Military Training: DOD Needs a Comprehensive Plan to Manage	 
Encroachment on Training Ranges (16-MAY-02, GAO-02-727T).	 
                                                                 
The following eight "encroachment" issues are hampering the	 
military's ability to carry out realistic training: endangered	 
species' critical habitat, unexploded ordnance and munitions,	 
competition for radio frequency spectra, protected marine	 
resources, competition for airspace, air pollution, noise	 
pollution, and urban growth around military installations.	 
Officials at all the installations and major commands GAO visited
in the continental United States reported that encroachment had  
affected some of their training range capabilities, requiring	 
work-arounds that are unrealistic. Service officials believe that
population growth is responsible for current encroachment	 
problems in the United States and is likely to cause more	 
training range losses in the future. Despite concerns about	 
encroachment, military readiness reports do not indicate the	 
extent to which encroachment is harming training. Improvements in
readiness reporting can better reveal shortfalls in training, but
the ability to fully assess training limitations and their impact
on capabilities and readiness will be limited without (1) more	 
complete baseline data on training range capabilities,		 
limitations, and requirements and (2) consideration of how live  
training capabilities may be complemented by training devices and
simulations. Progress in addressing individual encroachment	 
issues has been made, but more will be required to		 
comprehensively plan for encroachment. Legislation proposed by	 
the Department of Defense to "clarify" the relationship between  
military training and various environmental statues may require  
trade-offs between environmental policy and military training	 
objectives.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-727T					        
    ACCNO:   A03327						        
  TITLE:     Military Training: DOD Needs a Comprehensive Plan to     
Manage Encroachment on Training Ranges				 
     DATE:   05/16/2002 
  SUBJECT:   Air pollution					 
	     Environmental monitoring				 
	     Environmental policies				 
	     Marine policies					 
	     Military facilities				 
	     Military training					 
	     Noise pollution					 
	     Population growth					 
	     Radio frequency allocation 			 
	     Strategic planning 				 
	     Endangered species 				 
	     Defense capabilities				 
	     Defense cost control				 
	     Proposed legislation				 
	     Army Integrated Natural Resources			 
	     Management Plan					 
                                                                 
	     DOD Air Installation Compatible Use		 
	     Zones Program					 
                                                                 
	     DOD Global Status of Resources and 		 
	     Training System					 
                                                                 

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GAO-02-727T
     
Testimony Before the Committee on Government Reform, House of
Representatives

United States General Accounting Office

GAO For Release on Delivery Expected at 10: 00 a. m., EDT Thursday May 16,
2002

MILITARY TRAINING DOD Needs a Comprehensive Plan to Manage Encroachment on
Training Ranges

Statement of Barry W. Holman, Director, Defense Capabilities and Management

GAO- 02- 727T

Page 1 GAO- 02- 727T Military Training

Mr. Chairman and Members of the Committee: I am pleased to have the
opportunity to discuss the results of our recent work involving the
constraints that encroachment places on military training. As you know,
senior Department of Defense (DOD) and military services officials have
testified that they face growing difficulties in carrying out realistic
training at installations and training ranges 1 because of so- called
?encroachment? 2 issues, which limit their ability to train military forces
at the required levels of proficiency. The eight encroachment issues
identified by DOD are endangered species? critical habitat, unexploded
ordnance and munitions components, 3 competition for radio frequency
spectrum, protected marine resources, competition for airspace, air
pollution, noise pollution, and urban growth around military installations.

My testimony is based on the work that we recently carried out at your
request on the effects of encroachment in the continental United States on
military training and readiness. 4 I should also note that we recently
completed a review of constraints on the training of U. S. forces overseas.
5 The findings of the two reviews have some similarities. In response to the
questions you asked us to address, I will discuss (1) the growing impact of
encroachment on training range capabilities, (2) the effects of

1 The term ?training ranges? in this statement refers to air, live- fire,
ground maneuver, and sea ranges. 2 DOD defines ?encroachment? as the
cumulative result of any and all outside influences that inhibit normal
military training and testing. 3 Unexploded ordnance is munitions that (1)
have been primed, fused, armed, or otherwise prepared for action; (2) have
been fired, dropped, launched, projected, or placed in such a manner as to
constitute a hazard to operations, installations, personnel, or material;
and (3) remain unexploded either by malfunction, design or any other cause.
Munitions components- which DOD calls ?constituents?- include such things as
propellants, explosives, pyrotechnics, chemical agents, metal parts, and
other inert components that can pollute the soil or groundwater.

4 See U. S. General Accounting Office, Military Training: DOD Lacks a
Comprehensive Plan to Manage Encroachment on Training Ranges, GAO- 02- 614
(Washington, D. C., expected to be issued in June 2002).

5 See U. S. General Accounting Office, Military Training: Limitations Exist
Overseas but Are Not Reflected in Readiness Reporting, GAO- 02- 525
(Washington, D. C.: Apr. 30, 2002). The Chairman, Subcommittee on Readiness
and Management Support, Committee on Armed Services, U. S. Senate, requested
this review.

Page 2 GAO- 02- 727T Military Training

encroachment on training readiness and costs, and (3) DOD?s progress in
developing a comprehensive plan for addressing encroachment.

Officials at all the installations and major commands we visited here in the
continental United States reported that encroachment had affected some of
their training range capabilities, requiring work- arounds- or adjustments
to training events. Each of the installations we visited reported having
lost some capabilities in terms of the time that ranges were available or
the types of training that could be conducted. We identified similar effects
in most countries overseas in which U. S. forces are based. The potential
problem with work- arounds is that they lack realism and can lead to the
practice of tactics that are contrary to those used in combat. Service
officials believe that population growth is responsible for much of their
past and present encroachment problems in the United States and is likely to
cause more training range losses in the future.

Despite concerns voiced by DOD officials about the effects of encroachment
on training, DOD?s readiness reports do not indicate the extent to which
encroachment is adversely affecting training. In fact, most reports show
that units have a high state of readiness, and they are largely silent on
the issue of encroachment. While improvements in readiness reporting can and
should be made to better show any shortfalls in training, DOD?s ability to
fully assess training limitations and their overall impact on training
capabilities and readiness will be limited without (1) more complete
baseline data on training range capabilities and limitations and the
services? training range requirements and (2) a full consideration of how
live training capabilities may be complemented by other forms of training
such as those available through training devices and simulations. These
actions are not meant to take the place of other steps that may be needed to
deal with encroachment, but they are key to better depicting the net effects
of encroachment now and in the future. At the same time, it is important to
note that while it is widely recognized that encroachment results in work-
arounds that can increase training costs, those costs are not easily
determined or aggregated to measure their full effect. The funding
associated with DOD?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 service components except for
the Army. Summary

Page 3 GAO- 02- 727T Military Training

DOD officials recognize the need for a comprehensive plan to address
encroachment but have not yet finalized such a plan. DOD has made some
progress in addressing individual encroachment issues, but more will be
required to put in place a comprehensive plan to deal with 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 the specific actions planned, the time frames for
completing them, the clear assignment of responsibilities, and the funding
needed- elements that will be key to better ensuring the completeness and
viability of a comprehensive plan. Although DOD has not yet finalized a
comprehensive plan, progress has been made in a number of areas by a variety
of departmental organizations. For example, a steering committee has been
addressing explosive safety and environmental concerns and has recently
completed work on a munitions action plan that addresses safety and
environmental concerns related to munitions.

DOD also recently submitted a package of legislative proposals to Congress
to deal with various encroachment issues. DOD describes this package as
seeking to ?clarify? the relationship between military training and a number
of provisions in various environmental statutes. The consideration of these
legislative proposals will require Congress to consider the potential trade-
offs among multiple environmental policy objectives and their impact on
military training.

In our draft report on stateside encroachment issues, we made several
recommendations aimed at helping DOD develop a comprehensive plan for
dealing with encroachment and improve the information and data available for
identifying and reporting on the effects of encroachment. 6 In our recently
issued report on overseas training limitations, we made recommendations to
improve the quality of readiness reporting to better reflect training
constraints and to provide for a more comprehensive approach to addressing
training limitations. 7

Military ranges and training areas are used primarily to test weapons
systems and train military forces. Required facilities include air ranges
for air- to- air, air- to- ground, drop zone, and electronic combat
training; live- fire

6 See GAO- 02- 614. 7 See GAO- 02- 525. Background

Page 4 GAO- 02- 727T Military Training

ranges for artillery, armor (e. g., tanks), 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 DOD officials, a slow but steady increase in encroachment
problems has limited the use of training facilities and the gradual
accumulation of these problems increasingly threatens training readiness.
DOD has identified eight encroachment issues:

 Designation of critical habitat under the Endangered Species Act of 1973.
Under the act, agencies are required to ensure that their actions do not
destroy or adversely modify habitat that has been designated for endangered
or threatened species. Currently, over 300 such species are found on
military installations.

 Application of environmental statutes to military munitions. DOD believes
that the Environmental Protection Agency could apply environmental statutes
to the use of military munitions, shutting down or disrupting military
training. According to DOD officials, uncertainties about the future
application and enforcement of these statutes limit the officials? ability
to plan, program, and budget for compliance requirements.

 Competition for frequency spectrum. The telecommunications industry is
pressuring for the reallocation of some of the radio frequency spectrum from
federal to commercial control. DOD claims that over the past decade, it has
lost about 27 percent of the frequency spectrum allocated for aircraft
telemetry. And we previously reported that additional reallocation of
spectrum could affect space systems, tactical communications, and combat
training. 8

 Marine regulatory laws that require consultation with regulators when a
proposed action may affect a protected resource. Defense officials say that
the process empowers regulators to impose potentially stringent measures to
protect the marine environment from the effects of proposed training.

8 See U. S. General Accounting Office, Defense Spectrum Management: More
Analysis Needed to Support Spectrum Use Decisions for the 1755- 1850MHz
Band, GAO- 01- 795 (Washington, D. C.: Aug. 20, 2001).

Page 5 GAO- 02- 727T Military Training

 Competition for airspace. Increased airspace congestion limits pilots?
ability to train to fly as they would in combat.

 Clean Air Act requirements for air quality. DOD officials believe that the
act requires controls over emissions generated on DOD installations. New or
significant changes in range operations also require emissions analyses, and
if emissions exceed specified thresholds, they must be offset with
reductions elsewhere.

 Laws and regulations mandating noise abatement. DOD officials state that
weapons systems are exempt from the Noise Control Act of 1972, but DOD must
still assess the impact of noise under the National Environmental Policy
Act. As community developments have expanded closer to military
installations, concerns over noise from military operations have increased.
DOD officials report that pressure from groups at the local, regional, and
state levels can serve to restrict or reduce military training.

 Urban growth. DOD says that unplanned or ?incompatible? commercial or
residential development near training ranges compromises the effectiveness
of training activities. Local residents have filed lawsuits charging that
military operations lowered the value or limited the use of their property.

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 that units use to report readiness
against designed operational goals. 9 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 addition, DOD
is required under 10 U. S. C. 117 to prepare a quarterly readiness report to
Congress. The report is based on briefings to the Senior Readiness Oversight
Council, a forum assisted by the Defense Test and Training Steering Group.
In June 2000, the council directed the steering

9 Units use the Global Status of Resources and Training System to report
their readiness status monthly or whenever a change occurs in four resource
areas, including training. If a unit is not at the highest readiness level,
it must identify the reasons from a list that includes inadequate training
areas. Commanders may also include narrative statements with more detailed
explanations.

Page 6 GAO- 02- 727T Military Training

group to investigate encroachment and develop and recommend a comprehensive
plan of action.

The secretaries of the military services 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; and the Director, Operational
Test and Evaluation, provides advice on tests and evaluations.

Over time, the impact of encroachment on training ranges has gradually
increased. Because most encroachment problems are caused by population
growth and urban development, these problems are expected to increase in the
future.

Although the effects vary by service and by individual installation,
encroachment has generally 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 causes workarounds that
may limit the amount or quality of training. Installations overseas reported
facing similar training constraints.

Below are brief descriptions of some of the problems as reported by the
installations and organizations we visited in the continental United States.

 Marine Corps Base Camp Pendleton, California. Camp Pendleton officials
report encroachment problems related to endangered species and their
habitat, urbanization, air space, and noise. Recently, about 10 percent of
the installation has been designated as critical habitat for endangered
species. Airspace restrictions limit the number of days that weapons systems
can be employed, and noise restrictions limit night helicopter operations.

 Fort Lewis and the Yakima Training Center, Washington. Fort Lewis
officials report encroachment problems related to noise, air quality,
endangered species and their habitat, urbanization, frequency spectrum, and
munitions and munitions components. In response to Encroachment Has

Reduced Some Capabilities, and Its Effects Are Likely to Grow

Page 7 GAO- 02- 727T Military Training

local complaints, Fort Lewis voluntarily ceased some demolitions training.
Air quality regulations restrict the operation of smoke generators at Fort
Lewis. Habitat considerations restrict maneuvers and off- road vehicle
training in parts of both installations. There is periodic communications
interference.

 Nellis Air Force Base and Nevada Test and Training Range, Nevada.

Nellis Air Force Base has encroachment problems stemming from urbanization
and noise. Nellis officials said that urban growth near the base and safety
concerns have restricted the flight patterns of armed aircraft, causing
mission delays and cancellations. They also report that the two
installations receive a total of some 250 complaints about noise each year.

 Eglin Air Force Base, Florida. Eglin Air Force Base officials report
encroachment problems involving endangered species habitat, noise, urban
growth, and radio frequency spectrum. Eglin contains habitat for two
endangered species. Aircraft must alter flight paths to avoid commercial
towers and noise- sensitive areas. The base?s major target control system
receives frequency interference from nearby commercial operators.

 U. S. Atlantic Fleet. Atlantic Fleet officials report encroachment
problems stemming from endangered marine mammals and noise. Livefire
exercises at sea are restricted, and night live- fire training is not
allowed. Naval Air Station Oceana, Virginia, is the target of frequent noise
complaints.

 Special Operations Command. This command owns no training ranges of its
own and largely depends on others for the use of their training ranges. The
Navy component of the Special Operations Command reports being most directly
affected by encroachment from endangered species and urban development. A
variety of endangered species live on the training areas used by the Navy
Special Warfare Command in California, particularly on Coronado and San
Clemente islands. Because of 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. The Special Operations Command
has previously been able to mitigate deficiencies in local training areas by
traveling to alternate training sites. However, recent limitations on the
amount of time that units can spend away from their

Page 8 GAO- 02- 727T Military Training

home station 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.

DOD and military service officials said that many encroachment issues are
related to urbanization around military installations. They noted that most,
if not all, encroachment issues result from population growth and
urbanization and that growth around DOD installations is increasing at a
rate higher than the national average. According to DOD officials, new
residents near installations often view military activities as an
infringement on their rights, and some groups have organized in efforts to
reduce operations such as aircraft and munitions training. At the same time,
according to one Defense Department official, the increased speed and range
of weapons systems are expected to increase training range requirements. Our
recent report on training limitations overseas noted that, while some
restrictions are longstanding, the increase in restrictions facing U. S.
forces in many cases is the result of growing commercial and residential
development affecting established training areas and ranges. 10

Despite the loss of some training range capabilities, service readiness data
do not indicate that encroachment has significantly affected training
readiness. Even though in testimonies and during many other occasions DOD
officials have cited encroachment as preventing the services from training
as they would like, DOD?s primary readiness reporting system does not
reflect the extent to which encroachment is a problem. In fact, it rarely
cites training range limitations at all. Similarly, DOD?s quarterly reports
to Congress, which should identify specific readiness problems, hardly ever
mention encroachment as a problem. I should also note that our recent
assessment of training limitations overseas (which are often greater than
those found stateside) found that units abroad rarely report lower training
readiness in spite of concerns cited by DOD officials that training
constraints overseas can require work- arounds or in some instances prevent
training from being accomplished.

Although readiness reporting can and should be improved to address training
degradation due to encroachment and other factors, it will be difficult for
DOD to fully assess the impact of encroachment on its training

10 See GAO- 02- 525. Effects of

Encroachment on Training Readiness Are Not Reflected in Reported Data

Page 9 GAO- 02- 727T Military Training

capabilities and readiness without (1) obtaining more complete information
on both training range requirements and the assets available to support
those requirements and (2) considering to what extent other complementary
forms of training may help mitigate some of the adverse impacts of
encroachment. The information is needed to establish a baseline for
measuring losses or shortfalls.

A full assessment of the effects of encroachment on training capabilities
and readiness will be limited without better information on the services?
training range requirements and limitations and on the range resources
available to support those requirements. Each service has, to varying
degrees, assessed its training range requirements. For example, the Marine
Corps has completed one of the more detailed assessments among the services
concerning the degree to which encroachment has affected the training
capability of Camp Pendleton. The assessment determined to what extent Camp
Pendleton could support the training requirements of two unit types (a light
armored reconnaissance platoon and an artillery battery) and two specialties
(a mortar man and a combat engineer) by identifying the tasks that could be
conducted according 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 the training tasks
in the continuous scenario and from 75 to 92 percent of the tasks in the
fragmented scenario could be conducted according to standards. Some of the
tasks that could not be conducted according to standards were the
construction of mortar- and artillery- firing positions outside of
designated areas, cutting of foliage to camouflage positions, and terrain
marches. Marine Corps officials are completing a further analysis of four
other types of units or specialties at Camp Pendleton and said they might
expand the effort to other installations.

However, none of the services? studies have comprehensively reviewed
available range resources to determine whether assets are adequate to meet
needs, and they have not incorporated an assessment of the extent that other
types of complementary training could help offset shortfalls. We believe
that relying solely on the basis of live training, these assessments may
overstate an installation?s problems and do not provide a complete basis for
assessing training range needs. A more complete assessment of training
resources should include assessing the potential for using virtual

Page 10 GAO- 02- 727T Military Training

or constructive simulation technology to augment live training. 11 While
these types of complementary training cannot replace live training and
cannot eliminate encroachment, they may help mitigate some training range
limitations. Stated another way, these actions are not meant to take the
place of other steps to deal with encroachment, but they are key to more
fully depicting the net effects of encroachment on training capabilities now
and in the future.

Furthermore, to the extent that the services do have inventories of their
training ranges, they do not routinely share them with each other (or with
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 in nearby locations, increasing the risk of
inefficiencies, lost time and opportunities, delays, added costs, and
reduced training opportunities.

Although the services have been known to share 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, Maryland, 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 DOD- wide training
assets and capabilities would seem to be a logical step toward a more
complete assessment of training range capabilities and shortfalls that may
need to be addressed.

While some service officials have cited increasing costs because of
workarounds related to encroachment, the services? data systems do not
capture these costs in any comprehensive manner. At the same time, DOD?s
overall environmental conservation program funding, 12 which also

11 Virtual training uses simulation to replicate weapons systems and
settings.

Constructive training uses simulation to replicate units, weapons systems,
and terrain. 12 DOD?s Environmental Conservation Program funds numerous
activities, including endangered species management and preservation
programs, invasive species control, and inventories of natural and cultural
resources.

Page 11 GAO- 02- 727T Military Training

covers endangered species management, has fluctuated with only a modest gain
over the past 6 years, increasing in fiscal years 1996- 98, but then
dropping among all components, except for the Army. Total DOD conservation
program obligations fluctuated, increasing from $105 million in fiscal year
1996 to $136 million in fiscal years 1998- 99, and then decreasing to $124
million in fiscal year 2001. 13 DOD documents attribute the fluctuation in
conservation program obligations to increased costs from preparing
Integrated Natural Resource Management Plans.

Senior DOD officials recognized the need for a comprehensive plan to address
encroachment back in November 2000, but they have not yet finalized such a
plan.

The task was first given to a working group of subject matter experts, who
drafted plans of action for addressing the eight encroachment issues. The
draft plans include an overview and analysis of the issue, and current
actions being taken, as well as recommended 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.

 Developing assessment criteria to determine the cumulative effect of all
encroachment restrictions on training capabilities and readiness. 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
that these restrictions pose on training readiness has never been done.

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

13 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. Comprehensive Plan

for Addressing Encroachment Is Not Finalized

Page 12 GAO- 02- 727T Military Training

 Improving coordinated and collaborative efforts between base officials and
city planners and other local officials in managing urban growth.

At the time we completed our review, the draft action plans had not been
finalized. DOD officials told us that they consider the plans to be working
documents and stressed that many concepts remain under review and may be
dropped, altered, or deferred, while other proposals may be added. No
details were available on the overall actions planned, clear assignments of
responsibilities, measurable goals and time frames for accomplishing planned
actions, or funding requirements- information that would be needed in a
comprehensive plan.

Although DOD has not yet finalized a comprehensive plan of actions for
addressing encroachment issues, it has made progress in several areas. It
has taken or is in the process of taking a number of administrative actions
that include the following:

 DOD has finalized, and the services are tasked with implementing, a
Munitions Action Plan- an overall strategy for addressing the life- cycle
management of munitions to provide a road map that will help DOD meet the
challenges of sustaining its ranges.

 DOD formed a Policy Board on Federal Aviation Principles to review the
scope and progress of DOD activities and to develop the guidance and process
for managing special use air space.

 DOD formed a Clean Air Act Services? Steering Committee to review emerging
regulations and to work with the Environmental Protection Agency and the
Office of Management and Budget to protect DOD?s ability to operate.

 DOD implemented an Air Installation Compatible Use Zone Program to assist
communities in considering aircraft noise and safety issues in their land-
use planning.

 DOD is drafting a directive that establishes the department?s policy on
the 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 and direct increased emphasis on
outreach and coordination efforts with local communities and stakeholders.
In addition, the department

Page 13 GAO- 02- 727T Military Training

is preparing separate policy directives to establish a unified noise
abatement program and to specify the outreach and coordination requirements
highlighted in the sustainable ranges directive.

DOD is also seeking legislative actions to help deal with 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 legislative and
regulatory set of proposals by January 2002. The team agreed on a set of
possible legislative proposals for some encroachment issues. After internal
coordination deliberations, the proposals were submitted in late April 2002
to Congress for consideration. According to DOD, the legislative proposals
seek to ?clarify? the relationship between military training and a number of
provisions in various conservation statutes, including the Endangered
Species Act, the Migratory Bird Treaty Act, the Marine Mammal Protection
Act, and the Clean Air Act. DOD?s proposals would, among other things, do
the following:

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

 Permit DOD to ?take? 14 migratory birds under the Migratory Bird Treaty
Act without action by the Secretary of the Interior, where the removal would
be in connection with readiness activities, and require DOD to minimize the
removal 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. 15

14 The term ?take? means to harass, harm, pursue, hunt, shoot, wound, kill,
trap, capture, collect, or to attempt to engage in any such conduct. 15 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 that has the potential to injure
or disturb a marine mammal by causing disruption to behavioral patterns such
as migration, breathing, nursing, breeding, feeding, and sheltering.

Page 14 GAO- 02- 727T Military Training

 Modify the conformity provisions of the Clean Air Act. The proposal would
maintain the department?s obligation to conform 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.

These proposals reflect the needs identified by DOD?s draft action plans and
appear to be one step by the department toward developing a comprehensive
approach to managing encroachment issues that affect military training
ranges. The consideration of these legislative proposals affecting existing
environmental legislation will require Congress to consider potential trade-
offs among multiple environmental policy objectives and their impact on
military training.

We have recommended that DOD develop and maintain inventories of its
training ranges, capacities, and capabilities; finalize a comprehensive plan
of administrative actions that includes goals, timelines, projected costs,
and the clear assignment of responsibilities for addressing encroachment
issues; and periodically report on progress in addressing encroachment
issues. Our recently issued report on overseas training also recommended
that DOD develop reports that accurately capture the causes of training
shortfalls and objectively report units? ability to meet their training
requirements.

This concludes my statement. I would be pleased to answer any questions that
you or other members of the Committee may have at his time.

For further contacts regarding this statement, please contact Barry Holman
on (202) 512- 8412. Individuals making key contributions to this statement
include Glenn Furbish, John Lee, Mark Little, Stefano Petrucci, James Reid,
and John Van Schaik. Contact and

Acknowledgement

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