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Testimony Before the House Committee on Transportation and 
Infrastructure, Coast Guard and Maritime Transportation Subcommittee: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 2:00 p.m. 

Wednesday, April 20, 2005: 

Coast Guard: 

Preliminary Observations on the Condition of Deepwater Legacy Assets 
and Acquisition Management Challenges: 

Statement of Margaret T. Wrightson, Director: 

Homeland Security and Justice Issues: 

GAO-05-307T: 

GAO Highlights: 

Highlights of GAO-05-307T, a testimony for the Subcommittee on Coast 
Guard and Maritime Transportation, Committee on Transportation and 
Infrastructure: 

Why GAO Did This Study: 

In 2002, the Coast Guard began a multiyear, $19 billion to $24 billion 
acquisition program to replace or modernize its fleet of deepwater 
aircraft and cutters, so called because they are capable of operating 
many miles off the coast. For several years now, the Coast Guard has 
been warning that the existing fleet—especially cutters—was failing at 
an unsustainable rate, and it began studying options for replacing or 
modernizing the fleet more rapidly. Faster replacement is designed to 
avoid some of the costs that might be involved in keeping aging assets 
running for longer periods. 

This testimony, which is based both on current and past GAO work, 
addresses several issues related to these considerations: (1) changes 
in the condition of deepwater legacy assets during fiscal years 2000 
through 2004; (2) actions the Coast Guard has taken to maintain and 
upgrade deepwater legacy assets; and (3) management challenges the 
Coast Guard faces in acquiring new assets, especially if a more 
aggressive schedule is adopted.

What GAO Found: 

Available Coast Guard condition measures indicate that the Coast 
Guard’s deepwater legacy aircraft and cutters are generally declining, 
but these measures are inadequate to capture the full extent of the 
decline in the condition of deepwater assets with any degree of 
precision. GAO’s field visits and interviews with Coast Guard staff, as 
well as reviews of other evidence, showed significant problems in a 
variety of the assets’ systems and equipment. The Coast Guard has 
acknowledged that it needs to develop condition measures that more 
clearly demonstrate the extent to which asset conditions affect mission 
capabilities, but such measures have not yet been finalized or 
implemented.

The Coast Guard has taken several types of actions to help keep the 
deepwater legacy assets operational, but these actions, while helpful, 
may not fully address mission capability issues and may require 
additional funding. For example, to help meet mission requirements, 
Coast Guard staff are performing more extensive maintenance between 
deployments, but even so, aircraft and cutters continue to lose mission 
capabilities. One Coast Guard command is using a new approach to help 
sustain the oldest class of cutters, but this approach will likely 
require additional funds—something not included thus far in Coast Guard 
budget plans or requests. 

If the Coast Guard adopts a more aggressive acquisition schedule, it 
will likely continue to face a number of challenges that have already 
affected its ability to effectively manage the Deepwater program. GAO 
has warned that the Coast Guard’s acquisition strategy, which relies on 
a prime contractor (“system integrator”) to identify and deliver the 
assets needed, carries substantial risks. In 2004, well into the 
contract’s second year, key components for managing the program and 
overseeing the system integrator’s performance had not been effectively 
implemented. The Coast Guard has begun addressing some problems—for 
example, putting more emphasis on competition as a way to control 
costs—but many areas have not been fully addressed. A more aggressive 
schedule would only heighten the risks. 

U. S. Coast Guard Deepwater Legacy Assets: 

[See PDF for image]

[End of figure]

www.gao.gov/cgi-bin/getrpt?GAO-05-307T.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Margaret Wrightson at 
(415) 904-2200 or wrightsonm@gao.gov.

[End of section]

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss our preliminary observations 
on the condition of deepwater legacy assets,[Footnote 1] actions the 
Coast Guard has taken to maintain and upgrade these assets, and 
management challenges the Coast Guard faces in acquiring new assets, 
especially if a more aggressive schedule is adopted. Deepwater legacy 
assets consist mainly of aircraft and cutters capable of operating 
further out to sea, but missions may begin at ports, waterways, and 
coasts and extend seaward to wherever the Coast Guard is required to 
take action. The Coast Guard uses these assets to perform a variety of 
missions, such as interdicting illicit drug shipments or attempted 
landings by illegal aliens, rescuing mariners in difficulty at sea, 
protecting important fishing grounds, and responding to marine 
pollution. After the events of September 11, 2001, these missions were 
expanded to include a greater emphasis on port, waterways, and coastal 
security. The Coast Guard's expanded responsibilities caused changes in 
how the deepwater legacy assets are used--for example, in conducting 
more security patrols--and they also created a need to make adjustments 
in mission requirements for assets that would be updated or built as 
part of the long-term acquisition program. 

Many deepwater legacy assets are at or approaching the end of their 
estimated service lives. In 2002, the Coast Guard began a multiyear 
Integrated Deepwater System acquisition program to replace or modernize 
the legacy assets. The Coast Guard's new implementation plan estimates 
the cost for the Deepwater program at $19 billion to $24 billion. From 
fiscal years 2002 through 2005, the Coast Guard was appropriated nearly 
$2.2 billion for the Deepwater program. This amount included close to 
$1.3 billion for new acquisitions and $460.5 million for upgrades of 
the legacy assets. Further, because the Coast Guard must continue to 
operate the deepwater legacy assets until the new assets are acquired, 
the Coast Guard has spent close to $594 million during fiscal years 
2002 through 2004 to fund intermediate-and depot-level maintenance of 
these assets.[Footnote 2]

The Coast Guard is requesting $966 million for the Deepwater program 
for fiscal year 2006--$242 million more than Congress appropriated for 
the program last year. Part of this request ($239.5 million) is for 
maintenance and upgrades to some deepwater legacy assets and is 
predicated, in part, on the Coast Guard's assertion that its deepwater 
legacy assets are "failing at an unsustainable rate" and "headed for a 
train wreck." Faced with this concern, the Coast Guard has studied 
options for replacing deepwater legacy assets more rapidly than 
initially planned and thereby avoiding some of the costs that might be 
involved in upgrading these assets sufficiently to keep them running 
for longer periods. In the coming years, both the Coast Guard and 
Congress will likely be considering the advisability of such changes in 
the program. 

My testimony today addresses three issues related to these 
considerations: 

* Changes in the condition of deepwater legacy assets during fiscal 
years 2000 through 2004;

* Actions the Coast Guard has taken to maintain and upgrade deepwater 
legacy assets; and: 

* Management challenges the Coast Guard faces in acquiring new assets, 
especially if a more aggressive schedule is adopted. 

My testimony is based on past and current work for this subcommittee 
and other congressional committees. Our current work included analyzing 
data and condition measures[Footnote 3] used by the Coast Guard for 
determining deepwater legacy assets' condition,[Footnote 4] reviewing 
Coast Guard actions to maintain and upgrade the legacy assets, meeting 
with operations and maintenance staff covering each type of deepwater 
legacy aircraft and each class of deepwater legacy cutter, and 
assessing the improvements the Coast Guard is making in its management 
of the Deepwater acquisition. We will be following up this testimony 
with a written report that will contain additional, detailed 
information related to the condition of deepwater legacy assets, and 
the actions the Coast Guard is taking to maintain and upgrade them. As 
part of the follow-on report, we will also further examine the Coast 
Guard's management of the Deepwater program and follow up on 
recommendations made in a prior GAO report.[Footnote 5] Our work was 
carried out in accordance with generally accepted governmental auditing 
standards. 

In summary, our work thus far shows the following: 

* Coast Guard condition measures show that the deepwater legacy assets 
generally declined between fiscal years 2000 and 2004, but the Coast 
Guard's available condition measures are inadequate to capture the full 
extent of the decline in the condition of deepwater assets with any 
degree of precision. While there is no systematic, quantitative 
evidence sufficient to demonstrate that deepwater legacy assets are 
"headed for a train wreck," this does not mean that the assets are able 
to perform their missions safely, reliably, and at levels that meet or 
exceed Coast Guard standards. Evidence we gathered in ways other than 
reviewing condition measures, such as interviewing Coast Guard 
operations and maintenance staff, showed deteriorating and obsolete 
systems and equipment as a major cause of the reduction in mission 
capabilities for a number of deepwater legacy aircraft and cutters that 
will need to be addressed if the assets are to continue performing 
their missions at or near current levels until replacement assets 
become operational. These problems are not necessarily reflected in the 
condition measures. For example, the Coast Guard's HH-65 helicopter 
consistently exceeded the Coast Guard's primary condition measure 
during fiscal years 2000 through 2004, yet its engine is being replaced 
because of increasing in-flight power loss incidents, a significant 
safety and reliability issue. The Coast Guard has acknowledged that it 
needs measures that more clearly demonstrate the extent to which asset 
conditions affect mission capabilities, but such measures have not yet 
been finalized or implemented. 

* The Coast Guard has taken several types of actions to keep existing 
assets operational, but these actions, while helpful, may not fully 
address mission capability issues and may require additional funding. 
The Coast Guard now compiles information that can be used to better 
identify and prioritize the maintenance or upgrade projects that need 
to be done to keep existing assets operating. Coast Guard personnel, 
according to evidence obtained during our site visits, are also 
performing more maintenance on these assets than they have in the past-
-for example, spending additional time on maintenance when cutters are 
in port between deployments. These additional maintenance efforts are 
likely helping to prevent a more rapid decline in the condition of 
these assets, but it is important to note that even so, cutters and 
aircraft are still losing mission capabilities because of equipment and 
system failures. Finally, the Coast Guard's Pacific Area Command, which 
is heavily dependent on deteriorating 378-foot cutters, is attempting 
to use new strategies to help sustain the operation of these cutters 
through 2016, when they are currently scheduled to be fully replaced 
with newer cutters. According to the Pacific Area Commander, however, 
doing so is likely to require an additional infusion of funds--
something the Coast Guard has so far not included in its budget 
requests or plans. 

* The Coast Guard's fiscal year 2006 budget request of $966 million for 
the Deepwater program reflects significant revisions to the program's 
requirements, capabilities, and schedule in light of the homeland 
security mission. We have not yet analyzed the likely cost and schedule 
impact of these revisions. However, if a more aggressive acquisition 
schedule were adopted, the Coast Guard would likely continue to face a 
number of management challenges that have already affected its ability 
to effectively administer the Deepwater program. From the outset, we 
have expressed concern about the risks involved with the Coast Guard's 
acquisition strategy, which involves relying on a prime contractor (or 
"system integrator") to identify the assets needed, using tiers of 
subcontractors to design and build the actual assets. Last year, we 
reported that well into the contract's second year, key components 
needed to manage the program and oversee the system integrator's 
performance had not been effectively implemented. We made a number of 
recommendations in the areas of program management, contractor 
accountability, and cost control through competition. While the Coast 
Guard agreed with nearly all of these recommendations and has initiated 
actions to address these problems, we remain concerned that the program 
still carries major and inherent risks. The majority of our 
recommendations have yet to be fully addressed. Recent information 
shows continued challenges in the areas of overall system integration, 
cost and schedule management, and integrated product teams, which 
consist of contractor and government personnel and are the Coast 
Guard's principal tool for managing the Deepwater program. In our 
opinion, the uncertainties associated with the proposed revisions to 
the Deepwater program only heighten these risks. 

Background: 

As the lead federal agency for maritime homeland security within the 
Department of Homeland Security, the Coast Guard is responsible for 
homeland and nonhomeland security missions, including ensuring security 
in ports and waterways and along coastlines, conducting search and 
rescue missions, interdicting drug shipments and illegal aliens, 
enforcing fisheries laws, and responding to reports of pollution. The 
deepwater fleet, which consists of 186 aircraft and 88 cutters of 
various sizes and capabilities, plays a critical role in all of these 
missions. As shown in table 1, the fleet includes fixed-wing aircraft, 
helicopters, and cutters of varying lengths. 

Table 1: Deepwater Legacy Aircraft and Cutter Fleets (as of April 14, 
2005): 

[See PDF for image]

[A] Because of scheduled depot-level maintenance and upgrades that the 
deepwater aircraft have received or will receive, the service lives can 
be extended beyond the original estimated service lives. For the HH-65 
helicopter, a Coast Guard aviation official told us that the aircraft 
had no original estimated service life in terms of flight hours, but 
rather can continue to be operated as long as the structure of the 
aircraft is sound. 

[End of figure]

Some Coast Guard deepwater cutters were built in the 1960s. 
Notwithstanding extensive overhauls and other upgrades, a number of the 
cutters are nearing the end of their estimated service lives. 
Similarly, while a number of the deepwater legacy aircraft have 
received upgrades in engines, operating systems, and sensor equipment 
since they were originally built, they too have limitations in their 
operating capabilities. 

In 1996, the Coast Guard began developing what came to be known as the 
Integrated Deepwater System acquisition program as its major effort to 
replace or modernize these aircraft and cutters. This Deepwater program 
is designed to replace some assets--such as deteriorating cutters--with 
new cutters and upgrade other assets--such as some types of aircraft--
so they can meet new performance requirements.[Footnote 6]

The Deepwater program represents a unique approach to a major 
acquisition in that the Coast Guard is relying on a prime contractor--
the system integrator--to identify and deliver the assets needed to 
meet a set of mission requirements the Coast Guard has 
specified.[Footnote 7] In 2002, the Coast Guard awarded a contract to 
Integrated Coast Guard Systems (ICGS) as the system integrator for the 
Deepwater program. ICGS has two main subcontractors--Lockheed Martin 
and Northrop Grumman--who in turn contract with other subcontractors. 
The resulting program is designed to provide an improved, integrated 
system of aircraft, cutters, and unmanned aerial vehicles to be linked 
effectively through systems that provide command, control, 
communications, computer, intelligence, surveillance, reconnaissance, 
and supporting logistics. We have been reviewing the Deepwater program 
for several years. In recent reports we have pointed out difficulties 
the Coast Guard has been having in managing the Deepwater program and 
ensuring that the acquisition schedule is up to date and on 
schedule.[Footnote 8]

The existing schedule calls for acquisition of new assets under the 
Coast Guard's Deepwater program to occur over an approximately 20-year 
period. By 2007, for example, the Coast Guard is to receive the first 
National Security Cutter, which will have the capability to conduct 
military missions related to homeland security. Plans call for 6 to 8 
of these cutters to replace the 12 existing 378-foot cutters. However, 
in order to carry out its mission effectively, the Coast Guard will 
also need to keep all of the deepwater legacy assets operational until 
they can be replaced or upgraded. 

Deepwater Legacy Assets Show General Decline in Condition, But Current 
Measures Do Not Capture True Extent: 

Coast Guard condition measures show that the deepwater legacy assets 
generally declined between 2000 and 2004, but the Coast Guard's 
available condition measures are inadequate to capture the full extent 
of the decline in the condition of deepwater assets with any degree of 
precision. Other evidence we gathered, such as information from 
discussions with maintenance personnel, point to conditions that may be 
more severe than the available measures indicate. The Coast Guard 
acknowledges that it needs better condition measures but has not yet 
finalized or implemented such measures. 

Coast Guard's Condition Measures Show General Decline in Deepwater 
Assets, with Some Fluctuations: 

During fiscal years 2000 through 2004, the Coast Guard's various 
condition measures show a general decline, although there were year-to-
year fluctuations (see table 2). For deepwater legacy aircraft, a key 
summary measure of the condition--the availability index (the 
percentage of time aircraft are available to perform their missions)--
showed that except for the HU-25 medium-range surveillance aircraft, 
the assets continued to perform close to or above fleet availability 
standards over the 5-year period. In contrast, other condition measures 
for aircraft, such as cost per flight hour and labor hours per flight 
hour, generally reflected some deterioration. For cutters, a key 
summary measure of condition--percent of time free of major 
casualties[Footnote 9]--fluctuated but generally remained well below 
target levels. The number of major casualties generally rose from 
fiscal years 2000 through 2003 and then dropped slightly in fiscal year 
2004.[Footnote 10]

Table 2: Synopsis of Deepwater Legacy Assets' Condition: 

Deepwater legacy asset: HC-130 aircraft; 
Synopsis of general asset condition: The percentage of time the HC-130 
fleet was available to perform missions nearly met or exceeded the 
Coast Guard's target level during fiscal years 2000 through 2003, but 
dropped below the target level in fiscal year 2004. 

Deepwater legacy asset: HU-25 aircraft; 
Synopsis of general asset condition: The percentage of time the HU-25 
fleet was available to perform missions varied from year to year, but 
was consistently below the Coast Guard's target level during fiscal 
years 2000 through 2004. 

Deepwater legacy asset: HH-60 aircraft; 
Synopsis of general asset condition: The percentage of time the HH-60 
fleet was available to perform missions met or was just below the Coast 
Guard's target level during fiscal years 2000 though 2004. 

Deepwater legacy asset: HH-65 aircraft; 
Synopsis of general asset condition: The percentage of time the HH-65 
fleet was available to perform missions consistently exceeded the Coast 
Guard's target level during fiscal years 2000 through 2004. 

Deepwater legacy asset: 378-foot high-endurance cutters; 
Synopsis of general asset condition: The percentage of time the 378-
foot cutter fleet has operated free of deficiencies in mission-
essential equipment remained substantially below the Coast Guard's 
target level during fiscal years 2000 through 2004. 

Deepwater legacy asset: 270-foot and 210-foot medium-endurance cutters; 
Synopsis of general asset condition: The percentage of time the 210-
foot and 270-foot cutter fleets have operated free of deficiencies in 
mission-essential equipment was well below the Coast Guard's target 
level during fiscal years 2000 through 2004, but showed slight 
improvement in fiscal year 2004. 

Deepwater legacy asset: 110-foot and 123-foot patrol boats[A]; 
Synopsis of general asset condition: The percentage of time the patrol 
boat fleet has operated free of deficiencies in mission-essential 
equipment was below but near the Coast Guard's target level during 
fiscal years 2000 and 2001, but declined in more recent years. 

Source: GAO analysis of data provided by the U.S. Coast Guard. 

[A] Data on the 123-foot patrol boats were not compiled until fiscal 
year 2004. That year's data were added to the 110-foot patrol boat data 
to arrive at totals for the patrol boat fleet. 

[End of table]

Another, albeit less direct, measure of an asset's condition is 
deferred maintenance--the amount of scheduled maintenance that must be 
postponed on an asset in order to pay for unscheduled repairs. Such 
deferrals can occur when the Coast Guard does not have enough money to 
absorb unexpected maintenance expenditures and still perform all of its 
scheduled maintenance, thus creating a backlog. For example, in spring 
2004, while on a counter-drug mission, the 210-foot cutter Active 
experienced problems in the condition of its flight deck that were to 
be corrected during its scheduled depot-level maintenance. However, 
because of a lack of funding, the maintenance was deferred and the 
flight deck not repaired. As a result, the cutter lost 50 percent of 
its patrol time, since the required support helicopters could not take 
off from or land on it. 

As table 3 shows, deferred maintenance does not show a clear pattern 
across all classes of deepwater legacy assets. For the deepwater legacy 
aircraft, the overall amount of estimated deferred maintenance 
increased each year during fiscal years 2002 through 2004, from $12.3 
million to about $24.6 million. However, most of the increase came from 
one type of asset, the HH-60 helicopter, and was mainly the result of 
shortening the interval between scheduled depot-level maintenance from 
60 months to 48 months--thereby increasing the scheduled maintenance 
workload--and not from having to divert money to deal with unscheduled 
maintenance. For the deepwater cutters, the amount of estimated 
deferred maintenance increased from fiscal year 2002 to 2003, but then 
dropped significantly in fiscal year 2004. The decrease in fiscal year 
2004 came mainly because (1) the Coast Guard ceased maintenance on an 
icebreaker, thus freeing up some maintenance funds; 
and (2) the Coast Guard also received supplemental operational and 
maintenance funding, allowing it to deal with both scheduled and 
unscheduled maintenance. Thus, the drop in the estimate of deferred 
maintenance costs for fiscal year 2004 is not necessarily an indicator 
that the condition of the legacy assets was improving; it could result 
from the Coast Guard having more money to address the maintenance 
needs. 

Table 3: Estimated Costs for Deferred Maintenance of Deepwater Aircraft 
and Cutters, Fiscal Years 2002-2004: 

Deepwater asset: HC-130; 
Fiscal year 2002: $4,691,000; 
Fiscal year 2003: $7,016,000; 
Fiscal year 2004: $5,737,000. 

Deepwater asset: HU-25; 
Fiscal year 2002: 0; 
Fiscal year 2003: $201,000; 
Fiscal year 2004: 0. 

Deepwater asset: HH-60; 
Fiscal year 2002: $7,630,000; 
Fiscal year 2003: $9,436,000; 
Fiscal year 2004: $18,824,000. 

Deepwater asset: HH-65; 
Fiscal year 2002: 0; 
Fiscal year 2003: 0; 
Fiscal year 2004: 0. 

Deepwater asset: Subtotal for aircraft; 
Fiscal year 2002: $12,321,000; 
Fiscal year 2003: $16,653,000; 
Fiscal year 2004: $24,561,000. 

Deepwater asset: 378-foot cutters; 
Fiscal year 2002: $2,556,000; 
Fiscal year 2003: $8,135,000; 
Fiscal year 2004: $3,000,000. 

Deepwater asset: 270-foot cutters; 
Fiscal year 2002: $2,070,000; 
Fiscal year 2003: $870,000; 
Fiscal year 2004: 0. 

Deepwater asset: 210-foot cutters; 
Fiscal year 2002: $786,000; 
Fiscal year 2003: $1,137,000; 
Fiscal year 2004: 0. 

Deepwater asset: 110-foot patrol boats; 
Fiscal year 2002: $1,618,000; 
Fiscal year 2003: $1,961,000; 
Fiscal year 2004: $500,000. 

Deepwater asset: Subtotal for cutters; 
Fiscal year 2002: $7,030,000; 
Fiscal year 2003: $12,103,000; 
Fiscal year 2004: $3,500,000. 

Deepwater asset: Total for all deepwater assets; 
Fiscal year 2002: $19,351,000; 
Fiscal year 2003: $28,756,000; 
Fiscal year 2004: $28,061,000. 

Source: U.S. Coast Guard: 

Note: The Coast Guard estimates the cost for aircraft deferred 
maintenance by multiplying a percentage of average depot maintenance 
costs by the number of aircraft overdue for depot maintenance 
overhauls, plus the annual cost for extension inspections each year. 
The Coast Guard generally does not track deferred maintenance costs by 
cutter class, but compiled these data at GAO's request for fiscal years 
2002 through 2004. The Coast Guard estimated the costs of only the 
planned cutter maintenance that had to be deferred to the following 
year and not the amount of maintenance that should have been conducted 
and was not funded. 

[End of table]

Current Condition Measures Not Robust Enough to Clearly Link Condition 
with Effect on Missions: 

At the time we began our work, the Coast Guard's condition measures 
were not sufficiently robust to systematically link assets' condition 
with degradation in mission capabilities. As we discussed with Coast 
Guard officials, without such condition measures, the extent and 
severity of the decline in the existing deepwater legacy assets and 
their true condition cannot be fully determined. As a result, the 
picture that emerges regarding the condition of the deepwater legacy 
assets based on current Coast Guard condition measures should be viewed 
with some caution. While there is no systematic, quantitative evidence 
sufficient to demonstrate that deepwater legacy assets are nearing a 
"train wreck," this does not mean the assets are in good condition or 
have been performing their missions safely, reliably and at levels that 
meet or exceed Coast Guard standards. We identified two factors that 
need to be considered to put these condition measures in proper 
context. 

The first factor deals with limitations in the measures themselves. 
Simply put, the Coast Guard's measures of asset condition do not fully 
capture the extent of the problems. As such, they may understate the 
decline in the legacy assets' condition. More specifically, Coast Guard 
measures focus on events, such as flight mishaps or equipment 
casualties, but do not measure the extent to which these and other 
incidents degrade mission capabilities. Here are two examples in which 
the Coast Guard's current measures are not sufficiently robust to 
systematically capture degradation in mission capabilities: 

* The surface search radar system on the HC-130 long-range surveillance 
aircraft, called the APS-137 radar, is subject to frequent failures and 
is quickly becoming unsupportable. Flight crews use this radar to 
search for vessels in trouble and to monitor ships for illegal 
activity, such as transporting illicit drugs or illegal immigrants. 
When the radar fails, flight crews are reduced to looking out the 
window for targets, greatly reducing mission efficiency and 
effectiveness. A flight crew in Kodiak, Alaska, described this 
situation as being "like trying to locate a boat looking through a 
straw." Mission capability degradations such as these are not reflected 
in the Coast Guard's current condition measures. 

* The 378-foot cutter Jarvis recently experienced a failure in one of 
its two main gas turbines shortly after embarking on a living marine 
resources and search and rescue mission. While Jarvis was able to 
accomplish its given mission, albeit at reduced speeds, this casualty 
rendered the cutter unable to respond to any emergency request it might 
have received--but did not in this case--to undertake a mission 
requiring higher speeds, such as drug interdiction. The Coast Guard 
condition measures are not robust enough to capture these distinctions 
in mission capability. 

The second factor that needs to be kept in mind is the compelling 
nature of the other evidence we gathered outside of the Coast Guard's 
condition measures. This evidence, gleaned from information collected 
during our site visits and discussions with maintenance personnel, 
showed deteriorating and obsolete systems and equipment as a major 
cause of the reduction in mission capabilities for a number of 
deepwater legacy aircraft and cutters. Such problems, however, are not 
captured by the Coast Guard's condition measures. One example of this 
involves the HH-65 short-range recovery helicopter. While this 
helicopter consistently exceeded availability standards established by 
the Coast Guard over the 5-year period we examined, it is currently 
operating with underpowered engines that have become increasingly 
subject to power failures. As a result, Coast Guard pilots employ a 
number of work arounds, such as dumping fuel or leaving the rescue 
swimmer on scene if the load becomes too heavy. Further, because of 
increasing safety and reliability problems, the Coast Guard has also 
implemented a number of operational restrictions--such as not allowing 
the helicopter to land on helipads--to safeguard crew and passengers 
and prevent mishaps until all of the fleets' engines can be replaced. 

The Coast Guard has recently recognized the need for improved measures 
to more accurately capture data on the extent to which its deepwater 
legacy assets are degraded in their mission capabilities, but as of 
March 2005, such measures have not yet been finalized or implemented. 
Subsequent to our inquiries regarding the lack of condition and mission 
capability measures, Coast Guard naval engineers reported that they had 
begun developing a "percent of time fully mission capable" measure to 
reflect the degree of mission capability, as well as measures to track 
cutter readiness. We agree that measures like this are needed--and as 
soon as possible. Further, current plans call for the measure, if 
approved, to be used for cutters, but not for aircraft. Consequently, 
even if this measure were to be implemented across the Coast Guard, 
there would still be no measure to address degradation in mission 
capabilities for aircraft. We will be exploring this issue further in 
our follow-on report. 

Actions to Maintain and Upgrade Deepwater Legacy Assets Are Under Way, 
but Condition Issues Remain: 

The Coast Guard has taken several actions to address maintenance issues 
and upgrades for its deepwater legacy assets. These include 
establishing a compendium of information for making decisions regarding 
maintenance and upgrades, performing more extensive maintenance between 
deployments, and, at the Pacific Area Command, applying new business 
rules and strategies to better sustain the 378-foot high-endurance 
cutters through 2016. These additional efforts are likely helping to 
prevent a more rapid decline in the condition of these assets, but 
condition problems continue, and the efforts will likely involve 
additional costs. 

Compendium of Needs Is Being Compiled and Used: 

Since 2002, the Coast Guard has annually issued a Systems Integrated 
Near Term Support Strategy compendium. Among other things, this 
compendium consolidates information needed to make planning and 
budgeting decisions regarding maintenance and upgrades to sustain 
legacy assets. Its purpose is to serve as a tool for senior Coast Guard 
management in setting priorities and planning budgets. From this 
strategic document, the Coast Guard has identified a number of upgrades 
to improve the capabilities of the deepwater legacy aircraft and 
cutters. The most recent compendium (for fiscal year 2006) lists more 
than $1 billion worth of upgrades to the deepwater legacy assets. The 
planned upgrades identified in the compendium that have been approved 
and received initial funding account for an estimated $856 million the 
Coast Guard anticipates it will need to complete those projects. The 
approved upgrades for deepwater legacy assets are shown in table 4. 

Table 4: Approved Upgrades for Deepwater Legacy Aircraft and Cutters: 

Deepwater asset: HC-130 aircraft; 
Synopsis of planned upgrades: The Coast Guard is beginning to replace 
aircraft's dated and difficult to support surface search radar system; 
Estimated costs and time frames of upgrades: The radar system 
replacement is projected to cost $78 million and be completed in fiscal 
year 2008. A total of $9 million has been funded to date. 

Deepwater asset: HH-60 aircraft; 
Synopsis of planned upgrades: The Coast Guard has begun a service life 
extension plan and a replacement of the obsolete avionics suite; 
Estimated costs and time frames of upgrades: The service life extension 
program is estimated to cost $16 million and be completed by fiscal 
year 2009. The avionics replacement program is projected to cost $121 
million and be completed by fiscal year 2010. A total of $32.8 million 
has been funded to date for these upgrades. 

Deepwater asset: HH-65 aircraft; 
Synopsis of planned upgrades: Serious safety and reliability problems 
with the engine led the Coast Guard to place operational restrictions 
on the HH-65 fleet in October 2003; 
Estimated costs and time frames of upgrades: The Coast Guard plans to 
re-engine 84 HH-65 aircraft at a projected cost of $349 million, now 
estimated to be completed by February 2007. A total of $160.7 million 
has been funded to date. 

Deepwater asset: 270-foot and 210-foot medium-endurance cutters; 
Synopsis of planned upgrades: During fiscal year 2005 these cutters are 
to enter a legacy asset sustainment project known as the Mission 
Effectiveness Program (MEP) aimed at increasing their service lives 
until their replacement by a new cutter. The MEP includes upgrading 
major engineering subsystems such as evaporators, sewage systems, and 
gyrocompasses; 
Estimated costs and time frames of upgrades: The MEP is projected to 
cost a total of $292 million and be completed by fiscal year 2015. The 
medium-endurance cutters will ultimately be replaced by the Offshore 
Patrol Cutter. A total of $12.5 million has been funded to date. 

Deepwater asset: Total: 
Estimated costs and time frames of upgrades: $856 million total needed 
to fund these projects, of which $215 million has been funded to date. 

Source: GAO analysis of data provided by the U.S. Coast Guard. 

Note: While there has not been any funding approved for upgrades to the 
HU-25 aircraft, the 378-foot cutters, or the 110-foot and 123-foot 
patrol boats, since all of these deepwater legacy assets are scheduled 
to be replaced, each of these assets has upgrades listed in the Systems 
Integrated Near Term Support Strategy compendium. The HU-25 aircraft 
has an engine replacement project estimated to cost $78.1 million; the 
378-foot cutter has an MEP estimated to cost $137.8 million; and the 
patrol boats have three projects--replacement of the fin stabilizer 
system that is estimated to cost $10.4 million, an MEP that is 
estimated to cost $162 million, and replacement of the ship service 
generators that is estimated to cost $20.7 million. If the Coast Guard 
were to request funding for all of these sustainment projects, it would 
cost an additional $409 million. 

[End of table]

Among the projects already begun is the re-engining of the HH-65 
helicopters to increase the helicopter's power and capabilities. The 
Coast Guard is also upgrading several other aviation systems in an 
effort to improve aircraft capabilities. Enhancements are also planned 
for certain classes of deepwater cutters. For example, during this 
fiscal year, the Coast Guard is to begin a maintenance effectiveness 
project on the 210-foot and 270-foot cutters. This project includes 
replacing major engineering subsystems with the goal of extending the 
cutters' service lives until their replacement by the Offshore Patrol 
Cutter. Of the $856 million total estimated costs needed for the 
planned upgrades to the deepwater legacy assets listed above, the Coast 
Guard has received $215 million through fiscal year 2005 and has 
requested another $217.3 million in its fiscal year 2006 budget. The 
remaining estimated costs of $423.7 million would have to be funded 
beyond fiscal year 2006. 

Increasing Amounts of Maintenance Are Being Performed, but Loss of 
Mission Capabilities Continues: 

Coast Guard personnel consistently reported to us that crewmembers have 
to spend increasingly more time between missions to prepare for the 
next deployment. For example, to prevent further corrosion-related 
problems, air station maintenance personnel at the locations we visited 
said they have instituted additional measures, such as washing and 
applying fluid film to the aircraft prior to each deployment. Similar 
accounts were told by personnel working on cutters. For example, 
officers of the 270-foot cutter Northland told us that because of dated 
equipment and the deteriorating condition of its piping and other 
subsystems, crewmembers have to spend increasingly more time and 
resources while in port to prepare for their next deployment. While we 
could not verify these increases in time and resources because the 
Coast Guard does not capture data on these additional maintenance 
efforts, the need for increasing amounts of maintenance was a message 
we consistently heard from the operations and maintenance personnel 
with whom we met. 

Such efforts are likely helping to prevent a more rapid decline in the 
condition of these deepwater legacy assets, but it is important to note 
that even with the increasing amounts of maintenance, these assets are 
still losing mission capabilities because of deteriorating equipment 
and system failures. For example, in fiscal year 2004, one 378-foot 
cutter lost 98 counterdrug mission days because of a number of patrol-
ending casualties--including the loss of ability to raise and lower 
boats and run major electrical equipment--requiring $1.2 million in 
emergency maintenance. Another 378-foot cutter lost 27 counterdrug 
mission days in the fall of 2004 when it required emergency dry-dock 
maintenance because of hydraulic oil leaking into the reduction gear. 

New Initiative for Maintaining 378-Foot Cutters Is Under Way, but 
Additional Funding Will Likely Be Needed: 

One effort is under way at the Coast Guard's Pacific Area Command to 
improve maintenance practices for the 378-foot cutters.[Footnote 11] 
Pacific Area Command officials have recognized that a different 
approach to maintaining and sustaining legacy cutters may be needed 
and, as a first step, they have undertaken an initiative applying what 
they refer to as "new business rules and strategies" to better maintain 
the 378-foot high-endurance cutters through 2016. Under the original 
Deepwater proposal, the final 378-foot cutter was to be decommissioned 
in 2013, but by 2005, that date had slipped to 2016. To help keep these 
cutters running through this date, Pacific Area Command officials are 
applying such rules and strategies as (1) ensuring that operations and 
maintenance staffs work closely together to determine priorities, (2) 
recognizing that maintaining or enhancing cutter capabilities will 
involve trade-off determinations, and (3) accepting the proposition 
that with limited funding not all cutters will be fully capable to 
perform all types of missions. Pacific Area Command officials believe 
that in combination, these principles and strategies will result in 
more cost-effective maintenance and resource allocation decisions--
recognizing that difficult decisions will still have to be made to 
balance maintenance and operations. 

The Pacific Area Command's new initiative has the potential for 
assisting the Coast Guard in making more informed choices regarding the 
best use of their resources, but the approach will likely require 
additional funding. In particular, the Pacific Area Commander told us 
that in order for the 378-foot cutters to be properly maintained until 
their replacements become operational; the Coast Guard will have to 
provide additional funding for sustaining the 378-foot cutters. So far, 
the Coast Guard's budget plans or requests do not address this 
potential need. 

Management Challenges Faced in Acquiring New Assets Remain Significant: 

Since the inception of the Deepwater program, we have expressed 
concerns about the degree of risk in the acquisition approach and the 
Coast Guard's ability to manage and oversee the program. Last year, we 
reported that, well into the contract's second year, key components 
needed to manage the program and oversee the system integrator's 
performance had not been effectively implemented.[Footnote 12] We also 
reported that the degree to which the program was on track could not be 
determined because the Coast Guard was not updating its 
schedule.[Footnote 13] We detailed needed improvements in a number of 
areas, shown in table 5. These concerns have a direct bearing on any 
consideration to increase the program's pace. Because the Coast Guard 
was having difficulty managing the Deepwater program at the pace it had 
anticipated, increasing the pace by attempting to speed the acquisition 
would only complicate the problem. 

Table 5: Summary of Deepwater Areas Needing Management Attention as 
Reported by GAO: 

Areas of concern: Key components of management and oversight have not 
been effectively implemented; 
Recommendations to the U.S. Coast Guard: Improve integrated product 
teams responsible for managing the program by providing better 
training, approving charters, and improving systems for sharing 
information between teams. 

Recommendations to the U.S. Coast Guard: Ensure adequate staffing of 
the Deepwater program. 

Recommendations to the U.S. Coast Guard: Provide field personnel with 
guidance and training on transitioning to new Deepwater assets. 

Recommendations to the U.S. Coast Guard: Update the original 
acquisition schedule to support future budget requests, starting with 
the fiscal year 2006 request. 

Areas of concern: Procedures for ensuring contractor accountability are 
inadequate; 
Recommendations to the U.S. Coast Guard: Develop measurable award fee 
criteria consistent with guidance from the Office of Federal 
Procurement Policy. 

Recommendations to the U.S. Coast Guard: Provide for better input from 
U.S. Coast Guard technical representatives. 

Recommendations to the U.S. Coast Guard: Hold system integrator 
accountable for improving effectiveness of integrated product teams. 

Recommendations to the U.S. Coast Guard: Establish a time frame for 
putting steps in place to measure contractor's progress toward 
improving operational effectiveness. 

Recommendations to the U.S. Coast Guard: Establish a baseline for 
determining whether the acquisition approach is costing the government 
more than a traditional asset replacement approach. 

Recommendations to the U.S. Coast Guard: Establish criteria to 
determine when to adjust the project baseline and document the reasons 
for change. 

Areas of concern: Control of future costs through competition remains 
at risk because of weak oversight; 
Recommendations to the U.S. Coast Guard: Develop a comprehensive plan 
for holding the system integrator accountable for ensuring adequate 
competition among suppliers. 

Recommendations to the U.S. Coast Guard: For subcontracts over $5 
million awarded by the system integrator to the two major 
subcontractors, require notification to the Coast Guard about decisions 
to perform the work in-house rather than contracting it out. 

Source: Developed by GAO from our reports GAO-04-380 and GAO-04-695. 

[End of table]

The Coast Guard agreed with nearly all of our recommendations and has 
made progress in implementing some of them. In most cases, however, 
while actions are under way, management challenges remain that are 
likely to take some time to fully address. 

Improvement of Program Management and Contractor Oversight Is Mixed: 

We have seen mixed success in the Coast Guard's efforts to improve 
management of the program and contractor oversight. All four areas of 
concern--improving integrated project teams (IPT), ensuring adequate 
staff for the program, planning for human capital requirements for 
field units receiving new assets, and updating the program's schedule-
-have yet to be fully addressed. 

Strengthening Integrated Product Teams: 

Although the Deepwater program has made some efforts to improve the 
effectiveness of IPTs, we continue to see evidence that more 
improvements are needed for the teams to effectively do their jobs. 
These teams, the Coast Guard's primary tool for managing the program 
and overseeing the contractor, are generally chaired by a subcontractor 
representative and consist of members from subcontractors and the Coast 
Guard. The teams are responsible for overall program planning and 
management, asset integration, and overseeing delivery of specific 
Deepwater assets. Since our March 2004 report, the teams have been 
restructured, and 20 teams have charters setting forth their purpose, 
authority, and performance goals. And new, entry-level training is 
being provided to team members. 

Despite this progress, however, the needed changes are not yet 
sufficiently in place. A recent assessment by the Coast Guard of the 
system integrator's performance found that roles and responsibilities 
in some teams continue to be unclear. Decision making is to a large 
extent stovepiped, and some teams still lack adequate authority to make 
decisions within their realm of responsibility. One source of 
difficulty for some team members has been the fact that each of the two 
major subcontractors has used its own databases and processes to manage 
different segments of the program. Decisions on air assets are made by 
Lockheed Martin, while decisions regarding surface assets are made by 
Northrop Grumman. This approach can lessen the likelihood that a 
"system of systems" outcome will be achieved. Officials told us that 
more attention is being paid to taking a systemwide approach and that 
the Coast Guard has emphasized the need to ensure that the two major 
subcontractors integrate their management systems. 

Ensuring Adequate Staffing for the Deepwater Program: 

The Coast Guard has taken steps to more fully staff the Deepwater 
program, with mixed effects. In February 2005, the Deepwater program 
executive officer approved a revised human capital plan. The plan 
emphasizes workforce planning, including determining needed knowledge, 
skills, and abilities and developing ways to leverage institutional 
knowledge as staff rotate out of the program. This analysis is intended 
to help determine what gaps exist between needed skills and existing 
skills and to develop a plan to bridge these gaps. The Coast Guard has 
also taken some short-term steps to improve Deepwater program staffing, 
hiring contractors to assist with program support functions, shifting 
some positions from military to civilian to mitigate turnover risk, and 
identifying hard-to-fill positions and developing recruitment plans 
specifically for them. Finally, the Deepwater program and the Coast 
Guard's acquisition branch are now working on an automated system for 
forecasting military rotation cycles, a step Deepwater officials 
believe will help with long-range strategic workforce planning and 
analysis. 

Despite these actions, however, vacancies remain in the program, and 
some metrics that may have highlighted the need for more stability in 
the program's staff have been removed from the new human capital plan. 
As of January 2005, 244 positions were assigned to the program, but 
only 206 of these were filled, a 16 percent vacancy rate. A year ago, 
209 staff were assigned to the program. Further, the new human capital 
plan removes a performance goal that measured the percentage of billets 
filled at any given time. Coast Guard officials acknowledged that the 
prior plan's goal of a 95 percent or higher fill rate was unduly 
optimistic and was a poor measure of the Coast Guard's ability to meet 
its hiring goals. For example, billets for military personnel who plan 
to rotate into the program in the summer are created at the beginning 
of the budget year, leading the metric to count those positions as 
vacant from the beginning of the budget year until summer. Other 
performance metrics that were included in the prior plan to measure 
progress in human capital issues have also been removed. For example, 
to help ensure that incoming personnel received acquisition training 
and on-the-job training, a billet was included in the prior plan to 
serve as a floating training position that replacement personnel could 
use for a year before the departure of military incumbents. This 
position was never funded, and the new plan removes the billet. 

Improving Communication with Personnel Who Will Use the New Assets: 

The Coast Guard recognizes the critical need to inform the operators 
who are to use the Deepwater assets of progress in the program, and 
officials stated that, on the basis of our recommendations, they have 
made a number of improvements in this area. A November 2004 analysis of 
the Deepwater program's communication process, conducted in 
coordination with the National Graduate School, found that the 
communication and feedback processes were inadequate. Emphasis has now 
been placed on outreach to field personnel, with a multipronged 
approach involving customer surveys, face-to-face meetings, and 
presentations. We have not yet evaluated the effectiveness of the new 
approach. 

Human capital requirements for the Deepwater program--such as crew 
numbers and schedules, training, and support personnel--will have an 
increasing impact on the program's ability to meet its goals as the 
pace at which assets are delivered to field units picks up. Recent 
assessments by Coast Guard performance monitors show this to be an area 
of concern.[Footnote 14] Coast Guard officials have expressed concern 
about whether the system integrator is appropriately considering human 
capital in systems engineering decisions. The system integrator is 
required to develop a workforce management plan for Deepwater, as well 
as "human factors engineering" plans for each Deepwater asset and for 
the overall system of systems. The Coast Guard rejected the 
contractor's workforce management plan and several of the proposed 
human factors engineering plans as being inadequate. The rejections 
were due, in part, to the lack of an established and integrated system-
level engineering approach that shows how issues relating to human 
capabilities and limitations of actually performing with the system 
will be approached. One performance monitor noted that, as of late 
2004, requirements for staffing and training of maintenance facilities 
and organizations had yet to be determined. According to the Coast 
Guard, emphasis on a contractor's approach to addressing human capital 
considerations is necessary to ensure that Deepwater goals are met, 
especially as they pertain to operational effectiveness and total 
ownership cost. 

Updating the Acquisition Schedule: 

The Coast Guard has recently undertaken efforts to update the original 
2002 Deepwater acquisition schedule--an action that we suggested in our 
June 2004 report.[Footnote 15] The original schedule had milestone 
dates showing when work on an asset would begin and when delivery would 
be expected, as well as the integrated schedules of critical linkages 
between assets, but we found that the Coast Guard was not maintaining 
an updated and integrated version of the schedule.[Footnote 16] As a 
result, the Coast Guard could not demonstrate whether individual 
components and assets were being integrated and delivered on schedule 
and in critical sequence. As recently as October 2004, Deepwater 
performance monitors likewise expressed concern that the Coast Guard 
lacked adequate visibility into the program's status and that lack of 
visibility into the schedules for component-level items prevented 
reliable forecasting and risk analysis. The Coast Guard has since taken 
steps to update the outdated schedule, and has indicated that it plans 
to continue to update the schedule each month for internal management 
purposes, and semiannually to support its budget planning efforts. We 
think this is an important step toward improving the Coast Guard's 
management of the program because it provides a more tangible picture 
of progress, as well as a baseline for holding contractors accountable. 
We will continue to work closely with the Coast Guard to ensure 
progress is made and to monitor how risks are mitigated. 

Procedures for Ensuring System Integrator Accountability Are More 
Rigorous, but Concerns Remain: 

We have seen progress in terms of the rigor with which the Coast Guard 
is periodically assessing the system integrator's performance, but 
concerns remain about the broader issues of accountability for 
achieving the overarching goals of minimizing total ownership costs and 
maximizing operational effectiveness. 

Improving Criteria for Assessing Performance: 

Improvements continue to be made to the criteria for assessing the 
system integrator's performance. In March 2004, we reported that the 
process for assessing performance against specific contract tasks 
lacked rigor. The criteria for doing so have since been revised to more 
clearly reflect those that are objective, (that is, measured through 
automated tools against established metrics), and those that are 
subjective, meaning the narrative comments by Coast Guard performance 
monitors. Weights have been assigned to each set of evaluation factors, 
and the Coast Guard continues to refine the distribution of the weights 
to reach an appropriate balance between automated results and the 
eyewitness observations of the performance monitors. Coast Guard 
officials told us that they have also provided additional guidance and 
training to performance monitors. We found that efforts have been made 
to improve the consistency of the format used for their input in 
assessments of the system integrator's performance. Coast Guard 
officials said that they are continuing to make improvements to ensure 
that performance monitors' relevant observations are appropriately 
considered in making award fee determinations. 

It is important to note that although performance monitor comments are 
considered subjective, they are valuable inputs to assessing the system 
integrator's performance, particularly when they are tied to measurable 
outcomes. It will be necessary for the Coast Guard to continue refining 
the award fee factors as the program progresses. In some cases, we 
noted that the performance monitors' assessments differed vastly from 
the results of automated, data-driven assessments. For example, while 
schedule management is discussed in the Coast Guard's most recent 
assessment of the system integrator's performance as a major area of 
challenge and risk, the objective measure showed 100 percent compliance 
in this area. Another metric assesses the extent to which integrated 
product teams consider the impact of their decisions on the overall 
cost and effectiveness of the Deepwater program. Performance monitors 
reported that because system-level guidance had not been provided to 
the teams responsible for specific assets, they had a limited ability 
to see the whole picture and understand the impact of decisions on 
total ownership costs and operational effectiveness. However, the 
automated measure was again 100 percent compliance. Coast Guard 
officials said that, in some cases, the data-driven metrics do not 
accurately reflect the contractor's performance. For the next award fee 
assessment, Deepwater officials plan to revise the metrics and place 
more weight on the performance monitors' input, while ensuring that it 
is based on measurable outcomes. 

Holding the System Integrator Accountable for Effectiveness of Project 
Teams: 

Changes have been made to the award fee metrics that place additional 
emphasis on the system integrator's responsibility for making 
integrated project teams effective. Award fee criteria now incorporate 
specific aspects of how the integrator is managing the program, 
including administration, management commitment, collaboration, 
training, and empowerment of these teams. However, as discussed above, 
concerns remain about whether the teams are effectively accomplishing 
their goals. 

Evaluation of Operational Effectiveness and Total Ownership Cost: 

While the Coast Guard has developed models to measure the system 
integrator's performance in operational effectiveness and total 
ownership costs, concrete results have not yet emerged. Minimizing 
total ownership costs and maximizing operational effectiveness are two 
of the overarching goals of the Deepwater program. The system 
integrator's performance in these two areas will be a critical piece of 
information when the Coast Guard makes a decision about whether to 
award the contractor the first contract option period of 5 years. 
Initial decision making is to start next year. 

With regard to the operational effectiveness of the program, measuring 
the system integrator's impact has yielded limited results to date 
because few of the new assets are operational. The Coast Guard has 
developed modeling capabilities to simulate the effect of the new 
capabilities on its ability to meet its missions. However, until 
additional assets become operational, progress toward this goal will be 
difficult to determine. 

With regard to total ownership costs, the Coast Guard does not plan to 
implement our recommendation. It has not adhered to its original plan, 
set forth in the Deepwater program management plan, of establishing as 
its baseline a cost not to exceed the dollar value of replacing the 
assets under a traditional approach (e.g., on an asset-by-asset basis 
rather than a system-of-systems approach). Although a cost baseline 
consistent with the program management plan's approach was initially 
established, this number has not been rebaselined, as has the system 
integrator's cost estimate baseline, and is not being used to evaluate 
the contractor's progress in holding total ownership costs down. In 
practice, the baseline being used to measure total ownership cost is 
the system integrator's own cost estimate. As we reported in March 
2004, we believe that measuring the system integrator's cost growth 
compared with its own cost proposal will tell the government nothing 
about whether it is gaining efficiencies by turning to the system of 
systems concept. 

Establishing Criteria and Documenting Changes to the Baseline: 

Coast Guard officials stated that the contract total ownership cost and 
operational effectiveness baseline is adjusted based on approved 
decision memorandums from the Agency Acquisition Executive, the Vice 
Commandant of the Coast Guard. 

Coast Guard Has Taken Steps to Hold the System Integrator Accountable 
for Competition: 

The Coast Guard reported taking steps to address our recommendations 
concerning cost control through competition. Our recommendations 
pertained to competition among second-tier suppliers and notification 
of "make" decisions.[Footnote 17]

* Competition among second-tier suppliers. Coast Guard officials told 
us that in making the decision about whether to award the first 
contract option, the government will specifically examine the system 
integrator's ability to control costs by assessing the degree to which 
competition is fostered at the major subcontractor level. The 
evaluation will consider the subcontractors' project management 
structure and processes to control costs, as well as how market surveys 
of similar assets and major subsystems are implemented. The Coast Guard 
is focusing its attention on those areas that were priced after the 
initial competition for the Deepwater contract was completed, such as 
the HH-65 re-engining and the C-130J missionization.[Footnote 18] For 
example, a new process implemented for the C-130J missionization was a 
requirement for competition in subcontracting and government approval 
of all subcontracts exceeding $2 million in order for the Coast Guard 
to monitor the integrator's competition efforts. 

* Notification of make decisions. According to the Federal Acquisition 
Regulation, the prime contractor is responsible for managing contract 
performance, including planning, placing, and administering 
subcontracts as necessary to ensure the lowest overall cost and 
technical risk to the government. When "make-or-buy programs" are 
required, the government may reserve the right to review and agree on 
the contractor's make-or-buy program when necessary to ensure 
negotiation of reasonable contract prices, among other things. We 
recommended that the Coast Guard be notified of make decisions over $5 
million in order to facilitate controlling costs through competition. 
We suggested the $5 million threshold because Lockheed Martin, one of 
the major subcontractors, considers that amount to be the threshold for 
considering its suppliers major. The Coast Guard has asked the system 
integrator, on a voluntary basis, to provide notification one week in 
advance of a make decision of $10 million or more based on the criteria 
in the Federal Acquisition Regulation.[Footnote 19] According to Coast 
Guard officials, to date, no make decision has exceeded $10 million 
since the request was made. The details implementing this 
recommendation have not yet been worked out, such as specifically who 
in the Coast Guard will monitor the subcontractors' make decisions to 
ensure that the voluntary agreement is complied with. 

Concluding Observations: 

Our work to date suggests the costly and important Deepwater program 
will need constant monitoring and management attention to successfully 
accomplish its goals. In this respect, we identified three points that 
should be kept in mind in considering how to proceed with the program. 

* First, the need to replace or upgrade deteriorating legacy assets is 
considerable. While the Coast Guard lacks measures that clearly 
demonstrate how this deterioration affects its ability to perform 
deepwater-related missions, it is clear that the deepwater legacy 
assets are insufficient for the task. 

* Second, although the need to replace and upgrade assets is strong, 
there still are major risks in the Coast Guard's acquisition approach. 
The cost increases and schedule slippages that have already occurred 
are warning signs. We will continue to work with the Coast Guard to 
determine how best to manage these risks so that the Deepwater missions 
can be accomplished in the most cost-effective way. 

* Third, there are signs that as the Deepwater program moves ahead, the 
Coast Guard will continue to report more problems with sustaining 
existing assets, together with the attendant need for additional 
infusions of funding to deal with them. Some of these problems, such as 
those on the 378-foot cutters, are included in the compendium the Coast 
Guard uses to set sustainment priorities and plan budgets, but have not 
been funded because they pertain to assets that are among the first to 
be replaced. However, projects to address these problems are 
nevertheless likely to be needed. We will continue to work with the 
Coast Guard to determine if there is a more systematic and 
comprehensive approach to keeping the Congress abreast of the potential 
bill for sustaining these assets. 

Mr. Chairman and Members of the Subcommittee, this completes my 
prepared statement. I would be happy to respond to any questions that 
you or other Members of the Subcommittee may have at this time. 

Contacts and Acknowledgements: 

For information about this testimony, please contact Margaret 
Wrightson, Director, Homeland Security and Justice Issues, at (415) 904-
2200, or wrightsonm@gao.gov. Other individuals making key contributions 
to this testimony include Steven Calvo, Jerry Clark, Christopher 
Conrad, Adam Couvillion, Michele Fejfar, Geoffrey Hamilton, Julie 
Leetch, Michele Mackin, Christopher Miller, Stan Stenersen, and Linda 
Kay Willard. 

FOOTNOTES

[1] For purposes of this testimony, we use the term "legacy assets" to 
refer to the existing fleet of deepwater aircraft and cutters. These 
legacy assets include the HC-130, HU-25, HH-60, and HH-65 aircraft and 
the 378-foot high-endurance cutters, the 210-foot and 270-foot medium-
endurance cutters, and the 110-foot and 123-foot patrol boats. We did 
not include the 213-foot Acushnet, the 230-foot Storis, or the 282-foot 
Alex Haley as part of our analyses of the deepwater legacy assets 
because they are one-of-a-kind vessels. 

[2] Intermediate-level and depot-level maintenance include repairs and 
upgrades that are too time-consuming or complicated to be performed at 
the unit level. For aircraft, this would include repairing, 
overhauling, or rebuilding parts, components, and end items, and 
emergency manufacturing of unavailable parts. For cutters, intermediate-
and depot-level maintenance would include preventive or corrective 
maintenance, as well as a major overhaul or complete rebuild of parts, 
assemblies, and end items; as well as major hull repairs, general 
modifications, and testing. 

[3] To assess the reliability of the Coast Guard's data and condition 
measures, we questioned knowledgeable officials and reviewed existing 
documentation about the data and the systems that produced the data. We 
determined that the data were sufficiently reliable for the purposes of 
this testimony. 

[4] In assessing the condition of deepwater aircraft and cutters for 
this testimony, we analyzed what Coast Guard officials told us were the 
best available condition measures. For deepwater aircraft, we reviewed 
the availability index (percentage of time aircraft were available to 
complete missions), cost per flight hour, labor hours per flight hour, 
programmed flight hours per year, scheduled versus unscheduled 
maintenance expenditures, and estimated deferred maintenance. For 
cutters, we reviewed the number of major casualties, the percent of 
time free of major casualties, scheduled versus unscheduled 
maintenance, and estimated deferred maintenance. We also reviewed data 
on mishaps and the dispatch reliability index for aircraft, and lost 
cutter days and unscheduled maintenance days for cutters. We did not 
use data on these measures, though, because the data were either not 
relevant to our analysis, incomplete, not available for the entire time 
period covered by our review, or not sufficiently reliable for our 
purposes. 

[5] GAO, Contract Management: Coast Guard's Deepwater Program Needs 
Increased Attention to Management and Contractor Oversight, GAO-04-380 
(Washington, D.C.: March 9, 2004). 

[6] Current plans call for the Coast Guard to replace all of its 
deepwater legacy cutters and patrol boats, beginning with the 378-foot 
cutters. The Coast Guard also plans to replace the HU-25 aircraft, but 
will upgrade the existing HC-130 aircraft and HH-60 and HH-65 
helicopters to extend their service lives. 

[7] The mission requirements include such things as the ability to (1) 
respond to 90 percent of all distress incidents within 2 hours; (2) 
detect and track targets of any material such that the probability of 
detection is at least 90 percent for small targets, such as a person in 
the water or a single-engine civil aircraft; and (3) respond to 
National Emergency Response Operations within 48 hours. 

[8] See GAO, Coast Guard: Deepwater Program Acquisition Schedule Update 
Needed, GAO-04-695 (Washington, D.C.: June 14, 2004); Coast Guard: Key 
Management and Budget Challenges for Fiscal Year 2005 and Beyond, GAO-
04-636T (Washington, D.C.: April 7, 2004); and GAO-04-380. 

[9] A casualty is a deficiency in mission essential equipment; a major 
casualty causes the major degradation or loss of at least one primary 
mission. 

[10] However, major casualties for the 378-foot high-endurance cutters 
continued to increase in 2004. 

[11] The Pacific Area Command is responsible for operations covering 74 
million square miles, ranging from South America, north to the Arctic 
Circle and west to the Far East. 

[12] GAO-04-380. 

[13] GAO-04-695. 

[14] Performance monitors are contracting officers' technical 
representatives, who represent the contracting officer in monitoring 
the contractor's performance. 

[15] GAO-04-695. 

[16] Not maintaining a current and integrated schedule lessens the 
Coast Guard's ability to monitor the integrator's performance and take 
early action to resolve risks that could become problems later. 
Maintaining such a schedule is an industry best practice; the 
Department of Defense is required to do so in order to be able to 
report any breaches in cost, schedule, or performance targets. 

[17] A "make item" means an item or work effort to be produced or 
performed by the prime contractor or its affiliates, subsidiaries, or 
divisions. 

[18] The C-130J missionization, planned for the Coast Guard's six C-
130J aircraft, is intended to modify and install mission-essential 
equipment to convert the aircraft into C-130J long-range surveillance 
maritime patrol aircraft. 

[19] Federal Acquisition Regulation §15.407-2, "Make or Buy Programs."