oversight

Environmental Compliance: Better DOD Guidance Needed to Ensure That the Most Important Activities Are Funded

Published by the Government Accountability Office on 2003-06-17.

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

             United States General Accounting Office

GAO          Report to Congressional Committees




June 2003
             ENVIRONMENTAL
             COMPLIANCE
             Better DOD Guidance
             Needed to Ensure
             That the Most
             Important Activities
             Are Funded




GAO-03-639
                                                June 2003


                                                ENVIRONMENTAL COMPLIANCE

                                                Better DOD Guidance Needed to
Highlights of GAO-03-639, a report to the       Ensure That the Most Important
Senate and House Committees on Armed
Services                                        Activities Are Funded



The Department of Defense (DOD)                 DOD’s and the services’ policies and processes for the environmental quality
and its military services are                   program do not always ensure that program funds are targeted to the most
responsible for complying with a                important and appropriate environmental activities. Instead, GAO found
broad range of environmental laws               that some installations have funded low-priority or other activities that were
and other requirements that apply               ineligible under their environmental quality funding policies, at the same
to the lands they manage, including
more than 425 major military
                                                time that higher-priority activities were not funded. For example, at certain
installations covering about                    large installations that GAO visited, low-priority activities, such as noise
25 million acres across the United              monitoring, or ineligible activities, such as pest management, landscaping,
States. Through its environmental               and roof replacement, were funded while high-priority activities to prevent
quality program, DOD spends                     soil erosion were not.
about $2 billion per year to comply
with these requirements. Although               At the root of the problem is DOD’s broad program policy that does not
the services have made significant              provide specific guidance on what activities are eligible for the program
improvements in environmental                   and the resulting inconsistent interpretation and implementation of this
management in recent years, DOD                 policy by the military services. DOD’s policy requires that all high-priority
has not reached full environmental              activities be funded, but gives the services broad discretion in how this
compliance. In response to the
Senate Armed Services
                                                policy is put into place. As a result, GAO found (1) inconsistencies across
Committee’s report on the                       and within the services about which activities are eligible for environmental
National Defense Authorization Act              quality program funding and (2) the funding of some activities through the
for Fiscal Year 2002, we assessed               program that more closely relate to military operations or base maintenance.
how DOD and the services                        For example, some services use program funds for oil and hazardous
identify, prioritize, and fund their            material spill response plans, equipment, and cleanup costs, while other
environmental quality activities                services require the organization responsible for the spill to pay for the
to determine whether the                        cleanup portion of those costs. Similarly, service policies can differ
most important and appropriate                  regarding responsibility for funding maintenance of structures such as
activities are funded.                          water and sewer treatment facilities and historic buildings.

                                                Without a consistently implemented approach, there is no assurance
DOD should establish a more                     that DOD’s requirement to fund all high-priority activities is being met.
specific policy on which activities             Instead, some high-priority projects are being deferred. Generally, these
are eligible for funding through the            deferrals involve projects that, although required by law, do not have to
environmental quality program                   be completed by specific dates (e.g., surveys of properties required by
and how such activities should be               historic preservation law). Deferring such activities, however, can lead
prioritized and funded. The military            to larger and more costly problems later. Moreover, to fund unbudgeted
services should revise their policies           emergency environmental activities, the installations may have to defer
and processes to conform to the
                                                other high-priority environmental program activities, obtain funds from
revised DOD policy. DOD did
not provide comments on these                   other sources at the installation such as maintenance activities, or obtain
recommendations as of the                       funds from higher command levels. Some services have recently indicated
issuance date of this report.                   that the availability of funds for environmental activities is likely to get
                                                worse in future years, because of expected reductions in their budgets for
                                                this program. Such constraints make a well-implemented prioritization
                                                process even more important.
www.gao.gov/cgi-bin/getrpt?GAO-03-639.

To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Anu K. Mittal
at (202) 512-3841 or mittala@gao.gov.
Contents


Letter                                                                                                   1
              Results in Brief                                                                          2
              Background                                                                                4
              DOD’s and the Services’ Policies and Processes Do Not
                Always Ensure That the Most Important and Appropriate
                Environmental Quality Activities Are Funded                                              9
              Conclusions                                                                               22
              Recommendations for Executive Action                                                      22
              Agency Comments and Our Evaluation                                                        23

Appendix I    Scope and Methodology                                                                     24



Appendix II   GAO Contacts and Staff Acknowledgments                                                    26



Figure
              Figure 1: DOD’s Environmental Quality Funding, Fiscal Year 2002                           5




              Abbreviations

              DOD               Department of Defense
              GAO               General Accounting Office
              NEPA              National Environmental Policy Act




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              Page i                                       GAO-03-639 DOD Environmental Compliance
United States General Accounting Office
Washington, DC 20548




                                   June 17, 2003

                                   The Honorable John W. Warner
                                   Chairman
                                   The Honorable Carl Levin
                                   Ranking Minority Member
                                   Committee on Armed Services
                                   United States Senate

                                   The Honorable Duncan Hunter
                                   Chairman
                                   The Honorable Ike Skelton
                                   Ranking Minority Member
                                   Committee on Armed Services
                                   House of Representatives

                                   The Department of Defense (DOD) and its military services—the Air
                                   Force, Army, Navy, and Marine Corps—must comply with a broad
                                   spectrum of federal, state, and local environmental laws, regulations, and
                                   executive orders that apply to the lands they manage, including more than
                                   425 major military installations covering approximately 25 million acres
                                   across the United States. Through its environmental quality program,
                                   DOD spends about $2 billion per year to comply with environmental
                                   requirements that address (1) routine activities to ensure environmental
                                   compliance, such as the proper disposal of hazardous waste; (2) pollution
                                   prevention activities; and (3) a wide range of conservation activities,
                                   including the preservation of prehistoric sites and the protection of more
                                   than 300 endangered plant and animal species found on installations.
                                   To ensure that the environmental quality program funds the most
                                   important and appropriate activities, DOD has developed a general policy
                                   for the military services to follow in identifying, prioritizing, and funding
                                   environmental quality activities. In turn, each military service has
                                   established its own policy or guidance to implement the environmental
                                   quality program across its installations.

                                   Although the services have, over the past decade, made significant
                                   improvements in their environmental compliance record, according to
                                   DOD’s estimates these improvements have leveled off in recent years and
                                   DOD has not yet reached its goal of full environmental compliance. In
                                   response to provisions of the Senate Armed Services Committee’s report
                                   on the National Defense Authorization Act for Fiscal Year 2002, we


                                   Page 1                                 GAO-03-639 DOD Environmental Compliance
                   assessed DOD’s and the military services’ policies and processes for
                   identifying, prioritizing, and funding their environmental quality activities,
                   including unexpected or emergency needs, to determine the extent to
                   which these processes and practices ensure that the most important and
                   appropriate activities are funded.

                   As part of our work, we reviewed policies and procedures established
                   by DOD and the services to guide implementation of the environmental
                   quality program. We also visited 11 military installations to review how
                   they were implementing the program and reviewed the environmental
                   funding requests for fiscal years 1999 through 2001 for these 11 and
                   another 4 installations.1 We selected these installations based on their
                   large environmental budgets and because they represent a range of major
                   commands, missions, and geographic locations. Our observations about
                   individual projects or activities at these installations are not generalizable
                   to projects or activities at all military installations. We conducted our
                   work between May 2002 and May 2003 in accordance with generally
                   accepted government auditing standards. A more detailed description of
                   our review scope and methodology is in appendix I.


                   The Department of Defense’s and the military services’ policies and
Results in Brief   processes for the environmental quality program do not always ensure
                   that the most important and appropriate environmental activities are
                   funded. Instead, we found that some installations had funded low-priority
                   activities or ones that were ineligible under their policies, such as pest
                   management and roof replacement, at the same time that higher-priority
                   activities were not funded. At the root of the problem is DOD’s broad
                   program policy that does not provide specific guidance on what activities
                   are eligible for the program and the resulting inconsistent interpretation
                   and implementation of this policy by the military services. The
                   variations among the services’ programs can result in different
                   eligibility requirements for environmental activities across the services.


                   1
                     The installations we visited include the Air Force’s Eglin Air Force Base and Vandenberg
                   Air Force Base; the Army’s Fort Bliss, Fort Campbell, and Fort Carson; the Marine Corps’
                   Camp Lejeune and Camp Pendleton; and the Navy’s Mid-Atlantic Region (Naval Station
                   Norfolk and Naval Weapons Station Yorktown) and Southwest Region (Naval Air Station
                   North Island and Naval Station Point Loma). At the two Navy regions, we reviewed
                   environmental funding requests for Naval Station Norfolk, Naval Air Station Oceana, Naval
                   Weapons Station Yorktown, Naval Amphibious Base Little Creek, Naval Station San Diego,
                   Naval Air Station North Island, Naval Base Point Loma, and Naval Auxiliary Landing Field
                   San Clemente Island.




                   Page 2                                       GAO-03-639 DOD Environmental Compliance
For example, under the Air Force’s and the Army’s policies, the cleanup
of oil and hazardous substance spills is eligible for environmental
quality program funding, while the Navy and Marine Corps require the
organization responsible for the spill to pay the cleanup costs. The
variations can also result in funding activities through the environmental
quality program that may be more closely related to military operations
or base maintenance. For example, at some installations we visited the
environmental quality program funded routine maintenance activities.
Without a consistently implemented approach, there is no assurance that
DOD’s requirement for funding all high-priority environmental activities
is being met. We found that the services have not always been able to
fund all high-priority activities through the environmental quality program
and in some cases the installations we visited had to defer certain
environmental activities when funding was not available. Moreover, the
installations we visited were able to fund their emergency, unbudgeted,
high-priority environmental activities by redirecting funds from other
activities such as base maintenance. Some services indicated that this
situation is likely to worsen in the future with expected reductions in
their budgets for the program. Such constraints make a well-implemented
prioritization process even more important.

Because the broad nature of DOD’s policy and the resulting differences in
program implementation among the military services make it difficult to
ensure that the most important and appropriate environmental activities
are being funded, we are making recommendations to DOD aimed at
establishing a more specific policy on which activities are eligible for
environmental quality program funding and how such activities should
be prioritized and funded. Further, we are recommending that once
the department revises its policy, the services should update their own
policies and processes to ensure consistency with the revisions.

We provided DOD with a draft of this report for review and comment.
DOD provided technical clarifications, which we incorporated as
appropriate. However, DOD did not provide overall comments as of the
issuance date of this report.




Page 3                                GAO-03-639 DOD Environmental Compliance
             DOD’s operations at military installations and other defense sites in
Background   the United States are subject to the same environmental laws and
             regulations, such as the Clean Air Act and the Clean Water Act, as is
             private industry.2 Additionally, DOD policy calls for its organizational
             components to achieve, maintain, and monitor compliance with all
             applicable executive orders, as well as all federal, state, and local
             statutory and regulatory requirements.

             DOD has an environmental quality program to address these requirements,
             which fall into three main categories: (1) environmental compliance
             activities; (2) pollution prevention activities; and (3) conservation
             activities, such as the protection of natural and cultural resources present
             on military installations.3 DOD has developed and implemented policies
             for activities in each major program category.4

             By far, the majority of DOD’s investment in its environmental quality
             program is for its environmental compliance requirements. For example,
             in fiscal year 2002, about 81 percent of DOD’s investment of more than
             $2 billion in the environmental quality program was for compliance
             activities, including personnel costs for the entire program; 11 percent was
             for pollution prevention; and 8 percent was for conservation activities.
             (See fig. 1.)




             2
              Other requirements and policies apply to DOD’s activities overseas and to Navy ships at
             sea; these are outside the scope of this review.
             3
              In addition to its environmental quality program, DOD has a program focusing on the
             cleanup of contamination associated with past DOD activities. This program, known as
             the Defense Environmental Restoration Program, was established by section 211 of the
             Superfund Amendments and Reauthorization Act of 1986. Under the environmental
             restoration program, DOD is authorized to identify, investigate, and clean up environmental
             contamination at active or closing military installations, and on land that DOD formerly
             owned or leased. Funding for environmental restoration activities is provided through
             Component Environmental Restoration accounts; activities funded through these accounts
             are outside the scope of our review.
             4
              See Department of Defense Instruction (DODI) 4715.3, Environmental Conservation
             Program, May 3, 1996; DODI 4715.4, Pollution Prevention, June 18, 1996; and DODI 4715.6,
             Environmental Compliance, April 24, 1996.




             Page 4                                       GAO-03-639 DOD Environmental Compliance
Figure 1: DOD’s Environmental Quality Funding, Fiscal Year 2002




a
    Compliance includes personnel costs for the entire environmental quality program.


Funding allocated to the environmental quality program in recent years
has come largely from DOD’s appropriation for operation and
maintenance activities.5 This appropriation account funds a diverse set of
activities, including military training, depot maintenance, base operations




5
 In recent years, DOD’s operation and maintenance account has funded about 77 percent
of the environmental quality program. About 23 percent of environmental program funding
in recent years has been from other DOD accounts, including the Defense Working Capital
Funds, the procurement accounts, and the military construction account.




Page 5                                               GAO-03-639 DOD Environmental Compliance
support, and real property maintenance.6 The funding allocated to the
environmental quality program from the operations and maintenance
account may be used for other, nonenvironmental, purposes as needed by
the services or installations. For example, once funding for operations and
maintenance activities, including environmental quality activities, has been
allocated to an installation commander, the commander has the authority
to use these funds as necessary for the needs of the installation. Likewise,
if funding allocated to an installation by the service or the major command
for environmental quality activities is not sufficient to ensure that the
installation remains in compliance with its environmental requirements,
the installation commander has the authority to reallocate funds to the
environmental quality program.

Installation commanders are responsible for ensuring that their
installations are in compliance with environmental requirements.
The installations are responsible for identifying all regulations and
other environmental requirements that apply to them, and identifying
and tracking pending requirements.7 To carry out their environmental
responsibilities, the installation commanders are typically supported by
an environmental program office, including staff with expertise in various
environmental areas such as air, water, or hazardous waste. Managers
for these areas are responsible for identifying current and pending
environmental requirements applicable at their installation. Additionally,
DOD has regional environmental offices that assist installations in
identifying current and pending environmental requirements, particularly
at the state and local levels.



6
  In fiscal year 2002, DOD replaced its real property maintenance program, which had
been funded through the operations and maintenance appropriation, with two distinct
activities and accounting structures: (1) sustainment and (2) restoration and
modernization. Sustainment funds, which come primarily from the operations and
maintenance appropriation, cover expenses for all recurring maintenance costs and
contracts, as well as for major repairs of nonstructural components (e.g., replacing a roof
or repairing an air-conditioning system). Restoration includes repair and replacement work
to restore facilities damaged by inadequate sustainment, excessive age, natural disaster,
fire, accident, or other causes. Modernization includes altering, or modernizing, facilities
to meet new or higher standards, accommodate new functions, or replace structural
components. Restoration and modernization activities are funded through both the
operations and maintenance appropriation and the military construction appropriation.
For more information on these topics, see U.S. General Accounting Office, Defense
Infrastructure: Changes in Funding Priorities and Strategic Planning Needed to
Improve the Condition of Military Facilities, GAO-03-274 (Washington, D.C.: Feb. 2003).
7
 In the Navy, these responsibilities are performed by regional environmental offices rather
than by offices associated with each installation.



Page 6                                        GAO-03-639 DOD Environmental Compliance
    Officials at each installation develop a list of planned activities, along
    with the priority levels and estimated costs of these activities, for the
    installation’s environmental quality program for the upcoming 6 fiscal
    years. The greatest emphasis and detail is provided for those activities
    for funding in the first 2 fiscal years, called the budget years.

    DOD’s environmental quality policy uses the following classification
    system to prioritize environmental activities:

•   Class 0 activities are recurring activities needed to keep an environmental
    program running and meet compliance requirements, such as employee
    salaries, costs of environmental permits, and office supplies.

•   Class I activities are nonrecurring projects and activities that must be
    funded in the current program year (and, in some cases, up to several
    years in the future to complete the project or activity) to correct
    noncompliance with an environmental requirement or to ensure that the
    installation will remain in compliance.

•   Class II activities are those that have compliance deadlines, but
    these deadlines will not occur until after the current budget year.

•   Class III activities are typically referred to as “nice to have”
    activities that address overall environmental goals and objectives,
    but are not necessary for an installation to remain in compliance with
    environmental requirements.

    Based on DOD’s policy, the services have developed prioritization
    systems for making funding decisions. Consistent with DOD policy,
    Army and Air Force policies specify that Class 0 and Class I activities
    must be funded.8 Similarly, the Navy and Marine Corps also have a policy
    of funding all Class 0 and I activities, according to service officials, but
    their official program policy guidance does not mention this. Consistent
    with DOD policy, the services also require that selected Class II activities
    be funded in time to ensure compliance with future requirements. None
    of the services’ policies require funding of Class III activities. In this
    report, “must fund” Class 0 and I activities are referred to as high-priority
    activities.



    8
     The Air Force and Navy use the term “level” rather than “class”; in this report, however,
    the term “class” will be used to describe all of the services’ priority levels.




    Page 7                                        GAO-03-639 DOD Environmental Compliance
DOD’s policy does not differentiate among activities within Class 0 and
Class I. For example, because any unfunded Class I activity will result in
noncompliance with an environmental requirement, all Class I activities
have equal weight as “must fund” activities, according to DOD’s policy.
However, in addition to the priority categories described above, some
major commands have developed their own, more detailed prioritization
approaches to help ensure that the most important environmental
activities will be funded before other, less important activities within
the same class. These approaches are intended to rank proposed
environmental activities by their relative importance. These approaches
emphasize somewhat different considerations, such as the risk of harm to
human health or the environment should an activity not be funded, or the
risk of receiving a notice of violation from a regulator if the installation is
out of compliance with an environmental requirement.

After the environmental program’s staff has identified, prioritized, and
estimated the costs of proposed activities, the list of proposed activities
may be reviewed by other installation officials, such as legal staff or the
installation commander. The list is then forwarded to the next higher
command level for its approval. For the Air Force, Army, and Navy,
this next higher level is the major command,9 while Marine Corps
installations forward their proposed environmental budgets directly to
their environmental program’s headquarters. In some cases, the major
command disagrees with the priority level that an installation assigned
to an activity or the funding level that the installation requested. The
command, or headquarters, in the case of the Marine Corps, may
disapprove, or “invalidate,” a proposed activity for environmental funding,
revise the funding level estimate (either up or down), or change the
priority level. The major command consolidates the requests from each
installation under its authority, then submits a commandwide request to
its service headquarters.

The service headquarters are involved to differing degrees in reviewing
the details of the installations’ environmental requests. The Air Force’s
environmental staff rely on the reviews of individual proposed activities
by their major commands. As mentioned above, the Marine Corps’
environmental office is involved in assessing and prioritizing proposed


9
 The Navy refers to its higher command level as a “claimant”; however, for the purposes of
this report, the term major command will be used. Beginning in fiscal year 2004, the Army’s
new Installation Management Agency will serve as the next level for reviews of the Army’s
environmental quality program.




Page 8                                       GAO-03-639 DOD Environmental Compliance
                       activities at installations. The Navy’s environmental staff reviews proposed
                       activities to assess whether they are legally required to undertake them,
                       whether the cost estimates are reasonable, and whether the proposed
                       time frames for completing the activities are realistic. The Army’s
                       environmental staff reviews selected environmental activities that were
                       approved by the major commands. Army headquarters officials told us that
                       they expect to expand their review to all activities approved by their major
                       commands now that they have automated their database of proposed
                       environmental activities.

                       Next, the Office of the Secretary of Defense reviews the environmental
                       quality program budget requests. The Secretary’s office does not review
                       these budgets on a project-by-project basis; instead, its review focuses on
                       the services’ overall environmental compliance track records and whether
                       the proposed budgets will serve to continue to improve each service’s
                       compliance performance. Finally, the estimates for the environmental
                       quality program budget are incorporated into each service’s estimate of its
                       overall needs, and DOD’s overall budget request is included in the annual
                       presidential budget request to the Congress.10


                       Based on broad DOD policy, each military service has established its own
DOD’s and the          policy and processes to implement the environmental quality program.
Services’ Policies     Specifically, the four services have developed somewhat different criteria
                       under their policies and practices for determining which activities are
and Processes Do Not   eligible for funding through their environmental quality programs and
Always Ensure That     which activities are funded. Given these differences, DOD cannot be
                       certain that it is funding the most important and appropriate activities
the Most Important     across the services and, likewise, the services cannot ensure that they
and Appropriate        are devoting program funds to the most important and appropriate
Environmental          environmental activities at their installations.

Quality Activities
Are Funded



                       10
                         This process, which DOD calls its Planning, Programming, and Budgeting System, or
                       PPBS, takes about 2 years from planning to execution. For more information on this
                       process, see Congressional Research Service, A Defense Budget Primer, Dec. 9, 1998.




                       Page 9                                      GAO-03-639 DOD Environmental Compliance
The Services’ Varying                  DOD’s policy provides the services with a broad charge to comply with
Interpretations of DOD’s               applicable environmental requirements, such as statutes and regulations,
Broad Policy Have                      but leaves to the services most decisions about which activities are
                                       appropriate for funding through their environmental quality programs. We
Resulted in Inconsistent               found that the services’ varying interpretations of this policy have resulted
Eligibility Criteria and               in different eligibility requirements and in funding of activities through the
Funding of Activities More             environmental quality program that may have been more closely related to
Closely Related to Military            military operations or maintenance.
Operations or Maintenance

The Services’ Policies Differ in       Although the services have developed policies intended, in part, to clarify
Which Activities Are Eligible          which activities can be funded through the environmental quality program,
for Their Environmental                implementation of these policies has sometimes led to inconsistencies
Quality Programs                       across the services in the types of activities they determine eligible for
                                       funding. Also, some of the services or their organizational components
                                       have developed additional guidance to assist installations in determining
                                       whether certain activities can be funded through their environmental
                                       quality programs. For example, the Air Force’s Environmental Quality
                                       Programming Matrix provides an extensive listing of activities and
                                       indicates whether or not each is valid for environmental quality program
                                       funding. The Navy’s Pacific Fleet has similarly developed guidance, its
                                       Policy on Environmental Issues Matrix, to help clarify what is eligible for
                                       environmental funding. The Pacific Fleet’s guidance also indicates who
                                       should pay for activities that are not eligible for environmental quality
                                       program funding, something that the Air Force matrix does not address.

                                       While these efforts to provide additional guidance are helpful to the
                                       individual services’ environmental quality program managers, they do not
                                       address or resolve the cross-service inconsistencies on what activities are
                                       eligible for funding. For example, we found the following differences in
                                       program eligibility:

                                   •   Environmental impact statements. Under the National Environmental
                                       Policy Act (NEPA), the military services are required to assess the
                                       environmental effect of their major proposed actions, such as new
                                       construction or certain military training on their installations. The Navy’s
                                       and Air Force’s environmental quality programs consider NEPA-required
                                       environmental assessments or environmental impact statements as
                                       high-priority environmental activities. In fiscal year 2002, for example, the
                                       Navy’s environmental quality program spent $17.8 million to comply with
                                       NEPA requirements. In contrast, the Marine Corps’ and Army’s policies
                                       generally do not treat NEPA requirements as eligible for environmental



                                       Page 10                                GAO-03-639 DOD Environmental Compliance
    quality program funding. However, the Army’s environmental quality
    program will pay for some NEPA oversight and assistance activities
    such as training for environmental quality program staff. The Marine
    Corps’ policy requires that the organizations whose actions trigger
    NEPA requirements pay for NEPA-related expenses; only in the case that
    a project is environmentally driven does the Marine Corps policy allow
    environmental quality program funds to be used to pay for NEPA-related
    expenses.

•   Historic rehabilitation. The Marine Corps’ environmental quality
    program, which includes conservation of historic resources, requires
    installations to protect their properties that are listed on the National
    Register of Historical Places. For example, the Marine Corps’
    environmental quality program spent nearly $800,000 to restore an adobe
    ranch house on Camp Pendleton in southern California that was built in
    1890 and had been listed by the National Trust for Historic Preservation
    as one of the most endangered historic structures in the nation. Camp
    Pendleton’s environmental quality program is restoring the adobe and
    plaster house and farm buildings to their 1905 appearance. The restoration
    includes earthquake-proofing the structures as well as stabilizing the
    walls, floors, and roof. Marine Corps policy allows the environmental
    quality program to fund such activities because of the National Historic
    Preservation Act’s protection and preservation requirements. In contrast,
    Air Force policy does not consider the “maintenance and repair of
    National Register listed or eligible buildings, structures or objects” as a
    valid use of environmental quality program funds. Likewise, the Navy’s
    and the Army’s environmental quality programs do not fund the repair,
    maintenance, or rehabilitation of historic structures or properties,
    although the Army’s program will fund the preparation of plans for the
    repair, maintenance, and rehabilitation of such structures.

•   Oil and hazardous material spills. While all four services pay for plans
    to prevent and/or respond to oil and hazardous material spills and for spill
    cleanup equipment, only the Air Force’s and Army’s environmental quality
    programs pay for the actual cleanup. While the Navy and Marine Corps are
    liable under various federal and state laws to fund spill cleanups, they
    would likely use other operating funds for such cleanups. Typically, the
    organization that caused the spill would be expected to fund the cleanup.
    In contrast, the Air Force’s and Army’s environmental quality programs
    will pay for spill cleanups, but headquarters officials from both services
    told us that they encourage their environmental managers to seek
    reimbursement for spill cleanup costs from the unit that caused the spill.




    Page 11                               GAO-03-639 DOD Environmental Compliance
Some Activities Funded               The services’ broad interpretations of eligibility for their environmental
Through the Services’                quality programs have allowed installations to use the environmental
Environmental Quality                quality program to fund activities that may have been more closely related
Programs Are More Closely            to military operations or maintenance.
Related to Military Operations
or Maintenance                       For example, we noted the following:

                                 •   Bird/Aircraft Strike Hazard program. In fiscal year 2001, the Navy
                                     spent about $147,000 of environmental quality program funds to support
                                     an activity whose primary purpose is to ensure the safety of Navy pilots
                                     and aircraft at Naval Air Station North Island and a landing field at
                                     Imperial Beach. The purpose of this program is to reduce the risk of
                                     damage or loss that can occur when birds or other animals are hit by, or
                                     caught in, military aircraft during military operations. The Navy justified
                                     this activity as part of its environmental quality program because 1 of
                                     the 15 species of birds that pose a risk to aircraft is a federally listed
                                     endangered species and another is a threatened species. However, as
                                     clearly stated in the project description, the primary purpose of the
                                     activity is to control wildlife in order to protect aircraft. In contrast,
                                     other services require such activities to be funded by the organizations
                                     responsible for flight operations and not through the environmental
                                     quality programs.

                                 •   Wildfire suppression. The Navy has used environmental quality program
                                     funds to pay for the use of a helicopter to suppress wildfires caused by
                                     military operations, specifically by naval gunfire training on San Clemente
                                     Island, a Navy-owned island off the coast of southern California. Although
                                     Navy helicopters have the primary responsibility to be on standby to
                                     provide firefighting support when training ranges are in use, these
                                     helicopters are not always available. To meet its fire suppression needs
                                     when its helicopters are not available, the Navy has contracted with a
                                     private company for helicopter support. During the last 4 years the Navy
                                     has spent an average of $150,000 per year in environmental quality
                                     program funds to pay for this activity. The Navy justifies the activity as an
                                     environmental expense because wildfires could harm the 10 endangered
                                     species on the island. Nevertheless, the fires are the direct result of the
                                     Navy’s gunfire training activity, and funds for addressing the negative
                                     consequences of its actions normally come from the activity’s sponsor.
                                     It is unclear why this activity is treated differently from the case of
                                     hazardous spills discussed previously, in which the Navy requires the
                                     organization that caused the spill to pay for the cleanup.

                                 •   Roofs for drinking water reservoirs. The Marine Corps’ environmental
                                     quality program has replaced the roofs on six drinking water reservoirs at



                                     Page 12                                GAO-03-639 DOD Environmental Compliance
Camp Pendleton, at an estimated total cost of $4.7 million. According
to officials from Camp Pendleton’s comptroller’s office, the installation
has a backlog of more than $190 million in facility maintenance and repair
needs. Because this maintenance and repair activity had an environmental
connection—the repairs were needed to prevent animals from
contaminating the base’s water supply and to avoid violating the Safe
Drinking Water Act—installation officials decided to fund this activity
through the Marine Corps’ environmental quality program.

Several environmental officials acknowledged that characterizing certain
activities as environmental, or “painting them green,” rather than as facility
maintenance, restoration, or modernization improves the chance of their
being funded. According to these officials, installations may seek to fund
maintenance and infrastructure projects through the environmental quality
program because of the overall shortage of funds for facility maintenance,
restoration, and modernization. According to DOD officials, funding for
facility maintenance has been inadequate for many years, resulting in
deteriorated facilities at many installations.

The Air Force has tried to limit the use of environmental quality
program funds for maintenance and repair activities by establishing a
policy on funding infrastructure-related activities. The policy states
that environmental quality program funds can only be used to construct,
modify, or upgrade facilities or systems needed to comply with new
environmental laws and regulations. Such facilities or systems should
be maintained, repaired, or replaced using other funds. However, if a
regulator or major command determines that an installation is out of
compliance with an environmental requirement, an infrastructure project
may be eligible for environmental quality funding. The policy includes a
list of typical infrastructure projects, indicating whether they are eligible
for environmental quality program funding. In commenting on a draft of
the infrastructure policy, the Air Force Space Command raised concerns
about the policy’s possible negative effect on installations’ ability to
remain in compliance with environmental requirements. According to a
senior environmental official at the command, the Air Force’s
infrastructure policy, although well intentioned, is unrealistic because
funding for repair and maintenance activities has been insufficient for
many years.

We have long noted DOD’s need for improved facilities management,
and since 1997 we have identified DOD infrastructure management as a
high-risk area. Recently, we reported that the military services have not
made maintaining and improving their facilities a funding priority because



Page 13                                GAO-03-639 DOD Environmental Compliance
                            these needs must compete with other programs, such as force readiness
                            and the day-to-day costs of operating an installation.11


The Services Do Not         Certain low-priority activities were funded through the environmental
Always Ensure That          quality program at two Army installations we visited, even though some
Funding Is Targeted to      high priorities, considered “must fund” activities by DOD and Army policy,
                            were not funded. Moreover, at two installations we visited, we found that
the Highest Priority        the environmental quality programs had funded some activities that were
Environmental Activities,   ineligible to receive funding under their policies.
and in Some Cases, Have
Funded Activities That      For two Army installations we visited, the major command did not
Are Ineligible Under        provide environmental quality program funding for all “must funds,”
Their Policies              Class 0 and I activities, yet funded some lower-priority, Class III
                            activities.12 For example, the Fort Carson environmental director told us
                            that the percentage of funds received for validated Class 0 and I activities
                            dropped from about 90 percent in fiscal year 2000 to about 50 percent in
                            fiscal year 2002. At the same time, the command provided Fort Carson
                            with $104,000 in environmental quality program funds for three lower-
                            priority, Class III activities in fiscal year 2002. Similarly, at Fort Campbell,
                            the funding rate for Class 0 and I activities averaged 70 percent of the
                            amount required, according to installation officials. For example, we
                            determined that Fort Campbell received about $16 million, or 77 percent
                            of its high-priority requirements (defined as Class 0 and I activities) in
                            fiscal year 2001, but at the same time the command provided $600,000 in
                            environmental quality program funds to Fort Campbell for five lower-
                            priority, Class III activities. Some examples of high-priority activities not
                            funded at these two installations, and the lower-priority activities that
                            were funded by the major command, include the following:



                            11
                              U.S. General Accounting Office, Defense Infrastructure: Changes in Funding
                            Priorities and Strategic Planning Needed to Improve the Condition of Military
                            Facilities, GAO-03-274 (Washington, D.C.: Feb. 2003).
                            12
                              Class 0 consists of recurring activities (i.e., activities typically funded each year) needed
                            to keep an environmental program running and meet compliance requirements, such as
                            employee salaries and office supplies. Class I consists of nonrecurring activities that are
                            needed to either maintain or restore compliance with an environmental law, regulation,
                            or other requirement. Class II activities have compliance deadlines, but these deadlines
                            will not occur until after the budget year. In some cases, certain Class II activities are
                            considered “must fund” priorities if they must be initiated in the current year in order to
                            ensure that a future compliance deadline can be met. Class III consists of activities that are
                            not required by a specific environmental requirement that an installation must comply with,
                            but are intended to improve the environment.



                            Page 14                                        GAO-03-639 DOD Environmental Compliance
•   In fiscal year 1999, U.S. Forces Command did not provide funding for
    certain Class 0 and I activities at Fort Campbell such as hardware and
    software upgrades to automate program management; drinking water
    resource assessment and planning; and a firebreak redesign to control soil
    erosion entering streams. However, during the same year, the command
    provided funding for certain Class III activities at the installation, such as
    noise monitoring, minimization of construction debris by crushing for
    reuse as aggregate, and asbestos sampling and analysis. Ultimately,
    Fort Campbell was able to fund two of the high-priority activities in 1999,
    by using funds from other environmental activities or from outside the
    environmental quality program.

•   In fiscal years 1999 through 2002, U.S. Forces Command did not provide
    environmental funds for certain Class 0 and I activities at Fort Carson,
    such as removal of an underground storage tank from an abandoned
    landfill; watershed management, including repair of erosion control
    structures; and a survey of industrial sources and sanitary facilities, such
    as oil/water separators and septic system. However, during the same
    time period, the command provided funding for Class III activities at
    Fort Carson, such as radon sampling; replacement of a septic system on
    a training encampment with a connection to a sewage system; and the
    purchase and planting of seeds to reintroduce native plant species to
    re-vegetate burned and other environmentally disturbed areas.

    As illustrated by these examples, U.S. Forces Command has considered
    factors other than those included in DOD’s and the Army’s policies on
    prioritization when making funding decisions. Some considerations
    that the command used included whether (1) failure to fund the activity
    would result in an adverse impact on the installation’s military mission,
    (2) the activity could significantly reduce pollution, and (3) the activity
    is expected to provide a significant return on investment. These
    considerations resulted in the command’s funding activities that were
    lower priorities under DOD’s and the Army’s classification systems,
    while not funding high priorities as defined by these systems. According
    to the director of the Army’s environmental programs, the Installation




    Page 15                                GAO-03-639 DOD Environmental Compliance
    Management Agency13 will not use the major command’s approach
    for making funding decisions. Instead, the agency will always fund
    high-priority activities, as defined by DOD and Army policy, before
    funding Class III activities.

    Consistent with our findings at selected installations, the Army
    Audit Agency has reported that some Army installations have not
    funded all high-priority activities while at the same time funding
    lower-priority activities. In December 1999, the agency reported that
    of 234 environmental activities it reviewed at Army installations, the
    installations did not fund 55 activities classified as high priorities, while
    installations funded 13 other projects that were not classified as high
    priorities.14 The Army Audit Agency recommended that the Army reinforce
    the need to comply with its policy to fund high-priority activities.

    Moreover, some of the activities funded through the environmental quality
    program at two of the installations we visited were prohibited by service
    policy from receiving funds through this program. Specifically, we found
    the following:

•   Pest management. The environmental quality program at Fort Carson
    funded pest management as a recurring, high-priority activity for a number
    of years because base operating funds for this activity had not been
    available, according to the installation’s environmental quality program
    manager. This official told us that pest management is eligible for
    environmental quality program funding because chemicals are used to
    perform the work. However, our review of the Army’s program policy
    indicates that application of chemical pesticides for pest control is not
    eligible for environmental quality program funding, and officials from the
    Army’s Installation Management Agency agreed that this activity should
    not have been funded using environmental quality program funds.




    13
       In October 2002, the Army established the Installation Management Agency to oversee
    all components of installation support, including environmental programs. Previously,
    installation funding (including environmental funding) was routed through the Army’s
    major commands to individual installations. In some cases, this resulted in some
    installations receiving a fraction of their total budget because major commands withheld
    funds and unexpected mission priorities arose. Under the new agency structure,
    installation funding (including environmental funding) will go directly from the agency
    to the installations. This new funding system will go into effect in fiscal year 2004.
    14
         U.S. Army Audit Agency, Execution of Environmental Projects, December 1999.




    Page 16                                       GAO-03-639 DOD Environmental Compliance
•   Landscaping for a hazardous waste storage facility. Fort Carson used
    environmental quality program funds to pay for maintenance and repair,
    including landscaping, of a hazardous waste storage facility located on
    the installation. Fort Carson officials said that the landscaping was
    included as part of a larger activity—maintaining the hazardous waste
    storage facility—which is eligible for environmental funding. According to
    the Fort Carson environmental director, the installation has generally not
    had funds available from base operations accounts to fund base support
    activities such as this. However, our review of Army environmental policy
    indicates that environmental funding for routine grounds maintenance
    “such as grass mowing, tree pruning, and landscaping performed for the
    purpose of aesthetics” is specifically excluded. Officials from the Army’s
    Installation Management Agency agreed that landscaping should not have
    been funded using environmental quality program funds. Further, these
    officials as well as the director of environmental programs for the
    Army said that the entire activity should not have been funded using
    environmental quality program funds because routine repair and
    maintenance activities are more appropriately funded through the
    maintenance account.

•   Restoration and maintenance of a historic structure. Vandenberg
    Air Force Base has used environmental quality program funds to refurbish
    its Space Launch Complex 10, which the National Park Service had
    designated as “the best surviving example of a launch complex built in
    the 1950s at the beginning of the American effort to explore space.”
    The National Park Service also listed the site as one of America’s most
    endangered historic landmarks. The Air Force’s environmental quality
    program spent $925,000 on this activity during fiscal years 2000 through
    2002; the restoration is expected to take 8 years to complete, at an
    estimated total cost of more than $2 million. However, as previously
    mentioned, Air Force policy specifically prohibits the use of
    environmental funds for the maintenance and repair of historic landmarks.

    A senior environmental official from Vandenberg Air Force Base’s major
    command, the Air Force Space Command, explained that it can be difficult
    to obtain funding for repair and maintenance of historic structures,
    particularly if they are vacant. Installations’ sustainment, restoration, and
    modernization programs typically assign a lower funding priority to vacant
    historic structures than to structures that have a direct impact on the
    installations’ overall missions. Given that no other funding source on
    base is likely to maintain and restore historic properties, it often falls
    to the environmental quality program to carry out these conservation
    responsibilities, according to this official, despite their ineligibility under
    Air Force policy. The official further noted that legal counsel for the


    Page 17                                GAO-03-639 DOD Environmental Compliance
    command’s environmental office has advised the environmental quality
    program to repair and maintain historic structures to avoid “demolition by
    neglect” and to avoid violating the National Historic Preservation Act.

•   Roof repair. In fiscal year 2001, Fort Carson used $12,000 of
    environmental quality funds to repair a roof on a historic ranch house,
    according to installation resource management officials. The ranch house
    was being used by environmental quality program staff and students
    performing environmental research, according to the installation’s
    environmental director. The funds used for the roof replacement
    were taken from an approved activity to update and implement the
    installation’s integrated natural resources management plan required
    under the Sikes Act.15 The description of the activity as approved for
    funding does not mention roof repair. According to the environmental
    director, the activity’s narrative was a “catch all” that could be used
    to fund anything related to implementation of the natural resources
    plan, including repairing a roof on a historic structure. Although the
    environmental director acknowledged that this roof replacement could
    have been funded through the installation’s public works department,
    which is responsible for maintaining and repairing installation structures,
    he also said that the public works department did not have funding
    available for this activity, while the environmental quality program did.


    According to our review of Army policy, minor construction costs not
    related to new or expanded legal environmental requirements are not
    eligible for environmental funds. Army Installation Management Agency
    officials agreed that environmental funds should not have been used to
    fund this roof repair and said that they would not have funded this activity
    had it been specifically mentioned in the funding request for the natural
    resources plan. The environmental quality program could fund certain
    repairs of historic structures to maintain compliance with the National
    Historic Preservation Act, according to the officials.




    15
      The Sikes Act addresses all aspects of natural resources management on military
    installations. A 1997 amendment to the act requires the services to prepare an integrated
    natural resources management plan for each installation in the United States, except for
    installations that have been determined to lack significant natural resources.




    Page 18                                       GAO-03-639 DOD Environmental Compliance
The Services’               Although DOD’s and the services’ policies call for funding of all
Environmental Quality       high-priority environmental quality program activities, the services
Programs Cannot Ensure      have not always been able to fund all such activities through their
                            environmental quality program. While program managers for most of
That DOD’s Requirement      the installations we visited said that the environmental quality programs
to Fund All High-Priority   were generally able to fund high-priority environmental activities during
Needs Is Met                fiscal years 1999 through 2002, in some instances installations were
                            not able to fund all such activities. To address such situations, installation
                            officials deferred certain high-priority activities, sought an extension
                            of a compliance deadline, obtained funding from other sources at the
                            installation, or stretched their allotment of environmental funding to pay
                            for more activities than planned.

                            According to some environmental managers at the installations where
                            high-priority activities were deferred, the activities they were most likely
                            to defer were those that do not have a firm timeline for completion, such
                            as surveys of cultural resources. Certain requirements, such as those in
                            the Sikes Act or the National Historic Preservation Act that require
                            installations to survey their natural or cultural resources, do not provide
                            for a penalty for missing a deadline or do not specify when these activities
                            must be undertaken. Consequently, although not completing these
                            activities means that the installation is not in compliance with an
                            environmental requirement, there is little likelihood of a risk to human
                            health or a risk of receiving a notice of violation, fine, or penalty from a
                            regulator. Thus, noncompliance with these requirements presents, at least
                            in some cases, a lower risk to the installation than would noncompliance
                            with certain other environmental requirements. Nonetheless, DOD’s
                            definition of must-fund, high-priority environmental activities includes all
                            activities needed to keep installations in compliance with federal, state,
                            or local laws and regulations, as well as executive orders, even where
                            there are no compliance deadlines or risk of a fine. In cases in which
                            installations deferred selected required activities, it may have resulted in
                            noncompliance with federal environmental laws.

                            Officials at other installations we visited also cited concerns about the
                            deferral of certain environmental activities, particularly those that may
                            not have a compliance deadline and are thus considered lower priorities.
                            For example, a senior environmental official at Vandenberg Air Force Base
                            described how the rapid spread of Argentinean pampas grass, an invasive
                            species, had resulted in the U.S. Fish and Wildlife Service listing the
                            grass as a major threat to four federally endangered plant species on the
                            installation and requiring that the Air Force eradicate the grass—at a cost
                            of approximately $1 million. According to Vandenberg environmental


                            Page 19                                GAO-03-639 DOD Environmental Compliance
    officials, they had requested environmental funding for the project when
    the grass was initially found because they believed the cost to eradicate it
    at that time would be minimal compared to the future expense if the
    grass were left uncontrolled. However, the installation could not obtain
    environmental quality funding for the project because it was a Class III
    activity and Air Force policy prohibits funding of lower priorities. The
    project was not funded until the U.S. Fish and Wildlife Service listed the
    grass as a major threat to the endangered species.

    Environmental program managers at most of the installations we
    visited indicated that they have generally been able to fund emergency,
    high-priority environmental activities that occurred outside the normal
    budgeting cycle, but they have done so by using funds allocated for other
    planned high-priority activities, emergency or year-end funding from the
    environmental quality program, or other funding sources at the installation
    or command. In some cases, certain planned activities could be deferred
    because the regulatory deadlines slipped or the regulators granted the
    installation an extension on meeting the deadline. Some environmental
    managers also mentioned that in some instances, planned activities
    come in under budget, which can result in extra funds being available for
    other, unexpected needs. At the installations we visited, environmental
    managers dealt with a variety of unexpected needs for funding, including
    the following:

•   A Texas regulatory agency required Fort Bliss to immediately investigate
    and assess a fuel leak. To pay for this unbudgeted activity, the chief of
    the installation’s environmental compliance division approved the
    reprogramming of some of the funding from 13 other high-priority
    environmental activities.

•   Fort Campbell’s environmental office acquired some Army Corps of
    Engineers’ property that had soil erosion problems. Because the land was
    acquired during the middle of the fiscal year, the environmental quality
    program had not budgeted funds to address the erosion. The Corps agreed
    to provide funding for interim erosion control.

•   Camp Pendleton faced an emergency when sewage began to flow out of
    manholes on a training range near a wetland. The installation used base
    operating funds for cleanup and to clear out the clogged main sewer line.
    The Marine Corps’ environmental quality program also provided $500,000
    in emergency funding to determine the cause of the problem and, hoping




    Page 20                               GAO-03-639 DOD Environmental Compliance
    to avoid other such occurrences, to assess the condition of 150 miles of
    the main sewer line.16

    Regarding future, high-priority activities, some of the services have
    recently indicated that their environmental quality programs will have
    difficulties funding all high-priority activities in fiscal year 2003 and even
    greater difficulties in fiscal year 2004. Specifically,

•   In early 2003, in preparation of its presidential budget request for fiscal
    year 2004, the Army reported that in each fiscal year 1998 through 2003,
    its environmental quality program funded or will fund between 83 and
    98 percent of validated high-priority activities. However, the Army
    estimates that in fiscal 2004, the program will be able to fund just
    78 percent of its high-priority activities. Army officials indicated that
    their environmental quality program will not only face larger funding
    needs for high-priority activities in fiscal year 2004, but also that the
    program’s budget will be lower than the previous 2 years because some
    of these funds will be needed for other priorities, including the global
    war on terrorism and spare parts for military equipment. To address
    this anticipated shortfall, the Army expects its major commands and
    installations to provide funds from other command or installation budget
    sources as needed to ensure that the installations remain in compliance
    with environmental requirements. However, the availability of such
    funds is uncertain given DOD’s ongoing challenges in containing the
    deterioration of its military facilities as discussed earlier in this report.

•   According to Air Force officials, funding for the environmental quality
    program will be decreased in fiscal year 2004 because of competing
    demands on overall Air Force resources. Air Force officials also stated
    that this reduction will be absorbed by the major commands, which are
    required to fully fund all must-fund activities, even if it means migrating
    funds into the environmental quality program from other operations and
    maintenance activities.




    16
      The assessment, using video technology that could detect tree roots, cracks, and other
    potential problems, found that the sewer lines had been clogged by cooking grease, tree
    roots, and other objects that had been flushed down toilets, including t-shirts and diapers,
    in base housing and interstate highway rest stops along Camp Pendleton’s property. Based
    on the results of the emergency assessment, Camp Pendleton has requested $7.5 million in
    repairs, to be paid for through the Marine Corps’ sustainment, restoration, and
    modernization program rather than the environmental program.




    Page 21                                       GAO-03-639 DOD Environmental Compliance
                      DOD has established broad policy for its environmental compliance
Conclusions           program that does not specify which activities can be funded. As a
                      result, there is significant variation in how the services interpret this
                      policy and implement their own environmental quality programs. This
                      variation among the services’ programs can result in different eligibility
                      requirements for environmental activities across services and funding of
                      activities that would be more appropriately funded from other sources,
                      such as military operations or base maintenance. Given the services’
                      broad and differing interpretations of eligibility for environmental quality
                      program funding, as well as their inclusion of activities that are more
                      closely related to military operations or maintenance, DOD cannot be
                      assured that the services’ environmental funding needs have been
                      accurately identified, that its funds for environmental quality are being
                      targeted to its most critical environmental requirements, or that its
                      management of its environmental responsibilities continues to improve.
                      Although the services have, over the past decade, made significant
                      improvements in their environmental compliance performance, these
                      improvements have leveled off in recent years, and DOD has not reached
                      its goal of full environmental compliance. Further, given that the services
                      have not always been able to fund all high-priority environmental quality
                      activities and expect this condition to worsen in fiscal year 2004, it is all
                      the more important that DOD target its environmental quality program
                      funds wisely.


                      To ensure that DOD can better target environmental quality program
Recommendations for   funds to the most important and most appropriate activities, we
Executive Action      recommend that the Secretary of Defense establish a more specific
                      policy on which activities should be eligible for funding through the
                      services’ environmental quality programs and how such activities should
                      be prioritized and funded. We are also recommending that the military
                      services subsequently conform their policies and processes to the revised
                      DOD policy.




                      Page 22                                GAO-03-639 DOD Environmental Compliance
                     We provided DOD with a draft of this report for review and comment.
Agency Comments      DOD provided technical clarifications, which we incorporated as
and Our Evaluation   appropriate. However, DOD did not provide overall comments as of the
                     issuance date of this report.


                     We will send copies of this report to the Secretary of Defense; the
                     Director, Office of Management and Budget; appropriate congressional
                     committees; and other interested parties. We will also provide copies to
                     others upon request. In addition, the report will be available, at no charge,
                     on the GAO Web site at http://www.gao.gov.

                     If you or your staff have any questions, please call me or Edward Zadjura
                     at (202) 512-3841. Contributors to this report are listed in appendix II.




                     (Ms.) Anu K. Mittal
                     Acting Director, Natural Resources
                      and Environment




                     Page 23                                GAO-03-639 DOD Environmental Compliance
                         Appendix I: Scope and Methodology
Appendix I: Scope and Methodology


                         To assess DOD’s and the military services’ processes for identifying,
                         prioritizing, and funding their environmental quality activities, we
                         reviewed the policies and procedures established by DOD and the services
                         to guide implementation of the environmental quality program. We also
                         reviewed each service’s system for identifying, prioritizing, and funding
                         their environmental quality activities, and compared this information
                         across the services to identify differences in the programs.

                         To determine how environmental activities are identified and prioritized
                         by installations, we visited 11 active military installations in the United
                         States (listed below). Generally, we selected at least two installations from
                         each service. We selected these installations primarily because of their
                         large environmental quality budgets and because they represent a diversity
                         of major commands, military missions, and geographic locations. Because
                         the Navy’s environmental quality program is organized into regions,
                         we selected two Navy regional offices rather than two installations.
                         Within these two Navy regions, we visited a total of four installations
                         and reviewed environmental funding requests for an additional four
                         installations. Our observations about individual projects or activities at
                         these installations are not generalizable to projects or activities at all
                         military installations.


Military Installations   U.S. Air Force
GAO Visited              Eglin Air Force Base, Florida
                         Vandenberg Air Force Base, California

                         U.S. Army
                         Fort Bliss, Texas
                         Fort Campbell, Kentucky
                         Fort Carson, Colorado

                         U.S. Navy
                         Navy Mid-Atlantic Region: Naval Station Norfolk, Virginia; Naval Weapons
                         Station Yorktown, Virginia (Note: We also reviewed environmental funding
                         requests for Naval Air Station Oceana, Virginia, and Naval Amphibious
                         Base Little Creek, Virginia.)

                         Navy Region Southwest: Naval Air Station, North Island, California; Naval
                         Station Point Loma, California (Note: We also reviewed environmental
                         funding requests for Naval Station San Diego, California, and Naval
                         Auxiliary Landing Field San Clemente Island, California.)



                         Page 24                               GAO-03-639 DOD Environmental Compliance
Appendix I: Scope and Methodology




U.S. Marine Corps
Marine Corps Base Camp Lejeune, North Carolina
Marine Corps Base Camp Pendleton, California

At each installation visited, we interviewed environmental quality
program officials to obtain information about their implementation of the
environmental quality program. We reviewed these installations’ lists of
planned environmental projects for fiscal years 2002 through 2009 and
funding data for activities covering fiscal years 1999 through 2002. We
compared this information across the services to determine if there
were variations in the types of environmental activities being funded.
We also compared the installations’ lists of environmental activities to
service policy to determine if inappropriate or ineligible activities had
been funded.

To determine the role of the major commands in identifying, prioritizing,
and funding environmental activities and to obtain the commands’
perspectives on the environmental quality program, we discussed the
environmental quality program with officials from the major commands
associated with the installations and regions we visited: Army Forces
Command (Fort Campbell and Fort Carson), Army Training and Doctrine
Command (Fort Bliss), Air Force Space Command (Vandenberg Air Force
Base), Air Force Materiel Command (Eglin Air Force Base), the Navy’s
Atlantic Fleet (Navy Mid-Atlantic Region), and the Navy’s Pacific Fleet
(Navy Region Southwest). The Marine Corps does not have major
commands that play the type of role in the environmental quality program
that the commands play in the other services. We also discussed our
findings with officials of the Army’s new Installation Management Agency,
which will assume responsibility for funding environmental quality
programs at Army installations beginning in fiscal year 2004.

We also met with officials from the Office of the Secretary of Defense
and each service headquarters to obtain information on their roles in the
environmental quality program and their perspectives on the program, in
particular, on how environmental activities are identified, prioritized,
and funded.

We conducted our review from May 2002 through May 2003 in accordance
with generally accepted governmental auditing standards.




Page 25                              GAO-03-639 DOD Environmental Compliance
                  Appendix II: GAO Contacts and Staff
Appendix II: GAO Contacts and Staff
                  Acknowledgments



Acknowledgments

                  (Ms.) Anu K. Mittal (202) 512-3841
GAO Contacts      Edward Zadjura (202) 512-9914


                  In addition to the individuals named above, Kelly Blado, Christine Frye,
Acknowledgments   Roderick Moore, Cynthia Norris, and Susan Swearingen made key
                  contributions to this report. Also contributing to this report were
                  Doreen Feldman, Anne Rhodes-Klein, and Amy Webbink.




(360206)
                  Page 26                               GAO-03-639 DOD Environmental Compliance
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Waste, and Abuse in      E-mail: fraudnet@gao.gov
Federal Programs         Automated answering system: (800) 424-5454 or (202) 512-7470


                         Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800
Public Affairs           U.S. General Accounting Office, 441 G Street NW, Room 7149
                         Washington, D.C. 20548