GAO

United States General Accounting Office

Report to the Honorable

Peter A. DeFazio, House of 

Representatives

August 1999 DEFENSE 

ACQUISITIONS

Comanche Program 

Cost, Schedule, and 

Performance Status

GAO/NSIAD-99-146

Page 1 GAO/NSIAD-99-146 Defense Acquisition

United States General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-280314 Letter

August 24, 1999

The Honorable Peter A. DeFazio

House of Representatives

Dear Mr. DeFazio:

The Comanche helicopter program, with a total projected cost of 

$48 billion, is the Army’s largest aviation acquisition program. It began in 

1983 as an effort to replace the Army’s fleet of aging light utility, 

reconnaissance, and attack helicopters. Since then, the program has been 

restructured five times, and it is still in development. The first four times, it 

was restructured because of concerns over program affordability and 

changing requirements. As a result, planned procurement quantities were 

reduced, development was delayed, and unit costs increased. In July 1998, 

the Army restructured the program for the fifth time. 

As you requested, we reviewed the status of the Comanche program. 

Specifically, we assessed (1) risks in the Army’s restructured plans for 

developing and testing the Comanche, (2) changes in the Comanche’s 

performance capabilities and requirements, (3) current cost estimates for 

development, and (4) the Comanche’s impact on the Army’s overall aviation 

modernization efforts. 

Results in Brief The Comanche’s restructured program contains significant risks1

 of cost 

overruns, schedule delays, and degraded performance because it would 

(1) begin the engineering and manufacturing development phase before 

some key mission equipment technologies have matured and have been 

integrated into the flight-test aircraft; (2) compress the flight-test schedule, 

increasing the amount of concurrent developmental and operational 

testing; and (3) begin initial production before initial operational testing 

starts, resulting in concurrency between development testing and initial 

production. The program is proceeding to the next development phase 

with high levels of uncertainty. Successful commercial firms generally do 

1

Risk is a measure of the probability that a planned objective will not be met and of the consequences of 

failing to achieve that outcome.

Letr
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not proceed into product development and production with such high 

levels of uncertainty.2

The Army is proposing changes to the aircraft that would adversely impact 

some of the Comanche’s planned performance capabilities. While their 

exact impact is unknown, these changes will increase the risk that the 

Comanche’s planned performance goals will not be achieved. For example, 

to meet increased range requirements for certain missions, the Army plans 

to use external fuel tanks that would likely reduce the helicopter’s planned 

stealth, cruising speed, maneuverability, and other performance 

capabilities. Plans to add the Longbow fire control radar system would 

provide enhanced target acquisition capabilities but would add weight and 

drag that would reduce other performance capabilities. 

The Army acknowledges that it will not achieve its goal of executing the 

Comanche’s restructured development program within the planned funding 

estimate of about $4.4 billion for fiscal years 1999 through 2006. An 

analysis by the Department of Defense’s (DOD) Cost Analysis Improvement 

Group in November 1998, found that total program costs would be about 

$150 million (3.4 percent) higher than the Army’s current estimate. The 

Group also believes that insufficient near-term funding could lead to a 6- to 

12-month schedule delay, which could add between $275 million and 

$425 million to the program’s overall development costs. Further, the 

Army’s accelerated technology development and testing plans increase the 

risk of additional schedule delays and cost increases. 

The Army continues to single out the Comanche as the centerpiece of its 

aviation modernization plan. The Comanche program, as currently 

planned, would absorb an increasingly larger share of the Army’s total 

aviation budget and would account for about 64 percent of the budget in 

fiscal year 2008. According to the Army, its modernization plan provides 

the best balance between capabilities and resources. The plan recognizes 

that because of funding constraints, some program modernization 

requirements must be traded off. As a result, older helicopters will have to 

be retained longer than originally planned, some helicopter upgrades will 

be foregone, and lower quantities of some helicopters will have to be 

procured. 

2

Defense Acquisition: Best Commercial Practices Can Improve Program Outcomes

(GAO/T-NSIAD-99-116, Mar. 17, 1999).

Letr
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Given the risks and uncertainties associated with the Comanche 

development program, this report recommends that the Secretary of 

Defense reevaluate the Army’s highly concurrent restructured plan that 

accelerates the milestone II decision date for entering the engineering and 

manufacturing development phase. It also recommends an evaluation of 

the cost, schedule, and performance impacts resulting from changes in 

operational requirements and weight growth. In commenting on this 

report, DOD partially concurred with our recommendations. DOD stated 

that the Comanche overarching integrated product team considers the 

issues raised in our report as part of its acquisition oversight and review 

process and, therefore, no additional evaluations are necessary to satisfy 

our recommendations. According to DOD, the Comanche program 

manager’s approach to the management of risk and concurrency is 

considered prudent and appropriate. We are concerned that DOD’s 

acquisition oversight and review process continues to approve program 

development and production plans that contain significant cost and 

schedule risks. Accordingly, as DOD undertakes its reviews of the 

program, we plan to continue monitoring the results of the reviews. 

Background The Comanche helicopter program began in 1983 with the aim of building a 

family of high-technology, low-cost aircraft that would replace the Army’s 

light helicopter fleet of approximately 5,000 aircraft, including the AH-1 

Cobra, OH-6 Cayuse, OH-58 Kiowa, and UH-1 Iroquois (Huey). The Army 

subsequently decided to develop only a single Comanche aircraft capable 

of conducting either armed reconnaissance or attack missions. Critical to 

achieving the Comanche’s desired capabilities is the successful 

development of advanced technologies, especially for the mission 

equipment package, which accounts for over half of the aircraft’s cost. The 

reconnaissance portion of the package includes the target acquisition 

system, the night vision piloting system, the helmet-mounted display, and 

the integrated communication and navigation systems. The attack portion 

includes the Longbow radar, survivability and early warning equipment, the 

Doppler navigation system, external stores, and weapons. 

The Comanche is designed to have capabilities that overmatch an enemy. It 

will have weapon bays, landing gear, and a 20-mm gun that all retract into 

the fuselage and will be capable of carrying Longbow Hellfire and Stinger 

missiles, and Hydra rockets internally or externally. The aircraft is 

expected to have improved speed and agility; aircrew visibility; and 

reliability, availability, and maintainability over the current reconnaissance 
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and attack fleet. It is also designed for low observability (stealth) and is 

expected to be capable of deploying over long ranges without refueling.

The program entered the demonstration and validation phase3

 of 

development in June 1988. Between 1988 and 1998, the program was 

restructured five times, the development schedule was extended from 1996 

to 2006, and planned quantities were reduced from 2,096 to 1,292. Under 

the latest restructuring, in July 1998, the Army decided to retain the 

2 prototype aircraft already built but acquire 14 rather than 16 aircraft. The 

two prototypes and six preproduction aircraft would be used for 

developmental testing and eight preproduction aircraft would be used for 

initial operational testing and evaluation. The Army plan also accelerated 

the start of the engineering and manufacturing development phase 

19 months to March 2000. Initial operational testing and evaluation of the 

aircraft is now scheduled for February through August 2006, and delivery 

of the low-rate initial production aircraft is to begin in January 2007. The 

full-rate production decision and initial operational capability deadline of 

December 2006 have not been changed. The Army’s planned cost estimate 

for completing the restricted Comanche developmental program was about 

$4.4 billion.

The Army’s 

Restructured Plan 

Contains Significant 

Risks

Under the Army’s latest restructured development plan, the Comanche 

program would advance to the engineering and manufacturing 

development phase before some key mission equipment technologies have 

matured and are integrated into the aircraft and tested. Additionally, the 

Army’s plan would (1) compress the flight-test schedule into the last 3 years 

of development, increasing concurrent developmental and operational 

testing and (2) begin initial production before initial operational testing is 

started, increasing concurrency between testing and production.4

 As a 

result, the restructured program contains significant risk that some 

technologies may not be mature enough and may not be integrated and 

tested prior to the scheduled start of low-rate initial production. Testing 

could identify design changes that may be required after production has 

started, leading to costly retrofits.

3

This phase is now called the program definition and risk reduction phase.

4

Developmental testing verifies that design, technology, and technical performance of the helicopter 

will support operational testing. A Combined Test Team (of government and contractor personnel) is 

responsible for Comanche developmental testing. Operational testing, conducted by the user of the 

weapon system, assesses the system’s performance in an operational environment.
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Mission Equipment 

Technology Development 

Risk

The risk that the technologies required for the Comanche’s mission 

equipment package and associated avionics would not mature as planned 

has been a major concern since the program’s inception. In an effort to 

reduce risk, the Army’s previous development plans called for the mission 

equipment package to be integrated and tested on a prototype helicopter 

prior to the milestone II decision5

 to enter the engineering and 

manufacturing development phase. Under the current restructured 

program, the Army plans to enter the engineering and manufacturing 

development phase 19 months earlier than planned, while delaying 

integration and flight testing of the mission equipment package. Therefore, 

the reconnaissance mission equipment package will not be integrated and 

flight tested on a prototype helicopter prior to the milestone II decision. As 

a result, decisionmakers will not have important test results needed for 

assessing the state of the Comanche’s technologies for the milestone II 

decision. 

In our recent work in the defense acquisition reform area, we found a 

number of lessons that can be learned from best commercial practices and 

applied to DOD’s major system acquisitions. One in particular is that 

commercial firms generally obtain a higher level of knowledge before they 

transition from technology development to product development and, later, 

to production. The restructured program will squeeze more work into the 

Comanche’s engineering and manufacturing development phase and then 

reduce the amount of time available for the remainder of the work. This 

contrasts with best practices of leading commercial firms, which learn 

more about a product’s technology, design, and producibility much earlier 

than DOD does in the acquisition programs we reviewed. Such knowledge 

reduces the risks of cost overruns, schedule delays, and performance 

shortfalls.

One of the purposes of the program definition and risk reduction phase of 

development is to demonstrate that technology risks are well in hand 

before the next decision point—milestone II. Some reconnaissance 

mission equipment technologies for the Comanche helicopter remain 

immature and untested. According to Army assessments, the 

helmet-mounted display and two key elements of the electro-optical sensor 

system—the integrated communication, navigation, and identification 

5

The purpose of the milestone II decision is to determine whether the results of the program definition 

and risk reduction phase warrant entry into the engineering and manufacturing development phase, 

which validates the production process and demonstrates system capability through testing.
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avionics and the forward-looking infrared—have a moderate to high 

developmental risk. None of these technologies has been tested on a 

Comanche prototype. For example, the technology for the Comanche’s 

integrated communication, navigation, and identification avionics 

subsystem, which has been under development since 1981, has been 

demonstrated only in the laboratory, and flight-test hardware will not be 

flown on the Comanche preproduction aircraft until late 2003, over 3-1/2 

years after the engineering and manufacturing development phase is 

scheduled to begin. Flight tests of a production version of the subsystem 

are not scheduled until 2004.

In November 1998, DOD’s Cost Analysis Improvement Group noted that 

mission equipment package development was relatively immature. 

According to the Group, “there has not been any MEP [mission equipment 

package] flight testing to date and [there are] several technological 

challenges remaining.” Compared with some leading commercial products, 

the Comanche, like many DOD programs, is proceeding with less available 

knowledge about key factors of product development. This increases the 

risk that costs may be higher than planned, product development may take 

longer, and performance may be lower than planned. 

Mission Equipment 

Integration Risks

Throughout the Comanche’s development, the Army and others have 

emphasized that there are significant risks associated with the integration 

of mission equipment subsystems into the aircraft.6

 In its 1994 independent 

review, a panel convened by the Institute for Defense Analyses identified 

integration of the mission equipment package as the most challenging 

aspect of the mission equipment package. The review stressed the 

importance of sufficient testing and user involvement because integration 

must be performed properly in order to achieve the desired combat 

effectiveness.7

 Although some system integration is scheduled to start in 

late 2001, some key elements of the mission equipment package will not be 

fully integrated, tested, and demonstrated until much later. For example, 

the Comanche is not scheduled to complete a full demonstration of its 

integrated mission equipment package, including the fire control radar and 

6

Comanche system integration involves the integration of its weapon systems and battlefield 

information systems into a total weapon system that provides maximum effectiveness with minimum 

crew workload. 

7

The review panel made these observations about the Army’s efforts to “streamline” the Comanche’s 

development by combining the first two phases of development into one.
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external fuel and armament management system, on a preproduction 

aircraft until December 2006, about 4 months after completion of initial 

operational testing and evaluation. The analyses of this demonstration may 

not be available in time for consideration when the full-rate production 

decision is made in December 2006.

Compressed and 

Concurrent Test Schedule 

Increases Program Risk

The restructured test schedule increases the risk that the Comanche 

helicopter will not be adequately tested prior to the full-rate production 

decision. Under the restructured program, the Comanche’s initial 

operational capability date is still scheduled for December 2006, even 

though the preproduction test aircraft will be delivered 19 months later 

than previously planned. This results in the flight-test schedule being 

compressed into the last 3 years of development, which increases the 

amount of concurrency between developmental and operational testing 

and between testing and initial production. Such high concurrency 

increases the risk of costly design changes and retrofits. 

Compressed Test Schedule The first Comanche prototype was scheduled to complete 174 flight-test 

hours between January 4, 1996, and January 9, 1999. However, only 

128 flight-test hours were completed--an average of 3.5 hours per month. 

According to a program official, the Comanche flight-test program is 

behind schedule because of periodic developmental problems and funding 

constraints. 

The first preproduction aircraft for testing is scheduled for delivery in 

October 2003, 19 months later than previously planned. By retaining the 

December 2006 initial operational capability date, the 19-month delay in 

acquiring test aircraft will compress the majority of the Comanche’s 

flight-test schedule into the last 3 years of development, shortening the 

available time for completing all test events before the full-rate production 

decision. As a result, the restructured program calls for an aggressive 

flight-test schedule, flying each of the 14 preproduction aircraft 17 hours a 

month. According to a consultant who reviewed the Comanche program 

for DOD, helicopter test programs typically achieve 10 to 12 flight-test 

hours per month. In its initial assessment of the proposed restructured 

program, DOD’s Cost Analysis Improvement Group noted that (1) the delay 

in acquiring test aircraft increases the risk that the test program will not be 

completed on time with all necessary test points achieved and (2) any 

delays in the delivery of mission equipment package subsystems would 

directly impact flight-test progress.
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Concurrent Testing and 

Production 

To achieve program test objectives within the compressed time frame, the 

Army restructured the Comanche test program in such a way that it will 

increase the amount of concurrent developmental and operational testing 

and concurrency between testing and initial production. Developmental 

testing is scheduled to run to December 2006, while the initial operational 

test and evaluation is scheduled to start in February 2006 and to be 

completed in August 2006.

The Army plans to conduct initial operational testing with eight of the 

preproduction aircraft. It will award the low-rate initial production 

contract as early as February 2005, and the first low-rate initial production 

aircraft will not be delivered until January 2007. Therefore, the Army will 

buy low-rate initial production aircraft about a year before the initial 

operational test and evaluation starts and deliver these aircraft about 

5 months after it is completed. According to DOD, a program has high 

concurrency when it proceeds to low-rate initial production before 

significant initial operational testing and evaluation is completed. DOD 

guidance states that such programs typically have a higher risk of 

production items having to be retrofitted to make them work properly and 

of system design not being thoroughly tested. In its assessment of the 

Comanche preproduction program, DOD’s Cost Analysis Improvement 

Group reported that the revised program schedule increases the level of 

concurrency and limits opportunities to make configuration changes based 

on results of the flight-test program. We previously reported that weapon 

systems that enter initial production before completing adequate testing 

often required significant and sometimes costly modifications to achieve 

satisfactory performance.8

Modifications Increase 

Risk That Comanche 

Will Not Meet 

Performance 

Requirements

The Comanche’s performance requirements continue to evolve. To meet 

newly established mission requirements, the Army plans to make 

modifications that will adversely impact some of the Comanche’s planned 

performance capabilities. These capabilities, which distinguish the 

Comanche from other Army helicopters, include its low observability 

(stealth), lethality, high cruising speed, and maneuverability. The extent to 

which modifications would reduce operational performance is not yet 

known. We have found that successful commercial firms do not proceed to 

product development until there is near certainty that their product design 

8

Weapons Acquisition: Low-Rate Initial Production Used to Buy Weapon Systems Prematurely

(GAO/NSIAD-95-18, Nov. 21, 1994).
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will meet performance requirements and they have gone a long way to 

ensure that the item can be produced.

The Army’s draft update of the Comanche’s operational requirements 

document includes two new extended range mission scenarios that are 

beyond the range of the Comanche’s currently planned internal fuel 

capability. To meet new range requirements, the Army has decided to add 

auxiliary fuel tanks, either externally or in the internal weapon bays when 

the Comanche is used in those particular mission scenarios. While both 

solutions would reduce the Comanche’s planned operational performance, 

program officials could not tell us to what extent performance would be 

impacted. Adding wings with external fuel tanks would increase weight 

and drag, decrease cruise speed, impact aircraft maneuverability, and lower 

some of its planned stealth characteristics. Furthermore, placing fuel tanks 

in one or both weapon bays would, according to a program official, 

preclude carrying most if not all the weapons in the bays. This would 

maintain stealth characteristics but would reduce or eliminate the 

Comanche’s internal weapon load and therefore its lethality.

A major element of the restructured program is the accelerated 

development and integration of a smaller and lighter electronic version of 

the Longbow fire control radar. The radar is expected to provide enhanced 

target acquisition capabilities, but its size, shape, and weight would 

increase the Comanche’s radar signature and drag, reducing its stealth, 

range, and maneuverability. Although the Army has not yet decided on the 

shape of the radar, it expects the radar would reduce the Comanche’s 

cruising speed by about 11 knots. Program office officials could not tell us 

to what extent adding the radar, wings, and external fuel tanks would 

impact the Comanche’s overall performance.

Other weight increases would further reduce the Comanche performance 

capabilities, such as range, vertical rate of climb, endurance, cruising 

speed, maneuverability, and agility. Because it recently added 132 pounds 

of additional equipment to meet new operational requirements, the Army 

raised the Comanche’s empty weight design goal from 8,690 to 

8,822 pounds and lowered the required range for deploying without 

refueling from 1,260 to 1,206 nautical miles. 

The Army currently has a weight reduction program in place for the 

Comanche. However, the Comanche Combined Test Team, which was set 

up to manage testing under the development program, noted in August 

1998 that implementing changes to the aircraft to address problems 
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discovered during developmental testing would make it very difficult not to 

increase the aircraft’s weight. Because of its continuing concern over 

weight growth, the program office is now planning to modify the 

Comanche’s rotor to provide more lift capability.

Restructured Program 

Will Not Meet Funding 

Objective

According to the Cost Analysis Improvement Group’s evaluation of the 

restructured program’s planned cost estimates, the Army will not meet the 

Comanche program’s developmental funding objective. The Army 

acknowledges that it will not achieve its goal of executing the Comanche’s 

restructured development program within the planned funding estimate of 

about $4.4 billion for fiscal years 1999 through 2006.

The Army’s Cost and Economic Analysis Center, which determines the 

Army’s official cost position, concluded that allowing for inflation, the 

program office’s $4.4-billion estimate was reasonable. But DOD’s Cost 

Analysis Improvement Group concluded that the estimate was generally 

optimistic and that the restructured program would require $4.55 billion, 

about $150 million (3.4 percent) more then the program office estimated. 

The Group also said that if funding was not increased, a 6- to 12-month 

program delay would occur, adding between $275 million and $425 million 

to program costs. 

The Group noted significant differences between its estimate of Comanche 

funding requirements and the Army’s for fiscal year 2000 and in four of the 

six following fiscal years. For example, the Army estimated funding 

requirements for fiscal year 2000 and 2001 at $433 million and $574 million, 

respectively. The Group estimated these requirements at $484 million and 

$657 million, or $134 million more for the 2 years. The Group believes that 

more funding for the Comanche’s airframe and mission equipment package 

development is needed in fiscal years 2000 and 2001, before fabrication and 

assembly. The program office, however, believes the funds could be made 

available after fabrication and assembly and that the total shortfall may 

only be $109 million. 

Since the Group made its assessment in 1998, DOD has reduced proposed 

funding for the development program to reflect inflation rate decreases. 

According to the program office, the reduction aggravates the funding 

shortfall and, as a result, its assessment of the cost risk has increased from 

low to moderate. At the time of our review, the program office noted that 

the funding reduction could result in one preproduction aircraft being 

eliminated, deliveries of other aircraft being delayed, and the initial 
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operational capability date being delayed. The program office has since 

signed a Memorandum of Understanding with the Comanche developers 

defining the engineering and manufacturing development phase. It will 

include the design and fabrication of 13 rather than 14 preproduction 

aircraft. While this may decrease cost risks, it will further increase the 

risks that the flight-test program will not be completed on time with all 

necessary test points achieved. The program office also plans to increase 

the average monthly flight-test hours from 17 to 18 per aircraft and further 

delay delivery and flight testing of the preproduction aircraft by several 

more months.

Impact of Comanche 

on Army’s Aviation 

Modernization 

The Army continues to single out the Comanche as the centerpiece of its 

aviation modernization strategy. As development and production costs 

increase, the Comanche’s share of the Army’s overall aviation budget also 

increases. In 1994, we reported that the Army had chosen to use most of its 

available aircraft modernization resources to procure the Comanche 

helicopter and upgrade the Apache, thus forcing the Army to retain aging 

utility and cargo aircraft.9

 According to the 1998 Army aviation 

modernization plan, the Comanche is still the centerpiece, and “older, 

obsolescing aircraft will remain in the inventory into the foreseeable 

future.”

The plan points out that “continued pressures on the defense budget have 

forced the Army to trade off aviation modernization requirements . . . and 

consider reduced aircraft resourcing strategies.” According to program 

office officials, the plan was developed as the best balance between 

capabilities and resources, and while it is not the preferred approach, it is 

the optimum one based on available resources. In December 1998, the 

program office estimated that while the Army’s aviation budget would 

fluctuate from fiscal year 1999 through 2008, the Comanche’s share of the 

budget would consistently increase. For example, while the Army aviation 

budget was estimated to decrease from $2 billion to $1.9 billion between 

fiscal year 1999 and 2000, the Comanche’s share of the budget would 

increase from $368 million to $433 million or from 19 percent to 23 percent 

of the Army’s aviation budget. The Comanche’s share of the total projected 

Army aviation budget of $3.3 billion is expected to rise to about 64 percent 

in fiscal year 2008, when its annual production cost would be over 

9

Army Aviation: Modernization Strategy Needs to Be Reassessed (GAO/NSIAD-95-9, Nov. 24, 1994).
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$2 billion. Various Army aviation officials provided the following examples 

of how the Comanche’s funding requirements have impacted 

modernization efforts in other Army aviation programs.

• The Army decided to reduce the number of advanced Apache Longbow 

helicopters it plans to upgrade from 758 to 530 and end that program 

earlier than planned because it could not afford to have a second 

production line in progress when Comanche initial production starts in 

2005. 

• The Army will not achieve its utility helicopter requirements because of 

funding imbalances in the Army’s 1998 aviation modernization plan. The 

plan identified an unfunded requirement for an additional 90 Black 

Hawk helicopters to fill shortages in the Army’s utility helicopter fleet. 

But because of its inability to fund its requirement for new utility 

helicopters, the Army has decided to keep the Huey helicopter in service 

until at least fiscal year 2020. In its report accompanying the Fiscal 

Year 1998 National Defense Authorization Bill, the Senate Armed 

Services Committee noted that utility helicopter requirements were 

identified but not resourced in a balanced manner and cited the 

readiness of the National Guard utility fleet as a serious concern. In 

1994, we reported that as a consequence of its strategy to develop the 

Comanche, the Army had decided against funding other aviation 

program requirements, including modernization of the Huey light utility 

helicopter. Since then, the Army has had to ground its Huey helicopters 

on two occasions because of safety concerns. 

• As a stop gap measure until the Comanche is fielded, the Army procured 

a limited number of Kiowa Warrior helicopters to provide 

reconnaissance capability until fiscal year 2009, when the Army planned 

to transfer the Kiowa Warrior to the reserves. Although the Kiowa 

Warrior has operational deficiencies, the Army now plans to retain it in 

the active forces until fiscal year 2022 because there will not be enough 

Comanche helicopters to replace them. According to the 1998 Army 

aviation modernization plan, “long-term retention of these aircraft will 

require safety and sustainment upgrades to keep these aircraft viable. 

The Army estimates that a minimum of 190 aircraft will require 

additional refurbishment beyond what is currently planned. A Kiowa 

Warrior program office official said that the Army has not requested 

funding for the Kiowa Warrior since 1988, and does not plan to request 

funding for future refurbishment upgrades for the 190 aircraft, which are 

estimated to cost about $1.7 billion.
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Conclusions The Comanche’s restructured program continues to contain significant 

risks of cost overruns, schedule delays, and reduced performance. The 

program is proceeding into product development without some key 

technologies being mature and prior to critical mission equipment and 

component capabilities being integrated and tested in the aircraft. The 

Army is proposing changes to the aircraft that will increase, to an unknown 

degree, the risk that some key performance capabilities will not be met. It 

is also proceeding into product development when uncertainties and risks 

are high and not consistent with best practices of commercial firms. To pay 

for the program, the Army has reduced the number of advanced Apache 

Longbow helicopters it plans to modify and is buying and upgrading fewer 

other replacement aircraft. This will force the Army to retain older aircraft 

for a longer period of time. 

Recommendations We recommend that the Secretary of Defense reevaluate the Army’s 

decisions to (1) accelerate the Comanche program’s milestone II decision 

and (2) implement a development program with high concurrency. The 

reevaluation should demonstrate how the Army specifically plans to: 

• minimize the risk associated with the technology being developed for 

inclusion in the mission equipment package prior to the milestone II 

decision and 

• ensure that major mission equipment package systems can be 

successfully integrated and tested in the Comanche in order to meet 

developmental and operational test schedule requirements.

We also recommend that the Secretary of Defense require the Secretary of 

the Army, before the milestone II decision, to evaluate and report on the 

extent to which increased operational requirements and weight growth 

would impact key performance capabilities, such as stealth and 

maneuverability, and how the Army intends to manage the program’s cost 

and schedule to accommodate any adverse impacts, if found.

Agency Comments and 

Our Evaluation

DOD partially concurred with our first recommendation calling for a 

Secretary of Defense reevaluation of the Army’s plans. It noted that it 

exercises oversight of the Comanche program through the DOD acquisition 

process. Further, it considered the acceleration of the milestone II 

decision, as well as the program manager’s approach to the management of 

risk and concurrency, to be prudent and appropriate at this point in 
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program development. Specifically, DOD noted that integrated product 

teams review the issues raised in our first recommendation on a recurring 

basis and that the overarching integrated product team will revisit them 

again at least two more times before the milestone II decision. DOD 

believes the overarching product team reviews comply with our 

recommendations. 

DOD also partially concurred with our second recommendation calling for 

an evaluation and report, prior to the milestone II decision, on the impact 

of increased operational requirements and weight growth on the program’s 

cost, schedule, and performance. DOD stated that the Army has been 

directed to ensure that upgraded operational requirements are reviewed by 

the Joint Requirements Oversight Council prior to the milestone II 

decision. DOD further stated that the program’s overarching integrated 

product team will consider all the issues mentioned in the recommendation 

prior to the milestone II decision and that no additional report is required 

to satisfy the recommendation. 

We recognize that integrated product teams and overarching integrated 

product teams are an integral part of DOD’s acquisition oversight and 

review process. However, we are concerned that the oversight and review 

process continues to accept program plans that contain significant risks 

that are not generally accepted by leading commercial firms. Accordingly, 

as DOD undertakes its reviews of the program, we plan to continue 

monitoring the results of these reviews.

DOD’s comments are reprinted in appendix I. DOD also provided some 

technical comments, which we incorporated in the report where 

appropriate.

Scope and 

Methodology

To assess the risk in the Army’s plans for developing and testing the 

Comanche, we examined and compared program schedules, acquisition 

plans, and acquisition strategies and discussed potential changes with 

Comanche program officials. We reviewed flight-test plans schedules and 

reports and discussed key issues with program officials. We reviewed 

program documents related to risk and analyzed program risks and 

development problems by comparing them with various test schedules and 

plans.

To assess changes in performance capabilities and requirements, we 

analyzed actual and projected performance and compared it with the 
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Comanche’s operational requirements, system specifications, and 

projected mission scenarios. We also obtained and evaluated Army 

documents describing the way the Army plans to operate in the future. We 

compared the Comanche’s planned capabilities against the operational 

plans identified in those documents. 

To assess the status of current cost estimates for the Comanche, we 

reviewed program documentation, interviewed officials, and performed 

analyses of program costs. Our analyses focused on the impact of 

restructuring decisions on the Comanche program. To assess the 

Comanche’s impact on the Army’s overall aviation modernization efforts, 

we reviewed program documents, interviewed officials, and performed 

analyses of the program’s impact on the Army’s overall aviation plans. Our 

analyses focused on the impact of the Comanche’s costs on the Army’s 

ability to procure other aircraft and incorporate technological upgrades in 

its helicopter fleet. 

In performing our work, we obtained documents and interviewed officials 

from the Offices of the Secretary of Defense and of the Army, Washington, 

D.C.; the U.S. Army Aviation and Missile Command, Huntsville, Alabama; 

the Training and Doctrine Command and the Aviation Technical Test 

Center, Fort Rucker, Alabama; the Operational Test and Evaluation 

Command, Alexandria, Virginia; the Evaluation Analysis Center, Aberdeen, 

Maryland; the Boeing-Sikorsky Joint Project Office, Philadelphia, 

Pennsylvania; and the Longbow-Limited Corporation, Baltimore, Maryland.

We conducted our review from April 1998 to May 1999 in accordance with 

generally accepted government auditing standards.

As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after its 

issue date. At that time, we will send copies of this report to Senator John 

W. Warner, Chairman, and Senator Carl Levin, Ranking Minority Member, 

Senate Committee on Armed Services; Representative Floyd D. Spence, 

Chairman, and Representative Ike Skelton, Ranking Minority Member, 

House Committee on Armed Services; Senator Ted Stevens, Chairman, and 

Senator Robert C. Byrd, Ranking Minority Member, Senate Committee on 

Appropriations; and Representative C.W. Bill Young, Chairman, and 

Representative David R. Obey, Ranking Minority Member, House 

Committee on Appropriations. We are also sending copies of this report to 

the Honorable William Cohen, Secretary of Defense; the Honorable Louis 
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Page 16 GAO/NSIAD-99-146 Defense Acquisition

Caldera, Secretary of the Army; and the Honorable Jacob Lew, Director, 

Office of Management and Budget. Copies of this report will be made 

available to others on request.

If you have any questions regarding this report, please contact me on 

(202) 512-4841. GAO contacts and key contributors to this report are listed 

in appendix II.

Sincerely yours,

Louis J. Rodrigues

Director, Defense Acquisitions Issues

Letr
Page 17 GAO/NSIAD-99-146 Defense Acquisition
Page 18 GAO/NSIAD-99-146 Defense Acqusition

Appendix I

Comments From the Department of Defense ApenxIdi
Appendix I

Comments From the Department of Defense

Lert Page 19 GAO/NSIAD-99-146 Defense Acqusition

See pp. 13 and 14.

See pp. 13 and 14.
Page 20 GAO/NSIAD-99-146 Defense Acqusition

Appendix II

GAO Contacts and Staff Acknowledgments ApenxIdi

GAO Contacts James F. Wiggins, 202/512-4530

Robert J. Stolba, 202/512-8963

Acknowledgments In addition to those named above, Raymond W. Allen, Leon S. Gill,

William E. Petrick, Jr., and John P. Swain made key contributions to this 

report.

(707348) Lert
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