Report to Congressional Committees 

United States General Accounting Office 

GAO 

January 2004 DEPOT 

MAINTENANCE 

Army Needs Plan to 

Implement Depot 

Maintenance Report’s 

Recommendations 

GAO-04-220 
www.gao.gov/cgi-bin/getrpt?GAO-04-220.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Barry W. 

Holman at (202) 512-8412 or 

holmanb@gao.gov. 

Highlights of GAO-04-220, a report to 

Senate and House Armed Services 

Committees 

January 2004

DEPOT MAINTENANCE

Army Needs Plan to Implement Depot 

Maintenance Report’s Recommendations 

The Army’s proliferation report, issued in September 2003, did not fully 

identify the extent of depot-level maintenance work performed outside the 

Army’s public depots. The report estimated that the Army underreported 

its fiscal year 2001 $2.7 billion depot-level maintenance program by 

$188.6 million but indicated that this was a rough estimate and that further 

analysis is needed. It attributed this underreporting largely to work 

performed in two categories—work that met the criteria for depot-level 

maintenance work but was not reported as such and work at nondepot field 

facilities that involved depot-level maintenance tasks. GAO’s prior reviews 

also identified these categories as key contributors to underreporting. While 

the report noted that the Army has an extensive maintenance infrastructure 

with redundant capabilities, it did not address the extent of this redundancy. 

The lack of complete information on the extent of depot-level maintenance 

workloads limits the Army’s ability to fully account for this work in the 

Department of Defense’s (DOD) annual report to Congress on the allocation 

of public- and private-sector depot-level maintenance spending. The 2003 

proliferation report identified key Army limitations, including 

inconsistencies in applying the congressionally mandated definition of 

“depot maintenance,” weaknesses in its management information systems, 

and the failure to follow established policies and procedures for authorizing 

depot-level maintenance work at nondepot facilities. GAO’s current analysis 

and prior work confirmed that these limitations make it difficult for the 

Army to fully account for its maintenance workload as it moves closer to the 

50 percent ceiling for work performed by contractors. GAO’s most recent 

report on the Army’s 50-50 reporting for fiscal year 2002 showed that, after 

adjustments for known underreporting, the percentage of private-sector 

work increased to 49 percent. 

If implemented, the 29 recommendations in the 2003 report could enhance 

the Army’s ability to report on its 50-50 data and to evaluate the proliferation 

of depot-level maintenance work at nondepot facilities. The 

recommendations, which are consistent with those that GAO has previously 

made, are focused on key problem areas, such as the need for an improved 

understanding about the 50-50 rule and for compliance with reporting 

policies and procedures. Efforts have been undertaken to address some of 

the problem areas. However, the Army has not yet developed an action plan 

that identifies priorities, time frames, roles and responsibilities, evaluation 

criteria, and resources for managing the implementation of the 

recommendations. Until the Army does this, it will be difficult to assess to 

what extent the Army is likely to meet its desired objectives. While 

improvements should be accomplished, the complexity and vastness of the 

Army’s maintenance system and continuing questions about such issues as 

the definition of “depot maintenance” and changing maintenance strategies 

could continue to present challenges in fully recording all maintenance work 

that should be captured. 

Each year, the U.S. Army spends 

about $3 billion on depot-level 

maintenance and repair work for 

weapons systems and other 

equipment. However, because its 

data gathering and reporting 

processes have been limited, the 

Army historically has been unable 

to fully identify how much depotlevel maintenance takes place 

outside its five public depots. As a 

result, it has not been able to 

determine with precision how 

well it was meeting statutory 

requirements to limit contracted 

depot-level maintenance work to 

50 percent of the program budget. 

In the House report on the Fiscal 

Year 2001 Defense Authorization 

Act, Congress directed the Army to 

report on the proliferation of 

depot-level maintenance work at 

nondepot facilities and asked GAO 

to review that report. GAO 

examined the extent to which 

(1) the Army’s report identifies the 

amount of depot-level maintenance 

work done outside public depots; 

(2) the Army can account for its 

depot-level maintenance workload, 

as required by statute; and (3) the 

corrective actions in the report are 

likely to address the proliferation 

issue and enhance the Army’s 

reporting. 

GAO recommends that the 

Secretary of the Army develop an 

action plan to implement the 

recommendations in the Army’s 

2003 maintenance proliferation 

report. DOD concurred with GAO’s 

recommendation. 
Page i GAO-04-220 Army Depot Maintenance 

Letter 1

Results in Brief 2

Background 4

Army’s 2003 Proliferation Report Did Not Fully Identify DepotLevel Maintenance Performed outside Public Depots 9

Army Cannot Provide Congress with a Complete Accounting of Its 

Depot-Level Maintenance Work 14

Army Needs Action Plan to Address Proliferation and Reporting 

Issues 19

Conclusions 26

Recommendation 27

Agency Comments and Our Evaluation 27

Appendix I Scope and Methodology 29 

Appendix II Army Maintenance Sites 31 

Appendix III Army Report’s Issues and Recommendations 34 

Appendix IV Comments from the Department of Defense 39 

Related GAO Products 41 

Tables 

Table 1: Categories in Which Depot-Level Maintenance Work Was 

Not Identified in Fiscal Year 2001 10

Table 2: Capacity and Capability Information on 17 Sites That 

GAO Visited 32

Contents 
Page ii GAO-04-220 Army Depot Maintenance 

Figures 

Figure 1: Army Maintenance Structure 6

Figure 2: Various Army Maintenance Facilities 12

Abbreviations 

DOD Department of Defense 

GAO General Accounting Office 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-04-220 Army Depot Maintenance 

January 8, 2004 

The Honorable John W. Warner 

Chairman 

The Honorable Carl Levin 

Ranking Minority Member 

Committee on Armed Services 

United States Senate 

The Honorable Duncan L. Hunter 

Chairman 

The Honorable Ike Skelton 

Ranking Minority Member 

Committee on Armed Services 

House of Representatives 

Each year the Department of Defense (DOD) submits a report to Congress 

showing that billions of dollars have been spent on depot maintenance and 

repairs for Army weapons systems and support equipment.1

 In recent 

years, depot-level maintenance and repair work has expanded from the 

traditional fixed-location public depots to numerous nondepot repair 

facilities in the field. This shifting of depot-level maintenance workload to 

field facilities has contributed to uncertainty about the magnitude of 

depot-level maintenance capabilities and the distribution of work between 

public and private facilities. In October 1999, we reported on the Army’s 

first congressionally directed report on the proliferation of depot-level 

maintenance activities at nondepot facilities, noting that the Army faced 

a number of continuing challenges in attempting to address the 

fragmentation of depot-level maintenance work and the proliferation of 

depot-level maintenance facilities. We noted that the Army’s report did not 

 1

According to 10 U.S.C. 2460, depot maintenance workloads include (1) materiel 

maintenance and repair requiring the overhaul, upgrading, or rebuilding of parts, 

assemblies, or subassemblies and (2) testing and reclamation of equipment as necessary, 

regardless of the source of funds or the location where the work is performed. 10 U.S.C. 

2466 requires annual reports of public- and private-sector expenditures for depot 

maintenance services and stipulates that no more than 50 percent of annual depot 

maintenance funding provided for military departments and defense agencies can be 

used for work accomplished by contractors. These reports are generally referred to as 

“50-50 reports.” 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-04-220 Army Depot Maintenance 

sufficiently identify the extent of depot-level maintenance work performed 

at nondepot facilities.2

In the House Armed Services Committee’s report on the fiscal year 2001 

defense authorization act,3

 Congress directed the Secretary of the Army 

to provide a report that identifies the proliferation of depot-level 

maintenance performed outside of the five public depots. The Army 

formally submitted its report in September 2003. The committee’s report 

also requested that we provide a review of the Army’s report, including an 

assessment of the Army’s ability to comply with 10 U.S.C. 2466, which 

governs the distribution of depot-level maintenance funds between public 

and private facilities. Our review addresses the extent to which (1) the 

Army’s report identifies the amount of depot-level maintenance work 

performed outside the public depots, (2) the Army can account for its 

depot-level maintenance workload as required by 10 U.S.C. 2466, and 

(3) the corrective actions in the Army report are likely to address the 

proliferation of depot-level maintenance activities and enhance the 

accuracy and completeness of 50-50 reporting. 

To address these objectives, we drew largely from the body of work we 

have done in the past on the Army’s depot-level maintenance issues. In 

addition, we interviewed officials at Army headquarters, Army major 

commands, and maintenance facilities at selected field installations to 

gain a better understanding of the implications of the Army report’s 

findings and recommendations. A detailed description of our scope and 

methodology is included in appendix I. 

The Army’s 2003 report does not fully identify the extent of depot-level 

maintenance work performed at nondepot facilities and, thus, is not fully 

responsive to the mandate’s requirement that the Army identify the 

proliferation of these types of facilities. The report’s identification of 

proliferation was limited to an estimated $188.6 million that the Army 

might have underreported in its $2.7 billion depot-level maintenance 

program for fiscal year 2001. This amount was said to be a preliminary 

rough estimate that needed further validation and, in our view, is not fully 

 2

See U.S. General Accounting Office, Depot Maintenance: Army Report Provides 

Incomplete Assessment of Depot-Type Capabilities, GAO/NSIAD-00-20 (Washington, D.C.: 

Oct. 15, 1999). 

3

House Report 106-616 (May 12, 2000). 

Results in Brief 
Page 3 GAO-04-220 Army Depot Maintenance 

indicative of all the depot-level maintenance work being done at nondepot 

facilities. The report indicated that this underreporting was largely due to 

the performance of depot-level maintenance tasks by nondepot facilities in 

such areas as (1) programs that did not identify depot-level maintenance 

work tasks but met the criteria for depot-level maintenance work and 

(2) field-level maintenance involving depot-level tasks. From our prior 

work and current analysis, we agree that these two areas are major 

contributors to the Army’s underreporting of its depot-level maintenance 

work. Although the report pointed out that the Army has an extensive 

maintenance infrastructure with redundant capabilities and capacities, it 

did not provide any information on the extent of this redundancy or the 

types of maintenance facilities that could be consolidated. Otherwise, the 

Army’s report was consistent with our findings in recent years and our 

work for this engagement. 

The lack of complete information on the extent of depot-level 

maintenance work performed in nondepot facilities limits the accuracy 

and completeness of DOD’s annual report to Congress on the allocation 

of depot-level maintenance funds between the public and private 

sectors. In our analysis of the Army’s 50-50 reporting, we have said that 

underreporting depot work at nondepot facilities is one of the limitations 

affecting the Army’s ability to fully account for its depot-level maintenance 

work. Consistent with our prior work in this area, the Army’s report 

identified several key factors affecting the Army’s ability to precisely 

capture and report its depot-level maintenance data at nondepot 

facilities. These factors include (1) the inconsistent application of the 

congressionally mandated definition of “depot maintenance” and related 

guidance, (2) weaknesses in management information systems for 

collecting and reporting workload data, and (3) the failure to follow 

established policies and procedures for authorizing depot-level work at 

field-level facilities and outsourcing depot-level maintenance workloads. 

Our current analysis and our prior work identify these factors as 

underlying causes affecting the Army’s determination that it has complied 

with the 50-50 depot-funding requirement. While neither the Army nor we 

can precisely quantify the extent of depot-level maintenance work that 

should have been included in the 50-50 analysis, this information is key for 

the Army to effectively manage its depot-level maintenance program and 

for ensuring the accurate and complete reporting of where depot-level 

maintenance is being performed as required by the 50-50 legislation. Such 

data become even more significant as the Army moves closer to the ceiling 

permitted for work performed by contractors. For example, the Army’s 

depot-level maintenance data for fiscal year 2002 indicated that funding in 

the private sector for depot-level maintenance was below the 50 percent 
Page 4 GAO-04-220 Army Depot Maintenance 

limit. However, our adjustments for known errors in reporting increased 

the percentage of private-sector work to 49 percent from the 46.5 percent 

reported by the Army. An increase of more than 1 percent in the use of the 

private sector to perform more depot-level maintenance in the future 

could cause the Army to exceed its statutory limitation and thereby be 

required to seek a national security waiver and notify Congress as 

provided for in 10 U.S.C. 2466. 

If fully implemented, the recommendations in the Army’s report could 

improve the identification of additional depot-level maintenance work in 

nondepot facilities, resulting in improving the accuracy and completeness 

of the 50-50 reporting. The Army’s proliferation report generally addressed 

key problem areas, and the recommendations were consistent with 

recommendations we have made in the past. Efforts have been undertaken 

to address some of the problem areas; however, no action plan to manage 

the implementation has been developed. Evaluating the success of the 

proposed 29 recommendations will be difficult until the Army develops an 

action plan with priorities, time frames, responsible organizations, and 

evaluation criteria, and until the resources required have been identified. 

At the same time, while improvements should be accomplished, the 

complexity and vastness of the Army’s maintenance system and 

continuing questions about such issues as the definition of “depot 

maintenance” and changing maintenance strategies could continue to 

present challenges in fully recording all depot-level maintenance work that 

should be captured. 

In this report, we are recommending that the Army establish a plan to 

manage the implementation of the recommendations in the depot 

proliferation report. In commenting on a draft of this report, DOD 

concurred with our recommendation, noting that the Army is establishing 

an integrated product team to develop an action plan. The response stated 

that some of the recommendations in the Army’s report would require 

modification. 

The Army uses maintenance capabilities in both the public and private 

sectors to maintain, overhaul, and repair its military weapons systems, 

such as missiles, combat vehicles, tactical vehicles, aircraft, and 

communication and electronic equipment. The level at which maintenance 

work is performed depends largely on authorized capability, worker skills, 

and predefined work requirements. Legislative requirementswhich play 

an important role in managing the allocation of depot-level maintenance 

workmandate that DOD provide Congress with annual reports on the 

Background 
Page 5 GAO-04-220 Army Depot Maintenance 

distribution of funding for depot-level maintenance workloads in the 

public and private sectors. 

The Army assigns maintenance work to four categories—unit support, 

direct support, general support, and depot-level support.4

 Unit and direct 

support workloads, which are limited to routine or recurring requirements, 

such as oil changes and the removal and replacement of components, are 

performed at military units in field locations and funded by direct 

appropriations for operations and maintenance. 

General support, which consists of the repair and overhaul of parts and 

assemblies and some end items such as trucks, is generally performed at 

fixed (nonmobile) industrial facilities located on Army posts, camps, and 

stations, and it is funded by direct appropriations for operations and 

maintenance.5

 Military personnel, government-employed civilians, or 

contractor employees may perform this maintenance. 

Depot-level support, which includes the overhaul; upgrading; and 

rebuilding of parts, assemblies, and subassemblies; and testing and 

reclamation of equipment, is the most intensive category of maintenance 

and requires the highest level of skilled workers and more sophisticated 

test and plant equipment. It traditionally has been performed by 

(1) government-employed civilians working at government-owned 

industrial facilities under the command and control of the Army Materiel 

Command (currently five public depots) or (2) contractor personnel 

working in contractor owned and operated facilities performing work 

specified by Army Materiel Command-managed maintenance contracts. 

The Army’s five government-operated maintenance depots6

 are managed 

within the Army Working Capital Fund.7

 Contract depot-level maintenance 

work is not managed under the working capital fund. 

 4

The Army’s maintenance structure for aircraft and components has only three categories: 

unit, intermediate, and depot. 

5

One key exception is the cost of military personnel involved in this category of work, 

which is accounted for in a separate, centrally managed, Military Personnel appropriations 

account. 

6

The five public depots are located at Anniston, Ala.; Corpus Christi, Tex.; 

Chambersburg, Pa.; Texarkana, Tex.; and Tobyhanna, Pa. 

7

Using working capital funds, organizations sell goods and services to customers on the 

basis of rates designed to recoup the full cost of operations. 
Page 6 GAO-04-220 Army Depot Maintenance 

Figure 1: Army Maintenance Structure 

The Army has two categories of depot-level maintenance activities: 

• Activities that have been designated and organized by design and 

purpose to primarily perform depot-level maintenance and repair tasks. 

These activities would include the Army Materiel Command’s public 

depots; the Army’s forward deployed maintenance depots; and 

contractor depots, primarily located at both the national and 

installation levels. 

• Activities below the depot level that have been granted approval to 

perform specific depot-level tasks through a special or one-time 

authorization or that have been designated as a source of repair. 

These activities include Army National Guard Readiness Sustainment 

Maintenance Sites and Aviation Classification Repair Activity Depots, 

Army Reserve Installation Materiel Maintenance Activities, and Army 

Forces Command Contract Maintenance Facilities. These activities are 

primarily located at the installation level, and the work may be done by 

either government or contractor personnel. 
Page 7 GAO-04-220 Army Depot Maintenance 

Operations of the Army depots are guided by legislative requirements 

that divide the amount of depot work between the public and private 

sectors and add specificity to how such work is to be defined. For 

example, 10 U.S.C. 2464 provides for a government owned and operated 

core logistics capability that is sufficient to ensure an effective and timely 

response to a mobilization or other national emergency. Also, 10 U.S.C. 

2466 generally prohibits the use of more than 50 percent of the funds made 

available in a fiscal year for depot-level maintenance and repair by 

nonfederal personnel. 

In addition, 10 U.S.C. 2460 defines depot-level maintenance to encompass 

material maintenance or repair requiring the overhaul, upgrading, or 

rebuilding of parts, assemblies, or subassemblies and the testing and 

reclamation of equipment, regardless of the source of funds for the 

maintenance or repair or the location where maintenance or repair work 

is performed. Depot-level maintenance also encompasses software 

maintenance, interim contractor support,8

 and contractor logistics 

support9

 to the extent that work performed in these areas is depot-level 

maintenance. The statute excludes from depot-level maintenance the 

nuclear refueling of an aircraft carrier, the procurement of major 

modifications or upgrades of weapons systems that are designed to 

improve program performance, and the procurement of parts for safety 

modifications, although the term “depot maintenance” does cover the 

installation of parts for safety modifications. Congress has made changes 

to various depot-level maintenance requirements over the years. For 

example, the 1998 Defense Authorization Act established a statutory 

definition of depot-level maintenance and repair and increased DOD’s 

authority to use its depot-level maintenance funds for the private sector’s 

performance of the work from 40 to 50 percent.10

On the basis of statutory language defining depot-level maintenance, the 

Office of the Secretary of Defense issues annual guidance to the military 

departments for reporting their public-private workload allocations. The 

 8

Interim contractor support is designed to be an interim arrangement in which a contractor 

provides depot-level maintenance (and sometimes other logistics support) as part of the 

acquisition strategy for new systems. 

9

Contractor logistics support is designed to be a lifetime support concept in which a 

contractor provides most or all elements of logistics support, including depot-level 

maintenance. 

10Pub. L. No. 105-85 (Nov. 18, 1997) sections 355 and 357. 
Page 8 GAO-04-220 Army Depot Maintenance 

military departments also issue internal instructions to manage the data 

collection and reporting process tailored to their individual organizations 

and operating environments. 

As we have reported in recent years in examining DOD’s compliance with 

its so-called “50-50 requirement” under 10 U.S.C. 2466, all of the military 

departments have continuing data errors and inconsistencies in reporting 

and problems in documenting and independently validating their annual 

reports. We also have recognized the limitations of their financial systems, 

operations, and controls, as well as their continuing inability to capture 

and report the full costs of depot-level maintenance programs. Some of 

our most recent reports on depot-level maintenance issues are listed in the 

Related GAO Products section of this report. 

We previously reported that the Army had not sufficiently identified the 

extent of depot-level maintenance work performed at nondepot facilities 

in its April 14, 1999, report to the House Committee on Armed Services on 

depot proliferation.11 While the Army’s report indicated that 40 staff years 

of depot-level maintenance work was performed outside of the formal 

depot system by nondepot maintenance providers operating under 

specialized repair authorities, it also recognized that the figure was likely 

understated for a variety of reasons to include limitations in systems and 

procedures to fully quantify such work. We agreed. We also noted that in 

July 1999 the Army designated its Army Materiel Command as its National 

Maintenance Manager with responsibility for overseeing the Army’s 

logistics and maintenance support programs and managing maintenance 

facilities. In doing so, we noted then that while the Army recognized that it 

needed to modify and standardize Army data systems to fully account for 

depot-level maintenance work at all locations, it had not established clear 

action plans, milestones, and funding requirements for doing so. 

Our September 2003 report on DOD’s compliance with the 50-50 

requirement found that the Army’s latest reporting on depot-level 

workloads for fiscal years 2001 and 2002 had utilized a new, more 

centralized financial system to collect 50-50 data that corrected some of 

the transcription errors we had found the previous year but that we 

continued to find errors, omissions, and inconsistencies in its data.12

 11See GAO/NSIAD-00-20. 

12See U.S. General Accounting Office, Depot Maintenance: DOD’s 50-50 Reporting Should 

Be Streamlined, GAO-03-1023 (Washington, D.C.: Sept. 5, 2003). 
Page 9 GAO-04-220 Army Depot Maintenance 

Moreover, we reported that, as in prior years, the Army underreported 

public- and private-sector depot-level maintenance work at field locations 

as it continues unfinished efforts to consolidate maintenance activities and 

better control the proliferation of depot-level tasks at nondepot facilities. 

Although the mandate directed the Army to identify the proliferation of 

depot-level maintenance performed outside the public depots, the Army’s 

report on depot-level maintenance proliferation did not fully identify the 

extent of depot-level maintenance work performed at nondepot facilities. 

Instead, the report estimated that depot-level maintenance work valued at 

$188.6 million for fiscal year 2001 was not included in the Army’s depotlevel maintenance data and that further validation of this amount was 

needed. While this estimate may not be fully indicative of depot-level 

maintenance work being performed outside the public depots, it indicates 

underreporting in this area that is consistent with the observations we 

have made in our prior work. Although the report recognized that the 

Army has redundant capabilities and capacities, it did not provide any 

information on the extent of this redundancy or the extent of maintenance 

activities that could be consolidated. We also have previously reported the 

existence of this problem.13

While the Army’s report provided an estimate of depot-level maintenance 

work that was not appropriately identified as such in fiscal year 2001, it 

acknowledged that the amount was incomplete and needed further 

validation. The report listed seven specific areas where depot-level 

maintenance work performed by nondepot facilities was not identified and 

estimated this amounted to be $188.6 million. As illustrated by table 1, 

most of the unidentified amount occurred in field-level facilities that 

perform depot-level maintenance tasks. According to the report, two 

categories of work accounted for about 75 percent of the $188.6 million. 

These were facilities that performed field-level maintenance under the 

National Maintenance Program14 with embedded depot tasks and those 

 13See GAO/NSIAD-00-20. 

14The National Maintenance Program is the Army’s ongoing action to establish a fully 

integrated national maintenance requirements process that includes all depot-level 

maintenance requirements, regardless of the location of the work in a field facility or a 

maintenance depot. 

Army’s 2003 

Proliferation Report 

Did Not Fully Identify 

Depot-Level 

Maintenance 

Performed outside 

Public Depots 

Estimate of Work outside 

Depots Is Incomplete 
Page 10 GAO-04-220 Army Depot Maintenance 

under One-Time Repair authorizations.15 The report pointed out that 

some of the unidentified depot-level maintenance work resulted from 

a misunderstanding between the Army Materiel Command and its 

subordinate commands over which organization would report this type 

of work. 

Table 1: Categories in Which Depot-Level Maintenance Work Was Not Identified in 

Fiscal Year 2001 

Category of work not identified Amount Percent 

1. The overhaul, upgrading, and rebuilding of equipment that met 

the definition of depot-level maintenance. $3.3 1.8 

2. Reimbursable depot support at the installation level. 22.4 11.9 

3. Maintenance covered by warranty associated with the purchase 

price of equipment. 4.0 2.1 

4. Field-level maintenance under the National Maintenance 

Program with embedded depot-level tasks. 75.9 40.2 

5. Contract support at a public depot. 10.4 5.5 

6. Maintenance tasks performed under Specialized Repair 

Authority. 7.6 4.0 

7. Maintenance tasks performed under One-Time Repair 

authorization at field-level facilities. 65.0 34.5 

Total $188.6 100.0 

Source: U.S. Army’s 2003 Proliferation Report. 

The report’s identification of unidentified depot-level maintenance work 

performed by nondepot facilities is consistent with our prior reviews of 

the Army’s annual 50-50 data. For example, in our most recent report, we 

identified work categories such as unreported one-time repair actions 

and unreported work by commands that did not receive Army reporting 

guidance, which contributed to the Army’s inability to fully account for its 

depot-level maintenance work in 2002.16 We noted that, as in past years, 

the Army did not fully identify public- and private-sector depot-level 

maintenance work at field locations as it continued unfinished efforts to 

consolidate maintenance activities and better control the proliferation of 

depot-level tasks at nondepot locations. While neither we nor the Army 

can precisely identify the amount of depot-level maintenance work being 

 15One-Time Repair actions are depot repairs that are accomplished at nondepot locations 

following an organization’s request and approval to do this work on a limited basis. 

16See GAO-03-1023. 
Page 11 GAO-04-220 Army Depot Maintenance 

performed in nondepot maintenance facilities, our prior work and the 

Army’s latest report suggest that the $188.6 million estimate should not be 

construed as fully representing the amount of depot-level maintenance 

work performed at nondepot facilities. 

The Army’s proliferation report pointed out that the Army’s maintenance 

infrastructure has redundant capabilities and capacities that could be 

consolidated and streamlined to be more cost-effective. While the active 

Army, Army National Guard, and Army Reserve operate extensive 

maintenance facilities, some of which have the capability and capacity 

to perform depot-level maintenance work, the report did not provide 

any data to quantify the extent of redundancy or identify any possible 

candidates for consolidation. It did suggest that the Army further study 

the issue for opportunities to streamline its current expansive depot-level 

maintenance infrastructure. Moreover, the Army’s full implementation of 

its National Maintenance Programanother report recommendationis 

also intended to address streamlining the Army’s maintenance 

infrastructure. 

While we did not attempt to identify the full extent of this maintenance 

infrastructure as part of this review, our analysis supports the Army 

report’s contention that the Army has extensive nondepot facilities, some 

of which have the capability and capacity for depot-level maintenance 

tasks and are performing depot-level maintenance work. At the Army sites 

we visited, we observed maintenance activities involved with all levels of 

maintenance for ground and aviation systems. Similar to the Army’s public 

depots, these activities occupied large facilities that included machine 

shops, automobile and heavy- equipment repair shops, paint and body 

shops, and sandblasting areas. The pictures in figure 2 show some contrast 

and similarities in maintenance facilities at depot and nondepot locations. 

Army Has an Extensive 

Maintenance 

Infrastructure, but 

Capacity for Depot 

Maintenance Activities at 

Nondepot Locations Has 

Not Been Fully Addressed 
Page 12 GAO-04-220 Army Depot Maintenance 

Figure 2: Various Army Maintenance Facilities 
Page 13 GAO-04-220 Army Depot Maintenance 

Some of the activities had the capability and capacity for depot-level 

maintenance activities and were performing depot-level maintenance 

work. For example, the Readiness Business Center at Fort Campbell, 

Kentucky, has been authorized to perform depot-level maintenance tasks 

to repair components for tactical wheeled vehicles, radios, and 

helicopters. Of the total $27.1 million maintenance work performed by the 

Business Center in fiscal year 2002, about $4.5 million, or about 17 

percent, was identified as depot-level maintenance. Also maintenance 

officials at several facilities at Fort Riley, Kansasthree of them operated 

by the National Guard, one by the Fort Riley Directorate of Logistics, one 

by the Forces Command, and one by the Army Reserveestimated that 

their maintenance work for fiscal year 2002 totaled about $58.5 million. 

The National Guard performed about $35 million worth of depot-level 

maintenance in fiscal year 2002 and expects this workload to significantly 

increase. More details on the Army’s maintenance infrastructure are 

provided in appendix II. 

We have previously reported on the Army’s proliferation of facilities that 

perform depot-level maintenance work and the lack of a strategic plan 

for depots to guide its decisions on this issue. In an October 1999 report, 

we pointed out that the Army’s April 1999 study of the proliferation 

of depot-level maintenance activities at nondepot facilities did not 

sufficiently identify the extent of this type work.17 We also highlighted that 

the Army’s study, citing inadequate data on the subject of proliferation, did 

not make any recommendations for consolidating depot-level maintenance 

facilities. We noted that a key challenge that the Army faced was 

determining and overseeing the amount of depot-level maintenance 

capabilities controlled by major commands in the active Army and the 

Army National Guard. For various reasons, these commands were 

reluctant to reduce their present capability for performing depot-level 

maintenance workloads. For example, Reserve and National Guard 

Bureau officials said that having local maintenance facilities capable of 

performing some depot-level tasks was a readiness issue in that such 

facilities allowed their units more rapid turnaround time on equipment 

requiring this type of repair. 

In July 2003 we reported that work performed in the Army’s public depots 

had declined by 36 percent from fiscal year 1987 through fiscal year 2002, 

 17See GAO/NSIAD-00-20. 
Page 14 GAO-04-220 Army Depot Maintenance 

while the total depot-level maintenance program grew.18 We pointed out 

that future workload projections indicated further decline but that the 

full impact of the Iraq conflict on future depot-level workload was largely 

unknown. Among the host of factors that contributed to this decline were 

(1) DOD’s policy for greater reliance on the private sector for depot-level 

support of new weapons systems and major upgrades and (2) its increased 

reliance on the use of regional repair activities and private-sector 

contractors for work that might otherwise be done in the depots. We 

noted that neither DOD nor the Army had a comprehensive and current 

depot-level maintenance strategic plan, which was an essential aspect of 

ensuring future depot efficiency and viability. 

Without complete information on the extent of depot-level maintenance 

work performed in nondepot facilities, DOD’s annual report to Congress 

cannot fully account for the allocation of depot-level maintenance funds 

between the public and private sectors. In our analysis of DOD’s 50-50 

reporting, we have said that underreporting depot work in nondepot 

facilities is one of the limitations affecting the Army’s ability to fully 

account for its depot-level maintenance work. Consistent with our work 

in this area, the Army’s report on proliferation identifies a number of 

factors that preclude the Army from fully capturing and reporting its 

depot-level maintenance data at nondepot facilities. These factors include 

(1) inconsistent application of the congressionally mandated definition 

of “depot maintenance” and related guidance, (2) weaknesses in the 

management information systems for collecting and reporting data, 

and (3) the failure to follow established policies and procedures for 

authorizing depot-level work at field-level facilities and outsourcing 

work. Our current analysis and our prior work identify these factors as 

underlying causes affecting the Army’s determination that it has 

complied with the 50-50 rule. Furthermore, these limitations will become 

more significant as the Army approaches the statutory ceiling on the 

performance of depot-level maintenance work by contract. 

 18See U.S. General Accounting Office, Depot Maintenance: Key Unresolved Issues Affect 

the Army Depot System’s Viability, GAO-03-682 (Washington, D.C.: July 7, 2003). 

Army Cannot Provide 

Congress with a 

Complete Accounting 

of Its Depot-Level 

Maintenance Work 
Page 15 GAO-04-220 Army Depot Maintenance 

We have reported in the past that by not having complete information on 

the amount of depot-level maintenance work being performed in nondepot 

facilities, DOD cannot provide Congress with an accurate and complete 

report regarding the allocation of depot-level maintenance between the 

public and private sectors as required by 10 U.S.C. 2466. For example, 

our September 2003 report stated that our prior 50-50 reports have 

documented continuing problems and shortcomings in accurately and 

consistently reporting depot-level maintenance accomplished by both 

public- and private-sector sources at nondepot locations.19 For example, 

one-time depot repair actions at unit-level facilities went unreported. 

Other nondepot work was not reported because some commands did not 

receive 50-50 instructions and others misapplied the guidance. Contractors 

performed some of this work, and military or civilian government 

employees performed some of it. While neither the Army nor we know 

the extent of unreported work nor the amount performed by public- and 

private-sector employees, the impact effectively limits the accuracy and 

completeness of DOD’s report to Congress on the allocation of depot-level 

maintenance funds between the public and private sectors. Additionally, 

as discussed below, both the Army and we have identified three key 

factors inhibiting the Army’s ability to accurately and completely report 

depot-level maintenance work performed at nondepot facilities. 

A key factor inhibiting the Army’s ability to accurately and completely 

identify all depot-level maintenance work performed in nondepot facilities 

in DOD’s 50-50 report is that Army military activities inconsistently apply 

the congressionally mandated definition of “depot maintenance.” The 

Army’s proliferation report concluded that the congressionally mandated 

definition of depot-level maintenance is not widely known below the 

major command headquarters. In addition, the definition is open to 

interpretation, and the reporting guidance is not always well defined. 

At most of the commands and installations we visited, maintenance 

officials said that, in determining whether a maintenance task is 

depot-level maintenance, they follow the guidance found in the 

Army’s Maintenance Allocation Charts; technical manuals; and source, 

maintainability, and recovery codes for reparable components rather 

than apply the congressionally mandated definition. They expressed 

concerns that the congressional definition is not always consistent with 

this guidance, is too broad, and is subject to too much interpretation over 

 19See GAO-03-1023. 

Underreported 

Depot-Level Work 

Performed by Nondepot 

Maintenance Facilities 

Affects Accuracy of 

50-50 Report 

Inconsistent Application of 

Depot-Level Maintenance 

Definition and 50-50 Guidance 
Page 16 GAO-04-220 Army Depot Maintenance 

what maintenance tasks should be counted as depot-level tasks. For 

example, officials at the National Guard Bureau said that applying the 

definition to repair work performed by direct support and general support 

activities caused uncertainty in that the bureau considered most of the 

work at these levels to be nondepot-level work and to identify what work 

should be considered depot-level work required subjective decisions. 

Officials at the Reserve Command said that, while only maintenance 

work defined by the Army’s technical manuals as depot-level work 

should be reported as such, under the expanded definition of depot-level 

maintenance, some work defined as below depot-level could involve 

depot-level tasks such as changing and swapping out engines and 

transmissions for wheeled vehicles. Officials at the installation 

maintenance sites we visited made similar comments. 

In commenting on the proliferation report, the Army Materiel Command 

said that the application of the definition of depot-level maintenance 

contributed to the report’s findings that depot-level maintenance tasks at 

nondepot facilities were being underreported. The command added that 

tasks performed by these facilities were not distinguished as depot-level 

tasks in the Army guidance but, in the aggregate, these tasks may be 

equivalent to depot-level maintenance. Finally, the command said that the 

Army could only approximate the extent of work performed at nondepot 

facilities because it currently does not have a system to precisely capture 

information on maintenance work for DOD’s 50-50 report. 

In prior reports, we have concluded that the Army had not revised its 

maintenance policies and technical manuals to reflect the expanded 

definition of depot-level maintenance and, as a result, any attempt to 

estimate its extent at local facilities would be misleading.20 We also 

recently reported that some Army commands did not receive 50-50 

instructions and that others misapplied the guidance.21 The Army’s 2003 

report indicates that the Army will have to make these changes in its 

maintenance policies and technical manuals. For example, in recognizing 

that the Army had not yet incorporated the expanded definition into its 

policies and procedures for 50-50 reporting, the Army’s report suggested 

that the Army (1) provide more explicit guidance for 50-50 reporting to 

help ensure that its commands better understood reporting requirements 

and (2) develop an easy-to-use reference guide to help the commands 

 20See GAO/NSIAD-00-20. 

21See GAO-03-1023. 
Page 17 GAO-04-220 Army Depot Maintenance 

better determine what maintenance work should be included in the 

50-50 report. 

Inadequate Army management information systems are a second key 

factor inhibiting the Army’s ability to fully capture depot-level 

maintenance work performed in nondepot facilities. The Army’s 

problems with its management information systems are longstanding. 

In a December 2000 report, the Army Logistics Transformation Agency 

concluded that the Army’s maintenance environment was characterized by 

many “stovepipe” information systems and application programs that are 

predominately fed data manually by maintainers and operators. It also 

concluded that a wide range of maintenance-related information does not 

exist, is not adequate, or is not accessible. In our prior reviews, we also 

have reported weaknesses in the Army’s management information system. 

For example, in our 1999 report, we concluded that deficiencies in 

management information systems contributed to the Army’s inability to 

develop accurate and consistent estimates of its depot-level maintenance 

work.22 In our September 2003 report on DOD’s compliance with the 50-50 

requirement, we found that the Army’s latest reporting on depot-level 

workloads for fiscal years 2001 and 2002 had utilized a new, more 

centralized financial system to collect 50-50 data.23 This new system helped 

correct some of the transcription errors we had found the previous year, 

but we continued to find errors, omissions, and inconsistencies in the 

Army’s data. 

The Army’s proliferation report concluded that current management 

information systems for capturing depot-level maintenance work at the 

installation level are inadequate for collecting and reporting 50-50 data. 

According to the report, the systems cannot, among other things, 

(1) archive the data in a readily accessible manner or (2) allow for the 

separate counting of multiple maintenance actions associated with a 

single work order. (A work order may include three different levels 

of maintenance, including depot-level maintenance, but only one 

maintenance code can be assigned to the order.) Also the report pointed 

out that collecting and reporting depot-level maintenance work outside the 

Army’s five public depots was a convoluted and manual process. 

 22See GAO/NSIAD-00-20. 

23See GAO-03-1023. 

Army’s Management 

Information Systems Are 

Inadequate 
Page 18 GAO-04-220 Army Depot Maintenance 

Another factor inhibiting the accuracy and completeness of the 50-50 

report is that policies and procedures for authorizing depot-level work in 

nondepot facilities are not always followed. The Army’s proliferation 

report made the same conclusion and identified several areas where 

reporting officials did not believe that maintenance facilities were 

following policies and procedures for authorizing and reporting depotlevel maintenance work. For example, the report noted that maintenance 

facilities at the installation level were undertaking depot-level 

maintenance work without having higher command authorization and that 

some authorized one-time repairs were not being reported. The report also 

concluded that some weapons systems managers were not following 

current DOD and Army guidance in determining sources for providing 

depot-level maintenance support. 

In a prior report related to DOD’s process for determining depot-level 

maintenance repair strategies for its new weapons systems and major 

upgrades, we noted that many weapons systems managers, including those 

in the Army, were not following existing guidance regarding such tasks as 

adequately performing required cost comparisons between public and 

private facilities and coordinating maintenance support decisions between 

acquisition and logistics officials.24 We noted that service officials 

attributed these problems, in large part, to weaknesses in guidance, which 

they believed was inadequate, unclear, and sometimes contradictory. 

As the Army moves closer to the statutory ceiling for the funding for 

depot-level maintenance work performed in the private sector, the 

limitations in the Army’s ability to precisely capture its depot-level 

maintenance work will become more significant. For fiscal year 2002, the 

Army’s reported data ($2.7 billion for the total program) indicated that its 

funding in the private sector for depot-level maintenance remained below 

the 50-percent limit. However, our adjustments for known errors in 

reporting for that year increased the percentage of private-sector work to 

49 percent from the 46.5 percent reported by the Army.25 An increase of 

more than 1 percent in the use of the private sector to perform more 

depot-level maintenance in the future, could cause the Army to exceed its 

 24See U.S. General Accounting Office, Defense Depot Maintenance: DOD Shifting 

More Workload for New Weapon Systems to the Private Sector, GAO/NSIAD-98-8

(Washington D.C.: Mar. 31, 1998). 

25See GAO-03-1023. 

Policies and Procedures for 

Authorizing Work Are Not 

Always Being Followed 

Limitations More 

Significant for Future 

Assessment of 50-50 

Compliance 
Page 19 GAO-04-220 Army Depot Maintenance 

statutory limitation. Consequently, the Army would be required to seek a 

national security waiver and notify Congress as provided for in 10 U.S.C. 

2466(b).26

With regard to estimates of future compliance, the Army’s report noted 

that the Army might exceed the 50 percent ceiling for contractor support 

by fiscal year 2006. More recently, an official from the Army Materiel 

Command said that, for fiscal years 2002 and 2003, the Army experienced 

a 3 to 5 percent increase in its contract requirements for depot-level 

maintenance because increased operational requirements made the public 

depots unable to meet the total demand for depot-level maintenance work. 

She pointed out that, if this trend were to continue, the Army might have 

to seek a waiver from the Secretary of Defense, possibly as early as fiscal 

year 2004, to exceed the 50 percent limitation for work performed by the 

private sector. Another official at the Army Materiel Command said that 

the Army’s depot-level maintenance work in 2004 might increase by about 

$2.5 billion because of operational requirements for Army equipment 

deployed in the Middle East. He also said that, in an effort to keep up with 

maintenance demands, the Army’s five public depots have used extensive 

overtime, added second work shifts, hired temporary employees, and 

allowed some retirees to return to work. In his view, the public depots 

could not meet the demands of the increased maintenance work and the 

Army would have to use more contractors. 

The Army report’s recommendations are focused on key problem areas 

and are consistent with recommendations we have made in the past. If 

fully implemented, the recommendations in the Army’s proliferation report 

could improve the identification of additional depot-level maintenance 

work in nondepot facilities, and the accuracy and completeness of 50-50 

reporting. Efforts have been undertaken to address some of the problem 

areas; however, no action plan to manage the implementation has been 

developed. Evaluating the success of the proposed 29 recommendations 

will be difficult until the Army develops an action plan with priorities, time 

frames, responsible organizations, evaluation criteria, and the resources 

required to implement these recommendations. If actions are not 

implemented in a timely way, the Army will not likely have the 

 2610 U.S.C. 2466(b) provides that the Secretary of Defense may waive the 50 percent 

limitation if the Secretary determines that a waiver is necessary for reasons of national 

security and notifies Congress regarding the reasons for the waiver. 

Army Needs Action 

Plan to Address 

Proliferation and 

Reporting Issues 
Page 20 GAO-04-220 Army Depot Maintenance 

comprehensive information that it needs in the near term to comply with 

the 50-50 reporting requirements or to effectively manage the existing 

excess maintenance capabilities and infrastructure. On the other hand, the 

extent of improvements likely to be achieved in the long term is uncertain, 

given previous delays and the significant challenges that the Army faces in 

instituting solutions to ensure the consistent application of 50-50 reporting 

criteria. 

The Army report’s recommendations present an array of corrective 

measures that are focused on four key areas in which the Army could 

better evaluate the proliferation of depot-level maintenance facilities 

and manage its depot-level maintenance program. Appendix III lists the 

29 recommendations. Basically, the key areas represent a need for 

the following: 

• Improved communication and emphasis for the 50-50 requirement. 

The 14 recommendations in this area address improving the 50-50 

process. They include conducting annual 50-50 workshops, issuing 

clear guidance for 50-50 reporting, publicizing information about the 

depot-level maintenance program in professional publications, 

ensuring that compliance with the 50-50 rule becomes a priority, and 

developing an easy-to-use reference guide to help reporting activities 

better identify depot-level maintenance work that should be reported. 

• Improved management information systems. The three 

recommendations in this area address continuing efforts to develop a 

single integrated management information system capable of capturing 

and reporting depot-level maintenance work at nondepot facilities. 

• Enhanced compliance with policies and procedures for depot-level 

maintenance operations. The nine recommendations in this area 

address revising policies to ensure consistency in compliance with all 

applicable legislation, regulations, and policies; developing a policy 

requiring the acquisition of access to system technical data for use by 

government or other contract maintenance activities; and developing 

and implementing a plan for documenting baseline data to compare 

contractor and public depot support costs. 

• Develop the National Maintenance Program and consolidate 

maintenance activities. The three recommendations in this area 

address efforts to develop the National Maintenance Program and to 

conduct further analyses to identify opportunities for consolidating 

depot-level maintenance facilities. 

Recommendations Are 

Focused on Key Problem 

Areas 
Page 21 GAO-04-220 Army Depot Maintenance 

Of the Army proliferation report’s 29 recommendations to improve the 

identification and reporting of depot-level maintenance data, 3 were 

specifically directed toward managing the proliferation of depot-level 

maintenance at nondepot facilities. One of the recommendations identified 

the need for additional study and identification. 

The proliferation report’s recommendations are consistent with our prior 

recommendations regarding the Army’s proliferation of depot-level 

maintenance facilities and the 50-50 reporting process. For example, in 

September 2003, we recommended that the 50-50 reporting guidance be 

appropriately disseminated to reporting organizations and individuals and 

that staff be properly trained in a timely way to apply the guidance.27 In 

October 1999, we recommended that the Army address the following 

challenges:28

• Improving its management information systems. Our 

recommendation was that the Army identify requisite action items, 

time frames, and funding requirements for improving the Army’s 

information management systems to fully identify the magnitude and 

cost-effectiveness of depot-level maintenance work at various locations 

within the Army. 

• Finding opportunities to consolidate maintenance activities. We 

recommended that the Army establish (1) clear time frames and action 

plans for assessing requirements for the various types of depot-level 

maintenance facilities and (2) plans for achieving necessary 

consolidations and reductions of excess capabilities. 

• Enhancing the National Maintenance Program. We recommended 

that the Army incorporate the depot-level maintenance capabilities of 

both active and reserve components under the National Maintenance 

Program and assign the national maintenance manager with requisite 

responsibility and authority for depot-level maintenance capabilities in 

active and reserve facilities. 

 27See GAO-03-1023. 

28See GAO/NSIAD-00-20. 

Recommendations 

Consistent with Our 

Prior Work 
Page 22 GAO-04-220 Army Depot Maintenance 

While we made these recommendations 4 years ago, they continue to be 

essential to addressing the problems of the proliferation of depot-level 

maintenance facilities and inaccuracies in 50-50 reporting. 

The Army’s 2003 report noted that the Army had taken numerous steps 

since 1999 to improve its management of the proliferation of depot-level 

maintenance facilities and its 50-50 data. However, the report pointed 

out that the Army needed to implement the report’s recommendations 

before it can claim with complete confidence that it is meeting the 50-50 

requirement. Headquarters officials responsible for the report told us 

that the Army maintenance organizations concurred with the report’s 

recommendations. The Army has already begun implementing some of its 

report’s recommendations such as holding annual workshops and revising 

its guidance to include the congressional definition of depot-level 

maintenance. However, it has not yet developed an overall action plan for 

managing the implementation of all of the recommendations and, in 

particular, for setting priorities for the more-critical recommendations. 

As the report indicates, corrective actions are essential to improving 

the Army’s ability to better manage the proliferation of maintenance 

facilities and capture data for 50-50 reporting. Some of the critical 

recommendations, such as the need to identify opportunities for 

consolidating depot-level maintenance facilities, set up a single integrated 

management information system capable of capturing all depot-level 

maintenance data, and develop a National Maintenance Program to better 

manage depot-level maintenance work have been in process for several 

years. Thus, the identification of specific actions would appear 

necessary to help the Army accomplish the implementation of these 

recommendations more timely. A plan would include (1) the Army’s 

priority for implementing the recommendations, (2) the Army 

organizations accountable for implementation, (3) the specific time frames 

for accomplishment, (4) whether the benefits of accomplishment support 

the cost of implementation, (5) the funding required and the source of 

funds, and (6) the criteria to determine the effectiveness of the 

recommendations once they are implemented. 

Officials at the Army Communications-Electronics Command said that 

streamlining maintenance facilities is a good idea, but they do not have the 

tools that would enable the command to fully implement the proliferation 

report’s recommendations in this area. They said that updating Army 

Regulation 750-1 (Army Materiel Maintenance Policy) and conducting 

50-50 workshops were a step in the right direction, but that both actions 

Although Some Efforts Are 

Ongoing, Action Plan Not 

Yet Developed to Ensure 

Implementation of 

Recommendations in a 

Timely Manner 
Page 23 GAO-04-220 Army Depot Maintenance 

need to be more comprehensive in educating field-level personnel 

on policy and requirements. For example, they pointed out that just 

reiterating the congressional definition of depot-level maintenance 

in Army Regulation 750-1 did little to add clarity to the definition. 

Additionally, the last two workshops were spent largely on training for the 

Depot Maintenance Operations Planning System, a new system to be used 

by all Army major commands and acquisition managers to capture and 

report annual 50-50 workload data. According to these personnel, this 

system appears extremely complex and training should be aimed at those 

who are actually responsible for reporting maintenance data. Officials at 

the National Guard Bureau generally disagreed that the Army report’s 

recommendations will ensure accurate 50-50 reporting—especially in view 

of the apparent disconnect between the recommendations and the Army’s 

maintenance transformation process, and the Army’s plans for moving to 

two-level maintenance.29

Army Communications-Electronics Command officials also suggested 

that, for timely and effective implementation, the Army establish a 

working group of representatives with subject matter expertise from all 

levels within the Army to oversee the implementation. Officials at Army 

headquarters who were responsible for the report told us that they did not 

yet have a formal action plan established. They said they were planning 

to establish a working group in December 2003 to review the 

recommendations and determine what actions needed to be taken. 

As previously discussed the Army has taken steps to improve its 

management of the proliferation of depot-level maintenance facilities 

and its 50-50 reporting. The Army’s 2003 report and our analysis 

indicate that some of the key actions related to improving the Army’s 

long-standing issues in effectively identifying the proliferation of 

depot-level maintenance facilities and improving its 50-50 reporting 

have been in process for several years. The magnitude of long-term 

improvements likely to be realized remains uncertain, given prior delays in 

instituting solutions and the inconsistent understanding and application of 

50-50 reporting criteria. 

 29The Army plans to reduce the size of its logistics infrastructure by combining the current 

levels of maintenance into two levels: field-level, which will be “repair and return to user,” 

and sustainment-level, which will be “repair and return to supply.” 

Long-term Improvements 

in 50-50 Reporting May 

Remain Problematic 
Page 24 GAO-04-220 Army Depot Maintenance 

During our review, we observed that several actions related to the 

recommendations had been under way for a number of years but that 

completion dates had slipped and funding had become uncertain. For 

example, the recommendation that the Army continue efforts to establish 

a fully integrated national maintenance requirements determination 

process that includes all depot-level maintenance requirements refers to a 

program known as the National Maintenance Program. The Army initiated 

the program in July 1999 and planned to implement it by fiscal year 2004. 

However, full implementation has slipped to fiscal year 2006. Additionally, 

required funding to complete the program is uncertain. Army Materiel 

Command officials said that the program’s goal is to centrally coordinate 

and control depot-level maintenance work by developing standards for 

items being repaired at qualified repair sources. They said that (1) the 

program is helping to better identify and manage facilities that perform 

depot-level maintenance outside the public depots; (2) the number of 

maintenance facilities in the program has declined from 60 in fiscal year 

2000 to 45 in fiscal year 2003, and these are expected to further decline to 

25 in fiscal year 2005 as the Army decides which facilities will be qualified 

to perform depot-level maintenance work; and (3) the command was 

working with other commands to reduce the number of nondepot 

maintenance facilities. 

Full implementation of the National Maintenance Program appears to be 

a key initiative in addressing the proliferation of depot-level maintenance 

facilities. At the same time, our analysis indicates that, although the 

concept of the National Maintenance Program could help improve future 

annual reporting and eliminate some of the current fragmented and 

duplicative depot-level maintenance workload assignments, it is too early 

to assess the program’s full impact. The extent to which the program can 

resolve all the problems related to the proliferation and inaccurate and 

incomplete identification of depot-level maintenance work performed 

in nondepot facilities is unclear. The Army’s 2003 report noted that the 

Army’s schedule for completing the implementation of the National 

Maintenance Program has slipped to fiscal year 2006. During our review, 

we noted that, as of October 2003, the Army had completed standards for 

only 737about 18 percentof the 4,148 candidates for the program. 

While an estimated development cost of about $120 million has already 

been spent, the Army is a long way from having the required standards that 

are needed for the program. An Army Materiel Command official said that 

the Army was not planning to provide any additional funding for the 

further development of these standards. 
Page 25 GAO-04-220 Army Depot Maintenance 

In a prior report, we observed that, while the program is intended to 

consolidate and distribute overhaul work for components returned to the 

supply system, the evolving management framework will continue to allow 

local maintenance facilities to repair items returned directly to using 

organizations—maintenance-to-maintenance transactions that could meet 

the statutory definition of depot-level maintenance.30 Additionally, the 

program did not include some other depot-level maintenance work. For 

example, it does not address the allocation of depot-level maintenance 

requirements for overhauling, rebuilding, or upgrading major end items 

such as tactical wheeled vehicles that are currently being overhauled in 

field-level maintenance facilities or by contracts managed by field-level 

organizations even though this work meets the statutory definition of 

depot-level maintenance work. 

With regard to resolving deficiencies in management information systems, 

it is uncertain when the required changes that will be capable of capturing 

and reporting depot-level maintenance workloads performed in nondepot 

facilities will be operational. In October 2003, the Army began testing the 

transition of its database for Specialized Repair Authority and One-Time 

Repair authorizations into an automated system referred to as the Joint 

Computer-Aided Acquisition and Logistic Support system.31 The Army’s 

2003 report described this as an interim initiative to capture and report on 

maintenance work performed under these two types of authorizations. 

While this initiative will automate the capturing of this work, it will not 

identify all depot-level maintenance work that may be performed in fieldlevel facilities. For example, it will not capture depot-level maintenance 

actions performed on equipment that will be returned directly to the user 

without going through the Army’s supply system. A single integrated 

management information system is hoped for when the Army’s evolving 

Logistics Modernization Program is fully implemented. Testing at the first 

site, the Tobyhanna Army Depot, is ongoing, but problems have occurred. 

Earlier estimates of completion are about 18 to 24 months, but some 

 30See GAO/NSIAD-00-20. 

31The Joint Computer-Aided Acquisition and Logistic Support system is a multiservice 

program for developing the infrastructure to logistically support weapons systems 

throughout their life cycle. 
Page 26 GAO-04-220 Army Depot Maintenance 

delays are expected.32 Additionally, to what extent it will resolve all the 

deficiencies in the current systems is uncertain. 

We believe that the Army’s implementation of our prior recommendations, 

as well as the recommendations made in the Army’s proliferation report, 

are essential to providing the Army with more precise information for 

crucial decisions in the area of the Army’s depot-level maintenance 

infrastructure. Their timely and effective implementation depends largely 

on the necessary emphasis from senior Army leadership. If actions are 

not implemented in a timely manner, the Army will unlikely have the 

comprehensive information that it needs to determine the extent of 

proliferation and effectively manage its excess capabilities and the 

infrastructure it has—key data needed for complying with the existing 

reporting statute, identifying excess infrastructure and making appropriate 

consolidations, and making appropriate decisions for an additional round 

of base realignments and closures that has been authorized for 2005. 

The Army has not yet developed a plan for implementing the 

recommendations in the Army proliferation report. We believe it is 

essential that the Army have such a plan to help ensure the timely and 

effective implementation of the recommendations. Such a plan would 

include evaluating the priority for implementation and identifying the 

time frame for implementing the recommendations, the responsible 

organizations, and the criteria for measuring the desired results. 

While improvements should be accomplished, the complexity and 

vastness of the Army’s maintenance system and continuing questions 

about such issues as the definition of depot-level maintenance and 

changing maintenance strategies could continue to present challenges 

in fully recording all depot-level maintenance work. 

 32In July 2002, the Army changed the name of this program from the Wholesale Logistics 

Modernization Program to the Logistics Modernization Program. This is a new information 

system that is intended to help manage the Army’s supply, maintenance, and transportation 

functions. Beginning in July 2003, the Logistics Modernization Program will replace many 

of the Army’s old logistics information systems. 

Conclusions 
Page 27 GAO-04-220 Army Depot Maintenance 

To ensure the timely and effective implementation of the 

recommendations in the Army’s 2003 proliferation report to help the 

Army improve its management of maintenance operations, including the 

proliferation of depot-level maintenance facilities, and more precisely 

capture and report depot-level maintenance data, we recommend that the 

Secretary of the Defense direct the Secretary of the Army to establish a 

specific plan to manage the implementation of the 29 recommendations 

identified in the 2003 proliferation report. The plan should include the 

priority and time frames for implementation, the responsible organizations 

for implementing the plan, and the criteria for measuring success. 

The Department of Defense provided written comments (see app. IV) on a 

draft of this report. In commenting on the draft, the Office of the Deputy 

Undersecretary of Defense for Logistics and Materiel Readiness concurred 

with our recommendation that the Army establish a plan to manage the 

implementation of the 29 recommendations identified in the 2003 depot 

maintenance proliferation report. The Department noted that the Army is 

in the process of establishing an integrated product team to develop an 

action plan to address the 29 recommendations to include reevaluating the 

validity and modifying the recommendations where appropriate. The 

Department also stated that the Army expects to have an action plan in 

place no later than March 31, 2004. The Department’s response noted 

specifically that the recommendation contained in the Army’s report 

related to the designation of core work needs to be revised. We recognize 

that some adjustment to the recommendations may be necessary as the 

implementation plan is developed. Whether some recommendations 

require modification for implementation is not as significant for the Army 

as is the need for timely action and follow through to address the issues 

identified in the Army’s depot maintenance proliferation report. 

We are sending copies of this report to interested congressional 

committees; the Secretary of Defense; the Secretary of the Army; and the 

Director, Office of Management and Budget. We will make copies available 

to others upon request. In addition, the report will be available at no 

charge on the GAO Web site at http://www.gao.gov. 

Recommendation 

Agency Comments 

and Our Evaluation 
Page 28 GAO-04-220 Army Depot Maintenance 

If you or your staff have questions regarding this report, please contact me 

at (202) 512-8412 or holmanb@gao.gov or Julia Denman, Assistant 

Director, at (202) 512-4290 or denmanj@gao.gov. Other major contributors 

to this report were Nancy Benco, Wayne Gilliam, and Bobby Worrell. 

Barry W. Holman 

Director, Defense Capabilities 

 and Management 
Appendix I: Scope and Methodology 

Page 29 GAO-04-220 Army Depot Maintenance 

To answer the Senate and House Committees on Armed Services mandate 

contained in Report of the Committee on Armed Services, House of 

Representatives, Floyd D. Spence National Defense Authorization Act for 

Fiscal Year 2001, we reviewed the Army’s Fiscal Year 2002 Study of the 

Proliferation of Depot Maintenance-Type Activities Phase II Report, dated 

July 31, 2003. We interviewed Army officials and analyzed pertinent 

information regarding that report at (1) Army Headquarters in the 

Washington, D.C., area; (2) Headquarters, Army Materiel Command in 

Alexandra, Virginia; (3) three subordinate commands—the Army Aviation 

and Missile Command, Huntsville, Alabama; Communications-Electronics 

Command, Fort Monmouth, New Jersey; and the Tank-automotive and 

Armaments Command, Warren, Michigan; (4) Headquarters, National 

Guard Bureau, Arlington, Virginia; (5) Headquarters, Army Forces 

Command, Atlanta, Georgia; and (6) Headquarters, Army Reserve 

Command, Atlanta, Georgia. Also, we interviewed managers and 

reviewed pertinent information regarding maintenance facilities located at 

Fort Campbell, Kentucky; Fort McCoy, Wisconsin; Fort Riley, Kansas; and 

Fort Rucker, Alabama. We made extensive use of our prior work related to 

Army depot-level maintenance. 

To determine the extent to which the Army’s report identified the total 

amount of depot-level maintenance work performed at nondepot facilities, 

we examined the requirements of section 2466 of title 10, U.S. Code, and 

Army regulatory provisions for 50-50 reporting. We analyzed the report’s 

scope and methodology, findings, and disclosure of the amount it 

identified and compared these data with our prior work done on the 

Army’s annual 50-50 reporting process. We interviewed the study group 

manager, Army officials, and maintenance managers about the nature of 

maintenance work performed by nondepot facilities and about whether it 

was being reported as required. Because the Army has no central database 

or readily available data, we did not attempt to determine the Army’s 

universe of facilities that perform depot-level maintenance. 

To answer whether the Army can accurately account for its depot-level 

maintenance workloads and the key issues that preclude accurate 

reporting, we examined the report’s findings to determine what areas were 

identified as contributing problems. We used our prior work on the Army’s 

depot-level maintenance program to correlate, compare, and test the 

consistency of the identified problems with the ones we had previously 

reported. We interviewed the study group manager, Army officials, and 

maintenance personnel about the relevancy of the findings and the 

application to the Army’s depot-level maintenance operations. 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 30 GAO-04-220 Army Depot Maintenance 

To answer whether the corrective actions identified in the Army’s report 

are likely to address the proliferation issue and enhance the Army’s 

reporting, we examined the recommendations to determine how 

effectively they were linked to the identified problems. We also compared 

the recommendations with those that we had previously made to test for 

consistency. Finally, we discussed the relevancy of the recommendations 

with the study group manager, Army officials, and maintenance 

representatives. 

We conducted our analysis of the Army’s report from July through 

October 2003 in accordance with generally accepted government 

auditing standards. 
Appendix II: Army Maintenance Sites 

Page 31 GAO-04-220 Army Depot Maintenance 

The Army operates a number of maintenance facilities and has an 

extensive infrastructure for the maintenance of its military weapons 

systems and support equipment. For example, as we reported in April 

2003, the Army employs about 10,000 personnel at its five public depots 

to overhaul, repair, and upgrade its ground and air combat systems, 

subsystems, and assemblies.1

 The Army also has a vast number of other 

maintenance facilities operated by U.S. government-employed civilians 

and contractors. For example, we reported in October 1999 that the 

Army had another 102 maintenance facilities that were potential 

providers of depot-level maintenance services within the continental 

United States—28 active Army, 2 Army Reserve, and 72 Army National 

Guard.2

In addition, the Army operates maintenance activities that provide 

maintenance below the depot level. For example, as of August 2003, 

the Forces Command reported that it had maintenance facilities at 

10 installations that provide direct support for vehicle maintenance; the 

Army reserve had about 160 maintenance facilities located throughout the 

United States that perform unit, direct, and general maintenance support; 

the National Guard had additional maintenance facilities performing unit 

and direct support maintenance; and Army installations had a number of 

maintenance facilities that perform various levels of maintenance. 

We visited 17 of the Army, Army Reserve, and Army National Guard 

maintenance sites. These 17 sites performed maintenance work valued 

at more than $500 million during fiscal year 2002; employed more than 

4,700 military, civilian, and contractor personnel; and occupied facilities 

with more than 2 million square feet. Table 2 provides summary capacity 

and capability information about the sites. 

 1

See U.S. General Accounting Office, DOD Civilian Personnel: Improved Strategic 

Planning Needed to Help Ensure Viability of DOD’s Civilian Workforce, GAO-03-472

(Apr. 30, 2003). 

2

See GAO/NSIAD-00-20. 

Appendix II: Army Maintenance Sites 
Appendix II: Army Maintenance Sites 

Page 32 GAO-04-220 Army Depot Maintenance 

Table 2: Capacity and Capability Information on 17 Sites That GAO Visited 

Dollars in millions 

Installation Organization 

Government and 

contractor staff 

Facility size in 

square feet

Fiscal year 2002 

maintenance 

Capability to 

perform depot 

maintenance 

Fiscal year 

2002 depot 

maintenance 

 

Readiness Business 

Center 

308 195,249 $27.1 Yes $4.5a

Forces Command CMF 188 8,000 10.0 No None 

Fort Campbell, 

Kentucky 

National Guard UTES 19 14,675 .9 No None 

Reserve IMMA 202 140,000 4.9 Yes .7b

Reserve ECS 113 198,656 1.8 No None 

Fort McCoy, 

Wisconsin 

National Guard MATES 31 92,000 .5 Yes .05b

DOL 112 255,000 12.4 Yes 2.4c

Forces Command CMF 71 53,716 2.1 No None 

National Guard RSMS 142 88,612 14.1 Yes 14.1 

National Guard ATEAM 90 75,070 20.9 Yes 20.9d

National Guard MATES 89 123,000 6.7 Yes .6b

Fort Riley, 

Kansas 

Reserve ECS 78 14,040 2.3 No None 

ACLC 3,217 732,224 418.5 Yes 16.8e

DEL 22 3,000 2.5 No None 

ATSCOM 52 41,000 2.4 Yes .4 

National Guard UTES 14 16,664 1.5 No None 

Fort Rucker, 

Alabama 

Reserve ECS 15 4,000 .5 No None 

Sources: Fort Campbell, Kentucky: Readiness Business Center, Forces Command CMF, National Guard UTES; Fort McCoy, Wisconsin: Reserve IMMA, Reserve ECS, National Guard MATES; 

Fort Riley, Kansas: Forces Command CMF, National Guard RSMS, National Guard ATEAM, National Guard MATES, Reserve ECS; and Fort Rucker, Alabama: ACLC, DEL, ATSC, National Guard UTES, 

Reserve ECS. 

a

Data represent National Maintenance Program and Specialized Repair Authority. 

b

Data represent National Maintenance Program. 

c

Data include National Maintenance Program and One-Time Repairs. 

d

Data include Specialized Repair Authority. 

e

Data include National Maintenance Program, Specialized Repair Authority, and One-Time Repairs. 

Legend 

ACLC (Aviation Center Logistics Command)This organization, which reports to the Aviation and 

Missile Command, performs all levels of aviation maintenance in support of Fort Rucker’s flighttraining program. A contractor performs this maintenance work. 

ATSCOM (Air Traffic Services Command), a newly formed organization, provides worldwide direct, 

general, and limited depot-level maintenance for air traffic control systems. The maintenance data 

reported represents two components—F Company of the 58th Aviation Regiment and the Air Traffic 

Control Activity. 
Appendix II: Army Maintenance Sites 

Page 33 GAO-04-220 Army Depot Maintenance 

CSMS (Combined Support Maintenance Shop)Army National Guard facilities that provide direct 

support and general support levels of maintenance for National Guard surface equipment (trucks, 

tanks, etc.). 

DEL (Directorate of Engineering and Logistics)A Fort Rucker organization that performs 

organizational support, direct support, and general support for vehicles, construction equipment, and 

fire-fighting equipment. A contractor performs this maintenance work. 

DOL (Directorate of Logistics)Fort Riley organization that performs general support maintenance 

for tanks, trucks, construction equipment, small arms, etc. It also provides limited organizational and 

aviation intermediate maintenance. A contractor performs this maintenance work. 

Forces Command CMF (Forces Command Contractor Maintenance Facility)These maintenance 

facilities report to Forces Command and perform organizational and direct support maintenance on 

items such as trucks, trailers, tracked vehicles, vans, and generators. Contractors perform the 

maintenance work. 

National Guard ATEAM (Advanced Turbine Engine Army Maintenance)This Army National Guard 

facility rebuilds M1A1 tank engines. Its work, which is considered depot-level maintenance, is limited 

to National Guard assets. 

National Guard MATES (Maneuver Area Training Equipment Site)Army National Guard 

maintenance facilities that provide unit, direct support, and general support maintenance for assigned 

equipment. These sites are established to preposition selected items of equipment and are located at 

or near a training area. 

National Guard RSMS (Readiness Sustainment Maintenance Site)This National Guard facility at 

Fort Riley rebuilds 5-ton cargo trucks and trailers. Its work, which is considered depot-level 

maintenance, is generally limited to National Guard assets. Employees of the state of Kansas perform 

the work. 

National Guard UTES (Unit Training and Equipment Site)A National Guard facility that stores and 

performs organizational maintenance on tracked and wheeled vehicles for National Guard units within 

a specific geographic area. 

Readiness Business CenterA Fort Campbell organization that performs general support 

maintenance for wheeled vehicles and intermediate and limited depot-level maintenance for 

helicopters. Contractors perform the maintenance work. 

Reserve ECS (Equipment Concentration Site)Army Reserve facilities that store and maintain 

selected equipment for Army Reserve units in a specific geographic area. The maintenance work is 

performed by both government and contractor employees. 

Reserve IMMA (Army Reserve Installation Materiel Maintenance Activity)The facility provides 

organizational, direct, and general support maintenance for tactical vehicles—High Mobility Multipurpose Wheeled Vehicles, trucks, trailers—for Army Reserve units located at or near Fort McCoy. 

For the most part, contractor employees perform the maintenance work. 
Appendix III: Army Report’s Issues and 

Recommendations 

Page 34 GAO-04-220 Army Depot Maintenance 

The Army’s Fiscal Year 2002 Study of the Proliferation of Depot 

Maintenance-Type Activities identified 7 issues and made 

29 recommendations for the following improvements to enhance the 

Army’s ability to (1) evaluate the proliferation of nondepot facilities 

that perform depot-level maintenance and (2) identify and report on 

its 50-50 data. These recommendations were consistent with our 

prior recommendations—noted in referenced GAO products. 

Issue 1: Title 10 Definition of Depot Maintenance and 50-50 Reporting 

Policy Guidance

Recommendations: 

• Post the new Army Regulation 750-1 as soon as possible to the Army 

Publications Agency Web site. Posting the regulation will contribute to 

the education of Army activities on the congressional definition of 

“depot maintenance” and the 50-50 reporting process. 

• Continue to conduct annual 50-50 workshops and issue clear guidance 

regarding depot maintenance policies to major commands, program 

executive officers, and program managers. 

• Use Headquarters, Department of the Army, senior-level maintenance 

boards to communicate depot maintenance policies. 

• Publish depot maintenance information articles in professional 

publications. 

[See also GAO-03-1023; U.S. General Accounting Office, Depot 

Maintenance: Key Unresolved Issues Affect the Army Depot System’s 

Viability, GAO-03-682 (Washington, D.C.: July 7, 2003); and U.S. General 

Accounting Office, Depot Maintenance: Change in Reporting Practices 

and Requirements Could Enhance Congressional Oversight, GAO-03-16

(Washington, D.C.: Oct. 18, 2002).] 

Issue 2: Accuracy of Army’s Current 50-50 Reports

Recommendations 

• The Army Deputy Chief of Staff (G-4) should ensure that compliance 

with the 50-50 rule becomes an Army priority and that command 

emphasis is applied to correct all reporting problems. 

• Army G-4 should submit an amended 50-50 report for fiscal year 2002. 

Appendix III: Army Report’s Issues and 

Recommendations 
Appendix III: Army Report’s Issues and 

Recommendations 

Page 35 GAO-04-220 Army Depot Maintenance 

• Army G-4 should include all Army major commands, program executive 

offices, and separate commands in the 50-50 reporting process. 

[See also GAO-03-1023; U.S. General Accounting Office, Depot 

Maintenance: Workload Allocation Reporting Improved, but Lingering 

Problems Remain, GAO/NSIAD-99-154 (Washington, D.C.: July 13, 1999); 

and U.S. General Accounting Office, Depot Maintenance: Management 

Attention Required to Further Improve Workload Allocation Data, 

GAO-02-95 (Washington D.C.: Nov. 9, 2001).] 

Issue 3: Specialized Repair Authority and One-Time Repair Workload 

Reporting Requirements

Recommendations 

• Army G-4 should provide applicable major commands with immediate 

and specific guidance to reinforce compliance with current Specialized 

Repair Authority and One-Time Repair policies. Strong emphasis 

should be placed on collecting One-Time Repair data for 50-50 

reporting purposes. 

• Current policy and procedures regarding the approval and tracking of 

One-Time Repair should be expanded in Army Regulation 750-1. 

• Major commands should appoint an installation or local Specialized 

Repair Authority coordinator to ensure that (1) all major command 

facilities at an installation are provided the most current information 

on Specialized Repair Authority and One-Time Repair policies and 

(2) the appropriate Specialized Repair Authority and One-Time Repair 

production data are submitted properly through the installation or 

local regional major command Specialized Repair Authority 

coordinator to the major command headquarters. Similarly, the 

National Guard Bureau should appoint Specialized Repair Authority 

coordinators for each state, territory, and the District of Columbia. 

• Army G-4, in coordination with the Army Materiel Command (AMC), 

should direct the Aviation and Missile Command to terminate the 

existing Aviation Repair Authority process and immediately comply 

with all Headquarters, Department of Army, Specialized Repair 

Authority policies. 

[See also U.S. General Accounting Office, Depot Maintenance: Change in 

Reporting Practices and Requirements Could Enhance Congressional 

Oversight, GAO-03-16 (Washington D.C.: Oct. 18, 2002).] 
Appendix III: Army Report’s Issues and 

Recommendations 

Page 36 GAO-04-220 Army Depot Maintenance 

Issue 4: Army G-4 Guidance Regarding Depot Maintenance Reporting 

Procedures

Recommendations 

• Army G-4 should revise the 50-50 standard operating procedures to 

provide the major commands, program executive officers, and program 

managers with more explicit guidance regarding those 50-50 reporting 

requirements that are still causing confusion, 

• Army G-4 should coordinate with major commands, program executive 

officers, and program managers to ensure that the standard operating 

procedure revisions are clearly understood and that the 50-50 standard 

operating procedures address the upgrade and modification programs. 

• Army G-4 should develop a “decision tree” (an easy-to-use reference 

guide) to better distinguish between those programs that should be and 

should not be reported. 

[See also GAO-02-95 and GAO/NSIAD-99-154.] 

Issue 5: Impact of National Maintenance Program on 50-50 Reporting 

Processes Below Public Depot Level

Recommendations 

• AMC should continue efforts to establish a fully integrated national 

maintenance requirements determination process that includes all 

depot maintenance requirements. 

• The Army should complete the implementation of the National 

Maintenance Program by fiscal year 2006 as currently planned. 

• The Army should conduct further analyses to identify opportunities for 

consolidating depot-level maintenance activities. 

[See also GAO/NSIAD-00-20.] 

Issue 6: Management Information System Requirements for Improving 

Current Methods of Capturing and Reporting 50-50 Data

Recommendations 

• The Army should develop an integrated management information 

system capable of capturing and reporting depot maintenance 

workloads below the organic depot level. AMC should consider 
Appendix III: Army Report’s Issues and 

Recommendations 

Page 37 GAO-04-220 Army Depot Maintenance 

replacing the interim Specialized Repair Authority business 

systemthe combined Joint Computer-Aided Logistics Support 

System/Logistics Integrated Database/Army Electronic Product 

Support Systemswith a single integrated Specialized Repair 

Authority tracking and workload system through the development of 

the Logistics Modernization Program and as the various major 

command feeder systems are either replaced or consolidated by way of 

the development of the Global Combat Support System-Army. 

• Army G-4 should query AMC’s Logistics Integrated Database monthly 

to ensure that major command activities are using the new Department 

of the Army Pamphlet 738-750 maintenance codes for inputting 

workload data into automated systems to account for Specialized 

Repair Authority and One-Time Repair tasks embedded in maintenance 

workloads at the installation level. 

• Army G-4 should continue to support AMC’s efforts to develop a 

Maintenance Contract Database under the National Maintenance 

Program. 

[See also GAO-02-95 and GAO/NSIAD-00-20.] 

Issue 7: DOD and Army Policies Affecting Army’s Ability to Manage the 

Proliferation of Depot Maintenance Activities

Recommendations 

• New weapons systems should be designated as core or non-core up 

front in the system’s life cycle at Milestone C (Production and 

Deployment). The system’s Logistics Support Plan should be revised 

accordingly on the basis of core depot assessment and presented at 

Milestone C for approval. 

• The Army should adopt a new core depot assessment process for 

weapons systems that have not yet undergone core determination 

analyses. 

• The Army should continue to revise/replace flawed Department of the 

Army policies that apply to the Depot Source of Repair (DSOR) 

decision process. The primary objectives of this effort should be the 

consistent compliance of all applicable legislation, regulations, and 

policies, and to ensure that the organic depots are not excluded from 

the DSOR decision process. 
Appendix III: Army Report’s Issues and 

Recommendations 

Page 38 GAO-04-220 Army Depot Maintenance 

• The Army should audit/review program executive officer, program 

manager, and AMC activities to ensure that they are following guidance 

on core logistics requirements, weapons system support strategies, and 

the DSOR decision process in accordance with the Assistant Secretary 

of the Army for Acquisition, Logistics, and Technology [ASA (ALT)] 

memorandum dated January 9, 2003, entitled Depot Considerations in 

Acquisition. 

• The ASA (ALT) should develop an Army acquisition policy that requires 

program executive officers and program managers to acquire access to 

system technical data owned by the original equipment manufacturer 

for use by appropriate organic or contractor maintenance facilities 

during the performance of system logistical support. 

• The ASA (ALT), Army G-4, and AMC should establish a partnership 

with an approved memorandum of agreement to integrate acquisition 

weapons system requirements with traditional end item and secondary 

item overhaul requirements to (1) assist AMC in maximizing the 

capabilities of the five organic depots to meet core requirements and 

(2) seek a renewed commitment from all parties that the depots will 

not be excluded from the DSOR process without the required analyses 

being conducted. 

• Army G-4, ASA (ALT), and AMC should work closely together to 

develop and implement a plan for documenting baseline data to 

compare contractor costs with organic support costs. 

• Army G-4, ASA (ALT), AMC, and AMC’s major subordinate commands 

should work closely with Headquarters, Department of the Army ASA 

(ALT) staff to market the depots with the program executive officers 

and program managers at every opportunity. 

• Army G-4, ASA (ALT), and AMC should work closely together to 

explore future opportunities to expand the number of public/private 

partnerships as part of the Army’s overall industrial base strategy. 

[See also U.S. General Accounting Office, Defense Logistics: Actions 

Needed to Overcome Capability Gaps in the Public Depot System, 

GAO-02-105 (Washington, D.C.: Oct. 12, 2001) and U.S. General Accounting 

Office, Defense Depot Maintenance: DOD Shifting More Workload for 

New Weapon Systems to the Private Sector, GAO/NSIAD-98-8

(Washington, D.C.: Mar. 31, 1998).] 
Appendix IV: Comments from the Department 

of Defense 

Page 39 GAO-04-220 Army Depot Maintenance 

Appendix IV: Comments from the 

Department of Defense 
Appendix IV: Comments from the Department 

of Defense 

Page 40 GAO-04-220 Army Depot Maintenance 
Related GAO Products 

Page 41 GAO-04-220 Army Depot Maintenance 

Depot Maintenance: DOD’s 50-50 Reporting Should Be Streamlined. 

GAO-03-1023. Washington, D.C.: September 15, 2003. 

Depot Maintenance: Key Unresolved Issues Affect the Army Depot 

System’s Viability. GAO-03-682. Washington, D.C.: July 7, 2003. 

Department of Defense: Status of Financial Management 

Weaknesses and Progress Toward Reform. GAO-03-931T. 

Washington, D.C.: June 25, 2003. 

Depot Maintenance: Change in Reporting Practices and Requirements 

Could Enhance Congressional Oversight. GAO-03-16. Washington D.C.: 

October 18, 2002. 

Depot Maintenance: Management Attention Needed to Further 

Improve Workload Allocation Data. GAO-02-95. Washington D.C.: 

November 9, 2001. 

Defense Logistics: Actions Needed to Overcome Capability Gaps in the 

Public Depot System. GAO-02-105. Washington, D.C.: October 12, 2001. 

Defense Maintenance: Sustaining Readiness Support Capabilities 

Requires a Comprehensive Plan. GAO-01-533T. Washington, D.C.; 

March 23, 2001. 

Depot Maintenance: Key Financial Issues for Consolidations at Pearl 

Harbor and Elsewhere Are Still Unresolved. GAO-01-19. Washington, D.C.: 

January 22, 2001. 

Depot Maintenance: Action Needed to Avoid Exceeding Ceiling 

on Contract Workloads. GAO/NSIAD-00-193. Washington, D.C.: 

August 24, 2000. 

Depot Maintenance: Air Force Waiver to 10 U.S.C. 2466. 

GAO/NSIAD-00-152R. Washington, D.C.: May 22, 2000. 

Depot Maintenance: Air Force Faces Challenges in Managing to 50-50 

Ceiling. GAO/T-NSIAD-00-112. Washington, D.C.: March 3, 2000. 

Depot Maintenance: Future Year Estimates of Public and Private 

Workloads Are Likely to Change. GAO/NSIAD-00-69. Washington, D.C.: 

March 1, 2000. 

Related GAO Products 
Related GAO Products 

Page 42 GAO-04-220 Army Depot Maintenance 

Depot Maintenance: Army Report Provides Incomplete Assessment 

of Depot-Type Capabilities. GAO/NSIAD-00-20. Washington, D.C.: 

October 15, 1999. 

Depot Maintenance: Status of the Navy’s Pearl Harbor Project. 

GAO/NSIAD-99-199. Washington, D.C.: September 10, 1999. 

Depot Maintenance: Workload Allocation Reporting Improved, but 

Lingering Problems Remain. GAO/NSIAD-99-154. Washington, D.C.: 

July 13, 1999. 

Navy Ship Maintenance: Allocation of Ship Maintenance Work in 

the Norfolk, Virginia, Area. GAO/NSIAD-99-54. Washington, D.C.: 

February 24, 1999. 

Defense Depot Maintenance: Public and Private Sector Workload 

Distribution Reporting Can Be Further Improved. GAO/NSIAD-98-175. 

Washington, D.C.: July 23, 1998. 

Defense Depot Maintenance: DOD Shifting More Workload for New 

Weapon Systems to the Private Sector. GAO/NSIAD-98-8. Washington, 

D.C.: March 31, 1998. 

Defense Depot Maintenance: Information on Public and Private 

Sector Workload Allocations. GAO/NSIAD-98-41. Washington, D.C.: 

January 20, 1998. 

Defense Depot Maintenance: Uncertainties and Challenges DOD Faces 

in Restructuring Its Depot Maintenance Program. GAO/T-NSIAD-97-112. 

Washington, D.C.: May 1, 1997. Also, GAO/T-NSIAD-97-111. Washington, 

D.C.: March 18, 1997. 

Defense Depot Maintenance: DOD’s Policy Report Leaves Future Role 

of Depot System Uncertain. GAO/NSIAD-96-165. Washington, D.C.: 

May 21, 1996. 

Defense Depot Maintenance: More Comprehensive and Consistent 

Workload Data Needed for Decisionmakers. GAO/NSIAD-96-166. 

Washington, D.C.: May 21, 1996. 

Defense Depot Maintenance: Privatization and the Debate Over 

the Public-Private Mix. GAO/T-NSIAD-96-148. Washington, D.C.: 
Related GAO Products 

Page 43 GAO-04-220 Army Depot Maintenance 

April 17, 1996. Also, GAO/T-NSIAD-96-146. Washington, D.C.: 

April 16, 1996. 

Depot Maintenance: Issues in Allocating Workload Between the 

Public and Private Sectors. GAO/T-NSIAD-94-161. Washington, D.C.: 

April 12, 1994. 

(350413) 
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