records from the Bush Administration. Meeting the 
short term needs for which it was intended entailed using the most 
convenient technological solution possible. Had it been intended as a 
sustainable approach. NARA would have had to take a much more 
comprehensive approach, resulting in higher costs and a probable time 
frame longer than the solution was needed. Moreover, the contingency 
plan was implemented only for a small subset of the records. 

Regarding your last recommendation, an ERA Contingency Plan is 
currently under development, and will he provided to you upon 
completion. 

Again, we thank you for this opportunity and look forward to our future 
interactions as we continue the ERA acquisition process. 

Sincerely, 

Signed by: 

Michael J. Kraft, for: 
Adrienne C. Thomas: 
Acting Archivist of the United States: 

[End of Attachment 2] 

[End of section] 

Appendix II: Comments from the National Archives and Records 
Administration: 

National Archives and Records Administration: 
8601 Adelphi Road: 
College Park, Maryland 20740-6001: 

July 9, 2009: 

Government Accountability Office: 
Director of Information Technology Management Issues: 
Mr. David A. Powner: 
441 G Street NW: 
Washington DC, 20548: 

Dear Mr. Powner: 

We thank you for the opportunity to review and comment on the report 
entitled Electronic Records Archive: The National Archives' Fiscal Year 
2009 Electronic Archives Expenditure Plan (GAO-09-733). We appreciate 
the insight into the Expenditure Plan observations addressed in the 
report and would like to take this opportunity to address the 
recommendations. 

We are pleased to note your recognition that the FY 2009 ERA 
Expenditure Plan meets all six legislative conditions required for 
release of the appropriated multi-year funds. Regarding your 
recommendations on areas outside the scope of the Expenditure Plan 
legislative requirements, we have the following comments. 

The level of detail provided in the Expenditure Plan was addressed in a 
briefing to Congress on the specific outcomes to be achieved by the ERA 
program on April 27, 2009. We will add details to the next Expenditure 
Plan addressing costs and functions delivered to date, and what is 
planned for future increments. In addition, we will work with the 
Office of Management and Budget in an effort to make the ERA 
Expenditure Plan available at an earlier date. 

We appreciate GAO's guidance on Earned Value Management (EVM) and the 
information provided in its recently released Cost Estimating and 
Assessment Guide dated March 2009. Although this Guide was not 
available when the Expenditure Plan was written, NARA is pleased to 
note that GAO concluded that NARA fully adheres to 5 of the 13 best 
practices and partially adheres to 6. We are in the process of 
upgrading our EVM system and will strive to comply with all 13 best 
practices. 

The comment that the EOP system is not currently fulfilling its 
intended purpose fails to differentiate between what the system is 
capable of doing and the work being done on the system. The system does 
provide required functionality and is in fact accomplishing an enormous 
amount of work at exceptional speed. All the data will be ingested by 
the end of the fiscal year. Additionally, NARA can and does use the ERA 
EOP instance to search any records ingested into the system. 

NARA did use contingency systems at the end of the Bush 43 
Administration for two of the 62 different sets of electronic records. 
NARA implemented this temporary measure for a period of less than six 
months because of problems with the copies of the electronic records 
transferred to NARA by the EOP, not problems with the ERA system. The 
ERA system was ready to process these records if they had been 
transferred according to the specifications negotiated with the EOP. 
Issues with that data are now resolved and the data is in the ERA EOP. 
Use of the contingency systems was terminated at the end of June. 

The recommendation regarding a cost comparison between the ERA EOP and 
the contingency systems is problematic since it does not seem cost-
effective to conduct a retrospective analysis as to whether there might 
have been technology solutions for systems that have already been 
retired. Finally, the report minimizes the cost of longterm use of the 
full set of legacy systems. The report reflects only software licenses 
and operational support for only two of the contingency systems. It 
does not reflect costs NARA would have incurred if the EOP had not 
loaned NARA the proprietary hardware on which the two contingency 
systems resided, or the costs of software development for extending the 
full set of legacy systems in order to meet the ERA EOP requirements. 

Regarding your last recommendation, an ERA Contingency Plan has been 
developed and is in final review. We will provide a copy when the 
review process is completed. 

Again, we appreciate GAO's recognition that NARA has satisfied the 
legislative conditions for release of ERA funds. We thank you for this 
opportunity and look forward to our future interactions as we continue 
the ERA acquisition process. 

Sincerely, 

Signed by: 
Adrienne C. Thomas
Acting Archivist of the United States: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David A. Powner (202) 512-9286 or pownerd@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, key contributions to this 
report were made by James R. Sweetman, Jr., Assistant Director; Monica 
Perez Anatalio; Nabajyoti Barkakati; Carol Cha; Barbara Collier; Tisha 
Derricotte; Jennifer Echard; Pamlutricia Greenleaf; Kush Malhotra; Lee 
McCracken; and Tarunkant Mithani. 

[End of section] 

Footnotes: 

[1] Omnibus Appropriations Act, 2009, Pub. L. No. 111-8, div. D, title 
V, 123 Stat. 524, 667 (Mar. 11, 2009). 

[2] ERA's fiscal year 2009 budget authority totaled $67.6 million, 
which includes $0.6 million carried over from multi-year funds 
appropriated in previous years. 

[3] EVM is a project management tool that integrates the technical 
scope of work with schedule and cost elements for investment planning 
and control. It compares the value of work accomplished in a given 
period with the value of the work expected in that period. Differences 
in expectations are measured in both cost and schedule variances. OMB 
requires agencies to use EVM in their performance-based management 
systems for the parts of an investment in which development effort is 
required or system improvements are under way. 

[4] Omnibus Appropriations Act, 2009, Pub. L. No. 111-8, div. D, title 
V, 123 Stat. 524, 667 (Mar. 11, 2009). 

[5] ERA’s fiscal year 2009 budget authority totaled $67.6 million which 
includes $0.6 million carried over from multi-year funds appropriated 
in previous years. 

[6] Agencies develop an exhibit 300, also known as the Capital Asset 
Plan and Business Case Summary, to justify each request for a major 
information technology investment. OMB sets forth requirements for the 
exhibit 300 in Circular A-11, Part 7, Planning, Budgeting, Acquisition, 
and Management of Capital Assets. 

[7] EVM is a project management tool that integrates the technical 
scope of work with schedule and cost elements for investment planning 
and control. It compares the value of work accomplished in a given 
period with the value of the work expected in that period. Differences 
in expectations are measured in both cost and schedule variances. OMB 
requires agencies to use EVM in their performance-based management 
systems for the parts of an investment in which development effort is 
required or system improvements are under way. 

[8] 44 U.S.C. 2203(f)(1). 

[9] According to the Federal Acquisition Regulation, a firm-fixed-price 
contract provides for a price that is not subject to any adjustment on 
the basis of the contractor’s cost experience in performing the 
contract. 

[10] A cost plus award fee contract is a cost reimbursement contract 
that provides for a fee consisting of a base amount fixed at inception 
of the contract plus an award amount that may be given based upon a 
judgmental evaluation by the government of contract performance. 

[11] A record schedule is a document that describes agency records, 
establishes a period for their retention by the agency, and provides 
mandatory instructions for what to do with them when they are no longer 
needed for current government business. 

[12] Records appraisal is the process of determining the value and the 
final disposition of records, making them either temporary or 
permanent. 

[13] NARA’s original EOP plans included a National Security System. 
NARA subsequently deferred the capability to ingest classified national 
security data, stating that the volume to be transferred from the Bush 
Administration did not support the establishment of a full scale 
classified EOP system as planned. Instead, NARA migrated the classified 
data from the Bush Administration to an existing classified NARA 
presidential library system. 

[14] These are requests NARA receives from the current and former 
administrations, Congress, and the courts for access to presidential 
records. 

[15] GAO, Information Management: Challenges in Managing and Preserving 
Electronic Records, [hyperlink, http://www.gao.gov/products/GAO-02-586] 
(Washington, D.C.: June 17, 2002). Records Management: Planning for the 
Electronic Records Archives Has Improved, [hyperlink, 
http://www.gao.gov/products/GAO-04-927] (Washington, D.C.: Sept. 23, 
2004); Information Management: Acquisition of the Electronic Records 
Archives Is Progressing, [hyperlink, 
http://www.gao.gov/products/GAO-05-802] (Washington, D.C.; July 15, 
2005); Electronic Records Archives: The National Archives and Records 
Administration’s Fiscal Year 2006 Expenditure Plan, [hyperlink, 
http://www.gao.gov/products/GAO-06-906] (Washington, D.C.: Aug. 18, 
2006); and Information Management: The National Archives and Records 
Administration’s Fiscal Year 2007 Expenditure Plan, [hyperlink, 
http://www.gao.gov/products/GAO-07-987] (Washington, D.C.: July 27, 
2007). 

[16] GAO, Information Management: Challenges in Implementing an 
Electronic Records Archive, [hyperlink, 
http://www.gao.gov/products/GAO-08-738T] (Washington, D.C.: May 14, 
2008). 

[17] GAO, Information Management: The National Archives and Records 
Administration’s Fiscal Year 2008 Expenditure Plan, [hyperlink, 
http://www.gao.gov/products/GAO-08-1105] (Washington, D.C.: Sept. 26, 
2008). 

[18] GAO, GAO Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March, 
2009). 

[19] These are requests NARA receives from the current and former 
administrations, Congress, and the courts for access to presidential 
records. The priorities are determined by NARA’s Office of Presidential 
Libraries based on experience with the records of previous 
administrations. 

[20] A terabyte is about one trillion bytes or about 1,000 gigabytes. 

[21] FISMA was enacted as title III, E-Government Act of 2002, Pub. L. 
No. 107-347 (Dec. 17, 2002). 

[22] National Institute of Standards and Technology, Recommended 
Security Controls for Federal Information Systems, Special Publication 
800-53 Revision 1 (Gaithersburg, MD: December 2006). 

[23] Office of Management and Budget, “Guidance for Preparing and 
Submitting Security Plans of Action and Milestones,” Memorandum for the 
Heads of Executive Departments and Agencies, Mitchell E. Daniels, Jr., 
Director, M-02-01, October 17, 2001. 

[24] NARA estimates that it has received more than 300 million files 
from the Bush Administration. 

[25] GAO, Cost Estimating and Assessment Guide: Best Practices for 
Developing and Managing Capital Program Costs, [hyperlink, 
http://www.gao.gov/products/GAO-09-3SP] (Washington, D.C.: March 2009). 

[End of section] 

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