oregon wireless interoperability network: controls needed in
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Oregon Wireless Interoperability Network: Controls
Needed in Partnership and Site Acquisition Processes
Report No. 10-05
November 3, 2010
Marlene Hartinger, Chief of Audit Services Julie Ratcliff, Senior Internal Auditor
Sarah Myers, Senior Internal Auditor
Oregon Department of Transportation
AUDIT SERVICES
3930 Fairview Industrial Dr. SE ▪ Salem, Oregon ▪ 97302 ▪ (503) 986-4177
November 3, 2010
ODOT Audit Committee Members:
Matt Garrett, Director and Committee Chairman
Alan Brown, Commissioner
Jerri Bohard, Deputy Director, Operations
Clyde Saiki, Deputy Director, Central Services Division
Gregg Dal Ponte, Administrator, Motor Carrier Division
Tom McClellan, Administrator, DMV
Les Brodie, Chief Financial Officer, Financial Services
Dear Committee Members:
This audit, requested by the Major Projects Branch Manager, focuses on site acquisition and
partnership processes within the Oregon Wireless Interoperability Network (OWIN), which
has recently been transferred to ODOT. The objectives of this audit were to (1) determine the
adequacy of controls over partnership and site acquisition processes, and (2) determine the
extent to which partnership agreements demonstrate equity to the state.
Overall, we found that current controls over site acquisition and partnership processes are
inadequate. Budget information to monitor program performance, a key program control, is
incomplete and documentation supporting site acquisition decisions is lacking. The lack of
good information about the program means that oversight bodies have limited ability to
monitor the program effectively. We also found serious implementation problems at most of
the sites we reviewed; such as OWIN issuing an unauthorized sublease, ordering equipment
prematurely, allowing unauthorized equipment installation, and conducting work on sites
which will not be part of the OWIN network. Additionally we found that individuals without
the appropriate authority signed agreements, and management approved agreements
without adequate legal review. Key factors contributing to these control deficiencies include:
not following stated processes, multiple and inconsistent definitions for key terms, and a
project schedule that creates pressure to get sites developed without adequate information
or procedures. These control deficiencies have adverse consequences on the program, staff,
management, and those conducting oversight. This report includes recommendations to
address these control deficiencies.
We also found that the value of partnerships cannot be demonstrated with existing
information. OWIN has stated in program documents that its partnership agreements will
save $60 million in project costs, but we found that this savings estimate has no sound
methodological basis. Some agreements contain promises that are not in the state’s best
interests, such as providing construction and project management services to develop sites
that will not be utilized as part of the OWIN network. Further, OWIN lacks controls to ensure
that negotiations produce an equitable outcome. This report makes recommendations for
strengthening controls over the documentation and accounting of partnerships, and the
development and approval of partnership agreements.
We made multiple recommendations to develop better budgeting and oversight, improve
policies and procedures, and ensure that partnership agreements are equitable and effective.
Please contact me at (503) 986-4177 if you have questions about this report. Julie Ratcliff and
Sarah Myers, Senior Internal Auditors, conducted this audit.
Sincerely,
Marlene V. Hartinger, MBA, CPA, CIA
Chief of Audit Services
Oregon Department of Transportation
AUDIT SERVICES
TABLE
OF
CONTENTS
Summary 1
Background 2
Controls Over Partnership and Site Acquisition
Processes Are Inadequate
6
Budget Information to Monitor Program
Performance is Incomplete
7
Documentation Supporting Site Acquisition
Decisions is Lacking
7
Poor Controls Have Adverse Consequences for
Program Staff, Management, and Oversight
8
Decisions on Individual Site Projects Show Serious
Implementation Problems
8
Oversight Bodies Have Limited Ability to Monitor
Program Effectively
11
Several Factors Contribute to Inadequacy of
Controls
12
Technical Information Lacking 12
Units are Not Following Stated Processes 13
Key Terms Have Multiple Definitions, Creating
Inconsistencies in Information
15
Project Schedule Creates Pressure to Get Sites
Developed without Sufficient Information or
Procedures
19
Recent Changes Will Help, but Additional Actions
Needed
19
Equity of Partnership Agreements Cannot Be
Demonstrated with Existing Information
20
Estimate of $60 Million in Savings through
Partnership Agreements Has No Sound
Methodological Basis
21
OWIN Made Promises That Are Not in the State’s
Best Interests
22
OWIN Lacks Controls to Ensure that Negotiations
Produce an Equitable Outcome
23
Conclusion 24
TABLE
OF
CONTENTS
Recommendations 25
Developing Better Budgeting and Oversight 25
Improving Policies and Procedures 26
Ensuring that Partnership Agreements Are
Equitable and Effective
28
Objectives, Scope, and Methodology 28
Management Response 31
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estimate has no sound methodological basis. Some agreements
contain promises that are not in the state’s best interests, such
as providing construction and project management services to
develop sites that will not be utilized as part of the OWIN
network. Further, OWIN lacks controls to ensure that
negotiations produce an equitable outcome. This report makes
recommendations for strengthening controls over the
documentation and accounting of partnerships, and the
development and approval of partnership agreements.
BACKGROUND
In 2002, the Governor became concerned that Oregon’s public
safety communications infrastructure — which is crucial for
enabling public safety professionals to respond to emergencies
— was outdated, at risk of failure, and could not be depended
upon during a crisis. Of additional concern was the system’s lack
of interoperability — that is, public safety agencies were
operating incompatible radio systems which did not allow public
safety officials to communicate directly during emergencies. In
order to respond to these concerns, the Governor created the
State Interoperability Executive Council (SIEC) and charged it
with providing direction for planning and implementing
guidelines and approaches to address these interoperability
issues. In 2005, the emphasis on improved public safety
communications infrastructure was strengthened by passage of
House Bill 2101. This bill created policy to build an interoperable
communications infrastructure that would allow state, local,
federal and tribal public safety agencies to share information
instantly. Specifically, the bill laid the groundwork for the state
to:
1. Replace or upgrade old and broken infrastructure;
2. Fulfill Federal Communication Commission mandates to
convert from wideband to narrowband1 frequencies by
2013; and
3. Consolidate the four existing state agency systems
(ODOT, Oregon State Police, Forestry, and Corrections)
and provide an interoperability interface for all public
safety radio users.
In 2006, the state contracted to analyze Oregon’s public safety
wireless communications systems. The consultant estimated
that the optimum consolidated system would cost $906 million.
1 A wideband system supports high-bit-rate transmission, and a narrowband system supports low-bit-rate transmission.
3
This estimate was significantly higher than the Legislature
anticipated; as a result, the consultant was asked to “value
engineer” the design— that is, to reduce initial construction
costs and allow optimum system levels to be met gradually over
time. The consultant returned with an estimate of $665 million
for a less than optimum system that would meet the needs of
the state for the next 10 to 15 years.
The OWIN project itself was not created until 2007. Through
Senate Bill 136, the Legislature created a project structure
consisting of the SIEC, the Director of OWIN, and the Director’s
employees and subordinate officers. OWIN was tasked with
establishing and managing implementation of an interoperable
public safety communications network. However, public
sentiment was that the revised project estimate of $665 million
was still too high. In an effort to reduce costs of the project,
OWIN developed partnerships with public and private entities,
obtained grants, and decided to internally integrate the
project—which would involve performing program
management. OWIN further identified engineering efficiencies
and savings in operations and services. OWIN reported that,
with the savings it had identified, the estimated cost of the
network would be $414 million. In 2009, the Legislature
approved over $260 million in financing for future work on the
project.
Partnerships and Site
Acquisition
When initial cost estimates for the project were identified,
OWIN explored ways to reduce program costs including creating
partnerships. OWIN estimated that leveraging resources of
partnerships would reduce the project’s costs by $60 million.
The SIEC set direction for the project by creating a strategic goal
to promote collaborative partnerships in order to maximize
resource sharing. OWIN has negotiated partnerships with
private entities, and various public entities including federal,
tribal, state, and local jurisdictions; to date, OWIN reports that it
has signed sharing agreement with 33 partners.
When possible, OWIN tries to partner with owners or tenants of
existing communication sites in order to reduce costs. This
collaborative approach with partners ties partnerships and site
acquisition. Acquiring communication sites is commonly one of
the most difficult challenges of constructing a communication
network the size of OWIN. OWIN estimates approximately 300
sites will be part of the network. A communication site
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generally consists of a fenced compound containing a tower, an
equipment building, and a power generator. At each of these
sites, OWIN must obtain legal and physical possession of the
property, including establishing ownership or leases and right of
way and power easements. Most of OWIN’s proposed locations
already contain some type of communication site.
Site acquisition has been complicated by the fact that OWIN is
not building the interoperability network the way that
communication networks are generally built. Traditionally,
when building a wireless communication project of this scale,
the project owner would issue territorial coverage requirements
and hire a radio vendor to determine where radio sites should
be located to achieve the required coverage. Then, sites would
be acquired. According to OWIN management, due to various
political and economic reasons, OWIN began acquiring and
building sites before the radio system was designed. OWIN is
currently in the process of acquiring a radio vendor to design
the system. Because of this approach, OWIN technical staff has
concerns that the proposed sites will not provide the radio
coverage requirements established.
Project Governance In its initial phases, OWIN was housed within the Office of
Emergency Management (OEM) in OSP. When OEM was
transferred to the Oregon Military Department, OWIN stayed
under the umbrella of OSP. Because of ODOT’s experience and
expertise with large construction projects, the Legislature
transferred OWIN from OSP to ODOT in April 2010. When OWIN
was transferred, the Legislature also “unscheduled” OWIN’s
funding—that is, placed future years’ funding on hold—until an
independent quality assurance (QA) assessment was
performed.
OWIN operates under a governance model and has two
oversight bodies: the SIEC and the Project Steering Committee.
The SIEC’s role is to develop recommendations for policy and
guidelines, identify technology and standards, and coordinate
intergovernmental resources to facilitate statewide wireless
communications interoperability with emphasis on public
safety. The Project Steering Committee is responsible for
approving major project elements and milestones.
The SIEC was created by the Governor and is composed of 17
voting members, including representatives from the four
5
consolidated state agencies, the State Senate, the Association of
Oregon Counties, the State Sheriff’s Association, OEM, the
Oregon Association of Chiefs of Police, the Oregon Tribes, and
others. The Council is divided into five committees: executive,
technical, partnership, strategic planning, and awareness. The
SIEC sets policy for OWIN including defining acceptable
technologies and standards.
The Project Steering Committee is currently chaired by the
Director of Transportation and membership includes heads of
the three other consolidating agencies as well as
representatives of other key stakeholders. They are charged to
prioritize OWIN project deliverables and assure that the OWIN
project schedule meets project milestones. They are also
responsible for assuring that OWIN expenditures are on track
and that budget changes are appropriate.
Project Delivery
Method
OWIN decided to use the Construction Manager/ General
Contractor (CM/GC) project delivery method for creating the
OWIN network. The CM/GC approach creates collaboration
between OWIN, the architectural and engineering (A&E) firm
designing the sites, and the general contractor constructing the
project. By joining the project team during design, the CM/GC
firm can collaborate with the A&E firm on the development of
the design and preparation of the design documents. One
significant benefit of the CM/GC method comes from the close
interaction of the project team members.
According to the Oregon Public Contracting Coalition, “the
benefits resulting from the use of the CM/GC can be greatest
for projects that are high risk, possess a high level of technical
complexity, are governed by significant schedule constraints,
require complex phasing, contain budget limitations requiring a
construction cost guarantee during design, or will realize
substantial cost savings from value engineering analyses. The
primary considerations that should be taken into account when
evaluating CM/GC for use on a project are: time savings, cost
savings, technical complexity, and not diminishing competition
or encouraging favoritism.”
Independent Quality
Assurance Assessment
In response to the Legislature’s “unscheduling” of future
funding, OWIN hired a firm to conduct an independent quality
assurance (QA) review in March 2010. In April 2010, the firm
issued its first report, stating that OWIN was well managed and
6
under control. However, the firm also reported significant high-
risk items which needed to be addressed immediately.
Specifically, the firm reported that OWIN lacked:
• Detailed, comprehensive schedule for project completion;
• Staff with adequate financial experience;
• Established cost controls; and
• The ability to manage funding to meet accounting
standards.
The firm continued its review after issuing this first report and
the second report stated the health of the OWIN program had
significant issues that limit the effectiveness and/or success of
the program. Specifically, the QA vender found that:
• To date, very few sites are ready for construction;
• A comprehensive project schedule which supports the
mandatory completion date has not been established; and
• Detailed budget and cost tracking are lacking.
The Legislature has not rescheduled OWIN’s funding as a result
of the firm’s reports.
CONTROLS OVER
SITE ACQUISITION
AND PARTNERSHIP
PROCESSES ARE
INADEQUATE
The processes used by OWIN’s Site Acquisition and Partnerships
sections lack transparency and accountability. Budget
information to monitor program performance is incomplete and
inaccurate. Further, documentation supporting site acquisition
decisions is lacking. These control deficiencies have adverse
consequences on the program staff, management, and
oversight. Specifically, decisions on individual sites show that
implementation problems are widespread and oversight bodies
have limited ability to monitor the program effectively. The
causes of these deficiencies are that stated processes are not
being followed; terms have multiple definitions, creating
reporting inconsistencies; and the project schedule creates
pressure to get sites developed without sufficient information or
procedures.
While timelines and costs are subject to change over the life of
the project, it is important at any stage of a project to have a
clear idea of where the project actually stands given the
information available at that time. The OWIN project lacks a
documented and consistent baseline budget and individual site
budgets, and OWIN management cannot provide analysis or
documentation to support cost estimates and changes.
7
Additionally, site acquisition documentation is disorganized and
incomplete.
Budget Information to
Monitor Program
Performance is
Incomplete
OWIN reports that by partnering they can save the state
approximately 20 percent or more of the total project cost
versus building the system with no outside resources. They
report “partnership savings” in the amount of $60 million but
management has not been able to provide a defensible
methodology for determining these savings; as such, budgets
which report partnership savings as a quantifiable cost offset are
also not defensible.2 In May 2009, OWIN reported that it had
reduced program costs from $665 million to $414 million by re-
evaluating the independent consultant’s “overbuilt” system.
However, when we asked for documentation supporting
estimated system costs of $414 million, OWIN management was
unable to provide it.
In the September 2009 Financial Management Plan, OWIN
stated that the consultant’s estimate was being phased out and
replaced with an integrated budget that “accurately reflects the
‘OWIN as Integrator’ approach. ” According to the plan, goals of
the updated integrated budget were to provide:
• A baseline to measure actual expenses against projected
costs;
• Updated costs of services and materials;
• Site-level budget figures; and
• Avenues to replace estimates with negotiated contracted
prices and rates.
The plan stated that the integrated budget was being developed
in-house at no additional cost and would be complete by
November 2009. As of July 2010, OWIN had not developed the
budget.
Documentation
Supporting Site
Acquisition Decisions is
Lacking
OWIN lacks a document control process and as a result,
partnership and site acquisition information is kept in many
different locations and in multiple systems (paper files, various
database systems, shared drives, email, etc.). However, none of
the various systems contain complete site information and it is
difficult to assess the accuracy and reliability of information.
Grant information is not contained in files or elsewhere for sites
receiving grant funding; as a result, OWIN does not know what
2 Partnership savings are discussed in on page 21 of the report.
8
their responsibilities or limitations are and cannot ensure they
are fulfilling grant requirements. Additionally, some information
is contained at different agencies and it is often unclear who is
responsible for updating and maintaining information and who
has the most up to date and accurate information. These factors
limit data accessibility and reliability. We noted several other
items of concern during our review of site acquisition files; for
example:
1. Historical documents were not kept in files.
2. Agreements did not contain evidence of legal sufficiency
review.
3. Leases were not tracked in an electronic system, and as a
result, OWIN does not know what leases they have, the
terms, or when they expire.
4. Leases and agreements were in many different locations and
not easily accessible.
5. Fully executed documents were not consistently maintained.
Poor Controls Have
Adverse Consequences
for Program Staff,
Management, and
Oversight
Inadequate controls have created an environment where
decisions are made with inadequate information and where
reports provided to governing bodies, Legislature, and the public
are unclear or inaccurate. Providing unsubstantiated or
incorrect reports to oversight bodies hinders their ability to
effectively perform program governance duties and represents a
significant control deficiency. Further, without accurate and
reliable information oversight bodies will not be able to
effectively and efficiently fulfill their missions, and cost and
completion of the OWIN program will be unknown.
Decisions on Individual
Site Projects Show
Serious
Implementation
Problems
To investigate issues noted during the planning phase we
selected a judgmental sample consisting of fourteen sites alleged
to be problematic and three sites that were not alleged to have
issues. Our review of documentation for the seventeen sites
found that ten of the seventeen had implementation problems,
including:
1. sites where work was performed even though they were
not part of the OWIN network;
2. sites being approved by officials who lacked appropriate
authority to do so;
3. sites being approved without sufficient legal review;
4. a site with an unauthorized sublease;
5. sites in which equipment was installed before an agreement
was executed; and
6. a site where a tower was prematurely ordered.
9
As Figure 1 shows, three of the ten sites had more than one of
these problems. Such problems create legal liability and risk to
the OWIN program, as well as requiring additional resources for
such steps such as retroactively obtaining appropriate rights,
obtaining legal review, or amending agreements.
Figure 1 – Site Implementation Problems
Site
Not Part
of OWIN
Network
Lacked
Appropriate
Authority
Lacked
Legal
Sufficiency
Unauthorized
Subleases
Unauthorized
Entry and/or
Equipment
Installation
Tower
Prematurely
Ordered
Angora
Bear Mountain X
Beaver
Bennett Butte
Carmen Smith
Eagle Crest X
Golgotha X
Halls Ridge X X
Hamacker
Middle Mountain X X
Prairie Peak X
Prospect X X
Seaside X
Skamania
Washburn Butte X
Wilson
Woodburn X
Work Performed on Sites Not Part of OWIN Network
Our sample included two sites that are not going to be part of
the OWIN network, however, OWIN has performed work at the
sites.3 At one site, OWIN will be installing equipment
estimated to be worth in excess of $150,000. In order to install
this equipment, OWIN is also providing engineering and project
management services. At the second site, OWIN is performing
site management, site design, providing NEPA through a state
contract, and assisting with ordering equipment for the
county’s microwave and towers to connect to the OWIN
network, but not be part of it. At both of these sites, OWIN is
3 Seaside and Woodburn Shops.
10
contracting services out to an A&E firm; the current estimate
for A&E work is $18,467. Both supplemental agreements state
that OWIN will not have equipment at these sites.
Agreements Lacked Appropriate Authority
Agreements have been executed by management without
appropriate signature authority. In our sample two sites
exhibited signature authority issues; specifically,
• One agreement was signed by the former Director, who
did not have appropriate authority to execute agreements
over $75,000.4
• A lease amendment was executed by the Southwest
Implementation and Operations Coordinator (SW IO
Coordinator), who lacked signature authority .5
Agreements Lacked Legal Sufficiency Review
Further, two agreements should have gone through the
appropriate legal sufficiency review as their value exceeded
$150,000.6 DOJ has gone through the ratification process for
one of the sites and is in the process of reviewing other OWIN
siting documents and agreements to ensure they meet legal
requirements and are in the state’s best interest. DOJ
estimated that there are eight site-related agreements that will
need to be ratified due to the lack of legal sufficiency review.
Unauthorized Sublease
At one site, OWIN sublet equipment building space to a local
government even though OWIN personnel knew doing so was
in violation of the terms of OWIN’s primary lease. OWIN is
aware that they do not have the right to sublease at the site,
and equipment installation by the local government was not
permitted.
Unauthorized Entry and/or Equipment installation
We also found that OWIN allowed partners to install
equipment before OWIN had obtained consent from the site’s
controlling party to install the equipment or before OWIN had
signed agreements with the partners. OWIN also installed
equipment before they had authority to do so. In either case,
4 Lease at Halls Ridge. 5 Middle Mountain Lease. 6 Eagle Crest and Halls Ridge were executed by the former Director. 7 Golgotha, Bear, Middle Mountain, Prospect, Washburn Butte. 8 Prairie Peak
11
by installing equipment prior to legal authority OWIN lost the
good will of partners, incurred additional administrative
expense, and created a legal liability if anything should happen
to the equipment, structures, the tower, land, etc. In our
sample, we found that parties accessed sites, and in some
cases installed equipment, without authorization at five sites.7
Tower Prematurely Ordered
In June 2009, the Implementation Technical Lead ordered a
tower for a site at a cost of $218,470.8 However, the tower
was purchased before engineering studies were completed. In
June 2010 when the studies were complete, the tower was
deemed insufficient for the site. A replacement tower was
subsequently ordered at a cost of $241,407. Meanwhile, OWIN
has yet to find a place for the original tower and it is being
stored by the manufacturer. Per contract, the manufacturer
does not get paid the final instalment until installation to
ensure the tower meets all specifications. At this point, OWIN
has not paid the manufacturer the final instalment.
Additionally, the tower manufacturer can charge OWIN for
storage fees but has not done so.
Oversight Bodies Have
Limited Ability to
Monitor Program
Effectively
Project success hinges on timely and accurate dissemination of
information and OWIN presented incorrect information to the
Legislature; further, we did not find evidence that the SIEC or
Project Steering Committee reviewed detailed budget
information or Legislative submissions. During our fieldwork,
we asked OWIN for information on partnership efforts,
statuses, and standards. As the Legislature had already
requested this information, OWIN provided us with
information they had submitted to the Legislature. After a
review of LFO requests and OWIN responses, it became clear
that OWIN was not fulfilling Legislative requests; and that
many of the deliverables OWIN provided the Legislature were
incomplete or inaccurate. For example, Legislative
submissions from OWIN contain process documents that are
unknown and unused by OWIN staff, creating an appearance of
established processes where no such processes actually exist.
Reported information contains the following erroneous
information:
• Number and value of partnerships are unsubstantiated
and potentially overstated;
• System cost estimates vary and are not supported;
• Designation of sites reported as “complete” is
12
unreliable;
• Partnership and Site Acquisition processes detailed by
the Project Management Office are inaccurate;
• The “Partnership Management Plan,” which explains
what the partnering process entails, is unknown to
relevant management and staff, including the Quality
Assurance Manager responsible for process mapping;
and
• The procurement process document was an
unapproved draft submitted without staff knowledge.
As a result of incomplete information and requests, the
Legislature developed a lack of confidence in the management
of the program, which was evidenced in the 2010
“unscheduling” of funds. Re-scheduling OWIN funding will
depend upon LFO’s evaluation of OWIN’s responses to LFO’s
requests, as well as LFO’s analysis of OWIN’s “health” in project
management, financial management and other areas. Unless
OWIN provides timely, accurate, and useful information to the
Legislature, OWIN is at risk of losing funding. Further, without
receiving timely and accurate information, the Legislature and
other oversight bodies such as the SIEC and Project Steering
Committee are unable to effectively manage the project.
SEVERAL FACTORS
CONTRIBUTE TO
INADEQUACY OF
CONTROLS
We identified several factors that contribute to these control
problems. First, radio coverage and site related technical
information is lacking; thus site-related requirements are
unknown. Second, OWIN has only recently determined the
processes that Partnership and Site Acquisition staff should be
following, and these staff are not following the processes
OWIN has set forth. A third is that units are operating with
multiple definitions of some key terms, resulting in
inconsistent information. Finally, we found numerous
indications that management has influenced staff to get sites
“complete” without considering relevant risks to the state or
the system. This pressure stems from an accelerated program
schedule and limited staffing but creates a significant liability
to the state and represents a significant control deficiency.
Technical Information
Lacking
Both partnership and site acquisition staff lack technical
information regarding the intended use of the sites for which
they are negotiating. Essentially, those negotiating agreements
do not know OWIN’s needs at the site (i.e. how much space
OWIN will need on the tower and in the equipment building).
13
Partnership and Site Acquisition units lack technical
information because the radio system design is still unknown
as a whole system. Because the radio requirements of the
system are unknown, radio frequency (RF) staff must evaluate
the needs of each site separately. This process is time
consuming and there are limited RF staff to cover the whole
state. However, in order for OWIN to meet their deadline, Site
Acquisition is pressured to continue simultaneous to gathering
RF information.
With the lack of requisite technical information, OWIN and
contract site acquisition agents have taken different
approaches when negotiating leases. Contract site acquisition
staff takes a conservative approach and “use a worst case
scenario” when negotiating with partners. For example, these
agents negotiate as if OWIN will need the tallest possible
tower, 15 antennae spaces, and the largest equipment
building. These assumptions have led to high lease rates and
public relation issues as citizens have expressed concerns
about the impact of the large towers and equipment. OWIN
site acquisition agents have executed many site agreements in
which the technical details of the agreement are “to be
determined.” These agreements will need to be amended
after RF staff determines the technical needs of the site.
Amending the agreements will result in delays and increased
workload of both OWIN and contractor site acquisition agents.
Units Are Not Following
Stated Processes
Partnership and Site Acquisition sections have, until recently,
lacked defined roles and responsibilities. OWIN’s Project
Management Office (PMO) recently began mapping all OWIN’s
processes, but in our attempts to assess the Partnership and
Site Acquisition processes, we found that these PMO-mapped
processes have not been implemented and that the processes
for Site Acquisition and Partnerships described by the PMO do
not reflect actual practices. This is mainly because the roles
and responsibilities over Partnership and Site Acquisition
activities are not clearly defined. Moreover, there is lack of
consensus over the purpose of the process maps prepared by
the PMO. Further, OWIN lacks communication and a cohesive
project delivery methodology to ensure processes are accurate
and followed. We attempted to map the current “as-is”
processes of these two groups but found that the lack of
identified roles and responsibilities made doing so impractical.
14
Partnership and site acquisition go hand in hand. However, the
two groups are in segregated business units, and in addition to
the lack of clear delineation of responsibilities, communication
between the two groups is poor. For example, because of
frictions and disagreements between the two groups about
various decisions involving sites, at one point a “gag order” had
been instituted, in which key individuals in the two sections
were not permitted to speak with each other. Because both of
these sections perform negotiations with partners, defined
responsibilities and effective communication between the
units are essential for operations to run efficiently and to
present a consistent message to partners.
In April 2010, the PMO issued the first version of OWIN’s
business processes. This document was created by the Quality
Management Manager who compiled it based on information
supplied by each business unit. The independent quality
assurance contractor hired by OWIN in March 2010 used these
process documents in their review which concluded that
the OWIN project is well managed and under control. The
contractor specifically stated that OWIN has processes in place
such as "established project-wide status reporting standards
and procedures,” "a robust Quality Management Plan," and "a
structured central repository for documentation." However,
our fieldwork demonstrated the complete opposite of these
findings. Despite giving the program a positive review, the
contractor stated that most, if not all, processes and controls
are not used, noted lack of accounting resources, identified the
lack of cost controls as a high risk area, and stated that few
sites were ready for construction. Although the independent
quality assurance report identifies significant concerns, the
summary conclusions do not reflect the concerns raised in
their report.
During our audit work, we verified that processes described in
the business processes document were not performed. For
example, one of the steps listed in the business processes
document states that, “Partnerships perform an analysis of all
documentation and meeting minutes/results to determine that
a partnership is possible and feasible.” However, during our
audit work, we did not find analysis or documentation of
partnership meetings. We also found that there is some
misunderstanding regarding which section is responsible for
creating agreements.
15
Key Terms Have Multiple
Definitions, Creating
Inconsistencies in
Information
OWIN lacks consistent reporting definitions, which has led to
inaccurate and misleading reporting to oversight bodies and
the public. OWIN refers to site conditions as “complete” or
“CM/GC ready,” but our sample showed that these conditions
are not consistently defined. As a result, the Legislature,
potential contractors, executive management, steering
committees, and the public may all have incorrect perceptions
of OWIN’s progress.
Identifying Sites as “Complete” is a Misnomer
OWIN distributes maps that identify certain sites as complete
to the Legislature, management, partners, potential partners,
and the public; however, these sites are not necessarily
“complete” in line with a simple definition of complete. In the
context of OWIN, we concluded that for a site to be complete
OWIN must have:
1. Legally acquired the space,9
2. Concluded construction or equipment installation, and
3. The site must be fully operational and part of the OWIN
system.
OWIN does not use this definition of complete, nor has OWIN
developed a shared definition to ensure consistency when
identifying sites as complete. As a result, maps have been
misrepresenting the program’s progress to oversight bodies
and the public.
The map in question, referred to informally as the Blue Dot
Map, (because blue dots represent “complete” sites) is widely
distributed maps initially created as a partnership marketing
tool. According to the SW IO Coordinator, blue indicates that
equipment is installed and operational or a site has been
completed by a partner or OWIN collaborative effort.
According to the SW IO Coordinator, the original intent of the
map was not to represent all actions related to the project—
i.e., Engineering, Project Management, and Site Acquisition.
Over time, however, the Blue Dot Map has become the de
facto map of progress on the OWIN system. There are various
versions of the Blue Dot Map, and the one provided by OWIN
management for this audit shows 34 complete sites.
9 Space includes any aspect of land, tower, or building.
16
To address the accuracy of the Blue Dot Map we attempted to
identify OWIN’s definition of “complete” and found three
different definitions, which are presented in Figure 2.
Figure 2 – OWIN’s Various Definitions of Complete
Source Definition
Executive Management A site is complete for construction when the following is met
• We have a legal right to be on the site.
• We have a legal right to construct on the site.
A site is complete for Trunked Radio installation when the
following is met
• Site infrastructure has been completed and accepted.
• Microwave has been installed, is functional, and has been
accepted.
• Required network components have been installed, are
functional, and have been accepted.
A site is complete for full Voice Communication Operation when
the following is met
• Trunked Radio has been installed, is functional, and has
been accepted.
• Interoperability equipment has been installed, is
functional, and has been accepted.
• The site operates within the state wide communication
system meeting all functional requirements.
SW IO Coordinator Complete indicates that equipment is installed and operational or
a site has been completed by a partner or OWIN collaborative
effort.
Site Acquisition Manager Site acquisition complete is when all legal rights associated with
the site have been acquired.
Our sample of seventeen sites included nine that were identified
as “blue dot” sites; we found that three of these nine sites were
complete according to all three definitions, although there are
significant legal issues with two of the sites. As Figure 3 shows,
most of the sites were complete in accordance with the SW IO
Coordinator’s definition; however, far fewer of the nine sites met
the definitions used by executive management and only one site
met the definition of complete used by the auditors.
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Figure 3 – Degree to Which Blue Dot Sites Were “Complete” According to Various OWIN
Definitions
Definitions of Complete
Site Executive
Management
SW IO
Coordinator
Site
Acquisition
Manager
Comments
Bear Mountain X
Construction performed
without agreement by
County.
Carmen Smith
Supported only by Letter
of Intent, no other
agreements.
Eagle Crest X
Agreement did not go
through legal sufficiency
and were later ratified.
Golgotha X
Site will not be part of
the OWIN network.
Equipment was installed
without authority.
Halls Ridge X X X
Agreement should have
gone through legal
sufficiency review but did
not.
Middle Mountain X
Agreement not signed by
someone with signature
authority.
Prospect X X X
OWIN issued an
unauthorized subleased
to a city who installed
equipment.
Skamania X X X No issues noted with this
site.
Washburn Butte X
County installed
equipment without an
agreement.
The degree of misinterpretation caused by these multiple
definitions of “complete” can be seen in the actual status of
these nine sites. Despite being labeled “complete” we found
that eight of the nine sites had significant issues at the time
they were shown as “complete” on the Blue Dot Map.
Essentially, even if a site is “complete” according to all
definitions, there may still be significant issues requiring
attention and remediation by site acquisition agents or DOJ.
Issues noted during fieldwork include:
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• Equipment installed by partner agencies without
authorization.
• Construction performed by partner agencies without
agreement.
• One agreement lacked legal sufficiency review.
• An unauthorized sublease and subsequent equipment
installation.
• A blue dot site that will not be part of the OWIN network.
Internal documents indicate conflict within the staff about
these various definitions and the resulting accuracy of the Blue
Dot Maps. However, management has not addressed the
underlying problem brought on by the various definitions.
Sites Designated as CM/GC Ready Are Not Construction Ready
OWIN’s Partnership and Site Acquisition sections track site
readiness on a master spreadsheet identifying certain sites as
“CM/GC ready. ” One would expect that if a site was listed as
“CM/GC ready,” it would be ready for construction; in practice,
the term “CM/GC ready” is used inconsistently and may not
signify readiness at all. Management stated that if a site was
listed as CM/GC ready, then there would be a Notice to
Proceed (NTP) for the site signaling it was ready for
construction. However, our sample of seventeen sites included
two sites listed as CM/GC ready and neither of these sites had
a complete NTP.10 Additionally, the first site that the CM/GC
broke ground on was not listed as CM/GC ready. Of the
seventeen sites in our sample, three had complete NTPs.11
Traditionally, a NTP is a letter to a contractor stating the date
the contractor can begin work subject to the conditions of the
contract and the performance time of the contract starts from
the NTP date. We found that at OWIN, a NTP is basically an
internal working document, not reviewed and approved by
anyone, and signifies nothing. Essentially, even though OWIN
states that a complete NTP is the criteria by which they know
that a site is ready for construction, the use and adequacy of
NTPs was inconsistent. We found no criteria by which staff
could accurately tell whether or not a site was CM/GC ready.
10 Eagle Crest and Beaver Hill 11 Bennett Butte, Hamacker, and Prairie Peak.
19
Project Schedule Creates
Pressure to Get Sites
Developed without
Sufficient Information or
Procedures
The OWIN project is on a tight schedule because of the FCC
mandate to narrowband by December 31, 2012. We found
that site acquisition agents were pressured by OWIN
management to put agreements in place that were
inappropriate. For example, at one site, OWIN sublet
equipment building space to a local government even though
OWIN personnel knew doing so was in violation of the terms of
the primary lease. 12 The site acquisition agent writing the
agreement clearly indicated in the agreement that OWIN did
not have consent of the site’s controlling party to issue the
lease; however, the agreement was still executed by OWIN
leadership and the local government.
In discussing the issue of pressure with OWIN staff, individuals
provided us with examples of pressure on sites other than the
seventeen included in our sample. These examples included
pressure to issue an unauthorized sublease or share at four
sites in a county, where contract site acquisition staff said they
felt pressure from the SW IO Coordinator to get agreements
signed. Other documents showed that the SW IO Coordinator
requested that a contract site acquisition agent secure tower
and equipment building space without first identifying the
rental rate.
Recent Changes Will
Help, but Additional
Actions Are Needed
During the course of our audit work, the Interim Site
Acquisition Manager stated he made several changes to the
site acquisition process that could address some issues noted
in this report. Because of the time frame for OWIN to acquire
sites and the time schedule for releasing this report, we were
not able to verify that all of these changes were implemented,
but we saw progress towards implementation. The stated
changes include:
Obtaining radio frequency information prior to writing
agreements: Continuing forward, site acquisition agents will
have technical information prior to writing an agreement. As a
result, site acquisition agents will no longer need to issue
agreements where the technical details are “to be
determined,” which require amendments after technical
information becomes known.
12 Prospect
20
Entry and exit authorization before entering any sites: Site
acquisition agents will obtain permission from the land owner
or controller to access the premises before any OWIN staff is
allowed to access the site.
Site settlement documentation for all sites: In the future, site
acquisition agents will be required to provide documentation
of the site settlement showing what is being acquired or
leased, the basis or analysis, and how the agent determined
that the arrangement was in the best interest of the state. In
this site settlement documentation, agents must demonstrate
that public funds were spent in a reasonable manner.
Involving the ODOT Right of Way section in acquiring some
difficult sites: ODOT Right of Way section will be used to help
OWIN Site Acquisition handle sites that need to be moved to
condemnation. ODOT Right of Way has technical expertise to
handle eminent domain issues and OWIN will utilize this
expertise.
These changes seem to be a result of OWIN’s move from OSP
to ODOT and changes in site acquisition management.
Implementing these changes will add increased levels of
accountability and control over the Site Acquisition Process
and will allow OWIN staff to utilize the expertise of other ODOT
sections. On their own, however, these changes will not
address all of the issues we identified, which is why we include
a number of control-related recommendations at the end of
this report.
21
EQUITY OF
PARTNERSHIP
AGREEMENTS
CANNOT BE
DEMONSTRATED
WITH EXISTING
INFORMATION
In 2008, the Legislative Fiscal Office (LFO) acknowledged that
the success of OWIN in large part depends on the partnerships
it creates with local governments, federal agencies, and private
sector entities. A workgroup comprised of OWIN and LFO
officials said that partnerships are important given the mission
and cost of the OWIN system and that under any partnership
arrangement, local government must pay its “fair share” of the
costs. However, we were unable to determine whether or not
partnerships were equitable to the state. Further, some of the
partnership agreements for the sites we examined included
promises that were not in the state’s best interest, and OWIN
lacks controls to ensure that negotiations produce an equitable
outcome.
Estimate of $60 Million
in Saving through
Partnership Agreements
Has No Sound
Methodological Basis
The OWIN concept of partnerships leverages existing public
safety communications resources and services to reduce or
eliminate duplication and unnecessary expense. OWIN often
includes partnership savings in financial information; however,
these savings are unsubstantiated. We reviewed
documentation submitted to support the $60 million
partnership savings figure and found discrepancies in the
figures provided and lack of specificity in the value of partners’
contributions. For example, in a January 2010 presentation
given to the Project Steering Committee, OWIN reported
varying figures for the value of grants received and estimated
savings. In the presentation, the reported net benefit to the
state could be totaled as $55 million in one place and $61
million in another. Most documents we reviewed, including
agreements, did not quantify savings or specifications. For
example, agreements stated that the partner will:
• Contract to have microwave systems installed at the facility
to include the microwave antennas on the communication
tower.
• Provide drawing illustrating mounting application.
• Mount equipment.
• Construct and install, at partners’ expense, a new structure
at this location, subject to OWIN’s successfully negotiating,
if necessary, a ground lease at this location that will permit
the construction of such a structure.
• Oversee design and implementation of the new
communications site.
• Allow state to operate rent free for as long as the partner
retains an interest at the site.
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While partnering is an excellent concept, in reality the benefits
of partnerships to the OWIN program are unclear. OWIN
appears to be partnering with local governments without
receiving any discernable benefit other than being able to
report to the Legislature that they have partners. To become a
partner, an agency signs a non-binding agreement stating that
they may contribute to the OWIN system in the future. These
general sharing agreements do not contain any financial
obligations or roles and responsibilities language.
In various budget documents and presentations to steering
committees, the Legislature, partners, potential partners, and
the public, OWIN represents $60 million in partner savings.
OWIN management states that this figure is an estimate, yet
this estimate has been used to represent a funding source in
budget documents. According to OWIN’s Finance Director, the
partnerships are impossible to quantify defensively as savings
to the state because the general sharing agreements are
“nebulous.” To the extent the estimated savings are presented
as accomplished fact, they amount to a misrepresentation of
financial and partnership conditions.
OWIN Made Promises
that Are Not in the
State’s Best Interests
The Partnership section is solely responsible for negotiating
partnership responsibilities while site acquisition agents
become involved at the point of writing the general sharing
and supplemental agreements. In preparing the underlying
partnership agreements and working with partners, site
acquisition, contracted, and technical staff have found that
OWIN made promises to partners that are not in the best
interests of the state.
Specifically, OWIN is providing in-kind construction and project
management services to develop partner sites that will not be
utilized as part of the OWIN network. Examples include:
• OWIN is building a new tower at Dead Mountain for a
police department.
• The Vineyard Hill site is being developed for a private
company.
• OWIN is providing engineering and project management
services and installing a microwave for a police
department.
• Circuit provisioning was performed for a city at Prospect
and a private company at Starveout.
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• OWIN performed site design, drawings, and NEPA for the
Woodburn shop site to be used by a county.
OWIN Lacks Controls to
Ensure that Negotiations
Produce Equitable
Outcome
The partnering process does not contain controls or utilize
guidelines such as records of negotiation, cost-benefit analysis,
or cost estimates of goods and services to ensure that
decisions are made in the best interests of the state. Both
Partnership and Site Acquisition sections lack a documented
cost-benefit or similar analysis to determine the advantages
and disadvantages of entering into partnership or site specific
agreements. Because of these factors, we were unable to
determine if the agreement was equitable to both partners.
Further, in the absence of documentation, other OWIN
business units who are responsible for technical or
administrative details are unaware of the terms and doubt the
integrity of partnership arrangements.
In the absence of cost-benefit or similar analysis to determine
the advantages and disadvantages of entering into partnership,
the SW IO Coordinator referred auditors to the “partnership
responsibility matrix” which he asserts outlines each
participants’ responsibilities toward the partnership. However,
this tool appears inadequate for the following reasons:
1. Matrices are not consistently used for all partnerships. Only
5 of the 33 partners with signed sharing agreements and 2
partners without signed sharing agreements have matrices.
2. Matrices contain information for multiple partnerships,
which makes it difficult to distinguish the specific
responsibilities of each partner. Even though 7 partnerships
are covered under a matrix, only 5 matrices exist.
3. Matrices lack cost-estimates of goods and services.
Further, staff does not know the purpose of the matrices; staff
did not know where the information in the matrices came from
or whose responsibility it was to create them. Moreover, of the
partnership responsibility matrices we examined, one
contained information unrelated to the partnership; the
responsibility matrix stated that the partner was responsible
for installing equipment at a site, however, the stated
equipment was not OWIN’s, would not be on the OWIN
network, and would not benefit OWIN.
Another matter that is not adequately controlled in the
agreements is the inclusion of in-kind goods or services, such
24
as a partner providing OWIN rent free ground and tower space
in exchange for OWIN installing new propane tanks and
upgrading the partner’s generator and microwave equipment.
In some instances OWIN is providing in-kind goods and services
as consideration. The nature of partnerships involves in-kind
agreements, and DOJ believes the use of in-kind consideration
is appropriate when the terms of the agreement are equitable
to both parties. This may be appropriate if OWIN was
recording the information in financial systems– the difference
between the services provided and received must be recorded
as a revenue or expenditure. However, OWIN is not
documenting the financial terms of in-kind partnerships in
agreements or financial records.
Although the state’s Department of Justice (DOJ) is supportive
of in-kind consideration, these transactions require a high level
of justification and documentation. For example, a joint review
team consisting of the Oregon Department of Administrative
Services and Department of Human Services managers
concluded that leases should not provide for in-kind
consideration. The reasoning was that the amount of
resources necessary to account for in-kind transactions and the
high degree of effort necessary to justify the amounts are
impractical for state documentation and valuation
requirements.
DOJ has acted in response to the lack of due diligence in the
partnership and siting processes and, as a result, has become
more involved in reviewing OWIN agreements regardless of
legal thresholds.
CONCLUSION During our review of site acquisition and partnership
processes, we found that current controls over site acquisition
and partnership processes are inadequate. Components of
effective programmatic communication are the ability to
distribute needed information to oversight bodies in a timely
fashion and report project performance, including the project
status. However during our review, we found that oversight
bodies have limited ability to monitor the program effectively
because budget information is incomplete, key terms have
multiple and inconsistent definitions, and units are not
following stated processes. Control breakdowns were
evidenced through widespread implementation problems at
the sites we reviewed, such as approving sites without
25
adequate legal review, allowing unauthorized equipment
installation, and conducting work on sites that were not
actually intended to be part of the OWIN network.
Further, OWIN lacks clear policies and procedures and defined
roles and responsibilities that would ensure accountability over
program operations, both for site acquisition and partnership
agreements. Prior to 2009, OWIN was staffed by only a handful
of people and in the past year staff has increased to 24
positions. Staff asserts that many of the process and
procedures grew in response to the additional staff but details
such as roles and responsibilities have not been identified.
OWIN needs to implement a process for site acquisition and
partner building that is repeatable and documented. The
foundation for such processes would be a common
understanding of responsibilities within the organization.
We also found that the equity of partnerships cannot be
demonstrated with existing information. OWIN has stated in
program documents that its partnership agreements will save
$60 million in project costs, but we found that this savings
estimate has no sound methodological basis. Some
agreements contain promises that are not in the state’s best
interests, such as providing construction and project
management services to develop sites that will not be utilized
as part of the OWIN network. Further, OWIN lacks controls to
ensure that negotiations produce an equitable outcome.
OWIN faces significant internal and external constraints such as
an aggressive FCC deadline, lack of dedicated funding until
2009, rapid increases in staffing levels in recent months, and a
recent intra-agency move that created significant challenges to
program implementation, and may be causal elements to many
of the issues described in this report.
RECOMMENDATIONS To promote more accountable, transparent, and effective Site
Acquisition and Partnership processes, we recommend that
OWIN do the following:
Developing Better
Budgeting and Oversight
1. Update and validate the original “business case”
estimates and identify the actual program that OWIN will
be implementing, instead of using unidentified references
to “optimal” or “value-engineered” systems.
26
2. Develop, implement, and utilize a detailed financial plan
that includes:
a. Estimating assumptions and constraints.
b. Detailed scope, schedule, and program and site
budgets.
c. Expenditure plans.
d. Defensible methodology to quantify partnership
savings.
3. Develop a change management system to track, review,
approve, and report changes in budget, scope, and
schedule.
4. Empower a strong governance structure by:
a. Performing a governance review or audit to assess
the effectiveness of OWIN’s governance model.
b. Developing an appropriate oversight structure that
is reviewed, approved, and used by the SIEC and
Steering Committee.
c. Ensuring consistent and timely distribution of
program information.
d. Providing accurate and regular status reports to
governing bodies.
e. Reporting cost information to stakeholders
monthly.
Improving Policies and
Procedures
5. Develop, implement, and enforce policies and procedures
over Site Acquisition and Partnership processes;
specifically:
a. Clearly define roles and responsibilities for project
elements.
b. Clarify signature authority of various agreement
forms.
c. Obtain technical information before site
negotiations commence.
d. Maintain records of negotiation for all site related
negotiations.
e. Document cost-benefit or similar types of analysis
for partnerships and potential alternate sites.
6. Utilize consistent project management criteria and terms
throughout the program.
a. Discontinue use of Blue Dot Map until the term
“complete” is clearly defined.
27
b. Clearly define terms such as “complete” and
“CM/GC” ready.
c. Establish measures to verify and confirm that sites
are “complete” or “CM/GC ready” before
designating as such.
7. Develop measures to demonstrate the equity in
partnership and site specific agreements.
a. Identify partner roles and responsibilities in
agreements using guidance in ODOT’s
Procurement Manual for writing
intergovernmental agreements.
b. Cost estimates (based upon fair market value)
should be included in negotiations for all in-kind
goods and services.
c. Appropriately record in-kind transactions in
financial records.
8. Ensure agreements valued in excess of $150,000 over the
life of the agreement obtain required legal sufficiency.
9. Identify corrective action to remedy inappropriate
subleases without disrupting emergency services or
entering sites unlawfully.
10. Develop a shared centralized file management system
which contains current and complete information. Include
the following Partnerships and Site Acquisition
documentation:
a. Existing leases and agreements.
b. Draft leases and agreements.
c. Negotiation records.
d. Notice to proceed.
e. Cost benefit or similar analysis.
f. Historical documentation regarding stakeholders.
g. Evidence when an agreement has been reviewed
for legal sufficiency.
h. Signature authority of ODOT signatories.
i. Grant information.
j. Budgeting and percent complete information.
11. Utilize a lease tracking system for executed leases.
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12. Develop, implement, and utilize policies and procedures
to address the purpose, use, review, and approval of
notices to proceed.
Ensuring that
Partnership Agreements
Are Equitable and
Effective
13. Partnership responsibilities matrices, if continued, should:
a. Be developed for all partnerships.
b. Contain measures so that all staff is working from
the most current version and only those
authorized can make changes.
c. Contain cost estimates for goods and services
exchanged.
d. Have consistent standards so only information
related to the partnership is included.
14. Ensure that both OWIN and partner agencies have
appropriate authority prior to entering and installing
equipment at telecommunication sites.
15. Ensure that agreements are fully executed prior to
performing work.
OBJECTIVES, SCOPE
AND METHODOLOGY
This audit was requested by the Major Projects Branch
Manager in order to help ensure the effectiveness of controls
over site acquisition and partnership processes the OWIN
project. The objectives of this audit were (1) to determine the
adequacy of current controls over site acquisition and
partnership processes; and (2) to determine the extent to
which partnership agreements with governments and private
entities are equitable for the state. To achieve these
objectives, we selected a sample of sites and evaluated the
processes. With the site sample we reviewed:
• Partnership, site acquisition, and in-kind agreement
negotiation documentation.
• Agreement writing, review, and approval processes.
To complete this audit we:
• Interviewed OWIN executive management, partnership,
site acquisition, finance, procurement, and project
management;
• Reviewed documented processes for partnership and site
acquisition;
• Selected a judgmental sample of sites and reviewed site
files and related documentation;
29
• Evaluated controls needed to promote accountability,
transparency, and effectiveness; and
• Reviewed and analyzed applicable state statues, rules,
policies, procedures, and best practices.
Sample Methodology
To investigate issues noted during the planning phase we
selected a judgmental sample of fourteen sites containing
potential issue areas and three sites that were not alleged to
have issues. Allegations followed up during the site review
included:
• Legal sufficiency concerns
• Over-capacity tower
• Leases from other agencies
• Inequitable business deals
• Sites OWIN is “developing” but not using
• Signature authority issues
• Sites identified in “Blue Dot” memos
• Sites part of questionable partnerships
• In-Kind contributions
• Site Acquisition services performed by contract A&E
• Sites identified as “CM/GC” ready
• At least one site for each of the grants or funding streams
• Unauthorized subleases
• Towers or equipment installed without agreements or
authority
• Sites from list of "centers"
We conducted this performance audit 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 evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objectives.
Fieldwork was conducted between April and August 2010.
We appreciate the cooperation of OWIN, Major Projects
Branch, and ODOT Wireless staff during the course of this
audit.
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