Federal Personnel: Issues on the Need for NOAA's Commissioned Corps
(Letter Report, 10/31/96, GAO/GGD-97-10).

Pursuant to a congressional request, GAO reviewed the operations of the
National Oceanic and Atmospheric Administration's (NOAA) Commissioned
Corps, focusing on: (1) whether there continues to be a need for a
commissioned corps with military-like pay, allowances, and benefits; and
(2) what the costs would be if federal civilian employees performed the
Corps' functions.

GAO found that: (1) the NOAA Corps carries out civilian, rather than
military, functions; (2) Corps officers operate and manage NOAA research
and survey ships that collect the data needed to support fishery
management plans, oceanographic and climate research, and hydrographic
surveys; (3) Corps officers' entitlement to military ranks and
military-like compensation was an outgrowth of their temporary
assignments to the armed forces during World Wars I and II; (4) the
Department of Defense's war mobilization plans envision no role for the
Corps in the future; (5) Corps officers are not subject to the Uniform
Code of Military Justice; (6) the government would realize estimated net
savings of $661,000 by converting the Corps to civilian status; and (7)
a general downsizing in the Department of Commerce reduced the number of
Corps officers to 332 as of July 1996, with a goal of 285 officers by
2000.

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

 REPORTNUM:  GGD-97-10
     TITLE:  Federal Personnel: Issues on the Need for NOAA's 
             Commissioned Corps
      DATE:  10/31/96
   SUBJECT:  Mobilization
             Officer personnel
             Civilian employees
             Atmospheric research
             Federal agency reorganization
             Oceanographic research
             Defense contingency planning
             Reductions in force
             Military compensation
             Fringe benefits
IDENTIFIER:  World War II
             
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Cover
================================================================ COVER


Report to Congressional Requesters

October 1996

FEDERAL PERSONNEL - ISSUES ON THE
NEED FOR NOAA'S COMMISSIONED CORPS

GAO/GGD-97-10

NOAA Commissioned Corps

(410005)


Abbreviations
=============================================================== ABBREV

  DOD - Department of Defense
  ESSA - Environmental Science Services Administration
  EPA - Environmental Protection Agency
  NOAA - National Oceanic and Atmospheric Administration
  PHS - Public Health Service

Letter
=============================================================== LETTER


B-270666

October 31, 1996

The Honorable Lamar Smith
House of Representatives

The Honorable John R.  Kasich
House of Representatives

This report responds to your request that we review the operations of
the National Oceanic and Atmospheric Administration's (NOAA)
Commissioned Corps.  NOAA's Commissioned Corps is a uniformed service
whose officers are covered by a military-like compensation system in
a manner similar to the Commissioned Corps of the Public Health
Service (PHS).  NOAA Corps officers carry out a variety of
navigational and scientific functions, such as charting and
oceanographic research. 

You asked us to provide information on (1) issues surrounding whether
there is a continuing need for the NOAA and PHS Corps as uniformed
services with military-like pay, allowances, and benefits and (2)
what the costs would be if federal civilian employees carried out the
Corps' functions.  In a May 7, 1996, report,\1 we presented the
results of our review of the PHS Corps.  This report presents the
results of our review of the NOAA Corps.  Like the report on the PHS
Corps, this report provides answers to questions your designated
representative agreed would provide the information you were seeking. 
In general, the questions addressed why the NOAA Corps exists; what
the Corps officers' duties are; how the Corps is similar to and
different from the military; and what savings, if any, might result
from not using uniformed personnel to carry out current Corps
functions.  Our review did not examine whether the Corps' functions
or the number of persons used to accomplish those functions were
necessary or could be changed as the result of civilianization. 

In developing the information for this report, we interviewed---and
analyzed documents provided by--officials of NOAA, the NOAA
Commissioned Corps, the Department of Defense (DOD), the Office of
the Navy Oceanographer, the Office of Naval Research, the National
Science Foundation, and other organizations that could provide
insights into the Corps' functions, responsibilities, and costs. 
Appendix I describes in detail the objective, scope, and methodology
of our review, which was done in accordance with generally accepted
government auditing standards.  We requested comments on a draft of
this report from the Departments of Commerce and Defense.  The
Department of Commerce provided written comments.  Its letter is
discussed at the end of this report and reprinted in appendix II. 
The Department of Defense had no comments on the report. 


--------------------
\1 Federal Personnel:  Issues on the Need for the Public Health
Service's Commissioned Corps (GAO/GGD-96-55). 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Like the PHS Corps, the NOAA Corps carries out civilian, rather than
military, functions.  In contrast to the PHS Corps, NOAA Corps
officers who serve at sea have few civilian employee counterparts in
NOAA.  However, other agencies use federal civilian employees or
contractors to carry out duties similar to the functions NOAA assigns
to the Corps. 

NOAA Corps officers operate and manage NOAA's research and survey
ships that collect the data needed to support fishery management
plans, oceanographic and climate research, and hydrographic surveys. 
NOAA Corps officers also fly and manage NOAA's aircraft that are used
to penetrate hurricanes for research and to carry out surveys for
forecasting floods and mapping changing U.S.  shorelines.  Corps
officials said officers can expect to serve one-third of their
careers in each of the following work categories:  (1) sea duty; (2)
shore duty that involves responsibilities in marine centers, vessel
support, geodetic surveys, or aircraft operations; and (3) shore duty
that involves management and technical support in offices throughout
NOAA. 

NOAA Corps officers' entitlement to military ranks and military-like
compensation, including retirement eligibility at any age after
completing 20 years of service, was an outgrowth of their temporary
assignments to the armed forces during World Wars I and II.  The
Corps has not been incorporated into the armed forces since World War
II, and DOD's war mobilization plans envision no role for the Corps
in the future.  Generally, the Corps does not meet the criteria and
principles cited in a DOD report as justification for the military
compensation system.  Corps officers are not subject to the Uniform
Code of Military Justice that governs how military personnel are
managed. 

Actions are in process that could significantly change the Corps.  A
general downsizing in the Department of Commerce reduced the Corps
from about 400 officers in October 1994 to 332 officers as of July 1,
1996, with an eventual goal of a complement of 285 by the year 2000. 
Further, in January 1996, NOAA's Administrator asked Corps management
to develop a plan for civilianizing the Corps by the spring of 1997. 
At the time we prepared this report, the plan was being reviewed by
the Secretary of Commerce, who has overall responsibility for NOAA. 

Our estimates suggest that using civilian employees to carry out the
Corps' current functions would result in limited savings.  A
comparative cost analysis showed that it would have cost an estimated
$573,000 more in personnel costs to employ civilian workers during
the period July 1, 1994, through June 30, 1995, than the personnel
costs paid to Corps officers.  However, when the estimated federal
income tax benefits of $1,234,000 afforded to Corps officers from
their nontaxable allowances are considered, the government would
realize net savings of an estimated $661,000 by employing civilian
employees.  If the Corps were to be converted to civilian employment,
the actual net cost reduction could vary, depending on various
factors, including the method by which the conversion was
implemented, the applicability of 1994 through 1995 costs to future
years, and the accuracy of the underlying assumptions about Corps and
civilian personnel costs. 

It must also be recognized that, because the Corps is now smaller
than it was in the period in which we did our work and further
reductions are anticipated, any savings available from civilianizing
the Corps in the future would be reduced accordingly. 


   NOAA CORPS HISTORY AND CURRENT
   STATUS
------------------------------------------------------------ Letter :2

The organization that became NOAA was established in 1807, and in
1836 it officially became known as the Coast Survey.  The Survey
dispatched technical and scientific teams to survey the uncharted
U.S.  coastline and relied on the Army and the Navy to supply
personnel to augment the organization's civilian employees.  After
the Civil War, the Army withdrew from the Survey's work; the Navy
withdrew during the Spanish-American War, leaving the work to be done
solely by the employees of the newly named Coast and Geodetic Survey. 
After the Army and the Navy withdrew their personnel, many of the
Coast and Geodetic Survey's civilian employees working in the field
continued (1) maintaining a military-like operation with distinct
lines of authority, (2) wearing Navy uniforms, and (3) giving and
taking orders. 

At the outbreak of World War I, ships and men who were qualified to
operate the ships were needed immediately to augment the military
forces.  The Coast and Geodetic Survey was the only federal civilian
agency that could respond to these requirements.  Accordingly, in
1917, Congress passed legislation authorizing the President to
transfer the Survey's ships and men to the Navy and War Departments
for the duration of the war and officially giving military rank to
Coast and Geodetic Survey field officers when serving in the Army or
Navy.  The Joint Service Pay Act of 1920 extended the Navy's pay,
allowances, and retirement system to the members of the Coast and
Geodetic Survey who held ranks equivalent to Navy officers. 

In World War II, about half of the commissioned officers and ships of
the Coast and Geodetic Survey were temporarily transferred to the
armed services.  Officers' duties included training amphibious troops
in seamanship and navigation, serving as battalion observation
officers, and executing hydrographic surveys in advance of fleet
operations in the Aleutian Islands and the Western Pacific.  At the
end of the war, all Survey ships and officers were returned to the
Coast and Geodetic Survey and to civilian duties.  However, the Corps
continued to exist, and its officers retained their military ranks
and compensation. 

In 1965, the Coast and Geodetic Survey became the Environmental
Science Services Administration (ESSA), and in 1970, ESSA became
NOAA.  NOAA is composed of five line offices--(1) the National Marine
Fisheries Service; (2) the Office of Oceanic and Atmospheric
Research; (3) the National Weather Service; (4) the National Ocean
Service; and (5) the National Environmental Satellite, Data, and
Information Service--and the Office of the Administrator.  Corps
officers are assigned to work in all component offices of NOAA. 
Table 1 provides Corps officers' assignments to NOAA's component
offices in April 1995. 



                                Table 1
                
                     NOAA Corps Assignments in NOAA
                         Components, April 1995

                                                           Total Corps
NOAA Component Office                                         Officers
--------------------------------------------------  ------------------
National Marine Fisheries Service                                   35
Office of Oceanic and Atmospheric Research                          31
National Weather Service                                            10

National Ocean Service
----------------------------------------------------------------------
charting                                                            45
noncharting                                                         36
National Environmental Satellite, Data,                             12
 and Information Service
Office of the Administrator\a                                      227
======================================================================
Total                                                              396
----------------------------------------------------------------------
\a Includes NOAA Corps Operations, the Pacific and Atlantic Marine
Centers, Corps Personnel Center, aircraft pilots, and ships'
officers. 

Source:  Office of NOAA Corps Operations. 

Corps officials said officers can expect to serve one-third of their
careers in each of the following work categories:  (1) sea duty; (2)
shore duty that involves responsibilities in marine centers, vessel
support, geodetic surveys, or aircraft operations; and (3) shore duty
that involves management and technical support throughout NOAA. 

In October 1994, the Corps had approximately 400 commissioned
officers.  As a result of general downsizing in the Department of
Commerce, the Corps was reduced to 332 officers as of July 1, 1996. 
According to a Corps official, the ultimate downsizing goal was to
reduce the number of officers to 285 by the year 2000. 

NOAA has since expressed an interest in eliminating the Corps and
using civilian employees to carry out the Corps' functions.  In
January 1996, NOAA's Administrator announced that the NOAA Corps
would begin a transition to civilian status on October 1, 1996, and
directed that the transition be completed within 6 months.  He asked
the Director of NOAA Corps operations to develop an implementation
plan for civilianizing the Corps.  NOAA officials said that plan was
being reviewed by the Secretary of Commerce. 


   NOAA CORPS' SIMILARITY TO AND
   DIFFERENCES FROM THE MILITARY
------------------------------------------------------------ Letter :3

Corps members' entitlement to military ranks and military-like
compensation, including eligibility for retirement at any age after
20 years of service, was an outgrowth of their temporary service with
the armed forces during World Wars I and II.  The NOAA Corps has not
been incorporated into the armed forces since World War II, and DOD's
war mobilization plans envision no role for the Corps in the future. 
Corps officers continue to receive virtually the same pay and
benefits (including retirement) as the military. 

A 1984 DOD report\2 provided a detailed discussion of the criteria
and principles used to justify the military compensation system. 
According to the report, the main purpose of the military
compensation system is to ensure the readiness and sustainability of
the armed forces.  Military personnel can be assigned at any time to
any locations the services see fit, regardless of members' personal
preferences or risks.  In other words, the military compensation
system is based on the premise that individual aspirations and
preferences are subordinated to the good of the service.  The NOAA
Corps is not considered an armed service, and Corps officers are not
subject to the Uniform Code of Military Justice, which underlies how
military personnel are managed.\3 Accordingly, NOAA cannot press
criminal charges or pass sentence against an officer who disobeys
orders, and Corps officers can quit the Corps without legal
sanctions. 

Corps officials said the essential functions of the uniformed Corps
are to serve as deck officers aboard NOAA ships and to be a mobile
cadre of professionals who can be assigned with little notice to any
location and function where their services are necessary, often in
hazardous or harsh conditions.  We found that some Corps assignments
are of this nature, but civilian employees in other agencies are
often assigned to duties similar to those of the Corps.  For example,
the Environmental Protection Agency (EPA), the National
Transportation Safety Board, and the Federal Emergency Management
Agency use civilian employees to respond quickly to disasters and
other emergency situations.  Moreover, EPA and the Navy use ships
operated by civilian employees or contractors in conducting their
oceanic research.  Officials from these agencies said they have
experienced no problems in using civilian deck officers on the
vessels.  Also, NOAA ships have been operated on occasion by Wage
Marine (civilian)\4 deck officers, and NOAA officials termed this
approach successful. 


--------------------
\2 The Fifth Quadrennial Review of Military Compensation, Department
of Defense, January 1984. 

\3 Under a 1917 statute, the President can incorporate the Corps into
the military service in the event of national emergency.  Since all
military personnel are subject to the Uniform Code of Military
Justice, Corps officers, after being incorporated into the military,
would be subject to the code.  This situation has not occurred since
World War II. 

\4 A Wage Marine is a type of prevailing-rate excepted service
employee who serves as a master or mate on NOAA ships. 


   POTENTIAL COST REDUCTION
   RESULTING FROM CIVILIANIZING
   THE NOAA CORPS
------------------------------------------------------------ Letter :4

NOAA contracted with Arthur Andersen LLP to determine the comparative
costs of using civilian employees rather than Corps officers to carry
out the Corps' functions.  The contractor's report\5 was issued
August 30, 1995.  We examined the contractor's approach and
methodology and generally found them to be similar to those we would
have used.  Thus, other than making an adjustment we believed was
necessary for a more complete comparison, we accepted the
contractor's estimates of the comparative costs of using Corps
officers and civilian employees.  On the basis of the contractor's
report and the adjustment we made, we estimated that the cost to the
government would have been about $661,000 lower during the year July
1994 through June 1995, if civilian employees had been used.\6 If the
Corps is downsized as intended, the estimated cost savings would be
smaller in subsequent years. 


--------------------
\5 National Oceanic and Atmospheric Administration Commissioned
Officer Corps:  Comparison of NOAA Corps versus Federal Employees,
Arthur Andersen LLP, August 30, 1995. 

\6 The actual net cost reduction would vary, depending on various
factors, including the method by which any changes are implemented,
the applicability of 1994 costs to future years, and the accuracy of
the underlying assumptions concerning Corps and civilian personnel
costs. 


      ARTHUR ANDERSEN LLP COST
      COMPARISON STUDY
---------------------------------------------------------- Letter :4.1

The Arthur Andersen LLP report concluded that civilianization of the
Corps would increase government costs by $573,000 a year.  This
estimate was based on actual costs incurred during the year ending
June 30, 1995, and used a Corps strength of 384 officers.  Table 2
shows the Arthur Andersen LLP estimates. 



                                Table 2
                
                Arthur Andersen LLP Comparison of Corps
                      and Civilian Personnel Costs

                                                Federal
                              NOAA Corps       civilian
Category                        Officers      employees     Difference
-------------------------  -------------  -------------  -------------
Base pay/salaries            $15,795,000    $20,869,000   $(5,074,000)
Special pays, allowances,      5,486,000      3,710,000      1,776,000
 and bonuses
Benefits                       8,427,000      5,702,000      2,725,000
======================================================================
Total                        $29,708,000    $30,281,000     $(573,000)
----------------------------------------------------------------------
Source:  Arthur Andersen LLP report. 


      OUR ADJUSTMENT TO THE
      CONTRACTOR'S ESTIMATES
---------------------------------------------------------- Letter :4.2

Arthur Andersen LLP did not include in its comparison the federal
income tax advantage Corps officers receive from their housing and
subsistence allowances.  Like members of the military, NOAA Corps
officers pay no federal income taxes on these allowances.\7 As DOD
explained, the "cost" to the government arising from this tax
advantage comes in the form of a loss to the U.S.  Treasury of the
federal income taxes that would otherwise have been paid if the
allowances were taxable.\8 Federal civilian employees receive no such
tax advantages; they must pay their living expenses from their fully
taxable salaries. 

A DOD publication\9 pointed out that the actual federal tax benefit
that an individual member realizes is governed by many
considerations.  These considerations include (1) the aggregate
amount of a member's (and his or her spouse's) income, both earned
and unearned; (2) the amount of the member's housing and subsistence
allowances; (3) the member's marital status and number of dependents;
(4) whether the member takes the standard deduction or itemizes
deductions for federal income tax purposes; and (5) whether the
member is entitled to other types of tax exclusions.  DOD developed a
series of numerical estimates of the tax advantages to members using
certain assumptions related to these factors.  The publication noted
that members do not actually receive the tax advantage in cash or in
kind.  Accordingly, it is not a cost item in DOD's budget, nor is it
in NOAA's budget. 

According to its report, Arthur Andersen LLP did not include Corps
members' tax advantage as a cost of maintaining the Corps because it
did not represent "costs incurred by the Federal Government."
However, because the tax advantage represents a revenue loss to the
government and is of considerable monetary value to Corps members, we
believe it should be included in any cost comparison. 

Since NOAA Corps officers receive the same base pay and housing and
subsistence allowances as military officers at the same ranks, we
used DOD's tax advantage estimates to estimate the tax advantage
afforded to Corps members.  We estimated that the annual tax
advantage associated with the housing and subsistence allowance
amounts used in the Arthur Andersen LLP study would be $1,234,000 a
year.  Adjusting the Arthur Andersen LLP study results by the
estimated tax advantage amount results in a total government cost for
the Corps of $30,942,000 for the year, compared with the estimated
$30,281,000 cost of using civilian employees--a difference of
$661,000. 

If a decision were made to civilianize the NOAA Corps, whether there
would be any actual cost reductions would depend, in large part, on
the manner in which a transition to civilian employment would be
carried out, including the period of time over which the transition
would occur.  Any decision to replace Corps officers with civilian
employees could be implemented in a number of ways.  The
possibilities range from requiring all officers to immediately
convert to civilian employment, to longer-range measures such as
allowing all current officers to remain in place until retirement or
other separation and requiring all new entrants to be civilian
employees.  Or, perhaps all officers with a specific number of years
in the Corps could be allowed to continue in the Corps until
retirement or other separation. 

The amount of transition costs would also depend on how
considerations such as the following were resolved. 

(1) What retirement benefits or credits are given to officers for the
time they spend in the Corps before converting to civilian employment
and the civilian employee retirement system. 

(2) What resources would be required to recruit, train, and retain
civilian employees that might be needed to replace Corps officers who
opt to leave federal service. 

(3) The amount of additional resources, if any, that would be
required to administer the civilian workforce at NOAA after
civilianizing the Corps and its administrative personnel. 

A plan of action that addresses each of the above factors and other
possible considerations would be needed before estimates of the
transition costs involved could be determined. 


--------------------
\7 A major component of military and Corps compensation is termed
"Regular Military Compensation." This component includes basic pay,
nontaxable housing and subsistence allowances, and the tax advantage
accorded to members through the nontaxable allowances. 

\8 As actually calculated by DOD, the tax advantage is the amount of
additional income military (or Corps) personnel would need to retain
their take-home pay if their allowances were taxable. 

\9 Military Compensation Background Papers:  Compensation Elements
and Related Manpower Cost Items, Office of the Secretary of Defense,
Department of Defense, November 1991. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

The Department of Commerce provided written comments on a draft of
this report.  The comments and our responses are discussed below. 
The Department's comments are provided in their entirety in appendix
II. 

Although the Department expressed concerns about certain information
in the report, it acknowledged that a legislative proposal (prepared
by the Department) to "disestablish" the Corps was pending clearance
within the administration. 

The Department questioned the appropriateness of our applying DOD's
criteria for military compensation to the NOAA Corps.  It said the
criteria focused exclusively on the military services, rather than on
uniformed services in general.  In our opinion, the criteria we used
were appropriate.  The Corps' compensation system, generally the same
as the military compensation system, was legislatively established
after some Corps officers were temporarily assigned to the military
during World War I.  Thus, in evaluating whether the Corps should
continue to receive military-like compensation, we believe the
application of the criteria DOD used to justify the military
compensation system is reasonable. 

The Department noted that its goal for downsizing the Corps (if the
proposal to "disestablish" the Corps is not accepted) is to have a
Corps strength of 285 officers by the year 2000, rather than 280 as
stated in the draft report.  We changed the report to reflect this
updated estimate. 

According to the Department, the report's discussion of the history
of the Corps and how Corps officers came to receive ranks and
compensation similar to the military should have included more
detailed information.  We included additional historical information
consistent with the Department's suggestions. 

Similarly, the Department suggested that, to be more complete, the
report should acknowledge that Corps officers are subject to the
Uniform Code of Military Justice when serving with or assigned to the
armed forces.  We agree that this is the case.  However, the report
section cited by the Department already pointed out this exception to
the general rule in a footnote.  Accordingly, we did not believe a
change was needed to address this comment. 

The Department expressed an opinion that the report did not
sufficiently address the ways in which service with the Corps is
similar to military service.  We disagree.  The report discussed
areas of similarity between Corps and military service mentioned by
Corps officials during our review, but it also pointed out that
civilian employees in other agencies were often subject to the same
conditions of employment.  Moreover, many of the similarities
discussed in the Department's comments exist because the Corps is
compensated under a military-like system, not because the Corps has
responsibilities like the military.  It should also be noted that the
criteria for military compensation articulated in the DOD report are
based on the need for inducements and incentives to maintain a force
necessary "to insure successful accomplishment of the United States
national security objectives." Corps officers have not been involved
in meeting national security objectives since World War II. 

We also provided a draft of the report to DOD.  We were advised that,
after reviewing the draft, DOD had no comments. 


---------------------------------------------------------- Letter :5.1

As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 7 days
from the date of this report.  At that time, we will send copies to
the Secretaries of Commerce and Defense and other interested parties. 
We will also make copies available to others upon request. 

If you have questions concerning this report, please telephone me or
Associate Director, Timothy P.  Bowling, at (202) 512-8676.  Major
contributors to this report are listed in appendix III. 

L.  Nye Stevens
Director, Federal Management
 and Workforce Issues


OBJECTIVE, SCOPE, AND METHODOLOGY
=========================================================== Appendix I

The objective of this report is to provide information on the
operations of the National Oceanic and Atmospheric Administration
(NOAA) Commissioned Corps.  We were asked to address why the NOAA
Corps exists; what the Corps officers' duties are; how the Corps is
similar to and different from the military; and what savings, if any,
might result from not using uniformed personnel to carry out current
Corps functions. 

To gather the information on the continuing need for the Corps, we
reviewed NOAA Corps historical material and interviewed and obtained
documentation from officials of NOAA, including the Office of NOAA
Corps Operations; the Department of Defense (DOD), including the
Department of the Army and the Navy; Woods Hole Oceanographic
Institute; the National Science Foundation; the National
Transportation Safety Board; the Federal Emergency Management Agency;
and the Environmental Protection Agency. 

To compare the costs of using uniformed personnel or civilian
employees to carry out Corps duties, we reviewed the findings in an
August 1995 report\1 prepared by Arthur Andersen LLP under a contract
with NOAA.  We examined the contractor's approach and methodology and
generally found them to be similar to those we would have used. 
Other than making an adjustment we believed was appropriate to
reflect the estimated tax advantages Corps officers receive through
their nontaxable housing and subsistence allowances, we accepted the
contractor's findings as valid estimates of the comparative costs of
using Corps officers and civilian employees. 

It should be noted that we did not examine whether the Corps'
functions or the number of persons used to accomplish those functions
were necessary or could be changed as the result of civilianization. 
Thus, the report does not address issues such as whether
civilianization of the Corps could present opportunities for possible
savings through restructuring or consolidating NOAA operations. 
Neither did we examine the possibility of contracting with private
companies, rather than using civilian employees, to carry out the
Corps' current functions. 

We did our work in Washington, D.C.; Narragansett, Rhode Island; and
Woods Hole, Massachusetts, between November 1994 and January 1996. 
Our work was done in accordance with generally accepted government
auditing standards. 

The Department of Commerce provided written comments on a draft of
this report.  A copy of the letter is included as appendix II.  The
Department of Defense also reviewed a draft of the report and had no
comments. 



(See figure in printed edition.)Appendix II

--------------------
\1 National Oceanic and Atmospheric Administration Commissioned
Officers Corps:  Comparison of NOAA Corps versus Federal Employees,
August 30, 1995. 


COMMENTS FROM THE DEPARTMENT OF
COMMERCE
=========================================================== Appendix I



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III

GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C. 

Robert E.  Shelton, Assistant Director, Federal Management and
Workforce
 Issues
Nancy A.  Patterson, Assignment Manager
Philip Kagan, Technical Advisor
Steven J.  Berke, Evaluator-in-Charge
Marlene M.  Zacharias, Evaluator Assistant

*** End of document. ***