Defense Infrastructure
Army's Approach for Acquiring Land Is Not Guided by Up-to-Date Strategic Plan or Always Communicated Effectively Gao ID: GAO-09-32 January 13, 2009Recently, the Army forecast that it would experience a 4.5-million-acre training land shortfall by 2013 and proposed to purchase additional land adjacent to certain existing training ranges. In response to a congressional request, GAO reviewed the Army's approach for acquiring training land. This report (1) evaluates the Army's approach to the acquisition of training land, (2) describes the Army's consideration of alternatives and assessment of the environmental and economic effects, and (3) analyzes the Army's effectiveness in communicating its approach for making decisions to pursue these acquisitions before the Office of the Secretary of Defense's (OSD) approval. GAO reviewed the Army strategic plan for training lands and other relevant documents, and focused on all five land acquisitions since 2002 at Fort Irwin, California; three training sites in Hawaii; and the proposed expansion of the Pinon Canyon Maneuver Site in Colorado.
The Army has established an extensive, analytical approach to making decisions regarding training land acquisitions, but has not ensured that its strategic plan remains current. The Army's approach uses as its basis a strategic plan for training ranges and an analytically based range requirements model. In addition, the Army has a process during which training land shortfalls and capabilities are analyzed in multiple ways, by multiple parties, and at multiple times. However, the Army has not updated its strategic plan since it was developed in 2004. As a result, new initiatives that affect training land needs, such as base realignment and closure actions, are not explained in the plan. This is because the Army does not have a mechanism to ensure that the strategic plan is updated at regular intervals to reflect up-to-date training land requirements resulting from new initiatives. As a result, the training land needs articulated in the strategic plan are now 4 years out of date. To support the Army's requests to pursue major land acquisitions to support training, it conducted initial conceptual analyses in which it identified potential alternatives and assessed environmental and economic effects of its proposed land acquisitions at Fort Irwin, three sites in Hawaii, and Pinon Canyon Maneuver Site. After OSD approved the Army's land acquisition proposals, the National Environmental Policy Act of 1969 and Council on Environmental Quality regulations required the Army to conduct additional assessments, which it did at Fort Irwin and in Hawaii. The Consolidated Appropriations Act, 2008, stated that none of the funds made available in the act may be used for the expansion of the Pinon Canyon Maneuver Site. Army officials stated that they did not start the National Environmental Policy Act process at Pinon Canyon because of uncertainly over congressional support for the expansion and redirected their efforts to respond to the National Defense Authorization Act for Fiscal Year 2008, which required the Army to submit a report containing an analysis of the existing facilities at Fort Carson and Pinon Canyon. The Army delivered the required report in July 2008. Because of a lack of specificity in OSD and Army communication strategies, the Army has not been consistent or always effective in communicating its approach to acquire training land. According to OSD's policy, no major land acquisition proposal may be made public through official notice until OSD has approved the acquisition. The policy is unclear what public notification, such as informal community outreach, is permissible prior to approval. While the Army's strategic plan emphasizes that it is important to engage the public early in the process, it lacks specificity as to when and in what form this outreach should take place. In California and Hawaii, the Army followed the strategy articulated in its plan, openly explaining why it was acquiring land, which helped ease the start of the acquisition process. Army officials and community groups said that the Army did not adequately explain its reasoning for the proposed expansion at Pinon Canyon. In this case, the public at times relied on rumors and leaked documents. These information sources often did not provide clear, complete, or accurate data. Without a consistent and clear DOD-wide practice that both addresses concerns about early disclosure of land acquisitions and permits some flexibility to engage the public, the Army and other services are likely to experience communication problems similar to those encountered at Pinon Canyon.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-09-32, Defense Infrastructure: Army's Approach for Acquiring Land Is Not Guided by Up-to-Date Strategic Plan or Always Communicated Effectively
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
January 2009:
Defense Infrastructure:
Army's Approach for Acquiring Land Is Not Guided by Up-to-Date
Strategic Plan or Always Communicated Effectively:
GAO-09-32:
GAO Highlights:
Highlights of GAO-09-32, a report to congressional requesters.
Why GAO Did This Study:
Recently, the Army forecast that it would experience a 4.5-million-acre
training land shortfall by 2013 and proposed to purchase additional
land adjacent to certain existing training ranges. In response to a
congressional request, GAO reviewed the Army‘s approach for acquiring
training land. This report (1) evaluates the Army‘s approach to the
acquisition of training land, (2) describes the Army‘s consideration of
alternatives and assessment of the environmental and economic effects,
and (3) analyzes the Army‘s effectiveness in communicating its approach
for making decisions to pursue these acquisitions before the Office of
the Secretary of Defense‘s (OSD) approval. GAO reviewed the Army
strategic plan for training lands and other relevant documents, and
focused on all five land acquisitions since 2002 at Fort Irwin,
California; three training sites in Hawaii; and the proposed expansion
of the Piņon Canyon Maneuver Site in Colorado.
What GAO Found:
The Army has established an extensive, analytical approach to making
decisions regarding training land acquisitions, but has not ensured
that its strategic plan remains current. The Army‘s approach uses as
its basis a strategic plan for training ranges and an analytically
based range requirements model. In addition, the Army has a process
during which training land shortfalls and capabilities are analyzed in
multiple ways, by multiple parties, and at multiple times. However, the
Army has not updated its strategic plan since it was developed in 2004.
As a result, new initiatives that affect training land needs, such as
base realignment and closure actions, are not explained in the plan.
This is because the Army does not have a mechanism to ensure that the
strategic plan is updated at regular intervals to reflect up-to-date
training land requirements resulting from new initiatives. As a result,
the training land needs articulated in the strategic plan are now 4
years out of date.
To support the Army‘s requests to pursue major land acquisitions to
support training, it conducted initial conceptual analyses in which it
identified potential alternatives and assessed environmental and
economic effects of its proposed land acquisitions at Fort Irwin, three
sites in Hawaii, and Piņon Canyon Maneuver Site. After OSD approved the
Army‘s land acquisition proposals, the National Environmental Policy
Act of 1969 and Council on Environmental Quality regulations required
the Army to conduct additional assessments, which it did at Fort Irwin
and in Hawaii. The Consolidated Appropriations Act, 2008, stated that
none of the funds made available in the act may be used for the
expansion of the Piņon Canyon Maneuver Site. Army officials stated that
they did not start the National Environmental Policy Act process at
Piņon Canyon because of uncertainly over congressional support for the
expansion and redirected their efforts to respond to the National
Defense Authorization Act for Fiscal Year 2008, which required the Army
to submit a report containing an analysis of the existing facilities at
Fort Carson and Piņon Canyon. The Army delivered the required report in
July 2008.
Because of a lack of specificity in OSD and Army communication
strategies, the Army has not been consistent or always effective in
communicating its approach to acquire training land. According to OSD‘s
policy, no major land acquisition proposal may be made public through
official notice until OSD has approved the acquisition. The policy is
unclear what public notification, such as informal community outreach,
is permissible prior to approval. While the Army‘s strategic plan
emphasizes that it is important to engage the public early in the
process, it lacks specificity as to when and in what form this outreach
should take place. In California and Hawaii, the Army followed the
strategy articulated in its plan, openly explaining why it was
acquiring land, which helped ease the start of the acquisition process.
Army officials and community groups said that the Army did not
adequately explain its reasoning for the proposed expansion at Piņon
Canyon. In this case, the public at times relied on rumors and leaked
documents. These information sources often did not provide clear,
complete, or accurate data. Without a consistent and clear DOD-wide
practice that both addresses concerns about early disclosure of land
acquisitions and permits some flexibility to engage the public, the
Army and other services are likely to experience communication problems
similar to those encountered at Piņon Canyon.
What GAO Recommends:
GAO recommends that (1) the Army develop and implement a process to
update periodically its strategic plan for training ranges to reflect
current needs and (2) OSD and the Army jointly review their strategies
for communicating major land acquisitions and agree on a common
practice that would address concerns about early disclosure and provide
the Army and the other services some flexibility to engage the public.
DOD generally agrees with the recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-32]. For more
information, contact Brian J. Lepore at (202) 512-4523 or
leporeb@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Army's Approach to Training Land Acquisitions Is Extensive, but Based
on a Strategic Plan That Is Outdated:
Army Considered Alternatives and Prepared Assessments of Environmental
and Economic Effects before Pursuing OSD Waiver Approval:
Army Has Not Always Been Effective in Communicating Its Approach to
Training Land Acquisitions:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Army Range Requirements Model:
Army Range Requirements Model Uses Multiple Inputs to Determine
Training Land Requirements:
Army Range Requirements Model Has Several Quality Assurance Safeguards:
Appendix III: Comments from the Department of Defense:
Appendix IV: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Process for Updating Data in the Army Range Requirements
Model:
Figures:
Figure 1: The Army's Six-Step Process for Determining Whether to Pursue
Training Land Acquisitions:
Figure 2: Army Range Requirements Model's Multiple Inputs:
Abbreviations:
BRAC: base realignment and closure:
DOD: Department of Defense:
OSD: Office of the Secretary of Defense:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
January 13, 2009:
The Honorable Solomon P. Ortiz:
Chairman:
The Honorable J. Randy Forbes:
Ranking Member:
Subcommittee on Readiness:
Committee on Armed Services:
House of Representatives:
The Honorable Mark Udall:
United States Senate:
The Honorable Elizabeth Helen Markey:
House of Representatives:
In a July 2008 mandated report, the Army forecast that it would
experience a 4.5-million-acre training land shortfall by 2013.[Footnote
1] This forecast followed decades of reports by Army officials that the
Army faces increasing difficulties carrying out realistic training at
military installations and training ranges--the land and air space used
for live fire and maneuver training--due to encroachment and emerging
capabilities of new weapons systems that require additional land for
training. As one way to address the increasing training land shortfall,
the Army proposed to expand certain training areas by acquiring,
through purchase or lease, additional land adjacent to existing
training ranges in cases where the Army found expansion to be feasible,
affordable, and compatible with mission goals and environmental
conditions and requirements. However, the Army's efforts to acquire
land have often been met with opposition from landowners and groups who
questioned the basis for pursuing land expansions.
In 1989 and 1991, we reported that the Army pursued land acquisitions
without a rational strategy and instead made acquisition decisions on
the basis of targets of opportunity, such as the availability of land
for sale, making it difficult for the Army to justify its land
acquisitions to Congress and the public.[Footnote 2] Subsequently, the
Army Audit Agency reiterated the findings in our reports and the Rand
Arroyo Center recommended that the Army publish a national land
strategy.[Footnote 3] In September 1990, the Office of the Secretary of
Defense (OSD) issued a departmentwide moratorium on major land
acquisitions--those exceeding 1,000 acres or costing more than $1
million--for installations in the United States[Footnote 4] and updated
and provided further instruction on the moratorium in October 1993,
December 1994, November 2002, and July 2005.[Footnote 5] OSD's
memorandum was also incorporated into the Department of Defense (DOD)
guidance in January 2005.[Footnote 6] Waivers to this moratorium may be
granted by OSD on a case-by-case basis. After a waiver to this
moratorium is granted and before the final decision to acquire the
land, the department must ensure compliance with applicable provisions
of the National Environmental Policy Act of 1969,[Footnote 7] and the
Congress must appropriate the funds for the acquisition. Since the
moratorium was updated in 2002, the Army has obtained OSD waiver
approval to undertake four major training land acquisitions--involving
the National Training Center at Fort Irwin, California, and three sites
in Hawaii known as the South Range, West Pohakuloa Training Area, and
Parcel 1010. Army officials said that the Army has acquired parcels of
land at these four locations. Also, in February 2007, the Army
announced that OSD had granted a moratorium waiver and that the Army
could pursue a fifth acquisition--expansion of the existing 235,300-
acre training range, known as the Piņon Canyon Maneuver Site, near Fort
Carson, Colorado, by an additional 418,577 acres. This potential
expansion has drawn criticism from some affected landowners and
interest groups and, in July 2008, the Army reported that it planned to
limit the potential expansion of the maneuver site to 100,000 acres
instead of the initially proposed area.[Footnote 8]
In response to your request, we reviewed the Army's approach for
acquiring training land and focused on the Army's approach to obtaining
OSD waiver approval in four recent major acquisitions at Fort Irwin and
in Hawaii and the potential expansion of the Piņon Canyon Maneuver
Site. This report (1) evaluates the Army's approach for making
decisions regarding the acquisition of training land, (2) describes the
Army's consideration of alternatives and assessment of the
environmental and economic effects of acquiring training land, and (3)
analyzes the Army's effectiveness in communicating to Congress and the
public the approach used for making decisions to pursue these
acquisitions prior to OSD moratorium waiver.
During our review, we met with officials from the Office of the Under
Secretary of Defense for Acquisitions, Technology, and Logistics and
the Department of the Army to discuss the Army's approach for making
decisions regarding the acquisition of training land and to identify
the Army's major training land acquisitions and proposals. We focused
on five major training land acquisitions--expansion of the National
Training Center at Fort Irwin; three sites in Hawaii known as the South
Range, West Pohakuloa Training Area, and Parcel 1010; and the potential
expansion of the Piņon Canyon Maneuver Site, because they are the only
completed or planned major land acquisitions since OSD updated its
moratorium in 2002. To evaluate the Army's approach for making
decisions regarding the acquisition of training land, we evaluated
DOD's regulations that govern land acquisition and the Army's
directives, policies, and procedures that implement and clarify those
regulations. We identified the methods Army planning and budgeting
officials use to address training shortfalls and the model Army
officials at the installation level use to project and determine land
acquisition requirements. Specifically, we examined the Army's
strategic plan for training ranges, called the Range and Training Land
Strategy,[Footnote 9] and the training doctrine and policy,[Footnote
10] data elements, and formulas used in the Army Range Requirements
Model--the Army's analytically based approach for calculating training
land requirements and shortages. To determine whether the range
requirements model provided a consistent and reasonable framework for
estimating training land requirements and whether it used accurate
inputs, we reviewed the documentation supporting the model's analytic
framework, including the model's calculations and assumptions.[Footnote
11] To determine whether the Army considered alternatives to acquiring
training land and the potential effects, we compared Army's policies,
procedures, and practices for acquiring land with the actual practices
followed at the five sites we visited. We learned about these practices
by interviewing officials at each site and reviewing pertinent
documents. To analyze the Army's effectiveness in communicating to
Congress and the public the approach used for making decisions to
pursue an OSD waiver, we compared and contrasted the OSD policy
[Footnote 12] that specifies that no major land acquisition proposals
may be made public through a request for proposals, notice of intent to
perform environmental analysis, request for legislation or budget item,
press release, or other official notice until OSD has approved a waiver
to the department's major land acquisition moratorium,[Footnote 13] and
the Army strategic plan that emphasizes that key stakeholders must be
engaged early in the strategic planning process and that the public
must be included in the decision-making process. We also discussed
communication strategies, approved waiver requests, and public outreach
efforts prior to OSD waiver approval with OSD and Army headquarters
officials and installation personnel at each of the five sites we
visited. We used Army and public records to develop a list of affected
groups and nongovernmental organizations that have supported or opposed
these acquisitions. From the list, we selected key groups and
landowners to meet with who had participated regularly in Army's
planning and acquisition processes prior to OSD waiver approval by
attending public outreach meetings or by providing written comments to
the Army. We did not meet with groups involved in ongoing litigation
associated with the acquisitions.
We conducted this performance audit from October 2007 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. See
appendix I for more information on our scope and methodology.
Results in Brief:
The Army uses an extensive, analytical approach to making decisions
regarding training land acquisitions, but the approach does not include
a process to ensure that the 2004 Range and Training Land Strategy--the
strategic plan Army officials use to address training land shortfalls-
-is current. The Army's approach uses as its basis this strategic plan
and the Army Range Requirements Model that was implemented in 2006. The
strategic plan stipulates that acquiring training land is one among
several ways to mitigate training land shortfalls, and the range
requirements model uses Army training doctrine and policy and data
elements from numerous databases that affect training land needs to
calculate training land requirements and shortfalls. Along with the
strategic plan and the range requirements model, the Army has a six-
step process during which training land shortfalls and capabilities are
analyzed in multiple ways, by multiple parties, and at multiple times.
However, although Army officials said that basing a strategic plan on
current information is essential for ensuring that major land
acquisitions respond to up-to-date training needs, the Army has not
updated its strategic plan since it was initially developed in 2004.
This is because the Army does not have a process to ensure that the
strategic plan is updated at regular intervals to reflect up-to-date
training land requirements resulting from recent initiatives, such as
Grow the Force,[Footnote 14] base realignment and closure (BRAC), and
Global Defense Posture realignments.[Footnote 15] In addition, while
the range requirements model calculates each installation's training
needs based on a variety of factors that include recent initiatives and
updates these data at regular intervals, the model's calculations are
not reflected in the strategic plan. As a result, the training land
needs articulated in the Army's strategic plan are now 4 years out of
date, diminishing the plan's effectiveness as a tool to ensure land
acquisitions are based on current training needs.
In an effort to support its request for a waiver to the department's
moratorium on major land acquisitions, the Army conducted an initial
conceptual analysis in which it identified potential alternatives to
and assessed environmental and economic effects of its acquisition of
training land at Fort Irwin, the three sites in Hawaii, and the Piņon
Canyon Maneuver Site. After OSD approved the waiver requests, the Army
addressed the National Environmental Policy Act of 1969 and the
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 proposed project
constitutes a major federal action significantly affecting the quality
of the human environment, a more detailed environmental impact
statement.[Footnote 16] Army officials stated that they developed and
issued an environmental impact statement addressing the potential
expansion at Fort Irwin. Army officials also developed and issued a
programmatic environmental impact statement and site-specific
environmental impact statement analyzing the impacts of the proposed
Army transformation of the 2nd Brigade, 25th Infantry Division to a
Stryker Brigade Combat Team, which included the acquisition of land
located at all three sites in Hawaii. The original environmental impact
statements pertaining to the Hawaii acquisitions were initially subject
to litigation, but Army officials stated that the Army has since
prepared a new site-specific environmental impact statement pursuant to
the court's order.[Footnote 17] However, Army officials stated that the
Army has not issued an environmental impact statement for the potential
expansion of the Piņon Canyon Maneuver Site. The Consolidated
Appropriations Act, 2008, 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 the boundaries or size of the
maneuver site.[Footnote 18] Army officials told us that upon the
passage of the act, they redirected contract employees that had been
working on the potential expansion efforts to instead support the
Army's response to Section 2831 of the National Defense Authorization
Act for Fiscal Year 2008, which required the Army to submit a report
containing several different elements of analyses regarding Piņon
Canyon, such as an analysis of whether existing training facilities at
Fort Carson and the Piņon Canyon Maneuver Site are sufficient to
support the training needs of the units stationed or planned to be
stationed at Fort Carson. Army officials said 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. The Army delivered the report required by the
National Defense Authorization Act for Fiscal Year 2008 to Congress in
July 2008. Army officials stated that because the funding restrictions
in the Consolidated Appropriations Act, 2008, and Division E, Title 1
of the Consolidated Security, Disaster Assistance, and Continuing
Appropriations Act, 2009,[Footnote 19] apply only to Military
Construction Appropriations, this does not preclude the Army from
further studying the 100,000-acre site or starting the National
Environmental Policy Act process using other appropriations. However,
the 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. The officials further
stated that uncertainty over congressional support for the contemplated
expansion made a delay in expending funds to start the National
Environmental Policy Act process appear to be prudent.
Because of a lack of specificity in OSD and Army communication
strategies, the Army has not been consistent or always effective in
communicating its approach for deciding to pursue acquisitions of
training land. According to OSD's policy, no major land acquisition
proposals may be made public through a request for proposals, notice of
intent to perform environmental analysis, request for legislation or
budget item, press release, or other official notice until OSD has
approved a waiver to the department's major land acquisition
moratorium. However, although OSD's policy clearly prohibits potential
major land acquisitions being publicized in the specific manner
described above, it is unclear what, if any, stakeholder notification
(such as informal community outreach) is permissible under OSD's policy
prior to waiver approval. OSD officials said they were concerned that
early public announcement of a potential land acquisition would be
misinterpreted as an approved acquisition and that early disclosure
would affect land values in and around the potential acquisition. On
the other hand, the Army's strategic plan emphasizes that it is
important to engage key stakeholders--people living near the potential
land acquisition site, elected officials, nongovernmental groups, and
others--early in the planning process and that the public must be
included in the decision-making processes, because early engagement is
a critical step in signaling the right message and sustaining positive
interaction with the public. However, the Army's strategic plan lacks
specificity as to when, and in what form, this early outreach should
take place. During the initial phase of the land acquisitions that took
place in California and Hawaii, when the Army was in the process of
preparing its submission to OSD for waiver approval, it followed the
communications strategy articulated in its strategic plan, which states
that early engagement is a critical step in sustaining positive
interaction with the public. In Hawaii, the Army also included a
congressional delegation and other stakeholders early in the planning
process and secured their support before the request for waiver to the
department's moratorium was submitted. However, for the potential
expansion of the Piņon Canyon Maneuver Site, the Army did not follow an
approach similar to that in the previous four acquisitions with regard
to early communication with key stakeholders. Army officials and
community groups we interviewed said that the Army did not adequately
explain its reasoning for the proposed expansion prior to obtaining OSD
waiver approval. Army officials at Fort Carson explained that, in their
view, OSD's policy precluded proposed major land acquisitions from
being made public in any manner and from being discussed until the
Secretary or Under Secretary approved a waiver to the department's
moratorium on major land acquisitions. Without adequate explanations,
key stakeholders at times relied on rumors and leaked documents. These
information sources often 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. Without a consistent and clarified DOD-
wide practice that both addresses OSD's concerns about early disclosure
of potential major land acquisitions and, at the same time, permits the
Army and the other military services some flexibility to engage key
stakeholders early in the decision-making process, the Army and other
military services are likely to experience communication problems
similar to those encountered during the potential expansion of the
Piņon Canyon Maneuver Site.
We are recommending that (1) the Army develop and implement a process
to update periodically its strategic plan--Range and Training Land
Strategy--to reflect current training needs and (2) OSD and the Army
jointly review their strategies for communicating potential major land
acquisitions to the public and agree upon a common practice that would
address OSD's concerns about early disclosure and, at the same time,
permit Army and the other military services some flexibility to engage
key stakeholders earlier in the decision-making process. In written
comments to a draft of this report, DOD generally agreed with our
recommendations. We discuss DOD's comments in detail later in this
report.
Background:
For decades, senior OSD and Army officials have reported that they face
increasing difficulties in carrying out realistic training at military
installations and training ranges due to training constraints, such as
those resulting from encroachment and emerging technological advances
that improve the capabilities of new weapons systems. One proposed
solution to overcome training difficulties has been to expand training
areas by acquiring, through purchase or lease, sufficient land adjacent
to the affected installations and training ranges. However, the Army's
efforts to acquire land have often been met with opposition from
individuals and groups who questioned the Army's justification for
pursuing the land expansions.
Training Land Shortfalls Can Be Addressed by a Variety of Strategies:
The Army reports that it will have a 4.5-million-acre shortfall in
training land by 2013 from the combined effects of the Global Defense
Posture realignments, Grow the Force initiative, BRAC actions, and Army
transformation and modularity.[Footnote 20] Still, Army officials
stated they have no plans to acquire 4.5 million acres of land in the
United States to meet this need, but rather plan to address the
training land shortfall through four major strategies identified in the
Army's 2004 strategic plan--the Range and Training Land Strategy. The
strategies include (1) focused land management; (2) acquisition of
buffers to mitigate encroachment; (3) utilization of other federal
lands; and (4) when necessary, land acquisition. The strategic plan
also serves as the mechanism to prioritize Army training land
investments and helps optimize the use of all Army range and training
land assets by determining the capability, availability, and
accessibility of land.
Management of Land Acquisition Process:
Within DOD, the Under Secretary of Defense for Acquisition, Technology,
and Logistics and the Deputy Under Secretary of Defense for
Installations and Environment prescribe policies and procedures
governing the acquisition of land for military use. Within the Army,
the Office of the Assistant Secretary of the Army for Installations and
Environment has responsibility for policy development, program
oversight, and coordination of a wide variety of Army activities,
including management of Army installations. Within this office, the
Deputy Chief of Staff for Operations is responsible for developing and
coordinating policy, programs, and initiatives to achieve the directed
levels of training readiness for the Army. As part of those
responsibilities, the Deputy Chief of Staff establishes priorities and
requirements for Army ranges and training lands. Under the Deputy Chief
of Staff, the Office of the Assistant Chief of Staff for Installation
Management is responsible for program management on all matters
relating to overall management of Army installations, including real
property inventory and budget authority for the execution of Army
installations' operations and of the U.S. Army Corps of Engineers'
military construction and land acquisition functions. The Installation
Management Command, under the Assistant Chief of Staff for Installation
Management, is responsible for ensuring efficient and effective base
operations services and facilities, including providing and maintaining
high-quality training areas, ranges, and facilities. U.S. Army
garrisons provide everyday management of the training areas and ranges.
The Army Management Office for Training Simulations is responsible for
the Army Range Requirements Model.
Moratorium on Major Land Acquisitions:
On September 13, 1990, OSD issued a departmentwide moratorium on major
land acquisitions--those exceeding 1,000 acres or costing more than $1
million--for installations in the United States. OSD updated and
provided further instruction on this moratorium on October 24, 1990;
December 1, 1994; November 17, 2002; and July 28, 2005. Currently,
waivers of this moratorium may be granted at the OSD level on a case-
by-case basis if a military service can justify to OSD a need to
acquire more land. Army guidance sets forth requirements regarding the
preparation and submission of a military land acquisition proposal,
which summarizes, where applicable, information detailed in the range
complex master plan, range development plan, and analysis of
alternatives study. The military land acquisition proposal is forwarded
to the major army command and coordinated with the appropriate
installation management agency, and the major command forwards the
information to the Chief, Training Support Systems Division for
staffing, coordination, and approval by the Deputy Assistant Secretary
(Installation and Housing). Army guidance further states that final
concept approval of the military land acquisition proposal must be
provided by the Under Secretary of Defense for Acquisition, Technology,
and Logistics before an installation issues any official notices to the
public, including a notice of intent or a finding of no significant
impact.
Army's Recent and Potential Major Training Land Acquisitions:
Since DOD's 2002 update to the moratorium on major land acquisitions,
the Army has proposed or completed the following five major training
land acquisitions:
* National Training Center at Fort Irwin, California. In December 2003,
OSD approved the Army's waiver request to acquire about 222,000 acres
of land to expand the National Training Center site. At that time,
about 110,000 acres of public land had already been withdrawn for
military purposes, and the Army initially planned to purchase an
additional 112,000 acres from private and state land owners. The
purpose of the additional training land is to create a second brigade-
sized maneuver corridor to be utilized to meet training requirements.
Army officials said that, after revising the maneuver area to support
endangered species management and other factors, they completed the
acquisition of a 49,000-acre parcel in 2006 and a 23,000-acre parcel in
2008. According to the Army, the acquisition of a 78,000-acre parcel is
scheduled to be completed in 2010.
* South Range, Schofield Barracks, Hawaii. In December 2002, OSD
approved the Army's waiver request to acquire an additional 1,402 acres
at the South Range of Schofield Barracks on the island of Oahu, Hawaii.
The stated purpose of the expansion was to support Army training
requirements including the designation of the 2nd Brigade, 25th
Infantry Division as a Stryker brigade combat team. According to the
Army, the land was needed to provide additional space for such things
as maneuver training and a brigade-size motor pool. In September 2004,
the United States of America filed a complaint for the taking of this
property under its power of eminent domain, and for the ascertainment
and award of just compensation to the parties in interest in the amount
of $15.9 million. While a Hawaiian citizens group sought to set aside a
stipulated judgment to finalize the condemnation of the South Range
acquisition area, the 9th Circuit Court of Appeals ruled in October
2006 that the condemnation could proceed without judicial interference,
[Footnote 21] but that the use to which the land may be put would be
determined pending compliance with the National Environmental Policy
Act in another 9th Circuit Court of Appeals decision related to the
original environmental impact statements analyzing the impacts of the
proposed Army transformation.[Footnote 22] Army officials stated that
the Army has since prepared a new site-specific environmental impact
statement pursuant to the court's order, and that they completed the
acquisition of this land.
* West Pohakuloa Training Area, Hawaii. In February 2004, OSD approved
the Army's waiver request to acquire 22,675 acres of land adjacent to
the Pohakuloa Training Area on the island of Hawaii. The Army had been
leasing the land and using it for training since the 1940s and the
owner wanted to sell it. The stated purpose of the expansion was to
support training requirements for the 25th Infantry Division, the
Hawaii Army National Guard, U.S. Army Reserve, the 3rd Marine Regiment,
and the Stryker Brigade Combat Team. After obtaining OSD waiver
approval, Army officials also developed and issued a programmatic
environmental impact statement and site-specific environmental impact
statement analyzing the impacts of the proposed Army transformation of
the 2nd Brigade to a Stryker Brigade Combat Team, which included the
acquisition of land located at all three sites in Hawaii. These
original environmental impact statements were initially subject to
litigation, but Army officials stated that the Army has since prepared
a new site-specific environmental impact statement pursuant to the
court's order. Further, Army officials stated that they completed the
acquisition of this land in 2006.
* Parcel 1010, Hawaii. In October 2001, OSD approved the Army's request
for a waiver to acquire 1,010 acres of land adjacent to the Pohakuloa
Training Area on the island of Hawaii. The Army had been leasing the
land and using it for training since the 1940s and the owner wanted to
sell it. The stated purpose of the expansion was to support training
requirements for the 25th Infantry Division. Subsequently, the 2nd
Brigade, 25th Infantry Division, was designated as a Stryker Brigade
Combat Team. After obtaining OSD waiver approval, Army officials also
developed and issued a programmatic environmental impact statement and
site-specific environmental impact statement analyzing the impacts of
the proposed Army transformation of the 2nd Brigade to a Stryker
Brigade Combat Team, which included the acquisition of land located at
all three sites in Hawaii. These original environmental impact
statements were initially subject to litigation, but Army officials
stated that the Army has since prepared a new site-specific
environmental impact statement pursuant to the court's order. Further,
Army officials stated that they completed this acquisition in 2006.
* Piņon Canyon Maneuver Site, Colorado. Located about 150 miles
southeast of Fort Carson, Colorado, the Piņon Canyon Maneuver Site
opened in 1985 and is a training asset for Fort Carson, other
installations, and National Guard and Reserve units in the area. The
maneuver site's 235,896 acres combined with Fort Carson's training
areas comprise maneuver training lands second only to the National
Training Center at Fort Irwin in size. However, according to the July
2008 Army report, the total population of soldiers at Fort Carson will
increase from 14,500 to 28,500 by 2011, when the majority of stationing
decisions resulting from the Grow the Force initiative, BRAC actions,
Global Defense Posture realignments, and Army transformation and
modularity are scheduled to be complete[Footnote 23]d. In February
2007, OSD approved the Army's request for a waiver to acquire an
additional 418,577 acres of land to expand Piņon Canyon Maneuver Site,
which drew criticism from some local landowners, elected officials, and
nongovernmental groups. 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 proposed to limit the potential acquisition of additional
training land to 100,000 acres lying south of the existing maneuver
site. The Army also proposed to acquire land from willing sellers;
invest in training facilities; and work with the local community on a
variety of cultural, land use, and land management issues.
Prior Reports on Army's Land Acquisitions:
In 1989 and 1991, we reported that the Army pursued land acquisitions
without a rational strategy and, therefore, the decision process for
Army land expansions was being made in isolation from the full range of
training land needs.[Footnote 24] We noted several shortcomings in the
Army's plans and procedures for establishing land acquisition
priorities, identifying land requirements, and examining alternatives.
At that time, the Army approach to land acquisitions was motivated by
targets of opportunity--land was being acquired when it was available.
This made it difficult for the Army to justify its land acquisition
efforts. We recommended that the Army develop an overall strategy to
guide its land acquisitions, which it did in its 2004 Range and
Training Land Strategy.
In 1998, an Army Audit Agency report reiterated our findings.[Footnote
25] Specifically, the audit agency reported that the process the Army
used to justify training land acquisitions did not provide a
comprehensive assessment of the Army's total land requirements.
Essentially, the process identified training land requirements as the
total shortfalls reported at each installation and, because the Army
had not established its total training land requirements and the
capabilities of the land it controlled, it could not adequately
evaluate acquisition requests and set priorities. The audit agency
recommended analyzing overall Army-wide land requirements and
establishing a priority system for land initiatives, which the Army
included in its 2004 Range and Training Land Strategy.
In 1999, a Rand Arroyo Center report assessed the Army's land policy
and approaches to fulfilling Army needs for training lands, including
establishing training land requirements.[Footnote 26] The report
concluded that the Army had developed a coherent land use strategy, but
that it was an implicit one and had not been explained inside or
outside the Army. The center recommended that the Army publish a
national land strategy to help clarify the need for land, which the
Army did in its 2004 Range and Training Land Strategy.
Army's Approach to Training Land Acquisitions Is Extensive, but Based
on a Strategic Plan That Is Outdated:
The Army's extensive, analytical approach to making decisions for
pursuing training land acquisitions is based on (1) the Army's
strategic plan for training ranges--Range and Training Land Strategy--
that Army officials use 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. The Army uses the strategic
plan and model as starting points for a complex, six-step process in
which decisions to pursue training land acquisitions are analyzed in
multiple ways, by multiple parties, and at multiple times to ensure
that the Army's pursuit of land acquisitions is based on an adequate
assessment of training land needs and existing capabilities. Missing
from this process, however, is a mechanism to ensure that the Army's
strategic plan is updated regularly to reflect changes in training land
requirements, such as those resulting from the Grow the Force
initiative, BRAC actions, and Global Defense Posture realignments.
Although these updates have never been incorporated in the strategic
plan, the range requirements model has been updated on a regular basis
since it was implemented Army-wide in 2006 to reflect changing
requirements resulting from major initiatives.
Army's Approach to Making Land Acquisition Decisions Is Based on the
Strategic Plan for Training Ranges and the Range Requirements Model:
The strategic plan for training ranges--Range and Training Land
Strategy--and the Army Range Requirements Model are the key tools the
Army uses in its approach to making decisions about land acquisitions.
The 2004 strategic plan identifies training land requirements and
shortfalls based on the results of the range requirements model at that
time, prioritizes the shortfalls, and describes four ways the Army
planned to address these shortfalls, one of which is training land
acquisition. Because the strategic plan is based on pre-2004 data, it
reflects requirements resulting from the Army's transformation to a
modular force, but does not reflect force structure changes announced
since then. The model calculates training land requirements and
shortages based on Army doctrine and policy and installation data and,
because its data are updated on a regular basis, the model reflects
force structure changes that have taken place since 2004, such as the
more recent Grow the Force initiative, BRAC actions, and Global Defense
Posture realignments. When the Army updates its strategic plan in the
future, Army officials said that it will use the model's calculations
as the basis to estimate training land requirements and shortfalls for
the updated plan.
The Army developed the Range and Training Land Strategy as the
strategic plan that Army planning and budgeting officials use to select
the most appropriate course of action to address training land
shortfalls at specific Army installations. Published by the Army in
2004, the strategic plan states that the Army will inventory its
training land assets, optimize the use of all range and land assets,
identify short-and long-term land acquisition opportunities, and
prioritize installations where acquiring land is both feasible and
affordable. The plan also provides a framework and methodology to
address training land needs through focused land management, buffering
through partnerships, utilization of other federal lands, and, where
possible, land acquisition. The Army is to purchase training land only
where the following conditions are present: large land holdings are
available, acquisition is cost effective, land is compatible with
environmental conditions and requirements, land is contiguous to
existing training facilities, and population density in the surrounding
area is low. According to Army officials, a strategic plan with a well-
defined approach to determining land requirements and basing those
requirements on up-to-date information is essential for ensuring that
major land acquisitions respond to training needs.
The Army Range Requirements Model provides a consistent and reasonable
framework for Army headquarters, major commands, and installations to
use to calculate training land capability and requirements at
individual installations--just one step in the Army's overall process
for determining land needs and acquiring land for training. The model
uses Army training doctrine in conjunction with data from seven
administrative and operational databases, such as range inventories,
unit locations, planned acquisitions, and training courses, to
calculate an installation's annual training requirements. These
requirements can indicate either an adequate supply of land and ranges,
a surplus, or a shortfall. In addition, the data used by the model to
calculate these requirements reflect training and land requirements
resulting from recent initiatives, including Army transformation and
modularity, the Grow the Force initiative, BRAC actions, and Global
Defense Posture realignments. Not reflected in the model are training
lands that are not used due to environmental and cultural
considerations and other factors, all of which the Army addresses
through separate analyses at the end of the model's calculation
process. As such, the model does not provide the entire analysis
required for validation of training land needs and is not intended to
do so. Appendix II describes the Army Range Requirements Model in more
detail.
Army's Approach to Deciding Whether to Pursue Training Land
Acquisitions Consists of Complex, Six-Step Process:
To ensure the Army's pursuit of land acquisition is justifiable and
based on need, the Army's uses a six-step process beginning with
consultation with the strategic plan and ending with the purchase of
training land. Figure 1 illustrates this process.
Figure 1: The Army's Six-Step Process for Determining Whether to Pursue
Training Land Acquisitions:
[Refer to PDF for image]
1) Consult strategic plan to address training land needs;
Army Headquarters: Develop range and training land strategy to
determine capability, availability, and accessibility of land.
Plan resources to support strategy (not site specific).
2) Analyze factors that determine land requirements;
Army Installation and Headquarters: Conduct requirements analysis in
three key steps:
1. Doctrinal Analysis”Army Range Requirements Model calculates total
requirements based on Army training standards and mission activities.
2. Operational Analysis”adjusts model‘s requirement to account for
factors, such as prior use of ranges and condition of facilities.
3. Sustainability Analysis”further adjusts requirement to account for
factors such as environmental restrictions and land use by other
services.
3) Determine whether to pursue OSD waiver;
Army Installation: Develop key documents that identify land assets and
prioritize projects, including land acquisition, based on results of
requirements analyses.
1. Range Complex Master Plan”current assets and future requirements
prioritized by fiscal year.
2. Range Development Plan”prioritized list of range modernization and
land acquisition projects.
Army Headquarters: Review installation‘s prioritized training land
projects, including range modernization and land acquisitions on annual
basis to determine whether to pursue land acquisition. Program
resources based on approved strategy (not site specific).
4) Request waiver to pursue land acquisition;
Army Installation: Develop a moratorium waiver request to pursue an
acquisition; includes preliminary justification, cost estimates,
environmental impacts, and alternatives.
Army Headquarters: Review moratorium waiver request, submit to OSD for
approval. If approved, program resources that are site specific.
OSD: Approve or reject moratorium waiver request; if rejected, process
ends.
If waiver request is denied, acquisition process ends.
If waiver is approved:
5) Conduct analyses in preparation for land acquisition;
Army Installation and Headquarters: Conduct comprehensive analysis in
accordance with National Environmental Policy Act. Compile key points
from analysis into proposal for Headquarters approval. Budget resources
for land acquisition.
Army Corps of Engineers: Prepare Real Estate Planning Report, including
a gross land appraisal.
OSD: Approve Army proposal, then request congressional approval to
acquire land.
6) Authorize acquisition and seek appropriated funds.
Congress: Approve or deny OSD request, authorize acquisition,
appropriate funds.
Army Headquarters: Authorize Army Corps of Engineers to purchase land.
Army Corps of Engineers: Acquire property”prepare appraisals, conduct
landowner meetings, perform relocation study, conduct negotiations, and
closing.
Source: GAO analysis of information provided by DOD.
[End of figure]
Each of the six steps in the boxes illustrated in figure 1 is discussed
below.
* Consult strategic plan to address training land needs. The strategic
plan advocates maximizing the capability, availability, and
accessibility of all Army training lands so that training land
shortfalls can be addressed in a number of ways, one of which is land
acquisition. The strategy serves as the mechanism to prioritize Army
training land investment and helps to optimize the use of all Army
range and training land assets.
* Analyze factors that determine land requirements. An Army
installation works with Army headquarters to determine land
requirements though doctrinal, operational, and sustainability
analyses. The Army Range Requirements Model completes a doctrinal
analysis using Army training doctrine and land data that determines
training land requirements. 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 model's calculation of training land
requirements is simply a baseline of what the Army needs and is not the
final result, because the model does not take into account certain
factors that can impact training, such as compliance with environmental
regulations, protection of cultural resources, and condition of
facilities. The operational and sustainability analyses adjust the
model's calculations to account for those factors that the model itself
does not consider. For example, outside the model, Army officials
complete an operational analysis by comparing the doctrinal requirement
to the current training land assets and the condition of the facilities
to determine which facilities included in the model's calculation are
not suitable for training due to environmental and cultural
considerations and other factors. These officials also complete a
sustainability analysis by comparing results from the doctrinal and
operational analyses to factors, such as the use of training lands by
other military services, to further refine the model's calculation of
the training land requirement.
* Determine whether to pursue OSD waiver. The results of the land
requirements analyses drive two key documents that identify land assets
and prioritize training land projects at an installation, including
potential land acquisitions. First, the range complex master plan is
updated annually and identifies an installation's current assets and
future requirements prioritized by fiscal year. Second, the range
development plan is a prioritized list of range modernization and land
acquisition projects that identifies training area users and their
training requirements based on Army doctrine and regulations, such as
Army's Sustainable Range Program.[Footnote 27] Army headquarters
reviews installation training projects, including range modernization
and training land acquisitions, on an annual basis to determine whether
a potential acquisition should be pursued.
* Request waiver to pursue land acquisition. The Army installation
prepares and coordinates a proposal for a major land acquisition in
order to request a waiver to the department's moratorium on major land
acquisitions and submits the request to Army headquarters for review
and approval.[Footnote 28] If the request is approved, Army
headquarters then submits the waiver request to OSD for approval to
proceed with the land acquisition. The waiver request includes detailed
information from the range complex master plan and the range
development plan, together with a preliminary justification for 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.
* Conduct analyses in preparation for land acquisition. If the waiver
request is approved by OSD, the Army completes the applicable
environmental analysis required by the National Environmental Policy
Act of 1969. Concurrently, the appropriate U.S. Army Corps of Engineers
district office prepares a real estate planning package, which includes
the real estate planning report, the gross land appraisal, legal
documents for title transfer, and other related documents. The district
office forwards the final real estate package to Army headquarters,
which then reviews the package and forwards it to OSD for final
approval.
* Authorize acquisition and seek appropriated funds. OSD then requests
congressional approval to acquire the land. If the request is approved,
Congress authorizes the land acquisition and appropriates the necessary
funds. Army headquarters authorizes the U.S. Army Corps of Engineers to
purchase the land and the Corps acquires the property after completing
a series of land appraisals, landowner meetings, relocation studies,
negotiations, and closings.
Strategic Plan Does Not Reflect Land Requirements Associated with
Recent Initiatives:
Although the Army's 2004 strategic plan for training ranges provides a
well-defined approach to determining land requirements, the plan does
not reflect the 4.5-million-acre training land shortfall that the Army
reported to Congress in July 2008. The Army developed the strategic
plan to address training land shortfalls resulting from the Army's
transformation to a modular force. However, because the Army does not
have a process in place to routinely and systematically update the
plan, the plan has not been updated since 2004 and does not include the
training land needs resulting from more recent initiatives, such as
those from the Grow the Force initiative, BRAC actions, and Global
Defense Posture realignments. In 2007, the Army announced its
participation in the Grow the Force initiative, which is expected to
increase the Army's troop strength by 74,200 soldiers by 2013 and add a
total of six infantry brigade combat teams. According to the Army, a
heavy brigade combat team requires 170,000 acres and an infantry
brigade combat team requires 112,000 acres to conduct a free-flowing
exercise. A free-flowing exercise area will allow a brigade combat team
to train without stopping to reposition forces during the training
event, enhancing realism and effectiveness. In addition, the Army must
implement the recommendations of the 2005 BRAC Commission by 2011. BRAC
stationing changes will concentrate Army units and service schools at
key installations. Under the Global Defense Posture realignments, units
are to be moved from overseas locations in Europe and Asia back to the
United States. As part of the initiative, the Army plans to implement
shorter rotations of forces to more remotely located forward operating
sites so that the troops can spend more time in the United States. This
latter initiative adds to the need for training land because there are
no new Army installations being created to accommodate these additional
soldiers in the United States. Although these recent initiatives have
never been incorporated into the strategic plan, the range requirements
model has been updated on a regular basis since it was established in
2002 to reflect the effects of these initiatives on training land
needs. As a result, the model may generally accurately identify the
training land requirements. However, the current strategic plan cannot
be used to address the full range of training land needs or to develop
the approach to acquiring additional land, because the plan is out of
date, omitting several significant force structure changes since 2004.
Army Considered Alternatives and Prepared Assessments of Environmental
and Economic Effects before Pursuing OSD Waiver Approval:
The Army considered alternatives and prepared assessments of the
environmental and economic effects of the proposed land acquisitions in
an effort to address the requirements of OSD and Army policies and
regulations before pursuing OSD waiver approval at Fort Irwin, three
sites in Hawaii, and the Piņon Canyon Maneuver Site. After OSD approves
the waiver request, the Army must also address the National
Environmental Policy Act of 1969 and the 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.[Footnote 29] Army officials
stated that they developed and issued an environmental impact statement
addressing the potential expansion at Fort Irwin. Army officials also
developed and issued a programmatic environmental impact statement and
site-specific environmental impact statement analyzing the impacts of
the proposed Army transformation of the 2nd Brigade to a Stryker
Brigade Combat Team,[Footnote 30] which included the acquisition of
land located at the three sites in Hawaii. These original environmental
impact statements were initially subject to litigation, but Army
officials stated that the Army has since prepared a new site-specific
environmental impact statement pursuant to the court's order.[Footnote
31] However, the Army has not yet started the analysis of potential
alternatives and effects pursuant to the National Environmental Policy
Act for the potential expansion of the Piņon Canyon Maneuver Site. Army
officials stated that because the funding restrictions in the
Consolidated Appropriations Act, 2008, and Division E, Title 1 of the
Consolidated Security, Disaster Assistance, and Continuing
Appropriations Act, 2009, apply only to Military Construction
Appropriations, this does not preclude the Army from using other
appropriations to further study the 100,000-acre site or starting the
National Environmental Policy Act process. However, the officials
stated that the Army has voluntarily declined to spend other
appropriated funds to begin the National Environmental Policy Act
process due to congressional concerns. The officials further stated
that uncertainty over congressional support for the potential expansion
made a delay in spending funds to start the National Environmental
Policy Act process appear to be prudent.
Requirements for Army to Consider Alternatives and Assess Environmental
and Economic Impacts before Acquiring Land:
Before proceeding with a major land acquisition, the Army performs
assessments of alternatives to the proposed land acquisition and of the
potential environmental and economic impacts in two phases. In the
first phase, the Army conducts initial conceptual assessments of the
alternatives, potential environmental impacts, and cost in order to
support the request for a waiver to the department's major land
acquisition moratorium. The second phase occurs after OSD approves the
waiver request when the Army conducts the assessments of alternatives
and potential environmental and economic impacts in an effort to
address requirements contained in the National Environmental Policy Act
of 1969 and the regulations established by the Council on Environmental
Quality.
DOD guidance requires that an economic analysis be used to help decide
among the alternative methods to acquire real property and provide
guidance to the military services on how to proceed with the economic
analysis.[Footnote 32] Army guidance for the acquisition of training
land provides overall guidance for Army installations and reiterates
DOD policy by requiring Army installations to, among other things,
evaluate the economic feasibility of each alternative for all potential
training land acquisition projects.[Footnote 33] In addition, the
regulation requires an assessment of anticipated environmental impacts
and requires that Army installations develop a major land acquisition
proposal document that includes, where applicable, a summary of the
feasibility analysis as well as a list of potential environmental
impacts that must be submitted to the Under Secretary of Defense for
Acquisition, Technology, and Logistics before an installation issues
any official notices to the public.
Following OSD approval, the Army is then required to address the
provisions of the National Environmental Policy Act of 1969. The act
establishes environmental policies and procedures that shall be
followed by all federal agencies to the fullest extent possible.
[Footnote 34] One such requirement states that federal agencies shall
"include in every recommendation or report on proposals for legislation
and other major Federal actions significantly affecting the quality of
the human environment, a detailed statement by the responsible
official" regarding: (1) the environmental impact of the proposed
action, (2) any adverse environmental effects which cannot be avoided
should the proposal be implemented, (3) alternatives to the proposed
action, (4) the relationship between local short-term uses of man's
environment and the maintenance and enhancement of long-term
productivity, and (5) any irreversible and irretrievable commitments of
resources which would be involved in the proposed action should it be
implemented.[Footnote 35] In accordance with these requirements and the
regulations for implementing the National Environmental Policy Act of
1969 established by the Council for Environmental Quality, agencies
evaluate the likely environmental effects of a project they are
proposing to undertake with an environmental assessment or, if the
projects likely would significantly affect the environment, a more
detailed environmental impact statement. If, however, the agency
determines that activities of a proposed project fall within a category
of activities the agency has already determined has no significant
environmental impact--called a categorical exclusion--then the agency
generally need not prepare an environmental assessment or 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 36]
Additionally, after preparing a draft environmental impact statement,
federal agencies such as DOD are required to obtain the comments of any
federal agency which has jurisdiction by law or certain special
expertise, and request the comments of appropriate state and local
agencies, Native American tribes, and any agency which has requested
that it receive such statements. 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. OSD officials stated that analyses conducted
pursuant to the National Environmental Policy Act of 1969 and its
associated regulations are more in-depth than those initially prepared
in order to obtain OSD waiver approval, and comprise the second phase
of the Army's process to consider alternatives and assess environmental
impacts.
Army Prepared Analyses Required to Obtain OSD Waiver Approval and the
Environmental Impact Statements for Fort Irwin Parcels and Hawaiian
Sites:
The Army prepared the analyses required to obtain OSD waiver approval
at Fort Irwin and the three sites in Hawaii. After obtaining OSD waiver
approval, the Army also issued an environmental impact statement
related to the expansion at Fort Irwin and environmental impact
statements related to the transformation of the 2nd Brigade, which
included the acquisition of land located at the three sites in Hawaii.
National Training Center at Fort Irwin, California:
In February 2003, the Army developed a request for a waiver to the
department's moratorium, stating that it needed an additional 222,000
acres in training land at Fort Irwin for an estimated cost of $34
million to meet doctrinal training requirements and reduce its maneuver
training land shortfall. The waiver request included an initial
analysis of the potential environmental impacts resulting from the
expansion, such as the loss of habitat for the desert tortoise and Lane
Mountain milk-vetch plant--both endangered species--and the Army
proposed to purchase some land elsewhere to be used to protect the
desert tortoise and the milk-vetch. The Army noted that no community
development had been planned for the area the Army wanted to acquire,
so it believed that economic impacts to the surrounding community would
be negligible. In addition, the Army considered alternatives to the
proposed land acquisition, such as expanding in different locations
adjacent to the National Training Center and taking no action.
Following OSD's approval of the waiver request, the Army developed a
final environmental impact statement for the proposed acquisition,
which provided a description of alternatives, such as modifications to
the amount of land to be acquired and a no action alternative. The
environmental impact statement reiterated the conclusions of the
initial analyses in regards to the environmental impacts, noting that
the potential losses of the desert tortoise and Lane Mountain milk-
vetch plant were the most significant consequences to the environment.
However, the Army proposed various mitigation efforts and concluded
that any costs of such mitigation efforts should be offset by the value
added to the National Training Center's mission. The Army also
considered economic impacts in the environmental impact statement,
indicating that any private property acquired by the Army would
restrict future private and commercial development. Further, the Army
considered constructing improvements to the area prior to training
there through private subcontractors in the surrounding community.
However, the Army considered that any potential economic impacts from
increased employment and revenue to the area from this construction
would not be significant due to the short-term nature of the contracts.
The Army also considered alternatives to the acquisition for the
environmental impact statement, such as expanding in different
locations near Fort Irwin and a no action alternative. Army officials
said that they completed the acquisition of a 49,000-acre parcel in
2006 and a 23,000-acre parcel in 2008. According to the Army, the
acquisition of a 78,000-acre parcel is scheduled to be completed in
2010.
South Range, Schofield Barracks, Hawaii:
For the expansion of South Range, the Army requested a waiver to
department's moratorium in August 2002 to acquire 1,402 acres for an
estimated $21 million to meet doctrinal training requirements resulting
from Army transformation and from the establishment of the Stryker
brigades in Hawaii. The request included an initial analysis of the
impacts resulting from the expansion, which indicated that the
acquisition of the land itself would not have any significant impact on
the environment or economy. In addition, the Army considered
alternatives, such as using training ranges at Fort Lewis, Washington,
and the National Training Center at Fort Irwin, California; employing
computer-based simulation; and taking no action.
Following OSD's approval of the waiver request, the Army prepared and
issued a programmatic environmental impact statement in February 2002
and a site-specific environmental impact statement in May 2004
analyzing the impacts of the proposed Army transformation of the 2nd
Brigade to a Stryker Brigade Combat Team (the proposed transformation
included the acquisition of land located at South Range at Schofield
Barracks) with an associated record of decision following in July 2004
that recommended the transformation of the 2nd Brigade in Hawaii to a
Stryker Brigade Combat Team.
In September 2004, the United States of America filed a complaint for
the taking of the property under its power of eminent domain, and for
the ascertainment and award of just compensation to the parties in
interest in the amount of $15.9 million. Although a Hawaiian citizens
group sought to set aside a stipulated judgment to finalize the
condemnation of the South Range acquisition area, the 9th Circuit Court
of Appeals ruled that the condemnation could proceed without judicial
interference,[Footnote 37] but that the use to which the land could be
put would be determined pending compliance with the National
Environmental Policy Act in another 9th Circuit Court of Appeals
decision pertaining to the environmental impact statements prepared for
the transformation of the 2nd Brigade, which is discussed below. Army
officials said that they completed the acquisition of this land in
2006.
Following the issuance of the site-specific environmental impact
statement and record of decision referenced above, several Hawaiian
citizen groups brought action against DOD and the Army in the U.S.
District Court, Hawaii, alleging inadequate environmental review of the
Army's transformation of the combat teams. The U.S. District Court
ruled, in part, that the programmatic and site-specific environmental
impact statements fulfilled the National Environmental Policy Act
requirements.[Footnote 38] The Hawaiian citizens group appealed the
District Court's decision, and the U.S. Court of Appeals for the 9th
Circuit affirmed the district court's denial of summary judgment to the
Hawaiian citizens groups on their claim that the defendants did not
satisfy the National Environmental Policy Act's notice requirements,
but reversed the District Court's decision with respect to its finding
that the environmental impact statements considered all reasonable
alternatives to the transformation of the 2nd Brigade in Hawaii, and
remanded the action to DOD and the Army to prepare a supplemental site-
specific environmental impact statement with attention to alternative
locations.[Footnote 39] Army officials stated that the Army has since
prepared a new environmental impact statement pursuant to the court's
order.
West Pohakuloa Training Area, Hawaii:
For the acquisition at the Pohakuloa Training Area, the Army submitted
a waiver request to the department's moratorium in July 2003. At that
time, the Army indicated that it wanted to acquire 22,675 acres of
training land adjacent to Pohakuloa Training Area for an estimated
$15.3 million to address doctrinal training requirements from Army
transformation and to help address a training land shortfall of 32,249
acres in Hawaii. The request included an initial analysis of the
potential environmental and economic impacts resulting from the
expansion, which indicated that increased dust, vehicle emissions,
surface runoff, and erosion may occur due to the potential expansion.
The request identified budgetary savings through the avoidance of costs
associated with transporting troops from Hawaii to other training
locations, such as those at Fort Lewis, Washington, and Fort Chaffee,
Arkansas, although the Army did not elaborate on these costs.
Following OSD's approval of the waiver request, the Army prepared and
issued a programmatic environmental impact statement in February 2002
and a site-specific environmental impact statement in May 2004
analyzing the impacts of the proposed Army transformation of the 2nd
Brigade to a Stryker Brigade Combat Team (the proposed transformation
included the acquisition of land located at the Pohakuloa Training
Area, as well as land located at the other two Hawaii sites discussed
in this report) and an associated record of decision in July 2004 that
recommended the transformation of the 2nd brigade in Hawaii to a
Stryker Brigade Combat Team. These environmental impact statements were
subject to litigation, as discussed above, and the U.S. Court of
Appeals for the 9th Circuit ultimately directed DOD and Army to prepare
a supplemental site-specific environmental impact statement with
attention to alternative locations. Army officials stated that the Army
has since prepared a new environmental impact statement pursuant to the
court's order, and that they have acquired this land.
Parcel 1010, Hawaii:
For the Parcel 1010 acquisition, the Army developed a waiver request in
September 2001. In the request, the Army stated that it wanted to
acquire an additional 1,010 acres of Parcel 1010 for an estimated $1.5
million that the Army had been leasing since the 1940s. The request
included an initial analysis of the potential environmental effects of
the potential expansion, which stated that increased dust, vehicle
emissions, surface runoff, and erosion may occur due to expansion. The
Army reported that acquiring the land was most the viable option
because, if the property was sold for nonmilitary use, the Army would
have to clear it for unexploded ordnance, which would cost $14 million.
No economic impacts were identified from the proposed Parcel 1010
acquisition in the waiver request. The Army also considered
alternatives to the acquisition, such as using other military
installations and computer-based simulation for training, restationing
of units, and taking no action in its waiver request.
Following OSD's approval of the waiver request, the Army prepared and
issued a programmatic environmental impact statement in February 2002
and a site-specific environmental impact statement in May 2004
analyzing the impacts of the proposed Army transformation of the 2nd
Brigade to a Stryker Brigade Combat Team (the proposed transformation
included the acquisition of land located at Parcel 1010, as well as
land located at the other two Hawaii sites discussed in this report),
and an associated record of decision in July 2004 that recommended the
transformation of the 2nd Brigade in Hawaii to a Stryker Brigade Combat
Team. These environmental impact statements were subject to litigation,
as discussed above, and the U.S. Court of Appeals for the 9th Circuit
ultimately directed DOD and Army to prepare a supplemental site-
specific environmental impact statement with attention to alternative
locations. Army officials stated that the Army has since prepared a new
environmental impact statement pursuant to the court's order, and that
they acquired this land in 2006.
Army Conducted Initial Analyses to Pursue the Acquisition at Piņon
Canyon Maneuver Site:
In July 2006, the Army completed the initial analysis for deciding
whether to pursue the acquisition of training land at the Piņon Canyon
Maneuver Site and used the results of this analysis to support its
request for a moratorium waiver. The Army indicated that it needed up
to 418,577 acres of additional land in order to support doctrinal
training requirements and to replicate the conditions of potential
combat theaters. The request included an initial analysis of the
potential environmental impacts, such as erosion and dust problems,
cleanup of possible contaminated sites prior to training use, water
quality concerns, and damage to cultural sites. The request also
identified potential economic impacts that could result from the
acquisition--including the loss of tax base and threat to the ranching
economy--but did not attach a dollar amount to the impacts. In
addition, the Army considered alternatives to the proposed acquisition,
such as the use of the training ranges at Camp Guernsey, Wyoming;
Yakima Training Center, Washington; and Fort Irwin, California; use of
computer-based simulation; expanding nearby Fort Carson training
ranges; purchase or lease of smaller, noncontiguous sites; and taking
no action.
Although OSD approved the waiver request, the Consolidated
Appropriations Act, 2008, 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 the boundaries or size of the
Piņon Canyon Maneuver Site. Army officials told us that upon the
passage of the act, they redirected contract employees that had been
working on the potential expansion efforts to instead support the
Army's response to Section 2831 of the National Defense Authorization
Act for Fiscal Year 2008, which required the Army to submit a report
containing an analysis of whether existing training facilities at Fort
Carson and the Piņon Canyon Maneuver Site are sufficient to support the
training needs of units stationed or planned to be stationed at Fort
Carson, a report of need for any proposed addition of training land to
support units stationed or planned to be stationed at Fort Carson, and
an analysis of alternatives for enhancing economic development
opportunities in southeastern Colorado at the current site or through
any proposed expansion. Army officials told as 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. The Army delivered the report required by the
National Defense Authorization Act for Fiscal Year 2008 to Congress in
July 2008. After reassessing its initial plans, the Army reported that
it now identifies a potential acquisition of 100,000 acres rather than
the previously identified 418,577 acres for a variety of reasons
including budgetary restraints, concerns about historic and culturally
sensitive sites, and that a smaller expansion would affect a fewer
number of landowners. According to Army officials, because the funding
restrictions in the Consolidated Appropriations Act, 2008, and Division
E, Title 1 of the Consolidated Security, Disaster Assistance, and
Continuing Appropriations Act, 2009, apply only to Military
Construction Appropriations, this does not preclude the Army from
further studying the 100,000-acre site or starting the National
Environmental Policy Act process using other appropriations. However,
the officials stated that, to date, the Army has voluntarily declined
to spend funds to begin the National Environmental Policy Act 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 National Environmental Policy
Act process appear to be prudent.
Army Has Not Always Been Effective in Communicating Its Approach to
Training Land Acquisitions:
Because of the lack of specificity in OSD and Army communication
strategies, the Army has not been consistent or always effective in
communicating its approach for deciding to pursue acquisitions of
training land. According to OSD's policy, no major land acquisitions
may be made public through a request for proposals, notice of intent to
perform environmental analysis, request for legislation or budget line
item, press release, or other official notice without OSD approval.
While OSD's policy clearly prohibits potential major land acquisitions
being publicized through the official notices described above, it is
unclear what, if any, stakeholder notification (such as informal
community outreach) is permissible under OSD's policy prior to OSD
waiver approval. OSD officials said they were concerned that early
public announcement of a potential land acquisition would be
misinterpreted as an approved acquisition and that early disclosure
would affect land values in and around the potential acquisition. On
the other hand, the Army has a communication strategy that emphasizes
stakeholder involvement. Specifically, in its strategic plan, the Army
states that key stakeholders--people living near the potential land
acquisition site, elected officials, nongovernmental groups, and
others--must be engaged early in the planning process and that the
public must be included in the decision-making processes because early
engagement is considered a critical step in communicating its message
and sustaining positive interaction with the public. However, the Army
strategic plan lacks specificity as to when, and in what form, this
early outreach should occur.
During recent and ongoing land acquisitions, the Army inconsistently
implemented these OSD and Army communication strategies prior to
obtaining OSD waiver approval. In the cases of Fort Irwin and at the
three sites in Hawaii, the Army involved stakeholders before OSD
granted waivers to its land acquisition moratorium. At Fort Irwin, Army
officials said that a congressional delegation was involved in planning
and determining which land areas were to be acquired and that they had
met with landowners and local groups before the Army submitted its
waiver request. Similarly, Army officials involved key stakeholders
early in the planning process for the acquisition of training land in
Hawaii. According to Army officials, support from a congressional
delegation was obtained before the waiver requests were submitted.
Also, the landowners in the three acquisitions were willing sellers
that worked with the Army to actively communicate with and engage the
support of people living near the potential land acquisition sites,
elected officials, and nongovernmental groups. Army officials stated
that open communication with the public during the initial phase of the
acquisition process allowed them to proceed with the acquisitions with
the support of key stakeholders.
By contrast, in the case of the potential expansion of the Piņon Canyon
Maneuver Site, while Army officials informed the congressional
delegation that the Army was considering a potential expansion of the
maneuver site, it did not inform the public of its land acquisition
plans until after OSD approved the Army's request for a waiver to
pursue the expansion. While OSD's policy clearly prohibits potential
major land acquisitions being made public through a request for
proposals, notice of intent to perform environmental analysis, request
for legislation or budget line item, press release, or other official
notice, it is unclear what, if any, stakeholder notification (such as
informal community outreach) is permissible under OSD's policy prior to
OSD waiver approval. Army officials at Fort Carson said that, in an
effort to comply with OSD policy, they did not communicate openly with
the public or fully explain the Army's reasoning for the proposed
expansion prior to OSD waiver approval. These officials explained that,
in their view, OSD's policy required that proposed land acquisitions
not be made public or discussed in any way until after OSD had approved
a moratorium waiver. Affected landowners and community groups at times
relied on rumors and leaked documents as their only available source of
information, but these sources did not necessarily 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. For example, some
landowners and community groups near Piņon Canyon incorrectly assumed
that the Army's initial consideration of potential alternatives to the
land acquisition and assessment of the environmental and economic
impacts constituted the Army's final analysis justifying the expansion.
In another example, a coalition of nearby landowners approached the
Army in the fall of 2006 with inquiries about a leaked map, proposing a
1-million-acre expansion of the Piņon Canyon Maneuver Site. Army
officials explained to the Colorado citizens that the leaked map was a
planning map and did not represent Army's intentions for expansion.
However, coalition members stated their belief that the map represented
the Army's long-range land acquisition plan. They also said that the
Army's message was not consistent with the lack of a decision to pursue
land acquisition at other installations, such as Fort Hood, Texas, and
Fort Stewart, Georgia, where large numbers of Army units are located
and trained. Coalition members explained that training land shortages
existed at these installations and yet, the Army has not proposed
acquisition of additional training land at either installation.
[Footnote 40]
Army officials said that they could not fully explain their reasoning
in concluding that the proposed Piņon Canyon expansion was justified
because of OSD's policy restricting public disclosure and that the
Army's silence may have been misinterpreted as an unwillingness to
explain the Army's needs and plans. Without a consistent and clarified
DOD-wide practice that both addresses OSD's concerns about early
disclosure of potential major land acquisitions and, at the same time,
permits the Army and the other military services some flexibility to
engage key stakeholders early in the decision-making process, the Army
and other military services are likely to experience communication
problems similar to those encountered during the acquisition of
additional land at the Piņon Canyon Maneuver Site.
Conclusions:
The Army has improved its land acquisition process in recent years so
that it has a rational approach for determining land requirements and
alternatives rather than relying on targets of opportunity as it did in
the past when making major land acquisition decisions. However, the
Army's 2004 strategic plan for training ranges does not reflect up-to-
date training land needs, such as those associated with the Grow the
Force initiative, BRAC actions, and Global Defense Posture
realignments. Without a current strategic plan, Army officials charged
with planning and budgeting do not have a priority list of training
land shortages that helps them to strategically address these
shortages. The training land needs articulated in the 2004 strategic
plan are out of date because the Army does not have a process to
routinely and systematically update the plan. As a result, the
strategic plan has not been updated. Therefore, training land needs
articulated are 4 years out of date and will remain so, diminishing the
plan's effectiveness as a tool to ensure land acquisitions are based on
current training needs.
Because of the lack of specificity in OSD and Army communication
strategies, the Army has not been consistent or always effective in
communicating its approach for deciding to pursue acquisitions of
training land during the initial phase of the process. While early and
open communication helped the start of the acquisition process at Fort
Irwin and the three sites in Hawaii, the type of miscommunication that
occurred in the case of the proposed Piņon Canyon Maneuver Site
expansion before OSD waiver approval contributed to the opposition the
Army experienced in explaining to the public the justification for the
acquisition of training land at the site. Because OSD's policy states
that no major land acquisitions may be made public through a request
for proposals, notice of intent to perform environmental analysis,
request for legislation or budget line item, press release, or other
official notice without OSD approval of the moratorium waiver during
the land acquisition process, the Army has sometimes felt it has been
unable to adequately address the views and concerns of key
stakeholders--people living near the proposed land acquisition site,
elected officials, nongovernmental groups, and others--during the
initial phase of the acquisition process when explaining its reasons
that a potential land acquisition is justified. Furthermore, while
OSD's policy clearly prohibits potential major land acquisitions being
publicized through the official notices described above prior to waiver
approval, it is unclear what, if any, stakeholder notification (such as
informal community outreach) is permissible under OSD's policy prior to
OSD waiver approval. Without a consistent and clarified DOD-wide
practice that both addresses OSD's concerns about early disclosure of
potential major land acquisitions during the initial phase of the
process and, at the same time, permits the Army and the other military
services some flexibility to engage key stakeholders early in the
decision-making process, the Army and other military services are
likely to experience communication problems similar to those
encountered during the potential acquisition of additional land at the
Piņon Canyon Maneuver Site.
Recommendations for Executive Action:
To help planning and budgeting officials prioritize their efforts to
mitigate training land shortages and to improve the effectiveness with
which the military services communicate their approach for deciding
whether to pursue major training land acquisitions, we recommend that
the Secretary of Defense take the following two actions:
* Direct the Secretary of the Army to develop and implement a process
to update periodically its strategic plan--the Range and Training Land
Strategy--to reflect current training land needs.
* Direct the Under Secretary of Defense for Acquisition, Technology,
and Logistics and the Assistant Secretary of the Army for Installations
and Environment to jointly review their strategies for communicating
potential major land acquisitions to the public prior to OSD waiver
approval and agree upon a common practice that would address OSD's
concerns about early disclosure and, at the same time, permit the Army
and the other military services some flexibility to engage key
stakeholders--people living near the proposed land acquisition site,
elected officials, nongovernmental groups, and others--earlier in the
decision-making process. Such a common practice should specifically
address what kinds of public outreach, if any, are permissible prior to
OSD's waiver determination.
Agency Comments and Our Evaluation:
The Deputy Under Secretary of Defense (Installations and Environment)
provided written comments to a draft of this report. DOD's comments are
reprinted in their entirety in appendix III. DOD generally agreed with
our recommendations, although it did not indicate what, if any,
specific steps it would take to implement them.
In commenting on our recommendation for the Army to develop and
implement a process to update periodically its strategic plan, DOD
stated that the Army agrees with the recommendation, but DOD expressed
concern that the title of the report and the discussion on the
highlights page create the impression that the land acquisitions at the
Piņon Canyon Maneuver Site and in Hawaii were unsound or not valid. We
did not assess the soundness or validity of the Army's proposed or
completed land acquisitions. However, to ensure the Army's pursuit of
land acquisition is justifiable and based on need, we identified and
assessed the Army's six-step process beginning with the strategic plan
and ending with the purchase of training land. DOD also commented that
the Army's strategic plan was not out of date when the Army developed
the Piņon Canyon Maneuver Site expansion proposal in 2006 and explained
that the Grow the Army initiative had not been announced by the time
that the Army prepared the 2004 strategic plan.[Footnote 41]
Nonetheless, as we stated in our draft report, the BRAC and Global
Defense Posture realignments had been announced, directly affected Fort
Carson, and were being implemented after 2004 but before the 2006 Piņon
Canyon planned expansion was announced, thus the strategic plan was out
of date by 2006 even though the Grow the Army initiative was still to
be announced. Moreover, the Grow the Army initiative adds to the degree
of change not reflected in the Army's current 2004 strategic plan, thus
the need for the update as we recommended. In its comments on a draft
of this report, DOD did not indicate what, if any, specific steps it
would take to implement this recommendation. Hence, we continue to
believe that the Army should make plans in a timely manner to develop
and implement a process to update periodically its strategic plan to
reflect current training land needs.
DOD also commented that the draft report did not accurately reflect
Army officials' statements to us regarding congressional funding
restrictions involving the proposed Piņon Canyon Maneuver Site
expansion and proposed revised language to clarify the Army' position
on the restrictions. We have revised our report to respond to this
comment.
In commenting on our recommendation for a review of OSD and Army
strategies for communicating potential major land acquisitions to the
public prior to OSD waiver approval, DOD stated that when outreach is
desired in advance of waiver approval, the Deputy Secretary of Defense
or Under Secretary of Defense for Acquisition, Technology and Logistics
can approve early disclosure and permit the military services to engage
key stakeholders, elected officials, nongovernmental groups, and others
early in the decision-making process. While we recognize that the DOD
instruction permits some early engagement with stakeholders through a
process for requesting a waiver to the prohibition on early engagement,
our work showed that the Army's strategy is in conflict with DOD's
instruction, as we stated in our draft report. Due to the conflicts we
identified, we continue to believe that effective coordination of OSD's
and Army's policies will help to avoid such problems in the future,
hence the need for our recommendation.
We are sending copies of this report to the Secretary of Defense; the
Secretaries of the Army, the Navy, and the Air Force; the Commandant of
the Marine Corps; and the Director, Office of Management and Budget.
The report will be available at no charge on our Web site at
[hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, 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. The GAO staff members who made key
contributions to this report are listed in appendix III.
Signed by:
Brian J. Lepore, Director:
Defense Capabilities and Management:
[End of section]
Appendix I: Scope and Methodology:
In conducting our work, we met with and obtained data from officials in
the Office of the Under Secretary of Defense, Acquisitions, Technology,
and Logistics, and the Department of the Army. We limited our review to
those major training land acquisitions that the Army undertook or that
had been ongoing since the Office of the Secretary of Defense (OSD)
updated its policy moratorium on major land acquisitions in 2002. The
Department of Defense (DOD) defines "major land acquisitions" as those
larger than 1,000 acres or costing more than $1 million. Our initial
research found that because land values vary widely in the United
States, small land parcels in big cities would be compared with much
larger ones in other areas. Therefore, in an effort to make a more
accurate comparison of land acquisitions, we focused on acquisitions
and proposed acquisitions larger than 1,000 acres since DOD's updated
policy on the moratorium went into effect in November 2002, which
included the National Training Center at Fort Irwin, California; South
Range, West Pohakuloa Training Area, and Parcel 1010 in Hawaii; and
Piņon Canyon Maneuver Site, Colorado. We did not include the Navy,
Marine Corps, or Air Force in this review, because they had no major
land acquisitions in process or planned at the time of our review.
To evaluate the Army's approach for making decisions regarding the
acquisition of training land, we evaluated DOD regulations that govern
land acquisition and Army directives, policies, and procedures that
implement and clarify DOD's land acquisition regulations. To determine
whether Army land acquisition plans link acquisitions to requirements,
we compared OSD and Army strategic training ranges reports and the
training requirements mentioned in them with the Army's ability to meet
such requirements with the major training land acquisitions made or
ongoing since 2002. We also met with OSD and Army officials to discuss
the link between ongoing and planned acquisitions and current and
future training requirements and the Army's approach for making
decisions regarding the acquisitions in California and Hawaii and
potential expansion of the Piņon Canyon Maneuver Site. To identify the
benefits of the land acquisitions firsthand, we visited Fort Irwin,
California; South Range, West Pohakuloa Training Area, and Parcel 1010
in Hawaii; and Piņon Canyon Maneuver Site, Colorado. To evaluate how
the Army determined land acquisition requirements at each site, we met
with Army officials to discuss the procedures they followed and
challenges encountered during the land acquisition process and develop
a chronology of the process. Further, we met with officials from the
U.S. Army Corps of Engineers headquarters in Washington, D.C.; the
Hawaii District at Fort Shafter, Hawaii; and the Los Angeles District,
Los Angeles, California, to determine the steps taken to purchase the
land once the waiver request is granted.
In addition, we identified the methods Army planning and budgeting
officials use to address training shortfalls and evaluated the Army
Range Requirements Model--the Army's analytically based approach for
calculating training land requirements and shortages. Specifically, we
examined the Army's strategic plan for training ranges--Range and
Training Land Strategy. We also examined the training doctrine and
policy, data elements, and formulas used in the Army Range Requirements
Model--the Army's analytically based approach for calculating training
land requirements and any shortages. To determine whether the range
requirements model provided a consistent and reasonable framework for
estimating training land requirements and whether it used accurate
inputs, we reviewed the documentation supporting the range requirements
model's analytic framework--including the model's calculations and
assumptions--and identified the methods Army planning and budgeting
officials use to address training shortfalls. To determine whether the
Army complied with the DOD guidelines in the development, testing, and
validation of the range requirements model, we met with subject matter
experts who developed the model's methodology, including Army officials
and contractors. We also interviewed and obtained information from
representatives of key data systems that provide data to the model
including the Army's Operational Range and Inventory Sustainment
database, the Army Stationing and Installation Plan, the Training
Ammunition Management Information System, the National Guard Bureau
Unit Training Database, the Army Reserve Unit Training System, the Army
Training Requirements and Resources System, and the Army Master Range
Plan. We evaluated the justifications for and consistency of the Army's
adjustments and modifications, if any, to estimates of training range
land requirements and shortfalls computed by the model and the specific
rationale for determining training land requirements and shortfalls at
Fort Irwin, the three sites in Hawaii, and Piņon Canyon Maneuver Site.
To determine the reliability of the annual requirements estimates
generated by the range requirements model, we reviewed the
documentation supporting the model's analytic framework--including the
model's inputs, calculations, and assumptions--to determine whether the
model provides a consistent and reasonable framework for estimating
training land requirements. In addition, we assessed the accuracy of
the model's key inputs--such as the range inventory and the unit
training requirements. Although we found that there are minor effects
on the model's estimates based on inaccuracies or discrepancies in the
model's input data sources, we believe the model provides reasonable
information for use as a part of the Army's overall process for
determining land needs and acquiring land for training. Regarding range
inventory, we reviewed DOD regulations that require periodic
verification of the accuracy of range inventory information, determined
the extent to which the Army had complied with these regulations, and
discussed with Army officials any reasons for noncompliance. During our
site visits, we compared the range inventory information contained in
selected installation property records with the range inventory
information used by the model and had Army installation officials
explain any discrepancies. We discussed and corroborated our
observations on the Army's policies and procedures used to determine
training land requirements during meetings with OSD, Army headquarters,
and installation officials.
To determine whether the Army considered potential alternatives to
acquiring training land and the potential environmental and economic
effects before deciding to pursue OSD waiver approval, we reviewed OSD
guidance and Army policies, procedures, and practices for acquiring
land and compared them with the actual practices followed at the sites
we visited. We identified the requirements to consider alternatives and
the environmental and economic effects by reviewing OSD guidance on
requesting waivers to the department's major land acquisition
moratorium and OSD and Army guidance that prescribe the training land
acquisition process. We also reviewed the requirements of the National
Environmental Policy Act of 1969. We learned about the actual practices
followed by interviewing Army headquarters officials and officials at
Fort Irwin, the three sites in Hawaii, and Piņon Canyon Maneuver Site.
At each site visited, we documented and reviewed the initial conceptual
analysis the Army conducted to support requests for waivers to the
department's major land acquisition moratorium and to evaluate
potential alternatives, possible environmental effects, and costs. We
discussed our observations with Army officials to ensure that our
observations effectively addressed actual practices.
To analyze the Army's effectiveness in communicating to Congress and
the public the approach used for making decisions to pursue OSD waiver
approval, we discussed approved waiver requests and public outreach
efforts with officials from OSD, Army headquarters, and officials at
each site we visited. We reviewed OSD and the Army communication
strategies to identify their differences, Army documents and public
records to identify public questions and concerns, and evaluated the
Army's responses to the public. In addition, we reviewed Army documents
and public records to identify a list of affected groups and
nongovernmental organizations that have supported or opposed the
acquisitions in California, Hawaii, or Colorado. From the list, we met
with key groups and landowners who have participated regularly in
Army's planning and acquisition processes by attending public outreach
meetings or by providing written comments about an acquisition to the
Army. We documented Army responses to groups opposed to the land
acquisitions by interviewing Army and installation officials at Fort
Irwin, California; Fort Shafter, Schofield Barracks, and Wheeler Air
Force Base, Hawaii; and Fort Carson, Colorado. We also interviewed
members of the Sierra Club and Defenders of Wildlife in California and
the Piņon Canyon Expansion Opposition Coalition in Colorado to
determine their reasons for opposing the land acquisitions and obtain
their suggestions for improving the Army's approach to communicating to
Congress and the public. We did not meet with groups involved in
ongoing litigation associated with the acquisitions. We discussed our
observations with OSD and Army officials to obtain their perspective on
our initial observations and obtain their suggestions for improving the
Army's effectiveness in communicating the approach it uses for making
decisions to pursue major land acquisitions.
We conducted this performance audit from October 2007 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: Army Range Requirements Model:
The Army Range Requirements Model provides a consistent and reasonable
framework for Army headquarters, major commands, and installations to
use to calculate training land requirements--just one step in the
Army's overall process for determining land needs and acquiring land
for training. The model calculates the amount of land and the number of
days needed to complete training tasks by using the Army training
doctrine and policy in conjunction with input data from seven of the
Army's administrative and operational databases. The Army has several
quality assurance safeguards to ensure that the model is reliable and
updated regularly to help ensure that input data are accurate. The
process to update the model includes multilevel reviews by the Army
Management Office for Training Support Systems Division, subject matter
experts, and authorized users of the model, such as range and training
managers, that check for discrepancies between prior and updated
calculations and current conditions at individual installations. With
respect to the input data used by the model, Army officials are aware
of weaknesses associated with some of the Army's administrative and
operational databases that provide these data and routinely take steps
to mitigate their effect on the model's calculations. For example,
users have the opportunity to review the model's calculations and data
for accuracy and discrepancies and to address any issues. If any
inaccuracies or discrepancies in the data sources are identified, users
can extract the model data, request the data source program managers to
make the necessary modifications and corrections, recalculate the
training land needs, and send the recalculations to the model's program
office for validation and correction. As a result, we believe the
effects of the minor weaknesses in the Army's administrative and
operational databases on the model's calculations of the overall
training land needs are minimal.
Army Range Requirements Model Uses Multiple Inputs to Determine
Training Land Requirements:
Using Army's training doctrine and policy as its basis, the Army Range
Requirements Model uses data from seven administrative and operational
databases that provide information on training range inventories, unit
locations, planned purchases, and training courses to calculate the
optimum or maximum amount of land needed to train to doctrinal
standards and policy. Not reflected in the model are training lands
that are not used due to environmental and cultural considerations,
condition of facilities, and other factors, all of which the Army
addresses through separate analyses at the end of the model's
calculation process. As such, the model's calculations are not the
entire analysis required for validation of training land needs and are
not intended to be so. Figure 2 describes the model's multiple inputs-
-the training doctrine and policy are depicted on the left and the
administrative and operational databases are depicted as cylinders.
Figure 2: Army Range Requirements Model's Multiple Inputs:
[Refer to PDF for image]
Army Range Requirements Model's Multiple Inputs are illustrated as
follows:
Army Range Requirements Model: Received the following inputs:
* Current range capacity:
- Operational Range and Inventory Sustainment;
* Location of units by type:
- Army Stationing and Installation Plan;
- Total Ammunition Management Information System;
- National Guard Bureau Unit Training Database;
- U.S. Army Reserve Command Unit Training System;
* Planned purchases:
- Army Master Range Plan;
* Army doctrine and policy:
- Training strategy;
- Training standards;
- Weapons authorized;
- Available training areas and ranges;
* Training courses, locations, and ranges required:
- Army Training Requirements and Resources System;
- Programs of instruction for Army schools.
Source: GAO analysis of Army Range Requirements Model architecture.
[End of figure]
Model Requirements Based on Army Doctrine and Policy:
The range requirements model uses Army doctrine and policy--
specifically training strategy, training standards, weapons authorized
for training, and available training areas and ranges--as its basis for
generating training land requirements.
* Army Training Circular 25-1 provides training land requirements per
unit, which includes the amount of maneuver training land necessary to
meet training requirements specific to unit size and echelon.[Footnote
42] The model uses this data to determine the amount of land needed for
maneuver training at each of its installations.
* Army Training Circular 25-8 provides data on how each type of
training range is to be configured, such as the number of maneuver
lanes, objectives, and firing points required for each standard
range.[Footnote 43] The model uses this information to determine
whether an installation's training ranges are configured properly to
meet training requirements and to calculate the amount of land needed
for maneuver training at each Army installation.
* Army Pamphlet 350-38 provides training standards for the types of
weapons and weapon systems to be used during training exercises and
defines the required number of rounds to be fired for each weapon or
weapon system to meet training requirements.[Footnote 44] The model
uses this data to determine the types of ranges and training land
needed for different training events. Upon release of new training
standards, the Army reviews them for clarity before entering them into
the model. The latest version of this policy was published in July 2008
and is currently being revised for fiscal year 2009. After the updates
are complete, they will be incorporated into the model.
* Army Pamphlet 415-28 provides specific guidance on how property is to
be tracked across the Army, specifying the use of category codes for
each type of property including training land and ranges.[Footnote 45]
These category codes allow the Army to determine what types of training
land and ranges are available across all its installations. The model
uses the categorization codes to identify and define a specific range
or type of maneuver training land when generating training
requirements. The Army ensures that any updates to these codes are
reflected in the model by incorporating them as soon they are
published. The pamphlet was last updated in April 2006.
According to Army officials, the above Army doctrine and policies do
not reflect the increases in unit training and the use of training
ranges as a result of ongoing contingency operations. As more units,
including National Guard units, are mobilized for contingency
operations, they require more training than would have happened at a
greater frequency than in peacetime. Because the range requirements
model is based on doctrine that reflects peacetime assumptions, its
calculations do not reflect the current increased training. For
instance, in peacetime, most ranges are used 242 days a year (which is
the timeframe used by the range requirements model to calculate
training land needs). With increased training due to contingency
operations and mobilization of troops, many ranges are being used
almost year-round.
Model Uses Data from Seven Administrative and Operational Databases:
The Army Range Requirements Model uses data from seven administrative
and operational databases and relies on these data sources to provide
the initial quality assurance over these data:
* Operational Range and Inventory Sustainment to track the Army's range
inventory. This inventory provides geospatial data on each range, lists
the type of munitions used at each range, and describes range
conditions. Data in this inventory are required to be updated every 5
years. Army officials said that they would like to have the inventory
updated more often, but, since the range inventory is relatively stable
and does not change significantly, they believe that the system's data
have a minimal effect on the reliability of model's calculations.
Still, Army headquarters has asked that the inventory be updated more
frequently and has provided funding in order to do so. The data are
reviewed by both the U.S. Army Environmental Command, the Army office
responsible for oversight of the inventory, and by installations, who
are the primary users of the data.
* Army Stationing and Installation Plan to track the number of military
personnel on an installation. This plan, which is a database, contains
data on civilian and military personnel stationed at individual Army
installations. For example, the database shows the number of units
stationed on a specific installation during a given fiscal year. These
data undergo a quarterly multistep validation, verification, and update
process. The Army Assistant Chief of Staff for Installation Management,
the office responsible for oversight of the database, performs a data
integration process to normalize information provided to the system by
other Army data sources. Updated data are sent to users, such as Army
Installation Management Command and other Army commands, for review and
validation. The database's management office controls data entered,
limits access to the data to authorized users only, validates all data
edits, and integrates the validated data edits into the database.
According to an Army official, the data are around 75 to 80 percent
accurate even though they undergo a multistep review process on a
regular basis. Still, we believe the effects of the database's 75 to 80
percent accurate rate on the model's calculations are minimal, because
users of the range requirements model have the opportunity to review
the database's data for accuracy and discrepancies and to address any
issues with any inaccurate data used in model.
* Total Ammunition Management Information System to track the
organization of units training at an installation. This system provides
data needed to manage training ammunition requirements, authorizations,
forecasts, and expenditures. Because these data are categorized by
Army's hierarchical structure, they can be used to identify the
organization of units per Army echelon. Data are manually validated
each time the system is updated, which is usually twice a year.
* National Guard Bureau Unit Training Database to ensure that
installations used by National Guard units are accounted for when
calculating training land requirements. The database contains data on
installations where National Guard units have trained and are scheduled
to train, the type of training completed, as well as account for
increased training due to contingency operations. Data are collected in
a spreadsheet that is manually verified through two levels of review,
both done within the National Guard Bureau Training Support Branch, the
office with oversight of the database. The first review is by the
person entering the data and the other by his or her supervisor. In
addition, data are verified using a separate data system, the Range
Facility Management Support System, which tracks historical usage of
training land and ranges by National Guard units. National Guard
officials said that historical training data are not used by the active
Army to predict future training requirements, so the data from this
database must be edited to fit the model's business rules. As such, the
National Guard reviews the data and edits it to fit the model's
business rules.
* U.S. Army Reserve Command Unit Training System to ensure that
installations used by reserve units are accounted for when calculating
training land requirements. The system provides reserve unit data, such
as unit names and home stations, and serves as the central database for
approved training activities within U.S. Army Reserve Command. The
system provides data on annual training exercises involving more than
one unit but does not include regular training for individual units.
While Reserve Command training is underrepresented in the model, Army
officials are aware and account for this lack of data by estimating
regular training for individual Reserve units. Data in this database
are reviewed periodically to reflect updates and access to the data is
limited to authorized users only. Most data are entered at the major
command level and the major command has authority to grant access to
users. In addition, the data undergoes a multilevel review process when
entered into the system. The major command is responsible for an
initial review of new data entered into the system, which are then
reviewed for accuracy by subject matter experts. The final validation
of any edits made to the data is performed by the Reserve Command
Training Directorate, which maintains the system. Any issues resulting
can be addressed when the model requirements are reviewed by Reserve
users, who can identify discrepancies and notify the model program
office about them. We believe this should sufficiently minimize any
potential issues in training requirements calculated by the model.
* Army Master Range Plan to compare calculated land or range shortfalls
with programmed modernization projects and range or land acquisitions.
This comparison allows users to see when new training ranges or land
will be ready for use to meet training requirements. The plan is the
Army's database of record for approved range modernization and training
land acquisition projects, including when modernization projects will
begin and end, how much they will cost, what type of funding will be
used for them, and where they will be located. Data in this database
are verified and validated by installations, which develop prioritized
lists of their range modernization and training land projects. These
lists are first validated at the major command level followed by
validation at the Army Office of the Deputy Chief of Staff, Training
Support Systems Division, which has ultimate oversight over the
database.
* Army Training Requirements and Resources System to assist in
projecting range and training land requirements for various Army
schools. This system is the Army's central repository for all school-
related training courses and includes detailed information on
requirements, programs, costs, and personnel. The Assistant Secretary
of the Army for Manpower and Reserve Affairs has oversight over the
system, which can be accessed only by authorized users. The system is a
transactional database and any edits to the data in the system are
recorded and can be traced back to the user who changed the data. An
Army official said that, because the system can be accessed by a large
number of users and has vast quantities of data, Army schools and other
users are relied on to ensure that their class schedules are correct
and up to date. Another official explained that, because training
projections are estimated based on course schedules, they may not be
correct for many installations, as courses are added or canceled
throughout the year, including after the range requirements model
calculates training land needs. They added that this can potentially
cause model calculations to be inaccurate. However, the model's quality
assurance procedures allow users to note changes made to course
schedules, and account for any inaccuracies in the model's
calculations. We believe this should sufficiently mitigate any issues
associated with the range requirements model use of the data from this
system.
Army Range Requirements Model Has Several Quality Assurance Safeguards:
The Army Range Requirements Model has quality assurance safeguards to
ensure that the requirements it produces are valid. These include
limited access to the model, prohibiting users from permanently
altering or deleting the data, and transparency. In addition, the
process of updating the data used by the model also includes quality
assurance procedures, including multilevel reviews of the data. For
example, the range requirements model provides for authorized users at
an individual installation to identify and verify the source data used
by the model for their installation, which they routinely do. If the
authorized users find errors or discrepancies they cannot update the
data in the model themselves but rather provide the correct data to the
range requirements model program manager which researches the issue and
notifies the responsible data source manager of the correction. This
installation quality check is in addition to the quality and
reliability checks and procedures that exist within each of the data
sources. We believe that any potential errors or discrepancies are
sufficiently minimized before the data is used by the model to
calculate its final training land requirements for an individual
installation.
Model Quality Assurance Includes Limited Access, Inability to
Permanently Alter Data, and Provides Transparency:
The range requirements model can be used only by certain individuals
who are granted access by the model's management office, such as
installation range officers or training officers. These authorized
users can review their installations' training requirements, which
include detailed information on requirement calculations and associated
data sources and provide a level of transparency to help ensure
computation quality and accuracy. However, the users can not make any
substantive changes to the model's data and calculations. This helps
ensure that no data are accidentally deleted or permanently altered
from the data sources. In those instances where authorized users may be
concerned that the range requirements model does not take into account
certain factors, such as environmental or cultural considerations,
condition of facilities including ranges, and use of land by other
services, instead of making edits directly to the model, they can
extract data from the model and manipulate them to account for these
factors. Any edits to the model's calculations are then forwarded to
the installation command and the model's management office for
validation. If validated, a record is kept of these changes at the
installation level, though no modifications are made to the baseline
data. This allows users to identify needed changes to their
installation training requirement while not disrupting the overall
system. In addition, this level of transparency is important, because
the model's management office relies on users to determine whether
model requirements for their installations are adequate and correct.
Updates to Model Include Quality Assurance Procedures:
In addition to the above quality assurance safeguards, updates to the
model are part of a multistage process that provides an additional
layer of quality assurance to data used by the model when generating
training land requirements. Table 1 provides information on the steps
used to update information in the model.
Table 1: Process for Updating Data in the Army Range Requirements
Model:
Step: 1. Upload new data;
Action taken: New data are manually uploaded from data sources into a
temporary database.
Step: 2. Identify problems with updated data;
Action taken: An analysis is performed on the temporary database to
identify data that do not fit model procedures and business rules.
Subject matter experts then manually review the data to determine why
it does not fit model procedures and business rules.
Step: 3. Compute new data in the model;
Action taken: Data are incorporated to a test version of the model and
prospective training range requirements are computed.
Step: 4. Identify inconsistencies in new computations;
Action taken: Results of the test model are reviewed to check for
inconsistencies. Subject matter experts determine whether they are
valid or due to a flaw in the calculations.
Step: 5. Review computations;
Action taken: Results from the test model are circulated to select
members of the model user community to ensure any inconsistencies not
found in step 4 are identified.
Step: 6. Transfer updates;
Action taken: Data transferred from the test model to the actual model.
During the transfer data are tested to ensure they are identical.
Source: DOD.
[End of table]
The entire update process is performed by the model's management office
and consists of several steps that can take from 2 to 10 weeks to
complete depending on the complexity of the source data and the number
of discrepancies found in such data. The first step involves collecting
data from the seven data systems and manually uploading them into a
temporary database. These data are uploaded manually because, as
officials noted, most Army systems were developed at different times
for a variety of purposes, so are not designed to communicate
electronically. The second step of the update process identifies any
problems with the newly uploaded data. This includes applying the
model's business rules to the temporary database to see if the data can
function in the model. Any data that appear to cause problems are then
reviewed by subject matter experts in the model's management office to
determine what is wrong with the data. In the third step, the data are
uploaded to a test version of the model, which is used to calculate
prospective training requirements. The fourth step involves reviewing
the results of the test model for inconsistencies. For example, an
installation for which training requirements for a particular type of
range increase or decrease by more than 20 percent would be identified
for further review. Subject matter experts would then review all the
noted discrepancies to determine whether they are valid. The fifth step
includes another layer of review of the test model results. After the
subject matter experts are finished with their review, the test model
results are then forwarded to select members of the model user
community at the installation level. These users examine the test model
results to determine whether any inconsistencies exist; these would
have been inconsistencies not found in step four. The sixth and final
step in the update process involves transferring the data in the test
model to the actual model. During the transfer, the data are tested to
make sure they are the same in both models. Once the data are uploaded
to the actual model, they are used to determine official training
requirements and are available to the entire user community.
The update process helps ensure that the data used to determine
training land requirements are as accurate as possible. Although the
model relies on the quality of the data provided by the source systems,
the quality assurance procedures that are part of the update process
can help mitigate any potential problems with the source data. For
example, inaccuracies in any of the source systems, such as units or
ranges incorrectly labeled, would likely be caught in the second step
of the update process as the model's business rules would not be able
to identify such units or ranges. Moreover, if errors cause large
discrepancies in training requirements for certain installations, they
would likely be noted and examined to determine what caused them.
Further, users can review the test model calculations in step four,
which allows them to determine whether requirements for their
installations as well as for others appear to be inaccurate.
[End of section]
Appendix III: Comments from the Department of Defense:
Office Of The Under Secretary Of Defense:
Acquisition Technology And Logistics:
3000 Defense Pentagon:
Washington, DC 20301-3000:
December 23, 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 Department of Defense (DoD) response to the GAO draft
report, GAO-09-32, entitled, "Defense Infrastructure: Army's Approach
for Acquiring Land Is Not Guided by Up-to-Date Strategic Plan or Always
Communicated Effectively," dated November 20, 2008 (GAO Code 351105).
The Department appreciates the opportunity to comment on the draft
report. The Department's comments on the two specific recommendations
in the report are outlined in the enclosure. We continue to appreciate
the audit work performed by the GAO.
Sincerely,
Signed by:
Alex A. Beckler, for:
Wayne Arny:
Deputy Under Secretary of Defense:
(Installations and Environment):
Enclosure: As stated:
GAO Draft Report - Dated November 20, 2008:
GAO Code 351105/GAO-09-32:
"Defense Infrastructure: Army's Approach for Acquiring Land Is Not
Guided by Up-to-Date Strategic Plan or Always Communicated Effectively"
Department Of Defense Comments To The Recommendations:
Recommendation 1: The GAO recommends that the Secretary of Defense
direct the Secretary of the Army to develop and implement a process to
update periodically its strategic plan - Range and Training Land
Strategy - to reflect current training land needs.
DOD Response: Partially Concur. The Army agrees with the recommendation
to regularly update its strategic plan for training ranges. However,
the title of the GAO report, as well as the discussion on the
"Highlights" page, create the implication that the currently
contemplated land acquisitions at Pinion Canyon Maneuver Site (PCMS)
and in Hawaii are somehow unsound or not valid. Recommend the title be
changed to better reflect GAO's actual findings that the Army's land
acquisition process was fundamentally sound and well supported ("an
extensive, analytic approach" - GAO draft report, page 6) . We propose
as the new title: "Army's Approach to Acquiring Land is Sound but Could
Benefit from Regularly Updated Strategic Plans, and Communicated More
Effectively."
At the time PCMS expansion proposals were developed (2006), the
Strategic Plan was not outdated (Grow the Army had not yet been
announced). Additionally, the major events that would be updated into
the Strategic Plan (Grow the Army) have not invalidated the need to
expand at PCMS, but have, in fact, made the case for expansion at PCMS
even more pressing and urgent. Moreover, there is no indication (either
by GAO or by the Army) that any of the four key elements of the Army's
Range and Training Land Strategy would change in an updated Strategic
Plan (i.e., (1) focused land management, (2) buffers to prevent
encroachment, (3) utilize other federal lands, and (4) land acquisition
would still remain the same set of tools in an updated Strategic Plan).
Thus, while it is preferable and desirable to regularly update the
Strategic Plan, (a recommendation with which the Army concurs), the
Army does not concur with the implication in the title, "Highlights",
and "Results in Brief' that the failure to update the Strategic Plan in
the past four years makes any difference in the requirement to expand
PCMS, or in any way renders the rest of the "extensive, analytic"
process invalid or unsound.
Also with respect to the discussion of Recommendation 1, the
information on page 8 of the GAO report does not accurately reflect
what Army officials told GAO auditors regarding congressional funding
restrictions. The report states: "The Army has elected to treat the
funding restrictions...as a prohibition on the use of funds for any
action related to the potential expansion of [PCMS], effectively
putting the potential acquisition process (including any potential
[NEPA] analysis) on pause." That is incorrect. What Army officials
actually told auditors was that the funding ban was limited to Military
Construction Appropriations and did not prevent the expenditure of
Operations and Maintenance funding on the National Environmental Policy
Act (NEPA) process. The Army voluntarily decided to delay the NEPA
process because of uncertainty over congressional support for the
expansion. The Department therefore requests that the description of
the Army statements of its position be revised to read as follows:
"Army officials stated that because the funding restrictions apply only
to Military Construction Appropriations, this does not preclude the
Army from further studying the 100,000-acre site or starting the NEPA
process using other appropriations. However, to date the Army has
voluntarily declined to spend other appropriated funds to begin NEPA
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."
Recommendation 2: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Acquisition, Technology, and
Logistics and the Assistant Secretary of the Army for Installations and
Environment to jointly review their strategies for communicating
potential major land acquisitions to the public prior to OSD waiver
approval and agree upon a common practice that would address OSD's
concerns about early disclosure and at the same time, permit the Army
and the other military services some flexibility to engage key
stakeholders - people living near the proposed land acquisition site,
elected officials, nongovernmental groups, and others - earlier in the
decision making process. Such a common practice should specifically
address what kinds of public outreach, if any, are permissible prior to
OSD's waiver determination.
DOD Response: Partially Concur. DODI 4165.71, Real Property
Acquisition, Paragraph 6.1. Land Acquisition Approval, explicitly
states that "proposals for 1000 or more acres of land, or land with an
estimated purchase price or annual lease that exceeds $1M, must be
approved ... prior to any public announcement, request for proposals,
notice of intent to perform environmental analysis, request for
legislation, or budget line item, press release or other public
notice." When outreach is desired in advance of waiver approval, the
Department offers a two-step approval process whereby the Deputy
Secretary of Defense (DSD) or Under Secretary of Defense for
Acquistion, Technology and Logistics (USD[AT&L]), as appropriate,
approves going forward with some of the actions/studies listed above
and, upon completion, directs the military service to obtain final
DSD/USD(AT&L) approval to either enter into the lease or acquire the
land. The Department believes that this two-step approval process
provides early disclosure and permits military services some
flexibility to engage key stakeholders, elected officials,
nongovernmental groups, etc., early in the decision making process.
[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; Mae Jones; Ron La Due Lake; Katherine Lenane; Josh Margraf;
Dave Martin; Julia Matta; Charles Perdue; Courtney Reid; and Roger
Tomlinson made major contributions to this report.
[End of section]
Footnotes:
[1] Department of the Army, Department of the Army Response to the
National Defense Authorization Act 2008; Section 2829: Report on
Utilization and Potential Expansion of Army Operational Ranges
(Washington, D.C., July 24, 2008).
[2] GAO, Army Training: Need to Improve Assessments of Land
Requirements and Priorities, [hyperlink,
http://www.gao.gov/products/GAO/NSIAD-90-44BR] (Washington, D.C.: Dec.
1, 1989) and Army Training: Various Factors Create Uncertainty About
Need for More Land, [hyperlink,
http://www.gao.gov/products/GAO/NSIAD-91-103] (Washington, D.C.: Apr.
22, 1991).
[3] Army Audit Agency, Real Estate Acquisitions, Audit Report: AA 98-92
(Alexandria, Va., Mar. 9, 1998) and RAND Arroyo Center, Does the Army
Have a National Land Use Strategy? (Washington, D.C., 1999).
[4] OSD's policy currently states that the moratorium does not apply to
civil works programs managed by the U.S. Army Corps of Engineers;
renewals of existing leases, withdrawals, permits, or other use
agreements (other than those at bases being closed or realigned); or
the acquisition of a negative, nonpossessory easement by a military
department using the authority granted by Section 2684a of Title 10,
U.S. Code.
[5] Secretary of Defense, Land Acquisition and Leasing of Office Space
in the United States (Washington, D.C., Sept. 13, 1990) and Land
Acquisition and Leasing of Office Space in the United States
(Washington, D.C., Nov. 17, 2002). The policy requires that major land
acquisition proposals and their public disclosure must be approved by
the Secretary of Defense or the Deputy Secretary of Defense. Also, the
Under Secretary of Defense for Acquisition, Technology, and Logistics
may approve major land acquisitions proposals inside the Washington,
D.C. area (generally the geographic area that falls within 100 miles of
the Pentagon) and their public disclosure.
[6] DOD Instruction 4165.71, Real Property Acquisition (Washington,
D.C., Jan. 6, 2005). Section 6.1 states: "Proposals for [major land
acquisitions] must be approved by the Under Secretary of Defense for
Acquisition, Technology, and Logistics prior to any public
announcement, request for proposals, notice of intent to perform
environmental analysis, request for legislation or budget item, press
release, or other official notice, in accordance with the Secretary of
Defense memorandum."
[7] The National Environmental Policy Act of 1969, codified as amended
at 42 U.S.C. § 4321-4347, establishes environmental policies and
procedures that shall be followed by all federal agencies to the
fullest extent possible. In accordance with these requirements and the
regulations for implementing the National Environmental Policy Act of
1969 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.
[8] Department of the Army, Department of the Army Response to the
National Defense Authorization Act 2008; Section 2831(a): Report on the
Piņon Canyon Maneuver Site, Colorado (Washington, D.C., July 18, 2008).
Section 2831(b) of Pub. L. No. 110-181 (2008) requires us to review the
Army's report and the justification for the potential expansion of the
Piņon Canyon Maneuver Site and issue the results of our review within
180 days of the Army report's submission to the congressional defense
committees. See GAO, Defense Infrastructure: Additional Information Is
Needed to Better Explain the Proposed 100,000-Acre Expansion of the
Piņon Canyon Maneuver Site, [hyperlink,
http://www.gao.gov/products/GAO-09-171] (Washington, D.C.: Jan. 13,
2009).
[9] Department of the Army, Range and Training Land Strategy
(Washington, D.C., Feb. 11, 2004). The strategy addresses increasing
training land deficits through focused land management; acquisition of
buffers through partnerships to mitigate encroachment; utilization of
other federal lands; and when necessary, land acquisition.
[10] 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). Army Training Circular 25-1 provides
doctrinal land requirements by unit and information from the circular
provides range configuration by type of range. Army Training Circular
25-8 provides information on how each type of training range is to be
configured by showing the doctrinal number of lanes, objectives, and
firing points required for each standard range. Army Pamphlet 350-38
defines the type of weapons to be used in training exercises including
the required number of rounds to be fired for each weapon or weapon
system as part of training exercises. Army Pamphlet 415-28 provides
guidance on how property is to be tracked across the department,
specifically the use of category codes for each type of property
including training land and ranges.
[11] Data sources used by the Army Range Requirements Model that
influence training land requirements include the Operational Range and
Inventory Sustainment, Army Stationing and Installation Plan, Total
Ammunition Management Information System, National Guard Bureau Unit
Training Database, U.S. Army Reserve Command Unit Training System, Army
Master Range Plan, and Army Training Requirements and Resources System.
These data sources are discussed in appendix II.
[12] See Land Acquisition and Leasing of Office Space in the United
States.
[13] Section 6.1 of the Department of Defense Instruction 4165.71
states: "Proposals for [major land acquisitions] must be approved by
the Secretary of Defense for Acquisition, Technology, and Logistics
prior to any public announcement, request for proposals, notice of
intent to perform environmental analysis, request for legislation or
budget line item, press release, or other official notice, in
accordance with Secretary of Defense memorandum."
[14] In January 2007, the President announced the Grow the Force
initiative to increase the end strength in the Army by more than 74,000
soldiers by 2013 (and the Marine Corps by 27,000 marines by 2011) to
enhance U.S. forces, reduce stress on deployable personnel, and provide
necessary forces for success in the global war on terrorism.
[15] Under the Global Defense Posture initiative, DOD is realigning its
overseas basing structure to more effectively support current allies
and strategies in addition to addressing emerging threats. Included in
this rebasing effort is the expected return of about 70,000 military
and civilian personnel to the United States by 2011.
[16] If the agency determines that activities of a proposed project
fall within a category of activities the agency has already determined
has no significant environmental impact--called a categorical
exclusion--then the agency generally need not prepare an environmental
assessment or an environmental impact statement.
[17] See pages 28-30 for a description of this litigation.
[18] Pub. L. No. 110-161, Division I, Title IV, § 409 (2007).
[19] Pub. L. No. 110-329, Division E, Title I, § 127 (2008).
[20] In October 1999, the Chief of Staff of the Army announced plans to
transform the Army from its current Cold War organization and equipment
to a lighter, more strategically responsive force--the Stryker brigade
concept--to fill what it sees as a strategic gap in warfighting
capabilities. The key elements of the Army's transformation and
modularity efforts are the standardization of unit structure to modular
brigade combat teams and the integration of new technology and
equipment to make the Army more deployable, flexible, lethal, and
adaptive. According to the Army, the implementation of transformation
and modularity has resulted in significant changes to Army training
doctrine and increases in training support requirements--units are
required by doctrine to operate across a much larger area.
[21] United States of America v. 1,402 Acres of Land, 203 Fed. App. 70
(9th Cir. 2006).
[22] 'Ilio'Ulaokalani Coalition v. Rumsfeld, 464 F.3d 1083 (9th Cir.
2006), aff'g in part, rev'g in part, 369 F.Supp.2d 1246 (D. Haw.,
2005). See pages 30-33 for additional information.
[23] As we previously reported, there is a lack of consistent and
detailed information about planned defense personnel moves. See GAO,
Defense Infrastructure: High-Level Leadership Needed to Help
Communities Address Challenges Caused by DOD-Related Growth, GAO-08-665
(Washington, D.C.: June 17, 2008).
[24] See [hyperlink, http://www.gao.gov/products/GAO/NSIAD-90-44BR] and
[hyperlink, http://www.gao.gov/products/GAO/NSIAD-91-103].
[25] Army Audit Agency, Real Estate Acquisitions, Audit Report: AA 98-
92 (Alexandria, Va., Mar. 9, 1998).
[26] RAND Arroyo Center, Does the Army Have a National Land Use
Strategy? (Washington, D.C., 1999).
[27] Department of the Army Regulation 350-19, The Army Sustainable
Range Program, U.S. Army Chief of Staff (Washington, D.C., Aug. 30,
2005). The Sustainable Range Program is the Army's overall approach for
improving the way in which it designs, manages, and uses its ranges to
meet its training responsibilities.
[28] According to Army Regulation 350-19, a military land acquisition
proposal is 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
should summarize, where applicable, information detailed in the range
complex master plan, range development plan, and analysis of
alternatives study. The proposal should include a map of the proposed
acquisition, the purpose of the acquisition, and potential effects on
surrounding communities. When Army officials submit a waiver request,
they sometimes refer to a military land acquisition proposal as a major
land acquisition request.
[29] See 40 C.F.R. Part 1500.
[30] In this case, the Army prepared both a programmatic and site-
specific environmental impact statement because it adopted a tiered
approach in addressing the requirements of the National Environmental
Policy Act of 1969 and the associated Council on Environmental Quality
regulations. Tiering "refers to the coverage of general matters in
broader environmental impact statements... with subsequent narrower
statements or environmental analyses (such as... site specific
statements) incorporating by reference the general discussions and
concentrating solely on the issues specific to the statement
subsequently prepared." 40 C.F.R. Part 1508.28.
[31] See pages 28-30 for more details on this litigation.
[32] See the Department of Defense Instruction 4165.71 and the
Department of Defense Instruction 7041.3, Economic Analysis for
Decisionmaking, Under Secretary of Defense, Comptroller (Nov. 7, 1995).
[33] See Army Regulation 350-19.
[34] The National Environmental Policy Act of 1969 also established the
Council on Environmental Quality, which 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 the National Environmental Policy Act
of 1969 appear at 40 C.F.R. Part 1500.
[35] 42 U.S.C. § 4332(2)(C).
[36] 40 C.F.R. § 1502.13-1502.16.
[37] United States of America v. 1,402 Acres of Land, 203 Fed. App. 70
(9th Cir. 2006).
[38] 'Ilio'Ulaokalani Coalition v. Rumsfeld, 369 F.Supp.2d 1246 (D.
Hawaii 2005).
[39] 'Ilio'Ulaokalani Coalition v. Rumsfeld, 464 F.3d 1083 (9th Cir.
2006).
[40] A spokesperson for the coalition stated that the coalition
believes the Army's proposed expansion is wrong and completely
"unjustifiable" and that its opposition to the proposed expansion goes
beyond the way the Army communicated its proposal.
[41] The Army refers to its planned force structure expansion as Grow
the Army. DOD generally refers to the planned force structure expansion
of the Army and Marine Corps as Grow the Force.
[42] Army Training Circular 25-1, Training Land, U.S. Army Chief of
Staff (Washington, D.C., Mar. 15, 2004).
[43] Army Training Circular 25-8, Training Ranges, U.S. Army Chief of
Staff (Washington, D.C., Apr. 5, 2004).
[44] Army Pamphlet 350-38, Standards in Training Commissions, U.S. Army
Chief of Staff (Washington, D.C., July 24, 2004).
[45] Army Pamphlet 415-28, Real Property Category Codes, U.S. Army
Chief of Staff (Washington, D.C., Apr. 11, 2006).
[End of section]
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