Special Operations Forces: Additional Actions Are Needed to Effectively Manage Air Reserve Component

Over the past decade the Air Force has increasingly relied on the ARC to meet operational requirements. The ARC is composed of two entities—the Air National Guard (ANG) and the Air Force Reserve (AFR)—which together comprise a substantial part of the total Air Force capability. AFSOC relies on either volunteerism or involuntary mobilization to activate ARC units.

House Report 115-676, accompanying a bill for the National Defense Authorization Act for Fiscal Year 2019, contains a provision for GAO to assess ANG and AFR involuntary mobilization plans to support special operations. GAO evaluated the extent to which (1) AFSOC's mobilization process provides the ARC with timely and reliable forecasts of planned utilization of units and personnel; and (2) the ARC identifies and communicates information to AFSOC on the units and individuals available for mobilization or on voluntary deployments.

The Air Force Special Operation Command's (AFSOC) mobilization process does not fully support Air Reserve Component (ARC) needs for timely and reliable information. While AFSOC has established mobilization processes in line with Air Force guidance, the command faces difficulties, as follows:

consistently providing ARC units and personnel with timely notifications regarding anticipated demand for their capabilities;

coordinating with ARC commands on potential requirements for ARC capabilities; and

sharing reliable information about mission requirements and resources with ARC units and personnel.

According to AFSOC officials, these difficulties stem from AFSOC's limited organizational capacity to conduct the planning, coordination, and execution of involuntary mobilizations (that is, ARC units or personnel ordered to active duty). Other Air Force entities that provide ARC capabilities to meet Air Force-wide requirements have established the capacity within their operations departments to coordinate with the ARC when implementing the involuntary mobilization process. AFSOC officials stated that because AFSOC did not, until recently, regularly use involuntary mobilizations to access the ARC, it was not considered necessary to have an organizational entity dedicated to managing involuntary mobilizations. AFSOC officials stated that the command's operations center has submitted requests to its headquarters for additional resources toward creating such organizational capacity, but the requests were not funded in fiscal years 2018 or 2019, as other requests received higher priority. According to officials, AFSOC is currently exploring possible short-term solutions. In the absence of the organizational capacity to conduct the planning, coordination, and execution of involuntary mobilizations, AFSOC will continue to be impeded in providing the notice required to access the ARC in support of requirements.

The ARC does not provide AFSOC with complete information regarding which of its units could be used to support AFSOC requirements for special operations activities. The Air Force uses a model that captures and organizes Air Force-wide requirements, but the model does not include special operations requirements, and AFSOC is expected to develop its own processes for its unique requirements. According to AFSOC and ARC officials, the ARC has not developed a method for capturing and organizing special operations requirements because it has historically supported special operations activities using volunteerism, which is more flexible and requires less up-front planning. Consolidated information on potential unit deployments would provide units with advanced notification, facilitating deployment preparation activities and helping personnel make arrangements with civilian employers or in their personal lives. Without a method to provide consolidated information on reserve component units available for deployment, the ARC will not have the information it needs to successfully plan its deployments, or to easily identify which of its units will be available for mobilization.

GAO is making three recommendations, including that the Air Force should ensure that AFSOC has the organizational capacity to effectively initiate, coordinate, and execute ARC mobilizations; and should develop a method for providing AFSOC with consolidated information regarding units available for mobilizations. DOD concurred with one of these recommendations and partially concurred with two, stating that some information is being shared and a planned initiative could improve the information flow. GAO believes this initiative, if implemented, could address the intent of its recommendations.

U.S. Air Force Special Operations Command (AFSOC) relies on its Air  Reserve Component (ARC) to support operational needs and provide  strategic depth to meet potential future contingencies. The ARC is  comprised of two entities: the Air National Guard (ANG) and the Air Force  Reserve (AFR). As codified in law, the purpose of the ARC is to “provide  trained units and qualified persons available for active duty in the armed  forces, in time of war or national emergency, and at such other times as  the national security may require to fill the needs of the armed forces  whenever more units and persons are needed than are in the regular  components.” While the Air Force has historically relied on the ARC to  serve as a reserve force for potential major contingencies, over the past  decade the Air Force has increasingly relied on the ARC to meet  requirements for ongoing operations. This includes using the ARC to  support requirements that are known in advance as well as to provide the  ability to respond to unexpected events and emergent threats.

In both roles, ARC units need more predictability and time than do their  active duty counterparts to prepare their forces to support special  operations activities, according to ARC officials. These officials attribute  this need in part to ARC personnel’s having civilian careers, and thus less  time available to train for their missions, because they are not full-time  members of the military. The immediacy with which the ARC can support  activities is also affected by the advance notice required to access the  reserve component. ARC officials stress the importance of having timely  and reliable information on demands for their capabilities to ensure that  units are fully prepared to meet mission needs.

House Report 115-676, accompanying a bill for the National Defense  Authorization Act for Fiscal Year 2019, contains a provision for us to  assess Air National Guard and Air Force Reserve involuntary mobilization  plans to support special operations activities. This report evaluates the  extent to which (1) AFSOC’s mobilization process provides the ARC with  timely and reliable forecasts of planned utilization of its units and  personnel; and (2) the ARC identifies and communicates information to  AFSOC on the units and individuals available for mobilization or on  voluntary deployments.

For our first objective, we reviewed Department of Defense and Air Force  guidance on accessing the reserve component. Specifically, we analyzed  Department of Defense Instruction 1235.12, Accessing the Reserve  Components (RC), which establishes policy, assigns responsibilities, and  prescribes procedures for ordering units and members of the reserve  component to active duty as an operational force; and Air Force  Instruction 10-402, Mobilization Planning, which provides mobilization  process guidance and responsibilities regarding obtaining authority for the  issuance of orders to activate reserve component personnel. We also  reviewed relevant sections of Title 10 of the U.S. Code, including those  concerning the reserve component access authorities for activating  reserve component members for involuntary active duty.

For our second objective, we reviewed Air Force policies and guidance  related to mobilization within the ARC—specifically, Air Force Instructions  10-401, Air Force Operations Planning and Execution, and 10-301,  Managing Operational Utilization Requirements of the Air Reserve  Component Forces. Among other things, these instructions prescribe and  explain how the Air Force is to present forces for planning, deployment,  employment, sustainment, redeployment, and reconstitution. They also  direct the identification, collection, maintenance, and visibility of ARC  operational utilization requirements to support planning and decision- making at all levels. We reviewed ANG and AFR information on units  available for mobilization. For both objectives, we interviewed officials  from the Office of the Under Secretary of Defense for Personnel and  Readiness, Secretary of the Air Force Reserve Affairs and Airman  Readiness, AFSOC, ANG Readiness Center, AFR Command, and  several reserve component units, along with Air Combat Command and  Air Mobility Command, to discuss these topics and related challenges.

We conducted this performance audit from August 2018 to December  2019, in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

AFSOC is the Air Force component of U.S. Special Operations Command  and is responsible for providing Air Force capabilities and forces to  support special operations activities. Special operations are operations  requiring unique modes of employment, tactical techniques, equipment,  and training often conducted in hostile, denied, or politically sensitive  environments. Demand for AFSOC capabilities, including those provided  by the ARC, is identified as part of the Department of Defense’s (DOD)  Global Force Management process for assigning and allocating forces to  meet global requirements. This process allows the Secretary of Defense  to strategically manage forces—including the military services,  conventional forces, and special operations forces—to support strategic  guidance and meet combatant commander requirements. As part of this  process, the Joint Staff validates requirements for forces. U.S. Special  Operations Command, as the joint force provider, is responsible for  identifying and recommending forces to support special operations  requirements.

U.S. Special Operations Command coordinates with its service  component commands, including AFSOC, to determine which capabilities  and specific units are best suited to meet validated requirements for  special operations capabilities. After receiving these requirements,  AFSOC considers its available options to provide the capabilities needed.  This consideration includes reviewing active duty and reserve component  units that provide specific sets of capabilities, such as intelligence,  surveillance, and reconnaissance; personnel recovery; and radio and  television broadcasting for psychological operations.

If AFSOC, in conjunction with Headquarters Air Force, determines that  the best solution to meet a requirement is to use capabilities from the  ARC, it can rely on either volunteerism or involuntary recall to active  duty—referred to as involuntary mobilization—to activate the needed  forces. These two types of activation are described below.

Volunteerism. The Secretary of the Air Force is authorized to activate  ARC personnel on active duty with the consent of those individuals;  however, the consent of the state governor is required for the  voluntary activation of ANG personnel. According to Joint Publication  4-05, Joint Mobilization Planning (Feb. 21, 2014), volunteerism is  important because it enables a service to fill required positions with  reserve component personnel without its counting against the  statutory limits related to involuntary mobilization. However, the  guidance also states that volunteerism should be used judiciously,  because excessive use of volunteers removes personnel from reserve  component units, which could result in a reduction of the unit’s  readiness in the event of unit mobilization. Another factor that  mobilization planners must take into account is dwell time policy in  relation to deployments. Furthermore, the Air Force has established  specific goals for managing the operational tempo of its forces, and  planners need to consider this factor as well.

Involuntary Mobilization. Any unit or individual of a reserve component  may be ordered to active duty under multiple mobilization statutory  authorities under Title 10 of the U.S. Code that vary regarding the  number of personnel who can be mobilized, the duration of the  mobilization, and the approval authority. For example, section 12304  of Title 10, U.S. Code, provides authority to the President to  involuntarily activate up to 200,000 members of the selected reserve  for up to 365 days to augment active forces for an operational mission  or in response to certain emergencies.

AFSOC’s Mobilization Process Does Not Fully Support ARC Needs for Timely and Reliable Information

Air Force Has Established Guidance and Processes for Mobilizing the ARC

AFSOC is required to follow Air Force guidance for accessing ARC units  and personnel. The Air Force guidance implements DOD Instruction  1235.12, Accessing the Reserve Components (RC), which establishes  the overarching policies and procedures for accessing the reserve  components for all military departments. When AFSOC officials  determine that ARC capabilities are the appropriate option for a given  special operation requirement, their access to the reserve component is  governed by Air Force Instruction 10-301, Managing Operational  Utilization Requirements of the Air Reserve Component Forces. This  instruction outlines roles and responsibilities for managing requirements  for reserve component capabilities accessed through both involuntary  mobilizations and volunteerism. Among other things, it establishes that  AFSOC use the reserve component in a cyclical or periodic manner that  provides predictability to ARC individuals, to the individual’s employer,  and to the combatant command receiving the capabilities.

The process for accessing the reserve component through involuntary  mobilization is further outlined in Air Force Instruction 10-402,  Mobilization Planning. This guidance implements and expands on the  specific timelines for particular milestones during the mobilization process  established in DOD Instruction 1235.12, such as the identification of the  types of capabilities required and of the unit responsible for providing  them. These timelines vary, depending on whether the requirement for  capabilities is known well ahead of mobilization—a rotational, or  preplanned, requirement—or, conversely, is emergent.

Rotational or preplanned requirements: AFSOC must provide the  reserve component with a request for particular capabilities at least  330 days prior to the mobilization, to allow ANG or AFR officials to  identify the specific individuals who are available to support the  request. Air Force guidance communicates the time frames in which  reserve component personnel are to receive their mobilization orders.  Specifically, AFSOC is required to submit requests to mobilize the  ARC to Air Force headquarters to provide the Secretary of the Air  Force enough time to approve the request; and then to communicate  with ANG and AFR in sufficient time to provide personnel with their  mobilization orders at least 180 days prior the start date of rotational  or preplanned requirements.

Emergent requirements: AFSOC is required to submit requests so  that personnel receive notification at least 120 days prior to the  mobilization date. In comparison, there are no specific time frames  in the guidance for accessing the reserve component through  volunteerism. The guidance generally discusses volunteerism as an  approach that allows for ARC personnel to quickly respond to  requests for forces.

AFSOC officials told us that they have observed an increase in requests  from ARC units to use involuntary mobilizations rather than rely on the  use of volunteerism, and that they anticipate this trend to continue, since  involuntary mobilizations afford more predictability than do voluntary  deployments. As such, involuntary mobilizations help personnel manage  the frequency of time spent away from home and maximize their access  to military medical and retirement benefits. Specifically:

Managing time away from home: Air Force guidance limits the  frequency of involuntary mobilizations for an individual to a standard  of five periods of time spent at home for every one period spent  involuntarily mobilized. For example, an individual involuntarily  mobilized for 90 days would not be available to AFSOC for involuntary  mobilization for another 450 days after the individual’s return. This  provides ARC personnel with some assurance that they will not  deploy again for a specific window of time, unless they volunteer to do  so. We have previously reported on challenges faced by DOD in  setting policies to establish thresholds and track the total time  individual servicemembers may be away from home, including for  exercises, training, and deployment. We found that, with the  exception of the Navy and U.S. Special Operations Command, the  services either were not enforcing or had not established specific and  measurable thresholds in their policies. Additionally, we found that  DOD lacked reliable data for tracking the total time individual  servicemembers spent away from home. We recommended that DOD  clarify its policy to include specific and measurable department-wide  thresholds and take steps to emphasize the collection of complete  and reliable data. DOD concurred with our recommendation.

Medical and retirement benefits: Involuntary mobilization can also  maximize the window during which personnel receive medical and  retirement benefits. All ARC personnel are eligible for benefits up to  180 days prior to their involuntary mobilization or voluntary  deployment. However, to receive these benefits the individual must  also have been issued mobilization orders identifying the mobilization  date or, for a volunteer, the deployment date. As previously  discussed, Air Force guidance identifies notification time frames  designed to provide ARC personnel involuntarily mobilized to support  rotational or preplanned requirements with their orders at least 180  days prior to the mobilization start date. This time frame allows  personnel to receive these benefits for the entire time they are  potentially eligible. By contrast, personnel who are involuntarily  mobilized for emergent requirements are supposed to receive their  orders with at least 120 days’ notice, and, according to AFSOC  officials, volunteers can receive as little as one week’s notice. As a  result, personnel may prefer involuntary mobilization, as it generally  results in their receiving military medical and retirement benefits for  more time than they would have received them if they had  volunteered to deploy.

AFSOC Has Mobilization Processes but Faces Difficulties in Providing the ARC with Timely and Reliable Information about Requirements

AFSOC has mobilization processes that follow Air Force guidance, but it  faces difficulties in implementing these processes. Specifically, we found  AFSOC faces challenges in (1) consistently providing ARC units and  personnel with timely notifications regarding anticipated demand for their  capabilities; (2) coordinating with ANG and AFR commands on potential  requirements for ARC capabilities; and (3) sharing reliable information  about mission requirements and resources with ARC units and personnel.

AFSOC Has Not Always Provided Timely Notification to ARC Units and Personnel

The notifications that AFSOC gives ARC units or personnel of anticipated  demand for their capabilities generally do not meet the notification time  frames associated with involuntary mobilizations for non-emergent  requirements, thereby impeding ARC units’ ability to prepare for  deployments. Officials at three of the four reserve component units we  spoke with told us that AFSOC routinely provides units with limited notice  of requirements for capabilities, even though they predominately support  preplanned requirements that are known to AFSOC well in advance of  their execution. Therefore, the officials stated, AFSOC should have  sufficient time to identify and communicate the requirement for ARC  capabilities to reserve component units to enable them to meet required  time frames (for example, no less than 180 days in the case of non- emergent requirements). However, according to these officials, they  routinely receive 90 or fewer days’ notice of when they are expected to  provide capabilities for a given requirement. Due to this truncated time  frame, the requirement must either be staffed using volunteers or receive  approval from the Secretary of Defense to involuntarily mobilize reserve  component personnel with limited notice.

Receiving limited notification can create challenges for the ARC unit  providing the capabilities for AFSOC requirements. For example, officials  at one unit we spoke with stated that they requested that AFSOC provide  at least 9 months’ notice prior to a mobilization to ensure that personnel  received adequate training, because the unit provides a range of  specialized capabilities. However, officials stated that what they generally  received was 60 to 90 days’ notice, and that within this time frame the unit  faced challenges in obtaining access to the equipment needed to train  personnel for specific missions. Officials at another unit we spoke with  stated that since 2015 they had received 60 or fewer days’ notice for their  support of AFSOC requirements, one of which was an involuntary  mobilization supporting a non-emergent requirement. An official explained  that while AFSOC’s communication of requirements and planning of  involuntary mobilizations has improved over time, the unit expects that  orders for its next mobilization will be provided with fewer than 180 days’  notice. The official explained that in addition to limiting ARC personnel’s  access to medical and retirement benefits, the abbreviated time frames  make it difficult for them to coordinate their absences with their civilian  employers. AFSOC officials acknowledged that they have been late to  notify units in the past and identified this as an area in which they are  working to improve. The officials explained that in some instances the late  notification is a result of factors outside of AFSOC’s control, such as  instances in which the Secretary of Defense’s process for approving  requirements is delayed.

AFSOC Has Not Always Coordinated Directly with ANG and AFR Commands

We identified concerns regarding AFSOC’s practice of communicating  directly with reserve component units, rather than formally coordinating  with ANG and AFR commands, to develop potential requests for ARC unit  capabilities. For example, AFR officials stated that geographic proximity  to AFSOC frequently results in one unit’s receiving informal requests from  AFSOC for its capabilities. That unit provides remotely piloted aircraft  capabilities, which do not require personnel to deploy overseas. Officials  explained that AFSOC will contact that unit directly to request capabilities  to supplement the active duty personnel completing the same mission,  but commonly AFSOC will provide only a few days’ notice prior to the  requirement. According to these officials, personnel generally respond to  these requests by volunteering with limited advance notice.

AFSOC officials stated that communicating informally with the units to  determine the availability of their personnel and capabilities enables  AFSOC to expedite the identification of personnel potentially available to  meet a requirement. However, headquarters officials for both ANG and  AFR—who are responsible for identifying the specific personnel available  to meet a requirement—stated that these indirect communications  impede their ability to strategically manage and appropriately resource  units. For example, headquarters AFR officials identified an instance in  which changes to a unit’s anticipated contribution to a mission were  arranged with the unit, but not with officials at their higher headquarters at  the AFR. The requirement was originally for the AFR unit to supplement  an active duty unit already providing the capability for AFSOC, but was  expanded to require the AFR unit to have sole responsibility for providing  part of the capability. The absence of direct communication and formal  coordination between AFR headquarters and AFSOC during this  expansion led to differing expectations regarding the number of AFR  personnel needed to provide the capability required. AFR officials stated  that as a result of limited transparency into future requirements for that  unit, AFR headquarters did not request the appropriate level of funding for  the unit, thereby limiting the resources available to support the  requirement. AFSOC officials acknowledged that their use of informal  communication with units instead of coordinating with ANG and AFR  headquarters is not an ideal approach and could be improved.

AFSOC Does Not Always Share Reliable Information about Mission Requirements and Resources

We identified concerns regarding the frequency with which AFSOC has  changed the information it has communicated to ARC units about  anticipated requirements, thereby creating unpredictability and impeding  those units’ ability to train for and ultimately provide the capabilities  needed to execute those requirements. While requirements may change  subject to combatant command needs, AFSOC’s availability to proactively  coordinate with both the combatant command and the ARC has been  limited. AFSOC officials stated that, due to their limited capacity to  manage involuntary mobilizations, they are often dedicating time only to  those mobilizations that require urgent attention, as opposed to refining  the details of the requirement and coordinating with the units in advance  of the mobilization.

ARC officials stated that the unpredictability resulting from the changes  that occur can introduce challenges to the units’ ability to execute  requirements. For example, officials at one unit stated that the location of  a previous requirement changed at least three times in the 60 days  preceding its involuntary mobilization. Officials explained that changes to  the location of the requirement meant that the capabilities required by  AFSOC also changed, because the unit provides intelligence,  surveillance, and reconnaissance capabilities that need to be supported  by specific communications equipment. Depending on the location, this  equipment may already be in place, or it may be that the unit must bring it  with them. In a different instance, the same unit arrived at a location to  provide its intelligence, surveillance, and reconnaissance capabilities and  found that the location lacked the communications equipment the unit  needed to effectively use its capabilities.

Further, ARC officials explained that changes regarding what capabilities  are needed can create training challenges unique to the reserve  component. ARC unit officials explained that while reserve component  personnel maintain a standard level of readiness at all times,  deployments may require them to train to a specific skill set to meet a  mission requirement. For example, special tactics squadrons supporting  AFSOC requirements can support three different mission sets, each of  which may require specialized training to prepare for a specific mission,  according to unit officials. Given the nature of the reserve component,  these personnel have to complete this training during the limited windows  of time in which they are called in from their full-time civilian jobs. As a  result, the ARC has limited flexibility in responding to changes in training  requirements. AFSOC officials acknowledged that the ARC can face  challenges in meeting training requirements and that the advanced  planning associated with involuntary mobilizations can help ensure that  units have enough time to meet training requirements.

Other Air Force Entities Use Alternative Approaches to Planning, Coordinating, and Executing Involuntary Mobilizations, but AFSOC Lacks the Organizational Capacity

Other Air Force entities that provide ARC capabilities to meet Air Force  requirements through mobilization have established alternative  approaches to initiating, planning, and coordinating their respective  requirements for reserve component capabilities. Specifically, officials  from Air Combat Command and Air Mobility Command, which are Air  Force components similar to AFSOC regarding mobilization of ARC units,  described entities established within their operations departments to  coordinate with the ARC when implementing the involuntary mobilization  process. These entities each consist of four to five individuals who are  tasked on a full-time basis with ensuring that the reserve components are  utilized in a predictable manner. The efforts of these entities include  coordinating with the ARC to create plans that cover at least 2 years of  anticipated rotational and preplanned requirements. While Air Combat  Command and Air Mobility Command officials stated that they are  responsible for coordinating a larger number of mobilizations than  AFSOC coordinates, they noted that all three follow the same Air Force  guidance with regard to the involuntary mobilization process.

Officials from an ARC personnel recovery unit that supports Air Combat  Command missions highlighted the benefits of the predictability that  comes from Air Combat Command’s planning efforts. According to  those officials, anticipated mobilizations are communicated to them in a  schedule that covers a span of 5 years. More than a year before the unit  is scheduled to involuntarily mobilize, Air Combat Command  communicates the specifics of the requirement for the mission. The  officials stated that, in their experience, these details rarely change once  they have been communicated to the unit. By contrast, as previously  discussed, we spoke with officials from an ARC special tactics squadron  that provides AFSOC with capabilities similar to those of the personnel  recovery unit described above, who stated that they regularly receive  only 60-90 days’ notice prior to being deployed. They stated that they  face difficulties in adequately training personnel to provide capabilities  within these time frames. AFSOC officials stated that this issue is driven  in part by the fact that units coordinate directly with requesting commands  to fill their desired requirements.

According to AFSOC officials, AFSOC does not have a headquarters  entity dedicated to managing the planning, coordination, and execution of  reserve component capabilities because, until recently, AFSOC did not  use its reserve components to support ongoing missions to the extent that  they do today. As a result, it was not considered necessary to have an  organizational entity dedicated to managing involuntary mobilizations.  Instead, AFSOC assigned the roles and responsibilities associated with  initiating, planning, and coordinating ARC mobilizations within its overall  process for managing AFSOC’s assignment and allocation of forces.  AFSOC and ARC officials stated that under this process, a single  individual at AFSOC is responsible for managing the involuntary  mobilizations as a secondary duty. AFSOC officials stated that, given the  scope of other assigned responsibilities, this individual focuses on  managing involuntary mobilizations about half of one day in a work week.

According to the officials, having a limited staff dedicated to initiating,  planning, and coordinating involuntary mobilizations results in AFSOC’s  responding to issues as they become urgent and impedes its ability to  utilize the ARC in a predictable and stable manner. AFSOC officials also  stated that the shift to using the ARC to support AFSOC’s steady state  requirements, along with the increasing use of involuntary mobilizations to  access ARC capabilities, have exposed the limitations of their capacity to  manage involuntary mobilizations. These officials added that creating a  more robust organizational capacity to manage the involuntary  mobilization of the reserve component could counteract some of the  challenges they have experienced in providing timely notification to ARC  units, directly coordinating with ANG and AFR commands, and identifying  and communicating reliable information about requirements to ARC units.

AFSOC officials attribute the challenges faced in implementing AFSOC’s  involuntary mobilization processes to the absence of adequate capacity to  manage involuntary mobilizations. Specifically, they acknowledged that  with additional capacity they would be better positioned to undertake the  efforts needed to (1) provide more timely notification to ARC units, (2)  coordinate with ANG and AFR commands, and (3) increase  communication with the commands generating requirements. While  officials acknowledged that some last-minute changes are unavoidable,  they told us that having more personnel dedicated to AFSOC’s  mobilization process could potentially lead to having more timely  notifications or better indications of imminent changes. Further, some  factors that can affect the involuntary mobilization process fall outside of  AFSOC’s control, such as delays in the decision making process at the  Secretary of Defense level and changes in combatant commander  requirements. Although AFSOC cannot control all factors that affect  involuntary mobilization of the ARC, increasing its capacity to manage  involuntary mobilizations would improve its ability to anticipate and  proactively address the challenges introduced by external factors.

AFSOC officials stated that in recognition of this need, the command’s  operations center has submitted multiple requests for additional  resources to the headquarters in order to create a more robust  organizational capacity to manage the involuntary mobilization of the  reserve component. For example, the request submitted in January 2019  stated that AFSOC currently does not provide the support and guidance  that ARC units need to properly execute the involuntary mobilization  process. The request sought one additional full-time position dedicated to  managing involuntary mobilizations and coordinating involuntary  mobilizations with the ARC. Although AFSOC officials told us that the  request was validated by AFSOC leadership, the validation of a request  does not ensure that it will receive funding. After competing against other  funding requests from other Air Force components, the Financial  Management Board did not fund the position in fiscal years 2018 or 2019  because those other requests received higher priority. As an alternative  to the full-time position requested by the operations center, AFSOC  officials identified ongoing efforts to coordinate with the ANG that would  result in the ANG’s allocating personnel to fill a temporary position at  AFSOC. The individual in this position would be responsible for  supporting the mobilization process. AFSOC officials stated that such an  arrangement would help address the capacity challenges they currently  face, but also noted that it would be a short-term solution, and highlighted  that the individual filling the position would need to be familiar with  AFSOC, ANG, and AFR processes to execute his or her duties. In  addition, AFSOC officials could consider realigning existing capacity  within the command to directly address the limited capacity to manage  involuntary mobilizations. However, AFSOC officials emphasized that the  command as a whole currently operates with limited capacity.

In the absence of the Air Force developing additional AFSOC  organizational capacity dedicated to the planning, coordination, and  execution of involuntary mobilizations, AFSOC will continue to be  impeded in its ability to manage involuntary mobilizations in accordance  with Air Force guidance, including providing the notice required to access  the ARC through involuntary mobilization in support of preplanned or  rotational requirements. Additionally, at its current capacity AFSOC will  likely face increasing challenges in providing timely notification to ARC  units, coordinating with ANG and AFR commands, and enhancing  communication with the commands generating requirements to help  solidify mission specifics, as the number of involuntary mobilizations  quadruple by 2021, as estimated by AFSOC officials. As a result, units  may not be fully prepared to support requirements or able to effectively  conduct their mission once in theater. Further, AFSOC will continue to be  impeded in coordinating with ANG and AFR commands in a manner that  enables the ARC to strategically manage and resource units in support of  AFSOC’s requirements.

The ARC Does Not Provide Complete Information to AFSOC on Units Available for Mobilization or on Voluntary Deployments

The ARC Does Not Have Consolidated Information on Reserve Component Units Available to Support Special Operations Activities

While the Air Force’s force-generation model provides the ARC with a 24- month picture of the units it anticipates will be used to meet potential Air  Force-wide deployments, the ARC does not have a comparable model  with information on which ARC units could be used to support AFSOC  requirements for special operations activities. According to officials, the  ARC does not have a force-generation model for two reasons. First, while  the Air Force model works for Air Force-wide requirements, it does not  apply to special operations-specific requirements because they are  unique to the Air Force’s special operations component, AFSOC.  According to AFSOC officials, their command deploys units and  personnel differently from typical Air Force units in order to maximize the  number of requirements they can support with a smaller force. Second,  the ARC has historically supported special operations activities using  volunteerism, which is much more flexible than involuntary mobilization  and requires less upfront planning or notification. As a result, ARC  officials did not feel the need to develop a force-generation model for  special operations requirements. ANG and AFR officials told us that ARC  units will sometimes keep a unit-level schedule of their potential  deployments, but that information is not available in a consolidated or  consistent format. AFSOC officials added that any force-generation model  for special operations should consider the limited capacity of some  special operations capabilities. Officials stated that some capabilities in  the ARC are limited to one unit, which results in AFSOC deploying parts  of units rather than the whole unit to cover more requirements.

ANG and AFR officials agreed that a force-generation model regarding  future deployments could help identify which ARC units would be  susceptible to deploy during a given period of time, which would be  beneficial for planning ARC deployments. Consolidated information on  potential unit deployments would provide units with advanced notification,  making it easier to accomplish deployment preparation activities and  helping ARC personnel make arrangements for their potential  deployments. For example, ANG officials told us that advanced  notification to units can give the ARC more time to incorporate needed  training into drill training. Furthermore, unit personnel would also have  more time to make arrangements with civilian employers or in their  personal lives, making their transition to active duty easier and making it  more likely that they will view mobilizations favorably in the future.

Additionally, these officials stated that, with such a model, ANG and AFR  could more easily identify and communicate which ARC units would be  available for mobilization to support special operations activities. AFSOC  officials stated that, in turn, this could provide AFSOC with more certainty  that it would have access to ARC forces when needed. According to ANG  and AFR officials, AFSOC officials have expressed some concerns about  whether their command will have access to ARC forces. Specifically,  since a substantial part of the total Air Force capability resides in the  ARC, AFSOC officials are not certain that the capacity of ARC units  supporting special operations will be able to meet future requirements.  The officials added that by identifying units or individuals susceptible for  deployment in advance, AFSOC would have more confidence in the  ARC’s ability to support the command’s requirements.

According to Air Force guidance, a predictable force-generation model is  used to ensure proper force readiness and rapid responses to emerging  crises. Specifically, Air Force Instruction 10-401, Air Force Operations  Planning and Execution, calls for the Air Force and its components,  including the ANG and AFR, to manage the deployment of its forces in  order to meet global requirements while maintaining the highest possible  level of overall readiness. The instruction calls for the Air Force to  accomplish this task by establishing a force-generation model that can be  used to manage the rhythm of force deployments to meet global  combatant command requirements. The intent of the force-generation  model is to establish a predictable, standardized pattern to ensure that  forces are properly organized, trained, equipped, and ready to sustain  capabilities while rapidly responding to emerging crises.

ANG officials told us that they have taken some initial steps to create a  force-generation model and consolidate the various unit-level schedules  of ARC forces supporting special operations activities. Specifically, the  ANG advisor to AFSOC was developing a consolidated schedule of ARC  units intended for use by AFSOC to identify ANG units that could mobilize  to support AFSOC requirements. However, according to AFSOC officials,  the ANG advisor was expected to retire soon, and we found that ANG  headquarters officials were not aware of this effort, and there were no  plans to institutionalize it. AFR officials were likewise not aware of any  similar effort to consolidate schedules for their units’ different capabilities  to support special operations activities. Without having a method for  providing consolidated information on reserve component units that are  available for deployment, the ARC will not have the information it needs  to successfully plan its deployments, or easily identify and communicate  to AFSOC which of its units are or will be available for mobilization.  Furthermore, AFSOC officials may continue to have concerns that they  will not have access to high demand ARC capabilities to deploy under a  mobilization.

The ARC Does Not Have Complete Information on Voluntary Deployments

According to officials, although ANG and AFR units have a general  understanding as to how many volunteers they have supporting special  operations requirements at the unit level, the ANG and AFR lack a  mechanism for tracking volunteer deployment rates across the ARC.  Specifically, information on reserve components’ volunteer deployments  is not available in a form that facilitates tracking in order to understand  rates of volunteering or the contributions made by the ARC in supporting  special operations activities, according to officials.

The Air Force requires the ANG and AFR to track key data to ensure  proper management of ARC utilization and mission execution.  Specifically, Air Force Instruction 10-301, Managing Operational  Utilization Requirements of the Air Reserve Component Forces, calls for  the Air Force to identify full mission requirements for ARC utilization by  collecting, tracking, and organizing relevant data and prioritizing  requirements. It also states that these data are intended to aid in  allocating funding, matching units to requirements, executing  requirements, assessing each step of the process, and forecasting future  requirements. Additionally, Standards for Internal Control in the Federal  Government establishes that management should obtain relevant data  from reliable internal and external sources in a timely manner to facilitate  effective monitoring.

ANG and AFR officials told us that voluntary deployments are more  difficult to track than are involuntary mobilizations. Specifically, the  statutory requirements for involuntarily mobilizing ARC units or personnel  make tracking them simpler. For example, according to officials the  Secretary of Defense is required to approve or be notified of involuntary  mobilizations, and ANG and ARC units receive specific orders, all of  which are tracked closely. Voluntary deployments, however, do not have  the same approval requirements.

Nevertheless, ANG and AFR officials told us that ARC units may have  some information, as detailed below, on the numbers of volunteer  deployments, although this information provides only a partial picture of  volunteerism.

Travel System Data: Officials from a reserve component unit we  visited reported that some of the information on voluntary  deployments could be compiled from travel systems used to send  ARC units and personnel overseas. However, these officials added  that matching travel records to the volunteer status of individuals  could be time-consuming, because the travel systems are not  designed to perform this function. Furthermore, unit officials told us  that this travel information would be incomplete even if it were  compiled, because it would not include units and individuals  supporting operational requirements from their home stations—that is,  not traveling outside their normal locations. For example, according to  unit officials, personnel supporting remote piloted aircraft would not be  included in the information collected from the travel systems because  they do no travel outside their normal duty stations to carry out their  missions. Without travel orders, the system would not show these  types of deployments. Unit officials told us that there could be several  cases like this one in which the information compiled from the travel  system or other sources could be incomplete.

Man-Day Estimates: An AFSOC official told us that the system used  to track military personnel appropriation man-days could be another  source used to track volunteerism among ANG and AFR units.  According to this official, AFSOC uses a data system to transfer man- days to the volunteering ARC unit. This official stated that the  system used to make these transfers may contain the information  needed to track volunteerism, but acknowledged that no one at  AFSOC was using the system for this purpose. Furthermore, ANG  and AFR officials confirmed that the data system is not currently used  for tracking rates of volunteerism among ARC units.

According to AFR officials, tracking volunteerism would allow them to  more easily document the ARC’s contributions to support special  operations and evaluate whether ARC forces were being effectively  utilized. Specifically, ANG and AFR officials expressed concerns that  different rates of individual volunteerism within and across ARC units may  result in a misleading picture of overall unit utilization. In some cases,  incomplete data on volunteerism can result in overstating unit  contributions. For example, the unit-level figures regarding deployments  are actually averages of all the individuals in the unit. Officials expressed  concerns that as a result of using averages, units may appear to be more  highly utilized than they actually are, due to the high rates at which some  individuals from the unit volunteer to deploy. According to ANG and AFR  officials, some ARC personnel volunteer at high rates because they prefer  the additional income or benefits from these deployments, while other  personnel from the same units may prefer to deploy less often. ARC  officials expressed concerns that this disparity may not be immediately  visible to ARC and AFSOC leadership. AFSOC officials told us that they  share some of these concerns.

Other officials expressed concerns that without good information on  volunteerism rates, the ANG and AFR could not effectively manage  operational tempo goals. To measure operational tempo, DOD has  established policies relating to how long military personnel are deployed  versus at home (referred to as dwell time, or dwell). For example, ARC  personnel who deploy for 7 months and are in dwell for 14 months would  have a deployment-to-dwell ratio of 1:2. For ARC units, DOD also tracks  the mobilization-to-dwell ratio, which is the ratio of how long ARC  personnel are involuntarily mobilized versus not mobilized. DOD guidance  establishes that the mobilization-to-dwell ratio for ARC units should be  1:5.

According to ANG and AFR officials, ARC voluntary deployments are not  factored into the dwell calculations for either ratio, making it more difficult  to ensure that deployments do not fatigue ARC forces. Additionally,  Special Operations Command policy specifies that ARC units supporting  special operations should maintain the same deployment cycle as active  duty units, which as a goal should be no less than a 1:2 deployment-to- dwell ratio. ANG, AFR, and AFSOC officials agreed that tracking  volunteer deployment rates more comprehensively and consistently  would provide greater perspective on how ARC units are utilized and help  them more effectively manage their operational tempo goals.

Officials stated that an additional consequence of having incomplete data  on volunteerism is that the overall contributions of the ARC can be  understated, because the full range of support that ARC units and  personnel are providing is not being documented. For example, a report  used by the Air Force to track force contributions from its components,  including the ARC, shows that the AFR contributed forces to support  special operations activities for about 6 months of an approximately 4- year period. However, according to AFR officials, the command’s  contribution to support special operations activities was much higher than  what is documented in the report. The officials stated that AFR also  provided volunteer support to AFSOC over the entire period but that its  contributions are not fully reflected in the report, because volunteers  supporting an AFSOC-assigned mission are counted among the  contributions made by other active duty forces, rather than by AFR.

Without complete information on volunteer deployment rates among  reserve component forces, the ANG and AFR may face difficulties in  ensuring the effective utilization of their forces to support special  operations activities, documenting force contributions from the ARC, and  managing operational tempo and deployment-to-dwell goals. Further, the  ARC will not have the information it needs to ensure effective  management of its force utilization and mission execution. Specifically, it  will not be able to determine whether units are being fully utilized,  because of the distorted or incomplete volunteerism information.

With a substantial part of the total Air Force capability residing in the  ARC, AFSOC relies on mobilized ARC forces to support its operations.  Furthermore, AFSOC’s increasing use of ARC as an operational reserve  has highlighted the importance of the ARC’s and AFSOC’s planning and  information-sharing efforts. However, AFSOC’s implementation of its  mobilization process impedes its ability to provide the ARC with timely  notification of mobilizations, coordinate with ANG and AFR commands,  and share reliable information about requirements with the ARC. Without  resolving AFSOC’s organizational capacity challenge in managing  AFSOC requirements for reserve capabilities, AFSOC’s implementation  of this process is unlikely to improve.

AFSOC’s use of the ARC is also affected by the unavailability of complete  information regarding both the units available to mobilize and voluntary  deployment rates. Specifically, while the ARC is able to identify the units  anticipated to be available to support non-special operations  requirements, it does not have a method for communicating consolidated  information on the availability of units for special operations requirements.  Without such a method, AFSOC and the ARC do not have easily  accessible information about the current and future availability of ARC  units to support special operations requirements. In addition, voluntary  deployments are a key piece of the ARC’s support of AFSOC  requirements. However, the ARC has not developed a mechanism for  tracking the rate at which they occur. Without tracking volunteer  deployment rates, the ARC is limited in its ability both to ensure that its  forces are effectively utilized and to communicate the level of contribution  made by ARC volunteers in support of special operations requirements.

We are making three recommendations to DOD:  The Secretary of the Air Force, in coordination with ANG and AFR, should  ensure that AFSOC has the organizational capacity to effectively initiate,  coordinate, and execute ARC mobilizations, to include ensuring timely  and reliable notification of requirements to those units. (Recommendation  1)

The Secretary of the Air Force should ensure that the ANG and AFR  develop a method for providing AFSOC with consolidated information  regarding units available for immediate and future mobilizations to  support special operations activities, such as the Air Force provides to its  units with its force-generation model. (Recommendation 2)

The Secretary of the Air Force should ensure that the ANG and AFR  develop a mechanism for tracking volunteer deployments to better  manage ARC force utilization. (Recommendation 3)

In written comments on a draft of this report, DOD concurred with one  recommendation and partially concurred with two recommendations.  DOD’s comments are restated below and reprinted in appendix I. DOD  also provided technical comments, which we incorporated where  appropriate.

DOD concurred with the first recommendation that the Secretary of the  Air Force, in coordination with ANG and AFR, should ensure that AFSOC  has the organizational capacity to effectively initiate, coordinate, and  execute ARC mobilizations, to include ensuring timely and reliable  notification of requirements to those units. In its response, DOD stated  that the Air Force continues to balance manning requirements across the  spectrum of operations. DOD also stated that fully manning AFSOC for  this staff function would be helpful, whether additional manpower is  programmed or AFSOC mitigates internally by reallocating manpower.  We believe that fully manning AFSOC for this staff function, if fully  implemented, would meet the intent of the recommendation. In its  comments on this recommendation, DOD also stated that the ARC has a  process in place to provide timely notification to ANG and AFR units once  requirements are known. The department added that the ANG  implemented the Agile ARC Mobilization Process on June 1, 2019, which  streamlined policy and procedural chokepoints and improved notification  timelines by an average of 60 days. We note that, while improvements in  the notification timelines would be beneficial, it is too soon to understand  the long-term effect of the implementation of this process.

DOD partially concurred with the second recommendation that the  Secretary of the Air Force should ensure that the ANG and AFR develop  a method for providing AFSOC with consolidated information regarding  units available for immediate and future mobilizations to support special  operations activities, such as the Air Force provides to its units with its  force-generation model. In its comments, DOD stated that the AFR  currently provides AFSOC with information on units available, using  Reserve Component Periods, and that the AFR will assess whether re- posturing in multiple Reserve Component Periods will provide a portion of  capability with greater flexibility. We agree that this is a reasonable  approach. However, as we noted in our report, consolidated information  on reserve component units that are available for deployment could  provide ARC units with advanced notification, making it easier to  accomplish deployment preparation activities and help ARC personnel  make arrangements for their potential deployments. Additionally, DOD  stated that current information technology initiatives with the Air Force  Integrated Personnel and Pay System will eventually provide the Air  Force with functionality allowing a single, integrated system of software  suites. According to the department, Air Force Integrated Personnel and  Pay System will support a rapid and accurate information flow from the  first identification of a requirement through the processing and delivering  of orders, allowing the Air Force to start pay and benefits in an auditable  manner. However, DOD did not identify a timeline for when that system  would be available. We believe that improvements in the flow of  information regarding ARC unit availability are necessary and would help  to ensure that the ARC can successfully plan deployments, or easily  identify and communicate to AFSOC which of its units are or will be  available for mobilization. We believe that if this planned system is  implemented as described, it would meet the intent of the  recommendation.

DOD partially concurred with the third recommendation that the Secretary  of the Air Force should ensure that the ANG and AFR develop a  mechanism for tracking volunteer deployments to better manage ARC  force utilization. In its response, DOD stated that tracking volunteer  deployments requires timely information from AFSOC to properly identify  the requirements, establish expeditionary ARC units, and document the  transaction when ARC members are activated. Further, it stated that in  the short term, the AFR will work with AFSOC on further developing use  of the Air Force Consolidated Planning Schedule to better define  requirements. While coordination with AFSOC could help improve the  tracking process, we believe that the ANG and AFR also need to develop  a mechanism for tracking volunteer deployments to better manage ARC  force utilization. Additionally, DOD noted that the planned information  technology initiative, which it described in its response to our second  recommendation, could also have benefits for tracking voluntary  deployments. We believe that if the planned system is able to fully track  voluntary deployments, it would meet the intent of the recommendation.

We are sending copies of this report to the appropriate congressional  committees; the Secretary of Defense; the Under Secretary for Personnel  and Readiness; the Chief of the National Guard Bureau; and the  Commanders of Special Operations Command, Air Force Special  Operations Command, and Air Force Reserve Command. In addition, the  report will be available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-5431, or russellc@gao.gov. Contact points for our  respective offices of Congressional Relations and Public Affairs may be  found on the last page of this report. GAO staff who made major  contributions to this report are listed in appendix II.

Appendix I: Comments from the Department of Defense

Appendix II: GAO Contact and Staff Acknowledgments

In addition to the contact named above, individuals who made key  contributions to this report include Jim Reynolds, Assistant Director;  Adam Anguiano, Tracy Barnes, Adrianne Cline, Shylene Mata, Walter  Vance, and Cheryl Weissman.

The Air Force Special Operations Command has increasingly relied on Air Force reserve components to help carry out its mission. When needed, reservists of the Air National Guard and Air Force Reserve may volunteer for active duty or may be involuntarily mobilized. Reserve forces need more time to prepare for these duties than active-duty units.

The Command has had a difficult time coordinating with reserve force commanders and notifying reserve forces in a timely manner about what forces will be needed.

We made 3 recommendations, including actions to improve coordination between the Command and reserve components.


Airline Consumer Protections: Information on the Passenger Experience

Each year, hundreds of millions of passengers rely on airlines to get them to their destination without incident—including some of the 57 million Americans with a disability. While airlines maintain their performance and service have improved, passengers may still experience a range of inconveniences.

A number of consumer protections are in place at the federal level. These protections have addressed long tarmac delays and increased compensation for passengers who are involuntarily denied boarding. Some protections are specific to passengers with disabilities, requiring that airlines provide (1) help enplaning and deplaning, and (2) compensation for lost or damaged wheelchairs. DOT enforces these protections.

This statement discusses (1) DOT's data on airline operational performance from 2008 through 2017, and (2) what is known about passenger complaints and airlines' practices related to accessibility and non-discrimination issues. This statement is based on six prior GAO reports issued in the past 3 years. For that work, GAO analyzed relevant DOT data and passenger complaints; reviewed DOT documents and regulations; and interviewed DOT officials and representatives from selected airlines and consumer advocate organizations. For this statement, GAO updated prior analyses on passenger complaints for accessibility and discrimination issues and reviewed recent DOT rulemakings.

The Department of Transportation's (DOT) data show that airlines' operational performance—as measured by rates of denied boardings, mishandled baggage, and flight delays—generally improved from 2008 through 2017, the latest available data at the time of GAO's review. Nevertheless, in 2018, GAO found that passenger complaints to DOT across all complaint categories increased about 10 percent from 2008 through 2017 for 12 airlines that GAO selected for review. Complaints about airlines' operational performance accounted for around 50 percent of the total.

Passenger disability complaints submitted to airlines—which vastly outnumber such complaints submitted directly to DOT—have steadily increased since 2011. Unlike all other categories of passenger complaints, airlines are required to annually report the number of disability-related complaints they receive to DOT. Passenger disability complaints submitted directly to DOT also increased in 2019, accounting for the second highest level in the past 10 years. Complaints to airlines and DOT in 2017—the most recent year data were available—were most commonly about failure of airline staff to provide assistance, seating accommodation issues, and issues related to service animals. Passenger complaints submitted to DOT related to discrimination also rose in 2019, with 96 complaints filed. From 2010 through 2019, DOT received, on average, 80 complaints a year from passengers alleging discrimination, most commonly about racial discrimination.

DOT requires that airlines provide training on accessibility issues and encourages non-discrimination training for its staff. In 2017, GAO found that 12 selected airlines had accessibility-related training requirements for their staff and contractors, with some variations in the content and format. In 2019, GAO reported that representatives from six selected U.S. airlines provide non-discrimination training to employees, although not all contractor staff receive that training. Airlines have taken initial actions in other areas. More recently, in 2020, GAO found that only about 4.5 percent of the eight largest U.S. airlines' fleet of aircraft with single aisles were designed to accommodate airplane onboard wheelchairs.

Chairman Larsen, Ranking Member Graves, and members of the  Subcommittee:  Thank you for the opportunity to discuss our body of work on consumer  protections for airline passengers. Each year, hundreds of millions of  passengers rely on airlines to get them to their destination without  incident—including some of the 57 million Americans with a disability,  who may require additional assistance from airline personnel. While  airlines maintain that operational performance and customer service are  improving, citing better on-time performance and higher customer  satisfaction scores, passengers may still experience a range of  inconveniences, such as a delayed or canceled flight, lost or damaged  wheelchair, or unsatisfactory experience with airline staff. Moreover,  some non-discrimination advocacy organizations and others have  questioned whether airlines treat all passengers equally and without bias,  citing incidents where Muslim passengers and passengers of color  appear to be religiously or racially profiled. The Department of  Transportation (DOT) is responsible for ensuring that airlines adhere to  consumer protections afforded to passengers.

My testimony today is based on prior reports we issued from September  2017 through January 2020 on a variety of airline consumer protection  issues—including airlines’ denied boarding practices, impacts of airline IT  outages, and airlines’ disability and nondiscrimination trainings, among  others. Specifically, this testimony describes (1) trends in DOT’s data on  airline operational performance from 2008 through 2017 and airlines’  actions to improve such service, and (2) what is known about passenger  complaints and airlines’ practices related to accessibility and non- discrimination issues.

To conduct our prior work, we analyzed relevant DOT data on airlines’  operational performance and passenger complaints; reviewed DOT  documents and guidance, and applicable statutes and regulations; and  conducted interviews with DOT officials and representatives from  selected airlines and consumer advocacy organizations, among others.  More detailed information on our objectives, scope, and methodology can  be found in each of the reports. For this statement, we updated our prior  analyses on passenger complaints related to accessibility and  discrimination issues and reviewed DOT’s recent rulemakings. We  conducted the work on which this testimony is based in accordance with  generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on audit objectives. We believe the evidence obtained provides a  reasonable basis for our findings and conclusions based on our audit  objectives.

While U.S. airlines’ business practices were largely deregulated following  the Airline Deregulation Act of 1978, a number of consumer protections  are in place at the federal level. For example, some consumer  protections are required by federal statute, such as the Air Carrier Access  Act of 1986 (ACAA), as amended, which prohibits airlines from  discriminating against individuals based on a disability. Federal statutes  have also authorized DOT to regulate certain areas affecting passengers.  For example, DOT has the authority to stop airlines from engaging in  unfair or deceptive practices, or unfair methods of competition, and  promulgates consumer protection regulations under its statutory  authorities. Under these authorities, DOT issued three final rules on  Enhancing Airline Passenger Protections from 2009 through 2016.  These rules have addressed long tarmac delays, increased compensation  amounts for passengers who are involuntarily denied boarding, and  required certain airlines to post information about their fees and on-time  performance on their websites.

Airlines’ Operational Performance Has Generally Improved, but Passengers Filed More Complaints and May Experience a Range of Inconveniences

Rates of Mishandled Baggage and Denied Boardings Generally Declined From 2008 Through 2017, While Airlines’ On-Time Performance Remained Relatively Steady

In 2018, we found that airlines’ operational performance—as measured  by DOT data on denied boardings; mishandled baggage; and late,  cancelled, or diverted flights—generally improved from 2008 through  2017, the most recent data available at the time of our review. While  rates of voluntary and involuntary denied boardings and mishandled  baggage generally declined, airlines’ on-time performance stayed about  the same (fig. 1). For example, over the 10-year period of our review, the  lowest rate of involuntary denied boardings occurred in 2017. Specifically,  in 2017, airlines involuntarily denied boarding to about .003 percent of all  passengers (or about 23,000 of more than 680 million passengers)—a  slight decrease from prior years. Our more recent work on airlines’ denied  boarding practices found that even fewer passengers were denied  boarding involuntarily in 2018. Rates of mishandled baggage also  generally declined in recent years. For example, in 2017 airlines posted a  rate of 2.5 mishandled bags per 1,000 passengers (a rate of .25 percent  of mishandled bags per passenger enplanement), compared to a rate of  5.25 mishandled bags per 1,000 passengers in 2008.

In 2019, we identified a number of factors that can cause airlines’  operational issues. For example, passengers might be denied boarding  when airlines overbook their flights (i.e., intentionally sell more seats than  are available on a flight) or have to substitute smaller aircraft than what  was originally scheduled due to maintenance issues. We also found that  outages associated with airline IT systems—which are used for flight and  crew planning, passenger reservations or check-in, or for providing flight  information to the Federal Aviation Administration—can cause flight  delays and cancellations. While we found some outages caused  minimal issues, the impact of others was more substantial. For instance,  in 2016, an outage in one airline’s system that is used to check in and  board passengers resulted in the cancellation of 2,300 flights over 3 days.

The Rate of Passenger Complaints Generally Increased From 2008 Through 2017

While airlines’ operational performance generally improved, we found in  2018 that the number of passenger complaints reported to DOT, relative  to passenger boardings, generally increased from 2008 through 2017 for  12 selected airlines, peaking in 2015 and declining somewhat in later  years. Specifically, in that work we found that the rate of passenger  complaints reported to DOT, relative to passenger boardings, increased  about 10 percent, from about 1.1 complaints per 100,000 passengers in  2008 to 1.2 complaints per 100,000 passengers in 2017. Complaints  about operational issues discussed above—which make up three of  DOT’s 15 complaint categories—accounted for about half of all  complaints for the 12 selected airlines from 2008 through 2017. More  specifically, in 2018 we found:

Flight problems generally accounted for an average of about 33  percent of all complaints. This category includes complaints related to  delays, cancellations, and missed connections, among other things.  From 2008 through 2017, the rate of complaints in this category  generally increased.

Baggage issues generally accounted for an average of about 15  percent of total complaints. Complaints were largely related to lost,  delayed, or damaged bags. The rate of baggage complaints generally  decreased over our time period.

Denied boardings generally accounted for an average of about 4  percent of total complaints. Complaints were related to airlines’ failure  to solicit volunteers or providing compensation below the required  amount. Rates of complaints about denied boardings generally stayed  constant over our time period.

Two of the remaining 12 complaint categories tracked by DOT accounted  for about a quarter of passenger complaints. One category related to  reservations, ticketing, and boarding, and the other related to customer  service—such as airline staff having a poor attitude or refusing to provide  assistance, and unsatisfactory seat assignments. Each of these  categories generally accounted for an average of about 13 percent of all  complaints over the 10-year period.

Representatives from Selected Airlines Cited Technological and Other Actions Taken to Improve Service

Our previous work identified actions taken by airlines or DOT in response  to such operational issues. DOT’s actions are primarily related to  establishing regulations about operational issues. For example, while  DOT does not prohibit airlines from overbooking flights, it has set  compensation amounts for passengers denied boarding involuntarily.  DOT has also issued regulations related to returning mishandled baggage  within 24 hours, tarmac delays, and prohibiting chronically delayed  flights. Examples of airlines’ actions are listed below.

Reducing denied boardings. In 2019, we reported that selected  airlines have taken a range of actions, aimed at reducing involuntary  denied boardings. Some of these actions also provide additional  incentives for passengers to volunteer to be denied boarding. Actions  include reducing or eliminating overbookings; improving software to  better predict passenger no-shows; requesting volunteers earlier (e.g.,  at check-in instead of at the gate); increasing compensation for  volunteers; and conducting reverse auctions to solicit volunteers.

Less mishandled baggage. As we reported in 2018, representatives  from almost all airlines we interviewed reported investing resources to  improve baggage-handling efforts and minimize the effects to  passengers whose bags are lost or delayed. Among other actions,  airline representatives told us they upgraded baggage technology;  modernized the claims process, so passengers could complete forms  on-line; and instituted replacement baggage programs, where  passengers can get a replacement bag at the airport. One airline also  invested several million dollars to use radio frequency identification  technology to track bags, as well as allowing passengers to track their  baggage via an application on their smartphone.

Efforts to minimize flight disruptions. In 2018, we also reported  that selected airlines had taken numerous actions to improve on-time  performance or mitigate challenges for passengers associated with  flight delays and cancellations. For example, one airline began  tracking flights that were “at-risk” of meeting DOT’s definition of a  chronically delayed flight, so it could, among other things, swap crews  or substitute aircraft and avoid these types of delays. Other airlines  told us they use technology, such as text-messaging updates, to  communicate with passengers during delays and cancellations or  increased the number of circumstances for which passengers are  compensated during delays and cancellations.

Passengers May Experience Inconveniences When Operational Issues Occur

Our prior work has shown that passengers may be affected to varying  degrees by airline operational issues, and that incidents can be costly and  disruptive for some passengers. Airlines are required by DOT regulations  to provide compensation or certain amenities to inconvenienced  passengers under certain circumstances. For example, some passengers  who are denied boarding involuntarily are entitled to compensation, with  the amount varying based on certain factors. Airlines are also required  by DOT’s interpretation of the statutory prohibition on unfair and  deceptive practices to provide refunds for canceled and significantly  delayed flights, if a passenger chooses to cancel his or her trip. Beyond  those requirements, DOT officials previously told us that airlines are not  obligated to provide accommodations for flight disruptions, such as  cancellations and delays, unless specified in an airline’s contract of  carriage, although as mentioned above, some voluntarily choose to do so  in certain situations. This may result in significant inconveniences for  passengers, who may incur costs for lodging, meals and transportation.  However, according to our prior work, available information about the  number and magnitude of these effects is largely anecdotal and cannot  be quantified. Furthermore, our review of selected airlines’ contracts of  carriage in February 2019 showed variation in the types of  accommodations airlines provide and circumstances in which they will be  provided, when operational issues occur.

Civil Rights Complaints Have Recently Increased, and DOT and Most Airlines Have Training Efforts

Disability-Related Complaints Have Increased Steadily, While Discrimination-Related Complaints Have Seen a Recent Increase

According to the 2010 U.S. Census, 57 million Americans (roughly 1 in 5)  have a disability, and more than half of those 57 million Americans have  mobility issues. Furthermore, older Americans are representing an  increasing share of the U.S. population. As the population continues to  age, the likelihood of this group needing assistance may increase.  Without accommodations—such as effective communication of flight  information, accessible seats, appropriate boarding assistance, and  careful handling and stowage of wheelchairs and other assistive  devices—people with accessibility or mobility issues may face challenges  when flying, or they may be unable to fly altogether.

As previously mentioned, the ACAA prohibits airlines operating in the  U.S. from discriminating against individuals on the basis of disability in the  provision of air transportation. Under this law, DOT has promulgated  regulations requiring that airlines provide passengers with disabilities (1)  assistance in enplaning and deplaning; and (2) compensation for lost,  damaged, or delayed wheelchairs or other assistive devices. In contrast  to all other complaints that passengers submit directly to airlines, DOT  regulations require that airlines report annually to DOT the number of all  disability-related complaints they received.

In our May 2017 report, we provided information showing that disability  complaints reported to airlines and DOT generally increased from 2005  through 2015. More recent data shows that passenger complaints  reported to U.S. airlines continued to increase (see table 1). In particular,  we found that complaints reported to airlines on disability issues  increased by about 50 percent from 2010 (19,347) to 2017 (29,662), the  most recent year for which data are available. Based on our review, the  vast majority of passengers chose to file their disability complaints directly  to the airlines. Notably, the number of passenger complaints on disability  issues reported to DOT from 2010 through 2019 ranged from 572 to 944  and averaged about 780 complaints per year. Complaints reported to  DOT rose in 2019, after peaking in 2015 and declining the three following  years. In 2017, the last year data are available for both, complaints  reported to airlines and DOT were most commonly related to failure of  airline staff to provide assistance, seating accommodation issues, and  service animal issues.

As we have previously reported, the number of complaints may not fully  reflect the inconvenience experienced by passengers or would-be- passengers with accessibility issues. Some may choose not to fly and  others may have to take inconvenient or uncomfortable precautionary  measures to avoid using the aircraft lavatory. For example, in our recent  work examining the accessibility of aircraft lavatories, stakeholders we  interviewed told us that some passengers severely limit their food and  fluid intake in advance of the flight, risking dehydration; use a catheter; or  wear a protective undergarment. Furthermore, because lavatories  accessible by the aircraft’s onboard wheelchair are not required on most  aircraft (i.e., single-aisle aircraft) and there may not be an expectation  that the lavatory be accessible by an onboard wheelchair, passengers  may not see grounds to complain or may not take the time to submit a  complaint. More generally, in our prior work, we found that complaint data  are inherently limited because a substantial portion of dissatisfied  individuals do not submit complaints and are therefore not represented in  the complaint data.

A number of federal statutes also prohibit or have been interpreted by  DOT to prohibit airline discrimination against airline passengers. Federal  statute also allows airlines to refuse to transport any passenger if the  airline determines that the passenger is, or might be, a threat to safety.  According to DOT guidance, this determination is made by the pilot in  command of the aircraft or certain other specified airline personnel and  cannot be arbitrary, but must be based on specific facts and  circumstances known at the time. In its guidance, DOT has  unequivocally provided that a passenger’s status in a protected class  (e.g., race, ancestry, national origin, or religion) cannot be the  determinative factor in an airline’s decision to deny boarding or remove a  passenger from a flight.

Our August 2019 report showed that the total number of passenger  complaints reported to DOT against U.S. airlines alleging discrimination  generally declined from 2010 through 2015, but began to increase  starting in 2016. Moreover, updated data for 2019 show a further  increase, with 96 complaints filed (table 2). According to our analysis,  from 2010 through 2019, DOT received, on average, 80 discrimination- related complaints a year, most commonly about racial discrimination.  Despite the recent increase in the total number of discrimination  complaints, they account for a small percentage of total passenger  complaints DOT receives, as well as total passenger boardings. For  example, in 2019, of the 9,547 complaints DOT received against U.S.  airlines, 96 alleged discriminatory treatment.

As noted above and previously reported, DOT’s discrimination complaint  data does not capture passenger complaints reported directly to airlines.  In 2018, we reported that DOT officials estimated that, across all  complaint categories, for every passenger complaint they receive, airlines  receive about 50. While we have previously requested discrimination  complaint data from selected airlines, they have generally declined, citing  the proprietary nature of this information. Since 2017, DOT has  disaggregated discrimination complaints into sub-categories, such as  racial or religious discrimination, and published this data in its Air Travel  Consumer Report.

DOT and Airlines Have Ongoing Training Efforts on Disability and Discrimination Issues

We previously identified actions that DOT and airlines have taken that are  intended to ensure that no passengers are discriminated against on the  basis of disability or other protected class. Our work primarily examined  airlines’ efforts to train staff and contractors. However, our work also  identified other airline actions (both proactive and reactive) taken to  enhance compliance with consumer protections in these areas. For  example, one airline developed a wheelchair tracking system in response  to a DOT enforcement action to help reduce incidents of lost or  mishandled wheelchairs.

DOT requires that airlines provide their employees and contractor staff  who interact with the traveling public training on the proper and safe  operation of equipment used to accommodate passengers with a  disability, as well as on boarding and deplaning assistance. While not  required, DOT encourages airlines to implement comprehensive non- discrimination trainings to help prevent discrimination. DOT has also  developed training materials, available on its aviation consumer  protection website, for airline employees and contractor staff. These  materials include brochures, digital content, and videos on the rights of  passengers with disabilities, as well as tips on providing wheelchair  assistance at airports and onboard aircraft. In 2017, DOT also developed  guidance for airline personnel on non-discrimination topics. The material  included scenarios for recognizing discriminatory behavior and provided  examples of how to ask additional questions or conduct additional  screening in a non-discriminatory manner.

In 2017 we reviewed disability training programs for 12 selected airlines  and found that they all had disability-related training requirements for their  staff and contractors, with some variations in the content and format.  Over the course of that work, each airline demonstrated that it had, as  required, initial and recurrent training for its employees, contractors, and  complaint resolution officers (CRO). All 12 selected airlines used a mix  of training, including classroom-based training, computer-based training,  situational scenarios, and hands-on training, such as wheelchair handling  and lifting passengers into aisle seats to assist in boarding for specific  groups. We also found that these selected airlines generally consulted  with disability organizations when developing ACAA training programs.  Some airlines also voluntarily implemented quality assurance programs to  improve and sustain their disability-training programs’ performance.  Another step some airlines have taken, though not required by the ACAA  or its implementing regulations, is the creation of a disability board, which  serves as a forum for increasing awareness among their workforce about  disability issues.

In 2019, we reported that representatives from all six U.S. airlines we  selected for review told us they provide non-discrimination training to  employees, although not all contractor staff receive that training. These  representatives told us they provide initial non-discrimination training to  newly hired employees who interact with passengers—including, for  example, pilots, flight attendants, and customer service representatives— and that most regularly update the training based on current events or  changes in policy. Airline representatives provided high-level examples  describing the content of their trainings, but with one exception, they  declined to provide more specific information, citing the sensitive or  business proprietary nature of such materials.

We found some similarities and differences in what representatives  reported their trainings covered. For example, representatives generally  stated that non-discrimination trainings—which were typically embedded  in larger training programs and combined in-person and web-based  modules—emphasized treating all individuals fairly and without bias,  regardless of race, ancestry, or religion, among other things. Most also  said trainings covered implicit bias—a term that refers to attitudes or  stereotypes about groups of people that unconsciously affect a person’s  understanding, actions, and decisions—and half said they have used  DOT’s guidance discussed above, with some airline-specific  modifications.

Airlines and DOT Have Taken Initial Steps in Other Consumer Protection Areas

In our recent work on aircraft lavatories, we found that some U.S. airlines  voluntarily installed lavatories accessible by the aircraft’s onboard  wheelchair for some of their single-aisle aircraft. However, we found that  these aircraft only constituted about 4.5 percent of the eight selected  airlines’ combined single-aisle fleet. According to airline representatives,  providing lavatories accessible by the aircraft’s onboard wheelchair may  reduce the number of revenue generating seats in the aircraft cabin,  which can increase airlines’ costs and result in higher fares for  consumers. In lieu of lavatories accessible by the aircraft’s onboard  wheelchair, airline representatives said they have added certain features—such as assist handles or grab bars, and accessible call  buttons or door locks—designed to increase access to certain lavatory  functions.

DOT has recently issued three notices of proposed rulemaking (NPRM)  designed to improve the accessibility of aircraft lavatories, regulate  service animals, and clarify DOT’s authority to stop airlines from engaging  in unfair or deceptive practices. For example, in January 2020, DOT  issued an NPRM to solicit comments on short-term accessibility  improvements on single-aisle aircraft through the installation of  accessibility features within the lavatory, such as those mentioned above,  without changing the size of lavatories. In addition, DOT announced its  intention to issue an advance NPRM to address long-term accessibility  improvements and to solicit comments and gather information on the  costs and benefits of requiring airlines to increase the size of the single- aisle lavatory on new aircraft models to accommodate a wheelchair as  well as an assistant. In 2008, DOT noted that accessible lavatories on  single-aisle aircraft would benefit passengers with disabilities, but also  expressed concerns that revenue loss and other cost impacts could be  too great for the airlines.

The FAA Reauthorization Act of 2018 included a number of ongoing  requirements for DOT in the airline consumer protection area. For  example, DOT is responsible for developing leading non-discrimination  practices for airlines, in consultation with airlines and other consumer  advocates. In addition to our recently published work, we have ongoing  work examining airport accessibility for passengers with disabilities, as  well as DOT’s enforcement approach to consumer protections. We  anticipate issuing reports on the results of this work later this year.

Chairman Larsen, Ranking Member Graves, and members of the  Subcommittee, this completes my prepared remarks. I look forward to  answering any questions you may have.

If you or your staff have any questions about this statement, please  contact me at (202) 512-2834 or vonaha@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this statement. GAO staff who made key contributions to  this testimony are Jonathan Carver, Assistant Director, Geoffrey  Hamilton, Delwen Jones, Josh Ormond, Amy Suntoke, Melissa  Swearingen, and Elizabeth Wood.

This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.

Hundreds of millions of passengers expect airlines to get them to their destination smoothly. Sometimes, these travel plans can go awry.

This testimony draws on our airline consumer protection work since 2017.

Airlines’ performance generally improved from 2008 through 2017. Transportation Department data show a decline in cases of denied boardings—due to overbooked flights, for example—and mishandled baggage. Rates of late, cancelled, or diverted flights stayed about the same.

Passenger complaints on disability issues—e.g., airline staff failing to assist passengers—have steadily increased. Discrimination complaints have also increased recently.