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

Letter

Background

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.

Encroachment Has Reduced Some Capabilities, and Its Effects Are Likely to Grow

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.

Effects of Encroachment on Training Readiness and Costs Have Not Been Reflected in Most Service Readiness Reports

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.

Progress in Addressing Encroachment Issues Still Evolving

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.