United States Government Accountability Office

GAO Report to Congressional Committees

MILITARY BASE 

CLOSURES 

Opportunities Exist to 

Improve 

Environmental 

Cleanup Cost 

Reporting and to 

Expedite Transfer of 

Unneeded Property 

January 2007 

This report was amended on February 16, 2007, 

to correct headers, which were changed from 2ndto 1st-level headers on pages 12, 19, and 24. 

GAO-07-166 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

January 2007

MILITARY BASE CLOSURES 

Opportunities Exist to Improve 

Environmental Cleanup Cost Reporting 

and to Expedite Transfer of Unneeded 

Property 

Highlights of GAO-07-166 a report to 

congressional committees 

The cleanup of environmental 

contamination on unneeded 

property resulting from prior 

defense base realignment and 

closure (BRAC) rounds has been a 

key impediment to the transfer of

these properties and could be an

issue in the transfer and reuse of

unneeded property resulting from

the 2005 BRAC round. GAO’s 

analysis of available data indicates 

that, when completed, the cleanup 

for the four prior BRAC rounds is 

expected to cost about $13.2 billion 

and additional costs will be needed

for BRAC 2005 property. These 

costs reduce BRAC savings, 

especially in the short term. 

Because of broad congressional 

interest in BRAC, GAO prepared

this report under the Comptroller

General’s authority to conduct 

evaluations on his own initiative. 

GAO’s objectives were to examine 

costs to clean up 2005 BRAC 

properties, progress in transferring 

prior BRAC rounds properties to 

other users, and opportunities to 

expedite cleanups and transfers.

To address these issues, GAO 

analyzed cleanup cost estimates,

interviewed environmental officials 

and visited seven bases. 

While expected environmental cleanup costs for unneeded property arising 

from the 2005 BRAC round are not yet fully known, Department of Defense 

(DOD) data indicate that about $950 million will be needed to clean up these 

bases, adding to the estimated $13.2 billion total cleanup cost for the prior 

rounds. Although DOD’s cleanup program has matured compared to prior 

BRAC rounds, there are still many unknowns and the cleanup estimate for 

the 2005 round should be considered preliminary. In fact, environmental 

cleanup costs are likely to increase as more intensive environmental 

investigations are undertaken, additional hazardous conditions are 

discovered, and future reuse plans are finalized. Furthermore, Congress 

does not have full visibility over the total cost of DOD’s BRAC cleanup 

efforts because none of the four reports DOD prepares on various aspects of 

environmental cleanup present all types of costs—past and future—to 

complete cleanup at each base. Compiling a complete picture of all costs 

requires extracting information from multiple reports, as GAO has done to 

estimate the total cleanup cost for the four prior BRAC rounds. More 

complete and transparent cost information would assist Congress in 

conducting its oversight responsibilities for this multibillion dollar effort. 

 

While GAO’s analysis shows that DOD continues to make progress in 

transferring over 502,500 acres of unneeded property from the four prior 

BRAC rounds—78 percent of the acres have now been transferred compared 

to 72 percent 2 years ago—over 112,300 acres remain untransferred. 

Comparatively, a total of about 102,000 acres are potentially transferable as a 

result of the 2005 BRAC round. Impediments to transfer continue to be 

related primarily to a variety of interrelated environmental cleanup issues,

including limited technology to address unexploded ordnance and prolonged 

negotiations on compliance with environmental regulations. 

Opportunities exist to expedite the cleanup and transfer of unneeded 2005 

BRAC properties compared with other BRAC rounds. Congress provided 

DOD with a wide range of property transfer authorities for prior BRAC 

rounds. In the past DOD did not use some tools as much as others out of 

deference to community land reuse plans. For example, low- and no-cost 

transfer tools accounted for 65 percent of all acres transferred, whereas 

public and negotiated sales accounted for 5 percent. DOD’s March 2006 

guidance now encourages the services to make full use of all tools for 

transferring properties resulting from both the 2005 and prior-year BRAC

rounds. The services have processes in place to monitor their progress to 

clean up and transfer BRAC properties, but they are not required to report 

periodically to the Office of the Secretary of Defense on their successes and 

challenges in using various transfer authorities. Collectively, such lessons 

learned could help others expedite the cleanup and transfer of unneeded 

properties by maximizing the use of all available tools, thereby accelerating 

the economic benefits of property reuse to communities while also saving 

the ongoing caretaker costs being incurred by DOD for unneeded properties.

What GAO Recommends

GAO is recommending that DOD 

improve its reporting of BRAC 

environmental cleanup costs to

Congress and share lessons learned 

in the use of all available tools to 

clean up and transfer property. 

DOD partially concurred with 

GAO’s recommendations.

www.gao.gov/cgi-bin/getrpt?GAO-07-166.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Brian Lepore 

(202) 512-4523 or leporeb@gao.gov. 
Military Base Closures

Contents 

Letter 1

Results in Brief 3

Background 7

Expected Environmental Cleanup Costs for the 2005 BRAC Round 

Are Not Yet Fully Known 12 

DOD Continues to Make Progress in Transferring Unneeded 

Properties, but Environmental Cleanup Continues to be a Key 

Impediment to Transfer of Remaining Properties 19 

Opportunities Exist to Expedite Cleanup and Transfer of Unneeded 

BRAC Properties 24 

Conclusions 32

Recommendations for Executive Action 33 

Agency Comments and Our Evaluation 33 

Appendix I: Scope and Methodology 38 

Appendix II: CERCLA Cleanup Requirements 42 

Appendix III: Environmental Cleanup Cost Information in Four 

Selected Reports to Congress 44 

Appendix IV: Comments from the Department of Defense 47 

Appendix V: Key Prior GAO Reports on DOD Environmental 

Cleanup 50

Appendix VI: GAO Contacts and Staff Acknowledgments 51 

 

Page i GAO-07-166
Military Base Closures

Tables 

Table 1: Comparison of BRAC 2005 Recommendations with 

Recommendations from Prior Rounds 8 

Table 2: BRAC 2005 Major Closures’ Estimated Environmental 

Cleanup Costs from Fiscal Year 2006 to Completion (in 

millions) 14

Table 3: Total Expected Environmental Costs for Prior BRAC 

Rounds 18

Table 4: Top 10 Most Expensive Cost to Complete Cleanups at 

Prior Round BRAC Installations for Fiscal Year 2006 and 

Beyond (dollars in millions) 23 

Table 5: Property Transfer Alternatives under the BRAC Process 25 

Table 6: Use of Early Transfer Authority at Prior BRAC Round 

Bases, as of July 2006 30 

Figures 

Figure 1: Disposition of Unneeded BRAC Acreage from Prior 

Rounds, as of September 30, 2006 20 

Figure 2: Workers Searching for UXO at the Former Fort Ord Using 

Hand-Held Detection Devices 22 

Figure 3: Alternatives Used to Transfer Unneeded BRAC Acreage 

to Nonfederal Entities in Prior BRAC Rounds, as of 

September 30, 2006 27 

Abbreviations 

BRAC base realignment and closure 

CERCLA Comprehensive Environmental Response, Compensation 

and Liability Act 

DERP Defense Environmental Restoration Program 

DOD Department of Defense 

OSD Office of the Secretary of Defense 

SARA Superfund Amendments and Reauthorization Act 

UXO unexploded ordnance 

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Page ii GAO-07-166
United States Government Accountability Office

Washington, DC 20548 

January 30, 2007 

Congressional Committees 

The cleanup of environmental contaminants, such as hazardous chemicals 

or unexploded ordnance (UXO),1

 found on bases closed under the base 

realignment and closure (BRAC) process has historically been a key 

impediment to the expeditious transfer of unneeded property to other 

federal and nonfederal parties who can put the property to new uses. 

While the Department of Defense (DOD) is obligated to ensure that former 

base property is cleaned up to a level that is protective of human health

and the environment, the cleanup process can delay redevelopment in 

neighboring communities adversely impacted by the BRAC process. Our 

analysis of DOD data indicates that the estimated total cost to clean up 

environmental contaminants found on installations affected by the four 

prior BRAC rounds2

 is approximately $13.2 billion, and while most of this 

cost has already been incurred, the cleanup process is expected to 

continue for many years at some closure sites. Environmental cleanup of 

unneeded property arising from the 2005 BRAC round closures will add 

additional costs. Cleanup costs, combined with additional caretaker costs 

DOD continues to incur for untransferred properties, cause some offset to 

projected net savings from BRAC with the greatest impact occurring in the 

short term. 

This report is one in a series of reports we have issued on DOD 

environmental cleanup liabilities and property transfer issues that relate to

the BRAC process. (See app. V for a list of key prior GAO reports.) Our 

prior work3

 showed that, as of September 30, 2004, DOD had transferred 

about 72 percent of over 504,000 acres of unneeded BRAC property from 

the prior rounds to other entities for reuse, but about 140,000 acres of 

unneeded DOD property had not been transferred at that time, primarily 

 1

UXO refers to ordnance that remains unexploded either through malfunction or design 

and can injure personnel or damage material. Types of UXO include bombs, missiles,

rockets, artillery rounds, ammunition, or mines and is sometimes referred to as munitions 

and explosives of concern.

2

BRAC rounds were conducted in 1988, 1991, 1993, and 1995. 

3

GAO, Military Base Closures: Updated Status of Prior Base Realignments and Closures, 

GAO-05-138 (Washington, D.C.: Jan. 13, 2005).

Page 1 GAO-07-166 Military Base Closures
because of issues related to environmental cleanup. Further, we reported 

that estimated costs for environmental cleanup at sites from the prior 

BRAC rounds remained within the range of prior estimates, but those 

costs could increase if unknown or undetermined future cleanup 

responsibilities, such as additional unexploded ordnance or other harmful 

contaminants, emerged. 

Because of the broad congressional interest in the BRAC process, we 

prepared this report under the Comptroller General’s authority to conduct 

evaluations on his own initiative to examine (1) potential environmental 

cleanup costs for 2005 BRAC properties, including an examination of how 

these costs are reported for all BRAC properties; (2) DOD’s progress, since 

our prior work in 2005, to transfer unneeded properties from the four prior 

BRAC rounds; and (3) possible opportunities for DOD to expedite the 

cleanup and transfer of unneeded BRAC properties. This report is 

addressed to you because of your role in the oversight of DOD’s 

infrastructure and BRAC implementation actions. 

To examine the potential cost to clean up unneeded properties resulting 

from the 2005 BRAC round, we analyzed various DOD reports submitted to 

Congress on the environmental cost of cleanups at military bases in 

general, and interviewed DOD and military service officials familiar with 

the environmental cleanup process at military bases for clarification of 

these reports as well as the cleanup process as it affects BRAC bases. We 

visited four bases identified for closure in the 2005 BRAC round that 

reportedly have environmental cleanup needs—Fort Monroe, Hampton, 

Virginia; Umatilla Chemical Depot, Hermiston, Oregon; Brunswick Naval 

Air Station, Brunswick, Maine; and the Mississippi Army Ammunition 

Plant, Picayune, Mississippi. To assess DOD’s progress in transferring 

properties from the four prior BRAC rounds since our prior work in 2005, 

we analyzed the Defense Environmental Programs Fiscal Year 2005 

Annual Report to Congress and collected property transfer information 

from the cognizant offices in each of the military services. Although we 

found some discrepancies, we concluded that overall the DOD data were 

sufficiently reliable for the purposes of this report. To assess opportunities 

for DOD to expedite cleanup and transfer of unneeded properties due to 

environmental hazards, we reviewed the laws, regulations, and policies 

governing the cleanup and transfer of properties. We also visited three 

BRAC bases from the prior BRAC rounds—which represent the three 

bases with the most expensive estimated costs to complete environmental 

cleanup—and interviewed local community property reuse officials as 

well as military environmental cleanup specialists to obtain their 

perspective on cleanup and property transfer issues. The bases we visited 

Page 2 GAO-07-166 Military Base Closures
were the former Fort Ord, Marina, California; the former McClellan Air 

Force Base, Sacramento, California; and the former Alameda Naval Air 

Station, Alameda, California. We also interviewed officials representing 

federal and state environmental regulatory agencies for their perspective 

on DOD cleanup activities and any opportunities for DOD to expedite the 

cleanup and property transfer process while adhering to cleanup 

standards and regulations. We conducted our work from January 2006 

through November 2006 in accordance with generally accepted 

government auditing standards. Further details on our scope and 

methodology can be found in appendix I. 

While expected environmental cleanup costs for bases scheduled for 

closure as a result of the 2005 BRAC round are not yet fully known, DOD’s 

data indicate that about $950 million will be needed to complete these 

cleanups, adding to the estimated $13.2 billion required for the prior BRAC 

rounds. About $590 million of DOD’s $950 million for the 2005 round is 

attributable to estimated cleanup costs at 25 expected major base 

closures4

 consisting of about 102,000 acres5 of potentially transferable 

properties. The remaining $360 million is attributable to DOD’s estimated 

cleanup costs for minor base closures.6

 However, these estimates should 

be viewed as preliminary. Although DOD’s cleanup program for known 

environmental contamination has matured compared to that of prior 

BRAC rounds, the full extent of cleanup requirements and associated costs 

for the 2005 round is likely to increase as more intensive environmental 

investigations are undertaken, additional hazardous conditions that may 

exist are found, and future reuse plans are finalized. In addition, DOD’s 

munitions cleanup program is in its early stages, and the expected costs at 

many cleanup sites are not well defined or included in DOD’s estimates, at 

this time. DOD is in the process of further identifying its cleanup 

requirements, but it may be several more years before more precise cost 

Results in Brief 

 4

DOD defines a major closure as one where the installation’s plant replacement value 

exceeds $100 million. Included in this figure is the Navy’s Broadway Complex in California, 

which was to be a major closure if the Navy did not enter into a long-term lease to 

redevelop the Complex before January 1, 2007. The Complex was leased to a private firm in

November 2006 and thus will not close. 

5

This figure includes acreage at three chemical demilitarization bases slated for closure—

Deseret Chemical Depot, Utah; Newport Chemical Depot, Indiana; and Umatilla Chemical 

Depot, Oregon.

6

DOD defines minor closures as those installations with plant replacement values of less 

than or equal to $100 million. 

Page 3 GAO-07-166 Military Base Closures
estimates are available. Furthermore, Congress does not have full visibility 

over the total cost of DOD’s BRAC cleanup efforts because DOD does not, 

nor is it required to, present all types of costs—past and future—needed to 

complete the environmental cleanup at each BRAC installation in any one 

report, and because DOD does not fully explain the scope and limitations 

of the costs it does report. Transparency and accountability in financial

reporting and budgeting are essential elements for providing Congress a 

complete picture of the total cost of BRAC environmental cleanups to 

make appropriate budgetary decisions. DOD prepares at least four 

different reports for Congress on the status and cost of environmental 

cleanup for each military base, including BRAC bases. Each report is 

designed to serve a different purpose, such as budgetary, financial, and 

program oversight, resulting in various presentations of estimated and

actual cleanup costs. However, none of the reports provides the total 

expected cost—both the costs incurred to date as well as expected future 

costs—for environmental cleanup by installation. In order to get a more 

complete picture of cleanup costs, our analysis involved an in-depth 

examination of multiple DOD reports.7

 In the absence of one report that 

presents all environmental cleanup costs and estimates for each military 

base, Congress will continue to be presented with a varying array of 

information. More complete and transparent cost reports would assist 

Congress in carrying out its oversight responsibilities for the multibillion 

dollar BRAC environmental cleanup effort. In order to provide more 

complete and transparent cost information for the environmental cleanup

of unneeded properties from all BRAC rounds, we are recommending that 

DOD report all types of cleanup costs—past and expected future—

required to complete environmental cleanup at each BRAC installation and 

fully explain the scope and limitations of the environmental cleanup costs 

it currently presents to Congress. 

 7

Our analysis compiled from multiple DOD reports indicates that for the first four BRAC

rounds $9.0 billion has been made available for the environmental cleanup—restoration 

and munitions cleanup, compliance, and program management and planning—through 

fiscal year 2005, and that after fiscal year 2005 an estimated $4.2 billion more would be 

required to complete the cleanup, for an overall total of $13.2 billion. Similar information 

has not been compiled as yet for cleanup costs for the 2005 BRAC round. 

Page 4 GAO-07-166 Military Base Closures
Although our analysis shows that DOD continues to make progress in 

transferring8

 the over 502,500 acres9 of unneeded property resulting from 

the four prior BRAC rounds—78 percent (about 390,300 acres) has now 

been transferred compared to 72 percent (about 364,000 acres) 2 years 

ago—about 112,300 acres remain untransferred, and the cleanup of 

environmental contamination remains a key impediment. Environmental 

cleanup issues are unique to each site but cleanup delays, when they 

occur, usually result from a variety of interrelated factors, including 

limited available technology to address unexploded ordnance (UXO) 

cleanup issues, prolonged negotiations over how to comply with 

environmental regulations, and discovery of previously unknown and 

therefore unaddressed environmental hazards. 

Opportunities exist to expedite the cleanup and transfer of unneeded 2005 

BRAC properties. Over the years, Congress has provided DOD with a wide

range of property transfer authorities to expedite the cleanup and transfer 

of unneeded BRAC property, including public sales and the so-called 

“Early Transfer Authority,”10 which allows property to be transferred under 

certain conditions before all necessary cleanup actions have been 

completed. In prior BRAC rounds, DOD did not use some tools as often as 

others, such as public and negotiated sales, because DOD wanted to give a 

high priority to each community’s property reuse plans when disposing of 

unneeded BRAC properties. As of September 30, 2006, low or no-cost 

transfer tools such as public benefit, conservation, and economic 

development conveyances accounted for 65 percent of all acres 

transferred to nonfederal entities, whereas public and negotiated sales 

accounted for 5 percent. However, DOD’s guidance on implementing the 

2005 BRAC round suggests that more recent experience indicates that a 

broader range of approaches may now succeed where they would not have 

worked in the past. For example, at the former Alameda Naval Air Station, 

California, agreement was reached in 2000 to transfer some of the 

 8

For the purposes of this report, the term transfer refers to property that has been deeded 

to another user; it does not include leased property. Transfer data represent the best

available data provided by each of the services as of September 30, 2006. 

9

In 2005, we reported approximately 72 percent of 504,000 unneeded acres were disposed 

of by DOD. This unneeded acreage differs from the approximate 502,500 acres currently 

reported because as property is transferred, more accurate surveys are being completed, 

which changes the amount of available acres from one year to another. Further, some 

acreage initially declared excess has been retained by DOD, thus decreasing the acreage 

available for transfer. 

10Pub. L. No. 104-201, § 334 (1996). 

Page 5 GAO-07-166 Military Base Closures
installation’s property using a no-cost economic development conveyance,

but because of a subsequent decline in the economy, the local 

redevelopment authority could not meet the terms of the conveyance 

method (i.e., to create employment), and the Navy was reassessing its 

property transfer options, to include public sales, at the time of our 

review. 

DOD’s March 2006 Base Redevelopment and Realignment Manual

encourages the services to make full use of all available property transfer 

tools for both the 2005 BRAC as well as prior BRAC round bases. Each of 

the military services has processes in place to monitor its progress to 

clean up and transfer BRAC properties. For example, along with a system 

to track property transfers, Army environmental personnel meet about 

every 6 months to informally discuss cleanup funding requirements and 

property transfer issues. However, the Office of the Secretary of Defense

does not require the services to periodically report on their progress and 

challenges in transferring unneeded BRAC properties, or lessons learned 

in the application of various tools available to them, which collectively 

might provide more information and maximize the services’ efforts to 

accelerate the cleanup and transfer of remaining as well as new 2005 

BRAC properties. Without such a requirement, oversight of the services’ 

compliance with the new BRAC guidance could be more limited than is 

desirable if one objective is to enhance opportunities for exploiting 

lessons learned from the experience of other BRAC bases. Ultimately, as 

long as unneeded properties remain in DOD possession, communities are 

denied the full economic benefit of property reuse and DOD continues to 

incur ongoing caretaker costs. In order to ensure that the military services

are taking full advantage of all property cleanup and transfer mechanisms, 

we are recommending that DOD require the military services to 

periodically report to the Office of the Secretary of Defense actions both 

planned and taken to make full use of the transfer authorities available to 

them in the interest of expediting the property transfer process and 

sharing lessons learned.

In written comments on a draft of this report, DOD concurred with the 

fundamental aspects of both of our recommendations. DOD partially 

concurred with our first recommendation because it did not agree with 

our suggestion to include full cleanup cost information in the annual

BRAC budget justification documentation, but wanted to find another 

vehicle for reporting the information. Nonetheless, DOD concurred with 

our basic recommendation for DOD to report all costs required to 

complete environmental cleanup at each BRAC installation and to fully 

explain the scope and limitations of these costs to Congress. DOD 

Page 6 GAO-07-166 Military Base Closures
concurred with our second recommendation to require the military 

services to periodically report to the Office of the Secretary of Defense on 

the status and proposed strategy for transferring BRAC properties 

including an assessment of the usefulness of all tools at their disposal. 

DOD has undergone five BRAC rounds with the most recent occurring in 

2005. Under the first four rounds in 1988, 1991, 1993, and 1995, DOD closed 

97 major bases and had 55 major base realignments11 and hundreds of 

minor closures and realignments. DOD has reported that under the prior 

BRAC rounds it had reduced the size of its domestic infrastructure by 

about 20 percent and had generated about $6.6 billion in net annual 

recurring savings for those years following the completion of the 1995 

round in 2001. As a result of the 2005 BRAC decisions, DOD was slated to 

close an additional 25 major bases, complete 32 major realignments, and 

complete 755 minor base closures and realignments. At the time the BRAC 

decisions were finalized in November 2005, the BRAC Commission 

projected that implementation of these decisions would generate over $4 

billion in annual recurring net savings following the completion of 

implementing those decisions in 2011. In accordance with BRAC statutory 

authority, DOD must complete closure and realignment actions by 

September 15, 2011—-6 years following the date the President transmits 

his report on the BRAC recommendations to Congress.12 Environmental 

cleanup and property transfer actions can exceed the 6-year time limit, 

having no deadline for completion. 

Background 

In addition to reducing unneeded infrastructure and generating savings, 

DOD envisioned the 2005 BRAC round to be one that emphasized 

transformation by aligning the infrastructure with the defense strategy and 

fostered jointness by examining and implementing opportunities for 

greater jointness across DOD. As such, there are a considerably higher 

number of realignments to take place than in any of the four prior rounds, 

which has resulted in far more individual BRAC actions, many of which 

affect multiple bases. While the number of major closures and 

realignments are somewhat similar to those of previous rounds (see table 

 11DOD defines a “‘major base closure” as one where plant replacement value exceeds $100

million. DOD defines “plant replacement value” as the cost to replace an existing facility 

with a facility of the same size at the same location, using today’s building standards. DOD 

defines a “major base realignment” as one with a net loss of 400 or more military and 

civilian personnel. 

12Pub. L. No. 101-510, § 2904 (1990). 

Page 7 GAO-07-166 Military Base Closures
1), the number of minor closures and realignments is significantly greater 

than those in all previous rounds combined. Available data indicate that 

despite the larger number of actions associated with the 2005 BRAC round 

compared with previous rounds, the amount of property potentially 

available for transfer is likely to be much less than in prior BRAC rounds.

Although the total amount of acres available for transfer resulting from the 

2005 BRAC round is yet to be fully determined, the preliminary number of 

potentially transferable acres for the 25 major bases is about 102,000 

acres13 compared with a total of about 502,500 acres from the prior BRAC 

rounds combined. The extent of additional transferable acreage arising 

from the hundreds of minor base closures and realignments was not 

available at the time of our review, but is likely to be limited given the 

smaller size of many of those locations. 

Table 1: Comparison of BRAC 2005 Recommendations with Recommendations

from Prior Rounds

Major base 

Round Closures Realignments 

Minor base 

closures and

realignments

1988 16 4 23

1991 26 17 32

1993 28 12 123

1995 27 22 57

Total: prior BRAC rounds 97 55 235

Total: 2005 BRAC round 25 32 755 a

Source: DOD. 

a An individual base may be affected by more than one realignment.

A critical component to the process of transferring unneeded property 

arising from BRAC actions is the need to address the environmental 

contamination that has occurred over time due to military operations 

being conducted when the bases were active installations. Types of 

environmental contaminants found at military installations include 

solvents and corrosives; fuels; paint strippers and thinners; metals, such as 

lead, cadmium, and chromium; and unique military substances, such as 

nerve agents and unexploded ordnance. According to DOD officials, while 

 13This figure includes acreage at three chemical demilitarization bases slated for closure—

Deseret Chemical Depot, Utah; Newport Chemical Depot, Indiana; and Umatilla Chemical 

Depot, Oregon.

Page 8 GAO-07-166 Military Base Closures
environmental cleanup of these contaminants has been an ongoing 

process on active military bases, the cleanups often receive greater 

attention once a base has been selected for closure. Environmental 

cleanup is necessary for the transfer of unneeded contaminated property,

which becomes available as a result of base closures and realignments. 

While addressing the environmental cleanup of contaminated property is a 

requirement for property transfer to other users, the sometimes decadeslong cleanup process is not bound by the 6-year limitation for 

implementing required BRAC actions. As we have reported in the past,14

addressing the cleanup of contaminated properties has been a key factor 

related to delays in transferring unneeded BRAC property to other parties 

for reuse. DOD officials told us that they expect environmental cleanup to 

be less of an impediment during the 2005 round since the Department now 

had a more mature cleanup program in place to address environmental 

contamination on its bases. 

In conducting assessments of potential contamination and to determine 

the degree of cleanup required (on both active and closed bases), DOD 

must comply with cleanup standards and processes under all applicable 

environmental laws, regulations, and executive orders. The 

Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 (CERCLA), as amended,15 authorizes cleanup actions at federal 

facilities where there is a release of hazardous substances or the threat of 

such a release which can present a threat to public health and the 

environment. To clean up potentially contaminated sites on both active 

and closed bases, DOD generally follows the process that is required under 

CERCLA, which generally includes the following phases and activities: 

preliminary assessment, site investigation, remedial investigation and 

feasibility study, remedial design and remedial action, and long-term 

monitoring. (An explanation of these phases is provided in app. II.) 

The Superfund Amendments and Reauthorization Act of 198616 (SARA) 

added provisions to CERCLA specifically governing the cleanup of federal 

facilities, including active military bases and those that are slated for 

closure under BRAC and, among other things, required the Secretary of 

 14GAO, Military Base Closures: Progress in Completing Actions from Prior Realignments 

and Closures, GAO-02-433 (Washington, D.C.: Apr. 5, 2002). See app. V for a list of key

related prior GAO reports. 

1542 U.S.C. § 9601–9630; Pub. L. No. 99-499, (1986). 

16Pub. L. No. 99-499, § 120.

Page 9 GAO-07-166 Military Base Closures
Defense to carry out the Defense Environmental Restoration Program 

(DERP).17 Following SARA’s enactment, DOD established DERP, which 

now consists of two subprograms: (1) the Installation Restoration 

Program, which addresses the cleanup of hazardous substances that are 

primarily controlled under CERCLA and were released into the 

environment prior to October 17, 1986; and (2) the Military Munitions 

Response Program, which addresses the cleanup of munitions including 

UXO and the contaminants and metals related to munitions that were 

released into the environment prior to September 30, 2002. Cleanups of 

hazardous substances released after 1986 and munitions released after 

2002 are not eligible for DERP funds. These cleanups are generally 

referred to as non-DERP or “compliance” cleanups and often include 

activities that are regulated by the Resource Conservation and Recovery

Act. These cleanups involve the closure and cleanup of operations 

associated with landfills, training ranges, and underground storage tanks

and are generally funded under base operations and maintenance accounts 

for active bases. Once the property is determined to be unneeded and 

transferable to other users under BRAC, the cleanups are funded under 

the BRAC account. 

While SARA had originally required the government to warrant that all 

necessary cleanup actions had been taken before transferring property to 

nonfederal ownership, the act was amended in 1996 to expedite transfers 

of contaminated property.18 Now such property, under some 

circumstances, can be transferred to nonfederal users before all remedial 

action has been taken. However, certain conditions must exist before the 

department can exercise this early transfer authority, such as the property

must be suitable for the intended reuse and the governor of the state must 

concur with the transfer. 

In addition to investigations into potential hazards, DOD is required to 

follow National Environmental Policy Act requirements and consult with 

local redevelopment authorities19 during the process of property disposal 

and during the process of relocating functions from one installation to 

 17Pub. L. No. 99-499, § 211.

18The National Defense Authorization Act for Fiscal Year 1997, Pub. L. No. 104-201 § 334. 

19According to the Base Redevelopment and Realignment Manual, dated March 1, 2006, a

local redevelopment authority is any entity (including an entity established by a state or

local government) recognized by the Secretary of Defense as the entity responsible for 

developing the redevelopment plan with respect to the installation or for directing the 

implementation of such a plan. 

Page 10 GAO-07-166 Military Base Closures
another. Although the decision to close or realign installations is not 

subject to the National Environmental Policy Act, DOD is required to 

follow the act’s requirements during the process of property disposal and 

during the process of relocating functions from one installation to another. 

The National Environmental Policy Act requires federal agencies, 

including DOD, to consult with and obtain the comments of other federal 

agencies that have jurisdiction by law or special expertise with respect to

any environmental impact involved with the action. 

DOD’s March 2006 Base Redevelopment and Realignment Manual

requires the military services to prepare an Environmental Condition of 

Property Report for closing BRAC bases. The report is used to evaluate the 

environmental condition of all transferable property based on already 

available information on contamination. It can be used to identify “gaps” in 

information regarding environmental conditions and where more study is 

required. Environmental Condition of Property reports have replaced the 

former baseline surveys that were required when SARA was enacted in

1986. According to Army officials, the Army plans to have a total of 183 

Environmental Condition of Property reports completed for all of its 2005 

major and minor base closures by January 31, 2007. With respect to Army 

National Guard properties, the states will be responsible for their 

Environmental Condition of Property reports except for the five bases 

located on federal lands20 for which the Army will prepare the reports, if 

required. According to Navy officials, the Navy has completed all reports 

for lands affected by 2005 closures. Air Force officials reported that they

will have the reports completed for all their bases, which require one, by

April 2007. 

DOD has had a long-standing policy of not considering environmental 

cleanup costs in its BRAC decision making. Accordingly, the estimates 

using the Cost of Base Realignment Actions21 model, which is used to 

compare alternative actions during BRAC decision making, do not include 

the cost of environmental cleanup for BRAC-affected bases. Historically, 

we have agreed with DOD’s position that such costs are a liability to DOD 

regardless of its base closure recommendations. While such costs are not 

 20The five Army National Guard properties located on federal lands are Fort Chaffee 

Maneuver Training Center, Arkansas; National Guard Bell, California; Jackson Armory, 

Oregon; Oxford, Ohio; and the Army Aviation Support Facility, Wyoming.

21The Cost of Base Realignment Actions (COBRA) model is an analytical tool used to 

calculate the costs, savings, and return on investment of proposed realignment and closure 

actions. 

Page 11 GAO-07-166 Military Base Closures
included in the Cost of Base Realignment Actions model, they are included 

in developing BRAC implementation budgets and recorded as a BRAC 

cost. 

Expected environmental cleanup costs for the 2005 BRAC round are not 

yet fully known, but they are likely to increase from current estimates. 

DOD’s available data22 indicate that at least $950 million will be needed to

complete the cleanups now underway for known hazards on the major and 

minor bases scheduled for closure for the 2005 BRAC round. However, our 

prior work has indicated that as closures are implemented, more intensive 

environmental investigations occur and additional hazardous 

contamination may be uncovered resulting in higher cleanup costs. Also, 

the services’ estimates were based on cleanup standards that are 

applicable for the current use of the property, but reuse plans developed 

by communities sometimes lead to more stringent and thus more 

expensive cleanups.23 In addition, DOD is in the early phases of identifying 

and analyzing munitions hazards that may require additional cleanup at

both active and BRAC bases. Furthermore, the manner in which DOD is 

required to report all these costs to Congress is fragmented. Of the four 

reports DOD annually provides to Congress on environmental cleanup 

costs and estimates for its bases, none gives the entire cost picture by 

service or base. 

Although DOD data indicate that at least $950 million will be needed for 

cleanup of the major and minor base closures resulting from the 2005 

BRAC round, this figure reflects preliminary amounts that are likely to 

increase as more information is collected during BRAC implementation on 

the extent of cleanup required to safely reuse property in communities 

where future land use decisions have yet to be made. DOD’s best available 

data suggest that at least $590 million will be needed to complete the 

cleanup of the 25 major base closures and about $360 million will be 

needed for the minor closures. These amounts were developed from 

information contained in the Defense Environmental Programs Fiscal 

Year 2005 Annual Report to Congress, and they do not include all costs, 

Expected 

Environmental 

Cleanup Costs for the 

2005 BRAC Round 

Are Not Yet Fully 

Known 

Cleanup Cost Estimates 

for BRAC 2005 Round 

Bases Are Not Fully 

Known and Likely to 

Increase 

 22Defense Environmental Programs Fiscal Year 2005 Annual Report to Congress. 

23In commenting on a draft of this report, DOD officials emphasized that the Base 

Redevelopment and Realignment Manual states that DOD prefers that military department

cleanup decisions be based on the current use of the property.

Page 12 GAO-07-166 Military Base Closures
such as program management costs and non-DERP costs.24 In addition, the 

2005 BRAC round includes the closure of more than 100 reserve centers, 

the extent to which cleanups will be required and at what cost is largely 

unknown.25 Only 2 of these centers reported cleanup estimates in the 

Defense Environmental Programs Fiscal Year 2005 Annual Report to 

Congress. Our experience with prior BRAC round bases has shown that 

estimates tend to increase significantly once more detailed studies and 

investigations are completed. 

The following table provides DOD’s estimated cost to complete the 

environmental cleanup beyond fiscal year 2006 for the 25 major DOD base 

closures resulting from the 2005 BRAC round as reported in the Defense 

Environmental Programs Fiscal Year 2005 Annual Report to Congress. 

For certain bases, conflicting cost estimates appear between this report 

and those reported in the 2005 Defense Base Closure and Realignment 

Commission Report to the President.

26 According to DOD officials, the 

data provided to the BRAC Commission is now outdated and estimates 

contained in the Defense Environmental Programs Fiscal Year 2005 

Annual Report to Congress provide more current data. 

 24Non-DERP cleanups refer to those cleanups that are not eligible for Defense 

Environmental Program funds, i.e., cleanups of hazardous waste released after 1986 and

cleanups of munitions released after 2002. DOD uses the term compliance to refer to these

cleanups. 

25In commenting on a draft of this report, DOD officials stated that the majority of these 

facilities are small acreage, single buildings with limited operations. 

26See Appendix P of the 2005 Defense Base Closure and Realignment Commission Report 

to the President. 

Page 13 GAO-07-166 Military Base Closures
Table 2: BRAC 2005 Major Closures’ Estimated Environmental Cleanup Costs from 

Fiscal Year 2006 to Completion (in millions) 

Service Installation Estimated cost

Fort Monroe, Virginia $201

Deseret Chemical Depot, Utah 178

Kansas Army Ammunition Plant, Kansas 23

Selfridge Army Activity, Michigan 13

Fort Gillem, Georgia 10

Umatilla Chemical Depot, Oregona 9

Mississippi Army Ammunition Plant, Mississippi 8 

Fort McPherson, Georgia 7

Riverbank Army Ammunition Plant, California 5

Newport Chemical Depot, Indiana 5

Fort Monmouth, New Jersey 5

Army (12) 

Lone Star Army Ammunition Plant, Texas 1 

Naval Weapons Station Seal Beach, Concord 

Detachment, California 85

Naval Air Station Brunswick, Maine 16

Naval Air Station Willow Grove, Pennsylvania 6

Broadway Complex, Californiab Not availablec

Naval Air Station Atlanta, Georgia Not availablec

Naval Station Pascagoula, Mississippi Not availablec

Navy (7) 

Naval Station Ingleside, Texas Not availablec

Galena Forward Operating Location, Alaska 12

Brooks City Base, Texas 3

Cannon Air Force Base, New Mexicod 2

General Mitchell Air Reserve Station, Wisconsin 1

Onizuka Air Force Station, California 0

Air Force (6)

Kulis Guard Station, Alaska Not availablec

Total $590

Source: GAO analysis of DOD Defense Environmental Restoration Program (DERP) data.

a The Army is funding a portion of the Umatilla Chemical Depot cleanup with prior BRAC round 

dollars. 

b

The BRAC Commission recommended that the Broadway Complex close if the Navy could not enter 

into a long-term lease to redevelop the property by January 1, 2007. During the course of our review, 

the Navy announced they had entered into such a lease on November 22, 2006. 

c

Cleanup estimates were unavailable for these installations in the Defense Environmental Programs 

Fiscal Year 2005 Annual Report to Congress because they received no DERP funds. 

d

The Cannon Air Force Base closure recommendation becomes effective if the Secretary of the Air 

Force does not designate a new mission for the installation by December 31, 2009.

Page 14 GAO-07-166 Military Base Closures
Table 2 shows that DOD estimates it will spend at least $590 million to 

clean up the 25 major bases recommended for closure in 2005. However, 

we believe that this figure is low for several reasons. First, the amounts in 

table 2 only include the cost estimate for DERP eligible cleanups—those 

cleanups associated with contamination occurring prior to 1986 for 

hazardous waste and prior to 2002 for munitions. The cost for non-DERP 

cleanups and program management costs are not included. These 

additional costs could add millions to the overall cost estimate. Second, no 

cleanup cost estimates were available in the Defense Environmental 

Programs Fiscal Year 2005 Annual Report to Congress for 5 of the 25

major base closures either because the cleanups were not eligible for 

DERP funding, or because the bases had not been thoroughly assessed for 

environmental damage. As the bases undergo more complete and in-depth

environmental assessments, a clearer picture of environmental cleanup 

costs will likely emerge. Finally, these cost estimates will likely increase 

due to more in-depth investigations that are expected to address all 

environmental cleanup issues now that the bases have been scheduled for 

a BRAC closure. For example, during our visit to the Mississippi Army 

Ammunition Plant in June 2006, we noted that Army and contract officials

were preparing an environmental condition of property assessment to pull 

together all known environmental issues. Army officials told us that the 

ammunition plant had been closed and placed in standby status since 1990 

and that no aggressive environmental cleanup had taken place. When the 

plant was recommended for closure in 2005, the Army estimated that $8.4

million would be required to address environmental contamination caused 

by 2 inactive range munitions sites. Since that time, according to Army 

plant officials, as many as 46 more sites have been identified as having 

environmental concerns which will require further investigation and 

possible cleanup. Therefore, the total eventual cleanup costs are likely to 

be much higher than the current estimate of $8.4 million. 

DOD officials told us that the projected environmental cleanup cost 

estimates are relatively lower for the 2005 BRAC bases than for those of 

the prior rounds because the environmental conditions on the property of 

today’s bases are much better than those closed in previous rounds. These 

officials told us that this is primarily due to ongoing actions associated 

with DOD’s Installation Restoration Program (cleanup program) and the 

Military Munitions Response Program at active and BRAC bases. The 

restoration program addresses hazardous substances, pollutants, and 

other contaminants, and the munitions program addresses UXO and 

discarded munitions. The officials stated that contaminated sites identified 

under the installation restoration program are much farther along in the 

cleanup process than sites identified under the munitions program, 

Page 15 GAO-07-166 Military Base Closures
primarily because the restoration program has been in existence since 

1985 while the munitions program was only initiated in 2001. Our analysis 

of DOD-provided cleanup-phase27 data for the identified contaminated 

sites at 20 of the 25 major BRAC 2005 closures supports this assertion. For 

example, DOD’s data show that, as of September 30, 2005, 89 percent of 

the 571 installation restoration sites (508 sites) either had their cleanup 

remedy in place or had the remedy complete, and 91 percent (521 sites) 

had completed investigation studies. Comparatively, of the 50 identified 

munitions sites at the 20 bases, only 8 percent (4 sites) reported cleanup 

action complete and only 10 percent (5 sites) had completed investigation 

studies. However, federal cleanup officials as well as military 

environmental specialists told us that many of these sites may require 

further investigation and cleanup—and greater cleanup costs—if, as 

expected, the future control and use of the property shifts from the 

military to the private sector. Furthermore, DOD officials stated that many 

munitions sites were not required to be cleaned when they were 

operational ranges on active bases, but will require cleanup now that the 

bases have been closed. The Army estimates that the cost to address 

active ranges on their 2005 BRAC properties ranges from $37 million to 

$335 million and is not included in the $950 million estimate for cleanup of

2005 major and minor bases. 

DOD’s Environmental 

Cleanup Reports Do Not 

Provide a Complete 

Picture of Environmental 

Cleanup Cost Information 

Congress does not have complete visibility over the expected total cost of 

DOD’s cleanup efforts for the 2005 BRAC round or for the prior BRAC 

rounds because of a variety of reports that individually are incomplete and 

which collectively may present a confusing picture of costs. Although 

DOD prepares multiple reports for Congress on various environmental 

cleanup costs, none of them presents an overall total cost estimate per 

base, nor is DOD required to present this information. DOD does not fully 

explain the scope and limitations of the cost information presented. 

Transparency and complete accountability in financial reporting and 

budgetary backup documents are essential elements for providing 

Congress with a more complete picture of the total cleanup costs so it can 

make appropriate budgetary trade-off decisions to ensure the expeditious

cleanup and transfer of properties and ultimately realize savings for the 

U.S. government. In order to provide a complete picture of the total 

cleanup costs at BRAC bases, specific information must be extracted from 

various reports, which we have done in order to present the total costs to 

clean up properties resulting from prior BRAC round decisions. 

 27See app. II for a description of DOD’s environmental cleanup phases. 

Page 16 GAO-07-166 Military Base Closures
Congress annually receives the following four required reports28 from DOD 

that contain environmental cleanup costs and estimates for BRAC bases, 

two of which also include costs for active bases. 

• Annual BRAC Budget Appropriations Request29

• Annual Government’s Consolidated Financial Statement Report 

• Annual Defense Environmental Programs Report 

• Annual Section “2907” Report30

A detailed description of the environmental cleanup costs and estimates 

included in these reports is presented in appendix III. 

Our review showed that none of these reports provides information in one 

place on the total (spent plus estimated future environmental cleanup 

costs) expected for all environmental cost categories (DERP, non-DERP, 

and program management costs) by base. DOD officials told us that 

Congress will often mistakenly assume that the cost data presented in the 

Annual Defense Environmental Programs reports to Congress are the total

expected cost of the program. While these costs are typically the majority 

of the overall total costs, the report excludes the cost of cleanups by base 

that do not qualify for DERP funding. Although these non-DERP costs are 

presented elsewhere in the report, they are only presented in aggregate 

terms by service. From information contained in two of the reports, we 

determined that the expected environmental costs for the first four BRAC 

rounds will total $13.2 billion, as shown in table 3. 

 28The report names listed are the names commonly used. The official titles of these reports

are, DOD Base Realignment and Closure Executive Summary and Budget Justification, 

Department of Defense Performance and Accountability Report, Defense Environmental

Programs Annual Report to Congress, and Department of Defense Report on 2005 

Defense Base Closure and Realignment Implementation, respectively. 

29For the purposes of this report, we considered this information to be a report since it 

provides support information for the annual budget submission to Congress.

30This reporting requirement refers to Section 2907 of Public Law 101-510. 

Page 17 GAO-07-166 Military Base Closures
Table 3: Total Expected Environmental Costs for Prior BRAC Rounds 

Dollars in billions 

Cost category

Funds made

available through 

fiscal year 2005 

Estimated cost from 

fiscal year 2006 

through completion Total

DERP eligiblea cleanups 

(Installation Restoration 

Program and Military 

Munitions Response 

Program) 

$ 9.0 $ 3.8 $ 12.8 

Non-DERP cleanups 

(Compliance) 

Included in cleanup 

amount 

 0.4 0.4 

Program management and 

planning 

Included in cleanup 

amount 

Included in compliance 

amount 

Included in 

compliance 

amount 

Total $9.0 $ 4.2 $ 13.2 

Source: GAO analysis of DOD’s budget documentation for fiscal year 2005 and The Defense Environmental Programs Fiscal Year

2005 Annual Report to Congress.

a

BRAC cleanups are funded from BRAC accounts within DOD’s Military Construction appropriations. 

Cleanups of active bases are funded from DERP accounts for DERP eligible cleanups and Operation

and Maintenance accounts for non-DERP cleanups. DOD continues to track DERP eligible cleanups 

by base even after closure (when the funding source has shifted to the BRAC accounts). 

The $9.0 billion of funding made available for the four prior BRAC rounds 

for all cost categories was obtained from DOD’s BRAC Budget 

Appropriations Request for fiscal year 2005. The budget request did not 

provide data on the total cost to complete the environmental cleanup at 

the bases. The $3.8 billion cost from fiscal year 2006 through completion 

for the DERP eligible cleanups (Installation Restoration Program and 

Military Munitions Response Program) came from one section (Appendix 

E, Restoration Budget Summary) in the Defense Environmental Programs 

Fiscal Year 2005 Annual Report to Congress. On the basis of information 

in this report, the time required to complete the cleanup for some bases 

will take decades. For example, the estimated date to complete cleanup at 

the former Mather Air Force Base, California, is reported as 2074, and the

estimated date to complete cleanup at the former Toole Army Depot, Utah,

is reported as 2032. The $0.4 billion estimated cost from fiscal year 2006 

through completion for compliance (non-DERP) and program 

management and planning was extracted from another section of the 

Defense Environmental Programs Fiscal Year 2005 Annual Report to 

Congress (specifically, Appendix J, Installation Restoration Program and 

Military Munitions Response Program Status Tables) for each of the 

services. 

Page 18 GAO-07-166 Military Base Closures
None of the environmental reports DOD submits to Congress provide 

information in one place on the total costs and future cost estimates for 

each of the environmental cost categories by service and by base. Further,

the environmental cleanup costs and estimates DOD reports to Congress 

vary in their scope and limitations, but DOD does not fully explain their 

differences. As a result, the cost of cleaning up BRAC property lacks 

transparency and Congress does not have total visibility over this 

multibillion dollar BRAC environmental cleanup effort. 

DOD continues to make progress in transferring unneeded BRAC property 

since our last report on this subject.31 However, environmental cleanup of 

contamination continues to be a key impediment to transferring the 

remaining properties. Environmental cleanup issues are unique to each 

site but usually result from a variety of interrelated factors such as 

technological constraints, lengthy negotiations on regulatory compliance, 

and the discovery of previously unknown and therefore unaddressed 

environmental hazards. 

Since our last report on this subject in January 2005, DOD has made some 

progress in transferring remaining unneeded property, having transferred 

78 percent, (about 390,300 acres) of the 502,500 total unneeded acres32

from prior BRAC rounds to federal and nonfederal entities—up from 72 

percent (about 364,000 acres of the estimated 504,000 acres DOD reported 

at the end of fiscal year 2004) from 2 years ago. This represents an 

increase of about 26,300 acres from what we reported in January 2005. A

breakdown of the current status of unneeded BRAC property shows that 

DOD Continues to 

Make Progress in 

Transferring 

Unneeded Properties, 

but Environmental 

Cleanup Continues to 

be a Key Impediment 

to Transfer of 

Remaining Properties 

DOD Continues to Make 

Progress in Transferring 

Unneeded Properties 

 31In January 2005, we reported approximately 72 percent of 504,000 unneeded acres was

transferred by DOD to other users. That acreage differs from the approximate 502,500 

acres currently reported because as property is transferred, more accurate surveys are 

completed and acres figures change. Further, some acreage initially declared excess has 

been retained by DOD, thus decreasing the acreage available for transfer. 

32The unneeded acreage does not include over 23,000 acres at the Pueblo Chemical Depot, 

Colorado, which, although designated as unneeded, will not be available for further 

disposition until the chemical demilitarization mission at these bases is completed. 

Page 19 GAO-07-166 Military Base Closures
63 percent had been transferred to nonfederal entities, 15 percent had

been transferred to other federal agencies, 15 percent had been leased but 

not transferred, and 7 percent was untransferred and is awaiting future 

disposition (see fig. 1). 

Figure 1: Disposition of Unneeded BRAC Acreage from Prior Rounds, as of 

September 30, 2006 

63% 15%

15%

Transferred to 

nonfederal entities

316,800

Untransferred (but leased)

76,600

Transferred to 

federal entities

73,500

Source: GAO analysis of DOD data.

7%

Untransferred

35,700

Total acreage=502,500

Note: Figures do not add due to rounding. 

Nearly 22 percent (112,300 acres) 33 of the total acreage from prior BRAC 

rounds—7 percent (35,700 acres) of untransferred property plus 15 

percent (76,600 acres) of untransferred but leased property—has not been 

transferred. In other words, over 68 percent (76,600 acres) of the 

approximate 112,300 acres of untransferred property is being leased, 

leaving only 32 percent (35,700 acres) that is not in reuse. Leased property, 

while not transferred to the user, can afford the user and DOD some 

benefits. Communities, for example, can choose leasing while awaiting 

final environmental cleanup as an interim measure to promote property 

 33Of this amount, approximately 16,600 acres belong to the Air Force, 11,600 acres belong

to the Navy, and about 84,000 acres are owned by the Army. Included in the Army acreage

is about 50,000 untransferred acres at Jefferson Proving Grounds, Indiana, which is 

currently being retained by the Army and permitted to the U.S. Fish and Wildlife Service. 

Page 20 GAO-07-166 Military Base Closures
reuse and job creation. DOD also benefits, in some cases, as the 

communities assume responsibility for costs of protecting and maintaining 

these leased properties. By adding leased acres to the number of 

transferred acres, the amount of unneeded BRAC property in reuse rises 

to 93 percent. However, while leasing can provide short-term reuse 

benefits in terms of economic development opportunities, it may delay 

DOD’s larger goal to expedite property transfers. 

Cleanup of Environmental 

Contamination Continues 

to Cause Property Transfer 

Delays Due to a Variety of 

Interrelated Factors 

As we have reported in the past, environmental cleanup issues have and 

continue to delay the services from rapidly transferring unneeded BRAC 

property. As of September 30, 2006, about 81 percent of the approximate 

112,300 acres remaining to be transferred from the prior BRAC rounds 

(about 91,200 acres), which is located on 44 installations, have 

environmental contamination issues. Environmental cleanup issues are 

unique to each site but usually result from interrelated issues such as 

technological constraints, cleanup negotiations, and previously unknown 

environmental hazards, as described in the following examples. 

• Sometimes the available technology needed to detect and clean up 

UXO is limited and not fully effective. For example, at the former Naval 

Air Facility in Adak, Alaska, over 5,500 acres of UXO-contaminated 

property have not been transferred because the technology for 

economically cleaning up the UXO on this remote Aleutian island does 

not currently exist. At the former Fort Ord Army Base in Marina, 

California, about 11,800 acres contaminated with UXO still require 

cleanup, and this effort is currently expected to take until 2021 due to 

the labor-intensive nature of current cleanup technology (see fig. 2). 

We were told by DOD officials that the detection of UXO is not only 

labor intensive but difficult because the technology often used for this 

purpose cannot easily distinguish between UXO and waste scrap 

metals. 

Page 21 GAO-07-166 Military Base Closures
Figure 2: Workers Searching for UXO at the Former Fort Ord Using Hand-Held

Detection Devices 

• Prolonged negotiations between environmental regulators and DOD 

about compliance with environmental regulations and laws can delay 

property transfers. For example, at the former Fort Wingate, New 

Mexico, which was closed by the 1988 BRAC Commission and has 

about 8,800 acres of transferable property with environmental 

impediments, it took years of active negotiation between the Army and 

regulators to reach agreement for closure requirements permitted 

under the Resource Conservation and Recovery Act.34 At the former 

Fort Ord, California, open burning of the coastal chaparral is necessary 

before discovery and removal of UXO and other munitions can begin.

However, according to Army officials, the number of acres that can be

burned annually must be negotiated with the state and is controlled by 

California’s clean air standards. 

 34The Resource Conservation and Recovery Act governs the generation, transportation, and 

management of hazardous wastes in order to protect human health and the environment. 

Page 22 GAO-07-166 Military Base Closures
• Additional environmental contamination can be detected after a base is 

recommended for closure. For example, the former McClellan Air 

Force Base in Sacramento, California, was recommended for closure in 

1995 and traces of plutonium were found during a routine cleanup in 

September 2000, causing a cost increase of $21 million, and extending 

the completion schedule beyond 2030. 

Table 4 shows the most expensive “cost to complete” environmental 

cleanups on prior BRAC round bases. The estimated costs to complete 

cleanups at these 10 BRAC installations ($2.1 billion) account for more 

than half (55 percent) of DOD’s $3.8 billion future BRAC environmental 

restoration and munitions cleanup estimates for all unneeded properties 

on bases from the previous BRAC rounds. 

Table 4: Top 10 Most Expensive Cost to Complete Cleanups at Prior Round BRAC 

Installations for Fiscal Year 2006 and Beyond (dollars in millions) 

Service Former military base Estimated future cleanup costs 

Air Force McClellan Air Force Base, California $695.9

Army Fort Ord, California 342.3

Navy Alameda Naval Air Station, California 182.9

Army Fort Wingate, New Mexico 182.2

Army Fort McClellan, Alabama 152.7

Air Force Kelly Air Force Base, Texas 131.1

Navy Hunters Point Annex, California 127.7

Army Savanna Army Depot Activity, Illinois 99.4

Army Pueblo Chemical Depot, Colorado 88.0

Navy Moffett Naval Air Station, California 78.6

Total $2,080.8

Source: DOD data. 

Note: These figures were extracted from the Defense Environmental Programs Fiscal Year 2005 

Annual Report to Congress and only include DERP-eligible cleanups, which generally represent the

majority, but not all, cleanup costs. As previously noted, these estimates are not necessarily 

complete. 

Page 23 GAO-07-166 Military Base Closures
Although opportunities exist to expedite the cleanup and transfer of 

unneeded BRAC 2005 properties, as well as untransferred properties from 

prior BRAC rounds, it is not clear to what extent each of these 

opportunities are considered for BRAC properties nor what successes or 

challenges were seen in their application since the services are not 

required to report their strategies for addressing unclean and 

untransferred properties to the Office of the Secretary of Defense (OSD). 

Over the years, Congress has provided DOD with a wide range of property 

transfer authorities to expedite the cleanup and transfer of unneeded 

BRAC property, including public sales and the so-called “Early Transfer 

Authority,”35 which allows property to be transferred before all necessary 

cleanup actions have been completed. In prior BRAC rounds, there was 

more extensive use made of some tools than others, and as we previously 

reported, DOD could have given greater attention to early transfer 

authority. Each of the military services has processes in place to monitor 

their progress to clean and transfer BRAC properties. Also, DOD’s March 

2006 Base Redevelopment and Realignment Manual, which provides 

cleanup and disposal guidance for BRAC 2005 properties as well as 

untransferred properties from prior BRAC rounds, encourages the services 

to make wide use of all available property transfer tools. However, the

services are not required to report to OSD on the status of monitoring their 

progress, their strategies for transferring BRAC properties, lessons 

learned, or whether they are taking advantage of all available property 

cleanup and transfer tools. 

Congress has, over time, provided DOD with a wide range of property 

transfer mechanisms and tools to expedite the cleanup and transfer of 

unneeded BRAC property, including public sales, early transfer authority,

and privatization.36 The closure and realignment of individual installations 

creates opportunities for those unneeded properties to be made available 

to others for reuse. When an installation becomes a BRAC action, the 

unneeded property is reported as excess. Federal property disposal laws 

require DOD to first screen excess property for possible reuse by defense 

and other federal agencies. If no federal agency needs the property, it is 

declared surplus and is made available to nonfederal parties, including 

Opportunities Exist to 

Expedite Cleanup and 

Transfer of Unneeded 

BRAC Properties 

Many Property Disposal 

Alternatives Exist 

 35Pub. L. No. 104-201, § 334. 

36 “Privatization” is when property is transferred in connection with a payment to the new 

owner for the cost to complete the environmental cleanup. 

Page 24 GAO-07-166 Military Base Closures
state and local agencies, local redevelopment authorities, and the public,

using various transfer tools as shown in table 5.

Table 5: Property Transfer Alternatives under the BRAC Process 

Property transfer alternatives Purpose of property transfer alternatives

Public benefit conveyance Authorizes real and personal property transfers to state and local governments and 

certain nonprofit organizations for public purposes. Examples include schools, parks, 

airports, ports, public health facilities, historic monuments, and wildlife conservation. 

Conservation conveyance Authorizes a military department to convey surplus property that is suitable for 

conservation purposes to a state or local government, or to a nonprofit organization that 

exists primarily for the purpose of natural resource conservation. 

Economic development conveyance Authorizes a military department to convey real and personal BRAC property to a local 

redevelopment authority for the purposes of job generation on the installation. 

Negotiated sale Disposes of property by negotiated sale only under limited circumstances. Negotiated 

sales to public bodies can only be conducted if a public benefit, which would not be 

realized from competitive sale or authorized public benefit conveyance, will result from 

the negotiated sale. The grantee must pay no less than fair market value based upon 

highest and best use and an appraisal. 

Public sale Allows the military department, in consultation with the local redevelopment authority, to 

determine when public sale is the best method to dispose of a parcel. Public sale 

approaches include sealed bids, Internet auctions, and auction on the site to the highest 

bidder. 

Reversion Property for military installations was sometimes obtained from state and local 

governments at a reduced price or at no cost. In these cases, the deed or other 

instrument conveying the property to the military may contain reversionary rights or 

reverter clauses that provide for return of the property to its former owner once the 

military need has ended. 

Special legislation Congressional action through special legislation determining the terms and conditions for 

transferring BRAC properties.

Disposal to depository institutions Conveys the property and improvements to a bank or credit union that conducted 

business on a closed installation and constructed or substantially renovated the facility 

with its funds. The military department must offer the land on which the facility is located

to the financial institution before offering it to another entity; however, the depository 

institution must agree to pay fair market value. 

Exchange for military construction Provides an alternative authority for disposal of real property at a closing or realigning 

installation. This authority allows any real property at such an installation to be 

exchanged for military construction at that or another location. 

Source: DOD. 

Use of the Wide Range of 

Tools Has Been Limited in 

the Past, but Has Greater 

Emphasis Now 

Although prior DOD guidance to the military services promoted creativity 

within applicable laws and regulations to successfully close and reuse 

installations, DOD used some property transfer tools to a much greater 

extent than others. In some cases, DOD’s deference to community plans 

for economic development led it to use low or no-cost transfer tools more

often than property sales. As BRAC has evolved, there have been differing 

Page 25 GAO-07-166 Military Base Closures
emphases placed on the approaches used to transfer unneeded property.

For example, following the 1988 round, DOD emphasized revenue 

generation through the sale of unneeded properties. Following the BRAC 

rounds in the 1990s, however, DOD underscored economic development 

through direct, no-cost transfers of property to the public sector. The 

emphasis during the 2005 BRAC round appears to be headed towards a 

renewed importance on achieving fair market value through various 

transfer authorities and the consideration of all transfer tools available to 

quickly transfer unneeded property to others for reuse. 

The services have taken some steps to expand their use of the wide array

of transfer tools in recent years, most notably the Navy, which realized 

over $850 million in revenues from the sale of unneeded BRAC properties 

at two former Marine Corps air stations in California. Figure 3 illustrates 

the alternatives used to transfer unneeded BRAC property from the prior 

BRAC rounds to nonfederal entities as of September 30, 2006.

Page 26 GAO-07-166 Military Base Closures
Figure 3: Alternatives Used to Transfer Unneeded BRAC Acreage to Nonfederal 

Entities in Prior BRAC Rounds, as of September 30, 2006 

19% 19%

29%

17%

Economic 

development 

conveyance 

92,200

Public benefit 

conveyance 

52,300

Conservation 

conveyance 

60,900

Source: GAO analysis of DOD data.

12%

2% Public sale 

5,000

3% Negotiated sale 

8,300

Other 61,000

Reversion 37,200

205,400

(65%)

13,300

(5%)

Total acreage=316,800

Notes: Acreage is rounded to the nearest 100 acres and individual entries do not total due to 

rounding. The “other” category refers to various other transfers mechanisms, including special 

legislation, transfer for use by depository institutions, and exchanges for military construction. See 

table 5 for details on property transfer alternatives.

As shown in figure 3, low- and no-cost property conveyance mechanisms 

accounted for 65 percent (205,400) of all acres transferred—public benefit, 

conservation, and economic development conveyances were used in 17

percent, 19 percent, and 29 percent, respectively–whereas public and 

negotiated sales accounted for 5 percent (13,300) of all acres transferred. 

According to DOD officials, this trend reflected deference to local 

community organizations and their preference for low- and no-cost 

conveyances. Moreover, it also reflected the difficulty in using public and

negotiated sales at that time, because more time was often needed to 

determine the nature and extent of environmental contamination and its 

potential cleanup cost, to attract private property developers. However, as 

more information is developed at these sites and as local economic 

conditions change, a different approach to transferring property may now 

be successful, an approach which would not have worked in the past. For 

example, while an agreement was reached in 2000 on a no-cost economic 

Page 27 GAO-07-166 Military Base Closures
development conveyance at the former Alameda Naval Air Station, 

California, the local redevelopment authority could not follow through on 

the terms of this conveyance to create jobs because of a decline in the 

local economy. Therefore, both the local redevelopment authority and the

Navy were reassessing other property transfer options, including public 

sales, at the time of our review. 

Use of Early Transfer 

Authority May Facilitate 

Property Transfers 

Another tool for facilitating property transfers is the so-called “early 

transfer authority,” which is not actually a property transfer mechanism 

but rather an amendment to SARA, allowing the services to transfer 

property that has not been entirely cleaned under an authorized transfer 

conveyance. Recognizing that environmental cleanup has often delayed 

the transfer of BRAC property, Congress enacted the early transfer 

authority provision37 in 1996 which allows, under certain conditions, 

property to be transferred before all necessary cleanup actions have been 

completed. The transfer agreement identifies who will complete the 

cleanup and what funding the service will provide, if any. In addition, the 

entity assuming cleanup responsibilities will often purchase environmental 

insurance to insure itself against possible cost overruns. We previously 

reported that this tool should receive greater DOD attention38 and DOD has 

increased its use of this authority, transferring a total of about 23,700 acres 

using this method as of July 2006. 

There are typically two scenarios with which an early transfer is 

requested. In the first scenario, the deed to the property is provided to the 

new owner, such as a local redevelopment authority, and DOD continues 

the cleanup. For the other scenario, the user takes the deed to the 

property and as the new owner agrees to complete cleanup activities or to

control the implementation of an ongoing cleanup at the time of transfer. 

Although this tool is officially called the “Transfer Authority in Connection 

with Payment of Environmental Remediation Costs,” it is commonly 

referred to as “privatization.” DOD’s March 2006 Base Redevelopment and 

Realignment Manual39 states that if the fair market value of the property is

more than the cleanup cost, the purchaser must pay the military 

departments the difference. However, if fair market value is less than the 

 37Pub. L. No. 104-201, § 334.

38GAO, Military Base Closures: Progress in Completing Actions from Prior Realignments 

and Closures, GAO-02-433 (Washington, D.C.: Apr. 5, 2002).

39DOD, Base Redevelopment and Realignment Manual, 4165.66-M, March 1, 2006. 

Page 28 GAO-07-166 Military Base Closures
cleanup costs, the military department may pay the purchaser the 

difference. Because the purchaser will be responsible for completing the 

cleanup, the services must confirm that the purchaser has the technical 

expertise and financial capability to do so before considering this 

approach. In terms of cost, DOD retains responsibility for funding the 

environmental cleanup, regardless of whether it is performed by DOD or 

the user. 

A primary advantage of using the early transfer authority is that it makes 

property available to the future user as soon as possible, thus allowing 

environmental cleanup and redevelopment activities to proceed 

concurrently. This can save time and costs and provide users with greater 

control over both activities. Furthermore, it provides communities with 

the means to quickly put property into productive use, create jobs, and 

possibly create tax revenue. DOD reported that some reasons why the 

services were not taking full advantage of this authority were due to a lack

of information on early transfer authority by communities, how to use it, 

and how the process ensures the protection of public health, safety, and 

the environment. In addition, DOD cites a lack of support from state and 

local regulators as a reason for the previously limited use of this authority. 

However, a local redevelopment authority can purchase environmental 

insurance to transfer the risk of potential cost overruns from the property 

owner to the contractor and the insurance provider. By shifting the risk, 

contractors may be strongly motivated to complete the environmental 

cleanups in a timely and cost-efficient manner. According to one local 

redevelopment authority official, privatization of environmental cleanup 

(one scenario for achieving an early transfer) is now seen as a way to 

expedite the cleanup and transfer process significantly because DOD’s 

approach can be too methodical, while the private sector can remediate 

the hazards more economically and in less time. 

As of July 2006, the number of completed early property transfers had 

increased from 12 (about 8,200 acres) as of September 30, 2001, to 23

(about 23,700 acres). According to DOD officials, 8 early transfer authority 

actions are currently pending (in the process of being transferred), and 5 

are currently being considered for the future. Table 6 provides a list of 

locations where early transfer authority has been completed, i.e., where a 

deeded transfer has been completed, as of July 2006. 

Page 29 GAO-07-166 Military Base Closures
Table 6: Use of Early Transfer Authority at Prior BRAC Round Bases, as of July 

2006 

Installation Acres

Fort McClellan, Alabama 4,692

Naval Shipyard, Mare Island, California 3,486

Fort Devens, Massachusetts 2,358

Alabama Ammunition Plant, Alabama 2,235

Naval Air Station Memphis, Tennessee 1,863

Naval Air Station Agana, Guam 1,798

Tooele Army Depot, Utah 1,621

Naval Activities, Guam 1,482

Fort Ord, California 1,401

Fleet Industrial Supply Center, Oakland, California 676

Naval Shipyard, Charleston, South Carolina 436

Oakland Army Base, California 364

Grissom Air Force Base, Indiana 201

Bayonne Military Ocean Terminal, New Jersey 192

Griffiss Air Force Base, New York 179

Mather Air Force Base, California 165

Wurtsmith Air Force Base, Michigan 149

Naval Ordnance Station, Louisville, Kentucky 142

Fitzsimons Army Medical Center, Colorado 133

Naval Training Center, San Diego, California 51

Public Works Center, Guam 25

Lowry Air Force Base, Colorado 12

Naval Training Center, Orlando, Florida 9

Total acres 23,670

Source: DOD. 

Services Monitor Progress, 

but DOD Does Not Require 

Them to Report Property 

Transfer Strategies and 

Progress 

Although each of the military services has processes and procedures in 

place to monitor environmental cleanup and property transfer progress, 

DOD has not required the services to prepare and provide a BRAC 

property cleanup and transfer strategy to OSD, which has overall 

responsibility for overseeing the services’ implementation of 

environmental cleanup on unneeded BRAC properties. Without such a 

requirement, OSD cannot readily monitor and track the transfer tools the 

services are using to expedite the cleanup and transfer of BRAC 

properties. Further, there is less likelihood of the sharing of lessons 

Page 30 GAO-07-166 Military Base Closures
learned among the services, and communities could be denied full 

economic benefits that may be possible through expedited reuse of the 

property. 

In March 2006 guidance, DOD encouraged the military services to use all 

appropriate means to transfer unneeded property from the BRAC 2005 

round and prior BRAC rounds, and to dispose of property at the “highest 

and best use”.40 As the disposing agency, the military department has the 

authority to select the methods of disposing of unneeded properties. The 

guidance states that DOD recognizes that federal law provides it with an 

array of legal authorities by which to transfer property, but also recognizes

that the variety of installation types and the unique circumstances of the 

surrounding communities do not lend themselves to a single approach. 

We found that each of the services monitors BRAC property cleanup and 

disposal progress as part of their responsibility to dispose of unneeded 

BRAC property. According to the Army, discussions within the Army 

Conveyance Team41 can focus on progress and problems being 

encountered with a current property disposal method at an installation. 

The Army then attempts to resolve the problem with the local 

redevelopment authority. In addition, the Army has developed a system to 

track ongoing transfer conveyances for BRAC properties so it can identify

slippage and track progress. Approximately every 6 months Army 

environmental personnel meet to discuss funding requirements and 

property transfer issues. Within the Air Force Real Property Agency, 

environmental program reviews are performed at least twice a year to 

determine the extent of cleanup progress at Air Force BRAC installations. 

In addition, the Air Force conducts bimonthly reviews to identify potential 

problems and to confirm that the transfer schedule is being maintained. 

We were told by a Navy official that each Program Management Office 

regional director42 meets monthly with each of their BRAC teams to 

discuss cleanup and property disposal progress at BRAC properties and, if

 40The most likely use to which a property can be put, which will produce the highest 

monetary return, promote its maximum value, or serve a public or institutional purpose. 

41The Army Conveyance Team consists of the BRAC Program Manager; Base Transition 

Coordinator; Base Environmental Coordinator; representatives from the installation, Army

Environmental Law Division, Corps of Engineers and Army Office of General Counsel; and

other Army personnel as necessary. 

42The Navy Program Management Office (PMO) regions are: PMO West (San Diego, Calif.); 

PMO Southeast (Charleston, S.C.); and PMO Northeast (Philadelphia, Pa.). 

Page 31 GAO-07-166 Military Base Closures
needed, any potential alternative approaches that could expedite cleanup

and disposal. 

According to a key OSD official responsible for monitoring the services’ 

progress, the military services are not required to formally report their 

strategy for cleaning up and transferring BRAC properties, including 

sharing any challenges and successes they experienced in the use of 

various property disposal tools or that they fully considered using all the 

tools available to them. According to OSD and service officials in charge of

monitoring the services’ progress in the cleanup and transfer of unneeded

properties, the services currently provide OSD with only informal, ad hoc 

progress reports. Furthermore, these officials believe that a more regular 

and formal process for periodically reporting and sharing experiences with 

various transfer tools would be helpful to both OSD (in tracking the use of

these tools) and to the services (in learning from others’ successes and 

failures). One service official went on to state that more is actually learned 

by the failures rather than the successes and those experiences should be 

shared. We believe that sharing information, possibly via the Internet, 

among and between the services, communities, and the private sector, 

could facilitate the exchange of ideas and the sharing of lessons learned 

which may in turn expedite the cleanup and transfer of BRAC properties. 

Without such a requirement, OSD is hampered in tracking the services’ use 

of these tools to assure Congress that they are taking full advantage of all 

opportunities to expedite the cleanup and transfer of unneeded properties 

so that communities can realize the full economic benefits of expeditious 

property reuse. 

An incomplete picture of environmental cleanup costs at the beginning of 

the implementation of BRAC 2005 relates to a piecemeal reporting of 

environmental cleanup costs for bases when they are in an active status, 

coupled with the fact that environmental cleanup information evolves over 

time. DOD can ensure that Congress has the most complete information 

available by providing more clarification and explanation as to what is 

included and excluded in the environmental cleanup costs it presents to 

Congress and include the total expected cost—both incurred costs as well 

as the most current estimate of expected future costs—for the cleanup at 

BRAC bases. Without this information, Congress cannot ensure that scarce 

federal resources are used in the most efficient manner to address 

environmental cleanup issues at unneeded DOD properties so that 

productive new uses for these properties can be more quickly realized. 

Conclusions 

Page 32 GAO-07-166 Military Base Closures
Numerous tools have been made available to DOD to help expedite the

transfer of unneeded BRAC property to other users. As DOD seeks to use 

these tools for 2005 BRAC round bases, OSD could more effectively 

conduct its oversight responsibilities by requiring the services to 

periodically report on their progress to transfer properties and plans to 

take full advantage of the tools available to them. In addition, each of the 

services may find it useful to learn and benefit from the property transfer 

experiences gained with these tools within and among the services. Delays 

in transferring unneeded properties result in additional expense to DOD to 

care for and maintain these properties while the affected community 

receives no benefit—economic or otherwise—as it waits for the property 

to be redeveloped for productive use. 

In order to provide more complete and transparent cost information for 

the environmental cleanup of properties from all BRAC rounds, we 

recommend that the Secretary of Defense direct the Under Secretary of 

Defense (Acquisition, Technology, and Logistics) to report all costs (DERP

and non-DERP)—past and future—required to complete environmental 

cleanup at each BRAC installation and to fully explain the scope and 

limitations of all the environmental cleanup costs DOD reports to 

Congress. We suggest including this information in the annual BRAC 

budget justification documentation since it would accompany information 

Congress considers when making resource allocation decisions. 

In order to help ensure that the military services are taking full advantage 

of all tools available to clean up and transfer unneeded BRAC properties 

from the 2005 round, we recommend that the Secretary of Defense direct 

the Under Secretary of Defense (Acquisition, Technology, and Logistics) to 

require that the military services periodically report to OSD on the status 

and proposed strategy for transferring these properties and include an

assessment of the usefulness of all tools at their disposal. We suggest 

placing this information in an easily shared location, such as a Web site, so

that each service, and even the local communities and private sector, can

share and benefit from lessons learned. 

In written comments on a draft of this report, DOD concurred with the 

fundamental aspects of both of our recommendations to take actions to 

improve its reporting of BRAC environmental cleanup costs to Congress 

and to require the military services to periodically report to the Office of 

the Secretary of Defense on the status and proposed strategy for 

transferring unneeded BRAC properties. DOD’s comments are reprinted in

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 33 GAO-07-166 Military Base Closures
appendix IV and addressed as appropriate in the body of the report. DOD 

further provided technical comments, which we also incorporated as 

appropriate into this report. 

In order to provide more complete and transparent cost information on 

the entire cost of environmental cleanup, DOD concurred with our basic 

recommendation to report all costs—past and future—required to 

complete environmental cleanup at each BRAC installation and to fully 

explain the scope and limitations of all the environmental cleanup costs 

DOD reports to Congress. However, DOD’s comments reflect only a partial 

concurrence because DOD did not agree with our suggestion to include 

this information in the annual BRAC budget justification documentation. 

DOD stated its belief that this would be counterproductive and that 

Congress has prescribed the types of environmental information it wants 

presented in the budget documentation, which DOD complies with. In 

making our suggestion, it was not our intent that it be considered as part 

of the recommendation. However, we continue to believe that the annual 

BRAC budget justification documentation would be the most useful place 

for this cost-reporting information, since this documentation is referred to 

by Congress when deliberating BRAC environmental cleanup funding. 

Nonetheless, if the Department can meet the intent of our 

recommendation by submitting this information in another report, we 

defer to the Department on how best to report this information to 

Congress. 

In order to help ensure that the military services are taking full advantage 

of all tools available to clean up and transfer unneeded BRAC properties 

from the 2005 round, DOD concurred with our recommendation to require 

the military services to periodically report to the Office of the Secretary of

Defense on the status and proposed strategy for transferring BRAC 

properties and include an assessment of the usefulness of all tools at their 

disposal. Although DOD did not comment on our suggestion to accomplish 

this through a shared Web site in order to maximize the lessons learned, 

DOD officials embraced the idea as something easily doable in comments 

made during our exit interview with the agency. 

We are sending copies of this report to interested congressional 

committees; the Secretaries of Defense, the Army, Navy, and Air Force; 

and the Director, Office of Management and Budget. We will also make 

copies available to others upon request. In addition, the report will be 

available at no charge on GAO’s Web site on http://www.gao.gov. 

Page 34 GAO-07-166 Military Base Closures
Please contact me on (202) 512-4523, leporeb@gao.gov, or my Assistant 

Director, Jim Reifsnyder, at (202) 512-4166, reifsnyderj@gao.gov, if you or 

your staff has any questions concerning this report. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. GAO staff that made major contributions to this 

report are listed in appendix VI. 

Brian Lepore, Acting Director 

Defense Capabilities and Management 

Page 35 GAO-07-166 Military Base Closures
List of Congressional Committees

The Honorable Carl Levin 

Chairman 

The Honorable John McCain 

Ranking Minority Member 

Committee on Armed Services 

United States Senate 

The Honorable Daniel K. Inouye 

Chairman 

The Honorable Ted Stevens 

Ranking Minority Member 

Subcommittee on Defense 

Committee on Appropriations 

United States Senate 

The Honorable Tim Johnson 

Chairman 

The Honorable Kay Bailey Hutchinson 

Ranking Minority Member 

Subcommittee on Military Construction, 

 Veterans Administration, and Related Agencies 

Committee on Appropriations 

United States Senate 

The Honorable Ike Skelton 

Chairman 

The Honorable Duncan Hunter 

Ranking Minority Member 

Committee on Armed Services 

House of Representatives 

The Honorable John P. Murtha 

Chairman 

The Honorable C.W. Bill Young 

Ranking Minority Member 

Subcommittee on Defense 

Committee on Appropriations 

House of Representatives 

Page 36 GAO-07-166 Military Base Closures
The Honorable Chet Edwards 

Chairman 

The Honorable Roger F. Wicker 

Ranking Minority Member 

Subcommittee on Military Construction, 

 Veterans Affairs and Related Agencies 

Committee on Appropriations 

House of Representatives 

Page 37 GAO-07-166 Military Base Closures
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To address our first objective to examine potential cleanup costs 

associated with the Base Realignment and Closure (BRAC) process, we 

collected and analyzed relevant documentation generated by the Office of 

the Secretary of Defense and the military departments, and we interviewed 

key officials with knowledge of BRAC cost reports and estimates. We 

collected and analyzed environmental cleanup cost estimates for the 25 

major base closures and similar estimates for the minor closures and 

realignments for the 2005 BRAC round, as well as costs for the prior BRAC 

rounds. To gain a sense of the models used to estimate cleanup costs, we 

viewed a demonstration of the Remedial Action Cost Engineering 

Requirements System cost estimating tool used by the Army and the Air 

Force, and the Normalized Data cost estimating tool used by the Navy. We

interviewed knowledgeable officials about BRAC environmental cleanup 

costs from the Army Environmental Center, the Air Force Real Property 

Agency, and the Navy’s Northeast BRAC Program Management Office. In

addition, we visited four BRAC 2005 locations—Fort Monroe, Hampton, 

Virginia; Umatilla Chemical Depot, Hermiston, Oregon; Brunswick Naval 

Air Station, Brunswick, Maine; and the Mississippi Army Ammunition 

Plant, Picayune, Mississippi—to gain a better understanding of the 

environmental cleanup requirements facing these installations and the 

processes that base officials are following to estimate cleanup costs. We 

also interviewed Office of the Secretary of Defense and the services’ 

officials to gain an understanding of how the estimates derived from the 

services’ environmental cost estimating models are reported in various 

Department of Defense (DOD) environmental reports to Congress. In so 

doing, we analyzed the cost information contained in each report in order 

to derive estimated cleanup costs for the prior BRAC rounds. We also 

compared the cost estimates projected at the installation level with 

estimates that were reported to Congress to verify that the data were 

consistent. Although we found some discrepancies, we concluded that, 

overall, the DOD data were sufficiently reliable for the purposes of this 

report. 

To address our second objective to examine DOD’s progress in 

transferring unneeded properties from the four prior BRAC rounds, we 

reviewed our prior BRAC reports and reports prepared by the 

Congressional Research Service and DOD on this subject. Using property 

transfer information on the four prior BRAC rounds provided by the Office 

of the Secretary of Defense and the services, we updated the transfer 

acreage data reported in our January 2005 report in order to determine the

extent of progress made in the transfer of unneeded property. We assessed 

the reliability of the reported transferred property acreage by interviewing 

knowledgeable officials and comparing acreage totals to GAO reports 

Page 38 GAO-07-166 Military Base Closures
Appendix I: Scope and Methodology 

from prior years. Although the acreage totals change as property is 

transferred and more accurate land surveys are completed, we determined 

that the data were sufficiently reliable to provide overall comparisons. We 

interviewed officials from the Environmental Protection Agency’s Office of 

Federal Facilities and consulted with them about their concerns regarding 

environmental cleanup at prior BRAC round bases. We interviewed DOD 

and military service officials responsible for environmental cleanup at

BRAC and active bases at both the headquarters and field level to clarify 

reasons for property transfer delays, such as technology and regulations.

We visited the three BRAC bases from the four prior BRAC rounds with 

the most expensive estimated cost to complete for cleanups—the former 

McClellan Air Force Base, Sacramento, California; the former Fort Ord, 

Marina, California; and the former Alameda Naval Air Station, Alameda, 

California. During these visits, we spoke not only with military officials but 

also with officials from local redevelopment authorities at these 

installations, as well as officials from the California State Environmental 

Protection Agency, to determine the major impediments to property 

transfers. To supplement these discussions we collected data from the 

services on the extent that environmental issues were impeding property 

transfer. 

To address our third objective to assess possible opportunities for DOD to

expedite the cleanup and transfer of unneeded BRAC properties, we 

reviewed relevant laws, regulations, and policies governing the cleanup

and transfer of properties, and we also reviewed prior GAO and DOD 

reports on this subject. We also reviewed DOD’s 2006 Base Redevelopment 

and Realignment Manual for an assessment of tools available to the 

services for expediting the cleanup and property transfer. We analyzed the 

use of these tools to date at selected BRAC installations and compiled 

overall statistics on the use of these authorities in the prior BRAC rounds. 

We interviewed officials representing federal and state environmental 

regulatory agencies for their perspective on DOD cleanup activities and 

any opportunities for DOD to expedite the cleanup process while adhering 

to legal cleanup standards. In addition, during our visits to the seven 

installations mentioned earlier, we interviewed community officials for 

their perspective on the speed and quality of environmental cleanups and 

property transfers, and opportunities for speeding up the process. We 

spoke with cognizant from the Office of the Secretary of Defense (OSD) 

and service officials to ascertain their views as to the extent of oversight 

of the services’ use of existing transfer tools and the sharing of lessons 

learned from the property transfer process. 

Page 39 GAO-07-166 Military Base Closures
Appendix I: Scope and Methodology 

During the course of our review, we contacted the following offices with 

responsibility for oversight, management, and implementation of the 

environmental cleanup of military and specifically, BRAC bases: 

Office of the Secretary of Defense 

• Office of the Deputy Under Secretary of Defense for Acquisition, 

Technology and Logistics, Installations and Environment, 

Washington, D.C. 

• Office of the Secretary of Defense (Comptroller), Washington, D.C. 

Army 

• Army Office of the Assistant Chief of Staff of Installation Management, 

Base Realignment and Closure Division, Arlington, Virginia 

• Office of the Deputy Assistant Secretary of the Army, Environmental 

Safety and Occupational Health, Washington, D.C. 

• Army Installation Management Agency, Arlington, Virginia 

• Army Materiel Command, Fort Belvoir, Virginia 

• Army Environmental Center, Aberdeen, Maryland

• Army Corps of Engineers, Environmental Office for Formerly Used 

Defense Sites, Washington, D.C. 

• Army National Guard, Arlington, Virginia 

Navy 

• Navy BRAC Program Management Office Northeast, Philadelphia, 

Pennsylvania

• Navy BRAC Program Management Office, West, San Diego, California 

• Navy BRAC Environmental Office, Arlington, Virginia 

Air Force 

• Air Force Real Property Agency, Arlington, Virginia 

• Air Force Audit Agency, Washington, D.C. 

• Air National Guard, Arlington, Virginia

• Air Force Office of the Civil Engineer, Environmental Division, 

Arlington, Virginia 

Page 40 GAO-07-166 Military Base Closures
Appendix I: Scope and Methodology 

Other agencies 

• Federal Environmental Protection Agency, Federal Facilities Branch, 

Arlington, Virginia 

• Association of State and Territorial Solid Waste Management Officials, 

Washington, D.C. 

• State of California Environmental Protection Agency, Sacramento, 

California 

• Fort Ord Reuse Authority, Marina, California 

• McClellan Local Reuse Authority, Sacramento, California 

• Alameda Reuse and Redevelopment Authority, Alameda, California 

• Umatilla Reuse Authority, Hermiston, Oregon 

• Brunswick Local Redevelopment Authority, Brunswick, Maine 

• Fort Monroe Reuse Authority, Hampton, Virginia 

We visited three bases closed during the prior BRAC rounds—chosen 

because they represent each of the three services and also have the three 

most expensive estimated costs to complete cleanups for sites currently 

undergoing cleanup: 

• Fort Ord, Marina, California 

• McClellan Air Force Base, Sacramento, California 

• Alameda Naval Air Station, Alameda, California 

We also visited four bases scheduled for closure under the 2005 BRAC 

round—chosen to represent a variety of missions as well as geographic 

diversity: 

• Fort Monroe, Hampton, Virginia 

• Umatilla Chemical Depot, Hermiston, Oregon 

• Brunswick Naval Air Station, Brunswick, Maine 

• Mississippi Army Ammunition Plant, Picayune, Mississippi 

We conducted our work from January 2006 through November 2006 in

accordance with generally accepted government auditing standards. 

Page 41 GAO-07-166 Military Base Closures
Appendix II: CERCLA Cleanup Requirements Appendix II: CERCLA Cleanup Requirements 

The Comprehensive Environmental Response, Compensation, and 

Liability Act of 1980 (CERCLA),1

 as amended, authorizes cleanup actions 

at federal facilities where there is a release of hazardous substances or 

threat of such a release. CERCLA section 120(h) contains provisions that 

establish requirements for the transfer or lease of federally owned 

property based on storage, disposal, or known release of hazardous 

substances. All contracts for transfer or lease must include notice of this

storage, disposal, or release. Except as noted below, CERCLA section 

120(h)(3) requires that transfers of federal real property by deed must also 

include: (a) a covenant by the United States that all remedial action 

necessary to protect human health and the environment has been taken 

prior to transfer, (b) a covenant by the United States to undertake any 

further remedial action found to be necessary after transfer, and (c) a 

clause granting access to the transferred property in case remedial action 

or corrective action is found to be necessary after transfer. 

To clean up potentially contaminated sites on both active and closed 

bases, the Department of Defense (DOD) generally follows the process 

that is required under CERCLA, which generally includes the following 

phases and activities: 

• Preliminary Assessment—Available information is collected regarding 

contamination, including a search of historical records, to confirm 

whether a potential environmental contamination or military munitions 

hazard could be present and to determine whether further action is 

needed. 

• Site Investigation—This step usually involves a walk around the site by 

an environmental engineer and may involve some limited soil and 

water sampling including an analysis to determine the extent and 

source(s) of the hazards. 

• Remedial Investigation/Feasibility Study—More rigorous statistical 

sampling and analysis is conducted to determine the exact nature and 

extent of contamination and whether cleanup action is needed and, if 

so, select alternative cleanup approaches. This could include removal, 

limiting public contact, determining no further action is warranted, or 

cleaning of the hazardous media (soil, air, or water) on site. 

• Remedial Design/Remedial Action—This phase involves designing and

constructing the actual cleanup remedy, such as a pump and treat 

system for underground water, or the removal of munitions. 

 1

 Pub. L. No. 99-499 (1986). 

Page 42 GAO-07-166 Military Base Closures
Appendix II: CERCLA Cleanup Requirements

• Long-term Monitoring—At this phase, parties responsible for the 

cleanup periodically review the remedy in place to ensure its continued 

effectiveness, including checking for unexploded ordnance and 

conducting public education. 

While the Superfund Amendments and Reauthorization Act of 1986 had 

originally required the government to warrant that all necessary cleanup 

action had been taken before transferring property to nonfederal 

ownership, the act was amended in 1996 to expedite transfers of 

contaminated property.2

 Now such property, under some circumstances, 

can be transferred to nonfederal users before all remedial action has been

taken. However, certain conditions must exist before the department can 

exercise this “early transfer authority.” For example, the property must be 

suitable for transfer for the intended use; transfer of the property must not 

delay any cleanup actions; and the governor of the state where the 

property is located must approve the transfer. The advantage of an early

transfer is that property is made available under a transfer authority to the

future user as soon as possible to allow for concurrent environmental 

cleanup and redevelopment. The law still requires that contaminated sites 

must be cleaned up to ensure that past environmental hazards due to 

former DOD activity on transferred BRAC property are not harmful to 

human health or to the environment and that the property can support 

new use; however, the early transfer authority does allow for the 

concurrent cleanup and reuse of the property. 

 2

 Pub. L. No. 104-201, § 334. 

Page 43 GAO-07-166 Military Base Closures
Appendix III: Environmental Cleanup Cost 

Information in Four Selected Reports to Appendix III: Environmental Cleanup Cost Congress 

Information in Four Selected Reports to 

Congress 

The Department of Defense (DOD) annually provides Congress with four

required reports that include information on environmental cleanup costs 

and estimates at active and Base Realignment and Closure (BRAC) 

installations. Each report is prepared for a different purpose, such as 

budgetary, financial, or program oversight, resulting in various 

presentations of estimated and actual cleanup costs. None of the reports, 

however, provides the total environmental program costs and estimates 

for each service and their bases. The types of environmental program 

costs include restoration and munitions cleanup, compliance, and program 

management and planning. 

The four annual reports are1

 the (1) Annual BRAC Budget Appropriations 

Request, (2) Annual Defense Environmental Programs Report to Congress, 

(3) Annual Government’s Consolidated Financial Statement Report, and 

(4) Annual Section 2907 report.2

 The following provides a description of 

the reports’ mandates, when they are issued, and the information they 

contain. 

Annual BRAC Budget Appropriations Request: Section 206 of the

Defense Authorization Amendments and Base Closure and Realignment 

Act, Public Law 100-526, specifies the type of information required in 

DOD’s annual budget appropriation request for BRAC funding. DOD and 

the services prepare separate budget justification books that provide 

details for each BRAC round on funds made available for environmental 

cleanup and the budget request estimate for the fiscal year that the request

is being made for. The environmental funded amounts and the estimate 

include information on all environmental costs, including restoration and 

munitions cleanup, compliance, and program management and planning.

The information in DOD’s fiscal year 2006 budget request indicates that 

$9.0 billion had been made available for DERP (environmental restoration 

and munitions) cleanup and non-DERP (compliance and program 

management and planning) through fiscal year 2005 for the prior four 

BRAC rounds. The fiscal year 2006 budget request estimate for the 

 1

 The report titles listed are the titles commonly used. The official titles of these reports 

are, DOD Base Realignment and Closure Executive Summary and Budget Justification, 

Department of Defense Performance and Accountability Report, The Defense 

Environmental Programs Annual Report to Congress, and the Department of Defense

Report on 2005 Defense Base Closure and Realignment Implementation, respectively. 

2

 This reporting requirement refers to Section 2907 of Public Law 101–510. 

Page 44 GAO-07-166 Military Base Closures
Appendix III: Environmental Cleanup Cost 

Information in Four Selected Reports to 

Congress 

environmental cleanup costs was about $378 million. DOD also presented 

Congress with information on the 2005 BRAC closures and realignments, 

which shows that DOD and the services plan to spend about $426 million 

on the environmental cleanup cost categories between fiscal year 2006 and 

2011. The estimated amounts were presented in current or inflated dollars. 

Although the Annual BRAC Budget Appropriations Request report 

includes all categories of costs, it does not include—nor is DOD required 

to report—the total estimated cost to complete the environmental cleanup

(past and future costs) for the BRAC bases. 

Annual Government’s Consolidated Financial Statement Report: As 

required by the Chief Financial Officer Act of 1990 and the Government 

Management Reform Act of 1994, DOD is required to report on its 

estimated environmental liabilities in the federal government’s annual 

fiscal year consolidated financial statements, and does so each year in its 

performance and accountability report to Congress. The environmental 

liability information for active and BRAC bases is contained in note 14 of 

the financial statements for fiscal year 2005 and the information contains

separate line item amounts for the restoration and compliance categories. 

The environmental program management and planning cost amounts were 

included in the restoration amount and DOD uses the installations’ defense 

environmental programs data to compile a large portion of its 

environmental liabilities for financial statement reporting. 

The November 15, 2005, report for fiscal year 2005 activity indicates that 

the total BRAC restoration liability amount, or future cost to complete, 

was $3.5 billion. The BRAC environmental liability for compliance and 

program management and planning was reported as $206.5 million. The 

data are not inflated and are stated in current dollars. 

The government’s annual consolidated financial statement report presents 

the most complete information on the environmental cost categories for 

the cost to compete the cleanup. The information is reported in total for 

DOD and summarized for each service. However, the report does not 

provide information on how much has been made available for BRAC 

environmental cleanup, and there is no detailed information presented for 

individual bases. 

Annual Defense Environmental Programs Report to Congress: As 

required by section 2706 of Title 10, DOD annually submits this report to 

Congress. The latest report, which covered fiscal year 2005, was issued to 

Congress in March 2006. Different sections of the report discuss and 

Page 45 GAO-07-166 Military Base Closures
Appendix III: Environmental Cleanup Cost 

Information in Four Selected Reports to 

Congress 

provide planning and funding costs and cost estimate information for the 

various DOD environmental programs at active and BRAC bases. These 

sections have information on active and BRAC bases’ restoration and 

munitions cleanup expenditures for fiscal years 2004 and 2005 and the cost 

to complete the environmental cleanup from 2006 to completion. The 

report also presents information on non-DERP and program management 

and planning costs and estimates for BRAC activities in the aggregate (but 

not by base).

The information on the expected cost to complete the restoration and 

munitions environmental cleanup at BRAC bases for the first four rounds 

shows that DOD estimates this cost at about $3.8 billion from 2006 to 

completion. From the section of the report that reconciles the services’ 

cost to complete with the reported environmental liability, we were able to 

sum the services’ compliance and management and support costs and 

determine that the total cost to complete from fiscal year 2006 for these 

categories totaled about $0.4 billion. The dollar amounts for cost to 

complete from 2006 through 2011 were inflated and the dollar amounts 

from fiscal year 2012 to completion were in constant 2011 dollars. 

While the defense environmental programs report provides ample 

information on environmental cleanup costs and estimates, it does not 

consolidate the information to obtain an overall or total environmental 

cleanup cost amount for each service and base. 

Annual Section 2907 Report: This report addresses reporting 

requirements specified in section 2907 of Public Law 101-510, commonly 

referred to as the BRAC Act, for all BRAC 2005 installations. Among other 

things, the 2907 report includes details on the known environmental 

remediation restoration and munitions cleanup issues at each base 

affected by the 2005 BRAC recommendation. The information provides 

details on the estimate to complete the cleanup at each identified site, and 

plans and time lines to address the cleanup. According to DOD officials, 

the first report issued for the 2005 BRAC was in March 2006 and the 

estimates are based on the restoration and munitions cleanup data 

contained in the defense environmental programs report. 

Page 46 GAO-07-166 Military Base Closures
Appendix IV: Comments from the Department Appendix IV of Defense : Comments from the 

Department of Defense 

Page 47 GAO-07-166 Military Base Closures
Appendix IV: Comments from the Department 

of Defense 

Page 48 GAO-07-166 Military Base Closures
Appendix IV: Comments from the Department 

of Defense 

Page 49 GAO-07-166 Military Base Closures
Appendix V: Key Prior GAO Reports on DOD Appendix V Environmental Cleanup : Key Prior GAO Reports on DOD 

Environmental Cleanup 

Environmental Liabilities: Long-Term Planning Hampered by Control 

Weaknesses and Uncertainties in the Federal Government’s Estimates. 

GAO-06-427. Washington, D.C.: March 31, 2006. 

Military Bases: Analysis of DOD’s 2005 Selection Process and 

Recommendations for Base Closures and Realignments. GAO-05-785. 

Washington, D.C.: July 1, 2005. 

Military Base Closures: Observations on Prior and Current BRAC 

Rounds. GAO-05-614. Washington, D.C.: May 3, 2005. 

Military Base Closures: Updated Status of Prior Base Realignments and

Closures. GAO-05-138. Washington, D.C.: January 13, 2005. 

DOD Operational Ranges: More Reliable Cleanup Cost Estimates and a 

Proactive Approach to Identifying Contamination Are Needed. GAO-04-

601. Washington, D.C.: May 28, 2004. 

Military Munitions: DOD Needs to Develop a Comprehensive Approach 

for Cleaning Up Contaminated Sites. GAO-04-147. Washington, D.C.: 

December 19, 2003. 

Environmental Compliance: Better DOD Guidance Needed to Ensure 

That the Most Important Activities Are Funded. GAO-03-639. Washington, 

D.C.: June 17, 2003. 

Environmental Contamination: DOD Has Taken Steps to Improve 

Cleanup Coordination at Former Defense Sites but Clearer Guidance Is

Needed to Ensure Consistency. GAO-03-146. Washington, D.C.: March 28, 

2003. 

Military Base Closures: Progress Completing Actions from Prior 

Realignments and Closures. GAO-02-433. Washington, D.C.: April 5, 2002.

Military Bases: Status of Prior Base Realignment and Closure Rounds.

GAO/NSIAD-99-36. Washington, D.C.: December 11, 1998. 

Military Base Closures: Reducing High Costs of Environmental Cleanup 

Requires Difficult Choices. GAO/NSIAD-96-172. Washington, D.C.: 

September 5, 1996. 

Page 50 GAO-07-166 Military Base Closures
Appendix VI: 

A

GAO Contacts and Staff 

cknowledgments 

Page 51 GAO-07-166

Appendix VI: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts Brian Lepore, Acting Director (202) 512-4523 

Jim Reifsnyder, Assistant Director (202) 512-4166

In addition to the individuals named above, Barry Holman, Karen Kemper, 

Andy Marek, Bob Poetta, and Angie Zeidan made significant contributions 

to this report. 

Other individuals also contributing to this report include Susan Ditto, Ron 

La Due Lake, Steve Lipscomb, Ken Patton, Charles Perdue, and Ed 

Zadjura. 

Military Base Closures

Acknowledgments 

(350792) 
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