DEFENSE

INFRASTRUCTURE

Historic Properties

within the Department

of Defense

Statement of Henry L. Hinton, Jr., Managing Director, Defense Capabilities

and Management

United States General Accounting Office

GAO Testimony

Before the Subcommittee on Military Construction,

Committee on Appropriations, House of Representatives

For Release on Delivery

9:30 a.m. EDT

Thursday, March 15, 2001

GAO-01-497T
1 GAO-01-497T Defense Infrastructure

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss the management of historic properties1 within the

Department of Defense (DOD), the current and projected inventory of these properties, and

the cost to maintain these properties. My testimony is based on the preliminary results of

work we have done in response to a legislative mandate included in the Floyd D. Spence

National Defense Authorization Act for Fiscal Year 2001, which required us to determine the

reliability of the services’ current and projected inventory of historic properties and the

availability of data on the cost of maintaining and repairing these properties. Before

discussing our specific observations, I would like to briefly summarize the key points in my

statement.

RESULTS IN BRIEF

To be designated historic, a property must meet criteria specified in the Historic Preservation

Act of 1966 such as being associated with historic events or people or being architecturally

significant. The Office of the Secretary of Defense and the service headquarters provide

overall policy guidance as well as have negotiated agreements regarding treatment of certain

types of historic properties across the Department or respective services. However, the

majority of the decisions regarding historic properties are made at the installation level. The

installations are responsible for identifying and evaluating properties to determine if they

meet the criteria to be eligible for listing on the National Register as well as maintaining all

properties that are listed on or have been determined eligible for listing on the National

Register.

Based on our work thus far, the military services do not have complete and reliable data on

the number of its historic properties. None of the services have a centralized database that

comprehensively identifies all of their respective historic properties. Available data indicates

 

1There are five types of historic properties. Buildings are defined as any construction sheltering human activity. Structures

are defined as any constructions other than for human shelter and include such items as airplanes, bridges, and highways.

Objects are distinguished from buildings and structures based on being artistic in nature and small in scale and include

monuments, boundary markers, and statuary. A site is a location of significance such as a battlefield, cemetery, or shipwreck

and also includes archeological locations. A district is defined as “possessing a significant concentration, linkage, or

continuity of buildings, structures, objects, or sites united historically or aesthetically by plan or physical development.”
2 GAO-01-497T Defense Infrastructure

that the services have about 17,300 historic properties--about 10,100 in the Army.2 This

represents less than 5 percent of all Department of Defense facilities and most of the historic

buildings are in use. However, because of inconsistencies between the services’ real

property databases and cultural resource records, and the lack of an inventory of properties

that are eligible for listing on the National Register, the reliability of this number is

questionable. Further, while there is a large number of properties that need to be evaluated

over the next 10 years, it is uncertain how many of these properties will meet the criteria and

become eligible for listing on the National Register.

Data is not readily available to identify the costs of maintaining historic properties or to

separately account for repairs related to the historic aspects of these properties. The

Services do not account separately for or otherwise distinguish between money spent to

maintain and repair historic properties and that spent on non-historic properties. Cost data

we examined at several installations showed that overall, the day-to-day maintenance

conducted on historic properties was similar to maintenance on non-historic properties.

However, the costs of such maintenance can be proportionally greater where historic

properties are larger in size than current military requirements. This is especially true of

historic military family housing. At the same time, replacement of unique historical features

such as large porches, windows, and slate or tile roofs can result in higher maintenance and

repair costs for historic properties in the year the work is performed.

BACKGROUND

The National Historic Preservation Act of 19663 established a national historic preservation

program to provide for the ongoing identification and protection of historic properties. Under

the act, an historic property is any building, structure, object, site, or district included in or

eligible for inclusion in the National Register of Historic Places.4 To be eligible for the

National Register, a property must meet one of the following four criteria: (1) be associated

with significant historic events or activities, (2) be associated with people important in our

past, (3) embody distinctive design or physical characteristics, or (4) have the potential to

 

2This figure is limited to buildings and structures and excludes World War II wood buildings that have been approved for

demolition.

3P. L. 89-665, as amended, is codified at 16 U.S.C. 470 et. seq.
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provide important information about prehistory or history. In addition, the property generally

has to be 50 years of age or older.

The act generally requires federal agencies to identify, evaluate, and nominate historic

properties under agency control to the National Register. DOD requires each installation to

prepare a cultural resource management plan every 5 years to satisfy this requirement. The

plan includes an inventory of all properties that are listed on or have been determined eligible

for listing on the National Register as well as an evaluation of properties that will reach 50

years of age over the time period covered by the plan.

The act also requires that federal agencies (1) consider the effects of any maintenance,

repair, or renovation on historic properties—both those listed and eligible for listing in the

National Register, and (2) consult with the State Historic Preservation Officers to reach an

agreement regarding actions that affect historic properties that is beneficial to all. Thus,

when installation officials are about to begin work on a property either on or eligible for

inclusion on the National Register, they should consult with the state about what work will be

accomplished and what materials will be used, however, responsibility for funding the work

remains with the Department of Defense.

INSTALLATIONS ARE PRIMARILY RESPONSIBLE FOR

MANAGEMENT OF HISTORIC PROPERTIES

 The Office of the Secretary of Defense and the service headquarters have provided overall

policy guidance for the historic properties program as well as negotiated agreements

regarding treatment of certain types of historic properties across DOD or their respective

service. However, the majority of the decisions regarding historic properties are made at the

installation level. The installations are responsible for identifying and evaluating properties to

determine if they meet the criteria to be eligible for listing on the National Register as well as

maintaining all properties that are listed on or have been determined eligible for the National

Register.

 

4The National Park Service administers the National Register.
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The Office of the Secretary of Defense has issued policy guidance on cultural resources

management, which requires each of the service headquarters to develop a cultural

resources program and each installation to develop a cultural resources management plan,

which should include an inventory of historic properties. In addition, the Office of the

Secretary of Defense and the service headquarters have negotiated agreements regarding

historic properties. For example, the Office of the Secretary of Defense has negotiated an

agreement with the Advisory Council on Historic Preservation and the National Conference of

State Historic Preservation Officers that allows the services to demolish all World War II

wood buildings.5 The Army would like to propose a similar agreement that would allow it to

demolish certain Cold War Era properties. In addition, the Navy has negotiated an agreement

with the Advisory Council and the National Conference regarding the management of its

historic family housing. The agreement allows the Navy to prioritize maintenance and repair

actions among historic family housing. The Army has a proposed draft document with the

Council that could provide more efficient consultation with the State Historic Preservation

Officers.

Each DOD installation identifies and evaluates properties that will reach 50 years of age as

part of its cultural resources management plan. Once an installation completes its evaluation

of properties, it consults with the State Historic Preservation Officer. If installation and State

Historic Preservation officials agree that a property meets the criteria, it is considered

eligible for the National Register. If the State Office disagrees with the installation’s

recommendation, the service must seek a formal determination of eligibility from the National

Park Service.6 Officials at the installations we visited stated that they generally have been

able to reach an agreement with the State Historic Preservation Officer on whether

properties are or are not eligible for listing on the National Register. Once a property has

been determined eligible for listing on the National Register, the installation must manage it

the same as any property that is listed in the Register. For this reason, and because a formal

nomination can be expensive and divert resources from other cultural resource management

 

5 The Advisory Council on Historic Preservation is a federal agency set up by the National Historic Preservation Act that

advises all other federal agencies in ways to effectively carry out provisions of the act. The National Conference of State

Historic Preservation Officers is the professional association of the state government officials who carry out the national

historic preservation program.

6

 The Keeper of the National Register makes the final determination of property eligibility.
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activities, actual nomination of properties to the National Register is not a high priority within

the services. For example, the Army’s Cultural Resources Management regulations 7 state that

“the Army will formally nominate only those properties that it intends to interpret,

commemorate, or otherwise actively manage as sites of popular interest that are normally

open to the general public.”

The installations are also responsible for consulting with the State Historic Preservation

Officers regarding maintenance and repair work on historic properties. Cultural resource

officials at the installations we visited stated that they spend more time consulting with the

Officers on the maintenance and repair of historic properties than on whether properties meet

the criteria for listing on the National Register. Some of the installations we visited have

agreements with the Officers on the types of maintenance and repair projects that require

consultation. For example, the cultural resource official at Fort Leavenworth stated that he

only consults with the State Office on major projects that will affect the exterior of historic

properties but not on routine maintenance and repair projects.

DATA ON THE NUMBER OF HISTORIC

PROPERTIES IS NOT RELIABLE

Although the military services maintain cultural resource records on historical properties and

real property databases, containing both historical and nonhistorical properties; they do not

have complete and reliable data on the number of historic properties. None of the services

have a centralized database that identifies all of their respective historic properties. Our

analysis of data from the military services’ real property databases and cultural resource

records indicates the services have about 17,300 historic properties, most of which are inuse. However, results of military service auditor tests of additions, deletions, and

modification transactions for fiscal year 1999 indicated that real property transactions were

not promptly recorded. This problem, along with issues we identified such as conflicting

information between the Army’s real property database and its cultural resource records, and

the lack of information on Navy and Air Force properties that are eligible for listing, raise

questions regarding the reliability of the services’ information. Further, while there is a large

 

7

 Army Regulation 200-4, Cultural Resources Management.
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number of properties that need to be evaluated over the next 10 years, it is uncertain how

many of these properties will meet criteria and become eligible for listing on the National

Register.

Although each service maintains a real property database that should indicate whether

individual buildings and structures are historic properties, our work has shown that these

databases are not reliable. For example, the Navy, Marine Corps, and Air Force systems only

identify properties on the National Register, not properties that are eligible for listing on the

National Register. While the Army database includes both listed and eligible properties, it

does not include all the properties identified as historic in the cultural resource records. At

the same time, questions regarding the accuracy and completeness of cultural resource

records exist. The number of historic properties in table 1 represents our analysis of the

services’ real property databases and cultural resource records.

Table 1: Historic Properties by Service

Service Number of historic properties

Listed Eligible Total

Army a a10,110b

Navy 2,135 391c2,526

Marine Corps 49 590c639

Air Force 1,691 2,346c4,037

Total 17,312
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aArmy data does not identify whether a property is listed on or eligible for the National Register.

b This figure excludes 8,254 buildings approved for demolition.

c These service real property databases do not include information on eligible properties; these numbers were developed from

the services’ cultural resource records.

Source: Our analysis of available service data.

While information included in table 1 provides the best available data on the number of

historic properties, it is subject to certain limitations. The following examples highlight the

problems we had in determining the number of historic properties within each service.

• The Army’s real property database identifies 6,189 properties and its cultural resource

records, maintained at each installation, indicate 8,593 properties as historic—

excluding buildings approved for demolition.8 Our comparison of information between

these two data source indicates the Army has 10,110 historic properties. Army

officials stated that the additional properties that are included in cultural resource

records represent properties that are eligible for listing, but installations have not

updated the real property database. For example, the cultural resource records

identify 1,790 historic properties at Hawthorne Army Depot, Nevada, which are not

identified as historic in the Army’s real property database. About 1,533 of these

historic properties are munitions storage structures.

• The Navy’s real property database identifies 1,283 historic properties, but our work

indicates the Navy has at least 2,526 such properties. The database does not identify

8559 historic properties that are included in the Pearl Harbor, Hawaii, historic district.

In addition, the database does not identify 295 family housing dwellings at various

locations, 64 properties at Naval Shipyard Portsmouth, Maine, nor 32 properties at the

Naval Academy, Maryland, as historic properties eligible for listing on the National

Register. The cultural resource office does not maintain records on properties eligible

 

8

 The Army has a category of 8,254 historic buildings called “World War II Wood.” DOD has an agreement with the Advisory

Council on Historic Preservation and the National Conference of State Historic Preservation Officers that allows it to

demolish all the buildings in this category. The Army plans to demolish most of its inventory of World War II Wood properties

but to maintain those for which there is an operational requirement. We did not include any buildings in this category in our

Army total.
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for listing on the Register, so we could not determine how many properties might be

eligible throughout the Navy.

• The Marine Corps uses the same real property database as the Navy, and it does not

identify properties that are eligible for listing on the Register. Our analysis of

available cultural resource records at Marine Corps headquarters indicates there are

590 properties eligible for listing, including 239 at the Marine Corps Combat

Development Center, Quantico, Virginia, and 210 at Marine Corps Base Camp Lejeune,

North Carolina.

• The Air Force cultural resource records identified 2,346 eligible properties; however,

the cultural resource office could not identify where 1,183 of these properties were

located. An Air Force cultural resource official stated that the number of eligible

properties was developed from a 1999 inquiry—telephone and e-mail responses—but

no supporting documentation was retained. The remaining 1,163 eligible properties

were family housing that the Air Force can identify by base.

Service officials stated they are aware of the inconsistencies in the number of historic

properties between the real property databases and the cultural resource records. Army

officials in the Office of the Assistant Chief of Staff for Installation Management stated that

they are working to reconcile the differences between the real property database and each

installation’s cultural resource records. The Navy cultural resource manager agreed that the

existing real property database does not accurately capture data on historic properties. He

also acknowledged that the database does not distinguish between properties that are listed

on the National Register and those determined to be eligible for listing, and whether

properties are part of a historic district or listed individually. However, he stated that the

Navy is updating the real property database to allow it to make these distinctions.

 

9

 The Navy is developing a programmatic agreement with the state of Hawaii regarding the potential reuse and demolition of

some of these properties.
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Most Historic Properties Are Being Used

Cultural resource officials in each of the service headquarters stated, and our own

observations confirmed, that the majority of the historic properties are being used. About 36

percent of all historic properties are family housing dwellings. There were, however, a

relatively small number of vacant buildings at some of the installations we visited. In some

cases, the installations were developing plans to lease these properties to the private sector.

At the installations we visited, 87, or about 4 percent, of the identified 2,395 historic

properties were vacant. In some cases, the buildings were vacant because the bases did not

have sufficient funds to make the buildings usable and/or the structures were no longer

needed for mission requirements. For example, 2 of the identified 65 historic properties at the

Naval Training Center, Great Lakes, were vacant because, according to the installation’s

Director of Public Works, funds were not available to repair and update the property for

administrative office space. At Portsmouth Naval Shipyard, Maine, there was no mission

requirement for the naval prison structure there that has been closed since 1974. Navy

officials at Portsmouth were trying to lease the prison building and six other historic

properties to the private sector. Other locations were also developing plans to lease vacant

buildings, including 40 historic buildings at Fort Sam Houston, Texas.10

Further, each of the services has demolished properties that no longer are needed to meet

mission requirements and have lost their historical significance or structural integrity. In

fact, seven of the nine installations we visited had demolished or reached an agreement with

their respective state preservation office to demolish certain historic properties. For

example, officials at Fort Bliss, Texas, stated they have an agreement to demolish 24 historic

properties as long as other historic properties that were considered more significant are

maintained. Likewise, 5 of the 107 original historic properties have been demolished at Scott

Air Base, Illinois.

The Potential for Increased Numbers of Historic

Properties in the Future is Uncertain

 

1010 U.S.C. 2667 allows DOD to lease nonexcess property to others.
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According to service real property databases, about 73,600 properties within the services will

turn 50 years of age over the next 10 years. As seen in table 2, housing accounts for about

46,400, or about 63 percent, of the properties that will turn 50 years of age over the next 10

years.

However, the services will not know whether any of these properties are eligible for listing

until the cultural resource officials at the various military installations evaluate the properties

using the National Register criteria.

Table 2: Properties Reaching 50 Years of Age

 between 2001 and 2010

Type of property Number Percent

Housing 46,461 63

Other 27,163 37

Total 73,624 100

Source: Military service real property databases.

Service plans to privatize11 and demolish housing over the next several years could reduce

the potential number of properties that would have to be evaluated by the services for listing

on the National Register. In addition, the Army is considering legislation that would seek to

exempt Cold War era housing known as Capehart and Wherry from National Historic

Preservation Act compliance.

The potential eligibility of the remaining properties will not be known until installation cultural

resource officials evaluate the properties to determine if they meet the National Register

criteria. This should occur over the next 10 years as the properties reach 50 years of age.

Although properties at the installations we visited comprise only a small portion of the

properties that will turn 50 years of age over the next 10 years, cultural resource officials at

most of these installations do not believe that many of these properties will be found to have

 

11Congress authorized the Military Housing Privatization Initiative, which permitted DOD to enter into a variety of

arrangements with private sector entities to build and renovate military housing both on or near military bases 10 U.S.C. 2871-

2885.
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historical significance or unique architectural features that would make them eligible for the

National Register. For example, the cultural resource officer at Fort Bliss believes only 48 of

its 381 properties could be eligible for the National Register.

INFORMATION ON THE COST TO MAINTAIN AND REPAIR

HISTORIC PROPERTIES IS NOT READILY AVAILABLE

We were unable to determine composite maintenance and repair cost for fiscal year 2000 for

DOD’s historic properties because the services do not identify or account separately for the

money spent to repair and maintain historic properties or to restore the historic aspects of

these properties. Our analysis of cost data and interviews with officials at several

installations indicate that overall, the day-to-day maintenance and repair conducted on

historic properties is similar to maintenance and repair on non-historic properties. However,

the costs of such maintenance can be proportionally greater where historic properties are

larger in size than non-historic properties. This is especially true of historic military family

housing. Replacement of unique historic features such as large porches, windows, and slate

or tile roofs can also add to the cost of maintenance and repair in the year that the work is

performed. In the past, the military services have provided annual budget exhibits to

Congress that showed the inventory and the cost to maintain, repair, and improve historic

family housing. The Department eliminated the cost exhibit for the fiscal year 2002 budget

submission, but it will still require the services to provide budget exhibits showing their

inventory of historic housing.

The military services do not routinely track information on the overall cost to maintain and

repair historic properties. In addition, they do not separately or otherwise distinguish

between money spent to maintain historic properties and that spent on non-historic

properties. Information obtained in our discussions with installation officials and review of

maintenance and repair projects and costs indicated that overall the day-to-day maintenance

of historic properties was similar to non-historic properties. Officials at most of the

installations we visited noted that deciding which maintenance and repair projects to fund is

based on mission and worse case conditions, and not on whether a property is historic or nonhistoric. Also, officials at each of the services noted growing backlogs of maintenance and

repair projects that limit the amount of preventive maintenance that is done on historic as
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well as non-historic properties. They stated that tradeoffs are often required to address the

most critical needs.

While available information indicates that day-to-day maintenance and repair conducted on

historic properties is similar to such work on non-historic properties, prior DOD and service

studies have also shown that the size of historic properties, especially historic military family

houses, can result in costs being larger when compared to non-historic properties. For

example, a 1997 Army family housing report to Congress12 stated that the average historic

house is 3,376 gross square feet while the average size of a non-historic house is 1,490 gross

square feet. On a square foot basis the report concludes routine maintenance and repair may

be comparable between historic and non-historic properties, about $2.60 per square foot. 13

However, the study states that “the larger the dwelling unit (more roof area, square feet of

walls and floors) the more maintenance and utilities funding required.” The 1997 Navy report

to Congress14 and a September 2000 draft DOD report15 provide similar data and conclusions.

At the same time, prior DOD and service historic reports and service officials we spoke with

indicated that the unique features of some historic buildings result in higher maintenance and

repair costs. Some historic houses have slate or tile roofs, copper downspouts and gutters, or

large wooden porches whereas most non-historic homes do not have these features. For

example, at Fort Leavenworth, craftsmen repaired porches averaging about 800 square feet

for about $20,757 each in fiscal year 1999. While repair or replacement of these features may

represent sizeable costs in the year in which they occur, some of these types of materials

may be cost-effective from a life-cycle standpoint. Service officials stated that while a

shingle roof might cost less than a slate roof initially, if life-cycle costs are considered the

cost may be the same, although the impact on an installation’s budget may be greatest in the

year in which the costs are incurred. Service officials stated that they know they must

replace existing slate or tile roofs on historic properties with the same material, so they do

not consider using any other material. As a result, they do not compare the cost of replacing

a slate roof with a shingle roof.

 

12 Report to Congress on Historic Army Quarters, Mar. 1997.

13 Fiscal year 1996 Army-wide family housing cost data from the Army’s real property database.

14 Department of Navy’s Response to Congress on Historic Preservation, Apr. 1997.

15 The Cost of Maintaining Historic Military Family Housing, Sept. 2000.
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Mr. Chairman, this completes my prepared statement. I would be happy to respond to any

questions you or other Members of the Subcommittee may have at this time.

Contact and Acknowledgement

For future questions regarding this testimony, please contact.

Barry Holman (202) 512-5581

Michael Kennedy (202) 512-8333

Other individuals making key contributions to this testimony included William Crocker and

Richard Meeks.

(350053)