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Price Estimate for the Air Force's Aerial Refusing Aircraft Leasing 
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GAO-04-164R:

United States General Accounting Office:

Washington, DC 20548:

October 14, 2003:

The Honorable John Warner 
Chairman 
The Honorable Carl Levin 
Ranking Member 
Committee on Armed Services 
United States Senate:

Subject: Military Aircraft: Institute for Defense Analyses Purchase 
Price Estimate for the Air Force's Aerial Refueling Aircraft Leasing 
Proposal:

On September 4, 2003, we provided the Senate Committee on Armed 
Services our observations on the Air Force's proposed lease of 100 
Boeing 767 aircraft modified for aerial refueling, to be known as the 
KC-767A.[Footnote 1] At the hearing, the Committee heard testimony from 
the Institute for Defense Analyses (IDA) concerning the results of a 
study it did on the estimated acquisition cost of each 
aircraft.[Footnote 2] IDA concluded that $120.7 million was a 
reasonable price for a KC-767A aerial refueling aircraft. At the time 
of the hearing, we had just obtained access to the IDA study and were 
not in position to comment on it. On September 5, 2003, you asked us to 
analyze the IDA study and provide you our assessment. This letter 
responds to that request. Our objectives were to assess the 
reasonableness of IDA's approach to the issue of pricing the KC-767A 
aircraft and to provide any comments that we had on its methodology 
used to estimate the base prices and costs for each aircraft.

To analyze the IDA report, we reviewed the report submitted to the 
Office of the Under Secretary of Defense (Acquisition Technology and 
Logistics) and the Office of the Director, Program Analysis and 
Evaluation, Department of Defense (DOD).[Footnote 3] We met with the 
IDA (Cost Analysis and Research Division) and Air Force acquisition 
officials from the Office of the Assistant Secretary (Acquisition), 
Directorate of Global Reach. We also met with Office of Management and 
Budget officials to discuss the methodology, conclusions, and data used 
in IDA's analysis. In addition, we examined the Air Force's draft lease 
(which is still in negotiation and is subject to change) and reviewed 
documents and briefings from the Office of the Assistant Secretary of 
the Air Force for Acquisitions, Air Mobility Programs, to identify 
issues and costs that are related to the IDA study. Finally, we used 
data gathered for our review of the DOD response to your suggestion 
that the Air Force lease 25 aircraft and purchase 75[Footnote 4] and 
additional data gathered for our on-going review of tanker requirements 
being conducted for the House Armed Services Committee's Subcommittee 
on Readiness.

Summary:

We believe the IDA has provided a reasonable and comprehensive estimate 
within the stated objective and assumptions given by the study authors. 
The objective of the IDA study was to establish a reasonable direct 
purchase price for 100 KC-767A aircraft. (Refer to the enclosure for a 
description of the aircraft specifications as assessed by the IDA.) The 
IDA was not asked to and did not address or make any assumptions about 
provisions of the proposed lease, financing, suitability of leasing, or 
any other acquisition alternatives to the proposal. Further, the IDA 
did not attempt to reconcile its study results to coincide with the 
aircraft configuration currently being negotiated between the Air Force 
and Boeing.

Background:

The Department of Defense Appropriations Act for fiscal year 
2002[Footnote 5] included a provision allowing the Air Force to 
establish a multiyear pilot program for leasing Boeing 767 commercial 
aircraft to be used as aerial refueling aircraft. Aerial refueling 
provides a key capability in enhancing the mobility of U.S. forces and 
the Air Force is in the process of planning for the replacement of its 
aging aircraft fleet. As you know, the Air Force is in the final stages 
of negotiating a lease agreement with Boeing for 100 new 767 aircraft 
that will be modified for use as refueling aircraft.

While recognizing that aerial refueling is a key capability that is 
essential to the mobility of U.S. forces, the Senate Committee on Armed 
Services has raised many issues concerning the proposed Air Force 
lease, including questions about the validity of an independent DOD-
commissioned study performed by the Institute for Defense Analyses, a 
federally funded research and development center. The July 2003 IDA 
study entitled Purchase Price Estimate for the KC-767A Tanker Aircraft 
concluded that $120.7 million was a "conservative, robust" estimate of 
a reasonable purchase price for the proposed KC-767A aircraft.

The IDA Study and Our Assessment:

To determine the cost of acquiring 100 KC-767A aircraft and to 
formulate the associated assessment methodology and data sources, IDA 
first developed specific categories to describe the aircraft elements 
being priced. These categories,[Footnote 6] reflecting the most 
significant financial investments to the proposed aircraft purchase, 
were (a) basic B767-200ER aircraft, (b) enhanced B767-200ER features, 
(c) combination (so-called "combi") configuration modifications, (d) 
auxiliary fuel tanks, (e) tanker and other modifications, and (f) 
development costs. The Table provides a detailed summary of IDA's 
purchase price analysis.

Table 1: Summary of Institute for Defense Analyses' KC-767A Tanker/
Combi Purchase Price Analysis:

FY02 Dollars in millions.

Basic B767-200ER; IDA unit price estimate: 72.1; Primary 
analysis technique: Commercial pricing; Primary data sources: 
Consultants, Department of Transportation data.

Enhanced B767-200ER features; IDA unit price estimate: 1.6; 
Primary analysis technique: Commercial pricing; Primary data sources: 
Consultants, Boeing, Air Force data, IDA models, vendor quotes.

'Combi' modifications; IDA unit price estimate: 9.5; Primary 
analysis technique: Commercial pricing; Primary data sources: 
Consultants, public data.

Auxiliary fuel tanks; IDA unit price estimate: 6.3; Primary 
analysis technique: Cost analysis; Primary data sources: Vendor quotes, 
IDA models.

Tanker and other modifications; IDA unit price estimate: 20.3; 
Primary analysis technique: Cost analysis; Primary data sources: IDA 
models, Air Force, Boeing.

Development costs; IDA unit price estimate: 10.9; Primary 
analysis technique: Cost analysis; Primary data sources: Air Force, IDA 
models.

Total; IDA unit price estimate: 120.7.

Source: IDA and Air Force.

[End of table]

IDA separately estimated each of the above categories using a variety 
of estimating techniques including cost estimating relationships, cost 
models, and analogous data. In most cases, they used several techniques 
to generate multiple cost estimates of a single item. The IDA took an 
average of these estimates as the final estimate value in each 
category. Likewise, the IDA used commercial pricing techniques and 
marketing analysis where possible and traditional cost analysis 
techniques, as dictated by the content of the aircraft, where IDA 
determined that no significant commercial market existed.[Footnote 7] 
In addition, IDA's analysis relied on data from a variety of public 
sources, including other government sources, the analyses of consultant 
organizations hired by the IDA, data supplied by Boeing, other 
aerospace suppliers, and the Air Force. The specific categories and our 
conclusions about the reasonableness of the IDA analysis of each 
category follow:

* Basic B767-200ER: This element represents the cost to acquire the 
baseline aircraft, the commercial aircraft upon which the KC-767A is 
based. The necessary modifications and design changes would be applied 
to this aircraft. To determine the cost, the IDA gathered pricing 
information from five different commercial and government sources. 
These prices were then averaged to obtain the price used in the study. 
We believe this was a reasonable approach. In analytical terms, the 
coefficient of variance for the five data points used is very small (4 
percent), which shows the various estimates are close together and 
provides confidence in the estimate.[Footnote 8] We also note that data 
provided by the Air Force in October 2003 showed that they used six 
different methods to estimate the cost of the basic B767-200ER 
aircraft. The prices developed under the approaches ranged from $60.0 
million to $80.5 million per aircraft for an average of $71.1 million. 
Air Force officials ultimately used a weighted average and concluded 
that a reasonable price for the basic aircraft would be about $79.0 
million per aircraft.

* Enhanced B767-200ER features: This category includes features added 
to the basic aircraft to create the KC-767A. These items are not 
normally available on the 200ER variant of the B767 but have been 
specified by the Air Force for the KC-767A. However, Boeing has still 
not released its updated version of the system specifications 
negotiated for the B767-200ER aircraft variant. Each feature (e.g. 
enhanced cockpit, landing gear, and engines; upgraded power supply, 
etc.) was estimated separately using either commercially available 
information or IDA cost models. Again, given the complexity and 
assumptions associated with these engineering features, we believe the 
IDA's approach to be reasonable and comprehensive for estimating this 
element's cost.

* 'Combi' modifications: This element contains modifications to the 
baseline B767-200ER to allow the aircraft to transport passengers or 
freight, or a combination of the two simultaneously. To calculate this 
estimate, IDA performed three separate estimates and then took the 
average. Because this is a well-accepted and standard means to 
conducting analysis of this type, we believe this methodology 
represents a sound approach. Also, the coefficient of variation is very 
small (6 percent). This shows that the various estimates are close 
together and provides further confidence in the estimate.

* Auxiliary fuel tanks: This category provides for extra fuel capacity 
(i.e., the lower fuselage fuel tanks, pumps, and installation materials 
required to give the KC-767A additional fuel capacity). IDA solicited 
quotes from two different vendors to generate the estimate. The two 
quotes were averaged for the final result. Although, for assessment 
purposes, the quotes were further apart with a coefficient of variation 
of 34 percent, we believe they are only slightly above the rule of 
thumb for the range of reasonableness of about a 30 percent coefficient 
of variation.

* Tanker and other Air Force-unique modifications: This sub-grouping 
includes modifications associated with the refueling, fuel-receiving 
and military-unique capabilities. These modifications are associated 
with the ability to receive and offload fuel, including the 
installation of the centerline boom, the hose/drogue unit, the fuel 
receiving receptacle, the remote aerial refueling operator, and the 
plumbing and electrical changes associated with these items.[Footnote 
9] Avionics and miscellaneous Air Force requirements are also included 
in this category. The IDA separately estimated each modification that 
would occur. A cost estimating relationship was used to develop the 
final estimates, which were based on historical data collected by the 
IDA.[Footnote 10] We believe this to be a reasonable methodology and 
analytical tool for pricing this element.

* Development costs: This element, broken down into three sub-
categories, captures any non-recurring investment costs needed to 
design the KC-767A and represents the investment Boeing would make to 
create the KC-767A configuration. The IDA accepted Air Force data for 
most of the costs and used a cost estimating relationship to estimate 
the remainder. The IDA assumed that a portion of these development 
costs would be borne by the impending foreign sales to Italy and Japan 
and adjusted their estimate accordingly. We believe this is a 
reasonable approach for pricing this element.

In addition, as a further check on its assessment approach, the IDA 
enlisted an expert panel of former and/or retired distinguished Air 
Force officials to review its analytical approach and study methodology 
as well as its positions on a range of reasonable prices for the KC-
767A. IDA officials told us that the panel concurred with IDA's final 
report assessment and reporting results.

In its analysis, IDA used a December 19, 2002, system specification 
document identifying the KC-767A aircraft configuration. The notional 
aircraft is configured as a combination aerial refueling, cargo, and 
passenger aircraft designed to permit both freight hauling and 
passenger transport in the same mission. We provide a detailed 
description of the notional aircraft in appendix I. To obtain a lower 
negotiated price on the KC-767A aircraft, the Air Force has changed the 
specifications to eliminate the requirement that the aircraft be 
capable of passenger transport and cargo hauling on the same flight 
while retaining the other planned combi modifications.

Air Force and Office of Management and Budget Comments on the 
IDA Study:

Both the Air Force and Office of Management and Budget acknowledge that 
the IDA study was a useful and valuable tool used in negotiations with 
Boeing and believe it assisted the Air Force in negotiating a lower 
price for the 100 KC-767A aircraft leasing package. However, the Air 
Force believes that the IDA purchase price estimate did not have the 
"fidelity" or accuracy of its negotiation position with Boeing. Air 
Force officials told us that any line-by-line comparison of what 
individual items should cost between the IDA study results and those 
negotiated by the Air Force and Boeing is of limited value because the 
contract negotiation price was for 100 aircraft and each party would 
undoubtedly divide the pieces differently. However, the Air Force did 
not provide sufficient evidence to explain how negotiating for 100 
aircraft would necessarily lead to a higher price than the average unit 
price for 100 aircraft given that IDA did not assume that a volume 
discount would be given.

In addition, according to the Air Force, even if the IDA estimate 
proved correct and the price per aircraft were lower than the 
negotiated price, the government would be protected. Air Force 
officials pointed out that the contract as currently proposed includes 
a best price guarantee and a return-on-sales cap that enables the 
government to receive an equitable adjustment if Boeing's profit 
exceeds the cap. While the draft contract does include a "best price 
guarantee," this provision only guarantees that The Boeing Company will 
not sell comparable KC-767A aircraft for less than the Air Force would 
pay but it does not address the question of whether the Air Force could 
have obtained a lower price. Moreover, as we testified before the 
Senate Committees on Armed Services, and Commerce, Science and 
Transportation,[Footnote 11] it is not clear to us why the sales cap is 
15 percent as negotiated, when a financial analysis has concluded that 
Boeing's profit on commercial 767 aircraft is in the range of 6 
percent.[Footnote 12]

The Air Force also raised several other concerns with the IDA estimate 
surrounding different acquisition strategies used, different bases for 
estimates, etc. However, after review, we considered most of the 
differences to be inherent in the nature of IDA's tasking and not 
attributable to significant discrepancies or voids in information. For 
example, the IDA was directed to consider only the cost of a direct 
purchase price, not a leasing arrangement, so the IDA did assume a 
different acquisition strategy than the Air Force. However, the Air 
Force did not provide sufficient evidence to explain how a different 
acquisition strategy would necessarily lead to a different purchase 
price for the aircraft. Moreover, the cost estimates used by IDA to 
develop its purchase prices are applicable and also used by DOD cost 
estimators for both firm fixed price and cost contracts, and the 
planned lease of KC-767A aircraft is to be done under a firm fixed 
price contract.

Agency Comments and Our Evaluation:

In oral comments on a draft of this correspondence, representatives 
from the Air Force did not disagree with our analysis or our 
conclusions. However, these officials believe that they negotiated a 
reasonable price for the aircraft as planned to be configured by the 
Air Force and in the quantity to be delivered, and that the IDA 
estimate of $120.7 million per aircraft was not achievable. We do not 
know whether such a price is achievable because such analysis was 
outside the scope of our work.

In addition, officials from the Office of the Secretary of Defense and 
IDA generally concurred with our analysis and our report.

We conducted this work from September to October 2003 in accordance 
with generally accepted government auditing standards.

Unless you announce its contents earlier, we plan no further 
distribution of this letter until 10 days from its issue date. At that 
time, we will send copies of this letter to the chairman and ranking 
member of the Committee on Armed Services, House of Representatives, 
and the defense subcommittees of the Senate and House Committees on 
Appropriations. We will send a copy to the Chairman, Subcommittee on 
Readiness, House Committee on Armed Services, for whom we are 
conducting a broader body of work in this area. We will also send 
copies to the Secretary of Defense, the Director of the Office of 
Management and Budget, and the President of the Institute for Defense 
Analyses. We will also make copies available to other interested 
parties upon request. In addition, the letter will be available at no 
charge on the GAO Web site at http://www.gao.gov.

We appreciate this opportunity to be of assistance. If you or your 
staffs have any questions regarding this letter, please contact me at 
(202) 512-4914 or Brian J. Lepore, Assistant Director, at (202) 512-
4523. Other key contributors to this review were Ann M. Dubois, Joseph 
J. Faley, Jennifer K. Echard, Kenneth W. Newell, Madhav S. Panwar, 
Charles W. Perdue, Kenneth E. Patton, and Tim F. Stone.

Neal P. Curtin, Director 
Defense Capabilities and Management:

Signed by Neal P. Curtin: 

Enclosure:

[End of section]

Enclosure I: Description of Proposed Aircraft as Assessed by IDA:

The KC-767A tanker/combi aircraft (the aircraft can serve as an air-
refueling tanker, can carry freight or passengers, or can combine 
freight and passengers in the same mission) is to be based on the 
commercial B767-200ER.[Footnote 13] Modifications would include the 
addition of features available on other Boeing 767 models, as well as 
changes required for the military application. In the tanker role, 
total fuel capacity is to be just over 200,000 pounds, including up to 
41,000 pounds carried in added auxiliary fuel tanks. The KC-767A would 
have the capability to perform refueling by the hose/drogue and boom 
methods from the aircraft centerline and would also be able to receive 
fuel from other refueling aircraft. The cabin of the KC-767A would be 
convertible to three configurations. In the passenger configuration, 
the KC-767A would accommodate up to 190 passengers and 10 crewmembers. 
The freight configuration would accommodate 19 cargo pallets and 
10 crewmembers. The combination (so-called "Combi") configuration 
would have the capacity for 10 pallets, 10 crewmembers, and 
70 passengers, although this configuration has been dropped by the Air 
Force to reduce the price of the proposed aircraft.

FOOTNOTES

[1] Military Aircraft: Observations on the Proposed Lease of Aerial 
Refueling Aircraft by the Air Force. GAO-03-923T. Washington, D.C.: 
September 4, 2003.

[2] Purchase Price Estimate for the KC-767A Tanker Aircraft. IDA Paper 
P-3800. Alexandria, Virginia.: July 2003.

[3] These offices sponsored the IDA study.

[4] Military Aircraft: Observations on DOD's Aerial Refueling Aircraft 
Acquisition Options. GAO-04-169R. Washington, D.C.: October 14, 2003.

[5] Pub. L. No. 107-117, ยง 8159, 115 Stat. 2230, 2284-85.

[6] A detailed description of these categories may be found in the IDA 
report page S-2. 

[7] The Boeing Company has asserted that a commercial market does exist 
for its KC-767A aircraft.

[8] Coefficient of variation is a measure of dispersion. It is the 
ratio of the standard deviation to the arithmetic mean expressed as a 
percent. The smaller the number, the less the variation in the 
distribution and therefore the closer observations are to the mean.

[9] "Hose and drogue" or "probe and drogue" and "centerline boom and 
receptacle" refer to different types of refueling equipment systems 
used to refuel different types of aircraft in flight.

[10] A cost-estimating relationship is a cost function whose arguments 
are variables related to the performance of the items or to specific 
features of their designs.

[11] Military Aircraft: Observations on the Air Force's Plan to Lease 
Aerial Refueling Aircraft. GAO-03-1143T. Washington, D.C.: September 3, 
2003; and Military Aircraft: Observations on the Proposed Lease of 
Aerial Refueling Aircraft by the Air Force. GAO-03-923T. Washington, 
D.C.: September 4, 2003.

[12] Morgan Stanley, Does 767 Tanker Equate to 700+ Comml Orders?, (May 
30, 2003).

[13] System specification for Air Force KC-767A tanker transport 
aircraft, Boeing Integrated Defense Systems, December 19, 2002.