Regarding the Air Force’s Common Vertical Lift Support Program (CVLSP).
The Honorable Daniel Inouye,
Chairman
The Honorable Thad Cochran,
Ranking Member
Subcommittee on Defense,
Committee on Appropriations
United States Senate
Room S128, The Capitol
Washington, DC 20510
Dear Chairman Inouye, Ranking
Member Cochran, and Members of the Committee:
In coming weeks, Members of Congress will confront many
urgent matters, including deliberations of the Joint Select Committee on
Deficit Reduction and unresolved appropriations for the upcoming fiscal year.
As you and your colleagues assume a key role in these issues, the
362,000-member National Taxpayers Union (NTU) urges you to maximize every possible
opportunity for exercising prudent oversight in systems procurement. One such
opportunity we wish to bring to the Committee’s attention relates to the Air
Force’s Common Vertical Lift Support Program (CVLSP).
As you may know, since its founding in 1969 NTU and its
members have been involved in a plethora of discussions over defense purchasing
policies, including in recent times the KC-45A program, the F-35 alternate
engine, and the Medium Extended Air Defense System. In all of these cases, our
sole motivation has been to advocate on behalf of obtaining the best
possible value to servicepeople and taxpayers. NTU believes that a vigorous CVLSP
competition among multiple bidders, under realistically defined mission
requirements, will deliver this value.
CVLSP was originally conceived to replace UH-1N aircraft,
which are now performing non-combat tasks primarily within the continental
United States. Their duties include security at Air Force missile fields and
transport of priority personnel. Given such parameters, we were surprised to
learn of reports this spring that the service was considering invoking the
Economy Act to conduct single-source procurement. The system purchased under
this arrangement would be a variant of the UH-60 platform, thousands of which
are currently in U.S. and international service. However, after four decades of
engaging in military funding issues, often involving NTU staff members with
previous experience in the procurement field, we believe that applying the
Economy Act to CVLSP is neither justifiable nor proper.
For one, although the need for CVLSP has been described
as urgent, numerous alternatives are available for near-term modification and
purchase. Several firms, including Bell (with the UH-1Y), EADS North America
(Eurocopter) and AgustaWestland, offer robust aircraft that have been proven in
a variety of commercial, military, and security missions under challenging
conditions. Their features – including range, power-to-weight ratio,
environmental footprint, flight handling, defensive systems, and all-weather
performance – deserve a formal comparative evaluation, if for no other reason
than to more precisely focus the ongoing deliberations on how to deliver the
most capable system to the Air Force.
In
addition, there are serious concerns that exercising the Economy Act could
deprive taxpayers of considerable savings (by one firm’s estimate, $2.75
billion or more over the life of the contract). Not surprisingly, each company
(including Sikorsky, which would manufacture the sole-source option), claims
that its system provides significant dividends for taxpayers. Yet, it is
precisely the “discovery process” afforded by competitive bidding that will
allow these contentions to be systematically tested. One area of concern, for
example, centers around the Maintenance, Repair, and Overhaul (MRO) costs
associated with CVLSP. As Dr. Daniel Goure of the Lexington Institute wrote
earlier this year:
Aircraft
are complex systems that are difficult and relatively expensive to maintain.
Anything that reduces the costs of MRO is important. Yet, the Air Force only
competes a small fraction of its MRO work, particularly in the area of parts,
subsystems, and assemblies. Moreover, experience shows that major savings can
be achieved when parts
can be repaired rather than replaced with new ones. The Air Force needs to rethink
its approach to contracting as well as its MRO practices.
Proponents
of selecting the UH-60 for CVLSP through sole-sourcing might argue that MRO
costs would be lower under this
alternative than others, owing to the familiarity of Air Force technicians with
the airframe and the existence of a longstanding supply chain for the platform.
Yet, this is not necessarily the case. For instance, other bidders may have a
great deal of institutional expertise in providing safe repair procedures for
parts, as well as maintenance protocols for commercial clients that are more
cost-efficient while still meeting strict government certification
requirements. These are not mere academic concerns, as a report last year on
“common ground” deficit reduction ideas co-authored by NTU and the U.S. Public Interest
Research Group made clear. The study noted:
Given
the hundreds of billions of dollars that flow through the contracting process,
it is unsurprising that vast improvements can be made to their efficiency.
First, we recommend ending orders for obsolete parts and supplies in the Army,
Navy, Air Force, and Defense Logistics Agency. According to the Government
Accountability Office, these agencies waste billions purchasing items that go
unused or were never required in the first place. In some cases, the agencies
purchase 50 percent more parts than necessary. Streamlining this process would
save more than $184 billion over five years without materially impacting
national security.
Moreover, other life-cycle cost considerations may not
favor the sole-sourcing route. At least one model that could be considered
under CVLSP might require just one aircrew member in the cockpit – which could
be of significant benefit in keeping training and personnel costs manageable. Also,
owing to its size the UH-60 could need larger hangar space compared to several
of the other CVLSP options, which could be billeted in existing UH-1N
facilities. These military construction costs must likewise be accounted for in
any fair analysis. By far the best way to ensure such an investigation takes
place is through an open bidding process.
Finally,
NTU believes that CVLSP could help to strengthen the case for more competitive
procurement policies across systems as well as services. One persistent problem
NTU has encountered among defense expenditures is “mission creep by design,”
whereby an initial requirement is retooled through the input of numerous
parties to become fulfillable only through a limited number of platforms
(sometimes just one). This can stifle creative solutions – among them
adaptations of off-the-shelf commercial designs – that could answer to the
services’ purposes more nimbly and cost-effectively. Competitively bidding
CVLSP, guided by an RFP that is “rightsized” to the mission rather than a
preconceived system, could prompt desperately-needed reforms to the way the
military purchases its needs.
In
March, General Shackelford told the Tactical Air and Land Forces Subcommittee
of the House Armed Services Committee that he expected the Air Force “will go
towards a competitive strategy” for CVLSP. This was an extremely encouraging
development, followed by some others in the months leading up to today. You can
help to ensure that a competitive strategy does indeed take hold for this and
other programs as you craft requirements in appropriations legislation and as
you advise your colleagues on other panels.
In
the current fiscal environment, it is more imperative than ever before to heed
the advice from Joint Chiefs Chairman Admiral Mullen and “steward every dollar
that we have.” CVLSP presents an ideal occasion to do so, and NTU stands ready
to assist you in reaching this goal.
Sincerely,
Pete Sepp
Executive Vice President