United States Government Accountability Office

GAO Report to the Chairman, Committee on 

Finance, U.S. Senate 

NOAA

Next Steps to 

Strengthen Its 

Acquisition Function 

June 2006 

 

GAO-06-594 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2006

NOAA

Next Steps to Strengthen Its Acquisition 

Highlights of GAO-06-594, a report to the Function 

Chairman, Committee on Finance, U.S. 

Senate 

The National Oceanic and 

Atmospheric Administration 

(NOAA) accounts for about half of

the Department of Commerce’s

(Commerce) acquisition spending,

over $851 million in fiscal year 2005

alone. In recent years however, 

NOAA has experienced instances 

of poor contract management. 

GAO was asked to determine if

NOAA is positioned to effectively 

carry out its acquisition function. 

Specifically, GAO assessed the

extent to which NOAA has 

structured an acquisition 

organization that provides 

appropriate oversight; established 

policies and processes that 

promote, among other things, a 

knowledge-based acquisition 

process for development and

production of complex systems;

and planned and managed its 

contracting workforce to address 

future retirement challenges.

What GAO Recommends

GAO recommends establishment of 

policies for using a knowledgebased approach for complex 

developmental acquisitions and 

other actions to strengthen

oversight of NOAA contracting 

activities and build capacity of

NOAA’s contracting workforce to

address the agency’s retirement

challenges. After reviewing a draft

of this report, Commerce

concurred with our findings and 

recommendations. 

NOAA has yet to structure all of its field acquisition activities under the 

direct oversight of its acquisition organization, increasing the risk that 

taxpayers are not getting the best value for their dollars. To improve 

oversight of its acquisition function, NOAA reorganized in 2005 by having all 

acquisition divisions report to the NOAA Director of Acquisition and Grants. 

However, NOAA’s acquisition director still lacks direct line authority to 

oversee a National Weather Service field office that is responsible for one of 

the agency’s contracts worth up to half a billion dollars. Also, without 

appropriate oversight from the acquisition organization, collateral duty field 

staff who are not career contracting officers have bought millions of dollars 

in goods and services. Our work has shown that a well-functioning 

acquisition organization has direct lines of oversight between the head of 

acquisition and various components to help enforce policies that enable 

efficient and effective contract spending. 

Although NOAA has established clear and consistent policies for some key 

areas, such as advance acquisition planning, the agency lacks a knowledgebased process for developing and producing complex systems—a situation 

that can increase the risk of cost increases and schedule delays. NOAA is 

missing key elements that promote successful outcomes for complex 

developmental systems because it must adhere to Commerce’s acquisition 

policies that do not support a knowledge-based approach. Without such an 

approach, the multibillion-dollar satellite investment that NOAA is in the 

early stages of acquiring is at a higher risk of not meeting program 

requirements. 

NOAA has yet to focus on succession planning and management for its 

contracting workforce, although the agency is pursuing hiring flexibilities to 

recruit new contracting employees in anticipation of an impending wave of 

retirements. NOAA is facing a human capital challenge because of its aging 

contracting workforce and has reported that about 43 percent of contracting 

employees are now eligible to retire or will be eligible to retire by 2009.

While senior acquisition managers are concerned with the loss of a high 

percentage of their contracting staff to retirement and other attrition, NOAA 

has not specifically addressed such contracting workforce challenges in its

strategic human capital plan. Also, it is unclear whether human capital

planning under way by Commerce will determine the gaps in numbers and 

skills in the contracting workforce. Unless the future retirement and 

workforce capacity challenges are strategically addressed, NOAA could soon 

lose a significant portion of its contracting knowledge base. 

www.gao.gov/cgi-bin/getrpt?GAO-06-594.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Lisa Shames, 

202-512-4841, shamesl@gao.gov. 
Contents 

Letter 1

Results in Brief 2

Background 3

NOAA Lacks Oversight of Some Field Acquisition Activities 5 

Advances in Day-to-Day Acquisition Policies Not Matched in 

Policies for Complex Developmental Systems 9 

NOAA Has Taken Limited Actions to Address Contracting 

Workforce Retirement Challenges 12 

Conclusions 15

Recommendations for Executive Action 15 

Agency Comments and Our Evaluation 17 

Appendix I Scope and Methodology 18 

Appendix II Knowledge-Based Acquisition Framework for 

Complex Developmental Systems 20 

Appendix III Comments from the Department of Commerce 23 

Appendix IV GAO Contact and Staff Acknowledgments 26 

Table 

Table 1: NOAA’s Acquisition Divisions and Locations 4 

Figures 

Figure 1: Organizational Placement of NOAA Acquisition Function 7 

Figure 2: Demographics of the NOAA Contracting Specialists and 

Procurement Analysts as of September 2005 13 

Figure 3: Knowledge-Based Acquisition Framework 20 

Page i GAO-06-594 NOAA Acquisition Function
Abbreviations 

CPDF Central Personnel Data File 

GOES-R Geostationary Operational Environmental Satellite 

GS general series 

NOAA National Oceanic and Atmospheric Administration

OPM Office of Personnel Management 

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reproduce this material separately. 

Page ii GAO-06-594 NOAA Acquisition Function
United States Government Accountability Office

Washington, DC 20548 

June 7, 2006

The Honorable Charles E. Grassley 

Chairman 

Committee on Finance 

United States Senate 

Dear Mr. Chairman: 

The National Oceanic and Atmospheric Administration (NOAA) is one of 

the largest agencies within the Department of Commerce (Commerce) and 

accounts for 45 percent of the department’s dollars spent on acquisition. 

In fiscal year 2005 alone, NOAA’s acquisition organization contracted for 

over $851 million in goods and services in support of the agency’s mission. 

NOAA’s mission is to understand and predict changes in the Earth’s 

environment and conserve and manage coastal and marine resources to 

meet the nation’s economic, social, and environmental needs. To 

accomplish this mission, NOAA acquires goods including ships, satellites, 

aircraft, and high-performance computers as well as services such as 

hydrographic surveys, fisheries analyses, and buoy maintenance. For the

first time, NOAA is managing an expected $6.2 billion acquisition 

investment for developing a complex geostationary environmental 

satellite. 

NOAA relies more and more on contractor support to conduct its missioncritical work. However, in recent years, NOAA has experienced instances

of poor contract management that prompted the Commerce Inspector 

General to designate management of Commerce’s acquisition processes as 

one of the top 10 departmental management challenges. The Commerce 

Inspector General identified a lack of effective oversight and management 

controls over acquisition processes as a contributing factor to the poor 

contract management. 

In response to your request, we examined whether NOAA is positioned to

effectively carry out its acquisition function. Specifically, we assessed the 

extent to which NOAA has (1) structured an acquisition organization that

provides appropriate oversight; (2) established clear and consistent 

acquisition policies and processes that promote, among other things, a 

knowledge-based acquisition process for development and production of

complex systems; and (3) planned and managed its contracting workforce 

Page 1 GAO-06-594 NOAA Acquisition Function
to address future retirement challenges. See appendix I for additional 

details on scope and methodology. 

To conduct this work, we assessed information from NOAA headquarters 

and acquisition divisions and compared this information against what our 

previous work has shown to be best acquisition practices. We reviewed 

agency directives, memorandums, and other documentation; interviewed 

agency officials; and analyzed agency systems and processes. We 

conducted our review from August 2005 to April 2006 in accordance with 

generally accepted government auditing standards. 

NOAA has yet to structure all of its field acquisition activities under the 

direct oversight of its acquisition organization, increasing the risk that 

taxpayers are not getting the best value for their dollars. To improve 

oversight over its acquisition function, NOAA reorganized its acquisition 

divisions nationwide under the single authority of a headquarters office, 

headed by the Director of Acquisition and Grants. Yet NOAA’s acquisition 

director still lacks direct line authority to oversee the National Data Buoy 

Center, which is responsible for one of the agency’s largest contracts—

worth up to half a billion dollars. In addition, field staff who are not 

contracting officers but whose collateral responsibility is to acquire 

millions of dollars in goods and services annually manage contract actions

without appropriate oversight from the acquisition organization. Our best 

practices work has shown that a well-functioning acquisition organization 

has direct lines of authority and oversight between the head of acquisition

and various components of the organization in order to enforce acquisition 

policies effectively. 

Results in Brief 

Although NOAA has established clear and consistent acquisition policies

and processes in some key areas such as advance acquisition planning, the 

agency still lacks a knowledge-based acquisition process for development 

and production of complex systems. NOAA acquires a number of high-cost 

systems and is in the early acquisition stages of developing a new 

multibillion-dollar geostationary environmental satellite. However, it must 

adhere to Commerce’s policies for development and production of major 

systems and does not support a knowledge-based approach to acquiring 

such complex developmental systems. Senior Commerce and NOAA 

officials believe that NOAA program managers remain uncertain about the 

information they must provide to senior leaders for each key decision 

point. We have found that a knowledge-based approach enables program 

managers to be reasonably certain, at critical junctures, or “knowledge 

points,” in the acquisition life cycle, that complex developmental systems 

Page 2 GAO-06-594 NOAA Acquisition Function
are likely to meet established cost, schedule, and performance targets, and 

therefore they will be able to provide senior leaders with information 

needed to make sound investment decisions. 

NOAA has yet to focus on succession planning and management for its 

contracting workforce, although recognition of an impending wave of 

retirements prompted the agency to obtain approval to use more flexible 

direct hire authority to recruit new contracting employees. NOAA is facing 

a human capital challenge because of its aging contracting workforce and 

could soon lose a significant portion of its contracting knowledge base. 

For example, almost 52 percent of its contracting specialists are more than 

49 years old, and 66 percent have served at least 20 years with the agency.

Senior NOAA acquisition managers expressed concern about the looming 

retirements and other attrition of a high percentage of the contracting 

workforce. However, while NOAA completed a strategic human capital 

plan to help ensure it has the expertise necessary to achieve its mission, 

the plan does not address potential gaps in the agency’s contracting 

workforce. Also, while Commerce’s acquisition management office is 

developing a human capital plan to address challenges facing the 

contracting workforce, it is too early to determine if it will address the 

gaps in numbers and skills. 

We are making a recommendation to the Secretary of Commerce to 

incorporate a knowledge-based approach for complex developmental 

systems in revising the department’s acquisition policies and processes. 

We are also recommending that the Under Secretary of Commerce for 

Oceans and Atmosphere (1) take the necessary steps to provide oversight

authority for NOAA’s acquisition director over field acquisition activities 

and (2) conduct an assessment of the contracting workforce needed to

help achieve NOAA’s mission-critical work. After reviewing a draft of this 

report, Commerce concurred with our findings and recommendations. The 

full text of Commerce’s comments may be found in appendix III. 

The NOAA acquisition function is carried out by the headquarters 

acquisition office, headed by the Director of Acquisition and Grants, as 

well as 10 divisions, of which 6 are located at NOAA headquarters in Silver

Spring, Maryland, and 4 in regions throughout the country (see table 1). In

2005, NOAA employed 123 contracting and acquisition support staff in its 

acquisition function across headquarters and regional locations. 

Background 

Page 3 GAO-06-594 NOAA Acquisition Function
Table 1: NOAA’s Acquisition Divisions and Locations

Acquisition division Location 

National Environmental Satellite, Data, and Information Service Silver Spring, Md. 

National Ocean Service/National Marine Fisheries Service/Oceanic and Atmospheric Research Silver Spring, Md. 

National Weather Service Silver Spring, Md. 

Staff Offices and External Clients Silver Spring, Md. 

High Performance Computing Silver Spring, Md. 

Satellite Program Silver Spring, Md. 

Eastern Region Norfolk, Va. 

Central Region Kansas City, Mo. 

Mountain Region Boulder, Colo. 

Western Region Seattle, Wash. 

Source: NOAA. 

NOAA’s acquisition function also provides procurement services to several

other Commerce components, including the International Trade 

Administration, the Bureau of Economic Analysis, and the Economic 

Development Administration. In fiscal year 2005, NOAA administered over

15,000 contract actions with total awards over $851 million. 

In recent years, NOAA has experienced problems in acquiring goods and 

services. For example, NOAA’s inadequate negotiations and oversight, and 

lack of proper review, led the National Weather Service to pay for 

defective equipment and execute a contract modification without 

adequate negotiation for the transition power source for a high-resolution 

Doppler weather radar system jointly designed, acquired, and operated by

Commerce, the Department of Defense, and the Department of 

Transportation.1

 As a result, contract costs increased by approximately 

$4.5 million. Similarly, the Commerce Inspector General reported that 

NOAA had insufficient management controls to ensure adequate oversight 

 1

Department of Commerce Inspector General, National Oceanic and Atmospheric 

Administration: Acquisition of NEXRAD Transition Power Source Marred by 

Management, Technical, and Contractual Problems, Final Inspection Report OSE-15676 

(Washington, D.C.: September 2003). 

Page 4 GAO-06-594 NOAA Acquisition Function
of the procurement of over $65 million in new fisheries research vessels.2

For example, NOAA did not have the information required to effectively 

monitor the schedule and cost of the vessels and failed to implement an 

effective award fee plan on a timely basis to encourage superior 

performance by the contractor. 

Although NOAA has taken some actions, the agency has yet to structure all 

of its field acquisition activities under the appropriate oversight of its 

acquisition organization, increasing the risk that taxpayers are not getting

best value for their dollars. After the Commerce Inspector General 

criticized the lack of effective oversight and management controls over 

acquisition processes, NOAA changed the structure of its acquisition 

organization in 2005 to have acquisition divisions report to the Director of 

Acquisition and Grants. Yet the acquisition director lacks direct line 

authority over a field acquisition office in Mississippi. In addition, some 

NOAA field operations rely on staff who are not career contracting officers 

but whose collateral responsibilities are to procure goods and services 

without appropriate oversight from the acquisition organization. Our work 

has shown that a well-functioning acquisition organization has direct lines 

of oversight between the head of acquisition and various components of 

the organization to help enforce acquisition policies that enable the agency 

to get the best value on goods and services.3

In some respects, NOAA’s reorganization has fallen short in providing 

comprehensive authority to the NOAA acquisition director to provide 

appropriate oversight to field acquisition activities. After the Commerce 

Inspector General faulted NOAA’s contracting oversight, in an effort to 

better ensure oversight and management of acquisition across the agency, 

NOAA established an Acquisition and Grants Office in headquarters in 

2005. The reorganization elevated the office, formerly part of the NOAA 

Office of Finance and Administration, as a new staff office reporting 

NOAA Lacks 

Oversight of Some 

Field Acquisition 

Activities 

Acquisition Office 

Reorganization Was Not 

Comprehensive 

 2

Department of Commerce Inspector General, National Oceanic and Atmospheric 

Administration: Program for Acquiring Fisheries Research Vessels Needs Stronger 

Management Controls, Final Inspection Report STD-14428-2-0001 (Washington, D.C.: June 

2002). 

3

GAO, Homeland Security: Successes and Challenges in DHS’s Efforts to Create an

Effective Acquisition Organization, GAO-05-179 (Washington, D.C.: Mar. 29, 2005), and

Transportation Security Administration: High-Level Attention Needed to Strengthen

Acquisition Function, GAO-04-544 (Washington, D.C.: May 28, 2004).

Page 5 GAO-06-594 NOAA Acquisition Function
directly to the Deputy Under Secretary for Oceans and Atmosphere. Also, 

the NOAA regional acquisition divisions—which previously were separate 

entities reporting to the directors of the regional service centers in which 

they were located—all now report directly to the Director of the 

Acquisition and Grants Office as part of the reorganization. By elevating its 

acquisition office to a level that reports directly to an Under Secretary and 

having the divisions as direct reports to the acquisition director, NOAA has 

positioned itself to appropriately oversee agencywide acquisition activities 

and enforce acquisition policies. 

However, the reorganization was not comprehensive because it did not 

include the National Weather Service’s National Data Buoy Center 

acquisition office at the Stennis Space Center, Mississippi. Specifically, the 

Buoy Center does not report to the NOAA acquisition director (see fig. 1), 

even though this acquisition office is responsible for administering 

multiple contracts, including one of NOAA’s largest contracts, worth up to 

$500 million.4

 While contracting officers in the Buoy Center acquisition 

office derive their contracting authority from headquarters, they report 

through the Buoy Center chain of command, not to NOAA’s acquisition 

director. 

This reporting relationship was first established more than 20 years ago in

a Commerce appropriation act,5

 which created the Buoy Center acquisition 

office, and was stipulated in each subsequent appropriations act through 

1988, but not since. During the recent reorganization, NOAA officials 

believed these laws prohibited NOAA from changing the reporting 

relationship to one where the Buoy Center acquisition office would report 

directly to the NOAA Acquisition and Grants Office. However, an analysis 

by our general counsel found no law requiring the Buoy Center acquisition 

office to report to the Director of the Buoy Center or prohibiting NOAA 

from making this change. Commerce’s General Counsel agreed with our 

assessment. Although we did not identify any inefficiencies resulting from 

this current reporting relationship, we believe NOAA runs the risk of poor 

outcomes of contracts. 

 4

In 2005, the National Data Buoy Center awarded a 10-year (5-year base with 5 option 

years) technical services contract to provide life cycle support for NOAA’s Marine 

Observation Network; other buoy programs, including the network of Deep Ocean 

Assessment and Reporting of Tsunami stations; and its Data Assembly Center. 

5

Department of Commerce and Related Agencies Appropriation Act, 1984, Pub. L. No. 98-

166, November 28, 1983. 

Page 6 GAO-06-594 NOAA Acquisition Function
Figure 1: Organizational Placement of NOAA Acquisition Function

Under Secretary of Commerce for 

Oceans and Atmosphere and NOAA 

Administrator

 Chief Financial Officer

 Chief Administrative Officer

Director,

Program Analysis and Evaluation

Director, Workforce Management

NOAA Research Satellite and 

Information Service

Oceans and 

Coasts Service

National Weather 

Service

Program Planning 

and Integration

Office of 

Hydrologic 

Development

Office of the Chief 

Information Officer

Office of the Chief 

Financial Officer/Chief 

Administrative Officer

Office of Climate, 

Water, and 

Weather Services

Office of 

Operational 

Systems

Office of Science 

and Technology

Telecommunication 

and Operations

Center

National Data

Buoy Center

Maintenance, 

Logistics, and 

Acquisition Division

Operations Branch

Support Services Team

Financial Management Team

Procurement Team

Resources Branch Engineering Branch

Fisheries Service Marine and 

Aviation Operations

Assistant Secretary of Commerce for 

Oceans and Atmosphere and 

NOAA Deputy Administrator

Source: NOAA.

Director, Acquisition and Grants Deputy Under Secretary for Oceans

and Atmosphere

National Environmental Satellite, Data, 

and Information Service Acquisition Division

National Ocean Service/National Marine Fisheries

Service/Oceanic and Atmospheric Research Acquisition Division

National Weather Service Acquisition Division

Staff Offices and External Clients Acquisition Division

High Performance Computing Acquisition Division

Satellite Program Acquisition Division

Eastern Region Acquisition Division

Central Region Acquisition Division

Mountain Region Acquisition Division

Western Region Acquisition Division

Page 7 GAO-06-594 NOAA Acquisition Function
Certain NOAA field offices rely on “collateral duty” contracting officers 

who perform contracting duties in addition to their mission-related 

responsibilities but who are not career contracting officers. In these 

locations, collateral duty contracting officers have authority to make 

individual purchases of up to $25,000 for such day-to-day needs as 

provisions for ships. While NOAA relies on collateral duty contracting staff 

for a relatively small share of total agency procurement spending, these 

staff administered about 6,400 contract actions worth over $36 million 

alone in fiscal year 2005.

NOAA Relies on Staff Who 

Have Collateral 

Contracting 

Responsibilities 

NOAA’s acquisition director as well as senior field division contracting 

officers expressed concern about how well they can monitor the actions 

by staff with collateral duty contracting responsibilities to ensure that they 

follow NOAA acquisition policies. For example, unlike with their own 

contracting staff, some NOAA regional acquisition divisions provide only 

sporadic oversight over collateral duty contracting officers through 

occasional audits, either performed in person or through contract file 

samples sent by these staff for review. One regional acquisition division is

only able to audit work by staff with collateral contracting responsibilities 

once every 2 to 3 years. NOAA acquisition managers attributed their 

inability to provide regular oversight to limited time and resources, given 

other responsibilities. 

Our review of contracting weaknesses at a Department of Homeland 

Security agency found challenges similar to NOAA’s with regard to 

providing appropriate oversight to collateral duty contracting officers.6

 In 

view of such situations, we have found that an agency needs to explore 

ways of making collateral duty contracting officers in field locations 

accountable through the acquisition function for the contracting work. 

 6

GAO, Contract Management: INS Contracting Weaknesses Need Attention from the 

Department of Homeland Security, GAO-03-799 (Washington, D.C.: July 25, 2003). 

Page 8 GAO-06-594 NOAA Acquisition Function
Although NOAA has established clear and consistent acquisition policies

and processes for day-to-day acquisitions of goods and services, the 

agency lacks a knowledge-based acquisition process for development and 

production of complex systems. For example, NOAA has implemented 

planning processes intended to improve opportunities to achieve savings 

and reduce administrative burden in acquiring goods and services. 

However, NOAA has experienced difficulties in acquiring more complex 

developmental systems such as lacking sufficient management controls 

when it acquired its new fisheries research vessels. NOAA is missing key 

elements that promote successful outcomes because it must adhere to 

Commerce’s acquisition policies that do not promote a knowledge-based 

approach to acquiring complex developmental systems. Our work has 

shown that a knowledge-based approach would enable decision makers to 

be reasonably certain, at critical investment decision junctures in the 

acquisition life cycle, that the system is likely to meet cost, schedule, and

performance targets. 

To facilitate effective planning, award, and administration of contracts 

that help to ensure the best value on goods and services, NOAA recently 

implemented new policies and processes to guide the agency’s acquisition 

activities. For example, to ensure consistency of the NOAA acquisition 

process, a new acquisition handbook establishes standard operating 

procedures, which the agency previously lacked, such as required reviews 

and approvals, and quality assurance of acquisition activities within the 

agency. To ensure that contracting employees are adhering to proper 

procedures, NOAA instituted periodic acquisition management reviews. 

Under these reviews NOAA’s acquisition director (or a senior contracting 

officer appointed by the director) personally inspects a sample of 

completed contract files from an acquisition division in order to identify 

and remedy any systemic problem areas and identify best practices to 

share with other divisions. In the last few years, reviews in several 

divisions found a lack of proper contract file management, as required in

part 4.8 of the Federal Acquisition Regulation. The acquisition director 

consequently instructed the division heads to take steps with their staff to 

correct this problem. 

Advances in Day-toDay Acquisition 

Policies Not Matched 

in Policies for 

Complex 

Developmental 

Systems

New NOAA Policies and 

Processes Intended to 

Improve Acquisition 

Outcomes 

Recognizing that NOAA lacked effective acquisition planning and that this

lack was hindering effective workload management, the Acquisition and 

Grants Office in fiscal year 2005 implemented new advance acquisition 

planning requirements. For example, all staff offices and programs must 

develop annual acquisition plans that include acquisitions that are over 

$100,000 or expected to result in new contracts. To support these new 

Page 9 GAO-06-594 NOAA Acquisition Function
planning requirements and provide real-time data, the acquisition office 

deployed an online strategic acquisition management tool in fall 2005, in 

which NOAA staff offices and programs enter their annual acquisition 

plans for the upcoming fiscal year. Although the tool is new and still 

requires occasional modifications, NOAA officials generally agreed that it

provides considerable benefits for the acquisition process to better plan 

the agency’s use of resources and reduce the administrative burden 

previously experienced with managing unscheduled contracting 

requirements. 

NOAA’s Acquisition 

Process for Development 

of Complex Systems Lacks 

a Knowledge-Based 

Approach 

Because of the high dollar value and risk associated with acquiring 

complex developmental systems, Commerce requires that its subordinate 

organizations, including NOAA, adhere to departmentwide policy and

processes regarding such acquisitions. However, Commerce policies and 

processes do not promote a knowledge-based approach for acquiring 

these systems, increasing the risk that Commerce will make decisions to 

commit the government to major investments without knowing that 

NOAA’s systems can be developed at estimated costs, according to 

planned schedules, and with expected performance. Commerce officials 

acknowledged that their acquisition policy for developing major systems is 

outdated and said they are revising it.

7

 While the current policy identifies 

key decision points that a program must complete while acquiring a 

complex developmental system, it still lacks key features of a knowledgebased acquisition framework—specific criteria and metrics—that can be

used to measure whether a program is ready to move through each key 

decision point. 

Our work has shown that leading developers in industry and government 

organizations use a knowledge-based approach to deliver high-quality 

products on time and within budget. An acquisition policy that requires 

such a framework for complex developmental systems enables program 

managers to be reasonably certain, at critical junctures, or knowledge 

points, in the project’s acquisition life cycle, that their products will meet 

established cost, schedule, and performance targets. Such an acquisition 

policy also enables program managers to provide senior leaders with the 

information necessary to make sound project investment decisions for 

their agencies. Highlights of an acquisition policy that incorporates best 

 7

U.S. Department of Commerce, Major Systems Acquisitions for the Department of

Commerce, Department Administrative Order 208-3 (Washington, D.C.: Dec. 9, 1997). 

Page 10 GAO-06-594 NOAA Acquisition Function
practices for the development of complex systems include the equivalent 

of 

• Knowledge point 1: Resources and needs match. This point occurs 

when a match is made between the customer’s requirements and 

the product developer’s available resources in terms of knowledge, 

time, money, and capacity. 

• Knowledge point 2: Product design is stable. This point occurs when 

a program determines that a product’s design will meet customer 

requirements, as well as cost, schedule, and reliability targets.

• Knowledge point 3: Production processes are mature and the design 

is reliable. This is demonstrated when the product can be 

manufactured within cost, schedule, and quality targets. 

(See app. II for additional information on the knowledge-based acquisition 

framework for complex developmental systems.) 

Having a knowledge-based framework to guide acquisitions of complex 

developmental systems is especially critical given that NOAA is in the 

early acquisition stages of developing a geostationary environmental 

satellite at a projected investment cost of about $6.2 billion.8

 According to 

a Commerce official, in the past NOAA relied on agencies outside of 

Commerce to acquire such systems, but experienced cost and schedule 

problems.9

 To maintain management control over contractor performance, 

NOAA chose to manage the acquisition of its new satellite—the 

Geostationary Operational Environmental Satellite (GOES-R), which the 

agency plans to launch in 2012. 

 8

NOAA’s geostationary satellites analyze data to detect and track severe weather 

conditions such as tornadoes, flash floods, hailstorms, and hurricanes. They orbit the earth 

at a speed matching the earth’s rotation, allowing them to hover over one position on the

surface. 

9

GAO, Polar Orbiting Operational Environmental Satellites: Technical Problems, Cost

Increases, and Schedule Delays Trigger Need for Difficult Trade-off Decisions, 

GAO-06-249T (Washington, D.C.: Nov. 16, 2005); Space Acquisitions: Stronger

Development Practices and Investment Planning Needed to Address Continuing 

Problems, GAO-05-891T (Washington, D.C.: July 12, 2005); Polar Orbiting Environmental

Satellites: Information on Program Costs and Schedule Changes, GAO-04-1054 

(Washington, D.C.: Sept. 30, 2004); and Military Space Operations: Common Problems

and Their Effects on Satellite and Related Acquisitions, GAO-03-825R (Washington, D.C.: 

June 2, 2003). 

Page 11 GAO-06-594 NOAA Acquisition Function
Amplifying the need for clear guidance, NOAA officials told us the agency

is “feeling its way” through the GOES-R acquisition by relying on existing

Commerce and NOAA policies, but also learning from lessons drawn from 

previous satellite acquisitions at other agencies. According to senior 

officials directly involved, NOAA was forced to prepare for the most 

recent key decision point in 2005—authorizing program definition and risk 

reduction activities in the GOES-R acquisition—with vague guidance from

Commerce over what specific criteria and metrics were required for the

program to pass through the key decision point.

In order to be ready for the next key decision point, NOAA officials said 

that clearer guidance from Commerce is needed on the information 

required. The next key decision point is scheduled for fiscal year 2007 and

will commit the agency to development and production of the GOES-R 

series. Commerce acquisition management officials told us they are 

briefing NOAA officials and developing a plan for necessary 

documentation on the requirements for the project’s next key decision 

point. It remains to be seen whether these steps will provide sufficient 

clarity not only for what NOAA is expected to do to prepare for the 

remaining key decision points but also sufficient knowledge to make a 

well-informed decision on proceeding with the GOES-R acquisition. 

NOAA is facing a human capital challenge because of its aging contracting

workforce, and senior acquisition managers are concerned about the loss 

of a high percentage of their contracting staff to retirement and other 

attrition. However, NOAA has yet to focus on succession planning and 

management for its contracting workforce, even though the agency has 

approval to use flexible direct hire authority in anticipation of an 

impending wave of retirements. 

NOAA Has Taken 

Limited Actions to 

Address Contracting 

Workforce Retirement 

Challenges 

NOAA relies on contract specialists and procurement analysts to carry out 

its acquisition function.10 However, NOAA’s acquisition director is worried

about the near-term retirements of experienced contracting employees. 

Our analysis of Office of Personnel Management’s (OPM) personnel data 

for NOAA confirms there is cause for this sense of urgency, given that 

almost 52 percent of the agency’s contract specialists and procurement 

analysts are more than 49 years old and that 66 percent had at least 20 

 10Under the Office of Personnel Management’s general series (GS) of federal occupations,

GS-1102 (contracting series) employees are contract specialists and procurement analysts. 

Page 12 GAO-06-594 NOAA Acquisition Function
years of service (see fig. 2). Moreover, NOAA reported in January 2006 that 

about 43 percent of its contracting employees are already eligible to retire

or will become eligible to retire between now and fiscal year 2009. Given 

that NOAA has historically found that 50 percent of employees who are 

eligible to retire do so within 3 years, it could lose a significant portion of 

its contracting workforce within the next few years. 

In addition to being concerned about retirements, senior acquisition 

managers are very concerned about the significant acceleration in 

contracting staff turnover as well as what they view as “fierce” 

competition for federal contract specialists that prompts many to accept 

jobs outside of NOAA. For example, NOAA reported in January 2006 that 

over 12 percent of headquarters contracting positions are vacant. 

Moreover, NOAA’s acquisition organization is concerned that the risk of 

continuing losses is high, given that governmentwide, Commerce had the 

highest reported agency attrition rate of 19 percent for contracting 

employees as recently as fiscal year 2004. Our analysis of OPM’s fiscal year 

2005 personnel data affirms their concern, since about half of the 

contracting specialists and procurement analysts that separated that year

from NOAA transferred to jobs in other agencies (6 of the 13 employee 

separations). 

Figure 2: Demographics of the NOAA Contracting Specialists and Procurement Analysts as of September 2005

7%

11%

37%

45%

13%

20%

42%

Over 60

20–39

40–49

50–59

Source: OPM.

24%

Over 30

0–9

10–19

20–29

Age in years Service in years

Notes: GAO analysis of data from OPM’s Central Personnel Data File. Percentage may not add to 

100 because of rounding. 

Page 13 GAO-06-594 NOAA Acquisition Function
In 2006 NOAA’s workforce management office completed a strategic 

human capital management plan intended to respond to recognized 

challenges and to help ensure the agency has the scientific, technical, and 

administrative expertise necessary to accomplish NOAA’s mission. 

However, the plan does not specifically address the potential gaps in 

NOAA’s contracting workforce even though NOAA is responsible for 

executing up to 25 percent of the Department of Commerce’s budget on 

acquiring goods and services. Furthermore, because contracting expertise

was not recognized as mission-critical, the acquisition director said she 

was not asked and did not provide input about the challenges to the 

workforce management office. Involving senior management, employees, 

and other stakeholders in strategic human capital planning is an important 

step toward its successful implementation. 

In addition, Commerce has taken some initial steps to address this 

retirement challenge in its contracting workforce. The Secretary of 

Commerce’s Office of Acquisition Management and Financial Assistance 

hired a contractor to develop a human capital plan for the department’s 

contracting workforce. However, it is too early to determine if this 

Commerce-wide plan will determine the gaps in numbers and skills in the 

contracting workforce to achieve mission-critical work and develop 

strategies to address these gaps. Until this assessment of the contracting 

workforce is completed at the departmental level, NOAA will be hard 

pressed to make its own assessment. Also recognizing a critical staffing 

shortage, in January 2006, Commerce approved NOAA’s use of flexible 

direct hire authority to recruit qualified individuals.11 Civilian agency heads

are authorized to determine if a shortage exists in certain federal 

acquisition positions so that persons with high qualifications can be

recruited and directly hired. Direct hire authority allows an agency the 

flexibility to appoint individuals to positions without adherence to certain 

competitive examination requirements. According to a NOAA official, to 

date, NOAA has not implemented this authority. 

The prospect of many retirements in experienced staff make NOAA’s need 

for contracting workforce planning more significant, and NOAA stands to 

benefit greatly by planning strategically for its contracting workforce. Our 

work has shown that to recruit, develop, and retain the right number of 

people with the right skills to support mission needs, leading organizations 

go beyond a succession planning approach that focuses on simply 

 11Section 1413 of the Services Acquisition Reform Act of 2003 (Public Law 108-136). 

Page 14 GAO-06-594 NOAA Acquisition Function
replacing individuals and engage in broad, integrated succession planning

and management efforts that focus on strengthening both current and 

future organizational capacity.12 A key part of succession planning and 

management is to identify the talent required to achieve organizational 

goals. To that end, effective human capital planning involves 

(1) identifying the gaps in skills and competencies that need to be filled to

achieve current and future mission-critical work, (2) developing strategies

that are tailored to address these gaps, and (3) monitoring and evaluating 

the progress toward closing the gaps, and adjusting strategies accordingly.

Unless the future retirement and workforce capacity challenges are 

strategically addressed, NOAA could soon lose a significant portion of its 

contracting knowledge base. 

Effectively and efficiently acquiring goods and services will continue to 

play a major role in enabling NOAA to accomplish its mission. Therefore, 

NOAA’s success depends greatly on how well it manages its acquisition 

function. While NOAA has taken initial steps intended to put in place an 

efficient, effective, and accountable acquisition function, more can be

done. NOAA can improve oversight of its field acquisition operations by 

requiring direct reporting of all of its acquisition offices and developing an

oversight process for collateral duty contracting officers; adopting a 

knowledge-based acquisition process to help ensure that complex 

developmental systems meet cost, schedule, and performance targets; and 

addressing the imminent retirements of its contracting workforce to 

ensure it has a solid knowledge base to carry out its acquisition function. 

These next steps can facilitate achieving successful acquisition outcomes 

and enable NOAA to responsibly and prudently manage its investments to 

help meet the nation’s economic, social, and environmental needs. 

To close the gaps between NOAA’s current acquisition process and best 

practices for the development of complex systems, we recommend that 

the Secretary of Commerce take the following actions: 

Conclusions 

Recommendations for 

Executive Action 

• Incorporate a knowledge-based framework in the revision of 

Commerce’s policy for acquiring complex developmental systems. This 

 12GAO, Human Capital: Selected Agencies Have Opportunities to Enhance Existing 

Succession Planning and Management Efforts, GAO-05-585 (Washington, D.C.: June 30, 

2005), and Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003).

Page 15 GAO-06-594 NOAA Acquisition Function
framework should identify requirements for major system projects to 

attain specific product knowledge at significant stages in the 

acquisition life cycle. Demonstration of this knowledge should be used 

as a basis for decision making by departmental leadership at the 

following key points: 

• Before projects are approved to move from concept and technology 

development to start the acquisition program, the policy should 

require that customer requirements and product developers’ 

resources match, as indicated by achieving a high level of

technology maturity. 

• Before projects are approved to move from integration to 

demonstration, the policy should require that the product design is 

stable and performs as expected. 

• Before projects are approved to move from demonstration into 

production, the policy should require that its design is reliable and 

can be manufactured within cost, schedule, and quality targets. 

To provide appropriate oversight of NOAA’s field acquisition operations, 

we recommend that the Under Secretary of Commerce for Oceans and

Atmosphere take the following two actions: 

• take steps to ensure that NOAA’s Director of Acquisition and Grants 

has direct authority over all acquisition entities within the agency by 

realigning the National Data Buoy Center’s Acquisition Office to report 

directly to NOAA’s acquisition director and 

• provide for regular monitoring of collateral duty contracting officers in 

field offices to help ensure they are accountable to senior acquisition 

officials for their contracting work. 

To address the future retirement challenges of NOAA’s contracting 

workforce, we recommend that the Under Secretary of Commerce for 

Oceans and Atmosphere take the following action: 

• conduct a data-driven assessment of NOAA’s contracting workforce to 

(1) identify skill gaps, develop strategies to address these gaps, 

evaluate progress toward closing these gaps, and adjust strategies 

accordingly and (2) involve relevant stakeholders in the development 

of this assessment. 

Page 16 GAO-06-594 NOAA Acquisition Function
In written comments on a draft of this report signed by the Deputy 

Secretary of Commerce, the department agreed with our findings and 

recommendations. Commerce stated that the report presented an 

accurate assessment of the major issues NOAA faces and described 

current or planned actions to address the recommendations. The 

department’s comments are reprinted in appendix III. 

As we agreed with your office, unless you publicly announce the contents

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

from the date of this letter. We will then send copies to other interested 

congressional committees, the Secretary of Commerce, and the Under 

Secretary for Oceans and Atmosphere. We will make copies available to 

others on request. In addition, the report will be available at no charge on

GAO’s Web site at http://www.gao.gov. 

Agency Comments 

and Our Evaluation 

If you or your staff have any questions about this report, please contact me 

at (202) 512-4841 or shamesl@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 major contributions to this report are 

listed in appendix IV. 

Sincerely yours, 

Lisa Shames 

Acting Director, Acquisition 

 and Sourcing Management 

Page 17 GAO-06-594 NOAA Acquisition Function
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To determine if the National Oceanic and Atmospheric Administration 

(NOAA) has structured an acquisition organization that provides adequate 

oversight, we interviewed NOAA’s Director of Acquisition and Grants, the 

acquisition division heads, and Commerce acquisition management 

executives regarding NOAA’s acquisition function. We reviewed pertinent 

NOAA and Commerce organizational, management, and policy documents 

pertaining to the oversight of its acquisition activities. We also performed a 

legislative analysis of the establishment of the National Data Buoy Center 

in Mississippi to determine if there was a legal basis for not having its 

acquisition office report directly to NOAA’s Director of Acquisition and 

Grants. In addition, we reviewed reports from Commerce’s Office of the

Inspector General to obtain an understanding of relevant Commerce and 

NOAA acquisition management challenges. 

To determine if NOAA has established clear and consistent acquisition 

policies and processes that promote, among other things, a knowledgebased acquisition approach for development and production of complex 

systems, we reviewed acquisition policies, processes, and guidelines. We 

interviewed NOAA’s acquisition and grants director and acquisition 

division heads and reviewed information regarding new acquisition 

policies, handbook guidance, quality assurance, and planning processes. 

To determine if NOAA has established policies and processes that promote 

a knowledge-based review process for complex developmental systems 

acquisitions, we compared and discussed with NOAA and Commerce 

acquisition officials their policies for major acquisitions to our knowledgebased acquisition approach. Specifically, we compared and contrasted 

Commerce and NOAA’s major system acquisition review process with 

criteria contained in GAO best practices work on systems acquisition and 

space system acquisitions. 

Finally, to determine the extent to which NOAA has planned and managed 

its contracting workforce to address future retirement challenges, we 

interviewed NOAA and Commerce officials responsible for contracting 

workforce and strategic human capital planning. We also analyzed and 

compared NOAA’s contracting workforce and strategic human capital

planning efforts with principles of effective human capital management. In 

addition to obtaining Commerce and NOAA officials’ views and concerns 

regarding future human capital challenges, we analyzed data from Office 

of Personnel Management’s (OPM) Central Personnel Data File (CPDF), 

which is its database of federal civilian employees. Specifically, to assess 

the potential for retirements in the next few years in NOAA’s contracting 

workforce, the CPDF data we used reflected information on NOAA 

employees—as of September 30, 2005—working in the general series 

Page 18 GAO-06-594 NOAA Acquisition Function
Appendix I: Scope and Methodology 

(GS) 1102 contracting series of contract specialists and procurement 

analysts. We limited our analysis to focus on contract specialists and 

procurement analysts because NOAA’s Acquisition and Grants Office 

workforce mainly consists of this occupational category. We analyzed 

CPDF’s separations and demographic data (on the ages and years of 

service) and NOAA information for contract specialists and procurement 

analysts in order to identify the extent to which NOAA’s experienced 

contracting workforce is eligible for and thus has the potential for retiring 

in the near future. We did not independently verify the CPDF data on 

NOAA’s contracting series employees for the year we reviewed. However, 

we previously reported that data from the CPDF for key variables in 

another study—occupation, agency/subagency, birth date, and service 

computation date—were 99 percent accurate.1

We conducted our review from August 2005 through April 2006 in 

accordance with generally accepted government auditing standards. 

 1

See GAO, OPM’s Central Personnel Data File: Data Appear Sufficiently Reliable to Meet 

Most Customer Needs, GAO/GGD-98-199 (Washington, D.C.: Sept. 30, 1998). 

Page 19 GAO-06-594 NOAA Acquisition Function
Appendix II: K

Framework

Systems 

nowledge-Based Acquisition 

 for Complex Developmental 

Page 20 GAO-06-594

Appendix II: Knowledge-Based Acquisition 

Framework for Complex Developmental 

Systems 

The federal government spends billions annually to research, develop, and

produce large custom projects, such as satellites, space projects, weapon 

systems, air traffic control systems, and information technology systems. 

However, undesirable acquisition outcomes often occur because agency 

officials proceed further into development or production without 

obtaining sufficient knowledge that the product will be able to meet 

established cost, schedule, performance, and quality targets. 

The risk of undesirable acquisition outcomes can be significantly reduced. 

All product development acquisition projects, whether for a ship, airplane, 

missile, or satellite, go through a complex process of building knowledge. 

Ultimately, across the acquisition life cycle, this process brings together 

and integrates the technology, components, and subsystems needed for 

the product to work and be reliably manufactured. Over the past decade,

we have undertaken a body of best practices work that draws upon 

lessons learned from product development practices of leading 

commercial firms, which expect their program managers to deliver highquality products on time and within budget. 

Our work has identified three discrete points in the process for complex 

developmental systems at which obtaining certain levels of knowledge 

promote successful project outcomes. These knowledge points, depicted 

in figure 3, are defined in the following manner. 

Figure 3: Knowledge-Based Acquisition Framework 

Concept and technology 

development Production Integration Demonstration

Product development

Knowledge point 3

Production meets

costs, schedule, and 

quality targets

Knowledge point 2

Design performs as

expected

Knowledge point 1 Program start

Technologies, time, 

funding, and other 

resources match 

customer needs

Source: GAO.

• Knowledge point 1: Resources and needs match. This point occurs 

when a sound business case is made for the system—that is, a match is 

made between customer requirements and the product developer’s 

available resources in terms of knowledge, time, money, and capacity. 

Achieving a high level of technology maturity at the start of system 

development acquisition is an important indicator of whether this 

match has been made such that the technologies needed to meet 

 NOAA Acquisition Function
Appendix II: Knowledge-Based Acquisition 

Framework for Complex Developmental 

Systems 

essential product requirements have been demonstrated to work in 

their intended environment. 

• Knowledge point 2: Product design is stable. This point occurs when 

a program determines that a product’s design will meet customer 

requirements and cost, schedule, and reliability targets. A best practice 

is to achieve design stability at the system-level critical design review 

usually held midway through development. Completion of at least 

90 percent of engineering drawings at the system design review

provides tangible evidence that the design is stable. 

• Knowledge point 3: Production processes are mature and the design 

is reliable. This is demonstrated when a product can be manufactured 

within cost, schedule, and quality targets. A best practice is to ensure 

that all key manufacturing processes are in statistical control—they are 

repeatable, sustainable, and capable of consistently producing parts 

within the product’s quality tolerances and standards—at the start of 

production.

The attainment of each successive knowledge point builds on the 

preceding one. While the knowledge itself builds continuously without 

clear lines of demarcation, the attainment of knowledge points is 

sequential. In other words, production maturity cannot be attained if the 

critical technologies are not mature. 

This knowledge-based approach is not just applicable to improving how 

the Department of Defense manages the acquisition of weapon systems. 

As we have recently reported, utilizing a knowledge-based approach to 

manage complex developmental system acquisitions can likewise help 

civilian agencies reduce risk by ensuring high levels of knowledge are 

attained on individual acquisitions at key decision points, thereby enabling

senior leaders to make informed investment decisions.1

 A knowledgebased approach can also provide inexperienced program managers the 

necessary guidance to implement good management practices and ensure

 1

GAO, NASA: Implementing a Knowledge-Based Acquisition Framework Could Lead to 

Better Investment Decisions and Project Outcomes, GAO-06-218 (Washington, D.C.: Dec.

21, 2005), and Homeland Security: Successes and Challenges in DHS’s Efforts to Create

an Effective Acquisition Organization, GAO-05-179 (Washington, D.C.: Mar. 29, 2005). See

also GAO, Defense Acquisitions: Assessments of Selected Major Weapon Programs, 

GAO-06-391 (Washington, D.C.: Mar. 31, 2006) and Defense Acquisitions: Major Weapon 

Systems Continue to Experience Cost and Schedule Problems under DOD’s Revised 

Policy, GAO-06-368 (Washington, D.C.: Apr. 13, 2006). 

Page 21 GAO-06-594 NOAA Acquisition Function
Appendix II: Knowledge-Based Acquisition 

Framework for Complex Developmental 

Systems 

that the correct data are on hand for decision makers. Further, the 

methodology used by successful program managers to acquire complex 

developmental systems does not differ based upon each individual system

being acquired. Notwithstanding the type of system being acquired, these 

managers follow a regimented process that uses common and consistent 

criteria for decision making. 

Page 22 GAO-06-594 NOAA Acquisition Function
Appendix III: Comments from the Department Appendix III: Comments from the of Commerce 

Department of Commerce 

Page 23 GAO-06-594 NOAA Acquisition Function
Appendix III: Comments from the Department 

of Commerce 

Page 24 GAO-06-594 NOAA Acquisition Function
Appendix III: Comments from the Department 

of Commerce 

Page 25 GAO-06-594 NOAA Acquisition Function
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 26 GAO-06-594

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact Lisa Shames, (202) 512-4841 or shamesl@gao.gov. 

In addition to the individual named above, Carolyn Kirby, Assistant 

Director; Ian Jefferies; Jose Ramos; Sylvia Schatz; Bob Swierczek; and 

Greg Wilmoth made key contributions to this report. 

Staff 

Acknowledgments 

(120484) 

 NOAA Acquisition Function
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