Testimony

Before the Committee on Government Reform, House

of Representatives

United States General Accounting Office

GAO

For Release on Delivery

Expected at

10:00 a.m., EDT

Thursday

May 16, 2002

MILITARY TRAINING

DOD Needs a

Comprehensive Plan to

Manage Encroachment

on Training Ranges

Statement of Barry W. Holman, Director,

Defense Capabilities and Management

GAO-02-727T
Page 1 GAO-02-727T Military Training

Mr. Chairman and Members of the Committee:

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

work involving the constraints that encroachment places on military

training. As you know, senior Department of Defense (DOD) and military

services 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 required levels of proficiency. The eight

encroachment issues identified by DOD are endangered species’ critical

habitat, unexploded ordnance and munitions components,

3

 competition

for radio frequency spectrum, protected marine resources, competition for

airspace, air pollution, noise pollution, and urban growth around military

installations.

My testimony is based on the work that we recently carried out at your

request on the effects of encroachment in the continental United States on

military training and readiness.

4

 I should also note that we recently

completed a review of constraints on the training of U.S. forces overseas.

5

The findings of the two reviews have some similarities. In response to the

questions you asked us to address, I will discuss (1) the growing impact of

encroachment on training range capabilities, (2) the effects of

 1

 The term “training ranges” in this statement 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 is 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 such things as propellants,

explosives, pyrotechnics, chemical agents, metal parts, and other inert components that

can pollute the soil or groundwater.

4

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

Plan to Manage Encroachment on Training Ranges, GAO-02-614 (Washington, D.C.,

expected to be issued in June 2002).

5

 See 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, Subcommittee on Readiness and Management Support, Committee on

Armed Services, U.S. Senate, requested this review.
Page 2 GAO-02-727T Military Training

encroachment on training readiness and costs, and (3) DOD’s progress in

developing a comprehensive plan for addressing encroachment.

Officials at all the installations and major commands we visited here in the

continental United States reported that encroachment had affected some

of their training range capabilities, requiring work-arounds—or

adjustments to training events. Each of the installations we visited

reported having lost some capabilities in terms of the time that ranges

were available or the types of training that could be conducted. We

identified similar effects in most countries overseas in which U.S. forces

are based. The potential problem with work-arounds is that they lack

realism and can lead to the practice of tactics that are contrary to those

used in combat. Service officials believe that population growth is

responsible for much of their past and present encroachment problems in

the United States and is likely to cause more training range losses in the

future.

Despite concerns voiced by DOD officials about the effects of

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

extent to which encroachment is adversely affecting training. In fact, most

reports show that units have a high state of readiness, and they are largely

silent on the issue of encroachment. 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 on training range capabilities and limitations and

the services’ training range requirements and (2) a 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 are not meant to take the place of other steps that may be

needed to deal with encroachment, but they are key to better depicting the

net effects of encroachment now and in the future. At the same time, it is

important to note that while it is widely recognized that encroachment

results in work-arounds that can increase training costs, those costs are

not easily determined or aggregated to measure their full effect. The

funding associated with DOD’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 service components except for the Army.

Summary
Page 3 GAO-02-727T Military Training

DOD officials recognize the need for a comprehensive plan to address

encroachment but have not yet finalized such a plan. DOD has made some

progress in addressing individual encroachment issues, but more will be

required to put in place a comprehensive plan to deal with 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 the specific actions planned, the time

frames for completing them, the clear assignment of responsibilities, and

the funding needed—elements that will be key to better ensuring the

completeness and viability of a comprehensive plan. Although DOD has

not yet finalized a comprehensive plan, progress has been made in a

number of areas by a variety of departmental organizations. For example,

a steering committee has been addressing explosive safety and

environmental concerns and has recently completed work on a munitions

action plan that addresses safety and environmental concerns related to

munitions.

DOD also recently submitted a package of legislative proposals to

Congress to deal with various encroachment issues. DOD describes this

package as seeking to “clarify” the relationship between military training

and a number of provisions in various environmental statutes. The

consideration of these legislative proposals will require Congress to

consider the potential trade-offs among multiple environmental policy

objectives and their impact on military training.

In our draft report 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.6

 In

our recently issued report on overseas training limitations, we made

recommendations to improve the quality of readiness reporting to better

reflect training constraints and to provide for a more comprehensive

approach to addressing training limitations.7

Military ranges and training areas are used primarily to test weapons

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

 6

 See GAO-02-614.

7

 See GAO-02-525.

Background
Page 4 GAO-02-727T Military Training

ranges for artillery, armor (e.g., tanks), 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, a slow but steady increase in encroachment

problems has limited the use of training facilities and the gradual

accumulation of these problems increasingly threatens training readiness.

DOD has identified eight 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.

• 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 the future application and enforcement of these

statutes limit the officials’ ability to plan, program, and budget for

compliance requirements.

• Competition for frequency spectrum. The telecommunications

industry is pressuring for the reallocation of some of the radio

frequency spectrum from federal to commercial control. DOD claims

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

spectrum allocated for aircraft telemetry. And we previously reported

that additional reallocation of spectrum could affect space systems,

tactical communications, and combat training.

8

• 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 marine environment from

the effects of proposed training.

 8

 See 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 5 GAO-02-727T Military Training

• Competition for airspace. Increased airspace congestion limits pilots’

ability to train to fly as they would in combat.

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

the act requires controls over emissions generated on DOD

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

state that weapons systems are exempt from the Noise Control Act of

1972, but DOD must still assess the impact of noise under the National

Environmental Policy Act. As community developments have expanded

closer to military installations, concerns over noise from military

operations have increased. DOD officials report that pressure from

groups at the local, regional, and state levels can serve to restrict or

reduce military training.

• 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 that units use to report readiness

against designed operational goals.9

 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 a quarterly readiness

report to Congress. The report is based on briefings to the Senior

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

Training Steering Group. In June 2000, the council directed the steering

 9

 Units use the Global Status of Resources and Training System to report their readiness

status monthly or whenever a change occurs 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 inadequate training areas. Commanders may also include narrative statements

with more detailed explanations.
Page 6 GAO-02-727T Military Training

group to investigate encroachment and develop and recommend 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.

Over time, the impact of encroachment on training ranges has gradually

increased. Because most encroachment problems are caused by

population growth and urban development, 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 reported facing similar training constraints.

Below are brief descriptions of some of the problems as reported by the

installations and organizations we visited in the continental United States.

• Marine Corps Base Camp Pendleton, California. Camp Pendleton

officials report encroachment problems related to endangered species

and their habitat, urbanization, air space, and noise. Recently, about 10

percent of the installation has been designated as critical habitat for

endangered species. Airspace restrictions limit the number of days that

weapons systems can be employed, and noise restrictions limit night

helicopter operations.

• Fort Lewis and the Yakima Training Center, Washington. Fort Lewis

officials report encroachment problems related to noise, air quality,

endangered species and their habitat, urbanization, frequency

spectrum, and munitions and munitions components. In response to

Encroachment Has

Reduced Some

Capabilities, and Its

Effects Are Likely to

Grow
Page 7 GAO-02-727T Military Training

local complaints, Fort Lewis voluntarily ceased some demolitions

training. Air quality regulations restrict the operation of smoke

generators at Fort Lewis. Habitat considerations restrict maneuvers

and off-road vehicle training in parts of both installations. There is

periodic communications interference.

• Nellis Air Force Base and Nevada Test and Training Range, Nevada.

Nellis Air Force Base has encroachment problems stemming from

urbanization and noise. Nellis officials said that urban growth near the

base and safety concerns have restricted the flight patterns of armed

aircraft, causing mission delays and cancellations. They also report that

the two installations receive a total of some 250 complaints about noise

each year.

• Eglin Air Force Base, Florida. Eglin Air Force Base officials report

encroachment problems involving endangered species habitat, noise,

urban growth, and radio frequency spectrum. Eglin contains habitat for

two endangered species. Aircraft must alter flight paths to avoid

commercial towers and noise-sensitive areas. The base’s major target

control system receives frequency interference from nearby

commercial operators.

• U.S. Atlantic Fleet. Atlantic Fleet officials report encroachment

problems stemming from endangered marine mammals and noise. Livefire exercises at sea are restricted, and night live-fire training is not

allowed. Naval Air Station Oceana, Virginia, is the target of frequent

noise complaints.

• Special Operations Command. This command owns no training ranges

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

ranges. The Navy component of the Special Operations Command

reports being most directly affected by encroachment from endangered

species and urban development. A variety of endangered species live

on the training areas used by the Navy Special Warfare Command in

California, particularly on Coronado and San Clemente islands.

Because of 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. The Special Operations

Command has previously been able to mitigate deficiencies in local

training areas by traveling to alternate training sites. However, recent

limitations on the amount of time that units can spend away from their
Page 8 GAO-02-727T Military Training

home station 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 military service officials said that many encroachment issues are

related to urbanization around military installations. They noted that most,

if not all, encroachment issues result from population growth and

urbanization and that growth around DOD installations is increasing at a

rate higher than the national average. 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 one Defense Department official, the increased speed

and range of weapons systems are expected to increase training range

requirements. Our recent report on training limitations overseas noted

that, while some restrictions are longstanding, the increase in restrictions

facing U.S. forces in many cases is the result of growing commercial and

residential development affecting established training areas and ranges.10

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

do not indicate that encroachment has significantly affected training

readiness. Even though in testimonies and during many other occasions

DOD officials have cited encroachment as preventing the services from

training as they would like, DOD’s primary readiness reporting system

does not reflect the extent to which encroachment is a problem. In fact, it

rarely cites training range limitations at all. Similarly, DOD’s quarterly

reports to Congress, which should identify specific readiness problems,

hardly ever mention encroachment as a problem. I should also note that

our recent assessment of training limitations overseas (which are often

greater than those found stateside) found that units abroad rarely report

lower training readiness in spite of concerns cited by DOD officials that

training constraints overseas can require work-arounds or in some

instances prevent training from being accomplished.

Although readiness reporting can and should be improved to address

training degradation due to encroachment and other factors, it will be

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

 10 See GAO-02-525.

Effects of

Encroachment on

Training Readiness

Are Not Reflected in

Reported Data
Page 9 GAO-02-727T Military 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.

A full assessment of the effects of encroachment on training capabilities

and readiness will be limited without better information on the services’

training range requirements and limitations and on the range resources

available to support those requirements. Each service has, to varying

degrees, assessed its training range requirements. For example, the Marine

Corps has completed one of the more detailed assessments among the

services concerning the degree to which encroachment has affected the

training capability of Camp Pendleton. The assessment determined to

what extent Camp Pendleton could support the training requirements of

two unit types (a light armored reconnaissance platoon and an artillery

battery) and two specialties (a mortar man and a combat engineer) by

identifying the tasks that could be conducted according 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

the training tasks in the continuous scenario and from 75 to 92 percent of

the tasks in the fragmented scenario could be conducted according to

standards. Some of the tasks that could not be conducted according to

standards were the construction of mortar- and artillery-firing positions

outside of designated areas, cutting of foliage to camouflage positions, and

terrain marches. Marine Corps officials are completing a further analysis

of four other types of units or specialties at Camp Pendleton and said they

might expand the effort to other installations.

However, none of the services’ studies have comprehensively reviewed

available range resources to determine whether assets are adequate to

meet needs, and they have not incorporated an assessment of the extent

that other types of complementary training could help offset shortfalls. We

believe that relying solely on the basis of live training, these assessments

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

basis for assessing training range needs. A more complete assessment of

training resources should include assessing the potential for using virtual
Page 10 GAO-02-727T Military Training

or constructive simulation technology to augment live training.11 While

these types of complementary training cannot replace live training and

cannot eliminate encroachment, they may help mitigate some training

range limitations. Stated another way, these actions are not meant to take

the place of other steps to deal with encroachment, but they are key to

more fully depicting the net effects of encroachment on training

capabilities now and in the future.

Furthermore, to the extent that the services do have inventories of their

training ranges, they do not routinely share them with each other (or with

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 in nearby locations, increasing the risk of

inefficiencies, lost time and opportunities, delays, added costs, and

reduced training opportunities.

Although the services have been known to share 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, 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 DOD-wide

training assets and capabilities would seem to be a logical step toward a

more complete assessment of training range capabilities and shortfalls

that may need to be addressed.

While some service officials have cited increasing costs because of workarounds related to encroachment, the services’ data systems do not

capture these costs in any comprehensive manner. At the same time,

DOD’s overall environmental conservation program funding,12 which also

 11 Virtual training uses simulation to replicate weapons systems and settings.

Constructive training uses simulation to replicate units, weapons systems, and terrain.

12 DOD’s Environmental Conservation Program funds numerous activities, including

endangered species management and preservation programs, invasive species control, and

inventories of natural and cultural resources.
Page 11 GAO-02-727T Military Training

covers endangered species management, has fluctuated with only a

modest gain over the past 6 years, increasing in fiscal years 1996-98, but

then dropping among all components, except for the Army. Total DOD

conservation program obligations fluctuated, increasing from $105 million

in fiscal year 1996 to $136 million in fiscal years 1998-99, and then

decreasing to $124 million in fiscal year 2001.13 DOD documents attribute

the fluctuation in conservation program obligations to increased costs

from preparing Integrated Natural Resource Management Plans.

Senior DOD officials recognized the need for a comprehensive plan to

address encroachment back in November 2000, but they have not yet

finalized such a plan.

The task was first given to a working group of subject matter experts, who

drafted plans of action for addressing the eight encroachment issues. The

draft plans include an overview and analysis of the issue, and current

actions being taken, as well as recommended 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.

• 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 that 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 the operations of and training for recommended

base realignment actions.

 13 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.

Comprehensive Plan

for Addressing

Encroachment Is Not

Finalized
Page 12 GAO-02-727T Military Training

• Improving coordinated and collaborative efforts between base officials

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

At the time we completed our review, the draft action plans 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 the overall actions planned, clear assignments of

responsibilities, measurable goals and time frames for accomplishing

planned actions, or funding requirements—information that would be

needed in a comprehensive plan.

Although DOD has not yet finalized a comprehensive plan of actions for

addressing encroachment issues, it has made progress in several areas. It

has taken or is in the process of taking a number of administrative actions

that include the following:

• DOD has finalized, and the services are tasked with 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.

• 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 managing 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 operate.

• DOD implemented an Air Installation Compatible Use Zone Program to

assist communities in considering aircraft noise and safety issues in

their land-use planning.

• DOD is drafting a directive that establishes the department’s policy on

the 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 services to address encroachment on their ranges

and direct increased emphasis on outreach and coordination efforts

with local communities and stakeholders. In addition, the department
Page 13 GAO-02-727T Military Training

is preparing separate policy directives to establish a unified noise

abatement program and to specify the outreach and coordination

requirements highlighted in the sustainable ranges directive.

DOD is also seeking legislative actions to help deal with encroachment

issues. In December 2001, the Deputy Secretary of Defense established a

senior-level Integrated Product Team to act as the coordinating body for

encroachment efforts and to develop a comprehensive legislative and

regulatory set of proposals by January 2002. The team agreed on a set of

possible legislative proposals for 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

seek to “clarify” the relationship between military training and a number of

provisions in various conservation statutes, including the Endangered

Species Act, the Migratory Bird Treaty Act, the Marine Mammal Protection

Act, and the 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 Integrated Natural Resources

Management Plans have been completed pursuant to the Sikes Act. 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”

14 migratory birds under the Migratory Bird Treaty

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

would be in connection with readiness activities, and require DOD to

minimize the removal 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.15

 14 The term “take” means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture,

collect, or to attempt to engage in any such conduct.

15 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 that has the

potential to injure or disturb a marine mammal by causing disruption to behavioral patterns

such as migration, breathing, nursing, breeding, feeding, and sheltering.
Page 14 GAO-02-727T Military Training

• 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.

These proposals reflect the needs identified by DOD’s draft action plans

and appear to be one step by the department toward developing a

comprehensive approach to managing encroachment issues that affect

military training ranges. The consideration of these legislative proposals

affecting existing environmental legislation will require Congress to

consider potential trade-offs among multiple environmental policy

objectives and their impact on military training.

We have recommended that DOD develop and maintain inventories of its

training ranges, capacities, and capabilities; finalize a comprehensive plan

of administrative actions that includes goals, timelines, projected costs,

and the clear assignment of responsibilities for addressing encroachment

issues; and periodically report on progress in addressing encroachment

issues. 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.

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

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

For further contacts regarding this statement, please contact Barry

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

statement include Glenn Furbish, John Lee, Mark Little, Stefano Petrucci,

James Reid, and John Van Schaik.

Contact and

Acknowledgement

(350211)