Date: 2006-06-22
Speaker: DAVID M. WALKER (republican)
Chamber: S

Comptroller General of the United States. U.S. Government Accountability Office. Washington. DC. DEAR MR. WALKER: This is the Department of Defense (DoD) response to the GAO draft report. "Tactical Aircraft: DOD Should Present a New F22 Business Case Before Making Further Investments." dated May 8. 2006 (GAO Code 120474/GAO06455R). The Department does not agree with draft GAO reports recommendation to delay further investment in the F22. While the Department agrees with the GAOs emphasis on the importance of supporting our procurement decisions with appropriate "Business Case" analysis. we have performed such analysis to support F22 and tactical aircraft force structure decisions. and will continue to do so. Additional information and rationale for the Departments position is summarized below. Implementing the GAOs recommendation to delay investment in the F22 would disrupt production and create program instability. This Instability would be detrimental to our nations defense capabilities and our tactical aircraft industrial base. Over the past several procurement lots. the Air Force has been very successfully working with the prime contractor to drive down costs. Unit flyaway costs have come down 35% between Lot 1 and Lot 5. If stopped. production restart would be very costly and difficult to resume. breaking this positive trend. Likewise. there is considerable modernization work ongoing. To stop this work would result in large termination costs and would be very costly to resume. Multiple GAO reports have noted the negative impact that program instability has on program cost. schedule. and performance. The assumptions on which the GAOs recommendations are based were not understood. The quantity and mix of tactical aircraft to be procured by the Department has been and remains an area of significant "Business Case" analysis. As the geopolitical and fiscal environment changes. we continually reassess national security requirements and adjust our force structure as needed. Keeping the F22 production line active. preserves the Departments options and sustains the industrial base for efficient transition to Joint Strike fighter production. To suppott the Quadrennial Defense Review and preparation of the Presidents Fiscal Year 2007 Budget (PB07). the Department performed a Joint Air Dominance (JAD) Study. The JAD Study examined options for varying levels within the strike fighter mix. The Department looked at the war scenarios and cost implications of buying fewer variants of Joint Strike Fighters. increasing and decreasing the number of F22s. and buying more legacy aircraft at the expense of fewer fifth generation platforms. The results of these analyses are reflected in PB07. which sets forth a balanced portfolio of tactical aircraft assets. including Joint Strike Fighter. F22 and F/A18E/F. The draft GAO report makes note of. "the large disparity between what the Air Force wants for the F22A program and what OSD has committed to fund. there is a significant break in the business case to justify buying more F22As." The 381 aircraft the Air Force analysis indicates are required is a fiscally unconstrained projection of Service needs. The QDR analysis reflects fiscal realities and the need to address competing defense priorities. The JAD analysis showed that a balanced force structure mix of fifth generation fighters. with legacy F/A18E/Fs. F15Es and conventionally armed bombers. best met our requirements. Buying fifth generation tactical aircraft assets (F22 and JSF). for both the Air Force and the Department of the Navy. optimized capability. affordability. and mitigated risk better than other options. A detailed response is attached. Thank you for the opportunity to respond to this draft report.