2013 Arnold Community Council


Nov 18, 2013 (3 years and 6 months ago)


4 March 2013

2013 Arnold Community Council

Congressional Briefing Executive Summary

The Arnold Community Council (ACC) has been a long
time advocate of policy change in lieu of requests
for budget authority to solve problems at Arnold AFB,
Tennessee. Such an approach can save precious
federal tax dollars by eliminating unintended, negative consequences of legislation or regulation. The
ACC and its sister organizations have had some limited success using this approach. Because of looming,
large potential budget cuts, the need for such policy change and subsequent administrative flexibility is
more important than ever. Therefore, this year, the ACC and its sister organizations are advocating a
more powerful and effective way to implement th
eir policy change recommendations. Specifically, we
are asking those U.S. Representatives whose districts are home to major range and test centers to join
the recently chartered Congressional Range and Test Center Caucus (CRTCC). Consequently, the ACC
ll be advocating for five initiatives this year

1) The population of the CRTCC; 2) The opportunity to
accept new missions at Arnold AFB

specifically supporting a quick lease of AEDC land to a major
defense contractor and
providing a home for th
e 2013 NDAA directed hypersonic initiative; 3)
Statutory flexibility in dealing with federal budget cuts; 4) Regulatory relief to improve the
productivity of our National Assets at DoD ranges and test centers; and 5) International Trafficking in
Arms Regul
ation (ITAR) Streamlining
. Each of these issues will be discussed in greater detail in the
following pages.


The Congressional Range and Test Center Caucus

In 2012, Major Range and Test Facility Base (MRTFB) community support groups visiting
D.C. asked
Congressional Representatives why they do not hold hearings on the health and status of MRTFBs when
they are so critical to maintaining U.S. military

s technical and operational superiority. It was noted that
Congress regularly inquires about t
he health and status of DoD depots, major programs and MWR. In
2012, the Arnold AFB Community Council (ACC) broached the potential for an MRTFB Caucus with
congressional and senior DoD representatives. The expressed purpose of the proposed caucus was to
educate members of Congress on the strategic value of ranges and test centers, show the unusually high
return on investment captured by those facilities and support their operations. The proposed caucus
was favorably supported by congressional and senior
DoD officials. On January 22, 2013, the
Congressional Range and Test Center Caucus (CRTCC) was established. Congressmen Black (R
TN) and
Kilmer (D
WA) are the co

The goals of the CRTCC are to: 1) Support stable budget authority/flexibility for l
term investment in
major range and test facility base infrastructure; 2) Provide regulatory relief for greater flexibility in
supporting government and commercial customers; and 3) Ensure understanding of the importance of
MRTBs in the reduction of cos
t and risk in developing, fielding and maintaining DoD weapon systems.
Historically, senior decision makers have not had significant visibility into


major role that MRTBs
have in reducing the cost of fielding DoD systems. This Caucus can help correct

that deficiency through
the review of MRTB capabilities to support congressionally directed programs and initiatives. We ask
that every House of Representatives Member whose district supports an MRTFB join the caucus as soon
as they are aware of its exis
tence. Attached is a background briefing on the CRTCC.


New Mission



Quick Lease of AEDC Land

In early February, the State of Tennessee’s Department of Economic and Community Development
(ECD) put out a request for interested parties to identify 100 acres of property for commercial
development by a defense contractor that could be buffered by an ad
ditional 300
500 acres of
undevelopable land. The State of Tennessee received three responses including the lease of 152 acres
of AEDC property that had already been designated for commercial lease and development under USAF
Solicitation Number AFRPA
01, Enhanced Use Lease for Arnold AFB, TN.

The defense contractor (who wishes to remain unidentified) has indicated interest in the AEDC property
if they could center the 152
acre parcel a little further from a subdivision near the border of AEDC a
either have the surrounding 400 acres be designated undevelopable by the AF or lease the 500 acres
with the 100 acre industrial area centered therein. The facility would bring approximately 200
300 high
tech jobs to the area, with the state picking up
the tab for utility extension and site drainage
modifications through its FastTrack Program with an 18
20 % match by Coffee County and/or the City of
Manchester. Roadway extension from SR 55 to the site would be paid for by the Tennessee
Department of Tr
ansportation’s (TDOT’s) State Industrial Access (SIA) Program.

In the past, there have been two separate transfers of excess AEDC Reservation property to local
government entities that have resulted in huge economic benefit to the region with a resulting

to the AEDC operation through improved educational, transportation, healthcare, and cultural
infrastructure. The first was the sale of 125 acres bordering on the City of Tullahoma to the City of
Tullahoma in 1975 for use in the development of an
industrial park. The second was the sale of 795
acres, which was separated from the AEDC Reservation by the construction of Interstate Highway 24, to
Coffee County in 1977

also for the development of an industrial park. Today, there are 446 employees
n the Tullahoma Industrial Park and 2021 in the Coffee County Interstate Park. Obviously, this is an
economic impact to the region that is similar to the AEDC primary mission’s economic impact and brings
diversity to the region’s employment base.

The defe
nse contractor project currently interested in AEDC is an excellent opportunity for AEDC to
bring additional high tech jobs to the area while providing reimbursable dollars to the AF. The
interested defense contractor wants to be able to finalize a lease
by mid June 2013. This would be an
aggressive schedule for the AF to support. It would only be able to be completed if fast tracking could
be supported by SAF/IE and the Chief. Request that support be identified as soon as possible.


Accept New Missio
ns at AEDC


Hypersonic Ground Test Center of Excellence (CoE)

The DoD’s

new defense strategic guidance emphasizes the importance of projecting power despite anti
access/area denial (A2/AD) challenges. In addition to rebalancing focus towards the Asia
Pacific region,
the guidance states that the U.S. military “will invest as
required to ensure its ability to operate
effectively in A2/AD environments”. The wide expanses of distances in the Asia
Pacific region, the
growing A2/AD threat which requires greater stand
off distances, and the increasing need in modern
warfare for fast

response times for time
critical targeting are all challenges to meeting the guidance.
They all point to the need for the Department to invest in high
speed weapon and platform
technologies, including hypersonic flight. The ability to protect critical m
anned and unmanned
platforms, the ability to maintain existing air supremacy, and the ability to reach out and quickly destroy
both fixed and mobile targets will all require vehicle flight speeds that fall within the hypersonic regime,
defined herein as a
speed equal to or in excess of Mach 5. Speed is the attribute that will enable the
capability, but it is currently unavailable due to the immaturity of hypersonic technologies.

Congress, in its National Defense Authorization Act for Fiscal Year 2013, notes that the state of the
Nation’s hypersonic ground test and evaluation facilities and workforce have not received adequate
attention over the years facing both threats of divestu
re as well as gradual decay, and is concerned that
the broad developmental hypersonic RDT&E community needs renewed attention. At present, activities
to support development of hypersonic capabilities are scattered across various agencies, as well as
s the development spectrum. The AF, Army, Navy and OSD all have funded activities, and are
overseen by the Joint Technology Office for Hypersonics (JTOH). Within these agencies, the
management is further scattered across the research, development, and te
st and evaluation (T&E)
communities. The overall scattered efforts of hypersonic development is not presently exhibited to the
same extent in the area of test and evaluation, especially ground testing. With only a few exceptions,
the nation’s significant

hypersonic ground
test capabilities are
a part of

the Air Force’s Arnold
Engineering Development Complex (AEDC).

ACC Proposed Solution:

Create a Hypersonic Ground Test Center of Excellence (CoE) to manage and
coordinate hypersonic ground testing, lead
the development of advanced hypersonic ground test
capabilities and assure that the expertise of the hypersonic ground test workforce is developed and
sustained. Given the existing ground test facilities and accompanying workforce, AEDC should be the
tion for the CoE. The University of Tennessee Space Institute (UTSI), in close proximity to AEDC,
would support the CoE by providing a focused STEM educational program on High Speed Systems (see
attached description

of UTSI initiative
) to assure that the
expertise to achieve the Nation’s hypersonic
goals are met. Congress should direct DoD to designate AEDC as the Hypersonic Ground Test Center of

High Speed Systems Study and STEM Education Initiative in Support of

AEDC Hypersonic Test Center

of Excellence


The University of Tennessee Space Institute (UTSI)

Tullahoma, TN

The University of Tennessee

in close coordination with other UT campus

is proposing to establish a
focused educational program composed of graduate educations leading to special Certification, M.Sc.
and Ph.D. degrees in Aerospace and Mechanical Engineering with Hypersonic (systems) concentration,
in teaming with AEDC to supp
ort their quest to maintain their leadership as a center for Hypersonic
testing and evaluation, which is an area of national priority and importance. The program will also
include targeted STEM education and training courses in support of T&E and S&T and
in partnership
with participating DOD facilities. This program will establish partnerships with DOD and relevant
industry in an effort towards developing the state of the art High Speed Systems (HSS) Testing and
Evaluation (T&E) and Science and Technology

(S&T) Know
How, incorporating the latest physical and
computational modeling technologies and capabilities. This proposed effort involves developing
modular and portable academic educational programs that will be available at select locations
the nation, to maximize the educational and training experiences available to interested

This program will incorporate critical leading edge sciences, technologies, testing,
analysis/evaluation. Due to the security and sensitivity of some of th
e instructional materials, including
physical, models, facilities and numerical modeling resources all persons involved in the HSS/STEM
program will be required to be US citizens, possibly with additional qualifications agreed and negotiated
by sponsors an
d collaborating parties. Participation will be limited to US citizens, who would be
qualified and interested to become current or future government employees.


Statutory Flexibilities for Test Center/Complex Commanders

As budgets tighten, inadequ
ate direct budget authority exists to maintain test facilities and
infrastructure in a fully operational state for the current customer base. The Center/Complex
Commanders should have increased flexibility from Statutory and Air Force Instructions to bett
accomplish their missions. This flexibility includes:


Test Center/Complex Commanders should execute their authority cited in Paragraph of AFI 65
601 Vol 1, as of 16 Aug 2012.


Provide waivers to below threshold reprogramming limitations.


Relief from 80/20 obligation rule (Oct

AFI 65
601 Volume I, as of 16 Aug 2012, prescribes the funding responsibilities for Air Force Major Range
and Test Facility Base (MRTFB) activities. The facilities affected by this AFI are:

45th Space W
ing (Air Force Space Command Eastern Range), Patrick AFB

30th Space Wing (Air Force Space Command Western Range), Vandenberg AFB

Arnold Engineering Development Center (now Complex) (AEDC), Arnold AFB

Air Force Flight Test Center (AFFTC) (now AF Test
Center (AFTC)), Edwards AFB

Utah Test and Training Range (UTTR), at Hill AFB


(now 96
) Test Wing, Eglin AFB


(now 96
) Test Group (Holloman AFB)

Nevada Test and Training Range (NTTR) at Nellis AFB

The AFI prescribes standard methodologies for application of Direct Budget Authority (DBA) and
Reimbursable Budget Authority (RBA). It states: Effective beginning 1 October 2005 (FY 2006), and in
accordance with Section 232 of the FY 2003 National Defens
e Authorization Act (NDAA), the institutional
and overhead costs of facilities or resources within Major Range and Test Facility Base (MRTFB) program
areas are to be funded through the major test and evaluation type/related budget (DBA) accounts. RBA
is t
ypically used for Direct Costs: Those costs that are directly attributable to the use of the facility or
resource for testing under a particular program, over and above the institutional (appropriated) and
overhead (indirect) costs with respect to the faci
lity or resource. This is the standard cost application
across the MRTFB.

The AFI provides additional flexibility allowing the Commander to charge additional costs, as defined
below: By mutual agreement, investments in
new or existing

T&E fa
cilities may be funded,
whole or in part, by one or more DoD customers

of a MRTFB activity. This agreement must
delineate responsibilities for
funding, staffing, operating, and maintaining the facility and must be
approved by all parties

prior to obliga
tion of any funds for the project.

This paragraph is not actively used by AF Test Center/Complex Commanders and their test management
team as the financial management community cites the difficulty in passing audit

if commanders use
this “flexible approac
h”. Additionally, the financial community stands on another paragraph in this AFI
restricting charging to “single use facility customers”.
The financial community’s position should not
hinder the commander’s ability to discuss investment in test faciliti
es with customers
. Paragraph above provides flexibility, across the customer base, for one or more to fund
any costs

if they
agreed to and documented before any funds are obligated. This policy is clear: The Test
Center/Complex commander, and

his test management team, should use this approach when customers
need the work and DBA is insufficient to cover all the costs.

Recommendation 1
: Test Center/Complex Commanders should execute their authority cited in
Paragraph of AFI 65
601 Vo
l 1, as of 16 Aug 2012.

Similarly, the funding to the AF MRTFB’s is spread over a large number of Program Element Codes (PECs)
with use of each so restrictive it impacts the Commanders’ ability to best execute their mission.
Consistent with the new AF
Vision: ‘
The World’s Greatest Air Force: Powered by
Airmen, Fueled by
’, the Commanders’ will likely increase the use of the authority Below Threshold
Reprogramming (BTR) activity allowing up to $10M in RDT&E funds, $15M in O&M and $20M in
uction Funds from PEC to PEC at their installations for the most important missions per
Financial Management Regulation Volume 3, Chapter 6: Reprogramming of DoD Appropriated Funds

Congress can help the Commander’s by temporarily doubling the BTR thr
esholds for RDT&E, O&M and
Production funds to
$20M in RDT&E, $30M in O&M and $40M in Production PECs, respectively
. Local
Commanders and their Comptrollers have the greatest insight into their missions and need this flexibility
to achieve the best stewar
dship of their missions as a result of drastic budget challenges. This will
increase the burden to the finance community but will serve the mission more effectively.

Recommendation 2
: Congress temporarily increase the Below Threshold Reprogramming (BTR)

authority to $20M in RDT&E, $30M in O&M and $40M in Production PECs for flexibility in financial
execution during these tough financial times.

Obligation rules requiring 80% of all current year funds to be obligated by Jul will be very difficult with
is year’s budget challenges. Commanders will need to hold more management reserve to execute
their mission with limited funds. Historically, commanders are penalized with budget reductions if they
can’t obligate funds within this window.

: Comptrollers and Congress provide commanders relief from the 80/20 Obligation


Regulatory Relief for
Test Centers

As budgets become increasingly tight, it becomes more important for federally funded operations to be
more efficient. Over the
past several years AEDC has found many ways to increase its efficiency and
produce more customer output per labor hour. More recently, labor hours needed to produce reports
to satisfy new federal regulatory requirements have increased by $350K per year.
This trend severely
undermines efforts to increase customer output per labor hour. The outlook for future expenses to
cover newer regulations is even more onerous.

While the intent of federal statutes is usually positive the unintended consequences on loc
al job
markets can be stifling. At AEDC, several federal statutes have had precisely the opposite effect of their
sponsors’ desires. For example, the International Trafficking in Arms Regulation (ITAR) is supposed to
prevent critical defense technologies

from being exported overseas. In the international wind tunnel
business, when this is enforced at AEDC, it has had the effect of exporting both American technologies
and jobs overseas. Initiative 5 provides details for a streamlined ITAR process. Simila
rly, the Sarbanes
Oxley Act (SOX) is supposed to protect investors from falsified financial condition reporting by senior
officials in publically traded companies. Applying SOX at AEDC to a government owned, contractor
augmented complex is completely unne

Similar unintended, negative consequences are demonstrable at AEDC for the Americans with
Disabilities Act, Family Member Leave Act and Service Contract Act. The leadership at AEDC firmly
believes it could comply with the spirit and intent of the
se statutes in an efficient and effective manner,
if given relief from strict interpretation. Since it would be impractical to ask for individual relief from
each statute, AEDC proposes a solution for which it is well suited and would benefit the Nation a
s a

Because AEDC is exceptionally unique as an intersection of federal, commercial, research, test and
technology development efforts that are already extraordinarily well protected physically, virtually and
functionally, it is in a position to act
as a federal government reinvention laboratory with regard to
finding the best ways of implementing federal statutory requirements. AEDC proposes to offer its
people, processes and programs as a Beta site for testing new best practices regarding regulator
compliance. As a Beta site, AEDC would be responsible for finding the most efficient ways of
implementing regulations while complying with their intent. It is proposed that Congress authorize
AEDC as such a Beta site for a period of seven years to asse
ss productivity gains. Developing yearly
reports to assess productivity gains would be the purview of AEDC, but annual progress
to the
Department of the Air Force would be mandatory.

Upon successful implementation of the program, its
concepts cou
ld be used at other ranges and test centers.


International Trafficking in Arms Regulation (ITAR) Streamlining

It is the intent of Congress to facilitate the retention of world
class aerospace test ranges and facilities in
the United States, and to
continue the effort of streamlining and rewriting ITAR and EAR (Export
Administrative Regulation). Specifically, Congress recognizes that the long range objective of identifying
Arnold Engineering Development Complex (AEDC) as a facility with “government
program exemption”
for ITAR procedures will serve US interests.

The intent of this designation as a “government program exemption” is to have AEDC serve as a pilot
national aerospace test facility to explore the potential for increased international test w
ork that would
result from the rapid application of streamlined ITAR procedures being developed by inter
representatives under the leadership of the U.S. State Department. The means to accomplish this would
be through a two
step approach.

The fir
st step is for DDTC to permit the AEDC support contractor to submit a DSP
5 (or DSP
85 for
classified work) license application as an exception to ITAR 124.1(a) for defense services and technical
data, which normally requires the use of an agreement, witho
ut having to request permission from
DDTC prior to each license application. Since licenses are normally approved within 16

18 days rather
than the 4 to 6 months required for agreements, this approach will significantly improve AEDC’s ability
to work wi
th international parties. Additionally, implementation of this step is very simple. DDTC only
needs to change its current policy to permit AEDC to become a pilot program that could eventually have
immense benefit to National security and the mission of o
ur entire Department of Defense.

After a few years of validating the concept outlined in Step 1, then DDTC would implement the second
step by granting AEDC a “government program exemption” authority as principle test bed and beta site
for piloting, validat
ing and accelerating ITAR and related streamlining initiatives for potential application
to other Government programs and agencies. Ultimately, the Department of State would put
implementing language in their regulations that allows for “government progra
m exemptions.” AEDC
was specifically chartered by the Congress of the United States to support and accelerate military and
civilian domestic aerospace development which the “government program exemption” accomplishes.
Under the “government program exemp
tion”’ AEDC would provide a notice to DDTC of each project
being performed under the exemption.

This legislation will lead to increased use and improvement of American aerospace test facilities and
services by international firms as well as increased use b
y domestic firms leading international
aerospace development programs. Greater international use of American aerospace test facilities will
increase the sharing of costs to maintain test ranges and infrastructure, and ultimately lead to reduced
costs asso
ciated with testing at U.S. facilities, most of which are operated and maintained by the
Department of Defense and NASA.

AEDC would r
eport progress on achieving the intent of the
legislation bi