Range Report

[Lenny Siegel <lsiegel@cpeo.org>]

===========================================================
Need to find the right school to fit your needs
CollegeInformation.info has already found it. Get educated
on your future ? degrees, financial aid and more!
http://click.topica.com/caab6afaVxieSa8wsBba/ College Info
===========================================================


In February, 2004, the Under Secretary of Defense (Personnel and
Readiness) submitted a report to Congress: "Implementation of the
Department of Defense [DoD or DOD] Training Range Comprehensive Plan:
Ensuring Training Ranges Support Training Requirements." The report
provides a general description of the military training and testing
ranges, and it explains how they are managed by the armed services. The
appendices provide lists of military ranges and their functions. But for
those on either side of the debate over the Pentagon's Readiness and
Ranges Preservation Initiative, it provides no new ammunition.

Once DOD makes the document available on the Web, we will post the link.

The report reports the fundamental challenge of "encroachment":

"Today, the Department faces a paradox when it comes to the air, land,
water, and electromagnetic spectrum required to support realistic
training. On one hand, our platforms, weapons, and systems are growing
ever more capable, which, when combined with the attendant advancements
in doctrine and tactics, create requirements for more training space.
Aircraft and vehicles travel farther and faster. Sensors detect at
longer distances. Platforms deliver weapons accurately at greater
distances. Unmanned vehicles provide invaluable intelligence.
Communications systems carry more data to provide unprecedented
intelligence and enable extensive coordination. These changes have
brought about not only an overall increase in our military capabilities,
but also a vast increase in the size of the battlespace within which we
operate, and, therefore, within which we must train.

"On the other hand, encroachment reduces the size of the area that is
available for military training ? sometimes markedly so. Urban and
regional development have brought communities near or next to once
remote installation boundaries, bringing residents with concerns about
noise and safety, and forcing species, endangered and otherwise, to seek
refuge in the only natural terrain available nearby ? the very terrain
that military forces need for realistic training. Environmental
regulations limit training across the spectrum of military activities,
from amphibious assaults to anti-submarine warfare, from maneuver on
land to low level flight. Commercial air traffic competes for the SUA
needed for military training. Developers want to build new communities
below airspace used historically for military training. A host of new
commercial communications products compete for portions of the
electromagnetic spectrum currently or formerly used by the military.

"In short, our requirements for training space  are increasing, but the
air, land, water, and spectrum resources we need to conduct training are
shrinking." (p. 10/p. 14 PDF)

The report summarizes the Defense Department view of the negative
impacts of environmental regulations on readiness in the following three paragraphs.

"3.3.2. UXO and Munitions
Ranges and training areas are critical to DoD's ability to conduct
realistic, live-fire training and weapon systems testing. Live-fire is,
and will remain, the cornerstone of Service training and testing.
Military live-fire training and testing activities by necessity deposit
unexploded ordnance (UXO) and munitions constituents onto military
lands. CERCLA [Comprehensive Environmental Response, Compensation, and
Liability Act, or Superfund law], RCRA [Resource Conservation and
Recovery Act], the Clean Water Act (CWA), and the Safe Drinking Water
Act have implications for the use of military munitions, to include UXO
and munitions constituents on operational ranges. There is a growing
recognition that the application of these environmental laws in ways
unanticipated or unintended when first enacted can reduce range access,
availability, capacity, and capability. Restrictions on training and
testing can increase the extent to which military readiness is
compromised. Furthermore, uncertain application and inconsistent
enforcement of legislation and regulation limit DoD's ability to plan,
program, and budget for UXO and munitions compliance.

"3.3.6. Air Quality
Readiness limitations can arise due to application of the Clean Air Act
(CAA) to emissions generated on military installation and ranges. The
two most common concerns are opacity rules and air conformity
requirements. Opacity rules can restrict or prohibit some training and
testing activities such as smoke and mounted maneuver training and can
limit prescribed fires to manage vegetation. Opacity is a sensitive
issue with the public, especially near parks and designated wilderness
areas. Further, the 'general conformity' requirements of the Clean Air
Act, applicable only to federal agencies, threatens the Department's
ability to deploy new weapons systems and relocate existing ones,
despite the fact that only minor levels of emissions are involved.
Therefore, opacity and conformity standards may restrict certain
training and testing operations, as well as re-stationing or deploying
new weapons systems in non-attainment areas.

"3.3.10. Clean Water
Water quality is an environmentally sensitive issue for all stakeholders
on and near military training and testing ranges. The CWA, the
legislation that regulates discharges of pollutants into the waters of
the United States, gives the Environmental Protection Agency (EPA) the
authority to implement pollution control programs such as setting
wastewater and water quality standards. Private litigants have alleged
the CWA applies to military lands where munitions constituents released
during the course of testing and training may discharge into water
sources. If these litigants prevail on this theory, the act of using
munitions during the course of testing and training on operational
ranges could be subject to CWA permitting requirements and, depending on
the regulatory controls imposed, could significantly interfere with
training and testing." (pp. 32-35/pp. 36-39 PDF)

***

The statement on UXO and munitions describes those laws that DOD seeks
partial exemptions from - RCRA and CERCLA - in the same breath as the
Safe Drinking Water Act (SDWA). EPA has ordered the National Guard to
stop training with high explosives at the Massachusetts Military
Reservation, invoking SDWA, but DOD doesn't propose to change that law.
Instead, it has reportedly received White House clearance to submit once
again proposed changes to RCRA and CERCLA - which have not impeded and
do not interfere with readiness. The report offers no evidence in
support of this paragraph or the proposed language.

I also find it disingenuous that the Defense Department is complaining
about the "uncertain application and inconsistent enforcement of
legislation and regulation." Regulatory requirements are uneven because
the military consistently tries to escape them, sometimes with success.
It would be more reasonable to warn that cleanup up the mess on
munitions ranges would cost a lot of money.

Nor is the argument on Clean Air backed with concrete information. The
Defense Department wants to deploy new weapons systems - such as
aircraft - and relocate existing systems without considering their
impact on air quality. The issue isn't really whether such systems can
be fielded, but where. I have never heard the Department explain why
protecting our air shouldn't be a consideration in deciding where to
locate polluting planes and other vehicles.

Perhaps the most interesting data on readiness lies in the last appendix
(#K), a summary of the Marine Corps' Commanding Officers Readiness
Reporting System results. For each of 15 major Marine installations,
commanding officers have rated both the Quality and Quantity of five
types of facilities. It appears to be a fairly objective evaluation of
each facility, not designed to promote legislative changes.
Unfortunately the summary doesn't list the particular deficiencies or
reasons for them.

With C1 "readiest" and C4 worst, the combined evaluation of Marine Corps
facilities is

                                          Quality          Quantity

Training Buildings                C3                     C1
Simulation Facilities              C2                     C1
Training Support Facilities    C3                     C2
Training Ranges                    C3                     C1
Training Facilities Other        C2                     C1
  Than Buildings

Clearly, factors other than encroachment are contributing to reported
readiness deficiencies, since the Commanders reported degraded readiness
in all categories.

Furthermore, one foreign range - Iwakuni, Japan - is included among the
15. Even though U.S. environmental laws generally do not apply there, it
reported Range Quality of C3, the same level reported by five domestic installations.


Lenny
--


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org

===========================================================
Your opinion counts! We're conducting a survey for a
computer service/repair company. When you complete our
survey, you will also be entered into a drawing for one of
ten $100 prizes. Just click
http://click.topica.com/caab6PiaVxieSa8wsBbf/ Val Rad
===========================================================
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
CPEO: A DECADE OF SUCCESS.  Your generous support will ensure that our
important work on military and environmental issues will continue.
Please consider one of our donation options.  Thank you.
http://www.groundspring.org/donate/index.cfm?ID=2086-0|721-0