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entitled 'Defense Management: Continuing Questionable Reliance on 
Commercial Contracts to Demilitarize Excess Ammunition When Unused, 
Environmentally Friendly Capacity Exists at Government Facilities' 
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April 2, 2004:

The Honorable Donald H. Rumsfeld:

The Secretary of Defense:

Subject: Defense Management: Continuing Questionable Reliance on 
Commercial Contracts to Demilitarize Excess Ammunition When Unused, 
Environmentally Friendly Capacity Exists at Government Facilities:

Dear Mr. Secretary:

In April 2001, we reported that the Army Materiel Command's guidance 
required that 50 percent of the excess conventional ammunition 
demilitarization budget--a figure for which we did not find any 
analytical basis--be set aside for commercial firms that use 
environmentally friendly demilitarization processes. This resulted in 
the retention and underutilization of environmentally friendly 
demilitarization capabilities at government facilities and in 
additional program costs.[Footnote 1] We thus recommended that the 
Department of Defense (DOD) develop a plan in consultation with 
Congress that included procedures for assessing the appropriate mix of 
government and commercial sector capacity needed to demilitarize excess 
ammunition. Our intent was to have DOD reexamine the cost-effectiveness 
of using commercial versus government facilities to demilitarize excess 
ammunition. Over the past several months we have conducted work to 
determine the specific actions taken to implement our recommendation. 
We made extensive use of our prior work as a baseline to compare the 
changes in demilitarization capacity and utilization at government-
owned facilities since our prior report. We conducted our analysis of 
DOD's demilitarization program in accordance with generally accepted 
government auditing standards. The purpose of this letter is to bring 
to your attention that (1) the Army has taken only limited steps in 
response to our recommendation and (2) additional actions are needed to 
address our recommendation.

Results in Brief:

The Army continues to set aside 50 percent of the demilitarization 
budget to commercial firms, resulting in program inefficiencies and 
additional costs. In commenting on our recommendation in the April 2001 
report, DOD stated that the Army was preparing a study for Congress, 
due September 30, 2001, that could be used to address the mix of 
government and commercial sector capacity needed to demilitarize excess 
ammunition.[Footnote 2] The Army study concluded that, based upon its 
analysis of different commercial/government facility mixes, more 
ammunition could be demilitarized through greater reliance on existing 
environmentally friendly processes available at government-owned 
facilities. Nonetheless, the excess ammunition demilitarization 
program is still operated on Army Materiel Command guidance that 
requires a 50/50 split of funding between government and commercial 
demilitarization projects. This predetermined funding allocation, 
combined with increased government facility capacity to demilitarize 
excess ammunition and paying a commercial firm to have ammunition 
demilitarized by government employees, exacerbates the costs and 
related inefficiencies to operate the program.

Based on our follow-up efforts and analysis, this letter includes 
recommendations for executive action to enable the Army to operate a 
more efficient program and be better able to assess the 
demilitarization capacity needed at its government facilities. In 
commenting on a draft of the letter, DOD concurred with our 
recommendations and identified steps that it is taking to implement 
them.

Background:

The Secretary of the Army is the designated single manager of 
conventional ammunition for the Department of Defense. Under that 
umbrella, the Product Manager for Demilitarization is responsible for 
managing the demilitarization of conventional munitions for all of the 
military services.[Footnote 3] Demilitarization of conventional 
munitions takes place at government ammunition depots, plants, and 
centers--operated by the Joint Munitions Command, a subordinate command 
of the Army Materiel Command--and at contracted commercial 
firms.[Footnote 4] With the end of the Cold War, the services' need for 
conventional ammunition was significantly reduced, and by 1993 the Army 
reported a backlog of excess ammunition awaiting demilitarization that 
amounted to 354,000 tons, an amount that has since increased to about 
381,000 tons at the end of fiscal year 2003. To address this backlog, 
the Product Manager for Demilitarization's strategic plan includes a 
goal to reduce, through reasonable measures, the stockpile of excess 
conventional ammunition to 100,000 tons and 30,000 missiles in future 
years--considered a manageable level because higher quantities of 
excess ammunition are believed to impede access to needed ammunition 
and hinder the Army's ability to effectively support contingency 
operations.

In April 2001, we reported that the Army Materiel Command had 
previously issued guidance requiring that at least 50 percent of the 
excess conventional ammunition demilitarization budget be set aside for 
commercial firms that use resource, recovery, and recycling 
processes.[Footnote 5] While this guidance came about as a result of a 
request by the Chairman of the Senate Appropriations Subcommittee on 
Defense for DOD to look to commercial firms for environmentally 
friendly processes that could be used to help demilitarize excess 
ammunition, the Army Materiel Command initiated and expanded this 
effort without considering the impact on government facilities that 
have similar environmentally friendly demilitarization processes. Our 
report showed that the increased use of commercial firms to perform 
demilitarization resulted in the retention and underutilization of the 
more environmentally friendly resource, recovery, and recycling 
capabilities at government facilities. In fiscal year 2001, the 
government facilities were projected to operate at only 20 percent of 
their overall resource, recovery, and recycling demilitarization 
capacity. We also reported that additional costs were being incurred 
when a commercial firm undertook ammunition demilitarization for the 
Army, then contracted a portion of the work to three government 
facilities. The Army could have demilitarized the ammunition for less 
had it overseen the work itself.

Our report stressed the need for a greater emphasis on cost-
effectiveness and efficiency in deciding the appropriate mix of 
government and commercial demilitarization capacities instead of 
setting aside a predetermined 50 percent of the demilitarization budget 
for commercial firms--a percentage for which we did not find any 
analytical basis. In response to our concern, DOD stated that the Army 
was already preparing a study for Congress that addressed the 
feasibility of replacing open burning and open detonation with closed 
disposal technologies, and that this report, due September 30, 2001, 
could also be used to address the mix of government/commercial sector 
capacity needed to demilitarize excess ammunition.[Footnote 6]

The Army's Closed Disposal Technology Study used a computer-modeling 
input-output tool that integrates operating costs, capacity, and other 
variables in the demilitarization program to produce an optimal long-
range demilitarization plan to help determine the government/contractor 
mix for its demilitarization program.[Footnote 7] The study considered 
three options. Option 1 represented the current practice of allocating 
a predetermined 50 percent of the demilitarization funding to 
commercial firms; option 2 eliminated commercial firms from 
consideration; and option 3 had no predetermined funding allocation 
between commercial firms and government facilities. All three options 
required a minimum 65 percent utilization of environmentally friendly 
resource, recovery, and recycling processes.

According to the Army study, option 1 resulted in the greatest overall 
cost per ton over the 10-year period. Option 2 resulted in the lowest 
overall cost per ton; however, this was not considered a viable option 
because government facilities do not have resource, recovery, and 
recycling processes to demilitarize some types of ammunition. Under 
option 3, which was not constrained by a predetermined funding 
percentage assigned to commercial firms and government facilities, the 
study analysis identified a more cost-effective option than currently 
being pursued. The Army's model projected that the Army could more 
effectively use about $70.8 million in planned funding and demilitarize 
an additional 4,001 tons of ammunition during fiscal years 2002 through 
2011 compared to the current practice of allocating 50 percent of the 
demilitarization funding to commercial firms (see table 1). Under this 
option, over a 10-year period 29 percent of the demilitarization budget 
would go to commercial firms and 71 percent would go to government 
facilities, including use of the government's own environmentally 
friendly processes.

Table 1: Army Study Results Comparing Costs and Tons of Excess 
Ammunition Demilitarized by Devoting 50 Percent and 29 Percent of the 
Demilitarization Budget to Commercial Firms, Aggregate for Fiscal Years 
2002-11:

[See PDF for image]

Source: GAO analysis of Closed Disposal Technology Study.

[End of table]

The Army study concluded that, based upon its analysis, the 
demilitarization program should not assign a predetermined funding 
percentage to commercial firms and government facilities.

Army Practice Remains Unchanged,

Resulting in Inefficiencies and Additional Costs:

Despite the results of the Closed Disposal Technology Study, the Army 
continues to set aside 50 percent of the demilitarization budget to 
commercial firms, resulting in program inefficiencies and additional 
costs. According to the Product Manager for Demilitarization, the 
demilitarization program is still operated on guidance received from 
the Army Materiel Command that requires a 50/50 split of funding 
between government and commercial demilitarization projects. Moreover, 
since 2001, government facilities have increased their capacity to 
demilitarize excess ammunition using resource, recovery, and recycling 
processes from about 81,100 tons per year to about 156,600 tons per 
year, which has further exacerbated the inefficiencies associated with 
the existence of excess capacities in government facilities. This 
excess is further compounded by the realization that the maximum amount 
of excess ammunition that the Army can demilitarize using the resource, 
recovery, and recycling methods is limited to 170,946 tons out of the 
381,000 tons in the stockpile.

The increased government capacity and continued use of commercial firms 
to demilitarize excess ammunition at the same time the government 
facilities have existing excess capacity continues to raise questions 
about the appropriate mix of government and commercial sector capacity 
needed to demilitarize excess ammunition and the cost efficiency of the 
demilitarization program. Specifically, based on the current practice 
of setting aside 50 percent of the demilitarization budget for 
commercial demilitarization, we estimate that government facilities 
will operate at only 6 percent of their overall environmentally 
friendly demilitarization capacity to recover and reuse 156,600 tons of 
excess ammunition in fiscal year 2004 (see table 2).

Table 2: Government Facility Recovery and Reuse Demilitarization 
Capacity and Planned Use in Fiscal Year 2004:

Location: Anniston; 
Recovery and reuse capacity (tons): 1,000; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Location: Blue Grass; 
Recovery and reuse capacity (tons): 14,000; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Location: Crane; 
Recovery and reuse capacity (tons): 13,300; 
Recovery and reuse demilitarization planned (tons): 1,584; 
Percent of capacity to be used: 12.

Location: Hawthorne; 
Recovery and reuse capacity (tons): 49,000; 
Recovery and reuse demilitarization planned (tons): 4,599; 
Percent of capacity to be used: 9.

Location: Iowa; 
Recovery and reuse capacity (tons): 14,000; 
Recovery and reuse demilitarization planned (tons): 1,517; 
Percent of capacity to be used: 11.

Location: Letterkenny; 
Recovery and reuse capacity (tons): 1,000; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Location: Lone Star; 
Recovery and reuse capacity (tons): 2,000; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Location: Milan; 
Recovery and reuse capacity (tons): 1,800; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Location: McAlester; 
Recovery and reuse capacity (tons): 25,000; 
Recovery and reuse demilitarization planned (tons): 2,010; 
Percent of capacity to be used: 8.

Location: Pine Bluff; 
Recovery and reuse capacity (tons): 3,500; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Location: Red River; 
Recovery and reuse capacity (tons): 1,000; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Location: Sierra; 
Recovery and reuse capacity (tons): 24,000; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Location: Tooele; 
Recovery and reuse capacity (tons): 7,000; 
Recovery and reuse demilitarization planned (tons): 0; 
Percent of capacity to be used: 0.

Total; 
Recovery and reuse capacity (tons): 156,600; 
Recovery and reuse demilitarization planned (tons): 9,710; 
Percent of capacity to be used: 6.

Source: GAO analysis of data provided by the Defense Ammunition Center 
and the Product Manager for Demilitarization.

[End of table]

In addition, the Army continues to incur additional and unnecessary 
costs to the demilitarization program through its practice of 
contracting with a commercial firm to undertake ammunition 
demilitarization, which in turn contracted a portion of the work to 
three government facilities.[Footnote 8] In essence, the Army paid a 
commercial firm to have the ammunition demilitarized by government 
employees and incurred higher than necessary costs. More specifically, 
in one instance the commercial firm undertook ammunition 
demilitarization of 1,848 items for the Army for about $563 per item, 
and then contracted some of the work to a government facility for about 
$141 per item. If the Army had placed greater emphasis on cost-
effectiveness and cost-efficiency, the Army could have demilitarized 
the ammunition for about $780,000 less had it overseen the work itself.

Conclusion:

As we have previously noted, while it may be appropriate to rely on the 
private sector to enhance demilitarization capabilities, the continued 
use of the private sector to demilitarize excess ammunition at the same 
time the government facilities have excess capacity raises the question 
of whether the government is sponsoring too much capacity. Likewise, 
such limitations in use of government facilities continues to result in 
less demilitarization than would otherwise be possible even under 
existing funding levels. We do not believe that the Army has taken 
sufficient action to address the recommendation we made in our April 
2001 report, which called for the department to develop a plan in 
consultation with Congress that includes procedures for assessing the 
appropriate mix of government and commercial sector capacity needed to 
demilitarize excess ammunition and the cost-effectiveness of using 
contractors versus government facilities to demilitarize excess 
ammunition, with specific actions identified for addressing the 
capacity issue. We also do not believe that the Army has taken 
sufficient action to address the results of its Closed Disposal 
Technology Study, which concluded that the demilitarization program 
should not assign a predetermined funding percentage to commercial 
firms and government facilities, thus validating our findings and 
recommendation. Further, by paying a commercial firm to have excess 
ammunition demilitarized by government employees, the Army incurs 
higher than necessary costs. Until the Army discontinues its practice 
of setting aside 50 percent of the demilitarization budget to 
commercial firms and implements a more analytically based approach to 
workload allocations--such as set forth in the Closed Disposal 
Technology Study--that eliminates any predetermined funding allocation 
and discontinues the practice of paying a commercial firm to oversee 
the work of government employees, the Army will continue to 
underutilize demilitarization capacity at government facilities and 
risk incurring additional program costs.

Recommendations for Executive Action:

To enable the Army to operate a more efficient program and be better 
able to assess the demilitarization capacity needed at its government 
facilities, we recommend that you direct the Secretary of the Army to 
take the following three steps:

* discontinue the practice of setting aside an arbitrary 50 percent of 
the demilitarization budget to commercial firms;

implement a more analytically based approach to demilitarization 
workload allocations such as demonstrated in the Closed Disposal 
Technology Study analysis in which no arbitrary, predetermined funding 
allocation is made to commercial firms and government facilities; and:

discontinue the practice of paying a commercial firm to have ammunition 
demilitarized by government employees when the work can be overseen by 
the Army for less cost.

:

As you know, 31 U.S.C. 720 requires the head of a federal agency to 
submit a written statement of the actions taken on our recommendations 
to the Senate Committee on Governmental Affairs and the House Committee 
on Government Reform not later than 60 calendar days after the date of 
this letter. A written statement must also be sent to the House and 
Senate Committees on Appropriations with the agency's first request for 
appropriations made more than 60 calendar days after the date of this 
letter.

Agency Comments and Our Evaluation:

The Director of Defense Systems in the Office of the Under Secretary of 
Defense for Acquisition, Technology, and Logistics provided written 
comments on a draft of this letter. DOD's comments are reprinted in the 
enclosure. DOD agreed with our recommendations and identified steps 
that it is taking to implement them. In commenting on our 
recommendation to discontinue the practice of setting aside an 
arbitrary 50 percent of the demilitarization budget to commercial 
firms, DOD stated that the U.S. Army Materiel Command has rescinded 
this policy and that the fiscal year 2005 demilitarization program will 
not be constrained by a predetermined percentage set aside for the 
private sector.

In commenting on our recommendation to implement a more analytically 
based approach to demilitarization workload allocations, DOD stated 
that it will establish a team to perform a study to determine an 
analytical based approach for allocating demilitarization workload for 
the private sector and government and for enhancing its computer-
modeling program to be more robust as a decision making tool, including 
performing planning and analysis of government and commercial 
demilitarization workload. DOD stated that it plans to complete the 
study during fiscal year 2004 and to implement the results early in 
fiscal year 2005.

In commenting on our recommendation to discontinue the practice of 
paying a commercial firm to have ammunition demilitarized by government 
employees when the work can be overseen by the Army for less cost, DOD 
stated that it will add language to the follow-on commercial contract, 
anticipated for award in early fiscal year 2005, addressing the 
involvement between industry and government that considers an economic-
cost benefit analysis and awards demilitarization workload without 
regard to location of execution when an effort is in the best interests 
of the government.

Scope and Methodology:

To identify any limitations in the actions that the Army has taken in 
response to a recommendation contained in our prior report on the 
Army's management and oversight of excess ammunition, we reviewed 
applicable policies, procedures, and documents governing the 
demilitarization program. We made extensive use of our prior work as a 
baseline to compare the changes in demilitarization capacity and 
utilization at government-owned facilities since our prior 
report.[Footnote 9] We reviewed the Army's Closed Disposal Technology 
Study and analyzed the report's scope and methodology, findings, and 
conclusions related to the appropriate mix of government and commercial 
sector utilization needed to demilitarize excess ammunition. The Army's 
study used a computer-modeling tool that integrates operating cost, 
capacity, and other variables in the demilitarization program to 
produce an optimal long-range demilitarization plan. Additionally, 
various forms of constraints can be placed on the model, such as 
requiring the model to execute a certain percentage of demilitarization 
operations using resource, recovery, and recycling processes; 
allocating a certain minimum funding to commercial firms; or providing 
a specified level of workload to selected locations, either commercial 
firms or government facilities. For the study, the model used the 
following input data:

demilitarization capabilities and capacities available at government 
and commercial facilities;

existing and forecasted inventory levels of excess ammunition;

funding levels for each year's forecasted demilitarization program;

transportation costs between demilitarization locations, to include 
packing, crating, and handling;

percentages of resource, recovery, and recycling processes and open 
burning and open detonation/incineration processes, by weight, for 
various types of ammunition; and:

costs to perform demilitarization at government and commercial 
facilities.

While we did not assess the reliability of the model or validate the 
results, we did interview agency officials knowledgeable about the 
model and its data and we reviewed the types of input data and the 
constraints placed on the model to assure ourselves that the results 
appeared to be consistent. This allowed us to understand whether DOD's 
current practice is the most cost-effective program, considering 
capability, capacity, and cost data for both government and commercial 
facilities. Based on our analyses, we determined that the data were 
sufficiently reliable for the purposes of this letter.

To obtain current demilitarization program information and action taken 
since our report was published in April 2001, we met with officials and 
performed work at the Office of the Product Manager for 
Demilitarization, Picatinney Arsenal, New Jersey; McAlester Army 
Ammunition Plant, McAlester, Oklahoma; Army Materiel Command, Fort 
Belvoir, Virginia; and U.S. Army Defense Ammunition Center, McAlester, 
Oklahoma. For example, to assess the extent that the Army used 
commercial firms to demilitarize excess ammunition and its impact on 
the utilization of environmentally friendly demilitarization processes 
at government facilities, we obtained Army data on the government 
facilities' capabilities to demilitarize excess ammunition and compared 
the Army's demilitarization plans to these capabilities. This allowed 
us to identify and calculate excess capacity situations and compare 
this data with our prior work done on excess capacity at government 
facilities. We also obtained and reviewed contractor agreements with 
government facilities to perform the demilitarization work and 
evaluated contract information provided by the Army and by one 
government facility to determine if the government facility could have 
demilitarized the ammunition for less cost than was incurred by the 
Army's contract with this firm. We interviewed Army officials about the 
cost-effectiveness of relying on commercial firms to demilitarize 
excess ammunition at the same time that government facilities have 
similar demilitarization capabilities.

We conducted our analysis of DOD's demilitarization program from June 
2003 through January 2004 in accordance with generally accepted 
government auditing standards.

We are sending copies of this letter to the appropriate congressional 
committees and interested congressional committees and members. The 
letter is also available on GAO's homepage at http://www.gao.gov. If 
you or your staff have any questions on the matters discussed in this 
letter, please contact me at (202) 512-5581. Key contributors to this 
letter were Ron Berteotti, Roger Tomlinson, Chad Factor, and Robert 
Wild.

Sincerely yours,

Signed by: 

Barry Holman, Director:

Defense Capabilities and Management:

Enclosure:

(350394):

FOOTNOTES

[1] U.S. General Accounting Office, Defense Inventory: Steps the Army 
Can Take to Improve the Management and Oversight of Excess Ammunition, 
GAO-01-372 (Washington, D.C.: Apr. 12, 2001). As described in the 
report, the Army defines demilitarization as the act of removing the 
military offensive or defensive characteristics from munitions or 
otherwise rendering munitions innocuous or ineffectual for military 
use. Demilitarization includes, but is not limited to, processes 
involving resource recovery, recycling, reutilization, disassembly, 
conversion, melt out/steam out/wash out, incineration, open burning, 
and open detonation, to name a few.

[2] Joint Ordnance Commanders Group Munitions Demil/Disposal Subgroup 
Closed Disposal Technology Study (McAlester, Okla.: Sept. 2001). The 
study was in response to H.R. 106-754, directing the Army to prepare a 
report on the feasibility of replacing open burning and detontating 
processes with closed disposal technologies. 

[3] The Product Manager for Demilitarization is a management office of 
the Army Acquisition Corps and chartered by the Army Acquisition 
Executive (the Assistant Secretary of the Army for Acquisition, 
Logistics & Technology). The Product Manager for Demilitarization is 
under the Office of the Project Manager for Joint Services reporting to 
the Program Executive Officer for Ammunition. The Secretary of the Army 
is the DOD-designated Single Manager for Conventional Ammunition and 
the Program Executive Officer for Ammunition, as designated by the 
Secretary of the Army, acts as the single manager for conventional 
ammunition executor.

[4] Until December 2002, the Commander, U.S. Army Materiel Command, as 
designated by the Secretary of the Army, acted as the single manager 
for conventional ammunition for DOD.

[5] GAO-01-372.

[6] Joint Ordnance Commanders Group Munitions Demil/Disposal Subgroup, 
Closed Disposal Technology Study (McAlester, Okla.: Sept. 2001). 
HouseReport106-754 directed the study. H.R. Conf. Rep. No. 106-754, at 
99 (2000). On September 27, 2001, the study was sent to the Chairman 
and Ranking Member of the Senate Appropriations Subcommittee on 
Defense; the Chairman and Ranking Member of the Senate Committee on 
Armed Services; the Chairman and Ranking Member of the House 
Appropriations Subcommittee on Defense; and the Chairman and Ranking 
Member of the House Committee on Armed Services. 

[7] We did not assess the reliability of the model or validate the 
results; however, we did interview agency officials knowledgeable about 
the model and its data and we did take steps to confirm that the model 
results appeared to be consistent. Additional details are provided in 
the scope and methodology section. 

[8] The commercial firm entered into agreements for demilitarization 
services with government facilities at McAlester, Oklahoma; Crane, 
Indiana; and Tooele, Utah.

[9] GAO-01-372.