Environmental Protection: DOD Management Issues Related to Chaff (Letter
Report, 09/22/98, GAO/NSIAD-98-219).

Pursuant to a congressional request, GAO reviewed the Department of
Defense's (DOD) use of chaff and its long-term effects on the
environment, focusing on: (1) the extent and locations of chaff use; (2)
its reported known and potential effects; and (3) the initiatives being
taken or considered to address chaff's unintended effects.

GAO noted that: (1) chaff is used worldwide in conjunction with military
training, testing, and other assigned missions; (2) in fiscal year (FY)
1997, the Air Force reported using about 1.8 million bundles worldwide,
Navy and Marine Corps aircraft used more than 354,000 bundles and 593
rolls, and Navy combat ships used about 10,000 large bundles; (3) DOD
records indicate that FY 1998 inventories include more than 37 million
bundles and more than 141,000 rolls of chaff; (4) the Air Force holds
about 77 percent of the bundles, while the Navy and Marine Corps hold
all the rolls; (5) the Army has some mission needs but possesses and
uses little chaff in peacetime training or testing; (6) while DOD
components report that chaff is an effective means of defense for
aircraft, ships, and related weapons systems, DOD and other agencies
have identified some unintended and potential side effects of chaff; (7)
chaff can affect safety by interfering with air traffic control radar;
(8) chaff can also affect weather radar observations and the operation
of friendly radar systems, especially when vehicles stir up chaff that
has settled on the ground; (9) the services have a number of ongoing
initiatives to address concerns about the unintended and potential
effects of chaff; (10) for example, DOD has entered into or is
negotiating agreements with other federal agencies to address issues
related to commercial air safety, weather forecasting, and environmental
impacts on public lands; (11) also, the Navy has started a program to
develop degradable chaff that is estimated to cost about 40 percent more
than the current chaff; (12) while intended as beneficial, the Navy has
not yet defined the operational and environmental benefits that could
result from this program; (13) notwithstanding DOD's actions, some
concerns continue to be raised by the public and federal agencies about
the potentially harmful or undesirable effects of chaff on the
environment; (14) also, some of DOD's studies cite additional areas
where questions have been raised about the unintended effects of chaff;
(15) DOD has not systematically followed up on these questions or on the
recommendations of these reports to determine whether they merit
additional review; and (16) DOD continues to retain lead-based chaff in
its inventory even though this type of chaff has not been manufactured
since 1987 and is reportedly no longer in use.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  NSIAD-98-219
     TITLE:  Environmental Protection: DOD Management Issues Related to 
             Chaff
      DATE:  09/22/98
   SUBJECT:  Military inventories
             Radar equipment
             Military materiel
             Environmental monitoring
             Hazardous substances
             Military training
             Pollution control
             Defense capabilities
             Interagency relations
IDENTIFIER:  Chaff
             
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Cover
================================================================ COVER


Report to the Honorable
Harry Reid, U.S.  Senate

September 1998

ENVIRONMENTAL PROTECTION - DOD
MANAGEMENT ISSUES RELATED TO CHAFF

GAO/NSIAD-98-219

Chaff Management Issues

(709295)


Abbreviations
=============================================================== ABBREV

  BLM - Bureau of Land Management
  DOD - Department of Defense
  FAA - Federal Aviation Administration
  FWS - Fish and Wildlife Service
  NOAA - National Oceanic and Atmospheric Administration
  NWS - National Weather Service

Letter
=============================================================== LETTER


B-279055

September 22, 1998

The Honorable Harry Reid
United States Senate

Dear Senator Reid: 

This report responds to your request regarding the use of chaff by
the Department of Defense (DOD) and the effects of chaff.  Chaff is
composed of aluminum-coated silica glass fibers that can be spread by
aircraft in flight, ships at sea, and vehicles on the ground to help
them evade enemy radar.  You expressed concern about DOD's continued
use of chaff for decades without sufficient knowledge of its
long-term effects on the environment.  As agreed with your office,
this report addresses (1) the extent and locations of chaff use, (2)
its reported known and potential effects, and (3) the initiatives
being taken or considered to address chaff's unintended effects. 


   BACKGROUND
------------------------------------------------------------ Letter :1

Chaff works like a decoy by presenting a false target to enemy radar
systems.  It has been used by the military for more than 50 years. 
It was used during World War II and more recently during Operation
Desert Storm.  Chaff is also used in the peacetime training and
testing of weapons.  Chaff may be dispersed in bundles weighing from
a few ounces to
24 pounds or from rolls in a continuous stream of over 30 pounds per
minute.\1

DOD updated controls over the use of chaff in an October 1997 interim
draft of section 3212.02 of the Chairman of the Joint Chiefs of Staff
manual.  The manual sets the procedures for controlling the types of
chaff to be used, the areas where it can be used, and altitudes at
which it can be released.  Each military facility has the authority
to set local procedures that govern the use of chaff at training
ranges and other locations near the facility. 

Concern about the potential effects of chaff continues to be an issue
and has been expressed mainly by citizens and various public interest
groups.  In addition, some DOD research on the effects of chaff has
expressed concerns and recommended further research.  Most of the
public concerns center around its effects on human health and the
environment, including the potential for chaff particles to be
inhaled or ingested and chaff's effects on land, water, plants, and
animals. 


--------------------
\1 A bundle is any precut chaff load in containers such as plastic
tubes or cardboard boxes.  Chaff rolls consist of either about 3,000
continuous strands that are dispensed by a cutter or of precut fibers
placed between mylar sheets that are dispensed when the sheets are
separated. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

Chaff is used worldwide in conjunction with military training,
testing, and other assigned missions.  In fiscal year 1997, the Air
Force reported using about 1.8 million bundles worldwide, Navy and
Marine Corps aircraft used more than 354,000 bundles and 593 rolls,
and Navy combat ships used about 10,000 large bundles.  DOD records
indicate that fiscal year 1998 inventories include more than 37
million bundles and more than 141,000 rolls of chaff.  The Air Force
holds about 77 percent of the bundles, while the Navy and the Marine
Corps hold all the rolls.  The Army has some mission needs but
possesses and uses little chaff in peacetime training or testing. 

While DOD components report that chaff is an effective means of
defense for aircraft, ships, and related weapon systems, DOD and
other agencies have identified some unintended and potential side
effects of chaff.  Chaff can affect safety by interfering with air
traffic control radar.  Chaff can also affect weather radar
observations and the operation of friendly radar systems, especially
when vehicles stir up chaff that has settled on the ground.  It has
been reported that chaff has also caused power outages and damaged
electrical equipment.  Potential effects cited by Defense and other
organizations include those on health and the environment.  For
example, the Air Force reported that chaff has a potential but remote
chance of collecting in reservoirs and causing chemical changes that
may affect water and the species that use it. 

The services have a number of ongoing initiatives to address concerns
about the unintended and potential effects of chaff.  For example,
DOD has entered into or is negotiating agreements with other federal
agencies to address issues related to commercial air safety, weather
forecasting, and environmental impacts on public lands.  Also, the
Navy has started a program to develop degradable chaff that is
estimated to cost about 40 percent more than the current chaff. 
While intended as beneficial, the Navy has not yet defined the
operational and environmental benefits that could result from this
program. 

Notwithstanding DOD's actions, some concerns continue to be raised by
the public and federal agencies about the potentially harmful or
undesirable effects of chaff on the environment.  Also, some of DOD's
studies cite additional areas where questions have been raised about
the unintended effects of chaff.  DOD has not systematically followed
up on these questions or on the recommendations in these reports to
determine whether they merit additional review.  Lastly, DOD
continues to retain lead-based chaff in its inventory even though
this type of chaff has not been manufactured since 1987 and is
reportedly no longer in use. 


   EXTENT AND LOCATION OF CHAFF
   USE
------------------------------------------------------------ Letter :3

The first recorded large-scale use of chaff by American forces in
combat was on December 20, 1943, in an air raid by 8th Air Force
bombers over Bremen, Germany.  Today, the services use chaff on
combat ranges and at other locations worldwide for peacetime training
and testing. 

Aluminum, because of its electrical conductivity,\2 low cost, low
weight, and durability, has been a consistent ingredient in chaff. 
In the 1980s, the cost of chaff was further reduced by replacing
solid aluminum with hair-like silica glass fibers with a thin
aluminum coating.  Chaff was once produced using lead, and the Air
Force still has some chaff containing lead in its inventory. 
According to the manufacturer, chaff containing lead was last
manufactured in 1987.\3 The proportion of lead in chaff dropped from
about 1.2 ounces (7.5 percent) per pound in the 1950s to 0.16 ounces
(1 percent) by 1987. 

The Air Force, the Navy, and the Marine Corps are the leading users
of chaff.  Air Force records indicate they used nearly 2 million 6-
to 7-ounce bundles worldwide in fiscal year 1996 and about 1.8
million bundles in fiscal year 1997.  Navy and Marine Corps aircraft
together expended more than 340,000 and 354,000 similarly sized
bundles in fiscal years 1996 and 1997, respectively.  They also
reported using 158 rolls in fiscal year 1996 and 593 rolls in fiscal
year 1997.  The Army currently uses very little chaff but has the
capability to use it from some of its helicopters.  The Army used a
total of only 2,700 bundles of chaff from fiscal year 1991 to 1997. 
Army officials reported they plan to increase training with chaff and
are developing chaff and dispensing equipment to be used on
land-based vehicles.  (See app.  I for the various types of chaff
used and app.  II for data on reported chaff use by service and by
selected location.)

The services use chaff on training ranges around the world.  The Air
Force uses about 39 ranges in the United States and off its coast;
the Navy and the Marine Corps use 14 ranges.  The Air Force uses 14
ranges in 1 African and 7 European countries and 2 ranges in Korea,
while the Navy and the Marine Corps have 1 range in Italy.  According
to Army officials, the Army does not use chaff on any of its ranges,
but the other services do.  For example, the Air Force uses chaff at
White Sands Missile Range, and the Navy uses Dugway Proving Grounds
for Navy ship chaff acceptance testing.  Navy ships train with chaff
in most of the world's international waters.  Navy officials stated
that naval ships perform chaff tests and evaluations at two ranges
off the U.S.  east and west coasts.  Figure 1 shows the states and
offshore locations near the United States where chaff is used. 

   Figure 1:  States (shaded) and
   Off-shore Ranges Where Chaff Is
   Used

   (See figure in printed
   edition.)

The methods used to disperse chaff have evolved over the years, from
simply tossing it out of airplane windows to launching it with
spring-loaded or pneumatic machines.  Currently, the services use
pyrotechnic charges, rockets, mortars, air flows, or motors to
disperse chaff.  Many aircraft employ pyrotechnic charges that eject
chaff in bursts from small bundles weighing about 6 ounces, while
others use air flows to disperse ejected chaff.  The Navy uses small
rockets to launch airborne charges containing 8.5 pounds of chaff and
shipborne charges containing 16.8 pounds of chaff.  Navy ships can
also launch mortar-like charges of chaff weighing between 16 and 24
pounds.  Motors feed chaff from rolls of about 40 pounds through
cutters\4 carried on some aircraft to produce either bursts or a
continuous stream. 

The continuous stream technique, called saturation chaff, may be used
by aircraft to cover a large area.  By 2005 or 2006, the Army also
plans to use saturation chaff to mask vehicle and troop movements. 
Using a cutter,
360 pounds of chaff from nine 40-pound rolls can be deployed in 10
minutes.  Depending on the method and the number of aircraft, such
releases could disperse billions of fibers.  The B-52 can carry about
750 seven-ounce boxes of chaff; each box contains up to 11 million
fibers that can be expelled continuously or in bursts. 

Most chaff bundles contain millions of fibers.  For example, the
chaff bundles used most by the Air Force (RR-188) and the Navy
(RR-144) contain more than 5 million individual fibers each, and the
Navy's Zuni rocket warhead (RR-182) contains more than 100 million
fibers. 


--------------------
\2 Electrical conductivity is important because chaff absorbs and
reflects electromagnetic energy to create a radar echo. 

\3 Only one U.S.  manufacturer supplies chaff to the military. 
However, at least one additional manufacturer performs research and
development into chaff materials.  According to DOD, chaff with lead
was last produced in 1983. 

\4 A cutter is used to cut a group of continuous strands of chaff to
the desired length. 


   QUESTIONS CONTINUE TO BE RAISED
   CONCERNING KNOWN AND POTENTIAL
   EFFECTS OF CHAFF
------------------------------------------------------------ Letter :4

Studies addressing the effects of chaff cite a number of known and
potential effects.  Furthermore, our discussions with officials from
DOD, other federal agencies, and the private sector indicate that
there are additional questions about the effects of chaff.  Among
these are the known effects of chaff on various types of radar and
its potential effects on health and the environment. 


      AIR FORCE 1997 REPORT
      SUMMARIZES PAST CHAFF
      RESEARCH
---------------------------------------------------------- Letter :4.1

Ten studies (see app.  III) on the effects of chaff have been carried
out over the past 45 years on request by the Army, Navy, Air Force,
National Guard Bureau, and Canadian Forces Headquarters.\5 An August
1997 report for the U.S.  Air Force Air Combat Command was the most
recent and comprehensive review of the effects of chaff.  The report
includes original study as well as reviews of most of the previous
reports.  It cited the following categories that can be affected by
the use of chaff:  safety, air quality, physical resources (soil and
water), biological resources, and land and cultural resources.  Most
known chaff effects fall into the safety category, while potential
effects fall into the other categories.  The following sections
summarize the known and potential effects described in the Air Force
report. 


--------------------
\5 Although this was the only non-U.S.  military sponsor, we chose to
include it in our review because its report is a key animal study
cited in many of the other studies we reviewed. 


         SAFETY
-------------------------------------------------------- Letter :4.1.1

The report noted that while chaff is effective at confusing enemy
radar, it also interferes with air traffic control radar.  The report
said that chaff had interfered at least twice with Federal Aviation
Administration (FAA) radar but added that such events could be
effectively avoided or managed.  According to the report, safety
risks from the use of chaff are extremely low and impacts on
aircrews, aircraft, or the public are not anticipated.  For example,
the report found (1) no incidents of chaff interfering with satellite
tracking; (2) two recorded incidents of military fighter aircraft
interfering with FAA radar, but details were unavailable; (3) no
documentation that chaff had caused aircraft radar systems to falsely
identify nearby traffic; (4) no evidence of an aircraft engine
failing after ingesting chaff; and (5) no reported accidents in which
pilots were distracted by chaff. 

The report states that the primary safety concern is the potential
for interference with FAA's air traffic control radar but notes that
DOD and FAA have agreed to restrict locations, altitudes, and times
at which chaff can be used.  The report states that a newer type of
chaff that does not interfere with FAA radar is readily available. 


         AIR QUALITY
-------------------------------------------------------- Letter :4.1.2

Air quality issues addressed in the report include the potential for
(1) noncompliance with national air quality standards due to the
release of significant quantities of particulates, (2) release of
hazardous air pollutant emissions, and (3) visibility impairment. 
The report takes into consideration the Clean Air Act\6 and its
amendments and includes a literature review of chaff dispersion and
air quality effects as well as its own April 1994 technical report on
chaff particulate testing. 

The report's literature review shows that none of the previous
studies had addressed the possible formation of inhalable
particulates or issues related to compliance with the Clean Air Act. 
But the report indicates some inconsistencies in the reported size,
use, and manufacture of chaff.  The report cited a particulate test
showing that potential effects would not exceed air quality
standards, even though explosive charges on impulse cartridges may
result in minimal releases of particulates.  The report says that
further study may be needed on the potential for short-term
visibility impairment near training areas where large quantities of
chaff are used.  However, it says that chaff dispersed over a wide
area and settled quickly in particulate testing.  Its conclusions
assume chaff containing lead is no longer being used.  According to
DOD, there have been no reports of short-term visibility impairments
caused by chaff. 


--------------------
\6 The Clean Air Act requires the Environmental Protection Agency to
set national air quality standards. 


         SOIL AND WATER
-------------------------------------------------------- Letter :4.1.3

The report says that the chemical or physical effects of chaff on
soil and water would be very limited because chaff falls only in
small quantities in any one location.  It cites potential effects on
wildlife through ingestion, inhalation, or skin contact; on species,
habitat conditions, and aesthetics through settling in the water; and
on water quality.  The report includes a literature review, a
laboratory analysis, and field studies at two locations where chaff
is frequently used.  One location is arid desert (Nellis Range
Complex, Nevada) and the other humid woodlands (Townsend Air to
Ground Gunnery Range, Georgia). 

The report notes that the literature addressing the effects of chaff
on water quality and aquatic habitats is limited and that there has
been no systematic analysis of chemical changes in soils exposed to
various concentrations of chaff.  It cites a 1977 Navy report that
found no increase in aluminum or trace metals from chaff placed in
water.  The Air Force report notes that chaff's potential to
adversely affect the environment depends on the quantity deposited in
a particular area, the fibers' stability, the specific conditions of
the soil and water, and the sensitivity of the environment to
contaminants.  It states that the likelihood of chaff falling into a
particular pond, stream, or estuary in sufficient quantity to
measurably affect the water's chemical makeup is remote. 


         BIOLOGICAL RESOURCES
-------------------------------------------------------- Letter :4.1.4

The report addresses the potential biological effects of chaff on
wildlife due to inhalation, ingestion, and direct contact as well as
the effects of chaff on vegetation and aquatic life of chaff
decomposing in soil or water.  The Air Force reported no adverse
impacts from chaff and said that chaff is generally nontoxic. 
However, few studies of the effects of chaff on wildlife have been
conducted, and the report found no data on chaff's decomposition
process under different environmental conditions (arid, alkaline,
wet, acidic) or inside the digestive systems of animals.  The study
includes a literature review, field studies, and laboratory analyses
of soil samples taken at Nellis and Townsend, the two military range
areas studied.  The report cites a 1972 Canada Department of
Agriculture study that found no health hazards to farm animals.  The
Air Force study also cited a previous report on the Chesapeake Bay
ecosystem that found no impacts on the six marine organisms
studied.\7

The Air Force study reports the following: 

  -- Animals can inhale chaff particles, but the particles do not
     penetrate far into the respiratory system and can be easily
     cleared out. 

  -- Chaff disperses over a large area of land, limiting exposure of
     grazing animals.  Little chaff accumulated on the surface of
     standing water bodies.  Surface-feeding or bottom-feeding
     animals and fish may ingest chaff, but this only affects a few
     individual animals and has a low impact on species populations
     except in the case of protected species. 

  -- The numbers of chaff particles are negligible because chaff
     disperses over a large land area.  Low concentrations of chaff
     limit the likelihood that birds would use chaff for nests and
     expose the young. 

  -- Chaff disintegrates on land.  It decomposes slowly in arid areas
     and has no adverse effects on soil chemistry and plant growth. 
     Chaff interference with wildlife is expected to be negligible
     based on chaff use, characteristics, and observed accumulations. 

  -- Chaff decomposing in water has no adverse impacts on water
     chemistry and aquatic life.  In wet areas, chaff is covered by
     plant growth and dead leaves.  Chaff decomposes more rapidly in
     wet acidic environments, but when doing so it releases only
     minute amounts of chemicals. 

  -- Lead has not been used in the manufacture of chaff since 1983.\8


--------------------
\7 Two universities, working with the prime contractor, reported
effects on some of the Chesapeake Bay organisms studied, but the
prime contractor concluded these effects were not significant and
reported no short- or long-term adverse environmental effects in its
summary (see app.  III). 

\8 The manufacturer's representative told us the business had last
manufactured chaff with lead in 1987.  As discussed in this report,
chaff with lead was still in Air Force inventories at the time of our
review. 


         LAND AND CULTURAL
         RESOURCES
-------------------------------------------------------- Letter :4.1.5

Land resource issues addressed in the report concerned the
accumulation of chaff and its potential to alter the land's use and
visual quality, while cultural resource issues related to the
potential for physical or chemical impacts to alter the aesthetic
setting and cultural context.  The Air Force reviewed applicable laws
and other related information and produced the field studies'
technical report.  It did not identify any studies that assessed the
impacts of chaff on either land use or its visual quality, or on
cultural resources.  Nevertheless, according to the Air Force, while
chaff debris may be perceived as annoying or intrusive, it does not
accumulate in quantities likely to have such impacts.  The report
states that, overall, chaff debris has low visibility and little
effect on the aesthetic quality of the environment.  While noting
that little data existed, the study reports that common
nondestructive materials such as chaff have little potential for
effects.  The Air Force report states that the primary potential is
for chaff debris to affect the aesthetic setting but that cultural
resources are not generally located beneath airspace where heavy
chaff use is concentrated and examinations could be done on a
site-specific basis.  It noted that no research exists on Native
American concerns about the aesthetic effects of chaff deposits. 


      OTHER KNOWN CHAFF EFFECTS
---------------------------------------------------------- Letter :4.2

Our discussions with officials from federal agencies and the private
sector brought out other known effects that are discussed in the
following three sections. 


         EFFECTS ON WEATHER
-------------------------------------------------------- Letter :4.2.1

Chaff can show up on radar as a false weather phenomenon and may
affect lightning within storms.  The National Weather Service (NWS)
began to observe the widespread and frequent use of chaff in the late
1980s, when it started using new and more sensitive weather radar. 
Radar observations show that chaff can spread over several hundreds
of miles and stay in the air for up to a day.  A scientist formerly
with the National Oceanic and Atmospheric Administration (NOAA), who
now performs weather research at the University of Oklahoma,
estimated it would have taken more than 200 billion chaff particles
to create a radar picture taken in Arizona in 1997.  DOD officials
stated that it is improbable that such a large chaff deployment
occurred outside of combat and is unlikely to occur in any future DOD
training events.  Figure 2 shows a 1997 NWS weather radar image of
chaff over Southern Arizona.  NOAA also provided pictures taken since
1993 in many other parts of the country and showing radar images of
chaff. 

   Figure 2:  NWS Radar Image of
   Chaff Plumes Over Southern
   Arizona and Southwestern New
   Mexico on October 8, 1997. 

   (See figure in printed
   edition.)

According to NOAA officials and scientists, chaff can be easily
identified under clear skies, but it can give false readings under
other weather conditions and can thus impair the ability to make
accurate forecasts.  Chaff may be interpreted as precipitation and in
some cases could result in inaccurate warnings of severe weather. 
Chaff could therefore interfere with missions that rely on accurate
weather forecasts.  One NOAA technical report describes chaff's
interference with normal weather observation data in at least two
space-shuttle launch attempts.\9

NOAA scientists are also concerned that chaff may cause inaccurate
weather data to be archived for long-term climate research studies. 
Meteorologists can usually correctly identify chaff on radar, but
automated systems cannot now distinguish chaff from rainfall.  The
automated systems record chaff as precipitation and overstate the
amount of rain archived in the database.  Researchers may therefore
get inaccurate results from their studies. 

NOAA scientists are also trying to determine whether chaff suppresses
lightning because this may also make it more difficult to assess the
weather accurately.\10

Large storms will usually produce frequent lightning strikes to the
ground, and there is a direct correlation between the severity of a
storm and the number of such strikes.  However, it has been observed
that some large storms inside chaff clouds had little or no
lightning.  If chaff reduces lightning, it could cause forecasters to
underestimate the severity of storms.  NOAA scientists and a
University of Oklahoma weather researcher said they would like to
further study the effects of chaff on thunderstorms if they could
obtain funding.  DOD officials stated that the
U.S.  Forest Service has used chaff for a number of years to suppress
lightning and prevent forest fires, and NOAA issued an environmental
impact statement on lightning suppression in October 1972.  DOD
believes the findings of this project should be reviewed to determine
the need for additional analysis of this recognized phenomenon prior
to expending additional funds. 


--------------------
\9 Chaff Observations with WSR-88D:  Examples and Operational
Impacts, NOAA / NWS /Spaceflight Meteorology Group, Johnson Space
Center (July 1, 1994). 

\10 Intense Convective Storms With Little or No Lightning Over
Central Arizona:  A Case of Inadvertent Weather Modification?, NOAA,
Environmental Research Laboratories, National Severe Storms
Laboratory (July 22, 1996). 


         FRIENDLY FORCES RADAR
         SYSTEMS
-------------------------------------------------------- Letter :4.2.2

Just as it can confuse enemy and FAA radar and produce false
precipitation echos on NWS radar, chaff can also affect other
friendly radar systems and thus hinder military air traffic
controllers' and meteorologists' support for missions and operations. 
It can also affect friendly warning and targeting systems.  According
to Army chaff program officials, chaff on the ground can be stirred
up by vehicles and can thus interfere with friendly airborne radar
systems.  Although the Army stated this as an area of potential
concern, we found little documentation of these potential effects. 
To help alleviate the problem, the Army is developing chaff that will
reduce interference with friendly forces' radar systems.  It hopes to
have this chaff in the inventory by 2005-06. 


         POWER OUTAGES
-------------------------------------------------------- Letter :4.2.3

Chaff can disrupt electrical power and directly affect electrical
equipment.  San Diego Gas and Electric Company and Navy officials
have identified two instances in which chaff caused power outages in
1985.  In the first case, chaff accidently blown over San Diego,
California, during a Navy exercise 75 to 200 miles from the coast
affected power to 65,000 customers and disrupted air traffic control. 
The Navy reimbursed the power company between $50,000 and $60,000 for
damage.  The second incident occurred 5 days later, again in San
Diego, when a Navy jet inadvertently showered power lines with chaff
on takeoff, causing interruptions in power service. 


   CURRENT DOD INITIATIVES AND
   RELATED CHAFF MANAGEMENT ISSUES
------------------------------------------------------------ Letter :5

In an effort to address the unintended effects of chaff, DOD and the
services have ongoing initiatives related to air traffic control,
chaff use on public lands, chaff effects on weather, and degradable
chaff.  However, the initiative to develop degradable chaff is not
supported by an operational or environmental requirement.  According
to DOD, the need to develop degradable chaff is supported by its
obligation to protect the environment and its sensitivity to concerns
expressed by some members of the public over the use and
degradability of chaff.  Notwithstanding these actions, questions
about the potential adverse effects of chaff on health and the
environment continue to be raised by various public interest groups
and some federal and state officials.\11

DOD's own studies discuss some of the same questions.  Our work shows
that DOD has not systematically followed up on the questions being
raised to determine whether they merit any further action.  Also, DOD
continues to retain lead-based chaff in its inventory, even though it
is reportedly no longer being used. 


--------------------
\11 Public interest groups include the Rural Alliance for Military
Accountability, People for the West, the Wilderness Society, Citizen
Alert, and the Sierra Club.  Federal officials include those at the
Department of Interior's Bureau of Land Management and Fish and
Wildlife Service.  State officials include those at Nevada's
Department of Environmental Protection. 


      DOD INITIATIVES FOR CIVILIAN
      AIR TRAFFIC CONTROL
---------------------------------------------------------- Letter :5.1

To address concerns that chaff interferes with civilian air traffic
control radar, FAA and DOD components have agreed to restrict the use
of chaff and now require military installations to obtain clearance
when using chaff in training and testing.  DOD components also use
training chaff, which is designed not to interfere with FAA radar
frequencies.  FAA has established procedures for coordinating all DOD
electronic countermeasure missions and issues annual clearance
letters to military facilities that use chaff, outlining restrictions
that include controls over what kind of chaff can be used, where it
can be used, and the altitudes at which it can be released. 

The Air Force, the Navy, and the Army have coordinated electronic
countermeasures with FAA under a multiservice instruction that was
first issued in 1964.  According to DOD officials, an interim draft
section 3212.02 of the Chairman of the Joint Chiefs of Staff manual
replaced the multiservice instruction in October 1997 and is expected
to be finalized in October 1998.  In commenting on a draft of this
report, DOD said it has voluntarily restricted chaff use over
concerns about public safety. 


      DOD INITIATIVES FOR CHAFF
      USE ON PUBLIC LANDS
---------------------------------------------------------- Letter :5.2

Initiatives between DOD and Department of Interior agencies are
helping to identify and minimize the effects of chaff on public
lands.  The Fish and Wildlife Service (FWS) and the Bureau of Land
Management (BLM) have signed agreements with individual military
services to control chaff use over wildlife refuges, Native
Americans' reservations, and public lands near military training
grounds.  Examples include agreements signed November 21, 1994, for
the Cabeza Prieta National Wildlife Refuge near Luke Air Force Base,
Arizona; signed December 22, 1997, for the Desert National Wildlife
Refuge near Nellis Air Force Base, Nevada; and signed June 11, 1998,
for the public lands near Mountain Home Air Force Base, Idaho.  Many
military installations have local procedures to restrict the use of
chaff near environmentally sensitive areas or population centers.  In
1997, BLM set up a committee composed of representatives from the
military services and civilian agencies to explore, among other
issues, establishing a policy on dropping chaff over public lands,
where it may be considered litter.  The Navy said it has entered into
three limited agreements to restrict chaff use over wildlife refuges
and public lands because of concern over possible impacts on
sensitive species. 


      DOD INITIATIVES FOR CHAFF
      EFFECTS ON WEATHER
---------------------------------------------------------- Letter :5.3

DOD and components of NOAA have recently begun to identify and
address concerns that chaff interferes with weather radar data and
forecasting.  These initiatives have been aided by the placement of
new weather radar monitors at major military range weather
stations.\12 DOD frequency managers must now alert range operations
officials to halt high-altitude chaff drops within a specified
distance from the Kennedy Space Center prior to scheduled
space-shuttle launches.  Since February 1998, the Navy and NWS have
been conducting coordinated chaff drops to allow NWS radar to record
known quantities, areas, and times of chaff use.  They anticipate a
preliminary report by September 1998. 

NOAA officials suggested additional recommendations to address
chaff's effects on the weather, including improving NWS and DOD
liaison and interaction, having DOD alert NWS of planned unusual
chaff use, and having DOD limiting chaff use when significant weather
is reported over or near the ranges.  NOAA officials stated that
their computer programs could be modified to address chaff effects on
current forecasting and data archiving systems but said these
modifications would be costly. 


--------------------
\12 In a cooperative effort with DOD and FAA, NWS has deployed a
total of about 160 new weather surveillance radars. 


      NAVY'S INITIATIVE FOR
      DEGRADABLE CHAFF
---------------------------------------------------------- Letter :5.4

The Navy is developing a new type of chaff that will break up more
quickly in the environment.  It says the new chaff is needed to
alleviate public concerns about the health and environmental effects
of chaff, particularly the perceived threat that chaff can be
inhaled.  However, DOD has not demonstrated how it will address these
public concerns.  The new chaff is also more expensive. 

Some Navy program officials told us there is no operational or
environmental requirement to develop a new type of chaff and that the
Navy believes the chaff currently in use is not harmful to the
environment or a threat to health or public safety.  However, they
acknowledged that fiberglass chaff persists in the environment and
that some members of the public perceive chaff as environmentally
harmful or undesirable.  They are taking action to develop a new
degradable chaff, saying they thus hope to head off any possible
restrictions on chaff use that may result in reductions in military
training.  DOD officials stressed its obligation to protect the
environment and DOD's sensitivity to concerns expressed by some
members of the public.  It noted that the effort includes the
development of environmentally degradable parts to replace plastic
pieces presently used in systems that dispense chaff. 

Unlike fiberglass chaff, the new chaff's base material and its
aluminum coating can take a few weeks to a few months to break up,
depending on conditions.  Development of the new chaff began in
September 1993, and total development costs are estimated at about
$3.6 million.  Navy officials anticipate the new chaff will be
available beginning in fiscal year 2001 and expect to buy only
degradable chaff in the future.  They plan to buy about 474,000
bundles a year through fiscal year 2003.  A Navy program official
estimated that a bundle of the new chaff will cost about 40 percent
more than it does currently. 


      NO SYSTEMATIC FOLLOW-UP ON
      OPEN QUESTIONS
---------------------------------------------------------- Letter :5.5

Studies by DOD and others, including some carried out years ago,
continue to create questions in the public's mind about the health
and environmental effects of chaff.  Department records indicate that
DOD has not systematically followed up on these reports to determine
the merits of any outstanding question or the costs and benefits of
addressing them. 

While none of the studies we reviewed demonstrated significant
operational or environmental effects of chaff, 9 of the 10 reports
cited gaps in information on potential effects.  Six of the nine made
no recommendations but cited missing data, suggested additional
studies or long-term monitoring, or cited possible long-term chronic
effects.  Three reports recommended additional studies covering chaff
toxicity, long-term exposure, weathering, or other study areas. 
However, DOD has not reviewed the recommendations and information
gaps cited in the reports in a comprehensive and systematic way to
assess their merits for further actions.  For example, the Army's
January 1992 report cites data gaps and recommends that the long-term
risk and chronic exposure of inhaled fibers be evaluated. 
Specifically, it recommends

  -- future research on the resuspension rates of uncoated and coated
     fibers;

  -- studies to establish the weathering rates and chemical fate of
     metal coatings in soils, fresh water, and marine waters;

  -- a comprehensive review of threshold metal toxicity values for
     humans, animals, and important fresh water and marine organisms;

  -- a series of experiments to evaluate the potential impacts of
     fibers;

  -- an examination of the respirability of fibrous particles in
     avian species;

  -- aquatic and marine studies to establish the potential impacts of
     fibers; and

  -- future research on the pathology of inhaled fibers. 

The second and third of the above recommendations were partially
addressed in the Army's September 1992 report.  Two other reports
also partially addressed the second recommendation.\13 We found
limited evidence of follow-up on the other five recommendations. 

The 1997 Air Force study and its technical reports also cite the need
for data and further research, including long-term studies.  Two of
the three technical reports recommend further research.  One suggests
long-term studies to monitor chaff accumulation on water bodies in
high-use areas and the effects on animals using those water bodies. 
Another states that consideration could be given to monitoring
programs for highly sensitive environments subjected to repeated
chaff releases and conducting bioassay tests to further assess the
toxicity of chaff to aquatic organisms.  The final report noted that
in some cases it might be appropriate to analyze the potential for
impacts to highly sensitive aquatic habitats that support threatened
and endangered species in areas underlying airspace where chaff is
proposed for use.  But it does not recommend any follow-up work. 

Open questions similar to those in these reports have been cited by
public interest groups such as those identified earlier.  In
discussing these questions in May and June 1998, DOD and service
officials stated that additional actions were warranted on items such
as follow-ups to previous studies and chaff's weather-related
effects.  These officials said they are meeting to develop strategies
to address the use and effects of chaff.  They said these strategies,
which have yet to be defined, could include a systematic follow-up of
key study findings and recommendations and screening environmental
assessments and impact statements to ensure consistent citation of
study results.  They said efforts will need to be coordinated among
DOD components and could include interim controls over chaff use in
sensitive environments. 


--------------------
\13 Technical Report No.  4, Field Studies, October 1994, and
Technical Report No.  5, Laboratory Analysis of Chaff and Flare
Materials, November 1994, from the 1997 Air Force report. 


      UNNEEDED LEAD-BASED CHAFF
      INVENTORIES ARE BEING
      RETAINED
---------------------------------------------------------- Letter :5.6

During the course of our work, we noted that some lead-based chaff
was still being held in DOD's active inventory.  Older productions of
foil chaff contained lead and lead is known to be toxic and can
result in a number of health problems.  As a result, DOD stopped
purchasing chaff with lead.  The Air Force reported it does not
expect to use any chaff containing lead and the 1997 Air Force report
stated that it is highly unlikely that any chaff containing lead is
still in use.  However, we found that the Air Force still does have
chaff containing lead in its inventory and has no plans to eliminate
it. 

We were provided a sample of chaff containing lead at one of the Air
Force bases we visited during our review.  The sample we obtained was
of an aluminum-foil type used primarily by B-52s.  In addition, Air
Force records show that it still has in its inventory almost 40,000
bundles of chaff containing lead.  These records came from Air Force
and Defense Logistics Agency central inventory control points. 


   CONCLUSIONS
------------------------------------------------------------ Letter :6

DOD and the services have developed ongoing initiatives to address
certain concerns raised by the military's use of chaff.  These
initiatives include plans for increased liaison with agencies such as
BLM, FWS, and NWS.  Nevertheless, the public, DOD studies, and other
federal agencies continue to raise questions about the potential
adverse effects of chaff.  DOD has not systematically followed up to
determine whether these questions merit further action.  Further, the
Navy has initiated a degradable chaff research and development
program but has not yet completely analyzed the operational and
environmental benefits it expects to achieve.  Lastly, although
lead-based chaff has not been produced since 1987 and is no longer
reported used, it is still retained in DOD's inventory. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :7

We recommend that the Secretary of Defense direct

  -- the Secretary of the Navy to study the costs and benefits of the
     degradable chaff program before making a production procurement
     decision;

  -- the Secretaries of the Army, the Navy, and the Air Force to
     determine the merits of open questions made in previous chaff
     reports and whether additional actions are needed to address
     them; and

  -- the Secretary of the Air Force to prepare a specific plan to
     ensure that chaff containing lead at inventory control points
     and military installations is located and eliminated. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :8

In written comments on a draft of this report, DOD concurred with our
findings and recommendations.  (See app.  IV.) DOD stated that the
Navy is developing information on the costs and benefits of
degradable chaff for use in a procurement decision.  It stated that
the services will assess whether additional actions are needed to
address open questions from previous chaff reports.  DOD also said
that any training chaff with lead would be eliminated and that
operational chaff would be clearly marked so that it could only be
used to meet combat requirements.  DOD also provided technical
comments which we incorporated where appropriate. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :9

To address the extent and location of DOD's chaff use, the known and
potential effects of chaff, and initiatives to mitigate these
effects, we interviewed and obtained documents from officials at the
Department of Defense, the military services, components of the
National Oceanic and Atmospheric Administration (including the Office
of Oceanic and Atmospheric Research and the National Weather
Service), the Federal Aviation Administration, the Bureau of Land
Management, the Fish and Wildlife Service, the Environmental
Protection Agency, the Defense Logistics Agency, and the Federal
Communications Commission.  In addition, we spoke with state
officials and other parties from the states of Nevada, Florida,
Oklahoma, and Arizona, including Native Americans, public interest
groups, and interested citizens, to determine whether they had
concerns about chaff use or were aware of any health or environmental
effects.  We also visited chaff manufacturers' representatives to
discuss the production of chaff and the development of degradable
chaff. 

To obtain information on the extent and locations of chaff use, we
performed work at the following military installations:  Fallon Naval
Air Station and Nellis Air Force Base, Nevada; Eglin Air Force Base,
Florida; and Luke Air Force Base and Yuma Marine Corps Air Station,
Arizona.  These installations conduct operations using chaff as part
of their electronic countermeasure training.  At these locations we
discussed the use of chaff, the studies that have been performed on
chaff, and public perceptions about the use and effects of chaff from
military operations. 

We reviewed environmental reports and research studies, environmental
impact statements and assessments, and other related information
dealing with the effects of chaff to determine the environmental
effects of chaff that have been documented.  Our review of these
reports was limited to an analysis of their recommendations, issues,
and questions they raised.  We grouped these into generally related
categories to assess the extent to which DOD actions related to the
categories.  We did not attempt to analyze the content of each
report.  We did note that many of these studies were carried out a
number of years ago and that research records were not readily
available. 

We conducted our review from December 1997 to July 1998 in accordance
with generally accepted government auditing standards. 


---------------------------------------------------------- Letter :9.1

Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 15 days after its issue date.  At
that time, we will make copies available to appropriate Senate and
House committees; the Secretaries of Defense, the Army, the Navy, and
the Air Force; the Commandant of the Marine Corps; and the Director,
Defense Logistics Agency. 


Please contact me on (202) 512-8412 if you or your staff have any
questions concerning this report.  Major contributors to this report
are listed in appendix V. 

Sincerely,

David R.  Warren, Director
Defense Management Issues


TYPES OF CHAFF
=========================================================== Appendix I

Chaff type    Service          Weight           Composition\a        Inventory\b
------------  ---------------  ---------------  ---------------  ---------------
RR-170A/AL    Air Force        6.4 oz.          Fiber                 23,606,750
(operational
)

RR-180/AL     Air Force        6.4 oz.          Fiber                    830,786
(operational
)

RR-188/AL     Air Force        6.4 oz.          Fiber                  1,881,503
(training)

RR-112A/AL    Air Force        7.0 oz.          Fiber                    372,720
(B-52)

RR-136C/AL    Air Force        14.4 oz.         Fiber                    939,990
(RF-4)

RR-141E/AL    Air Force        6.9 oz.          Foil                     207,557
(EF-111)

RR-149/AL     Air Force        5.9 oz.          Foil                       1,440
(B-52)

RR-149A/AL    Air Force        Unknown          Fiber                        412
(B-52)

RR-72B/AL     Air Force        Unknown          Foil                      37,800

RR-72C/AL     Air Force        Unknown          Fiber                    210,360

RR-185/RR-    Air Force        Unknown          Fiber                    235,767
ZZZ (B-52)

RR-129/AL     Navy\c           4.7 oz.          Fiber                 Classified
(operational
)

RR-144/AL     Navy\c           4.8 oz.          Fiber                 Classified
(training)

RR-171/AL     Navy\c           41-43 lbs.       Fiber                 Classified
(roll)

RR-179/AL     Navy\c           40 lbs.          Fiber                 Classified
(roll)

RR-181/AL     Navy\c           16 lbs.          Fiber                 Classified
(AIRBOC-
ship)

RR-182/AL     Navy\c           8.5 lbs.         Fiber                 Classified
(Zuni
rocket)

RR-184/AL     Navy\c           1.4 oz.          Fiber                 Classified
(operational
)

RR-189/AL     Navy\c           1.4 oz.          Fiber                 Classified
(training)

MK-182 mod 1  Navy\d           16 lbs.          Fiber                      4,841

MK-182 mod 2  Navy\d           24 lbs.          Fiber                      4,909

MK-214        Navy\d           24.3 lbs.        Fiber                     50,163

MK-216        Navy\d           16.8 lbs.        Fiber                     24,118

M-1           Army             3.5 oz.          Fiber                    310,000
--------------------------------------------------------------------------------
\a Fiber:  aluminum-coated silica glass fibers; foil:  aluminum foil. 

\b Air Force data as of May 8, 1998; Navy data as of March 3, 1998;
and Army data as of February 23, 1998. 

\c Launched from airplanes. 

\d Dispensed from ships. 


SERVICES' USE OF CHAFF DURING
FISCAL YEARS 1991-97
========================================================== Appendix II



                                    Table II.1
                     
                     Air Force Chaff Used During Fiscal Years
                                1991-97 (bundles)

                                  Fiscal year
--------------------------------------------------------------------------------
Cha
ff
typ
e         1991       1992       1993       1994       1995       1996       1997
---  ---------  ---------  ---------  ---------  ---------  ---------  ---------
RR-  1,361,216  1,689,200  1,545,715  1,412,244  1,415,496    834,827    826,669
 17
 0A
 /
 AL
RR-          0          0        530          0          0          0      4,565
 18
 0/
 AL
RR-          0        103      7,105    166,447  1,285,876  1,153,439    950,655
 18
 8/
 AL
RR-
 11
 2A
 /
 AL
 \a
RR-          0          0          0          0          0          0          0
 13
 6C
 /
 AL
RR-          0          0          0          0          0          0          0
 14
 1E
 /
 AL
RR-
 14
 9/
 AL
 \a
RR-
 14
 9A
 /
 AL
 \a
RR-
 72
 B/
 AL
 \a
RR-
 72
 C/
 AL
 \a
RR-
 185
 an
 d
 RR
 -
 ZZ
 Z\
 a
--------------------------------------------------------------------------------
\a According to Air Force logistics officials, expenditure history
for these chaff types is unknown. 



                                    Table II.2
                     
                       Navy Air-launched Chaff Used During
                      Fiscal Years 1991-97 (bundles, unless
                               otherwise indicated)

                                  Fiscal year
--------------------------------------------------------------------------------
Cha
ff
typ
e         1991       1992       1993       1994       1995       1996       1997
---  ---------  ---------  ---------  ---------  ---------  ---------  ---------
RR-    343,117    436,219    277,665    243,219    339,087    233,662    107,469
 129
RR-     34,593     89,868     79,252     84,698     74,944     91,875    197,370
 144
RR-        641        179        199        115         58         47         26
 171
 (r
 ol
 ls
 )
RR-        665        367        289        327        369        111        567
 179
 (r
 ol
 ls
 )
RR-        171        189        166        148         88        279        217
 181
RR-        552         80         24          0          0          0          0
 182
 ro
 ck
 et
RR-          0          0          0          0        352      6,637     39,712
 184
RR-          0          0          0          0          0      8,303     10,145
 189
--------------------------------------------------------------------------------



                                    Table II.3
                     
                       Navy Sea-launched Chaff Used During
                          Fiscal Years 1991-97 (bundles)

                                  Fiscal year
--------------------------------------------------------------------------------
Cha
ff
typ
e         1991       1992       1993       1994       1995       1996       1997
---  ---------  ---------  ---------  ---------  ---------  ---------  ---------
MK-      1,752      1,599      1,215      1,403      1,029      1,293        581
 182
 Mo
 d
 1
MK-        733        661      1,218        806        263        373        175
 182
 Mo
 d
 2
MK-        721      1,704      5,332      1,987      1,957      3,129      8,472
 214
MK-        186        453        619        574      1,232      1,214      1,026
 216
--------------------------------------------------------------------------------





                                    Table II.4
                     
                       Army Chaff Used During Fiscal Years
                                1991-97 (bundles)

                                  Fiscal year
--------------------------------------------------------------------------------
Cha
ff
typ
e         1991       1992       1993       1994       1995       1996       1997
---  ---------  ---------  ---------  ---------  ---------  ---------  ---------
M-           0         50          0      1,251      1,161        118        120
 1
--------------------------------------------------------------------------------





                               Table II.5
                
                     Chaff Use Reported at Military
                    Installations Reviewed (bundles)

                             Fiscal year
----------------------------------------------------------------------
Installation            Chaff type        1995        1996        1997
----------------------  ----------  ----------  ----------  ----------
Nellis Air Force Base   RR-170         122,798      98,370      58,420
 (AFB), Nev.             RR-188        271,946     186,772     194,161
Eglin AFB, Fla.         RR-170          58,509     114,444     124,787
                         RR-188            645      14,260      22,291
                         other           2,480           0         704
Luke AFB, Ariz.         RR-170             Not         Not      12,667
                         RR-188      available   available     162,053
Fallon Naval Air        RR-129          35,610      55,469           0
 Station, Nev.           RR-144         12,480      36,660      13,212
Yuma Marine Corps Air   RR-129             Not         Not      24,169
 Station, Ariz.          RR-144      available   available      34,086
----------------------------------------------------------------------

GAO-REVIEWED REPORTS ON CHAFF
RESEARCH
========================================================= Appendix III

The reports we reviewed on chaff research were issued between 1952
and 1997.  As shown below, all but one were sponsored by DOD
components. 

Environmental Effects of Self-Protection Chaff and Flares, U.S.  Air
Force Air Combat Command (Aug.  1997).\1

Aquatic Toxicity and Fate of Iron and Aluminum Coated Glass Fibers,
U.S.  Army Chemical Research, Development, and Engineering Center
(Sept.  1992).\2

Environmental and Health Effects Review for Obscurant
Fibers/Filaments, prepared by the Pacific Northwest Laboratory for
the U.S.  Army Chemical Research, Development, and Engineering Center
(Jan.  1992). 

Environmental Effects of Air National Guard Chaff Training
Activities, prepared by Science and Engineering Associates, Inc., for
the National Guard Bureau (Dec.  1990). 

Identifying and Evaluating the Effects of Dispensing Chaff From
Military Aircraft, prepared by Science and Engineering Associates,
Inc., for the Air Force Strategic Air Command (Dec.  5, 1989). 

Environmental Effects of Chaff, U.S.  Air Force Occupational and
Environmental Health Laboratory (Dec.  1978). 

Effects of Aluminized Fiberglass on Representative Chesapeake Bay
Marine Organisms, prepared by Systems Consultants, Inc., for the U.S. 
Naval Research Laboratory (Nov.  23, 1977).\3

The Ingestion of Fiberglass Chaff by Cattle, prepared by the Canada
Department of Agriculture for the Director of Electronic Warfare,
Canadian Forces Headquarters (Mar.  8, 1972). 

Chaff, Wright Air Development Center (May 1956). 

Toxicity of Chaff to Livestock, U.  S.  Air Force Aeromedicine
Laboratory (1952). 



(See figure in printed edition.)Appendix IV

--------------------
\1 Includes three technical reports on the effects of chaff dated
April 1994, October 1994, and November 1994.  Portions of the report,
including two additional technical reports, address the effects of
flares, which are not included in our scope. 

\2 We also reviewed the Army Report, Aquatic Toxicity and Fate of
Nickel Coated Graphite Fibers, With Comparisons to Iron and Aluminum
Coated Glass Fibers, U.S.  Army Chemical and Biological Defense
Agency (July 1993), but because it focused mainly on infrared
obscurants rather than radar-evading chaff, we did not include it in
our scope. 

\3 Systems Consultants, Inc., incorporated reports by two
subcontractors, the University of Delaware and the University of
Maryland. 


COMMENTS FROM THE DEPARTMENT OF
DEFENSE
========================================================= Appendix III



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V

NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C. 

Charles I.  Patton, Jr.
Uldis Adamsons
Richard W.  Meeks

LOS ANGELES FIELD OFFICE

Lionel C.  Cooper, Jr.
Gary W.  Kunkle

OFFICE OF THE GENERAL COUNSEL,
WASHINGTON, D.C. 

Margaret L.  Armen

*** End of document. ***