United States General Accounting Office

GAO Report to Congressional Committees

May 1995 COMANCHE

HELICOPTER

Testing Needs to be

Completed Prior to

Production Decisions

GAO/NSIAD-95-112

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-259389 

May 18, 1995

The Honorable Strom Thurmond

Chairman

The Honorable Sam Nunn

Ranking Minority Member

Committee on Armed Services

United States Senate

The Honorable Floyd Spence

Chairman

The Honorable Ronald Dellums

Ranking Minority Member

Committee on National Security

House of Representatives

This report presents the results of our review of the Department of the

Army’s Comanche helicopter program. Because this program is the

centerpiece of Army aviation modernization efforts and faces major

funding shortages and restructuring, we focused our review on cost and

technical issues. Because of your expressed interest in the Comanche

program, we believe the information in this report will be useful as you

review the Department of Defense’s (DOD) plans for the program.

Background The Comanche program was established in 1983 to replace the Army’s

light helicopter fleet. The contractor team of Sikorsky Aircraft

Corporation and Boeing Helicopter Company were expected to design a

low-cost, lightweight, advanced technology helicopter capable of

performing the primary missions of armed reconnaissance and attack.

Critical to achieving these capabilities are the successful development of

advanced technologies, including composite materials, advanced avionics

and propulsion systems, and sophisticated software and hardware. The

Army must meet ambitious maintainability goals in order to (1) realize

significantly lower operating and support costs predicted for this program

and (2) achieve a wartime operational availability for the Comanche of 

6 hours per day.

In December 1994, the Secretary of Defense directed the Army to

restructure the Comanche helicopter program as part of efforts to meet

budgetary constraints. The Secretary’s restructure decision reduced

funding for the program from $4.2 billion to $2.2 billion for fiscal years

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1996 through 2001. In addition to extending the development phase by

3 years, it also called for two flyable prototypes to be produced and the

Comanche production decision to be deferred.

In response to the Secretary’s decision, the Army proposed a program

restructure that would allow it to acquire, within the Secretary’s funding

constraint, six aircraft in addition to the two prototypes by deferring

developmental efforts to fiscal year 2002 and beyond. DOD approved the

proposal in March 1995.

Results in Brief Under the Army’s restructured program, production decisions will be

made before operational testing of the Comanche starts, thereby

continuing the high degree of risks associated with concurrent

development and production. However, the time provided by extending

the development phase and the acquisition of the six additional aircraft

under the restructure provides the Army with the opportunity to conduct

operational testing before committing funds to any production decisions.

Because of the Comanche program’s high costs and technical risks, we

believe the Army should complete operational testing before long-lead and

low-rate initial production decisions are made, thereby significantly

reducing the risks from the program.

The Comanche will be a much more expensive armed reconnaissance

helicopter than the one originally justified to the Congress. The

Comanche’s program acquisition unit cost1

 has almost tripled in 10 years.

It has increased from $12.1 million in 1985 to $34.4 million as of

February 1995. Program acquisition unit cost increases occurred primarily

because of program restructuring and a 74-percent decrease in the

quantity of aircraft to be procured. Cost and program schedule will again

be affected because of the decisions to restructure the program.

After a decade of developing the Comanche, the Army continues to

experience technical problems. The Army is experiencing software

development and testing problems associated with electronic systems that

affect the performance of the Comanche. All key aircraft maintainability

requirements for the Comanche may not be achievable. Therefore, the

Comanche’s ability to meet its wartime availability requirements and its

objective of lower operating and support cost is questionable. On the

positive side, the program is currently meeting its goals of reducing

1

Throughout this report, both the total program acquisition costs and program acquisition unit costs

are depicted in current dollars and include research, development, and acquisition costs but exclude

military construction costs.

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maintenance levels and keeping within acceptable limits of overall weight

growth for the Comanche.

Restructuring

Continues Risks

The Army’s restructuring of the Comanche program continues risks

(1) associated with making production decisions before knowing whether

the aircraft will be able to perform as required and (2) of higher program

costs.

Restructuring Continues

Highly Concurrent

Program

According to DOD’s April 1990 guidelines for determining degrees of

concurrency, a program with high concurrency typically proceeds into

low-rate initial production before significant initial operational test and

evaluation is completed. Regarding the need to keep concurrency low, the

guidelines note that establishing programs with no concurrency, or a low

degree of concurrency, avoids the risks that (1) production items have to

be retrofitted to make them work properly and (2) system design will not

be thoroughly tested. As we recently reported, aircraft systems, including

the T-45A and C-17, that entered low-rate initial production before

successfully completing initial operational testing and evaluation

experienced significant and sometimes costly modifications to achieve

satisfactory performance.2

 Under the Army’s restructured program,

operational testing will not begin until after the low-rate initial production

decision is made, continuing the risks associated with the highly

concurrent Comanche program.

In responding to the Secretary’s restructure decision, the Army proposed,

and was subsequently granted approval, to buy six “early operational

capability” aircraft, in addition to the two prototypes that were to be

acquired under the Secretary’s decision. According to program officials,

these aircraft are estimated to cost in excess of $300 million. The Army

does not consider these aircraft as either prototype or low-rate initial

production aircraft; however, program officials believe that when these

aircraft are fielded, the Army will be able to better evaluate the

Comanche’s mission capability. The Army intends to fund these aircraft by

deferring additional developmental efforts to fiscal years 2002 and beyond.

Under the Army’s restructured program, operational testing will not begin

until well after funds are committed to buy production aircraft. Armed

reconnaissance and attack mission equipment packages are to be

2

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

(GAO/NSIAD-95-18, Nov. 1994).

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integrated into the six early operational aircraft by fiscal year 2004. The

Army plans to use these aircraft to start operational testing by about

August 2005. However, long-lead production decisions are scheduled for

November 2003, and low-rate initial production is planned to start in

November 2004, about 9 months before operational testing begins.

According to DOD’s guidelines, the amount of risk associated with

concurrency can be limited by reducing production aircraft to the

minimum necessary to perform initial operational testing. The Army

maintains that under the stretched out program it can conduct initial

operational testing with the six early operational aircraft. Because the

restructure has provided the additional time and aircraft, the Army has an

opportunity to significantly reduce or eliminate program concurrency and

its associated risks by completing operational testing before committing

funds to any production decisions.

Comanche Costs Continue

to Increase

The Comanche was originally justified to the Congress as a relatively

inexpensive aircraft. However, since 1985, the program has experienced

significant increases in program acquisition unit cost. Funding reductions

have caused the program to undergo significant restructuring, resulting in

sharp decreases in planned acquisition quantities and lengthening of

development schedules, thereby increasing Comanche program costs.

In 1985, the Comanche had estimated total program acquisition costs of

about $61 billion for 5,023 aircraft (or $12.1 million per aircraft). In 1992,

we reported that (1) as of October 1991, the program acquisition unit cost

had increased to $27.4 million, (2) acquisition quantities had been reduced

to 1,292 aircraft, and (3) future increases in cost per aircraft were likely.3

As of February 1995, the Comanche’s estimated program acquisition unit

cost was $34.4 million per aircraft, a 185-percent increase from the 1985

estimate. The estimated total program acquisition cost for the planned

acquisition of 1,292 aircraft is now more than $44 billion.

Both the Secretary’s decision and the Army’s restructure would extend the

development program by about 3 years and, under either, increase the risk

of higher total program cost and cost per aircraft. However, in reviewing

the Army’s restructure proposal, DOD noted some concern over Comanche

program costs for fiscal year 2002 and beyond and the large increase in

investment programs projected to occur about that time. We are also

3

Comanche Helicopter: Program Needs Reassessment Due to Increased Unit Cost and Other Factors

(GAO/NSIAD-92-204, May 27, 1992).

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concerned that the Army’s plan to defer additional developmental efforts

to fiscal year 2002 and beyond may increase the risk that needed funds

may not be available to perform the deferred developmental effort.

Technical Risks to Be

Resolved

The Comanche program’s uncertainties in software development and

aircraft maintainability increase the risk that the aircraft will not perform

successfully. We believe the restructuring provides additional time to

resolve these issues before the decision to enter production is made.

Software Development Is

at Risk

The Comanche will be the most computerized, software-intensive Army

helicopter ever built. The Army estimates that about 1.4 million lines of

code are required to perform and integrate mission critical functions. With

additional ground support and training software to be developed, the total

program will have more than 2.7 million lines of code. This compares to

about 573,000 lines of code for the upgraded Apache attack helicopter

with fire control radar. The Army estimates 95 percent of the Comanche’s

total software will be written in Ada, a DOD-developed programming

language. The Army plans to demonstrate initial software performance

with the mission equipment package, which includes the flight control

system, during first flight of the Comanche, scheduled for November 1995.

The development and integration of on-board, embedded computer

systems is a significant program objective. The Comanche’s performance

and capability depend heavily on these systems and efforts have been

ongoing to solve the problems associated with these systems.

Nevertheless, (1) software development problems still exist with the Ada

compilation system, (2) delays in software development and testing are

occurring, and (3) improvements are needed in configuration

management. If these issues are not resolved, the aircraft’s performance

and capability will be degraded and first flight could be delayed.

Development Problems Remain

Unresolved for the Ada

Compilation System

Almost all of the Comanche software will be developed in the Ada

programming language; however, software developers are not using the

same version of the Ada compilation system. The Ada compilation system

translates Ada code into machine language so that software can be used by

the Comanche’s computers. For example, it is being used to help develop

software for use on the mission equipment package that is critical for first

flight.

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Subcontractors and the contractor team should be using the same,

qualified version of this compilation system to ensure effective software

integration. However, fixes to individual compiler software problems are

not being shared with all developers; therefore, they are not using a

common compilation system. These problems have already delayed

qualification testing of the compilation system by 1 year.

The lack of a uniform, qualified compilation system among software

developers could put first flight at risk, according to the Defense Plant

Representative Office. Problems with software integration may show up

once integration testing begins in the June to November 1995 time frame.

If that occurs, there may not be time to fix problems prior to scheduled

first flight.

Delays in Software

Development and Testing

The program is experiencing high turnover of software engineers at one of

the contractor team’s facilities. In its December 1994, monthly assessment

report, the Defense Plant Representative Office, which is responsible for

contract oversight, observed that high turnover of software personnel was

putting scheduled first flight at risk. Loss of key personnel has already

contributed to schedule slippage in several critical software development

areas. Software development for the following areas has been affected: the

airborne engine monitoring system, aircraft systems management, control

database, and crewstation interface management.

The contractor team has formulated a “get well” plan that is dependent on

being able to hire additional personnel in these areas. However, hiring

additional qualified personnel is difficult, according to the Defense Plant

Representative Office, because employment would be short term.

The flight control system software verification testing is also being

delayed. As of February 8, 1995, Boeing had conducted only 163 of

approximately 500 tests originally planned to be completed by that date.

The subcontractor responsible for developing this software has been late

delivering software for testing and has provided faulty software to Boeing,

according to the Defense Plant Representative Office. Boeing established a

recovery plan for this area that would have resulted in a completion date

in March 1995—about a 1-month delay from the original plan. However, in

February 1995, the contractor revised the recovery plan to reflect a

completion date of July 1995—a 5-month delay.

The flight control system is critical to first flight, according to the Defense

Plant Representative Office. However, because of delays with verification

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testing, the Defense Plant Representative Office is concerned that the

remaining verification testing, as well as, the validation and formal

qualification testing will not be completed in a timely manner. As a result,

first flight may be delayed. Boeing is scheduled to complete these tests

prior to first flight. According to the program office, Boeing’s plan to

complete the testing calls for it to be conducted concurrently. If major

problems occur in any one of the testing phases, there may not be enough

time to fix the problem and complete all testing before first flight.

Improvements in Configuration

Management Are Needed

Configuration management is the discipline of applying technical and

administrative direction and surveillance to (a) control the flow of

information between organizations and activities within a project; 

(b) manage the ownership of, and changes to, controlled information; 

(c) ensure information consistency; and (d) enable product release,

acceptance, and maintenance. The part of configuration management used

to report software problems and changes among the contractor team and

subcontractors has shortcomings that put software development at risk.

In its November 1994 monthly assessment report, the Defense Plant

Representative Office observed that the lack of a common problem

reporting system made proper handling of software related changes

difficult. Furthermore, the report noted that this situation could adversely

impact scheduled first flight of the Comanche. As of February 1995, the

contractor team still did not have a common, automated database

available to track problem change reports. Thus, the contractor team, as

well as subcontractors, did not have visibility over changes made to

software.

Key Maintainability

Requirements at Risk

Maintainability requirements are important to achieving lower operating

and support costs and wartime availability goals. However, these goals are

at risk because key maintainability requirements such as direct

maintenance man-hours per flight hour (MMH/FH), the mean time to repair

(MTTR), and fault isolation may not be achievable. Individually, failure to

meet these parameters may not be a significant problem; however,

collectively they affect the ability of the Comanche to achieve lower

operating and support cost and wartime availability objectives.

Key Maintenance Goal May Not

Be Realistic

In March 1987, the Army established a 2.6 direct MMH/FH requirement for

the Comanche. It represents the corrective and preventive maintenance

per flight hour expected to be performed at the unit level. The Army

formulated its planned wartime operating tempo for a Comanche battalion

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based on 6 hours a day per aircraft, or 2,200 flying hours per year. It then

determined the maintenance factor needed to support this operating

tempo—2.6 MMH/FH. As the MMH/FH level increases, the number of

maintainers needed to sustain the 2,200 wartime flying hour goal

increases, as do operating and support costs. Conversely, if the Army

could not increase the number of maintainers, the planned operating

tempo would have to be reduced.

The reasonableness of the Comanche’s 2.6 direct MMH/FH requirement has

been debated for several years within the Army and DOD. Representatives

from the program office; the Army Materiel Systems Analysis Activity,

which independently evaluates program testing results; the Office of the

Assistant Secretary of the Army for Research, Development, and

Acquisition; and the Army Cost and Economic Analysis Center met on

October 28, 1994, to discuss the direct MMH/FH goal for the Comanche

program. They agreed that the 2.6-MMH/FH requirement was not a realistic,

achievable goal. Consequently, Army officials reached consensus and

agreed on 3.2 direct MMH/FH as the Army-wide position for this parameter.

However, during these discussions, Army Materiel Systems Analysis

Activity personnel noted that attaining a 3.2-MMH/FH goal represented a

medium to high risk, while a 4.3-MMH/FH goal had a low to medium risk.

Increasing the maintenance factor increased the number of maintainers

needed and will increase estimated operating and support costs by about

$800 million over a 20-year period.

The direct MMH/FH requirement does not represent the total maintenance

burden for the Comanche because it does not include indirect

maintenance time. The Army does not normally collect data on indirect

maintenance time. According to the program office, its best estimate of

indirect maintenance time, following Army guidance, is 2.5 MMH/FH, and

this figure has been used for calculating manpower needs for crew chief

personnel on the Comanche. Thus, the total maintenance burden assumed

for the Comanche is currently 5.7 MMH/FH (3.2 direct MMH/FH plus 

2.5 indirect MMH/FH).

Repair Requirement May Not

Be Met

To minimize turnaround time for repairs at the unit and depot, the Army

established MTTR requirements of 52 minutes for repairs at the unit level

and up to 12 hours at the depot level for the Comanche. These

requirements represents the average time expected to diagnose a fault,

remove and repair an item, and perform an operational check and/or test

flight. We determined that any increase in MTTR above 1 hour will begin to

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impact the Army’s wartime availability goal of 2,200 hours per year, unless

additional maintenance personnel are available.

As of January 1995, the contractor team was estimating that the Army

would achieve 59 minutes for unit level repairs. According to contractor

team officials, the requirement was not being met because the cure time

required for composite material used on the aircraft was greater than

expected. The contractor team discussed changing the MTTR requirement

to 1 hour; however, the program office believes the problem could be

resolved and did not believe the specification should be changed. The

contractor team has not yet developed MTTR estimates for depot-level

repair.

Key Diagnostic System

Requirement May Not Be

Achieved

The Comanche’s diagnostic system is required to correctly isolate failed

mechanical and electrical components at least 80 percent of the time with

a high degree of accuracy. A high level of accuracy is essential as it allows

maintainers to isolate and fix problems at the unit level. If the fault

isolation requirement is not met, the Comanche is unlikely to achieve its

MTTR requirement, thereby adversely affecting the Army’s ability to execute

its maintenance concept and its wartime availability goals.

Contractor team officials stated the fault isolation requirement was very

optimistic, and although they are striving to meet this requirement, it may

eventually have to be changed. As of January 1995, the contractor team

predicted the system could achieve an overall 69-percent fault isolation

rate; however, this rate would not meet the specification for mechanical

and electrical component fault isolation. There are design limitations on

two components, according to the program office, and changes to bring

these components into conformance with specifications would be costly

and increase the weight of the aircraft. Therefore, as of January 1995, the

contractor team and the program office have agreed not to take action on

these components.

False Removal Rate Is High

Risk

The Army established a requirement of a 1-percent false removal rate for

the Comanche. A false removal occurs when a part removed from the

aircraft shows no evidence of failure when tested. This requirement is

dependent, to a large extent, on the success of the fault detection/isolation

system in detecting and isolating failed components. Program personnel

characterize the 1-percent requirement as stringent and one that will be

challenging to achieve. An Army Materiel Systems Analysis Activity official

believes some design improvements have occurred in this area, but the

risk associated with achieving this requirement still remains high. If the

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Comanche does not meet this requirement, estimated operating and

support costs for the Comanche will be higher than previously predicted.

The Army has not had good experience in developing fault

detection/isolation and false removal systems for other aircraft. In

September 1990, we reported that the fault detection and isolation system

on the Apache aircraft did not always accurately detect the component

that caused a particular fault, and the system detected faults that did not

actually exist about 40 percent of the time.4

 As a result, Apache

maintainers had to perform additional work to locate failed components.

Recently, through a reliability program, the false removal rate for the

targeting and night vision systems on the Apache improved to about 10 to

15 percent, according to Army officials. This is still significantly higher

than the 1-percent requirement established for the Comanche program.

Some Program Goals

Are Currently Being

Met

Although the program is experiencing technical problems, it is currently

meeting its goals of reducing maintenance levels and keeping overall

weight growth within acceptable limits for the Comanche.

The Army’s maintenance concept for the Comanche program is predicated

on two levels of maintenance—unit- and depot-level maintenance. This

concept is important to achieving operating and support savings predicted

for the program because it eliminates the intermediate level of

maintenance. Unit-level maintenance entails removing and replacing

components required to return the aircraft to a serviceable condition.

Depot-level maintenance requires higher level maintenance skills and

sophisticated capital equipment and facilities not found at the unit level.

The Army traditionally uses a three-level maintenance concept that

includes intermediate-level maintenance to handle component repairs.

Intermediate-level maintenance is usually located close to the battalion. It

is performed on components that cannot be easily repaired at the unit

level and do not require the more sophisticated repairs done at the depot

level.

As of January 1995, no Comanche component had been designated for

repair at the intermediate level, according to the program office.

Contractor team personnel are conducting repair level analysis on

Comanche components to determine whether components should be

repaired at unit, intermediate, or depot facilities, according to program

4

Apache Helicopter: Serious Logistical Support Problems Must Be Solved to Realize Combat Potential

(GAO/NSIAD-90-294, Sept. 28, 1990).

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and contractor team officials. Any candidates identified for

intermediate-level repair are reviewed for possible design changes that

could allow maintenance at the unit or depot level. If economically

feasible, the contractor team will make design changes to the component

to preclude the need for intermediate-level repair.

As of February 7, 1995, the Comanche’s empty weight increased from its

original specification of 7,500 pounds to 7,883 pounds. Although the

Comanche’s weight continues to increase, it remains within the allowable

design limit of 7,997 pounds. Weight increases affect vertical rate of climb

performance on the Comanche. The Army established a limit of 

500 feet-per-minute as the minimum acceptable vertical rate of climb

performance.5

 If the Comanche’s weight exceeds 8,231 pounds, the engine

will have to be redesigned to produce enough power at 95 percent

maximum rated engine power to sustain the minimum 500 feet-per-minute

vertical rate of climb requirement.

Recommendation We recommend that the Secretary of Defense require the Army to

complete operational testing to validate the Comanche’s operational

effectiveness and suitability before committing any funds to acquire

long-lead production items or enter low-rate initial production.

Agency Comments

and Our Evaluation

DOD generally concurred with the findings and original recommendations

in our draft report. In commenting on the draft report, DOD offered

explanations about why the problems that we identified were occurring

and what they were doing to fix those problems. DOD disagreed with the

report’s conclusion about false removals and stated that we had not

presented any evidence that the Comanche’s 1-percent false removal rate

may not be achievable. We still believe that the false removal goal is high

risk and adjusted the report to more clearly reflect our concern.

Regarding our draft report recommendation that DOD develop program

fixes that achieve program goals and reduce the risks we identified, DOD

concurred and noted that the approved restructuring will significantly

reduce risk. DOD concurred with our other draft recommendation not to

commit production funds to the program until performance and mission

requirements are met and noted that the program would be reviewed by

DOD before approving the Army’s request to proceed to the engineering and

5

At 95-percent maximum rated engine power.

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manufacturing development phase—the Milestone II decision scheduled

for October 2001.

Because DOD concurred in our draft report recommendations and is taking

action on them, we are no longer including them in this report. However,

our analysis of information on the restructuring obtained after we had

submitted our draft report to DOD has further heightened our concerns

about the risk of concurrency; therefore, we have revised the report and

added a new recommendation. Under the stretched out, restructured

Comanche program, operational testing is not even scheduled to begin

until after the low-rate initial production decision is made. This approach

continues the risks associated with making production decisions before

knowing whether the aircraft will be able to perform as required.

Prior to the restructure, the Army planned to start operational testing with

eight aircraft in May 2003. Under the restructured program, the Army plans

to start operational testing with six helicopters by about August 2005. We

believe that the stretched out time frame and the six aircraft acquired

under the restructure provide sufficient time and aircraft to operationally

test the Comanche prior to making any production decisions.

Additionally, because operational testing is not scheduled until about

August 2005, DOD will not be in a position at Milestone II in October 2001

to adequately address whether the Comanche program is meeting its

performance requirements. DOD’s comments are presented in their entirety

in appendix I, along with our evaluation.

Scope and

Methodology

To assess cost changes, software development, maintainability, and weight

growth issues, we reviewed program documents and interviewed officials

from the Department of the Army headquarters, Washington, D.C.; the

Comanche Program Manager’s Office, St. Louis, Missouri; the U.S. Army

Materiel Systems Analysis Activity, Aberdeen Proving Ground, Maryland;

the Ada Validation Facility, Wright-Patterson Air Force Base, Ohio; and the

Office of the Assistant Secretary of Defense for Program Analysis and

Evaluation, Washington, D.C. We also reviewed program documents and

interviewed contractor and Defense Plant Representative Office officials

at the Boeing Helicopter Company, Philadelphia, Pennsylvania; the

Sikorsky Aircraft Corporation, Stratford, Connecticut; and the Comanche

Joint Program Office, Trumbull, Connecticut.

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We conducted our review between August 1994 and February 1995 in

accordance with generally accepted government auditing standards.

We are also sending copies of this report to the Chairmen and Ranking

Minority Members of the Senate and House Committees on

Appropriations, the Senate Committee on Governmental Affairs, and the

House Committee on Government Reform and Oversight; the Director,

Office of Management and Budget; and the Secretaries of Defense and the

Army. We will also provide copies to others upon request.

This report was prepared under the direction of Thomas J. Schulz,

Associate Director, Systems Development and Production Issues. Please

contact Mr. Schulz at (202) 512-4841 if you or your staff have any questions

concerning this report. Other major contributors to this report are listed in

appendix II.

Louis J. Rodrigues

Director, Systems Development and

 Production Issues

Page 13 GAO/NSIAD-95-112 Comanche Helicopter
Contents

Letter 1

Appendix I 

Comments From the

Department of

Defense

16

Appendix II 

Major Contributors to

This Report

29

Abbreviations

DOD Department of Defense

MTTR mean time to repair

MMH/FH maintenance man-hours per flight hour

Page 14 GAO/NSIAD-95-112 Comanche Helicopter
Page 15 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Note: GAO comments

supplementing those in the

report text appear at the

end of this appendix.

See comment 1.

See comment 2.

Page 16 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Page 17 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Now on pp. 3-5.

See comment 1.

Page 18 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

See pp. 11-12.

Now on p. 5.

Page 19 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Now on pp. 5-6.

Page 20 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Now on pp. 6-7.

Now on p. 7.

Page 21 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Now on pp. 7-8.

See comment 3.

Page 22 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Now on pp. 8-9.

See comment 3.

Now on p. 9.

Page 23 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

See comment 3.

Now on pp. 9-10.

See comment 4.

Page 24 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Now on pp. 10-11.

Page 25 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Page 26 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

Now on p. 12.

See pp. 11-12.

Now on p. 12.

See pp. 11-12.

Page 27 GAO/NSIAD-95-112 Comanche Helicopter
Appendix I 

Comments From the Department of Defense

The following are GAO’s comments on the Department of Defense’s (DOD)

letter dated April 20, 1995.

1. As DOD’s comments note, there are many measures of unit cost, such

as average unit flyaway cost, program acquisition unit cost, and unit

procurement cost. We believe that the program unit cost that we used in

the report—which the footnote in the report defines as total research,

development, and acquisition costs in current dollars—is as valid as

flyaway cost to portray program cost growth over time. We have adjusted

the report to more clearly define the basis of the unit cost we use.

2. These comments are dealt with on pages 11 and 12 of the report and in

our responses to the specific DOD comments that follow. Report material

on costs and concurrency has been revised to reflect information obtained

after our fieldwork had been concluded.

3. The report does not say that maintainability goals will never be met.

We pointed out that some key maintainability requirements are not being

met and, therefore, there is a risk that the Army may not achieve the lower

operating and support costs and wartime availability goals that it has

established for this program. We also said that individually, failure to meet

these parameters may not be a significant problem; however, collectively

they affect the ability of the Comanche to achieve the cost and availability

goals. This point is clearly illustrated in DOD’s comments on the failure of

the fault isolation system. According to DOD, “Fault isolation is one of the

key diagnostic system requirements. The DOD agrees that if the fault

isolation requirement is not met, the Comanche is unlikely to achieve its

mean-time-to-repair requirement, . . .”.

4. We still believe that this goal is very aggressive. DOD acknowledges

that this goal is stringent and the Army has not had good experience in the

past with false removals on other aircraft. Additionally, as noted in the

report, Army Materiel Systems Analysis Activity said the risk associated

with achieving this requirement remains high. We changed the section

heading to emphasize the high risk.

Page 28 GAO/NSIAD-95-112 Comanche Helicopter
Appendix II 

Major Contributors to This Report

National Security and

International Affairs

Division, Washington,

D.C.

Robert J. Stolba

Accounting and

Information

Management Division

David Chao

Kansas City Regional

Office

Gary L. Billen

Robert D. Spence

Lauri A. Bischof

Michael W. Buell

Karen A. Rieger

(707084) Page 29 GAO/NSIAD-95-112 Comanche Helicopter
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