Defense Infrastructure
Additional Information Is Needed to Better Explain the Proposed 100,000-Acre Expansion of the Pinon Canyon Maneuver Site Gao ID: GAO-09-171 January 13, 2009In 2007, the Army announced that the Office of the Secretary of Defense (OSD) had approved its request to expand its Pinon Canyon Maneuver Site, Colorado, by acquiring up to an additional 418,577 acres. The National Defense Authorization Act for Fiscal Year 2008 required the Army to address 29 provisions related to the expansion in a report to Congress. In July 2008, the Army reported that, although it had revalidated the requirement for at least 418,577 additional acres at the maneuver site, in response to community, cost, and other concerns it now proposed to limit the acquisition of additional training land to 100,000 acres. The act also required GAO to review the Army's report and the justification for the proposed expansion. This report examines the extent to which the Army's report (1) addresses the provisions of the mandate and (2) explains the selection of the 100,000-acre site. GAO compared the mandate requirements with the responses in the Army's report, met with Army officials to discuss the expansion, and visited the Pinon Canyon Maneuver Site and Fort Carson.
While the Army's 2008 report on the Pinon Canyon Maneuver Site generally addresses the provisions of the National Defense Authorization Act for Fiscal Year 2008, the report is lacking certain information that would help clarify six of the Army's responses to the mandate. For example, the Army provided a list of all the training activities that occurred at Pinon Canyon from May 2007 to April 2008, but this information does not indicate how much of the training area was used, nor does it indicate whether any of these exercises were performed simultaneously. Therefore, the report is not clear regarding how much of the maneuver site was used for training in a given month or annually and whether the units could train simultaneously. It is also unclear how this information was used to support the required analysis of the maximum annual training load without the proposed expansion of the site. Without additional information on the mandated provisions, it is difficult for Congress and the public to fully understand six of the Army's responses to the mandated provisions. The Army's report does not fully explain the current selection of the 100,000-acre site. Following are examples of specific issues not addressed in the Army's report: (1) The Army reported that it has reduced the amount of land it intends to purchase from 418,577 to 100,000 acres but did not explain its basis for selecting fewer acres or the specific site. (2) The estimated cost per acre used for internal planning to acquire additional land at the maneuver site has increased since 2007 but the Army's report does not discuss this increase. (3) The Army completed the required analyses when requesting OSD's approval for the up to 418,577-acre expansion, but has not completed an analysis for the current 100,000-acre proposal that would help to understand, among other items, how much of the 100,000 acres would actually be used for training, what type of training can be conducted, and what are the estimated costs to maintain the 100,000 acres. Army officials said that these questions and others would be difficult to address without the analysis required by the National Environmental Policy Act of 1969. Although the Army issued the mandated report, Army officials stated that, to date, the Army has voluntarily declined to spend other appropriated funds to begin the National Environmental Policy Act process due to congressional concerns about the potential effects of the proposed expansion. The officials further stated that uncertainty over congressional support for the potential expansion made a delay in expending funds to start the National Environmental Policy Act process appear to be prudent. Without the benefit of the analyses and information on how the Army identified the 100,000 acres currently being proposed for acquisition, especially in light of the growth in the estimated price per acre, it is difficult for Congress and the public to evaluate the full benefits and costs associated with the proposed 100,000-acre expansion.
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Director: Team: Phone:GAO-09-171, Defense Infrastructure: Additional Information Is Needed to Better Explain the Proposed 100,000-Acre Expansion of the Pinon Canyon Maneuver Site
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
January 2009:
Defense Infrastructure:
Additional Information Is Needed to Better Explain the Proposed 100,000-
Acre Expansion of the Piņon Canyon Maneuver Site:
GAO-09-171:
GAO Highlights:
Highlights of GAO-09-171, a report to congressional committees.
Why GAO Did This Study:
In 2007, the Army announced that the Office of the Secretary of Defense
(OSD) had approved its request to expand its Piņon Canyon Maneuver
Site, Colorado, by acquiring up to an additional 418,577 acres. The
National Defense Authorization Act for Fiscal Year 2008 required the
Army to address 29 provisions related to the expansion in a report to
Congress. In July 2008, the Army reported that, although it had
revalidated the requirement for at least 418,577 additional acres at
the maneuver site, in response to community, cost, and other concerns
it now proposed to limit the acquisition of additional training land to
100,000 acres.
The act also required GAO to review the Army‘s report and the
justification for the proposed expansion. This report examines the
extent to which the Army‘s report (1) addresses the provisions of the
mandate and (2) explains the selection of the 100,000-acre site. GAO
compared the mandate requirements with the responses in the Army‘s
report, met with Army officials to discuss the expansion, and visited
the Piņon Canyon Maneuver Site and Fort Carson.
What GAO Found:
While the Army‘s 2008 report on the Piņon Canyon Maneuver Site
generally addresses the provisions of the National Defense
Authorization Act for Fiscal Year 2008, the report is lacking certain
information that would help clarify six of the Army‘s responses to the
mandate. For example, the Army provided a list of all the training
activities that occurred at Piņon Canyon from May 2007 to April 2008,
but this information does not indicate how much of the training area
was used, nor does it indicate whether any of these exercises were
performed simultaneously. Therefore, the report is not clear regarding
how much of the maneuver site was used for training in a given month or
annually and whether the units could train simultaneously. It is also
unclear how this information was used to support the required analysis
of the maximum annual training load without the proposed expansion of
the site. Without additional information on the mandated provisions, it
is difficult for Congress and the public to fully understand six of the
Army‘s responses to the mandated provisions.
The Army‘s report does not fully explain the current selection of the
100,000-acre site. Following are examples of specific issues not
addressed in the Army‘s report:
* The Army reported that it has reduced the amount of land it intends
to purchase from 418,577 to 100,000 acres but did not explain its basis
for selecting fewer acres or the specific site.
* The estimated cost per acre used for internal planning to acquire
additional land at the maneuver site has increased since 2007 but the
Army‘s report does not discuss this increase.
* The Army completed the required analyses when requesting OSD‘s
approval for the up to 418,577-acre expansion, but has not completed an
analysis for the current 100,000-acre proposal that would help to
understand, among other items, how much of the 100,000 acres would
actually be used for training, what type of training can be conducted,
and what are the estimated costs to maintain the 100,000 acres.
Army officials said that these questions and others would be difficult
to address without the analysis required by the National Environmental
Policy Act of 1969. Although the Army issued the mandated report, Army
officials stated that, to date, the Army has voluntarily declined to
spend other appropriated funds to begin the National Environmental
Policy Act process due to congressional concerns about the potential
effects of the proposed expansion. The officials further stated that
uncertainty over congressional support for the potential expansion made
a delay in expending funds to start the National Environmental Policy
Act process appear to be prudent. Without the benefit of the analyses
and information on how the Army identified the 100,000 acres currently
being proposed for acquisition, especially in light of the growth in
the estimated price per acre, it is difficult for Congress and the
public to evaluate the full benefits and costs associated with the
proposed 100,000-acre expansion.
What GAO Recommends:
GAO recommends that the Army provide Congress with additional
information explaining (1) six of the responses to the mandate and (2)
the rationale for selecting the 100,000 acres for the proposed
expansion. DOD partially agreed with the recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-171]. For more
information, contact Brian J. Lepore at (202) 512-4523 or
leporeb@gao.gov.
[End of section]
Letter:
Results in Brief:
Background:
The Army's Report Generally Addresses the Mandate, but Additional
Information Would Help to Better Understand Its Responses:
The Army's Report Does Not Fully Explain the Identification of 100,000-
Acre Site for the Proposed Expansion of the Piņon Canyon Maneuver Site:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Reporting Categories and Provisions of Section 2831 of the
National Defense Authorization Act for Fiscal Year 2008:
Appendix III: Comments from the Department of Defense:
Appendix IV: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Information That Would Help Clarify the Army's Response to Six
Provisions of the National Defense Authorization Act for Fiscal Year
2008:
Table 2: Reporting Categories and Provisions of the National Defense
Authorization Act for Fiscal Year 2008 and Whether the Provisions Were
Adequately Addressed in the Army's 2008 Report:
Abbreviations:
DOD: Department of Defense:
NEPA: National Environmental Policy Act:
OSD: Office of the Secretary of Defense:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
January 13, 2009:
Congressional Committees:
The Army has reported that its training land shortfall will reach 4.5
million acres by 2013 due to the combined effects from a variety of
initiatives, including the 2005 base realignment and closure
recommendations, Grow the Army initiative, and transformation and
modularity,[Footnote 1] which have increased training land requirements
at installations across the continental United States. In its 2004
Range and Training Land Strategy,[Footnote 2] the Army identified Fort
Carson, Colorado, specifically its nearby Piņon Canyon Maneuver Site
training area, as an installation where land acquisition could be a
possible solution to help address the training land shortfall. In
February 2007, the Army announced that the Office of the Secretary of
Defense (OSD) had approved its request to expand the current 235,300
acres of the Piņon Canyon Maneuver Site by acquiring up to an
additional 418,577 acres for training.
However, the proposed expansion has drawn criticism from some affected
landowners and interest groups and has raised the attention of some
members of Congress with respect to how any acquired land will be used.
For instance, the National Defense Authorization Act for Fiscal Year
2007[Footnote 3] contained a mandate that required the Army to provide
Congress details concerning current and future training requirements at
Fort Carson and Piņon Canyon Maneuver Site. In response, the Army
reported in December 2006 that transformation is the primary factor
causing the largest increase in the Army's training land requirements.
For instance, transformation to a modular force increases the acreage
required for training a single brigade combat team by nearly 144
percent, from around 66,000 acres before transformation to
approximately 161,000 acres after.
The Consolidated Appropriations Act, 2008, which was enacted on
December 26, 2007, stated that none of the funds appropriated or
otherwise made available in the act may be used for any action that is
related to or promotes the expansion of boundaries or the size of the
Piņon Canyon Maneuver Site.[Footnote 4] Army officials stated that they
redirected the focus of contract employees that had been working on
potential expansion efforts to instead support the Army's response to
section 2831(a) of the National Defense Authorization Act for Fiscal
Year 2008,[Footnote 5] which required the Army to address 29 provisions
pertaining to the potential expansion of Piņon Canyon in a report to
Congress. These provisions fall in three categories: (1) an analysis of
whether existing training facilities are sufficient to support training
needs, (2) a report of need for any proposed addition of training land
to support units stationed or planned to be stationed at Fort Carson,
and (3) an analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion. Army officials told us that for the purposes of
the preparation of this mandated report, they used operations and
maintenance funds that, in their view, were not subject to the above-
referenced prohibition. In its report responding to this mandate, the
Army reported in July 2008 that, although it had revalidated the
requirement for at least 418,577 additional acres at the maneuver site,
in response to community, cost, and other concerns it now proposed to
limit the acquisition of additional training land to 100,000 acres
south of the existing site. Further, the Consolidated Security,
Disaster Assistance, and Continuing Appropriations Act, 2009, which was
enacted in September 2008, stated that none of the funds appropriated
or otherwise made available in Division E, Title I of the act may be
used for any action that is related to or promotes the expansion of
boundaries or size of the Piņon Canyon Maneuver Site.[Footnote 6]
According to Army officials, these funding restrictions apply only to
Military Construction Appropriations and do not preclude the Army from
further studying the 100,000-acre site or starting the National
Environmental Policy Act (NEPA) of 1969 process using other
appropriations.[Footnote 7] However, the officials stated that, to
date, the Army has voluntarily declined to spend other appropriated
funds to begin the NEPA process due to congressional concerns.
The National Defense Authorization Act for Fiscal Year 2008[Footnote 8]
also required us to review the Army's 2008 report on the Piņon Canyon
Maneuver Site and the justification for the proposed expansion of the
Piņon Canyon Maneuver Site, and to submit a report to Congress
regarding the results of our review no later than 180 days from the
release of the Army's report. This report examines the (1) extent to
which the Army's report addresses the provisions of the mandate and
where additional information would help clarify the Army's responses,
and (2) extent to which the Army's report explains the current
identification of the 100,000-acre site for the potential expansion of
the Piņon Canyon Maneuver Site.
In conducting our review, we examined all 29 reporting provisions
contained in the National Defense Authorization Act for Fiscal Year
2008 and compared them with the responses provided in the Army's 2008
report on the Piņon Canyon Maneuver Site. We met with appropriate Army
officials to understand and document the reasons for the Army's
responses and to discuss how the proposed expansion would benefit
training at Fort Carson. We also visited Fort Carson and the Piņon
Canyon Maneuver Site to see firsthand existing training facilities and
ranges. We also obtained and reviewed key policies and guidance the
Army has developed for managing its training lands and ranges to
determine how they were used by the Army to justify the need for the
expansion at Piņon Canyon Maneuver Site.[Footnote 9] We conducted this
performance audit from August 2008 through January 2009, in accordance
with generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives. A detailed description of our scope and
methodology is included in appendix I of this report.
Results in Brief:
While the Army's 2008 report on Piņon Canyon Maneuver Site generally
addresses the provisions laid out in section 2831 of the National
Defense Authorization Act for Fiscal Year 2008 by providing responses
to each of the 29 provisions,[Footnote 10] the report is lacking
certain information that would help clarify the Army's responses about
whether existing training facilities are sufficient to support the
training needs and alternatives for enhancing economic development
opportunities for southeastern Colorado for 6 of the 29 mandated
provisions. For example, in one response about whether existing
training facilities are sufficient to support the training needs, the
Army provided a list of all the training activities that occurred at
Piņon Canyon Maneuver Site from May 2007 to April 2008, but this
information did not indicate how much of the training area was used,
nor did it indicate whether any of these exercises were performed
simultaneously. Therefore, the report is not clear about how much of
the Piņon Canyon Maneuver Site was used for training in a given month
or annually or whether the units could train simultaneously, and it is
unclear how this information was used to support the required analysis
of the maximum annual training load without the proposed expansion of
the maneuver site. In another response, the Army was required to
provide a training calendar showing all planned brigade combat teams
stationed or planned to be stationed at Fort Carson at home station.
The calendar depicts all the brigade combat teams that are planned to
be stationed at Fort Carson as assigned to Fort Carson, but shows at
least two of these brigade combat teams deployed. Since Army officials
told us that the proposed expansion is based on peacetime assumptions,
the Army report is not clear as to why the calendar depicts brigade
combat teams as being deployed, given that in peacetime the teams would
be less likely to be deployed. In a response to alternatives for
enhancing economic development opportunities for southeastern Colorado,
the Army reported that it eliminated from consideration the option to
station an active duty unit at Piņon Canyon Maneuver Site during its
Programmatic Environmental Impact Statement for Grow the Army and that
surrounding communities do not have the infrastructure required to
support the stationing of units. However, the Army's response does not
explain or describe the analysis used in the environmental impact
statement; therefore, it is unclear how the Army came to the conclusion
that stationing units at the Piņon Canyon Maneuver Site is unfeasible.
Without certain additional information on the mandated provisions, it
is difficult for Congress and the public to fully understand some of
the Army's responses in its report.
The Army's 2008 report on the Piņon Canyon Maneuver Site does not fully
explain the current identification of the 100,000-acre site for the
proposed expansion. Since OSD approved the expansion of the maneuver
site in 2007, both the acreage proposed for acquisition and price per
acre have changed, and several important questions about the 100,000-
acre site selected for acquisition have not been addressed. First, in
its 2008 report, the Army stated that it has reduced the amount of land
it intends to acquire, but did not provide a detailed explanation of
how it identified the smaller site. Second, the estimated cost used for
internal planning to acquire additional land at the Piņon Canyon
Maneuver Site has increased since February 2007, when OSD initially
approved the Army's request to expand the maneuver site. However, the
Army's report does not discuss this increase in the price per acre.
Third, several important questions about the 100,000 acres selected for
acquisition have not been fully explained. While the Army completed the
required analyses outlined in Army Regulation 350-19[Footnote 11] in
requesting OSD's approval for the acquisition of up to 418,577 acres to
expand the Piņon Canyon Maneuver Site, the request was justified on the
estimated costs and benefits of the full 418,577-acre proposal and not
on a smaller acquisition. However, the Army has not fully explained (1)
how much of the 100,000 acres would actually be used for training, (2)
what benefits would be gained from adding the 100,000 acres to the
existing Piņon Canyon Maneuver Site, (3) what effect sustainment and
maintenance activities would have on training on the 100,000 acres, and
(4) what the future costs would be for sustaining and maintaining the
100,000 acres. Army officials said that these questions and others
would be difficult to address without the analysis required by NEPA. As
previously noted, the Consolidated Appropriations Act, 2008,[Footnote
12] prohibited the use of funds appropriated or otherwise made
available for any action that is related to or promotes the expansion
of the Piņon Canyon Maneuver Site, and the Consolidated Security,
Disaster Assistance, and Continuing Appropriations Act, 2009,[Footnote
13] prohibited the use of funds appropriated or otherwise made
available in Division E, Title 1 of the act for any action that is
related to or promotes the expansion of the Piņon Canyon Maneuver Site.
Army officials said these funding restrictions apply only to Military
Construction Appropriations and do not preclude the Army from further
studying the 100,000-acre site or starting the NEPA process using other
appropriated funds. The officials also stated that, to date, the Army
has voluntarily declined to spend other appropriated funds to begin the
NEPA process due to congressional concerns. The officials further
stated that uncertainty over congressional support for the potential
expansion made a delay in expending funds to start the NEPA process
appear to be prudent. Further, Army officials explained that the Army
would not begin the NEPA analysis for the potential expansion without
consulting with congressional stakeholders and having a reasonable
expectation that military construction funds would be available for the
potential acquisition. Without knowing how the Army identified the
100,000 acres currently being proposed for acquisition and several
other questions about benefits and costs of the proposed expansion, it
is difficult for Congress and the public to evaluate the full benefits
and costs associated with the proposed 100,000-acre expansion.
We are recommending that the Army provide Congress and the public with
additional information further explaining (1) the six responses about
whether existing training facilities are sufficient to support the
training needs and about alternatives for enhancing economic
development opportunities for southeastern Colorado, and (2) the
reasons the Army selected the current 100,000-acre site for the
proposed expansion and the growth in the estimated price per acre, as
well as more detailed information on how much of the 100,000 acres
would actually be used for training, what benefits would be gained from
adding the 100,000 acres to the existing maneuver site, what effect
sustainment and maintenance activities would have on training on the
100,000 acres, and what the future costs would be for sustaining and
maintaining the 100,000 acres. In written comments on a draft of this
report, the Army partially agreed with our recommendations, but did not
specify what actions, if any, it would take to implement them. In
addition, the Army raised a variety of concerns including our
characterization of its report and our initial inclusion of cost
estimates used for internal planning purposes. While we recognize that
the Army had certain concerns about our report, we continue to believe
the opportunity exists to improve its responses to Congress, hence the
need for our recommendations. We discuss the Army's comments in detail
later in this report.
Background:
The Army, in its initial Range and Training Land Strategy, identified
Fort Carson--specifically its Piņon Canyon Maneuver Site--as one
installation where potential land acquisition would be a feasible
solution to addressing overall training land shortfalls.[Footnote 14]
Fort Carson is located south of Colorado Springs, Colorado, and has
command over and administrative responsibility for the existing Piņon
Canyon Maneuver Site, a maneuver training facility located 150 miles
away in the southeastern area of the state. The maneuver site consists
of 235,000 acres, 95 percent (224,000 acres) of which is available for
maneuver training for soldiers stationed at Fort Carson and other
installations.
Proposed Expansion of the Piņon Canyon Maneuver Site:
In March 2005, the Army completed a Land Use Requirements Study that
examined the availability of training areas within Piņon Canyon
Maneuver Site and concluded that a shortfall of approximately 418,500
acres existed that needed to be addressed in order to meet training
requirements. The Army concluded that it needed additional land as the
result of the 2005 base realignment and closure, Grow the Army, and
transformation and modularity initiatives, which would increase the
number of brigade combat teams permanently stationed at Fort Carson
from one to five. Also, the number of soldiers is now expected to grow
from 14,500 to 28,500 by 2011 as the result of these initiatives.
In July 2006, the Army developed a land acquisition proposal in order
to secure approval from OSD to pursue an expansion of up to 418,577
acres at Piņon Canyon Maneuver Site. The proposed expansion area at
that time consisted of 100,000 acres of contiguous land directly south
of the existing Piņon Canyon Maneuver Site and 318,577 acres located to
the west of the site. Prior to OSD approval, information regarding the
expansion was unofficially disclosed to the press. This information,
including a map of the proposed expansion area, did not provide a
clear, complete, or accurate explanation of the Army's need for and
approach to acquiring additional land or of the Army's plans to also
use other strategies to meet critical training needs, and thus caused
concern regarding the Army's acquisition plans among some affected
landowners and interest groups.
Congressional Reporting Requirements and Direction:
The proposed expansions also raised the attention of Congress, which
sought more detailed information from the Army regarding any expansion
of the Piņon Canyon Maneuver Site. In response to section 2827 of the
National Defense Authorization Act for Fiscal Year 2007,[Footnote 15]
the Army provided a report to Congress that addressed questions related
to training requirements at Piņon Canyon Maneuver Site,[Footnote 16]
such as a description of the current and projected military
requirements, an analysis of the reasons for changes in training
requirements, and a proposed plan for addressing shortfalls in training
requirements. In February 2007, OSD approved the Army's request to
expand the Piņon Canyon Maneuver Site. However, the Consolidated
Appropriations Act, 2008, which was enacted in December 2007, stated
that none of the funds appropriated or otherwise made available in the
act may be used on any action that is related to or promotes the
expansion of the boundaries or size of the Piņon Canyon Maneuver Site.
[Footnote 17] Army officials stated that as a result, they redirected
the focus of contract employees that had been working on potential
expansion efforts to instead support the Army's response to section
2831 of the National Defense Authorization Act for Fiscal Year
2008,[Footnote 18] which required the Army to provide Congress with a
report regarding its plans for expansion at the Piņon Canyon Maneuver
Site within 6 months of the law's passage. Specifically, section 2831
of the act requires that the Army's report provide responses to 29
provisions that are categorized under three broad reporting categories:
(1) an analysis of whether existing training facilities are sufficient
to support training needs, (2) a report of need for any proposed
addition of training land to support units stationed or planned to be
stationed at Fort Carson, and (3) an analysis of alternatives for
economic development opportunities in southeastern Colorado at the site
or through any proposed expansion. Army officials told us that for the
purposes of preparing the report required by section 2831 of the
National Defense Authorization Act for Fiscal Year 2008, they used
operations and maintenance funds that, in their view, were not subject
to the above-referenced prohibition on the use of funds for any action
related to or promoting the expansion of the boundaries or size of the
Piņon Canyon Maneuver Site. The Army provided its report to Congress in
July 2008. Further, the Consolidated Security, Disaster Assistance, and
Continuing Appropriations Act,[Footnote 19] which was enacted in
September 2008, stated that none of the funds appropriated or otherwise
made available in Division E, Title I of the act may be used on any
action that is related to or promotes the expansion of the boundaries
or size of the Piņon Canyon Maneuver Site. According to Army officials,
these funding restrictions apply only to Military Construction
Appropriations and do not preclude the Army from further studying the
100,000-acre site or starting the NEPA process using other
appropriations. However, the officials stated that, to date, the Army
has voluntarily declined to begin the NEPA process due to congressional
concerns. The officials further stated that uncertainty over
congressional support for the potential expansion made a delay in
expending funds to start the NEPA process appear to be prudent.
Army's Guidance and Approach to Acquiring Land:
Army officials stated they address training land shortfalls through
four major strategies that include (1) focused land management; (2)
acquisition of buffers to mitigate encroachment; (3) utilization of
other federal lands; and (4) when necessary, land acquisition. In order
to proceed with a major land acquisition--defined as those exceeding
1,000 acres or costing more than $1 million--the Army is required to
seek approval from OSD because on September 13, 1990, OSD issued a
Department of Defense (DOD) wide moratorium on major land acquisitions.
The Secretary of Defense later revised and updated DOD's land
acquisition moratorium policy in October 1990, December 1994, November
2002, and July 2005. Waivers to this moratorium may be granted by the
Secretary or Office of the Secretary of Defense on a case-by-case basis
if a military service can justify to OSD a need to acquire more land.
When justifying a land acquisition in order to obtain OSD waiver
approval, such as the justification that was prepared in order to
obtain the waiver approval to pursue the potential land acquisition at
the Piņon Canyon Maneuver Site, Army officials follow a process and
methodology used to determine the amount of land needed to fulfill
training requirements. This multistep process entails three key steps-
-a doctrinal analysis,[Footnote 20] operational analysis, and
sustainability analysis.
* Doctrinal analysis. Army officials use the Army Range Requirements
Model to determine the doctrinal training requirement--the total amount
of land needed to completely meet doctrinal standards. The model
calculates how much land is needed to train a unit for a specific task
and how much land is needed based on Army doctrine and data from
several administrative and operational data systems. The training land
requirements calculated by the model are simply a baseline of what the
Army needs and are not the final results. For example, the model does
not account for certain factors that impact training, such as the
condition of training land assets, past usage of training land and
ranges, environmental restrictions, protection of cultural resources,
and encroachment pressures. The operational and sustainability analyses
adjust the model's calculations to account for those factors that the
model itself does not consider.
* Operational analysis. Army officials complete an operational analysis
that compares the doctrinal requirement with current range and training
land assets, the rate of use of these assets, and the condition of the
training land and ranges to determine which facilities are suitable and
not suitable for training. They adjust the range requirements model's
calculation based on the result of this analysis.
* Sustainability analysis. Army officials undertake a sustainability
analysis to account for factors, such as the use of training land by
other military services, environmental restrictions, and encroachment
pressures that make training land unusable. The results of the
sustainability analysis show the optimum amount of land the Army would
need to mitigate the impact of maneuver training damage. When possible,
the Army prefers to use land on a rotational basis to allow it to
recover from training, because increasing the concentration of training
exercises in a limited area of land can result in less time for
recovery and, consequently, additional repair and sustainment projects
that require funding. Army officials adjust the results of the
operational analysis based on the result of this sustainability
analysis.
After these analyses, if the proposed land acquisition project exceeds
$1 million or is greater than 1,000 acres, the Army installation
prepares and coordinates a major land acquisition proposal in order to
request a waiver to the department's moratorium on major land
acquisitions and submits the proposal to Army headquarters for review,
coordination, and approval. If the request is approved, Army
headquarters then submits the major land acquisition proposal to OSD
for approval to proceed with the land acquisition. The proposal
includes, where applicable, information from the range complex master
plan, the range development plan, and analysis of alternatives study
together with the purpose of the acquisition, estimate of cost,
assessment of the potential environmental impacts, and consideration of
alternatives. If the waiver request is denied by OSD, the process ends.
If OSD approves the waiver request, the Army then must address the
requirements of NEPA and the associated regulations established by the
Council on Environmental Quality, which require, in part, that all
federal agencies, including the Army, to evaluate the likely
environmental effects of projects they are proposing using an
environmental assessment or, if the project constitutes a major federal
action significantly affecting the quality of the human environment, a
more detailed environmental impact statement. If an environmental
impact statement is required for a particular acquisition, it must
include a purpose and need statement, a description of all reasonable
project alternatives and their associated environmental impacts
(including a "no action" alternative), a description of the environment
of the area to be affected or created by the alternatives being
considered, and an analysis of the environmental impacts of the
proposed action and each alternative.[Footnote 21] Until an agency
issues a final environmental impact statement and record of decision,
an agency generally may not take any action concerning the proposal
which would either have an adverse environmental impact or limit the
choice of reasonable alternatives. If the decision in the record of
decision is to acquire the land, OSD then requests congressional
approval to acquire the land. If Congress approves OSD's request,
Congress authorizes the land acquisition and appropriates the necessary
funds.
We more fully describe the Army's approach for acquiring additional
training land, including the information in the Army Range Requirements
Model, in a separate January 13, 2009, report.[Footnote 22]
The Army's Report Generally Addresses the Mandate, but Additional
Information Would Help to Better Understand Its Responses:
The Army's 2008 report on the Piņon Canyon Maneuver Site generally
addresses section 2831 of the National Defense Authorization Act for
Fiscal Year 2008 by responding to each of the mandate's 29 provisions.
For example, the report described additional training activities that
could be conducted if the site was expanded and adequately addressed 23
of the mandated provisions. However, we found that the responses to six
of the provisions--on whether existing training facilities are
sufficient to support the training needs and alternatives for enhancing
economic development opportunities for southeastern Colorado--were not
clear and lacked information that would help provide the reader a
better understanding (see table 1).
Table 1: Information That Would Help Clarify the Army's Response to Six
Provisions of the National Defense Authorization Act for Fiscal Year
2008:
Provision: Section 2831(a)(2)(A)(iii)(I): An analysis of whether
existing training facilities at Fort Carson, Colorado, and the site are
sufficient to support the training needs of units stationed or planned
to be stationed at Fort Carson, including a description of the current
training calendar and training load at the site, including the number
of brigade-sized and battalion-sized military exercises held at the
site since its establishment;
Information that would help clarify the response: The Army reported the
number of military brigade-sized and battalion-sized exercises held at
Piņon Canyon Maneuver Site from October 2004 to April 2008, even though
the provision requires that the Army list the number of exercises since
the establishment of the site. Although the Army noted that the system
it uses to capture training exercises began tracking training events in
2004, it does not mention how or whether such exercises were tracked
prior to 2004. However, in its 2007 report on Piņon Canyon Maneuver
Site, the Army indicated that it has been using the area to conduct
training exercises since 1985 but Army officials said that the
requested data did not existed for the early years. Still, additional
information would help the reader better understand why the Army did
not provide the number of training events since the establishment of
the Piņon Canyon Maneuver Site.
Provision: Section 2831(a)(2)(A)(iii)(II): An analysis of whether
existing training facilities at Fort Carson, Colorado, and the site are
sufficient to support the training needs of units stationed or planned
to be stationed at Fort Carson, including a description of the current
training calendar and training load at the site, including an analysis
of the maximum annual training load at the site, without expanding the
site;
Information that would help clarify the response: The Army reported the
annual training load at Piņon Canyon Maneuver Site from May 2007 to
April 2008. However, this information does not indicate how much of the
maneuver site was used, nor does it indicate whether any of these
exercises were performed simultaneously. Such information would help
the reader understand how much of the maneuver site is used for
training during a given month or annually. Also, an explanation as to
how this information was used to support the required analysis of the
maximum annual training load without the proposed expansion would help
the reader better understand how the Army developed its response to
this provision. The Army reported that adjustments to training events,
referred to as "workarounds," would be necessary to fully meet training
requirements without the expansion of the Piņon Canyon Maneuver Site
and that workarounds would have a negative impact on training. However,
the Army does not describe the nature of these workarounds or how they
would impact the training load. Such information would help the reader
better understand the type and amount of workarounds necessary to fully
meet training requirements at the existing Piņon Canyon Maneuver Site
and the potential benefits of an expansion that would obviate the need
for such workarounds. The Army reported that increased usage of current
training land would result in higher operational costs and greater
environmental damage to the land, but does not provide specific
information regarding operational costs or the specific effects of
increased usage of training land to support this observation. This
information would help the reader clearly understand the type and
amount of costs involved with not expanding the Piņon Canyon Maneuver
Site.
Provision: Section 2831(a)(2)(A)(iii)(III): An analysis of whether
existing training facilities at Fort Carson, Colorado, and the site are
sufficient to support the training needs of units stationed or planned
to be stationed at Fort Carson, including a description of the current
training calendar and training load at the site, including an analysis
of the training load and projected training calendar at the site when
all brigades stationed or planned to be stationed at Fort Carson are at
home station;
Information that would help clarify the response: The Army provided a
training calendar in appendix E of the report that lists all brigade
combat teams stationed and planned to be stationed at Fort Carson, but
the calendar shows that at least two of the brigade combat teams are to
be deployed in support of Operation Iraqi Freedom (Global War on
Terrorism). Since Army officials told us that acquisition plans are
made using peacetime assumptions, it is unclear why the Army chose to
use a training calendar in which not all the brigade combat teams are
physically present at home station. Additional information explaining
the training calendar would help the reader to better understand why
the Army chose to show its brigade combat teams deployed when the
acquisition is based on peacetime assumptions. Additional information
would also help the reader to better understand how deployment affects
training at the Piņon Canyon Maneuver Site. The Army reported that,
while there is currently a training land shortfall at Fort Carson and
the Piņon Canyon Maneuver Site, units are able to effectively train
using minor workarounds. With the increase in population at Fort
Carson, the Army reported that, without an expansion, the shortfall
would result in major training workarounds and less than optimal
training. It also reported that units would not be able to meet their
training requirements. However, the Army does not include a description
of the nature of these workarounds, the difference between minor and
major workarounds, or the training requirements that would not be met.
Such information would help the reader better understand the type and
amount of workarounds necessary to fully meet training requirements at
the existing Piņon Canyon Maneuver Site and the potential benefits of
an expansion.
Provision: Section 2831(a)(2)(C)(iii): An analysis of alternatives for
enhancing economic development opportunities in southeastern Colorado
at the current site or through any proposed expansion, including
consideration of the procurement of additional services and goods,
including biofuels and beef, from local businesses;
Information that would help clarify the response: The Army's response
discusses measures it would take to assist the local economy, such as
encouraging units to purchase goods in support of future training
events from local merchants near the Piņon Canyon Maneuver Site and
hosting contract training events for local small businesses. While the
Army's response discusses the procurement of additional services and
goods from local businesses (which presumably would be applicable to
the procurement of biofuels and beef), the report does not include a
specific discussion of procuring biofuels and beef from local
businesses. It is unclear why the Army did not directly address
biofuels or beef specifically. Clarification as to why this information
was not included would help the reader better understand how the Army
developed its response to this provision.
Provision: Section 2831(a)(2)(C)(viii): An analysis of alternatives for
enhancing economic development opportunities in southeastern Colorado
at the current site or through any proposed expansion including
consideration of additional investments in Army missions and personnel,
such as stationing an active duty unit at the site;
Information that would help clarify the response: The Army reported
that it is not consider stationing an active duty unit at Piņon Canyon
Maneuver Site because such an option was eliminated during its
Programmatic Environmental Impact Statement for Grow the Army[A] and
that surrounding communities do not have the infrastructure required to
support the stationing of units. However, by not explaining or
describing the analysis used in the environmental impact statement, it
is unclear how the Army came to the conclusion that stationing units at
the Piņon Canyon Maneuver Site is unfeasible.
Provision: Section 2831(a)(2)(C)(viii)(I): An analysis of alternatives
for enhancing economic development opportunities in southeastern
Colorado at the current site or through any proposed expansion,
including consideration of additional investments in Army missions and
personnel, such as stationing an active duty unit at the site,
including an analysis of anticipated operational benefits;
Information that would help clarify the response: The Army's
explanation regarding the anticipated operational benefits of
stationing an active duty unit at Piņon Canyon Maneuver Site lacks
specifics. For instance, the Army reported that operational benefits
resulting from the stationing of units at Piņon Canon Maneuver Site are
limited because the site lacks the infrastructure required to support a
unit, but it does not explain the types of infrastructure that are
needed. In addition, the Army's response does not include information
on the costs associated with the necessary infrastructure, nor does it
include information on the types of operational benefits this
infrastructure would provide. As such, it is unclear as to what type of
operational benefits would arise if the necessary infrastructure was in
place. Providing such information would make it easier for the reader
to understand how the Army determined that there would be little or no
operational benefit to stationing a unit at Piņon Canyon Maneuver Site.
Source: GAO analysis of the National Defense Authorization Act for
Fiscal Year 2008 and the Army's 2008 report on the Piņon Canyon
Maneuver Site.
[A] Department of the Army, Final Programmatic Environmental Impact
Statement for Army Growth and Force Structure Realignment (Washington,
D.C.: Oct. 26, 2007).
[End of table]
Army officials said that the 2008 report was reviewed at several
different management levels within the Department of the Army and was
intentionally written in a manner that would be easily understood by
the public after receiving criticisms concerning the technical nature
of the previous report on the Piņon Canyon Maneuver Site in response to
the National Defense Authorization Act for Fiscal Year 2007. As a
result, some information and technical data were revised or deleted
during this review and approval process. Nonetheless, without
additional information on these provisions, it is difficult for
Congress and the public to fully understand the Army's responses to
these provisions.
The Army's Report Does Not Fully Explain the Identification of 100,000-
Acre Site for the Proposed Expansion of the Piņon Canyon Maneuver Site:
The Army's 2008 report on the Piņon Canyon Maneuver Site does not fully
explain the current identification of the 100,000-acre site for the
proposed expansion. Since OSD approved the Army's pursuit of the
expansion of the maneuver site in 2007, both the acreage proposed for
acquisition and the price per acre used for planning purposes have
changed, and several important questions about benefits and costs of
the 100,000-acre site selected for acquisition have not yet been fully
explained. Army officials said that these questions would be addressed
during the analysis required by the NEPA process. However, Army
officials stated that the Army would not begin the NEPA process for the
potential expansion without consulting with congressional stakeholders
and having a reasonable expectation that military construction funds
would be available for the potential acquisition.
The Army's Report Does Not Fully Explain the Identification of the
Smaller Site:
The Army based its original request to expand Piņon Canyon Maneuver
Site by 418,577 acres on doctrinal requirements, but in its 2008 report
reduced this amount to 100,000 acres because of budgetary constraints,
concerns about potential historic and culturally sensitive areas, and
the fewer number of landowners with which to deal compared with the
larger number of landowners on the original 418,577 acres. However, the
Army did not provide further details on how it selected the fewer acres
or the specific 100,000-acre site south of the current maneuver site.
The Army reported that, although it had revalidated the requirement for
up to 418,577 additional acres at Piņon Canyon, the 100,000-acre
expansion would be used to develop a training complex capable of
supporting maneuver and live fire for a combined arms battalion and
would provide sufficient space to allow a heavy brigade combat team and
an infantry brigade combat team to conduct simultaneous combat training
exercises.
The Army's Report Does Not Discuss the Growth in the Price per Acre:
While the estimated cost to acquire additional land at the Piņon Canyon
Maneuver Site has increased, the Army's report does not disclose this
increase. For example, the report did not disclose that the estimated
cost per acre used for internal planning purposes has increased from
about $280 per acre since February 2007, when OSD initially approved
the Army's request to expand the maneuver site by 418,577 acres. At
that time, the estimated cost for the acquisition included the costs of
the land, improvements, relocation assistance, and administrative costs
and the goal was to complete the land acquisition within 5 years.
More recently, the Army's fiscal years 2010-2015 planning budget shows
that it is budgeting $52.6 million ($17.6 million in fiscal year 2010,
$20 million in fiscal year 2011, and $15 million in fiscal year 2012)
in military construction funds to expand the Piņon Canyon Maneuver
Site. According to an Army official, the increased cost estimate partly
reflects the idea that buying only from willing sellers and refraining
from using eminent domain could increase the per acre cost average.
Also, the Army shortened the acquisition schedule from 5 to 3 years in
an attempt to accommodate the concerns of expansion opponents who
asserted that the uncertainties over expansion have caused economic
hardship for some nearby landowners in terms of making investment
decisions on their land. According to the Army, opponents have stated
that local banks are less willing to lend money to nearby landowners
for their agribusinesses whose future operations are in question. So to
reduce the length of uncertainty, and create more clarity, the Army
shortened the acquisition schedule.
If the Army moves forward to acquire the land, Army officials said that
they are uncertain whether acquisition costs may increase or decrease
because of changes in economic and other conditions that are likely to
occur between now and when the potential acquisition would be
finalized. The process to complete the required NEPA process, to
request and obtain congressional approval to acquire the land, and to
actually purchase the land from willing sellers is expected to take
several years--the NEPA process alone is expected to take at least 16
to 24 months. During this period, for example, cattle prices or local
rainfall could increase or decrease, which would potentially change the
selling price of the land.
Several Important Questions about the 100,000-Acre Site Have Not Been
Fully Addressed:
Neither the original justification used to obtain OSD's waiver nor the
2007 report on the Piņon Canyon Maneuver Site provides any specific
information regarding the potential expansion of the maneuver site by
100,000 acres. In requesting OSD's approval for the acquisition of up
to 418,577 acres to expand the Piņon Canyon Maneuver Site, the request
was justified on the estimated costs and benefits of the full 418,577-
acre proposal and not on a smaller acquisition. While the Army
completed the analyses required by Army Regulation 350-19[Footnote 23]
in order to obtain OSD waiver approval to pursue the potential
acquisition up to 418,577 acres, the Army has not fully explained its
rationale for the potential acquisition of the smaller site currently
being proposed for acquisition.
According to Army Regulation 350-19, a military land acquisition
proposal is a series of questions intended to provide senior leadership
with the essential information to make a decision about a major land
acquisition. Specifically, Appendix B of the regulation states that a
land acquisition proposal should include the future use of the land,
potential benefits, funding, training, readiness, anticipated
environmental impacts, etc. The Army completed the analyses required in
order to obtain OSD approval to pursue the potential acquisition of up
to 418,577 acres. However, the Army has not fully explained the
rational behind the identification of the 100,000-acre site, such as
(1) how much of the 100,000 acres would actually be used for training,
(2) what benefits would be gained from adding the 100,000 acres to the
Piņon Canyon Maneuver Site, (3) what effect sustainment and maintenance
activities would have on training on the 100,000 acres, and (4) what
the future costs would be for sustaining and maintaining the 100,000
acres. For example, Fort Carson officials said that they did not know
but were concerned about the condition of the land and whether the Army
could quickly start using the land or would need to reseed the land
before training on it.
Analyses Required by the NEPA Process May Address Many Questions:
Army officials said that these questions regarding the 100,000-acre
expansion, including the amount usable for training, potential
benefits, the effects of sustainment and maintenance activities on
training, and the cost of sustainment and maintenance activities would
be difficult to address without the analysis required by the NEPA
process. For example, NEPA and the associated regulations established
by the Council on Environmental Quality, which require, in part, that
all federal agencies, including the Army, evaluate the likely
environmental effects of projects they are proposing using an
environmental assessment or, if the project constitutes a major federal
action significantly affecting the quality of the human environment, a
more detailed environmental impact statement. An environmental impact
statement must include a purpose and need statement, a description of
all reasonable project alternatives and their associated environmental
impacts (including a "no action" alternative), a description of the
environment of the area to be affected or created by the alternatives
being considered, and an analysis of the environmental impacts of the
proposed action and each alternative.[Footnote 24]
Army officials noted that the NEPA process would help to more clearly
explain and justify the proposed expansion by identifying overall
sustainment and maintenance costs as well as environmental and
historical restrictions on the 100,000 acres, which would provide a
more accurate picture of how much of the 100,000 acres could be used
for training, the type of training that could happen, and how quickly
the land could be used for training. As previously noted, none of the
funds appropriated or otherwise made available in the Consolidated
Appropriations Act, 2008, or in Division E, Title I of the Consolidated
Security, Disaster Assistance, and Continuing Appropriations Act, 2009,
may be used for any action that is related to or promotes the expansion
of the Piņon Canyon Maneuver Site. Army officials stated that these
funding restrictions apply only to Military Construction Appropriations
and do not preclude the Army from further studying the 100,000-acre
site or starting the NEPA process. However, the officials stated that,
to date, the Army has voluntarily declined to spend other appropriated
funds to begin the process due to congressional concerns putting the
potential acquisition process (including any type of NEPA analysis) on
pause. Further, Army officials explained that because military
construction funds are used for land acquisitions, the Army would not
begin the NEPA analysis for the potential expansion without consulting
with congressional stakeholders and having a reasonable expectation
that military construction funds would be available for the potential
acquisition.
Conclusions:
While the Army's 2008 report on the Piņon Canyon Maneuver Site
generally addresses the provisions outlined in section 2831 of the
National Defense Authorization for Fiscal Year 2008, more information
is needed to better understand the Army's responses to six provisions
on whether existing training facilities are sufficient to support the
training needs and alternatives for enhancing economic development
opportunities for southeastern Colorado. Without additional information
on the mandated provisions, it is difficult for Congress and the public
to fully understand the Army's report.
Additional information is also needed to help explain how the Army
decided to reduce the proposed expansion and selected the 100,000 acres
currently being proposed for acquisition, the growth in the estimated
price per acre, as well as how much of the 100,000 acres would actually
be used for training, what benefits would be gained from adding the
100,000 acres to the Piņon Canyon Maneuver Site, what effect
sustainment and maintenance activities would have on training on the
100,000 acres, and what the future costs would be for sustaining and
maintaining the 100,000 acres. Without the benefit of the analyses and
information on how the Army decided to select the 100,000 acres
currently being proposed for acquisition, especially in light of the
growth in the estimated price per acre, it is difficult for Congress
and the public to evaluate the full benefits and costs associated with
the proposed 100,000-acre expansion.
Recommendations for Executive Action:
To better inform congressional decision makers and facilitate
congressional oversight, we recommend that the Secretary of Defense
direct the Secretary of the Army to take the following two actions:
* Provide Congress with additional information explaining the six
responses about whether existing training facilities are sufficient to
support the training needs and about alternatives for enhancing
economic development opportunities for southeastern Colorado, which
were lacking in the Army's 2008 report on the maneuver site.
* Provide Congress with additional information explaining the reasons
the Army selected the current 100,000-acre site for the proposed
expansion and the growth in the estimated price per acre, as well as
how much of the 100,000 acres would actually be used for training, what
benefits would be gained from adding the 100,000 acres to the existing
maneuver site, what effect sustainment and maintenance activities would
have on training on the 100,000 acres, and what the future costs would
be for sustaining and maintaining the 100,000 acres.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, which represented the
views of DOD and the Army, the Assistant Secretary of the Army for
Installations and Environment partially agreed with our recommendations
but did not specify what actions, if any, DOD or the Army would take to
implement them. In addition, the Assistant Secretary provided general
report comments, specific report comments, and comments about our
recommendations but raised a variety of concerns in their comments
about our characterization of the Army's report, which we discuss
below.
General Report Comments:
In this comments section, the Army stated several times that GAO
concurred with the Army and suggested that our report title should be
revised to reflect that the Army's requirement for an expansion at the
Piņon Canyon Maneuver Site is valid. The Army also stated that the
title of our report does not match the actual findings of our report
and consequently leaves the reader with the impression that the Army
failed to address the central questions of Congress. Our work and this
report were focused on the extent to which the Army addressed the
report provisions required by the section 2831 of the National Defense
Authorization Act for Fiscal Year 2008 and the extent to which the Army
explained the need for the 100,000-acre expansion rather than the
418,577 acres that the Army initially sought. As such, our draft report
addresses these objectives and identified the 23 of the 29 reporting
provisions that the Army generally addressed but not the extent to
which we do or do not concur with the Army's plan. Moreover, as noted
in our report, the Army's responses to 6 of the provisions were not
clear and lacked information; consequently, we continue to believe that
the title of our report accurately reflects our findings and
recommendations.
Specific Report Comments:
The Army disagreed with the draft report's discussion of the increased
cost per acre to expand the Piņon Canyon Maneuver Site and recommended
these costs not be included in our final report. The Army stated that
no appraisals have been conducted to determine a more accurate price
per acre, and the cost figures were not requested by Congress and are
used for internal planning and budgeting purposes only. While we
recognize that comprehensive appraisals have not been done yet, the
Army used the estimated cost per acre that we cited in our draft report
to project the cost of the land acquisition in its moratorium waiver
request to OSD and increased estimates for internal budget purposes. We
included the initial and increased cost estimates in our draft report
because without this information we believed that it would be difficult
for Congress to effectively exercise its oversight of the proposed
expansion and, if found justified, to appropriate sufficient funds to
support it. Because we continue to believe that the Congress will need
this information, we did not remove our discussion of the potentially
increased acquisition cost; however, we revised our report to delete
the more recent, increased cost estimates to avoid a premature release
of the estimates since they have not been fully validated or disclosed
to the public by the Army. We continued to report the initial cost per
acre estimate the Army used in its moratorium waiver request to OSD
because this estimate is in already in the public domain.
The Army also commented that the draft report did not accurately
reflect Army officials' statements regarding congressional funding
restrictions involving the potential Piņon Canyon Maneuver Site
expansion and provided revised language to clarify the Army's position
on the restrictions. We have revised our report to respond to this
comment.
The Army also recommended that we characterize the Army's land
acquisition process as essentially reasonable or sound. We did not
assess the soundness of the Army's land acquisition process during this
review. However, we issued a companion report and concluded that the
Army has an extensive, analytical approach to making decisions for
pursuing training land acquisitions, which is based on (1) the Army's
strategic plan for training ranges--Range and Training Land Strategy--
used to address training land shortfalls and (2) the Army Range
Requirements Model, an analytical computerized decision support tool
that gathers data at the installation level to determine training
requirements and capabilities.[Footnote 25] While we also found that
the strategic plan needs to be updated, we concluded that the model
does provide a consistent and reasonable framework for Army
headquarters, major commands, and installations to use to calculate
training land capabilities and requirements at individual
installations.
Comments about Our Recommendations:
The Army partially agreed with the first recommendation to provide
Congress with additional information about (1) the extent to which
existing training facilities are sufficient to support training needs
and (2) alternatives for enhancing economic development opportunities
for southeastern Colorado. In its comments, the Army stated that it
strongly believes that the best way to provide this information to
Congress is through the NEPA process. It also stated that NEPA is a
critical part of the decision process and much of the information that
we recommended the Army provide Congress will be determined through the
NEPA process. Even though the Army had not started the NEPA process by
the time of our report, the Army's comments provided some of the
additional information regarding the six responses that we concluded
were lacking. Nonetheless, more detailed information would further
clarify these responses. For example, the Army provided a list of
workaround scenarios in its comments and provided one detailed example
of a workaround, but it still does not explain the difference between
minor and major workarounds, the amount of workarounds needed to meet
current training requirements, or how these workarounds impact the
training load at the Piņon Canyon Maneuver Site. At the same time
however, nothing in our recommendation prevents the Army from using the
NEPA process to provide the additional information still lacking if the
Army determines that this would be the most appropriate approach and
would provide the information to Congress in a timely manner.
Therefore, we continue to believe that providing more detailed
information on the six responses would help Congress and the public to
fully understand the Army's report.
The Army also partially agreed with our recommendation to provide the
rationale for selecting the 100,000 acres for the proposed expansion
but did not state what actions it plans to take, if any, to address the
recommendation. The Army stated that it believes that it adequately
explained in the report why it preferred a smaller land acquisition.
Specifically, the Army stated that from the outset it has placed a
priority on the acquisition of area A, the 100,000 acres proposed in
the initial expansion. While we are aware that the Army preferred the
100,000 acres initially, our recommendation was focused on the
usability and sustainability of the 100,000-acre parcel and not why the
Army chose to start with the 100,000 acres. We continue to believe that
the Congress needs this information to assist in its oversight of the
proposed expansion and therefore stand by our recommendation.
The Army also stated its assumption that all 100,000 acres of the site
will be used for training unless an in-depth analysis conducted during
the NEPA process reveals a major problem that would preclude the use of
most or all of the acreage. Further, the Army stated that while
execution of the range maintenance and sustainment program on the
100,000 acres would permit training land to be accessible and usable,
it is premature to project future sustainment costs. However, whether
the Army makes these determinations through the NEPA process or another
method, we continue to believe the amount of acreage useable for
training and sustainment cost projections to be valuable information in
determining the justification for the 100,000-acre site. Without this
information, it is difficult for Congress and the public to fully
understand the Army's justification for expansion.
The Army's comments are reprinted in their entirety in appendix III.
The Army also provided technical comments, which we have incorporated
into the report as appropriate.
We are sending copies of this report to the Secretary of Defense, the
Secretary of the Army, and the Director, Office of Management and
Budget. In addition, the report will be available at no charge on GAO's
Web site at [hyperlink, http://www.gao.gov]. If you have any questions,
please contact me at (202) 512-4523 or leporeb@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this report. Key contributors to this report
are listed in appendix IV.
Signed by:
Brian J. Lepore, Director:
Defense Capabilities and Management:
List of Committees:
The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate:
The Honorable Daniel K. Inouye:
Chairman:
The Honorable Thad Cochran Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
United States Senate:
The Honorable Tim Johnson:
Chairman:
The Honorable Kay Bailey Hutchison:
Ranking Member:
Subcommittee on Military Construction, Veterans' Affairs, and Related
Agencies:
Committee on Appropriations:
United States Senate:
The Honorable Ike Skelton:
Chairman:
The Honorable John M. McHugh:
Ranking Member:
Committee on Armed Services:
House of Representatives:
The Honorable John P. Murtha:
Chairman:
The Honorable C.W. Bill Young:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
House of Representatives:
The Honorable Chet Edwards:
Chairman:
The Honorable Zach Wamp:
Ranking Member:
Subcommittee on Military Construction, Veterans' Affairs, and Related
Agencies:
Committee on Appropriations:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To determine if the Army's report on the Piņon Canyon Maneuver Site
addresses the provisions of section 2831 of the National Defense
Authorization Act for Fiscal Year 2008, we reviewed all 29 provisions
for the Army's responses contained in the act and examined whether the
Army's report provided responses to, as well as all the necessary
information required by, the provisions. We also obtained and reviewed
documents used by the Army to develop responses to the mandate
including the Army's 2005 Land Use Requirements Study, both of the
Army's Piņon Canyon Maneuver Site reports in response to the National
Defense Authorization Acts for Fiscal Year 2007 and Fiscal Year 2008,
and the Army's land acquisition proposal requesting the Office of the
Secretary of Defense (OSD) approval for acquiring up to 418,577 acres.
We interviewed appropriate Army officials, including those directly
responsible for developing the 2008 report, to gain a better
understanding and document the reasons for the Army's responses to the
provisions of the act. During this audit, we met with officials from
the Office of the Deputy Assistant Secretary of the Army for
Installations and Housing, Washington D.C.; the Department of the Army
Management Office (Training Support Systems Division), Washington D.C.;
Army Forces Command, Fort McPherson, Georgia; Fort Carson, Colorado;
and Piņon Canyon Maneuver Site, Colorado.
To determine the extent to which the Army's 2008 report provides
justification for expanding the Piņon Canyon Maneuver Site, we obtained
and reviewed key Army policy guidance for managing its training lands
and ranges, specifically Army Regulation 350-19, The Army Sustainable
Range Program. We compared this guidance to the information provided in
the report to determine how it was used by the Army to justify the need
for expansion at the Piņon Canyon Maneuver Site. We also examined the
analyses used by the Army in developing its 2008 report to understand
how the Army justified its need for an additional 100,000 acres. In
addition, we obtained and reviewed past justifications for training
land expansion at the Piņon Canyon Maneuver Site, including the Army's
2005 Land Use Requirements Study, the Army's response to the National
Defense Authorization Act for Fiscal Year 2007, and the Army's land
acquisition proposal to request OSD approval for acquiring up to
418,577 acres. We did not review the Army's process for acquiring land,
including the use of the Army Range Requirements Model, because these
topics are addressed in detail in a concurrent GAO performance audit,
the results of which are to be published in a separate report in
January 2009.[Footnote 26] We used information gathered from this GAO
review of the Army's overall land acquisition process to supplement our
audit work for this report. In addition, we met with appropriate
officials from the Department of the Army Management Office (Training
Support Systems Division) and Fort Carson to discuss how the addition
of 100,000 acres to the Piņon Canyon Maneuver Site would benefit
training, as well as the workarounds that will be needed to meet
training requirements and potential land management and maintenance
costs. We also visited Fort Carson and the Piņon Canyon Maneuver Site
to see firsthand existing training facilities and ranges.
We conducted this performance audit from August 2008 through January
2009 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Reporting Categories and Provisions of Section 2831 of the
National Defense Authorization Act for Fiscal Year 2008:
Section 2831 of the 2008 National Defense Authorization Act for Fiscal
Year 2008 required that the Army submit a report to Congress detailing
its plans for expanding the Piņon Canyon Maneuver Site. In its report,
the Army was required to respond to 29 provisions regarding the
potential expansion. These provisions fall under three broad reporting
categories: (1) an analysis of whether existing training facilities at
Fort Carson, Colorado, and the site are sufficient to support the
training needs of units stationed or planned to be stationed at Fort
Carson; (2) a report of need for any proposed addition of training land
to support units stationed or planned to be stationed at Fort Carson;
and (3) an analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion. The Army's 2008 report generally addresses
section 2831 of the National Defense Authorization Act for Fiscal Year
2008 by responding to each of the mandate's 29 provisions.
Nevertheless, we found that the responses to six of the provisions were
not clear and lacked information that would help provide the reader a
better understanding of the Army's responses to the mandated
provisions. Table 2 lists the three reporting categories and 29
provisions the Army was required to address in its report, and
indicates those provisions for which additional information would help
clarify the Army's response.
Table 2: Reporting Categories and Provisions of the National Defense
Authorization Act for Fiscal Year 2008 and Whether the Provisions Were
Adequately Addressed in the Army's 2008 Report:
An analysis of whether existing training facilities at Fort Carson,
Colorado, and the site are sufficient to support the training needs of
units stationed or planned to be stationed at Fort Carson:
Reporting categories and provisions: Section 2831(a)(2)(A); An analysis
of whether existing training facilities at Fort Carson, Colorado, and
the site are sufficient to support the training needs of units
stationed or planned to be stationed at Fort Carson;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(A)(i); An
analysis of whether existing training facilities at Fort Carson,
Colorado, and the site are sufficient to support the training needs of
units stationed or planned to be stationed at Fort Carson, including a
description of any new training requirements or significant
developments affecting training requirements for units stationed or
planned to be stationed at Fort Carson since the 2005 Defense Base
Closure and Realignment Commission found that the base has 'sufficient
capacity' to support four brigade combat teams and associated support
units at Fort Carson;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(A)(ii); An
analysis of whether existing training facilities at Fort Carson,
Colorado, and the site are sufficient to support the training needs of
units stationed or planned to be stationed at Fort Carson, including a
study of alternatives for enhancing training facilities at Fort Carson
and the site within their current geographic footprint, including
whether these additional investments or measures could support
additional training activities;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(A)(iii); An
analysis of whether existing training facilities at Fort Carson,
Colorado, and the site are sufficient to support the training needs of
units stationed or planned to be stationed at Fort Carson, including a
description of the current training calendar and training load at the
site;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(A)(iii)(I); An
analysis of whether existing training facilities at Fort Carson,
Colorado, and the site are sufficient to support the training needs of
units stationed or planned to be stationed at Fort Carson, including a
description of the current training calendar and training load at the
site, including the number of brigade-sized and battalion-sized
military exercises held at the site since its establishment;
Adequately addressed in the report: No[A].
Reporting categories and provisions: Section 2831(a)(2)(A)(iii)(II); An
analysis of whether existing training facilities at Fort Carson,
Colorado, and the site are sufficient to support the training needs of
units stationed or planned to be stationed at Fort Carson, including a
description of the current training calendar and training load at the
site, including an analysis of the maximum annual training load at the
site, without expanding the site;
Adequately addressed in the report: No[A].
Reporting categories and provisions: Section 2831(a)(2)(A)(iii)(III);
An analysis of whether existing training facilities at Fort Carson,
Colorado, and the site are sufficient to support the training needs of
units stationed or planned to be stationed at Fort Carson, including a
description of the current training calendar and training load at the
site, including an analysis of the training load and projected training
calendar at the site when all brigades stationed or planned to be
stationed at Fort Carson are at home station;
Adequately addressed in the report: No[A].
A report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson:
Reporting categories and provisions: Section 2831(a)(2)(B); A report of
need for any proposed addition of training land to support units
stationed or planned to be stationed at Fort Carson;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(i); A report
of need for any proposed addition of training land to support units
stationed or planned to be stationed at Fort Carson, including a
description of additional training activities, and their benefits to
operational readiness, which would be conducted by units stationed at
Fort Carson if, through leases or acquisition from consenting
landowners, the site were expanded;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(i)(I); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including a
description of additional training activities, and their benefits to
operational readiness, which would be conducted by units stationed at
Fort Carson if, through leases or acquisition from consenting
landowners, the site were expanded to include the parcel of land
identified as "Area A" in the potential Piņon Canyon Maneuver Site land
expansion map;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(i)(II); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including a
description of additional training activities, and their benefits to
operational readiness, which would be conducted by units stationed at
Fort Carson if, through leases or acquisition from consenting
landowners, the site were expanded to include the parcel of land
identified as "Area B" in the potential Piņon Canyon Maneuver Site land
expansion map;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(i)(III); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including a
description of additional training activities, and their benefits to
operational readiness, which would be conducted by units stationed at
Fort Carson if, through leases or acquisition from consenting
landowners, the site were expanded to include the parcels of land
identified as "Area A" and "Area B" in the potential Piņon Canyon
Maneuver Site land expansion map;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(i)(IV); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including a
description of additional training activities, and their benefits to
operational readiness, which would be conducted by units stationed at
Fort Carson if, through leases or acquisition from consenting
landowners, the site were expanded to include acreage sufficient to
allow simultaneous exercises of a light infantry brigade and a heavy
infantry brigade at the site;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(i)(V); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including a
description of additional training activities, and their benefits to
operational readiness, which would be conducted by units stationed at
Fort Carson if, through leases or acquisition from consenting
landowners, the site were expanded to include acreage sufficient to
allow simultaneous exercises of two heavy infantry brigades at the
site;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(i)(VI); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including a
description of additional training activities, and their benefits to
operational readiness, which would be conducted by units stationed at
Fort Carson if, through leases or acquisition from consenting
landowners, the site were expanded to include acreage sufficient to
allow simultaneous exercises of a light infantry brigade and battalion
at the site;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(i)(VII); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including a
description of additional training activities, and their benefits to
operational readiness, which would be conducted by units stationed at
Fort Carson if, through leases or acquisition from consenting
landowners, the site were expanded to include acreage sufficient to
allow simultaneous exercises of a heavy infantry brigade and a
battalion at the site;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(ii); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including an
analysis of alternatives for acquiring or utilizing training land at
other installations in the United States to support training activities
of units stationed at Fort Carson;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(B)(iii); A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson, including an
analysis of alternatives for utilizing other federally owned land to
support training activities of units stationed at Fort Carson;
Adequately addressed in the report: Yes.
An analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion:
Reporting categories and provisions: Section 2831(a)(2)(C); An analysis
of alternatives for enhancing economic development opportunities in
southeastern Colorado at the current site or through any proposed
expansion;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(C)(i); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of the leasing of land
on the site or any expansion of the site to ranchers for grazing;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(C)(ii); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of the leasing of land
from private landowners for training;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(C)(iii); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of the procurement of
additional services and goods, including biofuels and beef, from local
businesses;
Adequately addressed in the report: No[A].
Reporting categories and provisions: Section 2831(a)(2)(C)(iv); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of the creation of an
economic development fund to benefit communities, local governments,
and businesses in southeastern Colorado;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(C)(v); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of the establishment of
an outreach office to provide technical assistance to local businesses
that wish to bid on Department of Defense contracts;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(C)(vi); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of the establishment of
partnerships with local governments and organizations to expand
regional tourism through expanded access to sites of historic,
cultural, and environmental interest on the site;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(C)(vii); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of an acquisition
policy that allows willing sellers to minimize the tax impact of a
sale;
Adequately addressed in the report: Yes.
Reporting categories and provisions: Section 2831(a)(2)(C)(viii); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of additional
investments in Army missions and personnel, such as stationing an
active duty unit at the site;
Adequately addressed in the report: No[A].
Reporting categories and provisions: Section 2831(a)(2)(C)(viii)(I); An
analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of additional
investments in Army missions and personnel, such as stationing an
active duty unit at the site, including an analysis of anticipated
operational benefits;
Adequately addressed in the report: No[A].
Reporting categories and provisions: Section 2831(a)(2)(C)(viii)(II);
An analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion, including consideration of additional
investments in Army missions and personnel, such as stationing an
active duty unit at the site, including an analysis of economic impacts
to surrounding communities;
Adequately addressed in the report: Yes.
Source: Army's 2008 Report on the Piņon Canyon Maneuver Site and the
National Defense Authorization Act for Fiscal Year 2008.
Note. As stated in the report, the Army's 2008 report generally
addresses each one of the mandate's 29 provisions. The third column of
table 2 indicates those provisions for which additional information
would help clarify the Army's response. There were six responses to the
mandated provisions, which are indicated by the term "no" in the third
column of table 2, for which additional information would help clarify
the Army's response.
[A] A response of "no" indicates that the Army's response to the
reporting provision lacked information that would help provide the
reader a better understanding of the Army's responses to the mandated
provisions; it does not indicate that the Army failed to address the
mandated provision.
[End of table]
[End of section]
Appendix III: Comments from the Department of Defense:
Department Of The Army:
Assistant Secretary Of The Army:
Installations And Environment:
110 Army Pentagon:
Washington DC 20310-0110:
December 22, 2008:
Mr. Brian J. Lepore:
Director:
Defense Capabilities and Management:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Mr. Lepore:
This is the Army and Department of Defense (DoD) response to the GAO
draft report with the working title, `Defense Infrastructure:
Additional Information Is Needed to Better Explain the Proposed 100,000-
Acre Expansion of the Piņon Canyon Maneuver Site,' dated November 20,
2008, (GAO Code 351258/GAO-09-171).
The Army and Department of Defense (DoD) appreciate the opportunity to
comment on the draft report. The coordinated Army/DoD comments on the
two specific recommendations in the report are outlined in the
enclosure. The comments are broken down into both `general comments'
and specific comments. General comments are those which have broad
applicability to the entire report (some phrases recur throughout the
draft report). The Army/DoD is particularly concerned about the working
title of the report, and recommends a title that more closely matches
GAO's findings and recommendations. We continue to appreciate the audit
work performed by the GAO.
Sincerely,
Signed by:
Mr. Keith E. Eastin:
Assistant Secretary of the Army:
Installations and Environment:
Enclosures: As stated:
GAO Draft Report - Dated November 20, 2008:
GAO Code 351258/GAO-09-171:
’Defense Infrastructure: Additional Information Is Needed to Better
Explain the Proposed 100,000-Acre Expansion of the Piņon Canyon
Maneuver Site“
Department Of The Army General Report Comments:
The working title and Highlights section of the GAO report do not match
the actual findings of GAO. The body of the GAO report says the Army‘s
July 2008 Report to Congress adequately addressed 23 of the 29
questions mandated by Congress (pg. 14) – including the critically
important questions asked by Congress in Section 2831(a)(2)(B): ’A
report of need for any proposed addition of training land to support
units stationed or planned to be stationed at Fort Carson.“
None of the responses to 2831(a)(2)(B) were flagged by GAO as being
insufficient in any way. Congress‘ intent was to have GAO independently
verify whether expanding PCMS was necessary, and whether there were
viable alternatives to expansion (see 2831(a)(2)(B)(iii)). On these
most important questions, GAO concurred with the Army, yet nowhere in
the working title or in the Highlights is this fact noted or
referenced.
The current working title leaves the reader with the impression that
the Army report failed to address the central questions of Congress.
Army recommends changing the title of GAO report to better reflect (and
balance) GAO‘s concurrence with the vast majority of the Army‘s report
(including the central question of whether more land was needed).
Accordingly, we propose the new title to be: ’Additional Land
Requirement at Piņon Canyon Maneuver Site is Valid, But Additional
Information Could Help Better Explain Contemplated Expansion.“
Recommend adding the following paragraph at the very beginning of the
GAO Highlights/summary page under ’What GAO Found:“
…The GAO found that the Army‘s report adequately addressed 23 of the 29
of the mandated Congressional reporting provisions, including the key
questions of whether the expansion of PCMS was needed to support units
stationed or planned to be stationed at Fort Carson, and whether there
were any viable alternatives to land expansion that would meet the
Army‘s training doctrinal requirements.‘
As it is currently written and structured, the focus is not on the 80%
agreement (23/29) between GAO and the Army, but on the 20% variance
between what the Army‘s report conveyed, and where GAO thought
additional information would be helpful.
Department Of The Army Specific Report Comments:
1. GAO Highlights, Bullet 2, ’The estimated cost...“
The Army strongly disagrees with the inclusion of this bullet and the
repeated emphasis throughout the report on ’growth in the estimated
price per acre.“ Congress did not include any questions in its
reporting requirement about the cost per acre. No appraisals have been
done on any property, so there is no evidentiary basis to state what
the cost per acre will be to acquire any of the property. Estimated
cost figures are used for internal planning and budgeting purposes
only. Any discussion of cost per acre will be misleading to the public
and should be removed from the report.
2. GAO Highlights, Last paragraph, line 1, ’Army officials said...“
Disagree with the phrase ’...would be difficult to address...“ and
recommend changing to, ’would be best addressed through the analysis
required...“
3. GAO Highlights, Last paragraph, line 7, ’This, in the view of the
Army...continue with the process when funds become available.“
These two sentences in the GAO ’Highlights“ are inaccurate and should
be deleted or revised. The Congressional appropriations limitation
applies only to the MILCON-VA appropriations bills for FY 2008 and FY
2009. It does not affect Defense Appropriations, which fund the
Operations and Maintenance (O&M) accounts that pay for EIS efforts in
compliance with NEPA. Therefore, the restrictions do not prevent or
preclude the Army from starting a NEPA analysis for expansion.
Recommend changing to, ’Since O&M funds are used to pay for NEPA
analyses, the Army is not precluded from further studying the 100,000-
acre site or starting the NEPA process, but to date the Army has
voluntarily deferred spending other appropriated funds while due to
Congressional concerns. Uncertainty over Congressional support for the
contemplated expansion made a delay in expending funds to start an
expansion NEPA appear to be prudent.“
4. GAO Highlights, Last paragraph, line 11, ’Without the benefit of the
analyses...“:
Disagree with the characterization that, ’the Army decided to select
the 100,000 acres...“ There was never a "decision" to purchase either
the 418,000 acres, or in the alternative, to purchase 100,000 acres
instead. The Army sought and received authorization to purchase up to
418,000 acres from OSD. The NEPA process is a critical part of the
decision process that will determine how much, if any land is
purchased. Until the NEPA process is complete, no decisions will be
made. Recommend changing to, ’Without the benefit of the NEPA analyses
it is difficult for Congress and the public to evaluate the full
benefits and costs...“
5. Page 2, Line 2:
’An increase in training acreage from 66,000 to 161,000 is well over
100 percent.“ Recommend changing this sentence to read: ’An increase in
training...is nearly 144 percent.
6. Page 2, Lines 17-19:
Disagree with the use of the phrase, ’...in their view...“
Congressional appropriations language does not restrict the use of O&M
funds. Recommend changing to, ’...the Army used operations and
maintenance funds that were not subject to the above-referenced...“
7. Page 4, Results in Brief:
The GAO report gives very short shrift to the fact that GAO concurred
with 80% of the Army‘s responses in its July 2008 report (23/29),
including its concurrence with the very significant issue of …a report
of need for more training land‘ – the central question raised by
Congress. Recommend GAO add the following immediately under ’Results in
Brief“ to balance the summary of GAO‘s results, ’The GAO found that the
Army‘s report adequately addressed 23 of the 29 mandated Congressional
reporting provisions, including the key questions of whether the
expansion of PCMS was needed to support units stationed or planned to
be stationed at Fort Carson, and whether there were any viable
alternatives to land expansion that would meet the Army‘s training
doctrinal requirements.“
8. Pages 6-7, 10 (last line of text):
Regarding NEPA and the Congressional appropriations limitations, see
comments above as to why the Congressional limitations do not preclude
or limit NEPA analysis related to PCMS expansion. Recommend these
portions of the GAO report be deleted or modified as recommended
previously.
9. Page 6, Lines 8-13:
Recommend GAO delete the phrase, ’However, the Army has not fully
explained...“ and replace with, ’The GAO, based on its discussions with
Army officials, believes that many of the following additional issues
could be better explained and discussed through the analysis required
by [NEPA]“
10. Pages 12-13:
Nowhere does the GAO report characterize the Army‘s land acquisition
process as essentially reasonable or sound, yet from the discussions
with the GAO analysts, this appears to be GAO‘s overall conclusion.
Recommend GAO state this conclusion, given that one of the questions
Congress and the public are interested in is whether the Army‘s land
acquisition process at PCMS can be trusted to produce logical and
reasoned recommendations.
Department Of Defense Comments To The Recommendations:
Recommendation 1: The GAO recommends that the Secretary of Defense
direct the Secretary of the Army to provide Congress with additional
information explaining the six responses about whether existing
training facilities are sufficient to support the training needs and
about alternatives for enhancing economic development opportunities for
southeastern Colorado, which were lacking in the Army‘s 2008 report on
the maneuver site.
DOD Response: Partially concur.
The Army strongly believes the best way to provide additional
information to Congress on the remaining issues is through the National
Environmental Policy Act (NEPA) process. As NEPA is a critical part of
the decision process and the next required step in land acquisition,
much of the information GAO recommends requesting will be determined
through this process. The Army believes that GAO should emphasize the
importance of the NEPA process. The recommendation should be changed to
read, ’The Army should begin NEPA at the appropriate time, and ensure
that the remaining issues be covered and discussed adequately either
through NEPA analysis, or through a similar mechanism of the Army‘s
choosing.“
The following additional information is provided to further explain the
six responses that GAO felt were lacking in the Army‘s 2008 Report.
1. Section 2831 (a)(2)(A)(iii)(I):
There is no requirement for the Army to keep detailed utilization
records for training events that do not involve live fire of munitions.
The Piņon Canyon Maneuver Site (PCMS) began keeping utilization records
with an automated training scheduling and utilization record for all
training events at its installations in 2004 with the current version
of the Range Facility Management Support System (RFMSS). While the Army
has been using PCMS to conduct training exercises since 1985, there was
no system in place to officially track utilization of maneuver training
areas prior to 2004. Therefore, the Army chose to provide information
on known training rather than relying on institutional memory and
interviews with former Fort Carson/PCMS range personnel, which is not
auditable. The Army made a decision to emphasize reliability and
quality of data verses quantity.
More importantly, as indicated on page 19 of the Army‘s 2008 report,
the historic use of PCMS does not reflect the future projected use, due
to changes within Army doctrine and Army force structure changes.
2. Section 2831 (a)(2)(A)(iii)(II):
Currently, PCMS contains approximately 224,000 acres available for
maneuver training. This allows for the following training exercises to
be conducted to doctrinal standards:
* One Heavy Brigade Combat Team (HBCT) conducting a free flowing
exercise (170,000 acres);
* One Infantry Brigade Combat Team (IBCT) conducting a free flowing
exercise (112,000 acres);
* Two IBCTs conducting free flowing exercises simultaneously (224,000
acres).
It is not currently possible for an HBCT and an IBCT to conduct free
flowing exercises simultaneously and is it also not possible for two
HBCTs to conduct free flowing exercises simultaneously.
Currently two HBCTs and one IBCT are stationed at Fort Carson and these
units can effectively train. Following the actions discussed on pages
14-16 of the Army‘s 2008 report, three HBCTs and two IBCTs will be
stationed at Fort Carson by 2011.
The Army believes that the July 2008 report does address the issue of
’work-arounds“, albeit from a broad perspective that is hopefully more
understandable for a layperson. However, for clarification, the types
of workarounds that are employed by units when training land is
restricted include, but are not limited to: reordering the sequence of
tasks or events in a training exercise; delaying the training on
certain tasks until deployment; not training the task or event to
doctrinal standard. Work-arounds decrease the quality of Soldier
training which is critical to success on the battlefield.
A specific example of ’work-arounds“ producing the effects described in
the July 2008 report: Lack of Maneuver Depth Causing
Exercises/Scenarios to Become Unrealistic. In a common training
scenario, a unit is ordered to launch an attack and maneuver
aggressively towards opposition force (OPFOR) held positions. The unit
then presses the attack for a pre-designated distance. Then the OPFOR
launches a counterattack, and the unit must shift quickly from attack
to defense, maneuvering while falling back a pre-designated distance.
This scenario is critical to instilling basic concepts of …defense in
depth‘ and teaching unit commanders how hard they can press an attack
before their Soldiers become exhausted, out of position, or excessively
dispersed (and hence vulnerable to a counterattack). If the scenario
calls for the entire attack-counter-attack-recover sequence to be
played out within a 15 km by 5 km maneuver box, but the actual amount
of acreage available is only half or less of what is doctrinally
required, one of the …work-arounds‘ will be for the US force to attack
from one side to the available maneuver box to the other, and then when
the OPFOR is ready to launch its counterattack, the exercise will be
halted, and all units will move several kilometers backwards so there‘s
enough room for the remainder of the scenario to be completed.
Obviously, this is totally unrealistic – there are no ’time outs“ on
the modern battlefield where Soldiers get to rest up and reorganize
prior to the enemy launching a counter-attack.
Page 19 of the July 2008 report notes that without expansion, it will
’make it difficult to train units to operate on the scale demanded by
the contemporary operating environment.“ This current operating
environment was explained on pages 8-9, with a chart depicting the
amount of terrain Brigades must secure on the battlefield growing
exponentially since World War II. Also, on pages 19-20, is a detailed
description of what training …work-arounds‘ can do to units and
Soldiers if they are not allowed to train in a dispersed manner similar
to their contemporary operating environment: ’work-around scenarios
that train units without stressing their full operational
capability—creates the risk of developing bad habits in training and
embeds false expectations as to true battlefield conditions.“
Regarding the costs associated with increased training and use of the
existing PCMS, the Integrated Training Area Management (ITAM) program
is the Army's premier program for sustaining its training land
throughout the Army. ITAM uses an integrated approach to sustaining its
training land through four components to provide integration of
doctrinal training requirements with sound land management methods,
repair of maneuver damage, assessment of land condition, and awareness
training for Soldiers and civilians to avoid preventable damage to
natural resources in the training area. Types of repair, maintenance
and associated costs are a function of weather conditions, intensity
and type of training, soil conditions, materials, and labor costs for
field crews to repair maneuver land damage. We expect an increase in
ITAM requirements over the FY 09 $2.42M requirement at PCMS. For
planning purposes we would estimate the future requirement on the
100,000 acres to be between $1.2M and $1.5M. However, this is merely an
estimate based on current requirements at PCMS.
3. Section 2831 (a)(2)(A)(iii)(III):
The Army‘s recent Posture Statements refer to the U.S. waging ’The Long
War“ in an ’Era of Persistent Conflict.“ The Posture Statement factors
into most Army plans as an assumption of regular rotations and
deployments for the foreseeable future. Regarding the issue of
peacetime vs. wartime deployment assumptions, if the Army did assume
peacetime conditions when all or most units would be at home station,
it is important to note that this assumption would substantially
increase the demand for training calendar space at PCMS, which would
strengthen, not weaken, the Army‘s case for, and need for, training
land expansion.
4. Section 2831 (a)(2)(C)(iii):
Regarding the Army‘s failure to specifically address ’biofuels“ and
’beef,“ the Army notes that on this question it interpreted the
reporting requirement broadly. Beef and biofuels are two examples;
however the Army cannot provide details regarding specific purchases of
any particular kind of good or service: (1) prior to NEPA and a
decision, and (2) due to the need to determine, from a procurement and
fiscal legal perspective, whether such purchases are allowable.
However, the Army did lay out an extensive and specific set of possible
economic development opportunities that could be implemented if PCMS
were expanded ($100M+ in new construction, approximately 100
civilians/contractors hired at PCMS with a payroll and operations
budget of $9M/annually, ideas for promoting tourism/cultural heritage)
that would broadly benefit the entire local community in and around Las
Animas County, Colorado. The Army compared the magnitude of these
projected economic benefits against the magnitude of estimated cattle
sales from Area A, and the Army‘s positive economic impact would be
significantly greater than any foregone cattle sales.
5. Section 2831 (a)(2)(C)(viii):
Regarding the question of infrastructure requirements to accommodate
stationing active duty units at PCMS itself, the Army ruled out
stationing units at PCMS during the Programmatic Environmental Impact
Statement (EIS) because of the prohibitive cost of replicating the
infrastructure at PCMS that currently exists at Fort Carson‘s
cantonment area and surrounding community. An internal Army analysis in
June 2007 concluded that it would cost 64 percent more ($331M+) to
station an IBCT at PCMS ($845M) rather than Fort Carson ($513M).
(Analysis attached)
Stationing an IBCT at PCMS would not only entail a $330M+ additional
cost but the additional civilians and contractors typically increase
the nearby communities‘ population by 8,000 to 10,000 persons total. In
Las Animas County, which has a total population of about 15,000
persons, adding an IBCT at PCMS could overwhelm and transform the local
community from a ranching heritage to a military bedroom community.
Lastly, stationing an IBCT at would require a substantially larger
cantonment area at PCMS, which would reduce the number of maneuver
acres available for training.
6. Section 2831 (a)(2)(C)(viii)(I):
Regarding the analysis of the operational benefits of stationing an
active duty unit at PCMS, the Army did not conduct an analysis of
operational benefits due to the fact that the costs to construct the
infrastructure to support a BCT at PCMS were prohibitive and simply
made the option of stationing completely infeasible. As noted above,
any operational benefits, even if cost-benefit considerations were not
a factor, would be partially negated by the loss of maneuver acreage in
order to build up the PCMS cantonment area and associated
infrastructure.
Recommendation 2: The GAO recommends that the Secretary of Defense
direct the Secretary of the Army to utilize available funds, if any, or
when funds become available to further study the proposed 100,000-acre
expansion site, provide Congress with additional information explaining
the reasons the Army selected the current 100,000-acre site for the
proposed expansion and the growth in the estimated price per acre, as
well as how much of the 100,000 acres would actually be used for
training, what benefits would be gained from adding the 100,000 acres
to the existing maneuver site, what effect sustainment and maintenance
activities would have on training on the 100,000 acres, and what the
future costs would be for sustaining and maintaining the 100,000 acres.
DOD Response: Partially Concur.
The Army believes that it did adequately explain why it preferred a
smaller land acquisition. Page 22 of the Army report, (with which GAO
concurred) states ’From the outset of the land acquisition process, the
Army has placed a priority on the acquisition of Area A“ and then the
report lists reasons why Area A (approximately 100,000 acres) was a
priority.
Pages 23-24 of the Army report (GAO also concurred) explains why Area
B, while appearing initially to offer many training advantages, is no
longer viewed as feasible. The Army report also notes (pages 4, 23)
that from the outset of the Army‘s contemplated expansion, budgetary
constraints would play a very important role in the process. Every
training advantage obtained through land expansion also had to be
weighed from a cost-benefit standpoint. Along those lines, pages 25-26
of the Army report (GAO also concurred) contain Army responses to
several Congressionally-directed training scenarios. An expansion equal
to Area A would allow the Army to mostly or fully meet every one of the
Congressional training scenarios. In short, the Army believes that Area
A (100,000 acres) provides the greatest training benefit, at the lowest
cost, the lowest acreage footprint, and with the fewest number of
affected landowners and communities.
The Army‘s land acquisition moratorium waiver request to the Office of
the Secretary of Defense (OSD) was never predicated on an …all or
nothing‘ proposition. The OSD approval memo of February 2007 allows the
Army to acquire up to 418,000 acres. The Army report is very clear that
all of the 100,000 acres will be used for training and to build a
$100M+ training range complex (described in detail on page 35 of the
Army report). The Army must use that assumption until it conducts an in-
depth environmental analysis done through NEPA. If NEPA were to uncover
a major problem that would preclude the use of most or all of the
contemplated 100,000 acres, the Army would reassess the contemplated
expansion.
Finally, as stated previously, execution of the ITAM program on the
100,000 acres would permit training land to be accessible and usable.
It would be premature to project what future cost would be; however,
since the FY 2009 ITAM requirement for PCMS was $2.42M, Army estimates
the future requirement will be between $1.0M and $1.5M annually. The
Army strongly disagrees with the implication that ITAM and other
sustainment costs are a factor of such significance that it could alter
the validity or necessity of the expansion itself.
As noted earlier in the comments to the ’Highlights“ section, the Army
disagrees with GAO‘s assessment that ’growth in the estimated price per
acre,“ is a …problem‘ that needs to be …addressed.‘ The Army has never
previously released any information to the public on estimated costs
per acre. Cost figures discussed by GAO do not reflect any
determination of fair market value, because no appraisals have been
conducted. The estimated cost figures generated by the Army are used
solely for internal planning and budgeting purposes and include best
guesses as to the cost for land, improvements, relocation assistance,
and administrative cost, but the discussion of cost estimates in the
GAO has strong potential to be confusing and misleading to the public.
Additionally, Congress did not ask for a discussion or explanation of
cost estimates. Army strongly recommends that discussion of estimated
land costs should be removed from the report.
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
Brian J. Lepore, (202) 512-4523 or leporeb@gao.gov:
Acknowledgments:
In addition to the contact named above, Mark Little, Assistant
Director; Ron La Due Lake; Mae Jones; Kate Lenane; Josh Margraf;
Courtney Reid; and Roger Tomlinson made major contributions to this
report.
[End of section]
Footnotes:
[1] Army transformation and modularity efforts include the
standardization of unit structure to modular brigade combat teams and
integration of new technology and equipment to make the Army more
deployable, flexible, lethal, and adaptive. In 2007, the President
announced the Grow the Army initiative, which is expected to increase
the Army's troop strength by 74,200 soldiers including active, National
Guard, and Reserve units by 2013.
[2] Department of the Army, Range and Training Land Strategy
(Washington, D.C.: Feb. 11, 2004).
[3] Pub. L. No. 109-364, § 2827 (2006).
[4] Pub. L. No. 110-161, Division I, Title IV, § 409 (2007).
[5] Pub. L. No. 110-181, § 2831(a) (2008).
[6] Pub. L. No. 110-329, Division E, Title I, § 127 (2008).
[7] NEPA, codified as amended at 42 U.S.C. § 4321-4347, establishes
environmental policies and procedures that are required to be followed
by all federal agencies to the fullest extent possible. In accordance
with these requirements and the regulations for implementing NEPA
established by the Council for Environmental Quality, agencies
typically evaluate the likely environmental effects of a project they
are proposing to undertake with an environmental assessment and/or
environmental impact statement. The Council on Environmental Quality is
responsible for, among other things, issuing guidelines and reviewing
agencies' policies and procedures to ensure compliance with the act.
Council on Environmental Quality regulations implementing NEPA appear
at 40 C.F.R. Part 1500.
[8] Pub. L. No. 110-181, § 2831(b) (2008).
[9] In addition to this review of the Army's 2008 report on the Piņon
Canyon Maneuver Site, we also reviewed the Army's approach for
acquiring additional training land, including the information in the
Army Range Requirements Model. The results of both reviews will be
published on January 13, 2009. See GAO, Defense Infrastructure: Army's
Approach for Acquiring Land Is Not Guided by Up-to-Date Strategic Plan
or Always Communicated Effectively, [hyperlink,
http://www.gao.gov/products/GAO-09-32] (Washington, D.C.: Jan. 13,
2009).
[10] The 29 provisions are listed in appendix II.
[11] Department of the Army Regulation 350-19, Sustainable Range
Program, U.S. Army Chief of Staff (Washington, D.C.: Aug. 30, 2005).
According to Army Regulation 350-19, a military land acquisition
proposal is a series of questions intended to provide senior leadership
with the essential information to make a decision about a major land
acquisition. When preparing the proposal, the proponent installation is
to summarize, where applicable, information detailed in the range
complex master plan, range development plan, and analysis of
alternatives study. The proposal is to include a map of the proposed
acquisition, the purpose of the acquisition, potential effects on
surrounding communities, and several other items related to the
proposed land acquisition.
[12] Consolidated Appropriations Act, 2008, Pub. L. No. 110-161,
Division I, Title IV, § 409 (2007).
[13] Consolidated Security, Disaster Assistance, and Continuing
Appropriations Act, 2009, Pub. L. No. 110-329, Division E, Title I, §
127 (2008).
[14] See Army's Range and Training Land Strategy.
[15] Pub. L. No. 109-364, § 2827 (2006).
[16] Department of the Army, National Defense Authorization Act Section
2827(a) Report on Piņon Canyon Maneuver Site (Washington, D.C.: Dec. 8,
2006).
[17] Pub. L. No. 110-161, Division I, Title IV, § 409 (2007).
[18] Pub. L. No. 110-181, § 2831 (2008).
[19] Pub. L. No. 110-329, Division E, Title I, § 127 (2008).
[20] Army training doctrine and policy are provided in four key
documents: Army Training Circular 25-1, Training Land, U.S. Army Chief
of Staff (Washington, D.C.: Mar. 15, 2004); Army Training Circular 25-
8, Training Ranges, U.S. Army Chief of Staff (Washington, D.C.: Apr. 5,
2004); Army Pamphlet 350-38, Standards in Training Commissions, U.S.
Army Chief of Staff (Washington, D.C.: July 24, 2008); and Army
Pamphlet 415-28, Real Property Category Codes, U.S. Army Chief of Staff
(Washington, D.C.: Apr. 11, 2006).
[21] 40 C.F.R. § 1502.13-1502.16.
[22] GAO, Defense Infrastructure: Army's Approach for Acquiring Land Is
Not Guided by an Up-to-Date Strategic Plan or Always Communicated
Effectively, [hyperlink, http://www.gao.gov/products/GAO-09-32]
(Washington, D.C.: Jan. 13, 2009).
[23] See Department of the Army Regulation 350-19.
[24] 40 C.F.R. § 1502.13-1502.16.
[25] GAO, Defense Infrastructure: Army's Approach for Acquiring Land Is
Not Guided by Up-to-Date Strategic Plan or Always Communicated
Effectively, [hyperlink, http://www.gao.gov/products/GAO-09-32]
(Washington, D.C.: Jan.13, 2009).
[26] See [hyperlink, http://www.gao.gov/products/GAO-09-32].
[End of section]
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