```
                                                                 
Military Training: DOD Lacks a Comprehensive Plan to Manage	 
Encroachment on Training Ranges (11-JUN-02, GAO-02-614).	 
                                                                 
Senior Department of Defense (DOD) and military service officials
have testified that they face increasing difficulties in carrying
out realistic training at military installations. There are eight
"encroachment" issues that affect or have the potential to affect
military training and readiness. The eight encroachment issues	 
are: endangered species habitat on military installations,	 
unexploded ordnance and munitions constituents, competition for  
radio frequency spectrum, protected marine resources, competition
for airspace, air pollution, noise pollution, and urban growth	 
around military installations. Whenever possible, the services	 
work around these issues by modifying the timing, tempo, and	 
location of training, as well as the equipment used. However,	 
these workarounds are becoming increasingly difficult and costly 
and they compromise the realism essential to effective training. 
Over time, the military services report they have increasingly	 
lost training range capabilities because of encroachment. Each of
the four installations and two major commands GAO visited	 
reported having lost some capabilities in terms of the time	 
training ranges were available or the types of training that	 
could be conducted. Higher-than-average population growth around 
installations makes further encroachment losses likely. Despite  
the loss of some capabilities, service readiness data do not	 
indicate the extent to which encroachment has significantly	 
affected reported training readiness. Although encroachment	 
workarounds may affect costs, the services have not documented	 
the overall impact of encroachment on training costs. The	 
services face difficulties in fully assessing the impact of	 
training ranges on readiness because they have not fully defined 
their training range requirements and lack information on the	 
training resources available to support those requirements. DOD  
officials recognize the need for a comprehensive plan of	 
administrative actions and legislative proposals to address	 
encroachment issues but have not yet finalized a plan for doing  
so.								 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-614 					        
    ACCNO:   A03528						        
  TITLE:     Military Training: DOD Lacks a Comprehensive Plan to     
Manage Encroachment on Training Ranges				 
     DATE:   06/11/2002 
  SUBJECT:   Air pollution					 
	     Defense capabilities				 
	     Defense cost control				 
	     Endangered species 				 
	     Environmental monitoring				 
	     Environmental policies				 
	     Marine policies					 
	     Marine resources					 
	     Military facilities				 
	     Military training					 
	     Noise pollution					 
	     Population growth					 
	     Proposed legislation				 
	     Radio frequency allocation 			 
	     Strategic planning 				 
	     DOD Global Status of Resources and 		 
	     Training System					 
                                                                 

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GAO-02-614
     
A

Report to Congressional Requesters

June 2002 MILITARY TRAINING DOD Lacks a Comprehensive Plan to Manage
Encroachment on Training Ranges

GAO- 02- 614

a

GAO United States General Accounting Office

Page i GAO- 02- 614 Military Training Letter 1

Results in Brief 3 Background 5 Encroachment Has Diminished Service Training
Range Capabilities 9 Impact of Encroachment on Readiness and Training Costs
Is Not

Well Reflected in DOD's Reported Data 15 Comprehensive Plan for Addressing
Encroachment Not Finalized,

but Some Action Has Been Taken 24 Conclusions 30 Recommendations for
Executive Action 31 Agency Comments and Our Evaluation 31

Appendix I Scope and Methodology 33

Appendix II Membership of DOD Encroachment- Related Groups 36

Appendix III DOD?s Draft Sustainable Ranges Action Plans for Addressing
Encroachment Issues 38

Endangered Species Act Action Plan 38 Unexploded Ordnance and Munitions
Constituents Action Plan 39 Radio Frequency Spectrum Action Plan 39 Maritime
Sustainability Action Plan 40 National Airspace Redesign Action Plan 40 Air
Quality Action Plan 41 Airborne Noise Action Plan 41 Urban Growth Action
Plan 41

Appendix IV Comments from the Department of Defense 42

Tables

Table 1: Members of the Senior Readiness Oversight Council 36 Table 2:
Members of the Defense Test and Training Steering Group 36 Table 3: Members
of the Integrated Product Team 37 Contents

Page ii GAO- 02- 614 Military Training Figure

Figure 1: DOD Environmental Conservation Program Obligations, Fiscal Years
1996- 2001 23

Abbreviation

DOD Department of Defense

Page 1 GAO- 02- 614 Military Training

June 11, 2002 The Honorable Dan Burton Chairman, Committee on Government
Reform House of Representatives

The Honorable Christopher Shays Chairman, Subcommittee on National Security,

Veterans Affairs, and International Relations Committee on Government Reform
House of Representatives

Senior Department of Defense and military service officials have testified
before Congress that they face increasing difficulties in carrying out
realistic training at military installations. According to the officials,
there are eight so- called ?encroachment? 1 issues that affect or have the
potential to affect military training and readiness. The eight encroachment
issues are: endangered species habitat on military installations, unexploded
ordnance and munitions constituents, 2 competition for radio frequency
spectrum, protected marine resources, competition for airspace, air
pollution, noise pollution, and urban growth around military installations.
Whenever possible, the services work around these issues by modifying the
timing, tempo, and location of training, as well as the equipment used.
However, defense officials have expressed concern that these workarounds are
becoming increasingly difficult and costly and that they compromise the
realism essential to effective training.

At your request, we examined (1) the impact that encroachment has had, or is
likely to have, on the services? training range capabilities; 3 (2) the

1 The Department of Defense defines encroachment as the cumulative result of
any and all outside influences that inhibit normal military training and
testing. 2 Unexploded ordnance are munitions that have been primed, fused,
armed, or otherwise prepared for action, and have been fired, dropped,
launched, projected, or placed in such a manner as to constitute a hazard to
operations, installations, personnel, or material and remain unexploded
either by malfunction, design or any other cause. Munitions constituents
consist of such things as propellants, explosives, pyrotechnics, chemical
agents, metal parts, and other inert components that can pollute the soil
and/ or ground water. 3 We use the term ?training ranges? to collectively
refer to air ranges, live- fire ranges,

ground maneuver ranges, and sea ranges.

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 02- 614 Military Training

effect training range losses have on the services? readiness and costs; and
(3) the department?s progress in formulating a comprehensive plan for
addressing encroachment issues.

This report focuses exclusively on military training ranges in the United
States and is our second assessment of encroachment issues and their impact
on military training ranges. The first assessment reviewed the effects of
encroachment on training ranges outside the continental United States and
was performed at the request of the Chairman, Subcommittee on Readiness and
Management Support, Committee on Armed Services, U. S. Senate. 4 We are also
reviewing for your committee how the U. S. Fish and Wildlife Service budgets
and allocates its endangered and threatened species (referred to as
endangered from here on in the report) program funds and what program
activities were emphasized in fiscal year 2001.

In conducting our work, we toured four installations and visited two major
commands. 5 We discussed encroachment with officials at each location to
hear and observe, first hand, how encroachment had affected their training
range capabilities. We also discussed the impact of encroachment on
readiness and costs with these officials, and then reviewed key Department
of Defense readiness reports, along with cost data from the department?s
Environmental Quality Program, to further understand how encroachment has
affected readiness and costs. Finally, we met with service and Department of
Defense officials responsible for developing plans for addressing
encroachment issues and discussed with these officials their progress in
formulating a comprehensive plan for addressing encroachment issues. A more
thorough description of our scope and methodology is in appendix I.

4 U. S. General Accounting Office, Military Training: Limitations Exist
Overseas but Are Not Reflected in Readiness Reporting, GAO- 02- 525
(Washington, D. C.: April 30, 2002). 5 Installations toured included Fort
Lewis, Washington; Marine Corps Base Camp Pendleton, California; Eglin Air
Force Base, Florida; and Nellis Air Force Base, Nevada. The major commands
reviewed included the U. S. Atlantic Fleet and the U. S. Special Operations
Command. These tours were based on recommendations of the service staffs as
having conditions representative of the types of encroachment pressures they
face. The visit to the U. S. Special Operations Command was included based
on the recommendation of the Committee on Government Reform staff because of
the command?s specialized training requirements and unique encroachment
pressures.

Page 3 GAO- 02- 614 Military Training

We summarized the findings of this review in testimony before the Committee
on Government Reform on May 16, 2002. 6

Over time, the military services report they have increasingly lost training
range capabilities because of encroachment. Each of the four installations
and two major commands we visited reported having lost some capabilities in
terms of the time training ranges were available or the types of training
that could be conducted. For example, Marine Corps Base Camp Pendleton,
California, has training limitations related to the use of off- road
vehicles and the digging of defensive positions because of the presence of
endangered species on its ranges. In addition, Eglin Air Force Base?s major
target control system suffers from frequency interference from nearby
commercial operators, which officials indicate presents a safety issue
because the problem can affect data links to weapons. Such constraints limit
units? ability to train as they would expect to fight or require
workarounds- or adjustments to training events- that can create bad habits
and affect performance in combat or, in some instances, prevent training
from being accomplished. Service officials believe that population growth
around military installations is responsible for much of their past and
present encroachment problems, and that higher- thanaverage population
growth around their installations makes further encroachment losses likely.

Despite the loss of some capabilities, service readiness data do not
indicate the extent to which encroachment has significantly affected
reported training readiness. While encroachment workarounds may affect
costs, the services have not documented the overall impact of encroachment
on training costs. Training readiness, as reported in official readiness
reports, remains high for most units. Our analysis of readiness reports from
active duty units in fiscal year 2001 showed that very few units reported
being unable to achieve combat- ready status 7 due to inadequate training
areas. However, improvements can and should be made to the department?s
readiness reporting to address training degradation due to encroachment and
other factors. At the same time, the

6 U. S. General Accounting Office, Military Training: DOD Needs A
Comprehensive Plan to Manage Encroachment on Training Ranges, GAO- 02- 727T
(Washington, D. C.: May 16, 2002). 7 A unit?s readiness is determined by the
extent to which it possesses the required

resources and training to undertake its wartime missions. Results in Brief

Page 4 GAO- 02- 614 Military Training

services face difficulties in fully assessing the impact of training ranges
on readiness because they have not fully defined their training range
requirements and lack information on the training resources available to
support those requirements. Service officials also report that encroachment
increases training costs, and can provide examples of such costs; however,
those costs have not been documented in a comprehensive manner. Funding
associated with the Department of Defense?s environmental conservation
program, which includes activities such as preservation programs and
endangered species management, shows only modest gains over the past 6
years, increasing from 1996 to 1998 but then dropping from 1999 to 2001
among all components except for the Army. However, Department of Defense
officials acknowledge that budget constraints and other priorities have
resulted in a backlog of some activities in this area.

Department of Defense officials recognize the need for a comprehensive plan
of administrative actions and legislative proposals to address encroachment
issues but have not yet finalized a plan for doing so. The services first
presented their encroachment problems to the Senior Readiness Oversight
Council 8 in June 2000, but as of April 2002 the department had not yet
finalized a comprehensive plan for addressing them due to the transition to
the new administration, the events of September 2001, and continuing
internal deliberations over how best to address encroachment. Although the
department has prepared draft action plans that deal with each encroachment
issue separately, the plans are not finalized, and information is not yet
available on specific actions planned, time frames for completing them,
clear assignment of responsibilities, and funding needed- the elements of a
comprehensive plan. The department has also drafted, but has not finalized,
an implementing directive meant to serve as the foundation for addressing
encroachment issues and one directive each on noise abatement and outreach
efforts. In December 2001, the department directed an Integrated Product
Team 9 to act as the coordinating body for all encroachment issues, develop
a comprehensive set of legislative and regulatory proposals by January 2002,
and formulate and manage outreach efforts. A package of legislative
proposals, described as clarifications in a department legislative summary,
was submitted to the Congress in late April 2002 seeking to modify several
specific statutory

8 Members of the Senior Readiness Oversight Council are identified in
appendix II of this report. 9 Members of the Integrated Product Team are
identified in appendix II of this report.

Page 5 GAO- 02- 614 Military Training

requirements, which Defense Department officials believe will preserve its
use of training ranges while protecting the environment. Although time
permitted only a cursory consideration of the proposals, they appear to be
another step by the department toward developing a comprehensive approach to
managing encroachment affecting military training ranges. Progress has also
been made in a number of areas by other departmental organizations. For
example, the Operational and Environmental Steering Committee for Munitions
has been addressing explosive safety and environmental concerns, and the
department recently approved a munitions action plan prepared by the
committee.

While the Congress considers the department?s legislative proposals, we
recommend executive action that requires the Department of Defense to
finalize a comprehensive plan for managing encroachment issues, develop the
ability to report critical encroachment- related training problems, and
develop and maintain inventories of its training infrastructure and quantify
its training requirements. In comments on a draft of this report, the
department substantially concurred with the contents of the report and our
recommendations. The department also provided technical clarifications,
which we incorporated as appropriate.

The Department of Defense?s (DOD) ranges and training areas are used
primarily to test weapon systems and train military forces; some facilities
are used for both testing and training purposes, while others are limited to
one use or the other. This report focuses primarily on facilities used for
training purposes. DOD needs ranges and training areas for all levels of
training. Required facilities include air ranges for air- to- air, air- to-
ground, drop zone, and electronic combat training; live- fire ranges for
artillery, armor, small arms, and munitions training; ground maneuver ranges
to conduct realistic force- on- force and live- fire training at various
unit levels; and sea ranges to conduct ship maneuvers for training.

According to a DOD official, today?s concerns about encroachment reflect the
cumulative result of a slow but steady increase in problems affecting the
use of their facilities. Historically, specific encroachment problems have
been addressed at individual ranges, most often on an ad hoc basis.
Recently, DOD officials have reported increased limits on and problems with
access to and the use of ranges. They believe that the gradual accumulation
of these limits and problems increasingly threatens training readiness. DOD
officials have identified eight encroachment issues of concern. These issues
are: Background

Page 6 GAO- 02- 614 Military Training

 The designation of critical habitat under the Endangered Species Act of
1973. DOD believes that critical habitat designations reduce its flexibility
to use designated lands for training and put its military mission in
jeopardy because, under the act, an agency is required to ensure that its
actions do not destroy or adversely modify designated habitat of any
endangered species. 10 Currently over 300 federally listed endangered plant
and animal species are found on military installations, and more are
anticipated. DOD officials maintain that their successful efforts in
managing training ranges have resulted in the training ranges becoming
havens for at- risk species. According to these officials, some of the
finest remaining examples of rare wildlife habitats are now on military
lands.

 The application of environmental statutes to military munitions, including
unexploded ordnance and munitions constituents. DOD believes that the
Environmental Protection Agency could apply environmental statutes to the
intended use of military munitions, shutting down or disrupting military
training on active ranges. For example, DOD officials note that in 1997
executive action was taken under the Safe Drinking Water Act that
essentially terminated live- fire training on the Massachusetts Military
Reservation because of unexploded ordnance and munitions constituents
leaching into drinking water in the surrounding area. According to DOD
officials, uncertainties about future application and enforcement of these
statutes limit the department?s ability to plan, program, and budget for
compliance requirements.

 Competition for frequency spectrum. The growth of consumer communications
devices has resulted in pressure from the telecommunications industry for
the reallocation of some radio frequency spectrum from federal to non-
federal control. According to DOD officials, since 1992 DOD has lost
approximately 27 percent of the total frequency spectrum allocated for
aircraft telemetry. DOD believes the possible reallocation of spectrum,
coupled with an increase in DOD activities that use it, raises concerns
about the availability of adequate spectrum to support operations and
training. For example, we previously reported that DOD is concerned that an
additional reallocation of spectrum in the 1755

10 The U. S. Fish and Wildlife Service and the National Marine Fisheries
Service list species that are at risk of becoming extinct throughout all or
a significant portion of their range. For each listed species, the
appropriate agency must designate critical habitat for those species.
Federal agencies must consult with the agencies on any action that
jeopardizes the continued existence of a listed species or could result in
the destruction or adverse modification of designated critical habitat.

Page 7 GAO- 02- 614 Military Training

to 1850 megahertz band could adversely affect space systems, tactical
communications, and combat training. 11

 The requirement to balance ocean resource protection mandates with
training needs. DOD officials believe DOD?s ability to train can sometimes
be limited by marine regulatory laws that require consultation with
regulators when a proposed action may affect a protected resource. Defense
officials have expressed concern that the process empowers regulators to
impose potentially stringent measures to protect the environment from the
effects of proposed DOD actions, which can affect DOD?s ability to conduct
operations and training in the marine environment.

 Competition for airspace. DOD officials have expressed concerns that
increased airspace congestion, caused by airline industry demands and the
military?s need for effective testing and training, limits the ability of
pilots to train as they will fight.

 The application of Clean Air Act regulations specifying requirements for
air quality. DOD officials believe these regulations can sometimes limit
DOD?s ability to base equipment and for units to train as they will fight,
particularly with smoke, because the act requires controls over emissions
commonly generated on defense installations. According to DOD officials,
opacity and conformity requirements are the most onerous for the department.
DOD officials told us opacity measures the visibility of air emissions and
can restrict or prohibit smoke training, mounted maneuvers, and intentional
burns to manage vegetation cover. The conformity rules require federal
agencies to analyze emissions from proposed projects or activities at
federal installations. DOD officials believe that any new or significant
change in range operations located in non- attainment areas requires an
emissions analysis. If emissions exceed specified thresholds, the increase
must be offset by reductions elsewhere.

 The application of environmental laws and regulations mandating noise
abatement. DOD officials state that weapon systems are exempt from the Noise
Control Act of 1972, but that the department must still assess the impact of
noise under the National Environmental Policy Act when

11 U. S. General Accounting Office, Defense Spectrum Management: More
Analysis Needed to Support Spectrum Use Decisions for the 1755- 1850MHz
Band, GAO- 01- 795 (Washington, D. C.: Aug. 20, 2001).

Page 8 GAO- 02- 614 Military Training

considering the environmental impact of its activities. As community
developments have expanded closer to military installations, concerns over
noise from military operations have increased. Defense officials report that
pressures from groups at the local, regional, and state levels can serve to
restrict or reduce military training.

 Unplanned or incompatible commercial or residential development (urban
growth) around training ranges and installations. DOD officials believe
encroachment of incompatible civilian activities compromises the
effectiveness of their training activities. Incompatible land uses can
compromise the health, safety, and welfare of both the military and civilian
sectors. DOD officials report that local residents have filed lawsuits
because they believe that military operations have impacted their property?s
value or restricted its use.

To the extent that encroachment adversely affects training readiness,
opportunities exist for the problems to be reported in departmental and
military service readiness reports. The Global Status of Resources and
Training System is the primary means for units to report readiness against
designed operational goals. The system?s database indicates, at selected
points in time, the extent to which units possess the required resources and
training to undertake their wartime missions.

In 1994, to improve its readiness assessment capabilities, DOD established
two forums- the Senior Readiness Oversight Council and the Joint Monthly
Readiness Review- to evaluate readiness from a joint and strategic
perspective. DOD is also required under 10 U. S. C. 482 to prepare a
quarterly readiness report to Congress that describes readiness problems.
DOD bases its quarterly report on briefings to the Senior Readiness
Oversight Council. The Senior Readiness Oversight Council is assisted by the
Defense Test and Training Steering Group, 12 which advises the council on
training range issues. In June 2000, the council directed the steering group
to investigate encroachment and develop and recommend a comprehensive plan
of action.

The Secretaries of the military departments are responsible for training
personnel and for maintaining their respective training ranges and
facilities. Within the Office of the Secretary of Defense, the Under

12 Members of the Defense Test and Training Steering Group are identified in
appendix II of this report.

Page 9 GAO- 02- 614 Military Training

Secretary of Defense for Personnel and Readiness develops policies, plans,
and programs to ensure the readiness of the force and provides oversight on
training. The Deputy Under Secretary of Defense for Installations and
Environment develops policies, plans, and programs for DOD?s environmental,
safety, and occupational health programs, including compliance with
environmental laws, conservation of natural and cultural resources,
pollution prevention, and explosive safety. The Director, Operational Test
and Evaluation, has oversight responsibility for all major test ranges,
manages all joint test and evaluation range investments (including spectrum
enhancement), and is also responsible for ensuring that congressionally
mandated live- fire test and evaluation is conducted on fully integrated
weapon systems.

Over time, the impact of encroachment on training ranges has gradually
increased. While the effect varies by service and individual installation,
in general encroachment has limited the extent to which training ranges are
available or the types of training that can be conducted. This limits units?
ability to train as they would expect to fight and/ or requires units to
work around the problem. However, as discussed in the next section, the
overall impact on readiness and training costs is not well documented.

Many encroachment issues result from or are exacerbated by population growth
and urbanization. DOD is particularly affected because urban growth near 80
percent of its installations exceeds the national average. According to DOD
officials, new inhabitants near installations often view military activities
as an infringement of their rights, and some groups have organized in an
effort to reduce range operations such as aircraft and munitions training.
These problems are expected to increase over time.

We visited four installations and two major commands and found that each has
lost some capability in terms of (1) the time training ranges were available
or (2) the types of activities that could be conducted. We found that the
types of encroachment and their impact varied between installations and
service organizations.

Camp Pendleton officials report encroachment problems related to endangered
species and their habitat, urbanization, competition for air space, and
noise restrictions. As of February 1, 2001, the Fish and Wildlife Service
had designated about 10 percent of the installation as critical habitat for
endangered species, which limits the use of off- road vehicles and the
digging of fighting positions. Restrictions caused by the presence
Encroachment Has

Diminished Service Training Range Capabilities

Examples of How Encroachment Is Affecting Training Capabilities

Marine Corps Base Camp Pendleton, California

Page 10 GAO- 02- 614 Military Training

of endangered species, recreational areas, and topographic and access
limitations have reduced the amount of beach available for amphibious
assaults and prevented training to doctrinal standards. Airspace
restrictions have limited the number of days that weapon systems can be
employed, and noise restrictions limit night helicopter operations.

Camp Pendleton officials are trying to limit future constraints imposed by
these encroachment issues through an outreach program that maintains open
communications with local, state, and national authorities and regulators
and local communities to educate them on the military?s mission and
operations and incorporate their concerns. Also, training events, such as
setting up fuel storage areas, are sometimes relocated to other areas of the
base when feasible; other exercises, such as bridging operations, have been
moved to Marine Corps Air Station Yuma, Arizona.

Fort Lewis and Yakima Training Center 13 officials report encroachment
problems related to noise, air quality, endangered species and their
habitat, urbanization, frequency spectrum, and munitions constituents. Due
to community noise complaints, Fort Lewis voluntarily ceased certain
demolitions training. Air quality regulations have restricted the Army?s
ability to operate new smoke generators at Fort Lewis. Endangered species
habitat considerations have limited off- road vehicle training at Fort Lewis
and Yakima and river- crossing operations at Yakima. Maneuvers are
restricted in prairie areas at Fort Lewis to preserve an endangered plant
and at Yakima to protect western sage grouse habitat. This reduces the types
of training that can be conducted by the Interim Brigade Combat Teams 14
based at Fort Lewis. Also, communications equipment used by the teams
overlaps with commercial communications networks, creating periodic
interference in communications. Finally, although Fort Lewis is situated
over an aquifer, and munitions constituents have been found in the water,
training has not yet been curtailed at this location.

Fort Lewis officials are trying to mitigate their encroachment problems by
(1) developing and maintaining scientifically defensible information that

13 The Yakima Training Center is a component of Fort Lewis that is used to
conduct largescale maneuver and live- fire operations. Yakima is
approximately 180 miles east of Fort Lewis. 14 Fort Lewis is home to two
Interim Brigade Combat Teams being organized around new

light armored wheeled vehicles under the Army?s Force Transformation
program. Fort Lewis and the Yakima

Training Center, Washington

Page 11 GAO- 02- 614 Military Training

can demonstrate the effectiveness of current environmental management; (2)
integrating range management with endangered species protection initiatives
to preserve critical habitat and training ranges; and (3) conducting an
outreach campaign to inform the public of the military?s training needs and
environmental successes. At Yakima, additional land was purchased recently
to increase maneuver space and reduce the environmental impacts of maneuver
training on current rangelands. Fort Lewis has moved some demolition
training to Yakima. Smoke- generating units must ensure that no smoke can
drift off base or obscure Mount Ranier during training. Negotiation between
the military and local agencies has alleviated some frequency encroachment
problems.

Nellis Air Force Base officials report encroachment problems stemming from
urbanization and noise. Nellis officials report that because of the
tremendous growth south of the base and safety concerns about overflying
urban areas with live munitions, armed aircraft must take off and land from
the north. This can cause mission delays for outbound traffic and mission
cancellations due to wind effects. They also report that Nellis and the
Nevada Test and Training Range 15 together receive about 250 noise- related
complaints annually that require adjustments to air operations.

To mitigate encroachment issues, base officials are working to procure 413
acres to avoid safety problems at its live ordnance departure area. To limit
the number of noise complaints, base officials said they restrict the use of
certain runways, impose speed and altitude restrictions, and require
straight- in approaches late at night and early in the morning. They are
also strengthening their outreach program to keep the communities around the
ranges informed about flight activities.

Eglin Air Force Base officials report encroachment problems involving
endangered species habitat, noise restrictions, urban growth, and
competition for radio frequency spectrum. Habitat for two endangered species
is found on Eglin?s ranges, impacting the availability of the ranges during
certain times of the year. To help offset complaints about the noise from
the explosive ordnance disposal school, smaller bombs may be detonated at
certain times. Urban sprawl causes aircraft to change altitudes and
direction to avoid commercial towers and noise- sensitive areas. In
addition, the base?s major target control system suffers from

15 The Nevada Test and Training Range is a component of the Nellis Range
Complex. Nellis Air Force Base and the

Nevada Test and Training Range, Nevada

Eglin Air Force Base, Florida

Page 12 GAO- 02- 614 Military Training

frequency interference from nearby commercial operators, presenting a safety
issue because the problem can affect data links to weapons.

Eglin officials told us that they have maintained an aggressive encroachment
program that has been successful at minimizing training impacts. For
example, the base has established an encroachment committee to review
requests for use of Eglin land. A very active outreach program meets
regularly with local civic leaders to enhance community support for the
base. The base has also developed a noise assessment prediction model that
can alleviate noise complaints by determining the effects of weather on the
noise created by military activities. This allows the base to modify its
activities accordingly. To address frequency encroachment, Eglin is trying
to narrow the bandwidth of its signals or move to another frequency.

Atlantic Fleet officials report encroachment problems stemming from the
presence of endangered species, particularly marine mammals, and airborne
noise. Restrictions caused by the presence of marine mammals impact live-
fire exercises at sea. Also, no night live- fire training is allowed.
Atlantic Fleet officials said that battle group staff must spend large
amounts of time consulting with the National Marine Fisheries Service on
endangered species mitigation. They noted that Naval Air Station Oceana,
Virginia, is the target of frequent noise complaints as a result of aircraft
training that includes low- altitude flights and practice carrier landings.

The Atlantic Fleet has a variety of encroachment mitigation programs. The
environmental section has developed an extensive report, based on geographic
information that shows the ranges of all endangered species in the Virginia-
Carolina Exercise Area. This allows the fleet to plan its exercises to avoid
harassing the species at risk. Prior to the beginning of live- fire
exercises, Navy aircraft and ships must search the training area for 2 hours
and then maintain a constant watch for marine mammals during the exercises.
If an animal enters the training area, the exercise is suspended until it
leaves. The Navy is evaluating construction and location of a Shallow Water
Training Range along the east coast of the United States to provide anti-
submarine warfare training in a littoral environment. Service officials note
that progress has been delayed over an assessment of potential impact to
marine mammals related to the definition of

?harassment.? To reduce noise complaints, the fleet is attempting to
establish a training airstrip in a less populated area. The Navy has also
established special procedures to deal with noise complaints and damage. U.
S. Atlantic Fleet, Naval

Station Norfolk, Virginia

Page 13 GAO- 02- 614 Military Training

The Navy component of the Special Operations Command reports being most
directly affected by encroachment from endangered species and urban
development. Specifically, a variety of endangered species live on the Navy
Special Warfare Command?s training areas in California, particularly on
Coronado and San Clemente Islands. Due to environmental restrictions, Navy
Special Warfare units can no longer practice immediate action drills on
Coronado beaches; they cannot use training areas in Coronado for combat
swimmer training; and they cannot conduct live- fire and maneuver exercises
on much of San Clemente Island during some seasons.

In the past, the Special Operations Command has been able to mitigate
deficiencies in local training areas by traveling to alternate training
sites. However, recent limitations on the amount of time units can spend
away from their home stations have required new solutions. The command is
requesting funding for new environmental documentation in its budget to
protect assets in California and is integrating its encroachment mitigation
efforts with DOD and the services.

DOD and service officials report that many encroachment issues are related
to urbanization around military installations. They noted that most, if not
all, encroachment issues such as noise, airspace, endangered species
habitat, and air quality, result from population growth and urbanization,
and that growth around DOD installations is increasing more than the
national average. At the same time, according to a defense official, the
increased speed and range of weapon systems are expected to increase
training range requirements. For the following reasons, DOD and service
officials believe they face increasing encroachment risks in several key
areas:

 Critical habitat designation. The Endangered Species Act requires the Fish
and Wildlife Service to designate critical habitat for endangered species at
the time of listing, or within 12 months if more data about habitat is
needed. Defense officials told us that private environmental interest groups
have repeatedly challenged the Wildlife Services? failure to designate
critical habitat and generally have prevailed, resulting in more and more
designations. To illustrate, they noted that the Fish and Wildlife Service
recently declined to designate critical habitat for a species at Camp
Pendleton, using its authority to exempt land from designation if it finds
that the benefits of exclusion outweigh the benefits of designation. They
also noted that the Natural Resource Defense Council, a public interest
group involved in environmental protection, is currently Special Operations
Command,

MacDill Air Force Base, Florida Effects of Encroachment Are Expected to Grow

Page 14 GAO- 02- 614 Military Training

challenging the decision in court. Marine Corps officials report that if the
Fish and Wildlife Service?s position is not upheld, approximately 57 percent
of Camp Pendleton?s training area could be designated as critical habitat
and could face additional restrictions on training. Fish and Wildlife
Service officials told us there could be significant increases in habitat
designations in coming years.

 Unexploded ordnance and munitions constituents. The application of
environmental laws to unexploded munitions and munitions constituents has,
to date, affected only one training installation in the continental U. S.,
the Massachusetts Military Reservation, used primarily by National Guard
forces. 16 It remains uncertain whether and to what extent the Environmental
Protection Agency will apply the laws to other installations. Environmental
Protection Agency officials told us that they were not explicitly monitoring
military ranges, but if it were brought to their attention that ordnance was
jeopardizing public health and safety at another installation, they would
take action to address the situation.

 Frequency spectrum. DOD officials told us that the commercial
communications industry has been pressing for access to frequency spectrum
currently allocated for federal use, but has stayed its request due to the
current national security situation. However, reallocation of some of that
spectrum is still under review. An interagency working group, with DOD
participation, has been formed and is examining options, including sharing
the spectrum and moving DOD operations to other bands. The outcome of these
efforts could affect DOD missions, including combat training and satellite
operations.

 Airspace congestion. Commercial air traffic growth is expected to result
in an increase in passengers from 600 million to an estimated one billion by
2010, increasing the overall demand for airspace volume. Military use of
airspace will also increase with the next generation of high- performance
weapon systems, standoff munitions, and unmanned aerial vehicles. In many
instances, the military?s use of airspace is tied directly to its ground
infrastructure, which cannot be changed easily. The Federal Aviation
Administration is in the process of redesigning the nation?s airways to
accommodate this growth. DOD is participating in the process to ensure

16 DOD officials told us that a second installation outside the continental
U. S., Fort Richardson, Alaska, is currently subject to a suit alleging
environmental violations that, if successful, could severely limit live-
fire training.

Page 15 GAO- 02- 614 Military Training

that its requirements are known early. There is no schedule for completing
the redesign, and until the redesign is completed, DOD cannot be certain how
its training will be affected.

 Air quality. The Clean Air Act requires federal agencies to analyze the
potential effect of proposed projects or activities on air quality.
According to DOD officials, installations located in areas that have not
met, or have only recently met, the National Ambient Air Quality Standards
must work with state or local regulatory agencies to offset any potential
emission increases from training activities. This ensures that the air
quality of the entire area is not significantly degraded. 17 This may create
conflicts with commercial development and could constitute a major impact as
competition for air emissions budgets and offsets increases.

 Noise. Noise problems are directly related to the degree that there are
people, wildlife, and noise- sensitive land uses (national parks,
wilderness, primitive areas, etc.) near military lands and low- level flying
routes. Expanding population near military installations, increased use of
public lands adjacent to military installations, training with more powerful
weapons, and increased night operations could all contribute to a growing
number of restrictions on DOD?s operations.

Service readiness data do not indicate to what extent encroachment has
significantly affected training readiness or costs, even though officials in
congressional testimonies and other forums cited examples of encroachment at
times preventing the services from training as they would like to. At the
same time, fully assessing the impact may be difficult because the services
lack information on (1) their training range requirements and (2) the
training range assets available to support these requirements. Similarly,
the services have very limited data indicating the effect of encroachment on
operating costs. Even though some service officials point to increasing
costs because of training workarounds related to encroachment, the services?
data systems do not capture these costs in any comprehensive manner. DOD
data, on the other hand, show fluctuations in total budget costs for
environmental conservation efforts, with an overall drop in obligations
since 1999, except for the Army. DOD

17 U. S. General Accounting Office, Air Pollution: Status of Implementation
and Issues of the Clean Air Act Amendments of 1990, GAO/ RCED- 00- 72
(Washington, D. C.: Apr. 17, 2000). Impact of

Encroachment on Readiness and Training Costs Is Not Well Reflected in DOD?s
Reported Data

Page 16 GAO- 02- 614 Military Training

officials acknowledge, however, that budget constraints and other priorities
have resulted in a backlog of some projects in this area.

DOD?s primary readiness reporting system should identify units that cannot
train to standards because of inadequate training ranges. Yet it is not
showing a problem in this area and rarely cites training range limitations
at all. Similarly, DOD?s quarterly reports to the Congress, which should
identify specific readiness problems, rarely mention encroachment as an
issue.

Each month, or whenever a change in readiness occurs, units report their
readiness status through the Global Status of Resources and Training System.
Units report their status in four resource areas, one of which is training.
18 Whenever a unit is not at the highest readiness level, it must identify
the reasons from a list (which includes inadequate training areas). We
analyzed monthly system data from active duty units in fiscal year 2001 and
found that training readiness remains high for most units. There are few
instances of units reporting lower training readiness, and even when they
did so, they rarely cited the lack of adequate training ranges, areas, or
airspace. Commanders may also include narrative comments in their readiness
assessments. We reviewed comments on readiness reports for fiscal year 2001
but found that training range limitations were not frequently cited.

Our recent assessment of training constraints outside the continental United
States (which are often greater than those found stateside) found that units
abroad rarely report lower training readiness in spite of concerns cited by
service officials that training constraints sometimes

18 The other three resource areas are equipment and supplies on hand,
equipment condition, and personnel. A unit?s training readiness status is
determined by the present level of training of assigned personnel compared
with the standards for a fully trained unit as defined by joint and service
directives. Service Reports Do Not

Report the Effects of Encroachment on Training Readiness

Page 17 GAO- 02- 614 Military Training

require workarounds. 19 We have long reported on limitations in DOD?s
readiness reporting system and the need for improvements. 20

DOD?s quarterly readiness reports to the Congress also identify few problems
from encroachment. DOD is required to report quarterly to Congress
describing readiness problems. We reviewed all reports submitted between
April 1999 and December 2001 and found two citations: in the April- June
1999 report, the Navy expressed concerns that encroachment was precluding
employment of high- altitude delivery tactics at the Naval Strike Air
Warfare Center, Fallon, Nevada; in the OctoberDecember 2000 report, DOD
noted that the Senior Readiness Oversight Council had convened in June 2000
to address encroachment issues. There was no further mention of encroachment
as a readiness problem in reports submitted through December 2001.

A full assessment of the effects of encroachment on readiness will be
limited without better information on the services? training range
requirements and on the range resources available to support those
requirements. The information is needed to establish a baseline for
measuring losses or shortfalls. Each service has, to varying degrees,
assessed its training range requirements. But none of them has
comprehensively reviewed available range resources to determine whether
assets are adequate to meet needs, and none has incorporated an assessment
of the extent that other types of training, such as virtual or constructive
training, 21 could help offset shortfalls. A DOD report on training lands
recognizes the importance of incorporating both approaches to training in
their plans. 22

19 See GAO- 02- 525. 20 See U. S. General Accounting Office, Military
Readiness: Congress Needs Better tools for Effective Oversight, GAO/ Tl-
NSIAD- 98- 124 (Washington, D. C.: Mar. 18, 1998); U. S. General Accounting
Office, Military Readiness: Improved Assessment Measures Are Evolving,

GAO/ T- NSIAD- 95- 117 (Washington, D. C.: Mar. 16, 1995); and U. S. General
Accounting Office, Military Readiness: DOD Needs to Develop a More
Comprehensive Measurement System, GAO/ NSIAD- 95- 29 (Washington, D. C.:
Oct. 27, 1994). 21 Virtual training uses simulation to replicate weapon
systems and settings. Constructive

training uses simulation to replicate units, weapon systems, and terrain. 22
Department of Defense, The Need for Ranges and Training Areas (Mar. 1999).
Full Assessment of

Readiness Impact Limited by Lack of Data on Training Requirements and
Inventory of Available Resources

Page 18 GAO- 02- 614 Military Training

Each service is responsible for determining its own resource needs for
training personnel. According to DOD, the process for identifying range and
training area needs is a ?top- down? process in which military planners
project the amount of training required to achieve military readiness.
Planners then formulate training plans using a ?strategies- to- tasks?
relationship. Once planners have promulgated the guidance, installation
commanders establish a ?bottom- up? process to ensure that requisite
training can be supported at locally available ranges and training areas or,
in case of a shortfall, to take action to acquire other assets. When there
is not enough rangeland to support the training, the commander examines
other training options, such as training aids, devices, simulators, and
simulation, or the commander may examine how to conduct live training on the
area available to the unit. The impact of a training range shortfall on a
unit?s training is the commander?s judgment. The process is functionally
similar among services but keyed to each service?s unique mission
requirements. Below are short descriptions of the assessments each service
carried out to determine its training range requirements.

In 2001, the Air Force completed an assessment it had begun 5 years earlier
to determine whether it had appropriate training space to ensure readiness.
The Air Force believed better resourcing decisions could be made if both the
requirements and current asset capabilities were stated more explicitly,
with resourcing decisions based on a rigorously derived assessment of gaps.
According to the assessment, in order to be defensible, infrastructure
requirements must be linked firmly to training requirements, which, in turn,
must be linked to operational requirements. To accomplish its assessment,
the Air Force identified its aircrew training requirements and compared them
to its existing range and airspace capabilities.

The Air Force study found that, nationwide, it has sufficient access to
airto- ground training ranges, albeit with some localized shortages. For
example, Pope Air Force Base, North Carolina, home of the 23d Fighter Group,
has no local range, and Moody Air Force Base, Georgia, home of the 347th
Rescue Wing, has insufficient capacity on its local ranges. This does not
mean, however, that the Air Force does not have encroachment issues that
need to be dealt with to preserve its air space. As already noted, the Air
Force?s major training facility, the Air Warfare Center at Nellis Air Force
Base, Nevada, has problems with urbanization that restrict aircraft takeoffs
with live ordnance. Air Force

Page 19 GAO- 02- 614 Military Training

The Navy began an assessment of its training range needs in 2001 and hopes
to complete the process late in fiscal year 2004. According to Navy
officials, the new database should quantify total range capability
requirements and each range?s contribution to readiness. The officials
believe that this should establish a link between training requirements and
readiness; formalize the process used to determine training range
requirements; better articulate the Navy?s training range strategy to DOD,
Congress, and the public; and better manage the effects of encroachment.

In January 2002, the Marine Corps completed an analysis of the extent to
which Camp Pendleton?s training facilities could support the training
requirements of two types of units (a light armored reconnaissance platoon
and an artillery battery) and two military specialties (a mortar man and a
combat engineer). The analysis identified to what extent the training tasks
for each unit or specialty could be conducted to standards in a ?continuous?
operating scenario (e. g., an amphibious assault and movement to an
objective) or in a fragmented manner (tasks completed anywhere on the camp).
The analysis found that from 60 to 69 percent of

?continuous? tasks and from 75 to 92 percent of the other training tasks
could be conducted to standards. A second analysis of four other types of
units or military specialties should be completed in June 2002. We were told
that the Marine Corps is planning to expand this effort to other
installations.

The Army has not conducted a complete analysis of its training requirements,
but it did conduct a training capacity analysis of its installations,
starting in 1997, that compared available assets and requirements as defined
by military planners (? doctrinal? standards). According to the analysis,
updated in 2002, many active duty installations do not have sufficient land
to support training to doctrinal standards. For example, only 22 percent of
active duty stateside installations have enough land to support their light
maneuver training needs, and only 42 percent of active duty installations
have enough land to support their heavy maneuver training needs. 23 These
installations are expected to use workarounds to meet training standards.

23 Training on light maneuver areas is limited to small units or units
having only wheeled vehicles; on heavy maneuver areas training is
unrestricted and covers all types of vehicles and equipment, including
tracked vehicles. Navy

Marine Corps Army

Page 20 GAO- 02- 614 Military Training

Although information gleaned from the studies is valuable for planning
purposes, we do not believe that the studies provide a complete picture of
the service?s training range needs. While live training may be preferred,
other options also need to be considered. We believe an analysis based
solely on live training may overstate an installation?s problems and does
not provide a complete basis for assessing training range needs or the
effects of encroachment.

A more complete assessment of training resources should include assessing
the potential for using virtual or constructive simulation technology to
augment live training. These alternatives sometimes allow units to train to
standards. And while they cannot replace live training and cannot fully
eliminate the impact of encroachment, they may help mitigate some training
range limitations. By increasing their investments in and use of virtual and
constructive simulation training, the services could also mitigate some of
the restrictions imposed on live training. In fact, the Army?s own guidance
recommends doing so and states that a commander?s analysis should consider
using virtual training or constructive training to partially offset live
training requirements (and thus the requirements for land). This is a
longstanding issue, one where we have previously cited the need to identify
the appropriate mix of live training and simulation technology. 24

To the extent that inventories of training ranges do exist, they are not
routinely shared with other services (or other organizations such as the
Special Operations Command). While DOD officials acknowledge the potential
usefulness of such data, there is no directory of DOD- wide training areas,
and commanders sometimes learn about capabilities available outside their
own jurisdiction by chance. All this makes it extremely difficult for the
services to leverage adequate assets that may be available nearby,
increasing the risk of inefficiencies, lost time and opportunities, delays,
added costs, and reduced training opportunities.

24 See U. S. General Accounting Office, Army Training: Various Factors
Create Uncertainty About Need for More Land, GAO/ NSIAD- 91- 103
(Washington, D. C.: Apr. 22, 1991); U. S. General Accounting Office, Army
Training: Computer Simulations Can Improve Common Training in Large Scale
Exercises, GAO/ NSIAD- 91- 67 (Washington, D. C.: Jan. 30, 1991); and U. S.
General Accounting Office, Operation Desert Storm: War Offers Important
Insights Into Army and Marine Corps Training Needs,

GAO/ NSIAD- 92- 240 (Washington, D. C.: Aug. 25, 1992). Other Options Not
Considered

in the Services? Studies No Shared Inventory of Training Ranges

Page 21 GAO- 02- 614 Military Training

Although there are examples of services sharing training ranges, these
arrangements are generally made through individual initiatives, not through
a formal or organized process that easily and quickly identifies all
available infrastructure. Navy Special Operations forces only recently
learned, for example, that some ranges at the Army?s Aberdeen Proving
Grounds are accessible from the water- a capability that is a key
requirement for Navy team training. Given DOD?s increasing emphasis on joint
capabilities and operations, having an inventory of defense- wide training
assets on all ranges, training or test, would seem to be a logical step
toward a more complete assessment of training range capabilities and
shortfalls that may need to be addressed.

DOD officials acknowledge that having a DOD- wide database of training
assets would also allow a more accurate measurement of Defense- wide
restrictions on training and of the cumulative effects of encroachment on
training readiness. In fact, an internal study group has suggested
developing assessment criteria that could be used to make a programmatic
assessment of the complete effects of encroachment on training readiness-
something DOD has not done.

Encroachment can increase the costs of conducting military training.
However, the services have not documented the overall impact of encroachment
on training costs. At the same time, DOD?s overall environmental
conservation funding, which would cover such things as endangered species
management, has fluctuated, rising between fiscal years 1996 and 1998 and
declining between fiscal years 1999 and 2001, except for the Army.

Officials at each of the locations we visited cited increasing workarounds
among the effects of encroachment on training, and many provided examples of
additional costs and actions associated with these workarounds. However,
none of the officials could provide composite data on the direct or indirect
costs they had incurred as a result of encroachment and workarounds. For
example, to protect marine mammals during naval gunfire exercises, the Navy
uses aircraft and surface vessels to observe the training area and hires
marine biologists to help crews spot and protect marine mammals. Marine
Corps officials also said that Camp Pendleton units are increasingly using
the Marine Corps Air Ground Combat Center, Twentynine Palms, California, to
work around training restrictions, and the officials provided estimates of
additional travel costs. But again, they could not provide us with aggregate
data showing how much their costs had increased. According to DOD officials,
Effects on Training Costs

Not Well Defined, While Environmental Conservation Costs Have Fluctuated

Impact on Overall Training Costs Not Documented

Page 22 GAO- 02- 614 Military Training

training expenses are paid with operations and maintenance funds, and
expenses specifically caused by encroachment are not identified separately
from other training expenses.

We examined the services? environmental conservation program obligations for
fiscal years 1996- 2001 and did not find any large or consistent increases
in spending. 25 As shown in figure 1, DOD?s spending on this program shows
only modest gains over the past 6 years, increasing in 1996- 98 but then
dropping among all components except for the Army.

25 DOD?s Environmental Conservation Program funds numerous activities,
including management and preservation of endangered species, control of
invasive species, and inventories of natural and cultural resources.
Environmental Conservation

Costs Have Fluctuated, but Without Significant Increase

Page 23 GAO- 02- 614 Military Training

Figure 1: DOD Environmental Conservation Program Obligations, Fiscal Years
1996- 2001

(Constant fiscal year 2001 dollars, in millions) Note: DOD agencies are not
shown but are included in the total. Source: DOD data.

Total DOD conservation program obligations fluctuated, increasing from $105
million in fiscal year 1996 to $136 million in fiscal years 1998 and 1999
and then decreasing to $124 million in fiscal year 2001. 26 Endangered
species management and preservation are a part of DOD?s conservation
program. If the services are performing additional conservation projects,
then the additional costs should be reflected in their environmental

26 For fiscal year 2003, DOD has requested $4 billion for its environmental
programs, which consist of environmental restoration, compliance, cleanup at
base closure sites, pollution prevention, environmental technology, and
conservation.

Page 24 GAO- 02- 614 Military Training

conservation program obligations. DOD documents attribute the fluctuations
in conservation program obligations to increased costs from preparing
Integrated Natural Resource Management Plans. An Army environmental official
also said that the increase in Army program obligations that occurred
between fiscal years 2000 and 2001 was due to the increased costs of
preparing the plans. According to DOD officials, the plans are required by
the Sikes Act and assist base commanders in conserving and rehabilitating
natural resources. DOD officials also acknowledge that budget constraints
and other priorities have resulted in some funding backlogs in this area.

DOD officials recognize the need for a comprehensive plan of administrative
actions and legislative proposals to address encroachment issues but, except
for a package of legislative proposals in late April 2002, have not yet
finalized such a plan. In June 2000, the services first presented their
encroachment problems to the Senior Readiness Oversight Council, which
recognized the need for a comprehensive plan to address encroachment issues.
However, as of April 2002, DOD was still developing a plan of administrative
actions. The task was first given to a group of subject matter experts, who
drafted plans of action for addressing the eight encroachment issues, but
the plans are not yet finalized and they contain few implementing details.
DOD is also drafting some policy and implementation directives. In December
2001, DOD appointed an Integrated Product Team to coordinate its
encroachment mitigation efforts, develop a comprehensive set of legislative
and regulatory proposals, and formulate and manage outreach efforts. The
team agreed on a tentative set of legislative proposals that could become
part of its comprehensive plan. Those legislative proposals were submitted
to the Congress in late April 2002 seeking to modify several statutes. The
proposed changes, in DOD?s view, would preserve its training ranges and
protect the environment. Other DOD organizations are also involved in
addressing encroachment issues, and they have made some progress.

DOD?s Senior Readiness Oversight Council took up the issue of encroachment
in June 2000 and tasked its Defense Test and Training Steering Group with
investigating the problem and developing a comprehensive plan of action. The
steering group formed a Sustainable Range Working Group, comprised of
subject matter experts who identified eight encroachment issues and drafted
separate action plans for each issue. The plans outlined recommended courses
of action, but they did not provide detailed implementation data. The plans
were briefed to the Comprehensive Plan

for Addressing Encroachment Not Finalized, but Some Action Has Been Taken

Actions Needed for a Comprehensive Plan Have Not Been Completed

Page 25 GAO- 02- 614 Military Training

Senior Readiness Oversight Council in November 2000. The council approved
the working group?s overall findings and recommendations and directed the
Test and Training Steering Group to take a number of actions, including
coordinating the plans with the services and appropriate agencies and
forwarding the results to the council by January 2001. The working group
continued its work on encroachment through 2001 but did not forward its
results to the council until late November 2001. DOD officials said that the
transition to the new administration, the events of September 2001, and
continuing internal deliberations delayed their efforts. They also said that
formulating possible legislative solutions for some of the problems was
difficult and consumed much of their time during 2001.

The working group focused on the eight encroachment issues identified in
this report. The group?s draft action plans included an overview and
analysis of an individual issue and current actions being taken, as well as
short-, mid-, and long- term strategies and actions to address the issue.
Examples of the types of future strategies and actions identified in the
draft plans include the following:

 Enhancing outreach efforts to build and maintain effective working
relationships with key stakeholders by making them aware of DOD?s need for
ranges and airspace, its need to maintain readiness, and its need to build
public support for sustaining training ranges. This was an overarching issue
for each of the encroachment issues.

 Clarifying the requirements of environmental and natural resource statutes
as they apply to DOD training and operations. One proposed action advocates
modifying the Sikes Act to permit installations managed under approved
Integrated Natural Resource Management Plans to be excluded from critical
habitat designations. Another would seek clarification of the term
?harassment? as used in the Marine Mammal Protection Act.

 Developing assessment criteria to identify all restrictions and determine
the cumulative effect these restrictions are having on readiness training.
The criteria would be appropriate for installations, special- use airspace,
atsea training areas, and other military operating areas. The draft plan
noted that while many examples of endangered species/ critical habitat and
land use restrictions are known, a programmatic assessment of the effect
these restrictions pose on testing and readiness training has never been
done.

 Developing a coordinated plan to obtain data, assess current range
conditions, and estimate the environmental impacts of current munitions

Page 26 GAO- 02- 614 Military Training

use on ranges. DOD would develop range clearance guidance and management
procedures on the basis of operational safety and environment constraints
associated with the hazards of unexploded ordnance, munitions scrap, target
debris, and other associated range scrap.

 Ensuring that any future base realignment and closure decisions thoroughly
scrutinize and consider the potential encroachment impact and restrictions
on operations and training of recommended base realignment actions.

 Improving coordinated and collaborative efforts between the military and
local communities in managing urban growth. Encouraging new and expanded
cooperative working relationships between base officials and city planners
and other local officials.

A more detailed overview of the working group?s recommended courses of
action and strategies for addressing each encroachment area is included in
appendix III. However, as noted, at the time we ended our review, the draft
action plans had not been finalized to provide a comprehensive plan for
addressing encroachment. DOD officials told us they consider the plans to be
working documents and stressed that many of their concepts remain under
review and may be dropped, altered, or deferred, while other proposals may
be added. No details were available on overall actions planned, clear
assignment of responsibilities, measurable goals and timeframes for
accomplishing planned actions, or identification of funding requirements-
information that would be needed in a comprehensive plan.

Effective management of encroachment issues on military training ranges has
been hindered by the divided management roles, responsibilities, and
accountability that exist among several different levels within the military
services and the Office of the Secretary of Defense. As discussed
previously, the Secretaries of the military departments are responsible for
training personnel and for maintaining their respective training ranges and
facilities. Within the Office of the Secretary of Defense, the Under
Secretary of Defense for Personnel and Readiness, the Deputy Under Secretary
of Defense for Installations and Environment, and the Director, Operational
Test and Evaluation, are responsible for different aspects of overseeing
training ranges and addressing encroachment issues.

Page 27 GAO- 02- 614 Military Training

In December 2001, the Deputy Secretary of Defense established a seniorlevel
Integrated Product Team to act as the coordinating body for encroachment
efforts and to develop a comprehensive set of legislative and regulatory
proposals by January 2002. The team agreed on a set of possible legislative
proposals for clarifying some encroachment issues, and, after internal
coordination deliberations, the proposals were submitted in late April 2002
to the Congress for its consideration.

According to DOD, its legislative proposals seek to clarify the relationship
between military training and a number of provisions in various conservation
statutes, including the Sikes Act, the Endangered Species Act, the Migratory
Bird Treaty Act, and the Marine Mammal Protection Act. Specifically, DOD?s
proposals would, among other matters:

 Preclude designation under the Endangered Species Act of critical habitat
on military lands for which Sikes Act Integrated Natural Resources
Management Plans have been completed. At the same time, the Endangered
Species Act requirement for consultation between DOD and other agencies on
natural resource management issues would be continued.

 Permit DOD to take migratory birds under the Migratory Bird Treat Act
without action by the Secretary of the Interior where the taking is in
connection with readiness activities. Also, they would require DOD to
minimize the taking of migratory birds to the extent practicable without
diminishment of military training or other capabilities, as determined by
DOD.

 Modify the definition of ?harassment? under the Marine Mammal Protection
Act as it applies to military readiness activities. 27

 Modify the conformity provisions of the Clean Air Act. The proposal would
maintain the department?s obligation to conform its military readiness
activities to applicable state implementation plans, but would give DOD

27 The Marine Mammal Protection Act?s definition of ?harassment? has been a
source of confusion. According to DOD, the statute defines ?harassment? in
terms of ?annoyance? or the ?potential to disturb,? standards that DOD
asserts are difficult to interpret. The statute, 10 U. S. C. 1362, defines
the term as any act of pursuit, torment, or annoyance which has the
potential to injure or disturb a marine mammal by causing disruption to
behavioral patterns such as migration, nursing, breeding, feeding, and
sheltering. DOD?s Legislative

Proposals to Address Encroachment Issues

Page 28 GAO- 02- 614 Military Training

3 years to demonstrate conformity. In the meantime, DOD could continue
military readiness activities.

 Change the definition of solid waste under the Solid Waste Disposal Act to
generally exclude explosives, unexploded ordnance, munitions, munition
fragments, or constituents when they are used in military training,
research, development, testing and evaluation; when not removed from an
operational range; when promptly removed from an off- range location; or
when recovered, collected, and destroyed on range at operational ranges.
Solid waste would not include buried unexploded ordnance when burial was not
a result of product use.

 Provide that ?release? under the Comprehensive Environmental Restoration,
Compensation, and Liability Act would not include explosives, unexploded
ordnance, munitions, munitions fragments, or constituents deposited on an
operational range incident to their normal and expected use. The proposal
explicitly preserves the President?s authority under the act to address an
imminent and substantial endangerment to the public health, welfare, or the
environment.

 Authorize the military departments to enter into agreements with private
conservation organizations concerning lands in the vicinity of military
installations to limit incompatible uses or preserve habitat so as to
eliminate or relieve environmental restrictions that might potentially
restrict or interfere with their military activities.

 Authorize the military departments to convey certain surplus real property
having conservation value to state and local governments or nonprofit
conservation organizations. In general, transferees would be required to use
and maintain the property for conservation purposes in perpetuity.

While time permitted only a cursory consideration of the proposals, they
appear to be another step by DOD toward developing a comprehensive approach
to managing encroachment affecting military training ranges.

Although DOD has not yet finalized a comprehensive plan of administrative
actions for addressing encroachment issues, it has made progress in several
areas, in addition to its legislative proposals. It is drafting a directive
that establishes the department?s policy on Sustainment of Ranges and
Operating Areas to serve as the foundation for addressing range
sustainability issues. The directive, currently in coordination within DOD,
would outline a policy framework for the Other Actions Underway

Page 29 GAO- 02- 614 Military Training

services to address encroachment on their ranges. According to a DOD
official, this directive will establish range sustainment as a planning and
management requirement for all operational ranges and will also direct
increased emphasis on outreach and coordination efforts with local
communities and stakeholders. In addition, a DOD official reports that the
department is currently preparing separate policy directives to establish a
unified noise abatement program for the department and to specify the
outreach and coordination requirements highlighted in the sustainable ranges
directive.

DOD has involved several other defense organizations in the range
sustainability issue. Several of these organizations were already addressing
specific encroachment issues prior to the services? initial presentation of
encroachment problems in June 2000. The Sustainable Ranges Working Group
incorporated the strategies already being implemented by these organizations
into its plans, and these organizations have continued working on their
original mandates. The organizations include the following:

 The DOD Operational and Environmental Executive Steering Committee for
Munitions is taking a life- cycle approach to DOD?s management and use of
munitions. The committee addresses issues associated with the removal of
unexploded ordnance at former ranges and the development of weapon systems
that avoid environmental problems. This committee recently completed work on
a DOD Munitions Action Plan to help the services address safety and
environmental concerns related to munitions.

 The Clean Air Act Services Steering Committee reviews emerging regulations
and works with the Environmental Protection Agency and the Office of
Management and Budget to protect DOD?s ability to operate. The committee
works to obtain changes in final regulations to accommodate military issues.
It has a number of subcommittees that address Clean Air Act issues that
impact ranges.

 The DOD Environmental Noise Working Group coordinates technical and policy
issues within DOD. The group is responsible for addressing aircraft and
ordnance- related environmental noise issues that have a bearing on DOD?s
ability to carry out its mission requirements.

DOD is also working to place national- level liaisons with key federal
agencies that have the potential to affect its range operations. For
example, a military officer has been assigned to the Office of the Secretary
of the Interior for two years, and DOD would like to assign liaisons at the

Page 30 GAO- 02- 614 Military Training

Environmental Protection Agency, the Department of Commerce, and the
Department of Agriculture. According to DOD officials, these liaisons would
represent DOD?s interests and would, it is hoped, be able to address and
solve range sustainability issues before they become problems.

DOD and the military services have lost training range capabilities and can
be expected to experience increased losses in the future absent efforts to
mitigate encroachment. The fact that DOD and service officials in
congressional testimonies and other forums cite the adverse effects of
encroachment on training, while commanders are not reporting any adverse
effects, suggests that additional steps are needed to improve the reporting
process. Our recent report on training limitations overseas recommended that
DOD make improvements in reporting training shortfalls. 28 At the same time,
a full assessment of the impact of encroachment on training and readiness
will be difficult without more complete data concerning training
requirements and available resources. Factors making such assessments
difficult include the lack of complete data on training range requirements,
failure to consider the potential for alternative training technologies to
augment live training, and inadequate inventories of facilities. While the
Army, Navy, and Marine Corps are at various stages in collecting this data,
DOD needs to ensure that these efforts continue to receive appropriate
management attention and are funded and staffed sufficiently to ensure
success. The information would also allow DOD to better defend its resource
requirements, focus and prioritize its efforts based on the relative
importance of land to the services? missions, make better stationing and
base closure decisions, and write more effective training plans. DOD has
taken some initial steps toward developing a comprehensive plan for
addressing encroachment issues. Of particular note are DOD?s recently
submitted legislative proposals. However, the proposals are only a piece of
the comprehensive plan DOD is working toward developing. A plan for other,
administrative actions to address encroachment issues remains to be
finalized. In finalizing its comprehensive plan, it is important that the
department clearly establishes goals and milestones for tracking progress,
identifies needed funding to accomplish the tasks, and assigns
responsibility for managing and coordinating the department?s efforts.

28 See GAO- 02- 525. Conclusions

Page 31 GAO- 02- 614 Military Training

While the Congress considers the department?s legislative proposals, we
recommend that the Secretary of Defense (1) require the services to develop
and maintain inventories of their training ranges, capacities, and
capabilities, and fully quantify their training requirements considering
complementary approaches to training; (2) create a DOD data base that
identifies all ranges available to the department and what they offer,
regardless of service ownership, so that commanders can schedule the best
available resources to provide required training; (3) finalize a
comprehensive plan for administrative actions that includes goals,
timelines, projected costs, and a clear assignment of responsibilities for
managing and coordinating the department?s efforts to address encroachment
issues on military training ranges; and (4) develop a reporting system for
range sustainability issues that will allow for the elevation of critical
training problems and progress in addressing them to the Senior Readiness
Oversight Council for inclusion in Quarterly Readiness Reports to the
Congress as appropriate.

In commenting on a draft of this report, the Deputy Under Secretary of
Defense (Readiness) substantially concurred with the substance of the report
and recommendations. He indicated that actions were underway or were planned
to deal with most of our recommendations. However, he suggested that we
modify the focus of our last recommendation pertaining to the development of
a reporting system for range sustainability issues. He said that our
recommendation should focus on operational readiness degradations (impacts
on combat capabilities) that result from encroachment and not merely on the
elevation of critical training problems and on the progress in addressing
them to the Congress. As noted elsewhere in this report, we recently
completed a companion report on training constraints overseas that
recommended improvements in readiness reporting; this goes to the heart of
the issue raised by DOD. We agree that DOD should give increased attention
to how encroachment issues affect operational readiness, and we would expect
the department to emphasize this issue in improving its readiness reporting
system. The recommendation in this report, however, goes beyond DOD?s
readiness reporting system. Given the department's often- voiced concerns
over the impact of encroachment on its training capabilities, our
recommendation in this report addresses the need for a system to foster
periodic reporting on critical training problems, such as those resulting
from encroachment, and on the progress in addressing them to the Senior
Readiness Oversight Council. This would enable the council to report
critical training problems, as appropriate, in its Quarterly Readiness
Reports to the Congress. Accordingly, we have not changed this
recommendation. Recommendations for

Executive Action Agency Comments and Our Evaluation

Page 32 GAO- 02- 614 Military Training

The Deputy Under Secretary?s comments are included in this report in
appendix IV. He also provided technical clarifications, which we
incorporated as appropriate.

Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 5 days after its issue date. At that time,
we will send copies of this report to the appropriate congressional
committees; the Secretaries of Defense, the Army, the Navy, and the Air
Force; and the Director, Office of Management and Budget. We also will make
copies available to others upon request. In addition, the report will be
available at no charge on the GAO Web site at http:// www. gao. gov.

Please contact me on (202) 512- 8412 if you or your staffs have any
questions concerning this report. In addition, Mark Little, Glenn Furbish,
James Reid, John Lee, Jason McMahon, John Van Schaik, and Stefano Petrucci
contributed to this report.

Barry W. Holman, Director Defense Capabilities and Management

Appendix I: Scope and Methodology Page 33 GAO- 02- 614 Military Training

To identify the impact encroachment has had, or is likely to have, on the
military service?s training range capabilities in the continental United
States, we visited four installations and two major commands. At each
installation or command we conducted field interviews and evaluated
available data on encroachment issues and how they impact training now, as
well as the potential for impacts to increase in the future. The
installations we visited were Fort Lewis, Washington; Marine Corps Base Camp
Pendleton, California; Eglin Air Force Base, Florida; and Nellis Air Force
Base, Nevada. The major commands we visited were the U. S. Atlantic Fleet,
Norfolk, Virginia, and the U. S. Special Operations Command, MacDill Air
Force Base, Tampa, Florida. The four installations and the U. S. Atlantic
Fleet were selected by the service staffs as having conditions
representative of the types of encroachment pressures they face, and the U.
S. Special Operations Command was selected at the request the Committee on
Government Reform staff as having unique encroachment pressures due to its
specialized training requirements. 1 We also interviewed officials and
received briefings at the service headquarters from officials who are
responsible for training and training area management. We discussed their
processes for identifying their respective training area needs, and the
resources available to support those needs. These officials include the
Range and Training Area Management Division, Training and Education Command,
Marine Corps Combat Development Command, Quantico, Virginia; the Land Use
and Military Construction Branch, Facilities and Services Division,
Installations and Logistics Department, Headquarters, U. S. Marine Corps,
Arlington, Virginia; Bases and Units Branch, Air Force Office of Civil
Engineering, Washington, D. C.; the U. S. Army Forces Command, Fort
McPherson, Georgia; Training Directorate, Office of the Army Deputy Chief of
Staff for Operations and Plans, Washington, D. C.; and the Fleet Readiness
Division, Office of the Deputy Chief of Naval Operations for Logistics,
Crystal City, Virginia.

To determine the effect training range losses have on the services? training
readiness and costs, we assessed DOD?s and the services? training ranges
requirements processes and their processes for identifying and managing
training readiness problems. Specifically, we gathered data on how the
services identify their training area needs, their processes for identifying
gaps between their training area needs and available resources, and the

1 Our review did not include Vieques (Atlantic Fleet Weapons Training
Facility), Puerto Rico, because the training constraints involving Vieques
are well known. Appendix I: Scope and Methodology

Appendix I: Scope and Methodology Page 34 GAO- 02- 614 Military Training

views of each of these officials on the impact of encroachment on training.
This includes officials from the Office of the Under Secretary of Defense
for Personnel and Readiness, Washington, D. C.; the Office of the Assistant
Under Secretary of Defense for Environmental Quality, Washington, D. C.; the
Range and Training Area Management Division, Training and Education Command,
Marine Corps Combat Development Command, Quantico, Virginia; the Land Use
and Military Construction Branch, Facilities and Services Division,
Installations and Logistics Department, Headquarters, U. S. Marine Corps,
Arlington, Virginia; the Bases and Units Branch, Air Force Office of Civil
Engineering, Washington, D. C.; the U. S. Army Forces Command, Fort
McPherson, Georgia; the Training Directorate, Office of the Army Deputy
Chief of Staff for Operations and Plans, Washington, D. C.; and the Fleet
Readiness Division, Office of the Deputy Chief of Naval Operations for
Logistics, Crystal City, Virginia. We reviewed fiscal year 2001 data from
the Global Status of Resources and Training System for the Army, Navy, Air
Force, and Marine Corps to determine the extent that commanders identify
training readiness problems caused by inadequate training ranges. For units
that reported low training readiness levels, we examined the specific
reasons cited for the lowered training readiness and also reviewed
commanders? comments to ascertain whether they attributed any of their
training readiness shortfalls to encroachment. We also analyzed cost data
from the DOD?s Environmental Quality Program for fiscal years 1996 through
2001 to determine if the services were incurring higher costs as a result of
environmental encroachment issues. We obtained this data from the Office of
the Assistant Deputy Under Secretary of Defense for Environmental Quality.
Finally, at each of the installations and major commands we visited, we
discussed costs associated with working around encroachment issues and
whether these costs, either direct or indirect, are captured in their
respective financial data systems.

To determine DOD?s progress in formulating a comprehensive plan for
addressing encroachment issues, we met with the members of the Sustainable
Ranges Working Group who are responsible for drafting DOD?s Sustainable
Ranges Action Plans. These include officials from the Office of the Under
Secretary of Defense for Personnel and Readiness, Washington, D. C.; the
Office of the Assistant Under Secretary of Defense for Environmental
Quality, Washington, D. C.; the Directorate of Operational Test and
Evaluation, Washington D. C.; the Land Use and Military Construction Branch,
Facilities and Services Division, Installations and Logistics Department,
Headquarters, U. S. Marine Corps, Arlington, Virginia; the Civil Aviation
Division, Air Force Directorate of Operations and Training, Washington, D.
C.; the Bases and Units Branch,

Appendix I: Scope and Methodology Page 35 GAO- 02- 614 Military Training

Air Force Office of Civil Engineering, Washington, D. C.; the Training
Directorate, Office of the U. S. Army Deputy Chief of Staff for Operations
and Plans, Washington, D. C.; the Office of Conformity and National
Environmental Protection Act Documentation, Operational Environmental
Compliance and Planning for the Chief of Naval Operations, Washington, D.
C.; the Office of Environmental Planning, Chief of Naval Operations,
Washington, D. C.; and the Facilities and Services Division, Installations
and Logistics Department, Headquarters, U. S. Marine Corps, Arlington,
Virginia. We discussed with these officials their analyses of the individual
issues, their rationale for selecting each action, milestones or timetables
that may exist, if any, and specific budgets for accomplishing each task. To
gain the perspective of the regulatory agencies responsible for DOD?s
proposed action plans, we conducted interviews with senior officials of the
Office of Enforcement and Compliance Assurance, Environmental Protection
Agency, Washington, D. C., and the Fish and Wildlife Service, Arlington,
Virginia.

We performed our review from May 2001 through April 2002 in accordance with
generally accepted government auditing standards.

Appendix II: Membership of DOD Encroachment- Related Groups

Page 36 GAO- 02- 614 Military Training

Table 1: Members of the Senior Readiness Oversight Council Membership

The Deputy Secretary of Defense The Chairman, Joint Chiefs of Staff Chief of
Staff, Air Force The Secretary of the Air Force Chief of Staff, Army The
Secretary of the Army Chief of Naval Operations Commandant of the Marine
Corps The Secretary of the Navy Under Secretary of Defense for Acquisition,
Technology and Logistics Under Secretary of Defense for Personnel and
Readiness The Under Secretary of Defense Policy Under Secretary of Defense
(Comptroller)

Source: DOD.

Table 2: Members of the Defense Test and Training Steering Group Membership

Director of Operational Test and Evaluation Directorate Deputy Under
Secretary of Defense (Readiness) Deputy Under Secretary of Defense
(Installations and Environment) Director of Defense Research and Engineering
Directorate Deputy Director of Development Test and Evaluation for Strategic
and Tactical Systems Directorate Principal Director of Interoperability for
Defense Information Systems Agency Senior Advisor for Defense Threat
Reduction Agency Deputy of Test, Simulation, and Evaluation for Missile
Defense Agency Chief of Technology Assessment Group for Defense Intelligence
Agency Deputy Director of Force Structure Resources and Assessment (J- 8)
for Joint Staff Deputy Under Secretary of the Army (Operations Research)
Director of Navy Test, Evaluation and Technology Requirements Director of
Air Force Test and Evaluation Directorate Executive Director of United
States Marine Corps Systems Command Director of Training Directorate for
Office of the Army Deputy Chief of Staff Operations and Plans Head of
Aviation Manpower and Training Programs Branch for Chief of Naval Operations
(N789) Director of Operations and Planning for Deputy Chief of Staff of Air
Force for Air and Space Operations Commanding General of United States
Marine Corps Training and Education Command Deputy Director of Resources and
Ranges for Operational Test and Evaluation Directorate Director of Readiness
and Training for Deputy Under Secretary of Defense (Readiness)

Source: DOD.

Appendix II: Membership of DOD Encroachment- Related Groups

Appendix II: Membership of DOD Encroachment- Related Groups

Page 37 GAO- 02- 614 Military Training

Table 3: Members of the Integrated Product Team Membership

Under Secretary of Defense for Personnel and Readiness Deputy Under
Secretary of Defense (Installations and Environment) Director of Operational
Test and Evaluation Directorate Assistant Secretary of the Army for
Installations and Environment Assistant Secretary of the Navy for
Installations and Environment Assistant Secretary of the Air Force for
Installations, Environment, and Logistics Director of the Army Training
Directorate Director of the Navy Fleet and Battle Group Training Branch
Director of the Air Force Directorate of Operations and Training Principal
Deputy Assistant Secretary of Defense for Legislative Affairs DOD Deputy
General Counsel for Environment and Installations

Source: DOD.

Appendix III: DOD?s Draft Sustainable Ranges Action Plans for Addressing
Encroachment Issues

Page 38 GAO- 02- 614 Military Training

Between June 2000 and November 2001, DOD drafted sustainable ranges action
plans for addressing range sustainability issues associated with endangered
species habitat on military installations, environmental legislation
covering unexploded ordnance and munitions, competition for the radio
frequency spectrum, protected marine resources, competition for airspace,
air pollution, noise pollution, and urban growth around military
installations. Each action plan provides an overview and analysis of its
respective encroachment issue, along with potential strategies and actions
to address the issue. In December 2000, the plans were presented to DOD
leadership, who approved the overall findings and recommendations and
directed that the proposals be coordinated with the services and appropriate
agencies. As of April 2002, the proposals continued to be reviewed and
refined within DOD and the services. Consequently, DOD considers these plans
working documents and many of the concepts proposed in them may be dropped,
altered, or deferred, and other proposals may be added. A short description
of each draft action plan, as of August 2001, follows.

To address problems related to the presence of endangered species on DOD
lands and the requirement to designate critical habitat, the proposed
strategy of the draft Endangered Species Act Action Plan was to (1) prevent
military training ranges from becoming a home for threatened and endangered
species; (2) improve DOD?s knowledge of endangered species and the impacts
of military activities on those species and species at risk; (3) cultivate
better partnerships with the Fish and Wildlife Service and the National
Marine Fisheries Service for managing endangered species; (4) negate the
need for critical habitat designation; and (5) seek legislative
clarification of laws where appropriate. To implement this strategy, the
plan proposes to seek clarification of species and habitat issues in the
Endangered Species Act. In addition, it proposes working with the Fish and
Wildlife Service to implement a policy that Integrated Natural Resource
Management Plans qualify as special management plans that negate the need
for critical habitat designation. It also proposes establishing a forum for
information exchange between DOD, the services, the Fish and Wildlife
Service, and the Department of the Interior to improve communication and
coordination on endangered species issues; conducting a programmatic
assessment of the effect endangered species restrictions have on military
testing and training; matching installation mission requirements to
endangered species recovery priorities so that installations with lesser
mission priorities have greater recovery burdens; and working proactively to
prevent the listing of at- risk species. It further proposes to build and
expand upon existing partnerships that integrate Appendix III: DOD?s Draft
Sustainable

Ranges Action Plans for Addressing Encroachment Issues

Endangered Species Act Action Plan

Appendix III: DOD?s Draft Sustainable Ranges Action Plans for Addressing
Encroachment Issues

Page 39 GAO- 02- 614 Military Training

DOD biodiversity planning with regional planning so that defense lands do
not become a home for threatened and endangered species, improve available
information on the impacts to endangered species from military training, and
develop policies on the use of land outside installations to meet
conservation requirements.

To address problems related to the application of environmental statutes to
unexploded ordnance and munitions constituents on active ranges, the draft
Unexploded Ordnance and Munitions Constituents Action Plan proposes a
strategy to improve and integrate requirements to develop, test, and use
munitions, while ensuring explosives safety and protecting human health,
safety, and the environment. To implement this strategy, the plan proposes
to develop a DOD munitions expenditure database, work with the regulatory
community to develop consistent responses to the environmental issues of
unexploded ordnance, and identify funding and resource requirements for the
unexploded ordnance mitigation program. This proposal would include a
consistent risk assessment methodology to deal with munitions and their
constituents on closed, transferring, and transferred ranges; a sustainable
range management program that integrates training requirements with
environmental and explosive safety requirements; a munitions acquisition
plan to minimize undesirable environmental and explosives safety impacts;
and a tailored legislative clarification of laws that could apply to
military munitions. In addition, the plan proposes to implement public
relations efforts to inform the Congress, regulators, and the public about
the military?s munitions requirements and develop community outreach and
educational tools that inform stakeholders and monitor the success of
stakeholder involvement. Another proposal calls for collecting scientific
data and developing new technologies to identify and reduce the
environmental impact of munitions, supporting the assessment of the
environmental and human health effects of ordnance disposal, and focusing on
the development of bullets and munitions with fewer environmental effects
than current ammunition.

To deal with problems caused by the increasing demand and competition for
radio frequency spectrum, the draft Radio Frequency Spectrum Action Plan
proposes a strategy of policy management and technological innovation. The
policy strategy proposes to engage the Congress in developing new laws and
policies that maintain DOD?s spectrum, while supporting the implementation
of the laws that currently protect reserved bandwidth, and to increase
funding for the Central Test and Evaluation Unexploded

Ordnance and Munitions Constituents Action Plan

Radio Frequency Spectrum Action Plan

Appendix III: DOD?s Draft Sustainable Ranges Action Plans for Addressing
Encroachment Issues

Page 40 GAO- 02- 614 Military Training

Investment Program to leverage existing technologies to improve the use of
current bandwidth. Proposed technological innovations include increasing the
efficiency of spectrum use by developing new systems to operate at higher
spectrum, scheduling of current band usage, and developing band- sharing
technologies.

To sustain maritime training capability, the draft Maritime Sustainability
Action Plan proposes a strategy of (1) engagement with regulators and
legislators, (2) collection of data on marine species and mitigation costs,
and (3) legislative and policy changes. Actions proposed include (1)
engaging regulators and legislators to further define and enforce marine
environmental laws, (2) developing a clearer definition of harassment of
endangered species to be applied to DOD activities, (3) initiating an
outreach program aimed at ensuring that members of Congress understand the
need for continued military training in offshore operating areas and the
military?s previous record of environmental stewardship, (4) initiating data
collection efforts to increase the amount of scientific data available about
marine species and their habitats and to gather data on the fiscal and
operational impacts of compliance with maritime environmental regulations,
(5) incorporating scientific data into exercise planning to minimize impacts
on endangered species, (6) developing an acquisition policy that new weapons
system use mature technologies to reduce the environmental impacts of
testing and training, (7) investigating the use of closed environments (i.
e., not the open ocean) for ordnance testing, and (8) minimizing, to the
maximum extent possible, the impact of new acoustic sensors and explosives
on the marine environment.

To address airspace problems associated with the increased requirements of
new generations of weapons and systems and the growing competition with the
commercial aviation industry, the draft National Airspace Redesign Action
Plan proposes a strategy to ensure that DOD requirements are included in the
national airspace redesign process by engaging the Federal Aviation
Administration in the process. The objectives of the national airspace
redesign process are to maintain system safety; to decrease system delay;
and to increase system flexibility, predictability, and user access. DOD?s
proposed actions to implement this strategy are to form (1) a senior- level
policy board on federal aviation to review the scope and progress of DOD
activities and develop guidance and processes for the future and (2) an
oversight group for DOD and Federal Aviation Administration national
airspace system integration. Maritime

Sustainability Action Plan

National Airspace Redesign Action Plan

Appendix III: DOD?s Draft Sustainable Ranges Action Plans for Addressing
Encroachment Issues

Page 41 GAO- 02- 614 Military Training

To address air quality issues at the federal, state, and local levels, the
draft Air Quality Action Plan proposes a tiered strategy that consists of
reviewing emerging regulations and working to obtain changes to final
regulations to accommodate military issues. The action plan recommendations
rely on engagement and outreach on the part of DOD and the services to
prevent future adverse impact on the use of training ranges. The elements of
these actions include approaching each specific issue from a position of
knowledge, starting at the local level with sound positions and working up
through major command and headquarters with federal and state regulators to
seek resolution; employing modeling and simulation as necessary; and
exploring science and technology initiatives to facilitate future equipment
and processes that emit fewer pollutants than legacy equipment.

To respond to noise encroachment, the draft Airborne Noise Action Plan
proposes a strategy that will engage other agencies and organizations when
they propose restrictions or programs that could impact DOD missions. DOD
believes that self- imposed restrictions and concessions by installations
often jeopardize their ability to accomplish their training missions.
Consequently, it identified actions that would result in two goals: (1)
developing a comprehensive integrated noise program and (2) factoring noise
into the development and acquisition process.

To address encroachment from urban growth, the draft Urban Growth Action
Plan proposes a strategy that will try to influence state and local
governments to adopt, implement, and enforce local encroachment prevention
plans and programs so that future incompatibilities between civilian growth
and military training needs might be avoided. The strategy relies on a
series of actions related to public relations and coordinated land use
programs to engage local communities. It includes (1) forming a coordinated
effort within DOD to build and expand upon existing urban development
encroachment partnerships; (2) ensuring installations have effective public
outreach plans; (3) requiring each installation and range to implement a
comprehensive planning process; (4) expanding the Joint Land Use Study
program to address range encroachment; (5) working with local authorities to
implement appropriate land use zoning near military installations; and (6)
having regional environmental coordinators monitor and advocate for DOD on
emerging land use issues. Air Quality Action

Plan Airborne Noise Action Plan

Urban Growth Action Plan

Appendix IV: Comments from the Department of Defense

Page 42 GAO- 02- 614 Military Training

Appendix IV: Comments from the Department of Defense

Appendix IV: Comments from the Department of Defense

Page 43 GAO- 02- 614 Military Training

See p. 31. See p. 31.

See p. 31. See p. 31.

Appendix IV: Comments from the Department of Defense

Page 44 GAO- 02- 614 Military Training (350075)

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