Coast Guard: As Deepwater Systems Integrator, Coast Guard Is Reassessing Costs and Capabilities but Lags in Applying Its Disciplined Acquisition Approach
Published: 2009-07-14T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Deepwater Program includes efforts to build or modernize ships and aircraft and to procure other capabilities. In 2002, the Coast Guard contracted with Integrated Coast Guard Systems (ICGS) to manage the acquisition as systems integrator. After a series of project failures, the Coast Guard announced in April 2007 that it would take over the lead role, with future work on individual assets bid competitively, and a program baseline of $24.2 billion was set. In June 2008, GAO reported on the Coast Guard's progress and made several recommendations, which the Coast Guard and the Department of Homeland Security (DHS) have addressed. In response to a Senate report accompanying the DHS Appropriations Bill, 2009, GAO addressed (1) efforts to manage Deepwater, (2) changes in cost and schedule of the assets, and (3) efforts to build an acquisition workforce. GAO reviewed Coast Guard and DHS documents and interviewed officials.
section_title: What GAO Found
paragraphs: The Coast Guard has assumed the role of systems integrator for the overall Deepwater Program by reducing the scope of the work on contract with ICGS and assigning these functions to Coast Guard stakeholders. As part of its systems integration responsibilities, the Coast Guard has undertaken a fundamental reassessment of the capabilities, number, and mix of assets it needs and expects to complete this analysis by the summer of 2009. At the individual Deepwater asset level, the Coast Guard has improved and begun to apply the disciplined management process contained in its Major Systems Acquisition Manual (MSAM), but did not meet its goal of complete adherence to this process for all Deepwater assets by the end of March 2009. For example, key acquisition management activities--such as operational requirements documents and test plans--are not in place for assets with contracts or orders recently awarded (such as the Fast Response Cutter and C4ISR) or in production, placing the Coast Guard at risk of cost growth or schedule slips. In addition, the MSAM does not appear to be consistent with recent DHS policy that requires entities responsible for operational testing to be independent of the system's users. Due in part to the Coast Guard's increased insight into what it is buying, the anticipated cost, schedules, and capabilities of many Deepwater assets have changed since the $24.2 billion baseline was established in 2007. Coast Guard officials have stated that this baseline reflected not a traditional cost estimate, but rather the anticipated contract costs as determined by ICGS. As the Coast Guard has developed its own cost baselines for some assets, it has become apparent that some of these assets it is procuring will likely cost more than anticipated--up to $2.7 billion more based on information to date. This represents approximately 39 percent cost growth for the assets with revised cost estimates. As more cost baselines are developed and approved, further cost growth is likely. Updated baselines also indicate that schedules have slipped for several of the assets. In addition, the current structure of the Coast Guard's budget submission to Congress does not include details at the asset level, such as estimates of total costs and total numbers to be procured, as do those of the Department of Defense, which acquires similar systems. One reason the Coast Guard hired a contractor as a systems integrator was because it recognized that it lacked the experience and depth in workforce to manage the acquisition internally. The Coast Guard acknowledges that it still faces challenges in hiring and retaining qualified acquisition personnel and that this situation poses a risk to the successful execution of its acquisition programs. According to human capital officials in the acquisition directorate, as of April 2009, the acquisition branch had 16 percent of positions unfilled, including key jobs such as contracting officers and systems engineers. Even as it attempts to fill its current vacancies, the Coast Guard plans to increase the size of its acquisition workforce significantly; the fiscal year 2010 budget request includes funding for 100 new acquisition workforce positions. In the meantime, the Coast Guard has been increasing its use of support contractors.

section_title: Letter
paragraphs: The Deepwater Program—the largest acquisition program in the Coast  Guard’s history—began in the late 1990s as an effort to recapitalize the  Coast Guard’s operational fleet. The program now includes projects to  build or modernize five classes each of ships and aircraft, and  procurement of other capabilities such as improved command, control,  communications, computers, intelligence, surveillance, and  reconnaissance (C4ISR) and unmanned aircraft. Recognizing that it did  not have in place a workforce with the experience and depth to manage  the acquisition, the Coast Guard contracted with Integrated Coast Guard  Systems (ICGS) in June 2002 as a systems integrator for Deepwater. After  a series of programmatic failures, the Commandant acknowledged in April  2007 that the Coast Guard had relied too heavily on contractors to do the  work of the government and that government and industry had failed to  control costs. He announced several major changes to the acquisition  approach for Deepwater, the key one being that the Coast Guard would  take over the role of systems integrator from ICGS, with future work on  individual assets to be potentially bid competitively outside of the existing  contract. In May 2007, soon after this announcement, the Department of  Homeland Security (DHS) approved an acquisition program baseline of  $24.2 billion for the Deepwater Program.
In response to a direction in the Senate report accompanying the  Department of Homeland Security Appropriations Bill, 2009, and  discussions with your staff, we (1) evaluated Coast Guard efforts to  manage the Deepwater Program at both the overall system and asset  levels; (2) assessed changes in cost, schedules, and capabilities from the  2007 baseline; and (3) identified Coast Guard efforts to build its  acquisition workforce to manage this multibillion dollar program. This  report updates information contained in our April 2009 testimony to the  Homeland Security Subcommittee of the House Appropriations  Committee.
To conduct our work, we reviewed key Coast Guard documentation such  as the Major Systems Acquisition Manual (MSAM), Blueprint for  Acquisition Reform, original and recently approved acquisition program  baselines, and human capital plans. We interviewed Coast Guard  acquisition directorate officials, including program managers and  contracting officers, and officials from other Coast Guard directorates  such as those responsible for human capital issues and for assessing and  developing operational requirements for Deepwater assets. We also  interviewed officials from ICGS and its first-tier subcontractors Lockheed  Martin and Northrop Grumman Shipbuilding. In addition, we relied in part  on our past work on the Deepwater Program. Appendix I contains more  information regarding our scope and methodology. We conducted this  performance audit between September 2008 and July 2009 in accordance  with generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on our audit objectives. We believe that the evidence obtained  provides a reasonable basis for our findings and conclusions based on our  audit objectives.
subsections: section_title: Background
paragraphs: The Coast Guard is a multimission, maritime military service within DHS.  The Coast Guard’s responsibilities fall into two general categories—those  related to homeland security missions, such as port security and vessel  escorts, and those related to the Coast Guard’s traditional missions, such  as search and rescue and polar ice operations. To carry out these  responsibilities, the Coast Guard operates a number of vessels and aircraft  and, through its Deepwater Program, is currently modernizing or replacing  a number of those assets. Since 2001, we have reviewed the Deepwater  Program and have informed Congress, DHS, and the Coast Guard of the  risks and uncertainties inherent in the acquisition. In June 2008, we  reported on our assessment of the preliminary steps the Coast Guard had  taken to revise its acquisition approach. For example, we found that the  Coast Guard had increased accountability by bringing Deepwater under a  restructured acquisition function and investing its government project  managers with management and oversight responsibilities formerly held  by ICGS. In addition, the Coast Guard had begun to manage Deepwater  under an asset-based approach, resulting in increased government control  and visibility over acquisitions. We concluded that while these steps were  beneficial, continued oversight and improvement were necessary to  further mitigate risks and made several recommendations, which the  Coast Guard and DHS have taken actions to address.
At the start of the Deepwater Program in the late 1990s, the Coast Guard  chose to use a system-of-systems acquisition strategy. A system-of-systems  is defined as the set or arrangement of assets that results when  independent assets are integrated into a larger system that delivers unique  capabilities. As the systems integrator, ICGS was responsible for  designing, constructing, deploying, supporting, and integrating the  Deepwater assets into a system-of-systems. Under this approach, the  Coast Guard provided the contractor with broad, overall performance  specifications—such as the ability to interdict illegal immigrants—and  ICGS determined the assets needed and their specifications. According to  Coast Guard officials, the ICGS proposal was submitted and priced as a  package; that is, the Coast Guard bought the entire solution and could not  reject any individual component. In November 2006, the Coast Guard  submitted a cost, schedule, and performance baseline to DHS that  established the total acquisition cost of the ICGS solution at $24.2 billion  and projected that the acquisition would be completed in 2027. In May  2007, shortly after the Coast Guard had announced its intention to take  over the role of systems integrator, DHS approved the baseline.
From fiscal year 2002 to fiscal year 2009, over $6 billion has been  appropriated for the Deepwater Program, about 25 percent of the total  anticipated costs of $24.2 billion. Figure 1 depicts a breakdown of how  these appropriations have been allocated as of fiscal year 2009, including  for integration and oversight functions; ongoing Deepwater assets; and  assets that the Coast Guard has cancelled or restructured.
Regarding the breakout of appropriations through fiscal year 2009, the  $876 million appropriated for integration and oversight has been allocated  for activities such as planning for Deepwater logistics, obsolescence  prevention, government program management, and systems engineering  and integration. Of the $288 million allocated for cancelled or restructured  assets, the Coast Guard allocated about $134 million to ICGS for two  projects that were subsequently cancelled: an estimated $95 million to  extend the Coast Guard’s 110-foot patrol boats by an additional 13 feet  (known as the 123-foot patrol boat conversions) and approximately $39  million for the initial design of the Fast Response Cutter (known as FRC- A). The Coast Guard terminated the design efforts for the FRC-A in  February 2008. In addition, three projects received significant funding  before being restructured or redesigned. The Coast Guard allocated  approximately $119 million to ICGS for the Vertical Unmanned Aerial  Vehicle before stopping work on the design in 2007 due to developmental  and cost concerns. Over $27 million was allocated for the Offshore Patrol  Cutter (OPC) before design work was stopped in 2006, and over $8 million  was allocated for cutter small boats before a decision was made in 2008 to  take a different acquisition approach for those assets. The Coast Guard is  now considering alternative designs for all three of these assets.
Table 1 describes in more detail the assets the Coast Guard is planning to  procure or upgrade under the Deepwater Program according to approved  acquisition baselines.
section_title: Coast Guard Has Assumed the Role of Systems Integrator but Lags in Applying Disciplined Asset- Level Processes as It Continues with Procurements
paragraphs: The Coast Guard has assumed the role of systems integrator for  Deepwater, concurrently downsizing the scope of systems engineering and  integration work under contract with ICGS. In conjunction with its role as  systems integrator, the Coast Guard has undertaken a fundamental  reassessment of the capabilities and mix of assets it needs to meet its  Deepwater missions. In addition, DHS and the Coast Guard have made  improvements in oversight and management of Deepwater; for example,  the Coast Guard has made progress in applying the MSAM acquisition  process to individual Deepwater assets and made improvements to the  process as a whole. However, the Coast Guard did not meet its goal of  having all assets fully compliant with the MSAM by the end of March 2009.  Hence, acquisition decisions for certain assets are being made without  having completed some key acquisition documentation in light of what the  Coast Guard views as pressing operational needs.
subsections: section_title: Coast Guard Has Assumed Key Systems Integrator Roles and Responsibilities from ICGS and Reduced Contractor’s Scope of Work
paragraphs: The role of systems integrator involves determining the mix of assets  needed to fulfill mission needs, as well as designing, procuring, and  integrating those assets into a system-of-systems capability greater than  the sum of the individual parts. ICGS’s role as systems integrator for the  Deepwater Program included managing requirements, determining how  assets would be acquired, defining how assets would be employed by  Coast Guard users in an operational setting, and exercising technical  authority over all asset design and configuration. In 2008, the Coast Guard  acknowledged that in order to assume the role of systems integrator, it  needed to define systems integrator functions and assign them to Coast  Guard stakeholders. As a result, the Coast Guard has established new  relationships among its directorates to assume control of key systems  integrator roles previously carried out by the contractor. Through a series  of policy changes and memoranda, the Coast Guard formally designated  certain directorates as technical authorities responsible for establishing,  monitoring, and approving technical standards for Deepwater assets  related to design, construction, maintenance, logistics, C4ISR, and life- cycle staffing and training. Furthermore, the Coast Guard’s capabilities  directorate is now responsible for determining operational requirements  and the asset mix to satisfy those requirements. This directorate is  expected to collaborate with the technical authorities to ensure that the  Coast Guard’s technical standards are incorporated during the  requirements development process. Finally, the acquisition directorate’s  program and project managers are responsible for procuring the assets  and are to be held accountable for ensuring that they fulfill the operational  requirements and the technical authority standards established by the  other directorates.
The collaborative relationships among the Coast Guard directorates  discussed above are depicted in figure 2.
When it contracted with ICGS in 2002, the Coast Guard lacked insight into  how the contractor’s proposed solution for Deepwater would meet overall  mission needs. This situation limited the Coast Guard’s ability to make  informed decisions about possible trade-offs between cost and capability.  As a way of improving its insight, the capabilities directorate has initiated  a fundamental reassessment of the capabilities and mix of assets the Coast  Guard needs to fulfill its Deepwater missions. The goals of this fleet mix  analysis include validating mission performance requirements and  revisiting the number and mix of all assets that are part of the Deepwater  Program. A specific part of the study will also analyze alternatives and  quantities for the OPC, which currently accounts for a projected $8  billion—about 33 percent—of total Deepwater costs. Coast Guard  leadership intends to base future procurement decisions on the results of  this analysis, which is expected to be completed in the summer of 2009.  According to a senior official in the capabilities directorate, the directorate  has recommended that this type of analysis be repeated every 4 years, or  once during each commandant’s tenure.
In conjunction with assuming the role of systems integrator, the Coast  Guard has reduced the scope and volume of ICGS’s systems engineering  and integration functions. For example, the most recent systems  engineering and integration task order, issued to ICGS in March 2009, is  limited to support services such as data management and quality  assurance for the assets currently on contract with ICGS, such as the  Maritime Patrol Aircraft (MPA), the National Security Cutter (NSC), and  C4ISR. By contrast, under the prior systems engineering and integration  task order, ICGS was responsible for systems integrator functions such as  developing the mix of assets to meet Coast Guard missions, the  development of operational concepts, requirements management, test and  evaluation management, and a number of other program management and  system-of-systems level functions.
While the Coast Guard does not intend to cancel ongoing orders with ICGS  for services or assets, it does not plan to acquire future assets from ICGS.  A step in this direction was the September 2008 competitive award of the  Fast Response Cutter to Bollinger Shipyards, Inc. Further, while ICGS will  continue to be responsible for the construction and delivery of the first  three NSCs, the Coast Guard intends to award contracts for construction  and long-lead-time materials for future NSCs directly to ICGS  subcontractor Northrop Grumman Shipbuilding. The Coast Guard’s  decision was formalized in a March 2009 contract modification with ICGS  stating that it will not award future work to ICGS after the current award  term ends in January 2011.
Table 2 shows that, as of May 2009, the Coast Guard has about $2.3 billion  under contract with ICGS in ongoing work. The table does not include the  total potential value of options and modifications that could be exercised  before the current award term expires.
section_title: Coast Guard and DHS Have Improved Oversight of the Deepwater Program but Gaps in Knowledge Remain Even as Production and Award of New Contracts Proceed
paragraphs: Since our June 2008 report on the Deepwater Program, and taking into  account our recommendations, the Coast Guard and DHS have taken steps  to improve management and oversight of Deepwater. We reported, for  example, that the Coast Guard had transitioned from a system-of-systems  acquisition approach to an asset-based approach that reflects the  disciplined and formalized process outlined in its MSAM. While the  introduction of this process was a significant improvement, we found that  the absence of a key milestone decision point before low-rate initial  production begins was problematic and put program outcomes at risk. In  response to our recommendation, the Coast Guard revised its MSAM to  require a formal design review, termed “acquisition decision event 2B,” to  ensure that risks are appropriately addressed before low-rate initial  production is authorized. The MSAM phases and acquisition decision  events are shown in figure 3.
The Coast Guard has made other improvements to its MSAM process. For  example, the MSAM now includes standardized cost-estimating  procedures to provide an accounting of all resources required to develop,  produce, deploy, and sustain a program. Before, there was minimal  guidance in the manual about the cost-estimating process; it now includes  a full description of the process and a cost-estimating template for project  managers. The MSAM process was also revised to require acquisition  planning and an early affordability assessment prior to acquisition  decision event 1 (the “analyze/select” phase), to help inform the budget  and planning processes.
DHS has also improved its oversight and management of the Deepwater  Program by reviewing the program under its own acquisition processes. In  June 2008, we reported that DHS approval of Deepwater acquisition  decisions at key points in the program was not required, as the department  had deferred decisions on specific assets to the Coast Guard in 2003. We  recommended that DHS rescind the delegation of Deepwater acquisition  authority, and, in September 2008, the Under Secretary did so. As a result,  DHS officials are now formally involved in reviewing and approving  acquisition decisions for Deepwater assets at key points in the program’s  life cycle. In November 2008, DHS issued a new interim management  directive that, if implemented as intended, should help ensure that the  department’s largest acquisitions, including Deepwater, are more  effectively overseen and managed.
Because the Coast Guard had previously exempted Deepwater from its  MSAM process, assets were procured without following a disciplined  program management approach. Recognizing the importance of ensuring  that each acquisition project is managed through a sustainable and  repeatable process and wanting to adhere to proven acquisition  procedures, in July 2008 the Coast Guard set a goal of completing the  MSAM acquisition management activities for all Deepwater assets by the  end of March 2009. However, of the 13 Deepwater assets, 9 were behind  schedule in terms of MSAM compliance as of May 2009, as not all required  documents and processes had been completed. Not complying with the  MSAM process puts the Coast Guard at risk of buying assets that do not  fully meet its needs and that may experience cost growth and schedule  slips.
subsections: section_title: Offshore Patrol Cutter and Unmanned Aerial System
paragraphs: Assets that are early in the development cycle, such as the Offshore Patrol  Cutter (OPC) and the Unmanned Aerial System, are at present compliant  with the MSAM process. For example, the MSAM directs the capabilities  directorate to charter an integrated product team to develop operational  requirements for Coast Guard assets. This approach is currently being  applied to the OPC, which is in the “analyze/select” phase of the MSAM  process. In accordance with MSAM guidelines, the OPC requirements team  includes representatives from the Coast Guard’s technical authorities,  acquisition project managers, test and evaluation officials, and research  and development officials. The goal of this process is to develop  operational requirements that are specific, testable, prioritized, and  defendable in order to adequately support the acquisition process and  satisfy users’ needs. The Coast Guard plans to continue to follow the  MSAM process, under which the operational requirements document and  other key acquisition documents will be approved by the Coast Guard and  DHS prior to the OPC entering the “obtain” phase, when capabilities are  developed and demonstrated. For the Unmanned Aerial System, currently  in the “need” phase of the acquisition process, the Coast Guard’s Office of  Research, Development, Test and Evaluation is currently conducting  preacquisition studies and tests to identify alternative approaches to  fulfilling mission requirements for maritime surveillance and inform early  cost estimates. Through these activities, the Coast Guard intends to  mitigate risks by identifying approaches with high levels of technical and  production maturity and leveraging development efforts underway by the  Department of Defense and DHS.
section_title: Maritime Patrol Aircraft and National Security Cutter
paragraphs: For assets well into production, such as the MPA and the NSC, the Coast  Guard has made some progress in the past year in retroactively developing  acquisition documentation with the intent of providing the traceability  from mission needs to operational performance that was previously  lacking. For example, the Coast Guard approved an operational  requirements document for the MPA in October 2008, to establish a formal  performance baseline and identify attributes for testing. Through this  process, the Coast Guard discovered that ICGS’s requirement for  operational availability (the amount of time that an aircraft is available to  perform missions) was excessive compared to the Coast Guard’s own  standards. According to a senior Coast Guard official responsible for  managing aviation assets, the ICGS requirement would have needlessly  increased costs to maintain and operate the aircraft.
In addition to revisiting its requirements for the MPA, the Coast Guard is  also revising its plans to test and procure the asset. In February 2009, the  Coast Guard submitted an MPA test plan to DHS with the intent of  obtaining approval for full-rate production based on the results of a  November 2008 operational assessment conducted by the U.S. Navy’s  Commander Operational Test and Evaluation Force (COMOPTEVFOR). In  April 2009, the DHS Director, Operational Test and Evaluation, approved  the plan for testing leading up to initial operational test and evaluation, but  required the Coast Guard to update and resubmit the plan before  operational testing begins. DHS and Coast Guard policy require  operational testing to be conducted before full-rate production is  approved. According to the senior official responsible for managing  aviation assets, the Coast Guard now plans to obtain DHS approval to  order further low-rate initial production aircraft at the next MPA  acquisition decision event, scheduled for the end of fiscal year 2009. With  11 of 36 MPAs already delivered or on contract, the Coast Guard has  already made a significant investment in this program before the testing  that would demonstrate that what it is buying meets Coast Guard needs.
DHS also required the Coast Guard to obtain concurrence with the test  plan from an operational test authority before proceeding with operational  testing of the MPA. According to DHS and Coast Guard policy, operational  testing should be conducted with the approval and under the oversight of  an independent operational test authority to ensure that tests are clearly  linked to requirements and mission needs. However, the MSAM appears to  be inconsistent with DHS policy regarding who this test authority should  be. The DHS Acquisition Guidebook states that an operational test  authority should be independent of both the acquirer and user, which  allows the test authority to present objective and unbiased conclusions  about an asset’s operational effectiveness and suitability. Further, a DHS  directive on test and evaluation issued in May 2009 distinguishes between  the “sponsor” (or user of the system), who is responsible for defining the  system’s operational requirements, and the operational test agent, who  plans, conducts, and reports independent operational test and evaluation  results. The MSAM, on the other hand, assigns responsibility for planning  and conducting operational testing to the sponsor—the Coast Guard’s  capabilities directorate—which represents the end user. While the Coast  Guard has a memorandum of agreement with COMOPTEVFOR to leverage  the Navy’s experience and expertise in conducting operational testing for  the MPA, the Coast Guard’s position is that its capabilities directorate can  function as the operational test authority, as it is independent of the  acquisition program office. The Director, DHS Test & Evaluation and  Standards said that, particularly given the recent change to the  department’s test and evaluation directive, the MSAM does not appear to  be consistent with DHS policy regarding the operational test authority.
The Coast Guard has also made a significant investment in the NSC  program before completing operational testing to demonstrate that the  capabilities it is buying meet Coast Guard needs. While some testing of the  NSC has already taken place, the tests conducted to date do not substitute  for the complete scope of operational testing that should be the basis for  further investment. For example, COMOPTEVFOR completed an  operational assessment of the NSC in 2007 to identify risks to the  program’s successful completion of operational testing. Before the first  NSC was delivered, it also underwent acceptance trials, conducted by the  U.S. Navy Board of Inspection and Survey, to determine compliance with  contract requirements and to test system capabilities. Since delivery of the  first NSC, the Coast Guard has also conducted flight deck and combat  system certifications with the assistance of the Navy. While these  demonstrations and certifications provide evidence that the first NSC  functions as intended, they do not fully demonstrate the suitability and  effectiveness of the ship for Coast Guard operations. According to  officials, a test plan to demonstrate these capabilities is expected to be  approved in July 2009, and COMOPTEVFOR may begin operational testing  in March 2010. However, by the time full operational testing is scheduled  to be completed in 2011, the Coast Guard plans to have six of eight NSCs  either built or under contract.
section_title: Fast Response Cutter and C4ISR
paragraphs: Based on its determination that the need for the capabilities to be  provided by the Fast Response Cutter and C4ISR is pressing, the Coast  Guard has contracted for these capabilities without having in place all  acquisition documentation required by the MSAM. This situation puts the  Coast Guard at risk for cost overruns and schedule slips if it turns out that  what it is buying does not meet its requirements. For example, in  September 2008, after conducting a full and open competition, the Coast  Guard awarded an $88.2 million contract to Bollinger Shipyards, Inc. for  the design and construction of a lead Fast Response Cutter. Prior to the  award, however, the Coast Guard did not have an approved operational  requirements document or test plan for this asset as required by the MSAM  process. Recognizing the risks inherent in this approach, the Coast Guard  developed a basic requirements document and an acquisition strategy  based on procuring a proven design. These documents were reviewed and  approved by the Coast Guard’s capabilities directorate, the engineering  and logistics directorate, and chief of staff before the procurement began.  The Coast Guard’s next acquisition decision event is scheduled for the first  quarter of fiscal year 2010 to obtain DHS approval for low-rate initial  production. According to officials, the Coast Guard intends to submit an  operational requirements document and test plan to DHS for this  acquisition decision event. With plans to exercise contract options for  hulls 2 through 8 in fiscal year 2010, the Coast Guard’s aggressive schedule  leaves little room for unforeseen problems. Program risks are  compounded by the fact that the Coast Guard plans to have at least 12  cutters either delivered or under contract prior to the scheduled  completion of operational testing in fiscal year 2012, before it has certainty  that what it is buying meets Coast Guard needs.
The Coast Guard has also continued its procurement of C4ISR capabilities  without an approved operational requirements document as required by  the MSAM. C4ISR encompasses the connections between surface, aircraft,  and shore-based assets and is intended to provide operationally relevant  information to Coast Guard field commanders. Design and development  costs for the first increment of C4ISR have increased significantly, from  $55.5 million to $141.3 million. According to Coast Guard officials, this  increase was due in part to the structure of the ICGS contract, under  which the Coast Guard lacked visibility into the contractor’s software  development processes and requirements. In addition, the ICGS C4ISR  solution developed under the first increment contained Lockheed Martin- proprietary software, making the Coast Guard reliant on the contractor for  maintenance and support.
In February 2009, the Coast Guard issued a task order to ICGS, with a total  potential value of $77.7 million, for a second increment of C4ISR design  and development. It was not until May 2009, however, that the  capabilities directorate reviewed and concurred with the capabilities  identified in the acquisition plan. Coast Guard officials stated that the  Coast Guard’s technical authority for C4ISR reviewed the acquisition plan  and statement of work to ensure conformance with Coast Guard technical  standards, but the officials said there is no operational requirements  document for this increment. The lack of operational requirements may  put the program at continued risk of cost increases if the Coast Guard  determines that what it is buying does not meet its needs. Through the  award of the second C4ISR increment, the Coast Guard has acquired some  of the data rights to the proprietary software developed under the first  increment. The Coast Guard’s goal is to gain greater visibility into the  software in order to compete future increments. According to officials,  future decisions about the C4ISR acquisition rest on the Coast Guard’s  ability to affordably maintain and support the C4ISR software and ensure  interoperability between Deepwater assets and the Coast Guard as a  whole; however, the Coast Guard has not yet determined how it will do so.  According to officials, acquisition of the third C4ISR increment will adhere  to the MSAM process, and documents critical to determining and testing  requirements and capabilities will be completed and approved by DHS  before the Coast Guard proceeds with a contract award in about 2 years.
section_title: Coast Guard Developing Better- Informed Cost and Schedule Estimates for Deepwater Assets, but Reporting May Not Keep Congress Fully Informed
paragraphs: Due in part to the Coast Guard’s increased insight into what it is buying,  the anticipated cost, schedules, and capabilities of many of the Deepwater  assets have changed since the establishment of the $24.2 billion baseline in  2007. Coast Guard officials have stated that this baseline reflected not a  traditional cost estimate, but rather the anticipated contract costs as  determined by ICGS. As the Coast Guard has developed its own cost  baselines, it has become apparent that some of the assets will likely cost  more than anticipated. Information to date shows that the total cost of the  program will likely grow by at least $2.7 billion. This represents growth of  approximately 39 percent for those assets with revised cost estimates.  Furthermore, assets may be ready for operational use later than  anticipated in the 2007 baseline and, at least initially, lack some of the  capabilities envisioned. As the Coast Guard develops more baselines,  further cost and schedule growth is likely to become apparent. While the  Coast Guard plans to update its annual budget requests with this new  information, the current structure of its budget submission to Congress  does not include details at the asset level, such as estimates of total costs  and total numbers to be procured.
subsections: section_title: Better-Informed Baselines Suggest Deepwater Costs Could Exceed $24.2 Billion
paragraphs: The $24.2 billion baseline for the Deepwater Program established cost,  schedule, and operational requirements for the Deepwater system as a  whole; these were then allocated to the major assets. Coast Guard officials  have stated that this baseline reflected not a traditional cost estimate but  ICGS’s anticipated contract costs. Furthermore, the Coast Guard lacked  insight into how ICGS arrived at some of the costs for Deepwater assets.  As the Coast Guard has assumed greater responsibility for management of  the Deepwater Program, it has begun to improve its understanding of costs  by establishing new baselines for individual assets based on its own cost  estimates. These baselines begin at the asset level and are developed by  Coast Guard project managers, validated by a separate office conducting  independent cost estimates within the acquisition branch and, in most  cases, are reviewed and approved by DHS. The estimates use common  cost-estimating procedures and assumptions and account for costs not  previously captured. As of June 2009, the Coast Guard had prepared 10  revised asset baselines. Two were approved by the Coast Guard (for the  sustainment projects for the medium endurance cutter and the patrol  boats) and 8 had been submitted to DHS, which had approved 5 of them.  These new baselines are formulated using various sources of information,  depending on the acquisition phase of the asset. For example, the baseline  for the NSC was updated using the actual costs of material, labor, and  other considerations already in effect at the shipyards. The baselines for  other assets, like the MPA, were updated using independent cost  estimates. As the Coast Guard approaches major milestones on Deepwater  assets, such as the decision to enter low-rate initial production or to begin  system development, officials have stated that the cost estimates for all  assets will be reassessed and revalidated.
In developing its own asset baselines, the Coast Guard has found that  some of the assets will likely cost more than anticipated. As of June 2009,  with 7 of the 10 baselines approved, the total cost of the program will  likely exceed $24.2 billion, with potential cost growth of approximately  $2.7 billion. For the assets with revised cost estimates, this represents cost  growth of approximately 39 percent. As baselines for the additional assets  are approved, further cost growth will likely become apparent. Table 3  provides the revised estimates of asset costs available as of June 2009. It  does not reflect the roughly $3.6 billion in other Deepwater costs, such as  program management, that the Coast Guard states do not require a new  baseline.
The Coast Guard’s new baselines provide not only a better understanding  of the costs of Deepwater assets, but also insight into the drivers of any  cost growth. For example, the new NSC baseline attributes a $1.3 billion  rise in cost to a range of factors, from the additional costs to correct  fatigue issues on the first three cutters—estimated by the Coast Guard to  add an additional $86 million—to changes in economic factors such as  labor and commodity prices that add an additional $434 million to the cost  of the first four ships. The $517 million rise in cost for the MPA is  attributed primarily to items that were not previously accounted for,  including $36 million for a training simulator, $30.6 million in facility  improvements, and $124 million for sufficient spare parts. An additional  $115.9 million is attributable to cost growth for the aircraft and  engineering changes.
The Coast Guard has structured some of the new baselines to indicate how  cost growth could be controlled by making trade-offs in asset quantities  and/or capabilities. For example, the new MPA baseline includes cost  increments that show the acquisition may be able to remain within the $1.7  billion estimate established in the 2007 baseline if 8 fewer aircraft than the  planned 36 are acquired. Coast Guard officials have stated that other  baselines currently under review by DHS present similar cost increments.  This information, if combined with data from the fleet mix study to show  the effect of quantity or capability reductions on the system-of-systems as  a whole, offers an opportunity to the Coast Guard for serious discussions  of cost and capability trade-offs. Given the approximately 39 percent cost  growth for the Deepwater assets that have revised cost estimates, the  trade-off assessment is critical—particularly with regard to the OPC,  which currently represents a substantial portion of the planned Deepwater  investment.
The Coast Guard’s reevaluation of baselines has also improved insight into  the schedules for when assets will first be available for operations and  when final assets will be delivered. For example, the initial operating  capability of the first NSC has been delayed by a year as compared to the  schedule in the 2007 baseline, and the MPA has been delayed by 21  months. Table 4 provides more information on initial operational  capability and final asset delivery schedules for Deepwater assets that  have had revised baselines approved. Other assets have baselines either  with DHS for approval or are in development.
Since many Deepwater assets are intended to replace older Coast Guard  assets, delays in their introduction and final deliveries could have an effect  beyond the Deepwater Program. For example, the NSC—together with the  OPC—is intended to replace older High Endurance and Medium  Endurance Cutters, some of which have been in service for over 40 years.  According to Coast Guard officials, the longer these older cutters remain  in service—due to a delay in the introduction of the NSC or the OPC to the  fleet or delays in delivering all of the assets—the more funding will be  required for maintenance of assets that are being replaced. According to a  senior official in the Coast Guard’s acquisition directorate, additional,  unplanned funding will be required for a sustainment project to keep the  High Endurance Cutters in service longer than anticipated. An acquisition  strategy to achieve this project is currently in development.
The Coast Guard’s reevaluation of baselines has also changed its  understanding of the capabilities of Deepwater assets. For example, Coast  Guard officials stated that the restructuring of the unmanned aircraft and  small boat projects has delayed the deployment of these assets with the  first NSC and reduces the ship’s anticipated capabilities in the near term.  We plan to report this summer on the operational effect of these delays on  the NSC.
section_title: Current Budget Reporting Lacks Detail at Asset Level and Limits Congressional Insight
paragraphs: The Coast Guard’s budget submission, as currently structured, limits  Congress’s understanding of details at the asset level in so far as it does  not include key information such as assets’ total acquisition costs or, for  the majority of assets, the total quantities planned. For example, while the  justification of the NSC request includes a detailed description of expected  capabilities and how these capabilities link to the Coast Guard’s missions  and activities funded by past appropriations, it does not include estimates  of total program cost, future award or delivery dates of remaining assets,  or even the total number of assets to be procured.
Our past work has emphasized that one key to a successful capital  acquisition, such as the multibillion-dollar ships and aircraft the Coast  Guard is procuring, is budget submissions that clearly communicate  needs. An important part of this communication is to provide decision  makers with information about cost estimates, risks, and the scope of a  planned project before substantial resources are committed. Good  budgeting also requires that the full costs of a project be considered  upfront when decisions are made. Other federal agencies that acquire  systems similar to those of the Coast Guard, such as the Department of  Defense, capture these elements in justifications of their budget requests.  To illustrate, table 5 provides a comparison of the information found in the  NSC budget justification with that the Navy is required to use in the  Department of Defense regulations for its shipbuilding programs.
While the Coast Guard’s asset-level Quarterly Acquisition Reports to  Congress and the annual Deepwater Program Expenditure Report include  some information on total costs and quantities, these documents are  provided only to the appropriations committees, and they contain selected  information that is restricted due to acquisition sensitive material. The  budget justification prepared by the Coast Guard is a tool that Congress  uses in its budget and appropriations deliberations. Presentation of  information on the full costs and quantities of Deepwater assets in the  Coast Guard’s budget submission can provide Congress greater insights in  fulfilling its roles of providing funding and conducting oversight.
section_title: Coast Guard Having Difficulty Staffing Government Acquisition Positions but Working to Improve Processes
paragraphs: The Coast Guard sought a systems integrator at the outset of the  Deepwater Program in part because its workforce lacked the experience  and depth to manage the acquisition internally. The Coast Guard  acknowledges that it still faces challenges in hiring and retaining qualified  acquisition personnel and that this situation poses a risk to the successful  execution of its acquisition programs. According to human capital officials  in the acquisition directorate, as of April 2009 the acquisition branch had  funding for 855 military and civilian personnel and had filled 717 of these  positions—leaving 16 percent unfilled. The Coast Guard has identified  some of these unfilled positions as core to the acquisition workforce, such  as contracting officers and specialists, program management support staff,  and engineering and technical specialists. Even as it attempts to fill its  current vacancies, the Coast Guard plans to increase the size of its  acquisition workforce significantly by the end of fiscal year 2011. For  example, the Coast Guard’s fiscal year 2010 budget request includes  funding for 100 new acquisition workforce positions, and the Coast Guard  anticipates requesting funding for additional positions in future budget  requests.
subsections: section_title: Coast Guard Has Expanded Collaboration with Independent Third Parties and Increased Use of Support Contractors to Assist with Acquisitions
paragraphs: To supplement and enhance its internal expertise, the Coast Guard has  increased its use of third-party, independent experts from outside both the  Coast Guard and existing Deepwater contractors. For example, a number  of organizations within the Navy have provided views and expertise on a  wide range of issues, including testing and safety. In addition, the Coast  Guard plans to use the American Bureau of Shipping, an organization that  establishes and applies standards for the design and construction of ship  and other marine equipment, as an advisor and independent reviewer on  the design and construction of the Fast Response Cutter. The Coast Guard  has also begun a relationship with a university-affiliated research center to  supplement its expertise as it executes its fleet-mix analysis.
In addition to third-party experts, the Coast Guard has been increasing its  use of support contractors. As of fiscal year 2009, approximately 170  contractor employees supported the acquisition directorate, a number that  has steadily increased in recent years. These contractors are performing a  variety of services—some of which support functions the Coast Guard has  identified as core to the government acquisition workforce—including  project management support, engineering, contract administration, and  business analysis and management. While support contractors can provide  a variety of essential services, their use must be carefully overseen to  ensure that they do not perform inherently governmental roles. The Coast  Guard, acknowledging this risk, is monitoring its use of support  contractors to properly identify the functions they perform and has  developed a policy to define what is and what is not inherently  governmental.
section_title: Coast Guard Has Made Progress in Identifying and Mitigating Acquisition Workforce Challenges
paragraphs: While the Coast Guard may be hard-pressed to fill the government  acquisition positions it has identified both now and in the future, it has  made progress in identifying the broader challenges it faces and is working  to mitigate them. The Coast Guard has updated two documents key to this  effort, the Blueprint for Acquisition Reform, now in its third iteration,  and the Acquisition Human Capital Strategic Plan, which is in its second  iteration. Each document identifies challenges the Coast Guard faces in  developing and managing its acquisition workforce and outlines initiatives  and policies to meet these challenges. For example, the Acquisition  Human Capital Strategic Plan sets forth three overall challenges and  outlines over a dozen strategies for addressing them in building and  maintaining an acquisition workforce. The discussion of strategies  includes status indicators and milestones for monitoring progress, as well  as supporting actions such as the formation of partnerships with the  Defense Acquisition University and continually monitoring turnover in  critical occupations. The Blueprint for Acquisition Reform supports  many of these initiatives and provides deadlines for their completion. In  fact, the Coast Guard has already completed a number of initiatives  including    achieving and maintaining Level III program manager certifications,    adopting a model to assess future workforce needs,   incorporating requests for additional staff into the budget cycle,   initiating tracking of workforce trends and metrics,    expanding use of merit-based rewards and recognitions, and  initiating training on interactions and relationships with contractors.
section_title: Conclusions
paragraphs: In assuming the role of systems integrator, the Coast Guard has made a  major change in its management of the Deepwater Program, one that has  increased its insight into the capabilities needed to fulfill Coast Guard  missions, the costs and capabilities of what it is currently procuring, and  what resources are needed to complete the acquisition. The continued  application and improvement of the disciplined management processes  inherent in the MSAM are also beneficial in helping to ensure that  Deepwater assets are designed and delivered to meet mission needs. While  these changes, as well as the additional oversight gained by DHS’s  participation in acquisition decisions, do not eliminate the risks associated  with this multibillion-dollar acquisition, they do help ensure that program  risks are more fully considered. However, the Coast Guard has not applied  the disciplined acquisition process to the FRC and the second increment  of C4ISR, recent contract actions that will involve additional investments  of taxpayer dollars over time. Further, as operational testing proceeds for  Deepwater assets, the MSAM appears to be inconsistent with DHS policy  and the recent directive on test and evaluation, which require operational  test authorities to be independent of the system’s user. Finally, in light of  the sheer size and scope of the Deepwater Program and Congress’s role in  providing funds, the Coast Guard’s budget submissions do not provide a  complete picture of the planned costs of Deepwater assets that would help  inform the decision-making process.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Commandant of the Coast Guard take the  following three actions:    Do not exercise further options under the Fast Response Cutter contract  and under the task order for the second increment of C4ISR until these  projects are brought into full compliance with the MSAM and DHS  acquisition directives.
Consult with the DHS Office of Test & Evaluation and Standards to  determine whether the MSAM conflicts with DHS’s directive regarding the  entity named as the independent operational test authority and, if so, take  steps to reconcile the inconsistency.
As the Coast Guard prepares future budget submissions for Deepwater,  include the total acquisition costs for the assets and total quantities  planned.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, the Coast Guard concurred  with our findings. The agency also stated that it concurred with our  recommendation to not exercise further contract options on the Fast  Response Cutter and the second increment of C4ISR until these projects  are brought into full compliance with the MSAM and DHS acquisition  directives, as well as our recommendation to consult with DHS on policies  regarding the independent operational test authority. DHS intends to take  our final recommendation, to provide total acquisition costs and quantities  in future budget submissions, under advisement. DHS noted that the  proposed changes could result in the Coast Guard failing to comply with  DHS budget submission guidelines and that Congress currently receives  long-term acquisition project information through the Quarterly  Acquisition Report to Congress. While we agree that this report includes  some information on total costs and quantities, as we state in the report, it  is provided only to the appropriations committees and contains other  information that is restricted and limits its distribution, and therefore its  utility, to decision makers. Presentation of information on the full costs  and quantities of Deepwater assets in the Coast Guard’s budget  submission can provide the information to a wider audience and better  assist Congress in providing funding and conducting oversight.
The comments from DHS are included in their entirety in appendix II.  Technical comments were also provided and incorporated into the report  as appropriate.
We are sending copies of this report to interested congressional  committees, the Secretary of Homeland Security, and the Commandant of  the Coast Guard. This report will also be available at no charge on GAO’s  Web site at http://www.gao.gov.
If you or your staff have any questions about this report or need additional  information, please contact me at (202) 512-4841 or huttonj@gao.gov.
Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this report. Staff  acknowledgements are provided in appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: Overall, in conducting this review, we relied in part on the information and  analysis in our April 2009 testimony, Update on Deepwater Program  Management, Cost, and Acquisition Workforce and our June 2008 report,  Change in Course Improves Deepwater Management and Oversight, but  Outcome Still Uncertain. Additional scope and methodology information  on each objective of this report follows.
To assess the Coast Guard’s efforts to manage the Deepwater Program at  the overall system-of-systems level, we reviewed the Coast Guard’s July  2008 Blueprint for Acquisition Reform, work group charters, and plans  and actions the Coast Guard has taken to assume the role of systems  integrator. To understand how the Coast Guard defined and assigned  systems integrator roles and responsibilities, we reviewed the Coast  Guard’s Major Systems Acquisition Manual (MSAM) and technical  authority instructions. We also interviewed senior acquisition directorate  officials, representatives of the Coast Guard’s capabilities directorate, and  representatives of Coast Guard’s technical authorities. To analyze the  scope and volume of work currently under contract with Integrated Coast  Guard Systems (ICGS) and the Coast Guard’s plans to end its contractual  relationship with ICGS, we reviewed task orders, contract statements of  work, and acquisition plans and interviewed senior acquisition directorate  officials and contracting officials. To assess the Coast Guard’s  implementation of a disciplined, project management process for  Deepwater acquisitions, we reviewed the most recent update to Coast  Guard’s MSAM and the Department of Homeland Security’s (DHS)  November 2008 Interim Acquisition Directive 102-01 as well as how  individual assets were complying with both sets of guidance. We  compared these policies with best practices reflected in previous GAO  work on major acquisitions. We also interviewed acquisition directorate  officials and program and project managers to discuss ongoing efforts to  transition the acquisition of Deepwater assets to the MSAM process and  spoke with DHS officials about the department’s major acquisition review  process and reporting requirements. We also interviewed Coast Guard  officials and analyzed documentation for the fleet-mix analysis currently  being conducted by the capabilities directorate. We conducted case  studies of selected assets, representing some that are in production as well  as some with recent contract awards. This analysis included reviews of  acquisition program baselines, operational requirements documents, test  plans, and other key acquisition documentation and interviews with  program and project managers and independent test authority officials. In  addition, we met with contractor and Coast Guard officials at Lockheed  Martin’s facilities in Moorestown, New Jersey and ICGS’s offices in  Arlington, Virginia to discuss the transition of systems integrator functions  and current work on C4ISR capabilities. We also met with Coast Guard  officials at the Aviation Logistics Center in Elizabeth City, North Carolina  to discuss their role in upgrading and maintaining Deepwater assets, and  the U.S. Navy’s Commander Operational Test and Evaluation Force in  Norfolk, Virginia to discuss their role in conducting operational testing.  Finally we met with Coast Guard officials and toured facilities and ships,  including the National Security Cutter Bertholf in Alameda, California.
To assess how cost, schedules, and capabilities have changed from the  2007 Deepwater Acquisition Program Baseline approved by DHS, we  reviewed that baseline and compared it to the revised baselines for  individual assets that have been approved to date. We also interviewed  senior acquisition directorate officials and program and project managers  to discuss how the Coast Guard is developing new acquisition program  baselines for individual assets and how the process used differs from that  in the 2007 baseline, such as the basis for cost estimates. We reviewed the  Coast Guard’s guidance and policy on cost estimating in the MSAM and  compared it to GAO best practices, including our Cost Assessment Guide:  Best Practices for Estimating and Managing Program Costs. We also  reviewed operational requirements documents and project reports for  selected assets in various stages of the development and production  processes to understand the major drivers of cost growth, schedule delays,  and capability changes. We interviewed acquisition directorate officials  and program and project managers to discuss options for controlling cost  growth by making trade-offs in asset quantities and/or capabilities, as well  as some of the potential implications of unplanned schedule delays. To  assess how well costs are communicated to Congress, we reviewed the  Office of Management and Budget’s guidance on budget justifications, the  Coast Guard’s 2009 and 2010 budget justifications, the Coast Guard’s 2008  Deepwater Expenditure Plan, and the Coast Guard’s Quarterly Acquisition  Reports to Congress. We compared the Coast Guard’s budget submissions  to those prepared by the Navy.
To assess the Coast Guard’s efforts to manage and build its acquisition  workforce, we reviewed Coast Guard organization charts for aviation,  surface, and C4ISR components showing government, contractor, and  vacant positions. We supplemented this analysis with interviews of  acquisition directorate officials, including contracting and Office of  Acquisition Workforce Management officials and program and project  managers to discuss current vacancy rates—especially for key acquisition  positions such as contracting officials and systems engineers—and the  Coast Guard’s plans to increase the size of the acquisition workforce. We  also reviewed documentation and interviewed senior acquisition  directorate officials about the Coast Guard’s use of third parties and  independent experts outside of the Coast Guard such as the U.S. Navy and  the American Bureau of Shipping, as well as increased use of support  contractors and oversight to prevent contractors from performing  inherently governmental functions. We reviewed documentation such as  the July 2008 Blueprint for Acquisition Reform and the updated  Acquisition Human Capital Strategic Plan and discussed workforce  initiatives, challenges, and obstacles to building an acquisition workforce,  including recruitment and difficulty in filling key positions.
We conducted this performance audit from September 2008 to July 2009 in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
section_title: Appendix II: Comments from the Department of Homeland Security
section_title: Appendix III: GAO Contact and Acknowledgments
paragraphs: For further information about this report, please contact John P. Hutton,  Director, Acquisition and Sourcing Management, at (202) 512-4841 or  huttonj@gao.gov. Other individuals making key contributions to this  report include Michele Mackin, Assistant Director; Greg Campbell;  Carolynn Cavanaugh; J. Kristopher Keener; Angie Nichols-Friedman; and  Sylvia Schatz.
section_title: Related GAO Products
paragraphs: Coast Guard: Update on Deepwater Program Management, Cost, and  Acquisition Workforce. GAO-09-620T. Washington, D.C.: April 22, 2009.
Coast Guard: Change in Course Improves Deepwater Management and  Oversight, but Outcome Still Uncertain. GAO-08-745. Washington, D.C.:  June 24, 2008.
Coast Guard: Observations on Changes to Management and Oversight of  the Deepwater Program. GAO-09-462T. Washington, D.C.: March 24, 2009.
Status of Selected Assets of the Coast Guard’s Deepwater Program.  GAO-08-270R. Washington, D.C.: March 11, 2008.
Coast Guard: Deepwater Program Management Initiatives and Key  Homeland Security Missions. GAO-08-531T. Washington, D.C.: March 5,  2008.
Coast Guard: Status of Efforts to Improve Deepwater Program  Management and Address Operational Challenges. GAO-07-575T.  Washington, D.C.: March 8, 2007.
Coast Guard: Status of Deepwater Fast Response Cutter Design Efforts.  GAO-06-764. Washington, D.C.: June 23, 2006.
Coast Guard: Changes to Deepwater Plan Appear Sound, and Program  Management Has Improved, but Continued Monitoring Is Warranted.  GAO-06-546. Washington, D.C.: April 28, 2006.
Coast Guard: Progress Being Made on Addressing Deepwater Legacy  Asset Condition Issues and Program Management, but Acquisition  Challenges Remain. GAO-05-757. Washington, D.C.: July 22, 2005.
Coast Guard: Preliminary Observations on the Condition of Deepwater  Legacy Assets and Acquisition Management Challenges. GAO-05-651T.  Washington, D.C.: June 21, 2005.
Coast Guard: Deepwater Program Acquisition Schedule Update Needed.  GAO-04-695. Washington, D.C.: June 14, 2004.
Contract Management: Coast Guard’s Deepwater Program Needs  Increased Attention to Management and Contractor Oversight.  GAO-04-380. Washington, D.C.: March 9, 2004.
Coast Guard: Actions Needed to Mitigate Deepwater Project Risks.  GAO-01-659T. Washington, D.C.: May 3, 2001.