Defense Management
High-Level Leadership Commitment and Actions Are Needed to Address Corrosion Issues Gao ID: GAO-07-618 April 30, 2007Corrosion can have a deleterious effect on military equipment and infrastructure in terms of cost, readiness, and safety. Recognizing this concern, the Bob Stump National Defense Authorization Act of Fiscal Year 2003 required the Department of Defense (DOD) to designate an official or organization to oversee and coordinate efforts to prevent and mitigate corrosion. Recently, the National Defense Authorization Act of Fiscal Year 2006 directed GAO to examine the effectiveness of DOD's corrosion prevention and mitigation programs. In addition, GAO evaluated the extent to which DOD has incorporated corrosion prevention planning in acquiring weapon systems. GAO reviewed strategy documents, reviewed corrosion prevention planning for 51 recent major weapon system acquisitions, and interviewed DOD and military service officials.
DOD continues to have problems that hinder progress in implementing its corrosion prevention and mitigation strategy. While it has created a Corrosion Policy and Oversight Office, that office lacks the ability to oversee and coordinate its efforts throughout DOD, as envisioned by Congress. For example, DOD's office does not review all of the services' proposed funding requests for corrosion programs, even though it is required to do so, because DOD has not directed the services to provide such information and none of the services has a designated official or office to oversee and coordinate servicewide corrosion activities. Without comprehensive reviews of the services' corrosion-related programs and proposed funding requests, the office cannot fulfill its oversight and coordination role. DOD has made some progress in identifying corrosion cost impacts, but it has not identified readiness and safety impacts. It recently completed corrosion cost impact studies for Army ground vehicles and Navy ships, identifying an estimated $4.5 billion in annual corrosion costs. Although the studies provided potentially useful data for reducing these costs, DOD has not developed an action plan to apply these data to developing corrosion prevention and mitigation strategies. Without an action plan, it could miss opportunities to achieve long-term cost savings. DOD has not yet developed results-oriented metrics, although GAO has previously recommended that it do so. Without top DOD and service leadership commitment to address these issues, corrosion prevention and mitigation will remain elusive goals and opportunities to reduce costs, enhance readiness, and avoid safety problems will be lost. Most of the weapon system acquisition programs GAO reviewed had not incorporated key elements of DOD corrosion prevention guidance. GAO found that only 14 of the 51 programs reviewed had both corrosion prevention plans and advisory teams, as encouraged in the DOD guidance. The primary reason most programs did not have these two elements is that they are not mandatory. As a result, these programs may be missing opportunities to prevent and mitigate corrosion.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-07-618, Defense Management: High-Level Leadership Commitment and Actions Are Needed to Address Corrosion Issues
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
April 2007:
Defense Management:
High-Level Leadership Commitment and Actions Are Needed to Address
Corrosion Issues:
GAO-07-618:
GAO Highlights:
Highlights of GAO-07-618, a report to congressional committees
Why GAO Did This Study:
Corrosion can have a deleterious effect on military equipment and
infrastructure in terms of cost, readiness, and safety. Recognizing
this concern, the Bob Stump National Defense Authorization Act of
Fiscal Year 2003 required the Department of Defense (DOD) to designate
an official or organization to oversee and coordinate efforts to
prevent and mitigate corrosion. Recently, the National Defense
Authorization Act of Fiscal Year 2006 directed GAO to examine the
effectiveness of DOD‘s corrosion prevention and mitigation programs. In
addition, GAO evaluated the extent to which DOD has incorporated
corrosion prevention planning in acquiring weapon systems. GAO reviewed
strategy documents, reviewed corrosion prevention planning for 51
recent major weapon system acquisitions, and interviewed DOD and
military service officials.
What GAO Found:
DOD continues to have problems that hinder progress in implementing its
corrosion prevention and mitigation strategy. While it has created a
Corrosion Policy and Oversight Office, that office lacks the ability to
oversee and coordinate its efforts throughout DOD, as envisioned by
Congress. For example:
* DOD‘s office does not review all of the services‘ proposed funding
requests for corrosion programs, even though it is required to do so,
because DOD has not directed the services to provide such information
and none of the services has a designated official or office to oversee
and coordinate servicewide corrosion activities. Without comprehensive
reviews of the services‘ corrosion-related programs and proposed
funding requests, the office cannot fulfill its oversight and
coordination role.
* DOD has made some progress in identifying corrosion cost impacts, but
it has not identified readiness and safety impacts. It recently
completed corrosion cost impact studies for Army ground vehicles and
Navy ships, identifying an estimated $4.5 billion in annual corrosion
costs. Although the studies provided potentially useful data for
reducing these costs, DOD has not developed an action plan to apply
these data to developing corrosion prevention and mitigation
strategies. Without an action plan, it could miss opportunities to
achieve long-term cost savings.
* DOD has not yet developed results-oriented metrics, although GAO has
previously recommended that it do so.
Without top DOD and service leadership commitment to address these
issues, corrosion prevention and mitigation will remain elusive goals
and opportunities to reduce costs, enhance readiness, and avoid safety
problems will be lost.
Most of the weapon system acquisition programs GAO reviewed had not
incorporated key elements of DOD corrosion prevention guidance. GAO
found that only 14 of the 51 programs reviewed had both corrosion
prevention plans and advisory teams, as encouraged in the DOD guidance.
The primary reason most programs did not have these two elements is
that they are not mandatory. As a result, these programs may be missing
opportunities to prevent and mitigate corrosion.
Table: Corrosion Prevention Planning for Major Acquisition Programs:
Army;
Programs that have a corrosion prevention and control plan: Yes: 5;
Programs that have a corrosion prevention and control plan: No: 8;
Programs that have a corrosion prevention and control plan: Total: 13;
Programs that have a corrosion prevention advisory team: Yes: 5;
Programs that have a corrosion prevention advisory team: No: 8;
Programs that have a corrosion prevention advisory team: Total: 13.
Air Force;
Programs that have a corrosion prevention and control plan: Yes: 4;
Programs that have a corrosion prevention and control plan: No: 9;
Programs that have a corrosion prevention and control plan: Total: 13;
Programs that have a corrosion prevention advisory team: Yes: 5;
Programs that have a corrosion prevention advisory team: No: 8;
Programs that have a corrosion prevention advisory team: Total: 13.
Navy;
Programs that have a corrosion prevention and control plan: Yes: 11;
Programs that have a corrosion prevention and control plan: No: 14;
Programs that have a corrosion prevention and control plan: Total: 25;
Programs that have a corrosion prevention advisory team: Yes: 8;
Programs that have a corrosion prevention advisory team: No: 17;
Programs that have a corrosion prevention advisory team: Total: 25.
Total;
Programs that have a corrosion prevention and control plan: Yes: 20;
Programs that have a corrosion prevention and control plan: No: 31;
Programs that have a corrosion prevention and control plan: Total: 51;
Programs that have a corrosion prevention advisory team: Yes: 18;
Programs that have a corrosion prevention advisory team: No: 33;
Programs that have a corrosion prevention advisory team: Total: 51.
Source: GAO analysis of service data.
[End of table]
What GAO Recommends:
GAO is recommending that the Secretary of Defense and the Under
Secretary of Defense for Acquisition, Technology and Logistics ensure
that actions designed to effectively implement DOD‘s corrosion
prevention strategy are taken. In commenting on a draft of this report,
DOD partially concurred with GAO‘s four recommendations. DOD‘s actions
are generally responsive to the intent of GAO‘s recommendations.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-618].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact William Solis at (202)
512-8365 or solisw@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
DOD Continues to Have Problems That Hinder Progress in Implementing Its
Corrosion Prevention and Mitigation Strategy:
Most Major Defense Acquisition Programs We Reviewed Have Not
Incorporated Key Elements of Corrosion Prevention Planning:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Defense Science Board Recommendations:
Appendix II: Scope and Methodology:
Appendix III: Organizational Structure of DOD's Corrosion Activities:
Appendix IV: Corrosion Prevention Planning in Selected Major Defense
Acquisition Programs:
Appendix V: Comments from the Department of Defense:
Appendix VI: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Corrosion Cost Segments and Estimated Completion Dates:
Table 2: Number of Major Acquisition Programs Having Either a Corrosion
Prevention and Control Plan or a Corrosion Prevention Advisory Team:
Table 3: Number of Major Acquisition Programs Having Both a Corrosion
Prevention and Control Plan and a Corrosion Prevention Advisory Team
and Programs Having Neither a Plan Nor a Team:
United States Government Accountability Office:
Washington, DC 20548:
April 30, 2007:
Congressional Committees:
The Department of Defense (DOD) spends an estimated $10 billion to $20
billion each year on corrosion-related maintenance on weapon systems
and infrastructure. Corrosion can affect mission readiness by taking
critical systems out of action. It also affects safety. For example,
since 1985, the Army has reported over 50 aircraft accidents, including
12 fatalities, caused by corrosion. Incorporating corrosion prevention
planning early in the acquisition process is the most effective way to
reduce and perhaps avoid corrosion impacts in terms of costs, readiness
and safety.
In recognition of the harm that corrosion can cause, Congress enacted,
as part of the Bob Stump National Defense Authorization Act of Fiscal
Year 2003, legislation that requires DOD to designate a senior official
or organization responsible for preventing and mitigating the corrosion
of military equipment and infrastructure.[Footnote 1] The authorization
act requires the designated official or organization to oversee and
coordinate efforts throughout the department, recommend policy
guidance, and review the corrosion prevention and mitigation programs
and funding levels proposed by each military service that will enable
them to make recommendations to the Secretary of Defense. The
authorization act also requires the official to provide oversight and
coordination of the efforts within the Department to prevent or
mitigate corrosion throughout the life cycle of military equipment and
infrastructure and to monitor DOD acquisition practices to ensure that
corrosion prevention technologies and treatments are fully considered
during research and development phases of the acquisition process and
are incorporated in each acquisition program to the extent deemed
appropriate. In addition, the authorization act directs the Secretary
of Defense to develop and implement a long-term strategy to reduce
corrosion and the effects of corrosion on DOD's military equipment and
infrastructure. In response to this act, DOD created the Corrosion
Policy and Oversight Office (Corrosion Office) within the Office of the
Under Secretary of Defense for Acquisition, Technology, and Logistics
and in December 2003 developed a long-term strategy to reduce corrosion
of military equipment and infrastructure.[Footnote 2] As part of the
strategy, DOD is developing a corrosion baseline to identify the
effects of corrosion on cost, readiness, and safety.
Since the passage of the Defense Authorization Act of 2003, we have
issued several reports on corrosion. Among other things, we have found
that DOD and the services do not have an effective approach to prevent
and mitigate corrosion, DOD's long-term strategy falls short of a
comprehensive strategic plan, and the Army is not adequately storing
land-based pre-positioned equipment to protect it from
corrosion.[Footnote 3] In 2003, we recommended that DOD develop a
strategic plan for corrosion prevention and mitigation that included
standardized methodologies for collecting and analyzing corrosion cost,
readiness, and safety data; clearly defined goals, outcome-oriented
objectives, and performance measures; identification of the level of
resources needed to accomplish goals and objectives; and mechanisms to
coordinate and oversee prevention and mitigation projects across the
department. In 2004 we further recommended that DOD accelerate
completion of its corrosion baseline, establish a funding mechanism to
implement the corrosion strategy, and submit to Congress a report
identifying the long-term funding and personnel resources needed to
implement the strategy. DOD concurred with all of these
recommendations.
In response to a request of the Under Secretary of Defense for
Acquisition, Technology, and Logistics, the Defense Science Board
issued a report in October 2004 on DOD's efforts for corrosion control,
referring to "the importance of leadership commitment and proper
incentives for ensuring corrosion is considered early and often in
decisions" and calling for an increased commitment on the part of DOD
to prevent and mitigate corrosion.[Footnote 4] This report found that
corrosion prevention has not been a priority across DOD, and it made 17
recommendations, most of which DOD concurred with. Specifically, DOD
concurred on 11, partially concurred on 4, and did not concur on 2.
Appendix I contains a complete list of Defense Science Board
recommendations and DOD's responses. Of the recommendations with which
DOD concurred, it has taken actions to incorporate some into its
strategy document and to begin implementing some of those. According to
our assessment, only minimal changes have been made to DOD's corrosion
strategy in response to the recommendations contained in the report of
the Defense Science Board.
The National Defense Authorization Act of Fiscal Year 2006 directed us
to examine the effectiveness of DOD's corrosion prevention and
mitigation programs.[Footnote 5] Specifically, we examined the extent
to which DOD has implemented its corrosion strategy in its oversight of
funding; its identification of cost, readiness, and safety impacts
through its corrosion baseline study; and its development of results-
oriented metrics. In addition, as agreed with your offices, we
evaluated the extent to which DOD has incorporated corrosion prevention
planning in the acquisition of major weapon systems.
In performing our work, we used the requirements for the DOD corrosion
strategy set forth in the Bob Stump National Defense Authorization Act
of Fiscal Year 2003, along with our previous recommendations, as a
baseline for evaluating DOD's corrosion prevention efforts. We reviewed
DOD and service guidance relating to corrosion prevention, and we
interviewed officials from the Office of the Secretary of Defense
(OSD), the Army, the Air Force, and the Navy. We also gathered and
reviewed information about corrosion prevention planning from a
nonprobability sample of 51 major defense acquisition programs. The
sample was based on the programs contained in DOD's Fiscal Year 2006
Major Defense Acquisition Program List.[Footnote 6] We reviewed
documents from these programs, including their acquisition plans and
corrosion prevention plans. A detailed description of our scope and
methodology is presented in appendix II. We conducted our work from
April 2006 through January 2007 in accordance with generally accepted
government auditing standards.
Results in Brief:
While DOD has taken some steps toward implementing its corrosion
prevention strategy since our 2003 and 2004 reports, its progress in
providing oversight of funding, identifying corrosion impacts, and
developing results-oriented metrics has been limited. For example:
* With regard to funding, the Corrosion Office does not review all of
the services' proposed funding requests related to prevention and
mitigation of corrosion, even though such reviews are required by 10
U.S.C. § 2228(b)(3). DOD has not directed the services to provide the
Corrosion Office with comprehensive data on their annual funding
requirements for corrosion prevention and mitigation. Furthermore, none
of the four services has a designated official or office to oversee and
coordinate servicewide corrosion activities, including identifying
annual funding requirements. Without comprehensive reviews of the
services' corrosion-related programs and proposed funding requests, the
Corrosion Office cannot fulfill its oversight and coordination role for
the department.
* With regard to developing a corrosion baseline, DOD has made some
progress in identifying cost impacts but has not identified readiness
and safety impacts. DOD has acknowledged that determining these impacts
is critical to implementing its corrosion strategy and assessing
progress. DOD accelerated the time frames for completing the overall
cost study and recently completed corrosion cost impact studies for two
segments of its corrosion baseline--Army ground vehicles and Navy
ships. Although these two cost impact studies provide potentially
useful data for reducing the estimated $4.5 billion in annual corrosion
costs, DOD has not developed an action plan to apply these data toward
developing corrosion prevention and mitigation strategies. Without an
action plan, DOD could miss opportunities for achieving long-term
corrosion cost savings. DOD officials told us that they decided to
identify cost impacts before they identify readiness and safety impacts
because more information is available regarding costs and identifying
cost impacts is an important step towards identifying readiness and
safety impacts.
* DOD has not yet developed results-oriented metrics that would provide
the capability to measure progress toward reducing corrosion impacts,
although we and Defense Science Board have previously recommended that
it do so. DOD asserts that it cannot establish such metrics until it
has first identified the corrosion impacts--yet, as stated above, DOD
has made only minimal progress in the identification of these impacts.
The lack of results-oriented metrics impedes DOD's ability to implement
its corrosion strategy.
Without top DOD and service leadership commitment to address these
issues, corrosion prevention and mitigation will remain an elusive
goal, and opportunities to reduce costs, enhance readiness, and avoid
safety problems will be lost.
Most of the weapon system acquisition programs we reviewed had not
incorporated key elements of corrosion prevention planning. Of the 51
recent major acquisitions we reviewed, only 14 had both corrosion
prevention plans and advisory teams. The guidebook created by the
Corrosion Office encourages weapon system acquisition programs to
incorporate corrosion prevention and control plans and advisory teams
in order to achieve viable corrosion prevention and control planning.
DOD acquisition program officials retain broad discretion in developing
individual approaches to corrosion prevention planning, and many
different approaches are taken within and among the services. However,
27 of the 51 programs we reviewed had not included either of the two
key elements of corrosion prevention planning. Most programs did not
have corrosion prevention plans or corrosion prevention advisory teams
in part because these plans and teams are not mandatory. As a result,
the Corrosion Office could not effectively monitor DOD acquisition
practices, as required by 10 U.S.C. § 2228(b)(5), to ensure that
corrosion prevention technologies and techniques were being fully
considered and incorporated when deemed appropriate. Moreover, these
programs may be missing opportunities to prevent future corrosion and
therefore mitigate the impacts of corrosion on the costs, readiness,
and safety of military equipment.
We are making recommendations designed to improve DOD's and the
services' efforts to prevent and mitigate corrosion. In commenting on a
draft of this report, DOD partially concurred with our recommendations.
In its response, DOD cited actions it planned to take which are
generally responsive to our recommendations. In addition, the
department provided several technical comments which we considered and
incorporated where appropriate. DOD's comments and our evaluation of
them appear later in this report.
Background:
The Principal Deputy Under Secretary of Defense for Acquisition,
Technology, and Logistics has been designated DOD's Corrosion
Executive. The Corrosion Executive is supported by staff assigned to
the Corrosion Office. The Corrosion Office was initially established in
2003 as an independent activity within the Office of the Under
Secretary of Defense for Acquisition, Technology, and Logistics,
reporting directly to the Corrosion Executive.[Footnote 7] In 2004, the
Corrosion Office was formally assigned to the Defense Systems
Directorate. The direct chain of command went through the Defense
Systems Directorate, which provided management and administrative
support. Following a reorganization of the Acquisition, Technology, and
Logistics organization in 2006, the Corrosion Office was moved to the
Systems and Software Engineering Directorate. The Corrosion Office no
longer reports directly to the Corrosion Executive. Appendix III
depicts DOD's organizational structure to address corrosion.
The Corrosion Office is led by the Special Assistant for Corrosion
Policy and Oversight and works closely with the Corrosion Prevention
and Control Integrated Product Team, which has representatives from the
military services and other DOD organizations to accomplish the goals
and objectives of the Corrosion Office. Several working teams have also
been established to conduct work in the seven areas making up the
corrosion strategy: policy and requirements; impact, metrics, and
sustainment; science and technology; communications and outreach;
facilities; training and doctrine; and specifications, standards, and
product qualification.
The Defense Acquisition Guidebook[Footnote 8] contains guidance
regarding the defense acquisition system, which exists to manage the
nation's investments in technologies, programs, and product support
necessary to achieve the National Security Strategy and support the
United States Armed Forces. This guidebook contains specific guidance
regarding acquisition strategies, which define the approach a program
manager will use to achieve program goals. Among other things, an
effective strategy minimizes the time and cost required to satisfy
approved capability needs. DOD's directive on the defense acquisition
process states that program managers shall consider corrosion
prevention and mitigation when making trade-off decisions that involve
cost, useful service, and effectiveness.[Footnote 9] Moreover, on
November 12, 2003, the Under Secretary of Defense for Acquisition,
Technology, and Logistics issued a policy memorandum stating that
corrosion prevention should be specifically addressed at the earliest
phases of the acquisition process by decision authorities at every
level.[Footnote 10]
DOD Continues to Have Problems That Hinder Progress in Implementing Its
Corrosion Prevention and Mitigation Strategy:
DOD has had long-standing problems in funding, identification of
impacts, and development of metrics, and these are continuing. DOD's
implementation of its long-term corrosion strategy, as required under
10 U.S.C. § 2228(c), has been hindered by weaknesses in these three
critical areas. First, the Corrosion Office does not review the
services' corrosion programs or annual budget requests, even though
this is required by 10 U.S.C. § 2228(b)(3). Second, the Corrosion
Office has made only minimal progress in identifying corrosion impacts.
Third, the Corrosion Office has not developed results-oriented metrics,
even though we have previously recommended that it do so.
DOD's Corrosion Office Does Not Review All of the Military Services'
Funding Requests:
Although 10 U.S.C. § 2228(b)(3) requires the Corrosion Office within
OSD to review the annual funding requests for the prevention and
mitigation of corrosion for each military service, the Corrosion Office
has not done so. The Corrosion Office does not review comprehensive
corrosion data from the services on their programs and funding requests
because (1) DOD has not required the services to provide budget
information to the Corrosion Office and (2) the services lack an
effective mechanism for coordinating with the Corrosion Office with
respect to their corrosion funding requests. None of the four services
has a designated official or office to oversee and coordinate corrosion
activities, including identifying annual servicewide funding
requirements. Without a requirement or mechanism for reporting service
funding information, the Corrosion Office officials said they are
unable to review the services' complete corrosion-related funding
information, and thus DOD is hampered in its ability to provide
oversight of the services' funding requests.
The Corrosion Office currently has oversight over only a small portion
of departmentwide corrosion spending that is provided through a
separate appropriations account. The Corrosion Office reviews and
selects for funding the projects that are proposed by the services
based on a combination of criteria, including: whether a project would
benefit more than one service, whether it is projected to be completed
within 2 years of its initial funding, the availability of matching
funds; and the return on investment that it offers. For fiscal year
2006, DOD and the military services funded about $24 million for
corrosion strategy efforts. Of this amount, $19 million was spent on 29
corrosion-related projects and about $5 million on contractor support,
training, outreach, and other administrative activities. The DOD
Corrosion Office projects a combined average return on investment of
42.5 to 1 for the $19 million, or a projected savings of $809 million
over the life of the projects.
The services frequently bypass the Corrosion Office to obtain their
funding for corrosion-related efforts. We reviewed the President's
budget justification for fiscal year 2006 and identified more than $97
million for service-specific corrosion mitigation-related projects in
addition to those reviewed by the Corrosion Office. These projects had
not been submitted to the Corrosion Office for review, and Corrosion
Office officials told us that they lacked any information about the $97
million and the status of the associated efforts. Because corrosion-
related projects may be included under other maintenance projects or
budget accounts, it is likely that there is more funding that we have
not identified. According to recent corrosion cost studies conducted by
DOD, the annual corrosion costs for Army ground vehicles and Navy ships
alone were identified to be $2.019 billion and $2.438 billion,
respectively. Without comprehensive reviews of the services' corrosion-
related programs and proposed funding requests, the Corrosion Office
cannot fulfill its oversight and coordination role for the department.
None of the four services has a designated official or office to
oversee and coordinate corrosion activities, despite a recommendation
by the Defense Science Board that they do so. Currently, multiple
offices in the services are responsible for corrosion programs and
related budgets. For example, several Air Force offices are responsible
for corrosion-related matters: maintenance issues belong to the Air
Force Corrosion Prevention and Control Office, corrosion policy for
weapon systems is managed by an office within the Air Force Maintenance
Directorate, and corrosion policy for infrastructure is handled by the
Air Force Civil Engineering Directorate. None of these offices has
comprehensive knowledge about corrosion activities throughout the Air
Force. Without a designated official or office for corrosion, the
services do not have the mechanism or capability to fully identify
their annual servicewide corrosion funding requirements.
Progress in Identifying Corrosion Impacts Has Been Minimal:
DOD has acknowledged since 2002 that the identification of cost,
readiness, and safety impacts is critical to the implementation of its
corrosion strategy. We recommended in 2003 that DOD complete a study to
identify these impacts, and further recommended in 2004 that DOD
accelerate its efforts in order to complete the baseline prior to its
original estimated date of 2011. According to DOD, the purpose of the
study is to document where corrosion problems exist, identify their
causes, and prioritize them for funding according to their relative
severity in terms of their impact on DOD costs, readiness, and safety.
In August 2004, after developing a cost-estimating methodology, a DOD
contractor began a study to determine the total cost of corrosion for
military equipment and facilities across the services. DOD currently
plans to complete this cost study by 2009, 2 years earlier than
originally planned. The study uses fiscal year 2004 costs as a
measurement baseline and consists of several segments, to be completed
sequentially. To date, it has made some progress in identifying
corrosion cost impacts. For example, in April 2006, DOD completed the
Army ground vehicle and Navy ship corrosion segments of this
study.[Footnote 11] Several segments remain to be completed, including
Army and Marine Corps aviation. Corrosion Office officials told us that
progress has been slower than expected, primarily because of a lack of
corrosion data. Table 1 shows the corrosion cost segments included in
the study and their planned completion dates.
Table 1: Corrosion Cost Segments and Estimated Completion Dates:
Corrosion cost segments: Army ground vehicles;
Estimated completion date: 2006 (actual).
Corrosion cost segments: Navy ships;
Estimated completion date: 2006 (actual).
Corrosion cost segments: DOD facilities;
Estimated completion date: 2007 (planned).
Corrosion cost segments: Army aviation and missiles;
Estimated completion date: 2007 (planned).
Corrosion cost segments: USMC ground vehicles;
Estimated completion date: 2007 (planned).
Corrosion cost segments: Navy and USMC aviation;
Estimated completion date: 2008.
Corrosion cost segments: Coast Guard aviation and ships;
Estimated completion date: 2008.
Corrosion cost segments: Air Force aviation and missiles;
Estimated completion date: 2009.
Source: LMI Government Consulting.
[End of table]
The two completed studies generated data that could be potentially
useful for developing initiatives aimed at reducing long-term corrosion
costs, but DOD lacks an action plan for using these data. For example,
the studies estimate the annual corrosion costs for Army ground
vehicles and Navy ships at $2.019 billion and $2.438 billion,
respectively. Costs are segregated in multiple ways, such as costs
incurred at the depot, organizational, and intermediate maintenance
levels; costs incurred while addressing a corrosion problem
(corrective); costs incurred while addressing a potential problem
(preventive); and direct costs incurred on end items or removable
parts. However, the Corrosion Office has not developed an action plan
on how it will use these data, or the data expected from future cost
studies, to develop corrosion prevention and mitigation strategies.
Without an action plan, DOD could miss opportunities for achieving long-
term corrosion cost savings.
Finally, although it acknowledges the importance of identifying
corrosion impacts related to readiness and safety, DOD has made
virtually no progress in assessing these impacts. DOD officials told us
that they decided to identify cost impacts before they identify
readiness and safety impacts because more information is available
regarding costs, and identifying cost impacts is an important step
towards identifying readiness and safety impacts. They said that some
of their efforts will shift to readiness and safety as the cost impact
study approaches completion.
DOD Has Not Yet Developed Results-Oriented Corrosion Metrics:
In June 2004, we reported that DOD lacked results-oriented metrics in
its corrosion strategy and, as a result, could not effectively monitor
progress toward achieving the goals of the corrosion strategy. In May
2005, DOD updated its November 2004 long-term corrosion strategy, but
the update still does not contain results-oriented metrics for
measuring progress toward targeted, quantifiable goals. In the strategy
update, DOD has catalogued the aspects of corrosion prevention cost,
readiness, and safety impacts that will need to be measured, but it has
not quantified them or linked them with targets for improvement. For
example, on a table entitled "Potential Revised Metrics Set", under the
column of safety impacts, the "facilities incidents" entry is linked
with the description "events over time related to corrosion." No
measurable outcomes are associated with either the designated impact or
the description. In addition, DOD officials told us that they cannot
establish quantifiable goals regarding corrosion costs until they have
completed the corrosion cost baseline, which, as noted earlier, DOD
plans to complete sometime in 2009. These officials said that metrics
for readiness and safety will likely take several additional years to
complete because less information is available regarding readiness and
safety impacts than information regarding cost impacts. They told us
that the accompanying definitions and procedures will also take several
years to complete.
Most Major Defense Acquisition Programs We Reviewed Have Not
Incorporated Key Elements of Corrosion Prevention Planning:
The Corrosion Prevention and Control Planning Guidebook encourages the
establishment of corrosion prevention and control plans and corrosion
prevention advisory teams as early as possible in the acquisition
process. However, only 14 of the 51 programs we reviewed actually had
both plans and advisory teams. DOD acquisition program officials have
taken diverse approaches to corrosion prevention planning. We found
that one reason why most programs did not have corrosion prevention
plans or corrosion prevention advisory teams is that while they are
strongly suggested, these elements are not mandatory.
DOD Guidance Encourages Corrosion Prevention Plans and Advisory Teams:
The guidebook developed by the Corrosion Office is intended to assist
acquisition program managers in developing and implementing effective
corrosion prevention and control programs for military equipment and
infrastructure.[Footnote 12] According to the Corrosion Prevention and
Control Guidebook, the corrosion prevention and control plan and the
corrosion prevention advisory team should be established as early as
possible in the acquisition process. DOD officials told us that
establishing both a plan and a team is critical to effective corrosion
prevention planning, and they strongly recommend that corrosion
prevention planning begin at the start of the technology development
phase of acquisition (Milestone A), when the effort is made to
determine the appropriate set of technologies to be integrated into the
weapon system. They said it should certainly occur no later than the
system development and demonstration phase (Milestone B), when the
first system and long lead procurement for follow-on systems may be
authorized. According to the guidebook, a corrosion prevention and
control plan should address a number of things, including system
design, including materials and processes to be used for corrosion
prevention and control, and should define the membership and
organization of the corrosion prevention advisory team. The team should
be actively involved in the review of design considerations, material
selections, costs, and any documentation that may affect corrosion
prevention and control throughout the life cycle of the system or
facility. Members should include representatives from the contractors
and DOD. In addition to this DOD guidance, the individual services have
issued guidance that also calls for incorporating corrosion prevention
planning during acquisition of weapon system programs.[Footnote 13]
Few Programs Have Both Corrosion Plans and Teams:
Most of the acquisition programs we reviewed did not have either plans
or advisory teams for corrosion prevention and control. We reviewed a
nonprobability sample of 51 major defense acquisition programs from the
Army, Navy, and Air Force and found that only 14 of them had both
corrosion prevention and control plans and corrosion prevention
advisory teams.[Footnote 14] A total of 20 programs had developed
corrosion prevention and control plans, and 18 had established advisory
teams. Of the 51 programs, 27 had neither a plan nor an advisory team.
Tables 2 and 3 list, by service, the number of programs we reviewed
that had developed corrosion prevention and control plans and
established corrosion prevention advisory teams. Appendix IV contains
information on specific programs that we reviewed.
Table 2: Number of Major Acquisition Programs Having Either a Corrosion
Prevention and Control Plan or a Corrosion Prevention Advisory Team:
Army;
Programs that have a corrosion prevention and control plan: Yes: 5;
Programs that have a corrosion prevention and control plan: No: 8;
Programs that have a corrosion prevention and control plan: Total: 13;
Programs that have a corrosion prevention advisory team: Yes: 5;
Programs that have a corrosion prevention advisory team: No: 8;
Programs that have a corrosion prevention advisory team: Total: 13.
Air Force;
Programs that have a corrosion prevention and control plan: Yes: 4;
Programs that have a corrosion prevention and control plan: No: 9;
Programs that have a corrosion prevention and control plan: Total: 13;
Programs that have a corrosion prevention advisory team: Yes: 5;
Programs that have a corrosion prevention advisory team: No: 8;
Programs that have a corrosion prevention advisory team: Total: 13.
Navy;
Programs that have a corrosion prevention and control plan: Yes: 11;
Programs that have a corrosion prevention and control plan: No: 14;
Programs that have a corrosion prevention and control plan: Total: 25;
Programs that have a corrosion prevention advisory team: Yes: 8;
Programs that have a corrosion prevention advisory team: No: 17;
Programs that have a corrosion prevention advisory team: Total: 25.
Total;
Programs that have a corrosion prevention and control plan: Yes: 20;
Programs that have a corrosion prevention and control plan: No: 31;
Programs that have a corrosion prevention and control plan: Total: 51;
Programs that have a corrosion prevention advisory team: Yes: 18;
Programs that have a corrosion prevention advisory team: No: 33;
Programs that have a corrosion prevention advisory team: Total: 51.
Source: GAO analysis of service data.
[End of table]
Table 3: Number of Major Acquisition Programs Having Both a Corrosion
Prevention and Control Plan and a Corrosion Prevention Advisory Team
and Programs Having Neither a Plan Nor a Team:
Army;
Programs having both a corrosion prevention and control plan and a
corrosion prevention advisory team: 4;
Programs having neither a corrosion prevention and control plan or
corrosion prevention advisory team: 7.
Air Force;
Programs having both a corrosion prevention and control plan and a
corrosion prevention advisory team: 4;
Programs having neither a corrosion prevention and control plan or
corrosion prevention advisory team: 8.
Navy;
Programs having both a corrosion prevention and control plan and a
corrosion prevention advisory team: 6;
Programs having neither a corrosion prevention and control plan or
corrosion prevention advisory team: 12.
Total;
Programs having both a corrosion prevention and control plan and a
corrosion prevention advisory team: 14;
Programs having neither a corrosion prevention and control plan or
corrosion prevention advisory team: 27.
Source: GAO analysis of service data.
[End of table]
Service Acquisition Officials Cite Diverse Approaches Taken to
Corrosion Prevention Planning:
Service acquisition officials told us that they retain broad discretion
in developing individual approaches to corrosion prevention planning.
We found that planning is inconsistently performed, and that so many
different approaches are taken within and among the services that DOD
is unable to maintain the oversight needed to ensure that corrosion
prevention is being effectively conducted. For example, the degree to
which corrosion prevention planning is performed depends on the
initiative of the respective acquisition program offices. The Air
Force's C-17A Globemaster program had a corrosion prevention plan and
corrosion prevention team in place early in the acquisition process,
several months before it obtained approval to proceed with full-scale
development. C-17 officials told us that they took a proactive approach
to avoid the corrosion problems experienced by the C-5 and KC-135
programs. In contrast, the Javelin program managed by the Army has not
established a corrosion prevention plan or corrosion prevention team,
even though the system development and most of its production
objectives have been completed. Javelin program officials told us that
they have extensive corrosion prevention requirements in the system
development specification and have obtained the advice of corrosion
prevention experts located at the Aviation and Missile Research and
Development Center.
Further, some program officials told us that specific corrosion
prevention plans and corrosion advisory teams were not needed because
other documents and processes provide the same function. The Navy's SSN
774 Class submarine program did not have a specific corrosion
prevention plan or corrosion prevention advisory team because the
program relied heavily on detailed specifications and technical
documents and on the experience of similarly designed
submarines.[Footnote 15]
Officials from some programs said it was too early in the acquisition
process for them to have a plan or team, while those from other
programs claimed it was too late. The Air Force KC-135 Replacement
program officials told us they do not have a corrosion prevention plan
or team because their system is still in the early development phase
and they have yet to establish firm dates for their program design
reviews. In contrast, Army High Mobility Artillery Rocket System
program officials said that it is not sensible to have a corrosion
prevention plan or team at this time because their program is currently
in full rate production.
Some programs we reviewed did not have a corrosion prevention plan or
team because program officials told us that upgrades to existing weapon
systems may be covered by an existing corrosion prevention plan or
team. On the one hand, the Airborne Warning and Control System Block
40/45 upgrade program is a modification to the prime mission equipment
of the E-3 aircraft. This program does not have its own corrosion
prevention and control team or corrosion prevention advisory team, but
rather is covered by the existing plan and team for the E-3 aircraft.
On the other hand, a different Air Force program we reviewed represents
an upgrade to the avionics system of the existing C-5 aircraft, and its
officials told us that corrosion prevention issues are more
appropriately addressed at the C-5 aircraft program level. These
officials told us that while the C-5 program has an existing corrosion
prevention advisory team, it does not currently have a current
corrosion prevention plan, though one is under development and expected
to be completed at the end of May 2007.
We found that one reason most programs have not prepared corrosion
prevention plans or established corrosion prevention advisory teams is
that these elements are not mandatory. Major acquisition programs
perform corrosion prevention planning at their discretion, and that may
or may not include having a corrosion prevention plan, a corrosion
prevention advisory team, or both. Further, these programs are not
required to provide the Corrosion Office information regarding
corrosion prevention planning. As a result, the Corrosion Office could
not effectively monitor DOD acquisition practices to ensure that
corrosion prevention technologies and techniques are being fully
considered and incorporated when appropriate. Moreover, these programs
may be missing opportunities to prevent future corrosion and thereby
mitigate the impacts of corrosion on the costs, readiness, and safety
of military equipment.
Conclusions:
More than 4 years have passed since Congress enacted legislation
requiring DOD to establish a corrosion prevention and mitigation
program, yet DOD has not met Congress's expectations. Since the passage
of this legislation, we have issued several reports on corrosion and
made numerous recommendations to strengthen DOD's ability to combat
corrosion. Further, the Defense Science Board has called for an
increased commitment on the part of DOD to prevent and mitigate
corrosion, referring to "the importance of leadership commitment and
proper incentives for ensuring corrosion is considered early and often
in decisions."[Footnote 16]
DOD's progress in implementing its corrosion strategy has been stymied
by critical weaknesses. These include the absence of DOD guidance
directing the services to provide the Corrosion Office with
comprehensive data about their annual funding requirements for
corrosion prevention and mitigation, the absence of a designated
corrosion official or corrosion office within each of the services, and
the absence of a DOD action plan to guide use of data in the corrosion
cost study to achieve long-term cost savings. Furthermore, the lack of
a DOD requirement for all major defense acquisition programs to have
both a corrosion prevention plan and a corrosion prevention team could
lead to inadequate corrosion prevention and, consequently, long-term
corrosion problems throughout the life cycle of weapon systems. These
and other weaknesses that we have raised in our previous reports
severely hinder DOD's ability to combat corrosion. Without top DOD and
service leadership commitment to addressing these issues, corrosion
prevention and mitigation will remain an elusive goal and opportunities
to reduce costs, enhance readiness, and avoid safety problems will be
lost.
Recommendations for Executive Action:
To effectively implement DOD's corrosion strategy and meet
congressional expectations expeditiously, we recommend that the
Secretary of Defense and the Under Secretary of Defense for
Acquisition, Technology, and Logistics provide the necessary leadership
and commitment to take the following four actions.
To ensure that DOD's Corrosion Office provides oversight and
coordination of the services' proposed funding requests for corrosion
prevention and mitigation programs, we recommend that the Secretary of
Defense:
* Direct the Under Secretary of Defense for Acquisition, Technology,
and Logistics to require the military services to provide comprehensive
data about their annual funding requirements for corrosion prevention
and mitigation efforts to the DOD Corrosion Office, before annual
funding requests are sent to Congress.
* Direct the Secretaries of the Army, Navy, and Air Force to designate
a corrosion official or a corrosion office within each service that is
responsible for corrosion prevention and mitigation, and that the
responsibilities of this official or office include identifying the
annual funding requirements for corrosion prevention and mitigation
efforts throughout the service.
To ensure that DOD does not miss opportunities for achieving long-term
corrosion cost savings, we recommend that the Secretary of Defense:
* Direct the Under Secretary of Defense for Acquisition, Technology,
and Logistics to develop an action plan for using the information
contained in the Army ground vehicle and Navy ship segments of DOD's
cost impact study. This plan should be completed as expeditiously as
possible and be updated in time to support the fiscal year 2009 budget
request. This plan should include information on corrosion cost areas
having the highest priority and a strategy for reducing these costs.
DOD should develop comparable action plans for the information to be
derived from cost segments completed in the future.
To improve DOD's ability to avoid or limit corrosion problems
experienced by weapon systems, we recommend that the Secretary of
Defense:
* Require major defense acquisition programs to prepare a corrosion
prevention plan and establish a corrosion prevention advisory team as
early as possible in the acquisition process.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, DOD partially concurred
with each of our four recommendations. In its response, DOD cited
actions it planned to take which are generally responsive to our
recommendations. In addition, the department provided several technical
comments which we considered and incorporated where appropriate. DOD's
comments are reprinted in appendix V.
DOD partially concurred with our recommendation to require the military
services to provide comprehensive data about their annual funding
requirements for corrosion prevention and mitigation efforts to the DOD
Corrosion Office before annual funding requests are sent to Congress.
DOD stated that a draft Corrosion Prevention and Control Department of
Defense Instruction will require the military departments during the
annual internal DOD budget process to submit information on the
proposed corrosion programs and funding levels to the DOD Corrosion
Executive. We believe this action is long overdue and is a step in the
right direction if implemented. However, it remains uncertain when the
instruction will be approved and what it will look like when finalized.
Although the instruction was expected to be approved in November 2006,
according to DOD officials, it is still undergoing revision. In
addition, the draft instruction, as it is currently written, does not
provide enough detail regarding the identification and submission of
comprehensive data for funding associated with all corrosion prevention
and mitigation efforts throughout DOD. For example, the draft
instruction does not specify the type of funding information that is to
be obtained by the services and reported to the DOD Corrosion Office.
DOD also commented that corrosion prevention and mitigation activities
are funded through many different sources, no program elements exist in
the military departments that directly tie to corrosion, and many
activities are funded to complete corrosion-related work but are not
identified as such in budget documents. However, as we stated in our
report, we reviewed the President's budget justification for fiscal
year 2006 and were able to readily identify more than $97 million for
service-specific corrosion mitigation-related projects for which the
Corrosion Office lacked any information.
DOD partially concurred with our recommendation that the Secretaries of
the Army, Navy, and Air Force designate a corrosion official or a
corrosion office within each service to be responsible for corrosion
prevention and mitigation, and that the responsibilities of this
official or office should include identifying the annual funding
requirements for corrosion prevention and mitigation efforts throughout
the service. DOD stated that the same draft DOD Instruction cited in
response to the first recommendation also specifies that the heads of
DOD components shall designate a senior individual or office for
oversight of corrosion matters, and it directs the Secretaries of the
military departments to support this individual or office. DOD stated
that the Air Force has already designated such an official. The draft
instruction as it pertains to each service having a corrosion executive
or a corrosion office responsible for corrosion prevention and
mitigation is responsive to our recommendation if implemented.
DOD partially concurred with our recommendation to develop an action
plan for using the information contained in the Army ground vehicle and
Navy ship segments of DOD's cost impact study. In response, DOD stated
that it would be impractical to develop an action plan in time to be
used for the 2008 budget cycle. While our recommendation was intended
for DOD to develop an action plan as soon as possible to support near-
term funding decisions for corrosion prevention and mitigation efforts,
we agree that DOD can not do this in time to be used for the 2008
budget cycle. Therefore, we have modified our recommendation to say
that DOD develop an action plan as expeditiously as possible and revise
the plan in time to support the fiscal year 2009 budget request. DOD
also stated that the DOD Corrosion Prevention and Mitigation Strategic
Plan already includes a requirement to select and fund corrosion
research projects and integrated product team activities to enhance and
improve corrosion prevention and mitigation throughout DOD. DOD further
stated that the Military Departments assess and make priorities
regarding corrosion based, in part, on funding for the "Top Ten" high
cost of corrosion-vulnerable systems. While these efforts may have
merit, we still believe that an action plan would provide additional
benefits as we recommend.
DOD partially concurred with our recommendation to require every major
defense acquisition program to prepare a corrosion prevention plan and
establish a corrosion prevention advisory team as early as possible in
the acquisition process. DOD stated that a corrosion prevention control
plan will be developed for all ACAT I programs before preliminary
design review and implementation will be reviewed at each milestone.
DOD noted that the establishment of a separate, formal Corrosion
Prevention Advisory Team may not be necessary for all program levels,
though such a team will be established for all ACAT I programs. DOD's
response is essentially responsive to our recommendation if carried
out. In subsequent discussions DOD officials told us that they
partially concurred because the response in some respects goes beyond
our recommendation by requiring that all ACAT I programs have a
corrosion prevention control plan and corrosion prevention advisory
team.
In addition to providing comments to our recommendations, DOD commented
about our statement that the development of metrics for readiness and
safety will likely take several additional years to complete because
DOD officials have placed a higher priority on completing the cost
impact studies. DOD commented that this is an inaccurate and dangerous
assertion and implies that the department holds safety and readiness,
the two linchpins of the operation military mind-set, in lower esteem
than cost. In subsequent discussions, DOD officials told us that they
decided to identify cost impacts before they identify readiness and
safety impacts because more information is available regarding costs,
and identifying cost impacts is an important step towards identifying
readiness and safety impacts. We have modified our report by
incorporating this statement.
We are sending copies of this report to the Secretary of Defense and
interested congressional committees. We will also make copies available
to others upon request. This report will also be available at no charge
on GAO's Web site at http://www.gao.gov.
If you or your staff have any questions regarding this report, please
contact me at (202) 512-8365 or solisw@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to
this report are listed in appendix VI.
Signed by:
William M. Solis, Director:
Defense Capabilities and Management:
List of Committees:
The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Minority Member:
Committee on Armed Services:
United States Senate:
The Honorable Daniel Inouye:
Chairman:
The Honorable Ted Stevens:
Ranking Minority Member:
Subcommittee on Defense:
Committee on Appropriations:
United States Senate:
The Honorable Ike Skelton:
Chairman:
The Honorable Duncan Hunter:
Ranking Minority Member:
Committee on Armed Services:
House of Representatives:
The Honorable John P. Murtha:
Chairman:
The Honorable C.W. Bill Young:
Ranking Minority Member:
Subcommittee on Defense:
Committee on Appropriations:
House of Representatives:
[End of section]
Appendix I: Defense Science Board Recommendations:
Defense Science Board recommendation: Create an independent team of
corrosion experts to review all programs coming to the Defense
Acquisition Board and all maintenance plans to provide the expertise
necessary to decision makers;
DOD response: Partially concur.
Defense Science Board recommendation: Develop incentive structures to
ensure corrosion and life cycle cost considerations in all designs and
manufacturing;
DOD response: Concur.
Defense Science Board recommendation: Mandate corrosion testing and
reporting at all stages of development;
DOD response: Concur.
Defense Science Board recommendation: Issue directive to require that
all major weapon system corrosion prevention advisory team members
complete a Defense Acquisition University-developed course on corrosion
control;
DOD response: Concur.
Defense Science Board recommendation: Accelerate the introduction of
activity based cost accounting to ensure future visibility into actual
life cycle cost and cost of corrosion;
DOD response: Concur.
Defense Science Board recommendation: Contract for support in
developing standard definitions, metrics, etc. to be completed and
promulgated within a year;
DOD response: Partially concur.
Defense Science Board recommendation: Direct the services to conform
with these standards and to enable capture of complete and accurate
organizational, intermediate, and depot-level corrosion man-hour,
material, and cost data;
DOD response: Concur.
Defense Science Board recommendation: Use these data to make fact-based
decisions regarding corrosion and corrosion cost and to track progress
of platform material improvement efforts;
DOD response: Concur.
Defense Science Board recommendation: Provide a separate funding line
to support annual assessment teams, to provide the means and expertise
to manage ongoing maintenance efforts, and to support organizational
level training and maintenance;
DOD response: Partially concur.
Defense Science Board recommendation: Implement well-defined
maintenance programs that included continuous corrosion performance
improvement and continuing assessment and reporting;
DOD response: Concur.
Defense Science Board recommendation: Require each service to contract
and execute its part;
DOD response: Concur.
Defense Science Board recommendation: Have all results reported to a
common database for analysis and to support the development of a joint
strategy for corrosion maintenance that accommodates the unique factors
associated with each service and system;
DOD response: Concur.
Defense Science Board recommendation: Extend assessment database to
capture existing aircraft and ship corrosion data;
DOD response: Concur.
Defense Science Board recommendation: Direct that services establish
best practices maintenance plans, benchmarking and providing adequate
training to all involved personnel at operator, intermediate, and depot
levels;
DOD response: Nonconcur.
Defense Science Board recommendation: Establish a corrosion executive
for each service with responsibility for oversight and reporting and
full authority over corrosion-specific funding and a strong voice in
corrosion-related funding;
DOD response: Concur.
Defense Science Board recommendation: Refocus and reinvigorate
corrosion science and technology portfolio. Triple the effective
funding in this area with particular emphasis on development of a
materials-corrosion tool set that emphasizes science-based modeling and
simulation; fundamental mechanistic understandings of corrosion
phenomena as well as accelerated testing; substitutes for effective
corrosion prevention materials which are being withdrawn because of
environmental and safety considerations; newly developed materials; and
nondestructive corrosion sensing and measurement in the field as
feedback to prognostic and condition-based maintenance tools;
DOD response: Partially concur.
Defense Science Board recommendation: Divide the responsibilities for
the Office of the Secretary of Defense's corrosion effort between three
separate organizations: Defense Systems; Logistics, Materiel, and
Readiness; and Installations and Engineering;
DOD response: Nonconcur.
Source: DOD.
Note: Of the 17 total recommendations made by the Defense Science
Board, DOD concurred on 11, partially concurred on 4, and did not
concur on 2.
[End of table]
[End of section]
Appendix II: Scope and Methodology:
To assess the Department of Defense's (DOD) efforts to implement its
corrosion prevention and mitigation strategy, including the oversight
of funding; identification of cost, readiness, and safety impacts; and
the development of results-oriented metrics, we reviewed DOD's funding
and progress for corrosion-related projects that it initiated during
fiscal years 2005 and 2006. We reviewed the President's budget
justification for fiscal year 2006 for corrosion-related efforts and
met with DOD officials within the Comptroller's Office regarding their
oversight of the Corrosion Policy and Oversight Office's budget. We
also met with DOD officials within the Office of the Under Secretary of
Defense for Acquisition, Technology, and Logistics to assess their
oversight of programs and funding levels of the military services
during the annual budget reviews as well as their monitoring of the
services' acquisition practices. In particular, we met with officials
with the Corrosion Policy and Oversight Office responsible for
managing, directing, and reviewing corrosion prevention and mitigation
initiatives. We met with DOD officials involved with developing DOD's
long-term strategy to prevent and control corrosion. We obtained their
assessments and perspectives on corrosion prevention and mitigation
programs and strategies; obtained and reviewed DOD policies,
procedures, guidelines, and draft instructions for prevention and
mitigation of corrosion on DOD military equipment and infrastructure;
and discussed additional actions that could be taken to further prevent
and mitigate corrosion. We reviewed DOD's funding requirements for
fiscal years 2005 through 2007 and future year projections.
To assess the extent to which the military services' have incorporated
corrosion prevention planning in the acquisition of major weapon
systems, we conducted a review of 51 major defense acquisition programs
from the Army, Navy, and Air Force. These 51 programs were selected
based on a nonprobability sample of acquisition programs from the
Fiscal Year 2006 Major Defense Acquisition Program List approved by the
Under Secretary of Defense for Acquisition, Technology, and Logistics.
Navy programs were about half of the programs on the list. A program is
designated a major acquisition program either by the Secretary of
Defense, or because it is estimated to require a total expenditure of
more than $365 million in research, development, test, and evaluation
funds or require a total expenditure of more than $2.19 billion in
procurement funds. Our program selection represented the functional
capability areas for battle space awareness, focused logistics, force
application, force protection, and joint training and included air,
ground, and sea weapon systems. In particular, we selected and reviewed
13 Army programs, 25 Navy programs, and 13 Air Force programs. We met
with officials responsible for managing the acquisition programs and
with officials having primary responsibility for overseeing corrosion
prevention and mitigation within the respective services. We obtained
and reviewed military service policies and instructions that establish
corrosion prevention and control program requirements. For the
acquisition programs we selected, we obtained and reviewed documents,
including the acquisition strategy, acquisition plan, and corrosion
prevention and control plans, as well as related information
establishing corrosion prevention advisory teams and other reports used
for tracking and monitoring corrosion-related design initiatives and
corrections. In particular, we discussed the barriers that exist to
more effectively employing corrosion control at program initiation and
acquisition.
We also reviewed the recommendations of the Defense Science Board
report on corrosion control issued in October 2004, and obtained DOD's
related responses and actions taken to better address its strategy for
corrosion prevention and mitigation. We met with Corrosion Policy and
Oversight Office officials regarding their concurrence and the related
actions taken to date.
We conducted our work from April 2006 through January 2007 in
accordance with generally accepted government auditing standards. We
did not validate the data provided by DOD. However, we reviewed
available data for inconsistencies and discussed the data with DOD. We
determined that the data used for our review were sufficiently reliable
for our purposes.
We interviewed officials and obtained documentation at the following
locations:[Footnote 17]
* Office of the Under Secretary of Defense, Corrosion Policy and
Oversight Office:
* Army:
- U.S. Army Materiel Command, Fort Belvoir, Virginia:
- U.S. Army Aviation and Missile Command, Redstone Arsenal, Alabama:
* Navy:
- Naval Air Systems Command, Patuxent River, Maryland:
- Naval Sea Systems Command, Washington Navy Yard:
* Air Force, Aeronautical Systems Center, Wright Patterson Air Force
Base, Dayton, Ohio:
[End of section]
Appendix III: Organizational Structure of DOD's Corrosion Activities:
[see PDF for Image]
Note: DUSD = Deputy Under Secretary of Defense.
[A] Currently filled by the Under Secretary of Defense for Acquisition,
Technology, and Logistics.
[End of figure]
[End of section]
Appendix IV: Corrosion Prevention Planning in Selected Major Defense
Acquisition Programs:
Army.
Service and program: AB3, Apache Block III;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: No.
Service and program: UH-60M Blackhawk Upgrade, Utility Helicopter
Upgrade Program;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: Light Utility Helicopter;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: CH-47F Cargo Helicopter;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Joint Cargo Aircraft;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Armed Reconnaissance Helicopter Program;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: Family of Medium Tactical Vehicles;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Stryker, Armored Vehicle;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: Bradley Upgrade, Bradley Fighting Vehicle System
Upgrade;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: Yes.
Service and program: High Mobility Artillery Rocket System;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Javelin, Advanced Anti-tank Weapon System;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Land Warrior, Integrated Soldier Fighting System;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Future Combat Systems;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Navy.
Service and program: CVN 21, Next Generation Nuclear Aircraft Carrier;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: Yes.
Service and program: DDG 1000, Zumwalt Class Destroyer;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: Yes.
Service and program: LHA Replacement New Amphibious Assault Ship;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: No.
Service and program: Littoral Combat Ship;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: No.
Service and program: Cobra Judy Replacement, Ship-based Radar System;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Maritime Prepositioning Force (Future);
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: T-AKE, Lewis and Clark Class of Auxiliary Dry
Cargo Ships;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: CG(X), Next Generation Cruiser;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: CVN 68, Nimitz Class Nuclear Powered Aircraft
Carrier;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: DDG 51, Guided Missile Destroyer;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: LPD 17, Amphibious Transport Dock;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: SSGN, Ohio Class Conversion;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: SSN 774, Virginia Class Submarine;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: SSDS, Ship Self Defense System Program;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: E-2C Reproduction, Hawkeye Carrier-Based Early
Warning Aircraft; Corrosion prevention and control plan: No; Corrosion
prevention advisory team: No.
Service and program: E-2D AHE, Advanced Hawkeye;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Vertical Takeoff and Land Tactical Unmanned Air
Vehicle;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: No.
Service and program: MH-60S, Utility Helicopter to Replace Existing CH-
46D, HH-60H, SH-3 & UH1N Helicopters;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: CH-53K, Heavy Lift Replacement Program;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: No.
Service and program: F/A-18E/F, Hornet Naval Strike Fighter;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: H-1 Upgrades, U.S. Marine Corps Mid-life Upgrade
to AH-1W Attack Helicopter and UH-1N Utility Helicopter;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: MH-60R, Multi-Mission Helicopter Upgrade;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: P-8A, Multi-Mission Maritime Aircraft Program;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: No.
Service and program: V-22, Osprey Joint Advanced Vertical Lift
Aircraft;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: VH-71, Presidential Helicopter Fleet Replacement
Program;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Air Force.
Service and program: AWACS Upgrade, Airborne Warning and Control System
Block 40/45 Upgrade Program;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Global Hawk, High Altitude Endurance Unmanned
Aircraft System;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: Yes.
Service and program: C-130 Aircraft Avionics Modernization Program;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: C-130J, Hercules Cargo Aircraft Program;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: C-17A, Globemaster III Advanced Cargo Aircraft
Program;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: C-5 Aircraft Avionics Modernization Program;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: C-5 RERP, Aircraft Reliability Enhancement and
Reengineering Program;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: B-2 RMP, Radar Modernization Program;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: F-22A, Advanced Tactical Fighter;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: F-35, Joint Strike Fighter Program;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: Joint Primary Aircraft Training System;
Corrosion prevention and control plan: Yes;
Corrosion prevention advisory team: Yes.
Service and program: KC-135 Replacement;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Service and program: Combat Search and Rescue Replacement Vehicle;
Corrosion prevention and control plan: No;
Corrosion prevention advisory team: No.
Source: GAO analysis of service data.
[End of table]
[End of section]
Appendix V: Comments from the Department of Defense:
Office Of The Under Secretary Of Defense:
3000 Defense Pentagon:
Washington, DC 20301-3000:
Acquisition Technology And Logistics:
Apr 20 2007:
Mr. William M. Solis:
Director, Defense Capabilities and Management:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Mr. Solis:
This is the Department of Defense (DoD) response to the GAO Draft
Report, "Defense Management: High Level Leadership Commitment and
Actions Are Needed to Address Corrosion Issues," dated April 5, 2007
(GAO Code 350825/GAO-07-618).
The report recommends that the Secretary of Defense direct the Under
Secretary for Acquisition, Technology, and Logistics to take several
actions regarding corrosion: implement active oversight of the Military
Departments' annual funding requests, develop plans using cost of
corrosion baseline study findings, and require corrosion prevention
control plans and assembly of corrosion prevention advisory teams. The
report also recommends that the Secretary direct the secretaries of the
Military Departments to designate Corrosion Executives or Corrosion
Offices.
The GAO report makes four "Recommendations for Executive Action;" the
Department partially concurs with each. Also, the Department disputes
the Report's characterization that cost is more important than
readiness and safety. Detailed comments on the report are enclosed. The
Department remains committed to meeting the requirements of the
Congress and, to the extent compatible with our core mission, the
positive recommendations of the subject GAO report.
Sincerely,
Signed by:
Mark D. Schaeffer:
Director:
Systems and Software Engineering:
Enclosure:
As stated:
GAO Draft Report - Dated April 5, 2007 GAO Code 350825/GAO-07-618:
"Defense Management: High Level Leadership Commitment and Actions Are
Needed to Address Corrosion Issues"
Department Of Defense Comments:
Comments on GAO recommendations:
Recommendation 1: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Acquisition, Technology, and
Logistics to require the Military Services to provide comprehensive
data about their annual funding requirements for corrosion prevention
and mitigation efforts to the DoD Corrosion Office, before annual
funding requests are sent to Congress.
DOD Response 1. Partially Concur. The Corrosion Prevention and Control
Department of Defense (DoD) Instruction 5000.rr, which is in
coordination, requires that the Military Departments submit to the DoD
Corrosion Executive, during the annual internal DoD budget process,
information on the proposed corrosion programs and funding levels. The
draft DoD Instruction also specifies that Services establish
responsibilities and methods for collecting and submitting this data.
However, corrosion prevention and mitigation activities are funded
through many different sources. No Program Elements exist in the
Military Departments that are tied directly to corrosion and many
activities are funded to complete corrosion-related work but are not
identified as such in budget documents. Corrosion requirements are
embedded in routine lifecycle maintenance costs (e.g. painting and
normal wear and tear) and non-routine repair costs due to corrosion
(e.g. material loss through rust and corrosion stress cracking),
acquisition program funding, operations and maintenance, and research,
development, testing and evaluation funding.
The Department expects that the Military Departments will use the
results from the ongoing - and then repeatable - Cost of Corrosion
Baseline Study (which is described in the report) in identifying the
top ten biggest cost drivers by segment. The Military Departments will
then be able to perform a technology assessment strategy of the biggest
corrosion cost drivers to be considered with other projects for
funding.
Recommendation 2: The GAO recommends that the Secretary of Defense
direct the Secretaries of the Army, Navy, and Air Force to designate a
Corrosion Executive or a Corrosion Office within each Service that is
responsible for corrosion prevention and mitigation, and that the
responsibilities of this official or office include identifying the
annual funding requirements for corrosion prevention and mitigation
efforts throughout the Service.
DOD Response 2: Partially Concur. The draft DoD Instruction 5000.rr
specifies that the Heads of DoD Components shall designate a Point of
Contact (POC) (a senior individual or office) for oversight of
corrosion matters, identified to the DoD Special Assistant for
Corrosion Policy and Oversight (SA/CPO). The DoD Instruction also
directs the Secretaries of the Military Departments to support the
corrosion POC in providing to the DoD Corrosion Executive, through the
SA/CPO, information on the Department's proposed corrosion programs.
The Air Force has already designated such an official. However, the
same issues with funding coordination as described in the response for
Recommendation 1 apply to this response as well.
Recommendation 3: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Acquisition, Technology, and
Logistics to develop an action plan for using the information contained
in the Army ground vehicle and Navy ship segments of DoD's cost impact
study. This plan should be completed in time to support the FY 2008
budget request and should include information on corrosion cost areas
having the highest priority and a strategy for reducing these costs.
DoD should develop comparable action plans for the information to be
derived from cost segments completed in the future.
DOD Response 3: Partially Concur. The President's budget for FY08 is
published. It would be impractical for the Military Departments
coordinated requirements to be addressed in this budget cycle; FY09 and
FY 10 are the next best opportunities for corrosion cost studies to
make an impact. The objective of the Cost of Corrosion Baseline Study
has been to identify specific systems that incur high corrosion
prevention and mitigation costs and to focus research and development
projects on those vulnerable high corrosion cost systems.
The DoD Corrosion Prevention and Mitigation Strategic Plan already
includes in the Policy Working Integrated Product Team Action Plan a
requirement to select and fund corrosion research projects and
integrated product team activities to enhance and improve corrosion
prevention and mitigation throughout the DoD. The Strategic Plan also
includes an Appendix titled "Project Selection and Management" which
provides specific requirements for Service submittal of plans for
proposed projects. A major requirement for project submittal is a
documented return-on-investment computation, which must include cost
details related to the current system and projected cost details
related to the proposed system. Proposed projects that reflect
significant savings are likely to be selected for funding and
implementation if other project plan specifications are met and funding
is available. As the results of the Cost of Corrosion Baseline Study
are completed, the Military Departments are expected to use the results
in selecting equipment and infrastructure projects for submittal.
Likewise, the DoD Corrosion Project Evaluation Team will cross check
submitted project plans against the Baseline Study results to help
establish funding priorities.
The Military Departments assess and make priorities regarding corrosion
based on (1) funding for the "Top Ten" high cost of corrosion
vulnerable systems, (2) funding for short-term, low-investment, high-
payoff systems, and (3) important activities for corrosion program
planning, execution and control. The Cost of Corrosion Baseline Study
provides a solid basis for supporting the annual budget request.
Recommendation 4: The GAO recommends that the Secretary of Defense
require major defense acquisition programs to prepare a corrosion
prevention plan and establish a corrosion prevention advisory team as
early as possible in the acquisition process.
DOD Response 4. Partially Concur. The draft DOD Instruction 5000.rr
states: (1) for acquisition category (ACAT) I programs, a review and
evaluation of corrosion planning shall be a topic for the Overarching
Integrated Product Team with issues raised to the Defense Acquisition
Board; (2) for all contracts exceeding $5,000,000, each DoD Component
shall establish a process to review and evaluate corrosion planning,
and (3) for all Military Construction infrastructure projects and for
all sustainment, restoration, and maintenance projects reported in the
DoD Facilities Assessment Database, each DoD Component shall establish
a process to review and evaluate corrosion planning.
The draft DoD Instruction also specifies that the Heads of DoD
Components shall establish a process to review and evaluate corrosion
planning that requires program and project managers to consider and
implement corrosion prevention and mitigation planning to minimize the
impact of corrosion and material deterioration throughout the system
and infrastructure life cycle, and develop procedures for corrosion
planning, process implementation, management, review and documentation
of results. The current draft DoD Instruction specifically calls for
corrosion prevention planning, but does not address corrosion advisory
teams, since the method for implementing the instruction can vary from
Service to Service. The outcome of each Service's method must comply
with the requirements of the instruction.
To strengthen this requirement, the Department concurs that a corrosion
prevention control plan shall be developed for all ACAT I programs
before preliminary design review and then implementation shall be
reviewed at each milestone. The establishment of a separate formal
Corrosion Prevention Advisory Team may not be necessary for all level
of programs based on the complexity of the program or other guidelines
already in place but shall be established for all ACAT I programs.
Additional comment of note:
GAO said, ". . . metrics for readiness and safety will likely take
several additional years to complete because they [DoD officials] have
placed a higher priority on completing the cost impact studies. They
told us that the accompanying definition and procedures will also take
several years to complete."
Non concur. This is an inaccurate and dangerous assertion. It implies
that the Department holds safety and readiness, the two linchpins of
the operational military mind-set, in lower esteem than cost. The issue
with readiness and safety is not one of priority but of information
availability: the problem of data in this area is much more
intransigent than cost and the cost methodology was difficult enough to
develop. The Corrosion Prevention and Control Integrated Product Team
representatives discussed readiness and safety at great length and
concluded that the Department should target readiness and safety
metrics very carefully.
Furthermore, in June 2003, the Department of Defense established the
Defense Safety Oversight Council (DSOC) chaired by the Under Secretary
for Personnel and Readiness and composed of the Under Secretaries of
OSD and Military Departments. The DSOC makes recommendations to the
Secretary of Defense on all matters and practices concerning safety and
impacting readiness. The DSOC is responsible for reviewing, promoting,
coordinating, and supporting activities to improve human performance,
safety education, standards, procedures, and equipment.
[End of section]
Appendix VI: GAO Contact and Staff Acknowledgments:
GAO Contact:
William M. Solis (202) 512-8365 or solisw@gao.gov:
Acknowledgments:
In addition to the individual named above, Harold Reich, Assistant
Director; Leslie Bharadwaja; Larry Bridges; Tom Gosling; K. Nicole
Harms; Charles Perdue; Cheryl Weissman; and Allen Westheimer made key
contributions to this report.
FOOTNOTES
[1] Pub. L. No. 107-314, § 1067 (2002), which added § 2228 to Title 10
of the United States Code.
[2] Department of Defense, Report to Congress, Department of Defense,
Long-Term Strategy to Reduce Corrosion and the Effects of Corrosion on
the Military Equipment and Infrastructure of the Department of Defense
(Washington, D.C.: December 2003).
[3] GAO, Defense Management: Opportunities to Reduce Corrosion Costs
and Increase Readiness, GAO-03-753 (Washington, D.C.: July 7, 2003);
Defense Management: Opportunities Exist to Improve Implementation of
DOD's Long-Term Corrosion Strategy, GAO-04-640 (Washington, D.C.: June
23, 2004); and Defense Management: Additional Measures to Reduce
Corrosion of Prepositioned Military Assets Could Achieve Cost Savings,
GAO-06-709 (Washington, D.C.: June 14, 2006).
[4] Defense Science Board, Office of the Undersecretary of Defense for
Acquisition, Technology, and Logistics, Report on Corrosion Control
(Washington, D.C.: October 2004).
[5] Pub. L. No. 109-163, § 356 (2006).
[6] Department of Defense, Under Secretary of Defense for Acquisition,
Technology and Logistics Fiscal Year 2006 Major Defense Acquisition
Program List (Washington, D.C.: September 2006). The programs on this
list were designated by the Secretary of Defense as major acquisition
program or are estimated to require a total expenditure of more than
$365 million in research, development, test, and evaluation funds or
require a total expenditure of more than $2.19 billion in procurement
funds.
[7] Because the position of Principal Deputy Under Secretary of Defense
for Acquisition, Technology, and Logistics is currently vacant, the
Under Secretary of Defense for Acquisition, Technology, and Logistics
is acting as DOD's Corrosion Executive.
[8] Defense Acquisition University, Defense Acquisition Guidebook, v.
1.6 (Ft. Belvoir, Va.: July 24, 2006).
[9] Department of Defense Directive 5000.1,The Defense Acquisition
System (May 12, 2003).
[10] Under Secretary of Defense for Acquisition, Technology, and
Logistics, Memorandum for Secretaries of the Military Departments,
Subject: Corrosion Prevention and Control, November 12, 2003.
[11] LMI Government Consulting, The Annual Cost of Corrosion for Army
Ground Vehicles and Navy Ships (McLean, Va.: April 2006).
[12] Department of Defense, Principle Deputy Under Secretary of
Defense, Acquisition, Technology, and Logistics, Corrosion Prevention
and Control Planning Guidebook (Washington, D.C.: July 2004).
[13] For example, The Air Force's Aircraft Structural Integrity Program
requires the creation of a corrosion prevention and control plan and
corrosion prevention advisory board.
[14] We reviewed 13 Army programs, 13 Air Force programs, and 25 Navy
programs based on a nonprobability sample from the Fiscal Year 2006
Major Defense Acquisition Program List.
[15] Such specifications and documents include a corrosion prevention
and control design manual, submarine class building specifications, and
material selection requirement documents.
[16] Defense Science Board, Office of the Undersecretary of Defense for
Acquisition, Technology, and Logistics, Report on Corrosion Control
(Washington, D.C.: October 2004).
[17] Unless otherwise noted, the officials listed in this appendix have
their offices in the Pentagon or at locations in the Washington, D.C.,
metropolitan area.
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