Defense Procurement: Air Force Did Not Fully Evaluate Options in Waiving Berry Amendment for Selected Aircraft
Published: 2005-09-23T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In April 2004, the Secretary of the Air Force approved a permanent waiver of the requirements of the Berry Amendment for 23 commercial derivative aircraft systems, representing more than 1,200 aircraft in the Air Force's inventory. The Berry Amendment generally requires the Department of Defense (DOD) to purchase certain domestically grown or produced items, including specialty metals used in defense systems such as aircraft. Waivers to the Berry Amendment can be granted under certain circumstances. GAO was asked to evaluate the supporting evidence and analysis that the Air Force relied on to waive the Berry Amendment. GAO did not conduct a legal analysis of the waiver.
section_title: What GAO Found
paragraphs: The Air Force did not follow established policy when evaluating the need for a waiver of the Berry Amendment for 23 commercial derivative aircraft systems. Specifically, the Air Force did not thoroughly analyze the opportunities for compliance with the Berry Amendment on a system-by-system basis, thereby diminishing the persuasiveness of the waiver's support. The Air Force's review of its compliance with the Berry Amendment regarding these systems began in early 2003 when it became aware that some aircraft manufacturers could not meet the Berry Amendment requirements. Faced with this problem, a senior Air Force acquisition official visited an aircraft manufacturer, two of its subcontractors (including a titanium producer), and an engine manufacturer. The Air Force's conclusion, based on these visits and knowledge of the aerospace industry, was that other contractors involved in the Air Force's acquisition and support of commercial derivative aircraft systems would also have difficulty complying with the Berry Amendment. In September 2003, the Secretary of the Air Force signed a temporary waiver that was initiated at the headquarters level and covered 19 systems. That was followed in April 2004 with a permanent waiver of the Berry Amendment for these 19 systems plus another 4. Air Force policy calls for certain actions before issuing a waiver, including conducting market research and conducting an analysis of what alternatives are available and why they are not acceptable. In this instance, the Air Force did not conduct market research for each system, as it believed no company could produce compliant parts--a position not explained in the waiver's supporting documents. The Air Force documented an analysis of alternatives for only 1 aircraft system in the waiver. Memos representing 18 other aircraft systems state that alternatives to the waiver had been considered and rejected as not feasible but did not identify what the alternatives were, while memos for 3 additional aircraft systems make no reference to whether alternatives had been considered. The Air Force provided no documentation about its analysis of alternatives for the 1 remaining aircraft system in the waiver. After discussions with representatives for all 23 aircraft systems, GAO concluded that the Air Force did not document alternatives or thoroughly review possible options to achieve compliance with the Berry Amendment for many of the aircraft systems. GAO has identified several instances that highlight the Air Force's lack of thoroughness in its waiver process for the 23 aircraft systems. For example, the Air Force did not question contractors' inability to provide compliant spare parts when they were military unique and therefore not the same as the parts used in commercial aircraft. Also, the Air Force included some aircraft systems in the waiver that were already covered under other regulatory exceptions to the Berry Amendment.

section_title: Letter
paragraphs: Congress enacted the Berry Amendment in 1941 to maintain a healthy  industrial base and encourage domestic production of items deemed  essential to meet defense needs. It generally requires the Department of  Defense (DOD) to purchase certain domestically grown or produced  items, including food, clothing, fabrics, and specialty metals such as  titanium and titanium alloys, but allows a waiver of these requirements  when goods cannot be found in satisfactory quality or sufficient quantity at  U.S. market prices. Citing this provision, in April 2004 the Secretary of the  Air Force permanently waived the Berry Amendment for the purchase and  support of 23 commercial derivative aircraft systems—representing over  1,200 aircraft in the Air Force inventory. These are commercial aircraft,  modified for military use, that provide support for critical mission areas  such as cargo and passenger airlift, medical evacuations, aerial refueling,  VIP transport, embassy support, surveillance, counterdrug enforcement,  and pilot training. Appendix I provides information on the 23 aircraft  systems included in the April 2004 waiver.
Because of the broad and permanent nature of the waiver, you asked us to  evaluate the supporting evidence and analysis that the Air Force relied on  to waive the Berry Amendment for certain commercial derivative aircraft  systems in its inventory. In response, this report evaluates the process the  Air Force followed as well as its rationale for waiving the Berry  Amendment for these aircraft. Our review focused on the Air Force’s  adherence to DOD and Air Force policy. We did not conduct a legal  analysis of the waiver.
In evaluating the Air Force’s process and rationale for waiving the Berry  Amendment, we reviewed the statute, regulations, and DOD and Air Force  policies that implement the Berry Amendment and provide guidance for  the waiver process. In addition, we analyzed documentation and  conducted interviews with senior Air Force acquisition officials as well as  Air Force officials in the field for each aircraft system on the waiver. We  also interviewed officials from the Office of the Secretary of Defense, the  Defense Logistics Agency, the Defense Contract Management Agency, and  the Department of Commerce to identify any additional guidance for  issuing a Berry Amendment waiver and to understand each organization’s  role in the Air Force’s waiver, if any. Finally, we conducted interviews and  site visits with representatives from three companies, accounting for 17  out of the 23 aircraft systems in the waiver, to better understand the  information provided to the Air Force about the companies’ difficulty in  complying with the Berry Amendment. We did not address whether the  waiver was legally valid, that is, whether the waiver was a proper exercise  of discretion by the Secretary of the Air Force under the Berry  Amendment.
We performed our review from October 2004 to September 2005 in  accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: The Berry Amendment generally prohibits DOD from using appropriated  or other available funds for the procurement of certain items that have not  been grown, reprocessed, reused, or produced in the United States.  Enacted in a 1941 defense appropriations act, the restriction initially  ensured that American troops wore uniforms and ate food grown or  produced in the United States. For more than 50 years, the Berry  Amendment consistently appeared in annual appropriations acts. The  scope of the restriction has changed over time to include additional items  and exceptions. The current version, codified in 2001, restricts DOD  purchases of food, clothing, certain fabrics, specialty metals, and certain  tools.
The specialty metals requirement was added to the Berry Amendment in  1972. DOD implemented the specialty metals requirement by applying it to  all contracts where the specialty metal is purchased directly by the  government or the prime contractor and to all subcontract tiers for six  major classes of programs—aircraft, missiles, ships, tank-automotive,  weapons, and ammunition. For these programs, the prime contractor  must include a clause that requires all subcontractors to comply with the  Berry Amendment’s specialty metals requirement. In addition, the Defense  Federal Acquisition Regulation Supplement (DFARS) identifies those  metals considered to be specialty metals, to include titanium, certain types  of steel, and other assorted metals and alloys. In 1996, Congress made  clear that the Berry Amendment does apply to all commercial item  purchases.
The Berry Amendment includes a number of exceptions to the  requirement to buy certain domestically produced articles. For example,  the requirement does not apply to the extent that the Secretary of Defense  or the Secretary of the military department concerned determines that  satisfactory quality and sufficient quantity of an item cannot be procured  as and when needed at U.S. market prices. Since May 2001, DOD policy  specifies that the authority to approve a Berry Amendment waiver is not  delegable below the Secretarial level, and the waiver is to include an  analysis of alternatives and a certification as to why such alternatives are  unacceptable. Additional exceptions to the Berry Amendment are allowed  for items already determined to be unavailable in the United States and  specialty metals purchased from a qualifying country, i.e., one that has  signed a memorandum of understanding with the United States.
The Berry Amendment does not include explicit criteria to be used or  requirements to be met to support and document a waiver. The Air  Force’s internal policy, the Air Force Federal Acquisition Regulation  Supplement, provides instruction as to what information the Air Force  decision makers would generally expect to be provided if asked to  approve a Berry Amendment waiver. The Air Force policy calls for the  contracting officer to conduct market research to determine if an article or  suitable substitute is available from a domestic source. If the article or  substitute is not available, the contracting officer contacts Air Force  headquarters, which in turn confers with the Department of Commerce  (Commerce) to request a list of possible domestic sources. If Air Force  headquarters notifies the contracting officer that domestic sources have  not been identified by Commerce, Air Force policy then specifies that the  contracting officer shall submit a determination and finding in a specified  format for the Secretary of the Air Force’s approval. This format is to  describe  the market research performed,    any alternatives/substitutes considered and why these  alternatives/substitutes are not satisfactory,  the total estimated cost of the item(s) being acquired,  the circumstances precluding the buying of a domestic end item, and  the impact if the waiver is not approved.
section_title: Air Force Waiver Lacked Thorough Analysis
paragraphs: The Air Force did not conduct a thorough analysis of opportunities for  compliance with the Berry Amendment on a system-by-system basis in  approving a broad, permanent waiver covering 23 commercial derivative  aircraft systems. The Air Force initiated the waiver at the headquarters  level after it became aware of problems with implementing the Berry  Amendment. In supporting the waiver, the Air Force did not conduct  market research as called for in its policy, thoroughly review alternatives,  or include an explanation as to why it believed that alternatives did not  exist for each of the systems in the waiver. We identified several instances  that highlight the Air Force’s lack of thoroughness in its analysis to  support the waiver.
subsections: section_title: Air Force Initiated Waiver after Identifying Problems with Berry Amendment Implementation
paragraphs: According to a senior Air Force official, the Deputy Assistant Secretary  (Contracting) and several Air Force officials met with titanium industry  representatives in November 2002 to discuss their concerns that some  aircraft manufacturers were not meeting the Berry Amendment  requirement for domestic specialty metals. Subsequently, the Air Force  formed an Integrated Product Team in March 2003 to study the history and  requirements of the Berry Amendment’s specialty metals provision and to  review the Air Force’s compliance. This team conducted a review of Air  Force Materiel Command contracts and uncovered a number of contracts  that lacked the clause that implements the Berry Amendment. The Air  Force buying commands attempted to negotiate with contractors to add  the required contract clause to those contracts. However, many  commercial derivative aircraft contractors refused to accept the specialty  metals provision that would require all contracts and subcontracts related  to aircraft programs to be compliant with the Berry Amendment. In the  summer of 2003, the Air Force official who led the waiver effort told us he  visited an aircraft manufacturer, two of its subcontractors (including a  titanium producer), and an engine manufacturer to evaluate the difficulty  of complying with the Berry Amendment specialty metals requirement.  Following these visits, the Air Force official concluded that other  contractors involved in the Air Force’s acquisition and support of  commercial derivative aircraft systems would also have difficulty  complying with the Berry Amendment.
According to Air Force officials, they initiated the waiver process at the  headquarters level instead of following the established procedure of  receiving individual requests from field contracting officers involved in  acquiring or supporting these systems. Officials stated that this method  was intended to ensure a consistent and comprehensive approach to  supporting the waiver. Air Force headquarters collected supporting  documentation that included letters from contractors and memos from the  military users of commercial derivative aircraft systems. These companies  indicated it would be “commercially impracticable” or otherwise not  possible to comply with the Berry Amendment. In addition, memos from  representatives of the military users of the aircraft indicated that the  alternatives presented to them were not feasible.
In September 2003, the Secretary of the Air Force signed a temporary  Berry Amendment waiver, effective through April 1, 2004, which covered  future aircraft deliveries under current acquisition contracts, as well as  current and future support contracts, for 19 commercial derivative aircraft  systems. In doing so, the Secretary of the Air Force made several findings,  including the following:    Contractors stated they could not comply with the Berry Amendment’s  specialty metals restriction “without substantial changes to their  manufacturing and supplier management processes,” which would  “cause substantial, largely unquantifiable, cost and schedule impacts.”
Pursuing Berry Amendment compliance could make contractors’  commercial products less competitive in the worldwide market.
The systems at issue are produced on the same production lines used  to support the commercial marketplace and generally comprise a  minute portion of the contractors’ overall commercial business.
Several contractors informed the Air Force they would no longer  accept contracts if the provisions implementing the Berry Amendment  were included.
On the basis of these findings, the Secretary of the Air Force determined  compliant commodities for certain commercial derivative aircraft systems  could not be acquired as and when needed in satisfactory quality and  sufficient quantity at U.S. market prices, the waiver was needed to sustain  ongoing operations of these systems and avoid major mission impacts, and  the waiver would be of limited duration while Congress considered  changes to the Berry Amendment in the fiscal year 2004 legislative cycle.  However, these legislative changes did not occur, and in April 2004 the  Secretary signed a permanent waiver that covered 23 commercial  derivative aircraft systems—which included 4 additional systems— exempting all of them from the Berry Amendment requirements. The  permanent waiver relied on the same findings as the temporary waiver.
section_title: Air Force Analysis Lacked Market Research and a Thorough Review of Alternatives
paragraphs: The Air Force policy identifies the need to conduct market research prior  to proceeding with a Berry Amendment waiver. According to the policy,  the Air Force is to request a list of possible domestic sources from the  Department of Commerce and draft a market research report indicating  what companies were contacted. The Air Force acquisition official who  drafted the policy told us that market research also includes advertising in  official government sources for contracting opportunities. Officials from  Commerce’s Bureau of Industry and Security and International Trade  Administration informed us that there was no record of the Air Force  requesting Commerce’s assistance in identifying domestic sources for the  support of commercial derivative aircraft on the waiver.
While this waiver encompasses 23 different aircraft systems and certain  related acquisition and support contracts, the Air Force did not conduct  market research on each system included in the waiver. A senior Air Force  acquisition official told us that it was unnecessary to conduct market  research for each system because Air Force officials were knowledgeable  about the aerospace industry and did not need to contact the Department  of Commerce for assistance. Another senior official who led the waiver  effort indicated that the original aircraft manufacturer owned the technical  data rights and, in some cases, was the primary supplier of these spare  parts. Therefore, this official believed that in some instances it would be  difficult and costly to purchase technical data rights so suppliers other  than the original aircraft manufacturer and its subcontractors could  produce the parts. Moreover, this same Air Force official became  convinced that no company could provide compliant spare parts after site  visits to an aircraft manufacturer, which accounted for 11 systems in the  waiver, and two of its suppliers (including a titanium producer) as well as  an engine manufacturer. However, these findings were not documented in  the waiver.
DOD and Air Force policies also specify the need to identify alternatives  and explain why such alternatives are unacceptable. In May 2001, the  Deputy Secretary of Defense directed that each military department’s  Secretary ensure that alternatives that do not require a waiver under the  Berry Amendment are presented to the relevant military users before  requesting a waiver. The military users must certify in writing why such  alternatives are unacceptable before the Secretary may approve a waiver.  The Air Force policy calls for similar information.
To address DOD and Air Force policy requirements, the Air Force  included 13 memos from military user representatives in the waiver’s  supporting documentation, representing 22 of the 23 aircraft systems on  the waiver.  As specified in Air Force policy, most of these memos address  the impact on the system if the waiver is not approved and state that the  compliant alternatives had been considered.  Specifically, memos  representing 18 aircraft systems state that they had considered compliant  alternatives and rejected them as not feasible, without stating what those  alternatives were.  Memos for 3 aircraft systems make no reference to  whether alternatives had been considered.  Only 1 memo representing a  single aircraft system contains an assessment of a potential alternative and  the delay it would cause to the aircraft’s mission if selected, although  other Air Force documentation indicated that the alternative would not  satisfy the Berry Amendment requirement.  Though most of the memos  state that alternatives had been considered, we found that in several  instances military users and their representatives who prepared the  memos were not presented with alternatives.  A senior Air Force official  who led the waiver effort acknowledged that the military users’ memos  contain boilerplate language about the consideration and rejection of  alternatives that would be compliant with the Berry Amendment.
Air Force program management officials, contracting officers, military  users, and a senior acquisition official told us that the Air Force did not  identify and pursue compliant alternatives because they did not believe  there were any available. For example, in many instances, contracting  officers and program managers stated that the only realistic option was to  pursue a Berry Amendment waiver. However, the waiver documentation  lacked an explanation as to why the Air Force did not believe any  alternatives were available.
section_title: Air Force Did Not Consider Possible Compliant Options
paragraphs: The Air Force missed opportunities to assess possible compliant options.  For instance, the Air Force and Boeing have entered into a contract,  referred to as the Rights Guard agreement, that could allow the Air Force  to order technical data for military derivatives of the Boeing 707, 727, 737,  and 747 commercial aircraft and to use that data to facilitate the  competitive procurement of replenishment spare parts. This contract was  in effect at the time the waiver was being considered and covered 8 of the  23 systems on the waiver, representing 636 (or 51 percent) of the  commercial derivative aircraft in the waiver. The senior Air Force official  who led the waiver effort, and a field contracting official who oversaw  support contracts for almost 90 percent of the aircraft on the Rights Guard  agreement, told us they did not consider this contract as a means to  acquire parts that would be compliant with the Berry Amendment.  Further, this senior acquisition official was unaware that the contract  applied to several Boeing models included in the waiver. While this  contract would not have resolved the compliance issues for all of the  aircraft systems listed on the waiver, this official acknowledged it might  have allowed the Air Force to achieve compliance for a limited number of  spare parts procurements for certain systems.
The Air Force also did not question the contractors’ inability to be  compliant on military unique spare parts. For example, we previously  reported on the Air Force award of a $7.9 million contract to Boeing in  September 2003 for 24 engine cowlings used on the E-3 Airborne Warning  and Control System (AWACS), a Boeing 707 aircraft modified for military  use. These engine cowlings were similar to those used on the commercial  707, but were modified to meet military requirements. Boeing proposed to  manufacture these engine cowlings rather than subcontracting the work as  it did in the original E-3 AWACS production contracts. This required the  company to include in its contract proposal the cost of acquiring  production equipment to manufacture these parts. The temporary waiver  of the Berry Amendment that included the E-3 AWACS was issued at the  same time that the Air Force awarded the engine cowlings contract.  However, it did not question Boeing’s inability to produce compliant  cowlings in-house. The waiver documentation did not include any  discussion or other indication that the Air Force questioned company  assertions that it could not meet Berry requirements, specifically for  military unique items.
In addition, the Air Force did not fully evaluate the cost of bringing  contractors into compliance. Although one company’s representatives said  that compliance would be costly, the Air Force did not validate what the  actual costs would be and did not assess whether the cost of complying  would be similar for the other manufacturers of commercial derivative  aircraft. For example, Gulfstream officials said that they performed a high- level review—which was provided to Air Force contracting officers—that  showed that about 0.2 percent of the total value of aircraft parts on the   C-37A originates in countries not exempt from the Berry Amendment.  However, the Air Force did not validate this estimate or determine the cost  or effort necessary for Gulfstream or any other similarly situated  contractor to achieve compliance.
Finally, the Air Force did not consider its leverage as the primary  customer of the T-6 aircraft, given that the U.S. government accounts for  364 out of 435 aircraft ordered as of August 2005, with planned purchases  of an additional 782 aircraft through 2015. The Air Force will also need to  purchase spare parts for the life of the aircraft system. According to  Raytheon, the company selects and establishes a supplier base during the  design, development, and testing of its commercial aircraft, resulting in  suppliers being certified by the Federal Aviation Administration. However,  the Air Force did not ask Raytheon what steps it would need to take and  what costs would be involved in complying with the Berry Amendment  requirement.
section_title: Air Force Did Not Recognize Some Systems Were Already Covered under Other Regulatory Exceptions
paragraphs: By not conducting a system-by-system review, the Air Force was unaware  that some systems were already covered under other regulatory  exceptions to the Berry Amendment. For example, one of the exceptions  allows specialty metals to be procured from a qualifying country. The   TG-15 support contract was already exempt from the Berry Amendment  specialty metal restriction because this training glider was manufactured  in Germany, a qualifying country. In another example, the senior Air Force  officials were not aware that the TG-10 and TG-14 support contracts were  already covered under the regulatory exception for certain foreign  manufactured equipment. This exception allows DOD to purchase spare  and replacement parts for foreign manufactured equipment when  domestic parts are deemed unavailable. Air Force contracting officials in  the field previously determined that spare parts for these two training  gliders were unavailable domestically, as these aircraft are manufactured  in the Czech Republic and Brazil. The support contract for these systems  was modified to cite this exception 6 months before they were added to  the permanent waiver.
Air Force officials did not consider any of these other regulatory  exceptions prior to including these training gliders in the waiver. Only  after we identified that these training gliders were already exempted did  the acquisition officials consult with contracting officials at Oklahoma City  Air Logistics Center—those responsible for managing the support  contract—to determine whether these exceptions had ever been  considered. Had the Air Force done so before finalizing the permanent  waiver, it may have discovered that these training gliders were already  covered through other regulatory exceptions. This illustrates the Air  Force’s lack of thoroughness by not coordinating the waiver with all of the  appropriate contracting officials in the field.
section_title: Conclusions
paragraphs: The Berry Amendment was enacted to strengthen the industrial base to  ensure that it could produce essential items for defense purposes.
Although the Department of Defense relies on commercial products to  satisfy some of its military requirements, it remains responsible for  assessing opportunities to satisfy the requirements of the Berry  Amendment. The Air Force’s failure to follow established policies and its  decision to combine 23 aircraft systems in one waiver diminished the  persuasiveness of the waiver’s support. By not thoroughly analyzing each  system on the waiver, the Air Force treated all systems as if they had the  same compliance problems, when in fact several of the systems had  unique circumstances that should have been considered and documented  before approving a waiver. Additionally, the Air Force did not fully  document its position on the lack of alternatives and has limited the  possibility of future review concerning these systems through the  execution of a permanent waiver.
section_title: Recommendation for Executive Action
paragraphs: Because the Air Force did not thoroughly analyze each system on the  waiver or fully document its position on the lack of alternatives, we are  making two recommendations to DOD so that it can improve the waiver’s  support or modify it as necessary. Specifically, we recommend that the  Secretary of Defense direct the Secretary of the Air Force to take the  following two actions:    Conduct an analysis of each commercial derivative aircraft system  included in the waiver to consider opportunities to achieve compliance  with the Berry Amendment requirements or to document why such  compliance is not possible. This should include   conducting market research, including consultation with the  Department of Commerce, and    assessing alternatives such as obtaining technical data rights to  manufacture compliant parts, identifying compliant suppliers for  military unique parts, determining the cost or effort for bringing  contractors into compliance, and considering if systems are already  exempted under other regulatory exceptions.
Assess, on a periodic basis, whether changes have occurred in the supplier  base for each aircraft system included in the waiver that would provide  opportunities to procure domestically produced items as required by the  Berry Amendment.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, DOD concurred with both of  our recommendations.  In response, DOD will direct the Air Force to  conduct an analysis of each commercial derivative aircraft system  included in the Berry Amendment waiver and to periodically assess  whether changes have occurred in the supplier base that would provide  opportunities to procure domestically produced items. In addition, DOD  provided comments from the Air Force, which indicated the Air Force’s  concurrence with our recommendations and its intent to develop a plan to  review the current waiver and rescind or modify it as appropriate.  DOD  and Air Force responses are reprinted in appendix II. We incorporated the  Air Force’s technical comments in the report as appropriate.
In its general comments, the Air Force stated that the waiver is reasonable  and necessary and that the draft report fails to acknowledge the  circumstances and rationale that compelled it to execute the waiver. The  Air Force also indicated that the report did not clearly articulate the scope  of the current waiver, which covers future spare parts purchases, but does  not include future aircraft purchases.
While the Air Force stated that the waiver is reasonable and necessary, our  report shows that the Air Force did not follow established policy when it  did not thoroughly analyze the opportunities for compliance on a system- by-system basis. Had it conducted market research and thoroughly  reviewed alternatives for each system on the waiver, the Air Force could  have strengthened the persuasiveness of the waiver’s support.  We are  encouraged that the Air Force has concurred with our recommendation to  reevaluate the support for each of the systems on the waiver.
The Air Force also stated that our report did not acknowledge the  circumstances and rationale for the waiver.  We disagree with this  assertion. Our first finding discusses at length the reasons the Air Force  considered a waiver necessary and outlines the waiver’s rationale based  on the Air Force’s supporting documentation. While we agree that it was  necessary for the Air Force to promptly address Berry Amendment  compliance issues, this should not have precluded the Air Force from  conducting a thorough analysis on how to achieve compliance on a  system-by-system basis, especially during the 6-month period that the  temporary waiver was in force.
In addition, the Air Force indicated that the report did not clearly  articulate the scope of the current waiver.  Although the draft report  correctly described the scope of the waiver, we made changes throughout  the report to specify and emphasize that the scope of the waiver covers  future aircraft deliveries under current acquisition contracts and current  and future support contracts. The waiver does not apply to commercial  derivative aircraft systems not listed on the waiver or future contracts for  systems on the waiver entered into after the waiver’s effective date.
We are sending copies of this report to the Honorable Donald H. Rumsfeld,  Secretary of Defense; the Honorable Preston M. Geren, Acting Secretary of  the Air Force; and interested congressional committees. We will also  provide copies to others on request. In addition, the report will 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, please contact me  at (202) 512-4841 or calvaresibarra@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. GAO staff who made major contributions to this  report are listed in appendix III.
section_title: Appendix I: Commercial Derivative Aircraft Included in the Air Force Waiver
section_title: Appendix II: Comments from the Department of Defense and the Air Force
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the contact named above, John Neumann, Assistant  Director; Noah Bleicher; Greg Campbell; Jeffrey Hartnett; Robert Lee;  Lillian Slodkowski; and Adam Vodraska made key contributions to this  report.