Battlefield Automation: Requirements Need to Be Updated Before the Air Defense System Is Produced (Letter Report, 09/22/94, GAO/NSIAD-94-213). This report is based on GAO's follow-up review of the Army's efforts to acquire a $1.1-billion command, control, and intelligence (C2I) system as part of its forward area air defense system. This C2I system consists of a ground-based sensor to detect and track aircraft and computer hardware and software to process that information. Despite the Defense Department's direction, the Army has not redefined the C2I system requirements and may also award a $59-million low-rate initial production contract before it receives the results of operational testing. As a result, the Army could be committing to the procurement of an unproven system that may not be justified. --------------------------- Indexing Terms ----------------------------- REPORTNUM: NSIAD-94-213 TITLE: Battlefield Automation: Requirements Need to Be Updated Before the Air Defense System Is Produced DATE: 09/22/94 SUBJECT: Army procurement Command/control/communications systems Air defense systems Combat readiness Warning systems Testing Military systems analysis Communications equipment Defense communications operations Defense appropriations IDENTIFIER: Forward Area Air Defense System FAADS C2I Soviet Union Warsaw Pact Avenger Missile System Air Defense Antitank System Bradley Fighting Vehicle Fiber Optic Guided Missile Army Rapid Force Projection Initiative Stinger Missile ADATS ************************************************************************** * This file contains an ASCII representation of the text of a GAO * * report. 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We are unable to accept electronic orders * * for printed documents at this time. * ************************************************************************** Cover ================================================================ COVER Report to Congressional Committees September 1994 BATTLEFIELD AUTOMATION - REQUIREMENTS NEED TO BE UPDATED BEFORE THE AIR DEFENSE SYSTEM IS PRODUCED GAO/NSIAD-94-213 Battlefield Automation Abbreviations =============================================================== ABBREV COEA - cost and operational effectiveness analysis C2I - command, control, and intelligence DOD - Department of Defense FAAD - Forward Area Air Defense GBS - ground-based sensor LOSF - line-of-sight-forward LOSR - line-of-sight-radar LSDIS - Light and Special Division Interim Sensor NLOS - non-line-of-sight Letter =============================================================== LETTER B-242246 September 22, 1994 The Honorable Sam Nunn Chairman, Committee on Armed Services United States Senate The Honorable Daniel K. Inouye Chairman, Subcommittee on Defense Committee on Appropriations United States Senate The Honorable Ronald V. Dellums Chairman, Committee on Armed Services House of Representatives The Honorable John P. Murtha Chairman, Subcommittee on Defense Committee on Appropriations House of Representatives Because of continuing congressional interest about the cost, schedule, and performance problems of the forward area air defense (FAAD) system, we conducted a follow-up review focused on the Army's efforts to acquire a $1.1- billion command, control, and intelligence (C2I) system as part of its FAAD system. The FAAD C2I system consists of the ground-based sensor (GBS) to detect and track aircraft and the computer hardware and software to process that intelligence information. In our previous report,\1 we recommended that the Secretary of Defense direct the Army to defer the GBS' low-rate initial production until testing proved that it met performance requirements and a cost and operational effectiveness analysis (COEA) justified the GBS as the best alternative for meeting forward area air defense needs. The Department of Defense (DOD) concurred and directed the Army to take corrective actions. In addition, at the time of that review, the Army was reevaluating its forward area air defense needs in light of major changes in both the threat and the FAAD weapons it planned to procure. Responding to DOD concerns about program requirements, the Army said a Division Air Defense Study would address and revise those requirements, which are needed to form the basis for testing systems and supporting the COEA. -------------------- \1 Battlefield Automation: More Testing and Analysis Needed Before Production of Air Defense Radar (GAO/NSIAD-93-175, July 30, 1993). RESULTS IN BRIEF ------------------------------------------------------------ Letter :1 Despite DOD's direction, the Army has not redefined the FAAD C2I system requirements and may also award a $59- million low-rate initial production contract before it receives the results of operational testing. As a result, the Army could be committing to the procurement of an unproven system that may not be justified. BACKGROUND ------------------------------------------------------------ Letter :2 To protect soldiers and equipment at the front battle lines, the Army needs air defense capabilities to detect and react to attacks by hostile aircraft. The Army plans to provide this capability through the development, acquisition, and deployment of the FAAD C2I system. FAAD C2I, conceived in 1986 to counter the Warsaw Pact air threat includes the FAAD C2I system and several air defense weapon systems. The Army has spent $516 million developing and producing the FAAD C2I system and plans to spend another $586 million to complete development and production.\2 -------------------- \2 The acquisition of the FAAD C2I system is broken into four blocks. The $516 million and $586 million are the development and production costs for Blocks I and II. The Army does not have a firm estimate for either Block III, the objective system, or Block IV, a preplanned improvement effort. ARMY NEEDS TO UPDATE REQUIREMENTS ------------------------------------------------------------ Letter :3 The massive Warsaw Pact air threat the FAAD C2I system was designed to counter has changed to smaller, less capable regional threats. In addition, the weapon systems intended to work with the FAAD C2I system have changed or been eliminated. Nevertheless, the Army has not updated the system's requirements. While it did update requirements for the forward area weapon systems, the Army plans to rely on a COEA to update requirements for the C2I systems. However, the purpose of a COEA is to evaluate alternatives to meet recognized defense needs, not to establish system requirements. THREAT AND WEAPON SYSTEMS HAVE CHANGED DRAMATICALLY ---------------------------------------------------------- Letter :3.1 FAAD C2I system requirements most likely will change due to dramatic differences in the threat it was intended to counter and the weapons it was intended to work with. With the dissolution of the Soviet Union and breakup of the Warsaw Pact, the Defense Intelligence Agency and the Army now believe the primary threat comes from various regional hotbeds of conflict, such as Iraq or North Korea, which do not have the air power of the former Soviet Union. Also, the FAAD C2I system was originally designed to counter the numerous fixed-wing aircraft of the Warsaw Pact that constituted the Cold War threat. The Army's latest post-Cold War air defense strategy for the forward area envisions Air Force fighter aircraft countering the fast-moving fixed-wing threat, while the Army defends against slow-moving helicopters and unmanned aerial vehicles. The diminished numbers and different types of aircraft the FAAD C2I system is expected to counter raise questions about FAAD C2I system requirements, such as the number of aircraft a sensor must be able to track at one time or the range required to detect the aircraft. Figure 1 shows the change in the threat. Figure 1: Change in Forward Area Air Defense Threat (See figure in printed edition.) The weapon systems intended to work with the FAAD C2I system also have changed. To date, the Army has fielded only one of the three original planned weapons, the line-of-sight-rear (LOSR), the Avenger. This weapon was designed to use GBS data to protect rear assets primarily from attacks by fixed-wing aircraft. However, funds for the Avenger were cut in the fiscal year 1995 budget planning efforts, and the Army does not plan to buy additional Avengers after fiscal year 1995. Thus, the Army will possess only limited quantities of this weapon system. The other two original weapons, the non-line-of-sight (NLOS) and line-of-sight-forward (LOSF), were canceled because of cost concerns and development problems. The Army has not developed a replacement for NLOS,\3 the fiber-optic guided missile, which was intended to counter pop-up helicopters. And instead of LOSF, the Air Defense Antitank System, the Army has fielded the Bradley Stinger Fighting Vehicle carrying teams of soldiers with shoulder-fired Stinger missiles. These are in addition to teams of foot soldiers equipped with binoculars and shoulder-fired Stinger missiles that have always been part of FAAD. Figure 2 shows how the original weapon systems concept has changed. Figure 2: FAAD Weapon Systems Have Changed (See figure in printed edition.) These drastic changes raise serious concerns about whether the FAAD C2I system requirements should remain unchanged. Therefore, it may be premature to commit to the planned development of sophisticated software. -------------------- \3 The Army is developing an Enhanced Fiber Optic Guided Missile system as a part of its Rapid Force Projection Initiative. This system addresses a requirement similar to NLOS. It plans to demonstrate the missile system in an Advanced Concept Technology Demonstration scheduled for 1997, and production may or may not be an outcome of that demonstration, according to the Rapid Force Projection Initiative Program Manager. The Army does not currently have plans to buy more of the systems than those acquired for the demonstration. ARMY HAS NOT UPDATED THE FAAD C2I SYSTEM REQUIREMENTS ---------------------------------------------------------- Letter :3.2 The Army has not responded to changes in the threat or weapon systems by updating the FAAD C2I system requirements. During our prior review of the GBS, Army air defense school officials told us they planned to reexamine the entire FAAD C2I system concept and recommend solutions in a Division Air Defense Study. However, the study, conducted in 1993, focused on FAAD weapon system capabilities and did not update the FAAD C2I system requirements. According to the Division Air Defense Study Director, the Army did not assess the FAAD C2I system requirements in the study because of time and resource constraints. The study director and the FAAD C2I system project manager stated they were relying on an upcoming FAAD C2I system COEA to assess requirements. However, according to DOD Instruction 5000.2, the purpose of a COEA is not to establish or reassess requirements, but to identify the advantages and disadvantages of alternatives being considered to meet recognized defense needs. A requirements study, on the other hand, would allow the Army to reassess the FAAD C2I system requirements in view of threat and weapon system changes. DOD Instruction 5000.2 mandates updates to system requirements at key decision points during development and acquisition. One major reason for documenting requirements is to avoid premature commitment to a system-specific solution. ARMY WAS NOT FOLLOWING DOD PROCUREMENT GUIDANCE ------------------------------------------------------------ Letter :4 In the past, the Army has not always followed DOD guidance for procuring systems, and there is some doubt it will adhere to that guidance with the FAAD C2I system. In 1993, we reported that the Army was developing and planned to procure the GBS without a COEA to determine its suitability and without completing operational testing. In response to that report, DOD said it expected the Army to complete a COEA by December 1994. DOD also delayed funding initial production of the GBS for 1 year to allow time to complete initial operational testing of the integrated system. At the time we began this review, the Army still planned to award a low-rate production contract before either the COEA or testing were completed. In April 1994, during this review, the GBS product office decided to delay awarding a $59-million low-rate production contract from November 1994 to January 1995, just a few months prior to the full-scale production decision planned for April 1995. The award would be based on a December 1994 low-rate initial production decision to comply with DOD direction. A COEA and operational testing are expected to be completed in December 1994. However, it is still uncertain that the COEA and operational testing will remain on schedule. The COEA study plan, for example, was supposed to be approved by the Army's Study Advisory Group by January 1994, but as of June 1994, the Army had received only limited approval of the plan. Similarly, in the past the schedule for operational testing has slipped. The Army does not have a COEA to support acquisition of the GBS, although one is required at acquisition milestones. The Army began a COEA for the GBS in April 1990, but suspended it in March 1992 because of changes in the threat and weapon systems. A Directorate of Combat Developments, Army Air Defense Artillery School, representative stated that a COEA for the GBS was not feasible until future air defense needs are defined. The Army expected air defense needs would be updated in the Division Air Defense Study. However, as stated above, that did not happen. ARMY CONTINUES TO ACQUIRE SYSTEM DESPITE CHANGES ------------------------------------------------------------ Letter :5 Regardless of the diminished threat and changes to the weapon systems, the Army is fielding Block I, an interim configuration of the FAAD C2I system, to light and special divisions. The full-scale production decision is planned for April 1995 for the GBS and Block II of the FAAD C2I system. Block I includes the computer hardware and basic software to interface with an interim sensor to detect aircraft and transmit air track data via an interim radio system. In September 1993, the 101st Airborne Division (Air Assault), Fort Campbell, Kentucky, accepted the first Block I system. The Army plans to field additional Block I systems to the 10th Mountain and 2nd Infantry Divisions in fiscal year 1995 and to the 82nd Airborne Division in fiscal year 1996, according to program officials. Block II, another interim system, is to build on the basic capabilities in Block I, with the primary enhancements being improved software and the GBS instead of the interim sensor. The Army considers Block III to be the objective FAAD C2I system with sophisticated software and aircraft identification capabilities. Block IV is a preplanned product improvement to further enhance communications and air battle management. The Army has not established firm cost estimates or timetables for Blocks III and IV. RECOMMENDATION ------------------------------------------------------------ Letter :6 Given the uncertainties that continue to surround the FAAD C2I system acquisition, there is the potential for the Army to commit to an unproven system that may not be justified. Therefore, we recommend that the Secretary of Defense direct the Secretary of the Army to defer any production and initial operational testing until the Army (1) updates the requirements for both the GBS and FAAD C2I system and (2) selects the best solution, based on a COEA, for satisfying the updated requirements. In addition, the Secretary of Defense should direct the Secretary of the Army to cancel the planned low-rate production decision because the full-scale production decision is only a few months later and the Army's reason (training) for initiating low-rate production is inconsistent with the purposes specified in 10 U.S.C. 2400 for initiating low-rate initial production. This would allow more time to evaluate test results before committing to production. AGENCY COMMENTS AND OUR EVALUATION ------------------------------------------------------------ Letter :7 While DOD agreed with much of the information in our report, it did not agree with our recommendations. DOD considers that the Army has validated the requirements for the FAAD C2I system against the current threat and changes in the air defense weapon systems. It, therefore, nonconcurred with our recommendation that the Army be required to defer low-rate initial production and initial operational testing until it has (1) updated the requirements for both the GBS and FAAD C2I system and (2) selected the best solution, based on a COEA, for satisfying those updated requirements. DOD also noted that the GBS is currently scheduled to undergo initial operational testing in conjunction with the FAAD C2I system prior to the full-scale production decision for both systems. On this basis, DOD nonconcurred with our recommendation that the Army be required to complete initial operational testing of the selected system prior to low-rate production. DOD stated that the Army revalidated the original FAAD C2I system Block I and Block II (with the GBS) requirements with a "War Fighting Lens Analysis," which is an internal Army array of weapon systems needs and available funding. In response to DOD's comments, we examined the Army's "War Fighting Lens Analysis" and discussed it with Army and DOD officials. We found that while the "War Fighting Lens Analysis" did revalidate the need for FAAD, it did not revalidate or update the specific FAAD C2I system requirements. DOD also stated that the Division Air Defense Study validated the need for a FAAD command and control system to support FAAD requirements in the new post-Cold War environment. It noted, however, that the specific requirements for the system must be further defined. Therefore, while demonstrating a continued need for FAAD, the study did not address the specific requirements for the FAAD C2I system given the post-Cold War environment. DOD also stated that it believes that the COEA for the FAAD C2I system will provide an analytical basis for updated requirements, at least for Block II for the heavy division. This position clearly demonstrates that the FAAD C2I system requirements may have changed from the original requirements because of changes in the threat and weapon systems. It also implies there is no current analytical basis or at least an adequate analytical basis for the current FAAD C2I system requirements. We believe this indicates that the Army and DOD have decided to maintain the status quo rather than reanalyze and update the definitive requirements that a post-Cold War air defense system should satisfy. Further, it seems inconceivable that the original requirements, set in 1986 for a Cold War threat, have not changed in some way because of (1) the current very different and diminished threat and (2) the more limited set of weapon systems the FAAD C2I system and GBS will work with. But even when this issue is realistically addressed, another issue remains and that is whether DOD and the Army can afford the system given (1) reduced funding for DOD and the services, (2) serious underfunding of DOD's own future years defense program, and (3) a less costly sensor, the Light and Special Division Interim Sensor, already in the field. Also, relying on a COEA that does not use analytically based, definitive requirements could result in the Army prematurely committing to a system-specific solution, which is contrary to DOD acquisition guidance. Given these facts, we continue to believe that the Army has not adequately updated the requirements for the FAAD C2I system and the GBS to reflect changes in the threat and weapon systems to be fielded. We, therefore, believe that our recommendation on the deferral of initial operational testing and production until updated requirements are completed should still be implemented. DOD stated that it wanted to initiate low-rate production to procure limited numbers of the GBS to support training needs. However, providing for training needs is not one of the three purposes specified in 10 U.S.C. 2400 for initiating low-rate initial production. These purposes are (1) to provide production configured or representative articles for operational test and evaluation, (2) establish an initial production base for the system, and (3) permit an orderly increase in the production rate for the system sufficient to lead to full-rate production upon the successful completion of operational test and evaluation. However, the GBS low-rate initial production decision would not appear to be required for any of these reasons because the Army already has representative items for test, and the system is composed of nondevelopmental items already in production. Therefore, low-rate production for testing articles, an initial production base, or ramping up would not appear to be needed. DOD also noted that the full-scale production decision for the systems is now scheduled for April 1995, just 4 months after the December 1994 low-rate production decision. Given this change in schedule and the rationale for low-rate production, we have changed our recommendation to include eliminating the low-rate production decision from the Army's acquisition plan. DOD's comments and our responses are in appendix I. SCOPE AND METHODOLOGY ------------------------------------------------------------ Letter :8 To determine whether the Army has updated the FAAD C2I system requirements for the post-Cold War era, we reviewed DOD and Army documents, including the Air Capabilities Study and the Division Air Defense Study, which redefined the air threat to the forward area and the concept for air defense in the post-Cold War era. Also, we were briefed by the Defense Intelligence Agency on the post-Cold War threat to the forward area of the battlefield. In addition, we examined Army plans for an upcoming FAAD C2I COEA and reviewed DOD and Army acquisition policy and guidance for system requirements and COEAs. Because the FAAD C2I system is dependent upon integration with the FAAD weapon systems, we also monitored the progress and problems of programs, such as the Avenger and the Bradley Stinger Fighting Vehicle weapon systems. We obtained information and held discussions with officials in the following organizations in Huntsville, Alabama: Air Defense Command and Control Systems Project Office; FAADS Sensors Product Office; FAADS Project Office; Intelligence and Security Directorate, U.S. Army Missile Command; and Research, Development, and Engineering Center, U.S. Army Missile Command. We also obtained information and held discussions with officials at the Defense Intelligence Agency, Washington, D.C.; U.S. Army Air Defense Artillery School, Fort Bliss, Texas; Headquarters, Department of Defense, Arlington, Virginia; Headquarters, Department of the Army, Arlington, Virginia; 101st Airborne (Air Assault) Division, Fort Campbell, Kentucky; and U.S. Army Training and Doctrine Command, Fort Monroe, Virginia. We performed our review from July 1993 through August 1994 in accordance with generally accepted government auditing standards. ---------------------------------------------------------- Letter :8.1 We are sending copies of this report to the Director, Office of Management and Budget; the Secretaries of Defense and the Army; and other interested parties. We will make copies available to others upon request. Please contact me at (202) 512-4841 if you or your staff have any questions concerning this report. Major contributors to this report are listed in appendix II. Louis J. Rodrigues Director, Systems Development and Production Issues (See figure in printed edition.)Appendix I COMMENTS FROM THE DEPARTMENT OF DEFENSE ============================================================== Letter (See figure in printed edition.) See comment 7. (See figure in printed edition.) (See figure in printed edition.) (See figure in printed edition.) (See figure in printed edition.) (See figure in printed edition.) (See figure in printed edition.) (See figure in printed edition.) (See figure in printed edition.) (See figure in printed edition.) See comment 2. (See figure in printed edition.) (See figure in printed edition.) The following are GAO's comments on the Department of Defense's (DOD) letter dated August 18, 1994. GAO COMMENTS ------------------------------------------------------------ Letter :9 1. Our concern is that the requirements for the forward area air defense (FAAD) command, control, and intelligence (C2I) system, including the ground-based sensor (GBS), have not been updated. As stated in our report, the Army planned such a requirements update in the Division Air Defense Study. However, the study did not specifically address FAAD C2I; it focused on the weapon system capabilities. In response to DOD's comments, we examined the Army's "War Fighting Lens Analysis" and discussed it with Army and DOD officials. We found that while the "War Fighting Lens Analysis" did revalidate the need for FAAD, it did not revalidate or update the specific FAAD C2I system requirements. Also, the upgrade of the Required Operational Capability into an Operational Requirements Document is essentially a format conversion and does not update requirements. The fact that the requirements outlined in the original requirements document were not changed is discussed in DOD's response to Finding C. Further, in a January 4, 1993, memorandum, DOD told the Army that it was concerned about requirements. For example, DOD stated, "The demise of the Warsaw Pact may have a significant impact on the performance needed in a FAAD C2I system . . . . However, the requirements have not yet been updated." The appropriate time to update the requirements would have been during the Division Air Defense Study. But, as mentioned in our report, this was not done. 2. We agree that a good cost and operational effectiveness analysis (COEA) can be used to show the value that good target detection/communications provide to the FAAD C2I system. However, as stated in our report, the purpose of a COEA is to evaluate alternatives to meet established requirements, which DOD Instruction 5000.2 requires to be updated at key decision points during development and acquisition. DOD Instruction 5000.2 further states that one of the major intents for documenting requirements is to avoid premature commitment to a system-specific solution. We recognize that the COEA guidance provided by DOD provides for analysis of alternatives. However, these alternatives are different variations of using the GBS and the Light and Special Division Interim Sensor (LSDIS). Our point is that the Army needs to develop and update an analytically based list of definitive requirements that a post-Cold War air defense system should have. Relying on a COEA without updated requirements could result in the Army prematurely committing to a system-specific solution. 3. As discussed above, the Army has not updated FAAD C2I system requirements. However, it seems inconceivable that the original requirements, set in 1986 for a Cold War threat, would not have changed in some way because of (1) the current very different and diminished threat and (2) the more limited set of weapon systems the FAAD C2I system will work with. Even so, DOD was not able to provide us with an analysis supporting its position that the requirements remain the same. Also, as previously mentioned, this was not done in the Division Air Defense Study. We agree that the threat has changed, and the change should have influenced sensor requirements. We would have expected the Division Air Defense Study to have considered these changes and their influence on FAAD C2I system requirements in an analytical framework. However, this was not done. DOD's comment that the GBS is the system being developed to meet these requirements is specifically what DOD guidance is seeking to prohibit when it states that the services should document requirements to avoid premature commitment to a system-specific solution. 4. DOD's comment again assumes the GBS is the solution without an analytical basis. For example, if the Avenger is now required to be more maneuverable, analysis might reveal that a more maneuverable, less sophisticated air defense system meets current requirements. Planned enhancements to the Bradley Stinger Fighting Vehicle are currently unfunded. 5. We recognize that the Army has already invested in and developed software for the FAAD C2I system; these are sunk costs and efforts. However, a COEA performed using properly updated system requirements may identify more cost-effective alternatives than the currently selected FAAD C2I system. Additionally, DOD's comment about the unacceptable alternative of going back to binoculars and voice radio for air defense implies that there are only two possible outcomes to the COEA process and completely disregards the existence of the LSDIS and other available sensors. 6. We disagree that the Division Air Defense Study "fully considered and found essential" the Block I and II requirements and resulting capabilities. However, the study, conducted in 1993, focused on FAAD weapon systems capabilities and did not update the FAAD C2I system requirements. According to the Division Air Defense Study Director, the Army did not assess the FAAD C2I system requirements in the study because of time and resource constraints. The study director and FAAD C2I system project manager stated they were relying on an upcoming FAAD C2I COEA to assess requirements. However, according to DOD Instruction 5000.2, the purpose of a COEA is not to establish or reassess requirements, but to identify the advantages and disadvantages of alternatives being considered to meet recognized defense needs. In all analyses, the study assumed the existence of the objective FAAD C2I system. Perhaps this was good enough to establish the need for some sort of automated command and control system, but, in our opinion, it was not sufficient for drawing conclusions regarding specific requirements for that system. 7. DOD's position that ". . . the [Division Air Defense] study director did not concentrate on validating requirements for the Forward Area Air Defense Command and Control System as, in fact, it was planned to do this during the DOD directed cost and operational effectiveness analysis," contradicts DOD's position in its response to Finding B that the purpose of a COEA is not to establish system requirements. DOD asserts that FAAD C2I system requirements have been updated. DOD, on the other hand, states that the COEA, ". . . will provide an analytical basis for updated requirements . . ." (see p. 17, para. 2), implying that requirements have not been updated. 8. As an indication that DOD has not managed the program as effectively as possible, we noted that a January 4, 1993, memorandum from the DOD to the Army stated that the influence of a reduction in the threat and FAAD C2I requirements needed to be studied. However, this was not done. As a second example, in an October 13, 1993, letter from DOD to GAO, DOD said that it would defer the initial production decision for the GBS to allow time for sufficient test and evaluation of the integrated system. However, the Army is now planning to make a low-rate initial production decision before the results from the integrated tests are completed and evaluated. Also, DOD's assertion that the Army is managing the program in accordance with DOD guidance is contradicted by the fact that the Army is planning for low-rate production for a reason clearly not within the purposes given for initiating low-rate production in 10 U.S.C. 2400. Additionally, the COEA, the initial operational test and evaluation, and the Defense Acquisition Board meeting have all slipped, lending credence to our concerns about the uncertainty that future efforts will remain on schedule. 9. We did recognize the initial fielding of a Block I system. Our point is that the Army continues to acquire a system without definitizing requirements. Also, the DOD contradicted itself by asserting that the schedule for a full-scale production decision-- the milestone III decision--in April 1995 provides time for the Army to "update requirements." This indicates that requirements have not yet been updated. We agree that a requirements update, along with the COEA, should be accomplished prior to the full-scale production decision. 10. We continue to believe that the Army needs to establish definitive requirements for the FAAD C2I system, including the GBS, before proceeding with acquisition. We believe, and we have stated in the report and in comments above, that a systematic analysis of requirements is essential to the acquisition of this system. 11. We have changed our report and recommendation to reflect DOD's comments that the low-rate initial production decision is now scheduled for December 1, 1994, and a full-scale production decision is scheduled for April 1995. Given these changes and potential problems with meeting the revised milestones, we have changed our recommendation to state that the low-rate initial production decision should be deleted entirely, and DOD and the Army should wait for the full-scale production decision, a delay of a few months. DOD stated that it wanted to begin low-rate initial production to procure limited numbers of the GBS to support training needs. However, providing for training needs is not one of the three purposes specified in 10 U.S.C. 2400 for initiating low-rate initial production. The three purposes are (1) to provide production configured or representative articles for operational test and evaluation, (2) establish an initial production base for the system, and (3) permit an orderly increase in the production rate for the system sufficient to lead to full-rate production upon the successful completion of operational test and evaluation. The GBS low-rate initial production decision will not meet any of these criteria because the Army already has representative items for test. Also, the system is composed of nondevelopmental items already in production. Therefore, deleting low-rate initial production will not hurt development of the system. Also, the Army does have the LSDIS and other sensors. MAJOR CONTRIBUTORS TO THIS REPORT ========================================================== Appendix II NATIONAL SECURITY AND INTERNATIONAL AFFAIRS DIVISION, WASHINGTON, D.C. -------------------------------------------------------- Appendix II:1 Bruce H. Thomas NEW YORK REGIONAL OFFICE -------------------------------------------------------- Appendix II:2 William L. Wright ATLANTA REGIONAL OFFICE -------------------------------------------------------- Appendix II:3 Allan C. Richardson Erin B. Baker Pamela A. Scott