Military Training
DOD Approach to Managing Encroachment on Training Ranges Still Evolving Gao ID: GAO-03-621T April 2, 2003DOD faces growing challenges in carrying out realistic training at installations and training ranges--land, air, and sea--because of encroachment by outside factors. These include urban growth, competition for radio frequencies or airspace, air or noise pollution, unexploded ordnance and munition components, endangered species habitat, and protected marine resources. Building on work reported on in 2002, GAO assessed (1) the impact of encroachment on training ranges, (2) DOD's efforts to document the effect on readiness and cost, and (3) DOD's progress in addressing encroachment.
Encroachment was reported as having affected some training range capabilities, requiring workarounds--or adjustments to training events--and sometimes limiting training, at all stateside installations and major commands GAO visited. GAO has identified similar effects abroad. Encroachment generally limits the time that training ranges are available and the types of training conducted. This in turn limits units' ability to train as they would fight. Most encroachment issues are caused by population growth and urban development. Because both are expected to increase, as are the speed and range of weapon systems used on training ranges, the problems are also expected to increase. Despite DOD--voiced concerns about encroachment's effects on training, service readiness data in 2002 did not show the impact of encroachment on training readiness or costs, although DOD's most recent quarterly report to Congress on readiness did tie a training issue directly to encroachment. While individual services are making some assessment of training requirements and limitations imposed by encroachment, comprehensive assessments remain to be done. Likewise, complete inventories of training ranges are not yet available to foster sharing of ranges on an interservice or joint basis. This increases the risk of inefficiencies, lost time and opportunities, delays, and added cost. Also, although some services have reported higher costs because of encroachment-related workarounds for training, service data systems do not capture the costs comprehensively. DOD has made some progress in addressing individual encroachment issues, such as implementing some short-term actions, proposing legislation to clarify the relationship between training and conservation statutes, and issuing a range sustainment directive. But more is required for a comprehensive plan, as recommended by GAO earlier, that clearly identifies steps to be taken, goals and milestones to track progress, and required funding.
GAO-03-621T, Military Training: DOD Approach to Managing Encroachment on Training Ranges Still Evolving
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Testimony:
Before the Committee on Environment and Public Works, U.S. Senate:
United States General Accounting Office:
GAO:
For Release on Delivery Expected at 9:30 a.m. EST:
Wednesday, April 2, 2003:
Military Training:
DOD Approach to Managing Encroachment on Training Ranges Still
Evolving:
Statement of Barry W. Holman, Director
Defense Infrastructure Issues:
GAO-03-621T:
GAO Highlights:
Highlights of GAO-03-621T, a testimony before the Committee on
Environment and Public Works, U.S. Senate
Why GAO Did This Study:
DOD faces growing challenges in carrying out realistic training at
installations and training ranges”land, air, and sea”because of
encroachment by outside factors. These include urban growth,
competition for radio frequencies or airspace, air or noise pollution,
unexploded ordnance and munition components, endangered species
habitat, and protected marine resources. Building on work reported on
in 2002, GAO assessed (1) the impact of encroachment on training
ranges, (2) DOD‘s efforts to document the effect on readiness and cost,
and (3) DOD‘s progress in addressing encroachment.
What GAO Found:
Encroachment was reported as having affected some training range
capabilities, requiring workarounds”or adjustments to training
events”and sometimes limiting training, at all stateside installations
and major commands GAO visited. GAO has identified similar effects
abroad. Encroachment generally limits the time that training ranges are
available and the types of training conducted. This in turn limits
units‘ ability to train as they would fight. Most encroachment issues
are caused by population growth and urban development. Because both are
expected to increase, as are the speed and range of weapon systems used
on training ranges, the problems are also expected to increase.
Despite DOD-voiced concerns about encroachment‘s effects on training,
service readiness data in 2002 did not show the impact of encroachment
on training readiness or costs, although DOD‘s most recent quarterly
report to Congress on readiness did tie a training issue directly to
encroachment. While individual services are making some assessment of
training requirements and limitations imposed by encroachment,
comprehensive assessments remain to be done. Likewise, complete
inventories of training ranges are not yet available to foster sharing
of ranges on an interservice or joint basis. This increases the risk of
inefficiencies, lost time and opportunities, delays, and added cost.
Also, although some services have reported higher costs because of
encroachment-related workarounds for training, service data systems
do not capture the costs comprehensively.
DOD has made some progress in addressing individual encroachment
issues, such as implementing some short-term actions, proposing
legislation to clarify the relationship between training and
conservation statutes, and issuing a range sustainment directive.
But more is required for a comprehensive plan, as recommended by GAO
earlier, that clearly identifies steps to be taken, goals and
milestones to track progress, and required funding.
What GAO Recommends:
GAO is not making any new recommendations. However, GAO did make
recommendations in reports issued in April and June 2002 (GAO-02-525
and GAO-02-614). They were aimed at (1) improving the quality of
readiness reporting to better reflect training constraints and (2)
helping DOD develop a comprehensive plan for dealing with encroachment
issues and improving the information and data available for identifying
and reporting on the effects of encroachment. In addition, the Congress
directed DOD to report periodically on its progress in addressing
encroachment issues and requires GAO to review those reports.
www.gao.gov/cgi-bin/getrpt?GAO-03-621T.
To view the full report, including the scope and methodology, click on
the link above. For more information, contact Barry W. Holman at
(202) 512-8412 or holmanb@gao.gov.
[End of section]
Mr. Chairman and Members of the Committee:
I am pleased to have the opportunity to discuss the results of our work
involving the constraints that encroachment places on military
training. As you know, senior Department of Defense (DOD) and service
officials have testified that they face growing difficulties in
carrying out realistic training at installations and training
ranges[Footnote 1] because of so-called ’encroachment“ [Footnote 2]
issues, which limit their ability to train military forces at the
desired levels and proficiencies. The eight encroachment issues
identified by DOD are urban growth around military installations,
competition for radio frequency spectrum; air pollution; noise
pollution; competition for airspace; unexploded ordnance and munitions
components;[Footnote 3] endangered species habitat; and protected
marine resources.
My testimony is largely built on work we reported on last year
concerning the effects of encroachment in the continental United States
on military training and readiness.[Footnote 4] Last year we also
reported on the constraints on training of U.S. forces
overseas.[Footnote 5] The findings of the two reviews have some
similarities. Today, I would like to briefly highlight our findings
regarding (1) the growing impact of encroachment on training range
capabilities, (2) DOD‘s efforts to document the effects of encroachment
on readiness and costs, and (3) DOD‘s process in addressing
encroachment.
Summary:
On the basis of our observations and discussions with officials at
installations and major commands we visited last year here in the
United States, we obtained numerous examples where encroachment had
affected some training range capabilities, requiring workarounds--or
adjustments to training events--and, in some cases, limited training.
We identified similar effects overseas. The potential problem with
workarounds is that they lack realism and can lead to the practice of
tactics that are contrary to those used in combat. Officials, both
stateside and abroad, reported that encroachment at times limits the
time that training ranges are available and the types of training that
can be conducted. Service officials believe that urbanization and
population growth is primarily responsible for encroachment in the
United States and is likely to cause more training range losses in the
future.
Despite concerns voiced repeatedly by DOD officials about the effects
of encroachment on training, DOD‘s readiness reports did not indicate
the extent to which encroachment was adversely affecting training
readiness and costs. In fact, at the time we did our review, most
readiness reports showed that units had a high state of readiness; and
they were largely silent on the issue of encroachment. Recently,
however, one DOD readiness report indicated that the Air Force has
attributed environmental encroachment to a reduced capability to
conduct flight training.[Footnote 6] We have previously reported on
limitations in DOD‘s readiness reporting.[Footnote 7] While
improvements in readiness reporting can and should be made to better
show any shortfalls in training, DOD‘s ability to fully assess training
limitations and their overall impact on training capabilities and
readiness will be limited without (1) more complete baseline data, such
as a comprehensive database, on all training range capabilities and the
services‘ training range requirements and (2) full consideration of how
live training capabilities may be complemented by other forms of
training, such as those available through training devices and
simulations. These actions will not replace other steps needed to deal
with encroachment, but they are key to better define the magnitude of
the encroachment problem now and in the future. At the same time, it is
important to note that while it is widely recognized that encroachment
results in workarounds that can increase training costs, those costs
are not easily aggregated to measure their full effect.
Although DOD has made some progress in addressing individual
encroachment issues, that effort is still evolving; and more work will
be required to put in place a comprehensive plan, as we recommended
earlier, that clearly identifies steps to be taken, goals and
milestones to track progress, and required funding. We reported last
year that the department had prepared draft action plans that deal with
each encroachment issue separately, but information was limited on
specific actions planned, time frames for completing them, and funding
needed. In December 2001, DOD directed an Integrated Product Team to
act as the coordinating body for all encroachment issues, develop a
comprehensive set of legislative and regulatory proposals by January
2002, and formulate and manage outreach efforts. Last year and just
recently, DOD submitted a package of legislative proposals, which it
describes as clarifications, seeking to modify several statutory
requirements. We are aware that consideration of these and other
related legislative proposals affecting existing environmental
legislation will need to include potential trade-offs among multiple
policy objectives and issues on which we have not taken a position. At
the same time, we also understand that DOD recently asked the services
to develop procedures for invoking the national security exceptions
under a number of environmental laws. Historically, DOD and the
services have been reluctant to seek such exceptions; and we are aware
of only a couple of instances where this has been done. In our report
last June on stateside encroachment issues, we made several
recommendations aimed at helping DOD develop a comprehensive plan for
dealing with encroachment and improve the information and data
available for identifying and reporting on the effects of encroachment.
[Footnote 8] Our two reports last year recommended that DOD develop
reports that accurately capture the causes of training shortfalls and
objectively report units‘ ability to meet their training requirements.
Following our reports, DOD issued a range sustainment
directive[Footnote 9] to establish policy and assign responsibilities
for the sustainment of test and training ranges; and the Special
Operations Command developed a database identifying the training ranges
it uses, type of training conducted, and restrictions on training. The
department also plans to develop a set of internal policies and
procedures based on the range sustainment directive, strengthen and
empower its management structure to deal with range issues, and take a
more proactive role in working with local governments and
organizations.
We are not making any new recommendations in this testimony. As you may
be aware, Mr. Chairman, section 366 of the Bob Stump National Defense
Authorization Act for Fiscal Year 2003 requires a series of yearly
reports to the Congress dealing with encroachment issues beginning this
year, and a requirement for GAO to review those reports. The first of
those reports was required to be submitted along with the President‘s
budget for fiscal year 2004. That report was to describe DOD‘s progress
in developing a comprehensive plan to use existing authorities to
address training constraints on the use of military lands, marine
areas, and airspace that are available in the United States and
overseas for training. However, to our knowledge, DOD has not yet
issued this report. The Act also requires the submission of a report
not later than June 30, 2003, on plans of the department to improve its
readiness reporting to reflect the readiness impact that training
constraints have on specific units of the armed forces.
Background:
Military ranges and training areas are used primarily to test weapon
systems and train military forces. Required facilities include air
ranges for air-to-air, air-to-ground, drop zone, and electronic combat
training; live-fire ranges for artillery, armor, small arms, and
munitions training; ground maneuver ranges to conduct realistic force-
on-force and live-fire training at various unit levels; and sea ranges
to conduct ship maneuvers for training.
According to DOD officials, there has been a slow but steady increase
in encroachment issues that have limited the use of training
facilities, and the gradual accumulation of these issues increasingly
threatens training readiness. DOD has identified eight such
encroachment issues:
* Designation of critical habitat under the Endangered Species Act of
1973. Under the Act, agencies are required to ensure that their actions
do not destroy or adversely modify habitat that has been designated for
endangered or threatened species. Currently, over 300 such species are
found on military installations. In 1994, under the previous
administration 14 agencies signed a federal memorandum of
understanding[Footnote 10] for implementing the Endangered Species
Act.[Footnote 11] The agencies agreed to establish or use existing
regional interagency working groups to identify geographic areas within
which the groups would coordinate agency actions and overcome barriers
to conserve endangered species and their ecosystems. Such cooperative
management could help DOD share the burden of land use restrictions on
military installations that are caused by encroachment issues, but
implementation of this approach has been limited. We are currently
reviewing this issue.[Footnote 12]
* Application of environmental statutes to military munitions. DOD
believes that the Environmental Protection Agency could apply
environmental statutes to the use of military munitions, shutting down
or disrupting military training. According to DOD officials,
uncertainties about future application and enforcement of these
statutes limit their ability to plan, program, and budget for
compliance requirements.
* Competition for radio frequency spectrum. The telecommunications
industry is pressuring for the reallocation of some of the radio
frequency spectrum from DOD to commercial control. DOD reports that
over the past decade, it has lost about 27 percent of the frequency
spectrum allocated for aircraft telemetry. And we previously reported
additional allocation of spectrum could affect space systems, tactical
communications, and combat training.[Footnote 13]
* Marine regulatory laws that require consultation with regulators when
a proposed action may affect a protected resource. Defense officials
say that the process empowers regulators to impose potentially
stringent measures to protect the environment from the effects of
proposed training in marine environments.
* Competition for airspace. Increased airspace congestion limits the
ability of pilots to train as they would fly in combat.
* Clean Air Act requirements for air quality. DOD officials believe the
Act requires controls over emissions generated on Defense
installations. New or significant changes in range operations also
require emissions analyses, and if emissions exceed specified
thresholds, they must be offset with reductions elsewhere.
* Laws and regulations mandating noise abatement. DOD officials stated
that weapon systems are exempt from the Noise Control Act of 1972, but
DOD must assess noise impact under the National Environmental Policy
Act. As community developments have expanded closer to military
installations, concerns over noise from military operations have
increased.
* Urban growth. DOD says that unplanned or ’incompatible“ commercial or
residential development near training ranges compromises the
effectiveness of training activities. Local residents have filed
lawsuits charging that military operations lowered the value or limited
the use of their property.
To the extent that encroachment adversely affects training readiness,
opportunities exist for the problems to be reported in departmental and
military service readiness reports. The Global Status of Resources and
Training System is the primary means units use to compare readiness
against designed operational goals.[Footnote 14] The system‘s database
indicates, at selected points in time, the extent to which units
possess the required resources and training to undertake their wartime
missions. In addition, DOD is required under 10 U.S.C. 117 to prepare
quarterly readiness reports to Congress. The reports are based on
briefings to the Senior Readiness Oversight Council, a forum assisted
by the Defense Test and Training Steering Group. In June 2000, the
council directed the steering group to investigate encroachment issues
and develop a comprehensive plan of action.
The secretaries of the military services are responsible for training
personnel and for maintaining their respective training ranges and
facilities. Within the Office of the Secretary of Defense, the Under
Secretary of Defense for Personnel and Readiness develops policies,
plans, and programs to ensure the readiness of the force and provides
oversight on training; the Deputy Under Secretary of Defense for
Installations and Environment develops policies, plans, and programs
for DOD‘s environmental, safety, and occupational health programs,
including compliance with environmental laws, conservation of natural
and cultural resources, pollution prevention, and explosive safety; and
the Director, Operational Test and Evaluation, provides advice on tests
and evaluations.
Encroachment Has Reduced Some Capabilities, and Its Effects Are Likely
to Grow:
On the basis of what we have seen, the impact of encroachment on
training ranges has gradually increased over time, reducing some
training capabilities. Because most encroachment problems are caused by
urban development and population growth, these problems are expected to
increase in the future.
Although the effects vary by service and by individual installation,
encroachment has generally limited the extent to which training ranges
are available or the types of training that can be conducted. This
limits units‘ ability to train as they would expect to fight and causes
workarounds that may limit the amount or quality of training.
Installations overseas all reported facing similar training
constraints.
Some of the problems reported by installations we visited last year
were those related to urban growth, radio frequency spectrum
interference, air quality, noise, air space, and endangered species
habitat. For example, in response to local complaints, Fort Lewis,
Washington, voluntarily ceased some demolitions training. Eglin Air
Force Base, Florida, officials reported the base‘s major target control
system received radio frequency spectrum interference from nearby
commercial operators. Nellis Air Force Base, Nevada, officials reported
that urban growth near the base and related safety concerns had
restricted flight patterns of armed aircraft, causing mission delays
and cancellations. They also reported that they receive approximately
250 complaints about noise each year. About 10 percent of Marine Corps
Base Camp Pendleton, California, had been designated as critical
habitat for endangered species. Atlantic Fleet officials reported
encroachment problems stemming from endangered marine mammals and
noise. They said that the fleet‘s live-fire exercises at sea were
restricted, and night live-fire training was not allowed.
More recently, in January 2003, DOD‘s Special Operations Command
reported that its units encounter a number of obstacles when scheduling
or using training ranges.[Footnote 15] According to the report, the
presence of endangered species and marine mammals on or near ranges
result in restrictions on training for at least part of the year--
closing the area to training, prohibiting live fire, or requiring
modified operations. For example, a variety of endangered species live
on the training areas of the Navy Special Warfare Command in
California, particularly on Coronado and San Clemente islands. Due to
environmental restrictions, Navy Special Warfare units report that they
can no longer practice immediate action drills on Coronado beaches;
they cannot use training areas in Coronado for combat swimmer training;
and they cannot conduct live-fire and maneuver exercises on much of San
Clemente Island during some seasons. In addition, the Special
Operations Command owns no training ranges of its own and largely
depends on others for the use of their training ranges. As a result,
command officials advised us that they must train under operational and
scheduling restrictions imposed by its host commands. For example, the
command normally trains at night; and because range management
personnel are not often available at night, this prevents such
training. Also, on many ranges, the command reported that priority is
given to larger units than special operations units causing it to
postpone or cancel training. According to the report, ranges are also
inadequately funded for construction, maintenance, repairs, and
upgrades. This results in some commanders using their own funds in
order to prevent the ranges from becoming dangerous or unusable.
The Special Operations Command, while expressing concern for the
future, reported that none of the eight encroachment issues identified
by DOD had yet stopped military training, due mostly to the creativity
and flexibility of its commanders and noncommissioned officers. In
general, when obstacles threaten training, the unit will find a
workaround to accomplish the training. In some instances, the unit may
travel to another training facility, costing additional money for
transportation and potentially requiring an extended stay at the
training site. By sending units away to train, the command limits its
ability to send people on future travel for training or missions due to
efforts to control the number of days per year that servicemembers are
deployed away from home. Other workarounds consist of commands using
different equipment, such as plastic-tipped bullets; changing
maneuvering, firing, and training methods to overcome training
obstacles; and using facilities that need repair. According to the
Special Operations Command, all of these workarounds expend more funds
and manpower in order to accomplish its training mission.
DOD and military service officials said that many encroachment issues
are related to urban growth around military installations. They noted
that most, if not all, encroachment issues result from urban and
population growth and that around DOD installations this is increasing
at a rate higher than the national average. Figure 1 illustrates the
increase in urban growth encroachment near Fort Benning, Georgia, while
the fort has remained relatively unchanged. According to DOD officials,
new residents near installations often view military activities as an
infringement on their rights, and some groups have organized in efforts
to reduce operations such as aircraft and munitions training. At the
same time, according to Defense officials, the increased speed and
range of weapon systems are expected to increase training range
requirements.
Figure 1: Historical and Projected Urban Growth Near Fort Benning,
Georgia:
[See PDF for image]
Note: (Top left to right) Urban growth near Fort Benning, Georgia, in
1955 and 1985. (Bottom left to right) Urban growth near Fort Benning,
Georgia, in 1996 and projected for 2008.
[End of figure]
Effects of Encroachment on Training Readiness and Costs Have Not Been
Reflected in Most Service Readiness Reports:
Despite the loss of some training range capabilities, service readiness
data did not show the impact of encroachment on training readiness.
However, DOD‘s January 2003 quarterly report to Congress did tie an Air
Force training issue directly to encroachment.
Even though DOD officials in testimonies and many other occasions have
repeatedly cited encroachment as preventing the services from training
to standards, DOD‘s primary readiness reporting system did not reflect
the extent to which encroachment was a problem. In fact, it rarely
cited training range limitations at all. Similarly, DOD‘s quarterly
reports to Congress, which should identify specific readiness problems,
hardly ever mentioned encroachment as a problem.
This is not surprising to us because we have long reported on
limitations in DOD‘s readiness reporting system and the need for
improvements; our most recent report was issued just last
week.[Footnote 16] Furthermore, on the basis of our prior reports on
readiness issues and our examination of encroachment, we do not believe
the absence of data in these reports concerning encroachment should be
viewed simply as ’no data, no problem!“ Rather, as with other readiness
issues we have examined over time, it suggests a lack of attention on
the part of DOD in fully assessing and reporting on the magnitude of
the encroachment problem.
However, DOD‘s most recent quarterly report did indicate a training
issue that is tied directly to encroachment. The January 2003
Institutional Training Readiness Report showed that the Air Force has
rated itself as
C-2 for institutional flight training.[Footnote 17] This indicates that
it is experiencing some deficiencies with limited impact on
capabilities to perform required institutional training. The Air Force
attributed this to training range availability and encroachment
combined with environmental concerns that are placing increasing
pressure on its ability to provide effective and realistic training.
The Air Force also reported that sortie[Footnote 18] cancellations are
becoming a more common occurrence and may soon adversely impact the
quality of training. For example, the spotting of a Sonoran Pronghorn
on the Barry M. Goldwater Range forces immediate cancellation or
relocation of scheduled missions.
Readiness reporting can and should be improved to address the extent of
training degradation due to encroachment and other factors. However, it
will be difficult for DOD to fully assess the impact of encroachment on
its training capabilities and readiness without (1) obtaining more
complete information on both training range requirements and the assets
available to support those requirements and (2) considering to what
extent other complementary forms of training may help mitigate some of
the adverse impacts of encroachment. The information is needed to
establish a baseline for measuring losses or shortfalls.
We previously reported that the services did not have complete
inventories of their training ranges and that they do not routinely
share available inventory data with each other (or with other
organizations such as the Special Operations Command). DOD officials
acknowledge the potential usefulness of such data and have some efforts
underway to develop these data. However, since there is no complete
directory of DOD-wide training areas, commanders sometimes learn about
capabilities available on other military bases by chance. All this
makes it extremely difficult for the services to leverage assets that
may be available in nearby locations, increasing the risk of
inefficiencies, lost time and opportunities, delays, added costs, and
reduced training opportunities.
Although the services have shared training ranges, these arrangements
are generally made through individual initiatives, not through a formal
or organized process that easily and quickly identifies all available
infrastructure. Last year, for example, our reported on
encroachment[Footnote 19] noted that the Navy Special Operations forces
recently learned that some ranges at the Army‘s Aberdeen Proving
Grounds in Maryland are accessible from the water--a capability that is
a key requirement for Navy team training. Given DOD‘s increasing
emphasis on joint capabilities and operations, having an inventory of
defense-wide training assets would seem to be a logical step toward a
more complete assessment of training range capabilities and shortfalls
that may need to be addressed.
This issue was recently reinforced by the January 2003 range report by
the Special Operations Command, which found that none of the services
had joint databases or management tools to combine all training ranges
into a single tool accessible to all commands. The command concluded
that such a centralized database would contribute to improving unit
readiness and mission success for all components. At the same time, we
cannot be sure of the extent to which recent military operations in the
Middle East could impact future training requirements. DOD will need to
reassess lessons learned from these operations.
Each service has, to varying degrees, assessed its training range
requirements and limitations due to encroachment. For example, the
Marine Corps has completed one of the more detailed assessments of the
degree to which encroachment has affected the training capability of
Camp Pendleton, California. The assessment determined to what extent
Camp Pendleton could support the training requirements of two unit
types and two specialties by identifying the tasks that could be
conducted to standards in a ’continuous“ operating scenario (e.g., an
amphibious assault and movement to an objective) or in a fragmented
manner (tasks completed anywhere on the camp). The analysis found that
from 60 to 69 percent of continuous tasks and from 75 to 92 percent of
the other training tasks could be conducted to standards. Some of the
tasks that could not be conducted to standards were the construction of
mortar-and artillery-firing positions outside of designated areas,
cutting of foliage to camouflage positions, and terrain marches. Marine
Corps officials said they might expand the effort to other
installations. At the same time, the Air Force has funded a study at
Shaw Air Force Base, South Carolina, which focuses on airspace
requirements; and the Center for Navy Analysis is reviewing
encroachment issues at Naval Air Station Fallon, Nevada. We have not
had an opportunity to review the progress or the results of these
efforts. In its 2003 range study report, the Special Operations Command
compiled a database identifying the training ranges it uses, type of
training conducted, and restrictions on training. In its study, the
command recommended that a joint training range database be produced
and made available throughout DOD so that all training ranges,
regardless of service ownership, may be efficiently scheduled and
utilized.
While recent efforts show increased activity on the part of the
services to assess their training requirements, they do not yet
represent a comprehensive assessment of the impacts of encroachments.
We have also previously reported that the services have not
incorporated an assessment of the extent that other types of
complementary training could help offset shortfalls. We believe these
assessments, based solely on live training, may overstate an
installation‘s problems and do not provide a complete basis for
assessing training range needs. A more complete assessment of training
resources should include assessing the potential for using virtual or
constructive simulation technology to augment live training. However,
based on our prior work I must emphasize, Mr. Chairman, that these
types of complementary training cannot replace live training and cannot
fully eliminate the impact of encroachment, though they may help
mitigate some training range limitations.
In addition, while some service officials have reported increasing
costs because of workarounds related to encroachment, the services‘
data systems do not capture these costs in any comprehensive manner. In
its January 2003 report, the Special Operations Command noted that the
services lacked a metric-base reporting system to document the impact
of encroachment or track the cost of workarounds in either manpower or
funds. We noted last year that DOD‘s overall environmental conservation
funding, which also covers endangered species management, had
fluctuated, with an overall drop (except for the Army) in obligations
since 1999. If the services are indeed conducting more environmental
assessments or impact analyses as a result of encroachment, the
additional costs should be reflected in their environmental
conservation program obligations.
Progress in Addressing Encroachment Issues Still Evolving:
DOD has made some progress in addressing individual encroachment
issues, including individual action plans and legislative proposals.
But more will be required to put in place a comprehensive plan that
clearly identifies steps to be taken, goals and milestones to track
progress, and required funding. Senior DOD officials recognized the
need to develop a comprehensive plan to address encroachment issues
back in November 2000, but efforts to do so are still evolving. To
their credit, DOD and the services are increasingly recognizing and
initiating steps to examine range issues more comprehensively and in a
less piecemeal fashion.
Recent efforts began in 2000 when a working group of subject matter
experts was tasked with drafting action plans for addressing the eight
encroachment issues. The draft plans include an overview and analysis
of the issues; and current actions being taken, as well as short-, mid-
, and long-term strategies and actions to address the issues. Some of
the short-term actions implemented include the following.
* DOD has finalized, and the services are implementing, a Munitions
Action Plan--an overall strategy for addressing the life-cycle
management of munitions to provide a road map that will help DOD meet
the challenges of sustaining its ranges.
* DOD formed a Policy Board on Federal Aviation Principles to review
the scope and progress of DOD activities and to develop the guidance
and process for special use air space.
* DOD formed a Clean Air Act Services‘ Steering Committee to review
emerging regulations and to work with the Environmental Protection
Agency and the Office of Management and Budget to protect DOD‘s ability
to train.
* DOD implemented an Air Installation Compatible Use Zone Program to
assist communities in considering aircraft noise and safety issues in
their land use planning.
Some future strategies and actions identified in the draft plans
addressing the eight encroachment issues include the following.
* Enhancing outreach efforts to build and maintain effective working
relationships with key stakeholders by making them aware of DOD‘s need
for training ranges, its need to maintain readiness, and its need to
build public support for sustaining training ranges.
* Developing assessment criteria to determine the cumulative effect of
all encroachment restrictions on training capabilities and readiness.
The draft plan noted that while many examples of endangered species/
critical habitat and land use restrictions are known, a programmatic
assessment of the effect these restrictions pose on training readiness
has never been done.
* Ensuring that any future base realignment and closure decisions
thoroughly scrutinize and consider the potential encroachment impact
and restrictions on operations and training of recommended base
realignment actions.
* Improving coordinated and collaborative efforts between base
officials and city planners and other local officials in managing urban
growth.
In December 2001, the Deputy Secretary of Defense established a senior-
level Integrated Product Team to act as the coordinating body for
encroachment efforts and to develop a comprehensive set of legislative
and regulatory proposals by January 2002. The team agreed on a set of
possible legislative proposals for clarifying some encroachment issues.
After internal coordination deliberations, the proposals were submitted
in late April 2002 to Congress for consideration. According to DOD, the
legislative proposals sought to ’clarify“ the relationship between
military training and a number of provisions in various conservation
and compliance statutes, including the Endangered Species Act, the
Migratory Bird Treaty Act, the Marine Mammal Protection Act, and Clean
Air Act. DOD‘s proposals would, among other things, do the following:
* Preclude designation under the Endangered Species Act of critical
habitat on military lands for which Sikes Act Integrated Natural
Resources Management Plans have been completed. At the same time, the
Endangered Species Act requirement for consultation between DOD and
other agencies on natural resource management issues would remain.
* Permit DOD to ’take“ migratory birds under the Migratory Bird Treaty
Act without action by the Secretary of the Interior, where the taking
would be in connection with readiness activities, and require DOD to
minimize the taking of migratory birds to the extent practicable
without diminishment of military training or other capabilities, as
determined by DOD.
* Modify the definition of ’harassment“ under the Marine Mammal
Protection Act as it applies to military readiness activities.[Footnote
20]
* Modify the conformity provisions of the Clean Air Act. The proposal
would maintain the Department‘s obligation to conform military
readiness activities to applicable state implementation plans but would
give DOD 3 years to demonstrate conformity. In the meantime, DOD could
continue military readiness activities.
* Change the definition of solid waste under the Solid Waste Disposal
Act to generally exclude explosives, unexploded ordnance, munitions,
munition fragments, or constituents when they are used in military
training, research, development, testing and evaluation; when not
removed from an operational range; when promptly removed from an off-
range location; or when recovered, collected, and destroyed on range at
operational ranges. Solid waste would not include buried unexploded
ordnance when burial was not a result of product use.
Of the above proposals, Congress passed, as part of the fiscal year
2003 defense authorization legislation, a provision related to the
Migratory Bird Treaty Act.[Footnote 21] Under that provision, until the
Secretary of the Interior prescribes regulations to exempt the armed
forces from incidental takings of migratory birds during military
readiness activities, the protections provided for migratory birds
under the Act do not apply to such incidental takings. In addition,
Congress authorized DOD to enter agreements to purchase property or
property interests for natural resource conservation purposes, such as
creating a buffer zone near installations to prevent encroachment
issues, such as urban growth.[Footnote 22]
In February 2003, DOD submitted to Congress the Readiness and Range
Preparedness Initiative for fiscal year 2004. In it, the department
restates a number of legislative proposals from 2002 and includes a
proposal concerning the Marine Mammal Protection Act. In the 2004
initiative, the department seeks to reconcile military readiness
activities with the Marine Mammal Protection Act by adding language to
sections of title 16 of the U.S. Code.
We are aware that consideration of these legislative proposals
affecting existing environmental legislation will need to include
potential tradeoffs among multiple policy objectives and issues on
which we have not taken a position. At the same time, we also
understand that DOD recently asked the services to develop procedures
for invoking the national security exceptions under a number of
environmental laws. Historically, DOD and the services have been
reluctant to seek such exceptions; and we are aware of only a couple of
instances where this has been done.
Our two reports last year both recommended that DOD develop reports
that accurately capture the causes of training shortfalls and
objectively report units‘ ability to meet their training requirements.
At the time we completed our reviews in 2002, DOD‘s draft action plans
for addressing the eight encroachment issues had not been finalized.
DOD officials told us that they consider the plans to be working
documents and stressed that many concepts remain under review and may
be dropped, altered, or deferred, while other proposals may be added.
No details were available on overall actions planned, clear assignments
of responsibilities, measurable goals and time frames for accomplishing
planned actions, or funding requirements--information that would be
needed in a comprehensive plan. Our report on stateside encroachment
problems also recommended that DOD develop and maintain a full and
complete inventory of service and department-wide training
infrastructure; consider more alternatives to live training; and ensure
that the plan for addressing encroachment includes goals, timelines,
responsibilities, and projected costs.[Footnote 23] Our recently issued
report on overseas training also recommended that DOD develop reports
that accurately capture the causes of training shortfalls and
objectively report units‘ ability to meet their training
requirements.[Footnote 24]
Following our reports, DOD issued a range sustainment directive to
establish policy and assign responsibilities for the sustainment of
test and training ranges,[Footnote 25] and the Special Operations
Command developed a database identifying the training ranges it uses,
type of training conducted, and restrictions on training. In addition,
DOD is working with the other regulatory agencies in the federal
government to manage the way in which laws are enforced and plans to
issue four more directives that cover outreach, range clearance,
community noise, and Air Installation Compatibility Use Zone.
In the Bob Stump National Defense Authorization Act for Fiscal Year
2003, Congress required the Secretary of Defense to develop a
comprehensive plan for using existing authorities available to the
Secretary of Defense and the secretaries of the military departments to
address training constraints on the use of military lands, marine
areas, and airspace that are available in the United States and
overseas for training.[Footnote 26] As part of the preparation of the
plan, the Secretary of Defense was expected to conduct an assessment of
current and future training range requirements of the armed forces and
an evaluation of the adequacy of current DOD resources (including
virtual and constructive training assets as well as military lands,
marine areas, and airspace available in the United States and overseas)
to meet those current and future training range requirements. Also, as
you may be aware, Mr. Chairman, that Act requires annual reports to
Congress dealing with encroachment issues beginning this year and
requires GAO to review those reports. The first of those reports was
required to be submitted along with the President‘s budget for fiscal
year 2004. That report was to describe the progress in developing a
comprehensive plan to address training constraints. To our knowledge,
Mr. Chairman, DOD has not completed a comprehensive plan or provided
Congress with the progress report. Officials of the Office of the
Secretary of Defense said that they plan to report to Congress later
this calendar year. The Act also requires the submission of a report
not later than June 30, 2003, on the department‘s plans to improve its
readiness reporting to reflect the readiness impact that training
constraints have on specific units of the armed forces.
This concludes my statement. I would be pleased to answer any questions
you or other members of the Committee may have at his time.
Contact and Acknowledgment:
For further contacts regarding this statement, please contact Barry W.
Holman on (202) 512-8412. Individuals making key contributions to this
statement include Tommy Baril, Byron Galloway, Jane Hunt, John Lee,
Mark A. Little, Patti Nichol, Michelle K. Treistman, and John Van
Schaik.
FOOTNOTES
[1] The term ’training ranges“ in this testimony refers to air, live-
fire, ground maneuver, and sea ranges.
[2] DOD defines encroachment as the cumulative result of any and all
outside influences that inhibit normal military training and testing.
[3] Unexploded ordnance are munitions that (1) have been primed, fused,
armed, or otherwise prepared for action; (2) have been fired, dropped,
launched, projected, or placed in such a manner as to constitute a
hazard to operations, installations, personnel, or material; and (3)
remain unexploded either by malfunction, design or any other cause.
Munitions components--which DOD calls ’constituents“--include things
such as propellants, explosives, pyrotechnics, chemical agents, metal
parts, and other inert components that can pollute the soil or ground
water.
[4] U.S. General Accounting Office, Military Training: DOD Lacks a
Comprehensive Plan to Manage Encroachment on Training Ranges,
GAO-02-614 (Washington, D.C.; June 11, 2002). The Chairmen of the
Committee on Government Reform and its Subcommittee on National
Security, Emerging Threats and International Relations, House of
Representatives, requested this review.
[5] U.S. General Accounting Office, Military Training: Limitations
Exist
Overseas but Are Not Reflected in Readiness Reporting, GAO-02-525
(Washington, D.C.: Apr. 30, 2002). The Chairman of the Subcommittee on
Readiness and Management Support, Committee on Armed Services, U.S.
Senate, requested this review.
[6] U.S. Department of Defense, Quarterly Readiness Report to the
Congress, Institutional Training Readiness Report for Fiscal Year 2002,
Unclassified Annex E (Washington, D.C.: Jan. 2003).
7] U.S. General Accounting Office, Military Readiness: New Reporting
System Is Intended to Address Long-Standing Problems, but Better
Planning Is Needed, GAO-03-456 (Washington, D.C.: Mar. 28, 2003).
[8] GAO-02-614.
[9] U.S. Department of Defense, Directive: Sustainment of Ranges and
Operating Areas (OPAREAs), 3200.15, Jan. 10, 2003.
[10] Federal Interagency Memorandum of Understanding for Implementation
of the Endangered Species Act, September 1994.
[11] The 14 federal agencies included the Department of Agriculture‘s
Forest Service; the Department of Defense; the U.S Army Corps of
Engineers; the Department of Commerce‘s National Marine Fisheries
Service; the Department of the Interior‘s Bureau of Land Management,
Bureau of Mines, Bureau of Reclamation, Fish and Wildlife Service,
Minerals Management Service, and National Park Service; the Department
of Transportation‘s Federal Aviation Administration, Federal Highway
Administration, and Coast Guard; and the Environmental Protection
Agency.
[12] At the request of the Committee on Government Reform and its
Subcommittee on National Security, Emerging Threats and International
Relations, House of Representatives, we are reviewing (1) the extent to
which management of endangered species and related land use
restrictions are shared by DOD and other federal landowners and (2) the
efforts that DOD and/or other federal landowners have undertaken to
promote cooperative management and additional steps needed to enhance
this approach. We expect to report on the results of this work later
this year.
[13] U.S. General Accounting Office, Defense Spectrum Management: More
Analysis Needed to Support Spectrum Use Decisions for the 1755-1850MHz
Band, GAO-01-795 (Washington, D.C.: Aug. 20, 2001).
[14] The Global Status of Resources and Training System, which units
use to report their readiness status monthly or whenever a change
occurs. Units report readiness in four resource areas, including
training. If a unit is not at the highest readiness level, it must
identify the reasons from a list that includes training areas.
Commanders may also include narrative statements with more detailed
explanations.
[15] U.S. Special Operations Command, Tiger Team Report: Global Special
Operations Forces Range Study, Jan. 27, 2003. The Special Operations
Command recommended that all components needed to create master range
plans that addressed their current and future range issues and
solutions. The command also recommended that plans identify and
validate training requirements and facilities available and define the
acceptable limits of workarounds.
[16] GAO-03-456.
[17] By a way of comparison, C-1 rating is when a unit is at its
highest readiness level and is able to fully meet its mission.
[18] A sortie is one mission by a single aircraft.
[19] GAO-02-614.
[20] The Marine Mammal Protection Act‘s definition of ’harassment“ has
been a source of confusion. According to DOD, the statute defines
’harassment“ in terms of ’annoyance“ or the ’potential to disturb,“
standards that DOD asserts are difficult to interpret. The statute, 10
U.S.C. 1362, defines the term as any act of pursuit, torment, or
annoyance which has the potential to injure or disturb a marine mammal
by causing disruption to behavioral patterns such as migration,
nursing, feeding, breeding, and sheltering.
[21] Section 315, P.L. 107-314, Dec. 2, 2002.
[22] Section 2811, P.L. 107-314, Dec. 2, 2002 (codified at 10 U.S.C.
2684).
[23] GAO-02-614.
[24] GAO-02-525.
[25] U.S. Department of Defense, Directive: Sustainment of Ranges and
Operating Areas (OPAREAs), 3200.15, Jan. 10, 2003.
[26] Section 366, P.L. 107-314, Dec. 2, 2002.
