SIXTH REPORT OF THE COURT MONITOR
This is the sixth report in a series of reports submitted by the Court Monitor pursuant to this Court's Order of April 16, 2001, to review and monitor "all of the Interior defendants' trust reform activities and file written reports of (the Court Monitor's) findings with the Court."
This report will address the Court Monitor's review of the "Status Report to the Court Number Eight" ("Eighth Quarterly Report"), submitted on January 17, 2002 under signature of the Secretary of the Interior, Gale A. Norton.
On November 26, 2001, the Interior Defendants ("Defendants") filed an "Emergency Motion To Stay Filing Of Eighth Quarterly Trust Reform Status Report Pending Ruling On Motion To Permit Modified Form Of Report" (Tab 1).
In the memorandum in support of that Motion accompanying it, the Defendants stated in part:
"As set forth in the Report Motion, certain critical events in Interior's trust reform efforts have taken place during and immediately following the period to be covered by the eighth quarterly report. These events include Interior's receipt of the finding on trust reform and its implementation of the trust reform recommendations of its independent consultant, EDS, undertaking a reorganization initiative placing Indian trust asset management under a single, newly formed directorate, and issuance of OHTA's 60 and 120-day reports. The reporting of these events constitutes a more informative status report for the eighth quarter than the form heretofore employed." Id. at 2.
On the same day, the Defendants also filed a "Motion To Permit Filing Modified Form Of Trust Reform Status Report For The Period Ending October 31, 2001" (Tab 2). In the attached Memorandum in support of that Motion the Defendants stated in part:
"These (EDS) reports together provide a knowledgeable and detailed view of the status of Interior's trust reform progress. Interior's senior managers have relied upon EDS' views in formulating their new management strategy.
This memorandum explains how the documents and Declarations comport with the Court's quarterly reporting requirements and how perpetuation of the previous quarterly reporting format will not adequately inform the Court, the plaintiffs or the public of either the significant findings of senior departmental managers and EDS or the actions of the Secretary based on those findings. A report based on the previous approach also runs the danger of presenting a confusing view of Interior's plans and intentions. Interior respectfully suggests that (i) the management insights provided by EDS make its reports a superior vehicle for communicating the status of trust reform, (ii) the reorganizational documents provide the best review of current departmental plans, and (iii) the OHTA reports document the status of historical accounting." Id. at 2-3. *fn1
Following a November 30, 2001 hearing before this Court in which the Court addressed issues regarding the EDS report and its impact regarding the accuracy of the Seventh Quarterly Report's statements concerning the status and progress of trust reform, the Defendant's filed "Interior Defendants' Response To The Court's Inquiry In the Order To Show Cause Dated November 28, 2001 (Tab 3). Defendants stated in part:
"The EDS Report does not render inaccurate Quarterly Status Report to the Court Number Seven ('Seventh Quarterly Report'), but it does identify shortcomings, some quite substantial, in the overall strategy for accomplishing trust reform that Interior had pursued before its receipt of the EDS Report. During the seventh quarterly reporting period, ending July 31, 2001, the Revised High Level Implementation Plan ('Revised HLIP') continued to define that overall strategy. Thus, the efforts described in the Seventh Quarterly Report related to the milestones that the Revised HLIP had defined as necessary to accomplish trust reform. With the publication of the EDS Report and Secretary of the Interior Gale A. Norton's ('Secretary's') acceptance of its recommendations, the overall strategy dramatically changed. The Seventh Quarterly Report's description of particular steps taken to accomplish the Revised HLIP was not rendered inaccurate by this change; but much of its was instead, rendered obsolete." Id. at 1-2, emphasis added. *fn2
Later, defendants stated:
"Interior's quarterly reports described the progress of Interior regarding the individual Revised HLIP milestones. They did not undertake a comprehensive analysis of the current status of trust reform each quarter, nor did they rely on any comprehensive, objective analyses of that status provided by independent consultants-. Subsequent events, most notably the findings in the EDS Report, suggested that the Revised HLIP did not provide an adequate foundation for achieving trust reform. These findings identify substantial shortcomings in the overall strategy of the Revised HLIP and, therefore, the continued usefulness of reporting on the milestones." Id. at 3, emphasis added.
"The EDS Report provided Interior with information it did not have before the filing of the Seventh Quarterly Report - an objective assessment of the current status of the TAAMS and BIA Data Cleanup subprojects from an outside source with no involvement in the decisions leading to adoption of the original strategy." Id. at 6, footnote omitted, emphasis added.
On December 17, 2001, this Court issued an Order (Tab 4) denying the Defendants' motion to permit filing a modified form of a trust reform status report and granting them an additional thirty days to comply with the Court's December 21, 1999 Order. It provided:
"Beginning March 1, 2000, defendants shall file with the court and serve upon plaintiffs quarterly status reports setting forth and explaining the steps that defendants have taken to rectify the breaches of trust declared today and to bring themselves into compliance with their statutory duties embodied in the Indian Trust Management Reform Act of 1994 and other applicable statutes and regulations governing the IIM trust.
It is further ORDERED that the Secretary of Interior shall personally sign all forthcoming quarterly reports." Id. at 1-2.
II. STATUS REPORT TO THE COURT NUMBER EIGHT
On January 17, 2002, Defendants, under signature of the Secretary of the Interior ("Secretary"), filed the Eighth Quarterly Report in compliance with this Court's Order (Tab 5).
The Eighth Quarterly Report is a massive document, 171 pages in length. It includes an Introduction, Observations by the Secretary, the Special Trustee, and the Director of the Office of Indian Trust Transition (OITT). It addresses the past quarterly reports' subprojects and adds new sections including Departmental Reorganization, Historical Trust Accounting, Current Accounting Activities, Fractionated Heirship, Cadastral Surveys, Information Technology System Security, and BIA Office of Information Resource Management.
The Eight Quarterly Report significantly changed the format of the individual reports including EDS and Special Trustee Observations on each subproject reviewed by them. Also, the Subproject Managers were given the opportunity to comment on both the EDS and Special Trustee Observations. For TAAMS, BIA Data Cleanup, and Probate, the Deputy Special Trustee, who had been assigned oversight of these subprojects, provided her observations on the subprojects' status. *fn3
Based on the scope of past Reports of the Court Monitor ("Reports") that have addressed historical accounting, TAAMS, and BIA Data Cleanup as well as the truthfulness, accuracy and completeness of the quarterly reports, this review of the Eighth Quarterly Report will track the past reviews and address TAAMS and BIA Data Cleanup as well as other pertinent sections of the Eighth Quarterly Report that may cast light on the status of trust reform and the Defendants compliance with this Court's December 21, 1999 Order and the Indian Trust Management Reform Act of 1994 ("1994 Reform Act").
The Office of Historical Accounting's (OHTA) Historical Accounting project, including a review of its section in this Eight Quarterly Report, is the subject of the Fifth Report of the Court Monitor previously filed with this Court.
Setting the tone for later observations by the senior management of the Department of the Interior, the Introduction begins its commentary by stating:
"Status Report Format - A Process in Transition. The Department's effort to satisfy its trust responsibilities to individual Indians is necessarily an evolving process, and as that process matures, the means to best inform the Court with respect to this process will also change. Thus, the format of this report varies from that employed in the seven earlier reports submitted to the Court. These changes are guided by reference to the Court's orders, activities of the Court Monitor and Special Master, the obstacles encountered thus far by the Department, and the Secretary's initiatives to advance trust reform and the accounting efforts beyond the point they were first envisioned by the original High-Level Implementation Plan ('HLIP') dated July 1, 1998. Prior reports were structured to report on the status of the revised and updated HLIP dated February 29, 2000, and the so-called 'four breaches.'
The Department has concluded, however, that the HLIP milestones have become increasingly disconnected from the overall objectives of trust reform. Some milestones have been achieved; some have not been achieved; some have been reported as complete, but little seems to have been accomplished; some have been changed; some need reevaluation; others should have been changed but were not; and in hindsight, trust beneficiaries would have benefited from inclusion of some elements of trust asset management that were not included in prior reports but are now contained in this report. Moreover, the Secretary's initiatives to reevaluate trust reform and to create a new organizational structure are more naturally described under new headings, rather than by reference to HLIP subprojects and milestones that have served their purpose, become ineffective, need consolidation given their interdependencies, or simply do not reflect the true status of trust reform. Id. at 4-5, emphasis added. *fn4
The Introduction goes on to state:
"The format of the HLIP did not encourage reporting on lack of success or the need for additional resources or efforts. In contrast, this report covers matters in addition to the status of subprojects. Subproject managers have been asked to discuss obstacles, resource needs, and whether they know at this time the full extent of the endeavor required. These matters are important for an accurate picture of the status of trust reform. Moreover, summary observations from EDS are included under the subprojects, and the managers of the subprojects are given the opportunity to comment upon the EDS observations so that all views are provided. Milestone charts are omitted since milestones do not fully disclose the status of trust reform." Id. at 5, emphasis added.
C. Secretary Gale Norton's Observations
The Secretary further reviewed both the past and the Eighth Quarterly Report's format and content by stating:
"This report details five months of the Department of the Interior's transition toward a better, more effective program of trust reform. It also details the Department's efforts to provide information to this Court that reflects, as accurately as possible, not only progress being made but also the problems and obstacles encountered. As indicated in the introduction, the style, methodology and content of this report differ from previous reports. We are introducing a new format that is designed to be more readable, and the information is based upon a methodology designed to document more objectively both accomplishments and lack of progress. The previous format focused on the steps we have taken and the completion of milestones. In retrospect, this format exacerbated the ordinary human inclination to report accomplishments and to ignore obstacles, difficulties and problems that were not directly related to the milestones. With this report, we have demanded that managers report both progress and problems. Our report also includes the key recommendations of outside management consultants who have criticized the current approach to some trust reform goals. The overarching goal is to provide the Court a more comprehensive and candid reflection of trust reform.
We believe we now have a better understanding of the objectives the Department must accomplish. This background does not excuse the Department's past failure to meet its responsibilities in trust management and trust management reform, but it does place in context our growing appreciation of the problems involved and the intensive effort necessary to address them. As described in prior submissions to the Court, the Department now views the High Level Implementation Plan (HLIP), by which trust management reform progress was measured and reported to the Court, to be obsolete-. The HLIP is outdated. Many of its identified activities have been designated as being completed; however, little material progress is evident." Id. at 6-7.
While a subject for analysis later in this Report in conjunction with a review of the Eighth Quarterly Report's individual sections, the Secretary's comments on the accuracy and completeness of the past quarterly reports substantially confirm the conclusions of the Court Monitor in past Reports that the seven quarterly reports submitted to this Court by the past and present administrations have been neither accurate nor complete. *fn5
D. Special Trustee Observations
The Observations of the Special Trustee, as the primary Department of the Interior (DOI) official designated by Congress to be responsible to Congress and the Secretary for trust reform oversight, bear particular review. He begins with General Observations including the following:
"It is critical for this Administration and the Department to take three important steps:
First, an overall strategy for trust reform needs to be determined.
Second, an effective organization to execute that strategy must be put in place and staffed. It will be critical that experienced executives, preferably with trust experience from the private sector, lead that organization and that there be accountability (and consequences) down the line within that organization.
Third, uniform business processes need to be provided for certain systems development and data cleanup efforts, and a business plan is needed for the overall organization for trust reform.
Another area of need for trust responsibility is prudent land management to provide beneficiaries, both tribal and individual, with the best income return on their land, normally the principal trust asset. While there are various allegations of mismanagement of the land, there is no overarching plan to effect adequate controls and assure responsible usage. This matter will have to be addressed by the planning process mentioned above.
Many current subproject reports do not provide suitable timelines for the completion of significant elements of the subproject. It is true that, with the input of EDS, many of these subprojects may require reorganization and even combination with other subprojects, and this reorganization of the subprojects is a major neat step for DOI. In many cases the length of time to accomplish subprojects, however, can be estimated and should be. Otherwise the Special Trustee, the Secretary, and the Court have no useful time dimensions.
Finally, documentation of the completed steps in the life of a subproject is required. Not all accomplishments to date have been documented sufficiently, and the Department will need to pursue this discipline." Id. at 11-12, emphasis added.
With respect to the Special Trustee's Observations on Certain Subprojects or Trust Responsibilities, two observations need mention now prior to reviewing the Eighth Quarterly Report's subsections.
In this Report, the Department responds to the fundamental tenet of trust: Is there an accurate accounting provided to the beneficiaries, individual and tribal? When one inspects the accounting responsibilities for trust assets under the law applicable to Indians trust, the answer is basically `no'. Until the requisite business plan, systems, policies and procedures, and, most importantly, effective management and employee accountability are firmly in place, the accounting responsibilities to the beneficiaries at best will be only partially fulfilled. Id. at 12, emphasis added in second sentence; remaining emphasis in original.
In this report, there are positives in the vetting process by the Department of the individual subprojects for the report plus the receipt of the EDS observations and recommendations on the status of all of the subprojects and trust reform. Overall progress on trust reform cannot be assured or confirmed, however, because of the apparent inadequate planning and execution to date of the apparent inadequate planning and execution to date of some subprojects and other important remedies for Indian trust.
Intelligent and objective planning in the upcoming months should provide for the appropriate steps to be taken. It is important to success that the DOI senior management recognizes the interdependencies of the total trust reform effort. Reporting for the subprojects herewith may not include reporting on steps that should have been planned, the absence of which may present problems to the completion of the subproject. It is in that sense, at least, that parts of this report remain inadequate, in the Special Trustee's judgment. Id. at 14
In light of these comments, the Court Monitor interviewed the Special Trustee to further expand on his reasoning and gain some idea of the specific subprojects that he was addressing. He stated in substance the following:
The specific projects that he referred to in his Observations were TRAMS, BIA Data Cleanup and Probate as well as the overall trust reform project interdependencies. It is his belief that these form the core of trust reform activities that may impact most severely on IIM trust beneficiaries due to poor planning and execution. They have not been well planned, executed, or reported as he has repeatedly pointed out in the quarterly reports' Special Trustee Observations beginning with the Third Quarterly Report.
Given the poor planning and subproject management, the best of intentioned senior managers reviewing these individual sections and the overall status of trust reform for the Eighth Quarterly Report could not hope to have uncovered all planning and execution failures and, thus, the reporting on at least these projects is most likely incomplete and inaccurate - thus inadequate - though not intentionally so. Much more investigation and verification must be done in order to be able to completely and effectively address and report on these projects in the future.
1. Director Office of Indian Trust Transition Observations
Mr. Ross Swimmer was appointed by the Secretary as Director of this office and is responsible for planning and implementing the transition of the trust functions into the new trust organization - the Bureau of Trust Asset Management or "BITAM." The Secretary also assigned him to compile the Eighth Quarterly Report. He required all subproject managers to submit written reports on the status and progress of their subprojects and met with all of them over a two week period where they were required to defend their reports and confirm or supplement information supplied in them. Their reports and defense of them were also subject to review by not only Swimmer but also the Special Trustee and, for at least the TRAMS, BIA Data Cleanup and Probate subprojects, the Deputy Special Trustee, Donna Erwin. Department of Justice (DOJ) and Office of Solicitor (SOL) attorneys were also present for periods during this review.
Some of the Director's Observations regarding the reviews he and Ms. Erwin carried out were the following:
"As a result of these reviews, beginning in January, OITT will begin to reassess, revise and reprioritize project objectives to generate a more comprehensive, interdependent plan to produce the greatest positive impact for Trust account beneficiaries and holders. In addition, further development and deployment of the ArtesiaLand System known as TRAMS has been deferred until we are satisfied that it is the most appropriate way to automate the land title, realty management and other required trust functions. Work related to TRAMS has been reviewed with subproject managers to explain to them the reasons for deferring further implementation of TRAMS. Also, cleanup projects are being redirected to insure that there is more emphasis on meeting DOI's fiduciary duties. Id. at 15, emphasis added.
Explaining some of the interview process he carried out, he stated:
"During the interview process, questions were asked such as: You state you did this task or training or report, etc., where is the documentation? Often the response was similar to: I really believe it was done, bat I will have to do more checking to confirm. In other words, subproject managers were willing to state certain progress was made but when challenged could not always defend their position. In other instances, I would hear that subproject managers had completed a task, but when asked what happened with their work to insure that the beneficiary received his/her income, the answer often was: That is not my area. As an example, title work might have been completed for a tract so that ownership is legally defensible, but realty might not get the information regarding leases or oil and gas receipts in order to meet distribution payment requirements. It is very alarming to read and hear reports of progress being made and, in some instances, projects completed without having this work fit into an overall context of trust management. It is apparent that some projects could be completed or `under control' yet not add substantively to the requirements of a person receiving income from assets held in trust for them. Although some confusion arises from different writing styles in their reports, the reporting often lacks complete thoughts and understanding of the problems affected or created by the work being reported.
There are many instances where work is being done by one agency or bureau and is simply 'thrown over the fence' to the next work group without the normal follow-up that would insure a beneficiary receives his/her income or other responsive information due from a trustee. It is essential that trust management reform and the on-going business of trust operations be managed by an organizational structure that has accountability from top to bottom. Id. at 15-16, emphasis in original.
The TAAMS' section provides some of the reasons for the observations of the Secretary, Special Trustee and Director, OITT, and the actions taken by the Director regarding TAAMS' future development.
Consistent with the Electronic Data Systems (EDS) November 12, 2001 Interim Report and Roadmap for TAAMS and BIA Data Cleanup, the Department of the Interior (DOI) is deferring realty and accounting functionality until the business processes are documented and defined. This delay will enable full definition of requirements for the automated system and is in conformance with recommendations by both the General Accounting Office (GAO) and Congress." Id. at 121.
The Deputy Secretary of the Interior, J. Steven Criles, who also was active in the direction and review involved with the preparation of the Eighth Quarterly Report, appointed Donna Erwin, the Deputy Special Trustee, to supervise the TAAMS, BIA Data Cleanup, and Probate subprojects on November 14, 2001. Erwin has extensive experience as a trust officer and was previously in charge of successfully managing the development and implementation of the Trust Finance and Accounting System (TFAS). She apparently made a quick assessment of the status of the TAAMS system development, both title and realty, as well as the necessary interfaces, and directed the subproject manager to, in part:
1. "Evaluate the ATS product for title for additional requirements.
2. Defer further development and implementation of the ATS product until business processes are completed.
3. Complete the modification including appropriate testing to correct minor flaws in the current title production system.
4. Perform a comparison of current title ownership to Realty and Oil & Gas ownership in the legacy system to determine number and type of anomalies.
5. provide additional reporting capability to the current Title production system.
6. Evaluate and modify as necessary all contracts supporting the ATS product to ensure contracts coincide with the recommendations to defer further development and implementation." Id. at 121-122, emphasis added.
There were no listed "Accomplishments" other than two regarding the above direction.
There were over 30 "significant remaining steps" including:
1. "Evaluate further deployment of the ATS product for current Title as recommended by EDS. *fn6
2. Evaluate the deployment of the ATS software to agencies and tribes within Rocky Mountain, Southern Plains, Alaska and Eastern Oklahoma Regions for read only access.
3. Complete review, validate, and re-engineer business processes.
4. Perform a comparison of title ownership residing in the ATS system to realty and Oil & Gas ownership in the legacy system to determine number and type of anomalies.
5. DOI has purchased 735 licenses and paying 10% help desk and 10% maintenance fee based on cost of licenses - only utilizing approximately 265.
6. Need to identify the universe of data cleanup problems for both legacy systems and manual records. Id. at 122-123, emphasis added.
In addition to the remaining significant steps there were an additional eight "Tasks to Correct Problems, Issues and Concerns including:
1. Renegotiate ATS contract that currently expires 1/28/02. *fn7
2. Approval and implementation of staffing requirements.
3. Establishment of accountability factors for all staff involved in trust reform vs. generic performance elements.
4. Training on business culture changes to reduce resistance and prepare managers and staff for types of problems that will potentially be encountered." Id. at 123, emphasis added.
Finally, over five months after the Court Monitor first challenged the representation in the quarterly reports that TAAMS current title was a "system of record" in four Regional title offices, the Eighth Quarterly Report confirms the Second Report of the Court Monitor and subsequent Reports' statements that the TRAMS current title module had not been properly designated as a system of record and still cannot be so called:
"Status of Land Title Records Offices
The ATS product is being used with limitations, for current title activities in Rocky Mountain, Southern Plains, Alaska and Eastern Oklahoma Regions. LRIS, courthouses, and/or manual processes are still used for title history and some current activities. Actual usage of the ATS product for current title varies widely among these four regions.
1. Mountain and Southern Plains regions use the ATS product for virtually all-current title activities.
2. Alaska region did not formerly utilize an automated title system. As a result title documents are being compiled by a contractor, encoded into the ATS product by a contractor, and then certified by BIA personnel. If a Title Status Report (TSR) is requested for a tract that is not already in the ATS product, then the title data is given priority for compiling, encoding and certification into the ATS product so the TSR can be generated and certified.
3. Eastern Oklahoma has been researching and entering into the ATS product income-producing tracts in the Chickasaw and Seminole land areas. The Self-Governance Tribes of Cherokee, Muscogee (Creek), and Choctaw Nations that have compacts for title have not been able to use the ATS product. The TRAMS Project Office is pending completion of personnel security packages." Id. at 123-124.
While it is not the purpose of this Report to address the truthfulness of the managers responsible for making this claim in the Fifth Quarterly Report, it was clearly false and known to be so under any definition applied to "systems of record" known to the Court Monitor *fn8 It was not corrected in any subsequent quarterly report nor in either the initial or subsequent TRAMS' subproject submissions in the Seventh Quarterly Report that were provided this Court following receipt by this Court of the Second Report of the Court Monitor on August 9, 2001. *fn9
The Special Trustee's Observations also highlighted the decision of the Defendants to delay further deployment of the TRAMS current title module and that serious consideration should be given to centralizing all title information in one organization in one location in conjunction with a single data system. Id. at 125.
The Deputy Special Trustee's "Assessment of sub-project" highlighted the work of the dedicated and concerned DOI employees who had worked on TRAMS but addressed the often-stated reasons for its potential demise including:
1. "TAAMS efforts have been handicapped by a perceived need for a 'quick fix' that prevented sufficient detailed information gathering and planning
2. TAAMS interdependencies with other trust reform efforts not well established
3. Insufficient continuity of project managers
4. Software contract has unresolved issues due to customization of system
5. Inadequate performance metrics have not been defined for contractor tasks
6. Inadequate project management" Id. at 126-127, emphasis added.
Due to the Director's decision to refuse to accept EDS' recommendation to "accelerate the nation-wide deployment of TAAMS title" even in light of the Secretary's acceptance of this recommendation, the Court Monitor spoke with both Swimmer and Erwin as well as with the EDS Project Manager. Their general statements about this decision centered on the fact that EDS had never tested the current title software, the May 2001 Integrated User Acceptance Tests had shown it to be questionable, and there were questions regarding its development and ability to be deployed even in the limited role it is performing in Billings. As evidence of this changed position by EDS, their "Trust Reform, Final Report and Roadmap," dated January 24, 2002 and filed with this Court on January 25, 2002, contains a "Clarification to Interim Report Published November 12, 2001" regarding TAAMS Title acceleration (see page 87 extract at Tab 6). That clarification states in part:
"Accelerating title,' means focusing existing resources on the data cleanup activities required to support the nation-wide deployment of core title functionality.
It is important to note the recommendation is not predicated on the introduction of new features or functions in the title module. It was specifically stated that the decision for enhancements should be made based on the costs and the associated benefits. If the costs outweigh the benefits then EDS recommends deferring further development and utilizing the current version as an interim solution.
As recommended in the Interim Report, the Department needs to develop a trust business model. Based on the business model, the Department needs to identify and evaluate appropriate information systems. Information system alternatives should include TAAMS, commercial applications, service bureau, outsourcing and modifications to existing legacy systems. Until this analysis is complete, the Department should continue to leverage TAAMS title." Id.
Interested to know what the new term "leverage" meant, the Court Monitor inquired of the project manager as to whether that term also meant deploy the system to other locations. The term "leverage" addresses the software within TAAMS title that incorporates the fractionalization calculations. As this application would have to be developed in any new system bought or designed to handle title work as it is unique to the IIM trust, one reason for further evaluating the possible retention of at least part of ATS' title software is this critical function that has already been developed and may save money and time if it can be integrated with whatever final system is selected by Defendants. Until that is determined, EDS believed Defendants should maintain at least this function until their later decision on the overall system requirements for trust reform. EDS did not mean to indicate in their previous reports that TAAMS title software was tested and found capable of meeting all user requirements or should be deployed to new locations without further stringent testing.
This section begins with a description of the project and the statement by the subproject manager that "DataCom performs the majority of the cleanup work." However, he added to this assessment that "(t)he reader should not assume that BIA is not involved in the work or that their effort is not being reported." Id. at 79.
To buttress his claim that DataCom is performing the majority of the cleanup work he lists eight pages of tasks being performed by DataCom. The Deputy Special Trustee, having reviewed this subproject, makes the following remarks among others:
"Assessment of sub-project
1. Definition of project not ...