STATEMENT BY
MAJOR
GENERAL R. L. VAN ANTWERP
ASSISTANT CHIEF OF STAFF FOR INSTALLATION
MANAGEMENT
HEADQUARTERS, DEPARTMENT OF THE ARMY
CONSTRAINTS AND CHALLENGES FACING MILITARY
TEST
AND TRAINING RANGES
22
MAY 2001
Mr.
Chairman and members of the Committee:
Thank you for providing the Army with
the opportunity to present our concerns about
what has become known as "Encroachment" to
our training installations, ranges and land. This is a challenging set of issues. We are discussing Encroachment today
because we recognize that societal changes,
demographics, and environmental issues are
impacting the way we train soldiers We recognize the need for, and have
begun implementing, innovative management
approaches to maintain the Army's readiness
and our ability to fulfill our national
security mission. The Army is not seeking to avoid any
responsibilities it has to the people of the
United States. We are not seeking relief from
compliance with environmental statutes. We will continue to fulfill our role as
a responsible environmental steward and do our
best to ensure that our practices do not
endanger the health or well being of any
American.
Our essential training focuses on maneuver and
weapons firing. Maneuver includes ground and aviation
maneuver. Weapons firing includes stationary
firing as well as integration of gunnery and
maneuver skills. To practice and maintain proficiency in
these core skill areas, we require maneuver
land and firing ranges to support a variety of
training from individual small arms to large
caliber crew-served weapons. Our major training installations all
include range complexes that support live
weapons firing, maneuver and maneuver
integrated with live-fire training. The Army must provide challenging,
realistic training scenarios, pushing soldiers
and units to train as we expect them to fight.
We have expended, and continue to expend, a great deal of effort and resources on both our range operations and modernization and on environmental compliance requirements associated with them. In sequestering these areas for training over an extended period of time, they have been protected from development. Military reservations have shielded these lands from other land uses that would have displaced the natural resources now found on those lands even as we have used them to train.
Some have suggested that increased use of simulations can offset our reliance on live weapons firing and maneuver training. While we have made a significant investment in simulations, live experiential training will remain vital due to the extreme rigors and demands of combat. Simulation can complement, but not entirely substitute for real training. It is true that these technologies offer exciting new ways to train some soldier tasks and aspects of military operations; however, these virtual tools themselves cannot integrate nearly all of the stresses of the battlefield simultaneously, as live training can. Thus, while simulation can be viewed as a valuable addition to live weapons firing and maneuver, it is not yet viable as a full replacement. To rely solely on simulations would be an abrogation of the Army's duties both to its soldiers and units, as well as to the Nation.
We carry out our training to ensure the combat readiness of our force. That readiness is critical to our ability to perform the missions assigned to us and to do so with a minimum of casualties, property destruction, and resource expenditure. We have learned hard lessons from the past when other priorities overshadowed our need to train young Americans for the uncompromising conditions and challenges of war.
As the Army continues its Transformation, we are mindful of the changing world and the imperative for the Army to remain a viable and effective part of the Defense team. This role requires that the Army maintain its focus on combat readiness despite many competing interests.
MISSION NEEDS -
WHY LIVE TRAINING AND TESTING IS IMPORTANT TO READINESS
The primary mission of the Army is to fight and win in armed conflict. Training soldiers, leaders, and units is the vital activity that ensures the readiness of the Army to accomplish this mission. To be effective, training must provide soldiers the opportunities to practice their skills in combat-like conditions. These conditions must be realistic, as well as physically and mentally challenging. The Army's training ranges, as well as those of our sister services, provide training opportunities to develop and improve a soldier's proficiency, competence, and confidence in the use of sophisticated weapons systems. The fact that the Army's mission increasingly includes peacekeeping operations does not reduce the need for combat training. In fact, "policing" requires soldiers to be highly proficient with pinpoint target identification and engagement procedures. This can only be accomplished by practicing with the actual weapon in specifically designed training exercises on our ranges and training areas dedicated to that purpose. Specialized peacekeeping training, however, cannot replace the basic emphasis on combat skills. Overwhelming evidence from the Army's Combat Training Centers proves that the teambuilding and weapons discipline skills developed for the Army's war-fighting role are critical to success during operations other than war. The bottom line is that today's missions require at least as much live training as did past missions.
The amount of live-fire training in the Army cannot be reduced without serious degradation to readiness and the concurrent increased risk to American soldiers. The amount of live-fire training that individual soldiers and units are required to complete is based on the common sense premise that certain skills are perishable and must be periodically exercised. In other words, to be effective with a certain weapon system, the soldier must shoot a certain number of times. The Army has established standards that identify the minimum number of times and specific firing events that a soldier must train to achieve a given level of proficiency. The Army currently has difficulty meeting these minimum standards because of limited facilities, funding, and time. Many ranges operate at maximum capacity so that units can meet the minimum standards. Any further limitation on these training facilities would inevitably cause a reduction in live-fire training below that needed by soldiers to remain minimally proficient.
Live training is critical to assessing the effectiveness and capability of not only the people but also the actual equipment that the Army depends on. The only way to ensure that a piece of equipment will be ready for battle is to put it through rigorous use beforehand. Weapons systems and vehicles, like the soldiers who count on them, must be tested and refined over and over to ensure quality and dependability.
ENCROACHMENT
The Army has used a variety of weapons on its ranges for well over 100 years under conditions not contemplated by our current environmental statutes. A number of these statutes contain broad, discretionary enforcement thresholds that are based on the assessment of the environmental regulatory authority as to whether a given condition or activity presents a "potential" risk or "imminent" hazard to human health or natural resources. The results of these assessments are, in many cases, added restrictions on the flexibility of the Army trainer. The Nation's environmental consciousness increased tremendously in the closing decades of the twentieth century, resulting in a multiplicity of environmental statutes and requirements.
Most of the Army's major training installations were established during the World Wars, and they were then both remote and isolated from population centers. However, since then, many installations have experienced considerable urban growth around their boundaries and are now often in the midst of large urban areas. As the Army prepares for its mission by training and testing, we create noise, dust, and ground disturbances that can be viewed as a nuisance to those who have become our neighbors.
The public perceives a reduced national security threat since the fall of the Soviet Union, which further reduces the perception of the value of live-fire testing and training activities. In fact, the rate of Army deployments is at an all time high. More soldiers are consistently deployed (including the Army National Guard and the Army Reserve) to more locations, more frequently, than ever before. At the same time, the Army's weapons systems and war fighting doctrine have increased the demand for training and testing ranges. For the individual soldier, the threat of personal harm becomes high when conditions change and what may have begun as a humanitarian mission, escalates to combat. At that point, there is no time for training.
The cumulative and aggregate effects from factors such as environmental regulation and urbanization, with accompanying noise, transportation and air quality issues , among others, have recently come to the forefront for DOD and Army leadership as a serious threat to future training and testing of our armed forces because of restrictions and limitations imposed by them. If not addressed quickly, and on a national basis, these threats to training may result in degradations to readiness. DOD calls this result "Encroachment." The effects of these Encroachment factors can be intensified by well-organized interest groups committed to broad environmental goals or specific issues. As the Army strives to reconcile its testing and training mission and its stewardship duties, we are pushing already severely constrained resources to the breaking point.
There are eight major Encroachment issues, plus an additional category of Outreach, identified by the Senior Readiness Oversight Council (SROC). They are: Airborne Noise, Unexploded Ordnance (UXO) and Munitions Constituents, Urban Sprawl, Endangered Species , Maritime Sustainability, Frequency Spectrum, Air Quality, and Air Space.
The Under Secretary and Chief of Staff of the Army are members of the SROC, which meets twice a year. The Director of Training and the Director of Testing are members of the Defense Testing & Training Steering Committee (DTTSG), the main committee supporting the SROC's Encroachment review. The DTTSG meets quarterly. In addition, there are nine Senior Readiness Work Groups (SRWGs), one for each of the Encroachment issues, plus Outreach, which meet on an as-needed basis. There are action officer level personnel on each of the SRWGs.
The Army's primary Encroachment concerns are urban sprawl, threatened and endangered species, and restrictions that impact our use of munitions. The Army's interests and concerns in other SROC Encroachment areas such as airborne noise and air quality are articulated in the oral and written testimony of our sister Services. We will elaborate more fully on the Encroachment issues of most concern to us, and articulate what Army is doing to address them, on the following pages.
URBAN SPRAWL
Urban sprawl, which is defined as unchecked residential and community growth, may present conflicts with our neighbors over noise, dust, and other effects of Army training. In some areas, it also triggers a competition for natural resources. When our installations were established, they generally were in rural areas, remote and isolated from populations. That has changed. The sum effect has been that Army installations, once far from public view, are now often in the midst of large urban areas.
The Army has seen significant urban growth around several major training facilities. There have been dramatic increases in population in close proximity to Fort Carson, CO; Fort Lewis, WA; Fort Hood, TX; Fort Benning, GA; Fort Bragg, NC; Fort Huachuca, AZ; and Camp Bullis, TX. For installations located in arid climates such as Fort Huachuca, growth in nearby communities has resulted in increased competition for water. Urban growth often exacerbates the effects of other Encroachment issues such as noise. The Army is aware of noise sensitivities in communities surrounding Fort Drum, NY; Fort Sill, OK; Fort Bragg, NC; Fort Carson, CO; Fort Campbell, KY; Fort Hood, TX; Fort Lewis, WA; Fort Riley, KS; Fort Stewart, GA; and Fort AP Hill, VA. There is a particular challenge in managing noise issues related to the Aviation School and its extended flight training areas over and around Fort Rucker, AL. As populations around these and other installations continue to grow, the Army expects other Encroachment concerns to intensify.
THREATENED & ENDANGERED SPECIES (T&ES) AND HABITAT
As we focus our training missions and Transformation on specific installations, we find that endangered species restrictions already limit the use of a significant portion of the landscape. Army lands host 153 Federally listed species on 94 installations, and 12 installations have lands designated as critical habitat (four of these habitats are as yet unoccupied by the species for which designated). As the habitat surrounding our installations is degraded by development, pressure to designate Army training ranges and maneuver areas as critical habitat for listed species increases. When critical habitat is designated, we are required to consult with the relevant regulatory agency, for example, U.S. Fish & Wildlife Service, whenever any of our actions on those ranges or areas may result in the destruction or adverse modification of critical habitat. By regulation, this consultation process can take as long as 195 days. Let me offer a few examples of challenges we face with regard to T&ES management.
The Red-Cockaded Woodpecker in the Southeast U.S. affects four major training installations (Forts Bragg, NC; Stewart, GA; Benning, GA; Polk, LA) and two major service school training bases (Forts Jackson, SC; and Gordon, GA). This species has benefited from the havens provided by our installations' training land and ranges, that have been insulated from urbanization and forestry practices in the region. The Army has committed resources to help the recovery of the species, while some developers have not made similar commitments. Restrictions on training as a result of Encroachment include limitations within 200 feet of cavity trees, including prohibition on use camouflage netting, artillery firing, and incendiary devices.
The many listed plants in Hawaii and the complexities of complying with the ESA prevented the use of a valuable multi-purpose range complex (MPRC) at the Army's Pohakuloa Training Area (PTA) on the island of Hawaii, built at a cost of $25 million in 1988. Although some training activities occur at PTA, the MPRC is not being used for the integrated maneuver, direct fire, indirect fire, and aerial gunnery and bombing for which it was designed and built.. We have also voluntarily closed our only large caliber firing range on Oahu - Makua Valley - while we complete our analysis under the National Environmental Policy Act, review cultural resources, and evaluate Endangered Species Act (ESA) management plans and agreements.
As the Nation's environmental consciousness increased in recent decades, so too has the Army's. We have undertaken a number of programs to uphold our environmental stewardship responsibilities. While ours has largely been a good news story regarding endangered species, some of the steps we have taken in consultation with the U.S. Fish and Wildlife Service (FWS) have restricted training. Fort Hood contains nearly 185,000 acres of ranges and training areas. Practices designed to support the goals of the Clean Water Act (CWA), the ESA and protection of cultural resources prohibit digging on approximately 128,000 acres (64%) of training land. This means no digging for vehicle fighting positions, survivability positions, maneuver obstacles, or individual fighting positions, all of which are required to meet doctrinal training standards for many units on Fort Hood. The FWS biological opinion, issued under the ESA for both the Golden Cheeked Warbler and the Black Capped Vireo, restricts training on over 66,000 acres (33%) of training land. While technically the restrictions found in this biological opinion are recommendations, in practice the Army never disregards these opinions. These restrictions include no digging, no tree or bush cutting, and no "habitat destruction" throughout the year on the entire core and non-core area. During March through August, vehicle and dismounted maneuver training is restricted to established trails, and halts in restricted areas are limited to two hours in designated endangered species "core areas" (46,620 acres of the 66,000 acres are designated "core areas."). Artillery firing, smoke generation, and chemical (riot control) grenades are prohibited within 100 meters of the boundaries of the designated "core areas." Use of camouflage netting and bivouac are prohibited across the entire "core area" during these months.
Fort Hood's training areas contain over 2219 (1,100 have been surveyed) archeological and culturally significant sites where digging is prohibited. To comply with the Clean Air Act and to promote safety, there is no smoke, flare, chemical grenade, or pyrotechnic use allowed on over 46,000 acres (23%) of training land. Due to noise restrictions, there is no Multiple Launch Rocket System or artillery fire allowed on over 1000 acres of land. These restrictions include only those driven by well-established and broadly applied environmental requirements. While some of these restrictions overlap on the same training areas, only about 17% of Fort Hood training lands are available for training without restriction.
Managing endangered species in accordance with existing regulations has been, and continues to be, a great challenge. Over the last three years, the Army has spent approximately $40 million in total on managing T&ES. As a land-based force, we need land to train. Our major training installations are large and must accommodate air and ground maneuver using our increasingly mobile weapon systems. Endangered species regulations have required us to review our training activities to ensure that they do not jeopardize the continued existence of T&ES. In some cases, we must modify our training activities to meet that requirement. Most often, this takes the form of a restriction on our already limited training land. In other cases, we've had to relocate the training entirely. Nationally, as additional species are listed and critical habitat for listed species increases, the amount of land available to us for unmodified training activities may decrease further.
UNEXPLODED ORDNANCE (UXO) AND MUNITIONS CONSTITUENTS
When military munitions do not function as intended, or fully detonate, they create unexploded ordnance (UXO). Many challenges arise if and when UXO is found on land intended for something other than military testing or training. Land no longer used for military testing and training includes former ranges being transferred to the public under the Base Realignment and Closure (BRAC) program, and ranges previously transferred out of military control and now being addressed under the Formerly Used Defense Sites (FUDS), and closed ranges on active installations. When found on active, inactive and closed military ranges, UXO poses fewer explosives safety hazards to the public, since the Army still controls these lands and restricts access to the public.
Currently there is no precise estimate of what it will cost to address UXO and munitions constituents. The Army's FY00 Financial Statement shows a $13 billion contingent liability for remediation of UXO and munitions constituents at closed, transferred and transferring ranges. Of the $13 billion, $5 billion is for closed and transferring ranges.
When military munitions function as intended, trace quantities of munitions constituents may be released into the air, soil, and surface and ground water at the firing point and in the impact area of the range. These munitions constituents can pose an environmental challenge if present in large enough quantities, and if the environmental laws and regulations applicable at that location restrict the particular constituents being emitted. Range impact areas also become littered with metal scrap from the exploded munitions items.
The use of environmental statutes, such as the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Resource Conservation & Recovery Act (RCRA), CWA, and the Safe Drinking Water Act (SDWA), to require investigation and cleanup of UXO and munitions constituents on active ranges could impact the Army's ability to fulfill its national security mission by causing the shut down or disruption of live-fire training. Regulators may themselves be vulnerable to enforcement by private citizens through lawsuits alleging failure to vigorously apply these and other environmental laws.
Our concerns about munitions focus on the future of live-fire training. In 1997, EPA Region I issued an Administrative Order (AO) under the Safe Drinking Water Act prohibiting the use of lead ammunition, propellants, explosives, and demolition materials at MMR. This Order was issued to prevent possible impacts to an EPA-designated sole source aquifer. This discretionary action essentially shut down live-fire training at MMR except for use of plastic, frangible, and green ammunition. Given the fact that our units employ a large number and type of weapons, and that we train with those weapons on literally thousands of ranges, the potential for cessation of live-fire training is of great concern to us.
The regulation of munitions is a complex issue that requires deliberate measures in the areas of environmental research and development, risk assessment, range design, and range management. Unilateral orders to stop firing while we investigate these challenging issues may impact readiness. A balanced approach is warranted. Such an approach should ensure that national security concerns, as well as environmental stewardship interests, are weighed by policy makers whose interests and perspectives are broad. While most environmental laws provide for Presidential exemptions and 10 U.S.C. Section 2014 allows for elevation of disputes between Executive Branch agencies where an administrative action affects training or a readiness activity in a manner that has or would have a significant adverse effect on military readiness, these extraordinary measures have been rarely invoked. We will work with Congress and the Administration to reduce uncertainty and increase flexibility in laws and regulations so as to strike the right balance of national security and the environment.
THE ARMY'S ACTIONS IN RESPONSE TO ENCROACHMENT
Our initial approach to Encroachment contains three key elements. First, we will respond to concerns at our closed, transferring and transferred ranges (Formerly Used Defense Sites (FUDS)) as DOD's Executive Agent, and perform the required response actions necessary to protect public health and the environment. Second, we will introduce a more sophisticated, integrated approach to range management that we call Sustainable Range Management. This approach will allow us to better manage our lands and maximize their use for military purposes. And third, after appropriate review and discussion with affected parties, we may seek legislative clarification to achieve reasonable application of statutes as they apply to active ranges and live training. We are working closely with the regulatory community.
PROGRAM OF RESPONSE AT CLOSED, TRANSFERRED, AND TRANSFERRING RANGES
The Army was the DOD lead agent for development of the Range Rule. Unfortunately, we were not able to come to agreement within the Administration, and in November 2000, DOD withdrew the rule. The objective of the Range Rule was to establish a uniform process that integrated environmental and explosives safety decision-making for munitions response activities at closed, transferred, and transferring ranges. Although the Administration has not addressed this issue, the Army and DOD believe that explosives safety decision-making must be the primary consideration in any program addressing risks at former military ranges, and that DOD should have the authority and responsibility for that decision. Because we believe that our field personnel still need consistent guidance, DOD is developing an internal DOD directive and instruction that integrates our explosives safety and environmental responsibilities. At the appropriate time, if the new Administration decides to pursue promulgation of a new range rule, DOD will use the directive and the instruction as the basis for negotiations with the many stakeholders over the new range rule.
In the interim, Army is implementing munitions response at BRAC and FUDS sites. The Army is DOD's executive agent for the FUDS program.
SUSTAINABLE RANGE MANAGEMENT
The creation of a Sustainable Range Management (SRM) Program to integrate environmental compliance and stewardship, facilities management, explosives safety, and training management on ranges and training land is our primary initiative to meet the challenges of Encroachment.
The Army is improving the way in which it designs, manages, and uses its ranges. This effort is helping the Army maximize the capability, availability, and accessibility of its ranges and training land to meet doctrinal training requirements needed to support its Title 10 mission and ensure a trained and ready force.
The Army's SRM effort is based upon three tenets: (1) Information Collection: establishing a scientifically defensible database that will ensure that the Army has the most current and best information related to the operational and environmental characteristics of its ranges; (2) Integrated Management: ensuring that the major management functions that directly affect ranges, operations/training, facilities management, explosives safety, and environmental management, are integrated to support the training mission; and (3) Outreach: articulating the Army's requirement for live-fire training to support national security and improving our understanding of the public's concern over the potential impacts of the live-fire training. The Army's current SRM effort is broad and complex, and has as its basis the development of a comprehensive SRM plan that we believe will ensure our ability to maintain and sustain our ranges and training lands well into the twenty-first century.
The Army has just completed the first phase of the plan, which identifies shortfalls (gaps) in current functions, policies, and procedures that could impede implementation of SRM across all levels of the Army, from Headquarters, Department of the Army (HQDA), down to the over 400 installations with range assets. Doctrinally-based core range requirements; those related to requirements for modernization of range facilities; services to support range operations; and maintenance requirements were analyzed against Encroachment factors to gauge our vulnerability to external effects that will preclude our ability to support mission training requirements on our ranges. Based on that analysis, the Army has developed goals and objectives for SRM and is currently drafting measures of merit for monitoring their effectiveness upon implementation. These goals and objectives for SRM build upon our doctrinally based core range requirements and integrate them with mechanisms to minimize Encroachment and the impacts of Encroachment, reduce environmental liability through sound environmental stewardship and compliance, and provide outreach to the public. The goals and objectives form the basis for our comprehensive SRM plan, which will evolve into a new Army training regulation.
As part of this effort, the Army is developing policies and procedures to correct the shortfalls identified during our initial analysis. We are developing integrated management strategies at the HQDA, Major Army Command, and installation levels to cut across functional lines in order to support the live-fire training mission and ensure our range capability into the future. Because Army ranges are a combination of training infrastructure, real property assets, and environmental resources, the integration of those management functions is vital to the success of this approach. To oversee this integrated approach and the comprehensive SRM plan, the Army created the Army Range Sustainment Integration Council (ARSIC) in June 2000. The ARSIC is a HQDA level Council of Colonels that acts as an integrated process team to support SRM by developing recommendations for integrated policy, positions, and action plans.
The Army's ability to implement SRM depends not only on its ability to meld the various management programs; i.e., training, facilities, explosives safety, and environment into a cohesive whole, but also on its ability to maintain accurate and up-to-date information and data related to the operational and environmental characteristics of our ranges, as well as the impact of munitions use on the environment. As part of this effort, HQDA has initiated a worldwide inventory of its active and inactive ranges. This inventory will provide a "ground-truth" baseline of the Army's extensive range infrastructure and provide the foundation for the comprehensive plan
The Army's Environmental Program has generally focused on the cantonment areas of our installations, with the exception of our Conservation Program. However, many installations are becoming aware of how environmental compliance requirements other than Conservation apply to ranges and have initiated monitoring programs where appropriate. Thus, the Army is undertaking an initiative, in support of SRM, to ensure a formal and logical basis for environmental planning and compliance on ranges. This initiative costs approximately $500,000 per year. Range environmental compliance will be funded from environmental compliance or conservations funds. Sustainable Range Management will rely on the effective integration of lessons learned and varied environmental compliance programs and practices currently in place within the Army.
HOW CONGRESS CAN HELP THE ARMY WITH THE RANGE ENCROACHMENT ISSUE
SUPPORT AND RESOURCE IMPLEMENTATION OF THE ARMY'S SUSTAINABLE RANGE MANAGEMENT PROGRAM.
Sustainable Range Management is the foundation for sustaining live training and the environment on our ranges. As we have in the past, we will continue to improve range operations, range modernization, state of the art land management, research on munitions effects and UXO management, and public outreach. Although final funding levels have not yet been established, we ask Congress to support this important program.
SUPPORT AND FOSTER COOPERATION AMONG REGULATORS AND THE MILITARY, IN WAYS THAT EMPHASIZE THE NEED TO BALANCE MILITARY READINESS CONCERNS AND ENVIRONMENTAL REGULATION.
The Army believes that Congress should continue to recognize that the training that results in the Army's readiness for combat is a positive societal good and a legal mandate. Defense of our nation is an important requirement that benefits all citizens. I believe there are ways to balance the needs of the military with the needs of the environment. Just as our Nation needs a well-trained military force, it also needs a healthy environment. In light of the Secretary's current strategic review, it would be premature to discuss specific proposals, but I look forward to working with other Federal agencies and Congress.
CLOSING
Mr. Chairman and members of the Committee:
Thank you for affording me the opportunity to testify before you today concerning an issue of great importance to the Army's future.
2120 Rayburn House Office Building
Washington, D.C. 20515
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