Military Base Realignments and Closures: Process for Reusing Property for Homeless Assistance Needs Improvements
Published: 2015-03-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The 2005 BRAC round resulted in 125 closed bases with over 73,000 acres of surplus property available. The Defense Base Closure and Realignment Act, as amended, requires DOD and HUD to assist communities in determining the best reuse of land and facilities, balancing needs of the local economy with those of homeless individuals and families.
GAO was mandated to review the extent to which DOD and HUD implemented the homeless assistance provisions while disposing of BRAC surplus property. This report addresses (1) the assistance provided as a result of BRAC 2005 and the extent to which DOD and HUD track its implementation and (2) any benefits and challenges encountered as DOD, HUD, and LRAs addressed homeless assistance provisions. GAO reviewed homeless assistance plans; interviewed DOD and HUD officials; and interviewed LRAs and homeless assistance providers from a nongeneralizable sample of 23 closed bases, selected based on size, geography, and types of assistance provided.
section_title: What GAO Found
paragraphs: A variety of homeless assistance was provided as a result of the 2005 round of base realignments and closures (BRAC), but the Departments of Defense (DOD) and Housing and Urban Development (HUD) do not require homeless assistance conveyance data to be tracked. Of the 125 large and small bases closed with surplus property, local redevelopment authorities (LRA) at 39 bases agreed to provide homeless assistance to 75 providers. If implemented, these agreements would provide nearly 50 parcels of property and over $29 million in total assistance. As of October 2014, GAO found that 27 of the 75 providers with agreements had received their property or monetary conveyances. However, DOD and HUD do not require tracking of the status of the homeless assistance conveyances. In contrast, the program administrator of the Title V homeless assistance program, which oversees conveyances for non-BRAC properties, developed policies to perform oversight in part because the government retains an interest in Title V properties. Without tracking the status of the conveyances, neither DOD nor HUD know the extent to which properties are actually being conveyed; the extent to which the providers are using the properties for their intended use; the extent to which LRAs are making sufficient efforts to find a replacement provider in the event of a provider dropping out; and ultimately the effectiveness of the homeless assistance program.
BRAC surplus property benefited homeless assistance efforts, but limited information and dedicated HUD resources contributed to challenges in the timeliness and feasibility of assistance provided. Homeless assistance providers GAO interviewed said that, among other things, the BRAC homeless assistance program provided the overall benefit of a no-cost property conveyance or financial assistance to support local homeless assistance efforts. However, LRAs and providers GAO interviewed also stated that they did not have sufficient and clear information from DOD and HUD regarding four steps of the homeless assistance process: (1) what information LRAs should give providers during property tours and workshops, (2) what information to include in providers' notices of interest about properties, (3) what information to include in developing legally binding agreements for conveying assistance, and (4) what alternatives are available to on-base property conveyances. For example, during required property tours and workshops, LRAs were unaware of what information to give and gave providers limited property condition information, which led to some providers withdrawing after they identified the cost of needed repairs. Without detailed information on these four steps, LRAs and providers may not have the knowledge necessary to make informed decisions. LRA officials also stated that they appreciated advice from HUD staff on the BRAC process. However, GAO found that HUD did not have enough resources dedicated to meet the 60-day review deadline in the BRAC statue for reviewing LRA redevelopment plans. According to HUD, two staff were assigned to review the plans, taking an average of 151 days longer than allowed to approve redevelopment plans with homeless assistance. However, HUD has not developed options to address reviewing the surge of plans in any future BRAC rounds. Without a means to ensure that needed staff resources are dedicated to HUD's review process, it will be difficult for HUD to provide reasonable assurance that the delays experienced during the BRAC 2005 round will not be repeated.
section_title: What GAO Recommends
paragraphs: GAO recommends that DOD and HUD track conveyance status and provide clear information on four steps of the homeless assistance process. HUD generally concurred, and DOD either partially concurred or did not concur with these recommendations, stating its existing guidance is sufficient. GAO believes these recommendations are still valid as discussed in the report. GAO also recommends that HUD address staff resources during a BRAC round, and HUD generally concurred.

section_title: Letter
paragraphs: A military base closure, while initially a source of local uncertainty and  challenges, also represents an opportunity for the local community to  potentially reuse the land and facilities to address community shortfalls,  including addressing the issue of homelessness. According to the  National Law Center on Homelessness and Poverty, as of October 2013  the number of Americans experiencing homelessness is estimated to be  between 1.5 million and 3.5 million in a given year. As a result of the  2005 round of base realignments and closures (BRAC), 125 closed bases  and over 73,000 acres of surplus property became available to meet the  needs of the local community for economic development, job growth,  public facilities and services, and homeless assistance. The Defense  Base Closure and Realignment Act of 1990, as amended (the BRAC  statute), requires the Departments of Defense (DOD) and Housing and  Urban Development (HUD) to take certain steps as part of the larger  BRAC process to both address the affected communities’ economic  interests in base reuse and help meet local needs for homeless  assistance. By providing homeless assistance providers with a no-cost  conveyance of surplus military property for homeless housing and  services, the 2005 BRAC round had the potential to meet some of the  urgent needs of those experiencing homelessness. If Congress should  decide to authorize a future round of BRAC, certain communities will  again potentially be faced with determining the best reuse of the land and  facilities, including balancing the needs of the local economy with those of  homeless individuals and families.
Under the BRAC statute, local redevelopment authorities (LRA), DOD,  and HUD have key roles in the BRAC homeless assistance process. The  LRA for each base approved for closure typically prepares a  redevelopment plan after consulting with representatives of the homeless  and other community groups affected by the base closure. DOD  determines the surplus property available for redevelopment and  homeless assistance, provides the LRAs with guidance on the planning  process, and ultimately conveys the surplus property. Meanwhile, HUD  evaluates the redevelopment plans to assess whether they appropriately  balance the needs of the community for economic and other development  with the needs of the homeless by reviewing and approving  redevelopment plans.
Since 2005, we have issued over 30 reports and testimonies on BRAC  2005 planning, implementation, costs, and savings that highlight  information DOD can use to improve the BRAC recommendation  development and implementation process. In a May 2013 report on  providing communities additional information to improve their ability to  adjust to base closures, we found that an expectations gap existed  between the Army and communities regarding the levels of maintenance  to be provided to facilities during the transition period between the Army’s  maintenance of the base and the transfer to the community. For example,  an official with the Army BRAC office told us that in fiscal year 2013 the  Army provided $49 million in caretaker funds for installations closed  during BRAC 2005; however, the official further stated that the LRAs  would like the buildings to be in new condition, which was not a realistic  expectation. We recommended, among other things, that the Army issue  guidance on specific levels of maintenance to be followed in the event of  a BRAC closure based on the probable reuse of the facilities.concurred with our recommendation. While there have been no additional  base closures since May 2013, in June 2014 DOD told us that the Army  agreed to publish property-maintenance guidance prior to closing  installations in the event of future base closures.
We have also issued numerous reports evaluating the effectiveness of  federal programs in meeting the housing and supportive-service needs of  those experiencing homelessness. In September 2014, we issued a  report reviewing implementation of Title V of the McKinney-Vento   which requires federal landholding agencies— Homeless Assistance Act, excluding DOD for the purposes of the BRAC 1995 and 2005 rounds—to  identify unused federal real property and make it available to homeless  assistance providers.identified challenges with the Title V homeless assistance program, such  as locating information on available properties and a complex application.  We recommended, among other things, that HUD and other Title V  homeless assistance program administrators address the challenges that  homeless assistance providers face by developing a web-based source of  information on the program. HUD concurred and noted that it had already  proposed legislative changes to create a web-based source of information  on available properties, although we reiterated that our recommendation  was not contingent upon legislative changes. The Related GAO Products  page at the end of this report provides a listing of our BRAC and  homeless assistance reports and testimonies.
We found that homeless assistance providers  In its report accompanying a bill for the National Defense Authorization  Act for Fiscal Year 2015, the House Armed Services Committee  mandated that we review the extent to which DOD and HUD effectively  implemented the homeless assistance provisions while disposing of  BRAC surplus property. This report addresses (1) the types of  assistance provided to homeless assistance providers as a result of  BRAC 2005 and the extent to which DOD and HUD track implementation  of the agreements reached, and (2) any benefits and challenges  encountered as DOD, HUD, and the LRAs addressed provisions for  homeless assistance as a result of BRAC 2005.
To determine the types of assistance provided to homeless assistance  providers, we collected data on all 125 bases with surplus property closed  as a result of BRAC 2005. To identify the number of bases that received  notices of interest from homeless assistance providers, two analysts  independently reviewed an internal HUD document used to track the  BRAC 2005 homeless assistance process, reviewed all redevelopment  plans for those entries in the HUD tracking document that indicated  notices of interest were submitted, and reconciled our analysis  accordingly. For those 51 LRAs that we determined had received interest  from homeless assistance providers, we identified and analyzed  information from the LRAs’ homeless assistance submissions as part of  their redevelopment plans to HUD. Specifically, we identified and  analyzed data describing the number of notices of interest received, the  number and types of properties agreed to be given to the homeless  assistance providers, and the number and description of the conveyances  of property or money that have occurred. We also analyzed the  redevelopment plans to determine reasons why some notices of interest  were not approved. Additionally, for each base with approved  conveyances, we collected data as of October 2014 from DOD, the LRAs,  and homeless assistance providers about the types and status of  properties or money conveyed. We interviewed cognizant HUD officials  regarding data reliability, including the data’s completeness and accuracy,  to help ensure that HUD’s data were sufficiently reliable for our report.  After assessing the data, we determined that the data were sufficiently  reliable for the purposes of determining the types of assistance provided  to homeless assistance providers. To evaluate the extent to which DOD  and HUD tracked implementation of the agreements, we interviewed  DOD and HUD officials regarding their roles in tracking the assistance  provided to homeless assistance providers and compared these roles to  criteria for management control activities in Standards for Internal Control  in the Federal Government. We also reviewed the tracking requirements  for the Title V homeless assistance program to determine whether any  applicable comparisons could be made to the tracking requirements for  the BRAC homeless assistance program.
To evaluate the benefits and challenges encountered as DOD, HUD, and  the LRAs addressed provisions for homeless assistance, we collected  documentary and testimonial evidence through a two-part approach. First,  we collected data from the redevelopment plans from the 51 LRAs that  received notices of interest from homeless assistance providers.  Specifically, we identified requests for extensions and completion dates  for required process steps, such as the homeless assistance submission  to HUD and approval by HUD. We then analyzed these data to compare  the actual timelines to the required timelines in the BRAC statute and  regulations. We also interviewed cognizant HUD officials regarding data  reliability, including about the data’s completeness and accuracy, to help  ensure that HUD’s data were sufficiently reliable for our report. After  assessing the data, we determined that the data were sufficiently reliable  for the purposes of evaluating the challenges encountered in addressing  the homeless assistance provisions. Second, to gather in-depth  information from a sample of the bases with surplus property closed as a  result of BRAC 2005, we conducted interviews regarding benefits and  challenges of the homeless assistance process with the LRAs, homeless  assistance providers, HUD field office representatives, and project  managers from the military departments and DOD’s Office of Economic  Adjustment—DOD’s primary source of assisting communities affected by  BRAC—from 23 closed bases. We visited 11 of these sites in four  locations—Georgia, New Jersey, Pennsylvania, and California—and we  contacted the other 12 sites via phone. We selected bases to contact to  reflect a range in number of homeless notices of interest received, size,  geographical representation, types of homeless assistance conveyance  provided, and to include representation from each military service.  Ultimately, we contacted 12 bases that received notices of interest and  implemented homeless assistance, 9 bases that received notices of  interest and did not implement homeless assistance, and 2 bases that did  not receive notices of interest. These interviews provided examples of  benefits and challenges faced by each individual party, but information  obtained is not generalizable to all parties involved in the homeless  assistance process. Further, we compared information about the  challenges cited with criteria for information and communications in  Standards for Internal Control in the Federal Government.about our scope and methodology are included in appendix I.
We conducted this performance audit from April 2014 to March 2015 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.
subsections: section_title: Background
subsections: section_title: Key Participants and Procedures of the BRAC Homeless Assistance Process
paragraphs: The Base Closure Community Redevelopment and Homeless Assistance  Act of 1994 (Redevelopment Act), which amended the BRAC statute,  established the homeless assistance process for properties on military  bases approved for closure after October 25, 1994. The key participants  in the current process include DOD’s Office of Economic Adjustment, the  military departments, HUD, the LRAs, and the homeless assistance  providers. Because DOD and HUD both have significant roles under the  BRAC statute, they jointly promulgated the regulations governing BRAC  homeless assistance. As a result, DOD and HUD collaborate in providing  guidance on the BRAC homeless assistance process.
DOD Office of Economic Adjustment. Within DOD, the Office of  Economic Adjustment—a field activity under the Office of the Under  Secretary of Defense for Acquisition, Technology, and Logistics— assists communities by providing technical and financial assistance in  planning and carrying out adjustment strategies in response to  significant defense actions including base closures. The Office of  Economic Adjustment has been delegated authority by the Secretary  of Defense to recognize the LRA for each base closed under BRAC. It  also provides planning-grant funds to those LRAs for which it  determines base closure will cause direct and significant adverse  consequences. An Office of Economic Adjustment project manager is  to be assigned to each of these bases as a facilitator and catalyst to  the community’s planning process.
Military Departments. The Secretary of Defense delegated to the  Secretaries of the military departments—Army, Navy, and Air Force— the disposal authority for bases closed under BRAC, including the  authority to manage surplus-property disposals such as homeless  assistance conveyances. Each military department assigns a project  manager to its bases closed under BRAC.
HUD. At HUD headquarters, the Office of Community Planning and  Development, Office of Special Needs Assistance Programs, carries  out HUD’s BRAC process responsibilities. HUD field offices provide  technical assistance to LRAs and homeless assistance providers  throughout the planning process. HUD’s role is to review the  redevelopment plan and homeless assistance submission that the  LRA submits to HUD and DOD. HUD may also negotiate and consult  with the LRA before or during its preparation of its plan.
LRAs. The LRA is any authority or instrumentality established by  state or local government and recognized by the Secretary of Defense  through the Office of Economic Adjustment as the entity responsible  for developing the redevelopment plan or for directing implementation  of the redevelopment plan. LRAs are required to perform certain steps  to allow the community input during its deliberations. The communities  in the vicinity of a base are defined by BRAC regulation as the political  jurisdiction or jurisdictions, other than the state, that include the LRA  for the base.
Homeless assistance providers. Homeless assistance providers,  also called “representatives of the homeless,” may include state or  local government agencies or private nonprofit organizations that  provide or propose to provide assistance to homeless persons and  families. Homeless assistance providers seek buildings and properties  that may provide supportive services, job and skills training,  employment programs, shelter, transitional housing, permanent  housing, food and clothing banks, treatment facilities, or other  activities that meet an identified need of the homeless or fill a gap in  the local Continuum of Care.
Under the BRAC statute as revised by the Redevelopment Act and its  implementing regulations, LRAs are required to accept and consider  notices of interest from homeless assistance providers. In this process,  the LRA prepares a redevelopment plan after consulting with homeless  assistance providers and other community groups affected by the base  closure, and HUD assesses the plan to determine whether it appropriately  balances the needs of the community for economic and other  development with the needs of the homeless. Subsequent to HUD  approval and other procedural steps, DOD may transfer properties for  homeless assistance purposes. Figure 1 shows the homeless assistance  process for BRAC surplus property under the Redevelopment Act.
Pursuant to the BRAC statute as amended by the Redevelopment Act,  the military departments are required to determine whether other DOD  components or federal agencies have a use for property at the BRAC  base, then notify the LRAs of any surplus property available for reuse and  publish that information in the Federal Register. The LRA then must  advertise the surplus property availability in a newspaper of general  circulation within the vicinity of the base. The advertisement must include  the period, required to be between 90 and 180 days following the  advertisement, during which it will receive notices of interest from  homeless assistance providers. The LRA must also conduct outreach  with homeless assistance providers, including holding a workshop and  tour of the properties. When the LRA completes its outreach process, it  has up to 270 days to generate a redevelopment plan and a homeless  assistance submission. The LRA must consider the notices of interest  and determine which, if any, to support with some combination of  buildings, property, or funding. If the LRA decides to support a notice of  interest, it develops legally binding agreements to implement no-cost  homeless assistance, which may differ substantially from the initial notice.  The LRA then submits these agreements as part of the homeless  assistance submission to HUD and the military department. If HUD  approves the base redevelopment plan, including the homeless  assistance submission, it will notify the LRA and the military department.  The military department—which during the redevelopment planning  conducts an environmental impact analysis of the base prior to disposal— is required to give the redevelopment plan, including the homeless  assistance recommendations, substantial deference in making property  disposal decisions. Once the military department completes its  environmental impact analysis and makes its record of decision, it  transfers surplus buildings and properties in accordance with the record  of decision, and may transfer properties for homeless assistance either to  the LRA or directly to the homeless assistance providers.
section_title: Types of Homeless Assistance Available through the BRAC Process
paragraphs: Pursuant to the BRAC statute and its implementing regulations, LRAs  may convey to homeless assistance providers on-base property or  buildings, off-base property or buildings, or funding in lieu of property. An  on-base conveyance may include undeveloped land, buildings to be  demolished in order to develop new structures, or entire buildings or  space within a building to provide assistance to those experiencing  homelessness. Such conveyances must be for no cost. Additionally, the  legally binding agreements must include a provision that, if a homeless  assistance provider ceases to provide services to the homeless, the  property will revert to the LRA. If this were to occur, the LRA must take  appropriate action to secure, to the maximum extent practicable, another  qualified homeless assistance provider to use the property to assist the  homeless. If the LRA is unable to find a qualified provider to use the  property, it will own the property without any further requirement to use  the property to assist the homeless.
As part of the planning process, the LRA may propose alternative  properties off base or financial assistance if those options would be more  compatible with the LRA’s proposed redevelopment plan for the base.  Off-base properties or buildings may include undeveloped land or excess  buildings owned by the local government. Funding may originate from  bonds, a percentage of sales from on-base property to private  developers, or through the issuance of forgivable loans, among other  options. In these cases where the LRA is providing off-base property or  funding, the legally binding agreements do not need to include a provision  that the conveyance revert to the LRA if a homeless assistance provider  ceases to provide services to the homeless.
section_title: A Variety of Homeless Assistance Was Provided through BRAC 2005, but DOD and HUD Do Not Require Conveyance Data to Be Tracked after Agreements Are Reached
paragraphs: Thirty-nine of the 125 bases closed as a result of BRAC 2005 that had  surplus property provided a variety of homeless assistance in response to  notices of interest submitted by homeless assistance providers. An  additional 12 bases’ LRAs received notices of interest that did not result  in a legally binding agreement, the reasons for which varied. However,  neither HUD nor DOD require that the status of conveyances be tracked  after legally binding agreements are reached, which limits the  departments’ ability to assess the homeless assistance program’s  effectiveness.
subsections: section_title: Thirty-Nine Bases’ LRAs Agreed to Provide Homeless Assistance to 75 Providers as a Result of BRAC 2005
paragraphs: Of the 125 bases with surplus property closed during BRAC 2005, 39  received notices of interest from homeless assistance providers that were  approved for assistance with 75 homeless assistance providers, 12 bases  received notices of interest that did not result in any assistance, and 74   Figure 2 shows the geographic  bases received no notices of interest.distribution of the properties.
The 39 bases’ LRAs that provided assistance did so in a variety of ways,  as seen in figure 3, below.
On-Base Property. Twenty-two bases’ LRAs provided assistance  through on-base property conveyances, granting specific existing  property to homeless assistance providers. This property included  nearly 50 parcels of both vacated military surplus buildings and plots  of undeveloped land. For instance, at General Mitchell Air Reserve  Station in Milwaukee, Wisconsin, a homeless assistance provider  requested a 56,000 square foot warehouse on the base for  emergency food storage and office space. The provider was selected  to receive homeless assistance and HUD approved the  redevelopment plan in December 2008. The warehouse was  conveyed to the provider in July 2010.
Off-Base Property. Three bases’ LRAs provided assistance through  off-base property conveyances, granting either a specific existing  building, a new building to be constructed, or a piece of undeveloped  land at a location that was not part of the former base. For example,  according to the homeless assistance provider, the LRA at the  Schroeder Hall U.S. Army Reserve Center in Long Beach, California,  granted a 10-year no-cost lease of off-base property to the provider,  with an option to purchase the property for a nominal fee at the  conclusion of the lease. The site is located near the former base, and  will house a psychiatric clinic for mentally ill people experiencing  homelessness.
Funding. Seven bases’ LRAs provided assistance through funding.
The assistance provided totaled over $29 million. The amount  provided ranged from $4,000 at Marshall U.S. Army Reserve Center  in Marshall, Texas, for providing supportive services and temporary  homeless housing assistance to $9.5 million at Fort McPherson in  Atlanta, Georgia, for the construction and operation of 125 units of  permanent supportive housing offsite.
A combination of different types of assistance. Seven bases’  LRAs provided assistance through a combination of on-base property,  off-base property, or funding. For example, the LRA at Truman Olson  U.S. Army Reserve Center in Madison, Wisconsin, offered one  provider off-base property and two providers funding of up to  $410,000 in forgivable loans.
Notices of interest requesting property in BRAC 2005 were submitted by  150 homeless assistance providers, 75 of whom negotiated a legally  binding agreement for assistance. Those that negotiated an agreement  were to receive on-base property, off-base property, funding, or a  combination, as seen in figure 4.
According to our analysis of the notices of interest and legally binding  agreements, of the 75 providers that negotiated an agreement, 44  providers (59 percent) negotiated legally binding agreements that  matched their initial notice of interest, whereas 31 providers (41 percent)  negotiated an agreement that differed from their initial notice. For  example, a homeless assistance provider submitted a notice of interest  requesting one of three specific on-base buildings at Fort Monmouth,  New Jersey. The LRA accepted the notice of interest and offered the  provider alternative on-base buildings. However, according to the  provider, these alternative buildings differed from the three that the  provider requested in the notice of interest and were not suitable for the  provider’s intended use. The provider was then offered funding in lieu of  on-base property, which the provider accepted. Table 1 provides an  example of three different types of outcomes that occurred between  assistance requested and that to be received by homeless assistance  providers.
section_title: Reasons Varied When No Legally Binding Agreement Was Reached
paragraphs: Of the 75 providers that submitted notices of interest for a homeless  assistance conveyance but did not ultimately sign a legally binding  agreement, we found six common reasons why the notices were not  approved. These reasons—identified by the LRAs in the homeless  assistance submissions and subsequently summarized by HUD in each  base’s memorandum of decision—included:
Organizational Capacity. Under BRAC regulations, providers are  required to submit, among other things, “a description of the financial  plan, the organization, and the organizational capacity of the  representative of the homeless to carry out the program.” Some  providers lacked organizational capacity to carry out their proposed  program. For instance, at Cambridge Memorial U.S. Army Reserve  Center in Cambridge, Minnesota, a provider submitted a notice of  interest seeking to construct 16 on-site housing units. However, the  provider stated that it could not afford to begin construction without a  large grant from the City of Cambridge. The city was unable to finance  such a large grant, so the LRA rejected the provider on the basis that  it lacked the organizational capacity to implement its proposal. HUD  concurred with the LRA’s determination in the memorandum of  decision.
Withdrawn by Provider. The provider may unilaterally withdraw from  the process at any time, even after it has been selected by the LRA to  receive assistance. For example, at Finnell U.S. Army Reserve Center  / Army Maintenance Support Activity 51 in Tuscaloosa, Alabama, a  consortium of homeless assistance providers submitted a notice of  interest to use the entire on-site property for social services, meeting  facilities, and apartment buildings for transitional housing. However,  because the LRA offered part of the requested property and the  providers were unsure of how they would get funding for the  development and ongoing maintenance of that offered property, the  consortium told us it withdrew its notice. Instead, the Army stated it is  in discussion with the City of Tuscaloosa for potential negotiated sale.
Ineligible for Homeless Assistance. BRAC regulation also requires  providers to demonstrate that their proposals describe the uses to  which the property will be put, which must involve specific homeless  assistance activities or other activities that will “meet an identified  need of the homeless.” Not all provider proposals addressed this  requirement. For instance, at Schroeder Hall U.S. Army Reserve  Center in Long Beach, California, a provider proposed the  construction of 100 units of low-income housing. The LRA concluded  that the proposal was focused on low-income families rather than  people currently experiencing homelessness and rejected the  proposal. HUD concurred in the memorandum of decision.
Redundancy. Under BRAC regulations, an LRA must provide an  explanation of why it rejected a particular notice of interest and a  description of the impact of the proposed homeless assistance  program on the community. The most common reason cited by the LRAs was that the group the provider hoped to assist was already  being accommodated by other providers in the area, and that further  redundancy of services could have a negative effect on the  community. For instance, at Fort McPherson in Atlanta, Georgia, a  provider submitted a notice of interest proposing the on-base  development of 200 units of supportive housing and associated  services. Although both the LRA and HUD determined that the  proposal was viable, there were already a number of supportive  housing projects being accommodated as part of the redevelopment.  To avoid overconcentration of supportive housing in the area of the  former base, the LRA rejected the proposal, and HUD concurred.
Incomplete Plan. Providers rejected for incomplete plans either failed  to include required information in their notices of interest or failed to  respond to HUD or LRA requests to provide this information after the  initial notices had been submitted. For instance, at Walter Reed Army  Medical Center in Washington, D.C., a provider submitted a notice of  interest requesting emergency, transitional, and permanent housing  but failed to include required documents. The LRA requested more  information, but the provider did not respond and thus the LRA  rejected the proposal. HUD concurred in the memorandum of  decision.
Unsuitable Site. The LRA may determine that the site selected by the  provider would not be fit for the plan proposed. For instance, at  Germantown Memorial U.S. Army Reserve Center in Philadelphia,  Pennsylvania, a provider proposed renovating several on-site surplus  buildings to create 48 units of permanent housing for homeless  seniors. The LRA cited several reasons in its rejection of the proposal,  including that the provider had proposed housing seniors in the  organizational maintenance shop and that the site suffered from  hazardous waste contamination, sinkholes, and poor drainage,  rendering the former base unfit for human habitation. HUD concurred  with the LRA’s reasoning.
Table 2 illustrates reasons that providers’ notices of interest did not result  in legally binding agreements as well as the frequency for each reason.
In five cases, providers withdrew their notices of interest but received  property, funds, or other assistance from the LRA outside of the BRAC  process. For instance, at Waukegan Armed Forces Reserve Center in  Waukegan, Illinois, we were told by a homeless assistance provider that it  had withdrawn from the process in exchange for 15 units of city property  at a different site, to be conveyed by 2015. According to the provider, it  signed a memorandum of understanding with the LRA. Because the  exchange happened outside of the official BRAC process, HUD did not  review the memorandum of understanding or comment on the  arrangement. This arrangement allowed the provider to circumvent the  HUD review, which, according to the LRA, allowed greater flexibility in the  makeup of the plan and also the timing of the property conveyance.  However, because this arrangement is not subject to HUD review, the  provider may not have legal recourse if the arrangement falls through  unless a binding agreement was signed by both parties. HUD officials  agreed that these five cases of provider withdrawal would not be recorded  as assistance officially provided under the BRAC homeless assistance  process, although they added that the existence of the BRAC homeless  assistance process is what allowed the providers to negotiate with the  LRA.
section_title: Neither HUD nor DOD Requires Tracking of the Long-Term Status of Homeless Assistance Conveyances
paragraphs: We found that neither HUD nor DOD requires tracking of the long-term  conveyance status of those properties that were awarded through legally  binding agreements to determine the effectiveness of the program.  Through our analysis of data collected from DOD, LRAs, and homeless  assistance providers, we found that as of October 2014, 27 of the 75  providers with legally binding agreements have received their homeless  assistance conveyance.
According to a HUD general counsel official, HUD has no oversight over  the homeless assistance program after it approves the redevelopment  plans. Consequently, HUD does not know whether providers are  receiving different assistance than what was approved in the  redevelopment plan. For example, HUD approved a legally binding  agreement at Fort Monmouth, New Jersey, in which a provider was to  receive an emergency shelter on-base, but instead the provider told us it  is going to receive a smaller shelter off-base. HUD also does not know  whether providers are using the conveyed properties as stated in their  plans. For example, a provider we spoke with stated that because the  types of homeless assistance grants and funding options have changed  since it submitted its notice of interest in 2006, it would have to change  the services identified in its original plan to get funding. According to HUD  officials, the LRAs have incentives to ensure that the homeless  assistance providers adhere to the agreed-upon plans, because the  property can revert to the LRA at no cost if the provider does not follow  the terms of the legally binding agreement. However, once HUD approves  a homeless assistance submission, it has no further contact with that  LRA. HUD has no mechanism for recording whether the property was  conveyed under the terms approved in the homeless assistance  submission, or whether the property was conveyed at all. Moreover, we  found instances where a provider that signed a legally binding agreement  for a conveyance withdrew from the process before homeless assistance  could be provided. For example, we spoke to a provider with an  agreement for 39 units of supportive housing that chose to withdraw prior  to receiving the property. While the BRAC statute requires LRAs to take  actions to try to secure another provider to take over, HUD does not track  whether this happens.
Moreover, DOD officials told us they also do not have oversight over the  properties after conveyance to homeless assistance providers, adding  that, in their view, this does not fall under DOD’s responsibilities.  According to the officials, the BRAC homeless assistance process was  designed for DOD to dispose of the property and then be removed from  the process. However, until DOD conveys the property either directly to  the homeless assistance provider or to the LRA to then convey to the  providers, DOD officials stated that they might be in the best position to  know the status of the conveyances and share that information with HUD.  Additionally, DOD’s Office of Economic Adjustment and the military  services already assign project managers to communicate with and  provide advice to LRAs. As part of their duties, DOD officials stated that  these project managers could periodically relay information on the closure  back to HUD, including the conveyance status of the property.
Neither HUD nor DOD’s jointly issued BRAC regulations include specific  requirements to track the long-term status of BRAC homeless assistance  conveyances. While the BRAC statute does not require that the data be  tracked, it also does not prohibit it. However, tracking this information  would conform with recommended and accepted government practices.  Standards for Internal Control in the Federal Government states that  managers are responsible for providing reliable, useful, and timely  information for transparency and accountability of programs and their  operations. In addition, the Title V homeless assistance program tracks  long-term conveyance status information. Similar to the BRAC statute, the  statute establishing the Title V homeless assistance program also does  not require or prohibit the tracking of federal buildings and property given  to assist the homeless. However, unlike the BRAC homeless assistance  process, under the Title V homeless assistance program the program  administrator (Department of Health and Human Services) developed  policies and procedures to perform compliance oversight and to ensure  that the provider uses the property according to the terms in the approved  application, in part because if a provider is not implementing or is unable  to implement the program consistent with the approved application, the  property title may revert back to the federal government. To accomplish  this oversight, providers are required to submit annual utilization reports,  and the Department of Health and Human Services is to conduct site  visits of the properties at least once every 5 years. Although the Title V  program differs from the BRAC program because of the federal  government’s reversionary interest in homeless assistance property,officials from HUD stated that HUD and DOD could use Title V program  oversight as a model, and added that it would be a good idea for HUD  and DOD to know whether the property ultimately is used for homeless  assistance. HUD officials also stated that the homeless assistance  program could be improved if HUD was required to track data over time  regarding the status of the conveyances. DOD officials added that the  military services track and could share with HUD the status of properties  not yet conveyed or directly conveyed from DOD to the homeless  assistance provider. However, the DOD officials stated they do not know  the status of the properties once conveyed, at which point it would be  more efficient for the LRAs to directly report to HUD.
By not requiring the tracking of the status of homeless assistance  conveyances, neither HUD or DOD know the effectiveness of the  program, to what extent properties are actually being conveyed to the  homeless assistance providers, the extent to which the providers are  using the properties for their intended use and, in the event of a provider  dropping out, the extent to which LRAs are making sufficient efforts to find  a replacement provider. Without these data, DOD and HUD lack insight  into the effectiveness of the homeless assistance program. In addition,  they remain unable to identify additional areas to consider in reviewing  redevelopment plans or adjustments that may be needed in processes or  procedures in the future should additional BRAC rounds take place.
section_title: BRAC Surplus Property Benefited Homeless Assistance Efforts, but Limited Information and Number of Dedicated HUD Resources Hampered the Timeliness and Feasibility of Assistance Provided
paragraphs: The process for conveying BRAC surplus property increased the potential  for addressing homelessness in communities. However, we found that  insufficient and unclear information added to the length of time it took the  various parties to complete the necessary documentation and reviews  and jeopardized the overall success of the program by potentially limiting  participation in the process or by creating unfulfilled expectations for the  program participants. Furthermore, while homeless assistance providers  and LRA officials stated that they appreciated the advice they received  from HUD headquarters staff, there was a backlog and delays in  reviewing redevelopment plans due to the small size of the HUD review  team.
subsections: section_title: Local Providers Cited Benefits of the BRAC Homeless Assistance Process
paragraphs: Homeless assistance providers told us that the BRAC homeless  assistance program provided the overall benefit of a no-cost property  conveyance or financial assistance to support local homeless assistance  efforts, and at 11 of the 12 bases we contacted where homeless  assistance providers received assistance, providers shared other  perspectives on why they thought the program was beneficial. For  example, some providers said that the BRAC homeless assistance  process elevated awareness of homelessness issues for those making  the decisions concerning the conveyance of BRAC surplus property.  Other providers said they may not have had access to this type of no-cost  conveyance without the BRAC process putting them as a lead contender  for the property.
Although some communities worked with homeless assistance providers  before the BRAC homeless assistance process began, providers also  mentioned that the opportunity for homeless assistance providers to  receive property through this process created an additional forum for the  community to discuss the needs of the homeless and identify ways to  address those needs with the identified surplus property. For example, at  the Inspector/Instructor Facility at West Trenton Marine Corps Reserve  Center, New Jersey, LRA and homeless assistance officials engaged in  ongoing negotiations about the future use of the property. LRA officials  said they initially rejected the provider’s notice of interest, but because of  the BRAC homeless assistance process, HUD ultimately awarded the  property to the provider. The provider told us that the property is being  renovated to provide housing in the main building, as shown in figure 5.  The provider also said future renovations will include room to make  ancillary services available on site for those experiencing homelessness,  such as a diaper bank that will provide diapers, wipes, and other infant  supplies and an auto-maintenance job-training facility.
We also found examples where homeless assistance providers worked  together in consortiums to improve their chances of receiving homeless  assistance in the BRAC process. In our analysis of HUD homeless  assistance decision documents, we found examples at 17 of 51 bases  where homeless assistance providers formed consortiums to pool their  resources to express interest in the property as well as coordinate their  service efforts to assist those experiencing homelessness. For instance,  at one base we visited, six providers formed a consortium to expedite  timelines by having one review schedule and a single representative to  coordinate with the LRA. Further, officials told us that the consortium  brought together providers with varied expertise in the homeless  assistance process, including providers with homeless assistance and  property-development experience.
Officials from LRAs and homeless assistance providers also told us that  the flexibility of LRAs to offer various types of assistance to homeless  assistance providers—the conveyance of on-base property, an alternative  off-base site, money in lieu of property, or some combination thereof— allowed for assistance options that might be a better fit than conveyance  of the BRAC site in some circumstances, as explained in the following  examples.
Onizuka Air Force Base, California: According to an LRA official, two  notices of interest were initially rejected because they requested a no- cost property conveyance for not only homeless housing but also  affordable housing, which is not allowed under BRAC statute. Those  providers whose notices of interest were rejected also told us that  because the base was so far from public transportation and other  resources, the proposed project might not be eligible for tax credits  and other financial assistance needed to complete the project. Rather  than awarding on-base property, the LRA stated it sold an alternative  property to the providers and awarded them $8.2 million in local  housing funds to assist with land and construction costs. One provider  said construction for its portion of the site is under way, as shown in  figure 6, and the other provider said it planned to start construction by  the end of 2014.
George L. Richey U.S. Army Reserve Center, California: According to  officials from the LRA, one notice of interest was initially rejected  because it included a request for a no-cost property conveyance to be  used for both affordable and homeless housing. Although the site is  close to public transportation, LRA officials said that the site is located  in an industrial area, where groceries, clinics, and other social  services might not be as accessible to those receiving assistance.  Given the center’s proximity to the county jail and another law- enforcement office, LRA officials said they provided a public benefit  conveyance to the Santa Clara Sherriff’s office for use as an  emergency- response training and readiness center, as shown in  figure 7. In exchange, LRA officials told us that they offered to sell the  homeless assistance provider an alternate site and provide a  forgivable loan of $1,590,000, with the caveat that a certain  percentage of the planned units be reserved specifically for homeless  housing. Officials from the homeless assistance provider and the LRA  told us that as of September 2014, the details of the off-base proposal  continue to be negotiated.
Fort Gillem, Georgia: According to an LRA official, two providers  combined their proposal for on-base property. The official told us that  one provider decided it lacked the capacity to support building a new  shelter, and the other provider opted to support the other providers’  homeless efforts in lieu of building a new shelter itself. After both  groups’ interest in the on-base location waned, the official said that  the LRA offered an alternative to both providers that would include the  transfer of $900,000 from the eventual sale of Fort Gillem to support  building a new, larger shelter adjacent to one provider’s existing  facility that would be operated jointly by both providers. Providers said  they planned to start construction by the end of 2014.
section_title: Homeless Assistance Providers and LRAs Said They Did Not Have Sufficient and Clear Information and Guidance about the BRAC Homeless Assistance Process
paragraphs: LRAs and homeless assistance providers we spoke with told us they did  not have sufficient and clear information and guidance at several steps in  the BRAC homeless assistance process. We found that a lack of  sufficient and clear information added to the length of time it took the  various parties to complete the necessary documentation to move the  process forward and jeopardized the success of the program by limiting  participation or by creating unfulfilled expectations for the program  participants. According to Standards for Internal Control in the Federal  Government, information should be communicated in a form and within a  time frame that enables personnel to carry out their responsibilities  efficiently.steps of the BRAC homeless assistance process.
Specifically, we found limited information in the following four
HUD and DOD guidance to the LRAs does not clearly specify what  information the LRAs should provide to homeless assistance  providers on the condition of the property while conducting workshops  and tours to help providers develop their notices of interest.
HUD and DOD guidance provided to homeless assistance providers  is not clear on what information is necessary to include in completing  their notices of interest.
HUD and DOD guidance provided to the LRAs does not provide  sufficient detail on what information needs to be included in  developing their legally binding agreements.
HUD and DOD guidance to the LRAs is not clear on the various  alternatives available to homeless assistance providers instead of on- base property conveyances.
First, during required workshops and property tours, providers said that  LRAs gave limited information to them on the condition of the property.  According to homeless assistance providers and LRA officials we  interviewed, some BRAC properties were in need of repairs, such as  utility upgrades and hazardous-material remediation, to comply with the  most recent building codes and to make them appropriate for homeless  assistance reuse (see fig. 8). For instance, HUD and DOD regulations  require that LRAs must conduct at least one workshop where homeless  assistance providers have an opportunity to, among other things, tour the  buildings and properties available either on or off the base. However,  we found that the level of detail and property access that LRAs granted to  providers varied. As a result, some providers withdrew from the process  after they obtained more information about the condition of the property  and determined it was no longer a feasible project. For example, one  homeless assistance provider told us she was not allowed to leave the  bus during the property tour and was unable to physically inspect the  premises prior to submitting a notice of interest. Another told us she was  not allowed to inspect the property until after the legally binding  agreement was drafted. After identifying the needed repairs, including  utility updates and addressing Americans with Disabilities Act  requirements, the provider said she eventually pulled out of the  agreement due to the cost and extent of rehabilitation needed. Some  homeless assistance providers we interviewed suggested that details on  what and when property condition information will be provided, such as  sharing it on a website, might be helpful.
According to DOD officials, the properties may have been inhabited by  military personnel during the time of the tours and thus could not be  physically inspected. Additionally, the LRAs might not have completed a  facilities survey or infrastructure inspection to provide property information  by the time the tours for providers were held. However, the DOD officials  stated that it was important for the providers to receive additional  information about the property condition so that they could make an  educated decision regarding submitting a notice of interest or signing a  legally binding agreement. Additionally, LRA officials at one base we  contacted said it would have been helpful to have known more about the  property condition earlier in the process to better evaluate how those  details could affect the overall redevelopment plan.
Second, homeless assistance providers said that they did not receive  clear information on the full extent of what to include in their notices of  interest, which contributed to providers being removed from consideration  for BRAC homeless assistance properties as well as LRAs being granted  extensions to submit redevelopment plans to HUD. HUD and DOD  regulations require that notices of interest describe (1) the proposed  homeless assistance program and supportive services to be provided on  the property such as job and skills training, employment programs,  shelters, transitional housing, or treatment facilities; (2) the need for the  program; (3) the extent to which the program is or will be coordinated with  other homeless assistance programs in the communities in the vicinity of  the base; (4) information about the physical requirements necessary to  carry out the program, including a description of the buildings and  property at the base that are necessary to carry out the program; (5) the  financial plan, the organization, and the organizational capacity of the  homeless assistance provider to carry out the program; and (6) an  assessment of the time required to start carrying out the program.
These regulations on notices of interest notwithstanding, among the 75  providers whose notices of interest were rejected, we identified 17  examples where the LRA and HUD agreed that the notices of interest  were incomplete and providers said they needed more shared and  specific guidance on what to include. While the regulations provide  general information about what should be included, not all participants in  the BRAC process were aware of the regulations. For example, a  provider that submitted a notice of interest for property at Fort McPherson  told us that it did not receive any additional guidance on what to include.  Instead, the provider stated that the lack of guidance and familiarity with  the regulations led it to look for alternative guidance and found an online  example of a notice of interest from another base closure in Philadelphia.  Some providers suggested that a template or additional examples of  notices of interest would have provided clarity. Other times, HUD officials  told us that the LRAs would ask that notices include much more than was  required by the regulations, such as a list of all homeless assistance  programs conducted and audited financial statements for the previous 5  years, which made it more difficult for providers to submit complete  notices of interest. For example, one notice of interest for Walter Reed  Army Medical Center lacked information regarding the number of units,  the supportive services to be offered, and financing for the project. HUD  officials stated that a template on notices of interest might make it easier  for providers to know what was required to be included and help prevent  confusion concerning LRA requests for additional information that is not  required.
LRA officials said they often requested additional time for providers to  submit supplementary information to complete the notices of interest. We  found that 88 percent of LRAs (45 out of 51) requested extensions from  the Office of Economic Adjustment to submit their redevelopment plan to  HUD, and some requested multiple extensions (see fig. 9). According to  HUD and DOD regulations, LRAs have 270 days after the deadline for  receipt of notices of interest to submit their redevelopment plans to HUD.  However, the extensions resulted in LRAs taking an average of 654 days  to submit their redevelopment plans. HUD officials agreed that these  extensions further delayed the HUD review process and conveyance of  homeless assistance.
Third, we found that HUD guidance and regulations did not provide  detailed information to LRAs and homeless assistance providers on the  acceptable terms of legally binding agreements. In addition, although  BRAC homeless assistance regulations provide a few specific  requirements for legally binding agreements, they do not provide detailed  guidance on what terms will constitute an acceptable agreement under  the process. For example, the regulations require legally binding  agreements to include a process for negotiating alternative arrangements  for homeless assistance in the event environmental analysis deems the  property unsuitable for its intended use, and also require the inclusion of  a reverter clause whereby on-base property that ceases to be used for  homeless assistance reverts back to the LRA or other entity. However,  there is limited other guidance on what terms or types of arrangements  are or are not acceptable. For example, there is no standard information  on appropriate no-cost conveyance lease terms or time frames for  conveyances of the property. While there are general criteria for HUD’s  review of the redevelopment plans as a whole, a HUD general counsel  official stated that, other than a few provisions required by regulation,  there are no specific criteria for the review of legally binding agreements,  and instead the official uses professional judgment to assess the  sufficiency of the agreements.
The limited information and specificity in the regulations contributed to  delays in approving redevelopment plans, as a HUD general counsel  official stated that the legally binding agreements typically required  revisions before she could approve them, and addressing the revisions  required additional time. The HUD general counsel official told us that she  requested revisions to approximately 80 percent of legally binding  agreements received, and in some cases multiple revised drafts were  needed prior to HUD approval. Requested revisions included, but were  not limited to, requiring more specificity related to  the proposed property location, such as the building numbers for on- base property;  the number of individuals and type of population to be served; and  the type of housing assistance to be provided—that is, permanent,  supportive, or transitional.
Some homeless assistance providers we spoke with noted the length of  the HUD review of legally binding agreements as contributing to the  longer duration of the overall HUD review process. For example, one  homeless assistance provider told us that HUD’s review and approval of  the agreement was the slowest part of the BRAC homeless assistance  process. Another homeless assistance provider we interviewed stated  that it took 2 years for HUD to approve the legally binding agreement.  DOD officials we spoke with suggested that having more standardized  information might help HUD’s review process, and they suggested a  standard template could be beneficial.
In some cases, the HUD official responsible for reviewing redevelopment  plans told us she approved redevelopment plans without signed legally  binding agreements. Instead, HUD would accept a consent letter from the  homeless assistance providers stating that they reviewed and agreed to  the terms of the agreement as written. However, because the legally  binding agreements were not signed, HUD officials stated that LRAs  could subsequently alter the terms after HUD approval, which could affect  the final conveyance and ultimately affect the feasibility of the homeless  assistance to be provided. Further, although HUD regulations do not  require that the agreements be signed prior to HUD’s approval of LRA  redevelopment plans, HUD does not have information available, such as  through a website, to clarify the implications of unsigned agreements for  the parties involved in the process. We found examples of situations in  which the LRA changed the terms of the agreements resulting in the  provider considering withdrawing from the process or the terms not  meeting the provider’s expectations about the time frame for the  assistance to be provided. For example, one homeless assistance  provider told us that it may have to withdraw from accepting a property  conveyance because the LRA had changed the terms of the unsigned  legally binding agreement from a 49-year lease to a year-to-year lease,  and this would have prevented the provider from guaranteeing continuity  of homeless assistance operations. Another homeless assistance  provider we spoke with stated that the LRA tried to change the terms of  the legally binding agreement, which was signed by the provider but not  the LRA, and told this provider that it might not receive the homeless  assistance conveyance for up to 25 years.
Fourth, although alternatives to conveyances of on-base properties were  viewed as a benefit to the process, not all LRAs or homeless assistance  providers we spoke with were aware of the permissible alternatives.  According to the BRAC statute, conveyances for the assistance of the  homeless may be made at no cost, but DOD is required to seek  consideration for certain other types of conveyances. For this reason,  HUD requires that the proposed use of the property provided under a  homeless assistance conveyance be limited to authorized homeless  assistance programs, and may only provide minimal or incidental benefit  to other groups. Organizations serving other populations—such as  persons with disabilities or of low-income—that are not also homeless  cannot receive no-cost homeless assistance conveyances. However,  some homeless assistance providers we interviewed told us that the best  options to provide homeless assistance often include mixed uses of the  property, including options for low-income housing or other revenue- generating efforts that could be used to fund the proposed homeless  assistance, in addition to the homeless assistance itself. LRAs may offer  homeless assistance conveyances at no cost in conjunction with other  types of conveyances that are made at reduced or market cost. This  enables homeless assistance providers to develop the property for mixed- use.
Some LRAs we spoke with offered alternatives to accommodate these  mixed-use efforts, such as financial assistance or off-base properties, or  allowing the sale of property for affordable housing alongside the no-cost  homeless assistance conveyance for mixed-use development. For  example, an LRA official from the Sergeant J.W. Kilmer U.S. Army  Reserve Center in Edison, New Jersey (see fig. 10) stated that the legally  binding agreement between the LRA and Monarch Housing Associates  provides for the sale of undeveloped land on-base to the homeless  assistance collaborative, with 75 percent of the land sold for affordable  housing at a cost of $975,000 and 25 percent of the land provided for free  as part of the no-cost homeless assistance conveyance. Additionally, in  San Jose, California, the LRA for the George L. Richey U.S. Army  Reserve Center offered to sell off-base property to Charities Housing  Development Corporation for $6,750,000, with part of the purchase price  as a forgivable loan of $1,590,000 from the county, to be used for housing  for persons experiencing homelessness and of low-income.
BRAC regulations require that the LRAs assess the balance of economic  redevelopment and other development needs of the communities in the  vicinity of the installation with the needs of the homeless in those  communities, and explain how their redevelopment plans address that  balance.offer homeless assistance providers alternatives to conveyances of on- base property, but because the BRAC homeless assistance process is  primarily focused on the reuse of surplus federal facilities, LRAs are not  required to offer alternatives to on-base property. As a result, not all  homeless assistance providers we interviewed were offered these  alternatives. For example, one homeless assistance provider told us it  would have liked to receive financial assistance or off-base property, but   In an effort to accommodate this balance, LRAs may choose to  the LRA did not offer either alternative, and 8 years later the provider is  waiting to receive on-base property. Another homeless assistance  provider stated that it did not know that financial assistance was an option  until later in the process, and that knowledge of financial assistance as a  permissible alternative would have assisted in shortening the time frame  to receive homeless assistance. At another base, the leader of a coalition  of five homeless assistance providers told us that the providers may  withdraw from the process because they require a mixed-use option,  which the LRA has not offered. Their withdrawal would leave the LRA  needing to spend additional time trying to find other providers for property  designated for homeless assistance on which, according to a DOD  official, the Army has already spent approximately $1 million in caretaker  costs. Furthermore, one LRA we spoke with also was not aware that  homeless assistance conveyances could be offered in conjunction with  other types of conveyances. Specifically, the LRA told us that it would  have been easier to accommodate homeless assistance if the BRAC  regulations allowed for sale of property for affordable housing in addition  to homeless assistance conveyances.
Based on our review of BRAC homeless assistance regulations, we found  that the regulations did not provide detailed information on alternatives to  on-base property. Specifically, the regulations do not describe which  combinations of money or property or both are acceptable homeless  assistance arrangements, although the regulations appear to contemplate  that homeless assistance can be provided in a variety of ways, requiring,  among other things, “a description of how buildings, property, funding,  and/or services on or off the installation will be used to fill some of the  gaps in the current continuum of care system.” Additionally, there are  not sources of publicly available information, such as a website or  pamphlet, to disseminate this information.
Without providing clear and sufficient information on the condition of the  property to be shared during workshops and tours, required elements for  notices of interest, acceptable terms of legally binding agreements, and  legal alternatives to on-base property, it will be difficult for LRAs and  homeless assistance providers to have the knowledge necessary to make  an informed decision about the BRAC homeless assistance process,  which, in turn, may negatively affect the time frame and feasibility of the  proposed homeless assistance.
section_title: LRAs Cited the HUD Headquarters Staff as Helpful, but the Limited Number of HUD Staff Dedicated to the Review of Redevelopment Plans Delayed the BRAC Homeless Assistance Process
paragraphs: LRA officials we interviewed expressed appreciation for advice from HUD  staff as they navigated through the BRAC homeless assistance process,  but we found that the limited number of HUD staff dedicated to the review  of redevelopment plans slowed the process. At many interviews we  conducted with LRAs, LRA officials expressed appreciation, with one LRA  official stating that she reached out to the HUD headquarters staff  multiple times while compiling the redevelopment plan and their  assistance was very helpful. The official also noted that HUD field office  staff assisted the LRA in identifying where homeless assistance providers  were located in the aftermath of a natural disaster. Another LRA official  told us that the LRA interacted directly with the HUD headquarters BRAC  Coordinator throughout the process and that the coordinator was very  willing to help and provided tailored service repeatedly. Another LRA  official stated that HUD officials traveled to advise the LRA on the  redevelopment process in person.
However, HUD did not have enough resources dedicated to meet the 60- day deadline established in the BRAC statute for reviewing the surge of  LRA redevelopment plans, which added to the delay in implementing the  BRAC homeless assistance provision. During the 2005 BRAC homeless  assistance process, it took HUD an average of 666 days, ranging from 8  to 1,777 days, to approve the 51 redevelopment plans that included  notices of interest for homeless assistance (see fig. 11).
The BRAC statute required that HUD complete an initial review within 60  days of receipt of the redevelopment plan. HUD and DOD regulations  construed this as requiring that HUD complete that review within 60 days  after receipt of a completed plan. HUD requested additional information  from 45 of 51 plans with interest from homeless assistance providers in  order to consider the plans complete. HUD officials stated that this  interpretation of the BRAC statute enabled HUD and the LRAs to  communicate further about the requirements for the redevelopment plan  submission. Fifteen of the 51 redevelopment plans were approved within  the statutory deadlines, as construed by HUD and DOD. However, even  working from the dates on which HUD considered the LRAs’  redevelopment plans complete, or, in the case of plans for which HUD  issued a preliminary adverse determination, from the resubmission date,  HUD took, on average, 151 days longer than allowed by statute to review  the redevelopment plans.
According to Standards for Internal Control in the Federal Government,  an agency’s organizational structure should provide a framework to  achieve agency objectives, including compliance with applicable laws and  regulations and the effective and efficient use of agency resources. However, HUD did not effectively dedicate resources for reviewing the  surge of LRA redevelopment plans to meet its 60-day time frame for  review of the plans. According to HUD officials, two HUD headquarters  staff members were assigned to review 125 LRA redevelopment plans,  51 of which had notices of interest from homeless assistance providers.  HUD staff suggested that additional, temporary staff at the headquarters  level and increased involvement of field staff could potentially expedite  the review times, although they stated additional funding would be  required. However, HUD has not fully developed options to address  reviewing the surge of plans. Both DOD and HUD officials told us that, for  some redevelopment plans, HUD’s review time was lengthened because  DOD directed HUD to prioritize the review of plans of bases ready to be  conveyed. In doing so, HUD delayed the review of plans which other  bases’ LRAs may have submitted earlier. However, HUD officials added  that DOD’s prioritization of their review partially contributed to the delays  and the underlying source was their insufficient number of dedicated staff  resources.
GAO/AIMD-00-21.3.1.
Without sufficient staff resources dedicated to the review of LRA  redevelopment plans and homeless assistance submissions, HUD was  not typically able to meet the 60-day deadline set forth in the BRAC  statute, and the BRAC homeless assistance process was delayed. During  interviews, homeless assistance providers, LRA officials, and military  officials provided examples to us of how the length of the HUD review  contributed to the longer time frame for the process, affected their ability  to move forward, or required additional effort to manage. For example,  when asked about challenges encountered in the BRAC homeless  assistance process, one DOD official responded that the HUD review  process took 4 years. A homeless assistance provider stated that it took  HUD approximately 3 years to approve the redevelopment plan. An LRA  told us that due to delays in the HUD review process, the LRA could not  move forward with design guidelines or zoning regulations, which slowed  the overall redevelopment process. Another LRA stated that it cost the  city $55,000 in staff and incidental costs while it awaited HUD’s review. In  addition, since the BRAC homeless assistance process often spanned  several years, multiple parties told us they experienced staff turnover and  had to reeducate existing staff and brief new staff on the process, which  took additional time and effort. Without a means to ensure that sufficient  staff resources are dedicated to HUD’s review process, it will be difficult  for HUD to provide reasonable assurance that the delays experienced  during BRAC 2005 will not be repeated in the event of future BRAC  rounds, potentially hindering the effectiveness of the homeless assistance  process as established and ultimately the redevelopment of the closed  base.
section_title: Conclusions
paragraphs: BRAC 2005 was the largest and costliest BRAC round in DOD history,  and its closure of 125 military bases with surplus property affected the  economies of the surrounding communities. While each community faced  uncertainty regarding the loss of local business and jobs, the BRAC  statute also offered an opportunity for homeless assistance providers to  receive no-cost property conveyances and help address local  homelessness needs. With 75 providers expected to receive nearly 50  parcels of property and over $29 million in assistance, the 2005 BRAC  homeless assistance program offered benefits. However, HUD and DOD  have no requirement to track whether those plans are executed as  agreed upon, whether the actual property is conveyed to the homeless  assistance providers, whether homeless assistance providers are  implementing the program consistent with the approved agreements, or  whether the conveyance reverts back to the LRA at no cost if a provider  drops out of the agreement. Without a requirement to track the status of  all BRAC homeless assistance conveyances, it will be difficult for HUD  and DOD to identify the overall effectiveness of those conveyances on its  homeless assistance goals and determine whether program changes are  needed to improve the process in any future BRAC round.
The BRAC homeless assistance process provides needed assistance to  the homeless population across the nation, but the BRAC regulations  state it must be balanced against the redevelopment activities of the  community. Delays in redevelopment as the communities consider the  homeless assistance program can cost DOD and the LRA wasted  financial resources, create unfulfilled expectations for program  participants, and ultimately jeopardize the success of the BRAC homeless  assistance program by impeding the time frame and feasibility for  homeless individuals and families to receive assistance and for the  ultimate redevelopment of the closed base. Limited and unclear  information from HUD and DOD to homeless assistance providers and  LRAs on what should be included in tours of on-base property, notices of  interest, and legally binding agreements has contributed to delays in  submitting notices and even resulted in withdrawals by homeless  assistance providers from the process. Similarly, limited information from  HUD and DOD to LRA decision makers on alternatives to on-base  property conveyances has contributed to timeline extensions and  additional costs to DOD to maintain the properties to be conveyed.  Moreover, we found that the surge in HUD’s responsibilities when a  BRAC round is announced results in resource challenges for the  department. Although many LRAs we spoke with agreed that HUD  provided expertise and advice on the homeless assistance process, with  few dedicated resources HUD did not provide a timely review of homeless  assistance submissions and redevelopment plans. Homeless assistance  providers benefited from obtaining no-cost property or financial  assistance, and awareness of homelessness issues was elevated among  local community leaders during the BRAC 2005 round, but the challenges  of limited information and dedicated HUD resources emerged that  hampered the timeliness and success of the program. As Congress  considers whether to authorize another BRAC round, efforts by HUD and  DOD to address these challenges would help to minimize delays and  improve the effectiveness of the program.
section_title: Recommendations for Executive Action
paragraphs: We recommend the following six actions:  To help determine the effectiveness of BRAC homeless assistance  conveyances, the Secretaries of Housing and Urban Development and  Defense should update the BRAC homeless assistance regulations to  require that conveyance statuses be tracked. These regulatory updates  could include requiring DOD to track and share disposal actions with HUD  and requiring HUD to track the status following disposal, such as type of  assistance received by providers and potential withdrawals by providers.
To assist homeless assistance providers and LRAs in completing the  steps of the BRAC homeless assistance process within required time  frames, to provide additional information to reduce unfulfilled expectations  about the decisions made in executing the homeless assistance  agreements, and to promote a greater dissemination of this information,  the Secretaries of Housing and Urban Development and Defense, for  each of the following four elements, should update the BRAC homeless  assistance regulations; establish information-sharing mechanisms, such  as a website or informational pamphlets; or develop templates to include  specific guidance that clearly identifies the information that should be  provided to homeless assistance providers during tours of on-base  property, such as the condition of the property;  information for homeless assistance providers to use for preparing  their notices of interest; guidance for legally binding agreements and clarification on the  implications of unsigned agreements; and  specific information on legal alternatives to providing on-base  property, including acceptable alternative options such as financial  assistance or off-base property in lieu of on-base property, information  about rules of sale for on-base property conveyed to homeless  assistance providers, and under what circumstances it is permissible  to sell property for affordable housing alongside the no-cost homeless  assistance conveyance.
To help improve the timeliness of the HUD review process, the Secretary  of Housing Urban Development should develop options to address the  use of staff resources dedicated to the reviews of bases during a BRAC  round, such as assigning temporary headquarters staff or utilizing current  field HUD staff.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to HUD and DOD for review and  comment. In written comments, HUD generally concurred with all six of  the recommendations, including five that would need to be jointly  implemented with DOD, and identified some actions it intends to take to  address them. DOD partially concurred with three of the joint  recommendations and did not concur with the remaining two joint  recommendations. HUD’s and DOD’s comments are summarized below  and reprinted in their entirety in appendixes III and IV, respectively. HUD  and DOD also provided technical comments, which we incorporated as  appropriate.
HUD generally concurred and DOD partially concurred with the first  recommendation to update the BRAC homeless assistance regulations to  require that conveyance statuses be tracked, which could include  requiring DOD to track and share disposal actions with HUD and requiring  HUD to track the status following disposal. HUD stated that it is willing to  update the BRAC homeless assistance regulations to track the  conveyances of property for homeless assistance, but noted that it will  require DOD agreement to do so because the regulations are joint. In its  response, DOD stated that while it concurs in the value of tracking  homeless assistance and other conveyances, it can do so without any  change to existing regulations. DOD did not identify any actions it will take  on how to track the homeless assistance conveyances in the absence of  a regulatory update, and also did not indicate that it would work with HUD  to update the regulations. Moreover, DOD did not explain how program  staff would know to track the conveyance status in the absence of  guidance requiring them to do so. As we noted in the report, both  departments need to be involved in tracking the conveyance status; DOD  is in the best position to know the status of the conveyances prior to the  property disposal, and HUD is in the best position to communicate with  the LRAs to know the status of the conveyances following property  disposal. Also as noted in the report, HUD and DOD officials stated that  they saw value in tracking the conveyance statuses. By updating the  regulations, both departments can jointly commit to tracking long-term  conveyance status information and, in turn, providing timely and useful  information about the BRAC homeless assistance program. We continue  to believe that updating the BRAC homeless assistance regulations to  require the tracking of conveyances of property for homeless assistance  will provide HUD and DOD with better insight into the effectiveness of the  BRAC homeless assistance program and help identify adjustments that  may be needed to improve program processes or procedures to be used  in any future BRAC rounds.
HUD generally concurred and DOD partially concurred with the second  recommendation to update the BRAC homeless assistance regulations,  establish information-sharing mechanisms, or develop templates to  include specific guidance that clearly identifies the information that should  be provided to homeless assistance providers during tours of on-base  property, such as the condition of the property. HUD stated that it will  update its BRAC guidebook, website, and presentations to provide  clarifying information for homeless assistance providers regarding what  information should be included during tours of on-base property. HUD  also noted in its response that this will require DOD and military  department agreement to implement and that the provision of information  about the condition of on-base property and access to that property is  under the purview of the military department. DOD stated that while it  already provides generic information about the property, the LRAs and  interested homeless assistance providers can undertake facility  assessments following the tours. However, DOD did not provide  additional detail or explanation about how it would provide information  about the condition of the property or access to it.
As we stated in the report, we found that the level of detail and property  access that LRAs granted to providers varied. As a result, some providers  withdrew from the process after they obtained more information about the  condition of the property and determined it was no longer a feasible  project. These withdrawals left the LRAs needing to spend additional time  trying to find other providers for property designated for homeless  assistance and jeopardized the success of the BRAC homeless  assistance program by impeding the feasibility of individuals and families  experiencing homelessness to receive assistance. We also noted that,  while the LRAs might not have completed a facilities survey or  infrastructure inspection to provide property information by the time the  tours for providers were held, some homeless assistance providers we  interviewed suggested that details on when this information would be  provided might be helpful. We continue to believe that specific guidance  is needed to help ensure that information regarding tours of on-base  property—such as property condition or, in the case that the information  is not available prior to the tours, details on when information about  property condition might be available—is provided to homeless  assistance providers, thus helping to ensure they have the knowledge  necessary to make an informed decision about the BRAC homeless  assistance process, including the time frame and feasibility of the  proposed homeless assistance.
HUD generally concurred and DOD did not concur with the third  recommendation to update the BRAC homeless assistance regulations,  establish information-sharing mechanisms, or develop templates to  include information for homeless assistance providers to use in preparing  their notices of interest. HUD stated that it will update its BRAC  guidebook, website, and presentations to provide clarifying information for  homeless assistance providers to use in preparing their notices of  interest. HUD also stated that it considered the current regulations and  BRAC guidebook sufficient to inform providers as long as LRAs did not  place additional requirements, which may create an undue burden for  providers. In its response, DOD stated that the existing regulatory  guidance is adequate for providers’ expressions of interest, given that  these expressions evolve as the redevelopment planning effort proceeds  and they learn more about the property—the process of which the second  recommendation above is intended to expedite. As we noted in the report,  while the regulations relevant to the third recommendation provide  general information about what should be included in homeless  assistance providers’ notices of interest, not all participants in the BRAC  process were aware of the regulations, and LRAs sometimes requested  additional information that was not required. Homeless assistance  providers we interviewed told us that they did not receive clear  information on the full extent of what to include in their notices of interest,  which contributed to providers being removed from consideration for  BRAC homeless assistance properties. Among the 75 providers whose  notices of interest were rejected, we identified 17 examples where the  LRA and HUD agreed that the notices of interest were incomplete.  Providers said they needed more shared and specific information on what  to include, and some providers suggested that a template or additional  examples of notices of interest would have provided clarity. Additionally,  LRA officials told us they often requested additional time to allow  providers to complete the notices of interest, contributing to extensions in  the process that resulted in LRAs taking an average of 654 days to  submit their redevelopment plans—more than twice the 270-day deadline  given to LRAs to submit their plans following the end of the period for  receipt of notices of interest. Furthermore, nothing in the recommendation  requires that regulations be changed if the departments do not wish to do  so; rather, at the departments’ discretion, we recommended that the  departments update the regulations, establish information-sharing  mechanisms such as a website or informational pamphlets, or develop  templates.
We believe that HUD’s proposed action to update its BRAC guidebook,  website, and presentations, if implemented, is responsive to the  recommendation and can help ensure that homeless assistance providers  are able to complete their notices of interest with the required information  necessary for consideration, which could assist LRAs in submitting their  redevelopment plans on time and ultimately accelerate the BRAC  homeless assistance and base redevelopment process. We continue to  believe that DOD should work with HUD to implement the joint  recommendation.
HUD concurred and DOD partially concurred with the fourth  recommendation to update the BRAC homeless assistance regulations,  establish information-sharing mechanisms, or develop templates to  include guidance for legally binding agreements and clarification on the  implications of unsigned agreements. HUD stated that it will update its  BRAC guidebook, website, and presentations to provide clarifying  information for homeless assistance providers to use in preparing legally  binding agreements and on the implications of unsigned agreements.  DOD did not commit to taking any actions to provide this information and  instead noted that any action should ensure that a legally binding  agreement does not bind DOD to disposal actions it is unable to carry out.  Nothing in the recommendation requires DOD to sign an agreement it  cannot carry out.
DOD further noted that the purpose of the legally binding agreement is to  provide remedies and recourse for the LRA and provider in carrying out  an accommodation following property disposal. We agree that legally  binding agreements can provide recourse, but we found that some  agreements were being approved prior to being signed and that providers  did not know that unsigned agreements would limit their recourse in the  process. For example, we found that the LRA could subsequently alter  unsigned agreements, potentially affecting the final conveyance and  ultimately the feasibility of the homeless assistance to be provided. In  addition, during the course of our review we found that the limited  information and specificity in the regulations contributed to delays in  approving base redevelopment plans, as a HUD general counsel official  told us that she requested revisions to approximately 80 percent of legally  binding agreements received and addressing the revisions required  additional time. DOD officials told us that having more standardized  information, such as a standard template, could help HUD’s review  process—consistent with what we are recommending. We believe that  HUD’s proposed actions to clarify information regarding legally binding  agreements and the implications of unsigned agreements, if  implemented, are responsive to the recommendation and could help  facilitate the timeliness of HUD’s review and provide additional awareness  for homeless assistance providers regarding the timeliness and feasibility  of the proposed homeless assistance. We continue to believe that DOD  should take similar actions to provide additional information and help  ensure the expeditious redevelopment of bases closed under BRAC.
HUD generally concurred and DOD did not concur with the fifth  recommendation to update the BRAC homeless assistance regulations,  establish information-sharing mechanisms, or develop templates to  include specific information on legal alternatives to providing on-base  property, including acceptable alternative options such as financial  assistance or off-base property in lieu of on-base property, information  about rules of sale for on-base property conveyed to homeless assistance  providers, and under what circumstances it is permissible to sell property  for affordable housing alongside the no-cost homeless assistance  conveyance. HUD stated that it will update its BRAC guidebook, website,  and presentations to clarify that the use of off-base property and financial  assistance are acceptable alternate means of homeless assistance  accommodation in base redevelopment plans and to include examples of  alternatives to on-base property that have been approved to date. HUD  also stated that this will require DOD and military department agreement  to implement.
DOD did not concur with the recommendation. In its response, DOD  stated that providers may only be considered through specific  expressions of interest in surplus BRAC property, and these suggested  alternatives may only be considered within the context of what is legally  permissible given the specific circumstances at each installation. Nothing  in the recommendation suggests that DOD identify alternatives that are  not legally permissible or indicates that all alternatives should be offered  in every circumstance; rather, we found that when alternatives were being  considered, all parties lacked information about which types of  information were legally permissible. While providers may only express  interest in surplus BRAC property, we found that LRAs may offer  providers alternatives to conveyances of on-base property to better  balance economic redevelopment and the needs of the homeless in those  communities. The BRAC regulations contemplate that homeless  assistance can be provided in a variety of ways, but we found that the  regulations did not provide detailed information on alternatives to on-base  property and sources of publicly available information, such as a website  or pamphlet, to disseminate this information were not available. Further,  DOD noted in its response that HUD may provide examples of  alternatives to on-base property that have been approved to date as part  of a local accommodation to offer examples for LRAs and providers.  DOD’s suggestion is consistent with HUD’s response. We believe that  this proposed action—along with HUD’s plan to update its BRAC  guidance, website, and presentations—may provide LRAs and homeless  assistance providers with additional feasible options for homeless  assistance through the BRAC process.
Finally, HUD generally concurred with the sixth recommendation to  develop options to address the use of staff resources dedicated to the  reviews of bases during a BRAC round, such as assigning temporary  headquarters staff or utilizing current field HUD staff. HUD stated that it  temporarily assigned headquarters staff and utilized field office staff  during the 2005 round of BRAC. However, as we noted in our report,  HUD’s efforts to provide staff resources during the 2005 round of BRAC  were insufficient, resulting in HUD typically being unable to meet the 60- day deadline set forth in the BRAC statute and the BRAC homeless  assistance process being delayed. HUD also stated that, in the event of  another BRAC round the size of 2005, it would encourage Congress to  allocate funding for appropriate temporary staff resources to assist the  department in meeting important timelines. However, even without  dedicated funding, we believe that HUD should consider ways to  temporarily reorganize or dedicate additional staff members to meet its  60-day time frame for review of the redevelopment plans. By providing  sufficient staff resources, HUD may be able to minimize the delays it  experienced during BRAC 2005, ultimately improving the timeliness and  effectiveness of future BRAC rounds and expediting base redevelopment.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of Defense, and the Secretary of Housing and  Urban Development. In addition, the report is available at no charge on  the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-4523 or leporeb@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix V.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The objectives of our review were to address (1) the types of assistance  provided to homeless assistance providers as part of the 2005 base  realignment and closure (BRAC) round and the extent to which the  Departments of Defense (DOD) and Housing and Urban Development  (HUD) track implementation of the agreements reached and (2) any  benefits and challenges encountered as DOD, HUD, and the local  redevelopment authorities (LRA) addressed provisions for homeless  assistance as a result of BRAC 2005.
To define the scope for both objectives, we first identified total bases  closed with surplus property and then classified those bases as (1)  receiving notices of interest and implementing homeless assistance, (2)  receiving notices of interest but not implementing homeless assistance,  and (3) not receiving notices of interest. Specifically, to identify the scope  of our review of 125 bases closed with surplus property during the 2005  BRAC round, we obtained comprehensive lists of base closures with  surplus property from DOD and HUD. We then reconciled the lists and  requested follow-up information from each department, as applicable. We  also interviewed agency officials at DOD and HUD knowledgeable about  the data to help ensure that the lists were complete, and we determined  they were complete and sufficient to use for our engagement. To classify  the bases into these three categories, two analysts independently  reviewed an internal HUD document used to track the BRAC 2005  homeless assistance process. From our review, we identified 39 bases  that received notices of interest from homeless assistance providers that  were approved to implement homeless assistance, 12 bases that  received notices of interest that were not approved for assistance, and 74  bases that did not receive notices of interest. The HUD tracking document  identified bases that did and did not implement homeless assistance;  however, HUD staff did not formally track the number of bases that  received notices of interest but did not result in legally binding  agreements. To classify these bases, two analysts reviewed the HUD  tracking document for comments that suggested this categorization. From  these comments, the two analysts independently identified a set of bases  that received notices of interest but did not result in legally binding  agreements and reconciled them as appropriate.
Additionally, for those bases that the HUD tracking document identified as  implementing homeless assistance, we further reviewed the  redevelopment plans and HUD approval documents. From these reviews,  we found five instances in which the homeless assistance provider  withdrew its notice of interest in exchange for homeless assistance from  the community outside of the BRAC process. HUD’s tracking document  identified two of these instances as the base implementing homeless  assistance and three of these instances as the base not implementing  homeless assistance. Because the homeless assistance providers at  these five bases withdrew their notices of interest for assistance and HUD  did not review a legally binding agreement between the provider and  LRA, we categorized these five instances as bases that received notices  of interest but did not implement homeless assistance.
Moreover, we also selected a nonprobability sample of three bases that  did not implement homeless assistance to determine whether additional  bases received notices of interest that were not identified in the  comments in HUD’s tracking document. We selected bases that  represented a range of size, geography, and military service. Ultimately,  from the three bases we selected that did not receive homeless  assistance, we did not find any that received notices of interest. While the  results of our review of HUD’s tracking document, redevelopment plans,  and judgmental sample indicated that there are 12 bases that received  notices of interest but did not implement homeless assistance, it is  possible that more bases received notices of interest but did not  ultimately convey property or provide other types of assistance to  homeless assistance providers.
To determine the types of assistance provided to homeless assistance  providers for those 51 LRAs that received interest from homeless  assistance providers, we reviewed the LRAs’ homeless assistance  submissions as part of their redevelopment plans to HUD and identified  and analyzed information. Specifically, we identified and analyzed the  number of notices of interest received, the number and types of  properties requested by the homeless assistance providers, the number  and types of properties agreed to be given from the LRA to the homeless  assistance providers, and the number and description of the conveyances  of property or money that have occurred. We also analyzed the  redevelopment plans to determine reasons why some notices of interest  were not approved. To evaluate the extent to which the DOD and HUD  tracked the implementation of the agreements, we interviewed DOD and  HUD officials regarding their roles in tracking the assistance provided to  homeless assistance providers and compared these roles to criteria for  management control activities in Standards for Internal Control in the  Federal Government. For the 39 bases with approved conveyances, we  collected data as of October 2014 from DOD’s military departments, the  LRAs, and homeless assistance providers about the types of properties  or money conveyed and the status of that conveyance. We also reviewed  the tracking requirements for the Title V homeless assistance program to  determine whether any applicable comparisons could be made to the  tracking requirements for the BRAC homeless assistance program.
To evaluate the benefits and challenges encountered as DOD, HUD, and  the LRAs addressed provisions for homeless assistance, we collected  documentary and testimonial evidence through a two-part approach. First,  we collected data from the redevelopment plans from all 51 LRAs that  received interest from homeless assistance providers. Specifically, we  identified requests for extensions and completion dates for required  process steps, such as the homeless assistance submission to HUD and  approval by HUD. We then analyzed these data and compared the actual  timelines to the required timelines in the BRAC statute and regulations.  Second, to gather in-depth information from a sample of the bases with  surplus property closed as a result of BRAC 2005, we conducted  semistructured interviews regarding benefits and challenges of the  homeless assistance process with the LRAs and homeless assistance  providers from 23 closed bases. We attempted to contact all homeless  assistance providers affiliated with those base closures; however, we  were unable to reach all providers and ultimately contacted 54 providers  associated with the 23 base closures.locations—Georgia, New Jersey, Pennsylvania, and California—and we  contacted 12 of these sites via phone. For those bases we visited, we  also interviewed the HUD field office representatives and project  managers from the military departments and DOD’s Office of Economic  Adjustment—DOD’s primary organization providing assistance to   We visited 11 of these sites in four  communities affected by BRAC. We selected bases to reflect a range of  factors including the number of homeless notices of interest received,  base size, geographical representation, types of homeless assistance  conveyance provided, and to include representation from each military  service. Ultimately, we contacted 12 bases that received notices of  interest and implemented homeless assistance, 9 bases that received  notices of interest and did not implement homeless assistance, and 2  bases that did not receive notices of interest. These interviews provide  examples of benefits and challenges faced by each individual party, but  information obtained is not generalizable to all parties involved in the  homeless assistance process. Further, we compared information about  the challenges cited with criteria for information and communications in   See table 3  Standards for Internal Control in the Federal Government.for a summary of bases and number of associated homeless assistance  providers we contacted.
In order to assess the reliability of the data presented in this report, we  corroborated the data in HUD’s tracking document with the data in the  LRAs’ redevelopment plans and interviewed knowledgeable agency  officials at HUD regarding data reliability, including any limitations of  HUD’s data related to its completeness and accuracy. After assessing the  data, we determined that the data were sufficiently reliable for the  purposes of determining the types of assistance provided to homeless  assistance providers and the challenges encountered in addressing the  homeless assistance provisions, and we discuss our findings in the  report.
We conducted this performance audit from April 2014 to March 2015 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.
section_title: Appendix II: Comparison of Title V and Redevelopment Act Homeless Assistance Processes
paragraphs: Since the Defense Base Closure and Realignment (BRAC) Act of 1990  was enacted, there have been two distinct authorities governing the  homeless assistance process on military bases closed under BRAC.  From the enactment of the BRAC statute in 1990 until October 1994, Title  V of the McKinney-Vento Homeless Assistance Act—which allows  certain excess, surplus, unutilized, and underutilized federal property to  be used to provide assistance to the homeless—applied with slight  modifications to BRAC closures. For properties on military bases  approved for closure after October 25, 1994, amendments to the BRAC  statute made in the Base Closure Community Redevelopment and  Homeless Assistance Act of 1994 (Redevelopment Act) govern the  homeless assistance process. The Redevelopment Act aimed to revise  and improve the process for disposing of buildings and property at bases  closed under BRAC. According to the Department of Housing and Urban  Development (HUD), many individuals involved in military base reuse at  the time had concluded that Title V did not adequately address the  multiple interests related to large parcels of surplus federal properties  such as military bases.
Title V of the McKinney-Vento Homeless Assistance Act designated the  General Services Administration, Department of Health and Human  Services, and HUD to administer the homeless assistance program, with  the General Services Administration delegating its property disposal  authority to the Department of Defense (DOD) for bases closed under  BRAC. Under the Title V homeless assistance program, DOD was  required to submit a description of its vacant base-closure properties to  HUD. HUD would then determine whether any property was suitable for  use to assist the homeless. HUD would publish its determination in the  Federal Register, at which time qualified homeless assistance providers  could apply for and receive the requested property. Following transfer of  the property to the homeless assistance provider, the Department of  Health and Human Services was to perform compliance oversight and  ensure that the grantee was using the property according to the terms in  the approved application.
In contrast to the Title V homeless assistance program, the BRAC statute  as amended by the Redevelopment Act is overseen by HUD and DOD. In  general, the Redevelopment Act replaced the Title V homeless  assistance program with a community-based process, in which the local  redevelopment authority (LRA) prepares a redevelopment plan after  consulting with homeless assistance providers and other community  groups affected by the base closure, and HUD ensures that the plan  appropriately balances the needs of the community for economic and  other development with the needs of the homeless. Subsequent to HUD  approval and other procedural steps, DOD may transfer properties for  homeless assistance purposes.
The number of bases at which property or funding for homeless  assistance were provided has varied for each round of base closures, as  seen in figure 12. Under the earlier BRAC rounds, which were governed  by the Title V homeless assistance program, properties at nine bases  were transferred to homeless assistance providers, including properties at  seven bases in the 1991 BRAC round and at two bases in the 1993  BRAC round. Under the Redevelopment Act homeless assistance  program, properties were transferred or offers of financial assistance  were made to homeless assistance providers at 92 bases, including at 53  bases in the 1995 BRAC round and at 39 bases in the 2005 BRAC round.
section_title: Appendix III: Comments from the Department of Housing and Urban Development
section_title: Appendix IV: Comments from the Department of Defense
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Laura Durland (Assistant  Director), Emily Biskup, Grace Coleman, Chris Cronin, Lorraine Ettaro,  Erica Miles, Silvia Porres, Jodie Sandel, Amie Steele, Erik Wilkins- McKee, and Michael Willems made key contributions to this report.
section_title: Related GAO Products
paragraphs: Federal Real Property: More Useful Information to Providers Could  Improve the Homeless Assistance Program. GAO-14-739. Washington,  D.C.: September 30, 2014.
DOD Joint Bases: Implementation Challenges Demonstrate Need to  Reevaluate the Program. GAO-14-577. Washington, D.C.: September 19,  2014.
Defense Infrastructure: Communities Need Additional Guidance and  Information to Improve Their Ability to Adjust to DOD Installation Closure  or Growth. GAO-13-436. Washington, D.C.: May 14, 2013.
Military Bases: Opportunities Exist to Improve Future Base Realignment  and Closure Rounds. GAO-13-149. Washington, D.C.: March 7, 2013.
DOD Joint Bases: Management Improvements Needed to Achieve  Greater Efficiencies. GAO-13-134. Washington, D.C.: November 15,  2012.
Military Base Realignments and Closures: The National Geospatial- Intelligence Agency’s Technology Center Construction Project.  GAO-12-770R. Washington, D.C.: June 29, 2012.
Military Base Realignments and Closures: Updated Costs and Savings  Estimates from BRAC 2005. GAO-12-709R. Washington, D.C.: June 29,  2012.
Veteran Homelessness: VA and HUD Are Working to Improve Data on  Supportive Housing Program. GAO-12-726. Washington, D.C.: June 26,  2012.
Homelessness: Fragmentation and Overlap in Programs Highlight the  Need to Identify, Assess, and Reduce Inefficiencies. GAO-12-491.  Washington, D.C.: May 10, 2012.
Military Base Realignments and Closures: Key Factors Contributing to  BRAC 2005 Results. GAO-12-513T. Washington, D.C.: March 8, 2012.
Homeless Women Veterans: Actions Needed to Ensure Safe and  Appropriate Housing. GAO-12-182. Washington, D.C.: December 23,  2011.
Excess Facilities: DOD Needs More Complete Information and a Strategy  to Guide Its Future Disposal Efforts. GAO-11-814. Washington, D.C.:  September 19, 2011.
Military Base Realignments and Closures: Review of the Iowa and Milan  Army Ammunition Plants. GAO-11-488R. Washington, D.C.: April 1,  2011.
GAO’s 2011 High-Risk Series: An Update. GAO-11-394T. Washington,  D.C.: February 17, 2011.
Defense Infrastructure: High-Level Federal Interagency Coordination Is  Warranted to Address Transportation Needs beyond the Scope of the  Defense Access Roads Program. GAO-11-165. Washington, D.C.:  January 26, 2011.
Military Base Realignments and Closures: DOD Is Taking Steps to  Mitigate Challenges but Is Not Fully Reporting Some Additional Costs.  GAO-10-725R. Washington, D.C.: July 21, 2010.
Rural Homelessness: Better Collaboration by HHS and HUD Could  Improve Delivery of Services in Rural Areas. GAO-10-724. Washington,  D.C.: July 20, 2010.
Homelessness: A Common Vocabulary Could Help Agencies Collaborate  and Collect More Consistent Data. GAO-10-702. Washington, D.C.: June  30, 2010.
Defense Infrastructure: Army Needs to Improve Its Facility Planning  Systems to Better Support Installations Experiencing Significant Growth.  GAO-10-602. Washington, D.C.: June 24, 2010.
Homelessness: Information on Administrative Costs for HUD’s  Emergency Shelter Grants Program. GAO-10-491. Washington, D.C.:  May 20, 2010.
Military Base Realignments and Closures: Estimated Costs Have  Increased While Savings Estimates Have Decreased Since Fiscal Year  2009. GAO-10-98R. Washington, D.C.: November 13, 2009.
Military Base Realignments and Closures: Transportation Impact of  Personnel Increases Will Be Significant, but Long-Term Costs Are  Uncertain and Direct Federal Support Is Limited. GAO-09-750.  Washington, D.C.: September 9, 2009.
Military Base Realignments and Closures: DOD Needs to Update Savings  Estimates and Continue to Address Challenges in Consolidating Supply- Related Functions at Depot Maintenance Locations. GAO-09-703.  Washington, D.C.: July 9, 2009.
Defense Infrastructure: DOD Needs to Periodically Review Support  Standards and Costs at Joint Bases and Better Inform Congress of  Facility Sustainment Funding Uses. GAO-09-336. Washington, D.C.:  March 30, 2009.
Military Base Realignments and Closures: DOD Faces Challenges in  Implementing Recommendations on Time and Is Not Consistently  Updating Savings Estimates. GAO-09-217. Washington, D.C.: January  30, 2009.
Military Base Realignments and Closures: Army Is Developing Plans to  Transfer Functions from Fort Monmouth, New Jersey, to Aberdeen  Proving Ground, Maryland, but Challenges Remain. GAO-08-1010R.  Washington, D.C.: August 13, 2008.
Defense Infrastructure: High-Level Leadership Needed to Help  Communities Address Challenges Caused by DOD-Related Growth.  GAO-08-665. Washington, D.C.: June 17, 2008.
Defense Infrastructure: DOD Funding for Infrastructure and Road  Improvements Surrounding Growth Installations. GAO-08-602R.  Washington, D.C.: April 1, 2008.
Military Base Realignments and Closures: Higher Costs and Lower  Savings Projected for Implementing Two Key Supply-Related BRAC  Recommendations. GAO-08-315. Washington, D.C.: March 5, 2008.
Defense Infrastructure: Realignment of Air Force Special Operations  Command Units to Cannon Air Force Base, New Mexico. GAO-08-244R.  Washington, D.C.: January 18, 2008.
Military Base Realignments and Closures: Estimated Costs Have  Increased and Estimated Savings Have Decreased. GAO-08-341T.  Washington, D.C.: December 12, 2007.
Military Base Realignments and Closures: Cost Estimates Have  Increased and Are Likely to Continue to Evolve. GAO-08-159.  Washington, D.C.: December 11, 2007.
Military Base Realignments and Closures: Impact of Terminating,  Relocating, or Outsourcing the Services of the Armed Forces Institute of  Pathology. GAO-08-20. Washington, D.C.: November 9, 2007.
Military Base Realignments and Closures: Transfer of Supply, Storage,  and Distribution Functions from Military Services to Defense Logistics  Agency. GAO-08-121R. Washington, D.C.: October 26, 2007.
Defense Infrastructure: Challenges Increase Risks for Providing Timely  Infrastructure Support for Army Installations Expecting Substantial  Personnel Growth. GAO-07-1007. Washington, D.C.: September 13,  2007.
Military Base Realignments and Closures: Plan Needed to Monitor  Challenges for Completing More Than 100 Armed Forces Reserve  Centers. GAO-07-1040. Washington, D.C.: September 13, 2007.
Military Base Realignments and Closures: Observations Related to the  2005 Round. GAO-07-1203R. Washington, D.C.: September 6, 2007.
Military Base Closures: Projected Savings from Fleet Readiness Centers  Likely Overstated and Actions Needed to Track Actual Savings and  Overcome Certain Challenges. GAO-07-304. Washington, D.C.: June 29,  2007.
Military Base Closures: Management Strategy Needed to Mitigate  Challenges and Improve Communication to Help Ensure Timely  Implementation of Air National Guard Recommendations. GAO-07-641.  Washington, D.C.: May 16, 2007.
Military Base Closures: Opportunities Exist to Improve Environmental  Cleanup Cost Reporting and to Expedite Transfer of Unneeded Property.  GAO-07-166. Washington, D.C.: January 30, 2007.
Military Bases: Observations on DOD’s 2005 Base Realignment and  Closure Selection Process and Recommendations. GAO-05-905.  Washington, D.C.: July 18, 2005.
Military Bases: Analysis of DOD’s 2005 Selection Process and  Recommendations for Base Closures and Realignments. GAO-05-785.  Washington, D.C.: July 1, 2005.
Military Base Closures: Observations on Prior and Current BRAC  Rounds. GAO-05-614. Washington, D.C.: May 3, 2005.
Military Base Closures: Assessment of DOD’s 2004 Report on the Need  for a Base Realignment and Closure Round. GAO-04-760. Washington,  D.C.: May 17, 2004.