Coast Guard Acquisitions: Enhanced Oversight of Testing Could Benefit National Security Cutter Program and Future DHS Acquisitions
Published: 2016-02-03T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Coast Guard's flagship, 418-foot NSC was first commissioned in 2008. It completed initial testing, an event designed to test all critical systems that are necessary for successful operations, in the spring of 2014, after 7 of the 8 planned cutters were already under contract and 3 ships were operational. GAO has been reviewing the NSC as part of its broader Coast Guard acquisition reviews since 2001.
This statement is primarily based on GAO's January 2016 report on the NSC's initial testing event ( GAO-16-148 ), and addresses issues related to (1) the results of the NSC's initial test event, (2) the Coast Guard's plans for follow-on testing, and (3) the performance of the NSC during operations. The statement also includes GAO's observations on the Coast Guard's acquisition approach for its Fast Response Cutter and Offshore Patrol Cutter programs. GAO reviewed these two programs in June 2014 ( GAO-14-450 ) and April 2015 ( GAO-15-171SP ) and also conducted selected updates on their acquisition status in January 2016. The statement also draws on GAO's prior work on commercial shipbuilding best practices.
section_title: What GAO Found
paragraphs: In January 2016, GAO reported that the Navy's Commander, Operational Test and Evaluation Force conducted the initial testing on the National Security Cutter (NSC) in spring 2014, when three of the cutters were already operational. The Navy deemed the NSC operationally effective and suitable. At the same time however, the testing revealed some major deficiencies. Two metrics used to assess an asset in testing are key performance parameters (KPP) and critical operational issues (COI). The NSC met 18 of 19 COIs and 12 of its 19 KPPs. Navy testers found 10 major deficiencies that varied in terms of their effect on the NSC program, including 4 deficiencies related to the NSC's weapon systems and 1 for its cutter boats. The Coast Guard plans to correct most of the NSC's major deficiencies.
Also, as GAO reported, following initial testing, a Department of Homeland Security (DHS) acquisition review board approved the NSC program for full rate production in October 2014. The Coast Guard plans to begin follow-on testing in fall 2016. DHS acquisition guidance does not specify the timing of follow-on testing for its programs or any actions program offices should take in response to the findings of follow-on testing. As a result, future DHS acquisitions risk fielding assets without knowing the full capabilities, as was the case with the NSC.
GAO also found that problems discovered outside of testing are preventing the Coast Guard from operating fully capable NSCs. By the time of initial testing, the Coast Guard had nearly 4 years' experience operating NSCs and has encountered issues that require retrofits. In order to minimize cost increases for some changes, the Coast Guard plans to maintain the original equipment for the production of the remaining NSCs and conduct retrofits after accepting delivery. In some instances, replacement equipment is still in the prototype phase. The identified problems will continue to affect the NSC until retrofits are implemented.
GAO has observed, based on prior work reviewing the Coast Guard's ongoing Fast Response Cutter program and plans for its upcoming Offshore Patrol Cutter program, that the Coast Guard has matured its acquisition process. The process to date reflects some lessons learned from the NSC acquisition, for example in the areas of competition and the schedule for initial testing. Furthermore, as the $12 billion Offshore Patrol Cutter program moves forward, it may have opportunities to further incorporate some best practices that GAO has highlighted in May 2009 ( GAO-09-322 ) and March 2013 ( GAO-13-325 ) on other shipbuilding work. For example, before a contract is signed, best practices call for a full understanding of the effort needed to design and construct the ship to be reached, enabling commercial buyers and shipbuilders to sign a contract that fixes the price, delivery date, and ship performance parameters.
section_title: What GAO Recommends
paragraphs: In January 2016 ( GAO-16-148 ), GAO recommended that DHS take several actions to strengthen oversight of test and evaluation of major assets. GAO also recommended that the Coast Guard direct the NSC program to clarify the key performance parameters for cutter boat operations. DHS and the Coast Guard concurred with all of these recommendations.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the status of the Coast Guard’s  National Security Cutter (NSC) program, in particular its initial test results  and operational effectiveness. The flagship, 418-foot NSC was first  commissioned in 2008, and completed initial operational test and  evaluation (IOT&E), an event designed to test all critical systems that are  necessary for successful operations, in the spring of 2014, after 7 of the 8  cutters were under contract. We have been reviewing the NSC as part of  our broader Coast Guard acquisition reviews since 2001.
My statement today is based on our January 2016 report on the NSC’s  IOT&E event. I will address issues related to (1) the results of the NSC’s  IOT&E, (2) the Coast Guard’s plans for follow-on operational test and  evaluation (FOT&E), and (3) the performance of the NSC during  operations. I will also offer observations on the acquisition approach of  the Coast Guard’s Fast Response Cutter (FRC) that is currently being  deployed and the planned Offshore Patrol Cutter (OPC). The FRC  replaces the Coast Guard’s Island Class Patrol boat, and provides greater  fuel capacity and improved communications capabilities over the legacy  asset, as well as the ability to conduct full operations in moderate sea  conditions. The OPC is intended to replace the Coast Guard’s aging  Medium Endurance Cutter fleet and is to be the backbone of the cutter  fleet for the foreseeable future. We most recently reviewed the FRC and  OPC as part of our June 2014 report on Coast Guard acquisitions, which  was work requested by this committee, and our April 2015 report on the  Department of Homeland Security’s (DHS) major acquisitions.
Based on findings from our January 2016 report, we recommended that  DHS take several actions to strengthen oversight of test and evaluation of  major assets. We also recommended that the Coast Guard direct the  NSC program to clarify the key performance parameters (KPP) for cutter  boat operations. DHS and the Coast Guard concurred with all of our  recommendations.
For our January 2016 report, we reviewed the NSC’s program  documentation, including test reports, and key metrics the Coast Guard  uses to evaluate assets. We interviewed Coast Guard officials and  officials from the Navy’s Commander, Operational Test and Evaluation  Force (COTF)—which conducted the NSC testing—to determine areas  where the NSC is or is not meeting required capabilities and performance  metrics. To add important context to our review, we toured the NSC used  for IOT&E (Stratton) and interviewed the Commanding Officer concerning  his experiences operating the vessel and its capabilities. To assess the  Coast Guard’s plans for FOT&E, we reviewed Coast Guard and DHS  guidance and Coast Guard documents. We interviewed Coast Guard  officials to determine the timeline for FOT&E, identify what systems will  be tested, and determine what, if any, changes are planned for the NSC  fleet based on IOT&E and operations. To assess the performance of the  NSC during regular operations, we reviewed after action reports and  engineering reports, which are prepared by the cutters’ commanding  officers, to identify any equipment casualties (i.e., equipment failures) the  cutters are experiencing on a regular basis and the effect that these  casualties are having on operations. We also toured the Huntington  Ingalls Industry shipyard in Pascagoula, Mississippi, where the NSCs are  built to gain an understanding of how design changes are incorporated  into the production process. For our April 2015 review that included the  OPC and FRC, we reviewed the programs’ schedules, cost estimates,  and acquisition plans and interviewed program officials. For our June  2014 report, we reviewed the acquisition program baseline for programs  in the Coast Guard’s portfolio as well as the Coast Guard’s budget and  discussed the acquisition portfolio with Coast Guard, DHS, and Office of  Management and Budget officials and followed up on previous efforts to  address affordability. This statement also draws from our prior work on  commercial best practices in shipbuilding. More information about the  scope and methodology of this past work can be found in these reports.  We also obtained updated information from the Coast Guard on the  acquisition status of the FRC and OPC, which we incorporated as  appropriate throughout the statement, and shared with Coast Guard  officials our observations on the FRC and planned OPC acquisition  approaches.
We conducted the work on which this statement is based 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: DHS and Coast Guard acquisition guidelines require operational test and  evaluation by an independent test agency to confirm that the production  configured system meet all requirements before approval for full-rate  production. The Coast Guard uses the U.S. Navy’s COTF to conduct  operational tests and other evaluations for its major acquisition programs  according to those programs’ requirements. COTF serves as an  independent evaluator of an asset’s capabilities and has experience  testing U.S. Navy assets.
In conducting operational testing, COTF evaluates an asset’s operational  effectiveness and suitability:
For operational effectiveness, testers determine whether or not an  asset can meet its missions.
For operational suitability, testers determine whether or not the  agency can logistically support the asset to an acceptable standard,  such as having the asset available for operations 85 percent of its  scheduled deployment time.
Critical operational issues (COI) are one metric used to determine an  asset’s operational effectiveness and suitability and are stated in the form  of a question. COIs are examined during testing to evaluate a system’s  ability to provide the desired capability and perform its mission. COTF  assessed the NSC’s COIs, for example, by comparing the outcome of the  test event against the full scope of the COI to determine whether the COI  was met or not. Unmet COIs are often the result of related deficiencies,  which are identified during testing and include any system that is lacking  in its ability to meet normal standards or to function as intended.  Deficiencies are scored based on the severity of the problem and its  impact on the asset’s ability to accomplish its mission. COIs and  deficiencies identified during testing both factor into an asset’s overall  operational effectiveness and suitability rating.
In addition to verifying that an asset is operationally effective and suitable,  operational testing also tests key performance parameters (KPP), which  are the capabilities considered essential for mission accomplishment.  KPPs are listed by threshold values, which are the minimum acceptable  level of performance, and objective values, which are the desired level of  performance. For example, a KPP for the NSC is being able to reach a  maximum speed of 28 knots for a threshold value and 31 knots for an  objective value. KPPs differ from COIs in that KPPs focus on specific  performance metrics, while COIs focus on certain types of missions that  an asset should be able to conduct or an asset’s ability to be ready to  perform those missions. Table 1 provides examples of COIs and KPPs for  the NSC.
Operational testing can occur over many test events. Two of those key  test events are:  Initial Operational Test and Evaluation (IOT&E): This event is meant  to gather the data necessary to resolve COIs, determine an asset’s  operational effectiveness and suitability, and, according to Coast  Guard acquisition guidance, occur prior to a full-rate production  decision. The test event concludes with a rating of operationally  effective or not effective, operationally suitable or not suitable.
Follow-on operational test and evaluation (FOT&E): This event is  conducted after IOT&E and an asset’s full rate production decision  and focuses on refining the conclusions that were made during  previous operational test events, evaluating production changes, and  reevaluating the system to ensure that it continues to meet  operational needs. It also validates any incomplete or deferred  requirements and verifies the correction of deficiencies identified  during IOT&E. FOT&E concludes with an operational effectiveness  and suitability rating similar to that of IOT&E.
Following IOT&E and FOT&E, COTF writes a test report that focuses on  the resolution of the asset’s COIs and any deficiencies that were  identified during testing. These reports typically include a summary of the  resolution of the asset’s COIs.
section_title: While Initial Operational Testing Revealed Some Major Deficiencies, the NSC Met Most of Its Key Performance Parameters
paragraphs: As we reported in January 2016, IOT&E took place about 2 years later  than planned and after 7 of the 8 planned NSCs were under contract, with  3 operational. We have previously found that delaying critical test events  can lead to late discoveries and could result in additional design changes  and costs to programs. The 8 NSCs are planned to be fully operational  by 2020 and the Coast Guard is phasing out the legacy 378-foot High  Endurance Cutters as the NSCs enter operations. During testing, the  NSC successfully demonstrated 18 of its 19 COIs, with one COI— cybersecurity—being deferred to FOT&E. This deferral was due to the  DHS Director of Operational Test and Evaluation (DOT&E) postponing  the testing of the NSC’s cybersecurity capabilities until a more robust test  plan could be developed to reflect emerging threats.
At the conclusion of IOT&E, COTF found the NSC to be operationally  effective and suitable, but with 10 major deficiencies. None of the major  deficiencies were rated as severe, which would preclude the NSC from  accomplishing its mission. Five of the 10 major deficiencies pertained to  the NSC’s weapon systems and cutter boats. Table 2 shows the 10  deficiencies.
In its assessment of the NSC’s IOT&E event, DOT&E stated that the  reliability and operational availability issues of the weapon systems—the  CIWS, NULKA Launcher, TRS-3D air search radar, and the 57-mm gun— affect the overall ability of the NSC to conduct certain missions. While the  CIWS, NULKA launcher, and air search radar were all repaired following  IOT&E, post-operational reports indicate that problems persist with these  systems as they were often unavailable during operations. Despite these  findings, as noted above, COTF found the NSC to be operationally  effective and suitable.
While COIs and deficiencies factor into a system’s operational  effectiveness and suitability rating, KPPs are measures of the capabilities  considered essential to mission accomplishment. In our January 2016  report, we found that during IOT&E and other test events, the NSC fully  met 12 of its 19 KPPs. However, by not meeting all KPPs, the Coast  Guard is not able to demonstrate that the NSC is providing the  capabilities that it intended to field. For instance, the Coast Guard has not  yet demonstrated that the NSC can achieve a hard and soft kill against a  subsonic cruise missile as required, or fully meet interoperability  requirements with the Department of Defense, DHS, and other  government agencies. Table 3 displays the 7 KPPs not fully met for the  NSC, the test results, and a discussion of these results.
Of the 7 KPPs not met, 3 pertain to the NSC’s cutter boat operations. The  cutter boats are designed to be integral to the NSC’s overall capability,  operate both within and beyond the visual range of the NSC, and  enhance the overall mission effectiveness of the NSC in every mandated  mission area. We found that the Coast Guard and COTF have different  interpretations of the cutter boat KPPs. COTF conducted IOT&E  according to the NSC’s test and evaluation plan and determined that the  three KPPs involving cutter boats were not fully met since the boats are  unable to operate through all sea state 5 conditions. According to Coast  Guard officials, the September 2012 requirements document for the NSC  should have been written more clearly to convey the sea state  expectation for cutter boat launch and recovery operations, since the  NSC’s sea state KPP was never intended to be applicable to the  operation of the cutter boats. In January 2016 we recommended, and the  Coast Guard concurred, that the NSC’s KPPs for the operation of the  cutter boats should be clarified.
section_title: Unclear Guidance on Follow-on Testing May Lead to NSCs and Future DHS Assets Deploying without Having Demonstrated Full Capabilities
paragraphs: As we reported in January 2016, according to COTF officials, FOT&E will  begin in the fall of 2016 and is scheduled to continue through at least  2017. Following IOT&E, DHS held an acquisition review board (ARB) to  discuss the outcome of IOT&E, which resulted in DHS approving the NSC  program for full rate production in October 2014. ARBs review major  acquisition programs for proper management, oversight, accountability,  and alignment with DHS’s strategic functions at acquisition decision  events and other meetings as needed. The resulting acquisition decision  memorandum (ADM) from October 2014 directed the Coast Guard to  conduct FOT&E and complete three action items: (1) complete testing of  the cybersecurity COI; (2) verify the correction of all major deficiencies,  including the unmet KPPs; and (3) assess the NSC’s cyber-security  capabilities. The cybersecurity COI is planned to be tested in 2016,  which, if successful, will address the first and third requirements of the  ADM, but other testing events are expected to occur through 2017 and  possibly beyond.
The ADM also directed the Coast Guard to verify the correction of all  deficiencies, including the 7 unmet KPPs. According to Coast Guard  officials, they have corrected 4 of the 10 major deficiencies from IOT&E  that involved equipment failures by restoring the operational status of the  related systems on the Stratton, and they have plans to correct four more.  However, according to Coast Guard documentation and officials, they  may not correct 2 deficiencies due to the cost of making fleet-wide  changes, and because the Coast Guard has developed an interim  solution. Table 4 shows the Coast Guard’s plans, as we reported in  January 2016, for resolving the major deficiencies.
As we also found in January 2016, while the Coast Guard has plans to  conduct FOT&E for the NSC, it will have accepted the delivery of at least  the 6th NSC before the testing is complete, meaning that the Coast  Guard will be operating 6 NSCs before it has resolved issues from IOT&E  and knows the cutter’s full capabilities. DHS’s guidance for its major  acquisitions does not require programs to conduct FOT&E, nor does it  specify the timing of FOT&E or the actions that should be taken following  the completion of testing. Further, DHS’s directive on test and  evaluation does not include any direction or guidance on FOT&E.
We concluded in our January 2016 report that this gap in DHS guidance  also has implications for future DHS assets. Most significantly, the Coast  Guard is in the process of designing the OPC, which is the last of the  major cutter classes to be built as part of the recapitalization program.  This cutter class, which is intended to bridge the mission gap between the  FRC and NSC, is estimated to cost $12.1 billion, making it the most  expensive Coast Guard recapitalization program to date. Without  updated guidance that establishes timeframes and responsibilities for  completing all testing, the Coast Guard risks encountering the same  scenario with the OPC—and other future DHS assets—that it has  experienced with the NSC. That is, the Coast Guard could continue to  buy assets without having demonstrated their full capabilities in testing. In  January 2016 we recommended that updated guidance should establish  factors that should be considered with planning FOT&E, including when  test events will be concluded. We also recommended that an ARB be  held, if necessary, to provide oversight and specify any further actions  programs should take following FOT&E. DHS agreed with these  recommendations and estimated they would be implemented by  November 2016.
section_title: Problems Discovered Outside of IOT&E Are Preventing the Coast Guard from Operating Fully Capable NSCs
paragraphs: As we reported in January 2016, by the time of the spring 2014 IOT&E  event, the Coast Guard had nearly four years of experience operating the  NSCs. The Coast Guard has encountered several issues that require  major retrofits and design changes on the NSC to correct problems  encountered during operations and discovered during test events outside  of IOT&E. The total cost of changes we identified as of June 2015 totals  approximately $202 million. In order to minimize cost increases for some  of these changes, the Coast Guard plans to maintain the original  equipment design for the production of the remaining NSCs and plans to  conduct retrofits after accepting delivery of the cutters. In some instances,  replacement equipment is still in the prototype phase. The problems  identified with these systems during operations will continue to impact the  NSC until the design changes are implemented across the fleet. Figure 1  shows selected systems that will require retrofits after all eight cutters are  built.
Early testing can allow performance issues to be discovered at a point  when fixes can be incorporated into the design of an asset while it is still  in production. As we have previously found for Department of Defense  programs, continuing with full-rate production before ensuring that assets  meet key requirements risks replicating problems in each new asset until  such problems are corrected. The Coast Guard conducted IOT&E several  years after it began operating the NSC and after the contracts for the  majority of the fleet had been initiated. As a result, the Coast Guard plans  to purchase and install equipment with known design flaws on the NSCs  that are currently in production. Thus, the Coast Guard will be faced with  paying for the replacement of these systems with new equipment that it  must also purchase.
Furthermore, we found in January 2016 that the Coast Guard has  encountered a variety of problems with the cutter’s propulsion systems  during operations and, although there are several factors known to  influence these problems, the root causes and the method and cost of  potential solutions are not yet known. The problems include: (1) high  engine temperatures, which limit the top speed of the cutter in certain  conditions, (2) cracked cylinder heads, which are occurring at a rate  higher than expected and are the NSCs number one operational degrader  and cost driver for maintenance, and (3) overheating generator bearings,  which have caused at least one patrol to be cut short due to the lack of an  effective backup generator. Although the Coast Guard has two studies  underway to identify the root causes of these problems, until the causes  are identified and corrective actions implemented, the Coast Guard is at  risk of experiencing costly and potentially mission-limiting problems with  this equipment across the fleet. Thus, we recommended, and DHS  agreed, to provide oversight and specify any further actions the NSC  program should take at the conclusion of the studies related to the  propulsion systems.
section_title: Observations on the FRC and OPC Acquisitions
paragraphs: As the Coast Guard has progressed in its acquisition of cutters, it has  matured its acquisition processes, which has been demonstrated in its  approach with the FRC and OPC programs. The process to date reflects  some lessons learned from the NSC acquisition, for example in the areas  of competition and the schedule for IOT&E. Furthermore, as the $12  billion OPC program moves forward, it may have opportunities to further  incorporate some best practices that we have highlighted in our past work  on shipbuilding.
As we reported in June 2014 and April 2015, the Coast Guard purchased  the technical specifications and licenses necessary to build the FRC in  order to use the information to conduct a full and open competition for the  remaining 26 of 58 planned vessels. According to Coast Guard officials,  the second phase of the acquisition was intended to promote competition  and allowed bidders on the contract to make certain design changes to  the ship, though the key performance parameters remain the same and  the design for several critical systems—such as the propulsion system,  generators, hull structure, and bridge layout—remain the same. The  Coast Guard plans to award a contract for the second phase of this  acquisition by the end of June 2016. We noted in June 2014 that when  the government owns technical data rights, it does not need to rely on  only one contractor to meet requirements.
As we also reported in April 2015, the Coast Guard is using a two- phased, competitive strategy to select a contactor to construct the OPC.  In general, as we have previously found, competition is likely to save  taxpayer dollars as opposed to a sole source acquisition approach, such  as was used for the NSC. During the first phase for the OPC, the Coast  Guard conducted a full and open competition to select three contractors  to perform preliminary and contract design work, and, in February 2014,  awarded firm-fixed price contracts to three shipbuilders. For the second  phase, the Coast Guard plans to award, by the end of fiscal year 2016, a  contract to one of these shipbuilders to complete the detailed design of  the vessel and construct the first 9 to 11 ships. As we also reported, the  Coast Guard plans to recompete the contract for the remaining vessels.
Competitive contracts can allow for the best return on investment for  taxpayers by saving taxpayer money, conserving scarce resources,  improving contractor performance, curbing fraud, and promoting  accountability for results. According to Coast Guard officials, the Coast  Guard currently plans to award the construction contract for the lead OPC  ship in fiscal year 2018 and deliver this ship in 2021. As we found in April  2015, the OPC’s initial and full operational capability dates both slipped  15 months, which the Coast Guard attributes to procurement delays,  including a bid protest that GAO ultimately denied in June 2014. The  Coast Guard’s fiscal year 2016 Capital Investment Plan reflects $1.5  billion in funding for the OPC, which funds the detailed design work and  construction of the first three vessels. After the first 3 of the planned fleet  of 25 OPCs are built, the Coast Guard plans to increase its purchase to 2  OPCs per year until the final asset is delivered, currently scheduled for  fiscal year 2035.
Regarding the timeframes for IOT&E, as we reported in January 2016,  this event occurred for the NSC after 3 of its 8 planned cutters were  operational. For the FRC, IOT&E occurred after 4 of the planned 58  cutters were operational. For the OPC, the Coast Guard plans to begin  IOT&E by December 2023, by which time it expects to have 1 operational  OPC of a planned buy of 25.
In addition to its efforts to enhance competition, the Coast Guard has  developed a warranty provision under its contract with Bollinger  Shipyards for the FRC program that has held the contractor responsible  for production deficiencies. As we reported in June 2014, the Coast  Guard does not always have insight into how much it costs the  contractors to fix these issues. However, after multiple deficiencies  interrupted production, officials noted they are confident that the Coast  Guard has received value from this warranty. The Coast Guard plans to  use these strategies when purchasing the OPC.
Based on best practices that we have previously identified, the Coast  Guard may have opportunities to incorporate additional shipbuilding best  practices with the OPC program. In May 2009, we reported on best  practices that commercial shipbuilders use to ensure that ships are  delivered on time and within budget. We found that before a contract is  signed, a full understanding of the effort needed to design and construct  the ship is reached, enabling commercial buyers and shipbuilders to sign  a contract that fixes the price, delivery date, and ship performance  parameters. To minimize risk, buyers and shipbuilders reuse previous  designs to the extent possible and attain an in-depth understanding of  new technologies included in the ship design. Before construction begins,  commercial shipbuilders complete key design phases that correspond  with the completion of a three-dimensional product model. Final  information on the systems that will be installed on the ship is needed to  allow design work to proceed. During construction, buyers maintain a  presence in the shipyard and with key suppliers to ensure the ship meets  quality expectations and is delivered on schedule. We will continue to  assess the progress of the FRC and OPC acquisitions going forward.
Chairman Hunter, Ranking Member Garamendi, and Members of the  Subcommittee, this concludes my prepared statement. I would be  pleased to respond to any questions.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: If you or your staff have any questions about this statement, please  contact Michele Mackin at (202) 512-4841 or mackinm@gao.gov. In  addition, contact points for our Offices of Congressional Relations and  Public Affairs may be found on the last page of this statement. Individuals  who made key contributions to this testimony include Katherine Trimble,  Assistant Director; John Crawford; Lindsey Cross; and Peter W.  Anderson.
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