Issues on the National Oceanographic and Atmospheric Administration's (NOAA) Commissioned Corps

Published by the Government Accountability Office on 1997-12-02.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

      United States
      General Accounting Office
      Washington, D.C. 20548

      General Government Division
        . .                                                     ._ _

      December 2, 1997

      The Honorable John McCain
      Chairman, Committee on Commerce,
        Science, and Transportation
      United States Senate

      The Honorable Olympia J. Snowe
      Chairwoman, Subcommittee on Oceans
         and Fisheries
      Committee on Commerce, Science,
         and Transportation
      United States Senate

      Subject: Issues on the National Oceanographic and Atmospheric
               Administration’s (NOAA) Commissioned Corns

      On October 29, 1997, we testified before the Subcommittee on Oceans and
      Fisheries, Senate Committee on Commerce, Science, and Transportation, on
      issues pertaining to NOAA’s Commissioned Corps. The Commissioned Corps is
      a uniformed service whose officers are covered by a military-Iike compensation
      system. NOAA Corps officers carry out a variety of navigational and scientific
      functions, such as charting and oceanographic research. On October 31, 1996,
      we issued a report? to Congressmen Lamar Smith and John R. Kasich on the
      results of our limited review of (1) issues concerning the NOAA Corps as a
      uniformed service with mihtary-like pay, allowances, and benefits and (2) what
      would be the comparative cost of using civilian employees, rather than
      uniformed officers, to carry out the NOAA Corps’ functions.

      Following the October 1997 hearing, you asked us for further information
      regarding the NOAA Corps and NOAA’s plans to civilianize its officers, This
      letter responds to your questions. It should be noted that since we completed
      our audit work on the NOAA Corps assignment in 1996, we have done no
      further work involving the NOAA Corps. Your questions and our responses

      ‘Federal Personnel: Issues on the Need for NOAA’s Commissioned Cores
      (GAO/GGD-97-10, Oct. 31, 1996).
                                                GAO/GGD-9%35R      Issues   on the NOAA   Corps


Question 1. The GAO noted in its report in 1996 that the Department       of Defense
(DOD) war mobilization   plans did not call for usage of the NOAA Corps and fleet.
Do you know if any updated DOD war mobilization      plans envision a role for the
NOAA Corps? Do you know if DOD war mobilization         plans prior to World Wars I
or II had envisioned usage of the Coast and Geodetic Survey vessels and

GAO Resnonse: Because we did no further work after our 1996 report, Federal
Personnel: Issues on the Need for NOAA’s Commissioned Corns (GAO/GGD-97-10, Oct.
31, 1996) was issued, we do not know whether any updated DOD mobilization plans
envision a role for the NOAA Corps. We can say, however, that when we did our original
work the answer to the question whether any future plan updates would envisage a role
for the Corps was “no.” DOD officials characterized the probability of the NOAA Corps
being called upon in the event of an emergency as only “hardly or slightly” possible. One
official said that in the event of “total war,” the NOAA Corps would be used, as would all
of us then in the room.

When we did our work, we did not discuss whether DOD had war mobilization plans
prior to World Wars I or II. We did find, however, that the Corps’ participation in World
War I did not occur without congressional action. In 1917, it was necessary for Congress
to pass a law, temporarily authorizing the emergency transfer of ships and men from the
Coast and Geodetic Survey to the Navy and War Departments. The transfer to the
military during World War II did not involve the entire Commissioned Corps. We found
that 94, or about 55 percent, of the Coast and Geodetic Survey officers were transferred
to the military.

Question 2. If the Corps were called up during a war mobilization         effort, would
the presence of a uniformed Corps make the transfer significantly         more efficient
than would otherwise be the case if the operation were completely         run by

GAO Resnonse: As we responded to question 1, it is highly unlikely that the NOAA Corps
would be called upon during a war. However, if that were to occur, it is worth noting
that civilians have been used in wartime to carry out military duties. For example, when
doing the work that led to our October 1996 report, we found that the Navy used civilian
hydrographers for Navy missions. DOD officials said that these hydrographers can be
sent into combat and that civilian hydrographers were sent to the Persian Gulf and to
Vietnam during wartime. Four were on the U.S.S. Pueblo when it was captured and were
held in captivity along with the rest of the crew.

 2                                                    GAO/GGD-9%35R   Issues on the NOAA   Corps
Question 3. Have you had an opportunity   to look at the Hay/Huggins cost analysis
done for NOAA? What are your thoughts on this analysis? Do you consider it
sound? Do you have any disagreements    or find any weaknesses with it?

GAO Response: The analysis was a methodologically sound comparison of the costs of
the NOAA Corps retirement benefits and the Federal Employees’ Retirement System
(FERS) benefits that would apply under civilianization. The full cost of a retirement
system is best expressed as the present value of the future benefits provided to the
current active and retired members of the system. This cost is paid for from current
assets, the present value of future member contributions, the present value of future
employer normal cost contributions, and the amortization of the plan’s remaining
unfunded liabilities. As would be expected, Hay/Huggins used this approach to prepare a
present value analysis of retirement. costs under two scenarios: (1) a scenario that
continued NOAA Corps at its Corps strength as of December 31, 1996, and (2) a scenario
that terminated the NOAA Corps with retirement rights as specified by the NOAA Corps
transition plan at the same staff strength.

Not only was the approach that Haymuggins used the most appropriate approach for
assessing retirement system costs, the analysis used the same assumptions, information
and methodologies that are currently used to measure these costs in the NOAA Corps and
FERS programs. The retirement cost information that Hay/Huggins used came from the
most recent reports that NOAA and OPM had prepared at that time to meet actuarial
reporting requirements under P.L. 95595. As such, it was the best information that
Hay/Huggins could have used. Hay/Huggins also used a Thrift Savings Plan (TSP)
contribution cost estimate that refiected the prevailing rate of agency TSP contributions,
which helped to ensure that FERS costs would not be understated. Regarding the
calculation and amortization of unfunded liabilities, the analysis: (1) included the present
value of the NOAA Corps program’s unfunded liability as reported for the NOAA Corps
retirement system, projected forward to September 30, 1997, net of the cost of future
benefits for Officers with less than 15 years of service who would not be vested at the
time the plan was terminated; (2) applied the economic and demographic assumptions of
the FERS Board of Actuaries to estimate the liabilities and present value of contributions
to FERS for the NOAA Corps officers; and (3) counted the unfunded liability that would
be created because Officer contributions to purchase equivalent years of military service
under FERS would not fully offset the costs of these FERS benefits. Incorporating these
factors into the amortization cost estimates helped to ensure that the NOAA Corps
retirement system unfunded liabilities and associated amortization costs would not be
overstated and those of FERS would not be understated.

3                                                    GAOIGGD-9%35R   Issues on the NOAA   Corps
Question 4. How does the NOAA Corps disestablishment       plan compare to the
transition plans accompanying downsizing efforts iu other departments     of the
federal government ? Is it reasonable by any standard?   Is it more or less
generous to employees than other such plans?

GAO Resnonse: The plans of other federal agencies are not comparable with the
Department of Commerce’s plan for the NOAA Corps. Among the nine agency
streamlining plans we examined in our recent work, representing most of the federal
downsizing to date, none transferred employees from one personnel system to another.
The Department of Commerce’s plan contemplates NOAA Corps officers’ current mtitary-
like personnel system being eliminated and Corps officers becoming federal civilian
employees, who would be placed in FERS. Since we are aware of no other plans upon
which to base a comparison, we have no basis to gauge the comparative reasonableness
of the NOAA Corps disestablishment plan.

Question 5. Do you believe that NOAA could have a difficult            time fiudiug
qualified and interested civilian replacements for the NOAA           Corps officers?    If
not, why not?

GAO Resnonse: Civilians already carry out similar work for other military services and
federal agencies. When we gathered information for our October 1996 report, 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. As we said in that report, although we found that some
Corps assignments were of this nature, civilian employees in other agencies were often
assigned to duties similar to those of the Corps. For example, the Environmental
Protection Agency and the Navy used ships operated by civilian employees or contractors
in conducting their oceanic research. One retired Navy official said NOAA has only
noncombatant ships that by agency choice are commanded by officers, while the Navy’s
noncombatant ships contain no officers. He said that all contracted crews are holders of
Master Mariner’s and Chief licenses, and that the Navy considers these individuals to be
 officers. He also said that the Navy can send its civilian contractors’ crews into “harm’s
 way.” The Navy’s hydrography ships mapped amphibious land areas in the Gulf War, and
 Navy oilers, which also function in combat situations, have civilian crews.

Further, as we also said in our report, the National Transportation Safety Board and the
Federal Emergency Management Agency used civilian employees to respond quickly to
disasters and other emergency situations. These employees were deployed to any
location with little notice and often under hazardous or harsh conditions.

 4                                                    GAO/GGD-9%35R     Issues on the NOAA    Corps
Question 6. The GAO’s report indicated that the Navy uses civilians to operate             its
research vess.els. Is this true for all vessels? Are there any substantive
differences-between   the Navy’s research operations and those of the NOAA

GAO Resnonse: During our work reviewing the activities of the NOAA Corps, we found
that the Office of Naval Research managed research with a military goal, primarily using
civilian-operated commercial vessels or ships operated by universities. NOAA’s research
was found to be nonmilitary and was primarily carried out using NOAA ships.

As agreed with your office, we will make copies of this correspondence available to
others upon request. Please contact me at (202) 512-8676if you or your staff have any

L. Nye Stevens
Director, Federal Management
   and Workforce Issues


5                                                   GAO/GGD-9%35R   Issues on the NOAA   Corps
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