B-308603

June 18, 2007

The Honorable Robert C. Byrd

Chairman, Committee on Appropriations

United States Senate

The Honorable John Conyers, Jr.

Chairman, Committee on the Judiciary

United States House of Representatives

Subject: Presidential Signing Statements Accompanying the Fiscal Year 2006 Appropriations Acts

This letter responds to your request that we examine the fiscal year 2006 appropriations acts and the President’s accompanying signing statements to identify the provisions in the acts to which the President took exception and to determine how the President executed those provisions. We also examined how the federal courts have treated signing statements in their published opinions.

We found that in 11 signing statements the President singled out 160 specific provisions from the fiscal year 2006 appropriations acts. We examined 19 of these provisions to determine whether the agencies responsible for their execution carried out the provisions as written.^[1] Of these 19 provisions, 10 provisions were executed as written, 6 were not, and 3 were not triggered and so there was no agency action to examine.[2] With regard to the use of signing statements by the federal courts, we found that they cite or refer to them infrequently and only in rare instances have relied on them as authoritative interpretations of the law.

In this review, we did not assess the merits of the President’s objections, nor did we examine the constitutionality of the provisions to which the President objected.

BACKGROUND

There is no established definition of “signing statement.” Signing statements usually take the form of a presidential statement or press release issued in connection with the President’s signing of a bill. There is even some disagreement as to the first historical use of a signing statement. Many scholars cite President Andrew Jackson’s statement accompanying an appropriations act involving internal improvements as the first signing statement.[3] Other scholars point to a statement made by President James Monroe a month after signing a law regulating the appointment of military officers.[4] Various presidential administrations have used signing statements since the early nineteenth century with a variety of responses by Congress and the courts.[5]

Some signing statements praise the newly signed law and those involved in its passage. An example of such a signing statement was President Clinton’s statement upon signing the Omnibus Consolidated Appropriations Act, 1997:

“This bill is good for America, and I am pleased that my Administration could fashion it with the Congress on a bipartisan basis. It moves us further down the road toward our goal of a balanced budget while protecting, not violating, the values we share as Americans—opportunity, responsibility, and community.”[6]

The signing statement goes on to discuss specific parts of the act in similar fashion. In other signing statements, presidents have offered their interpretation of or have explained how agencies will execute a new law. Presidents also have raised constitutional concerns or objections to new statutes in signing statements. In some instances, a single signing statement serves some or all of these purposes. In other cases, presidents have issued multiple signing statements with different purposes for a single law. Not all laws have accompanying signing statements.

According to the Congressional Research Service, presidential “signing statements have become increasingly common since the Reagan Administration” and have been used by Presidents to raise constitutional or interpretive objections to congressional enactments.[7] Both the Senate and House of Representatives have held hearings in the past year on signing statements.[8]

For fiscal year 2006, the President issued signing statements for 11 of the 12 appropriations acts passed by Congress.[9] These signing statements[10] single out 160 provisions in the appropriations acts that raise some constitutional concern or objection of the President. In some cases, the President used these signing statements to direct the executive branch to construe the provisions in a manner that the President believed would cure the provisions’ perceived constitutional deficiencies.

PRESIDENTIAL CONCERNS AND OBJECTIONS

We categorized each of the 160 provisions specifically identified by the President in the signing statements according to the nature of the President’s concern with or objection to the provision. These concerns or objections are rooted in the President’s understanding of his constitutional role and powers. Based on the language used in the signing statements, we identified 12 interconnected categories of concern or objection. Our understanding of each of the categories and their constitutional bases comes from the brief statements in the signing statements themselves, from the provisions cited therein, and, in some cases, from other executive branch statements.[11]

We list the 12 categories in Enclosure II. For ease of explanation, we sorted these categories into four groups: (1) objections related to the theory of the unitary executive; (2) objections related to the Commander in Chief power, national security, foreign relations, or law enforcement; (3) objections related to the bicameralism and presentment clauses of the Constitution; and (4) miscellaneous categories related to the Recess Appointments Clause and the Fifth Amendment.

We did not address the merits of the President’s interpretation of his constitutional role and powers. Nor did we address the applicability of any particular concern or objection to the specific provisions addressed under that concern or objection. We also did not examine the constitutionality of the provisions to which the President objected.

The Theory of the Unitary Executive

Four of the 12 categories we identified relate to the theory of the unitary executive. The signing statements themselves do not explain the unitary executive theory, but simply assert it as a basis for the President’s concern or objection to a number of different provisions. According to the Office of Legal Counsel (OLC), the theory of the unitary executive is rooted in Article II of the Constitution and, specifically, in the vesting in the President of the executive power[12] and the instruction that the President “take Care that the Laws be faithfully executed.”[13] OLC has opined that these constitutional provisions provide the President a right to control executive branch employees and officers:

“In order to fulfill those [constitutional] responsibilities, the President must be able to rely upon the faithful service of subordinate officials. To the extent that Congress or the courts interfere with the President’s right to control or receive effective service from his subordinates within the Executive Branch, those other branches limit the ability of the President to perform his constitutional function.”[14]

OLC has also described the unitary executive theory this way:

“Because no one individual could personally carry out all executive functions, the President delegates many of these functions to his subordinates in the executive branch. But because the Constitution vests this power in him alone, it follows that he is solely responsible for supervising and directing the activities of his subordinates in carrying out executive functions.”[15]

These two versions are not exclusive, and other versions exist.[16] The signing statements do not specify whether they are adopting either of these versions of the unitary executive theory or some other version.

The provisions in the categories relating to the unitary executive require some action or organization within the executive branch. Common examples are provisions that require some type of communication by an executive branch employee or officer to Congress, such as transmitting information to Congress,[17] consulting with Congress or congressional committees,[18] or making legislative recommendations to Congress.[19] According to OLC, the provisions similar to these are constitutionally suspect because they interfere with the President’s right to control executive branch employees and officers. [20]

The President also objects to certain provisions based on an asserted authority to withhold from Congress information sometimes considered privileged. These provisions require an executive branch entity to provide Congress with information that the President believes could compromise the deliberative processes of the President or interfere with his general constitutional duties.[21] In one case the signing statement links the authority to withhold information to the authority to supervise the unitary executive branch.[22]

Commander in Chief, National Security, Foreign Relations, and Law Enforcement

Four of the twelve categories relate to a function of the federal government in which the President asserts he has the primary constitutional role. The first of these categories contains provisions that could, according to the President, interfere with his constitutional role as Commander in Chief.[23] Such provisions relate to transferring defense articles or services to other nations or international organizations, integrating foreign intelligence information, conducting foreign intelligence operations, and managing the command and control relationships within the Armed Forces.

A second category, also based on the President’s authority as Commander in Chief, relates to the President’s authority to classify and control access to national security information. The signing statements assert that the Supreme Court of the United States has held that the power to classify and control access to national security information does not depend on a legislative grant of authority but flows from the Constitution. The provisions in this category relate to access to or disclosure of national security information to nonexecutive entities, such as congressional committees.

In a third category are provisions that, according to the signing statements, “purport to direct or burden the Executive’s conduct of foreign relations.”[24] According to one signing statement, the Constitution commits to the President the primary responsibility for conducting the foreign relations of the United States.[25] There is no single constitutional provision establishing presidential authority over foreign relations like the Commander in Chief clause. The President does have specific constitutional authority to make treaties and appoint ambassadors with the advice and consent of the Senate, and to receive ambassadors.[26]

A fourth category contains one provision relating to the President’s law enforcement powers. According to the signing statement addressing this provision, decisions on the deployment of law enforcement officials are part of the President’s executive power, and Congress cannot dictate to the President how to wield this power.[27]

Bicameralism and Presentment Clauses of the Constitution

Two of the 12 categories relate to the bicameralism and presentment requirements of the Constitution. The Constitution requires that before a bill can become a law it must pass both the House of Representatives and the Senate (bicameralism) and be presented to the President for his signature (presentment).[28] The President then can sign or veto the bill, but if a bill is vetoed, Congress can vote to override the President’s veto.[29]

The first category related to bicameralism and presentment contains over 70 provisions. The President identified these 70 provisions as implicating the constitutional principles enunciated by the Supreme Court in Immigration and Naturalization Service v. Chadha, 462 U.S. 919 (1983). At issue in Chadha was a statute which allowed a resolution passed by only one house of Congress to override a determination made by the Attorney General under a grant of statutory authority. The Court held that such a “legislative veto” was unconstitutional because it allowed one house of Congress to overrule the Attorney General’s lawful action, instead of both houses voting to overrule the action and presenting the passed bill to the President. Chadha, 462 U.S. at 959. Some of the provisions in this category require agencies to obtain congressional committee approval prior to making certain types of obligations, expenditures, or reprogrammings of appropriated funds. Other provisions require prior approval for a plan for expenditure. In a few cases, the provision directs the agency to submit a report for approval.

In the second category the President refers to bicameralism and presentment, but does not cite Chadha. Many of these provisions require an agency to act in accordance with existing documents, such as joint statements of managers, committee reports, or Senate reports. Although the law refers to these documents, the President declares, “These documents do not satisfy the constitutional requirements of bicameral approval and presentment to the President needed to give them the force of law.”[30]

Miscellaneous Objections

The President also objects to certain provisions that he feels implicate two constitutional clauses not directly related to the others discussed above.

The first of these is the recess appointments clause, which grants the President the power to fill all vacant appointments that occur during the recess of the Senate with a commission that expires at the end of the next congressional session.[31] The President identified one provision in relation to his power to make recess appointments. That provision prohibited the use of appropriated funds to pay the salary of any person serving in a position for which the President nominated the person and the Senate voted not to confirm the nomination. The President declared that the executive branch would “construe this provision in a manner consistent with the President’s constitutional authority to make recess appointments.”[32]

The second of these categories involves the Fifth Amendment to the Constitution, which prohibits the federal government from depriving any person of life, liberty, or property without due process of law.[33] Several signing statements observe that the act accompanied by the signing statement contains provisions which raise an objection or concern under the Fifth Amendment. According to the signing statements, these provisions relate to race, ethnicity, gender, and state residency. Although four signing statements make this observation generally, only one signing statement identified specific provisions.

AGENCY ACTIONS

Of the 160 provisions of law to which the President raised some concern or objection, we selected 19 provisions to examine to determine how the agencies were executing them. This group includes at least one provision from each appropriations act and at least one provision from 11 of the 12 categories of presidential concern or objection we identified.[34]

We contacted the relevant agencies and asked them how they were executing the provisions. After evaluating the responses we received, we determined that agencies failed to execute six provisions as enacted. Ten provisions were executed as written and three provisions were not triggered so there was no agency action to assess. Of the six provisions that agencies did not execute as written, the President objected to three on the grounds that they violated the bicameralism and presentment clauses of the Constitution as enunciated in Chadha. The President objected to two others on unitary executive grounds, and a single provision on the grounds that it infringed on his law enforcement powers. A detailed summary of our findings for each of the 19 provisions appears in Enclosure III. Although we found the agencies did not execute the provisions as enacted, we cannot conclude that agency noncompliance was the result of the President’s signing statements.

Agencies did not execute six provisions as follows:

·        Chadha: The Pension Benefit Guaranty Corporation (PBGC) did not seek approval from the congressional appropriations committees prior to incurring obligations for administrative expenses beyond the level set by Congress in the appropriations act. However, PBGC did notify the committees of its action.

·        Chadha: The Federal Emergency Management Agency (FEMA) did not submit a proposal and expenditure plan for housing as directed by Congress in the appropriations act because, according to FEMA, it does not normally produce such plans.

·        Chadha: The Department of Agriculture did not obtain prior approval for a transfer of funds as required by the applicable appropriations act. However, it did notify the committees prior to transferring the funds and responded to a subsequent congressional request for information.

·        Unitary Executive: The Department of Defense (DOD) did not include as part of the fiscal year 2007 budget submission to Congress separate budget justification documents for the costs of all contingency operations for the Military Personnel, Operation and Maintenance, and Procurement accounts. DOD did provide a separate justification document that included the costs of contingency operations in the Balkans and Guantanamo Bay but did not include costs for any other contingency operations, such as those in Iraq.

·        Unitary Executive: DOD responded to an inquiry from the Chairman of the Subcommittee on Military Quality of Life and Veterans Affairs, House Committee on Appropriations, in 38 days, instead of 21 days as directed by the appropriations act.

·        Law Enforcement: Customs and Border Patrol (CBP) did not relocate its checkpoints in the Tucson sector every 7 days as directed by Congress in the appropriations act. CBP told us that such relocations were not always consistent with CBP’s mission requirements. Instead, CBP shut down its checkpoints for short periods in an effort to comply with what CBP termed the “advisory provision” in the appropriations act.

Three provisions required agencies to take an action only if a certain prior event occurred. The event did not occur, so the portion of the provision to which the President objected was not triggered. For example, if the Department of the Interior (Interior) used its 2006 appropriation for “the emergency reconstruction, replacement, or repair of aircraft, buildings, utilities, or other facilities or equipment damaged or destroyed by fire, flood, storm, or other unavoidable causes,” it was required to seek a supplemental appropriation to replenish the funds promptly.[35] Interior did not use any of its fiscal year 2006 appropriation for these purposes and did not trigger the requirement that it seek a supplemental appropriation.

SIGNING STATEMENTS AND THE FEDERAL COURTS

We also examined how the federal courts have treated presidential signing statements in their published opinions. A search of all federal case law since 1945 found fewer than 140 cases that cited presidential signing statements. When courts did cite signing statements, it was for a variety of reasons. The most common use of a signing statement was to supplement legislative history such as committee reports. Courts have also cited signing statements to establish the date of signing, to provide a short summary of the statute, to explain the purpose of the statute, or to describe the underlying policy behind the statute. After reviewing the courts’ use of presidential signing statements, we determined that, overall, federal courts infrequently cite or refer to them in their published opinions.

Cases containing citations to the signing statements of three acts in particular—the act disapproving the amendments to the Sentencing Guidelines,[36] the Antiterrorism and Effective Death Penalty Act,[37] and the Civil Rights Act of 1991[38]—account for over a third of the cases in which courts have cited or referred to signing statements. Further, citations to signing statements that raise constitutional concerns have appeared in a few cases dealing with the constitutional issues discussed in the signing statements. These constitutional issues include separation of powers principles, foreign relations matters, and federalism constraints. The federal courts have only in rare instances treated signing statements as authoritative sources of interpretation of either statutes or the Constitution. For more information, see Enclosure IV.

SUMMARY

In 11 of the 12 appropriations acts for fiscal year 2006, the President issued signing statements identifying constitutional concerns or objections with some provisions appearing in the acts. In total, the President singled out 160 provisions of law in these 11 signing statements, which we categorized on the basis of the President’s stated concern or objection. We examined 19 of these provisions and found that agencies did not execute 6 of the provisions as written. In 3 instances, the relevant portion of the provision was not triggered. Agencies executed the remaining 10 provisions as written. We also found that federal courts infrequently cite or refer to signing statements and have only in rare instances relied on them as authoritative interpretations of the law.

We hope you find this information useful. Should you have any questions, please contact Susan A. Poling, Managing Associate General Counsel, at 202-512-2667. Assistant General Counsel Carlos Diz, Senior Staff Attorney Wesley Dunn, and Staff Attorney Andrew Jackson Stephens made key contributions to this opinion.

Sincerely yours,

Gary L. Kepplinger

General Counsel

Enclosure I: Scope and Methodology

Enclosure II: Categories of the President’s Objections

Enclosure III: Agency Actions

Enclosure IV: Presidential Signing Statements and Federal Court Opinions

Scope and Methodology

GAO initiated this undertaking at the request of the Chairmen of the Senate Committee on Appropriations and the House Committee on the Judiciary. We began by reviewing the presidential signing statements for all the appropriations acts for fiscal year 2006. The President issued statements upon signing all of the appropriations acts, including the emergency supplemental, with the exception of the Legislative Branch Appropriations Act.[39]

We reviewed the 11 signing statements and identified 160 specific provisions in the appropriations acts that the President addressed in the signing statements. The signing statements indicate that the provisions that the President specifically identifies are not the only provisions in the acts that might raise the cited concerns or objections of the President. Further, in several signing statements, the President raises a concern or objection without specifically identifying any provisions in the act raising that concern or objection. We arrived at the number of 160 provisions by listing all the provisions specifically identified in the signing statements. We chose to be conservative in how we counted. The President cited some provisions under more than one objection; we counted these only once. The President separately cited some subsections of a single provision; we counted all subsections of a provision as only one provision.

We sorted the provisions into 12 categories according to the language the President used in the signing statements to describe his basis of concern or objection. Different signing statements share identical or almost identical language describing the President’s concerns with specific provisions. For example, six signing statements share the following, almost identical, language:

“The executive branch shall construe certain provisions of the Act that purport to require congressional committee approval for the execution of the law as calling solely for notification, as any other construction would be inconsistent with the constitutional principles enunciated by the Supreme Court of the United States in INS v. Chadha.”[40]

Two more signing statements share similar language: “The executive branch shall construe as calling solely for notification those provisions of the Act that are inconsistent with the requirements of bicameral passage and presentment set forth in the Constitution, as construed by the Supreme Court of the United States in 1983 in INS v. Chadha.”[41] We categorized all the provisions noted under this language together. [42]

We then considered which provisions would be appropriate for further inquiry. In examining the provisions, we identified some for which it would be difficult to determine whether the President was executing the provision, either because of the breadth of executive action covered by the provision or because the information would not be readily available due to national security or foreign relations concerns. For example, a provision in the Foreign Operations Appropriations Act conditions funding for counterdrug activities in the Andean region of South America on consultation and reporting to Congress.[43] To assess whether the executive branch complied with this provision, we would have had to inquire about all the counterdrug activities in the Andean region of South America. An example of a provision that was too broad is section 107 of the Military Quality of Life and Veterans Affairs Appropriations Act, which states, “None of the funds made available in this title for minor construction may be used to transfer or relocate any activity from one base or installation to another, without prior notification to the Committees on Appropriations of both Houses of Congress.”[44] For us to determine whether the agencies carried out this provision as written, we would need information regarding how the military has used all the funds appropriated in the act for minor construction and would need to assess whether the military has used them to transfer activities between bases or installations. Of the 160 provisions which the President addressed, 31 fit into these categories, including all of the provisions to which the President objected on the grounds that the provision impinged on his general authority as Commander in Chief.

We did not pursue one provision because it had been overtaken by subsequent events. In his signing statement, the President noted provisions that dealt with the legal rights of detainees in the war on terror, specifically restricting the right of habeas corpus.[45] Subsequently, the United States Supreme Court found that these provisions preserved the right of some detainees to petition for habeas corpus.[46] On October 17, 2006, Congress responded with the Military Commissions Act of 2006 which again restricted the right of habeas corpus for detainees.[47]

Of the remaining 128 provisions for which action on the part of agencies was more readily determinable, we identified 19 provisions to pursue further. These 19 include at least 1 from 11 of the 12 different categories[48] of concern and at least 1 from each of the 11 appropriations acts. For every category that applied to 12 or more provisions, we selected at least 2 provisions to pursue.

For 18 of the 19 provisions, we identified the agency responsible for executing the provision. We then sent a letter to the General Counsels of these agencies describing the provision and the President’s signing statement and asking how the agency had complied with the provision in the appropriations act, what form that compliance or noncompliance took, and to provide us with all relevant documentation. After receiving the agency responses, we contacted the agencies with follow-up questions as needed. We also researched the history of some of the provisions to better understand the nature of the requirement and the agencies’ responses. We did not determine whether agency noncompliance was a result of the President’s signing statement.

One of the 19 provisions did not relate to action by an agency. That provision forbids the payment of any appropriated funds to any person filling a position for which he or she was nominated if the Senate voted not to approve the nomination.[49] Regarding this provision, we searched for all nominees on whom the Senate voted not to approve their nomination within the last 20 years and then confirmed that the nominees were not currently employed in the positions for which they were nominated.

We also reviewed the history of the use of signing statements in the federal courts. We searched in legal databases for federal court cases from 1945 to May 2007 that cited presidential signing statements. We reviewed these cases and analyzed the purposes for which the courts cited the signing statements.

Categories of the President’s Objections

Categories of provisions	Appropriation acts[50] where provision appears	Specific provisions cited by the President in the signing statements[51]	Number of provisions in each act in each category	Number of provisions in each category
Categories related to the theory of the unitary executive
Provisions that the executive branch shall construe “in a manner consistent with the President’s authority to supervise the unitary executive branch”	Agriculture	sect. 719	1	4
	Transportation	sect. 836; Office of Management and Budget, “Salaries and Expenses”	2
	Homeland Security	sect. 529	1
Provisions that “purport to make consultation with Congress a precondition to the execution of the law” which shall be construed “in a manner consistent with the President’s authority to supervise the unitary executive branch”	Energy and Water	sect. 101; sect. 303	2	18
	Foreign Operations	sect. 506; sect. 509; sect. 512; sect. 534; sect. 543; sect. 564; sect. 576; sect. 595; USAID, “Transition Initiatives”; Department of State, “Andean Counterdrug Initiative”; Department of the Treasury, “Debt Restructuring”	11
	Defense	Office of Justice Programs, “State and Local Law Enforcement Assistance”	1
	Interior	National Park Service, “Historic Preservation Fund”; Environmental Protection Agency, “State and Tribal Assistance Grants”; Smithsonian Institution, “Administrative Provisions”	3
	Emergency Supplemental	sect. 1304	1
Provisions that purport to require the executive branch to make recommendations to Congress which shall be construed in a manner consistent with the President’s authority to supervise the unitary executive branch	Agriculture	sect. 715	1	13
	Defense	sect. 8010; sect. 8100; sect. 8032; sect. 8037; “Operation and Maintenance, Defense-Wide”	5
	Interior	sect. 101; sect. 103	2
	Transportation	sect. 182; sect. 208; sect. 219; sect. 315; sect. 818	5
Provisions that mandate or regulate the submission to Congress or other entities of information that “could impair . . . the deliberative processes of the Executive, or the performance of the Executive’s constitutional duties”	Labor	Health and Human Services, “Office of the Secretary, General Departmental Management”	1	7
	Veterans Affairs	sect. 126	1
	Transportation	sect. 120; sect. 182; sect. 818; sect. 820; “Operating Subsidy Grants to the National Railroad Passenger Corporation”	5
Categories related to the Commander in Chief power, national security, foreign relations, and law enforcement
Provisions the executive branch will construe consistent with the President’s constitutional authority as Commander in Chief[52]	Defense	sect. 8059; sect. 8104; sect. 8106; sect. 8119	4	4
Provisions that infringe on “the President’s authority to classify and control access to information on national security”	Defense	sect. 8007; sect. 8011; sect. 8093	3	11
	Homeland Security	sect. 516	1
	Veterans Affairs	sect. 107; sect. 110; sect. 113; sect. 118	4
	Emergency Supplemental	sect. 1209; sect. 2202; “Joint Improvised Explosive Device Defeat Fund”	3
Provisions that “purport to direct or burden the Executive’s conduct of foreign relations”	Foreign Operations	sect. 506; sect. 514; sect. 551; sect. 561; sect. 562; sect. 575; sect. 590; sect. 593	8	16
	Veterans Affairs	sect. 118	1
	Science	sect. 405; sect. 413; sect. 414; sect. 631; sect. 637; “International Trade Administration, Operations and Administration”; “Contributions for International Peacekeeping Activities”	7
Provision relating to decisions on the deployment of law enforcement officials	Homeland Security	Customs and Border Protection, “Salaries and Expenses”	1	1
Categories related to the bicameralism and presentment clauses of the Constitution
Provisions that require the approval of a congressional entity and implicate “the principles enunciated by the Supreme Court of the United States in INS v. Chadha”	Agriculture	sect. 705; sect. 716; sect. 732; Food and Drug Administration, “Salaries and Expenses”	4	70
	Defense	sect. 8005	1
	Veterans Affairs	sect. 128; sect. 129; sect. 130; sect. 201; sect. 211; sect. 216; sect. 225; sect. 226; sect. 227; sect. 229; “Department of Defense Base Closure Account 2005”; Department of Veterans Affairs, “Information Technology Systems”; Department of Veterans Affairs, “Construction, Major Projects”	13
	Homeland Security	sect. 504; sect. 538; sect. 518; sect. 505; sect. 509; sect. 511; sect. 526; “United States Visitor and Immigrant Status Indicator Technology”; Customs and Border Protection, “Automation Modernization”; Customs and Border Protection, “Air and Marine Interdiction, Operation, Maintenance, and Procurement”; Immigration and Customs Enforcement, “Automation Modernization”; United States Secret Service, “Salaries and Expenses”; “Research, Development, Acquisition, and Operations—Science and Technology”	13
	Interior	sect. 130; sect. 405; sect. 421; sect. 422; sect. 435; United States Fish and Wildlife Service, “Administrative Provisions”; National Park Service, “Construction”; Department Management, “Salaries and Expenses”; Natural Resources Damage Assessment and Restoration, “Administrative Provisions”; Forest Service, “Wildland Fire Management”; Forest Service, “Administrative Provisions”; Indian Health Service, “Administrative Provisions”; Smithsonian Institution, “Administrative Provisions”	13
	Labor	sect. 103; sect. 208; “Pension Benefit Guaranty Corporation Fund”	3