October 19, 2018

Dear Advisory Committee Members,

On behalf of the 350,000 members of MOAA, thank you for the work you are doing on behalf of our military and veterans and their families. The deliberative and collaborative process by which you have studied the time and space constraints at Arlington National Cemetery is sincerely appreciated.

Further, thank you for allowing our association, along with many other veterans’ groups, to provide meaningful input on this topic. It shows great prudence and thoughtfulness to fully consider the opinions and interests of groups representing millions of our nation's servicemembers and families. I know we all agree on the importance of these burial grounds as a place of remembrance for those who serve.

Much of the capacity talks have revolved around "preserving the promise" of Arlington National Cemetery. To us, preserving the promise of the cemetery is resolving to allow those in the currently eligible population with expectations of burial at Arlington to execute their end-of-life plans. In our view, no promise exists that the cemetery will remain open for new burials forever. Nor is there a promise that future servicemembers, even retirees, will have the option for burial there. "Preserving the promise" also means preserving the dignified setting, aesthetics, and history of the cemetery. While many other national cemeteries across the nation serve a similar purpose in honoring those who served, Arlington has a special connotation.

MOAA has several recommendations:

·         Avoid restricting eligibility for the military retiree population, other than reserving a set number of plots for specific honorees, such as those killed in action or those who receive a Medal of Honor;

·         Urge Congress to appropriate funds for acquisition and development of adjacent land, including completion of the Southern Expansion project currently underway; and

·         Seek funds for the study and eventual acquisition of noncontiguous land to be used as an Arlington annex.

Throughout the course of deliberation, two primary options have come into focus for extending the active life of the cemetery: eligibility changes and expansion. Eligibility restrictions are more challenging for us to concede. MOAA does not oppose reserving a select number of gravesites for those who are killed in action or earn a particular award of high honor. However, the expectation and earned right to be laid to rest at Arlington for the currently eligible population should not be exchanged for an active duty servicemember who dies from a noncombat-related incident many decades in the future. If and when eligibility changes for some gravesites, there must also be a clear definition of "line of duty deaths" so the currently eligible veteran does not feel as though they were denied a spot unfairly. "Qualifying awards" must also be clearly delineated.

Along those lines, anticipating and managing future burial opportunity expectations is an absolute must. A robust communication plan should be put in place well ahead of any effective date of eligibility changes. MOAA will surely do our part in spreading the word, but the Army must also seek all avenues to avoid the undesirable scenario of exacerbating an already stressful and emotional time in families' lives because of a lack of awareness.  

Further, if at the end of your deliberations, eligibility restrictions are deemed desirable or necessary, MOAA suggests there should at a minimum be a reinstatement of a reservation system to allow those who already have plans a chance to have their wishes honored.

We surveyed our membership about the cemetery's capacity concerns two years ago, revealing that reaching maximum capacity is a widely accepted fate. Our members accept that when the cemetery is full, it's full. At the same time, respondents were evenly split over changing eligibility restrictions after expansion options are exhausted. About two-thirds of respondents suggested eligibility changes would be acceptable as long as retirees remain eligible. Our survey very much underscored the difficulty policymakers face in making a decision.

Congress might be focused on the eligibility side of the equation, but expansion should not be dismissed. We believe expansion of the cemetery grounds, contiguously or not, is a viable path forward and is the preferred method of extending the life of the cemetery. While a costly and time-consuming undertaking, MOAA members have clearly indicated their preference of expansion over significantly restricting eligibility. The advisory committee's first survey also revealed a strong desire to undertake expansion efforts.

Admittedly, opportunities for expansion to adjacent lands are limited, with approximately 448 acres of government-owned land and 65 acres of privately-owned land. However, Option 2C of the February 2017 Advisory Committee report to Congress (PL 114-158) suggests the establishment of a new DoD national cemetery at a new location, which could serve as the starting point for noncontiguous expansion. Locations such as Gettysburg or Quantico could serve as dignified burial sites associated with the original Arlington cemetery. While such a cemetery would not possess the same feel at the outset, there is potential to develop such an aura over time. Recall the Arlington we know today did not develop its reputation overnight.

I'll conclude by emphasizing the feasibility of meeting the requirements set forth in the FY 2019 National Defense Authorization Act without disenfranchising a large portion of the currently eligible population. If you set aside just over 30,000 of the currently available plots - either in or above ground or a combination of both - for servicemembers who are killed in action, die on active duty, and/or are recipients of the Medal of Honor, and current burial rates continued according to your calculations, the cemetery would remain active for 150 more years.*

According to the 2017 Report to Congress (PL 114-158), roughly 146,000 plots or niches remain, assuming eventual completion of the Southern Expansion project. That means 80 percent of the first interment burial sites could remain open for a broader segment of the currently eligible population, and the cemetery would still remain active “well into the future.”

Thus, I implore you once more to avoid restricting eligibility for the military retiree population with some exception, take bold steps to acquire more land, and develop a strategic plan for acquisition for noncontiguous land for the future.

Thank you once again for the opportunity to share MOAA's perspective on the options going forward prior to your final recommendation. We are grateful for the full commitment to exploring all potential courses of action on this issue and eagerly await any final decisions that come from this discussion.

I welcome any opportunities to further contribute to your deliberations.

Sincerely,

Dana T. Atkins

President and CEO