“The commission calls for the wholesale replacement of the PPBE system with a new “defense resourcing system” that aims to align the budget request more closely to strategy.“
“The almost 400-page report, published was written by the Commission on Planning, Programming, Budgeting and Execution (PPBE), draws on two years of research and more than 400 interviews, and resulted in 28 recommendations, half of which are denoted as key changes.
“The Pentagon requires a “fundamental restructuring” of its budget-making process and new authorities to make funding more flexible in order for the department to be able to quickly respond to new threats or adopt critically needed tech, according to a new report by congressionally mandated bipartisan commission.
Among them are reforms that would allow the Defense Department to address long-held complaints about the current budget process, including giving it new authorities to move money amongst weapons programs or to start new programs even while under a continuing resolution. That’s currently forbidden, and a CR, like the one the military is currently under, keeps spending exactly as it was the previous year.
While some of the recommendations can be immediately implemented by the Pentagon, others will need congressional approval or long-term buy-in from department leadership, said Ellen Lord, the commission’s vice chair and a former Pentagon acquisition chief.
“We believe we have a substantive document here with 28 very important recommendations that will all be for naught if we do not have implementation guidance from the department, as well as language from Congress,” she told reporters.
In a statement released this afternoon, Deputy Defense Secretary Kathleen Hicks commended the commission for their work but fell short of expressing support for any of the individual recommendations.
“The Department looks forward to evaluating the additional recommendations released by the PPBE Reform Commission today, in close cooperation with Congress, the Office of Management and Budget, and other stakeholders,” Hicks said.
Critics have slammed the current budget-making process for being slow and cumbersome, with the Pentagon beginning work on a budget about two years before funding is approved by Congress. That timeline can keep the Defense Department from being able to procure new tech like software and AI at the speed that they are made available in the commercial sector, the commission said.
“One of the most consistent concerns the commission heard over the past two years is that the current PPBE process lacks agility, limiting the department’s ability to respond quickly and effectively to evolving threats, unanticipated events and emerging technological opportunities,” the commission stated in the report.
At the same time, CRs and late budgets can also inhibit the department’s ability to start new programs or begin work on key initiatives.
The commission makes several other recommendations aimed at improving the flexibility of the budgeting process, such as raising the amount of funding that the Pentagon can shift among programs without needing congressional approval — known as below threshold reprogramming — and addressing “color of money” issues that can complicate buying software or make it difficult to replace the procurement of obsolescent parts with more widely available options.
One recommendation highly sought by some in the Pentagon would allow the department to carry over 5 percent of the budgets for operations and maintenance and military personnel into the following year, reducing the rush of spending that can occur by the military at the end of the year due to the current “use it or lose it” policy.
Another recommendation focuses on mitigating budgetary problems caused by a CR and would permit the Pentagon to begin a new start program or increase a production rate as laid out in a given budget request so long as the House and Senate appropriations committees had approved a bill including the new program or higher rate.
Robert Hale, the commission’s chairman and a former Pentagon comptroller, acknowledged that changes related to the carryover budget and CR could be a tough sell for Congressional appropriators, but added he believed the commission’s recommendations “balanced congressional oversight against some needed flexibility.”
The commission also calls for the creation of an analytic software platform that would crunch financial, contracting, logistics and readiness data “to allow decision makers to see the complete sight picture as never before, driving more meaningful decisions.”
The commission, which was created by Congress through fiscal 2022 National Defense Authorization Act, released an interim reportin August that called for 13 immediate reforms.
Deputy Secretary of Defense Kathleen Hicks said then that the Pentagon would begin adopting “all actions that can be implemented now, as recommended by the Commission and within its purview.”
The department released its implementation plan for the first 13 recommendations laid out in the interim report.”
Valerie covers the congressional and defense industry beat for Breaking Defense. Valerie has extensive national security reporting expertise, having served as the air warfare beat reporter for Defense News for five years. During that time her work was recognized by numerous awards, including the prestigious National Press Club Michael A. Dornheim Award for defense journalism. Valerie most recently covered commercial aerospace for Reuters. She also previously worked at Defense Daily and National Defense Magazine.
“Asking warriors to do everything poses great dangers for our country — and the military. Our armed services have become the one-stop shop for America’s policymakers.“
“When my mother came for lunch at the Pentagon, I shepherded her through the visitor’s entrance, maneuvered her onto the escalator, and had just ushered her past the chocolate shop when she stopped short. I stopped too, letting an army of crisply uniformed officers and shirt-sleeved civilians flow past us down the corridor. Taking in the Pentagon’s florist shop, the banks, the nail salon, and the food court, my mother finally looked back at me. “So the heart of American military power is a shopping mall?”
She wasn’t far off. By the time I started working at the Defense Department in the early years of the Obama administration, the Pentagon’s 17.5 miles of corridors had sprouted dozens of shops and restaurants catering to the building’s 23,000 employees. And, over time, the U.S. military has itself come to offer a similar one-stop shopping experience to the nation’s top policymakers. At the Pentagon, you can buy a pair of new running shoes or order the Navy to search for Somali pirates.
At the Pentagon, you can buy a pair of new running shoes or order the Navy to search for Somali pirates.
You can grab some Tylenol at CVS or send a team of Army medics to fight malaria in Chad. You can buy yourself a new cell phone or task the National Security Agency with monitoring a terrorist suspect’s text messages. You can purchase a small chocolate fighter jet or order up drone strikes in Yemen.
You name it, the Pentagon supplies it. As retired Army Lt. Gen. Dave Barno once put it to me, the relentlessly expanding U.S. military has become “a Super Walmart with everything under one roof” — and two successive presidential administrations have been eager consumers.
But the military’s transformation into the world’s biggest one-stop shopping outfit is no cause for celebration. On the contrary, it’s at once the product and the driver of seismic changes in how we think about war, with consequent challenges both to our laws and to the military itself.
Here’s the vicious circle in which we’ve trapped ourselves: As we face novel security threats from novel quarters — emanating from nonstate terrorist networks, from cyberspace, and from the impact of poverty, genocide, or political repression, for instance — we’ve gotten into the habit of viewing every new threat through the lens of “war,” thus asking our military to take on an ever-expanding range of nontraditional tasks. But viewing more and more threats as “war” brings more and more spheres of human activity into the ambit of the law of war, with its greater tolerance of secrecy, violence, and coercion — and its reduced protections for basic rights.
Meanwhile, asking the military to take on more and more new tasks requires higher military budgets, forcing us to look for savings elsewhere, so we freeze or cut spending on civilian diplomacy and development programs. As budget cuts cripple civilian agencies, their capabilities dwindle, and we look to the military to pick up the slack, further expanding its role.
“If your only tool is a hammer, everything looks like a nail.” The old adage applies here as well. If your only functioning government institution is the military, everything looks like a war, and “war rules” appear to apply everywhere, displacing peacetime laws and norms. When everything looks like war, everything looks like a military mission, displacing civilian institutions and undermining their credibility while overloading the military.
More is at stake than most of us realize. Recall Shakespeare’s Henry V:
In peace there’s nothing so becomes a man
As modest stillness and humility:
But when the blast of war blows in our ears,
Then imitate the action of the tiger;
Stiffen the sinews, summon up the blood,
Disguise fair nature with hard-favour’d rage…
In war, we expect warriors to act in ways that would be immoral and illegal in peacetime. But when the boundaries around war and the military expand and blur, we lose our ability to determine which actions should be praised and which should be condemned.
For precisely this reason, humans have sought throughout history to draw sharp lines between war and peace — and between the role of the warrior and the role of the civilian. Until less than a century ago, for instance, most Western societies maintained that wars should be formally declared, take place upon clearly delineated battlefields, and be fought by uniformed soldiers operating within specialized, hierarchical military organizations. In different societies and earlier times, humans developed other rituals to delineate war’s boundaries, from war drums and war sorcery to war paint and complex initiation rites for warriors.
Like a thousand other human tribes before us, we modern Americans also engage in elaborate rituals to distinguish between warriors and civilians: Our soldiers shear off their hair, display special symbols on their chests, engage in carefully choreographed drill ceremonies, and name their weapons for fearsome spirits and totem animals (the Hornet, the Black Hawk, the Reaper). And despite the changes ushered in by the 9/11 attacks, most of us view war as a distinct and separate sphere, one that shouldn’t intrude into our everyday world of offices, shopping malls, schools, and soccer games. Likewise, we relegate war to the military, a distinct social institution that we simultaneously lionize and ignore. War, we like to think, is an easily recognizable exception to the normal state of affairs and the military an institution that can be easily, if tautologically, defined by its specialized, war-related functions.
But in a world rife with transnational terrorist networks, cyberwarriors, and disruptive nonstate actors, this is no longer true. Our traditional categories — war and peace, military and civilian — are becoming almost useless.
In a cyberwar or a war on terrorism, there can be no boundaries in time or space: We can’t point to the battlefield on a map or articulate circumstances in which such a war might end. We’re no longer sure what counts as a weapon, either: A hijacked passenger plane? A line of computer code? We can’t even define the enemy: Though the United States has been dropping bombs in Syria for almost two years, for instance, no one seems sure if our enemy is a terrorist organization, an insurgent group, a loose-knit collection of individuals, a Russian or Iranian proxy army, or perhaps just chaos itself.
We’ve also lost any coherent basis for distinguishing between combatants and civilians: Is a Chinese hacker a combatant? What about a financier for Somalia’s al-Shabab, or a Pakistani teen who shares extremist propaganda on Facebook, or a Russian engineer paid by the Islamic State to maintain captured Syrian oil fields?
When there’s a war, the law of war applies, and states and their agents have great latitude in using lethal force and other forms of coercion. Peacetime law is the opposite, emphasizing individual rights, due process, and accountability.
When we lose the ability to draw clear, consistent distinctions between war and not-war, we lose any principled basis for making the most vital decisions a democracy can make: Which matters, if any, should be beyond the scope of judicial review? When can a government have “secret laws”? When can the state monitor its citizens’ phone calls and email? Who can be imprisoned and with what degree, if any, of due process? Where, when, and against whom can lethal force be used? Should we consider U.S. drone strikes in Yemen or Libya the lawful wartime targeting of enemy combatants or nothing more than simple murder?
When we heedlessly expand what we label “war,” we also lose our ability to make sound decisions about which tasks we should assign to the military and which should be left to civilians.
Today, American military personnel operate in nearly every country on Earth — and do nearly every job on the planet. They launch raids and agricultural reform projects, plan airstrikes and small-business development initiatives, train parliamentarians and produce TV soap operas. They patrol for pirates, vaccinate cows, monitor global email communications, and design programs to prevent human trafficking.
Many years ago, when I was in law school, I applied for a management consulting job at McKinsey & Co. During one of the interviews, I was given a hypothetical business scenario: “Imagine you run a small family-owned general store. Business is good, but one day you learn that Walmart is about to open a store a block away. What do you do?”
“Roll over and die,” I said immediately.
The interviewer’s pursed lips suggested that this was the wrong answer, and no doubt a plucky mom-and-pop operation wouldn’t go down without a fight: They’d look for a niche, appeal to neighborhood sentiment, or maybe get artisanal and start serving hand-roasted chicory soy lattes. But we all know the odds would be against them: When Walmart shows up, the writing is on the wall.
Like Walmart, today’s military can marshal vast resources and exploit economies of scale in ways impossible for small mom-and-pop operations. And like Walmart, the tempting one-stop-shopping convenience it offers has a devastating effect on smaller, more traditional enterprises — in this case, the State Department and other U.S. civilian foreign-policy agencies, which are steadily shrinking into irrelevance in our ever-more militarized world. The Pentagon isn’t as good at promoting agricultural or economic reform as the State Department or the U.S. Agency for International Development — but unlike our civilian government agencies, the Pentagon has millions of employees willing to work insane hours in terrible conditions, and it’s open 24/7.
It’s fashionable to despise Walmart — for its cheap, tawdry goods, for its sheer vastness and mindless ubiquity, and for the human pain we suspect lies at the heart of the enterprise. Most of the time, we prefer not to see it and use zoning laws to exile its big-box stores to the commercial hinterlands away from the center of town. But as much as we resent Walmart, most of us would be hard-pressed to live without it.
As the U.S. military struggles to define its role and mission, it evokes similarly contradictory emotions in the civilian population. Civilian government officials want a military that costs less but provides more, a military that stays deferentially out of strategy discussions but remains eternally available to ride to the rescue. We want a military that will prosecute our ever-expanding wars but never ask us to face the difficult moral and legal questions created by the eroding boundaries between war and peace.
We want a military that can solve every global problem but is content to remain safely quarantined on isolated bases, separated from the rest of us by barbed wire fences, anachronistic rituals, and acres of cultural misunderstanding. Indeed, even as the boundaries around war have blurred and the military’s activities have expanded, the U.S. military itself — as a human institution — has grown more and more sharply delineated from the broader society it is charged with protecting, leaving fewer and fewer civilians with the knowledge or confidence to raise questions about how we define war or how the military operates.
It’s not too late to change all this.
No divine power proclaimed that calling something “war” should free us from the constraints of morality or common sense or that only certain tasks should be the proper province of those wearing uniforms. We came up with the concepts, definitions, laws, and institutions that now trap and confound us — and they’re no more eternal than the rituals and categories used by any of the human tribes that have gone before us.
We don’t have to accept a world full of boundary-less wars that can never end, in which the military has lost any coherent sense of purpose or limits. If the moral and legal ambiguity of U.S.-targeted killings bothers us, or we worry about government secrecy or indefinite detention, we can mandate new checks and balances that transcend the traditional distinctions between war and peace. If we don’t like the simultaneous isolation and Walmartization of our military, we can change the way we recruit, train, deploy, and treat those who serve, change the way we define the military’s role, and reinvigorate our civilian foreign-policy institutions.
After all, few generals actually want to preside over the military’s remorseless Walmartization: They too fear that, in the end, the nation’s over-reliance on an expanding military risks destroying not only the civilian competition but the military itself. They worry that the armed services, under constant pressure to be all things to all people, could eventually find themselves able to offer little of enduring value to anyone.
Ultimately, they fear that the U.S. military could come to resemble a Walmart on the day after a Black Friday sale: stripped almost bare by a society both greedy for what it can provide and resentful of its dominance, with nothing left behind but demoralized employees and some shoddy mass-produced items strewn haphazardly around the aisles.”
Rosa Brooks is a law professor at Georgetown University and a senior fellow with the New America/Arizona State University Future of War Project. She served as a counselor to the U.S. defense undersecretary for policy from 2009 to 2011 and previously served as a senior advisor at the U.S. State Department. Her most recent book is How Everything Became War and the Military Became Everything.
This article has been updated to adjust the amount of the national debt from what was $16 Trillion in 2012 when we first began our Pentagon critique to what is now in excess of $34 Trillion.
Ask yourself if there are not other alternatives for the future of our country, to include statesmanship, and international economic cooperation to cease warfare and weaponizing efforts among great nations.
We offer not only our opinion on the massive Military Industrial Complex, but also the opinions of three experts who have lived war fighting – on the recent fields of battle, and in weapons systems development.
The quotations are extracts from larger articles. We suggest the reader follow the links after each to become further informed.
It is our hope that the facts offered here will contribute to the knowledge of US citizenry regarding hard decisions forthcoming on the nature of war fighting and its role in the future of our country.
OUR VIEW
This site was founded in 2006, based on the 36 years experience in war zones and major corporations in the US Military Industrial Complex. Our view is expressed in the below article, an extract of which reads:
“Presidents, Congressmen, Cabinet Members and Appointees project a knowledgeable demeanor but they are spouting what they are told by career people who never go away and who train their replacements carefully. These are military and civil servants with enormous collective power, armed with the Federal Acquisition Regulation, Defense Industrial Security Manuals, compartmentalized classification structures and “Rice Bowls” which are never mixed.
Our society has slowly given this power structure its momentum which is constant and extraordinarily tough to bend. The cost to the average American is exorbitant in terms of real dollars and bad decisions. Every major power structure member in the Pentagon’s many Washington Offices and Field locations in the US and Overseas has a counterpart in Defense Industry Corporate America. That collective body has undergone major consolidation in the last 20 years. What used to be a broad base of competitive firms is now a few huge monoliths, such as Lockheed Martin, General Dynamics, Northrop Grumman, Raytheon and Boeing, with neat stacks of exclusive, dedicated subcontractors under each. The stacked pricing load of these arrangements is enormously expensive.
Government oversight committees are carefully stroked. Men like Sam Nunn and others who were around for years in military and policy oversight roles have been cajoled, given into on occasion but kept in the dark about the real status of things until it is too late to do anything but what the establishment wants. This still continues – with increasing high technology and potential for abuse.”
Paul Riedner is a graduate of the University of Minnesota’s Carlson School of Management. and personally, sacrificed four years in support of war effort — one deployed as an army engineer diver.
“There remain countless inner struggles that lurk in dark corners of my psyche. They are difficult to measure or even explain.
What does it mean to have been a part of this war?
To have been a part of: 4,500 American deaths; 33,000 Americans wounded; estimates as high as 600,000 Iraqi deaths; more than $1 trillion in taxpayer money spent; $9 billion lost or unaccounted for; huge corporate profiteering; a prisoner-abuse scandal; a torture record worthy of the Hague; a hand in the financial crisis, and runaway unemployment when we get home.
I’ve learned that we are easily duped and that we quickly forget. Saddam has WMDs. No, we are exporting democracy. No, we are protecting human rights, and by the way, their oil will pay for it all.
I’ve learned that 9/11 was used against us. We gladly handed over our civil liberties in the name of security. And recently our Congress quietly reapproved the unconstitutional Patriot Act.”
Lieutenant-Colonel Daniel L. Davis was on active duty in the United States Army, serving as a Regular Army officer in the Armor Branch when he wrote this article. He had just completed his fourth combat deployment. (Desert Storm, Afghanistan in 2005-06, Iraq in 2008-09, and Afghanistan again in 2010-11). In the middle of his career he served eight years in the US Army Reserve and held a number of civilian jobs, one of which was an aide for US Senator Kay Bailey Hutchison (Legislative Correspondent for Defense and Foreign Affairs).
From “Dereliction of Duty II
Senior Military Leaders’ Loss of Integrity Wounds Afghan War Effort 27 January 2012”
“We have lavished praise a few of our senior military leaders for being “warrior-scholars” whose intellectualism exceeds those of most wearing the uniform. But what organization in the world today – whether an international terrorist organization or virtually every major company on the globe – needs physical territory on which to plan “future 9/11 attacks”? Most are well acquainted with the on-line and interconnected nature of numerous global movements. We here in the United States know video conferencing, skyping, emailing, texting, twittering, Facebooking, and virtually an almost limitless number of similar technologies.
And a few men have convinced virtually the entire Western world that we must stay on the ground in one relatively postage-stamp sized country – even beyond a decade and a half – to prevent “another 9/11” from being planned, as though the rest of the world’s geography somehow doesn’t matter, and more critically, that while the rest of the world does its planning on computers and other electronic means, al-Qaeda must be capable only of making such plans on the ground, and only on the ground in Afghanistan.
When one considers what these few leaders have asked us to believe in light of the facts pointed out above, the paucity of logic in their argument becomes evident. What has been present in most of those arguments, however, has been emotionally evocative words designed to play strongly on American patriotism: “…this is where 9/11 was born!” “these young men did not die in vain” “this is a tough fight” etc. It is time – beyond time – for the evidence and facts to be considered in their comprehensive whole in a candid and honest public forum before we spend another man or woman’s life or limbs in Afghanistan.”
Franklin C. “Chuck ” Spinney Pentagon’s Office of Program Analysis and Evaluation (better-known by its former name, Systems Analysis, set up to make independent evaluations of Pentagon Policy)
Author – “Defense Facts of Life: The Plans-Reality Mismatch”, which sharply criticized defense budgeting, arguing that the defense bureaucracy uses unrealistic assumptions to buy in to unsustainable programs, and explaining how the pursuit of complex technology produced expensive, scarce and inefficient weapons. Spinney spent his career refining and expanding this analysis. The report was largely ignored despite a growing reform movement, whose goal was to reduce military budget increases from 7% to 5% after inflation. Two years later, he expounded on his first report, including an analysis on the miscalculation of the burden costs of a majority of the weapon systems and re-titled it “Defense facts of life: The Plans/Reality Mismatch”, which later became simply known as the “Spinney Report”:
“And that’s why we ought to treat the defense industry as a public sector; and if we did that then you wouldn’t see these gross disparities in salaries creeping in. But essentially if you try to understand what’s going on in the Pentagon and this is the most important aspect, and it gets at the heart of our democracy. Is that we have an accounting system that is unauditable. Even by the generous auditing requirements of the federal government.
Now what you have to understand is the kind of audits I’m talking about these are not what a private corporation would do with a rigorous accounting system. Essentially the audits we are required to do are mandated under the Chief Financial Officers Act of 1990, and a few amendments thereafter. But it’s the CFO Act of 1990 that’s the driver.
And it basically was passed by Congress that required the inspector generals of each government department, not just the Pentagon, but NASA, health, education, welfare, all the other departments, interior department where the inspector general has to produce an audit each year. Saying, basically verifying that the money was spent on what Congress appropriated it for. Now that’s not a management accounting audit. It’s basically a checks and balances audit.
Well, the Pentagon has never passed an audit. They have 13 or 15, I forget the exact number, of major accounting categories. That each one has it’s own audit. The only one of those categories that’s ever been passed is the retirement account.
Now under the CFO Act of 1990 they have to do this audit annually. Well, every year they do an audit and the inspector general would issue a report saying we have to waive the audit requirements, because we can’t balance the books. We can’t tell you how the money got spent.
Now what they do is try to track transactions. And in one of the last audits that was done the transactions were like… there were like $7 trillion in transactions. And they couldn’t account for about four trillion of those transactions. Two trillion were unaccountable and two trillion they didn’t do, and they accounted for two trillion.”
The material here is submitted on its own merits. Consider it carefully as the Pentagon has consumed nearly 70% of US disposable tax revenue in recent years and our national debt exceeds $34 Trillion. National Debt Clock
Ask yourself if there are other alternatives for the future of our country, to include statesmanship, international economic cooperation and de-weaponizing efforts among great nations.
Military pay raises have been minimal, recruiting has fallen considerably below target in the services. How do we acquire, train and retain what we need? Reserves and National Guard involve long term multiple deployments with no assurance of a future for those who return.
What is the mix of technology and manpower required to fight today’s wars? The following are 3 perspectives from experts: Can YOU answer the Citizen’s Question at the end?
Mark Seip a senior Navy fellow at the Atlantic Council recently noted the cultural and conception gap that exists between America and it volunteer armed forces:
“From the military side, many of us feel that we are unique to our generation in our calling; that we rose above the self-absorbed stereotype often associated with both Gen Xers and Millennials to protect our nation. We accept significant time away from our families, often subpar working conditions compared to our civilian counterparts, and average pay in relation to the skills we possess in order to wear the uniform. Moreover, as our nation’s warrior corps we assume a level of risk since time immemorial, that our occupation entails a distinct possibility of loss of life. Our service therefore requires a level of confidence and self-assurance to do our jobs and take the risks required.
Second, the widening gap is a function of exposure, both in numbers and in proximity. As Fallows points out, 2.5 million served in either Iraq or Afghanistan. To provide context, according to an NPR study 8.7 million served in some capacity in Vietnam. Furthermore, during Vietnam the majority of the generation at that time had fathers and mothers who served in some capacity either in WWII, Korea or both. Today, however, the actual number and/or the tangential family tie to the military is lower, reinforcing the distance between those in service and the rest of the nation.”The Military/Civilian Gap
PERSPECTIVE 2 – From a Military Contractor
Eric Prince, the former CEO of Black Water continues to insist that private security employees working for the U.S. government in warzones should be tried under the Uniform Code of Military Justice, instead of the civilian criminal justice system.
“It’s quite different for a jury that is 7,000 miles away from the warzone, looking at a split-second decision made seven years earlier in a warzone, minutes after a large car bomb goes off.” Prince said he hopes the guards’ convictions can be successfully appealed. “The last chapter is not written yet.”
Although he quit the business, Prince still sees a future for the private security business.
“The world is a much more dangerous place, there is more radicalism, more countries that are melting down or approaching that state.” At the same time, the Pentagon is under growing pressure to cut spending and the cost of the all-volunteer force keeps rising, Prince said.
“The U.S. military has mastered the most expensive way to wage war, with a heavy expensive footprint.” Over the long run, the military might have to rely more on contractors, as it will become tougher to recruit service members. Prince cited recent statistics that 70 percent of the eligible population of prospective troops is unsuitable to serve in the military for various reasons such as obesity, lack of a high school education, drug use, criminal records or even excessive tattoos. In some cases, Prince said, it might make more sense to hire contractors.”Eric Prince on Future Wars
PERSPECTIVE 3 – From a Military Analyst
“DEFENSE ONE” Notes:
“The film “American Sniper” about legendary Navy SEAL sniper Chris Kyle broke box office records this holiday season when the picture earned a million dollars in five days on only a handful of screens. It is time we grappled with America’s actual wars and their real-time, life and death consequences, once again with as much dedication as we line up to watch them play out on the big screen.
The military may be fighting a war. Or wars. But we, as a country, are not.In USA Today’s list of its most read articles of 2014, neither the war in Afghanistan nor the simmering fight in Iraq – to which U.S. troops are headed back – cleared the top 10. The same is true for Yahoo’s list of its most searched stories. No Iraq or Afghanistan in sight.
It is nearly inconceivable but somehow true that in the 2013 government shutdown, death benefits for the families of those killed in action fighting for the United States also shut off.”The Movies Vs. Real War
Citizen’s question: Could or should we reinstate the draft?
“THE PROJECT ON GOVERNMENT OVERSIGHT (POGO) “The Bunker” – By Mark Thompson)“
“The GAO’s latest 259-page opus https://www.gao.gov/assets/gao-23-106059.pdf says that between 2020 and 2022, the number of major weapons the Pentagon was buying dropped from 84 to 75, an 11% reduction.
Nonetheless, that smaller number of programs’ total cost ticked up by 1%, and took 7% longer to deliver. Programs Are Not Consistently Implementing Practices That Can Help Accelerate Acquisitions”
The Bunker just might as well hang up his helmet and call it a day. The Government Accountability Office’s 21st annual report(PDF) on Pentagon procurement reads like TheBunker’s Greatest Hits, echoing the lethargic inagility and bad decisions that have plagued U.S. defense procurement for decades. Sure, the GAO isn’t always right. But The Bunker relied on the General Accounting Office’s work for decades before it renamed itself in 2004 due to its expanding mission. “Moving beyond financial audits, GAO began conducting performance audits — examining how government programs were performing and whether they were meeting their objectives,” the agency says.
You can bet your bottom taxpayer dollar that the Defense Department wishes the GAO had stuck to its historical bean-counting, and didn’t worry its little green-eyeshaded head about what those beans were buying. Bottom line: Its often dire Generally Accurate Observations are routinely better than the Pentagon’s.
The GAO’s latest 259-page opus says that between 2020 and 2022, the number of major weapons the Pentagon was buying dropped from 84 to 75, an 11% reduction. Nonetheless, that smaller number of programs’ total cost ticked up by 1%, and took 7% longer to deliver. Such numbers, compounded annually, mean the Pentagon is spending more to get less, later.
The study, issued June 8, says the costs of 35 major weapons programs surged by $37 billion (4%)(PDF) over the past year, after adjusting for inflation. “Rising modernization costs, production inefficiencies, and supply chain challenges drove the majority of costs,” the report said.
“Over half of the 26 major defense acquisition programs GAO assessed that had yet to deliver operational capability reported new delays,” it added. “Driving factors included supplier disruptions, software development delays, and quality control deficiencies.”
It’s worth pointing out that neither China nor Russia has its own GAO that regularly publicly publishes such warts-and-all reports on their military efforts. “Sunlight is said to be the best of disinfectants,” Louis Brandeis wrote in 1913, three years before joining the Supreme Court. He was speaking of the power of disclosure “in the struggle against the Money Trust,” but such klieg lights are just as critical when it comes to U.S. national security.
The Bunker has never been able to understand the national security state’s fevered belief that weapons designed without such public and independent scrutiny are going to take the U.S. military to the cleaners. For you kiddos, the dictionary definition of being “taken to the cleaners” means “to deprive (someone) of a large amount of money.” Plainly the U.S. has the world’s cleanest taxpayers.”
“NATIONAL DEFENSE MAGAZINE” By Cari Shearer and Jacob Winn
“Science-and-technology programs received more than $22 billion in direct appropriations across the Defense Department — more than 18 percent above fiscal year 2022 funding, and nearly $6 billion more than what was requested for 2023.”
“After a late budget request and multiple continuing resolutions, President Joe Biden signed into law a full-year omnibus appropriations act for the 2023 fiscal year — with increased funding for defense science and technology programs.
These additions — commonly referred to as congressional earmarks — when informed by industry or university technical and defense market expertise, and aligned with transition opportunities, can represent an expedited path through the otherwise cumbersome traditional programming and budgeting process.
This can make the programs funded by this year’s increases more responsive to threats, technological opportunity or program realities. That said, earmarks are still no substitute for well-planned budget requests and consistent levels of funding.
This year’s science-and-technology appropriations gave well-deserved focus to emerging technologies, especially those recognized by the Defense Department as critical technology areas that range from seed areas like quantum science, to effective adoption sectors like artificial intelligence and microelectronics, as well as defense-specific technologies like hypersonic and directed energy systems.
Taken together, these funding increases may go a long way toward helping the department develop and procure more systems. To understand these trends, the Emerging Technologies Institute is developing a capability to track budget and appropriations data to allow the National Defense Industrial Association and its members to better monitor these critical investments and the opportunities they represent to develop and deliver new defense technologies.
The S&T budget includes the funding provided to the services and defense agencies, including the Defense Advanced Research Projects Agency and the Missile Defense Agency, to support basic research, applied research and advanced technology development activities.
These research-and-development programs fund scientific inquiry and breakthroughs as well as engineering and early prototyping activities intended to transition into formal acquisition efforts and operational use. Breakthroughs stemming from defense research and development are rooted in defense needs but can have far-reaching impacts for the commercial world when they advance academia and industry’s knowledge in domains like materials science, biology or renewable energy.
Measuring the percentage of the defense budget’s topline that goes toward science and technology is a popular metric for defense analysts trying to determine whether the Defense Department is over- or under-investing in its future capabilities. Many say 3 percent of topline funding is the ideal goal. In 2023, S&T received just under 2.8 percent of the topline. While this still falls short of the ideal, it represents the most significant year since the funding last met the 3 percent target in 2007 — and much higher than 2022’s 2.16 percent.
On top of that, Congress allocated more than $150 million for military construction to modernize military lab and test center infrastructure.
Basic research activities, typically performed at universities, received nearly $3 billion, a 5.7 percent increase over fiscal year 2022 levels. Much of this extra funding was provided through grants for university research on priorities like artificial intelligence and material science, fields that are crucial to maintaining a technological edge over peer competitors.
Applied research activities fared even better. These programs received nearly $8 billion, an almost 13 percent increase over 2022. This includes added investments for projects related to offensive hypersonics, operational energy, biotechnology and additive manufacturing.
Of the three categories of defense S&T, advanced technology development activities received almost $11 billion, nearly 26 percent more than 2022. These programs typically fund industry technology demonstrations and early prototypes. While Congress is on the right track by funding more of these projects, there are still perceived gaps in the Pentagon’s ability to establish a predictable pathway into formal acquisition programs. The requirements-based, funding, contracting, market, organizational and cultural barriers to technology transition are commonly captured under the simple term: “valley of death.”
To help the department overcome these challenges and be more responsive to emerging technology opportunities, Congress did set aside some additional funding outside the S&T budget activities to transition successful projects into production. That included an approval of the administration’s request for a major investment in the Rapid Defense Experimentation Reserve Fund of more than $300 million.
Additionally, Congress provided the Accelerate the Procurement and Fielding of Innovative Technologies program $150 million for procurement activities, a 50 percent increase over the request. This funding should be continued in future years as it will likely benefit contractors, especially small businesses, whose work on breakthrough technologies would otherwise not lead them to a military customer.
To maintain U.S. innovation, the Biden administration and Congress should continue to prioritize S&T funding next year. Additionally, the Defense Department should work to better plan the transition paths for high-priority science-and-technology efforts into prototyping and acquisition and build its budget accordingly.
Legislators should also consider making S&T goals and thresholds more explicit. They should explore the efficacy of requesting an annual list of underfunded areas from the department.
A regression to the mean in future years would lead to canceled or delayed research and development projects, fewer rapid developments, missed opportunities and more programs languishing in the valley of death.”
“It’s groundbreaking because never before has there been an institute dedicated solely to [Pentagon] performance improvement,” Deputy Defense Secretary Kathleen Hicks said at the launch event.
“Management reform advances the entire department, including acquisition, technology ― all of which are essential to the department’s mission and to directly support the warfighter.”
“The U.S. Defense Department, a mammoth federal agency long criticized even from within as inefficient and overly complex, is embarking on a new step toward improving how it conducts its affairs.
The department launched the Defense Management Institute, an independent research entity aimed at advancing the Pentagon’s management, organization, performance improvement and enterprise business operations. Proponents said the entity, part of the nonprofit Institute for Defense Analyses, will have a far-reaching impact as it pools experts and past research for officials and lawmakers to solve problems or retool the department.
The new launch comes amid fresh calls in Congress to cut the Pentagon’s budget. House Speaker Kevin McCarthy, R-Calif., has signaled his support for some cuts in defense spending amid growing tension within the House GOP ranks over the party’s approach to a coming fight over the debt limit.
The $858 billion national defense budget makes up half of all discretionary federal spending, but cutting it could mean unwinding some of the world’s most complex bureaucracies. The Defense Department not only employs a massive array of troops and civilians, but it operates around the globe with a medical system, a school system, an internal intelligence agency and grocery chain.
Officials say the Defense Management Institute, or DMI, will not only conduct studies and analyses on behalf of the department but also build a public library of past management reform studies and reports spanning the Pentagon’s own boards and commissions, as well as academic institutions and think tanks.
“Future generations of the department should not have to start from scratch. This institute will help them solve problems more quickly and efficiently,” Hicks said.
DMI would also bring together and link defense officials to the loose community of experts in the field, which includes former Pentagon employees, congressional staffers and private sector management consultants.
DMI plans to tackle a major job, right off the bat, when it conducts a review of the effectiveness of defense agencies and field activities, which Congress mandated in the 2023 defense policy bill. These components, among the most complex parts of the department, have periodically been targeted for cuts by lawmakers.
Defense budget expert Todd Harrison said the new organization could fast become a go-to source of ideas and analysis to identify waste and inefficiency in defense, or potentially reassure fiscal conservatives that investments in defense are well spent.
But a key factor in its success will be how well it can establish its intellectual independence from the Institute for Defense Analyses and Pentagon leadership, he added.
“I think it is a significant step in terms of creating the institutional momentum for sustaining a focus on better management and performance across the defense enterprise,” said Harrison, the managing director at Metrea Strategic insights. “This creates an organization and a body of people whose full-time job will be building the intellectual basis for better decision making, [but it] must be willing to speak truth to power to be credible.”
The DMI launch is arguably the most public step in the realm of defense management reform since Congress in 2020 eliminated the Pentagon’s chief management officer job, four years after establishing it as DoD’s No. 3 position.
The department has since dispersed the CMO’s duties and responsibilities among different officials. Hicks is the DoD’s management chief, while the lead for department reform is former Air Force Secretary Michael Donley, who is both the department’s current director of administration and management as well as its performance improvement officer.
Donley, who spearheaded the launch of DMI, said one of the key goals is to translate private sector practices and experience to the Pentagon.
Among performance improvement efforts under the Biden administration, Hicks said she and Defense Secretary Lloyd Austin have expanded the role of the Defense Business Council and pushed the broader use of data analytics to inform decision-making.
To harness big data, the DoD developed an internal application, called Pulse, in less than five months, which Hicks said would set the pace for similar efforts.
“The secretary will have a far better view of implementation of the [National Defense Strategy] than our predecessors were ever afforded,” she said. “This dashboard approach will give us data-driven insights into what’s working and what stuck and what we can do about it.”
Joe Gould is the senior Pentagon reporter for Defense News, covering the intersection of national security policy, politics and the defense industry. He served previously as Congress reporter.
“The situation in Ukraine is providing a “teachable moment” for why it matters that the Defense Department accomplish a clean audit that establishes it has an accurate count of everything its purchased. The Pentagon has failed its annual audit for the fifth year in a row.
During the process — which covers more than $3.5 trillion in Defense Department assets — about 1,600 auditors conducted 220 in-person site visits and 750 virtual site visits, reviewing business processes, counting pieces of equipment and pouring over 29,000 documents, according to the Pentagon.“
__________________________________________________________________________________________________”The “The Pentagon has failed its annual audit for the fifth year in a row, an expected result that nonetheless represents something of a disappointment for an effort that officials hoped would continue steady, if incremental, year over year progress.
Of the 27 military agencies audited, seven received a clean audit and one received a qualified opinion — a term used to describe an audit that will be clean after resolving a key issue. That’s “basically the same picture as last year,” Pentagon Comptroller Mike McCord told reporters on Tuesday ahead of the audit’s release.
The ultimate result of the audit was “a disclaimer of opinion,” a technical term that denotes when an auditor cannot give an opinion, essentially indicating that the audit did not come back clean.
“I would not say that we that we flunked,” McCord said. “The process is important for us to do, and it is making us get better. It is not making us get better as fast as we want.”
The Pentagon also held steady on the number of material weaknesses found during the audit, which measures deficiencies in accounting procedures. Specifically, the latest audit discovered three new material weaknesses while consolidating six previously-established weaknesses into three issues, for a total of 28 material weaknesses.
“Not the progress I would have hoped for,” McCord said. “We had hoped to get one or two of those knocked off.”
However, McCord also noted advancements in certain areas, specifically in the use of big data software like Advana, which uses automated “bots” to crunch numbers and reduce financial management tasks — helping reduce the workload for the Pentagon’s financial management staff and ensure that information captured is accurate.
Altogether, McCord characterized the department’s progress as “somewhat modest” and although he expects future audits to show continued improvement, he cautioned it will take time.
“We are seeing people invest in systems, and analytics and things like that I think are going to pay off. But at the same time, it’s fair to say that we have some challenges, in particular, on putting a value on inventory. That is still a pretty big hill for us to climb,” he said.
The comprehensive Defense Department audit is comprised of 27 different audits performed by independent firms, which are then consolidated into the overall audit by the DoD Inspector General.
The Pentagon has failed every audit since 2018, the first audit of the department ever performed in its history. In 2020, the Pentagon’s acting comptroller Thomas Harker signaled that the department could begin to pass its annual audit as early as 2027, but McCord said last year that the department isn’t close enough to that date to know for sure whether that goal is viable.
McCord said audits can help detect fraud and, when clean, can improve taxpayer confidence in the Pentagon’s financial processes. However, he noted that the Pentagon has other mechanisms to root out wasteful spending that the audit cannot capture.
“Not to undervalue the audit, but in fairness, passing an audit doesn’t tell you that you spent the money wisely, it shows that you can match the records of the obligations in the financial system to the contracts,” he said.
At the same time, the situation in Ukraine is providing a “teachable moment” for why it matters that the Defense Department accomplish a clean audit that establishes it has an accurate count of everything its purchased.
“We’ve not been in in in a conflict with a peer competitor — a kinetic conflict — as Ukrainians are with the Russians,” McCord said. “We’ve not been in a position where we’ve got only a few days of some critical munition left. But we are now supporting a partner who is. And so when they appeal to us for help and say, ‘I’ve got a week’s worth left of something. …When can you get me more?’ that’s, to me, a really great example of why it matters to give this sort of thing right.”.
Valerie covers the air warfare beat for Breaking Defense while also serving as point person for major Pentagon policy and strategy developments. Valerie has extensive national security reporting expertise, having served as the air warfare beat reporter for Defense News for five years. During that time her work was recognized by numerous awards, including the prestigious National Press Club Michael A. Dornheim Award for defense journalism. She previously worked at Defense Daily, National Defense Magazine, and spent two years as the Washington correspondent for the Tokyo Chunichi Shimbun. A graduate of the renowned University of Missouri-Columbia journalism program.
“BREAKING DEFENSE” – By Aaron Mehta, Editor In Chief
The GAO’s Weapon System Annual Assessment found broad concerns about the defense industrial base.GAO picked 29 Major Defense Acquisition Projects (MDAPs) to study for potential delays. Of those, 17 — over half — reported project delays in the last year; nine had also suffered program delays in the previous year.
In terms of the industrial base, of the 59 programs surveyed by GAO, 38 reported they were tracking at least one industrial base risk — with more than half reporting multiple risks, and 15 of the programs reporting those industrial base challenges said they contributed to program cost and schedule changes.
“The Columbia-class submarine program jumped billions in price, the Air Force’s T-7A trainer has a bird problem, and cyber concerns remain prevalent across the department, according to a newly-released report by the Government Accountability Office.
GAO does not study every single Pentagon weapon system, instead seeking to find a representative segment; it also has something of a time delay, with research having been completed primarily in 2021. Still, the annual report is considered a key overview to provide lawmakers and the public with a sense of how the DoD is spending taxpayer money.
Among the programs that have faced delays since the last GAO report
VC-25B Presidential Aircraft: “The program projects a delay due to the contractor transitioning to a new supplier and other issues, which requires the program to develop a new baseline,” GAO found.
CVN 78 Gerald Ford carrier: “The program reported a 21-month delay in its December 2019 Selected Acquisition Report. In September 2021, the program reported an additional delay due to issues with the ship’s Advanced Weapons Elevators.”
MQ-4c Triton UAV: “The program reported a 16-month delay in its December 2019 Selected Acquisition Report. Program officials reported an additional delay due to technical problems.”
Next Generation Jammer Mid Band: “The program reported a delay due to a design issue with a test pod, which required a redesign to support flight testing. The issue was first discovered in 2019, but the program did not anticipate at the time that it would affect testing.”
Improved Turbine Engine Program: “The program reported nearly a 16-week delay due to material or supplier delays as a result of COVID-19 challenges. In addition, the program reported that the contractor is experiencing higher than anticipated costs due to COVID-19 and is currently negotiating an equitable adjustment. Program officials stated they did not know the total effect on costs as of August 2021.”
To better help with tracking the issues, GAO is asking DoD to update its “industrial base assessment instruction to define the circumstances that would constitute a known or projected problem or substantial risk that a necessary industrial capability may be lost.”
The report also features a number of interesting nuggets from various different programs. For instance, the Air Force is concerned about pilot safety if its new T-7A trainer were to hit a bird of a certain side.
“In June 2021, the program began tracking a risk related to protecting the pilot in the event of hitting a 4-pound bird during certain flight conditions,” the GAO found. Specifically, officials told us that the program needs to ensure the aircraft’s windshield will survive the impact of hitting a bird of this size in flight. Mitigating this risk by working to correct the root cause may lead to additional schedule delays, which program officials told us they are willing to accept to ensure pilot safety. Program officials told us that mitigations include minor redesign of the windshield area.”
Cybersecurity concerns are spread throughout the report, with a particularly eye-catching issue with the F-15EX raised by the watchdog.
“The program continues to track a cybersecurity vulnerability risk stemming from the F-15EX design, derived from FMS aircraft and, according to the program, not designed to U.S. Air Force cybersecurity requirements,” the GAO found. “The program office plans to bring subject matter experts together in April 2022 to conduct a tabletop exercise in which they talk through how they would respond to simulated scenarios in identifying vulnerabilities. Subsequently, the program office plans to conduct other cybersecurity assessments, with results from the tabletop exercise determining the scope and dates of these additional assessments.”
And of course, the cost increase on the Columbia-class — the first of which, the USS District of Columbia, saw a keel-laying ceremony over the weekend — may draw the ire of lawmakers.
“The Navy updated its acquisition program baseline in 2021 and its estimated acquisition costs increased by over $3.4 billion since our last assessment,” GAO found. “This increase reflects the August 2020 independent cost estimate for the whole class, expenditures on the supplier base, missile tubes that required costly rework, poor contractor performance during design, and updated construction costs, among other things.
“Program officials stated that Electric Boat, Newport News Shipbuilding, and a missile tube supplier experienced inefficiencies in 2020 due to COVID-19. However, the shipbuilders prioritized Columbia class work over other programs at the shipyards, which minimized additional cost and schedule implications.”
“Though many of today’s national-security discussions are focused on the war in Ukraine or congressional action on the 2023 budget, a far more important, strategic, and bureaucratic battle is taking place inside the Pentagon over the 2024 program build.“
“From the quick consumption of weapons in Ukraine to rising inflation, the current resourcing plan is untenable.
For those who are unfamiliar with Pentagon jargon and timelines: from January to July, the services build their five-year budget proposals, called “the Program.” Since the 2023 budget now lies with Congress, the armed services are currently building the 2024-29 Program, which will be submitted to the Office of the Secretary of Defense in July. The services build their program based upon the Defense Planning Guidance, detailed instructions and resource levels given to them by OSD. From August to November, the services defend these programs to the OSD staff, much in the same way a doctoral candidate defends their thesis. In December, the President’s Office of Management and Budget provides final topline financial guidance and in January, the budget goes to the printer to be submitted to Congress in February. (Of course, this schedule is in an ideal world.)
Today, the services are making their final programming decisions, such as which weapons are terminated, which force structure gets cut, and what levels of readiness they will maintain. Given what we are learning with the war in Ukraine, there are four crucial lessons to learn that would, if accepted, upend the current strategy that is underpinning the building of the defense budget.
First, we are likely to run out of bullets and weapons in a protracted, multi-front war. We now have two data points from wars both small in scope and scale that have shown us that it takes years to replenish expended munitions: the last decade’s war against ISIS, and the present war in Ukraine. This has been part of the Defense Department’s deliberate strategy to hope that “shock and awe” makes wars short. Wars are a test of wills, and if your adversary knows you will run out of munitions, they will find a way to hold on and fight until you are bare of bullets. The Russians are finding this out right now, but even three years ago, the National Defense Strategy Commission declared, “Nearly any conflict between the United States and its most capable competitors would entail significant demand for long-range, high precision munitions. Large quantities of shorter-range high-precision munitions will be needed, as well.”
What should DoD do? Invest billions of dollars in building out surge capacity for munitions and weapons. Right now, DoD is too concerned with the efficient, low-cost production of munitions and weapons, rather than ensuring that the arsenal of democracy has the surge, but more costly, capacity to ramp up production during a war. This will be expensive, but not nearly as expensive as running out of bullets during a war.
Second, prepare for war this decade, not just for war next decade. Secretary Robert Gates warned that the Pentagon has “next war-itis.” In the case of the current 2024 program-build, the strategy is to be prepared for war with China in 2030s by taking risk in the 2020s. This is seen, for example, in the proposal to spend nearly as much on research and development ($130 billion) as on procurement ($145 billion). But Russia has shown us that a declining power will strike sooner rather than later. Many believe that China’s growth is no longer assured, and this may make Beijing much more dangerous in 2027 than in 2037. The Pentagon’s current emphasis on future weapons over current weapons must be switched; that is, we should see much more money spent on current weapons at the expense of future weapon development. Importantly, if you spend more on procuring fieldable weapons now, many of the supply-chain issues experienced today will improve. Conversely, if DoD remains focused on future development, the supply chain will only get weaker as actual production lines wither in an effort to research and prototype rather than manufacture and produce.
Third, nuclear modernization, while critical to our deterrence, must not be done at the expense of the conventional force. Russia is nuclear-strong and conventionally weak. This posture, as we now see, heightens the chance of nuclear war, not reduce it. The bills associated with the deferred modernization the U.S. nuclear triad are nearly $1 trillion. Without additional funding, we risk becoming a modernized nuclear power with limited capacity in our conventional forces. Our Army, Navy, Marine Corps, and Air Force are already too small. The recapitalization of the triad is important, but it should be done with additional funding from OMB, not from internal spending cuts to the conventional forces to foot the triad’s bill.
Finally, inflation might do more damage to our fighting force than has been done by any enemy or even the last decade’s period of sequestration. It appears that the U.S. might be on track for a two-to-three-year cumulative jump of nearly 20 percent. To put that into context, this is the same as reducing the defense budget by $160 billion. From first denying there was rampant inflation early last year, to insisting it was simply transitory, then claiming it really would not affect the Pentagon, the administration is seriously misguiding Congress and the public. We now see reports of contractors wanting to walk away from fixed-cost contracts and negotiating large increases in future, longer-term contracts to ensure that they are compensated for inflation as well. If left unaddressed, inflation will hollow out the force, just like it did in 1979. OMB must provide DoD with the increased funding, even though this will be politically unpalatable.
Taken together, a non-resilient supply chain, reduced procurement of current weapons, trading conventional forces for nuclear forces, and underestimating inflation’s impact will certainly lead to a future military disaster and embolden our adversaries to act sooner than later. OMB and OSD can and should immediately take steps to address this decline and they should do it today, before the services complete their program builds. It is easy to sit around and mock the state of the Russian military, but it is much harder to look in a mirror and wonder what part of the experiences the Russians are having would be similar for us if we engaged in a large-scale war. The resourcing strategy that was put together before the war in Ukraine, coupled with record-high inflation, cannot be accepted as correct. Instead, our defense-resourcing strategy needs to be updated, informed by the four lessons above, to ensure we do not meet the fate of the Russian army. We owe the American people nothing less. “
John Ferrari is a visiting fellow at the American Enterprise Institute (AEI). A retired two-star Army general, he has served as the U.S. Army’s director of program analysis and evaluation.
ROSE COVERED GLASSES 