Industrial Base: U.S. Tactical Wheeled Vehicle Manufacturers Face Period of Uncertainty as DOD Purchases Decline and Foreign Sales Potential Remains Unknown
Published: 2012-09-13T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: DODs need for TWVs dramatically increased in response to operational demands and threats experienced in Afghanistan and Iraq. TWVs primarily transport cargo and personnel in the field and include the High Mobility Multi-purpose Wheeled and Mine Resistant Ambush Protected vehicles. The U.S. TWV industrial base, which includes manufacturers and suppliers of major subsystems, increased production to meet DODs wartime requirements. That base now faces uncertainties as DODs budget declines and operational requirements for these vehicles decrease. In addition to sales to DOD, U.S. manufacturers sell vehicles to foreign governments.
The Senate Armed Services Committee Report on a bill for the National Defense Authorization Act for Fiscal Year 2012 directed GAO to (1) describe the composition of the U.S. TWV industrial base, (2) determine how many U.S. manufactured TWVs were purchased by foreign governments from fiscal years 2007 through 2011, and (3) identify factors perceived as affecting foreign governments decisions to purchase these vehicles. GAO analyzed data from DOD on U.S. and foreign government TWV purchases, as well as sales data from the four primary U.S. TWV manufacturers. GAO also collected data from five foreign governments, including those that did and did not purchase U.S. TWVs.
section_title: What GAO Found
paragraphs: The U.S. tactical wheeled vehicle (TWV) industrial base includes seven manufacturers that utilize common suppliers of major subsystems, such as engines and armor. Four of these manufacturers reported that their reliance on sales to the Department of Defense (DOD) varies, in part, as they also produce commercial vehicles or parts. Collectively, the seven manufacturers supplied DOD with over 158,000 TWVs to meet wartime needs from fiscal years 2007 through 2011. DOD, however, plans to return to pre-war purchasing levels, buying about 8,000 TWVs over the next several years, in part, due to fewer requirements.
Almost 28,000 U.S.-manufactured TWVs were purchased for use by foreign governments from fiscal years 2007 through 2011. Approximately 92 percent of these vehicles were paid for using U.S. security assistance funds provided to foreign governments. Iraq and Afghanistan were the largest recipients of such assistance, but officials stated that DOD does not plan to continue funding TWV purchases for these countries. While sales to foreign governments are unlikely to offset reductions in DOD purchases, manufacturers reported that foreign sales are becoming an increasingly important part of their revenue stream.
Sales of U.S.-manufactured TWVs to foreign governments may be affected by multiple interrelated factors, including the availability of used DOD vehicles for sale, foreign competition, differing vehicle requirements, and concerns associated with U.S. arms transfer control regimes. U.S. manufacturers said sales of used Army TWVs to foreign governments could affect their ability to sell new vehicles. U.S. manufacturers and foreign governments also identified a number of non-U.S. manufacturers that produce TWVs that meet foreign governments requirements, such as right-side drive vehicles. While U.S. manufacturers can produce vehicles that meet these requirements, vehicles they produced for DOD generally have not. Finally, manufacturers and foreign officials had mixed views on how the U.S. arms transfer control regimes may affect foreign governments decisions to purchase U.S. vehicles. U.S. manufacturers and foreign officials expressed concerns with processing times and U.S. end-use restrictions, but foreign officials also said that such concerns have not been a determining factor when purchasing TWVs that meet their requirements.
section_title: What GAO Recommends
paragraphs: GAO is not making recommendations in this report. DOD, the Department of State, and two manufacturers provided technical or clarifying comments on a report draft that were incorporated as appropriate.

section_title: Letter
paragraphs: Tactical wheeled vehicles (TWV) have played a critical role in supporting  the warfighter, as most recently demonstrated in Afghanistan and Iraq.  TWVs are primarily designed for use by forces in the field to transport  cargo and personnel and are capable of operating on primary and  secondary roads, trails, and cross-country terrain. The Department of  Defense’s (DOD) need for TWVs increased dramatically in response to  the operational demands and threats, such as improvised explosive  devices, experienced by U.S. forces during Operation Enduring Freedom  and Operation Iraqi Freedom. For example, DOD’s procurements for two  types of TWVs—the High Mobility Multi-purpose Wheeled Vehicle  (HMMWV) and the Family of Medium Tactical Vehicles (FMTV)— increased from 5,500 in 2002 to 27,350 vehicles in 2006. To meet these  requirements, the U.S. TWV industrial base, which includes vehicle  manufacturers and their suppliers of major subsystems and parts,  increased vehicle production. However, that industrial base now faces a  period of uncertainty as requirements for these vehicles decrease with the  withdrawal of U.S. forces from Iraq and the planned drawdown in  Afghanistan, along with declines in DOD’s budget.
In addition to sales to DOD, the U.S. TWV industrial base also sells  vehicles to foreign governments. The sale of U.S. arms and dual-use  items, including TWVs, to friendly nations and allies is an integral  component of both U.S. national security and foreign policy. The Arms  Export Control Act (AECA) authorizes the President to control the export  and import of arms. The AECA authorizes the U.S. government to sell  arms to foreign governments through government-to-government  agreements as part of the Foreign Military Sales (FMS) program. It also  authorizes the issuance of export licenses for U.S. manufacturers to sell  arms directly to eligible foreign governments, known as direct commercial  sales (DCS). Regardless of the method of sale, each FMS request or  DCS license application is reviewed by officials from DOD and the  Department of State (State) to ensure the sale would not result in harm to  U.S. interests and is consistent with national security and foreign policies.
In response to directions in the Senate Armed Services Committee  Report on a bill for the National Defense Authorization Act for Fiscal  Year 2012, we (1) described the composition of the U.S. TWV industrial  base and the extent of manufacturers’ reliance on sales to DOD,  (2) determined how many U.S. manufactured TWVs foreign governments  purchased in fiscal years 2007 through 2011, and (3) identified factors  that are perceived as affecting foreign governments’ decisions to  purchase these vehicles.
We did not include TWV parts purchased by DOD or any efforts intended to sustain or  upgrade its existing vehicles. and electronic data testing for missing data, outliers, and obvious errors  and determined the data to be sufficiently reliable for our purposes.
To determine how many U.S. TWVs were purchased by foreign  governments, we obtained FMS and DCS data for fiscal years 2007  through 2011. We obtained FMS data from the Army TACOM Life Cycle  Management Command’s Security Assistance Management Directorate  and the Marine Corps Systems Command’s International Programs  Directorate as they directly facilitate the FMS process for TWVs within  DOD. We obtained DCS data from the four TWV manufacturers included  in our scope. The FMS data we obtained from DOD contain foreign sales  data for the three remaining TWV manufacturers, but we did not collect  DCS data from them. We limited FMS and DCS data to vehicles that were  purchased by DOD in fiscal years 2007 through 2011 and also sold to  foreign governments. We assessed the reliability of FMS data reported by  DOD by interviewing officials knowledgeable about the data and cross- checking the data with FMS records from the four manufacturers we met  with. We assessed the reliability of DCS data reported by the four  manufacturers we met with by interviewing officials knowledgeable about  the data and performing electronic testing. Based on those efforts, we  determined that the FMS and DCS data reported to us were sufficiently  reliable for our purposes.
To identify factors perceived as affecting foreign government decisions to  purchase U.S. TWVs, we interviewed representatives from the four U.S.  TWV manufacturers included in our scope, foreign government officials  from five selected countries, and DOD, State, and Department of  Commerce (Commerce) officials. We interviewed officials from three  countries that were among the biggest buyers of U.S. TWVs through the  FMS program in fiscal years 2007 through 2011 or DCS in fiscal years  2008 through 2011. We also interviewed officials from two allied countries  that did not purchase U.S. TWVs through the FMS program in fiscal years  2007 through 2011 or DCS in fiscal years 2008 through 2011 to gain  additional perspectives. Some of the five countries were in the process of  purchasing TWVs. Collectively, these officials provided information on  foreign manufacturers of TWVs and foreign TWV requirements. Because  the countries provided us with information on the size and composition of  their TWV fleets, which some regard as sensitive, we are not identifying  the countries that participated in our review by name. To determine how  the U.S. arms transfer control regimes may affect such sales to foreign  governments, we also reviewed the AECA, Export Administration Act of  1979, International Traffic in Arms Regulations, DOD’s Security  Assistance Management Manual, and related U.S. guidance. To  determine how many U.S. TWV sales to foreign governments were  denied, we interviewed officials from State’s Directorate of Defense Trade  Controls and Regional Security and Arms Transfer offices and  Commerce’s Bureau of Industry and Security. We also reviewed available  State export licensing data for fiscal years 2008 through 2011 and  Commerce’s data for fiscal years 2007 through 2011.
We conducted this performance audit from October 2011 to September  2012 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
subsections: section_title: Tactical Wheeled Vehicles
paragraphs: DOD and the military services classify TWVs by weight or payload  capacity into three categories—light, medium, and heavy—although the  definitions of each class vary among the services. Each class generally  includes multiple variants or models built on a common chassis. For  example, the Army’s FMTV consists of 2.5- and 5-ton capacity trucks,  each with the same chassis and includes cargo, tractor, van, wrecker,  and dump truck variants. Table 1 lists the TWVs acquired by the military  services over five fiscal years, fiscal years 2007 through 2011.
Requirements for TWVs have evolved over the last decade, in part, due  to the operational threats encountered in Afghanistan and Iraq. TWVs  were traditionally viewed as utility vehicles that required little armor  because the vehicles operated behind the front lines. However, the tactics  used against forces in these countries dictated that vehicles needed more  protection. For example, the HMMWV was conceived and designed to  support operations in relatively benign environments behind the front line,  but it proved to be highly vulnerable to attacks from improvised explosive  devices, rocket-propelled grenades, and small arms fire when it was  required to operate in urban environments. As a result, DOD identified an  urgent operational need for armored tactical vehicles to increase crew  protection and mobility of soldiers. Although the initial solution—the Up- Armored HMMWV—provided greater protection, the enemy responded by  increasing the size, explosive force, and type of improvised explosive  devices, which were capable of penetrating even the most heavily  armored vehicles. Consequently, the Mine Resistant Ambush Protected  (MRAP) vehicle was approved in 2007 as a rapid acquisition capability.  DOD recognized that no single manufacturer could provide all of the  vehicles needed to meet requirements quickly enough, so it awarded  contracts to multiple manufacturers.
The AECA authorizes the President to control the export of arms, such as  TWVs. The authority to promulgate regulations on these items has been  delegated to the Secretary of State. State administers arms transfer  controls through the International Traffic in Arms Regulations and  designates, with the concurrence of DOD, the articles and services  deemed to be arms. These arms constitute the United States Munitions  List (USML). DOD’s TWVs are generally designated as Category VII  (Tanks and Military Vehicles) items on the USML.
Arms, including TWVs, can be sold and exported to foreign governments  through the FMS program or DCS. Under the FMS program, the U.S.  government procures items on behalf of eligible foreign governments  using the same acquisition process used for its own military needs. While  State has overall regulatory responsibility for the FMS program and  approves such sales of arms to eligible foreign governments, DOD’s  Defense Security Cooperation Agency administers the program.  Alternatively, the DCS process allows foreign governments to directly  negotiate with and purchase arms from U.S. manufacturers. For TWVs  controlled on the USML, manufacturers must generally apply for an  export license to State’s Directorate of Defense Trade Controls, which  authorizes the export of arms to foreign governments.
State officials assess all arms export requests through the FMS program  and DCS license applications against 12 criteria specified in the  Conventional Arms Transfer Policy, as summarized in table 2. DOD officials assess the technical risks of the sensitive or classified electronic  equipment associated with the sale of TWVs to foreign governments,  including the type of armor, sensors or weapons attached to the vehicle,  and any signature information. Aside from these technologies, State and  DOD officials said the departments generally consider the technology  associated with TWVs comparable to commercially available trucks and  do not have any additional policies pertaining to the sale of TWVs to  foreign governments.
In accordance with the AECA, recipient countries of arms, including  TWVs, must generally agree to a set of U.S. arms transfer conditions,  regardless if sold through the FMS program or DCS. The conditions  include agreeing to use the items only for intended purposes without  modification, not to transfer possession to anyone not an agent of the  recipient country without prior written consent of the U.S. government,  and to maintain the security of any defense article with substantially the  same degree of protection afforded to it by the U.S. government. To  ensure compliance with these conditions, recipient countries must permit  observation and review by U.S. government representatives on the use  and possession of U.S. TWVs and other arms.
While the majority of TWVs that DOD purchases are regulated on the  USML, a small number that lack armor, weapons, or equipment that  would allow armor or weapons to be mounted are considered to be dual- use items—having both commercial and military applications. These  items are controlled under the Export Administration Act of 1979, which  established Commerce’s authority to control these items through its  Export Administration Regulations and Commerce Control List.  On the  Commerce Control List, DOD’s TWVs are generally designated as  Category 9 (Propulsion Systems, Space Vehicles, and Related  Equipment) items. For DCS of such items, U.S. manufacturers must  comply with the Export Administration Regulations to determine if an  export license from the Commerce’s Bureau of Industry and Security is  required.
section_title: U.S. TWV Industrial Base Includes a Number of Manufacturers Whose Reliance on Sales to DOD Vary
subsections: section_title: Numerous Vehicle Manufacturers and Suppliers Comprise the U.S. TWV Industrial Base
paragraphs: The U.S. TWV industrial base includes seven vehicle manufacturers, over  90 major subsystem suppliers, and potentially thousands of parts and  component suppliers. Four of the seven manufacturers provided  approximately 92 percent of all TWVs purchased by DOD in fiscal years  2007 through 2011. Figure 1 identifies the manufacturers, the vehicles  they produced, and the percent of all vehicles purchased by DOD from  each manufacturer in fiscal years 2007 through 2011.
Although these manufacturers produced 11 different families of TWVs,  which included over 50 vehicle variants, they generally relied on common  suppliers for major subsystem components. For example, the  manufacturers relied on six or fewer suppliers to provide components,  such as engines or tires. In contrast, the manufacturers relied on more  than 25 armor suppliers, in part, because there was a shortage of vehicle  armor during initial MRAP production. DOD reported that the  requirements for armor, in response to the conflicts in Iraq and  Afghanistan, provided an opportunity for several suppliers to begin  producing armor, which eventually resolved the armor shortage. In  addition to these suppliers, manufacturers we met with reported there  were potentially thousands of other companies that produced parts for  these vehicles. See figure 2 for more information on the number of  suppliers that produced major subsystems on DOD’s TWVs.
DOD purchased over 158,000 TWVs in fiscal years 2007 through 2011  but plans to buy significantly less from now through fiscal year 2017. DOD  demands for TWVs increased dramatically in response to the operational  demands and threats experienced by U.S. forces during Operation  Enduring Freedom and Operation Iraqi Freedom. For example, between  fiscal years 1998 through 2001, before these two wars began, Army  budget documents indicate plans to purchase approximately  5,000 HMMWVs. After the start of Operation Enduring Freedom, Army  budget documents in 2003 reflected an increased requirement for  HMMWVs and, at the time, it planned to purchase approximately 23,000  though fiscal year 2009. However, after Operation Iraqi Freedom began,  the need for HMMWVs increased further and the Army reported that it  ultimately purchased approximately 64,000 between 2003 through 2009.
As U.S. forces began to draw down from the conflicts in Iraq and  Afghanistan, DOD’s operational requirements for TWVs declined. For  example, while DOD bought over 100,000 TWVs in fiscal years 2007 and  2008, DOD plans to purchase less than 1,000 TWVs in fiscal years 2015  and 2016. In all, DOD plans to purchase approximately 8,000 TWVs in  fiscal years 2012 through 2017, as shown in figure 3.
Future defense budgets will likely constrain new vehicle purchases and  the size of a fleet the military services will be able to sustain. Army  officials told us that it would cost approximately $2.5 billion per year to  sustain its current fleet of approximately 260,000 TWVs and meet any  new TWV requirements. Officials stated, however, that the Army can no  longer afford and does not need such a sized fleet, in part, due to budget  cuts and potential force structure changes. The Army is re-evaluating how  many TWVs it needs and can afford, which will be outlined in a revised  TWV strategy. In developing this revised strategy, Army officials  recognize that the Army has a relatively young fleet of TWVs, averaging  9 years of age, many of which will be part of its fleet through 2040.
While this revised strategy has not been completed, the Army has already  made changes to reduce its TWV costs. For example, in February 2012  the Army reduced the number of FMTVs it planned to purchase by  approximately 7,400 vehicles. At that time, the Army also terminated a  HMMWV modernization effort, known as the Modernized Expanded  Capability Vehicle, which was intended to improve vehicle performance  and crew protection on over 5,700 HMMWVs. Officials stated that this  effort was terminated, in part, because of DOD-wide funding constraints.  Army officials estimate that these actions will result in a total savings of  approximately $2.7 billion in fiscal years 2013 through 2017. Furthermore,  Army officials stated that the Army plans to reduce the size of its TWV  fleet to match force structure requirements. They also stated that, as of  July 2012, the Army plans to reduce its total fleet by over 42,000 vehicles.  Officials added that more vehicles could be divested depending on any  future force structure changes and budget constraints.
Despite budget constraints, the industrial base will have some  opportunities over the next several years to produce a new TWV for DOD.  The Joint Light Tactical Vehicle (JLTV) is a new DOD program, designed  to fill the gap between the HMMWV and MRAP by providing near-MRAP  level protection while maintaining all-terrain mobility. As we previously  reported, the Army and Marine Corps are pursuing a revised  developmental approach for JLTV and awarded technology development  contracts to three industry teams. The program completed the  technology development phase in January 2012. Last month, the Army  awarded three contracts for the JLTV’s engineering and manufacturing  development phase. While production contracts will not be awarded for  some time, DOD reports that it plans to purchase approximately  55,000 JLTVs over a 25-year period with full rate production beginning in  fiscal year 2018. With production of other TWVs for DOD largely coming  to an end in fiscal year 2014, DOD considers the JLTV program to be  critical in maintaining an industrial base to supply TWVs to the military.
In addition to new production, the Army and Marine Corps also plan to  invest in sustainment efforts that could be completed by the U.S. TWV  industrial base. These efforts include restoring or enhancing the combat  capability of vehicles that were destroyed or damaged due to combat  operations. For example, Marine Corps officials reported that it plans to  recapitalize approximately 8,000 HMMWVs beginning in fiscal year 2013.  In addition, the Army is in the process of resetting the portion of its FMTV  fleet that was deployed through at least fiscal year 2017 as well as  recapitalizing some of its heavy TWVs.
section_title: Manufacturer Reliance on Sales to DOD Varied
paragraphs: Despite the significant decrease in DOD TWV purchases, the four  manufacturers we met with generally reported that these sales remain an  important part of their revenue stream. However, there is a wide range in  the degree to which the manufacturers were reliant on DOD in a given  year. For example, as shown in table 3, one manufacturer reported that  for 2007 its revenue from sales to DOD accounted for 4 percent of its total  revenue while another manufacturer reported such revenue was as high  as 88 percent, with the other two manufacturers falling within that range.
Among the four manufacturers, the extent of reliance on revenue from  DOD sales varied, in part, because of vehicles sold in the commercial  truck and automotive sectors. Aside from producing TWVs,  manufacturers produced or assembled commercial vehicles, such as  wreckers, fire trucks, school buses, and handicap-accessible taxis, as  well as vehicle components, such as engines, transmissions, and  suspensions.
According to the four manufacturers, their suppliers of TWV major  subsystem components generally produced items in the commercial  automotive and truck industries. For example, according to  manufacturers, suppliers generally produced parts, such as engines,  transmissions, axles, and tires for their commercial vehicles in addition to  supplying parts for the TWVs they produce. However, vehicle armor, a  major TWV component, is primarily a defense-unique item and those  suppliers were not typically used in the manufacturers’ commercial  vehicles.
section_title: DOD Has Several Studies Under Way to Assess the U.S. TWV Industrial Base
paragraphs: DOD currently has several studies under way to better understand the  U.S. TWV industrial base, its capabilities, and how declining DOD sales  may affect it. In 2011, DOD’s Office of Manufacturing and Industrial Base  Policy began a multifaceted review of the U.S. TWV industrial base that  includes surveying suppliers, conducting site visits, and paneling experts.  The Army’s TACOM Life Cycle Management Command also has ongoing  studies, including a review to assess the health of the industrial base and  others intended to identify its supplier base and any risks associated with  sustaining DOD’s TWV fleet. Some of the goals of these different studies  are to better understand how different vehicle supply chains affect others,  identify single point failures in the supply chain, and provide DOD  leadership with improved information so they may better tailor future  acquisition policies.
section_title: TWV Sales to Foreign Governments Were Relatively Few and Generally Purchased with U.S. Funds
paragraphs: U.S. manufacturers sold relatively few TWVs for use by foreign  governments in fiscal years 2007 through 2011, when compared to the  158,000 vehicles sold to DOD over that same period. However, most of  the manufacturers we met with stated that while sales of TWVs to foreign  governments have not equaled those sold to DOD, such sales are  becoming an increasingly important source of revenue as DOD  purchases fewer vehicles. According to data provided by DOD and the  four manufacturers, foreign governments purchased approximately  28,000 TWVs, either through the FMS program or through DCS, in fiscal  years 2007 through 2011. In addition to these sales to foreign  governments, manufacturers reported they exported approximately  5,000 other TWVs that were different vehicles than those DOD purchased  during that time period. Nearly all TWVs sold to foreign governments  were sold through the FMS program rather than through DCS. DOD  reports that about 27,000 TWVs were sold through the FMS program,  while the four manufacturers we met with reported that about  700 vehicles were sold through DCS in fiscal years 2007 through 2011.See figure 4 for a comparison of TWVs sold to DOD and to foreign  governments through the FMS program and DCS in fiscal years 2007  through 2011.
Approximately 95 percent of TWVs purchased through the FMS program  from fiscal year 2007 through 2011 were paid for using U.S. government  funding through different security and military assistance programs. The  U.S. Congress authorizes and appropriates funds for assistance  programs that support activities, such as security, economic, and  governance assistance in foreign countries. Examples of such assistance  programs include the Afghanistan Security Forces Fund and Iraq Security  Assistance Fund, which were sources of funding for TWVs purchased for  Afghanistan and Iraq through the FMS program. While Afghanistan and  Iraq were the largest recipients of U.S. manufactured TWVs through such  assistance programs, DOD officials informed us that as the war efforts  conclude there, U.S. funding for TWVs for these two countries’ security  forces has declined and is not planned to continue. In addition, a smaller  number of TWVs were sold through the FMS program to countries using  their own funds. Figure 5 identifies the countries that purchased the most  U.S. manufactured TWVs with U.S. or their own funds through the FMS  program.
section_title: U.S. Manufacturers and Foreign Governments Identified Multiple Interrelated Factors That May Affect TWV Foreign Sales
paragraphs: U.S. manufacturers of TWVs and foreign government officials we met  with identified a number of interrelated factors that they perceive as  affecting whether a foreign government decides to purchase U.S.  manufactured TWVs. These included potential future competition from  transfers of excess (used) U.S. military TWVs, competition from foreign  manufacturers, and differing foreign requirements for TWVs. In addition,  these U.S. manufacturers and foreign government officials expressed  mixed views on the effect the U.S. arms transfer control regimes may  have on foreign governments’ decisions to buy U.S. vehicles. These  officials said that processing delays and end-use restrictions can  influence foreign governments’ decisions to buy U.S. TWVs. Despite  these issues, foreign government officials said the U.S. arms transfer  control regimes would not adversely affect their decisions to purchase a  U.S.-manufactured TWV that best meets their governments’  requirements.
subsections: section_title: Potential Transfers of Used Army TWVs Viewed as Risk by Manufacturers to Future Sales of U.S. TWVs to Foreign Governments
paragraphs: The U.S. manufacturers we met with regard the Army’s intent to reduce  its TWV fleet size as a risk to their future sales of TWVs to foreign  governments. Army officials said it is still assessing its TWV requirements  and potential plans to divest over 42,000 vehicles, but they acknowledge  that a number of these TWVs could be transferred through the FMS  program. The four U.S. manufacturers consider these used vehicles to be  a risk to their future sales of U.S. TWVs to foreign governments because  foreign governments could be less likely to purchase new vehicles from  U.S. manufacturers if the U.S. Army transfers these used vehicles  through foreign assistance programs. U.S. manufacturers told us they  would like more involvement in DOD’s decisions on its plans for these  divested vehicles so they may provide input on potential effects on the  industrial base. Commerce’s Bureau of Industry and Security reviews  proposed FMS of divested items to identify effects on the relevant  industry. During this review, Commerce provides industry with the  opportunity to identify any impacts of the potential FMS on marketing or  ongoing sales to the recipient country. When approving these transfers,  State and Defense Security Cooperation Agency officials said the  U.S. government must also weigh national security and foreign policy  concerns, which could outweigh industrial base concerns with transfers of  used DOD TWVs to foreign countries.
While concerned about the potential for competition from the FMS of  these retired vehicles, U.S. manufacturers also view these planned  divestitures as a potential to provide repair or upgrade business that  could help sustain their production capabilities during a period of low  DOD demand. Some manufacturers we met with stated that they would  like to purchase DOD’s used TWVs, before they are made available to  foreign governments, so they may repair or upgrade them and then sell  them to foreign governments. DOD is currently reviewing its policies to  determine which vehicles, if any, could be sold back to manufacturers.  Another manufacturer, while not interested in purchasing the vehicles,  expressed interest in providing repair or upgrade services on the used  TWVs before they are sold to foreign governments. Defense Security  Cooperation Agency officials stated that excess defense articles, such as  the used TWVs, are generally made available to foreign governments in  “as is” condition and recipient countries are responsible for the cost of any  repairs or upgrades they may want to make. They added that in such  instances, it could be possible for U.S. manufacturers to perform such  services, but it would be at the direction of the purchasing country, not the  U.S. government.
section_title: Foreign Competition, Different Vehicle Requirements, and Concerns Associated with U.S. Arms Transfer Control Regimes Affect Foreign Governments’ Decisions to Purchase U.S. TWVs
paragraphs: Foreign government and manufacturer officials that we interviewed  identified a number of TWV manufacturers that compete with U.S.  manufacturers for international sales. Examples of foreign manufacturers  are shown in table 4.
Officials from two countries that had not purchased U.S. manufactured  TWVs explained that their countries have a well established automotive  industrial base capable of producing TWVs that meet their governments’  needs. While all of the foreign officials we interviewed reported that their  countries had no policies that favor their domestic manufacturers,  governments that have not purchased U.S. TWVs generally purchased  vehicles from domestic manufacturers. For example, foreign officials from  one country said that all of their government’s TWVs are assembled  within its borders.
While all of the competitors to U.S. TWV manufacturers are not  headquartered in the purchasing countries, foreign officials reported that  many of these companies have established dealer and supplier networks  within their countries. Foreign officials reported that these domestic dealer  and supplier networks make vehicle sustainment less expensive and  more manageable, in part, because it is easier and quicker to obtain  replacement parts or have vehicles repaired. In contrast, foreign officials  said that U.S. TWV manufacturers do not generally have the same dealer  and supplier networks within their countries. They added that this can  make maintenance of the U.S. vehicles more expensive, in part, due to  the added cost of shipping.
In addition to the number of TWV manufacturer competitors, foreign  officials also reported that there is limited foreign demand for TWVs.  Foreign officials reported that their governments purchase relatively few  TWVs compared to the U.S. government, in part, because their fleet size  requirements are much smaller. Foreign officials we interviewed reported  TWV fleets that ranged in size from 2 to 9 percent the size of the U.S.  Army’s fleet. For example, foreign officials from one country stated that  their military was in the process of upgrading its entire fleet of  approximately 7,500 vehicles, which is less than 3 percent of the size of  the U.S. Army’s TWV fleet.
Foreign government officials also explained that U.S. manufacturers can  generally produce TWVs to meet their governments’ requirements, but  the vehicles U.S. TWV manufacturers are producing for DOD do not  necessarily align with these requirements. Foreign government officials  identified the following areas where their governments’ requirements  differ from those of DOD:
DOD’s TWVs are generally larger than what their government can  support. For example, officials from one foreign government reported  that its military considered purchasing U.S. manufactured MRAP  vehicles but did not have the cargo planes required to transport a  vehicle the size and weight of DOD’s MRAP vehicles. Instead,  according to the official, this country purchased a mine and ambush  protected vehicle developed by one of its domestic manufacturers that  is smaller and lighter than the DOD’s MRAP vehicles and better  aligned with its transportation capabilities.
Their governments do not always require the same level of  capabilities afforded by DOD’s TWVs and, in some cases,  requirements may be met by commercially available vehicles. For  example, foreign government officials identified a number of vehicles  in their governments’ tactical fleets that are based on commercial  products from automobile companies such as Jeep and Land Rover.
Their governments have different automotive or design standards for  military vehicles that do not always align with those produced for DOD  by U.S. manufacturers. For example, officials from one country said  that their military is required to purchase right-side drive vehicles,  which are not always supported by U.S. manufacturers. While their  military can obtain a waiver to purchase a left-side drive vehicle, this  presents training challenges as the majority of the vehicles in its fleet  are right-side drive vehicles. Foreign officials said that while U.S.  manufacturers are capable of meeting these requirements, foreign  competitors may be more familiar with these requirements.  Manufacturers that we interviewed said they produce or are  developing TWVs to better meet foreign customers’ requirements. For  example, one U.S. manufacturer said it was developing a right-side  drive variant of one of its vehicles and another manufacturer said that  it has a line of TWVs for its international customers that better meets  those requirements.
U.S. manufacturers and foreign officials expressed mixed views on the  effect the U.S. arms transfer control regimes may have on the sale of  U.S.-manufactured TWVs to foreign customers. Officials we met with  reported that, generally, the U.S. arms transfer control regimes do not  inhibit foreign governments from purchasing U.S. manufactured TWVs.  Accordingly, we found that once the FMS and DCS process was initiated,  no eligible foreign sales or licenses for U.S. TWVs were denied. For  example, State officials reported that no countries eligible to participate in  the FMS program were denied requests to purchase TWVs in fiscal years  2007 and 2011. Similarly, State DCS license data indicated that no  licenses for vehicle purchases were denied from fiscal years 2008  through 2011.
While sales of TWVs to foreign governments are generally approved by  the U.S. government once initiated, U.S. manufacturers and foreign  officials said that foreign governments may prefer to purchase vehicle  manufactured outside the United States, in part, due to the amount of  time to process sales and licenses requests and end-use restrictions  associated with the U.S. arms transfer control regimes. Specifically,  manufacturers said the congressional notification process can result in  lengthy delays during the FMS and DCS approval process. The AECA  requires notification to Congress between 15 and 45 days in advance of  its intent to approve certain DCS licenses or FMS agreements.  Preceding the submission of this required statutory notification to the U.S.  Congress, State provides Congress with an informal review period that  does not have a fixed time period for action. One manufacturer stated that  this informal review period, in one case, lasted over a year and, after  which, the prospective customer decided to not continue with the  purchase. Another manufacturer said that the informal congressional  notification process is unpredictable because there is no set time limit for  review, making it difficult for the manufacturer to meet delivery  commitments to foreign customers. State officials acknowledged that the  informal congressional notification period can delay the DCS and FMS  process because there is no designated time limit for review. According to  State officials, the department established a new tiered review process in  early 2012 to address this issue by establishing a time bounded informal  review period that is based on the recipient country’s relationship with the  U.S. government. The formal notification period remains unchanged.
Foreign officials said when TWVs that meet their governments’  requirements are available from manufacturers outside the United States,  AECA restrictions on third party transfers and end-use administrative  requirements associated with U.S. manufactured vehicles could affect  their governments purchasing decisions. Foreign officials explained that  there are a number of TWV manufacturers outside the United States that  can meet their requirements and vehicles sold by those manufacturers do  not necessarily come with the same end-use restrictions as U.S. vehicles.  For example, the AECA restricts the transfer of arms, including U.S.  manufactured, TWVs to a third party without consent of the U.S.  government. Some foreign officials said their governments prefer to use  private companies, when possible, to make repairs and maintain its TWV  fleet because it can reduce costs compared to government repair work.  These foreign officials said that U.S. third party transfer restrictions  require that their governments obtain permission from the U.S.  government before transferring a U.S. TWV to a private company for  repairs, which creates an administrative burden. Additionally, foreign  governments are required to maintain information on U.S. TWVs’ end-use  and possession that must be available to U.S. officials when requested to  ensure compliance with U.S. end-use regulations. Foreign officials from  one country said the maintenance of this information is an administrative  burden and will be more difficult to manage as their government tries to  reduce its workforce in a limited budget environment. Foreign officials  said that TWVs purchased from manufacturers outside of the Untied  States are not generally encumbered with these same restrictions and  administrative burdens, making maintenance of these vehicles easier and  cheaper, in some cases. State officials acknowledged these concerns  from foreign governments but said these restrictions play an important  role in protecting U.S. national security interests.
Foreign officials reported, however, that the U.S. arms transfer control  regimes would not adversely affect their decision to purchase a U.S.  vehicle that best meets their governments’ requirements in terms of  capabilities and cost. Foreign officials said that U.S. manufacturers make  vehicles that are reliable and highly capable. When their governments  have requirements that align with those associated with U.S.  manufactured vehicles, foreign officials said that the U.S. arms transfer  control regimes would not be a factor in their governments’ decisions to  purchase the vehicles. Foreign officials that we interviewed also said their  governments are experienced buyers of U.S. arms and are able to  successfully navigate the FMS and DCS processes and U.S. end-use  restrictions to obtain the military equipment they require.
section_title: Concluding Observations
paragraphs: The volume of TWVs DOD purchased to meet operational requirements  in Iraq and Afghanistan was unique due to specific threats. Many of these  vehicles are no longer needed and DOD’s need for new TWVs is  expected to decline in coming years. Further, given the current budgetary  environment, DOD cannot afford to support the size of its current fleet or  buy as many vehicles as it once did. Though U.S. manufacturers  increased their production to meet those past needs, they will be  challenged in responding to the sharp decline in DOD’s TWV  requirements in future years. As DOD continues its studies of the U.S.  TWV industrial base, it may be better positioned to address these  challenges and how DOD can mitigate any risks to sustaining its TWV  fleet. It is unlikely that sales to foreign governments will ever offset  declines in sales to DOD, but foreign sales may be more important to the  industrial base now more than ever. U.S. manufacturers, however, are  presented with a number of factors that affect their ability to sell TWVs to  foreign governments. While no foreign officials indicated that their  governments would not buy U.S. TWVs, there has been relatively limited  demand for the vehicles U.S. manufacturers have produced for DOD.  Further, there are many foreign manufacturers that can supply vehicles  that meet foreign governments’ requirements. Each of the U.S.  manufacturers we met with was either selling or developing alternative  vehicles that better meet foreign governments’ requirements, but the  extent to which those efforts will stimulate additional sales has yet to be  seen. Further, U.S. manufacturers raised concerns that their competitors  could eventually include the U.S. military as it makes plans to divest itself  of used TWVs that it could make available to foreign governments at  reduced costs or for free. Additionally, while U.S. manufacturers  perceived the U.S. arms transfer control regimes to be more burdensome  than those of other countries, the regimes are not a determining factor  when foreign governments seek to purchase TWVs.
section_title: Agency Comments and Third-Party Views
paragraphs: We provided a draft of this report to DOD, State, and Commerce, as well  as the four manufacturers and five foreign governments with whom we  met, for their review and comment. DOD and State provide technical  comments and two of the manufacturers provided clarifications, which we  incorporated into the report as appropriate. Commerce, two  manufacturers, and the five foreign governments informed us that they  had no comments.
We are sending copies of this report to the Secretary of Defense; the  Secretaries of the Army and the Navy; the Secretary of State; Secretary  of Commerce; and the four manufacturers and five foreign governments  with whom we met. In addition, the report also is available at no charge  on the GAO website at http://www.gao.gov.
If you or your staff have any questions concerning this report, please  contact me at (202) 512-4841 or martinb@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 members who made key  contributions to this report are listed in appendix I.
section_title: Appendix I: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the contact name above, the following staff members made  key contributions to this report: Johana R. Ayers, Assistant Director;  Patrick Dudley; Dayna Foster; Beth Reed Fritts; Justin Jaynes; Julia  Kennon; Roxanna Sun; Robert Swierczek; Bradley Terry; Brian Tittle; and  Alyssa Weir.