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Seven Ways to Improve DoD's Environmental Security Program
Executive summary of Office of the Undersecretary of Defense for Acquisition and Technology, , Monday, May 22, 1995

The Department of Defense is the largest customer for goods in the United States, one of the largest land managers and a major operator of facilities and bases. Therefore, DoD's policies can have a substantial impact, both positive and negative, on the environment throughout the country.

The department's major mission is to protect the nation and its interests throughout the world. Meeting environmental requirements is an important, but corollary obligation similar in nature to the environmental management role in industrial operations, whose major mission is to produce goods and services.

This Defense Science Board Task Force is concerned about both the rising costs and the barriers to readiness, exemplified by restrictions on training and vessel mobility, caused by environmental requirements. Since a primary requirement for any society must be to defend itself, the task force needed to determine what strategy would best suit this objective, while meeting other national priorities, such as environmental quality.

The task force concluded that the department must not only meet its legally required responsibilities, but because of its size and importance should also provide leadership in certain environmental areas that directly impact the DoD. By doing so, the task force believes that the DoD can strengthen its defense mission over the long term.

Almost all premier private sector firms are providing environmental leadership. They are finding opportunities for cost savings through prudent environmental management, technology investments and pollution prevention. They are also involving local and state stakeholders in their decisions.

This proactive management approach is not pursued for altruistic reasons. The management of these companies are convinced that they can reduce environmental costs in the long run, have greater flexibility in their operations and, hence, gain competitive advantages through such an approach.

The task force believes that the department faces a similar set of decisions. If the DoD takes a proactive, leadership position working with stakeholders, pursuing new technology and pollution prevention, leveraging its buying power and pursuing the most significant risks first it will be in a much stronger position to assure U.S. national security interests.

Public support in the communities in which the department operates will be key to preserving operational flexibility. Moreover, there is little doubt that the DoD will ultimately need to meet environmental requirements. The task force believes that it will be cheaper in the long run to meet its requirements in a proactive fashion than to be forced to do so through protracted regulatory proceedings at the state and local levels.

In recent years, the department's investment in environmental security has been sizable: a direct annual investment of over $5 billion and about $2 billion of additional defense industry costs absorbed annually. Even at this level of investment, it is difficult to satisfy all local, state and federal regulatory requirements in a timely fashion.

DoD now faces an increasing requirement for environmental dollars, particularly in the cleanup area. It is just now shifting from study to cleanup, and this shift will further raise costs. Additionally, BRAC-95 [base realignment and closure] funds have not yet been included in the DoD budgetary plans.

A recent Congressional Budget Office report states that: "DoD will probably need additional funds beyond those in the current budget plan to continue to meet the program's objectives ... legislative relief may be required..." (January 1995). The recent congressional FY [fiscal year] 95 recisions only compound the problem, Thus, at a minimum, the DoD needs a rational way to set priorities.

The demand for more resources is coupled with projections of shrinking environmental budgets. The task force has identified several initiatives aimed at achieving the DoD environmental needs at lower costs. Specifically:

 

  • Comparative risk reduction prioritization of investments;
  • A focus on implementation of pollution prevention actions;
  • More rapid validation and deployment of new commercial technology for DoD use;
  • Investment in early development and deployment of emerging technology aimed at defense-unique requirements;
  • Greater efficiency and effectiveness of environmental management (do more with less funding);
  • Adjustments in environmental legislation (e.g., regarding land-use, timing, etc.) consistent with risk reduction priorities;
  • Stability of funding (for the next five years at $5B[illion]/year).

DoD is one of the largest landowners in the United States (more than 25 million acres). With overseas areas increasingly restricted and with longer-range weapons needs, the requirement for domestic air, land and water for training, testing and operations is growing. At the same time, conservation demands are increasingly restricting DoD's domestic land, air and water activities.

Specifically, with regard to the impact of environmental concerns and regulation on military readiness, the task force found a large number of examples of potential readiness impacts. For example:

 

  • Limitations imposed on Air Force use of ranges (test and training);
  • Constrained naval operations caused by differing oil discharge standards in U.S. waters (harbors, rivers and coastal regions);
  • Constraints on use of military aircraft and ground support vehicles (e.g., California air quality standards);
  • Reduction of Navy's ability to use sonar devices in tests and exercises because of the potential adverse effect on marine mammals;
  • Limitations on Army armored vehicle maneuvers on training ranges that are habitats of threatened or endangered species (e.g., desert tortoises);
  • Tightening advanced ship solid waste discharge standards (national and international) impacting naval operations.

The task force believes that a proactive DoD approach to future conservation issues is required today. If DoD is perceived as a good steward of the lands, especially at the local level, it will likely retain greater flexibility for its operations and training.

In summary, environmental security is clearly growing as a DoD issue area, and initial steps have been taken in the right direction. However, the task force finds a lack of a DoD-wide system for setting priorities and for confronting the issues head-on. Without change, DoD will not be capable of addressing its high-risk environmental needs; will make inefficient and ineffective investments in environmental security with its scarce resources; will continue to use outdated technology; and, as a result, will face increased environmental threats to military force readiness.

Significantly, with restrictive budgets and growing resource needs, the DoD will not be able to satisfy its environmental commitments in a timely fashion. There is clear evidence that better results are achievable. The DoD must set goals and establish metrics to measure accomplishments against such goals through the year 2000. Specific actions must be initiated today in order to achieve these objectives.

The task force has identified seven opportunities that offer the potential for significant improvements in the DoD environmental security program. In order to capitalize on these opportunities, the task force makes the following recommendations:

A management program of cleanup, compliance, pollution prevention and conservation projects based on comparative risk reduction.

DoD environmental security funding will not be sufficient to fully satisfy all cleanup, compliance, pollution prevention and conservation requirements in a timely manner. DoD's current reactive, case-by-case approach often falls to address highest risks first.

A resource-constrained, comparative-risk-reduction management solution is required to set priorities. DoD must evaluate the risk reduction potential and costs associated with its various investments across the spectrum of activities and make decisions based on the greatest overall return. To fully implement such an approach will require close cooperation with regulators and other stakeholders (particularly at the local level).

Recommendations:

 

  • Institute a comparative risk reduction approach for budget planning in cleanup, compliance, pollution prevention and conservation during the FY 1997 budgeting process.

     

    • Initially, implement a qualitative approach based on management and stakeholder judgments.

       

    • Strive for quantitative data wherever such data is available (e.g., in the cleanup area).

       

    • Actively pursue involvement with stakeholders through advisory boards (including federal, state and local regulators).

       

    • Over time, develop credible, understandable quantitative evaluation tools and data bases for showing the comparative risks, cost-effectiveness and times associated with alternative cleanup, compliance, pollution prevention and conservation efforts.

       

  • Develop an overall implementation plan to reduce the most serious risks and to tackle projects with greatest potential for risk reduction, given available resources.
  • Evaluate the critical drivers for risks associated with DoD environmental security, particularly land-use and time to achieve compliance or cleanup.
  • Greatly expand the use of modern modeling and simulation tools and techniques applied to environmental problems.
  • Push for consistent national and international standards in areas affecting DoD operations (e.g., ship discharges) to reduce environmental risks without impeding military operational flexibility.

Increasing focus on pollution prevention.

Pollution prevention is the reduction or elimination of pollution generation through substitution of inputs, process changes and better housekeeping. The task force finds too little emphasis on pollution prevention, even though it has demonstrated significant returns on investment. The result is that pollution prevention projects are underfunded during budget tradeoffs. Today, there are insufficient incentives for cost-reducing, longer-term investments.

Recommendations:

 

  • Establish incentives and new budget mechanisms for increased investment in pollution prevention.

     

    • Strengthen the commitment of senior officials to emphasize the value added from preventing pollution.

       

    • Incorporate pollution prevention criteria into research, development, test, evaluation, production, operations, maintenance/support and disposal program investment policies in the DoD planning, programing and budgeting process.

       

    • Significantly increase RDT&E [research, development, test and evaluation], production and maintenance program investments in pollution prevention -- phase in such increases over a six-year period.

       

    • Allocate an additional $100M[illion]/year for pollution prevention initiatives (to appropriate military service programs).

       

    • Work with the defense industry to facilitate (and "incentivize") investments in pollution prevention.

       

    • Encourage pollution prevention as a mechanism for achieving compliance.

       

    • Allow local commands to use net savings from pollution prevention investments for other initiatives.

       

    • Use nonappropriated funds (e.g., from recycling) and defense business operational funds to incentivize pollution prevention.

       

  • Develop and use result-oriented metrics and benchmarking to monitor progress and manage pollution prevention programs.

     

    • Establish demanding goals, relate goals to investments, set the levels for individual performers and monitor progress.

       

Accelerating Technology Development and Deployment.

Many existing cleanup technologies offer significant risk and/or cost reduction potential that is not currently being realized due, in significant part, to institutional inertia and regulatory barriers. Many DoD problems are identical to those of the public and private sectors and are amenable to treatment by technologies developed outside DoD. There are, however, some DoD-unique environmental problems requiring development of new technologies by DoD, and there are numerous technologies for early exploitation.

In both categories (i.e., of commercial and DoD-unique), there is a need to significantly reduce the timeframe for environmental technology demonstration, validation and application. The biggest bottleneck today is in the early deployment of new technology.

Technology demonstrations can be an important part of DoD's process for achieving more rapid verification and deployment of the most promising technologies. There is also a concern that with shrinking budgets, sufficient environmental science and technology investments will not be made that could dramatically reduce future costs.

Recommendations:

 

  • Devote an additional $150M/year for accelerated environmental technology demonstration and deployment.

     

    • Support current DoD and national environmental technology demonstration programs.

       

    • Establish an additional 50-100 cleanup sites focused on accelerating the transition of promising environmental technologies into practice.

       

    • Allocate the additional $150 million, through a military service-managed joint program office, to manage the environmental technology demonstration and deployment effort.

       

    • Establish data protocols, standardized reporting and a means to rapidly disseminate results.

       

    • Focus resources on demonstrating and validating relevant commercial industry cleanup technology to the maximum extent possible.

       

    • Encourage effective approval coordination among the states for technologies demonstrated under this program.

       

    • Implement a DoD approach for accepting liability for new technology demonstrations and applications similar to that of DoE [Department of Energy]; explore need for new liability legislation.

       

  • Open DoD sites for technology demonstration and verification of technologies.

     

    • Assure regulatory participation.

     

  • Prioritize and focus DoD technology investments on high-potential environmental technologies that target high-risk or high-cost problems experienced by the DoD.

     

    • Areas where insufficient commercial effort is taking place.

     

  • Expand on existing cooperation among agencies and departments and with industry to seek maximum leverage for DoD investments.
  • Develop a set of incentives (e.g., extra resources, merit bonuses, etc.) for government site directors to utilize new technologies.
  • Urge EPA [Environmental Protection Agency] to develop measures to encourage/empower site managers to approve the use of innovative technologies when appropriate (senior managers in both agencies must be involved).
  • Maintain the environmental science and technology budget at current levels, as a minimum.

     

    • Proof of principle and field demonstration efforts are a critical element of DoD investments.

     

  • Develop procurement incentives that encourage the early deployment of promising technologies (e.g., procure performance of a function or job rather than the current procurement practice of buying environmental services based on labor hours and rates).

     

    • Pursue management initiatives.

     

  • Re-evaluate the roles of various participants in DoD environmental technology programs (DoD and national laboratories, industry and academia) to determine whether the resources are being allocated to the most effective performers.

     

    • This needs independent review of all performers to ensure that only the best performers are funded.

     

Integrating environmental considerations into weapons systems life cycles (R&D to disposal).

Approximately 80 percent of environmental costs (associated with hazardous wastes) relate to weapon systems' life-cycle costs, including those at military bases (per the DoD inspector general). For this reason, the task force focused attention on the weapon system acquisition process.

DoD must identify and integrate environmental issues (including pollution prevention) into all aspects of the life cycle for systems and components (R&D to disposal). Commercial experience has clearly demonstrated that front-end design for a system's life cycle pays big rewards. Acquisition practices of the department should adopt appropriate commercial, best environmental practices. This should be a subset of the DoD initiative in acquisition reform.

Recommendations:

 

  • Integrate pollution prevention into the acquisition life-cycle decision process through procedural changes (for new systems, system modifications and existing systems, including maintenance and provisioning).

     

    • Require environmental expertise on integrated product-process teams.

       

    • Establish goals to educate the acquisition work force in environmental considerations.

       

    • Ensure that needed investments are funded.

       

    • Pursue management initiatives.

     

  • Strengthen acquisition and support processes to promote cost-effective environmental practices.

     

    • Make environmental considerations a normal part of DoD's life-cycle process.

       

    • Pursue personnel training and assignment policies that provide environmentally knowledgeable personnel.

       

    • Investigate changes to the Defense Business Operations Fund and other capitalization sources to provide incentives to fund pollution prevention initiatives.

       

  • Develop and advocate streamlined federal environmental review processes for weapon systems.

     

    • Otherwise, as weapons acquisition processes are streamlined, the environmental review process will hinder the deployment schedule.

     

  • Intensify DoD efforts toward achieving uniform national and international environmental standards in areas affecting many DoD operations.

     

  • Develop credible life-cycle costing tools and data bases that focus on rapid development of usable models; incorporate predicted environmental costs, risks and performance; achieve better ways for accounting for the cost savings associated with pollution prevention.

     

  • Pursue management initiatives.

Assuring efficient and effective implementation through benchmarking and appropriate metrics.

The task force found that little quantitative data is currently available to compare DoD implementation with other agencies (e.g., EPA, DoE) or, particularly, with commercial or international best practices. In each area of environmental security, goals need to be established and implementation results measured over time. Congress needs to be assured that environmental security appropriations are being spent efficiently and effectively.

Recommendations:

 

  • Initiate a benchmarking effort to compare DoD implementation with that of EPA, DoE, commercial industry and foreign practices.

     

    • Pick specific non-DoD-unique environmental cleanup sites to start such an effort (e.g., hazardous waste sites).

       

    • Relate metrics to managers' ability to achieve them.

       

    • Analyze the differences between best practices and current practices.

     

  • Define a continuing, DoD-wide process for benchmarking, defining metrics, setting goals; measuring progress toward goals and rewarding managers.

Developing a DoD proactive focus on natural and cultural resource conservation affecting military readiness.

Readiness requirements include large areas of land, airspace, harbors and coastal areas for training, testing and operations. Force modernization and changing geopolitical considerations are increasing the requirement for domestic activities in these areas (e.g., larger test ranges).

Additionally, installation realignments could increase the intensity of the use of existing areas. The DoD must fully understand and manage the relationship between readiness and conservation of natural and cultural resources in the land areas. The issue is not tanks vs. environment, it is tanks and environment.

The DoD Biodiversity Initiative is a positive example of proactive leadership to address the need and to build community understanding and support for necessary DoD operations on lands that are habitats for threatened and endangered species and contain delicate ecosystems.

Today, conservation requirements are considered soft in the DoD planning and budgeting process, in comparison with cleanup and compliance which relate directly to protection of human health. As a result, conservation suffers poor support in resource allocations. This cannot continue.

Only if DoD is perceived as a good steward of its lands will it likely attain the needed flexibility for its future operations and training. It is especially critical that stewardship be perceived in a positive way by local stakeholders.

Recommendations:

 

  • Develop and implement a proactive program to sustain mission needs, minimize adverse readiness impacts and conserve resources on the lands DoD manages.
  • Develop meaningful metrics for guiding and managing conservation projects.
  • Enhance DoD's training program for natural and cultural resource managers as part of the DoD environmental training school system.
  • Invest an additional $50M/year in natural and cultural resource management on DoD lands.

Creating a stable, $5B/year budget for five years to credibly satisfy DoD environmental security needs.

DoD's environmental requirements are still rising and will continue to do so through the 1990s. Specifically:

Cleanup. DoD is just now shifting from measurement and analysis to the far more expensive efforts at actual cleanup of active bases.

Base realignments and closures. A large, unfunded need remains, yet local stakeholders and regulators desire full implementation of cleanup requirements; additionally, environmental impacts for BRAC-95 are unfunded and only compound the resource problem.

Compliance. New compliance requirements are just now being quantified and some have been found to be inordinately expensive and detrimental to military operations.

Pollution prevention. There is too little emphasis on pollution prevention throughout DoD; budget mechanisms are needed for pollution prevention investments.

Conservation. DoD is just now beginning to understand and quantify its conservation needs such that it can ensure operational flexibility and readiness.

Technology. DoD must accelerate technology demonstration and application in order to achieve its goals within constrained budgets; further, in order to achieve long term cost savings, DoD needs a stable science and technology base focused on defenseunique and very-high-cost environmental demands.

Base realignments and closure environmental requirements are of particular concern. In most cases, land cannot be transferred to local entities until cleanup has occurred. Yet BRAC funding is clearly insufficient. The DoD is not now able to meet all of its BRAC-91 environmental funding requirements, and the environmental funding for the most recent round of proposed closures (BRAC-95) is not included in current DoD plans and budgets.

Even if the total budget can be kept stable, it may not be possible to fund all BRAC work in a timely fashion. Priorities should be established based on the following: significant environmental risks; community organization and capability to develop economically productive uses for the land; community and regulator willingness to accept a reasonable cleanup approach.

To implement a more efficient and effective environmental security program, budget stability, a long-range vision, and metrics to measure program success are all critical. Even a stable, $5B/year funding level will be insufficient without significant process improvements -- both are required. After FY 2000, the required dollars should be less, as a result of the process improvements being fully implemented.

Recommendations:

 

  • Stabilize the DoD environmental security budget at the $5B per year level for five years (FY 1996 - FY 2000). This funding level would include the resource allocation recommendations of this task force. Most of the resources will continue to go toward meeting current cleanup and compliance requirements.
  • Implement the efficiency and effectiveness recommendations of this task force or even the added funds will be inadequate. In some cases, such implementation will require legislative reform.

On this, the 25th anniversary of Earth Day, the environment continues to be a major issue for the nation and the DoD and must continue to be incorporated into the mainstream of the DoD's activities and resource allocations. The task force sees the potential for the DoD to dramatically improve its environmental security programs.

The task force believes that the DoD must take a leadership role in those environmental security areas that impact its operations and costs. By showing such leadership and working closely with regulators and community stakeholders, the DoD can put itself in a better position to greatly lower its environmental costs and minimize the environmental impacts on its readiness.

In order to implement these recommendations, the undersecretary of defense (acquisition and technology) should:

 

  • Prepare plans for DoD action on each of the seven opportunities for improvement, with milestones and completion dates;
  • Periodically (e.g., semiannually) report progress against these milestones to an independent board.

 

Published for internal information use by the American Forces Information Service, a field activity of the Office of the Assistant to the Secretary of Defense (Public Affairs), Washington, D.C. Parenthetical entries are speaker/author notes; bracketed entries are editorial notes. This material is in the public domain and may be reprinted without permission. Defense Issues is available on the Internet via the World Wide Web at http://www.defenselink.mil/speeches/index.html.