Defense Infrastructure: Historic Properties within the Department of
Defense (Testimony, 03/15/2001, GAO/GAO-01-497T).

The Office of the Secretary of Defense and the service headquarters
provide overall policy guidance as well as have negotiated agreements
regarding treatment of certain types of historic properties across the
Department or respective services. However, the majority of the
decisions regarding historic properties are made at the installation
level. The installations are responsible for identifying and evaluating
properties to determine if they meet the criteria to be eligible for
listing on the National Register of Historic Places as well as
maintaining all properties that are listed on or have been determined
eligible for listing on the National Register. The military services do
not have complete and reliable data on the number of its historic
properties. None of the services have a centralized database that
comprehensively identifies all of their respective historic properties.
Data is not readily available to identify the costs of maintaining
historic properties or to separately account for repairs related to the
historic aspects of these properties. The services do not account
separately for or otherwise distinguish between money spent to maintain
and repair historic properties and that spent on non-historic
properties. Cost data GAO examined at several installations showed that
overall, the day-to-day maintenance conducted on historic properties was
similar to maintenance on non-historic properties.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-497T
     TITLE:  Defense Infrastructure: Historic Properties within the
	     Department of Defense
      DATE:  03/15/2001
   SUBJECT:  Historic preservation
	     Military facilities
	     Cost analysis
	     Maintenance costs
IDENTIFIER:  National Register of Historic Places

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GAO-01-497T

DEFENSE INFRASTRUCTURE

Historic Properties within the Department of Defense Statement of Henry L.
Hinton, Jr., Managing Director, Defense Capabilities and Management

United States General Accounting Office

GAO Testimony Before the Subcommittee on Military Construction,

Committee on Appropriations, House of Representatives

For Release on Delivery 9: 30 a. m. EDT Thursday, March 15, 2001

GAO- 01- 497T

1 GAO- 01- 497T Defense Infrastructure

Mr. Chairman and Members of the Subcommittee: I am pleased to be here today
to discuss the management of historic properties 1 within the Department of
Defense (DOD), the current and projected inventory of these properties, and
the cost to maintain these properties. My testimony is based on the
preliminary results of work we have done in response to a legislative
mandate included in the Floyd D. Spence National Defense Authorization Act
for Fiscal Year 2001, which required us to determine the reliability of the
services' current and projected inventory of historic properties and the
availability of data on the cost of maintaining and repairing these
properties. Before discussing our specific observations, I would like to
briefly summarize the key points in my statement.

RESULTS IN BRIEF

To be designated historic, a property must meet criteria specified in the
Historic Preservation Act of 1966 such as being associated with historic
events or people or being architecturally significant. The Office of the
Secretary of Defense and the service headquarters provide overall policy
guidance as well as have negotiated agreements regarding treatment of
certain types of historic properties across the Department or respective
services. However, the majority of the decisions regarding historic
properties are made at the installation level. The installations are
responsible for identifying and evaluating properties to determine if they
meet the criteria to be eligible for listing on the National Register as
well as maintaining all properties that are listed on or have been
determined eligible for listing on the National Register.

Based on our work thus far, the military services do not have complete and
reliable data on the number of its historic properties. None of the services
have a centralized database that comprehensively identifies all of their
respective historic properties. Available data indicates

1 There are five types of historic properties. Buildings are defined as any
construction sheltering human activity. Structures are defined as any
constructions other than for human shelter and include such items as
airplanes, bridges, and highways. Objects are distinguished from buildings
and structures based on being artistic in nature and small in scale and
include monuments, boundary markers, and statuary. A site is a location of
significance such as a battlefield, cemetery, or shipwreck and also includes
archeological locations. A district is defined as “possessing a
significant concentration, linkage, or continuity of buildings, structures,
objects, or sites united historically or aesthetically by plan or physical
development.”

2 GAO- 01- 497T Defense Infrastructure

that the services have about 17,300 historic properties-- about 10,100 in
the Army. 2 This represents less than 5 percent of all Department of Defense
facilities and most of the historic buildings are in use. However, because
of inconsistencies between the services' real property databases and
cultural resource records, and the lack of an inventory of properties that
are eligible for listing on the National Register, the reliability of this
number is questionable. Further, while there is a large number of properties
that need to be evaluated over the next 10 years, it is uncertain how many
of these properties will meet the criteria and become eligible for listing
on the National Register.

Data is not readily available to identify the costs of maintaining historic
properties or to separately account for repairs related to the historic
aspects of these properties. The Services do not account separately for or
otherwise distinguish between money spent to maintain and repair historic
properties and that spent on non- historic properties. Cost data we examined
at several installations showed that overall, the day- to- day maintenance
conducted on historic properties was similar to maintenance on non- historic
properties. However, the costs of such maintenance can be proportionally
greater where historic properties are larger in size than current military
requirements. This is especially true of historic military family housing.
At the same time, replacement of unique historical features such as large
porches, windows, and slate or tile roofs can result in higher maintenance
and repair costs for historic properties in the year the work is performed.

BACKGROUND

The National Historic Preservation Act of 1966 3 established a national
historic preservation program to provide for the ongoing identification and
protection of historic properties. Under the act, an historic property is
any building, structure, object, site, or district included in or eligible
for inclusion in the National Register of Historic Places. 4 To be eligible
for the National Register, a property must meet one of the following four
criteria: (1) be associated with significant historic events or activities,
(2) be associated with people important in our past, (3) embody distinctive
design or physical characteristics, or (4) have the potential to

2 This figure is limited to buildings and structures and excludes World War
II wood buildings that have been approved for demolition. 3 P. L. 89- 665,
as amended, is codified at 16 U. S. C. 470 et. seq.

3 GAO- 01- 497T Defense Infrastructure

provide important information about prehistory or history. In addition, the
property generally has to be 50 years of age or older.

The act generally requires federal agencies to identify, evaluate, and
nominate historic properties under agency control to the National Register.
DOD requires each installation to prepare a cultural resource management
plan every 5 years to satisfy this requirement. The plan includes an
inventory of all properties that are listed on or have been determined
eligible for listing on the National Register as well as an evaluation of
properties that will reach 50 years of age over the time period covered by
the plan.

The act also requires that federal agencies (1) consider the effects of any
maintenance, repair, or renovation on historic properties- both those listed
and eligible for listing in the National Register, and (2) consult with the
State Historic Preservation Officers to reach an agreement regarding actions
that affect historic properties that is beneficial to all. Thus, when
installation officials are about to begin work on a property either on or
eligible for inclusion on the National Register, they should consult with
the state about what work will be accomplished and what materials will be
used, however, responsibility for funding the work remains with the
Department of Defense.

INSTALLATIONS ARE PRIMARILY RESPONSIBLE FOR MANAGEMENT OF HISTORIC
PROPERTIES

The Office of the Secretary of Defense and the service headquarters have
provided overall policy guidance for the historic properties program as well
as negotiated agreements regarding treatment of certain types of historic
properties across DOD or their respective service. However, the majority of
the decisions regarding historic properties are made at the installation
level. The installations are responsible for identifying and evaluating
properties to determine if they meet the criteria to be eligible for listing
on the National Register as well as maintaining all properties that are
listed on or have been determined eligible for the National Register.

4 The National Park Service administers the National Register.

4 GAO- 01- 497T Defense Infrastructure

The Office of the Secretary of Defense has issued policy guidance on
cultural resources management, which requires each of the service
headquarters to develop a cultural resources program and each installation
to develop a cultural resources management plan, which should include an
inventory of historic properties. In addition, the Office of the Secretary
of Defense and the service headquarters have negotiated agreements regarding
historic properties. For example, the Office of the Secretary of Defense has
negotiated an agreement with the Advisory Council on Historic Preservation
and the National Conference of State Historic Preservation Officers that
allows the services to demolish all World War II wood buildings. 5 The Army
would like to propose a similar agreement that would allow it to demolish
certain Cold War Era properties. In addition, the Navy has negotiated an
agreement with the Advisory Council and the National Conference regarding
the management of its historic family housing. The agreement allows the Navy
to prioritize maintenance and repair actions among historic family housing.
The Army has a proposed draft document with the Council that could provide
more efficient consultation with the State Historic Preservation Officers.

Each DOD installation identifies and evaluates properties that will reach 50
years of age as part of its cultural resources management plan. Once an
installation completes its evaluation of properties, it consults with the
State Historic Preservation Officer. If installation and State Historic
Preservation officials agree that a property meets the criteria, it is
considered eligible for the National Register. If the State Office disagrees
with the installation's recommendation, the service must seek a formal
determination of eligibility from the National Park Service. 6 Officials at
the installations we visited stated that they generally have been able to
reach an agreement with the State Historic Preservation Officer on whether
properties are or are not eligible for listing on the National Register.
Once a property has been determined eligible for listing on the National
Register, the installation must manage it the same as any property that is
listed in the Register. For this reason, and because a formal nomination can
be expensive and divert resources from other cultural resource management

5 The Advisory Council on Historic Preservation is a federal agency set up
by the National Historic Preservation Act that advises all other federal
agencies in ways to effectively carry out provisions of the act. The
National Conference of State Historic Preservation Officers is the
professional association of the state government officials who carry out the
national historic preservation program. 6 The Keeper of the National
Register makes the final determination of property eligibility.

5 GAO- 01- 497T Defense Infrastructure

activities, actual nomination of properties to the National Register is not
a high priority within the services. For example, the Army's Cultural
Resources Management regulations 7 state that “the Army will formally
nominate only those properties that it intends to interpret, commemorate, or
otherwise actively manage as sites of popular interest that are normally
open to the general public.”

The installations are also responsible for consulting with the State
Historic Preservation Officers regarding maintenance and repair work on
historic properties. Cultural resource officials at the installations we
visited stated that they spend more time consulting with the Officers on the
maintenance and repair of historic properties than on whether properties
meet the criteria for listing on the National Register. Some of the
installations we visited have agreements with the Officers on the types of
maintenance and repair projects that require consultation. For example, the
cultural resource official at Fort Leavenworth stated that he only consults
with the State Office on major projects that will affect the exterior of
historic properties but not on routine maintenance and repair projects.

DATA ON THE NUMBER OF HISTORIC PROPERTIES IS NOT RELIABLE

Although the military services maintain cultural resource records on
historical properties and real property databases, containing both
historical and nonhistorical properties; they do not have complete and
reliable data on the number of historic properties. None of the services
have a centralized database that identifies all of their respective historic
properties. Our analysis of data from the military services' real property
databases and cultural resource records indicates the services have about
17,300 historic properties, most of which are inuse. However, results of
military service auditor tests of additions, deletions, and modification
transactions for fiscal year 1999 indicated that real property transactions
were not promptly recorded. This problem, along with issues we identified
such as conflicting information between the Army's real property database
and its cultural resource records, and the lack of information on Navy and
Air Force properties that are eligible for listing, raise questions
regarding the reliability of the services' information. Further, while there
is a large

7 Army Regulation 200- 4, Cultural Resources Management.

6 GAO- 01- 497T Defense Infrastructure

number of properties that need to be evaluated over the next 10 years, it is
uncertain how many of these properties will meet criteria and become
eligible for listing on the National Register.

Although each service maintains a real property database that should
indicate whether individual buildings and structures are historic
properties, our work has shown that these databases are not reliable. For
example, the Navy, Marine Corps, and Air Force systems only identify
properties on the National Register, not properties that are eligible for
listing on the National Register. While the Army database includes both
listed and eligible properties, it does not include all the properties
identified as historic in the cultural resource records. At the same time,
questions regarding the accuracy and completeness of cultural resource
records exist. The number of historic properties in table 1 represents our
analysis of the services' real property databases and cultural resource
records.

Table 1: Historic Properties by Service Number of historic properties
Service Listed Eligible Total

Army a a 10,110 b Navy 2,135 391 c 2,526 Marine Corps 49 590 c 639 Air Force
1,691 2,346 c 4,037

Total 17,312

7 GAO- 01- 497T Defense Infrastructure

a Army data does not identify whether a property is listed on or eligible
for the National Register. b This figure excludes 8,254 buildings approved
for demolition. c These service real property databases do not include
information on eligible properties; these numbers were developed from the
services' cultural resource records.

Source: Our analysis of available service data. While information included
in table 1 provides the best available data on the number of historic
properties, it is subject to certain limitations. The following examples
highlight the problems we had in determining the number of historic
properties within each service.

ï¿½ The Army's real property database identifies 6,189 properties and its
cultural resource records, maintained at each installation, indicate 8,593
properties as historic- excluding buildings approved for demolition. 8 Our
comparison of information between these two data source indicates the Army
has 10,110 historic properties. Army officials stated that the additional
properties that are included in cultural resource records represent
properties that are eligible for listing, but installations have not updated
the real property database. For example, the cultural resource records
identify 1,790 historic properties at Hawthorne Army Depot, Nevada, which
are not identified as historic in the Army's real property database. About
1,533 of these historic properties are munitions storage structures.

ï¿½ The Navy's real property database identifies 1,283 historic properties,
but our work indicates the Navy has at least 2,526 such properties. The
database does not identify 855 9 historic properties that are included in
the Pearl Harbor, Hawaii, historic district. In addition, the database does
not identify 295 family housing dwellings at various locations, 64
properties at Naval Shipyard Portsmouth, Maine, nor 32 properties at the
Naval Academy, Maryland, as historic properties eligible for listing on the
National Register. The cultural resource office does not maintain records on
properties eligible

8 The Army has a category of 8,254 historic buildings called “World
War II Wood.” DOD has an agreement with the Advisory Council on
Historic Preservation and the National Conference of State Historic
Preservation Officers that allows it to demolish all the buildings in this
category. The Army plans to demolish most of its inventory of World War II
Wood properties but to maintain those for which there is an operational
requirement. We did not include any buildings in this category in our Army
total.

8 GAO- 01- 497T Defense Infrastructure

for listing on the Register, so we could not determine how many properties
might be eligible throughout the Navy.

ï¿½ The Marine Corps uses the same real property database as the Navy, and it
does not identify properties that are eligible for listing on the Register.
Our analysis of available cultural resource records at Marine Corps
headquarters indicates there are 590 properties eligible for listing,
including 239 at the Marine Corps Combat Development Center, Quantico,
Virginia, and 210 at Marine Corps Base Camp Lejeune, North Carolina.

ï¿½ The Air Force cultural resource records identified 2,346 eligible
properties; however, the cultural resource office could not identify where
1,183 of these properties were located. An Air Force cultural resource
official stated that the number of eligible properties was developed from a
1999 inquiry- telephone and e- mail responses- but no supporting
documentation was retained. The remaining 1,163 eligible properties were
family housing that the Air Force can identify by base.

Service officials stated they are aware of the inconsistencies in the number
of historic properties between the real property databases and the cultural
resource records. Army officials in the Office of the Assistant Chief of
Staff for Installation Management stated that they are working to reconcile
the differences between the real property database and each installation's
cultural resource records. The Navy cultural resource manager agreed that
the existing real property database does not accurately capture data on
historic properties. He also acknowledged that the database does not
distinguish between properties that are listed on the National Register and
those determined to be eligible for listing, and whether properties are part
of a historic district or listed individually. However, he stated that the
Navy is updating the real property database to allow it to make these
distinctions.

9 The Navy is developing a programmatic agreement with the state of Hawaii
regarding the potential reuse and demolition of some of these properties.

9 GAO- 01- 497T Defense Infrastructure

Most Historic Properties Are Being Used Cultural resource officials in each
of the service headquarters stated, and our own observations confirmed, that
the majority of the historic properties are being used. About 36 percent of
all historic properties are family housing dwellings. There were, however, a
relatively small number of vacant buildings at some of the installations we
visited. In some cases, the installations were developing plans to lease
these properties to the private sector.

At the installations we visited, 87, or about 4 percent, of the identified
2,395 historic properties were vacant. In some cases, the buildings were
vacant because the bases did not have sufficient funds to make the buildings
usable and/ or the structures were no longer needed for mission
requirements. For example, 2 of the identified 65 historic properties at the
Naval Training Center, Great Lakes, were vacant because, according to the
installation's Director of Public Works, funds were not available to repair
and update the property for administrative office space. At Portsmouth Naval
Shipyard, Maine, there was no mission requirement for the naval prison
structure there that has been closed since 1974. Navy officials at
Portsmouth were trying to lease the prison building and six other historic
properties to the private sector. Other locations were also developing plans
to lease vacant buildings, including 40 historic buildings at Fort Sam
Houston, Texas. 10

Further, each of the services has demolished properties that no longer are
needed to meet mission requirements and have lost their historical
significance or structural integrity. In fact, seven of the nine
installations we visited had demolished or reached an agreement with their
respective state preservation office to demolish certain historic
properties. For example, officials at Fort Bliss, Texas, stated they have an
agreement to demolish 24 historic properties as long as other historic
properties that were considered more significant are maintained. Likewise, 5
of the 107 original historic properties have been demolished at Scott Air
Base, Illinois.

The Potential for Increased Numbers of Historic Properties in the Future is
Uncertain

10 10 U. S. C. 2667 allows DOD to lease nonexcess property to others.

10 GAO- 01- 497T Defense Infrastructure

According to service real property databases, about 73,600 properties within
the services will turn 50 years of age over the next 10 years. As seen in
table 2, housing accounts for about 46,400, or about 63 percent, of the
properties that will turn 50 years of age over the next 10 years. However,
the services will not know whether any of these properties are eligible for
listing until the cultural resource officials at the various military
installations evaluate the properties using the National Register criteria.

Table 2: Properties Reaching 50 Years of Age between 2001 and 2010 Type of
property Number Percent

Housing 46,461 63 Other 27,163 37

Total 73,624 100

Source: Military service real property databases. Service plans to privatize
11 and demolish housing over the next several years could reduce the
potential number of properties that would have to be evaluated by the
services for listing on the National Register. In addition, the Army is
considering legislation that would seek to exempt Cold War era housing known
as Capehart and Wherry from National Historic Preservation Act compliance.

The potential eligibility of the remaining properties will not be known
until installation cultural resource officials evaluate the properties to
determine if they meet the National Register criteria. This should occur
over the next 10 years as the properties reach 50 years of age. Although
properties at the installations we visited comprise only a small portion of
the properties that will turn 50 years of age over the next 10 years,
cultural resource officials at most of these installations do not believe
that many of these properties will be found to have

11 Congress authorized the Military Housing Privatization Initiative, which
permitted DOD to enter into a variety of arrangements with private sector
entities to build and renovate military housing both on or near military
bases 10 U. S. C. 2871- 2885.

11 GAO- 01- 497T Defense Infrastructure

historical significance or unique architectural features that would make
them eligible for the National Register. For example, the cultural resource
officer at Fort Bliss believes only 48 of its 381 properties could be
eligible for the National Register.

INFORMATION ON THE COST TO MAINTAIN AND REPAIR HISTORIC PROPERTIES IS NOT
READILY AVAILABLE

We were unable to determine composite maintenance and repair cost for fiscal
year 2000 for DOD's historic properties because the services do not identify
or account separately for the money spent to repair and maintain historic
properties or to restore the historic aspects of these properties. Our
analysis of cost data and interviews with officials at several installations
indicate that overall, the day- to- day maintenance and repair conducted on
historic properties is similar to maintenance and repair on non- historic
properties. However, the costs of such maintenance can be proportionally
greater where historic properties are larger in size than non- historic
properties. This is especially true of historic military family housing.
Replacement of unique historic features such as large porches, windows, and
slate or tile roofs can also add to the cost of maintenance and repair in
the year that the work is performed. In the past, the military services have
provided annual budget exhibits to Congress that showed the inventory and
the cost to maintain, repair, and improve historic family housing. The
Department eliminated the cost exhibit for the fiscal year 2002 budget
submission, but it will still require the services to provide budget
exhibits showing their inventory of historic housing.

The military services do not routinely track information on the overall cost
to maintain and repair historic properties. In addition, they do not
separately or otherwise distinguish between money spent to maintain historic
properties and that spent on non- historic properties. Information obtained
in our discussions with installation officials and review of maintenance and
repair projects and costs indicated that overall the day- to- day
maintenance of historic properties was similar to non- historic properties.
Officials at most of the installations we visited noted that deciding which
maintenance and repair projects to fund is based on mission and worse case
conditions, and not on whether a property is historic or nonhistoric. Also,
officials at each of the services noted growing backlogs of maintenance and
repair projects that limit the amount of preventive maintenance that is done
on historic as

12 GAO- 01- 497T Defense Infrastructure

well as non- historic properties. They stated that tradeoffs are often
required to address the most critical needs.

While available information indicates that day- to- day maintenance and
repair conducted on historic properties is similar to such work on non-
historic properties, prior DOD and service studies have also shown that the
size of historic properties, especially historic military family houses, can
result in costs being larger when compared to non- historic properties. For
example, a 1997 Army family housing report to Congress 12 stated that the
average historic house is 3,376 gross square feet while the average size of
a non- historic house is 1,490 gross square feet. On a square foot basis the
report concludes routine maintenance and repair may be comparable between
historic and non- historic properties, about $2.60 per square foot. 13
However, the study states that “the larger the dwelling unit (more
roof area, square feet of walls and floors) the more maintenance and
utilities funding required.” The 1997 Navy report to Congress 14 and a
September 2000 draft DOD report 15 provide similar data and conclusions.

At the same time, prior DOD and service historic reports and service
officials we spoke with indicated that the unique features of some historic
buildings result in higher maintenance and repair costs. Some historic
houses have slate or tile roofs, copper downspouts and gutters, or large
wooden porches whereas most non- historic homes do not have these features.
For example, at Fort Leavenworth, craftsmen repaired porches averaging about
800 square feet for about $20,757 each in fiscal year 1999. While repair or
replacement of these features may represent sizeable costs in the year in
which they occur, some of these types of materials may be cost- effective
from a life- cycle standpoint. Service officials stated that while a shingle
roof might cost less than a slate roof initially, if life- cycle costs are
considered the cost may be the same, although the impact on an
installation's budget may be greatest in the year in which the costs are
incurred. Service officials stated that they know they must replace existing
slate or tile roofs on historic properties with the same material, so they
do not consider using any other material. As a result, they do not compare
the cost of replacing a slate roof with a shingle roof.

12 Report to Congress on Historic Army Quarters, Mar. 1997. 13 Fiscal year
1996 Army- wide family housing cost data from the Army's real property
database. 14 Department of Navy's Response to Congress on Historic
Preservation, Apr. 1997. 15 The Cost of Maintaining Historic Military Family
Housing, Sept. 2000.

13 GAO- 01- 497T Defense Infrastructure

Mr. Chairman, this completes my prepared statement. I would be happy to
respond to any questions you or other Members of the Subcommittee may have
at this time.

Contact and Acknowledgement

For future questions regarding this testimony, please contact. Barry Holman
(202) 512- 5581 Michael Kennedy (202) 512- 8333

Other individuals making key contributions to this testimony included
William Crocker and Richard Meeks.

(350053)
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