Military Base Realignments and Closures: DOD Has Improved Environmental Cleanup Reporting but Should Obtain and Share More Information
Published: 2017-01-19T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The environmental cleanup of bases closed under the BRAC process has historically been an impediment to the expeditious transfer of unneeded property to other federal and nonfederal parties. While DOD is obligated to ensure that former installation property is cleaned up to a level that is protective of human health and the environment, the cleanup process can delay redevelopment in communities affected by the BRAC process.
The House Report accompanying the fiscal year 2016 Military Construction, Veterans Affairs, and Related Agencies Appropriations Bill includes a provision for GAO to update its 2007 report on the environmental cleanup and transfer of installations closed under BRAC. This report addresses the extent to which DOD has made progress in: (1) capturing and reporting environmental cleanup costs at installations closed under BRAC and (2) transferring excess property and mitigating any challenges. GAO reviewed DOD guidance, cost data, and property transfer data; visited installations selected from among those with the highest cleanup costs, as well as other factors; and interviewed DOD and service officials.
section_title: What GAO Found
paragraphs: The Department of Defense (DOD) has captured and reported more comprehensive cost information in its environmental cost reporting for installations closed under the Base Realignment and Closure (BRAC) process since GAO last reported on the issue in 2007. For example, GAO reported in 2007 that the costs DOD reported for environmental cleanup for installations closed under the 2005 BRAC round were not complete; however, since fiscal year 2009, DOD's annual reports to Congress on environmental cleanup have included cleanup costs for all identified munitions and contaminants. For example, DOD estimated as of September 30, 2015, that it will need about $3.4 billion to complete environmental cleanup for installations closed under all BRAC rounds, in addition to the approximately $11.5 billion it has already spent. Despite this improvement in reporting, DOD has not reported to Congress in its annual report that the removal of certain emerging contaminants (i.e., contaminants that have a reasonable possible pathway to enter the environment, present a potential unacceptable human health or environmental risk, and do not have regulatory standards based on peer-reviewed science) will be significant. Without DOD including in its annual report to Congress its best estimate of these increased costs, Congress will not have visibility into the significant costs and efforts associated with the cleanup of emerging contaminants on BRAC installations and therefore will not have the necessary information to make more informed funding decisions.
DOD has used a variety of methods since GAO's 2007 report to continue to make progress in transfers of unneeded BRAC property. For example, as of September 30, 2015, DOD reported that it had transferred about 85 percent of its unneeded property identified in all BRAC rounds (see figure below). Despite this progress, installation officials stated that they continue to face challenges, such as navigating multiple regulatory agencies or disposing of radiological contamination, that increased the time it takes to clean up and transfer property. Installation officials GAO spoke with stated that they periodically reach out to officials at other installations, and across services, for help in learning how to expedite or resolve challenges, but there is no formal mechanism within DOD to capture and share this type of information. Installation officials further stated that a system to capture lessons learned would assist them in this effort. Without a mechanism to record and share lessons learned, installation personnel charged with implementing cleanup efforts are missing opportunities to share information and could duplicate errors made in the past.
section_title: What GAO Recommends
paragraphs: GAO recommends that (1) DOD include in future reports to Congress that the cleanup of emerging contaminants will increase cleanup costs, and estimate such costs, and (2) share best practices on mitigating cleanup and property transfer challenges. DOD concurred with GAO's recommendations.

section_title: Letter
paragraphs: The cleanup of environmental contaminants, such as hazardous  substances or unexploded ordnance, found on military installations  closed under the Base Realignment and Closure (BRAC) process has  cost billions of dollars and has historically been a key impediment to the  expeditious transfer of unneeded property to other federal and nonfederal  parties that can make new uses of the property. While the Department of  Defense (DOD) is obligated to ensure that former installation property is  cleaned up to a level that is protective of human health and the  environment, the cleanup process can delay redevelopment in  communities affected by the BRAC process.
This report is one in a series of reports we have issued on the BRAC  environmental cleanup and transfer process. In 2007, we reported that  Congress did not have full visibility over the total cost of DOD’s BRAC  cleanup efforts because none of the four reports DOD prepared on  various aspects of environmental cleanup presented all types of costs— past and future—to complete cleanup at each installation, and that  compiling a complete picture of all costs required extracting information  from multiple reports. We also found in 2007 that opportunities existed to  expedite the cleanup and transfer of unneeded 2005 BRAC properties  compared with other BRAC rounds, and recommended that the military  services report periodically to the Office of the Secretary of Defense  (OSD) on the status and proposed strategies for transferring properties.  Since 2007, DOD has taken actions to address these issues, which are  described later in this report.
In its report accompanying the Military Construction, Veterans Affairs, and  Related Agencies Appropriations Bill, 2016, the House Committee on  Appropriations included a provision for us to update our 2007 report on  the BRAC environmental cleanup progress. In response, this report  assesses the extent to which DOD has made progress (1) capturing and  reporting environmental cleanup costs at installations closed under all  prior BRAC rounds and (2) transferring excess property from all prior  BRAC rounds and mitigating any challenges in the environmental cleanup  and transfer process.
To determine the extent to which DOD has made progress in capturing  and reporting environmental cleanup costs at installations closed under  all prior BRAC rounds, we collected cost data from the Office of the  Deputy Assistant Secretary of Defense for Environment, Safety, and  Occupational Health’s Knowledge-Based Corporate Reporting System as  of September 30, 2015.  We interviewed DOD officials with knowledge of  these data to gather information, such as information about how data are  collected and verified, to assess the reliability of the data. We determined  these data to be sufficiently reliable for the purpose of presenting cleanup  costs DOD has identified. Furthermore, we interviewed DOD and service  officials to identify improvements made in their reporting of these data  and to identify any omissions in the total costs reported or estimated for  the future. We compared DOD’s efforts to capture and report its  environmental cleanup costs in its annual report to Congress on  environmental cleanup to criteria, such as costs being transparent and  complete, in DOD’s financial management regulation and DOD’s manual  on the management of the Defense Environmental Restoration Program.
To determine the extent to which DOD has made progress in transferring  excess property, we collected and analyzed data from DOD’s Office of  Economic Adjustment as of September 30, 2015, and interviewed Office  of Economic Adjustment officials with knowledge of these data to gather  information, such as who has access to and oversight of the database, to  assess the reliability of the data. We found these data to be sufficiently  reliable for our purposes. To identify any processes or procedures that  DOD or the services have implemented to expedite the cleanup and  transfer process and challenges that continue to hamper progress, we  interviewed officials from the Office of the Deputy Assistant Secretary of  Defense for Environment, Safety, and Occupational Health and the three  military departments and selected seven sites at which to interview  installation officials responsible for the caretaking and cleanup of the  installations as well as representatives from the local redevelopment  authorities. During these site visits, we also discussed the extent to which  installation officials shared lessons learned with other installation officials.  We reviewed this information in light of DOD’s and the Office of  Management and Budget’s guidance on lessons learned as well as  Standards for Internal Control in the Federal Government. Our site  selection was guided by three main variables, specifically a mix of  installations that: (1) were closed under legacy BRAC rounds (i.e.,  installations closed in BRAC rounds in 1988, 1991, 1993, and 1995) and  installations closed under BRAC 2005, (2) are among those with the  highest environmental cleanup costs, and (3) represented all three of the  military departments. We visited four installations closed under legacy  BRAC rounds: McClellan Air Force Base, California; Mather Air Force  Base, California; Fort Ord, California; and Treasure Island Naval Station  Hunters Point Annex, California; and three 2005 BRAC round closures:  Fort Monmouth, New Jersey; Naval Air Station Joint Reserve Base Willow  Grove, Pennsylvania; and Brooks City-Base, Texas. Further information  about our scope and methodology is in appendix I.
We conducted this performance audit from January 2016 to January 2017  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
paragraphs: Since 1988, DOD has relied on the BRAC process as an important  means of reducing excess infrastructure to meet changing force structure  needs. DOD has undergone five BRAC rounds: 1988, 1991, 1993, 1995,  and 2005. Under the five BRAC rounds, DOD has closed a total of 120  major installations and implemented a number of major and minor  realignment actions. Table 1 shows the number of major installation  closures, major realignments, and minor closures and realignments for  each of the five BRAC rounds.
In accordance with the BRAC statute, DOD must complete closure and  realignment actions no later than 6 years following the date that the  President transmits his report on the BRAC recommendations to  Congress. For BRAC 2005, the round’s completion date was September  15, 2011. The statute allows environmental cleanup and property transfer  actions associated with BRAC sites to exceed the 6-year time limit, and  does not set a deadline for completion. In our prior work, we have  reported that the cleanup of contaminated properties has been a key  factor related to delays in transferring unneeded property through the  BRAC process.
In conducting assessments of potential contamination and determining  the extent of cleanup required on installations closed because of BRAC  decisions, DOD must comply with cleanup standards and processes  under all applicable environmental laws, regulations, and executive  orders. The Comprehensive Environmental Response, Compensation,  and Liability Act of 1980 (CERCLA), as amended, authorizes cleanup  actions at federal facilities where there is a release of hazardous  substances or the threat of such a release that can present a threat to  public health and the environment. The Superfund Amendments and  Reauthorization Act of 1986 added provisions to CERCLA specifically  governing the cleanup of federal facilities, including active military  installations and those closed under BRAC, and required the Secretary of  Defense to carry out the Defense Environmental Restoration Program.  Under the Defense Environmental Restoration Program, DOD conducts  environmental restoration activities at active installations, Formerly Used  Defense Site properties, and BRAC locations in the United States to  address DOD contamination from hazardous substances, pollutants, or  contaminants; unexploded ordnance, discarded military munitions, or  munitions constituents; or building demolition and debris removal. Types  of environmental contaminants found at military installations include  solvents and corrosives; fuels; paint strippers and thinners; metals, such  as lead, cadmium, and chromium; and unique military substances, such  as nerve agents and unexploded ordnance. The program includes the  investigation, identification, and cleanup of contamination from hazardous  substances, pollutants, and contaminants; the correction of other  environmental damage (such as detection and disposal of unexploded  ordnance) that creates a threat to the public health or environment; and  the demolition and removal of unsafe buildings and structures.  The U.S.  Environmental Protection Agency and state regulatory agencies are  responsible for overseeing cleanup decisions to ensure that applicable  requirements are met.
In general, the services, as the owners of the property, put final cleanup  remedies in place before the property is transferred. However, under  some circumstances the services may conduct an early transfer before  cleanup has been completed. When remedies are in place for addressing  the contamination of a former installation or the services and the  communities have agreed to an early transfer, the property can be  transferred to a local redevelopment authority responsible for  implementing a plan for civilian reuse. Figure 1 shows the major  milestones in the cleanup and transfer process required under CERCLA.
Since 2005, we have issued more than 30 reports and testimonies on  BRAC planning, implementation, costs, and savings that highlight  information DOD can use to improve the BRAC recommendation  development and implementation process. For example, in 2015 we  reported that a variety of homeless assistance was provided as a result of  BRAC 2005 but that DOD and the Department of Housing and Urban  Development do not require tracking of data about the transfer of property  for homeless assistance. We recommended that DOD and the  Department of Housing and Urban Development track property transfer  status. DOD partially concurred with this recommendation and stated that  action on this recommendation is pending the authorization of a future  BRAC round. See the Related GAO Products page at the end of this  report for a list of reports related to BRAC.
section_title: DOD’s Latest Report to Congress Captures More-Comprehensive Environmental Cleanup Cost Information, but Omits Emerging Contaminants’ Cleanup Costs
paragraphs: DOD has captured and reported more-comprehensive cost information in  its environmental cost reporting for installations closed under BRAC;  however, DOD has not reported to Congress that the cleanup of  emerging contaminants could significantly increase the total cost of  environmental cleanup at installations closed by the BRAC process.
subsections: section_title: DOD Has Improved Its Environmental Cleanup Cost Reporting since 2007
paragraphs: DOD has improved its reporting of environmental cleanup costs to  Congress by capturing more-comprehensive information that we identified  as missing from its 2007 annual report. For example, we reported in  2007 that the costs for environmental cleanup for installations closed  under the 2005 BRAC round were not complete partly because DOD  excluded the cleanup costs for contaminants released on DOD property  after 1986 and munitions released on DOD property after 2002. We  recommended in our 2007 report that DOD provide all costs—past and  future—required to complete environmental cleanup at each BRAC  installation and to fully explain the scope and limitations of all the  environmental cleanup costs that DOD reports to Congress. In response,  in December 2008 DOD revised the activities eligible for the Defense  Environmental Response Program by including the cleanup for all  identified munitions and hazardous contaminants. In its Fiscal Year  2009 Defense Environmental Programs Annual Report to Congress, DOD  began reporting cleanup costs for all identified munitions and  contaminants and continued to report these costs in subsequent reports  to Congress including the Defense Environmental Programs Annual  Report to Congress for FY 2015.
In addition, we reported in 2007 that DOD had not reported complete  environmental cleanup costs on installations closed under the 2005  BRAC round partly because it omitted additional information such as  program-management costs—indirect, overhead, and management costs  related to the environmental cleanup that cannot be attributed to a  specific installation. In response, DOD issued an update to its Defense  Environmental Restoration Program in March 2012 clarifying the  requirement for the services to include program-management costs in  their cleanup costs estimates and including these costs in the 2015  annual report to Congress.
In its annual report to Congress, DOD reported that it spent $609.6  million to clean up properties closed under BRAC in fiscal year 2015.  DOD estimated as of September 30, 2015, that it will need about $3.4  billion to complete environmental cleanup for installations closed under  all BRAC rounds, including $475 million in program-management costs.  Through fiscal year 2015, DOD has spent approximately $11.5 billion,  including $813 million in program-management costs, for environmental  cleanup of installations closed under all BRAC rounds. Of this $3.4  billion, DOD will need about $435 million to complete the cleanup for  installations under the 2005 BRAC round, including $427 million for  major installations, and $2.5 billion to complete the cleanup for  installations under the legacy rounds (installations closed under the 1988,  1991, 1993, and 1995 BRAC rounds). Table 2 shows the total  environmental cleanup costs including the past and remaining costs to  complete the environmental cleanup for the 23 major installations closed  under BRAC 2005.
Table 3 shows the 10 installations from the legacy BRAC rounds (i.e.,  1988, 1991, 1993, and 1995) with the highest remaining environmental  cleanup costs based on cost information from fiscal year 2015. The cost  estimate of $1.2 billion to complete the environmental cleanup at these 10  BRAC installations accounts for 41 percent of the total remaining  environmental cleanup costs ($2.9 billion) for installations under all BRAC  rounds.
section_title: DOD Has Not Notified Congress about Increasing Cleanup Costs Related to Emerging Contaminants
paragraphs: DOD did not notify Congress in its most recent report in fiscal year 2015  on environmental programs that the costs for environmental cleanup at  BRAC installations will significantly increase due to the high cost of  remediating emerging contaminants, primarily perfluorooctane sulfonate  (PFOS) and perfluorooctanoic acid (PFOA), two types of perfluorinated  compounds, at many of the installations closed under BRAC. According  to DOD officials, the services are still investigating the scope of the  problem and the costs are not fully defined.
Although DOD officials have not determined the total costs for cleaning  up emerging contaminants at installations closed under BRAC, service  BRAC officials stated that the cost of cleaning up perfluorinated  compounds—specifically PFOS and PFOA—from installations closed  under BRAC will likely be significant. For example, Air Force BRAC  officials told us that the agency has programmed $100 million over the  next 5 years for the investigation and remediation of emerging  contaminants. Further, they stated that this amount does not include the  additional cost to complete the cleanup of emerging contaminants such  as PFOS and PFOA. Navy BRAC officials stated that the cleanup of  PFOS and PFOA at both active and closed installations could greatly  increase the environmental cleanup costs, into the billions of dollars. Also,  Army BRAC officials stated that the cleanup of PFOS and PFOA is a  serious issue that will greatly affect environmental cleanup costs.
Service officials stated they are continuing to identify and investigate sites  on installations, such as water systems, fire training activities, crash sites,  and aircraft hangers that may have been contaminated with PFOS or  PFOA. For example, Air Force BRAC officials stated that as of August  2016 they had identified 30 installations requiring preliminary assessment  investigations for PFOS and PFOA, but as of October 2016, the Air Force  anticipates that only 25 of these installations will require further  investigation. Navy BRAC officials stated that as of September 2016 they  had identified 35 BRAC installations with sites that are contaminated or  may be potentially contaminated with PFOS and PFOA. Further, Navy  BRAC officials stated that this number is likely to increase as they  conduct additional investigations. An Army BRAC official stated that Army  personnel have begun sampling sites at installations where PFOS and  PFOA may have been used, but have not yet determined which  installations may be potentially contaminated.
According to service BRAC officials, it could take many years to identify  new sites, investigate the soil and water system, and conduct cleanup  action for removing perfluorinated compounds. However, the presence of  perfluorinated compounds has already affected DOD’s ability to transfer  property. For example, the transfer of property at a former Navy  installation was delayed because in May 2016 levels of PFOS and PFOA  that exceeded the Environmental Protection Agency’s health advisory  levels were found in the local drinking water. Although the agency’s  health advisory is not binding, DOD officials stated that they want to  ensure that the levels of PFOS and PFOA in drinking water supplied to  residents are below the advisory levels.
According to DOD’s Financial Management Regulation, transparency and  complete accountability in financial reporting and budgetary backup  documents are essential elements for providing Congress with a more- comprehensive picture of total costs so it can make appropriate  budgetary trade-off decisions to ensure the expeditious cleanup and  transfer of properties and ultimately realize savings for the U.S.  government. Also, DOD’s manual on the management of the defense  environmental restoration program states that DOD shall improve its  financial management and reporting of environmental cleanup costs by  providing accurate, complete, reliable, timely, and auditable financial  information.
However, DOD’s annual report to Congress does not make any mention  of the significant increase in costs that the department is likely to incur  identifying and cleaning up these contaminants.  As a result, DOD has not  provided Congress with all of the available information on total cleanup  costs because its annual report did not reflect that cleanup costs will  significantly increase due to PFOS and PFOA on many DOD installations  including those closed under BRAC. Although DOD has been  investigating the presence of PFOS and PFOA at DOD installations for  several years, according to DOD officials, at the time of the last report to  Congress, the extent of the issue was not yet known. DOD officials  acknowledge they have not provided Congress with a complete picture of  total cleanup costs because DOD is working to identify locations where  DOD may have a known or suspected release of PFOS and PFOA on  DOD installations, including those closed under BRAC. DOD officials told  us they have briefed certain committees of Congress on this issue,  including the likelihood of increased costs for environmental cleanup.   However, DOD has not provided the full Congress with notification  through its annual report that DOD’s costs to clean up these  contaminants are expected to increase significantly. While the department  does not know the exact amount of the costs, DOD has an opportunity to  notify Congress of the expected increase and provide its best estimate of  the costs based on known information at the time of its annual report.  Without DOD notifying Congress about this expected cost increase and  providing the best estimate of costs for the cleanup of perfluorinated  compounds and other emerging contaminants to the extent known,  Congress will lack total visibility over this potentially significant BRAC  environmental cleanup effort and will not have necessary information to  make more-informed funding decisions.
section_title: DOD Has Made Progress in Transferring Excess Property, but Information on Successful Mitigation Strategies Is Not Widely Available
paragraphs: DOD has used a variety of methods since our 2007 report to continue to  make progress in transfers of unneeded BRAC property. At the same  time, installation officials stated that challenges remain, including unique  situations that will require more time to overcome, and others that are  more widespread, such as navigating multiple regulatory agencies or  dealing with emerging contaminants. Installation officials indicated that  lessons learned from installations that have successfully navigated these  more-widespread issues are not easily obtained and if they were  available it could help them and future officials facing cleanup of BRAC  property expedite the cleanup and transfer of properties.
subsections: section_title: DOD Has Made Progress in Transferring Unneeded Properties Identified in BRAC Rounds through a Variety of Methods
paragraphs: DOD has reported transferring about 85 percent (490,678 out of 575,758  acres) of unneeded property identified in all BRAC rounds through a  variety of methods, which is an increase from the 78 percent of property  transferred before and during 2007, the year of our previous review.  Regarding only the 2005 BRAC round, DOD reported that it had  transferred about 66 percent (60,224 out of 90,914 acres) of its unneeded  property as of September 30, 2015. Figure 2 shows the disposition of the  unneeded acreage from all prior BRAC rounds. The bulk of the transfers,  71 percent (406,668 acres) were to nonfederal entities. While DOD’s goal  is to transfer property to other entities for reuse, as we noted in our 2007  report, leasing property can also afford the user and DOD some benefits.  As we also reported in 2007, communities, for example, can choose  leasing as an interim measure while awaiting final environmental cleanup  and thereby promote property reuse and job creation. DOD also benefits,  in some cases, as the communities assume responsibility for costs of  protecting and maintaining these leased properties. By adding leased  acres to the number of transferred acres, the amount of unneeded BRAC  property being reused rises to 86 percent, according to our analysis.
Congress has provided DOD with a wide range of property transfer  methods and tools to expedite the cleanup and transfer of unneeded  BRAC property, including public benefit conveyances and negotiated  property sales. The closure and realignment of individual installations  creates opportunities for those unneeded properties to be made available  to others for reuse. When an installation is closed under BRAC, the  unneeded property is reported as excess. Federal property disposal laws  require DOD to first screen excess property for possible reuse by defense  and other federal agencies. If no federal agency needs the property, it is  declared surplus and is made available to nonfederal parties, including  state and local agencies, local redevelopment authorities, and the public,  using the various transfer tools as shown in table 4.
In 2007, we recommended that the services report periodically to OSD on  the status and proposed strategies for transferring excess BRAC  properties. In response, OSD began requiring the services to report on  the status of all excess property including the available acreage and the  authority used to transfer the property. In transferring its unneeded  property from the previous BRAC rounds, our analysis shows that DOD  primarily relies on reversions, economic development conveyances, and  public benefit conveyances. Figure 3 shows the breakdown of the  methods used by DOD for transferring property from all of the BRAC  rounds.
Improvements in funding for BRAC-related expenses and cleanup  technology have expedited the cleanup process and transfer of property.  For example, in 2013, Congress established a single BRAC account to  fund all BRAC-related expenses for all BRAC rounds, including costs for  environmental cleanup. Previously, there were two BRAC accounts—one  to fund activities related to legacy BRAC rounds and one to fund activities  related to the 2005 BRAC round. According to DOD and Army officials,  the single account has been beneficial in funding cleanup expenses.  According to Army officials, the Army was able to sell properties closed  under BRAC 2005, and the funds from these sales were available to use  to fund environmental cleanup. In addition, as we reported in 2007 and  according to Army officials we spoke with on this review, installations  closed in the BRAC 2005 round typically needed less environmental  cleanup because the services had already implemented cleanup  programs while the installations were active. As a result, Army officials  told us there was a large surplus in the BRAC 2005 account. With the  merging of the two accounts, the Army was able to use the surplus  money from the 2005 BRAC account to clean up properties closed in the  legacy BRAC rounds.
In addition, improvements in cleanup technology have expedited  environmental restoration in some locations. In our 2007 report, we  reported that the technology to detect and clean up unexploded ordnance  was limited and not fully effective. However, since our last report there  have been advances in this technology that make the cleanup of  unexploded ordnance faster and more effective. For example officials at  Fort Ord, California, informed us that DOD has developed a new tool, the  advanced geophysical classification technology, commonly referred to as  the advanced classification.  This technology enables personnel to  address the potential explosives safety hazards at munitions response  sites by identifying buried metal objects and determining whether they are  military munitions or harmless debris. According to officials, the use of the  advanced geophysical classification technology will allow DOD to reduce  cleanup time and costs. Installation officials also told us about using  innovative techniques for cleaning up contaminants in groundwater,  including injecting the groundwater with oil or organisms to facilitate the  natural attenuation of contaminants; these techniques should help  expedite cleanup at BRAC locations.
section_title: Officials Identified Challenges That Impede Progress, but DOD Does Not Have a Method for Installation Officials to Share Lessons Learned on Successful Mitigation Strategies
paragraphs: Installation officials and local redevelopment authority representatives  involved in the cleanup, transfer, and reuse of the property identified  challenges that continue to impede the environmental cleanup and  transfer process. Officials told us that some of their challenges are due to  unique situations that have to be addressed individually, but other  challenges are more common and widespread.  Installation officials told  us that not having information available on previous successful mitigation  strategies that may have been identified for common and widespread  challenges hampers their ability to expedite the cleanup and transfer of  some properties.
The unique challenges installation officials told us about during our site  visits result in additional time needed to conduct the environmental  cleanup and ultimately to transfer the property. For example, at Fort Ord,  California, the Army needs to burn the brush on the former training range  area to clean up unexploded ordnances. However, to perform this  controlled burn, the weather conditions need to be ideal due to concerns  of the fire spreading in dry conditions. In 2015, the Army was unable to  execute this burn due to unfavorable weather conditions. As of  September 2016, the Army still had not been able to conduct burns at  Fort Ord because of wildfires in the area that required the use of the fire  resources that would be necessary to control the burns and because of  dry weather conditions. Another unique challenge that results in additional  time to execute cleanup is when the properties are at remote locations.  For example, the Air Force can ship supplies and perform cleanup only  during certain months of the year at the former Galena Forward Operating  Location, Alaska, because of the severely cold weather that freezes the  river used for transportation. This limitation cuts down on the ability to  ship supplies and equipment to the installation for cleanup and to remove  waste from the site for disposal. The Navy faces similar challenges with  the cleanup at the former Naval Air Facility Adak, Alaska.
Officials told us about two other challenges that are more common and  widespread. First, officials at five of the seven installations we visited told  us that a key challenge across installations is coordinating with the large  number of regulatory agencies involved in environmental cleanup issues.  For example, installation and local redevelopment authority officials from  California stated that there are multiple environmental agencies in  California, each with its own area of concern, and that the agencies are  not always easy to coordinate with. In addition, some states, including  California and New Jersey, have stricter standards than the  Environmental Protection Agency has on certain contaminants, and the  services must clean up the contaminated property to the stricter state  level. Further, certain states, including Alaska and California, do not allow  disposal or storage of radiological contaminants in the state, and these  contaminants must be shipped to another state. For example, Navy  BRAC officials stated that they dispose of and transport radiological  waste from cleanup operations at Treasure Island Hunters Point,  California—closed under the 1991 BRAC round—to a Utah landfill  designated to receive this kind of waste. According to Navy BRAC  officials, the additional environmental cleanup costs for disposing of and  transporting radiological waste to the Utah landfill versus keeping the  waste in California is over $1 million per year.
Secondly, officials told us that the newly discovered presence of  emerging contaminants is a challenge that has delayed the transfer of  property and extended the timeline for cleanup in some locations,  especially former airfields. The most common emerging contaminants on  DOD installations are perfluorinated compounds, specifically PFOS and  PFOA, found in fire-fighting foam used throughout the nation by the  military and commercial airports. In 2009, the Environmental Protection  Agency issued a provisional health advisory establishing levels at 400  parts per trillion for PFOA and 200 parts per trillion for PFOS in drinking  water. In May 2016, EPA replaced the provisional advisories with a  lifetime health advisory for PFOS and PFOA of 70 parts per trillion in  drinking water. This level applies both to the chemicals individually and to  the concentrations of both, when combined.  Although Environmental  Protection Agency health advisories are nonenforceable, DOD issued an  instruction in 2009 stating that DOD will perform sampling, conduct site- specific risk assessments, and take actions for emerging contaminants  released from DOD facilities. According to DOD officials, DOD is in the  beginning stages of determining the extent of this problem, and has  discovered levels of PFOS and PFOA that exceed the Environmental  Protection Agency’s health advisory level at numerous installations,  including Naval Air Station Joint Reserve Base Willow Grove,  Pennsylvania, and Pease Air Force Base, New Hampshire.
Installation officials we spoke with stated that they periodically reach out  to officials at other installations informally, even across services, for help  in learning how to expedite or resolve these challenges as well as others,  but there is no formal mechanism, such as a web-based database, within  DOD to capture this type of information. Officials stated that a system to  capture lessons learned would assist them in addressing challenges at  their installations and would be important for any future BRAC rounds, as  current personnel may no longer be employed within the department. One  example of an innovative approach to dealing with the disposal of  radioactive material is at the former McClellan Air Force Base, California.  In 2007, we reported that traces of plutonium were found during a routine  cleanup in September 2000, causing a cost increase of $21 million and  extending the completion schedule beyond 2030. However, since 2007,  officials told us that they realized a better way to decrease the costs of  disposing of radioactive material by using a consolidation landfill on the  installation. According to installation officials, the Air Force will save over  $200 million by disposing of this material in this manner rather than  shipping the material to a disposal facility in another state. Figure 4 shows  the consolidation landfill at the former McClellan Air Force Base.
DOD has created a joint lessons-learned program, and the guidance for  this program states that recording, analyzing, and developing improved  processes, procedures, and methods based on lessons learned are  primary tools in developing improvements in overall performance.  Further, the Office of Management and Budget’s guidance on the  preparation, submission, and execution of the budget states that agencies  should consider lessons learned from past efforts to continuously improve  service delivery and resolve management challenges. Although this  guidance is not specific to environmental cleanup, it provides good  examples of how lessons-learned programs can be structured. Further,  Standards for Internal Control in the Federal Government state that  communication throughout an entity is an important part of achieving the  entity’s objectives and includes the communication of quality information  to all levels of the entity. The Office of the Deputy Assistant Secretary of  Defense for Environment, Safety, and Occupational Health currently  oversees a Cleanup Committee composed of senior environmental  officials from each of the services. The purpose of this committee is to  communicate, discuss, and resolve cleanup issues. According to DOD  officials, this group meets regularly to share lessons learned and improve  DOD policy. However, installation officials do not attend these meetings  and do not have a mechanism to routinely record and share information  on lessons learned, successful strategies, helpful contacts, or insight they  have gained from previous DOD cleanups. Installation officials we spoke  with indicated that a repository or method to record and share this type of  information would be beneficial to others who face similar challenges in  the future. Without a repository or method to record and share lessons  learned, installation personnel charged with implementing cleanup efforts  are missing opportunities to share lessons learned about how various  locations have successfully addressed cleanup challenges and may  therefore be at risk of duplicating errors made in the past by others who  faced the same kind of cleanup issues.
section_title: Conclusions
paragraphs: The cleanup of environmental contaminants on installations closed under  BRAC has historically been a key impediment to the transfer and ultimate  reuse of the property by the community. Environmental cleanup is costly,  and DOD estimates that it will need about $3.4 billion in addition to the  approximately $11.5 billion it has already spent to manage and complete  environmental cleanup of installations closed under all BRAC rounds.  Since 2007, DOD has improved its reporting of these cleanup costs to  Congress by including in its annual reports information on how these  additional costs have contributed to the overall cost increases DOD has  experienced in implementing the BRAC recommendations. Despite these  improvements, DOD has not reported to Congress how the cleanup of  emerging contaminants, especially certain perfluorinated compounds, at  installations closed under BRAC will significantly increase the estimated  cleanup costs. Without including such information in its annual report,  DOD has not provided Congress full visibility over the expected increase  in costs and the necessary information to make more-informed funding  decisions.
DOD has also made progress in transferring property closed under  BRAC; however, officials identified several challenges in the cleanup and  transfer process, and some of these challenges may be aided by sharing  information from others who have successfully developed mitigation  strategies or navigated the complex regulatory environment. Without a  repository or method to record and share lessons learned, installation  personnel charged with implementing cleanup efforts may face  unnecessary delays or obstacles to cleanup issues that could have been  alleviated from the valuable insight gained by prior DOD experience with  these issues.
section_title: Recommendations for Executive Action
paragraphs: To provide Congress with better visibility over the costs for the  environmental cleanup of properties from all BRAC rounds to inform  future funding decisions, we recommend that the Secretary of Defense  direct the Secretaries of the military departments to include in future  annual reports to Congress that environmental cleanup costs will increase  due to the cleanup of perfluorinated compounds and other emerging  contaminants, and to include best estimates of these costs as additional  information becomes available.
To help the services more effectively share information and address  environmental cleanups and transfers, we recommend that the Secretary  of Defense direct the Secretaries of the military departments to create a  repository or method to record and share lessons learned about how  various locations have successfully addressed cleanup challenges.
section_title: Agency Comments
paragraphs: We provided a draft of this report to DOD for review and comment. In its  written comments, DOD concurred with our recommendations. DOD also  provided technical comments which we incorporated as appropriate.  DOD’s comments are printed in their entirety in appendix II.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of Defense; the Secretaries of the Army, the  Navy, and the Air Force; and the Assistant Secretary of Defense for  Energy, Installations, and Environment. In addition, the report is available  at no charge on our website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-4523 or leporeb@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine the extent to which the Department of Defense (DOD) has  made progress in capturing and reporting environmental cleanup costs at  installations closed under all prior Base Realignment and Closure (BRAC)  rounds, we collected cost data from the Office of the Deputy Assistant  Secretary of Defense for Environment, Safety, and Occupational Health’s  Knowledge-Based Corporate Reporting System as of September 30,  2015. We specifically analyzed information from the database on  environmental cleanup costs from fiscal year 2015—both past and  future—for all installations closed under the 2005 BRAC round as well as  the costs for installations closed under the legacy rounds (installations  closed in BRAC rounds 1988, 1991, 1993, and 1995). We interviewed  DOD officials with knowledge about these data to gather information to  assess the reliability of the data. We determined these data to be  sufficiently reliable for the purpose of presenting costs DOD has  identified. We reviewed and examined DOD regulations and guidance on  requirements for estimating and reporting costs, such as DOD’s Financial  Management Regulation and DOD Manual 4715.20, Defense  Environmental Restoration Program (DERP) Management. In addition,  we interviewed officials with the Office of the Deputy Assistant Secretary  of Defense for Environment, Safety, and Occupational Health and the  services to gain an understanding of how the estimates were derived from  the services and reported to Congress. We also examined the Defense  Environmental Programs Annual Report to Congress for Fiscal Year  2015—the most-recent report—to determine what environmental cleanup  costs and information were last reported to Congress. We compared  DOD’s efforts to capture and report on environmental cleanup costs in its  annual report to Congress on environmental cleanup to criteria, such as  costs being transparent and complete, in DOD’s financial-management  regulations and DOD’s manual on the management of the Defense  Environmental Restoration Program in conducting our analysis of the  data. Furthermore, we interviewed key officials with knowledge of  BRAC’s cost reporting and estimating from DOD and the services to  determine the extent to which DOD has made improvements in reporting  these data and identified any omissions in the total costs reported or  estimated for the future.
To determine the extent to which DOD has made progress in transferring  excess property, we collected and analyzed data from the Office of  Economic Adjustment as of September 30, 2015, and interviewed  officials with knowledge of these data to gather information to assess the  reliability of the data. We found these data to be sufficiently reliable for  our purposes. To identify any processes or procedures that DOD and the  services have implemented to expedite the cleanup and transfer process  and challenges that continue to hamper progress, we interviewed officials  from the Office of the Deputy Assistant Secretary of Defense for  Environment, Safety, and Occupational Health and the three military  departments. In addition, we selected seven sites at which to interview  installation officials responsible for the caretaking and cleanup of the  installations as well as representatives from the local redevelopment  authorities. Our site selection was based on three criteria: (1) a mix of  installations that were closed under legacy BRAC rounds and installations  closed under BRAC 2005, (2) installations from among those with the  highest environmental cleanup costs, and (3) installations that  represented all three of the military departments. We visited four legacy  BRAC round closures: McClellan Air Force Base, California; Mather Air  Force Base, California; Fort Ord, California; and Treasure Island Naval  Station Hunters Point Annex, California; and three 2005 BRAC round  closures: Fort Monmouth, New Jersey; Naval Air Station Joint Reserve  Base Willow Grove, Pennsylvania; and Brooks City-Base, Texas. We also  observed sites at the BRAC installations we visited to determine the  status of DOD’s cleanup efforts and the transfer of properties. To provide  further insight into cleanup and transfer issues, we also conducted phone  interviews with representatives from additional local redevelopment  authorities, also selected based on environmental cleanup costs and  service and geographical representation. In these site visits and  telephone interviews, we also discussed the extent to which installation  officials shared lessons learned with other installation officials. We  reviewed this information in light of DOD’s and the Office of Management  and Budget’s guidance on lessons learned as well as our Standards for  Internal Control in the Federal Government.
During our review, we interviewed the following offices involved with the  management and implementation of the environmental cleanup and  transfer of property for BRAC installations:  Assistant Secretary of Defense (Energy, Installations, and  Environment)
Office of the Deputy Assistant Secretary of Defense for  Environment, Safety, and Occupational Health, Arlington, Virginia.  Office of Economic Adjustment, Arlington, Virginia  Army Office of the Assistant Chief of Staff of Installation  Management, BRAC Division, Arlington, Virginia   Former Fort Ord, California  Former Fort Monmouth, New Jersey  Navy BRAC Program Management Office, Arlington, Virginia  Former Treasure Island Naval Station Hunters Point, California  Former Naval Air Station Joint Reserve Base Willow Grove,  Pennsylvania  Office of the Assistant Secretary of the Air Force (Installations,  Environment & Energy), Air Force BRAC Management Office,  Arlington, Virginia  Air Force Civil Engineering Center, Lackland Air Force Base,  Texas  Former McClellan Air Force Base, California  Former Mather Air Force Base, California  Former Brooks City-Base, Texas   Alameda, California (Former Alameda Naval Air Station,  California)  Brooks Development Authority, San Antonio, Texas (Former  Brooks City-Base, Texas)  Concord, California (Former Concord Naval Weapons Station,  California)  Fort Ord Reuse Authority, Monterey, California (Former Fort Ord,  California)  Fort McClellan Authority, Anniston, Alabama (Former Fort  McClellan, Alabama)
Fort Monmouth Economic Revitalization Authority, Oceanport,  New Jersey (Former Fort Monmouth, New Jersey)  Fort Monroe Authority, Hampton, Virginia (Former Fort Monroe,  Virginia)  Horsham Land Redevelopment Authority, Philadelphia,  Pennsylvania (Former Naval Air Station Joint Reserve Base  Willow Grove, Pennsylvania)  Office of Community Investment and Infrastructure, San  Francisco, California (Former Treasure Island Hunters Point,  California)  Sacramento County, California (Former McClellan Air Force Base  and former Mather Air Force Base)  Seneca County Industrial Development Agency, Waterloo, New  York (Former Seneca Army Depot, New York)  Vallejo, California (Former Mare Island Naval Shipyard, California)
We conducted this performance audit from January 2016 to January 2017  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: Comments from the Department of Defense
section_title: Appendix III: 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), Tracy Barnes, Leslie Bharadwaja, Tracy Burney, Michele Fejfar,  Amie Lesser, and Richard Powelson made key contributions to this  report.
section_title: Related GAO Products
paragraphs: Military Base Realignments and Closures: More Guidance and  Information Needed to Take Advantage of Opportunities to Consolidate  Training. GAO-16-45. Washington, D.C.: February 18, 2016.
Military Base Realignments and Closures: Process for Reusing Property  for Homeless Assistance Needs Improvements. GAO-15-274.  Washington, D.C.: March 16, 2015.
DOD Joint Bases: Implementation Challenges Demonstrate Need to  Reevaluate the Program. GAO-14-577. Washington, D.C.: September 19,  2014.
Defense Health Care Reform: Actions Needed to Help Realize Potential  Cost Savings from Medical Education and Training. GAO-14-630.  Washington, D.C.: July 31, 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.
Defense Health Care: Applying Key Management Practices Should Help  Achieve Efficiencies within the Military Health System. GAO-12-224.  Washington, D.C.: April 12, 2012.
Military Base Realignments and Closures: Key Factors Contributing to  BRAC 2005 Results. GAO-12-513T. Washington, D.C.: March 8, 2012.
Excess Facilities: DOD Needs More Complete Information and a Strategy  to Guide Its Future Disposal Efforts. GAO-11-814. Washington, D.C.:  September 19, 2011.
Military Base Realignments and Closures: Review of the Iowa and Milan  Army Ammunition Plants. GAO-11-488R. Washington, D.C.: April 1,  2011.
GAO’s 2011 High-Risk Series: An Update. GAO-11-394T. Washington,  D.C.: February 17, 2011.
Defense Infrastructure: High-Level Federal Interagency Coordination Is  Warranted to Address Transportation Needs beyond the Scope of the  Defense Access Roads Program. GAO-11-165. Washington, D.C.:  January 26, 2011.
Military Base Realignments and Closures: DOD Is Taking Steps to  Mitigate Challenges but Is Not Fully Reporting Some Additional Costs.  GAO-10-725R. Washington, D.C.: July 21, 2010.
Defense Infrastructure: Army Needs to Improve Its Facility Planning  Systems to Better Support Installations Experiencing Significant Growth.  GAO-10-602. Washington, D.C.: June 24, 2010.
Military Base Realignments and Closures: Estimated Costs Have  Increased While Savings Estimates Have Decreased Since Fiscal Year  2009. GAO-10-98R. Washington, D.C.: November 13, 2009.
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.