Military Training: DOD Approach to Managing Encroachment on Training Ranges Still Evolving
Published: 2003-04-02T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.

section_title: Letter
paragraphs: 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 ranges because of so-called “encroachment”   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; 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. Last year we also reported on the constraints on  training of U.S. forces overseas. 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.
subsections: section_title: Background
paragraphs: 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  understanding for implementing the Endangered Species Act. 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.
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.
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. 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  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.
section_title: Encroachment Has Reduced Some Capabilities, and Its Effects Are Likely to Grow
paragraphs: 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  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. 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,  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.
section_title: Effects of Encroachment on Training Readiness and Costs Have Not Been Reflected in Most Service Readiness Reports
paragraphs: 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. 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. 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 sortie 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  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 DOD- wide 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 encroachment  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  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 artillery- firing 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  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.
section_title: Progress in Addressing Encroachment Issues Still Evolving
paragraphs: 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 short- term 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.
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 senior- level 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  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.
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.
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. 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.
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,  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. 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.
Following our reports, DOD issued a range sustainment directive 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. 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.