Building a 21st Century Infrastructure for America: Coast Guard Sea, Air, and Land Capabilities: Part II

Statement of

Ronald O'Rourke

Specialist in Naval Affairs

Before

House Transportation and Infrastructure Committee

Coast Guard and Maritime Transportation Subcommittee

Hearing on

Building a 21st Century Infrastructure for

America: Coast Guard Sea, Air, and Land

Capabilities: Part II

July 25, 2017

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https://crsreports.congress.gov

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Chairman Hunter, Ranking Member Garamendi, distinguished members of the subcommittee, thank you

for the opportunity to appear before you today to discuss building a 21st century infrastructure for

America: Coast Guard sea, air, and land capabilities.

As requested, my testimony focuses on Coast Guard ship acquisition. I have been working on military

ship acquisition issues for Congress for 33 years, including Coast Guard ship acquisition issues for almost

20 years.1 I currently maintain CRS reports for Congress on cutter acquisition and the polar icebreaker

program.2 For additional reference, this statement includes a summary of acquisition lessons learned for

Navy shipbuilding in Appendix A, and some considerations on the use of warranties in shipbuilding

contracts in Appendix B.

Funding Level for Coast Guard’s Acquisition (AC&I)

Account

Coast Guard Officials Now Regularly Mention a Figure of $2 Billion per

Year

Much of the discussion in recent years about Coast Guard acquisition has focused on past, current, and

potential future funding levels for the Coast Guard’s Acquisition, Construction, and Improvements

(AC&I) account. Coast Guard officials this year have begun stating regularly what they stated only

infrequently in previous years: that executing the Coast Guard’s various acquisition programs fully and on

a timely basis will require the AC&I account to be funded in coming years at a level of about $2 billion

per year. Statements from Coast Guard officials on this issue in past years have sometimes put this figure

as high as about $2.5 billion per year.3

Navy Shipbuilding Funding Requests Have Increased Substantially

During the Years of the BCA

An annual AC&I funding level of $2 billion or $2.5 billion per year would represent something like a

100% increase over requested amounts for the AC&I account in recent years. That may make the

achievement of a funding level of $2 billion or $2.5 billion per year look daunting.

By way of comparison, however, it can be noted that Navy in recent years has testified to a need for

substantially increasing the size of the Navy’s shipbuilding account—known formally as the Shipbuilding

and Conversion, Navy, or SCN, account—and that requested funding levels for this account have

increased substantially in recent years, notwithstanding the caps on defense spending under the Budget

Control Act (BCA). The Navy’s FY2013 budget—the first budget submitted after enactment of the BCA

in 2011—requested a total of $13.58 billion for the SCN account. Five years later, with the BCA, as

amended, still in place, the Navy’s FY2018 budget, as amended on June 29, 2017, requests a total $20.40

1 See, for example, CRS Report 98-830 F, Coast Guard Integrated Deepwater System: Background and Issues for Congress,

October 5, 1998, by Ronald O’Rourke.

2 CRS Report R42567, Coast Guard Cutter Procurement: Background and Issues for Congress, by Ronald O'Rourke, and CRS

Report RL34391, Coast Guard Polar Icebreaker Modernization: Background and Issues for Congress, by Ronald O'Rourke.

3 See, for example, the spoken testimony of Admiral Robert Papp, then-Commandant of the Coast Guard, before this

subcommittee on October 4, 2011, and remarks by Coast Guard Rear Admiral Mark Butt at the 2012 Navy League Sea Air Space

conference, as quoted in David Perera, “The Coast Guard Is Shrinking,” FierceHomelandSecurity.com, April 18, 2012.

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billion for the SCN account—an increase of about $6.8 billion, or about 50%, over the FY2013 requested

figure.

A 50% increase over the amount requested for the AC&I account for FY2013 ($1.217 billion) or the

amount requested for the AC&I account FY2018 ($1.204 billion) would equate to an AC&I funding level

of about $1.8 billion, which is fairly close to the figure of $2 billion being mentioned this year by Coast

Guard officials. Under the Coast Guard’s FY2013 budget submission, the AC&I account was projected to

increase to $1.722 billion by FY2017; under the service’s FY2017 budget submission, it was projected to

increase to $1.841 billion by FY2021.

Using Past AC&I Funding Levels as a Guide for Future AC&I Funding

Levels Poses Issues

In assessing future funding levels for executive branch agencies, a common practice is to assume or

predict that the figure in coming years will likely be close to where it has been in previous years. While

this method can be of analytical and planning value, for an agency like the Coast Guard, which goes

through periods with less acquisition of major platforms and periods with more acquisition of major

platforms, this approach might not always be the best approach, at least for the AC&I account.

More important, in relation to maintaining Congress’s status as a co-equal branch of government,

including the preservation and use of congressional powers and prerogatives, an analysis that assumes or

predicts that future funding levels will resemble past funding levels can encourage an artificially narrow

view of congressional options regarding future funding levels, depriving Congress of agency in the

exercise of its constitutional power to set funding levels and determine the composition of federal

spending.

Planned Force-Level Goals for New Cutters Have

Remained Unchanged Since to 2004

As I have noted in previous testimony and reports, the Coast Guard’s program of record for National

Security Cutters (NSCs), Offshore patrol Cutters (OPCs), and Fast Response Cutters (FRCs) includes

only about 61% as many cutters as the Coast Guard calculated in 2009 would be needed to fully perform

its projected future missions.4 The Coast Guard’s planned force levels for NSCs, OPCs, and FRCs have

remained unchanged since 2004. In contrast, the Navy since 2004 has adjusted its ship force-level goals

eight times in response to changing strategic and budgetary circumstances.5

Although the Coast Guard’s strategic situation and resulting mission demands may not have changed as

much as the Navy’s have since 2004, the Coast Guard’s budgetary circumstances may have changed since

2004. The 2004 program of record was heavily conditioned by Coast Guard expectations in 2004 about

future funding levels in the AC&I account. Those expectations may now be different, as suggested by the

willingness of Coast Guard officials this year to begin regularly mentioning the need for an AC&I funding

level of $2 billion per year.

4 See Appendix A of CRS Report R42567, Coast Guard Cutter Procurement: Background and Issues for Congress, by Ronald

O'Rourke.

5 See Table 1 and Table B-1 of CRS Report RL32665, Navy Force Structure and Shipbuilding Plans: Background and Issues for

Congress, by Ronald O'Rourke. As shown in those tables, the Navy’s force-level goal of 2002-2004 was followed by new forcelevel goals in early 2005, February 2006, mid-2011, September 2011, March 2012, January 2013, March 2015, and December

2016.

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More to the point, continuing to, in effect, use the Coast Guard’s 2004 expectations of future funding

levels for the AC&I account as an implicit constraint on planned force levels for NSCs, OPCs, and FRCs

can encourage an artificially narrow view of Congress’s options regarding future Coast Guard force levels

and associated funding levels, depriving Congress of agency in the exercise of its constitutional power to

provide for the common defense and general welfare of the United States, and to set funding levels and

determine the composition of federal spending.

Funding Coast Guard Ships Through Navy’s

Shipbuilding Account

As a supplemental means of funding the acquisition of Coast Guard ships, Congress has the option of

providing funding for the acquisition of Coast Guard ships through the SCN account. Although this

approach creates some complexity in tracking and executing funding for Coast Guard ship acquisition, it

has been used in the past. The Coast Guard’s medium polar icebreaker, Healy, was funded largely through

the SCN account,6 and the FY2017 Department of Defense appropriations act (Division C of H.R.

244/P.L. 115-31 of May 5, 2017) provided $150 million for the current polar icebreaker program.

On three occasions in recent years—in 2002, 2006, and 2013—Navy and Coast Guard leaders have

signed a joint National Fleet Policy Statement to provide (as stated in the 2013 edition) “direction and

guidance for our Services to achieve commonality and interoperability for 21st century maritime and naval

operations.” The document states that “This Policy is particularly important in light of: significantly

constrained fiscal resources; the growing costs of acquiring, training, and maintaining technologically

advanced forces; and the complexity and lethality of national security threats and challenges confronting

the Nation in and from the maritime domain.” It states further that “This Policy enables Navy and Coast

Guard forces to effectively and efficiently support each other while identifying specific methods and

measurements, avoid redundancies and achieve economies of scale to maximize our Nation’s investment

of increasingly scarce resources.”7

6 The somewhat complicated funding history for the ship is as follows: The Coast Guard’s proposed FY1990 budget requested

$244 million for the acquisition of an icebreaker. The FY1990 DOD appropriations act (H.R. 3072/P.L. 101-165 of November

21, 1989) provided $329 million for the ship in the SCN account. (See pages 77 and 78 of H.Rept. 101-345 of November 13,

1989.) This figure was then reduced by $4.2 million by a sequester carried out under the Balanced Budget And Emergency

Deficit Control Act of 1985, also known as the Gramm-Rudman-Hollings Act (H.J.Res. 372/P.L. 99-177 of December 12, 1985).

Another $50 million was rescinded by the Dire Emergency Supplemental Appropriations for Disaster Assistance, Food Stamps,

Unemployment Compensation Administration, and Other Urgent Needs, and Transfers, and Reducing Funds Budgeted for

Military Spending Act of 1990 (H.R. 4404/P.L. 101-302 of May 25, 1990). An additional $59 million for the ship was then

appropriated in the FY1992 DOD Appropriations Act (H.R. 2521/P.L. 102-172 of November 26, 1991). Also, an additional $40.4

million in acquisition funding for the ship was provided through a series of annual appropriations in the Coast Guard’s AC&I

account from FY1988 through FY2001. The resulting net funding for the ship was thus $374.2 million, of which $333.8 million,

or 89.2%, was DOD funding, and $40.4 million, or 10.8%, was Coast Guard acquisition funding. (Source: Undated Coast Guard

information paper provided to CRS by Coast Guard legislative liaison office, March 3, 2016.)

7 The National Fleet, A Joint Untied States Navy and United States Coast Guard Policy Statement, undated but issued in 2013.

Accessed July 17, 2017, at https://www.uscg.mil/seniorleadership/DOCS/National%20Fleet%20Policy%20%20signed%2025Jun13.pdf.

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OPC Program: Option for Reducing Cost Through

Multiyear Contracting

As I have testified previously to this subcommittee,8 the Navy in recent years, with congressional

approval, has made significant use of multiyear contracting (i.e., multiyear procurement [MYP] and block

buy contracting) in its shipbuilding and aircraft acquisition programs.9 Among other things, the Navy in

recent years has used multiyear contracting for all three of its year-to-year shipbuilding programs—the

Virginia-class attack submarine program, the DDG-51 destroyer program, and the Littoral Combat Ship

(LCS) program. These three programs account for more than two-thirds of all the ships in the Navy’s

five- year shipbuilding plans in recent years. Savings from the use of MYP recently have, among other

things, helped Congress and the Navy to convert a nine-ship buy of DDG-51 class destroyers in FY2013FY2017 into a 10-ship buy, and a nine-ship buy of Virginia-class attack submarines in FY2014-FY2018

into a 10- ship buy. The Navy is also now using block buy contracting in the John Lewis (TAO-205) class

oiler program.10 In contrast, the Coast Guard to date has not used multiyear contracting for its

shipbuilding or other acquisition programs.

As I have testified previously to this subcommittee, using multiyear contracting in the 25-ship OPC

program—specifically, block buy contracting with economic order quantity (EOQ) authority for the initial

ships in the program,11 followed by either block buy contracting with EOQ authority or multiyear

procurement (MYP) contracting for later ships in the program—rather than annual contracting might

reduce the total acquisition cost of the program by about $1 billion,12 a savings (which would accumulate

over time) equivalent to or a bit greater than the acquisition cost of either a polar icebreaker or a 35-ship

program to replace Coast Guard’s current 35-ship inland waterways fleet.

This potential savings of $1 billion represents a once-in-a-generation opportunity for using multiyear

contracting to reduce the cost of an individual Coast Guard acquisition program by such an amount. The

$1 billion in potential savings is considerably greater than the savings (discussed later in this statement)

that might be achieved by using multiyear contracting in the polar icebreaker acquisition program.

The Coast Guard is currently using a contract with options for acquiring the first nine ships in the OPC

program. Although a contract with options may look like a form of multiyear contracting, it is not an

8 See, for example, Statement of Ronald O'Rourke, Specialist in Naval Affairs, Before [the] House Transportation and

Infrastructure Committee, Coast Guard and Maritime Transportation Subcommittee Hearing on The Status of Coast Guard Cutter

Acquisition Programs, February 3, 2016, p. 5.

9 As I have testified previously, from a congressional perspective, tradeoffs in making greater use of multiyear contracting

include the following: reduced congressional control over year-to-year spending, and tying the hands of future Congresses;

reduced flexibility for making changes in acquisition programs in response to unforeseen changes in strategic or budgetary

circumstances (which can cause any needed funding reductions to fall more heavily on acquisition programs not covered by

multiyear contracts); a potential need to shift funding from later fiscal years to earlier fiscal years to fund EOQ purchases of

components; the risk of having to make penalty payments to shipbuilders if multiyear contracts need to be terminated due to

unavailability of funds needed for the continuation of the contracts; and the risk that materials and components purchased for

ships to be procured in future years might go to waste if those ships are not eventually procured. Congress has considered these

tradeoffs in deciding whether to grant the Navy authority for using multiyear contracting in the service’s shipbuilding and other

acquisition programs.

10 For additional discussion of multiyear contracting, see CRS Report R41909, Multiyear Procurement (MYP) and Block Buy

Contracting in Defense Acquisition: Background and Issues for Congress, by Ronald O'Rourke and Moshe Schwartz.

11 EOQ authority is authority to make up-front batch purchases of selected components of all the end items (in this case, ships)

that are to be acquired under the contract.

12 See, for example, Statement of Ronald O'Rourke, Specialist in Naval Affairs, Before [the] House Transportation and

Infrastructure Committee, Coast Guard and Maritime Transportation Subcommittee Hearing on The Status of Coast Guard Cutter

Acquisition Programs, February 3, 2016, p. 5.

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example of multiyear contracting. Contracts with options operate more like annual contracting, and they

do not achieve the savings that can be achieved through multiyear contracting. Acquiring the first nine

ships in the OPC program under the current contract with options could forego roughly $350 million of

the $1 billion in potential savings.

One option for the subcommittee would be to look into the possibility of having the Coast Guard either

convert the current OPC contract at an early juncture into a block buy contract with EOQ authority, or if

conversion is not possible, replace the current contract at an early juncture with a block buy contract with

EOQ authority.13 Replacing the current contract with a block buy contract might require re-competing the

program, which would require effort on the Coast Guard’s part and could create business risk for Eastern

Shipbuilding Group, the shipbuilder that holds the current contract. On the other hand, the cost to the

Coast Guard of re-competing the program would arguably be small relative to a potential additional

savings of perhaps $300 million, and Eastern arguably would have a learning curve advantage in any new

competition by virtue of its experience in building the first OPC.

OPC Program: Option for Increasing Procurement Rate

to Complete Program Sooner

The current procurement profile for the OPC, which reaches a maximum projected rate of two ships per

year, would deliver OPCs many years after the end of the originally planned service lives of the mediumendurance cutters that they are to replace. Coast Guard officials have testified that the service plans to

extend the service lives of the medium-endurance cutters until they are replaced by OPCs. There will be

maintenance and repair expenses associated with extending the service lives of medium-endurance

cutters, and if the Coast Guard does not also make investments to increase the capabilities of these ships,

the ships may have less capability in certain regards than OPCs.

One possible option for addressing this situation would be to increase the maximum annual OPC

procurement rate from the currently planned two ships per year to three or four ships per year. Doing this

could result in the 25th OPC being delivered about four years or six years sooner, respectively, than under

the currently planned maximum rate. Increasing the OPC procurement rate to three or four ships per year

would require a substantial increase to the Coast Guard’s AC&I account, which gets back to the issue

discussed earlier of future funding levels for that account and Congress’s agency in setting funding levels

and determining the composition of federal spending.

Increasing the maximum procurement rate for the OPC program could, depending on the exact approach

taken, reduce OPC unit acquisition costs due to improved production economies of scale. Doubling the

rate to four ships per year, for example, could reduce unit procurement costs by as much as 10%, which

could result in hundreds of millions of dollars in additional savings in acquisition costs for the program.

Increasing the maximum procurement rate could also create new opportunities for using competition in

the OPC program. Notional alternative approaches for increasing the OPC procurement rate to three or

four ships per year include but are not necessarily limited to the following:

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increasing the production rate to three or four ships per year at Eastern Shipbuilding—an

option that would depend on Eastern Shipbuilding’s production capacity;

introducing a second shipyard to build Eastern’s design for the OPC;

introducing a second shipyard (such as one of the other two OPC program finalists) to

build its own design for the OPC—an option that would result in two OPC classes; or

13 As part of the replacement scenario, the Coast Guard could end the implementation of the current contract with options by not

exercising an option.

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building additional NSCs in the place of some of the OPCs—an option that might include

de-scoping equipment on those NSCs where possible to reduce their acquisition cost and

make their capabilities more like that of the OPC. Such an approach would be broadly

similar to how the Navy is planning to use a de-scoped version of the San Antonio (LPD17) class amphibious ship as the basis for its planned LX(R) class amphibious ships.14

Polar Icebreakers: Option for Reducing Cost Through

Block Buy Contracting

In previous testimony and reports, I have provided estimates of the savings that might be achieved by

using block buy contracting rather than annual contracting for acquiring polar icebreakers. Most recently,

in my CRS report on the polar icebreaker program, I have estimated that using a block buy contract that

included EOQ purchases would reduce the combined acquisition cost of three heavy polar icebreakers by

upwards of 7%, which could equate to a savings of upwards of $200 million.

The new report on polar icebreaker acquisition from the National Academies of Sciences, Engineering,

and Medicine (NASEM) recommends acquiring four science-ready heavy polar icebreakers built in series

to a common design as the most cost-effective approach for meeting U.S. needs for both heavy and

medium polar icebreakers.15 The savings from using a block buy contract with EOQ purchases on such a

four-ship acquisition would be greater than the savings on a three-ship heavy polar icebreaker acquisition.

If policymakers decide to procure five or six science-ready heavy polar icebreakers built in series to a

common design, the savings of using block buy contracting with EOQ purchases could be greater still—

in a six-ship program, I estimate, the savings could exceed $400 million. The NASEM report notes that its

recommended approach would additionally avoid incurring the design and engineering costs (estimated in

the report at $126 million) for a separate class of medium polar icebreakers.

Inland Waterways Fleet

The Coast Guard is in the early stages of analysis for an anticipated recapitalization of the service’s inland

waterways fleet of river tenders, construction tenders, and inland buoy tenders. The Coast Guard has

testified that replacements for these tenders might cost about $25 million each.16

It is not clear yet whether the 35 existing tenders will need to be replaced on a strict one-for-one basis—

the Coast Guard is now examining that issue—but using the figure of $25 million, the total acquisition

cost of a 35-unit replacement program might be roughly $875 million, although this figure might be

reduced through use of multiyear contracting. Numerous U.S. shipyards—including shipyards that are not

capable of building the Coast Guard’s larger and more complex cutters—might be interested in bidding

for this program.

Mr. Chairman, this concludes my statement. Thank you again for the opportunity to testify, and I will be

pleased to respond to any questions the subcommittee may have.

14 For additional discussion, see CRS Report R43546, Navy John Lewis (TAO-205) Class Oiler Shipbuilding Program:

Background and Issues for Congress, by Ronald O'Rourke.

15 Division on Earth and Life Studies and Transportation Research Board of the National Academies of Sciences, Engineering,

and Medicine, Acquisition and Operation of Polar Icebreakers: Fulfilling the Nation’s Needs, Letter Report, cover letter dated

July 11, 2017, 147 pp.

16 Spoken testimony of Vice Admiral Sandra Stosz, Deputy Coast Guard Commandant, Mission Support, at a June 7, 2017,

hearing on Coast Guard Sea, Land and Air Capabilities before this subcommittee, as reflected in transcript of hearing.

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Appendix A. A Summary of Some Acquisition Lessons

Learned for Navy Shipbuilding

A general summary of lessons learned in Navy shipbuilding, reflecting comments made repeatedly by

various sources over the years, includes the following:

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

At the outset, get the operational requirements for the program right. Properly

identify the program’s operational requirements at the outset. Manage risk by not trying

to do too much in terms of the program’s operational requirements, and perhaps seek a

so-called 70%-to-80% solution (i.e., a design that is intended to provide 70%-80% of

desired or ideal capabilities). Achieve a realistic balance up front between operational

requirements, risks, and estimated costs.

Impose cost discipline up front. Use realistic price estimates, and consider not only

development and procurement costs, but life-cycle operation and support (O&S) costs.

Employ competition where possible in the awarding of design and construction

contracts.

Use a contract type that is appropriate for the amount of risk involved, and structure

its terms to align incentives with desired outcomes.

Minimize design/construction concurrency by developing the design to a high level of

completion before starting construction and by resisting changes in requirements (and

consequent design changes) during construction.

Properly supervise construction work. Maintain an adequate number of properly

trained Supervisor of Shipbuilding (SUPSHIP) personnel.

Provide stability for industry, in part by using, where possible, multiyear procurement

(MYP) or block buy contracting.

Maintain a capable government acquisition workforce that understands what it is

buying, as well as the above points.

Identifying these lessons is not the hard part—most if not all these points have been cited for years. The

hard part is living up to them without letting circumstances lead program-execution efforts away from

these.

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Appendix B. Some Considerations Relating to

Warranties in Shipbuilding and Other Defense

Acquisition

In discussions of Coast Guard (and also Navy) shipbuilding, one question that sometimes arises is

whether including a warranty in a shipbuilding contract is preferable to not including one.

Including a warranty in a shipbuilding contract (or a contract for building some other kind of defense end

item), while potentially valuable, might not always be preferable to not including one—it depends on the

circumstances of the acquisition, and it is not necessarily a valid criticism of an acquisition program to

state that it is using a contract that does not include a warranty (or a weaker form of a warranty rather than

a stronger one).

Including a warranty generally shifts to the contractor the risk of having to pay for fixing problems with

earlier work. Although that in itself could be deemed desirable from the government’s standpoint, a

contractor negotiating a contract that will have a warranty will incorporate that risk into its price, and

depending on how much the contractor might charge for doing that, it is possible that the government

could wind up paying more in total for acquiring the item (including fixing problems with earlier work on

that item) than it would have under a contract without a warranty.

When a warranty is not included in the contract and the government pays later on to fix problems with

earlier work, those payments can be very visible, which can invite critical comments from observers. But

that does not mean that including a warranty in the contract somehow frees the government from paying

to fix problems with earlier work. In a contract that includes a warranty, the government will indeed pay

something to fix problems with earlier work—but it will make the payment in the less-visible (but still

very real) form of the up-front charge for including the warranty, and that charge might be more than what

it would have cost the government, under a contract without a warranty, to pay later on for fixing those

problems.

From a cost standpoint, including a warranty in the contract might or might not be preferable, depending

on the risk that there will be problems with earlier work that need fixing, the potential cost of fixing such

problems, and the cost of including the warranty in the contract. The point is that the goal of avoiding

highly visible payments for fixing problems with earlier work and the goal of minimizing the cost to the

government of fixing problems with earlier work are separate and different goals, and that pursuing the

first goal can sometimes work against achieving the second goal.

The Department of Defense’s guide on the use of warranties states:

Federal Acquisition Regulation (FAR) 46.7 states that “the use of warranties is not mandatory.”

However, if the benefits to be derived from the warranty are commensurate with the cost of the

warranty, the CO [contracting officer] should consider placing it in the contract. In determining

whether a warranty is appropriate for a specific acquisition, FAR Subpart 46.703 requires the CO

to consider the nature and use of the supplies and services, the cost, the administration and

enforcement, trade practices, and reduced requirements. The rationale for using a warranty should

be documented in the contract file....

In determining the value of a warranty, a CBA [cost-benefit analysis] is used to measure the life

cycle costs of the system with and without the warranty. A CBA is required to determine if the

warranty will be cost beneficial. CBA is an economic analysis, which basically compares the Life

Cycle Costs (LCC) of the system with and without the warranty to determine if warranty coverage

will improve the LCCs. In general, five key factors will drive the results of the CBA: cost of the

warranty + cost of warranty administration + compatibility with total program efforts + cost of

overlap with Contractor support + intangible savings. Effective warranties integrate reliability,

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maintainability, supportability, availability, and life-cycle costs. Decision factors that must be

evaluated include the state of the weapon system technology, the size of the warranted population,

the likelihood that field performance requirements can be achieved, and the warranty period of

performance.17

Disclaimer

This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan shared staff

to congressional committees and Members of Congress. It operates solely at the behest of and under the direction of

Congress. Information in a CRS Report should not be relied upon for purposes other than public understanding of

information that has been provided by CRS to Members of Congress in connection with CRS’s institutional role.

CRS Reports, as a work of the United States Government, are not subject to copyright protection in the United

States. Any CRS Report may be reproduced and distributed in its entirety without permission from CRS. However,

as a CRS Report may include copyrighted images or material from a third party, you may need to obtain the

permission of the copyright holder if you wish to copy or otherwise use copyrighted material.

17

Department of Defense, Department of Defense Warranty Guide, Version 1.0, September 2009, accessed July 13, 2017, at

www.acq.osd.mil/dpap/pdi/ ... /departmentofdefensewarrantyguide[1].doc.

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