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entitled 'Defense Infrastructure: Additional Information Is Needed to 
Better Explain the Proposed 100,000-Acre Expansion of the Piñon Canyon 
Maneuver Site' which was released on January 13, 2009.

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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

January 2009: 

Defense Infrastructure: 

Additional Information Is Needed to Better Explain the Proposed 100,000-
Acre Expansion of the Piñon Canyon Maneuver Site: 

GAO-09-171: 

GAO Highlights: 

Highlights of GAO-09-171, a report to congressional committees. 

Why GAO Did This Study: 

In 2007, the Army announced that the Office of the Secretary of Defense 
(OSD) had approved its request to expand its Piñon Canyon Maneuver 
Site, Colorado, by acquiring up to an additional 418,577 acres. The 
National Defense Authorization Act for Fiscal Year 2008 required the 
Army to address 29 provisions related to the expansion in a report to 
Congress. In July 2008, the Army reported that, although it had 
revalidated the requirement for at least 418,577 additional acres at 
the maneuver site, in response to community, cost, and other concerns 
it now proposed to limit the acquisition of additional training land to 
100,000 acres. 

The act also required GAO to review the Army’s report and the 
justification for the proposed expansion. This report examines the 
extent to which the Army’s report (1) addresses the provisions of the 
mandate and (2) explains the selection of the 100,000-acre site. GAO 
compared the mandate requirements with the responses in the Army’s 
report, met with Army officials to discuss the expansion, and visited 
the Piñon Canyon Maneuver Site and Fort Carson. 

What GAO Found: 

While the Army’s 2008 report on the Piñon Canyon Maneuver Site 
generally addresses the provisions of the National Defense 
Authorization Act for Fiscal Year 2008, the report is lacking certain 
information that would help clarify six of the Army’s responses to the 
mandate. For example, the Army provided a list of all the training 
activities that occurred at Piñon Canyon from May 2007 to April 2008, 
but this information does not indicate how much of the training area 
was used, nor does it indicate whether any of these exercises were 
performed simultaneously. Therefore, the report is not clear regarding 
how much of the maneuver site was used for training in a given month or 
annually and whether the units could train simultaneously. It is also 
unclear how this information was used to support the required analysis 
of the maximum annual training load without the proposed expansion of 
the site. Without additional information on the mandated provisions, it 
is difficult for Congress and the public to fully understand six of the 
Army’s responses to the mandated provisions. 

The Army’s report does not fully explain the current selection of the 
100,000-acre site. Following are examples of specific issues not 
addressed in the Army’s report: 

* The Army reported that it has reduced the amount of land it intends 
to purchase from 418,577 to 100,000 acres but did not explain its basis 
for selecting fewer acres or the specific site. 

* The estimated cost per acre used for internal planning to acquire 
additional land at the maneuver site has increased since 2007 but the 
Army’s report does not discuss this increase. 

* The Army completed the required analyses when requesting OSD’s 
approval for the up to 418,577-acre expansion, but has not completed an 
analysis for the current 100,000-acre proposal that would help to 
understand, among other items, how much of the 100,000 acres would 
actually be used for training, what type of training can be conducted, 
and what are the estimated costs to maintain the 100,000 acres. 

Army officials said that these questions and others would be difficult 
to address without the analysis required by the National Environmental 
Policy Act of 1969. Although the Army issued the mandated report, Army 
officials stated that, to date, the Army has voluntarily declined to 
spend other appropriated funds to begin the National Environmental 
Policy Act process due to congressional concerns about the potential 
effects of the proposed expansion. The officials further stated that 
uncertainty over congressional support for the potential expansion made 
a delay in expending funds to start the National Environmental Policy 
Act process appear to be prudent. Without the benefit of the analyses 
and information on how the Army identified the 100,000 acres currently 
being proposed for acquisition, especially in light of the growth in 
the estimated price per acre, it is difficult for Congress and the 
public to evaluate the full benefits and costs associated with the 
proposed 100,000-acre expansion. 

What GAO Recommends: 

GAO recommends that the Army provide Congress with additional 
information explaining (1) six of the responses to the mandate and (2) 
the rationale for selecting the 100,000 acres for the proposed 
expansion. DOD partially agreed with the recommendations. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-171]. For more 
information, contact Brian J. Lepore at (202) 512-4523 or 
leporeb@gao.gov. 

[End of section] 

Letter: 

Results in Brief: 

Background: 

The Army's Report Generally Addresses the Mandate, but Additional 
Information Would Help to Better Understand Its Responses: 

The Army's Report Does Not Fully Explain the Identification of 100,000- 
Acre Site for the Proposed Expansion of the Piñon Canyon Maneuver Site: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Reporting Categories and Provisions of Section 2831 of the 
National Defense Authorization Act for Fiscal Year 2008: 

Appendix III: Comments from the Department of Defense: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Information That Would Help Clarify the Army's Response to Six 
Provisions of the National Defense Authorization Act for Fiscal Year 
2008: 

Table 2: Reporting Categories and Provisions of the National Defense 
Authorization Act for Fiscal Year 2008 and Whether the Provisions Were 
Adequately Addressed in the Army's 2008 Report: 

Abbreviations: 

DOD: Department of Defense: 

NEPA: National Environmental Policy Act: 

OSD: Office of the Secretary of Defense: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

January 13, 2009: 

Congressional Committees: 

The Army has reported that its training land shortfall will reach 4.5 
million acres by 2013 due to the combined effects from a variety of 
initiatives, including the 2005 base realignment and closure 
recommendations, Grow the Army initiative, and transformation and 
modularity,[Footnote 1] which have increased training land requirements 
at installations across the continental United States. In its 2004 
Range and Training Land Strategy,[Footnote 2] the Army identified Fort 
Carson, Colorado, specifically its nearby Piñon Canyon Maneuver Site 
training area, as an installation where land acquisition could be a 
possible solution to help address the training land shortfall. In 
February 2007, the Army announced that the Office of the Secretary of 
Defense (OSD) had approved its request to expand the current 235,300 
acres of the Piñon Canyon Maneuver Site by acquiring up to an 
additional 418,577 acres for training. 

However, the proposed expansion has drawn criticism from some affected 
landowners and interest groups and has raised the attention of some 
members of Congress with respect to how any acquired land will be used. 
For instance, the National Defense Authorization Act for Fiscal Year 
2007[Footnote 3] contained a mandate that required the Army to provide 
Congress details concerning current and future training requirements at 
Fort Carson and Piñon Canyon Maneuver Site. In response, the Army 
reported in December 2006 that transformation is the primary factor 
causing the largest increase in the Army's training land requirements. 
For instance, transformation to a modular force increases the acreage 
required for training a single brigade combat team by nearly 144 
percent, from around 66,000 acres before transformation to 
approximately 161,000 acres after. 

The Consolidated Appropriations Act, 2008, which was enacted on 
December 26, 2007, stated that none of the funds appropriated or 
otherwise made available in the act may be used for any action that is 
related to or promotes the expansion of boundaries or the size of the 
Piñon Canyon Maneuver Site.[Footnote 4] Army officials stated that they 
redirected the focus of contract employees that had been working on 
potential expansion efforts to instead support the Army's response to 
section 2831(a) of the National Defense Authorization Act for Fiscal 
Year 2008,[Footnote 5] which required the Army to address 29 provisions 
pertaining to the potential expansion of Piñon Canyon in a report to 
Congress. These provisions fall in three categories: (1) an analysis of 
whether existing training facilities are sufficient to support training 
needs, (2) a report of need for any proposed addition of training land 
to support units stationed or planned to be stationed at Fort Carson, 
and (3) an analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion. Army officials told us that for the purposes of 
the preparation of this mandated report, they used operations and 
maintenance funds that, in their view, were not subject to the above- 
referenced prohibition. In its report responding to this mandate, the 
Army reported in July 2008 that, although it had revalidated the 
requirement for at least 418,577 additional acres at the maneuver site, 
in response to community, cost, and other concerns it now proposed to 
limit the acquisition of additional training land to 100,000 acres 
south of the existing site. Further, the Consolidated Security, 
Disaster Assistance, and Continuing Appropriations Act, 2009, which was 
enacted in September 2008, stated that none of the funds appropriated 
or otherwise made available in Division E, Title I of the act may be 
used for any action that is related to or promotes the expansion of 
boundaries or size of the Piñon Canyon Maneuver Site.[Footnote 6] 
According to Army officials, these funding restrictions apply only to 
Military Construction Appropriations and do not preclude the Army from 
further studying the 100,000-acre site or starting the National 
Environmental Policy Act (NEPA) of 1969 process using other 
appropriations.[Footnote 7] However, the officials stated that, to 
date, the Army has voluntarily declined to spend other appropriated 
funds to begin the NEPA process due to congressional concerns. 

The National Defense Authorization Act for Fiscal Year 2008[Footnote 8] 
also required us to review the Army's 2008 report on the Piñon Canyon 
Maneuver Site and the justification for the proposed expansion of the 
Piñon Canyon Maneuver Site, and to submit a report to Congress 
regarding the results of our review no later than 180 days from the 
release of the Army's report. This report examines the (1) extent to 
which the Army's report addresses the provisions of the mandate and 
where additional information would help clarify the Army's responses, 
and (2) extent to which the Army's report explains the current 
identification of the 100,000-acre site for the potential expansion of 
the Piñon Canyon Maneuver Site. 

In conducting our review, we examined all 29 reporting provisions 
contained in the National Defense Authorization Act for Fiscal Year 
2008 and compared them with the responses provided in the Army's 2008 
report on the Piñon Canyon Maneuver Site. We met with appropriate Army 
officials to understand and document the reasons for the Army's 
responses and to discuss how the proposed expansion would benefit 
training at Fort Carson. We also visited Fort Carson and the Piñon 
Canyon Maneuver Site to see firsthand existing training facilities and 
ranges. We also obtained and reviewed key policies and guidance the 
Army has developed for managing its training lands and ranges to 
determine how they were used by the Army to justify the need for the 
expansion at Piñon Canyon Maneuver Site.[Footnote 9] We conducted this 
performance audit from August 2008 through January 2009, in accordance 
with generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings and 
conclusions based on our audit objectives. We believe that the evidence 
obtained provides a reasonable basis for our findings and conclusions 
based on our audit objectives. A detailed description of our scope and 
methodology is included in appendix I of this report. 

Results in Brief: 

While the Army's 2008 report on Piñon Canyon Maneuver Site generally 
addresses the provisions laid out in section 2831 of the National 
Defense Authorization Act for Fiscal Year 2008 by providing responses 
to each of the 29 provisions,[Footnote 10] the report is lacking 
certain information that would help clarify the Army's responses about 
whether existing training facilities are sufficient to support the 
training needs and alternatives for enhancing economic development 
opportunities for southeastern Colorado for 6 of the 29 mandated 
provisions. For example, in one response about whether existing 
training facilities are sufficient to support the training needs, the 
Army provided a list of all the training activities that occurred at 
Piñon Canyon Maneuver Site from May 2007 to April 2008, but this 
information did not indicate how much of the training area was used, 
nor did it indicate whether any of these exercises were performed 
simultaneously. Therefore, the report is not clear about how much of 
the Piñon Canyon Maneuver Site was used for training in a given month 
or annually or whether the units could train simultaneously, and it is 
unclear how this information was used to support the required analysis 
of the maximum annual training load without the proposed expansion of 
the maneuver site. In another response, the Army was required to 
provide a training calendar showing all planned brigade combat teams 
stationed or planned to be stationed at Fort Carson at home station. 
The calendar depicts all the brigade combat teams that are planned to 
be stationed at Fort Carson as assigned to Fort Carson, but shows at 
least two of these brigade combat teams deployed. Since Army officials 
told us that the proposed expansion is based on peacetime assumptions, 
the Army report is not clear as to why the calendar depicts brigade 
combat teams as being deployed, given that in peacetime the teams would 
be less likely to be deployed. In a response to alternatives for 
enhancing economic development opportunities for southeastern Colorado, 
the Army reported that it eliminated from consideration the option to 
station an active duty unit at Piñon Canyon Maneuver Site during its 
Programmatic Environmental Impact Statement for Grow the Army and that 
surrounding communities do not have the infrastructure required to 
support the stationing of units. However, the Army's response does not 
explain or describe the analysis used in the environmental impact 
statement; therefore, it is unclear how the Army came to the conclusion 
that stationing units at the Piñon Canyon Maneuver Site is unfeasible. 
Without certain additional information on the mandated provisions, it 
is difficult for Congress and the public to fully understand some of 
the Army's responses in its report. 

The Army's 2008 report on the Piñon Canyon Maneuver Site does not fully 
explain the current identification of the 100,000-acre site for the 
proposed expansion. Since OSD approved the expansion of the maneuver 
site in 2007, both the acreage proposed for acquisition and price per 
acre have changed, and several important questions about the 100,000- 
acre site selected for acquisition have not been addressed. First, in 
its 2008 report, the Army stated that it has reduced the amount of land 
it intends to acquire, but did not provide a detailed explanation of 
how it identified the smaller site. Second, the estimated cost used for 
internal planning to acquire additional land at the Piñon Canyon 
Maneuver Site has increased since February 2007, when OSD initially 
approved the Army's request to expand the maneuver site. However, the 
Army's report does not discuss this increase in the price per acre. 
Third, several important questions about the 100,000 acres selected for 
acquisition have not been fully explained. While the Army completed the 
required analyses outlined in Army Regulation 350-19[Footnote 11] in 
requesting OSD's approval for the acquisition of up to 418,577 acres to 
expand the Piñon Canyon Maneuver Site, the request was justified on the 
estimated costs and benefits of the full 418,577-acre proposal and not 
on a smaller acquisition. However, the Army has not fully explained (1) 
how much of the 100,000 acres would actually be used for training, (2) 
what benefits would be gained from adding the 100,000 acres to the 
existing Piñon Canyon Maneuver Site, (3) what effect sustainment and 
maintenance activities would have on training on the 100,000 acres, and 
(4) what the future costs would be for sustaining and maintaining the 
100,000 acres. Army officials said that these questions and others 
would be difficult to address without the analysis required by NEPA. As 
previously noted, the Consolidated Appropriations Act, 2008,[Footnote 
12] prohibited the use of funds appropriated or otherwise made 
available for any action that is related to or promotes the expansion 
of the Piñon Canyon Maneuver Site, and the Consolidated Security, 
Disaster Assistance, and Continuing Appropriations Act, 2009,[Footnote 
13] prohibited the use of funds appropriated or otherwise made 
available in Division E, Title 1 of the act for any action that is 
related to or promotes the expansion of the Piñon Canyon Maneuver Site. 
Army officials said these funding restrictions apply only to Military 
Construction Appropriations and do not preclude the Army from further 
studying the 100,000-acre site or starting the NEPA process using other 
appropriated funds. The officials also stated that, to date, the Army 
has voluntarily declined to spend other appropriated funds to begin the 
NEPA process due to congressional concerns. The officials further 
stated that uncertainty over congressional support for the potential 
expansion made a delay in expending funds to start the NEPA process 
appear to be prudent. Further, Army officials explained that the Army 
would not begin the NEPA analysis for the potential expansion without 
consulting with congressional stakeholders and having a reasonable 
expectation that military construction funds would be available for the 
potential acquisition. Without knowing how the Army identified the 
100,000 acres currently being proposed for acquisition and several 
other questions about benefits and costs of the proposed expansion, it 
is difficult for Congress and the public to evaluate the full benefits 
and costs associated with the proposed 100,000-acre expansion. 

We are recommending that the Army provide Congress and the public with 
additional information further explaining (1) the six responses about 
whether existing training facilities are sufficient to support the 
training needs and about alternatives for enhancing economic 
development opportunities for southeastern Colorado, and (2) the 
reasons the Army selected the current 100,000-acre site for the 
proposed expansion and the growth in the estimated price per acre, as 
well as more detailed information on how much of the 100,000 acres 
would actually be used for training, what benefits would be gained from 
adding the 100,000 acres to the existing maneuver site, what effect 
sustainment and maintenance activities would have on training on the 
100,000 acres, and what the future costs would be for sustaining and 
maintaining the 100,000 acres. In written comments on a draft of this 
report, the Army partially agreed with our recommendations, but did not 
specify what actions, if any, it would take to implement them. In 
addition, the Army raised a variety of concerns including our 
characterization of its report and our initial inclusion of cost 
estimates used for internal planning purposes. While we recognize that 
the Army had certain concerns about our report, we continue to believe 
the opportunity exists to improve its responses to Congress, hence the 
need for our recommendations. We discuss the Army's comments in detail 
later in this report. 

Background: 

The Army, in its initial Range and Training Land Strategy, identified 
Fort Carson--specifically its Piñon Canyon Maneuver Site--as one 
installation where potential land acquisition would be a feasible 
solution to addressing overall training land shortfalls.[Footnote 14] 
Fort Carson is located south of Colorado Springs, Colorado, and has 
command over and administrative responsibility for the existing Piñon 
Canyon Maneuver Site, a maneuver training facility located 150 miles 
away in the southeastern area of the state. The maneuver site consists 
of 235,000 acres, 95 percent (224,000 acres) of which is available for 
maneuver training for soldiers stationed at Fort Carson and other 
installations. 

Proposed Expansion of the Piñon Canyon Maneuver Site: 

In March 2005, the Army completed a Land Use Requirements Study that 
examined the availability of training areas within Piñon Canyon 
Maneuver Site and concluded that a shortfall of approximately 418,500 
acres existed that needed to be addressed in order to meet training 
requirements. The Army concluded that it needed additional land as the 
result of the 2005 base realignment and closure, Grow the Army, and 
transformation and modularity initiatives, which would increase the 
number of brigade combat teams permanently stationed at Fort Carson 
from one to five. Also, the number of soldiers is now expected to grow 
from 14,500 to 28,500 by 2011 as the result of these initiatives. 

In July 2006, the Army developed a land acquisition proposal in order 
to secure approval from OSD to pursue an expansion of up to 418,577 
acres at Piñon Canyon Maneuver Site. The proposed expansion area at 
that time consisted of 100,000 acres of contiguous land directly south 
of the existing Piñon Canyon Maneuver Site and 318,577 acres located to 
the west of the site. Prior to OSD approval, information regarding the 
expansion was unofficially disclosed to the press. This information, 
including a map of the proposed expansion area, did not provide a 
clear, complete, or accurate explanation of the Army's need for and 
approach to acquiring additional land or of the Army's plans to also 
use other strategies to meet critical training needs, and thus caused 
concern regarding the Army's acquisition plans among some affected 
landowners and interest groups. 

Congressional Reporting Requirements and Direction: 

The proposed expansions also raised the attention of Congress, which 
sought more detailed information from the Army regarding any expansion 
of the Piñon Canyon Maneuver Site. In response to section 2827 of the 
National Defense Authorization Act for Fiscal Year 2007,[Footnote 15] 
the Army provided a report to Congress that addressed questions related 
to training requirements at Piñon Canyon Maneuver Site,[Footnote 16] 
such as a description of the current and projected military 
requirements, an analysis of the reasons for changes in training 
requirements, and a proposed plan for addressing shortfalls in training 
requirements. In February 2007, OSD approved the Army's request to 
expand the Piñon Canyon Maneuver Site. However, the Consolidated 
Appropriations Act, 2008, which was enacted in December 2007, stated 
that none of the funds appropriated or otherwise made available in the 
act may be used on any action that is related to or promotes the 
expansion of the boundaries or size of the Piñon Canyon Maneuver Site. 
[Footnote 17] Army officials stated that as a result, they redirected 
the focus of contract employees that had been working on potential 
expansion efforts to instead support the Army's response to section 
2831 of the National Defense Authorization Act for Fiscal Year 
2008,[Footnote 18] which required the Army to provide Congress with a 
report regarding its plans for expansion at the Piñon Canyon Maneuver 
Site within 6 months of the law's passage. Specifically, section 2831 
of the act requires that the Army's report provide responses to 29 
provisions that are categorized under three broad reporting categories: 
(1) an analysis of whether existing training facilities are sufficient 
to support training needs, (2) a report of need for any proposed 
addition of training land to support units stationed or planned to be 
stationed at Fort Carson, and (3) an analysis of alternatives for 
economic development opportunities in southeastern Colorado at the site 
or through any proposed expansion. Army officials told us that for the 
purposes of preparing the report required by section 2831 of the 
National Defense Authorization Act for Fiscal Year 2008, they used 
operations and maintenance funds that, in their view, were not subject 
to the above-referenced prohibition on the use of funds for any action 
related to or promoting the expansion of the boundaries or size of the 
Piñon Canyon Maneuver Site. The Army provided its report to Congress in 
July 2008. Further, the Consolidated Security, Disaster Assistance, and 
Continuing Appropriations Act,[Footnote 19] which was enacted in 
September 2008, stated that none of the funds appropriated or otherwise 
made available in Division E, Title I of the act may be used on any 
action that is related to or promotes the expansion of the boundaries 
or size of the Piñon Canyon Maneuver Site. According to Army officials, 
these funding restrictions apply only to Military Construction 
Appropriations and do not preclude the Army from further studying the 
100,000-acre site or starting the NEPA process using other 
appropriations. However, the officials stated that, to date, the Army 
has voluntarily declined to begin the NEPA process due to congressional 
concerns. The officials further stated that uncertainty over 
congressional support for the potential expansion made a delay in 
expending funds to start the NEPA process appear to be prudent. 

Army's Guidance and Approach to Acquiring Land: 

Army officials stated they address training land shortfalls through 
four major strategies that include (1) focused land management; (2) 
acquisition of buffers to mitigate encroachment; (3) utilization of 
other federal lands; and (4) when necessary, land acquisition. In order 
to proceed with a major land acquisition--defined as those exceeding 
1,000 acres or costing more than $1 million--the Army is required to 
seek approval from OSD because on September 13, 1990, OSD issued a 
Department of Defense (DOD) wide moratorium on major land acquisitions. 
The Secretary of Defense later revised and updated DOD's land 
acquisition moratorium policy in October 1990, December 1994, November 
2002, and July 2005. Waivers to this moratorium may be granted by the 
Secretary or Office of the Secretary of Defense on a case-by-case basis 
if a military service can justify to OSD a need to acquire more land. 
When justifying a land acquisition in order to obtain OSD waiver 
approval, such as the justification that was prepared in order to 
obtain the waiver approval to pursue the potential land acquisition at 
the Piñon Canyon Maneuver Site, Army officials follow a process and 
methodology used to determine the amount of land needed to fulfill 
training requirements. This multistep process entails three key steps-
-a doctrinal analysis,[Footnote 20] operational analysis, and 
sustainability analysis. 

* Doctrinal analysis. Army officials use the Army Range Requirements 
Model to determine the doctrinal training requirement--the total amount 
of land needed to completely meet doctrinal standards. The model 
calculates how much land is needed to train a unit for a specific task 
and how much land is needed based on Army doctrine and data from 
several administrative and operational data systems. The training land 
requirements calculated by the model are simply a baseline of what the 
Army needs and are not the final results. For example, the model does 
not account for certain factors that impact training, such as the 
condition of training land assets, past usage of training land and 
ranges, environmental restrictions, protection of cultural resources, 
and encroachment pressures. The operational and sustainability analyses 
adjust the model's calculations to account for those factors that the 
model itself does not consider. 

* Operational analysis. Army officials complete an operational analysis 
that compares the doctrinal requirement with current range and training 
land assets, the rate of use of these assets, and the condition of the 
training land and ranges to determine which facilities are suitable and 
not suitable for training. They adjust the range requirements model's 
calculation based on the result of this analysis. 

* Sustainability analysis. Army officials undertake a sustainability 
analysis to account for factors, such as the use of training land by 
other military services, environmental restrictions, and encroachment 
pressures that make training land unusable. The results of the 
sustainability analysis show the optimum amount of land the Army would 
need to mitigate the impact of maneuver training damage. When possible, 
the Army prefers to use land on a rotational basis to allow it to 
recover from training, because increasing the concentration of training 
exercises in a limited area of land can result in less time for 
recovery and, consequently, additional repair and sustainment projects 
that require funding. Army officials adjust the results of the 
operational analysis based on the result of this sustainability 
analysis. 

After these analyses, if the proposed land acquisition project exceeds 
$1 million or is greater than 1,000 acres, the Army installation 
prepares and coordinates a major land acquisition proposal in order to 
request a waiver to the department's moratorium on major land 
acquisitions and submits the proposal to Army headquarters for review, 
coordination, and approval. If the request is approved, Army 
headquarters then submits the major land acquisition proposal to OSD 
for approval to proceed with the land acquisition. The proposal 
includes, where applicable, information from the range complex master 
plan, the range development plan, and analysis of alternatives study 
together with the purpose of the acquisition, estimate of cost, 
assessment of the potential environmental impacts, and consideration of 
alternatives. If the waiver request is denied by OSD, the process ends. 

If OSD approves the waiver request, the Army then must address the 
requirements of NEPA and the associated regulations established by the 
Council on Environmental Quality, which require, in part, that all 
federal agencies, including the Army, to evaluate the likely 
environmental effects of projects they are proposing using an 
environmental assessment or, if the project constitutes a major federal 
action significantly affecting the quality of the human environment, a 
more detailed environmental impact statement. If an environmental 
impact statement is required for a particular acquisition, it must 
include a purpose and need statement, a description of all reasonable 
project alternatives and their associated environmental impacts 
(including a "no action" alternative), a description of the environment 
of the area to be affected or created by the alternatives being 
considered, and an analysis of the environmental impacts of the 
proposed action and each alternative.[Footnote 21] Until an agency 
issues a final environmental impact statement and record of decision, 
an agency generally may not take any action concerning the proposal 
which would either have an adverse environmental impact or limit the 
choice of reasonable alternatives. If the decision in the record of 
decision is to acquire the land, OSD then requests congressional 
approval to acquire the land. If Congress approves OSD's request, 
Congress authorizes the land acquisition and appropriates the necessary 
funds. 

We more fully describe the Army's approach for acquiring additional 
training land, including the information in the Army Range Requirements 
Model, in a separate January 13, 2009, report.[Footnote 22] 

The Army's Report Generally Addresses the Mandate, but Additional 
Information Would Help to Better Understand Its Responses: 

The Army's 2008 report on the Piñon Canyon Maneuver Site generally 
addresses section 2831 of the National Defense Authorization Act for 
Fiscal Year 2008 by responding to each of the mandate's 29 provisions. 
For example, the report described additional training activities that 
could be conducted if the site was expanded and adequately addressed 23 
of the mandated provisions. However, we found that the responses to six 
of the provisions--on whether existing training facilities are 
sufficient to support the training needs and alternatives for enhancing 
economic development opportunities for southeastern Colorado--were not 
clear and lacked information that would help provide the reader a 
better understanding (see table 1). 

Table 1: Information That Would Help Clarify the Army's Response to Six 
Provisions of the National Defense Authorization Act for Fiscal Year 
2008: 

Provision: Section 2831(a)(2)(A)(iii)(I): An analysis of whether 
existing training facilities at Fort Carson, Colorado, and the site are 
sufficient to support the training needs of units stationed or planned 
to be stationed at Fort Carson, including a description of the current 
training calendar and training load at the site, including the number 
of brigade-sized and battalion-sized military exercises held at the 
site since its establishment; 
Information that would help clarify the response: The Army reported the 
number of military brigade-sized and battalion-sized exercises held at 
Piñon Canyon Maneuver Site from October 2004 to April 2008, even though 
the provision requires that the Army list the number of exercises since 
the establishment of the site. Although the Army noted that the system 
it uses to capture training exercises began tracking training events in 
2004, it does not mention how or whether such exercises were tracked 
prior to 2004. However, in its 2007 report on Piñon Canyon Maneuver 
Site, the Army indicated that it has been using the area to conduct 
training exercises since 1985 but Army officials said that the 
requested data did not existed for the early years. Still, additional 
information would help the reader better understand why the Army did 
not provide the number of training events since the establishment of 
the Piñon Canyon Maneuver Site. 

Provision: Section 2831(a)(2)(A)(iii)(II): An analysis of whether 
existing training facilities at Fort Carson, Colorado, and the site are 
sufficient to support the training needs of units stationed or planned 
to be stationed at Fort Carson, including a description of the current 
training calendar and training load at the site, including an analysis 
of the maximum annual training load at the site, without expanding the 
site; 
Information that would help clarify the response: The Army reported the 
annual training load at Piñon Canyon Maneuver Site from May 2007 to 
April 2008. However, this information does not indicate how much of the 
maneuver site was used, nor does it indicate whether any of these 
exercises were performed simultaneously. Such information would help 
the reader understand how much of the maneuver site is used for 
training during a given month or annually. Also, an explanation as to 
how this information was used to support the required analysis of the 
maximum annual training load without the proposed expansion would help 
the reader better understand how the Army developed its response to 
this provision. The Army reported that adjustments to training events, 
referred to as "workarounds," would be necessary to fully meet training 
requirements without the expansion of the Piñon Canyon Maneuver Site 
and that workarounds would have a negative impact on training. However, 
the Army does not describe the nature of these workarounds or how they 
would impact the training load. Such information would help the reader 
better understand the type and amount of workarounds necessary to fully 
meet training requirements at the existing Piñon Canyon Maneuver Site 
and the potential benefits of an expansion that would obviate the need 
for such workarounds. The Army reported that increased usage of current 
training land would result in higher operational costs and greater 
environmental damage to the land, but does not provide specific 
information regarding operational costs or the specific effects of 
increased usage of training land to support this observation. This 
information would help the reader clearly understand the type and 
amount of costs involved with not expanding the Piñon Canyon Maneuver 
Site. 

Provision: Section 2831(a)(2)(A)(iii)(III): An analysis of whether 
existing training facilities at Fort Carson, Colorado, and the site are 
sufficient to support the training needs of units stationed or planned 
to be stationed at Fort Carson, including a description of the current 
training calendar and training load at the site, including an analysis 
of the training load and projected training calendar at the site when 
all brigades stationed or planned to be stationed at Fort Carson are at 
home station; 
Information that would help clarify the response: The Army provided a 
training calendar in appendix E of the report that lists all brigade 
combat teams stationed and planned to be stationed at Fort Carson, but 
the calendar shows that at least two of the brigade combat teams are to 
be deployed in support of Operation Iraqi Freedom (Global War on 
Terrorism). Since Army officials told us that acquisition plans are 
made using peacetime assumptions, it is unclear why the Army chose to 
use a training calendar in which not all the brigade combat teams are 
physically present at home station. Additional information explaining 
the training calendar would help the reader to better understand why 
the Army chose to show its brigade combat teams deployed when the 
acquisition is based on peacetime assumptions. Additional information 
would also help the reader to better understand how deployment affects 
training at the Piñon Canyon Maneuver Site. The Army reported that, 
while there is currently a training land shortfall at Fort Carson and 
the Piñon Canyon Maneuver Site, units are able to effectively train 
using minor workarounds. With the increase in population at Fort 
Carson, the Army reported that, without an expansion, the shortfall 
would result in major training workarounds and less than optimal 
training. It also reported that units would not be able to meet their 
training requirements. However, the Army does not include a description 
of the nature of these workarounds, the difference between minor and 
major workarounds, or the training requirements that would not be met. 
Such information would help the reader better understand the type and 
amount of workarounds necessary to fully meet training requirements at 
the existing Piñon Canyon Maneuver Site and the potential benefits of 
an expansion. 

Provision: Section 2831(a)(2)(C)(iii): An analysis of alternatives for 
enhancing economic development opportunities in southeastern Colorado 
at the current site or through any proposed expansion, including 
consideration of the procurement of additional services and goods, 
including biofuels and beef, from local businesses; 
Information that would help clarify the response: The Army's response 
discusses measures it would take to assist the local economy, such as 
encouraging units to purchase goods in support of future training 
events from local merchants near the Piñon Canyon Maneuver Site and 
hosting contract training events for local small businesses. While the 
Army's response discusses the procurement of additional services and 
goods from local businesses (which presumably would be applicable to 
the procurement of biofuels and beef), the report does not include a 
specific discussion of procuring biofuels and beef from local 
businesses. It is unclear why the Army did not directly address 
biofuels or beef specifically. Clarification as to why this information 
was not included would help the reader better understand how the Army 
developed its response to this provision. 

Provision: Section 2831(a)(2)(C)(viii): An analysis of alternatives for 
enhancing economic development opportunities in southeastern Colorado 
at the current site or through any proposed expansion including 
consideration of additional investments in Army missions and personnel, 
such as stationing an active duty unit at the site; 
Information that would help clarify the response: The Army reported 
that it is not consider stationing an active duty unit at Piñon Canyon 
Maneuver Site because such an option was eliminated during its 
Programmatic Environmental Impact Statement for Grow the Army[A] and 
that surrounding communities do not have the infrastructure required to 
support the stationing of units. However, by not explaining or 
describing the analysis used in the environmental impact statement, it 
is unclear how the Army came to the conclusion that stationing units at 
the Piñon Canyon Maneuver Site is unfeasible. 

Provision: Section 2831(a)(2)(C)(viii)(I): An analysis of alternatives 
for enhancing economic development opportunities in southeastern 
Colorado at the current site or through any proposed expansion, 
including consideration of additional investments in Army missions and 
personnel, such as stationing an active duty unit at the site, 
including an analysis of anticipated operational benefits; 
Information that would help clarify the response: The Army's 
explanation regarding the anticipated operational benefits of 
stationing an active duty unit at Piñon Canyon Maneuver Site lacks 
specifics. For instance, the Army reported that operational benefits 
resulting from the stationing of units at Piñon Canon Maneuver Site are 
limited because the site lacks the infrastructure required to support a 
unit, but it does not explain the types of infrastructure that are 
needed. In addition, the Army's response does not include information 
on the costs associated with the necessary infrastructure, nor does it 
include information on the types of operational benefits this 
infrastructure would provide. As such, it is unclear as to what type of 
operational benefits would arise if the necessary infrastructure was in 
place. Providing such information would make it easier for the reader 
to understand how the Army determined that there would be little or no 
operational benefit to stationing a unit at Piñon Canyon Maneuver Site. 

Source: GAO analysis of the National Defense Authorization Act for 
Fiscal Year 2008 and the Army's 2008 report on the Piñon Canyon 
Maneuver Site. 

[A] Department of the Army, Final Programmatic Environmental Impact 
Statement for Army Growth and Force Structure Realignment (Washington, 
D.C.: Oct. 26, 2007). 

[End of table] 

Army officials said that the 2008 report was reviewed at several 
different management levels within the Department of the Army and was 
intentionally written in a manner that would be easily understood by 
the public after receiving criticisms concerning the technical nature 
of the previous report on the Piñon Canyon Maneuver Site in response to 
the National Defense Authorization Act for Fiscal Year 2007. As a 
result, some information and technical data were revised or deleted 
during this review and approval process. Nonetheless, without 
additional information on these provisions, it is difficult for 
Congress and the public to fully understand the Army's responses to 
these provisions. 

The Army's Report Does Not Fully Explain the Identification of 100,000- 
Acre Site for the Proposed Expansion of the Piñon Canyon Maneuver Site: 

The Army's 2008 report on the Piñon Canyon Maneuver Site does not fully 
explain the current identification of the 100,000-acre site for the 
proposed expansion. Since OSD approved the Army's pursuit of the 
expansion of the maneuver site in 2007, both the acreage proposed for 
acquisition and the price per acre used for planning purposes have 
changed, and several important questions about benefits and costs of 
the 100,000-acre site selected for acquisition have not yet been fully 
explained. Army officials said that these questions would be addressed 
during the analysis required by the NEPA process. However, Army 
officials stated that the Army would not begin the NEPA process for the 
potential expansion without consulting with congressional stakeholders 
and having a reasonable expectation that military construction funds 
would be available for the potential acquisition. 

The Army's Report Does Not Fully Explain the Identification of the 
Smaller Site: 

The Army based its original request to expand Piñon Canyon Maneuver 
Site by 418,577 acres on doctrinal requirements, but in its 2008 report 
reduced this amount to 100,000 acres because of budgetary constraints, 
concerns about potential historic and culturally sensitive areas, and 
the fewer number of landowners with which to deal compared with the 
larger number of landowners on the original 418,577 acres. However, the 
Army did not provide further details on how it selected the fewer acres 
or the specific 100,000-acre site south of the current maneuver site. 
The Army reported that, although it had revalidated the requirement for 
up to 418,577 additional acres at Piñon Canyon, the 100,000-acre 
expansion would be used to develop a training complex capable of 
supporting maneuver and live fire for a combined arms battalion and 
would provide sufficient space to allow a heavy brigade combat team and 
an infantry brigade combat team to conduct simultaneous combat training 
exercises. 

The Army's Report Does Not Discuss the Growth in the Price per Acre: 

While the estimated cost to acquire additional land at the Piñon Canyon 
Maneuver Site has increased, the Army's report does not disclose this 
increase. For example, the report did not disclose that the estimated 
cost per acre used for internal planning purposes has increased from 
about $280 per acre since February 2007, when OSD initially approved 
the Army's request to expand the maneuver site by 418,577 acres. At 
that time, the estimated cost for the acquisition included the costs of 
the land, improvements, relocation assistance, and administrative costs 
and the goal was to complete the land acquisition within 5 years. 

More recently, the Army's fiscal years 2010-2015 planning budget shows 
that it is budgeting $52.6 million ($17.6 million in fiscal year 2010, 
$20 million in fiscal year 2011, and $15 million in fiscal year 2012) 
in military construction funds to expand the Piñon Canyon Maneuver 
Site. According to an Army official, the increased cost estimate partly 
reflects the idea that buying only from willing sellers and refraining 
from using eminent domain could increase the per acre cost average. 
Also, the Army shortened the acquisition schedule from 5 to 3 years in 
an attempt to accommodate the concerns of expansion opponents who 
asserted that the uncertainties over expansion have caused economic 
hardship for some nearby landowners in terms of making investment 
decisions on their land. According to the Army, opponents have stated 
that local banks are less willing to lend money to nearby landowners 
for their agribusinesses whose future operations are in question. So to 
reduce the length of uncertainty, and create more clarity, the Army 
shortened the acquisition schedule. 

If the Army moves forward to acquire the land, Army officials said that 
they are uncertain whether acquisition costs may increase or decrease 
because of changes in economic and other conditions that are likely to 
occur between now and when the potential acquisition would be 
finalized. The process to complete the required NEPA process, to 
request and obtain congressional approval to acquire the land, and to 
actually purchase the land from willing sellers is expected to take 
several years--the NEPA process alone is expected to take at least 16 
to 24 months. During this period, for example, cattle prices or local 
rainfall could increase or decrease, which would potentially change the 
selling price of the land. 

Several Important Questions about the 100,000-Acre Site Have Not Been 
Fully Addressed: 

Neither the original justification used to obtain OSD's waiver nor the 
2007 report on the Piñon Canyon Maneuver Site provides any specific 
information regarding the potential expansion of the maneuver site by 
100,000 acres. In requesting OSD's approval for the acquisition of up 
to 418,577 acres to expand the Piñon Canyon Maneuver Site, the request 
was justified on the estimated costs and benefits of the full 418,577- 
acre proposal and not on a smaller acquisition. While the Army 
completed the analyses required by Army Regulation 350-19[Footnote 23] 
in order to obtain OSD waiver approval to pursue the potential 
acquisition up to 418,577 acres, the Army has not fully explained its 
rationale for the potential acquisition of the smaller site currently 
being proposed for acquisition. 

According to Army Regulation 350-19, a military land acquisition 
proposal is a series of questions intended to provide senior leadership 
with the essential information to make a decision about a major land 
acquisition. Specifically, Appendix B of the regulation states that a 
land acquisition proposal should include the future use of the land, 
potential benefits, funding, training, readiness, anticipated 
environmental impacts, etc. The Army completed the analyses required in 
order to obtain OSD approval to pursue the potential acquisition of up 
to 418,577 acres. However, the Army has not fully explained the 
rational behind the identification of the 100,000-acre site, such as 
(1) how much of the 100,000 acres would actually be used for training, 
(2) what benefits would be gained from adding the 100,000 acres to the 
Piñon Canyon Maneuver Site, (3) what effect sustainment and maintenance 
activities would have on training on the 100,000 acres, and (4) what 
the future costs would be for sustaining and maintaining the 100,000 
acres. For example, Fort Carson officials said that they did not know 
but were concerned about the condition of the land and whether the Army 
could quickly start using the land or would need to reseed the land 
before training on it. 

Analyses Required by the NEPA Process May Address Many Questions: 

Army officials said that these questions regarding the 100,000-acre 
expansion, including the amount usable for training, potential 
benefits, the effects of sustainment and maintenance activities on 
training, and the cost of sustainment and maintenance activities would 
be difficult to address without the analysis required by the NEPA 
process. For example, NEPA and the associated regulations established 
by the Council on Environmental Quality, which require, in part, that 
all federal agencies, including the Army, evaluate the likely 
environmental effects of projects they are proposing using an 
environmental assessment or, if the project constitutes a major federal 
action significantly affecting the quality of the human environment, a 
more detailed environmental impact statement. An environmental impact 
statement must include a purpose and need statement, a description of 
all reasonable project alternatives and their associated environmental 
impacts (including a "no action" alternative), a description of the 
environment of the area to be affected or created by the alternatives 
being considered, and an analysis of the environmental impacts of the 
proposed action and each alternative.[Footnote 24] 

Army officials noted that the NEPA process would help to more clearly 
explain and justify the proposed expansion by identifying overall 
sustainment and maintenance costs as well as environmental and 
historical restrictions on the 100,000 acres, which would provide a 
more accurate picture of how much of the 100,000 acres could be used 
for training, the type of training that could happen, and how quickly 
the land could be used for training. As previously noted, none of the 
funds appropriated or otherwise made available in the Consolidated 
Appropriations Act, 2008, or in Division E, Title I of the Consolidated 
Security, Disaster Assistance, and Continuing Appropriations Act, 2009, 
may be used for any action that is related to or promotes the expansion 
of the Piñon Canyon Maneuver Site. Army officials stated that these 
funding restrictions apply only to Military Construction Appropriations 
and do not preclude the Army from further studying the 100,000-acre 
site or starting the NEPA process. However, the officials stated that, 
to date, the Army has voluntarily declined to spend other appropriated 
funds to begin the process due to congressional concerns putting the 
potential acquisition process (including any type of NEPA analysis) on 
pause. Further, Army officials explained that because military 
construction funds are used for land acquisitions, the Army would not 
begin the NEPA analysis for the potential expansion without consulting 
with congressional stakeholders and having a reasonable expectation 
that military construction funds would be available for the potential 
acquisition. 

Conclusions: 

While the Army's 2008 report on the Piñon Canyon Maneuver Site 
generally addresses the provisions outlined in section 2831 of the 
National Defense Authorization for Fiscal Year 2008, more information 
is needed to better understand the Army's responses to six provisions 
on whether existing training facilities are sufficient to support the 
training needs and alternatives for enhancing economic development 
opportunities for southeastern Colorado. Without additional information 
on the mandated provisions, it is difficult for Congress and the public 
to fully understand the Army's report. 

Additional information is also needed to help explain how the Army 
decided to reduce the proposed expansion and selected the 100,000 acres 
currently being proposed for acquisition, the growth in the estimated 
price per acre, as well as how much of the 100,000 acres would actually 
be used for training, what benefits would be gained from adding the 
100,000 acres to the Piñon Canyon Maneuver Site, what effect 
sustainment and maintenance activities would have on training on the 
100,000 acres, and what the future costs would be for sustaining and 
maintaining the 100,000 acres. Without the benefit of the analyses and 
information on how the Army decided to select the 100,000 acres 
currently being proposed for acquisition, especially in light of the 
growth in the estimated price per acre, it is difficult for Congress 
and the public to evaluate the full benefits and costs associated with 
the proposed 100,000-acre expansion. 

Recommendations for Executive Action: 

To better inform congressional decision makers and facilitate 
congressional oversight, we recommend that the Secretary of Defense 
direct the Secretary of the Army to take the following two actions: 

* Provide Congress with additional information explaining the six 
responses about whether existing training facilities are sufficient to 
support the training needs and about alternatives for enhancing 
economic development opportunities for southeastern Colorado, which 
were lacking in the Army's 2008 report on the maneuver site. 

* Provide Congress with additional information explaining the reasons 
the Army selected the current 100,000-acre site for the proposed 
expansion and the growth in the estimated price per acre, as well as 
how much of the 100,000 acres would actually be used for training, what 
benefits would be gained from adding the 100,000 acres to the existing 
maneuver site, what effect sustainment and maintenance activities would 
have on training on the 100,000 acres, and what the future costs would 
be for sustaining and maintaining the 100,000 acres. 

Agency Comments and Our Evaluation: 

In written comments on a draft of this report, which represented the 
views of DOD and the Army, the Assistant Secretary of the Army for 
Installations and Environment partially agreed with our recommendations 
but did not specify what actions, if any, DOD or the Army would take to 
implement them. In addition, the Assistant Secretary provided general 
report comments, specific report comments, and comments about our 
recommendations but raised a variety of concerns in their comments 
about our characterization of the Army's report, which we discuss 
below. 

General Report Comments: 

In this comments section, the Army stated several times that GAO 
concurred with the Army and suggested that our report title should be 
revised to reflect that the Army's requirement for an expansion at the 
Piñon Canyon Maneuver Site is valid. The Army also stated that the 
title of our report does not match the actual findings of our report 
and consequently leaves the reader with the impression that the Army 
failed to address the central questions of Congress. Our work and this 
report were focused on the extent to which the Army addressed the 
report provisions required by the section 2831 of the National Defense 
Authorization Act for Fiscal Year 2008 and the extent to which the Army 
explained the need for the 100,000-acre expansion rather than the 
418,577 acres that the Army initially sought. As such, our draft report 
addresses these objectives and identified the 23 of the 29 reporting 
provisions that the Army generally addressed but not the extent to 
which we do or do not concur with the Army's plan. Moreover, as noted 
in our report, the Army's responses to 6 of the provisions were not 
clear and lacked information; consequently, we continue to believe that 
the title of our report accurately reflects our findings and 
recommendations. 

Specific Report Comments: 

The Army disagreed with the draft report's discussion of the increased 
cost per acre to expand the Piñon Canyon Maneuver Site and recommended 
these costs not be included in our final report. The Army stated that 
no appraisals have been conducted to determine a more accurate price 
per acre, and the cost figures were not requested by Congress and are 
used for internal planning and budgeting purposes only. While we 
recognize that comprehensive appraisals have not been done yet, the 
Army used the estimated cost per acre that we cited in our draft report 
to project the cost of the land acquisition in its moratorium waiver 
request to OSD and increased estimates for internal budget purposes. We 
included the initial and increased cost estimates in our draft report 
because without this information we believed that it would be difficult 
for Congress to effectively exercise its oversight of the proposed 
expansion and, if found justified, to appropriate sufficient funds to 
support it. Because we continue to believe that the Congress will need 
this information, we did not remove our discussion of the potentially 
increased acquisition cost; however, we revised our report to delete 
the more recent, increased cost estimates to avoid a premature release 
of the estimates since they have not been fully validated or disclosed 
to the public by the Army. We continued to report the initial cost per 
acre estimate the Army used in its moratorium waiver request to OSD 
because this estimate is in already in the public domain. 

The Army also commented that the draft report did not accurately 
reflect Army officials' statements regarding congressional funding 
restrictions involving the potential Piñon Canyon Maneuver Site 
expansion and provided revised language to clarify the Army's position 
on the restrictions. We have revised our report to respond to this 
comment. 

The Army also recommended that we characterize the Army's land 
acquisition process as essentially reasonable or sound. We did not 
assess the soundness of the Army's land acquisition process during this 
review. However, we issued a companion report and concluded that the 
Army has an extensive, analytical approach to making decisions for 
pursuing training land acquisitions, which is based on (1) the Army's 
strategic plan for training ranges--Range and Training Land Strategy-- 
used to address training land shortfalls and (2) the Army Range 
Requirements Model, an analytical computerized decision support tool 
that gathers data at the installation level to determine training 
requirements and capabilities.[Footnote 25] While we also found that 
the strategic plan needs to be updated, we concluded that the model 
does provide a consistent and reasonable framework for Army 
headquarters, major commands, and installations to use to calculate 
training land capabilities and requirements at individual 
installations. 

Comments about Our Recommendations: 

The Army partially agreed with the first recommendation to provide 
Congress with additional information about (1) the extent to which 
existing training facilities are sufficient to support training needs 
and (2) alternatives for enhancing economic development opportunities 
for southeastern Colorado. In its comments, the Army stated that it 
strongly believes that the best way to provide this information to 
Congress is through the NEPA process. It also stated that NEPA is a 
critical part of the decision process and much of the information that 
we recommended the Army provide Congress will be determined through the 
NEPA process. Even though the Army had not started the NEPA process by 
the time of our report, the Army's comments provided some of the 
additional information regarding the six responses that we concluded 
were lacking. Nonetheless, more detailed information would further 
clarify these responses. For example, the Army provided a list of 
workaround scenarios in its comments and provided one detailed example 
of a workaround, but it still does not explain the difference between 
minor and major workarounds, the amount of workarounds needed to meet 
current training requirements, or how these workarounds impact the 
training load at the Piñon Canyon Maneuver Site. At the same time 
however, nothing in our recommendation prevents the Army from using the 
NEPA process to provide the additional information still lacking if the 
Army determines that this would be the most appropriate approach and 
would provide the information to Congress in a timely manner. 
Therefore, we continue to believe that providing more detailed 
information on the six responses would help Congress and the public to 
fully understand the Army's report. 

The Army also partially agreed with our recommendation to provide the 
rationale for selecting the 100,000 acres for the proposed expansion 
but did not state what actions it plans to take, if any, to address the 
recommendation. The Army stated that it believes that it adequately 
explained in the report why it preferred a smaller land acquisition. 
Specifically, the Army stated that from the outset it has placed a 
priority on the acquisition of area A, the 100,000 acres proposed in 
the initial expansion. While we are aware that the Army preferred the 
100,000 acres initially, our recommendation was focused on the 
usability and sustainability of the 100,000-acre parcel and not why the 
Army chose to start with the 100,000 acres. We continue to believe that 
the Congress needs this information to assist in its oversight of the 
proposed expansion and therefore stand by our recommendation. 

The Army also stated its assumption that all 100,000 acres of the site 
will be used for training unless an in-depth analysis conducted during 
the NEPA process reveals a major problem that would preclude the use of 
most or all of the acreage. Further, the Army stated that while 
execution of the range maintenance and sustainment program on the 
100,000 acres would permit training land to be accessible and usable, 
it is premature to project future sustainment costs. However, whether 
the Army makes these determinations through the NEPA process or another 
method, we continue to believe the amount of acreage useable for 
training and sustainment cost projections to be valuable information in 
determining the justification for the 100,000-acre site. Without this 
information, it is difficult for Congress and the public to fully 
understand the Army's justification for expansion. 

The Army's comments are reprinted in their entirety in appendix III. 
The Army also provided technical comments, which we have incorporated 
into the report as appropriate. 

We are sending copies of this report to the Secretary of Defense, the 
Secretary of the Army, and the Director, Office of Management and 
Budget. In addition, the report will be available at no charge on GAO's 
Web site at [hyperlink, http://www.gao.gov]. If you have any questions, 
please contact me at (202) 512-4523 or leporeb@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. Key contributors to this report 
are listed in appendix IV. 

Signed by: 

Brian J. Lepore, Director: 
Defense Capabilities and Management: 

List of Committees: 

The Honorable Carl Levin: 
Chairman: 
The Honorable John McCain: 
Ranking Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable Daniel K. Inouye: 
Chairman: 
The Honorable Thad Cochran Ranking Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
United States Senate: 

The Honorable Tim Johnson: 
Chairman: 
The Honorable Kay Bailey Hutchison: 
Ranking Member: 
Subcommittee on Military Construction, Veterans' Affairs, and Related 
Agencies: 
Committee on Appropriations: 
United States Senate: 

The Honorable Ike Skelton: 
Chairman: 
The Honorable John M. McHugh: 
Ranking Member: 
Committee on Armed Services: 
House of Representatives: 

The Honorable John P. Murtha: 
Chairman: 
The Honorable C.W. Bill Young: 
Ranking Member: 
Subcommittee on Defense: 
Committee on Appropriations: 
House of Representatives: 

The Honorable Chet Edwards: 
Chairman: 
The Honorable Zach Wamp: 
Ranking Member: 
Subcommittee on Military Construction, Veterans' Affairs, and Related 
Agencies: 
Committee on Appropriations: 
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

To determine if the Army's report on the Piñon Canyon Maneuver Site 
addresses the provisions of section 2831 of the National Defense 
Authorization Act for Fiscal Year 2008, we reviewed all 29 provisions 
for the Army's responses contained in the act and examined whether the 
Army's report provided responses to, as well as all the necessary 
information required by, the provisions. We also obtained and reviewed 
documents used by the Army to develop responses to the mandate 
including the Army's 2005 Land Use Requirements Study, both of the 
Army's Piñon Canyon Maneuver Site reports in response to the National 
Defense Authorization Acts for Fiscal Year 2007 and Fiscal Year 2008, 
and the Army's land acquisition proposal requesting the Office of the 
Secretary of Defense (OSD) approval for acquiring up to 418,577 acres. 
We interviewed appropriate Army officials, including those directly 
responsible for developing the 2008 report, to gain a better 
understanding and document the reasons for the Army's responses to the 
provisions of the act. During this audit, we met with officials from 
the Office of the Deputy Assistant Secretary of the Army for 
Installations and Housing, Washington D.C.; the Department of the Army 
Management Office (Training Support Systems Division), Washington D.C.; 
Army Forces Command, Fort McPherson, Georgia; Fort Carson, Colorado; 
and Piñon Canyon Maneuver Site, Colorado. 

To determine the extent to which the Army's 2008 report provides 
justification for expanding the Piñon Canyon Maneuver Site, we obtained 
and reviewed key Army policy guidance for managing its training lands 
and ranges, specifically Army Regulation 350-19, The Army Sustainable 
Range Program. We compared this guidance to the information provided in 
the report to determine how it was used by the Army to justify the need 
for expansion at the Piñon Canyon Maneuver Site. We also examined the 
analyses used by the Army in developing its 2008 report to understand 
how the Army justified its need for an additional 100,000 acres. In 
addition, we obtained and reviewed past justifications for training 
land expansion at the Piñon Canyon Maneuver Site, including the Army's 
2005 Land Use Requirements Study, the Army's response to the National 
Defense Authorization Act for Fiscal Year 2007, and the Army's land 
acquisition proposal to request OSD approval for acquiring up to 
418,577 acres. We did not review the Army's process for acquiring land, 
including the use of the Army Range Requirements Model, because these 
topics are addressed in detail in a concurrent GAO performance audit, 
the results of which are to be published in a separate report in 
January 2009.[Footnote 26] We used information gathered from this GAO 
review of the Army's overall land acquisition process to supplement our 
audit work for this report. In addition, we met with appropriate 
officials from the Department of the Army Management Office (Training 
Support Systems Division) and Fort Carson to discuss how the addition 
of 100,000 acres to the Piñon Canyon Maneuver Site would benefit 
training, as well as the workarounds that will be needed to meet 
training requirements and potential land management and maintenance 
costs. We also visited Fort Carson and the Piñon Canyon Maneuver Site 
to see firsthand existing training facilities and ranges. 

We conducted this performance audit from August 2008 through January 
2009 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Reporting Categories and Provisions of Section 2831 of the 
National Defense Authorization Act for Fiscal Year 2008: 

Section 2831 of the 2008 National Defense Authorization Act for Fiscal 
Year 2008 required that the Army submit a report to Congress detailing 
its plans for expanding the Piñon Canyon Maneuver Site. In its report, 
the Army was required to respond to 29 provisions regarding the 
potential expansion. These provisions fall under three broad reporting 
categories: (1) an analysis of whether existing training facilities at 
Fort Carson, Colorado, and the site are sufficient to support the 
training needs of units stationed or planned to be stationed at Fort 
Carson; (2) a report of need for any proposed addition of training land 
to support units stationed or planned to be stationed at Fort Carson; 
and (3) an analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion. The Army's 2008 report generally addresses 
section 2831 of the National Defense Authorization Act for Fiscal Year 
2008 by responding to each of the mandate's 29 provisions. 
Nevertheless, we found that the responses to six of the provisions were 
not clear and lacked information that would help provide the reader a 
better understanding of the Army's responses to the mandated 
provisions. Table 2 lists the three reporting categories and 29 
provisions the Army was required to address in its report, and 
indicates those provisions for which additional information would help 
clarify the Army's response. 

Table 2: Reporting Categories and Provisions of the National Defense 
Authorization Act for Fiscal Year 2008 and Whether the Provisions Were 
Adequately Addressed in the Army's 2008 Report: 

An analysis of whether existing training facilities at Fort Carson, 
Colorado, and the site are sufficient to support the training needs of 
units stationed or planned to be stationed at Fort Carson: 

Reporting categories and provisions: Section 2831(a)(2)(A); An analysis 
of whether existing training facilities at Fort Carson, Colorado, and 
the site are sufficient to support the training needs of units 
stationed or planned to be stationed at Fort Carson; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(A)(i); An 
analysis of whether existing training facilities at Fort Carson, 
Colorado, and the site are sufficient to support the training needs of 
units stationed or planned to be stationed at Fort Carson, including a 
description of any new training requirements or significant 
developments affecting training requirements for units stationed or 
planned to be stationed at Fort Carson since the 2005 Defense Base 
Closure and Realignment Commission found that the base has 'sufficient 
capacity' to support four brigade combat teams and associated support 
units at Fort Carson; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(A)(ii); An 
analysis of whether existing training facilities at Fort Carson, 
Colorado, and the site are sufficient to support the training needs of 
units stationed or planned to be stationed at Fort Carson, including a 
study of alternatives for enhancing training facilities at Fort Carson 
and the site within their current geographic footprint, including 
whether these additional investments or measures could support 
additional training activities; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(A)(iii); An 
analysis of whether existing training facilities at Fort Carson, 
Colorado, and the site are sufficient to support the training needs of 
units stationed or planned to be stationed at Fort Carson, including a 
description of the current training calendar and training load at the 
site; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(A)(iii)(I); An 
analysis of whether existing training facilities at Fort Carson, 
Colorado, and the site are sufficient to support the training needs of 
units stationed or planned to be stationed at Fort Carson, including a 
description of the current training calendar and training load at the 
site, including the number of brigade-sized and battalion-sized 
military exercises held at the site since its establishment; 
Adequately addressed in the report: No[A]. 

Reporting categories and provisions: Section 2831(a)(2)(A)(iii)(II); An 
analysis of whether existing training facilities at Fort Carson, 
Colorado, and the site are sufficient to support the training needs of 
units stationed or planned to be stationed at Fort Carson, including a 
description of the current training calendar and training load at the 
site, including an analysis of the maximum annual training load at the 
site, without expanding the site; 
Adequately addressed in the report: No[A]. 

Reporting categories and provisions: Section 2831(a)(2)(A)(iii)(III); 
An analysis of whether existing training facilities at Fort Carson, 
Colorado, and the site are sufficient to support the training needs of 
units stationed or planned to be stationed at Fort Carson, including a 
description of the current training calendar and training load at the 
site, including an analysis of the training load and projected training 
calendar at the site when all brigades stationed or planned to be 
stationed at Fort Carson are at home station; 
Adequately addressed in the report: No[A]. 

A report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson: 

Reporting categories and provisions: Section 2831(a)(2)(B); A report of 
need for any proposed addition of training land to support units 
stationed or planned to be stationed at Fort Carson; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(i); A report 
of need for any proposed addition of training land to support units 
stationed or planned to be stationed at Fort Carson, including a 
description of additional training activities, and their benefits to 
operational readiness, which would be conducted by units stationed at 
Fort Carson if, through leases or acquisition from consenting 
landowners, the site were expanded; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(i)(I); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including a 
description of additional training activities, and their benefits to 
operational readiness, which would be conducted by units stationed at 
Fort Carson if, through leases or acquisition from consenting 
landowners, the site were expanded to include the parcel of land 
identified as "Area A" in the potential Piñon Canyon Maneuver Site land 
expansion map; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(i)(II); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including a 
description of additional training activities, and their benefits to 
operational readiness, which would be conducted by units stationed at 
Fort Carson if, through leases or acquisition from consenting 
landowners, the site were expanded to include the parcel of land 
identified as "Area B" in the potential Piñon Canyon Maneuver Site land 
expansion map; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(i)(III); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including a 
description of additional training activities, and their benefits to 
operational readiness, which would be conducted by units stationed at 
Fort Carson if, through leases or acquisition from consenting 
landowners, the site were expanded to include the parcels of land 
identified as "Area A" and "Area B" in the potential Piñon Canyon 
Maneuver Site land expansion map; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(i)(IV); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including a 
description of additional training activities, and their benefits to 
operational readiness, which would be conducted by units stationed at 
Fort Carson if, through leases or acquisition from consenting 
landowners, the site were expanded to include acreage sufficient to 
allow simultaneous exercises of a light infantry brigade and a heavy 
infantry brigade at the site; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(i)(V); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including a 
description of additional training activities, and their benefits to 
operational readiness, which would be conducted by units stationed at 
Fort Carson if, through leases or acquisition from consenting 
landowners, the site were expanded to include acreage sufficient to 
allow simultaneous exercises of two heavy infantry brigades at the 
site; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(i)(VI); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including a 
description of additional training activities, and their benefits to 
operational readiness, which would be conducted by units stationed at 
Fort Carson if, through leases or acquisition from consenting 
landowners, the site were expanded to include acreage sufficient to 
allow simultaneous exercises of a light infantry brigade and battalion 
at the site; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(i)(VII); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including a 
description of additional training activities, and their benefits to 
operational readiness, which would be conducted by units stationed at 
Fort Carson if, through leases or acquisition from consenting 
landowners, the site were expanded to include acreage sufficient to 
allow simultaneous exercises of a heavy infantry brigade and a 
battalion at the site; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(ii); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including an 
analysis of alternatives for acquiring or utilizing training land at 
other installations in the United States to support training activities 
of units stationed at Fort Carson; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(B)(iii); A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson, including an 
analysis of alternatives for utilizing other federally owned land to 
support training activities of units stationed at Fort Carson; 
Adequately addressed in the report: Yes. 

An analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion: 

Reporting categories and provisions: Section 2831(a)(2)(C); An analysis 
of alternatives for enhancing economic development opportunities in 
southeastern Colorado at the current site or through any proposed 
expansion; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(C)(i); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of the leasing of land 
on the site or any expansion of the site to ranchers for grazing; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(C)(ii); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of the leasing of land 
from private landowners for training; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(C)(iii); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of the procurement of 
additional services and goods, including biofuels and beef, from local 
businesses; 
Adequately addressed in the report: No[A]. 

Reporting categories and provisions: Section 2831(a)(2)(C)(iv); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of the creation of an 
economic development fund to benefit communities, local governments, 
and businesses in southeastern Colorado; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(C)(v); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of the establishment of 
an outreach office to provide technical assistance to local businesses 
that wish to bid on Department of Defense contracts; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(C)(vi); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of the establishment of 
partnerships with local governments and organizations to expand 
regional tourism through expanded access to sites of historic, 
cultural, and environmental interest on the site; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(C)(vii); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of an acquisition 
policy that allows willing sellers to minimize the tax impact of a 
sale; 
Adequately addressed in the report: Yes. 

Reporting categories and provisions: Section 2831(a)(2)(C)(viii); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of additional 
investments in Army missions and personnel, such as stationing an 
active duty unit at the site; 
Adequately addressed in the report: No[A]. 

Reporting categories and provisions: Section 2831(a)(2)(C)(viii)(I); An 
analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of additional 
investments in Army missions and personnel, such as stationing an 
active duty unit at the site, including an analysis of anticipated 
operational benefits; 
Adequately addressed in the report: No[A]. 

Reporting categories and provisions: Section 2831(a)(2)(C)(viii)(II); 
An analysis of alternatives for enhancing economic development 
opportunities in southeastern Colorado at the current site or through 
any proposed expansion, including consideration of additional 
investments in Army missions and personnel, such as stationing an 
active duty unit at the site, including an analysis of economic impacts 
to surrounding communities; 
Adequately addressed in the report: Yes. 

Source: Army's 2008 Report on the Piñon Canyon Maneuver Site and the 
National Defense Authorization Act for Fiscal Year 2008. 

Note. As stated in the report, the Army's 2008 report generally 
addresses each one of the mandate's 29 provisions. The third column of 
table 2 indicates those provisions for which additional information 
would help clarify the Army's response. There were six responses to the 
mandated provisions, which are indicated by the term "no" in the third 
column of table 2, for which additional information would help clarify 
the Army's response. 

[A] A response of "no" indicates that the Army's response to the 
reporting provision lacked information that would help provide the 
reader a better understanding of the Army's responses to the mandated 
provisions; it does not indicate that the Army failed to address the 
mandated provision. 

[End of table] 

[End of section] 

Appendix III: Comments from the Department of Defense: 

Department Of The Army: 
Assistant Secretary Of The Army: 
Installations And Environment: 
110 Army Pentagon: 
Washington DC 20310-0110: 

December 22, 2008: 

Mr. Brian J. Lepore: 
Director: 
Defense Capabilities and Management: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, DC 20548: 

Dear Mr. Lepore: 

This is the Army and Department of Defense (DoD) response to the GAO 
draft report with the working title, `Defense Infrastructure: 
Additional Information Is Needed to Better Explain the Proposed 100,000-
Acre Expansion of the Piñon Canyon Maneuver Site,' dated November 20, 
2008, (GAO Code 351258/GAO-09-171). 

The Army and Department of Defense (DoD) appreciate the opportunity to 
comment on the draft report. The coordinated Army/DoD comments on the 
two specific recommendations in the report are outlined in the 
enclosure. The comments are broken down into both `general comments' 
and specific comments. General comments are those which have broad 
applicability to the entire report (some phrases recur throughout the 
draft report). The Army/DoD is particularly concerned about the working 
title of the report, and recommends a title that more closely matches 
GAO's findings and recommendations. We continue to appreciate the audit 
work performed by the GAO. 

Sincerely, 

Signed by: 

Mr. Keith E. Eastin: 
Assistant Secretary of the Army: 
Installations and Environment: 

Enclosures: As stated: 

GAO Draft Report - Dated November 20, 2008: 
GAO Code 351258/GAO-09-171: 

“Defense Infrastructure: Additional Information Is Needed to Better 
Explain the Proposed 100,000-Acre Expansion of the Piñon Canyon 
Maneuver Site” 

Department Of The Army General Report Comments: 

The working title and Highlights section of the GAO report do not match 
the actual findings of GAO. The body of the GAO report says the Army’s 
July 2008 Report to Congress adequately addressed 23 of the 29 
questions mandated by Congress (pg. 14) – including the critically 
important questions asked by Congress in Section 2831(a)(2)(B): “A 
report of need for any proposed addition of training land to support 
units stationed or planned to be stationed at Fort Carson.” 

None of the responses to 2831(a)(2)(B) were flagged by GAO as being 
insufficient in any way. Congress’ intent was to have GAO independently 
verify whether expanding PCMS was necessary, and whether there were 
viable alternatives to expansion (see 2831(a)(2)(B)(iii)). On these 
most important questions, GAO concurred with the Army, yet nowhere in 
the working title or in the Highlights is this fact noted or 
referenced. 

The current working title leaves the reader with the impression that 
the Army report failed to address the central questions of Congress. 
Army recommends changing the title of GAO report to better reflect (and 
balance) GAO’s concurrence with the vast majority of the Army’s report 
(including the central question of whether more land was needed). 
Accordingly, we propose the new title to be: “Additional Land 
Requirement at Piñon Canyon Maneuver Site is Valid, But Additional 
Information Could Help Better Explain Contemplated Expansion.” 

Recommend adding the following paragraph at the very beginning of the 
GAO Highlights/summary page under “What GAO Found:” 

‘The GAO found that the Army’s report adequately addressed 23 of the 29 
of the mandated Congressional reporting provisions, including the key 
questions of whether the expansion of PCMS was needed to support units 
stationed or planned to be stationed at Fort Carson, and whether there 
were any viable alternatives to land expansion that would meet the 
Army’s training doctrinal requirements.’ 

As it is currently written and structured, the focus is not on the 80% 
agreement (23/29) between GAO and the Army, but on the 20% variance 
between what the Army’s report conveyed, and where GAO thought 
additional information would be helpful. 

Department Of The Army Specific Report Comments: 

1. GAO Highlights, Bullet 2, “The estimated cost...” 

The Army strongly disagrees with the inclusion of this bullet and the 
repeated emphasis throughout the report on “growth in the estimated 
price per acre.” Congress did not include any questions in its 
reporting requirement about the cost per acre. No appraisals have been 
done on any property, so there is no evidentiary basis to state what 
the cost per acre will be to acquire any of the property. Estimated 
cost figures are used for internal planning and budgeting purposes 
only. Any discussion of cost per acre will be misleading to the public 
and should be removed from the report. 

2. GAO Highlights, Last paragraph, line 1, “Army officials said...” 

Disagree with the phrase “...would be difficult to address...” and 
recommend changing to, “would be best addressed through the analysis 
required...” 

3. GAO Highlights, Last paragraph, line 7, “This, in the view of the 
Army...continue with the process when funds become available.” 

These two sentences in the GAO “Highlights” are inaccurate and should 
be deleted or revised. The Congressional appropriations limitation 
applies only to the MILCON-VA appropriations bills for FY 2008 and FY 
2009. It does not affect Defense Appropriations, which fund the 
Operations and Maintenance (O&M) accounts that pay for EIS efforts in 
compliance with NEPA. Therefore, the restrictions do not prevent or 
preclude the Army from starting a NEPA analysis for expansion. 
Recommend changing to, “Since O&M funds are used to pay for NEPA 
analyses, the Army is not precluded from further studying the 100,000-
acre site or starting the NEPA process, but to date the Army has 
voluntarily deferred spending other appropriated funds while due to 
Congressional concerns. Uncertainty over Congressional support for the 
contemplated expansion made a delay in expending funds to start an 
expansion NEPA appear to be prudent.” 

4. GAO Highlights, Last paragraph, line 11, “Without the benefit of the 
analyses...”: 

Disagree with the characterization that, “the Army decided to select 
the 100,000 acres...” There was never a "decision" to purchase either 
the 418,000 acres, or in the alternative, to purchase 100,000 acres 
instead. The Army sought and received authorization to purchase up to 
418,000 acres from OSD. The NEPA process is a critical part of the 
decision process that will determine how much, if any land is 
purchased. Until the NEPA process is complete, no decisions will be 
made. Recommend changing to, “Without the benefit of the NEPA analyses 
it is difficult for Congress and the public to evaluate the full 
benefits and costs...” 

5. Page 2, Line 2: 

“An increase in training acreage from 66,000 to 161,000 is well over 
100 percent.” Recommend changing this sentence to read: “An increase in 
training...is nearly 144 percent. 

6. Page 2, Lines 17-19: 

Disagree with the use of the phrase, “...in their view...” 
Congressional appropriations language does not restrict the use of O&M 
funds. Recommend changing to, “...the Army used operations and 
maintenance funds that were not subject to the above-referenced...” 

7. Page 4, Results in Brief: 

The GAO report gives very short shrift to the fact that GAO concurred 
with 80% of the Army’s responses in its July 2008 report (23/29), 
including its concurrence with the very significant issue of ‘a report 
of need for more training land’ – the central question raised by 
Congress. Recommend GAO add the following immediately under “Results in 
Brief” to balance the summary of GAO’s results, “The GAO found that the 
Army’s report adequately addressed 23 of the 29 mandated Congressional 
reporting provisions, including the key questions of whether the 
expansion of PCMS was needed to support units stationed or planned to 
be stationed at Fort Carson, and whether there were any viable 
alternatives to land expansion that would meet the Army’s training 
doctrinal requirements.” 

8. Pages 6-7, 10 (last line of text): 

Regarding NEPA and the Congressional appropriations limitations, see 
comments above as to why the Congressional limitations do not preclude 
or limit NEPA analysis related to PCMS expansion. Recommend these 
portions of the GAO report be deleted or modified as recommended 
previously. 

9. Page 6, Lines 8-13: 

Recommend GAO delete the phrase, “However, the Army has not fully 
explained...” and replace with, “The GAO, based on its discussions with 
Army officials, believes that many of the following additional issues 
could be better explained and discussed through the analysis required 
by [NEPA]” 

10. Pages 12-13: 

Nowhere does the GAO report characterize the Army’s land acquisition 
process as essentially reasonable or sound, yet from the discussions 
with the GAO analysts, this appears to be GAO’s overall conclusion. 
Recommend GAO state this conclusion, given that one of the questions 
Congress and the public are interested in is whether the Army’s land 
acquisition process at PCMS can be trusted to produce logical and 
reasoned recommendations. 

Department Of Defense Comments To The Recommendations: 

Recommendation 1: The GAO recommends that the Secretary of Defense 
direct the Secretary of the Army to provide Congress with additional 
information explaining the six responses about whether existing 
training facilities are sufficient to support the training needs and 
about alternatives for enhancing economic development opportunities for 
southeastern Colorado, which were lacking in the Army’s 2008 report on 
the maneuver site. 

DOD Response: Partially concur. 

The Army strongly believes the best way to provide additional 
information to Congress on the remaining issues is through the National 
Environmental Policy Act (NEPA) process. As NEPA is a critical part of 
the decision process and the next required step in land acquisition, 
much of the information GAO recommends requesting will be determined 
through this process. The Army believes that GAO should emphasize the 
importance of the NEPA process. The recommendation should be changed to 
read, “The Army should begin NEPA at the appropriate time, and ensure 
that the remaining issues be covered and discussed adequately either 
through NEPA analysis, or through a similar mechanism of the Army’s 
choosing.” 

The following additional information is provided to further explain the 
six responses that GAO felt were lacking in the Army’s 2008 Report. 

1. Section 2831 (a)(2)(A)(iii)(I): 

There is no requirement for the Army to keep detailed utilization 
records for training events that do not involve live fire of munitions. 
The Piñon Canyon Maneuver Site (PCMS) began keeping utilization records 
with an automated training scheduling and utilization record for all 
training events at its installations in 2004 with the current version 
of the Range Facility Management Support System (RFMSS). While the Army 
has been using PCMS to conduct training exercises since 1985, there was 
no system in place to officially track utilization of maneuver training 
areas prior to 2004. Therefore, the Army chose to provide information 
on known training rather than relying on institutional memory and 
interviews with former Fort Carson/PCMS range personnel, which is not 
auditable. The Army made a decision to emphasize reliability and 
quality of data verses quantity. 

More importantly, as indicated on page 19 of the Army’s 2008 report, 
the historic use of PCMS does not reflect the future projected use, due 
to changes within Army doctrine and Army force structure changes. 

2. Section 2831 (a)(2)(A)(iii)(II): 

Currently, PCMS contains approximately 224,000 acres available for 
maneuver training. This allows for the following training exercises to 
be conducted to doctrinal standards: 

* One Heavy Brigade Combat Team (HBCT) conducting a free flowing 
exercise (170,000 acres); 

* One Infantry Brigade Combat Team (IBCT) conducting a free flowing 
exercise (112,000 acres); 

* Two IBCTs conducting free flowing exercises simultaneously (224,000 
acres). 

It is not currently possible for an HBCT and an IBCT to conduct free 
flowing exercises simultaneously and is it also not possible for two 
HBCTs to conduct free flowing exercises simultaneously. 

Currently two HBCTs and one IBCT are stationed at Fort Carson and these 
units can effectively train. Following the actions discussed on pages 
14-16 of the Army’s 2008 report, three HBCTs and two IBCTs will be 
stationed at Fort Carson by 2011. 

The Army believes that the July 2008 report does address the issue of 
“work-arounds”, albeit from a broad perspective that is hopefully more 
understandable for a layperson. However, for clarification, the types 
of workarounds that are employed by units when training land is 
restricted include, but are not limited to: reordering the sequence of 
tasks or events in a training exercise; delaying the training on 
certain tasks until deployment; not training the task or event to 
doctrinal standard. Work-arounds decrease the quality of Soldier 
training which is critical to success on the battlefield. 

A specific example of “work-arounds” producing the effects described in 
the July 2008 report: Lack of Maneuver Depth Causing 
Exercises/Scenarios to Become Unrealistic. In a common training 
scenario, a unit is ordered to launch an attack and maneuver 
aggressively towards opposition force (OPFOR) held positions. The unit 
then presses the attack for a pre-designated distance. Then the OPFOR 
launches a counterattack, and the unit must shift quickly from attack 
to defense, maneuvering while falling back a pre-designated distance. 
This scenario is critical to instilling basic concepts of ‘defense in 
depth’ and teaching unit commanders how hard they can press an attack 
before their Soldiers become exhausted, out of position, or excessively 
dispersed (and hence vulnerable to a counterattack). If the scenario 
calls for the entire attack-counter-attack-recover sequence to be 
played out within a 15 km by 5 km maneuver box, but the actual amount 
of acreage available is only half or less of what is doctrinally 
required, one of the ‘work-arounds’ will be for the US force to attack 
from one side to the available maneuver box to the other, and then when 
the OPFOR is ready to launch its counterattack, the exercise will be 
halted, and all units will move several kilometers backwards so there’s 
enough room for the remainder of the scenario to be completed. 
Obviously, this is totally unrealistic – there are no “time outs” on 
the modern battlefield where Soldiers get to rest up and reorganize 
prior to the enemy launching a counter-attack. 

Page 19 of the July 2008 report notes that without expansion, it will 
“make it difficult to train units to operate on the scale demanded by 
the contemporary operating environment.” This current operating 
environment was explained on pages 8-9, with a chart depicting the 
amount of terrain Brigades must secure on the battlefield growing 
exponentially since World War II. Also, on pages 19-20, is a detailed 
description of what training ‘work-arounds’ can do to units and 
Soldiers if they are not allowed to train in a dispersed manner similar 
to their contemporary operating environment: “work-around scenarios 
that train units without stressing their full operational 
capability…creates the risk of developing bad habits in training and 
embeds false expectations as to true battlefield conditions.” 

Regarding the costs associated with increased training and use of the 
existing PCMS, the Integrated Training Area Management (ITAM) program 
is the Army's premier program for sustaining its training land 
throughout the Army. ITAM uses an integrated approach to sustaining its 
training land through four components to provide integration of 
doctrinal training requirements with sound land management methods, 
repair of maneuver damage, assessment of land condition, and awareness 
training for Soldiers and civilians to avoid preventable damage to 
natural resources in the training area. Types of repair, maintenance 
and associated costs are a function of weather conditions, intensity 
and type of training, soil conditions, materials, and labor costs for 
field crews to repair maneuver land damage. We expect an increase in 
ITAM requirements over the FY 09 $2.42M requirement at PCMS. For 
planning purposes we would estimate the future requirement on the 
100,000 acres to be between $1.2M and $1.5M. However, this is merely an 
estimate based on current requirements at PCMS. 

3. Section 2831 (a)(2)(A)(iii)(III): 

The Army’s recent Posture Statements refer to the U.S. waging “The Long 
War” in an “Era of Persistent Conflict.” The Posture Statement factors 
into most Army plans as an assumption of regular rotations and 
deployments for the foreseeable future. Regarding the issue of 
peacetime vs. wartime deployment assumptions, if the Army did assume 
peacetime conditions when all or most units would be at home station, 
it is important to note that this assumption would substantially 
increase the demand for training calendar space at PCMS, which would 
strengthen, not weaken, the Army’s case for, and need for, training 
land expansion. 

4. Section 2831 (a)(2)(C)(iii): 

Regarding the Army’s failure to specifically address “biofuels” and 
“beef,” the Army notes that on this question it interpreted the 
reporting requirement broadly. Beef and biofuels are two examples; 
however the Army cannot provide details regarding specific purchases of 
any particular kind of good or service: (1) prior to NEPA and a 
decision, and (2) due to the need to determine, from a procurement and 
fiscal legal perspective, whether such purchases are allowable. 

However, the Army did lay out an extensive and specific set of possible 
economic development opportunities that could be implemented if PCMS 
were expanded ($100M+ in new construction, approximately 100 
civilians/contractors hired at PCMS with a payroll and operations 
budget of $9M/annually, ideas for promoting tourism/cultural heritage) 
that would broadly benefit the entire local community in and around Las 
Animas County, Colorado. The Army compared the magnitude of these 
projected economic benefits against the magnitude of estimated cattle 
sales from Area A, and the Army’s positive economic impact would be 
significantly greater than any foregone cattle sales. 

5. Section 2831 (a)(2)(C)(viii): 

Regarding the question of infrastructure requirements to accommodate 
stationing active duty units at PCMS itself, the Army ruled out 
stationing units at PCMS during the Programmatic Environmental Impact 
Statement (EIS) because of the prohibitive cost of replicating the 
infrastructure at PCMS that currently exists at Fort Carson’s 
cantonment area and surrounding community. An internal Army analysis in 
June 2007 concluded that it would cost 64 percent more ($331M+) to 
station an IBCT at PCMS ($845M) rather than Fort Carson ($513M). 
(Analysis attached) 

Stationing an IBCT at PCMS would not only entail a $330M+ additional 
cost but the additional civilians and contractors typically increase 
the nearby communities’ population by 8,000 to 10,000 persons total. In 
Las Animas County, which has a total population of about 15,000 
persons, adding an IBCT at PCMS could overwhelm and transform the local 
community from a ranching heritage to a military bedroom community. 
Lastly, stationing an IBCT at would require a substantially larger 
cantonment area at PCMS, which would reduce the number of maneuver 
acres available for training. 

6. Section 2831 (a)(2)(C)(viii)(I): 

Regarding the analysis of the operational benefits of stationing an 
active duty unit at PCMS, the Army did not conduct an analysis of 
operational benefits due to the fact that the costs to construct the 
infrastructure to support a BCT at PCMS were prohibitive and simply 
made the option of stationing completely infeasible. As noted above, 
any operational benefits, even if cost-benefit considerations were not 
a factor, would be partially negated by the loss of maneuver acreage in 
order to build up the PCMS cantonment area and associated 
infrastructure. 

Recommendation 2: The GAO recommends that the Secretary of Defense 
direct the Secretary of the Army to utilize available funds, if any, or 
when funds become available to further study the proposed 100,000-acre 
expansion site, provide Congress with additional information explaining 
the reasons the Army selected the current 100,000-acre site for the 
proposed expansion and the growth in the estimated price per acre, as 
well as how much of the 100,000 acres would actually be used for 
training, what benefits would be gained from adding the 100,000 acres 
to the existing maneuver site, what effect sustainment and maintenance 
activities would have on training on the 100,000 acres, and what the 
future costs would be for sustaining and maintaining the 100,000 acres. 

DOD Response: Partially Concur. 

The Army believes that it did adequately explain why it preferred a 
smaller land acquisition. Page 22 of the Army report, (with which GAO 
concurred) states “From the outset of the land acquisition process, the 
Army has placed a priority on the acquisition of Area A” and then the 
report lists reasons why Area A (approximately 100,000 acres) was a 
priority. 

Pages 23-24 of the Army report (GAO also concurred) explains why Area 
B, while appearing initially to offer many training advantages, is no 
longer viewed as feasible. The Army report also notes (pages 4, 23) 
that from the outset of the Army’s contemplated expansion, budgetary 
constraints would play a very important role in the process. Every 
training advantage obtained through land expansion also had to be 
weighed from a cost-benefit standpoint. Along those lines, pages 25-26 
of the Army report (GAO also concurred) contain Army responses to 
several Congressionally-directed training scenarios. An expansion equal 
to Area A would allow the Army to mostly or fully meet every one of the 
Congressional training scenarios. In short, the Army believes that Area 
A (100,000 acres) provides the greatest training benefit, at the lowest 
cost, the lowest acreage footprint, and with the fewest number of 
affected landowners and communities. 

The Army’s land acquisition moratorium waiver request to the Office of 
the Secretary of Defense (OSD) was never predicated on an ‘all or 
nothing’ proposition. The OSD approval memo of February 2007 allows the 
Army to acquire up to 418,000 acres. The Army report is very clear that 
all of the 100,000 acres will be used for training and to build a 
$100M+ training range complex (described in detail on page 35 of the 
Army report). The Army must use that assumption until it conducts an in-
depth environmental analysis done through NEPA. If NEPA were to uncover 
a major problem that would preclude the use of most or all of the 
contemplated 100,000 acres, the Army would reassess the contemplated 
expansion. 

Finally, as stated previously, execution of the ITAM program on the 
100,000 acres would permit training land to be accessible and usable. 
It would be premature to project what future cost would be; however, 
since the FY 2009 ITAM requirement for PCMS was $2.42M, Army estimates 
the future requirement will be between $1.0M and $1.5M annually. The 
Army strongly disagrees with the implication that ITAM and other 
sustainment costs are a factor of such significance that it could alter 
the validity or necessity of the expansion itself. 

As noted earlier in the comments to the “Highlights” section, the Army 
disagrees with GAO’s assessment that “growth in the estimated price per 
acre,” is a ‘problem’ that needs to be ‘addressed.’ The Army has never 
previously released any information to the public on estimated costs 
per acre. Cost figures discussed by GAO do not reflect any 
determination of fair market value, because no appraisals have been 
conducted. The estimated cost figures generated by the Army are used 
solely for internal planning and budgeting purposes and include best 
guesses as to the cost for land, improvements, relocation assistance, 
and administrative cost, but the discussion of cost estimates in the 
GAO has strong potential to be confusing and misleading to the public. 
Additionally, Congress did not ask for a discussion or explanation of 
cost estimates. Army strongly recommends that discussion of estimated 
land costs should be removed from the report. 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Brian J. Lepore, (202) 512-4523 or leporeb@gao.gov: 

Acknowledgments: 

In addition to the contact named above, Mark Little, Assistant 
Director; Ron La Due Lake; Mae Jones; Kate Lenane; Josh Margraf; 
Courtney Reid; and Roger Tomlinson made major contributions to this 
report. 

[End of section] 

Footnotes: 

[1] Army transformation and modularity efforts include the 
standardization of unit structure to modular brigade combat teams and 
integration of new technology and equipment to make the Army more 
deployable, flexible, lethal, and adaptive. In 2007, the President 
announced the Grow the Army initiative, which is expected to increase 
the Army's troop strength by 74,200 soldiers including active, National 
Guard, and Reserve units by 2013. 

[2] Department of the Army, Range and Training Land Strategy 
(Washington, D.C.: Feb. 11, 2004). 

[3] Pub. L. No. 109-364, § 2827 (2006). 

[4] Pub. L. No. 110-161, Division I, Title IV, § 409 (2007). 

[5] Pub. L. No. 110-181, § 2831(a) (2008). 

[6] Pub. L. No. 110-329, Division E, Title I, § 127 (2008). 

[7] NEPA, codified as amended at 42 U.S.C. § 4321-4347, establishes 
environmental policies and procedures that are required to be followed 
by all federal agencies to the fullest extent possible. In accordance 
with these requirements and the regulations for implementing NEPA 
established by the Council for Environmental Quality, agencies 
typically evaluate the likely environmental effects of a project they 
are proposing to undertake with an environmental assessment and/or 
environmental impact statement. The Council on Environmental Quality is 
responsible for, among other things, issuing guidelines and reviewing 
agencies' policies and procedures to ensure compliance with the act. 
Council on Environmental Quality regulations implementing NEPA appear 
at 40 C.F.R. Part 1500. 

[8] Pub. L. No. 110-181, § 2831(b) (2008). 

[9] In addition to this review of the Army's 2008 report on the Piñon 
Canyon Maneuver Site, we also reviewed the Army's approach for 
acquiring additional training land, including the information in the 
Army Range Requirements Model. The results of both reviews will be 
published on January 13, 2009. See GAO, Defense Infrastructure: Army's 
Approach for Acquiring Land Is Not Guided by Up-to-Date Strategic Plan 
or Always Communicated Effectively, [hyperlink, 
http://www.gao.gov/products/GAO-09-32] (Washington, D.C.: Jan. 13, 
2009). 

[10] The 29 provisions are listed in appendix II. 

[11] Department of the Army Regulation 350-19, Sustainable Range 
Program, U.S. Army Chief of Staff (Washington, D.C.: Aug. 30, 2005). 
According to Army Regulation 350-19, a military land acquisition 
proposal is a series of questions intended to provide senior leadership 
with the essential information to make a decision about a major land 
acquisition. When preparing the proposal, the proponent installation is 
to summarize, where applicable, information detailed in the range 
complex master plan, range development plan, and analysis of 
alternatives study. The proposal is to include a map of the proposed 
acquisition, the purpose of the acquisition, potential effects on 
surrounding communities, and several other items related to the 
proposed land acquisition. 

[12] Consolidated Appropriations Act, 2008, Pub. L. No. 110-161, 
Division I, Title IV, § 409 (2007). 

[13] Consolidated Security, Disaster Assistance, and Continuing 
Appropriations Act, 2009, Pub. L. No. 110-329, Division E, Title I, § 
127 (2008). 

[14] See Army's Range and Training Land Strategy. 

[15] Pub. L. No. 109-364, § 2827 (2006). 

[16] Department of the Army, National Defense Authorization Act Section 
2827(a) Report on Piñon Canyon Maneuver Site (Washington, D.C.: Dec. 8, 
2006). 

[17] Pub. L. No. 110-161, Division I, Title IV, § 409 (2007). 

[18] Pub. L. No. 110-181, § 2831 (2008). 

[19] Pub. L. No. 110-329, Division E, Title I, § 127 (2008). 

[20] Army training doctrine and policy are provided in four key 
documents: Army Training Circular 25-1, Training Land, U.S. Army Chief 
of Staff (Washington, D.C.: Mar. 15, 2004); Army Training Circular 25- 
8, Training Ranges, U.S. Army Chief of Staff (Washington, D.C.: Apr. 5, 
2004); Army Pamphlet 350-38, Standards in Training Commissions, U.S. 
Army Chief of Staff (Washington, D.C.: July 24, 2008); and Army 
Pamphlet 415-28, Real Property Category Codes, U.S. Army Chief of Staff 
(Washington, D.C.: Apr. 11, 2006). 

[21] 40 C.F.R. § 1502.13-1502.16. 

[22] GAO, Defense Infrastructure: Army's Approach for Acquiring Land Is 
Not Guided by an Up-to-Date Strategic Plan or Always Communicated 
Effectively, [hyperlink, http://www.gao.gov/products/GAO-09-32] 
(Washington, D.C.: Jan. 13, 2009). 

[23] See Department of the Army Regulation 350-19. 

[24] 40 C.F.R. § 1502.13-1502.16. 

[25] GAO, Defense Infrastructure: Army's Approach for Acquiring Land Is 
Not Guided by Up-to-Date Strategic Plan or Always Communicated 
Effectively, [hyperlink, http://www.gao.gov/products/GAO-09-32] 
(Washington, D.C.: Jan.13, 2009). 

[26] See [hyperlink, http://www.gao.gov/products/GAO-09-32]. 

[End of section] 

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