MILITARY BASES

DOD Has Processes to 

Comply with Statutory 

Requirements for 

Closing or Realigning 

Installations 

Report Congressional Committees

June 2013

GAO-13-645

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-645, a report to 

congressional committees

June 2013

MILITARY BASES

DOD Has Processes to Comply with Statutory 

Requirements for Closing or Realigning Installations

Why GAO Did This Study

DOD may be required to meet specific 

statutory requirements before closing 

or realigning installations that are 

authorized to employ 300 or more 

DOD civilians. In light of these 

requirements, DOD has historically 

used the BRAC process for closing or 

realigning bases that are above 

statutory thresholds. However, in 

March 2012, the Deputy Under 

Secretary of Defense (Installations and 

Environment) testified that because of 

fiscal and strategic imperatives, in the 

absence of an additional BRAC round, 

DOD may be forced to use its existing 

authorities to begin to realign and close 

bases. Subsequently, the National 

Defense Authorization Act for Fiscal 

Year 2013 mandated GAO to review 

the processes that DOD uses to close 

and realign military installations outside 

of the BRAC process. This report 

describes the extent to which DOD has 

processes in place to implement 

installation closures and realignments 

within the United States, and the extent 

to which DOD has implemented 

closures and realignments outside of 

the BRAC process. 

To conduct its work, GAO examined 

DOD’s approach to implementing 

basing actions and interviewed DOD 

officials to identify how their approach 

ensures compliance with 10 U.S.C. § 

2687. 

GAO is not making any 

recommendations in this report. In 

commenting on this report DOD stated 

the report, in general, explains the 

processes it follows to comply with 

requirements for closing or realigning 

installations outside of a 

congressionally authorized BRAC 

process.

What GAO Found

The Department of Defense (DOD) and the military services have processes to 

meet statutory requirements for base closures and realignments, and use these 

processes hundreds of times each year to make basing decisions outside of the 

Base Realignment and Closure (BRAC) process. These processes provide 

guidance for all types of basing actions, including, but not limited to base 

closures and realignments. For example, basing decisions can include actions 

such as reductions in force, disestablishments, renaming a command, and other 

organization changes. Generally, each service’s basing decision process uses 

similar criteria, scope, and methodologies to determine where to locate its force 

structure, and each process is documented in established guidance. Each 

service’s process requires a series of analyses, such as analysis of capability 

and capacity, cost estimates, and environmental considerations. Additionally, 

each service basing decision process includes legal reviews and an evaluation of 

the effect on civilian personnel. According to service officials, these reviews 

provide them data to determine whether a closure or realignment is above 

thresholds established in section 2687 of Title 10, U.S. Code (hereafter 10 

U.S.C. § 2687), and therefore subject to additional evaluations and congressional 

notification. Specific statutory thresholds include:

• closure of any installation with 300 or more direct-hire DOD civilian 

authorized positions (this includes all authorized positions, regardless of 

whether they are vacant or filled); and

• realignment of any installation with 300 or more direct-hire DOD civilian 

authorized positions (vacant or filled), if the realignment will reduce the 

installation by 1,000 or more civilian positions, or 50 percent or more of the 

total civilian authorized positions.

DOD has conducted closures or realignments that have either fallen below the 

thresholds of 10 U.S.C. § 2687 or were authorized by the BRAC process, 

according to DOD officials. For example, the January 2011 disestablishment of 

Joint Forces Command was a basing decision that, according to DOD, reduced 

civilian personnel and eliminated functions at multiple installations, but did not 

require evaluations and congressional notification pursuant to 10 U.S.C. § 2687. 

Specifically, one of the installations affected by the disestablishment of Joint 

Forces Command was Naval Support Activity Norfolk, Virginia—the installation 

where Joint Forces Command was headquartered. Naval Support Activity Norfolk 

had approximately 3,200 civilian personnel at the time of the disestablishment, of 

which 1,058 (about 33 percent) were Joint Forces Command personnel. 

According to DOD, a significant number of Joint Forces Command functions and 

positions were eliminated through a reduction in force—an action that is not 

subject to 10 U.S.C. § 2687—and the remainder were part of a realignment of 

Naval Support Activity Norfolk that fell below the statutory thresholds of 1,000 

authorized civilian personnel or 50 percent of the total civilian personnel 

authorized to be employed at the installation. Officials also told us they do not 

anticipate any future closures or realignments pursuant to this statute, citing 

BRAC as the preferred method for implementing basing actions that are above 

statutory thresholds.

View GAO-13-645. For more information, 

contact Brian Lepore at (202) 512-4523 or 

leporeb@gao.gov.
Page i GAO-13-645 Military Bases

Letter 1 

Background 3

DOD Has Processes in Place for Making All Basing Decisions, 

Including Those Related to 10 U.S.C. § 2687, and Uses Them 

Hundreds of Time Per Year 7

Agency Comments and Our Evaluation 13

Appendix I 10 U.S.C. § 2687 16

Appendix II Comments from the Department of Defense 19

Appendix III GAO Contact and Staff Acknowledgments 21

Related GAO Products 22

Tables

Table 1: Key Terms Included in 10 U.S.C. § 2687 and Summary of 

DOD’s Interpretation of Terms 6

Table 2: Civilian Personnel Data Required by Each Service in 

Making Basing Decisions 8

Figure

Figure 1: Overview of Closures and Realignments Pursuant to 10 

U.S.C. § 2687 5

Contents 
Page ii GAO-13-645 Military Bases

Abbreviations

BRAC base realignment and closure

DOD Department of Defense

OSD Office of the Secretary of Defense

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Page 1 GAO-13-645 Military Bases

441 G St. N.W.

Washington, DC 20548

June 27, 2013

Congressional Committees

The military services’ decisions about where to base their force structure 

in the United States can have significant strategic, socioeconomic, and 

cost implications for the Department of Defense (DOD) and affected 

communities. In 1977, Congress passed legislation requiring DOD to 

meet specific requirements before closing or realigning installations that 

are authorized to employ a certain number of DOD civilians.1 These 

statutory requirements, found at section 2687 of title 10, U.S. Code 

(hereafter 10 U.S.C. § 2687), have, according to DOD officials, 

constrained their ability to close or realign installations exceeding the 

civilian personnel thresholds. DOD has instead used the Base 

Realignment and Closure (BRAC) process since its enactment for these 

purposes. In March 2012, the Deputy Under Secretary of Defense 

(Installations and Environment) testified that because of fiscal and 

strategic imperatives, in the absence of congressional authorization for an 

additional BRAC round, DOD may be “forced to use its existing 

authorities to begin to realign and close bases.”2 Subsequently, in the 

National Defense Authorization Act for Fiscal Year 2013,3

 

1

Pub. L. No. 95-82, § 612 (1977).

Congress 

mandated GAO to review the processes that DOD uses to make 

decisions relating to closures and realignments at military installations,

including closures and realignments occurring both above and below the 

threshold levels specified in 10 U.S.C. § 2687. This report describes the 

extent to which DOD has processes in place to implement installation 

closures and realignments within the United States, and the extent to 

which DOD has implemented closures and realignments outside of the 

BRAC process. For a copy of the full language of 10 U.S.C. § 2687, see 

appendix I.

2

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 Cong. 38 (Mar. 8, 2012) (testimony of Under 

Secretary of Defense (Installations and Environment) Dr. Dorothy Robyn).

3

Pub. L. No. 112-239, § 2712 (2013).

 
 

Page 2 GAO-13-645 Military Bases

The scope of our work was to provide a description of the processes used 

by DOD in making decisions to close or realign military installations within 

the United States (50 states, the District of Columbia, and U.S. 

territories), pursuant to 10 U.S.C. § 2687. To determine the extent to 

which DOD has processes in place for closing and realigning military 

installations outside of the BRAC process, we identified and examined 

current DOD processes for implementing basing actions.4 To determine 

whether the services’ processes include steps to ensure compliance with 

the requirements of 10 U.S.C. § 2687, we reviewed documents and 

discussed the processes with officials in the Office of the Secretary of 

Defense (OSD) and each of the services to identify when and where in 

the processes’ closures and realignments are reviewed for compliance 

with the statute. Furthermore, we met with attorneys from the Office of 

General Counsel in OSD and each of the services to discuss their 

interpretations of the statute and how these interpretations may affect 

DOD’s ability to ensure consistent compliance with 10 U.S.C. § 2687. To 

describe the extent to which each service has closed or realigned 

installations pursuant to 10 U.S.C. § 2687, we met with officials and 

reviewed data from each of the services related to all basing actions 

affecting civilian personnel during fiscal years 2009 through 2012. 

Additionally, because some requirements in 10 U.S.C. § 2687 were 

enacted as recently as January 2013, and may not yet be reflected in the 

services’ processes, for these requirements we reviewed the steps DOD 

is taking to update its processes to ensure compliance with the new 

requirements.5

We conducted this performance audit from November 2012 to June 2013 

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.

 

4

The four military services each use different terminology and definitions when describing 

their basing decision processes. For example, the Army describes its process as 

“stationing,” the Marine Corps generally uses the term “force laydown,” the Air Force uses 

the term “beddown,” and the Navy uses the terms “strategic laydown” and “strategic 

dispersal.” For the purposes of this report, we use “basing” to refer to the services’ 

processes to make decisions about where to establish locations for their force structure.

5

Pub.L. No. 112-239, § 2712 (2013).
 

Page 3 GAO-13-645 Military Bases

In the early 1960s, the Secretary of Defense, at the President’s direction, 

developed and implemented a base closure program, with minimal 

consultation with Congress. This program resulted in hundreds of base 

closures and realignments, including closure of more than 60 major 

bases. Subsequently, in 1977, Congress enacted 10 U.S.C. § 2687 to 

establish procedures that DOD must generally follow when closing or 

realigning a military installation, in the United States or its territories, 

where 500 or more civilian personnel were authorized to be employed.6 In 

1978, Congress amended the law by lowering the threshold to 300 or 

more civilian personnel.7 In the years following the passage of 10 U.S.C. 

§ 2687, DOD’s attempts to close major installations in the United States 

did not succeed. Consequently, in 1988 the Secretary of Defense 

chartered the first BRAC Commission to review and recommend bases 

for realignment and closure.8 In 1990, Congress revised the BRAC 

process, which has, as amended, governed subsequent rounds of 

realignments and closures in 1991, 1993, 1995, and 2005.9

In the absence of authorization to carry out the BRAC process, 

installation closures and realignments that are subject to the requirements 

in 10 U.S.C. § 2687 include the

Most recently, 

in its proposed budget for fiscal year 2014, DOD requested authorization 

for an additional BRAC round.

• closure of any installation with 300 or more direct-hire permanent 

DOD civilian authorized positions (this includes all authorized 

positions, regardless of whether they are vacant or filled); and

• realignment of any installation with 300 or more direct-hire permanent 

DOD civilian authorized positions (vacant or filled), if the realignment 

 

6

10 U.S.C. § 2687 applies to any military installation that is located within any of the 50 

States, the District of Columbia, the Commonwealth of Puerto Rico, American Samoa, the 

Virgin Islands, the Commonwealth of the Northern Mariana Islands, or Guam. 

7

Pub. L. No. 95-356, § 805 (1978).

8

In 1988, the Secretary of Defense chartered the first BRAC Commission, which operated 

in accordance with the processes later established by Congress in the Defense 

Authorization Amendments and Base Closure and Realignment Act of 1988, Pub. L. No. 

100-526 (1988). 

9

The 1990 statute, Pub. L. No. 101-510, Title XXIX (10 U.S.C. § 2687 note), authorized 

the 1991, 1993, and 1995 rounds. It has been amended numerous times, most 

significantly when 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). 

Background 
 

Page 4 GAO-13-645 Military Bases

will involve a reduction by (1) 1,000 or more civilian positions, or (2) 

50 percent or more of the total civilian authorized positions.10

Statutory requirements for closures or realignments exceeding these 

thresholds generally include, but are not limited to, congressional 

committee notification by the Secretary of Defense or military department 

Secretary of the proposed closure or realignment as part of its annual 

request for authorization of appropriations, and an evaluation of the fiscal, 

local economic, budgetary, environmental, strategic, and operational 

consequences of the closure or realignment. Additionally, in January 

2013, 10 U.S.C. § 2687 was amended so as to prohibit closures and 

realignments at installations with fewer than 300 authorized DOD civilian 

personnel for 5 years after the date on which a decision is made to 

reduce the civilian personnel below 300.11

 

10See table 1 for a full definition of these statutory terms, and a summary of how DOD 

interprets them.

Figure 1 provides a general 

overview of the requirements in 10 U.S.C. § 2687.

11Pub. L. No. 112-239, § 2712 (2013).
 

Page 5 GAO-13-645 Military Bases

Figure 1: Overview of Closures and Realignments Pursuant to 10 U.S.C. § 2687

Table 1 provides a summary of the definitions of key terms included in the 

statute and DOD’s interpretation of these terms.
 

Page 6 GAO-13-645 Military Bases

Table 1: Key Terms Included in 10 U.S.C. § 2687 and Summary of DOD’s Interpretation of Terms

Term Definitions provided in 10 U.S.C. § 2687 Summary of DOD’s interpretations of key terms 

Civilian Personnel Direct-hire, permanent civilian employees of the 

Department of Defense (DOD).

DOD officials we met with all agreed that temporary, 

term, or contract employees should not be counted 

towards the civilian personnel thresholds. Some 

officials we met with disagreed as to whether to 

include or exclude nonappropriated fund positions. 

Additionally, according to OSD officials any conclusion 

of the OSD General Counsel on this matter would be 

determinative.

Closure The statute does not define what constitutes a 

closure.

In the absence of a definition for the term closure, the 

Office of the Secretary of Defense (OSD) has deferred 

to the definition of closure used in the BRAC process. 

DOD and prior BRAC Commissions have defined a 

“closure” as “all missions or activities of a certain 

installation have ceased or have been relocated. All 

personnel positions will either be eliminated or 

relocated, except for personnel required for caretaking, 

conducting any ongoing environmental cleanup and 

disposal of the base, or remaining in authorized 

enclaves.” 

Realignment Any action which both reduces and relocates 

functions and civilian personnel positions, but does 

not include a reduction in force resulting from 

workload adjustments, reduced personnel or 

funding levels, skill imbalances, or other similar 

causes.

DOD officials interpret the term realignment to mean 

that authorized civilian positions are eliminated at the 

losing installation and moved during the relocation of a 

function to another installation. This may or may not 

result in an overall net loss of DOD civilian positions.

Military Installations Refers to a base, camp, post, station, yard, center, 

homeport facility for any ship, or other activity 

under the jurisdiction of DOD including any leased 

facility, which is located within any of the several 

States, the District of Columbia, the 

Commonwealth of Puerto Rico, American Samoa, 

the Virgin Islands, the Commonwealth of the 

Northern Mariana Islands, or Guam. It does not 

include any facility used primarily for civil works, 

rivers and harbors projects, or flood control 

projects. 

DOD officials agree the statutory definition of military 

installation is clear. While every discreet parcel of 

property could be viewed as a separate installation, it 

is standard practice in the military departments to 

assign smaller parcels of property, particularly leased 

property, to a nearby military installation, making that 

property part of the larger installation. 

Source: 10 U.S.C. § 2687 and GAO summary of DOD information.
 

Page 7 GAO-13-645 Military Bases

DOD and the military services have processes in place to meet statutory 

requirements for basing decisions, and according to DOD officials they 

use these processes to make hundreds of basing decisions each year 

that are not subject to 10 U.S.C. § 2687. For example, in addition to 

closures and realignments, basing decisions can include actions such as 

reductions in force, disestablishments, changes to mission statements, 

and other organization changes. According to DOD officials, since the 

1977 enactment of 10 U.S.C. § 2687, the department has not closed or 

realigned any installation pursuant to the procedures set out in 10 U.S.C. 

§ 2687. All closures or realignments since 1977 have either fallen below 

the thresholds of 10 U.S.C. § 2687 or were undertaken with a statutorily 

authorized BRAC process. They also told us they do not anticipate that 

closures or realignments pursuant to this statute will take place in the 

near future, citing BRAC as the preferred method for implementing basing 

actions that are above statutory thresholds.

Each military service has its own processes for evaluating and 

implementing basing decisions, including proposals to close or realign 

installations outside of the BRAC process.12

 

12In May 2010, we issued a report evaluating the services’ basing decision processes and 

we found that the processes used by the Army, Marine Corps, and Air Force fully 

incorporated the key elements, associated factors, and management-control standards 

that were necessary for a comprehensive process. We found that the Navy needed 

additional guidance for its processes to be complete, specifically that some of the Navy’s 

guidance lacked detailed information about specific actions taken during the process and 

defining responsibility for completing certain types of analyses. According to Navy officials, 

steps are being taken to remedy these issues, and officials expect to issue revised 

guidance in fall 2013. GAO, Defense Infrastructure: Opportunities Exist to Improve the 

Navy’s Basing Decision Process and DOD Oversight, 

Generally, the services’ 

basing decision processes use similar criteria, scope, and methodologies 

to determine where to locate the services’ force structure, and each 

process is documented in established guidance. Each service’s process 

requires a series of analyses, such as analysis of capability and capacity, 

cost estimates, and environmental considerations. For example, the 

Army’s process includes publishing a comprehensive strategy, developing 

feasible alternatives, ensuring that the documentation of alternatives 

addresses all known costs, informing interested parties of actions, and 

obtaining decisions and clearance from Army headquarters to announce 

and execute any actions. Examples of criteria used by Army planners 

when developing feasible stationing alternatives include operational 

GAO-10-482 (Washington, D.C.: 

May 11, 2010).

DOD Has Processes in 

Place for Making All 

Basing Decisions, 

Including Those 

Related to 10 U.S.C. § 

2687, and Uses Them 

Hundreds of Time Per 

Year 

DOD Has Processes in 

Place for Making Basing 

Decisions That Comply 

with 10 U.S.C. § 2687
 

Page 8 GAO-13-645 Military Bases

considerations, budget impact, facilities impact, and environmental 

impact. Similarly, the Air Force has a centralized basing process that 

includes the use of quantitative criteria in basing decisions such as 

mission imperatives, environmental effects, costs, and logistic support.

Each service’s process also provides for a review of how decisions may 

affect civilian personnel. According to service officials, this review 

provides them with data to determine whether the basing action is above 

or below 10 U.S.C. § 2687 thresholds. Table 2 describes each military 

service’s guidance and the requirements to evaluate any effect on civilian 

personnel.

Table 2: Civilian Personnel Data Required by Each Service in Making Basing Decisions

Service Guidance document Requirement to evaluate effect on civilian personnel

Air Force Air Force Instruction 10-503,Strategic Basing

Air Force Instruction 38-101, Manpower and 

Organization

Basing action requests require information on authorized 

and proposed staffing, including civilians.

Army Army Regulation 5-10, Stationing Basing actions require documentation of civilian impact, and 

the reduction in force or transfer of 50 or more civilians 

outside of the local commuting area requires additional 

actions to be taken, such as congressional notification and 

coordinating with the Civilian Human Resources Agency. 

Marine Corps Marine Corps Order 5311.1D, Total Force 

Structure Process

Basing actions include assessment to determine effects on 

civilian personnel. 

Navy Chief of Naval Operations Instruction 5400.44A, 

Navy Organization Change Manual

Basing actions require information on the effect of the action 

on civilian personnel, including the total number of civilian 

personnel and the total annual salary.

Source: GAO review of DOD documents.

In addition to the requirement to provide data on the effect on civilian 

personnel, each service’s basing decision process includes legal reviews 

of basing decisions, which, according to service officials, occur at multiple 

stages throughout the process and ensure compliance with 10 U.S.C. §

2687 as well as all other applicable laws and policies. Service attorneys 

told us that during reviews of basing actions, if compliance questions 

arise there is coordination with OSD attorneys to ensure decisions are 

consistent across the services and comply with all applicable laws. For 

example, according to officials, service and OSD attorneys are currently 

discussing how to interpret a provision added to 10 U.S.C. § 2687 in 

January 2013 that states that no action may be taken to close or realign a 

military installation within 5 years after the date on which a decision is 

made to reduce the authorized civilian personnel at that installation below 

300. On the basis of our interviews with service and OSD attorneys, there 
 

Page 9 GAO-13-645 Military Bases

are variations in how to interpret this provision. In the view of OSD and Air 

Force officials, the new provision is retrospective—that is, any closure or 

realignment occurring after January 2013 would need to be evaluated to 

determine whether a service had taken action to reduce civilian positions 

below the threshold during the previous 5 years. Conversely, Army, Navy, 

and Marine Corps officials interpret the statute as prospective—that is, if 

any installation after January 2013 reduces its civilians below 300, DOD 

is prohibited from closing or realigning that installation for the next 5 

years. At the time of our review OSD officials said that they were 

informally discussing the statute with the services as it relates to 

proposed realignments and closures; however, OSD officials stated that 

they have no immediate plans to issue clarifying guidance and stated that 

generally they play a minimal role in determining how the services 

manage their organizational needs through basing actions.13

While 10 U.S.C. § 2687 establishes congressional notification and 

waiting-period requirements that DOD must meet when implementing 

closures or certain realignments, DOD may close or realign installations 

without being subject to those requirements if the proposed action falls 

below specific thresholds. Specifically, closures and realignments that 

trigger congressional notification and waiting include any:

• closure of any installation with 300 or more direct-hire permanent 

DOD civilian authorized positions (this includes all authorized 

positions, regardless of whether they are vacant or filled); or 

• realignment of any installation with 300 or more direct-hire permanent 

DOD civilian authorized positions (vacant or filled), if the realignment 

will involve a reduction by (1) 1,000 or more civilian positions, or (2) 

50 percent or more of the total civilian authorized positions.

According to service officials, they undertake hundreds of basing actions 

each year that do not trigger the requirements in 10 U.S.C. § 2687 

because either they do not exceed the thresholds established in the 

 

13According to OSD officials, they are only involved in the implementation of basing 

actions if there is a specific reason, such as for basing actions into or within the National 

Capital Region that exceed $500,000. These actions are restricted by law unless the 

Secretary of Defense waives the restriction by certifying in writing to the congressional 

defense committees that such a relocation is required in the best interest of the 

government.

DOD Makes Hundreds of 

Basing Decisions Annually
 

Page 10 GAO-13-645 Military Bases

statute, or the action does not qualify as a realignment as defined by the 

statue. During discussions with OSD and the military services, officials 

provided some examples of recent realignments that DOD determined 

were not subject to 10 U.S.C. § 2687. Below we describe three of these 

examples, which were selected because they demonstrate typical basing 

actions that are not subject to 10 U.S.C. § 2687.

The January 2011 disestablishment of Joint Forces Command led to 

approved basing decisions that, according to DOD, reduced civilian 

personnel and eliminated functions at multiple installations, but did not 

exceed the personnel threshold of 10 U.S.C. § 2687, which would have 

triggered the congressional notification and evaluation process. For 

example, one of the installations affected by the disestablishment of Joint 

Forces Command was Naval Support Activity Norfolk, Virginia—the 

installation where Joint Forces Command was headquartered. Naval 

Support Activity Norfolk, according to DOD documents, had 

approximately 3,200 civilian personnel at the time of the disestablishment, 

of which 1,058 (about 33 percent) were Joint Forces Command 

personnel.14

The April 2012 relocation of the Army Intermodal Distribution Platform 

Management Office from the Tobyhanna Army Depot in Pennsylvania to 

the Scott Air Force Base in Illinois is another example of an approved 

basing decision that, according to DOD, did not exceed the personnel 

thresholds in 10 U.S.C. § 2687. This example demonstrates what the 

services characterize as a typical realignment. In this example, the Army 

made a decision—on the basis of an Army Audit Agency report—to 

relocate the Army Intermodal Distribution Platform Management Office 

and 14 of its authorized civilian positions from Tobyhanna Army Depot to 

Scott Air Force Base. At the time, Tobyhanna was authorized to employ 

According to DOD, a significant number of Joint Forces 

Command functions and positions were eliminated through a reduction in 

force—an action that is not subject to 10 U.S.C. § 2687—and the 

remainder were part of a realignment of Naval Support Activity Norfolk, 

which fell below the statutory thresholds of 1,000 authorized civilian 

personnel or 50 percent of the total civilian personnel authorized to be 

employed at the installation.

 

14Of the 1,058 Joint Forces Command civilian personnel, 516 were physically located 

within the Naval Support Activity Norfolk perimeter and 542 were at the Suffolk Annex, a 

leased location which, although located outside of the Naval Support Activity Norfolk 

perimeter, is considered part of Naval Support Activity Norfolk.

The Disestablishment of the 

Joint Forces Command 

The Relocation of an Army 

Office from Tobyhanna Army 

Depot to Scott Air Force Base
 

Page 11 GAO-13-645 Military Bases

over 5,000 civilian personnel, making it potentially subject to compliance 

with the procedures of 10 U.S.C. § 2687. Additionally, this action would 

both reduce and relocate functions and civilian personnel positions, 

thereby meeting the definition of realignment established in 10 U.S.C. § 

2687. However, because only 14 civilian authorizations (less than 1 

percent of the total positions at the installation) were eliminated from 

Tobyhanna as a result of this action, and therefore did not exceed the 10 

U.S.C. § 2687 threshold, the Army was not required to conduct 

evaluations and submit congressional notifications pursuant to 10 U.S.C. 

§ 2687.

The October 2011 disestablishment of the Center for Naval Engineering 

in Norfolk, Virginia, and the consolidation of its mission at the Surface 

Warfare Officers School Command in Newport, Rhode Island, is another 

example of an approved basing decision that, according to DOD, did not 

exceed the thresholds in 10 U.S.C. § 2687. This example demonstrates a 

realignment involving few authorized civilian personnel positions. As a 

result, the Navy disestablished the Center for Naval Engineering in 

Norfolk and seven civilian authorized positions were reduced. These 

authorizations accounted for less than 1 percent of the over 13,000 

authorized civilian positions at Norfolk, and therefore did not exceed the 

10 U.S.C. § 2687 threshold.

In discussing examples of basing actions, DOD officials stated that 

determining the total number of DOD civilian authorized positions at an 

installation can be challenging. Specifically, because each service 

maintains personnel data in different data systems, and because multiple 

services can be tenants at a single installation, it can be difficult to 

determine the total number of DOD authorized civilian positions. 

According to service officials, generally the service initiating the 

realignment will request the tenant organizations to provide the service 

with the total number of authorized civilian personnel located at the 

installation in question. For example, according to an OSD attorney, 

obtaining civilian personnel data for the Joint Forces Command 

disestablishment was an arduous process because the services and 

organizations within the services each have various systems and 

processes maintaining the necessary data. While collecting these data for 

Joint Forces Command was not easy, according to the OSD attorney 

responsible for reviewing the decision, she nonetheless was able to 

collect the necessary civilian personnel data to ensure compliance with 

10 U.S.C. § 2687.

Consolidation of a Navy 

Mission from Norfolk, Virginia, 

at Newport, Rhode Island 
 

Page 12 GAO-13-645 Military Bases

Further, we found that the services use caution when considering a 

basing action at an installation where the total number of personnel falls 

close to the 300-position threshold. For example, in February 2012, the 

Air Force considered a proposal to close the Air Reserve Station in 

Pittsburgh, Pennsylvania. According to an Air Force attorney, the Air 

Force determined that there were approximately 280 DOD authorized 

civilian positions at the Air Reserve Station, some of which were vacant. 

Because this number was close to the threshold established in 10 U.S.C. 

§ 2687, additional steps were taken to ensure that the proposed closure 

would comply with the law. Specifically, in addition to the total number of 

authorized civilian positions, officials also determined the number of 

civilian over-hires15

While these examples did not exceed the threshold requiring evaluations 

and congressional notification under 10 U.S.C. § 2687, DOD and the 

services have established requirements for congressional notification of 

planned basing actions. For example, the Marine Corps’ process states 

that its Office of Legislative Affairs should keep Congress advised as 

appropriate of all changes associated with reorganizations. The Army’s 

guidance provides that some members of Congress receive notice of 

approved basing actions before they are announced to the public, and in 

cases that DOD deems to be politically sensitive, members of Congress 

may be informed about a basing study that is being initiated at the time of 

the study’s initiation. Additionally, a 2011 DOD instruction requires notice 

to Congress of decisions that, among other things, include the release of 

50 or more civilian employees from federal employment during a fiscal 

year at an installation, facility, or activity; a closure or reduction in 

workforce at an installation that may be expected to be of interest to 

at the installation and included these in their count of 

authorized civilian personnel. While Air Force analysis determined that 

the overall number of authorized civilian personnel, including over-hires, 

was still fewer than 300, Air Force officials ultimately decided not to close 

the Air Reserve Station in Pittsburgh. Instead, according to officials, the 

Air Force plans on using the Air Reserve Station to house additional 

aircraft.

 

15According to Air Force officials, when funding is available, units sometimes hire 

personnel for positions not reflected on the Unit Manning Document. These positions are 

called “over-hires.” 
 

Page 13 GAO-13-645 Military Bases

members of Congress and the public; or the realignment of 50 or more 

civilian employees outside of the local commuting area.16

We provided a draft of this report to DOD for comment. In its written 

comments, reproduced in appendix II, DOD stated this report, in general, 

explains the processes it follows to comply with requirements for closing 

or realigning installations outside of a congressionally authorized BRAC 

process. DOD also provided some technical comments. In response, we 

made editorial changes to specific sections of the report for clarity.

We are sending copies of this report to the appropriate congressional 

committees; the Secretary of Defense; the Secretaries of the Army, Navy, 

and Air Force and Commandant of the Marine Corps; and the Director, 

Office of Management and Budget. In addition, the report is available at 

no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about 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. GAO staff who made key contributions to this report

are listed in appendix III.

Brian J. Lepore

Director

Defense Capabilities and Management

 

16Department of Defense, DOD Civilian Personnel Management System: Coordination 

and Clearance Requirements for Personnel Reductions, Closures of Installations and 

Reductions of Contract Operations in the United States, DOD Instruction 1400.25 (Jan. 

19, 2011).

Agency Comments

and Our Evaluation
 

Page 14 GAO-13-645 Military Bases

List of Committees

The Honorable Carl Levin

Chairman

The Honorable James M. Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Dick 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 Bill Young

Chairman

The Honorable Pete Visclosky

Ranking Member

Subcommittee on Defense

Committee on Appropriations

House of Representatives
 

Page 15 GAO-13-645 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: 10 U.S.C. § 2687

Page 16 GAO-13-645 Military Bases

(a) Notwithstanding any other provision of law, no action may be taken to 

effect or implement— 

(1) the closure of any military installation at which at least 300 civilian 

personnel are authorized to be employed;

(2) any realignment with respect to any military installation referred to 

in paragraph 

(1) involving a reduction by more than 1,000, or by more than 50 

percent, in the number of civilian personnel authorized to be 

employed at such military installation at the time the Secretary of 

Defense or the Secretary of the military department concerned notifies 

the Congress under subsection (b) of the Secretary’s plan to close or 

realign such installation; or

(3) any construction, conversion, or rehabilitation at any military facility 

other than a military installation referred to in clause (1) or (2) which 

will or may be required as a result of the relocation of civilian 

personnel to such facility by reason of any closure or realignment to 

which clause (1) or (2) applies, unless and until the provisions of 

subsection (b) are complied with.

(b) No action described in subsection (a) with respect to the closure of, or 

a realignment with respect to, any military installation referred to in such 

subsection may be taken unless and until— 

(1) the Secretary of Defense or the Secretary of the military 

department concerned notifies the Committee on Armed Services of 

the Senate and the Committee on Armed Services of the House of 

Representatives, as part of an annual request for authorization of 

appropriations to such Committees, of the proposed closing or 

realignment and submits with the notification— 

(A) an evaluation of the fiscal, local economic, budgetary, 

environmental, strategic, and operational consequences of such 

closure or realignment; and

(B) the criteria used to consider and recommend military 

installations for such closure or realignment, which shall include 

at a minimum consideration of— 

Appendix I: 10 U.S.C. § 2687
Appendix I: 10 U.S.C. § 2687

Page 17 GAO-13-645 Military Bases

(i) the ability of the infrastructure (including transportation infrastructure) 

of both the existing and receiving communities to support forces, 

missions, and personnel as a result of such closure or realignment; and

(ii) the costs associated with community transportation infrastructure 

improvements as part of the evaluation of cost savings or return on 

investment of such closure or realignment; and

(2) a period of 30 legislative days or 60 calendar days, whichever is 

longer, expires following the day on which the notice and evaluation 

referred to in clause (1) have been submitted to such committees, during 

which period no irrevocable action may be taken to effect or implement 

the decision.

(c) No action described in subsection (a) with respect to the closure of, or 

realignment with respect to, any military installation referred to in such 

subsection may be taken within five years after the date on which a 

decision is made to reduce the civilian personnel thresholds below the 

levels prescribed in such subsection.

(d)This section shall not apply to the closure of a military installation, or a 

realignment with respect to a military installation, if the President certifies 

to the Congress that such closure or realignment must be implemented 

for reasons of national security or a military emergency.

(e)(1) After the expiration of the period of time provided for in subsection 

(b)(2) with respect to the closure or realignment of a military installation, 

funds which would otherwise be available to the Secretary to effect the 

closure or realignment of that installation may be used by him for such 

purpose.

(2) Nothing in this section restricts the authority of the Secretary to 

obtain architectural and engineering services under section 2807 of this 

title.

(f) If the Secretary of Defense or the Secretary of the military department 

concerned determines, pursuant to the National Environmental Policy Act

of 1969 (42 U.S.C. 4321 et seq.), that a significant transportation impact 

will occur as a result of an action described in subsection (a), the action 

may not be taken unless and until the Secretary of Defense or the 

Secretary of the military department concerned— 
Appendix I: 10 U.S.C. § 2687

Page 18 GAO-13-645 Military Bases

(1) analyzes the adequacy of transportation infrastructure at and in 

the vicinity of each military installation that would be impacted by the 

action;

(2) concludes consultation with the Secretary of Transportation with 

regard to such impact;

(3) analyzes the impact of the action on local businesses, 

neighborhoods, and local governments; and

(4) includes in the notification required by subsection (b)(1) a 

description of how the Secretary intends to remediate the significant 

transportation impact.

(g) In this section:

(1) The term “military installation” means a base, camp, post, station, 

yard, center, homeport facility for any ship, or other activity under the 

jurisdiction of the Department of Defense, including any leased 

facility, which is located within any of the several States, the District 

of Columbia, the Commonwealth of Puerto Rico, American Samoa, 

the Virgin Islands, the Commonwealth of the Northern Mariana 

Islands, or Guam. Such term does not include any facility used 

primarily for civil works, rivers and harbors projects, or flood control 

projects.

(2) The term “civilian personnel” means direct-hire, permanent 

civilian employees of the Department of Defense.

(3) The term “realignment” includes any action which both reduces 

and relocates functions and civilian personnel positions, but does not 

include a reduction in force resulting from workload adjustments, 

reduced personnel or funding levels, skill imbalances, or other similar 

causes.

(4) The term “legislative day” means a day on which either House of 

Congress is in session.
Appendix II: Comments from the Department 

of Defense

Page 19 GAO-13-645 Military Bases

Appendix II: Comments from the Department 

of Defense
Appendix II: Comments from the Department 

of Defense

Page 20 GAO-13-645 Military Bases

Note: Page numbers in 

the draft report may differ 

from those in this report.
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 21 GAO-13-645 Military Bases

Brian J. Lepore, (202) 512-4523 or leporeb@gao.gov

In addition to the contact named above, Harold Reich (Assistant Director), 

Greg Marchand, Stephanie Moriarty, Richard Powelson, Tida Reveley, 

Kelly Rubin, and Amie Steele made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 
Related GAO Products

Page 22 GAO-13-645 Military Bases

Defense Infrastructure: DOD’s Excess Capacity Estimating Methods 

Have Limitations. GAO-13-535. Washington, D.C.: June 20, 2013.

Military Bases: Opportunities Exist to Improve Future Base Realignment 

and Closure Rounds. GAO-13-149. Washington, D.C.: March 7, 2013.

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.

Related GAO Products
Related GAO Products

Page 23 GAO-13-645 Military Bases

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.

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.
Related GAO Products

Page 24 GAO-13-645 Military Bases

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.

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 
Related GAO Products

Page 25 GAO-13-645 Military Bases

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.

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.

Military Bases: Review of DOD’s 1998 Report on Base Realignment and 

Closure. GAO/NSIAD-99-17. Washington, D.C.: November 13, 1998.

(351779)
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