Coast Guard
Station Readiness Improving, but Resource Challenges and Management Concerns Remain Gao ID: GAO-05-161 January 31, 2005For years, the Coast Guard has conducted search and rescue operations from its network of stations along the nation's coasts and waterways. In 2001, reviews of station operations found that station readiness--the ability to execute mission requirements in keeping with standards--was in decline. The Coast Guard began addressing these issues, only to see its efforts complicated by expanded post-September 11, 2001, homeland security responsibilities at many stations. GAO reviewed the impact of changing missions on station needs, the progress made in addressing station readiness needs, and the extent to which plans are in place for addressing any remaining needs.
The Coast Guard does not yet know the extent to which station readiness needs have been affected by post-September 11 changes in mission priorities, although increases in homeland security operations have clearly affected activities and presumably affected readiness needs as well. Following the attacks, stations in and near ports received the bulk of port security duties, creating substantial increases in workloads. The Coast Guard is still in the process of defining long-term activity levels for homeland security and has yet to convert the homeland security mission into specific station readiness requirements. Until it does so, the impact of these new duties on readiness needs cannot be determined. The Coast Guard says it will revise readiness requirements after security activity levels have been finalized. Increased staffing, more training, new boats, more personal protection equipment (such as life vests), and other changes have helped mitigate many long-standing station readiness concerns. However, stations have been unable to meet current Coast Guard standards and goals in the areas of staffing and boats, an indication that stations are still significantly short of desired readiness levels in these areas. Also, because Coast Guard funding practices for personal protection equipment have not changed, stations may have insufficient funding for such equipment in the future. The Coast Guard does not have an adequate plan in place for addressing remaining readiness needs. The Coast Guard's strategic plan for these stations has not been updated to reflect increased security responsibilities, and the agency lacks specific planned actions and milestones. Moreover, the Coast Guard has yet to develop measurable annual goals that would allow the agency and others to track stations' progress.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-161, Coast Guard: Station Readiness Improving, but Resource Challenges and Management Concerns Remain
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Report to the Senate and House Committees on Appropriations:
United States Government Accountability Office:
GAO:
January 2005:
Coast Guard:
Station Readiness Improving, but Resource Challenges and Management
Concerns Remain:
GAO-05-161:
GAO Highlights:
Highlights of GAO-05-161, a report to the Senate and House Committees
on Appropriations:
Why GAO Did This Study:
For years, the Coast Guard has conducted search and rescue operations
from its network of stations along the nation‘s coasts and waterways.
In 2001, reviews of station operations found that station readiness”the
ability to execute mission requirements in keeping with standards”was
in decline. The Coast Guard began addressing these issues, only to see
its efforts complicated by expanded post-September 11, 2001, homeland
security responsibilities at many stations. GAO reviewed the impact of
changing missions on station needs, the progress made in addressing
station readiness needs, and the extent to which plans are in place for
addressing any remaining needs.
What GAO Found:
The Coast Guard does not yet know the extent to which station readiness
needs have been affected by post-September 11 changes in mission
priorities, although increases in homeland security operations have
clearly affected activities and presumably affected readiness needs as
well. Following the attacks, stations in and near ports received the
bulk of port security duties, creating substantial increases in
workloads. The Coast Guard is still in the process of defining long-
term activity levels for homeland security and has yet to convert the
homeland security mission into specific station readiness requirements.
Until it does so, the impact of these new duties on readiness needs
cannot be determined. The Coast Guard says it will revise readiness
requirements after security activity levels have been finalized.
Increased staffing, more training, new boats, more personal protection
equipment (such as life vests), and other changes have helped mitigate
many long-standing station readiness concerns. However, stations have
been unable to meet current Coast Guard standards and goals in the
areas of staffing and boats, an indication that stations are still
significantly short of desired readiness levels in these areas. Also,
because Coast Guard funding practices for personal protection equipment
have not changed, stations may have insufficient funding for such
equipment in the future.
The Coast Guard does not have an adequate plan in place for addressing
remaining readiness needs. The Coast Guard‘s strategic plan for these
stations has not been updated to reflect increased security
responsibilities, and the agency lacks specific planned actions and
milestones. Moreover, the Coast Guard has yet to develop measurable
annual goals that would allow the agency and others to track stations‘
progress.
A Coast Guard Boat and a Multimission Station:
[See PDF for image]
[End of figure]
What GAO Recommends:
To assist the Coast Guard in addressing station readiness concerns, GAO
recommends that once security requirements have been defined, the Coast
Guard
* revise strategic plans to reflect new security responsibilities and
to include specific actions and other mechanisms for meeting station
needs,
* develop annual station goals, and
* revise practices for funding station personal protection equipment.
The Department of Homeland Security and the Coast Guard reviewed a
draft of this report and generally agreed with the findings and
recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-05-161.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Margaret Wrightson at
(415) 904-2200 or wrightsonm@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Added Security Responsibilities Had Impact on Readiness Needs but
Extent of Impact Unknown:
Progress Made in Addressing Readiness Concerns but Stations Are Still
Unable to Meet Standards and Goals:
Strategic Plan for Improving Station Readiness Lacks Key Components for
Measuring Progress:
Conclusions:
Recommendations:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Actions Taken by Category to Meet Station Readiness Needs:
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Tables:
Table 1: Selected Types of Positions and Occupations at Stations:
Table 2: Selected Types of Boats Operated by Stations:
Table 3: Selected Findings from OIG, Coast Guard, and Senate Reports on
Multimission Station Readiness Concerns:
Table 4: Examples of Coast Guard Efforts to Address Station Staffing
Needs:
Table 5: Comparison of the 68-and 84-Hour Workweek Schedules:
Table 6: Examples of Coast Guard Efforts to Address Station Training
Needs:
Table 7: Examples of Coast Guard Efforts to Address Station Boat Needs:
Table 8: Selected Examples of Coast Guard Strategic Goals, Objectives,
and Initiatives for Multimission Stations:
Table 9: Workweek Results of August 2003 Station Survey:
Table 10: Additional Examples of Implemented or Planned Initiatives to
Address Station Staffing Needs:
Table 11: Examples of Coast Guard Efforts to Address Station Training
Needs:
Table 12: Examples of Coast Guard Efforts to Address Station Boat
Needs:
Table 13: Concerns Regarding Coast Guard Processes and Practices for
Identifying and Funding Station PPE Needs:
Figures:
Figure 1: Total Boat Hours for All Station Programs, Pre-September 11
Baseline through 2004:
Figure 2: Boat Hours for Selected Programs, Pre-September 11 Baseline
through 2004:
Figure 3: Coast Guard 47-Foot Motor Lifeboat (left) and 41-Foot Utility
Boat:
Figure 4: Response Boat Small:
Figure 5: Station Crew Member Wearing Cold Weather PPE:
Abbreviations:
GPRA: Government Performance and Results Act:
MARSEC: Maritime Security Condition:
MSO: Marine Safety Offices:
MSST: Maritime Safety and Security Teams:
OIG: Office of Inspector General:
PPE: personal protection equipment:
PWCS: Ports, Waterways, and Coastal Security:
United States Government Accountability Office:
Washington, DC 20548:
January 31, 2005:
The Honorable Thad Cochran:
Chairman:
The Honorable Robert C. Byrd:
Ranking Minority Member:
Committee on Appropriations:
United States Senate:
The Honorable Jerry Lewis:
Chairman:
The Honorable David R. Obey:
Ranking Minority Member:
Committee on Appropriations:
House of Representatives:
The 188 Coast Guard multimission stations located along the nation's
coastlines and interior waterways have been a mainstay of one of the
Coast Guard's oldest missions--finding and rescuing mariners in
danger.[Footnote 1] In 2001, after a series of search and rescue
mishaps, the Coast Guard and others conducted reviews of station
operations. These reviews showed that station readiness had been
declining for more than 20 years and was continuing to
decline.[Footnote 2] In response to these findings, the Coast Guard
began a long-term effort to address station needs. The response focused
in large part on reconfiguring operations and bolstering resources in
four areas--staffing, training, boats, and the personal protection
equipment used by personnel during operations, such as life vests and
survival suits.
This effort, which began prior to the terrorist attacks of September
11, 2001, was complicated by the new and increased homeland security
responsibilities stations assumed in the wake of the attacks. With the
intensification of maritime security operations, the Coast Guard faces
additional challenges in reorganizing resources to meet potential
maritime threats and at the same time reach new and sustainable levels
of readiness.
The term "readiness," as used by the Coast Guard, involves more than
the ability to carry out required operations, such as a rescue or a
security patrol; it involves the ability to do so at a sustainable
level while adhering to agency standards. For example, a station may
have enough personnel to carry out rescues and other required missions,
but not enough to meet agency standards that specify the number of
hours personnel should work. In this scenario, the station is not
considered fully ready because it is not complying with agency
standards and, therefore, may have difficulty maintaining its
performance over an extended period. However, as the example
illustrates, a lack of full readiness should not be interpreted as an
inability to meet basic mission responsibilities. Moreover, readiness
requirements can change depending on the needs of the mission. While
some assets at a station may not fully meet readiness requirements for
certain missions, they can be used to perform other missions. For
example, a rescue boat with a mechanical problem that precluded
operating it at top speed would not meet full readiness requirements
for rescues or high-speed chases, but it could meet requirements for
missions that did not typically require high speeds, such as patrols or
vessel escorts. Thus, a lack of full readiness does not affect all
missions equally.
This report, the second of two reviews directed by Congress on
multimission station operations,[Footnote 3] focuses on the Coast
Guard's progress in addressing long-standing station readiness
needs[Footnote 4] while balancing changing mission demands.
Specifically, this report addresses the extent to which the Coast
Guard:
* has experienced a change in multimission station readiness needs as a
result of post-September 11 changes in mission priorities;
* has been able to address readiness concerns through the addition of
resources in the areas of personnel, training, boats, and personal
protection equipment; and:
* has plans in place for addressing any readiness needs that may still
exist.
To address these objectives, we analyzed Coast Guard data, reviewed
relevant documents, and interviewed headquarters and field officials.
The key data we reviewed included (1) station resource (boat) hour
data, used to track the number of hours spent on individual missions;
(2) port activities data, used to monitor security operations at key
ports; (3) various operations data (in the areas of staffing, training,
boats, and personal protection equipment), used to monitor station
needs; and (4) fiscal year 2003 results from the Coast Guard's annual
station workload survey, used to assess changes in personnel workloads.
On the basis of interviews with knowledgeable agency officials, data
assessments from previous reports, and reviews of existing
documentation, we determined that these data were sufficiently reliable
for this report. To better understand stations' readiness needs and how
those needs have changed over time, we also visited 8 multimission
stations on the Pacific and Atlantic coasts and interviewed relevant
field officials. The stations were selected based on geographic
location, proximity to a strategic port,[Footnote 5] and the number of
station resource hours expended on various missions during fiscal year
2003. To further explore how changes in mission priorities after
September 11 affected stations, we interviewed by telephone officials
responsible for operations at 8 additional stations, located at various
strategic ports, which we selected based on the number of station
resource hours expended on port security operations. For security
purposes, the 16 stations we visited or reviewed through telephone
interviews are not identified in this report. On the basis of input
from station personnel, we also interviewed officials from 13 local and
state organizations that have partnerships with 8 of the stations we
reviewed. Appendix I explains in more detail the scope of our work and
the methodology we used. We conducted our work for this second report
from September 2003 through December 2004 in accordance with generally
accepted government auditing standards.
Results in Brief:
The Coast Guard does not yet know the extent to which station readiness
needs--primarily resource levels--have been affected by post-September
11 changes in mission priorities. However, increases in homeland
security operations after the September 11 terrorist attacks clearly
affected stations' mission activities and presumably the readiness
needs related to those activities. Following the attacks, the Coast
Guard elevated the homeland security mission to a level commensurate
with the search and rescue mission, and stations were assigned the
brunt of the Coast Guard's port security responsibilities. These new
responsibilities led to substantial increases in the stations' security
workloads. In addition, these workload levels may change in the future
once the Coast Guard has established long-term security activity
standards for stations and other units. Currently, the Coast Guard is
operating under interim homeland security guidelines, which establish
recommended security activities for field units according to each
maritime security threat level. These guidelines are not, according to
Coast Guard officials, considered requirements because the recommended
operations established by the guidelines exceed current resource
levels. Because the Coast Guard is still in the process of defining
long-term, risk-based standards for security activities, it has yet to
translate the impact of security-related mission responsibilities into
specific station readiness requirements, such as staffing standards.
Until it does so, the impact of these new homeland security
responsibilities on readiness needs cannot be determined. Further,
without specific requirements, neither the Coast Guard nor others can
measure the progress made in meeting station readiness needs. Officials
said they plan to start revising station readiness requirements once
long-term homeland security requirements have been finalized, which the
Coast Guard expects to occur in February 2005. Because the interim
security guidelines exceed available resources, officials told us
stations and other units are expected to perform security operations as
allowed for by their existing resources. Given these factors, Coast
Guard data indicate that stations and other units are meeting most of
the port security activities expected of them.
Operational improvements in staffing, training, boats, and personal
protection equipment, as well as increases in resource levels at
stations, have helped mitigate a number of long-standing readiness
concerns. However, even without the new readiness requirements as a
gauge to measure progress, it is clear that stations have been unable
to meet current Coast Guard standards and goals related to staffing,
boats, and equipment, which indicates that stations are still
significantly short of desired readiness levels in some areas. Since
2001, the Coast Guard has increased station staffing by 25 percent and
realigned the stations' staffing structure, expanded training programs,
embarked on an extensive program to replace and standardize aging
boats, and provided all station personnel with personal protection
equipment. However, there are indications that station personnel
continue to work significantly longer hours than are allowed for under
the Coast Guard's work standards, which are in place to ensure that
personnel do not become overly fatigued. Regarding boats, although the
Coast Guard has replaced old boats and increased the number of boats at
many stations, Coast Guard inspections showed that about five boats in
every six inspected at selected stations in 2003 did not initially meet
readiness requirements. Finally, while station personnel appear to have
been outfitted with sufficient personal protection equipment as of
fiscal year 2003, the Coast Guard's processes and practices for
determining funding needs--such as not basing funding estimates on the
number of personnel assigned to stations and historically funding only
about half of identified needs--raise concerns that the Coast Guard may
not allot sufficient funds in the future for station equipment.
The Coast Guard does not have an adequate plan in place for achieving
and assessing station readiness in its new post-September 11 operating
environment. The Boat Forces Strategic Plan--the Coast Guard's strategy
for maintaining and improving essential multimission station
capabilities over the next 10 years--is the agency's primary tool for
measuring progress in meeting station readiness requirements. Although
the plan outlines a significant array of long-term goals, objectives,
and initiatives for addressing station readiness needs, it has not been
updated to reflect increased homeland security responsibilities imposed
on stations in the wake of September 11. The plan also lacks key
elements, such as specific planned actions and milestones that would
help assure Congress and others that the Coast Guard will continue to
make progress in restoring station readiness. For example, the plan
does not identify what actions will be needed to ensure that station
personnel are placed in positions that are appropriate with their
experience, or to increase the actual length of time personnel are
assigned to stations. In addition, the plan lacks a clear link between
objectives and required funding levels. Furthermore, the Coast Guard
has yet to develop measurable annual goals that would allow the agency
to track its progress in achieving long-term goals and objectives,
allow others to effectively monitor and measure progress, and provide
accountability. Coast Guard officials told us that changing priorities
can make it difficult to adhere to long-term strategic plans and to
maintain program consistency; they also noted that the Coast Guard
intends to review the Boat Forces Strategic Plan on an annual basis.
To assist the Coast Guard in addressing past and future readiness
concerns, we are recommending that the Secretary of the Department of
Homeland Security, in consideration of any revised homeland security
requirements, direct the Commandant of the Coast Guard to ensure that
the Boat Forces Strategic Plan is revised to (1) reflect the impact of
homeland security requirements on station needs and (2) identify
specific actions, milestones, and funding requirements for meeting
those needs and responsibilities. We are also recommending that the
Coast Guard develop measurable annual goals for stations and revise
funding practices for personal protection equipment to reliably
identify annual station funding needs and to use this information when
making future funding decisions.
Background:
What Are Multimission Stations?
As shore-based units located along the nation's coasts and interior
waterways, the Coast Guard's 188 multimission stations conduct a wide
range of operations, from rescuing mariners in distress to patrolling
ports against acts of terrorism. The stations are involved in all Coast
Guard programs,[Footnote 6] including search and rescue, port security,
recreational and commercial fishing vessel safety, marine environmental
response, and law enforcement (drug and migrant interdiction). Their
involvement varies geographically from one Coast Guard district to the
next, depending on differing conditions among regions.[Footnote 7] Some
program operations also vary depending on the season--for example,
search and rescue operations are greater in the summer when
recreational boating is more active and lower in the winter. Because
stations are traditionally associated with search and rescue
operations, they can be compared to fire stations, in the sense that
crew members remain at the station for extended periods, on duty, ready
to respond to an emergency.[Footnote 8]
Stations range in size from as few as 4 personnel at seasonal stations
to as many as 60 personnel at larger stations. Individual stations are
usually commanded by a command cadre consisting of an officer-in-
charge--such as a senior chief petty officer--an executive petty
officer, and an engineering petty officer. The command cadre is
responsible for overseeing personnel, equipment, and mission-related
issues. In support of operations, the stations also provide unit-level
(on-the-job) training as well as equipment and minor boat maintenance.
As shown in table 1, stations employ personnel in numerous occupations,
but the principal staff usually consists of boatswain's mates--those
who operate the boats and carry out many station duties. In addition to
performing essential station responsibilities, boatswains' mates can
undergo additional training for more advanced occupations, such as a
coxswain (a boat driver) or a surfman (a coxswain who is qualified to
operate boats in heavy weather and high surf conditions).
Table 1: Selected Types of Positions and Occupations at Stations:
Rate (occupation)/position: Seaman apprentice/seaman;
Rank and grade[A]: Seaman apprentice/seaman (E-2 - E-3);
Description: Personnel who are in training for deck, weapons,
administrative, and certain electronics positions.
Rate (occupation)/position: Fireman apprentice/fireman;
Rank and grade[A]: Fireman apprentice/fireman (E-2 - E-3);
Description: Personnel who are in training for engineering and certain
hull positions.
Rate (occupation)/position: Machinery technician;
Rank and grade[A]: Starts at petty officer 3rd class (E-4);
Description: Personnel who operate, maintain, and repair engines, gas
turbines, and transmissions equipment, as well as auxiliary,
refrigeration, air conditioning, and electrical equipment.
Rate (occupation)/position: Boatswain's mate;
Rank and grade[A]: Starts at petty officer 3rd class (E-4);
Description: Personnel who are proficient in deck and boat seamanship
and have a working knowledge of all Coast Guard programs.
Rate (occupation)/position: Coxswain;
Rank and grade[A]: Starts at petty officer 3rd class (E-4);
Description: A boatswain's mate who is in charge of a boat and is
qualified to drive it.
Rate (occupation)/position: Surfman;
Rank and grade[A]: Starts at petty officer 2nd class (E-5);
Description: A coxswain--boat driver--who is qualified to drive boats
in heavy weather and high surf conditions.[B].
Rate (occupation)/position: Communications watchstander;
Rank and grade[A]: Starts at seaman (E-3);
Description: Personnel who stand watch--that is, who staff
communications systems and towers--for specific periods of time.
Rate (occupation)/position: Storekeeper;
Rank and grade[A]: Starts at petty officer 3rd class (E-4);
Description: Personnel who budget, order, receive, inventory, and
account for station purchases and requisitions.
Source: U.S. Coast Guard.
[A] The grade E-1, which is not listed, applies to seaman recruits--
personnel who are undergoing recruit training to become oriented to the
Coast Guard and a military environment.
[B] Surfmen are usually stationed at designated surf stations, which
are defined as stations that experience surf greater than 8 feet for 37
or more days during a calendar year.
[End of table]
Like the number of personnel, the number of boats at stations varies.
Small, seasonal stations may have only one boat, while larger stations
can have as many as nine. Table 2 describes the type of boats stations
typically operate. (see app. II for pictures of selected boats). All
station personnel are required to wear personal protection equipment
(PPE), while operating or riding in a boat. Coast Guard personnel use
PPE to protect against various dangers, such as inclement weather and
cold water exposure. PPE includes items such as life vests, helmets,
goggles, gloves, cold weather protection suits, thermal underwear, and
electronic location devices. (See app. II for more information on the
nature and use of PPE.)
Table 2: Selected Types of Boats Operated by Stations:
Type of boat: Response boat (small);
Specifications: 25-foot, maximum speed of 43 knots, maximum seas of 6
feet, brought into service in 2003[A];
Purpose: Used to conduct high-speed maneuvering tactics, including
homeland security operations.
Type of boat: Utility boat (big);
Specifications: 41-foot, maximum speed of 26 knots, maximum seas of 8
feet, brought into service in 1973[B];
Purpose: Designed to operate in moderate weather and sea conditions
(commonly referred to as the station "workhorse").
Type of boat: Motor lifeboat;
Specifications: 47-foot, maximum speed 25 knots, maximum seas of 30
feet and surf of 20 feet, started production in 1997;
Purpose: Designed as a fast-response rescue boat for high seas, surf,
and heavy weather conditions, it is used in extreme at-sea weather
conditions.
Type of boat: Nonstandard boats;
Specifications: Varies from 9-foot to 30-foot, with a range of
apabilities[C];
Purpose: Used for a variety of missions, including search and rescue
and law enforcement.
Source: U.S. Coast Guard.
[A] The Coast Guard plans to continue purchasing these boats through
2009, to replace nonstandard boats.
[B] The Coast Guard is planning to replace these boats with more
versatile and faster response boat mediums and plans to award a
contract for production in 2005.
[C] Nonstandard boats include a variety of small boats purchased at the
field level; these boats were purchased based on the preference and
discretion of the local commander rather than through a centralized,
coordinated effort.
[End of table]
What Are the Roles of Multimission Stations in Port and Nonport Areas?
Following the events of September 11, the Coast Guard created a new
program area for homeland security operations--the Ports, Waterways,
and Coastal Security (PWCS) program.[Footnote 9] The type and frequency
of PWCS activities performed by stations varies depending on whether a
station is located in a port area or in a nonport area. Stations
located in or near a port tend to perform more PWCS tasks, such as
patrolling, escorting vessels, and other duties.[Footnote 10] The
responsibilities can vary by port, however, depending on several
factors, including the availability of other Coast Guard units to share
in operations, the strategic importance of the port, and the support of
non-Coast Guard entities--such as state and local agencies--in both
homeland and nonhomeland security activities. Although stations located
in nonport areas also conduct PWCS operations, such as patrolling
waterways, they tend to have fewer PWCS responsibilities. In general,
stations located in nonport areas do not have the responsibility of
maintaining the security of critical infrastructure, high-profile
vessels, or shore operations as do stations located in port areas. As
tactical units,[Footnote 11] stations do not determine the nature or
frequency of their tasks; rather, they carry out the tasks assigned to
them by operational units,[Footnote 12] which provide oversight as well
as operational and administrative support to the stations.
Why Is Readiness a Concern?
In 2001, studies by the Office of Inspector General (OIG) and a Coast
Guard internal review team found that readiness conditions at
multimission stations had been deteriorating for over 20
years.[Footnote 13] The studies, which had largely consistent findings,
identified readiness concerns in the areas of staffing, training, and
boats and presented recommendations for addressing these concerns.
Table 3 presents selected findings from these studies, as well as
congressional concerns regarding station readiness. In December 2002,
in response to a recommendation from the OIG and at the direction of
the Senate Appropriations Committee,[Footnote 14] the Coast Guard
developed a draft strategic plan to maintain and improve essential
capability of all its boat force units, including stations.[Footnote
15] The plan recognized that stations did not have sufficient resources
to be fully capable of meeting all their workload requirements and that
it would take both increases in resources as well as "more judicious
tasking by operational commanders" to address the imbalance.[Footnote
16] In its 2003 report on station operations, the OIG criticized the
plan for being too general in nature, specifically regarding how and
when the Cost Guard will increase staffing, training, equipment, and
experience levels at stations.
Table 3: Selected Findings from OIG, Coast Guard, and Senate Reports on
Multimission Station Readiness Concerns:
Category: Staffing;
Concern: A shortage of personnel;
Explanation/ impact: Increases workweek hours for crew and compels
command cadre to fill in during operations.
Category: Staffing;
Concern: Declining levels of experienced personnel;
Explanation/ impact: Reduces the number of qualified staff available to
supervise, provide on-the-job training, and conduct necessary
operations.
Category: Staffing;
Concern: Shortened tours of duty (high personnel turnover);
Explanation/impact: Exacerbates the impact of personnel shortages and
lack of senior personnel for on-the-job training and supervision.
Category: Staffing;
Concern: Inadequate mix of positions, skills, and expertise across
stations;
Explanation/impact: Affects mission performance.
Category: Staffing;
Concern: Positions filled with uncertified or inexperienced personnel;
Explanation/impact: Increases workweek hours and affects mission
performance.
Category: Staffing;
Concern: Insufficient number of qualified surfmen;
Explanation/impact: Increases workweek for crew and command cadre.
Category: Training;
Concern: Lack of formal entry-level training for boatswain's mates;
Explanation/impact: Increases the training burden for senior station
personnel; Results in nonstandard training techniques and knowledge
gaps among personnel.
Category: Training;
Concern: Lack of standardized training in boat operations;
Explanation/ impact: Increases the number of boat mishaps and training
burden for senior station personnel.
Category: Boats;
Concern: Nonstandard boats;
Explanation/impact: Contributes to boat mishap rates (in part because
of lack of adequate training).
Category: Boats;
Concern: Aging boats[A];
Explanation/impact: Reduces operational and maintenance effectiveness.
Category: Boats;
Concern: Boats failing to meet operational inspection standards;
Explanation/impact: Reduces mission capability.
Category: Personal protection equipment;
Concern: Shortage of adequate equipment;
Explanation/impact: Reduces crew safety during search and rescue
missions.
Source: OIG, U.S. Coast Guard, and U.S. Senate Committee on
Appropriations.
[A] Boats nearing the end of their service life.
[End of table]
Added Security Responsibilities Had Impact on Readiness Needs but
Extent of Impact Unknown:
Added security responsibilities after the September 11 attacks had a
definite--but as yet unmeasured--impact on stations' readiness needs.
Stations have seen a substantial increase in their security workload,
along with a shifting of activity levels in other missions. The effect
of these changes on readiness needs is still largely undetermined,
mainly because the Coast Guard has not yet translated the security-
related mission responsibilities into specific staffing standards and
other requirements. Until it does so, the impact of increased
responsibilities on readiness cannot be determined nor can the Coast
Guard or others measure progress made in meeting station needs. With
the support of state and local entities, stations and other units
appear to be meeting the majority of port security responsibilities
identified in the Coast Guard's interim guidelines.
Stations Have Increased Operations to Address Homeland Security
Responsibilities:
After September 11, the Coast Guard's multimission stations experienced
a substantial rise in overall activity levels. Following the attacks,
the Coast Guard elevated the priority of the homeland security program
to a level commensurate with search and rescue, and according to field
and headquarters officials, stations were assigned the brunt of the
Coast Guard's port security responsibilities. These responsibilities
led to considerable increases in the stations' security workloads. One
way to see this change is in the number of hours that station boats
were operated before and after September 11. Station boat hours
increased by 44 percent from a level of about 217,000 hours prior to
the terrorist attacks to more than 300,000 hours by the end of fiscal
year 2004 (see fig. 1). [Footnote 17] Coast Guard officials explained
that increases in boat hours were due to increased homeland security
responsibilities and the 160 additional boats and personnel stations
received from fiscal years 2002 to 2004.[Footnote 18]
Figure 1: Total Boat Hours for All Station Programs, Pre-September 11
Baseline through 2004:
[See PDF for image]
Note: Data for "Pre-9/11 baseline" represents a 2-year average of boat
hours expended in fiscal years 1999 and 2000.
[End of figure]
While total boat hours for stations increased following September 11,
the trend among specific programs varied greatly, with some programs
experiencing substantial increases and others experiencing declines
(see fig. 2). Most notably, boat hours for the PWCS program increased
by almost 1,900 percent between pre-September 11 levels and fiscal year
2004. Coast Guard officials attributed the increases in PWCS hours to
(1) stations' expanded homeland security responsibilities, (2) several
elevations in the Maritime Security Condition (MARSEC) after
2001,[Footnote 19] and (3) acquisition of new boats and additional
personnel stations received in fiscal years 2002 through 2004.
Conversely, during the same period, hours dedicated to nonhomeland
security programs decreased. For example, boat hours expended for
search and rescue decreased by 15 percent, while hours for living
marine resources decreased by 61 percent.
Figure 2: Boat Hours for Selected Programs, Pre-September 11 Baseline
through 2004:
[See PDF for image]
Note: Data for "Pre-September 11 Baseline" represents a 2-year average
of boat hours expended in fiscal years 1999 and 2000.
[End of figure]
Similar trends emerge in the limited data available about how Coast
Guard personnel spend their time at stations. While the Coast Guard
does not formally track the number of work hours station personnel
spend on each program (either when operating a boat or while at the
station), it does administer a survey each year to personnel at
selected stations, asking them to estimate how they spent their time
over an average week or week period in August.[Footnote 20] Survey
results indicated that the number of hours spent on PWCS activities
increased for those responding by about 29 percent between calendar
years 2002 and 2003, while the number of hours spent on search and
rescue activities decreased by about 12 percent.
Coast Guard officials told us that although the stations' workload has
increased since September 11, mission performance has not suffered.
This does not mean that they believe stations' readiness needs were not
affected by the increase in operations, only that stations have been
able to sustain expected performance despite increased workloads.
Officials responsible for overseeing operations at the stations we
contacted explained that stations have been able to sustain performance
levels by achieving greater efficiencies in operations, specifically by
(1) conducting multiple missions during port security operations and
(2) coordinating their efforts with state and local organizations. They
also noted that stations have received additional boats and personnel
since September 11. It is likely that other factors also play a role in
this issue. Our prior work on the Coast Guard's overall use of
resources suggests an additional possible factor, such as decreases in
search and rescue responsibilities over time.[Footnote 21] This work
also showed that even in those program areas in which the number of
boat hours declined following September 11, the Coast Guard was
generally able to meet performance goals.
Effect of Homeland Security Responsibilities on Readiness Needs Not Yet
Known:
The Coast Guard has not yet determined the extent to which changes in
post-September 11 mission priorities--specifically, increases in
homeland security responsibilities--have affected station readiness
needs. Coast Guard officials told us there are two reasons for this.
First, the Coast Guard's maritime homeland security requirements are
being revised to better align with current resource levels. The Coast
Guard is currently working under Operation Neptune Shield, an interim
set of guidelines that establishes Coast Guard's homeland security
activity levels--taskings--under each MARSEC level. However, because
the guidelines call for a level of operations that exceeds the Coast
Guard's current resource levels, the Coast Guard is in the process of
revising the guidelines. Officials told us they expect the new, long-
term, risk-based requirements to establish more realistic activity
levels that better align with existing resources and take into account
support from state and local organizations at strategic ports.[Footnote
22] Officials told us they expect to have new activity level standards
finalized by February 2005. Under these new standards--requirements--it
is possible that station workload levels may change. Officials also
told us that although the new requirements, known as the Strategic
Deployment Plan, will better align security operations with existing
resources, the Coast Guard will need to monitor this balance in the
future given the dynamic nature of homeland security issues.
Second, because homeland security requirements have yet to be
finalized, the Coast Guard has begun, but not yet completed, efforts to
update station staffing standards and other requirements to reflect
post-September 11 changes in mission priorities and station readiness
needs. Officials told us that once homeland security requirements have
been finalized under the Strategic Deployment Plan, they will revise
station staffing standards and other requirements to better reflect
readiness needs. Although station staffing levels have been increased
in response to the new homeland security priorities and past reports of
staffing readiness concerns, the staffing standards are still based
upon pre-September 11 mission priorities (i.e., search and rescue
operational levels). Until the Coast Guard can translate the impact of
security-related activities into specific station requirements, the
impact of the new homeland security responsibilities on station
readiness needs cannot be determined. Furthermore, without specific
requirements, neither the Coast Guard nor others can measure the
progress made in meeting station readiness needs.
With Assistance from Other Entities, Most Stations Can Perform Expected
Port Security Operations:
While the impact of new responsibilities on overall readiness needs
remains unknown, there is evidence that most stations have been able to
meet the port security responsibilities--i.e., activity levels--
expected of them given their available resources and, in some cases,
all security responsibilities with the help of other entities. Since
the level of security activities established under the interim
guidelines exceeds available resources, the Coast Guard has
communicated to stations and other units that they are expected to
carry out security operations within the constraints of existing
resources.[Footnote 23] The Coast Guard does not track station-specific
performance regarding port security responsibilities, but in 2003 it
developed an unofficial evaluation system that indicates that current
security responsibilities for major ports--for which stations bear
significant responsibility--are largely being met. This evaluation
system--referred to as the Scorecard system--captures activity levels
for selected PWCS standards at ports of high military and economic
significance.[Footnote 24] However, it is important to note that the
Scorecard results are not station-specific in that (1) they do not
separate tasks handled by stations from those of other entities (either
Coast Guard or other) that address port security needs and (2) stations
that do not contribute to port security are not included. Nonetheless,
the Scorecard results do provide some indication that at least some
stations are for the most part able to meet their current port security
responsibilities. Furthermore, of the 16 stations we reviewed,
officials from all but 1 told us that PWCS responsibilities--as
identified by the interim guidelines--were being met. In most
instances, stations reported meeting PWCS responsibilities with the
assistance of state and local entities, which were either directly
performing PWCS tasks or performing other mission responsibilities--
such as fisheries enforcement or search and rescue--that allowed
station personnel to focus on PWCS responsibilities.
There are also clear signs that partnerships with other agencies and
other Coast Guard units play an essential role in the stations' ability
to meet assigned homeland security tasks. Most of the officials
responsible for overseeing operations at the 16 stations we reviewed
told us that their stations have been able to meet increased
operational responsibilities only by sharing overall tasks--
nonhomeland security-related as well as homeland security-related--
with state and local partners as well as other Coast Guard entities.
Officials explained that they have developed two main types of
partnerships. First, they have established partnerships with local
organizations such as police, fire, and marine patrol units to conduct
port security operations as well as nonhomeland security activities.
Officials at the majority of stations we contacted told us that they
rely on assistance from marine patrol units to conduct patrols of key
infrastructure, such as harbor docks; officials from several stations
also indicated that these units assist with vessel escorts. Officials
also told us that stations rely on partner organizations to conduct
nonhomeland security activities, such as search and rescue, and that
expanded partnership efforts have resulted in operational efficiencies.
For example, officials representing one station located at a major port
told us that a local partner increased its search and rescue operations
following September 11, allowing the Coast Guard station to focus more
of its efforts on homeland security operations.
Second, stations have relied on varying levels of support from other
Coast Guard components, namely, Marine Safety Offices (MSO)[Footnote
25] and Maritime Safety and Security Teams (MSSTs),[Footnote 26] to
conduct port security operations. Station officials we interviewed told
us that the level of support provided by both components varied. For
example, MSST support varied by geographic location. One official told
us that certain MSSTs located on the Pacific Coast each set aside 5,000
hours a year to perform port security operations, while those on the
East Coast do not. Headquarters officials told us that because the
Coast Guard is still considering the role MSSTs will play in port
security operations, the amount of support they provide to stations
will vary. One senior headquarters official told us that newly
established MSSTs can generally provide only a limited amount of
support because of initial training requirements. As the MSSTs mature,
they are usually able to assume greater responsibilities for port
security operations.
While stations' efforts to leverage external support are commendable,
the extent to which they can continue to rely on that support is
unclear. To better understand the potential for support levels to
change, we contacted a number of state and local organizations that
partner with the stations we interviewed. We asked them if they
expected their level of support would change in the future. Of the 13
organizations we contacted, officials from 12 organizations told us
that since the September 11 attacks, they have either directly
increased port security operations or increased other operations--such
as search and rescue--that enable Coast Guard stations to focus on port
security and other missions. One of the organizations we contacted
explained that they had plans to decrease resource levels allocated to
port security in future years. In addition, another 6 organizations we
contacted emphasized that while they did not have plans in place to
reduce funding levels for port security, they were not confident that
future funding would continue at current levels.
Progress Made in Addressing Readiness Concerns but Stations Are Still
Unable to Meet Standards and Goals:
The Coast Guard has made progress in addressing multimission station
readiness concerns identified prior to September 11. The Coast Guard
has increased station staffing levels by 25 percent, expanded formal
training programs and increased training capacity, begun modernizing
its small boat fleet, and as of fiscal year 2003 appeared to have
provided station personnel with appropriate amounts of PPE. However,
despite this progress, the Coast Guard has yet to meet existing
readiness standards and goals in the areas of staffing and boats and
does not have adequate processes in place to help ensure the future
funding of station PPE, a shortcoming that could result in an
insufficient supply of PPE at stations in future years.
Station Staffing Levels Have Increased but Key Staffing Standards and
Goals Have Not Yet Been Met:
Since 2001, the Coast Guard has developed a variety of initiatives
aimed at resolving long-standing staffing concerns at multimission
stations. Table 4 presents a selection of the initiatives, either
planned or under way, that we identified as noteworthy in addressing
station staffing needs. (App. II contains a more detailed description
of the initiatives.)
Table 4: Examples of Coast Guard Efforts to Address Station Staffing
Needs:
Concern: A shortage of personnel;
Initiatives undertaken to address concerns:
Staffing levels increased:
* In fiscal years 2002 and 2003, the number of personnel assigned to
stations increased by 1,109 active duty personnel, or 25 percent;
* An additional 451 personnel were added in fiscal year 2004 for
stations and command centers;
* According to one senior official, no additional personnel will be
assigned to stations in fiscal year 2005.
Initiatives undertaken to address concerns:
Number of authorized positions increased;
* In fiscal years 2002 and 2003, the number of full-time positions at
stations increased by 482;
* An additional 317 positions were added in fiscal year 2004;
* According to one senior official, no additional positions will be
added to stations in fiscal year 2005.
Concern: Declining levels of experienced personnel;
Initiatives undertaken to address concerns:
New direct retention initiatives initiated:
* In fiscal year 2003, $5.9 million was expended on 312 selective
reenlistment bonuses to station boatswain's mates and machinists;
* Between fiscal years 2003 and 2004, the surfman pay premium was
increased by 33 percent.
Concern: Shortened tours of duty (high personnel turnover);
Initiatives undertaken to address concerns:
Assignment practices modified:
* New personnel assignment practices are being implemented to allow for
increased tour lengths for surfman-qualified personnel and to reduce
turnover in all personnel assignments.
Concern: Inadequate mix of skills, expertise, and positions across
stations;
Initiatives undertaken to address concerns:
Staffing mix being reconfigured:
* In fiscal year 2001, an occupation (rating) review was concluded;
* Reconfiguring of station staffing standard is expected to begin in
2005.
Initiatives undertaken to address concerns:
Number of specialized and senior positions increased:
* In fiscal years 2002-2004, 99 support positions were added (with 19
more needed);
* In fiscal years 2002 and 2003, 486 senior petty officer positions
were added.[A].
Concern: Positions filled with uncertified or inexperienced personnel;
Initiatives undertaken to address concerns:
Assignment and incentive systems being revised:
* Plans are under way to (1) establish officer and enlisted career
paths, (2) base station assignments on position requirements and
personnel experience, and (3) develop motivation and incentive systems
for enlisted personnel.
Source: U.S. Coast Guard.
[A] Senior personnel are considered to be petty officer 2nd class
(grade E-5) and above.
[End of table]
In addition to increasing the number of personnel and positions
allotted to stations by 25 and 12 percent,[Footnote 27] respectively,
the Coast Guard has begun to reconfigure aspects of the station
staffing program to provide more effective operations. For example, in
an effort to provide a more appropriate mix of positions and skills at
stations and to address concerns about insufficient numbers of senior
personnel, the Coast Guard added 99 support officer positions in fiscal
years 2002 through 2004, and 486 senior petty officer positions in
fiscal years 2002 and 2003. According to one official, the additional
support positions will allow station command cadre to spend less time
on administrative work and more time on operations. Recognizing that in
the past a significant number of positions had been initially filled
with unqualified personnel, the Coast Guard plans to take steps to base
assignments on position requirements and experience. Furthermore, once
long-term homeland security responsibilities have been determined, the
Coast Guard plans to complete steps it has already begun to reconfigure
its station staffing standards, which define the number and type of
positions at stations based on mission requirements. The
reconfiguration is expected to better align staffing resources with
mission activities. Despite this progress, the Coast Guard has yet to
meet five key standards and goals related to staffing at the stations.
Each is discussed below.
Adherence to Workweek Standards:
Most notably, despite increases in station staffing levels over the
past 2 years and other actions, average station workweek hours continue
to exceed, by significant levels, the 68-hour standard established by
the Coast Guard in 1988 to limit fatigue and stress among station
personnel.[Footnote 28] According to the Coast Guard's Boat Forces
Strategic Plan, excessive workweek hours is symptomatic of "the adverse
operational trends, identified lack of resources, and general reduction
in —readiness" experienced by stations in recent years.[Footnote 29]
Moreover, the plan also notes that the high number of stations working
in excess of 68 hours shows that "staffing continues to be a
significant problem at stations." According to estimates from Coast
Guard surveys of station personnel, although the average work week at
stations decreased somewhat between 1998 and 2003, since 1994 it has
not dropped below 81 hours per week.[Footnote 30] It should be noted
that these survey data, although the best source of information
available on station workweek hours, may have limitations. That is, the
survey is administered every August--during both the peak search and
rescue season and the Coast Guard's period for rotating personnel--and
it may be that a year-round average, which would include off-peak,
winter hours, would be lower. In addition, although response rates for
every year were not readily available, the 2003 response rate was
relatively low, with only a little over half of the personnel surveyed
responding.[Footnote 31]
An explanation of how workweek hours are measured may be helpful in
interpreting this workweek information. The way in which the workweek
is measured at stations is similar to the way it is measured in
professions such as firefighting, in that personnel are on duty for an
extended amount of time--such as 24 hours--to respond to emergencies
but may spend part of it in recreation, sleep, exercise, training, or
other activities. Personnel can thus be on duty or off duty for
consecutive periods of time during a week. Workweek hours are
calculated by totaling the amount of hours spent on duty or at a
station, over a 1-week period, or averaging the amount of time spent on
duty over a 2-week period. The Coast Guard's 2003 survey of stations
indicated that slightly less than half of all respondents reported
working either an average 77-or 84-hour workweek. Approximately 6
percent of respondents reported working a 68-hour workweek. (See app.
II for more information regarding these results.)
According to the Coast Guard, working excessively long hours leads to
injury and illness.[Footnote 32] Officials told us that station
personnel can exceed the 68-hour work week standard in one of two
ways.[Footnote 33] First, they can be assigned to a work schedule that
averages to more than 68 hours a week, such as an 84-hour schedule. The
work schedule, which is determined by the officer-in-charge, defines
the number of days personnel spend on duty and is therefore the primary
driver of whether personnel will consistently work an average of 68
hours per week or some number above that amount.[Footnote 34] There are
advantages and disadvantages associated with each of the many possible
schedules stations can adopt--table 5 shows a comparison of the 68-and
84-hour work schedules. For example, a potential disadvantage to having
personnel work the 68-hour schedule is that it requires stations to
retain more qualified personnel for duty work than the 84-hour
schedule, which could be one reason why officers-in-charge who are
short of qualified personnel would use the higher hour schedule. The
84-hour schedule, in contrast, requires smaller numbers of qualified
personnel, which could be of benefit to stations with high workloads
and too few qualified personnel. It could also be preferred by some
personnel because it provides for 3-day weekends. However, a
significant disadvantage to the 84-hour schedule, as noted in the
station operations and training manual,[Footnote 35] is that it puts
personnel "at significant risk of exceeding fatigue standards," which
is why it is normally restricted to stations with low numbers of
response-driven cases. In other words, personnel at stations that have
a greater number of response operations--such as rescue cases--are at a
higher risk of exceeding fatigue standards because they are underway
(that is, operating a boat) more often. The Coast Guard's 1991 staffing
study found that long hours on duty resulted in lost time among
personnel because of illness and injury, as well as increased attrition
levels.[Footnote 36] According to officials, in the late 1990s the
Coast Guard switched from an 84-hour standard--which it had adopted to
better meet significant staffing shortages--to the present 68-hour
standard because of concerns about crew fatigue and an increasing
number of boat accidents.
Table 5: Comparison of the 68-and 84-Hour Workweek Schedules:
68-hour workweek: Workweek is divided into duty work, nonduty work, and
off-duty hours.[A];
Average 84-hour workweek: Workweek is divided into duty work and off-
duty hours.[B].
68-hour workweek: Crew accomplish training and maintenance tasks during
nonduty work hours;
Average 84-hour workweek: Crews perform all work--mission-and
nonmission-related--during duty hours.
68-hour workweek: Does not provide for 3-day weekends;
Average 84-hour workweek: Provides for two 3-day weekends each month.
68-hour workweek: Reduces unproductive work time (that is, time spent
eating and sleeping);
Average 84-hour workweek: Since crews are at the station for longer
periods of time, they spend more time eating and sleeping.
68-hour workweek: Reduces the potential for crew on duty to exceed
fatigue standards;
Average 84-hour workweek: Crews are at significant risk of exceeding
fatigue standards. Therefore, this work schedule is normally restricted
to stations that do not have high numbers of response-driven cases
(higher numbers of such cases increase the likelihood that crew members
will become overly fatigued).
68-hour workweek: Requires more qualified personnel because each person
spends less time in duty status;
Average 84-hour workweek: Requires fewer qualified personnel because
each person spends more time in duty status.
Source: GAO analysis of U.S. Coast Guard data.
[A] Personnel who are in "duty" status must remain at a station--
usually for 24 hours or longer--and be available to perform mission
requirements and operations. Depending on the schedule, personnel can
also perform "nonduty" work (called "day work"), which consists of any
work other than watchstanding, certain administrative and personal
tasks, and unit training. Personnel in nonduty status usually spend a
limited number of hours--a normal workday--at the station. While on
duty or nonduty status, personnel can perform watchstanding, which is
the performance of certain operational tasks that require personnel to
be at specific places for specified amounts of times (e.g.,
communications, security). Personnel standing watch may, depending on
the nature of the watch, also perform collateral tasks.
[B] Under this schedule, crew members work 120 hours during 1 week (2
days on duty, 2 days off, and 3 days on) and 48 hours the next (2 days
off duty, 2 days on, 3 days off). Over a 2-week period, the crew
average 84 hours on duty and 84 hours off duty a week.
[End of table]
A second way personnel can exceed the 68-hour schedule is by working
overtime, which, if significant, can also lead to lost time due to
illness and injury. Overtime generally occurs when required operations
exceed the number of qualified, available personnel. As with the 84-
hour work schedule, significant amounts of overtime can increase the
likelihood that personnel will exceed Coast Guard fatigue standards and
can lead to lower retention levels for trained personnel.
Field and headquarters officials told us that at most stations, the
high number of hours worked is being driven by the following factors:
* an increase in homeland security responsibilities;
* an increase in the number of inexperienced personnel;
* the formation of MSSTs, which siphoned experienced and qualified
crewmembers from stations; and:
* a lack of sufficient support for training, building and equipment
maintenance, and administrative duties.
Of these factors, the primary one is the increased homeland security
role. One senior official told us that although increased staffing
levels may have been sufficient to meet pre-September 11 mission needs,
the homeland security mission has greatly expanded the stations'
workload, and it is unknown whether current staffing levels will be
sufficient to meet operational requirements as well as the 68-hour work
week standard. According to senior Coast Guard officials, it may take 5
to 10 years before the 68-hour standard is attained at all stations
because of the high levels of inexperienced personnel and other issues
previously discussed. In fact, one senior official questioned whether
stations will ever reach the goal given competing Coast Guard
priorities.[Footnote 37] Officials told us that the Coast Guard will
not be able to determine optimum station staffing levels until (1)
long-term homeland security requirements have been identified,
(2) inexperienced staff have grown into senior positions,[Footnote 38]
and (3) all new staffing initiatives (such as increased administrative
support) have taken effect. Until these issues have been addressed,
officials said it is likely that stations with high workloads and
resource constraints will continue to work longer work weeks.
Appropriate Mix of Junior and Senior Personnel:
The Office of Boat Forces' targeted goal for senior personnel, as a
percentage of total station personnel, is 50 percent;[Footnote 39] as
of March 2004, senior staff comprised about 37 percent of total staff.
Officials told us that in recent years stations have received a
significant number of relatively inexperienced personnel, which has
skewed staffing proportions, and that it will take at least 3 years to
increase the number of senior personnel to desired levels.
Adherence to Full Assignment Length:
The Coast Guard has yet to meet its goal of an average 48-month station
assignment (tour of duty) for experienced personnel.[Footnote 40]
According to Coast Guard data, the average tour of duty length for
boatswain's mates increased from 33 months in 1999 to 35 months in
2000, but has remained fairly constant between 35 and 36 months through
2003.[Footnote 41] Although assignment practices have been modified for
some personnel to allow for longer tour lengths at stations, officials
told us that meeting the 48-month goal will be a challenge given that
stations draw upon a pool of personnel they share with other units--
such as ships--that generally require shorter tours of duty.[Footnote
42] Thus, significant changes to station assignment policies will
affect these other units. One senior official told us that although the
stations may not meet the 48-month goal in the foreseeable future,
given competing personnel needs from other units, even extending the
average tour length to 36 months would be a significant improvement.
Increasing the tour length lessens the training burden on senior
station personnel (i.e., they end up training fewer new personnel) and
allows a station to reap the benefits of the training it has already
invested in junior personnel.[Footnote 43]
Sufficient Levels of Qualified Surfmen:
Stations continue to experience a shortage of qualified surfmen. As of
June 2004, approximately 42 percent of surfman positions were not
filled with qualified personnel. According to training and program
officials, in the past this shortage stemmed from difficulties in
recruiting sufficient numbers of applicants, because of several
factors: (1) a long training process of 3 to 6 years (deters potential
applicants); [Footnote 44] (2) higher workloads (because of the
shortage of qualified personnel); (3) remote assignment locations
(surfman stations are largely located in remote areas of the
Northwest); (4) obstacles to promotion (promotion to senior enlisted
ranks requires a year of sea duty, which surfmen, who are needed at
stations, have difficulty obtaining); and (5) program challenges (make
it difficult to retain bonus pay benefits).
To address these challenges, the Coast Guard has revised relevant
personnel policies to facilitate career advancement and to clarify the
process for becoming a surfman. The Coast Guard has also revamped the
surfman training program by developing courses that that address
training needs. Regarding the former, the Coast Guard has (1) eased
requirements for advancement (waived the requirement for 1 year of sea
duty for promotion to senior positions) and (2) allowed surfmen to
retain special pay status after they transfer to a new station and are
in the process of certifying for their new area of operation.[Footnote
45] Beginning in May 2005, surfmen will also receive additional points
on their service-wide exams, the scores of which are used to determine
promotions. Regarding training, the Coast Guard has concentrated on a
two-pronged approach. First, to increase the number of trainees who
actually qualify as surfmen, in 2004 the Coast Guard implemented a new
2-year intensive training program that will require trainees to reside
at the surfman training center; this will allow trainees to concentrate
more fully on the training process. Officials told us they would not
know the impact of this new training initiative until 2006, when the
first class of resident trainees graduates. Second, to improve formal
training for personnel who are qualifying through on-the-job training
at their stations, in November 2004, the Coast Guard implemented a new
2-week surfman course. Because the course was designed in part to
relieve the training burden on stations (which are short of qualified
surfmen who can serve as instructors), trainees will complete most of
their qualification requirements during training. Officials expected 18
students to take the course during the winter of 2004.
Matching Number of Personnel with Number of Positions:
The Coast Guard has not met its goal of aligning the number of
individuals assigned to stations with the number of designated
positions, making it unclear whether station staffing levels
(individuals assigned to stations), which are currently greater than
designated positions, will remain at current levels or decrease,
potentially affecting station workweek hours and other issues.[Footnote
46] At the end of fiscal year 2004, the estimated number of personnel
assigned to stations exceeded the number of Coast Guard-designated
positions by an estimated 1,019 (or about 17 percent of total estimated
personnel assigned to stations).[Footnote 47] Because the 1,019
personnel are not assigned to permanent positions, and thus their
assignment is potentially more temporary than that of other personnel,
the Coast Guard could not assure us that the estimated fiscal year 2004
station staffing level of 5,925 personnel will be maintained in the
future.[Footnote 48] In contrast, the number of designated positions--
4,906 at the end of fiscal year 2004--is considered permanent.
Officials told us that although the Coast Guard's goal is to align
personnel and position levels, it has been necessary to assign a
greater number of less experienced staff to the stations, above
designated staffing levels, to develop required numbers of senior staff
(officials estimate it takes three junior personnel to produce one
senior crew member). Attrition patterns, limited space on ships, and
the need to expose junior personnel to on-the-job-training are driving
factors in this decision. The Coast Guard does not plan to add either
additional personnel or positions to stations in fiscal year 2005;
rather, it will use this time to evaluate current station resource
levels and give junior personnel time to gain experience and become
fully trained. It is unclear how this decision may affect staffing
levels--if staffing levels drop, the number of hours station personnel
work might increase. On the other hand, if lower staffing levels are
accompanied by higher levels of experienced personnel, then workweek
hours might be unaffected or even decline. The impact will also depend
in part on other factors, such as the implementation of remaining
staffing initiatives--such as the station staffing standards--and the
nature of future homeland security responsibilities.
Coast Guard Has Formalized the Majority of Its Training and Taken Steps
to Increase Training Capacity at National Training Centers:
Since 2001, the Coast Guard has made progress in developing a more
formalized training program and in expanding the number of training
slots available for the majority of station occupations. As late as
August 2003, when we began our work, the Coast Guard had yet to
determine whether formal training delivered in a classroom environment
was preferable to on-the-job training--administered by senior personnel
at stations--or whether it should utilize a combination of both on a
long-term basis. Subsequently, the Coast Guard identified formal
training as its preferred training method because, according to
officials, it provides greater accountability for consistent and
uniform training across all occupations and stations.[Footnote 49] To
date, the Coast Guard has taken steps to formalize or augment several
aspects of station training, including boatswain's mate and boat driver
training. With respect to boatswain's mate training, in fiscal year
2002 the Coast Guard instituted a formal training center with the
capacity to train 120 trainees per year; during fiscal year 2003 it
more than tripled the center's capacity to 450 training slots. Training
officials told us they plan to further expand the capacity of the
center each year through 2006, when its annual capacity is expected to
reach 1,000 slots, the estimated number of new boatswain's mates needed
each year. Furthermore, in conjunction with efforts to modernize its
boat fleet, in fiscal year 2003 the Coast Guard increased the amount of
formal training available to boat drivers who were learning to operate
new response boats and nonstandard boats. Training officials told us
that they employed a two-pronged approach to train operators on the new
boats using on-site training teams, which conduct training at the
stations, and a new 2-week national training center course. Table 6
provides additional information regarding the Coast Guard's initiatives
to address training needs. (See app. II for a more detailed discussion
of the Coast Guard's planned and ongoing initiatives regarding station
training needs.)
Table 6: Examples of Coast Guard Efforts to Address Station Training
Needs:
Need: Boatswain's mate training;
Initiatives undertaken to address concerns: Boatswain's mate training
center reinstituted;
* The boatswain's mate training center was reinstituted in fiscal year
2002;
boatswain's mates' trainee positions were increased from 120 in fiscal
year 2002 to 450 in fiscal year 2003;
* Four additional classrooms and 51 personnel were added at the
training center in fiscal years 2003 and 2004, at a cost of $3.5
million, to meet training throughput goals;
Training center to augment on-the-job training established;
* A provisional training center was established in fiscal year 2003 to
augment station on-the-job training.[A].
Need: Coxswain (boat driver) training;
Initiatives undertaken to address concerns: On-site response boat
training developed;
* Training teams were established to provide on-site training to
station personnel in boat handling techniques;
Boat driving course established;
* In fiscal year 2004, a 2-week training course on driving, law
enforcement, and boat operations was implemented.
Need: Surfman training;
Initiatives undertaken to address concerns: Efforts to expedite surfman
training initiated;
* A 2-year training program was instituted in fiscal year 2004 to
accelerate the surfman training process for 10 surfman trainees;
New surfman training course established;
* A new surfman training course was established in fiscal year 2004 to
provide intensive training in heavy weather conditions.
Need: Boarding officer and boarding team member training;
Initiatives undertaken to address concerns: Formal law enforcement
training expanded;
* Efforts were initiated to increase training slots for boarding
officers and boarding team members by over one-fourth (between fiscal
years 2004 and 2005) by relocating maritime law enforcement training to
the Department of Homeland Security's Federal Law Enforcement Training
Center.[B].
Need: Evaluation of job performance;
Initiatives undertaken to address concerns: Written examinations
reconfigured;
* In 2004, to better assess knowledge levels regarding station
operations, written examinations that are administered to station
personnel biennially were revised.
Source: U.S. Coast Guard.
[A] This training center also provides training to boatswain's mates
assigned to cutters.
[B] The Federal Law Enforcement Training Center provides basic,
advanced, specialized, and refresher training for law enforcement
officers from 75 federal agencies. The Maritime Law Enforcement Center,
which provides boarding officer and boarding team member training to
all Coast Guard personnel, was relocated to increase capacity and to
develop training partnerships with other federal agencies.
[End of table]
According to officials, the Coast Guard's efforts to train boat drivers
were developed to address missions with greatest priority as well as
for training needs for new boats going into service. For example, in
2003 and 2004, training teams were deployed to all strategic ports to
provide training in tactical operations, an emerging requirement
following the attacks of September 11. In addition, to address safety
concerns associated with the operation of nonstandard boats, officials
told us that training efforts were targeted at stations that would
retain nonstandard boats, while the Coast Guard completes its program
to replace stations' nonstandard boats.
Progress Made in Modernizing Boat Fleet, but Inspection Results
Indicate Weaknesses in Boat Readiness:
Since 2001, the Coast Guard has made progress in restructuring the
stations' boat fleet to address safety and operational concerns
resulting from aging and nonstandard boats. The Coast Guard has focused
a major part of its efforts on replacing an assorted variety of
nonstandard small boats with new, standardized boats. Officials told us
that although the Coast Guard had just started planning the acquisition
of the new boats in 2001, following the attacks of September 11, it
expedited the purchase of 100 of the new boats to meet stations'
increased homeland security responsibilities. Approximately 50 of these
boats were distributed to stations located at strategic ports, to
provide quick response capabilities for port security operations, and
to stations in critical need of new boat replacement. The remaining 50
boats were distributed to MSSTs. In 2003, the Coast Guard developed a
multiyear contract to replace the remainder of stations' aging and
nonstandard boats with an estimated 350 new boats. The Coast Guard has
also initiated efforts to replace the aging 41-foot utility boat fleet,
which will reach the end of its 25-year service life beginning in 2005,
with a medium-size utility boat. Officials told us that as of August
2003 the Coast Guard was in the process of reviewing three medium boat
prototypes and that they expect to select a manufacturer in 2005. In
addition, in 2003, the Coast Guard completed the replacement of the 30-
year old 44-foot motor lifeboat with a fleet of new 47-foot motor life
boats. Table 7 describes the Coast Guard's actions to address concerns
regarding the stations' boat fleet. (See app. II for a more detailed
discussion of ongoing and planned efforts for addressing station boat
needs.)
Table 7: Examples of Coast Guard Efforts to Address Station Boat Needs:
Need: Aging and nonstandard small boats[A];
Initiatives undertaken to address concerns: New small boats acquired to
address increased security responsibilities;
* One hundred small response boats were purchased following the attacks
of September 11 to augment security capability at strategic ports and
to replace nonstandard boats;
Multiyear contract to purchase small boats was developed;
* A contract was signed allowing for the purchase of up to an
additional 700 small response boats through fiscal year 2009 to replace
the remainder of the aging nonstandard boats and to supplement
stations' multimission response capability.
Need: Aging medium-sized boats;
Initiatives undertaken to address concerns: Efforts to replace medium
boats initiated;
* Efforts were initiated to replace 41-foot utility boats with a new
medium response boat;
$12 million was requested in its fiscal year 2005 budget to begin
production.[B].
Need: Inspection of small boats;
Initiatives undertaken to address concerns: Inspection teams for small
boats instituted;
* In fiscal year 2004 the Coast Guard instituted teams to inspect new
standardized small boats, at a cost of $637,000.
Source: U.S. Coast Guard.
[A] The Coast Guard expects to replace approximately 350 nonstandard
small boats in use at stations. Approximately 50 nonstandard boats used
by stations for unique geographic or weather-specific operational
requirements--such as 14-foot skiffs and 30-foot special purpose craft
boats--will be retained.
[B] The Coast Guard has determined that the 41-foot utility boat--
acquired between 1973 and 1980--is approaching the end of its service
life.
[End of table]
Despite this progress, the Coast Guard has yet to meet mission
readiness goals for medium-sized boats (utility and motor life boats),
as indicated by internal inspection results.[Footnote 50] The Office of
Boat Forces' goal is for 80 percent of boats inspected to meet
readiness standards at the initial inspection. Results from the Coast
Guard's fiscal year 2003 inspections indicate that only 16 percent of
the motor lifeboats and utility boats inspected met mission readiness
goals when initially inspected.[Footnote 51] After a 1-day opportunity
to correct identified problems, approximately 81 percent had met
readiness goals. It is important to note that the majority of the
discrepancies cited were not of such severity that they would prevent
the boats from being used in most mission operations. For example, the
failure of navigation lights on a 41-foot utility boat could preclude
the boat from being operated (i.e., disable it) until the lights were
fixed or the operational commander issued a waiver outlining the
conditions under which the boat could be operated. Boats that receive
waivers are considered able to "perform some missions, but not all
missions safely."[Footnote 52] In this scenario, the boat's failure to
meet full readiness standards would not necessarily affect the
station's operational readiness. Officials also told us that in order
to ensure that operational readiness is maintained at stations when a
boat is disabled, all multimission stations have more than one boat.
Officials attributed the inability of stations to meet full readiness
standards for boats to the following:
* Junior engineers did not have the necessary experience to perform
maintenance in compliance with operating manuals and configuration
updates from the manufacturer.
* Engineers lacked sufficient time to perform maintenance because of
increased operational hours (that is, the boats are being used more
often, and the engineers assigned to perform maintenance are spending
more time conducting boat operations).
* Station utility boats were reaching the end of their service life and
had deteriorated to the point that they required more maintenance to
meet mission readiness standards.
* New boats are more technologically advanced (e.g., satellite
navigation systems) requiring specialized technical training in order
to perform maintenance.
Officials told us that they are taking various steps to respond to
these issues. First, to compensate for the lack of experience among
junior engineers, the Coast Guard intends to intensify the training
that is provided to engineers for the motor lifeboat. In November 2004,
the Coast Guard implemented a 2-week course focused specifically on
motor lifeboat operations and maintenance. The Coast Guard does not
have plans, however, to provide specialized training for utility boat
maintenance, given that these boats are at the end of their life span
and will be replaced within a few years with new medium response boats.
Likewise, the replacement of the utility boats will address low scores
related to their deteriorating condition. Regarding the lack of time
engineers have to perform maintenance, officials told us that this
issue will be examined after the Coast Guard has reassessed changes in
station workloads following September 11.
Processes and Practices for Estimating PPE Funding Needs Result in
Allocation Shortfalls:
As of the end of fiscal year 2003, station personnel appeared to have
sufficient PPE, but the Coast Guard does not have adequate processes
and practices in place to help prevent funding shortfalls from
recurring. The Coast Guard's continued use of these processes and
practices in fiscal year 2004 resulted in a $1.9 million shortfall in
estimated PPE funding needs for that year. As we discussed in our
previous report,[Footnote 53] following the expenditure of an
additional $5.6 million on PPE in fiscal year 2003 to address perceived
shortfalls, active and reserve station personnel appeared to possess
sufficient PPE. However, the Coast Guard's processes and practices for
estimating station PPE needs and allocating funds have historically
resulted in an underfunding of station PPE, despite congressional
direction to provide adequate supplies of PPE.[Footnote 54] If these
funding practices are not modified, funding shortfalls could continue
to occur in the future. Moreover, such funding shortages would affect
the Coast Guard's ability to meet one of its strategic objectives for
stations--namely, to ensure that station personnel are properly
outfitted with mission-specific equipment, such as PPE.[Footnote 55] A
shortfall in estimated PPE funding needs of $1.9 million occurred in
fiscal year 2004, although the actual impact of the shortfall--in terms
of PPE that was needed but not purchased--is not known, since the
purchase of PPE is not tracked at the headquarters level. A shortfall
of $1.9 million is projected for fiscal year 2005.
Following a mishap in 2001 in which the improper use of PPE was found
to have contributed to the death of two station personnel, the adequacy
of PPE took on added importance.[Footnote 56] The Coast Guard has
emphasized the importance of PPE, both through a Commandant directive
and in its policy manual,[Footnote 57] stating that the proper supplies
and use of PPE is one of the top priorities of Coast Guard management.
Although these measures are important, several aspects of the Coast
Guard's processes for estimating and allocating station PPE funds raise
concerns. Appendix II discusses these concerns in detail, but they are
summarized as follows:
* The Coast Guard's forecasting models do not recognize PPE funding
needs for personnel assigned to stations over and above the number of
designated positions. This is because the forecasting models are
predicated on the number of positions designated for stations, rather
than the number of personnel assigned (in fiscal year 2004 the
estimated number of personnel assigned to stations exceeded positions
by an estimated 1,019). According to program officials, historically
the amount of funds allotted by the Coast Guard each fiscal year for
station PPE has not been sufficient to fund the estimated needs of all
assigned station personnel. For example, in 2003, the OIG reported that
the Coast Guard had not provided PPE funding for 541 (69 percent) of
the 789 personnel it had added to stations during fiscal year
2002.[Footnote 58]
* Even when funding is narrowed to just designated positions, the Coast
Guard's traditional practice has been to fund only about half of PPE
station needs, according to program officials.[Footnote 59] For
example, in fiscal year 2003, the Coast Guard initially allocated $1.8
million, or 56 percent, of the estimated $3.2 million needed to provide
PPE for personnel in designated station positions.[Footnote 60]
Stations also receive general operating funds that may be used to
purchase PPE, although these funds are also used for other purposes,
such as boat maintenance.
* Assumptions used in PPE forecasting models have not been validated,
according to officials.[Footnote 61] Without validated assumptions, the
Coast Guard could be either underestimating or overestimating the life
span and replacement cycle of the PPE. According to one official, the
assumptions were based on input from station personnel.
* The Coast Guard does not require that PPE funds allocated to stations
and oversight units actually be spent on PPE, according to program
officials. Officials told us that in the interests of command
flexibility units are allowed to spend allocated PPE funds on various
operational expenses. Although such flexibility may be needed, the
former PPE program manager told us that it was possible that oversight
units have not been passing PPE funds on to stations as intended (i.e.,
the amount expended for PPE may be less than the amount allocated). To
help address this possibility, the official said that in recent years
he has disclosed to stations the total amount of PPE funding available
to them, including funds held by oversight units.
Officials told us the Coast Guard has no immediate plans to revise the
traditional PPE funding allocation process because they believe it has
been sufficiently reliable for the agency's purposes. However, the
process may change once long-term homeland security requirements have
been identified. Given the historic shortages in PPE funding that have
resulted from the Coast Guard's allocation processes, as witnessed by
the onetime increase in funding during fiscal year 2003, it seems
likely that stations will experience shortfalls in the future if PPE
allocation processes and practices are not adjusted.
Strategic Plan for Improving Station Readiness Lacks Key Components for
Measuring Progress:
The Coast Guard Guard's Boat Forces Strategic Plan,[Footnote 62] its
10-year plan for maintaining and improving readiness at stations and
other boat units, lacks key components for achieving and assessing
station readiness in the post-September 11 operating environment. The
plan, although extensive, has not been updated to include the impact of
post-September 11 homeland security requirements on station operations.
The plan also does not identify the specific actions, milestones, and
funding amounts needed to assure Congress and others that the Coast
Guard is committed to achieving identified readiness levels. Moreover,
the Coast Guard has yet to develop measurable annual goals for stations
that would (1) allow it to track its progress in achieving long-term
goals and objectives, (2) allow others to effectively monitor and
measure progress, and (3) provide accountability. Without these key
planning elements, the strategic plan's effectiveness as a management
tool, as well as the Coast Guard's ability to ensure desired progress
in meeting station readiness needs, is limited.
Current Strategic Plan Outlines Numerous Goals, Objectives, and
Initiatives:
The Boat Forces Strategic Plan identifies strategic goals in four
areas: (1) leadership and management; (2) personnel and staffing; (3)
training and expertise; and (4) equipment, support, and technology.
These goals are supported by objectives and initiatives, the latter of
which are prioritized, by fiscal year, in a summary implementation
plan. Table 8 presents examples of goals, objectives, and initiatives,
as well as the targeted time frames, pertaining to each of the four
readiness categories (staffing, training, boats, and PPE). The
initiatives contained in the plan are designed to address station
readiness concerns identified in 2001. For example, to address the
concern that stations' have not received the appropriate number of
positions or qualified personnel, the plan contains an initiative to
revise station staffing standards as well as an initiative regarding
the need to staff stations according to these revised standards.
Table 8: Selected Examples of Coast Guard Strategic Goals, Objectives,
and Initiatives for Multimission Stations:
Category: Staffing;
Goals: Provide leadership to ensure effective boat operations;
Objectives: Ensure that tasking can be met by available resources;
Initiatives: Establish a mechanism that outlines intended capabilities
of resources provided to stations;
Fiscal year time frames: 2003.
Category: Staffing;
Goals: Ensure the right number of positions/ people, with appropriate
experience and skills;
Objectives: Ensure sufficient numbers of personnel--with appropriate
experience/skills--are assigned;
Initiatives: Revise station staffing standards; Staff stations
according to standards;
Fiscal year time frames: 2003; 2003-2007.
Category: Training;
Goals: Deliver new training in a standardized manner;
Objectives: Establish a system to provide appropriate operations
training;
Initiatives: Increase staffing and throughput at training centers;
Fiscal year time frames: 2003-2005.
Category: Training;
Goals: Deliver new training in a standardized manner;
Objectives: Ensure personnel receive training appropriate to each
mission;
Initiatives: Coordinate with training centers to provide mission-
specific training;
Fiscal year time frames: 2005.
Category: Boats;
Goals: Acquire and maintain capital assets, facilities, equipment, and
technology;
Objectives: Acquire capital assets (boats);
Initiatives: Recapitalize small and medium-sized boats;
Fiscal year time frames: 2003-2006.
Category: PPE;
Goals: Acquire and maintain capital assets, facilities, equipment, and
technology;
Objectives: Coordinate, enable, align, and monitor mission-specific
equipment to ensure appropriate outfitting;
Initiatives: Coordinate with program managers to fully fund mission-
specific equipment;
Fiscal year time frames: 2005, 2006, 2008, 2010, 2012.
Source: GAO analysis of U.S. Coast Guard data.
[End of table]
Lack of Key Planning Elements:
Although the strategic plan provides an indication of what overall
measures may be needed to restore station readiness, the Coast Guard
has not developed key planning elements in four areas--either
pertaining to the strategic plan or related to it--that are essential
to setting clear expectations about what will be achieved, and
translating the expectations into specific funding needs. In four key
areas, as discussed later, the Coast Guard does not follow practices
that we and others have identified as necessary to effectively measure
performance and hold agencies accountable for results.[Footnote 63]
* Plan not updated to reflect homeland security responsibilities: The
plan has not been updated to reflect the impact of post-September 11
homeland security requirements on stations. Although it incorporates
performance goals for other Coast Guard programs,[Footnote 64] the plan
does not incorporate--because they have yet to be finalized--goals and
requirements for the PWCS program, a major driver of station
operations.[Footnote 65] Until those requirements have been developed,
the capability and resources stations will need to address one of their
most significant operational responsibilities, and hence overall
readiness needs, cannot be fully determined. For example, the plan
cites two important initiatives in the category of staffing--(1) revise
station staffing standards (i.e., determine the optimal number and type
of personnel needed at each station) and (2) staff stations according
to those standards. According to the plan's implementation summary,
these standards were to be revised in fiscal year 2003 and station
staffing completed by fiscal year 2007. As of January 2005, officials
had yet to revise the standards because long-term homeland security
responsibilities had not been finalized. Until the staffing standards
have been revised, the bigger picture--when stations staffing needs
will be met--cannot be determined.
* Plan contains insufficient details on specific planned actions and
milestones: The plan does not identify, in sufficient detail, planned
actions and milestones.[Footnote 66] Effective strategic plans should
show an obvious link between objectives and the specific actions that
will be needed to meet those objectives. These actions, in turn, should
be clearly linked to milestones. Although the plan includes a summary
implementation schedule, it does not clearly identify what steps will
be taken to implement the initiatives and when they will be completed.
For example, the plan does not identify what actions will be needed to
ensure that station personnel are placed in positions that are
appropriate for their experience, or to increase the actual length of
time personnel are assigned to stations.
* Plan's objectives not linked with budget: The plan lacks a clear link
between objectives and required funding levels. Without a clear
understanding of the funding needed each year, there is little
assurance that initiatives will be implemented and long-term objectives
realized.[Footnote 67] Clearly identifying funding needs would also
help to ensure that projected goals and objectives are commensurate
with available resource levels.[Footnote 68] Because the plan does not
identify the funding needed to carry out key objectives and
initiatives, even in the short term, it is unclear whether the Coast
Guard will be able to fund initiatives according to proposed time
frames.
* Lack of measurable annual goals: The Coast Guard has not established
measurable annual goals linked to the long-term goals identified in the
strategic plan. Without annual goals, Congress, the Coast Guard, and
others cannot effectively and readily measure an agency's progress in
meeting its long-term goals.
The above planning elements would help the Coast Guard and Congress use
the strategic plan as a more effective tool for monitoring station
readiness needs and identifying areas of continuing concern. As with
any strategic plan, Coast Guard officials agree that it will also need
to be revisited and revised to keep pace with changing events and,
thus, the plan will be reviewed on an annual basis. The Coast Guard's
plan may be particularly susceptible to changing circumstances, given
that it must deal with so many unpredictable events, ranging from
natural disasters and accidents to the uncertainties of terrorist
threats. A senior headquarters official told us that while the Coast
Guard should more clearly identify expectations regarding annual goals,
continually changing priorities often make it difficult for the agency
to adhere to--and fund--long-term strategic plans and in some cases to
even maintain program consistency. We acknowledge that these
difficulties exist and must be considered in developing and using the
plan, but even with these difficulties, incorporating the key elements
discussed above would improve the plan's effectiveness as a management
tool.
Conclusions:
It has been 3 years since the September 11 terrorist attacks changed
the mission priorities for multimission stations, and there is no doubt
that station readiness requirements need to be updated to reflect this
new reality. The Coast Guard's decision to hold off updating these
requirements until they can be aligned with homeland security
responsibilities Coast Guard-wide is sensible. The readiness of
multimission stations is but one of the many competing demands the
Coast Guard must balance as it attempts to meet increased homeland
security responsibilities while continuing to support other missions.
Nonetheless, the Coast Guard still needs to have the necessary plans,
processes, and safeguards in place to help ensure that it can continue
the impressive progress made thus far in addressing 20 years of
operational deterioration at stations. In particular, indications of
high workweek hours for many personnel and inadequate processes and
practices used to estimate and fund needs for personal protection
equipment may limit the stations' readiness. Historic shortages in
station PPE funding allocations, which continued in fiscal years 2004
and are estimated for 2005, indicate that stations will continue to
experience funding shortfalls in the future unless PPE allocation
processes and practices are adjusted. Perhaps more significantly, it
remains unclear where station readiness falls in the Coast Guard's list
of priorities, as evidenced by a lack of measurable annual goals
related to stations and the lack of detail--in terms of both specific
actions as well as necessary funding--in the Boat Forces Strategic
Plan, the Coast Guard's strategy for addressing station readiness
issues. The lack of specificity on the Coast Guard's part thus far is
perhaps understandable given the challenges it has faced in the wake of
September 11. However, continuing in this way will make it difficult to
know what the Coast Guard intends as a readiness baseline, how close or
far away it is from achieving this level, and what it thinks will be
needed to get there.
Recommendations:
To help ensure that the Coast Guard and Congress have the information
necessary to effectively assess station readiness needs and track
progress in meeting those needs, and that multimission station
personnel receive sufficient personal protection equipment to perform
essential and hazardous missions as specified by Congress, we recommend
that the Secretary of Homeland Security, in consideration of any
revised homeland security requirements, direct the Commandant of the
Coast Guard to take the following three actions:
* Revise the Boat Forces Strategic Plan to (1) reflect the impact of
homeland security requirements on station needs and (2) identify
specific actions, milestones, and funding needs for meeting those
needs.
* Develop measurable annual goals for stations.
* Revise the processes and practices for estimating and allocating
station PPE funds to reliably identify annual funding needs and use
this information in making future funding decisions.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Department of Homeland
Security and the Coast Guard for their review and comment. The
Department of Homeland Security and the Coast Guard generally concurred
with our findings and recommendations and did not provide formal
comments for inclusion in the final report. The Coast Guard, however,
provided technical clarifications as well as suggested contextual
adjustments, which we incorporated to ensure the accuracy of the
report.
We are sending copies of this report to interested congressional
committees and subcommittees. We will also make copies available to
others on request.
If you or your staffs have any questions about this report, please
contact me at (415) 904-2200 or Steven N. Calvo at (206) 287-4839. Key
contributors to this report are listed in appendix III. This report
will also be available at no charge on GAO's Web site at http://
www.gao.gov.
Signed by:
Margaret T. Wrightson, Director,
Homeland Security and Justice Issues:
[End of section]
Appendix I: Scope and Methodology:
To examine the extent to which multimission station readiness needs
changed as a result of post-September 11 changes in mission priorities,
we reviewed relevant Coast Guard documents, including Operation Neptune
Shield, the agency's interim guidelines for implementing homeland
security operations; the Maritime Strategy for Homeland Security; and
mission planning guidance used to establish fiscal year 2004 mission
priorities. We also reviewed our previous work on the Coast Guard's
efforts to balance its homeland security and nonhomeland security
missions.[Footnote 69] In addition, we interviewed headquarters
officials regarding trends in station operations and the agency's plans
for addressing the homeland security mission. To better understand how
station performance was affected by changes in mission priorities, we
reviewed data from the Coast Guard's Scorecard System, its unofficial
process for monitoring security operations at strategic ports. We
interviewed officials responsible for analyzing and compiling these
data at the field and headquarters levels and determined that the data
were sufficiently reliable for the purposes of this report, given the
parameters of the system. We also reviewed boat hour data from the
Coast Guard's Abstract of Operations database to determine trends in
the number of hours station boats were operated, by program, both
before and after September 11. Boat hour data, reported by station
crews, represent the number of hours that boats were operated by
station personnel. To develop a more representative estimate of pre-
September 11 boat hours and to normalize for fluctuations in hours that
might occur in a single year, we averaged the number of boat hours
expended during fiscal years 1999 and 2000 to create a pre-September 11
baseline.[Footnote 70] The Coast Guard agreed with our use of this 2-
year average as an appropriate baseline of pre-September 11 boat hours.
To determine the reliability of the data, we used assessments from our
previous report,[Footnote 71] which consisted of (1) a review of
existing documentation regarding the data and the systems that produced
them and (2) interviews with knowledgeable agency officials. On the
basis of these assessments, we determined that the data were
sufficiently reliable for the purposes of this report.
We visited 8 multimission stations on the Pacific and Atlantic coasts,
as well as the four groups and activities responsible for overseeing
their operations, to better understand how stations' readiness needs
changed following September 11.[Footnote 72] These stations were
selected on the basis of geographic location, proximity to a strategic
port, and the number of boat hours expended in fiscal year 2003 on
homeland security, search and rescue, and law enforcement operations.
To further explore how increased homeland security operations had
affected stations, we conducted telephone interviews with field
officials responsible for overseeing operations at 8 additional
stations located at strategic ports. We selected these additional 8
stations based on the number of station resource hours expended on port
security operations. To assess the levels of support provided to
stations by state and local organizations, we contacted 13
organizations identified as key partners for 8 of the stations we
reviewed.
To address multimission station readiness concerns identified prior to
September 11, we reviewed the Department of Transportation's Office of
Inspector General (OIG) reports on station readiness,[Footnote 73] the
Coast Guard's internal review of station operations,[Footnote 74] and
various congressional reports. We also spoke with Coast Guard
headquarters officials from the Offices of Boat Forces; Budget and
Programs; and Workforce Performance, Training, and Development. To
identify actions the Coast Guard has taken or is planning to take
regarding station readiness concerns, we reviewed available Coast Guard
data regarding station staffing, training, boats, and personal
protection equipment (PPE). In the areas of staffing and PPE, we used
data from our May 2004 report--such as the number of staff and
positions added to stations in fiscal year 2003 and the estimated
amount of funds expended on station PPE in fiscal year 2003--which we
had determined were sufficiently reliable for reporting purposes. To
assess the reliability of training and boat data, we (1) reviewed
existing documentation regarding the data and how they were developed
and (2) interviewed knowledgeable agency officials. We determined that
the data were sufficiently reliable for the purposes of this report.
Furthermore, we interviewed officials responsible for overseeing
operations at the 16 stations we reviewed, as well as at relevant
oversight units. To review the Coast Guard's training programs and
identify progress made in expanding formal training opportunities for
station personnel, we visited the following Coast Guard training
centers: the Motor Life Boat School; the Boatswain's Mate School, the
Boat Forces Center, the Boat Engineering School; and the Maritime Law
Enforcement Center. In addition, we interviewed officials from the
Coast Guard's internal inspection teams to discuss biennial inspections
of station operations and reviewed station inspection results for
fiscal years 2002 and 2003.
To obtain a better understanding of personnel workloads and how those
workloads may be changing, we also reviewed fiscal years 2002 and 2003
survey results from the Coast Guard's annual survey of station
personnel activities. With some exceptions, the Coast Guard has
conducted an annual survey of station workweek hours since 1991. The
Coast Guard uses the survey results to gauge changes in the average
number of hours personnel work each week, and thus have not validated
the survey. Personnel are asked to report the number of hours spent
among 49 predefined activities during an average workweek in August. In
2003, personnel at 77 of the 188 stations were surveyed, with personnel
from 64 stations responding, for a total response rate of 54 percent of
all personnel surveyed. (Response rate data were not readily available
for other survey years.) One possible reason for this low response rate
may be that nonrespondents did not have time to complete the survey,
which could mean that workweek hours were under-reported. However, it
is also possible that personnel who were working longer hours per week
were more inclined to report that condition, leading to an over-
reporting of workweek hours. To assess the reliability of the data, we
interviewed the headquarters officials who oversee the survey as well
as available documentation. Recognizing the limitations of the data--
such as the low response rate--we determined that the data were
sufficiently reliable for the purposes of this report. That is, as an
indicator of average station workweek hours, and general trends in
those hours over time, the survey results are sufficiently reliable.
To assess the extent to which Coast Guard's plans address station
readiness needs, we reviewed the Coast Guard's Boat Forces Strategic
Plan, the agency's strategy for maintaining and improving essential
operations capabilities for all boat units, including multimission
stations. We also reviewed the Department of Transportation OIG's
assessment of the draft plan.[Footnote 75] To identify practices for
effectively measuring program performance, we reviewed the Government
Performance and Results Act (GPRA) of 1993,[Footnote 76] our prior work
on results-oriented management,[Footnote 77] and Office of Management
and Budget circulars.[Footnote 78]
We conducted our work between September 2003 and December 2004 in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: Actions Taken by Category to Meet Station Readiness Needs:
This appendix presents additional information regarding the four
categories of multimission station operations we reviewed--staffing,
training, boats, and PPE. The appendix also contains additional
information regarding the initiatives the Coast Guard has either
started or plans to develop to address concerns in each of these
categories.
Staffing:
The Coast Guard has initiated multiple efforts to address staffing
concerns at multimission stations. This section provides additional
information regarding Coast Guard (1) station survey results regarding
workweek hours and (2) initiatives to address staffing concerns.
Survey of Station Workweek Hours:
Approximately 44 percent of the individuals who responded to the Coast
Guard's 2003 station staffing survey indicated that they worked an
average workweek that was in excess of the 68-hour standard (see table
9).[Footnote 79] Approximately 6 percent of those questioned indicated
they worked a standard 68-hour work week.
Table 9: Workweek Results of August 2003 Station Survey:
Average workweek hours: 84;
Number of responses: 393;
Percent: 29.
Average workweek hours: 77;
Number of responses: 202;
Percent: 15.
Average workweek hours: 68;
Number of responses: 87;
Percent: 6.
Average workweek hours: Other[A];
Number of responses: 408;
Percent: 30.
Average workweek hours: Not applicable[B];
Number of responses: 118;
Percent: 9.
Average workweek hours: Did not answer;
Number of responses: 158;
Percent: 12.
Average workweek hours: Total;
Number of responses: 1,366;
Percent: 101.
Source: U.S. Coast Guard.
Note: Percentages do not total to 100 because of rounding.
[A] Indicates individual worked some combination of hours other than
the three listed (i.e., 68, 77, or 84).
[B] Number of responses for which the question was not relevant,
usually because the individual's schedule did not match the options
provided.
[End of table]
Initiatives to Address Staffing Concerns:
Table 10 presents additional information on initiatives the Coast Guard
has under way or plans to develop with regard to station staffing
needs.
Table 10: Additional Examples of Implemented or Planned Initiatives to
Address Station Staffing Needs:
Area of concern: A shortage of personnel;
Initiatives undertaken to address concerns: Staffing levels increased;
* To address a perceived shortage of personnel, in fiscal years 2002
and 2003, the Coast Guard added 1,109 personnel to stations, an
increase of 25 percent. In fiscal year 2004, another 451 personnel were
added to stations and command centers and 80 personnel to groups in
support of station search and rescue activities. These increases
addressed staffing inequities between stations, especially those with
high operational tempos and high workweek hours. The Coast Guard
reported in fiscal year 2003 that increased staffing levels had reduced
the average workweek for station personnel by 3.18 percent from 1998 to
2002.
Area of concern: A shortage of personnel;
Initiatives undertaken to address concerns: Number of positions
increased;
* The number of personnel assigned to stations exceeds the number of
full- time positions authorized (in fiscal year 2003, the number of
assigned personnel exceeded full-time positions by 885). To address
this imbalance and better match the number of assigned positions with
required operational tasking levels, the Coast Guard added 482 full-
time positions to stations in fiscal years 2002 and 2003 and an
additional 317 positions in fiscal year 2004.
Area of concern: Declining levels of experienced personnel;
Initiatives undertaken to address concerns: Direct retention
initiatives initiated;
* In fiscal year 2003, the Coast Guard expended $5.9 million on 312
selective reenlistment bonuses to station boatswain's mates and
machinists ($4.2 million for boatswain's mates and $1.7 million to
machinery technicians);
* Between fiscal years 2003 and 2004, the surfman pay premium was
increased by 33 percent.[A];
* Beginning in fiscal year 2002, enlisted personnel have been entitled
to a basic allowance for food;
* The average portion of housing costs paid by personnel has decreased
from 18.3 percent in fiscal year 2000 to 3.5 percent in 2004; in 2005,
this expense will be reduced to zero.
Area of concern: Declining levels of experienced personnel;
Initiatives undertaken to address concerns: Indirect retention
initiatives;
* Individual stations have also invested in projects that indirectly
contribute to retention through improved staff morale. At our request,
the Coast Guard asked 29 (15 percent) of the 188 multimission stations
to provide data on estimated expenditures for such projects. The 24
stations that responded reported expenditures of $350,000 in fiscal
year 2003 for infrastructure and lifestyle improvements such as new
furniture, sports equipment, and entertainment systems.[B].
Area of concern: Shortened tours of duty (high personnel turnover);
Initiatives undertaken to address concerns: Assignment practices
modified;
* New personnel assignment practices are being implemented to allow for
increased tour lengths for surfman-qualified personnel and to reduce
turnover in all personnel assignments;
* Plans to set policy for average assignment length for enlisted
personnel at grades E-4 through E-6 for 48 months or longer, or as
identified for specific units.
Area of concern: Inadequate mix of skills, expertise, and positions
across stations;
Initiatives undertaken to address concerns: Staffing mix being
reconfigured;
* To ensure consistency across stations, address mission performance
needs, and provide necessary skills, the Coast Guard concluded an
occupation (rating) review in fiscal year 2001 and expects to begin
reconfiguring the station staffing standard (staffing model) in fiscal
year 2005;
Number of specialized and senior positions increased;
* To ease the administrative burden on stations, in fiscal years 2002-
2004, the Coast Guard added 99 support positions (with 19 more needed);
* To better meet unit tasking and responsibilities, in fiscal years
2002 and 2003, the Coast Guard added 486 senior petty officer positions
at stations.[C].
Area of concern: Positions filled with uncertified or inexperienced
personnel;
Initiatives undertaken to address concerns: Assignment and incentive
systems being revised;
* Plans to establish officer and enlisted (boatswain's mate and
machinist) career paths;
* Plans to base station assignments on position requirements and
personnel experience;
* Plans to identify work factors that reduce the incentive of
personnel; develop ways to mitigate the impact of these factors on
personnel;
* Develop motivation and incentive systems for personnel.
Source: U.S. Coast Guard.
[A] A surfman is a coxswain--boat driver--who is qualified to pilot
boats in heavy weather and high surf conditions.
[B] According to a Coast Guard official, the source of funds for these
improvements can be station, group, or district operating budgets or
donations by Coast Guard support groups.
[C] Senior personnel are considered to be petty officer 2nd class (E-5)
and above.
[End of table]
Training:
Initiatives to Increase Formal Training Opportunities for Station
Personnel:
Since 2001, the Coast Guard has taken steps to increase training
capacity at national training centers. Two efforts to expand formal
training slots have been the reinstituting of the boatswain's mate
training center and the implementation of response boat training
courses. Additional information regarding training efforts are
summarized in table 11.
Table 11: Examples of Coast Guard Efforts to Address Station Training
Needs:
Need: Boatswain's mate training;
Initiatives: Boatswain's mate training center reinstituted;
* Reinstituted the boatswain's mate training center in fiscal year
2002, which more than tripled the number of boatswain's mates training
slots, from 120 in 2002 to 450 in fiscal year 2003, plans to train 800
boatswain's mates in fiscal year 2005; Training capacity at boatswain's
mate training center increased;
* Added four additional classrooms and personnel to the center in
fiscal years 2003 and 2004 at a total cost of $3.5 million;
* Condensed the training curriculum from 12 weeks in 2002 to 9 weeks in
2003 to increase the number of students trained; Training center to
augment on-the-job training established;
* Established, at a cost of $960,000, a provisional training center in
fiscal year 2003 to augment station on-the-job training; trained 300
station personnel in 2003.[A]; Training curriculum for station trainees
amended;
* Initiated new training curriculum for boatswain's mate trainees at
stations that better links tasks with qualification requirements and
improves command cadre oversight of training efforts.
Need: Coxswain (boat driver) training;
Initiatives: On-site response boat training developed;
* Established training teams to provide on- site training to station
personnel on boat handling techniques;
Response boat driving course established;
* In fiscal year 2004, at a cost of $500,000, implemented a 2-week
training course on driving and boat operations.[B] The Coast Guard
expects to train approximately 100 students in fiscal year 2004 and
projects it will train 300 students in fiscal year 2005.
Need: Surfman training;
Initiatives: Efforts to address shortage of qualified surfmen
initiated;
* Instituted, at a cost of $667,000, a 2- year training program in
fiscal year 2004 to expedite the surfman training process for 10
surfman trainees; New surfman training course established;
* Established a new surfman training course in fiscal year 2004;
Capacity at training center increased;
* Expanded training facilities to add one new classroom at a cost of
$500,000.
Need: Boat engineer training;
Initiatives: New engineering training course established;
* Established a new 47-foot boat engineer-training course in 2004.
Need: Boarding officer and boarding team member training;
Initiatives: Formal law enforcement training expanded;
* Initiated plans to increase training slots for boarding officers and
boarding team members by over one-fourth between fiscal years 2004 and
2005; Law enforcement training center relocated to increase capacity;
* Relocated the Maritime Law Enforcement Center--which provides
training to boarding officers and boarding team members--to the Federal
Law Enforcement Training Center at Charleston, South Carolina, at a
cost of $2.2 million.[C].
Source: U.S. Coast Guard.
[A] This training center also provides training to boatswain's mates
assigned to cutters.
[B] Funds provided a new boat docking facilities and personal
protective equipment for students.
[C] The Federal Law Enforcement Training Center, a component of the
Department of Homeland Security, provides basic, advanced, specialized,
and refresher training for law enforcement officers from 75 federal
agencies. The Maritime Law Enforcement Center, which provides boarding
officer and boarding team member training to all Coast Guard personnel,
was relocated to increase capacity and to develop training partnerships
with other federal agencies. Expenses included new boat facilities, a
new training simulator, and the relocation of training boats.
[End of table]
Initiatives to Evaluate Station Personnel Knowledge Levels:
The Coast Guard has also taken steps to improve the way it evaluates
job performance for station personnel. To monitor knowledge levels and
provide insight on areas of training that may need
improvement,[Footnote 80] every 2 years station personnel are tested on
requisite areas of job performance.[Footnote 81] In an effort to
improve how the examinations measure station personnel knowledge
levels, the Coast Guard employed professional test writers in 2004 to
revise the examinations.[Footnote 82] Over the past few years test
scores for station personnel have shown mixed trends. For example,
between fiscal years 2002 and 2003 assessment results for boat drivers
and motor lifeboat engineers improved somewhat, while results for crew
members (boat personnel other than the boat driver or engineer) and for
utility boat engineers decreased slightly. Coast Guard officials told
us that they are exploring the reasons for these results, but in
general, increases in test results can be attributed to improvements
made in on-the-job training. Conversely, decreases can be attributed to
a continued lack of experience on the part of junior personnel, the
number of which have increased in the past few years, and to high
levels of personnel turnover at stations.
Boats:
Multimission station personnel use a variety of boats to support
operations. Figures 3 and 4 illustrate three of the primary boats used
by station personnel.
Figure 3: Coast Guard 47-Foot Motor Lifeboat (left) and 41-Foot Utility
Boat:
[See PDF for image]
[End of figure]
Figure 4: Response Boat Small:
[See PDF for image]
[End of figure]
The Coast Guard has made progress in replacing nonstandard and aging
boats to support station operations. Table 12 presents additional
information regarding the Coast Guard's initiatives to modernize
stations' boat fleet.
Table 12: Examples of Coast Guard Efforts to Address Station Boat
Needs:
Need: Aging and nonstandard small boats[A];
Initiatives: New small boats acquired immediately after September 11 to
address increased security responsibilities;
* Purchased 100 small response boats following the attacks of September
11, to augment security capability at strategic ports and to replace
nonstandard boats in a critical state of deterioration;[B] 50 went to
stations and 50 to Maritime Safety and Security Teams (MSSTs);
Multiyear contract to purchase small boats developed;
* In May 2003, the Coast Guard signed a contract allowing for the
purchase of up to an additional 700 small response boats through fiscal
year 2009, at a cost of $145 million.[C] These boats are intended to
replace the remainder of the aging nonstandard boats and to supplement
stations' multimission response capability for search and rescue and
homeland security operations. Boat acquisition is also a component of
the Coast Guard's initiative to enhance security operations in support
of its maritime strategy for homeland security;
* As of January 2005, the Coast Guard had purchased 205 boats, with
plans to purchase an additional 30 boats by March 2005. Of these, 31
went to MSSTs, 10 to training centers, and 164 to stations;
Response boat training implemented;
* Implemented on-site training at stations and a 2-week course at the
national boat training center to provide training in boat handling
techniques.
Need: Aging medium-sized boats;
Initiatives: Efforts to replace medium boats initiated;
* Initiated efforts to replace 41-foot utility boats with a new medium
response boat;
requested $12 million in its fiscal year 2005 budget request to begin
production on 6 boats.[D];
* Tested three prototypes and expects to award a contract in 2005 for
fleet replacement.
Need: Inspection of small boats;
Initiatives: Inspection teams for small boats instituted;
* In fiscal year 2004, the Coast Guard instituted teams to inspect new
standardized small boats, at a cost of $637,000 (includes a staff of
eight inspectors).
Source: U.S. Coast Guard.
[A] The Coast Guard expects to replace approximately 300 of the 350
nonstandard small boats in use at stations in 2001. Approximately 50
nonstandard boats used by stations for unique geographic or weather-
specific operational requirements--such as 14-foot skiffs and 30-foot
special purpose craft boats--will be retained.
[B] The Coast Guard purchased these boats in 2002 for stations and
MSSTs to address port security responsibilities at strategic ports;
they were not a part of the May 2003 contract Coast Guard developed to
replace nonstandard boats.
[C] These boats are essentially the same as those purchased immediately
after September 11--both are off-the-shelf.
[D] The Coast Guard has determined that the 41-foot utility boat--
acquired between 1973 and 1980--is approaching the end of its service
life.
[End of table]
PPE:
As we previously reported,[Footnote 83] anecdotal and quantitative data
indicate that as of fiscal year 2003 active and reserve station
personnel possessed sufficient levels of PPE. During fiscal year 2003,
the Coast Guard spent $7.5 million to address PPE shortfalls for
station personnel, of which $5.6 million came from specially designated
funds. In fiscal year 2003, the cost of a total basic PPE outfit was
$1,296. The cost of a cold weather PPE outfit, which is used by
personnel working at stations where the outdoor temperature falls below
50 degrees Fahrenheit, was $1,431. (Fig. 5 shows a station crew member
in cold weather PPE.) According to the Coast Guard, personnel at 135
(72 percent) of the 188 multimission stations require cold weather PPE
in addition to basic PPE.
Figure 5: Station Crew Member Wearing Cold Weather PPE:
[See PDF for image]
[End of figure]
Despite indications that the Coast Guard had met its goal in fiscal
year 2003 of providing sufficient amounts of PPE to all active duty and
reserve station personnel, concerns remain as to whether the Coast
Guard will provide sufficient funding for station PPE in the future.
The Coast Guard's processes for estimating station PPE needs and
allocating funds have historically resulted in an under funding of
station PPE. See table 13 for concerns regarding the Coast Guard's
processes and practices for allocating funds for station PPE.
Table 13: Concerns Regarding Coast Guard Processes and Practices for
Identifying and Funding Station PPE Needs:
Concern: Forecasting models do not recognize PPE funding needs for
personnel assigned over and above the number of designated positions;
Explanation:
* Officials told us that historically the amount of funds allocated
each fiscal year for station PPE was not sufficient to fund the
estimated needs of all personnel.[A] Because the forecasting models
are predicated on the number of positions designated rather than the
number of personnel assigned, it does not recognize PPE funding needs
for personnel assigned over and above the designated number of
positions;
* In fiscal year 2003, the Coast Guard allocated $5.6 million to
address PPE shortfalls at stations but did not adjust its forecasting
models.[B] Officials told us that in addition to receiving specific PPE
allocations for designated positions, each year stations receive
general operating funds, which can be used toward PPE for personnel
assigned over and above the designated number of positions.
Concern: Historically the Coast Guard has funded approximately half of
all PPE needs associated with designated positions;
Explanation:
* According to officials, the Coast Guard has historically funded
between 50 and 60 percent of the identified recurring PPE costs for
designated positions.[C] In fiscal year 2004, approximately 55 percent
of estimated PPE needs associated with designated active and reserve
positions were funded, leaving a shortfall of approximately $6 million
in estimated needs.
Concern: Assumptions used in forecasting models have not been
validated[D];
Explanation:
* According to officials, the assumptions used in PPE forecasting
models were based on input from station personnel and have not been
validated or reassessed in light of current operations.
Concern: Units are not required to spend allocated PPE funds on PPE;
Explanation:
* According to officials, the total amount of funds allocated for PPE
are distributed among stations and their oversight units, but in the
interests of command flexibility units are not required to spend these
funds on PPE.[E] When stations need PPE, they are to communicate this
need to the oversight units;
* According to the former PPE program manager, it is possible that
oversight units may not pass the funds onto stations as intended (i.e.,
the amount allocated for PPE may not be the amount expended). To
address this possibility, in recent years the official had disclosed to
stations the total amount of PPE funding available to them, including
funds held by oversight units.
Concern: Coast Guard headquarters does not track the expenditure of
survival PPE funds;
Explanation:
* Although the Coast Guard tracks overall PPE expenditures, the
category tracked includes items other than survival PPE, such as body
armor and toxic mask protectors. It is the responsibility of field
commanders to ensure that station PPE requirements are met.
Source: GAO analysis of U.S. Coast Guard data.
[A] In its fiscal year 2002 audit (MH-2003-028, p. 5), the OIG reported
that the Coast Guard did not provide PPE funding for 69 percent of the
personnel added to stations during fiscal year 2002.
[B] In fiscal year 2003, Coast Guard allocated $5.6 million in
designated appropriation funds for PPE purchases. According to
officials, fiscal year 2003 was the first year in which the Coast Guard
provided PPE funds for personnel assigned to stations over and above
designated positions.
[C] In fiscal year 2003, the forecasting models estimated PPE needs of
$3.2 million for personnel in designated positions, but the Coast Guard
initially allocated $1.8 million, or 56 percent, of the identified need
to fund PPE.
[D] According to officials, the forecasting models assume that PPE for
active duty station personnel will need to be replaced every 3 years,
PPE for reserve personnel every 5 years, and PPE for auxiliary
personnel every 7 years.
[E] As an exception to this practice, in fiscal year 2003, Coast Guard
headquarters advised field units that the additional $5.6 million could
be used only for the purchase of station PPE.
[End of table]
[End of section]
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Margaret T. Wrightson (415) 904-2200:
Steven N. Calvo (206) 287-4839:
Staff Acknowledgments:
In addition to those named above, Randy B. Williamson, Barbara A.
Guffy, Joel Aldape, Marisela Perez, Stan G. Stenersen, Dorian R.
Dunbar, Ben Atwater, Michele C. Fejfar, Elizabeth H. Curda, and Ann H.
Finley made key contributions to this report.
FOOTNOTES
[1] Multimission stations perform all Coast Guard missions.
[2] Office of Inspector General, Department of Transportation, Audit of
the Small Boat Station Search and Rescue Program, MH-2001-094
(Washington, D.C.: Sept. 14, 2001) and June 13, 2001, testimony by
Kenneth M. Mead, Inspector General, U.S. Department of Transportation,
CC-2001-184. In 2001, the Coast Guard issued its own internal report--
the Project Kimball Report--on the operational readiness of all its
boat units, including stations. The findings of the report were largely
consistent with the issues identified by the Inspector General.
[3] Our first report addressed whether the Coast Guard's outlays for
stations in fiscal year 2003 exceeded those in fiscal year 2002 by the
designated amount of $15.7 million, as directed in P.L. 108-7, Division
1, Title 1 (Consolidated Appropriations Resolution, 2003). See GAO,
Coast Guard: Station Spending Requirements Met, but Better Processes
Needed to Track Designated Funds, GAO-04-704 (Washington, D.C.: May 28,
2004).
[4] "Readiness needs" refers to the resources, people, training, and
equipment that stations require to execute mission requirements in
accordance with standards.
[5] "Strategic ports" are ports having critical assets and
infrastructure of economic, environmental or national security
significance.
[6] The Coast Guard has responsibilities that fall into 11 programs
within two broad missions--homeland security and nonhomeland security.
[7] For example, in South Florida migrant interdiction is a major
program at some stations, but it is virtually nonexistent in the Great
Lakes region.
[8] Coast Guard standards require that boat crews be able to launch a
boat within 30 minutes of a distress call.
[9] The PWCS program includes activities such as conducting harbor
patrols, vulnerability assessments, and other activities to prevent
terrorist attacks and minimize the damage from attacks that occur.
[10] For security purposes, the specific duties of these stations are
not identified.
[11] In this sense, the term "tactical" refers to procedures or
maneuvers carried out in pursuit of a goal.
[12] Operational units, which can include a group, activity, or a
sector, serve as a parent unit for overseeing station operations and
for providing guidance on policy and administrative matters.
[13] OIG, MH-2001-094 and U.S. Coast Guard, Project Kimball Report.
[14] Senate Report 107-38, Senate Committee on Appropriations,
accompanying the Department of Transportation and Related Agencies
Appropriations Act, 2002 (P.L. 107-87).
[15] U.S. Coast Guard, Report on Boat Forces Strategic Plan
(Washington, D.C.: July 7, 2004). Although a draft of the plan was
provided to the OIG for comment in 2002, it was not released to
Congress until 2004.
[16] United States Coast Guard, Boat Forces Strategic Plan, p. 5.
[17] We calculated a resource hour baseline from which the change in
resource hours following the September 11 attacks could be estimated.
This baseline is an average of the 2 complete fiscal years preceding
the attacks, fiscal years 1999 and 2000. We did not include 2001 data
because these data were not available on a monthly basis. We developed
this baseline as a more representative depiction of boat hours expended
by stations prior to the events of September 11. For the purposes of
this report, we refer to this calculation as the pre-September baseline
or as pre-September 11 levels. Coast Guard officials agreed with this
approach to this analysis.
[18] According to officials, stations received 50 new boats in fiscal
year 2002, 34 in fiscal year 2003, and 76 in fiscal year 2004. Each of
these boats was allotted approximately 500 to 600 hours of operating
time per year. Stations also received additional boats as part of
replacement needs, but these boats would not account for increases in
overall boat hours for the time period we reviewed.
[19] MARSEC, the Coast Guard's security assessment system, corresponds
to the Department of Homeland Security's Homeland Security Advisory
System, which uses a series of colors to inform the nation about the
federal government's perception of the terror threat level. As MARSEC
levels rise, so does the level of security activities the Coast Guard
is expected to conduct.
[20] The Coast Guard has administered this survey each year since 1991,
with the exception of years 1999-2001. The response rate in 2003 was 54
percent.
[21] See GAO, Coast Guard: Relationship between Resources Used and
Results Achieved Needs to Be Clearer, GAO-04-432, (Washington, D.C.:
Mar. 22, 2004). This work addressed all Coast Guard operations, not
just station operations.
[22] Officials told us that because units may not have the resources to
carry out the responsibilities outlined in Operation Neptune Shield,
they are considered to be "guidelines." However, the new
responsibilities, because they will more closely align with resources,
will be considered "requirements."
[23] According to senior officials, the Coast Guard does not expect
units, including stations, to fully meet the taskings identified in the
interim guidelines. Senior headquarters officials told us that
operational commanders are responsible for executing Operation Neptune
Shield's operational guidelines within station resource levels.
However, the officials responsible for operations at the majority of
the 16 stations we reviewed said that they interpreted these
operational responsibilities to be required tasks.
[24] The Scorecard reflects efforts of all entities involved in
waterborne activities, and in some cases includes support from state,
local, and other federal agencies. The scorecard assigns one of three
ratings for ports based on the level of PWCS activities attained: (1)
"green" when 90 percent or more of security responsibilities are
completed, (2) "yellow" when the majority of responsibilities are
completed, and (3) "red" when less than 70 percent of responsibilities
are completed.
[25] MSOs are the Coast Guard's primary operational units for promoting
safe boating practices. MSO responsibilities include establishing and
enforcing standards and regulations for vessel operations; licensing
mariners; conducting boating safety outreach efforts, and investigating
marine accidents. There are 47 MSO offices in the United States.
[26] The Maritime Transportation Security Act of 2002 (P.L. 107-295)
directed the formation of MSSTs to provide fast deployment capability
in response to domestic threats in U.S. ports and waterways. As of
January 2005, 12 of 13 MSSTs had been commissioned; the Coast Guard
expects the 13th MSST to be operational in 2005.
[27] See pages 28 and 36 for a discussion of the relationship between
station positions and personnel.
[28] The Coast Guard cites the 68-hour work-week standard as the
objective for Coast Guard shore units with 24-hour operational
readiness requirements, such as multimission stations and air stations.
Although it holds out the 68-hour workweek as the standard, the Coast
Guard also allows station officers-in-charge the discretion to choose
longer workweek schedules that may better meet readiness and
performance requirements.
[29] The United States Coast Guard Boat Forces Strategic Plan, July 7,
2004, p. 27.
[30] Since 1991(with the exception of years 1999-2001), the Coast Guard
has conducted an annual survey of station workweek hours. The Coast
Guard has used the results of the surveys to try to gauge changes in
the average number of hours personnel work each week. Personnel are
asked to report the number of hours spent among 49 predefined
activities during an average workweek in August.
[31] In 2003, personnel at 77 of the 188 stations were surveyed, with
personnel from 64 stations responding (a total response rate of 54
percent of all personnel surveyed). One possible reason for this low
response rate may be that nonrespondents did not have time to complete
the survey, which could mean that workweek hours were under-reported.
However, it is also possible that personnel who were working longer
hours per week were more inclined to report that condition, leading to
an over-reporting of workweek hours.
[32] It should be noted that long work hours do not necessarily entail
long hours underway (i.e., operating a boat). According to officials,
station crew members can work an 84-hour schedule that does not include
more hours underway than what crewmembers working a 68-hour schedule
experience. However, the Coast Guard's Boat Operations and Training
Manual cautions that an 84-hour work schedule should be restricted to
units with "low response mission workloads," meaning units that do not
have a high launch rate. Thus, although it does not automatically
follow that working longer hours puts personnel at a greater risk of
exceeding agency fatigue standards, it is possible. The Coast Guard has
established fatigue standards that limit the number of hours crew
members can be underway in order to reduce the likelihood of accidents
due to overwork. For example, crew members operating in heavy weather-
-seas and swell conditions combining to exceed 8 feet or winds
exceeding 30 knots--cannot operate a boat for more than 6 hours in a
24-hour period and require 8 hours of rest, leaving 10 hours for other
activity.
[33] According to Coast Guard officials, there are no penalties to
exceeding the 68-hour work week, as long as fatigue standards are not
exceeded. The Coast Guard accepts that local operations requirements
and unit characteristics allow command discretion on alternative
schedules that meet readiness and performance requirements; while these
schedules may be more attractive to personnel, they may also require
more hours at the unit.
[34] Although personnel can work less than a 68-hour workweek under
some circumstances, officials told us the 68-hour workweek should be
considered the threshold of hours worked.
[35] U.S. Coast Guard Boat Operations and Training (BOAT) Manual,
Volume I, Part 3, Chapter 1, Section G, p. 3-25.
[36] U.S. Coast Guard Station Staffing Study In Pursuit of Excellence:
Building a Better Station (Washington, D.C; July 31, 1991).
[37] The Coast Guard does not plan to add either positions or personnel
to stations in fiscal year 2005 because, according to one official, the
stations need time to adjust to the influx of new personnel they have
received, as well as their increased homeland security
responsibilities.
[38] According to the Coast Guard, it takes approximately 5 years for a
new recruit to advance to petty officer 2nd class rank (E-5) and
approximately 10 years to advance to petty officer 1st class (E-6).
[39] The Office of Boat Forces oversees station operations and resource
needs.
[40] According to officials, this goal does not apply to inexperienced
personnel (E-2 and E-3), who are in the process of qualifying for their
jobs These personnel have shorter duty lengths than experienced
personnel because of the need to expose them to as many different
experiences as possible during their training period. One senior
official told us that this practice may be revisited given the training
burden it places on senior station personnel.
[41] Data represent average tour lengths for boatswain's mates E-4
through E-6.
[42] For example, sea duty (on ships) is considered "arduous duty" and,
therefore, is limited to 1, 2, or 3 years. Stations, for the most part,
are considered nonarduous duty, and therefore, assigned personnel
generally have longer tour-of-duty assignments.
[43] According to officials, personnel who are within 1 year of their
full tour of duty are usually eligible for reassignment. Generally, the
Coast Guard will look first to transfer personnel who have completed
their full tour of duty, but if this is not possible, it will next
evaluate those who are closest to completing their tour.
[44] Hands-on surfman training can take place only in the winter, when
surf conditions are appropriately severe. In some years, trainees do
not have the opportunity to practice surfman skills under appropriate
weather conditions, a fact that can prolong the time it takes to
qualify.
[45] Surfmen receive a special pay status--a salary bonus--as an
incentive for continuing to serve as a qualified surfman. Changes in
personnel policy now allow surfmen to retain their special pay status
after they transfer to a different station and are in the process of
certifying--learning the area of operations--at their new station
assignment.
[46] The OIG raised this issue as a concern in its 2003 report (MH-
2003-028, pp. 5 and 10), noting that the shorter average tour length
for entry-level personnel (9 to 23 months) added to the uncertainty of
permanent dedicated staffing levels. In responding to these findings,
the Coast Guard agreed that all personnel assigned to stations should
be placed in permanent positions.
[47] This figure was calculated by comparing the number of positions
designated to stations in fiscal year 2004 with the estimated number of
personnel assigned. It does not reflect attrition, transfers, or other
actions that may have occurred during the year.
[48] This figure was calculated by adding the estimated number of
personnel assigned to stations and command centers in fiscal year 2004
(451 personnel) to the number of personnel assigned during fiscal year
2003 (5,474 personnel). It does not reflect attrition, transfers, or
other actions.
[49] Coast Guard operations officials told us that although formal
training has been recognized as the preferred training mechanism for
station personnel, on-the-job training, which is also an important
component of station training, will still be maintained. Our previous
work in the area of training design has shown that federal agencies can
use a variety of training delivery mechanisms as long as criteria are
used that link agency goals with training efforts. See GAO, Human
Capital: Selected Agencies' Experiences and Lessons Learned in
Designing Training and Development Programs, GAO-04-291 (Washington,
D.C.: Jan. 30, 2004).
[50] As of 2004, the Coast Guard had conducted inspections of stations'
medium boats (utility and motor life boats). The Coast Guard plans to
begin inspecting its new small response boats in 2005.
[51] In fiscal year 2003, teams inspected 49 motor lifeboats and 37
utility boats at 84 of the 188 Coast Guard multimission stations.
[52] According to the Coast Guard's boat operations manual, when
issuing a waiver, operational commanders can decide whether a boat
should be restricted from performing certain missions. Operational
commanders have the flexibility to determine whether a boat can perform
some missions or whether it could perform all missions with certain
restrictions. In the case of inoperable navigation lights, Coast Guard
officials told us that a commander would likely issue a waiver to
restrict the boat from being operated at night but would allow crews to
operate and perform all missions during daytime hours.
[53] GAO-04-704, p. 8.
[54] Congress has repeatedly identified the importance of PPE. In
fiscal years 2002 and 2003, Congress earmarked a total of $30.2 million
for station readiness needs, including PPE needs. See P.L. 107-87,
Title 1, (Department of Transportation and Related Agencies
Appropriations Act, 2002) and P.L. 108-7. (An earmark refers to funds
set aside within an appropriation for a specified purpose.) The
Maritime Transportation Security Act of 2002 (P.L. 107-295) also
directs the Commandant to ensure that all Coast Guard personnel are
equipped with adequate safety equipment while performing search and
rescue missions.
[55] This objective is identified in the Coast Guard's Boat Forces
Strategic Plan, July 7, 2004, p. 41.
[56] Chief of Staff's Final Decision Letter on a Class "A" Mishap:
Coast Guard Station Niagara CG-214341 Capsizing and Subsequent
Fatalities on 23 March 2001 (Feb. 6, 2002). Following this mishap, the
Coast Guard began requesting additional funds for station PPE with each
budget request that included additional positions. Officials also
revised the qualification guide to require boat crewmen to don and
manipulate each piece of survival equipment required of them in the
conditions for which the equipment was designed. Moreover, the training
manual now requires crewmen to annually demonstrate proficiency in
survival techniques if lost overboard or involved in a capsizing. The
Coast Guard has also taken steps to ensure that personnel performing
boat operations are either outfitted with a personal location device or
that their boats are equipped with a float-free location device.
[57] May 2003 Commandant Directive 10470 and Rescue and Survival
Systems Manual, chapters 3 and 4. In the directive, the Commandant
cited an internal research report that attributed 20 percent of the
total risk facing boat personnel to exposure to extreme weather
conditions.
[58] OIG, MH-2003-028, p. 4.
[59] The Coast Guard was unable to provide data on historical modeling
estimates; the program manager told us that these data are not
retained.
[60] During fiscal year 2003, the Coast Guard allotted an additional
$5.6 million in earmarked funds to address--according to officials--
accumulated PPE shortfalls. The $5.6 million was part of $15.7 million
in specially designated funds appropriated in fiscal year 2003 to
address station readiness needs.
[61] According to officials, the forecasting models assume that PPE for
active duty station personnel will need to be replaced every 3 years,
PPE for reserve personnel every 5 years, and PPE for auxiliary
personnel every 7 years.
[62] The Coast Guard's Boat Forces Strategic Plan, July 7, 2004. The
Boat Forces Strategic Plan is designed to support the Coast Guard's
overall strategic plan, the United States Coast Guard Strategic Plan
1999. The Boat Forces Strategic Plan presents a strategic approach for
all Coast Guard boat forces units, including stations, groups, aids to
navigation, and other units. For this discussion, we focus only on
those sections of the plan that apply to multimission stations.
[63] We have issued numerous reports on results-oriented management,
including guides to developing and reviewing strategic plans. The
criteria presented in these guides stem from the Government Performance
and Results Act (GPRA) of 1993 (P.L. 103-62). See Executive Guide:
Effectively Implementing the Government Performance and Results Act,
GAO/GGD-96-118 (Washington, D.C.: June 1996) and Agencies' Strategic
Plans Under GPRA: Key Questions to Facilitate Congressional Review,
GAO/GGD-10.1.16 (Washington, D.C.: May 1997, Version 1). Other entities
have also used GPRA to provide guidance for strategic planning; see,
for example, Office of Management and Budget, Circular No. A-11, Part
6, Sections 200 (Overview of Strategic Plans, Performance Budgets, and
Performance and Accountability Reports) and 210 (Preparing a Strategic
Plan: The Main Elements).
[64] According to the Coast Guard, the plan's goals and objectives were
based on the estimated station capacity required to meet individual
program performance goals.
[65] As previously discussed, the Coast Guard has been operating under
interim homeland security guidelines and is in the process of
identifying long-term requirements.
[66] In 2002, the OIG reviewed a draft of the strategic plan and found
it too general to be useful in guiding Coast Guard efforts or in
measuring the progress of those efforts (see MH-2003-028, p. 6). In
light of these limitations, the OIG recommended that the Coast Guard
revise the plan to identify specific actions, time frames, and
responsibilities required for meeting long-term objectives, such as the
68-hour workweek standard. Although the Coast Guard generally agreed
with the recommendations, officials told us the plan was not revised to
include the OIG's recommendations nor does the Coast Guard have plans
to incorporate them in the future.
[67] In 1993, the Senate Committee on Governmental Affairs stressed
that a multiyear strategic plan not only lay out long-term goals for
implementing an organization's mission but include the resources needed
to achieve these goals. (Senate Report 103-58, accompanying GPRA of
1993, P.L. 103-62.)
[68] The Coast Guard notes in the strategic plan that resource
proposals should reference the goals of the plan. The Coast Guard also
notes that the plan should serve as the foundation for new budget
initiatives, for reprioritizing and reallocating existing resources
(positions, boats, and funding), and for adjusting taskings to
available resource levels.
[69] See GAO, Coast Guard: Relationship between Resources Used and
Results Achieved Needs to Be Clearer, GAO-04-432 (Washington, D.C.:
Mar. 22, 2004) and GAO, Coast Guard: Challenges during the Transition
to the Department of Homeland Security, GAO-03-594T (Washington, D.C.:
Apr. 2003).
[70] We did not include fiscal year 2001 data because these data were
not available on a monthly basis.
[71] See GAO-04-432.
[72] For security purposes, we are not identifying the ports we
visited.
[73] Office of Inspector General, Department of Transportation, Audit
of the Small Boat Station Search and Rescue Program, MH-2001-094
(Washington, D.C.: Sept. 14, 2001) and Audit of the Use of Fiscal Year
2002 Funds to Improve the Operational Readiness of Small Boat Stations
and Command Centers, MH-2003-028 (Washington, D.C.: Apr. 15, 2003).
[74] U.S. Coast Guard, Project Kimball Report, October 11, 2001.
[75] OIG, MH-2003-028.
[76] GPRA of 1993 (P.L. 103-62).
[77] See GAO, Executive Guide: Effectively Implementing the Government
Performance and Results Act, GAO/GGD-96-118 (Washington, D.C.: June
1996) and Agencies' Strategic Plans Under GPRA: Key Questions to
Facilitate Congressional Review, GAO/GGD-10.1.16 (Washington, D.C.:
May 1997, Version 1).
[78] Office of Management and Budget, Circular No. A-11, Part 6,
Sections 200 (Overview of Strategic Plans, Performance Budgets, and
Performance and Accountability Reports) and 210 (Preparing a Strategic
Plan: The Main Elements).
[79] Since 1991, with the exception of years 1999-2001, the Coast Guard
has conducted an annual survey of station workweek hours. The Coast
Guard has used the results of the survey to try to gauge changes in the
average number of hours personnel work each week. In 2003, personnel at
77 of the 188 stations were surveyed, with personnel from 64 stations
responding (a total response rate of 54 percent of all personnel
surveyed). One possible reason for this low response rate may be that
nonrespondents did not have time to complete the survey, which could
mean that workweek hours were under-reported. However, it is also
possible that personnel who were working longer hours per week were
more inclined to report that condition, leading to an over-reporting of
workweek hours.
[80] This exercise is in addition to the initial and recurring testing
requirements that personnel face when they qualify for a rating and a
job. As well as being required to recertify for their rating every 6
months, station personnel must be certified when they move to a new
station. Station senior personnel are responsible for ensuring that on-
the-job training satisfies training requirements.
[81] Test scores are not tracked by individual and there are no
consequences for a low score. Rather, results are examined in total,
and low scores are used to examine the appropriateness of the training
provided to stations in specific areas.
[82] The Coast Guard administers separate examinations to station
personnel, by type of boat, to three different groups: (1) boat
drivers, (2) engineers, and (3) crew members. These examinations are in
addition to the on-the-job training and formal training station
personnel receive when training to qualify for a job. Written
examinations assess overall training provided to station personnel
through formal and on-the-job training. We did not evaluate the
adequacy of the training provided to station personnel, as this was not
identified as an area of concern in either the OIG or internal Coast
Guard studies. In its 2001 report, the Inspector General highlighted
that the Coast Guard does not assign a pass or fail score to
examination results. In response, Coast Guard officials told us that
the intent of the examinations is to assess stations' overall
performance and not identify individual performance levels.
[83] See GAO, Coast Guard: Station Spending Requirements Met, but
Better Processes Needed to Track Designated Funds, GAO-04-704
(Washington, D.C.: May 28, 2004).
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