Environmental Compliance: Better DOD Guidance Needed to Ensure	 
That the Most Important Activities Are Funded (17-JUN-03,	 
GAO-03-639).							 
                                                                 
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.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-639 					        
    ACCNO:   A06901						        
  TITLE:     Environmental Compliance: Better DOD Guidance Needed to  
Ensure That the Most Important Activities Are Funded		 
     DATE:   06/17/2003 
  SUBJECT:   Defense cost control				 
	     Environmental monitoring				 
	     Environmental policies				 
	     Military cost control				 
	     Military policies					 
	     Policy evaluation					 
	     Environmental law					 

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GAO-03-639

Report to Congressional Committees

United States General Accounting Office

GAO

June 2003 ENVIRONMENTAL COMPLIANCE

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

GAO- 03- 639

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. 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 should establish a more specific policy on which activities are
eligible for funding through the environmental quality program

and how such activities should be prioritized and funded. The military
services should revise their policies and processes to conform to the
revised DOD policy. DOD did not provide comments on these recommendations
as of the issuance date of this report.

www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 639. To view the full product,
including the scope and methodology, click on the link above. For more
information, contact Anu K. Mittal at (202) 512- 3841 or mittala@ gao.
gov. Highlights of GAO- 03- 639, a report to the

Senate and House Committees on Armed Services June 2003

ENVIRONMENTAL COMPLIANCE

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

Page i GAO- 03- 639 DOD Environmental Compliance Letter 1 Results in Brief
2 Background 4 DOD*s and the Services* Policies and Processes Do Not

Always Ensure That the Most Important and Appropriate Environmental
Quality Activities Are Funded 9 Conclusions 22 Recommendations for
Executive Action 22 Agency Comments and Our Evaluation 23 Appendix I Scope
and Methodology 24

Appendix II GAO Contacts and Staff Acknowledgments 26

Figure

Figure 1: DOD*s Environmental Quality Funding, Fiscal Year 2002 5
Abbreviations

DOD Department of Defense GAO General Accounting Office NEPA National
Environmental Policy Act Contents

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Page 1 GAO- 03- 639 DOD Environmental Compliance

June 17, 2003 The Honorable John W. Warner Chairman The Honorable Carl
Levin Ranking Minority Member Committee on Armed Services United States
Senate

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

The Department of Defense (DOD) and its military services* the Air Force,
Army, Navy, and Marine Corps* must comply with a broad spectrum of
federal, state, and local environmental laws, regulations, and executive
orders that apply to the lands they manage, including more than 425 major
military installations covering approximately 25 million acres across the
United States. Through its environmental quality program, DOD spends about
$2 billion per year to comply with environmental

requirements that address (1) routine activities to ensure environmental
compliance, such as the proper disposal of hazardous waste; (2) pollution
prevention activities; and (3) a wide range of conservation activities,
including the preservation of prehistoric sites and the protection of more
than 300 endangered plant and animal species found on installations. To
ensure that the environmental quality program funds the most important and
appropriate activities, DOD has developed a general policy for the
military services to follow in identifying, prioritizing, and funding
environmental quality activities. In turn, each military service has
established its own policy or guidance to implement the environmental
quality program across its installations.

Although the services have, over the past decade, made significant
improvements in their environmental compliance record, according to DOD*s
estimates these improvements have leveled off in recent years and DOD has
not yet reached its goal of full environmental compliance. In

response to provisions of the Senate Armed Services Committee*s report on
the National Defense Authorization Act for Fiscal Year 2002, we

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 03- 639 DOD Environmental Compliance

assessed DOD*s and the military services* policies and processes for
identifying, prioritizing, and funding their environmental quality
activities, including unexpected or emergency needs, to determine the
extent to

which these processes and practices ensure that the most important and
appropriate activities are funded.

As part of our work, we reviewed policies and procedures established by
DOD and the services to guide implementation of the environmental quality
program. We also visited 11 military installations to review how they were
implementing the program and reviewed the environmental funding requests
for fiscal years 1999 through 2001 for these 11 and another 4
installations. 1 We selected these installations based on their large
environmental budgets and because they represent a range of major
commands, missions, and geographic locations. Our observations about

individual projects or activities at these installations are not
generalizable to projects or activities at all military installations. We
conducted our work between May 2002 and May 2003 in accordance with
generally accepted government auditing standards. A more detailed
description of our review scope and methodology is in appendix I.

The Department of Defense*s and the military services* policies and
processes for the environmental quality program do not always ensure that
the most important and appropriate environmental activities are funded.
Instead, we found that some installations had funded low- priority
activities or ones that were ineligible under their policies, such as pest
management and roof replacement, at the same time that higher- priority
activities were not funded. At the root of the problem is DOD*s broad
program policy that does not provide specific guidance on what activities
are eligible for the program and the resulting inconsistent interpretation
and implementation of this policy by the military services. The variations
among the services* programs can result in different eligibility
requirements for environmental activities across the services.

1 The installations we visited include the Air Force*s Eglin Air Force
Base and Vandenberg Air Force Base; the Army*s Fort Bliss, Fort Campbell,
and Fort Carson; the Marine Corps* Camp Lejeune and Camp Pendleton; and
the Navy*s Mid- Atlantic Region (Naval Station Norfolk and Naval Weapons
Station Yorktown) and Southwest Region (Naval Air Station North Island and
Naval Station Point Loma). At the two Navy regions, we reviewed
environmental funding requests for Naval Station Norfolk, Naval Air
Station Oceana, Naval Weapons Station Yorktown, Naval Amphibious Base
Little Creek, Naval Station San Diego, Naval Air Station North Island,
Naval Base Point Loma, and Naval Auxiliary Landing Field San Clemente
Island. Results in Brief

Page 3 GAO- 03- 639 DOD Environmental Compliance

For example, under the Air Force*s and the Army*s policies, the cleanup of
oil and hazardous substance spills is eligible for environmental quality
program funding, while the Navy and Marine Corps require the organization
responsible for the spill to pay the cleanup costs. The variations can
also result in funding activities through the environmental quality
program that may be more closely related to military operations or base
maintenance. For example, at some installations we visited the
environmental quality program funded routine maintenance activities.
Without a consistently implemented approach, there is no assurance that
DOD*s requirement for funding all high- priority environmental activities
is being met. We found that the services have not always been able to fund
all high- priority activities through the environmental quality program
and in some cases the installations we visited had to defer certain
environmental activities when funding was not available. Moreover, the
installations we visited were able to fund their emergency, unbudgeted,
high- priority environmental activities by redirecting funds from other

activities such as base maintenance. Some services indicated that this
situation is likely to worsen in the future with expected reductions in
their budgets for the program. Such constraints make a well- implemented
prioritization process even more important.

Because the broad nature of DOD*s policy and the resulting differences in
program implementation among the military services make it difficult to
ensure that the most important and appropriate environmental activities
are being funded, we are making recommendations to DOD aimed at
establishing a more specific policy on which activities are eligible for
environmental quality program funding and how such activities should be
prioritized and funded. Further, we are recommending that once the
department revises its policy, the services should update their own
policies and processes to ensure consistency with the revisions.

We provided DOD with a draft of this report for review and comment. DOD
provided technical clarifications, which we incorporated as appropriate.
However, DOD did not provide overall comments as of the issuance date of
this report.

Page 4 GAO- 03- 639 DOD Environmental Compliance

DOD*s operations at military installations and other defense sites in the
United States are subject to the same environmental laws and regulations,
such as the Clean Air Act and the Clean Water Act, as is private industry.
2 Additionally, DOD policy calls for its organizational components to
achieve, maintain, and monitor compliance with all applicable executive
orders, as well as all federal, state, and local statutory and regulatory
requirements.

DOD has an environmental quality program to address these requirements,
which fall into three main categories: (1) environmental compliance
activities; (2) pollution prevention activities; and (3) conservation
activities, such as the protection of natural and cultural resources
present on military installations. 3 DOD has developed and implemented
policies for activities in each major program category. 4 By far, the
majority of DOD*s investment in its environmental quality

program is for its environmental compliance requirements. For example, in
fiscal year 2002, about 81 percent of DOD*s investment of more than $2
billion in the environmental quality program was for compliance
activities, including personnel costs for the entire program; 11 percent
was for pollution prevention; and 8 percent was for conservation
activities. (See fig. 1.)

2 Other requirements and policies apply to DOD*s activities overseas and
to Navy ships at sea; these are outside the scope of this review. 3 In
addition to its environmental quality program, DOD has a program focusing
on the cleanup of contamination associated with past DOD activities. This
program, known as the Defense Environmental Restoration Program, was
established by section 211 of the Superfund Amendments and Reauthorization
Act of 1986. Under the environmental

restoration program, DOD is authorized to identify, investigate, and clean
up environmental contamination at active or closing military
installations, and on land that DOD formerly owned or leased. Funding for
environmental restoration activities is provided through Component
Environmental Restoration accounts; activities funded through these
accounts are outside the scope of our review.

4 See Department of Defense Instruction (DODI) 4715. 3, Environmental
Conservation Program, May 3, 1996; DODI 4715.4, Pollution Prevention, June
18, 1996; and DODI 4715.6,

Environmental Compliance, April 24, 1996. Background

Page 5 GAO- 03- 639 DOD Environmental Compliance

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

a Compliance includes personnel costs for the entire environmental quality
program. Funding allocated to the environmental quality program in recent
years has come largely from DOD*s appropriation for operation and
maintenance activities. 5 This appropriation account funds a diverse set
of activities, including military training, depot maintenance, base
operations 5 In recent years, DOD*s operation and maintenance account has
funded about 77 percent of the environmental quality program. About 23
percent of environmental program funding in recent years has been from
other DOD accounts, including the Defense Working Capital

Funds, the procurement accounts, and the military construction account.

Page 6 GAO- 03- 639 DOD Environmental Compliance

support, and real property maintenance. 6 The funding allocated to the
environmental quality program from the operations and maintenance account
may be used for other, nonenvironmental, purposes as needed by the
services or installations. For example, once funding for operations and

maintenance activities, including environmental quality activities, has
been allocated to an installation commander, the commander has the
authority to use these funds as necessary for the needs of the
installation. Likewise, if funding allocated to an installation by the
service or the major command for environmental quality activities is not
sufficient to ensure that the installation remains in compliance with its
environmental requirements,

the installation commander has the authority to reallocate funds to the
environmental quality program. Installation commanders are responsible for
ensuring that their

installations are in compliance with environmental requirements. The
installations are responsible for identifying all regulations and other
environmental requirements that apply to them, and identifying and
tracking pending requirements. 7 To carry out their environmental
responsibilities, the installation commanders are typically supported by
an environmental program office, including staff with expertise in various
environmental areas such as air, water, or hazardous waste. Managers

for these areas are responsible for identifying current and pending
environmental requirements applicable at their installation. Additionally,
DOD has regional environmental offices that assist installations in
identifying current and pending environmental requirements, particularly
at the state and local levels.

6 In fiscal year 2002, DOD replaced its real property maintenance program,
which had been funded through the operations and maintenance
appropriation, with two distinct activities and accounting structures: (1)
sustainment and (2) restoration and modernization. Sustainment funds,
which come primarily from the operations and maintenance appropriation,
cover expenses for all recurring maintenance costs and contracts, as well
as for major repairs of nonstructural components (e. g., replacing a roof
or repairing an air- conditioning system). Restoration includes repair and
replacement work to restore facilities damaged by inadequate sustainment,
excessive age, natural disaster,

fire, accident, or other causes. Modernization includes altering, or
modernizing, facilities to meet new or higher standards, accommodate new
functions, or replace structural components. Restoration and modernization
activities are funded through both the

operations and maintenance appropriation and the military construction
appropriation. For more information on these topics, see U. S. General
Accounting Office, Defense Infrastructure: Changes in Funding Priorities
and Strategic Planning Needed to Improve the Condition of Military
Facilities, GAO- 03- 274 (Washington, D. C.: Feb. 2003).

7 In the Navy, these responsibilities are performed by regional
environmental offices rather than by offices associated with each
installation.

Page 7 GAO- 03- 639 DOD Environmental Compliance

Officials at each installation develop a list of planned activities, along
with the priority levels and estimated costs of these activities, for the
installation*s environmental quality program for the upcoming 6 fiscal
years. The greatest emphasis and detail is provided for those activities
for funding in the first 2 fiscal years, called the budget years.

DOD*s environmental quality policy uses the following classification
system to prioritize environmental activities:

 Class 0 activities are recurring activities needed to keep an
environmental program running and meet compliance requirements, such as
employee salaries, costs of environmental permits, and office supplies.

 Class I activities are nonrecurring projects and activities that must be
funded in the current program year (and, in some cases, up to several
years in the future to complete the project or activity) to correct
noncompliance with an environmental requirement or to ensure that the
installation will remain in compliance.

 Class II activities are those that have compliance deadlines, but these
deadlines will not occur until after the current budget year.

 Class III activities are typically referred to as *nice to have*
activities that address overall environmental goals and objectives, but
are not necessary for an installation to remain in compliance with
environmental requirements.

Based on DOD*s policy, the services have developed prioritization systems
for making funding decisions. Consistent with DOD policy, Army and Air
Force policies specify that Class 0 and Class I activities must be funded.
8 Similarly, the Navy and Marine Corps also have a policy of funding all
Class 0 and I activities, according to service officials, but their
official program policy guidance does not mention this. Consistent with
DOD policy, the services also require that selected Class II activities be
funded in time to ensure compliance with future requirements. None

of the services* policies require funding of Class III activities. In this
report, *must fund* Class 0 and I activities are referred to as high-
priority activities.

8 The Air Force and Navy use the term *level* rather than *class*; in this
report, however, the term *class* will be used to describe all of the
services* priority levels.

Page 8 GAO- 03- 639 DOD Environmental Compliance

DOD*s policy does not differentiate among activities within Class 0 and
Class I. For example, because any unfunded Class I activity will result in
noncompliance with an environmental requirement, all Class I activities
have equal weight as *must fund* activities, according to DOD*s policy.
However, in addition to the priority categories described above, some
major commands have developed their own, more detailed prioritization

approaches to help ensure that the most important environmental activities
will be funded before other, less important activities within the same
class. These approaches are intended to rank proposed environmental
activities by their relative importance. These approaches emphasize
somewhat different considerations, such as the risk of harm to human
health or the environment should an activity not be funded, or the risk of
receiving a notice of violation from a regulator if the installation is
out of compliance with an environmental requirement.

After the environmental program*s staff has identified, prioritized, and
estimated the costs of proposed activities, the list of proposed
activities may be reviewed by other installation officials, such as legal
staff or the installation commander. The list is then forwarded to the
next higher command level for its approval. For the Air Force, Army, and
Navy, this next higher level is the major command, 9 while Marine Corps
installations forward their proposed environmental budgets directly to
their environmental program*s headquarters. In some cases, the major
command disagrees with the priority level that an installation assigned to
an activity or the funding level that the installation requested. The
command, or headquarters, in the case of the Marine Corps, may disapprove,
or *invalidate,* a proposed activity for environmental funding, revise the
funding level estimate (either up or down), or change the priority level.
The major command consolidates the requests from each installation under
its authority, then submits a commandwide request to its service
headquarters. The service headquarters are involved to differing degrees
in reviewing

the details of the installations* environmental requests. The Air Force*s
environmental staff rely on the reviews of individual proposed activities
by their major commands. As mentioned above, the Marine Corps*
environmental office is involved in assessing and prioritizing proposed

9 The Navy refers to its higher command level as a *claimant*; however,
for the purposes of this report, the term major command will be used.
Beginning in fiscal year 2004, the Army*s new Installation Management
Agency will serve as the next level for reviews of the Army*s
environmental quality program.

Page 9 GAO- 03- 639 DOD Environmental Compliance

activities at installations. The Navy*s environmental staff reviews
proposed activities to assess whether they are legally required to
undertake them, whether the cost estimates are reasonable, and whether the
proposed time frames for completing the activities are realistic. The
Army*s environmental staff reviews selected environmental activities that
were approved by the major commands. Army headquarters officials told us
that they expect to expand their review to all activities approved by
their major commands now that they have automated their database of
proposed environmental activities. Next, the Office of the Secretary of
Defense reviews the environmental

quality program budget requests. The Secretary*s office does not review
these budgets on a project- by- project basis; instead, its review focuses
on the services* overall environmental compliance track records and
whether the proposed budgets will serve to continue to improve each
service*s compliance performance. Finally, the estimates for the
environmental quality program budget are incorporated into each service*s
estimate of its overall needs, and DOD*s overall budget request is
included in the annual presidential budget request to the Congress. 10
Based on broad DOD policy, each military service has established its own

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

10 This process, which DOD calls its Planning, Programming, and Budgeting
System, or PPBS, takes about 2 years from planning to execution. For more
information on this process, see Congressional Research Service, A Defense
Budget Primer, Dec. 9, 1998. DOD*s and the

Services* Policies and Processes Do Not Always Ensure That the Most
Important and Appropriate Environmental Quality Activities Are Funded

Page 10 GAO- 03- 639 DOD Environmental Compliance

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

Although the services have developed policies intended, in part, to
clarify which activities can be funded through the environmental quality
program, implementation of these policies has sometimes led to
inconsistencies across the services in the types of activities they
determine eligible for funding. Also, some of the services or their
organizational components have developed additional guidance to assist
installations in determining whether certain activities can be funded
through their environmental quality programs. For example, the Air Force*s
Environmental Quality Programming Matrix provides an extensive listing of
activities and indicates whether or not each is valid for environmental
quality program funding. The Navy*s Pacific Fleet has similarly developed
guidance, its

Policy on Environmental Issues Matrix, to help clarify what is eligible
for environmental funding. The Pacific Fleet*s guidance also indicates who
should pay for activities that are not eligible for environmental quality
program funding, something that the Air Force matrix does not address.

While these efforts to provide additional guidance are helpful to the
individual services* environmental quality program managers, they do not
address or resolve the cross- service inconsistencies on what activities
are

eligible for funding. For example, we found the following differences in
program eligibility:

 Environmental impact statements. Under the National Environmental Policy
Act (NEPA), the military services are required to assess the environmental
effect of their major proposed actions, such as new construction or
certain military training on their installations. The Navy*s and Air
Force*s environmental quality programs consider NEPA- required
environmental assessments or environmental impact statements as high-
priority environmental activities. In fiscal year 2002, for example, the
Navy*s environmental quality program spent $17.8 million to comply with
NEPA requirements. In contrast, the Marine Corps* and Army*s policies
generally do not treat NEPA requirements as eligible for environmental The
Services* Varying

Interpretations of DOD*s Broad Policy Have Resulted in Inconsistent
Eligibility Criteria and Funding of Activities More Closely Related to
Military Operations or Maintenance

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

Page 11 GAO- 03- 639 DOD Environmental Compliance

quality program funding. However, the Army*s environmental quality program
will pay for some NEPA oversight and assistance activities such as
training for environmental quality program staff. The Marine Corps* policy
requires that the organizations whose actions trigger NEPA requirements
pay for NEPA- related expenses; only in the case that a project is
environmentally driven does the Marine Corps policy allow environmental
quality program funds to be used to pay for NEPA- related expenses.

 Historic rehabilitation. The Marine Corps* environmental quality
program, which includes conservation of historic resources, requires
installations to protect their properties that are listed on the National
Register of Historical Places. For example, the Marine Corps*
environmental quality program spent nearly $800, 000 to restore an adobe
ranch house on Camp Pendleton in southern California that was built in
1890 and had been listed by the National Trust for Historic Preservation
as one of the most endangered historic structures in the nation. Camp
Pendleton*s environmental quality program is restoring the adobe and
plaster house and farm buildings to their 1905 appearance. The restoration
includes earthquake- proofing the structures as well as stabilizing the
walls, floors, and roof. Marine Corps policy allows the environmental
quality program to fund such activities because of the National Historic
Preservation Act*s protection and preservation requirements. In contrast,
Air Force policy does not consider the *maintenance and repair of National
Register listed or eligible buildings, structures or objects* as a valid
use of environmental quality program funds. Likewise, the Navy*s and the
Army*s environmental quality programs do not fund the repair, maintenance,
or rehabilitation of historic structures or properties, although the
Army*s program will fund the preparation of plans for the repair,
maintenance, and rehabilitation of such structures.

 Oil and hazardous material spills. While all four services pay for plans
to prevent and/ or respond to oil and hazardous material spills and for
spill cleanup equipment, only the Air Force*s and Army*s environmental
quality programs pay for the actual cleanup. While the Navy and Marine
Corps are liable under various federal and state laws to fund spill
cleanups, they would likely use other operating funds for such cleanups.
Typically, the organization that caused the spill would be expected to
fund the cleanup. In contrast, the Air Force*s and Army*s environmental
quality programs will pay for spill cleanups, but headquarters officials
from both services

told us that they encourage their environmental managers to seek
reimbursement for spill cleanup costs from the unit that caused the spill.

Page 12 GAO- 03- 639 DOD Environmental Compliance

The services* broad interpretations of eligibility for their environmental
quality programs have allowed installations to use the environmental
quality program to fund activities that may have been more closely related
to military operations or maintenance.

For example, we noted the following:  Bird/ Aircraft Strike Hazard
program. In fiscal year 2001, the Navy

spent about $147,000 of environmental quality program funds to support an
activity whose primary purpose is to ensure the safety of Navy pilots and
aircraft at Naval Air Station North Island and a landing field at Imperial
Beach. The purpose of this program is to reduce the risk of damage or loss
that can occur when birds or other animals are hit by, or caught in,
military aircraft during military operations. The Navy justified this
activity as part of its environmental quality program because 1 of the 15
species of birds that pose a risk to aircraft is a federally listed
endangered species and another is a threatened species. However, as
clearly stated in the project description, the primary purpose of the
activity is to control wildlife in order to protect aircraft. In contrast,
other services require such activities to be funded by the organizations
responsible for flight operations and not through the environmental
quality programs.

 Wildfire suppression. The Navy has used environmental quality program
funds to pay for the use of a helicopter to suppress wildfires caused by
military operations, specifically by naval gunfire training on San
Clemente Island, a Navy- owned island off the coast of southern
California. Although Navy helicopters have the primary responsibility to
be on standby to provide firefighting support when training ranges are in
use, these helicopters are not always available. To meet its fire
suppression needs when its helicopters are not available, the Navy has
contracted with a private company for helicopter support. During the last
4 years the Navy has spent an average of $150,000 per year in
environmental quality program funds to pay for this activity. The Navy
justifies the activity as an environmental expense because wildfires could
harm the 10 endangered

species on the island. Nevertheless, the fires are the direct result of
the Navy*s gunfire training activity, and funds for addressing the
negative consequences of its actions normally come from the activity*s
sponsor. It is unclear why this activity is treated differently from the
case of hazardous spills discussed previously, in which the Navy requires
the organization that caused the spill to pay for the cleanup.

 Roofs for drinking water reservoirs. The Marine Corps* environmental
quality program has replaced the roofs on six drinking water reservoirs at
Some Activities Funded

Through the Services* Environmental Quality Programs Are More Closely

Related to Military Operations or Maintenance

Page 13 GAO- 03- 639 DOD Environmental Compliance

Camp Pendleton, at an estimated total cost of $4.7 million. According to
officials from Camp Pendleton*s comptroller*s office, the installation has
a backlog of more than $190 million in facility maintenance and repair
needs. Because this maintenance and repair activity had an environmental
connection* the repairs were needed to prevent animals from contaminating
the base*s water supply and to avoid violating the Safe

Drinking Water Act* installation officials decided to fund this activity
through the Marine Corps* environmental quality program.

Several environmental officials acknowledged that characterizing certain
activities as environmental, or *painting them green,* rather than as
facility maintenance, restoration, or modernization improves the chance of
their being funded. According to these officials, installations may seek
to fund

maintenance and infrastructure projects through the environmental quality
program because of the overall shortage of funds for facility maintenance,
restoration, and modernization. According to DOD officials, funding for
facility maintenance has been inadequate for many years, resulting in
deteriorated facilities at many installations.

The Air Force has tried to limit the use of environmental quality program
funds for maintenance and repair activities by establishing a policy on
funding infrastructure- related activities. The policy states that
environmental quality program funds can only be used to construct, modify,
or upgrade facilities or systems needed to comply with new environmental
laws and regulations. Such facilities or systems should be maintained,
repaired, or replaced using other funds. However, if a regulator or major
command determines that an installation is out of compliance with an
environmental requirement, an infrastructure project may be eligible for
environmental quality funding. The policy includes a list of typical
infrastructure projects, indicating whether they are eligible for
environmental quality program funding. In commenting on a draft of the
infrastructure policy, the Air Force Space Command raised concerns

about the policy*s possible negative effect on installations* ability to
remain in compliance with environmental requirements. According to a
senior environmental official at the command, the Air Force*s
infrastructure policy, although well intentioned, is unrealistic because
funding for repair and maintenance activities has been insufficient for
many years. We have long noted DOD*s need for improved facilities
management,

and since 1997 we have identified DOD infrastructure management as a high-
risk area. Recently, we reported that the military services have not made
maintaining and improving their facilities a funding priority because

Page 14 GAO- 03- 639 DOD Environmental Compliance

these needs must compete with other programs, such as force readiness and
the day- to- day costs of operating an installation. 11 Certain low-
priority activities were funded through the environmental

quality program at two Army installations we visited, even though some
high priorities, considered *must fund* activities by DOD and Army policy,
were not funded. Moreover, at two installations we visited, we found that
the environmental quality programs had funded some activities that were
ineligible to receive funding under their policies. For two Army
installations we visited, the major command did not

provide environmental quality program funding for all *must funds,* Class
0 and I activities, yet funded some lower- priority, Class III activities.
12 For example, the Fort Carson environmental director told us that the
percentage of funds received for validated Class 0 and I activities
dropped from about 90 percent in fiscal year 2000 to about 50 percent in
fiscal year 2002. At the same time, the command provided Fort Carson

with $104,000 in environmental quality program funds for three
lowerpriority, Class III activities in fiscal year 2002. Similarly, at
Fort Campbell, the funding rate for Class 0 and I activities averaged 70
percent of the amount required, according to installation officials. For
example, we determined that Fort Campbell received about $16 million, or
77 percent of its high- priority requirements (defined as Class 0 and I
activities) in fiscal year 2001, but at the same time the command provided
$600,000 in environmental quality program funds to Fort Campbell for five
lowerpriority,

Class III activities. Some examples of high- priority activities not
funded at these two installations, and the lower- priority activities that
were funded by the major command, include the following:

11 U. S. General Accounting Office, Defense Infrastructure: Changes in
Funding Priorities and Strategic Planning Needed to Improve the Condition
of Military Facilities, GAO- 03- 274 (Washington, D. C.: Feb. 2003).

12 Class 0 consists of recurring activities (i. e., activities typically
funded each year) needed to keep an environmental program running and meet
compliance requirements, such as employee salaries and office supplies.
Class I consists of nonrecurring activities that are needed to either
maintain or restore compliance with an environmental law, regulation, or
other requirement. Class II activities have compliance deadlines, but
these deadlines will not occur until after the budget year. In some cases,
certain Class II activities are considered *must fund* priorities if they
must be initiated in the current year in order to ensure that a future
compliance deadline can be met. Class III consists of activities that are

not required by a specific environmental requirement that an installation
must comply with, but are intended to improve the environment. The
Services Do Not

Always Ensure That Funding Is Targeted to the Highest Priority
Environmental Activities, and in Some Cases, Have Funded Activities That
Are Ineligible Under Their Policies

Page 15 GAO- 03- 639 DOD Environmental Compliance

 In fiscal year 1999, U. S. Forces Command did not provide funding for
certain Class 0 and I activities at Fort Campbell such as hardware and
software upgrades to automate program management; drinking water resource
assessment and planning; and a firebreak redesign to control soil erosion
entering streams. However, during the same year, the command provided
funding for certain Class III activities at the installation, such as
noise monitoring, minimization of construction debris by crushing for

reuse as aggregate, and asbestos sampling and analysis. Ultimately, Fort
Campbell was able to fund two of the high- priority activities in 1999, by
using funds from other environmental activities or from outside the
environmental quality program.  In fiscal years 1999 through 2002, U. S.
Forces Command did not provide

environmental funds for certain Class 0 and I activities at Fort Carson,
such as removal of an underground storage tank from an abandoned landfill;
watershed management, including repair of erosion control structures; and
a survey of industrial sources and sanitary facilities, such as oil/ water
separators and septic system. However, during the same time period, the
command provided funding for Class III activities at Fort Carson, such as
radon sampling; replacement of a septic system on a training encampment
with a connection to a sewage system; and the purchase and planting of
seeds to reintroduce native plant species to re- vegetate burned and other
environmentally disturbed areas.

As illustrated by these examples, U. S. Forces Command has considered
factors other than those included in DOD*s and the Army*s policies on
prioritization when making funding decisions. Some considerations that the
command used included whether (1) failure to fund the activity would
result in an adverse impact on the installation*s military mission, (2)
the activity could significantly reduce pollution, and (3) the activity is
expected to provide a significant return on investment. These
considerations resulted in the command*s funding activities that were
lower priorities under DOD*s and the Army*s classification systems, while
not funding high priorities as defined by these systems. According to the
director of the Army*s environmental programs, the Installation

Page 16 GAO- 03- 639 DOD Environmental Compliance

Management Agency 13 will not use the major command*s approach for making
funding decisions. Instead, the agency will always fund high- priority
activities, as defined by DOD and Army policy, before funding Class III
activities.

Consistent with our findings at selected installations, the Army Audit
Agency has reported that some Army installations have not funded all high-
priority activities while at the same time funding lower- priority
activities. In December 1999, the agency reported that of 234
environmental activities it reviewed at Army installations, the
installations did not fund 55 activities classified as high priorities,
while installations funded 13 other projects that were not classified as
high priorities. 14 The Army Audit Agency recommended that the Army
reinforce the need to comply with its policy to fund high- priority
activities.

Moreover, some of the activities funded through the environmental quality
program at two of the installations we visited were prohibited by service
policy from receiving funds through this program. Specifically, we found
the following:

 Pest management. The environmental quality program at Fort Carson funded
pest management as a recurring, high- priority activity for a number of
years because base operating funds for this activity had not been
available, according to the installation*s environmental quality program
manager. This official told us that pest management is eligible for

environmental quality program funding because chemicals are used to
perform the work. However, our review of the Army*s program policy
indicates that application of chemical pesticides for pest control is not
eligible for environmental quality program funding, and officials from the
Army*s Installation Management Agency agreed that this activity should not
have been funded using environmental quality program funds.

13 In October 2002, the Army established the Installation Management
Agency to oversee all components of installation support, including
environmental programs. Previously, installation funding (including
environmental funding) was routed through the Army*s major commands to
individual installations. In some cases, this resulted in some

installations receiving a fraction of their total budget because major
commands withheld funds and unexpected mission priorities arose. Under the
new agency structure, installation funding (including environmental
funding) will go directly from the agency to the installations. This new
funding system will go into effect in fiscal year 2004.

14 U. S. Army Audit Agency, Execution of Environmental Projects, December
1999.

Page 17 GAO- 03- 639 DOD Environmental Compliance

 Landscaping for a hazardous waste storage facility. Fort Carson used
environmental quality program funds to pay for maintenance and repair,
including landscaping, of a hazardous waste storage facility located on
the installation. Fort Carson officials said that the landscaping was
included as part of a larger activity* maintaining the hazardous waste
storage facility* which is eligible for environmental funding. According
to the Fort Carson environmental director, the installation has generally
not had funds available from base operations accounts to fund base support

activities such as this. However, our review of Army environmental policy
indicates that environmental funding for routine grounds maintenance *such
as grass mowing, tree pruning, and landscaping performed for the purpose
of aesthetics* is specifically excluded. Officials from the Army*s
Installation Management Agency agreed that landscaping should not have
been funded using environmental quality program funds. Further, these

officials as well as the director of environmental programs for the Army
said that the entire activity should not have been funded using
environmental quality program funds because routine repair and maintenance
activities are more appropriately funded through the maintenance account.

 Restoration and maintenance of a historic structure. Vandenberg Air
Force Base has used environmental quality program funds to refurbish its
Space Launch Complex 10, which the National Park Service had designated as
*the best surviving example of a launch complex built in the 1950s at the
beginning of the American effort to explore space.* The National Park
Service also listed the site as one of America*s most endangered historic
landmarks. The Air Force*s environmental quality program spent $925,000 on
this activity during fiscal years 2000 through 2002; the restoration is
expected to take 8 years to complete, at an estimated total cost of more
than $2 million. However, as previously mentioned, Air Force policy
specifically prohibits the use of environmental funds for the maintenance
and repair of historic landmarks.

A senior environmental official from Vandenberg Air Force Base*s major
command, the Air Force Space Command, explained that it can be difficult
to obtain funding for repair and maintenance of historic structures,
particularly if they are vacant. Installations* sustainment, restoration,
and modernization programs typically assign a lower funding priority to
vacant historic structures than to structures that have a direct impact on
the installations* overall missions. Given that no other funding source on
base is likely to maintain and restore historic properties, it often falls
to the environmental quality program to carry out these conservation
responsibilities, according to this official, despite their ineligibility
under Air Force policy. The official further noted that legal counsel for
the

Page 18 GAO- 03- 639 DOD Environmental Compliance

command*s environmental office has advised the environmental quality
program to repair and maintain historic structures to avoid *demolition by
neglect* and to avoid violating the National Historic Preservation Act.

 Roof repair. In fiscal year 2001, Fort Carson used $12,000 of
environmental quality funds to repair a roof on a historic ranch house,
according to installation resource management officials. The ranch house
was being used by environmental quality program staff and students
performing environmental research, according to the installation*s
environmental director. The funds used for the roof replacement were taken
from an approved activity to update and implement the installation*s
integrated natural resources management plan required under the Sikes Act.
15 The description of the activity as approved for funding does not
mention roof repair. According to the environmental director, the
activity*s narrative was a *catch all* that could be used to fund anything
related to implementation of the natural resources plan, including
repairing a roof on a historic structure. Although the environmental
director acknowledged that this roof replacement could have been funded
through the installation*s public works department, which is responsible
for maintaining and repairing installation structures, he also said that
the public works department did not have funding available for this
activity, while the environmental quality program did.

According to our review of Army policy, minor construction costs not
related to new or expanded legal environmental requirements are not
eligible for environmental funds. Army Installation Management Agency
officials agreed that environmental funds should not have been used to
fund this roof repair and said that they would not have funded this
activity had it been specifically mentioned in the funding request for the
natural resources plan. The environmental quality program could fund
certain repairs of historic structures to maintain compliance with the
National Historic Preservation Act, according to the officials.

15 The Sikes Act addresses all aspects of natural resources management on
military installations. A 1997 amendment to the act requires the services
to prepare an integrated natural resources management plan for each
installation in the United States, except for

installations that have been determined to lack significant natural
resources.

Page 19 GAO- 03- 639 DOD Environmental Compliance

Although DOD*s and the services* policies call for funding of all high-
priority environmental quality program activities, the services have not
always been able to fund all such activities through their environmental
quality program. While program managers for most of the installations we
visited said that the environmental quality programs were generally able
to fund high- priority environmental activities during

fiscal years 1999 through 2002, in some instances installations were not
able to fund all such activities. To address such situations, installation
officials deferred certain high- priority activities, sought an extension
of a compliance deadline, obtained funding from other sources at the
installation, or stretched their allotment of environmental funding to pay
for more activities than planned.

According to some environmental managers at the installations where high-
priority activities were deferred, the activities they were most likely to
defer were those that do not have a firm timeline for completion, such as
surveys of cultural resources. Certain requirements, such as those in the
Sikes Act or the National Historic Preservation Act that require
installations to survey their natural or cultural resources, do not
provide for a penalty for missing a deadline or do not specify when these
activities must be undertaken. Consequently, although not completing these
activities means that the installation is not in compliance with an
environmental requirement, there is little likelihood of a risk to human
health or a risk of receiving a notice of violation, fine, or penalty from
a regulator. Thus, noncompliance with these requirements presents, at
least in some cases, a lower risk to the installation than would
noncompliance with certain other environmental requirements. Nonetheless,
DOD*s definition of must- fund, high- priority environmental activities
includes all activities needed to keep installations in compliance with
federal, state, or local laws and regulations, as well as executive
orders, even where there are no compliance deadlines or risk of a fine. In
cases in which installations deferred selected required activities, it may
have resulted in noncompliance with federal environmental laws.

Officials at other installations we visited also cited concerns about the
deferral of certain environmental activities, particularly those that may
not have a compliance deadline and are thus considered lower priorities.
For example, a senior environmental official at Vandenberg Air Force Base
described how the rapid spread of Argentinean pampas grass, an invasive
species, had resulted in the U. S. Fish and Wildlife Service listing the

grass as a major threat to four federally endangered plant species on the
installation and requiring that the Air Force eradicate the grass* at a
cost of approximately $1 million. According to Vandenberg environmental
The Services*

Environmental Quality Programs Cannot Ensure That DOD*s Requirement to
Fund All High- Priority Needs Is Met

Page 20 GAO- 03- 639 DOD Environmental Compliance

officials, they had requested environmental funding for the project when
the grass was initially found because they believed the cost to eradicate
it at that time would be minimal compared to the future expense if the
grass were left uncontrolled. However, the installation could not obtain
environmental quality funding for the project because it was a Class III
activity and Air Force policy prohibits funding of lower priorities. The
project was not funded until the U. S. Fish and Wildlife Service listed
the grass as a major threat to the endangered species.

Environmental program managers at most of the installations we visited
indicated that they have generally been able to fund emergency, high-
priority environmental activities that occurred outside the normal
budgeting cycle, but they have done so by using funds allocated for other
planned high- priority activities, emergency or year- end funding from the
environmental quality program, or other funding sources at the
installation or command. In some cases, certain planned activities could
be deferred because the regulatory deadlines slipped or the regulators
granted the installation an extension on meeting the deadline. Some
environmental managers also mentioned that in some instances, planned
activities come in under budget, which can result in extra funds being
available for other, unexpected needs. At the installations we visited,
environmental managers dealt with a variety of unexpected needs for
funding, including the following:

 A Texas regulatory agency required Fort Bliss to immediately investigate
and assess a fuel leak. To pay for this unbudgeted activity, the chief of
the installation*s environmental compliance division approved the
reprogramming of some of the funding from 13 other high- priority
environmental activities.  Fort Campbell*s environmental office acquired
some Army Corps of

Engineers* property that had soil erosion problems. Because the land was
acquired during the middle of the fiscal year, the environmental quality
program had not budgeted funds to address the erosion. The Corps agreed to
provide funding for interim erosion control.

 Camp Pendleton faced an emergency when sewage began to flow out of
manholes on a training range near a wetland. The installation used base
operating funds for cleanup and to clear out the clogged main sewer line.
The Marine Corps* environmental quality program also provided $500,000 in
emergency funding to determine the cause of the problem and, hoping

Page 21 GAO- 03- 639 DOD Environmental Compliance

to avoid other such occurrences, to assess the condition of 150 miles of
the main sewer line. 16 Regarding future, high- priority activities, some
of the services have

recently indicated that their environmental quality programs will have
difficulties funding all high- priority activities in fiscal year 2003 and
even greater difficulties in fiscal year 2004. Specifically,

 In early 2003, in preparation of its presidential budget request for
fiscal year 2004, the Army reported that in each fiscal year 1998 through
2003, its environmental quality program funded or will fund between 83 and
98 percent of validated high- priority activities. However, the Army
estimates that in fiscal 2004, the program will be able to fund just

78 percent of its high- priority activities. Army officials indicated that
their environmental quality program will not only face larger funding
needs for high- priority activities in fiscal year 2004, but also that the
program*s budget will be lower than the previous 2 years because some of
these funds will be needed for other priorities, including the global war
on terrorism and spare parts for military equipment. To address

this anticipated shortfall, the Army expects its major commands and
installations to provide funds from other command or installation budget
sources as needed to ensure that the installations remain in compliance
with environmental requirements. However, the availability of such funds
is uncertain given DOD*s ongoing challenges in containing the
deterioration of its military facilities as discussed earlier in this
report.

 According to Air Force officials, funding for the environmental quality
program will be decreased in fiscal year 2004 because of competing demands
on overall Air Force resources. Air Force officials also stated that this
reduction will be absorbed by the major commands, which are required to
fully fund all must- fund activities, even if it means migrating funds
into the environmental quality program from other operations and
maintenance activities.

16 The assessment, using video technology that could detect tree roots,
cracks, and other potential problems, found that the sewer lines had been
clogged by cooking grease, tree roots, and other objects that had been
flushed down toilets, including t- shirts and diapers, in base housing and
interstate highway rest stops along Camp Pendleton*s property. Based on
the results of the emergency assessment, Camp Pendleton has requested $7.5
million in repairs, to be paid for through the Marine Corps* sustainment,
restoration, and

modernization program rather than the environmental program.

Page 22 GAO- 03- 639 DOD Environmental Compliance

DOD has established broad policy for its environmental compliance program
that does not specify which activities can be funded. As a result, there
is significant variation in how the services interpret this policy and
implement their own environmental quality programs. This variation among
the services* programs can result in different eligibility requirements
for environmental activities across services and funding of activities
that would be more appropriately funded from other sources, such as
military operations or base maintenance. Given the services* broad and
differing interpretations of eligibility for environmental quality program
funding, as well as their inclusion of activities that are more closely
related to military operations or maintenance, DOD cannot be assured that
the services* environmental funding needs have been accurately identified,
that its funds for environmental quality are being targeted to its most
critical environmental requirements, or that its management of its
environmental responsibilities continues to improve. Although the services
have, over the past decade, made significant improvements in their
environmental compliance performance, these improvements have leveled off
in recent years, and DOD has not reached its goal of full environmental
compliance. Further, given that the services

have not always been able to fund all high- priority environmental quality
activities and expect this condition to worsen in fiscal year 2004, it is
all the more important that DOD target its environmental quality program
funds wisely.

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

Recommendations for Executive Action

Page 23 GAO- 03- 639 DOD Environmental Compliance

We provided DOD with a draft of this report for review and comment. DOD
provided technical clarifications, which we incorporated as appropriate.
However, DOD did not provide overall comments as of the issuance date of
this report.

We will send copies of this report to the Secretary of Defense; the
Director, Office of Management and Budget; appropriate congressional
committees; and other interested parties. We will also provide copies to
others upon request. In addition, the report will be available, at no
charge, on the GAO Web site at http:// www. gao. gov.

If you or your staff have any questions, please call me or Edward Zadjura
at (202) 512- 3841. Contributors to this report are listed in appendix II.

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

and Environment Agency Comments

and Our Evaluation

Appendix I: Scope and Methodology Page 24 GAO- 03- 639 DOD Environmental
Compliance

To assess DOD*s and the military services* processes for identifying,
prioritizing, and funding their environmental quality activities, we
reviewed the policies and procedures established by DOD and the services
to guide implementation of the environmental quality program. We also
reviewed each service*s system for identifying, prioritizing, and funding
their environmental quality activities, and compared this information
across the services to identify differences in the programs.

To determine how environmental activities are identified and prioritized
by installations, we visited 11 active military installations in the
United States (listed below). Generally, we selected at least two
installations from each service. We selected these installations primarily
because of their

large environmental quality budgets and because they represent a diversity
of major commands, military missions, and geographic locations. Because
the Navy*s environmental quality program is organized into regions, we
selected two Navy regional offices rather than two installations. Within
these two Navy regions, we visited a total of four installations and
reviewed environmental funding requests for an additional four
installations. Our observations about individual projects or activities at
these installations are not generalizable to projects or activities at all
military installations.

U. S. Air Force Eglin Air Force Base, Florida Vandenberg Air Force Base,
California

U. S. Army Fort Bliss, Texas Fort Campbell, Kentucky Fort Carson, Colorado

U. S. Navy Navy Mid- Atlantic Region: Naval Station Norfolk, Virginia;
Naval Weapons Station Yorktown, Virginia (Note: We also reviewed
environmental funding requests for Naval Air Station Oceana, Virginia, and
Naval Amphibious Base Little Creek, Virginia.) Navy Region Southwest:
Naval Air Station, North Island, California; Naval Station Point Loma,
California (Note: We also reviewed environmental funding requests for
Naval Station San Diego, California, and Naval Auxiliary Landing Field San
Clemente Island, California.) Appendix I: Scope and Methodology

Military Installations GAO Visited

Appendix I: Scope and Methodology Page 25 GAO- 03- 639 DOD Environmental
Compliance U. S. Marine Corps Marine Corps Base Camp Lejeune, North
Carolina

Marine Corps Base Camp Pendleton, California At each installation visited,
we interviewed environmental quality program officials to obtain
information about their implementation of the environmental quality
program. We reviewed these installations* lists of planned environmental
projects for fiscal years 2002 through 2009 and funding data for
activities covering fiscal years 1999 through 2002. We compared this
information across the services to determine if there

were variations in the types of environmental activities being funded. We
also compared the installations* lists of environmental activities to
service policy to determine if inappropriate or ineligible activities had
been funded. To determine the role of the major commands in identifying,
prioritizing,

and funding environmental activities and to obtain the commands*
perspectives on the environmental quality program, we discussed the
environmental quality program with officials from the major commands
associated with the installations and regions we visited: Army Forces
Command (Fort Campbell and Fort Carson), Army Training and Doctrine
Command (Fort Bliss), Air Force Space Command (Vandenberg Air Force Base),
Air Force Materiel Command (Eglin Air Force Base), the Navy*s Atlantic
Fleet (Navy Mid- Atlantic Region), and the Navy*s Pacific Fleet (Navy
Region Southwest). The Marine Corps does not have major commands that play
the type of role in the environmental quality program that the commands
play in the other services. We also discussed our findings with officials
of the Army*s new Installation Management Agency, which will assume
responsibility for funding environmental quality programs at Army
installations beginning in fiscal year 2004.

We also met with officials from the Office of the Secretary of Defense and
each service headquarters to obtain information on their roles in the
environmental quality program and their perspectives on the program, in
particular, on how environmental activities are identified, prioritized,
and funded. We conducted our review from May 2002 through May 2003 in
accordance

with generally accepted governmental auditing standards.

Appendix II: GAO Contacts and Staff Acknowledgments

Page 26 GAO- 03- 639 DOD Environmental Compliance

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

In addition to the individuals named above, Kelly Blado, Christine Frye,
Roderick Moore, Cynthia Norris, and Susan Swearingen made key
contributions to this report. Also contributing to this report were Doreen
Feldman, Anne Rhodes- Klein, and Amy Webbink. Appendix II: GAO Contacts
and Staff

Acknowledgments GAO Contacts Acknowledgments

(360206)

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