Littoral Combat Ship: Additional Testing and Improved Weight Management Needed Prior to Further Investments
Released: 2014-07-30T00:00:00

Letter

Background

The LCS consists of two separate acquisition programs: one for the seaframe and one for the mission packages, which, when integrated with the seaframe and supplemented with aviation support, provide the ship’s mission capability. In order to demonstrate LCS mission capability both seaframe variants will be evaluated through developmental and operational testing. Developmental testing is intended to assist in identifying system performance, capabilities, limitations, and safety issues to help reduce design and programmatic risks. Operational testing is intended to assess a weapon system’s capability in a realistic environment when maintained and operated by warfighters, subjected to routine wear-and-tear, and employed in combat conditions.

Seaframe

The Navy is procuring two different seaframe designs from shipbuilding teams led by Lockheed Martin—which builds its ships at Marinette Marine in Marinette, Wisconsin—and Austal USA in Mobile, Alabama. This report refers to the Lockheed Martin ships as the Freedom variant and the Austal USA ships as the Independence variant. The two designs reflect different contractor solutions to meet the same set of performance requirements. The most notable difference is that the Lockheed Martin Freedom variant (LCS 1 and other odd-numbered seaframes, 3 through 23) is a monohull design with a steel hull and aluminum superstructure, while the Austal USA Independence variant (LCS 2 and other even- numbered seaframes, 4 through 24) is an aluminum trimaran.shows the first two LCS seaframes.

See table 1 for the current status of seaframe construction.

As we previously reported, the Navy is investigating potentially significant design changes to the ships while production is under way. Some of these initiatives include:

Changes to improve habitability: Part of the LCS concept is to reduce the number of crew on the ship by relying extensively on shore-based support for the ship’s administrative personnel and maintenance needs. Prior to the deployment of LCS 1 to Singapore, the Navy added 20 extra beds—called berths—to the ship to accommodate extra people, and has also made a similar change to LCS 2 and subsequent ships. However, the Navy did not add equivalent amounts of crew storage space, additional water and sanitation systems, and food storage, and while the Navy officials stated that the ships still meet requirements, the Navy is investigating changes to better meet Navy standards. The Navy and the shipyards are now evaluating how to make these changes to both variant designs, but the effects have been described by the program office as pervasive throughout much of the ship.

Changes to increase commonality: many of the systems on the two seaframe variants are not common; commonality can enhance efficient maintenance, training, manning, and logistics. The Navy is investigating making changes to improve commonality between the two variants, including selecting a common combat management system—an architecture that uses computers to integrate sensors (such as a radar) with shipboard weapon systems—for both seaframes.

Changes to improve safety: the Independence variant was designed without bridge wings, which are enclosed areas that extend out to the sides of the ship from the bridge to provide enhanced visibility and safety for the crew for maneuvers like docking the ship. The Navy has added bridge wings to LCS 2, and now plans to add bridge wings to all the ships of this variant.

Ship Weight

As part of the decision to make any design changes to a ship, the designer needs to consider the effect that the changes might have on ship weight. Weight is a critical aspect of a ship design, and is measured in several ways:

Light ship condition: The ship is complete and ready for service, repair parts are held onboard, and liquids in machinery are at operating levels. Light ship condition does not include items of variable load, such as officers and crew; ammunition; aircraft and vehicles that are fully fueled with repair parts available; full supply of provisions and stores; and full tanks for potable water, lube oil, and fuel. For LCS, the light ship condition does not include installation of a mission package.

Full load condition: Light ship condition plus variable loads. For LCS, full load condition includes an installed mission package and is the condition against which performance requirements are assessed.

Naval architectural limit: The maximum weight that a ship can displace while still meeting its stability and survivability requirements. For LCS, naval architectural limits are unique to each seaframe variant.

To ensure that ships meet required capabilities, the Navy and its shipbuilders typically engage in intensive estimating, weighing, and reporting processes throughout construction to identify and monitor a ship’s weight and stability. As part of these processes, shipbuilders actively estimate and track certain information, including the following:

Builder’s margin, which consists of weight and vertical center of gravity allowances included in a weight estimate to cover slight variations of component weight and centers of gravity that take place throughout the design and construction of a ship.

Service life allowances, which refer to weight and vertical center of gravity budgets included in a ship’s design to accommodate changes due to ship alterations and unplanned growth during the ship’s operational lifetime, which tend to increase displacement and affect stability.

Weights are definitively determined as part of a ship’s inclining experiment, which involves moving known weights around the ship and measuring how they change the ship’s equilibrium. This allows for the Navy to determine a ship’s displacement and the height and longitudinal position of its center of gravity. For most ships, inclining experiments take place immediately prior to delivery and after significant post-delivery maintenance periods, when necessary.

Mission Packages

The LCS mission package designs are based on standard shipping containers that are outfitted with a variety of unmanned systems, sensors, and weapons that can be loaded onto and off of the seaframe. Mission packages are also accompanied by an aviation detachment, consisting of an MH-60 helicopter and its flight and support crew, as well as vertical take-off unmanned aerial vehicles. These packages are intended to give the Navy flexibility to change equipment in the field to meet different mission needs and incorporate new technology to address emerging threats. The Navy plans on fielding one anti-submarine warfare (ASW) increment and four mine countermeasures (MCM) and surface warfare (SUW) increments. The Navy will upgrade all mission packages to the same configuration as additional increments are fielded. The Navy plans to buy a total of 64 mission packages—though this quantity could change if the number of seaframes acquired is reduced. See table 2 for a brief discussion of the mission packages.

Initial LCS Deployment

To obtain operational experience with LCS, the Navy last year deployed USS Freedom carrying an increment 2 SUW mission package. The ship departed San Diego, California, for operations in the Western Pacific under the command of the Navy’s 7th Fleet in early March 2013. The ship was deployed for approximately 10 months, returning to the United States in late December 2013. The 7th Fleet area of responsibility poses unique challenges to the Navy given the vast distances it covers. While on this deployment, USS Freedom participated in an international exhibition as well as several multilateral naval exercises with regional navies, including Singapore; Malaysia; Brunei; and Indonesia. The ship also conducted some real-world operations as directed by the 7th Fleet, such as participating in humanitarian assistance disaster relief to the Philippines following a major typhoon. See figure 2 for a map showing the location of the Singapore deployment and the Navy fleet areas of responsibility in the Indo-Pacific region.

Initial Deployment and Further Testing Yielded Additional Learning about LCS Systems and Capabilities, but Gaps in Knowledge Remain

Since July 2013, the Navy has made progress demonstrating and testing various facets of LCS systems and capability but significant gaps remain in the Navy’s knowledge of how the LCS will operate and what capabilities it will provide the Navy. The deployment to Singapore provided the Navy with an opportunity to examine key LCS concepts operationally, including: the ship’s smaller manning profile, rotational crewing, and use of off-ship maintenance and support. The deployment was limited because only one of the two variants carrying one mission package was deployed, and mechanical problems prevented USS Freedom from spending as much time as planned underway—that is, at sea unanchored and not at port. As a result, some key concepts could not be demonstrated. While the deployment provided useful insight for the Navy, it was never intended to be a substitute for formal testing and evaluation activities. The Navy has also completed additional developmental testing on the seaframes and mission packages, which has enabled the Navy to characterize performance of some systems, but many capabilities have not been demonstrated in an operational environment.

Singapore Deployment Provided Useful Knowledge about LCS Operations, but Significant Unknowns Persist Regarding LCS Concepts and Use

Navy officials have stated that they were able to learn some valuable lessons from the deployment of USS Freedom to Singapore, and the Navy has taken several steps to analyze post-deployment lessons learned. According to the Navy, the deployment demonstrated the LCS’s ability to participate in cooperative exercises and helped carry out the Navy’s forward presence mission in Asia, thereby freeing up more costly multi-mission warships to carry out other high-priority Navy duties. Navy officials also said USS Freedom demonstrated how a LCS can fill the need for a smaller U.S. ship that can dock in more foreign ports than larger U.S. vessels, which they believe will be a valuable tool for engaging with certain countries that might otherwise be hard to access. Further, USS Freedom’s SUW mission package crew was able to conduct some launch and recovery operations with Rigid Hull Inflatable Boats and to participate in boarding exercises, which provided lessons about the operations of these boats as well as the systems on USS Freedom needed to launch and recover them. These operations, although undoubtedly useful for the Navy, were never intended as formal testing and evaluation activities—or to replace them. Therefore, key unknowns remain regarding how the Navy will eventually be able to use the LCS and how well the ship meets its performance requirements.

Initial Deployment Provided Insight, but Key Concepts Remain Untested or Not Validated

USS Freedom’s deployment to Singapore represented an opportunity for the Navy to gain insight into the feasibility of the LCS’s unique operational concepts. However, some of the fundamental concepts on which the program is premised—such as the maintenance and manning concepts— were demonstrated in a limited manner because the deployment involved only one ship of the Freedom variant and this ship is not representative of other ships of that variant. In other cases, certain concepts have not yet been demonstrated. Therefore, some of the lessons learned from the deployment cannot be extrapolated to the entire LCS class or all of the ships planned for the Freedom variant. Until additional deployments have been conducted—in conjunction with operational test events—the Navy will have insufficient data to evaluate the feasibility of these concepts on both variants. Table 3 identifies the key concepts that underpin the program and the degree to which the Navy was able to Questions remaining regarding evaluate them on this deployment.LCS’s underlying concepts will, in turn, have implications for the practicality of certain requirements and key differences between the two variants—issues that have the potential to affect future acquisition decisions.

In addition, mechanical problems hampered the Navy’s ability to operate USS Freedom as planned during the Singapore deployment. Based on information provided by LCS program officials responsible for LCS fleet introduction, USS Freedom’s mechanical failures resulted in 55 days of mission days lost, which is a significant portion of its 10-month deployment. Navy officials stated many of these days were planned in- port periods. The ship could not fully participate in at least two planned or requested exercises and some operational 7th Fleet presence missions while repairs were conducted. According to the LCS program office, several of the more problematic pieces of equipment that resulted in significant lost underway days are either slated to be replaced on follow-on Freedom class ships or have already have been replaced on LCS 3 or LCS 5. Table 4 depicts some of the most significant equipment failures and how the Navy believes they have been corrected on subsequent seaframes.

Even with the reduced number of operational mission days, the Singapore deployment raised questions about the practicality of the small crew size. LCS is intended to operate with a crew that is smaller than comparable surface combatants. This reduced manning has long been a focus of Navy analysis, and the increase to a 50-person crew for the deployment was the maximum size allowed by current program requirements. This number was augmented by civilian contractor technical experts who could assist with troubleshooting and some maintenance. However, as shown in table 3, even with these additional people the deployment provided indications that the crew strained to keep up with duties. Further, the ship is currently at capacity in terms of the number of crew members it can accommodate. Therefore, any increase in crew size would require a significant redesign of the seaframes and would necessitate a revision to the maximum 50-person manning requirement, which has been validated by the Joint Requirements Oversight Council. Officials from the office of the Chief of Naval Operations told us after the deployment that they are not considering any further revision to the manning requirements for the ship, although some manning studies are under way to assess the rank and billet structure for the mission packages and aviation detachment.

Additionally, some of USS Freedom’s equipment is unique to that ship, unique to the Freedom variant, or unique to LCS class, which we were told made some repair efforts cumbersome and slow. For example, crew members told us that in some cases they had to track down spare parts that were sometimes available only in foreign countries rather than being able to find them in Navy inventories. While some of this may be a first-of- class issue, replacement of some ship systems with more reliable ones or with systems that are more commonly found in the Navy inventory may also reduce these burdens on the crew in the future. According to the LCS program office, replacing these less reliable systems should mean that future deployments of other ships from the Freedom class should not incur the same number of failures as USS Freedom. However, as DOT&E has observed, no formal operational testing has been conducted to verify and quantify these improvements, although Navy and DOT&E officials said that they were working together on operational test opportunities. Until the Navy completes further underway periods and/or testing it will not be able to determine the significance of improvements on ship availability.

Fleet Observations on Deployment Highlight Potential Limitations on LCS Usage

This first deployment provided limited insight into how the LCS might be utilized in the different theaters in which the Navy operates. USS Freedom was deployed to Singapore and conducted operations for 7th Fleet largely consisting of participation in planned multi-lateral exercises. While 7th Fleet officials noted that a benefit of having LCS in theater was that the ship could participate in international exercises, thereby freeing up other surface combatants for other missions, they were still not certain about the ship’s potential capabilities and attributes, or how they would best utilize an LCS in their theater. Until the Navy completes additional testing and deployments, it will not have adequate operational data and operational experience on which to base assumptions regarding LCS utilization. Table 5 discusses some of the observations related to the LCS deployment that we discussed with 7th Fleet officials related to the LCS deployment.

Navy Has Made Progress with Recent Testing but Additional Testing Needed to Demonstrate LCS Capabilities

Since July 2013, the Navy has completed additional testing on the seaframes and mission modules and is seeing results but has not yet proven performance in an operational environment. Table 6 describes these recently completed events and some important considerations about the testing.

Outstanding Weight Management and Concurrency Risks Continue to Complicate LCS Acquisition

Although the Navy has gained knowledge related to LCS capabilities and concepts since our July 2013 report, there continue to be significant acquisition risks to the program. Key among these is managing the weight of the ships. Initial LCS seaframes face limitations resulting from weight growth during construction of the first several ships. This weight growth has required the Navy to make compromises on performance of LCS 1 and LCS 2 and may complicate existing plans to make additional changes to each seaframe design. While weight growth is not uncommon over the life of a ship and the Navy builds a weight allowance into ships to account for this growth, LCS has significantly lower available margin compared to other ship classes. Compounding these issues, the Navy has not received complete or accurate weight reports from the LCS seaframe prime contractors—and the Navy’s lengthy review process has hindered a timely resolution. Additionally, as we have previously reported, the Navy has considerable testing to complete before the program demonstrates operational capability. Further, the Navy has continued with the acquisition without the knowledge that would be gained from additional testing. For example, since our last report, the Navy has granted the mission modules program approval to accelerate the mission package production rate before completing key test activities to demonstrate their performance.

Seaframe Weight Growth Affects Performance and Design Changes, with Navy Oversight Challenged by Inadequate Contractor Weight Reports

Weight growth occurred on the first four LCS seaframes, which affected the capabilities of both Freedom and Independence variant seaframes. This situation has led the Navy to accept lower than minimum requirements on two delivered seaframes (LCS 1 and 2) in endurance and sprint speeds, respectively. Further, weight growth has caused three delivered LCS seaframes (LCS 1, 2, and 4) to not achieve the required service life allowance for weight. Weight management in shipbuilding programs, including the LCS, is critical to ensuring that performance requirements associated with survivability, sea keeping (meaning the ability to withstand rough sea conditions), and the ability to accommodate upgrades during ship service lives, are met. For LCS seaframes, specific performance requirements that are sensitive to weight include the following:

3,500-nautical-mile range (endurance) when operated at a speed of

40-knot sprint speed,

20-foot navigational draft (the greatest depth, in feet, of the keel),

50-metric-ton service life allowance for weight, and

0.15-meter service life allowance for stability.

In the LCS program, weight management and reporting processes also rely on accurate mission package weight data. The Navy provides mission package weight estimates to the shipbuilders to include in their full load condition estimates.

Table 7 identifies the Navy’s current weight estimates for each of the first six LCS seaframes under full load conditions, along with current service life allowance projections for each ship as compared to the required 50 metric tons. As is depicted, there are several seaframes that do not have the required amount of service life remaining due to weight growth.

LCS 2 faces the most significant weight challenges of any of the first six seaframes, but Navy officials stated they have a strategy to mitigate the issue while still meeting requirements. According to Navy estimates, LCS 2 is so heavy in the full load condition that it exceeds its naval architectural limit—an outcome that provides no service life allowance for weight and restricts the ship’s ability to execute its required missions. Subject matter experts in naval architecture who we interviewed stated that operating a ship in excess of its naval architectural limit can make it prone to failure in certain weather or damage conditions, and the ship can also see a decreased service life due to structural fatigue. Navy officials stated that they will limit fuel loads on LCS 2, as necessary, to ensure the naval architectural limit is not exceeded. In addition, the Navy is developing design modifications for Independence variant seaframes to reduce fuel capacity—estimated to total over 100 metric tons—in order to restore service life allowances. Although this reduction will reduce the endurance of these ships, the Navy reports that this variant has excess fuel capacity—as demonstrated during LCS 2 calm water trials in June 2013—and will still meet LCS range at transit speed requirements after the fuel reduction.

Further, as table 7 shows, three of the other LCS seaframes—LCS 1, LCS 4, and LCS 6—also do not currently meet their service life allowance requirements for weight when configured in normal, full load conditions. For example, LCS 1 and LCS 4 have near or less than 50 percent of the required 50 metric ton service life allowances for weight (25.8 and 16.5 tons, respectively), and the Navy projects LCS 6 will enter service with less than 63 percent (31.3 metric tons) of its required 50 metric ton service life allowance for weight. At present, LCS 6 has over 29 metric tons of builder’s margin available, which if still available at delivery could offset that particular ship’s estimated service life allowance deficit for weight.

Weight growth contributed to LCS 1 and LCS 2 not achieving some requirements related to endurance and sprint speed respectively, when operated in normal, full load conditions. For instance, although LCS 1 meets its sprint speed requirement of 40 knots, excess weight growth to date in part prevents that ship from achieving the 3,500 nautical miles at 14 knots endurance requirement. Alternatively, LCS 2 can only sprint at 39.5 knots under full loads, but is predicted to exceed the endurance requirement by over 800 nautical miles, albeit at potential risk to its naval architectural limit, as discussed above.

LCS Has Low Weight Growth Margins Compared to Other Ship Classes

Complicating the weight growth on early LCS seaframes is the fact that LCS requirements for service life allowances already fall short of the growth margins called for under Navy and industry recommended practice. Table 8 outlines recommended service life allowances for different ship types as compared to LCS requirements.

Because of the LCS’s comparatively low service life allowance requirements, the Navy’s ability to accommodate alterations and growth on these ships over their expected 20-year minimum service lives will be significantly more constrained than is typical for other surface ships. In 2012, the Office of the Chief of Naval Operations highlighted the importance of this issue across ship classes, noting in an instruction that inadequate service life allowances for weight and vertical center of gravity have resulted in expensive corrective ship changes or in the inability to modernize ships through installation of new weapons systems.

Low Growth Margins May Complicate Future Changes

Navy program officials told us they expect that most future weight—and capability—growth on LCS would occur within mission packages, not seaframes. However, as we previously reported, the Navy is considering changes to the seaframe designs that could further increase weight estimates. As mentioned above, these changes could include increases in: (1) habitability to support larger crews than initially anticipated; (2) commonality between the seaframe variants and with other Navy ships; and (3) changes to improve safety. We reported in July 2013 that the Navy had undertaken several technical studies on these initiatives. These studies have not yet been completed. Navy officials stated that the possible changes are low risk and would not affect LCS performance requirements. However, some changes, including those related to habitability, are likely to add weight. According to the program office, weight considerations occur for every change and corresponding trades are required to be made in order to approve the change. For example:

Early estimates indicate that roughly 10 to 20 metric tons could be added due to accommodations for a larger crew, and would require pervasive modifications to each seaframe design. If so, these changes would heighten weight challenges and resulting service life allowance shortfalls.

A change was made to LCS 2 in a recent maintenance period to increase the size of the rescue boat from 5 meters to 7 meters, which will make the boat more stable in heavier seas. This change resulted in an approximately 15 metric ton weight increase to LCS 2; it is planned for all Independence variant seaframes. According to the contractor, by removing weight from other areas of LCS 6 and follow-on ships designs, the larger rescue boat will add 1.3 metric tons.

Another proposed change would increase commonality and combat capability by replacing the Freedom variant’s rolling airframe missile system with the heavier missile system found on the Independence variant. While the specifics of this potential change have not yet been determined or approved, Navy technical experts told us that such a modification would subsequently increase the Freedom variant’s weight and could also result in center of gravity changes.

Weight constraints could make future modifications more costly than anticipated. For instance, subject matter experts in naval architecture told us that the Navy may find it has to seek lighter alternatives to the systems or equipment it wants, which could complicate the redesign and construction modification efforts or make them more costly—or both. Because the Navy has not yet completed technical studies evaluating its possible changes, the weight effects remain unknown. According to Navy officials, preliminary studies on the habitability changes should be completed this year, and more detailed design work will not occur until fiscal year 2015. The Navy has established a weight working group with Navy and shipyard representatives that program officials said is intended to try and identify ways to offset weight growth from some of these design changes.

Additionally, once a ship is delivered and handed over to the fleet, fleet operators and maintainers assume responsibility for these weight management processes, which continue throughout the ship’s service life. For ships that are weight constrained—meaning, at or nearing their naval architectural limits for displacement—these weight management processes are typically more robust and costly. For instance, a Navy instruction states that weight must be kept within naval architectural limits and provides that for ships that are weight constrained, any additional weight must be compensated for by removing weight from the ship. Inclining experiments must usually be completed following maintenance periods to ensure the ship’s naval architectural limits remain unbreached. As operational assets, LCS 1 and LCS 2 are—according to Navy reporting—both in a weight constrained status.

Mission Package Weights Continue to Evolve, but Growth Margin Is Constrained

According to Navy officials, the seaframes have low growth margins because the mission packages are supposed to be flexible enough to accommodate any future upgrades and growth. However, weight challenges exist on the mission packages as well, and weight and space constraints are limiting the extent to which the Navy can accommodate new mission package systems. Similar to the seaframes, the Navy also tracks and manages mission package weights. Mission packages (regardless of which type) are required to consume no more than 180 metric tons when installed aboard a seaframe. Of this 180-metric-ton allocation, 105 metric tons are allotted to the actual mission package equipment, whereas 75 metric tons are reserved for fuel to power that equipment. However, LCS requirements documents do not include a service life allowance requirement for mission packages, and based on current weight estimates, room for future growth on the final increments ranges from approximately 14 metric tons for some configurations of the MCM mission package to none for the ASW mission package. According to Navy officials, future additions to mission packages—beyond the systems currently planned for increment 4 configurations—will be offset by removing existing systems, described below, to the extent required to meet the 105 metric ton weight limitation. For MCM, Navy officials stated that they cannot include all the current increment 4 systems that they are buying in a package at one time, so they have recently developed two options with different system configurations. Figure 3 highlights current mission package weights that are estimated for each increment of mission package capability, including the two MCM options but excluding potential weight reduction efforts.

At present, the Navy anticipates that the equipment associated with an increment 4 SUW package will require slightly less than the 105-metric- ton allotment. This estimate is contingent on surface-to-surface missile systems not yet selected delivering within the assigned weight margins.

The Navy has identified a weight reduction plan to provide an additional 5 metric tons.

Navy weight estimates for increment 4 of the MCM mission package, however, do not reflect all the systems being acquired for that package. Space and weight constraints have required the Navy to modify how it intends to outfit increment 4 of the MCM mission package. Although the Navy plans to acquire all the systems planned for that increment, space and weight limitations will not allow LCS seaframes to carry all of these systems at one time. According to LCS program officials, MCM mission commanders will have either (1) the Unmanned Influence Sweep System and the unmanned surface vehicle that tows it, or (2) the minehunting Surface Mine Countermeasures Unmanned Undersea Vehicle—called Knifefish—available—but not both systems. As a result, LCS seaframes outfitted with the increment 4 MCM package may have decreased minesweeping or mine detection capability. These scenarios would preclude LCS from meeting its MCM minesweeping performance requirements; Knifefish is a new capability that was recently added to the program, and officials from the mission module program office stated that it is not a capability currently defined in LCS requirements documentation. The Navy has identified some options for weight reduction for this package that could bring the combined weight with these two systems included together to just under 105 metric tons, but physical space constraints would still prohibit both being carried together.

Further, ASW mission package equipment is also estimated to exceed its 105-metric-ton allotment by approximately 4 metric tons. In response, the Navy has identified weight reduction options within that package that it estimates will shed a combined 10 metric tons of weight. Several of these options require redesign of existing systems, which could introduce risk.

Deficiencies in Contractor Reports Have Hindered Navy Oversight of LCS Weight Challenges

The Navy has faced challenges obtaining accurate and complete weight estimates from the contractors. The Navy’s primary mechanism for tracking seaframe weights are quarterly weight reports, which are produced and delivered by each of the LCS prime contractors per contract requirements. These reports provide data on the physical characteristics of seaframes under construction, including the magnitude, location, and distribution of weight within each ship. These data are based on estimated and calculated weights derived from design drawings, historical data, and vendor-furnished information, and are updated with actual component weight information during construction by the shipbuilder. Under the terms of their contracts, LCS prime contractors are required to prepare and report data within weight reports in accordance with Navy and industry recommended practices, which include using the Navy’s Expanded Ship Work Breakdown Structure (ESWBS) classification system to structure and summarize data. ESWBS facilitates the grouping of materials, equipment, and ship components in a consistent reporting format, which in turn positions Navy reviewers to audit the contractors’ work. At their highest level, ESWBS groupings are organized around major systems of the ship, such as the hull structure and propulsion plant, but ESWBS groupings are broken down to include individual components of these respective systems, such as diesel engines.

An inclining experiment is important as it represents the point where weight data transitions from estimated or calculated data into actual data. According to Navy officials, when the weight of a ship is determined at an inclining experiment, the weight totals should be very close to those identified in the preceding weight reports. Acceptable deviation is considered to be only 0.5 percent or less, according to Navy technical experts. In the LCS program, however, inclining experiments for the first two seaframes revealed weight growth that the prime contractors had not fully accounted for within their weight reports. For example, the LCS 1 inclining experiment that followed that ship’s initial post-delivery work periods revealed that the ship weighed approximately 90 metric tons more than expected. However, it was unclear to the prime contractor where this excess weight was located or how it was distributed within the ship, though Navy program officials told us that they now believe it was due largely to additional insulation and paint. In response, Lockheed Martin increased its weight estimates for LCS 3 and worked with the Navy to evaluate and resolve the 90 metric ton discrepancy. As part of these analyses, Lockheed Martin was able to assign much of the weight growth to individual ESWBS accounts, and subsequently inclined LCS 3 to within 1 percent of that ship’s revised weight estimate. However, full resolution of the 90 metric tons weight discrepancy remains incomplete. Weight reports for LCS 5 and follow-on ships identified over 23 metric tons of weight that Lockheed Martin and the Navy have not yet identified as belonging within specific ESWBS accounts. Similar to LCS 1, LCS 2’s inclining revealed an approximately 5 percent deviation from expected weight, and General Dynamics’ Bath Iron Works and Austal USA have over 13 metric tons of weight, outside of the ESWBS accounts, on later Independence variant seaframes. Carrying forward excess weight can have impacts on the ships over the course of their service lives, and may have impacts on construction of follow-on seaframes. In order to remedy persisting deficiencies in the weight reports, Navy officials stated that the administrative contracting officer—responsible for ensuring that the contractor is fulfilling the contract under the specified terms, including price, schedule, and quality—could withhold a percentage of progress payments. To date, however, Navy officials report that they have not pursued such withholds in the LCS program.

As part of the terms of the block buy contracts for LCS seaframes, the Navy is required to review and comment on weight reports within 60 days after they are submitted by a prime contractor. During the past 2 years, the Navy has, in several cases, provided detailed comments back to the contractors on weight reports that it identified as deficient. Comments back to the prime contractors identified fundamental classification and estimating errors and the use of outdated weight information, among other reporting deficiencies, which the Navy judged as time sensitive and critically important to address (see appendix II, which contains excerpts from Navy comments on contractor weight reports). The Navy often requested LCS prime contractors to modify and resubmit the report within 30 days—consistent with the terms of the contracts.

However, the prime contractors have not addressed the Navy’s comments and resubmitted weight reports, largely because the Navy’s review is typically taking longer than 60 days. One contractor stated that the Navy’s review took 6 to 12 months. According to Navy officials, reviews of weight reports now take less than 6 months. Nevertheless, by the time that the Navy’s comments for one particular report are submitted to the contractor, the contractor has often already submitted the next quarter’s weight report. As a result, LCS contractors stated to us that they generally do not make revisions to the previously submitted reports. Thus, issues raised in the Navy’s comments are not immediately addressed by the contractors. These revisions can affect weight estimates, but cannot be identified until a corrected weight report has been submitted. As a result, serious issues within weight reports persist that could obscure timely identification of negative weight trends within one or both seaframe variants.

Risk of LCS Concurrency Remains—with Mission Package Procurement Exceeding Levels Needed for Operational Testing

As we previously reported, the Navy’s acquisition approach to the LCS program involves a significant degree of concurrency; that is, the Navy is buying the ships while key concepts and performance are still being tested. Since we issued our report in July 2013, the Navy received approval from DOT&E for the LCS test and evaluation master plan (TEMP), which sets forth the testing that must be completed to ensure that the program meets requirements. In order to determine the degree to which the information from test events would be available to inform the Navy’s decision to purchase additional seaframes, we compared the Navy’s current acquisition strategy—which calls for releasing a request for proposals in 2015 in support of a planned 2016 award of future seaframe contracts—with the program’s test schedule as outlined in the most recent TEMP. Figure 4 illustrates the test events that will be completed before and after these acquisition events.

As shown in figure 4, we found that a number of significant test events as outlined in the TEMP will not be completed in time to inform the development or release of a request for proposals or the award of follow- on contract(s), or they will be completed on one variant but not both. Many of these test events are part of operational testing. Operational testing includes live-fire testing, which provides timely assessment of the survivability and lethality of a weapon system. The significance of conducting operational testing is reflected by the fact that statute requires a program to complete realistic survivability tests and initial operational testing before starting full rate production. The Navy plans to continue buying seaframes before completing operational test events that demonstrate the capability of the seaframes, that is, equipped with mission packages that can meet initial requirements. Other tests highlighted in the figure include shock and survivability tests, which demonstrate that the ship designs can safely absorb and control damage. Realistic survivability tests are required by statute before a program proceeds beyond low-rate initial production.

Moreover, based on current test plans, DOT&E has concerns about the adequacy and nature of some tests, which led to lengthy revisions of earlier versions of the TEMP. Due to these concerns, DOT&E issued a conditional approval letter stating that the test plan was not adequate to support later phases of operational testing, and that the out-years of the program are still not well defined. Final performance requirements are defined in the program’s capabilities development document, and last year the Navy developed requirements for increment 2 SUW and increment 1 MCM to support testing. However, no requirements currently exist for the other increments. DOT&E granted the Navy approval to move to the operational testing of increment 2 SUW and increment 1 MCM as described in the TEMP, which the Navy plans to begin in 2014 and 2015, respectively, but DOT&E required the Navy to update and resubmit the TEMP to support testing for later increments. As such, the above schedule may change with subsequent TEMP submissions.

To help mitigate the concurrency in the LCS program—in particular to better align planned contractual actions with obtaining knowledge through some of these test events—we recommended in July 2013 that the Navy reassess its acquisition strategy. Specifically, we recommended that the Department of Defense (DOD) limit future seaframe acquisitions until it completed a full-rate production review. We also recommended that DOD report to Congress on the relative advantages of each seaframe variant for each key LCS mission prior to awarding any additional seaframe contracts. In its written response, DOD did not agree with our recommendations aimed at slowing the pace of seaframe procurements. DOD cited the need to buy ships at the planned pace to keep pricing low and saw no value in reducing production pending the full-rate production decision. DOD agreed that the Navy could, if requested by Congress, report on the performance of each seaframe variant against current LCS requirements, but did not address the need to provide an assessment of the relative costs and advantages and disadvantages of the variants against operational and mission needs. Such steps remain important to help ensure that the level of capability provided by LCS is militarily useful given the warfighter’s current capability needs and that continued investment in the program is warranted.

Pace of Mission Package Procurement Outpacing Levels Needed for Operational Testing

The Navy continues to move forward with a strategy that buys mission packages before their performance is demonstrated. The Navy held a Milestone B review for the mission packages in January 7, 2014, which would typically authorize a program to begin system design and demonstration efforts and determine the low-rate production quantity, which is necessary to—among other things—provide production configured or representative articles for operational tests. Based on this review, the Assistant Secretary of the Navy for Research, Development, and Acquisitions authorized the program to effectively accelerate mission package production, granting the program approval to procure 5 test units According to DOD guidance, and up to 27 production mission packages.low-rate production usually begins at Milestone C, when programs are authorized to begin initial production. As we highlighted in our last report, continuing into what is essentially full-rate production—as this 32 mission packages is half of the total planned quantity of mission packages for the program—increases the risk that the Navy will be purchasing systems that have not been validated to meet requirements through testing. We also recommended in July 2013 that the Navy only buy the minimum quantities of mission module systems required to support operational testing. DOD did not agree with this recommendation, stating that mission package procurements were at a rate necessary to: support (1) developmental and operational testing of the two seaframe variants with each mission module increment; (2) fleet training needs; and (3) operational LCS ships. In its memorandum on the Navy’s Remote Minehunting System (RMS) operational assessment and Milestone C decision, DOT&E raised similar concerns, stating for example that the Navy should strictly limit any production of RMS, including the Remote Multi-mission Vehicle (RMMV), until greater system maturity and reliability are demonstrated on the version of RMS that will be initially fielded.

We also recommended in July 2013 that the Navy ensure that the program baseline submitted for the mission modules’ Milestone B establish program goals for cost, schedule, and performance for each mission module increment. DOD partially concurred with this recommendation, but our review of the program baseline found that it does not define the thresholds and objectives for performance for each increment of the mission modules. Officials from the office of the Chief of Naval Operations stated that there is no plan to update the baseline to include this performance information since they believe that the LCS mission package increments actually represent only one increment of capability. Without defined performance thresholds and objectives for each mission package increment, decision makers will continue to lack information needed to effectively monitor the development of the increments, and a baseline against which to measure performance.

Additional Reporting Should Provide Congress with Key Information to Support Decision Making

We raised two matters for Congressional consideration in our July 2013 report. First, to ensure that continued LCS investments are informed by adequate knowledge, we suggested that Congress consider restricting funding for additional seaframes until the Navy completes ongoing technical and design studies related to potential changes in LCS requirements, capabilities, and the commonality of systems on the two seaframe variants. Second, to ensure timely and complete information on the capabilities of each seaframe variant prior to making decisions about future LCS procurements, we suggested that Congress consider requiring DOD to report on the relative advantages of each variant in carrying out the three primary LCS missions.

In the National Defense Authorization Act (NDAA) for Fiscal Year 2014, Congress directed the Navy to complete a number of studies that are in line with our recommendations to provide additional information on some of the risk areas that we identified. The legislation restricts the obligation or expenditure of fiscal year 2014 funding for construction or advanced procurement for LCS seaframes 25 and 26 until the Navy submits the required reports and certifications. However, as LCS 25 and LCS 26 are not yet under contract, the Navy cannot use fiscal year 2014 money to fund these seaframes. As of the end of January 2014, Navy officials told us that they had just begun coordinating efforts and collecting data to write reports as required in the NDAA for Fiscal Year 2014. A copy of this NDAA requirement can be found in appendix III.

Conclusions

The Navy has made progress since our last report in demonstrating LCS capabilities. In particular, completing the initial deployment of an LCS with a mission package to an overseas location provided the Navy with important real-world lessons learned that are being used to refine plans for subsequent deployments. However, these deployments are not a substitute for operational testing. Completing further developmental and operational test events will continue to provide the Navy will valuable data with which it can evaluate the performance of systems and make adjustments, as needed. The Navy still has a great deal of learning to do about the ships, the integrated capability that they are intended to provide when equipped with the mission packages, and how the overall LCS concept will be implemented. Not having adequate knowledge—such as the results of additional deployments and key operational test events— may result in the Navy buying ships that are more costly or burdensome to manage over the course of their service lives. Events such as rough water trials, shock and total ship survivability trials are intended to provide confidence that the ships will last their intended lifespan and are survivable, while deployments and operational testing of initial mission packages help provide confidence that the LCS will meet its performance requirements. Moving forward without this information complicates potential design changes to seaframes or mission packages.

As we have concluded in past work, the Navy’s continued approach of procuring the ships before proving their capabilities through testing increases the risks of costly retrofits or reduced performance. In addition, the Navy’s recent decision to accelerate the acquisition of mission packages further limits the flexibility that the program will have to adjust to any problems that may arise during operational testing. With the Navy’s planned fiscal year 2016 contract awards for seaframes fast approaching, we believe the recommendations that we made in July 2013 are still important steps that the Navy can take to reduce risks to the program, but additional steps are also warranted.

Further, the Navy’s ability to manage the ships’ weight has been constrained, as the contractors’ reporting has not been accurate or in a format that would be most useful to naval engineers. The Navy could improve the expediency with which it reviews and comments on contractor weight reports. Tools are available to improve the contractor’s weight reporting, such as pursuing financial withholds, and modifying the LCS contracts to include additional mechanisms to ensure better reporting. More accurate and timely reporting will help the Navy target the drivers of weight growth and assess the feasibility of the additional design changes being considered for both seaframe variants.

Recommendations for Executive Action

1. We recommend that the Under Secretary of Defense for Acquisition, Technology, and Logistics require—before approving the release of the request for proposals for future contracts for either seaframe variant—that both variants: a. Have deployed to a forward overseas location; b. Have completed rough water, ship shock, and total ship survivability testing; and c. Have completed initial operational test and evaluation of the SUW mission package on the Freedom variant and the MCM mission package on the Independence variant. 2. To improve the Navy’s ability to effectively oversee weight management of the LCS seaframes, we recommend the Secretary of the Navy direct the LCS Seaframe Program Manager to a. Take steps to ensure that the Navy completes its reviews and submits comments, if any, on the weight reports to the contractors within the timeframes dictated by the contract; and b. Consider actions to make the contractor more responsive to the Navy’s identified accuracy and content problems in the weight reports, including pursuing financial withholds or modifying the contract language.

Agency Comments and Our Evaluation

We provided a draft of this report to DOD for review and comment. In its written comments, which are included in appendix IV, DOD partially agreed with our recommendations to complete certain testing and deployment activities before approving the release of the request for proposals for future seaframes. DOD agreed with our recommendations related to seaframe weight management.

DOD officials stated that they have every intention of completing as many as possible of the test and demonstration items that we identified in our recommendation before releasing the request for proposals (RFP) for future seaframe contracts, but disagreed that the release of the RFP should hinge on completion of these events. DOD officials stated that creating a break in the production of the seaframes would increase program costs and have significant industrial base considerations. We are not advocating a production break, but we do believe it is conceivable that subsequent seaframe unit cost increases could be lower than the potential increases in overall program costs if testing uncovered the need for costly retrofits, redesign, and/or requirements changes that would then have to be made to ships in production. We chose to use the release of the RFP as a decision point because we believe that drafting an RFP that is based on key knowledge of LCS performance serves as an important risk mitigation tool for the government. Specifically, if the government goes forward with an RFP that is not fully informed by the results of the important test activities we identified in our recommendation, any changes that might be later identified as necessary would have to be reflected in an amended RFP, which could delay the award of contracts and potentially cause a production break. The department noted that a Defense Acquisition Board (DAB) review is planned in the fiscal year 2016 time frame and that the Board will approve the Navy’s acquisition strategy for LCS before additional seaframe contracts are awarded. DOD stated that this review will take into account the progress of testing for both seaframes, and that every item we identified in our recommendation will be completed prior to the DAB except for the completion of the full- scale ship shock trials. We believe it will be important that the department makes certain that the DAB review occurs at a point when the Navy can be directed to pause and revise its acquisition strategy and the RFP for LCS if necessary to ensure it reflects the most current knowledge gained from testing and deployments. It is possible that continued testing could inform changes to the numbers of each variant procured, changes that would need to be incorporated into the acquisition strategy before the DAB authorizes the Navy to continue to buy more seaframes.

Further, we continue to believe that the Navy needs to identify a means to conduct a full-scale ship shock trial before committing to contracts for further seaframes. Because the LCS seaframes are based on commercial designs—though heavily modified—we believe these trials are important to ensure that the Navy is buying ships that will meet its survivability needs. This is especially true with the Independence class variant, which is based on a novel hullform for the Navy and represents the Navy’s first- time use of aluminum for a ship of this size. The Navy has itself identified that it lacks sufficient data on which to confidently base assumptions of this variant’s performance in an underwater shock environment, which makes completing this test event before DAB review and award of contracts important.

DOD agreed to take steps as we recommended to improve the weight management of the LCS seaframes, and plans to review within 180 days the process by which it reviews the contractor weight submissions and the methods by which it can ensure that the contractors are responsive to Navy accuracy and content concerns.

We also provided relevant portions of the draft report (in particular, the sections on weight management) to the contractors and incorporated their technical comments as appropriate.

We are sending copies of this report to the appropriate congressional committees and the Secretaries of Defense and the Navy. In addition, the report is available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at 202-512-4841 or mackinm@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 key contributions to this report are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

To assess the Navy’s lessons learned from the deployment of the first Littoral Combat Ship (LCS) to Singapore, we analyzed reports from various LCS stakeholders, including Navy 7th Fleet Destroyer Squadron 7 (responsible for LCS during the deployment), and the Office of the Chief of Naval Operations (OPNAV). We also traveled to the forward-deployed location in Singapore, and interviewed USS Freedom’s commanding officer and some of the crew; as well as officials from the LCS fleet introduction program office (PMS 505); Destroyer Squadron 7; and Commander, Logistics Force Western Pacific. We also traveled to Japan to interview 7th Fleet officials involved with LCS logistics; policy and planning; warfare requirements; strategy; and operations. Furthermore, we conducted interviews with relevant Navy officials, such as the OPNAV office that is the resource sponsor for the LCS program (N96); LCS seaframe program office (PMS 501); and the LCS and Joint High Speed Vessel Council. To assess what knowledge the Navy has obtained about LCS since our previous report, we analyzed DOD, Navy and contractor documents, including test and evaluation letters of observation from the Commander, Operational Testing and Evaluation Force (COTF); testing reports from the Director, Operational Testing and Evaluation (DOT&E); as well as the Board of Inspection and Survey (INSURV) reports. We analyzed documentation from the LCS mission module program office (PMS 420), including an LCS contractor test report. Furthermore, we interviewed officials from OPNAV; the LCS and Joint High Speed Vessel Council; Naval Sea Systems Command (NAVSEA); DOT&E; COTF; INSURV; the Naval Surface Warfare Center; the LCS seaframe program office; the LCS mission module program office; and the Navy Modeling and Simulation Office. Finally, we leveraged previous GAO reports on the LCS dating back to 2005.

To assess additional risks for the LCS program related to weight management, we analyzed Navy and contractor documentation including weight reports; inclining experiment reports; LCS seaframe contracts; the LCS Capabilities Development Document; and seaframe building specifications. To understand weight management and reporting practices, we analyzed the Society of Allied Weight Engineers Recommended Practices and NAVSEA policies on weight management. Furthermore, we conducted interviews with Lockheed Martin; Bath Iron Works; Marinette Marine; Austal USA; the American Bureau of Shipping; and the Navy’s Supervisor of Shipbuilding. To evaluate the naval architecture limits of the LCS seaframes, we interviewed retired naval architects with significant Navy ship design experience, as well as American Bureau of Shipping representatives. We also met with technical experts from the Naval Systems Engineering Directorate (SEA05).We analyzed Navy and contractor documents, including the LCS test and evaluation master plan; DOT&E test and evaluation master plan approval memo; the LCS mission modules Milestone B documentation; and the Navy’s acquisition decision memorandum. Furthermore, we conducted interviews with officials from DOT&E; COTF; and INSURV.

We conducted this performance audit from September 2013 to July 2014 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.

Appendix II: Selected Navy Comments on Recent LCS Weight Reports

Appendix II: Selected Navy Comments on Recent LCS Weight Reports Navy comment “Main structural elements such as shell, framing and decks are calculated by frame… This results in nearly impossible review and audit capability. This method does not adhere to Extended Ship’s Work Breakdown Structure (ESWBS)…”

Associated prime contractor Austal USA “Weight report structure and format are problematic. The subject quarterly weight report consisted of various disjointed, mislabeled, and conflicting files which are difficult to assemble and correlate for reporting purposes.”

LCS 6 and follow-on Independence variant seaframes “It appears the computer aided design effort to incorporate detail data for Group 1 weights is fraught with ESWBS classification errors…It appears Group 1 has been arbitrarily classified to the point of a loss of control of the details.”

LCS 6 and LCS 8 “The LCS 3 quarterly weight reports overestimated the ship by approximately 90 tons. The details of that same database have essentially been carried over to the LCS 5 accepted weight estimate and subsequent quarterly weight reports…The last two quarterly weight reports have not shown any progress toward improving the details (via recalculations) and reducing risk…”

Lockheed Martin LCS 5 and “The LCS 6 and LCS 8 calculated light ship condition with remaining margin is projected to be 56 tons lighter than LCS 4 inclined light ship condition. When the…correction is incorporated into the projection, the full load condition for weight exceeds the (naval architectural limit) for displacement by…30 tons. Specifically, the service life allowance for weight is deficient by 30 tons. This is a serious and unprecedented situation that has to be addressed quickly.”

Non-submission “Submittal did not include an updated quarterly weight report…a no-submittal indicates the projected full load of the ship at delivery is currently unknown.”

LCS 6 and follow-on Independence variant seaframes “Mission package descriptions, weights and centers have not been updated in years. The Contractor must update the mine countermeasures and surface warfare mission packages with the latest values.”

Appendix III: 2014 National Defense Authorization Act Navy Reporting Requirements

Section 124 of the National Defense Authorization Act for Fiscal Year 2014 restricts the obligation or expenditure of fiscal year 2014 funding for construction or advanced procurement for LCS seaframes 25 and 26 until the Navy submits the required reports and certifications. This section reads: SEC. 124. LIMITATION ON AVAILABILITYOF FUNDS FOR LITTORAL COMBAT SHIP (a) LIMITATION—None of the funds authorized to be appropriated by this Act or otherwise made available for fiscal year 2014 for construction or advanced procurement of materials for the Littoral Combat Ships designated as LCS 25 or LCS 26 may be obligated or expended until the Secretary of the Navy submits to the congressional defense committees each of the following: 1) The report required by subsection (b)(1). 2) A coordinated determination by the Director of Operational Test and Evaluation and the Under Secretary of Defense for Acquisition, Technology, and Logistics that successful completion of the test evaluation master plan for both seaframes and each mission module will demonstrate operational effectiveness and operational suitability. 3) A certification that the Joint Requirements Oversight Council— a) has reviewed the capabilities of the legacy systems that the Littoral Combat Ship is planned to replace and has compared such capabilities to the capabilities to be provided by the Littoral Combat Ship; b) has assessed the adequacy of the current capabilities development document for the Littoral Combat Ship to meet the requirements of the combatant commands and to address future threats as reflected in the latest assessment by the defense intelligence community; and c) has either validated the current capabilities development document or directed the Secretary to update the current capabilities development document based on the performance of the Littoral Combat Ship and mission modules to date. 4) A report on the expected performance of each seaframe variant and mission module against the current or updated capabilities development document. 5) Certification that a capability production document will be completed for each mission module before operational testing. (b) REPORT— (1) IN GENERAL—Not later than 60 days after the date of the enactment of this Act, the Chief of Naval Operations, in coordination with the Director of Operational Test and Evaluation, shall submit to the congressional defense committees a report on the current concept of operations and expected survivability attributes of each of the Littoral Combat Ship seaframes. (2) ELEMENTS—The report required by paragraph (1) shall set forth the following, a) A review of the current concept of operations of the Littoral Combat Ship and a comparison of such concept of operations with the original concept of operations of the Littoral Combat Ship. b) An assessment of the ability of the Littoral Combat Ship to carry out the core missions of the Cooperative Strategy for 21st Century Seapower of the Navy. c) A comparison of the combat capabilities for the three missions assigned to the Littoral Combat Ship seaframes (anti-surface warfare, mine countermeasures, and anti-submarine warfare) with the combat capabilities for each of such missions of the systems the Littoral Combat Ship is replacing. d) An assessment of expected survivability of the Littoral Combat Ship seaframes in the context of the planned employment of the Littoral Combat Ship as described in the concept of operations. e) The current status of operational testing for the seaframes and the mission modules of the Littoral Combat Ship. f) An updated test and evaluation master plan for the Littoral Combat Ship. g) A review of survivability testing, modeling, and simulation conducted to date on the two seaframes of the Littoral Combat Ship. h) An updated assessment of the endurance of the Littoral Combat Ship at sea with respect to maintenance, fuel use, and sustainment of crew and mission modules. i) An assessment of the adequacy of current ship manning plans for the Littoral Combat Ship and an assessment of the impact that increased manning has on design changes and the endurance of the Littoral Combat Ship. j) A list of the casualty reports to date on each Littoral Combat Ship, including a description of the impact of such casualties on the design or ability of that Littoral Combat Ship to perform assigned missions. (3) FORM—The report required by paragraph (1) shall be submitted in classified form and unclassified form.

Appendix IV: Comments from the Department of Defense

Appendix V: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, the following staff members made key contributions to this report: Diana Moldafsky (Assistant Director); Greg Campbell; Jenny Chow; Christopher R. Durbin; G. Oliver Elliott; Laura Greifner; Kristine Hassinger; Kenneth Patton; C. James Madar; Sabrina Streagle; Roxanna Sun; and Hai Tran.