Report to Congressional Requesters

United States General Accounting Office

GAO

October 2002 DEFENSE

INFRASTRUCTURE

Fire Protection at

Philadelphia Naval

Business Center Meets

Response Standards

GAO-03-20
Page i GAO-03-20 Military Bases

Letter 1

Results in Brief 1

Background 2

Most Enclaves Rely on Local Rather Than Federal Fire Protection 5

Fire Protection at the Business Center Is Similar to That Provided

Elsewhere in Philadelphia 7

Future Development Could Affect Existing Arrangement for Fire

Protection 9

Conclusions 10

Agency Comments 10

Scope and Methodology 11

Appendix I Federal Enclave at the Philadelphia Naval Business

Center 14

Appendix II Mutual Aid Agreement between the Navy and the

City of Philadelphia 17

Appendix III Comments from the Department of Defense 22

Tables

Table 1: Fire Protection Services at Federal Enclaves Created at

Closed Installations 6

Table 2: Navy Fire, EMS, and Other Calls and Mutual Aid

Responses by the Navy and the City of Philadelphia, 2000

to 2002 (as of September 4, 2002) 9

Figures

Figure 1: Map of the Enclave at the Philadelphia Naval Business

Center 14

Figure 2: Aerial Photograph of the Philadelphia Naval Business

Center 16

Contents
Page 1 GAO-03-20 Military Bases

October 29, 2002

The Honorable Solomon P. Ortiz

Ranking Minority Member

Subcommittee on Military Readiness

Committee on Armed Services

House of Representatives

The Honorable Robert A. Brady

House of Representatives

When the Department of Defense closed military installations as part of

the base realignment and closure process and transferred properties to

public and private ownership, it in some cases retained a portion of an

installation as a military enclave. During this process, legal jurisdiction

over an enclave may be transferred from the federal government to the

local government. Such a transfer may incorporate provisions for fire

protection and other services by local and state governments. Because of

your concerns about the adequacy of fire protection at the federal enclave

located on the former Naval Shipyard and Naval Station in Philadelphia,

Pennsylvania, now called the Philadelphia Naval Business Center, we

conducted this review. Our overall objectives were to determine (1) who

provides fire protection services for the Navy-retained property in

Philadelphia and how this fire protection compares with that at other

closed military bases where some property was retained by the

Department of Defense; (2) how the level of fire protection services at the

business center measures up to that provided elsewhere in the City of

Philadelphia; and (3) what the future prospects are for changing the way

fire protection is provided at the Navy’s enclave.

A federal fire-fighting service provides fire protection services at the

Navy’s enclave located at the Philadelphia Naval Business Center. This is

one of three military enclaves, formed during the base closure and

realignment process, which is still protected by federal firefighters.

Twenty-four other military enclaves were converted from federal to local

fire protection during the base closure process. The Navy retained a

federal fire-fighting force at its enclave at the Philadelphia Naval Business

Center because the Commonwealth of Pennsylvania did not respond to the

Navy’s request to change the jurisdiction of the Navy-retained land. The

Navy sought to change the jurisdiction from exclusive federal to

proprietary to provide uniform fire and police protection over the business

center and the Navy’s enclave there.

United States General Accounting Office

Washington, DC 20548

Results in Brief
Page 2 GAO-03-20 Military Bases

The level of fire protection at the Philadelphia Naval Business Center is

similar to that available elsewhere in the City of Philadelphia, but the

arrangements for providing that protection differ. If a fire occurs on

non-Navy property within the business center, both the Navy and the

Philadelphia fire departments will automatically respond to the call, with

the Navy as the first responder. However, if the fire is located on

Navy-owned property at the business center, only Navy firefighters will

automatically respond to the alarm. If they need additional fire-fighting

assistance, they must first call the city fire department, which will then

send assistance. These arrangements are the result of a mutual aid

agreement the Navy and the City of Philadelphia signed in March 2000 that

is up for renewal in March 2003. According to Navy officials, the

agreement enables the Navy to meet the Department of Defense’s and the

Navy’s fire response standards. In the 29 months since the agreement was

signed, the Navy’s fire department has requested assistance from the

Philadelphia Fire Department for one fire, but the Navy has responded to

25 fire requests at non-Navy property within the business center. Both city

and Navy fire department officials told us they have found the agreement

beneficial and they expect to renew it.

As private development at the Philadelphia Naval Business Center

continues, the fire protection arrangements are expected to be reassessed.

The Commissioner of the Philadelphia Fire Department told us that, as

development at the business center continues to increase, his office will

need to reevaluate the location of city-owned fire stations in the area

around the business center. This reevaluation could provide an

opportunity for the Commonwealth of Pennsylvania, the City of

Philadelphia, and the Navy to reassess jurisdictional issues and the need

for a separate fire department to service the Navy’s enclave.

In commenting on a draft of this report, the department concurred with

the results.

To enable the Department of Defense (DOD) to close unneeded bases and

realign others, Congress enacted base realignment and closure legislation

that instituted base closure rounds in 1988, 1991, 1993, and 1995.1

 In some

 1

 The 1988 round was completed under the Defense Authorization Amendments and Base

Closure and Realignment Act (P.L. 100-526). The last three rounds were completed under

the Defense Base Closure and Realignment Act of 1990 (P.L. 101-510).

Background
Page 3 GAO-03-20 Military Bases

cases, DOD retained some of the property and created military enclaves on

closed installations.

Generally, as part of the base closure process, DOD prefers to change the

jurisdiction of the property that it has retained from exclusive federal to

proprietary jurisdiction.2

 Under exclusive federal jurisdiction, the federal

government is responsible for providing all municipal services and

enforcing federal laws. The state and local governments do not have any

authority or obligation to provide municipal services under this type of

jurisdiction, except under mutual support agreements. Under proprietary

jurisdiction,3

 the federal government has rights—similar to a private

landowner—but also maintains its authorities and responsibilities as the

federal government. Under this type of jurisdiction, the local government

is the principal municipal police and fire authority.

Following the decision to close the installations in 1991, the Naval

Shipyard and the Naval Station in Philadelphia were officially closed in

September 1995 and January 1996, respectively. In March 2000, the Navy

transferred 1,180 acres of the property to the Philadelphia Authority for

Industrial Development, the local redevelopment authority. The Navy

retained exclusive federal jurisdiction over about 2704

 acres as a military

enclave. As a result, the Navy is responsible for providing all municipal

services, including fire protection, in this enclave. Similarly, the City of

Philadelphia and the Commonwealth of Pennsylvania maintain jurisdiction

over the 1,180 acres that were transferred. The federal government has

no jurisdiction over this land. Together, the Navy-retained and

Navy-transferred property is called the Philadelphia Naval Business

Center.

The Navy’s 270-acre enclave in Philadelphia is made up of several distinct

noncontiguous areas separated by the transferred acreage. (See app. I for

a map and an aerial photograph of the enclave.) The Navy retained 67

buildings that house more than 2,300 civilian, contractor, and military

 2

 Two other types of jurisdiction exist. Under concurrent jurisdiction, federal and local

agencies provide services and enforce both federal and local laws, respectively. Under

partial jurisdiction, the local government retains all legislative and judicial authority not

ceded to the federal government.

3

 Proprietary jurisdiction over property is also sometimes described as having a proprietary

interest in the property. We use the two interchangeably.

4

 About 162 acres are on land and 108 acres are submerged at the enclave’s reserve basin.
Page 4 GAO-03-20 Military Bases

employees. The majority of the Navy’s employees—about 1,800—work in

about 47 office buildings. The remaining 500 Navy employees work at

industrial or maintenance activities, including the Naval Foundry and

Propeller Shop; a hull, mechanical, and electrical systems test facility; and

a public works center. The enclave also includes a reserve basin that is

used as a docking area for about 38 Navy inactive ships.

In contrast, the non-Navy part of the business center includes about 45

private firms with approximately 2,500 employees. This part is being

developed by the Philadelphia Industrial Development Corporation, the

City of Philadelphia’s private economic development corporation. The

corporation is authorized by the local redevelopment authority to attract

private business to the Philadelphia Naval Business Center, a business and

industrial park that is undergoing redevelopment utilizing the 1,180

transferred acres.

The Navy facilities are protected by a federal fire service consisting of 26

personnel5

 and 2 fire engines6 located on the enclave. The Navy estimated

that the cost was $2.5 million to operate the federal fire department at the

enclave during fiscal year 2001.

The City of Philadelphia is responsible for providing fire protection

services to private development on non-Navy property at the business

center. It is also responsible for providing additional fire protection to the

Navy facilities according to a March 2000 Mutual Aid Assistance

Agreement. The agreement was signed by both Navy and City of

Philadelphia officials, and it is intended to provide additional fire

equipment and firefighters to respond to fires and other emergencies on

each other’s property at the business center. (See app. II for a copy of the

agreement.) Although not specified in the agreement, enclave command

officials and Navy and city fire department officials told us that in practice,

the Navy firefighters are first responders to all fire alarms at the business

center—on both Navy and non-Navy property. The city fire department

automatically responds to fire calls on non-Navy property at the business

center; it responds to a fire on Navy property if it is called by the Navy fire

department.

 5

 The Navy fire service is authorized 29 staff, but 3 positions are currently vacant. The

Navy’s intent is to fully staff the fire service.

6

 The Navy fire service also has a reserve engine that is not staffed.
Page 5 GAO-03-20 Military Bases

The DOD Fire and Emergency Services Program7 provides policy that

governs fire protection at military installations. The policy states that the

first arriving fire apparatus shall meet a travel time8

 of 5 minutes for

90 percent of all alarms and that the remaining apparatus shall meet a

travel time of 10 minutes for all alarms. The policy also states that the

initial response to a fire will be two engine companies and one ladder

company but that another engine company may replace the ladder

company. The number of full-time fire and emergency service personnel

and equipment needed to meet these standards at any installation may

depend on the extent to which equivalent forces are available from outside

sources. The DOD policy encourages installations to enter into reciprocal

agreements with local fire departments for mutual fire and emergency

services to meet these standards. Navy policy9

 mirrors that of DOD.

The Navy considers a number of factors, including the strategic

importance, the criticality to the overall Navy mission, the degree of fire

and life safety hazards, the value of facilities and equipment, and the

availability of outside support, in determining fire protection requirements

at each installation. Using these criteria, the federal enclave at the

business center is required to have a fully staffed on-site federal

fire-fighting force; however, some of the fire-fighting force may be satisfied

by city assets based on a mutual aid agreement.

Today, according to military service base realignment and closure

officials, federal firefighters operate at only 3 of the 27 federal enclaves

that were created at closed Navy, Army, and Air Force installations (see

table 1).

 7

 DOD Instruction 6055.6.

8

 Travel time is defined as the amount of time it takes a fire apparatus to travel from the fire

station to an emergency incident.

9

 Operations Navy Instruction 11320.23F, April 25, 2001.

Most Enclaves Rely

on Local Rather Than

Federal Fire

Protection
Page 6 GAO-03-20 Military Bases

Table 1: Fire Protection Services at Federal Enclaves Created at Closed

Installations

Number with fire protection provided by

Service

Closed installations

with federal enclaves

Federal

firefighters

Local

firefighters

Navy 3 12

Army 14 1 13

Air Force 10 1 9

Total 27a3 24

a

Other military enclaves receive fire protection from local firefighters, but they had local fire protection

services before the installation closed.

Source: DOD data.

The enclave at the former Philadelphia Naval Shipyard and Naval Station

is the only Navy enclave where a federal fire protection presence remains.

According to Navy officials, federal fire protection was retained because

the Commonwealth of Pennsylvania did not respond to the Navy’s request

in 1999 to change the jurisdictional status of the property from exclusive

federal to proprietary jurisdiction in anticipation of the Navy transferring

the ownership of excess land. In its April 1999 letter to the governor of

Pennsylvania requesting the change, the Navy stated that such a change

would provide uniform jurisdiction over the business center and the

Navy’s enclave there. In addition, Navy officials told us that the change

would mean that the City of Philadelphia would have been responsible for

providing all municipal services such as fire and police protection.

The Navy’s two other enclaves—the former Charleston, South Carolina,

and Long Beach, California, shipyards—receive fire protection services

from the local communities.10 A Navy official told us that the land at the

former Charleston and Long Beach shipyards had already been designated

as concurrent jurisdiction before they were closed, so the Navy did not

have to request a change in designation. In addition, local governments

agreed to provide fire protection to the federal enclaves at both former

shipyards.

Like the Navy, the Army retained federal firefighters at only one of its

federal enclaves. The remaining 13 Army enclaves are protected by local

community firefighters. According to an official in the Army’s Base

 10 The enclave at Charleston consists of 26 acres and 15 buildings and the enclave at Long

Beach consists of 15 acres and 4 buildings.
Page 7 GAO-03-20 Military Bases

Realignment and Closure Office, a federal fire-fighting force was retained

at the enclave created when Fort Ord, California, was closed in order to

provide fire protection for a 1,600-unit housing complex and other

community support facilities, such as a military exchange and

commissary. Before Fort Ord closed, the installation was under exclusive

federal jurisdiction, but now the enclave is under concurrent jurisdiction.

According to an Army base realignment and closure official, most of the

other 13 Army installations changed from exclusive federal to proprietary

jurisdiction.

The Air Force also retained federal firefighters at only one of its enclaves

while local firefighters provide fire protection at nine other Air Force

enclaves. According to the Air Force’s Fire Protection Program Manager, a

federal firefighter force was maintained at the enclave created when

Grissom Air Force Base, Indiana, was closed to support the substantial

flying mission that remained. Before the installation was closed, most of

the land at Grissom, which is now an Air Reserve Base, was under

exclusive federal jurisdiction, while a smaller portion was under

proprietary jurisdiction; currently, all of the property at Grissom is under

proprietary jurisdiction. The other nine Air Force enclaves are also under

proprietary jurisdiction, although five had exclusive federal jurisdiction

and two had a mix of exclusive and proprietary jurisdiction before the

installations were closed.

The level of fire protection at the business center is similar to that

available elsewhere in the City of Philadelphia, but the arrangements for

providing that protection are different. When a fire occurs on non-Navy

property within the business center, both the City of Philadelphia Fire

Department and the firefighters from the Navy’s enclave automatically

respond to the call. When a fire occurs at the Navy’s enclave at the

business center, only the Navy firefighters automatically respond to the

alarm. If they need additional fire-fighting help, they must first call the city

fire department, which will then send assistance. This mutual assistance is

part of the agreement between the Navy and the City of Philadelphia,

which Navy officials state enables them to meet DOD’s and Navy’s fire

response requirements.

Senior Philadelphia city fire department officials told us that they respond

to alarms in the city or within the city-owned parts of the business center

with a minimum of 2 engines, 2 ladders, and 19 firefighters. They noted

that none of their 61 fire stations have the full complement of equipment

and firefighters needed for the minimum response but that they rely on

Fire Protection at the

Business Center Is

Similar to That

Provided Elsewhere

in Philadelphia
Page 8 GAO-03-20 Military Bases

support from other fire stations throughout the city. Similarly, the Navy’s

fire department at the federal enclave in the business center does not

have—on its own—the full complement of equipment and firefighters

needed for a minimum response as specified in DOD and Navy policy.

However, the Navy’s fire department is able to meet DOD’s and Navy’s

standards through its agreement with the City of Philadelphia. According

to the Philadelphia Fire Commissioner, when the city responds to a

request for assistance from the Navy, the city fire department would not

necessarily respond with a ladder truck but with enough equipment and

firefighters to bring the responding assets up to the city’s minimum

standards. This is especially true when the call involves an emergency

other than a fire.

A Philadelphia Deputy Fire Commissioner estimated that the response

time for an engine company from the nearest Philadelphia city fire station

to the main gate of the business center would be just under 7 minutes and

that the response time from the nearest ladder company would be less

than 11 minutes. He also said that it would take additional time to get from

the main gate to various parts of the Navy’s enclave. According to a study

performed by the International Association of Firefighters,11 the first

Philadelphia Fire Department ladder truck would arrive at the main gate of

the business center in about 5 minutes and 55 seconds. Navy officials said

that the Philadelphia Fire Department’s response times meet the current

DOD and Navy response criteria—10 minutes for subsequent arriving

vehicles—assuming the city fire department is arriving after Navy

firefighters have already responded to the alarm.

The Navy’s fire department has responded to more than 300 calls each

year during the last 2 full years, and it is on track for responding to more

than 300 calls in 2002. These calls included fire emergencies, emergency

medical service (EMS) requests, rescues, natural gas leaks, hazardous

materials incidents, standby fueling operations, and alarms with no fire.

During this same period, Navy data indicate the enclave’s firefighters have

responded to a total of 41 fires, 16 of which were on the enclave.

From the time that the agreement was signed in March 2000 to September

2002, 29 months later, City of Philadelphia firefighters responded to one

 11 International Association of Firefighters, Philadelphia Naval Shipyard Federal Fire

Department (NAVSSES): Feasibility Study on the Use of Philadelphia City Fire

Apparatus to Comply with Department of Defense Instruction 6055.6 Fire Apparatus

Deployment Requirements (Philadelphia, Pa.: June 21, 2002).
Page 9 GAO-03-20 Military Bases

fire call on the Navy’s enclave as part of the agreement. They also

responded to 39 EMS calls and 4 other calls at the enclave during the same

period. Table 2 shows the number of fire, EMS, and other responses that

the Navy and the City of Philadelphia conducted under their mutual aid

agreement.

Table 2: Navy Fire, EMS, and Other Calls and Mutual Aid Responses by the Navy and the City of Philadelphia, 2000 to 2002

(as of September 4, 2002)

City aid to the Navy Navy aid to the city

Calendar year

Total number of Navy fire

and emergency calls Fire EMS Other Fire EMS Other

2000 320 1 16 1 7 39 23

2001 363 0 10 3 10 55 17

2002 219 0 13 0 8 56 14

Total 1 39 4 25 150 54

Source: Navy fire department on the business center.

On the other hand, during the same period, the Navy fire department

responded to 25 mutual aid fire calls on non-Navy property at the business

center. It also responded to 150 EMS and 54 other calls on non-Navy

property. Both Navy and Philadelphia city fire department officials told us

that they have found the agreement mutually beneficial and that they

expect to renew the agreement in March 2003.

According to city fire department officials, future economic development

at the business center is expected to require a reassessment of fire

protection services provided by the City of Philadelphia. Currently, about

45 private tenants with about 2,500 employees are housed in 47 buildings

located on non-Navy property. However, the development corporation

plans to add additional office space at the business center over the next

several years. For example, a 43,000-square foot building directly across

from the Navy command building is under renovation; when it is

completed in early 2003, it will provide office space for about 150 people.

In addition, the development corporation plans to provide an additional

800,000 square feet of office space over the next 8 years. According to the

Philadelphia Fire Department Commissioner, as development in the

business center continues to expand, his office is expected to reevaluate

the location of fire stations located near the business center. This

reevaluation could provide an opportunity for the Commonwealth of

Pennsylvania, the City of Philadelphia, and the Navy to reassess

Future Development

Could Affect Existing

Arrangement for Fire

Protection
Page 10 GAO-03-20 Military Bases

jurisdictional issues and the need for a separate fire department to service

the Navy’s enclave.

A recent development underscored the possibility of change in fire

protection at the business center. In August 2002, the development

corporation announced that a developer plans to build 230 private homes

on land outside the main gate of the business center. A Philadelphia

Deputy Fire Commissioner stated that the city would need to reconsider

fire protection for this area once the planned development was completed.

At the time of the transfer of excess land at the former Philadelphia Naval

Shipyard and Naval Station to the redevelopment authority, the Navy tried

unsuccessfully to change the jurisdiction of the 270-acre enclave it

retained from exclusive federal to proprietary. This jurisdictional change

would have been similar to what occurred at most other military enclaves

created during the base closure and realignment process. According to

Navy officials, such a change would have provided uniform jurisdiction

over both the non-Navy property and the Navy-owned enclave at the

business center. This change would have given the City of Philadelphia

responsibility for providing all municipal services, including fire

protection, at the business center. Instead, the jurisdiction at the

Navy-owned enclave remains exclusively federal, and the Navy spends

about $2.5 million annually to retain its fire department there. As private

development at the business center and in its immediate vicinity continues

to grow over the next few years, the business center’s fire protection

arrangements may have to be reevaluated. Philadelphia Fire Department

officials told us they recognize they will need to reevaluate the way fire

protection is provided at the business center. This reevaluation could

provide the Commonwealth of Pennsylvania, the City of Philadelphia, and

the Navy with an opportunity to reconsider the jurisdictional issues and

reassess the need for a separate Navy fire department to service the Navy’s

enclave at the business center.

In commenting on a draft of this report, the Deputy Under Secretary of

Defense (Installations and Environment) concurred with the report. DOD’s

comments are included in this report as appendix III.

Conclusions

Agency Comments
Page 11 GAO-03-20 Military Bases

We conducted our work at the Office of the Director Navy Fire and

Emergency Services and Base Closure Office, the Naval Facilities

Engineering Command in Washington, D.C., the Ship Systems Engineering

Station and the Fire Department, the Philadelphia Naval Business Center,

the Philadelphia Fire Department, and Philadelphia Industrial

Development Corporation. We also did work at the Army’s Base

Realignment and Closure office, the office of the Assistant Chief of Staff

for Installation Management, and the Air Force Base Conversion Agency.

To determine how fire protection services at the business center

compared with those at other federal enclaves created under base closure,

we reviewed the 1988, 1991, 1993, and 1995 base realignment and closure

reports and identified where DOD retained property on closed

installations. We analyzed information from the Army and Navy base

closure offices and the Air Force Base Conversion Agency on how fire

protection was provided at the retained federal property on closed

installations and on the jurisdiction at the installations prior to and after

closure. We reviewed DOD and Navy guidance regarding the staffing and

equipping of fire departments.

To determine how fire responses at the business center compared with

those elsewhere in the City of Philadelphia, we interviewed the

Commissioner and two Deputy Commissioners in the Philadelphia Fire

Department to obtain information on how city firefighters respond to fire

alarms in the City of Philadelphia and on the business center. In addition,

we interviewed the Chief and the Assistant Chiefs of the Navy fire

department to determine how Navy firefighters respond to fire alarms on

Navy and non-Navy properties within the business center and we analyzed

Navy fire department workload data. We also analyzed response time

information provided by the Navy and the Philadelphia fire departments.

Finally, we reviewed the agreement between the Navy and the City of

Philadelphia regarding fire protection at the business center.

To determine how future development of the business center would affect

how fire protection is provided, we interviewed the Commissioner and

two Deputy Commissioners in the Philadelphia Fire Department. To

obtain information on future development at the business center, we

interviewed officials from the Philadelphia Industrial Development

Corporation.

Scope and

Methodology
Page 12 GAO-03-20 Military Bases

We conducted our review from July through September 2002 in

accordance with generally accepted government auditing standards.

We are sending copies of this report to interested congressional

committees; the Secretaries of Defense, the Army, the Navy, and the Air

Force; and the Director, Office of Management and Budget. We will also

provide copies to others upon request. In addition, the report will be

available at no charge on GAO’s Web site at http://www.gao.gov.

Please contact me on (202) 512-8412 if you or your staff have any

questions regarding this report. Key contributors to this report were

Michael Kennedy, Richard Meeks, Aaron Loudon, Ken Patton, and

Nancy Benco.

Barry Holman, Director

Defense Capabilities and Management
Page 13 GAO-03-20 Military Bases
Appendix I: Federal Enclave at the

Philadelphia Naval Business Center

Page 14 GAO-03-20 Military Bases

Figure 1: Map of the Enclave at the Philadelphia Naval Business Center

Appendix I: Federal Enclave at the

Philadelphia Naval Business Center
Appendix I: Federal Enclave at the

Philadelphia Naval Business Center

Page 15 GAO-03-20 Military Bases

Source: Philadelphia Industrial Development Corporation and Navy data.
Appendix I: Federal Enclave at the

Philadelphia Naval Business Center

Page 16 GAO-03-20 Military Bases

Figure 2: Aerial Photograph of the Philadelphia Naval Business Center

Source: Navy photograph.
Appendix II: Mutual Aid Agreement between

the Navy and the City of Philadelphia

Page 17 GAO-03-20 Military Bases

Appendix II: Mutual Aid Agreement between

the Navy and the City of Philadelphia
Appendix II: Mutual Aid Agreement between

the Navy and the City of Philadelphia

Page 18 GAO-03-20 Military Bases
Appendix II: Mutual Aid Agreement between

the Navy and the City of Philadelphia

Page 19 GAO-03-20 Military Bases
Appendix II: Mutual Aid Agreement between

the Navy and the City of Philadelphia

Page 20 GAO-03-20 Military Bases
Appendix II: Mutual Aid Agreement between

the Navy and the City of Philadelphia

Page 21 GAO-03-20 Military Bases
Appendix III: Comments from the Department

of Defense

Page 22 GAO-03-20 Military Bases

Appendix III: Comments from the

Department of Defense

(350237)
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