United States General Accounting Office

GAO Report to Congressional Requesters

October 1996 FEDERAL

PERSONNEL

Issues on the Need for

NOAA’s Commissioned

Corps

G O A

years

1921 - 1996

GAO/GGD-97-10

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-270666 

October 31, 1996

The Honorable Lamar Smith

House of Representatives

The Honorable John R. Kasich

House of Representatives

This report responds to your request that we review the operations of the

National Oceanic and Atmospheric Administration’s (NOAA) Commissioned

Corps. NOAA’s Commissioned Corps is a uniformed service whose officers

are covered by a military-like compensation system in a manner similar to

the Commissioned Corps of the Public Health Service (PHS). NOAA Corps

officers carry out a variety of navigational and scientific functions, such as

charting and oceanographic research.

You asked us to provide information on (1) issues surrounding whether

there is a continuing need for the NOAA and PHS Corps as uniformed

services with military-like pay, allowances, and benefits and (2) what the

costs would be if federal civilian employees carried out the Corps’

functions. In a May 7, 1996, report,1

 we presented the results of our review

of the PHS Corps. This report presents the results of our review of the NOAA

Corps. Like the report on the PHS Corps, this report provides answers to

questions your designated representative agreed would provide the

information you were seeking. In general, the questions addressed why the

NOAA Corps exists; what the Corps officers’ duties are; how the Corps is

similar to and different from the military; and what savings, if any, might

result from not using uniformed personnel to carry out current Corps

functions. Our review did not examine whether the Corps’ functions or the

number of persons used to accomplish those functions were necessary or

could be changed as the result of civilianization.

In developing the information for this report, we interviewed—and

analyzed documents provided by—officials of NOAA, the NOAA

Commissioned Corps, the Department of Defense (DOD), the Office of the

Navy Oceanographer, the Office of Naval Research, the National Science

Foundation, and other organizations that could provide insights into the

Corps’ functions, responsibilities, and costs. Appendix I describes in detail

the objective, scope, and methodology of our review, which was done in

accordance with generally accepted government auditing standards. We

requested comments on a draft of this report from the Departments of

1

Federal Personnel: Issues on the Need for the Public Health Service’s Commissioned Corps

(GAO/GGD-96-55).

Page 1 GAO/GGD-97-10 NOAA Commissioned Corps
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Commerce and Defense. The Department of Commerce provided written

comments. Its letter is discussed at the end of this report and reprinted in

appendix II. The Department of Defense had no comments on the report.

Results in Brief Like the PHS Corps, the NOAA Corps carries out civilian, rather than

military, functions. In contrast to the PHS Corps, NOAA Corps officers who

serve at sea have few civilian employee counterparts in NOAA. However,

other agencies use federal civilian employees or contractors to carry out

duties similar to the functions NOAA assigns to the Corps.

NOAA Corps officers operate and manage NOAA’s research and survey ships

that collect the data needed to support fishery management plans,

oceanographic and climate research, and hydrographic surveys. NOAA

Corps officers also fly and manage NOAA’s aircraft that are used to

penetrate hurricanes for research and to carry out surveys for forecasting

floods and mapping changing U.S. shorelines. Corps officials said officers

can expect to serve one-third of their careers in each of the following work

categories: (1) sea duty; (2) shore duty that involves responsibilities in

marine centers, vessel support, geodetic surveys, or aircraft operations;

and (3) shore duty that involves management and technical support in

offices throughout NOAA.

NOAA Corps officers’ entitlement to military ranks and military-like

compensation, including retirement eligibility at any age after completing

20 years of service, was an outgrowth of their temporary assignments to

the armed forces during World Wars I and II. The Corps has not been

incorporated into the armed forces since World War II, and DOD’s war

mobilization plans envision no role for the Corps in the future. Generally,

the Corps does not meet the criteria and principles cited in a DOD report as

justification for the military compensation system. Corps officers are not

subject to the Uniform Code of Military Justice that governs how military

personnel are managed.

Actions are in process that could significantly change the Corps. A general

downsizing in the Department of Commerce reduced the Corps from

about 400 officers in October 1994 to 332 officers as of July 1, 1996, with

an eventual goal of a complement of 285 by the year 2000. Further, in

January 1996, NOAA’s Administrator asked Corps management to develop a

plan for civilianizing the Corps by the spring of 1997. At the time we

prepared this report, the plan was being reviewed by the Secretary of

Commerce, who has overall responsibility for NOAA.

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Our estimates suggest that using civilian employees to carry out the Corps’

current functions would result in limited savings. A comparative cost

analysis showed that it would have cost an estimated $573,000 more in

personnel costs to employ civilian workers during the period July 1, 1994,

through June 30, 1995, than the personnel costs paid to Corps officers.

However, when the estimated federal income tax benefits of $1,234,000

afforded to Corps officers from their nontaxable allowances are

considered, the government would realize net savings of an estimated

$661,000 by employing civilian employees. If the Corps were to be

converted to civilian employment, the actual net cost reduction could

vary, depending on various factors, including the method by which the

conversion was implemented, the applicability of 1994 through 1995 costs

to future years, and the accuracy of the underlying assumptions about

Corps and civilian personnel costs.

It must also be recognized that, because the Corps is now smaller than it

was in the period in which we did our work and further reductions are

anticipated, any savings available from civilianizing the Corps in the future

would be reduced accordingly.

NOAA Corps History

and Current Status

The organization that became NOAA was established in 1807, and in 1836 it

officially became known as the Coast Survey. The Survey dispatched

technical and scientific teams to survey the uncharted U.S. coastline and

relied on the Army and the Navy to supply personnel to augment the

organization’s civilian employees. After the Civil War, the Army withdrew

from the Survey’s work; the Navy withdrew during the Spanish-American

War, leaving the work to be done solely by the employees of the newly

named Coast and Geodetic Survey. After the Army and the Navy withdrew

their personnel, many of the Coast and Geodetic Survey’s civilian

employees working in the field continued (1) maintaining a military-like

operation with distinct lines of authority, (2) wearing Navy uniforms, and

(3) giving and taking orders.

At the outbreak of World War I, ships and men who were qualified to

operate the ships were needed immediately to augment the military forces.

The Coast and Geodetic Survey was the only federal civilian agency that

could respond to these requirements. Accordingly, in 1917, Congress

passed legislation authorizing the President to transfer the Survey’s ships

and men to the Navy and War Departments for the duration of the war and

officially giving military rank to Coast and Geodetic Survey field officers

when serving in the Army or Navy. The Joint Service Pay Act of 1920

Page 3 GAO/GGD-97-10 NOAA Commissioned Corps
B-270666 

extended the Navy’s pay, allowances, and retirement system to the

members of the Coast and Geodetic Survey who held ranks equivalent to

Navy officers.

In World War II, about half of the commissioned officers and ships of the

Coast and Geodetic Survey were temporarily transferred to the armed

services. Officers’ duties included training amphibious troops in

seamanship and navigation, serving as battalion observation officers, and

executing hydrographic surveys in advance of fleet operations in the

Aleutian Islands and the Western Pacific. At the end of the war, all Survey

ships and officers were returned to the Coast and Geodetic Survey and to

civilian duties. However, the Corps continued to exist, and its officers

retained their military ranks and compensation.

In 1965, the Coast and Geodetic Survey became the Environmental

Science Services Administration (ESSA), and in 1970, ESSA became NOAA.

NOAA is composed of five line offices—(1) the National Marine Fisheries

Service; (2) the Office of Oceanic and Atmospheric Research; (3) the

National Weather Service; (4) the National Ocean Service; and (5) the

National Environmental Satellite, Data, and Information Service—and the

Office of the Administrator. Corps officers are assigned to work in all

component offices of NOAA. Table 1 provides Corps officers’ assignments

to NOAA’s component offices in April 1995.

Table 1: NOAA Corps Assignments in

NOAA Components, April 1995 NOAA Component Office Total Corps Officers

National Marine Fisheries Service 35

Office of Oceanic and Atmospheric Research 31

National Weather Service 10

National Ocean Service

charting 45

noncharting 36

National Environmental Satellite, Data,

and Information Service

12

Office of the Administratora 227

Total 396

aIncludes NOAA Corps Operations, the Pacific and Atlantic Marine Centers, Corps Personnel

Center, aircraft pilots, and ships’ officers.

Source: Office of NOAA Corps Operations.

Page 4 GAO/GGD-97-10 NOAA Commissioned Corps
B-270666 

Corps officials said officers can expect to serve one-third of their careers

in each of the following work categories: (1) sea duty; (2) shore duty that

involves responsibilities in marine centers, vessel support, geodetic

surveys, or aircraft operations; and (3) shore duty that involves

management and technical support throughout NOAA.

In October 1994, the Corps had approximately 400 commissioned officers.

As a result of general downsizing in the Department of Commerce, the

Corps was reduced to 332 officers as of July 1, 1996. According to a Corps

official, the ultimate downsizing goal was to reduce the number of officers

to 285 by the year 2000.

NOAA has since expressed an interest in eliminating the Corps and using

civilian employees to carry out the Corps’ functions. In January 1996,

NOAA’s Administrator announced that the NOAA Corps would begin a

transition to civilian status on October 1, 1996, and directed that the

transition be completed within 6 months. He asked the Director of NOAA

Corps operations to develop an implementation plan for civilianizing the

Corps. NOAA officials said that plan was being reviewed by the Secretary of

Commerce.

NOAA Corps’

Similarity to and

Differences From the

Military

Corps members’ entitlement to military ranks and military-like

compensation, including eligibility for retirement at any age after 20 years

of service, was an outgrowth of their temporary service with the armed

forces during World Wars I and II. The NOAA Corps has not been

incorporated into the armed forces since World War II, and DOD’s war

mobilization plans envision no role for the Corps in the future. Corps

officers continue to receive virtually the same pay and benefits (including

retirement) as the military.

A 1984 DOD report2

 provided a detailed discussion of the criteria and

principles used to justify the military compensation system. According to

the report, the main purpose of the military compensation system is to

ensure the readiness and sustainability of the armed forces. Military

personnel can be assigned at any time to any locations the services see fit,

regardless of members’ personal preferences or risks. In other words, the

military compensation system is based on the premise that individual

aspirations and preferences are subordinated to the good of the service.

The NOAA Corps is not considered an armed service, and Corps officers are

not subject to the Uniform Code of Military Justice, which underlies how

2

The Fifth Quadrennial Review of Military Compensation, Department of Defense, January 1984.

Page 5 GAO/GGD-97-10 NOAA Commissioned Corps
B-270666 

military personnel are managed.3 Accordingly, NOAA cannot press criminal

charges or pass sentence against an officer who disobeys orders, and

Corps officers can quit the Corps without legal sanctions.

Corps officials said the essential functions of the uniformed Corps are to

serve as deck officers aboard NOAA ships and to be a mobile cadre of

professionals who can be assigned with little notice to any location and

function where their services are necessary, often in hazardous or harsh

conditions. We found that some Corps assignments are of this nature, but

civilian employees in other agencies are often assigned to duties similar to

those of the Corps. For example, the Environmental Protection Agency

(EPA), the National Transportation Safety Board, and the Federal

Emergency Management Agency use civilian employees to respond

quickly to disasters and other emergency situations. Moreover, EPA and the

Navy use ships operated by civilian employees or contractors in

conducting their oceanic research. Officials from these agencies said they

have experienced no problems in using civilian deck officers on the

vessels. Also, NOAA ships have been operated on occasion by Wage Marine

(civilian)4

 deck officers, and NOAA officials termed this approach

successful.

Potential Cost

Reduction Resulting

From Civilianizing the

NOAA Corps

NOAA contracted with Arthur Andersen LLP to determine the comparative

costs of using civilian employees rather than Corps officers to carry out

the Corps’ functions. The contractor’s report5

 was issued August 30, 1995.

We examined the contractor’s approach and methodology and generally

found them to be similar to those we would have used. Thus, other than

making an adjustment we believed was necessary for a more complete

comparison, we accepted the contractor’s estimates of the comparative

costs of using Corps officers and civilian employees. On the basis of the

contractor’s report and the adjustment we made, we estimated that the

cost to the government would have been about $661,000 lower during the

3

Under a 1917 statute, the President can incorporate the Corps into the military service in the event of

national emergency. Since all military personnel are subject to the Uniform Code of Military Justice,

Corps officers, after being incorporated into the military, would be subject to the code. This situation

has not occurred since World War II.

4

A Wage Marine is a type of prevailing-rate excepted service employee who serves as a master or mate

on NOAA ships.

5

National Oceanic and Atmospheric Administration Commissioned Officer Corps: Comparison of

NOAA Corps versus Federal Employees, Arthur Andersen LLP, August 30, 1995.

Page 6 GAO/GGD-97-10 NOAA Commissioned Corps
B-270666 

year July 1994 through June 1995, if civilian employees had been used.6 If

the Corps is downsized as intended, the estimated cost savings would be

smaller in subsequent years.

Arthur Andersen LLP Cost

Comparison Study

The Arthur Andersen LLP report concluded that civilianization of the

Corps would increase government costs by $573,000 a year. This estimate

was based on actual costs incurred during the year ending June 30, 1995,

and used a Corps strength of 384 officers. Table 2 shows the Arthur

Andersen LLP estimates.

Table 2: Arthur Andersen LLP

Comparison of Corps and Civilian

Personnel Costs Category

NOAA Corps

Officers

Federal civilian

employees Difference

Base pay/salaries $15,795,000 $20,869,000 $(5,074,000)

Special pays,

allowances, and

bonuses

5,486,000 3,710,000 1,776,000

Benefits 8,427,000 5,702,000 2,725,000

Total $29,708,000 $30,281,000 $(573,000)

Source: Arthur Andersen LLP report.

Our Adjustment to the

Contractor’s Estimates

Arthur Andersen LLP did not include in its comparison the federal income

tax advantage Corps officers receive from their housing and subsistence

allowances. Like members of the military, NOAA Corps officers pay no

federal income taxes on these allowances.7

 As DOD explained, the “cost” to

the government arising from this tax advantage comes in the form of a loss

to the U.S. Treasury of the federal income taxes that would otherwise have

been paid if the allowances were taxable.8

 Federal civilian employees

receive no such tax advantages; they must pay their living expenses from

their fully taxable salaries.

6

The actual net cost reduction would vary, depending on various factors, including the method by

which any changes are implemented, the applicability of 1994 costs to future years, and the accuracy

of the underlying assumptions concerning Corps and civilian personnel costs.

7

A major component of military and Corps compensation is termed “Regular Military Compensation.”

This component includes basic pay, nontaxable housing and subsistence allowances, and the tax

advantage accorded to members through the nontaxable allowances.

8

As actually calculated by DOD, the tax advantage is the amount of additional income military (or

Corps) personnel would need to retain their take-home pay if their allowances were taxable.

Page 7 GAO/GGD-97-10 NOAA Commissioned Corps
B-270666 

A DOD publication9 pointed out that the actual federal tax benefit that an

individual member realizes is governed by many considerations. These

considerations include (1) the aggregate amount of a member’s (and his or

her spouse’s) income, both earned and unearned; (2) the amount of the

member’s housing and subsistence allowances; (3) the member’s marital

status and number of dependents; (4) whether the member takes the

standard deduction or itemizes deductions for federal income tax

purposes; and (5) whether the member is entitled to other types of tax

exclusions. DOD developed a series of numerical estimates of the tax

advantages to members using certain assumptions related to these factors.

The publication noted that members do not actually receive the tax

advantage in cash or in kind. Accordingly, it is not a cost item in DOD’s

budget, nor is it in NOAA’s budget.

According to its report, Arthur Andersen LLP did not include Corps

members’ tax advantage as a cost of maintaining the Corps because it did

not represent “costs incurred by the Federal Government.” However,

because the tax advantage represents a revenue loss to the government

and is of considerable monetary value to Corps members, we believe it

should be included in any cost comparison.

Since NOAA Corps officers receive the same base pay and housing and

subsistence allowances as military officers at the same ranks, we used

DOD’s tax advantage estimates to estimate the tax advantage afforded to

Corps members. We estimated that the annual tax advantage associated

with the housing and subsistence allowance amounts used in the Arthur

Andersen LLP study would be $1,234,000 a year. Adjusting the Arthur

Andersen LLP study results by the estimated tax advantage amount results

in a total government cost for the Corps of $30,942,000 for the year,

compared with the estimated $30,281,000 cost of using civilian

employees—a difference of $661,000.

If a decision were made to civilianize the NOAA Corps, whether there would

be any actual cost reductions would depend, in large part, on the manner

in which a transition to civilian employment would be carried out,

including the period of time over which the transition would occur. Any

decision to replace Corps officers with civilian employees could be

implemented in a number of ways. The possibilities range from requiring

all officers to immediately convert to civilian employment, to longer-range

measures such as allowing all current officers to remain in place until

9

Military Compensation Background Papers: Compensation Elements and Related Manpower Cost

Items, Office of the Secretary of Defense, Department of Defense, November 1991.

Page 8 GAO/GGD-97-10 NOAA Commissioned Corps
B-270666 

retirement or other separation and requiring all new entrants to be civilian

employees. Or, perhaps all officers with a specific number of years in the

Corps could be allowed to continue in the Corps until retirement or other

separation.

The amount of transition costs would also depend on how considerations

such as the following were resolved.

(1) What retirement benefits or credits are given to officers for the time

they spend in the Corps before converting to civilian employment and the

civilian employee retirement system.

(2) What resources would be required to recruit, train, and retain civilian

employees that might be needed to replace Corps officers who opt to leave

federal service.

(3) The amount of additional resources, if any, that would be required to

administer the civilian workforce at NOAA after civilianizing the Corps and

its administrative personnel.

A plan of action that addresses each of the above factors and other

possible considerations would be needed before estimates of the

transition costs involved could be determined.

Agency Comments The Department of Commerce provided written comments on a draft of

this report. The comments and our responses are discussed below. The

Department’s comments are provided in their entirety in appendix II.

Although the Department expressed concerns about certain information in

the report, it acknowledged that a legislative proposal (prepared by the

Department) to “disestablish” the Corps was pending clearance within the

administration.

The Department questioned the appropriateness of our applying DOD’s

criteria for military compensation to the NOAA Corps. It said the criteria

focused exclusively on the military services, rather than on uniformed

services in general. In our opinion, the criteria we used were appropriate.

The Corps’ compensation system, generally the same as the military

compensation system, was legislatively established after some Corps

officers were temporarily assigned to the military during World War I.

Thus, in evaluating whether the Corps should continue to receive

Page 9 GAO/GGD-97-10 NOAA Commissioned Corps
B-270666 

military-like compensation, we believe the application of the criteria DOD

used to justify the military compensation system is reasonable.

The Department noted that its goal for downsizing the Corps (if the

proposal to “disestablish” the Corps is not accepted) is to have a Corps

strength of 285 officers by the year 2000, rather than 280 as stated in the

draft report. We changed the report to reflect this updated estimate.

According to the Department, the report’s discussion of the history of the

Corps and how Corps officers came to receive ranks and compensation

similar to the military should have included more detailed information. We

included additional historical information consistent with the

Department’s suggestions.

Similarly, the Department suggested that, to be more complete, the report

should acknowledge that Corps officers are subject to the Uniform Code

of Military Justice when serving with or assigned to the armed forces. We

agree that this is the case. However, the report section cited by the

Department already pointed out this exception to the general rule in a

footnote. Accordingly, we did not believe a change was needed to address

this comment.

The Department expressed an opinion that the report did not sufficiently

address the ways in which service with the Corps is similar to military

service. We disagree. The report discussed areas of similarity between

Corps and military service mentioned by Corps officials during our review,

but it also pointed out that civilian employees in other agencies were often

subject to the same conditions of employment. Moreover, many of the

similarities discussed in the Department’s comments exist because the

Corps is compensated under a military-like system, not because the Corps

has responsibilities like the military. It should also be noted that the

criteria for military compensation articulated in the DOD report are based

on the need for inducements and incentives to maintain a force necessary

“to insure successful accomplishment of the United States national

security objectives.” Corps officers have not been involved in meeting

national security objectives since World War II.

We also provided a draft of the report to DOD. We were advised that, after

reviewing the draft, DOD had no comments.

Page 10 GAO/GGD-97-10 NOAA Commissioned Corps
B-270666 

As agreed with your office, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 7 days from the

date of this report. At that time, we will send copies to the Secretaries of

Commerce and Defense and other interested parties. We will also make

copies available to others upon request.

If you have questions concerning this report, please telephone me or

Associate Director, Timothy P. Bowling, at (202) 512-8676. Major

contributors to this report are listed in appendix III.

L. Nye Stevens

Director, Federal Management

 and Workforce Issues

Page 11 GAO/GGD-97-10 NOAA Commissioned Corps
Contents

Letter 1

Appendix I 

Objective, Scope, and

Methodology

14

Appendix II 

Comments From the

Department of

Commerce

16

Appendix III 

Major Contributors to

This Report

20

Tables Table 1: NOAA Corps Assignments in NOAA Components,

April 1995

4

Table 2: Arthur Andersen LLP Comparison of Corps and Civilian

Personnel Costs

7

Abbreviations

DOD Department of Defense

ESSA Environmental Science Services Administration

EPA Environmental Protection Agency

NOAA National Oceanic and Atmospheric Administration

PHS Public Health Service

Page 12 GAO/GGD-97-10 NOAA Commissioned Corps
Page 13 GAO/GGD-97-10 NOAA Commissioned Corps
Appendix I 

Objective, Scope, and Methodology

The objective of this report is to provide information on the operations of

the National Oceanic and Atmospheric Administration (NOAA)

Commissioned Corps. We were asked to address why the NOAA Corps

exists; what the Corps officers’ duties are; how the Corps is similar to and

different from the military; and what savings, if any, might result from not

using uniformed personnel to carry out current Corps functions.

To gather the information on the continuing need for the Corps, we

reviewed NOAA Corps historical material and interviewed and obtained

documentation from officials of NOAA, including the Office of NOAA Corps

Operations; the Department of Defense (DOD), including the Department of

the Army and the Navy; Woods Hole Oceanographic Institute; the National

Science Foundation; the National Transportation Safety Board; the

Federal Emergency Management Agency; and the Environmental

Protection Agency.

To compare the costs of using uniformed personnel or civilian employees

to carry out Corps duties, we reviewed the findings in an August 1995

report1

 prepared by Arthur Andersen LLP under a contract with NOAA. We

examined the contractor’s approach and methodology and generally found

them to be similar to those we would have used. Other than making an

adjustment we believed was appropriate to reflect the estimated tax

advantages Corps officers receive through their nontaxable housing and

subsistence allowances, we accepted the contractor’s findings as valid

estimates of the comparative costs of using Corps officers and civilian

employees.

It should be noted that we did not examine whether the Corps’ functions

or the number of persons used to accomplish those functions were

necessary or could be changed as the result of civilianization. Thus, the

report does not address issues such as whether civilianization of the Corps

could present opportunities for possible savings through restructuring or

consolidating NOAA operations. Neither did we examine the possibility of

contracting with private companies, rather than using civilian employees,

to carry out the Corps’ current functions.

We did our work in Washington, D.C.; Narragansett, Rhode Island; and

Woods Hole, Massachusetts, between November 1994 and January 1996.

Our work was done in accordance with generally accepted government

auditing standards.

1

National Oceanic and Atmospheric Administration Commissioned Officers Corps: Comparison of

NOAA Corps versus Federal Employees, August 30, 1995.

Page 14 GAO/GGD-97-10 NOAA Commissioned Corps
Appendix I 

Objective, Scope, and Methodology

The Department of Commerce provided written comments on a draft of

this report. A copy of the letter is included as appendix II. The Department

of Defense also reviewed a draft of the report and had no comments.

Page 15 GAO/GGD-97-10 NOAA Commissioned Corps
Appendix II 

Comments From the Department of

Commerce

Page 16 GAO/GGD-97-10 NOAA Commissioned Corps
Appendix II 

Comments From the Department of

Commerce

Page 17 GAO/GGD-97-10 NOAA Commissioned Corps
Appendix II 

Comments From the Department of

Commerce

Page 18 GAO/GGD-97-10 NOAA Commissioned Corps
Appendix II 

Comments From the Department of

Commerce

Page 19 GAO/GGD-97-10 NOAA Commissioned Corps
Appendix III 

Major Contributors to This Report

General Government

Division, Washington,

D.C.

Robert E. Shelton, Assistant Director, Federal Management and Workforce

 Issues

Nancy A. Patterson, Assignment Manager

Philip Kagan, Technical Advisor

Steven J. Berke, Evaluator-in-Charge

Marlene M. Zacharias, Evaluator Assistant

(410005) Page 20 GAO/GGD-97-10 NOAA Commissioned Corps
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