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TO THE HEADS
OF EXECUTIVE DEPARTMENTS AND ESTABLISHMENTS
SUBJECT:
Consolidation of Agency Data Centers
1.
Purpose. This Bulletin provides guidelines for
significantly reducing the number of agency data centers and
reducing the total cost of data center operations
governmentwide. This Bulletin calls for agencies to:
- Reduce the
total number of agency data centers during the next 24
months, by closing many currently operating data centers and
concentrating their operations into a smaller number of
physical locations.
- Collocate
small and mid-tier computing platforms in larger data
centers.
- Modernize
remaining data centers in order to improve the delivery of
services.
- Outsource
information processing requirements to other Federal or
commercial data centers if the aggregate installed base is
below minimum target sizes.
2.
Background. The National Performance Review (NPR) report,
Reengineering Through Information Technology, includes a
recommendation to develop a Governmentwide data processing
consolidation and modernization plan. Industry experience
suggests operational savings of between 30 percent and 50
percent from consolidation when compared with unconsolidated
operations. With the assistance of the NPR and the Council of
Federal Data Center Directors, a committee was formed to
assist in collecting and analyzing information on today's
agency data center environment. The committee's report,
Consolidation of Federal Data Centers, recommends a data
center consolidation strategy and provides a plan for
implementing the recommended strategy. Information on
obtaining copies of the report can be found in Attachment 1.
3.
Applicability. This Bulletin applies to all Executive
agencies that operate or finance the operation of agency data
centers that support Government missions.
4. Policy.
Agencies are allowed considerable discretion as to which data
center(s) to retain and which to close so long as (1) the
selected consolidation scenario is cost-effective and the best
value, and (2) minimal data center target sizes are met.
Agencies should
strive for revenue neutral consolidation plans with capital
and operating expenditure savings being used to fund the
consolidation effort. Agencies should conduct business case
analyses to determine whether a site should be expanded into a
consolidated agency data center or phased out.
5.
Exceptions. OMB will consider exceptions to the guidance
and policy contained in this Bulletin on a case-by-case basis.
All requests for exceptions shall be submitted by the agency's
chief operating officer or comparable official. Exception
requests should be directed to the OMB policy official with
responsibility for the agency requesting the exception.
Requests for exceptions should also be noted in summary and
progress reports.
6.
Definitions. As used in this Bulletin:
a. Agency
- The term agency means any executive department, military
department, Government corporation, Government controlled
corporation, or other establishment in the executive branch of
the Federal Government, or any independent regulatory agency.
b. Agency Data
Center - Large centralized information processing
operations have traditionally been referred to as agency data
centers. This bulletin focuses on consolidating small,
mid-tier, and large computing platforms into such centralized
information processing centers. In order to identify all
information technology assets that should be considered for
consolidation, this traditional definition is expanded as
described below.
In the context of
consolidation and modernization, an agency data center is
defined as any automated information processing operation with
a standing staff of five or more full-time-equivalent (FTE)
employees (computer operators, computer systems programmers,
telecommunications specialists, administrative support staff,
etc.) that performs one or more of the following functions:
processes agency-approved automated applications systems,
affords time-sharing services to agency personnel, provides
office automation and records management services through a
centralized processor, and/or provides network management
support for agency wide area networks.
Facilities that
merely support local area networks (LANs), file servers, or
desktop computers are not categorized as agency data centers.
Applications programmers are not included in calculating FTE
employees.
c. Agency Data
Center Consolidation - Agency data center consolidation
means concentrating data processing into fewer physical
facilities and combining workload onto fewer computers. Agency
data center consolidation includes one or more of the
following concepts:
Collocation -
Moving information processing systems from multiple locations
to a single location where they continue to operate as
discrete systems.
Hardware
Consolidation and Upgrade - Combining hardware components from
various locations into centralized, modernized hardware
configurations.
Workload
Consolidation - Moving software applications workload from two
or more computer systems into discrete workload segments that
are processed on a single computer system. Workload
consolidated in this manner is considered to be "rehosted."
Workload consolidation is distinct from consolidation and
standardization of software applications that result from
reengineering basic functions and services and related
systems.
d. Agency Data
Center Modernization - Agency data center modernization
means upgrading, enhancing, and/or phasing out and replacing
outdated facilities, equipment, and operating practices, to
keep pace with improvements in information technology and
management methods. Modernized facilities, technology, and
management practices play a critical role in capturing the
economic benefits of agency data center consolidation.
e.
Outsourcing - Outsourcing means obtaining data processing
services from other Federal agencies or commercial concerns.
7.
Responsibilities. a. All Federal Agencies. The head of
each agency will:
- By March 1,
1996, develop an inventory of agency data centers and
identify the FY 1995 end-of-year size and cost of operations
of each data center in the format provided in Attachment 1.
A good starting point for most agencies will be found in the
Consolidation of Federal Data Centers report.
- By June 3,
1996, develop a data center consolidation strategy for
meeting the minimum target sizes established in Attachment
2. Agencies with an aggregate installed base below the
minimum target sizes must develop a strategy for outsourcing
to other Federal or commercial data centers.
- By September
2, 1996, develop a detailed Implementation Plan for
consolidation in accordance with Attachment 3. The plan
should identify all issues that will affect the schedule,
including those relating to acquisitions, human resources,
funding, and facility improvements. The plan will ensure
that agency data centers designated by agencies as receiving
sites be given administrative and budgetary priority for
facility buildout and upgrade; environmental improvements
(e.g., power supply, air conditioning, air purification);
adequate security and access provisions; and continuity of
operations.
- By June 1998,
complete consolidations.
- Determine if a
proper financing mechanism (management fund) exists in the
agency's account structure, within which a Federal data
center can be efficiently, and effectively operated on a
fee-for-service basis. Where the proper financing mechanism
does not exist, agencies should provide draft authorization
language along with their FY 1998 budget submission.
- Assure that
data center fee structures adhere to the costing
methodologies prescribed in OMB Circular A-130 (subsection
8.b.4.c) and the standardized accounting practices as
recommended by the Financial Accounting Standards Advisory
Board (FASAB) and issued by OMB and the General Accounting
Office (GAO).
- Provide
summary and progress reports to OMB in accordance with the
following schedule.
Inventory of Agency Data Centers --
Due March 1, 1996
Data Center Consolidation Strategy --
Due June 3, 1996
Summary of Implementation Plans -- Due
September 2, 1996
Semi-annual Report on the Status of
Consolidation -- Due January 30, 1997, and every six months
thereafter
b. General
Services Administration. The General Services Administration
will:
- Review any
relevant requests for Delegations of Procurement Authority
to verify that agencies are complying with the guidelines
contained in this Bulletin.
- Allow the
procurement of additional computing capabilities for agency
data centers that are offering cross-servicing to other
agencies.
- Award and
service governmentwide contracts to provide agencies with
quick, low-cost alternatives for obtaining commercial data
processing services.
c. Office of
Management and Budget. The Office of Management and Budget
will:
- Review
agencies' streamlining plans and budget requests for
consistency with this Bulletin.
- Track
agencies' semi-annual reporting on progress towards
consolidation.
- Review
legislation for working capital funds in support of data
centers that offer services on a fee-for-service basis.
- Monitor
consolidated agency data centers for cost and effectiveness
relative to the private sector and for conformance with
overall government policies.
- Promulgate
additional guidance as appropriate.
8.
Submission Requirements. Agencies are asked to provide the
required summary and progress reports to Sally Katzen,
Administrator, Office of Information and Regulatory Affairs,
Room 10236, NEOB, Washington, D.C. 20503.
9. Information
Contacts. Specific agency concerns should be directed to
the agency's program examiner. General questions regarding
Attachments 1-4 of the Bulletin can be directed to Jasmeet
Seehra at 202-395-3123.
10.
Termination Date. This Bulletin expires three years from
date of issuance.
Alice M. Rivlin
Director
Attachment 1 -
Inventory of Agency Data Centers
Attachment 2 - Data Center
Consolidation Strategy
Attachment 3 - Summary of
Implementation Plans
Attachment 4 - Semi-annual Report on
the Status of Consolidation
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Attachment
1
Inventory of Agency Data Centers
Agencies will
provide for OMB review an aggregate data center inventory for
the agency containing the elements identified in section 1.2.
In order to develop the aggregate information, agencies will
conduct site surveys of data centers to establish the agency's
current information processing environment, including
technical, staffing, and cost data. Agencies will then develop
a single site survey database to accommodate the results of
all site surveys. For many agencies, the report of the
interagency committee, Consolidation of Federal Data
Centers, will be a good starting point for developing
an inventory.
1.1 Individual
Data Center Inventory. Agencies will collect the following
site-level technical, staffing, and cost data for each data
center:
(a) Data center
name, location, and primary mission;
(b) Basic hardware
configuration:
- Mainframe
processors including quantity, make/model, and processor
rating, and [Note: The delineation between mid-tier
processors and mainframes often blurs on the margins. As
defined by this bulletin mainframe processors are
large-scale, multi-tasking computers that (1) serve large
numbers of concurrent on-line users and/or (2) execute batch
applications. These machines generally operate on raised
computer room floors and require controlled environmental
conditions.]
- Small and
mid-tier processors including quantity, make/model, and
primary use; [Note: As defined by this bulletin, small and
mid-tier processors do not include desktop personal
computers or scientific work stations. Small and mid-tier
processors are those machines that fall in the range between
the work station and the mainframe. Examples of their uses
include, but are not limited to, client servers, network
controllers, process controllers, and dedicated single
application processors.]
(c) Federal
and contractor data center staff, including data center
management personnel, computer operators, computer systems
programmers, communications specialists, and administrative
and support staff; and
(d) FY 1995 costs
for hardware (purchase, lease, and maintenance); software
(purchase, licenses,and maintenance); staffing (direct and
indirect); utilities; facilities (purchase, lease, and
maintenance); communications (voice and data); and contract
services. A suggested format the individual data center
inventory is provided below.
Individual
Data Center Inventory
Reports are
populated with sample data for illustrative purposes.
Department of
_________(Department Name)_________
General
Information
| Data center name |
Data Center
Name |
| Data center location |
Complete
Address |
| Primary Mission |
Briefly describe primary service
provided by Data
Center |
Basic Hardware
Configuration
Mainframe
Processors
| Quantity |
Make/Model |
Processor Rating |
Total Processing Power Quantity
X Processor Rating |
| -- |
2 |
IBM 3090-300S |
58 MIPS |
116 MIPS |
| -- |
2 |
Unisys 2200-644 |
53 MIPS |
106 MIPS |
| Total |
4 |
-- |
-- |
222
MIPS |
Small and
Mid-Tier Processors
|
Quantity |
Make/Model |
Primary Use |
|
4 |
DEC VAX 4000/70A |
Departmental client
server |
|
5 |
IBM AS/400 Model 9406 |
Distributed departmental
processing |
|
3 |
HP 9000 Model 800/H40 |
Departmental client
server |
| Total |
12 |
-- |
-- |
Number of Staff
|
Federal |
Contractor |
Total |
| Management |
3 |
0 |
3 |
Operations/Productions
Recovery |
5 |
3 |
8 |
Computer
System
Programmers |
2 |
2 |
4 |
Communications/
Network
Support |
0 |
3 |
3 |
Administrative and
Support
Staff |
4 |
4 |
8 |
| Total |
14 |
12 |
26 |
Data Center Cost
Recovery
| Cost Element |
|
Congressionally
Appropriated |
Revenues Derived
From
Services |
| Hardware |
Purchases |
$1,000,000.00 |
$500,000.00 |
| -- |
Lease |
- 0 - |
$100,000.00 |
| -- |
Maintenance |
$70,000.00 |
$40,000.00 |
| -- |
Total |
$1,070,000.00 |
$640,000.00 |
| Software |
Purchases |
$30,000.00 |
$42,000.00 |
| -- |
Licenses |
$42,000.00 |
$30,000.00 |
| -- |
Maintenance |
$40,000.00 |
$40,000.00 |
| -- |
Total |
$112.000.00 |
$112,000.00 |
Staffing (Federal
FTEs
only) |
Direct |
$1,000,000.00 |
$500,000.00 |
| -- |
Indirect |
$200,000.00 |
$100,000.00 |
| -- |
Total |
$1,200,000.00 |
$600,000.00 |
| Utilities |
-- |
$200,000.00 |
$100,000.00 |
| Facilities |
Purchase |
- 0 - |
- 0 - |
| -- |
Lease |
$200,000.00 |
$100,000.00 |
| -- |
Maintenance |
$70,000.00 |
$40,000.00 |
| -- |
Total |
$270,000.00 |
$140,000.00 |
| Communications |
Voice |
$70,000.00 |
$70,000.00 |
| -- |
Data |
$100,000.00 |
$100,000.00 |
| -- |
Total |
$170,000.00 |
$170,000.00 |
Contract
Services* |
-- |
$200,000.00 |
$100,000.00 |
Other (Please
Specify) |
-- |
- 0 - |
- 0 - |
| Grand Total |
-- |
$3,222,000.00 |
$1,862,000.00 |
*Contract
staffing is reported under contract services
1.2 Aggregate
Data Center Inventory. Agencies will provide to OMB in the
format shown below a summary report that aggregates the
technical , staffing, and data elements at the agency level;
total costs for each element for FY 1995, and total agency
costs for FY 1995.
AGGREGATE
DATA CENTER INVENTORY
(to be provided to
OMB)
Department
of ________Department Name ______________
Total
Mainframe Product Line Processing Power
| Product line |
Total Processing
Power* |
| Amdahal |
325 MIPS |
| Honeywell |
75 MIPS |
| Digital |
200 VUPS |
| Total |
600 |
* Dissimilar
processing power rating units should be aggregated when
completing this table (see Attachment 2).
Small and
Mid-Tier Processors
| Product Line |
Quantity |
| Hewlett Packard |
32 |
| Netframe |
12 |
| Total |
44 |
Number of
Staff
Agency
Aggregate Data Center Cost Recovery
| Cost Element |
Congressionally
appropriated |
Derived
from
Services |
| Hardware |
$5,350,000.00 |
$3,200,000.00 |
| Software |
$560,000.00 |
$220,000.00 |
| Staffing (Federal FTEs only) |
$6,000,000.00 |
$3,000,000.00 |
| Utilities |
$1,000,000.00 |
$500,000.00 |
| Facilities |
$1,350,000.00 |
$700,000.00 |
| Communications |
$850,000.00 |
$850,000.00 |
| Contract Services* |
$1,000,000.00 |
$500,000.00 |
| Other (Please specify) |
- 0 - |
- 0 - |
| Total |
$16,110,000.00 |
$9,310,000.00 |
*Contract
staffing should be reported under contract services
List of Data
Centers
| Data Center |
Computed Data Center
Size* |
| St. Louis |
325 MIPS |
| Seattle, WA |
200 MIPS |
| Washington, D.C. |
75 VUPS |
| Total |
600 |
* Dissimilar
processing power rating units should be aggregated when
completing this table -- see attachment 2.
--------------------------------------------------------------------------------
Attachment
2
Data Center Consolidation Strategy
Agencies will
develop a data center consolidation strategy to meet the
target sizes set out below.
2.1 Target
Sizes. The following minimum target sizes are established
for the various large scale computing product lines. These
minimal target sizes are based on the central processing units
housed at a particular center. The targets do not include the
processing capacity of the small and mid-tier machines
installed at the site. Note that these are minimum targets and
that agencies are encouraged to set higher targets where
cost-effective.
PRODUCT
LINE |
DIGITAL |
HONEYWELL |
IBM/IBM
COMPATIBLE |
UNISYS |
| Minimal Size |
225 VUPS |
175 MIPS |
325 MIPS |
225
MIPS |
The minimal
target size in a heterogeneous product line environment shall
be that of the product line with the highest minimal target
sizes. With concurrence of the agency's chief operating
officer or comparable official, the minimal target size shall
be the numerical average of the several product lines.
Departmental high
performance scientific processors (except embedded machines
and those used principally for research) should be
consolidated (1) into a single location or (2) into the same
facilities that house general purpose computers. When
consolidated into general purpose computer facilities, these
machines should not be included in the minimal target size
computation. However, housing scientific processors at a
particular center may be used to economically justify a center
that would otherwise be at least 90 percent of the minimal
target size. Similarly, housing of a large number of small and
mid-tier processors may be used to economically justify a
center that would otherwise be at least 90 percent of the
minimal target size.
2.2 Data
Center Consolidation Strategy. Each agency will submit by
June 3, 1996 a data center consolidation strategy addressing
the following elements:
- Alternatives
Analysis. The agency consolidation strategy should be based
on analysis of alternatives including outsourcing. Based on
the data center inventory, analysis of alternatives should
reflect the technical feasibility and probable cost
effectiveness of each alternative. Agencies are allowed
considerable discretion as to which data center(s) to retain
and which to close so long as (1) the selected consolidation
scenario is cost-effective and the best value, and (2)
minimal data center target sizes are met.
- Architecture
Design - The agency's data center consolidation strategic
plan will identify the technical solution--a high-level
consolidation architecture that reflects the best approach
to consolidating the organization's data centers based on
the selected data center consolidation alternative. The
technical solution or consolidation architecture will
identify the receiving and closing data centers and workload
realignment as well as the communications architecture.
Agencies should seek commercial disaster recovery solutions
rather than dividing their work load into multiple sites for
the purpose of disaster recovery, unless (l) each site meets
the minimal target size, and (2) the combined capital and
operating costs, less the costs of commercial disaster
recovery, is less than the single site operation.
- Implementation
Approach - The high-level implementation approach identifies
major consolidation tasks and presents a schedule,
milestones, and resources. Major consolidation tasks include
development of the agency's Data Center Consolidation
Implementation Plan and supporting documents and plans, and
implementation activities such as preparing receiving sites,
transitioning workload from closing to receiving sites,
performing necessary environmental upgrades or modifications
at receiving sites, and conducting acquisition activities.
- Funding Plan -
The funding plan identifies and forecasts costs associated
with the consolidation process. Funding requirements for all
major tasks associated with consolidation are included in
this spending plan. Forecast savings from consolidation are
offset against expenditures to identify the net cost of
consolidation.
- Exceptions -
The agency consolidation strategy should identify data
centers that, for non-economic, mission-related reasons,
cannot be included in the consolidation plan. OMB will
consider exceptions on a case-by-case basis only. Requests
for exceptions shall be approved by the agency's chief
operating officer or comparable official.
--------------------------------------------------------------------------------
Attachment
3
Summary of Implementation Plans
Each agency
should develop an agency-wide Data Center Consolidation
Implementation Plan describing how the agency will achieve the
objectives of its consolidation strategy. A summary of this
plan will be provided to OMB for review by September 2, 1996.
The agency's Data Center Consolidation Implementation Plan
serves as a project master plan that allows the agency to
monitor progress and facilitates semiannual reporting to OMB.
The plan, which evolves as the consolidation effort
progresses, contains the consolidation strategy, project tasks
resources required, roles and responsibilities, and master
schedule of consolidation project tasks and milestones.
To ensure the
completeness and consistency of supporting documents and
plans, which will become attachments to the plan, the agency's
Data Center Consolidation Implementation Plan should include
the following:
a. Detailed
Technical Architecture
b. Transition Plan
c. Concept of
Operation Plan
d. Security Plan and Disaster Recovery
Plan
e. Resources Management Technical Plan (Funding
Plan)
f. Human Resources Plan
g. Acquisition Plan
h.
Fee-for-Service Structure
I. Optimization Plan
3.1 Detailed
Technical Architecture - The detailed technical
architecture for each consolidated data center should
describe: (1) the information processing environment,
including processor platforms, on-line storage requirements,
output devices, terminals, communications and network devices,
and other peripheral devices; (2) resource allocation by user
environments; (3) commercial-off-the-shelf software, and
operating system software; (4) the physical layout including
hardware placement, cabling, communications, power
distribution, and HVAC requirements; and (5) the configuration
of all sites affected by this Bulletin, including network
connectivity and output devices.
3.2 Transition
Plan - Depending on the size and complexity of the
consolidated data center architecture, detailed transition
plans may be developed for each receiving or closing site. A
Transition Plan outlines the required activities and documents
the process for: (1) conducting the final closing site
baseline of workload mix and corresponding performance levels
that must be met by the receiving site prior to acceptance;
(2) reconfiguration of the receiving site to accommodate
additional data processing and communications workload
requirements; (3) systems integration and testing to ensure
that the configuration meets the design specifications; (4)
moving the data processing workloads from closing sites to the
receiving site; (5) receiving site coordination with closing
site customers during the acceptance to ensure, in accordance
with mutually agreed-upon criteria, that they are receiving
service at least equal to that provided in the closing system
environment; (6) close-out activities that will be undertaken
after the closing site is successfully transitioned and
accepted at the receiving site; and (7) moving the receiving
site data processing workloads to an optimal processing
configuration. The transition plan includes a schedule showing
start and end dates for transition tasks and milestones.
3.3 Concept of
Operation Plan - The concept of operation plan should
identify the performance goals and objectives of the
consolidated data center and define how the consolidated data
center will operate to meet those goals and objectives.
Consolidated data center policies and procedures should be
designed according to best practices, provide service at least
equal to that provided by the closing sites, place
responsibilities at the lowest workable level, and promote
standardization among the agency's consolidated data centers.
The concept of operation should define the consolidated data
center's approach to: (1) customer support and problem
resolution; (2) capacity management, including capacity
planning, service level management, and performance
management; (3) configuration and change management; (4)
customer and data center security management responsibilities;
(5) production scheduling and production problem resolution;
(6) tape management; and (7) direct access storage device
(DASD) management.
3.4 Security
Plan and Disaster Recovery Plan - The agency should review
and revise as necessary its information systems security
program policies and procedures to reflect the requirements of
the consolidated data center environment. Data center security
plans should (1) define the security environment, (2) identify
security requirements, (3) establish customer and data center
security roles and responsibilities, (4) describe core
security services provided by the data center and any
customer-unique security services, (5) describe how security
services will be provided and periodically reviewed and
tested, and (6) identify security training and awareness
activities. The data center security plan should be supported
by documented procedures. The agency should establish a
disaster recovery plan that (1) identifies critical agency
operations and (2) describes how critical agency operations
will be recovered in the event of a disaster. Agencies should
consider commercial disaster recovery solutions offered
through the GSA.
3.6 Resources
Management Technical Plan (Funding Plan) - Detailed
consolidation spending plans should reflect all projected
consolidation project costs including (1) capital investments,
(2) TDY travel and relocation, (3) equipment transportation,
(4) software licenses, (5) human resources implementation
costs, (6) communications costs, (7) facility improvements,
and (8) disaster recovery.
3.7 Human
Resources Plan - Agencies should develop a human resources
plan with the objectives of retaining necessary personnel at
closing sites until the sites are successfully transitioned,
establishing qualifications for consolidated data center
personnel, and providing options for closing site personnel.
The human resources plan should include: (1) data center
personnel skills requirements, (2) data center personnel
skills inventory, (3) transfer options, (4) training options,
and (5) outplacement options.
3.8
Acquisition Plan - Acquisition plans should be developed
to support agency data center consolidation and modernization
efforts that require upgraded or new hardware, software, and
communications equipment; facility improvements; and physical,
personnel, and information systems security improvements.
3.9
Fee-for-Service Structure - If the receiving data center
has a fee-for-service chargeback structure in place, it should
be expanded to include new customers. If the receiving center
has not operated on a fee-for-service basis, a chargeback
structure and corresponding procedures should be established
and implemented as new customers begin using the data center.
The fee-for-service structure should (1) track system usage,
(2) monitor operational costs, (3) establish service rates,
and (4) bill users. For the purposes of the data consolidation
plan, data center operations should be considered separate
from other non-related business activities supported in the
same working capital fund.
3.10
Optimization Plan - Optimization plans encompass the
design and implementation activities for building an optimal
agencywide processing configuration in all consolidated data
centers. An optimization plan should identify efforts to
optimize data center operations through standardization of
operating systems, database management systems, programming
languages, and off-the-shelf software; modernization,
including technology insertions and communications and
hardware upgrades; automation; and reengineering.
--------------------------------------------------------------------------------
Attachment
4
Semi-Annual Report on Status of
Consolidation
Agencies will
provide to OMB on a semi-annual basis beginning January 30,
1997, the following Major Consolidation Milestones report. For
each milestone contained in the Major Consolidation Milestones
report, the agency should develop subordinate consolidation
milestones with planned and actual completion dates.
Failure to
achieve the planned completion date for Major Consolidation
Milestones must be accompanied by a narrative explanation and
a recovery plan to return to schedule by the next semi-annual
reporting date.
Semi-Annual
Reporting
Major Consolidation Milestones
Major
Consolidation
Milestone |
Planned Completion
Date |
Actual Completion
Date |
| Conduct Data Center
Inventory |
-- |
-- |
| Develop Consolidation
Strategy |
-- |
-- |
| Develop Implementation Plan |
-- |
-- |
Insert Agency Specific
Milestones
from Implementation Plan |
-- |
-- |
| Complete Consolidation |
6/30/98 |
-- |
|