GAO 

United States Government Accountability Office

Report to the Subcommittee on 

Readiness, Committee on Armed 

Services, House of Representatives 

DEFENSE 

INFRASTRUCTURE 

DOD Needs to Take 

Actions to Address 

Challenges in Meeting 

Federal Renewable 

Energy Goals 

December 2009 

GAO-10-104 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

December 2009 

DEFENSE INFRASTRUCTURE 

DOD Needs to Take Actions to Address Challenges in 

Meeting Federal Renewable Energy Goals 

Highlights of GAO-10-104, a report to the 

Subcommittee on Readiness, Committee 

on Armed Services, House of 

Representatives 

The Department of Defense (DOD) 

consumes about 60 percent of all 

energy used at federal government 

facilities. To encourage an 

increased use of energy from 

renewable sources, such as solar 

and wind power, (1) the Energy 

Policy Act of 2005 (the 2005 Act) 

directs DOD to consume at least 3 

percent of its total electricity from 

renewable resources starting in 

fiscal year 2007; (2) Executive 

Order 13423 (the 2007 Executive 

Order) directs that an amount 

equal to half of the statutorily 

required renewable energy be 

generated by sources placed into 

service in 1999 or later; and (3) the 

2007 Defense Authorization Act 

directed that at least 25 percent of 

electricity consumed by DOD come 

from renewable sources in fiscal 

year 2025. GAO was asked to 

examine (1) DOD’s progress 

toward these three key goals for 

consuming renewable energy in 

fiscal years 2007 and 2008, (2) 

challenges to DOD meeting those 

goals, and (3) DOD’s plans to meet 

the goals. GAO reviewed relevant 

laws and DOD and Department of 

Energy (DOE) policy, plans, and 

data; interviewed agency officials; 

and visited DOD facilities. 

What GAO Recommends

GAO makes 5 recommendations to 

DOD, including that DOD 

accurately report progress toward 

the goals and develop a long-term, 

DOD-wide plan to address 

challenges and meet goals. DOD 

concurred with 4 recommendations 

and partially concurred with 1, 

agreeing with its intent but stating 

that it is a service responsibility. 

DOD has three key goals for its installations’ consumption of renewable 

energy, contained in the 2005 Act, the 2007 Executive Order, and the fiscal 

year 2007 National Defense Authorization Act. DOD met the goals in the 2005 

Act and 2007 Executive Order in fiscal year 2007. However, in fiscal year 2008, 

DOD fell just short of the 2005 Act goal. Moreover, in fiscal years 2007 and 

2008, DOD overstated its progress toward the goal in the 2007 Defense 

Authorization Act, counting nonelectric renewable energy. In these 2 fiscal 

years, the 2007 Defense Authorization Act goal allowed only electric 

renewable energy to be counted. According to amendments in the fiscal year 

2010 Defense Authorization Act—which became law in October 2009—DOD is 

now able to count nonelectric renewable energy toward this goal. 

In fiscal years 2007 and 2008, when calculating progress toward the 2007 

Defense Authorization Act goal, DOD included renewable electricity produced 

on DOD land, but not consumed by DOD. According to DOD, it has “facilitated 

production,” but has not “directly consumed” this electricity. It is unclear 

whether such renewable energy should be included in the Office of the 

Secretary of Defense’s (OSD) calculations of progress toward this goal. 

Moreover, OSD has not published guidance clarifying key terms in the 

language of the goal. With such guidance specifying how the services are to 

implement this goal, DOD will have greater assurance that it can accurately 

assess progress toward the goal and accurately report on this progress to 

Congress. 

DOD faces three key challenges in meeting the renewable energy goals. First, 

renewable energy projects may sometimes be incompatible with installations’ 

need to use land for primary mission objectives. For example, wind turbines 

may conflict with aircraft operations during training. Second, renewable 

energy is often more expensive than nonrenewable energy. Therefore, using 

renewable energy can be at odds with DOD and DOE guidance that calls for 

DOD to invest in energy projects when cost-effective. In response, DOD plans 

to obtain additional funds by joining with private industry, such as local 

electric utilities, to develop renewable energy projects. Third, however, the 

use of those private sector approaches can be constrained by several factors. 

For example, energy produced by the projects may not count toward the 

renewable energy goals. By addressing these challenges, DOD would 

strengthen its ability to fully realize the potential of its renewable energy 

resources, improving its chances of meeting the goals in the most costeffective way. 

OSD has not developed a long-term, DOD-wide plan to help ensure that DOD 

meets the renewable energy goals. Such a plan that identifies and addresses 

key challenges, has strategies for coordinating the services’ renewable energy 

activities, sets realistic performance measures for achieving the goals, and 

aligns DOD resources will better enable DOD to meet the renewable energy 

goals.

View GAO-10-104 or key components.

For more information, contact Mark Gaffigan 

at (202) 512-3168 or gaffiganm@gao.gov or 

Brian Lepore at (202) 512-4523 or 

leporeb@gao.gov. 
Page i GAO-10-104 

Contents 

Letter 1

Background 4 

DOD Met the 2007 Goals, Missed a 2008 Goal, and Overstated 

Reported Progress in Both Years toward the 2007 Defense 

Authorization Act Goal 12 

DOD Faces Three Key Ongoing Challenges to Its Ability to Meet 

the Renewable Energy Goals 17 

OSD Lacks a Long-Term, Departmentwide Plan to Meet the 

Renewable Energy Goals 30 

Conclusions 34 

Recommendations for Executive Action 35 

Agency Comments and Our Evaluation 37 

Appendix I Scope and Methodology 39 

Appendix II Comments from the Department of Defense 43 

Appendix III GAO Contacts and Staff Acknowledgments 46 

Related GAO Products 47 

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 Defense Infrastructure 
United States Government Accountability Office

Washington, DC 20548 

 

December 18, 2009 

The Honorable Solomon P. Ortiz 

Chairman 

The Honorable J. Randy Forbes 

Ranking Member 

Subcommittee on Readiness 

Committee on Armed Services 

House of Representatives 

The Department of Defense (DOD) is the largest single energy consumer 

in the United States—accounting for over 60 percent of all federal 

government facilities’ energy consumption in fiscal year 2006. To put this 

in a national perspective, if DOD were a state, it would rank between the 

35th and 36th largest states, based on total electricity consumption.1

 DOD 

reported that it spent almost $4 billion on facility energy in fiscal year 

2008.2

 Over the course of many years, federal statutes and executive orders 

have set and revised a number of goals for changing the way federal 

agencies use or obtain energy. 

Existing laws and an executive order direct federal agencies to increase 

their use of renewable sources of energy such as solar and wind power. 

First, the Energy Policy Act of 2005 (the 2005 Act) directs federal 

agencies—“to the extent economically feasible and technically 

practicable”—that 3 percent of the electrical energy consumed in fiscal 

years 2007 through 2009 come from renewable energy, with this 

percentage gradually increasing to 7.5 percent annually beginning in fiscal 

year 2013.3

 The amount of electricity needed to meet the 3 percent goal in 

Defense Infrastructure

 

1

In this example, we used DOD’s total facility electricity use for fiscal year 2007. 

2

DOD divides its energy consumption into two main categories: mobility energy and 

facilities energy. We have previously reported that mobility energy is required for moving 

and sustaining DOD’s forces and weapons platforms for military operations, while facilities 

energy is consumed at fixed installations. This report focuses on facilities energy. For 

previous work on mobility energy, see GAO, Defense Management: Overarching 

Organizational Framework Needed to Guide and Oversee Energy Reduction Efforts for 

Military Operations, GAO-08-426 (Washington, D.C.: Mar. 13, 2008). 

3

Section 203 of the 2005 Act directs the President, acting through the Secretary of Energy, 

to achieve these goals on behalf of the federal government as a whole. Furthermore, 

Department of Energy (DOE) guidance implementing this statutory goal directs each 

federal agency to meet this goal. 

Page 1 GAO-10-104 
 

fiscal year 2007 would power about 79,209 homes for 1 year.4 Second, 

Executive Order 13423 (the 2007 Executive Order) directs that in each 

fiscal year, an amount of renewable energy equal to at least half of the 

statutorily required renewable energy that is consumed by a federal 

agency must come from “new renewable sources placed into service after 

January 1, 1999.”5

 Third, Section 2852 of the National Defense 

Authorization Act for Fiscal Year 2007 (the 2007 Defense Authorization 

Act) established a goal for DOD “to produce or procure” not less than 25 

percent of its total electricity consumption during fiscal year 2025 and 

each fiscal year thereafter, from renewable energy sources.6,7

 The amount 

of power needed to meet the 25 percent goal in fiscal year 2025 would 

power approximately 660,080 homes for 1 year.8

 While one of the statutes 

and the executive order also contain goals for agencies to increase their 

energy efficiency, this report focuses on goals regarding the use of 

renewable energy at federal facilities. 

 

4

This example is based on DOE information concerning the 2007 average residential 

consumption in the United States and DOD information concerning its fiscal year 2007 

facility electricity consumption. We use the example only to provide a sense of the amount 

of electricity required to meet the goal in the 2005 Act. Because the goal is calculated as a 

percentage of DOD’s annual electricity use, the actual amount of electricity that it 

represents will likely change annually, along with DOD’s electricity consumption. 

5

DOE guidance directs each federal agency to meet the goals in the 2005 Act and the 2007 

Executive Order. DOE, Office of Energy Efficiency and Renewable Energy, Renewable 

Energy Requirement Guidance for EPACT 2005 and Executive Order 13423 (Jan. 28, 

2008). 

6

Pub. L. No. 109-364, § 2852(a)(1) (2006) (codified at 10 U.S.C. § 2911). The law directed 

DOD “to produce or procure not less than 25 percent of the total quantity of electric energy 

it consumes within its facilities and in its activities during fiscal year 2025 and each fiscal 

year thereafter from renewable energy sources (as defined in section 203(b) of the Energy 

Policy Act of 2005).” As explained below, this goal was amended by the National Defense 

Authorization Act for Fiscal Year 2010, Pub. L. No. 111-84, § 2842 (2009). 

7

Although not required to do so at the time, DOD reported its progress toward achieving 

this goal in both fiscal years 2007 and 2008. However, DOD is now required to report its 

progress toward achieving this goal by the National Defense Authorization Act for Fiscal 

Year 2010, Pub. L. No. 111-84 § 332 (2009). 

8

This example is based on DOE information concerning the 2007 average residential 

consumption in the United States and DOD information concerning its fiscal year 2007 

facility electricity consumption. We use the example only to provide a sense of the amount 

of energy required to meet the goal in the 2007 Defense Authorization Act. Because the goal 

is calculated as a percentage of DOD’s annual electricity use, the actual amount of 

electricity that it represents will likely change annually, along with DOD’s electricity 

consumption. 

Page 2 GAO-10-104 Defense Infrastructure
 

This report responds to your request that we review the status of DOD’s 

progress in meeting the three key renewable energy goals. Specifically, for 

domestic installations,9

 we (1) assessed the progress DOD had made 

toward the three key goals for consuming renewable energy in fiscal years 

2007 and 2008, (2) identified the challenges that may affect DOD’s ability 

to meet the renewable energy goals, and (3) assessed DOD’s plans to meet 

the renewable energy goals. 

To determine whether DOD met the three key goals for consuming 

renewable energy in its domestic installations in fiscal years 2007 and 

2008,10 we reviewed DOD and service guidance and Department of Energy 

(DOE) guidance applicable to DOD and the services to identify the goals, 

and we compared the goals to DOD’s renewable energy consumption data 

from DOD submissions to DOE for use in DOE’s Annual Report to 

Congress on Federal Government Energy Management and Conservation 

Programs for fiscal years 2007 and 2008. To determine the reliability of 

these data, we interviewed officials at each level of data collection, 

aggregation, and review: those responsible for entering this information 

into data collection templates at the facilities level, for summarizing it and 

checking for accuracy at the headquarters level for each of the services, 

and for combining the services’ data into a total for DOD and assessing the 

accuracy of this total. We determined that these data were sufficiently 

reliable for the purpose of determining the extent to which DOD met the 

renewable energy goals. 

To identify the challenges that may affect DOD’s ability to meet the 

renewable energy goals, we reviewed key documents—such as a DOD 

assessment of installations’ potential for renewable energy development—

and interviewed officials from the Office of the Secretary of Defense 

(OSD) and the services (U.S. Army, U.S. Navy, and U.S. Air Force) who are 

responsible for managing DOD’s renewable energy efforts.11 Because DOD 

 

9

While there are DOD overseas installations that use renewable energy, this report 

addresses renewable energy use in DOD installations located in the 50 states. 

10In this report, we define “renewable energy” as energy generated from solar; wind; 

biomass; landfill gas; ocean (including tidal, wave, current, and thermal); geothermal 

(including ground source heat pumps and electric generation); municipal solid waste; or 

new hydroelectric generation capacity achieved since 1999 from increased efficiency or 

additions of new capacity at an existing hydroelectric project. 

11In this report, we define “services” as the U.S. Army, U.S. Navy, and U.S. Air Force 

because the Department of the Navy manages both the Navy’s and Marine Corps’ 

renewable energy programs. 

Page 3 GAO-10-104 Defense Infrastructure
 

told us that aggregated data on DOD’s renewable energy projects were 

unavailable, we asked OSD to collect data on the location, size, and type of 

renewable energy projects using a data collection instrument we provided. 

To determine the reliability of these data provided by OSD, we checked 

them against previously identified information about a selection of 

projects, and when we found inconsistencies, we discussed the 

inconsistencies with OSD and the services and made corrections. We also 

visited five installations to determine the practical effect of the challenges 

to meeting renewable energy goals. We selected these installations 

because they represent each of the services, have different types and sizes 

of renewable energy projects, and operate in three states. 

To assess DOD’s plans for meeting the renewable energy goals, we 

obtained and reviewed OSD and service plans to determine the extent to 

which they exhibited elements generally found in effective strategic 

planning documents. We also assessed the information systems the 

services use to track their renewable energy generation and consumption. 

Because two of the three services had not developed adequate information 

systems for monitoring or reporting their use of renewable energy, we did 

not use data from those systems to determine our findings, and we discuss 

the limitations of these systems further in our report. Our analysis of 

DOD’s renewable energy production and consumption relied on the annual 

template reports submitted to OSD and a data collection instrument we 

developed, and not on the data logged into the services’ information 

systems. In addition, we met with renewable energy experts at DOE’s 

National Laboratories, selected nongovernmental organizations, and the 

public utility commissions of the states where we also visited DOD 

installations. We conducted this performance audit from October 2008 to 

November 2009, 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. 

Background 

The U.S. Renewable 

Energy Market 

Three characteristics of the U.S. renewable energy market are key to 

understanding DOD’s renewable energy activities: (1) the generally higher 

cost of renewable energy compared with nonrenewable energy in the 

Page 4 GAO-10-104 Defense Infrastructure
 

United States; (2) renewable energy certificates; and (3) state standards, 

mandates, and financial incentives. 

According to DOE, in the United States renewable energy is generally 

more expensive than energy derived from nonrenewable sources.12 We 

have previously reported that renewable energy technologies have 

typically generated more expensive energy than nonrenewable sources 

because of renewable energy technologies’ relatively high up-front capital 

costs and the fact that they operate intermittently, which results in less 

generation for every megawatt of installed generation capacity.13 For 

example, solar energy can only be generated during daytime hours and 

wind energy can only be generated during periods of sustained wind 

activity. 

Higher Cost of Renewable 

Energy 

Federal efforts to increasingly rely on renewable energy are taking place 

within the context of a renewable energy commodities market for buying 

and selling this energy through renewable energy certificates. In the 

United States, renewable energy production essentially creates two 

products: the energy itself and an associated commodity, called a 

renewable energy certificate. Each renewable energy certificate represents 

a certain amount of energy generated using a renewable resource. 

Renewable Energy Certificates 

According to the Environmental Protection Agency, these certificates 

represent the environmental attributes of renewable energy generation 

(e.g., 1 megawatt hour of wind power) that has been produced by private 

or public entities and can be sold to other parties,14 including DOD and the 

services.15 According to DOE’s National Renewable Energy Laboratory, the 

 

12DOE, Energy Information Administration, Annual Energy Outlook 2009, DOE/EIA-0383 

(Washington, D.C., March 2009). 

13GAO, Advanced Energy Technologies: Budget Trends and Challenges for DOE’s Energy 

R&D Program, GAO-08-556T (Washington, D.C.: Mar. 5, 2008), and Advanced Energy 

Technologies: Key Challenges to Their Development and Deployment, GAO-07-550T 

(Washington, D.C.: Feb. 28, 2007). 

14A watt is the basic unit used to measure electric power. A watt-hour is equal to a watt of 

power applied for 1 hour. A kilowatt-hour is 1,000 watt-hours, and a megawatt-hour is 1,000 

kilowatt-hours. 

15According to the Environmental Protection Agency, one example of an environmental 

attribute is the avoided carbon emissions from renewable energy generation, compared to 

nonrenewable generation. The renewable energy certificate associated with a specific 

source of renewable energy generation and the reporting rights to the avoided emissions 

associated with the certificate are also considered an environmental attribute. 

Page 5 GAO-10-104 Defense Infrastructure
 

certificates provide renewable energy producers with an extra stream of 

revenue that helps to offset the higher cost of renewable energy projects.16

Bought and sold in a fashion similar to stocks and bonds, renewable 

energy certificates are a commodity with fluctuating prices. According to 

DOE’s Pacific Northwest National Laboratory, the relative instability of the 

price for renewable energy certificates is a result of fluctuations in 

demand for these certificates.17 In addition, these certificates facilitate the 

buying, selling, and trading of renewable energy without the need to 

actually transmit the electricity to each customer holding a certificate. 

However, under DOE guidance for implementing the 2005 Act goal to 

obtain 3 percent of electricity from renewable sources and the 2007 

Executive Order goal to obtain an amount equal to half of the statutorily 

required renewable energy from sources placed into service after January 

1, 1999, an agency can count renewable energy certificates toward these 

goals only if the certificate is retained by the agency, retired, or precluded 

from transfer to a third party.18 This is because, according to the DOE 

guidance for implementing these two goals, if more than one party owns 

the same certificate, the credibility of the certificates in the general market 

could be jeopardized. Thus, if the federal agency does not retain, retire, or 

preclude the transfer of the certificate, it cannot claim the renewable 

energy that certificate represents toward the 2005 Act and 2007 Executive 

Order goals. 

In order to follow this guidance, an installation or service buying 

renewable energy has two options: buy both the energy and the certificate 

or buy just the certificate. Purchasing the energy and certificate together is 

referred to as buying “bundled” renewable energy. When a purchaser buys 

only the certificate, the renewable energy associated with the certificate is 

sold to another consumer without the certificate, and is known as buying 

“unbundled” energy. For instance, at one Air Force installation we visited, 

Air Force officials explained that the owner of a photovoltaic array located 

 

16DOE, National Renewable Energy Laboratory, Emerging Markets for Renewable Energy 

Certificates: Opportunities and Challenges, NREL / TP-620-37388 (Golden, Colo., January 

2005). 

17DOE, Pacific Northwest National Laboratory, Purchasing Renewable Power for the 

Federal Sector: Basics, Barriers, and Possible Options, PNNL/16485. (Richland, Wash., 

April 2008). 

18DOE, Office of Energy Efficiency and Renewable Energy, Renewable Energy 

Requirement Guidance for EPACT 2005 and Executive Order 13423, §§ 3.2.1, 3.3.1. 

Page 6 GAO-10-104 Defense Infrastructure
 

on the installation sells the project’s certificates to the local utility and 

sells the unbundled energy to the installation. DOD often buys only the 

certificate, to avoid the cost of developing its own projects.19 Another 

reason a federal agency, such as DOD, would purchase certificates is that 

according to DOE guidance pertaining to the goals in the 2005 Act and 

2007 Executive Order, purchasing and retaining these certificates is one 

way for an agency to get credit toward meeting these two renewable 

energy goals. This allows DOD installations that do not have renewable 

resources to contribute to achieving the renewable energy goals to which 

DOD is subject. However, it is important to note that if DOD buys only the 

certificate, the department is not purchasing actual energy that it can use 

to run its installations. This means that if DOD purchases just the 

certificate, the department still needs to buy actual energy at an additional 

cost. 

For instance, a DOD installation without any renewable energy projects 

could purchase a certificate for 1 megawatt hour of renewable energy 

generated elsewhere—for example, from utility-owned wind turbines in a 

different state. According to the DOE guidance implementing the 2005 Act 

goal to obtain 3 percent of electricity from renewable sources and the 2007 

Executive Order goal to obtain an amount equal to half of the statutorily 

required renewable energy from sources placed into service after January 

1, 1999, DOD’s ownership of a renewable energy certificate is the key 

requirement if energy is to count toward either of these goals. For 

example, an agency can count energy toward the goals in the 2005 Act and 

2007 Executive Order by purchasing a certificate for 1 megawatt hour of 

renewable energy plus the actual energy (that is, by purchasing bundled 

renewable energy), by using one megawatt of renewable energy from a 

project on federal land or owned by a federal agency and retaining or 

retiring a certificate, or by purchasing just a certificate for 1 megawatt 

hour of renewable energy generated elsewhere. In each case, the key 

qualification for counting the energy toward these two goals is that DOD 

retains or retires a renewable energy certificate. However, it is important 

to note that if DOD buys only the certificate, the department is not 

 

19Although DOD purchased a substantial amount of unbundled renewable energy 

certificates in fiscal years 2007 and 2008, it is important to note that according to DOD 

data, there are 217 renewable projects located on or near DOD’s installations in the 50 

states; we discuss these projects throughout the report. In fiscal years 2007 and 2008, the 

renewable energy DOD claimed toward the goals came from each of the applicable 

categories: production of bundled renewable energy from such projects; purchases of 

bundled renewable energy; and purchases of unbundled renewable energy certificates. 

Page 7 GAO-10-104 Defense Infrastructure
 

purchasing actual energy that it can use to run its installations. This means 

that if DOD purchases just the certificate, the department still needs to 

buy actual energy at an additional cost. 

Further, for the purposes of the 2005 Act goal, a bonus equivalent to 

doubling the amount of renewable energy used or purchased is available 

for qualified renewable energy sources generating electricity on federal or 

Indian lands, when that electricity is consumed at a federal facility, and the 

renewable energy certificates are not transferred to a party outside the 

federal government.20 For example, at one Marine Corps installation we 

visited, Marine Corps officials explained that the installation consumes 

renewable electricity from a photovoltaic solar array located on-site, and 

because DOD owns the array, it also owns the certificates associated with 

the project’s renewable electricity. In this case, because the project is 

located on federal land, DOD consumes the electricity, and DOD retains 

the certificates, the department can claim the bonus, counting the project’s 

total amount of electricity twice toward the goal in the 2005 Act. However, 

if the agency is operating such a project that otherwise qualifies for the 

bonus and then transfers the renewable energy certificates to a party 

outside the federal government, the agency gives up its right to count that 

amount of renewable energy for its goal, as well as its right to claim the 

bonus. 

If an agency wishes to transfer the renewable energy certificates to a party 

outside the federal government and still count the project’s energy toward 

the goal in the 2005 Act, the agency must purchase renewable energy 

certificates from another source, effectively replacing the project’s original 

certificates that the agency transferred. For the purposes of this report, we 

call these additional certificates replacement certificates. According to 

DOD data, the department has been able to utilize this approach. For 

 

20According to the DOE guidance, this bonus equivalent is available if any of the following 

conditions are met: (1) the renewable energy is produced and used on-site at a federal 

facility; (2) the renewable energy is produced on federal lands and used at a federal facility; 

(3) the renewable energy is produced on Indian land and used at a federal facility; or (4) 

the electricity produced on-site at a federal facility is sold to a third party, but the power 

purchase contract explicitly states that the federal agency retains ownership of the related 

renewable energy certificates and nonenergy attributes, the energy buyer is precluded from 

representing that such purchased energy is “renewable” for any purpose, and all renewable 

energy and nonenergy attributes must be retained on-site. Further, nonelectric energy from 

renewable sources is not eligible for the bonus. DOE, Office of Energy Efficiency and 

Renewable Energy, Renewable Energy Requirement Guidance for EPACT 2005 and 

Executive Order 13423, § 3.4. 

Page 8 GAO-10-104 Defense Infrastructure
 

instance, in fiscal year 2008, 190,964 megawatt hours of renewable energy 

certificates purchased by DOD were eligible to be used as replacement 

certificates by the department. Because DOD had renewable energy 

projects for which it had not retained the original certificates, it was able 

to use these replacement certificates to claim 190,964 megawatt hours of 

renewable energy toward the 2005 Act goal to obtain 3 percent of 

electricity from renewable sources. 

Many states have established policies that promote renewable energy. 

Specifically, according to the Database of State Incentives for Renewables 

and Efficiency,21 as of September 2009, 

State Standards, Mandates, and 

Financial Incentives 

• 34 states and the District of Columbia have established renewable 

portfolio standards requiring or encouraging that a fixed percentage of the 

electricity consumed in the state be generated from renewable sources; 

• 40 states and the District of Columbia have established interconnection 

rules for electric utilities to connect renewable energy sources to the 

power transmission grid, which in some cases allows nonutility power 

producers to receive credit for excess generation; and 

• 48 states and the District of Columbia offer tax credits, grants, or rebates 

to stimulate the development of renewable energy projects. 

Federal law requires DOD to comply with state laws governing the 

provision of electric utility services when using appropriated dollars to 

purchase energy.22 Certain types of state laws can affect DOD renewable 

energy projects. For example, the energy manager at a Navy installation 

we visited told us that because of a fee called a departing load charge, the 

installation had decided to reduce the size of a planned solar project from 

an estimated 15 to 20 megawatts to 5 megawatts. At the time this decision 

was made, utilities in the state where this installation is located could 

charge a customer this type of fee if the customer self-generated a portion 

of its electricity, reducing the amount of electricity the customer would 

purchase from the utility. According to Public Utilities Commission 

officials in this state, fees like the departing load charge exist so that 

utilities can recoup their investment in the energy infrastructure the 

 

21This database is available at http://www.dsireusa.org and is maintained by staff at the 

North Carolina State University in partnership with the Interstate Renewable Energy 

Council, and is funded by the DOE. 

22Section 591(a) of Title 40, U.S. Code. In addition, DOD must comply with state utility 

commission rulings and electric utility franchises or service territories established under 

state statute, state regulation, or state-approved territorial agreements. 

Page 9 GAO-10-104 Defense Infrastructure
 

utilities initially built to supply 100 percent of their customers’ electricity 

demand. In the case of the Navy installation we visited, once the proposed 

solar project began operating, the installation would have purchased less 

electricity from the utility because a portion of its electricity needs would 

be satisfied by the solar project. According to Navy officials, concerns 

about the impact of the departing load charge influenced the decision to 

reduce the size of the solar project. 

Sources of Funding for 

Renewable Energy 

Projects 

DOD has funded renewable energy projects on its installations using both 

up-front appropriated dollars and various types of agreements with private 

sector entities.23 DOD primarily uses funding from two kinds of 

appropriation accounts to develop renewable energy projects. First, DOD 

uses a military construction account to pay for the Energy Conservation 

Investment Program—funding that Congress provides directly to OSD and 

that OSD, in turn, allocates to each of the services. Program funds are 

specifically directed toward energy conservation and renewable energy 

projects. Second, the services’ annual operation and maintenance 

appropriations provide funding that many installations have used to 

support small renewable energy projects.24

DOD has also joined with private sector entities, entering into various 

types of arrangements to develop renewable energy projects. Because 

these different arrangements with the private sector provide DOD with an 

alternative to using only up-front appropriations to fund renewable energy 

projects, we refer to these arrangements as alternative financing 

approaches. For the purposes of this report, we define an alternative 

financing approach as any funding arrangement other than projects in 

which total project costs are funded only through full up-front 

appropriations. DOD has entered into several different types of these 

approaches that have resulted in renewable energy projects. 

 

23In this report, we define appropriated funding as “up-front” when DOD has sufficient 

funding to pay for the full cost of the renewable energy project before a commitment is 

made for the project, instead of the funding DOD uses to make payments on capital 

borrowed through certain types of alternative financing approaches. We have previously 

reported that full up-front appropriations are the best way to maintain governmentwide 

fiscal control. See GAO, Budget Issues: Alternative Approaches to Finance Federal 

Capital, GAO-03-1011 (Washington, D.C.: Aug. 21, 2003). 

24For purposes of this report, we define “small” renewable energy projects as those under 

1,000 million British thermal units of renewable energy production per year. 

Page 10 GAO-10-104 Defense Infrastructure
 

According to DOE guidance implementing the 2005 Act goal to obtain 3 

percent of electricity from renewable sources and the 2007 Executive 

Order goal to obtain an amount equal to half of the statutorily required 

renewable energy from sources placed into service after January 1, 1999, 

as well as the 2007 Defense Authorization Act goal that 25 percent of 

electricity consumed by DOD come from renewable sources in 2025,25

DOD as a department—rather than each of the services—is responsible for 

meeting the goals. However, within DOD, the activities required to meet 

these goals are carried out by both OSD and the services. DOD Instruction 

4170.11 specifies that the Office of the Deputy Under Secretary of Defense 

(Installations and Environment) acting under the authority, direction, and 

control of the Office of the Under Secretary of Defense (Acquisition, 

Technology and Logistics) oversees the military services’ renewable 

energy activities, is responsible for implementing policies and providing 

guidance to manage installation energy resources, and is responsible for 

providing annual programming guidance and overseeing the achievement 

of the energy goals and objectives.26 The services are responsible for 

implementing OSD’s guidance to meet the goals. The services do so by 

purchasing bundled renewable energy, unbundled renewable energy 

certificates, and developing renewable energy generation projects on their 

installations. 

Roles of OSD and the 

Services in DOD’s 

Renewable Energy 

Activities 

 

25DOE, Office of Energy Efficiency and Renewable Energy, Renewable Energy 

Requirement Guidance for EPACT 2005 and Executive Order 13423, and Section 2911(e) 

of Title 10, U.S. Code. 

26DOD Instruction 4170.11, Installation Energy Management, enc. 2 § 1 (Dec. 11, 2009). 

Page 11 GAO-10-104 Defense Infrastructure
 

DOD Met the 2007 

Goals, Missed a 2008 

Goal, and Overstated 

Reported Progress in 

Both Years toward the 

2007 Defense 

Authorization Act 

Goal 

DOD Met Both Goals in 

Fiscal Year 2007 

According to DOD’s fiscal year 2007 submission for DOE’s Annual Energy 

Management Report, DOD met both of the goals regarding its installations’ 

consumption of renewable energy in fiscal year 2007. In fiscal year 2007, 

5.5 percent of DOD’s total electricity consumption was from renewable 

sources, exceeding the 2005 Act goal of obtaining 3 percent of electricity 

from renewable sources. In the same year, 3.3 percent of the renewable 

energy consumed by DOD was “new,” exceeding the 2007 Executive Order 

goal to obtain an amount equal to half of the statutorily required 

renewable energy from sources placed into service after January 1, 1999. 

DOD Narrowly Missed a 

Goal in Fiscal Year 2008 

According to DOD’s fiscal year 2008 submission for DOE’s Annual Energy 

Management Report, DOD met only one of the two applicable goals 

regarding the consumption of facility renewable energy in fiscal year 2008. 

Specifically, in fiscal year 2008, 2.9 percent of DOD’s total electricity use 

was derived from renewable sources, thus falling just short of the 2005 Act 

goal of obtaining 3 percent of electricity from renewable sources. In the 

same year, 1.8 percent of the renewable energy consumed by DOD was 

“new”—exceeding the 2007 Executive Order goal to obtain an amount 

equal to half of the statutorily required renewable energy from sources 

placed into service after January 1, 1999. 

DOD missed meeting the 2005 Act goal in fiscal year 2008 because the 

price of renewable energy certificates increased significantly from fiscal 

year 2007 to fiscal year 2008, and as a result, DOD purchased fewer of 

these certificates. In fiscal year 2007, DOD relied on unbundled renewable 

energy certificates for almost 90 percent of the renewable energy that it 

purchased. In that year, DOD purchased certificates that allowed it to 

claim credit for approximately 0.88 million megawatt hours of energy. 

However, in fiscal year 2008, the price of the certificates rose almost 185 

Page 12 GAO-10-104 Defense Infrastructure
 

percent. Responding to the increase, DOD bought substantially fewer 

renewable energy certificates that year—purchases that allowed DOD to 

claim credit for 0.32 million megawatt hours. According to an OSD official, 

that fiscal year 2008 decrease in the amount of renewable energy that DOD 

could claim caused the department to miss the 2005 Act goal of obtaining 3 

percent of electricity from renewable sources. As a result, DOD’s total 

consumption of renewable energy, including that claimed through 

renewable energy certificates, decreased, and DOD missed the 2005 Act 

goal for fiscal year 2008. 

DOD Overstated Its Fiscal 

Years 2007 and 2008 

Progress toward the 

Defense Authorization Act 

Goal for Fiscal Year 2025 

DOD’s fiscal years 2007 and 2008 progress toward the fiscal year 2025 

goal—reported in DOD’s submissions to DOE for the Annual Energy 

Management Report—was overstated because DOD counted nonelectric 

renewable energy that under the 2007 Defense Authorization Act, DOD 

should not have counted. It is important to note that the National Defense 

Authorization Act for Fiscal Year 2010 contains several amendments to the 

language defining the goal in the 2007 Defense Authorization Act that 

change the goal’s requirements.27 For example, DOD will be able to count 

nonelectric renewable energy toward the 2025 goal. However, regardless 

of changes in the goal’s requirements, DOD overstated its progress toward 

the goal in fiscal years 2007 and 2008. 

A key OSD official acknowledged that DOD incorrectly included 

nonelectric energy in its reported progress toward the 2007 Defense 

Authorization Act goal of having 25 percent of its total electricity 

consumption during fiscal year 2025 come from renewable energy sources. 

According to this official, beginning in fiscal year 2007, DOD adopted an 

internal policy goal to obtain at least 25 percent of its installations’ total 

energy from renewable resources by fiscal year 2025. Under this internal 

DOD policy, all types of renewable energy counted toward the goal. 

However, Congress incorporated a similar statutory goal into the fiscal 

year 2007 Defense Authorization Act. At that time, Congress specified that 

only renewable electricity could be counted toward this statutory goal. 

But, according to OSD and service officials, in fiscal years 2007 and 2008 

the Army, Navy, and OSD did not adapt their calculations to the act’s new 

definition of what type of renewable energy counts toward the goal, 

incorrectly adding nonelectric renewable energy to electric renewable 

energy in their calculations of progress toward the goal. 

 

27Pub L. No. 111-84, § 2842 (2009). 

Page 13 GAO-10-104 Defense Infrastructure
 

According to the 2007 Defense Authorization Act, DOD’s goal was to 

“produce or procure not less than 25 percent of the total quantity of 

electric energy it consumes within its facilities and in its activities during 

fiscal year 2025 and each fiscal year thereafter from renewable energy 

sources.”28 Previous GAO work has shown that performance measures 

should be clearly stated and the definitions of key terms should be 

consistent with the methodology used for calculating the measure.29 In 

calculating its progress toward the 2025 goal, DOD utilized an accounting 

method that includes renewable energy where DOD “facilitates the 

production, but does not directly consume the renewable energy.” 

However, OSD has not issued guidance that provides a clear explanation 

of this methodology and its legal rationale for how its accounting method 

is consistent with the language of the statute. In particular, OSD has not 

defined several key terms in the act, including “produce” and “consumes.” 

Without additional information on DOD’s accounting method,30 it is 

unclear whether renewable electricity where DOD has “facilitated 

production” on DOD land—but has not “directly consumed” such 

renewable energy—should properly be included in OSD’s calculation of 

progress toward the goal. Further, without such clarification from OSD, it 

is unclear how the services are to properly implement the 2007 Defense 

Authorization Act goal. 

OSD Has Not Issued 

Guidance to Clarify What 

Should Be Included in Its 

Calculations of Progress 

toward the 2025 Goal 

Found in the 2007 Defense 

Authorization Act 

DOD has utilized an accounting method in calculating its progress toward 

the 2007 Defense Authorization Act goal where “the Department facilitates 

the production, but does not directly consume the renewable energy.”31

Pursuant to this accounting method, in its fiscal years 2007 and 2008 

submissions for DOE’s Annual Energy Management Report, OSD reported 

DOD’s progress toward the 2007 Defense Authorization Act goal by using a 

 

28In the act, “renewable energy sources” are those resources defined as renewable in 

section 203(b) of the Energy Policy Act of 2005 (42 U.S.C. 15852(b)). As explained above, 

the 2025 goal in the 2007 Defense Authorization Act was amended by the National Defense 

Authorization Act for Fiscal Year 2010, Pub. L. No. 111-84, § 2842 (2009). 

29GAO, Agencies’ Strategic Plans Under GPRA: Key Questions to Facilitate Congressional 

Review, GAO/GGD-10.1.16 (Washington, D.C.: May 1997). 

30Because of this lack of clarity, in June 2009, we requested that DOD’s Office of General 

Counsel provide us with DOD’s legal rationale for counting renewable energy not 

consumed by DOD toward the 2007 Defense Authorization Act goal. We also asked several 

questions related to DOD’s interpretation of the act, including DOD’s definition of key 

terms and the extent to which DOD’s current methodology is consistent with the plain 

language of the act. As of December 2009, DOD had not responded. 

31DOD, Report to Congress on Renewable Energy (Washington D.C., April 2008), 4. 

Page 14 GAO-10-104 Defense Infrastructure
 

calculation that included renewable electricity from a power plant that 

uses a renewable resource on DOD land but does not supply renewable 

electricity to DOD. Specifically, OSD included the renewable electricity 

produced at one geothermal power plant located on a Navy installation 

toward the 2007 Defense Authorization Act goal, although the Navy did not 

use or purchase the renewable electricity produced at this location. Given 

that the statute stated that it shall be DOD’s goal to “produce or procure 

not less than 25 percent of the total quantity of electric energy it consumes

within its facilities and in its activities during fiscal year 2025 and each 

fiscal year thereafter from renewable energy sources” (emphasis added), 

DOD’s legal rationale for how this accounting method is consistent with 

the language of the statute is unclear. 

When DOE issued guidance on the implementation of the 2005 Act and the 

2007 Executive Order, it provided extensive information to federal 

agencies on the implementation of the goals and the definition of terms. 

Specifically, the DOE guidance provides several paragraphs as to how 

projects and purchases qualify as “consumed” electricity in order to be 

counted toward the 2005 Act requirement, and addresses the requirements 

for use of renewable energy certificates in that context.32 However, OSD 

has not issued guidance that provides a clear explanation of its 

methodology for calculating progress toward the goal contained in the 

2007 Defense Authorization Act, including an explanation of how its 

accounting method is consistent with the language of the statute. For 

example, DOD’s April 2008 report stated that DOD “produce[s]” energy 

that meets the terms of the statute when it “facilitates the production” of 

renewable energy, but the circumstances under which DOD has 

“facilitate[ed] the production” of renewable energy to such an extent as it 

may be considered “produced” by DOD, as the statute specifies, are 

unclear.33 As another example, DOD’s April 2008 report stated that DOD 

counts energy toward the 2007 Defense Authorization Act goal when it 

does not “directly consume” such energy. However, the circumstances 

under which DOD has indirectly consumed such energy are unclear, as is 

the extent to which this indirect consumption is consistent with the 

statute’s requirement to consume such energy. Because OSD has not 

 

32DOE, Office of Energy Efficiency and Renewable Energy, Renewable Energy 

Requirement Guidance for EPACT 2005 and Executive Order 13423, § 3. 

33It is unclear, for example, whether DOD would consider energy that is generated by a 

private developer on DOD land where DOD is not directly involved in the production and 

distribution of that renewable energy as “produced” by DOD. 

Page 15 GAO-10-104 Defense Infrastructure
 

provided such guidance on its method of accounting for renewable energy 

use, it is unclear whether OSD’s inclusion of renewable geothermal 

electricity that DOD neither directly produced nor “directly consumed” in 

its calculation of progress toward the goal is consistent with the act. 

Further, without such clarification from OSD, it is unclear how the 

services are to properly calculate progress toward the 2007 Defense 

Authorization Act goal. 

This lack of clarity is significant because whether electricity from this 

geothermal power plant is properly included may have a serious effect on 

how much progress OSD reports to Congress in meeting the 2007 Defense 

Authorization Act goal. Because this plant generates nearly three-fourths 

of the total domestic renewable energy produced on DOD land, by 

including the plant’s electricity as part of the total amount of electricity 

that qualifies for the 2007 Defense Authorization Act goal, OSD calculated 

that DOD achieved substantial progress toward the goal in fiscal years 

2007 and 2008. In contrast, if OSD does not include the plant’s electricity in 

its future reporting, it could likely report significantly less progress toward 

the 2007 Defense Authorization Act goal. 

Without providing a clear definition of either the key terms in the act or a 

methodology for calculating progress toward the goal, OSD cannot ensure 

that the information on its progress toward meeting the goal is consistent 

or can be compared to past years’ information. Further, in the absence of 

such clarification from OSD, it is unclear how the services are to properly 

implement the 2007 Defense Authorization Act goal. Thus, until OSD 

addresses this lack of clarity, DOD will not be able to accurately measure 

its own progress toward the goal or accurately report on its progress to 

Congress. 

Page 16 GAO-10-104 Defense Infrastructure
 

DOD Faces Three Key 

Ongoing Challenges 

to Its Ability to Meet 

the Renewable 

Energy Goals 

Development of 

Renewable Energy 

Projects Is Not Always 

Compatible with the 

Primary Mission of a DOD 

Installation 

According to a 2005 DOD study,34 renewable energy projects may 

sometimes be incompatible with installations’ needs for land use to meet 

primary mission objectives. Officials from DOD and most of the state 

public utility commissions with which we met told us that when renewable 

projects and an installation’s primary mission are in potential competition, 

it is possible to develop these projects while maintaining mission 

effectiveness. This balance has been achieved when installation officials 

have found accommodations that enable a project to be developed without 

compromising primary mission objectives. However, OSD officials have 

acknowledged that OSD has not provided guidance indicating when it is 

appropriate for installation officials to develop such accommodations. 

Thus, DOD may not be availing itself of potential opportunities for 

renewable projects on its land. 

The 2005 DOD study determined that the potential impact of a project on 

an installation’s mission reduces DOD’s ability to fully utilize all of the 

renewable resources on its installations. According to data included in the 

study’s implementation plan, while DOD had the potential to annually 

obtain enough renewable energy to equal 20 percent of DOD’s total facility 

electricity use,35 the incompatibility between renewable energy projects 

and the primary mission of some installations would likely prevent DOD 

from fully realizing this potential. Officials at four of the five installations 

we visited explained that they had decided not to encroach on the land 

used for core mission activities in order to meet the renewable energy 

goals. For example, a Marine Corps installation we visited conducted an 

 

34DOD, Report to Congress: DOD Renewable Energy Assessment Final Report 

(Washington, D.C., Mar. 14, 2005). 

35This calculation was performed using the amount of electricity consumed by DOD 

installations in fiscal year 2006. The scope of the DOD study included generation of 

renewable energy on installations, generation of renewable energy on land near 

installations, and purchases of renewable energy. 

Page 17 GAO-10-104 Defense Infrastructure
 

assessment of wind resources that determined there were sufficient 

prevailing winds to install wind turbines to generate electricity. However, 

the location of this resource was designated for training activities 

involving rotary-wing aircraft and live-fire exercises—activities that 

installation officials determined to be incompatible with the siting and 

operation of wind turbines. DOD may also identify renewable energy 

projects outside its installations as incompatible with the installations’ 

primary mission objectives. For example, an Air Force installation 

commander requested that the Department of the Interior’s Bureau of 

Land Management withdraw permits for a planned solar thermal plant 20 

miles from the installation. The request noted that the tower required for 

the solar thermal plant would hamper installation operations, including 

the operation of military radar. 

In addition, the transmission and distribution infrastructure required to 

convey power from renewable energy projects to an installation’s 

buildings or to the utility grid can sometimes be affected by an 

installation’s mission. For example, officials at a Navy installation we 

visited told us that they were planning to install a solar photovoltaic 

system adjacent to the installation’s existing geothermal plant, to allow the 

geothermal plant to run more efficiently by providing power to cool the 

plant’s turbines. However, if the installation was to use the power 

generated by the solar and geothermal plants, the power lines required to 

distribute the power to the installation would have to be routed around 

areas designated for testing of live ordnance. The installation energy 

manager told us that the additional cost to route the power lines around 

the testing areas would make the project too costly to implement. 

However, it is sometimes possible to develop renewable projects while 

maintaining mission effectiveness even when there is potential 

incompatibility between the two. For example, at one Air Force 

installation we visited, the installation officials were restricted in their 

ability to install a photovoltaic array due to concerns from the air 

operations staff that reflections from the array could disrupt training. A 

resolution to the incompatibility of installation needs was found by placing 

the array in a location that did not conflict with training, yet had an 

adequate solar resource. In another example, representatives from federal 

land management agencies, the services, and county officials worked with 

DOD installations to develop a map that indicates the height of wind 

turbines that require DOD review. In a certain part of the map colored red, 

all turbines over 200 feet need to be reviewed by DOD to ensure 

compatibility with the installations’ mission. In other areas, colored green, 

no DOD review is required. 

Page 18 GAO-10-104 Defense Infrastructure
 

According to the officials responsible for drafting DOD’s energy security 

strategy, decisions about specific renewable energy projects should be 

made at the installation level because of the differing specifics of each 

project. But, according to these officials, DOD’s draft energy security 

strategy does not provide guidance to enable installation officials to 

develop the accommodations that may be possible and required to develop 

renewable energy projects that do not affect an installation’s primary 

mission. While many states have established goals requiring or 

encouraging that a fixed percentage of the electricity consumed in the 

state be generated from renewable sources, state government officials we 

interviewed said that they have removed DOD installations from 

consideration as possible sources for the renewable energy required to 

meet these state goals because of a lack of guidance specifying where 

renewable energy projects can be located on DOD lands. A senior OSD 

energy official has acknowledged that base commanders need to do a 

better job “compromising” between the two goals of primary mission 

execution and renewable energy project development and that OSD needs 

to do a better job of providing guidance to these commanders on their 

consideration of such projects. At the time of our report, the services were 

conducting assessments to determine which installations can most cost 

effectively develop locally available resources. However, the lack of OSD 

guidance indicating when it is appropriate for installation officials to 

develop such accommodations to establish a balance between renewable 

energy projects and an installation’s mission may delay or impede the 

development of renewable energy projects on and around DOD 

installations. 

Purchasing or Generating 

Renewable Energy May 

Conflict with DOD Policy 

and DOE Guidance to 

Invest in Renewable 

Energy Cost Effectively 

Both DOD policy and DOE’s guidance implementing the 2005 Act goal to 

obtain 3 percent of electricity from renewable sources and the 2007 

Executive Order goal to obtain an amount equal to half of the statutorily 

required renewable energy from sources placed into service after January 

1, 1999, encourage agency investment in renewable energy projects when 

it is cost-effective.36 DOD requires its facilities to use life-cycle cost 

analysis to determine whether a planned energy project is cost-effective 

relative to the status quo, and the DOE guidance notes that agencies 

 

36Further, the language of the 2005 Act goal itself directs fulfillment of the goal to obtain a 

certain percentage of energy from renewable sources “to the extent economically feasible 

and technically practicable.” 

Page 19 GAO-10-104 Defense Infrastructure
 

should develop certain on-site renewable energy systems when “life-cycle 

cost-effective” to do so. 

However, as we have previously reported, energy from renewable sources 

generally costs more than energy from nonrenewable sources, such as 

fossil fuels.37 According to our analysis of DOD data, most DOD 

installations would need to spend more money to generate or purchase 

renewable electricity than they would to purchase conventional electricity 

offered by their local utilities. That is because the cost of renewable 

electricity is often greater than the cost of conventional electricity, the 

latter of which makes up the majority of the electricity sold by utilities.38

Furthermore, in most states, DOD’s installations pay below-average rates 

for nonrenewable electricity.39 That means that most domestic DOD 

installations are even more likely to pay a higher price for renewable 

electricity than for the nonrenewable electricity provided by their local 

utilities. Thus, it may be challenging for DOD to develop on-site renewable 

energy systems that qualify for the goals while also attempting to follow 

DOD policy and DOE guidance that encourage investment in renewable 

energy projects when cost-effective. 

One way for DOD to partially mitigate the challenges posed by higher-cost 

renewable electricity may be to purchase or generate nonelectric 

renewable energy, which DOD officials explained is more cost-effective 

than electric sources. Our analysis of DOD data indicates that a sizable 

proportion—26 percent—of DOD’s total on-site domestic renewable 

energy production comes from nonelectric renewable energy sources. 

Ground source heat pumps are an example of nonelectric renewable 

technology; they provide nonelectric heating and cooling by using the 

constant temperature of the earth.40 These heat pumps are used in 5 of the 

 

37GAO, Department of Energy: Key Challenges Remain for Developing and Deploying 

Advanced Energy Technologies to Meet Future Needs, GAO-07-106 (Washington, D.C.: Dec. 

20, 2006), and GAO-07-550T. 

38According to GAO analysis of DOE data, almost all of the electricity generated in the 

United States comes from nonrenewable sources. For instance, in 2008, 91 percent of U.S. 

electricity generation came from power plants using nonrenewable sources of fuel, such as 

coal, natural gas, and nuclear material. 

39We compared prices paid by DOD installations to the average price for utility-delivered 

electricity in the states in which the installations were located. 

40According to the Environmental Protection Agency, these heat pumps are underground 

coils used to transfer heat from the ground to the inside of a building. See 

http://www.epa.gov/OCEPATERMS/gterms.html. 

Page 20 GAO-10-104 Defense Infrastructure
 

10 largest renewable energy projects on domestic DOD installations. 

According to DOE documentation, after 5 to 10 years, installations that 

install these pumps would save enough money through the pumps’ 

operation to repay the financing used to purchase and install them.41 In 

contrast, according to Navy officials, an installation that installs a 

renewable electric technology, such as a photovoltaic solar array, could 

have a substantially longer payback period—up to 35 years. However, 

according to the guidance and law that implement and establish the 

renewable energy goals, nonelectric renewable energy sources only 

qualified toward one of the three goals—the goal found in the 2007 

Executive Order stating that an agency is to obtain an amount equal to half 

of the statutorily required renewable energy from sources placed into 

service after January 1, 1999. As discussed earlier in this report, the 

National Defense Authorization Act for Fiscal Year 2010 amends the 

language defining the goal in the 2007 Defense Authorization Act. For 

example, DOD will now be able to count nonelectric renewable energy 

toward the 2007 Defense Authorization Act goal. However, as discussed 

earlier in the report, OSD has provided neither a clear definition of key 

terms in the act nor a methodology for calculating progress toward the 

goal. As a result it is unclear what effect these changes will have on the 

amount of progress DOD will be able to claim toward meeting this goal. 

Another example of the challenge faced by DOD to implement costeffective renewable energy projects involves the use of renewable energy 

generation as a source of backup power on DOD installations. According 

to DOD officials, it is particularly difficult to develop on-site renewable 

energy for backup power that is cost-effective because this use of 

renewable energy presents two technical challenges that make it 

expensive relative to conventional sources of backup power. 

• First, because certain renewable energy technologies,42 such as solar and 

wind, provide intermittent power, they require batteries to store the 

energy they produce or supplementary, conventional generation to ensure 

uninterrupted power. For example, because solar energy can only be 

 

41The payback data were obtained from the DOE Energy Efficiency and Renewable Energy: 

Energy Savers Web site at http://www.energysavers.gov/your_home/space_heating_ 

cooling/index.cfm/mytopic=12640. 

42Certain types of renewable electricity generation technologies—such as geothermal and 

biomass—can provide uninterrupted power, but because of certain limitations, relatively 

few DOD installations can use these types of renewable energy. For example, the 

distribution of these types of resources is limited to certain parts of the country. 

Page 21 GAO-10-104 Defense Infrastructure
 

generated during daylight hours, the average solar project operates 

approximately 20 percent of the hours in a year, according to industry 

standards. According to DOD officials, the battery technology needed to 

store a solar project’s electricity is currently too expensive for most 

installations to install. At one installation we visited, batteries and 

supplementary conventional power—to be used during the night and on 

cloudy days—would be necessary if the installation used its solar array as 

source of backup power. However, according to installation officials, this 

additional equipment would cost an estimated $50 million, increasing the 

original cost of the project by about 50 percent. 

• Second, technical and safety challenges require special controls to 

integrate the on-site renewable energy generation with an installation’s 

existing electrical infrastructure and operate the renewable technology 

safely during a power supply disruption. The technology required for 

coordinating an on-site generation project—renewable or nonrenewable—

with power delivered by the utility grid is costly. For example, at one 

installation we visited, DOD officials explained that using either of the two 

on-site renewable energy projects as a source of backup power would 

require upgrades to the installation’s energy distribution network that 

would allow the installation to switch from grid-delivered power to on-site 

power. These officials told us that such upgrades would be prohibitively 

expensive. Further, because of safety concerns, an installation’s 

interconnection agreement with its utility company requires that any onsite generation be switched off during utility grid outages external to the 

installation, to ensure that external utility wires are not electrified during 

repairs. Only one of the five installations we visited had installed a 

renewable energy system that allowed part of the installation to operate 

during an off-installation utility outage. That installation designed its 

distribution system to enable a solar photovoltaic system to power certain 

buildings during power outages, but this system relies on natural gas 

backup, increasing the total project cost. 

DOD officials explained that because renewable energy has a relatively 

higher cost than conventional alternatives, it is less feasible as a source of 

backup power for domestic installations. As a result of the high costs 

associated with using renewable energy as a source of backup power, 

installations generally rely on diesel generators for backup power. 

Because DOD policy requires energy projects to be cost-effective over 

their life cycles, and renewable energy projects are generally more 

expensive than nonrenewable energy projects, renewable energy projects 

are rarely selected to provide backup generation on military installations. 

Page 22 GAO-10-104 Defense Infrastructure
 

Alternative Financing 

Approaches Are 

Potentially Beneficial, but 

DOD Faces Three Key 

Obstacles in Implementing 

Them 

According to DOD officials, entering into alternative financing approaches 

to develop renewable energy projects offers three main advantages to 

DOD. First, certain alternative financing approaches may be more costeffective than DOD-funded and DOD-owned development of larger 

renewable energy projects. According to DOD officials, entering into 

alternative financing approaches to develop renewable energy projects 

may increase the likelihood of developing these projects on DOD land. 

This is because private developers have more options than DOD when it 

comes to obtaining project financing. For instance, developers can sell 

either the project’s energy or renewable energy certificates to a third 

party, such as the local utility. However, DOD officials stated that DOD 

cannot make these types of sales. In addition, according to DOD officials, 

in some cases, private developers are able to accept renewable energy 

incentives, such as tax credits, that DOD cannot claim. 

The second advantage, according to DOD officials, is that the government 

can realize significant benefits when renewable energy projects are owned 

by private developers because the contractor may provide operation and 

maintenance of the equipment. For example, officials at an Air Force 

installation we visited explained that their maintenance staff does not have 

anyone with the expertise to operate and maintain the installation’s 

renewable projects, and because contractors perform these functions, the 

installation does not need to hire additional staff to perform these tasks. 

Finally, although the services use up-front appropriated funding to develop 

smaller renewable energy projects, DOD officials explained that up-front 

appropriated funding may be a poor fit for developing the larger, highercost renewable projects that a key official says are necessary to achieve 

the renewable energy goals. According to GAO analysis of DOD project 

data, the services primarily use two types of up-front appropriated funding 

for smaller renewable projects: the Energy Conservation Investment 

Program, funded with a military construction account, and the operations 

and maintenance accounts. Because the total amount of annual Energy 

Conservation Investment Program funding is divided among the services, 

officials explained that they are limited in the amount of resources they 

can commit to a high-cost project from that account. According to DOD, 

OSD generally grants Energy Conservation Investment Program funding 

for potential renewable projects based on analysis of the project’s lifecycle costs; the less an installation’s energy costs, the less likely it may be 

to receive funding from that account. Because many DOD installations pay 

low rates for utility-delivered electricity, their proposals for Energy 

Conservation Investment Program funds to develop renewable projects 

Page 23 GAO-10-104 Defense Infrastructure
 

are often not selected, increasing the challenge DOD faces in funding 

projects that meet the criteria for funding. 

According to DOD officials, operations and maintenance funding may also 

be difficult to use for the development of the large, higher-cost renewable 

projects that the services plan to develop to meet DOD’s renewable energy 

goals. For instance, according to an Army official, the service considered 

building a 35-megawatt concentrated solar thermal plant. If completed, 

this project would be one of the largest on DOD land. According to this 

official, the Army estimated that the project would require an estimated 

$1.8 billion in appropriated funding. Because annual allocations of 

operations and maintenance funding are typically limited to $750,000 per 

project,43 these funds may not be sufficient to fund such large, costly 

projects. 

Although DOD has developed many small renewable energy projects with 

up-front appropriated funding, it has relied on alternative financing 

approaches for its relatively few large renewable energy projects. For 

example, GAO analysis of DOD data indicates that while the majority—74 

percent—of renewable energy projects are funded using up-front 

appropriations, these projects only generate 13 percent of renewable 

energy produced on DOD land. In contrast, while only 18 percent of 

projects are funded using alternative financing, these projects generate the 

majority—86 percent—of renewable energy produced on DOD land. 

Because alternative financing can supplement up-front appropriated 

funding, the services have encouraged the use of such approaches, in 

which a private developer provides much or all of the funding required to 

develop an energy project that uses a renewable source on, or close to, 

DOD land. We determined that although these approaches can make more 

funding available for DOD renewable energy projects, DOD needs to 

overcome the following three key obstacles to implementing these 

approaches. 

• First, specific, local circumstances at installations can limit financing 

options for renewable energy projects and limit DOD’s ability to develop a 

departmentwide strategy for financing projects. 

• Second, DOD has a relatively small community of officials with the 

necessary expertise to develop and manage these approaches. 

 

4310 U.S.C. § 2805(c). 

Page 24 GAO-10-104 Defense Infrastructure
 

• Third, under DOE guidance, unless agencies meet two criteria, the 

agencies cannot count renewable energy from projects built at federal 

facilities or owned by a federal agency but located on private property 

toward the goal in the 2005 act goal of obtaining 3 percent of their 

electricity from renewable sources and the 2007 Executive Order goal to 

obtain an amount equal to half of the statutorily required renewable 

energy from sources placed into service after January 1, 1999.44 The first 

criterion is that the renewable energy be produced and used on-site by a 

federal agency, or the renewable energy be produced by a project owned 

by a federal agency but installed on private property. The second criterion 

is that the agency retain or replace the renewable energy certificates 

associated with the energy produced. Thus, because alternative financing 

arrangements often require agencies such as DOD to permit the private 

developer to take possession of the renewable energy certificates, DOD 

would not be able to count the energy produced by alternatively financed 

projects toward the 2005 Act and 2007 Executive Order goals. 

If installation officials wish to use an alternative financing approach, they 

could use one of several types, including Energy Savings Performance 

Contracts and Utility Energy Service Contracts.45 However, in practice, the 

type of approach chosen by an installation can depend on the specific 

financing options locally available to that particular installation. For 

example, an official at an Air Force installation we visited told us that the 

installation has only been able to use Energy Savings Performance 

Contracts. This is because the local electric utility has not offered a Utility 

Energy Service Contract, as in this type of contract the utility usually earns 

a profit only after demonstrating that it has saved its customer money by 

decreasing the amount of money the customer spends on energy. Because 

the installation’s electricity prices are already low, it would be difficult for 

the utility to further lower the installation’s energy costs. While an 

installation official stated that the installation is interested in developing 

additional renewable energy projects, he explained that the installation 

Limitations Caused by Local 

Conditions at Installations 

 

44DOE, Office of Energy Efficiency and Renewable Energy, Renewable Energy 

Requirement Guidance for EPACT 2005 and Executive Order 13423, § 3.2.1, 3.2.2. 

45Energy Savings Performance Contracts allow federal agencies to hire a contractor to 

develop energy conservation or renewable energy projects with the expectation that the 

annual savings from the project will fund the project’s annual costs. We have previously 

reported the Energy Savings Performance Contracts are likely to be more expensive over 

the long run than using full upfront appropriations to purchase assets; see GAO, Capital 

Financing: Partnerships and Energy Savings Performance Contracts Raise Budgeting 

and Monitoring Concerns, GAO-05-55 (Washington, D.C.: Dec. 16, 2004). Utility Energy 

Service Contracts are contracts between a federal agency and the local utility to provide 

comprehensive energy improvements, such as an energy efficiency or renewable energy. 

Page 25 GAO-10-104 Defense Infrastructure
 

has already developed the projects that are most cost-effective when using 

an Energy Savings Performance Contract. The official explained that if the 

installation decides to develop additional renewable energy projects, it 

may need to find a new contract and financing vehicle. 

The specific, local circumstances surrounding the financing of renewable 

energy projects have made the creation of a DOD-wide strategy for 

funding these projects challenging. According to DOD officials, the market 

conditions that may make a potential renewable energy project attractive 

to private developers are often location and time specific. For example, 

another Air Force installation we visited partnered with a developer that 

financed and built one of the nation’s largest solar photovoltaic arrays on 

the installation’s land. The installation was able to negotiate a contract for 

low electricity prices with the developer because the Air Force provided 

the developer with the project’s renewable energy certificates. At the time 

of negotiation, this was possible because of the renewable energy 

certificates’ high price in the state’s electricity market. However, 

according to Navy officials, when the Navy subsequently attempted to 

replicate this project development model at an installation in the same 

state, the price of renewable energy certificates had decreased 

significantly, and the Navy’s potential private sector partners declined the 

project because they did not want to retain the now-less-valuable 

renewable energy certificates. A key OSD official explained that because 

alternative financing approaches depend on these types of specific, local 

conditions, a departmentwide strategy for financing these projects is not 

likely to be feasible. Rather, according to the OSD official, the more 

feasible approach would be to have an installation’s energy management 

staff—experts on these local circumstances—develop the approaches. 

According to DOD officials with whom we spoke, the department has a 

shortage of officials with the necessary expertise to develop and manage 

alternative financing approaches. GAO has previously reported that if an 

agency is to effectively and efficiently implement these types of 

approaches, agency officials with adequate contracting expertise are 

critical to the success of the agency’s efforts and to protecting the 

Shortage of Staff with 

Expertise for Developing 

Alternative Financing 

Approaches 

Page 26 GAO-10-104 Defense Infrastructure
 

government’s interest in regard to government financial resources 

committed to these approaches.46

During our review, we found that DOD installations have varying human 

capital resources and expertise for developing alternative financing 

approaches. For example, according to Army officials, trained and 

qualified energy managers are in “short supply” at Army installations, most 

of the Army’s contracting officers are generalists and have not been 

trained in contracting for renewable energy projects, and the Army also 

lacks personnel sufficiently trained in the legal requirements for 

authorizing the development of renewable energy projects. Officials from 

the Navy had similar concerns, explaining that when it comes Energy 

Savings Performance Contracts, the Navy does not have the expertise to 

define its own contract requirements or compare the renewable energy 

project proposals to determine which of the potential contractors to hire. 

Air Force officials stated that because of the shortage of trained energy 

managers in the Air Force, most of the personnel serving in this capacity 

have an installation management workload that is two or three times 

larger than it should be. The officials explained that when personnel have 

workloads this large, they will usually not have enough time to fully 

execute their multiple responsibilities. 

Despite DOD guidance requiring that all installations have trained energy 

management personnel, we have previously reported that energy 

managers at some DOD installations lacked the expertise required to 

negotiate contracts for complex alternative financing approaches, and 

DOD has not adequately trained these managers in negotiating these 

contracts.47 In the course of our review, a shortage of trained energy 

managers was evident at some of the installations we visited. For example, 

some energy managers were not aware of certain strategies and 

contracting methods for renewable energy project development because 

they had not received relevant training. At one installation we visited, the 

energy management staff were largely unfamiliar with alternative 

financing because they had not received training on the subject. According 

 

46In our previous work, we have found that these contracts offer some benefits and 

challenges similar to those we discuss in this report. See GAO, Energy Savings: 

Performance Contracts Offer Benefits, but Vigilance Is Needed to Protect Government 

Interests, GAO-05-340 (Washington, D.C.: June 22, 2005). 

47GAO, Federal Energy Management: Addressing Challenges through Better Plans and 

Clarifying the Greenhouse Gas Emission Measure Will Help Meet Long-term Goals for 

Buildings, GAO-08-977 (Washington, D.C.: Sept. 30, 2008). 

Page 27 GAO-10-104 Defense Infrastructure
 

to service officials, energy managers are sometimes “dual hatted,” serving 

as both the energy manager and the utility manager, giving an energy 

manager two complex jobs to do at the same time. At another installation 

we visited, the utility manager told us that because he was dual hatted, he 

did not have time to develop additional alternative financing approaches. 

Army officials told us that it was increasingly difficult to recruit and retain 

qualified energy managers because of increasing competition with other 

government entities and private sector employers. To address this 

challenge, service officials said that they plan to hire additional staff to 

support efforts to meet the renewable energy goals. However, this hiring is 

not expected to be completed until fiscal year 2013, at the earliest. 

As we explained earlier in this report, DOD expects to rely increasingly on 

alternative financing approaches to meet the renewable energy goals. For 

DOD to effectively implement these approaches, the department will 

require energy management staff who have the relevant expertise for 

implementing the approaches. However, because we found that the 

services and their installations’ staff often lack expertise in developing 

alternative financing approaches, DOD may by limited in its ability both to 

use these approaches to develop renewable energy projects and to do so 

in a manner that adequately protects the government’s financial resources 

committed to these approaches. 

According to DOD officials, in most cases, private developers are generally 

interested in partnering with DOD in order to sell the projects’ unbundled 

energy or associated renewable energy certificates to a third party. These 

officials explained that the generally accepted business model for these 

types of approaches includes a renewable energy resource on or near DOD 

land that is harnessed by a project financed, built, and operated by thirdparty developer that then sells the unbundled energy to DOD or other 

customers and typically retains ownership of the project’s renewable 

energy certificates.48

Much of the Energy Generated 

May Not Qualify for Meeting 

the Renewable Energy Goals 

However, under such approaches, DOD often would neither consume the 

renewable energy nor retain the renewable energy certificates. When DOD 

does not consume the renewable energy, a developer would provide some 

other form of compensation for the use of the renewable resource on DOD 

 

48Although DOD has relatively few projects that follow this model, according to DOD 

officials, the department plans to enter into more alternative financing approaches that 

follow this model. 

Page 28 GAO-10-104 Defense Infrastructure
 

land. For example, in the largest renewable energy project on DOD land, 

DOD does not consume the energy but instead receives financial 

compensation based on the sale of the project’s energy. If DOD neither 

consumes the renewable energy nor retains the renewable energy 

certificates, a serious challenge may be posed to DOD’s ability to meet the 

renewable energy goals. That occurs because, according to DOE’s 

guidance on implementation of the 2005 Act and the 2007 Executive 

Order—guidance designed to preserve the integrity of the renewable 

energy certificate market—for an agency to count a project’s renewable 

energy toward these goals, the project must meet two requirements. First, 

the renewable energy must be produced and used on-site at a federal 

agency or the renewable energy must be produced by a project owned by a 

federal agency but installed on private property. Second, the agency must 

retain or replace the renewable energy certificates associated with the 

energy produced. In addition, as we discussed earlier, unlike DOE, DOD 

has not issued guidance that provides a clear explanation of its 

methodology for calculating progress toward the fiscal year 2025 goal 

under the 2007 Defense Authorization Act, including DOD’s definition of 

“consumption” and the treatment of renewable energy certificates in that 

context. 

When DOD consumes the unbundled energy from a project built at a 

federal facility and does not retain the certificate—as is the case with one 

of the largest renewable energy projects on DOD land—DOD has two 

options: to not count the energy toward the renewable energy goals or to 

obtain new renewable energy certificates to replace those retained by the 

private developer.49 If DOD plans to count the energy toward the goals, it 

would need to choose the second option, since under DOE guidance, DOD 

would need to consume the energy and own renewable energy certificates 

in order to count the energy toward the renewable energy goals. If DOD 

chose to purchase replacement renewable energy certificates, then it 

would generally pay a higher price for the energy consumed because DOD 

would need to purchase two products—the renewable energy and the 

replacement certificates. In short, while alternative financing approaches 

supplement DOD’s appropriated funding and cost DOD less up front, if 

DOD intends to count projects’ energy toward the renewable energy 

 

49According to the DOE guidance, a federal agency can obtain replacement certificates in 

two different ways. It can trade with another federal agency or purchase the certificates 

from another source. DOE, Office of Energy Efficiency and Renewable Energy, Renewable 

Energy Requirement Guidance for EPACT 2005 and Executive Order 13423, § 3.2.2. 

Page 29 GAO-10-104 Defense Infrastructure
 

goals,50 DOD generally faces additional costs to purchase replacement 

certificates. 

OSD Lacks a LongTerm, 

Departmentwide Plan 

to Meet the 

Renewable Energy 

Goals 

OSD Has Not Developed a 

Departmentwide, LongTerm Plan to Meet the 

Renewable Energy Goals 

Previous GAO work has shown that long-term plans can help agencies 

ensure that they meet their goals by identifying potential challenges 

agencies face in meeting their goals, coordinating the actions of agencies’ 

components in pursuit of the goals, laying out performance measures for 

achieving those goals, aligning agency activities and resources to attain the 

goals, and providing the data agencies need to accurately assess progress 

against these performance measures. 

Although DOD guidance states that offices within OSD are responsible for 

providing guidance and oversight for meeting DOD’s energy goals, OSD 

has not developed a plan for meeting the renewable energy goals. DOD’s 

draft energy security strategy that OSD was developing at the time of our 

review does address some issues relevant to DOD installations’ use of 

renewable energy, according to an official representing OSD. For instance, 

the official explained that the draft strategy recognizes that renewable 

energy technologies tend to be more costly than nonrenewable energy 

generation. However, the draft strategy focuses on energy security without 

specifically addressing the renewable energy goals or presenting a plan to 

achieve them. For example, the draft strategy does not specify how DOD is 

to coordinate the services’ renewable energy activities, according to 

officials from OSD. 

 

50In such cases, it is unclear whether DOD must purchase replacement certificates to count 

the renewable energy toward the fiscal year 2025 goal under the 2007 Defense 

Authorization Act. As discussed earlier in the report, DOD has not developed guidance that 

could clarify this issue. 

Page 30 GAO-10-104 Defense Infrastructure
 

Because OSD has not developed a long-term, departmentwide plan to meet 

DOD’s renewable energy goals, DOD instead relies on OSD’s current 

approach to managing the services’ renewable energy efforts as the means 

for achieving the goals. A senior OSD official who plays a key role in 

OSD’s renewable energy activities explained that under OSD’s current 

approach, each of the services plans, budgets, and implements an 

individual renewable energy effort. He explained that by following this 

approach, DOD intends to achieve—or nearly achieve—the renewable 

energy goals in most years. However, we found four reasons that that this 

approach may not be effective in helping DOD meet the renewable energy 

goals. Specifically, the approach (1) does not identify key challenges to 

meeting the goals or contain solutions for mitigating those challenges; 

(2) relies on the services to develop individual approaches to meeting the 

goals, which may not be effective; (3) lacks accurate performance 

measures with which DOD could assess progress toward the goals; and 

(4) may not be effectively aligning DOD’s resources toward achieving the 

goals. 

First, OSD did not identify the key challenges we discussed earlier in this 

report. Specifically, OSD did not identify as a key challenge its dependence 

on renewable energy certificates—a commodity with fluctuating prices—

to meet the renewable goals. When the price of renewable energy 

certificates increased significantly from fiscal year 2007 to fiscal year 2008, 

DOD purchased fewer of these certificates, and DOD missed meeting the 

2005 Act goal of obtaining 3 percent of electricity from renewable sources 

in fiscal year 2008. When this occurred, OSD had neither a plan identifying 

this key challenge nor a solution for mitigating the challenge, such as 

relying more on sources of renewable energy with more stable pricing. For 

instance, according to an analysis by DOE’s Pacific Northwest National 

Laboratory, purchasing renewable energy from a wind turbine project is 

generally less risky than purchasing renewable energy certificates in a 

volatile market.51 Because OSD lacked such a plan or solution, DOD was 

unprepared to compensate for the decrease in the amount of renewable 

energy that it claimed toward the goals when it purchased fewer 

certificates. 

Second, we found that if the services separately pursue their own courses 

with regard to renewable energy efforts, their individual approaches may 

 

51DOE, Pacific Northwest National Laboratory, Purchasing Renewable Power for the 

Federal Sector: Basics, Barriers, and Possible Options.

Page 31 GAO-10-104 Defense Infrastructure
 

not be effective in helping DOD meet its renewable energy goals. While the 

three services are developing renewable energy plans, their plans lack key 

elements. For example, the Air Force’s plan lacks accurate cost estimates 

and complete data on how much funding has been allocated to renewable 

energy projects. In addition, the Army’s plan is preliminary in nature and 

cannot yet be considered complete. For instance, according to its plan and 

Army officials, the Army still needs to develop implementation strategies, 

establish and coordinate performance measures, and begin the “significant 

job” of executing the plan. Finally, the Navy’s plan is also preliminary; 

does not explain how the Navy will align its organizations’ renewable 

activities to attain the goals; does not discuss what type, or amount, of 

resources the Navy will commit to these activities; and does not address 

the Navy’s need for better management of its energy data. 

Third, OSD’s current approach lacks accurate performance measures with 

which to assess DOD’s progress toward meeting the 2007 Defense 

Authorization Act goal. GAO has previously reported that by specifying 

performance measures, agencies are better able to monitor progress made 

and hence better able to achieve the goals. While OSD has established 

performance measures to assess DOD’s progress toward meeting the 2007 

Defense Authorization Act goal, those performance measures are based on 

inaccurate calculations. Specifically, according to a key official, OSD 

assumed that DOD’s renewable energy consumption would increase by 

roughly 1 percent annually. In its fiscal year 2010 Budget Request 

Summary Justification (published in May 2009), DOD included renewable 

energy consumption targets for fiscal years 2009 and 2010, based on this 

assumption. However, as we discussed earlier in the report, DOD 

overstated its fiscal years 2007 and 2008 renewable electricity 

consumption by incorrectly including nonelectric renewable energy 

toward this goal. Because DOD’s renewable energy consumption targets 

for fiscal years 2009 and 2010 were based on these previous, inaccurate 

calculations, the fiscal years 2009 and 2010 targets were also overstated 

and hence similarly unlikely to be achieved. 

As discussed earlier in this report, the National Defense Authorization Act 

for Fiscal Year 2010 amends the language defining the goal in the 2007 

Defense Authorization Act. However, at the time DOD published the 

targets, the original requirements of the 2007 Defense Authorization Act 

goal were still in effect. This means that—regardless of the subsequent 

changes to the 2007 Defense Authorization Act goal—DOD’s renewable 

energy consumption targets for fiscal years 2009 and 2010 were based on 

calculations that were inaccurate at the time DOD published the targets. 

Page 32 GAO-10-104 Defense Infrastructure
 

Finally, the services may not be effectively aligning DOD resources in 

pursuit of the renewable energy goals. According to DOD Instruction 

4170.11, offices within OSD are responsible for providing oversight for the 

achievement of the renewable energy goals. However, OSD is not 

coordinating the services’ allocation of resources in pursuit of the DODwide renewable energy goals, as evidenced by the fact that the services’ 

cost estimates include projects that generate renewable energy that would 

not count toward at least two of the renewable energy goals. Specifically, 

officials from each of the services explained that their estimates on the 

total cost of meeting the renewable energy goals are based on the 

assumption that at least a portion of the renewable energy will be 

generated through alternative financing approaches on DOD land. 

However, if the private developers sell the associated renewable energy 

certificates to third parties, and DOD does not replace the certificates, 

DOD cannot count the energy toward the goals in the 2005 Act or 2007 

Executive Order. Further, as discussed above, in the absence of additional 

guidance from OSD, it is unclear how the services are to properly count 

production of unbundled energy toward the 2007 Defense Authorization 

Act goal. If OSD’s lack of oversight continues, the services’ cost estimates 

may continue to include projects whose energy would not count toward 

these two goals. 

Lacking a coordinated, DOD-wide plan for achieving the renewable energy 

goals, OSD has instead relied on an approach that has not identified key 

challenges or potential solutions, established accurate performance 

measures, or aligned DOD’s resources in pursuit of the goals. This means 

that OSD has relied on the services to develop individual approaches. As a 

result, OSD has relied on the services’ incomplete plans for achieving 

these goals, and lacks a coordinated DOD-wide plan to meet the 

challenging goal contained in the 2007 Defense Authorization Act. 

OSD Lacks Visibility on 

Renewable Energy 

Projects, and Services 

Lack Adequate 

Information Systems for 

Tracking Renewable 

Energy Use 

GAO has previously reported that strategic information management 

provides agencies with the data they need to improve program 

effectiveness and ensure consistent results. However, OSD does not have a 

system in place to track individual renewable energy projects or key 

information about these projects. Thus, while OSD is responsible for 

coordinating the services’ renewable energy activities in pursuit of the 

goals, it does not have adequate visibility over the services’ renewable 

energy efforts. For example, at the time of our review, OSD had neither a 

list of the renewable energy generation projects operating in DOD 

installations nor key information on the projects, such as their location, 

the type or amount of energy they produce, or the amount of funding 

Page 33 GAO-10-104 Defense Infrastructure
 

required to develop the projects. In order to complete our review, we 

gathered various data on these types of projects from DOD to develop our 

own data set. According to a key OSD official responsible for DOD’s 

energy management, the data set we created was the first of its kind. 

Although DOD policy requires all of the services to collect and manage 

data on the procurement and use of energy on their installations, at the 

time of our review, two of the three had not developed adequate 

information systems for monitoring or reporting their use of renewable 

energy. Specifically, the software that these two services use to manage 

their energy data does not reflect the sources of renewable energy that are 

eligible to be counted toward the renewable energy goals. For example, at 

two installations we visited, installation officials explained that the 

software they use to report their renewable energy production and 

consumption can only record the use of one category of energy: wind. 

However, both installations used forms of renewable energy other than 

wind. As a result, one installation had to use complex calculations in a 

lengthy process of conversion, transforming its data from these other 

technologies into units that it could report as wind energy. According to 

service officials, the Air Force and Navy were in the process of addressing 

several of the issues that we have identified in this report. For instance, an 

Air Force official told us that the Air Force is working on updating its 

system for managing energy information. However, the Air Force official 

was unable to provide us with a date by which the service was planning to 

complete the update of its energy management software. 

As a result of the lack of adequate data management in the services and 

OSD, DOD lacks accurate, complete, and consistent data for effectively 

managing its renewable energy resources in pursuit of the renewable 

energy goals. Lacking such data, OSD cannot effectively coordinate 

service efforts in pursuit of the renewable energy goals, and DOD may not 

be able to accurately assess its performance against the goals. 

DOD met both the 2005 Act and 2007 Executive Order goals in fiscal year 

2007 and met the 2007 Executive Order goal in fiscal year 2008. However, 

in that same fiscal year, it missed the 2005 Act goal, and in both fiscal 

years overstated its progress toward the 2007 Defense Authorization Act 

goal. Furthermore, DOD does not have all the elements in place to enable 

it to maximize its progress toward meeting these goals. First, because the 

services lack OSD guidance that provides a methodology for calculating 

progress toward the 2007 Defense Authorization Act goal and OSD’s legal 

rationale for how its accounting method is consistent with the language of 

Conclusions 

Page 34 GAO-10-104 Defense Infrastructure
 

the statute, when the services calculate their progress toward the 2007 

Defense Authorization Act, they cannot be sure whether including 

electricity generated on DOD lands but not consumed by DOD is 

consistent with the act. Such guidance would better enable OSD to both 

accurately measure DOD’s progress toward the goal and accurately report 

on this progress to Congress. Second, OSD lacks guidance that could 

assist installation officials in developing accommodations to resolve 

potential incompatibilities between renewable energy projects and an 

installation’s primary mission. Guidance would assist DOD in its 

development of renewable energy projects on and around DOD 

installations. Third, DOD lacks a sufficient cadre of qualified officials 

trained to effectively implement alternative financing approaches. With a 

sufficient number of officials qualified to effectively implement these 

approaches, DOD would improve its opportunities for developing 

renewable energy projects while protecting the government’s financial 

resources committed to these projects. Fourth, OSD lacks a long-term, 

DOD-wide plan containing strategies for coordinating the services’ 

renewable energy activities, establishing accurate performance measures 

for achieving the renewable energy goals, and effectively aligning DOD 

resources in pursuit of these goals. Such a plan would strengthen DOD’s 

ability to meet future annual goals for renewable energy consumption. It is 

important to note that the fiscal year 2010 Defense Authorization Act 

amended the 2007 Authorization Act. However, because OSD lacks a clear 

methodology for calculating progress towards the 2007 Act’s goal, 

determining the effect of the amendments on the amount of renewable 

energy the department can claim toward that goal is uncertain. Moreover, 

there are other key challenges we have identified in this report. Thus, a 

long-term, DOD-wide plan would still strengthen DOD’s ability to meet 

these goals. Fifth, OSD lacks a system for tracking individual renewable 

energy projects DOD-wide, and two of the three services do not have 

adequate data systems for monitoring or reporting their use of renewable 

energy. With an OSD system that tracks projects across DOD and service 

systems that adequately monitor and report data on their renewable 

energy use, DOD would be better able to effectively coordinate service 

efforts in pursuit of the renewable energy goals, monitor and report 

service use of renewable energy, and accurately assess DOD’s 

performance against the goals. 

To enhance DOD’s ability to achieve the renewable energy goals 

consistent with the need to maximize cost-effectiveness, follow existing 

federal guidance, and increase oversight of DOD’s renewable energy 

activities, we recommend that the Secretary of Defense direct the Under 

Recommendations for 

Executive Action 

Page 35 GAO-10-104 Defense Infrastructure
 

Secretary of Defense (Acquisition, Technology and Logistics) in 

conjunction with the secretaries of the services to take the following five 

actions: 

• Develop and issue guidance specifying how to accurately report DOD’s 

annual progress toward the 2007 Defense Authorization Act goal, as 

amended by fiscal year 2010 Defense Authorization Act. Among other 

things, this guidance should clearly define how the services are to apply 

the terms “produce” and “consume” to their implementation of the goal 

and how OSD is to apply the terms to its reporting of DOD’s progress 

toward the goal. 

• Develop and issue guidance to assist the services in determining how to 

balance the use of land for renewable projects with their installations’ 

primary missions, thereby assisting installation commanders and potential 

investors in knowing which land on the installations may be available for 

renewable energy projects, consistent with the installations’ mission 

capabilities. 

• Facilitate the successful implementation of alternative financing 

approaches and help ensure that DOD can maximize its opportunities for 

completing cost-effective renewable energy projects by (1) determining 

the adequate number of energy managers, contracting officials, and other 

officials with the necessary expertise to administer these complex 

transactions and (2) determining and providing the appropriate level of 

training to these employees. 

• Develop a long-term, DOD-wide plan to assist DOD in effectively and 

efficiently meeting the renewable energy goals over the long term. At a 

minimum, this plan should identify key challenges—such as the higher 

price of renewable energy compared with conventional energy and 

volatility in renewable energy certificate markets—that DOD faces in 

meeting the goals and ways to mitigate those challenges. The plan should 

also coordinate the services’ renewable energy activities, contain realistic 

performance measures for DOD and the services so that OSD can 

accurately assess annual progress, and align DOD’s resources in pursuit of 

the renewable energy goals. 

• Develop information systems or processes that will enable OSD to have 

visibility over DOD renewable energy projects, allow the services to 

monitor and coordinate the services’ consumption of renewable energy, 

and guide DOD toward achievement of the renewable energy goals. 

Page 36 GAO-10-104 Defense Infrastructure
 

In written comments on a draft of this report, DOD concurred with our 

recommendations to develop (1) guidance on reporting progress toward 

the goal to obtain 25 percent of its facilities’ energy from renewable 

sources by 2025, (2) guidance on balancing installations’ renewable energy 

goals with the installations’ missions, (3) a plan to meet renewable energy 

goals, and (4) information systems improving visibility over service 

progress toward the renewable energy goals. DOD partially concurred 

with our recommendation that OSD work with the secretaries of the 

services to facilitate the successful implementation of alternative financing 

approaches and help ensure that DOD maximizes opportunities for 

completing cost-effective renewable energy projects by (1) determining 

the adequate number of energy managers, contracting officials, and other 

officials with the necessary expertise to administer these complex 

transactions and (2) determining and providing the appropriate level of 

training to these officials. In its comments, DOD acknowledged that 

sufficient personnel with appropriate skills are necessary to execute thirdparty finance actions. However, DOD also stated that implementing the 

recommendation is the services’ responsibility because DOD Instruction 

4170.11 requires the services to designate and assign adequate staff to 

satisfy statutory energy management mandates, and manage the number 

and skills of these officials. While we recognize that the instruction 

specifies that the military services are to designate and assign energy 

management staff to their facilities, our report clearly stated that the 

Army, Navy, and Air Force had not fully implemented the instruction since 

each of these services continue to experience shortages of qualified energy 

officials. Moreover, the instruction assigns to an office within OSD the 

responsibility of conducting oversight of the services’ implementation of 

the instruction, and OSD’s activities to date have similarly not led to 

sufficient numbers of trained energy officials at the installations. As a 

result, we continue to believe that our recommendation has merit, and 

consequently we reiterate the recommendation. DOD’s comments are 

reprinted in appendix II of this report. 

Agency Comments 

and Our Evaluation 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

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

congressional committees; the Secretaries of Defense, Energy, the Army, 

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

the Director, Office of Management and Budget. The report also will be 

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

Page 37 GAO-10-104 Defense Infrastructure
 

If you or your staff have any questions concerning this report, please 

contact Mark Gaffigan at (202) 512-3168 or gaffiganm@gao.gov or Brian J. 

Lepore 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 to this report are listed in 

Mark Gaffigan

appendix III. 

Brian J. Lepore, Director 

Defense Capabilities and Management 

, Director 

Natural Resources and Environment 

Page 38 GAO-10-104 Defense Infrastructure
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

Our objectives were to (1) determine whether the Department of Defense 

(DOD) met three key goals for consuming renewable energy in fiscal years 

2007 and 2008; (2) identify the challenges that may affect DOD’s ability to 

meet the renewable energy goals; and (3) assess DOD’s plans to meet the 

renewable energy goals. 

To determine whether DOD met the Energy Policy Act of 2005 (the 2005 

Act) and Executive Order 13423 (the 2007 Executive Order) goals for 

consumption of renewable energy in its facilities in fiscal years 2007 and 

2008, we analyzed data on DOD’s performance toward these goals from 

the department’s annual energy management reports for fiscal years 2007 

and 2008. These reports were submitted by DOD to the Department of 

Energy (DOE) for use in DOE’s Annual Report to Congress on Federal 

Government Energy Management and Conservation Programs. For fiscal 

years 2007 and 2008, we considered DOD to have met the 2005 Act goal if 

it obtained at least 3 percent of the electricity it consumed from renewable 

sources as defined in section 203 of the act, and considered DOD to have 

met the 2007 Executive Order goal if it obtained equal to half (or 1.5 

percent) of this energy from new renewable sources as defined in section 

2(b) of the executive order. In addition, we met with officials from DOE’s 

Federal Energy Management Program—which prepared guidance for 

agencies to follow when meeting the goals—to gain their perspective on 

how progress toward the goals is calculated. We also met with officials 

from the Office of the Under Secretary of Defense (Acquisition, 

Technology and Logistics), the Facility Energy office of the Office of the 

Deputy Under Secretary of Defense (Installations and Environment), and 

each of the military services to discuss how DOD and the services 

calculated their progress toward the goals. To determine DOD’s progress 

toward the National Defense Authorization Act for Fiscal Year 2007 goal 

for consumption of renewable energy, we reviewed DOD’s reported 

progress toward the goal included in the fiscal years 2007 and 2008 annual 

energy management reports and data provided by the services to the 

Facility Energy office of the Deputy Under Secretary of Defense 

(Installations and Environment) for preparation of the report. We also 

reviewed the legal language that established the goal and discussed our 

interpretation of this language with officials in the Office of the Secretary 

of Defense (OSD) General Counsel’s office. 

The data used by DOD to determine its progress toward the three goals are 

assembled using a data collection instrument that is separate from the 

information systems used by the military services to manage energy data. 

This data collection instrument is an electronic template created by DOE’s 

Federal Energy Management Program and disseminated to the federal 

Page 39 GAO-10-104 Defense Infrastructure 
Appendix I: Scope and Methodology 

agencies to use to assemble data for their annual energy management 

reports. To determine the reliability of the data used by DOD to report its 

progress toward the three goals, we interviewed officials at each level of 

data collection, aggregation, and review: those responsible for preparing 

the data collection tool sent to energy managers at the military facilities; 

for entering this information into data collection tools at the facility level; 

for summarizing it and checking it for accuracy at the headquarters level 

for each of the services; and for combining the services’ data into a 

departmentwide total and assessing the accuracy of this total. We also 

obtained the data submitted by the services to OSD, and compared the two 

data sets for completeness and accuracy. We did not find discrepancies 

between the data submitted by the services to OSD and the department’s 

annual energy management report data. We determined that these data 

were sufficiently reliable for our purpose, which was to convey the 

progress DOD made toward the three key goals for consumption of 

renewable energy in its facilities. 

To identify the challenges that affect DOD’s ability to meet these goals in 

the future, we met with officials at the Facility Energy office of the Deputy 

Under Secretary of Defense (Installations and Environment), each of the 

military services’ headquarters, and offices within each military service 

with responsibility for renewable energy projects, and obtained and 

analyzed relevant documentation from these officials. Using a data 

collection instrument, we also collected data on the location, size, type, 

and financing of renewable energy projects at DOD. We used this data 

collection instrument because DOD does not have a central, 

comprehensive list of renewable energy projects. We sent the instrument 

to OSD with instructions in December 2008, and OSD sent the instrument 

to each of the services for each facility with relevant projects to complete 

the instrument. The initial data collection instrument, which we received 

from OSD in February 2009, accounted for all renewable energy projects 

from relevant DOD facilities, but was incomplete in that information on 

funding mechanisms was not provided for all projects. We made a followup request to OSD to clarify the missing elements of the data. These 

elements were incorporated into the original response from OSD. To 

determine the reliability of these data, we checked them against previously 

identified information about the projects and, when inconsistencies were 

found, discussed them with OSD and the services and made corrections 

when relevant. We determined these data were sufficiently reliable for our 

purpose, which was to establish how much renewable energy DOD 

produced from electric and nonelectric renewable energy and from 

projects financed through each type of financing approach. We also visited 

five military facilities to determine the practical effect of the challenges to 

Page 40 GAO-10-104 Defense Infrastructure
Appendix I: Scope and Methodology 

meeting renewable energy goals on the facilities. We selected these 

installations because they represent each of the military services, have 

different types and sizes of renewable energy projects, and operate in 

three different states. At these locations, we interviewed the facility energy 

managers and other relevant officials; confirmed data we had received 

about the facilities’ renewable energy projects; viewed renewable energy 

projects at the facilities; and obtained relevant documents, including 

contracts for renewable energy projects, energy reports generated from 

on-site data management systems, and utility invoices. We systematically 

reviewed these interviews with OSD, military service, and facility officials 

to determine what primary challenges DOD faces and the tools the 

department uses to meet the renewable energy goals. 

For our review of DOD’s plans to meet these goals in the future, we 

reviewed planning documents obtained from OSD and military service 

officials as well as planning documents from DOD officials that 

summarized DOD’s limited plans to achieve the renewable energy goals 

from fiscal year 2010 through fiscal year 2025. We also met with DOD 

officials to discuss efforts to develop a departmentwide, long-term plan to 

meet the renewable energy goals. We systematically reviewed these 

documents and interviews to determine whether DOD’s plans contained 

key elements as identified by our past work.1

 To assess the information 

systems used by the military services to manage their energy data, we met 

with officials at each of the military service headquarters with 

responsibility for managing these systems, and obtained and analyzed 

relevant documentation about these systems. We also asked energy 

managers at the military facilities we visited about their use of these 

systems. We determined that there are problems associated with the 

systems used by two of the services. Specifically, the Navy’s central Webbased data system to manage energy data has been unavailable since 

December 2007, and the Air Force’s data system is unable to manage 

renewable energy data, requiring the use of spreadsheets directly e-mailed 

from installations to Air Force headquarters. We discuss these problems in 

more detail in our findings. 

In addition to audit work described above, we also met with renewable 

energy experts at DOE’s National Laboratories, selected nongovernmental 

organizations—including the National Association of Regulatory Utility 

Commissioners and the Interstate Renewable Energy Council—and the 

 

1

GAO/GGD-10.1.16. 

Page 41 GAO-10-104 Defense Infrastructure
Appendix I: Scope and Methodology 

public utility commissions of the states where we conducted site visits. We 

also participated in DOE webcast training on alternative financing 

mechanisms for renewable energy projects and attended GovEnergy, an 

energy training workshop and exposition for federal agencies. 

We conducted this performance audit from October 2008 to November 

2009 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. 

Page 42 GAO-10-104 Defense Infrastructure
Appendix II: Comments from the Department Appendix II: Comments from the Department of Defense 

of Defense 

Page 43 GAO-10-104 Defense Infrastructure 
Appendix II: Comments from the Department 

of Defense 

Page 44 GAO-10-104 Defense Infrastructure
Appendix II: Comments from the Department 

of Defense 

Page 45 GAO-10-104 Defense Infrastructure
Appendix III: GAO

A

 Contacts and Staff 

cknowledgments 

Page 46 GAO-10-104 

Appendix III: GAO Contacts and Staff 

Acknowledgments 

Mark Gaffigan, (202) 512-3168 or gaffiganm@gao.gov

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

In addition to the contacts named above, Terrel Dorn, Director; Susan 

Irving, Director; Carol Henn, Assistant Director; Ernie Hazera, Assistant 

Director; Harold Reich, Assistant Director; John Van Schaik, Assistant 

General Counsel; Leslie Bharadwaja; Kenneth Cooper; Pamela Davidson; 

Cynthia Grant; Sarah Jones; Foster Kerrison; Ron La Due Lake; Katherine 

Lenane; Brian Mullins; Carol Shulman; Vasiliki Theodoropoulos; Jason 

Trentacoste; Christopher Turner; Cheryl Weissman; Sherie Walker; 

Michael Willems; Ignacio Yanes; and Kimberly Young made key 

contributions to this report. 

Acknowledgments 

 Defense Infrastructure 
Related GAO Products Related GAO Products 

Defense Critical Infrastructure: Actions Needed to Improve the 

Consistency, Reliability, and Usefulness of DOD’s Tier 1 Task Critical 

Asset List. GAO-09-740R. Washington, D.C.: July 17, 2009. 

Federal Energy Management: Addressing Challenges through Better 

Plans and Clarifying Greenhouse Gas Emission Measure Will Help Meet 

Long-term Goals for Buildings. GAO-08-977. Washington, D.C.: September 

30, 2008. 

Defense Management: Overarching Organizational Framework Needed 

to Guide and Oversee Energy Reduction Efforts for Military Operations. 

GAO-08-426. Washington, D.C.: March 13, 2008. 

Advanced Energy Technologies: Budget Trends and Challenges for DOE’s 

Energy R&D Program. GAO-08-556T. Washington, D.C.: March 5, 2008. 

Transmission Lines: Issues Associated with High-Voltage DirectCurrent Transmission Lines along Transportation Rights of Way. 

GAO-08-347R. Washington, D.C.: February 1, 2008. 

Advanced Energy Technologies: Key Challenges to Their Development 

and Deployment. GAO-07-550T. Washington, D.C.: February 28, 2007. 

Department of Energy: Key Challenges Remain for Developing and 

Deploying Advanced Energy Technologies to Meet Future Needs. 

GAO-07-106. Washington, D.C.: December 20, 2006. 

Renewable Energy: Increased Geothermal Development Will Depend on 

Overcoming Many Challenges. GAO-06-629. Washington, D.C.: May 24, 

2006. 

Energy Savings: Performance Contracts Offer Benefits, but Vigilance Is 

Needed to Protect Government Interests. GAO-05-340. Washington, D.C.: 

June 22, 2005. 

National Energy Policy: Inventory of Major Federal Energy Programs 

and Status of Policy Recommendations. GAO-05-379. Washington, D.C.: 

June 10, 2005. 

Meeting Energy Demand in the 21st Century: Many Challenges and Key 

Questions. GAO-05-414T. Washington, D.C.: March 16, 2005. 

Page 47 GAO-10-104 Defense Infrastructure
Related GAO Products 

Capital Financing: Partnerships and Energy Savings Performance 

Contracts Raise Budgeting and Monitoring Concerns. GAO-05-55. 

Washington, D.C.: December 16, 2004. 

Geothermal Energy: Information on the Navy’s Geothermal Program. 

GAO-04-513. Washington, D.C.: June 4, 2004. 

Budget Issues: Alternative Approaches to Finance Federal Capital. 

GAO-03-1011. Washington, D.C.: August 21, 2003. 

Agencies’ Strategic Plans Under GPRA: Key Questions to Facilitate 

Congressional Review. GAO/GGD-10.1.16. Washington, D.C.: May 1997. 

Executive Guide: Effectively Implementing the Government Performance 

and Results Act. GAO/GGD-96-118. Washington, D.C.: June 1996. 

(351274) Page 48 GAO-10-104 Defense Infrastructure
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