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the Sustainability of Training Ranges' which was released on September 
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GAO-10-977R: 

United States Government Accountability Office: 
Washington, DC 20548: 

September 14, 2010: 

Congressional Committees: 

Subject: Military Training: DOD Continues to Improve Its Report on the 
Sustainability of Training Ranges: 

Recent operations in Iraq, Afghanistan, and other locations around the 
world have highlighted the need for U.S. forces to train as they 
intend to fight. Military training ranges provide the primary means to 
accomplish this goal. The Department of Defense's (DOD) training 
ranges vary in size from a few acres, for small arms training, to over 
a million acres for large maneuver exercises and weapons testing, and 
include broad open ocean areas for offshore training and testing. New 
advances in military technology to combat emerging threats in ongoing 
operations in Iraq, Afghanistan, and other locations around the world 
generate the need to continually update and maintain DOD's training 
ranges. Senior DOD and military service officials have reported for 
some time that they face increasing difficulties in carrying out 
realistic training at military installations due to outside 
influences. DOD has defined a number of factors--including air 
pollution, noise pollution, endangered species, critical habitats and 
other protected resources, and urban growth around installations--that 
it says encroach upon its training ranges and capabilities. 

Because the military faces obstacles in acquiring new training lands, 
the preservation and sustainment of its current lands are a priority. 
Sustainable training range management focuses on practices that allow 
the military to manage its ranges in a way that ensures their 
usefulness well into the future. As required by section 366(a) of the 
Bob Stump National Defense Authorization Act for Fiscal Year 2003 (as 
amended),[Footnote 1] DOD was to submit a comprehensive plan for using 
existing authorities available to the department to address training 
constraints caused by limitations on the use of worldwide military 
lands, marine areas, and airspace to Congress in fiscal year 2004 with 
annual progress reports beginning in fiscal year 2005 and extending 
through 2013. Enclosure I includes the full text of section 366 as 
amended. As part of the preparation of this plan, the Secretary of 
Defense was to conduct an assessment of current and future training 
range requirements and an evaluation of the adequacy of DOD's current 
range resources to meet those requirements. The plan was also to 
include: 

* proposals to enhance training range capabilities and address any 
shortfalls in resources identified pursuant to that assessment and 
evaluation; 

* goals and milestones for tracking planned actions and measuring 
progress; 

* projected funding requirements to implement planned actions; and: 

* designation of an office in the Office of the Secretary of Defense 
and in each of the military departments responsible for overseeing 
implementation of the plan. 

Section 366(a)(5) requires that DOD's annual reports describe the 
department's progress in implementing its comprehensive plan and any 
actions taken or to be taken to address training constraints caused by 
limitations on the use of military lands, marine areas, and airspace. 
Section 366(b) required DOD to submit a report to Congress on its 
plans to improve its readiness reporting system to reflect the 
readiness impact of certain training constraints. Section 366(c) also 
requires DOD to develop and maintain a training range inventory to be 
submitted with the President's budget for fiscal year 2004 and annual 
updates for 2005 through 2013. Section 366(d) further required that we 
evaluate the plans submitted pursuant to subsections 366(a) and (b), 
and submit our annual evaluations of DOD's reports to Congress within 
90 days[Footnote 2] of receiving these reports from DOD. 

Although in our prior reviews of DOD's sustainable ranges reports we 
noted that DOD had not addressed various required elements when it 
initially submitted its comprehensive plan, we concluded that DOD had 
improved its report submissions over time and had reported on actions 
taken on various GAO recommendations. Enclosure II provides a complete 
list of our recommendations and DOD's actions in response to them. Our 
review of DOD's 2010 sustainable ranges report is our seventh response 
to section 366 of the Bob Stump National Defense Authorization Act for 
Fiscal Year 2003 (as amended). In this review we discuss actions DOD 
reported to address two GAO recommendations made in response to prior 
sustainable ranges reports--specifically, that DOD develop 
quantifiable goals in the comprehensive plan and include in that plan 
projected funding estimates for range sustainment efforts.[Footnote 3] 
We focus on these recommendations because DOD did not fully address 
them in its previously issued sustainable ranges reports. We also 
discuss differences between DOD's 2010 and 2009 sustainable ranges 
reports and opportunities to improve future ones. In accordance with 
the mandate, we are submitting this report to you within 90 days after 
having received DOD's 2010 sustainable ranges report on June 16, 2010. 

Scope and Methodology: 

To review actions DOD reported to address two GAO recommendations made 
in response to prior sustainable ranges reports, we compared the 
information contained in DOD's 2010 sustainable ranges report with 
these two recommendations. We focused on these recommendations because 
DOD had not fully addressed them in its sustainable ranges reports. 
Regarding the remaining recommendations that GAO had made in response 
to prior sustainable ranges reports, at the time of our review, DOD 
had either taken action on these recommendations or was in the midst 
of implementing them. To determine the extent to which the 2010 
sustainable ranges report differs from the 2009 submission, we 
compared the two reports and discussed key revisions with military and 
other DOD officials involved with preparing these reports. We also 
discussed with Office of the Secretary of Defense (OSD) officials 
their plans for the 2011 report submission and reviewed their data 
request sent to the military services in July 2010 requesting 
information for the 2011 report. We further discussed with these and 
other military officials the extent to which opportunities exist for 
improving future sustainable ranges report submissions. We also 
reviewed the extent to which DOD's sustainable ranges report has 
addressed the elements of subsection 366(a)(5). The intent of our 
review was not to comprehensively evaluate the data presented in the 
2010 and 2009 sustainable ranges reports but rather to determine the 
extent to which the report indicated that DOD had made progress 
implementing prior recommendations and whether the report could be 
improved. 

We conducted this performance audit from June 2010 through September 
2010 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. 

DOD Addressed Two GAO Key Recommendations by Providing Measurable Data 
and Projected-Funding Estimates: 

As in years past, DOD has continued to show progress in addressing our 
recommendations related to the elements of section 366 of the Bob 
Stump National Defense Authorization Act for Fiscal Year 2003 (as 
amended). In 2009, we reiterated two prior recommendations that when 
implemented would provide Congress with specific and measurable range-
sustainment goals and milestones and the funding that would be needed 
to address those goals.[Footnote 4] Specifically, we recommended that 
DOD develop quantifiable goals in the comprehensive plan in order to 
better track planned actions and measure progress for implementing 
those actions. We also recommended that DOD include projected funding 
estimates of range-sustainment efforts. In the 2010 sustainable ranges 
report, DOD addressed these two key recommendations. 

DOD Developed Measurable Range-Sustainment Goals and Milestones and 
Identified OSD-and Service-Level Offices Responsible for Implementing 
Them: 

In our review of DOD's 2004 sustainable ranges report, we recommended 
that DOD provide quantifiable goals and milestones for tracking 
planned actions and measuring progress in future annual reports. DOD 
agreed with our recommendation and took steps to address it by 
identifying broad goals and some milestones in the 2005 sustainable 
ranges report. However, we reiterated this 2004 recommendation in our 
2009 review because the broad goals were not measurable. The 2010 
sustainable ranges report included a new set of goals that DOD states 
are measurable, attainable, and more closely aligned with the 
Integrated Product Team's[Footnote 5] seven sustainable-ranges focus 
areas. As stated in the 2010 report and confirmed through our 
discussions with OSD officials, DOD developed this new set of goals 
after determining in 2009 that many of the goals and milestones used 
in previous reports had either been overcome by other events or 
outlived their relevance. The new goals are to mitigate encroachment 
pressures on training activities from competing operation space (land, 
air, sea, space, and cyber) uses; mitigate frequency spectrum 
competition; meet military airspace challenges; manage increasing 
military demand for range space, address impacts from new energy 
infrastructure and renewable energy impacts; anticipate climate change 
impacts; and environmental stewardship. 

In the 2010 sustainable ranges report, DOD reports that using this new 
set of goals as a common framework, each military service created its 
own set of actions and milestones and provided dates for when each 
milestone is to be achieved. For example, in the 2010 report, the Navy 
identifies actions and milestones to address one of the new goals 
focused on sustaining excellence in environmental stewardship. The 
Navy plans to continue executing environmental-management and range- 
sustainability programs servicewide in accordance with applicable laws 
and regulations. Milestones to measure this action include renewing 
expiring annual Marine Mammal Protection Act authorizations; 
conducting an evaluation of implementation and effectiveness of 
integrated natural resources management plans at the end of each 
fiscal year; and complete ongoing environmental planning for at-sea 
operational areas and range complexes by the end of fiscal year 2012. 
By providing new goals along with service-specific actions and 
milestones, DOD has provided measurable data for identifying and 
tracking progress in mitigating encroachment in order to effectively 
evaluate prior efforts, thus satisfying the intent of our prior 
recommendation. 

In addition to the new goals, actions, and milestones, DOD identified 
in its 2010 report a list of training range offices within OSD and 
each of the military services responsible for implementing the planned 
actions and milestones. According to military and other DOD officials, 
these goals, actions, and milestones will continue to be reviewed and 
updated annually to ensure DOD continues to effectively address 
training requirements as well as constraints or limitations that may 
arise in the future. According to DOD officials, actions will be 
tracked to determine how well they were executed and to measure their 
level of effectiveness in meeting the goal's objective. By providing 
measurable actions and milestones and identifying the responsible 
offices for tracking progress toward these actions, DOD and 
congressional decision makers can more accurately assess progress made 
toward the goal of DOD-wide training range sustainment. 

DOD Included Projected Funding Estimates of Range-Sustainment Efforts: 

In our 2009 review, we reiterated our 2004 recommendation that DOD 
include funding projections of range sustainment efforts in its 
report. DOD concurred with our recommendation in 2004 and took some 
steps toward obtaining funding estimates from each of the services. 
For example, DOD created a Sustainable Ranges Funding Subgroup in 2004 
within the Working Integrated Product Team[Footnote 6] to develop a 
common framework across the military services for consistently and 
accurately tracking and reporting range sustainment funding. This 
group developed four main funding categories[Footnote 7] as a common 
starting point from which to report training range sustainment data. 
In the 2010 sustainable ranges report, DOD provided projected-funding 
estimates for each of the military services for the fiscal year 2009--
2015 time frame. This is the first year DOD has reported future 
funding estimates of its range sustainment efforts beyond the budget 
year. According to OSD officials, although DOD has not previously 
included this data in prior reports, the military services have been 
collecting data for projected-funding estimates since 2004. OSD 
officials also told us they included the data in this year's report 
after receiving approval to publish the information from the OSD 
Comptroller's Office. Each of the funding categories along with their 
definitions and specific examples are provided in the 2010 sustainable 
ranges report. According to the report, defining each of the funding 
categories helps ensure consistent data reporting across the services. 

DOD Added Context in the 2010 Sustainable Ranges Report as Compared 
with the 2009 Report to Make Data More Meaningful and Has Efforts 
Under Way to Provide Context for the Data Presented in Future Reports: 

According to DOD officials, significant differences between DOD's 2010 
and 2009 sustainable ranges reports include the addition of measurable 
range-sustainment goals and milestones and the projected funding 
estimates of range-sustainment efforts. During our review, we noted 
other differences. In the 2010 sustainable ranges report, DOD provided 
context for the data presented there, and efforts under way to gather 
data for the 2011 report point toward continued emphasis on providing 
context for reported data. In addition, DOD summarized actions under 
way or planned to address training constraints and provided an update 
on critical issues facing the services regarding range capabilities 
and encroachment factors. 

DOD Provided Context for the Data Presented in the 2010 Report, and 
Data-Gathering Efforts for the 2011 Report Point toward a Continued 
Emphasis on Providing Context for Reported Data: 

DOD moved range-specific detail that was previously located in 
sustainable ranges report appendixes into the body of the 2010 report. 
In last year's report, DOD published range-specific detail in the 
report appendixes apart from the overall range encroachment and 
capability scores. However, in the 2010 report DOD moved this 
narrative into the report body in order to directly link the relevant 
chapter and range data with the appropriate supporting narrative. For 
example, the Marine Corps warfare training center in Bridgeport, 
California, reported a moderate overall encroachment score per this 
year's report. Specific examples of factors that contribute to that 
encroachment--such as restrictions on the use of land adjacent to the 
warfare training center--are explained in a comment section directly 
linked to the encroachment score. Our review found that the 
information provided in the report body provides the reader with a 
more direct link between a range's assessment and the factors that 
contribute to a range's overall capability and encroachment score. 

The 2010 sustainable ranges report also included a new success-stories 
section highlighting significant areas of progress in mitigating 
encroachment. For example, as part of the Army Compatible Use Buffer 
Program,[Footnote 8] the Army partnered with groups including the 
Conservation Fund, the Nature Conservancy, and the U.S. Fish and 
Wildlife Service to put nearly 3,000 acres of land into conservation 
easements near Fort A.P. Hill, Virginia. The report states this buffer 
preserves the installation's training mission while also conserving 
valuable wildlife habitat and sensitive natural and cultural resources. 

According to officials from OSD and the military services, actions and 
milestones identified in the 2010 report will be continuously revised 
and updated in the 2011 report. DOD officials hosted a workshop in 
June 2010 to begin data collection for the 2011 report. DOD expects to 
issue its next sustainable ranges report by February 2011. As in years 
past, development of the 2011 report will involve initial staff level 
inputs, coordination through the Sustainable Ranges Integrated Product 
Team, and formal coordination with the services and OSD. Plans for 
next year's sustainable ranges report also include providing more 
information about the relationship between range data and the 
installations reports feeding into the Defense Readiness Reporting 
System.[Footnote 9] This information will include encroachment and 
capability data regarding individual installations. 

According to the data input request OSD sent to the military services 
for the 2011 report, OSD expanded the data entry and analysis process. 
OSD instructed the services to provide a clearer level of detail and 
comments regarding whether the range complex's capabilities or 
encroachment pressures have been improving or degrading, as well as 
future projections. In other words, OSD requested the services to 
provide more detailed historical information on factors that 
contribute to a range's overall capability or encroachment score. 
Further, OSD requested the services to provide future projections of a 
range's overall encroachment and capability scores and more detailed 
information on potential changes to the scores in future years. 
Potential changes could be due to a variety of circumstances, such as 
improved accuracy in the range assessment data or changes in 
encroachment pressures. By requesting more details regarding 
historical information and future projections of a range's overall 
encroachment or capability score, OSD and the military services may 
have a better understanding of why a range has a certain score so that 
it can better mitigate encroachment and reduce training constraints. 

OSD and Army officials agreed that trend analysis of range data 
collected over multiple years could also improve future reports by 
providing a more comprehensive understanding of a range's capability 
or encroachment score, rather than displaying the data as a snapshot 
in time. An OSD official also told us the Integrated Product Team is 
working to improve direct correlation between encroachment assessments 
in the 2011 sustainable ranges report, and the requests being made by 
military services for funds through the Readiness and Environmental 
Protection Initiative.[Footnote 10] For example, he said that if the 
report assesses a certain training range with a low capability or 
encroachment score, the Integrated Product Team wants to ensure that 
the military service owning the range is requesting appropriate funds 
through the Readiness and Environmental Protection Initiative to 
improve those ranges. However, an Army official told us such a 
correlation may be difficult because the range assessment process is 
currently based on data collected as a snapshot in time. The official 
stated this does not provide the cumulative bigger picture or show how 
much progress the Army, for instance, has made since the report's 
inception. A snapshot in time does not allow for a broader view of 
what the Army is doing to mitigate encroachment. For example, if a 
particular training range reports severe encroachment year after year, 
it may imply the military service is not working to mitigate the 
encroachment. However, if the assessment is based on an endangered 
species law, the service can do little to reverse this effect, 
regardless of the funding that might be available. OSD and Army 
officials agree that using range data to perform trend analysis could 
help prevent potential misconceptions and provide a more comprehensive 
understanding of what the range's capability and encroachment score 
means. 

DOD Reported Progress, Summarized Actions to Address Training 
Constraints, and Provided an Update on Critical Issues Facing the 
Services Regarding Range Capabilities and Encroachment Factors: 

DOD reported progress in implementing its comprehensive plan as 
required by section 366 of the Bob Stump National Defense 
Authorization Act for Fiscal Year 2003 (as amended),[Footnote 11] by 
providing new goals, actions, and milestones for this plan as 
described above. DOD also reported actions taken or to be taken to 
address training constraints caused by limitations on the use of 
military lands, marine areas, and airspace. For example, in the 2010 
range assessments, all four of the military services reported 
increased range capability scores. Also, according to the 2010 
sustainable ranges report, regional partnerships have enabled DOD to 
work successfully with multistate, multiagency teams to address 
substantial sustainability issues. For example, OSD and military 
service officials stated that renewable energy development has the 
potential to significantly impact their ability to train and is a 
growing area of concern. Coordination with these regional 
partnerships[Footnote 12] has allowed DOD to identify and address 
renewable energy development by seeking compatible land uses that are 
mutually beneficial to all concerned parties. By forming these 
partnerships, DOD has taken steps to prevent conflicts between 
military training and proposed renewable energy development. 

DOD's 2010 sustainable ranges report also includes additional updates 
to the special interest section for each of the services. The special 
interest section briefly highlights critical issues facing the 
services regarding range capabilities and encroachment factors. For 
example, this year the Air Force provides information about the 
integration of unmanned aerial systems into existing airspace and its 
efforts to increase flight safety. We previously reported that by 
highlighting its most pressing range sustainability issues, DOD 
officials can begin to prioritize the department's actions to address 
range issues in the most efficient and effective manner. DOD officials 
told us the sustainable ranges report will continue to include annual 
updates to the special interest section regarding general issues 
relevant to the report. 

Agency Comments: 

In commenting on a draft of this report, DOD concurred with the 
findings. DOD's comments are included in their entirety in enclosure 
III. DOD also provided technical comments, which we have incorporated 
into this report as appropriate. 

We are sending copies of this report to the Secretary of Defense; the 
Secretaries of the Army, the Navy, and the Air Force; the Commandant 
of the Marine Corps; the Director, Office of Management and Budget, 
and interested congressional committees. In addition, this report will 
be available at no charge on our Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, 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. GAO staff who made key contributions 
to this report include James Reifsnyder, Assistant Director; Courtney 
Reid; Jena Whitley; Alex Wise; Michael Willems; and Mae Jones. 

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 Ike Skelton:
Chairman:
The Honorable Howard P. McKeon:
Ranking Member:
Committee on Armed Services:
House of Representatives: 

The Honorable Norman D. Dicks:
Chairman:
The Honorable C. W. Bill Young:
Ranking Member:
Subcommittee on Defense:
Committee on Appropriations:
House of Representatives: 

[End of section] 

Enclosure I: 

Section 366 of the Bob Stump National Defense Authorization Act for 
Fiscal Year 2003 (as amended)[Footnote 13] 

SEC. 366. Training Range Sustainment Plan, Global Status of Resources 
and Training System, and Training Range Inventory. 

(a) Plan Required--(1) The Secretary of Defense shall develop a 
comprehensive plan for using existing authorities available to the 
Secretary of Defense and the Secretaries of the military departments 
to address training constraints caused by limitations on the use of 
military lands, marine areas, and airspace that are available in the 
United States and overseas for training of the Armed Forces. 

(2) As part of the preparation of the plan, the Secretary of Defense 
shall conduct the following: 

(A) An assessment of current and future training range requirements of 
the Armed Forces. 

(B) An evaluation of the adequacy of current Department of Defense 
resources (including virtual and constructive training assets as well 
as military lands, marine areas, and airspace available in the United 
States and overseas) to meet those current and future training range 
requirements. 

(3) The plan shall include the following: 

(A) Proposals to enhance training range capabilities and address any 
shortfalls in current Department of Defense resources identified 
pursuant to the assessment and evaluation conducted under paragraph 
(2). 

(B) Goals and milestones for tracking planned actions and measuring 
progress. 

(C) Projected funding requirements for implementing planned actions. 

(D) Designation of an office in the Office of the Secretary of Defense 
and in each of the military departments that will have lead 
responsibility for overseeing implementation of the plan. 

(4) At the same time as the President submits to Congress the budget 
for fiscal year: 

2004, the Secretary of Defense shall submit to Congress a report 
describing the progress made in implementing this subsection, 
including: 

(A) the plan developed under paragraph (1); 

(B) the results of the assessment and evaluation conducted under 
paragraph (2); and: 

(C) any recommendations that the Secretary may have for legislative or 
regulatory changes to address training constraints identified pursuant 
to this section. 

(5) At the same time as the President submits to Congress the budget 
for each of fiscal years 2005 through 2013, the Secretary shall submit 
to Congress a report describing the progress made in implementing the 
plan and any additional actions taken, or to be taken, to address 
training constraints caused by limitations on the use of military 
lands, marine areas, and airspace. 

(b) Readiness Reporting Improvement--Not later than June 30, 2003, the 
Secretary of Defense, using existing measures within the authority of 
the Secretary, shall submit to Congress a report on the plans of the 
Department of Defense to improve the Global Status of Resources and 
Training System to reflect the readiness impact that training 
constraints caused by limitations on the use of military lands, marine 
areas, and airspace have on specific units of the Armed Forces. 

(c) Training Range Inventory--(1) The Secretary of Defense shall 
develop and maintain a training range inventory for each of the Armed 
Forces: 

(A) to identify all available operational training ranges; 

(B) to identify all training capacities and capabilities available at 
each training range; and: 

(C) to identify training constraints caused by limitations on the use 
of military lands, marine areas, and airspace at each training range. 

(2) The Secretary of Defense shall submit an initial inventory to 
Congress at the same time as the President submits the budget for 
fiscal year 2004 and shall submit an updated inventory to Congress at 
the same time as the President submits the budget for fiscal years 
2005 through 2013. 

(d) GAO Evaluation--The Secretary of Defense shall transmit copies of 
each report required by subsections (a) and (b) to the Comptroller 
General. Within 90 days after receiving a report, the Comptroller 
General shall submit to Congress an evaluation of the report. 

(e) Armed Forces Defined--In this section, the term "Armed Forces" 
means the Army, Navy, Air Force and Marine Corps. 

[End of section] 

Enclosure II: 

List of Prior GAO Reviews and Recommendations, and DOD Action to Date: 

GAO-10-103R: DOD's Report on Sustainability of Training Ranges 
Addresses Most of the Congressional Reporting Requirements and 
Continues to Improve with Each Annual Update (October 27, 2009). 

GAO recommendation: Because our prior recommendation for quantifiable 
goals and milestones for tracking planned actions and measuring 
progress and our recommendation for projecting funding requirements to 
more fully address training constraints remain open, we did not make 
new recommendations in this report; 
Original DOD response: N/A; 
DOD actions: N/A. 

GAO-09-128R: Improvement Continues in DOD's Reporting on Sustainable 
Ranges, but Opportunities Exist to Improve Its Range Assessments and 
Comprehensive Plan (December 15, 2008). 

GAO recommendation: Include each service's rationale for excluding the 
specific training ranges not included in its assessment of the 
adequacy of current resources to meet requirements in future 
sustainable ranges reports; 
Original DOD response: Concur. Future reports will incorporate 
rationale as to why some ranges may be included in the inventory, yet 
not have a capability or encroachment assessment performed; 
DOD actions: DOD's included in its 2009 report the rationale for 
excluding some Army and Marine Corps range assessments. In 2010, DOD 
extended this rationale to all service ranges not assessed in the 
report. 

GAO recommendation: Include the Marine Corps' individual combat 
training elements as the mission areas in the range capability and 
encroachment assessment in future sustainable ranges reports;
Original DOD response: Did not concur. The Marine Corps' approach to 
assessing range capability and encroachment is consistent with all the 
source documents and methodologies by which the Marine Corps manages 
and resources its ranges. The capabilities assessments are designed to 
measure the ranges' ability to support the levels of training on the 
Marine Corps training continuum. Those levels of training are all 
based on established training responsibilities embodied in Marine 
Corps Tasks. In future reports, they will provide greater explanatory 
comments on both capabilities and encroachment impacts, but the 
framework established in their Required Range Capabilities Document, 
range complex management plans, and range management orders all 
support the methodology they have employed in this report; 
DOD actions: No further changes were made since our last review of the 
sustainable ranges report found that the Marine Corps' mission areas 
have remained the same. In regard to the 2009 sustainable ranges 
report, DOD stated that greater explanatory comments on impacts to 
training were provided in the Special Interest section of Chapter 3 
and Appendix C for all services. DOD officials had also stated that 
the Marine Corps is considering how best to provide future assessments 
to include greater detail in response to an increased emphasis on 
developing consistent measures for DOD readiness reporting. 

GAO recommendation: Update on the actions taken by the Air Force to 
address DOD's modernization and investment goals for range sustainment 
in future sustainable ranges reports; 
Original DOD response: Concur. Updates of actions taken by each 
Service over the proceeding year towards completion of goals and 
milestones will be addressed; 
DOD actions: This year's report includes a list of seven new goals 
which align with the seven sustainable ranges Integrated Product Team 
(IPT) focus areas. Therefore the update to the modernization and 
investment goal is no longer applicable. The Air Force has provided 
actions and milestones with measurable end dates for all of the new 
goals except for mitigating frequency spectrum competition which is to 
be determined. An Air Force official stated that actions and 
milestones toward this goal will be included in the 2011 ranges report. 

GAO recommendation: Include a detailed description of all funding data 
included in each funding category, for each of the military services 
in future sustainable ranges reports; 
Original DOD response: Concur. The Office of the Secretary of Defense 
will work with the Services to provide a more detailed description of 
what areas are financed within each of the funding categories; 
DOD actions: No further changes have been made since DOD included a 
table with specific examples for each of the four funding categories 
in their 2009 sustainable ranges report. 

GAO-08-10R: Improvement Continues in DOD's Reporting on Sustainable 
Ranges, but Opportunities Exist to Improve Its Range Assessments and 
Comprehensive Plan (October 11, 2007). 

GAO recommendation: Develop clear criteria and standard methods for 
assessing current and future training range requirements and 
capabilities; 
Original DOD response: Concur. Will continue to develop and improve 
the criteria and methodology associated with our range requirements 
and capabilities assessment processes in our subsequent reports; 
DOD actions: No further changes were found since DOD established 
standardized criteria and identified common factors to assess range 
capabilities and encroachment in the 2008 sustainable ranges report. 

GAO recommendation: Include funding information on the services' range 
sustainment efforts in funding reports; 
Original DOD response: Concur. Programming funding data associated 
with range sustainment will be captured and documented in future 
Sustainable Ranges Reports to Congress to the extent possible. 
However, any funding data presented beyond the current year will be 
subject to a caveat that final Service budgets for out years are 
subject to change; 
DOD actions: DOD's 2010 report provides training range funding 
projections through fiscal year 2015. Additionally, footnotes to the 
table provide explanation as to how some funding requirements are 
determined. 

GAO-06-725R: Improvement Continues in DOD's Reporting on Sustainable 
Ranges but Additional Time Is Needed to Fully Implement Key 
Initiatives (June 20, 2006). 

GAO recommendation: Because our previous recommendations remained 
open, we did not recommend any new executive actions in this report; 
Original DOD response: N/A; 
DOD actions: N/A. 

GAO-06-29R: Some Improvements Have Been Made in DOD's Annual Training 
Range; Reporting but It Still Fails to Fully Address Congressional 
Requirements (Oct. 25, 2005). 

GAO recommendation: Because our prior recommendations for improving 
the Office of the Secretary of Defense's annual training range 
reporting remained open, valid, and not fully addressed, we did not 
make new recommendations in this report; 
Original DOD response: N/A; 
DOD actions: N/A. 

GAO-04-608: Military Training: DOD Report on Training Ranges Does Not 
Fully Address Congressional Reporting Requirements (June 4, 2004). 

GAO recommendation: Develop an integrated training range database that 
identifies available training resources, specific capacities and 
capabilities, and training constraints caused by limitations on the 
use of training ranges, which could be continuously updated and shared 
among the Services at all command levels, regardless of Service 
ownership; 
Original DOD response: Did not concur. Each military service already 
processes and is improving range information systems that address the 
features described in this recommendation. Further, the Department 
agrees that, as a long-term goal these systems should be linked to 
support joint use. It is DOD policy to document encroachment concerns 
and environmental considerations and improve information systems 
related to range management. The services and the Office of the 
Secretary of Defense are moving forward in a deliberate approach that 
builds on existing systems and carefully manages the costs and risks 
inherent in information system integration and development. As part of 
our yearly Section 366 reports, the Department will document progress 
in this evolutionary effort to link and improve the Service range 
information systems. However, the department non-concurs with the 
recommendation ... It must be recognized that each Service operates 
ranges to meet specific training requirements. While increased cross- 
Service or cross-functional use is a DOD goal, it does not resolve 
training constraints brought about by encroachment; 
DOD actions: According to DOD officials, the Range Assessment Module 
(RAM) has been incorporated into the Defense Readiness Reporting 
System. DOD is currently updating RAM to provide the module user with 
a strategic look at how ranges are being used and allow unit 
commanders the ability to leave feedback regarding range capabilities. 

GAO recommendation: Develop a comprehensive plan, which includes 
quantifiable goals and milestones for tracking planned actions and 
measuring progress, and projected funding requirements to more fully 
address identified training constraints; 
Original DOD response: Concur. Meeting section 366 requirements can be 
accomplished only through a long-term approach. Under the Office of 
the Secretary of Defense leadership, each of the military services has 
initiated an enhanced range management and comprehensive planning 
process, as an integral element of expanding range sustainability 
programs. In line with this evolution, future reports will more fully 
address goals and milestones and project funding requirements 
associated with these comprehensive plans. The department is and will 
continue to execute a comprehensive program to improve sustainability 
of its ranges, and disagrees with the implication in this 
recommendation that it does not; 
DOD actions: The 2010 sustainable ranges report has seven new goals 
that are measurable, attainable, and more in line with the Integrated 
Product Team's focus areas. The report outlines which offices in each 
of the military services are responsible for actions needed to achieve 
each milestone. The report also outlines actions and milestones for 
each service to meet a particular goal; and provide measurable dates 
for when each milestone is to be accomplished. DOD officials stated 
that actions will be reviewed and updated as necessary during monthly 
Working Integrated Product Team meetings. Additionally, the report 
provides training range funding projections through fiscal year 2015. 

GAO recommendation: Assess current and future training range 
requirements and evaluate the adequacy of current resources to meet 
these requirements; 
Original DOD response: Did not concur. The Department has begun a 
program to better define range requirements. Because a valid 
requirements base must be a bottom-up process, this effort entails 
detailed work at each installation. It is unclear why GAO chose to not 
examine these efforts. Also, it is both impractical and inappropriate 
to include this level of detail in an OSD-level report. DOD believes 
that the Congress is better served if the Department describes, 
summarizes, and analyzes training requirements in its Section 366 
report, rather than simply providing the requirements themselves; 
DOD actions: According to DOD and military service officials, a 
Sustainable Ranges Funding Subgroup was formed in 2004 and four main 
funding categories were defined and agreed upon by each of the 
military services. DOD noted in this year's sustainable ranges report 
that future funding will necessarily be subject to change and is 
presented for planning purposes only. 

GAO recommendation: Develop a readiness reporting system to reflect 
the impact on readiness caused by training constraints due to 
limitations on the use of training ranges; 
Original DOD response: Did not concur. The Department stated that it 
is inappropriate to modify the Global Status of Resources Training 
System report to address encroachment. DOD believes it is best to 
assess how encroachment impacts affect the ability of installations 
and ranges to conduct training and testing. DOD plans to incorporate 
encroachment impacts on readiness into the Defense Readiness Reporting 
System (DRRS), which is currently under development; 
DOD actions: According to DOD officials, DRRS is operational and 
incorporates the capability and encroachment assessments for training 
contained in the sustainable ranges report. Currently the Range 
Assessment Module (RAM) shows information at the unit-level. RAM is 
continuing to be updated in an effort to provide the end-user with a 
more strategic assessment of individual range capabilities. 

Sources: GAO and DOD. 

[End of table] 

[End of section] 

Enclosure III: 

Comments from the Department of Defense: 

Office Of The Under Secretary Of Defense: 
Personnel And Readiness: 
4000 Defense Pentagon: 
Washington, D.C. 20301-4000: 

September 2, 2010: 

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 Department of Defense (DoD) response to the Government 
Accountability Office Draft Report GAO-10-977R, "Military Training: 
DoD Continues to Improve Its Report on the Sustainability of Training 
Ranges," dated August 13, 2010 (GAO Code 351479). 

Thank you for the opportunity to comment on this draft. The DoD 
appreciates the opportunity to work with the GAO to continually 
improve reporting on the ability of our training ranges to meet the 
needs of the warfighter. The Department agrees in general with the 
report and has no specific comments. 

Sincerely, 

Signed by: 
Samuel D. Kleinman
Deputy Under Secretary of Defense (Readiness): 

[End of section] 

Related GAO Products: 

Military Training: DOD's Report on the Sustainability of Training 
Ranges Addresses Most of the Congressional Reporting Requirements and 
Continues to Improve with Each Annual Update. [hyperlink, 
http://www.gao.gov/products/GAO-10-103R]. Washington, D.C.: October 
27, 2009. 

Military Training: Improvement Continues in DOD's Reporting on 
Sustainable Ranges, but Opportunities Exist to Improve Its Range 
Assessments and Comprehensive Plan. [hyperlink, 
http://www.gao.gov/products/GAO-09-128R]. Washington, D.C.: December 
15, 2008. 

Military Training: Compliance with Environmental Laws Affects Some 
Training Activities, but DOD Has Not Made a Sound Business Case for 
Additional Environmental Exemptions. [hyperlink, 
http://www.gao.gov/products/GAO-08-407]. Washington, D.C.: March 7, 
2008. 

Improvement Continues in DOD's Reporting on Sustainable Ranges, but 
Opportunities Exists to Improve Its Range Assessments and 
Comprehensive Plan. [hyperlink, 
http://www.gao.gov/products/GAO-08-10R]. Washington, D.C.: October 11, 
2007. 

Improvement Continues in DOD's Reporting on Sustainable Ranges, but 
Additional Time Is Needed to Fully Implement Key Initiatives. 
[hyperlink, http://www.gao.gov/products/GAO-06-725R]. Washington, 
D.C.: June 20, 2006. 

Military Training: Funding Requests for Joint Urban Operations 
Training and Facilities Should Be Based on Sound Strategy and 
Requirements. [hyperlink, http://www.gao.gov/products/GAO-06-193]. 
Washington, D.C.: December 8, 2005. 

Some Improvements Have Been Made in DOD's Annual Training Range 
Reporting but It Still Fails to Fully Address Congressional 
Requirements. [hyperlink, http://www.gao.gov/products/GAO-06-29R]. 
Washington, D.C.: October 25, 2005. 

Military Training: Actions Needed to Enhance DOD's Program to 
Transform Joint Training. [hyperlink, 
http://www.gao.gov/products/GAO-05-548]. Washington, D.C.: June 21, 
2005. 

Military Training: Better Planning and Funding Priority Needed to 
Improve Conditions of Military Training Ranges. [hyperlink, 
http://www.gao.gov/products/GAO-05-534]. Washington, D.C.: June 10, 
2005. 

Military Training: DOD Report on Training Ranges Does Not Fully 
Address Congressional Reporting Requirements. [hyperlink, 
http://www.gao.gov/products/GAO-04-608[. Washington, D.C.: June 4, 
2004. 

Military Training: Implementation Strategy Needed to Increase 
Interagency Management for Endangered Species Affecting Training 
Ranges. [hyperlink, http://www.gao.gov/products/GAO-03-976[. 
Washington, D.C.: September 29, 2003. 

Military Training: DOD Approach to Managing Encroachment on Training 
Ranges Still Evolving. [hyperlink, 
http://www.gao.gov/products/GAO-03-621T[. Washington, D.C.: April 2, 
2003. 

Military Training: DOD Lacks a Comprehensive Plan to Manage 
Encroachment on Training Ranges. [hyperlink, 
http://www.gao.gov/products/GAO-02-614[. Washington, D.C.: June 11, 
2002. 

Military Training: DOD Needs a Comprehensive Plan to Manage 
Encroachment on Training Ranges. [hyperlink, 
http://www.gao.gov/products/GAO-02-727T]. Washington, D.C.: May 16, 
2002. 

Military Training: Limitations Exist Overseas but Are Not Reflected in 
Readiness Reporting. [hyperlink, 
http://www.gao.gov/products/GAO-02-525]. Washington, D.C.: April 30, 
2002. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 107-314 (2002). Section 366 originally required 
reports for fiscal years 2005 through 2008. However, this requirement 
was extended through 2013 by section 348 of the John Warner National 
Defense Authorization Act for Fiscal Year 2007, Pub. L. No. 109-364 
(2006). Additionally, section 1063(c)(2) of Pub. L. No. 110-181 (2008) 
made a clerical amendment to section 348 of Pub. L. No. 109-364. 

[2] This requirement was extended from 60 days to 90 days by section 
348 of Pub. L. No. 109-364 (2006). 

[3] GAO, Military Training: DOD's Report on the Sustainability of 
Training Ranges Addresses Most of the Congressional Reporting 
Requirements and Continues to Improve with Each Annual Update. 
[hyperlink, http://www.gao.gov/products/GAO-10-103R] (Washington, 
D.C.: Oct. 27, 2009). 

[4] GAO, Military Training: DOD's Report on the Sustainability of 
Training Ranges Addresses Most of the Congressional Reporting 
Requirements and Continues to Improve with Each Annual Update. 
[hyperlink, http://www.gao.gov/products/GAO-10-103R]. (Washington, 
D.C.: Oct. 27, 2009). 

[5] The Sustainable Ranges Integrated Product Team's (IPT) mission is 
to be the DOD coordinating body responsible for oversight, 
development, and coordination of a comprehensive DOD response to 
encroachment pressures that adversely affect ranges. This IPT operates 
on two levels. The Overarching Integrated Product Team (OIPT) acts as 
the coordination forum for the development of range sustainment 
strategies. The Working Integrated Product Team (WIPT) works under the 
direction of the OIPT and meets regularly to implement the OIPT's 
recommendations and direction. 

[6] The Working Integrated Product Team also collaborates with other 
DOD and military service organizations to address range sustainability 
issues. 

[7] The funding categories are modernization and investment; 
operations and maintenance; environmental; and encroachment. 

[8] The Army Compatible Use Buffer program is used by the Army to 
enter into cooperative agreements with partners to create buffer zones 
around at-risk testing or training ranges while simultaneously 
protecting natural resources. 

[9] In 2002, DOD Directive 7730.65, Department of Defense Readiness 
Reporting System (DRRS), established the Defense Readiness Reporting 
System to measure and report on the readiness of military forces and 
the supporting infrastructure to meet missions and goals assigned by 
the Secretary of Defense. 

[10] The Readiness and Environmental Protection Initiative provides 
oversight for and helps fund military installations' compatible land 
use partnerships and projects. Readiness and Environmental Protection 
Initiative is an important tool for creating buffer zones around 
military installations. 

[11] Pub. L. No. 107-314 (2002). Section 366 originally required 
reports for fiscal years 2005 through 2008. However, this requirement 
was extended through 2013 by section 348 of the John Warner National 
Defense Authorization Act for Fiscal Year 2007, Pub. L. No. 109-364 
(2006). Additionally, section 1063(c)(2) of Pub. L. No. 110-181 (2008) 
made a clerical amendment to section 348 of Pub. L. No. 109-364. 

[12] DOD's regional partnerships include the Western Regional 
Partnership and the Southeast Regional Partnership for Planning and 
Sustainability. 

[13] Section 366 of the Bob Stump National Defense Authorization Act 
for Fiscal Year 2003 was amended by Pub. L. No. 109-364, § 348 (2006); 
and Pub. L. No. 110-181, § 1063(c)(2) (2008). 

[End of section] 

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