Environmental Compliance:

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

GAO-03-639: Published: Jun 17, 2003. Publicly Released: Jun 17, 2003.

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

DOD's and the services' policies and processes for the environmental quality program do not always ensure that program funds are targeted to the most important and appropriate environmental activities. Instead, GAO found that some installations have funded low-priority or other activities that were ineligible under their environmental quality funding policies, at the same time that higher-priority activities were not funded. For example, at certain large installations that GAO visited, low-priority activities, such as noise monitoring, or ineligible activities, such as pest management, landscaping, and roof replacement, were funded while high-priority activities to prevent soil erosion were not. At the root of the problem is DOD's broad program policy that does not provide specific guidance on what activities are eligible for the program and the resulting inconsistent interpretation and implementation of this policy by the military services. DOD's policy requires that all high-priority activities be funded, but gives the services broad discretion in how this policy is put into place. As a result, GAO found (1) inconsistencies across and within the services about which activities are eligible for environmental quality program funding and (2) the funding of some activities through the program that more closely relate to military operations or base maintenance. For example, some services use program funds for oil and hazardous material spill response plans, equipment, and cleanup costs, while other services require the organization responsible for the spill to pay for the cleanup portion of those costs. Similarly, service policies can differ regarding responsibility for funding maintenance of structures such as water and sewer treatment facilities and historic buildings. Without a consistently implemented approach, there is no assurance that DOD's requirement to fund all high-priority activities is being met. Instead, some high-priority projects are being deferred. Generally, these deferrals involve projects that, although required by law, do not have to be completed by specific dates (e.g., surveys of properties required by historic preservation law). Deferring such activities, however, can lead to larger and more costly problems later. Moreover, to fund unbudgeted emergency environmental activities, the installations may have to defer other high-priority environmental program activities, obtain funds from other sources at the installation such as maintenance activities, or obtain funds from higher command levels. Some services have recently indicated that the availability of funds for environmental activities is likely to get worse in future years, because of expected reductions in their budgets for this program. Such constraints make a well-implemented prioritization process even more important.

Recommendation for Executive Action

  1. Status: Closed - Implemented

    Comments: DOD updated its policy in March 2005.

    Recommendation: To ensure that DOD can better target environmental quality program funds to the most important and most appropriate activities, the Secretary of Defense should establish a more specific policy on which activities should be eligible for funding through the services' environmental quality programs and how such activities should be prioritized and funded. The military services should subsequently conform their policies and processes to the revised DOD policy.

    Agency Affected: Department of Defense


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