B-209584 January 11, 1983

B-209584 January 11, 1983

The Honorable Carl D. Perkins Chairman, Committee on Education and Labor House of Representatives

Dear Mr. Chairman:

This is in response to your letter of October 6, 1982, forwarding to us an unsigned letter received by your office in which it is alleged that students at the National War College have keen organized to lobby for the defense budget on Capitol Hill. Specifically, the letter alleges that:

"Each student has been assigned a member of Congress who will be visited under the guise of discussing defense issues. The purpose is to influence the reconciliation conference, the continuing resolution process, and the 1984 budget. The student body has been broken up into seminars for purposes of developing lobbying strategies. The outcome will be to develop a plan for systematically increasing defense spending."

Our investigation has revealed that students at the National War College were indeed required to visit members of Congress as part of a seminar dealing with the legislative process. However, we found no evidence that the purpose of these visits was to lobby for the defense budget.

We asked the Department of Defense to comment on the allegations raised in the letter. DOD responded that the students at the National War College had visited members of Congress as part of an academic exercise and that the allegations of lobbying were unfounded. DOD explained that:

"The seminar in question is offered by the National War College under the name 'Strategic Studies Program.' It has been in existence for 3-4 years and offers students valuable insights into the legislative process. The program is divided into three sections, entitled 'Recent Trends in Congress', 'Military Reform Group', and 'Budget Process Group.' Under the program, students are assigned reading material and are then asked to contact a member of Congress and/or his staff about the legislative process and report back to the class on what they have learned. Students are not 'assigned' a member of Congress and most select members from their hometown. Since the discussions focus on the more general aspects as to how policy is made, there is no attempt to lobby on behalf of particular programs or the Department of Defense generally."

A memorandum to the College's students from the Dean of Students and Administration outlining the Capitol Hill assignment supports DOD's characterization of the visits as an "academic exercise" rather than a lobbying campaign. Instead of assigning students to meet with specified members of Congress, the memorandum instructs the students to plan to; meet one of the following:

"(1) Member of the House/Senate Armed Services Committee.

"(2) Member of the Defense Appropriations Subcommittee of the House/Senate Appropriations Committee.

"(3) Member of the House or Senate Veterans Affairs, Foreign Affairs, or Budget Committees. a(4) Their own House or Senate member."

The memorandum specifically encourages contact with "members representing a cross-section of opinion", i.e. "controversial members" as well as friends of defense." The memorandum defines the topic for discussion as "The Defense Policy Process in Congress: Who, How, and Why," and advises students to prepare specific questions before their visits. It thus appears pears that the Capitol Hill visits are intended to educate students at the College on the formulation of defense policy rather than to influence specific budgetary decisions.

It is accordingly our conclusion that no improper lobbying activity book place in this instance.

Sincerely yours,

Milton J. Socolar for Comptroller General of the united States