This is the accessible text file for GAO report number GAO-04-220 
entitled 'Depot Maintenance: Army Needs Plan to Implement Depot 
Maintenance Report's Recommendations' which was released on January 08, 
2004.

This text file was formatted by the U.S. General Accounting Office 
(GAO) to be accessible to users with visual impairments, as part of a 
longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to Webmaster@gao.gov.

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately.

Report to Congressional Committees:

United States General Accounting Office:

GAO:

January 2004:

DEPOT MAINTENANCE:

Army Needs Plan to Implement Depot Maintenance Report's 
Recommendations:

GAO-04-220:

GAO Highlights:

Highlights of GAO-04-220, a report to Senate and House Armed Services 
Committees 

Why GAO Did This Study:

Each year, the U.S. Army spends about $3 billion on depot-level 
maintenance and repair work for weapons systems and other equipment. 
However, because its data gathering and reporting processes have been 
limited, the Army historically has been unable to fully identify how 
much depot-level maintenance takes place outside its five public 
depots. As a result, it has not been able to determine with precision 
how well it was meeting statutory requirements to limit contracted 
depot-level maintenance work to 50 percent of the program budget. In 
the House report on the Fiscal Year 2001 Defense Authorization Act, 
Congress directed the Army to report on the proliferation of depot-
level maintenance work at nondepot facilities and asked GAO to review 
that report. GAO examined the extent to which (1) the Army’s report 
identifies the amount of depot-level maintenance work done outside 
public depots; (2) the Army can account for its depot-level 
maintenance workload, as required by statute; and (3) the corrective 
actions in the report are likely to address the proliferation issue 
and enhance the Army’s reporting.

What GAO Found:

The Army’s proliferation report, issued in September 2003, did not 
fully identify the extent of depot-level maintenance work performed 
outside the Army’s public depots. The report estimated that the Army 
underreported its fiscal year 2001 $2.7 billion depot-level 
maintenance program by $188.6 million but indicated that this was a 
rough estimate and that further analysis is needed. It attributed this 
underreporting largely to work performed in two categories—work that 
met the criteria for depot-level maintenance work but was not reported 
as such and work at nondepot field facilities that involved depot-
level maintenance tasks. GAO’s prior reviews also identified these 
categories as key contributors to underreporting. While the report 
noted that the Army has an extensive maintenance infrastructure with 
redundant capabilities, it did not address the extent of this 
redundancy.

The lack of complete information on the extent of depot-level 
maintenance workloads limits the Army’s ability to fully account for 
this work in the Department of Defense’s (DOD) annual report to 
Congress on the allocation of public- and private-sector depot-level 
maintenance spending. The 2003 proliferation report identified key 
Army limitations, including inconsistencies in applying the 
congressionally mandated definition of “depot maintenance,” weaknesses 
in its management information systems, and the failure to follow 
established policies and procedures for authorizing depot-level 
maintenance work at nondepot facilities. GAO’s current analysis and 
prior work confirmed that these limitations make it difficult for the 
Army to fully account for its maintenance workload as it moves closer 
to the 50 percent ceiling for work performed by contractors. GAO’s 
most recent report on the Army’s 50-50 reporting for fiscal year 2002 
showed that, after adjustments for known underreporting, the 
percentage of private-sector work increased to 49 percent. 

If implemented, the 29 recommendations in the 2003 report could 
enhance the Army’s ability to report on its 50-50 data and to evaluate 
the proliferation of depot-level maintenance work at nondepot 
facilities. The recommendations, which are consistent with those that 
GAO has previously made, are focused on key problem areas, such as the 
need for an improved understanding about the 50-50 rule and for 
compliance with reporting policies and procedures. Efforts have been 
undertaken to address some of the problem areas. However, the Army has 
not yet developed an action plan that identifies priorities, time 
frames, roles and responsibilities, evaluation criteria, and resources 
for managing the implementation of the recommendations. Until the Army 
does this, it will be difficult to assess to what extent the Army is 
likely to meet its desired objectives. While improvements should be 
accomplished, the complexity and vastness of the Army’s maintenance 
system and continuing questions about such issues as the definition of 
“depot maintenance” and changing maintenance strategies could continue 
to present challenges in fully recording all maintenance work that 
should be captured.

What GAO Recommends:

GAO recommends that the Secretary of the Army develop an action plan 
to implement the recommendations in the Army’s 2003 maintenance 
proliferation report. DOD concurred with GAO’s recommendation.

www.gao.gov/cgi-bin/getrpt?GAO-04-220.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact Barry W. Holman at 
(202) 512-8412 or holmanb@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Army's 2003 Proliferation Report Did Not Fully Identify Depot-Level 
Maintenance Performed outside Public Depots:

Army Cannot Provide Congress with a Complete Accounting of Its Depot-
Level Maintenance Work:

Army Needs Action Plan to Address Proliferation and Reporting Issues:

Conclusions:

Recommendation:

Agency Comments and Our Evaluation:

Appendix I: Scope and Methodology:

Appendix II: Army Maintenance Sites:

Appendix III: Army Report's Issues and Recommendations:

Appendix IV: Comments from the Department of Defense:

Related GAO Products:

Tables:

Table 1: Categories in Which Depot-Level Maintenance Work Was Not 
Identified in Fiscal Year 2001:

Table 2: Capacity and Capability Information on 17 Sites That 
GAO Visited:

Figures:

Figure 1: Army Maintenance Structure:

Figure 2: Various Army Maintenance Facilities:

Abbreviations:

DOD: Department of Defense:

GAO: General Accounting Office:

United States General Accounting Office:

Washington, DC 20548:

January 8, 2004:

The Honorable John W. Warner: 
Chairman: 
The Honorable Carl Levin: 
Ranking Minority Member: 
Committee on Armed Services: 
United States Senate:

The Honorable Duncan L. Hunter: 
Chairman: 
The Honorable Ike Skelton: 
Ranking Minority Member: 
Committee on Armed Services: 
House of Representatives:

Each year the Department of Defense (DOD) submits a report to Congress 
showing that billions of dollars have been spent on depot maintenance 
and repairs for Army weapons systems and support equipment.[Footnote 1] 
In recent years, depot-level maintenance and repair work has expanded 
from the traditional fixed-location public depots to numerous nondepot 
repair facilities in the field. This shifting of depot-level 
maintenance workload to field facilities has contributed to uncertainty 
about the magnitude of depot-level maintenance capabilities and the 
distribution of work between public and private facilities. In October 
1999, we reported on the Army's first congressionally directed report 
on the proliferation of depot-level maintenance activities at nondepot 
facilities, noting that the Army faced a number of continuing 
challenges in attempting to address the fragmentation of depot-level 
maintenance work and the proliferation of depot-level maintenance 
facilities. We noted that the Army's report did not sufficiently 
identify the extent of depot-level maintenance work performed at 
nondepot facilities.[Footnote 2]

In the House Armed Services Committee's report on the fiscal year 2001 
defense authorization act,[Footnote 3] Congress directed the Secretary 
of the Army to provide a report that identifies the proliferation of 
depot-level maintenance performed outside of the five public depots. 
The Army formally submitted its report in September 2003. The 
committee's report also requested that we provide a review of the 
Army's report, including an assessment of the Army's ability to comply 
with 10 U.S.C. 2466, which governs the distribution of depot-level 
maintenance funds between public and private facilities. Our review 
addresses the extent to which (1) the Army's report identifies the 
amount of depot-level maintenance work performed outside the public 
depots, (2) the Army can account for its depot-level maintenance 
workload as required by 10 U.S.C. 2466, and (3) the corrective actions 
in the Army report are likely to address the proliferation of depot-
level maintenance activities and enhance the accuracy and completeness 
of 50-50 reporting.

To address these objectives, we drew largely from the body of work we 
have done in the past on the Army's depot-level maintenance issues. In 
addition, we interviewed officials at Army headquarters, Army major 
commands, and maintenance facilities at selected field installations to 
gain a better understanding of the implications of the Army report's 
findings and recommendations. A detailed description of our scope and 
methodology is included in appendix I.

Results in Brief:

The Army's 2003 report does not fully identify the extent of depot-
level maintenance work performed at nondepot facilities and, thus, is 
not fully responsive to the mandate's requirement that the Army 
identify the proliferation of these types of facilities. The report's 
identification of proliferation was limited to an estimated $188.6 
million that the Army might have underreported in its $2.7 billion 
depot-level maintenance program for fiscal year 2001. This amount was 
said to be a preliminary rough estimate that needed further validation 
and, in our view, is not fully indicative of all the depot-level 
maintenance work being done at nondepot facilities. The report 
indicated that this underreporting was largely due to the performance 
of depot-level maintenance tasks by nondepot facilities in such areas 
as (1) programs that did not identify depot-level maintenance work 
tasks but met the criteria for depot-level maintenance work and 
(2) field-level maintenance involving depot-level tasks. From our prior 
work and current analysis, we agree that these two areas are major 
contributors to the Army's underreporting of its depot-level 
maintenance work. Although the report pointed out that the Army has an 
extensive maintenance infrastructure with redundant capabilities and 
capacities, it did not provide any information on the extent of this 
redundancy or the types of maintenance facilities that could be 
consolidated. Otherwise, the Army's report was consistent with our 
findings in recent years and our work for this engagement.

The lack of complete information on the extent of depot-level 
maintenance work performed in nondepot facilities limits the accuracy 
and completeness of DOD's annual report to Congress on the allocation 
of depot-level maintenance funds between the public and private 
sectors. In our analysis of the Army's 50-50 reporting, we have said 
that underreporting depot work at nondepot facilities is one of the 
limitations affecting the Army's ability to fully account for its 
depot-level maintenance work. Consistent with our prior work in this 
area, the Army's report identified several key factors affecting the 
Army's ability to precisely capture and report its depot-level 
maintenance data at nondepot facilities. These factors include (1) the 
inconsistent application of the congressionally mandated definition of 
"depot maintenance" and related guidance, (2) weaknesses in management 
information systems for collecting and reporting workload data, and (3) 
the failure to follow established policies and procedures for 
authorizing depot-level work at field-level facilities and outsourcing 
depot-level maintenance workloads. Our current analysis and our prior 
work identify these factors as underlying causes affecting the Army's 
determination that it has complied with the 50-50 depot-funding 
requirement. While neither the Army nor we can precisely quantify the 
extent of depot-level maintenance work that should have been included 
in the 50-50 analysis, this information is key for the Army to 
effectively manage its depot-level maintenance program and for ensuring 
the accurate and complete reporting of where depot-level maintenance is 
being performed as required by the 50-50 legislation. Such data become 
even more significant as the Army moves closer to the ceiling permitted 
for work performed by contractors. For example, the Army's depot-level 
maintenance data for fiscal year 2002 indicated that funding in the 
private sector for depot-level maintenance was below the 50 percent 
limit. However, our adjustments for known errors in reporting increased 
the percentage of private-sector work to 49 percent from the 46.5 
percent reported by the Army. An increase of more than 1 percent in the 
use of the private sector to perform more depot-level maintenance in 
the future could cause the Army to exceed its statutory limitation and 
thereby be required to seek a national security waiver and notify 
Congress as provided for in 10 U.S.C. 2466.

If fully implemented, the recommendations in the Army's report could 
improve the identification of additional depot-level maintenance work 
in nondepot facilities, resulting in improving the accuracy and 
completeness of the 50-50 reporting. The Army's proliferation report 
generally addressed key problem areas, and the recommendations were 
consistent with recommendations we have made in the past. Efforts have 
been undertaken to address some of the problem areas; however, no 
action plan to manage the implementation has been developed. Evaluating 
the success of the proposed 29 recommendations will be difficult until 
the Army develops an action plan with priorities, time frames, 
responsible organizations, and evaluation criteria, and until the 
resources required have been identified. At the same time, while 
improvements should be accomplished, the complexity and vastness of the 
Army's maintenance system and continuing questions about such issues as 
the definition of "depot maintenance" and changing maintenance 
strategies could continue to present challenges in fully recording all 
depot-level maintenance work that should be captured.

In this report, we are recommending that the Army establish a plan to 
manage the implementation of the recommendations in the depot 
proliferation report. In commenting on a draft of this report, DOD 
concurred with our recommendation, noting that the Army is establishing 
an integrated product team to develop an action plan. The response 
stated that some of the recommendations in the Army's report would 
require modification.

Background:

The Army uses maintenance capabilities in both the public and private 
sectors to maintain, overhaul, and repair its military weapons systems, 
such as missiles, combat vehicles, tactical vehicles, aircraft, and 
communication and electronic equipment. The level at which maintenance 
work is performed depends largely on authorized capability, worker 
skills, and predefined work requirements. Legislative 
requirements: which play an important role in managing the allocation of 
depot-level maintenance work: mandate that DOD provide Congress with 
annual reports on the distribution of funding for depot-level 
maintenance workloads in the public and private sectors.

The Army assigns maintenance work to four categories--unit support, 
direct support, general support, and depot-level support.[Footnote 4] 
Unit and direct support workloads, which are limited to routine or 
recurring requirements, such as oil changes and the removal and 
replacement of components, are performed at military units in field 
locations and funded by direct appropriations for operations and 
maintenance.

General support, which consists of the repair and overhaul of parts and 
assemblies and some end items such as trucks, is generally performed at 
fixed (nonmobile) industrial facilities located on Army posts, camps, 
and stations, and it is funded by direct appropriations for operations 
and maintenance.[Footnote 5] Military personnel, government-employed 
civilians, or contractor employees may perform this maintenance.

Depot-level support, which includes the overhaul; upgrading; and 
rebuilding of parts, assemblies, and subassemblies; and testing and 
reclamation of equipment, is the most intensive category of maintenance 
and requires the highest level of skilled workers and more 
sophisticated test and plant equipment. It traditionally has been 
performed by (1) government-employed civilians working at government-
owned industrial facilities under the command and control of the Army 
Materiel Command (currently five public depots) or (2) contractor 
personnel working in contractor owned and operated facilities 
performing work specified by Army Materiel Command-managed maintenance 
contracts. The Army's five government-operated maintenance 
depots[Footnote 6] are managed within the Army Working Capital 
Fund.[Footnote 7] Contract depot-level maintenance work is not managed 
under the working capital fund.

Figure 1: Army Maintenance Structure:

[See PDF for image]

[End of figure]

The Army has two categories of depot-level maintenance activities:

* Activities that have been designated and organized by design and 
purpose to primarily perform depot-level maintenance and repair tasks. 
These activities would include the Army Materiel Command's public 
depots; the Army's forward deployed maintenance depots; and contractor 
depots, primarily located at both the national and installation levels.

* Activities below the depot level that have been granted approval to 
perform specific depot-level tasks through a special or one-time 
authorization or that have been designated as a source of repair. 
These activities include Army National Guard Readiness Sustainment 
Maintenance Sites and Aviation Classification Repair Activity Depots, 
Army Reserve Installation Materiel Maintenance Activities, and Army 
Forces Command Contract Maintenance Facilities. These activities are 
primarily located at the installation level, and the work may be done 
by either government or contractor personnel.

Operations of the Army depots are guided by legislative requirements 
that divide the amount of depot work between the public and private 
sectors and add specificity to how such work is to be defined. For 
example, 10 U.S.C. 2464 provides for a government owned and operated 
core logistics capability that is sufficient to ensure an effective and 
timely response to a mobilization or other national emergency. Also, 10 
U.S.C. 2466 generally prohibits the use of more than 50 percent of the 
funds made available in a fiscal year for depot-level maintenance and 
repair by nonfederal personnel.

In addition, 10 U.S.C. 2460 defines depot-level maintenance to 
encompass material maintenance or repair requiring the overhaul, 
upgrading, or rebuilding of parts, assemblies, or subassemblies and the 
testing and reclamation of equipment, regardless of the source of funds 
for the maintenance or repair or the location where maintenance or 
repair work is performed. Depot-level maintenance also encompasses 
software maintenance, interim contractor support,[Footnote 8] and 
contractor logistics support[Footnote 9] to the extent that work 
performed in these areas is depot-level maintenance. The statute 
excludes from depot-level maintenance the nuclear refueling of an 
aircraft carrier, the procurement of major modifications or upgrades of 
weapons systems that are designed to improve program performance, and 
the procurement of parts for safety modifications, although the term 
"depot maintenance" does cover the installation of parts for safety 
modifications. Congress has made changes to various depot-level 
maintenance requirements over the years. For example, the 1998 Defense 
Authorization Act established a statutory definition of depot-level 
maintenance and repair and increased DOD's authority to use its depot-
level maintenance funds for the private sector's performance of the 
work from 40 to 50 percent.[Footnote 10]

On the basis of statutory language defining depot-level maintenance, 
the Office of the Secretary of Defense issues annual guidance to the 
military departments for reporting their public-private workload 
allocations. The military departments also issue internal instructions 
to manage the data collection and reporting process tailored to their 
individual organizations and operating environments.

As we have reported in recent years in examining DOD's compliance with 
its so-called "50-50 requirement" under 10 U.S.C. 2466, all of the 
military departments have continuing data errors and inconsistencies in 
reporting and problems in documenting and independently validating 
their annual reports. We also have recognized the limitations of their 
financial systems, operations, and controls, as well as their 
continuing inability to capture and report the full costs of depot-
level maintenance programs. Some of our most recent reports on depot-
level maintenance issues are listed in the Related GAO Products section 
of this report.

We previously reported that the Army had not sufficiently identified 
the extent of depot-level maintenance work performed at nondepot 
facilities in its April 14, 1999, report to the House Committee on 
Armed Services on depot proliferation.[Footnote 11] While the Army's 
report indicated that 40 staff years of depot-level maintenance work 
was performed outside of the formal depot system by nondepot 
maintenance providers operating under specialized repair authorities, 
it also recognized that the figure was likely understated for a variety 
of reasons to include limitations in systems and procedures to fully 
quantify such work. We agreed. We also noted that in July 1999 the Army 
designated its Army Materiel Command as its National Maintenance 
Manager with responsibility for overseeing the Army's logistics and 
maintenance support programs and managing maintenance facilities. In 
doing so, we noted then that while the Army recognized that it needed 
to modify and standardize Army data systems to fully account for depot-
level maintenance work at all locations, it had not established clear 
action plans, milestones, and funding requirements for doing so.

Our September 2003 report on DOD's compliance with the 50-50 
requirement found that the Army's latest reporting on depot-level 
workloads for fiscal years 2001 and 2002 had utilized a new, more 
centralized financial system to collect 50-50 data that corrected some 
of the transcription errors we had found the previous year but that we 
continued to find errors, omissions, and inconsistencies in its 
data.[Footnote 12] Moreover, we reported that, as in prior years, the 
Army underreported public-and private-sector depot-level maintenance 
work at field locations as it continues unfinished efforts to 
consolidate maintenance activities and better control the proliferation 
of depot-level tasks at nondepot facilities.

Army's 2003 Proliferation Report Did Not Fully Identify Depot-Level 
Maintenance Performed outside Public Depots:

Although the mandate directed the Army to identify the proliferation of 
depot-level maintenance performed outside the public depots, the Army's 
report on depot-level maintenance proliferation did not fully identify 
the extent of depot-level maintenance work performed at nondepot 
facilities. Instead, the report estimated that depot-level maintenance 
work valued at $188.6 million for fiscal year 2001 was not included in 
the Army's depot-level maintenance data and that further validation of 
this amount was needed. While this estimate may not be fully indicative 
of depot-level maintenance work being performed outside the public 
depots, it indicates underreporting in this area that is consistent 
with the observations we have made in our prior work. Although the 
report recognized that the Army has redundant capabilities and 
capacities, it did not provide any information on the extent of this 
redundancy or the extent of maintenance activities that could be 
consolidated. We also have previously reported the existence of this 
problem.[Footnote 13]

Estimate of Work outside Depots Is Incomplete:

While the Army's report provided an estimate of depot-level maintenance 
work that was not appropriately identified as such in fiscal year 2001, 
it acknowledged that the amount was incomplete and needed further 
validation. The report listed seven specific areas where depot-level 
maintenance work performed by nondepot facilities was not identified 
and estimated this amounted to be $188.6 million. As illustrated by 
table 1, most of the unidentified amount occurred in field-level 
facilities that perform depot-level maintenance tasks. According to the 
report, two categories of work accounted for about 75 percent of the 
$188.6 million. These were facilities that performed field-level 
maintenance under the National Maintenance Program[Footnote 14] with 
embedded depot tasks and those under One-Time Repair 
authorizations.[Footnote 15] The report pointed out that some of the 
unidentified depot-level maintenance work resulted from 
a misunderstanding between the Army Materiel Command and its 
subordinate commands over which organization would report this type 
of work.

Table 1: Categories in Which Depot-Level Maintenance Work Was Not 
Identified in Fiscal Year 2001:

Category of work not identified: 1. The overhaul, upgrading, and 
rebuilding of equipment that met the definition of depot-level 
maintenance; Amount: $3.3; Percent: 1.8.

Category of work not identified: 2. Reimbursable depot support at the 
installation level; Amount: 22.4; Percent: 11.9.

Category of work not identified: 3. Maintenance covered by warranty 
associated with the purchase price of equipment; Amount: 4.0; Percent: 
2.1.

Category of work not identified: 4. Field-level maintenance under the 
National Maintenance Program with embedded depot-level tasks; Amount: 
75.9; Percent: 40.2.

Category of work not identified: 5. Contract support at a public 
depot; Amount: 10.4; Percent: 5.5.

Category of work not identified: 6. Maintenance tasks performed under 
Specialized Repair Authority; Amount: 7.6; Percent: 4.0.

Category of work not identified: 7. Maintenance tasks performed under 
One-Time Repair authorization at field-level facilities; Amount: 65.0; 
Percent: 34.5.

Category of work not identified: Total; Amount: $188.6; Percent: 100.0.

Source: U.S. Army's 2003 Proliferation Report.

[End of table]

The report's identification of unidentified depot-level maintenance 
work performed by nondepot facilities is consistent with our prior 
reviews of the Army's annual 50-50 data. For example, in our most 
recent report, we identified work categories such as unreported one-
time repair actions and unreported work by commands that did not 
receive Army reporting guidance, which contributed to the Army's 
inability to fully account for its depot-level maintenance work in 
2002.[Footnote 16] We noted that, as in past years, the Army did not 
fully identify public-and private-sector depot-level maintenance work 
at field locations as it continued unfinished efforts to consolidate 
maintenance activities and better control the proliferation of depot-
level tasks at nondepot locations. While neither we nor the Army can 
precisely identify the amount of depot-level maintenance work being 
performed in nondepot maintenance facilities, our prior work and the 
Army's latest report suggest that the $188.6 million estimate should 
not be construed as fully representing the amount of depot-level 
maintenance work performed at nondepot facilities.

Army Has an Extensive Maintenance Infrastructure, but Capacity for 
Depot Maintenance Activities at Nondepot Locations Has Not Been Fully 
Addressed:

The Army's proliferation report pointed out that the Army's maintenance 
infrastructure has redundant capabilities and capacities that could be 
consolidated and streamlined to be more cost-effective. While the 
active Army, Army National Guard, and Army Reserve operate extensive 
maintenance facilities, some of which have the capability and capacity 
to perform depot-level maintenance work, the report did not provide 
any data to quantify the extent of redundancy or identify any possible 
candidates for consolidation. It did suggest that the Army further 
study the issue for opportunities to streamline its current expansive 
depot-level maintenance infrastructure. Moreover, the Army's full 
implementation of its National Maintenance Program: another report 
recommendation: is also intended to address streamlining the Army's 
maintenance infrastructure.

While we did not attempt to identify the full extent of this 
maintenance infrastructure as part of this review, our analysis 
supports the Army report's contention that the Army has extensive 
nondepot facilities, some of which have the capability and capacity for 
depot-level maintenance tasks and are performing depot-level 
maintenance work. At the Army sites we visited, we observed maintenance 
activities involved with all levels of maintenance for ground and 
aviation systems. Similar to the Army's public depots, these activities 
occupied large facilities that included machine shops, automobile and 
heavy-equipment repair shops, paint and body shops, and sandblasting 
areas. The pictures in figure 2 show some contrast and similarities in 
maintenance facilities at depot and nondepot locations.

Figure 2: Various Army Maintenance Facilities:

[See PDF for image]

[End of figure]

Some of the activities had the capability and capacity for depot-level 
maintenance activities and were performing depot-level maintenance 
work. For example, the Readiness Business Center at Fort Campbell, 
Kentucky, has been authorized to perform depot-level maintenance tasks 
to repair components for tactical wheeled vehicles, radios, and 
helicopters. Of the total $27.1 million maintenance work performed by 
the Business Center in fiscal year 2002, about $4.5 million, or about 
17 percent, was identified as depot-level maintenance. Also maintenance 
officials at several facilities at Fort Riley, Kansas: three of them 
operated by the National Guard, one by the Fort Riley Directorate of 
Logistics, one by the Forces Command, and one by the Army 
Reserve: estimated that their maintenance work for fiscal year 2002 
totaled about $58.5 million. The National Guard performed about $35 
million worth of depot-level maintenance in fiscal year 2002 and 
expects this workload to significantly increase. More details on the 
Army's maintenance infrastructure are provided in appendix II.

We have previously reported on the Army's proliferation of facilities 
that perform depot-level maintenance work and the lack of a strategic 
plan for depots to guide its decisions on this issue. In an October 
1999 report, we pointed out that the Army's April 1999 study of the 
proliferation of depot-level maintenance activities at nondepot 
facilities did not sufficiently identify the extent of this type 
work.[Footnote 17] We also highlighted that the Army's study, citing 
inadequate data on the subject of proliferation, did not make any 
recommendations for consolidating depot-level maintenance facilities. 
We noted that a key challenge that the Army faced was determining and 
overseeing the amount of depot-level maintenance capabilities 
controlled by major commands in the active Army and the Army National 
Guard. For various reasons, these commands were reluctant to reduce 
their present capability for performing depot-level maintenance 
workloads. For example, Reserve and National Guard Bureau officials 
said that having local maintenance facilities capable of performing 
some depot-level tasks was a readiness issue in that such facilities 
allowed their units more rapid turnaround time on equipment requiring 
this type of repair.

In July 2003 we reported that work performed in the Army's public 
depots had declined by 36 percent from fiscal year 1987 through fiscal 
year 2002, while the total depot-level maintenance program 
grew.[Footnote 18] We pointed out that future workload projections 
indicated further decline but that the full impact of the Iraq conflict 
on future depot-level workload was largely unknown. Among the host of 
factors that contributed to this decline were (1) DOD's policy for 
greater reliance on the private sector for depot-level support of new 
weapons systems and major upgrades and (2) its increased reliance on 
the use of regional repair activities and private-sector contractors 
for work that might otherwise be done in the depots. We noted that 
neither DOD nor the Army had a comprehensive and current depot-level 
maintenance strategic plan, which was an essential aspect of ensuring 
future depot efficiency and viability.

Army Cannot Provide Congress with a Complete Accounting of Its Depot-
Level Maintenance Work:

Without complete information on the extent of depot-level maintenance 
work performed in nondepot facilities, DOD's annual report to Congress 
cannot fully account for the allocation of depot-level maintenance 
funds between the public and private sectors. In our analysis of DOD's 
50-50 reporting, we have said that underreporting depot work in 
nondepot facilities is one of the limitations affecting the Army's 
ability to fully account for its depot-level maintenance work. 
Consistent with our work in this area, the Army's report on 
proliferation identifies a number of factors that preclude the Army 
from fully capturing and reporting its depot-level maintenance data at 
nondepot facilities. These factors include (1) inconsistent application 
of the congressionally mandated definition of "depot maintenance" and 
related guidance, (2) weaknesses in the management information systems 
for collecting and reporting data, and (3) the failure to follow 
established policies and procedures for authorizing depot-level work at 
field-level facilities and outsourcing work. Our current analysis and 
our prior work identify these factors as underlying causes affecting 
the Army's determination that it has complied with the 50-50 rule. 
Furthermore, these limitations will become more significant as the Army 
approaches the statutory ceiling on the performance of depot-level 
maintenance work by contract.

Underreported Depot-Level Work Performed by Nondepot Maintenance 
Facilities Affects Accuracy of 50-50 Report:

We have reported in the past that by not having complete information on 
the amount of depot-level maintenance work being performed in nondepot 
facilities, DOD cannot provide Congress with an accurate and complete 
report regarding the allocation of depot-level maintenance between the 
public and private sectors as required by 10 U.S.C. 2466. For example, 
our September 2003 report stated that our prior 50-50 reports have 
documented continuing problems and shortcomings in accurately and 
consistently reporting depot-level maintenance accomplished by both 
public-and private-sector sources at nondepot locations.[Footnote 19] 
For example, one-time depot repair actions at unit-level facilities 
went unreported. Other nondepot work was not reported because some 
commands did not receive 50-50 instructions and others misapplied the 
guidance. Contractors performed some of this work, and military or 
civilian government employees performed some of it. While neither the 
Army nor we know the extent of unreported work nor the amount performed 
by public-and private-sector employees, the impact effectively limits 
the accuracy and completeness of DOD's report to Congress on the 
allocation of depot-level maintenance funds between the public and 
private sectors. Additionally, as discussed below, both the Army and we 
have identified three key factors inhibiting the Army's ability to 
accurately and completely report depot-level maintenance work performed 
at nondepot facilities.

Inconsistent Application of Depot-Level Maintenance Definition and 50-
50 Guidance:

A key factor inhibiting the Army's ability to accurately and completely 
identify all depot-level maintenance work performed in nondepot 
facilities in DOD's 50-50 report is that Army military activities 
inconsistently apply the congressionally mandated definition of "depot 
maintenance." The Army's proliferation report concluded that the 
congressionally mandated definition of depot-level maintenance is not 
widely known below the major command headquarters. In addition, the 
definition is open to interpretation, and the reporting guidance is not 
always well defined.

At most of the commands and installations we visited, maintenance 
officials said that, in determining whether a maintenance task is 
depot-level maintenance, they follow the guidance found in the 
Army's Maintenance Allocation Charts; technical manuals; and source, 
maintainability, and recovery codes for reparable components rather 
than apply the congressionally mandated definition. They expressed 
concerns that the congressional definition is not always consistent 
with this guidance, is too broad, and is subject to too much 
interpretation over what maintenance tasks should be counted as depot-
level tasks. For example, officials at the National Guard Bureau said 
that applying the definition to repair work performed by direct support 
and general support activities caused uncertainty in that the bureau 
considered most of the work at these levels to be nondepot-level work 
and to identify what work should be considered depot-level work 
required subjective decisions. Officials at the Reserve Command said 
that, while only maintenance work defined by the Army's technical 
manuals as depot-level work should be reported as such, under the 
expanded definition of depot-level maintenance, some work defined as 
below depot-level could involve depot-level tasks such as changing and 
swapping out engines and transmissions for wheeled vehicles. Officials 
at the installation maintenance sites we visited made similar comments.

In commenting on the proliferation report, the Army Materiel Command 
said that the application of the definition of depot-level maintenance 
contributed to the report's findings that depot-level maintenance tasks 
at nondepot facilities were being underreported. The command added that 
tasks performed by these facilities were not distinguished as depot-
level tasks in the Army guidance but, in the aggregate, these tasks may 
be equivalent to depot-level maintenance. Finally, the command said 
that the Army could only approximate the extent of work performed at 
nondepot facilities because it currently does not have a system to 
precisely capture information on maintenance work for DOD's 50-50 
report.

In prior reports, we have concluded that the Army had not revised its 
maintenance policies and technical manuals to reflect the expanded 
definition of depot-level maintenance and, as a result, any attempt to 
estimate its extent at local facilities would be misleading.[Footnote 
20] We also recently reported that some Army commands did not receive 
50-50 instructions and that others misapplied the guidance.[Footnote 
21] The Army's 2003 report indicates that the Army will have to make 
these changes in its maintenance policies and technical manuals. For 
example, in recognizing that the Army had not yet incorporated the 
expanded definition into its policies and procedures for 50-50 
reporting, the Army's report suggested that the Army (1) provide more 
explicit guidance for 50-50 reporting to help ensure that its commands 
better understood reporting requirements and (2) develop an easy-to-use 
reference guide to help the commands better determine what maintenance 
work should be included in the 50-50 report.

Army's Management Information Systems Are Inadequate:

Inadequate Army management information systems are a second key factor 
inhibiting the Army's ability to fully capture depot-level maintenance 
work performed in nondepot facilities. The Army's problems with its 
management information systems are longstanding. In a December 2000 
report, the Army Logistics Transformation Agency concluded that the 
Army's maintenance environment was characterized by many "stovepipe" 
information systems and application programs that are predominately fed 
data manually by maintainers and operators. It also concluded that a 
wide range of maintenance-related information does not exist, is not 
adequate, or is not accessible. In our prior reviews, we also have 
reported weaknesses in the Army's management information system. For 
example, in our 1999 report, we concluded that deficiencies in 
management information systems contributed to the Army's inability to 
develop accurate and consistent estimates of its depot-level 
maintenance work.[Footnote 22] In our September 2003 report on DOD's 
compliance with the 50-50 requirement, we found that the Army's latest 
reporting on depot-level workloads for fiscal years 2001 and 2002 had 
utilized a new, more centralized financial system to collect 50-50 
data.[Footnote 23] This new system helped correct some of the 
transcription errors we had found the previous year, but we continued 
to find errors, omissions, and inconsistencies in the Army's data.

The Army's proliferation report concluded that current management 
information systems for capturing depot-level maintenance work at the 
installation level are inadequate for collecting and reporting 50-50 
data. According to the report, the systems cannot, among other things, 
(1) archive the data in a readily accessible manner or (2) allow for 
the separate counting of multiple maintenance actions associated with a 
single work order. (A work order may include three different levels 
of maintenance, including depot-level maintenance, but only one 
maintenance code can be assigned to the order.) Also the report pointed 
out that collecting and reporting depot-level maintenance work outside 
the Army's five public depots was a convoluted and manual process.

Policies and Procedures for Authorizing Work Are Not Always Being 
Followed:

Another factor inhibiting the accuracy and completeness of the 50-50 
report is that policies and procedures for authorizing depot-level work 
in nondepot facilities are not always followed. The Army's 
proliferation report made the same conclusion and identified several 
areas where reporting officials did not believe that maintenance 
facilities were following policies and procedures for authorizing and 
reporting depot-level maintenance work. For example, the report noted 
that maintenance facilities at the installation level were undertaking 
depot-level maintenance work without having higher command 
authorization and that some authorized one-time repairs were not being 
reported. The report also concluded that some weapons systems managers 
were not following current DOD and Army guidance in determining sources 
for providing depot-level maintenance support.

In a prior report related to DOD's process for determining depot-level 
maintenance repair strategies for its new weapons systems and major 
upgrades, we noted that many weapons systems managers, including those 
in the Army, were not following existing guidance regarding such tasks 
as adequately performing required cost comparisons between public and 
private facilities and coordinating maintenance support decisions 
between acquisition and logistics officials.[Footnote 24] We noted that 
service officials attributed these problems, in large part, to 
weaknesses in guidance, which they believed was inadequate, unclear, 
and sometimes contradictory.

Limitations More Significant for Future Assessment of 50-50 Compliance:

As the Army moves closer to the statutory ceiling for the funding for 
depot-level maintenance work performed in the private sector, the 
limitations in the Army's ability to precisely capture its depot-level 
maintenance work will become more significant. For fiscal year 2002, 
the Army's reported data ($2.7 billion for the total program) indicated 
that its funding in the private sector for depot-level maintenance 
remained below the 50-percent limit. However, our adjustments for known 
errors in reporting for that year increased the percentage of private-
sector work to 49 percent from the 46.5 percent reported by the 
Army.[Footnote 25] An increase of more than 1 percent in the use of the 
private sector to perform more depot-level maintenance in the future, 
could cause the Army to exceed its statutory limitation. Consequently, 
the Army would be required to seek a national security waiver and 
notify Congress as provided for in 10 U.S.C. 2466(b).[Footnote 26]

With regard to estimates of future compliance, the Army's report noted 
that the Army might exceed the 50 percent ceiling for contractor 
support by fiscal year 2006. More recently, an official from the Army 
Materiel Command said that, for fiscal years 2002 and 2003, the Army 
experienced a 3 to 5 percent increase in its contract requirements for 
depot-level maintenance because increased operational requirements 
made the public depots unable to meet the total demand for depot-level 
maintenance work. She pointed out that, if this trend were to continue, 
the Army might have to seek a waiver from the Secretary of Defense, 
possibly as early as fiscal year 2004, to exceed the 50 percent 
limitation for work performed by the private sector. Another official 
at the Army Materiel Command said that the Army's depot-level 
maintenance work in 2004 might increase by about $2.5 billion because 
of operational requirements for Army equipment deployed in the Middle 
East. He also said that, in an effort to keep up with maintenance 
demands, the Army's five public depots have used extensive overtime, 
added second work shifts, hired temporary employees, and allowed some 
retirees to return to work. In his view, the public depots could not 
meet the demands of the increased maintenance work and the Army would 
have to use more contractors.

Army Needs Action Plan to Address Proliferation and Reporting Issues:

The Army report's recommendations are focused on key problem areas and 
are consistent with recommendations we have made in the past. If fully 
implemented, the recommendations in the Army's proliferation report 
could improve the identification of additional depot-level maintenance 
work in nondepot facilities, and the accuracy and completeness of 50-50 
reporting. Efforts have been undertaken to address some of the problem 
areas; however, no action plan to manage the implementation has been 
developed. Evaluating the success of the proposed 29 recommendations 
will be difficult until the Army develops an action plan with 
priorities, time frames, responsible organizations, evaluation 
criteria, and the resources required to implement these 
recommendations. If actions are not implemented in a timely way, the 
Army will not likely have the comprehensive information that it needs 
in the near term to comply with the 50-50 reporting requirements or to 
effectively manage the existing excess maintenance capabilities and 
infrastructure. On the other hand, the extent of improvements likely to 
be achieved in the long term is uncertain, given previous delays and 
the significant challenges that the Army faces in instituting solutions 
to ensure the consistent application of 50-50 reporting criteria.

Recommendations Are Focused on Key Problem Areas:

The Army report's recommendations present an array of corrective 
measures that are focused on four key areas in which the Army could 
better evaluate the proliferation of depot-level maintenance facilities 
and manage its depot-level maintenance program. Appendix III lists the 
29 recommendations. Basically, the key areas represent a need for 
the following:

* Improved communication and emphasis for the 50-50 requirement. The 14 
recommendations in this area address improving the 50-50 process. They 
include conducting annual 50-50 workshops, issuing clear guidance for 
50-50 reporting, publicizing information about the depot-level 
maintenance program in professional publications, ensuring that 
compliance with the 50-50 rule becomes a priority, and developing an 
easy-to-use reference guide to help reporting activities better 
identify depot-level maintenance work that should be reported.

* Improved management information systems. The three recommendations in 
this area address continuing efforts to develop a single integrated 
management information system capable of capturing and reporting depot-
level maintenance work at nondepot facilities.

* Enhanced compliance with policies and procedures for depot-level 
maintenance operations. The nine recommendations in this area address 
revising policies to ensure consistency in compliance with all 
applicable legislation, regulations, and policies; developing a policy 
requiring the acquisition of access to system technical data for use by 
government or other contract maintenance activities; and developing and 
implementing a plan for documenting baseline data to compare contractor 
and public depot support costs.

* Develop the National Maintenance Program and consolidate maintenance 
activities. The three recommendations in this area address efforts to 
develop the National Maintenance Program and to conduct further 
analyses to identify opportunities for consolidating depot-level 
maintenance facilities.

Of the Army proliferation report's 29 recommendations to improve the 
identification and reporting of depot-level maintenance data, 3 were 
specifically directed toward managing the proliferation of depot-level 
maintenance at nondepot facilities. One of the recommendations 
identified the need for additional study and identification.

Recommendations Consistent with Our Prior Work:

The proliferation report's recommendations are consistent with our 
prior recommendations regarding the Army's proliferation of depot-level 
maintenance facilities and the 50-50 reporting process. For example, in 
September 2003, we recommended that the 50-50 reporting guidance be 
appropriately disseminated to reporting organizations and individuals 
and that staff be properly trained in a timely way to apply the 
guidance.[Footnote 27] In October 1999, we recommended that the Army 
address the following challenges:[Footnote 28]

* Improving its management information systems. Our recommendation was 
that the Army identify requisite action items, time frames, and funding 
requirements for improving the Army's information management systems to 
fully identify the magnitude and cost-effectiveness of depot-level 
maintenance work at various locations within the Army.

* Finding opportunities to consolidate maintenance activities. We 
recommended that the Army establish (1) clear time frames and action 
plans for assessing requirements for the various types of depot-level 
maintenance facilities and (2) plans for achieving necessary 
consolidations and reductions of excess capabilities.

* Enhancing the National Maintenance Program. We recommended that the 
Army incorporate the depot-level maintenance capabilities of both 
active and reserve components under the National Maintenance Program 
and assign the national maintenance manager with requisite 
responsibility and authority for depot-level maintenance capabilities 
in active and reserve facilities.

While we made these recommendations 4 years ago, they continue to be 
essential to addressing the problems of the proliferation of depot-
level maintenance facilities and inaccuracies in 50-50 reporting.

Although Some Efforts Are Ongoing, Action Plan Not Yet Developed to 
Ensure Implementation of Recommendations in a Timely Manner:

The Army's 2003 report noted that the Army had taken numerous steps 
since 1999 to improve its management of the proliferation of depot-
level maintenance facilities and its 50-50 data. However, the report 
pointed out that the Army needed to implement the report's 
recommendations before it can claim with complete confidence that it is 
meeting the 50-50 requirement. Headquarters officials responsible for 
the report told us that the Army maintenance organizations concurred 
with the report's recommendations. The Army has already begun 
implementing some of its report's recommendations such as holding 
annual workshops and revising its guidance to include the congressional 
definition of depot-level maintenance. However, it has not yet 
developed an overall action plan for managing the implementation of all 
of the recommendations and, in particular, for setting priorities for 
the more-critical recommendations.

As the report indicates, corrective actions are essential to improving 
the Army's ability to better manage the proliferation of maintenance 
facilities and capture data for 50-50 reporting. Some of the critical 
recommendations, such as the need to identify opportunities for 
consolidating depot-level maintenance facilities, set up a single 
integrated management information system capable of capturing all 
depot-level maintenance data, and develop a National Maintenance 
Program to better manage depot-level maintenance work have been in 
process for several years. Thus, the identification of specific actions 
would appear necessary to help the Army accomplish the implementation 
of these recommendations more timely. A plan would include (1) the 
Army's priority for implementing the recommendations, (2) the Army 
organizations accountable for implementation, (3) the specific time 
frames for accomplishment, (4) whether the benefits of accomplishment 
support the cost of implementation, (5) the funding required and the 
source of funds, and (6) the criteria to determine the effectiveness of 
the recommendations once they are implemented.

Officials at the Army Communications-Electronics Command said that 
streamlining maintenance facilities is a good idea, but they do not 
have the tools that would enable the command to fully implement the 
proliferation report's recommendations in this area. They said that 
updating Army Regulation 750-1 (Army Materiel Maintenance Policy) and 
conducting 50-50 workshops were a step in the right direction, but that 
both actions need to be more comprehensive in educating field-level 
personnel on policy and requirements. For example, they pointed out 
that just reiterating the congressional definition of depot-level 
maintenance in Army Regulation 750-1 did little to add clarity to the 
definition. Additionally, the last two workshops were spent largely on 
training for the Depot Maintenance Operations Planning System, a new 
system to be used by all Army major commands and acquisition managers 
to capture and report annual 50-50 workload data. According to these 
personnel, this system appears extremely complex and training should be 
aimed at those who are actually responsible for reporting maintenance 
data. Officials at the National Guard Bureau generally disagreed that 
the Army report's recommendations will ensure accurate 50-50 reporting-
-especially in view of the apparent disconnect between the 
recommendations and the Army's maintenance transformation process, and 
the Army's plans for moving to two-level maintenance.[Footnote 29]

Army Communications-Electronics Command officials also suggested 
that, for timely and effective implementation, the Army establish a 
working group of representatives with subject matter expertise from all 
levels within the Army to oversee the implementation. Officials at Army 
headquarters who were responsible for the report told us that they did 
not yet have a formal action plan established. They said they were 
planning to establish a working group in December 2003 to review the 
recommendations and determine what actions needed to be taken.

Long-term Improvements in 50-50 Reporting May Remain Problematic:

As previously discussed the Army has taken steps to improve its 
management of the proliferation of depot-level maintenance facilities 
and its 50-50 reporting. The Army's 2003 report and our analysis 
indicate that some of the key actions related to improving the Army's 
long-standing issues in effectively identifying the proliferation of 
depot-level maintenance facilities and improving its 50-50 reporting 
have been in process for several years. The magnitude of long-term 
improvements likely to be realized remains uncertain, given prior 
delays in instituting solutions and the inconsistent understanding and 
application of 50-50 reporting criteria.

During our review, we observed that several actions related to the 
recommendations had been under way for a number of years but that 
completion dates had slipped and funding had become uncertain. For 
example, the recommendation that the Army continue efforts to establish 
a fully integrated national maintenance requirements determination 
process that includes all depot-level maintenance requirements refers 
to a program known as the National Maintenance Program. The Army 
initiated the program in July 1999 and planned to implement it by 
fiscal year 2004. However, full implementation has slipped to fiscal 
year 2006. Additionally, required funding to complete the program is 
uncertain. Army Materiel Command officials said that the program's goal 
is to centrally coordinate and control depot-level maintenance work by 
developing standards for items being repaired at qualified repair 
sources. They said that (1) the program is helping to better identify 
and manage facilities that perform depot-level maintenance outside the 
public depots; (2) the number of maintenance facilities in the program 
has declined from 60 in fiscal year 2000 to 45 in fiscal year 2003, and 
these are expected to further decline to 25 in fiscal year 2005 as the 
Army decides which facilities will be qualified to perform depot-level 
maintenance work; and (3) the command was working with other commands 
to reduce the number of nondepot maintenance facilities.

Full implementation of the National Maintenance Program appears to be 
a key initiative in addressing the proliferation of depot-level 
maintenance facilities. At the same time, our analysis indicates that, 
although the concept of the National Maintenance Program could help 
improve future annual reporting and eliminate some of the current 
fragmented and duplicative depot-level maintenance workload 
assignments, it is too early to assess the program's full impact. The 
extent to which the program can resolve all the problems related to the 
proliferation and inaccurate and incomplete identification of depot-
level maintenance work performed in nondepot facilities is unclear. The 
Army's 2003 report noted that the Army's schedule for completing the 
implementation of the National Maintenance Program has slipped to 
fiscal year 2006. During our review, we noted that, as of October 2003, 
the Army had completed standards for only 737: about 18 percent: of the 
4,148 candidates for the program. While an estimated development cost 
of about $120 million has already been spent, the Army is a long way 
from having the required standards that are needed for the program. An 
Army Materiel Command official said that the Army was not planning to 
provide any additional funding for the further development of these 
standards.

In a prior report, we observed that, while the program is intended to 
consolidate and distribute overhaul work for components returned to the 
supply system, the evolving management framework will continue to allow 
local maintenance facilities to repair items returned directly to using 
organizations--maintenance-to-maintenance transactions that could meet 
the statutory definition of depot-level maintenance.[Footnote 30] 
Additionally, the program did not include some other depot-level 
maintenance work. For example, it does not address the allocation of 
depot-level maintenance requirements for overhauling, rebuilding, or 
upgrading major end items such as tactical wheeled vehicles that are 
currently being overhauled in field-level maintenance facilities or by 
contracts managed by field-level organizations even though this work 
meets the statutory definition of depot-level maintenance work.

With regard to resolving deficiencies in management information 
systems, it is uncertain when the required changes that will be capable 
of capturing and reporting depot-level maintenance workloads performed 
in nondepot facilities will be operational. In October 2003, the Army 
began testing the transition of its database for Specialized Repair 
Authority and One-Time Repair authorizations into an automated system 
referred to as the Joint Computer-Aided Acquisition and Logistic 
Support system.[Footnote 31] The Army's 2003 report described this as 
an interim initiative to capture and report on maintenance work 
performed under these two types of authorizations. While this 
initiative will automate the capturing of this work, it will not 
identify all depot-level maintenance work that may be performed in 
field-level facilities. For example, it will not capture depot-level 
maintenance actions performed on equipment that will be returned 
directly to the user without going through the Army's supply system. A 
single integrated management information system is hoped for when the 
Army's evolving Logistics Modernization Program is fully implemented. 
Testing at the first site, the Tobyhanna Army Depot, is ongoing, but 
problems have occurred. Earlier estimates of completion are about 18 to 
24 months, but some delays are expected.[Footnote 32] Additionally, to 
what extent it will resolve all the deficiencies in the current systems 
is uncertain.

Conclusions:

We believe that the Army's implementation of our prior recommendations, 
as well as the recommendations made in the Army's proliferation report, 
are essential to providing the Army with more precise information for 
crucial decisions in the area of the Army's depot-level maintenance 
infrastructure. Their timely and effective implementation depends 
largely on the necessary emphasis from senior Army leadership. If 
actions are not implemented in a timely manner, the Army will unlikely 
have the comprehensive information that it needs to determine the 
extent of proliferation and effectively manage its excess capabilities 
and the infrastructure it has--key data needed for complying with the 
existing reporting statute, identifying excess infrastructure and 
making appropriate consolidations, and making appropriate decisions for 
an additional round of base realignments and closures that has been 
authorized for 2005.

The Army has not yet developed a plan for implementing the 
recommendations in the Army proliferation report. We believe it is 
essential that the Army have such a plan to help ensure the timely and 
effective implementation of the recommendations. Such a plan would 
include evaluating the priority for implementation and identifying the 
time frame for implementing the recommendations, the responsible 
organizations, and the criteria for measuring the desired results.

While improvements should be accomplished, the complexity and 
vastness of the Army's maintenance system and continuing questions 
about such issues as the definition of depot-level maintenance and 
changing maintenance strategies could continue to present challenges 
in fully recording all depot-level maintenance work.

Recommendation:

To ensure the timely and effective implementation of the 
recommendations in the Army's 2003 proliferation report to help the 
Army improve its management of maintenance operations, including the 
proliferation of depot-level maintenance facilities, and more precisely 
capture and report depot-level maintenance data, we recommend that the 
Secretary of the Defense direct the Secretary of the Army to establish 
a specific plan to manage the implementation of the 29 recommendations 
identified in the 2003 proliferation report. The plan should include 
the priority and time frames for implementation, the responsible 
organizations for implementing the plan, and the criteria for measuring 
success.

Agency Comments and Our Evaluation:

The Department of Defense provided written comments (see app. IV) on a 
draft of this report. In commenting on the draft, the Office of the 
Deputy Undersecretary of Defense for Logistics and Materiel Readiness 
concurred with our recommendation that the Army establish a plan to 
manage the implementation of the 29 recommendations identified in the 
2003 depot maintenance proliferation report. The Department noted that 
the Army is in the process of establishing an integrated product team 
to develop an action plan to address the 29 recommendations to include 
reevaluating the validity and modifying the recommendations where 
appropriate. The Department also stated that the Army expects to have 
an action plan in place no later than March 31, 2004. The Department's 
response noted specifically that the recommendation contained in the 
Army's report related to the designation of core work needs to be 
revised. We recognize that some adjustment to the recommendations may 
be necessary as the implementation plan is developed. Whether some 
recommendations require modification for implementation is not as 
significant for the Army as is the need for timely action and follow 
through to address the issues identified in the Army's depot 
maintenance proliferation report.

We are sending copies of this report to interested congressional 
committees; the Secretary of Defense; the Secretary of the Army; and 
the Director, Office of Management and Budget. We will make copies 
available to others upon request. In addition, the report will be 
available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff have questions regarding this report, please 
contact me at (202) 512-8412 or holmanb@gao.gov or Julia Denman, 
Assistant Director, at (202) 512-4290 or denmanj@gao.gov. Other major 
contributors to this report were Nancy Benco, Wayne Gilliam, and Bobby 
Worrell.

Barry W. Holman: 
Director, Defense Capabilities and Management:

Signed by Barry W. Holman: 

[End of section]

Appendix I: Scope and Methodology:

To answer the Senate and House Committees on Armed Services mandate 
contained in Report of the Committee on Armed Services, House of 
Representatives, Floyd D. Spence National Defense Authorization Act for 
Fiscal Year 2001, we reviewed the Army's Fiscal Year 2002 Study of the 
Proliferation of Depot Maintenance-Type Activities Phase II Report, 
dated July 31, 2003. We interviewed Army officials and analyzed 
pertinent information regarding that report at (1) Army Headquarters in 
the Washington, D.C., area; (2) Headquarters, Army Materiel Command in 
Alexandra, Virginia; (3) three subordinate commands--the Army Aviation 
and Missile Command, Huntsville, Alabama; Communications-Electronics 
Command, Fort Monmouth, New Jersey; and the Tank-automotive and 
Armaments Command, Warren, Michigan; (4) Headquarters, National Guard 
Bureau, Arlington, Virginia; (5) Headquarters, Army Forces Command, 
Atlanta, Georgia; and (6) Headquarters, Army Reserve Command, Atlanta, 
Georgia. Also, we interviewed managers and reviewed pertinent 
information regarding maintenance facilities located at Fort Campbell, 
Kentucky; Fort McCoy, Wisconsin; Fort Riley, Kansas; and Fort Rucker, 
Alabama. We made extensive use of our prior work related to Army depot-
level maintenance.

To determine the extent to which the Army's report identified the total 
amount of depot-level maintenance work performed at nondepot 
facilities, we examined the requirements of section 2466 of title 10, 
U.S. Code, and Army regulatory provisions for 50-50 reporting. We 
analyzed the report's scope and methodology, findings, and disclosure 
of the amount it identified and compared these data with our prior work 
done on the Army's annual 50-50 reporting process. We interviewed the 
study group manager, Army officials, and maintenance managers about the 
nature of maintenance work performed by nondepot facilities and about 
whether it was being reported as required. Because the Army has no 
central database or readily available data, we did not attempt to 
determine the Army's universe of facilities that perform depot-level 
maintenance.

To answer whether the Army can accurately account for its depot-level 
maintenance workloads and the key issues that preclude accurate 
reporting, we examined the report's findings to determine what areas 
were identified as contributing problems. We used our prior work on the 
Army's depot-level maintenance program to correlate, compare, and test 
the consistency of the identified problems with the ones we had 
previously reported. We interviewed the study group manager, Army 
officials, and maintenance personnel about the relevancy of the 
findings and the application to the Army's depot-level maintenance 
operations.

To answer whether the corrective actions identified in the Army's 
report are likely to address the proliferation issue and enhance the 
Army's reporting, we examined the recommendations to determine how 
effectively they were linked to the identified problems. We also 
compared the recommendations with those that we had previously made to 
test for consistency. Finally, we discussed the relevancy of the 
recommendations with the study group manager, Army officials, and 
maintenance representatives.

We conducted our analysis of the Army's report from July through 
October 2003 in accordance with generally accepted government 
auditing standards.

[End of section]

Appendix II: Army Maintenance Sites:

The Army operates a number of maintenance facilities and has an 
extensive infrastructure for the maintenance of its military weapons 
systems and support equipment. For example, as we reported in April 
2003, the Army employs about 10,000 personnel at its five public depots 
to overhaul, repair, and upgrade its ground and air combat systems, 
subsystems, and assemblies.[Footnote 33] The Army also has a vast 
number of other maintenance facilities operated by U.S. government-
employed civilians and contractors. For example, we reported in October 
1999 that the Army had another 102 maintenance facilities that were 
potential providers of depot-level maintenance services within the 
continental United States--28 active Army, 2 Army Reserve, and 72 Army 
National Guard.[Footnote 34]

In addition, the Army operates maintenance activities that provide 
maintenance below the depot level. For example, as of August 2003, 
the Forces Command reported that it had maintenance facilities at 
10 installations that provide direct support for vehicle maintenance; 
the Army reserve had about 160 maintenance facilities located 
throughout the United States that perform unit, direct, and general 
maintenance support; the National Guard had additional maintenance 
facilities performing unit and direct support maintenance; and Army 
installations had a number of maintenance facilities that perform 
various levels of maintenance.

We visited 17 of the Army, Army Reserve, and Army National Guard 
maintenance sites. These 17 sites performed maintenance work valued 
at more than $500 million during fiscal year 2002; employed more than 
4,700 military, civilian, and contractor personnel; and occupied 
facilities with more than 2 million square feet. Table 2 provides 
summary capacity and capability information about the sites.

Table 2: Capacity and Capability Information on 17 Sites That 
GAO Visited:

Dollars in millions.

Installation: Fort Campbell, Kentucky; 

Organization: Readiness Business Center; 
Government and contractor staff: 308; 
Facility size in square feet: 195,249; 
Fiscal year 2002 maintenance: $27.1; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: $4.5[A].

Organization: Forces Command CMF; 
Government and contractor staff: 188; 
Facility size in square feet: 8,000; 
Fiscal year 2002 maintenance: 10.0; 
Capability to perform depot maintenance: No; 
Fiscal year 2002 depot maintenance: None.

Organization: National Guard UTES; 
Government and contractor staff: 19; 
Facility size in square feet: 14,675; 
Fiscal year 2002 maintenance: .9; 
Capability to perform depot maintenance: No; 
Fiscal year 2002 depot maintenance: None.

Installation: Fort McCoy, Wisconsin; 

Organization: Reserve IMMA; 
Government and contractor staff: 202; 
Facility size in square feet: 140,000; 
Fiscal year 2002 maintenance: 4.9; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: .7[B].

Organization: Reserve ECS; 
Government and contractor staff: 113; 
Facility size in square feet: 198,656; 
Fiscal year 2002 maintenance: 1.8; 
Capability to perform depot maintenance: No; 
Fiscal year 2002 depot maintenance: None.

Organization: National Guard MATES; 
Government and contractor staff: 31; 
Facility size in square feet: 92,000; 
Fiscal year 2002 maintenance: .5; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: .05[B].

Installation: Fort Riley, Kansas; 

Organization: DOL; 
Government and contractor staff: 112; 
Facility size in square feet: 255,000; 
Fiscal year 2002 maintenance: 12.4; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: 2.4[C].

Organization: Forces Command CMF; 
Government and contractor staff: 71; 
Facility size in square feet: 53,716; 
Fiscal year 2002 maintenance: 2.1; 
Capability to perform depot maintenance: No; 
Fiscal year 2002 depot maintenance: None.

Organization: National Guard RSMS; 
Government and contractor staff: 142; 
Facility size in square feet: 88,612; 
Fiscal year 2002 maintenance: 14.1; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: 14.1.

Organization: National Guard ATEAM; 
Government and contractor staff: 90; 
Facility size in square feet: 75,070; 
Fiscal year 2002 maintenance: 20.9; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: 20.9[D].

Organization: National Guard MATES; 
Government and contractor staff: 89; 
Facility size in square feet: 123,000; 
Fiscal year 2002 maintenance: 6.7; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: .6[B].

Organization: Reserve ECS; 
Government and contractor staff: 78; 
Facility size in square feet: 14,040; 
Fiscal year 2002 maintenance: 2.3; 
Capability to perform depot maintenance: No; 
Fiscal year 2002 depot maintenance: None.

Installation: Fort Rucker, Alabama; 

Organization: ACLC; 
Government and contractor staff: 3,217; 
Facility size in square feet: 732,224; 
Fiscal year 2002 maintenance: 418.5; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: 16.8[E].

Organization: DEL; 
Government and contractor staff: 22; 
Facility size in square feet: 3,000; 
Fiscal year 2002 maintenance: 2.5; 
Capability to perform depot maintenance: No; 
Fiscal year 2002 depot maintenance: None.

Organization: ATSCOM; 
Government and contractor staff: 52; 
Facility size in square feet: 41,000; 
Fiscal year 2002 maintenance: 2.4; 
Capability to perform depot maintenance: Yes; 
Fiscal year 2002 depot maintenance: .4.

Organization: National Guard UTES; 
Government and contractor staff: 14; 
Facility size in square feet: 16,664; 
Fiscal year 2002 maintenance: 1.5; 
Capability to perform depot maintenance: No; 
Fiscal year 2002 depot maintenance: None.

Organization: Reserve ECS; 
Government and contractor staff: 15; 
Facility size in square feet: 4,000; 
Fiscal year 2002 maintenance: .5; 
Capability to perform depot maintenance: No; 
Fiscal year 2002 depot maintenance: None. 

Sources: Fort Campbell, Kentucky: Readiness Business Center, Forces 
Command CMF, National Guard UTES; Fort McCoy, Wisconsin: Reserve IMMA, 
Reserve ECS, National Guard MATES; Fort Riley, Kansas: Forces Command 
CMF, National Guard RSMS, National Guard ATEAM, National Guard MATES, 
Reserve ECS; and Fort Rucker, Alabama: ACLC, DEL, ATSC, National Guard 
UTES, Reserve ECS.

[A] Data represent National Maintenance Program and Specialized Repair 
Authority.

[B] Data represent National Maintenance Program.

[C] Data include National Maintenance Program and One-Time Repairs.

[D] Data include Specialized Repair Authority.

[E] Data include National Maintenance Program, Specialized Repair 
Authority, and One-Time Repairs.

Legend:

ACLC: (Aviation Center Logistics Command): This organization, which 
reports to the Aviation and Missile Command, performs all levels of 
aviation maintenance in support of Fort Rucker's flight-training 
program. A contractor performs this maintenance work.

ATSCOM: (Air Traffic Services Command), a newly formed organization, 
provides worldwide direct, general, and limited depot-level maintenance 
for air traffic control systems. The maintenance data reported 
represents two components--F Company of the 58th Aviation Regiment and 
the Air Traffic Control Activity.

CSMS: (Combined Support Maintenance Shop): Army National Guard 
facilities that provide direct support and general support levels of 
maintenance for National Guard surface equipment (trucks, tanks, 
etc.).

DEL: (Directorate of Engineering and Logistics): A Fort Rucker 
organization that performs organizational support, direct support, and 
general support for vehicles, construction equipment, and fire-fighting 
equipment. A contractor performs this maintenance work.

DOL: (Directorate of Logistics): Fort Riley organization that performs 
general support maintenance for tanks, trucks, construction equipment, 
small arms, etc. It also provides limited organizational and aviation 
intermediate maintenance. A contractor performs this maintenance work.

Forces Command CMF: (Forces Command Contractor Maintenance 
Facility): These maintenance facilities report to Forces Command and 
perform organizational and direct support maintenance on items such as 
trucks, trailers, tracked vehicles, vans, and generators. Contractors 
perform the maintenance work.

National Guard ATEAM: (Advanced Turbine Engine Army Maintenance): This 
Army National Guard facility rebuilds M1A1 tank engines. Its work, 
which is considered depot-level maintenance, is limited to National 
Guard assets.

National Guard MATES (Maneuver Area Training Equipment Site): Army 
National Guard maintenance facilities that provide unit, direct 
support, and general support maintenance for assigned equipment. These 
sites are established to preposition selected items of equipment and 
are located at or near a training area.

National Guard RSMS (Readiness Sustainment Maintenance Site): This 
National Guard facility at Fort Riley rebuilds 5-ton cargo trucks and 
trailers. Its work, which is considered depot-level maintenance, is 
generally limited to National Guard assets. Employees of the state of 
Kansas perform the work.

National Guard UTES (Unit Training and Equipment Site): A National 
Guard facility that stores and performs organizational maintenance on 
tracked and wheeled vehicles for National Guard units within a 
specific geographic area.

Readiness Business Center: A Fort Campbell organization that performs 
general support maintenance for wheeled vehicles and intermediate and 
limited depot-level maintenance for helicopters. Contractors perform 
the maintenance work.

Reserve ECS (Equipment Concentration Site): Army Reserve facilities 
that store and maintain selected equipment for Army Reserve units in a 
specific geographic area. The maintenance work is performed by both 
government and contractor employees.

Reserve IMMA (Army Reserve Installation Materiel Maintenance 
Activity): The facility provides organizational, direct, and general 
support maintenance for tactical vehicles--High Mobility Multi-purpose 
Wheeled Vehicles, trucks, trailers--for Army Reserve units located at 
or near Fort McCoy. For the most part, contractor employees perform the 
maintenance work.

[End of table]

[End of section]

Appendix III: Army Report's Issues and Recommendations:

The Army's Fiscal Year 2002 Study of the Proliferation of Depot 
Maintenance-Type Activities identified 7 issues and made 
29 recommendations for the following improvements to enhance the Army's 
ability to (1) evaluate the proliferation of nondepot facilities 
that perform depot-level maintenance and (2) identify and report on 
its 50-50 data. These recommendations were consistent with our 
prior recommendations--noted in referenced GAO products.

Issue 1: Title 10 Definition of Depot Maintenance and 50-50 Reporting 
Policy Guidance Recommendations:

* Post the new Army Regulation 750-1 as soon as possible to the Army 
Publications Agency Web site. Posting the regulation will contribute to 
the education of Army activities on the congressional definition of 
"depot maintenance" and the 50-50 reporting process.

* Continue to conduct annual 50-50 workshops and issue clear guidance 
regarding depot maintenance policies to major commands, program 
executive officers, and program managers.

* Use Headquarters, Department of the Army, senior-level maintenance 
boards to communicate depot maintenance policies.

* Publish depot maintenance information articles in professional 
publications.

[See also GAO-03-1023; U.S. General Accounting Office, Depot 
Maintenance: Key Unresolved Issues Affect the Army Depot System's 
Viability, GAO-03-682 (Washington, D.C.: July 7, 2003); and U.S. 
General Accounting Office, Depot Maintenance: Change in Reporting 
Practices and Requirements Could Enhance Congressional Oversight, GAO-
03-16 (Washington, D.C.: Oct. 18, 2002).]

Issue 2: Accuracy of Army's Current 50-50 Reports Recommendations:

* The Army Deputy Chief of Staff (G-4) should ensure that compliance 
with the 50-50 rule becomes an Army priority and that command emphasis 
is applied to correct all reporting problems.

* Army G-4 should submit an amended 50-50 report for fiscal year 2002.

* Army G-4 should include all Army major commands, program executive 
offices, and separate commands in the 50-50 reporting process.

[See also GAO-03-1023; U.S. General Accounting Office, Depot 
Maintenance: Workload Allocation Reporting Improved, but Lingering 
Problems Remain, GAO/NSIAD-99-154 (Washington, D.C.: July 13, 1999); 
and U.S. General Accounting Office, Depot Maintenance: Management 
Attention Required to Further Improve Workload Allocation Data, GAO-02-
95 (Washington D.C.: Nov. 9, 2001).]

Issue 3: Specialized Repair Authority and One-Time Repair Workload 
Reporting Requirements Recommendations:

* Army G-4 should provide applicable major commands with immediate and 
specific guidance to reinforce compliance with current Specialized 
Repair Authority and One-Time Repair policies. Strong emphasis should 
be placed on collecting One-Time Repair data for 50-50 reporting 
purposes.

* Current policy and procedures regarding the approval and tracking of 
One-Time Repair should be expanded in Army Regulation 750-1.

* Major commands should appoint an installation or local Specialized 
Repair Authority coordinator to ensure that (1) all major command 
facilities at an installation are provided the most current information 
on Specialized Repair Authority and One-Time Repair policies and 
(2) the appropriate Specialized Repair Authority and One-Time Repair 
production data are submitted properly through the installation or 
local regional major command Specialized Repair Authority coordinator 
to the major command headquarters. Similarly, the National Guard Bureau 
should appoint Specialized Repair Authority coordinators for each 
state, territory, and the District of Columbia.

* Army G-4, in coordination with the Army Materiel Command (AMC), 
should direct the Aviation and Missile Command to terminate the 
existing Aviation Repair Authority process and immediately comply with 
all Headquarters, Department of Army, Specialized Repair Authority 
policies.

[See also U.S. General Accounting Office, Depot Maintenance: Change in 
Reporting Practices and Requirements Could Enhance Congressional 
Oversight, GAO-03-16 (Washington D.C.: Oct. 18, 2002).]

Issue 4: Army G-4 Guidance Regarding Depot Maintenance Reporting 
Procedures Recommendations:

* Army G-4 should revise the 50-50 standard operating procedures to 
provide the major commands, program executive officers, and program 
managers with more explicit guidance regarding those 50-50 reporting 
requirements that are still causing confusion,

* Army G-4 should coordinate with major commands, program executive 
officers, and program managers to ensure that the standard operating 
procedure revisions are clearly understood and that the 50-50 standard 
operating procedures address the upgrade and modification programs.

* Army G-4 should develop a "decision tree" (an easy-to-use reference 
guide) to better distinguish between those programs that should be and 
should not be reported.

[See also GAO-02-95 and GAO/NSIAD-99-154.]

Issue 5: Impact of National Maintenance Program on 50-50 Reporting 
Processes Below Public Depot Level Recommendations:

* AMC should continue efforts to establish a fully integrated national 
maintenance requirements determination process that includes all depot 
maintenance requirements.

* The Army should complete the implementation of the National 
Maintenance Program by fiscal year 2006 as currently planned.

* The Army should conduct further analyses to identify opportunities 
for consolidating depot-level maintenance activities.

[See also GAO/NSIAD-00-20.]

Issue 6: Management Information System Requirements for Improving 
Current Methods of Capturing and Reporting 50-50 Data Recommendations:

* The Army should develop an integrated management information system 
capable of capturing and reporting depot maintenance workloads below 
the organic depot level. AMC should consider replacing the interim 
Specialized Repair Authority business system: the combined Joint 
Computer-Aided Logistics Support System/Logistics Integrated Database/
Army Electronic Product Support Systems: with a single integrated 
Specialized Repair Authority tracking and workload system through the 
development of the Logistics Modernization Program and as the various 
major command feeder systems are either replaced or consolidated by way 
of the development of the Global Combat Support System-Army.

* Army G-4 should query AMC's Logistics Integrated Database monthly to 
ensure that major command activities are using the new Department of 
the Army Pamphlet 738-750 maintenance codes for inputting workload data 
into automated systems to account for Specialized Repair Authority and 
One-Time Repair tasks embedded in maintenance workloads at the 
installation level.

* Army G-4 should continue to support AMC's efforts to develop a 
Maintenance Contract Database under the National Maintenance Program.

[See also GAO-02-95 and GAO/NSIAD-00-20.]

Issue 7: DOD and Army Policies Affecting Army's Ability to Manage the 
Proliferation of Depot Maintenance Activities Recommendations:

* New weapons systems should be designated as core or non-core up front 
in the system's life cycle at Milestone C (Production and Deployment). 
The system's Logistics Support Plan should be revised accordingly on 
the basis of core depot assessment and presented at Milestone C for 
approval.

* The Army should adopt a new core depot assessment process for weapons 
systems that have not yet undergone core determination analyses.

* The Army should continue to revise/replace flawed Department of the 
Army policies that apply to the Depot Source of Repair (DSOR) decision 
process. The primary objectives of this effort should be the consistent 
compliance of all applicable legislation, regulations, and policies, 
and to ensure that the organic depots are not excluded from the DSOR 
decision process.

* The Army should audit/review program executive officer, program 
manager, and AMC activities to ensure that they are following guidance 
on core logistics requirements, weapons system support strategies, and 
the DSOR decision process in accordance with the Assistant Secretary of 
the Army for Acquisition, Logistics, and Technology [ASA (ALT)] 
memorandum dated January 9, 2003, entitled Depot Considerations in 
Acquisition.

* The ASA (ALT) should develop an Army acquisition policy that requires 
program executive officers and program managers to acquire access to 
system technical data owned by the original equipment manufacturer for 
use by appropriate organic or contractor maintenance facilities during 
the performance of system logistical support.

* The ASA (ALT), Army G-4, and AMC should establish a partnership with 
an approved memorandum of agreement to integrate acquisition weapons 
system requirements with traditional end item and secondary item 
overhaul requirements to (1) assist AMC in maximizing the capabilities 
of the five organic depots to meet core requirements and (2) seek a 
renewed commitment from all parties that the depots will not be 
excluded from the DSOR process without the required analyses being 
conducted.

* Army G-4, ASA (ALT), and AMC should work closely together to develop 
and implement a plan for documenting baseline data to compare 
contractor costs with organic support costs.

* Army G-4, ASA (ALT), AMC, and AMC's major subordinate commands should 
work closely with Headquarters, Department of the Army ASA (ALT) staff 
to market the depots with the program executive officers and program 
managers at every opportunity.

* Army G-4, ASA (ALT), and AMC should work closely together to explore 
future opportunities to expand the number of public/private 
partnerships as part of the Army's overall industrial base strategy.

[See also U.S. General Accounting Office, Defense Logistics: Actions 
Needed to Overcome Capability Gaps in the Public Depot System, GAO-02-
105 (Washington, D.C.: Oct. 12, 2001) and U.S. General Accounting 
Office, Defense Depot Maintenance: DOD Shifting More Workload for New 
Weapon Systems to the Private Sector, GAO/NSIAD-98-8 (Washington, D.C.: 
Mar. 31, 1998).]

[End of section]

Appendix IV: Comments from the Department of Defense:

DEPUTY UNDER SECRETARY OF DEFENSE FOR LOGISTICS AND MATERIEL READINESS 
3500 DEFENSE PENTAGON 
WASHINGTON, DC 20301-3500:

DEC 12 2003:

Mr. Barry W. Holman:

Director, Defense Capabilities and Management 
U.S. General Accounting Office, Room 4440B 441 G Street, N W:

Washington, D.C. 20548:

Dear Mr. Holman:

This is the Department of Defense (DoD) response to the General 
Accounting Office (GAO) draft report, "DEPOT MAINTENANCE: "Army Needs 
Plan to Implement Depot Maintenance Report's Recommendations," (GAO 
Code 350413/GAO 04-220). The Department concurs with the report's 
recommendation with qualifications. GAO recommended the Secretary of 
Defense direct the Secretary of the Army to establish a specific plan 
to manage the implementation of the 29 recommendations in the Army's 
2003 proliferation report. While the Department agrees with this 
recommendation in concept, some of the 29 recommendations in the Army 
Report will require modification, as discussed in our detailed response 
to the draft report's recommendation.

The Army is in the process of establishing an Integrated Product Team 
(IPT) to revalidate the 29 recommendations in its proliferation report 
and to develop an action plan to address them. The Army expects to have 
a final action plan in place not later than March 31, 2004.

The Department's detailed response to the GAO recommendation is in the 
enclosure. The DoD appreciates the opportunity to comment on the draft 
report.

Sincerely,

Signed for:

Diane K. Morales: 

GAO CODE 350413/GAO-04-220:

"DEPOT MAINTENANCE: ARMY NEEDS PLAN TO IMPLEMENT DEPOT MAINTENANCE 
REPORT'S RECOMMENDATIONS":

DEPARTMENT OF DEFENSE COMMENTS TO THE RECOMMENDATION:

RECOMMENDATION: The GAO recommended that the Secretary of Defense 
direct the Secretary of the Army to establish a specific plan to manage 
the implementation of the 29 recommendations identified in the 2003 
proliferation report. The plan should include the priority and time 
frames for implementation, the responsible organizations, and the 
criteria for measuring success. (Page 21/Draft Report):

DoD RESPONSE: Concur with qualifications. The Department agrees in 
concept that the Secretary of the Army should establish a specific plan 
to manage the implementation of the 29 recommendations in the 2003 
proliferation report. However, some of the recommendations in the 
report will require modification. For example, under issue seven in the 
proliferation report, the first recommendation states "New weapon 
systems should be designated as core or non-core up front in the 
system's life cycle at Milestone C (Production and Deployment).":

The recommendation is in error since weapon systems are not core. Core 
consists of skills, equipment and facilities that must be sustained. 
The required decision to be made by Milestone C is whether workload 
from a system will be used to sustain core capability requirements.

The Army is in the process of establishing an Integrated Product Team 
(IPT) to develop an action plan to address the 29 recommendations. As 
part of its review, the IPT will reevaluate the validity of the 29 
proliferation report recommendations and modify them where appropriate.

It is anticipated that this IPT will conduct its initial meeting before 
the end of the calendar year with an initial draft action plan 
available for staffing not later than January 31, 2004. The Army 
expects to have a final action plan in place no later than March 3I, 
2004.

[End of section]

Related GAO Products:

Depot Maintenance: DOD's 50-50 Reporting Should Be Streamlined. GAO-03-
1023. Washington, D.C.: September 15, 2003.

Depot Maintenance: Key Unresolved Issues Affect the Army Depot System's 
Viability. GAO-03-682. Washington, D.C.: July 7, 2003.

Department of Defense: Status of Financial Management Weaknesses and 
Progress Toward Reform. GAO-03-931T. Washington, D.C.: June 25, 2003.

Depot Maintenance: Change in Reporting Practices and Requirements Could 
Enhance Congressional Oversight. GAO-03-16. Washington D.C.: October 
18, 2002.

Depot Maintenance: Management Attention Needed to Further 
Improve Workload Allocation Data. GAO-02-95. Washington D.C.: November 
9, 2001.

Defense Logistics: Actions Needed to Overcome Capability Gaps in the 
Public Depot System. GAO-02-105. Washington, D.C.: October 12, 2001.

Defense Maintenance: Sustaining Readiness Support Capabilities 
Requires a Comprehensive Plan. GAO-01-533T. Washington, D.C; March 23, 
2001.

Depot Maintenance: Key Financial Issues for Consolidations at Pearl 
Harbor and Elsewhere Are Still Unresolved. GAO-01-19. Washington, D.C.: 
January 22, 2001.

Depot Maintenance: Action Needed to Avoid Exceeding Ceiling on Contract 
Workloads. GAO/NSIAD-00-193. Washington, D.C.: August 24, 2000.

Depot Maintenance: Air Force Waiver to 10 U.S.C. 2466. GAO/NSIAD-00-
152R. Washington, D.C.: May 22, 2000.

Depot Maintenance: Air Force Faces Challenges in Managing to 50-50 
Ceiling. GAO/T-NSIAD-00-112. Washington, D.C.: March 3, 2000.

Depot Maintenance: Future Year Estimates of Public and Private 
Workloads Are Likely to Change. GAO/NSIAD-00-69. Washington, D.C.: 
March 1, 2000.

Depot Maintenance: Army Report Provides Incomplete Assessment of Depot-
Type Capabilities. GAO/NSIAD-00-20. Washington, D.C.: October 15, 
1999.

Depot Maintenance: Status of the Navy's Pearl Harbor Project. GAO/
NSIAD-99-199. Washington, D.C.: September 10, 1999.

Depot Maintenance: Workload Allocation Reporting Improved, but 
Lingering Problems Remain. GAO/NSIAD-99-154. Washington, D.C.: 
July 13, 1999.

Navy Ship Maintenance: Allocation of Ship Maintenance Work in 
the Norfolk, Virginia, Area. GAO/NSIAD-99-54. Washington, D.C.: 
February 24, 1999.

Defense Depot Maintenance: Public and Private Sector Workload 
Distribution Reporting Can Be Further Improved. GAO/NSIAD-98-175. 
Washington, D.C.: July 23, 1998.

Defense Depot Maintenance: DOD Shifting More Workload for New Weapon 
Systems to the Private Sector. GAO/NSIAD-98-8. Washington, D.C.: March 
31, 1998.

Defense Depot Maintenance: Information on Public and Private 
Sector Workload Allocations. GAO/NSIAD-98-41. Washington, D.C.: 
January 20, 1998.

Defense Depot Maintenance: Uncertainties and Challenges DOD Faces 
in Restructuring Its Depot Maintenance Program. GAO/T-NSIAD-97-112. 
Washington, D.C.: May 1, 1997. Also, GAO/T-NSIAD-97-111. Washington, 
D.C.: March 18, 1997.

Defense Depot Maintenance: DOD's Policy Report Leaves Future Role 
of Depot System Uncertain. GAO/NSIAD-96-165. Washington, D.C.: May 21, 
1996.

Defense Depot Maintenance: More Comprehensive and Consistent Workload 
Data Needed for Decisionmakers. GAO/NSIAD-96-166. Washington, D.C.: May 
21, 1996.

Defense Depot Maintenance: Privatization and the Debate Over 
the Public-Private Mix. GAO/T-NSIAD-96-148. Washington, D.C.: 
April 17, 1996. Also, GAO/T-NSIAD-96-146. Washington, D.C.: 
April 16, 1996.

Depot Maintenance: Issues in Allocating Workload Between the Public and 
Private Sectors. GAO/T-NSIAD-94-161. Washington, D.C.: April 12, 1994.

FOOTNOTES

[1] According to 10 U.S.C. 2460, depot maintenance workloads include 
(1) materiel maintenance and repair requiring the overhaul, upgrading, 
or rebuilding of parts, assemblies, or subassemblies and (2) testing 
and reclamation of equipment as necessary, regardless of the source of 
funds or the location where the work is performed. 10 U.S.C. 2466 
requires annual reports of public-and private-sector expenditures for 
depot maintenance services and stipulates that no more than 50 percent 
of annual depot maintenance funding provided for military departments 
and defense agencies can be used for work accomplished by contractors. 
These reports are generally referred to as "50-50 reports."

[2] See U.S. General Accounting Office, Depot Maintenance: Army Report 
Provides Incomplete Assessment of Depot-Type Capabilities, GAO/NSIAD-
00-20 (Washington, D.C.: Oct. 15, 1999).

[3] House Report 106-616 (May 12, 2000).

[4] The Army's maintenance structure for aircraft and components has 
only three categories: unit, intermediate, and depot.

[5] One key exception is the cost of military personnel involved in 
this category of work, which is accounted for in a separate, centrally 
managed, Military Personnel appropriations account.

[6] The five public depots are located at Anniston, Ala; Corpus 
Christi, Tex; Chambersburg, Pa; Texarkana, Tex; and Tobyhanna, Pa.

[7] Using working capital funds, organizations sell goods and services 
to customers on the basis of rates designed to recoup the full cost of 
operations.

[8] Interim contractor support is designed to be an interim arrangement 
in which a contractor provides depot-level maintenance (and sometimes 
other logistics support) as part of the acquisition strategy for new 
systems.

[9] Contractor logistics support is designed to be a lifetime support 
concept in which a contractor provides most or all elements of 
logistics support, including depot-level maintenance.

[10] Pub. L. No. 105-85 (Nov. 18, 1997) sections 355 and 357.

[11] See GAO/NSIAD-00-20.

[12] See U.S. General Accounting Office, Depot Maintenance: DOD's 50-50 
Reporting Should Be Streamlined, GAO-03-1023 (Washington, D.C.: Sept. 
5, 2003).

[13] See GAO/NSIAD-00-20.

[14] The National Maintenance Program is the Army's ongoing action to 
establish a fully integrated national maintenance requirements process 
that includes all depot-level maintenance requirements, regardless of 
the location of the work in a field facility or a maintenance depot.

[15] One-Time Repair actions are depot repairs that are accomplished at 
nondepot locations following an organization's request and approval to 
do this work on a limited basis.

[16] See GAO-03-1023.

[17] See GAO/NSIAD-00-20.

[18] See U.S. General Accounting Office, Depot Maintenance: Key 
Unresolved Issues Affect the Army Depot System's Viability, GAO-03-682 
(Washington, D.C.: July 7, 2003).

[19] See GAO-03-1023.

[20] See GAO/NSIAD-00-20.

[21] See GAO-03-1023.

[22] See GAO/NSIAD-00-20.

[23] See GAO-03-1023.

[24] See U.S. General Accounting Office, Defense Depot Maintenance: DOD 
Shifting More Workload for New Weapon Systems to the Private Sector, 
GAO/NSIAD-98-8 (Washington D.C.: Mar. 31, 1998).

[25] See GAO-03-1023.

[26] 10 U.S.C. 2466(b) provides that the Secretary of Defense may waive 
the 50 percent limitation if the Secretary determines that a waiver is 
necessary for reasons of national security and notifies Congress 
regarding the reasons for the waiver.

[27] See GAO-03-1023.

[28] See GAO/NSIAD-00-20.

[29] The Army plans to reduce the size of its logistics infrastructure 
by combining the current levels of maintenance into two levels: field-
level, which will be "repair and return to user," and sustainment-
level, which will be "repair and return to supply." 

[30] See GAO/NSIAD-00-20.

[31] The Joint Computer-Aided Acquisition and Logistic Support system 
is a multiservice program for developing the infrastructure to 
logistically support weapons systems throughout their life cycle.

[32] In July 2002, the Army changed the name of this program from the 
Wholesale Logistics Modernization Program to the Logistics 
Modernization Program. This is a new information system that is 
intended to help manage the Army's supply, maintenance, and 
transportation functions. Beginning in July 2003, the Logistics 
Modernization Program will replace many of the Army's old logistics 
information systems.

[33] See U.S. General Accounting Office, DOD Civilian Personnel: 
Improved Strategic Planning Needed to Help Ensure Viability of DOD's 
Civilian Workforce, GAO-03-472 (Apr. 30, 2003).

[34] See GAO/NSIAD-00-20.

GAO's Mission:

The General Accounting Office, the investigative arm of Congress, 
exists to support Congress in meeting its constitutional 
responsibilities and to help improve the performance and accountability 
of the federal government for the American people. GAO examines the use 
of public funds; evaluates federal programs and policies; and provides 
analyses, recommendations, and other assistance to help Congress make 
informed oversight, policy, and funding decisions. GAO's commitment to 
good government is reflected in its core values of accountability, 
integrity, and reliability.

Obtaining Copies of GAO Reports and Testimony:

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through the Internet. GAO's Web site ( www.gao.gov ) contains 
abstracts and full-text files of current reports and testimony and an 
expanding archive of older products. The Web site features a search 
engine to help you locate documents using key words and phrases. You 
can print these documents in their entirety, including charts and other 
graphics.

Each day, GAO issues a list of newly released reports, testimony, and 
correspondence. GAO posts this list, known as "Today's Reports," on its 
Web site daily. The list contains links to the full-text document 
files. To have GAO e-mail this list to you every afternoon, go to 
www.gao.gov and select "Subscribe to e-mail alerts" under the "Order 
GAO Products" heading.

Order by Mail or Phone:

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to:

U.S. General Accounting Office

441 G Street NW,

Room LM Washington,

D.C. 20548:

To order by Phone: 	

	Voice: (202) 512-6000:

	TDD: (202) 512-2537:

	Fax: (202) 512-6061:

To Report Fraud, Waste, and Abuse in Federal Programs:

Contact:

Web site: www.gao.gov/fraudnet/fraudnet.htm E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470:

Public Affairs:

Jeff Nelligan, managing director, NelliganJ@gao.gov (202) 512-4800 U.S.

General Accounting Office, 441 G Street NW, Room 7149 Washington, D.C.

20548: