August 23, 1999

RADM Fred L. Ames, USCG
United States Coast Guard (G-W)
2100 2nd Street SW
Washington, DC 20593-0001

Dear Admiral Ames:

The Chief Warrant and Warrant Officers Association recently concluded our 70th annual meeting.  One of the many agenda items discussed during this meeting was the shortage of personnel the Coast Guard was experiencing and how the warrant officer corps could be used to partially alleviate the shortage.  Increasing the opportunity for chief warrant officers to remain on active duty in excess of 30 years could result in a small reduction in the shortage of enlisted personnel.  Amending the USCG Personnel Manual would allow for an immediate impact and changing 10 U.S.C.1305(c) would provide a larger long-term impact.

Prior to 30 September 1985, retention of warrant officers beyond 30 years of total service under Title 10 U.S.C. 1305(c) was a common administrative practice.  That practice was sharply curtailed in 1985 because the Coast Guard was going through several years of reductions in personnel.  The limitations imposed in 1985 remain in effect today, even though the Coast Guard has fewer personnel then needed.  This limitation could be removed by amending Article 12.C.6 (b)(3) to reinstate the policy in effect prior to 30 September 1985 [See Enclosure (1)].  This would allow chief warrant officers who have completed 28 years of service for retirement to request extensions of up to four years, stating that they are willing to serve in any assignment/geographic area.  The decision on granting the extension would be based on the record of the officer, chain of command recommendations and service needs, considering the impact on enlisted to warrant officer appointments and the needs of the particular specialty, on a case by case basis.

The administrative action recommended above could have an immediate impact on the Coast Guard personnel shortage.  As a longer-term solution we recommend a change to 10 U.S.C. 1305(a) to allow Coast Guard chief warrant officers to serve for 30 years of active service as a warrant officer.  We would expect that the Selective Early Retirement provisions of 10 U.S.C. 581 may need to be used more frequently if chief warrant officers are allowed to continue on active duty for 30 years of warrant officer service.

I would like the opportunity to discuss your thoughts on this matter and offer the Associationís assistance in preparing a proposal that invokes the Commandantís authority to allow the Coast Guard to resolve a work force situation through the use of internal resources.

Sincerely,

Randy J. Cornell
President

Provisions of Article 12-C-6.b (3), USCG Personnel Manual

prior to promulgation of CH-24 on 30 September 1985

 (3)       The Commandant also may defer the retirement, in accordance with subparagraph (1), of a commissioned warrant or warrant officer with his/her consent and upon recommendation of a board of officers, but not later that 60 days after he/she becomes 62 years of age.       (10 USC 1305).     Chief warrant officers desiring to continue their active duty beyond 30 years may apply to Commandant (G-PO-3), at any time after they have completed 28 years of service for retirement.  Requests for extension shall be in a letter format and contain the following information: 

(a)           reason for requesting the extension. 

(b)           a statement by the requester indicating willingness to serve in any assignment/geographic area. 

(c)           desired length of extension.  Extensions may be granted for any period up to a maximum of 4 years for a single request.  Subsequent requests may be granted based on additional requests.  Chief warrant officers who are extended and are selected for promotion will be required to serve 2 years in the new grade.  Consideration of requests for retention by chief warrant officers serving as such shall be based on Service needs, considering the impact on enlisted to warrant officer promotions and the needs of the particular specialty.  Consideration of requests for retention by chief warrant officers serving in a higher temporary grade shall be based on Service needs taking into account the impact on the officer corps.  A chief warrant officer serving on an extension is not precluded from applying for voluntary retirement when he/she meets all eligibility requirements as set forth in article 12-C-9. 

(d)                 a concise recommendation by member's commanding officer. 

Provisions of Article 12-C-6.b (3), USCG Personnel Manual

after CH-24 is was promulgated on 30 September 1985 

3.  To satisfy a specific Service need, the Commandant also may defer retirement under subparagraph 1 above of a commissioned warrant officer with his/her consent and if a board of officers so recommends for up to 60 days after the officer turns 62 years old (10 USC 1305). Routine management of billet structure and staffing anticipates most Service needs.  Only in extremely unusual situations will a Service need arise which extending a Chief warrant officer on active duty beyond the mandatory 30-year retirement point can satisfy.  Chief warrant officers who want to continue on active duty beyond thirty years may apply to Commander, (CGPC-opm-1) between nine and 12 months before the mandatory retirement date.  Extensions may be granted for any period up to a maximum of four years for a single request.   Subsequent extensions may be granted based on additional requests.   Chief warrant officers so extended and selected for promotion are required to serve two years in the new grade.  A chief warrant officer serving on an extension may apply for voluntary retirement when he/she meets all eligibility requirements listed in Article 12.C.9.   Extension requests will be kept on file pending the identification of specific Service needs.   Whenever a need arises, a board of officers screens eligible applicants and selects the best-qualified candidate.  If an extension is not approved by six months before to the mandatory retirement date, the request will be removed from the file and the member retires on the mandatory retirement date.  A member may withdraw a request from consideration at any time. Submit extension requests in a letter format and contain the following information: 

a.  The reason to request the extension.

b.  The officerís statement indicating he or she is willing to serve in any assignment or geographic area. 

c.  Desired length of extension.

d.  A concise recommendation by the memberís chain of command.