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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

February 2013: 

Charter Schools: 

Guidance Needed for Military Base Schools on Startup and Operational 
Issues: 

GAO-13-67: 

GAO Highlights: 

Highlights of GAO-13-67, a report to Congressional Committees. 

Why GAO Did This Study: 

Many families struggle to balance their job demands with ensuring that 
their children have access to a high-quality education, and for 
military families this struggle can be exacerbated by the highly 
mobile nature of their service. Family concerns about education affect 
readiness and retention of military personnel, according to the 
Department of Defense (DOD). The majority of children of military 
families in the United States attend public schools. A 2008 DOD study 
recommended offering military families a public charter school option 
in areas with poorly-performing local schools. In response to a 
directive in a House Appropriations Committee report, GAO examined: 
(1) the characteristics and origins of charter schools on military 
installations, and (2) the challenges charter schools on military 
installations have faced in starting up and continuing their 
operations. 

To conduct this review, GAO interviewed officials in the eight charter 
schools on domestic military bases and one school being planned; 
visited two schools; interviewed Education and DOD officials; and 
reviewed relevant federal laws and school, federal agency, and other 
documents. 

What GAO Found: 

Eight charter schools were located on domestic military bases and one 
charter school was being developed on a base at the time of GAO’s 
review. The military base charter schools differed in their academic 
focuses and served military-connected students to different degrees. 
For example, one school focused on science, technology, engineering, 
and mathematics while another used the arts to teach all subjects. 
Enrollment of military-connected students at these base charter 
schools ranged from 42 percent to 90 percent, and three schools used 
preferences to ensure a higher proportion of these students. For 
example, one charter school with a stated mission of educating 
military-connected children gave first preference to children of 
active-duty personnel, who represented the preponderance of enrolled 
students. The schools were established to address different interests, 
including family perceptions about the quality of education in local 
school districts and military officials’ need to attract and retain 
military families to bases. In some instances the impetus for 
establishing a charter school on a military base originated with 
private entities. For example, a private developer hired to build 
housing on the base worked with a charter management organization to 
develop a charter school they thought would make living on the base 
more attractive to military families. 

Charter school officials cited several challenges to starting up and 
operating on military bases, such as using enrollment preferences for 
military-connected students, providing civilian access to schools, and 
obtaining facilities. Most states require schools to be open to all 
students, and when organizers of one school sought to enroll solely 
military-connected students, state law prohibited this because of the 
state’s open enrollment requirements. Some states have changed or 
interpreted their charter school laws to enable schools to give 
enrollment preference to military-connected students. Furthermore, two 
charter schools that have enrollment preferences for military- 
connected students have received Department of Education (Education) 
Charter Schools Program (CSP) grants, which require charter schools to 
provide all students an equal opportunity to attend the school and 
admit students by lottery if there are more applicants than spaces 
available. Although these military base charter schools have received 
these grants, Education has expressed concern that the use of such 
enrollment preferences would violate CSP program requirements. Charter 
schools have also encountered operational challenges. For example, 
access for civilians can be difficult. Nearly all the military base 
charter schools were located behind the base’s security gate, 
requiring civilians to complete a background check and show a pass. 
Several school officials reported difficulties conducting school 
activities such as open houses and sporting events because each base 
had a limit on the number of security passes for civilians. Like other 
charter schools, military base charter school officials also reported 
obstacles to obtaining facilities, such as financing. However, they 
also encountered unique challenges, such as complex military facility 
and land leases. Several school and military base officials said that 
having guidance and more information sharing could help with startup 
and operational challenges charter schools on military bases face. 
However, there is currently little guidance or information sharing 
about military base charter schools. 

What GAO Recommends: 

GAO recommends that Education clarify whether military base charter 
schools that use enrollment preferences are eligible for charter 
school grants and that DOD and Education take actions to help address 
startup and operational challenges for these schools. In their 
responses, DOD and Education agreed with GAO’s recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-13-67]. For more 
information, contact George A. Scott (202) 512-7215 or scottg@gao.gov. 

[End of section] 

Letter: 

Background: 

Charter Schools on Military Bases Enrolled Military-Connected Students 
to Varying Degrees and Were Started in Response to Family, Military, 
and Private Interests: 

Charter Schools on Military Bases Faced Challenges with Enrollment 
Preferences, Civilian Access to Schools, and Facilities: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Charter School Profiles: 

Appendix II: Air Force Guidelines and Information on Charter Schools: 

Appendix III: Comments from the U.S. Department of Defense: 

Appendix IV: Comments from the U.S. Department of Education: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Characteristics of Charter Schools on Domestic U.S. Military 
Bases: 

Table 2: Enrollment Preferences for Military-Connected Students at 
Charter Schools on U.S. Military Bases: 

Table 3: Enrollment Preferences for Belle Chasse Academy: 

Table 4: Military Base Charter School Facility Types and Funding 
Sources: 

Figures: 

Figure 1: Charter Schools on Military Bases in the United States: 

Figure 2: Timeline of Charter School Startups on Domestic Military 
Bases: 

Figure 3: Percentage of Military-Connected and Civilian Students at 
Charter Schools on Military Bases in the United States in School Year 
2011-12: 

Abbreviations: 

BRAC: Base Realignment and Closure: 

CCD: Common Core of Data: 

CMO: charter management organization: 

CSDC: Charter School Development Corporation: 

CSP: Charter Schools Program: 

DOD: Department of Defense: 

ESEA: Elementary and Secondary Education Act of 1965: 

IDEA: Individuals with Disabilities Education Act: 

LEA: local educational agency: 

MOU: memorandum of understanding: 

SEA: state educational agency: 

STEM: science, technology, engineering, and mathematics: 

United States Government Accountability Office: 
Washington, DC 20548: 

February 5, 2013: 

The Honorable Chairman:
The Honorable Ranking Member:
Subcommittee on Military Construction, Veterans' Affairs, and Related 
Agencies: Committee on Appropriations:
United States Senate: 

The Honorable John Culberson:
Chairman:
The Honorable Sanford D. Bishop, Jr.
Ranking Member:
Subcommittee on Military Construction, Veterans' Affairs, and Related 
Agencies: Committee on Appropriations:
House of Representatives: 

Many families struggle to balance their job demands with ensuring that 
their children have access to high-quality education, but for military 
families this struggle can be exacerbated by the highly mobile nature 
of their service and the consequences of their mobility on the 
emotional and social well-being of their children.[Footnote 1] 
Military families often move every 2 to 3 years as parents are 
reassigned from one duty station to another, which can be disruptive 
for children's education. Military families' concerns about the 
availability and quality of public elementary and secondary education 
options for their children affect readiness, job satisfaction, and 
retention, according to a recent report for the Department of Defense 
(DOD).[Footnote 2] While nearly 80 percent of children in military 
families attend public schools, according to DOD, another DOD report 
recommended that parents be allowed to form charter schools on 
military bases. The report indicated that charter schools on bases 
could offer another educational option for military children in 
geographic areas with underperforming public schools in addition to 
private schools or home schooling.[Footnote 3] Charter schools are 
publicly-funded, independently-operated public schools that are 
allowed to operate with more autonomy than traditional public schools 
in exchange for increased accountability for student academic 
achievement. 

In response to concerns that children of military families in 
underperforming school districts have few alternatives to traditional 
public schools, a House Appropriations Committee Report required that 
GAO conduct a study of charter schools located on military 
installations.[Footnote 4] For this study, we examined the following: 

(1) the characteristics and origins of charter schools on military 
installations, and: 

(2)the challenges charter schools on military installations have faced 
in starting up and continuing their operations. 

To conduct this review, we interviewed school officials at all eight 
charter schools operating on domestic military bases and conducted 
site visits to two of these schools.[Footnote 5] At the two site visit 
schools, located in Louisiana and Maryland, we interviewed school 
administrators, military base commanders and school liaison officers, 
charter management officials, parent representatives, and others. We 
selected these schools for site visits on the basis of years in 
operation, military-connected student enrollment, local educational 
agency (LEA) status, and enrollment size.[Footnote 6] For the eighth 
charter school at Naval Station Great Lakes, we interviewed DOD 
headquarters and regional installation officials to obtain information 
about the school's origins since the school recently opened but was 
under development during our period of data collection. We also 
interviewed military officials knowledgeable about a charter school 
currently being planned for Fort Bragg. 

We reviewed charter school applications and other documentation as 
appropriate for the eight schools as well as available documentation 
on the one school in development. We focused on charter schools on 
domestic installations because charter schools are authorized by 
individual states and do not exist outside the United States. We also 
interviewed Department of Education (Education) and DOD officials 
about charter school program requirements, the educational needs of 
military-connected children, and federal funding for these schools and 
reviewed federal agency data and reports on these issues. We 
interviewed experts from relevant educational and military 
organizations. The most complete data set available at the time of our 
review--Education's Common Core of Data Public Elementary/Secondary 
School Universe Survey (CCD)--was collected for school year 2009-2010, 
and three of the eight military base charter schools we reviewed 
opened after that school year. Therefore, to develop current 
information on the characteristics of these military base charter 
schools, we first obtained school data reported in DOD's Report on 
Charter Schools on Military Installations (July 2012). Because these 
data had been compiled from multiple sources, including military base 
charter schools, we contacted military base charter school 
administrators to confirm the accuracy of their charter school 
characteristics, including year established, grade range, LEA status, 
enrollment level of military-connected students, and other 
characteristics and to obtain supplemental information as needed. We 
determined that the steps we took ensured that these data were 
sufficiently reliable for our purposes. We also used data from 
Education's CCD and the Private School Universe Survey for school year 
2009-10 to develop maps showing schools surrounding the military bases 
that have charter schools. Finally, in addition to reviewing charter 
school literature and other background materials, we reviewed relevant 
federal laws, regulations, and guidance, as well as state laws on 
charter schools, including the eight states that had existing or 
planned military base charter schools: Arizona, Arkansas, California, 
Florida, Illinois, Louisiana, Maryland, and North Carolina. 

We conducted this performance audit from April 2012 through February 
2013 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. 

Background: 

There are about 1.2 million school-age children of military-connected 
families, and the majority of students attend public and private 
schools located off military bases.[Footnote 7] In addition to these 
off-base options, several school options are available on military 
bases for military-connected children, including traditional public 
schools, DOD-operated schools, and, more recently, public charter 
schools.[Footnote 8] These options are described below. 

* Traditional public schools: Approximately 160 traditional public 
schools operated by local school districts are located on military 
bases in the United States. According to DOD, 94 percent of students 
attending public schools on military bases are military-connected 
children. Traditional public schools are generally open to all 
students in the geographic area they serve. 

* DOD-operated schools: Although the majority of DOD schools are 
located overseas, 64 DOD schools currently operate on military bases 
in the United States,[Footnote 9] and these domestic DOD schools 
enroll about 28,000 students. DOD schools--open only to eligible 
dependents of active duty military and DOD civilians who reside on 
military installations--constitute a separate school system 
administered by the Department of Defense Education Activity (DoDEA). 
Domestic DOD schools were established to educate military children in 
communities where the local schools were deemed unable to provide a 
suitable education, among other reasons. DOD school systems depend 
almost entirely on federal funds, unlike public schools, which are 
funded primarily with local and state taxes and for which federal 
funding constitutes a small portion of total resources. As we noted in 
an earlier study, questions have been raised periodically concerning 
the continuing need for DOD schools.[Footnote 10] DOD has commissioned 
various studies since the 1980s exploring the possibility of 
transferring DOD schools to local school districts, and over the 
years, DOD has transferred some DOD schools to local public school 
districts.[Footnote 11] 

* Charter schools: Charter schools are a relatively new option for 
students. These schools are public schools created to achieve a number 
of goals, including encouraging innovation in public education, 
providing an alternative to poor performing schools, and giving 
families an additional educational option to traditional public 
schools. Charter schools operate with more autonomy than traditional 
public schools in exchange for agreeing to improve student 
achievement, an agreement that is formalized in a contract or charter 
with the school's authorizing body. A school's charter defines the 
specific academic goals and outlines school finances and other aspects 
of operation. Charter schools provide students and parents with 
increased educational options. However, research has found 
considerable variability in charter school performance on student 
achievement.[Footnote 12] 

Enrollment and interest in charter schools has grown rapidly in the 
past few years. According to the National Center for Education 
Statistics, the number of students enrolled in public charter schools 
more than quadrupled, from 0.3 million to 1.6 million students between 
school years 1999-2000 and 2009-2010, while the percentage of all 
public schools that were public charter schools increased from 2 to 5 
percent. In the 2009-2010 school year, about 5,000 charter schools 
operated in 40 states and the District of Columbia.[Footnote 13] 
Meanwhile parental interest in this public school option has also 
grown. According to a survey conducted by one national charter school 
organization, nearly two-thirds of charter schools across the nation 
reported having children on their waiting list, with an average 
waiting list totaling 228 students.[Footnote 14] 

The 2008 DOD report on military compensation recommended that military-
connected parents be allowed to form charter schools on military 
bases. The 2008 DOD report indicated that offering a charter school 
option in areas with underperforming local public schools would give 
parents stationed in those locations another choice in addition to the 
private school or home schooling options that may currently exist. 
This recommendation was part of the report's broader emphasis on the 
need to increase service members' choices in order to enhance 
recruiting and retention efforts in the uniformed services and, 
ultimately, support military readiness. 

Charter School Operations and Funding: 

Charter schools are established according to individual state charter 
school laws, and these state laws determine how schools operate and 
are funded. Depending on the state, a range of groups and 
organizations can establish a charter school, including parents, 
educators, private nonprofit organizations, and universities. A 
significant portion of charter schools nationally are established or 
operated by private management organizations, such as charter 
management organizations (CMO).[Footnote 15] According to one research 
institute, in the 2010-2011 school year, 35 percent of all public 
charter schools were operated by such private management 
organizations, and these schools accounted for almost 42 percent of 
all students enrolled in charter schools.[Footnote 16] States also set 
requirements for how charter schools operate. For example, most state 
charter school laws generally require that charter schools be open to 
all students within a specified boundary (commonly referred to as 
"open enrollment" requirements). In addition, most state charter 
school laws generally require that charter schools that receive more 
student applications than have available classroom spaces must enroll 
students based upon a lottery or some other random selection process 
to ensure that enrollment to the school is fair and does not favor 
particular groups of students. States also specify which entities can 
authorize the establishment of a charter school, including state 
departments of education, state boards of education, school districts 
or local educational agencies (LEA), institutions of higher education, 
and municipal governments. Authorizers are responsible for monitoring 
school performance and have the authority to close schools or take 
other actions if academic goals and state financial requirements are 
not met. States also define how charter schools are structured. For 
example, unlike traditional public schools that are generally part of 
a larger LEA, some states establish charter schools as their own LEA 
while others allow schools to choose between being a distinct LEA or 
part of a larger LEA for certain purposes, such as special education. 
In general, schools that operate as separate LEAs may be able to 
directly obtain federal funds or apply for federal grants that would 
otherwise be distributed among schools in a larger LEA.[Footnote 17] 
It may, therefore, be financially advantageous for schools to be 
separate LEAs, although this advantage also comes with the added 
responsibility associated with LEAs. Finally, states determine how 
charter schools will be publicly funded. In most states, charter 
schools are largely funded according to the formula states use for 
traditional public schools, usually a per-pupil allocation based on 
student attendance. As public schools, charter schools are also 
eligible to receive formula funding from some federal programs, such 
as those authorized by the Individuals with Disabilities Education Act 
(IDEA) and Title I of the Elementary and Secondary Education Act. 
[Footnote 18] 

Federal Resources Available to Charter Schools on Military Bases: 

DOD and Education have had a formal memorandum of understanding (MOU) 
since 2008 to collaborate on addressing the educational needs and 
unique challenges faced by children of military families, including 
serving as a resource for communities exploring alternative school 
options, such as charter schools. 

In addition, a number of federal resources are available that may be 
used to assist in starting and operating charter schools, some of 
which focus on schools serving military-connected students, among 
others: 

* Impact Aid: Education and DOD administer Impact Aid programs 
[Footnote 19] that provide qualifying LEAs--encompassing both 
traditional public schools and charter schools--with funds to 
compensate LEAs for revenue losses resulting from federal activities 
and to help students connected with these federal activities--which 
may include military-connected students--meet state academic 
standards.[Footnote 20] Appropriations for Education's Impact Aid 
program were almost $1.3 billion in fiscal year 2010, and Congress 
appropriated $40 million in additional funding for DOD Impact Aid in 
2012. One type of Impact Aid grant is designed to support the 
construction and repair of school buildings and is awarded to LEAs on 
a competitive basis. 

* DOD grants: 

- DOD provides discretionary grants--about $50 million in grants to 38 
military-connected school districts for fiscal year 2012--for 
enhancing student learning opportunities, student achievement, and 
educator professional development at military-connected schools, as 
well as about $9 million for math, science, English, and foreign 
language programs affecting military-connected students. 

- DOD is authorized to provide up to $250 million to make grants, 
conclude cooperative agreements, or supplement other federal funds to 
construct, renovate, repair, or expand elementary and secondary public 
schools on military installations in order to address capacity or 
facility condition deficiencies at such schools.[Footnote 21] The 
Consolidated Appropriations Act, 2012, provided an additional $250 
million for DOD to continue addressing capacity and condition issues 
of public schools on military installations.[Footnote 22] 

* Charter Schools Program resources: Education also provides supports 
and resources through its Charter Schools Program (CSP).[Footnote 23] 

- CSP provides funds--about $255 million in fiscal year 2012--to 
create high-quality charter schools, disseminate information about 
effective schools, and support the replication and expansion of 
successful schools, among other purposes. In applying for grants for 
state education agencies, state agencies must describe, among other 
things, how they will disseminate information about effective schools 
and how students in the community will be given an equal opportunity 
to attend the charter school.[Footnote 24] A 2011 White House report 
details an agency-wide effort to develop a coordinated approach to 
supporting military families.[Footnote 25] One specific administration 
commitment is for Education to make supporting military families one 
of its supplemental priorities for its discretionary grant programs. 
This priority, which has been implemented, favors grant applications 
to meet the needs of military-connected students. 

- CSP funds a number of organizations, including the National Charter 
School Resource Center and the National Resource Center on Charter 
School Finance and Governance, which provide a diverse range of 
information on charter schools. 

Charter Schools on Military Bases Enrolled Military-Connected Students 
to Varying Degrees and Were Started in Response to Family, Military, 
and Private Interests: 

While most schools located on military bases were traditional public 
schools or DOD schools, eight were charter schools at the time of our 
review. The military base charter schools differed among themselves in 
their academic focuses and in the number of military-connected 
children they served. In addition to the eight schools, most of which 
were located on Air Force bases or on joint Air Force/Navy bases, 
another charter school was being developed on the Fort Bragg Army base 
at the time of our review (see figure 1).[Footnote 26] 

Figure 1: Charter Schools on Military Bases in the United States: 

[Refer to PDF for image: illustrated U.S. map] 

Beale AFB (California): Wheatland Charter Academy; 
Davis-Monthan AFB (Arizona): Sonoran Science Academy; 
Fort Bragg (North Carolina): Fort Bragg Regional High School; 
Joint Base Andrews (Maryland): Imagine Andrews Public Charter School; 
Little Rock AFB (Arkansas): Jacksonville Lighthouse Charter School: 
Flightline Upper Academy; 
Naval Station Great Lakes (Illinois): LEARN 6 in North Chicago; 
NAS/JRB New Orleans (Louisiana): Belle Chasse Academy; 
NAS Key West (Florida): Sigsbee Charter School; 
Vandenberg AFB (California): Manzanita Public Charter School. 

Source: GAO analysis of Department of Defense data; National Atlas of 
the United States (base map). 

[End of figure] 

Most military base charter schools opened after 2008, following DOD's 
Quadrennial Review that recommended parents be allowed to form charter 
schools on bases to provide another educational option for military 
children in geographic areas with underperforming public schools, in 
addition to private schools or home schooling options (see figure 2). 

Figure 2: Timeline of Charter School Startups on Domestic Military 
Bases: 

[Refer to PDF for image: timeline] 

2001: 
Wheatland Charter Academy (California); 

2002: 
Belle Chasse Academy (Louisiana); 

2008: 
The Department of Defense recommends that parents be allowed to form 
charter schools on military bases; 
Manzanita Public Charter School (California); 

2009: 
Sonoran Science Academy-Davis-Monthan (Arizona); 

2010: 
Sigsbee Charter School (Florida); 

2011: 
Imagine Andrews Public Charter School (Maryland); 
Jacksonville Lighthouse Charter School Flightline Upper Academy 
(Arkansas); 

2012: 
LEARN 6 in North Chicago (Illinois); 

In development: 
Fort Bragg Regional High School (North Carolina). 

Source: GAO analysis of Department of Defense and charter schools' 
data. 

[End of figure] 

Charter Schools on Military Bases Offer Different Academic Focuses: 

Like many charter schools located in public school districts across 
the country, many of the eight schools on military bases offered a 
program with a particular academic focus (see table 1). For example, 
Sonoran Science Academy, the only charter school currently on a 
military base that serves children from grade 6 through grade 10, 
offers a college preparatory program with a focus on science, 
technology, engineering, and mathematics subjects (STEM). In school 
year 2011-12, Sonoran Science Academy served 185 children in grades 6 
through 10 and plans to expand through the 12th grade by adding a 
grade each year. Manzanita Public Charter School offered a program for 
children learning English in which classes are taught in both English 
and the children's home language, known as a dual immersion language 
program. The program's goal was to support bilingualism and bi-
literacy. Located on Vandenberg Air Force Base, but outside the base's 
security gate, Manzanita Public Charter School served 438 students in 
school year 2011-12. Sigsbee Charter School in Key West draws on the 
school's location to offer an environmental education program with a 
focus on marine studies. The only one of the eight schools on a 
military base to offer a pre-kindergarten program, Sigsbee served 410 
children through grade 7 in school year 2011-12. In Arkansas on the 
Little Rock Air Force Base, Flightline Upper Academy chose a 
curriculum in which the arts are used to teach all subjects. The 
school served 164 students in grades 5 through 8 in school year 2011-
12. Both of these schools--Sigsbee and Flightline--are located behind 
the security gate on their respective military bases. Table 1 provides 
information on the characteristics of the eight charter schools. 
[Footnote 27] 

Table 1: Characteristics of Charter Schools on Domestic U.S. Military 
Bases: 

School: Belle Chasse Academy; 
Military installation and state: Naval Air Station Joint Reserve Base, 
New Orleans, Louisiana; 
School mission/vision: The mission of Belle Chasse Academy is to 
educate our military-dependent children, no matter what their 
background or previous school experience, to fully achieve their 
personal and academic potential; 
Academic focus: Comprehensive core curriculum in liberal arts; 
Grades: K-8; 
Operations: Independent; 
Total enrollment in SY 2011-12: 942. 

School: Imagine Andrews Public Charter School; 
Military installation and state: Joint Base Andrews, Maryland; 
School mission/vision: Our mission is to serve our nation by providing 
the students of the Andrews Community with a "world class" education, 
while meeting the needs of military families; 
Academic focus: Liberal arts program; 
Grades: K-4[A]; 
Operations: CMO (Imagine Schools); 
Total enrollment in SY 2011-12: 265. 

School: Jacksonville Lighthouse Charter School: Flightline Upper 
Academy; 
Military installation and state: Little Rock Air Force Base, Arkansas; 
School mission/vision: We prepare our students for college through a 
rigorous arts-infused program; 
Academic focus: Arts-infused Curriculum; 
Grades: 5-8[A]; 
Operations: CMO; (Lighthouse Academies); 
Total enrollment in SY 2011-12: 164. 

School: LEARN 6 in North Chicago; 
Military installation and state: Naval Station Great Lakes,; 
Illinois; 
School mission/vision: Our mission is to provide children with the 
academic foundation and ambition to earn a college degree; 
Academic focus: College preparation; 
Grades: K-2 and 6-7[A]; 
Operations: CMO (LEARN Charter School Network); 
Total enrollment in SY 2011-12: [B]. 

School: Manzanita Public Charter School; 
Military installation and state: Vandenberg Air Force Base, California; 
School mission/vision: We are dedicated to advancing academic 
excellence in Lompoc by providing students in kindergarten through 
sixth grade with the intellectual capacity to participate and work 
productively in a multicultural society; 
Academic focus: Dual immersion language program; 
Grades: K-6; 
Operations: Independent; 
Total enrollment in SY 2011-12: 438. 

School: Sigsbee Charter School; 
Military installation and state: Naval Air Station Key West, Florida; 
School mission/vision: To provide each child with the opportunities 
and skill sets to realize his or her fullest potential in surroundings 
tailored to meet the needs of the transient military child as well as 
to provide another option for children in the Key West community; 
Academic focus: Environmental studies, with focus on marine studies; 
Grades: PK-7; 
Operations: Independent; 
Total enrollment in SY 2011-12: 410. 

School: Sonoran Science Academy; 
Military installation and state: Davis-Monthan Air Force Base, Arizona; 
School mission/vision: The Mission of Sonoran Schools is to provide a 
rigorous college-prep, STEM-focused education through a challenging 
and comprehensive curriculum, continuous assessment, and dedicated 
teachers who inspire their students to become the leaders of tomorrow; 
Academic focus: Science, technology, engineering, and mathematics; 
Grades: 6-10[A]; 
Operations: CMO; (Sonoran Schools); 
Total enrollment in SY 2011-12: 185. 

School: Wheatland Charter Academy; 
Military installation and state: Beale Air Force Base, California; 
School mission/vision: None; 
Academic focus: Montessori-blended curriculum; 
Grades: K-5; 
Operations: Independent; 
Total enrollment in SY 2011-12: 104. 

Source: GAO analysis of information from military base charter schools: 

[A] School plans to expand grades it will offer. 

[B] SY 2011-12 enrollment data for LEARN 6 in North Chicago was 
unavailable because this school just opened for the SY 2012-13 session. 

[End of table] 

Most Base Charter Schools Served Predominantly Military-Connected 
Students: 

While the charter schools' academic focuses differed considerably, 
most military base charter schools served predominantly children of 
military-connected families and some of these schools took various 
steps to attract these students. For example, the largest charter 
school operating on a base, the Belle Chasse Academy, serves more than 
900 elementary and middle school children. To address the needs 
associated with high mobility and parental deployments that military-
connected students experience, Belle Chasse Academy offers 
psychological and other counseling services, welcome clubs, and a 
buddy program to ease an incoming student's transition to Belle Chasse 
Academy. With 90 percent of its students coming from military 
families, Belle Chase Academy has the largest percentage of military-
connected children of the schools currently in operation. While the 
children of civilians can attend the school, which is located inside 
the security gate on the Naval Air Station Joint Reserve Base New 
Orleans, Belle Chase Academy officials told us they initially took 
several steps to attract children of military personnel. For example, 
they held multiple town meetings for military families, distributed 
flyers on the base, and posted notices on the school's website 
encouraging military-connected families to enroll their children as 
soon as the service member receives his or her orders (see text box.) 
Belle Chasse Academy officials said the Academy is well-known now and 
they no longer have to conduct as much outreach. 

[Text box: 
Belle Chasse Academy: Promoting Early Enrollment of Military-Connected 
Students: 
The Belle Chasse Academy includes the following announcement on its 
website: 
...Active-duty personnel are enjoined to register their children to 
attend Belle Chasse Academy as soon as they are in receipt of orders. 
This enables the school to plan effectively and ensures that your 
student has a space in the appropriate grade and setting. BCA is space-
limited, and we cannot ensure that every dependent of active-duty 
personnel has space unless you assist us in planning. We are an open-
enrollment school, so unless we have reserved a spot for your student, 
we must admit students who apply if there is a vacancy. Thanks for 
your cooperation. 
Source: [hyperlink, http://www.bellechasseacademy.org], downloaded 
Sept. 28, 2012. End of text box] 

Imagine Andrews and Sigsbee charter schools also considered educating 
the children of military-connected families an integral component of 
their mission. Sigsbee Charter School officials described the children 
of military-connected families as "central to the school's mission" 
and said they offered services geared to the needs of this transient 
population. For example, the school has a military life counselor 
available to children with an active-duty parent, who holds small 
group sessions that address family stress, deployment, and issues 
related to moving.[Footnote 28] Sigsbee officials also told us they 
work closely with a professional organization that provides services 
to educators working with military-connected children and send the 
school's staff to professional development sponsored by this 
organization. Imagine Andrews, where two-thirds of its students come 
from military-connected families, offers a range of services for these 
children: for example, according to the school's website, Imagine 
Andrews staff receives in-depth professional development on how to 
recognize the warning signs of the stressors faced by students in 
military-connected families and how to help those students deal 
effectively with the challenges they encounter. While Sonoran Science 
Academy does not specifically state that serving the children of 
military-connected families is part of its mission, it enrolled a high 
percentage of these children and provided services geared to their 
needs. For example, the school provides a full-time counselor and 
offers a buddy program for military-connected students transferring 
into the school, a self-esteem program, and a support group for 
students with a recently-deployed parent. Located inside the gate on 
the Davis-Monthan Air Force Base in Arizona, Sonoran Science Academy 
has a student body that includes 76 percent military-connected 
students. (See figure 3). 

Figure 3: Percentage of Military-Connected and Civilian Students at 
Charter Schools on Military Bases in the United States in School Year 
2011-12: 

[Refer to PDF for image: horizontal bar graph] 

School: Belle Chasse Academy; 
Location: NAS/JRB New Orleans (Louisiana); 
Percentage of civilian students: 10%; 
Percentage of military-connected students: 90%. 

School: Sonoran Science Academy-Davis Monthan; 
Location: Davis-Monthan AFB (Arizona); 
Percentage of civilian students: 24%; 
Percentage of military-connected students: 76%. 

School: Wheatland Charter Academy; 
Location: Beale AFB (California); 
Percentage of civilian students: 29%; 
Percentage of military-connected students: 71%. 

School: Sigsbee Charter School[A]; 
Location: NAS Key West (Florida); 
Percentage of civilian students: 20-30%; 
Percentage of military-connected students: 70-80%. 

School: Imagine Andrews Public Charter School; 
Location: Joint Base Andrews (Maryland); 
Percentage of civilian students: 35%; 
Percentage of military-connected students: 65%. 

School: Jacksonville Lighthouse Charter School: Flightline Upper 
Academy; 
Location: Little Rock AFB (Arkansas); 
Percentage of civilian students: 50%; 
Percentage of military-connected students: 50%. 

School: Manzanita Public Charter School; 
Location: Vandenberg AFB (California); 
Percentage of civilian students: 58%; 
Percentage of military-connected students: 42%. 

Source: AGO analysis of school-reported data. 

Note: Enrollment data for LEARN 6 in North Chicago were unavailable 
because the school opened in SY 2012-13. 

[A] Sigsbee Charter School provided an estimate ranging from 70-80 
percent military-connected students. 

[End of figure] 

In addition, three schools used enrollment preferences to ensure the 
children of military-connected families had a greater chance of 
securing a place in the school: Belle Chasse Academy, Imagine Andrews, 
and Sigsbee. These schools were among the five schools with the 
highest enrollment of students from military-connected families. 

Family and Military Needs and Private Interests Were Among Key Reasons 
for Establishing Charter Schools: 

While all of the charter schools on military bases serve a large 
percentage of military-connected students, they were started for 
various reasons, including family perceptions about the quality of 
education available for their children in local school districts and 
military officials' need to attract and retain military families to 
bases. Moreover, in some instances the impetus for establishing a 
charter school on a military base originated with private housing 
developers on military bases and charter management organizations. 

At Imagine Andrews and other schools, school officials told us some 
parents expressed reservations about enrolling their child in local 
public schools due to the perception that those schools were of poor 
quality. As a result, many military families chose to live off-base, 
which allowed their children access to other districts they believed 
had higher quality schools. For example, one Belle Chasse Academy 
parent we interviewed said his concerns about the quality of schooling 
available in New Orleans led him to consider refusing assignment to 
the base. Belle Chasse Academy officials also said that some personnel 
accept assignment to the base, but leave their families behind in 
communities they believe provide better educational opportunities for 
their children. In these cases, leaving family behind often negatively 
impacted service members' job readiness and happiness, Belle Chasse 
Academy officials and others noted. Navy officials who helped develop 
LEARN 6 in North Chicago said quality is important because parents 
want assurance that their children will "keep up" in the school in 
which they are currently enrolled and will at least be on grade level 
when they have to transfer to a new school.[Footnote 29] Additional 
parental concerns included children's safety and the schools' 
convenience or proximity to home, according to school officials and 
others. 

Military interests were also significant in the creation of some of 
the charter schools we reviewed. Officials at several schools said 
that base commanders recognized the important role of quality schools 
in attracting and retaining service members on base and that 
commanders' support was critical to charter school development on 
base. For example, at Sonoran Science Academy and Imagine Andrews, 
school officials credited the base commander with being a driving 
force behind the vision of creating a charter school. Furthermore, the 
military Base Realignment and Closure (BRAC) process may contribute to 
growth in the number of military-connected families living on certain 
bases and heighten demand for more schooling options on bases, 
including charter schools.[Footnote 30] At LEARN 6 in North Chicago, 
military and state interests both contributed to the creation of the 
charter school. Partly in response to declines in the military 
population at Naval Station Great Lakes, the state board of education, 
which approved the charter school application, noted that the district 
stood to lose millions of dollars in federal Impact Aid if it did not 
take immediate action to attract and retain military families. 
[Footnote 31] The state board further noted that a charter school 
could help ensure the district's continued eligibility for federal 
Impact Aid funds while offering another public school option for the 
district's students. 

Housing developers and charter management organizations (CMO) also led 
moves to establish some charter schools on military bases, according 
to some school officials we interviewed. For example, housing 
developers at Joint Base Andrews that were hired by the military to 
privatize on-base housing believed that having a charter school on 
base would attract more families to on-base living. The housing 
developers worked with Imagine Schools, the CMO, to develop a charter 
school that would make living on base more attractive. In another 
case, the CMO Lighthouse Academies decided to open a new charter 
school campus--Flightline Upper Academy--when demand for spaces in its 
existing charter school exceeded capacity. Although the new charter 
school was ultimately located on a nearby military base, the CMO's 
original plan was to provide more options for children in the 
community, not to target the children of military-connected families 
for enrollment in the school. 

At Manzanita Charter School, public school educators were the planners 
because they perceived a need for better educational options for the 
children of economically disadvantaged families and English language 
learners. The school's planners told us they had not considered the 
children of military-connected families as a target population for 
enrollment. They said the decision to locate the school on a military 
base was one of necessity--it was the only facility the local 
authorizer offered the charter school organizers. 

Charter Schools on Military Bases Faced Challenges with Enrollment 
Preferences, Civilian Access to Schools, and Facilities: 

Enrollment Preferences for Military-Connected Students Posed Hurdles 
for School Planners: 

While charter schools on military bases encountered some of the same 
challenges as other charter schools around the nation--such as 
acquiring facilities and startup funding--they also experienced 
challenges unique to starting up and operating a charter school on a 
military base. One of these challenges is maintaining slots for 
military students whose parents may move more frequently. 
Specifically, because the high turnover rate among military-connected 
students at military base charter schools could limit enrollment 
access of these students,[Footnote 32] three charter schools provided 
military-connected students with an enrollment preference (see table 
2). 

Table 2: Enrollment Preferences for Military-Connected Students at 
Charter Schools on U.S. Military Bases: 

School: Imagine Andrews Public Charter School; 
Enrollment preference: 
* Dual enrollment system with separate lotteries for children whose 
parents are assigned to and reside on base, up to 65 percentage of the 
school's enrollment, and all other off-base children up to 35 percent 
of the school's enrollment. 

School: Belle Chasse Academy; 
Enrollment preference: 
* Hierarchy of enrollment preferences prioritizes the children of 
active duty military personnel, followed by reservists, retirees, DOD 
employees, staff, and civilians; 
* If there are openings after all active duty applicants are placed 
during initial enrollment period, a lottery is conducted in which all 
eligible remaining students are placed in groups by grade and names 
are drawn until vacancies are filled. 

School: Sigsbee Charter School; 
Enrollment preference: 
* Lottery divided into active duty military families and non-active 
duty military families. Numbers from the active duty list are drawn 
first to determine the order in which applicants will be offered 
positions at each grade level; 
* If spaces are still available, numbers from the non-active duty 
lottery list are drawn. In the event that there are more applicants 
than space available, a waiting list is to be created in the event 
that selected applicants reject a position and their spot becomes 
available. Active duty military dependents are placed at the top of 
this list as they transfer into the area. 

Source: GAO analysis of school information. 

[End of table] 

Planners for Imagine Andrews wanted all of the slots at the school to 
be reserved for military families, according to a CMO representative. 
However, Maryland law requires charter schools to be open to all 
students.[Footnote 33] In 2010 the Maryland legislature revised the 
law to provide an exemption to the open enrollment requirement for 
military base charter schools, as long as students with parents who 
are not assigned to the base constitute at least 35 percent of 
enrollment.[Footnote 34] However, children of military parents who are 
assigned to the base, but live off the base, are grouped with 
civilians because Imagine Andrews also requires residency on the base 
for enrollment preference. Despite the school's military student 
enrollment preference, an Imagine Andrews official said that the 
school would likely encounter concerns about enrollment from military-
connected parents whose children are not able to enroll in the school 
due to limited slots. Similarly, a representative of Belle Chasse 
Academy said the school also explored how they could maintain slots 
for military-connected children. In addition to a stated mission to 
educate military-connected children and its efforts to encourage 
military-connected parents to register their children as soon as they 
are assigned to the base, the school uses a hierarchy of admission 
preferences, with the top six tiers for military-connected students, 
the seventh tier for the children of staff, and the final and eighth 
tier for civilian students (see table 3). According to the official, 
these preferences were allowed as an admission standard under an 
interpretation of the law by the state Attorney General's office, 
which determined that it was acceptable as long as the mission, 
academics, and programs of the school were targeted to military-
connected students. The preferences have enabled the school to 
maintain high military student enrollment--approximately 90 percent in 
SY 2011-12. The official said the school does not generally conduct a 
lottery because it could lead to higher levels of civilian enrollment 
and undermine the school's mission to educate military-connected 
children. 

Table 3: Enrollment Preferences for Belle Chasse Academy: 

Preference: 1st; 
Student whose parents are: Active duty living on base. 

Preference: 2nd; 
Student whose parents are: Active duty waiting for base housing. 

Preference: 3rd; 
Student whose parents are: Active duty living in the community. 

Preference: 4th; 
Student whose parents are: Reservists. 

Preference: 5th; 
Student whose parents are: Retirees. 

Preference: 6th; 
Student whose parents are: DOD. 

Preference: 7th; 
Student whose parents are: Staff. 

Preference: 8th; 
Student whose parents are: Civilian. 

Source: Belle Chasse Academy documents. 

[End of table] 

Sigsbee Charter School also encountered a challenge to ensuring 
enrollment slots for military-connected students. Created prior to 
recent changes in Florida state law that now permit charter schools to 
give enrollment preference to children of an active duty member of any 
branch of the United States Armed Forces,[Footnote 35] the school 
utilized a provision in state law that allows a charter school to give 
enrollment preference to children of workplace employees.[Footnote 36] 
A school official explained that the school considered the base a 
workplace but could not establish a formal business partnership with 
the base because the base does not provide the school with funds. As a 
result, school officials established a formal partnership with the 
base through a memorandum of understanding, which it considered a 
business partnership for the purposes of satisfying the state 
requirement for using the school's enrollment preference. 

Two other schools that wanted to focus on enrolling military-connected 
students, including one school currently in development, did not plan 
to use an enrollment preference because officials said they either 
believed or were told by state education officials it was not 
allowable under state charter school law. For example, a Navy official 
involved with establishing LEARN 6 in North Chicago at Naval Station 
Great Lakes explained that, while planners for the school wanted to 
focus on enrolling military-connected students, Illinois state law 
required the school to be open to all students. According to the 
official, this requirement could pose a long-term challenge to 
maintaining enrollment access for military-connected families. He 
indicated that school stakeholders are currently working to propose 
changes to Illinois state law that would enable the school to use a 
preference for military-connected students at a minimum of one-third 
of the school's enrollment. Similarly, Fort Bragg military officials 
involved with establishing a charter high school on the base said that 
school planners wanted an enrollment preference for military-connected 
students but were told by state education officials that North 
Carolina's charter law does not allow for such a preference. One 
official indicated the CMO planned to challenge the state's 
interpretation of the law. However, even without such a preference, 
base officials noted that the school's prospective location on the 
base would ensure high military-connected student enrollment. 
Officials said that the school did not plan to include transportation 
in its budget. However, they said the school may consider offering fee-
based busing to students living on base--but not to students living 
off base. Doing so could also result in higher military-connected 
student enrollment. 

Of the three schools currently using an enrollment preference for 
military-connected students, Sigsbee Charter School and Imagine 
Andrews received CSP subgrants from their state departments of 
education. As previously noted, both schools used lottery-based 
preferences to enroll military-connected students at higher rates than 
civilian students. The statute authorizing CSP grants requires charter 
schools, as a condition of receiving funding, to admit students on the 
basis of a lottery if more students apply than can be accommodated, 
and to provide a description of how students in the community will be 
given an equal opportunity to attend the charter school.[Footnote 37] 
Education, in its non-regulatory guidance, states that a charter 
school receiving CSP funds must hold one lottery that provides 
qualified students with an equal opportunity to attend the school, but 
also provides for certain exemptions to the lottery requirement. For 
example, the guidance allows certain categories of applicants to be 
exempted, such as the siblings of students, children of a charter 
school's founders, and children of employees in a work-site charter 
school. However, the guidance does not specifically address whether 
schools may exempt military-connected students from a lottery. 
Further, the guidance also states that schools may use weighted 
lotteries, which are lotteries that give preference to one set of 
students over another, but only when they are necessary to comply with 
certain federal laws, such as Title VI of the Civil Rights Act of 
1964,[Footnote 38] or applicable state laws. CSP officials told us 
that there were limits to how lottery preferences can be used. For 
example, a CSP official said that the practice of holding separate 
lotteries for enrolling civilian and military-connected students is 
not consistent with CSP requirements. The official also stated concern 
about enrollment preferences that would significantly limit civilian 
enrollment access to a school. However, another CSP official stated 
that they would not necessarily be aware of the specific enrollment 
practices of Sigsbee Charter School and Imagine Andrews at the time 
the awards were made, in part because both were subgrantees of state 
educational agency (SEA) grants and, under federal regulations, the 
SEA, not Education, is primarily responsible for monitoring subgrant 
activities and ensuring that subgrantees comply with applicable 
federal program requirements.[Footnote 39] However, the official said 
that CSP does not require SEAs to describe the enrollment preferences 
of school subgrantees in their grant applications.[Footnote 40] 

Civilian Access to Schools Limited by Base Security Requirements: 

When charter schools are located on military bases, base security 
requirements can limit access for civilians. Of the eight charter 
schools, six are currently located inside a protected security 
perimeter, which generally requires that civilians pass a background 
check and carry a base pass to access the school. The background check 
for one base school, Imagine Andrews, consists mainly of checking the 
validity of the applicant's driver's license and reviewing any 
recorded criminal history. For this base, passes take about two days 
to process, are valid for one year, and applicants who are denied 
access can appeal the decision. At another charter school, Flightline 
Upper Academy, some civilian parents did not pass the background 
checks required for base access, according to a school official. When 
this happens, however, the official said that school staff can escort 
children to the school. 

Base security requirements can also limit community participation in 
school events and activities. For example, an Imagine Andrews official 
stated that the base restricts each civilian family to three passes, 
which can create a challenge for them during school events, such as an 
honors breakfast or awards ceremony. He noted that military-connected 
families on the base have no such restriction. Further, the official 
noted that the base does not permit civilian access to the school on 
weekends, which would prevent the school from holding extracurricular 
activities, such as morning tutorials or enrichment programs, during 
this time. The official also explained that the school conducted 
certain community outreach events, such as open houses, off-base to 
give off-base civilian families an opportunity to learn about the 
school without requiring access to the base. Similarly, an official 
with Sonoran Science Academy Davis-Monthan said that base restrictions 
on civilian access on weekends prevented them from holding community 
events on the school grounds. As a result, the school rented off-base 
facilities, such as a YMCA. According to the official, the base's 
limitations on public access was the school's most significant 
challenge because it limits the school's ability to establish 
relationships with the community and inform the public about the 
school. 

Two base schools--Manzanita Public Charter School and LEARN 6 in North 
Chicago--were located outside the base security gate and therefore did 
not require base access for civilians. According to a military 
official who assisted with establishing LEARN 6 in North Chicago at 
Naval Station Great Lakes, school organizers and stakeholders 
considered the issue of civilian access to the school prior to its 
opening and were concerned about the possibility that parents of some 
civilian students given slots at the school through the lottery would 
not pass the background check and would not be allowed access to the 
school. As a result, the base command, the school's charter management 
company, and the Illinois State Board of Education jointly agreed that 
the school should be located outside the base security perimeter in 
order for the school to operate on the base. Because the school was 
slated to occupy a former military hospital training facility inside 
the perimeter, the base command arranged to move a section of the 
perimeter so that the school would be located outside it and fully 
accessible to the public. 

Some schools, including Wheatland Charter Academy, Manzanita Public 
Charter School, and LEARN 6 in North Chicago, were located on bases 
that also hosted a traditional public school. While we did not examine 
these or other district-run public schools on bases, we believe 
civilian access to them may similarly be limited as a result of 
military base security requirements.[Footnote 41] 

Obtaining Facilities on Bases Can Be Challenging and Complex for 
Charter School Planners: 

Like charter schools generally, military base charter schools 
encountered difficulties obtaining facilities for school use, and they 
may face additional challenges because of their location on military 
bases (see table 4). As we previously found, securing adequate school 
facilities is one of the greatest challenges for new charter 
schools[Footnote 42] because they typically are not able to rely on 
the same resources for facility financing--such as local taxes and tax-
exempt municipal bonds--as public schools that are operated by school 
districts. We also previously reported that charter schools' access to 
other facility financing options, such as private lending, can also be 
limited. Charter schools are often considered credit risks because 
they may have limited credit histories, lack significant cash flows, 
and have short-term charters that can be revoked. As a result, private 
loans are not easily accessible to charter schools for facility 
financing, so they often rely on state or district per-pupil 
allocations to finance their facilities. 

Table 4: Military Base Charter School Facility Types and Funding 
Sources: 

School: Belle Chasse Academy; 
Installation: Naval Air Station Joint Reserve Base New Orleans, 
Louisiana; 
Facility type: New school construction; 
Primary source of financing: Private bank loan with guaranty from the 
U.S. Department of Agriculture. 

School: Imagine Andrews Public Charter School; 
Installation: Joint Base Andrews-NAF Maryland; 
Facility type: New school construction; 
Primary source of financing: Private bank loan with guaranty from real 
estate developer. 

School: Jacksonville Lighthouse Charter School: Flightline Upper 
Academy; 
Installation: Little Rock AFB, Arkansas; 
Facility type: Converted former military conference center; 
Primary source of financing: Private donations. 

School: LEARN 6 in North Chicago; 
Installation: Naval Station Great Lakes, Illinois; 
Facility type: Converted former military hospital training facility; 
Primary source of financing: Funds provided by the charter management 
organization. 

School: Manzanita Public Charter School; 
Installation: Vandenberg AFB, California; 
Facility type: Current district school building; 
Primary source of financing: School district. 

School: Sigsbee Charter School; 
Installation: Naval Air Station Key West, Florida; 
Facility type: Renovated former district school building; 
Primary source of financing: Per-pupil funds. 

School: Sonoran Science Academy; 
Installation: Davis-Monthan AFB, Arizona; 
Facility type: Former district school building; 
Primary source of financing: No financing reported. 

School: Wheatland Charter Academy; 
Installation: Beale AFB, California; 
Facility type: Renovated current district school building; 
Primary source of financing: School district. 

Source: GAO analysis of charter school information. 

[End of table] 

Two schools we examined encountered challenges initially securing 
financing for the construction of new facilities. According to a Belle 
Chasse Academy official, the school struggled to find a bank that 
could underwrite a long-term loan to build a facility on Naval Air 
Station Joint Reserve Base New Orleans. School planners were 
eventually able to secure a loan after receiving a loan guarantee 
through the U.S. Department of Agriculture Rural Development Community 
Facilities Guaranteed Loan Program. Similarly, construction of a 
school facility for Imagine Andrews was able to start on Joint Base 
Andrews after a loan for this work was secured by the Charter School 
Development Corporation (CSDC)--a non-profit group that helps finance 
charter schools. A representative for the CMO, Imagine Schools, 
indicated that CSDC secured the loan because the CMO had limited 
capacity to finance the construction. CSDC cosigned the loan with the 
CMO, and a private real estate developer guaranteed the loan. 

Securing financing to renovate facilities for charter schools on bases 
was another obstacle for some schools. For example, Sigsbee Charter 
School moved into a former public school facility on Naval Air Station 
Key West that required significant renovation.[Footnote 43] The local 
district provided funds to defray the renovation cost, but these did 
not fully cover the needed repairs. Because none of the grant funds 
the school received could be used to renovate its facility, the school 
relied extensively on local volunteers, including military personnel 
and parents of students who would attend the school, to make many of 
the essential repairs to the facility. According to a school official, 
there are no funds to complete the remaining renovation work. For 
Flightline Upper Academy on Little Rock Air Force Base, school 
planners converted a base facility previously used as a conference 
center and that was slated for demolition. Renovations included 
removing asbestos, replacing old pipes, and repairing the roof. The 
cost of the renovations was paid for primarily through donations from 
a private housing developer and foundations--with no financial 
contributions from the Air Force. A school official noted that the 
school was able to address its main financing needs for facility 
repair prior to opening. However, he stated that the school's 
significant investment in renovating a building it leases from the 
base comes with risk because the Air Force could decide not to renew 
the 5-year lease and take back the building. 

Some school representatives said they also had to navigate complex 
facility and land lease arrangements. With Imagine Andrews, the non-
profit CSDC will own the completed facility and lease it to Imagine 
Schools. The Air Force leased the property to a nonprofit joint 
venture between the Air Force and a private housing developer, which 
in turn leased it to CSDC. Imagine Andrews stakeholders also received 
assistance in structuring the facility financing and land-lease 
agreements from an agency that oversees the housing privatization 
program for the Air Force. A Navy official involved with establishing 
LEARN 6 in North Chicago stated that the real estate arrangements, 
such as the lease for the school site and facility, were complex and 
required the involvement of multiple stakeholders, including the CMO, 
the Navy, and the local municipality. In particular, the official said 
understanding the appropriate support role for the Navy was a 
significant challenge to acquiring the facility for the school. For 
example, the official said it was unclear whether the Navy could 
provide funds for the school site, such as paying for its utilities. 
He noted that guidance on developing a lease agreement for charter 
schools on military bases would be beneficial and could potentially 
have saved school planners significant resources during startup. 

Similarly, other military and school officials cited the need for 
federal guidance and information sharing on starting and operating a 
charter school on a military base. For example, base officials at Fort 
Bragg said that they unsuccessfully sought information from the Army 
that would have helped guide their efforts to establish a charter high 
school on the base, such as liability issues related to operating a 
charter school on federal property. North Carolina state education 
officials denied the school's application because school planners 
revised it after the deadline in order to replace most of the founding 
members on the school's governing board with new members. According to 
state education officials, school planners told them they removed 
these members because a military regulation made them ineligible to 
serve on the school's board. As a result of the application denial, 
the school will not open in 2013 as planned. We also found that 
currently, little guidance and information sharing exist for guiding 
the development of military base charter schools and addressing their 
startup and operational challenges and the guidance that does exist is 
not DOD-wide. While the Air Force produced guidance to support 
community efforts to develop charter schools on its bases, it does not 
apply to other military service bases.[Footnote 44] Army officials 
said they are currently developing charter school guidance for bases, 
which they plan to distribute in January 2013. Further, while 
Education and DOD have taken initial steps to support information 
sharing on developing charter schools on military bases--such as 
Education conducting outreach efforts with school planners and 
stakeholders at Naval Station Great Lakes and DOD and Education 
providing online information--some school officials suggested more 
information sharing could be helpful. For example, according to an 
official at Sigsbee Charter School, which opened 2 years ago, school 
planners found the information Belle Chasse Academy representatives 
provided on establishing on school on a base to be valuable for their 
own efforts. The official noted that more information sharing in this 
area would be useful. 

Conclusions: 

Against the backdrop of a growing and diverse charter school 
landscape, charter schools on military bases have emerged as one 
additional option for military-connected parents. How rapidly charter 
schools will spread to other military bases is difficult to predict, 
but demand among military families and base communities for more 
military base charter schools will likely increase, especially in 
light of residential growth on bases affected by military Base 
Realignment and Closure. While the number of charter schools operating 
on military bases is currently small, they present a novel set of 
challenges for charter school founders and operators as well as an 
opportunity for Education and DOD to be in the forefront of emergent 
issues for these charter schools. One issue that the various 
stakeholders may well confront is the tension between preserving the 
public mission of charter schools of being open to all students and 
the desire in military base communities to ensure enrollment of 
military-connected students. This tension is already emerging as some 
charter schools use enrollment preferences to ensure continued 
enrollment access for highly mobile military-connected students. Using 
such enrollment preferences could have implications for whether or not 
a charter school is eligible for federal CSP grant funding. Although 
Education officials have expressed concern to us over some charter 
schools' enrollment preferences and practices, CSP guidance does not 
specifically address the issue of enrollment preference for military-
connected students. Moreover, in two cases, CSP subgrants were awarded 
by states to charter schools about which Education expressed concerns 
because of the nature of their enrollment preferences. However, 
Education does not require SEA applicants for CSP grants to indicate 
whether schools use enrollment preferences and, if so, to describe 
those preferences. Such a requirement would allow Education and the 
states to better determine if an applicant is eligible to receive CSP 
funds. 

Finally, as charter school planners, authorizers, and military base 
commands consider adding schools on bases, they could benefit from 
having information to help them better weigh the tradeoffs of locating 
charter schools on bases, including the need for community outreach 
and civilian access to schools. The 2008 MOU between DOD and Education 
was intended, in part, to facilitate this kind of information 
development. Such information would also help them address the types 
of challenges current schools have encountered. As existing charter 
schools have discovered, determining DOD requirements and allowable 
practices--such as the role of base command--was often difficult. 
Having guidance from DOD on appropriate ways to establish and operate 
charter schools on military bases may help mitigate these common 
challenges and smooth school startups and operations. Military base 
charter schools that have experienced some of these stumbling blocks 
could share useful information with planners of charter schools in 
other military base communities--such as information about making 
facilities and lease arrangements, and building effective working 
relationships between school administrators and base command. 

Recommendations for Executive Action: 

Education: 

To ensure that Charter Schools Program grants are provided only to 
schools that meet eligibility criteria, we recommend that the 
Secretary of Education direct the Charter Schools Program office to 
revise the Charter Schools Program guidance to: 

* Clarify CSP grant requirements regarding charter school enrollment 
preferences, including preferences for military-connected students, 
such as whether schools can hold separate lotteries for military-
connected and civilian students and the extent to which schools can 
enroll military-connected students under work-site exemptions, and: 

* Require applicants for CSP grants and subgrants to describe any 
enrollment preferences in their applications. 

DOD: 

To address the specific needs of military communities that charter 
schools on bases serve while preserving the public mission of charter 
schools, we recommend that the Secretary of Defense develop and set 
standards for operating charter schools on military bases and require 
the appropriate military services to create guidance based on those 
standards. The guidance should describe the requirements and allowable 
practices for establishing and operating charter schools on military 
bases. At a minimum, this guidance should address the following areas: 

* The appropriate role of military base command and other DOD offices 
and agencies in supporting the creation and operation of charter 
schools; 

* Reasonable base access and security arrangements for civilian 
children, parents, and others involved in a military base charter 
school; and: 

* Military lease arrangements and other property-related issues for a 
charter school on a base. 

DOD and Education: 

To serve as a resource for military base communities exploring 
educational options, as stated in their 2008 Memorandum of 
Understanding, we also recommend that the Secretaries of DOD and 
Education facilitate the sharing of information among interested 
parties--such as base commanders and school planners and officials--on 
how military base charter schools have addressed startup and 
operational challenges. 

Agency Comments and Our Evaluation: 

We provided a draft copy of this report to DOD and Education for 
review and comment. DOD's comments are reproduced in appendix III and 
Education's comments are in appendix IV. The agencies generally agreed 
with our recommendations, and Education described its plans for 
implementing them. Specifically, in response to our recommendation to 
clarify CSP grant guidance, Education stated that it will review its 
current non-regulatory guidance to determine how it can clarify 
admissions and lottery requirements for military-base charter schools 
that receive CSP funds. With respect to the two charter schools noted 
in our report that had enrollment preferences but received CSP grants 
from their states, Education said that the schools' receipt of these 
grants raises compliance questions. Education has asked the states to 
conduct reviews of these instances and report back to the Department. 
Education also agreed with our recommendation to require CSP 
applicants to describe enrollment preferences in their applications. 
Education said it intends to revise its CSP grant application notices 
to require descriptions of any enrollment preferences. Furthermore, 
Education plans to request that SEA grantees require CSP subgrant 
applicants to describe recruitment and admissions policies and 
practices, including any enrollment preferences they plan to employ. 

Education acknowledged the importance of working together with DOD to 
enhance awareness of the unique challenges involved in locating 
charter schools on bases and indicated steps they would take to 
continue this work. For example, Education stated that the Working 
Group established under the DOD and Education Memorandum of 
Understanding will continue to facilitate the sharing of information 
on challenges through shared newsletters, outreach, conference 
participation, panel discussions, and websites. 

The agencies also provided technical comments that were incorporated, 
as appropriate. 

We are sending copies of this report to the Secretaries of DOD and 
Education, relevant congressional committees, and other interested 
parties. In addition, this report will be available at no charge on 
GAO's website at [hyperlink, http://www.gao.gov]. If you or your staff 
have any questions about this report, please contact me at (202) 512-
7215 or scottg@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs can be found on the last 
page of this report. GAO staff who made major contributions to this 
report are listed in appendix V. 

Signed by: 

George A. Scott: 
Director: 
Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Charter School Profiles: 

Belle Chasse Academy:
Naval Air Station Joint Reserve Base New Orleans, Louisiana. 

Mission statement: 

The mission of Belle Chasse Academy is to educate our military-
dependent children, no matter what their background or previous school 
experience, to fully achieve their personal and academic potential 
through the acquisition of core knowledge and the skills of analysis, 
problem-solving, communication, and global responsibility. 

Charter school data: 

Opening school year (SY): 2002-03; 
Local district: Plaquemines Parish School Board; 
Authorizer: Louisiana Board of Elementary and Secondary Education; 
LEA status: Own LEA; 
Charter management organization: No; 
Charter Schools Program grant: No. 

Student body: 

Grades: K-8; 
Total students SY 11-12: 942; 
Military-connected student enrollment SY 11-12: 845 (90%); 
Preference for military-connected: Yes; 
Waiting list: Yes; 
Adequate Yearly Progress for SY 10-11: Met; 
Title I: Yes; Free-reduced lunch eligible: 44%; 

School Year 2011-12 student demographics: 

White: 41%; 
Black: 42%; 
Hispanic: 12%; 
Asian/Pacific Islander: 1%; 
American Indian/Alaskan: 1%; 
Two or more races: 3%. 

Sources: GAO analysis of charter school data; National Atlas 
of the United States. 

Figure: Public, Charter, and Private Schools near Naval Air Station 
Joint Reserve Base New Orleans: 

[Refer to PDF for image: map] 

Source: GAO analysis of National Center for Education Statistics' 
public and private school data and U.S. Census Bureau data. 

Note: Schools shown are only those within the local school district. 
The public and private schools included on this map serve some or all 
of the same grade levels offered by the charter school located on the 
military base. 

[End of figure] 

[End of Belle Chasse Academy profile] 

Imagine Andrews Public Charter School:
Joint Base Andrews, Maryland. 

Mission statement: 

Imagine Andrews Public Charter School (PCS) was established … to 
provide outstanding educational opportunities for military and 
community students. Our mission is to serve our nation by providing the 
students of the Andrews Community with a "world class" education, while 
meeting the needs of military families. Our vision is to create a 
school environment that prepares students for high school and beyond, 
develops their strong moral character, and provides them with the 
skills necessary to lead and advance our nation. 

Charter school data: 

Opening school year (SY): 2011-12; 
Local district: Prince George's County Public Schools; 
Authorizer: Prince George's County Public Schools; 
LEA status: Part of school district; 
Charter management organization: Imagine Schools; 
Charter Schools Program grant: Yes; 

Student body: 
Grades: K-4 (expanding to 8); 
Total students SY 11-12: 265; 
Military-connected student enrollment SY 11-12: 65%; 
Preference for military-connected: Yes; 
Waiting list: Yes; 
Adequate Yearly Progress for SY 10-11: School was not open in SY 2010-
11; 
Title I: No; 
Free-reduced lunch eligible: 15%; 

School Year 2011-12 student demographics: 

White: 37%; 
Black: 43%; 
Hispanic: 6%; 
Asian/Pacific Islander: 14%; 
American Indian/Alaskan: Not reported; 
Two or more races: Not reported. 

Sources: GAO analysis of charter school data; National Atlas of the 
United States. 

Figure: Public, Charter, and Private Schools near Joint Base Andrews: 

[Refer to PDF for image: map] 

Source: GAO analysis of National Center for Education Statistics' 
public and private school data and U.S. Census Bureau data. 

Note: Schools shown are only those within the local school district. 
The public and private schools included on this map serve some or all 
of the same grade levels offered by the charter school located on the 
military base. 

[End of figure] 

[End of Imagine Andrews Public Charter School profile] 

Jacksonville Lighthouse Charter School: Flightline Upper Academy:
Little Rock Air Force Base, Arkansas. 

Mission statement: 

We prepare our students for college through a rigorous arts-infused 
program. 

Charter school data: 

Opening school year (SY): 2011-12; 
Local district: Pulaski County Special School District; 
Authorizer: Arkansas State Board of Education; 
LEA status: Own LEA; 
Charter management organization: Lighthouse Academies; 
Charter Schools Program grant: Yes; 

Student body: 
Grades: 5-8 (expanding to 12); 
Total students SY 11-12: 164; 
Military-connected student enrollment SY 11-12: 82 (50%); 
Preference for military-connected: No; 
Waiting list: Yes; 
Adequate Yearly Progress for SY 10-11: School was not open in SY 2010-
11; 
Title I: Yes; 
Free-reduced lunch eligible: 21%; 

School Year 2011-12 student demographics: 
White: 48%; 
Black: 43%; 
Hispanic: 4%; 
Asian/Pacific Islander: 4%; 
American Indian/Alaskan: 1%; 
Two or more races: Not reported; 

Sources: GAO analysis of charter school data; National Atlas of the 
United States. 

Figure: Public, Charter, and Private Schools near Little Rock Air 
Force Base: 

[Refer to PDF for image: map] 

Source: GAO analysis of National Center for Education Statistics' 
public and private school data and U.S. Census Bureau data. 

Note: Schools shown are only those within the local school district. 
The public and private schools included on this map serve some or all 
of the same grade levels offered by the charter school located on the 
military base. 

[End of figure] 

[End of Jacksonville Lighthouse Charter School: Flightline Upper 
Academy profile] 

LEARN 6 in North Chicago:
Naval Station Great Lakes, Illinois. 

Mission statement: 

To provide children with the academic foundation and ambition to earn a 
college degree. 

Charter school data: 

Opening school year (SY): 2012-13; 

Local district: North Chicago Community Unit School District 187; 
Authorizer: Independent Authority for School District 187; 
LEA status: Part of school district; 
Charter management organization: LEARN Charter School Network; 
Charter Schools Program grant: No; 

Student body: 

Grades: K-2 & 6-7 in SY 2012-13 (expanding to K-8); 
Total students SY 11-12: School was not open in SY 2011-12; 
Military-connected student enrollment SY 11-12: School was not open in 
SY 2011-12; 
Preference for military-connected: No; 
Waiting list: Yes; 
Adequate Yearly Progress for SY 10-11: School was not open in SY 2010-
11; 
Title I: Yes; 
Free-reduced lunch eligible: 66%; 

School Year 2011-12 student demographics: 
School was not open in SY 2011-12. 

Sources: GAO analysis of charter school data; National Atlas of the 
United States. 

Figure: Public, Charter, and Private Schools near Naval Station Great 
Lakes Military Base: 

[Refer to PDF for image: map] 

Source: GAO analysis of National Center for Education Statistics' 
public and private school data and U.S. Census Bureau data. 

Note: Schools shown are only those within the local school district. 
The public and private schools included on this map serve some or all 
of the same grade levels offered by the charter school located on the 
military base. 

[End of figure] 

[End of LEARN 6 in North Chicago profile] 

Manzanita Public Charter School:
Vandenberg Air Force Base, California. 

Mission statement: 

We are dedicated to advancing academic excellence in Lompoc by 
providing students in kindergarten through sixth grade with the 
intellectual capacity to participate and work productively in a multi-
cultural society. 

Charter school data: 

Opening school year (SY): 2008-09; 
Local district: Lompoc Unified School District; 
Authorizer: Lompoc Unified School District; 
LEA status: Own LEA; 
Charter management organization: No; 
Charter Schools Program grant: Yes; 

Student body: 
Grades: K-6; 
Total students SY 11-12: 438; 
Military-connected student enrollment SY 11-12: 184 (42%); 
Preference for military-connected: No; 
Waiting list: No; 
Adequate Yearly Progress for SY 10-11: Did not meet; 
Title I: Yes; 
Free-reduced lunch eligible: 66%; 

School Year 2011-12 student demographics: 
White: 28%; 
Black: 7%; 
Hispanic: 56%; 
Asian/Pacific 
Islander: 2%; 
American Indian/Alaskan: 1%; 
Two or more races: 6%. 

Sources: GAO analysis of charter school data; National Atlas of the 
United States. 

Figure: Public, Charter, and Private Schools near Vandenberg Air 
Force Base: 

[Refer to PDF for image: map] 

Source: GAO analysis of National Center for Education Statistics' 
public and private school data and U.S. Census Bureau data. 

Note: Schools shown are only those within the local school district. 
The public and private schools included on this map serve some or all 
of the same grade levels offered by the charter school located on the 
military base. 

[End of figure] 

[End of Manzanita Public Charter School profile] 

Sigsbee Charter School:
Naval Air Station Key West, Florida. 

Mission statement: 

To provide each child with the opportunities and skill sets to realize 
his or her fullest potential in surroundings tailored to meet the needs 
of the transient military child as well as to provide another option 
for children in the Key West community... 

Charter school data: 

Opening school year (SY): 2010-11; 
Local district: Monroe County School District; 
Authorizer: The School Board of Monroe County Schools; 
LEA status: Part of school district; 
Charter management organization: No; 
Charter Schools Program grant: Yes; 

Student body: 

Grades: PK-7; 
Total students SY 11-12: 410; 
Military-connected student enrollment SY 11-12: 70%-80%; 
Preference for military-connected: Yes; 
Waiting list: Yes; 
Adequate Yearly Progress for SY 10-11: Met; 
Title I: No; 
Free-reduced lunch eligible: 20%; 

School Year 2011-12 student demographics: 

White: 62%; 
Black: 7%; 
Hispanic: 23%; 
Asian/Pacific 
Islander: 2%; 
American Indian/Alaskan: 0%; 
Two or more races: 6%. 

Sources: GAO analysis of charter school data; National Atlas of the 
United States. 

Figure: Public, Charter, and Private Schools near Naval Air Station 
Key West: 

[Refer to PDF for image: map] 

Source: GAO analysis of National Center for Education Statistics' 
public and private school data and U.S. Census Bureau data. 

Note: Schools shown are only those within the local school district. 
The public and private schools included on this map serve some or all 
of the same grade levels offered by the charter school located on the 
military base. 

[End of figure] 

[End of Sigsbee Charter School profile] 

Sonoran Science Academy Davis-Monthan:
Davis-Monthan Air Force Base, Arizona. 

Mission statement: 

The mission of Sonoran Schools is to provide a rigorous college prep, 
STEM-focused education through a challenging and comprehensive 
curriculum, continuous assessment, and dedicated teachers who inspire 
their students to become the leaders of tomorrow. 

Charter school data: 

Opening school year (SY): 2009-10; 
Local district: Tucson Unified School District; 
Authorizer: Arizona State Board of Charter Schools; 
LEA status: Own LEA; 
Charter management organization: Sonoran Schools, Inc.; 
Charter Schools Program grant: Yes; 

Student body: 

Grades: 6-10 (expanding to 12); 
Total students SY 11-12: 185; 
Military-connected student enrollment SY 11-12: 140 (76%); 
Preference for military-connected: No; 
Waiting list: No; 
Adequate Yearly Progress for SY 10-11: Met; 
Title I: Yes; 
Free-reduced lunch eligible: 21%; 

School Year 2011-12 student demographics: 
White: 55%; 
Black: 17%; 
Hispanic: 25%; 
Asian/Pacific Islander: 1%; 
American Indian/Alaskan: 1%; 
Two or more races: 1%. 

Sources: GAO analysis of charter school data; National Atlas of the 
United States. 

Figure: Public, Charter, and Private Schools near Davis-Monthan Air 
Force Base: 

[Refer to PDF for image: map] 

Source: GAO analysis of National Center for Education Statistics' 
public and private school data and U.S. Census Bureau data. 

Note: Schools shown are only those within the local school district. 
The public and private schools included on this map serve some or all 
of the same grade levels offered by the charter school located on the 
military base. 

[End of figure] 

[End of Sonoran Science Academy Davis-Monthan profile] 

Wheatland Charter Academy:
Beale Air Force Base, California. 

Mission statement: 

None: 

Charter school data: 

Opening school year (SY): 2001-02; 
Local district: Wheatland School District; 
Authorizer: Wheatland School District; 
LEA status: Part of school district; 
Charter management organization: No; 
Charter Schools Program grant: No; 

Student body: 

Grades: K-5; 
Total students SY 11-12: 104; 
Military-connected student enrollment SY 11-12: 74 (71%); 
Preference for military-connected: No; 
Waiting list: No; 
Adequate Yearly Progress for SY 10-11: Did not meet; 
Title I: Yes; 
Free-reduced lunch eligible: 38%; 

School Year 2011-12 student demographics: 

Did not receive complete demographic data, but school 
is predominantly White. 

Sources: GAO analysis of charter school data; National Atlas of the 
United States. 

Figure: Public, Charter, and Private Schools near Beale Air Force 
Base: 

[Refer to PDF for image: map] 

Source: GAO analysis of National Center for Education Statistics' 
public and private school data and U.S. Census Bureau data. 

Note: Schools shown are only those within the local school district. 
The public and private schools included on this map serve some or all 
of the same grade levels offered by the charter school located on the 
military base. 

[End of figure] 

[End of Wheatland Charter Academy profile] 

[End of section] 

Appendix II: Air Force Guidelines and Information on Charter Schools: 

Department of The Air Force: 
Headquarters United States Air Force: 
Washington D.C. 

February 2, 2010: 

Memorandum For ALMAJCOM/A1: 

From: HQ USAF/A1S: 
201 12th Street South, Suite 413: 
Arlington, VA 22202-4306: 

Subject: Air Force Policy on Charter Schools and Installation 
Involvement: 

Installation commanders are encouraged to support parental and 
community efforts to develop and enhance learning opportunities for 
all children and especially military connected students. These 
opportunities can include traditional public schools, private schools, 
virtual schools, home schools, and charter schools. 

Effective immediately, HQ USAF/A1S will be notified through MAYCOM/A1s 
if a charter school or other educational development effort that 
includes the use or leasing of Air Force facilities, or involvement by 
other Air Force functions (for example regular base access for non-DOD 
card holders), is being considered by an installation. HQ USAF/A1S 
will coordinate with HQ USAF/A7C and other HQ USAF elements and 
provide guidance on appropriate action. 

Under no circumstances should Air Force personnel, in their official 
capacity, initiate a charter or sign as a participant in a charter 
school. This memo has been coordinated with HQ USAF/A7C. My POC for 
this issue is Ms. Lorraine M. Neuser, Lorraine.Neuser@Pentagon.af.mil, 
703-604-0195. 

Signed by: 

Charles E. Milam: 
Director of Services: 
DCS/Manpower, Personnel and Services: 

cc: ALMAJCOM/A1S. 

[End of letter] 

Guidelines And Information on Charter Schools: 

Charter School Overview: 

Charter schools are established according to individual State charter 
school laws. The enactment of State charter school laws is solely a 
State prerogative, and the definition of a "charter school" under 
State law is a matter of State policy. Details on what States have 
charter school laws can be found at: [hyperlink, 
http://www.publiccharters.org/states] and other web sites. In 
addition, in order to receive US Department of Education Charter 
School Program funds, a charter school must meet the definition in 
Section 5210(1) of the Elementary and Secondary Education Act which is 
as follows: 

"The term 'charter school' means a public school that: 

1. In accordance with a specific State statute authorizing the 
granting of charters to schools, is exempt from significant State or 
local rules that inhibit the flexible operation and management of 
public schools, but not from any rules relating to the other 
requirements of this paragraph [the paragraph that sets forth the 
Federal definition]; 

2. Is created by a developer as a public school, or is adapted by a 
developer from an existing public school, and is operated under public 
supervision and direction; 

3. Operates in pursuit of a specific set of educational objectives 
determined by the school's developer and agreed to by the authorized 
public chartering agency; 

4. Provides a program of elementary or secondary education, or both; 

5. Is nonsectarian in its programs, admissions policies, employment 
practices, and all other operations, and is not affiliated with a 
sectarian school or religious institution; 

6. Does not charge tuition; 

7. Complies with the Age Discrimination Act of 1975, Title VI of the 
Civil Rights Act of 1964, Title IX of the Education Amendments of 
1972, Section 504 of the Rehabilitation Act of 1973, Title H of the 
Americans with Disabilities Act of 1990, and Part B of the Individuals 
with Disabilities Education Act; 

8. Is a school to which parents choose to send their children, and 
that admits students on the basis of a lottery, if more students apply 
for admission than can be accommodated; 

9. Agrees to comply with the same Federal and State audit requirements 
as do other elementary schools and secondary schools in the State, 
unless such requirements are specifically waived for the purpose of 
this program; 

10. Meets all applicable Federal, State, and local health and safety 
requirements; 

11. Operates in accordance with State law; and; 

12. Has a written performance contract with the authorized public 
chartering agency in the State that includes a description of how 
student performance will be measured in charter schools pursuant to 
State assessments that are required of other schools and pursuant to 
any other assessments mutually agreeable to the authorized public 
chartering agency and the charter school." 

HQ USAF Policy on Charter Schools: 

The policy letter (Attachment 3), published in February 2010, states 
that "installation commanders are encouraged to support parental and 
community efforts to develop and enhance learning opportunities for 
all children and especially military connected students. However, Air 
Force personnel, in their official capacity, should not initiate or 
sign as a participant in a charter school." However, installation 
commanders may sign on behalf of Air Force with respect to any support 
agreement needed to memorialize various parties' roles and 
responsibilities. Installation leadership is asked to notify HQ 
USAF/A1S through the appropriate MAJCOM chain of any charter school 
effort. This notification should take the form of a letter or email 
memo explaining in detail the installation involvement in the charter 
school process and position of installation leadership. Updates on the 
progress of any charter school initiative should be provided to A1S 
when significant changes in the status occur. 

Installations will ensure the following minimum criteria are met 
before submitting notification: 

* School accommodate a minimum of 150 students; 

* Facility be housed in a permanent structure, no temporary/modular 
buildings will be used; 

* All base access/security concerns coordinated with the installation 
and MAJCOM Security Forces. 

Waiver authority lies with AF/A1S for exceptions to policy. 

Questions and requests for additional information on this guidance 
should be addressed to HQ USAF/A1S. 

The following installation agencies, at minimum, need to be consulted. 
A checklist including these agencies is at Attachment 1 and must be 
completed and attached to the original HQ USAF/A1S notification 
letter. Checklist items are intended to further assist installation
POCs when charter school initiatives are being worked by school 
districts or local communities. 

School Liaison Officer: Provides coordination of installation support 
and liaisons with community and school POCs. Installation leadership 
may direct the school liaison officer (SLO) to serve as POC to develop 
a feasibility study using parent feedback/surveys and research 
background information on the charter school including a review of the 
proposed business plan. The SLO can also initiate coordination with 
other base functionals who may require involvement if the charter 
school may be located on the installation. 

Force Support Squadron and/or Mission Support Squadron Commander: May 
host town hall meetings or initiate surveys/focus groups to assess 
parental support for charter school. 

Legal Office: Reviews/researches applicable state and federal laws and 
regulations that may impact the installation or families, to include 
local charter school statues, fiscal law, and ethics (standards of 
conduct). Reviews charter school memoranda of understanding/agreement. 
Provides legal opinions to installation leadership on other issues 
concerning the formation and running of charter schools. Will be one 
of the more in-depth coordination efforts connected with using base 
facilities for a charter school. 

Civil Engineering: OPR if charter school is requesting use/leasing of 
Air Force owned facilities/real property. Monitors building codes, 
determines suitability of permanent facilities for use as a school 
(see Attachment 2 for additional details). 

Security Forces: Provides information/coordination on issues such as 
base access for non-DOD personnel and other security issues including 
emergency procedures and force protection. Will be one of the more in-
depth coordination efforts connected with using base facilities for a 
charter school. 

Transportation: May be involved if students will use AF transportation 
to and from school or if school will be establishing bus routes on the 
installation. 

Plans Office: Provides guidance and coordination as required. 

Contracting: Guidance and support to charter school on any contracting 
issues. 

Attachment 1: Charter School/Installation Checklist: 

Base Agency/Office: School Liaison Officer; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Force Support or Mission Support Commander; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Legal Office; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Civil Engineering; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Security Forces; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Transportation; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Plans Office; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Contracting Office; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Other; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Base Agency/Office: Other; 
Coordination Date: 
POC name, office symbol and phone: 
What coordination has taken place? (comments required): 

Attachment 2: HQ USAF/A7C Reference: 

From AFI 32-9003, Granting Temporary Use of Air Force Real Property, 
Section 2.8. - Public Schools. 

2.8.1. The installation commander may lease Air Force real property 
without charge to states, political subdivisions, or their agencies 
for public schools. The in-kind consideration must equal the 
property's fair market value. The lease's term must not exceed 5 years. 

2.8.2. The installation commander may lease Air Force land without 
charge to states, political subdivisions, or their agencies for 
building public schools. The lease's term must not exceed 25 years. 
The lessee pays all construction costs, including utility hookups, 
sidewalks and parking areas. 

2.8.3. School lessees must reimburse the Air Force for utilities and 
services it supplies. 

2.8.4. The installation commander and REMO (Real Property Management 
Office) make sure that the lease lets the Air Force use school 
facilities during non-school hours, even for religious services and 
classes, in a manner compatible with local law and practice. Air Force 
funds may pay the school lessee occupancy costs and a proportionate 
share of maintenance costs. 

[End of section] 

Appendix III: Comments from the U.S. Department of Defense: 

Office of the Assistant Secretary of Defense: 
Readiness and Force Management: 
4000 Defense Pentagon: 
Washington, D.C. 20301-4000: 

January 22, 2013: 

Mr, George A. Scott: 
Director: 
Education, Workforce, Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street NW: 
Washington, DC 20548: 

Dear Mr Scott: 

This is the Department of Defense (DoD) response to the Government 
Accountability Office (GAO) draft report GAO, "Charter Schools: 
Guidance Needed for Military Base Schools on Startup and Operational 
Issues," dated December 3, 2012 (GAO Code 131164). The Department 
concurs with the recommendations contained in the draft report. 

The Department appreciates the opportunity to respond to the draft 
report. Should you have any questions, my point of contact is Ms. 
Kathleen Facon, Chief, Educational Partnership, Department of Defense 
Education Activity (DoDEA). Ms. Facon may be reached by telephone at 
(571) 372-5834 or via e-mail at kathleen.facon@hq.dodea.edu. 

Signed by: 

[Illegible] for: 
Frederick E. Vollrath: 
Principal Deputy Assistant Secretary of Defense (Readiness and Force 
Management): 
Performing the Duties of the Assistant Secretary of Defense (Readiness 
and Force Management): 

[End of section] 

Appendix IV: Comments from the U.S. Department of Education: 

United States Department of Education: 
Office Of Innovation and Improvement: 
400 Maryland Ave. SW: 
Washington, DC 20202: 
[hyperlink, http://www.ed.gov] 

December 18, 2012: 

Mr. George A. Scott: 
Director, Education, Workforce, and Income Security Issues: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Scott: 

We appreciate the opportunity to comment on the Government 
Accountability Office (GAO) draft report, "Guidance Needed for 
Military Base Schools on Startup and Operational Issues." 

We appreciate the time that GAO has committed to this study, and I am 
pleased to respond on behalf of the U.S. Department of Education 
(Department or ED). Our technical comments on the draft report are 
enclosed, and our responses to your specific recommendations to the 
Department follow. 

Recommendation 1: Clarify Charter Schools Program (CSP) grant 
requirements regarding charter school enrollment preferences, 
including preferences for military-connected students, such as whether 
schools can hold separate lotteries for military-connected and 
civilian students and the extent to which schools can enroll military-
connected students under workplace exemptions. 

While the existing CSP guidance is already widely regarded as being 
very useful, we agree with GAO's recommendation that the Department 
should review its guidance and clarify grant requirements regarding 
charter school enrollment issues, including issues related to military-
connected students where that would be appropriate and helpful. 
Despite the relatively small number of charter schools located on 
military bases compared to the overall charter school universe (i.e., 
eight schools out of over 5,000 charter schools nationally), the 
Department has taken a number of steps to address the needs of 
military-connected families and will take appropriate steps to help 
ensure that charter school developers have the information they need 
related to the CSP to serve this population of students appropriately 
and effectively. 

The CSP authorizing statute and non-regulatory guidance outline 
permissible enrollment practices for all recipients of CSP grants, 
including charter schools located on military bases. As GAO states
in its report, the CSP authorizing legislation requires charter 
schools receiving CSP funds to admit students on the basis of a 
lottery if more students apply for admission than can be accommodated. 
In addition, the CSP Non-regulatory Guidance, issued in April 2011, 
provides guidance regarding the circumstances under which a charter 
school that is a recipient of CSP funds may operate a weighted lottery 
or exempt certain categories of applicants from the lottery and admit 
them automatically. Although the CSP guidance does not specifically 
mention military-connected students, the guidance that applies to 
admissions and use of the lottery applies to military-connected 
students on the same basis as other students. Currently, the following 
categories of students may be exempted from the lottery: (a) students 
enrolled in a public school at the time it is converted into a charter 
school; (b) students who are eligible to attend, and are living in the 
attendance area of, a public school at the time it is converted into a 
charter school; (c) siblings of students already admitted to or 
attending a charter school; (d) children of a charter school's 
founders, teachers, and staff (so long as the total number of students 
allowed under this exemption constitutes only a small percentage of 
the school's total enrollment); and (e) children of employees at a 
work-site charter school (so long as the total number of students 
allowed under this exemption constitutes only a small percentage of 
the school's total enrollment). While most of the exemptions are based 
on each applicant's specific circumstances, we believe the exemption 
for children of employees at a work-site charter school could apply to 
military-connected students on a general basis. 

The CSP Non-regulatory Guidance states that weighted lotteries are 
permissible under the CSP only in limited circumstances: (I) when 
necessary to comply with applicable civil rights laws or state law; or 
(2) to provide greater choice to students seeking to change schools 
under the public school choice provisions of Title I, Part A of the 
Elementary and Secondary Education Act of 1965, as amended. The 
guidance could include more specific information on military-connected 
students. It is available at the following web address: [hyperlink, 
http://www2.ed.gov/programs/eharter/legislation.html]. 

It is worth noting that in at least two instances, states provided CSP 
subgrants to charter schools on military bases that may have used 
enrollment practices that raise compliance questions under the CSP 
program requirements. State educational agency (SEA) grantees in these 
states have the primary responsibility for administering their 
respective states' CSP subgrant programs, monitoring subgrant 
activities, and ensuring that subgrantees comply with CSP program 
requirements; therefore, we have requested that the respective SEAs 
conduct reviews of these situations and report back to the Department. 

The Department will review its current Non-regulatory Guidance to 
determine options for how the Department can clarify admissions and 
lottery requirements for charter schools operating on military bases 
that receive CSP funds. 

Recommendation 2: Require applicants for CSP grants and subgrants to 
describe any enrollment preferences in their applications. 

Under the CSP, the Department awards grants to SEAs to enable them to 
operate charter school subgrant programs in their states. SEAs, in 
turn, award subgrants to charter schools and charter school 
developers. In states in which the SEA does not have a current CSP 
grant, charter school developers and charter schools may apply 
directly to the Department for CSP planning and implementation grants. 
While the Department is responsible for monitoring its direct 
grantees' project activities and compliance with CSP program 
requirements, in states in which the CSP is administered by the SEA, 
the SEA bears primary responsibility for monitoring its subgrantees' 
activities and ensuring that they comply with CSP program requirements. 

As GAO mentions in its draft report, currently the Department does not 
require SEAs to include in their CSP applications descriptions of any 
"enrollment preferences" charter schools are allowed to employ in 
their respective states. We agree that descriptions of the "enrollment 
preferences" authorized under an SEA applicant's state charter school 
law would be a helpful addition to CSP applications, even though the 
CSP statute does not require the Department to collect this 
information. 

Therefore, the Department intends to revise its CSP grant application 
notices to require SEAs and other eligible applicants, as appropriate, 
to describe any enrollment preferences that charter schools in their 
respective states are required or permitted to employ. In addition, 
the Department intends to request that SEA grantees require applicants 
for CSP subgrants to include in their applications descriptions of 
their recruitment and admissions policies and practices, including any 
enrollment preferences they plan to employ. The Department also will 
utilize the CSP monitoring process to review and assess SEA practices 
for reviewing subgrantee admissions policies, including the use of a 
lottery and any enrollment preferences. 

Recommendation 3: To serve as a resource for military base communities 
exploring educational options, as stated in their 2008 Memorandum of 
Understanding, we also recommend that the Secretaries of DOD and 
Education facilitate the sharing of information among interested 
parties—such as base commanders and school and official planners—on 
how military base charter schools have addressed startup and 
operational challenges. 

The Department of Defense (DoD)–ED Memorandum of Understanding (MOU) 
created a Working Group to implement the elements of the MOU, which 
specifically identifies charter schools as a focus area for 
collaboration. The Working Group will continue to facilitate the 
sharing of information on startups and operational challenges through 
shared newsletters, outreach, conference participation, panel 
discussions, and websites. The MOU Working Group on charter schools 
provides a forum for both Departments to keep abreast of the emergent 
issues facing charter schools on military bases. The Department of 
Education is committed to enhancing awareness for charter school 
developers and military-connected communities regarding the novel set 
of challenges involved in locating charter schools on bases. 

Thank you again for the opportunity to comment on the draft report. 
The Department remains committed to improving educational 
opportunities for military-connected children, including through the 
possible creation of high-quality public charter schools located on 
military bases. Please let us know if you have any questions or would 
like to discuss our comments. We look forward to receiving the final 
report. 

Sincerely, 

Signed by: 

James H. Shelton III: 
Assistant Deputy Secretary for Innovation and Improvement: 

Enclosure: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

George A. Scott, 202-512-7215 or scottg@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Sherri K. Doughty, Assistant 
Director; Sandra L. Baxter; Edward F. Bodine; and Deborah A. Signer 
made significant contributions to this report. Also contributing to 
this report were James Bennett, Deborah Bland, Jessica A. Botsford, 
Ying Long, James M. Rebbe, Terry L. Richardson, Laura L. Talbott, and 
Kathleen L. van Gelder. 

[End of section] 

Footnotes: 

[1] GAO, K-12 Education: Many Challenges Arise in Educating Students 
Who Change Schools Frequently, [hyperlink, 
http://www.gao.gov/products/GAO-11-40] (Washington, D.C.: Nov. 18, 
2010). 

[2] American Institutes for Research, Educational Options and 
Performance of Military-Connected School Districts - Final Report (San 
Mateo, CA: May 2011). 

[3] Department of Defense, Report of the Tenth Quadrennial Review of 
Military Compensation, Vol. II, Deferred and Noncash Compensation 
(Washington, D.C.: July 2008). 

[4] Report on Military Construction, Veterans Affairs, and Related 
Agencies Appropriations Bill, 2012, H.R. Rep. No. 112-94, at 16 
(2011). DOD had a related mandate to report on locations where charter 
schools could improve the quality of education for children of 
military families while meeting their unique needs. Report on Military 
Construction, Veterans Affairs, and Related Agencies Appropriations 
Bill, 2012, S. Rep. No. 112-29, at 15 (2011). DOD's Report on Charter 
Schools on Military Installations was issued in July 2012. 

[5] We initially identified seven currently operational charter 
schools as well as two charter schools under development at Naval 
Station Great Lakes in North Chicago Illinois, and Fort Bragg, North 
Carolina. After the charter school at Naval Station Great Lakes began 
operations in school year 2012-13, we included it among currently 
existing charter schools, for a total of eight schools. 

[6] For purposes of Department of Education discretionary grant 
programs, a military-connected student is generally defined as a child 
participating in an early learning program, a student in pre-school 
through grade 12, or a student enrolled in postsecondary education or 
training who has a parent or guardian on active duty in the uniformed 
services. Supplemental Priorities for Discretionary Grant Programs, 75 
Fed. Reg. 78,486, 78,509 (Dec. 15, 2010). 

[7] Of these students, about 1.1 million students are enrolled in 
public or private schools located off military bases, or in home-
school programs, according to DOD. 

[8] These school options may vary from base to base. 

[9] Domestic DOD schools are located in Alabama, Georgia, Kentucky, 
New York, North Carolina, South Carolina, Virginia, Guam, and Puerto 
Rico. None of these DOD schools are located on military bases that 
also have charter schools. One charter school is currently being 
planned for a military base with a DOD school, but the schools cover 
different grade ranges. 

[10] See GAO, DOD Schools: Limitations in DOD-Sponsored Study on 
Transfer Alternatives Underscore Need for Additional Assessment, 
[hyperlink, http://www.gao.gov/products/GAO-05-469] (Washington, D.C.: 
April 2005). 

[11] See, for example, John Helmick, Westat, and Lisa Hudson, Defense 
Manpower Data Center, A Study of Schools Serving Military Families in 
the U.S.: Education Quality, Federal Administration, and Funding 
(Arlington, VA: October 1997). In 2002, DOD began a study to evaluate 
the feasibility of transferring DOD schools in the continental United 
States to individual local educational agencies (LEAs). The final 
report was not completed, according to a DOD official. 

[12] Julian R. Betts and Y. Emily Tang, The Effect of Charter Schools 
on Student Achievement: A Meta-Analysis of the Literature (Seattle, 
WA: October 2011). 

[13] National Center for Education Statistics, Institute of Education 
Sciences, U.S. Department of Education, Fast Facts: Charter Schools. 
[hyperlink, http://nces.ed.gov/FastFacts/display.asp?id=30] Accessed 
9/27/2012. 

[14] National Alliance for Public Charter Schools, 2011-2012 NAPCS 
Charter School Survey, National Waiting List Results. 

[15] According to the Department of Education Charter Schools Program, 
a CMO is a nonprofit organization that operates or manages multiple 
charter schools by centralizing or sharing certain functions and 
resources among schools. [hyperlink, 
http://www2.ed.gov/programs/charter-rehqcs/eligibility.html]. Accessed 
11/7/12. 

[16] National Education Policy Center, Profiles of For-Profit and 
Nonprofit Education Management Organizations: Thirteenth Annual Report 
- 2010-2011 (Boulder, CO: January 2012). 

[17] With regard to special education, one common practice in states 
where charter schools are their own LEA is for the state to make 
charter schools responsible for providing special education services 
themselves. See GAO, Charter Schools: Additional Federal Attention 
Needed to Protect Access for Students with Disabilities, [hyperlink, 
http://www.gao.gov/products/GAO-12-543] (Washington, D.C.: June 2012.) 

[18] See [hyperlink, http://www.gao.gov/products/GAO-12-543]. 

[19] 20 U.S.C. §§ 7701-7714. 

[20] GAO, Education of Military Dependent Students: Better Information 
Needed to Assess Student Performance, [hyperlink, 
http://www.gao.gov/products/GAO-11-231] (Washington. D.C.: March 2011). 

[21] Department of Defense and Full-Year Continuing Appropriations 
Act, 2011, Pub. L. No. 112-10, § 8109, 125 Stat. 38, 82. 

[22] Pub. L. No. 112-74, § 8118, 125 Stat. 786, 833. 

[23] See GAO, Charter Schools: Education Could Do More to Assist 
Charter Schools with Applying for Discretionary Grants, [hyperlink, 
http://www.gao.gov/products/GAO-11-89] (Washington, D.C.: December 
2010). 

[24] 20 U.S.C. § 7221b(b). 

[25] The White House, Strengthening our Military Families: Meeting 
America's Commitment (Washington, D.C.: January, 2011). 

[26] Fort Bragg Regional High School will not open as proposed in 
school year 2013-14. In addition, several other military bases have 
been interested in initiating charter schools on the bases, according 
to military officials we spoke to. These bases included: Joint Base 
Anacostia-Bolling in Washington, D.C.; Joint Base Charleston in South 
Carolina; MacDill Air Force Base in Tampa, Florida; and Barksdale Air 
Force Base in Louisiana. 

[27] See appendix I for profiles of individual charter schools on 
military bases. 

[28] The Department of Defense provides military life counselors to 
schools with high populations of children in military-connected 
families. 

[29] These concerns are consistent with those in the 2011 American 
Institutes for Research report for DOD. 

[30] The BRAC process is designed to overcome obstacles to eliminating 
unneeded DOD infrastructure and to help DOD match needed 
infrastructure to the force structure and to support military 
missions. GAO, Military Base Realignments and Closures: Key Factors 
Contributing to BRAC 2005 Results, [hyperlink, 
http://www.gao.gov/products/GAO-12-513T] (Washington, D.C.: March 8, 
2012.) 

[31] In this case, the state board of education overruled the local 
school board to approve the CMO's charter school proposal. 

[32] A 2008 DOD report observed that if civilian children put their 
names on a military base charter school's waiting list, they will 
receive newly open slots before the children of service members who 
subsequently transfer into the installation. Due to the high turnover 
rate that military base charter schools would expect to see among the 
children of military personnel, a school's enrollment could consist of 
mostly civilian students over time, as civilian students enroll at a 
greater rate than military-connected students. The report concluded 
that such a result would frustrate the original intent of establishing 
charter schools on military bases. Department of Defense, Report of 
the Tenth Quadrennial Review of Military Compensation, Vol. II, 
Deferred and Noncash Compensation (Washington, D.C.: July 2008). 

[33] Md. Code Ann. § 9-102(3). As discussed later, CSP would preclude 
reserving all slots for military families, according to Education. 

[34] Md. Code Ann. § 9-102.1. 

[35] Fla. Stat. Ann. § 1002.33(10)(d)(6). 

[36] Under Florida law, a "charter school-in-the-workplace" may be 
established when a business partner provides the school facility to be 
used and the school must enroll students based upon a random lottery 
that involves all of the children of employees of that business or 
corporation. Fla. Stat. Ann. § 1002.33(15). 

[37] 20 U.S.C. § 7221i(1)(H) and 7221b(b)(3)(I)(2). 

[38] Others are Title IX of the Education Amendments of 1972, Section 
504 of the Rehabilitation Act of 1973, and the Equal Protection Clause 
of the Constitution. 

[39] 34 C.F.R. § 80.40(a). 

[40] A recent report by Education's Office of the Inspector General 
(OIG) determined that the Office of Innovation and Improvement (OII), 
which administers the Charter Schools Program, did not effectively 
oversee and monitor the SEA and non-SEA grants and did not have an 
adequate process to ensure SEAs effectively oversaw and monitored 
their subgrantees. The report also notes Education's proposed 
corrective actions. Office of the Inspector General, U.S. Department 
of Education. The Office of Innovation and Improvement's Oversight and 
Monitoring of the Charter Schools Program's Planning and 
Implementation Grants: Final Audit Report. (New York, NY: September, 
2012). 

[41] According to DOD estimates, 6 percent of the students who attend 
district-run public schools on military bases are civilian. Department 
of Defense. www.militaryhomefront.dod.mil]. Accessed 10/25/2012. 

[42] GAO, New Charter Schools across the Country and in the District 
of Columbia Face Similar Start-Up Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-03-899] (Washington, D.C: September 
2003). 

[43] A 2011 DOD assessment of facility conditions and capacity of 
public school on military bases rated the condition of Sigsbee Charter 
School's facility as poor. Department of Defense. [hyperlink, 
http://www.militaryhomefront.dod.mil]. Accessed 10/25/2012. 

[44] See appendix II for Air Force guidance. 

[End of section] 

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