United States General Accounting Office

GAO Report to the Honorable

Harry Reid, U.S. Senate

September 1998 ENVIRONMENTAL

PROTECTION

DOD Management

Issues Related to Chaff

GAO/NSIAD-98-219

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-279055 

September 22, 1998

The Honorable Harry Reid

United States Senate

Dear Senator Reid:

This report responds to your request regarding the use of chaff by the

Department of Defense (DOD) and the effects of chaff. Chaff is composed

of aluminum-coated silica glass fibers that can be spread by aircraft in

flight, ships at sea, and vehicles on the ground to help them evade enemy

radar. You expressed concern about DOD’s continued use of chaff for

decades without sufficient knowledge of its long-term effects on the

environment. As agreed with your office, this report addresses (1) the

extent and locations of chaff use, (2) its reported known and potential

effects, and (3) the initiatives being taken or considered to address chaff’s

unintended effects.

Background Chaff works like a decoy by presenting a false target to enemy radar

systems. It has been used by the military for more than 50 years. It was

used during World War II and more recently during Operation Desert

Storm. Chaff is also used in the peacetime training and testing of weapons.

Chaff may be dispersed in bundles weighing from a few ounces to

24 pounds or from rolls in a continuous stream of over 30 pounds per

minute.1

DOD updated controls over the use of chaff in an October 1997 interim draft

of section 3212.02 of the Chairman of the Joint Chiefs of Staff manual. The

manual sets the procedures for controlling the types of chaff to be used,

the areas where it can be used, and altitudes at which it can be released.

Each military facility has the authority to set local procedures that govern

the use of chaff at training ranges and other locations near the facility.

Concern about the potential effects of chaff continues to be an issue and

has been expressed mainly by citizens and various public interest groups.

In addition, some DOD research on the effects of chaff has expressed

concerns and recommended further research. Most of the public concerns

center around its effects on human health and the environment, including

1

A bundle is any precut chaff load in containers such as plastic tubes or cardboard boxes. Chaff rolls

consist of either about 3,000 continuous strands that are dispensed by a cutter or of precut fibers

placed between mylar sheets that are dispensed when the sheets are separated.

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the potential for chaff particles to be inhaled or ingested and chaff’s

effects on land, water, plants, and animals.

Results in Brief Chaff is used worldwide in conjunction with military training, testing, and

other assigned missions. In fiscal year 1997, the Air Force reported using

about 1.8 million bundles worldwide, Navy and Marine Corps aircraft used

more than 354,000 bundles and 593 rolls, and Navy combat ships used

about 10,000 large bundles. DOD records indicate that fiscal year 1998

inventories include more than 37 million bundles and more than 141,000

rolls of chaff. The Air Force holds about 77 percent of the bundles, while

the Navy and the Marine Corps hold all the rolls. The Army has some

mission needs but possesses and uses little chaff in peacetime training or

testing.

While DOD components report that chaff is an effective means of defense

for aircraft, ships, and related weapon systems, DOD and other agencies

have identified some unintended and potential side effects of chaff. Chaff

can affect safety by interfering with air traffic control radar. Chaff can also

affect weather radar observations and the operation of friendly radar

systems, especially when vehicles stir up chaff that has settled on the

ground. It has been reported that chaff has also caused power outages and

damaged electrical equipment. Potential effects cited by Defense and other

organizations include those on health and the environment. For example,

the Air Force reported that chaff has a potential but remote chance of

collecting in reservoirs and causing chemical changes that may affect

water and the species that use it.

The services have a number of ongoing initiatives to address concerns

about the unintended and potential effects of chaff. For example, DOD has

entered into or is negotiating agreements with other federal agencies to

address issues related to commercial air safety, weather forecasting, and

environmental impacts on public lands. Also, the Navy has started a

program to develop degradable chaff that is estimated to cost about

40 percent more than the current chaff. While intended as beneficial, the

Navy has not yet defined the operational and environmental benefits that

could result from this program.

Notwithstanding DOD’s actions, some concerns continue to be raised by the

public and federal agencies about the potentially harmful or undesirable

effects of chaff on the environment. Also, some of DOD’s studies cite

additional areas where questions have been raised about the unintended

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effects of chaff. DOD has not systematically followed up on these questions

or on the recommendations in these reports to determine whether they

merit additional review. Lastly, DOD continues to retain lead-based chaff in

its inventory even though this type of chaff has not been manufactured

since 1987 and is reportedly no longer in use.

Extent and Location

of Chaff Use

The first recorded large-scale use of chaff by American forces in combat

was on December 20, 1943, in an air raid by 8th Air Force bombers over

Bremen, Germany. Today, the services use chaff on combat ranges and at

other locations worldwide for peacetime training and testing.

Aluminum, because of its electrical conductivity,2

 low cost, low weight,

and durability, has been a consistent ingredient in chaff. In the 1980s, the

cost of chaff was further reduced by replacing solid aluminum with

hair-like silica glass fibers with a thin aluminum coating. Chaff was once

produced using lead, and the Air Force still has some chaff containing lead

in its inventory. According to the manufacturer, chaff containing lead was

last manufactured in 1987.3

 The proportion of lead in chaff dropped from

about 1.2 ounces (7.5 percent) per pound in the 1950s to 0.16 ounces

(1 percent) by 1987.

The Air Force, the Navy, and the Marine Corps are the leading users of

chaff. Air Force records indicate they used nearly 2 million 6- to 7-ounce

bundles worldwide in fiscal year 1996 and about 1.8 million bundles in

fiscal year 1997. Navy and Marine Corps aircraft together expended more

than 340,000 and 354,000 similarly sized bundles in fiscal years 1996 and

1997, respectively. They also reported using 158 rolls in fiscal year 1996

and 593 rolls in fiscal year 1997. The Army currently uses very little chaff

but has the capability to use it from some of its helicopters. The Army

used a total of only 2,700 bundles of chaff from fiscal year 1991 to 1997.

Army officials reported they plan to increase training with chaff and are

developing chaff and dispensing equipment to be used on land-based

vehicles. (See app. I for the various types of chaff used and app. II for data

on reported chaff use by service and by selected location.)

2

Electrical conductivity is important because chaff absorbs and reflects electromagnetic energy to

create a radar echo.

3

Only one U.S. manufacturer supplies chaff to the military. However, at least one additional

manufacturer performs research and development into chaff materials. According to DOD, chaff with

lead was last produced in 1983.

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The services use chaff on training ranges around the world. The Air Force

uses about 39 ranges in the United States and off its coast; the Navy and

the Marine Corps use 14 ranges. The Air Force uses 14 ranges in 1 African

and 7 European countries and 2 ranges in Korea, while the Navy and the

Marine Corps have 1 range in Italy. According to Army officials, the Army

does not use chaff on any of its ranges, but the other services do. For

example, the Air Force uses chaff at White Sands Missile Range, and the

Navy uses Dugway Proving Grounds for Navy ship chaff acceptance

testing. Navy ships train with chaff in most of the world’s international

waters. Navy officials stated that naval ships perform chaff tests and

evaluations at two ranges off the U.S. east and west coasts. Figure 1 shows

the states and offshore locations near the United States where chaff is

used.

Figure 1: States (shaded) and Off-shore Ranges Where Chaff Is Used

Denotes off-shore ranges

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The methods used to disperse chaff have evolved over the years, from

simply tossing it out of airplane windows to launching it with

spring-loaded or pneumatic machines. Currently, the services use

pyrotechnic charges, rockets, mortars, air flows, or motors to disperse

chaff. Many aircraft employ pyrotechnic charges that eject chaff in bursts

from small bundles weighing about 6 ounces, while others use air flows to

disperse ejected chaff. The Navy uses small rockets to launch airborne

charges containing 8.5 pounds of chaff and shipborne charges containing

16.8 pounds of chaff. Navy ships can also launch mortar-like charges of

chaff weighing between 16 and 24 pounds. Motors feed chaff from rolls of

about 40 pounds through cutters4

 carried on some aircraft to produce

either bursts or a continuous stream.

The continuous stream technique, called saturation chaff, may be used by

aircraft to cover a large area. By 2005 or 2006, the Army also plans to use

saturation chaff to mask vehicle and troop movements. Using a cutter, 

360 pounds of chaff from nine 40-pound rolls can be deployed in 10

minutes. Depending on the method and the number of aircraft, such

releases could disperse billions of fibers. The B-52 can carry about 750

seven-ounce boxes of chaff; each box contains up to 11 million fibers that

can be expelled continuously or in bursts.

Most chaff bundles contain millions of fibers. For example, the chaff

bundles used most by the Air Force (RR-188) and the Navy

(RR-144) contain more than 5 million individual fibers each, and the

Navy’s Zuni rocket warhead (RR-182) contains more than 100 million

fibers.

Questions Continue to

Be Raised Concerning

Known and Potential

Effects of Chaff

Studies addressing the effects of chaff cite a number of known and

potential effects. Furthermore, our discussions with officials from DOD,

other federal agencies, and the private sector indicate that there are

additional questions about the effects of chaff. Among these are the known

effects of chaff on various types of radar and its potential effects on health

and the environment.

Air Force 1997 Report

Summarizes Past Chaff

Research

Ten studies (see app. III) on the effects of chaff have been carried out over

the past 45 years on request by the Army, Navy, Air Force, National Guard

Bureau, and Canadian Forces Headquarters.5

 An August 1997 report for

4

A cutter is used to cut a group of continuous strands of chaff to the desired length.

5

Although this was the only non-U.S. military sponsor, we chose to include it in our review because its

report is a key animal study cited in many of the other studies we reviewed.

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the U.S. Air Force Air Combat Command was the most recent and

comprehensive review of the effects of chaff. The report includes original

study as well as reviews of most of the previous reports. It cited the

following categories that can be affected by the use of chaff: safety, air

quality, physical resources (soil and water), biological resources, and land

and cultural resources. Most known chaff effects fall into the safety

category, while potential effects fall into the other categories. The

following sections summarize the known and potential effects described in

the Air Force report.

Safety The report noted that while chaff is effective at confusing enemy radar, it

also interferes with air traffic control radar. The report said that chaff had

interfered at least twice with Federal Aviation Administration (FAA) radar

but added that such events could be effectively avoided or managed.

According to the report, safety risks from the use of chaff are extremely

low and impacts on aircrews, aircraft, or the public are not anticipated.

For example, the report found (1) no incidents of chaff interfering with

satellite tracking; (2) two recorded incidents of military fighter aircraft

interfering with FAA radar, but details were unavailable; (3) no

documentation that chaff had caused aircraft radar systems to falsely

identify nearby traffic; (4) no evidence of an aircraft engine failing after

ingesting chaff; and (5) no reported accidents in which pilots were

distracted by chaff.

The report states that the primary safety concern is the potential for

interference with FAA’s air traffic control radar but notes that DOD and FAA

have agreed to restrict locations, altitudes, and times at which chaff can be

used. The report states that a newer type of chaff that does not interfere

with FAA radar is readily available.

Air Quality Air quality issues addressed in the report include the potential for

(1) noncompliance with national air quality standards due to the release of

significant quantities of particulates, (2) release of hazardous air pollutant

emissions, and (3) visibility impairment. The report takes into

consideration the Clean Air Act6

 and its amendments and includes a

literature review of chaff dispersion and air quality effects as well as its

own April 1994 technical report on chaff particulate testing.

The report’s literature review shows that none of the previous studies had

addressed the possible formation of inhalable particulates or issues

related to compliance with the Clean Air Act. But the report indicates

6

The Clean Air Act requires the Environmental Protection Agency to set national air quality standards.

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some inconsistencies in the reported size, use, and manufacture of chaff.

The report cited a particulate test showing that potential effects would not

exceed air quality standards, even though explosive charges on impulse

cartridges may result in minimal releases of particulates. The report says

that further study may be needed on the potential for short-term visibility

impairment near training areas where large quantities of chaff are used.

However, it says that chaff dispersed over a wide area and settled quickly

in particulate testing. Its conclusions assume chaff containing lead is no

longer being used. According to DOD, there have been no reports of

short-term visibility impairments caused by chaff.

Soil and Water The report says that the chemical or physical effects of chaff on soil and

water would be very limited because chaff falls only in small quantities in

any one location. It cites potential effects on wildlife through ingestion,

inhalation, or skin contact; on species, habitat conditions, and aesthetics

through settling in the water; and on water quality. The report includes a

literature review, a laboratory analysis, and field studies at two locations

where chaff is frequently used. One location is arid desert (Nellis Range

Complex, Nevada) and the other humid woodlands (Townsend Air to

Ground Gunnery Range, Georgia).

The report notes that the literature addressing the effects of chaff on water

quality and aquatic habitats is limited and that there has been no

systematic analysis of chemical changes in soils exposed to various

concentrations of chaff. It cites a 1977 Navy report that found no increase

in aluminum or trace metals from chaff placed in water. The Air Force

report notes that chaff’s potential to adversely affect the environment

depends on the quantity deposited in a particular area, the fibers’ stability,

the specific conditions of the soil and water, and the sensitivity of the

environment to contaminants. It states that the likelihood of chaff falling

into a particular pond, stream, or estuary in sufficient quantity to

measurably affect the water’s chemical makeup is remote.

Biological Resources The report addresses the potential biological effects of chaff on wildlife

due to inhalation, ingestion, and direct contact as well as the effects of

chaff on vegetation and aquatic life of chaff decomposing in soil or water.

The Air Force reported no adverse impacts from chaff and said that chaff

is generally nontoxic. However, few studies of the effects of chaff on

wildlife have been conducted, and the report found no data on chaff’s

decomposition process under different environmental conditions (arid,

alkaline, wet, acidic) or inside the digestive systems of animals. The study

includes a literature review, field studies, and laboratory analyses of soil

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samples taken at Nellis and Townsend, the two military range areas

studied. The report cites a 1972 Canada Department of Agriculture study

that found no health hazards to farm animals. The Air Force study also

cited a previous report on the Chesapeake Bay ecosystem that found no

impacts on the six marine organisms studied.7

The Air Force study reports the following:

• Animals can inhale chaff particles, but the particles do not penetrate far

into the respiratory system and can be easily cleared out.

• Chaff disperses over a large area of land, limiting exposure of grazing

animals. Little chaff accumulated on the surface of standing water bodies.

Surface-feeding or bottom-feeding animals and fish may ingest chaff, but

this only affects a few individual animals and has a low impact on species

populations except in the case of protected species.

• The numbers of chaff particles are negligible because chaff disperses over

a large land area. Low concentrations of chaff limit the likelihood that

birds would use chaff for nests and expose the young.

• Chaff disintegrates on land. It decomposes slowly in arid areas and has no

adverse effects on soil chemistry and plant growth. Chaff interference with

wildlife is expected to be negligible based on chaff use, characteristics,

and observed accumulations.

• Chaff decomposing in water has no adverse impacts on water chemistry

and aquatic life. In wet areas, chaff is covered by plant growth and dead

leaves. Chaff decomposes more rapidly in wet acidic environments, but

when doing so it releases only minute amounts of chemicals.

• Lead has not been used in the manufacture of chaff since 1983.8

Land and Cultural Resources Land resource issues addressed in the report concerned the accumulation

of chaff and its potential to alter the land’s use and visual quality, while

cultural resource issues related to the potential for physical or chemical

impacts to alter the aesthetic setting and cultural context. The Air Force

reviewed applicable laws and other related information and produced the

field studies’ technical report. It did not identify any studies that assessed

the impacts of chaff on either land use or its visual quality, or on cultural

resources. Nevertheless, according to the Air Force, while chaff debris

may be perceived as annoying or intrusive, it does not accumulate in

quantities likely to have such impacts. The report states that, overall, chaff

7

Two universities, working with the prime contractor, reported effects on some of the Chesapeake Bay

organisms studied, but the prime contractor concluded these effects were not significant and reported

no short- or long-term adverse environmental effects in its summary (see app. III).

8

The manufacturer’s representative told us the business had last manufactured chaff with lead in 1987.

As discussed in this report, chaff with lead was still in Air Force inventories at the time of our review.

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debris has low visibility and little effect on the aesthetic quality of the

environment. While noting that little data existed, the study reports that

common nondestructive materials such as chaff have little potential for

effects. The Air Force report states that the primary potential is for chaff

debris to affect the aesthetic setting but that cultural resources are not

generally located beneath airspace where heavy chaff use is concentrated

and examinations could be done on a site-specific basis. It noted that no

research exists on Native American concerns about the aesthetic effects of

chaff deposits.

Other Known Chaff Effects Our discussions with officials from federal agencies and the private sector

brought out other known effects that are discussed in the following three

sections.

Effects on Weather Chaff can show up on radar as a false weather phenomenon and may

affect lightning within storms. The National Weather Service (NWS) began

to observe the widespread and frequent use of chaff in the late 1980s,

when it started using new and more sensitive weather radar. Radar

observations show that chaff can spread over several hundreds of miles

and stay in the air for up to a day. A scientist formerly with the National

Oceanic and Atmospheric Administration (NOAA), who now performs

weather research at the University of Oklahoma, estimated it would have

taken more than 200 billion chaff particles to create a radar picture taken

in Arizona in 1997. DOD officials stated that it is improbable that such a

large chaff deployment occurred outside of combat and is unlikely to

occur in any future DOD training events. Figure 2 shows a 1997 NWS weather

radar image of chaff over Southern Arizona. NOAA also provided pictures

taken since 1993 in many other parts of the country and showing radar

images of chaff.

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Figure 2: NWS Radar Image of Chaff Plumes Over Southern Arizona and Southwestern New Mexico on October 8, 1997.

According to NOAA officials and scientists, chaff can be easily identified

under clear skies, but it can give false readings under other weather

conditions and can thus impair the ability to make accurate forecasts.

Chaff may be interpreted as precipitation and in some cases could result in

inaccurate warnings of severe weather. Chaff could therefore interfere

with missions that rely on accurate weather forecasts. One NOAA technical

report describes chaff’s interference with normal weather observation

data in at least two space-shuttle launch attempts.9

9

Chaff Observations with WSR-88D: Examples and Operational Impacts, NOAA / NWS /Spaceflight

Meteorology Group, Johnson Space Center (July 1, 1994).

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NOAA scientists are also concerned that chaff may cause inaccurate

weather data to be archived for long-term climate research studies.

Meteorologists can usually correctly identify chaff on radar, but automated

systems cannot now distinguish chaff from rainfall. The automated

systems record chaff as precipitation and overstate the amount of rain

archived in the database. Researchers may therefore get inaccurate results

from their studies.

NOAA scientists are also trying to determine whether chaff suppresses

lightning because this may also make it more difficult to assess the

weather accurately.10 Large storms will usually produce frequent lightning

strikes to the ground, and there is a direct correlation between the severity

of a storm and the number of such strikes. However, it has been observed

that some large storms inside chaff clouds had little or no lightning. If

chaff reduces lightning, it could cause forecasters to underestimate the

severity of storms. NOAA scientists and a University of Oklahoma weather

researcher said they would like to further study the effects of chaff on

thunderstorms if they could obtain funding. DOD officials stated that the

U.S. Forest Service has used chaff for a number of years to suppress

lightning and prevent forest fires, and NOAA issued an environmental

impact statement on lightning suppression in October 1972. DOD believes

the findings of this project should be reviewed to determine the need for

additional analysis of this recognized phenomenon prior to expending

additional funds.

Friendly Forces Radar Systems Just as it can confuse enemy and FAA radar and produce false precipitation

echos on NWS radar, chaff can also affect other friendly radar systems and

thus hinder military air traffic controllers’ and meteorologists’ support for

missions and operations. It can also affect friendly warning and targeting

systems. According to Army chaff program officials, chaff on the ground

can be stirred up by vehicles and can thus interfere with friendly airborne

radar systems. Although the Army stated this as an area of potential

concern, we found little documentation of these potential effects. To help

alleviate the problem, the Army is developing chaff that will reduce

interference with friendly forces’ radar systems. It hopes to have this chaff

in the inventory by 2005-06.

Power Outages Chaff can disrupt electrical power and directly affect electrical equipment.

San Diego Gas and Electric Company and Navy officials have identified

two instances in which chaff caused power outages in 1985. In the first

10Intense Convective Storms With Little or No Lightning Over Central Arizona: A Case of Inadvertent

Weather Modification?, NOAA, Environmental Research Laboratories, National Severe Storms

Laboratory (July 22, 1996).

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case, chaff accidently blown over San Diego, California, during a Navy

exercise 75 to 200 miles from the coast affected power to 65,000

customers and disrupted air traffic control. The Navy reimbursed the

power company between $50,000 and $60,000 for damage. The second

incident occurred 5 days later, again in San Diego, when a Navy jet

inadvertently showered power lines with chaff on takeoff, causing

interruptions in power service.

Current DOD

Initiatives and Related

Chaff Management

Issues

In an effort to address the unintended effects of chaff, DOD and the

services have ongoing initiatives related to air traffic control, chaff use on

public lands, chaff effects on weather, and degradable chaff. However, the

initiative to develop degradable chaff is not supported by an operational or

environmental requirement. According to DOD, the need to develop

degradable chaff is supported by its obligation to protect the environment

and its sensitivity to concerns expressed by some members of the public

over the use and degradability of chaff. Notwithstanding these actions,

questions about the potential adverse effects of chaff on health and the

environment continue to be raised by various public interest groups and

some federal and state officials.11 DOD’s own studies discuss some of the

same questions. Our work shows that DOD has not systematically followed

up on the questions being raised to determine whether they merit any

further action. Also, DOD continues to retain lead-based chaff in its

inventory, even though it is reportedly no longer being used.

DOD Initiatives for Civilian

Air Traffic Control

To address concerns that chaff interferes with civilian air traffic control

radar, FAA and DOD components have agreed to restrict the use of chaff and

now require military installations to obtain clearance when using chaff in

training and testing. DOD components also use training chaff, which is

designed not to interfere with FAA radar frequencies. FAA has established

procedures for coordinating all DOD electronic countermeasure missions

and issues annual clearance letters to military facilities that use chaff,

outlining restrictions that include controls over what kind of chaff can be

used, where it can be used, and the altitudes at which it can be released.

The Air Force, the Navy, and the Army have coordinated electronic

countermeasures with FAA under a multiservice instruction that was first

issued in 1964. According to DOD officials, an interim draft section 3212.02

11Public interest groups include the Rural Alliance for Military Accountability, People for the West, the

Wilderness Society, Citizen Alert, and the Sierra Club. Federal officials include those at the

Department of Interior’s Bureau of Land Management and Fish and Wildlife Service. State officials

include those at Nevada’s Department of Environmental Protection.

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of the Chairman of the Joint Chiefs of Staff manual replaced the

multiservice instruction in October 1997 and is expected to be finalized in

October 1998. In commenting on a draft of this report, DOD said it has

voluntarily restricted chaff use over concerns about public safety.

DOD Initiatives for Chaff

Use on Public Lands

Initiatives between DOD and Department of Interior agencies are helping to

identify and minimize the effects of chaff on public lands. The Fish and

Wildlife Service (FWS) and the Bureau of Land Management (BLM) have

signed agreements with individual military services to control chaff use

over wildlife refuges, Native Americans’ reservations, and public lands

near military training grounds. Examples include agreements signed

November 21, 1994, for the Cabeza Prieta National Wildlife Refuge near

Luke Air Force Base, Arizona; signed December 22, 1997, for the Desert

National Wildlife Refuge near Nellis Air Force Base, Nevada; and signed

June 11, 1998, for the public lands near Mountain Home Air Force Base,

Idaho. Many military installations have local procedures to restrict the use

of chaff near environmentally sensitive areas or population centers. In

1997, BLM set up a committee composed of representatives from the

military services and civilian agencies to explore, among other issues,

establishing a policy on dropping chaff over public lands, where it may be

considered litter. The Navy said it has entered into three limited

agreements to restrict chaff use over wildlife refuges and public lands

because of concern over possible impacts on sensitive species.

DOD Initiatives for Chaff

Effects on Weather

DOD and components of NOAA have recently begun to identify and address

concerns that chaff interferes with weather radar data and forecasting.

These initiatives have been aided by the placement of new weather radar

monitors at major military range weather stations.12 DOD frequency

managers must now alert range operations officials to halt high-altitude

chaff drops within a specified distance from the Kennedy Space Center

prior to scheduled space-shuttle launches. Since February 1998, the Navy

and NWS have been conducting coordinated chaff drops to allow NWS radar

to record known quantities, areas, and times of chaff use. They anticipate

a preliminary report by September 1998.

NOAA officials suggested additional recommendations to address chaff’s

effects on the weather, including improving NWS and DOD liaison and

interaction, having DOD alert NWS of planned unusual chaff use, and having

12In a cooperative effort with DOD and FAA, NWS has deployed a total of about 160 new weather

surveillance radars.

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DOD limiting chaff use when significant weather is reported over or near

the ranges. NOAA officials stated that their computer programs could be

modified to address chaff effects on current forecasting and data archiving

systems but said these modifications would be costly.

Navy’s Initiative for

Degradable Chaff

The Navy is developing a new type of chaff that will break up more quickly

in the environment. It says the new chaff is needed to alleviate public

concerns about the health and environmental effects of chaff, particularly

the perceived threat that chaff can be inhaled. However, DOD has not

demonstrated how it will address these public concerns. The new chaff is

also more expensive.

Some Navy program officials told us there is no operational or

environmental requirement to develop a new type of chaff and that the

Navy believes the chaff currently in use is not harmful to the environment

or a threat to health or public safety. However, they acknowledged that

fiberglass chaff persists in the environment and that some members of the

public perceive chaff as environmentally harmful or undesirable. They are

taking action to develop a new degradable chaff, saying they thus hope to

head off any possible restrictions on chaff use that may result in

reductions in military training. DOD officials stressed its obligation to

protect the environment and DOD’s sensitivity to concerns expressed by

some members of the public. It noted that the effort includes the

development of environmentally degradable parts to replace plastic pieces

presently used in systems that dispense chaff.

Unlike fiberglass chaff, the new chaff’s base material and its aluminum

coating can take a few weeks to a few months to break up, depending on

conditions. Development of the new chaff began in September 1993, and

total development costs are estimated at about $3.6 million. Navy officials

anticipate the new chaff will be available beginning in fiscal year 2001 and

expect to buy only degradable chaff in the future. They plan to buy about

474,000 bundles a year through fiscal year 2003. A Navy program official

estimated that a bundle of the new chaff will cost about 40 percent more

than it does currently.

No Systematic Follow-Up

on Open Questions

Studies by DOD and others, including some carried out years ago, continue

to create questions in the public’s mind about the health and

environmental effects of chaff. Department records indicate that DOD has

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not systematically followed up on these reports to determine the merits of

any outstanding question or the costs and benefits of addressing them.

While none of the studies we reviewed demonstrated significant

operational or environmental effects of chaff, 9 of the 10 reports cited gaps

in information on potential effects. Six of the nine made no

recommendations but cited missing data, suggested additional studies or

long-term monitoring, or cited possible long-term chronic effects. Three

reports recommended additional studies covering chaff toxicity, long-term

exposure, weathering, or other study areas. However, DOD has not

reviewed the recommendations and information gaps cited in the reports

in a comprehensive and systematic way to assess their merits for further

actions. For example, the Army’s January 1992 report cites data gaps and

recommends that the long-term risk and chronic exposure of inhaled

fibers be evaluated. Specifically, it recommends

• future research on the resuspension rates of uncoated and coated fibers;

• studies to establish the weathering rates and chemical fate of metal

coatings in soils, fresh water, and marine waters;

• a comprehensive review of threshold metal toxicity values for humans,

animals, and important fresh water and marine organisms;

• a series of experiments to evaluate the potential impacts of fibers;

• an examination of the respirability of fibrous particles in avian species;

• aquatic and marine studies to establish the potential impacts of fibers; and

• future research on the pathology of inhaled fibers.

The second and third of the above recommendations were partially

addressed in the Army’s September 1992 report. Two other reports also

partially addressed the second recommendation.13 We found limited

evidence of follow-up on the other five recommendations.

The 1997 Air Force study and its technical reports also cite the need for

data and further research, including long-term studies. Two of the three

technical reports recommend further research. One suggests long-term

studies to monitor chaff accumulation on water bodies in high-use areas

and the effects on animals using those water bodies. Another states that

consideration could be given to monitoring programs for highly sensitive

environments subjected to repeated chaff releases and conducting

bioassay tests to further assess the toxicity of chaff to aquatic organisms.

The final report noted that in some cases it might be appropriate to

13Technical Report No. 4, Field Studies, October 1994, and Technical Report No. 5, Laboratory Analysis

of Chaff and Flare Materials, November 1994, from the 1997 Air Force report.

Page 15 GAO/NSIAD-98-219 Chaff Management Issues
B-279055 

analyze the potential for impacts to highly sensitive aquatic habitats that

support threatened and endangered species in areas underlying airspace

where chaff is proposed for use. But it does not recommend any follow-up

work.

Open questions similar to those in these reports have been cited by public

interest groups such as those identified earlier. In discussing these

questions in May and June 1998, DOD and service officials stated that

additional actions were warranted on items such as follow-ups to previous

studies and chaff’s weather-related effects. These officials said they are

meeting to develop strategies to address the use and effects of chaff. They

said these strategies, which have yet to be defined, could include a

systematic follow-up of key study findings and recommendations and

screening environmental assessments and impact statements to ensure

consistent citation of study results. They said efforts will need to be

coordinated among DOD components and could include interim controls

over chaff use in sensitive environments.

Unneeded Lead-Based

Chaff Inventories Are

Being Retained

During the course of our work, we noted that some lead-based chaff was

still being held in DOD’s active inventory. Older productions of foil chaff

contained lead and lead is known to be toxic and can result in a number of

health problems. As a result, DOD stopped purchasing chaff with lead. The

Air Force reported it does not expect to use any chaff containing lead and

the 1997 Air Force report stated that it is highly unlikely that any chaff

containing lead is still in use. However, we found that the Air Force still

does have chaff containing lead in its inventory and has no plans to

eliminate it.

We were provided a sample of chaff containing lead at one of the Air

Force bases we visited during our review. The sample we obtained was of

an aluminum-foil type used primarily by B-52s. In addition, Air Force

records show that it still has in its inventory almost 40,000 bundles of chaff

containing lead. These records came from Air Force and Defense Logistics

Agency central inventory control points.

Conclusions DOD and the services have developed ongoing initiatives to address certain

concerns raised by the military’s use of chaff. These initiatives include

plans for increased liaison with agencies such as BLM, FWS, and NWS.

Nevertheless, the public, DOD studies, and other federal agencies continue

to raise questions about the potential adverse effects of chaff. DOD has not

Page 16 GAO/NSIAD-98-219 Chaff Management Issues
B-279055 

systematically followed up to determine whether these questions merit

further action. Further, the Navy has initiated a degradable chaff research

and development program but has not yet completely analyzed the

operational and environmental benefits it expects to achieve. Lastly,

although lead-based chaff has not been produced since 1987 and is no

longer reported used, it is still retained in DOD’s inventory.

Recommendations We recommend that the Secretary of Defense direct

• the Secretary of the Navy to study the costs and benefits of the degradable

chaff program before making a production procurement decision;

• the Secretaries of the Army, the Navy, and the Air Force to determine the

merits of open questions made in previous chaff reports and whether

additional actions are needed to address them; and

• the Secretary of the Air Force to prepare a specific plan to ensure that

chaff containing lead at inventory control points and military installations

is located and eliminated.

Agency Comments In written comments on a draft of this report, DOD concurred with our

findings and recommendations. (See app. IV.) DOD stated that the Navy is

developing information on the costs and benefits of degradable chaff for

use in a procurement decision. It stated that the services will assess

whether additional actions are needed to address open questions from

previous chaff reports. DOD also said that any training chaff with lead

would be eliminated and that operational chaff would be clearly marked

so that it could only be used to meet combat requirements. DOD also

provided technical comments which we incorporated where appropriate.

Scope and

Methodology

To address the extent and location of DOD’s chaff use, the known and

potential effects of chaff, and initiatives to mitigate these effects, we

interviewed and obtained documents from officials at the Department of

Defense, the military services, components of the National Oceanic and

Atmospheric Administration (including the Office of Oceanic and

Atmospheric Research and the National Weather Service), the Federal

Aviation Administration, the Bureau of Land Management, the Fish and

Wildlife Service, the Environmental Protection Agency, the Defense

Logistics Agency, and the Federal Communications Commission. In

addition, we spoke with state officials and other parties from the states of

Nevada, Florida, Oklahoma, and Arizona, including Native Americans,

Page 17 GAO/NSIAD-98-219 Chaff Management Issues
B-279055 

public interest groups, and interested citizens, to determine whether they

had concerns about chaff use or were aware of any health or

environmental effects. We also visited chaff manufacturers’

representatives to discuss the production of chaff and the development of

degradable chaff.

To obtain information on the extent and locations of chaff use, we

performed work at the following military installations: Fallon Naval Air

Station and Nellis Air Force Base, Nevada; Eglin Air Force Base, Florida;

and Luke Air Force Base and Yuma Marine Corps Air Station, Arizona.

These installations conduct operations using chaff as part of their

electronic countermeasure training. At these locations we discussed the

use of chaff, the studies that have been performed on chaff, and public

perceptions about the use and effects of chaff from military operations.

We reviewed environmental reports and research studies, environmental

impact statements and assessments, and other related information dealing

with the effects of chaff to determine the environmental effects of chaff

that have been documented. Our review of these reports was limited to an

analysis of their recommendations, issues, and questions they raised. We

grouped these into generally related categories to assess the extent to

which DOD actions related to the categories. We did not attempt to analyze

the content of each report. We did note that many of these studies were

carried out a number of years ago and that research records were not

readily available.

We conducted our review from December 1997 to July 1998 in accordance

with generally accepted government auditing standards.

Unless you publicly announce its contents earlier, we plan no further

distribution of this report until 15 days after its issue date. At that time, we

will make copies available to appropriate Senate and House committees;

the Secretaries of Defense, the Army, the Navy, and the Air Force; the

Commandant of the Marine Corps; and the Director, Defense Logistics

Agency.

Page 18 GAO/NSIAD-98-219 Chaff Management Issues
B-279055 

Please contact me on (202) 512-8412 if you or your staff have any

questions concerning this report. Major contributors to this report are

listed in appendix V.

Sincerely,

David R. Warren, Director

Defense Management Issues

Page 19 GAO/NSIAD-98-219 Chaff Management Issues
Contents

Letter 1

Appendix I 

Types of Chaff

22

Appendix II 

Services’ Use of Chaff

During Fiscal Years

1991-97

23

Appendix III 

GAO-Reviewed

Reports on Chaff

Research

25

Appendix IV 

Comments From the

Department of

Defense

27

Appendix V 

Major Contributors to

This Report

29

Tables Table II.1: Air Force Chaff Used During Fiscal Years 1991-97 23

Table II.2: Navy Air-launched Chaff Used During Fiscal Years

1991-97

23

Table II.3: Navy Sea-launched Chaff Used During Fiscal Years

1991-97

24

Table II.4: Army Chaff Used During Fiscal Years 1991-97 24

Table II.5: Chaff Use Reported at Military Installations Reviewed 24

Figures Figure 1: States and Off-shore Ranges Where Chaff Is Used 4

Page 20 GAO/NSIAD-98-219 Chaff Management Issues
Contents

Figure 2: NWS Radar Image of Chaff Plumes Over Southern

Arizona and Southwestern New Mexico on October 8, 1997.

10

Abbreviations

BLM Bureau of Land Management

DOD Department of Defense

FAA Federal Aviation Administration

FWS Fish and Wildlife Service

NOAA National Oceanic and Atmospheric Administration

NWS National Weather Service

Page 21 GAO/NSIAD-98-219 Chaff Management Issues
Appendix I 

Types of Chaff

Chaff type Service Weight Compositiona Inventoryb

RR-170A/AL (operational) Air Force 6.4 oz. Fiber 23,606,750

RR-180/AL (operational) Air Force 6.4 oz. Fiber 830,786

RR-188/AL (training) Air Force 6.4 oz. Fiber 1,881,503

RR-112A/AL (B-52) Air Force 7.0 oz. Fiber 372,720

RR-136C/AL (RF-4) Air Force 14.4 oz. Fiber 939,990

RR-141E/AL (EF-111) Air Force 6.9 oz. Foil 207,557

RR-149/AL (B-52) Air Force 5.9 oz. Foil 1,440

RR-149A/AL (B-52) Air Force Unknown Fiber 412

RR-72B/AL Air Force Unknown Foil 37,800

RR-72C/AL Air Force Unknown Fiber 210,360

RR-185/RR-ZZZ (B-52) Air Force Unknown Fiber 235,767

RR-129/AL (operational) Navyc 4.7 oz. Fiber Classified

RR-144/AL (training) Navyc 4.8 oz. Fiber Classified

RR-171/AL (roll) Navyc 41-43 lbs. Fiber Classified

RR-179/AL (roll) Navyc 40 lbs. Fiber Classified

RR-181/AL (AIRBOC-ship) Navyc 16 lbs. Fiber Classified

RR-182/AL (Zuni rocket) Navyc 8.5 lbs. Fiber Classified

RR-184/AL (operational) Navyc 1.4 oz. Fiber Classified

RR-189/AL (training) Navyc 1.4 oz. Fiber Classified

MK-182 mod 1 Navyd 16 lbs. Fiber 4,841

MK-182 mod 2 Navyd 24 lbs. Fiber 4,909

MK-214 Navyd 24.3 lbs. Fiber 50,163

MK-216 Navyd 16.8 lbs. Fiber 24,118

M-1 Army 3.5 oz. Fiber 310,000

aFiber: aluminum-coated silica glass fibers; foil: aluminum foil.

bAir Force data as of May 8, 1998; Navy data as of March 3, 1998; and Army data as of

February 23, 1998.

cLaunched from airplanes.

dDispensed from ships.

Page 22 GAO/NSIAD-98-219 Chaff Management Issues
Appendix II 

Services’ Use of Chaff During Fiscal Years

1991-97

Table II.1: Air Force Chaff Used During Fiscal Years 1991-97 (bundles)

Fiscal year

Chaff type 1991 1992 1993 1994 1995 1996 1997

RR-170A/AL 1,361,216 1,689,200 1,545,715 1,412,244 1,415,496 834,827 826,669

RR-180/AL 0 0 530 0 0 0 4,565

RR-188/AL 0 103 7,105 166,447 1,285,876 1,153,439 950,655

RR-112A/ALa

RR-136C/AL 0 0 0 0 0 0 0

RR-141E/AL 0 0 0 0 0 0 0

RR-149/ALa

RR-149A/ALa

RR-72B/ALa

RR-72C/ALa

RR-185 and RR-ZZZa

aAccording to Air Force logistics officials, expenditure history for these chaff types is unknown.

Table II.2: Navy Air-launched Chaff Used During Fiscal Years 1991-97 (bundles, unless otherwise indicated)

Fiscal year

Chaff type 1991 1992 1993 1994 1995 1996 1997

RR-129 343,117 436,219 277,665 243,219 339,087 233,662 107,469

RR-144 34,593 89,868 79,252 84,698 74,944 91,875 197,370

RR-171 (rolls) 641 179 199 115 58 47 26

RR-179 (rolls) 665 367 289 327 369 111 567

RR-181 171 189 166 148 88 279 217

RR-182 rocket 552 80 24 0 0 0 0

RR-184 0 0 0 0 352 6,637 39,712

RR-189 0 0 0 0 0 8,303 10,145

Page 23 GAO/NSIAD-98-219 Chaff Management Issues
Appendix II 

Services’ Use of Chaff During Fiscal Years

1991-97

Table II.3: Navy Sea-launched Chaff Used During Fiscal Years 1991-97 (bundles)

Fiscal year

Chaff type 1991 1992 1993 1994 1995 1996 1997

MK-182 Mod 1 1,752 1,599 1,215 1,403 1,029 1,293 581

MK-182 Mod 2 733 661 1,218 806 263 373 175

MK-214 721 1,704 5,332 1,987 1,957 3,129 8,472

MK-216 186 453 619 574 1,232 1,214 1,026

Table II.4: Army Chaff Used During Fiscal Years 1991-97 (bundles)

Fiscal year

Chaff type 1991 1992 1993 1994 1995 1996 1997

M-1 0 50 0 1,251 1,161 118 120

Table II.5: Chaff Use Reported at

Military Installations Reviewed

(bundles)

Fiscal year

Installation Chaff type 1995 1996 1997

Nellis Air Force

Base (AFB), Nev.

RR-170

RR-188

122,798

271,946

98,370

186,772

58,420

194,161

Eglin AFB, Fla. RR-170

RR-188

other

58,509

645

2,480

114,444

14,260

0

124,787

22,291

704

Luke AFB, Ariz. RR-170

RR-188

Not available Not available 12,667

162,053

Fallon Naval Air

Station, Nev.

RR-129

RR-144

35,610

12,480

55,469

36,660

0

13,212

Yuma Marine

Corps Air Station,

Ariz.

RR-129

RR-144

Not available Not available 24,169

34,086

Page 24 GAO/NSIAD-98-219 Chaff Management Issues
Appendix III 

GAO-Reviewed Reports on Chaff Research

The reports we reviewed on chaff research were issued between 1952 and

1997. As shown below, all but one were sponsored by DOD components.

Environmental Effects of Self-Protection Chaff and Flares, U.S. Air Force

Air Combat Command (Aug. 1997).1

Aquatic Toxicity and Fate of Iron and Aluminum Coated Glass Fibers,

U.S. Army Chemical Research, Development, and Engineering Center

(Sept. 1992).2

Environmental and Health Effects Review for Obscurant Fibers/Filaments,

prepared by the Pacific Northwest Laboratory for the U.S. Army Chemical

Research, Development, and Engineering Center (Jan. 1992).

Environmental Effects of Air National Guard Chaff Training Activities,

prepared by Science and Engineering Associates, Inc., for the National

Guard Bureau (Dec. 1990).

Identifying and Evaluating the Effects of Dispensing Chaff From Military

Aircraft, prepared by Science and Engineering Associates, Inc., for the Air

Force Strategic Air Command (Dec. 5, 1989).

Environmental Effects of Chaff, U.S. Air Force Occupational and

Environmental Health Laboratory (Dec. 1978).

Effects of Aluminized Fiberglass on Representative Chesapeake Bay

Marine Organisms, prepared by Systems Consultants, Inc., for the U.S.

Naval Research Laboratory (Nov. 23, 1977).3

The Ingestion of Fiberglass Chaff by Cattle, prepared by the Canada

Department of Agriculture for the Director of Electronic Warfare,

Canadian Forces Headquarters (Mar. 8, 1972).

Chaff, Wright Air Development Center (May 1956).

1

Includes three technical reports on the effects of chaff dated April 1994, October 1994, and

November 1994. Portions of the report, including two additional technical reports, address the effects

of flares, which are not included in our scope.

2

We also reviewed the Army Report, Aquatic Toxicity and Fate of Nickel Coated Graphite Fibers, With

Comparisons to Iron and Aluminum Coated Glass Fibers, U.S. Army Chemical and Biological Defense

Agency (July 1993), but because it focused mainly on infrared obscurants rather than radar-evading

chaff, we did not include it in our scope.

3

Systems Consultants, Inc., incorporated reports by two subcontractors, the University of Delaware

and the University of Maryland.

Page 25 GAO/NSIAD-98-219 Chaff Management Issues
Appendix III 

GAO-Reviewed Reports on Chaff Research

Toxicity of Chaff to Livestock, U. S. Air Force Aeromedicine Laboratory

(1952).

Page 26 GAO/NSIAD-98-219 Chaff Management Issues
Appendix IV 

Comments From the Department of Defense

Page 27 GAO/NSIAD-98-219 Chaff Management Issues
Appendix IV 

Comments From the Department of Defense

Page 28 GAO/NSIAD-98-219 Chaff Management Issues
Appendix V 

Major Contributors to This Report

National Security and

International Affairs

Division, Washington,

D.C.

Charles I. Patton, Jr.

Uldis Adamsons

Richard W. Meeks

Los Angeles Field

Office

Lionel C. Cooper, Jr.

Gary W. Kunkle

Office of the General

Counsel, Washington,

D.C.

Margaret L. Armen

(709295) Page 29 GAO/NSIAD-98-219 Chaff Management Issues
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