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

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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.

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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.

17

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.

22

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.

23

• 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.

28

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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MANAGEMENT RESPONSE

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MANAGEMENT RESPONSE

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MANAGEMENT RESPONSE

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MANAGEMENT RESPONSE

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MANAGEMENT RESPONSE

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MANAGEMENT RESPONSE

36

MANAGEMENT RESPONSE

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