This is the accessible text file for GAO report number GAO-02-614 
entitled 'Military Training: DOD Lacks a Comprehensive Plan to Manage 
Encroachment on Training Ranges' which was released on June 11, 2002. 

This text file was formatted by the U.S. General Accounting Office 
(GAO) to be accessible to users with visual impairments, as part of a 
longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the 
printed version. The portable document format (PDF) file is an exact 
electronic replica of the printed version. We welcome your feedback. 
Please E-mail your comments regarding the contents or accessibility 
features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

United States General Accounting Office: 
GAO: 

Report to Congressional Requesters: 

June 2002: 

Military Training: 

DOD Lacks a Comprehensive Plan to Manage Encroachment on Training 
Ranges: 

GA0-02-614: 

Contents: 

Letter: 

Results in Brief: 

Background: 

Encroachment Has Diminished Service Training Range Capabilities: 

Impact of Encroachment on Readiness and Training Costs Is Not Well 
Reflected in DOD's Reported Data: 

Comprehensive Plan for Addressing Encroachment Not Finalized, but Some 
Action Has Been Taken: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Membership of DOD Encroachment-Related Groups: 

Appendix III: DOD's Draft Sustainable Ranges Action Plans for 
Addressing Encroachment Issues: 
Endangered Species Act Action Plan: 
Unexploded Ordnance and Munitions Constituents Action Plan: 
Radio Frequency Spectrum Action Plan: 
Maritime Sustainability Action Plan: 
National Airspace Redesign Action Plan: 
Air Quality Action Plan: 
Airborne Noise Action Plan: 
Urban Growth Action Plan: 

Appendix IV: Comments from the Department of Defense: 

Tables: 

Table 1: Members of the Senior Readiness Oversight Council: 

Table 2: Members of the Defense Test and Training Steering Group: 

Table 3: Members of the Integrated Product Team: 

Figure: 

Figure 1: DOD Environmental Conservation Program Obligations, Fiscal 
Years 1996-2001: 

Abbreviation: 

DOD: Department of Defense: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

June 11, 2002: 

The Honorable Dan Burton: 
Chairman, Committee on Government Reform: 
House of Representatives: 

The Honorable Christopher Shays: 
Chairman, Subcommittee on National Security, Veterans Affairs, and 
International Relations: 
Committee on Government Reform: 
House of Representatives: 

Senior Department of Defense and military service officials have 
testified before Congress that they face increasing difficulties in 
carrying out realistic training at military installations. According 
to the officials, there are eight so-called "encroachment"[Footnote 1] 
issues that affect or have the potential to affect military training 
and readiness. The eight encroachment issues are: endangered species 
habitat on military installations, unexploded ordnance and munitions 
constituents,[Footnote 2] competition for radio frequency spectrum, 
protected marine resources, competition for airspace, air pollution, 
noise pollution, and urban growth around military installations.
Whenever possible, the services work around these issues by modifying 
the timing, tempo, and location of training, as well as the equipment 
used. However, defense officials have expressed concern that these 
workarounds are becoming increasingly difficult and costly and that 
they compromise the realism essential to effective training. 

At your request, we examined (1) the impact that encroachment has had, 
or is likely to have, on the services' training range capabilities; 
[Footnote 3] (2) the effect training range losses have on the 
services' readiness and costs; and (3) the department's progress in 
formulating a comprehensive plan for addressing encroachment issues. 

This report focuses exclusively on military training ranges in the 
United States and is our second assessment of encroachment issues and 
their impact on military training ranges. The first assessment 
reviewed the effects of encroachment on training ranges outside the 
continental United States and was performed at the request of the 
Chairman, Subcommittee on Readiness and Management Support, Committee 
on Armed Services, U.S. Senate.[Footnote 4] We are also reviewing for 
your committee how the U.S. Fish and Wildlife Service budgets and 
allocates its endangered and threatened species (referred to as 
endangered from here on in the report) program funds and what program 
activities were emphasized in fiscal year 2001. 

In conducting our work, we toured four installations and visited two 
major commands.[Footnote 5] We discussed encroachment with officials 
at each location to hear and observe, first hand, how encroachment had 
affected their training range capabilities. We also discussed the 
impact of encroachment on readiness and costs with these officials, 
and then reviewed key Department of Defense readiness reports, along 
with cost data from the department's Environmental Quality Program, to 
further understand how encroachment has affected readiness and costs. 
Finally, we met with service and Department of Defense officials 
responsible for developing plans for addressing encroachment issues 
and discussed with these officials their progress in formulating a 
comprehensive plan for addressing encroachment issues. A more thorough 
description of our scope and methodology is in appendix I. 

We summarized the findings of this review in testimony before the 
Committee on Government Reform on May 16, 2002.[Footnote 6] 

Results in Brief: 

Over time, the military services report they have increasingly lost 
training range capabilities because of encroachment. Each of the four 
installations and two major commands we visited reported having lost 
some capabilities in terms of the time training ranges were available 
or the types of training that could be conducted. For example, Marine 
Corps Base Camp Pendleton, California, has training limitations 
related to the use of off-road vehicles and the digging of defensive 
positions because of the presence of endangered species on its ranges. 
In addition, Eglin Air Force Base's major target control system 
suffers from frequency interference from nearby commercial operators, 
which officials indicate presents a safety issue because the problem 
can affect data links to weapons. Such constraints limit units' 
ability to train as they would expect to fight or require workarounds-—
or adjustments to training events—-that can create bad habits and 
affect performance in combat or, in some instances, prevent training 
from being accomplished. Service officials believe that population 
growth around military installations is responsible for much of their 
past and present encroachment problems, and that higher-than-average 
population growth around their installations makes further 
encroachment losses likely. 

Despite the loss of some capabilities, service readiness data do not 
indicate the extent to which encroachment has significantly affected 
reported training readiness. While encroachment workarounds may affect 
costs, the services have not documented the overall impact of 
encroachment on training costs. Training readiness, as reported in 
official readiness reports, remains high for most units. Our analysis 
of readiness reports from active duty units in fiscal year 2001 showed 
that very few units reported being unable to achieve combat-ready 
status[Footnote 7] due to inadequate training areas. However, 
improvements can and should be made to the department's readiness 
reporting to address training degradation due to encroachment and 
other factors. At the same time, the services face difficulties in 
fully assessing the impact of training ranges on readiness because 
they have not fully defined their training range requirements and lack 
information on the training resources available to support those 
requirements. Service officials also report that encroachment 
increases training costs, and can provide examples of such costs; 
however, those costs have not been documented in a comprehensive 
manner. Funding associated with the Department of Defense's 
environmental conservation program, which includes activities such as 
preservation programs and endangered species management, shows only 
modest gains over the past 6 years, increasing from 1996 to
1998 but then dropping from 1999 to 2001 among all components except 
for the Army. However, Department of Defense officials acknowledge 
that budget constraints and other priorities have resulted in a 
backlog of some activities in this area. 

Department of Defense officials recognize the need for a comprehensive 
plan of administrative actions and legislative proposals to address 
encroachment issues but have not yet finalized a plan for doing so. 
The services first presented their encroachment problems to the Senior
Readiness Oversight Council[Footnote 8] in June 2000, but as of April 
2002 the department had not yet finalized a comprehensive plan for 
addressing them due to the transition to the new administration, the 
events of September 2001, and continuing internal deliberations over 
how best to address encroachment. Although the department has prepared 
draft action plans that deal with each encroachment issue separately, 
the plans are not finalized, and information is not yet available on 
specific actions planned, time frames for completing them, clear 
assignment of responsibilities, and funding needed—-the elements of a 
comprehensive plan. The department has also drafted, but has not 
finalized, an implementing directive meant to serve as the foundation 
for addressing encroachment issues and one directive each on noise 
abatement and outreach efforts. In December 2001, the department 
directed an Integrated Product Team[Footnote 9] to act as the 
coordinating body for all encroachment issues, develop a comprehensive 
set of legislative and regulatory proposals by January 2002, and 
formulate and manage outreach efforts. A package of legislative 
proposals, described as clarifications in a department legislative 
summary, was submitted to the Congress in late April 2002 seeking to 
modify several specific statutory requirements, which Defense 
Department officials believe will preserve its use of training ranges 
while protecting the environment. Although time permitted only a 
cursory consideration of the proposals, they appear to be another step 
by the department toward developing a comprehensive approach to 
managing encroachment affecting military training ranges. Progress has 
also been made in a number of areas by other departmental 
organizations. For example, the Operational and Environmental Steering
Committee for Munitions has been addressing explosive safety and 
environmental concerns, and the department recently approved a 
munitions action plan prepared by the committee. 

While the Congress considers the department's legislative proposals, 
we recommend executive action that requires the Department of Defense 
to finalize a comprehensive plan for managing encroachment issues, 
develop the ability to report critical encroachment-related training 
problems, and develop and maintain inventories of its training 
infrastructure and quantify its training requirements. In comments on 
a draft of this report, the department substantially concurred with 
the contents of the report and our recommendations. The department 
also provided technical clarifications, which we incorporated as 
appropriate. 

Background: 

The Department of Defense's (DOD) ranges and training areas are used 
primarily to test weapon systems and train military forces; some 
facilities are used for both testing and training purposes, while 
others are limited to one use or the other. This report focuses 
primarily on facilities used for training purposes. DOD needs ranges 
and training areas for all levels of training. Required facilities 
include air ranges for air-to-air, air-to-ground, drop zone, and 
electronic combat training; live-fire ranges for artillery, armor, 
small arms, and munitions training; ground maneuver ranges to conduct 
realistic force-on-force and live-fire training at various unit 
levels; and sea ranges to conduct ship maneuvers for training. 

According to a DOD official, today's concerns about encroachment 
reflect the cumulative result of a slow but steady increase in 
problems affecting the use of their facilities. Historically, specific 
encroachment problems have been addressed at individual ranges, most 
often on an ad hoc basis. Recently, DOD officials have reported 
increased limits on and problems with access to and the use of ranges. 
They believe that the gradual accumulation of these limits and 
problems increasingly threatens training readiness. DOD officials have 
identified eight encroachment issues of concern. These issues are: 

* The designation of critical habitat under the Endangered Species Act 
of 1973. DOD believes that critical habitat designations reduce its 
flexibility to use designated lands for training and put its military 
mission in jeopardy because, under the act, an agency is required to 
ensure that its actions do not destroy or adversely modify designated 
habitat of any endangered species.[Footnote 10] Currently over 300 
federally listed endangered plant and animal species are found on 
military installations, and more are anticipated. DOD officials 
maintain that their successful efforts in managing training ranges 
have resulted in the training ranges becoming havens for at-risk 
species. According to these officials, some of the finest remaining 
examples of rare wildlife habitats are now on military lands. 

* The application of environmental statutes to military munitions, 
including unexploded ordnance and munitions constituents. DOD believes 
that the Environmental Protection Agency could apply environmental 
statutes to the intended use of military munitions, shutting down or 
disrupting military training on active ranges. For example, DOD 
officials note that in 1997 executive action was taken under the Safe 
Drinking Water Act that essentially terminated live-fire training on 
the Massachusetts Military Reservation because of unexploded ordnance 
and munitions constituents leaching into drinking water in the 
surrounding area According to DOD officials, uncertainties about 
future application and enforcement of these statutes limit the 
department's ability to plan, program, and budget for compliance 
requirements. 

* Competition for frequency spectrum. The growth of consumer
communications devices has resulted in pressure from the 
telecommunications industry for the reallocation of some radio 
frequency spectrum from federal to non-federal control. According to 
DOD officials, since 1992 DOD has lost approximately 27 percent of the 
total frequency spectrum allocated for aircraft telemetry. DOD 
believes the possible reallocation of spectrum, coupled with an 
increase in DOD activities that use it, raises concerns about the 
availability of adequate spectrum to support operations and training. 
For example, we previously reported that DOD is concerned that an 
additional reallocation of spectrum in the 1755 to 1850 megahertz band 
could adversely affect space systems, tactical communications, and 
combat training.[Footnote 11] 

* The requirement to balance ocean resource protection mandates with 
training needs. DOD officials believe DOD's ability to train can 
sometimes be limited by marine regulatory laws that require 
consultation with regulators when a proposed action may affect a 
protected resource. Defense officials have expressed concern that the 
process empowers regulators to impose potentially stringent measures 
to protect the environment from the effects of proposed DOD actions, 
which can affect DOD's ability to conduct operations and training in 
the marine environment. 

* Competition for airspace. DOD officials have expressed concerns that 
increased airspace congestion, caused by airline industry demands and 
the military's need for effective testing and training, limits the 
ability of pilots to train as they will fight. 

*The application of Clean Air Act regulations specifying requirements 
for air quality. DOD officials believe these regulations can sometimes 
limit DOD's ability to base equipment and for units to train as they 
will fight, particularly with smoke, because the act requires controls 
over emissions commonly generated on defense installations. According 
to DOD officials, opacity and conformity requirements are the most 
onerous for the department. DOD officials told us opacity measures the 
visibility of air emissions and can restrict or prohibit smoke 
training, mounted maneuvers, and intentional burns to manage 
vegetation cover. The conformity rules require federal agencies to 
analyze emissions from proposed projects or activities at federal 
installations. DOD officials believe that any new or significant 
change in range operations located in non-attainment areas requires an 
emissions analysis. If emissions exceed specified thresholds, the 
increase must be offset by reductions elsewhere. 

* The application of environmental laws and regulations mandating 
noise abatement. DOD officials state that weapon systems are exempt 
from the Noise Control Act of 1972, but that the department must still 
assess the impact of noise under the National Environmental Policy Act 
when considering the environmental impact of its activities. As 
community developments have expanded closer to military installations, 
concerns over noise from military operations have increased. Defense 
officials report that pressures from groups at the local, regional, 
and state levels can serve to restrict or reduce military training. 

* Unplanned or incompatible commercial or residential development (urban
growth) around training ranges and installations. DOD officials believe
encroachment of incompatible civilian activities compromises the 
effectiveness of their training activities. Incompatible land uses can 
compromise the health, safety, and welfare of both the military and 
civilian sectors. DOD officials report that local residents have filed 
lawsuits because they believe that military operations have impacted 
their property's value or restricted its use. 

To the extent that encroachment adversely affects training readiness, 
opportunities exist for the problems to be reported in departmental 
and military service readiness reports. The Global Status of Resources 
and Training System is the primary means for units to report readiness 
against designed operational goals. The system's database indicates, 
at selected points in time, the extent to which units possess the 
required resources and training to undertake their wartime missions. 

In 1994, to improve its readiness assessment capabilities, DOD 
established two forums—-the Senior Readiness Oversight Council and the 
Joint Monthly Readiness Review-—to evaluate readiness from a joint and 
strategic perspective. DOD is also required under 10 U.S.C. 482 to 
prepare a quarterly readiness report to Congress that describes 
readiness problems. DOD bases its quarterly report on briefings to the 
Senior Readiness Oversight Council. The Senior Readiness Oversight 
Council is assisted by the Defense Test and Training Steering Group, 
[Footnote 12] which advises the council on training range issues. In 
June 2000, the council directed the steering group to investigate 
encroachment and develop and recommend a comprehensive plan of action. 

The Secretaries of the military departments are responsible for 
training personnel and for maintaining their respective training 
ranges and facilities. Within the Office of the Secretary of Defense, 
the Under Secretary of Defense for Personnel and Readiness develops 
policies, plans, and programs to ensure the readiness of the force and 
provides oversight on training. The Deputy Under Secretary of Defense 
for Installations and Environment develops policies, plans, and 
programs for DOD's environmental, safety, and occupational health 
programs, including compliance with environmental laws, conservation 
of natural and cultural resources, pollution prevention, and explosive 
safety. The Director, Operational Test and Evaluation, has oversight 
responsibility for all major test ranges, manages all joint test and 
evaluation range investments (including spectrum enhancement), and is 
also responsible for ensuring that congressionally mandated live-fire 
test and evaluation is conducted on fully integrated weapon systems. 

Encroachment Has Diminished Service Training Range Capabilities: 

Over time, the impact of encroachment on training ranges has gradually 
increased. While the effect varies by service and individual 
installation, in general encroachment has limited the extent to which 
training ranges are available or the types of training that can be 
conducted. This limits units' ability to train as they would expect to 
fight and/or requires units to work around the problem. However, as 
discussed in the next section, the overall impact on readiness and 
training costs is not well documented. 

Many encroachment issues result from or are exacerbated by population 
growth and urbanization. DOD is particularly affected because urban 
growth near 80 percent of its installations exceeds the national 
average. According to DOD officials, new inhabitants near 
installations often view military activities as an infringement of 
their rights, and some groups have organized in an effort to reduce 
range operations such as aircraft and munitions training. These 
problems are expected to increase over time. 

Examples of How Encroachment Is Affecting Training Capabilities: 

We visited four installations and two major commands and found that 
each has lost some capability in terms of (1) the time training ranges 
were available or (2) the types of activities that could be conducted. 
We found that the types of encroachment and their impact varied 
between installations and service organizations. 

Marine Corps Base Camp Pendleton, California: 

Camp Pendleton officials report encroachment problems related to 
endangered species and their habitat, urbanization, competition for 
air space, and noise restrictions. As of February 1, 2001, the Fish 
and Wildlife Service had designated about 10 percent of the 
installation as critical habitat for endangered species, which limits 
the use of off-road vehicles and the digging of fighting positions. 
Restrictions caused by the presence of endangered species, 
recreational areas, and topographic and access limitations have 
reduced the amount of beach available for amphibious assaults and 
prevented training to doctrinal standards. Airspace restrictions have 
limited the number of days that weapon systems can be employed, and 
noise restrictions limit night helicopter operations. 

Camp Pendleton officials are trying to limit future constraints 
imposed by these encroachment issues through an outreach program that 
maintains open communications with local, state, and national 
authorities and regulators and local communities to educate them on 
the military's mission and operations and incorporate their concerns. 
Also, training events, such as setting up fuel storage areas, are 
sometimes relocated to other areas of the base when feasible; other 
exercises, such as bridging operations, have been moved to Marine 
Corps Air Station Yuma, Arizona. 

Fort Lewis and the Yakima Training Center, Washington: 

Fort Lewis and Yakima Training Center[Footnote 13] officials report 
encroachment problems related to noise, air quality, endangered 
species and their habitat, urbanization, frequency spectrum, and 
munitions constituents. Due to community noise complaints, Fort Lewis 
voluntarily ceased certain demolitions training. Air quality 
regulations have restricted the Army's ability to operate new smoke 
generators at Fort Lewis. Endangered species habitat considerations 
have limited off-road vehicle training at Fort Lewis and Yakima and 
river-crossing operations at Yakima. Maneuvers are restricted in 
prairie areas at Fort Lewis to preserve an endangered plant and at 
Yakima to protect western sage grouse habitat. This reduces the types 
of training that can be conducted by the Interim Brigade Combat Teams 
[Footnote 14] based at Fort Lewis. Also, communications equipment used 
by the teams overlaps with commercial communications networks, 
creating periodic interference in communications. Finally, although 
Fort Lewis is situated over an aquifer, and munitions constituents 
have been found in the water, training has not yet been curtailed at 
this location. 

Fort Lewis officials are trying to mitigate their encroachment 
problems by (1) developing and maintaining scientifically defensible 
information that can demonstrate the effectiveness of current 
environmental management; (2) integrating range management with 
endangered species protection initiatives to preserve critical habitat 
and training ranges; and (3) conducting an outreach campaign to inform 
the public of the military's training needs and environmental 
successes. At Yakima, additional land was purchased recently to 
increase maneuver space and reduce the environmental impacts of 
maneuver training on current rangelands. Fort Lewis has moved some 
demolition training to Yakima. Smoke-generating units must ensure that 
no smoke can drift off base or obscure Mount Ranier during training. 
Negotiation between the military and local agencies has alleviated 
some frequency encroachment problems. 

Nellis Air Force Base and the Nevada Test and Training Range, Nevada: 

Nellis Air Force Base officials report encroachment problems stemming 
from urbanization and noise. Nellis officials report that because of 
the tremendous growth south of the base and safety concerns about 
overflying urban areas with live munitions, armed aircraft must take 
off and land from the north. This can cause mission delays for 
outbound traffic and mission cancellations due to wind effects. They 
also report that Nellis and the Nevada Test and Training Range 
[Footnote 15] together receive about 250 noise-related complaints 
annually that require adjustments to air operations. 

To mitigate encroachment issues, base officials are working to procure 
413 acres to avoid safety problems at its live ordnance departure area 
To limit the number of noise complaints, base officials said they 
restrict the use of certain runways, impose speed and altitude 
restrictions, and require straight-in approaches late at night and 
early in the morning. They are also strengthening their outreach 
program to keep the communities around the ranges informed about 
flight activities. 

Eglin Air Force Base, Florida: 

Eglin Air Force Base officials report encroachment problems involving 
endangered species habitat, noise restrictions, urban growth, and 
competition for radio frequency spectrum. Habitat for two endangered 
species is found on Eglin's ranges, impacting the availability of the 
ranges during certain times of the year. To help offset complaints 
about the noise from the explosive ordnance disposal school, smaller 
bombs may be detonated at certain times. Urban sprawl causes aircraft 
to change altitudes and direction to avoid commercial towers and noise-
sensitive areas. In addition, the base's major target control system 
suffers from frequency interference from nearby commercial operators, 
presenting a safety issue because the problem can affect data links to 
weapons. 

Eglin officials told us that they have maintained an aggressive 
encroachment program that has been successful at minimizing training 
impacts. For example, the base has established an encroachment 
committee to review requests for use of Eglin land. A very active 
outreach program meets regularly with local civic leaders to enhance 
community support for the base. The base has also developed a noise 
assessment prediction model that can alleviate noise complaints by 
determining the effects of weather on the noise created by military 
activities. This allows the base to modify its activities accordingly. 
To address frequency encroachment, Eglin is trying to narrow the 
bandwidth of its signals or move to another frequency. 

U.S. Atlantic Fleet, Naval Station Norfolk, Virginia: 

Atlantic Fleet officials report encroachment problems stemming from 
the presence of endangered species, particularly marine mammals, and 
airborne noise. Restrictions caused by the presence of marine mammals 
impact live-fire exercises at sea Also, no night live-fire training is 
allowed. Atlantic Fleet officials said that battle group staff must 
spend large amounts of time consulting with the National Marine 
Fisheries Service on endangered species mitigation. They noted that 
Naval Air Station Oceana, Virginia, is the target of frequent noise 
complaints as a result of aircraft training that includes low-altitude 
flights and practice carrier landings. 

The Atlantic Fleet has a variety of encroachment mitigation programs. 
The environmental section has developed an extensive report, based on 
geographic information that shows the ranges of all endangered species 
in the Virginia-Carolina Exercise Area This allows the fleet to plan 
its exercises to avoid harassing the species at risk. Prior to the 
beginning of live-fire exercises, Navy aircraft and ships must search 
the training area for 2 hours and then maintain a constant watch for 
marine mammals during the exercises. If an animal enters the training 
area, the exercise is suspended until it leaves. The Navy is 
evaluating construction and location of a Shallow Water Training Range 
along the east coast of the United States to provide anti-submarine 
warfare training in a littoral environment. Service officials note 
that progress has been delayed over an assessment of potential impact 
to marine mammals related to the definition of "harassment." To reduce 
noise complaints, the fleet is attempting to establish a training 
airstrip in a less populated area. The Navy has also established 
special procedures to deal with noise complaints and damage. 

Special Operations Command, MacDill Air Force Base, Florida: 

The Navy component of the Special Operations Command reports being 
most directly affected by encroachment from endangered species and 
urban development. Specifically, a variety of endangered species live 
on the Navy Special Warfare Command's training areas in California, 
particularly on Coronado and San Clemente Islands. Due to 
environmental restrictions, Navy Special Warfare units can no longer 
practice immediate action drills on Coronado beaches; they cannot use 
training areas in Coronado for combat swimmer training; and they 
cannot conduct live-fire and maneuver exercises on much of San 
Clemente Island during some seasons. 

In the past, the Special Operations Command has been able to mitigate 
deficiencies in local training areas by traveling to alternate 
training sites. However, recent limitations on the amount of time 
units can spend away from their home stations have required new 
solutions. The command is requesting funding for new environmental 
documentation in its budget to protect assets in California and is 
integrating its encroachment mitigation efforts with DOD and the 
services. 

Effects of Encroachment Are Expected to Grow: 

DOD and service officials report that many encroachment issues are 
related to urbanization around military installations. They noted that 
most, if not all, encroachment issues such as noise, airspace, 
endangered species habitat, and air quality, result from population 
growth and urbanization, and that growth around DOD installations is 
increasing more than the national average. At the same time, according 
to a defense official, the increased speed and range of weapon systems 
are expected to increase training range requirements. For the 
following reasons, DOD and service officials believe they face 
increasing encroachment risks in several key areas: 

* Critical habitat designation. The Endangered Species Act requires 
the Fish and Wildlife Service to designate critical habitat for 
endangered species at the time of listing, or within 12 months if more 
data about habitat is needed. Defense officials told us that private 
environmental interest groups have repeatedly challenged the Wildlife 
Services' failure to designate critical habitat and generally have 
prevailed, resulting in more and more designations. To illustrate, 
they noted that the Fish and Wildlife Service recently declined to 
designate critical habitat for a species at Camp Pendleton, using its 
authority to exempt land from designation if it finds that the 
benefits of exclusion outweigh the benefits of designation. They also 
noted that the Natural Resource Defense Council, a public interest 
group involved in environmental protection, is currently challenging 
the decision in court. Marine Corps officials report that if the Fish 
and Wildlife Service's position is not upheld, approximately 57 
percent of Camp Pendleton's training area could be designated as 
critical habitat and could face additional restrictions on training. 
Fish and Wildlife Service officials told us there could be significant 
increases in habitat designations in coming years. 

* Unexploded ordnance and munitions constituents. The application of 
environmental laws to unexploded munitions and munitions constituents 
has, to date, affected only one training installation in the 
continental U.S., the Massachusetts Military Reservation, used 
primarily by National Guard forces.[Footnote 16] It remains uncertain 
whether and to what extent the Environmental Protection Agency will 
apply the laws to other installations. Environmental Protection Agency 
officials told us that they were not explicitly monitoring military 
ranges, but if it were brought to their attention that ordnance was 
jeopardizing public health and safety at another installation, they 
would take action to address the situation. 

* Frequency spectrum. DOD officials told us that the commercial 
communications industry has been pressing for access to frequency 
spectrum currently allocated for federal use, but has stayed its 
request due to the current national security situation. However, 
reallocation of some of that spectrum is still under review. An 
interagency working group, with DOD participation, has been formed and 
is examining options, including sharing the spectrum and moving DOD 
operations to other bands. The outcome of these efforts could affect 
DOD missions, including combat training and satellite operations. 

* Airspace congestion. Commercial air traffic growth is expected to 
result in an increase in passengers from 600 million to an estimated 
one billion by 2010, increasing the overall demand for airspace 
volume. Military use of airspace will also increase with the next 
generation of high-performance weapon systems, standoff munitions, and 
unmanned aerial vehicles. In many instances, the military's use of 
airspace is tied directly to its ground infrastructure, which cannot 
be changed easily. The Federal Aviation Administration is in the 
process of redesigning the nation's airways to accommodate this 
growth. DOD is participating in the process to ensure that its 
requirements are known early. There is no schedule for completing the 
redesign, and until the redesign is completed, DOD cannot be certain 
how its training will be affected. 

* Air quality. The Clean Air Act requires federal agencies to analyze 
the potential effect of proposed projects or activities on air 
quality. According to DOD officials, installations located in areas 
that have not met, or have only recently met, the National Ambient Air 
Quality Standards must work with state or local regulatory agencies to 
offset any potential emission increases from training activities. This 
ensures that the air quality of the entire area is not significantly 
degraded.[Footnote 17] This may create conflicts with commercial 
development and could constitute a major impact as competition for air 
emissions budgets and offsets increases. 

* Noise. Noise problems are directly related to the degree that there 
are people, wildlife, and noise-sensitive land uses (national parks, 
wilderness, primitive areas, etc.) near military lands and low-level 
flying routes. Expanding population near military installations, 
increased use of public lands adjacent to military installations, 
training with more powerful weapons, and increased night operations 
could all contribute to a growing number of restrictions on DOD's 
operations. 

Impact of Encroachment on Readiness and Training Costs Is Not Well 
Reflected in DOD's Reported Data: 

Service readiness data do not indicate to what extent encroachment has 
significantly affected training readiness or costs, even though 
officials in congressional testimonies and other forums cited examples 
of encroachment at times preventing the services from training as they 
would like to. At the same time, fully assessing the impact may be 
difficult because the services lack information on (1) their training 
range requirements and (2) the training range assets available to 
support these requirements. Similarly, the services have very limited 
data indicating the effect of encroachment on operating costs. Even 
though some service officials point to increasing costs because of 
training workarounds related to encroachment, the services' data 
systems do not capture these costs in any comprehensive manner. DOD 
data, on the other hand, show fluctuations in total budget costs for 
environmental conservation efforts, with an overall drop in 
obligations since 1999, except for the Army. DOD officials 
acknowledge, however, that budget constraints and other priorities 
have resulted in a backlog of some projects in this area. 

Service Reports Do Not Report the Effects of Encroachment on Training 
Readiness: 

DOD's primary readiness reporting system should identify units that 
cannot train to standards because of inadequate training ranges. Yet 
it is not showing a problem in this area and rarely cites training 
range limitations at all. Similarly, DOD's quarterly reports to the 
Congress, which should identify specific readiness problems, rarely 
mention encroachment as an issue. 

Each month, or whenever a change in readiness occurs, units report 
their readiness status through the Global Status of Resources and 
Training System. Units report their status in four resource areas, one 
of which is training.[Footnote 18] Whenever a unit is not at the 
highest readiness level, it must identify the reasons from a list 
(which includes inadequate training areas). We analyzed monthly system 
data from active duty units in fiscal year 2001 and found that 
training readiness remains high for most units. There are few 
instances of units reporting lower training readiness, and even when 
they did so, they rarely cited the lack of adequate training ranges, 
areas, or airspace. Commanders may also include narrative comments in 
their readiness assessments. We reviewed comments on readiness reports 
for fiscal year 2001 but found that training range limitations were 
not frequently cited. 

Our recent assessment of training constraints outside the continental 
United States (which are often greater than those found stateside) 
found that units abroad rarely report lower training readiness in 
spite of concerns cited by service officials that training constraints 
sometimes require workarounds.[Footnote 19] We have long reported on 
limitations in DOD's readiness reporting system and the need for 
improvements.[Footnote 20] 

DOD's quarterly readiness reports to the Congress also identify few 
problems from encroachment. DOD is required to report quarterly to 
Congress describing readiness problems. We reviewed all reports 
submitted between April 1999 and December 2001 and found two 
citations: in the April-June 1999 report, the Navy expressed concerns 
that encroachment was precluding employment of high-altitude delivery 
tactics at the Naval Strike Air Warfare Center, Fallon, Nevada; in the 
October-December 2000 report, DOD noted that the Senior Readiness 
Oversight Council had convened in June 2000 to address encroachment 
issues. There was no further mention of encroachment as a readiness 
problem in reports submitted through December 2001. 

Full Assessment of Readiness Impact Limited by Lack of Data on 
Training Requirements and Inventory of Available Resources: 

A full assessment of the effects of encroachment on readiness will be 
limited without better information on the services' training range 
requirements and on the range resources available to support those 
requirements. The information is needed to establish a baseline for 
measuring losses or shortfalls. Each service has, to varying degrees, 
assessed its training range requirements. But none of them has 
comprehensively reviewed available range resources to determine 
whether assets are adequate to meet needs, and none has incorporated 
an assessment of the extent that other types of training, such as 
virtual or constructive training,[Footnote 21] could help offset 
shortfalls. A DOD report on training lands recognizes the importance 
of incorporating both approaches to training in their plans.[Footnote 
22] 

Each service is responsible for determining its own resource needs for 
training personnel. According to DOD, the process for identifying 
range and training area needs is a "top-down" process in which 
military planners project the amount of training required to achieve 
military readiness. Planners then formulate training plans using a 
"strategies-to-tasks" relationship. Once planners have promulgated the 
guidance, installation commanders establish a "bottom-up" process to 
ensure that requisite training can be supported at locally available 
ranges and training areas or, in case of a shortfall, to take action 
to acquire other assets. When there is not enough rangeland to support 
the training, the commander examines other training options, such as 
training aids, devices, simulators, and simulation, or the commander 
may examine how to conduct live training on the area available to the 
unit. The impact of a training range shortfall on a unit's training is 
the commander's judgment. The process is functionally similar among 
services but keyed to each service's unique mission requirements. 
Below are short descriptions of the assessments each service carried 
out to determine its training range requirements. 

Air Force: 

In 2001, the Air Force completed an assessment it had begun 5 years 
earlier to determine whether it had appropriate training space to 
ensure readiness. The Air Force believed better resourcing decisions 
could be made if both the requirements and current asset capabilities 
were stated more explicitly, with resourcing decisions based on a 
rigorously derived assessment of gaps. According to the assessment, in 
order to be defensible, infrastructure requirements must be linked 
firmly to training requirements, which, in turn, must be linked to 
operational requirements. To accomplish its assessment, the Air Force 
identified its aircrew training requirements and compared them to its 
existing range and airspace capabilities. 

The Air Force study found that, nationwide, it has sufficient access 
to air-to-ground training ranges, albeit with some localized 
shortages. For example, Pope Air Force Base, North Carolina, home of 
the 23d Fighter Group, has no local range, and Moody Air Force Base, 
Georgia, home of the 347th Rescue Wing, has insufficient capacity on 
its local ranges. This does not mean, however, that the Air Force does 
not have encroachment issues that need to be dealt with to preserve 
its air space. As already noted, the Air Force's major training 
facility, the Air Warfare Center at Nellis Air Force Base, Nevada, has 
problems with urbanization that restrict aircraft takeoffs with live 
ordnance. 

Navy: 

The Navy began an assessment of its training range needs in 2001 and
hopes to complete the process late in fiscal year 2004. According to 
Navy officials, the new database should quantify total range 
capability requirements and each range's contribution to readiness. 
The officials believe that this should establish a link between 
training requirements and readiness; formalize the process used to 
determine training range requirements; better articulate the Navy's 
training range strategy to DOD, Congress, and the public; and better 
manage the effects of encroachment. 

Marine Corps: 

In January 2002, the Marine Corps completed an analysis of the extent to
which Camp Pendleton's training facilities could support the training 
requirements of two types of units (a light armored reconnaissance 
platoon and an artillery battery) and two military specialties (a 
mortar man and a combat engineer). The analysis identified to what 
extent the training tasks for each unit or specialty could be 
conducted to standards in a "continuous" operating scenario (e.g., an 
amphibious assault and movement to an objective) or in a fragmented 
manner (tasks completed anywhere on the camp). The analysis found that 
from 60 to 69 percent of "continuous" tasks and from 75 to 92 percent 
of the other training tasks could be conducted to standards. A second 
analysis of four other types of units or military specialties should 
be completed in June 2002. We were told that the Marine Corps is 
planning to expand this effort to other installations. 

Army: 

The Army has not conducted a complete analysis of its training
requirements, but it did conduct a training capacity analysis of its 
installations, starting in 1997, that compared available assets and 
requirements as defined by military planners ("doctrinal" standards). 
According to the analysis, updated in 2002, many active duty 
installations do not have sufficient land to support training to 
doctrinal standards. For example, only 22 percent of active duty 
stateside installations have enough land to support their light 
maneuver training needs, and only 42 percent of active duty 
installations have enough land to support their heavy maneuver 
training needs.[Footnote 23] These installations are expected to use 
workarounds to meet training standards. 

Other Options Not Considered in the Services' Studies: 

Although information gleaned from the studies is valuable for planning 
purposes, we do not believe that the studies provide a complete 
picture of the service's training range needs. While live training may 
be preferred, other options also need to be considered. We believe an 
analysis based solely on live training may overstate an installation's 
problems and does not provide a complete basis for assessing training 
range needs or the effects of encroachment. 

A more complete assessment of training resources should include 
assessing the potential for using virtual or constructive simulation 
technology to augment live training. These alternatives sometimes 
allow units to train to standards. And while they cannot replace live 
training and cannot fully eliminate the impact of encroachment, they 
may help mitigate some training range limitations. By increasing their 
investments in and use of virtual and constructive simulation 
training, the services could also mitigate some of the restrictions 
imposed on live training. In fact, the Army's own guidance recommends 
doing so and states that a commander's analysis should consider using 
virtual training or constructive training to partially offset live 
training requirements (and thus the requirements for land). This is a 
longstanding issue, one where we have previously cited the need to 
identify the appropriate mix of live training and simulation 
technology.[Footnote 24] 

No Shared Inventory of Training Ranges: 

To the extent that inventories of training ranges do exist, they are 
not routinely shared with other services (or other organizations such 
as the Special Operations Command). While DOD officials acknowledge 
the potential usefulness of such data, there is no directory of DOD-
wide training areas, and commanders sometimes learn about capabilities 
available outside their own jurisdiction by chance. All this makes it 
extremely difficult for the services to leverage adequate assets that 
may be available nearby, increasing the risk of inefficiencies, lost 
time and opportunities, delays, added costs, and reduced training 
opportunities. 

Although there are examples of services sharing training ranges, these 
arrangements are generally made through individual initiatives, not 
through a formal or organized process that easily and quickly 
identifies all available infrastructure. Navy Special Operations 
forces only recently learned, for example, that some ranges at the 
Army's Aberdeen Proving Grounds are accessible from the water—a 
capability that is a key requirement for Navy team training. Given 
DOD's increasing emphasis on joint capabilities and operations, having 
an inventory of defense-wide training assets on all ranges, training 
or test, would seem to be a logical step toward a more complete 
assessment of training range capabilities and shortfalls that may need 
to be addressed. 

DOD officials acknowledge that having a DOD-wide database of training 
assets would also allow a more accurate measurement of Defense-wide 
restrictions on training and of the cumulative effects of encroachment 
on training readiness. In fact, an internal study group has suggested 
developing assessment criteria that could be used to make a 
programmatic assessment of the complete effects of encroachment on 
training readiness—something DOD has not done. 

Effects on Training Costs Not Well Defined, While Environmental 
Conservation Costs Have Fluctuated: 

Encroachment can increase the costs of conducting military training. 
However, the services have not documented the overall impact of 
encroachment on training costs. At the same time, DOD's overall 
environmental conservation funding, which would cover such things as 
endangered species management, has fluctuated, rising between fiscal 
years 1996 and 1998 and declining between fiscal years 1999 and 2001, 
except for the Army. 

Impact on Overall Training Costs Not Documented: 

Officials at each of the locations we visited cited increasing 
workarounds among the effects of encroachment on training, and many 
provided examples of additional costs and actions associated with 
these workarounds. However, none of the officials could provide 
composite data on the direct or indirect costs they had incurred as a 
result of encroachment and workarounds. For example, to protect marine 
mammals during naval gunfire exercises, the Navy uses aircraft and 
surface vessels to observe the training area and hires marine 
biologists to help crews spot and protect marine mammals. Marine Corps 
officials also said that Camp Pendleton units are increasingly using 
the Marine Corps Air Ground Combat Center, Twentynine Palms, 
California, to work around training restrictions, and the officials 
provided estimates of additional travel costs. But again, they could 
not provide us with aggregate data showing how much their costs had 
increased. According to DOD officials, training expenses are paid with 
operations and maintenance funds, and expenses specifically caused by 
encroachment are not identified separately from other training 
expenses. 

Environmental Conservation Costs Have Fluctuated, but Without 
Significant Increase: 

We examined the services' environmental conservation program 
obligations for fiscal years 1996-2001 and did not find any large or 
consistent increases in spending.[Footnote 25] As shown in figure 1, 
DOD's spending on this program shows only modest gains over the past 6 
years, increasing in 1996-98 but then dropping among all components 
except for the Army. 

Figure 1: DOD Environmental Conservation Program Obligations, Fiscal 
Years 1996-2001: 

[Refer to PDF for image: multiple line graph] 

The graph depicts DOD Environmental Conservation Program Obligations 
in constant fiscal year 2001 dollars for each of the following: 
Total; 
Army; 
Air Force; 
Navy. 

Note: DOD agencies are not shown but are included in the total. 

Source: DOD data. 

[End of figure] 

Total DOD conservation program obligations fluctuated, increasing from
$105 million in fiscal year 1996 to $136 million in fiscal years 1998 
and 1999 and then decreasing to $124 million in fiscal year 2001. 
[Footnote 26] Endangered species management and preservation are a 
part of DOD's conservation program. If the services are performing 
additional conservation projects, then the additional costs should be 
reflected in their environmental conservation program obligations. DOD 
documents attribute the fluctuations in conservation program 
obligations to increased costs from preparing Integrated Natural 
Resource Management Plans. An Army environmental official also said 
that the increase in Army program obligations that occurred between 
fiscal years 2000 and 2001 was due to the increased costs of preparing 
the plans. According to DOD officials, the plans are required by the 
Sikes Act and assist base commanders in conserving and rehabilitating 
natural resources. DOD officials also acknowledge that budget 
constraints and other priorities have resulted in some funding 
backlogs in this area. 

Comprehensive Plan for Addressing Encroachment Not Finalized, but Some 
Action Has Been Taken: 

DOD officials recognize the need for a comprehensive plan of 
administrative actions and legislative proposals to address 
encroachment issues but, except for a package of legislative proposals 
in late April 2002, have not yet finalized such a plan. In June 2000, 
the services first presented their encroachment problems to the Senior 
Readiness Oversight Council, which recognized the need for a 
comprehensive plan to address encroachment issues. However, as of 
April 2002, DOD was still developing a plan of administrative actions. 
The task was first given to a group of subject matter experts, who 
drafted plans of action for addressing the eight encroachment issues, 
but the plans are not yet finalized and they contain few implementing 
details. DOD is also drafting some policy and implementation 
directives. In December 2001, DOD appointed an Integrated Product Team 
to coordinate its encroachment mitigation efforts, develop a 
comprehensive set of legislative and regulatory proposals, and 
formulate and manage outreach efforts. The team agreed on a tentative 
set of legislative proposals that could become part of its 
comprehensive plan. Those legislative proposals were submitted to the 
Congress in late April 2002 seeking to modify several statutes. The 
proposed changes, in DOD's view, would preserve its training ranges 
and protect the environment. Other DOD organizations are also involved 
in addressing encroachment issues, and they have made some progress. 

Actions Needed for a Comprehensive Plan Have Not Been Completed: 

DOD's Senior Readiness Oversight Council took up the issue of 
encroachment in June 2000 and tasked its Defense Test and Training 
Steering Group with investigating the problem and developing a 
comprehensive plan of action. The steering group formed a Sustainable 
Range Working Group, comprised of subject matter experts who 
identified eight encroachment issues and drafted separate action plans 
for each issue. The plans outlined recommended courses of action, but 
they did not provide detailed implementation data The plans were 
briefed to the Senior Readiness Oversight Council in November 2000. 
The council approved the working group's overall findings and 
recommendations and directed the Test and Training Steering Group to 
take a number of actions, including coordinating the plans with the 
services and appropriate agencies and forwarding the results to the 
council by January 2001. The working group continued its work on 
encroachment through 2001 but did not forward its results to the 
council until late November 2001. DOD officials said that the 
transition to the new administration, the events of September 2001, 
and continuing internal deliberations delayed their efforts. They also 
said that formulating possible legislative solutions for some of the 
problems was difficult and consumed much of their time during 2001. 

The working group focused on the eight encroachment issues identified 
in this report. The group's draft action plans included an overview 
and analysis of an individual issue and current actions being taken, 
as well as short-, mid-, and long-term strategies and actions to 
address the issue. Examples of the types of future strategies and 
actions identified in the draft plans include the following: 

* Enhancing outreach efforts to build and maintain effective working 
relationships with key stakeholders by making them aware of DOD's need 
for ranges and airspace, its need to maintain readiness, and its need 
to build public support for sustaining training ranges. This was an 
overarching issue for each of the encroachment issues. 

* Clarifying the requirements of environmental and natural resource 
statutes as they apply to DOD training and operations. One proposed 
action advocates modifying the Sikes Act to permit installations 
managed under approved Integrated Natural Resource Management Plans to 
be excluded from critical habitat designations. Another would seek 
clarification of the term "harassment" as used in the Marine Mammal 
Protection Act. 

* Developing assessment criteria to identify all restrictions and 
determine the cumulative effect these restrictions are having on 
readiness training. The criteria would be appropriate for 
installations, special-use airspace, at-sea training areas, and other 
military operating areas. The draft plan noted that while many 
examples of endangered species/critical habitat and land use 
restrictions are known, a programmatic assessment of the effect these 
restrictions pose on testing and readiness training has never been 
done. 

* Developing a coordinated plan to obtain data, assess current range 
conditions, and estimate the environmental impacts of current 
munitions use on ranges. DOD would develop range clearance guidance 
and management procedures on the basis of operational safety and 
environment constraints associated with the hazards of unexploded 
ordnance, munitions scrap, target debris, and other associated range 
scrap. 

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

* Improving coordinated and collaborative efforts between the military 
and local communities in managing urban growth. Encouraging new and 
expanded cooperative working relationships between base officials and 
city planners and other local officials. 

A more detailed overview of the working group's recommended courses of 
action and strategies for addressing each encroachment area is 
included in appendix III. However, as noted, at the time we ended our 
review, the draft action plans had not been finalized to provide a 
comprehensive plan for addressing encroachment. DOD officials told us 
they consider the plans to be working documents and stressed that many 
of their concepts remain under review and may be dropped, altered, or 
deferred, while other proposals may be added. No details were 
available on overall actions planned, clear assignment of 
responsibilities, measurable goals and timeframes for accomplishing 
planned actions, or identification of funding requirements-—
information that would be needed in a comprehensive plan. 

Effective management of encroachment issues on military training 
ranges has been hindered by the divided management roles, 
responsibilities, and accountability that exist among several 
different levels within the military services and the Office of the 
Secretary of Defense. As discussed previously, the Secretaries of the 
military departments are responsible for training personnel and for 
maintaining their respective training ranges and facilities. Within 
the Office of the Secretary of Defense, the Under Secretary of Defense 
for Personnel and Readiness, the Deputy Under Secretary of Defense for 
Installations and Environment, and the Director, Operational Test and 
Evaluation, are responsible for different aspects of overseeing 
training ranges and addressing encroachment issues. 

DOD's Legislative Proposals to Address Encroachment Issues: 

In December 2001, the Deputy Secretary of Defense established a senior-
level Integrated Product Team to act as the coordinating body for 
encroachment efforts and to develop a comprehensive set of legislative 
and regulatory proposals by January 2002. The team agreed on a set of 
possible legislative proposals for clarifying some encroachment 
issues, and, after internal coordination deliberations, the proposals 
were submitted in late April 2002 to the Congress for its 
consideration. 

According to DOD, its legislative proposals seek to clarify the 
relationship between military training and a number of provisions in 
various conservation statutes, including the Sikes Act, the Endangered 
Species Act, the Migratory Bird Treaty Act, and the Marine Mammal 
Protection Act. Specifically, DOD's proposals would, among other 
matters: 

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

* Permit DOD to take migratory birds under the Migratory Bird Treat 
Act without action by the Secretary of the Interior where the taking 
is in connection with readiness activities. Also, they would require 
DOD to minimize the taking of migratory birds to the extent 
practicable without diminishment of military training or other 
capabilities, as determined by DOD. 

* Modify the definition of "harassment" under the Marine Mammal 
Protection Act as it applies to military readiness activities. 
[Footnote 27] 

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

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

* Provide that "release" under the Comprehensive Environmental 
Restoration, Compensation, and Liability Act would not include 
explosives, unexploded ordnance, munitions, munitions fragments, or 
constituents deposited on an operational range incident to their 
normal and expected use. The proposal explicitly preserves the 
President's authority under the act to address an imminent and 
substantial endangerment to the public health, welfare, or the 
environment. 

* Authorize the military departments to enter into agreements with 
private conservation organizations concerning lands in the vicinity of 
military installations to limit incompatible uses or preserve habitat 
so as to eliminate or relieve environmental restrictions that might 
potentially restrict or interfere with their military activities. 

* Authorize the military departments to convey certain surplus real 
property having conservation value to state and local governments or 
nonprofit conservation organizations. In general, transferees would be 
required to use and maintain the property for conservation purposes in 
perpetuity. 

While time permitted only a cursory consideration of the proposals, 
they appear to be another step by DOD toward developing a 
comprehensive approach to managing encroachment affecting military 
training ranges. 

Other Actions Underway: 

Although DOD has not yet finalized a comprehensive plan of 
administrative actions for addressing encroachment issues, it has made 
progress in several areas, in addition to its legislative proposals. 
It is drafting a directive that establishes the department's policy on 
Sustainment of Ranges and Operating Areas to serve as the foundation 
for addressing range sustainability issues. The directive, currently 
in coordination within DOD, would outline a policy framework for the 
services to address encroachment on their ranges. According to a DOD 
official, this directive will establish range sustainment as a 
planning and management requirement for all operational ranges and 
will also direct increased emphasis on outreach and coordination 
efforts with local communities and stakeholders. In addition, a DOD 
official reports that the department is currently preparing separate 
policy directives to establish a unified noise abatement program for 
the department and to specify the outreach and coordination 
requirements highlighted in the sustainable ranges directive. 

DOD has involved several other defense organizations in the range 
sustainability issue. Several of these organizations were already 
addressing specific encroachment issues prior to the services' initial 
presentation of encroachment problems in June 2000. The Sustainable 
Ranges Working Group incorporated the strategies already being 
implemented by these organizations into its plans, and these 
organizations have continued working on their original mandates. The 
organizations include the following: 

* The DOD Operational and Environmental Executive Steering Committee 
for Munitions is taking a life-cycle approach to DOD's management and 
use of munitions. The committee addresses issues associated with the 
removal of unexploded ordnance at former ranges and the development of 
weapon systems that avoid environmental problems. This committee 
recently completed work on a DOD Munitions Action Plan to help the 
services address safety and environmental concerns related to 
munitions. 

* The Clean Air Act Services Steering Committee reviews emerging 
regulations and works with the Environmental Protection Agency and the 
Office of Management and Budget to protect DOD's ability to operate. 
The committee works to obtain changes in final regulations to 
accommodate military issues. It has a number of subcommittees that 
address Clean Air Act issues that impact ranges. 

* The DOD Environmental Noise Working Group coordinates technical and 
policy issues within DOD. The group is responsible for addressing 
aircraft and ordnance-related environmental noise issues that have a 
bearing on DOD's ability to carry out its mission requirements. 

DOD is also working to place national-level liaisons with key federal 
agencies that have the potential to affect its range operations. For 
example, a military officer has been assigned to the Office of the 
Secretary of the Interior for two years, and DOD would like to assign 
liaisons at the Environmental Protection Agency, the Department of 
Commerce, and the Department of Agriculture. According to DOD 
officials, these liaisons would represent DOD's interests and would, 
it is hoped, be able to address and solve range sustainability issues 
before they become problems. 

Conclusions: 

DOD and the military services have lost training range capabilities 
and can be expected to experience increased losses in the future 
absent efforts to mitigate encroachment. The fact that DOD and service 
officials in congressional testimonies and other forums cite the 
adverse effects of encroachment on training, while commanders are not 
reporting any adverse effects, suggests that additional steps are 
needed to improve the reporting process. Our recent report on training 
limitations overseas recommended that DOD make improvements in 
reporting training shortfalls.[Footnote 28] At the same time, a full 
assessment of the impact of encroachment on training and readiness 
will be difficult without more complete data concerning training 
requirements and available resources. Factors making such assessments 
difficult include the lack of complete data on training range 
requirements, failure to consider the potential for alternative 
training technologies to augment live training, and inadequate 
inventories of facilities. While the Army, Navy, and Marine Corps are 
at various stages in collecting this data, DOD needs to ensure that 
these efforts continue to receive appropriate management attention and 
are funded and staffed sufficiently to ensure success. The information 
would also allow DOD to better defend its resource requirements, focus 
and prioritize its efforts based on the relative importance of land to 
the services' missions, make better stationing and base closure 
decisions, and write more effective training plans. DOD has taken some 
initial steps toward developing a comprehensive plan for addressing 
encroachment issues. Of particular note are DOD's recently submitted 
legislative proposals. However, the proposals are only a piece of the 
comprehensive plan DOD is working toward developing. A plan for other, 
administrative actions to address encroachment issues remains to be 
finalized. In finalizing its comprehensive plan, it is important that 
the department clearly establishes goals and milestones for tracking 
progress, identifies needed funding to accomplish the tasks, and 
assigns responsibility for managing and coordinating the department's 
efforts. 

Recommendations for Executive Action: 

While the Congress considers the department's legislative proposals, 
we recommend that the Secretary of Defense (1) require the services to
develop and maintain inventories of their training ranges, capacities, 
and capabilities, and fully quantify their training requirements 
considering complementary approaches to training; (2) create a DOD 
data base that identifies all ranges available to the department and 
what they offer, regardless of service ownership, so that commanders 
can schedule the best available resources to provide required 
training; (3) finalize a comprehensive plan for administrative actions 
that includes goals, timelines, projected costs, and a clear 
assignment of responsibilities for managing and coordinating the 
department's efforts to address encroachment issues on military 
training ranges; and (4) develop a reporting system for range 
sustainability issues that will allow for the elevation of critical 
training problems and progress in addressing them to the Senior 
Readiness Oversight Council for inclusion in Quarterly Readiness 
Reports to the Congress as appropriate. 

Agency Comments: 

In commenting on a draft of this report, the Deputy Under Secretary of 
Defense (Readiness) substantially concurred with the substance of the
and Our Evaluation report and recommendations. He indicated that 
actions were underway or were planned to deal with most of our 
recommendations. However, he suggested that we modify the focus of our 
last recommendation pertaining to the development of a reporting 
system for range sustainability issues. He said that our 
recommendation should focus on operational readiness degradations 
(impacts on combat capabilities) that result from encroachment and not 
merely on the elevation of critical training problems and on the 
progress in addressing them to the Congress. As noted elsewhere in 
this report, we recently completed a companion report on training 
constraints overseas that recommended improvements in readiness 
reporting; this goes to the heart of the issue raised by DOD. We agree 
that DOD should give increased attention to how encroachment issues 
affect operational readiness, and we would expect the department to 
emphasize this issue in improving its readiness reporting system. The 
recommendation in this report, however, goes beyond DOD's readiness 
reporting system. Given the department's often-voiced concerns over 
the impact of encroachment on its training capabilities, our 
recommendation in this report addresses the need for a system to 
foster periodic reporting on critical training problems, such as those 
resulting from encroachment, and on the progress in addressing them to 
the Senior Readiness Oversight Council. This would enable the council 
to report critical training problems, as appropriate, in its Quarterly 
Readiness Reports to the Congress. Accordingly, we have not changed 
this recommendation. 

The Deputy Under Secretary's comments are included in this report in 
appendix IV. He also provided technical clarifications, which we 
incorporated as appropriate. 

Unless you publicly announce its contents earlier, we plan no further 
distribution of this report until 5 days after its issue date. At that 
time, we will send copies of this report to the appropriate 
congressional committees; the Secretaries of Defense, the Army, the 
Navy, and the Air Force; and the Director, Office of Management and 
Budget. We also will make copies available to others upon request. In 
addition, the report will be available at no charge on the GAO Web 
site at [hyperlink, http://www.gao.gov]. 

Please contact me on (202) 512-8412 if you or your staffs have any 
questions concerning this report. In addition, Mark Little, Glenn 
Furbish,James Reid, John Lee, Jason McMahon, John Van Schaik, and 
Stefano Petrucci contributed to this report. 

Signed by: 

Barry W. Holman, Director: 
Defense Capabilities and Management: 

[End of section] 

Appendix I: Scope and Methodology: 

To identify the impact encroachment has had, or is likely to have, on 
the military service's training range capabilities in the continental 
United States, we visited four installations and two major commands. 
At each installation or command we conducted field interviews and 
evaluated available data on encroachment issues and how they impact 
training now, as well as the potential for impacts to increase in the 
future. The installations we visited were Fort Lewis, Washington; 
Marine Corps Base Camp Pendleton, California; Eglin Air Force Base, 
Florida; and Nellis Air Force Base, Nevada. The major commands we 
visited were the U.S. Atlantic Fleet, Norfolk, Virginia, and the U.S. 
Special Operations Command, MacDill Air Force Base, Tampa, Florida. 
The four installations and the U.S. Atlantic Fleet were selected by 
the service staffs as having conditions representative of the types of 
encroachment pressures they face, and the U.S. Special Operations 
Command was selected at the request the Committee on Government Reform 
staff as having unique encroachment pressures due to its specialized 
training requirements.[Footnote 29] We also interviewed officials and 
received briefings at the service headquarters from officials who are 
responsible for training and training area management. We discussed 
their processes for identifying their respective training area needs, 
and the resources available to support those needs. These officials 
include the Range and Training Area Management Division, Training and 
Education Command, Marine Corps Combat Development Command, Quantico, 
Virginia; the Land Use and Military Construction Branch, Facilities 
and Services Division, Installations and Logistics Department, 
Headquarters, U.S. Marine Corps, Arlington, Virginia; Bases and Units 
Branch, Air Force Office of Civil Engineering, Washington, D.C.; the 
U.S. Army Forces Command, Fort McPherson, Georgia; Training 
Directorate, Office of the Army Deputy Chief of Staff for Operations 
and Plans, Washington, D.C.; and the Fleet Readiness Division, Office 
of the Deputy Chief of Naval Operations for Logistics, Crystal City, 
Virginia. 

To determine the effect training range losses have on the services' 
training readiness and costs, we assessed DOD's and the services' 
training ranges requirements processes and their processes for 
identifying and managing training readiness problems. Specifically, we 
gathered data on how the services identify their training area needs, 
their processes for identifying gaps between their training area needs 
and available resources, and the views of each of these officials on 
the impact of encroachment on training. This includes officials from 
the Office of the Under Secretary of Defense for Personnel and 
Readiness, Washington, D.C.; the Office of the Assistant Under 
Secretary of Defense for Environmental Quality, Washington, D.C.; the 
Range and Training Area Management Division, Training and Education 
Command, Marine Corps Combat Development Command, Quantico, Virginia; 
the Land Use and Military Construction Branch, Facilities and Services 
Division, Installations and Logistics Department, Headquarters, U.S. 
Marine Corps, Arlington, Virginia; the Bases and Units Branch, Air 
Force Office of Civil Engineering, Washington, D.C.; the U.S. Army 
Forces Command, Fort McPherson, Georgia; the Training Directorate, 
Office of the Army Deputy Chief of Staff for Operations and Plans, 
Washington, D.C.; and the Fleet Readiness Division, Office of the
Deputy Chief of Naval Operations for Logistics, Crystal City, 
Virginia. We reviewed fiscal year 2001 data from the Global Status of 
Resources and Training System for the Army, Navy, Air Force, and 
Marine Corps to determine the extent that commanders identify training 
readiness problems caused by inadequate training ranges. For units 
that reported low training readiness levels, we examined the specific 
reasons cited for the lowered training readiness and also reviewed 
commanders' comments to ascertain whether they attributed any of their 
training readiness shortfalls to encroachment. We also analyzed cost 
data from the DOD's Environmental Quality Program for fiscal years 
1996 through 2001 to determine if the services were incurring higher 
costs as a result of environmental encroachment issues. We obtained 
this data from the Office of the Assistant Deputy Under Secretary of 
Defense for Environmental Quality. Finally, at each of the 
installations and major commands we visited, we discussed costs 
associated with working around encroachment issues and whether these 
costs, either direct or indirect, are captured in their respective 
financial data systems. 

To determine DOD's progress in formulating a comprehensive plan for 
addressing encroachment issues, we met with the members of the
Sustainable Ranges Working Group who are responsible for drafting
DOD's Sustainable Ranges Action Plans. These include officials from the
Office of the Under Secretary of Defense for Personnel and Readiness,
Washington, D.C.; the Office of the Assistant Under Secretary of 
Defense for Environmental Quality, Washington, D.C.; the Directorate of
Operational Test and Evaluation, Washington D.C.; the Land Use and
Military Construction Branch, Facilities and Services Division,
Installations and Logistics Department, Headquarters, U.S. Marine Corps,
Arlington, Virginia; the Civil Aviation Division, Air Force 
Directorate of Operations and Training, Washington, D.C.; the Bases 
and Units Branch, Air Force Office of Civil Engineering, Washington, 
D.C.; the Training Directorate, Office of the U.S. Army Deputy Chief 
of Staff for Operations and Plans, Washington, D.C.; the Office of 
Conformity and National Environmental Protection Act Documentation, 
Operational Environmental Compliance and Planning for the Chief of 
Naval Operations, Washington, D.C.; the Office of Environmental 
Planning, Chief of Naval Operations, Washington, D.C.; and the 
Facilities and Services Division, Installations and Logistics 
Department, Headquarters, U.S. Marine Corps, Arlington, Virginia. We 
discussed with these officials their analyses of the individual 
issues, their rationale for selecting each action, milestones or 
timetables that may exist, if any, and specific budgets for 
accomplishing each task. To gain the perspective of the regulatory 
agencies responsible for DOD's proposed action plans, we conducted 
interviews with senior officials of the Office of Enforcement and 
Compliance Assurance, Environmental Protection Agency, Washington, 
D.C., and the Fish and Wildlife Service, Arlington, Virginia. 

We performed our review from May 2001 through April 2002 in accordance 
with generally accepted government auditing standards. 

[End of section] 

Appendix II: Membership of DOD Encroachment-Related Groups: 

Table 1: Members of the Senior Readiness Oversight Council: 

Membership: 
The Deputy Secretary of Defense; 
The Chairman, Joint Chiefs of Staff; 
Chief of Staff, Air Force; 
The Secretary of the Air Force; 
Chief of Staff, Army; 
The Secretary of the Army; 
Chief of Naval Operations; 
Commandant of the Marine Corps; 
The Secretary of the Navy; 
Under Secretary of Defense for Acquisition, Technology and Logistics; 
Under Secretary of Defense for Personnel and Readiness; 
The Under Secretary of Defense Policy; 
Under Secretary of Defense (Comptroller). 

Source: DOD. 

[End of table] 

Table 2: Members of the Defense Test and Training Steering Group: 

Membership: 
Director of Operational Test and Evaluation Directorate; 
Deputy Under Secretary of Defense (Readiness); 
Deputy Under Secretary of Defense (Installations and Environment); 
Director of Defense Research and Engineering Directorate; 
Deputy Director of Development Test and Evaluation for Strategic and 
Tactical Systems Directorate; 
Principal Director of Interoperability for Defense Information Systems 
Agency; 
Senior Advisor for Defense Threat Reduction Agency; 
Deputy of Test, Simulation, and Evaluation for Missile Defense Agency; 
Chief of Technology Assessment Group for Defense Intelligence Agency; 
Deputy Director of Force Structure Resources and Assessment (J-8) for 
Joint Staff; 
Deputy Under Secretary of the Army (Operations Research); 
Director of Navy Test, Evaluation and Technology Requirements; 
Director of Air Force Test and Evaluation Directorate; 
Executive Director of United States Marine Corps Systems Command; 
Director of Training Directorate for Office of the Army Deputy Chief 
of Staff Operations and Plans; 
Head of Aviation Manpower and Training Programs Branch for Chief of 
Naval Operations (N789); 
Director of Operations and Planning for Deputy Chief of Staff of Air 
Force for Air and Space Operations; 
Commanding General of United States Marine Corps Training and 
Education Command; 
Deputy Director of Resources and Ranges for Operational Test and 
Evaluation Directorate; 
Director of Readiness and Training for Deputy Under Secretary of 
Defense (Readiness). 

Source: DOD. 

[End of table] 

Table 3: Members of the Integrated Product Team: 

Membership: 
Under Secretary of Defense for Personnel and Readiness; 
Deputy Under Secretary of Defense (Installations and Environment); 
Director of Operational Test and Evaluation Directorate; 
Assistant Secretary of the Army for Installations and Environment; 
Assistant Secretary of the Navy for Installations and Environment; 
Assistant Secretary of the Air Force for Installations, Environment, 
and Logistics; 
Director of the Army Training Directorate; 
Director of the Navy Fleet and Battle Group Training Branch; 
Director of the Air Force Directorate of Operations and Training; 
Principal Deputy Assistant Secretary of Defense for Legislative 
Affairs; 
DOD Deputy General Counsel for Environment and Installations. 

Source: DOD. 

[End of table] 

[End of section] 

Appendix III: DOD's Draft Sustainable Ranges Action Plans for 
Addressing Encroachment Issues: 

Between June 2000 and November 2001, DOD drafted sustainable ranges 
action plans for addressing range sustainability issues associated 
with endangered species habitat on military installations, 
environmental legislation covering unexploded ordnance and munitions, 
competition for the radio frequency spectrum, protected marine 
resources, competition for airspace, air pollution, noise pollution, 
and urban growth around military installations. Each action plan 
provides an overview and analysis of its respective encroachment 
issue, along with potential strategies and actions to address the 
issue. In December 2000, the plans were presented to DOD leadership, 
who approved the overall findings and recommendations and directed 
that the proposals be coordinated with the services and appropriate 
agencies. As of April 2002, the proposals continued to be reviewed and 
refined within DOD and the services. Consequently, DOD considers these 
plans working documents and many of the concepts proposed in them may 
be dropped, altered, or deferred, and other proposals may be added. A 
short description of each draft action plan, as of August 2001, 
follows. 

Endangered Species Act Action Plan: 

To address problems related to the presence of endangered species on 
DOD lands and the requirement to designate critical habitat, the 
proposed strategy of the draft Endangered Species Act Action Plan was 
to (1) prevent military training ranges from becoming a home for 
threatened and endangered species; (2) improve DOD's knowledge of 
endangered species and the impacts of military activities on those 
species and species at risk; (3) cultivate better partnerships with 
the Fish and Wildlife Service and the National Marine Fisheries 
Service for managing endangered species; (4) negate the need for 
critical habitat designation; and (5) seek legislative clarification 
of laws where appropriate. To implement this strategy, the plan 
proposes to seek clarification of species and habitat issues in the 
Endangered Species Act. In addition, it proposes working with the Fish 
and Wildlife Service to implement a policy that Integrated Natural 
Resource Management Plans qualify as special management plans that 
negate the need for critical habitat designation. It also proposes 
establishing a forum for information exchange between DOD, the 
services, the Fish and Wildlife Service, and the Department of the 
Interior to improve communication and coordination on endangered 
species issues; conducting a programmatic assessment of the effect 
endangered species restrictions have on military testing and training; 
matching installation mission requirements to endangered species 
recovery priorities so that installations with lesser mission 
priorities have greater recovery burdens; and working proactively to 
prevent the listing of at-risk species. It further proposes to build 
and expand upon existing partnerships that integrate DOD biodiversity 
planning with regional planning so that defense lands do not become a 
home for threatened and endangered species, improve available 
information on the impacts to endangered species from military 
training, and develop policies on the use of land outside 
installations to meet conservation requirements. 

Unexploded Ordnance and Munitions Constituents Action Plan: 

To address problems related to the application of environmental 
statutes to unexploded ordnance and munitions constituents on active 
ranges, the draft Unexploded Ordnance and Munitions Constituents 
Action Plan proposes a strategy to improve and integrate requirements 
to develop, test, and use munitions, while ensuring explosives safety 
and protecting human health, safety, and the environment. To implement 
this strategy, the plan proposes to develop a DOD munitions 
expenditure database, work with the regulatory community to develop 
consistent responses to the environmental issues of unexploded 
ordnance, and identify funding and resource requirements for the 
unexploded ordnance mitigation program. This proposal would include a 
consistent risk assessment methodology to deal with munitions and 
their constituents on closed, transferring, and transferred ranges; a 
sustainable range management program that integrates training 
requirements with environmental and explosive safety requirements; a 
munitions acquisition plan to minimize undesirable environmental and 
explosives safety impacts; and a tailored legislative clarification of 
laws that could apply to military munitions. In addition, the plan 
proposes to implement public relations efforts to inform the Congress, 
regulators, and the public about the military's munitions requirements 
and develop community outreach and educational tools that inform 
stakeholders and monitor the success of stakeholder involvement. 
Another proposal calls for collecting scientific data and developing 
new technologies to identify and reduce the environmental impact of 
munitions, supporting the assessment of the environmental and human 
health effects of ordnance disposal, and focusing on the development 
of bullets and munitions with fewer environmental effects than current 
ammunition. 

Radio Frequency Spectrum Action Plan: 

To deal with problems caused by the increasing demand and competition 
for radio frequency spectrum, the draft Radio Frequency Spectrum 
Action Plan proposes a strategy of policy management and technological 
innovation. The policy strategy proposes to engage the Congress in 
developing new laws and policies that maintain DOD's spectrum, while 
supporting the implementation of the laws that currently protect 
reserved bandwidth, and to increase funding for the Central Test and 
Evaluation Investment Program to leverage existing technologies to 
improve the use of current bandwidth. Proposed technological 
innovations include increasing the efficiency of spectrum use by 
developing new systems to operate at higher spectrum, scheduling of 
current band usage, and developing band-sharing technologies. 

Maritime Sustainability Action Plan: 

To sustain maritime training capability, the draft Maritime 
Sustainability Action Plan proposes a strategy of (1) engagement with 
regulators and legislators, (2) collection of data on marine species 
and mitigation costs, and (3) legislative and policy changes. Actions 
proposed include (1) engaging regulators and legislators to further 
define and enforce marine environmental laws, (2) developing a clearer 
definition of harassment of endangered species to be applied to DOD 
activities, (3) initiating an outreach program aimed at ensuring that 
members of Congress understand the need for continued military 
training in offshore operating areas and the military's previous 
record of environmental stewardship, (4) initiating data collection 
efforts to increase the amount of scientific data available about 
marine species and their habitats and to gather data on the fiscal and 
operational impacts of compliance with maritime environmental 
regulations, (5) incorporating scientific data into exercise planning 
to minimize impacts on endangered species, (6) developing an 
acquisition policy that new weapons system use mature technologies to 
reduce the environmental impacts of testing and training, (7) 
investigating the use of closed environments (i.e., not the open 
ocean) for ordnance testing, and (8) minimizing, to the maximum extent 
possible, the impact of new acoustic sensors and explosives on the 
marine environment. 

National Airspace Redesign Action Plan: 

To address airspace problems associated with the increased 
requirements of new generations of weapons and systems and the growing 
competition with the commercial aviation industry, the draft National 
Airspace Redesign Action Plan proposes a strategy to ensure that DOD 
requirements are included in the national airspace redesign process by 
engaging the Federal Aviation Administration in the process. The 
objectives of the national airspace redesign process are to maintain 
system safety; to decrease system delay; and to increase system 
flexibility, predictability, and user access. DOD's proposed actions 
to implement this strategy are to form (1) a senior-level policy board 
on federal aviation to review the scope and progress of DOD activities 
and develop guidance and processes for the future and (2) an oversight 
group for DOD and Federal Aviation Administration national airspace 
system integration. 

Air Quality Action Plan: 

To address air quality issues at the federal, state, and local levels, 
the draft Air Quality Action Plan proposes a tiered strategy that 
consists of reviewing emerging regulations and working to obtain 
changes to final regulations to accommodate military issues. The 
action plan recommendations rely on engagement and outreach on the 
part of DOD and the services to prevent future adverse impact on the 
use of training ranges. The elements of these actions include 
approaching each specific issue from a position of knowledge, starting 
at the local level with sound positions and working up through major 
command and headquarters with federal and state regulators to seek 
resolution; employing modeling and simulation as necessary; and 
exploring science and technology initiatives to facilitate future 
equipment and processes that emit fewer pollutants than legacy 
equipment. 

Airborne Noise Action Plan: 

To respond to noise encroachment, the draft Airborne Noise Action Plan 
proposes a strategy that will engage other agencies and organizations 
when they propose restrictions or programs that could impact DOD 
missions. DOD believes that self-imposed restrictions and concessions 
by installations often jeopardize their ability to accomplish their 
training missions. Consequently, it identified actions that would 
result in two goals: (1) developing a comprehensive integrated noise 
program and (2) factoring noise into the development and acquisition 
process. 

Urban Growth Action Plan: 

To address encroachment from urban growth, the draft Urban Growth 
Action Plan proposes a strategy that will try to influence state and 
local governments to adopt, implement, and enforce local encroachment 
prevention plans and programs so that future incompatibilities between 
civilian growth and military training needs might be avoided. The 
strategy relies on a series of actions related to public relations and 
coordinated land use programs to engage local communities. It includes 
(1) forming a coordinated effort within DOD to build and expand upon 
existing urban development encroachment partnerships; (2) ensuring 
installations have effective public outreach plans; (3) requiring each 
installation and range to implement a comprehensive planning process; 
(4) expanding the Joint Land Use Study program to address range 
encroachment; (5) working with local authorities to implement 
appropriate land use zoning near military installations; and (6) 
having regional environmental coordinators monitor and advocate for 
DOD on emerging land use issues. 

[End of section] 

Appendix IV: Comments from the Department of Defense: 

Under Secretary Of Defense: 
Personnel And Readiness: 
4000 Defense Pentagon: 
Washington, D.C. 20301-4000: 

May 29, 2001: 

Mr. Barry W. Holman: 
Director, Defense Capabilities and Management: 
U.S. General Accounting Office: 
Washington, D.C. 20548: 

Dear Mr. Holman: 

This is the Department of Defense (DoD) response to the General 
Accounting Office Draft Report GAO-02-614, "Military Training: DoD 
Lacks a Comprehensive Plan to Manage Encroachment on Training Ranges," 
April 25, 2002 (GAO Code 350075). 

The Department appreciates the opportunity to comment on this draft, 
and substantially concurs with the contents of the report and the 
recommendations offered within. The Department offers adjustments to 
the GAO draft recommendations along with several general and specific 
comments in the enclosure, and has provided additional technical 
comments separately to GAO for inclusion. 

Sincerely, 

Signed by: 

[Illegible] for: 
Paul W. Mayberry: 
Under Secretary of Defense (Readiness): 

Enclosure: As stated: 

[End of letter] 

GAO Code 350075/GAO-02-614: 

"Military Training: DOD Lacks A Comprehensive Plan To Manage 
Encroachment On Training Ranges" 

Department Of Defense Comments To The Recommendations: 

Recommendation 1: The GAO recommended that the Secretary of Defense
require the Services to develop and maintain inventories of their 
training ranges, capacities, and capabilities, and fully quantify 
their training requirements considering complimentary approaches to 
training. (Page 30/Draft Report) [See p. 31] 

DoD Response: Concur. The services have already been tasked with 
compiling inventories and have made substantial progress in that 
effort. The services have met and are developing a statement of work 
in order to contract a firm capable of delivering an enterprise level 
web-enabled system that will allow cross-service as well as intra-
service training use of this inventory data. 

Recommendation 2: The GAO recommended that the Secretary of Defense 
create a DoD data base that identifies all ranges available to the 
Department and what they offer, regardless of Service ownership, so 
that commanders can schedule the best available resources to provide 
required training. (Page 30/Draft Report) [See p. 31] 

DoD Response: Concur. The enterprise level web-enabled system 
described above will incorporate this capability. Business rules will 
be developed in accordance with the needs of each service to maximize 
the flexibility to utilize other service ranges. 

Recommendation 3: The GAO recommended that the Secretary of Defense 
finalize a comprehensive plan for administrative actions that includes 
goals, timelines, projected costs, and a clear assignment of 
responsibilities for managing and coordinating the Department's 
efforts to address encroachment issues on military training ranges.
(Page 30/Draft Report) [See p. 31] 

DoD Response: Concur. The Department agrees with the need to develop a 
definitive program to counter encroachment. 

Recommendation 4: The GAO recommended that the Secretary of Defense 
develop a reporting system for range sustainability issues that will 
allow for the elevation of critical training problems and progress in 
addressing them to the Senior Readiness Oversight Council for 
inclusion in Quarterly Readiness Reports to the Congress as
appropriate. (Page 30/Draft Report) [See p. 31] 

DoD Response: Partially Concur. The GAO recommendation should read: 
"develop a reporting system with sufficient granularity to routinely 
capture operational readiness degradations (impacts on combat 
capabilities) that result from encroachment, not merely documenting 
instances of encroachment limitations on training. This system will 
allow for the elevation of critical training problems and progress in 
addressing them to the Senior Readiness Oversight Council for 
inclusion in Quarterly Readiness Reports to the Congress as 
appropriate." The impact on readiness is the critical issue here and 
not merely the existence of encroachment. While measuring that impact 
is not a simple process, including it here keeps the readiness focus 
and supports DoD comment on ongoing readiness reporting improvement 
efforts. 

[End of section] 

Footnotes: 

[1] The Department of Defense defines encroachment as the cumulative 
result of any and all outside influences that inhibit normal military 
training and testing. 

[2] Unexploded ordnance are munitions that have been primed, fused, 
armed, or otherwise prepared for action, and have been fired, dropped, 
launched, projected, or placed in such a manner as to constitute a 
hazard to operations, installations, personnel, or material and remain 
unexploded either by malfunction, design or any other cause. Munitions 
constituents consist of such things as propellants, explosives, 
pyrotechnics, chemical agents, metal parts, and other inert components 
that can pollute the soil and/or ground water. 

[3] We use the term "training ranges" to collectively refer to air 
ranges, live-fire ranges, ground maneuver ranges, and sea ranges. 

[4] U.S. General Accounting Office, Military Training: Limitations 
Exist Overseas but Are Not Reflected in Readiness Reporting, 
[hyperlink, http://www.gao.gov/products/GAO-02-525] (Washington, D.C.: 
April 30, 2002). 

[5] Installations toured included Fort Lewis, Washington; Marine Corps 
Base Camp Pendleton, California; Eglin Air Force Base, Florida; and 
Nellis Air Force Base, Nevada. The major commands reviewed included 
the U.S. Atlantic Fleet and the U.S. Special Operations Command. These 
tours were based on recommendations of the service staffs as having 
conditions representative of the types of encroachment pressures they 
face. The visit to the U.S. Special Operations Command was included 
based on the recommendation of the Committee on Government Reform 
staff because of the command's specialized training requirements and 
unique encroachment pressures. 

[6] U.S. General Accounting Office, Military Training: DOD Needs A 
Comprehensive Plan to Manage Encroachment on Training Ranges, 
[hyperlink, http://www.gao.gov/products/GAO-02-727T] (Washington, 
D.C.: May 16, 2002). 

[7] A unit's readiness is determined by the extent to which it 
possesses the required resources and training to undertake its wartime 
missions. 

[8] Members of the Senior Readiness Oversight Council are identified 
in appendix II of this report. 

[9] Members of the Integrated Product Team are identified in appendix 
II of this report. 

[10] The U.S. Fish and Wildlife Service and the National Marine 
Fisheries Service list species that are at risk of becoming extinct 
throughout all or a significant portion of their range. For each 
listed species, the appropriate agency must designate critical habitat 
for those species. Federal agencies must consult with the agencies on 
any action that jeopardizes the continued existence of a listed 
species or could result in the destruction or adverse modification of 
designated critical habitat. 

[11] U.S. General Accounting Office, Defense Spectrum Management: More 
Analysis Needed to Support Spectrum Use Decisions for the 1755-1850MHz 
Band, [hyperlink, http://www.gao.gov/products/GAO-01-795] (Washington, 
D.C.: Aug. 20, 2001). 

[12] Members of the Defense Test and Training Steering Group are 
identified in appendix II of this report. 

[13] The Yakima Training Center is a component of Fort Lewis that is 
used to conduct large-scale maneuver and live-fire operations. Yakima 
is approximately 180 miles east of Fort Lewis. 

[14] Fort Lewis is home to two Interim Brigade Combat Teams being 
organized around new light armored wheeled vehicles under the Army's 
Force Transformation program. 

[15] The Nevada Test and Training Range is a component of the Nellis 
Range Complex. 

[16] DOD officials told us that a second installation outside the 
continental U.S., Fort Richardson, Alaska, is currently subject to a 
suit alleging environmental violations that, if successful, could 
severely limit live-fire training. 

[17] U.S. General Accounting Office, Air Pollution: Status of 
Implementation and Issues of the Clean Air Act Amendments of 1990, 
[hyperlink, http://www.gao.gov/products/GAO/RCED-00-72] (Washington, 
D.C.: Apr. 17, 2000). 

[18] The other three resource areas are equipment and supplies on 
hand, equipment condition, and personnel. A unit's training readiness 
status is determined by the present level of training of assigned 
personnel compared with the standards for a fully trained unit as 
defined by joint and service directives. 

[19] See [hyperlink, http://www.gao.gov/products/GAO-02-525]. 

[20] See U.S. General Accounting Office, Military Readiness: Congress 
Needs Better tools for Effective Oversight, [hyperlink, 
http://www.gao.gov/products/GAO/TI-NSIAD-98-124] (Washington, D.C.: 
Mar. 18, 1998); U.S. General Accounting Office, Military Readiness: 
Improved Assessment Measures Are Evolving, [hyperlink, 
http://www.gao.gov/products/GAO/T-NSIAD-95-117] (Washington, D.C.: 
Mar. 16, 1995); and U.S. General Accounting Office, Military 
Readiness: DOD Needs to Develop a More Comprehensive Measurement 
System, [hyperlink, http://www.gao.gov/products/GAO/NSIAD-95-29] 
(Washington, D.C.: Oct. 27, 1994). 

[21] Virtual training uses simulation to replicate weapon systems and 
settings. Constructive training uses simulation to replicate units, 
weapon systems, and terrain. 

[22] Department of Defense, The Need for Ranges and Training Areas 
(Mar. 1999). 

[23] Training on light maneuver areas is limited to small units or 
units having only wheeled vehicles; on heavy maneuver areas training 
is unrestricted and covers all types of vehicles and equipment, 
including tracked vehicles. 

[24] See U.S. General Accounting Office, Army Training: Various 
Factors Create Uncertainty About Need for More Land, [hyperlink, 
http://www.gao.gov/products/GAO/NSIAD-91-103] (Washington, D.C.: Apr. 
22, 1991); U.S. General Accounting Office, Army Training: Computer 
Simulations Can Improve Common Training in Large Scale Exercises, 
[hyperlink, http://www.gao.gov/products/GAO/NSIAD-91-67] (Washington, 
D.C.: Jan. 30, 1991); and U.S. General Accounting Office, Operation 
Desert Storm: War Offers Important Insights Into Army and Marine Corps 
Training Needs, [hyperlink, 
http://www.gao.gov/products/GAO/NSIAD-92-240] (Washington, D.C.: Aug. 
25, 1992). 

[25] DOD's Environmental Conservation Program funds numerous 
activities, including management and preservation of endangered 
species, control of invasive species, and inventories of natural and 
cultural resources. 

[26] For fiscal year 2003, DOD has requested $4 billion for its 
environmental programs, which consist of environmental restoration, 
compliance, cleanup at base closure sites, pollution prevention, 
environmental technology, and conservation. 

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

[28] See [hyperlink, http://www.gao.gov/products/GAO-02-525]. 

[29] Our review did not include Vieques (Atlantic Fleet Weapons 
Training Facility), Puerto Rico, because the training constraints 
involving Vieques are well known. 

[End of section] 

GAO’s Mission: 

The General Accounting Office, the investigative arm of Congress, 
exists to support Congress in meeting its constitutional 
responsibilities and to help improve the performance and accountability 
of the federal government for the American people. GAO examines the use 
of public funds; evaluates federal programs and policies; and provides 
analyses, recommendations, and other assistance to help Congress make 
informed oversight, policy, and funding decisions. GAO’s commitment to 
good government is reflected in its core values of accountability, 
integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through the Internet. GAO’s Web site [hyperlink, 
http://www.gao.gov] contains abstracts and fulltext files of current 
reports and testimony and an expanding archive of older products. The 
Web site features a search engine to help you locate documents using 
key words and phrases. You can print these documents in their entirety, 
including charts and other graphics. 

Each day, GAO issues a list of newly released reports, testimony, and 
correspondence. GAO posts this list, known as “Today’s Reports,” on its 
Web site daily. The list contains links to the full-text document 
files. To have GAO e-mail this list to you every afternoon, go to 
[hyperlink, http://www.gao.gov] and select “Subscribe to daily E-mail 
alert for newly released products” under the GAO Reports heading. 

Order by Mail or Phone: 

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to: 

U.S. General Accounting Office: 
441 G Street NW, Room LM: 
Washington, D.C. 20548: 

To order by Phone: 
Voice: (202) 512-6000: 
TDD: (202) 512-2537: 
Fax: (202) 512-6061: 

To Report Fraud, Waste, and Abuse in Federal Programs Contact:
Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Public Affairs: 

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