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Report to Congressional Committees:

United States General Accounting Office:

GAO:

June 2003:

Environmental Compliance:

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

GAO-03-639:

GAO Highlights:

Highlights of GAO-03-639, a report to the Senate and House Committees 
on Armed Services 

Why GAO Did This Study:

The Department of Defense (DOD) and its military services are 
responsible for complying with a broad range of environmental laws and 
other requirements that apply to the lands they manage, including more 
than 425 major military installations covering about 25 million acres 
across the United States. Through its environmental quality program, 
DOD spends about $2 billion per year to comply with these 
requirements. Although the services have made significant improvements 
in environmental management in recent years, DOD has not reached full 
environmental compliance. In response to the Senate Armed Services 
Committeeís report on the National Defense Authorization Act for 
Fiscal Year 2002, we assessed how DOD and the services identify, 
prioritize, and fund their environmental quality activities to 
determine whether the most important and appropriate activities are 
funded.

What GAO Found:

DODís and the servicesí policies and processes for the environmental 
quality program do not always ensure that program funds are targeted 
to the most important and appropriate environmental activities. 
Instead, GAO found that some installations have funded low-priority or 
other activities that were ineligible under their environmental 
quality funding policies, at the same time that higher-priority 
activities were not funded. For example, at certain large 
installations that GAO visited, low-priority activities, such as noise 
monitoring, or ineligible activities, such as pest management, 
landscaping, and roof replacement, were funded while high-priority 
activities to prevent soil erosion were not.

At the root of the problem is DODís 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. DODís policy 
requires that all high-priority activities be funded, but gives the 
services broad discretion in how this policy is put into place. As a 
result, GAO found (1) inconsistencies across and within the services 
about which activities are eligible for environmental quality program 
funding and (2) the funding of some activities through the program 
that more closely relate to military operations or base maintenance. 
For example, some services use program funds for oil and hazardous 
material spill response plans, equipment, and cleanup costs, while 
other services require the organization responsible for the spill to 
pay for the cleanup portion of those costs. Similarly, service 
policies can differ regarding responsibility for funding maintenance 
of structures such as water and sewer treatment facilities and 
historic buildings.

Without a consistently implemented approach, there is no assurance 
that DODís requirement to fund all high-priority activities is being 
met. Instead, some high-priority projects are being deferred. 
Generally, these deferrals involve projects that, although required by 
law, do not have to be completed by specific dates (e.g., surveys of 
properties required by historic preservation law). Deferring such 
activities, however, can lead to larger and more costly problems 
later. Moreover, to fund unbudgeted emergency environmental 
activities, the installations may have to defer other high-priority 
environmental program activities, obtain funds from other sources at 
the installation such as maintenance activities, or obtain funds from 
higher command levels. Some services have recently indicated 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.

What GAO Recommends:

DOD should establish a more specific policy on which activities are 
eligible for funding through the environmental quality program and how 
such activities should be prioritized and funded. The military 
services should revise their policies and processes to conform to the 
revised DOD policy. DOD did not provide comments on these 
recommendations as of the issuance date of this report.

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:

Results in Brief:

Background:

DOD's and the Services' Policies and Processes Do Not Always Ensure 
That the Most Important and Appropriate Environmental 
Quality Activities Are Funded:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Scope and Methodology:

Appendix II: GAO Contacts and Staff Acknowledgments:

Figure:

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

Abbreviations:

DOD: Department of Defense GAOGeneral Accounting Office 

NEPA: National Environmental Policy Act:

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 
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.[Footnote 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.

Results in Brief:

The Department of Defense's and the military services' policies and 
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. 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.

Background:

DOD's operations at military installations and other defense sites in 
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.[Footnote 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.[Footnote 3] DOD has developed and 
implemented policies for activities in each major program 
category.[Footnote 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.):

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

[See PDF for image]

[A] Compliance includes personnel costs for the entire environmental 
quality program.

[End of figure]

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

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.[Footnote 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.

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,[Footnote 
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 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.[Footnote 10]

DOD's and the Services' Policies and Processes Do Not Always Ensure 
That the Most Important and Appropriate Environmental 
Quality Activities Are Funded:

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

The Services' Varying Interpretations of DOD's Broad Policy Have 
Resulted in Inconsistent Eligibility Criteria and Funding of Activities 
More Closely Related to Military Operations or Maintenance:

DOD's policy provides the services with a broad charge to comply with 
applicable environmental requirements, such as statutes and 
regulations, but leaves to the services most decisions about which 
activities are appropriate for funding through their environmental 
quality programs. We found that the services' varying interpretations 
of this policy have resulted in different eligibility requirements and 
in funding of activities through the environmental quality program that 
may have been more closely related to military operations or 
maintenance.

The Services' Policies Differ in Which Activities Are Eligible for 
Their Environmental Quality Programs:

Although the services have developed policies intended, in part, to 
clarify which activities can be funded through the environmental 
quality program, implementation of these policies has sometimes led to 
inconsistencies 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 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.

Some Activities Funded Through the Services' Environmental Quality 
Programs Are More Closely Related to Military Operations or 
Maintenance:

The services' broad interpretations of eligibility for their 
environmental quality programs have allowed installations to use the 
environmental quality program to fund activities that may have been 
more closely 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 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 these needs must compete with other programs, such as force 
readiness and the day-to-day costs of operating an 
installation.[Footnote 11]

The Services Do Not Always Ensure That Funding Is Targeted to 
the Highest Priority Environmental Activities, and in Some Cases, Have 
Funded Activities That Are Ineligible Under Their Policies:

Certain low-priority activities were funded through the environmental 
quality program at two Army installations we visited, even though some 
high priorities, considered "must fund" activities by DOD and Army 
policy, were not funded. Moreover, at two installations we visited, we 
found that the environmental quality programs had funded some 
activities that were ineligible to receive funding under their 
policies.

For two Army installations we visited, the major command did not 
provide environmental quality program funding for all "must funds," 
Class 0 and I activities, yet funded some lower-priority, Class III 
activities.[Footnote 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:

* 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 Management Agency[Footnote 13] 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.[Footnote 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.

* 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 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.[Footnote 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.

The Services' Environmental Quality Programs Cannot Ensure That DOD's 
Requirement to Fund All High-Priority Needs Is Met:

Although DOD's and the services' policies call for funding of all 
high-priority environmental quality program activities, the services 
have not always been able to fund all such activities through their 
environmental quality program. While program managers for most of 
the installations we visited said that the environmental quality 
programs were generally able to fund high-priority environmental 
activities during 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 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 to avoid other such occurrences, to assess the condition of 
150 miles of the main sewer line.[Footnote 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.

Conclusions:

DOD has established broad policy for its environmental compliance 
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.

Recommendations for Executive Action:

To ensure that DOD can better target environmental quality program 
funds to the most important and most appropriate activities, we 
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.

Agency Comments and Our Evaluation:

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.

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.

[End of section]

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

Signed by Anu K. Mittal:

[End of section]

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 GAO Visited:

U.S. Air Force 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.):

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.

[End of section]

Appendix II: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

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

Acknowledgments:

In addition to the individuals named above, Kelly Blado, Christine 
Frye, 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.

FOOTNOTES

[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.

[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.

[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. 

[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.

[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.

[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.

[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.

[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.

[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.

[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.

[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.

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