MILITARY BASES

Opportunities Exist to 

Improve Future Base 

Realignment and 

Closure Rounds 

Report to Congressional Committees

March 2013 

GAO-13-149 

United States Government Accountability Office

GAO 
 United States Government Accountability Office 

Highlights of GAO-13-149, a report to 

congressional committees 

March 2013 

MILITARY BASES

Opportunities Exist to Improve Future Base 

Realignment and Closure Rounds 

Why GAO Did This Study 

As directed by the House Armed 

Services Committee, this report 

discusses lessons learned that could 

be applied if Congress chooses to 

authorize future BRAC rounds. GAO 

assessed (1) how DOD estimated 

BRAC costs and savings and any ways 

its methodology could be improved, (2) 

OSD leadership over BRAC 2005, and 

(3) any legislative changes Congress 

may wish to make that could enhance 

oversight of any future round. 

What GAO Found and Recommends 

The Department of Defense (DOD) developed and used a quantitative model 

known as the Cost of Base Realignment Actions (COBRA), which GAO has 

found to be a reasonable estimator for comparing potential costs and savings 

among candidate alternatives, to estimate the costs and savings associated with 

Base Realignment and Closure (BRAC) 2005 recommendations. However, 

DOD’s process for providing the BRAC Commission with cost and savings 

estimates was hindered in many cases by underestimating recommendationspecific requirements that were entered into the COBRA model. For example, 

military construction costs for BRAC 2005 increased from $13.2 billion estimated 

by the BRAC Commission in 2005 to $24.5 billion after implementation ended in 

2011. Most of this 86 percent increase was caused by requirements that were 

added or identified after implementation began. While GAO recognizes that some 

military construction requirements were added after DOD submitted its initial cost 

estimates to the BRAC Commission, GAO found that other cost estimates 

increased because requirements were initially understated or not identified as 

inputs into COBRA. DOD also did not fully anticipate information technology 

requirements for many recommendations. For example, the initial information 

technology cost estimate for one recommendation was nearly $31 million, but 

implementation costs increased to over $190 million once those requirements 

were better defined. Also, DOD was unable to always document the methodology 

used to estimate savings from reducing military personnel positions. Therefore, 

to increase the fidelity of the initial cost estimates that DOD submits with its 

recommendations to the BRAC Commission for a future BRAC round, GAO is 

recommending that the Office of the Secretary of Defense (OSD) improve the 

process for identifying and estimating the cost of requirements for military 

construction and information technology and update the guidance on 

documenting how it identifies military personnel position-elimination savings. 

The military services and other DOD components provided leadership and 

oversight over the 2005 BRAC round at the highest levels, and OSD established 

a governance structure that was led by higher-level leaders compared to 

previous rounds and included a larger role for specialized working groups. By 

implementing BRAC 2005, DOD closed 24 major bases, realigned 24 major 

bases, eliminated about 12,000 civilian positions, and achieved estimated net 

annual recurring savings of $3.8 billion; however, the department cannot provide 

documentation to show to what extent it reduced plant replacement value or 

vacated leased space as it reported in May 2005 that it intended to do. Also, 

DOD did not establish a target for reducing excess infrastructure, as it did in the 

1995 BRAC round. In addition, DOD bundled multiple closures and realignments 

into single, highly complex recommendations in its report to the Commission 

without itemizing the costs and savings associated with each separate major 

action, thus limiting visibility into the estimated costs and savings for individual 

closures and realignments. Further, OSD did not establish a process to ensure a 

timely security review of its supporting data to prevent the disclosure of classified 

information, thus delaying the Commission’s work. To improve planning for 

measuring results of a future BRAC round, GAO is recommending that DOD 

identify appropriate measures of effectiveness, develop a plan to demonstrate 

the extent to which it achieved intended results, and establish a target for View GAO-13-149. For more information, 

contact Brian J. Lepore at (202) 512-4523 or 

leporeb@gao.gov. 

The 2005 BRAC round was the 

biggest, most complex, costliest BRAC 

round ever. Unlike the four previous 

rounds, which focused on reducing 

infrastructure, the Secretary of 

Defense saw BRAC 2005 as a unique 

opportunity to adjust DOD’s base 

structure to meet new challenges, such 

as international terrorism and weapons 

of mass destruction, and to meet future 

challenges, such as designating where 

forces returning from overseas would 

be located. While DOD’s stated goals 

for BRAC 2005 included eliminating 

unneeded infrastructure, they also 

included furthering the transformation 

of DOD’s force structure and fostering 

joint capabilities among the military 

services, resulting in recommendations 

of unprecedented scope and 

complexity. As GAO found in June 

2012, BRAC implementation costs 

grew to about $35 billion, exceeding 

the initial 2005 estimate of $21 billion 

by 67 percent. As part of its fiscal year 

2013 budget request, DOD asked for 

two more rounds of BRAC in 2013 and 

2015. Congress has not acted on this 

request. 
Highlights of GAO-13-149 (Continued) 

United States Government Accountability Office

eliminating excess infrastructure in its initiating guidance, consistent with the selection criteria for a future BRAC round.

Also, to improve the availability of cost and savings information to BRAC decision makers, GAO is recommending that, 

when planning a future BRAC round, DOD limit the practice of bundling potentially stand-alone realignments or closures 

into single recommendations; but if DOD determines that bundling multiple realignments or closures into one 

recommendation is appropriate, itemize the costs and savings associated with each major action in its report to the BRAC 

Commission. Furthermore, GAO is recommending that OSD develop a process to conduct a timely security review of all 

BRAC data during DOD’s recommendation development process to resolve any data-security issues and better ensure 

that the BRAC Commission receives timely information for its independent review. 

Finally, GAO’s analysis of BRAC 2005 identified several opportunities where potential amendments to the BRAC statute 

could provide Congress with improved visibility over costs and savings expected from implementing BRAC 

recommendations and offer greater assurances about expected outcomes if future BRAC rounds are authorized. DOD’s 

goals for BRAC 2005 emphasized transformation and jointness. Although reductions in excess infrastructure to generate 

cost savings remained an important goal for DOD, the extent and timing of potential costs and savings, including the 

number of years it would take for the savings to exceed costs, was included as “other” or secondary criteria. As a result, 

many BRAC recommendations were not expected to produce 20-year net savings. Also, the BRAC Commission added 

contingency clauses to some recommendations, which allowed some outcomes to be defined by events or decisions that 

could occur after Congress could have prevented the BRAC recommendations from becoming binding, if it so chose. 

Hence, Congress had limited visibility into the potential cost of those recommendations. GAO is suggesting several 

matters for Congress to consider for amending the BRAC statute if it decides to authorize future BRAC rounds. First, if 

cost savings are to be a goal of any future BRAC round, Congress could elevate the priority DOD and the BRAC 

Commission give to potential costs and savings as a selection criterion for making BRAC recommendations. Second, 

Congress could consider requiring OSD to formally establish targets that the department expects to achieve from a future 

BRAC process and require OSD to propose selection criteria as necessary to help achieve those targets. Finally, 

Congress could consider whether to limit or prohibit the BRAC Commission from adding a contingent element to any 

BRAC recommendation and, if it is to be permitted, under what conditions. 

How GAO Conducted Its Work

For this report, GAO analyzed DOD’s 2005 report to the BRAC Commission and the Commission’s report to the President 

and reviewed BRAC policy memorandums, guidance, and other relevant documentation. To assess how DOD estimated 

BRAC costs and savings and any ways its methodology could be improved, GAO analyzed DOD’s COBRA model and 

DOD’s BRAC budget submissions to Congress. To assess OSD leadership over BRAC 2005 and opportunities to improve 

planning for future BRAC rounds, GAO interviewed officials from the 2005 BRAC Commission, the Office of the Deputy 

Under Secretary of Defense (Installations and Environment), the military services’ BRAC offices, and officials working with 

the joint cross-service groups. Finally, to assess what legislative changes, if any, Congress may wish to make that could 

enhance oversight of any future round, GAO reviewed the goals of BRAC 2005 and the criteria used to develop and 

evaluate BRAC 2005 recommendations, in addition to interviewing officials from the 2005 BRAC Commission and the 

Office of the Deputy Under Secretary of Defense (Installations and Environment). 

Agency Comments and GAO’s Evaluation

In commenting on a draft of this report, DOD did not concur with five out of ten recommendations, in part because it stated

that the intent of GAO’s recommendations to establish targets and measures of effectiveness was to prioritize capacity 

reductions over military value. However, nothing in these recommendations precludes optimizing military value while still 

measuring effectiveness and setting capacity reduction targets. The military value analysis could identify which 

installations have greatest value while still permitting DOD to reduce excess capacity as appropriate. Thus, GAO 

continues to believe that implementing these recommendations would help improve the BRAC process. 
Highlights of GAO-13-149 (Continued) 

United States Government Accountability Office

A summary of BRAC 2005 lessons learned, for which GAO has made recommendations to OSD and matters for Congress to 

consider in authorizing any future BRAC rounds, is provided in the table below. 

GAO Findings and Recommendations 

• Some requirements were understated or not included in initial BRAC cost estimates, such as military construction 

and information technology requirements. 

GAO is recommending that OSD improve the process for identifying these requirements as it develops 

initial cost estimates for a future BRAC.

• The standard factor for estimating information technology costs was understated. 

GAO is recommending that OSD update the standard factor for this expense item.

• DOD did not consistently document its basis for military personnel savings estimates.

GAO is recommending that OSD update its guidance on how it will identify these savings for a future 

BRAC round. 

• Some intended BRAC results were not tracked.

GAO is recommending that OSD identify appropriate measures of effectiveness and develop a plan to 

demonstrate the extent it achieved intended results for a future BRAC round. 

• OSD did not establish a target for reducing excess infrastructure. 

GAO is recommending that OSD establish a reduction target in its initiating guidance, consistent with the 

selection criteria for a future BRAC round.

• Bundling of multiple closures or realignments into a single recommendation limited visibility of costs and savings 

in OSD’s report to the BRAC Commission. 

GAO is recommending that OSD limit this practice, or itemize the costs and savings associated with each 

major action if OSD determines that bundling multiple realignments or closures into one 

recommendation is appropriate.

• A timely review of BRAC supporting data for potential security risks did not take place.

GAO is recommending that OSD develop a process for a future BRAC round to resolve any data-security 

issues so the BRAC Commission receives the supporting data in a timelier manner for its independent 

review. 

• Cost savings was not a priority consideration in the BRAC statutory selection criteria nor was cost savings a 

priority when OSD established goals for the BRAC 2005 round. 

If cost savings are to be a goal of any future BRAC round, GAO is suggesting that Congress consider 

amending a future BRAC statute by (1) elevating the priority DOD and the BRAC Commission give to 

potential costs and savings as a selection criterion for making BRAC recommendations, (2) requiring 

OSD to formally establish specific goals that the department expects to achieve from a future BRAC 

process, and (3) requiring OSD to propose selection criteria as necessary to help achieve those goals.

• Contingency clauses for some BRAC recommendations limited Congress’s visibility of complete cost information 

and expected outcomes. 

GAO is suggesting that Congress consider in a future BRAC statute whether to limit or prohibit the BRAC 

Commission from adding a contingent element to any BRAC recommendation and, if permitted, under 

what conditions.
Page i GAO-13-149 Military Bases 

Letter 1 

Background 6

DOD Used a Reasonable Model to Estimate Costs and Savings, but 

Increased Attention to Requirements Entered into the Model 

Would Enhance the Reliability of the Initial Estimates 23

High-Level Leadership and a New Governance Structure Guided 

BRAC 2005 Planning and Management, but Opportunities Exist 

to Enhance Planning of Future BRAC Rounds 34

Several Amendments to the BRAC Statute Could Offer Congress 

Greater Assurances of Future BRAC Outcomes 50

Conclusions 58

Recommendations for Executive Action 60

Matters for Congressional Consideration 62

Agency Comments and Our Evaluation 62

Appendix I Objectives, Scope, and Methodology 70 

Appendix II List of Prior GAO Reviews Related to BRAC 2005, Related 

Recommendations, and DOD Actions to Date 75 

Appendix III Comments from the Department of Defense 95 

Appendix IV GAO Contact and Staff Acknowledgments 101 

Related GAO Products 102

Tables 

Table 1: BRAC Actions for All BRAC Rounds 22

Table 2: Examples of BRAC Recommendations Estimated to Have 

20-Year Net Costs 54

Contents 
Page ii GAO-13-149 Military Bases 

Figures 

Figure 1: Timeline of BRAC 2005 Round 7

Figure 2: DOD Criteria for the 1995 and 2005 BRAC Rounds 11

Figure 3: DOD’s BRAC 2005 Recommendation Development 

Process 12

Figure 4: Key Inputs and Outputs of the COBRA Model 14

Figure 5: Defense Budget Authority for Fiscal Years 1987 through 

2011 21

Figure 6: Uses of the COBRA Model in the BRAC Process 24

Figure 7: DOD’s BRAC Leadership Structure 36

Figure 8: Legislatively Codified Selection Criteria for the BRAC 

2005 Round 52

Figure 9: Timeline Showing Decision Points Related to Cannon Air 

Force Base and Oceana Naval Air Station Contingency 

Recommendations 58

Abbreviations 

BRAC base realignment and closure 

COBRA Cost of Base Realignment Actions 

DOD Department of Defense 

OSD Office of the Secretary of Defense

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Page 1 GAO-13-149 Military Bases 

United States Government Accountability Office

Washington, DC 20548 

March 7, 2013 

Congressional Committees 

The 2005 Base Realignment and Closure (BRAC) round1

 was the fifth 

round of base closures and realignments undertaken by the Department 

of Defense (DOD) since 1988, and it was the biggest, most complex, 

costliest BRAC round ever. DOD manages a global real-property portfolio 

consisting of more than 555,000 facilities worldwide, with a replacement 

value of nearly $850 billion. Since 1988, DOD has relied on the BRAC 

process as an important means of reducing excess infrastructure and 

realigning bases to meet changing force structure needs. However, in 

2005, the Secretary of Defense noted that the decade since the previous 

BRAC round had been a period of dramatic change involving new 

challenges posed by international terrorism, the proliferation of weapons 

of mass destruction, ungoverned areas, rogue states, and nonstate 

actors. Unlike previous BRAC rounds, which focused on reducing excess 

infrastructure, the Secretary saw BRAC 2005 as a unique opportunity to 

adjust U.S. base structure to meet these developments, and to be 

positioned to meet the challenges envisioned during the next two 

decades, such as designating where forces returning to the United States 

from overseas bases would be located. 

In addition, BRAC 2005 was unique in that it was conducted in an era 

generally characterized by growing defense budgets and increasing 

military personnel levels amid ongoing operations in Afghanistan and 

Iraq, while every BRAC round prior to 2005 was conducted in an era 

characterized by declining defense budgets and reductions to military 

personnel levels as the Cold War drew to a close. Also, unlike prior BRAC 

rounds where the focus was on eliminating excess capacity and realizing 

cost savings, the 2005 BRAC round was implemented during a time of 

conflict when many military capabilities were surging and DOD was 

implementing other extensive worldwide transformation initiatives such as 

 

1

Congress authorized BRAC 2005 with the passage of the National Defense Authorization 

Act for Fiscal Year 2002, Pub. L. No. 107-107, Title XXX (2001). The law reauthorized the 

BRAC process by amending the authority under which the 1991, 1993, and 1995 rounds 

had been carried out, the Defense Base Closure and Realignment Act of 1990, Pub. L. 

No. 101-510, Title XXIX (10 U.S.C. 2687 note). Throughout this report, we will refer to the 

Defense Base Closure and Realignment Act of 1990 (as amended) as “the BRAC statute.” 

 
 

Page 2 GAO-13-149 Military Bases 

relocating soldiers primarily from Europe and Korea to the United States, 

and transforming the Army’s force structure from an organization based 

on divisions to more rapidly deployable, brigade-based units, which in 

turn also affected DOD’s facility infrastructure requirements. Therefore, in 

addition to reducing excess infrastructure and producing savings, DOD’s 

goals for BRAC 2005 included furthering transformation and fostering 

jointness. Finally, both DOD and the BRAC Commission2

 reported that, 

as in prior rounds, their primary consideration in making and evaluating 

recommendations for the 2005 round was military value.3

Consequently, in contrast to prior rounds, many of the BRAC 2005 

recommendations involved complex realignments such as colocating like 

organizations and functions across the military services on one 

installation, supporting the activation of brigade combat teams, moving 

numerous organizations and activities from leased space to DOD-owned 

installations, creating a new Maneuver Center for ground combat training, 

and reconfiguring the defense supply, storage, and distribution network. 

Compared to previous BRAC rounds, the BRAC 2005 round also 

contained more recommendations aimed at fostering jointness, such as 

expanding and establishing joint military medical centers, consolidating all 

the military services’ enlisted medical training at one installation, and 

creating new joint centers of excellence. According to the Secretary of 

Defense’s 2005 base closure and realignment report, the base closure 

and realignment recommendations the department generated from the 

2005 round addressed almost every defense mission area and affected 

most of the department’s major U.S. installations. To implement this 

round, DOD executed hundreds of BRAC actions involving over 800 

defense locations and the planned relocation of about 125,000 personnel. 

 

2

The BRAC statute establishes an independent commission to review the Secretary of 

Defense’s realignment and closure recommendations, with the authority to change these 

recommendations in certain circumstances if it determines that the Secretary deviated 

substantially from the legally mandated selection criteria and a DOD force structure plan. 

The 2005 Defense Base Closure and Realignment Commission (referred to in this report 

as the BRAC Commission) presented its list of final recommendations to the President of 

the United States, who approved them in their entirety. The President subsequently 

forwarded these BRAC recommendations to Congress, and they became effective on 

November 9, 2005. 

3

Military value refers to the four BRAC selection criteria (see figure 1) given priority 

consideration by the Secretary and BRAC Commission in the making of recommendations 

for closures or realignments. The military value criteria include such considerations as an 

installation’s current and future mission capabilities, condition, ability to accommodate 

future needs, and cost of operations. 
 

Page 3 GAO-13-149 Military Bases 

The BRAC Commission acknowledged in its 2005 report that the 2005 

round resulted in recommendations of unprecedented scope and 

complexity, including more base realignments with interrelated 

implementation schedules and more bases that were affected by multiple 

recommendations than any previous round. While DOD advanced a 

number of its goals for the 2005 BRAC round—eliminating some excess 

physical capacity, making progress toward transforming its forces and 

support systems to meet new threats, and establishing joint bases and 

centers—these efforts came at a higher cost to the department than 

initially anticipated. As we reported in June 2012,4

 overall onetime 

implementation costs for BRAC 2005 grew from $21 billion originally 

estimated by the BRAC Commission in 2005 to about $35.1 billion, an 

increase of about $14.1 billion, or 67 percent.5

 In addition, as the Deputy 

Under Secretary of Defense (Installations and Environment) testified in 

March 2012,6

 BRAC 2005 was a major engine of recapitalization.7 As a 

result, military construction costs funded from the BRAC 2005 account 

through fiscal year 2011 totaled $24.5 billion. In contrast, military 

construction costs for the four prior BRAC rounds combined amounted to 

less than $7 billion. 

Further, due to its scope and complexity, this BRAC round required more 

detailed planning and management by the Office of the Secretary of 

Defense (OSD) and the military services to ensure that all required 

actions would be completed by the statutorily imposed deadline of 

September 2011. In 2002, the Secretary of Defense emphasized that the 

effort to reconfigure DOD’s infrastructure to maximize both warfighting 

capability and efficiency through BRAC required the focus and 

prioritization only senior leadership could bring. In prior work on 

successful organizational mergers and transformations, we found that, 

 

4

GAO, Military Base Realignments and Closures: Updated Costs and Savings Estimates 

from BRAC 2005, GAO-12-709R (Washington, D.C.: June 29, 2012). 

5

DOD calculated the $35.1 billion in onetime implementation costs using fiscal year 2011 

dollars, which includes inflation, while the BRAC Commission estimate of $21 billion is in 

constant fiscal year 2005 dollars, which excludes inflation. In constant 2005 dollars, costs 

increased to about $32.2 billion, an increase of 53 percent. 

6

Hearing on the Request for Authorization of Another BRAC Round and Additional 

Reductions in Overseas Bases, Before the Readiness Subcommittee of the House 

Committee on Armed Services, 112th Congress (Mar. 8, 2012) (written statement of Dr. 

Dorothy Robyn, Deputy Under Secretary of Defense for Installations and Environment). 

7

Recapitalization occurs when facilities need to be repaired or rebuilt. 
 

Page 4 GAO-13-149 Military Bases 

when federal agencies seek to transform their cultures in response to 

governance challenges, a key practice is to ensure that top leadership 

drives the transformation.8

Speaking before the Association of Defense Communities annual 

conference in August 2012, the Secretary of Defense stated that as DOD 

draws down its forces from the wars of this last decade, it will be moving 

toward a smaller, leaner, and more-agile force over the next 5 years for 

both strategic and financial reasons. The Secretary noted that DOD faces 

tough fiscal constraints due to the very real financial crisis confronting the 

country and that as the force structure drew down, having to incur costs 

to maintain large infrastructure would reduce the funds needed to train 

and support service members. As part of its fiscal year 2013 budget 

request, DOD asked for two more rounds of BRAC in 2013 and 2015. 

Although Congress has thus far declined to authorize additional BRAC 

rounds, Congress has previously taken the opportunity to amend the 

BRAC statute in various ways, as when authorizing the 2005 BRAC round 

requested by DOD. Should Congress decide to authorize one or more 

additional rounds in the future, similar legislation would be needed. 

Since 2005, we have issued over 30 reports and testimonies on BRAC 

2005 planning, implementation, costs, and savings that could highlight 

information DOD can use to improve the BRAC recommendation 

development and implementation process. See appendix II for certain 

BRAC-related reports with a description of our findings and 

recommendations. The Related GAO Products page at the end of this 

report provides a more complete listing of our BRAC reports and 

testimonies. 

We are conducting this work as directed by the House Armed Services 

Committee in its report accompanying the National Defense Authorization 

Act for 2008.9

 The purpose of this report is to discuss lessons learned that 

can be applied to any future BRAC rounds. Specifically, our objectives 

were to assess: (1) how DOD estimated the costs and savings for BRAC 

2005, and to what extent could its methodology be improved; (2) to what 

extent OSD provided high-level leadership over BRAC 2005, and what 

 

8

GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers and 

Organizational Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003). 

9

H.R. Rep. No. 110-146, at 514 (2007). 
 

Page 5 GAO-13-149 Military Bases 

opportunities, if any, exist to enhance planning for any future BRAC 

round; and (3) what legislative changes, if any, could Congress make that 

would enhance the oversight of a future round of BRAC. 

To achieve these objectives, we analyzed our extensive body of prior 

work related to all five BRAC rounds to identify key issues and broad 

trends; we also analyzed DOD’s May 2005 base realignment and closure 

report and the 2005 BRAC Commission’s September 2005 report to the 

President, reviewed OSD policy memorandums and guidance on 

conducting BRAC 2005, and examined other relevant documentation 

such as supporting BRAC reports prepared by the military services or 

other components related to the development of BRAC 2005 

recommendations. To determine how DOD estimated the costs and 

savings that would result from BRAC 2005 and the extent to which its 

methodology might be improved, we analyzed DOD’s cost-estimating 

model, the Cost of Base Realignment Actions (COBRA), and it’s 

supporting documentation; we interviewed officials in OSD’s Basing 

Directorate, and other officials knowledgeable about the cost and savings 

estimates developed for BRAC 2005; and we used DOD’s BRAC 2005 

budget submissions to Congress as well as our previous work to assess 

the changes in BRAC 2005 costs and savings estimates. 

To determine the extent to which OSD provided high-level leadership 

over the planning and management of BRAC 2005, and what 

opportunities, if any, exist to enhance planning and management of any 

future BRAC round, along with other documents, we reviewed OSD policy 

and guidance documents and the 2005 BRAC Commission Report to the 

President. In addition, we interviewed the Chairman of the 2005 BRAC 

Commission and members of the Commission’s executive staff, and the 

former Deputy Under Secretary of Defense (Installations and 

Environment) who oversaw BRAC 2005 between April 2001 and 

November 2004 to obtain their insights on the BRAC 2005 process. 

To determine what, if any, legislative changes Congress could make to 

enhance oversight of a future round of BRAC, we reviewed the process 

for developing and implementing BRAC 2005 recommendations, and 

compared that process to those used in prior rounds of BRAC. We 

reviewed the goals of BRAC 2005 and the criteria used to develop and 

evaluate BRAC 2005 recommendations. We interviewed officials from the 

2005 BRAC Commission; the Office of the Deputy Under Secretary of 

Defense’s (Installations and Environment) Basing Directorate, which is 

responsible for overseeing BRAC implementation; and associated BRAC 
 

Page 6 GAO-13-149 Military Bases 

implementation offices in the Army, the Navy, and the Air Force, and 

other DOD components that were involved in BRAC 2005. 

We began this performance audit in March 2011, but suspended the 

review at various points to respond to several congressional hearings 

related to BRAC10 and to prepare a separate product that updated the 

costs and savings estimates associated with BRAC 2005 

implementation.11 We reinstated this review in August 2012, and 

completed it in March 2013. We conducted this performance audit in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Further details on our scope 

and methodology can be found in appendix I. 

Congress established clear time frames in the BRAC statute for many of 

the milestones involved with base closures and realignments, and BRAC 

2005 took 10 years from authorization to completion. Congress 

authorized the BRAC 2005 round in 2001. DOD then established its own 

internal requirements, expressed the goals of the BRAC round, and spent 

about 2 years collecting data and developing a list of proposed base 

realignment and closure actions to submit to the independent 

Commission for review. The BRAC Commission then had about 4 months 

to assess and amend the recommendations for submission to the 

President. After the President’s certification of approval and transmission 

of the recommendations to Congress, Congress had approximately a 

45-day period in which it could disapprove the recommendations, under a 

 

10GAO, Military Base Realignments and Closures: Key Factors Contributing to BRAC 

2005 Results, GAO-12-513T (Washington, D.C.: Mar. 8, 2012); Federal Real Property: 

Proposed Civilian Board Could Address Disposal of Unneeded Facilities, GAO-11-704T 

(Washington, D.C.: June 9, 2011); and Federal Real Property: Progress Made on 

Planning and Data, but Unneeded Owned and Leased Facilities Remain, GAO-11-520T 

(Washington, D.C.: Apr. 6, 2011). 

11GAO-12-709R. 

Background 

BRAC 2005 Was a 10-Year 

Process 
 

Page 7 GAO-13-149 Military Bases 

joint-resolution process specified in the BRAC statute, without which the 

recommendations became binding. Finally, the BRAC statute required 

DOD to complete recommendations for closing or realigning bases made 

in BRAC 2005 by September 15, 2011—6 years from the date the 

President submitted his certification of approval of the recommendations 

to Congress. Figure 1 displays the timeline of the BRAC 2005 round. 

Figure 1: Timeline of BRAC 2005 Round 

In carrying out this 10-year process, Congress played a considerable role. 

For the most part, the framework adopted in the authorizing legislation for 

the 2005 BRAC round was rooted in the historical framework used in 

previous rounds. The Defense Base Closure and Realignment Act of 

1990 created what has become a structured process for making BRAC 

recommendations, one that gives the public insight into the basis for 

recommendations made by the Secretary of Defense. DOD also played a 

considerable role in that it established the analytical framework for 

developing the BRAC recommendations and implemented the 

recommendations that became binding. 
 

Page 8 GAO-13-149 Military Bases 

The 2005 BRAC round process generally followed the legislative 

framework of previous BRAC rounds, with many elements of the process 

carried forward or built upon lessons learned from the past. For example, 

in the statute authorizing the 2005 BRAC round, Congress directed DOD 

to propose and adopt final selection criteria that followed a framework 

similar to the criteria employed in previous BRAC rounds.12 Also, the 

authorizing statute for BRAC 2005 required DOD to base its 

recommendations on the use of certified data, an infrastructure inventory, 

and a force structure plan, similar to past BRAC rounds.13

DOD collected capacity and military value data that were certified as to 

their accuracy by hundreds of persons in senior leadership positions 

across the country. Specifically, the data had to be certified as accurate 

and complete to the best of the originator’s knowledge and belief. This 

requirement was designed to overcome concerns about the consistency 

and reliability of data used in the process. These certified data were 

obtained from DOD databases and from hundreds of defense 

installations. DOD continued to collect certified data, as needed, to 

support follow-up questions and cost calculations, and to develop 

recommendations. The Secretary of Defense testified before the BRAC 

Commission in May 2005 that, in total, DOD estimated that it collected 

25 million pieces of data as part of the BRAC 2005 process. Given the 

extensive volume of requested data from the 10 separate groups (three 

military departments and seven joint cross-service groups), we noted in 

our July 2005 report14 that the data-collection process was quite lengthy 

and required significant efforts to help ensure data accuracy, particularly 

from joint cross-service groups that were attempting to obtain common 

data across multiple military components. In some cases, coordinating 

data requests, clarifying questions and answers, controlling database 

entries, and other issues led to delays in the data-driven analysis DOD 

originally envisioned. As time progressed, however, these groups 

 

12Pub. L. No. 107-107, § 3002 (2001) (amending the BRAC statute by adding a new 

section 2913). 

13Id., § 3003 (2001) (amending the BRAC statute by adding a new section 2914). Unlike in 

previous rounds, where the force structure plan was based on a 6-year period, the force 

structure plan for BRAC 2005 was based on a 20-year period. See §§ 2903(a), 2912(a) of 

the BRAC statute, as amended. 

14GAO, Military Bases: Analysis of DOD’s 2005 Selection Process and Recommendations 

for Base Closure and Realignments, GAO-05-785 (Washington D.C.: July 1, 2005). 

Congress Established a 

Legislative Framework for 

BRAC 

Use of Certified Data 
 

Page 9 GAO-13-149 Military Bases 

reported that they obtained the needed data, for the most part, to inform 

and support their scenarios. The DOD Inspector General and the 

services’ audit agencies played an important role in ensuring that the data 

used in the BRAC analyses were accurate and certified by cognizant 

senior officials. 

Each of the military services and the seven joint cross-service groups 

established by DOD were subject to the requirement of the BRAC statute 

that DOD consider its 20-year force structure plan and existing 

infrastructure inventory in making its recommendations for BRAC 2005.15

As we reported in 2004,16 DOD was required to provide a comprehensive 

inventory of military installations worldwide for each military department, 

with specifications of the number and type of facilities in the active and 

reserve forces of each department. DOD based its force structure plan for 

BRAC purposes on an assessment of probable threats to national 

security during a 20-year period beginning with fiscal year 2005. DOD 

provided this plan to Congress in March 2004, and, as authorized by the 

statute, the department subsequently updated the plan 1 year later in 

March 2005. These updates to the force structure affected some ongoing 

BRAC analyses at the time. For example, the Industrial Joint CrossService Group reassessed its data pertaining to overhauling and repairing 

ships on the basis of the updated force structure outlook and decided that 

one of its two smaller shipyards—Naval Shipyard Pearl Harbor, Hawaii, or 

Naval Shipyard Portsmouth, Maine—could close. Ultimately, the Navy 

proposed to close the Portsmouth shipyard in Maine; however this 

candidate recommendation was rejected by the Commission during its 

review. In addition, the Navy told us in 2005 that it recalculated its 

capacity on the basis of updates to the force structure plan and 

determined that there was no significant change to its original analysis. 

The other groups, such as those examining headquarters and support 

activities, education and training, or technical functions, considered 

updates to the defense 20-year force structure and determined the 2005 

force structure changes would have no effect on their development of 

recommendations. 

 

15Section 2914(a) of the BRAC statute required DOD to make its recommendations for 

closure or realignment on the basis of the force structure plan and infrastructure inventory 

prepared under section 2912, and the final selection criteria specified under section 2913. 

16GAO, Military Base Closures: Assessment of DOD’s 2004 Report on the Need for a 

Base Realignment and Closure Round, GAO-04-760 (Washington, D.C.: May 17, 2004). 

Consideration of DOD’s 

Infrastructure Inventory and 

20-Year Force Structure Plan 
 

Page 10 GAO-13-149 Military Bases 

The 2001 legislation authorizing the 2005 BRAC round directed DOD to 

propose and adopt selection criteria that would give priority to military 

value.17 (In prior rounds the department made military value the primary 

consideration as a matter of policy.) As figure 2 shows, the first four of 

eight criteria DOD was required to use to develop and select its candidate 

BRAC recommendations were related to military value. The manner in 

which each military service or joint cross-service group approached its 

analysis of military value varied according to the unique aspects of the 

individual service or cross-service function. These groups typically 

assessed military value by identifying multiple attributes or characteristics 

related to each military value criterion, then identifying qualitative metrics 

and measures and associated questions to collect data to support the 

overall military value analysis. For the 2005 round, the BRAC statute was 

amended to enhance the emphasis placed on two aspects of military 

value—an installation’s ability to serve as a staging area for homeland 

defense missions and its ability to meet unanticipated surge 

requirements—compared to military value criteria for prior rounds (1991, 

1993, and 1995), which did not include these emphases.18 In addition to 

the priority military value criteria, the 2001 authorizing statute directed 

DOD to address four “other considerations” in its selection criteria. 

Figure 2 compares the 1995 BRAC criteria with those adopted for 2005, 

with changes applicable for the BRAC 2005 round highlighted in color. 

 

17The statute authorizing BRAC 2005, Pub. L. No. 107-107, § 3002 (2001), amended the 

BRAC statute by inserting a new section, § 2913, which directed DOD to ensure that 

“military value” was the primary consideration for BRAC recommendations. Specifically, it 

described a number of considerations to be included at a minimum in the military value 

criteria, while also establishing four “special considerations” to be addressed in selection 

criteria outside of military value. Consistent with prior BRAC rounds, the law also required 

DOD to publish its proposed criteria in the Federal Register. DOD proposed its criteria at 

68 Fed. Reg. 74221 (2003) and spelled out its final criteria at 69 Fed. Reg. 6948 (2004). 

18Congress codified the criteria as adopted by DOD, adding “surge” requirements as a 

consideration. Ronald W. Reagan National Defense Authorization Act for Fiscal Year 

2005, Pub. L. No. 108-375, § 2832 (2004). 

Primary Consideration of 

Military Value Criteria 
 

Page 11 GAO-13-149 Military Bases 

Figure 2: DOD Criteria for the 1995 and 2005 BRAC Rounds 
 

Page 12 GAO-13-149 Military Bases 

In a 1997 report on lessons learned from previous BRAC rounds, and 

again in 2005,19 we affirmed the soundness of these basic criteria and 

generally endorsed their retention for the future, while recognizing the 

potential for improving the process by which the criteria are used in 

decision making. Adoption of these criteria adds to the approach an 

element of consistency and continuity with those of past BRAC rounds. 

On the basis of our analytical work, we reported in July 200520 that DOD 

established and generally followed a logical and reasoned process for 

formulating its list of BRAC 2005 recommendations. The BRAC 

recommendations, for the most part, resulted from a data-intensive 

process that was supplemented by the use of military judgment as 

needed. The process began with a set of sequential steps by assessing 

capacity and military value, developing and analyzing scenarios, then 

identifying candidate recommendations, which led to the Office of the 

Secretary of Defense’s (OSD) final list of BRAC recommendations as 

depicted in figure 3. 

Figure 3: DOD’s BRAC 2005 Recommendation Development Process 

 

19GAO, Military Bases: Lessons Learned From Prior Base Closure Rounds, 

GAO/NSIAD-97-151 (Washington, D.C.: July 25, 1997); Military Base Closures: 

Observations on Prior and Current BRAC Rounds, GAO-05-614 (Washington, D.C.: May 

3, 2005). 

20GAO-05-785. 

DOD’s Analytical 

Framework for Developing 

BRAC Recommendations 
 

Page 13 GAO-13-149 Military Bases 

In addition, OSD established an oversight structure that allowed the 

seven individual joint cross-service groups21 to play a larger, more visible 

role in the 2005 BRAC process compared to BRAC 1995. Despite some 

overlap in data collection and other phases of the process, these groups 

and the military services generally followed the sequential BRAC process 

designed to evaluate and subsequently identify recommendations within 

their respective areas, with only the Army using a separate but parallel 

process to evaluate its reserve components. DOD provided overall policy 

guidance for the BRAC process, including a requirement that its 

components develop and implement internal control plans to ensure the 

accuracy and consistency of their data collection and analyses. These 

plans also helped to ensure the overall integrity of the process and the 

information upon which DOD considered each group’s recommendations. 

To provide a framework for promoting consistency in estimating the costs 

and savings associated with various proposed BRAC recommendations, 

DOD used an estimation model, known as the Cost of Base Realignment 

Actions (COBRA). The COBRA model has been used in the base closure 

process since 1988. DOD designed the COBRA model to provide 

consistency across the military services and joint cross-service groups in 

estimating BRAC costs and savings, and OSD officials told us it is used to 

ensure that all installations are treated equally during the process of 

selecting candidate recommendations.22 It provided important financial 

information to the selection process as decision makers weighed the 

financial implications for various BRAC actions along with military value 

and other selection criteria when arriving at final decisions regarding the 

suitability of BRAC recommendations. Specifically, DOD is required to 

consider the extent and timing of potential costs and savings, including 

the number of years until savings exceed costs, as a selection criterion in 

its BRAC selection process.23 The COBRA model relies to a large extent 

 

21The Secretary of Defense established the seven joint cross-service groups, each led by 

senior military or civilian officials and each tasked with evaluating scenarios and ultimately 

developing realignment and closure recommendations related to a common business–

oriented support function that crossed military services and defense agencies—Education 

and Training, Headquarters and Support Activities, Industrial, Intelligence, Medical, Supply 

and Storage, and Technical. 

22Section 2903(c)(3)(A) of the BRAC statute requires that the Secretary of Defense 

consider all military installations inside the United States equally without regard to whether 

the installation has been previously considered or proposed for closure or realignment. 

23This is specified as one of the “other criteria” in § 2913(c)(1) of the BRAC statute, as 

amended. 

Cost of Base Realignment 

Actions Model 
 

Page 14 GAO-13-149 Military Bases 

on standard factors and averages, and it is not intended to represent 

budget-quality estimates. We have examined COBRA in the past and 

have found it to be a generally reasonable estimator for comparing 

potential costs and savings among candidate alternatives. In the 

intervening years, COBRA has been revised to address certain problems 

we and others have identified after each round. 

The COBRA model expresses cost and savings estimates in constantyear dollars and does not include expected inflation over the 6-year 

implementation period. Constant dollars measure the value of purchased 

goods and services at price levels that are the same as the base-year 

level. Constant dollars do not contain any adjustments for inflation that 

have occurred outside the base year. In contrast, then-year dollars 

measure the value of goods and services at price levels that contain all 

inflationary increases expected to occur in a program over the duration of 

its appropriation. Then-year dollars are also called “current” or “nominal” 

dollars. 

It is important to note that, as with any model, the quality of the output is 

dependent on the quality of the input. Key inputs and outputs of the 

COBRA model are shown in figure 4. 

Figure 4: Key Inputs and Outputs of the COBRA Model 
 

Page 15 GAO-13-149 Military Bases 

The three key financial measures that the COBRA model generates are 

as follows: 

 Onetime implementation costs—represent the investment DOD has to 

make in facility construction, renovation, and other up-front expenses. 

 Net annual recurring savings—calculated by deducting DOD 

estimates of the annual recurring costs from the annual recurring 

savings that are expected to accrue in 2012, the year after the BRAC 

2005 recommendations have been completed and are expected to be 

in a steady state (for simplicity, in this report we refer to these 

recurring savings as net annual savings). 

 Net present value—a financial calculation that accounts for the time 

value of money by determining the present value of future savings 

minus up-front investment costs over a specific period of time. We 

have previously reported that 20-year net present value is a key 

indicator of expected cost results.24 Determining net present value is 

important because it illustrates both the up-front investment costs and 

long-term savings in a single amount. In the context of BRAC 2005 

implementation, net present value is calculated for a 20-year period 

from 2006 through 2025. 

The statute authorizing BRAC 2005 directed that, should a BRAC round 

occur, a new Treasury account was to be established for purposes 

specified for BRAC 2005.25 In addition, the BRAC statute requires DOD to 

submit annual reports to Congress as part of its budget request, including 

a schedule containing revised BRAC cost and savings estimates for each 

closure and realignment recommendation.26 The cost data reflected in the 

BRAC account accurately reflect all BRAC related costs, according to the 

BRAC budget overview to Congress. DOD presents its schedule in its 

annual budget request to Congress, which includes its request for the 

appropriations needed to fund BRAC implementation costs. 

 

24GAO-12-709R. 

25Pub. L. No. 107-107, § 3005 (2001) (amending the BRAC statute by adding a new 

section 2906A). 

26Section 2907 of the BRAC statute. 

Budgeting for BRAC 

Implementation 
 

Page 16 GAO-13-149 Military Bases 

The BRAC statute also established an independent Defense Base 

Closure and Realignment Commission27 to review and analyze DOD’s 

recommendations, make changes if needed, and report its findings, 

conclusions, and recommendations to the President.28 For BRAC 2005, 

the Commission consisted of nine commissioners supported by a staff of 

over 100 persons drawn from diverse backgrounds encompassing 

government, law, academia, and the military in temporary positions.29 

The BRAC Commission was formed shortly before receiving the 

Secretary of Defense’s submissions. The BRAC Commission could 

approve, modify, reject, or add closure and realignment 

recommendations, subject to certain procedural requirements. Also, the 

BRAC Commission provided opportunities to interested parties, as well as 

community and congressional leaders, to provide testimony and express 

viewpoints. The Commission then voted on each individual closure or 

realignment recommendation, and those that were approved were 

included in the Commission’s report to the President. 

On September 8, 2005, the BRAC Commission submitted a report to the 

President reporting that the Secretary made more recommendations, with 

more complexity, than all four previous base closure rounds combined. 

The Commission also reported that it assessed the BRAC 

recommendations for consistency with the eight statutory selection criteria 

and the DOD force structure plan, and forwarded 182 recommendations 

to the President. The Commission approved 119 recommendations with 

no change, amended 45 recommendations, significantly modified 13 

recommendations, added 5 of its own, and rejected 13 recommendations 

in their entirety. After receiving the Commission’s final recommendations, 

the President was to review the recommendations of the Secretary of 

Defense and the Commission and prepare a report by September 23, 

2005, containing his approval and certification of all the 

recommendations, or disapproval of the Commission’s recommendations 

 

27Id., §§ 2902(a), 2912(d). 

28Id., §§ 2903(d), 2914(d). 

29GAO detailed six staff to the BRAC 2005 Commission to assist in the Commission’s 

independent analysis of the Secretary of Defense’s candidate recommendations. 

Congress Established a 

Review Structure 
 

Page 17 GAO-13-149 Military Bases 

in whole or in part.30 The President submitted his report and certification 

of approval of the 2005 Commission’s recommendations to Congress on 

September 15, 2005. Relying on the BRAC Commission’s report to inform 

its decision, the House of Representatives voted down a joint resolution 

to disapprove the Commission’s recommendations,31 and since Congress 

did not pass such a resolution, the recommendations became binding on 

November 9, 2005.32 Finally, the BRAC statute required DOD to complete 

recommendations for closing or realigning bases made in the BRAC 2005 

round within the 6-year time frame ending on September 15, 2011, 

6 years from the date the President submitted his approval of the 

recommendations to Congress. 

Closing unneeded defense facilities has historically been difficult because 

of public concern about the economic effects of closures on communities 

and the perceived lack of impartiality in the decision-making process. 

Since 1977, section 2687 of Title 10 of the United States Code has set 

the general conditions under which military installations may be closed or 

realigned. It prohibits any action to effect certain closures or realignments 

of military installations unless, among other things, DOD provides notice 

of the proposed closure or realignment to Congress, along with reports on 

fiscal, local, economic, environmental, strategic, and operational 

consequences of the proposal.33 The 2005 BRAC Commission noted in 

 

30Had the President disapproved of the Commission’s recommendations, the Commission 

would have had until October 20, 2005, to submit a revised list of recommendations to the 

President for further consideration. If the President had not submitted a report and 

certification to Congress of his approval of the Commission’s revised recommendations by 

November 7, 2005, the BRAC process would have been terminated. 

31H.R. J. Res. 65, 109th Cong. (2005). 

32Had Congress enacted (over a potential Presidential veto) a joint resolution of 

disapproval in accordance with sections 2904(b) and 2908 of the BRAC statute before 

either 45 days of the date of the President’s submission or the adjournment of Congress 

for the session, whichever was sooner, the Secretary of Defense would have been 

prohibited from implementing the recommendations. 

33Notification requirements apply to proposed closures of military installations with at least 

300 authorized civilian personnel, or realignments at installations with 300 or more 

authorized civilian personnel that involve a reduction by more than1,000, or by more than 

50 percent, of the number of civilian personnel authorized to be employed at the 

installation. 

Requirements to Ensure 

Fairness and Objectivity of 

the Base-Closing Process 
 

Page 18 GAO-13-149 Military Bases 

its report that the requirements of section 2687 effectively halted base 

closures until 1988, when the first version of BRAC34 was enacted. 

Since that time, a variety of requirements or procedures, some already 

discussed, have been either mandated by the BRAC statute, as 

amended, or adopted by DOD over time to ensure the fairness and 

objectivity of the base-closing process. Some of these requirements or 

procedures include the following: 

 All installations must be compared equally against selection criteria, 

and a current force structure plan and infrastructure inventory must be 

developed by the Secretary of Defense. 

 Selection criteria for identifying candidates for closure and 

realignment must be made available for public comment before being 

finalized. 

 All DOD components analyzing and developing BRAC proposals must 

use specific models for assessing the cost and savings associated 

with BRAC actions and the potential economic impact on communities 

affected by those actions to ensure consistency. 

 Information submitted for use by the Secretary of Defense or the 

Commission in the BRAC decision-making process must be certified 

to overcome concerns about the consistency and reliability of data 

used in the process. 

 An independent commission is required to review DOD’s proposed 

closures and realignments and to finalize a list of proposed closures 

and realignments to be presented to the President for his review and 

subsequent submission to Congress. Also, the BRAC Commission is 

required to hold public hearings. 

 

34Defense Authorization Amendments and Base Closure and Realignment Act, Pub. L. 

No. 100-526 (1988). 
 

Page 19 GAO-13-149 Military Bases 

 The BRAC process imposes specific time frames for completing 

specific portions of the process. 

 While the President may disapprove the Commission’s 

recommendations in whole or in part, which allows the Commission to 

revise its list of recommendations, the recommendations ultimately 

become binding only if accepted in their entirety by both the President 

and Congress. 

 In addition to GAO’s statutorily mandated role in reporting on the 

BRAC process, the military services’ audit agencies and DOD 

Inspector General personnel are involved in auditing the process to 

better ensure the accuracy of data used in decision making and 

enhance the overall integrity of the process. 

We have played a long-standing role in the BRAC process. As requested 

by congressional committees, as was the case for the 1988 BRAC round, 

or as mandated by law since 1990, we have served as an independent 

and objective observer of the BRAC process and have assessed and 

reported on DOD’s decision-making processes leading up to proposed 

realignment and closure recommendations in each of the five rounds. To 

make informed and timely assessments, we have consistently operated in 

a real-time setting since the 1991 BRAC round and have had access to 

portions of the process as it has evolved, thus affording the department 

an opportunity to address any concerns we raised on a timely basis. We 

observed the 2005 BRAC process since DOD’s initial work began on the 

2005 round. 

Specifically, for the 2005 BRAC round, the BRAC statute required DOD to 

report to Congress on several BRAC-related issues in 2004 in order for 

the 2005 round to proceed. The statute directed, among other things, that 

the Secretary of Defense provide Congress with a 20-year force structure 

plan and a worldwide inventory of military installations in its submission of 

its fiscal year 2005 budget documentation and separately publish the final 

selection criteria for the 2005 BRAC round no later than February 16, 

2004.35 In addition, the statute required the Secretary of Defense to 

 

35Sections 2912 and 2913 of the BRAC statute. Section 2913, establishing DOD’s 

requirement to propose and adopt selection criteria, was subsequently amended when 

Congress codified the criteria, as previously described in this report. 

GAO’s Role in the BRAC 

Process 
 

Page 20 GAO-13-149 Military Bases 

certify, on the basis of the force structure plan and infrastructure 

inventory, that the need existed for closure or realignment of military 

installations, and that the additional round of closures and realignments 

would result in annual net savings for each military department beginning 

no later than fiscal year 2011. The statute also required us, if DOD’s 

certifications were provided, to submit a report to Congress, within 60 

days of the issuance of DOD’s report, evaluating specific aspects of 

DOD’s required submissions. DOD published its final selection criteria on 

February 12, 2004, and reported on the other requirements, including the 

necessary certifications, on March 23, 2004. In May 2004,36 we reported 

that DOD’s report to Congress generally addressed all of the 

requirements in section 2912 of the Defense Base Closure and 

Realignment Act of 1990, as amended, and separately complied with the 

requirements in section 2913 for adopting selection criteria to guide 

BRAC decision making. We noted that DOD’s analysis of excess 

infrastructure capacity, which was completed for the 2004 report outside 

the BRAC process, had some limitations that could make it difficult to 

project a total amount of excess capacity across DOD. 

In addition, as with the three previous BRAC rounds, the statute 

authorizing the 2005 round required us to provide a detailed analysis of 

the Secretary’s recommendations and DOD’s selection process. In July 

2005, we issued a report analyzing DOD’s 2005 selection process and 

recommendations for base closures and realignments.37 In particular, we 

reported that DOD’s recommendations, if approved, would have varying 

degrees of success in achieving goals that were set forth by the Secretary 

of Defense, despite producing closure and realignment actions numbering 

more than those of all four previous rounds combined. However, we also 

found that DOD’s decision-making process for developing its 

recommendations was generally logical, well documented, and reasoned; 

and we identified various issues regarding DOD’s BRAC 

recommendations, as well as candidate recommendations that were not 

included on DOD’s final list, that may have warranted further attention by 

the BRAC Commission. Since publishing that assessment, we have 

continued to monitor implementation of BRAC 2005. We have issued 

more than 30 reports related to the BRAC 2005 round (see the Related 

GAO Products list at the end of this report). 

 

36GAO-04-760. 

37GAO-05-785. 
 

Page 21 GAO-13-149 Military Bases 

BRAC 2005 differed from prior rounds in three significant ways—the 

circumstances under which it took place, its scope, and its scale. Unlike 

prior BRAC rounds, which were implemented during times of declining 

defense budgets and in which the focus was on eliminating excess 

capacity and realizing cost savings, BRAC 2005 was conducted in a 

global security environment characterized by increasing defense budgets 

and increasing military end strengths after the terrorist attacks of 

September 11, 2001, and was conducted concurrently with combat 

operations in Afghanistan and Iraq.38 At the same time, DOD was 

engaged in an initiative to relocate thousands of personnel from overseas 

to the continental United States. Changes in overall DOD fiscal year 

budget authority amounts since BRAC began are depicted in figure 5. 

Figure 5: Defense Budget Authority for Fiscal Years 1987 through 2011 

 

38Operation Enduring Freedom began in October 2001 and Operation Iraqi Freedom 

began in March 2003. 

BRAC 2005 Differed 

Significantly from Prior 

Rounds 
 

Page 22 GAO-13-149 Military Bases 

The scope of BRAC 2005 was also expanded compared to prior BRAC 

rounds. In addition to the traditional emphasis on eliminating unneeded 

infrastructure to achieving savings, DOD’s goals for the 2005 BRAC 

round also included transforming39 the military by correlating base 

infrastructure to the force structure and enhancing joint capabilities by 

improving joint utilization to meet current and future threats. Finally, the 

scale of BRAC 2005 was much larger than the prior four rounds. BRAC 

2005 generated more than twice the number of BRAC actions than all 

prior BRAC rounds combined. Table 1 compares the number of individual 

actions embedded within the BRAC 2005 recommendations with the 

number of similar actions needed to implement the recommendations in 

the prior rounds. The table shows that the number of individual BRAC 

actions was larger in BRAC 2005 (813) than in the four prior BRAC 

rounds combined (387). 

Table 1: BRAC Actions for All BRAC Rounds 

Round 

Major base 

closures 

Major 

realignments 

Minor 

closures and 

realignments Total actions 

1988 16 4 23 43 

1991 26 17 32 75 

1993 28 12 123 163 

1995 27 22 57 106 

Total for four 

prior rounds 

97 55 235 387 

BRAC 2005 24 24 765 813 

Source: GAO analysis of DOD data. 

Note: For BRAC 2005, DOD defined major base closures as those that had a plant replacement value 

exceeding $100 million, and defined major base realignments as those that had a net loss of 400 or 

more military and civilian personnel. In prior BRAC rounds, closures and realignments were often 

difficult to tabulate precisely, and GAO relied on DOD’s characterization of which bases were 

considered to be major in the absence of a consistent definition. 

 

39In the late 1990s, DOD embarked on a major effort to transform its business processes, 

human capital, and military capabilities. Transformation is also seen as a process 

intended to provide continuous improvements to military capabilities. 
 

Page 23 GAO-13-149 Military Bases 

DOD used a quantitative model, known as the Cost of Base Realignment 

Actions (COBRA), which we have stated to be a generally reasonable 

estimator for comparing potential costs and savings among candidate 

alternatives,40 to estimate the costs and savings associated with BRAC 

2005 recommendations; however, DOD’s process for providing the BRAC 

Commission with cost and savings estimates was hindered in many 

cases by inputs into COBRA that significantly underestimated 

recommendation-specific requirements—such as the need for military 

construction projects unique to certain missions or locations, information 

technology requirements for missions with considerable reliance on that 

capability, and other types of requirements, such as contract-termination 

costs. In addition, the standard factor COBRA uses to calculate 

information technology costs may be inaccurate, and DOD is unable to 

demonstrate the reliability of data it entered into COBRA to estimate 

savings from reducing or eliminating military personnel positions. By 

ensuring that all anticipated implementation costs are considered and 

included in COBRA during the comparison of BRAC scenarios, DOD 

would improve the reliability of the cost estimates it provides to any future 

BRAC Commission. 

DOD has developed a quantitative model, known as COBRA, to estimate 

potential costs and savings of various BRAC options and to compare 

them. The COBRA model has been used in the base-closure process 

since 1988, and we have found it to be a generally reasonable estimator 

for comparing potential costs and savings among candidate alternatives. 

DOD designed the COBRA model to provide consistency across the 

military services and joint cross-service groups in estimating BRAC costs 

and savings, and officials stated that the model helps to ensure that all 

installations are treated equally during the process of selecting candidate 

recommendations. When developing and analyzing possible BRAC 

recommendations for DOD to consider, the military services and joint 

cross-service groups used the COBRA model to calculate costs, savings, 

and return on investment for the purpose of comparing similar BRAC 

scenarios.41 COBRA estimates costs for such factors as personnel 

 

40GAO-05-785. 

41A scenario is a proposal that has been declared for formal analysis by a military 

department or joint cross-service group deliberative body and is officially accounted for 

and tracked by OSD. 

DOD Used a 

Reasonable Model to 

Estimate Costs and 

Savings, but Increased 

Attention to 

Requirements Entered 

into the Model Would 

Enhance the 

Reliability of the 

Initial Estimates 

DOD’s Process for 

Estimating the Cost of 

BRAC 2005 

Recommendations 
 

Page 24 GAO-13-149 Military Bases 

severance, moving costs, and military construction over the 

implementation period, and also estimates savings for such factors as 

personnel position eliminations over that same period—any of which may 

influence the BRAC decision-making process. 

As figure 6 shows, OSD ultimately used the COBRA model’s cost and 

savings estimates—along with a scenario’s military value and other 

criteria—to compare and select the final 222 recommendations that it 

submitted to the BRAC Commission. In doing so, OSD presented 

COBRA’s estimated costs and savings from implementing candidate 

recommendations to the BRAC Commission. In turn, the Commission 

also used the COBRA model to cost out modifications and changes in its 

review for the final recommendations. 

Figure 6: Uses of the COBRA Model in the BRAC Process 

The COBRA model relies to a large extent on standard factors and 

averages. Therefore, the model’s estimates do not represent the actual 

amounts that Congress will be asked to fund through appropriations to 

implement BRAC recommendations, although they do produce an idea or 

approximation as to how much a recommendation will cost to implement. 

Although we believe the COBRA model is a reasonable comparison tool, 

DOD officials told us that in order to have the model produce estimates 

that more-closely approximate actual implementation costs, detailed 

requirements, especially those for military construction, would need to be 
 

Page 25 GAO-13-149 Military Bases 

captured up front—before the model is run to compare alternative 

scenarios—but that the need to prevent premature dissemination of 

information about potential BRAC recommendations hindered the ability 

of BRAC analysts to obtain detailed information needed to fully identify 

some requirements. 

DOD’s process for providing the BRAC Commission with cost and 

savings estimates was hindered in some cases by inputs into COBRA 

that underestimated recommendation-specific requirements—such as the 

need for military construction projects unique to certain missions or 

locations, information technology requirements for missions with 

considerable reliance on that capability, and other types of requirements. 

As we reported in June 2012,42 onetime implementation costs for BRAC 

2005 grew from $21 billion originally estimated by the BRAC Commission 

in 2005 to about $35.1 billion, or by 67 percent, primarily because of 

higher-than-anticipated military construction costs.43 Military construction 

costs for the BRAC 2005 round increased from $13.2 billion based on 

original estimates by the BRAC Commission to $24.5 billion, an 86 

percent increase, while over the same period, general inflation increased 

by 13.7 percent. On the basis of key principles we derived from cost-

 

42GAO-12-709R. 

43DOD calculated the $35.1 billion in onetime implementation costs using fiscal year 2011 

dollars, which includes inflation, while the BRAC Commission estimate of $21 billion is in 

constant fiscal year 2005 dollars, which excludes inflation. In constant 2005 dollars, costs 

increased to about $32.2 billion, an increase of 53 percent. 

DOD Understated or Did 

Not Include Some 

Requirements for Many 

BRAC 2005 

Recommendations, 

Resulting in Higher Costs 

Than Originally Estimated 

Military Construction 

Requirements Were 

Understated or Not Included in 

Initial BRAC Cost Estimates 
 

Page 26 GAO-13-149 Military Bases 

estimating and budgeting guidance,44 we have determined that a key 

principle for evaluating cost estimates is ensuring that all significant costs 

are included. However, in many cases, DOD did not include some 

significant military construction requirements that were needed to 

implement the recommendations as envisioned, resulting in the 

identification of additional requirements and related cost increases after 

the recommendations were approved by the BRAC Commission. Hence, 

the increase of $11.3 billion in military construction costs drove about 80 

percent of the total cost increases of $14.1 billion for BRAC 2005. For 

example: 

 Technology center and warehouse for the National GeospatialIntelligence Agency—The identification and addition of this 

requirement resulted in a 200,000 square footage increase in the size 

of a new facility as part of the recommendation that closed National 

Geospatial-Intelligence Agency leased locations and realigned others 

to Fort Belvoir, Virginia. DOD officials told us that the initial cost 

estimates were based on an erroneous entry into the COBRA model 

that assumed the facility would be used as a general administrative 

building instead of the more-secure facility that was required. This 

erroneous assumption contributed to military construction costs 

increasing by about $726 million from the initial estimate of $950 

million. 

 Vehicle maintenance shops for many Armed Forces Reserve 

Centers—Of the 44 BRAC recommendations aimed at transforming 

Reserve Component facilities throughout the country and improving 

 

44We reviewed numerous federal guidance documents related to cost estimating, 

accounting standards, economic analysis, and budgeting and identified key principles that 

we believe can be applied to the evaluation of cost-savings estimates. Two of those four 

principles include having an appropriate level of detailed documentation such that a 

reasonably informed person could easily recreate, update, or understand the cost 

estimate, and all significant costs and key assumptions should be included in the cost 

estimate. The guidance documents we reviewed include: GAO, GAO Cost Estimating and 

Assessment Guide: Best Practices for Developing and Managing Capital Program Costs,

GAO-09-3SP (March 2009); Office of Management and Budget Circular No. A-11, 

Preparation, Submission and Execution of the Budget (August 2011, superseded by an 

August 2012 issuance); Federal Accounting Standards Advisory Board, Statement of 

Federal Financial Accounting Standards 4 (June 2011); Department of Defense Instruction 

7041.3, Economic Analysis for Decisionmaking (Nov. 7, 1995); and Department of 

Defense Financial Management Regulation 7000.14-R, vol. 4, ch. 22, Cost Finding (May 

2010). We believe that these documents collectively contain broad themes that can be 

applied to evaluating cost analyses. 
 

Page 27 GAO-13-149 Military Bases 

homeland defense, training, and deployment capabilities, which 

directed the construction of 125 new Armed Forces Reserve Centers, 

a total of 35 vehicle maintenance shops were left out of initial 

estimates. After learning of the omissions, the Army added military 

construction requirements that resulted in about $54 million in 

additional costs to implement those recommendations. According to 

an OSD Basing Directorate official, the overall cost to implement the 

44 recommendations was around $3 billion. 

 Additional requirements identified for the recommendation to establish 

San Antonio Regional Medical Center and Realign Enlisted Medical 

Training to Fort Sam Houston, Texas—This recommendation 

established the San Antonio Regional Military Medical Center by 

relocating inpatient medical care from Lackland Air Force Base, 

Texas, and realigned DOD basic and specialty enlisted medical 

training from four other DOD installations to Fort Sam Houston. Onetime implementation costs increased $953 million (92 percent) for 

several reasons, such as the identification of additional requirements 

to move medical inpatient care functions from Wilford Hall Medical 

Center at Lackland Air Force Base to Fort Sam Houston. Additionally, 

according to DOD officials, requirements for instructional and 

laboratory space expanded to accommodate an over 40 percent 

increase in the number of students DOD expected to receive medical 

training at Fort Sam Houston compared to initial assumptions, 

resulting in more military construction than initially anticipated. 

Further, DOD’s initial dormitory construction assumptions did not 

account for accommodation for the female student population that 

would be at Fort Sam Houston, according to Army officials. Finally, 

the cost of various operation and maintenance activities, such as 

moving people and equipping the medical center, were higher than 

initially estimated. 

 Historic-building renovations—Initial assumptions for the renovation of 

existing buildings at Wright-Patterson Air Force Base, Ohio, and 

Randolph Air Force Base, Texas, did not account for the higher cost 

of historic renovations compared to renovating newer buildings, which 

contributed to over $20 million in additional military construction costs 

to a recommendation that, among other things, consolidated 

geographically separate units of the Air Force Research Laboratory. 

 Service-specific requirements—According to Air Force officials, 

requirements for constructing the Navy and the Air Force portions of a 

new facility were not included in initial estimates for the 

recommendation that closed Brooks City-Base, Texas, and relocated 
 

Page 28 GAO-13-149 Military Bases 

several Air Force, Army, and Navy medical missions to other 

locations, adding $74 million to initial construction cost estimates. This 

recommendation, among other things, consolidated geographically 

separate units of the Air Force Research Laboratory. 

 Medical and other facilities—The Army identified additional military 

construction, including medical facilities and other projects, to support 

Maneuver Center training at Fort Benning, Georgia. These military 

construction requirements drove 92 percent, or $880 million, of the 

$915 million cost increase after the recommendation had been 

approved. This recommendation consolidated the Armor and Infantry 

Centers and Schools at Fort Benning, created the Maneuver Center 

for ground-forces training and doctrine development and allowed the 

Army to reduce the number of basic combat training locations from 

five to four. 

Moreover, DOD’s own data confirmed that the majority of the $14 billion 

in the BRAC 2005 cost increase was related to military construction. For 

example, data obtained from DOD showed the following expense 

categories that experienced cost growth:

 construction of additional facilities to enhance capabilities, address 

deficiencies—BRAC as a recapitalization engine—and construction 

industry inflation since 2005 ($11 billion), 

 inflation for expenses other than construction ($1.8 billion), 

 program-management costs not in COBRA ($0.6 billion), 

 environmental-restoration costs not in COBRA ($0.4 billion), and 

 additional operation and maintenance support cost ($0.2 billion). 

Another reason for the growth in implementation costs over DOD’s initial 

BRAC estimates was that DOD had difficulties accurately anticipating 

information technology requirements for many recommendations, leading 

to significantly understated information technology costs for some BRAC 

recommendations—particularly those that involved missions with 

considerable reliance on such capabilities. For example, information 

technology requirements for two supply-related recommendations that 

required the Defense Logistics Agency to assume roles previously 

performed by the military services were initially understated, in part 

because of the complexity of developing the required information 

Requirements for BRAC 

Recommendations with 

Significant Information 

Technology Requirements 

Were Understated 
 

Page 29 GAO-13-149 Military Bases 

technology. First, the recommendation that realigned DOD’s supply, 

storage, and distribution management involved complex businessprocess reengineering efforts, including software development and the 

synchronization of several existing and evolving information technology 

systems, in addition to equipment purchases. The initial information 

technology estimate for this BRAC recommendation was $30.9 million; 

however, implementation costs increased to over $190 million once 

information technology requirements were fully defined. As we reported in 

2008,45 DOD officials told us that when this recommendation was 

developed they did not have a good sense of what information system 

would have to be specially designed and what the development of those 

systems would cost. Second, the cost to implement another supplyrelated recommendation, which consolidated depot-level reparable 

procurement management within the Defense Logistics Agency and 

realigned procurement and related support functions at 13 locations, 

increased by $307 million, in part due to COBRA inputs for information 

technology requirements that did not reflect actual business processes 

and other information technology needs. 

Other relocated or realigned DOD missions or organizations that were 

especially reliant on information technology were particularly vulnerable to 

cost increases. For instance, DOD’s original information technology cost 

estimate for the new Defense Information Systems Agency building at 

Fort Meade, Maryland, was $17 million. However, that estimate assumed 

the information technology costs commensurate with a facility that served 

only an administrative function, as opposed to the agency’s information 

security mission. After the BRAC Commission had approved the 

recommendation, the Defense Information Systems Agency conducted an 

analysis that included what it identified to be the minimum necessary 

requirements to enable it to continue performing its mission after the 

move. After the requirements to implement this recommendation were 

fully reflected in the business plan, estimated costs increased to 

$95 million. 

For some other types of BRAC recommendations we reviewed, 

information technology cost increases were driven by the increased size 

of related military construction projects. For example, for the 

 

45GAO, Military Base Realignments and Closures: Higher Costs and Lower Savings 

Projected for Implementing Two Key Supply-Related BRAC Recommendations, 

GAO-08-315 (Washington, D.C.: March 5, 2008). 
 

Page 30 GAO-13-149 Military Bases 

recommendation to close Brooks City-Base, an additional 56,000 square 

feet was added to construction plans to accommodate personnel not 

initially accounted for, which required adding extra square footage that 

also had to be equipped with computers and other information technology 

equipment for these personnel relocating to Lackland Air Force Base, 

Texas. Similarly, for the recommendation that closed Fort McPherson, 

Georgia, and relocated the Army’s Forces Command headquarters and 

the Army Reserve Command headquarters to Fort Bragg, North 

Carolina,46 information technology costs that corresponded to added 

military construction projects as well as more-refined costs for installation 

of communications, automation, and information-systems equipment 

increased costs from nearly $20 million to $139 million. For another 

recommendation in which DOD relocated several Army commands and 

regional offices to various locations such as Fort Sam Houston, Texas; 

Fort Knox, Kentucky; and Redstone Arsenal, Alabama, information 

technology costs increased from an initial estimate of nearly $2 million to 

about $58 million because of information technology requirements 

associated with additional military construction projects that had not been 

previously identified, as well as information technology requirements for 

various Army headquarters organizations. 

While the majority of the cost increases for BRAC 2005 were associated 

with military construction and information technology requirements, initial 

cost estimates did not include other types of requirements that were 

similarly left out or understated during the recommendation development 

phase. For example, DOD officials told us that—since they considered 

COBRA to be primarily a tool for comparing different scenarios, rather 

than a cost-estimating tool—in some cases, known requirements, such as 

furnishings for new buildings, were not entered as inputs into COBRA 

because analysts assumed that those requirements would be the same 

regardless of which scenario was chosen, and therefore the costs related 

to those requirements would not affect the comparison. However, after 

completing the comparison process and selecting its candidate 

recommendations, DOD submitted these COBRA estimates to the BRAC 

Commission as its estimated costs to implement the 2005 round. To 

ensure that all installations and surrounding communities involved in a 

given scenario are treated equally, OSD BRAC officials told us that they 

 

46The BRAC Commission, in another recommendation, directed the Air Force to transfer 

real-property accountability for Pope Air Force Base, North Carolina, to the Army, making 

it part of Fort Bragg, North Carolina. 

Other Types of Requirements 

Were Understated or Not 

Included 
 

Page 31 GAO-13-149 Military Bases 

could not add requirements or related costs to COBRA after candidate 

recommendations were selected, generally the last 2 months before their 

release to the Commission. Still, unless OSD ensures that, during the 

development and comparison of BRAC scenarios, all anticipated BRAC 

implementation costs are considered and included in the COBRA model, 

the cost estimates that DOD provides to any future BRAC Commission 

may not be reliable. 

In addition, 4 of the 14 BRAC recommendations for which implementation 

costs increased the most compared to initial estimates had cost increases 

associated with moving personnel or equipment. For instance, costs 

increased for transporting equipment such as oversized tactical vehicles 

and weapon systems from Aberdeen Proving Ground, Maryland, to Fort 

Lee, Virginia. In another of those four cases—the recommendation in 

which DOD relocated several Army commands and regional offices to 

various locations such as Fort Sam Houston, Texas; Fort Knox, Kentucky; 

and Redstone Arsenal, Alabama—DOD experienced added costs of over 

$41 million for personnel-related costs and the transportation of 

equipment. 

Two of the 14 recommendations with the largest cost increases 

experienced those increases partly because existing contracts had to be 

terminated or modified. For example, the recommendation that 

reconfigured DOD’s wholesale supply, storage, and distribution network 

across the United States while also consolidating these functions at 

several military maintenance depots experienced cost increases in part 

because of the need to modify existing contracts to implement the 

recommendation. In addition, a recommendation that relocated several 

Army commands and regional offices incurred costs for contract 

termination that were not anticipated in the initial cost estimates. 

Improvements to the COBRA model and the reliability of data DOD enters 

into it could enhance DOD’s cost-estimating methodology, should 

Congress authorize a future BRAC round. Specifically, the standard factor 

COBRA uses to calculate cost estimates for information technology may 

be inaccurate. Also, better documentation would enable DOD to 

demonstrate the reliability of data used to generate military personnel 

savings estimates, which accounted for almost half of DOD’s estimated 

BRAC savings in 2005. 

Improvements to DOD’s 

Model for Estimating the 

Cost of Base Realignment 

and Closure Actions and 

Inputs to the Model Could 

Enhance DOD’s CostEstimating Methodology 
 

Page 32 GAO-13-149 Military Bases 

The standard factor COBRA uses to calculate cost estimates for 

information technology may be inaccurate. As part of DOD’s analytical 

process for developing recommendations for the 2005 round, DOD 

established a Joint Process Action Team to, among other things, revise 

and enhance the COBRA model. As of the time the COBRA Joint 

Process Action Team performed its work in 2003, COBRA had not been 

used since 1995. Technology improvements, among other factors, 

enabled or necessitated updates to the model. According to the Joint 

Process Action Team’s report, the revised COBRA contained 61 standard 

factors—such as average personnel salaries and costs for moving 

personnel and equipment—which OSD officials stated were applied to all 

installations equally. The revised COBRA model also used 183 different 

algorithms, or formulas, to estimate the costs and savings associated with 

actions that are necessary to implement BRAC recommendations over a 

legislatively required 6-year implementation period. 

Nevertheless, multiple DOD officials told us that the costs to implement 

some recommendations were significantly underestimated because the 

standard factor for information technology was understated in the COBRA 

model. Officials in OSD’s Basing Directorate told us that they plan to 

review the model’s standard factors prior to any future BRAC round. 

Should Congress authorize another BRAC round, even if in the near 

future, it will again have been about a decade since the COBRA model 

was last updated for BRAC 2005, and advances in technology since then, 

such as data-storage technology, will likely make the standard factors 

COBRA uses to estimate information technology costs outdated. 

Although almost half of DOD’s estimated net annual savings from the 

2005 BRAC round were attributed to eliminating military personnel 

positions, it is unclear how DOD arrived at some of those savings 

estimates because the military services and joint cross-service groups did 

not consistently document the assumptions they used to arrive at the 

number of military personnel position eliminations that they entered into 

the COBRA model. Along with ensuring that all significant costs are 

included in a cost estimate, another key principle of cost estimation we 

identified is that estimates should have an appropriate level of detailed 

documentation such that a reasonably informed person could easily 

recreate, update, or understand the estimate.47 However, it is not clear 

 

47See footnote 44. 

COBRA’s Standard Factor 

Underestimated Information 

Technology Costs 

DOD Did Not Consistently 

Document Its Basis for Military 

Personnel Savings Estimates in 

COBRA 
 

Page 33 GAO-13-149 Military Bases 

how the services and joint cross-service groups determined the number 

of military personnel position eliminations that they entered into COBRA 

for the purpose of calculating savings that could be derived by realigning 

a mission from one location to another. For example, according to DOD’s 

fiscal year 2011 budget submission to Congress, DOD eliminated 

1,416 military personnel positions through its implementation of the BRAC 

recommendation that combined training and doctrine development for 

ground forces by relocating the Armor Center and School from Fort Knox, 

Kentucky, to Fort Benning, Georgia, and established the Maneuver 

Center of Excellence. The COBRA documentation supporting this 

recommendation does not provide information on the methodology used, 

the assumptions made, or the sources used to calculate the 1,416 military 

personnel positions that would be eliminated as a result of this 

realignment—and others—because DOD’s guidance on the use of the 

COBRA model does not require users to enter a narrative into COBRA 

documenting any basis for the numbers provided. 

Similarly, documentation supporting the 507 positions eliminated by the 

BRAC recommendation that established the Net Fires Center at Fort Sill, 

Oklahoma, provided neither the rationale nor the methodology used to 

determine how the numbers were calculated. Conversely, the BRAC 

analysts for some recommendations did provide clear documentation to 

support their savings estimates. For example, documentation 

accompanying the BRAC recommendation that closed Fort Gillem, 

Georgia, and eliminated 71 military personnel positions provided an 

explanation on the information and methodology used to develop the 

savings estimate. In addition, source data and methodology were 

documented for the 288 military personnel positions eliminated for the 

BRAC recommendation that closed Fort McPherson, Georgia. 

Nevertheless, the lack of consistent documentation to accompany inputs 

to the COBRA model decreases confidence in the fidelity of the cost and 

savings estimates that the model produces. In planning for any future 

BRAC round, developing guidance that ensures more-consistent 

documentation of the process, sources, and methods used to develop 

personnel savings data could provide DOD decision makers with greater 

assurance that scenarios proposed by the military services and joint 

cross-service groups are based on sound assumptions. 
 

Page 34 GAO-13-149 Military Bases 

DOD’s planning process for the complex BRAC 2005 round was guided 

by high-level leadership and a new governance structure, but 

opportunities exist to better demonstrate results and to enhance the 

planning of future BRAC rounds. OSD, the military services, and other 

DOD components provided leadership and oversight at the highest levels, 

and OSD established a governance structure that was led by higher-level 

leaders than previous rounds and included a larger, more visible role for 

specialized working groups that developed recommendations related to 

complex, department-wide issues. However, DOD is unable to fully 

demonstrate that it achieved the desired outcomes from this BRAC round 

because it did not develop a plan to track the extent to which the round 

met some of the statistical measures that DOD presented to the BRAC 

Commission to illustrate the breadth and depth of its proposed actions. In 

addition DOD did not establish a target for reducing excess infrastructure 

through this BRAC round as it did for the 1995 round. In other ways, 

DOD’s planning for BRAC 2005 limited visibility into expected costs and 

complicated the Commission’s review. Specifically, DOD bundled multiple 

closures and realignments into single recommendations and submitted 

them to the BRAC Commission as more-complex recommendations, 

which limited visibility into the estimated costs and savings and 

complicated the Commission’s review, and DOD did not establish a 

process to ensure a timely review of BRAC supporting data needed to 

prevent the disclosure of classified information, thus delaying the 

Commission’s work. 

In a 2002 memo to the department’s high-level leadership, the Secretary 

of Defense made it clear that BRAC 2005 would be the means by which 

the department transformed the military by correlating base infrastructure 

to the force structure, an effort that required the focus and prioritization 

that only senior DOD leadership could bring. Toward that end, DOD 

established a new, extensive governance structure that facilitated a 

department-wide planning effort by involving many more high-level 

leaders throughout DOD and ensured upper-level management oversight 

of the process and the resulting recommendations that the Secretary 

proposed to the BRAC Commission. 

Our prior work on organizational transformation has identified high-level 

leadership attention as a key practice that can help agencies to manage 

High-Level Leadership 

and a New 

Governance Structure 

Guided BRAC 2005 

Planning and 

Management, but 

Opportunities Exist to 

Enhance Planning of 

Future BRAC Rounds 

DOD Provided High-Level 

Leadership and 

Established a New 

Governance Structure to 

Plan and Manage This 

Complex BRAC Round 
 

Page 35 GAO-13-149 Military Bases 

large-scale change.48 In the case of BRAC 2005, the governing structure 

involved high-level leaders from across the department and coordination 

among many stakeholders. At the highest level, an executive-level 

Infrastructure Executive Council, led by the Deputy Secretary of Defense, 

was designated the policy-making and oversight body for the entire BRAC 

2005 process. This council met more than 20 times during the BRAC 

process to establish policy and oversee the entire BRAC recommendation 

development process, according to DOD’s 2005 report to the BRAC 

Commission. Next, the Under Secretary of Defense (Acquisition, 

Technology and Logistics) led a senior-level subordinate group, the 

Infrastructure Steering Group, which met more than 60 times and 

oversaw cross-service analyses of common business–oriented functions 

and integrated that process with the military departments’ and defense 

agencies’ own analyses, setting milestones, and resolving issues as the 

analyses unfolded. 

DOD’s governance structure for BRAC 2005 also allowed seven 

individual joint cross-service groups to play a larger, more visible role 

compared to BRAC 1995. The Secretary of Defense established the 

seven joint cross-service groups, each led by senior military or civilian 

officials and each tasked with evaluating scenarios and ultimately 

developing realignment and closure recommendations related to a 

common business–oriented support function that crossed military 

services and defense agencies—Education and Training, Headquarters 

and Support Activities, Industrial, Intelligence, Medical, Supply and 

Storage, or Technical, as shown in figure 7. 

 

48GAO-03-669. 
 

Page 36 GAO-13-149 Military Bases 

Figure 7: DOD’s BRAC Leadership Structure 

DOD emphasized that the joint cross-service groups were to analyze 

common business-oriented functions for BRAC 2005, an approach made 

more important by the desire to develop transformational BRAC 

recommendations. As with the 1995 BRAC round, these joint crossservice groups performed analyses and developed closure and 

realignment options in addition to those developed by the military 
 

Page 37 GAO-13-149 Military Bases 

services. However, our evaluation of DOD’s 1995 round49 indicated that 

the joint cross-service groups submitted options through the military 

services for approval, resulting in few being approved. Conversely, the 

number of BRAC recommendations developed by these joint crossservice groups and subsequently approved by the BRAC Commission 

increased significantly in the BRAC 2005 round. This was due, in part, to 

high-level leadership ensuring that the options were reviewed by DOD’s 

senior-level Infrastructure Steering Group, rather than the military 

services. 

In addition, DOD established four Joint Process Action Teams to facilitate 

a common analytical approach to the application of the four BRAC 

selection criteria not related to military value—costs and savings 

potential, economic impact, community impact, and environmental 

impact.50 Senior leaders from each of the military departments oversaw 

their respective services’ BRAC analytical teams. At the end of the joint 

cross-service groups’ and individual military departments’ analytical 

processes, the two senior-executive-level groups approved each 

candidate recommendation. Finally, before DOD forwarded its candidate 

recommendations to the BRAC Commission, the department engaged a 

small group of former executive-level government officials, called the 

“Red Team,” to provide an independent assessment of candidate 

recommendations and offer feedback and suggestions for improving the 

quality of the candidate-recommendation packages. Moreover, early in 

the BRAC process, OSD issued close to a dozen memorandums 

establishing policy, responsibilities, and procedures for developing 

realignment and closure recommendations for submission to the BRAC 

Commission. These policy memos established a consistent analytical 

approach to help ensure that the department treated all bases equally as 

required in the BRAC statute.51

DOD recognized that the size and complexity of the BRAC 2005 

round—specifically, the large number of transformational 

recommendations—presented significant implementation challenges 

 

49GAO, Military Bases: Lessons Learned From Prior Base Closure Rounds, 

GAO/NSIAD-97-151 (Washington, D.C.: July 25, 1997). 

50Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005, Pub. L. No. 

108-375, § 2832 (2004) (amending § 2913 of the BRAC statute). 

51Section 2903(c)(3)(A) of the BRAC statute. 
 

Page 38 GAO-13-149 Military Bases 

that would require high-level leadership to be more involved in 

strategically managing the implementation of this round compared to past 

rounds. According to OSD BRAC officials, during prior BRAC rounds, 

OSD’s oversight of BRAC implementation was typically limited to 

adjudicating disagreements among the services over implementation 

issues. To better inform OSD of the financial details and implementation 

status of each of the 182 BRAC 2005 recommendations, for the first time 

OSD required the military departments to develop detailed business plans 

to delineate required actions, their timing, and the resources needed to 

complete those actions. Business plans were to be updated every 6 

months. Among other things, the business plans facilitated oversight by 

requiring the services and defense agencies to document their 

concurrence with BRAC implementation plans and by calling any 

disagreements among stakeholders to the attention of the OSD Basing 

Office and ultimately, if necessary, to the senior-level Infrastructure 

Steering Group. Service officials told us that the business plans were a 

good managerial decision that facilitated needed OSD oversight given the 

complexity of this BRAC round. Through the business plans, OSD 

officials were able to provide comprehensive, centrally managed 

oversight of the BRAC program, monitoring the services actions, any 

disagreements among stakeholders, and the timing and cost of 

implementation. 

Additionally, beginning in December 2008, as concerns grew that some 

recommendations were at risk of not being completed by the statutorily 

mandated deadline of September 2011, OSD directed the military 

services to provide status briefings on various recommendations facing 

implementation challenges to ensure that senior leadership stayed 

apprised of significant issues affecting BRAC implementation. For 

example, our analysis at that time showed DOD expected almost 400 of 

the total of about 800 locations to complete their BRAC recommendations 

in 2011, which was within the last 9 months of the statutory 

implementation period, and about 230 of those almost 400 locations were 

scheduled to complete their recommendations in the last 2 weeks before 

the deadline. Further, our analysis showed that some of these 230 

locations involved some of the most-costly and most-complex BRAC 

recommendations, which already incurred setbacks and thus had little 
 

Page 39 GAO-13-149 Military Bases 

leeway to meet the completion deadline if further delays occurred.52

Furthermore, we testified in March 2012 that DOD demonstrated 

sustained leadership attention and a high level of coordination among 

many stakeholders to complete transformational-type recommendations 

by the required date.53 For example, the Defense Logistics Agency was 

faced with the potential for disruptions to depot operations during 

implementation of the BRAC recommendation to consolidate supply, 

storage, and distribution functions within the agency. The agency took 

certain steps we have identified as best practices to minimize the 

potential for disruption, such as committing sustained high-level 

leadership and including relevant stakeholders in an organizational 

structure to address implementation challenges as they arose. The 

agency had to develop strategic agreements with the military services 

that ensured that all stakeholders agreed on its plans for implementation, 

and had to address certain human capital and information technology 

challenges. 

Although implementing a large-scale organizational transformation such 

as BRAC 2005 is not a simple endeavor, during our analysis of BRAC 

2005 we found that while DOD is able to demonstrate some results that 

this round produced, it did not track two of the four statistics it listed as 

illustrating the breadth and depth of the round. In addition, DOD did not 

establish a target for reducing excess infrastructure, as it did for the 1995 

round. 

It is possible to quantify some results of BRAC 2005. For instance, DOD 

closed 24 major bases, realigned 24 major bases, and took action to 

implement over 765 other BRAC actions across the country.54 In addition, 

DOD reported in its fiscal year 2011 budget request that about 18,000 

military personnel positions and about 12,000 civilian positions were 

eliminated as a result of the 2005 BRAC round. DOD also tracked the 

estimated cost and savings of each recommendation, and adjusted these 

 

52GAO, Military Base Realignments and Closures: DOD Faces Challenges in 

Implementing Recommendations on Time and Is Not Consistently Updating Savings 

Estimates, GAO-09-217 (Washington, D.C.: Jan. 30, 2009). 

53GAO-12-513T. 

54DOD defined major closures as those where plant replacement value exceeds 

$100 million. 

Opportunities Exist to 

Better Demonstrate 

Results of Future BRAC 

Rounds 

OSD Can Demonstrate Some 

Results, but It Did Not Develop 

a Plan to Track Some Statistics 

Presented in Its 2005 BRAC 

Report 
 

Page 40 GAO-13-149 Military Bases 

estimates annually as necessary. As we reported in June 2012,55 DOD 

estimated net annual recurring savings of $3.8 billion as of the end of 

fiscal year 2011, compared to its original projection of over $5 billion per 

year based on the set of candidate recommendations it presented to the 

BRAC Commission.56

In its 2005 Base Closure and Realignment Report, DOD stated that while 

it is difficult to measure the full extent of the improvements in 

effectiveness and efficiency of the BRAC 2005 recommendations, the 

following statistics would illustrate the breadth and depth of the effect of 

its proposed actions: 

 About 18,000 civilian support positions will be eliminated. 

 At the 6-year point in implementation, the department will begin to 

realize net annual savings of over $5 billion per year from BRAC 2005 

actions, in addition to about $7 billion from previous BRAC rounds. 

 5 percent of plant replacement value57 will be reduced. 

 About 12 million square feet of leased space will be vacated for moresecure, functionally enhanced facilities. 

After the Commission had reviewed DOD’s recommendations and made 

some changes—such as allowing the Air Force to find a new mission for 

Cannon Air Force Base, New Mexico—DOD reestimated the percentage 

reduction in plant replacement value on the basis of the set of 

recommendations the Commission approved and presented to the 

President in September 2005. Subsequently, DOD projected in 2005 

that the expected plant replacement value reduction would likely be 

around 3 percent. 

 

55GAO-12-709R. 

56After the Commission completed its review in September 2005, it modified, rejected, and 

added to the recommendations and estimated at that time projected savings to be around 

$4.2 billion. 

57According to DOD, plant-replacement value is the cost to replace an existing facility with 

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

Page 41 GAO-13-149 Military Bases 

While DOD identified four statistics that it stated would illustrate the effect 

of its proposed BRAC actions, it did not establish these statistics as 

potential measures of effectiveness or devise other methods that would 

enable the department to determine the success of the BRAC round. 

Our extensive body of prior work on monitoring performance and results 

highlights the importance of using performance measures to track an 

agency’s progress and performance, and stresses that performance 

measures should include a baseline and target; should be objective, 

measurable, and quantifiable; and should include a time frame.58 Our 

Standards for Internal Control in the Federal Government59 emphasizes 

that an agency’s management should track major agency achievements 

and compare these to the agencies’ plans, goals, and objectives. Also, 

we have noted that agency managers need to compare actual 

performance to planned or expected results and analyze the differences. 

Although DOD developed tracking mechanisms for measuring the extent 

to which it had eliminated civilian support positions and realized net 

annual recurring savings, it did not track the extent to which it had actually 

reduced plant replacement value or vacated leased space upon 

completion of the BRAC 6-year implementation period in 2011. DOD 

tracked the elimination of civilian support positions and expected net 

savings through annual budget submissions to Congress and through its 

required business plan updates. For example, the fiscal year 2011 BRAC 

budget request, which was DOD’s last BRAC budget request during the 

statutory 6-year implementation period, showed that 12,196 civilian 

positions were eliminated by implementing the 182 BRAC 

recommendations. Also, DOD tracked net annual recurring savings 

resulting from BRAC implementation, which were estimated to be 

 

58GAO, Military Transformation: Clear Leadership, Accountability, and Management Tools 

Are Needed to Enhance DOD’s Efforts to Transform Military Capabilities, GAO-05-70 

(Washington, D.C.: Dec. 17, 2004); See also GAO, Streamlining Government: 

Opportunities Exist to Strengthen OMB’s Approach to Improving Efficiency, GAO-10-394 

(Washington, D.C.: May 7, 2010); Managing for Results: Enhancing Agency Use of 

Performance Information for Management Decision Making, GAO-05-927 (Washington, 

D.C.: Sept. 9, 2005); Defense Management: Tools for Measuring and Managing Defense 

Agency Performance Could Be Strengthened, GAO-04-919 (Washington, D.C.: Sept. 13, 

2004); High-Performing Organizations: Metrics, Means, and Mechanisms for Achieving 

High Performance in the 21st Century Public Management Environment, GAO-04-343SP 

(Washington, D.C.: Feb. 13, 2004); and GAO-03-669. 

59GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999). 
 

Page 42 GAO-13-149 Military Bases 

$3.8 billion, according to DOD’s fiscal year 2011 BRAC 2005 budget 

request. 

DOD officials were unable to provide us with information on whether the 

department actually reduced plant replacement value by 3 percent, or the 

extent to which it vacated 12 million square feet of leased space upon 

completion of BRAC implementation, because DOD had not developed a 

plan or mechanism to monitor those changes throughout the 6-year 

BRAC implementation period. According to DOD basing officials, plant 

replacement value is a good statistic to use, and the department will 

continue to use it, although applying it to data collected prior to the 

implementation of BRAC recommendations does not account for changes 

in the data that occurred over the 2006 to 2011 BRAC implementation 

period, most notably the significant amount of military construction. As we 

reported in June 2012,60 DOD’s estimated BRAC-related military 

construction costs were about $24.5 billion, which represented an 

increase of 86 percent from the BRAC Commission’s original estimate of 

about $13.2 billion. Those construction projects, many of which were 

either identified or expanded after implementation of the round’s 

recommendations had begun, would have affected any net reduction in 

plant replacement value if measured in 2011 after BRAC implementation 

was complete. In accordance with DOD’s Financial Management 

Regulation, plant replacement value is calculated by applying current 

construction pricing data to the total inventory of the current physical 

plant. 61 In the future, establishing a plan or method to track changes in 

net plant replacement value—or some other measure of infrastructure 

reduction—would enable DOD officials to provide Congress with morecomplete information on the extent to which the department actually 

reduced excess infrastructure as a result of completed BRAC 

recommendations. 

Further, although DOD reported to the BRAC Commission that it would 

vacate about 12 million square feet of leased space, DOD did not track 

the extent to which it vacated leased space. Vacating leased space is 

important to minimize the extent to which DOD is incurring expenses to 

rent space off-base where available and useable space can be obtained 

 

60GAO-12-709R. 

61DOD Financial Management Regulation 7000.14-R, Volume 3, Chapter 17, Appendix C, 

Attachment 2, Plant Replacement Value (Dec. 1996). 
 

Page 43 GAO-13-149 Military Bases 

on DOD-owned installations. Also, due to enhanced antiterrorism forceprotection measures generally provided at DOD installations compared to 

private-sector facilities, DOD wanted to use BRAC to vacate leased 

space that did not offer this level of protection. However, DOD officials 

stated that they found it difficult to measure vacated leased space 

because, in some cases, DOD simply backfilled vacated leased space 

with other DOD activities—which also calls into question the extent to 

which changes in the utilization of leased space has improved force 

protection. Army officials also told us that they did not track leases that 

the Army vacated as a result of BRAC because those leases were 

typically long-term and thus could not be terminated at the time BRAC 

was being implemented. Rather, the Army simply filled such space with 

other non-BRAC service functions. At the same time, due to other 

ongoing DOD initiatives, some leased space may be vacated for reasons 

other than BRAC. Therefore, according to OSD, it is difficult to measure 

any net reduction in leased space or to identify what proportion of any 

reduction was directly due to BRAC actions. Moreover, an after-action 

report prepared by one of the BRAC joint cross-service groups 

responsible for many recommendations that realigned DOD activities out 

of leased space reported that the department does not have effective 

management controls in place to monitor leased space. The report states 

that leased space outside of the National Capitol Region is not effectively 

controlled or managed, and as a result it is not accurately inventoried in 

BRAC. 

For any future BRAC round, identifying measures of effectiveness that it 

is able to track, and tracking results according to those measures, could 

better enable DOD to demonstrate whether the implementation of a 

BRAC round will achieve improved efficiency and effectiveness, or 

otherwise have the effect that the department says its proposed 

recommendations will accomplish when submitting them to the BRAC 

Commission. 

DOD’s ability to demonstrate results from BRAC 2005 is further hindered 

because it did not establish a target for the amount of excess 

infrastructure to be reduced by this round, although an important goal of 

this and other BRAC rounds was to reduce excess capacity. For example, 

in guidance initiating the 1995 BRAC round, the Deputy Secretary of 

Defense established a minimum of 15 percent of DOD-wide plant 

replacement value as a target for reducing domestic base structure. In a 

March 2004 report to Congress, the Secretary of Defense stated that 

DOD needed the BRAC 2005 round given that, at that time, the 

DOD Did Not Establish a 

Target for the Amount of 

Excess Infrastructure It Would 

Reduce as a Result of BRAC 

2005 
 

Page 44 GAO-13-149 Military Bases 

department had about 24 percent excess capacity. Yet the Secretary did 

not set a reduction target for the round. 

Our prior work on results-oriented management tools states that goals 

should establish intended performance and focus on the results 

required.62 Further, GAO’s Standards for Internal Control states that 

agency managers should be able to compare actual performance to 

planned or expected results and analyze the differences. However, in the 

absence of a specific measurable target for reducing excess capacity 

through the 2005 BRAC process, the department is not now in a position 

to compare actual BRAC infrastructure reductions to its planned or 

expected reduction. In March 2012, DOD requested two more rounds of 

BRAC for fiscal years 2013 and 2015, and the Deputy Under Secretary of 

Defense (Installations and Environment) stated63 that DOD will need to 

close and realign installations to eliminate excess capacity resulting from 

reductions in force structure in Europe and the United States. 

Establishing a clear infrastructure-reduction target for any future BRAC 

round and developing a plan to compare that target to actual performance 

by the end of that round’s implementation period would improve the 

department’s ability to demonstrate that it reduced excess infrastructure. 

 

62GAO-05-70. 

63Hearing on the Request for Authorization of Another BRAC Round and Additional 

Reductions in Overseas Bases (written statement of Dr. Dorothy Robyn). 
 

Page 45 GAO-13-149 Military Bases 

For the BRAC 2005 round, DOD bundled some closures and 

realignments together and submitted them in its report to the BRAC 

Commission64 as more-complex, single recommendations, limiting 

visibility into the estimated costs and savings for individual closures or 

realignments and complicating the Commission’s ability to review them. In 

some cases, DOD bundled proposed closures and realignments that it 

expected to result in 20-year net present value costs with other proposals 

that it expected to result in 20-year net present value savings,65 reducing 

visibility into the estimated costs and savings of individual components in 

its report to the BRAC Commission. For example, the recommendation to 

transform the Army’s reserve components in Arizona, which DOD 

estimated would generate a 20-year net present value savings of almost 

$52 million, included the creation of an Armed Forces Reserve Center at 

the Buckeye Training Site, Arizona. A previous scenario, which focused 

solely on the Buckeye training site, indicated that the Army would incur a 

net cost of almost $9 million over the 20-year period. However, bundling 

reduced the visibility of these net costs and instead produced a candidate 

recommendation with 20-year net savings overall. 

Another proposal to relocate Army integrated material management 

functions66 from Rock Island, Illinois, to Detroit, Michigan—which DOD 

expected to result in 20-year net costs—was combined with a proposal 

for consolidating depot-level reparable procurement across DOD and 

transferring consumable-item management to the Defense Logistics 

Agency—which DOD expected to result in 20-year net savings. The 

BRAC Commission estimated in 2005 that the resulting bundled 

candidate recommendation would save about $157 million annually, 

beginning in 2012. However, we worked directly with Defense Logistics 

Agency officials to identify the net cost or savings for each of the three 

elements of the recommendation—relocation of Army integrated material 

management functions; consolidation of depot-level reparable 

 

64DOD, Report on Base Closure and Realignment Recommendations to the BRAC 

Commission (May 13, 2005). 

65Net present value is a financial calculation that accounts for the time value of money by 

determining the present value of future savings minus up-front investment costs over a 

specific period of time. In the context of BRAC 2005 implementation, net present value is 

calculated for a 20-year period from 2006 through 2025. 

66Implementation costs associated with this element of the recommendation are 

attributable primarily to relocations that consolidate various Army Tank-automotive and 

Armaments Command integrated material management activities at Detroit, Michigan. 

DOD’s Bundling of 

Multiple Closures or 

Realignments in a Single 

Recommendation Limited 

Visibility of Costs and 

Savings Estimates and 

Complicated the 

Commission’s Review 
 

Page 46 GAO-13-149 Military Bases 

procurement; and the transfer of consumable-item management. 

According to the agency’s estimates as of September 2007, the relocation 

of Army integrated material management functions to Detroit, Michigan, 

was never estimated to have net annual savings, instead, it was 

estimated to have a net cost of nearly $11 million annually. 

In addition, some BRAC recommendations bundled closures or 

realignments that were not expected to recoup up-front costs for long 

periods of time with other proposals having shorter payback periods,67

effectively reducing the visibility of these payback periods by subsuming 

separate elements within a consolidated, or bundled, recommendation. 

For instance, the relocation of various Army offices from leased and 

government-owned space onto Fort Sam Houston, Texas, which was 

expected to recoup its up-front implementation costs after 3 years, at 

which point net savings begin to accrue, was bundled with the relocation 

of a major command—the Army Materiel Command, from Fort Belvoir, 

Virginia, to Redstone Arsenal, Alabama—which was not expected to 

recoup its up-front cost for more than 100 years.68 Bundling these 

realignments into one BRAC recommendation resulted in a more-positive 

overall financial outcome—specifically, an expected 20-year net present 

value savings of about $123 million, which DOD expected to begin 

accruing after 10 years. Similarly, the realignment of Lambert–St. Louis 

International Airport Air Guard Station, Missouri, which originally resulted 

in a 20-year net present value cost of about $22 million, was bundled with 

the closure of Otis Air National Guard Base, Massachusetts, and the 

 

67Payback period is a metric used by DOD and the BRAC Commission in evaluating 

individual BRAC recommendations and represents the time required to recoup up-front 

investment costs to implement BRAC recommendations. Thus, payback is when 

cumulative savings exceed cumulative costs. 

68DOD’s justification for relocating various Army offices from leased space onto Fort Sam 

Houston was reducing the department’s reliance on leased space, which it stated has 

historically higher overall costs than government-owned space and generally does not 

meet antiterrorism force-protection standards. DOD justified the relocation of Army 

Materiel Command from Fort Belvoir to Redstone Arsenal as the relocation would avoid 

future military construction costs at Fort Belvoir because the majority of the command’s 

space on Fort Belvoir was in temporary structures. 
 

Page 47 GAO-13-149 Military Bases 

realignment of Atlantic City Air Guard Station, New Jersey.69 The 

combined recommendation resulted in a 20-year net present value 

savings of $336 million, which DOD expected to begin accruing after 

3 years. We also found that 8 of the 21 recommendations produced by 

the Headquarters and Support Activities Joint Cross-Service Group 

consisted of packages in DOD’s report to the Commission that 

consolidated two or more recommendations that the group had previously 

approved as stand-alone candidate recommendations. In seven of those 

instances, the bundles limited the visibility of up-front costs for individual 

components that the group initially estimated would take over a decade to 

recoup. 

We recognize that, in some cases, it may make sense to combine BRAC 

actions to form a logical and cohesive summary of the steps required to, 

for example, relocate units housed on closing bases or to consolidate 

similar functions that are fragmented across the military services. 

However, we have determined that information presented should be easy 

to use, and estimates of cost and savings should describe in sufficient 

detail the calculations performed,70 and if the estimate contains multiple 

initiatives, we believe the cost to implement these initiatives should be 

separately visible in the report to better facilitate oversight and informed 

decision making for the BRAC Commission, the President, and Congress, 

as part of the BRAC process. OSD officials told us that they provided to 

the Commission the more-detailed COBRA analysis to help with 

understanding bundled recommendations. Nonetheless, BRAC 2005 

Commission executive officials told us that they found it difficult, timeconsuming, and not always possible to determine the extent to which 

costly BRAC 2005 realignments or closures were bundled with other lesscostly recommendations, and that DOD’s report to the BRAC Commission 

did not include the costs and savings expected to result from the 

components of bundled recommendations. As a result, the BRAC 

Commission, the President, and Congress did not have full visibility over 

 

69Otis Air National Guard Base, Massachusetts, remains open because the BRAC 

Commission did not recommend closing Otis Air National Guard Base. The Commission 

found that the Secretary of Defense deviated substantially from the first military value 

selection criterion and the force structure plan in the DOD proposal to close Otis. 

Massachusetts Air National Guard units located there include the 102nd Intelligence Wing, 

the 253rd Combat Communications Group, and the 267th Combat Communications 

Squadron. 

70See footnote 44. 
 

Page 48 GAO-13-149 Military Bases 

some of the estimated costs or savings potential of a number of individual 

closures and realignments, preventing closer scrutiny of the financial 

implications of the BRAC 2005 round. 

Furthermore, the 2005 BRAC Commission reported that bundling or 

comingling proposals under the title of a single recommendation made 

the work of the Commission more difficult. The Chairman of the 2005 

BRAC Commission told us that the Commission’s review for this round 

was more complicated compared to prior rounds because of the large 

number of bundled recommendations the Commission had to review. The 

Chairman stated that, in prior rounds, DOD submitted more singlecomponent recommendations, which were easier to review, and it was an 

arduous process to break bundled recommendations down into their 

component parts in order to assess whether any changes were 

necessary. Also, some of the BRAC 2005 Commission’s executive staff 

who had worked with prior BRAC Commissions told us that the practice of 

bundling multiple components into single recommendations was not as 

pervasive in prior BRAC rounds compared to the 2005 round. In addition, 

our analysis of DOD’s presentation of candidate recommendations to the 

1991, 1993, and 1995 BRAC Commissions confirmed that those rounds 

had more single stand-alone recommendations compared to BRAC 2005. 

However, we recognize that the 2005 round’s goals of furthering the 

transformation of DOD’s force structure and fostering joint capabilities 

among the military services resulted in recommendations of 

unprecedented scope and complexity. By limiting the practice of bundling, 

or requiring that components’ costs for bundled recommendations be 

disclosed, DOD will increase visibility of estimated cost and savings 

estimates for its actions and facilitate the independent review process for 

future BRAC rounds. 

The BRAC Commission was delayed in obtaining full access to DOD’s 

backup data justifying its candidate recommendations because the 

department did not adequately plan to conduct a timely review of these 

data to ensure that classified information was not compromised. As 

discussed in the BRAC Commission’s 2005 report, delays affected DOD’s 

primary backup data, meeting minutes, and scenario evaluations the 

department used to develop and justify the closure and realignment 

recommendations. According to OSD officials, intelligence officials 

screened the backup data as they were collected, and the department did 

not expect to encounter data-security issues when transmitting that 

information to the BRAC Commission. However, before the information 

was released to the BRAC Commission, an intelligence official raised 

DOD Did Not Conduct a 

Timely Review of BRAC 

Data for Potential Security 

Risks Prior to Its Release 

to the BRAC Commission 
 

Page 49 GAO-13-149 Military Bases 

concerns that, in the aggregate, some backup data could be classified 

because of the compilation of the data.71 To ensure that classified 

information was not compromised, the Deputy Secretary of Defense 

classified all of the backup data until a security review had been 

completed.72 Subsequently, DOD conducted a formal security review of 

all BRAC-related documentation. This review caused a 1-month delay in 

declassifying and releasing much of the information to the Commission, 

but without a corresponding extension in the time allotted to the 

Commission for its review. 

The BRAC statute directed specific steps in the BRAC process, such as 

when and what types of information DOD would submit to Congress and 

the BRAC Commission, and the Commission’s deadline for reporting to 

the President. For example, the statute directed DOD to submit to the 

Commission and Congress its recommendations for base closures and 

realignments no later than May 16, 2005. DOD submitted its 

recommendations on May 13, 2005, and under the BRAC statute, then 

had 7 days to transmit additional information, including a summary of the 

selection process that resulted in the recommendation for each 

installation and a justification for each recommendation. In addition, DOD 

was required to make all information it used to prepare the 

recommendations available not only to Congress, but to the BRAC 

Commission and GAO as well. Further, the statute required the 

Commission to provide a report to the President not later than September 

8, 2005. Although DOD publicly released its candidate recommendations 

to the BRAC Commission on May 13, 2005, DOD released the backup 

data to the Commission incrementally, over a period of 1 month, with the 

 

71Executive Order 12958, Classified National Security Information (Apr. 17, 1995), in 

effect during the 2005 BRAC Commission’s tenure, defined compilation as an aggregation 

of preexisting unclassified items of information. The order explained that compilation of 

items of information that are individually unclassified may be classified if the compiled 

information reveals an additional association or relationship that meets the standards for 

classification under the order and is not otherwise revealed in the individual items of 

information. 

72DOD Regulation 5200.1-R, Information Security Program (Jan. 14, 1997), established 

the department’s Information Security Program to promote the proper and effective 

classification, protection, and downgrading of official information requiring protection in the 

interest of national security and the declassification of information no longer requiring such 

protection. DOD Directive 5400.4, Provision of Information to Congress (Jan. 30, 1978), 

served as the department’s policy of providing information to Congress during the time 

OSD delivered its recommendations and supporting documentation to Congress and the 

BRAC Commission in May 2005. 
 

Page 50 GAO-13-149 Military Bases 

vast majority of the declassified data transmitted to the Commission by 

June 14. According to OSD officials, the department provided the 

Commission with all of the newly classified data at a secured location; 

however, since only a few Commission staff members had security 

clearances at the time, access to the information remained unavailable to 

the majority of the staff. The BRAC statute allows the BRAC Commission 

less than 4 months to conduct its review; however, that time frame was 

compressed further because members did not have all of the information 

in a timely manner. The Chairman of the BRAC Commission and his 

executive staff told us the delay in getting the backup data was a primary 

concern. The delay risked the Commission’s ability to comply with the law 

to complete a comprehensive review of the large number of 

recommendations proposed and submit its report to the President 

according to the mandated deadline. As the BRAC Commission noted in 

its report to the President, by anticipating the potential security risks 

presented by the aggregation of data and planning ahead to prevent 

problems with its release, DOD could have expedited the Commission’s 

review process. 

Our analysis of BRAC 2005 identified several areas where potential 

amendments to the BRAC statute could enhance oversight for Congress 

if any future BRAC rounds are authorized. First, DOD’s goals for BRAC 

2005 emphasized transformation and jointness, and the timing and extent 

of savings was not a primary selection criterion, resulting in many BRAC 

recommendations that were not expected to produce 20-year net savings. 

Also, when the BRAC Commission completed its review of DOD’s 

proposals, Congress had limited visibility of complete cost information for 

some recommendations containing contingency clauses. These clauses, 

added by the BRAC Commission, did not provide a definitive expected 

outcome for some BRAC recommendations, but instead allowed the 

outcome to be defined by events or decisions that would potentially occur 

during the implementation period, after Congress could have taken action 

under the BRAC statute to prevent the recommendations from becoming 

binding if it so chose. Should Congress wish to increase its oversight of 

any future BRAC rounds, our analysis of lessons learned from the 2005 

BRAC round identified several possible changes to the BRAC statute that 

could provide Congress with improved visibility over costs and savings 

expected from implementing BRAC recommendations and offer greater 

assurances regarding expected outcomes. 

Several Amendments 

to the BRAC Statute 

Could Offer Congress 

Greater Assurances of 

Future BRAC 

Outcomes 
 

Page 51 GAO-13-149 Military Bases 

DOD did not prioritize cost savings when establishing its goals for BRAC 

2005, and savings were not prioritized under the statutory selection 

criteria used in making closure or realignment recommendations for the 

BRAC 2005 round. While noting the necessity of eliminating excess 

physical capacity in order to preserve scarce resources, the Secretary of 

Defense emphasized that the primary objectives of BRAC 2005 were to 

transform the military by realigning base structure to better serve defense 

strategy and meet force structure needs, while fostering more jointness 

among the military services. DOD proposed eight selection criteria for 

BRAC 2005 recommendations, which it divided into two categories—

primary and secondary considerations—consistent with prior BRAC 

rounds and statutory guidance. As previously described, these criteria 

were made available for public comments by means of the Federal 

Register, and Congress ultimately codified them with minor alterations. 

The legislatively codified selection criteria for the 2005 BRAC round are 

shown in figure 8. As figure 8 shows, the selection criteria for BRAC 2005 

did not include cost savings among those criteria to be given priority 

consideration. Although reductions in excess infrastructure to generate 

cost savings remained an important goal, “the extent and timing of 

potential costs and savings,” including the number of years for the 

savings to exceed costs, was included as “other” or secondary criteria. 

DOD’s Goals and the 

BRAC Selection Criteria 

for BRAC 2005 Did Not 

Prioritize Savings 
 

Page 52 GAO-13-149 Military Bases 

Figure 8: Legislatively Codified Selection Criteria for the BRAC 2005 Round 

For prior BRAC rounds, under procedures established in the BRAC 

statute, DOD had also adopted four priority “military value” criteria and 

established “other” criteria; however, in those prior rounds Congress did 

not specify the adoption or prioritization of certain criteria in the law. 

Further, unlike prior BRAC rounds, BRAC 2005 was not primarily focused 

on reducing infrastructure to achieve savings. The 2005 BRAC 

Commission noted in its report to the President that, while previous 

rounds of BRAC had the explicit goal of saving money and downsizing 

the military in order to reap a “peace dividend,” several DOD witnesses at 

BRAC Commission hearings made it clear that the purpose of many 2005 

BRAC recommendations was to advance the goals of transformation, 

improve capabilities, and enhance military value in a manner that was not 
 

Page 53 GAO-13-149 Military Bases 

necessarily savings oriented. Similarly, after the end of the 6-year 

implementation period, the Deputy Under Secretary of Defense 

(Installations and Environment) testified in March 2012 that the 2005 

BRAC round had focused principally on reconfiguring capacity to 

maximize war fighting capability and efficiency as opposed to eliminating 

excess capacity, adding that BRAC 2005 served as an engine of 

recapitalization for enduring military facilities. The Deputy Under 

Secretary also testified that the 2005 round took place during a period of 

growth in the military, and it reflected the goals and needs of that time. 

DOD presented over 20 proposed recommendations to the BRAC 

Commission that it estimated would not result in any net savings over a 

20-year period beginning in 2006, meaning the implementation of those 

recommendations would incur net costs by year 2025. In addition, the 

2005 BRAC Commission, after conducting its review, modified some of 

DOD’s recommendations and added some of its own, ultimately 

approving 30 recommendations that were not expected to result in 

20-year net present value savings. Both DOD and the BRAC Commission 

justified those recommendations on the basis of military value. In 

comparison, DOD proposed a total of only four recommendations that 

were not expected to result in 20-year net savings in the prior four BRAC 

rounds combined. Some examples of BRAC recommendations that were 

justified on the basis of military value that were not expected to result in 

20-year net present value savings are listed in table 2. 
 

Page 54 GAO-13-149 Military Bases 

Table 2: Examples of BRAC Recommendations Estimated to Have 20-Year Net Costs 

Constant fiscal year 2005 dollars in millions 

BRAC recommendation (Commission number) Excerpts in which DOD justified the recommendation 

Estimated 20-

year net cost 

Realign Fort Bragg, NC, by relocating the 7th Special 

Forces Group to Eglin Air Force Base, FL, and by 

activating the 4th Brigade Combat Team, 82nd 

Airborne Division, and relocating European-based 

forces to Fort Bragg, NC. (#4) 

Supports the Army modular force transformation; enhances 

military value and training capabilities; and supports joint 

specialized training needs. 

$639.2

Realign Fort Hood, TX by relocating a Brigade 

Combat Team and Unit of Employment Headquarters 

to Fort Carson, CO. (#6) 

Enhances the military value of the installations and the 

home-station training and readiness of the units at the 

installations by relocating units to installations that can best 

support the training and maneuver requirements associated 

with the Army’s transformation. 

980.4

Operational Army—realigns Fort Bliss, TX; Fort 

Hood, TX; Fort Riley, KS; Fort Campbell, KY; and 

Fort Sill, OK to include rebasing of units from 

overseas to various domestic locations. (#10) 

Ensures the Army has sufficient infrastructure, training land 

and ranges to meet the requirements to transform the 

Operational Army as identified in the 20-year force 

structure plan. It also ensures the Army maintains adequate 

surge capacity. 

7,846.7

Reserve Component Transformation, MA (closes 

Army Reserve Equipment Concentration Site 65 

Annex, Ayer, MA, and realigns other units and 

facilities). (#25) 

Transforms reserve component facilities; constructs a 

multicomponent multifunctional Armed Forces Reserve 

Center; provides the opportunity for other local, state, or 

federal organizations to partner with the reserve 

components to enhance homeland security and homeland 

defense at a reduced cost to those agencies. 

60.4

Realign Beale Air Force Base, CA, and Selfridge Air 

National Guard Base, MI. (#82)a Realigns tanker aircraft from Beale to capitalize on Beale’s 

high military value and emerging mission. The receiver 

locations for Beale’s tankers each have above-average 

military value for reserve component bases in the tanker 

mission. 

57.9

Establish Joint Strike Fighter initial joint training site. 

(#125) 

Establishes Eglin Air Force Base, FL, as an initial joint 

training site that teaches entry-level aviators and 

maintenance technicians how to safely operate and 

maintain the new Joint Strike Fighter F-35 aircraft with 

curricula that permit services latitude to preserve serviceunique culture and a faculty and staff that brings a “train as 

we fight: jointly” national perspective to the learning 

process. 

226.3

Source: 2005 BRAC Commission. 

a

This recommendation had 20-year net savings before changes made by the BRAC Commission. 

 
 

Page 55 GAO-13-149 Military Bases 

In our prior work, we have found that program goals need to be carefully 

defined and supported by appropriate evaluation tools, as both can be 

key determinants of program results.73 Thus, the justification for initiating 

a BRAC round, the goals specified for the round by DOD, and the 

selection criteria used by DOD to develop candidate recommendations 

and used by the BRAC Commission to evaluate DOD’s proposed 

recommendations and to propose changes or additions as appropriate, 

are all factors in determining the results of the BRAC round. The selection 

criteria used by DOD and the BRAC Commission for BRAC 2005 

ultimately facilitated DOD’s efforts to achieve its goals for that round. We 

recognize that military value is an appropriate consideration for BRAC 

selection criteria. However, in any future BRAC round, DOD’s justification 

and goals for the round, and Congress’s direction for how the selection 

criteria should be used, will play a significant role in determining what the 

round achieves. 

In her March 2012 testimony, the Deputy Under Secretary of Defense 

(Installations and Environment) stated, “Because the focus [of the 2005 

round] was on transforming installations to better support forces—as 

opposed to saving money and space—it is a poor gauge of the savings 

that the Department can achieve through another BRAC round. The prior 

BRAC rounds—which reduced capacity and paid off in two to three 

years—represent a better gauge of such savings.” If DOD proposes 

further BRAC rounds in order to achieve savings by reducing excess 

infrastructure, and if Congress authorizes future BRAC rounds, requiring 

DOD to specify its goals and explain how the BRAC criteria for that round 

are structured to help facilitate those goals, and elevating the priority 

 

73We reviewed numerous documents related to establishing program goals, aligning them 

with the agency’s mission, and providing criteria for evaluating outcomes or criteria that 

are applicable when initiating a new program for use in evaluating expected outcomes, 

and identified key principles that we believe can be applied to establishing criteria for 

evaluating proposed BRAC recommendations. The documents we reviewed include: 

GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: January 

2012); Defense Business Transformation: Status of Department of Defense Efforts to 

Develop a Management Approach to Guide Business Transformation, GAO-09-272R 

(Washington, D.C.: Jan. 9, 2009); Results-Oriented Government: Practices That Can Help 

Enhance and Sustain Collaboration among Federal Agencies, GAO-06-15 (Washington, 

D.C.: Oct. 21, 2005); and Government Reform: Goal-Setting and Performance, 

GAO/AIMD/GGD-95-130R (Washington, D.C.: Mar. 27, 1995). We believe that these 

documents collectively contain broad themes that can be applied to defining program 

goals and establishing criteria for evaluating likely outcomes before implementing actions 

intended to achieve those goals. 
 

Page 56 GAO-13-149 Military Bases 

given to the extent and timing of potential costs and savings, are steps 

that could increase the focus on savings as a desirable outcome for that 

round. 

The BRAC Commission added contingency clauses to some 

recommendations; hence, Congress did not have complete information 

about potential costs and savings during the statutory period during which 

it could have disapproved the proposed package of recommendations. 

Under the BRAC statute, Congress has approximately 45 days from the 

date the President submits the package of recommendations to decide 

whether to disapprove the recommendations, and if it declines to do so, 

the entire package becomes binding.74 For BRAC 2005, the Commission 

submitted its report to the President on September 8, 2005, and the 

President transmitted the recommendations to Congress on September 

15, 2005. In the absence of congressional disapproval, the 

recommendations became binding on November 9, 2005. However, in a 

departure from prior BRAC rounds, the BRAC 2005 Commission added 

contingency clauses to some of DOD’s candidate recommendations. 

These clauses added conditions that were not expected to be resolved 

until after the November 9, 2005 deadline. Thus, when Congress declined 

to disapprove the recommendations and the package became binding on 

November 9, 2005, the outcome of some of the recommendations was 

unknown. 

For example, DOD submitted a candidate recommendation to the BRAC 

Commission proposing the closure of Cannon Air Force Base, New 

Mexico. However, instead of either accepting or rejecting this 

recommendation, the BRAC Commission modified the recommendation 

to make the closing of Cannon Air Force Base contingent on whether the 

Secretary of Defense could find a new mission for the base by December 

31, 2009—over 4 years after the BRAC recommendations were to 

 

74Once the recommendations become binding, DOD must initiate all closure or 

realignment actions no later than 2 years after the date on which the President transmits 

the recommendations to Congress, and must complete these actions within 6 years from 

the same date. 

Contingency Clauses for 

Some Recommendations 

Limited Congress’s 

Visibility of Complete Cost 

Information and Expected 

Outcomes 
 

Page 57 GAO-13-149 Military Bases 

become binding.75 In June 2006, DOD announced that Air Force Special 

Operations Command would establish a new mission at Cannon Air 

Force Base and the command would take ownership of the base on 

October 1, 2007. As a result, Cannon Air Force Base remained open. 

We reported in 2008 that estimated funding requirements to establish the 

Air Force Special Operations Command mission at Cannon were about 

$517 million, but this was not considered to be a BRAC 2005 

implementation cost. Furthermore, the BRAC statute requires DOD to 

initiate closure or realignment actions no later than 2 years after the 

recommendations become binding. Therefore, had DOD taken the time 

the BRAC Commission allowed and then decided to close the base, it 

would have been impossible for the department to begin the closure 

process within statutory time frames. 

In another example, the BRAC Commission added a recommendation to 

realign Oceana Naval Air Station, Virginia, by relocating the East Coast 

Master Jet Base to Cecil Field, Florida, but only if the Commonwealth of 

Virginia and the municipal governments of Virginia Beach and 

Chesapeake, Virginia, failed to enact and enforce legislation to prevent 

further encroachment of Naval Air Station Oceana by the end of March 

2006. Once again, this was after the date BRAC recommendations 

became binding on November 9, 2005. In addition, this recommendation 

was contingent on the actions of state and local governments—entities 

over which DOD has no authority. Further, the Commission did not 

provide the President or Congress with any cost or savings estimates for 

this recommendation. As part of the 1993 BRAC round, Naval Air Station 

Cecil Field was closed in 1999 and the fighter jets stationed at Cecil Field 

were relocated to Oceana Naval Air Station, Virginia. Cecil Field remains 

closed while Naval Air Station Oceana remains open. The timeline of 

decision points related to Cannon Air Force Base and Oceana Naval Air 

Station is depicted in figure 9. 

 

75The BRAC Commission, rather than rejecting the Secretary’s recommendation to close 

Cannon Air Force Base, recommended realigning Cannon Air Force Base, New Mexico, 

by disestablishing the 27th Fighter Wing and distributing its aircraft to meet the Primary 

Aircraft Authorization requirements established by the base closure and realignment 

recommendations of the Secretary of Defense, as amended by the Base Closure and 

Realignment Commission. 
 

Page 58 GAO-13-149 Military Bases 

Figure 9: Timeline Showing Decision Points Related to Cannon Air Force Base and Oceana Naval Air Station Contingency 

Recommendations 

The addition of contingencies by the BRAC Commission and the absence 

of cost and savings estimates related to those contingencies prevented 

the President and Congress from having complete information on which 

to base their decisions within the time frames required for BRAC 2005. 

Recent budget projections by GAO, the Congressional Budget Office, and 

others show that the federal government is on an unsustainable long-term 

fiscal path. New budgetary demands and demographic trends will place 

serious budgetary pressures on federal discretionary spending, as well as 

on other federal policies and programs, in the coming years. As resources 

become scarce, competition for them will increase. It is imperative, 

therefore, that government programs deliver as promised, not only 

because of their value to their users but because every dollar spent on 

one program may mean one less available dollar to fund other efforts. By 

taking steps to increase the fidelity of the initial cost estimates that it 

submits to the BRAC Commission for a future BRAC round—especially 

for potentially costly military construction and significant information 

technology projects—as well as improving the standard factors used by 

its cost-estimating model, and ensuring that BRAC analysts have a sound 

basis for data entered into the COBRA model, the department could 

enhance public confidence in the BRAC process and take better 

advantage of opportunities to achieve cost savings that it can apply to 

other defense priorities. 

Conclusions 
 

Page 59 GAO-13-149 Military Bases 

Additionally, both Congress and the executive branch have recognized 

the importance of focusing on agency performance and results. To 

achieve better results, program officials will need higher levels of 

knowledge when they start, and careful monitoring so that better 

estimates can be made of total program costs at completion. The BRAC 

process is no exception. By establishing targets for reducing excess 

capacity, identifying appropriate measures of effectiveness, and planning 

to track those measures, DOD will be in a much stronger position to 

demonstrate the benefits it achieves relative to the up-front 

implementation costs for any future BRAC round. Taking steps to be a 

more results-oriented agency may also help DOD to gain approval for 

additional rounds of BRAC in the future. Similarly, improving its BRAC 

planning processes to ensure greater visibility over estimated costs and 

savings for proposed recommendations—such as limiting the practice of 

bundling many potentially stand-alone realignments or closures into 

single recommendations—would better inform decision making and 

provide Congress a more-complete picture of the budgetary implications 

of any future BRAC round. Without providing both Congress and the 

BRAC Commission with better insight into the costs and savings potential 

of individual recommendations and any proposed BRAC round as a 

whole, DOD could potentially risk its ability to use BRAC as a tool for 

reducing excess capacity and ensuring that its infrastructure efficiently 

and effectively meets the needs of its force structure. Further, limiting the 

practice of bundling in the future could facilitate the independent review 

process for any future BRAC Commission. Similarly, DOD could facilitate 

the Commission’s review by planning to complete its review of potentially 

classified data, and ensuring that all supporting data for its candidate 

recommendations are submitted to the Commission, in a timely manner. 

Finally, in March 2012, the House Armed Services Committee’s 

Subcommittee on Readiness held a hearing to discuss DOD’s request 

for authorization of another BRAC round. At that hearing, we testified that 

the goals of any future BRAC round and the recommendation selection 

criteria would go a long way toward determining the nature of that round. 

Therefore, should Congress approve another round of BRAC, and if it 

wishes to increase its oversight of that round, our lessons-learned 

review identified several legislative steps that could improve visibility—

particularly over the costs and savings that such a round might 

produce—and offer greater assurances regarding expected outcomes of 

DOD’s recommendations. If Congress takes steps to improve its 

oversight of the cost savings potential of a proposed BRAC round, such 

as modifying the BRAC selection criteria and limiting the BRAC 

Commission from including in its approved recommendations 
 

Page 60 GAO-13-149 Military Bases 

contingencies that will not be resolved until after the time frame provided 

under the BRAC statute for Congress to act on the entire package of 

proposed recommendations, Congress may be able to enhance its 

information about likely results from BRAC before it has to decide 

whether to permit the recommendations to be implemented. 

We are making 10 recommendations for executive action, contingent on 

the authorization of a future BRAC round, as follows. 

To increase the fidelity of the initial cost estimates that DOD submits with 

its recommendations to the BRAC Commission for a future BRAC round, 

we recommend that the Secretary of Defense direct the Under Secretary 

of Defense (Acquisition, Technology and Logistics) to 

 work with the military services, defense agencies, and other 

appropriate stakeholders to improve the process for fully identifying 

recommendation-specific military construction requirements and 

ensuring that those requirements are entered into the COBRA model 

and not understated in implementation costs estimates prior to 

submitting recommendations to the BRAC Commission; 

 establish a process for ensuring that information technology 

requirements associated with candidate recommendations that are 

heavily reliant on such technology have been identified to the extent 

required to accomplish the associated mission, before 

recommendations and cost estimates are submitted to the BRAC 

Commission; and 

 ensure that, during the development and comparison of BRAC 

scenarios, all anticipated BRAC implementation costs—such as 

relocating personnel and equipment—are considered and included in 

the COBRA model when comparing alternatives and generating cost 

estimates. 

To increase confidence in the fidelity of the cost estimates that DOD 

submits to the BRAC Commission for a future BRAC round, we 

recommend that the Secretary of Defense direct the Under Secretary of 

Defense (Acquisition, Technology and Logistics) to 

 take steps to ensure that COBRA’s standard factor for information 

technology is updated and based on technological developments 

since the most recent COBRA update; and 

Recommendations for 

Executive Action 
 

Page 61 GAO-13-149 Military Bases 

 update COBRA guidance to require users to provide a narrative 

explaining the process, sources, and methods used to develop the 

data entered into COBRA to develop military personnel positionelimination savings. 

To improve planning for measuring the results of implementing the BRAC 

recommendations for a future BRAC round, we recommend that the 

Secretary of Defense direct the Deputy Under Secretary of Defense 

(Installations and Environment) to 

 identify appropriate measures of effectiveness and develop a plan to 

demonstrate the extent to which the department achieved the results 

intended from the implementation of the BRAC round; and 

 establish a target for eliminating excess capacity in its initiating 

guidance to high-level department-wide leadership, consistent with 

the BRAC selection criteria chosen for a future BRAC round. 

To provide more-complete information and increased visibility into the 

expected costs and savings for individual BRAC closures or realignments, 

we recommend that, when planning any potential future BRAC round, the 

Secretary of Defense direct the Under Secretary of Defense (Acquisition, 

Technology and Logistics) to 

 limit the practice of bundling many potentially stand-alone 

realignments or closures into single recommendations; and 

 if DOD determines that bundling multiple realignments or closures into 

one recommendation is appropriate, itemize the costs and savings 

associated with each major discrete action in its report to the BRAC 

Commission. 

Further, to ensure that the BRAC Commission receives timely access to 

information supporting BRAC recommendations for its review, we 

recommend that the Secretary of Defense develop a process to ensure 

that any data-security issues are resolved in time to provide all 

information to the BRAC Commission in a timely manner by conducting a 

security review of all BRAC data during DOD’s recommendation 

development process, to include a review of the aggregation of 

unclassified data for potential security concerns and possible 

classification if necessary. 
 

Page 62 GAO-13-149 Military Bases 

If cost savings are to be a goal of any future BRAC round, Congress may 

wish to consider amending the BRAC statute by elevating the priority 

DOD and the BRAC Commission give to potential costs and savings as a 

selection criterion for making base closure and realignment 

recommendations. 

Also, if Congress authorizes additional BRAC rounds, it may wish to 

consider amending BRAC legislation by requiring the Secretary of 

Defense to 

 formally establish specific goals that the department expects to 

achieve from a future BRAC process; and 

 propose selection criteria as necessary to help achieve those goals, if 

necessary and appropriate. 

Finally, if Congress decides to authorize a future base closure round, it 

may want to consider whether to limit or prohibit the BRAC Commission 

from adding a contingent element to any recommendation and, if 

permitted, under what conditions. 

We provided a draft of this report to DOD for review and comment. In 

response, DOD concurred with 3 of our 10 recommendations, partially 

concurred with 2, and did not concur with 5. 

As we have stated in prior GAO reports, the BRAC process is 

fundamentally sound. We have reported that DOD’s process for 

conducting its BRAC 2005 analysis was generally logical, reasoned, and 

well documented and we continue to believe that the process remains 

fundamentally sound based on this review, although our analysis 

identified several opportunities to improve the process for any future 

rounds. Moreover, our conclusion that the BRAC process is sound does 

not preclude opportunities for improvement, and it is in that spirit that we 

offer our recommendations. 

After considering the points raised by DOD in its comments, we believe 

that our recommendations continue to have merit because they could 

improve and strengthen BRAC outcomes by incorporating more 

accountability into the process. By extension this would enhance a future 

BRAC Commission’s ability to effectively and efficiently review DOD’s 

candidate recommendations and Congress’s understanding of the impact 

of these recommendations. 

Matters for 

Congressional 

Consideration 

Agency Comments 

and Our Evaluation 
 

Page 63 GAO-13-149 Military Bases 

In its letter to us, OSD equated our discussion of the importance of 

establishing measurements of effectiveness and capacity reduction 

targets with requiring DOD to close a particular number of bases or 

eliminate a particular number of civilian jobs. OSD also stated that our 

report advocates prioritizing reductions in infrastructure over optimizing 

military value. To the contrary, nothing in our recommendations to 

improve the process precludes optimizing military value. OSD also stated 

that our report implies that the mismatch between actual BRAC costs and 

the initial estimates reflects flaws in the cost estimating model rather than 

the impact of subsequent decisions. We recognize that actual costs differ 

from the original estimates due to decisions that were subsequently 

made. However, our recommendations related to COBRA are to improve 

the information that DOD enters into the model, not the model itself. Cost 

estimating models generally produce more reliable outputs with more 

complete and accurate data inputs, and that is the intent of our 

recommendations related to DOD’s COBRA model. 

DOD did not concur with our first recommendation, to improve the 

process for fully identifying recommendation-specific military construction 

requirements and ensuring that those requirements are entered into 

COBRA and not understated in implementation cost estimates. DOD 

stated that the primary advantage of COBRA is to provide real-time 

comparison of scenarios to aid analysis and decision making, not to 

develop budget-quality estimates. As our report clearly states, we 

recognize that COBRA is not intended to provide budget-quality 

estimates, but that does not preclude the possibility of improvements to 

COBRA. We believe that, if DOD were to implement our 

recommendation, the result would be more accurate initial cost estimates 

that DOD submits to the BRAC Commission for review. 

DOD partially concurred with our second recommendation, to establish a 

process for ensuring that information technology requirements associated 

with candidate recommendations heavily reliant on such technology have 

been identified before submission to the Commission. DOD 

acknowledged that information technology costs should be better 

estimated but added that a separate process is not necessary and stated 

that it can improve cost estimating by reevaluating the standard factors 

used in COBRA and by providing additional guidance as appropriate. Our 

intent was to provide DOD flexibility in deciding how to implement our 

recommendation, so we did not recommend a separate process 

specifically, just one that improves the accuracy of cost estimating for 

information technology requirements. If DOD chooses to improve COBRA 

to ensure more accurate information technology requirements are 
 

Page 64 GAO-13-149 Military Bases 

identified during DOD’s decision-making process, those actions would 

meet the intent of our recommendation. 

DOD did not concur with our third recommendation, to ensure that all 

anticipated BRAC implementation costs, such as relocating personnel 

and equipment, are considered and included in the COBRA model when 

comparing alternatives and generating initial cost estimates during DOD’s 

decision-making process. DOD reiterated that COBRA is not designed to 

develop budget quality estimates, nor can it reflect future implementation 

investment decisions made after BRAC recommendations become 

binding. We acknowledge that COBRA cannot predict future decisions but 

we still believe that including likely BRAC recommendation 

implementation costs will produce a more reliable initial cost estimate, 

and therefore a better basis for scenario comparisons; hence we continue 

to believe that there is need for our recommendation. 

DOD concurred with our fourth and fifth recommendations, to update the 

standard factor for information technology used in COBRA, and to update 

COBRA guidance to require users to provide an explanation for the 

methodology used to develop military personnel position-elimination 

savings. 

DOD did not concur with our sixth recommendation, to identify measures 

of effectiveness and develop a plan to demonstrate the extent to which 

DOD achieved its intended results from a future BRAC round. DOD 

stated that military value should continue to be the key driver for BRAC. 

Nothing in our recommendation undermines DOD’s reliance on military 

value as the primary selection criteria for DOD’s base closure and 

realignment candidate recommendations. Measures of effectiveness 

provide federal agencies information on the extent to which goals and 

objectives have been achieved. DOD can still prioritize military value 

while identifying measures that help determine whether DOD achieved 

the military value that it seeks. We believe that, if DOD effectively 

implements our recommendation, the department is likely to have a better 

understanding of whether it achieved its intended results while still 

continuing to enhance military value from particular BRAC 

recommendations. DOD also stated that its business plan process is the 

best way to measure effectiveness. We acknowledge the benefits of 

business plans; however, these business plans address implementation 

of individual BRAC recommendations and not the effectiveness of the 

BRAC process as a whole. Hence, we continue to believe that there is 

need for our recommendation. 
 

Page 65 GAO-13-149 Military Bases 

DOD did not concur with our seventh recommendation, to establish a 

target for eliminating excess capacity in DOD’s initiating guidance to highlevel department-wide leadership consistent with the BRAC selection 

criteria chosen for a future BRAC round. DOD stated that goals or 

overarching capacity targets would subvert the intent of the BRAC statute 

to develop recommendations based on military value and would preclude 

examination of a full array of closure and realignment options. In March 

2004, the Secretary of Defense reported to Congress that DOD needed 

the BRAC 2005 round because, at that time, DOD had about 24 percent 

excess capacity. Similarly, in 2012, the Secretary of Defense noted that 

incurring costs to maintain large infrastructure reduces funds needed to 

train and support service members, thus suggesting that disposing of 

excess capacity to save money is important. Our recommendation 

specifies that targets should be consistent with the BRAC selection 

criteria, which does not interfere with DOD’s reliance on military value as 

the primary criteria for making recommendations. The setting of targets is 

simply a means to identify the magnitude of needed reductions while the 

military value selection criteria can remain the primary consideration in 

making recommendations for closure and realignment. Consequently, if 

DOD still believes it has excess capacity and requests authorization for 

BRAC rounds on that basis, then our recommendation can enhance 

DOD’s ability to achieve its goal. 

DOD did not concur with our eighth recommendation, to limit the practice 

of bundling potentially stand-alone realignments or closures into single 

BRAC recommendations. DOD does not believe bundling is problematic 

and stated that the examples we cited were bundled since they shared a 

common mission and purpose, and bundling maximized military value. 

Nonetheless, as our report notes, the practice of bundling can limit 

visibility into the estimated costs and savings for individual closures or 

realignments that are elements of the bundle and can make the 

Commission’s review more difficult, although DOD disputed this latter 

point too. However, the 2005 BRAC Commission’s executive staff told us 

that bundling made their review more difficult because of the need to 

deconstruct the bundle to assess whether any changes were necessary, 

as our report clearly states. Further, we acknowledge that in some cases 

bundling is warranted, and it is for this reason we recommended limiting 

the practice, not prohibiting it. 

DOD partially concurred with our ninth recommendation, to itemize the 

costs and savings associated with each major discrete action in its report 

to the BRAC Commission of bundled realignments and closures when 

bundling is determined to be warranted. DOD stated that where 
 

Page 66 GAO-13-149 Military Bases 

appropriate, the department could highlight cost and savings associated 

with major actions, and that action would meet the intent of our 

recommendation. 

DOD concurred with our tenth recommendation to develop a process to 

ensure that any data-security issues are resolved in a timely manner at 

the outset of any future BRAC round. 

Finally, DOD did not concur with our matter for congressional 

consideration that Congress may wish to require the Secretary of 

Defense to formally establish specific goals the department expects to 

achieve from a future BRAC round. However, the Secretary of Defense 

did establish goals for BRAC 2005 in his report to Congress certifying the 

need for a BRAC round in March 2004. Specifically, the Secretary of 

Defense reported to Congress that the BRAC 2005 round would be used 

to (1) promote force transformation, (2) enhance jointness, and (3) 

dispose of excess facilities. As we have previously testified, establishing 

such goals for BRAC 2005 helps to explain the results, and we continue 

to believe that Congress may want to require the Secretary of Defense to 

establish goals, as he did in 2004. DOD did not comment on the 

remaining matters for congressional consideration in our report. 

DOD’s written comments are reprinted in appendix III. 

We are sending copies of this report to the appropriate congressional 

committees. We are also sending copies to the Secretary of Defense; the 

Under Secretary of Defense (Comptroller); the Under Secretary of 

Defense (Acquisition, Technology and Logistics); the Secretaries of the 

Army, Navy, and Air Force; the Commandant of the Marine Corps; and 

the Deputy Under Secretary of Defense (Installations and Environment). 

This report will also be available at no charge on our website at 

http://www.gao.gov. 

 
 

Page 67 GAO-13-149 Military Bases 

Should you or your staff have any questions concerning this report, 

please contact me at (202) 512-4523 or leporeb@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. Key contributors are listed in 

appendix IV. 

Brian J. Lepore 

Director 

Defense Capabilities and Management 

 
 

Page 68 GAO-13-149 Military Bases 

List of Committees 

The Honorable Carl Levin 

Chairman 

The Honorable James N. Inhofe 

Ranking Member 

Committee on Armed Services 

United States Senate 

The Honorable Richard J. Durbin 

Chairman 

The Honorable Thad Cochran 

Ranking Member 

Subcommittee on Defense 

Committee on Appropriations 

United States Senate 

The Honorable Tim Johnson 

Chairman 

The Honorable Mark Kirk 

Ranking Member 

Subcommittee on Military Construction, Veterans’ Affairs, and Related 

Agencies 

Committee on Appropriations 

United States Senate 

The Honorable Howard P. “Buck” McKeon 

Chairman 

The Honorable Adam Smith 

Ranking Member 

Committee on Armed Services 

House of Representatives 

The Honorable C.W. Bill Young 

Chairman 

The Honorable Pete Visclosky 

Ranking Member 

Subcommittee on Defense 

Committee on Appropriations 

House of Representatives 
 

Page 69 GAO-13-149 Military Bases 

The Honorable John Culberson 

Chairman 

The Honorable Sanford Bishop 

Ranking Member 

Subcommittee on Military Construction, Veterans’ Affairs, and Related 

Agencies 

Committee on Appropriations 

House of Representatives 
Appendix I: Objectives, Scope, and 

Methodology 

Page 70 GAO-13-149 Military Bases 

For this lessons-learned report, our objectives were to determine (1) how 

the Department of Defense (DOD) estimated the cost and savings for 

base realignment and closure (BRAC) 2005 and the extent to which its 

estimating methodology could be improved; (2) the extent to which the 

Office of the Secretary of Defense (OSD) provided high-level leadership 

over the planning and management of the BRAC 2005 round, and what 

opportunities, if any, exist to enhance planning and management of any 

future BRAC round; and (3) what legislative changes, if any, could 

Congress make that would enhance the oversight of a future round of 

BRAC. 

To determine how DOD estimated the costs and savings that would result 

from BRAC 2005 and the extent to which its methodology could be 

improved, we reviewed key documents related to BRAC 2005, such as 

DOD’s May 2005 base realignment and closure report, and BRAC 

business plans that laid out the cost and savings estimates for the actions 

required to implement the recommendations. We analyzed DOD’s costestimating model, the Cost of Base Realignment Actions (COBRA), and 

its supporting documentation. We analyzed the model’s inputs and 

standard factor assumptions and reviewed documentation on scenario 

data calls. We discussed with the military services and officials from OSD 

the process for identifying requirements for facilities and other necessary 

items for implementing BRAC recommendations and including them in 

the cost estimates produced by COBRA. We reviewed numerous federal 

guidance documents related to cost estimating, accounting standards, 

economic analysis, and budgeting and identified key principles that we 

believe are applicable to effectively evaluating cost estimates. These 

principles are 

 there should be an appropriate level of detailed documentation such 

that a reasonably informed person could easily recreate, update, or 

understand the cost estimate; 

 all significant costs and key assumptions should be included; 

 the reliability of the data used to develop the estimate should be 

verified or validated; and 

 the accuracy of the calculations performed should be verified or 

validated. 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology 

Page 71 GAO-13-149 Military Bases 

The guidance documents we reviewed include: GAO Cost Estimating and 

Assessment Guide, GAO-09-3SP; Office of Management and Budget 

Circular No. A-11, Preparation, Submission and Execution of the Budget

(August 2011, superseded by an August 2012 issuance); Federal 

Accounting Standards Advisory Board, Statement of Federal Financial 

Accounting Standards 4 (June 2011); DOD Instruction 7041.3, Economic 

Analysis for Decisionmaking (Nov. 7, 1995); and DOD Financial 

Management Regulation 7000.14-R, volume 4, chapter 22, Cost Finding

(May 2010). We believe that these documents collectively contain broad 

themes that are applicable to evaluating cost analyses. To apply these 

key principles, we interviewed officials in the Office of the Deputy Under 

Secretary of Defense’s (Installations and Environment) Basing 

Directorate, the office responsible for overseeing BRAC implementation. 

In addition, we analyzed the 2005 BRAC Commission’s September 2005 

report to the President and DOD’s BRAC 2005 budget submissions to 

Congress to track changes in cost and savings estimates. Further, we 

reviewed our prior work related to costs and savings from BRAC 2005, 

including multiple reports updating costs and savings estimates from 

BRAC 2005 and discussing the reasons for variances from earlier 

estimates. For a list of our reports related to BRAC 2005, see the Related 

GAO Products section at the end of this report. 

To determine the extent to which OSD provided high-level leadership 

over the planning and management of BRAC 2005, and what 

opportunities, if any, exist to enhance planning and management of any 

future BRAC round, we reviewed OSD policy memorandums and 

guidance on conducting BRAC 2005, documents discussing security 

procedures specific to BRAC 2005 and results-oriented reporting 

requirements, the results of prior BRAC rounds, meeting minutes of the 

BRAC 2005 Infrastructure Executive Council, and the 2005 BRAC 

Commission Report to the President. In addition, we interviewed the 

Chairman of the 2005 BRAC Commission, members of the Commission’s 

executive staff, and the former Deputy Under Secretary of Defense 

(Installations and Environment) who oversaw BRAC 2005 between April 

2001 and November 2004, to obtain their insights on the BRAC 2005 

process. We also spoke with OSD and military service officials 

knowledgeable about efforts to provide supporting documents to the 

BRAC Commission for analysis and review, and we discussed efforts to 

develop outcome-oriented performance measures for BRAC rounds with 

officials from OSD. 

To determine what, if any, legislative changes Congress could make that 

would enhance the oversight of a future round of BRAC, we reviewed the 
Appendix I: Objectives, Scope, and 

Methodology 

Page 72 GAO-13-149 Military Bases 

process for developing, reviewing, and implementing BRAC 2005 

recommendations, and compared it to processes used in prior rounds of 

BRAC. Specifically, we reviewed the Secretary of Defense’s policy 

statements related to the goals of BRAC 2005 and compared them to the 

goals of prior BRAC rounds. We reviewed meeting minutes from DOD’s 

Infrastructure Executive Council and from DOD’s Infrastructure Steering 

Group, and documents produced in consultation with DOD’s “Red Team,” 

which was charged with evaluating DOD proposals prior to their 

submission to the BRAC Commission for review.76 We reviewed the goals 

of BRAC 2005 and the statutorily mandated BRAC criteria using key 

principles we derived from documents related to program evaluations, 

and identified key principles that we believe can be applied to establishing 

BRAC goals and criteria for use in evaluating BRAC recommendations. 

The key principles we discuss here are included in documents such as 

Designing Evaluations: 2012 Revision, GAO-12-208G; Performance 

Measurement and Evaluation: Definitions and Relationships, 

GAO-05-739SP; Government Reform: Goal Setting and Performance, 

GAO/AIMD/GGD-95-130R; Results-Oriented Government: Practices That 

Can Help Enhance and Sustain Collaboration among Federal Agencies, 

GAO-06-15; and Defense Business Transformation: Status of Department 

of Defense Efforts to Develop a Management Approach to Guide 

Business Transformation, GAO-09-272R. We identified certain 

recommendations that the BRAC Commission either added or modified 

that were contingent on events occurring outside the BRAC process, and 

analyzed those recommendations to determine how they could affect 

congressional visibility and oversight. We interviewed officials from the 

OSD Basing Directorate, OSD General Counsel, and the BRAC 

Commission to obtain their views on any changes that could enhance 

oversight. 

 

76In the later stages of the BRAC analysis, the department engaged a small group of 

executive-level former government officials, called the “Red Team,” to provide an 

independent assessment of candidate recommendations. The Red Team met with each 

military department and joint cross-service group. It reviewed candidate 

recommendations, report drafts, and supporting materials. The team’s insights provided 

feedback and suggestions for improving the quality of the candidate recommendations 

submitted to the BRAC Commission for review. 
Appendix I: Objectives, Scope, and 

Methodology 

Page 73 GAO-13-149 Military Bases 

In the course of our review, we interviewed the following specific 

personnel and entities: 

 former Chair and executive staff members from the BRAC 2005 

Commission; 

 former Deputy Under Secretary of Defense for Installations and 

Environment; 

 former Deputy Assistant Secretaries for BRAC—Army, Navy, and Air 

Force; 

 former DOD BRAC “Red Team” Leader; 

 Office of the Under Secretary of Defense (Comptroller); 

 OSD Basing Directorate; 

 OSD BRAC General Counsel; 

 OSD Office of Economic Adjustment; 

 former members of the following BRAC 2005 joint cross-service 

groups: 

 Headquarters and Support Activities, 

 Industrial, 

 Medical, 

 Supply and Storage, and 

 Technical; and 

 military-service BRAC offices: 

 Army, 

 Navy, and 

 Air Force. 

We began this performance audit in March 2011, but suspended the 

review at various points to respond to three congressional hearings 
Appendix I: Objectives, Scope, and 

Methodology 

Page 74 GAO-13-149 Military Bases 

related to BRAC (two testimonies on how a BRAC-like process may be 

useful for disposing of excess federal real property in April 201177 and 

June 2011,78 and a testimony on BRAC 2005 results in March 201279) 

and to issue a separate report updating the costs and savings associated 

with BRAC 2005 in June 2012.80 We reinstated this review in August 

2012, and completed it in March 2013. We conducted this performance 

audit in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

 

77GAO, Federal Real Property: Progress Made on Planning and Data, but Unneeded 

Owned and Leased Facilities Remain, GAO-11-520T, (Washington, D.C.: April 6, 2011). 

78GAO, Federal Real Property: Proposed Civilian Board Could Address Disposal of 

Unneeded Facilities, GAO-11-704T (Washington, D.C.: June 9, 2011). 

79GAO, Military Base Realignments and Closures: Key Factors Contributing to BRAC 

2005 Results, GAO-12-513T (Washington, D.C.: Mar. 8, 2012). 

80GAO, Military Base Realignments and Closures: Updated Costs and Savings Estimates 

from BRAC 2005, GAO-12-709R (Washington, D.C.: June 29, 2012). 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 75 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

GAO-13-134—DOD Joint Bases: Management Actions Needed to Achieve Greater Efficiencies (Nov. 16, 2012) 

Develop and implement a plan that 

provides measurable goals linked to 

achieving savings and efficiencies at the 

joint bases and provide guidance to the 

joint bases that directs them to identify 

opportunities for cost savings and 

efficiencies. The Department of Defense 

(DOD) should at a minimum consider the 

items identified in its recommendation to 

the 2005 Base Realignment and Closure 

(BRAC) Commission as areas for possible 

savings and efficiencies, including: 

 paring unnecessary management 

personnel, 

 consolidating and optimizing contract 

requirements, 

 establishing a single space 

management authority to achieve 

greater utilization of facilities, and 

 reducing the number of base support 

vehicles and equipment. 

Did not concur. DOD said such targets 

would burden and restrict the authority of 

local commanders to manage the merger of 

the formerly stand-alone bases into joint 

bases while implementing new 

organizational structures, which would 

unnecessarily risk negative impacts to 

mission support when operational 

effectiveness of the bases is paramount. 

DOD stated that the department should 

continue its patient approach to obtaining 

savings and efficiencies at joint bases 

because it is working. All of the Air Force–

led joint bases reduced civilian positions, 

and the Navy chose to not fill all of their 

civilian vacancies. Finally, the creation of 

the joint bases is equivalent to the mergers 

of corporations with very different financial 

systems, management structures, 

operating procedures, and cultural 

differences. DOD stated the importance of 

empowering each joint base commander to 

design, implement, and adapt cost efficient 

and effective approaches to their unique 

situations while adopting new and crosscutting business practices, as incubators of 

innovation. DOD decided to allow for an 

extended transition period and defer nearterm savings. 

DOD actions not expected. 

Continue to develop and refine the Cost 

Performance and Visibility Framework in 

order to 

 eliminate data reliability problems, 

 facilitate comparisons of joint basing 

costs with the cost of operating the 

separate installations prior to 

implementing joint basing, and 

 identify and isolate the costs and 

savings resulting from actions and 

initiatives specifically resulting from 

joint basing and excluding DOD- or 

service-wide actions and initiatives. 

Partial concur. DOD stated that its Cost 

Performance and Visibility Framework 

already provides a method to collect 

quarterly data on performance towards the 

Common Output Level Standards, annual 

data on personnel assigned, and funds 

obligated for each joint base. However, 

DOD is addressing inconsistencies in the 

current data captured in the Framework 

and is improving its data reliability with 

considerable investment and the 

expectation to begin assessing joint base 

efficiencies by the end of fiscal year 2012. 

DOD stated it would be able to make 

several comparisons, such as the current 

fiscal year financial and performance data 

to the baseline and previous year’s 

obligations; and the joint base’s baseline 

data with the costs of operating the 

separate installations prior to implementing 

joint basing. DOD acknowledged that the 

comparison of the costs of operating 

DOD actions pending. 

Appendix II: List of Prior GAO Reviews 

Related to BRAC 2005, Related 

Recommendations, and DOD Actions to Date 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 76 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

separate installations would not identify 

cost savings resulting solely from joint 

basing and asserted the impracticality of 

isolating and distinguishing joint basing 

cost savings from the savings that result 

from DOD- or Service-wide actions using 

the data contained in its Framework. 

Further, DOD pointed out that it did not 

believe that accounting systems are 

designed to track savings, rather they are 

designed to track expenses and 

disbursements. 

Direct the joint bases to compile a list of 

those common standards in all functional 

areas needing clarification and the reasons 

why they need to be clarified, including 

those standards still being provided or 

reported on according to service-specific 

standards rather than the common 

standard. 

Partial concur. DOD stated that a 

quarterly feedback process on the joint 

base common standards and an annual 

review process that incorporates input from 

the joint bases already exist. Further, 

standards may need changing as priorities 

change and missions evolve, but the 

current process strikes an appropriate 

balance between the analytical burden of 

repeated reviews with the need for clarity 

and refinement. DOD also stated that it 

believes that reviewing all the standards 

simultaneously does not allow for the depth 

of analysis required to make sound 

decisions, and suggested that GAO 

conduct a qualitative assessment of the 

standards because the findings appear to 

be based on an anecdotal assessment. 

DOD actions pending. 

Amend the Office of the Secretary of 

Defense (OSD) joint standards review 

process to prioritize review and revision of 

those standards most in need of 

clarification within this list. 

Partial concur. See above. DOD actions pending. 

Develop a common strategy to expand 

routine communication between the joint 

bases, and between the joint bases and 

OSD, to encourage joint resolution of 

common challenges and sharing of best 

practices and lessons learned. 

Partial concur. DOD stated that it believed 

there are already mechanisms in place to 

facilitate routine communication between 

the joint bases, as well as between OSD 

and the joint bases, and that it is increasing 

those opportunities. DOD listed the various 

opportunities it has for sharing joint basing 

information, including yearly joint base site 

visits and an annual management review 

meeting with the joint base commanders. 

DOD actions pending. 

Develop guidance to ensure all the joint 

bases develop and provide training 

materials to incoming personnel on how 

installation services are provided on joint 

bases. 

Partial concur. DOD stated that it will 

ensure each of the services is providing 

training materials to incoming personnel; 

however, joint base commanders need 

flexibility to tailor training to the needs of 

their installation. 

DOD actions pending. 

 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 77 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

GAO-12-770R—Military Base Realignments and Closures: The National Geospatial-Intelligence Agency’s Technology Center 

Construction Project (June 29, 2012) 

No recommendations were included in this 

report. We reported that National 

Geospatial-Intelligence Agency (NGA) 

officials modified the original scope of work 

for the center during construction by not 

outfitting one of the two floors of the new 

building originally planned for data storage 

because they believed both floors would 

have provided more storage than required, 

beyond the intent of the BRAC 

recommendation to consolidate existing 

capability. We found a lack of clarity 

regarding responsibility for oversight of this 

project. The decision to change the scope 

was not communicated to OSD, to the 

project’s business manager—the 

Department of the Army—or to Congress. 

These stakeholders were unable to 

participate in the decision; however, the 

NGA provided them with information 

regarding the decision at a later date. 

N/A N/A 

GAO-11-814—Excess Facilities: DOD Needs More Complete Information and a Strategy to Guide Its Future Disposal Efforts 

(Sept. 19, 2011) 

Develop and implement a methodology for 

calculating and recording utilization data for 

all types of facilities, and modify processes 

to update and verify the accuracy of 

reported utilization data to reflect a facility’s 

true status. 

Partial concur. DOD has already begun 

some efforts to improve its utilization data 

and will continue the development and 

implementation of appropriate procedures. 

DOD did not specify what actions it has 

completed to date or the time frames for 

completion. 

DOD actions pending. 

Develop strategies and measures to 

enhance the management of DOD’s excess 

facilities after the current demolition 

program ends, taking into account external 

factors that may affect future disposal 

efforts. 

Concur. DOD stated it will work with the 

military departments to continue to develop 

and implement the most effective and 

efficient methods to eliminate excess 

facilities and excess capacity, but did not 

provide any details or specific time frames 

for these efforts. 

DOD actions pending. 

 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 78 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

GAO-11-165—Defense Infrastructure: High-Level Federal Interagency Coordination Is Warranted to Address Transportation 

Needs Beyond the Scope of the Defense Access Roads Program (Jan. 26, 2011) 

Update regulations and clarify guidance for 

the Defense Access Roads certification and 

funding process; develop working-level 

guidance for potential program users; and 

effectively communicate the regulations 

and working-level guidance to all federal, 

state, and local stakeholders. 

Partial concur. DOD stated that although it 

will work with the Department of 

Transportation to update Defense Access 

Roads regulations and clarify guidance, 

they believe sufficient guidance for and 

awareness of the program exists. 

DOD actions pending. In January 2012, 

the Deputy Under Secretary of Defense for 

Installations and Environment stated that 

the office issued a coordination 

memorandum that was awaiting signature. 

The memorandum asks the military 

departments to coordinate on a draft policy 

change to the Defense Access Roads 

criteria. The Deputy Under Secretary of 

Defense did not have a projected date by 

which the coordination memorandum would 

be signed, nor did the office know whether 

it would be signed. In July 2012, DOD 

stated that updating the Defense Access 

Roads regulation involves multiple 

stakeholders within DOD and outside of 

DOD (e.g., the Department of 

Transportation, Congress, and local elected 

officials), and that efforts to modify the 

regulation to add a criterion that may 

increase the number of road projects that 

are eligible for funding must be balanced 

against an environment of declining 

resources. As such, the office leadership 

has elected to proceed cautiously in 

determining the best path forward to 

address the Defense Access Roads issue. 

In May 2012, DOD officials met with 

Department of Transportation officials to 

discuss next steps and how to improve 

interaction between the two departments. 

DOD further stated that given the need to 

proceed cautiously, it is likely that changes 

would not be completed until after DOD 

submits a Defense Access Roads report to 

the congressional defense committees in 

February 2013 as required by the Senate 

Appropriations Military Construction and 

Veterans Affairs subcommittee report 

(Report 112-168). 

Routinely coordinate with the Secretary of 

Transportation to meet regularly, identify all 

existing federal transportation funding 

resources, and develop a strategy for 

affording priority consideration for the use 

of those funds and other resources for the 

benefit of communities most severely 

affected by DOD. 

Partial concur. DOD stated that the 

department would continue to work closely 

with the Department of Transportation to 

assist communities affected by DOD 

actions but that the Department of 

Transportation does not have discretionary 

funds that it can use to target defenseimpacted communities, and instead, state 

and local communities must advance 

defense-related transportation projects. 

DOD action complete. In April 2011, DOD 

stated that the department will continue to 

work with Department of Transportation to 

provide technical and financial assistance 

to communities affected by DOD actions. 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 79 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

GAO-10-725R—Military Base Realignments and Closures: DOD Is Taking Steps to Mitigate Challenges but Is Not Fully 

Reporting Some Additional Costs (July 21, 2010)

Take steps to capture and appropriately 

report to Congress any BRAC-related 

implementation costs that are funded from 

outside the BRAC process. 

Concur. DOD noted that it is in the process 

of drafting new BRAC guidance that, 

among other items, will direct the services 

and defense agencies to provide a final 

accounting for all BRAC costs (both inside 

and outside of the account). 

DOD action complete. On August 5, 2010, 

the Deputy Under Secretary of Defense 

(Installations and Environment) issued a 

guidance memo to the military services and 

DOD agencies requiring all BRAC business 

plan managers to fully capture the costs 

and savings of BRAC 2005 by submitting a 

final BRAC financial display that captures 

all BRAC-related expenditures (both inside 

and outside of the BRAC account). 

GAO-10-602—Defense Infrastructure: Army Needs to Improve Its Facility Planning Systems to Better Support Installations 

Experiencing Significant Growth (June 24, 2010) 

Develop and implement guidance that 

requires the Army Criteria Tracking System 

to be updated as changes to facility design 

and criteria are made. 

Concur. DOD stated that the Army has 

already taken action to enhance the 

accuracy of its planning systems to better 

respond to changing requirements. 

DOD action complete. In May 2010, the 

Army incorporated the functionality of the 

Army Criteria Tracking System into its webbased Real Property Planning and Analysis 

System, thereby linking the two systems 

and ensuring that as one is reviewed the 

other is reviewed and as one is updated the 

other is updated. Because the Real 

Property Planning and Analysis System is 

web-based, changes can be made in real 

time. Similarly, because the Army Criteria 

Tracking System is now incorporated into 

the Real Property Planning and Analysis 

System, the Army Criteria Tracking System 

is now web-based and changes to it can be 

made in real time. 

Develop and implement policies and 

procedures for linking other systems, such 

as the Army Range Requirements Model 

and the Army Health Planning Agency’s 

system, to the Real Property Planning and 

Analysis System in order to eliminate any 

potential confusion as to the correct range 

and medical facility requirements. 

Concur. DOD stated that it plans to partly 

address our recommendation by fielding a 

comprehensive range planning tool. 

DOD action complete. The Army stated 

that, as of June 2010, the Army Range 

Requirements Model was now being used 

to generate the range requirements in the 

Real Property Planning and Analysis 

System and that because the Army Health 

Facility Planning Agency does not have an 

automated system to generate 

requirements, the Army was manually 

obtaining hospital requirements and 

inputting them into the Real Property 

Planning and Analysis System. These 

actions eliminate two sets of requirements 

for ranges and hospitals, reducing any 

potential confusion. 

 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 80 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

Develop a streamlined mechanism to 

expedite the flow of stationing information 

to installations. 

Concur. DOD stated that the Army has 

already initiated improvements in its 

process and is evaluating additional 

streamlining measures. 

DOD action complete. In January 2012, 

DOD reported that the Army continues to 

enhance the flow of stationing information. 

All unit moves are now combined by 

installation by fiscal year, significantly 

reducing the number of actions being 

processed. In August 2010, the Army staff 

issued guidance to the field (Installation 

Management Command) that clarified 

formal lines of communication and 

established protocol to differentiate 

between official and unofficial taskings, 

enabling installation commanders to focus 

on approved official actions. All 

stakeholders are better involved in the early 

stages of force structure actions, force 

design updates, concept plans, and 

leadership direction. In April 2012, DOD 

reported that a copy of the August 2010 

Army staff guidance that clarified formal 

lines of communication was provided to the 

field (Installation Management Command). 

Modify existing guidance to enhance 

communication between decision makers 

and installations so that installation facility 

planners are notified when stationing 

actions are changed. 

Concur. DOD stated that the Army has 

already initiated improvements in its 

communication process and that the 

department is evaluating additional 

measures to ensure that data integrity and 

transparency are achieved. 

DOD action complete. See above. 

GAO-10-98R—Military Base Realignments and Closures: Estimated Costs Have Increased While Savings Estimates Have 

Decreased Since Fiscal Year 2009 (Nov. 13, 2009) 

No recommendations were included in this 

report, but the report noted DOD’s 

estimated one-time costs to implement the 

2005 BRAC round increased by almost 

$2.5 billion from fiscal year 2009 to fiscal 

year 2010, bringing the total 

implementation cost estimate to $34.9 

billion. In addition, net annual recurring 

savings for fiscal year 2012 and beyond will 

have decreased by almost $94 million to 

about $3.9 billion, and BRAC savings DOD 

expects to generate over a 20-year period 

from 2006 through 2025 have declined to 

$10.9 billion in constant fiscal year 2005 

dollars. 

Concur. DOD concurred with the findings 

of our report, and stated that the report 

accurately characterizes the cost growth 

that has occurred from the fiscal year 2009 

President’s Budget to the fiscal year 2010 

President’s Budget. However, DOD noted 

that as it has stated previously, even 

though the BRAC 2005 round is costing 

more and savings are less than originally 

estimated in 2005, implementation of these 

recommendations is an important element 

of the department’s ongoing effort to 

reshape its infrastructure to respond to 

global challenges. 

N/A 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 81 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

GAO-09-703—Military Base Realignments and Closures: DOD Needs to Update Savings Estimates and Continue to Address 

Challenges in Consolidating Supply-Related Functions at Depot Maintenance Locations (July 9, 2009) 

Remove savings estimates that are not 

clearly the direct result of 2005 BRAC 

actions (including savings sometimes 

referred to as “BRAC enabled”). 

Concur. DOD stated that such savings will 

be removed from savings estimates 

reported in the August 2009 business plan 

submission. 

DOD action complete. In DOD’s 2009 

biannual Business Plan, the Defense 

Logistics Agency had removed those 

savings from its estimates. 

Update its 4-year-old data to reflect the 

most recent estimate of inventory levels 

available for consolidation. 

Concur. DOD stated that it will use the 

most recent estimate of inventory levels 

available and update the savings 

calculations for inventory reductions in its 

August 2009 business plan. 

DOD action complete. In DOD’s 2009 

biannual Business Plan, the Defense 

Logistics Agency used updated inventory 

levels in its current estimate for savings 

related to this BRAC recommendation. 

Apply current information on the timing of 

inventory consolidations (specifically, when 

they will begin and how long they will take) 

and exclude projected savings for 

consolidating Army and Marine Corps 

inventories with the Defense Logistics 

Agency. 

Concur. DOD stated that savings 

calculations for projected inventory 

reductions will reflect the current schedule 

of consolidating materiel, be updated in the 

August 2009 business plan, and show that 

no Army or Marine Corps inventory is 

available for consolidation. 

DOD action complete. In DOD’s August 

2009 biannual Business Plan, the Defense 

Logistics Agency used current information 

regarding a later timetable for inventory 

consolidations and eliminated any savings 

from the Army and Marine Corps 

inventories since there will not be any 

available to consolidate. 

Revise and finalize an approved 

methodology which implements these steps 

and can be consistently followed by all the 

services and the Defense Logistics Agency 

over time. 

Concur. DOD stated that the new 

calculations will be documented in the 

August 2009 business plan and updates 

and revisions will be incorporated and 

staffed by the end of calendar year 2009. 

DOD action complete. According to DOD, 

in 2010 and 2011, the department 

documented updates and revisions to the 

methodologies for projecting or tracking, or 

both, BRAC savings associated with the 

supply, storage, and distribution functions 

and inventories in the Cost and Savings 

Tracking Plan, which was in its second 

coordination cycle. DOD stated that the 

Cost and Savings Tracking Plan will be 

updated to reflect cost and savings 

calculation changes for other supply and 

storage recommendations. 

GAO-09-336—Defense Infrastructure: DOD Needs to Periodically Review Support Standards and Costs at Joint Bases and 

Better Inform Congress of Facility Sustainment Funding Uses (Mar. 30, 2009) 

Periodically review the installation support 

standards as experience is gained with 

delivering installation support at the joint 

bases and make adjustments, if needed, to 

ensure that each standard reflects the level 

of service necessary to meet installation 

requirements as economically as possible. 

Partial concur. DOD stated that further 

action to implement the recommendation 

was not necessary because the joint base 

memorandum of agreement template 

already requires periodic reviews to ensure 

that installation support is delivered in 

accordance with appropriate, common, 

output-level standards. 

DOD action complete. In January 2011, 

DOD stated that the department now 

reviews the standards annually on a regular 

schedule for appropriateness, applicability, 

and performance. In addition to the annual 

review, the department implemented a cost 

and performance visibility framework under 

which the joint bases report how well the 

standards are being met. DOD stated that 

the reported information can assist in 

determining whether any adjustments need 

to be made to the standards. 

 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 82 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

Periodically review administrative costs as 

joint basing is implemented to minimize any 

additional costs and prevent the loss of 

existing installation support efficiencies. 

Partial concur. DOD stated that further 

action to implement the recommendation 

was not necessary because it had already 

established a process to periodically review 

joint basing costs as part of DOD’s 

planning, program, budget and execution 

system and that the joint base 

memorandum of agreement template 

requires periodic reviews of mission and 

resource impacts. 

DOD actions not expected. 

Complete a detailed analysis of the 

estimated installation support costs from 

the initial joint bases and report the results 

of the analysis to Congress in the 

department’s documents supporting the 

administration’s annual budget submission 

or another document deemed appropriate. 

Partial concur. DOD stated that it is 

collecting estimated installation support 

cost information at the joint bases and that 

the information will be provided if Congress 

requests it. 

DOD action complete. In July 2011, DOD 

stated that it had established procedures 

for collecting installation support costs at 

the 12 joint bases and, by using a cost and 

performance visibility framework, the joint 

bases report cost and manpower annually 

6 weeks after the end of the fiscal year. 

According to DOD, the information is 

analyzed in conjunction with performance 

data reported quarterly, to get an overall 

assessment of how well the standards for 

installation support are being met and the 

costs associated with those standards. 

DOD stated that it will continue to respond 

to requests for information from Congress 

with regard to the joint basing initiative. 

Increase the attention given to facility 

sustainment spending by summarizing and 

reporting to Congress the amount of 

budgeted sustainment funds spent on other 

purposes in the department’s documents 

supporting the administration’s annual 

budget submission or another document 

deemed appropriate. 

Partial concur. DOD stated that it will 

collect and summarize the amount of 

budgeted sustainment funds spent on other 

purposes and that the information will be 

provided if Congress requests it. 

DOD action complete. In July 2011, DOD 

stated that the department was monitoring 

the budgeting and execution of facilities 

sustainment in order to determine how 

much of the funding budgeted for 

sustainment is diverted to other purposes. 

DOD also stated that the department was 

currently collecting information on the 

sustainment tasks that are deferred in a 

given year at a sampling of installations 

across DOD and that the information would 

help inform decision making with regard to 

facilities sustainment funding. Finally, DOD 

previously stated that it would provide 

Congress with information on the amount of 

budgeted sustainment funds spent on other 

purposes if Congress requests it. 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 83 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

GAO-09-217—Military Base Realignments and Closures: DOD Faces Challenges in Implementing Recommendations on Time 

and Is Not Consistently Updating Savings Estimates (Jan. 30, 2009) 

Modify the recently issued guidance on the 

status of BRAC implementation to establish 

a briefing schedule with briefings as 

frequently as OSD deems necessary to 

manage the risk that a particular 

recommendation may not meet the statutory 

deadline, but at a minimum, at 6-month 

intervals, through the rest of the BRAC 2005 

implementation period—a schedule that 

would enable DOD to continually assess 

and respond to the challenges identified by 

the services and defense agencies that 

could preclude recommendation completion 

by September 15, 2011. 

Concur. DOD noted that BRAC business 

managers have and will continue to provide 

briefings on the status of implementation 

actions associated with recommendations 

exceeding $100 million, and that these 

briefings provide a forum for BRAC 

business managers to explain their actions 

to mitigate challenges. 

DOD action complete. The Deputy Under 

Secretary of Defense (Installations and 

Environment) issued a memo in November 

2008 requiring the military services and 

defense agencies to provide the OSD 

BRAC Office status briefings. According to 

OSD, the briefings were needed to ensure 

senior leadership was apprised of 

significant issues impacting BRAC 

implementation by the statutory deadline. 

The first round of status briefings took 

place in December 2008. 

Modify the recently issued guidance on the 

status of BRAC implementation to require 

the services and defense agencies to 

provide information on possible mitigation 

measures to reduce the effects of those 

challenges. 

Concur. DOD noted that BRAC business 

managers have and will continue to provide 

briefings on the status of implementation 

actions associated with recommendations 

exceeding $100 million, and that these 

briefings provide a forum for BRAC 

business managers to explain their actions 

to mitigate challenges. 

DOD action complete. According to DOD, 

in 2009 and 2010, the department required 

business managers to identify specific 

mitigation measures for BRAC 

recommendations that have construction 

projects that are scheduled to complete 

within 3 months of the statutory deadline. 

The purpose of these mitigation measures 

is to reduce the risk of not completing 

implementation of a recommendation by 

the BRAC deadline. These mitigation 

measures are identified and monitored in a 

tracking tool to help ensure they are 

implemented and the risk is reduced. As 

appropriate, the DOD basing office 

conducts additional follow-up meetings with 

business managers for specific issues or 

follows up by means of other contacts that 

occur between the routine 6-month briefing 

intervals. This helps to ensure DOD is 

making progress and implementation of 

recommendations is on track. As part of 

this process, six recommendations were 

identified as having particular risk. DOD 

briefed these six recommendations to key 

Senate and House staff in March 2010. 

 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 84 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

Take steps to improve compliance with 

DOD’s regulation requiring updated BRAC 

savings estimates. 

Concur. The department stated that it is 

emphasizing savings updates during its 

briefings and in all future business plan 

approval documentation. 

DOD action complete. On August 5, 2010, 

the Deputy Under Secretary of Defense 

(Installations and Environment) issued a 

guidance memo to the military services and 

DOD agencies regarding BRAC 2005 Final 

Business Plans, and Other Reporting 

Requirements. Among other things, this 

guidance emphasized to the military 

services and defense agencies that it is 

imperative that the final financial displays 

for BRAC 2005 contain updated projections 

of recurring savings. 

GAO-08-665—Defense Infrastructure: High-Level Leadership Needed to Help Communities Address Challenges Caused by 

DOD-Related Growth (June 17, 2008) 

Develop and implement guidance, no later 

than the end of fiscal year 2008, that is 

consistent with DOD Directive 5410.12 for 

the timely, complete, and consistent 

dissemination of DOD planning information 

such as estimated timelines and numbers 

of personnel relocating, as well as 

demographic data such as numbers of 

school-aged children, and to update this 

information quarterly. 

Concur. Although DOD indicated it would 

continue to work with the cognizant DOD 

components to ensure compliance with the 

directive, actions taken to date have not 

resulted in the military services’ 

development and implementation of 

guidance, which we believe is necessary 

for providing more complete and consistent 

personnel relocation planning data for 

impacted communities. Moreover, DOD 

was not explicit in its comments as to what 

steps it intends to take to ensure that the 

military services have implemented such 

guidance by the end of fiscal year 2008. 

With respect to our recommended action to 

provide information updates on a quarterly 

basis, DOD indicated that not all situations 

are conducive to quarterly updates. 

DOD action complete. From January 

through March 2011, the military services 

and the head of the Defense Logistics 

Agency issued guidance for the timely, 

complete, and consistent dissemination of 

DOD planning information such as military 

and civilian personnel changes and schoolage children increases and decreases in 

accordance with DOD Directive 5410.12. 

Although DOD missed our recommendation 

deadline, issuing this guidance facilitates 

the preparation of effective plans to 

minimize the economic effects on 

communities resulting from changes in 

defense programs. 

Implement Executive Order 12788 by 

holding regular meetings of the full 

executive-level Economic Adjustment 

Committee and by serving as a 

clearinghouse of information for identifying 

expected community impacts and problems 

as well as identifying existing resources for 

providing economic assistance to 

communities affected by DOD activities. In 

addition, this information should be updated 

at least quarterly and made easily available 

to all interested stakeholders at the local, 

state, and federal levels. 

Concur. DOD stated that it will develop an 

information clearinghouse that will identify 

federal programs and resources to affected 

communities, present successful state and 

local responses, and provide the Economic 

Adjustment Committee members with a 

basis to resource their assistance 

programs. Based on DOD’s comments, it is 

unclear whether DOD, as chair of the 

Economic Adjustment Committee, intends 

to call and periodically hold meetings of the 

full executive-level committee to provide 

the high-level federal leadership that we 

believe is necessary to more effectively 

coordinate federal agency assistance to 

impacted communities. 

DOD action complete. DOD regularly 

reconvened the full executive-level Economic 

Adjustment Committee meetings from 

February 25, 2009, to September 2, 2010, 

and completed actions that met the intent of 

our recommendation by establishing a 

clearinghouse website in December 2009 to 

support states and communities undertaking 

local economic adjustment activity and 

federal agencies working to support efforts. 

By reconvening the full executive-level 

Economic Adjustment Committee and setting 

up the clearinghouse website, DOD 

increased its ability to engage other federal 

agencies at a high level to promote 

interagency and intergovernmental 

cooperation and share information on a 

continual basis. DOD activated a publicly 

accessible website in December 2008 

(www.eaclearinghouse.gov), managed by the 

Office of Economic Adjustment, containing 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 85 GAO-13-149 Military Bases 

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information such as service migration 

information, federal agency assistance 

programs, community profiles, and 

community redevelopment plans. 

GAO-08-315—Military Base Realignments and Closures: Higher Costs and Lower Savings Projected for Implementing Two 

Key Supply-Related BRAC Recommendations (Mar. 5, 2008) 

Revise its business plans to exclude all 

expected savings that are not the direct 

result of BRAC actions. 

Did not concur. DOD stated that while the 

$172 million in potential savings for 

implementing the supply, storage, and 

distribution recommendation and the $71 

million in potential savings for implementing 

the depot-level reparable recommendation 

were not directly the result of BRAC actions, 

the estimated savings were enabled by 

BRAC actions and should be attributable to 

the recommendations. According to DOD, 

enabled savings are savings initiatives that 

were enhanced in some way by the BRAC 

implementation actions (e.g., increased 

scope, more aggressively pursued, or 

moved in new directions). 

DOD actions not expected. 

Implement methodologies for periodically 

monitoring and updating net savings for the 

supply, storage, and distribution and depotlevel reparable recommendations 

throughout the implementation period. 

Such methodologies, at a minimum, should 

include: 

 clear metrics for measuring the 

magnitude of actual costs and savings, 

 a comparison of the actual costs and 

savings to the prior estimates to 

coincide with the required semiannual 

business plan updates, and 

 explanations for actual cost and 

savings variances from estimates 

presented in the business plans. 

Concur. DOD action complete. According to DOD, in 

2009, the Office of the Under Secretary of 

Defense (Acquisition, Technology and 

Logistics) established a standard DOD format 

for measuring the magnitude of actual costs 

and savings, and required DOD Components 

to submit business plans in February and 

August that compared current costs and 

savings with prior estimates, and justify any 

changes by funding category. The Defense 

Logistics Agency has since updated cost and 

savings for BRAC recommendations on a 

semiannual basis synchronized with the 

programming and budget cycles, and 

compared actual costs and savings to prior 

year estimates. The magnitude of actual 

costs and savings are collected in a relational 

database developed to compare actual costs 

and savings to prior-year estimates. The 

database has data on BRAC 

Recommendation 176, Depot Level 

Reparable Management, and BRAC 

Recommendation 177, Supply, Storage, and 

Distribution Reconfiguration. For example, in 

the February 2009 business plans for BRAC 

Recommendation 176 and BRAC 

Recommendation 177, the Defense Logistics 

Agency compared costs and savings to prior 

estimates for each funding category, and 

when there was a variance in a funding 

category, it included an explanation for the 

change in cost and savings. 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 86 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

Ensure that necessary funding to meet 

implementation milestones is reflected in all 

respective service and Defense Logistics 

Agency budget submissions for the 

remainder of the implementation period 

ending in fiscal year 2011. 

Concur. DOD action complete. According to DOD, 

the BRAC decision memorandums provide 

the resources to fully fund implementation 

during the 6-year BRAC implementation 

statutory period. Annually the DOD BRAC 

office goes through an extensive analysis 

to compare each business plan 

requirement to program funding (Program 

Review). If funding shortfalls are identified, 

the components are directed by means of a 

Program Decision Memorandum to fully 

fund. The office of the Under Secretary of 

Defense (Acquisition, Technology and 

Logistics) issued a June 22, 2007, 

memorandum directing DOD Components 

to fully fund BRAC implementation during 

the 6-year statutory period. To properly 

inform the Planning, Programming, 

Budgeting, and Execution process during 

the statutory BRAC implementation period, 

each military department and defense 

agency responsible for overseeing 

business plans, will submit updated 

business plans to the DOD BRAC office in 

February and August until completion of the 

implementation actions. The August 

submission will be used to inform the next 

Planning, Programming, Budgeting, and 

Execution cycle. The components must 

ensure that the program and budget 

submissions during the annual DOD 

Program and Budget Review incorporate all 

changes in the August business-plan 

submissions. 

GAO-08-244R—Defense Infrastructure: Realignment of Air Force Special Operations Command Units to Cannon Air Force 

Base, New Mexico (Jan. 18, 2008) 

No recommendations were included in the 

report. DOD will incur additional costs to 

establish a new mission at Cannon; 

however, these costs were not considered 

as part of the BRAC process because the 

decision to relocate Air Force Special 

Operations Command was made after the 

BRAC Commission was disestablished and 

the President’s report of the BRAC 

recommendations was sent to Congress. In 

addition, because these costs were not part 

of the BRAC process, Congress did not 

have visibility at the time of approval over 

the Cannon recommendation and its effect 

on the total costs and savings from 

implementing the BRAC 2005 

recommendations. 

N/A N/A 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 87 GAO-13-149 Military Bases 

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GAO-08-341T—Military Base Realignments and Closures: Estimated Costs Have Increased and Estimated Savings Have 

Decreased (Dec. 12, 2007) 

No recommendations were included in this 

report. We reported that DOD plans to 

spend more and save less than originally 

estimated for the 2005 BRAC round. DOD’s 

cost estimates to implement the 2005 

recommendations, as reported in its fiscal 

year 2008 BRAC budget submission, have 

increased by 48 percent, from $21 billion to 

$31 billion, for the 6-year implementation 

period. While projected costs have 

increased, projected net annual recurring 

savings have decreased about 5 percent, 

from $4.2 billion to $4.0 billion annually. As 

a result of the increases in costs and 

decreases in savings, GAO’s analysis 

shows that accumulated savings are 

projected to offset accumulated costs in 

2017 rather than 2013 as projected by the 

BRAC Commission. 

N/A N/A 

GAO-08-159—Military Base Realignments and Closures: Cost Estimates Have Increased and Are Likely to Continue to 

Evolve (Dec. 11, 2007) 

Explain, in DOD’s BRAC budget 

submission to Congress, the difference 

between annual recurring savings 

attributable to military personnel 

entitlements and annual recurring savings 

that will readily result in funds available for 

other defense priorities. 

Concur. DOD noted that military personnel 

reductions attributable to a BRAC 

recommendation as savings are as real as 

savings generated through end strength 

reductions. DOD also stated that while it 

may not reduce overall end strength, its 

reductions in military personnel for each 

recommendation at a specific location are 

real and these personnel reductions allow 

the department to reapply these military 

personnel to support new capabilities and 

improve operational efficiencies. 

DOD action complete. The fiscal year 

2009 DOD budget estimates for BRAC 

2005 included language that stated, “To the 

extent that savings generated from military 

personnel reductions at closing or 

realigning installations are immediately 

used to fund military personnel priorities, 

these resources are not available to fund 

other Defense priorities.” Such language 

was not included in the prior year (fiscal 

year 2008) budget submittal to Congress. 

OSD stated that the insertion of this 

language would provide a better 

explanation of its BRAC estimated annual 

recurring savings to Congress. 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 88 GAO-13-149 Military Bases 

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GAO-08-121R—Military Base Realignments and Closures: Transfer of Supply, Storage, and Distribution Functions from 

Military Services to Defense Logistics Agency (Oct. 26, 2007) 

No recommendations were included in this 

report. We reported that the Defense 

Logistics Agency and the services have 

taken several actions in an effort to reach 

agreement on which supply, storage, and 

distribution functions and related positions 

and inventories are to transfer to the 

Defense Logistics Agency as a result of 

implementing the 2005 BRAC supply, 

storage, and distribution recommendation. 

Although the services have reached 

agreement with the Defense Logistics 

Agency on the specific functions to be 

transferred, officials from all of the services 

have expressed concerns in four key areas 

regarding the transfers. The Defense 

Logistics Agency is developing plans to 

minimize the risk of disrupting depot 

maintenance, but it faces several 

challenges. Our analysis of the BRAC 

Commission cost and savings estimates 

and Defense Logistics Agency’s planning 

documents shows that over the fiscal year 

2006 to 2011 BRAC implementation period, 

estimated costs have increased by about 

$45 million and estimated savings have 

decreased—by about $1 billion—for 

transferring the supply, storage, and 

distribution functions and associated 

inventories from the military services’ 

industrial depots to the Defense Logistics 

Agency. 

Concur. DOD concurred in principle with 

our findings and conclusions. 

N/A 

GAO-07-1040—Military Base Realignments and Closures: Plan Needed to Monitor Challenges for Completing More Than 100 

Armed Forces Reserve Centers (Sept. 13, 2007) 

Develop a plan for routinely bringing 

together the various stakeholders as a 

group, to include the state Army National 

Guard when appropriate, to monitor for and 

develop steps to mitigate implementation 

challenges should they occur. These steps 

should include ways to monitor and 

mitigate the effects of potential challenges 

on BRAC completion time frames, project 

cost and scope, construction quality, and 

capacity of the facility to meet changing 

mission requirements. 

Partial concur. DOD believes that GAO 

overlooked the various groups, forums, or 

plans that the Army has in place to assist 

with BRAC execution and management. 

DOD stated that the Army already has a 

plan in place to bring the various 

stakeholders together; however, Army 

BRAC headquarters officials acknowledged 

that they could be more proactive in 

outreaching and communicating with the 

stakeholders on how to deal with and 

mitigate particular challenges associated 

with constructing 125 AFRCs. DOD also 

stated that the Army BRAC office will begin 

quarterly BRAC program reviews with the 

Assistant Secretary of the Army for 

Installations and Environment, which will 

DOD action complete. The Army BRAC 

Office has taken several steps to 

implement the recommendation over the 

last several years. In March 2009, the Army 

BRAC Office provided a BRAC 2005 

program updated to the Army Vice Chief of 

Staff with representation from the Army 

National Guard and Reserves. In addition, 

the Army BRAC Division Reserve 

Component Branch, the Army Reserve 

Division, and the full time Army National 

Guard and Army Reserve liaisons assigned 

to the Army BRAC Office have collaborated 

at BRAC summits in October 2009 and 

April 2010 where issues affecting U.S. 

Army Reserve Command were discussed 

with Army National Guard and Army 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 89 GAO-13-149 Military Bases 

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further provide a forum for discussing and 

vetting issues affecting the BRAC program. 

Reserve Command, presenting their 

concerns. Furthermore, the Army BRAC 

division chief discusses implementation 

issues with BRAC stakeholders including 

the Army National Guard and Reserve on a 

monthly basis. 

GAO-07-1007—Defense Infrastructure: Challenges Increase Risks for Providing Timely Infrastructure Support for Army 

Installations Expecting Substantial Personnel Growth (Sept. 13, 2007) 

Determine why there are differences 

between headquarters and gaining bases 

with respect to the number of arriving and 

departing personnel. 

Partial concur. DOD stated that the Army 

had determined the cause of the 

differences and taken corrective action by 

establishing the Army Stationing and 

Installation Plan (ASIP) as the single, 

unified source of installation planning 

population data to be used Army-wide. 

DOD action complete. In January 2007 

the Army designated the ASIP as the 

single, unified source of installation 

planning population data to be used Armywide. In May 2008, the Army issued 

guidance that helped reduce the 

differences between the populations 

reported by headquarters and the 

installations by ensuring that ASIP 

population data be used for reporting 

external to the Army and allowing 

predecisional unit moves to be used for 

internal planning. Lastly, in a memorandum 

of agreement signed in May 2009 the Army 

established the responsibilities to conduct 

an ASIP quarterly edit cycle to resolve 

discrepancies between Army official force 

structure data and “on the ground” 

situation. According to the ASIP Program 

Manager, there will always be differences 

between the data in the ASIP and what is 

available at the installation level because 

installations get predecisional information 

that is not yet in the ASIP. The actual 

moves have not yet been approved by the 

Army’s Vice Chief of Staff, but the quarterly 

ASIP edit cycle is in place to resolve 

discrepancies, which are vetted by the 

Department of the Army Headquarters 

G3/517 for review. This reconciliation 

process has resolved the problems that 

were apparent, and once the discrepancies 

are discussed, the ASIP and force structure 

documents are updated to reflect any 

necessary changes. 

 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 90 GAO-13-149 Military Bases 

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Ensure that Army headquarters and base 

officials are collaborating to agree on Army 

personnel movement plans so that base 

commanders and surrounding communities 

can effectively plan for expected growth. 

This collaboration to reach agreement 

should continue as expected personnel 

movement actions are revised over time. 

Partial concur. DOD stated that the Army 

had already taken corrective action. The 

Army stated that in May 2007 it issued 

guidance that allowed installations to plan 

for anticipated unit moves that may not be 

reflected in the ASIP and to discuss these 

plans with local communities as long as 

they are appropriately qualified as 

predecisional and subject to change. Army 

officials also stated that in June 2007, they 

would ensure that installations forward all 

population or stationing, or both, issues to 

the Department of the Army headquarters 

for resolution. 

DOD action complete. In May 2007, the 

Army issued guidance that allowed 

installations to plan for anticipated moves 

that may not be reflected in the ASIP and to 

discuss these plans with local communities 

as long as they are appropriately qualified 

as predecisional and subject to change. In 

addition, the Army issued a memorandum 

of agreement between the Office of the 

Deputy Chief of Staff G-3/5/7 in May 2009 

to close information gaps and improve 

timely reconciliation of disparate data 

between installation planners, force 

planners, and headquarters. The 

memorandum established an ASIP 

quarterly edit cycle to resolve discrepancies 

between Army official force structure data 

and the “on the ground” situation. 

According to the ASIP Program Manager at 

the time of the review, there will always be 

differences between the data in ASIP and 

what is available at the installation level 

because installations get predecisional 

information that is not yet in ASIP. The 

actual moves had not yet been approved 

by the Army’s Vice Chief of Staff but the 

quarterly ASIP edit cycle is in place to 

resolve discrepancies, which are vetted 

with the Department of the Army 

Headquarters G3/517 for review. This 

reconciliation process has resolved the 

problems that were apparent. Once the 

discrepancies are discussed, the ASIP and 

force structure documents are updated to 

reflect any necessary changes. 

GAO-07-641—Military Base Closures: Management Strategy Needed to Mitigate Challenges and Improve Communication to 

Help Ensure Timely Implementation of Air National Guard Recommendations (May 16, 2007) 

Develop a mitigation strategy to be shared 

with key stakeholders that anticipates, 

identifies, and addresses related 

implementation challenges. At a minimum, 

this strategy should include time frames for 

actions and responsibilities for each 

challenge, and facilitate the ability of Air 

National Guard headquarters officials to act 

to mitigate potential delays in interim 

milestones. 

Partial concur. DOD suggested a 

modification to the recommendation to 

clarify that the director, Air National Guard, 

is normally tasked by the Chief, National 

Guard Bureau. DOD also stated that 

mitigation plans cannot be released until 

they have been thoroughly vetted with all of 

the key stakeholders. 

DOD action complete. The National 

Guard Bureau implemented a Strategic 

Communication Plan that provides affected 

units with the information they need to 

successfully complete BRAC actions and 

develop opportunities for follow-on 

missions at BRAC-affected locations. The 

Air National Guard Strategic Planning 

process, which is based on state 

involvement at all levels of the planning 

process, is the cornerstone and allows 

states to provide input to the Air National 

Guard Strategic Plan and ensures that 

states have the necessary information to 

implement those plans. The National Guard 

Bureau Strategic Communication Plan also 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 91 GAO-13-149 Military Bases 

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incorporates Air Force communications. 

Finally, the National Guard Bureau is 

engaging in high-level communication with 

the state Adjutants General. 

Expand the Strategic Communication Plan 

to include how the Air National Guard 

headquarters will provide the affected Air 

National Guard units with the information 

needed to implement the BRAC-related 

actions. 

Partial concur. DOD stated it is incumbent 

upon the Air National Guard and all 

affected units to maximize established 

chains of leadership and communication to 

effectively manage and execute BRAC 

actions. The Director, Air National Guard, 

acknowledges that there are challenges in 

communicating with the units and that 

some unit commanders may not have the 

information that they feel they need to 

implement the BRAC recommendation and 

their new missions. 

DOD actions not expected. 

Report in the Air Force annual BRAC 

budget submission the costs and source of 

funding required to establish replacement 

missions for the Air National Guard units 

that will lose their flying missions as a result 

of BRAC 2005. 

Did not concur. DOD does not believe 

these costs are BRAC-related because 

establishment of replacement missions was 

not part of the recommendations. DOD 

stated that BRAC funds cannot be used to 

establish these missions and that the costs 

in question have been appropriately 

programmed and budgeted in the Air 

Force’s regular military construction 

account. 

DOD actions not expected. 

GAO-07-304—Military Base Closures: Projected Savings from Fleet Readiness Centers Are Likely Overstated and Actions 

Needed to Track Actual Savings and Overcome Certain Challenges (June 29, 2007)

Update the business plan for the fleet 

readiness centers (1) to reflect only savings 

that are directly related to implementing the 

recommendation, and (2) update projected 

onetime savings when data are available. 

Concur. DOD stated it considers military 

personnel reductions attributable to BRAC 

recommendations as savings that are just 

as real as savings generated through endstrength reductions. While the department 

may not reduce overall end strength, the 

reductions in military personnel for each 

recommendation at a specific location are 

real. 

DOD action complete. The Commander, 

Fleet Readiness Centers, updated the 

business plan in August 2009 to reflect 

savings directly related to the BRAC action 

to establish fleet readiness centers. The 

Navy updated projected savings directly 

related to implementing the 

recommendation, showing that overall 

savings projections of $1.151 billion from 

the August 2007 version of the business 

plan should not change since changes to 

projected savings targets in some of the six 

fleet readiness center locations that 

exceeded savings targets in some years 

were offset by the inability to meet savings 

targets at other locations or in other years. 

The Navy updated projected onetime 

savings when data became available by 

changing some savings projected in the 

2009 version of the business plan (from a 

GAO recommendation to recategorize 

approximately $25 million per year from 

recurring savings) to onetime savings. 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 92 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

Monitor implementation of the 

recommendation to determine the extent 

that savings already taken from the Navy 

budget are actually achieved. 

Concur. DOD action complete. The Navy has 

demonstrated sustained leadership 

devoted to implementing the BRAC 

recommendation for establishing fleet 

readiness centers, as evidenced by 

successive leaders who have developed 

implementation plans and completed each 

phase of implementation over time. In 

addition, the Navy’s implementation 

guidance for fleet readiness centers 

specifies that key measures include, in 

part, achieving savings targets. As such, 

the Navy’s monthly report to the fleet 

readiness center commanders includes an 

analysis of the variance between savings 

projected and those actually achieved at 

the six fleet readiness centers. These 

reports provide objective, outcome-oriented 

metrics for improving readiness and 

detailing six separate savings categories. 

Commanding Officers or Officers-in-Charge 

of specific centers are evaluated for their 

results and held accountable for achieving 

savings targets. Management tools 

developed by the implementation team for 

fleet readiness centers have supported the 

identification of additional opportunities to 

realize savings. Continuing efforts to 

monitor implementation, and develop 

mechanisms to improve performance and 

accountability have allowed the Navy to 

determine the extent to which savings 

already taken from the Navy budget for 

aircraft maintenance are actually achieved. 

GAO-07-166—Military Base Closures: Opportunities Exist to Improve Environmental Cleanup Cost Reporting and to Expedite 

Transfer of Unneeded Property (Jan. 30, 2007) 

Report all costs (Defense Environmental 

Restoration Program and non–Defense 

Environmental Restoration Program)—past 

and future—required to complete 

environmental cleanup at each BRAC 

installation and to fully explain the scope 

and limitations of all the environmental 

cleanup costs DOD reports to Congress. 

We suggest including this information in the 

annual BRAC budget justification 

documentation since it would accompany 

information Congress considers when 

making resource allocation decisions. 

Concur. DOD concurred with our basic 

recommendation; however, DOD’s 

comments reflect only a partial concurrence 

because DOD did not agree with our 

suggestion to include this information in the 

annual BRAC budget justification 

documentation. DOD stated its belief that 

this would be counterproductive and that 

Congress has prescribed the types of 

environmental information it wants 

presented in the budget documentation, 

which DOD complies with. 

DOD action complete. DOD stated that in 

October 2008, the Assistant Deputy Under 

Secretary of Defense for the Environment, 

Safety, and Occupational Health 

determined that the Annual Report to 

Congress is the appropriate and best 

format to provide Congress with cleanup 

information on the DOD BRAC 

environmental programs. The annual report 

data is updated annually, by means of the 

electronic reporting system from the DOD 

components to the Deputy Under Secretary 

of Defense for Installations and 

Environment. The 2007 annual report 

provided BRAC site cost data through fiscal 

year 2007 and the estimated cost to 

complete for fiscal year 2008. The annual 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

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report is a comprehensive document 

designed to answer the many stakeholder 

questions that have developed over the 

many years of executing BRAC cleanup. 

The cost and budget data that appear in 

the annual report are also in the annual 

budget justification submitted to Congress 

in support of the President’s Budget 

Request. The fiscal year 2007 annual 

report states that the “BRAC account 

provides funding for restoration, closurerelated compliance, and planning activities 

at closing or realigned military installations 

in the U.S. and its territories. Unlike other 

appropriations, Congress provides BRAC 

funding according to BRAC rounds and 

allows it to remain available until 

expended—there are no expiration dates 

for these funds. Over the past 10 years, 

Congress has provided $5.8 billion for 

environmental activities at BRAC 

installations. Fiscal year 2006 through 

fiscal year 2009 funding levels reflect 

funding for restoration at BRAC rounds I-IV, 

as well as BRAC 2005 installations. The 

estimated Congressional appropriation for 

BRAC environmental activities in fiscal year 

2008 is $550.6 million, and DOD is 

requesting $454.8 million for fiscal year 

2009. 

Require that the military services 

periodically report to OSD on the status 

and proposed strategy for transferring 

unneeded BRAC properties and include an 

assessment of the usefulness of all tools at 

their disposal. We suggest placing this 

information in an easily shared location, 

such as a Web site, so that each service, 

and even the local communities and private 

sector, can share and benefit from lessons 

learned. 

Concur. DOD concurred with our 

recommendation to require the military 

services to periodically report to OSD on 

the status and proposed strategy for 

transferring BRAC properties and include 

an assessment of the usefulness of all tools 

at their disposal. Although DOD did not 

comment on our suggestion to accomplish 

this through a shared Web site in order to 

maximize the lessons learned, DOD 

officials embraced the idea as something 

easily doable in comments made during our 

exit interview with the agency. 

DOD action complete. According to DOD, 

military departments are required to now 

report on the status of all excess real 

property to include the available acreages, 

and under which authority the land was 

transferred, conveyed, or otherwise 

disposed of. In June of 2011, we contacted 

the responsible OSD office and were 

provided sufficient evidence that all four of 

the military services are now (within the last 

2 years) reporting the status of excess real 

property to OSD. In addition, the DOD 

Inspector General’s written response of 

February 25, 2011, when they closed out 

the GAO recommendation stated that the 

Deputy Under Secretary of Defense 

(Installations and Environment) continually 

reviews the need for new authorities and 

changes to existing authorities. 

 
Appendix II: List of Prior GAO Reviews Related 

to BRAC 2005, Related Recommendations, and 

DOD Actions to Date 

Page 94 GAO-13-149 Military Bases 

GAO recommendation Original DOD response DOD actions 

GAO-05-785—Military Bases: Analysis of DOD’s 2005 Selection Process and Recommendations for Base Closures and 

Realignments (July 1, 2005) 

Establish mechanisms for tracking and 

periodically updating savings estimates in 

implementing individual recommendations, 

with emphasis both on savings related to 

the more traditional realignment and 

closure actions as well as those related 

more to business process reengineering. 

Concur. No written comments provided. In 

providing oral comments on a draft of this 

report, the Deputy Under Secretary of 

Defense for Installations and Environment 

concurred with our recommendation. 

DOD action complete. The Joint Action 

Scenario Team, a joint team DOD set up to 

develop and propose various joint reserve 

component recommended actions, 

incorporated GAO’s suggestions of specific 

information in its summary reports and 

supporting documentation in order to 

withstand scrutiny and provide a clear 

understanding to outside parties, including 

GAO and the military service audit 

agencies, of the process leading to the 

ultimate decisions regarding recommended 

BRAC actions. 

GAO-04-760—Military Base Closures: Assessment of DOD’s 2004 Report on the Need for a Base Realignment and Closure 

Round (May 17, 2004) 

Include in the Secretary of Defense’s May 

2005 report on recommendations for base 

closures and realignments a full discussion 

of relevant assumptions, and allowances 

made for potential future force structure 

requirements and changes, including the 

potential for future surge requirements. 

Concur. DOD action complete. The Secretary of 

Defense’s May 2005 report to the BRAC 

Commission addressed several of these 

factors. For example, the report contained 

a discussion about current and future 

national security threats the department 

considered during its deliberations. In 

addition, the report included a copy of the 

Secretary of Defense’s January 2005 

“Policy Memoranda Seven—Surge” which 

outlined five steps DOD would take to meet 

the statutory requirements to consider 

surge in the development of BRAC 

recommendations. Further, some of the 

military departments and joint cross-service 

groups discussed the steps they took to 

incorporate the possibility of future surge 

requirements during their analyses. 

Source: GAO, DOD, and GAO analysis of DOD information. 

Note: N/A = not applicable. 
Appendix III: Comments from the Department 

of Defense 

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Department of Defense 
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of Defense 

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Appendix III: Comments from the Department 

of Defense 

Page 99 GAO-13-149 Military Bases 
Appendix III: Comments from the Department 

of Defense 

Page 100 GAO-13-149 Military Bases 
Appendix IV: GAO Contact and Staff 

Acknowledgments 

Page 101 GAO-13-149 Military Bases 

Brian J. Lepore, (202) 512-4523 or leporeb@gao.gov

In addition to the contact named above, Laura Talbott, Assistant Director; 

Vijay Barnabas; John Beauchamp; Susan Ditto; Brandon Jones; Paulina 

Reaves; Greg Marchand; Charles Perdue; and John Trubey made key 

contributions to this report. 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 
Related GAO Products 

Page 102 GAO-13-149 Military Bases 

DOD Joint Bases: Management Improvements Needed to Achieve 

Greater Efficiencies. GAO-13-134. Washington, D.C.: 

November 15, 2012. 

Military Base Realignments and Closures: The National GeospatialIntelligence Agency’s Technology Center Construction Project. 

GAO-12-770R. Washington, D.C.: June 29, 2012. 

Military Base Realignments and Closures: Updated Costs and Savings 

Estimates from BRAC 2005. GAO-12-709R. Washington, D.C.: 

June 29, 2012. 

Military Base Realignments and Closures: Key Factors Contributing to 

BRAC 2005 Results. GAO-12-513T. Washington, D.C.: March 8, 2012. 

Excess Facilities: DOD Needs More Complete Information and a Strategy 

to Guide Its Future Disposal Efforts. GAO-11-814. Washington, D.C.: 

September 19, 2011. 

Military Base Realignments and Closures: Review of the Iowa and Milan 

Army Ammunition Plants. GAO-11-488R. Washington, D.C.: 

April 1, 2011. 

GAO’s 2011 High-Risk Series: An Update. GAO-11-394T. Washington, 

D.C.: February 17, 2011. 

Defense Infrastructure: High-Level Federal Interagency Coordination Is 

Warranted to Address Transportation Needs beyond the Scope of the 

Defense Access Roads Program. GAO-11-165. Washington, D.C.: 

January 26, 2011. 

Military Base Realignments and Closures: DOD Is Taking Steps to 

Mitigate Challenges but Is Not Fully Reporting Some Additional Costs. 

GAO-10-725R. Washington, D.C.: July 21, 2010. 

Defense Infrastructure: Army Needs to Improve Its Facility Planning 

Systems to Better Support Installations Experiencing Significant Growth. 

GAO-10-602. Washington, D.C.: June 24, 2010. 

Military Base Realignments and Closures: Estimated Costs Have 

Increased While Savings Estimates Have Decreased Since Fiscal Year 

2009. GAO-10-98R. Washington, D.C.: November 13, 2009. 

Related GAO Products 
Related GAO Products 

Page 103 GAO-13-149 Military Bases 

Military Base Realignments and Closures: Transportation Impact of 

Personnel Increases Will Be Significant, but Long-Term Costs Are 

Uncertain and Direct Federal Support Is Limited. GAO-09-750. 

Washington, D.C.: September 9, 2009. 

Military Base Realignments and Closures: DOD Needs to Update Savings 

Estimates and Continue to Address Challenges in Consolidating SupplyRelated Functions at Depot Maintenance Locations. GAO-09-703. 

Washington, D.C.: July 9, 2009. 

Defense Infrastructure: DOD Needs to Periodically Review Support 

Standards and Costs at Joint Bases and Better Inform Congress of 

Facility Sustainment Funding Uses. GAO-09-336. Washington, D.C.: 

March 30, 2009. 

Military Base Realignments and Closures: DOD Faces Challenges in 

Implementing Recommendations on Time and Is Not Consistently 

Updating Savings Estimates. GAO-09-217. Washington, D.C.: 

January 30, 2009. 

Military Base Realignments and Closures: Army Is Developing Plans to 

Transfer Functions from Fort Monmouth, New Jersey, to Aberdeen 

Proving Ground, Maryland, but Challenges Remain. GAO-08-1010R. 

Washington, D.C.: August 13, 2008. 

Defense Infrastructure: High-Level Leadership Needed to Help 

Communities Address Challenges Caused by DOD-Related Growth. 

GAO-08-665. Washington, D.C.: June 17, 2008. 

Defense Infrastructure: DOD Funding for Infrastructure and Road 

Improvements Surrounding Growth Installations. GAO-08-602R. 

Washington, D.C.: April 1, 2008. 

Military Base Realignments and Closures: Higher Costs and Lower 

Savings Projected for Implementing Two Key Supply-Related BRAC 

Recommendations. GAO-08-315. Washington, D.C.: March 5, 2008. 

Defense Infrastructure: Realignment of Air Force Special Operations 

Command Units to Cannon Air Force Base, New Mexico. GAO-08-244R. 

Washington, D.C.: January 18, 2008. 
Related GAO Products 

Page 104 GAO-13-149 Military Bases 

Military Base Realignments and Closures: Estimated Costs Have 

Increased and Estimated Savings Have Decreased. GAO-08-341T. 

Washington, D.C.: December 12, 2007. 

Military Base Realignments and Closures: Cost Estimates Have 

Increased and Are Likely to Continue to Evolve. GAO-08-159. 

Washington, D.C.: December 11, 2007. 

Military Base Realignments and Closures: Impact of Terminating, 

Relocating, or Outsourcing the Services of the Armed Forces Institute of 

Pathology. GAO-08-20. Washington, D.C.: November 9, 2007. 

Military Base Realignments and Closures: Transfer of Supply, Storage, 

and Distribution Functions from Military Services to Defense Logistics 

Agency. GAO-08-121R. Washington, D.C.: October 26, 2007. 

Defense Infrastructure: Challenges Increase Risks for Providing Timely 

Infrastructure Support for Army Installations Expecting Substantial 

Personnel Growth. GAO-07-1007. Washington, D.C.: 

September 13, 2007. 

Military Base Realignments and Closures: Plan Needed to Monitor 

Challenges for Completing More Than 100 Armed Forces Reserve 

Centers. GAO-07-1040. Washington, D.C.: September 13, 2007. 

Military Base Realignments and Closures: Observations Related to the 

2005 Round. GAO-07-1203R. Washington, D.C.: September 6, 2007. 

Military Base Closures: Projected Savings from Fleet Readiness Centers 

Likely Overstated and Actions Needed to Track Actual Savings and 

Overcome Certain Challenges. GAO-07-304. Washington, D.C.: 

June 29, 2007. 

Military Base Closures: Management Strategy Needed to Mitigate 

Challenges and Improve Communication to Help Ensure Timely 

Implementation of Air National Guard Recommendations. GAO-07-641. 

Washington, D.C.: May 16, 2007. 

Military Base Closures: Opportunities Exist to Improve Environmental 

Cleanup Cost Reporting and to Expedite Transfer of Unneeded Property. 

GAO-07-166. Washington, D.C.: January 30, 2007. 
Related GAO Products 

Page 105 GAO-13-149 Military Bases 

Military Bases: Observations on DOD’s 2005 Base Realignment and 

Closure Selection Process and Recommendations. GAO-05-905. 

Washington, D.C.: July 18, 2005. 

Military Bases: Analysis of DOD’s 2005 Selection Process and 

Recommendations for Base Closures and Realignments. GAO-05-785. 

Washington, D.C.: July 1, 2005. 

Military Base Closures: Observations on Prior and Current BRAC 

Rounds. GAO-05-614. Washington, D.C.: May 3, 2005. 

Military Base Closures: Assessment of DOD’s 2004 Report on the Need 

for a Base Realignment and Closure Round. GAO-04-760. Washington, 

D.C.: May 17, 2004. 

(351593)
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