Defense Infrastructure
Fire Protection at Philadelphia Naval Business Center Meets Response Standards Gao ID: GAO-03-20 October 29, 2002When the Department of Defense closed military installations as a part of the base realignment and closure process and transferred properties to public and private ownership, it in some cases retained a portion of an installation as a military enclave. During this process, legal jurisdiction over an enclave may be transferred from the federal government to the local government. Such a transfer may incorporate provisions for fire protection and other services by local and state governments. A federal fire-fighting service provides fire protection services at the Navy's enclave located at the Philadelphia Naval Business Center. This is one of the three military enclaves, formed during the base closure and realignment process, which is still protected by federal firefighters. Twenty-four other military enclaves were converted from federal to local fire protection during the base closure process. The Navy retained a federal fire-fighting force at its enclave at the Philadelphia Naval Business Center because of Commonwealth of Pennsylvania did not respond to the Navy's request to change the jurisdiction of the Navy-retained land. The level of fire protection at the Philadelphia Naval Business Center is similar to that available elsewhere in the City of Philadelphia, but the arrangements for providing that protection differ. If a fire occurs on non-Navy property within the business center, both the Navy and the Philadelphia fire departments will automatically respond to the call, with the Navy as the first responder. However, if the fire is located on Navy-owned property at the business center, only Navy firefighters will automatically respond to the alarm. As private development at the Philadelphia Naval Business Center continues, the fire protection arrangements are expected to be reassessed. The Commissioner of the Philadelphia Fire Department stated that, as development at the business center continues to increase, his office will need to reevaluate the location of city-owned fire stations in the area around the business center.
GAO-03-20, Defense Infrastructure: Fire Protection at Philadelphia Naval Business Center Meets Response Standards
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Report to Congressional Requesters:
United States General Accounting Office:
GAO:
October 2002:
Defense Infrastructure:
Fire Protection at Philadelphia Naval Business Center Meets Response
Standards:
Military Bases:
GAO-03-20:
Contents:
Letter:
Results in Brief:
Background:
Most Enclaves Rely on Local Rather Than Federal Fire Protection:
Fire Protection at the Business Center Is Similar to That Provided
Elsewhere in Philadelphia:
Future Development Could Affect Existing Arrangement for Fire
Protection:
Conclusions:
Agency Comments:
Scope and Methodology:
Appendix I: Federal Enclave at the Philadelphia Naval Business Center:
Appendix II: Mutual Aid Agreement between the Navy and the
City of Philadelphia:
Appendix III: Comments from the Department of Defense:
Tables:
Table 1: Fire Protection Services at Federal Enclaves Created at Closed
Installations:
Table 2: Navy Fire, EMS, and Other Calls and Mutual Aid Responses by
the Navy and the City of Philadelphia, 2000 to 2002 (as of September 4,
2002):
Figures:
Figure 1: Map of the Enclave at the Philadelphia Naval Business Center:
Figure 2: Aerial Photograph of the Philadelphia Naval Business Center:
Letter:
October 29, 2002:
The Honorable Solomon P. Ortiz
Ranking Minority Member
Subcommittee on Military Readiness
Committee on Armed Services
House of Representatives:
The Honorable Robert A. Brady
House of Representatives:
When the Department of Defense closed military installations as part of
the base realignment and closure process and transferred properties to
public and private ownership, it in some cases retained a portion of an
installation as a military enclave. During this process, legal
jurisdiction over an enclave may be transferred from the federal
government to the local government. Such a transfer may incorporate
provisions for fire protection and other services by local and state
governments. Because of your concerns about the adequacy of fire
protection at the federal enclave located on the former Naval Shipyard
and Naval Station in Philadelphia, Pennsylvania, now called the
Philadelphia Naval Business Center, we conducted this review. Our
overall objectives were to determine (1) who provides fire protection
services for the Navy-retained property in Philadelphia and how this
fire protection compares with that at other closed military bases where
some property was retained by the Department of Defense; (2) how the
level of fire protection services at the business center measures up to
that provided elsewhere in the City of Philadelphia; and (3) what the
future prospects are for changing the way fire protection is provided
at the Navy‘s enclave.
Results in Brief:
A federal fire-fighting service provides fire protection services at
the Navy‘s enclave located at the Philadelphia Naval Business Center.
This is one of three military enclaves, formed during the base closure
and realignment process, which is still protected by federal
firefighters. Twenty-four other military enclaves were converted from
federal to local fire protection during the base closure process. The
Navy retained a federal fire-fighting force at its enclave at the
Philadelphia Naval Business Center because the Commonwealth of
Pennsylvania did not respond to the Navy‘s request to change the
jurisdiction of the Navy-retained land. The Navy sought to change the
jurisdiction from exclusive federal to proprietary to provide uniform
fire and police protection over the business center and the Navy‘s
enclave there.
The level of fire protection at the Philadelphia Naval Business Center
is similar to that available elsewhere in the City of Philadelphia, but
the arrangements for providing that protection differ. If a fire occurs
on non-Navy property within the business center, both the Navy and the
Philadelphia fire departments will automatically respond to the call,
with the Navy as the first responder. However, if the fire is located
on Navy-owned property at the business center, only Navy firefighters
will automatically respond to the alarm. If they need additional fire-
fighting assistance, they must first call the city fire department,
which will then send assistance. These arrangements are the result of a
mutual aid agreement the Navy and the City of Philadelphia signed in
March 2000 that is up for renewal in March 2003. According to Navy
officials, the agreement enables the Navy to meet the Department of
Defense‘s and the Navy‘s fire response standards. In the 29 months
since the agreement was signed, the Navy‘s fire department has
requested assistance from the Philadelphia Fire Department for one
fire, but the Navy has responded to 25 fire requests at non-Navy
property within the business center. Both city and Navy fire department
officials told us they have found the agreement beneficial and they
expect to renew it.
As private development at the Philadelphia Naval Business Center
continues, the fire protection arrangements are expected to be
reassessed. The Commissioner of the Philadelphia Fire Department told
us that, as development at the business center continues to increase,
his office will need to reevaluate the location of city-owned fire
stations in the area around the business center. This reevaluation
could provide an opportunity for the Commonwealth of Pennsylvania, the
City of Philadelphia, and the Navy to reassess jurisdictional issues
and the need for a separate fire department to service the Navy‘s
enclave.
In commenting on a draft of this report, the department concurred with
the results.
Background:
To enable the Department of Defense (DOD) to close unneeded bases and
realign others, Congress enacted base realignment and closure
legislation that instituted base closure rounds in 1988, 1991, 1993,
and 1995.[Footnote 1] In some cases, DOD retained some of the property
and created military enclaves on closed installations.
Generally, as part of the base closure process, DOD prefers to change
the jurisdiction of the property that it has retained from exclusive
federal to proprietary jurisdiction.[Footnote 2] Under exclusive
federal jurisdiction, the federal government is responsible for
providing all municipal services and enforcing federal laws. The state
and local governments do not have any authority or obligation to
provide municipal services under this type of jurisdiction, except
under mutual support agreements. Under proprietary
jurisdiction,[Footnote 3] the federal government has rights--similar to
a private landowner--but also maintains its authorities and
responsibilities as the federal government. Under this type of
jurisdiction, the local government is the principal municipal police
and fire authority.
Following the decision to close the installations in 1991, the Naval
Shipyard and the Naval Station in Philadelphia were officially closed
in September 1995 and January 1996, respectively. In March 2000, the
Navy transferred 1,180 acres of the property to the Philadelphia
Authority for Industrial Development, the local redevelopment
authority. The Navy retained exclusive federal jurisdiction over about
270[Footnote 4] acres as a military enclave. As a result, the Navy is
responsible for providing all municipal services, including fire
protection, in this enclave. Similarly, the City of Philadelphia and
the Commonwealth of Pennsylvania maintain jurisdiction over the 1,180
acres that were transferred. The federal government has
no jurisdiction over this land. Together, the Navy-retained and
Navy-transferred property is called the Philadelphia Naval Business
Center.
The Navy‘s 270-acre enclave in Philadelphia is made up of several
distinct noncontiguous areas separated by the transferred acreage. (See
app. I for a map and an aerial photograph of the enclave.) The Navy
retained 67 buildings that house more than 2,300 civilian, contractor,
and military employees. The majority of the Navy‘s employees--about
1,800--work in about 47 office buildings. The remaining 500 Navy
employees work at industrial or maintenance activities, including the
Naval Foundry and Propeller Shop; a hull, mechanical, and electrical
systems test facility; and a public works center. The enclave also
includes a reserve basin that is used as a docking area for about 38
Navy inactive ships.
In contrast, the non-Navy part of the business center includes about 45
private firms with approximately 2,500 employees. This part is being
developed by the Philadelphia Industrial Development Corporation, the
City of Philadelphia‘s private economic development corporation. The
corporation is authorized by the local redevelopment authority to
attract private business to the Philadelphia Naval Business Center, a
business and industrial park that is undergoing redevelopment utilizing
the 1,180 transferred acres.
The Navy facilities are protected by a federal fire service consisting
of 26 personnel[Footnote 5] and 2 fire engines[Footnote 6] located on
the enclave. The Navy estimated that the cost was $2.5 million to
operate the federal fire department at the enclave during fiscal year
2001.
The City of Philadelphia is responsible for providing fire protection
services to private development on non-Navy property at the business
center. It is also responsible for providing additional fire protection
to the Navy facilities according to a March 2000 Mutual Aid Assistance
Agreement. The agreement was signed by both Navy and City of
Philadelphia officials, and it is intended to provide additional fire
equipment and firefighters to respond to fires and other emergencies on
each other‘s property at the business center. (See app. II for a copy
of the agreement.) Although not specified in the agreement, enclave
command officials and Navy and city fire department officials told us
that in practice, the Navy firefighters are first responders to all
fire alarms at the business center--on both Navy and non-Navy property.
The city fire department automatically responds to fire calls on non-
Navy property at the business center; it responds to a fire on Navy
property if it is called by the Navy fire department.
The DOD Fire and Emergency Services Program[Footnote 7] provides policy
that governs fire protection at military installations. The policy
states that the first arriving fire apparatus shall meet a travel
time[Footnote 8] of 5 minutes for
90 percent of all alarms and that the remaining apparatus shall meet a
travel time of 10 minutes for all alarms. The policy also states that
the initial response to a fire will be two engine companies and one
ladder company but that another engine company may replace the ladder
company. The number of full-time fire and emergency service personnel
and equipment needed to meet these standards at any installation may
depend on the extent to which equivalent forces are available from
outside sources. The DOD policy encourages installations to enter into
reciprocal agreements with local fire departments for mutual fire and
emergency services to meet these standards. Navy policy[Footnote 9]
mirrors that of DOD.
The Navy considers a number of factors, including the strategic
importance, the criticality to the overall Navy mission, the degree of
fire and life safety hazards, the value of facilities and equipment,
and the availability of outside support, in determining fire protection
requirements at each installation. Using these criteria, the federal
enclave at the business center is required to have a fully staffed on-
site federal
fire-fighting force; however, some of the fire-fighting force may be
satisfied by city assets based on a mutual aid agreement.
Most Enclaves Rely on Local Rather Than Federal Fire Protection:
Today, according to military service base realignment and closure
officials, federal firefighters operate at only 3 of the 27 federal
enclaves that were created at closed Navy, Army, and Air Force
installations (see table 1).
Table 1: Fire Protection Services at Federal Enclaves Created at Closed
Installations:
Service: Navy; Closed installations with federal enclaves: 3; Number
with fire protection provided by: Federal: 1; Number with fire
protection provided by: Local: 2.
Service: Army; Closed installations with federal enclaves: 14; Number
with fire protection provided by: Federal: 1; Number with fire
protection provided by: Local: 13.
Service: Air Force; Closed installations with federal enclaves: 10;
Number with fire protection provided by: Federal: 1; Number with fire
protection provided by: Local: 9.
[A] Other military enclaves receive fire protection from local
firefighters, but they had local fire protection services before the
installation closed.
Source: DOD data.
[End of table]
The enclave at the former Philadelphia Naval Shipyard and Naval Station
is the only Navy enclave where a federal fire protection presence
remains. According to Navy officials, federal fire protection was
retained because the Commonwealth of Pennsylvania did not respond to
the Navy‘s request in 1999 to change the jurisdictional status of the
property from exclusive federal to proprietary jurisdiction in
anticipation of the Navy transferring the ownership of excess land. In
its April 1999 letter to the governor of Pennsylvania requesting the
change, the Navy stated that such a change would provide uniform
jurisdiction over the business center and the Navy‘s enclave there. In
addition, Navy officials told us that the change would mean that the
City of Philadelphia would have been responsible for providing all
municipal services such as fire and police protection.
The Navy‘s two other enclaves--the former Charleston, South Carolina,
and Long Beach, California, shipyards--receive fire protection services
from the local communities.[Footnote 10] A Navy official told us that
the land at the former Charleston and Long Beach shipyards had already
been designated as concurrent jurisdiction before they were closed, so
the Navy did not have to request a change in designation. In addition,
local governments agreed to provide fire protection to the federal
enclaves at both former shipyards.
Like the Navy, the Army retained federal firefighters at only one of
its federal enclaves. The remaining 13 Army enclaves are protected by
local community firefighters. According to an official in the Army‘s
Base Realignment and Closure Office, a federal fire-fighting force was
retained at the enclave created when Fort Ord, California, was closed
in order to provide fire protection for a 1,600-unit housing complex
and other community support facilities, such as a military exchange and
commissary. Before Fort Ord closed, the installation was under
exclusive federal jurisdiction, but now the enclave is under concurrent
jurisdiction. According to an Army base realignment and closure
official, most of the other 13 Army installations changed from
exclusive federal to proprietary jurisdiction.
The Air Force also retained federal firefighters at only one of its
enclaves while local firefighters provide fire protection at nine other
Air Force enclaves. According to the Air Force‘s Fire Protection
Program Manager, a federal firefighter force was maintained at the
enclave created when Grissom Air Force Base, Indiana, was closed to
support the substantial flying mission that remained. Before the
installation was closed, most of the land at Grissom, which is now an
Air Reserve Base, was under exclusive federal jurisdiction, while a
smaller portion was under proprietary jurisdiction; currently, all of
the property at Grissom is under proprietary jurisdiction. The other
nine Air Force enclaves are also under proprietary jurisdiction,
although five had exclusive federal jurisdiction and two had a mix of
exclusive and proprietary jurisdiction before the installations were
closed.
Fire Protection at the Business Center Is Similar to That Provided
Elsewhere in Philadelphia:
The level of fire protection at the business center is similar to that
available elsewhere in the City of Philadelphia, but the arrangements
for providing that protection are different. When a fire occurs on non-
Navy property within the business center, both the City of Philadelphia
Fire Department and the firefighters from the Navy‘s enclave
automatically respond to the call. When a fire occurs at the Navy‘s
enclave at the business center, only the Navy firefighters
automatically respond to the alarm. If they need additional fire-
fighting help, they must first call the city fire department, which
will then send assistance. This mutual assistance is part of the
agreement between the Navy and the City of Philadelphia, which Navy
officials state enables them to meet DOD‘s and Navy‘s fire response
requirements.
Senior Philadelphia city fire department officials told us that they
respond to alarms in the city or within the city-owned parts of the
business center with a minimum of 2 engines, 2 ladders, and 19
firefighters. They noted that none of their 61 fire stations have the
full complement of equipment and firefighters needed for the minimum
response but that they rely on support from other fire stations
throughout the city. Similarly, the Navy‘s fire department at the
federal enclave in the business center does not have--on its own--the
full complement of equipment and firefighters needed for a minimum
response as specified in DOD and Navy policy. However, the Navy‘s fire
department is able to meet DOD‘s and Navy‘s standards through its
agreement with the City of Philadelphia. According to the Philadelphia
Fire Commissioner, when the city responds to a request for assistance
from the Navy, the city fire department would not necessarily respond
with a ladder truck but with enough equipment and firefighters to bring
the responding assets up to the city‘s minimum standards. This is
especially true when the call involves an emergency other than a fire.
A Philadelphia Deputy Fire Commissioner estimated that the response
time for an engine company from the nearest Philadelphia city fire
station to the main gate of the business center would be just under 7
minutes and that the response time from the nearest ladder company
would be less than 11 minutes. He also said that it would take
additional time to get from the main gate to various parts of the
Navy‘s enclave. According to a study performed by the International
Association of Firefighters,[Footnote 11] the first Philadelphia Fire
Department ladder truck would arrive at the main gate of the business
center in about 5 minutes and 55 seconds. Navy officials said that the
Philadelphia Fire Department‘s response times meet the current DOD and
Navy response criteria--10 minutes for subsequent arriving vehicles--
assuming the city fire department is arriving after Navy firefighters
have already responded to the alarm.
The Navy‘s fire department has responded to more than 300 calls each
year during the last 2 full years, and it is on track for responding to
more than 300 calls in 2002. These calls included fire emergencies,
emergency medical service (EMS) requests, rescues, natural gas leaks,
hazardous materials incidents, standby fueling operations, and alarms
with no fire. During this same period, Navy data indicate the enclave‘s
firefighters have responded to a total of 41 fires, 16 of which were on
the enclave.
From the time that the agreement was signed in March 2000 to September
2002, 29 months later, City of Philadelphia firefighters responded to
one fire call on the Navy‘s enclave as part of the agreement. They also
responded to 39 EMS calls and 4 other calls at the enclave during the
same period. Table 2 shows the number of fire, EMS, and other responses
that the Navy and the City of Philadelphia conducted under their mutual
aid agreement.
Table 2: Navy Fire, EMS, and Other Calls and Mutual Aid Responses by
the Navy and the City of Philadelphia, 2000 to 2002 (as of September 4,
2002):
Calendar year: 2000; Total number of Navy fire and emergency calls:
320; City aid to the Navy: Fire: 1; City aid to the Navy: EMS: 16; City
aid to the Navy: Other: 1; [Empty]; Navy aid to the city: Fire: 7; Navy
aid to the city: EMS: 39; Navy aid to the city: Other: 23.
Calendar year: 2001; Total number of Navy fire and emergency calls:
363; City aid to the Navy: Fire: 0; City aid to the Navy: EMS: 10; City
aid to the Navy: Other: 3; [Empty]; Navy aid to the city: Fire: 10;
Navy aid to the city: EMS: 55; Navy aid to the city: Other: 17.
Calendar year: 2002; Total number of Navy fire and emergency calls:
219; City aid to the Navy: Fire: 0; City aid to the Navy: EMS: 13; City
aid to the Navy: Other: 0; [Empty]; Navy aid to the city: Fire: 8; Navy
aid to the city: EMS: 56; Navy aid to the city: Other: 14.
Source: Navy fire department on the business center.
[End of table]
On the other hand, during the same period, the Navy fire department
responded to 25 mutual aid fire calls on non-Navy property at the
business center. It also responded to 150 EMS and 54 other calls on
non-Navy property. Both Navy and Philadelphia city fire department
officials told us that they have found the agreement mutually
beneficial and that they expect to renew the agreement in March 2003.
Future Development Could Affect Existing Arrangement for Fire
Protection:
According to city fire department officials, future economic
development at the business center is expected to require a
reassessment of fire protection services provided by the City of
Philadelphia. Currently, about 45 private tenants with about 2,500
employees are housed in 47 buildings located on non-Navy property.
However, the development corporation plans to add additional office
space at the business center over the next several years. For example,
a 43,000-square foot building directly across from the Navy command
building is under renovation; when it is completed in early 2003, it
will provide office space for about 150 people. In addition, the
development corporation plans to provide an additional 800,000 square
feet of office space over the next 8 years. According to the
Philadelphia Fire Department Commissioner, as development in the
business center continues to expand, his office is expected to
reevaluate the location of fire stations located near the business
center. This reevaluation could provide an opportunity for the
Commonwealth of Pennsylvania, the City of Philadelphia, and the Navy to
reassess jurisdictional issues and the need for a separate fire
department to service the Navy‘s enclave.
A recent development underscored the possibility of change in fire
protection at the business center. In August 2002, the development
corporation announced that a developer plans to build 230 private homes
on land outside the main gate of the business center. A Philadelphia
Deputy Fire Commissioner stated that the city would need to reconsider
fire protection for this area once the planned development was
completed.
Conclusions:
At the time of the transfer of excess land at the former Philadelphia
Naval Shipyard and Naval Station to the redevelopment authority, the
Navy tried unsuccessfully to change the jurisdiction of the 270-acre
enclave it retained from exclusive federal to proprietary. This
jurisdictional change would have been similar to what occurred at most
other military enclaves created during the base closure and realignment
process. According to Navy officials, such a change would have provided
uniform jurisdiction over both the non-Navy property and the Navy-owned
enclave at the business center. This change would have given the City
of Philadelphia responsibility for providing all municipal services,
including fire protection, at the business center. Instead, the
jurisdiction at the
Navy-owned enclave remains exclusively federal, and the Navy spends
about $2.5 million annually to retain its fire department there. As
private development at the business center and in its immediate
vicinity continues to grow over the next few years, the business
center‘s fire protection arrangements may have to be reevaluated.
Philadelphia Fire Department officials told us they recognize they will
need to reevaluate the way fire protection is provided at the business
center. This reevaluation could provide the Commonwealth of
Pennsylvania, the City of Philadelphia, and the Navy with an
opportunity to reconsider the jurisdictional issues and reassess the
need for a separate Navy fire department to service the Navy‘s enclave
at the business center.
Agency Comments:
In commenting on a draft of this report, the Deputy Under Secretary of
Defense (Installations and Environment) concurred with the report.
DOD‘s comments are included in this report as appendix III.
Scope and Methodology:
We conducted our work at the Office of the Director Navy Fire and
Emergency Services and Base Closure Office, the Naval Facilities
Engineering Command in Washington, D.C., the Ship Systems Engineering
Station and the Fire Department, the Philadelphia Naval Business
Center, the Philadelphia Fire Department, and Philadelphia Industrial
Development Corporation. We also did work at the Army‘s Base
Realignment and Closure office, the office of the Assistant Chief of
Staff for Installation Management, and the Air Force Base Conversion
Agency.
To determine how fire protection services at the business center
compared with those at other federal enclaves created under base
closure, we reviewed the 1988, 1991, 1993, and 1995 base realignment
and closure reports and identified where DOD retained property on
closed installations. We analyzed information from the Army and Navy
base closure offices and the Air Force Base Conversion Agency on how
fire protection was provided at the retained federal property on closed
installations and on the jurisdiction at the installations prior to and
after closure. We reviewed DOD and Navy guidance regarding the staffing
and equipping of fire departments.
To determine how fire responses at the business center compared with
those elsewhere in the City of Philadelphia, we interviewed the
Commissioner and two Deputy Commissioners in the Philadelphia Fire
Department to obtain information on how city firefighters respond to
fire alarms in the City of Philadelphia and on the business center. In
addition, we interviewed the Chief and the Assistant Chiefs of the Navy
fire department to determine how Navy firefighters respond to fire
alarms on Navy and non-Navy properties within the business center and
we analyzed Navy fire department workload data. We also analyzed
response time information provided by the Navy and the Philadelphia
fire departments. Finally, we reviewed the agreement between the Navy
and the City of Philadelphia regarding fire protection at the business
center.
To determine how future development of the business center would affect
how fire protection is provided, we interviewed the Commissioner and
two Deputy Commissioners in the Philadelphia Fire Department. To obtain
information on future development at the business center, we
interviewed officials from the Philadelphia Industrial Development
Corporation.
We conducted our review from July through September 2002 in accordance
with generally accepted government auditing standards.
We are sending copies of this report to interested congressional
committees; the Secretaries of Defense, the Army, the Navy, and the Air
Force; and the Director, Office of Management and Budget. We will also
provide copies to others upon request. In addition, the report will be
available at no charge on GAO‘s Web site at http://www.gao.gov.
Please contact me on (202) 512-8412 if you or your staff have any
questions regarding this report. Key contributors to this report were
Michael Kennedy, Richard Meeks, Aaron Loudon, Ken Patton, and
Nancy Benco.
Barry Holman, Director
Defense Capabilities and Management:
Signed by Barry Holman:
[End of section]
Appendix I: Federal Enclave at the Philadelphia Naval Business Center:
Figure 1: Map of the Enclave at the Philadelphia Naval Business Center:
[See PDF for image]
Source: Philadelphia Industrial Development Corporation and Navy data.
[End of figure]
Figure 2: Aerial Photograph of the Philadelphia Naval Business Center:
[See PDF for image]
Source: Navy photograph.
[End of figure]
[End of section]
Appendix II: Mutual Aid Agreement between the Navy and the City of
Philadelphia:
[See PDF for image]
[End of section]
Appendix III: Comments from the Department of Defense:
ACQUISITION. TECHNOLOGY AND LOGISTICS:
OFFICE OF THE UNDER SECRETARY OF DEFENSE:
3000 DEFENSE PENTAGON WASHINGTON, DC 20301-3000:
OCT 22 2002:
Mr. Barry W. Holman:
Director, Defense Capabilities and Management U. S. General Accounting
Office:
441 G Street, N.W. Washington, DC 20548:
Dear Mr. Holman:
This is the Department of Defense‘s response to the GAO Draft Report,
GAO-03-20, ’DEFENSE INFRASTRUCTURE: Fire Protection at Philadelphia
Naval Business Center Meets Response Standards,“ dated September 27,
2002 (GAO Code 350237/GAO-03-20). We concur with the results and have
no additional comments.
Sincerely,
Raymond F. DuBois Deputy Under Secretary of Defense (Installations and
Environment):
Signed by Raymond F. DuBois:
[End of figure]
FOOTNOTES:
[1] The 1988 round was completed under the Defense Authorization
Amendments and Base Closure and Realignment Act (P.L. 100-526). The
last three rounds were completed under the Defense Base Closure and
Realignment Act of 1990 (P.L. 101-510).
[2] Two other types of jurisdiction exist. Under concurrent
jurisdiction, federal and local agencies provide services and enforce
both federal and local laws, respectively. Under partial jurisdiction,
the local government retains all legislative and judicial authority not
ceded to the federal government.
[3] Proprietary jurisdiction over property is also sometimes described
as having a proprietary interest in the property. We use the two
interchangeably.
[4] About 162 acres are on land and 108 acres are submerged at the
enclave‘s reserve basin.
[5] The Navy fire service is authorized 29 staff, but 3 positions are
currently vacant. The Navy‘s intent is to fully staff the fire service.
[6] The Navy fire service also has a reserve engine that is not
staffed.
[7] DOD Instruction 6055.6.
[8] Travel time is defined as the amount of time it takes a fire
apparatus to travel from the fire station to an emergency incident.
[9] Operations Navy Instruction 11320.23F, April 25, 2001.
[10] The enclave at Charleston consists of 26 acres and 15 buildings
and the enclave at Long Beach consists of 15 acres and 4 buildings.
[11] International Association of Firefighters, Philadelphia Naval
Shipyard Federal Fire Department (NAVSSES): Feasibility Study on the
Use of Philadelphia City Fire Apparatus to Comply with Department of
Defense Instruction 6055.6 Fire Apparatus Deployment Requirements
(Philadelphia, Pa.: June 21, 2002).
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