Summary and Analysis of the

Future of Arlington National

Cemetery

DESCRIPTION Arlington National Cemetery is set

to reach maximum capacity by the

early 2040s. A Congressionally

mandated report by the Advisory

Committee on Arlington National

Cemetery has proposed several

options for extending that capacity

well into the future to serve the

nation’s servicemembers and

veterans. The Reserve Officers

Association offers several positions

on these options and proposals on

the future of Arlington National

Cemetery.

Ashwin Iyer Legislative and Military Policy

Assistant (Intern)

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Table of Contents

Introduction ............................................................................................................................................................. 2

Options .................................................................................................................................................................... 3

Reserve Officers Association Positions .................................................................................................................. 5

Conclusion .............................................................................................................................................................. 6

Appendices .............................................................................................................................................................. 7

Appendix A ......................................................................................................................................................... 7

Appendix B ......................................................................................................................................................... 8

Appendix C ......................................................................................................................................................... 9

Appendix D ....................................................................................................................................................... 11

Appendix E ........................................................................................................................................................ 12

Appendix F ........................................................................................................................................................ 13

Appendix G ....................................................................................................................................................... 14

Appendix H ....................................................................................................................................................... 15

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Introduction On 7 June 2017, the Reserve Officers Association attended a “stakeholder roundtable dialogue” and

Honor Subcommittee meeting for The Advisory Committee on Arlington National Cemetery. The ACANC is a

congressionally mandated non-discretionary advisory committee established under Title 10 U.S. Code § 4723 to

provide a vehicle for advice and recommendations to the Army with respect to the administration of Arlington

National Cemetery, the erection of memorials at the cemetery, and master planning for the cemetery. The Honor

Subcommittee is tasked with reviewing and providing recommendations to its parent committee on extending

the future of active burial gravesites, veteran eligibility criteria, and master planning. Appendix A provides the

mandate of Title 10 U.S. Code § 4723.

In response to Public Law 114-158, enacted on 20 May 2016, the ACANC produced a report titled:

“The Future of Arlington National Cemetery: Report on the Cemetery’s Interment and Inurnment Capacity

2017.” The report details the issue of declining capacity for interment and inurnment at the iconic Arlington

National Cemetery (ANC), and provides several options to prolong the longevity of the cemetery as an active

burial ground and final resting place for United States servicemembers, veterans, and their family members.

Appendix B provides the language of PL 114-158 and the requirements of the law. Specifically, the law

requires the publishing of “a report on the interment and inurnment capacity of Arlington National Cemetery,

including: the estimated date that the Secretary determines the cemetery will reach maximum interment and

inurnment capacity; and recommendations for legislative actions and nonlegislative options that the Secretary

determines necessary to ensure that the maximum interment and inurnment capacity of the cemetery is not

reached until well into the future.”

Founded on May 13, 1864, ANC has over 150 years of history and has interred and inurned over

400,000 people in that time. In just one year, fiscal year 2016, ANC became the first resting place of more than

7,100 servicemembers, veterans, and their family members, and averaged approximately 30 funeral services

each weekday. According to the Center for Army Analysis, the cemetery will reach capacity in the early 2040s,

if the ANC’s current geographical footprint and eligibility standards are maintained. Appendix C provides a

summary of the current eligibility standards for in-ground interment and above-ground inurnment at ANC.

Appendix D provides a map of the current geographical footprint of the cemetery.

This projection by the Center for Army Analysis has drastic implications for the ability of ANC to serve

current and future generations. If ANC maintains the current eligibility standards and geographical size, an 18-

year-old joining the armed forces today would have no chance of being laid to rest at ANC. Additionally, most

veterans of recent conflicts, such as the Gulf War, Somalia, Iraq, Afghanistan, and the War on Terrorism, would

never be afforded the honor of burial at ANC. If nothing is done to change the status quo, even heroes killed in

action or those receiving valorous awards, perhaps even the Medal of Honor, would be denied the honor.

Appendix E provides a graph showing the forecast of available ANC space by population and time.

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Options

In the ACANC report, several options are laid out to deal with the stated issue of Arlington National

Cemetery capacity, and to answer the Congressional directive to extend the longevity of the cemetery “well in

to the future.” The subcommittee defined this as adding 100 more years of longevity, or doubling the life of the

cemetery. This approach does not account for any future conflicts, which would drastically alter projections.

These options are broken down into three main types: changes to eligibility, changes to the geographical

footprint, and alternative approaches. In any future course of action chosen to solve this problem, a combination

of several of these options would most likely be necessary. Appendix F provides the given options in a chart,

and analyzes the potential benefits and impacts that would result from each individual option.

Expansion

One way to increase the capacity and longevity of the cemetery is to increase its geographical size. For

approximately the past 15 years, ANC has undergone the Millennium Expansion project, which has added 27

acres to the ANC. With completion occurring in 2017, the Millennium project will create over 27,000 new

burial opportunities and add more columbaria space, thus extending the longevity of the cemetery into the early

2040s. Appendix G provides a map of the recent and planned expansion projects. The ANC is currently in the

planning stages of a second land project, titled the Southern Expansion project. While yet to be approved by the

Secretary of the Army, the proposed Southern Expansion would add approximately 38 acres of land to ANC.

While promising, estimates project that this expansion would add 10-15 years of longevity to the cemetery,

delaying the potential closure to the mid-2050s. Lands surrounding ANC are highly developed with government

buildings, utilities, roads, and residential areas. In addition, there have been questions about preserving the

iconic nature of ANC, and that having highways and storage facilities so near the graves of servicemembers and

veterans would be a break from tradition. Thus, land expansion alone cannot be the answer, and we must look to

potential changes in eligibility standards.

Eligibility

Another way to increase the longevity of the cemetery “well into the future” is to restrict eligibility

standards for burial and inurnment. Over the course of ANC’s history, eligibility standards have changed

several times, both expanding and limiting eligibility, to accommodate servicemembers and veterans of major

wars, and to preserve the operation of the cemetery. Appendix H provides a timeline of major eligibility

changes over the past 150 years and the effects that they had on the number of interments per year. Thus, there

is historical precedent for changing eligibility at ANC.

Some of the proposed options for changes to ANC eligibility include the following:

• Making no change to eligibility standards.

• Adopting the requirement of a minimum of 24 months of continuous active duty used by the VA at other

national cemeteries

• Requiring for a retiree a certain length of service (e.g. 25 years)

• Only allowing those who are killed in action, die on active duty or receive qualifying awards.

• Only allowing those who are killed in action, die on active duty or receive the Medal of Honor.

• Only allowing those who are killed in action or receive the Medal of Honor.

• Changing eligibility for inground burial only.

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These options are difficult decisions to make, as each option restricts certain groups of servicemembers

and veterans. However, making no change to eligibility standards would practically ensure the closure of this

hallowed ground in the near future. This would fail to meet the requirements of the Congressional mandate to

extend the longevity of the cemetery into the next century.

Alternative Approaches

Apart from changing eligibility and the geographical footprint of the cemetery, other options were

presented by the ACANC. These include the use of the existing space in new ways, such as creating more

inurnment space or using “green burials” more frequently; the prohibition of new ANC monuments and

memorials that do not contain remains; the reservation of a certain number of burial spots for those who are

killed in action, die on active duty, or receive the Medal of Honor; and the enhancement of VA national

cemetery services to the level of ANC. Some of these practices would alter the iconic appearance of ANC, and

may incite criticism for a departure from tradition.

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Reserve Officers Association Positions For more than 90 years the Reserve Officers Association has been the only organization dedicated to

supporting Reservists and their critical role in national defense. Reserve service carries unique burdens and for

more than nine decades, the Reserve Officers Association has been the nation’s leading advocate for lifelong

support in recognition of these unprecedented contributions to the cause of freedom.

Alternatives and Expansion

To ensure the longevity of the cemetery and continuing the legacy of honoring those who sacrifice in the

line of duty, ROA would consider all the alternative approaches presented. In addition, ROA would consider all

options to expand the geographical footprint of the cemetery. ROA also presents two unique options that would

be viable as future courses of action.

Specifically, ROA suggests the establishment of a Department of Defense Arlington National Cemetery

annex, at a location such as Fort Belvoir. This would provide burial space for currently eligible members if

future restrictions are adopted. Though converting existing land to suit the purposes of ANC would take

decades to plan and execute, there is pressing need to relieve the constraint on space. Of course, the annex

would have to fulfill necessary criteria, such as the establishment of more funeral honors teams, chaplains,

cemetery operations, and support staff, as well as horses and equipment used in the ceremonies.

Another option that ROA suggests is the establishment of new Department of Defense national

cemeteries in the Central and Pacific zones. Many servicemember and veterans’ families seek to have a final

resting place for their loved ones that is easily accessible for visitation and commemoration. Having national

cemeteries across the country might better serve those families rather than concentrating interments and

inurnments in the Washington, D.C., area.

Eligibility

Regarding eligibility standards, ROA supports reviewing eligibility changes to standards for interment

and inurnment at Arlington National Cemetery and offers two points of consideration: First, maintaining the

status quo practically ensures the closure of ANC within 30 years, with significant consequences for present and

future veterans who, under current provisions, would be permitted burial there. Second – and of key importance

to ROA – federal law (32 CFR 553.12 - Eligibility for interment in Arlington National Cemetery) discriminates

against members of the Reserve and National Guard, establishing eligibility for: “Any service member who dies

on active duty in the U.S. Armed Forces (except those service members serving on active duty for training

only).” ROA wants this changed to establish eligibility and equity. Regardless of duty status, those who serve

honorably in the line of duty (along with other criteria) should be worthy of being buried at ANC.

ROA would oppose the option to mirror the VA national cemetery requirement of a minimum of 24

months of continuous active duty. Not only would that restrict many groups of servicemembers and

disenfranchise many veterans’ groups, but it is also an arbitrary baseline. The life (and death) of a

servicemember who serves for under 24 months is of no less value than that of any other servicemember. ROA

would only consider this option if companion changes at VA cemeteries are pursued. Otherwise, unnecessary

alienation would be the result.

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Conclusion ROA is not reflexively supportive of the ACANC’s general goal of changing eligibility requirements,

beyond our resolve to correct the aforementioned inequity that affects members of the Reserve and Guard.

Whether the rules stay as they are or become highly restrictive, whether or not we have more wars (we will), it

is inevitable that ANC will one day reach capacity.

The real solution is identification and development of alternative sites to place our warriors in honored

rest, as well as increasing the size of the cemetery and pursuing alternative approaches to expand its capacity.

While these are difficult decisions, preserving the cemetery’s operation for a period reasonably extended into

future is certainly highly desirable. Maintaining the status quo would result in closure in the near future and

leave no other place of ANC’s stature. That would be a disservice to current and future veterans and

servicemembers and disrupts a magnificent legacy of national memorialization. We must have a place of

Arlington’s stature and symbolism – whether it is the current site or ultimately a new one developed “in its

image” and ready to assume the sacred mission.

This was the first meeting by the subcommittee in a series of national engagements in connection with

the issue at hand. ROA appreciates the opportunity to participate and contribute to a matter of great importance

to the nation and to those who have lost their lives in defense of all we hold dear.

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Appendices

Appendix A

10 U.S. Code § 4723 - Advisory committee on Arlington National Cemetery

(a)Appointment.—

The Secretary of the Army shall appoint an advisory committee on Arlington National Cemetery.

(b)Role.—

The Secretary of the Army shall advise and consult with the advisory committee with respect to the administration of

Arlington National Cemetery, the erection of memorials at the cemetery, and master planning for the cemetery.

(c)Reports and Recommendations.—

The advisory committee shall make periodic reports and recommendations to the Secretary of the Army.

(d)Submission to Congress.—

Not later than 90 days after receiving a report or recommendations from the advisory committee under subsection (c), the

Secretary of the Army shall submit the report or recommendations to the congressional defense committees and the

Committees on Veterans’ Affairs of the Senate and House of Representatives and include such comments and

recommendations of the Secretary as the Secretary considers appropriate.

(Added Pub. L. 112–81, div. A, title V, § 591(a)(1), Dec. 31, 2011, 125 Stat. 1440.)

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Appendix B

130 STAT. 394 PUBLIC LAW 114–158—MAY 20, 2016 Public Law 114–158 114th Congress

Be it enacted by the Senate and House of Representatives of the

United States of America in Congress assembled,

SECTION 1. INURNMENT OF CREMATED REMAINS IN ARLINGTON NATIONAL

CEMETERY OF CERTAIN PERSONS WHOSE

SERVICE IS DEEMED TO BE ACTIVE

SERVICE.

(a) In General.--Section 2410 of title 38, United States Code, is

amended by adding at the end the following new subsection:

``(c)(1) The Secretary of the Army shall ensure that, under such

regulations as the Secretary may prescribe, the cremated remains of any

person described in paragraph (2) are eligible for above ground

inurnment in Arlington National Cemetery with military honors in

accordance with section 1491 of title 10.

``(2) A person described in this paragraph is a person whose service

has been determined to be active duty service pursuant to section 401 of

the GI Bill Improvement Act of 1977 (Public Law 95-202; 38 U.S.C. 106

note) as of the date of the enactment of this paragraph.''.

(b) <<NOTE: 38 USC 2410 note.>> Applicability.--

(1) In general.--The amendment made by subsection (a) shall

apply with respect to--

(A) the remains of a person that are not formally

interred or inurned as of the date of the enactment of

this Act; and

(B) a person who dies on or after the date of the

enactment of this Act.

(2) Formally interred or inurned defined.--In this

subsection, the term ``formally interred or inurned'' means

interred or inurned in a cemetery, crypt, mausoleum,

columbarium, niche, or other similar formal location.

SEC. 2. REPORT ON CAPACITY OF ARLINGTON NATIONAL CEMETERY.

Not later than 180 days after the date of the enactment of this Act,

the Secretary of the Army shall submit to the Committees on Veterans'

Affairs and the Committees on Armed Services of the House of

Representatives and the Senate a report on the interment and inurnment

capacity of Arlington National Cemetery, including--

(1) <<NOTE: Estimate. Determination.>> the estimated date

that the Secretary determines the cemetery will reach maximum

interment and inurnment capacity; and

(2) <<NOTE: Recommendations.>> in light of the unique and

iconic meaning of the cemetery to the United States,

recommendations for legislative actions and nonlegislative

options that the Secretary determines necessary to ensure that

the maximum interment and inurnment capacity of the cemetery is

not reached until well into the future, including such actions

and options with respect to--

(A) redefining eligibility criteria for interment

and inurnment in the cemetery; and

(B) considerations for additional expansion

opportunities beyond the current boundaries of the

cemetery.

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Appendix C

Eligibility for Interment (Ground Burial of Casketed or Cremated Remains)

Eligibility for interment at Arlington National Cemetery is verified at the time of need (at the time of death) and cannot be

verified by the cemetery or accommodated before that time. However, in accordance with Title 32 Code of Federal

Regulations Part 553, section 15a, the following individuals are eligible for interment (in-ground burial) at Arlington

National Cemetery:

▪ Any active duty member of the Armed Forces (except those members serving on active duty for training only).

▪ Any retired member of the Armed Forces. A retired member of the Armed Forces, in the context of this paragraph, is

a retired member of the Army, Navy, Air Force, Marine Corps, Coast Guard, or a Reserve component who has served

on active duty (other than for training), is carried on an official retired list, and is entitled to receive retired pay

stemming from service in the Armed Forces. If, at the time of death, a retired member of the Armed Forces is not

entitled to receive retired pay stemming from his service in the Armed Forces until some future date, the retired member

will not be eligible for ground burial.

▪ Any former member of the Armed Forces separated for physical disability prior to 1 October 1949 who has served on

active duty (other than for training) and who would have been eligible for retirement under the provisions of 10 United

States Code (U.S.C.) 1201 had that statute been in effect on the date of his separation.

▪ Any former member of the Armed Forces whose last active duty (other than for training) military service terminated

honorably and who has been awarded one of the following decorations

1. Medal of Honor

2. Distinguished Service Cross (Air Force Cross or Navy Cross)

3. Distinguished Service Medal

4. Silver Star

5. Purple Heart

▪ Persons who have held any of the following positions provided their last period of active duty (other than for training)

as a member of the Armed Forces terminated honorably:

1. An elective office of the United States Government

2. Office of the Chief Justice of the United States or of an Associate Justice of the Supreme Court of the United States

3. An office listed in 5 U.S.C. 5312 or 5 U.S.C. 5313

4. The Chief of a mission who was at any time during his/her tenure classified in class I under the provisions of Section

411 of the Act of 13 August 1946, 60 Stat. 1002, as amended (22 U.S.C. 866, 1964 ed.)

▪ Any former prisoner of war who, while a prisoner of war, served honorably in the active military, naval, or air service,

whose last period of active military, naval, or air service terminated honorably and who died on or after November 30,

1993.

1. The term “former prisoner of war” means a person who, while serving in the active military, naval, or air service,

was forcibly detained or interned in line of duty—

2. The term "active military, naval, or air service" includes active duty, any period of active duty for training during

which the individual concerned was disabled or died from a disease or injury incurred or aggravated in line of

duty, and any period of inactive duty training during which the individual concerned was disabled or died from

an injury incurred or aggravated in line of duty.

▪ The spouse, widow or widower, minor child and, at the discretion of the Secretary of the Army, unmarried adult child

of any of the persons listed above.

Eligibility for Inurnment in the Columbarium or Niche Wall

Eligibility for inurnment at Arlington National Cemetery is verified at the time of need (at the time of death) and cannot be

verified by the cemetery or accommodated before that time. However, in accordance with Title 32 Code of Federal

Regulations Part 553, section 15a, the following individuals are eligible for inurnment (Columbarium or Niche Wall) at

Arlington National Cemetery:

▪ Any member of the Armed Forces who dies on active duty.

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▪ Any former member of the Armed Forces who served on active duty (other than for training) and whose last service

terminated honorably.

▪ Any member of a Reserve component of the Armed Forces, and any member of the Army National Guard or the Air

National Guard, whose death occurs under honorable conditions while he is on active duty for training or performing

full-time service; performing authorized travel to or from that duty or service; or is on authorized inactive duty training

including training performed as a member of the Army National Guard or the Air National Guard. Also included are

those members whose deaths occur while hospitalized or undergoing treatment at the expense of the United States for

injury or disease contracted or incurred under honorable conditions while on that duty or service or performing that travel

or inactive duty training.

▪ Any member of the Reserve Officers' Training Corps of the Army, Navy, or Air Force whose death occurs under

honorable conditions while attending an authorized training camp or on an authorized practice cruise, performing

authorized travel to or from that camp or cruise, or hospitalized or undergoing treatment at the expense of the United

States for injury or disease contracted or incurred under honorable conditions while attending that camp or cruise,

performing that travel, or undergoing that hospitalization or treatment at the expense of the United States.

▪ Any former prisoner of war who, while a prisoner of war, served honorably in the active military, naval, or air service,

whose last period of active military, naval, or air service terminated honorably and who died on or after November 30,

1993.

▪ Any citizen of the United States who, during any war in which the United States has been or may hereafter be engaged,

served in the Armed Forces of any government allied with the United States during that war, whose last active service

terminated honorably by death or otherwise, and who was a citizen of the United States at the time of entry on such

service and at the time of death.

▪ Commissioned officers, United States Coast and Geodetic Survey (now National Oceanic and Atmospheric

Administration) who die during or subsequent to the service specified in the following categories and whose last service

terminated honorably:

▪ Any commissioned officer of the United States Public Health Service who served on full-time duty on or after July 29,

1945, if the service falls within the meaning of active duty for training as defined in 38 U.S.C. 101(22) or inactive duty

training as defined in 38 U.S.C. 101(23) and whose death resulted from a disease or injury incurred or aggravated in line

of duty. Also, any commissioned officer of the Regular or Reserve Corps of the Public Health Service who performed

active service prior to July 29, 1945 in time of war; on detail for duty with the Armed Forces; or while the service was

part of the military forces of the United States pursuant to Executive order of the President.

Spouses, minor children, and dependent adult children of the persons listed above. (Army Regulation 290-5 defines an

adult dependent child as an adult permanently incapable of self-support because of physical or mental disability incurred

before age 21.)

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Appendix D

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Appendix E

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Appendix F

Option Benefit Impact

Eligibility

1.a. Maintain Current Eligibility N/C N/C

1.b. 24 months of continuous active duty service minimum.

2 weeks of cemetery longevity for each year enacted

Restrictive on eligibility

1.c. Retirees at or above a certain length of service. Dependent on final decision Restrictive on eligibility, disenfranchise certain veteran groups

1.d. Killed in action, die on active duty, qualifying awards. [Points of reference KIA: (OEF 2,346), (OIF 4,412)]

Cemetery remains active until mid to late 2100s

Restrictive on eligibility and exclusionary to retirees

1.e. Killed in action, die on active duty, Medal of Honor only. [Point of Reference MoH: (3,500)]

Delay closure by 150 to 200 years Restrictive on eligibility and exclusionary to other qualifying awards

1.f. Killed in action, Medal of Honor only. Delay closure by at least 200 years Restrictive on eligibility and exclusionary

1.g. Change for in-ground burial, leave inurnment more open.

Burials until at least 2150 Above-ground space would reach capacity much faster

Expansion

2.a. Proposed Southern Expansion Project. (38 acres)

40-60K more burials, delay closure to the early 2050s

$20-$30 million per year of extended cemetery longevity

2.b. Adjacent government lands. (448 acres)

1,200 burials per acre, 1 year of longevity per 4 acres

Higher cost of repurposing developed land

2.c. Establish new DoD national cemetery. Dependent on final decision Dependent on location

Alternative approaches

3.a. New ways to use existing space. (more inurnment capacity, green burials)

Dependent on final decision Controversy from changing traditional ANC standards

3.b. Preserve set number of space for killed in action, die on active duty, Medal of Honor.

2 years of longevity for every 1000 spaces preserved

ANC overall capacity and timeframe would be shorter compared to changing eligibility

3.c. Prohibit use of ANC space for erecting monuments and memorials without remains. [Point of Reference: (31 memorials)]

Would help preserve existing space Restrictive of erecting monuments/memorials at ANC

3.d. Enhance VA cemeteries to mirror ANC’s. [Point of Reference: (135 national cemeteries)]

Dependent on final decision Dependent on final decision

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Appendix G

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Appendix H