Environmental Compliance
Better DOD Guidance Needed to Ensure That the Most Important Activities Are Funded Gao ID: GAO-03-639 June 17, 2003The Department of Defense (DOD) and its military services are responsible for complying with a broad range of environmental laws and other requirements that apply to the lands they manage, including more than 425 major military installations covering about 25 million acres across the United States. Through its environmental quality program, DOD spends about $2 billion per year to comply with these requirements. Although the services have made significant improvements in environmental management in recent years, DOD has not reached full environmental compliance. In response to the Senate Armed Services Committee's report on the National Defense Authorization Act for Fiscal Year 2002, we assessed how DOD and the services identify, prioritize, and fund their environmental quality activities to determine whether the most important and appropriate activities are funded.
DOD's and the services' policies and processes for the environmental quality program do not always ensure that program funds are targeted to the most important and appropriate environmental activities. Instead, GAO found that some installations have funded low-priority or other activities that were ineligible under their environmental quality funding policies, at the same time that higher-priority activities were not funded. For example, at certain large installations that GAO visited, low-priority activities, such as noise monitoring, or ineligible activities, such as pest management, landscaping, and roof replacement, were funded while high-priority activities to prevent soil erosion were not. At the root of the problem is DOD's broad program policy that does not provide specific guidance on what activities are eligible for the program and the resulting inconsistent interpretation and implementation of this policy by the military services. DOD's policy requires that all high-priority activities be funded, but gives the services broad discretion in how this policy is put into place. As a result, GAO found (1) inconsistencies across and within the services about which activities are eligible for environmental quality program funding and (2) the funding of some activities through the program that more closely relate to military operations or base maintenance. For example, some services use program funds for oil and hazardous material spill response plans, equipment, and cleanup costs, while other services require the organization responsible for the spill to pay for the cleanup portion of those costs. Similarly, service policies can differ regarding responsibility for funding maintenance of structures such as water and sewer treatment facilities and historic buildings. Without a consistently implemented approach, there is no assurance that DOD's requirement to fund all high-priority activities is being met. Instead, some high-priority projects are being deferred. Generally, these deferrals involve projects that, although required by law, do not have to be completed by specific dates (e.g., surveys of properties required by historic preservation law). Deferring such activities, however, can lead to larger and more costly problems later. Moreover, to fund unbudgeted emergency environmental activities, the installations may have to defer other high-priority environmental program activities, obtain funds from other sources at the installation such as maintenance activities, or obtain funds from higher command levels. Some services have recently indicated that the availability of funds for environmental activities is likely to get worse in future years, because of expected reductions in their budgets for this program. Such constraints make a well-implemented prioritization process even more important.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-03-639, Environmental Compliance: Better DOD Guidance Needed to Ensure That the Most Important Activities Are Funded
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Report to Congressional Committees:
United States General Accounting Office:
GAO:
June 2003:
Environmental Compliance:
Better DOD Guidance Needed to Ensure That the Most Important Activities
Are Funded:
GAO-03-639:
GAO Highlights:
Highlights of GAO-03-639, a report to the Senate and House Committees
on Armed Services
Why GAO Did This Study:
The Department of Defense (DOD) and its military services are
responsible for complying with a broad range of environmental laws and
other requirements that apply to the lands they manage, including more
than 425 major military installations covering about 25 million acres
across the United States. Through its environmental quality program,
DOD spends about $2 billion per year to comply with these
requirements. Although the services have made significant improvements
in environmental management in recent years, DOD has not reached full
environmental compliance. In response to the Senate Armed Services
Committee‘s report on the National Defense Authorization Act for
Fiscal Year 2002, we assessed how DOD and the services identify,
prioritize, and fund their environmental quality activities to
determine whether the most important and appropriate activities are
funded.
What GAO Found:
DOD‘s and the services‘ policies and processes for the environmental
quality program do not always ensure that program funds are targeted
to the most important and appropriate environmental activities.
Instead, GAO found that some installations have funded low-priority or
other activities that were ineligible under their environmental
quality funding policies, at the same time that higher-priority
activities were not funded. For example, at certain large
installations that GAO visited, low-priority activities, such as noise
monitoring, or ineligible activities, such as pest management,
landscaping, and roof replacement, were funded while high-priority
activities to prevent soil erosion were not.
At the root of the problem is DOD‘s broad program policy that does not
provide specific guidance on what activities are eligible for the
program and the resulting inconsistent interpretation and
implementation of this policy by the military services. DOD‘s policy
requires that all high-priority activities be funded, but gives the
services broad discretion in how this policy is put into place. As a
result, GAO found (1) inconsistencies across and within the services
about which activities are eligible for environmental quality program
funding and (2) the funding of some activities through the program
that more closely relate to military operations or base maintenance.
For example, some services use program funds for oil and hazardous
material spill response plans, equipment, and cleanup costs, while
other services require the organization responsible for the spill to
pay for the cleanup portion of those costs. Similarly, service
policies can differ regarding responsibility for funding maintenance
of structures such as water and sewer treatment facilities and
historic buildings.
Without a consistently implemented approach, there is no assurance
that DOD‘s requirement to fund all high-priority activities is being
met. Instead, some high-priority projects are being deferred.
Generally, these deferrals involve projects that, although required by
law, do not have to be completed by specific dates (e.g., surveys of
properties required by historic preservation law). Deferring such
activities, however, can lead to larger and more costly problems
later. Moreover, to fund unbudgeted emergency environmental
activities, the installations may have to defer other high-priority
environmental program activities, obtain funds from other sources at
the installation such as maintenance activities, or obtain funds from
higher command levels. Some services have recently indicated that the
availability of funds for environmental activities is likely to get
worse in future years, because of expected reductions in their budgets
for this program. Such constraints make a well-implemented
prioritization process even more important.
What GAO Recommends:
DOD should establish a more specific policy on which activities are
eligible for funding through the environmental quality program and how
such activities should be prioritized and funded. The military
services should revise their policies and processes to conform to the
revised DOD policy. DOD did not provide comments on these
recommendations as of the issuance date of this report.
www.gao.gov/cgi-bin/getrpt?GAO-03-639.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact Anu K. Mittal at
(202) 512-3841 or mittala@gao.gov.
Contents:
Letter:
Results in Brief:
Background:
DOD's and the Services' Policies and Processes Do Not Always Ensure
That the Most Important and Appropriate Environmental
Quality Activities Are Funded:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: GAO Contacts and Staff Acknowledgments:
Figure:
Figure 1: DOD's Environmental Quality Funding, Fiscal Year 2002:
Abbreviations:
DOD: Department of Defense GAOGeneral Accounting Office
NEPA: National Environmental Policy Act:
United States General Accounting Office:
Washington, DC 20548:
June 17, 2003:
The Honorable John W. Warner Chairman The Honorable Carl Levin Ranking
Minority Member Committee on Armed Services United States Senate:
The Honorable Duncan Hunter Chairman The Honorable Ike Skelton Ranking
Minority Member Committee on Armed Services House of Representatives:
The Department of Defense (DOD) and its military services--the Air
Force, Army, Navy, and Marine Corps--must comply with a broad spectrum
of federal, state, and local environmental laws, regulations, and
executive orders that apply to the lands they manage, including more
than 425 major military installations covering approximately 25 million
acres across the United States. Through its environmental quality
program, DOD spends about $2 billion per year to comply with
environmental requirements that address (1) routine activities to
ensure environmental compliance, such as the proper disposal of
hazardous waste; (2) pollution prevention activities; and (3) a wide
range of conservation activities, including the preservation of
prehistoric sites and the protection of more than 300 endangered plant
and animal species found on installations. To ensure that the
environmental quality program funds the most important and appropriate
activities, DOD has developed a general policy for the military
services to follow in identifying, prioritizing, and funding
environmental quality activities. In turn, each military service has
established its own policy or guidance to implement the environmental
quality program across its installations.
Although the services have, over the past decade, made significant
improvements in their environmental compliance record, according to
DOD's estimates these improvements have leveled off in recent years and
DOD has not yet reached its goal of full environmental compliance. In
response to provisions of the Senate Armed Services Committee's report
on the National Defense Authorization Act for Fiscal Year 2002, we
assessed DOD's and the military services' policies and processes for
identifying, prioritizing, and funding their environmental quality
activities, including unexpected or emergency needs, to determine the
extent to which these processes and practices ensure that the most
important and appropriate activities are funded.
As part of our work, we reviewed policies and procedures established
by DOD and the services to guide implementation of the environmental
quality program. We also visited 11 military installations to review
how they were implementing the program and reviewed the environmental
funding requests for fiscal years 1999 through 2001 for these 11 and
another 4 installations.[Footnote 1] We selected these installations
based on their large environmental budgets and because they represent a
range of major commands, missions, and geographic locations. Our
observations about individual projects or activities at these
installations are not generalizable to projects or activities at all
military installations. We conducted our work between May 2002 and May
2003 in accordance with generally accepted government auditing
standards. A more detailed description of our review scope and
methodology is in appendix I.
Results in Brief:
The Department of Defense's and the military services' policies and
processes for the environmental quality program do not always ensure
that the most important and appropriate environmental activities are
funded. Instead, we found that some installations had funded low-
priority activities or ones that were ineligible under their policies,
such as pest management and roof replacement, at the same time that
higher-priority activities were not funded. At the root of the problem
is DOD's broad program policy that does not provide specific guidance
on what activities are eligible for the program and the resulting
inconsistent interpretation and implementation of this policy by the
military services. The variations among the services' programs can
result in different eligibility requirements for environmental
activities across the services. For example, under the Air Force's and
the Army's policies, the cleanup of oil and hazardous substance spills
is eligible for environmental quality program funding, while the Navy
and Marine Corps require the organization responsible for the spill to
pay the cleanup costs. The variations can also result in funding
activities through the environmental quality program that may be more
closely related to military operations or base maintenance. For
example, at some installations we visited the environmental quality
program funded routine maintenance activities. Without a consistently
implemented approach, there is no assurance that DOD's requirement for
funding all high-priority environmental activities is being met. We
found that the services have not always been able to fund all high-
priority activities through the environmental quality program and in
some cases the installations we visited had to defer certain
environmental activities when funding was not available. Moreover, the
installations we visited were able to fund their emergency, unbudgeted,
high-priority environmental activities by redirecting funds from other
activities such as base maintenance. Some services indicated that this
situation is likely to worsen in the future with expected reductions in
their budgets for the program. Such constraints make a well-implemented
prioritization process even more important.
Because the broad nature of DOD's policy and the resulting differences
in program implementation among the military services make it difficult
to ensure that the most important and appropriate environmental
activities are being funded, we are making recommendations to DOD aimed
at establishing a more specific policy on which activities are eligible
for environmental quality program funding and how such activities
should be prioritized and funded. Further, we are recommending that
once the department revises its policy, the services should update
their own policies and processes to ensure consistency with the
revisions.
We provided DOD with a draft of this report for review and comment. DOD
provided technical clarifications, which we incorporated as
appropriate. However, DOD did not provide overall comments as of the
issuance date of this report.
Background:
DOD's operations at military installations and other defense sites in
the United States are subject to the same environmental laws and
regulations, such as the Clean Air Act and the Clean Water Act, as is
private industry.[Footnote 2] Additionally, DOD policy calls for its
organizational components to achieve, maintain, and monitor compliance
with all applicable executive orders, as well as all federal, state,
and local statutory and regulatory requirements.
DOD has an environmental quality program to address these requirements,
which fall into three main categories: (1) environmental compliance
activities; (2) pollution prevention activities; and (3) conservation
activities, such as the protection of natural and cultural resources
present on military installations.[Footnote 3] DOD has developed and
implemented policies for activities in each major program
category.[Footnote 4]
By far, the majority of DOD's investment in its environmental quality
program is for its environmental compliance requirements. For example,
in fiscal year 2002, about 81 percent of DOD's investment of more than
$2 billion in the environmental quality program was for compliance
activities, including personnel costs for the entire program;
11 percent was for pollution prevention; and 8 percent was for
conservation activities. (See fig. 1.):
Figure 1: DOD's Environmental Quality Funding, Fiscal Year 2002:
[See PDF for image]
[A] Compliance includes personnel costs for the entire environmental
quality program.
[End of figure]
Funding allocated to the environmental quality program in recent years
has come largely from DOD's appropriation for operation and maintenance
activities.[Footnote 5] This appropriation account funds a diverse set
of activities, including military training, depot maintenance, base
operations support, and real property maintenance.[Footnote 6] The
funding allocated to the environmental quality program from the
operations and maintenance account may be used for other,
nonenvironmental, purposes as needed by the services or installations.
For example, once funding for operations and maintenance activities,
including environmental quality activities, has been allocated to an
installation commander, the commander has the authority to use these
funds as necessary for the needs of the installation. Likewise, if
funding allocated to an installation by the service or the major
command for environmental quality activities is not sufficient to
ensure that the installation remains in compliance with its
environmental requirements, the installation commander has the
authority to reallocate funds to the environmental quality program.
Installation commanders are responsible for ensuring that their
installations are in compliance with environmental requirements.
The installations are responsible for identifying all regulations and
other environmental requirements that apply to them, and identifying
and tracking pending requirements.[Footnote 7] To carry out their
environmental responsibilities, the installation commanders are
typically supported by an environmental program office, including staff
with expertise in various environmental areas such as air, water, or
hazardous waste. Managers for these areas are responsible for
identifying current and pending environmental requirements applicable
at their installation. Additionally, DOD has regional environmental
offices that assist installations in identifying current and pending
environmental requirements, particularly at the state and local levels.
Officials at each installation develop a list of planned activities,
along with the priority levels and estimated costs of these activities,
for the installation's environmental quality program for the upcoming 6
fiscal years. The greatest emphasis and detail is provided for those
activities for funding in the first 2 fiscal years, called the budget
years.
DOD's environmental quality policy uses the following classification
system to prioritize environmental activities:
* Class 0 activities are recurring activities needed to keep an
environmental program running and meet compliance requirements, such as
employee salaries, costs of environmental permits, and office supplies.
* Class I activities are nonrecurring projects and activities that must
be funded in the current program year (and, in some cases, up to
several years in the future to complete the project or activity) to
correct noncompliance with an environmental requirement or to ensure
that the installation will remain in compliance.
* Class II activities are those that have compliance deadlines, but
these deadlines will not occur until after the current budget year.
* Class III activities are typically referred to as "nice to have"
activities that address overall environmental goals and objectives,
but are not necessary for an installation to remain in compliance with
environmental requirements.
Based on DOD's policy, the services have developed prioritization
systems for making funding decisions. Consistent with DOD policy,
Army and Air Force policies specify that Class 0 and Class I activities
must be funded.[Footnote 8] Similarly, the Navy and Marine Corps also
have a policy of funding all Class 0 and I activities, according to
service officials, but their official program policy guidance does not
mention this. Consistent with DOD policy, the services also require
that selected Class II activities be funded in time to ensure
compliance with future requirements. None of the services' policies
require funding of Class III activities. In this report, "must fund"
Class 0 and I activities are referred to as high-priority activities.
DOD's policy does not differentiate among activities within Class 0 and
Class I. For example, because any unfunded Class I activity will result
in noncompliance with an environmental requirement, all Class I
activities have equal weight as "must fund" activities, according to
DOD's policy. However, in addition to the priority categories described
above, some major commands have developed their own, more detailed
prioritization approaches to help ensure that the most important
environmental activities will be funded before other, less important
activities within the same class. These approaches are intended to rank
proposed environmental activities by their relative importance. These
approaches emphasize somewhat different considerations, such as the
risk of harm to human health or the environment should an activity not
be funded, or the risk of receiving a notice of violation from a
regulator if the installation is out of compliance with an
environmental requirement.
After the environmental program's staff has identified, prioritized,
and estimated the costs of proposed activities, the list of proposed
activities may be reviewed by other installation officials, such as
legal staff or the installation commander. The list is then forwarded
to the next higher command level for its approval. For the Air Force,
Army, and Navy, this next higher level is the major command,[Footnote
9] while Marine Corps installations forward their proposed
environmental budgets directly to their environmental program's
headquarters. In some cases, the major command disagrees with the
priority level that an installation assigned to an activity or the
funding level that the installation requested. The command, or
headquarters, in the case of the Marine Corps, may disapprove, or
"invalidate," a proposed activity for environmental funding, revise the
funding level estimate (either up or down), or change the priority
level. The major command consolidates the requests from each
installation under its authority, then submits a commandwide request to
its service headquarters.
The service headquarters are involved to differing degrees in reviewing
the details of the installations' environmental requests. The Air
Force's environmental staff rely on the reviews of individual proposed
activities by their major commands. As mentioned above, the Marine
Corps' environmental office is involved in assessing and prioritizing
proposed activities at installations. The Navy's environmental staff
reviews proposed activities to assess whether they are legally required
to undertake them, whether the cost estimates are reasonable, and
whether the proposed time frames for completing the activities are
realistic. The Army's environmental staff reviews selected
environmental activities that were approved by the major commands. Army
headquarters officials told us that they expect to expand their review
to all activities approved by their major commands now that they have
automated their database of proposed environmental activities.
Next, the Office of the Secretary of Defense reviews the environmental
quality program budget requests. The Secretary's office does not review
these budgets on a project-by-project basis; instead, its review
focuses on the services' overall environmental compliance track records
and whether the proposed budgets will serve to continue to improve each
service's compliance performance. Finally, the estimates for the
environmental quality program budget are incorporated into each
service's estimate of its overall needs, and DOD's overall budget
request is included in the annual presidential budget request to the
Congress.[Footnote 10]
DOD's and the Services' Policies and Processes Do Not Always Ensure
That the Most Important and Appropriate Environmental
Quality Activities Are Funded:
Based on broad DOD policy, each military service has established its
own policy and processes to implement the environmental quality
program. Specifically, the four services have developed somewhat
different criteria under their policies and practices for determining
which activities are eligible for funding through their environmental
quality programs and which activities are funded. Given these
differences, DOD cannot be certain that it is funding the most
important and appropriate activities across the services and, likewise,
the services cannot ensure that they are devoting program funds to the
most important and appropriate environmental activities at their
installations.
The Services' Varying Interpretations of DOD's Broad Policy Have
Resulted in Inconsistent Eligibility Criteria and Funding of Activities
More Closely Related to Military Operations or Maintenance:
DOD's policy provides the services with a broad charge to comply with
applicable environmental requirements, such as statutes and
regulations, but leaves to the services most decisions about which
activities are appropriate for funding through their environmental
quality programs. We found that the services' varying interpretations
of this policy have resulted in different eligibility requirements and
in funding of activities through the environmental quality program that
may have been more closely related to military operations or
maintenance.
The Services' Policies Differ in Which Activities Are Eligible for
Their Environmental Quality Programs:
Although the services have developed policies intended, in part, to
clarify which activities can be funded through the environmental
quality program, implementation of these policies has sometimes led to
inconsistencies across the services in the types of activities they
determine eligible for funding. Also, some of the services or their
organizational components have developed additional guidance to assist
installations in determining whether certain activities can be funded
through their environmental quality programs. For example, the Air
Force's Environmental Quality Programming Matrix provides an extensive
listing of activities and indicates whether or not each is valid for
environmental quality program funding. The Navy's Pacific Fleet has
similarly developed guidance, its Policy on Environmental Issues
Matrix, to help clarify what is eligible for environmental funding. The
Pacific Fleet's guidance also indicates who should pay for activities
that are not eligible for environmental quality program funding,
something that the Air Force matrix does not address.
While these efforts to provide additional guidance are helpful to the
individual services' environmental quality program managers, they do
not address or resolve the cross-service inconsistencies on what
activities are eligible for funding. For example, we found the
following differences in program eligibility:
* Environmental impact statements. Under the National Environmental
Policy Act (NEPA), the military services are required to assess the
environmental effect of their major proposed actions, such as new
construction or certain military training on their installations. The
Navy's and Air Force's environmental quality programs consider NEPA-
required environmental assessments or environmental impact statements
as high-priority environmental activities. In fiscal year 2002, for
example, the Navy's environmental quality program spent $17.8 million
to comply with NEPA requirements. In contrast, the Marine Corps' and
Army's policies generally do not treat NEPA requirements as eligible
for environmental quality program funding. However, the Army's
environmental quality program will pay for some NEPA oversight and
assistance activities such as training for environmental quality
program staff. The Marine Corps' policy requires that the organizations
whose actions trigger NEPA requirements pay for NEPA-related expenses;
only in the case that a project is environmentally driven does the
Marine Corps policy allow environmental quality program funds to be
used to pay for NEPA-related expenses.
* Historic rehabilitation. The Marine Corps' environmental quality
program, which includes conservation of historic resources, requires
installations to protect their properties that are listed on the
National Register of Historical Places. For example, the Marine Corps'
environmental quality program spent nearly $800,000 to restore an adobe
ranch house on Camp Pendleton in southern California that was built in
1890 and had been listed by the National Trust for Historic
Preservation as one of the most endangered historic structures in the
nation. Camp Pendleton's environmental quality program is restoring the
adobe and plaster house and farm buildings to their 1905 appearance.
The restoration includes earthquake-proofing the structures as well as
stabilizing the walls, floors, and roof. Marine Corps policy allows the
environmental quality program to fund such activities because of the
National Historic Preservation Act's protection and preservation
requirements. In contrast, Air Force policy does not consider the
"maintenance and repair of National Register listed or eligible
buildings, structures or objects" as a valid use of environmental
quality program funds. Likewise, the Navy's and the Army's
environmental quality programs do not fund the repair, maintenance, or
rehabilitation of historic structures or properties, although the
Army's program will fund the preparation of plans for the repair,
maintenance, and rehabilitation of such structures.
* Oil and hazardous material spills. While all four services pay for
plans to prevent and/or respond to oil and hazardous material spills
and for spill cleanup equipment, only the Air Force's and Army's
environmental quality programs pay for the actual cleanup. While the
Navy and Marine Corps are liable under various federal and state laws
to fund spill cleanups, they would likely use other operating funds for
such cleanups. Typically, the organization that caused the spill would
be expected to fund the cleanup. In contrast, the Air Force's and
Army's environmental quality programs will pay for spill cleanups, but
headquarters officials from both services told us that they encourage
their environmental managers to seek reimbursement for spill cleanup
costs from the unit that caused the spill.
Some Activities Funded Through the Services' Environmental Quality
Programs Are More Closely Related to Military Operations or
Maintenance:
The services' broad interpretations of eligibility for their
environmental quality programs have allowed installations to use the
environmental quality program to fund activities that may have been
more closely related to military operations or maintenance.
For example, we noted the following:
* Bird/Aircraft Strike Hazard program. In fiscal year 2001, the Navy
spent about $147,000 of environmental quality program funds to support
an activity whose primary purpose is to ensure the safety of Navy
pilots and aircraft at Naval Air Station North Island and a landing
field at Imperial Beach. The purpose of this program is to reduce the
risk of damage or loss that can occur when birds or other animals are
hit by, or caught in, military aircraft during military operations. The
Navy justified this activity as part of its environmental quality
program because 1 of the 15 species of birds that pose a risk to
aircraft is a federally listed endangered species and another is a
threatened species. However, as clearly stated in the project
description, the primary purpose of the activity is to control wildlife
in order to protect aircraft. In contrast, other services require such
activities to be funded by the organizations responsible for flight
operations and not through the environmental quality programs.
* Wildfire suppression. The Navy has used environmental quality program
funds to pay for the use of a helicopter to suppress wildfires caused
by military operations, specifically by naval gunfire training on San
Clemente Island, a Navy-owned island off the coast of southern
California. Although Navy helicopters have the primary responsibility
to be on standby to provide firefighting support when training ranges
are in use, these helicopters are not always available. To meet its
fire suppression needs when its helicopters are not available, the Navy
has contracted with a private company for helicopter support. During
the last 4 years the Navy has spent an average of $150,000 per year in
environmental quality program funds to pay for this activity. The Navy
justifies the activity as an environmental expense because wildfires
could harm the 10 endangered species on the island. Nevertheless, the
fires are the direct result of the Navy's gunfire training activity,
and funds for addressing the negative consequences of its actions
normally come from the activity's sponsor. It is unclear why this
activity is treated differently from the case of hazardous spills
discussed previously, in which the Navy requires the organization that
caused the spill to pay for the cleanup.
* Roofs for drinking water reservoirs. The Marine Corps' environmental
quality program has replaced the roofs on six drinking water reservoirs
at Camp Pendleton, at an estimated total cost of $4.7 million.
According to officials from Camp Pendleton's comptroller's office, the
installation has a backlog of more than $190 million in facility
maintenance and repair needs. Because this maintenance and repair
activity had an environmental connection--the repairs were needed to
prevent animals from contaminating the base's water supply and to avoid
violating the Safe Drinking Water Act--installation officials decided
to fund this activity through the Marine Corps' environmental quality
program.
Several environmental officials acknowledged that characterizing
certain activities as environmental, or "painting them green," rather
than as facility maintenance, restoration, or modernization improves
the chance of their being funded. According to these officials,
installations may seek to fund maintenance and infrastructure projects
through the environmental quality program because of the overall
shortage of funds for facility maintenance, restoration, and
modernization. According to DOD officials, funding for facility
maintenance has been inadequate for many years, resulting in
deteriorated facilities at many installations.
The Air Force has tried to limit the use of environmental quality
program funds for maintenance and repair activities by establishing a
policy on funding infrastructure-related activities. The policy states
that environmental quality program funds can only be used to construct,
modify, or upgrade facilities or systems needed to comply with new
environmental laws and regulations. Such facilities or systems should
be maintained, repaired, or replaced using other funds. However, if a
regulator or major command determines that an installation is out of
compliance with an environmental requirement, an infrastructure project
may be eligible for environmental quality funding. The policy includes
a list of typical infrastructure projects, indicating whether they are
eligible for environmental quality program funding. In commenting on a
draft of the infrastructure policy, the Air Force Space Command raised
concerns about the policy's possible negative effect on installations'
ability to remain in compliance with environmental requirements.
According to a senior environmental official at the command, the Air
Force's infrastructure policy, although well intentioned, is
unrealistic because funding for repair and maintenance activities has
been insufficient for many years.
We have long noted DOD's need for improved facilities management,
and since 1997 we have identified DOD infrastructure management as a
high-risk area. Recently, we reported that the military services have
not made maintaining and improving their facilities a funding priority
because these needs must compete with other programs, such as force
readiness and the day-to-day costs of operating an
installation.[Footnote 11]
The Services Do Not Always Ensure That Funding Is Targeted to
the Highest Priority Environmental Activities, and in Some Cases, Have
Funded Activities That Are Ineligible Under Their Policies:
Certain low-priority activities were funded through the environmental
quality program at two Army installations we visited, even though some
high priorities, considered "must fund" activities by DOD and Army
policy, were not funded. Moreover, at two installations we visited, we
found that the environmental quality programs had funded some
activities that were ineligible to receive funding under their
policies.
For two Army installations we visited, the major command did not
provide environmental quality program funding for all "must funds,"
Class 0 and I activities, yet funded some lower-priority, Class III
activities.[Footnote 12] For example, the Fort Carson environmental
director told us that the percentage of funds received for validated
Class 0 and I activities dropped from about 90 percent in fiscal year
2000 to about 50 percent in fiscal year 2002. At the same time, the
command provided Fort Carson with $104,000 in environmental quality
program funds for three lower-priority, Class III activities in fiscal
year 2002. Similarly, at Fort Campbell, the funding rate for Class 0
and I activities averaged 70 percent of the amount required, according
to installation officials. For example, we determined that Fort
Campbell received about $16 million, or 77 percent of its high-priority
requirements (defined as Class 0 and I activities) in fiscal year 2001,
but at the same time the command provided $600,000 in environmental
quality program funds to Fort Campbell for five lower-priority, Class
III activities. Some examples of high-priority activities not funded at
these two installations, and the lower-priority activities that were
funded by the major command, include the following:
* In fiscal year 1999, U.S. Forces Command did not provide funding for
certain Class 0 and I activities at Fort Campbell such as hardware and
software upgrades to automate program management; drinking water
resource assessment and planning; and a firebreak redesign to control
soil erosion entering streams. However, during the same year, the
command provided funding for certain Class III activities at the
installation, such as noise monitoring, minimization of construction
debris by crushing for reuse as aggregate, and asbestos sampling and
analysis. Ultimately, Fort Campbell was able to fund two of the high-
priority activities in 1999, by using funds from other environmental
activities or from outside the environmental quality program.
* In fiscal years 1999 through 2002, U.S. Forces Command did not
provide environmental funds for certain Class 0 and I activities at
Fort Carson, such as removal of an underground storage tank from an
abandoned landfill; watershed management, including repair of erosion
control structures; and a survey of industrial sources and sanitary
facilities, such as oil/water separators and septic system. However,
during the same time period, the command provided funding for Class III
activities at Fort Carson, such as radon sampling; replacement of a
septic system on a training encampment with a connection to a sewage
system; and the purchase and planting of seeds to reintroduce native
plant species to re-vegetate burned and other environmentally disturbed
areas.
As illustrated by these examples, U.S. Forces Command has considered
factors other than those included in DOD's and the Army's policies on
prioritization when making funding decisions. Some considerations
that the command used included whether (1) failure to fund the activity
would result in an adverse impact on the installation's military
mission, (2) the activity could significantly reduce pollution, and
(3) the activity is expected to provide a significant return on
investment. These considerations resulted in the command's funding
activities that were lower priorities under DOD's and the Army's
classification systems, while not funding high priorities as defined by
these systems. According to the director of the Army's environmental
programs, the Installation Management Agency[Footnote 13] will not use
the major command's approach for making funding decisions. Instead, the
agency will always fund high-priority activities, as defined by DOD and
Army policy, before funding Class III activities.
Consistent with our findings at selected installations, the Army
Audit Agency has reported that some Army installations have not
funded all high-priority activities while at the same time funding
lower-priority activities. In December 1999, the agency reported that
of 234 environmental activities it reviewed at Army installations, the
installations did not fund 55 activities classified as high priorities,
while installations funded 13 other projects that were not classified
as high priorities.[Footnote 14] The Army Audit Agency recommended that
the Army reinforce the need to comply with its policy to fund high-
priority activities.
Moreover, some of the activities funded through the environmental
quality program at two of the installations we visited were prohibited
by service policy from receiving funds through this program.
Specifically, we found the following:
* Pest management. The environmental quality program at Fort Carson
funded pest management as a recurring, high-priority activity for a
number of years because base operating funds for this activity had not
been available, according to the installation's environmental quality
program manager. This official told us that pest management is eligible
for environmental quality program funding because chemicals are used to
perform the work. However, our review of the Army's program policy
indicates that application of chemical pesticides for pest control is
not eligible for environmental quality program funding, and officials
from the Army's Installation Management Agency agreed that this
activity should not have been funded using environmental quality
program funds.
* Landscaping for a hazardous waste storage facility. Fort Carson used
environmental quality program funds to pay for maintenance and repair,
including landscaping, of a hazardous waste storage facility located on
the installation. Fort Carson officials said that the landscaping was
included as part of a larger activity--maintaining the hazardous waste
storage facility--which is eligible for environmental funding.
According to the Fort Carson environmental director, the installation
has generally not had funds available from base operations accounts to
fund base support activities such as this. However, our review of Army
environmental policy indicates that environmental funding for routine
grounds maintenance "such as grass mowing, tree pruning, and
landscaping performed for the purpose of aesthetics" is specifically
excluded. Officials from the Army's Installation Management Agency
agreed that landscaping should not have been funded using environmental
quality program funds. Further, these officials as well as the director
of environmental programs for the Army said that the entire activity
should not have been funded using environmental quality program funds
because routine repair and maintenance activities are more
appropriately funded through the maintenance account.
* Restoration and maintenance of a historic structure. Vandenberg
Air Force Base has used environmental quality program funds to
refurbish its Space Launch Complex 10, which the National Park Service
had designated as "the best surviving example of a launch complex built
in the 1950s at the beginning of the American effort to explore space."
The National Park Service also listed the site as one of America's most
endangered historic landmarks. The Air Force's environmental quality
program spent $925,000 on this activity during fiscal years 2000
through 2002; the restoration is expected to take 8 years to complete,
at an estimated total cost of more than $2 million. However, as
previously mentioned, Air Force policy specifically prohibits the use
of environmental funds for the maintenance and repair of historic
landmarks.
A senior environmental official from Vandenberg Air Force Base's major
command, the Air Force Space Command, explained that it can be
difficult to obtain funding for repair and maintenance of historic
structures, particularly if they are vacant. Installations'
sustainment, restoration, and modernization programs typically assign a
lower funding priority to vacant historic structures than to structures
that have a direct impact on the installations' overall missions. Given
that no other funding source on base is likely to maintain and restore
historic properties, it often falls to the environmental quality
program to carry out these conservation responsibilities, according to
this official, despite their ineligibility under Air Force policy. The
official further noted that legal counsel for the command's
environmental office has advised the environmental quality program to
repair and maintain historic structures to avoid "demolition by
neglect" and to avoid violating the National Historic Preservation Act.
* Roof repair. In fiscal year 2001, Fort Carson used $12,000 of
environmental quality funds to repair a roof on a historic ranch house,
according to installation resource management officials. The ranch
house was being used by environmental quality program staff and
students performing environmental research, according to the
installation's environmental director. The funds used for the roof
replacement were taken from an approved activity to update and
implement the installation's integrated natural resources management
plan required under the Sikes Act.[Footnote 15] The description of the
activity as approved for funding does not mention roof repair.
According to the environmental director, the activity's narrative was a
"catch all" that could be used to fund anything related to
implementation of the natural resources plan, including repairing a
roof on a historic structure. Although the environmental director
acknowledged that this roof replacement could have been funded through
the installation's public works department, which is responsible for
maintaining and repairing installation structures, he also said that
the public works department did not have funding available for this
activity, while the environmental quality program did.
According to our review of Army policy, minor construction costs not
related to new or expanded legal environmental requirements are not
eligible for environmental funds. Army Installation Management Agency
officials agreed that environmental funds should not have been used to
fund this roof repair and said that they would not have funded this
activity had it been specifically mentioned in the funding request for
the natural resources plan. The environmental quality program could
fund certain repairs of historic structures to maintain compliance with
the National Historic Preservation Act, according to the officials.
The Services' Environmental Quality Programs Cannot Ensure That DOD's
Requirement to Fund All High-Priority Needs Is Met:
Although DOD's and the services' policies call for funding of all
high-priority environmental quality program activities, the services
have not always been able to fund all such activities through their
environmental quality program. While program managers for most of
the installations we visited said that the environmental quality
programs were generally able to fund high-priority environmental
activities during fiscal years 1999 through 2002, in some instances
installations were not able to fund all such activities. To address
such situations, installation officials deferred certain high-priority
activities, sought an extension of a compliance deadline, obtained
funding from other sources at the installation, or stretched their
allotment of environmental funding to pay for more activities than
planned.
According to some environmental managers at the installations where
high-priority activities were deferred, the activities they were most
likely to defer were those that do not have a firm timeline for
completion, such as surveys of cultural resources. Certain
requirements, such as those in the Sikes Act or the National Historic
Preservation Act that require installations to survey their natural or
cultural resources, do not provide for a penalty for missing a deadline
or do not specify when these activities must be undertaken.
Consequently, although not completing these activities means that the
installation is not in compliance with an environmental requirement,
there is little likelihood of a risk to human health or a risk of
receiving a notice of violation, fine, or penalty from a regulator.
Thus, noncompliance with these requirements presents, at least in some
cases, a lower risk to the installation than would noncompliance with
certain other environmental requirements. Nonetheless, DOD's
definition of must-fund, high-priority environmental activities
includes all activities needed to keep installations in compliance with
federal, state, or local laws and regulations, as well as executive
orders, even where there are no compliance deadlines or risk of a fine.
In cases in which installations deferred selected required activities,
it may have resulted in noncompliance with federal environmental laws.
Officials at other installations we visited also cited concerns about
the deferral of certain environmental activities, particularly those
that may not have a compliance deadline and are thus considered lower
priorities. For example, a senior environmental official at Vandenberg
Air Force Base described how the rapid spread of Argentinean pampas
grass, an invasive species, had resulted in the U.S. Fish and Wildlife
Service listing the grass as a major threat to four federally
endangered plant species on the installation and requiring that the Air
Force eradicate the grass--at a cost of approximately $1 million.
According to Vandenberg environmental officials, they had requested
environmental funding for the project when the grass was initially
found because they believed the cost to eradicate it at that time would
be minimal compared to the future expense if the grass were left
uncontrolled. However, the installation could not obtain environmental
quality funding for the project because it was a Class III activity and
Air Force policy prohibits funding of lower priorities. The project was
not funded until the U.S. Fish and Wildlife Service listed the grass as
a major threat to the endangered species.
Environmental program managers at most of the installations we
visited indicated that they have generally been able to fund emergency,
high-priority environmental activities that occurred outside the normal
budgeting cycle, but they have done so by using funds allocated for
other planned high-priority activities, emergency or year-end funding
from the environmental quality program, or other funding sources at the
installation or command. In some cases, certain planned activities
could be deferred because the regulatory deadlines slipped or the
regulators granted the installation an extension on meeting the
deadline. Some environmental managers also mentioned that in some
instances, planned activities come in under budget, which can result in
extra funds being available for other, unexpected needs. At the
installations we visited, environmental managers dealt with a variety
of unexpected needs for funding, including the following:
* A Texas regulatory agency required Fort Bliss to immediately
investigate and assess a fuel leak. To pay for this unbudgeted
activity, the chief of the installation's environmental compliance
division approved the reprogramming of some of the funding from 13
other high-priority environmental activities.
* Fort Campbell's environmental office acquired some Army Corps of
Engineers' property that had soil erosion problems. Because the land
was acquired during the middle of the fiscal year, the environmental
quality program had not budgeted funds to address the erosion. The
Corps agreed to provide funding for interim erosion control.
* Camp Pendleton faced an emergency when sewage began to flow out of
manholes on a training range near a wetland. The installation used base
operating funds for cleanup and to clear out the clogged main sewer
line. The Marine Corps' environmental quality program also provided
$500,000 in emergency funding to determine the cause of the problem
and, hoping to avoid other such occurrences, to assess the condition of
150 miles of the main sewer line.[Footnote 16]
Regarding future, high-priority activities, some of the services have
recently indicated that their environmental quality programs will have
difficulties funding all high-priority activities in fiscal year 2003
and even greater difficulties in fiscal year 2004. Specifically,
* In early 2003, in preparation of its presidential budget request for
fiscal year 2004, the Army reported that in each fiscal year 1998
through 2003, its environmental quality program funded or will fund
between 83 and 98 percent of validated high-priority activities.
However, the Army estimates that in fiscal 2004, the program will be
able to fund just 78 percent of its high-priority activities. Army
officials indicated that their environmental quality program will not
only face larger funding needs for high-priority activities in fiscal
year 2004, but also that the program's budget will be lower than the
previous 2 years because some of these funds will be needed for other
priorities, including the global war on terrorism and spare parts for
military equipment. To address this anticipated shortfall, the Army
expects its major commands and installations to provide funds from
other command or installation budget sources as needed to ensure that
the installations remain in compliance with environmental requirements.
However, the availability of such funds is uncertain given DOD's
ongoing challenges in containing the deterioration of its military
facilities as discussed earlier in this report.
* According to Air Force officials, funding for the environmental
quality program will be decreased in fiscal year 2004 because of
competing demands on overall Air Force resources. Air Force officials
also stated that this reduction will be absorbed by the major commands,
which are required to fully fund all must-fund activities, even if it
means migrating funds into the environmental quality program from other
operations and maintenance activities.
Conclusions:
DOD has established broad policy for its environmental compliance
program that does not specify which activities can be funded. As a
result, there is significant variation in how the services interpret
this policy and implement their own environmental quality programs.
This variation among the services' programs can result in different
eligibility requirements for environmental activities across services
and funding of activities that would be more appropriately funded from
other sources, such as military operations or base maintenance. Given
the services' broad and differing interpretations of eligibility for
environmental quality program funding, as well as their inclusion of
activities that are more closely related to military operations or
maintenance, DOD cannot be assured that the services' environmental
funding needs have been accurately identified, that its funds for
environmental quality are being targeted to its most critical
environmental requirements, or that its management of its environmental
responsibilities continues to improve. Although the services have, over
the past decade, made significant improvements in their environmental
compliance performance, these improvements have leveled off in recent
years, and DOD has not reached its goal of full environmental
compliance. Further, given that the services have not always been able
to fund all high-priority environmental quality activities and expect
this condition to worsen in fiscal year 2004, it is all the more
important that DOD target its environmental quality program funds
wisely.
Recommendations for Executive Action:
To ensure that DOD can better target environmental quality program
funds to the most important and most appropriate activities, we
recommend that the Secretary of Defense establish a more specific
policy on which activities should be eligible for funding through the
services' environmental quality programs and how such activities should
be prioritized and funded. We are also recommending that the military
services subsequently conform their policies and processes to the
revised DOD policy.
Agency Comments and Our Evaluation:
We provided DOD with a draft of this report for review and comment. DOD
provided technical clarifications, which we incorporated as
appropriate. However, DOD did not provide overall comments as of the
issuance date of this report.
We will send copies of this report to the Secretary of Defense; the
Director, Office of Management and Budget; appropriate congressional
committees; and other interested parties. We will also provide copies
to others upon request. In addition, the report will be available, at
no charge, on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions, please call me or Edward
Zadjura at (202) 512-3841. Contributors to this report are listed in
appendix II.
[End of section]
(Ms.) Anu K. Mittal
Acting Director,
Natural Resources and Environment:
Signed by Anu K. Mittal:
[End of section]
Appendix I: Scope and Methodology:
To assess DOD's and the military services' processes for identifying,
prioritizing, and funding their environmental quality activities, we
reviewed the policies and procedures established by DOD and the
services to guide implementation of the environmental quality program.
We also reviewed each service's system for identifying, prioritizing,
and funding their environmental quality activities, and compared this
information across the services to identify differences in the
programs.
To determine how environmental activities are identified and
prioritized by installations, we visited 11 active military
installations in the United States (listed below). Generally, we
selected at least two installations from each service. We selected
these installations primarily because of their large environmental
quality budgets and because they represent a diversity of major
commands, military missions, and geographic locations. Because the
Navy's environmental quality program is organized into regions,
we selected two Navy regional offices rather than two installations.
Within these two Navy regions, we visited a total of four installations
and reviewed environmental funding requests for an additional four
installations. Our observations about individual projects or activities
at these installations are not generalizable to projects or activities
at all military installations.
Military Installations GAO Visited:
U.S. Air Force Eglin Air Force Base, Florida Vandenberg Air Force Base,
California:
U.S. Army Fort Bliss, Texas Fort Campbell, Kentucky Fort Carson,
Colorado:
U.S. Navy Navy Mid-Atlantic Region: Naval Station Norfolk, Virginia;
Naval Weapons Station Yorktown, Virginia (Note: We also reviewed
environmental funding requests for Naval Air Station Oceana, Virginia,
and Naval Amphibious Base Little Creek, Virginia.):
Navy Region Southwest: Naval Air Station, North Island, California;
Naval Station Point Loma, California (Note: We also reviewed
environmental funding requests for Naval Station San Diego, California,
and Naval Auxiliary Landing Field San Clemente Island, California.):
U.S. Marine Corps Marine Corps Base Camp Lejeune, North Carolina Marine
Corps Base Camp Pendleton, California:
At each installation visited, we interviewed environmental quality
program officials to obtain information about their implementation of
the environmental quality program. We reviewed these installations'
lists of planned environmental projects for fiscal years 2002 through
2009 and funding data for activities covering fiscal years 1999 through
2002. We compared this information across the services to determine if
there were variations in the types of environmental activities being
funded. We also compared the installations' lists of environmental
activities to service policy to determine if inappropriate or
ineligible activities had been funded.
To determine the role of the major commands in identifying,
prioritizing, and funding environmental activities and to obtain the
commands' perspectives on the environmental quality program, we
discussed the environmental quality program with officials from the
major commands associated with the installations and regions we
visited: Army Forces Command (Fort Campbell and Fort Carson), Army
Training and Doctrine Command (Fort Bliss), Air Force Space Command
(Vandenberg Air Force Base), Air Force Materiel Command (Eglin Air
Force Base), the Navy's Atlantic Fleet (Navy Mid-Atlantic Region), and
the Navy's Pacific Fleet (Navy Region Southwest). The Marine Corps does
not have major commands that play the type of role in the environmental
quality program that the commands play in the other services. We also
discussed our findings with officials of the Army's new Installation
Management Agency, which will assume responsibility for funding
environmental quality programs at Army installations beginning in
fiscal year 2004.
We also met with officials from the Office of the Secretary of Defense
and each service headquarters to obtain information on their roles in
the environmental quality program and their perspectives on the
program, in particular, on how environmental activities are identified,
prioritized, and funded.
We conducted our review from May 2002 through May 2003 in accordance
with generally accepted governmental auditing standards.
[End of section]
Appendix II: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
(Ms.) Anu K. Mittal (202) 512-3841 Edward Zadjura (202) 512-9914:
Acknowledgments:
In addition to the individuals named above, Kelly Blado, Christine
Frye, Roderick Moore, Cynthia Norris, and Susan Swearingen made key
contributions to this report. Also contributing to this report were
Doreen Feldman, Anne Rhodes-Klein, and Amy Webbink.
FOOTNOTES
[1] The installations we visited include the Air Force's Eglin Air
Force Base and Vandenberg Air Force Base; the Army's Fort Bliss, Fort
Campbell, and Fort Carson; the Marine Corps' Camp Lejeune and Camp
Pendleton; and the Navy's Mid-Atlantic Region (Naval Station Norfolk
and Naval Weapons Station Yorktown) and Southwest Region (Naval Air
Station North Island and Naval Station Point Loma). At the two Navy
regions, we reviewed environmental funding requests for Naval Station
Norfolk, Naval Air Station Oceana, Naval Weapons Station Yorktown,
Naval Amphibious Base Little Creek, Naval Station San Diego, Naval Air
Station North Island, Naval Base Point Loma, and Naval Auxiliary
Landing Field San Clemente Island.
[2] Other requirements and policies apply to DOD's activities overseas
and to Navy ships at sea; these are outside the scope of this review.
[3] In addition to its environmental quality program, DOD has a program
focusing on the cleanup of contamination associated with past DOD
activities. This program, known as the Defense Environmental
Restoration Program, was established by section 211 of the Superfund
Amendments and Reauthorization Act of 1986. Under the environmental
restoration program, DOD is authorized to identify, investigate, and
clean up environmental contamination at active or closing military
installations, and on land that DOD formerly owned or leased. Funding
for environmental restoration activities is provided through Component
Environmental Restoration accounts; activities funded through these
accounts are outside the scope of our review.
[4] See Department of Defense Instruction (DODI) 4715.3, Environmental
Conservation Program, May 3, 1996; DODI 4715.4, Pollution Prevention,
June 18, 1996; and DODI 4715.6, Environmental Compliance, April 24,
1996.
[5] In recent years, DOD's operation and maintenance account has funded
about 77 percent of the environmental quality program. About 23 percent
of environmental program funding in recent years has been from other
DOD accounts, including the Defense Working Capital Funds, the
procurement accounts, and the military construction account.
[6] In fiscal year 2002, DOD replaced its real property maintenance
program, which had been funded through the operations and maintenance
appropriation, with two distinct activities and accounting structures:
(1) sustainment and (2) restoration and modernization. Sustainment
funds, which come primarily from the operations and maintenance
appropriation, cover expenses for all recurring maintenance costs and
contracts, as well as for major repairs of nonstructural components
(e.g., replacing a roof or repairing an air-conditioning system).
Restoration includes repair and replacement work to restore facilities
damaged by inadequate sustainment, excessive age, natural disaster,
fire, accident, or other causes. Modernization includes altering, or
modernizing, facilities to meet new or higher standards, accommodate
new functions, or replace structural components. Restoration and
modernization activities are funded through both the operations and
maintenance appropriation and the military construction appropriation.
For more information on these topics, see U.S. General Accounting
Office, Defense Infrastructure: Changes in Funding Priorities and
Strategic Planning Needed to Improve the Condition of Military
Facilities, GAO-03-274 (Washington, D.C.: Feb. 2003).
[7] In the Navy, these responsibilities are performed by regional
environmental offices rather than by offices associated with each
installation.
[8] The Air Force and Navy use the term "level" rather than "class"; in
this report, however, the term "class" will be used to describe all of
the services' priority levels.
[9] The Navy refers to its higher command level as a "claimant";
however, for the purposes of this report, the term major command will
be used. Beginning in fiscal year 2004, the Army's new Installation
Management Agency will serve as the next level for reviews of the
Army's environmental quality program.
[10] This process, which DOD calls its Planning, Programming, and
Budgeting System, or PPBS, takes about 2 years from planning to
execution. For more information on this process, see Congressional
Research Service, A Defense Budget Primer, Dec. 9, 1998.
[11] U.S. General Accounting Office, Defense Infrastructure: Changes in
Funding Priorities and Strategic Planning Needed to Improve the
Condition of Military Facilities, GAO-03-274 (Washington, D.C.: Feb.
2003).
[12] Class 0 consists of recurring activities (i.e., activities
typically funded each year) needed to keep an environmental program
running and meet compliance requirements, such as employee salaries and
office supplies. Class I consists of nonrecurring activities that are
needed to either maintain or restore compliance with an environmental
law, regulation, or other requirement. Class II activities have
compliance deadlines, but these deadlines will not occur until after
the budget year. In some cases, certain Class II activities are
considered "must fund" priorities if they must be initiated in the
current year in order to ensure that a future compliance deadline can
be met. Class III consists of activities that are not required by a
specific environmental requirement that an installation must comply
with, but are intended to improve the environment.
[13] In October 2002, the Army established the Installation Management
Agency to oversee all components of installation support, including
environmental programs. Previously, installation funding (including
environmental funding) was routed through the Army's major commands to
individual installations. In some cases, this resulted in some
installations receiving a fraction of their total budget because major
commands withheld funds and unexpected mission priorities arose. Under
the new agency structure, installation funding (including environmental
funding) will go directly from the agency to the installations. This
new funding system will go into effect in fiscal year 2004.
[14] U.S. Army Audit Agency, Execution of Environmental Projects,
December 1999.
[15] The Sikes Act addresses all aspects of natural resources
management on military installations. A 1997 amendment to the act
requires the services to prepare an integrated natural resources
management plan for each installation in the United States, except for
installations that have been determined to lack significant natural
resources.
[16] The assessment, using video technology that could detect tree
roots, cracks, and other potential problems, found that the sewer lines
had been clogged by cooking grease, tree roots, and other objects that
had been flushed down toilets, including t-shirts and diapers, in base
housing and interstate highway rest stops along Camp Pendleton's
property. Based on the results of the emergency assessment, Camp
Pendleton has requested $7.5 million in repairs, to be paid for through
the Marine Corps' sustainment, restoration, and modernization program
rather than the environmental program.
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