Testimony 

Before the Committee on Environment 

and Public Works, U.S. Senate 

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 9:30 a.m. EST 

Wednesday, April 2, 2003 MILITARY TRAINING

DOD Approach to Managing 

Encroachment on Training 

Ranges Still Evolving 

Statement of Barry W. Holman, Director 

Defense Infrastructure Issues 

GAO-03-621T 
Encroachment was reported as having affected some training range 

capabilities, requiring workarounds—or adjustments to training events—and 

sometimes limiting training, at all stateside installations and major commands 

GAO visited. GAO has identified similar effects abroad. Encroachment 

generally limits the time that training ranges are available and the types of 

training conducted. This in turn limits units’ ability to train as they would 

fight. Most encroachment issues are caused by population growth and urban 

development. Because both are expected to increase, as are the speed and 

range of weapon systems used on training ranges, the problems are also 

expected to increase. 

Despite DOD-voiced concerns about encroachment’s effects on training, 

service readiness data in 2002 did not show the impact of encroachment on 

training readiness or costs, although DOD’s most recent quarterly report to 

Congress on readiness did tie a training issue directly to encroachment. While 

individual services are making some assessment of training requirements and 

limitations imposed by encroachment, comprehensive assessments remain to 

be done. Likewise, complete inventories of training ranges are not yet 

available to foster sharing of ranges on an interservice or joint basis. This 

increases the risk of inefficiencies, lost time and opportunities, delays, and 

added cost. Also, although some services have reported higher costs because 

of encroachment-related workarounds for training, service data systems do 

not capture the costs comprehensively. 

DOD has made some progress in addressing individual encroachment issues, 

such as implementing some short-term actions, proposing legislation to clarify 

the relationship between training and conservation statutes, and issuing a 

range sustainment directive. But more is required for a comprehensive plan, 

as recommended by GAO earlier, that clearly identifies steps to be taken, 

goals and milestones to track progress, and required funding. 

Urban Growth near Fort Benning, Georgia, from 1955 to 1996 and Projected for 2008 

Note: Columbus and Phenix City are shown to the upper left of Fort Benning, Georgia. 

DOD faces growing challenges in 

carrying out realistic training at 

installations and training ranges—

land, air, and sea—because of 

encroachment by outside factors. 

These include urban growth, 

competition for radio frequencies 

or airspace, air or noise pollution, 

unexploded ordnance and munition 

components, endangered species 

habitat, and protected marine 

resources. Building on work 

reported on in 2002, GAO assessed 

(1) the impact of encroachment on 

training ranges, (2) DOD’s efforts 

to document the effect on 

readiness and cost, and (3) DOD’s 

progress in addressing 

encroachment. 

GAO is not making any new 

recommendations. However, GAO 

did make recommendations in 

reports issued in April and June 

2002 (GAO-02-525 and GAO-02-

614). They were aimed at 

(1) improving the quality of 

readiness reporting to better reflect 

training constraints and (2) helping 

DOD develop a comprehensive 

plan for dealing with encroachment 

issues and improving the 

information and data available for 

identifying and reporting on the 

effects of encroachment. In 

addition, the Congress directed 

DOD to report periodically on its 

progress in addressing 

encroachment issues and requires 

GAO to review those reports. 

www.gao.gov/cgi-bin/getrpt?GAO-03-621T.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact Barry W. 

Holman at (202) 512-8412 or 

holmanb@gao.gov. 

Highlights of GAO-03-621T, a testimony 

before the Committee on Environment and 

Public Works, U.S. Senate 

April 2, 2003

MILITARY TRAINING 

DOD Approach to Managing 

Encroachment on Training Ranges 

Still Evolving 
Page 1 GAO-03-621T Military Training 

Mr. Chairman and Members of the Committee: 

I am pleased to have the opportunity to discuss the results of our work 

involving the constraints that encroachment places on military training. As 

you know, senior Department of Defense (DOD) and service officials have 

testified that they face growing difficulties in carrying out realistic training 

at installations and training ranges1

 because of so-called “encroachment” 2

issues, which limit their ability to train military forces at the desired levels 

and proficiencies. The eight encroachment issues identified by DOD are 

urban growth around military installations, competition for radio 

frequency spectrum; air pollution; noise pollution; competition for 

airspace; unexploded ordnance and munitions components;3

 endangered 

species habitat; and protected marine resources. 

My testimony is largely built on work we reported on last year concerning 

the effects of encroachment in the continental United States on military 

training and readiness.4

 Last year we also reported on the constraints on 

training of U.S. forces overseas.5

 The findings of the two reviews have 

some similarities. Today, I would like to briefly highlight our findings 

regarding (1) the growing impact of encroachment on training range 

capabilities, (2) DOD’s efforts to document the effects of encroachment on 

readiness and costs, and (3) DOD’s process in addressing encroachment. 

 1

 The term “training ranges” in this testimony refers to air, live-fire, ground maneuver, and 

sea ranges. 

2

 DOD defines encroachment as the cumulative result of any and all outside influences that 

inhibit normal military training and testing. 

3

 Unexploded ordnance are munitions that (1) have been primed, fused, armed, or 

otherwise prepared for action; (2) have been fired, dropped, launched, projected, or placed 

in such a manner as to constitute a hazard to operations, installations, personnel, or 

material; and (3) remain unexploded either by malfunction, design or any other cause. 

Munitions components—which DOD calls “constituents”—include things such as 

propellants, explosives, pyrotechnics, chemical agents, metal parts, and other inert 

components that can pollute the soil or ground water. 

4

 U.S. General Accounting Office, Military Training: DOD Lacks a Comprehensive Plan to 

Manage Encroachment on Training Ranges, GAO-02-614 (Washington, D.C.; June 11, 

2002). The Chairmen of the Committee on Government Reform and its Subcommittee on 

National Security, Emerging Threats and International Relations, House of Representatives, 

requested this review. 

5

 U.S. General Accounting Office, Military Training: Limitations Exist Overseas but Are 

Not Reflected in Readiness Reporting, GAO-02-525 (Washington, D.C.: Apr. 30, 2002). The 

Chairman of the Subcommittee on Readiness and Management Support, Committee on 

Armed Services, U.S. Senate, requested this review. 
Page 2 GAO-03-621T Military Training 

On the basis of our observations and discussions with officials at 

installations and major commands we visited last year here in the United 

States, we obtained numerous examples where encroachment had 

affected some training range capabilities, requiring workarounds—or 

adjustments to training events—and, in some cases, limited training. We 

identified similar effects overseas. The potential problem with 

workarounds is that they lack realism and can lead to the practice of 

tactics that are contrary to those used in combat. Officials, both stateside 

and abroad, reported that encroachment at times limits the time that 

training ranges are available and the types of training that can be 

conducted. Service officials believe that urbanization and population 

growth is primarily responsible for encroachment in the United States and 

is likely to cause more training range losses in the future. 

Despite concerns voiced repeatedly by DOD officials about the effects of 

encroachment on training, DOD’s readiness reports did not indicate the 

extent to which encroachment was adversely affecting training readiness 

and costs. In fact, at the time we did our review, most readiness reports 

showed that units had a high state of readiness; and they were largely 

silent on the issue of encroachment. Recently, however, one DOD 

readiness report indicated that the Air Force has attributed environmental 

encroachment to a reduced capability to conduct flight training.6

 We have 

previously reported on limitations in DOD’s readiness reporting.7

 While 

improvements in readiness reporting can and should be made to better 

show any shortfalls in training, DOD’s ability to fully assess training 

limitations and their overall impact on training capabilities and readiness 

will be limited without (1) more complete baseline data, such as a 

comprehensive database, on all training range capabilities and the 

services’ training range requirements and (2) full consideration of how live 

training capabilities may be complemented by other forms of training, 

such as those available through training devices and simulations. These 

actions will not replace other steps needed to deal with encroachment, but 

they are key to better define the magnitude of the encroachment problem 

now and in the future. At the same time, it is important to note that while it 

is widely recognized that encroachment results in workarounds that can 

 6

 U.S. Department of Defense, Quarterly Readiness Report to the Congress, Institutional 

Training Readiness Report for Fiscal Year 2002, Unclassified Annex E (Washington, D.C.: 

Jan. 2003). 

7

 U.S. General Accounting Office, Military Readiness: New Reporting System Is Intended 

to Address Long-Standing Problems, but Better Planning Is Needed, GAO-03-456

(Washington, D.C.: Mar. 28, 2003). 

Summary 
Page 3 GAO-03-621T Military Training 

increase training costs, those costs are not easily aggregated to measure 

their full effect. 

Although DOD has made some progress in addressing individual 

encroachment issues, that effort is still evolving; and more work will be 

required to put in place a comprehensive plan, as we recommended 

earlier, that clearly identifies steps to be taken, goals and milestones to 

track progress, and required funding. We reported last year that the 

department had prepared draft action plans that deal with each 

encroachment issue separately, but information was limited on specific 

actions planned, time frames for completing them, and funding needed. In 

December 2001, DOD directed an Integrated Product Team 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. Last year and just recently, DOD submitted a 

package of legislative proposals, which it describes as clarifications, 

seeking to modify several statutory requirements. We are aware that 

consideration of these and other related legislative proposals affecting 

existing environmental legislation will need to include potential trade-offs 

among multiple policy objectives and issues on which we have not taken a 

position. At the same time, we also understand that DOD recently asked 

the services to develop procedures for invoking the national security 

exceptions under a number of environmental laws. Historically, DOD and 

the services have been reluctant to seek such exceptions; and we are 

aware of only a couple of instances where this has been done. In our 

report last June on stateside encroachment issues, we made several 

recommendations aimed at helping DOD develop a comprehensive plan 

for dealing with encroachment and improve the information and data 

available for identifying and reporting on the effects of encroachment. 8

Our two reports last year recommended that DOD develop reports that 

accurately capture the causes of training shortfalls and objectively report 

units’ ability to meet their training requirements. Following our reports, 

DOD issued a range sustainment directive9

 to establish policy and assign 

responsibilities for the sustainment of test and training ranges; and the 

Special Operations Command developed a database identifying the 

training ranges it uses, type of training conducted, and restrictions on 

training. The department also plans to develop a set of internal policies 

 8 GAO-02-614. 

9

 U.S. Department of Defense, Directive: Sustainment of Ranges and Operating Areas 

(OPAREAs), 3200.15, Jan. 10, 2003. 
Page 4 GAO-03-621T Military Training 

and procedures based on the range sustainment directive, strengthen and 

empower its management structure to deal with range issues, and take a 

more proactive role in working with local governments and organizations. 

We are not making any new recommendations in this testimony. As you 

may be aware, Mr. Chairman, section 366 of the Bob Stump National 

Defense Authorization Act for Fiscal Year 2003 requires a series of yearly 

reports to the Congress dealing with encroachment issues beginning this 

year, and a requirement for GAO to review those reports. The first of those 

reports was required to be submitted along with the President’s budget for 

fiscal year 2004. That report was to describe DOD’s progress in developing 

a comprehensive plan to use existing authorities to address training 

constraints on the use of military lands, marine areas, and airspace that 

are available in the United States and overseas for training. However, to 

our knowledge, DOD has not yet issued this report. The Act also requires 

the submission of a report not later than June 30, 2003, on plans of the 

department to improve its readiness reporting to reflect the readiness 

impact that training constraints have on specific units of the armed forces. 

Military ranges and training areas are used primarily to test weapon 

systems and train military forces. 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 DOD officials, there has been a slow but steady increase in 

encroachment issues that have limited the use of training facilities, and the 

gradual accumulation of these issues increasingly threatens training 

readiness. DOD has identified eight such encroachment issues: 

• Designation of critical habitat under the Endangered Species Act of 

1973. Under the Act, agencies are required to ensure that their actions 

do not destroy or adversely modify habitat that has been designated for 

endangered or threatened species. Currently, over 300 such species are 

found on military installations. In 1994, under the previous 

administration 14 agencies signed a federal memorandum of 

Background 
Page 5 GAO-03-621T Military Training 

understanding10 for implementing the Endangered Species Act.11 The 

agencies agreed to establish or use existing regional interagency 

working groups to identify geographic areas within which the groups 

would coordinate agency actions and overcome barriers to conserve 

endangered species and their ecosystems. Such cooperative 

management could help DOD share the burden of land use restrictions 

on military installations that are caused by encroachment issues, but 

implementation of this approach has been limited. We are currently 

reviewing this issue.12

• Application of environmental statutes to military munitions. DOD 

believes that the Environmental Protection Agency could apply 

environmental statutes to the use of military munitions, shutting down 

or disrupting military training. According to DOD officials, 

uncertainties about future application and enforcement of these 

statutes limit their ability to plan, program, and budget for compliance 

requirements. 

• Competition for radio frequency spectrum. The telecommunications 

industry is pressuring for the reallocation of some of the radio 

frequency spectrum from DOD to commercial control. DOD reports 

that over the past decade, it has lost about 27 percent of the frequency 

spectrum allocated for aircraft telemetry. And we previously reported 

additional allocation of spectrum could affect space systems, tactical 

communications, and combat training.13

 10 Federal Interagency Memorandum of Understanding for Implementation of the 

Endangered Species Act, September 1994. 

11 The 14 federal agencies included the Department of Agriculture’s Forest Service; the 

Department of Defense; the U.S Army Corps of Engineers; the Department of Commerce’s 

National Marine Fisheries Service; the Department of the Interior’s Bureau of Land 

Management, Bureau of Mines, Bureau of Reclamation, Fish and Wildlife Service, Minerals 

Management Service, and National Park Service; the Department of Transportation’s 

Federal Aviation Administration, Federal Highway Administration, and Coast Guard; and 

the Environmental Protection Agency. 

12 At the request of the Committee on Government Reform and its Subcommittee on 

National Security, Emerging Threats and International Relations, House of Representatives, 

we are reviewing (1) the extent to which management of endangered species and related 

land use restrictions are shared by DOD and other federal landowners and (2) the efforts 

that DOD and/or other federal landowners have undertaken to promote cooperative 

management and additional steps needed to enhance this approach. We expect to report on 

the results of this work later this year. 

13 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 6 GAO-03-621T Military Training 

• Marine regulatory laws that require consultation with regulators 

when a proposed action may affect a protected resource. Defense 

officials say that the process empowers regulators to impose 

potentially stringent measures to protect the environment from the 

effects of proposed training in marine environments. 

• Competition for airspace. Increased airspace congestion limits the 

ability of pilots to train as they would fly in combat. 

• Clean Air Act requirements for air quality. DOD officials believe the 

Act requires controls over emissions generated on Defense 

installations. New or significant changes in range operations also 

require emissions analyses, and if emissions exceed specified 

thresholds, they must be offset with reductions elsewhere. 

• Laws and regulations mandating noise abatement. DOD officials 

stated that weapon systems are exempt from the Noise Control Act of 

1972, but DOD must assess noise impact under the National 

Environmental Policy Act. As community developments have expanded 

closer to military installations, concerns over noise from military 

operations have increased. 

• Urban growth. DOD says that unplanned or “incompatible” commercial 

or residential development near training ranges compromises the 

effectiveness of training activities. Local residents have filed lawsuits 

charging that military operations lowered the value or limited the use 

of their property. 

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 units use to compare readiness 

against designed operational goals.14 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 addition, 

DOD is required under 10 U.S.C. 117 to prepare quarterly readiness reports 

to Congress. The reports are based on briefings to the Senior Readiness 

 14 The Global Status of Resources and Training System, which units use to report their 

readiness status monthly or whenever a change occurs. Units report readiness in four 

resource areas, including training. If a unit is not at the highest readiness level, it must 

identify the reasons from a list that includes training areas. Commanders may also include 

narrative statements with more detailed explanations. 
Page 7 GAO-03-621T Military Training 

Oversight Council, a forum assisted by the Defense Test and Training 

Steering Group. In June 2000, the council directed the steering group to 

investigate encroachment issues and develop a comprehensive plan of 

action. 

The secretaries of the military services 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 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; and the Director, 

Operational Test and Evaluation, provides advice on tests and evaluations. 

On the basis of what we have seen, the impact of encroachment on 

training ranges has gradually increased over time, reducing some training 

capabilities. Because most encroachment problems are caused by urban 

development and population growth, these problems are expected to 

increase in the future. 

Although the effects vary by service and by individual installation, 

encroachment has generally 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 causes 

workarounds that may limit the amount or quality of training. Installations 

overseas all reported facing similar training constraints. 

Some of the problems reported by installations we visited last year were 

those related to urban growth, radio frequency spectrum interference, air 

quality, noise, air space, and endangered species habitat. For example, in 

response to local complaints, Fort Lewis, Washington, voluntarily ceased 

some demolitions training. Eglin Air Force Base, Florida, officials reported 

the base’s major target control system received radio frequency spectrum 

interference from nearby commercial operators. Nellis Air Force Base, 

Nevada, officials reported that urban growth near the base and related 

safety concerns had restricted flight patterns of armed aircraft, causing 

mission delays and cancellations. They also reported that they receive 

approximately 250 complaints about noise each year. About 10 percent of 

Marine Corps Base Camp Pendleton, California, had been designated as 

Encroachment Has 

Reduced Some 

Capabilities, and Its 

Effects Are Likely to 

Grow 
Page 8 GAO-03-621T Military Training 

critical habitat for endangered species. Atlantic Fleet officials reported 

encroachment problems stemming from endangered marine mammals and 

noise. They said that the fleet’s live-fire exercises at sea were restricted, 

and night live-fire training was not allowed. 

More recently, in January 2003, DOD’s Special Operations Command 

reported that its units encounter a number of obstacles when scheduling 

or using training ranges.15 According to the report, the presence of 

endangered species and marine mammals on or near ranges result in 

restrictions on training for at least part of the year—closing the area to 

training, prohibiting live fire, or requiring modified operations. For 

example, a variety of endangered species live on the training areas of the 

Navy Special Warfare Command in California, particularly on Coronado 

and San Clemente islands. Due to environmental restrictions, Navy Special 

Warfare units report that they 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 addition, the Special Operations Command owns no training ranges of 

its own and largely depends on others for the use of their training ranges. 

As a result, command officials advised us that they must train under 

operational and scheduling restrictions imposed by its host commands. 

For example, the command normally trains at night; and because range 

management personnel are not often available at night, this prevents such 

training. Also, on many ranges, the command reported that priority is 

given to larger units than special operations units causing it to postpone or 

cancel training. According to the report, ranges are also inadequately 

funded for construction, maintenance, repairs, and upgrades. This results 

in some commanders using their own funds in order to prevent the ranges 

from becoming dangerous or unusable. 

The Special Operations Command, while expressing concern for the 

future, reported that none of the eight encroachment issues identified by 

DOD had yet stopped military training, due mostly to the creativity and 

flexibility of its commanders and noncommissioned officers. In general, 

 15 U.S. Special Operations Command, Tiger Team Report: Global Special Operations 

Forces Range Study, Jan. 27, 2003. The Special Operations Command recommended that 

all components needed to create master range plans that addressed their current and future 

range issues and solutions. The command also recommended that plans identify and 

validate training requirements and facilities available and define the acceptable limits of 

workarounds. 
Page 9 GAO-03-621T Military Training 

when obstacles threaten training, the unit will find a workaround to 

accomplish the training. In some instances, the unit may travel to another 

training facility, costing additional money for transportation and 

potentially requiring an extended stay at the training site. By sending units 

away to train, the command limits its ability to send people on future 

travel for training or missions due to efforts to control the number of days 

per year that servicemembers are deployed away from home. Other 

workarounds consist of commands using different equipment, such as 

plastic-tipped bullets; changing maneuvering, firing, and training methods 

to overcome training obstacles; and using facilities that need repair. 

According to the Special Operations Command, all of these workarounds 

expend more funds and manpower in order to accomplish its training 

mission. 

DOD and military service officials said that many encroachment issues are 

related to urban growth around military installations. They noted that 

most, if not all, encroachment issues result from urban and population 

growth and that around DOD installations this is increasing at a rate higher 

than the national average. Figure 1 illustrates the increase in urban growth 

encroachment near Fort Benning, Georgia, while the fort has remained 

relatively unchanged. According to DOD officials, new residents near 

installations often view military activities as an infringement on their 

rights, and some groups have organized in efforts to reduce operations 

such as aircraft and munitions training. At the same time, according to 

Defense officials, the increased speed and range of weapon systems are 

expected to increase training range requirements. 
Page 10 GAO-03-621T Military Training 

Figure 1: Historical and Projected Urban Growth Near Fort Benning, Georgia 

Note: (Top left to right) Urban growth near Fort Benning, Georgia, in 1955 and 1985. (Bottom left to 

right) Urban growth near Fort Benning, Georgia, in 1996 and projected for 2008. 
Page 11 GAO-03-621T Military Training 

Despite the loss of some training range capabilities, service readiness data 

did not show the impact of encroachment on training readiness. However, 

DOD’s January 2003 quarterly report to Congress did tie an Air Force 

training issue directly to encroachment. 

Even though DOD officials in testimonies and many other occasions have 

repeatedly cited encroachment as preventing the services from training to 

standards, DOD’s primary readiness reporting system did not reflect the 

extent to which encroachment was a problem. In fact, it rarely cited 

training range limitations at all. Similarly, DOD’s quarterly reports to 

Congress, which should identify specific readiness problems, hardly ever 

mentioned encroachment as a problem. 

This is not surprising to us because we have long reported on limitations 

in DOD’s readiness reporting system and the need for improvements; our 

most recent report was issued just last week.16 Furthermore, on the basis 

of our prior reports on readiness issues and our examination of 

encroachment, we do not believe the absence of data in these reports 

concerning encroachment should be viewed simply as “no data, no 

problem!” Rather, as with other readiness issues we have examined over 

time, it suggests a lack of attention on the part of DOD in fully assessing 

and reporting on the magnitude of the encroachment problem. 

However, DOD’s most recent quarterly report did indicate a training issue 

that is tied directly to encroachment. The January 2003 Institutional 

Training Readiness Report showed that the Air Force has rated itself as 

C-2 for institutional flight training.17 This indicates that it is experiencing 

some deficiencies with limited impact on capabilities to perform required 

institutional training. The Air Force attributed this to training range 

availability and encroachment combined with environmental concerns 

that are placing increasing pressure on its ability to provide effective and 

realistic training. The Air Force also reported that sortie18 cancellations are 

becoming a more common occurrence and may soon adversely impact the 

quality of training. For example, the spotting of a Sonoran Pronghorn on 

 16 GAO-03-456. 

17 By a way of comparison, C-1 rating is when a unit is at its highest readiness level and is 

able to fully meet its mission. 

18 A sortie is one mission by a single aircraft. 

Effects of 

Encroachment on 

Training Readiness 

and Costs Have Not 

Been Reflected in 

Most Service 

Readiness Reports 
Page 12 GAO-03-621T Military Training 

the Barry M. Goldwater Range forces immediate cancellation or relocation 

of scheduled missions. 

Readiness reporting can and should be improved to address the extent of 

training degradation due to encroachment and other factors. However, it 

will be difficult for DOD to fully assess the impact of encroachment on its 

training capabilities and readiness without (1) obtaining more complete 

information on both training range requirements and the assets available 

to support those requirements and (2) considering to what extent other 

complementary forms of training may help mitigate some of the adverse 

impacts of encroachment. The information is needed to establish a 

baseline for measuring losses or shortfalls. 

We previously reported that the services did not have complete 

inventories of their training ranges and that they do not routinely share 

available inventory data with each other (or with other organizations such 

as the Special Operations Command). DOD officials acknowledge the 

potential usefulness of such data and have some efforts underway to 

develop these data. However, since there is no complete directory of DODwide training areas, commanders sometimes learn about capabilities 

available on other military bases by chance. All this makes it extremely 

difficult for the services to leverage assets that may be available in nearby 

locations, increasing the risk of inefficiencies, lost time and opportunities, 

delays, added costs, and reduced training opportunities. 

Although the services have shared 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. Last year, for example, our reported on encroachment19

noted that the Navy Special Operations forces recently learned that some 

ranges at the Army’s Aberdeen Proving Grounds in Maryland 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 would 

seem to be a logical step toward a more complete assessment of training 

range capabilities and shortfalls that may need to be addressed. 

This issue was recently reinforced by the January 2003 range report by the 

Special Operations Command, which found that none of the services had 

 19 GAO-02-614. 
Page 13 GAO-03-621T Military Training 

joint databases or management tools to combine all training ranges into a 

single tool accessible to all commands. The command concluded that such 

a centralized database would contribute to improving unit readiness and 

mission success for all components. At the same time, we cannot be sure 

of the extent to which recent military operations in the Middle East could 

impact future training requirements. DOD will need to reassess lessons 

learned from these operations. 

Each service has, to varying degrees, assessed its training range 

requirements and limitations due to encroachment. For example, the 

Marine Corps has completed one of the more detailed assessments of the 

degree to which encroachment has affected the training capability of 

Camp Pendleton, California. The assessment determined to what extent 

Camp Pendleton could support the training requirements of two unit types 

and two specialties by identifying the tasks that 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. Some of the tasks that could not 

be conducted to standards were the construction of mortar- and artilleryfiring positions outside of designated areas, cutting of foliage to 

camouflage positions, and terrain marches. Marine Corps officials said 

they might expand the effort to other installations. At the same time, the 

Air Force has funded a study at Shaw Air Force Base, South Carolina, 

which focuses on airspace requirements; and the Center for Navy Analysis 

is reviewing encroachment issues at Naval Air Station Fallon, Nevada. We 

have not had an opportunity to review the progress or the results of these 

efforts. In its 2003 range study report, the Special Operations Command 

compiled a database identifying the training ranges it uses, type of training 

conducted, and restrictions on training. In its study, the command 

recommended that a joint training range database be produced and made 

available throughout DOD so that all training ranges, regardless of service 

ownership, may be efficiently scheduled and utilized. 

While recent efforts show increased activity on the part of the services to 

assess their training requirements, they do not yet represent a 

comprehensive assessment of the impacts of encroachments. We have also 

previously reported that the services have not incorporated an assessment 

of the extent that other types of complementary training could help offset 

shortfalls. We believe these assessments, based solely on live training, may 

overstate an installation’s problems and do not provide a complete basis 

for assessing training range needs. A more complete assessment of 
Page 14 GAO-03-621T Military Training 

training resources should include assessing the potential for using virtual 

or constructive simulation technology to augment live training. However, 

based on our prior work I must emphasize, Mr. Chairman, that these types 

of complementary training cannot replace live training and cannot fully 

eliminate the impact of encroachment, though they may help mitigate 

some training range limitations. 

In addition, while some service officials have reported increasing costs 

because of workarounds related to encroachment, the services’ data 

systems do not capture these costs in any comprehensive manner. In its 

January 2003 report, the Special Operations Command noted that the 

services lacked a metric-base reporting system to document the impact of 

encroachment or track the cost of workarounds in either manpower or 

funds. We noted last year that DOD’s overall environmental conservation 

funding, which also covers endangered species management, had 

fluctuated, with an overall drop (except for the Army) in obligations since 

1999. If the services are indeed conducting more environmental 

assessments or impact analyses as a result of encroachment, the 

additional costs should be reflected in their environmental conservation 

program obligations. 

DOD has made some progress in addressing individual encroachment 

issues, including individual action plans and legislative proposals. But 

more will be required to put in place a comprehensive plan that clearly 

identifies steps to be taken, goals and milestones to track progress, and 

required funding. Senior DOD officials recognized the need to develop a 

comprehensive plan to address encroachment issues back in November 

2000, but efforts to do so are still evolving. To their credit, DOD and the 

services are increasingly recognizing and initiating steps to examine range 

issues more comprehensively and in a less piecemeal fashion. 

Recent efforts began in 2000 when a working group of subject matter 

experts was tasked with drafting action plans for addressing the eight 

encroachment issues. The draft plans include an overview and analysis of 

the issues; and current actions being taken, as well as short-, mid-, and 

long-term strategies and actions to address the issues. Some of the shortterm actions implemented include the following. 

• DOD has finalized, and the services are implementing, a Munitions 

Action Plan—an overall strategy for addressing the life-cycle 

management of munitions to provide a road map that will help DOD 

meet the challenges of sustaining its ranges. 

Progress in 

Addressing 

Encroachment Issues 

Still Evolving 
Page 15 GAO-03-621T Military Training 

• DOD formed a Policy Board on Federal Aviation Principles to review 

the scope and progress of DOD activities and to develop the guidance 

and process for special use air space. 

• DOD formed a Clean Air Act Services’ Steering Committee to review 

emerging regulations and to work with the Environmental Protection 

Agency and the Office of Management and Budget to protect DOD’s 

ability to train. 

• DOD implemented an Air Installation Compatible Use Zone Program to 

assist communities in considering aircraft noise and safety issues in 

their land use planning. 

Some future strategies and actions identified in the draft plans addressing 

the eight encroachment issues 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 training ranges, its need to maintain readiness, and its need to 

build public support for sustaining training ranges. 

• Developing assessment criteria to determine the cumulative effect of 

all encroachment restrictions on training capabilities and readiness. 

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 

training readiness has never been done. 

• 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 base officials 

and city planners and other local officials in managing urban growth. 

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. 

After internal coordination deliberations, the proposals were submitted in 

late April 2002 to Congress for consideration. According to DOD, the 

legislative proposals sought to “clarify” the relationship between military 
Page 16 GAO-03-621T Military Training 

training and a number of provisions in various conservation and 

compliance statutes, including the Endangered Species Act, the Migratory 

Bird Treaty Act, the Marine Mammal Protection Act, and Clean Air Act. 

DOD’s proposals would, among other things, do the following: 

• 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 

remain. 

• Permit DOD to “take” migratory birds under the Migratory Bird Treaty 

Act without action by the Secretary of the Interior, where the taking 

would be in connection with readiness activities, and 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.20

• Modify the conformity provisions of the Clean Air Act. The proposal 

would maintain the Department’s obligation to conform military 

readiness activities to applicable state implementation plans but would 

give DOD 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. 

 20 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, feeding, breeding, and sheltering. 
Page 17 GAO-03-621T Military Training 

Of the above proposals, Congress passed, as part of the fiscal year 2003 

defense authorization legislation, a provision related to the Migratory Bird 

Treaty Act.21 Under that provision, until the Secretary of the Interior 

prescribes regulations to exempt the armed forces from incidental takings 

of migratory birds during military readiness activities, the protections 

provided for migratory birds under the Act do not apply to such incidental 

takings. In addition, Congress authorized DOD to enter agreements to 

purchase property or property interests for natural resource conservation 

purposes, such as creating a buffer zone near installations to prevent 

encroachment issues, such as urban growth.22

In February 2003, DOD submitted to Congress the Readiness and Range 

Preparedness Initiative for fiscal year 2004. In it, the department restates a 

number of legislative proposals from 2002 and includes a proposal 

concerning the Marine Mammal Protection Act. In the 2004 initiative, the 

department seeks to reconcile military readiness activities with the Marine 

Mammal Protection Act by adding language to sections of title 16 of the 

U.S. Code. 

We are aware that consideration of these legislative proposals affecting 

existing environmental legislation will need to include potential tradeoffs 

among multiple policy objectives and issues on which we have not taken a 

position. At the same time, we also understand that DOD recently asked 

the services to develop procedures for invoking the national security 

exceptions under a number of environmental laws. Historically, DOD and 

the services have been reluctant to seek such exceptions; and we are 

aware of only a couple of instances where this has been done. 

Our two reports last year both recommended that DOD develop reports 

that accurately capture the causes of training shortfalls and objectively 

report units’ ability to meet their training requirements. At the time we 

completed our reviews in 2002, DOD’s draft action plans for addressing the 

eight encroachment issues had not been finalized. DOD officials told us 

that they consider the plans to be working documents and stressed that 

many 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 assignments of responsibilities, 

 21 Section 315, P.L. 107-314, Dec. 2, 2002. 

22 Section 2811, P.L. 107-314, Dec. 2, 2002 (codified at 10 U.S.C. 2684). 
Page 18 GAO-03-621T Military Training 

measurable goals and time frames for accomplishing planned actions, or 

funding requirements—information that would be needed in a 

comprehensive plan. Our report on stateside encroachment problems also 

recommended that DOD develop and maintain a full and complete 

inventory of service and department-wide training infrastructure; consider 

more alternatives to live training; and ensure that the plan for addressing 

encroachment includes goals, timelines, responsibilities, and projected 

costs.23 Our recently issued report on overseas training also recommended 

that DOD develop reports that accurately capture the causes of training 

shortfalls and objectively report units’ ability to meet their training 

requirements.24

Following our reports, DOD issued a range sustainment directive to 

establish policy and assign responsibilities for the sustainment of test and 

training ranges,25 and the Special Operations Command developed a 

database identifying the training ranges it uses, type of training conducted, 

and restrictions on training. In addition, DOD is working with the other 

regulatory agencies in the federal government to manage the way in which 

laws are enforced and plans to issue four more directives that cover 

outreach, range clearance, community noise, and Air Installation 

Compatibility Use Zone. 

In the Bob Stump National Defense Authorization Act for Fiscal Year 2003, 

Congress required the Secretary of Defense to develop a comprehensive 

plan for using existing authorities available to the Secretary of Defense 

and the secretaries of the military departments to address training 

constraints on the use of military lands, marine areas, and airspace that 

are available in the United States and overseas for training.26 As part of the 

preparation of the plan, the Secretary of Defense was expected to conduct 

an assessment of current and future training range requirements of the 

armed forces and an evaluation of the adequacy of current DOD resources 

(including virtual and constructive training assets as well as military lands, 

marine areas, and airspace available in the United States and overseas) to 

meet those current and future training range requirements. Also, as you 

 23 GAO-02-614. 

24 GAO-02-525. 

25 U.S. Department of Defense, Directive: Sustainment of Ranges and Operating Areas 

(OPAREAs), 3200.15, Jan. 10, 2003. 

26 Section 366, P.L. 107-314, Dec. 2, 2002. 
Page 19 GAO-03-621T Military Training 

may be aware, Mr. Chairman, that Act requires annual reports to Congress 

dealing with encroachment issues beginning this year and requires GAO to 

review those reports. The first of those reports was required to be 

submitted along with the President’s budget for fiscal year 2004. That 

report was to describe the progress in developing a comprehensive plan to 

address training constraints. To our knowledge, Mr. Chairman, DOD has 

not completed a comprehensive plan or provided Congress with the 

progress report. Officials of the Office of the Secretary of Defense said 

that they plan to report to Congress later this calendar year. The Act also 

requires the submission of a report not later than June 30, 2003, on the 

department’s plans to improve its readiness reporting to reflect the 

readiness impact that training constraints have on specific units of the 

armed forces. 

This concludes my statement. I would be pleased to answer any questions 

you or other members of the Committee may have at his time. 

Contact and Acknowledgment 

For further contacts regarding this statement, please contact Barry W. 

Holman on (202) 512-8412. Individuals making key contributions to this 

statement include Tommy Baril, Byron Galloway, Jane Hunt, John Lee, 

Mark A. Little, Patti Nichol, Michelle K. Treistman, and John Van Schaik. 

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