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entitled 'Improvement Continues in DODís Reporting on Sustainable 
Ranges, but Opportunities Exist to Improve Its Range Assessments and 
Comprehensive Plan' which was released on December 16, 2008. 

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December 15, 2008: 

Congressional Committees: 

Subject: Improvement Continues in DOD's Reporting on Sustainable 
Ranges, but Opportunities Exist to Improve Its Range Assessments and 
Comprehensive Plan: 

Recent operations in Iraq, Afghanistan, and other locations around the 
world have highlighted the need for U.S. forces to train as they intend 
to fight. Department of Defense (DOD) training ranges and operating 
areas are required to be managed and operated to support their long- 
term viability and utility to meet the national defense mission. The 
use of military training ranges enhances training by providing 
realistic, hands-on experience. Sustainable training range management 
focuses on the practices that allow the military to manage its ranges 
in a way that ensures their usefulness well into the future. Because 
the military faces obstacles in acquiring new training lands, the 
preservation and sustainable management of its current lands must be 
priorities. New advances in technology, coupled with a shift in force 
posture, mean that DOD needs to continually update and maintain its 
training ranges. Military training ranges vary in size from a few 
acres--for small arms training--to over a million acres for large 
maneuver exercises and weapons testing, and include broad open ocean 
areas for offshore training and testing. These ranges face ever 
increasing limitations and restrictions on land, water, and airspace as 
residential, commercial, and industrial development continues to expand 
around and encroach upon once remote military training and testing 
installations. 

Section 366 of the Bob Stump National Defense Authorization Act for 
Fiscal Year 2003,[Footnote 1] dated December 2, 2002, required that the 
Secretary of Defense report on several items related to its training 
ranges. First, it required the Secretary to develop a comprehensive 
plan for using existing authorities available to the Secretary and the 
military services to address training constraints caused by limitations 
on the use of military lands, marine areas, and airspace--both in the 
United States and overseas. Section 366 of the act required the 
Secretary of Defense, in preparing the plan, to conduct an assessment 
of current and future training range requirements and an evaluation of 
the adequacy of current DOD resources--including virtual and 
constructive assets as well as military lands, marine areas, and 
airspace available in the United States and overseas--to meet current 
and future training range requirements. The plan was to include (1) 
proposals to enhance training range capabilities and address any 
shortfalls in DOD resources identified pursuant to the assessment and 
evaluation discussed above, (2) goals and milestones for tracking 
planned actions and measuring progress, (3) projected funding 
requirements for implementing planned actions, and (4) designation of 
an office in the Office of the Secretary of Defense (OSD) and in each 
of the military departments with lead responsibility for overseeing the 
implementation of the plan. Section 366 further required the Secretary 
to submit the plan, the results of the assessment and evaluation, and 
any recommendations that the Secretary may have for legislative or 
regulatory changes to address training constraints in a report to 
Congress at the same time that the President submitted the budget for 
fiscal year 2004. In addition, section 366 required the Secretary to 
submit a report to Congress annually for fiscal years 2005 through 
2013[Footnote 2] describing the progress made in implementing the 2004 
plan and any additional actions taken or to be taken to address 
training constraints caused by limitations on the use of military land, 
marine areas, or airspace. Section 366 also required the Secretary to 
report to Congress, not later than June 30, 2003, on its plans to 
improve DOD's readiness reporting system to reflect the readiness 
impact on specific units of the military services due to training 
constraints caused by limitations on the use of military lands, marine 
areas, and airspace. Finally, section 366 required the Secretary to (1) 
develop and maintain an inventory that identifies all available 
operational training ranges, all training range capacities and 
capabilities, and any training constraints caused by limitations on the 
use of military lands, marine areas, and airspace at each training 
range in fiscal year 2004 and (2) provide an updated inventory to 
Congress each year for fiscal years 2005 through 2013.[Footnote 3] The 
Under Secretary of Defense for Personnel and Readiness issued DOD's 
fifth annual sustainable ranges report and inventory to Congress on 
September 18, 2008.[Footnote 4] Enclosure I contains the text of 
section 366 of the act. 

Section 366(d) of the Bob Stump National Defense Authorization Act for 
Fiscal Year 2003 requires GAO to submit to Congress an evaluation of 
DOD's report regarding its training range comprehensive plan and its 
readiness reporting improvements within 90 days of receiving the report 
from DOD. We received the report and inventory on September 16, 2008. 
In 2007, we found that DOD had made improvements to its annual 
sustainable ranges report, but further improvements could be 
made.[Footnote 5] 

This is our fifth review in response to our mandate in section 366 of 
the act.[Footnote 6] It discusses (1) the extent to which DOD's 2008 
sustainable ranges report and training range inventory address the 
elements of section 366 and (2) opportunities for DOD to further 
improve its sustainable ranges report. 

Because DOD has addressed most of the elements of section 366 that were 
to be addressed in its fiscal year 2004 report, as well as the 
recommendations we included in our 2007 assessment, we focused our 
review on summarizing the changes made to DOD's sustainable ranges 
report in addressing these elements and recommendations and on 
identifying opportunities for improving DOD's report to make it more 
useful to Congress and other interested parties. To determine the 
extent to which DOD's 2008 sustainable ranges report and training range 
inventory address the elements of section 366 that were required to be 
in DOD's original fiscal year 2004 plan, we reviewed the report and 
inventory and met with DOD and service officials to discuss them. We 
discussed challenges DOD faced in meeting the congressionally mandated 
requirements in fiscal year 2004--and continues to face--and changes in 
the report and inventory since 2007. We also compared the report and 
training range inventory to the criteria in section 366 of the National 
Defense Authorization Act for Fiscal Year 2003 to determine the extent 
to which this year's report addresses the elements of section 366 that 
were required to be in DOD's original fiscal year 2004 plan. To 
identify opportunities for DOD to improve its comprehensive plan within 
the sustainable ranges report, we compared the 2008 report with 
elements of the comprehensive plan required by section 366. We also 
compared DOD's 2008 report and training range inventory to prior DOD 
and GAO reports. In addition, we reviewed this year's report to 
determine if DOD addressed the recommendations we included in our 2007 
report. To determine the progress that the services have made in their 
initiatives to sustain their training ranges, we met with service 
officials about their inputs to DOD's 2008 sustainable ranges report 
and inventory, key initiatives they have undertaken to address range 
sustainment, challenges in addressing range sustainment and 
encroachment issues, and progress or changes since we last reported. 
The objective of this engagement was to determine the extent to which 
DOD's sustainable ranges report addressed the elements of section 366, 
not to comprehensively evaluate the data presented in the report. We 
conducted this performance audit from August 2008 through December 2008 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Results in Brief: 

DOD continues to make progress in addressing most of the elements of 
section 366. This year's report describes the progress DOD has made in 
implementing its range sustainment plan, as required by section 366. 
Further, DOD's 2008 sustainable ranges report has made progress in 
addressing the elements of section 366 required for DOD's original 
fiscal year 2004 report, but the report does not fully address three of 
these elements. The report updates improvements made in addressing four 
elements of the act required for DOD's fiscal year 2004 report: (1) the 
evaluation of the adequacy of resources to meet current and future 
requirements; (2) DOD's goals and milestones for tracking planned 
actions and measuring progress; (3) designation of offices within OSD 
and the military departments that are responsible for overseeing the 
implementation of DOD's sustainable ranges comprehensive plan; and (4) 
DOD's plans to improve its readiness reporting system. To address the 
adequacy of its current resources to meet current and future 
requirements, DOD established standardized criteria and identified 
common factors to assess range capabilities and encroachment, as we 
recommended in our 2007 report.[Footnote 7] DOD officials said that 
they worked closely with service officials to build a common set of 
capability attributes and encroachment factors and service-specific 
mission areas to evaluate them against. In addition, for the first 
time, DOD's sustainable ranges report also includes three elements of 
section 366 required to be included in DOD's fiscal year 2004 report: 
(1) an assessment of current and future training range requirements, 
(2) an evaluation of virtual and constructive[Footnote 8] assets to 
meet range requirements, and (3) projected funding requirements for 
implementing planned range sustainability actions. On the other hand, 
the report did not put forth any recommendations that the Secretary may 
have for legislative or regulatory changes to address training 
constraints, nor did it explain the omission. Additionally, while DOD 
did not identify training constraints caused by limitations on the use 
of military lands, marine areas, and airspace for each of its ranges, 
it included an assessment of such constraints on its major training 
ranges. As in prior years, DOD officials told us that the large volume 
of data required to identify capacities, capabilities, and constraints 
on all of its ranges makes doing so impractical. Finally, DOD did not 
provide proposals to enhance training range capabilities or address any 
shortfalls in its resources identified pursuant to the assessment and 
evaluation under Section 366(a)(2), although each of the services has 
assessed their current resources to meet current and future 
requirements, which has allowed them to determine their shortfalls in 
resources. 

Although DOD has made progress in addressing elements of section 366, 
opportunities exist to provide additional information in support of its 
sustainable ranges report. For example, although each of the services 
identified the training ranges that would be assessed and conducted an 
assessment of these ranges, DOD's 2008 report does not provide a 
rationale for excluding some of its ranges. Including this information 
would have clarified the process used to determine which ranges would 
be assessed. In addition, DOD included standardized criteria and common 
factors for assessing the adequacy of current DOD resources to meet 
current and future requirements, but the Marine Corps deviated from the 
approach used by the other services to define its mission areas. The 
Marine Corps assessed how its range capabilities and encroachment 
factors impact a unit's ability to complete training, rather than 
assessing how specific mission training tasks are affected, although 
benefits may exist from identifying impacts at the unit level. This 
approach makes it difficult to know which specific Marine Corps 
training tasks are impacted and thus also difficult to determine where 
resources should be allocated to improve the Marine Corps range 
sustainment program. Furthermore, although DOD established goals and 
milestones for tracking planned actions and measuring progress for four 
critical range sustainment areas, one of these goals has not been 
updated. Since 2006, DOD has continued to duplicate the stated goal for 
operations and maintenance as the modernization and investment goal in 
its sustainable ranges reports. Additionally, for the past 2 years, the 
Air Force deviated from the approach used by the other services and did 
not update its actions to support DOD's modernization and investment 
goal. Without the annual updates, Congress has less visibility of the 
progress made toward achieving this goal. Finally, although this is the 
first year that DOD's sustainable ranges report has included projected 
funding requirements for implementing planned actions related to its 
range sustainability efforts, DOD's report does not identify the 
specific funding elements that each service included to determine its 
projected funding requirements. DOD expects to refine the collection 
and presentation of this information in future reports. In the 
meantime, without including the detailed funding elements for each 
service in the report, DOD limits congressional visibility over the 
services' actual range sustainment costs. We are making recommendations 
designed to improve the content of the sustainable ranges report. In 
commenting on a draft of this report, DOD concurred with three of our 
recommendations and did not concur with one recommendation. We discuss 
DOD's comments later in this report. DOD also provided technical 
comments on a draft of this report, which we have incorporated where 
appropriate. 

DOD Continues to Make Progress in Addressing Most Section 366 Elements: 

DOD has made progress in addressing most of the elements included in 
section 366 of the Bob Stump National Defense Authorization Act for 
Fiscal Year 2003. DOD's 2008 sustainable ranges report and inventory is 
responsive to the requirement that DOD describe the progress made in 
implementing its sustainable ranges plan and any additional action 
taken, or to be taken, to address training constraints caused by 
limitations on the use of military lands, marine areas, and airspace. 
The report also includes improvements to its standardized criteria and 
common factors for assessing the adequacy of current DOD resources to 
meet current and future requirements, as we recommended in our report 
last year; updates to the designated lead offices within DOD and the 
services that are responsible for implementing DOD's range sustainment 
plan; and an update on the status of its readiness reporting system. In 
addition, this year's report includes four elements of section 366 that 
were required to be included in DOD's fiscal year 2004 report, but have 
not been captured in prior years' reports. However, this year's report 
does not include any recommendations the Secretary may have for 
legislative or regulatory changes to address training constraints, nor 
did DOD assess the training constraints on all of its training ranges. 
Additionally, DOD's report did not provide proposals to enhance 
training range capabilities or address any shortfalls in its resources 
identified pursuant to the assessment and evaluation under Section 
366(a)(2). 

DOD's Sustainable Ranges Report Describes the Progress Made in 
Implementing Its Range Sustainment Plan: 

Rather than revisiting the details of many of the sustainable range 
initiatives discussed in previous reports, DOD's 2008 report provides 
an update on the continued progress being made in implementing the 
range sustainment plan, and any additional actions it has taken or 
plans to take to address training constraints caused by limitations on 
the use of military lands, marine areas, and airspace, as required by 
section 366(a)(5). According to DOD, its 2008 report differs in 
structure and format from previous reports in that it represents an 
update to DOD's previous four reports, builds on previous DOD 
submissions on its range sustainment activities, and serves as a 
baseline for future reports. In this report DOD reestablishes the 
baseline for future reports by (1) analyzing program element data, such 
as the comprehensive range inventory; (2) assessing progress made in 
implementing goals and actions; (3) applying new standardized methods 
for assessing range capabilities and encroachment impacts; (4) 
addressing funding requirements associated with implementing range 
sustainability initiatives; and (5) identifying new program directions, 
priorities, and management initiatives. Furthermore, DOD's report 
states that the objective of this new format is to provide Congress 
with a concise and consistent report that highlights the continued 
evolution of the sustainable ranges initiative and allows progress 
against section 366 reporting requirements to be easily determined. 

DOD Has Continued to Make Improvements in Addressing Four Other 
Elements of Section 366: 

Over the last few years DOD has continued to make improvements in 
addressing and updating its responses to four other elements of section 
366 required in DOD's fiscal year 2004 report. These elements include: 
(1) DOD's evaluation of the adequacy of resources to meet current and 
future requirements, (2) updates to DOD's goals and milestones for 
tracking planned actions measuring progress, (3) an updated list of the 
designated offices within OSD and the military departments that have 
lead responsibility for overseeing the implementation of DOD's 
sustainable ranges comprehensive plan, and (4) DOD's plans to improve 
its defense readiness reporting system to reflect the readiness impact 
that training range constraints have on its operational forces. 

Adequacy of Current Resources to Meet Current and Future Requirements: 

Like last year's report, DOD's 2008 report includes an evaluation of 
the adequacy of each service's current resources to meet current and 
future training range requirements, including military lands, marine 
areas, and airspace available in the United States and overseas. In our 
2007 report,[Footnote 9] we recommended that DOD establish standardized 
criteria and identify the common factors it used in assessing the 
adequacy of current DOD resources to meet current and future 
requirements. DOD concurred and incorporated our recommendation in its 
evaluation by assessing a given range's ability to support assigned 
missions areas using 13 common capability attributes and 12 common 
encroachment factors. According to DOD officials, they worked closely 
with service officials to build a common set of capability attributes 
and encroachment factors and service-specific mission areas to evaluate 
them against. DOD's evaluation includes an assessment of range 
capabilities and the encroachment factors--such as noise restrictions 
or endangered species restrictions--that constrain training ranges. 
These assessments are presented in table format and rated with red, 
yellow, and green scores to convey the severity of the impacts caused 
by shortfalls in required capabilities to meet current and future 
requirements. For example, the Army assessed land shortages at Fort 
Campbell, Kentucky; Fort Carson/Pinon Canyon Maneuver Site, Colorado; 
Fort Drum, New York; Fort Hood, Texas; and Fort Riley, Kansas as 
severely affecting its overall mission, while it considered shortfalls 
in available targets to have only a minimal impact. Establishing these 
criteria provides DOD with a consistent approach for reporting the 
impact that range sustainment has on DOD units across all services. 
Each military service used a doctrinal approach to identify its mission 
areas as standard criteria for assessing range capabilities and the 
impact of various encroachment factors. 

Goals and Milestones for Tracking Planned Actions and Measuring 
Progress: 

In 2005, DOD established goals and milestones for tracking planned 
actions and measuring progress in four critical range sustainment 
areas--modernization and investment, operations and maintenance, 
environment, and encroachment. For each goal, actions and milestones 
have been identified for fulfillment during fiscal years 2005 through 
2011. The stated goals for each of these critical sustainment areas are 
as follows: 

* Modernization and Investment: Sustain range operations in accordance 
with OSD and service training transformation strategies by resourcing 
advanced instrumentation and other infrastructure. 

* Operations and Maintenance: Provide resources for standardized land 
management structure and operations that mitigate encroachment and 
provide for range sustainment. Maximize and sustain the availability of 
military range infrastructure and land assets. 

* Environment: Focus the environmental management systems to fully 
support sustained required access to ranges. 

* Encroachment: Maximize the accessibility of DOD ranges by minimizing 
restrictions brought about by encroachment factors. Implement 
sustainment outreach efforts that will improve public understanding of 
DOD requirements for training and testing, and support coalition- 
building and partnering on range sustainment issues important to DOD 
readiness. 

According to DOD, this common framework of goals and milestones has 
enabled DOD and the services to make meaningful comparisons and 
measurements of past performance and progress toward both near-and long-
term objectives. DOD's 2008 report provided updates, as necessary, to 
actions taken by the services in response to the four goals and 
milestones. 

Designation of Lead Offices Responsible for Overseeing Implementation 
of Range Sustainability Plan: 

This year's report provides an update to the informational table 
presented in DOD's 2004 report that identifies the offices within OSD 
and the military departments that have lead responsibility for 
overseeing the implementation of DOD's comprehensive range 
sustainability plan. DOD's 2008 report not only provides the new 
organizational names for some of the responsible offices, but for the 
Navy, it also identifies offices that were not previously included in 
DOD's 2004 report. Table 1 identifies the responsible offices within 
the Office of the Secretary of Defense and the military services. 

Table 1: Responsible Training Range Offices within OSD and the Military 
Services: 

Organization: Office of the Secretary of Defense (OSD); 
Office with designated responsibility: Office of the Deputy Under 
Secretary of Defense (Personnel & Readiness) OUSD(P&R); 
Director, Military Training, and Sustainable Ranges;
Office of the Deputy Under Secretary of Defense (Readiness). 

Organization: Air Force; 
Office with designated responsibility: Deputy Chief of Staff for 
Operations, Plans, and Requirements; 
Director of Current Operations and Training Ranges and Airspace 
Division, HQ USAF (Headquarters United States Air Force)/A30- AR. 

Organization: Army; 
Office with designated responsibility: Office of the Deputy Chief of 
Staff, G-3/5/7; Training Directorate; 
Training Support Systems Division (DAMO-TRS). 

Organization: Navy; 
Office with designated responsibility: Office of the Chief of Naval 
Operations, Materiel Readiness, and Logistics (N4); 
Fleet Readiness Division (N43); Range Modernization and Investment 
(N433) and Range Operations and Maintenance (N433); 
Environmental Readiness Division (N45) Operational and Environmental 
Readiness Planning Branch (N456); 
Commander, Naval Installations Command (CNIC)/Ashore Readiness Division 
(N46). 

Organization: Marine Corps; 
Office with designated responsibility: Commanding General, Training, 
and Education Command; Range and Training Area Management Division; 
Range Modernization & Investment; Range Operations & Maintenance; 
Deputy Commandant for Installations and Logistics; 
Facilities and Services Division; Environmental; Encroachment. 

Source: DOD's 2008 Report to Congress on Sustainable Ranges (September 
2008). 

[End of table] 

Readiness Reporting Improvements: 

Although DOD has not finalized its plans to incorporate a range 
readiness component into its new Defense Readiness Reporting System, it 
has made progress in establishing the framework for this initiative. 
DOD stated in its 2008 sustainable ranges report that it plans to 
establish a component within the Defense Readiness Reporting System 
that will report "range as a resource" for supporting a military 
mission. In its report, DOD stated that efforts are under way to design 
the model to be used for reporting range readiness through its 
readiness reporting system. DOD officials also told us that the 
department will conduct a pilot test over the next several months to 
validate its concept for managing the data necessary to support this 
system. DOD stated in its report that this pilot test will form the 
basis of the functional requirements to build the initial range 
readiness pages into the new readiness reporting system. According to 
DOD officials, funding for the pilot has been approved and the pilot is 
expected to implement the assessment framework outlined in DOD's 2008 
report. Additionally, DOD officials stated that this pilot test will 
accomplish the first phase of a two-phased implementation plan for 
reporting range readiness in Defense Readiness Reporting System 
implementation. The objective of the second phase will be to link 
readiness assessments from units and their associated mission-essential 
tasks and assessments from an installation's functional requirements to 
the range assessment framework. In response to a direction from the 
House Armed Services Committee Report on the 2009 National Defense 
Authorization Act, DOD is planning to present the results of the pilot 
test in a report to the committee in March 2009.[Footnote 10] The 
report will include information on how encroachment affects the 
training and readiness levels of tactical units. 

DOD's 2008 Sustainable Ranges Report Addresses Three Elements of 
Section 366 That Were Not Included In Previous Reports: 

DOD's 2008 sustainable ranges report includes three elements that were 
not included in prior reports: (1) an assessment of the current and 
future training requirements of the armed forces; (2) a description of 
virtual and constructive training assets used to provide realistic 
training events that help to meet DOD training requirements and (3) 
projected funding requirements associated with implementing planned 
actions. 

Assessment of Current and Future Training Range Requirements: 

Section 366 required DOD to provide an assessment of current and future 
requirements in its fiscal year 2004 report. To address this element of 
Section 366, DOD's 2008 sustainable ranges report emphasized describing 
the processes used by each of the services to derive its current and 
future training range requirements. With respect to current training 
requirements, DOD's report states that each of the services maintains a 
comprehensive set of processes specific to its mission and command 
structure and that these processes are used to develop, document, and 
execute training objectives and requirements. Additionally, the report 
states that DOD groups its future requirements into two categories: 
near term and long term. According to DOD, near-term requirements can 
be assessed with some degree of accuracy, because the services can 
reasonably anticipate the near-term strategic environment, operating 
concepts, and technological capabilities. However, assessing long-term 
requirements is significantly more challenging, because there is 
greater uncertainty surrounding these factors. 

DOD's 2008 report states that each of the services has developed a 
framework for determining its current and future training requirements. 
Although the frameworks all have similarities, each service's framework 
is unique, and each includes an assessment of the national security and 
military strategies of the United States, guidance for the development 
and employment of forces, the Universal Joint Task List and Combatant 
Commander assigned Mission Essential Tasks, and lessons learned from 
previous training evaluations, among other things. The strategies for 
assessing service training requirements can also be found in a variety 
of DOD publications, doctrinal reports, and guidance documents. 

Live, Virtual, and Constructive Training Strategy: 

Unlike prior reports, this year's report also includes an evaluation of 
virtual and constructive training assets to meet current and future 
training range requirements. The overview of DOD's live, virtual, and 
constructive training strategy included in this year's report outlines 
the role this training strategy plays in providing what DOD believes is 
realistic, comprehensive, and cost-effective training. DOD stated that 
this type of training cannot replace live training, but it can 
supplement and enhance live training to sustain proficiency. DOD stated 
in its 2008 report that live, virtual, and constructive training and 
other related departmental science and technology initiatives will 
greatly increase the capabilities and interoperability of the virtual 
training environment. According to DOD, when its live, virtual, and 
constructive training network is fully operational, it will provide 
commanders with immediate access to a global communications, 
experimentation, testing, and education network that will enable units 
to train effectively at an affordable cost from geographically 
dispersed locations. Additionally, DOD stated that in November 2007 it 
successfully conducted an integrated live, virtual, and constructive 
training proof-of-concept demonstration. The demonstration used 
existing technologies to network an F-15E aircraft (live) with an F-15E 
simulator (virtual), while integrating computer-generated threats 
(constructive) into both environments. The live aircraft and the manned 
F-15E simulator, operating as a wingman, targeted and destroyed the 
simulated threats that appeared on their respective radar displays. The 
progress gained from this proof of concept will help DOD move forward 
on designing and building a more robust training component. 

Projected Funding Requirements: 

Section 366 required DOD's fiscal year 2004 report to include projected 
funding requirements for implementing planned actions related to its 
range sustainability effort. We have consistently reported that DOD 
failed to provide such funding requirements in prior reports. However, 
this year marks the first time DOD has included funding information in 
its sustainable ranges report. In an attempt to develop a common 
framework across the services for consistently and accurately reporting 
range sustainment funding, a sustainable ranges funding subgroup was 
formed in 2004 to examine funding strategies and categories used by the 
services for their training range sustainability efforts. In this 
year's report, DOD included four main categories, established by the 
funding subgroup, as a common starting point from which to report 
training range sustainment funding data: (1) modernization and 
investment, (2) operations and maintenance, (3) environment, and (4) 
encroachment. DOD stated in its report that these categories serve as 
an initial framework being explored by DOD and the services to track, 
report, and project the need for future fiscal resources to support 
range sustainment. Table 2 displays the estimated range sustainment 
funding for fiscal years 2008 and 2009 for each service that was 
included in DOD's 2008 report. 

Table 2: Service Training Range Sustainment Funding (dollars in 
millions)A: 

Service: Air Force: Modernization & Investment; 
Fiscal year: 2008: $60.4; 
Fiscal year: 2009: $62.0. 

Service: Air Force: Operations and Maintenance; 
Fiscal year: 2008: $197.6; 
Fiscal year: 2009: $205.7. 

Service: Air Force: Environmental; 
Fiscal year: 2008: $31.8; 
Fiscal year: 2009: $23.9. 

Service: Air Force: Encroachment; 
Fiscal year: 2008: $6.67[B]; 
Fiscal year: 2009: N/A. 

Service: Air Force Total; 
Fiscal year: 2008: $296.4; 
Fiscal year: 2009: $301.6. 

Service: Army: Modernization & Investment; 
Fiscal year: 2008: $321.5; 
Fiscal year: 2009: $339.3. 

Service: Army: Operations and Maintenance; 
Fiscal year: 2008: $217.8; 
Fiscal year: 2009: $293.5. 

Service: Army: Environmental; 
Fiscal year: 2008: $78.0; 
Fiscal year: 2009: $84.5. 

Service: Army: Encroachment; 
Fiscal year: 2008: $129.2; 
Fiscal year: 2009: $137.3. 

Service: Army Total; 
Fiscal year: 2008: $807.0; 
Fiscal year: 2009: $914.5. 

Service: Marine Corps: Modernization & Investment; 
Fiscal year: 2008: $25.5; 
Fiscal year: 2009: $53.2. 

Service: Marine Corps: Operations and Maintenance; 
Fiscal year: 2008: $33.7[C]; 
Fiscal year: 2009: $42.6[C]. 

Service: Marine Corps: Environmental; 
Fiscal year: 2008: $5.7; 
Fiscal year: 2009: $5.7. 

Service: Marine Corps: Encroachment; 
Fiscal year: 2008: $5.0; 
Fiscal year: 2009: $5.0. 

Service: Marine Corps Total; 
Fiscal year: 2008: $69.9; 
Fiscal year: 2009: $106.4. 

Service: Navy: Modernization & Investment; 
Fiscal year: 2008: $85.0; 
Fiscal year: 2009: $93.0. 

Service: Navy: Operations and Maintenance; 
Fiscal year: 2008: $174.2; 
Fiscal year: 2009: $177.9. 

Service: Navy: Environmental; 
Fiscal year: 2008: $12.3; 
Fiscal year: 2009: $10.0. 

Service: Navy: Encroachment; 
Fiscal year: 2008: $8.0; 
Fiscal year: 2009: $11.0. 

Service: Navy Total; 
Fiscal year: 2008: $279.5; 
Fiscal year: 2009: $291.7. 

Service: All Services: Service Total; 
Fiscal year: 2008: $1,452.8; 
Fiscal year: 2009: $1,614.2. 

Source: DOD's 2008 Report to Congress on Sustainable Ranges (September 
2008). 

Totals may not add due to rounding. 

[A] Range clearance funds are part of a program objective memorandum 
2010 initiative. 

[B] Estimated value. 

[C] Funds for real property maintenance and funds provided via base 
operating support are not included as these programs are centrally 
managed and breakouts to range-specific expenditures were not 
available. 

[End of table] 

This first attempt to summarize range sustainment funding data is an 
important step toward determining the adequacy of existing range 
sustainment resources. 

DOD's Sustainable Ranges Report Still Does Not Fully Address Three 
Elements of Section 366 That Were Required To Be Included in DOD's 
Original Fiscal Year 2004 Report and Inventory: 

Although DOD's 2008 sustainable ranges report addresses most of the 
elements of section 366 that were required for DOD's original fiscal 
year 2004 report and inventory, it still does not include any 
recommendations the Secretary may have for legislative or regulatory 
changes to address training constraints, and DOD still has not assessed 
the training constraints on all of its training ranges. Additionally, 
DOD's report does not provide proposals to enhance training range 
capabilities or address any shortfalls in its resources identified 
pursuant to the assessment and evaluation under Section 366(a)(2). 

Recommendations for Legislative or Regulatory Changes: 

In last year's report, DOD provided an explanation of its decision not 
to include any new recommendations for legislative or regulatory 
changes,[Footnote 11] but did not include such an explanation in this 
year's report. However, DOD's 2008 report does include a detailed 
overview of the legislative and regulatory initiatives that it has 
previously submitted to Congress, including approved exemptions from 
the Migratory Bird Treaty Act, the Endangered Species Act, and the 
Marine Mammal Protection Act, as well as previous recommendations to 
obtain exemptions from the Clean Air Act, the Resource Conservation and 
Recovery Act, and the Comprehensive Environmental Response Compensation 
and Liability Act that have not been approved.[Footnote 12] DOD's 
report also includes a discussion of specific state-and service-level 
legislative initiatives designed to alleviate some of the constraints 
placed on the military's ability to train. DOD officials told us that 
they do not have any plans to amend DOD's existing process for 
submitting requests for legislative language. 

Training Range Inventories: 

Although DOD did not identify all training constraints caused by 
limitations on the use of military lands, marine areas, and airspace 
for all of its ranges, as required in DOD's fiscal year 2004 inventory, 
it included an assessment of such constraints on its major training 
ranges in its 2008 report. As in prior years, DOD officials reported 
that it was impractical to complete an assessment for every training 
range in its inventory due to the large volume of data that would be 
required to identify capacities, capabilities, and constraints within 
its inventory. However, Appendix C of DOD's 2008 report does include a 
comprehensive listing of all operational training ranges and the 
capacities and capabilities available at each training range. For each 
range complex in DOD's training and testing inventory, DOD identifies 
the capacity of a range based on range description (land area for 
ranges, special-use airspace, sea surface area, and underwater tracking 
area) and the various types of capabilities that the range supports-- 
such as air to air/surface to air, air to ground, land maneuver, land 
impact area, land firing range, amphibious area, ocean operating area, 
and underwater tracking. 

DOD Did Not Provide Proposals to Enhance Training Range Capabilities or 
Address Any Shortfalls in Its Resources: 

As mentioned earlier, each of the services has assessed the adequacy of 
its current resources to meet current and future requirements, which 
has allowed them to determine their shortfalls in resources. However, 
DOD's 2008 report does not provide proposals to enhance training range 
capabilities or address any shortfalls in its resources identified 
pursuant to the assessment and evaluation under Section 366(a)(2), as 
required for DOD's fiscal year 2004 report. As a part of this 
assessment, each service identified its most prominent shortfalls and 
encroachment factors across all of its ranges. Some of the range 
capability attributes that resulted in shortfalls include land space, 
scoring and feedback system, threats, targets, and infrastructure. 
Additionally, some of the encroachment factors contributing to training 
range constraints included air quality, spectrum, wetlands, adjacent 
land use, and threatened and endangered species. According to DOD, the 
relationship between encroachment and capability is an emerging concept 
that will be further developed in future reports. Furthermore, DOD's 
2008 report concludes that the capabilities and encroachment data can 
be used by decision makers, planners, and analyst to develop strategies 
to (1) mitigate range and training area shortfalls, (2) bring required 
capabilities up to standards, and (3) address negative impacts from 
encroachment. However, proposed strategies for addressing these issues 
were not included in DOD's report. 

Opportunities Exist to Further Improve DOD's Range Sustainability Plan: 

Opportunities exist for DOD to further improve its comprehensive range 
sustainability plan by including additional information in its 
responses to three elements of section 366: (1) adequacy of current 
resources to meet current and future training requirements, (2) goals 
and milestones for tracking planned actions and measuring progress, and 
(3) projected funding requirements for implementing planned actions. 

DOD's Assessment of the Adequacy of Its Resources Does Not Include the 
Services' Rationales for Excluding Some Ranges in Their Evaluations: 

DOD's assessment of the adequacy of its resources does not include the 
services' rationales for excluding some ranges from their evaluations. 
According to DOD officials, the overall range capability and 
encroachment assessments included in DOD's 2008 sustainable ranges 
report are fairly accurate, based on available data, and vetted through 
multiple offices within DOD and the services in order to decrease the 
level of subjectivity. To guide the services through the assessment 
process DOD provided a reporting structure and definitions of each 
rating category. Each of the services identified the training ranges 
that it would assess and conducted assessments of these ranges, 
followed by confirmation of the final assessments by the headquarters 
of each service. However DOD's 2008 report does not provide an 
explanation of why each service excluded certain training ranges from 
its range capabilities and encroachment assessment. For example, the 
Army assessed only 14 of the more than 10,000 training ranges located 
on its 479 installations, while the Air Force excluded 6 of its 41 
ranges, the Marine Corps excluded 5 of its 14 ranges, and the Navy 
excluded 1 of its 23 ranges. Although the Air Force, Navy, and Marine 
Corps excluded only a small percentage of their ranges from their range 
capabilities and encroachment assessments, they did not explain the 
omissions. According to DOD and Army officials, the 14 ranges included 
in the Army's analysis represent Army Tier One installations and these 
Tier One installations support home station tasks for 88 percent of the 
Army's active component combat brigades. Furthermore, DOD reported to 
us that although the services did not provide rationale for excluding 
some of their ranges, the included ranges represented a significant 
percentage of the service's total range acreage, with the exception of 
the Army. For example, while the Army assessed only 30 percent of its 
total range acreage, the Marine Corps assessed 97.6 percent, the Air 
Force assessed 99.6 percent, and the Navy assessed 100 percent of their 
total range acreages. Additionally, DOD and service officials told us 
that the assessments included in DOD's 2008 report represented all of 
their major training ranges. DOD officials also stated that the 
services chose not to include assessments of all ranges because of the 
infrequent use and limited scope of some of the ranges. However, these 
explanations were not included in DOD's 2008 report. Consequently, DOD 
and the services missed an opportunity to provide more clarity to the 
process they used to determine which ranges would be assessed. 

The Marine Corps Deviated from the Approach Used by the Other Services 
to Define Its Mission Areas When Evaluating the Adequacy of Its 
Resources: 

Although DOD has established standard criteria for reporting the 
factors affecting its training ranges, our review of DOD's report found 
that the Marine Corps deviated from the approach used by the other 
services in defining its mission areas. Instead of assessing how a 
range's capability and encroachment factors impact specific mission 
training tasks--the approach used by the other services--the Marine 
Corps assessed how these factors impact an entire unit's ability to 
conduct training. The Marine Corps executes its national security 
missions through the Marine Air-Ground Task Force concept. Organized 
for specific missions, the task force has a standard structure 
consisting of four basic combat elements: command, aviation combat, 
ground combat, and logistics command. Instead of identifying these 
basic combat elements as the mission areas for assessing its ranges' 
capabilities and the impact of encroachment on those mission areas, the 
Marine Corps conducted its assessment using individual, unit, and 
Marine Air Ground Task Force expeditionary-level training[Footnote 
13]as its mission areas. Although there may be benefits from 
identifying impacts at the unit level, this approach makes it difficult 
to know which specific Marine Corps training tasks are impacted. 
Although DOD officials said the Marine Corps' approach is acceptable, 
it is inconsistent with the other services' approach, and it may also 
make it difficult to determine where resources should be allocated to 
improve the Marine Corps range sustainment program. 

One of DOD's Goals and Milestones Was Not Updated: 

Each year DOD requires the services to provide updates on actions they 
have taken to address DOD's four goals and milestones for its critical 
range sustainment areas--modernization and investment, operations and 
maintenance, environment, and encroachment; one of these goals was not 
updated. As mentioned earlier, according to DOD's 2005 report, the goal 
for modernization and investment is to sustain range operations in 
accordance with OSD and the services-level training transformation 
strategies by resourcing advanced instrumentation and other 
infrastructure. Since 2006, DOD has continued to duplicate the stated 
goal for operations and maintenance (resource for standardized land 
management structure and operations that mitigate encroachment and 
provide for range sustainment and maximize and sustain the availability 
of military range infrastructure and land assets) as the modernization 
and investment goal in its sustainable ranges report. Additionally, 
with respect to actions taken by the services to address DOD's 
modernization and investment goal, we found that the Air Force has not 
identified any actions in support of DOD's modernization and investment 
goal since it provided a progress report in DOD's 2006 report, whereas 
the other services reported on their progress in addressing actions 
related to this objective. For example, the Army, Navy, and Marine 
Corps reported updates to their efforts to (1) develop and annually 
update their range complex plans and (2) identify and document 
management processes for determining range requirements. In DOD's 2006 
report, the Air Force stated that it was in the process of developing 
templates for standardizing its range complex plans across its ranges. 
To date, the Air Force has not provided any additional information 
regarding the progress it has made in developing its range complex 
plans, nor has it reported its progress regarding any other actions DOD 
prescribed for addressing this goal. According to Air Force officials, 
the Air Force did not provide updated information to DOD for inclusion 
in its 2008 report because the Air Force has not taken any additional 
actions with respect to this goal. Unless the services provide annual 
updates regardless of whether they have taken any additional action on 
this DOD initiative, Congress has no visibility over the progress they 
have made toward achieving this goal. 

Projected Funding Requirements Do Not Provide Details on Funding 
Categories: 

This year's report is the first to include funding information; 
however, the accuracy of DOD's projected funding requirements can be 
improved. DOD has acknowledged in previous reports that it faces 
several challenges in addressing this requirement, because funding is 
managed differently by each service, and costs are spread across 
multiple funding categories. In its 2008 report, DOD provided guidance 
to the services by providing general descriptions of the various 
initiatives that should be included in each of the four range 
sustainability funding categories--modernization and investment, 
operations and maintenance, environment, and encroachment. However, in 
identifying projected funding requirements for each service, DOD's 
report does not provide a description of the funding data included in 
each of the four main categories. Furthermore, because the report does 
not provide this description, Congress has limited visibility over the 
specific content of each service's costs for range sustainment. 
According to DOD officials, the department expects to further refine 
how it collects and presents this information in future reports. DOD 
officials have initiated a study aimed at determining all of the 
funding elements included in DOD's range sustainment efforts, and they 
plan to use the results of this study to provide a more accurate view 
of funding for range sustainment in future reports. As DOD continues to 
refine its funding requirements in its future reports, the inclusion of 
specific details that comprise the cost associated with each funding 
category would help provide visibility to DOD and Congress of all 
sustainable range costs, including those costs that may be centrally 
managed. For example, the costs associated with range operations on an 
installation that may be centrally managed, such as real property 
maintenance, range operations, or related base operating costs, have 
not been included in each service's projected funding requirements. The 
inclusion of this information would also provide Congress and others 
with the necessary details to understand the funding estimates that 
support the cost of managing DOD's range sustainment. 

Conclusions: 

DOD has continued to improve its annual sustainable ranges report over 
the past few years. DOD's 2008 sustainable ranges report continues the 
trend and the report and its updated training range inventory address 
the mandated requirement to describe the progress made in implementing 
DOD's sustainable ranges plan and any additional action taken, or to be 
taken, to address training constraints. DOD's annual sustainable ranges 
report has also adequately addressed most of the elements of section 
366 that were required to be in DOD's original fiscal year 2004 report 
and inventory, with the exception of providing recommendations the 
Secretary may have for legislative or regulatory changes, and not 
assessing all of its ranges for training constraints caused by 
limitations on the use of military lands, marine areas, and airspace. 
Additionally, DOD's report did not provide proposals to enhance 
training range capabilities or address any shortfalls in its resources 
identified pursuant to the assessment and evaluation under Section 
366(a)(2). However, opportunities exist for DOD to continue to improve 
its report to make it more useful to Congress and other interested 
parties in coming years. For example, DOD could provide more clarity in 
its rationale for determining which ranges will be assessed. 
Furthermore, as DOD continues to evaluate the adequacy of its 
resources, the use of a consistent approach to define the Marine Corps 
mission areas for assessing range capability and encroachment would 
make it easier to identify which Marine Corps training tasks are 
impacted and where resources should be allocated. Additionally, DOD's 
sustainable ranges report could be improved by requiring the Air Force 
to update actions it has taken to address DOD's modernization and 
investment goal. Lastly, as DOD continues to refine its funding 
requirements in future reports, having a detailed description of all 
funding data included in each category would provide Congress and 
others with visibility of all costs, including the necessary details to 
understand the funding estimates that support the cost of managing 
DOD's range sustainment. 

Recommendations for Executive Action: 

To improve the range requirements and capabilities assessments and 
future comprehensive plans within the sustainable ranges reports, we 
recommend that the Secretary of Defense direct the Under Secretary of 
Defense for Personnel and Readiness, in consultation with the 
Secretaries of the military departments, to include the following four 
items in future sustainable ranges reports: 

* each service's rationale for excluding training ranges from its 
assessment of the adequacy of current resources to meet requirements, 

* the Marine Corps' individual combat training elements as the mission 
areas in the range capability and encroachment assessment, 

* an update on the actions taken by the Air Force to address DOD's 
modernization and investment goals for range sustainment, and: 

* a detailed description of all funding data included in each funding 
category, for each of the military services. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, the Deputy Under 
Secretary of Defense for Readiness concurred with three of our 
recommendations and indicated that actions will be taken in future 
reports to address them. DOD did not concur with our recommendation to 
include the Marine Corps' individual combat training elements as the 
mission areas in the range capability and encroachment assessment in 
future sustainable ranges reports. DOD stated that the Marine Corps' 
approach for assessing range capability and encroachment is consistent 
with the methodologies the Marine Corps uses to manage and resource its 
ranges. In addition, DOD stated that the levels of training displayed 
in the range capability and encroachment assessment charts are based on 
established training tasks. 

Although we recognize and commend DOD for establishing standard 
criteria for reporting the factors affecting its training ranges, the 
mission areas used by the Marine Corps may not provide Congress with 
the information needed to determine the specific training elements 
impacted by a range's capability attributes or encroachment factors. 
Additionally, the approach used by the Marine Corps is inconsistent 
with the other services' approach to identifying their mission areas. 
The purpose of the range capability and encroachment assessments charts 
in the 2008 sustainable ranges report is to help DOD identify mission 
areas inhibited by a range's inability to support specific training 
activities and consistency in presentation across all of the services 
enhances this understanding. While we recognize that the Marine Corps 
chose to display its mission areas based on established training tasks 
and this approach is consistent with its doctrine, we believe that 
providing additional information identifying the individual training 
elements that comprise the levels of training on the Marine Corps 
training continuum would provide Congress with more insight into which 
specific Marine Corps training elements are impacted by a range's 
inability to adequately support their training missions. Given that a 
Marine expeditionary unit has a standard structure consisting of four 
basic combat elements--command, aviation combat, ground combat, and 
logistics command--we believe that presenting the elements or mission-
specific tasks related to the four elements in the Marine Corps range 
capability and encroachment assessments would be much more useful. For 
example, instead of simply listing the Marine Expeditionary Unit (MEU) 
as a mission area, the Marine Corps could list the specific training 
activities that the MEU performs, such as fire support, aviation, or 
logistics. Listing these elements as mission areas would provide 
Congress and other interested parties with the additional information 
necessary to address and potentially fund the specific areas of 
training deemed not fully mission capable. Consequently, we continue to 
believe that our recommendation is valid. Furthermore, during our 
discussions with Marine Corps officials, they stated that they have the 
ability to provide this type of information if Congress or others 
required such detailed information. Nothing in our recommendation 
prevents the Marine Corps from presenting the information both ways. 
Consequently, we stand by our recommendation. 

The Deputy Under Secretary of Defense's comments are reprinted in 
enclosure II. DOD also provided technical comments, which we have 
incorporated where appropriate. 

We are sending copies of this report to the appropriate congressional 
committees. We are also sending copies to the Secretary of Defense; the 
Secretaries of the Army, the Navy, and the Air Force; the Commandant of 
the Marine Corps; and the Director, Office of Management and Budget. In 
addition, this report will be available at no charge on our Web site at 
[hyperlink, http://www.gao.gov]. If you or your staff have any 
questions about this report, please contact me at (202) 512-4523 or 
leporeb@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. GAO staff who made key contributions to this report are listed 
in enclosure III. 

Signed by: 

Brian J. Lepore, Director: 
Defense Capabilities and Management: 

List of Committees: 

The Honorable Carl Levin: 
Chairman: 
The Honorable John McCain: 
Ranking Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable Daniel K. Inouye: 
Chairman: 
The Honorable Thad Cochran: 
Ranking Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
United States Senate: 

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

The Honorable John P. Murtha: 
Chairman: 
The Honorable C. W. Bill Young: 
Ranking Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
House of Representatives: 

[End of section] 

Enclosure I: 

Section 366 of the Bob Stump National Defense: 

Authorization Act for Fiscal Year 2003: 

SEC. 366. Training Range Sustainment Plan, Global Status of Resources 
and Training System, and Training Range Inventory. 

(a) Plan Required--(1) The Secretary of Defense shall 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 caused by limitations on the use of 
military lands, marine areas, and airspace that are available in the 
United States and overseas for training of the Armed Forces. 

(2) As part of the preparation of the plan, the Secretary of Defense 
shall conduct the following: 

(A) An assessment of current and future training range requirements of 
the Armed Forces. 

(B) An evaluation of the adequacy of current Department of Defense 
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. 

(3) The plan shall include the following: 

(A) Proposals to enhance training range capabilities and address any 
shortfalls in current Department of Defense resources identified 
pursuant to the assessment and evaluation conducted under paragraph 
(2). 

(B) Goals and milestones for tracking planned actions and measuring 
progress. 

(C) Projected funding requirements for implementing planned actions. 

(D) Designation of an office in the Office of the Secretary of Defense 
and in each of the military departments that will have lead 
responsibility for overseeing implementation of the plan. 

(4) At the same time as the President submits to Congress the budget 
for fiscal year 2004, the Secretary of Defense shall submit to Congress 
a report describing the progress made in implementing this subsection, 
including--: 

(A) the plan developed under paragraph (1); 

(B) the results of the assessment and evaluation conducted under 
paragraph (2); and: 

(C) any recommendations that the Secretary may have for legislative or 
regulatory changes to address training constraints identified pursuant 
to this section. 

(5) At the same time as the President submits to Congress the budget 
for each of fiscal years 2005 through 2008,[Footnote 14] the Secretary 
shall submit to Congress a report describing the progress made in 
implementing the plan and any additional actions taken, or to be taken, 
to address training constraints caused by limitations on the use of 
military lands, marine areas, and airspace. 

(b) Readiness Reporting Improvement--Not later than June 30, 2003, the 
Secretary of Defense, using existing measures within the authority of 
the Secretary, shall submit to Congress a report on the plans of the 
Department of Defense to improve the Global Status of Resources and 
Training System to reflect the readiness impact that training 
constraints caused by limitations on the use of military lands, marine 
areas, and airspace have on specific units of the Armed Forces. 

(c) Training Range Inventory--(1) The Secretary of Defense shall 
develop and maintain a training range inventory for each of the Armed 
Forces--: 

(A) to identify all available operational training ranges; 

(B) to identify all training capacities and capabilities available at 
each training range; and: 

(C) to identify training constraints caused by limitations on the use 
of military lands, marine areas, and airspace at each training range. 

(2) The Secretary of Defense shall submit an initial inventory to 
Congress at the same time as the President submits the budget for 
fiscal year 2004 and shall submit an updated inventory to Congress at 
the same time as the President submits the budget for fiscal years 2005 
through 2008.[Footnote 15] 

(d) GAO Evaluation--The Secretary of Defense shall transmit copies of 
each report required by subsections (a) and (b) to the Comptroller 
General. Within 60 days after receiving a report, the Comptroller 
General shall submit to Congress an evaluation of the report.[Footnote 
16] 

[End of section] 

Enclosure II: Comments from the Department of Defense: 

Office Of The Under Secretary Of Defense: 
4000 Defense Pentagon: 
Washington, DC 20301-4000: 

Personnel And Readiness: 

December 9, 2008: 

Mr. Brian J. Lepore: 
Director, Defense Capabilities and Management: 
U.S. Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Lepore: 

This is the Department of Defense (DoD) response to the General 
Accounting Office Draft Report GAO-09-128R, "Improvement Continues in 
DOD's Reporting on Sustainable Ranges, but Opportunities Exist to 
Improve its Ranges Assessments and Comprehensive Plan," November 10, 
2008. 

Thank you for the opportunity to comment on this draft. The DoD 
appreciates the GAO's assessment of the encroachment challenges facing 
our nation's military ranges and operating areas and the Department's 
comprehensive plan to sustain these critical assets. As the GAO 
observes, we believe that annual reporting to Congress continues to 
improve over time as the Department's sustainable ranges effort 
matures. 

DoD responses on the specific GAO recommendations are enclosed. We look 
forward to continuing to work with Congress and the GAO to maintain a 
ready and sustainable military testing and training infrastructure. 

Sincerely,

Signed by: 

Samuel D. Kleinman: 
Deputy Under Secretary of Defense: 

Enclosure: 
As stated: 

GAO-09-128R Draft Report: 

"Improvement Continues in DOD's Reporting on Sustainable Ranges, but 
Opportunities Exist to Improve its Ranges Assessments and Comprehensive 
Plan": 

Department Of Defense Comments To Recommendations: 

Recommendation 1: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness, in 
consultation with the Secretaries of the military departments, to 
include each service's rational for excluding the specific training 
ranges not included in its assessment of the adequacy of current 
resources to meet requirements in future sustainable ranges reports. 

DOD Response: Concur, future reports will incorporate rationale as to 
why some ranges may be included in the inventory, yet not have a 
capability or encroachment assessment performed. 

Recommendation 2: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness, in 
consultation with the Secretaries of the military departments, to 
include the Marine Corps' individual combat training elements as the 
mission areas in the range capability and encroachment assessment in 
future sustainable ranges reports. 

DOD Response: Non-concur, the Marine Corps' approach to assessing range 
capability and encroachment is consistent with all the source documents 
and methodologies by which the Marine Corps manages and resources its 
ranges. The capabilities assessments are designed to measure the 
ranges' ability to support the levels of training on the Marine Corps 
training continuum. Those levels of training are all based on 
established training responsibilities embodied in Marine Corps Tasks 
(MCTs), which are derived from the Universal Joint Task List and Joint 
Tactical Tasks. In future reports, they will provide greater 
explanatory comments on both capabilities and encroachment impacts, but 
the framework established in their Required Range Capabilities Document 
(RCD), range complex management plans, and range management orders all 
support the methodology they have employed in this report. 

Recommendation 3: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness, in 
consultation with the Secretaries of the military departments, to 
include an update on the actions taken by the Air Force to address 
DoD's modernization and investment goals for range sustainment in 
future sustainable ranges reports. 

DOD Response: Concur, updates of actions taken by each Service over the 
preceding year towards completion of goals and milestones will be 
addressed. 

Recommendation 4: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness, in 
consultation with the Secretaries of the military departments, to 
include a detailed description of all funding data included in each 
funding category, for each of the military services in future 
sustainable ranges reports. 

DOD Response: Concur, OSD will work with the Services to provide a more 
detailed description of what areas are financed within each of the 
funding categories.

[End of section] 

Enclosure III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Brian Lepore, (202) 512-4523 or leporeb@gao.gov: 

Acknowledgments: 

In addition to the person named above, Harold Reich, Assistant 
Director; Jason Jackson; Joanne Landesman; Katherine Lenane; and 
Jacqueline McColl made key contributions to this report. 

[End of section] 

Related GAO Products: 

Military Training: Compliance with Environmental Laws Affects Some 
Training Activities, but DOD Has Not Made a Sound Business Case for 
Additional Environmental Exemptions. GAO-08-407. Washington, D.C.: 
March 7, 2008. 

Improvement Continue in DOD's Reporting on Sustainable Ranges, but 
Opportunities Exists to Improve Its Range Assessments and Comprehensive 
Plan. GAO-08-10R. Washington, D.C.: October 11, 2007. 

Improvement Continues in DOD's Reporting on Sustainable Ranges, but 
Additional Time Is Needed to Fully Implement Key Initiatives. GAO-06-
725R. Washington, D.C.: June 20, 2006. 

Military Training: Funding Requests for Joint Urban Operations Training 
and Facilities Should Be Based on Sound Strategy and Requirements. GAO-
06-193. Washington, D.C.: December 8, 2005. 

Some Improvements Have Been Made in DOD's Annual Training Range 
Reporting but It Still Fails to Fully Address Congressional 
Requirements. GAO-06-29R. Washington, D.C.: October 25, 2005. 

Military Training: Actions Needed to Enhance DOD's Program to Transform 
Joint Training. GAO-05-548. Washington, D.C.: June 21, 2005. 

Military Training: Better Planning and Funding Priority Needed to 
Improve Conditions of Military Training Ranges. GAO-05-534. Washington, 
D.C.: June 10, 2005. 

Military Training: DOD Report on Training Ranges Does Not Fully Address 
Congressional Reporting Requirements. GAO-04-608. Washington, D.C.: 
June 4, 2004. 

Military Training: Implementation Strategy Needed to Increase 
Interagency Management for Endangered Species Affecting Training 
Ranges. GAO-03-976. Washington, D.C.: September 29, 2003. 

Military Training: DOD Approach to Managing Encroachment on Training 
Ranges Still Evolving. GAO-03-621T. Washington, D.C.: April 2, 2003. 

Military Training: DOD Lacks a Comprehensive Plan to Manage 
Encroachment on Training Ranges. GAO-02-614. Washington, D.C.: June 11, 
2002. 

Military Training: DOD Needs a Comprehensive Plan to Manage 
Encroachment on Training Ranges. GAO-02-727T. Washington, D.C.: May 16, 
2002. 

Military Training: Limitations Exist Overseas but Are Not Reflected in 
Readiness Reporting. GAO-02-525. Washington, D.C.: April 30, 2002. 

[End of section] 

Footnotes:  

[1] Pub. L. No. 107-314 (2002). 

[2] Section 366 originally required reports for fiscal years 2005 
through 2008. However, this requirement was extended through 2013 by 
section 348 of the John Warner National Defense Authorization Act for 
Fiscal Year 2007, Pub. L. No. 109-364 (2006). 

[3] Id. 

[4] Department of Defense, Office of the Under Secretary of Defense for 
Personnel and Readiness, Report to Congress on Sustainable Ranges 
(Washington, D.C.: September 2008). This report addresses the progress 
DOD has made in implementing its sustainable ranges plan and any 
additional action taken, or to be taken, to address training 
constraints caused by limitations, and contains an updated training 
range inventory as well as the elements of section 366 that were 
required to be in DOD's original fiscal year 2004 report and inventory. 

[5] GAO, Improvement Continues in DOD's Reporting on Sustainable 
Ranges, but Opportunities Exist to Improve Its Range Assessments and 
Comprehensive Plan, [hyperlink, http://www.gao.gov/products/GAO-08-10R] 
(Washington, D.C.: Oct. 11, 2007). 

[6] GAO was not specifically required by section 366 to review DOD's 
training range inventory. However, because DOD submits this inventory 
with its sustainable ranges report, we elected to review DOD's training 
inventory, as we have done in past years. 

[7] [hyperlink, http://www.gao.gov/products/GAO-08-10R]. 

[8] DOD describes virtual training as training involving real people 
operating simulated systems. Constructive training is training 
involving the use of simulated personnel operating simulated equipment 
in a computer-game-style training environment. 

[9] [hyperlink, http://www.gao.gov/products/GAO-08-10R]. 

[10] H.R. Rep. No. 110-652, at 331 (2008). 

[11] In it s 2007 report, DOD stated that there was an existing process 
by which DOD must submit all requests for legislative language that 
includes, among other things, obtaining approval from DOD's Office of 
Legislative Affairs and Office of Management and Budget, and that the 
deadline for this process is the same as the deadline for the 
sustainable ranges report. 

[12] GAO, Military Training: Compliance with Environmental Laws Affects 
Some Training Activities, but DOD Has Not Made a Sound Business Case 
for Additional Environmental Exemptions, [hyperlink, 
http://www.gao.gov/products/GAO-08-407] (Washington, D.C.: Mar. 7, 
2008). 

[13] Marine Air Ground Task Force expeditionary-level training includes 
unit-level and brigade-level training. 

[14] This requirement was extended through 2013 by section 348 of the 
John Warner National Defense Authorization Act for Fiscal Year 2007. 

[15] Id. 

[16] This requirement was extended to 90 days by section 348 of the 
John Warner National Defense Authorization Act for Fiscal Year 2007. 

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