Tina AmereihnDeputy Assistant Administrator for Information Services & CIOFederal Aviation Administration800 Independence Ave, SWRoom 602Washington, DC 20591
Dear Ms. Amereihn:
On behalf of the 362,000-member National Taxpayers Union (NTU), I write to encourage all possible deliberation over available alternatives to the Federal Aviation Administration (FAA) in its future information technology (IT) upgrade efforts. As a strong supporter of the Administration’s Federal Data Center Consolidation Initiative (FDCCI), NTU believes that taxpayers deserve highest consideration in this process.
Since its founding in 1969, NTU has taken an active role toward government procurement policy development in a plethora of environments and applications, from military projects such as the Common Vertical Lift Support Helicopter to civilian undertakings such as the U.S. Patent and Trademark Office’s build-to-lease scheme. Our work also translates to the state and local level, where currently NTU is urging officials to reexamine outdated municipal bidding procedures that tend to exclude new and cost-effective materials for water and sewer infrastructure.
Besides these areas, NTU is deeply involved in matters of government technology purchases. During the 1980s, for example, our members related to Congress and other officials many sad experiences with the Internal Revenue Service’s (IRS’s) patchwork of computers and their capacity for absurd tax-record errors. Our policy staff also weighed in on the shortcomings of many other federal IT projects, including the FBI’s Virtual Case File and the Defense Travel System.
In 1997, an NTU official served on an 18-member commission appointed by Congress and the President whose recommendations later became the basis for the landmark IRS Restructuring and Reform Act. Many of this commission’s findings centered upon the need for a technology modernization strategy, one whose tenets remain applicable today.
I cite this information to illustrate that, whether the issue involved hardware or software, NTU has encountered “common principles of success” for contracting. They are not especially original insights; in fact many have been articulated more eloquently from authorities such as the National Research Council, the Information Technology Association of America, and the Chief Information Officers Council. The most obvious guidelines are managerial in nature (such as oversight of vendors), directly affecting financial and schedule discipline. Others are more strategic:
- Allowing productivity and planning goals to drive infrastructure decisions (e.g., shedding outdated business practices before modernizing the actual systems serving them);
- Establishing a receptive environment to new developments that can yield large cost-efficiency gains;
- Avoiding overreliance on centrally-managed systems that require elaborate in-house support and supervision;
- Designing meaningful metrics to accurately track the cost savings and other windfalls from IT investments; and
- Creating a specification process that minimizes biased outcomes toward systems with features of marginal utility; and encourages where possible innovative yet robust, proven solutions that enjoy acceptance in the private sector. This includes RFPs that are “rightsized” to the mission at hand.
Given our ongoing participation in procurement policymaking, it is not remarkable that NTU and its members have intently observed federal agencies’ varied responses to the Administration’s Federal Data Center Consolidation Initiative.
Perhaps more noteworthy, however, are the varied potential benefits to taxpayers surrounding these responses. The General Services Administration has reported a 50 percent cost savings by moving employee email applications to a virtual network. The Department of Agriculture’s choice for “cloud” email service has cut per-account costs by 38 percent, to the equivalent of $96 annually, while the Department of the Interior recently unveiled a contract that is expected to hold employee email accounts to roughly $56 apiece each year.
Outcomes like these are occurring across a number of agencies, legacy systems, and contractors, leading us to note with concern the announcement of a contract for FAA and some other DoT employees that yields a per-account cost equivalent of nearly $163 per year. Granted, numerous details are involved in these contracts to which NTU is not privy. Nor do we profess some extraordinary degree of expertise in the technical minutiae of email applications. Nonetheless, our many years of experience with the fiscal side of procurement give us cause to raise several points:
1) How did FAA’s initial bidding process comport with the “principles of contracting success” described above, and some of the “best practices” identified in the report co-released by the Chief Information Officers’ Council? (See note 2.)
2) Was consideration given to the satisfaction with service reported by other agencies as they implemented their new email systems? IT change leaders in other agencies have identified unanticipated improvements to employee communication and collaboration from the new platforms, specifically in social media.
3) If security in the email system is of particular concern to FAA, have the results with other agencies, which have relayed high confidence in their virtual networks, been taken into account? With the Federal Risk and Authorization Management Program, security standards have been established for all qualifying vendors. If FAA has a special national security need for email users, need it apply the entire FAA workforce?
4) In the final analysis, is it possible to determine the reasons for the disparity in per-account costs in FAA’s email contract versus arrangements in other agencies? Are there specific capabilities that have contributed to the higher costs?
To reiterate, NTU’s interest in these matters is confined to ensuring that federal procurement practices deliver value not only for federal employees but also for taxpayers. Indeed, this communication is just one part of NTU’s ongoing activities on behalf of competitive procurement reform across all agencies and levels of government. It is in this spirit that we ask the preceding questions, to which we are hopeful you can provide some answers.
Late last year NTU partnered with the U.S. Public Interest Research Group to produce a report for Congress’s deficit reduction “Super Committee” that outlined more than $1 trillion in budget savings over 10 years. The project was intended to illustrate how citizen groups across the ideological spectrum could cooperate to identify opportunities to forge a more effective government. One key recommendation of the report was to implement federal IT management reforms:
Taking advantage of options such as virtual network-based computing technology while closing up to 800 of the 2,100 federal data centers nationwide, as proposed by the Obama Administration, would save taxpayers an estimated $160 billion over the coming decade.
If the responses of agencies to this initiative are to be models rather than outliers, they must balance many factors, including realistic needs assessments, a willingness to examine all options, diligent oversight, and the need to create a more sustainable government. For this reason, as well as the fact that we will be following FDCCI’s future progress throughout the federal government, I would appreciate any information that could improve our understanding of FAA’s decisions. I would also welcome any insights you could share about FAA’s IT plans going forward. NTU would be pleased to offer any assistance in this regard. Thank you for your consideration.
Sincerely,Pete SeppExecutive Vice President
 For further reference, please see “A Vision for a New IRS: Report of the National Commission on Restructuring the Internal Revenue Service,” June 25, 1997. See, especially, Appendix F, “Modernization Supplementary Information.” Available at http://www.house.gov/natcommirs/report1.pdf.
 Chief Information Officers Council, et al., “Creating Effective Cloud Computing Contracts for the Federal Government: Best Practices for Acquiring IT as a Service,” February 24, 2012, http://www.cio.gov/cloudbestpractices.pdf.
 Chief Information Officer for the U.S. Government, “Agencies Have Identified 78 Systems Migrating to the Cloud,” available at http://www.cio.gov/documents/IT_Reform_Agency_Cloud_Migrations_FINAL_%28w_DOD%29.pdf.
 U.S. Department of Agriculture, Chief Information Officer, “Enterprise Email in the Cloud: Consolidating 21 Email Systems into an Enterprise System Using Cloud Services,” March 8, 2011, http://www.cio.gov/documents/USDA_CloudEMail_Final.pdf.
 Calculated from Department of Interior News Release, May 1, 2012, http://www.doi.gov/news/pressreleases/Interior-Selects-Google-Apps-for-Government-for-Cloud-Email-and-Collaboration-Services.cfm; and, Maureen O’Gara, “Google Wins the Battle of the Interior Department,” Cloud Computing, May 7, 2012, http://cloudcomputing.sys-con.com/node/2270523.
 Calculated from Timothy R. Smith, “For FAA, It’s Not Just Planes in the Cloud,” Washington Post, June 7,2012, http://www.washingtonpost.com/blogs/federal-eye/post/for-faa-its-not-just-planes-in-the-cloud/2012/06/07/gJQAfQgeLV_blog.html; and, Computer Sciences Corporation News Release, June 7, 2012, http://www.csc.com/newsroom/press_releases/84802-csc_wins_91_million_contract_to_implement_cloud_services_for_the_faa.
 Timothy R. Smith, “As Federal Agencies Shift to Cloud Email, Officials Tout Savings, Security,” Washington Post, June 26, 2012, http://www.washingtonpost.com/politics/as-federal-agencies-shift-to-cloud-e-mail-officials-tout-savings-security/2012/06/26/gJQAsjQf5V_story.html.
 Andrew Moylan, Dan Smith, and Rich Williams, “Toward Common Ground: Bridging the Political Divide with Deficit Reduction Recommendations for the Super Committee,” National Taxpayers Union and U.S. Public Interest Research Group, September 2011; http://www.ntu.org/news-and-issues/budget-spending/uspirg_toward_common_ground.pdf.