Water Resources Projects: Army Corps of Engineers Can Further Enhance Acceleration of Feasibility Studies

Water resources development projects undertaken by the Corps—such as those to reduce the risks from coastal storms—historically have taken years or even decades to complete. To implement these projects, the Corps first conducts a feasibility study, which includes an analysis of the federal interest and the costs, benefits, and environmental impacts of a project; such studies can take several years to complete.

WRRDA 2014 requires the Corps to, among other things, conduct activities to accelerate the completion of feasibility studies. The act also includes a provision for GAO to assess acceleration reforms. This report examines the extent to which the Corps has (1) addressed the WRRDA 2014 feasibility study acceleration provisions, (2) reviewed the impact of its feasibility study acceleration reforms, and (3) maintained complete milestone data for its studies. GAO reviewed WRRDA 2014 and Corps documents; reviewed 19 feasibility studies subject to the act's acceleration provisions; analyzed data on key milestones; and interviewed Corps officials and stakeholders.

The U.S. Army Corps of Engineers has taken steps to address some feasibility study acceleration provisions under the Water Resources Reform and Development Act of 2014 (WRRDA 2014) but not others. For example, to implement a provision related to coordination, the Corps in September 2015 issued guidance emphasizing the importance of early coordination with other federal agencies to avoid delays later in the process. However, the Corps has not taken steps to address other provisions, such as one that calls for the Corps to establish a database to make publicly available information on the status of feasibility studies, citing resource constraints. The Corps does not have a plan to address these other provisions. A plan that includes resource estimates would better position the Corps to address the remaining acceleration provisions.

The Corps regularly monitors feasibility studies and has conducted some reviews of its acceleration reforms, such as an analysis that found that some studies were too complex to complete within the agency's timing and cost requirements—i.e., within 3 years and for less than $3 million. However, the Corps has not comprehensively evaluated the reforms' impacts. Corps officials and stakeholders expressed differing views on the reforms' impacts on the costs, time frames, and quality of feasibility studies. For example, many Corps officials GAO interviewed said the reforms' overall goals to reduce studies' cost and time frames were positive, but others raised concerns, such as that the $3 million cost limitation may not be realistic for different geographic areas. Corps officials said they have not conducted a comprehensive impact review in part because they are focused on monitoring ongoing studies. These officials said they see the value in conducting such a review as they complete more studies, but they have not developed a plan to do so. Developing an evaluation plan would help the Corps conduct a timely and effective review.

The Corps has not maintained complete milestone data in its central data system for the 19 feasibility studies GAO reviewed (see figure). For example, 12 studies did not include data for one or more milestones. Corps officials said agency policy requires the entry of information on 10 key milestones in the agency's central data system. However, GAO found that the policy only explicitly requires that two of the key 10 milestones be entered into the agency's central data system. Without clarifying its policy to help ensure officials enter data on all milestones in the central data system, the Corps will not have complete data to efficiently monitor the progress of feasibility studies.

GAO is making three recommendations to the Department of Defense to direct the Assistant Secretary of the Army for Civil Works to (1) develop a plan with resource estimates to address the remaining WRRDA 2014 provisions, (2) develop a plan to comprehensively evaluate the impacts of the agency's acceleration reforms, and (3) clarify its policy to help ensure district officials enter data on required milestones for feasibility studies in its central data system. The agency concurred with the recommendations.

Water resources development projects undertaken by the U.S. Army  Corps of Engineers—such as those to improve navigation channels or  reduce the risks from coastal storms—historically have taken years or  even decades to move from conception to completion. This is due in part  to the length of time the Corps takes to complete feasibility studies, which  include analyses of the federal interest in as well as the costs, benefits,  and environmental impacts of the projects. Some feasibility studies have  taken more than a decade to complete. For example, a Corps feasibility  study reviewing the possible deepening of a navigation channel serving  ports in Texas and Louisiana was initiated in March 2000 and completed  in July 2011. In addition, a Corps feasibility study reviewing flood risk  management options for the Ala Wai canal watershed in Hawaii was  initiated in March 2001 and completed in December 2017.

Recognizing the need to address lengthy time frames for its projects, the  Corps initiated changes in February 2012 aimed at improving and  streamlining feasibility studies, reducing their costs, and expediting their  completion. For example, the Corps established a policy that feasibility  studies are to be completed in less than 3 years, at a cost of not more  than $3 million, and with the ongoing involvement of all three  organizational levels of the Corps—headquarters, divisions, and districts.  The Corps refers to this as the 3x3x3 rule. The Corps also instituted  changes in March 2012 in how it conducts risk management—the  process of considering risks and taking steps to address those risks—as  part of its feasibility study process. Specifically, Corps officials are to  consider the types of risks, as well as the likelihood and consequences of  those risks, when making decisions such as whether to conduct additional  analysis of a particular issue. A 2015 Corps document stated that  previously the Corps’ senior leadership was involved at the end of a  feasibility study but since the 2012 changes is now involved early on to  understand risks and make related decisions.

The Water Resources Reform and Development Act of 2014 (WRRDA  2014) was subsequently enacted and contains provisions related to,  among other things, accelerating the completion of, and improving public  transparency around, feasibility studies for which an environmental  impact statement (EIS) is conducted. For example, the Corps is required  to establish a database to make publicly available certain information on  the status and progress of its feasibility studies. WRRDA 2014 also  codified the Corps’ 3x3x3 rule. Given its own initiatives and the  provisions in WRRDA 2014, the Corps is engaged in a wide array of  reforms to the feasibility study process, which we refer to in this report as  acceleration reforms.

The Corps collects information to manage its feasibility studies in its  central data system. In this system, the Corps maintains data on the  dates for key milestones, such as the date the Corps initiates the  feasibility study process. According to Corps documents, including these  milestone data in the agency’s central data system facilitates reporting on  the status and progress of its feasibility studies and other projects.

WRRDA 2014 includes a provision for us to assess the Corps’ reforms  carried out in response to the project acceleration reforms in the act,  including an evaluation of certain impacts, and report to Congress 5 and  10 years after enactment of the act. This report examines the extent to  which the Corps has (1) addressed the WRRDA 2014 feasibility study  acceleration provisions, (2) reviewed the impact of its feasibility study  acceleration reforms, and (3) maintained complete milestone data for  feasibility studies in its central data system.

To conduct our work, we reviewed the first 19 feasibility studies subject to  the WRRDA 2014 acceleration provisions. These include feasibility  studies that (1) were initiated after June 10, 2014, the date WRRDA 2014  was enacted, through August 15, 2018, and (2) for which an EIS is  prepared. We reviewed Corps guidance on the agency’s process for  planning feasibility studies and other related documentation. We also  conducted an in-depth review of seven of these 19 feasibility studies. We  selected these seven feasibility studies because they represent different  types of water resources development projects, are at varying stages of  completion, and are geographically dispersed. The seven studies provide  illustrative examples but are not generalizable to all Corps’ feasibility  studies subject to the WRRDA 2014 acceleration provisions. For each of  the seven studies, we reviewed project management plans and other  project documents, such as draft feasibility studies, if available. From  August 2018 through November 2018, we visited the Corps’ four district  offices that led these seven studies to learn more about the status and  progress of each feasibility study and the Corps’ coordination with other  federal agencies and nonfederal sponsors, among other things. We  interviewed Corps officials at the three divisions overseeing the districts  conducting the seven feasibility studies and representatives from  nonfederal sponsors for these studies. We also interviewed officials from  federal agencies, such as the Fish and Wildlife Service (FWS) and the  National Marine Fisheries Service (NMFS).

To examine the extent to which the Corps addressed the WRRDA 2014  feasibility study acceleration provisions, we reviewed the Corps’  documentation related to the implementation of those provisions, such as  guidance and agency policies. We also interviewed Corps headquarters  officials as well as division and district officials from the three divisions  and four districts discussed above and obtained related documentation.

To examine the extent to which the Corps has reviewed the impact of its  feasibility study acceleration reforms, we reviewed Corps policy,  guidance, training, and other documentation on the implementation of  those reforms. We interviewed Corps headquarters officials to learn  what, if any, (1) new policies were in place to help division and district  officials implement the reforms; and (2) review or analysis headquarters  officials had completed of the reforms’ impacts on the cost, time frames,  or quality of feasibility studies. We compared this information with  guidance for program evaluation.

To examine the extent to which the Corps has maintained complete  milestone data for feasibility studies in its central data system, we  reviewed the Corps’ information on the status of the 19 feasibility studies  in our review. We also analyzed data from the Corps’ central data system  on all feasibility studies with an EIS. We assessed the reliability of these  data by reviewing related documentation, conducting data testing for any  missing data, and interviewing knowledgeable Corps officials, among  other things. We determined that the data were sufficiently reliable for the  purpose of understanding which districts and divisions conducted  feasibility studies and for understanding the types of milestones that were  entered into the central data system. However, as discussed in this  report, we determined that the milestone data were not sufficiently reliable  for other purposes. We reviewed data for the 19 feasibility studies to  determine whether they conformed to the Corps’ policy on what milestone  data should be in its data system. For more information on our objectives,  scope, and methodology, see appendix I.

We conducted this performance audit from April 2018 to July 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform our audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

The Corps is one of the world’s largest public engineering, design, and  construction management agencies. Located within the Department of  Defense, the Corps has both military and civilian responsibilities. Through  the civilian Civil Works Program, the Corps plans, constructs, operates,  and maintains a wide range of water resources development projects  such as navigation and flood risk projects. The Assistant Secretary of the  Army for Civil Works, appointed by the President, sets the strategic  direction for the program and has principal responsibility for the overall  supervision of functions relating to the Army’s Civil Works Program. The  Chief of Engineers, a military officer, is responsible for execution of the  civil works and military missions. At the Corps level, the Civil Works  Program is organized into three tiers: headquarters in Washington, D.C.;  eight regional divisions; and 38 local district offices (see fig. 1).

Corps headquarters primarily develops policies and guidance to  implement the agency’s responsibilities and plans the direction of the  organization. The divisions, which were established generally according  to watershed boundaries, primarily coordinate the districts’ civil works and  military projects and are commanded by military officers. The districts,  also commanded by military officers, are to, among other things, plan and  implement feasibility studies and the resulting water resources  development projects that are approved by the divisions and  headquarters.

Major Steps in Corps Water Resources Development Projects

There are several steps in conducting a Corps water resources  development project. When a local community perceives a need or  experiences a water resources problem that is beyond its ability to solve,  it typically contacts the Corps for assistance. These communities and  Congress, as well as other entities, play key roles in the process. Figure 2  illustrates the major steps in conducting a Corps water resources  development project.

As identified above, one of the major steps in initiating a water resources  development project is conducting a feasibility study. Feasibility studies  further investigate a water resources problem and make  recommendations on whether a project is in the federal interest, and if so,  how the problem should be addressed. Generally, the cost of a feasibility  study is shared between the Corps and a nonfederal sponsor, such as a  local port authority or a state agency.

In 2012, the Corps began using a new approach to conducting feasibility  studies, referred to as SMART Planning. As part of this approach, Corps  officials are to use and document a risk-informed approach to decision- making. Specifically, Corps officials are to consider risks at each point in  the feasibility study process and balance the probability and  consequences associated with those risks with the time and costs needed  to avoid or mitigate risks through, for example, collecting additional data  or conducting additional analysis. By doing so, they are to conduct only  the additional analysis needed to make a decision at that point in the  process. At each step, Corps officials are to use an approach that  balances the level of detail, data collection, research, and associated  risks with what is necessary to deliver the feasibility study, and they are to  justify any additional work as the best course forward.

The Corps’ feasibility study process consists of four phases (scoping,  alternative evaluation and analysis, feasibility-level analysis, and Chief’s  report) and a number of key milestones, such as identifying project  alternatives for further review (see fig. 3). The complete feasibility study  process is to take place within the statutory target time frame of less than  3 years (36 months). The Corps uses SMART Planning to help feasibility  studies meet the agency’s 3x3x3 rule. Corps policy allows the Corps to  spend more money and take more time on an unusually complex  feasibility study if the district leading the study requests and receives an  exemption from headquarters or the Assistant Secretary of the Army for  Civil Works. However, Corps policy indicates that such exemptions are  not routine and are to be granted only after careful consideration and  review by division and headquarters officials. In addition, WRRDA 2014,  as amended, provides that the Secretary of the Army may make an  exception by extending the timeline of a study if the Secretary determines  that the study is too complex to comply with the 3x3x3 rule. The Secretary  is not to extend the timeline for a feasibility study for a period of more  than 10 years, and any feasibility study that is not completed before that  date shall no longer be authorized. The act also requires the Secretary  to provide written notice to the Senate Committee on Environment and  Public Works and the House Committee on Transportation and  Infrastructure each time the Corps grants such an exception.

The feasibility study process includes work the Corps undertakes to  satisfy requirements under the National Environmental Policy Act (NEPA)  and other environmental statutes. Under NEPA, federal agencies are to  evaluate the potential effects of proposed projects on the environment.  When the Corps determines that a water resources development project  could have significant environmental effects, it must prepare an EIS.  The Corps issues a draft EIS as part of the overall draft feasibility report  for public and stakeholder review and issues a final EIS when it issues its  final feasibility report. Feasibility studies that require an EIS typically  represent larger and more complex studies than those that do not require  an EIS. According to a 2013 Congressional Research Service report,  Corps feasibility studies that are larger and more complex tend to require  additional funding and time when compared to less complex, smaller  studies. While the Corps does not publish information on the length of  time it takes to complete feasibility studies, our analysis of publicly  available data showed that the median time it took the Corps to complete  a feasibility study with an EIS was more than 7 years for those studies  completed from 2008 through 2018.

Statutory Provisions for Accelerating Feasibility Studies

WRRDA 2014 contains provisions related to, among other things,  accelerating the completion of feasibility studies for which an EIS is  prepared. These provisions broadly fall into different general categories,  which we grouped as follows:

Coordination and administration. These provisions are generally  process oriented. Among other things, they relate to facilitating the  process of coordinating and administering feasibility studies by, for  example, encouraging the Corps and other agencies to coordinate  early in the feasibility study process and resolve issues expeditiously.

Environmental review. These provisions relate to implementing  NEPA and other environmental statutes when conducting feasibility  studies. For example, the Corps is to establish a program to measure  and report on progress made to improve and expedite the planning  and environmental review process.

Public transparency. These provisions generally require the Corps  to, among other things, make information publicly available on how it  is implementing the acceleration provisions.

The Corps Has Taken Steps to Address Some Feasibility Study Acceleration Provisions but Not Others

The Corps has taken steps to address broad WRRDA 2014 provisions  related to facilitating the process of coordinating and administering  feasibility studies. For example:  Issuance of a joint coordination guide. In September 2015, as a  result of the act and previous ongoing coordination efforts, the Corps,  NMFS, and FWS worked together to jointly issue a coordination guide  for conducting feasibility studies. The guide discusses the feasibility  study process in depth and emphasizes the importance of  substantive, early engagement among the three agencies to  successfully deliver projects and avoid delays later in the process that  may result from lingering disagreements among the agencies.

Issuance of Corps guidance on WRRDA 2014 acceleration  provisions. In March 2018, the Corps issued guidance on how  officials should implement the WRRDA 2014 acceleration provisions  when conducting feasibility studies. This includes guidance on  implementing administrative changes such as deadlines for gathering  agency or public comments. It also includes guidance on coordination  within the agency as well as with other agencies and stakeholders,  such as nonfederal sponsors. For example, WRRDA 2014 provides  that the Corps is to make certain information available to other  agencies as early as practicable in the environmental review process.  The Corps’ March 2018 guidance indicates that Corps officials are to  provide information on the (1) environmental and socioeconomic  resources located within the physical area associated with a feasibility  study, and (2) general locations of the different alternatives under  consideration. While the guidance was not issued for almost 4 years  after the enactment of WRRDA 2014, several Corps headquarters  and district officials said the Corps disseminated information on how  to implement the acceleration provisions to the districts in various  ways, such as through webinars and working with teams that had  initiated feasibility studies subject to the act’s acceleration provisions.

Many Corps headquarters, division, and district officials said that many of  the act’s coordination and administration provisions are similar to long- standing practices they followed, based on requirements in other laws  such as NEPA. For example, according to many Corps headquarters,  division, and district officials, the WRRDA 2014 provision to develop a  coordinated environmental review process is generally consistent with  NEPA and its implementing regulations. According to a Corps  headquarters official, the WRRDA 2014 coordination provisions add  specificity to the Corps’ existing practices by detailing which agencies to  involve in coordination efforts and when to involve them.

The Corps also has taken steps to address one of the WRRDA 2014  provisions related to public transparency. Specifically, the Corps is to  annually prepare, and make publicly available, a list of feasibility studies  subject to the acceleration provisions that do not have adequate funding  to make substantial progress toward completion of the study. Corps  headquarters and district officials said that in the past the Corps funded  several hundred active feasibility studies at any given time. While this  allowed for many feasibility studies to remain active and make some  progress, it also made less funding available for individual feasibility  studies and slowed the progress of some studies, according to several  Corps officials. According to a February 2012 Corps policy memo, agency  leadership initiated a process to review all active feasibility studies to  determine which were the most viable for congressional funding. The  Corps re-scoped or deactivated the remainder of the feasibility studies.  Many Corps district and headquarters officials told us this allowed for  increased funding for and progress to be made on the feasibility studies  that remained active. As a result of the Corps’ efforts, headquarters  officials said the number of active Corps feasibility studies decreased  from 653 in 2012 to 89 at the end of 2018. In addition, they said that  because active feasibility studies now have greater levels of funding, the  agency has not had to report any active feasibility studies that do not  have adequate funding.

However, as of May 2019, the Corps has not addressed other WRRDA  2014 provisions related to public transparency and environmental review.  These include the following:

Status and progress database. By June 2015, the Corps was to  establish and maintain an electronic database and, in coordination  with other federal and state agencies, issue reporting requirements to  make publicly available the status and progress regarding compliance  with applicable requirements of NEPA and other required approval or  action.

Performance measurement. The Corps is to establish a program to  measure and report on progress made toward improving and  expediting the planning and environmental review process.

Environmental review guidance. The Corps is to (1) prepare, in  consultation with the Council on Environmental Quality and other  federal agencies with jurisdiction over actions or resources that may  be impacted by a project, guidance documents that describe the  coordinated environmental review processes the Corps intends to use  to implement reforms for planning projects, and (2) issue guidance on  the use of programmatic approaches for the environmental review  process that carries out specified actions and meets specified  requirements.

In other instances, the Corps has taken some initial steps but has not fully  addressed certain WRRDA 2014 provisions. Specifically, not later than  180 days after the act’s enactment, the Corps was to survey the agency’s  use of categorical exclusions in projects since 2005, publish a review of  that survey, and solicit requests from other federal agencies and project  sponsors for new categorical exclusions. By June 2015, the Corps was  to propose a new categorical exclusion if it identified a category of  activities that merited such action. As of May 2019, the Corps had  conducted an internal survey and solicited input through the Federal  Register on its procedures for implementing NEPA. However, Corps  headquarters officials said they had not published a review of its survey,  targeted requests for new categorical exclusions to other federal agencies  and nonfederal sponsors, or proposed new exclusions as merited.  Appendix II contains a more detailed summary of the WRRDA 2014  acceleration provisions, along with information on Corps actions to  address each provision.

Corps headquarters officials identified resource constraints as the primary  reason for not addressing some public transparency and environmental  review provisions. For example, to develop environmental review  guidance, Corps headquarters officials told us that they would need to  conduct various steps, including drafting guidance, conducting  administrative review with other federal agencies, soliciting public  comment, and revising the guidance. Headquarters officials also said they  were involved in a similar effort with other federal agencies to develop  environmental review guidance in a publication called the 2015 Red  Book, an effort they characterized as labor intensive.

In addition, to establish a database to publicly report on the status of its  feasibility studies, Corps headquarters officials said they would need to  stand up and maintain a website similar to the Federal Infrastructure  Permitting Dashboard for federal infrastructure projects. The Corps is  one of many agencies involved in the effort to create and maintain this  dashboard, and Corps headquarters officials said the effort was a  resource-intensive process. Corps headquarters officials said that while  they have not created the database required by WRRDA 2014, relevant  information is available through the agency’s annual public reports on  active and recently completed feasibility studies’ milestones and  schedules. Corps headquarters officials also said the status of feasibility  studies is often available on the Corps districts’ websites. However, this  information is not easily accessible without knowing which district office is  responsible for a given feasibility study.

While Corps officials identified resource constraints as the primary reason  for not addressing certain WRRDA 2014 provisions, they did not provide  specific estimates on the resources that the Corps would need to address  these provisions. In addition, the officials said they do not have a plan that  addresses how and when they intend to implement the provisions they  have yet to address. We have previously reported on leading practices for  sound planning and have found that implementation plans that include  resource estimates help ensure organizations achieve their goals and  objectives. Such a plan would better position the Corps to address the  remaining WRRDA 2014 provisions related to environmental review and  public transparency.

The Corps Has Performed Some Review of Its Feasibility Study Acceleration Reforms but Has Not Conducted a Comprehensive Evaluation of Impacts

The Corps monitors feasibility studies and has done some review of its  acceleration reforms but has not conducted a comprehensive evaluation  of the impacts of these reforms. In terms of monitoring, Corps policy  states that division and district leaders are responsible for monitoring  feasibility studies within their areas of responsibility. According to Corps  policy, districts are to prepare a quality control plan for each project to  ensure compliance with all technical and policy requirements, and  divisions are responsible for quality assurance by ensuring that districts  plan, design, and deliver quality projects on schedule and within budget.  Corps headquarters officials also said they monitor the progress of  feasibility studies during management meetings, during which they  discuss the cost and status of feasibility studies as well as the quality of  those studies; such meetings are largely led by Corps management or by  the Corps’ Planning Advisory Board, which oversees the quality of  feasibility studies.

In addition to monitoring individual feasibility studies, Corps headquarters  officials said they have conducted some broader reviews of how the  acceleration reforms are progressing. For example, they conducted a  trend analysis in October 2018 and again in April 2019 to identify the  reasons why some feasibility studies have received exceptions from the  timing and cost requirements of the 3x3x3 rule. These analyses, among  other things, identified that some studies were too complex to be  completed within 3 years or for less than $3 million, according to Corps  officials. Furthermore, based on their experiences with various reform  efforts, Corps officials said that they have been making real-time  enhancements. For example, based on input from the Corps’ Planning  Advisory Board, Corps leadership has called for the agency to clarify its  updated approach to risk management, according to Corps officials.  These officials said each component within the Corps that is involved in  conducting feasibility studies is to issue internal guidance on its risk  management approach.

However, Corps headquarters officials said the Corps has not conducted  a comprehensive evaluation of acceleration reforms to determine what  impacts the reforms have had and whether any modifications to those  reforms are needed. Corps and other agency officials and stakeholders  we interviewed differed in their views of the acceleration reforms’ impacts  on the cost, time frames, and quality of feasibility studies:

Cost and time frames for completing feasibility studies. Many  Corps officials said they agreed with the overall goals of reducing  costs and increasing the speed with which feasibility studies are  carried out. Some Corps headquarters and district officials said  SMART Planning and the 3x3x3 rule are changing the Corps’ culture  around the amount of time and cost a feasibility study should take.  However, several Corps district and headquarters officials said some  Corps staff are experiencing difficulties with the cultural change  represented by SMART Planning and the 3x3x3 rule. For example, a  Corps district official said that in the past some Corps navigation  economists had one year to complete some modeling analyses for  feasibility studies, but they now are to complete such work in 90 days  due to the constraints of SMART Planning and the 3x3x3 rule, which  has been a difficult adjustment. In addition, many Corps headquarters,  division, and district officials raised concerns that the cost limitation of  $3 million may not be realistic given differences in cost across  geographic locations or the loss of spending value over time caused  by inflation.

Quality of feasibility studies. Several Corps district officials we  interviewed said they like the Corps’ new policy of involving other  agencies earlier in the process and with more frequency. They said  they believe this approach has improved coordination with other  agencies—by, for example, inviting the other federal agencies to join  the Corps in a formal initiation meeting—which can in turn improve the  overall quality of a feasibility study. However, some FWS and NMFS  officials said they would like to be more involved and have better  communication with the Corps than they currently do, such as  throughout the feasibility study process rather than just at the  beginning of a study and at the end when their formal review is  requested. Similarly, several Corps headquarters, district, and division  officials have commended the agency’s new approach to risk  management and stated that they aim to provide partner agencies  with the information they need to conduct their work on the feasibility  study. However, many Corps, FWS, and NMFS officials and  nonfederal sponsors we interviewed said they were concerned that  this new approach might result in insufficient information for making  decisions, which could affect the quality of feasibility studies. For  example, for six of the seven studies that we reviewed, officials from  FWS and NMFS said it has become more difficult for them to provide  meaningful input on the feasibility study alternatives considered  because the Corps provides them with less detailed information than  in the past.

Corps officials and other stakeholders we interviewed also expressed  concern about possible impacts of the 3x3x3 rule on the quality of  feasibility studies. For example, many Corps headquarters, division, and  district officials said that because the 3x3x3 rule puts constraints on costs  and time frames, if the scope of a feasibility study is not similarly reduced,  it can affect the study’s quality. In addition, nonfederal sponsors for four of  the seven studies we examined expressed concerns with the 3x3x3 rule;  three of these four nonfederal sponsors said they believe that the Corps  is more focused on meeting the cost and schedule timelines than on the  needs or quality of the study.

Senior Corps headquarters officials said they are confident that the cost  and duration of feasibility studies has decreased overall as a result of the  acceleration reforms but could not provide us with documentation to  support this observation. Specifically, officials said in March 2019 that  based on analysis they had recently conducted, most feasibility studies  are now being completed within 4 years and at a lower cost than  feasibility studies undertaken prior to implementation of the 3x3x3 rule.  While these results may not meet the 3x3x3 rule, officials said that these  feasibility studies were the first subject to the acceleration reforms and  may not depict the likelihood of future feasibility studies meeting the rule.  This is, in part, because Corps officials who are working on new feasibility  studies have the benefit of the past several years of experience working  with the SMART Planning process. Further, Corps officials said that they  do not have formal documentation summarizing how the acceleration  reforms have affected the quality of their feasibility studies overall, but  they monitor individual feasibility studies, as described earlier.

According to Corps headquarters officials, the Corps has not conducted a  more comprehensive evaluation of the broader impacts of the  acceleration reforms because it has only completed a small number of  feasibility studies since 2012 under the acceleration reforms, and officials  are focused on monitoring their ongoing individual studies. These officials  said they see the value in conducting such an evaluation as they  complete more studies but that they have not developed formal plans to  do so. Effective program evaluation includes an evaluation plan—that is,  a plan that takes into account the questions guiding the evaluation, the  constraints faced in studying the program, and the information needs of  the intended users. Developing an evaluation plan would help position  the Corps to conduct a timely and effective review of the impacts of the  acceleration reforms overall.

The Corps Has Not Maintained Complete Milestone Data for Selected Feasibility Studies in Its Central Data System

The Corps has not maintained complete data on the 10 key milestones in  its central data system for more than half of the feasibility studies we  reviewed. Specifically, for the 19 feasibility studies we reviewed, we found  that:  seven studies in the Corps’ central data system included complete  data for all 10 key milestones, and  twelve studies were missing one or more milestones in the data  system.

Table 1 provides information on the key milestone data included in the  Corps’ central data system for the 19 feasibility studies we reviewed.

Many Corps headquarters and division officials said that Corps officials  vary in their knowledge of its central data system. Many headquarters,  division, and district officials we interviewed also acknowledged that, in  general, the milestone information entered into the Corps’ central data  system can be inconsistent across different feasibility studies.

Corps headquarters officials said agency policy requires district officials  conducting feasibility studies to enter data on 10 key milestones for each  study into the agency’s central data system. However, while the policy  identified the 10 milestones, it only explicitly requires that two of the 10  milestones be entered into the agency’s central data system.

Specifically, the policy states that officials are to enter into the Corps’ data  system the milestones for (1) feasibility study initiation and (2) posting of  the plan for peer and stakeholder review. Corps officials said the intent of  the policy is for all 10 key milestones to be entered into the central data  system but acknowledged that the policy may not be clear. In part to  assist district officials in conducting feasibility studies, Corps  headquarters officials created a template, which includes information on  nine of the 10 key milestones. In addition, a Corps district official said she  was unclear on the agency’s expectations about which milestones to  enter into the central data system. Corps headquarters officials said they  contact district officials responsible for feasibility studies to obtain up-to- date information and ensure they understand the progress of each  feasibility study. While this may help to ensure accuracy and  completeness of milestone data on feasibility studies, several Corps  district officials said the process of responding to such data calls can be  time consuming and take them away from their core responsibilities.  Without clarifying its policy to help ensure district officials enter data on all  key milestones for feasibility studies into its central data system, the  Corps will not have complete data to efficiently monitor the progress of  feasibility studies.

The Corps has taken steps to address the acceleration provisions in  WRRDA 2014, such as those related to coordination. However, it has not  fully addressed provisions related to environmental review or public  transparency. Corps officials said they do not have a plan that addresses  implementation of remaining provisions or the resources that will be  required to implement them. An implementation plan that includes  resource estimates would better position the Corps to address the  remaining provisions in WRRDA 2014.

Further, the Corps monitors the progress of feasibility studies and has  conducted some reviews of the individual acceleration reforms. However,  the agency has not developed an evaluation plan for its acceleration  reforms to better understand the reforms’ impacts overall and determine  whether any modifications to those reforms are needed. Developing such  a plan would enable the Corps to conduct a timely and effective  evaluation.

Further, without clarifying its policy to ensure district officials enter all key  milestone dates for feasibility studies into its central data system, the  Corps will continue to lack complete data to efficiently monitor the  progress of feasibility studies.

We are making the following three recommendations to the Department  of Defense:  The Secretary of the Army should direct the Assistant Secretary of the  Army for Civil Works to develop an implementation plan that includes  resource estimates to address the remaining WRRDA 2014 acceleration  provisions. (Recommendation 1)

The Secretary of the Army should direct the Assistant Secretary of the  Army for Civil Works to develop a plan to conduct a comprehensive  evaluation of the impacts of the agency’s feasibility study acceleration  reforms. (Recommendation 2)

The Secretary of the Army should direct the Assistant Secretary of the  Army for Civil Works to clarify its policy to help ensure district officials  enter data on all key milestones for feasibility studies into its central data  system. (Recommendation 3)

We provided a draft of this report to the Department of Defense for review  and comment. In its written comments, reprinted in appendix III, the  Department concurred with our recommendations. The Department  commented that we should redirect our recommendations to the Assistant  Secretary of the Army for Civil Works rather than to the Chief of  Engineers and the Commanding General of the U.S. Army Corps of  Engineers, which we did. The Department also provided technical  comments, which we incorporated as appropriate.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of Defense, the Secretary of the Department of  the Interior, the Secretary of Commerce, and other interested parties. In  addition, the report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-3841 or FennellA@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix IV.

Appendix I: Objectives, Scope, and Methodology

This report examines the extent to which the U.S. Army Corps of  Engineers has (1) addressed the feasibility study acceleration provisions  under the Water Resources Reform and Development Act of 2014  (WRRDA 2014), (2) reviewed the impact of its feasibility study  acceleration reforms, and (3) maintained complete milestone data for  feasibility studies in its central data system.

To conduct our work, we reviewed the first 19 feasibility studies subject to  the WRRDA 2014 feasibility study acceleration provisions, among other  things. These feasibility studies included those that (1) were initiated after  June 10, 2014, the date WRRDA 2014 was enacted, through August 15,  2018, and (2) for which an environmental impact statement (EIS) is  prepared. We chose to review studies through August 15, 2018, because  after that date the Corps initiated several feasibility studies using funding  in a supplemental appropriation the Corps received in February 2018 to  conduct work in response to recent large hurricanes, and Corps officials  said they planned to use a somewhat different approach to conducting  these studies. For each study, we reviewed Corps guidance on the  agency’s process for planning feasibility studies and other related  documentation. We examined information from the Corps on the progress  and status of the19 feasibility studies. We also reviewed information for  each feasibility study on the Corps’ business line or program, the district  or division overseeing the study, and information on which studies had  received exceptions from the 3x3x3 rule.

We also conducted a more in-depth review of seven of these 19 feasibility  studies. We selected these seven studies because they represent  different types of water resources development projects, were at varying  stages of completion, and are geographically dispersed. The seven  studies, and the Corps districts leading these studies, are:

Coastal Texas Protection and Restoration (Galveston District);

Houston Ship Channel Expansion Channel Improvement Project  (Galveston District);

Matagorda Ship Channel (Galveston District);

Gulf Intercoastal Waterway: Brazos River Floodgates and Colorado  River Locks Systems (Galveston District);

Mississippi River Ship Channel, Gulf to Baton Rouge, Louisiana  General Reevaluation Report (New Orleans District);

Sacramento River, General Reevaluation Report (Sacramento

Port of Long Beach Deep Draft Navigation Improvements (Los  Angeles District).

For each of these seven studies, we reviewed project management plans  and other project documents, such as draft feasibility studies, if available.  From August 2018 through November 2018, we visited the four district  offices that led these seven studies, including the Corps’ Galveston, Los  Angeles, New Orleans, and Sacramento district offices. During these  visits, we discussed the status and progress of each of these feasibility  studies and the Corps’ coordination with other federal agencies and  nonfederal sponsors, among other things. For each study, we interviewed  officials from nonfederal sponsors—such as the state or local government  associated with individual studies—and from federal partners—including  the Fish and Wildlife Service (FWS) and the National Marine Fisheries  Service (NMFS). We selected FWS and NMFS because of the important  role they play in reviewing environmental aspects of Corps feasibility  studies and their role in the 2015 joint publication on coordination. We  also interviewed Corps officials at the three divisions overseeing the  districts that conducted the feasibility studies we selected. This included  officials from the Corps’ South Pacific, Mississippi Valley, and  Southwestern divisions. While the seven studies provide illustrative  examples, they are not generalizable to all of the Corps’ feasibility studies  for which an EIS is prepared.

We developed and used four standard sets of semi-structured interview  questions for the following groups: the (1) Corps district office officials  conducting the seven selected feasibility studies, (2) FWS and NMFS  officials working with the Corps on these studies, (3) Corps division  officials overseeing each study, and (4) nonfederal sponsors who worked  with the Corps on each study.

To characterize the views of those we interviewed throughout the report,  we defined modifiers to quantify officials’ views as follows:  “some” refers to responses from two to four Corps officials and/or  stakeholders;  “several” refers to responses from five to seven Corps officials and/or  stakeholders; and  “many” refers to responses from eight or more Corps officials and/or  stakeholders.

To examine the extent to which the Corps addressed the WRRDA 2014  feasibility study acceleration provisions, we compiled a list of the  provisions. We then reviewed the Corps’ documentation related to the  implementation of these provisions, including agency guidance and  policies. We compared this information with the WRRDA 2014  acceleration provisions. To do this, we created categories for the  acceleration provisions and grouped the provisions by category.

To examine the extent to which the Corps has reviewed the impact of its  acceleration reforms, we reviewed Corps policy, guidance, training, and  other documentation on implementation of those reforms. We use the  term acceleration reforms to refer to the requirements that new feasibility  studies are to be completed in less than 3 years and at a cost of not more  than $3 million, the Corps’ risk management of feasibility studies through  its new SMART Planning process, and the WRRDA 2014 acceleration  provisions. We reviewed documentation from the Corps on the feasibility  studies that have received exceptions from the 3x3x3 rule. We  interviewed Corps headquarters officials to learn what, if any, (1) new  policies were in place to help division and district staff implement the  reforms; and (2) review or analysis headquarters officials had completed  of the impacts of the reforms on the cost, time frames, or quality of  feasibility studies. We also interviewed Corps districts and division  officials who were responsible for the seven studies about how the  acceleration reforms were working, as well as FWS and NMFS officials  and nonfederal sponsors about their views of the impacts of the new  processes on their work on these feasibility studies. We compared this  information with program evaluation guidance.

To examine the extent to which the Corps has maintained complete  milestone data for feasibility studies in its central data system, we  obtained milestone data from the system for the 19 Corps feasibility  studies in our review. We analyzed the milestone data to determine which  milestone dates were in the system and then worked with Corps  headquarters officials to verify that information. We assessed the  reliability of these data by reviewing related documentation and  interviewing knowledgeable officials, among other things. We determined  that the data were sufficiently reliable for the purpose of understanding  which districts and divisions conducted feasibility studies and for  understanding the types of milestones that were entered into the central  data system. However, as discussed in this report, we determined that  the milestone data were not sufficiently reliable for other purposes. We  reviewed data for all feasibility studies in our review to determine whether  they conformed to Corps expectations on what milestone data should be  in the system.

We estimated the median time it took the Corps to complete a feasibility  study for which an EIS was prepared. To do this, we obtained from the  Corps website the names of all feasibility studies completed with a Chief’s  Report from July 2008 through June 2018 and the dates they were  completed. We verified with Corps headquarters officials that its list of  studies with a Chief’s Report was current for that time frame. For each of  these feasibility studies, we then found the associated notice of intent to  complete an EIS as published in the Federal Register. While the date the  Corps filed a notice of intent to complete an EIS is not the initiation date  for the feasibility study, we used it as a proxy since Corps headquarters  officials said that, in the past, the notice of intent was filed soon after a  study was initiated. We calculated the time between the date the notice of  intent was filed and the date of the Chief’s report to arrive at an estimate  of the amount of time the each feasibility study took to complete. We then  calculated the median time it took to complete these feasibility studies.

Appendix II: U.S. Army Corps of Engineers Project Acceleration Statutory Provisions and Corps Actions Related to Each Provision

Appendix II: U.S. Army Corps of Engineers  Project Acceleration Statutory Provisions and  Corps Actions Related to Each Provision provides guidance, independently evaluates, and  approves the document before taking subsequent  action; and  ensures the project sponsor complies with all  design and mitigation commitments.

In addition, any NEPA documents prepared in this way  are to be adopted and used by any federal agency  when making any determination to the same extent  the agency could adopt or use a document prepared  by another federal agency under NEPA.

Category name  Coordination and Administration  Designating Jurisdictional Agencies  GAO summary of statutory provision  For all federal, state, and local governments and  Indian tribes that may have jurisdiction over a project  or that may be required to review some aspect of the  feasibility study or make a determination on issuing a  permit or other decision, the Corps must:  identify these agencies as early as practicable,  and  invite these agencies to participate or coordinate  as early as practicable and set a deadline for  response.

Corps actions related to provision  The Corps issued its WRRDA 2014  acceleration guidance in March 2018. as well as the  Principles and Guidelines and Planning  Guidance Notebook.

Any federal agency invited by the Corps will be  designated as a cooperating agency unless that  agency follows certain specified steps.

Plan for Coordinating Input and Completing  Environmental Review  The Corps, after consultation with and with the  concurrence of relevant entities is to establish a plan  for coordinating public and agency participation in, and  comment on, the environmental review process for  each feasibility study or category of studies. As soon  as practicable but not later than 45 days after the  close of the public comment period on a draft  Environmental Impact Statement (EIS), the Corps,  after consultation with and with the concurrence of  relevant entities, also is to establish, as a part of the  coordination plan, a schedule for completing the  environmental review process. In doing so, the Corps  is to consider certain factors, provide the schedule to  relevant entities, and make it available to the public.

The Corps issued its WRRDA 2014  acceleration guidance in March 2018. In  addition, a Corps official indicated that  portions of this provision are implemented  under the Corps’ NEPA procedures.

The Corps issued its WRRDA 2014  acceleration guidance in March 2018. not more than 60 days for agency or public  comment on a draft EIS, and  not more than 30 days for agency and public  comment on other environmental review  documents.

GAO summary of statutory provision  Issue Identification and Resolution  The Corps, the cooperating agencies, and any  participating agencies are required to work  cooperatively to identify and resolve issues that could  delay completion of the environmental review process  or result in the denial of any approval required for the  project study under applicable laws.

Corps actions related to provision  The Corps issued its WRRDA 2014  acceleration guidance in March 2018. In  addition, a Corps official indicated that  portions of this provision are implemented  under the Corps’ NEPA procedures and  Planning Guidance Notebook. Many  Corps district officials said they have used  various strategies, such as meetings, to  resolve issues with other agencies.

The Corps is to make information available to the  cooperating and participating agencies as soon  as practicable in the environmental review  process regarding the environmental and  socioeconomic resources located within the  project area and the general locations of the  alternatives under consideration.  Based on information from the Corps,  cooperating and participating agencies are to  identify as early as practicable any issues of  concern regarding the potential environmental or  socioeconomic impacts of the project, including  any issues that could substantially delay or  prevent an agency from granting a permit or  other approval that is needed for the project  study.

On the request of a participating or cooperating  agency or project sponsor, the Corps is to  convene an issue resolution meeting with the  relevant entities to resolve issues that may (1)  delay completion of the environmental review  process, or (2) result in denial of any approval  required for the project study under applicable  laws. Such a meeting is to be held not later than  21 days after the Corps receives the request for  the meeting unless the Corps determines there is  good cause to extend that deadline. Additionally,  the Corps may convene an issue resolution  meeting at its discretion, regardless of whether  such a meeting is requested.  If resolution cannot be achieved within 30 days of  an issue resolution meeting and the Corps  determines that all information necessary to  resolve the issue has been obtained, the Corps  is to forward the dispute to the heads of the  relevant agencies for resolution.

Corps actions related to provision  The Corps issued its WRRDA 2014  acceleration guidance in March 2018.

The Corps must notify the Senate Committee on  Environment and Public Works and the House  Committee on Transportation and Infrastructure  as soon as practicable. The Corps must continue  notifications every 60 days thereafter until all  decisions have been made by the federal  agency.  The amount of funds made available to support  the office of the head of that federal agency must  be reduced by certain specified amounts, subject  to certain limitations.

The Corps, NMFS, and FWS jointly issued  a coordination guide for conducting  feasibility studies in September 2015. The  Corps also issued its WRRDA 2014  acceleration guidance in March 2018.b In  addition, a Corps official indicated that  portions of this provision are implemented  under the agency’s NEPA procedures  and Planning Guidance Notebook,f as well  as the Principles and Guidelines.e

Upon request by a state or project sponsor, and  to the maximum extent practicable and  appropriate, as determined by the agencies, the  Corps and other federal agencies with relevant  jurisdiction in the environmental review process  are to provide technical assistance to the state or  project sponsor in carrying out early coordination  activities.  If requested by a state or project sponsor, the  Corps, in consultation with other federal agencies  with relevant jurisdiction, may establish  memoranda of agreement with certain entities to  carry out early coordination activities, subject to  certain limitations.

New Information  The Corps is to consider information received after the  close of a comment period if the information satisfies  the requirements for a supplemental EIS under NEPA  regulations.

The Corps issued its WRRDA 2014  acceleration guidance in March 2018.

With respect to the environmental review process for  any project study, the Corps is to have the authority  and responsibility to (1) take actions as are necessary  and proper and within the Corps’ authority to facilitate  the expeditious resolution of the environmental review  process for the project study, and (2) prepare or  ensure that any required EIS or other environmental  review document required to be completed under  NEPA is completed in accordance with applicable  federal law.

Publishing Information on Studies with Inadequate  Funding to Make Substantial Progress  The Corps is to annually prepare and make publicly  available a list of feasibility studies that the agency  does not have adequate funding to make substantial  progress toward the completion of the study.

The Corps has undertaken a multi-year  effort to focus funding on the feasibility  studies the agency determined are the  most viable options for Congressional  funding and then re-scope or deactivate  the remaining studies.

The Corps has not taken action as of May  2019. not later than June 10, 2015, establish and  maintain an electronic database and, in  coordination with other federal and state  agencies, issue reporting requirements to make  publicly available the status and progress with  respect to compliance with applicable  requirements of NEPA and other required  approval or action; and   publish the status and progress of any such  required approval or action on a feasibility study.

Categorical Exclusions  Not later than 180 days after June 10, 2014, the  Corps is to:  conduct an internal survey on its use of  categorical exclusions since 2005,  publish a review of the survey that includes a  description of certain specified information, and   solicit requests from other federal agencies and  project sponsors for new categorical exclusions.

As of May 2019, the Corps had conducted  an internal survey and solicited public  input through the Federal Register on its  procedures for implementing NEPA.  However, Corps headquarters officials  said they had not published a review of its  survey, targeted requests for new  categorical exclusions to other federal  agencies and nonfederal sponsors, or  proposed new exclusions as merited.

If the Corps identifies a category of activities that  merits establishing a new categorical exclusion, the  agency is also to propose new categorical exclusions  by June 10, 2015.

Performance Measurement  The Corps is to establish a program to measure and  report on progress made toward improving and  expediting the planning and environmental review  process.

The Corps has not taken action as of May  2019.

GAO summary of statutory provision  Guidance on Coordinated Environmental Review  The Corps, in consultation with the Council on  Environmental Quality and other federal agencies with  jurisdiction over actions or resources that may be  impacted by a project, is to prepare guidance  documents that describe the coordinated  environmental review processes that the Corps  intends to use to implement the reforms for the  planning of projects.

Corps actions related to provision  The Corps has not taken action as of May  2019. Corps officials said they have  reached out to the Council on  Environmental Quality several times and  are waiting for feedback on preparing this  guidance.

Guidance on Programmatic Approaches to  Environmental Review  The Corps is to issue guidance on the use of  programmatic approaches to carry out the  environmental review process that carries out  specified actions and meets specified requirements.

U.S. Army Corps of Engineers, Implementation Guidance for Section 1005 of the Water Resources  Reform and Development Act of 2014 (WRRDA 2014), Project Acceleration (Washington, D.C.:  March 2018).  Pub. L. No. 91-190, 83 Stat 852 (1970) (codified as amended at 42 U.S.C. §§ 4321-4347).

Appendix III: Comments from the Department of Defense

Appendix IV: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Vondalee R. Hunt (Assistant  Director), Candace Carpenter (Analyst in Charge), Matthew Levie, and  Rebecca Makar made key contributions to this report. In addition, Michael  Armes, Justin Fisher, Gwen Kirby, Patricia Moye, and Kiki  Theodoropoulos contributed to the report.

The Army Corps of Engineers undertakes water resources projects to reduce the risk of damage from coastal storms, among other things. The Corps first conducts a feasibility study to determine costs, benefits, and whether the project is in the federal interest. Such studies can take years. To accelerate feasibility studies, Congress and the Corps introduced reforms.

The Corps has not fully implemented recent reforms, evaluated the impact of its reforms, or maintained complete data on its feasibility studies.

We recommended developing plans to implement remaining reforms and evaluate the impacts of reforms, and taking other actions.


Presidential Helicopter: Program Continues to Make Development Progress While Addressing Challenges

The mission of the presidential helicopter fleet is to provide safe, reliable, and timely transportation in support of the President. The Navy plans to acquire a fleet of 23 VH-92A helicopters to replace the current Marine Corps fleet of VH-3D and VH-60N aircraft. Initial delivery of VH-92A presidential helicopters is scheduled to begin in fiscal year 2020 with production ending in fiscal year 2023. The total cost of this acquisition program was originally estimated at almost $5.2 billion.

The National Defense Authorization Act of 2014 included a provision for GAO to report on the VH-92A program annually, until the Navy awards the full-rate production contract. This report discusses (1) the extent to which the program is meeting its cost and schedule goals and (2) challenges facing the program in system development.

To determine how the program is progressing, GAO analyzed program documents; and spoke with officials from the program office, the Defense Contract Management Agency, contractors, Director, Operational Test and Evaluation, and Department of Defense, Developmental Test and Evaluation. GAO also assessed the program's integrated master schedule against GAO best practices.

Acquisition cost estimates for the Presidential Helicopter Replacement Program (also known as the VH-92A) have declined from $5.18 billion to $4.95 billion, for 23 new helicopters, since the program started in April 2014 (see table), and the program remains within its planned schedule. The contractor attributes this cost decrease to several factors: stable requirements, a low number of design changes, and program efficiencies.

The program has delayed some program milestones—for example, its low-rate production decision—by 5 months from its original baseline goal. Although this remains within the approved schedule, the program will have less time than planned between the end of development testing and start of operational assessment. Program officials told GAO they expect to have enough information from both the government-led integrated testing and the operational assessment to inform the low-rate production decision.

Continuing development challenges concerning performance requirements may affect whether the program can deliver fully capable aircraft on time in the future. These include:

VH-92A start procedures: As we reported last year, the VH-92A was pursuing technical improvements related to Sikorsky's S-92A propulsion system, which has yet to meet a VH-92A performance requirement. Program risk for this performance requirement has not changed since our April 2018 report on the program.

Landing zone suitability: As GAO found in 2018, the program has not yet met a key system capability requirement for landing the helicopter without damaging the landing zone—for example, the White House South Lawn. According to program officials, Sikorsky plans to have a solution for this performance requirement by November 2020 .

Mission communications system: The VH-92A program has experienced problems connecting the aircraft's communication system to secure networks, due to changes in network security requirements, presenting a new risk area for the program. The Navy anticipates having a fix by January 2020. These changes are expected to be incorporated into the four production representative helicopters being built under the development contract in time for the program's initial operational test and evaluation.

GAO is not making any recommendations in this report, but will continue to monitor the potential cost growth and schedule delays as the program responds to challenges meeting capability requirements.

The Navy’s VH-92A program is to replace the aging presidential  helicopter fleet, which has been in service for several decades. The VH- 92A program intends to provide new helicopters for safe, reliable, and  timely transportation for the President of the United States and other  parties as directed by the White House Military Office. The Navy plans to  acquire a fleet of 23 VH-92A helicopters to replace the Marine Corps’  existing fleet of VH-3D and VH-60N aircraft. The Navy’s acquisition  strategy is to integrate mature technologies and an executive interior into  an existing helicopter while minimizing modifications. Initial delivery of the  VH-92A helicopters is scheduled to begin in fiscal year 2020 with  production ending in fiscal year 2023.

The National Defense Authorization Act of 2014 included a provision for  GAO to report on the Presidential Helicopter program annually until the  Navy awards a contract for full-rate production, currently planned for  2021. In this report we discuss (1) the extent to which the program is  meeting cost, schedule, and performance goals and (2) challenges, if  any, the program has experienced in developmental testing and in  producing aircraft and plans for addressing the challenges.

To assess whether the program is achieving cost, schedule, and  performance goals, we compared cost estimates and program milestones  established at the start of development to current estimates and  milestone dates. These data were contained in defense acquisition  executive summary reports, selected acquisition reports, and program  briefings provided by the program office and Sikorsky Aircraft  Corporation, a Lockheed Martin Company (the prime contractor for the  program). We also examined and analyzed key acquisition documents  including contractor monthly status reports, earned value management  data, and Defense Contract Management Agency reports to determine  the performance and cost status of the development effort. We reviewed  the program’s Integrated Master Schedule (IMS) and compared it against  best practices criteria in the GAO Schedule Assessment Guide and discussed the results of our schedule assessment with VH-92A program  officials. To understand potential program challenges facing the program  in system development and steps taken to address those challenges, we  interviewed program officials from the Navy’s Presidential Helicopter  Program Office, as well as officials from the Defense Contract  Management Agency and from the offices of the Director, Operational  Testing and Evaluation, and Department of Defense (DOD),  Developmental Test and Evaluation to better understand the test and  evaluation aspects of the program. We analyzed data on program risks  and challenges obtained during our visits to the Navy’s Presidential  Helicopter Program office in Patuxent River, Maryland and the Lockheed  Martin facility in Owego, New York.

We conducted this performance audit from June 2018 to April 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit and obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

The Marine Corps uses a fleet of 23 helicopters to support the President  in the national capital region and when traveling in the continental United  States and overseas. These aircraft have been in service for decades. In  April 2002, the Navy began development of a replacement helicopter later  identified as the VH-71 program. By 2009, schedule delays, performance  issues, and a doubling of cost estimates, from $6.5 billion in 2005 to $13  billion in 2009, prompted the Navy to terminate the program.

The need for a replacement helicopter remained, and by April 2012, the  Office of the Secretary of Defense approved the Navy’s current  acquisition approach. The Navy’s approach is based on the modification  of an in-production aircraft to replace the legacy aircraft, by incorporating  an executive cabin interior and unique mission equipment such as  communications and mission systems, and limiting modifications to the  aircraft to avoid a costly airworthiness recertification.

In May 2014, the Navy awarded a fixed-price incentive (firm target)  contract to Sikorsky Aircraft Corporation, a Lockheed Martin Company,  for an Engineering and Manufacturing Development (EMD) phase. The  contract includes options for production quantities. The VH-92A  presidential helicopter is based on Sikorsky’s S-92A commercial  helicopter. The fixed- price incentive contract includes a ceiling price of  $1.3 billion that limits the maximum amount that the Navy may have to  pay the contractor under the contract subject to other contract terms.  The VH-92A is expected to provide improved performance, survivability,  and communications capabilities, while offering increased passenger  capacity when compared to the current helicopters.

Sikorsky is taking S-92A aircraft from an active production line (at the  Sikorsky plant in Coatesville, Pennsylvania) to a dedicated VH-92A  modification facility for subsystem integration at its plant in Stratford,  Connecticut. When the aircraft arrives from Coatesville, some  components, such as circuit breaker panels, engines, and main and tail  rotor blades are removed. After airframe modifications are done, the  aircraft is then transferred to the Sikorsky facility in Owego, New York,  where integration of the mission communications system, painting, and  contractor-led testing, installation of the executive cabin interior, and the  delivery of the aircraft will take place. See figure 1 for a depiction of  modification of the commercial S-92A aircraft to the VH-92A presidential  helicopter.

The VH-92A development program includes delivery of two Engineering  Development Model (EDM) test aircraft and four System Demonstration  Test Article (SDTA) aircraft. The first flight of the first EDM aircraft took  place in July 2017 and the second EDM aircraft’s first flight occurred in  November 2017. The two EDM aircraft are currently undergoing  government-led integrated testing, at Naval Air Station Patuxent River,  Maryland, and were used to conduct an operational assessment in March  2019 to support a decision on whether to enter low-rate initial production.  The four SDTA aircraft, now in the modification stages, are production  representative aircraft being built under the development contract. These  aircraft are to be used in the VH-92A’s initial operational test and  evaluation, which is planned to begin in March 2020. The results of that  testing will be used to inform a decision whether to enter full-rate  production in 2021. These SDTA aircraft will be used to determine  whether the VH-92A is operationally effective and suitable for its intended  use.

In July 2018, the Federal Aviation Administration certified the VH-92A  EDM-1 aircraft and supporting documentation to allow delivery to the  government under the contract.  According to the program office, the first  EDM VH-92A configured test aircraft arrived at Naval Air Station in  Patuxent River, Maryland, to begin government-led performance testing.  The program office explained that in December 2018, the contractor  provided VH-92A EDM-2, the second development aircraft, to the Navy  and it, too, is undergoing government testing.

VH-92A Cost Estimates Are Decreasing While Program Manages Its Schedule and Performance Goals

The VH-92A total program acquisition cost estimate has declined from  $5.18 billion to $4.95 billion (then-year dollars)—since the program  started in April 2014. Contractor officials attribute that the estimated  decline in cost is due to stable requirements, a low number of design  changes, and streamlined processes and reviews. The program has  incurred delays of about 5 months to the start of its operational  assessment due to parts shortages and early integration problems during  product development. Program officials told us they have adjusted  schedule milestones accordingly and now project that the VH-92A is on  track to meet its key performance parameters, including providing a fully  interoperable mission communications system (MCS) in time for initial  operational test and evaluation in 2020.

Cost Estimates Have Declined Due to Stable Requirements and Efficiency Gains

The Navy continues to reduce its acquisition cost estimate for the VH-92A  program. The total VH-92A program acquisition cost estimate has  decreased $234 million or about 4.5 percent—from $5.18 billion to $4.95  billion (then-year dollars)—since the program started in April 2014. The  total program acquisition unit costs have decreased by the same  percentage. According to the program office, this decrease is comprised,  in part, by reductions of approximately: $36 million for lower than expected inflation rates, $88 million for efficiencies gained during development, and $103 million for revised spare parts cost and equipment production  list.

A key factor in controlling total program acquisition cost has been  performance requirements stability. The Navy has not added any key  performance requirements to the fixed-price contract, thereby limiting cost  growth. In addition, the Navy and the contractor have been able to limit  the number of necessary design changes that require modifications to  aircraft. These modifications are now being incorporated into the four  production representative aircraft. The Navy is using an existing basic  ordering agreement with Sikorsky, separate from the VH-92A contract, for  two additional design changes that are not part of the baseline program.  These changes are to allow for improved visibility from the aircraft’s  forward door and the addition of a fifth multi-functional display in the  cockpit (which is identical to the existing four displays) to improve  situational awareness. The program office is working with the contractor  to determine the best time to make these modifications to the aircraft in  order to minimize the effect on the production schedule. The final costs  are still being negotiated; however, the program office expects the cost of  implementing these two engineering changes to be minimal relative to the  program’s total acquisition cost.

The Navy and contractor have also taken advantage of other cost saving  measures including streamlining some work processes and revised  testing approach for some components; they are also sharing secure  facilities used in support of the current presidential helicopter. In addition,  they eliminated activities deemed redundant to the Federal Aviation  Administration VH-92A airworthiness certification and plan to use a  streamlined reporting process for the March 2019 operational  assessment. According to program officials, the VH-92A has also  optimized its live fire test and evaluation program.

The Program Is Operating within Its Original Approved Schedule Baseline, Despite Experiencing Some Delays in Development

Overall, Sikorsky reported it had accomplished about 83.3 percent of  development work, with the remainder to be completed by October 2020.  As of February 2019, the contractor estimates it would have completed  nearly all of its activities necessary to demonstrate performance  specification compliance per the contract, by February 2019, and the  Navy is now more than halfway through its ground and flight testing  requirements needed to a support Milestone C, the decision point for  entering into low-rate initial production. The program has addressed  delays resulting from technical challenges and new discoveries during  development by delaying the start dates for the operational assessment,  the low-rate initial production decision, and initial operational test and  evaluation by 5 months each. The milestone start dates still meet the  baseline schedule thresholds.

As we found in the past, part shortages and the integration and assembly  effort taking longer than planned have all contributed to delays early in  the development of the two engineering development model aircraft. The  overall effect has been between 3 and 5 months of schedule delays. In  addition, some work initially allocated to the contractor’s site will now be  completed at the Naval Air Station, Patuxent River, Maryland. This is a  result of the contractor’s inability to get some parts when needed to  maintain the planned build schedule. According to the program office, the  Navy has implemented a number of mitigation strategies to reduce the  effect of the schedule slip, including leasing a commercial S-92A for pilot  training, reducing the duration of some future activities, adjusting the  program’s schedule, and reexamining and optimizing some work  processes to maintain the approved program baseline schedule.

We also found that the program’s integrated master schedule met the  best practices for a reliable schedule compared against best practices  criteria in the GAO Schedule Assessment Guide. The success of  programs depend, in part, on having an integrated and reliable master  schedule that defines when and how long work will occur and how each  activity is related to the others. Such a schedule is necessary for  government acquisition programs for many reasons. It provides not only a  road map for systematic project execution but also the means by which to  gauge progress, identify and resolve potential problems, and promote  accountability at all levels of the program. An IMS provides a time  sequence for the duration of a program’s activities and helps everyone  understand both the dates for major milestones and the activities that  drive the schedule. A program’s IMS is also a vehicle for developing a  time-phased budget baseline. Moreover, it is an essential basis for  managing tradeoffs between cost, schedule, and scope. Among other  things, scheduling allows program management to decide between  possible sequences of activities, determine the flexibility of the schedule  according to available resources, predict the consequences of managerial  action or inaction on events, and allocate contingency plans to mitigate  risks. Our research has identified 10 best practices associated with  effective schedule estimating that can be collapsed into 4 general  characteristics (comprehensive, well-constructed, credible, and  controlled) for sound schedule estimating. Overall, we found the  program’s IMS fully met one and substantially met three of the four  characteristics for sound schedule estimating.

Table 2 provides a comparison of the planned timeframe for key events at  development start to the current estimated schedule.

The Navy’s operational assessment began in March 2019 and ended  about 30 days later; this is nearly 2 months prior to the Milestone C  review, which will authorize low-rate initial production. The contractor’s  delivery of the first engineering development model aircraft to the  government was about a month late. A Developmental Test and  Evaluation official stated that this reduced the already short window of  time between the end of development testing and start of the operational  assessment. A Director, Operational Test and Evaluation official  responsible for monitoring the program expressed concern that there is  little time to address any new discoveries found during the operational  assessment. The program office acknowledged that, while solutions to  any newly discovered problems may not be ready to implement at the  start of production, it expects to have enough information from  government-led integrated testing and the operational assessment to  move forward with the Milestone C decision.

The Program Made Progress in Demonstrating Performance Goals through Planned Developmental Testing

According to the contractor, by February 2019, its test program for the  first two development aircraft will be nearly completed. In addition, as of  December 2018, the government completed about 48 percent of its  development ground and flight test points to support Milestone C but is  slightly behind, as it had planned to complete about 57 percent at this  time. Between August and December 2018, the program conducted  three major test events—the Navy conducted 14 landings on the White  House south lawn to assess approaches, departures, and operations in  the landing zone. The Navy also installed MCS version 2.0 on the second  EDM aircraft in support of the operational assessment and tested the  ability to transport the VH-92A in a cargo plane. Figure 2 shows the status  of government testing as of January 2019.

While the program has made progress, the VH-92A program continues to  face development challenges that could affect Sikorsky’s ability to deliver  fully capable aircraft prior to the start of initial operational test and  evaluation. Those challenges include issues associated with the aircraft’s  start procedures for the propulsion system, landing zone suitability, and  the aircraft’s mission communications system interoperability with secure  networks. According to the program office, the performance requirements  associated with these challenges may not be fully achieved until after the  low-rate initial production decision currently planned for June 2019, which  may result in a need to retrofit already built aircraft. Below is additional  information on each of those performance requirements.

VH-92A aircraft start procedures: As we reported last year, the VH- 92A was pursuing technical improvements related to the S-92A  propulsion system, which was not meeting a performance  requirement.  According to program officials, a previously identified  solution is no longer being pursued. However, these officials stated  that the program is continuing to assess current capabilities and both  material and non-material solutions to any potential capability  shortfalls. Testing to demonstrate aircraft performance against the  requirement will be completed prior to the Milestone C review in June  2019. Design changes, if needed, will be coordinated with program  stakeholders. Program risk for this performance requirement has not  changed since our April 2018 report on the program.

Landing zone suitability: The VH-92A operates in and out of a  variety of restrictive and highly visible landing zones. The White  House South Lawn is one of the most frequent locations utilized for  helicopter operations in support of the President. As we reported last  year, the program was not meeting a key system capability  requirement to land the aircraft without adversely affecting landing  zones (including the White House South Lawn). The program has  still not fully met this requirement and its assessment of this risk has  increased since our last report. According to program officials,  Sikorsky expects to have a solution for this requirement by November  2020.

Mission Communications System (MCS): The mission  communications system is a subsystem of the VH-92A aircraft that  provides on-board and off-board communications services for the  pilots, passengers, and crew. Currently, the VH-92A program has  experienced problems connecting the MCS to secure networks,  presenting a new risk area for the program. According to program  officials, the MCS cannot connect to required secure networks due to  recent changes in security protocols. Design changes will be needed  to permanently correct this problem. For the March 2019 operational  assessment, the program plans to connect to existing networks that  do not use the new security protocols. This allowed the operational  assessment to proceed but will limit the scope of testing. The Navy  plans to have a final fix by January 2020 that will then be incorporated  into the four production representative helicopters built under the  development contract. These changes have caused the Navy to delay  the start of the VH-92 initial operational test and evaluation by 3  months, a delay that is still within the approved program baseline  threshold, as discussed earlier.

We provided a draft of this report to DOD for review and comment. DOD  provided technical comments, which were incorporated as appropriate.

We are sending copies of this report to the appropriate congressional  committees, the Acting Secretary of Defense and the Secretary of the  Navy. In addition, the report is available at no charge on the GAO website  at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-4841 or sullivanm@gao.gov. Contacts points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix l.

Appendix l: GAO Contact and Staff Acknowledgments

In addition to the contract above, Bruce H. Thomas, Assistant Director;  Marvin E. Bonner; Bonita J. P. Oden: Peter Anderson, Juana S.  Collymore, Danny C. Royer, and Marie Ahearn made key contributions to  this report.

Presidential Helicopter: VH-92A Program Is Stable and Making Progress  While Facing Challenges. GAO-18-359. Washington, D.C.: April 30, 2018.

Defense Acquisitions: Assessments of Selected Weapon Programs.  GAO-17-333SP. Washington, D.C.: March 30, 2017.

Presidential Helicopter: Program Progressing Largely as Planned.  GAO-16-395. Washington, D.C.: April 14, 2016.

Presidential Helicopter Acquisition: Program Established Knowledge- Based Business Case and Entered System Development with Plans for  Managing Challenges. GAO-15-392R.Washington, D.C.: April 14, 2015.

Presidential Helicopter Acquisition: Update on Program’s Progress toward  Development Start. GAO-14-358R. Washington, D.C.: April 10, 2014.

Department of Defense’s Waiver of Competitive Prototyping Requirement  for the VXX Presidential Helicopter Replacement Program.  GAO-13-826R.Washington, D.C.: September 6, 2013.

Presidential Helicopter Acquisition: Program Makes Progress in  Balancing Requirements, Costs, and Schedule. GAO-13-257.  Washington, D.C.: April 9, 2013.

Presidential Helicopter Acquisition: Effort Delayed as DOD Adopts New  Approach to Balance Requirements, Costs, and Schedule.  GAO-12-381R. Washington, D.C.: February 27, 2012.

Defense Acquisitions: Application of Lessons Learned and Best Practices  in the Presidential Helicopter Program. GAO-11-380R. Washington, D.C.:  March 25, 2011.

The President relies on a fleet of helicopters for transportation that has been in service for decades. The Navy plans to replace this fleet with 23 new helicopters, called VH-92As.

Our annual review of this acquisition found

The estimated cost has declined from $5.18 billion to $4.95 billion since 2014. This was in part because there have been few design changes

The program remains within its overall schedule. However, delays will give program officials 3 to 5 months less time to evaluate whether they are ready to begin production

The program continues to work on challenges in communication links, and other areas