oversight

Military Training: DOD Approach to Managing Encroachment on Training Ranges Still Evolving

Published by the Government Accountability Office on 2003-04-02.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                            United States General Accounting Office

GAO                         Testimony
                            Before the Committee on Environment
                            and Public Works, U.S. Senate


For Release on Delivery
Expected at 9:30 a.m. EST
Wednesday, April 2, 2003    MILITARY TRAINING
                            DOD Approach to Managing
                            Encroachment on Training
                            Ranges Still Evolving
                            Statement of Barry W. Holman, Director
                            Defense Infrastructure Issues




GAO-03-621T
                                               April 2, 2003


                                               MILITARY TRAINING

                                               DOD Approach to Managing
Highlights of GAO-03-621T, a testimony
before the Committee on Environment and        Encroachment on Training Ranges
Public Works, U.S. Senate
                                               Still Evolving


DOD faces growing challenges in                Encroachment was reported as having affected some training range
carrying out realistic training at             capabilities, requiring workarounds—or adjustments to training events—and
installations and training ranges—             sometimes limiting training, at all stateside installations and major commands
land, air, and sea—because of                  GAO visited. GAO has identified similar effects abroad. Encroachment
encroachment by outside factors.               generally limits the time that training ranges are available and the types of
These include urban growth,                    training conducted. This in turn limits units’ ability to train as they would
competition for radio frequencies              fight. Most encroachment issues are caused by population growth and urban
or airspace, air or noise pollution,           development. Because both are expected to increase, as are the speed and
unexploded ordnance and munition               range of weapon systems used on training ranges, the problems are also
components, endangered species
                                               expected to increase.
habitat, and protected marine
resources. Building on work
reported on in 2002, GAO assessed              Despite DOD-voiced concerns about encroachment’s effects on training,
(1) the impact of encroachment on              service readiness data in 2002 did not show the impact of encroachment on
training ranges, (2) DOD’s efforts             training readiness or costs, although DOD’s most recent quarterly report to
to document the effect on                      Congress on readiness did tie a training issue directly to encroachment. While
readiness and cost, and (3) DOD’s              individual services are making some assessment of training requirements and
progress in addressing                         limitations imposed by encroachment, comprehensive assessments remain to
encroachment.                                  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
GAO is not making any new                      added cost. Also, although some services have reported higher costs because
recommendations. However, GAO                  of encroachment-related workarounds for training, service data systems do
did make recommendations in                    not capture the costs comprehensively.
reports issued in April and June
2002 (GAO-02-525 and GAO-02-                   DOD has made some progress in addressing individual encroachment issues,
614). They were aimed at                       such as implementing some short-term actions, proposing legislation to clarify
(1) improving the quality of                   the relationship between training and conservation statutes, and issuing a
readiness reporting to better reflect          range sustainment directive. But more is required for a comprehensive plan,
training constraints and (2) helping           as recommended by GAO earlier, that clearly identifies steps to be taken,
DOD develop a comprehensive
plan for dealing with encroachment
                                               goals and milestones to track progress, and required funding.
issues and improving the
information and data available for             Urban Growth near Fort Benning, Georgia, from 1955 to 1996 and Projected for 2008
identifying and reporting on the
effects of encroachment. In
addition, the Congress directed
DOD to report periodically on its
progress in addressing
encroachment issues and requires
GAO to review those reports.




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

To view the full report, including the scope
and methodology, click on the link above.
For more information, contact Barry W.         Note: Columbus and Phenix City are shown to the upper left of Fort Benning, Georgia.
Holman at (202) 512-8412 or
holmanb@gao.gov.
Mr. Chairman and Members of the Committee:

I am pleased to have the opportunity to discuss the results of our work
involving the constraints that encroachment places on military training. As
you know, senior Department of Defense (DOD) and service officials have
testified that they face growing difficulties in carrying out realistic training
at installations and training ranges1 because of so-called “encroachment” 2
issues, which limit their ability to train military forces at the desired levels
and proficiencies. The eight encroachment issues identified by DOD are
urban growth around military installations, competition for radio
frequency spectrum; air pollution; noise pollution; competition for
airspace; unexploded ordnance and munitions components;3 endangered
species habitat; and protected marine resources.

My testimony is largely built on work we reported on last year concerning
the effects of encroachment in the continental United States on military
training and readiness.4 Last year we also reported on the constraints on
training of U.S. forces overseas.5 The findings of the two reviews have
some similarities. Today, I would like to briefly highlight our findings
regarding (1) the growing impact of encroachment on training range
capabilities, (2) DOD’s efforts to document the effects of encroachment on
readiness and costs, and (3) DOD’s process in addressing encroachment.


1
 The term “training ranges” in this testimony refers to air, live-fire, ground maneuver, and
sea ranges.
2
 DOD defines encroachment as the cumulative result of any and all outside influences that
inhibit normal military training and testing.
3
 Unexploded ordnance are munitions that (1) have been primed, fused, armed, or
otherwise prepared for action; (2) have been fired, dropped, launched, projected, or placed
in such a manner as to constitute a hazard to operations, installations, personnel, or
material; and (3) remain unexploded either by malfunction, design or any other cause.
Munitions components—which DOD calls “constituents”—include things such as
propellants, explosives, pyrotechnics, chemical agents, metal parts, and other inert
components that can pollute the soil or ground water.
4
 U.S. General Accounting Office, Military Training: DOD Lacks a Comprehensive Plan to
Manage Encroachment on Training Ranges, GAO-02-614 (Washington, D.C.; June 11,
2002). The Chairmen of the Committee on Government Reform and its Subcommittee on
National Security, Emerging Threats and International Relations, House of Representatives,
requested this review.
5
 U.S. General Accounting Office, Military Training: Limitations Exist Overseas but Are
Not Reflected in Readiness Reporting, GAO-02-525 (Washington, D.C.: Apr. 30, 2002). The
Chairman of the Subcommittee on Readiness and Management Support, Committee on
Armed Services, U.S. Senate, requested this review.



Page 1                                                      GAO-03-621T Military Training
          On the basis of our observations and discussions with officials at
Summary   installations and major commands we visited last year here in the United
          States, we obtained numerous examples where encroachment had
          affected some training range capabilities, requiring workarounds—or
          adjustments to training events—and, in some cases, limited training. We
          identified similar effects overseas. The potential problem with
          workarounds is that they lack realism and can lead to the practice of
          tactics that are contrary to those used in combat. Officials, both stateside
          and abroad, reported that encroachment at times limits the time that
          training ranges are available and the types of training that can be
          conducted. Service officials believe that urbanization and population
          growth is primarily responsible for encroachment in the United States and
          is likely to cause more training range losses in the future.

          Despite concerns voiced repeatedly by DOD officials about the effects of
          encroachment on training, DOD’s readiness reports did not indicate the
          extent to which encroachment was adversely affecting training readiness
          and costs. In fact, at the time we did our review, most readiness reports
          showed that units had a high state of readiness; and they were largely
          silent on the issue of encroachment. Recently, however, one DOD
          readiness report indicated that the Air Force has attributed environmental
          encroachment to a reduced capability to conduct flight training.6 We have
          previously reported on limitations in DOD’s readiness reporting.7 While
          improvements in readiness reporting can and should be made to better
          show any shortfalls in training, DOD’s ability to fully assess training
          limitations and their overall impact on training capabilities and readiness
          will be limited without (1) more complete baseline data, such as a
          comprehensive database, on all training range capabilities and the
          services’ training range requirements and (2) full consideration of how live
          training capabilities may be complemented by other forms of training,
          such as those available through training devices and simulations. These
          actions will not replace other steps needed to deal with encroachment, but
          they are key to better define the magnitude of the encroachment problem
          now and in the future. At the same time, it is important to note that while it
          is widely recognized that encroachment results in workarounds that can


          6
           U.S. Department of Defense, Quarterly Readiness Report to the Congress, Institutional
          Training Readiness Report for Fiscal Year 2002, Unclassified Annex E (Washington, D.C.:
          Jan. 2003).
          7
           U.S. General Accounting Office, Military Readiness: New Reporting System Is Intended
          to Address Long-Standing Problems, but Better Planning Is Needed, GAO-03-456
          (Washington, D.C.: Mar. 28, 2003).



          Page 2                                                  GAO-03-621T Military Training
increase training costs, those costs are not easily aggregated to measure
their full effect.

Although DOD has made some progress in addressing individual
encroachment issues, that effort is still evolving; and more work will be
required to put in place a comprehensive plan, as we recommended
earlier, that clearly identifies steps to be taken, goals and milestones to
track progress, and required funding. We reported last year that the
department had prepared draft action plans that deal with each
encroachment issue separately, but information was limited on specific
actions planned, time frames for completing them, and funding needed. In
December 2001, DOD directed an Integrated Product Team to act as the
coordinating body for all encroachment issues, develop a comprehensive
set of legislative and regulatory proposals by January 2002, and formulate
and manage outreach efforts. Last year and just recently, DOD submitted a
package of legislative proposals, which it describes as clarifications,
seeking to modify several statutory requirements. We are aware that
consideration of these and other related legislative proposals affecting
existing environmental legislation will need to include potential trade-offs
among multiple policy objectives and issues on which we have not taken a
position. At the same time, we also understand that DOD recently asked
the services to develop procedures for invoking the national security
exceptions under a number of environmental laws. Historically, DOD and
the services have been reluctant to seek such exceptions; and we are
aware of only a couple of instances where this has been done. In our
report last June on stateside encroachment issues, we made several
recommendations aimed at helping DOD develop a comprehensive plan
for dealing with encroachment and improve the information and data
available for identifying and reporting on the effects of encroachment. 8
Our two reports last year recommended that DOD develop reports that
accurately capture the causes of training shortfalls and objectively report
units’ ability to meet their training requirements. Following our reports,
DOD issued a range sustainment directive9 to establish policy and assign
responsibilities for the sustainment of test and training ranges; and the
Special Operations Command developed a database identifying the
training ranges it uses, type of training conducted, and restrictions on
training. The department also plans to develop a set of internal policies


8
    GAO-02-614.
9
 U.S. Department of Defense, Directive: Sustainment of Ranges and Operating Areas
(OPAREAs), 3200.15, Jan. 10, 2003.



Page 3                                                 GAO-03-621T Military Training
             and procedures based on the range sustainment directive, strengthen and
             empower its management structure to deal with range issues, and take a
             more proactive role in working with local governments and organizations.

             We are not making any new recommendations in this testimony. As you
             may be aware, Mr. Chairman, section 366 of the Bob Stump National
             Defense Authorization Act for Fiscal Year 2003 requires a series of yearly
             reports to the Congress dealing with encroachment issues beginning this
             year, and a requirement for GAO to review those reports. The first of those
             reports was required to be submitted along with the President’s budget for
             fiscal year 2004. That report was to describe DOD’s progress in developing
             a comprehensive plan to use existing authorities to address training
             constraints on the use of military lands, marine areas, and airspace that
             are available in the United States and overseas for training. However, to
             our knowledge, DOD has not yet issued this report. The Act also requires
             the submission of a report not later than June 30, 2003, on plans of the
             department to improve its readiness reporting to reflect the readiness
             impact that training constraints have on specific units of the armed forces.


             Military ranges and training areas are used primarily to test weapon
Background   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




             Page 4                                             GAO-03-621T Military Training
     understanding10 for implementing the Endangered Species Act.11 The
     agencies agreed to establish or use existing regional interagency
     working groups to identify geographic areas within which the groups
     would coordinate agency actions and overcome barriers to conserve
     endangered species and their ecosystems. Such cooperative
     management could help DOD share the burden of land use restrictions
     on military installations that are caused by encroachment issues, but
     implementation of this approach has been limited. We are currently
     reviewing this issue.12

•    Application of environmental statutes to military munitions. DOD
     believes that the Environmental Protection Agency could apply
     environmental statutes to the use of military munitions, shutting down
     or disrupting military training. According to DOD officials,
     uncertainties about future application and enforcement of these
     statutes limit their ability to plan, program, and budget for compliance
     requirements.

•    Competition for radio frequency spectrum. The telecommunications
     industry is pressuring for the reallocation of some of the radio
     frequency spectrum from DOD to commercial control. DOD reports
     that over the past decade, it has lost about 27 percent of the frequency
     spectrum allocated for aircraft telemetry. And we previously reported
     additional allocation of spectrum could affect space systems, tactical
     communications, and combat training.13


10
 Federal Interagency Memorandum of Understanding for Implementation of the
Endangered Species Act, September 1994.
11
  The 14 federal agencies included the Department of Agriculture’s Forest Service; the
Department of Defense; the U.S Army Corps of Engineers; the Department of Commerce’s
National Marine Fisheries Service; the Department of the Interior’s Bureau of Land
Management, Bureau of Mines, Bureau of Reclamation, Fish and Wildlife Service, Minerals
Management Service, and National Park Service; the Department of Transportation’s
Federal Aviation Administration, Federal Highway Administration, and Coast Guard; and
the Environmental Protection Agency.
12
  At the request of the Committee on Government Reform and its Subcommittee on
National Security, Emerging Threats and International Relations, House of Representatives,
we are reviewing (1) the extent to which management of endangered species and related
land use restrictions are shared by DOD and other federal landowners and (2) the efforts
that DOD and/or other federal landowners have undertaken to promote cooperative
management and additional steps needed to enhance this approach. We expect to report on
the results of this work later this year.
13
  U.S. General Accounting Office, Defense Spectrum Management: More Analysis Needed
to Support Spectrum Use Decisions for the 1755-1850MHz Band, GAO-01-795
(Washington, D.C.: Aug. 20, 2001).


Page 5                                                    GAO-03-621T Military Training
•   Marine regulatory laws that require consultation with regulators
    when a proposed action may affect a protected resource. Defense
    officials say that the process empowers regulators to impose
    potentially stringent measures to protect the environment from the
    effects of proposed training in marine environments.

•   Competition for airspace. Increased airspace congestion limits the
    ability of pilots to train as they would fly in combat.

•   Clean Air Act requirements for air quality. DOD officials believe the
    Act requires controls over emissions generated on Defense
    installations. New or significant changes in range operations also
    require emissions analyses, and if emissions exceed specified
    thresholds, they must be offset with reductions elsewhere.

•   Laws and regulations mandating noise abatement. DOD officials
    stated that weapon systems are exempt from the Noise Control Act of
    1972, but DOD must assess noise impact under the National
    Environmental Policy Act. As community developments have expanded
    closer to military installations, concerns over noise from military
    operations have increased.

•   Urban growth. DOD says that unplanned or “incompatible” commercial
    or residential development near training ranges compromises the
    effectiveness of training activities. Local residents have filed lawsuits
    charging that military operations lowered the value or limited the use
    of their property.

To the extent that encroachment adversely affects training readiness,
opportunities exist for the problems to be reported in departmental and
military service readiness reports. The Global Status of Resources and
Training System is the primary means units use to compare readiness
against designed operational goals.14 The system’s database indicates, at
selected points in time, the extent to which units possess the required
resources and training to undertake their wartime missions. In addition,
DOD is required under 10 U.S.C. 117 to prepare quarterly readiness reports
to Congress. The reports are based on briefings to the Senior Readiness


14
   The Global Status of Resources and Training System, which units use to report their
readiness status monthly or whenever a change occurs. Units report readiness in four
resource areas, including training. If a unit is not at the highest readiness level, it must
identify the reasons from a list that includes training areas. Commanders may also include
narrative statements with more detailed explanations.



Page 6                                                      GAO-03-621T Military Training
                        Oversight Council, a forum assisted by the Defense Test and Training
                        Steering Group. In June 2000, the council directed the steering group to
                        investigate encroachment issues and develop a comprehensive plan of
                        action.

                        The secretaries of the military services are responsible for training
                        personnel and for maintaining their respective training ranges and
                        facilities. Within the Office of the Secretary of Defense, the Under
                        Secretary of Defense for Personnel and Readiness develops policies, plans,
                        and programs to ensure the readiness of the force and provides oversight
                        on training; the Deputy Under Secretary of Defense for Installations and
                        Environment develops policies, plans, and programs for DOD’s
                        environmental, safety, and occupational health programs, including
                        compliance with environmental laws, conservation of natural and cultural
                        resources, pollution prevention, and explosive safety; and the Director,
                        Operational Test and Evaluation, provides advice on tests and evaluations.


                        On the basis of what we have seen, the impact of encroachment on
Encroachment Has        training ranges has gradually increased over time, reducing some training
Reduced Some            capabilities. Because most encroachment problems are caused by urban
                        development and population growth, these problems are expected to
Capabilities, and Its   increase in the future.
Effects Are Likely to
                        Although the effects vary by service and by individual installation,
Grow                    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

                        Page 7                                           GAO-03-621T Military Training
critical habitat for endangered species. Atlantic Fleet officials reported
encroachment problems stemming from endangered marine mammals and
noise. They said that the fleet’s live-fire exercises at sea were restricted,
and night live-fire training was not allowed.

More recently, in January 2003, DOD’s Special Operations Command
reported that its units encounter a number of obstacles when scheduling
or using training ranges.15 According to the report, the presence of
endangered species and marine mammals on or near ranges result in
restrictions on training for at least part of the year—closing the area to
training, prohibiting live fire, or requiring modified operations. For
example, a variety of endangered species live on the training areas of the
Navy Special Warfare Command in California, particularly on Coronado
and San Clemente islands. Due to environmental restrictions, Navy Special
Warfare units report that they can no longer practice immediate action
drills on Coronado beaches; they cannot use training areas in Coronado
for combat swimmer training; and they cannot conduct live-fire and
maneuver exercises on much of San Clemente Island during some seasons.
In addition, the Special Operations Command owns no training ranges of
its own and largely depends on others for the use of their training ranges.
As a result, command officials advised us that they must train under
operational and scheduling restrictions imposed by its host commands.
For example, the command normally trains at night; and because range
management personnel are not often available at night, this prevents such
training. Also, on many ranges, the command reported that priority is
given to larger units than special operations units causing it to postpone or
cancel training. According to the report, ranges are also inadequately
funded for construction, maintenance, repairs, and upgrades. This results
in some commanders using their own funds in order to prevent the ranges
from becoming dangerous or unusable.

The Special Operations Command, while expressing concern for the
future, reported that none of the eight encroachment issues identified by
DOD had yet stopped military training, due mostly to the creativity and
flexibility of its commanders and noncommissioned officers. In general,



15
  U.S. Special Operations Command, Tiger Team Report: Global Special Operations
Forces Range Study, Jan. 27, 2003. The Special Operations Command recommended that
all components needed to create master range plans that addressed their current and future
range issues and solutions. The command also recommended that plans identify and
validate training requirements and facilities available and define the acceptable limits of
workarounds.



Page 8                                                    GAO-03-621T Military Training
when obstacles threaten training, the unit will find a workaround to
accomplish the training. In some instances, the unit may travel to another
training facility, costing additional money for transportation and
potentially requiring an extended stay at the training site. By sending units
away to train, the command limits its ability to send people on future
travel for training or missions due to efforts to control the number of days
per year that servicemembers are deployed away from home. Other
workarounds consist of commands using different equipment, such as
plastic-tipped bullets; changing maneuvering, firing, and training methods
to overcome training obstacles; and using facilities that need repair.
According to the Special Operations Command, all of these workarounds
expend more funds and manpower in order to accomplish its training
mission.

DOD and military service officials said that many encroachment issues are
related to urban growth around military installations. They noted that
most, if not all, encroachment issues result from urban and population
growth and that around DOD installations this is increasing at a rate higher
than the national average. Figure 1 illustrates the increase in urban growth
encroachment near Fort Benning, Georgia, while the fort has remained
relatively unchanged. According to DOD officials, new residents near
installations often view military activities as an infringement on their
rights, and some groups have organized in efforts to reduce operations
such as aircraft and munitions training. At the same time, according to
Defense officials, the increased speed and range of weapon systems are
expected to increase training range requirements.




Page 9                                            GAO-03-621T Military Training
Figure 1: Historical and Projected Urban Growth Near Fort Benning, Georgia




Note: (Top left to right) Urban growth near Fort Benning, Georgia, in 1955 and 1985. (Bottom left to
right) Urban growth near Fort Benning, Georgia, in 1996 and projected for 2008.




Page 10                                                           GAO-03-621T Military Training
                     Despite the loss of some training range capabilities, service readiness data
Effects of           did not show the impact of encroachment on training readiness. However,
Encroachment on      DOD’s January 2003 quarterly report to Congress did tie an Air Force
                     training issue directly to encroachment.
Training Readiness
and Costs Have Not   Even though DOD officials in testimonies and many other occasions have
                     repeatedly cited encroachment as preventing the services from training to
Been Reflected in    standards, DOD’s primary readiness reporting system did not reflect the
Most Service         extent to which encroachment was a problem. In fact, it rarely cited
Readiness Reports    training range limitations at all. Similarly, DOD’s quarterly reports to
                     Congress, which should identify specific readiness problems, hardly ever
                     mentioned encroachment as a problem.

                     This is not surprising to us because we have long reported on limitations
                     in DOD’s readiness reporting system and the need for improvements; our
                     most recent report was issued just last week.16 Furthermore, on the basis
                     of our prior reports on readiness issues and our examination of
                     encroachment, we do not believe the absence of data in these reports
                     concerning encroachment should be viewed simply as “no data, no
                     problem!” Rather, as with other readiness issues we have examined over
                     time, it suggests a lack of attention on the part of DOD in fully assessing
                     and reporting on the magnitude of the encroachment problem.

                     However, DOD’s most recent quarterly report did indicate a training issue
                     that is tied directly to encroachment. The January 2003 Institutional
                     Training Readiness Report showed that the Air Force has rated itself as
                     C-2 for institutional flight training.17 This indicates that it is experiencing
                     some deficiencies with limited impact on capabilities to perform required
                     institutional training. The Air Force attributed this to training range
                     availability and encroachment combined with environmental concerns
                     that are placing increasing pressure on its ability to provide effective and
                     realistic training. The Air Force also reported that sortie18 cancellations are
                     becoming a more common occurrence and may soon adversely impact the
                     quality of training. For example, the spotting of a Sonoran Pronghorn on




                     16
                          GAO-03-456.
                     17
                       By a way of comparison, C-1 rating is when a unit is at its highest readiness level and is
                     able to fully meet its mission.
                     18
                          A sortie is one mission by a single aircraft.



                     Page 11                                                      GAO-03-621T Military Training
the Barry M. Goldwater Range forces immediate cancellation or relocation
of scheduled missions.

Readiness reporting can and should be improved to address the extent of
training degradation due to encroachment and other factors. However, it
will be difficult for DOD to fully assess the impact of encroachment on its
training capabilities and readiness without (1) obtaining more complete
information on both training range requirements and the assets available
to support those requirements and (2) considering to what extent other
complementary forms of training may help mitigate some of the adverse
impacts of encroachment. The information is needed to establish a
baseline for measuring losses or shortfalls.

We previously reported that the services did not have complete
inventories of their training ranges and that they do not routinely share
available inventory data with each other (or with other organizations such
as the Special Operations Command). DOD officials acknowledge the
potential usefulness of such data and have some efforts underway to
develop these data. However, since there is no complete directory of 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 encroachment19
noted that the Navy Special Operations forces recently learned that some
ranges at the Army’s Aberdeen Proving Grounds in Maryland are
accessible from the water—a capability that is a key requirement for Navy
team training. Given DOD’s increasing emphasis on joint capabilities and
operations, having an inventory of defense-wide training assets would
seem to be a logical step toward a more complete assessment of training
range capabilities and shortfalls that may need to be addressed.

This issue was recently reinforced by the January 2003 range report by the
Special Operations Command, which found that none of the services had


19
     GAO-02-614.



Page 12                                           GAO-03-621T Military Training
joint databases or management tools to combine all training ranges into a
single tool accessible to all commands. The command concluded that such
a centralized database would contribute to improving unit readiness and
mission success for all components. At the same time, we cannot be sure
of the extent to which recent military operations in the Middle East could
impact future training requirements. DOD will need to reassess lessons
learned from these operations.

Each service has, to varying degrees, assessed its training range
requirements and limitations due to encroachment. For example, the
Marine Corps has completed one of the more detailed assessments of the
degree to which encroachment has affected the training capability of
Camp Pendleton, California. The assessment determined to what extent
Camp Pendleton could support the training requirements of two unit types
and two specialties by identifying the tasks that could be conducted to
standards in a “continuous” operating scenario (e.g., an amphibious
assault and movement to an objective) or in a fragmented manner (tasks
completed anywhere on the camp). The analysis found that from 60 to 69
percent of continuous tasks and from 75 to 92 percent of the other training
tasks could be conducted to standards. Some of the tasks that could not
be conducted to standards were the construction of mortar- and 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

Page 13                                          GAO-03-621T Military Training
                      training resources should include assessing the potential for using virtual
                      or constructive simulation technology to augment live training. However,
                      based on our prior work I must emphasize, Mr. Chairman, that these types
                      of complementary training cannot replace live training and cannot fully
                      eliminate the impact of encroachment, though they may help mitigate
                      some training range limitations.

                      In addition, while some service officials have reported increasing costs
                      because of workarounds related to encroachment, the services’ data
                      systems do not capture these costs in any comprehensive manner. In its
                      January 2003 report, the Special Operations Command noted that the
                      services lacked a metric-base reporting system to document the impact of
                      encroachment or track the cost of workarounds in either manpower or
                      funds. We noted last year that DOD’s overall environmental conservation
                      funding, which also covers endangered species management, had
                      fluctuated, with an overall drop (except for the Army) in obligations since
                      1999. If the services are indeed conducting more environmental
                      assessments or impact analyses as a result of encroachment, the
                      additional costs should be reflected in their environmental conservation
                      program obligations.


                      DOD has made some progress in addressing individual encroachment
Progress in           issues, including individual action plans and legislative proposals. But
Addressing            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
Encroachment Issues   required funding. Senior DOD officials recognized the need to develop a
Still Evolving        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.


                      Page 14                                          GAO-03-621T Military Training
•   DOD formed a Policy Board on Federal Aviation Principles to review
    the scope and progress of DOD activities and to develop the guidance
    and process for special use air space.

•   DOD formed a Clean Air Act Services’ Steering Committee to review
    emerging regulations and to work with the Environmental Protection
    Agency and the Office of Management and Budget to protect DOD’s
    ability to train.

•   DOD implemented an Air Installation Compatible Use Zone Program to
    assist communities in considering aircraft noise and safety issues in
    their land use planning.

Some future strategies and actions identified in the draft plans addressing
the eight encroachment issues include the following.

•   Enhancing outreach efforts to build and maintain effective working
    relationships with key stakeholders by making them aware of DOD’s
    need for training ranges, its need to maintain readiness, and its need to
    build public support for sustaining training ranges.

•   Developing assessment criteria to determine the cumulative effect of
    all encroachment restrictions on training capabilities and readiness.
    The draft plan noted that while many examples of endangered
    species/critical habitat and land use restrictions are known, a
    programmatic assessment of the effect these restrictions pose on
    training readiness has never been done.

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

•   Improving coordinated and collaborative efforts between base officials
    and city planners and other local officials in managing urban growth.

In December 2001, the Deputy Secretary of Defense established a 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

Page 15                                           GAO-03-621T Military Training
training and a number of provisions in various conservation and
compliance statutes, including the Endangered Species Act, the Migratory
Bird Treaty Act, the Marine Mammal Protection Act, and Clean Air Act.
DOD’s proposals would, among other things, do the following:

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

•    Permit DOD to “take” migratory birds under the Migratory Bird Treaty
     Act without action by the Secretary of the Interior, where the taking
     would be in connection with readiness activities, and require DOD to
     minimize the taking of migratory birds to the extent practicable
     without diminishment of military training or other capabilities, as
     determined by DOD.

•    Modify the definition of “harassment” under the Marine Mammal
     Protection Act as it applies to military readiness activities.20

•    Modify the conformity provisions of the Clean Air Act. The proposal
     would maintain the Department’s obligation to conform military
     readiness activities to applicable state implementation plans but would
     give DOD 3 years to demonstrate conformity. In the meantime, DOD
     could continue military readiness activities.

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


20
  The Marine Mammal Protection Act’s definition of “harassment” has been a source of
confusion. According to DOD, the statute defines “harassment” in terms of “annoyance” or
the “potential to disturb,” standards that DOD asserts are difficult to interpret. The statute,
10 U.S.C. 1362, defines the term as any act of pursuit, torment, or annoyance which has the
potential to injure or disturb a marine mammal by causing disruption to behavioral patterns
such as migration, nursing, feeding, breeding, and sheltering.



Page 16                                                      GAO-03-621T Military Training
Of the above proposals, Congress passed, as part of the fiscal year 2003
defense authorization legislation, a provision related to the Migratory Bird
Treaty Act.21 Under that provision, until the Secretary of the Interior
prescribes regulations to exempt the armed forces from incidental takings
of migratory birds during military readiness activities, the protections
provided for migratory birds under the Act do not apply to such incidental
takings. In addition, Congress authorized DOD to enter agreements to
purchase property or property interests for natural resource conservation
purposes, such as creating a buffer zone near installations to prevent
encroachment issues, such as urban growth.22

In February 2003, DOD submitted to Congress the Readiness and Range
Preparedness Initiative for fiscal year 2004. In it, the department restates a
number of legislative proposals from 2002 and includes a proposal
concerning the Marine Mammal Protection Act. In the 2004 initiative, the
department seeks to reconcile military readiness activities with the Marine
Mammal Protection Act by adding language to sections of title 16 of the
U.S. Code.

We are aware that consideration of these legislative proposals affecting
existing environmental legislation will need to include potential tradeoffs
among multiple policy objectives and issues on which we have not taken a
position. At the same time, we also understand that DOD recently asked
the services to develop procedures for invoking the national security
exceptions under a number of environmental laws. Historically, DOD and
the services have been reluctant to seek such exceptions; and we are
aware of only a couple of instances where this has been done.

Our two reports last year both recommended that DOD develop reports
that accurately capture the causes of training shortfalls and objectively
report units’ ability to meet their training requirements. At the time we
completed our reviews in 2002, DOD’s draft action plans for addressing the
eight encroachment issues had not been finalized. DOD officials told us
that they consider the plans to be working documents and stressed that
many concepts remain under review and may be dropped, altered, or
deferred, while other proposals may be added. No details were available
on overall actions planned, clear assignments of responsibilities,


21
     Section 315, P.L. 107-314, Dec. 2, 2002.
22
     Section 2811, P.L. 107-314, Dec. 2, 2002 (codified at 10 U.S.C. 2684).



Page 17                                                         GAO-03-621T Military Training
measurable goals and time frames for accomplishing planned actions, or
funding requirements—information that would be needed in a
comprehensive plan. Our report on stateside encroachment problems also
recommended that DOD develop and maintain a full and complete
inventory of service and department-wide training infrastructure; consider
more alternatives to live training; and ensure that the plan for addressing
encroachment includes goals, timelines, responsibilities, and projected
costs.23 Our recently issued report on overseas training also recommended
that DOD develop reports that accurately capture the causes of training
shortfalls and objectively report units’ ability to meet their training
requirements.24

Following our reports, DOD issued a range sustainment directive to
establish policy and assign responsibilities for the sustainment of test and
training ranges,25 and the Special Operations Command developed a
database identifying the training ranges it uses, type of training conducted,
and restrictions on training. In addition, DOD is working with the other
regulatory agencies in the federal government to manage the way in which
laws are enforced and plans to issue four more directives that cover
outreach, range clearance, community noise, and Air Installation
Compatibility Use Zone.

In the Bob Stump National Defense Authorization Act for Fiscal Year 2003,
Congress required the Secretary of Defense to develop a comprehensive
plan for using existing authorities available to the Secretary of Defense
and the secretaries of the military departments to address training
constraints on the use of military lands, marine areas, and airspace that
are available in the United States and overseas for training.26 As part of the
preparation of the plan, the Secretary of Defense was expected to conduct
an assessment of current and future training range requirements of the
armed forces and an evaluation of the adequacy of current DOD resources
(including virtual and constructive training assets as well as military lands,
marine areas, and airspace available in the United States and overseas) to
meet those current and future training range requirements. Also, as you


23
     GAO-02-614.
24
     GAO-02-525.
25
  U.S. Department of Defense, Directive: Sustainment of Ranges and Operating Areas
(OPAREAs), 3200.15, Jan. 10, 2003.
26
     Section 366, P.L. 107-314, Dec. 2, 2002.



Page 18                                                GAO-03-621T Military Training
           may be aware, Mr. Chairman, that Act requires annual reports to Congress
           dealing with encroachment issues beginning this year and requires GAO to
           review those reports. The first of those reports was required to be
           submitted along with the President’s budget for fiscal year 2004. That
           report was to describe the progress in developing a comprehensive plan to
           address training constraints. To our knowledge, Mr. Chairman, DOD has
           not completed a comprehensive plan or provided Congress with the
           progress report. Officials of the Office of the Secretary of Defense said
           that they plan to report to Congress later this calendar year. The Act also
           requires the submission of a report not later than June 30, 2003, on the
           department’s plans to improve its readiness reporting to reflect the
           readiness impact that training constraints have on specific units of the
           armed forces.

           This concludes my statement. I would be pleased to answer any questions
           you or other members of the Committee may have at his time.

           Contact and Acknowledgment

           For further contacts regarding this statement, please contact Barry W.
           Holman on (202) 512-8412. Individuals making key contributions to this
           statement include Tommy Baril, Byron Galloway, Jane Hunt, John Lee,
           Mark A. Little, Patti Nichol, Michelle K. Treistman, and John Van Schaik.




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