Military Base Closures and Affected Defense Department Civil Service Employees

Military Base Closures and Affected Defense
Department Civil Service Employees
Updated April 16, 2007
Clinton T. Brass and Barbara L. Schwemle
Analysts in American National Government
Government and Finance Division
Jon O. Shimabukuro
Legislative Attorney
American Law Division

Military Base Closures and Affected Defense
Department Civil Service Employees
Summary
As a step in the 2005 round of the base realignment and closure (BRAC)
process, the Defense Base Closure and Realignment Commission (commonly
referred to as the BRAC Commission) recommended on September 8, 2005, that a
number of domestic U.S. military installations be closed or realigned. Overall, the
BRAC Commission estimated that the recommended closures or realignments would
result in a net decrease of 15,874 federal civilian jobs at the Department of Defense
(DOD). On September 15, 2005, the President approved the commission’s
recommendations and transmitted them to Congress. Congress rejected H.J.Res. 65
(a resolution of disapproval of the BRAC Commission recommendations) on October

27, 2005. The BRAC Commission recommendations took effect on November 9,

2005, and are required to be implemented by 2011.

As BRAC-related closures and realignments are implemented, there will likely
be several implications and options for affected DOD civil service employees relating
to reductions in force (RIFs) and several types of transition assistance. In addition,
DOD’s National Security Personnel System (NSPS) and labor-management relations
could have implications in some respects for how DOD employees are affected by
the BRAC process.
This report will be updated if major changes occur in the BRAC process
regarding DOD civil service employees. Implementation of NSPS is discussed in
CRS Report RL31954, DOD’s National Security Personnel System: Statute,
Regulations, and Implementation Plans, coordinated by Barbara Schwemle.

Contents
BRAC and DOD Civilian Employees..................................1
Transition Assistance for Employees...................................2
What Will Happen to Affected DOD Civil Service Employees?.............4
Reduction in Force (RIF)........................................4
Transfer of Function............................................5
Voluntary Early Retirement Authority (VERA)......................6
Voluntary Separation Incentive Payments (VSIPs)....................6
Job Placement Programs........................................6
Benefits and Entitlements.......................................7
Implications of NSPS and Labor-Management Relations...................7
National Security Personnel System (NSPS).........................7
Labor-Management Relations....................................8
Appendix. Net Federal Civilian Job Changes, by State, Territory,
and District of Columbia.......................................10
List of Tables
Table 1. Net Federal Civilian Job Changes Under 2005 BRAC
Commission Recommendations.................................10

Military Base Closures and Affected
Defense Department Civil Service
Employees
BRAC and DOD Civilian Employees
On May 13, 2005, the Department of Defense (DOD) announced
recommendations to close or realign a number of domestic U.S. military bases in
order to consolidate forces and save funds. The announcement occurred as a step in
the 2005 round of the base realignment and closure (BRAC) process, as authorized
by Congress in 2001.¹ Specifically, DOD recommended closures and realignments
that the agency estimated would eliminate approximately 18,000 civilian support
positions.² In addition, the DOD recommendations contemplated significant
restructuring and consolidation of support functions with potential implications for
affected civilian employees.
Under the BRAC framework, Secretary of Defense Donald Rumsfeld
transmitted the recommendations to the Defense Base Closure and Realignment
Commission (commonly referred to as the BRAC Commission) for its review and
recommendations. After its review process, on September 8, 2005, the BRAC
Commission transmitted its recommendations in a report to President George W.
Bush.³ The BRAC Commission accepted a majority of DOD’s recommendations for
closure and realignment, rejected or modified some DOD recommendations, and
made several recommendations on its own initiative. Appendix O of the BRAC
Commission’s report included information about “employment impact by economic
areas and states,” including, among other things, net direct job changes (i.e., increases
and decreases for each state and area) for military, civilian, and contractor personnel.
Overall, the data in Appendix O indicated a net decrease of 15,874 federal civilian
jobs across all states and areas, corresponding to the BRAC Commission’s

¹ For more on the BRAC process and specific timing of steps in the 2005 round, see CRS
Report RL32216, Military Base Closures: Implementing the 2005 Round, by David E.
Lockwood. A BRAC “timeline” is located on DOD’s main BRAC website, available at
[http://www.dod.mil/brac/].
² U.S. Department of Defense, “Part 1 of 2: Results and Process,” Base Closure and
Realignment Report, vol. 1, May 2005, p. 4 (hereafter “DOD BRAC Report”), available at
[http://www.dod.mil/brac/vol_I_parts_1_and_2.html ].
³ U.S. Defense Base Closure and Realignment Commission, 2005 Defense Base Closure and
Realignment Commission Report (Arlington, VA: Sept. 8, 2005), available at
[http://www.brac.gov/finalreport.html]. For discussion, see CRS Report RS22291, Military
Base Closures: Highlights of the 2005 BRAC Commission Report and Proposed Legislation,
by Daniel Else and David Lockwood.

recommendations. Maryland was listed with the largest increase in net civilian jobs
(7,773) among all states, and Virginia was listed with the largest decrease (-10,838).
(See Appendix of this report for a table showing net job changes for each state,
territory, and the District of Columbia.⁴)
On September 15, 2005, the President, who could accept or reject the BRAC
Commission’s recommendations only in their entirety, approved the commission’s
recommendations and transmitted them to Congress. On October 27, 2005, Congress
rejected H.J.Res. 65, a resolution of disapproval of the BRAC Commission’s
recommendations. The recommendations took effect on November 9, 2005.⁵ In late
2005, DOD issued instructions to the military departments and defense agencies to
create a “Business Plan” for each of the recommendations drafted by the commission⁶
and approved by the President. DOD reportedly planned to develop “general plans”
early in 2006 to implement the BRAC Commission’s recommendations, with over

240 specific implementation plans being developed thereafter at “their own pace,

their own schedule and their own cost structure.”⁷ Barring future congressional
action, DOD is required to implement the recommendations by 2011.
Congress did not enact a Military Construction Appropriations Act for FY2007.
P.L. 110-5, the Revised Continuing Appropriations Resolution for FY2007, provides⁸
an appropriation of nearly $2.5 billion for BRAC. This amount is $3.1 billion less
than the President requested. H.R. 1591, emergency supplemental appropriations for
FY2007, as passed by the House and the Senate, includes the $3.1 billion for the

2005 Department of Defense Base Closure Account. Unless the President vetoes the⁹

legislation, BRAC would be fully funded.
Transition Assistance for Employees
According to DOD, “[w]hen implementing decisions during the past four BRAC
rounds, the Department worked diligently to assist its military and civilian personnel
in transition ... [and] attempted to minimize involuntary separations of Defense

⁴ The appendix, which lists employment impacts by state and metropolitan statistical area,
is separately available from the full BRAC Commission report at [http://www.brac.gov/
docs/final/AppendixO.pdf].
⁵ Donna Miles, “BRAC Deadline Expires; DoD to Begin Closures, Realignments,”
American Forces Information Service, Nov. 9, 2005, available at
[http://www.defenselink.mil/news/Nov2005/20051109_3280.html ].
⁶ CRS Report RL33766, Military Base Closures and Realignment: Status of the 2005
Implementation Plan, by Kristine E. Blackwell.
⁷ Sgt. Sara Wood, “BRAC Implementation Plan on Schedule, Official Says,” American
Forces Information Service, Dec. 12, 2005, available at [http://www.defenselink.mil/
news/Dec2005/20051212_3622.html ].
⁸ P.L. 110-5, Feb. 15, 2007, 121 Stat. 8, at 40.
⁹ For an analysis of the funding for BRAC, see CRS Report RL33427, Military
Construction, Military Quality of Life and Veterans Affairs: FY2007 Appropriations, by
Daniel H. Else, Christine Scott, and Sidath Viranga Panangala.

civilians at closing or realigning installations through a variety of placement,
retirement, and federal retraining programs.”¹⁰ As evidence of the success of these
programs, DOD also stated that “[e]ven though the Department’s civilian workforce
has been reduced by 40 percent since the first BRAC rounds began in 1988, less than
10 percent of the affected employees were involuntarily separated.”¹¹ For the current
round, DOD stated:
One of the Department’s challenges at installations subject to BRAC decisions
is the fair and effective management of human resources. The closure of
installations with the potential for separating a large number of civilian
employees presents major challenges to commanders and human resource
personnel. While these installations will still have missions to accomplish, the
employees will be stressed about their careers and employment security. In this
atmosphere, productivity will suffer and the employees’ overall quality of life
may diminish. The Department has a number of mitigating placement, transition,¹²
and worker assistance programs to draw from....
In order to assist with efforts to mitigate the impact of job separations (e.g., through
reduction in force) and otherwise help civilian employees with transitions, DOD
established a “BRAC Transition” website and created a brochure to assist civil
service employees (appropriated fund employees) and nonappropriated fund (NAF)
employees.¹³ The website outlines several available resources, including job
placement programs, separation incentives, and various benefit and entitlement

¹⁰ DOD BRAC Report, p. 27.
¹¹ U.S. Department of Defense, BRAC Transition, Assistance for DOD Civilian Employees,
Base Realignment and Closure (BRAC) Information (Washington: DOD, [May 15, 2005]),
p. 1, available at [http://www.cpms.osd.mil/brac/brac_index.aspx] (at bottom, select
“download brochure”).
¹² DOD BRAC Report, p. 29.
¹³ For the website, see [http://www.cpms.osd.mil/brac/brac_index.aspx]. The brochure is the
previously cited U.S. Department of Defense, BRAC Transition, Assistance for DOD
Civilian Employees. NAF employees, sometimes also called nonappropriated fund
instrumentality (NAFI) employees, typically include personnel who work at post exchanges
or commissaries. NAF employees are federal employees within DOD, but are not legally
considered federal civil service employees (i.e., not deemed an employee for the purpose of
most laws administered by the U.S. Office of Personnel Management). See U.S.
Department of Defense, Personnel Policy Manual for Nonappropriated Fund
Instrumentalities, DOD 1401.1-M, Dec. 1988, reissued Dec. 26, 2001, p. 17, available at
[http://www.dtic.mil/whs/directives/corres/html/140101m.htm]. However, some laws that
apply to federal civil service employees can be administratively adopted by regulation for
application to NAF employees. For example, see U.S. Department of the Army,
Nonappropriated Funds Personnel Policy, Army Regulation 215-3, Aug. 29, 2003, available
at [http://www.cpol.army.mil/library/naf/welcome.html].

programs, including some from other agencies.¹⁴ This report focuses on DOD civil
service (appropriated fund) employees.¹⁵
What Will Happen to Affected DOD
Civil Service Employees?
When BRAC closures and realignments are implemented, there will likely be
several implications and options for affected DOD civil service employees.¹⁶ The
sections below briefly identify a number of them. As noted in DOD’s BRAC report,
however, “[c]oncerns about the implementation of BRAC decisions are numerous
and based on very installation-specific circumstances. For many of these concerns,
sufficient information may be available only after BRAC decisions are finalized and
installation-specific implementation plans are developed.”¹⁷ Therefore, it appears
that detailed information about these implications or options will emerge over time.
Reduction in Force (RIF)
Perhaps the most severe potential effect of BRAC on affected employees could
be a reduction in force (RIF). Under delegated authority from the Secretary of
Defense, RIF actions are approved by certain senior DOD officials. Redelegation of
the approval authority to the lowest practical level is authorized when fewer than 50
employees are involuntarily separated through RIF, or when the RIF occurs as a
result of BRAC. RIFs within DOD may not commence until 45 days after Congress
has received the appropriate information about the action. Each employee affected
by a RIF must receive a specific written notice of at least 60 full days (not counting
notice delivery dates and effective dates) before the action becomes effective. The
employee’s labor representative is notified at the same time. When 50 or more
employees in a competitive area are being separated, the state dislocated worker
unit(s), chief elected official(s) of local government(s) where the separations will
occur, and the Office of Personnel Management (OPM) must be notified in writing.
Except in specific situations, RIF or other termination notices cannot be issued or
made effective between December 15 and January 3.
DOD’s final regulations to implement the RIF provisions of the National
Security Personnel System (NSPS, described in a later section), which became

¹⁴ For more information, see CRS Report RS22184, Military Base Closures: Redevelopment
Assistance Programs, by Baird Webel.
¹⁵ For information about transition assistance specifically for NAF employees, see the
BRAC Transition website, which provides customized information for civil service and
NAF employees. For more on NAF employee policies, see, for example, U.S. Department
of the Army, NAF Employee Handbook, Aug. 2004, available at
[http://cpol.army.mil/library/naf/handbook/].
¹⁶ For press coverage after DOD released its initial recommendations, see Stephen Barr,
“Help and Hope for Workers At Risk in Base Closings,” Washington Post, May 15, 2005,
p. C2.
¹⁷ DOD BRAC Report, pp. 28-29.

effective on November 28, 2005, are different from the RIF rules that apply to other
civilian employees government-wide. Under the government-wide regulations, an
employee’s retention standing in a RIF is based, in descending order, on tenure,
veterans’ preference, length of service, and performance (5 CFR §351.501(a)). Were
a RIF to occur after the NSPS rules are fully implemented, in an installation covered
by the NSPS, performance would precede length of service in determining retention
standing (5 CFR §9901.607(a)). Under both the government-wide and NSPS
regulations, a higher-standing employee could displace a lower-standing employee
on the same retention list.¹⁸ DOD is to address changes to the RIF process included
in the NSPS regulations to ensure that the rules are applied consistently across DOD
components. An employee may appeal the RIF action to the Merit Systems
Protection Board (MSPB) not later than 30 days after the RIF effective date. An
employee in a bargaining unit covered by a negotiated grievance procedure that does
not exclude RIF must use the negotiated grievance procedure. The employee may not
appeal the RIF action to MSPB unless the employee alleges the action was based
upon discrimination. The collective bargaining agreement covers the time limits for
filing a grievance under a negotiated grievance procedure. Several authorities (i.e.,
VERA and VSIP, described below) are intended to reduce the number of involuntary
separations.
Transfer of Function
According to DOD, if an employee’s organization is realigned to another
geographic location, the employee might or might not be offered the opportunity to
move with the work.¹⁹ An employee’s right of assignment depends on whether the
employee’s organization is being moved due to a “transfer of function.” As DOD
explains, a transfer of function “occurs when a function ceases in one location and
is moved to one or more other locations that are not performing that specific type of
work.”²⁰ In such a case, non-temporary employees would have the right to move with
their work if the alternative at the losing organization were separation or demotion

¹⁸ The regulations at 5 CFR §351.702(a), applicable to other civilian employees government-
wide, provide that displacement may generally occur if the employee: (1) meets the OPM
standards and requirements for the position; (2) is physically qualified to perform the duties
of the position; (3) meets any special qualifying condition for the position; and (4) has the
capacity, adaptability, and special skills needed to satisfactorily perform the duties of the
position without undue interruption. Under the NSPS regulations at 5 CFR §9901.608(a),
displacement may occur if: (1) the higher-standing employee is qualified for the position,
consistent, as applicable, with 5 CFR §351.702, or the Department’s own qualifications
applied consistent with other requirements in 5 CFR §351.702; (2) no undue interruption
would result from displacement; and (3) the position of the lower-standing employee is in
the same pay band, or in a lower pay band, as the position of the higher-standing employee
(Federal Register, vol. 70, Nov. 1, 2005, p. 66205).
¹⁹ U.S. Department of Defense, “Base Realignment and Closure (BRAC) 2005 Frequently
Asked Questions,” question #17 for appropriated fund employees (hereafter, “BRAC
FAQs”), available at [http://www.cpms.osd.mil/brac/AF-BRAC.aspx].
²⁰ Detailed information about transfers of function is available from U.S. Office of Personnel
Management, Restructuring Information Handbook, module 4, available at
[http://www.opm.gov/rif/handbook/rih.asp].

due to a RIF. If a realignment were not a transfer of function, an employee would not
have the right to accompany the function to the new location. In such a case, DOD
might give employees the opportunity to volunteer to relocate with the organization.
If, however, such an employee does not volunteer, or volunteers but is not selected,
the employee would be subject to a resulting RIF action and might be eligible for
transition assistance.
Voluntary Early Retirement Authority (VERA)
Employees who are at least 50 years of age with at least 20 years of creditable
service (or 25 years of service at any age) may be eligible for early retirement. These
requirements apply to individuals covered by the Civil Service Retirement System
(CSRS) and the Federal Employees Retirement System (FERS). Annuities for CSRS
employees are reduced by 2% a year for each year the retiree is under age 55.
Individuals serving under an appointment without time limit and continuously
employed by DOD for more than 30 days before an installation’s reduction or
restructuring was approved are eligible for VERA. Employees who are involuntarily
separated for misconduct or unacceptable performance, or who have received a
specific RIF separation notice, are not eligible for early retirement. VERA is not an
entitlement and may be offered to all employees or to specific groups of employees,
depending on the circumstances of the reduction or restructuring.
Voluntary Separation Incentive Payments (VSIPs)
Employees who accept a VSIP (also known as a “buyout”) agree to separate
from the workforce voluntarily by optional retirement, early retirement (under
VERA), or resignation. Generally, employees must be U.S. citizens, have permanent
appointments, and have at least 12 months of continuous employment with DOD to
be eligible for a separation incentive. VSIPs are $25,000 or the amount of severance
pay an employee would receive under the standard formula, whichever is less, and
are taxable. Individuals receiving an incentive payment who want to return to
employment with DOD within 12 months of separation or with any federal agency
within five years, must repay the full amount of the VSIP. Under a program called
VSIP Phase II, cash incentives may be offered to encourage employees at
installations that are not downsizing to resign or retire. This would create vacancies
for individuals who are registered for the Priority Placement Program and who may
be involuntarily separated because their installation is restructuring or closing.²¹
Job Placement Programs
Among the programs available to assist displaced civilian employees in
continuing their careers in other federal agencies are the Priority Placement Program
(PPP), Interagency Career Transition Assistance Plan (ICTAP), Reemployment
Priority List (RPL), and job exchanges.²² Generally, these programs involve some
degree of priority placement within a certain geographic or commuting area and

²¹ Further details are available at [http://www.cpms.osd.mil/brac/separation.aspx].
²² Fact sheets are available at [http://www.cpms.osd.mil/brac/Job_Placement.aspx].

require the displaced individual to have a certain level of competency in order to be
placed. Each also has certain registration requirements and time limitations. NAF
employees are covered by a separate RPL and can be placed in civil service positions
under an interchange agreement signed by DOD and OPM. DOD employees whose
work is contracted out or whose bases are being closed must be given “the right of
first refusal” for vacant positions (i.e., environmental cleanup and restoration or
security) by the contractor retained to prepare an installation for closure or to
maintain it after closure. Retraining and readjustment assistance (including career
counseling, testing, and placement assistance) is provided to displaced federal
employees under the Workforce Investment Act,²³ which is administered through
state employment security agencies.
Benefits and Entitlements
For civil service employees who are separated by RIF, transfer of function, or
other displacement action, a number of “benefit and entitlement” programs would be
available for eligible employees.²⁴ DOD commanders and activity heads are
authorized to use appropriated funds to provide certain assistance, such as career
transition training, to employees adversely affected by BRAC. Outplacement
subsidies could also be offered to other federal agencies to hire displaced DOD
employees through reimbursement for moving expenses. Employees who are
involuntarily separated may also be entitled to severance pay, extended employment
for retirement or health benefits, or temporary continuation of health insurance
coverage, among other entitlements and benefits.
Implications of NSPS and
Labor-Management Relations
National Security Personnel System (NSPS)
Implementation of DOD’s NSPS could have implications in some respects for²⁵
how DOD employees are affected by the BRAC process. According to DOD,

²³ For discussion, see CRS Report RS22184, Military Base Closures: Redevelopment
Assistance Programs, by Baird Webel.
²⁴ Detailed fact sheets are available at [http://www.cpms.osd.mil/brac/brac_Benefits.aspx].
²⁵ The NSPS was enacted as part of Title XI of the National Defense Authorization Act for
FY2004 (P.L. 108-136; 117 Stat. 1392, at 1621), and allows DOD to establish a new human
resources management system for the agency, notwithstanding a number of provisions of
Title 5, United States Code, which establish various policies related to management of the
federal civil service. See CRS Report RL31954, DOD’s National Security Personnel
System: Statute, Regulations, and Implementation Plans, coordinated by Barbara L.
Schwemle. For a DOD overview of NSPS implementation plans and timing, see
[http://www.cpms.osd.mil/nsps/index.html]. On Feb. 27, 2006, a federal district court
enjoined subparts G, H, and I of the NSPS regulations, which involve adverse actions,
appeals, and labor-management relations. An appeal of the decision is likely. See American
(continued...)

Benefits such as health and life insurance, retirement, thrift savings plan, annual
and sick leave, severance pay and moving expenses are untouched as a result of
NSPS. Additionally, the Department’s primary tools for transition assistance for
its civilians, such as outplacement services, priority placement and separation
incentives, will be available to employees under NSPS. Eligibility for those
programs and services is not affected by NSPS.²⁶
Nevertheless, it is possible that NSPS implementation might affect collective
bargaining agreements and RIFs, with attendant implications for employees, as
discussed elsewhere in this report. It is not yet clear, however, if or when the NSPS
will be implemented for employees potentially affected by the BRAC process.
According to DOD, BRAC will not affect the “overall implementation” of NSPS, and
activities on the BRAC list will not automatically be excluded from “Spiral One” (the
first phase) of the NSPS implementation. However, “[c]omponents will assess
whether inclusion of a BRAC site in Spiral One is appropriate, considering such
factors as the anticipated time frame for the closure/realignment and impact on the
mission and the workforce.”²⁷
Labor-Management Relations
DOD employees are currently represented by 43 unions.²⁸ Although the
Secretary of Defense has broad authority to take appropriate action to provide for the
more effective and efficient operation of the agency, including the transfer and
reassignment of any function or duty, the collective bargaining agreements that were
negotiated by DOD and the unions may include provisions that have implications for
how DOD employees are affected by the BRAC process.
For example, an agreement may include a negotiated grievance procedure that
could be invoked in connection with a RIF action.²⁹ In National Federation of
Federal Employees v. FLRA, a 2004 case involving non-professional employees at
the U.S. Army’s Letterkenny Depot, whose activities were transferred following a
decision by the BRAC Commission, the collective bargaining agreement that was
negotiated between the parties included a provision that permitted the union to
request bargaining within 10 days after receiving notice of a change in working
conditions.³⁰

²⁵ (...continued)
Federation of Government Employees, AFL-CIO v. Rumsfeld, No. CIV. 05-2183 EGS
(D.D.C. Feb. 27, 2006).
²⁶ U.S. Department of Defense, “BRAC FAQs,” question #28 for appropriated fund
employees.
²⁷ Ibid., question #27 for appropriated fund employees.
²⁸ 70 Fed. Reg. 66,120 (Nov. 1, 2005) (final NSPS rule).
²⁹ See, for example, Snyder v. Dept. of Defense, No. 00-3022, 2000 WL 380089 (Fed. Cir.
Apr. 11, 2000).
³⁰ 369 F.3d 548 (D.C. Cir. 2004).

Although a collective bargaining agreement may include provisions that affect
the BRAC process, such provisions could arguably be nullified by the
implementation of the NSPS. Section 9901.905(a) of the NSPS regulations indicates
that any provision of a collective bargaining agreement that is inconsistent with the
regulations or DOD implementing issuances is unenforceable.³¹ In addition, section
9901.917(d)(2) of the regulations states that management has no obligation to bargain
over a change to a condition of employment unless the change is “foreseeable,
substantial, and significant in terms of both impact and duration on the bargaining
unit, or on those employees in that part of the bargaining unit affected by the
change.”³²
In February 2006, however, a federal district court enjoined the regulations on
the grounds that they failed to ensure collective bargaining rights, did not provide for
the independent third-party review of labor-relations decisions, and failed to provide
a fair process for appealing adverse actions.³³ The case has been appealed and a
decision from the court of appeals is expected shortly. Whether unions have a
significant role in the BRAC process will likely depend on the validity of the NSPS
regulations, as well as the provisions of existing agreements and other DOD
implementing issuances.

³¹ 5 C.F.R. § 9901.905(a).
³² 5 C.F.R. § 9901.917(d)(2).
³³ American Federation of Government Employees, AFL-CIO v. Rumsfeld, 422 F.Supp.2d

16 (D.D.C. 2006).

Appendix. Net Federal Civilian Job Changes, by
State, Territory, and District of Columbia
Table 1. Net Federal Civilian Job Changes Under 2005 BRAC
Commission Recommendations
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^To^t^a^{l Net}^Federa^{l Civ}^ilia^{n J}^o^b^Chaⁿ^g^e^s^-¹⁵^,⁸⁷⁴
^Source:^{U.S. Def}^eⁿ^s^{e B}^a^s^e^C^l^os^u^r^{e an}^{d R}^ealigⁿ^m^en^{t C}^o^m^mⁱ^s^sⁱ^on^,^{2005 D}^e^f^e^ns^{e Bas}^e^C^l^os^ur^e
^{and Real}ⁱ^gnm^ent^C^o^m^mⁱ^s^sⁱ^{on Repor}^t^{, A}^ppen^dⁱ^x^O^.