	Background

DOD’s operations at military installations and other defense sites in  the United States are subject to the same environmental laws and  regulations, such as the Clean Air Act and the Clean Water Act, as is  private industry. 1.) The installations are responsible for identifying all regulations and  other environmental requirements that apply to them, and identifying  and tracking pending requirements. DOD’s and the Services’ Policies and Processes Do Not Always Ensure That the Most Important and Appropriate Environmental Quality Activities Are Funded

Based on broad DOD policy, each military service has established its own  policy and processes to implement the environmental quality program. The Services’ Varying Interpretations of DOD’s Broad Policy Have Resulted in Inconsistent Eligibility Criteria and Funding of Activities More Closely Related to Military Operations or Maintenance

DOD’s policy provides the services with a broad charge to comply with  applicable environmental requirements, such as statutes and regulations,  but leaves to the services most decisions about which activities are  appropriate for funding through their environmental quality programs. The Services’ Policies Differ in Which Activities Are Eligible for Their Environmental Quality Programs

Although the services have developed policies intended, in part, to clarify  which activities can be funded through the environmental quality program,  implementation of these policies has sometimes led to inconsistencies  across the services in the types of activities they determine eligible for  funding. In fiscal year 2002, for example, the  Navy’s environmental quality program spent $17.8 million to comply with  NEPA requirements. Oil and hazardous material spills. It is unclear why this activity is treated differently from the case of  hazardous spills discussed previously, in which the Navy requires the  organization that caused the spill to pay for the cleanup. The Services Do Not Always Ensure That Funding Is Targeted to the Highest Priority Environmental Activities, and in Some Cases, Have Funded Activities That Are Ineligible Under Their Policies

Certain low-priority activities were funded through the environmental  quality program at two Army installations we visited, even though some  high priorities, considered “must fund” activities by DOD and Army policy,  were not funded. Specifically, we found  the following:    Pest management. Landscaping for a hazardous waste storage facility. Restoration and maintenance of a historic structure. The Services’ Environmental Quality Programs Cannot Ensure That DOD’s Requirement to Fund All High-Priority Needs Is Met

Although DOD’s and the services’ policies call for funding of all  high-priority environmental quality program activities, the services  have not always been able to fund all such activities through their  environmental quality program. According to some environmental managers at the installations where  high-priority activities were deferred, the activities they were most likely  to defer were those that do not have a firm timeline for completion, such  as surveys of cultural resources. Environmental program managers at most of the installations we  visited indicated that they have generally been able to fund emergency,  high-priority environmental activities that occurred outside the normal  budgeting cycle, but they have done so by using funds allocated for other  planned high-priority activities, emergency or year-end funding from the  environmental quality program, or other funding sources at the installation  or command. This  variation among the services’ programs can result in different eligibility  requirements for environmental activities across services and funding of  activities that would be more appropriately funded from other sources,  such as military operations or base maintenance. Although the services have, over the past decade, made significant  improvements in their environmental compliance performance, these  improvements have leveled off in recent years, and DOD has not reached  its goal of full environmental compliance.
Why GAO Did This Study

The Department of Defense (DOD) and its military services are responsible for complying with a broad range of environmental laws and other requirements that apply to the lands they manage, including more than 425 major military installations covering about 25 million acres across the United States. Through its environmental quality program, DOD spends about $2 billion per year to comply with these requirements. Although the services have made significant improvements in environmental management in recent years, DOD has not reached full environmental compliance. In response to the Senate Armed Services Committee's report on the National Defense Authorization Act for Fiscal Year 2002, we assessed how DOD and the services identify, prioritize, and fund their environmental quality activities to determine whether the most important and appropriate activities are funded.

What GAO Found

DOD's and the services' policies and processes for the environmental quality program do not always ensure that program funds are targeted to the most important and appropriate environmental activities. Instead, GAO found that some installations have funded low-priority or other activities that were ineligible under their environmental quality funding policies, at the same time that higher-priority activities were not funded. For example, at certain large installations that GAO visited, low-priority activities, such as noise monitoring, or ineligible activities, such as pest management, landscaping, and roof replacement, were funded while high-priority activities to prevent soil erosion were not. At the root of the problem is DOD's broad program policy that does not provide specific guidance on what activities are eligible for the program and the resulting inconsistent interpretation and implementation of this policy by the military services. DOD's policy requires that all high-priority activities be funded, but gives the services broad discretion in how this policy is put into place. As a result, GAO found (1) inconsistencies across and within the services about which activities are eligible for environmental quality program funding and (2) the funding of some activities through the program that more closely relate to military operations or base maintenance. For example, some services use program funds for oil and hazardous material spill response plans, equipment, and cleanup costs, while other services require the organization responsible for the spill to pay for the cleanup portion of those costs. Similarly, service policies can differ regarding responsibility for funding maintenance of structures such as water and sewer treatment facilities and historic buildings. Without a consistently implemented approach, there is no assurance that DOD's requirement to fund all high-priority activities is being met. Instead, some high-priority projects are being deferred. Generally, these deferrals involve projects that, although required by law, do not have to be completed by specific dates (e.g., surveys of properties required by historic preservation law). Deferring such activities, however, can lead to larger and more costly problems later. Moreover, to fund unbudgeted emergency environmental activities, the installations may have to defer other high-priority environmental program activities, obtain funds from other sources at the installation such as maintenance activities, or obtain funds from higher command levels. Some services have recently indicated that the availability of funds for environmental activities is likely to get worse in future years, because of expected reductions in their budgets for this program. Such constraints make a well-implemented prioritization process even more important.