This is the accessible text file for GAO report number GAO-06-528T entitled 'Capitol Visitor Center: Status of Project's Schedule and Cost as of March 15, 2006' which was released on March 15, 2006. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. Because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Testimony: Before the Subcommittee on the Legislative Branch, Committee on Appropriations, U.S. Senate: United States Government Accountability Office: GAO: For Release on Delivery Expected at 10:30 a.m. EST: Wednesday, March 15, 2006: Capitol Visitor Center: Status of Project's Schedule and Cost as of March 15, 2006: Statement of Bernard L. Ungar, Director: Terrell Dorn, Assistant Director: Physical Infrastructure Issues: GAO-06-528T: Mr. Chairman and Members of the Subcommittee: We are pleased to be here today to assist the Subcommittee in monitoring progress on the Capitol Visitor Center (CVC) project. Our remarks will focus on the Architect of the Capitol's progress in achieving selected project milestones and in managing the project's schedule since the Subcommittee's February 15, 2006, hearing on the project.[Footnote 1] As part of this discussion, we will address a number of key challenges and risks that continue to face the project, as well as actions AOC has taken or plans to take to address these risks. In addition, we will discuss the status of the project's costs and funding. Our remarks today are based on our review of schedules and financial reports for the CVC project and related records maintained by AOC and its construction management contractor, Gilbane Building Company; our observations on the progress of work at the CVC construction site; and our discussions with the CVC team (including AOC and its major CVC contractors), AOC's Chief Fire Marshal, and representatives from the U.S. Capitol Police. We also reviewed AOC's construction management contractor's periodic schedule assessments and daily reports on the progress of interior wall and floor stonework. In summary: Since the Subcommittee's February 15 CVC hearing, the CVC team has continued to move the project's construction forward, but we continue to believe, as we said at the February hearing, that AOC's proposed opening dates--April 2007 for the base CVC project and May 2007 for the House and Senate expansion spaces--do not allow enough time to complete several critical activities and to address problems, challenges, risks, and uncertainties. During the past month, the CVC team has essentially maintained the pace of critical interior wall stone installation, developed a draft work plan for floor stone installation, started to develop a work plan to prevent a stacking of trades[Footnote 2] during finish work, and maintained the opening dates that AOC announced at the February CVC hearing. However, the number of activities critical to the project's timely completion has increased, and several of these activities are now scheduled to take longer to complete than planned. In addition, wall stone deliveries are still backlogged, critical building systems still have to be commissioned and tested, and although the project's overall design is essentially complete, certain design elements are still incomplete or are being clarified or refined. If the CVC team is successful in addressing these issues, we believe that the base CVC project can be opened to the public with a temporary cap on visitor occupancy in May 2007 and that the expansion spaces can be opened for occupancy beginning in mid-August to early September 2007. Congress may even be able to occupy the expansion spaces earlier if AOC implements a phased opening plan it is considering and if AOC is able to perform acceptance testing of the CVC and the expansion spaces concurrently rather than sequentially--a possibility AOC is continuing to explore. Nonetheless, we believe that AOC will be challenged to meet the later dates we are projecting because of the problems, challenges, risks, and uncertainties facing the project. We currently estimate that the total cost to complete the entire CVC project is about $556 million without an allowance for risks and uncertainties. This estimate exceeds our February 15 estimate by about $1 million because AOC now preliminarily estimates that it will need about that much to pay for contractual support needed to complete acceptance testing of the facility's fire protection system in time to meet the project's schedule. AOC plans to use its general administration appropriations for this work, including funds for fiscal year 2006 that it has on hand and about $950,000 in fiscal year 2007 funds that Congress has not yet provided. To date, about $528 million has been provided for CVC construction. We continue to estimate that AOC will need about $25.6 million more in CVC construction funds to complete the entire CVC project without an allowance for risks and uncertainties and taking into account funding AOC plans to use from existing appropriations. Our $584 million estimate of the cost to complete the entire project with an allowance for risks and uncertainties remains unchanged because the cost of acceptance testing is one of the uncertainties covered by this allowance. AOC Has Moved Construction Forward, but the Project Continues to Experience Delays and Face Risks and Uncertainties: AOC's February 2006 schedule shows, as did its January 2006 schedule, that the CVC base project will be ready to open to the public with a temporary certificate of occupancy on February 13, 2007, and that the House and Senate expansion spaces will be ready for occupancy on April 24, 2007. To allow for possible delays and start-up time for operations, AOC has proposed an April 2007 opening date for the base project and a May 2007 occupancy date for the expansion spaces. AOC expects all construction work in the CVC, East Front, and expansion spaces to be completed by the April opening date for the base project, but the CVC's occupancy at any one time will be temporarily limited to 3,500, compared with about 4,200, the normal anticipated occupancy level.[Footnote 3] Our Analysis Indicates Later Opening Dates Than AOC Is Proposing: We continue to believe, as we testified in February, that the CVC is more likely to be ready for opening with a temporary certificate of occupancy by about the end of May 2007 than by April 2007, as AOC is proposing. Our projected opening is somewhat later than AOC's because CVC team managers and members we interviewed believe that certain work, such as interior stonework and finish work for the base project and East Front, will take longer to complete than the revised schedule allows. Our projection also assumes that AOC will be successful in addressing the challenges it faces and takes into account the time that AOC believes will be necessary to prepare for operations after construction work is completed. Similarly, we continue to believe that the House and Senate expansion spaces are more likely to be ready in mid-August or early September 2007 than in April or May 2007, as AOC is proposing. We consider the later time frames more likely for two reasons. First, AOC has scheduled the acceptance testing of the expansion spaces after the acceptance testing of the base project and, according to our analysis, the base project's testing will take longer than scheduled. Second, AOC's Chief Fire Marshal believes the acceptance testing of the expansion spaces will take longer than scheduled. However, the expansion spaces could be ready sooner if AOC advances the schedule for the acceptance testing--a possibility AOC is exploring. Although construction work has been progressing and the sequence 2 contractor has met several schedule milestones, delays have continued in a number of areas, and ongoing risks and uncertainties could cause further delays. AOC's construction management contractor reported that, in terms of the dollar value of the work in place, the overall CVC project was about 77 percent complete and the sequence 2 work was about 63 percent complete as of February 28-up from about 74 percent and 59 percent, respectively, as of January 31. Furthermore, as of March 13, the sequence 2 contractor had completed work on five of the nine schedule milestones that were due to be completed by today's hearing, according to the project's January 2006 schedule. Three of the five were completed on time or ahead of schedule. (See table 1 in app. I.) According to AOC's construction management contractor, during the last 4 weeks, the sequence 2 contractor installed 4,363 pieces of interior wall stone, compared with its 4,794-piece wall stone installation target, but installed only 1,590 square feet of its preliminary 3,600 square-foot floor stone installation target. (See table 2 in app. I.) In addition, in measuring the sequence 2 contractor's February performance against the project's January 2006 schedule, AOC's construction management contractor reported delays in 12 of the 20 activity paths identified as important to meeting the base project's overall completion date. These delays included, but were not limited to, work in the East Front, the exhibit gallery, the auditorium, the utility tunnel, the great hall, and the orientation theaters and ranged from 2 to 36 work days, but did not affect the base project's overall completion date.[Footnote 4] According to the CVC team, the delays occurred for a variety of reasons, such as design changes, problematic sequence 1 work, late submissions or approvals of shop drawings, and changes in the sequence of work activities by the sequence 2 contractor. Finally, in its CVC progress report for February, AOC's construction management contractor said that the sequence 2 contractor's monthly billings (reflecting the value of construction work done relative to the project's schedule) were generally not sufficient to meet AOC's currently scheduled completion date. The construction management contractor's February progress report also showed that several House and Senate expansion space activities had fallen behind the project's January 2006 schedule. These activities involved work on the House and Senate circular stairs, the House and Senate lower levels, and space intended for use by the U.S. Capitol Police on the service level. The CVC team said these activities were delayed because of (1) problems associated with sequence 1 or other sequence 2 work, (2) redesign resulting from the CVC team's misunderstanding of congressional requirements for certain space, or (3) security-related design changes. According to the CVC team, these delays will not affect the schedule for opening the expansion spaces, but could delay the base CVC project's opening if the lost time cannot be recovered, since certain expansion space work must be completed before the CVC can be opened to the public. At this time, the sequence 2 subcontractor doing the expansion space work believes that most, if not all, of the lost time can be recovered and that all expansion space construction work necessary for the CVC's opening will be completed by December 31, 2006. Project's Schedule Remains Vulnerable to Problems, Challenges, Risks, and Uncertainties, Despite Actions AOC Has Taken and Plans to Take: As we indicated during the Subcommittee's February 15 CVC hearing, we believe that AOC will be challenged to meet even the later opening dates we have identified, given the problems, challenges, risks, and uncertainties facing the project. A brief update on these, as well as on AOC's actions and plans for addressing them, follows: * Delivery of stone and pace of stone installation remain critical. In the 4 weeks preceding today's hearing, the sequence 2 contractor reported receiving 9 of the 10 truckloads of interior wall stone it was expecting from the stone fabricator, but had not received any of the 20- truckload backlog. According to AOC, the supply of interior wall stone is adequate for the CVC at this time, given the quantity on hand, providing that the fabricator continues to deliver about 1,000 pieces a week for the next 12 weeks. However, AOC said that the pace of installation is such that additional delays are likely to occur if the fabricator does not deliver the needed stone on time. According to AOC's construction management contractor, the sequence 2 contractor has installed 4,363 pieces of interior wall stone since the last hearing, meeting about 91 percent of its production target. By contrast, the sequence 2 contractor has installed only about 1,590 square feet of floor stone, or about 44 percent of the quantity specified in a preliminary floor stone installation plan that the contractor provided to AOC shortly after the February 15 hearing. In addition, seven of the nine schedule milestones that AOC and we have been tracking for the Subcommittee for today's hearing are related to interior wall stone installation, and the sequence 2 contractor has met three of these seven milestones. Although the sequence 2 contractor has recently increased the number of stone masons working on the project, delays are likely if the targets for interior wall and floor stone installation are not achieved. The targets could possibly be missed if the masons are less productive than planned, work spaces are not ready or available for stonework to begin, or the fabricator fails to deliver stone on time. During the February 15 hearing, we noted that it was critically important for the CVC team to aggressively address this area. AOC and its construction management contractor agreed and have been tracking interior wall stone installation daily. In its February CVC progress report, AOC's construction management contractor noted that interior wall stone delivery was the most critical issue at that time. * Trade stacking could delay completion. As we discussed during the Subcommittee's February 15 CVC hearing, trade stacking could hold up finish work, such as drywall or ceiling installation, electrical and plumbing work, plastering, or floor stone installation. This work could be stacked if wall stone is not installed on schedule. Although the pace of wall stone installation was essentially maintained in February, it is not, according to AOC's construction management contractor, sufficient to eliminate the risk of trade stacking and delays in finish work. Such a situation could also increase the risk of accidents and injuries. Hence, it remains important, as we said at the February CVC hearing, for the CVC team to closely monitor construction to identify potential trade stacking and promptly take steps to avoid or, if necessary, address it. The CVC team has also identified trade stacking as a high risk, and the sequence 2 contractor has begun to develop area- by-area plans that will show when each subcontractor will be working in each area. The sequence 2 contractor expects to complete these plans over the next few weeks and to meet regularly with its subcontractors to review and update the plans. We believe this is a positive step but note that further delays in completing wall stone installation could still limit the available work space, making it difficult for all the trades to complete their work on schedule. AOC agrees and plans to monitor this situation during its weekly risk management meetings with the CVC team. * Complex building systems remain a significant risk. The CVC will house complex building systems, including systems for heating, air conditioning, and ventilation; fire protection; and security. These systems not only have to perform well individually, but their operation also has to be integrated. If the CVC team encounters any significant problems with their functioning, either individually or together, during commissioning or acceptance testing, the project could be seriously delayed. The shop drawings for the CVC's fire protection system, which are expected by the end of this week, have not yet been approved by AOC's Chief Fire Marshal. Delays could arise if the proposed system does not meet the design specifications or fire protection code requirements. In addition, the Chief Fire Marshal notes that delays could arise if the CVC team does not adequately pretest the system and correct any problems found during the pretesting. The CVC team is aware of these risks and has been taking steps to mitigate them as part of its risk management process. During the Subcommittee's February 15 CVC hearing, we suggested that the CVC team reassess its risk mitigation plans to ensure that it has identified the steps necessary to prevent major problems during the building systems' commissioning or testing and has measures in place to deal quickly with any such problems should they arise. AOC agreed and said that the CVC team will be continuously assessing this situation as part of its risk management process. It is also important to note that the Chief Fire Marshal's timely completion of the fire protection system's acceptance testing depends on his ability to obtain sufficient funding for a contractor to help his staff perform the tests. We will discuss this funding issue later in our testimony. * Building design continues to evolve. The CVC has undergone a number of design changes. Some of these changes, such as changes in the exhibit gallery and in the East Front, have resulted in delays. In addition, designs or shop drawings for some elements of the project, such as certain security features, space for the Capitol guide service, and aspects of the facility's fire protection systems, have not yet been completed or fully approved and are subject to change. Moreover, eight design changes or clarifications have been issued since January 25, 2006. Additional design changes are being considered and have the potential to cause further delays. During the Subcommittee's February 15 CVC hearing, we said it would be important for the CVC team to carefully consider the need for proposed scope and design changes and try to minimize the impact of necessary changes on the project's schedule and cost. AOC agreed and said it plans to make only necessary design changes. * Multiple critical activity paths complicate schedule management. In reporting on the project's February 2006 schedule, AOC's construction management contractor identified 20 critical activity paths that are important to the project's on-time completion--2 more paths than the contractor identified in reporting on the project's January 2006 schedule. According to the contractor's report on the project's February 2006 schedule, several of these activities fell behind schedule during the month and could delay the project's completion if the lost time cannot be recovered. As we have said in a number of our previous testimonies on the CVC, having a large number of critical and near-critical activities complicates project management and increases the risk of missing completion dates. We believe that the CVC team will be particularly challenged to manage all of these areas concurrently and to deal effectively with problems that could arise within these areas, especially if multiple problems arise at the same time. During our February 15 testimony, we said that it would be important for the CVC team to reassess its capacity to effectively manage and coordinate the schedule and work for the remainder of the project. According to AOC, the CVC team has done this and believes that it has the needed capacity. While we believe that the steps being taken by the sequence 2 contractor to address trade stacking should, if effectively implemented, help in managing these critical activities, we continue to be concerned about this issue and plan to monitor it closely as the project proceeds. * Opening the CVC and expansion spaces at different times is likely to result in a temporary cap on CVC occupancy and increase costs. As we reported during the Subcommittee's February 15 CVC hearing, AOC's current plan to open the CVC in April 2007 before the expansion spaces are scheduled for completion is likely to result in a temporary cap on visitor occupancy and a need to construct temporary emergency exits for fire and life safety protection.[Footnote 5] AOC is proposing this sequential approach because it believes that conducting the acceptance testing for the fire protection system for the CVC and the expansion spaces concurrently would delay opening the CVC to the public. Although AOC has not yet estimated the additional costs associated with the temporary measures that would need to be taken, it does not believe they will be substantial. During our February 15 testimony, we said that it would be important for AOC to identify and consider the pros and cons (including the estimated costs) of opening the CVC and expansion spaces at about the same time and provide this information to Congress. AOC agreed and said that a senior superintendent with its construction management contractor will be evaluating this situation and that AOC will provide the information to Congress when the evaluation is complete. Finally, as we have said in previous discussions with AOC, its construction management contractor, and the Subcommittee, it will be important for AOC to have adequate analysis and documentation of the reasons and responsibilities for delays.[Footnote 6] We discussed this issue with AOC and its construction management contractor again last week, and they agreed to reassess this area and get back to us after the reassessment is done. They said that although they had received requests related to accelerating sequence 2 work, they had not yet received any requests from contractors for payment of costs related to delays encountered during sequence 2. However, they consider such requests likely in the future and agree that they need good information for evaluating them. Need for Additional Funding Has Grown: In February, we estimated that the total cost to complete the entire CVC project would be about $555 million without an allowance for risks and uncertainties and could be as much as about $584 million with such an allowance. To date, about $528 million has been provided for CVC construction. This amount does not include about $7.7 million that was made available for either CVC construction or operations.[Footnote 7] According to AOC, it expects to use about $2 million of this amount for construction. To obtain the additional funding that it expected to need to complete the project's construction, AOC, in December 2005, requested $20.6 million as part of its budget request for fiscal year 2007. This request was based, in part, on discussions with us and took into account our November 16, 2005, estimate of the cost to complete the project's construction without an allowance for risks and uncertainties and funding from existing appropriations. Our subsequent work--completed in preparation for the Subcommittee's February 15 CVC hearing--indicated that AOC would need about $5 million more, or about $25.6 million in additional funds, to complete construction without an allowance for risks and uncertainties. AOC has indicated that it plans to request this additional $5 million as a supplement to its fiscal year 2007 budget for CVC construction. In February 2006, AOC contracted with a fire protection engineering firm, in part, to help AOC's Fire Marshal Division inspect, test, and review plans for the CVC's fire protection system. AOC has not yet received the final shop drawings for this system, but it preliminarily estimates that these contractual support services will cost about $1,150,000. According to AOC, it may be able to reduce these expected costs and it will be exploring ways to do so. On the basis of AOC's preliminary estimate and belief that the expected costs may be reduced, we added $1 million to our $555 million estimate of the cost to complete the entire project without an allowance for risks and uncertainties, bringing our total estimate to $556 million. We did not, however, change our $584 million estimate of the cost to complete the entire project with an allowance for risks and uncertainties, since contractual support costs for acceptance testing would be covered under such an allowance. Nor did we change our $25.6 million estimate of the additional CVC construction funds AOC would need because AOC has used and plans to use a different appropriation account to pay for this contractual support. AOC has used and plans to use its general administration account because this contractual support is needed to accommodate an overall increase in the Fire Marshal Division's workload, including its CVC-related work. AOC plans to use a total of $200,000 in fiscal year 2006 general administration appropriations to pay for contractual support for the CVC's acceptance testing and has requested another $450,000 in fiscal year 2007 general administration appropriations. After AOC has received the final shop drawings for the CVC's fire protection system and has explored ways to reduce the cost of needed contractor support, it plans to reprioritize its fiscal year 2007 general administration budget request to obtain the remainder of the funding needed. At this time, AOC expects this amount to be somewhat less than $500,000, which would bring the total fiscal year 2007 funding needed for contractual support for CVC acceptance testing to about $950,000. We plan to monitor and report to the Subcommittee on these costs as soon as AOC has a firmer estimate. Mr. Chairman, this completes our prepared statement. We would be pleased to answer any questions that you or Members of the Subcommittee may have. Contacts and Acknowledgments: For further information about this testimony, please contact Bernard Ungar at (202) 512-4232 or Terrell Dorn at (202) 512-6923. Other key contributors to this testimony include Shirley Abel, John Craig, Maria Edelstein, Elizabeth Eisenstadt, Brett Fallavollita, Jeanette Franzel, Jackie Hamilton, Bradley James, Scott Riback, and Regina Santucci. [End of section] Appendix I: Capitol Visitor Center: Critical Construction Milestones and Stone Installation Targets, February 16-March 15, 2006: Table 1 compares the actual with the scheduled completion dates for critical sequence 2 construction milestones scheduled to be completed by March 15, 2006. Table 2 compares the actual with the targeted pace of wall and floor stone installation. The targets for wall stone installation are related to the wall stone milestones identified in table 1. The preliminary targets for floor stone installation are related to milestones that are scheduled to be completed after March 15, 2006. Table 1: Critical Construction Milestones, February 16-March 15, 2006: Activity: Wall Stone Area 2; Location: East Front Basement; Scheduled completion: 3/06/06. Activity: Wall Stone Area 2 Pedestals; Location: Orientation Lobby Upper Level; Scheduled completion: 2/16/06; Actual completion: 3/08/06. Activity: Wall Stone Area 1 Base; Location: Orientation Lobby Upper Level; Scheduled completion: 2/20/06; Actual completion: 2/20/06. Activity: Wall Stone Area 1; Location: Orientation Lobby Upper Level; Scheduled completion: 3/06/06; Actual completion: 3/02/06. Activity: Wall Stone Area 3 Base; Location: Orientation Lobby Upper Level; Scheduled completion: 3/10/06; Actual completion: 2/20/06. Activity: Interior CMU Walls; Location: East Front Subbasement; Scheduled completion: 2/06/06; Actual completion: 2/21/06. Activity: Hang VP Drywall Ceiling; Location: Congressional Auditorium Lower Level; Scheduled completion: 3/13/06. Activity: Wall Stone Area 1; Location: East Front Basement; Scheduled completion: 2/20/06. Activity: Install Pipe Sta. 0+00-2+00; Location: Utility Tunnel; Scheduled completion: 3/08/06. Source: AOC's January 2006 CVC sequence 2 construction schedule for the scheduled completion dates and AOC and its construction management contractor for the actual completion dates as of March 13, 2006. [End of table] Table 2: Targets for Wall and Floor Stone Installation through March 11, 2006: Week starting: 13 Feb. 2006; Pieces of interior wall stone stone: Target: 1,060; Pieces of interior wall stone stone: Actual: 1,054; Square feet of interior floor: Preliminary target: 500; Square feet of interior floor: Actual: 150. Week starting: 20 Feb. 2006; Pieces of interior wall stone stone: Target: 1,280; Pieces of interior wall stone stone: Actual: 1,214; Square feet of interior floor: Preliminary target: 500; Square feet of interior floor: Actual: 0. Week starting: 27 Feb. 2006; Pieces of interior wall stone stone: Target: 1,180; Pieces of interior wall stone stone: Actual: 1,046; Square feet of interior floor: Preliminary target: 1,200; Square feet of interior floor: Actual: 740. Week starting: 6 Mar. 2006; Pieces of interior wall stone stone: Target: 1,274; Pieces of interior wall stone stone: Actual: 1049; Square feet of interior floor: Preliminary target: 1,400; Square feet of interior floor: Actual: 700. Week starting: Total; Pieces of interior wall stone stone: Target: 4,794; Pieces of interior wall stone stone: Actual: 4,363; Square feet of interior floor: Preliminary target: 3,600; Square feet of interior floor: Actual: 1,590. Source: Sequence 2 contractor for targets and AOC's construction management contractor for actual amounts installed. According to the sequence 2 contractor, the targets for floor-stone installation are preliminary and may change. [End of table] FOOTNOTES [1] GAO, Capitol Visitor Center: Results of Risk-based Analysis of Schedule and Cost, GA0-06-440T (Washington, D.C.: Feb. 15, 2006). [2] Trade stacking can occur when workers from different trades, such as stone masons, electricians, plumbers, or plasterers, have to work in the same area at the same time to meet a schedule, sometimes making it difficult to ensure sufficient space and resources for concurrent work. [3] This temporary limit will be necessary because the "horizontal exits," or passages, through the expansion spaces, which the life safety code requires for exiting the base CVC project, will not be available until later. These horizontal exits cannot be used until the fire alarm system in the expansion spaces has been fully tested and accepted--work that is not slated to be completed until after the base CVC is scheduled to open. Some additional work will likely be required to provide temporary emergency exit routes from the CVC, but the CVC team does not believe that this work or its costs should be substantial. [4] However, several activities, including interior wall stone installation, penthouse mechanical work, and East Front fire protection system acceptance testing, were delayed to the extent that even relatively short additional delays could affect the CVC's overall completion date. [5] According to AOC, the CVC's occupancy at any one time would be temporarily limited to 3,500, compared with about 4,200, the normal anticipated occupancy level, until acceptance testing of the fire protection system for the expansion spaces has been completed. [6] See for example: GAO, Capitol Visitor Center: Effective Schedule Management and Updated Cost Information Are Important, GAO-05-811T (Washington, D.C.: June 14, 2005). [7] Public Law 108-447, enacted on December 8, 2004, provided that up to $10.6 million could be transferred from AOC's Capitol Building appropriation account for the use of the CVC project. The use of the amount transferred is subject to the approval of the House and Senate Committees on Appropriations. In June 2005, AOC received approval to use about $2.8 million of this $10.6 million, leaving a balance of about $7.7 million that can be used in the future after a rescission amounting to $84,800. AOC recently received approval to use more of these funds; we will discuss this in our testimony for the next CVC hearing.