oversight

Coast Guard: Mission Performance Challenged by the Declining Condition and Rising Costs of its Legacy Vessel Fleet

Published by the Government Accountability Office on 2012-09-20.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                            United States Government Accountability Office

GAO                         Testimony
                            Before the Subcommittee on Coast Guard
                            and Maritime Transportation, Committee
                            on Transportation and Infrastructure,
                            House of Representatives
                            COAST GUARD
For Release on Delivery
Expected at 2:00 p.m. EST
September 20, 2012



                            Mission Performance
                            Challenged by the
                            Declining Condition and
                            Rising Costs of its Legacy
                            Vessel Fleet
                            Statement of Stephen L. Caldwell, Director
                            Homeland Security and Justice Issues




GAO-12-934T
Chairman LoBiondo, Ranking Member Larsen, and Members of the
Subcommittee:

Thank you for the opportunity to discuss the condition of the Coast
Guard’s legacy vessel fleet, and challenges the Coast Guard faces in
sustaining these vessels and meeting mission requirements. The Coast
Guard, within the Department of Homeland Security, is the principal
federal agency responsible for maritime safety, security, and
environmental stewardship. The legacy vessel fleet is critical for
executing Coast Guard missions, which include defense operations;
search and rescue; and securing ports, waterways, and coastal areas. My
comments will focus on the legacy 378-foot high endurance cutters, 270-
foot and 210-foot medium endurance cutters, and 110-foot patrol boats,
and are based on findings from the report we released in July 2012. 1

The legacy high endurance cutters, medium endurance cutters, and
patrol boats are either approaching the end of or are past their originally-
expected service lives, with a number of these vessels having entered
into service in the 1960s and 1970s. Coast Guard officials report that
these legacy vessels have become increasingly costly to maintain and
their degraded condition has negatively affected the Coast Guard’s
operational capacity to meet mission requirements. The Coast Guard is in
the midst of a long-term recapitalization plan that could cost as much as
$29 billion to replace legacy vessels, aircraft, and other related systems. 2
However, since beginning the acquisition program in 1996, the Coast
Guard has experienced cost, management, and oversight problems that
have led to considerable delays in the delivery of new vessels—by as
much as 13 years. In turn, delays in delivery of the replacement vessels
have created uncertainties regarding how the Coast Guard will sustain its
legacy vessels and meet mission requirements.


1
  Our published report provides additional details on the sizes and capabilities of each of
these vessels. See GAO, Coast Guard: Legacy Vessels’ Declining Conditions Reinforce
Need for More Realistic Performance Targets, GAO-12-741 (Washington, D.C.: July 31,
2012).
2
  The Coast Guard’s asset recapitalization plan includes projects to build or modernize
five classes each of vessels and aircraft and undertake procurement of other capabilities,
such as improved command, control, communications, computers, intelligence,
surveillance, and reconnaissance. This report focuses only on the legacy vessel fleet. For
more information on the recapitalization effort as a whole, see GAO, Coast Guard: Action
Needed As Approved Deepwater Program Remains Unachievable. GAO-11-743
(Washington, D.C.: July 28, 2011).




Page 1                                                                          GAO-12-934T
My testimony today summarizes the findings of our July 2012 report and
addresses (1) how the physical condition of the Coast Guard’s legacy
vessel fleet changed from fiscal years 2005 through 2011, and key
actions the Coast Guard has taken related to the physical condition of its
legacy fleet; (2) key annual maintenance expenditure trends for the
legacy vessel fleet, and the extent to which the Coast Guard’s cost
estimating process has followed established best practices; and (3) the
operational capacity of the legacy vessel fleet and the extent to which the
Coast Guard faces challenges in sustaining the legacy vessel fleet and
meeting mission requirements.

For our report, we analyzed Coast Guard data from fiscal years 2005
through 2011 on the legacy vessels’ condition, cost, and operational
performance. We interviewed relevant Coast Guard headquarters officials
and conducted site visits to five Coast Guard field locations where legacy
vessels were based or undergoing maintenance. We also compared the
documentation that the Coast Guard uses to compute its annual legacy
vessel maintenance cost estimates against established best practices. 3
We reviewed Coast Guard documents and other evidence that outlined
challenges the Coast Guard faces in sustaining its legacy vessels and
meeting mission requirements given delays in deploying replacement
vessels. Further, we evaluated the Coast Guard’s actions against Office
of Management and Budget guidance. 4 We conducted this work in
accordance with generally accepted government auditing standards. Our
July 2012 report provides further details on our scope and methodology. 5




3
  GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and
Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: Mar. 2, 2009).
4
  Office of Management and Budget, Program Assessment Rating Tool Guidance Number
2007-2, (Washington, D.C.: Jan. 29, 2007).
5
    GAO-12-741.




Page 2                                                                 GAO-12-934T
                        From fiscal years 2005 through 2011, the physical condition of the Coast
Legacy Vessel Fleet’s   Guard’s legacy vessels was generally poor. A primary Coast Guard
Condition Is Poor and   measure of a vessel’s condition—the operational percent of time free of
                        major casualties—shows that the high endurance cutters, medium
Generally Declining     endurance cutters, and patrol boats generally remained well below target
Despite Coast Guard     levels from fiscal years 2005 through 2011. 6 For example, over this 7-
Maintenance Efforts     year period, the operational percent of time free of major casualties
                        averaged about 44 percent for the high endurance cutters and about 65
                        percent for the medium endurance cutters versus a target of 72 percent;
                        and the patrol boats averaged approximately 74 percent versus a target
                        of 86 percent. Other evidence, such as our review of vessel condition
                        assessments and inspections the Coast Guard conducts of the legacy
                        vessels, also shows that the condition of the legacy vessel fleet is
                        generally declining. For example, a variety of Coast Guard assessments
                        show that legacy vessels’ critical operating systems—such as main diesel
                        engines—have been increasingly prone to mission-degrading casualties.
                        In addition, Coast Guard senior maintenance officials and vessel crew
                        members we interviewed noted increased maintenance challenges
                        because of the advanced age of the legacy vessels. In particular, the
                        maintenance managers for both the high endurance and medium
                        endurance cutters reported that the performance of critical systems on
                        these legacy vessel classes has become increasingly unpredictable and
                        refurbishments of these vessel classes’ least reliable systems have
                        brought limited returns on the investments. Maintenance officials and
                        vessel crew members also reported devoting increasing amounts of time
                        and resources to troubleshoot and resolve maintenance issues because
                        some systems and parts on these legacy vessel classes are obsolete.

                        The Coast Guard has taken two key actions to improve the condition of its
                        legacy vessels. First, in 2009, the Coast Guard reorganized its
                        maintenance command structure to focus on standardization of practices.
                        Under this reorganization, the Coast Guard eliminated its two
                        Maintenance and Logistics Commands and replaced them with a
                        centralized command structure—the Surface Forces Logistics Center—
                        whereby a single product line manager oversees the maintenance of




                        6
                         A major casualty is a deficiency in mission essential equipment that causes the major
                        degradation or loss of a primary mission.




                        Page 3                                                                       GAO-12-934T
similar classes of vessels. 7 Coast Guard officials reported that this
change was made to enable better oversight of the condition of entire
classes of the vessel fleet, reduce the workload on vessel crews by
providing centralized support for procurement of replacement parts, and
implement centralized maintenance plans to address commonly occurring
casualties. 8 Second, Coast Guard officials also reported that the Coast
Guard was on schedule to complete a 10-year, almost half-billion dollar
set of sustainment projects to refurbish selected patrol boats and upgrade
medium endurance cutters, known as Mission Effectiveness Projects,
which are intended to improve legacy vessel operating and cost
performance. Our July 2012 report provides additional information
regarding these actions but, as noted in the report, the condition of these
legacy vessels continues to decline despite these efforts.




7
  The Coast Guard established the Surface Forces Logistics Center under which Coast
Guard vessels are grouped into five product lines whose mission support, maintenance
procedures, priorities, and funds are overseen by a single product line manager. The
product lines are the (1) Long Range Enforcer (which includes the high endurance cutter
and the national security cutter); (2) Medium Endurance Cutter; (3) Ice Breaker, Buoy
Tender and Construction Tender; (4) Patrol Boat (which includes the 110-foot patrol boat
and fast response cutter); and (5) Small Boat.
8
 According to Coast Guard officials, vessel crews had previously been responsible for
managing procurement of replacements for minor casualties. According to these officials,
doing so could be time consuming for crews. Under the reorganization, the Surface
Forces Logistics Center manages a greater share of the procurement of replacement
parts and systems to both reduce the workload of crews and provide better oversight
across the vessel fleet. Additionally, the new organization is structured to provide a single
point of accountability (the product line manager) for all maintenance, system upgrades,
and supply functions for a vessel class.




Page 4                                                                          GAO-12-934T
                      Expenditures for the two key types of legacy vessel annual depot-level
Maintenance           maintenance—scheduled and unscheduled maintenance—declined from
Expenditures Have     fiscal year 2005 to fiscal year 2007, and then rose from fiscal year 2007
                      to fiscal year 2011. 9 For example, scheduled maintenance expenditures
Recently Increased,   rose from about $43 million in fiscal year 2007 to about $70 million in
and the Process for   fiscal year 2011. Coast Guard officials attributed the increase in
Estimating Costs      scheduled maintenance expenditures to better identifying maintenance
                      needs, increasing the prioritization of completing all scheduled
Does Not Fully Meet   maintenance, and the receipt of supplemental funding. In contrast,
Best Practices        unscheduled maintenance expenditures varied by vessel class from fiscal
                      years 2005 through 2011, but the high endurance cutter fleet consistently
                      incurred the greatest share of unscheduled maintenance expenditures.
                      For example, high endurance cutters accounted for 86 percent of all
                      unscheduled maintenance expenditures in fiscal year 2011. Coast Guard
                      officials attributed the comparatively high unscheduled maintenance
                      expenditures to the high endurance cutters’ advanced age and size. 10

                      Further, annual depot-level maintenance expenditures often exceeded
                      the Coast Guard’s budgeted funds for depot-level maintenance for the
                      legacy vessels—known as Standard Support Levels—from fiscal years
                      2005 through 2011. For example, actual depot-level maintenance
                      expenditures for the high endurance cutters were about 3.6 times higher
                      than Standard Support Levels in fiscal year 2009—$55.5 million
                      compared with $15.5 million. The Standard Support Levels have
                      generally remained unchanged over decades and do not reflect the rising
                      costs to maintain the legacy vessels as they have aged. 11 Senior Coast
                      Guard vessel maintenance officials cited this funding gap as a challenge,


                      9
                       Depot-level maintenance is vessel maintenance that is beyond the capability of the
                      operating units.
                      10
                         Coast Guard officials told us that major casualties on three high endurance cutters—the
                      CHASE, DALLAS and GALLATIN—contributed disproportionately to these expenditures in
                      fiscal years 2010 and 2011. The Coast Guard has since decommissioned the CHASE and
                      DALLAS on May 13, 2011 and March 30, 2012, respectively.
                      11
                         According to Coast Guard officials, Standard Support Levels are established when a
                      vessel class enters service or undergoes a service life extension program. For example,
                      the Coast Guard reset the Standard Support Level for the high endurance cutters after
                      conducting a service life extension program between 1987 and 1992—the Fleet
                      Renovation and Modernization Program—but has not reset the Standard Support Levels
                      for the medium endurance cutters or patrol boats. Coast Guard officials indicated that the
                      Coast Guard increases Standard Support Levels using non-pay inflation, but it has not
                      done so every year.




                      Page 5                                                                        GAO-12-934T
noting that supplemental funding had been critical to enable the Coast
Guard to fund necessary maintenance for the legacy vessel fleet. Our
July 2012 report provides further information regarding the Coast Guard’s
annual depot-level maintenance expenditures.

Our review found that the Coast Guard’s process for estimating legacy
vessel annual depot-level maintenance costs does not fully reflect
relevant best practices. GAO’s Cost Estimating and Assessment Guide
states that a high-quality and reliable cost estimate includes certain best
practice characteristics. We determined that the three characteristics
relevant to the Coast Guard’s cost estimation process are that the
process should be (1) well-documented, (2) comprehensive, and (3)
accurate. Our assessment showed that the Coast Guard’s legacy vessel
maintenance cost-estimating process partially met the three
characteristics, as follows:

•   Partially comprehensive: The Coast Guard’s process for estimating
    annual legacy vessel depot-level maintenance costs defines the
    program, among other things, but does not document all cost-
    influencing ground rules and assumptions (e.g., inflation rate).

•   Partially well-documented: The Coast Guard’s process for
    estimating annual legacy vessel depot-level maintenance costs
    discusses the technical baseline description, and the data in the
    baseline are consistent with the estimate; however, the Coast Guard
    did not provide documentation that discusses key cost estimating
    factors, such as how the data were normalized or the reliability of the
    data.

•   Partially accurate: The Coast Guard’s process for estimating annual
    legacy vessel depot-level maintenance costs contains few, if any,
    minor mathematical mistakes and is regularly updated to reflect
    significant program changes and current status. However, we
    assessed the cost estimate as being not fully accurate because Coast
    Guard officials could not provide us with documentation that would
    allow us to assess the reliability of the historical data used, the
    accuracy of the calculations, the relationship of the data to the
    historical contractor bids, or the final estimates for all maintenance
    costs.

To address these issues, in our July 2012 report, we recommended that
the Secretary of Homeland Security direct the Commandant of the Coast
Guard to ensure that the Coast Guard’s annual depot-level maintenance



Page 6                                                            GAO-12-934T
                       cost estimates conform to cost estimating best practices. DHS concurred
                       with this recommendation and described actions the Coast Guard has
                       taken or plans to take, but these actions may not fully address the intent
                       of this recommendation. For example, DHS noted that given current fiscal
                       constraints, the Coast Guard will focus on improvements that do not
                       require additional resources. While we agree that federal resources are
                       limited, aligning the cost estimating process for legacy vessel
                       maintenance with best practices would not necessarily require an
                       increased investment of resources. Rather, having a well documented
                       cost estimating process and using accurate historical data should enable
                       the Coast Guard to operate more efficiently. 12


                       The operational capacity of the Coast Guard’s legacy vessel fleet
Declining Condition    declined from fiscal years 2006 through 2011. In particular, while
of the Legacy Vessel   performance varied across the legacy vessel classes, two key Coast
                       Guard metrics—operational hours and lost cutter days—show that the
Fleet Makes            legacy vessels did not meet their operational capacity targets and lost
Operational Capacity   considerable planned operational time. For example, the high endurance
Targets Increasingly   cutters and 210-foot medium endurance cutters did not meet any of their
                       operational hour targets from fiscal years 2006 through 2011, and the
Unachievable           270-foot medium endurance cutters met their targets only in fiscal year
                       2008. Specifically, operational hours for the high endurance cutters
                       declined by about 32 percent from fiscal year 2008 to 2011, 13 and the
                       combined operational hours of the 210-foot and 270-foot medium
                       endurance cutters declined nearly 21 percent from fiscal year 2007 to
                       fiscal year 2011. 14 In addition, Coast Guard data show the high and
                       medium endurance cutters, collectively, averaged about 618 lost cutter
                       days per year from fiscal years 2006 through 2011. Further, the number
                       of lost cutter days for the high endurance cutters has been nearly


                       12
                          See the July 2012 report for more information on DHS’s comments and our evaluation
                       of them.
                       13
                          Coast Guard headquarters officials reported that two high endurance cutters were
                       decommissioned in fiscal year 2011 for a total reduction of 3,330 operational hours from
                       that achieved in fiscal year 2010.
                       14
                          Coast Guard officials attributed declines in the medium endurance cutters’ capacity
                       primarily to increased unscheduled maintenance. However, the officials also reported that
                       because medium endurance cutters were taken out of service on a rotating basis to
                       undergo the Mission Effectiveness Project, doing so may have also decreased the
                       medium endurance cutters’ operational hours by as much as 9,900 hours annually.




                       Page 7                                                                       GAO-12-934T
equivalent to three high endurance cutters being out of service for an
entire year in each of the last 3 fiscal years. Moreover, lost cutter days for
both the 210-foot and 270-foot medium endurance cutters combined
more than doubled, from 122 lost cutter days in fiscal year 2006 to 276
lost cutter days in fiscal year 2010. 15 Coast Guard headquarters officials
reported that the declining operational capacity of its legacy vessel fleet—
particularly the high and medium endurance cutters—has been a prime
contributor to the Coast Guard’s declining ability to meet mission
requirements and intercept threats beyond U.S. territorial waters.

Coast Guard officials also reported that delays in the delivery of
replacement vessels will require the Coast Guard to continue to operate
its legacy vessels beyond their originally-expected service lives and result
in a widening operational capacity gap. 16 As a result, these officials
expect the Coast Guard’s legacy vessels to become increasingly
unreliable, have increasingly diminished operational capacity, and be
increasingly costly and challenging to maintain. In the next few years, the
operational capacity gap that exists for the high endurance cutter and
patrol boat fleets is expected to increase because of actions the Coast
Guard plans to take to better balance the needs of the legacy fleet with
the acquisition of replacement vessels. For example, by the end of fiscal
year 2012, the Coast Guard plans to end the “High Tempo/High
Maintenance” program for eight of its patrol boats. 17 Then, in fiscal year
2013, the Coast Guard plans to decommission the next two most
degraded and costly high endurance cutters, as well as three patrol
boats. While these actions will reduce legacy fleet expenditures, they will



15
   Coast Guard officials attributed the majority of the high endurance cutter lost cutter
days to propulsion system casualties. For example, the Coast Guard reported that
catastrophic engine failure rendered the high endurance cutters DALLAS, CHASE, and
GALLATIN inoperative for 1 year, 1 year and 5 months, and 2 years, respectively, during
this time period. As stated previously, the Coast Guard has since decommissioned the
CHASE and DALLAS.
16
   The Naval Engineering Manual defines remaining service life as the time period during
which no major expenditures will be required for hull and structural repairs or
modernizations, or for machinery or system modernizations based solely on the vessel’s
capability to meet existing mission requirements.
17
   The “High Tempo/High Maintenance” program was designed to mitigate the loss of
eight patrol boats to hull failure and six to deployment to Bahrain by doubling the
operational hour output of eight patrol boats through the use of double crews and
increased maintenance. Coast Guard officials reported that these eight patrol boats will
return to normal operations at the end of fiscal year 2012.




Page 8                                                                        GAO-12-934T
also increase the vessel fleet’s operational capacity gap because the
Coast Guard will not receive sufficient numbers of replacement vessels
during this time period to make up for the lost capacity.

The ongoing delivery of replacement vessels is expected to help mitigate
the existing operational capacity gap for the legacy high endurance cutter
and patrol boat fleets. However, Coast Guard officials reported, and our
analysis of Coast Guard documents confirms, that the medium endurance
cutter fleet will be most affected by delays in delivery of replacement
vessels. The Coast Guard is refurbishing its medium endurance cutters
through the Mission Effectiveness Project to increase these cutters’
reliability and reduce longer-term maintenance costs, and third-party
assessments show that the performance of those medium endurance
cutters that have completed the project has improved. 18 Even if the most
optimistic projections were realized, though, and the Mission
Effectiveness Project was to extend the medium endurance cutters’
service lives by 15 years, the medium endurance cutters would remain in
service increasingly beyond the end of their originally-expected service
lives before full deployment of their replacement vessels—the offshore
patrol cutters. In particular, according to current plans, some of the 270-
foot medium endurance cutters are to remain in service as late as 2033—
up to 21 years beyond the end of their originally-expected service lives—
before they are replaced. Coast Guard officials reported that a further
refurbishment of the medium endurance cutters will be necessary to meet
operational requirements and that the Coast Guard is in the early stages
of developing plans for addressing the expected gap between remaining
medium endurance cutter fleet service lives and the delivery of the
replacement offshore patrol cutters.

Coast Guard efforts to sustain its legacy vessel fleet and meet mission
requirements until the replacement vessels are delivered are also
challenged by uncertainties regarding the future mix of vessels, as well as
the implementation of a rotational crew concept for the replacement
vessel for the high endurance cutters, known as the national security




18
   The Coast Guard has contracted with the Department of Transportation, Research and
Innovative Technology Administration’s Volpe National Transportation Systems Center to
conduct annual assessments of the effectiveness of the Mission Effectiveness Project.




Page 9                                                                    GAO-12-934T
cutter. 19 The Coast Guard’s fiscal year 2013 to 2017 5-year Capital
Investment Plan does not allocate funds for the acquisition of the last two
replacement national security cutters, as called for by the program of
record, and it is unclear how this could affect the decommissioning
schedule of the high endurance cutters, the last of which the Coast Guard
currently plans to decommission in fiscal year 2023. 20

The Coast Guard has established operational hour targets for the number
of hours its vessels are expected to conduct operations or missions each
fiscal year and uses these targets to inform planning decisions, such as
setting performance targets and corresponding resource allocations.
Although senior Coast Guard headquarters officials reported considering
various factors when setting overall mission performance targets
annually, these officials reported doing so based on the assumption that
vessel class assets will achieve 100 percent of their operational hour
targets. Our analysis of Coast Guard data, though, makes it clear that the
Coast Guard’s legacy vessel fleet has increasingly fallen below
operational hour targets in recent years, and this trend is expected to
continue. In addition, Coast Guard officials reported that the decline in
legacy vessel operational capacity has challenged the Coast Guard’s
ability to meet its mission performance targets. Further, Coast Guard
operational commanders reported taking actions to mitigate the effect of
declining legacy vessel capacity, such as diverting vessels tasked to
other missions to help complete operations. Nevertheless, the Coast
Guard has not revised legacy vessel operational hour targets because,
according to Coast Guard officials, doing so would lower its mission
performance targets. However, these targets have gone unmet because
of the declining operational capacity of the legacy vessel fleet. Because it
sets mission performance targets and allocates resources on the
assumption that legacy vessels will achieve 100 percent of operational
hour targets, the Coast Guard’s allocation of resources is not realistic.
Further, because the Coast Guard uses vessels’ operational hour targets



19
   The Coast Guard’s program of record assumes that the new national security cutter
fleet will achieve more operational capacity than the legacy high endurance cutter fleet by
implementing a rotational crew concept in which the Coast Guard would have four sets of
crew staff and operate three national security cutters on a rotating basis to increase the
vessels’ operational time.
20
   The Coast Guard recently revised the high endurance cutter decommissioning schedule
to delay the decommissioning of the last high endurance cutter from 2020 to 2023 in its
fiscal years 2013-2017 Capital Investment Plan.




Page 10                                                                        GAO-12-934T
                   to set agency-wide performance targets and to allocate resources,
                   consistent achievement of its performance targets is at increased risk.

                   In our July 2012 report, we recommended that the Secretary of Homeland
                   Security direct the Commandant of the Coast Guard to adjust legacy
                   vessel fleet operational hour targets to reflect actual capacity, as
                   appropriate by class. DHS did not concur with this recommendation and
                   noted, among other things, that reducing the operational hour targets
                   would fail to fully utilize those assets not impacted by maintenance
                   issues. We disagree with DHS’s position because, as noted in the July
                   2012 report, while senior Coast Guard officials reported that the Coast
                   Guard adjusts its mission performance targets annually, it does not also
                   adjust legacy vessel operational hour targets annually. These officials
                   also stated that the Coast Guard’s mission performance targets are
                   based on each vessel class’s capacity, with the assumption that each
                   vessel will operate at 100 percent of its planned operating time. Thus, we
                   do not believe that reducing the operational hour targets would result in a
                   failure by the Coast Guard to fully utilize assets not impacted by
                   maintenance challenges and continue to believe that this
                   recommendation has merit. 21

                   Chairman LoBiondo, Ranking Member Larsen, and members of the
                   subcommittee, this completes my prepared statement. I would be happy
                   to respond to any questions you may have at this time.


                   For questions about this statement, please contact Stephen L. Caldwell at
GAO Contact and    (202) 512-9610 or caldwells@gao.gov. Contact points for our Offices of
Staff              Congressional Relations and Public Affairs may be found on the last page
                   of this statement. Individuals making key contributions to this statement
Acknowledgements   include Christopher Conrad (Assistant Director) and Michael C.
                   Lenington. Additional contributors include Jason Berman, Chloe Brown,
                   and Lara Miklozek.




                   21
                      See the July 2012 report for more information on DHS’s comments and our evaluation
                   of them.




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                   Page 11                                                                   GAO-12-934T
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