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DEPARTMENT OF THE AIR FORCE
WASHINGTON
OFFICE OF THE ASSISTANT
SECRETARY
DC
FEB 042004
MEMORANDUM FOR DEPUTY UNDER SECRETARYOF DEFENSE(INSTALLATIONS
AND ENVIRONMENT)
FROM SAF/IE
1665Air Force Pentagon
WashingtonDC 20330-1665
SUBJECT: Draft FederalRegisterNotice Regardingthe Final BRAC 2005 SelectionCriteria
(Your Memo, 30 Jan04)
On behalf of the Air ForceInfrastructureExecutiveCouncilmembers,andthe Air Force
Vice Chief of Staff, I concurwith the subjectFederalRegisterNotice,
r
NELSONF.
AssistantSecretary
(Installations,Environment& Logistics)
cc:
SecAF
CSAF
AF/CV
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.
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DEPUTY SECRETARY OF DEFENSE
1010 DEFENSE PENTAGON
WASHINGTON, DC 20301-1010
ACTION MEMO
TO: SECRETARYOF DEFENSE
FROM: Honorable Paul Wolfowitz, Deputy Secretaryof Defense
SUBJECT: Base Realignment and Closure (BRAC) Pinal Selection Criteria
The BRAC statuterequires the use of public selectioncriteria in the analytical
process. Selection criteria, along with the force structure plan, are the basis on which
the Commissionjudges DoD recommendations. DoD published draft criteria in the
Federal Register on December23,2003, for public comment (TAB B).
The Departmentreceived in excessof 200 letters from the public and membersof
Congress. Written commentsreceived from membersof Congressin advance of
publication were also considered in this process.
The draft criteria were designedto accommodatethe diversity of missions and
functions within the Department. We are not proposing any changesto them because
they either already addressthe comments or are broad enoughto accommodate them
through appropriate implementing guidance.
The statuterequires the Departmentto submit its criteria to the congressionaldefense
conunittees and publish them in the Federal Register (with a comment analysis), by
February 16, 2004, or BRAC ends. Since that date is a holiday, we will publish the
final criteria by the previous Thursday, February 12. The document must be at the
Federal Register no later than 2 p.m. on Tuesday, February 10, to meet that schedule.
Concurrent with forwarding this packageto you, we have provided drafts of the final
criteria and Federal Register notice to the Office of Managementand Budget. E.O.
12866requires OMB review of significant Federal Register notices prior to
publication. We do not anticipate their input will alter our recommendations.
I recommend you approve the final criteria, the Federal Register notice publishing
thesecriteria and analysis of comments,and sign the letters to the congressional
defensecommittees transmitting the final criteria (TAB A).
COORD: IEC MembersandGC at TAB D
RECOMMENDATION:
Attachments:As stated
Approve
Disapprove
Other
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THE UNDER SECRETARY
OF DEFENSE
3010 DEFENSE PENTAGON
WASHINGTON, DC 20301.3010
FEB 2 2004
ACQUISITION,
TECHNOLOGY
AND LOGISTICS
MEMORANDUM FOR INFRASTRUCTURE EXECUTIVE COUNCIL (IEC) MEMBERS
GENERAL COUNSEL OF THE DEPARTMENT OF DEFENSE
THROUGH: INFRASTRUCTURE STEERING GROUP (ISG) MEMBERS
SUBJECT: Final Base Realignment and Closure SelectionCriteria
The Base Realignment and Closure (BRAC) statuterequires the Department to
develop selectioncriteria to use in its analytical process. The selection criteria are
important becausethey, along with the force structure plan, are the basis on which the
Commissionjudges the Department's recommendations. The Department published draft
selectioncriteria in the Federal Register on December23, 2003, with public comments due
by January 28, 2004 (TAB B). The Department subsequentlyissued an extension of the
comment period to January 30thin conjunction with a clarification for when the comments
must be received (TAB C).
The Department must now submit the final criteria to the congressional defense
committees, and publish them in the Federal Register,with its analysis of the public
comments, by February 16,2004. Since that date falls on a holiday, we will publish the
final criteria by the previous Thursday, February 12,2004. To meet that publication
schedule,the document must be at the Federal Registerno later than 2 p.m. on Tuesday,
February 10,2004. Unless the criteria are disapproved by an Act of Congress, they become
final on March 15, 2004.
The OSD BRAC staff, with assistancefrom your BRAC principal, reviewed the
public and congressionalcomments received to determine if those comments raise issues
that may require changesto the draft criteria. Their assessmentis that the concerns
expressedin the comments are best addressedthrough policy guidance. Therefore, I
propose that we recommend to the Secretarythat he publish the final criteria unchanged.
At its January30, 2004, meeting the ISG decided that the compressedschedule for
publishing the final selection criteria compels a concurrentISG and IEC coordination
process. The package at TAB A contains the draft Federal Register notice (TAB 1), the
action memorandumto the Secretaryof Defense(TAB 2), and a letter transmitting the
Federal Register notice to the congressionaldefensecommittees (TAB 3) for your review
and coordination. The Federal Register notice includes an analysis of commentsreceived
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and an explanation of why we did not make changesto the criteria if they were suggested. I
believe thesecriteria comply with all statutoryrequirements and are broad enough to
support the Department's BRAC analysis.
Pleaseprovide your coordination and any commentsto the OSD BRAC Office by
noon on February 5, 2004. If we do not receive your coordination by this time, we will
assumeyour concurrence.
J?d-[}d~
Michael W. Wynne
Acting USD (Acquisition, Technology & Logistics)
Chainnan, Infrastructure Steering Group
Attachments:
As Stated
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DEPARTMENT OF DEFENSE
Office of the Secretary
Departmentof Defense SelectionCriteria for Closing and Realigning Military Installations
Inside the United States.
AGENCY: Departmentof Defense(DoD).
ACTION: Final SelectionCriteria.
SUMMARY: The Secretaryof Defense,in accordancewith Section2913(a) of the DefenseBase
Closureand RealignmentAct of 1990,Public Law 101-510,as amended,10 U.S.C. 2687 note, is
required to publish the final selectioncriteria to be used by the Departmentof Defense in making
recommendationsfor the closure or realignment of military installations inside the United States.
EFFECTIVE DATE: February 12,2004.
FOR FURTHER INFORMATION CONTACT: Mr. Mike McAndrew, Base Realignmentand
ClosureOffice, ODUSD(I&E), (703) 614-5356.
SUPPLEMENTARYINFORMATION:
A. Final SelectionCriteria
The final criteria to be used by the Departmentof Defenseto make recommendationsfor the
closure or realignmentof military installations inside the United Statesunder the DefenseBase
Closureand RealignmentAct of 1990,Public Law 101-510,as amended,10 U.S.C. 2687 note,
are asfollows:
In selectingmilitary installations for closure or realignment,the Departmentof Defense,
giving priority considerationto military value (the first four criteria below), will consider:
Military Value
The~urrent and future mission capabilities and the impact on operationalreadinessof the
Departmentof Defense'stotal force, including impact on joint warfighting, training, and
readiness.
2. The availability and condition of land, facilities and associatedairspace(including training
areassuitable for maneuverby ground, naval, or air forces throughout a diversity of climate
and terrain areasand stagingareasfor the use of the Armed Forcesin homelanddefense
missions) at both existing and potential receiving locations.
3. The ability to accommodatecontingency,mobilization, and future total force requirementsat
both existing and potential receiving locationsto supportoperationsand training.
4. The cost of operationsand the manpowerimplications.
Other Considerations
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5. The extent and timing of potential costsand savings,including the number of years,
beginning with the date of completion of the closure or realignment, for the savingsto exceed
the costs.
6. The economic impact on existing communities in the vicinity of military installations.
7. The ability of both the existing and potential receiving communities'infrastructureto support
forces, missions,and personnel.
8. The environmentalimpact, including the impact of costsrelated to potential environmental
restoration,wastemanagement,and environmentalcomplianceactivities.
B. Analysis of Public Comments
The Departmentof Defense (DoD) receiveda variety of commentsfrom the public, membersof
Congress,and other electedofficials in responseto the proposedDoD selectioncriteria for
closing and realigning military installations inside the United States. The Departmentalso
receiveda number of letters from membersof CongressregardingBRAC selectioncriteria
before publication of the draft criteria for comment. The Departmenthastreatedthose letters as
commentson the draft criteria and included the points raised therein in our assessmentof public
comments. The commentscanbe groupedinto three categories:general,military value, and
other considerations. The following is an analysis of thesecomments.
(1) General Comments:
(a) Numerouscommentorsexpressedsupport for the draft criteria without suggesting
changesand usedthe opportunity to provide information on their particular installations. DoD
understandsand greatly appreciatesthe high value that communitiesplace on the installations in
their areaand the relationships that have emergedbetweenthe Departmentand local
communities. Both the BRAC legislation and DoD's implementationof it ensurethat all
installations will be treated equally in the baserealignmentand closureprocess.
(b) Severalcomrnentorsgave various reasonswhy a particular installation, type of
installation, or installations designatedby Congressas unique assetsor strategicports, should be
eliminated from any closure or realignmentevaluation. Public Law I 01-510 directs DoD to
evaluateall installations equally. The Departmenthas issuedguidanceto all DoD Components
instructing them to treat all installations equally.
(c) Somecornmentorsindicated the selectioncriteria should reflect the statutoryrequirement.
of section2464 of title 10, United StatesCode,to maintain a core logistics capability, and the
statutory limitation of Section2466 that the Departmentspendno more than 50% of its depotlevel maintenanceand repair funds to contract for the performanceof suchworkload. The
Departmentbelieves, consistentwith the developmentand application of the criteria used in all
previous rounds, that it is inappropriateto include any statutoryconstraintsin the selection
I
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criteria becausethey are too varied and numerousand could preclude evaluationof all
installations equally. However, the absenceof theserequirementsin the text of the
criteria should not be construedas an indication that the Departmentwill ignore these or any
other statutoryrequirementsor limitations in making its final recommendations.
(d) The Departmentdid not receive any requestsfrom local governmentsthat a particular
installation be closed or realigned pursuantto section2914 (b)(2) of Public Law 101-510,which
statesthat the Secretaryshall considerany notice received from a local governmentin the
vicinity of a military installation that the local governmentwould approve of the closure or
realignment of the installation. However, a few private citizens askedthat a particular
installation be closed or that operationsbe restrictedto limit noise or other community impacts.
( e) A few commentorsexpressedconcernover the broad nature of the criteria and requested
greaterdetail, including in somecasesrequestsfor defmitions, specificity regarding select
functions, and explanationsof when a closureas opposedto a realignmentwas appropriate.
While the Departmentappreciatesa desire for detail, the inherent mission diversity of the
Military Departmentsand DefenseAgenciesmakes it impossible for DoD to specify detailed
criteria that could be applied to all installations and functions within the Department. Broad
criteria allow flexibility of applicationacrossa wide range of functions within the Department.
(f) A few commentorsrecommendedassigningspecific weights to individual criteria and
applying those criteria uniformly acrossthe Department. It would be impossible for DoD to
specify weights for each criterion that could be applied uniformly to all installations and
functions becauseof the inherent mission diversity within the Department. Other than the
requirementto give the military value criteria priority consideration,the numbering reflected in
the listing of the criteria are not intendedto assignan order of precedenceto an individual
criterion.
(g) One commentorsuggestedthat section2687 of title 10, United StatesCode,requires the
Departmentto exclude military installations with lessthan 300 authorized civilian positions from
considerationfor closure or realignmentunderBRAC. While section 2687 allows the
Departmentto close or realign suchinstallations outsidethe BRAC process,it does not preclude
their considerationwithin BRAC. In order for the Departmentto reconfigure its current
infrastructure into one in which operationalcapacitymaximizes both warfighting capability and
efficiency, it must undertakean analysisof the totality of its infrastructure, not just those with
300 or more authorized civilian positions.
(h) Somecommentorswere concernedthat BRAC would be used as a "back door" method of
privatizing civilian positions. DoD' s civil serviceemployeesare an integral part of successful
accomplishmentof defensemissions. Section2904 specifically limits the ability of the Secretary
of Defenseto carry out a privatization in place of a military installation recommendedfor closure
or realignmentto situationswhere that option is specified in the recommendationsof the
Commissionand determinedby the Commissionto be the most cost-effectivemethod of
implementation of the recommendation. Therefore,if any closure or realignment
recommendationincludesprivatization, it will be clearly statedin the recommendation.
,
,.
\
.
)Ii
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(i) One commentorsuggestedthat the Departmentneededto conducta comprehensivestudy
of U.S. military installations abroadand assesswhetherexisting U.S. basestructuresand
locations meetthe needsof currentand future missions. The BRAC statuteappliesto military
installations inside the United States,the District of Columbia, the Commonwealthof Puerto
Rico, Guam, the Virgin Islands, American Samoa,and any other commonwealth,territory, or
possessionof the United States. As a parallel action, the Secretaryof Defensehas already
undertakena comprehensivestudy of global basing and presence-the Integrated Global
Presenceand Basing Strategy(IGPBS). BRAC will accommodateany decisions from that study
that relocateforces to the U.S. DoD will incorporateour global basing strategyinto a
comprehensiveBRAC analysis,therebyensuring that any overseasredeploymentdecisions
inform our recommendationsto the BRAC Commission.
(j) A few commentorscautionedthe Departmentagainstusing the authority provided by
Section2914(c) to close and retain installations in inactive statusbecauseof the negative effect
such action might have on the relevant local community. The Departmentrecognizesthat job
creationgained through the economicreuseof facilities is critically important to mitigate the
negative impact of BRAC recommendations.As such,the Departmentwill exercisethe utmost
caution and considerationwhen exercisingits authority to retain installations in an inactive
status. It should be noted that the Departmenthas always had this authority, even though its
appearancein the authorizing legislation for the 2005 round would indicate it is a new authority
As such,the Department'sactionsin the four previous baseclosure rounds demonstratethat it
will be exercisedjudiciously.
(k) A few commentorsaskedthe Departmentto give priority to relocating activities within
the samestate or local community. The Departmentrecognizesthat the economic impact of
BRAC reductionscan be lessenedby moving functions to geographicallyproximate
locations. However, as specified in the BRAC legislation, military value must be the primary
considerationwhen making thesedecisions. Specifically, those factors that are set out in criteria
one through four are the most important considerationswhen selectingreceiving locations.
(2) Military Value Comments:
(a) A majority of commentsreceived dealt with the military value criteria. In the aggregate,
military value refers to the collection of attributes that determinehow well an installation
supportsforce structure,functions, and or missions.
(b) One commentorwas concernedthat the Departmentwould lose sight of the value of
service-uniquefunctions when applying criteria that include referenceto jointness. The
Departmentrecognizesthe distinct military value provided by both service-uniquefunctions and
those functions that are performed by more than one service. Accordingly, the Secretary
establisheda processwherein the Military Departmentsareresponsiblefor analyzing their
service-uniquefunctions, while Joint Cross-ServiceGroups,which include representativesfrom
eachof the military services,analyzethe commonbusiness-orientedsupportfunctions.
(c) A few commentorswere concernedthat criterion two, which capturesthe legislative
requirementsset out in Section2913(b)(1)-(3), did not recite verbatim the languagein the BRAC
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statute. They urged incorporationof "Preservationof' into the fmal criteria to ensurethat the
2005 BRAC round preservethe infrastructurenecessaryto supportfuture military requirements.
The Departmentdoes not agreewith the assertionthat the criteria must contain the word
"preservation" in orderto comply with the BRAC statute or with congressionalintent. The
report of the Committee of Conferenceto accompanyS. 1438,the National Defense
Authorization Act for Fiscal Year 2002, refers to the preceding list of requirementsas "factors
that must be evaluatedand incorporatedin the Secretary'sfinal list of criteria." The BRAC
statutedoes not require, as a matterof law, a verbatim recitation of the factors set out in section
2913. On the contrary, a requirementfor a verbatim recitation is inconsistentwith the
requirementsfor publication of draft criteria, an extensivepublic commentperiod, and
finalization of criteria only after reviewing public comments. lfthe Secretarywere bound to
adoptthe statutorylanguageas his criteria, the detailed publication processrequired by Congress
would be meaningless. While the criteria proposedby the Secretarydo not recite the statutory
languageverbatim, they do fully reflect the nine factors set out in the statute,and as suchare
legally sufficient. Additionally, selectioncriteria must facilitate discriminating amongvarious
military installations, assessingthe value of eachand comparing them againsteachother to see
which installations offer the greatestvalue to the Department. Criteria one through three assess
the assetsof military installations againsteachother, valuing those with more of those assets
more highly than those without thoseassets. By valuing the installations with more of these
assetshigher, the Department"preserves"thesevaluable assetsset out in the criteria. However,
if the Departmentwere to modify the criteria to include "preservation,"as suggestedin the
comment,we would be forced to assesshow an installation "preserves"somethingrather than
whetheran installation possessesthe assetsworthy of preservation. Therefore,while the
Departmentagreesthat preservationof theseassetsis important, including the word preservation
in the criteria will not further that objective, and may actually force an opposite result.~
(d) A few commentorsstressedthe importanceof maintaining a surgecapacity. Surge
requirementscanarise for any numberof reasons,including contingencies,mobilizations, or
extendedchangesin force levels. The Departmentbelieves that as currently drafted criteria one
and three capturethe conceptof surgecapacity. As was the casewith the criteria used in the past
three rounds ofBRAC, criterion one requiresthe Departmentto consider "current and~"
mission capabilities and criterion three assesses
the "ability to accommodatecontingency.
mobilization and future total force reauirements". In 1999, after three rounds of BRAC using
thesecriteria (and similar criteria used in the fIrst round of BRA C), the Departmentlooked
closely at its ability to accommodateincreasedrequirementsand found that even after four
rounds of baserealignmentsand closuresit could accommodatethe reconstitution of 1987force
structure -a significantly more robust force than exists today -which is a more demanding
scenariothan a short term mobilization. Further, as required by Section2822 of the National
DefenseAuthorization Act for Fiscal Year 2004 (Public Law 108-136),the Secretary,as part of
his assessmentof probablethreatsto nationalsecurity, will determinethe "potential, prudent,
surgerequirementsto meetthosethreats."
(e) Numerouscommentorsstatedthat previous BRAC rounds failed to evaluateresearch,
development,test and evaluation,engineering,procurement,and technical facilities accurately,
becauseof the lack of effective criteria to considerthe featuresessentialto their performance.
They noted that the criteria applied to suchfacilities in previous rounds were largely the same
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criteria that were applied to operations,training and maintenancefacilities serving very different
functions. DoD highly values its research,development,test and evaluation, engineering,
procurement,and technicalfacilities. The Departmentbelieves that research,development,
engineering,procurementand other technicalcapabilitiesare elementsof military captured
within criteria one through four. The Departmentwill considermilitary value in a way that
incorporatestheseelements.
(f) Severalcommentorsalso raisedconcernsthat the criteria did not take into accountthe
availability of intellectual capital, critical trade skills, a highly trained work force, allied
presence,and the synergy among nearbyinstallations and betweenDoD facilities and nearby
industrial clustersand academicinstitutions. DoD appreciatesthe importance of having an
availablepool of intellectual capital and critical trade skills that make up, and allow us to recruit
and retain, a highly trained and experiencedwork force, as well as the synergyprovided by
nearbyfacilities. DoD believesthat, to the extent that the availability of highly skilled civilian or
contractorwork forces and relationships with local institutions and other installations influence
our ability to accomplishthe mission, they are capturedin criteria one, three and seven.
(g) Somecommentorsurged DoD to considerstrategic location and irreplaceableproperties
and facilities as part of military value. DoD agreesthat the availability and condition of land and
facilities are an integral part of military value and believestheseissuesare covered under
criterion two. Furthermore,the strategic location of DoD facilities informs criteria one and
three.
(h) Somecommentorssaid that an installation's demonstratedability to transform, streamline
businessoperations,and managesuccessfulprogramsshould be consideredas part of military
value. In someinstancescommentorspraisedthe outstandingwork of a particular installation or
group of installations. DoD recognizesand appreciatesthe outstandingwork done by its
installations. We believe that criteria one and three captureboth the ability to perform a mission
and the quality of that work -both of which, in turn, capturethe willingness to transform and
streamline.
(i) Somecommentorsrecommendedthat DoD consideran installation's role in homeland
defense,security, domesticpreparedness,and the war on terrorism as a part of military value.
Somesuggestedthat an installation's proximity to and ability to protect vital national assets,
transportationfacilities, major urban centersand international borderswas a key consideration,
while othersindicated that geographicdiversity or complete isolation should be the real objective
in orderto enhancesecurity. The securityof our nation, whether expressedas homeland defense,
domesticpreparedness,or fighting the war on terrorism, is an important DoD mission. Both the
BRAC legislationand DoD' s implementationof it ensurethat homeland defenseand security are
consideredin the BRAC process. Specifically, criterion two requires DoD Componentsto
consider"[ t]he availability and condition of land, facilities and associatedairspace. ..as staging
areasfor the use of the Armed Forces in homelanddefensemissions." Additionally, as a mission
of DoD, all of theseissuesare capturedby the requirementsof criteria one and three.
(j) Somecommentorsnoted that, in someareasof the country, expanding civilian use of
adjacentlands is encroachingupon military propertiesand has impacted critical training
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requirementsand preparationsfor deployments. Somesaid that installations located in rural
regions with accessto large areasof operationalairspaceover land and water as well as direct
ingress/egressroutes from water to land will be key to future military operationaland training
requirements. DoD believes that the issue of encroachmentis capturedby criterion two which
requiresthe Departmentto considerthe availability and condition of land, facilities and
associatedairspace.
(k) Somecommentorsrecommendedthat DoD considerthe difficulty of relocatingmissions
and functions requiring federal nuclear licensesor environmentalpermits, as part of military
value. DoD recognizesthe importance of federal licensesand permits. The ability to
accommodatecurrentand future force requirements,which includes Federal licensing and
permitting requirements,is covered under criteria one, two and three. Furthermore,the impact of
environmentalcomplianceactivities (i.e., permits and licenses)is also specifically capturedin
criterion eight.
(1) A few commentorswere concernedthat the "cost of operations" languagein criterion
four would not be a meaningful measureof military value becauseit would appearto encourage
the closure or realignmentof an installation in a high cost of living area,despite important
strategicreasonsfor retaining that installation. BecauseDoD operatesin a resourceconstrained
environment,all resources-land, facilities, personnel,and financial -have value. The
Departmentbelieves monetaryresourcesare an inextricable componentof military value
becauseall equipment,services,and military salariesare dependenton the availability of this
resource. Therefore,the extentto which one installation can be operatedat less costthan another
is worthy of consideration,particularly for businessoperations,althoughthe importanceof this
will vary dependingon the function involved.
(3) Other Considerations:
(a) Criteria five through eight deal with other considerations,suchas costsand savingsand
economic,community, and environmentalimpacts.
(b) Somecommentorsrecommendeda standardizedinterpretationof the costcriteria. The
Departmentagreesthat costsand savings must be calculateduniformly. To that end, we are
improving the Costof Base RealignmentActions (COBRA) model used successfullyin previous
BRAC rounds to addressissuesof uniformity and will provide it to the Military Departmentsand
the Joint Cross-ServiceGroups for calculation of costs,savings,and return on investmentin
accordancewith criterion five.
(c) Severalcommentorsstatedthat total mission supportcostsassociatedwith reestablishing
or realigning a military activity should be considered,including suchthings as the costsof
reestablishingintellectual capital and relationships with nearbybusinessesand academic
institutions, the costsassociatedwith mission disruption, the costs of contractorrelocations,and
the availability and reliability of raw materials and supplies. DoD has improved the Costof Base
RealignmentActions (COBRA) model used in prior BRAC rounds to more accuratelyand
appropriatelyreflect the variety of costs of baserealignmentand closure actions. DoD will
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provide it to the Military Departmentsand the Joint Cross-ServiceGroups for calculation of
costs,savings,and return on investmentin accordancewith criterion five.
(d) A few commentorsstated DoD should considerthe total resourceimpact of a
recommendationto the Federal Governmentand reflect both costsand savings. The Department
understandsthe decisionmaking value of comprehensiveconsiderationof costs. In accordance
with section29l3(d), the Department's application of its cost and savings criterion will "take
into accountthe effect of the proposedclosure or realignment on the costsof any other activity
of the Departmentof Defense or any other Federal agencythat may be required to assume
responsibility for activities at the military installations." The Departmentwill issueguidanceto
the Military Departmentsand the Joint Cross ServiceGroups that incorporatesthis requirement
in the application of criterion five.
( e) Somecommentorsaskedthat DoD considerthe impact of closing or realigning an
installation on the local community and on military retirees in the areawho rely on the
installation's medical facilities, commissary,and other activities. While military value criteria
must be the primary consideration,the impact of a closure or realignment on the local
community, including military retirees residing therein, will be consideredthrough criteria five,
six, and seven. The DoD Componentswill calculateeconomic impact on existing communities
by measuringthe effects on direct and indirect employmentfor eachrecommendedclosure or
realignment. Theseeffects will be determinedby using statistical information obtained from the
Departmentsof Labor and Commerce. This is consistentwith the methodology used in prior
BRAC rounds to measureeconomic impact.
(f) Somecommentorsaskedthat DoD recognizethat their state, facility or community was
affected by closuresand realignmentsin prior BRAC rounds and that it, therefore,be protected
in this round. Theseand other commentorssuggestedthat the Departmentview economic
impact cumulatively or take into accountthe needof a community for an economic boost. Still
others suggestedthat the current BRAC round respectdecisionsmade in prior BRAC rounds and not take any action inconsistentwith a prior recommendation. DoD recognizesthe impact
that BRAC can have on local communities,and makes every effort in the implementationphase
ofBRAC to softenthe effect of closuresand realignmentson local communities. However, the
BRAC statute specifically requiresthe Secretaryto considerall military installations in the
United Statesequally, without regard to whetherthat installation has previously beenconsidered
for closure or realignment.
(g) The United StatesGeneralAccounting Office (GAO) statedthat the draft criteria, if
adopted,would add an elementof consistencyand continuity in approachwith those of the past
three BRAC rounds. It noted that its analysisof lessonslearned from prior BRAC rounds
affinned the soundnessof thesebasic criteria and generallyendorsedtheir retention for the
future, while recognizing the potential for improving the processby which the criteria are used in
decision-making. It suggestedthat DoD clarify two issues: (1) the Department's intention to
considerpotential coststo other DoD activities or federal agenciesthat may be affected by a
proposedclosure or realignment recommendationunderthe criterion related to cost and savings,
and (2) the extentto which the impact of costsrelatedto potential environmentalrestoration,
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wastemanagement,and environmentalcomplianceactivities will be included in cost and savings
analysesof individual BRAC recommendations.
As discussedabove, DoD recognizesthat the BRAC legislation required it to considercost
impacts to other DoD entities and Federalagenciesin its BRAC decision-makingand will issue
implementing guidanceto ensurethat suchcostsare consideredunder criterion five.
On the secondpoint raised by GAO, which was echoedby a few other commentors,DoD policy
guidancehas historically stipulated that environmentalrestorationcostswere not to be factored
into analysesof costsand savingswhen examiningpotential installations for realignmentand
closure, since DoD was obligated to restorecontaminatedsites on military installations
regardlessof whether or not they were closed. DoD concurs with GAO that determining such
costscould be problematic in advanceof a closuredecision, since reuseplans for BRAC
propertieswould not yet be determinedand studiesto identify restorationrequirementswould
not yet be completed.As suggested,DoD will issueguidanceto clarify considerationof
environmental costs.
(h) A few commentorssuggestedthat criterion seven-the ability of both the existing and
potential receiving communities' infrastructureto supportforces, missions,and personnel-be
included in military value and receive priority consideration. DoD believes,and has
demonstratedin previous BRAC rounds, that factors falling within this criterion canbe applied
within the military value criteria if they directly relate to the elementsof criteria one through
four.
(i) A few commentorsaskedthe Departmentto considerthe socialas well as the economic
impact on existing communities. The Departmentrecognizesthat its installations can be key
componentsof the social fabric of the communities in which they are located, in both a positive
or negative sense. For instance,the BRAC statuterequires that the Departmentconsiderany
notice received from a local governmentin the vicinity of a military installation that it would
approve of the closure or realignment of the installation. Additionally, becausesocial impact is
an intangible factor that would be difficult for the Departmentto quantify and measurefairly,
issuesof social impact are bestaddressedto the BRAC Commissionduring its processof
receiving public input.
G) A few commentorswantedto ensurethat, as the Departmentconsidersthe ability of
community infrastructure to supportthe military, DoD view that ability as evolving, and consider
the willingness and capacity of the community to make additional investments. The
infrastructure provided by the communitiessurrounding our installationsis a key componentin
their efficient and effective operation. As the BRAC legislation has establisheda stringent
timetable for the Secretaryto arrive at recommendations,the Departmentmust focus on the
existing, demonstratedability of a community to supportits installation, especiallyas potential
investmentactions may not translateinto reality.
(k) One comrnentorrequestedclarification that criterion eight -environmental impact includes considerationof the impact of the closure or realignmenton historic properties. As has
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beenthe casein prior rounds of baseclosure,the Departmentwill considerhistoric properties as
a part of criterion eight.
(1) Severalcomrnentorsstated that the criteria should considerthe effect of closuresand
realignmentson the quality of life and morale of military personneland their families. The
Departmentagreesthat the quality of life provided to its military personneland their families
significantly contributesto the Department's ability to recruit and retain quality personnel.
Military personnelare betterable to perform their missions when they feel comfortable that their
needsand those of their families are takencare of. The Departmentbelieves that quality of life
is capturedthroughoutthe criteria, particularly criterion seven.
C. Previous Federal Register References
1.
2.
3.
4.
5.
6.
7.
55 FR 49678, November 30, 1990: Draft selectioncriteria and requestfor comments.
55 FR 53586, December31, 1990: Extend commentperiod on draft selectioncriteria.
56 FR 6374, February 15, 1991: Final selectioncriteria and analysisof comments.
57 FR 59334, December15, 1992: Final selectioncriteria.
59 FR 63769, December9, 1994: Final selectioncriteria
68 FR 74221, December23,2003: Draft selectioncriteria and requestfor comments.
69 FR 3335, January23, 2004: Extend commentperiod on draft selectioncriteria.
DATED: February 10,2004
Linda Bynum
Alternate OSD Federal Register
Liaison Officer
Departmentof Defense