(U) MV-22 Squadrons Could Improve Reporting of Mission Capability Rates and Readiness

SECRET

Additional Copies (U) To obtain additional copies of this repmt, contact the Secondary Repmts Distribution Unit at [email protected].

Suggestions for Audits (U) To suggest or request audits, contact the Office of the Deputy Inspector General for Auditing at [email protected] or by mail.

Depmtment of Defense Office of Inspector General Office of the Deputy Inspector General for Auditing ATTN: Audit Suggestions/13F25-04 4800 Mark Center Drive Alexandria, VA 22350-1500

OEPARTI.IEHT OF DEFENSE To report fraud, waste, mismanagement, and abuse of authority. Send written complaints to: Defense Hotline, The Pentagon, Washington, DC 20301 ·1900 Phone: 800.424.9098 e-mail: [email protected] www.dodig.mil/hotline

(U) Acronyms and Abbrevi ations AMCR Aircraft Material Condition Repmting AMSRR Aviation Maintenance Supply Readiness Reporting CJCSM Chairman of the Joint Chiefs of Staff Manual CNAF Commander, Naval Air Forces DECKPLATE Decision Knowledge Programming for Logistics Analysis and Technical Evaluation DRRS-MC Defense Readiness Reporting System-Marine Corps GSORTS Global Status of Resources and Training System MCAS Marine Corps Air Station MCO Marine Corps Order MCR Mission Capability Rate MCRT Marine Corps Readiness Tool NAMP Naval Aviation Maintenance Program NAVAIR Naval Air Systems Command OIMA NALCOMIS Optimized Intermediate Maintenance Activity Naval Aviation Logistics Command Management Information System PMA-275 Program Manager Air-275, "Joint Advanced Vettical Lift Aircraft (V -22) Osprey Program" VMM Marine Medium Ti ltrotor Squadron

SECRET 8~CIY;T INSPECTOR GENERAL DEPARTMENT OF DEFENSE 4800 MARK CENTER DRIVE ALEXANDRIA, VI RGINIA 22350-1500

October 23, 2013

MEMORANDUM FOR COMI'vlANDER, MARINE F RCES COMMAND COMMANDER, MARIN E rORCES PACIFIC NAVAL INSP ECTOR GENERAL

SUBJECT: MV-22 Squadrons Could Improve Rep011ing of Mission Capability Rates and Readiness (Report No. DODIG-20 14-00 I) (U)

(U) We are providing this report for review and comment. MV-22 squadron commanders computed the mi ssion capability rates for five of six squadrons reviewed using erroneous aircraft inventory reports and work orders. In addition MY -22 quadran commanders submitted incomplete or inaccurate readiness report for the six quadrons. As a result, the mission capability rates were unreliable and senior DoD officials could have deployed MV -22 squadrons that were not prepared for missions.

(U) We considered management comments on a dra ft of this report when preparing the fin al report. DoD Directive 7650. 3 requires that recommendations be resolved promptl y. Comments from the Commander, Naval Air Force, Pacific and the Deputy Commandant for Aviation, responding for the Deputy Commandant for Plans, Policies, and Operations; the Commander, Marine Forces Command; and the Commander, Marine Forces, Paci fie were partially responsive. Therefore we request additional comments on Reco mmendations I, 2.a, 2.b.(l ), 2. b.(2), 2.c. 3.a, 3.b, and 3.c by November 26,2013.

(U) Please provide comments that conform to the requirements of DoD Directive 7650.3. If possible, send a PDF fil e cont aining your comments to---a duJi · .~m i l. mi l. Copies of management comments mu st co ntain the actt~e authorizing official. We cannot accept the /S igned/ symbol in place of the actual signature. If you arrange to send classified comments electronically, you must send them over the SECRET Internet Protocol Router Network (SfPRNET).

(U) We appreciate the courtesies extended to the staff. Please direct questions to me at (703) 604-8866 (DSN 664-8866).

I I ) Alice F. Carey Assistant Inspector Genera l Readiness, Operations, and Suppm1 SECRET

SECRET SECRET Report No. DODIG-2014-001 (Project No. D2011-DOOOLH-0170.000) October 23, 2013 Results in Brief: (U) MV-22 Squadrons Could Improve Reporting of Mission Capability Rates and Readiness

• (U) place a continued emphasis on the (U) What We Did reliability of data critical to the MCR. (U) Our overall objective was to evaluate the accuracy of the aircraft inventory reports and work (U) As a result, the MCRs were unreliable, and orders used to compute the MV-22 mission senior DoD and Marine Corps officials could have capability rates (MCR) from October 1, 2008, deployed MV-22 squadrons that were not prepared through September 30, 2011. In addition, we for missions. evaluated readiness reports to determine whether MV-22 squadrons repotied accurate and complete (U) What We Recommend equipment condition (R-Ievel) and category (U) We recommend the Commander, Naval (C-leve!) information for the MV-22. Air Forces, revise the Commander, Naval Air Forces Instruction 4790.2A, "Naval Aviation Maintenance (U) What We Found Program," November 10, 2009, to include detailed (U) From FY 2009 through FY 2011, MV-22 procedures for maintenance officers to verify the squadron commanders computed the Naval Aviation accuracy and completeness of aircraft inventory Maintenance Program MCR for five of the six . repotis and work orders before submission. squadrons using erroneous aircraft inventory repotis and work orders. Squadron maintenance personnel: (U) We recommend the Commander, Marine Forces • (U) improperly recorded MV-22 aircraft Command and the Commander, Marines Forces status information 167 of 200 times on Pacific: aircraft inventory repotis for • (U) require MV-22 squadrons track and out-of-reporting periods; and report on the accuracy and completion of • (U) did not adequately prepare 112 of 907 aircraft inventory repotis and work orders; work orders that we reviewed. and • (U) require subordinate MV-22 (U) In addition, MV-22 squadron commanders organizations and activities, at all levels of submitted incomplete or inaccurate readiness reports the command, to cetiify the accuracy of for the six squadrons. For example, squadron readiness reports submitted. operations personnel provided incomplete or inaccurate R-level information for 199 of265 (U) Management Comments and readiness reports. Furthermore, 5 squadrons did not Our Response provide complete C-leve! information for 127 of265 (U) Comments from the Commander, Naval Air readiness reports. Force, Pacific, responding for the Commander, Naval Air Forces, were patiially responsive. (U) This occurred because MV-22 squadron Comments from the Deputy Commandant for commanders did not: Aviation, responding for the Deputy Commandant • (U) adequately train MV-22 maintenance for Plans, Policies, and Operations, the Commander, personnel to prepare aircraft inventory Marine Forces Command, and the Commander, repotis and work orders nor MV-22 Marine Forces Pacific, were partially responsive. operations personnel on readiness repotis; Please see the Recommendations Table on the back • (U) verify the accuracy of aircraft inventory of this page. reports, work orders, and readiness reports; or

SECRET SECRET Report No. DODIG-2014-001 (Project No. 02011-DOOOLH-0170.000) October 23, 2013

(U) Recommendations Table

Management Recommendations No Additional I I Requiring Comment Comments Required I Commander, Naval Air Forces II Deputy Commandant for Plans, 12.a, 2.b.(l), 2.b.(2), 2.c Policies, and Operations Commander, Marine Forces 1 3.a, 3.b, 3.c Command Commander, Marine Forces 13.a, 3.b, 3.c Pacific

Please provide comments by November 26, 2013.

SECRET II SJ;CRF;T

(U) Table of Contents

(U) Introduction

(U) Objective 1 (U) MV-22 Program 1 (U) MV -22 Mission Capability Rate Requirement and Calculation 2 (U) Historical Mission Capability Rates 3 (U) Readiness Reporting Guidance 4 (U) Review of Internal Controls 5

(U) Finding. MV-22 Squadrons Should Improve Recordkeeping for Mission Capability Rates and Readiness Reporting 6

(U) Better Recordkeeping Could Improve the Accuracy of the Naval Aviation Maintenance Program Mission Capability Rate 6 (U) Training on Preparing Maintenance Documentation Needed Improvement 9 (U) Maintenance Personnel Needed to Verify Data 10 (U) Readiness Reports Adversely Affected Decision Making 10 (U) Training on Preparing Readiness Reports Needed Improvement 15 (U) Squadron Commanders Did Not Verify Readiness Data 16 (U) Emphasis on Data Reliability Needed Increased Focus 17 (U) Accurate Data Should Improve Decision Making 18 (U) Management Comments on the Finding and Our Response 18 (U) Recommendations, Management Comments, and Our Response 18

(U) Appendixes

(U) A. Scope and Methodology 25 (U) Use of Computer-Processed Data 27 (U) Use of Technical Assistance 27 (U) Prior Coverage 28 (U) B. MY-22's Organizations and Squadrons 29 (U) C. Management Comments on the Finding 31

(U) Annex. Classified Information Used in the Preparation of This Report 34

(U) Management Comments

Naval Air Force, Pacific 35 U.S. Marine Corps 37

SECRET SECiffiT

(U) Introduction (U) Objective (U) Our overall objective was to evaluate whether the V -22 Osprey's performance met the mission capability rate (MCR) requirements. Specifically, we intended to evaluate how the frequency of repairs and the replacement of supply parts affected the V-22's mission readiness from October 1, 2008, through September 30, 2010. On January 12, 2012, we reannounced the audit objective to include FY 2011. Although DoD procured two variants of the V-22 (the Marine Corps' MV~22 and the Air Force's CV -22), for the purpose of this report, we focused on six Marine Medium Tiltrotor Squadrons (VMMs) that operate the MV-22 variant. See Appendix A for a discussion of scope and methodology.

(U) This repott does not address whether missions were undertaken or completed. In the report, we use the MV-22 MCR to define the "V-22 Osprey's performance." The MCR measures the availability and capability of the aircraft to perform a designated mission. During the audit, we identified systemic errors associated with repair and supply parts data used to compute MV-22 MCRs. As a result, we evaluated the accuracy of aircraft inventory reports and work orders used to suppott the computation of the MCR. By improving the accuracy of the data used to compute the MCR, the Marine Corps will obtain better information about the mission readiness ofthe MV-22. (U) MV-22 Program (U) The MV -22, a tiltrotor vertical/short takeoff and landing aircraft, was designed in the 1980s for the Marine Corps to perform assault support missions. 1 The MV-2 2 is a tiltrotor aircraft that can take off vertically like a helicopter and transition to a turboprop airplane configuration. The aircraft transports combat equipped Marines, equipment, and supplies from assault ships and land bases in support of combat and noncombat operations. The Marine Corps intended for the MV-22 to replace the CH-46E helicopter and become the only medium-lift aircraft for the Marine Corps. The Marine Corps considered the MV -22 a more effective option than the CH-46E because it provides the Marine Corps with improved capabilities to perform missions with its greater speed and increased range.

(U) The MV-22 home bases are at Marine Corps A ir Station (MCAS) New River, Notth Carolina; MCAS M iramar, California; and Naval Air Station Patuxent River, Maryland. These bases are home to 13 squadrons that fly the MV-22. As of September 2011 , the

1 (U) Assault support missions enhance a commander's ability to focus and sustain combat power against an enemy as well as take advantage of opportunities identified during combat. These missions use aircraft to provide tacti cal mobility an d logistical support to the Marine Air Ground Task Force. SECRET 1 81;CRET

(U) Marine Corps accepted delivery of 152 MV-22s. See Appendix B for detailed information on the MV-22's organizations and squadrons. (U) MV-22 MC R Requirement and Calculation (U) DoD Instruction 3110.05, "Readiness-based Materiel Condition Reporting for Mission Essential Systems and Equipment," September 25, 2006, requires Military Departments to establish a materiel condition goal for each type of aircraft and to track mission capability as the primary measure of materiel condition. Additionally, Military Departments are required to report mission capability in suppott of the Defense Readiness Repotting System.

(U) Chairman of the Joint Chiefs of Staff Manual (CJCSM) 3170.01B, "Operation of the Joint Capabilities Integration and Development System," May 11 , 2005, states that a capability production document identifies the warfighter's required operational capability from a weapon system. The capability production document for the MV-22 states that aircraft availability is a requirement and that the MCR measures the availability and capability of the MV-22. In the capability production document, the MCR goal was set at 82 percent.2

(U) The Commander, Naval Air Forces (CNAF), issued two instructions providing policy for tracking and calculating MCRs: CNAF Instruction 4790.2A, "The Naval Aviation Maintenance Program (NAMP)," November I 0, 2009; and CNAF Instruction 5442.1, "Aircraft Material Condition Reporting (AMCR)," March 31, 2005.

(U) According to the NAMP, the MCR measures the aircraft material condition of readiness. To determine the MCR, the NAMP requires the Marine Corps to track aircraft status and mission capability information. Squadron maintenance personnel use aircraft inventory reports to document when an aircraft is in-reporting status or out-ofreporting status. An aircraft is in-reporting when the aircraft is available to perform missions and out-of-repotting at all other times (for example, before a new aircraft is delivered to a squadron, while an aircraft undergoes depot-level maintenance, or when an aircraft is placed in long-term storage). Squadron maintenance personnel use work orders to document when an aircraft is non-mission capable.3

2 (U) A MCR requirement of 82 percent means that the MV -22 was avail able and capable of performing any of its assigned missions for 82 hours of 100 hours. 3 (U) An aircraft is non-mission capable when it cannot perform any missions because of maintenance requirements. SECRET

(U) Marine Corps information systems aggregate the aircraft inventory reports and work orders to obtain a continuous real-time calculation of the aircraft status and mission capability information for each aircraft, which is called Record Type 794 data. The NAMP MCR formula is:

(U) MCR = In-Repmting Hmirs5 -Non-Mission Capable Hours6 In-Reporting Hours

(U) According to CNAF Instruction 5442.1A, "Aircraft Material Condition Repmting," March 15, 2010, squadron commanders must repot1 the aircraft material condition on a daily basis to support the readiness-based decisions of higher commands. Squadron commanders are required to repott their squadron's AMCR MCR no later than 8:00a.m. local time. The AMCR MCR is a snapshot of the availability and capability of the squadron's aircraft to perform missions. The Defense Readiness Repotting System-Marine Corps (DRRS-MC) uses the AMCR MCR percentage to determine equipment condition (R-level), which is a component used to determine the overall unit readiness.7 The AMCR MCR formula is:

8 9 (U) MCR = In-Repmting Aircraft - Non-Mission Capable Aircraft In-Reporting Aircraft (U) Historical MCRs (U) The MV-22 MCR goal was set at 82 percent. However, from FY 2009 through FY 2011, the MY-22's MCR did not meet the 82 percent requirement. Specifically, the MV-22 fleet-wide NAMP MCR average was computed at 58 percent in FY 2009, 45 percent in FY 2010, and 57 percent in FY 2011. The MV -22 fleet-wide AMCR MCR average was computed at 65 percent in FY 2009,63 percent in FY 2010, and 66 percent in FY 2011 . Senior Marine Corps officials and operational commanders rely on the NAMP MCR average and AMCR MCR average to develop improvements for future operations, including maintenance and readiness assessment. The NAMP MCR average

4 (U) "Monthly Summary Record," Record Type 79 is a monthly record that states the aircraft status information, mission capability information, and flight data for each aircraft. 5 (U) In-reporting hours are the number of hours in a month that the squadron's aircraft were available to perform missions. 6 (U) Non-mission capable hours are the number of in-repmiing hours in a month that the squadron's aircraft could not perform any missions because of maintenance requirements. 7 (U) Decision makers use the overall unit readiness to determine the ability of the select unit to undertake wa1iime missions for whi ch the unit was organized or designed. 8 (U) In-repmiing aircraft are the number of aircraft in a squadron that were available to perform missions at the time of the squadron's daily AMCR repmi. 9 (U) Non-mission capable aircraft are the number of in -reporting aircraft in a squadron that could not perform any missions because of maintenance requirements at the time of the squadron's daily AMCR rep mi. SECRET 3 SECRET

(U) was based on aircraft records prepared by squadron maintenance personnel. The AMCR MCR average represents the squadron commanders' assessment of the mission capability of their aircraft. (U) Readiness Reporting Guidance (U) Congress required the Secretary ofDefense to establish a readiness reporting system under section 117, title 10, United States Code (10 U.S.C. § 117). The readiness reporting system is required to measure in an objective, accurate, and timely manner the capability of the armed forces to carry out the National Security Strategy prescribed by the President, the Chairman of the Joint Chiefs of Staff, and the defense planning guidance provided by the Secretary of Defense.

(U//FOUO) Congress also required the Chairman of the Joint Chiefs of Staff (the Chairman) to plan, advise, and formulate policy under section 153, title 10, United States Code (1 0 U.S.C. § 153). Specifically, the Chairman is required to establish and maintain, after consultation with the combatant commands, a uniform system for evaluating the preparedness of each combatant command to carry out assigned missions. One of the rep01ting systems the Chairman of Joint Chiefs of Staff created was the Global Status of Resources and Training System (GSORTS). 1° Chairman of the Joint Chief of Staff Instruction 3401.02A, "GSORTS," current as of June 12, 2008, and Chairman of the Joint Chief Staff Instruction 340 1.02B, "Force Readiness Reporting," May 31, 2011, establishes uniform policy, procedures, and criteria for the repotting of authoritative information to the President and Secretary of Defense. GSORTS is a resource and unit monitoring system and an internal readiness management tool that indicates the level of units' select resources and training status required to undertake the mission(s) for which they were organized or designed.

(U//FOUO) To meet 10 U.S.C. repotting requirements, the Deputy Commandant for Plans, Policies, and Operations established policies and procedures for repotting authoritative identification, location, and resource information on units and organizations for the Marine Corps within the Marine Corps Order (MCO) P3000.13D, "Marine Corps Status of Resources and Training System (SORTS) Standard Operating Procedures (SOP)," April 17, 2002; and MCO 3000.13, "Marine Corps Readiness Reporting Standard Operating Procedures," July 30, 2010. These policies and procedures include general instructions for SORTS reporting, including data required, reporting frequency, and management responsibilities. The MCO P3000.13D also states, "SORTS was designed primari ly to measure the day-to-day status of operating forces, but has evolved to become an internal management tool for use by the CJCS, combatant command, and Services." MCO P3000.13D and MCO 3000.13 both state that they are the governing

10 (U) GSORTS, the authoritative source, is the single automated reporting system, whi ch contains all services resource level information. Resource level information includes the P (Personnel), R (Equipment Condition), S (Supply and Equipment), and T (Training) level information. SECRET 4 8~CRET

(U//POUO) authority for all Marine Corps SORTS reporting requirements and applies to all Marine Corps readiness reporting organizations. Development or use of any additional software, reporting formats, local standards or definitions within any part of readiness reporting requires prior authorization from the Deputy Commandant for Plans, Policies, and Operations.

(U) In May 2011, Headquarters, Marine Corps, Operations Division, Deputy Commandant for Plans, Policies and Operations, Readiness Branch created a Marine Corps Commander's Readiness Handbook. The Handbook assists the commanding officers with the readiness repmting process. The Handbook also states the commanding officer must ensure that his/her readiness officer is familiar with MCO 3000.13. The Handbook states, "Commander's should CAREFULLY review readiness repmts before submission to ensure accuracy. Without timely and accurate repot1s, Force Readiness cannot be ascet1ained."

(U//POUO) Based on MCR and readiness repmting guidance, we evaluated aircraft inventory repmts, work orders, and readiness reports for six YMMs from FY 2009 through FY 2011. The six squadrons reviewed were YMM-161, YMM-162, YMM-165, YMM-166, YMM-264, and YMM-365. Specifically, we evaluated the accuracy ofthe aircraft inventory reports and work orders used to compute the MY-22 MCR. In addition, we evaluated readiness repmts to determine whether MY -22 squadrons repotted accurate and complete equipment condition (R-level) and category level (C-level) 11 information for the MY- 22. (U) Revi ew of Internal Controls (U) DoD Instruction 5010.40, "Managers' Internal Control Program (MICP) Procedures," July 29, 2010, requires DoD organizations to implement a comprehensive system of internal controls that provide reasonable assurance that programs are operating as intended and to evaluate the effectiveness of the controls.

(U) We identified weaknesses in internal controls over aircraft maintenance operations and readiness reporting. Specifically, MV-22 squadron commanders did not adequately train MY -22 maintenance personnel to prepare aircraft inventory reports and work orders nor MY-22 operations personnel on readiness reports. MY-22 squadron commanders did not verify the accuracy of aircraft inventory repot1s, work orders , or readiness repmts. In addition, MY-22 squadron commanders did not place an emphasis on the reliability of the data critical to the MCR. We will provide a copy of the report to the senior officials responsible for internal controls at Naval Air Forces; Headquarters, Marine Corps; Marine Forces Command; and Marine Forces Pacific.

11 (U) The C-leve! refl ects the condition of the ava il able four resource levels, equipment condition (R-level), equipment and supplies on hand (S-Ieve!), personnel (P-level), and unit training status (T-level). C-levels, by themselves, do not project a unit's combat performance once committed to combat. 8~CRET 5 SECRET

(U) Finding. MV-22 Squadrons Should Improve Recordkeeping for MCRs and Readiness Reporting (U) From FY 2009 through FY 2011, MV-22 squadron commanders computed the NAMP MCR for five of six squadrons using erroneous aircraft inventory reports and work orders. Squadron maintenance personnel:

• (U) improperly recorded MV-22 aircraft status information 167 of200 times on aircraft inventory reports for out-of-reporting periods; and • (U) did not adequately prepare 112 of 907 work orders that we reviewed.

(U) In addition, MV -22 squadron commanders submitted incomplete or inaccurate readiness reports for six squadrons. For example, squadron operations personnel provided incomplete or inaccurate R-level information for 199 of265 readiness repmis. Furthermore, 5 squadrons did not provide complete C-leve! information for 127 of 265 readiness reports.

(U) This occurred because MV -22 squadron commanders did not:

• (U) adequately train MV-22 maintenance personnel to prepare aircraft inventory repmis and work orders nor MV-22 operations personnel on readiness reports; e (U) verify the accuracy of aircraft inventory repotis, work orders, and readiness repotis; or • (U) place a continued emphasis on the reliability of data critical to the MCR.

(U) As a result, the MCRs were unreliable, and senior DoD and Marine Corps officials could have deployed MV -22 squadrons that were not prepared for missions.

(U) Better Record keeping Could Improve the Accuracy of the NAMP MCR (U) Marines at five of the six MV-22 squadrons prepared aircraft inventory reports and work orders containing erroneous data. According to chapters 1 and 3 of the NAMP, a squadron commander is responsible for the maintenance and mission capability of the squadron's aircraft as well as accomplishing the squadron's mission. Squadron maintenance personnel document maintenance actions and mission capability data on work orders. Squadron personnel also record aircraft status information on aircraft inventory repotis. Squadron personnel use mission capability and aircraft status information to compute the NAMP MCR. Chapter 15 ofthe NAMP states that squadron maintenance personnel must strive for absolutely accurate records.

Sll;CRET 6 8};CRET

(U) However, MV-22 squadrons' aircraft inventory reports and work orders contained errors, including the following:

• (U) improperly recorded aircraft status information; and • (U) miscoded mission capability and maintenance information.

(U) Aircraft Inventory Reports Contained Incorrect Status Information (U) Squadron maintenance personnel improperly recorded MY- 22 status information 167 of 200 times on aircraft inventory reports for out-of-reporting periods from FY 2009 through FY 2011. According to chapter 5 of the NAMP, squadron maintenance personnel are required to accurately document on aircraft inventory repotis an aircraft's status information (either in-repotiing or out-of-reporting). The NAMP authorizes squadron maintenance personnel to record an aircraft as out-of-repotiing when the aircraft is either undergoing depot-level maintenance, is lost, or destroyed in an accident. 12 According to Chapter 13 of the NAMP, aircraft inventory repotis must be dated within 1 minute of an aircraft status change. However, for 66 of 167 entries, squadron maintenance personnel reported the aircraft as out-of-repotiing longer than the required timeframe. For the remaining 101entries, there were no depot-level records to suppoti whether the aircraft were actually out-of-repotiing.

(U) For example, VMM-162 maintenance personnel prepared an April2011 work order that stated aircraft 166736 required repairs to the aircraft's right engine nacelle. According to records from Fleet Readiness (U) Consequently, VMM-162 Center East, depot-level personnel evaluated maintenance personnel recorded the damage on April 18, 2011, and concluded aircraft 16673 6 as out-ofreporting for that the aircraft did not require depot-level at least 96 hours longer than the maintenance. However, squadron required time.fi-ame. maintenance personnel prepared aircraft inventory repotis stating that depot-level repairs began on April18, 2011, and were completed on April22, 2011. Consequently, VMM-162 maintenance personnel recorded aircraft 166736 as out-of-repotiing for at least 96 hours longer than the required timeframe.

(U) Similarly, in April 2011 , VMM-161 maintenance personnel found that aircraft 168005 's nose landing gear collapsed. VMM -161 maintenance personne l prepared work orders to document the damage and the repairs that they performed. Squadron maintenance personnel also prepared aircraft inventory repotis stating depot-level repairs began on April 27, 20 11, and were completed on June 7, 201 1.

12 (U) The Chi ef of Naval Operations can authorize squad rons to rep011 aircraft as out-of-reporting in additional circumstances on a case-by-case basis. Naval Air Systems Command and Defense Contract Management Agency officials prepare aircraft inventory rep011s for all other out-of-repor1ing situations. . 8};CRET 7 81;CRET

(U) However, there were no depot-level work orders that supported the repairs. Without a depot-level work order, the Squadron Commander, VMM-161, could not demonstrate how long the depot-level repairs took to complete or whether the repairs were performed. Consequently, VMM-161 maintenance personnel reported aircraft 168005 as out-of reporting and could not demonstrate that this decision was appropriate.

(U) Work Orders Reported Incorrect Data (U) MV-22 maintenance personnel prepared 112 of907 work orders that we reviewed from FY 2009 through FY 2011 that captured incorrect data. Of the 112 work orders for aircraft, 30 were coded as mission capable when MV -22 maintenance personnel should have coded the aircraft as non-mission capable. The remaining 82 work orders contained various types of errors, such as recording conflicting information on work orders and using non-existent codes.

(U) According to chapter 17 of the NAMP, squadron maintenance personnel are to record on work orders whether aircraft are non-mission capable because of an aircraft malfunction. If an aircraft malfunction prevents safe flight, personnel must record the aircraft as non-mission capable in accordance with the Mission Essential Subsystem Matrix. The Mission Essential Subsystem Matrix for the MV-22 provides guidance on when an aircraft malfunction prevents the safe flight of an MV -22.

(U//FOUO) For example, on April 1, 2010, VMM-365 maintenance personnel found that the battery was "dead" for aircraft 166498. Squadron maintenance personnel replaced the battery by April 14, 2010. When (UI/FOUO) Maintenance documenting this maintenance action, squadron personnel should have recorded maintenance personnel prepared a work order the aircraft as non-mission recording the aircraft as fully mission capable capable because the aircraft did from April 1, 2010, through April 14, 2010. not have a working battery. However, the Mission Essential Subsystem Matrix states that an MV -22 cannot fly safely without an aircraft battery. Maintenance personnel should have recorded the aircraft as non-mission capable because the aircraft did not have a working battery.

(U//FOUO) Similarly, in July 2010, VMM-264 maintenance personnel prepared a work order to document maintenance on the flight control system for aircraft 165853, which is necessary for safe flight according to the Mission Essential Subsystem Matrix. Squadron maintenance personnel coded the work order to state that they removed and replaced a leaking flight control actuator. However, the maintenance personnel recorded on the same work order that they did not remove the flight control actuator and only tested for a leak. Consequently, the Squadron Commander, VMM-264, cou ld not demonstrate what maintenance actually occurred or whether this maintenance action would have rendered aircraft 165853 as non-mission capable.

81;CRI;T 8 SECRET

(U) Training on Preparing Maintenance Documentation Needed Improvement (U) MV-22 squadron commanders did not adequately train MV-22 maintenance personnel on the preparation of aircraft inventory reports and work orders as required by the NAMP. According to the NAMP, a squadron commander has overall responsibility for ensuring maintenance personnel are trained. Under the direction of the squadron commander, work center supervisors must ensure proper training of squadron maintenance personnel, and maintenance officers must ensure training is completed. Squadron commanders conduct training through the Maintenance In-Service Training Program (In-Service Training), which establishes policy, responsibilities, and requirements for training at maintenance activities. In-Service Training modules include lectures, personnel qualification standards, and on-the-job training for maintenance of aircraft. The NAMP requires that training records for maintenance personnel be maintained in the Navy's Advanced Skills Management system. The NAMP also states that indoctrination training for maintenance personnel must be completed within 30 days of reporting to a squadron.

(U) Marine Corps maintenance officials did not have sufficient documentation to prove that adequate training existed for all MV -22 maintenance personnel for the six squadrons based on documentation available in the Advanced Skills Management system. Specifically, 13 of 40 maintenance personnel from VMM-161, VMM-165, and VMM-166 did not have their training documented in the system and did not complete their NAMP indoctrination training within 30 days of rep01ting to their respective squadrons. Advanced Skills Management system showed that maintenance personnel accomplished multiple course levels on the same day and finalized a second level course before completing the first level course. Additionally, maintenance officers from VMM-162, VMM-264, and VMM-365 stated that they did not have complete maintenance training documentation for their maintenance personnel.

(U) Also, the Navy internal inspection rep01ts identified maintenance personnel training deficiencies from FY 2009 through FY 2011. For example, inspection rep01ts from FY 2010 through FY 2011 repeatedly stated that VMM-161 did not always provide mandatory training, maintain training records for each Marine, or document formal and on-the-job training. These and other training problems resulted in maintenance personnel preparing inaccurate records. For example, the inspectors found that maintenance records for (U) These and other training life-limited patts refl ected inaccurate problems resulted in replacement times. Maintenance personnel maintenance personnel improperly maintained records for explosives preparing inaccurate records. installed on the aircraft and improperly controlled hazardous materials because of inaccurate inventories. Additionally, Marine Corps maintenance officials stated in an inspection report that VMM-161 repeatedly flew an aircraft although the aircraft was restricted from fl ight operations. MV -22 maintenance personnel should receive training on how to prepare aircraft inventory

SECRET 9 SJ;CRST

(U) repot1s and work orders, in accordance with the NAMP, on a reoccurring basis to prevent errors in maintenance data. (U) Maintenance Personnel Needed to Verify Data (U) MV-22 squadron commanders did not verify the accuracy of the information included in the MCR calculation. Specifically, squadron maintenance personnel did not verify the accuracy of aircraft inventory reports or work orders. According to chapter 15 of the NAMP, maintenance personnel should prepare complete and accurate documentation. The guidance discusses procedures that supervisors must take to ensure accurate documentation. However, Program Manager Air-275, "Joint Advanced Vet1ical Lift Aircraft (V-22) Osprey Program," (PMA-275) 13 and Headquat1ers, Marine Corps officials acknowledged that maintenance personnel manually entered data into multiple systems and did not ensure the data were correct. Although maintenance personnel were required to ensure the accuracy of aircraft inventory repot1s and work orders, errors occurred repeatedly as discussed earlier. MV-22 squadron commanders should cet1ify that maintenance personnel have verified maintenance information before submission to prevent reporting errors. MV-22 squadron commanders should establish a checklist to validate the correct entry of maintenance information. (U) Read iness Reports Adversely Affected Decision Making (U) MV-22 squadron commanders submitted incomplete or inaccurate readiness repot1s. Specifically, for the six squadrons reviewed, MV-22 squadron commanders provided incomplete or inaccurate R-level information, and five of the six squadrons did not include complete C-leve! information.

(U) R-Levellnformation for Readiness Reporting Needed Improvement (U) MV- 22 squadron commanders provided 199 of 265 readiness reports from FY 2009 through FY 2011 with incomplete R-level information and 23 readiness reports with inaccurate R-level information for the 6 squadrons reviewed. The R-level is one of four resource levels squadron commanders evaluate to determine the overall readiness of a unit. According to the Commander's Readiness Handbook, the R-level represents, "[o]f the gear that I actually have, this is how much actually works like it is supposed to." The R-level is the percentage of aircraft in a squadron's possession that are in-reporting and mission capable. Squadron operations personnel use the AMCR MCR calcul ation to

13 (U) PMA-275 is a subordinate organi zation to Program Executive Office Air Anti-Submarine Warfare, Assault and Special Mission Programs. The Program Executive Office Air Anti -S ubmarine Warfare, Assault and Special Mission Programs is a subordinate organ ization to the Assistant Secretary of the Navy (Research, Development, and Acquisition). SECRJ;T 10 SECRET

(U) determine the DRRS-MC 14 R-level. Table 1 shows the AMCR MCR formula and the criterion for assigning the R-level.

Table 1. MCR Formula and Criterion for R-Level (U) (U) I Rule I R-1 I R-2 I R-3 I R-4 In-Reporting Aircraft minus Non-Mission Capable Aircraft I divided by 100-75 74-60 59-50 49-0 In-Repmting Aircraft percent percent percent percent . . Source: U.S. Manne Corps Plans, Policies, and OperatiOns, "Commander's Readmess Handbook," May 20 11. (U)

(U//POUO) CJCSM 3150.02A, "Global Status of Resources and Training System (GSORTS)," April29, 2004, and CJCSM 3150.02B "GSORTS," March 25,2011, require commanders to submit detailed remarks for each resource level (P, S, R, and T level) that has a numerical value of less than one (that is, for example, R-2, R-3, or R-4). At a minimum, the commander's R-level remarks must include the following data elements:

• (U) the number of authorized, required, assigned and available equipment; • (U) a list of equipment types with problems; e (U) an explanation of the causes of the problems (if known); • (U) assistance already requested; and • (U) any fmther actions required.

(U) Commanders of the 6 MV -22 squadrons submitted 265 readiness reports for the 36-month period reviewed. The readiness reports had systemic issues with the completeness and accuracy ofthe R-level information the squadron commanders reported. For example, 199 readiness repotts did not include· required data elements or MCR, and 23 readiness repotts identified that the commanders' narrative remarks were inconsistent with the reported R-level. 15 Table 2 (on page 12) shows the number of R-level reports containing incomplete or inaccurate R-level information for each squadron.

14 (U) DRRS-MC is a Marine Corp s readiness repmi ing system consisting of an input and output tool. This output tool pull s both resource level information from the local data collection in DRRS-MC. 15 (U) Readiness reports that did not include the MCR percentage were also missing data elements. SECRET 11 SECRI5T

Table 2. Readiness Reports Containing Incomplete or Inaccurate R-Level Information by Squadron (U) (U) InarruratP R-lPvPl I InromplPtP R-lPnl Information Information R-lPnl RPmarks oa· NumbProf MCRWPrl' MV-22 RPadinPss Missing Data Missing MCR lnronsistPnt With Squadron RPports ElPmPnts Ppa·rpntagP R-lPvPl 161 44 39 18 0 162 II 57 47 16 3

165 13 . 11 11 11 166 29 13 10 7 264 63 52 23 0 365 59 37 12 2 Total* 265 199 90 I 23 * The number of missing data elemen s. mtssing MCR percentage. aud remarks mcmlSastent wtth MCR do not equal the total number of readiness repot1s because some itenlS were captmed in multiple categories. (U)

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(U) MV-22 Squadron Commanders Reported Incomplete C-Leve/ Remarks for Readiness Reports (U) MV-22 squadron commanders provided incomplete and inaccurate C-leve} infotmation for five of six squadrons reviewed. The C-level reflects the ability of the select unit to undettake the wa1time tnissions for which the unit was organized or designed (core Inission). For 127 of the 265 readiness reports, the collllllanders' remarks did not suppott the resource level rating or the collllllanders' decision to subjectively raise the unit's C-level rating.

(U) According to MCO 3000.13, the collllllanding officers' C-level will equate to the lowest rating of any of the unit's individually measured resource and training ratings (P, S, R, and T). The only exception to this is if the commanding officer subjectively raised or lowered the C-leve} or Commandant of the Marine Cotps directs a unit to rep01t a C-level of a five. The collllllander's remarks are required on all C-leve} assessments to help higher headqumters understand the organization's mission readiness and capabilities. The collllllander's remarks must explain the rating and put them in context. Table 3 (on page 14) illustrates the definition of the C-level.

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Table 3. Category Level (C-Level) Definition (U) (U) I I C-1 I Could execute full wat1ime missions : C-2 I Could execute most ofwrutime missions C-3 I Could execute many but not aU wa11ime missions Reqt~ired a~d~tional resources or training in order to execute C-4 I wa111me nusstons C-5 I Not prepared to execute wrutime missions Source: Marine Cmps Order 3000.13, ''Mru·ine Corps Readiness Repmtiug Standard Operating Procedures." July 30. 2010. (U)

(U//FOUO) CJCSM 3150.02, "GSORTS," states that the collllllander must provide a summaty when multiple resource levels limit the C-leve!. Specifically, the commander must list the resources with problems; provide the quantities of resom-ces authorized, required, assigned, and available· explain the causes of the problems ifknown; identify assistance already requested; and highlight any additional actions required. Table 4 shows the number of squadron readiness reports where the commanders' C-leve! remarks were inconsistent with the lowest resource rating or the collllllancler's ovenicle.

Table 4. MV-22 Squadrons' Inconsistent C-Level Information (U) (U) I Rt>marks Do Not Rl'marks Do Not I I Numbt>r of Support tht> Support tht> Rt>adint>ss Lowt>st Commandt>a·s' MV-22 Squadrons Rt>ports Rt>som·rt> Rating 0Vl'l'l'idt> 161 I 44 29 I 0 162 I 57 29 I 9 165 I 13 0 0 166 I 29 3 I 8 I 264 I 63 10 I 22 I 365 I 59 15 2 Total I 265 86 II 41 (U)

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(U) Training on Preparing Readiness Reports Needed Improvement (U) MV-22 squadron conummders did not ensure squadron operations persollllel received adequate training on preparing readiness reports. A Headqumters, Marine Cmps official stated that the high tumover of MV-22 squadron personnel affected the data entiy of required readiness repmting info1mation. This caused the squadrons to have a constant lemning cmve on repo1ting readiness. In addition, MV-22 squadrons lacked persollllel trained in entering required resource level info1mation.

(U) According to MV -22 squadron operations persollllel, readiness report training occmTed infrequently. Headquarters, Marine Cmps persollllel stated that they conducted n·aining for squadron operations persollllel. Specifically, Squadron Coll1lllander, VMM-162, stated that during his 2-week Coll1lllanders Officers' School, he received a 1-hour classroom brief on DRRS-MC readiness repo1ting but no hands-on training. The coll1lllander stated this was the only readiness repo1ting training that he received and no refresher training was required.

(U) Au operations officer16 assigned to VMM-162 stated he did not receive either fo1mal or refresher n·aining on readiness repo1ting. The officer received his training through on-the-job training and trial and enor. VMM-264 operations officer stated the last fmmal n·aining on readiness repo1ting that he received was in 2000. In addition, Marine Co1ps

16 (U) The operations officer is the liaison between the operations chief and the squadron commander and reviews the readiness rep011s for accuracy and completeness before the squadron COilllllllllder reviews them. S~CRET 15 SECRET

(U) operations officials did not have sufficient documentation to prove that adequate training existed for all MV-22 operations personnel for the six squadrons based on documentation available in the Advanced Skills Management system. Specifically, all14 operations personnel reviewed from VMM-161, VMM-165, and VMM-166 did not have their training documented in the system. Therefore, Headquarters, Marine Corps personnel should provide formal and refresher training to MV-22 operations personnel on how to report readiness in DRRS-MC.

(U) The officers assigned to VMM-162 and VMM-264 were not familiar with the Commander's Readiness Handbook, which Headquarters, Marine Corps personnel designed to assist commanding officers with the readiness reporting process. The Commander's Readiness Handbook addresses the need for accurate and timely readiness repmis, which will enable higher headquarters to identify and understand the commander's squadron shortfalls and move quickly to mitigate or address them. The Commander's Readiness Handbook also includes the Commander's Checklist, which is a best practice, to improve reporting accuracy and effectiveness. The Commander's Checklist includes statements, such as "[r]emarks should explain the impact of the resource levels on your unit's readiness for both core and assigned missions; and were personnel and equipment accurately reflected." However, the Commander's Readiness Handbook does not include detailed examples of unit commander's C-leve! remarks and resource level remarks. The Commander's Checklist also does not include checking for the required data elements. In addition, there was no requirement to submit the Commander's Checklist with the official readiness report to attest to the accuracy of the repmi. Therefore, the Deputy Commandant for Plans, Policies, and Operations, should revise the Commander' s Readiness Handbook and Commander' s Checklist to include detailed examples. In addition, Headquarters, Marine Corps personnel should require MV-22 squadron commanders to use the Commander's Checklist in the preparation of readiness reports. (U) Sq uadron Commanders Did Not Verify Readiness Data (U//FOUO) MV-22 squadron commanders did not verify the accuracy or completeness of the readiness reports, including information required for the R-level and C-leve!. CJCSM 31 50.02 identifies the information required for the readiness reports. However, we identified that from FY 2009 through FY 2011, MV-22 squadron commanders signed and submitted readiness reports that did not contain all of the required elements. For example, Headquarters, Marine Corps Plans, Policies, and Operations personnel stated that although the VMM-165 squadron received a R-1 without possessing an aircraft, the Squadron Commander, VMM-165 reported an overall C-leve! ofC-5. Headquarters, Marine Corps Plans, Policies, and Operations personnel stated the C-5 level indicated the unit was either activating, deactivating or redesignating.

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(U//FOUO) According to CJCSM 3150.02A, the Setvice Chiefs17 must monitor GSORTS data repm1ing for accuracy, timeliness, and validity within their respective assigned responsibilities, and initiate conective action, as required. Additionally, MCO P3000.13 states that the Commanders, Marine Forces and Major Subordinate Collllllands must also monitor SORTS data for accuracy, timeliness, and validity and initiate conective actions as required. Lastly, MCO P3000.13 requires commanding officers to validate the accuracy of units' SORTS repm1s by signing each SORTS repm1 submitted. There were no instances where commanders at higher levels required MV -22 squadron conunanders to resubmit any of the readiness reports we reviewed to conect enors in repm1ing. The Commander, Marine Forces Command and Commander, Marine Forces Pacific, should require subordinate MV -22 organizations and activities to cet1ify the accuracy and completeness of the readiness repot1ing infonnation before submission to prevent incomplete or inconect infmmation from being repm1ed. (U) Emphasis on Data Reliability Needed Increased Focus (U) Marine Corps squadron commanders were aware of a lack of emphasis on the reliability of data critical to the MCR; however, the issue still existed. According to chapter 3 of the NAMP, "generating high standards of quality in a maintenance organization demands a sincere interest on the pat1 of the CO [Connnanding Officer] which must be evident to evetyone in the command." However, in a Marine Corps policy letter dated October 30 2007, the Connnanding General, 2nd Marine Aircraft Wing, stated, "I am concemed for the safety of personnel, equipment, aircraft, and the fundamental lack ofNaval Aviation Maintenance Program (NAMP) knowledge among key maintenance depat1ment personnel." At that time, the commanding general also noted, "an insufficient emphasis on quality technical training."

(U) Despite emphasis from the Commanding General, 2nd Marine Aircraft Wing, Marine Corps officials did not emphasize the reliability of data critical to the MCR.

17 (U/~ According to Headqua11ers. Marine CoiJJS Plans. Policy. and Operations persollllel. the Commandant of the tvlari.ne Corps is their Service Chief. S~ CR}; T 17 8J£CRET

(U) For example, MV -22 officials acknowledged that the submission of aircraft inventory reports were at the wrong times and may contain errors. According to one squadron commander, the squadrons have many priorities and, as a result, personnel may file the records late. Another MV -22 official stated that MV-22 squadron personnel usually did not prepare all required aircraft inventory repmts when they transfer aircraft for depot-level maintenance. MV-22 officials also stated that some MV-22 squadron personnel did not focus on the accuracy of information recorded on work orders. Although Marine Corps leaders identified these issues in 2007, they still existed. Marine Corps officials should track and report on the accuracy and completion of aircraft inventory reports, work orders, and readiness reports to demonstrate an increased focus on data reliability. (U) Accurate Data Should Improve Decision Making (U) Marine Corps officials did not ensure the MV -22 maintenance records and readiness reports were complete and accurate because the Marine Corps did not sufficiently train maintenance and operations personnel and did not verify that the data were correct. Consequently, the MCRs for the six squadrons were unreliable from FY 2009 through FY 2011. Senior DoD and Marine Corps officials run the risk of deploying squadrons to multiple contingency operations simultaneously based on inadequate maintenance and readiness data. Marine Corps officials should place an increased emphasis on the reliability of the data critical to the MCR and readiness reporting to ensure that the reporting of the data is without error, so decision makers have valid information. (U) Management Comments on th e Finding and Our Response (U) The Commander, Naval Air Force, Pacific and the Deputy Commandant for Aviation provided comments on the finding. See Appendix C for the Commander's and Deputy Commandant's comments on the finding and our response. (U) Recommendations, Management Comments, and Our Response 1. (U) We recommend the Commander, Naval Air Forces, revise the Commander, Naval Air Forces Instruction 4790.2A, "Naval Aviation Maintenance Program," November 10, 2009, to include detailed procedures for maintenance officers to use to verify the accuracy and completeness of aircraft inventory reports and work orders before submission.

(U) Commander, Naval Air Forces, Pacific Management Comments (U) The Commander, Naval Air Forces, Pacific, respond ing for the Commander, Naval Air Forces, agreed with the recommendation. The Commander, Naval Air Forces, Pacific, stated that improvements in the NAMP are needed for procedures and responsibilities for verifying Aircraft Inventory Readiness Repmting System and work 8J£CRET 18 8~CRET

(U) orders. The Commander, Naval Air Forces, Pacific, will incorporate the following changes in the NAMP. Specifically, the NAMP will include the additional responsibility for the maintenance material control officer to validate the accuracy of Aircraft Inventory Readiness Reporting System before submission. The additional responsibility ofthe collateral duty inspector, work center supervisor, maintenance control desk supervisor, maintenance master chief petty officer, maintenance material control officer, and maintenance officer to emphasize of importance of verifying the correct Equipment Operational Capability code to be used on work orders. In addition, the NAMP will include an additional responsibility for the maintenance officer to review aircraft readiness rates and validate that correct reporting procedures are being followed. The NAMP changes are estimated to be completed by September 15,2013. Lastly, the Commander, Naval Air Force, Pacific, provided additional information on improvements to Aircraft Inventory Readiness Repmting System that will affect the tracking of time on all active work orders and will require approval from the aircraft controlling custodian before acceptance of the aircraft inventory report making errors more identifiable. The improvements to the Aircraft Inventory Readiness Reporting System are expected to be completed in December 2013.

(U) Our Response (U) Comments from the Commander, Naval Air Forces, Pacific, were partially responsive. We agree that the Commander, Naval Air Forces, Pacific's, incorporation of the changes to the NAMP will add internal controls and a segregation of duties to the maintenance process. However, the response did not include detailed procedures for maintenance officers to use to verify the accuracy of completeness of aircraft inventory reports and work orders. In addition, the NAMP changes that will require the maintenance material control officer to validate the accuracy of Aircraft Inventory Readiness Reporting System before submission will not resolve the recommendation because it is a change that focuses on the system output. However, our recommendation fo cuses on the system inputs by addressing the issue of erroneous Aircraft Custody/Status Change Reports (aircraft inventory repmts) used to compute the mission capability rate. Therefore, we request that the Commander, Naval Ai r Forces, Pacific readdress Recommendation 1 and provide additional comments in response to the final repoti.

(U) Commander, Marine Forces Command Management Comments (Unsolicited) (U) Although not required to comment, the Deputy Commandant for Aviation responding for the Commander, Marine Forces Command, agreed with Recommendation 1. The deputy commandant will coordinate with Commander, Naval Air Forces to include detailed procedures for maintenance officers to verify the accuracy and completeness of aircraft inventory and work orders before submission beyond what already exists in the Commander, Naval Air Forces Instruction 4790.2A, "Naval Aviation Maintenance Program," (NAMP) paragraphs 3.5.3, 3.5.4, and 5.2.

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(U) Our Response (U) The Deputy Commandant for Aviation provided an unsolicited response to Recommendation 1. We agree with the Deputy Commandant's response to Recommendation 1.

2. (U) We recommend the Deputy Commandant for Plans, Policies, and Operations:

a. (U) Require mandatory training and establish refresher training for all MV-22 operations personnel on how to complete readiness reports in the Defense Readiness Reporting System-Marine Corps.

b. (U) Revise the Commander's Readiness Handbook, January 2012 to include at a minimum: (1) (U) Detailed examples of the commander's category level remarks and equipment condition level remarks.

(2) (U) In the Commander's Checklist, the equipment condition data elements and a requirement for the commander's signature on the readiness reports to attest to the accuracy of information provided.

c. (U) Require submission of the revised Commander's Checklist with the readiness report.

(U) Deputy Commandant for Plans, Policies, and Operations Management Comments (U) The Deputy Commandant for Aviation provided responses to Recommendations 2.a, 2.b.(l), 2.b.(2), and 2.c on behalf of the Deputy Commandant for Plans, Policies, and Operations.

(U) The Deputy Commandant for Aviation agreed with Recommendations 2.a and 2.b.(l) but did not provide any actions to implement the recommendations. The deputy commandant partially agreed with Recommendation 2.b.(2). The deputy commandant stated that there should be no requirement for commanding officers to sign readiness reports and there is no DoD, Joint Staff, or Service readiness directive requirement for commanding officers to sign or maintain paper copies of readiness repotts. He stated that the cost of electronic signatures would outweigh the benefi t to implement electronic signatures into DRRS-MC or DRRS-Strategic. The deputy commandant stated that Marine Corps officials wi ll reemphasize that commanding officers are responsible for the accuracy of their reports. The deputy commandant disagreed with Recommendation 2.c. He stated that the Commander's Readiness Handbook identifies the importance of using MCO 3000.13, "Marine Corps Readiness Reporting Standard Operating Procedures," as the source of detailed instructions for readiness report submission. The deputy commandant also stated that there is no requirement from DOD, Jo int Staff or Services SECRET 20 SECRET

(U) readiness directives for a checklist to be included with readiness reports. He stated that the cost would outweigh the benefit to incorporate a checklist for submission into DRRS-MC or DRRS-Strategic.

(U) Our Response (U) Comments from the Deputy Commandant for Aviation on Recommendations 2.a and 2.b.(l) were patiially responsive because although they agreed with the recommendations, no actions to implement the recommendations were provided. Comments from the deputy commandant on Recommendation and 2.b.(2) were partially responsive. The deputy commandant did not address incorporating the equipment condition data elements into the Commander's Checklist and did not explain how the deputy commandant would reemphasize the accuracy of the commanding officers readiness reporting. In this regard, the deputy commandant did not provide any cost benefit analysis to demonstrate that the cost of electronic signatures would outweigh the benefit of requiring squadron commanders electronic sign readiness repotis in DRRS-MC or DRRS-Strategic. Comments from the deputy commandant on Recommendations 2.c were nonresponsive. We still maintain that the Commander's Checklist should be required with the submission of the readiness repmi to increase the effectiveness of the readiness guidance by adding another control mechanism to ensure proper reporting of readiness. Therefore, we request that the Deputy Commandant for Aviation readdress Recommendations 2.a, 2.b.(l), 2.b.(2), and 2.c and provide comments on the final repoti.

3. (U) We recommend the Commander, Marine Forces Command, and the Commander, Marine Forces Pacific:

a. (U) Implement mandatory training and establish refresher training for all MV-22 maintenance personnel on how to complete aircraft inventory reports and work orders outlined in Commander, Naval Air Forces Instruction 4790.2A, "Naval Aviation Maintenance Program," November 10, 2009.

b. (U) Require MV-22 squadrons track and report on the accuracy and completion of aircraft inventory reports and work orders.

c. (U) Require subordinate MV-22 organizations and activities, at all levels of the command, to certify the accu racy of readiness reports submitted.

(U) Commander, Marine Forces Command Management Comments (U) The Deputy Commandant for Aviation provided responses to Recommendation 3 .a, 3.b, and 3.c on behalf of the Commander, Marine Forces Command. The deputy commandant did not state whether he agreed or disagreed with Recommendations 3.a. The deputy commandant stated that maintenance material control officers, maintenance control, and maintenance administration Marines are required to attend training courses for Optimized Organizational Maintenance Activity Naval Aviation Logistics Command

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(U) Management Information System aircraft inventory reporting and work orders documentation in accordance with the NAMP. He stated that mandatory refresher training is provided through technical training in accordance with the Squadron Monthly Maintenance Plans. All training is entered into Advanced Skills Management that assists leadership in verifying and validating all personnel are qualified to execute appropriate tasks based on their ability.

(U) The deputy commandant did not state whether he agreed or disagreed with Recommendations 3.b. The deputy commandant stated he would recommend a NAMP change request to specify that the maintenance material control officers must validate all Subsystem Capability Impact Reporting related work orders before reporting and to clarify that the maintenance material control officers must establish procedures to monitor Aircraft Inventory Readiness Reporting System. He stated that a long-term solution will be the fielding of "One NALCOMIS" which will reintroduce the squadron work center supervisor and squadron data analyst to the work order validation process before Aircraft Inventory Readiness Repmting System and DECKPLATE uploads for squadrons in FY 2017.

(U) The deputy commandant did not state whether he agreed or disagreed with Recommendations 3.c. The deputy commandant stated that the NAMP change request addresses the accuracy and certification at the squadron level. The Marine Aviation Logistics Squadron oversight of squadron out of reporting aircraft adds another layer of verification. The deputy commandant stated that the Commander, Marine Forces Command would recommend a NAMP Change to the Aircraft Records and Reports program to increase the frequency of Aircraft Maintenance Officer Certifications. The deputy commandant stated the Commander, Marine Forces Command regularly screens unit reports and direct any resubmissions through the chain of command. Commanders are required to approve their unit reports in DRRS-MC.

(U) Our Response (U) Comments from the Deputy Commandant for Aviation on Recommendations 3.a, 3.b, and 3.c were nonresponsive. Specifically, for Recommendation 3.a., the Finding demonstrated that MV -22 squadron commanders did not adequately train maintenance personnel on the preparation of aircraft inventory repmis and work orders as required by the NAMP. For Recommendation 3.b. , the deputy commandant stated they would request changes to the NAMP; however, these changes will not address the recommendation to track and report on the accuracy and completion of aircraft inventory reports and work orders. The fie lding of "One NALCOMIS" in FY 2017 is not a timely solution for ensuring the accuracy and completion of aircraft inventory reports and work orders. For Recommendation 3.c., the deputy commandant stated they would request changes to the NAMP, however, these changes do not address the recommendation to require all subordinate MY -22 organizations to certify the accuracy of readiness reports in DRRS-MC. Although, the deputy commandant stated they screen subordinate unit readiness reports, our Finding demonstrated that MY -22 squadron commanders were not adequately screening unit readiness reports as evidenced by the large number of 81'CRET 22 81;CRBT

(U) incomplete or inaccurate readiness reports submitted. Therefore, we request that the Deputy Commandant for Aviation readdress Recommendations 3.a, 3.b, and 3.c and provide additional comments in response to the final report.

(U) Commander, Marine Forces, Pacific Management Comments (U) The Deputy Commandant for Aviation provided responses to Recommendation 3 .a, 3.b, and 3.c on behalf of the Commander, Marine Forces, Pacific.

(U) The deputy commandant agreed with Recommendations 3 .a. He stated all Optimized Organizational Maintenance Activity work center supervisors, in accordance with the NAMP, should complete the Naval Aviation Organization Maintenance Activity Work Center Supervisor's course that teaches the basics for work order documentation. The implementation of Optimized Organizational Maintenance Activity removed the work center supervisor's signature block from work orders, but this does not take away the responsibility to screen for adequate documentation. The implementation of "One NALCOMIS" in FY 2017 will bring work center supervisors back in the sign off chain. Until then, the collateral duty inspector will have the responsibility for adequate documentation at the work center. The deputy commandant recommends revising the collateral duty inspector's training syllabus in Advanced Skills Management to include formal training of the collateral duty inspector before signing work orders.

(U) The deputy commandant agreed with Recommendations 3.b. The deputy commandant requested that the DoDIG recommend to the Space and Naval Warfare Systems Center to fix the interface between Optimized Organizational Maintenance Activity and DECKPLA TE to ensure all Aircraft Custody/Status Change Repmts replicate properly which can improve the overall accuracy of aircraft inventory repmts. The deputy commandant highlighted that the transition to Optimized Organizational Maintenance Activity made information output faster and increased the collateral duty inspector's role, but decreased the squadron analyst's role by taking away the ability to review and correct improper work order documentation. The collateral duty inspectors are last in the process to ensure work orders are correctly documented.

(U) The deputy commandant agreed with Recommendations 3 .c. He stated the Commander, Marine Forces, Pacific regularly screens unit reports and directs resubmission through the chain of command. Commanders are required to approve their unit reports in DRRS-MC.

(U) Our Response (U) Comments from the Deputy Commandant for Av iation on Recommendations 3.a, 3.b, and 3.c were partially responsive. The deputy commandant's responses to the recommendations were partially responsive because he did not provide specific actions that will be taken to address the recommendations. For Recommendation 3.a., the work center supervisors were already required to complete the Naval Aviation Organization Maintenance Activity Work Center Supervisor's course for preparing work orders and the training was ineffective as evidenced by the numerous errors identified in the Finding 81;CRET 23 SECRET

(U) with the work orders in the report. According to the NAMP, the work center supervisor is responsible for ensuring that the work order is accurate and complete and should be involved in the sign off process for work orders. For Recommendation 3.b., the deputy commandant did not specify how the increase in the collateral duty inspector's role with work orders will implement the recommendation to track and repmt on the accuracy and completeness of work orders. For Recommendation 3.c., the Finding demonstrated that there were numerous errors with the readiness repmts submitted in DRRS-MC and the commanders screening efforts did not discover those errors. Therefore, we request that the Deputy Commandant for Aviation readdress Recommendations 3.a, 3.b, and 3.c and provide additional comments in response to the final report.

(U) Deputy Commandant for Plans, Policies, and Operations Management Comments (Unsolicited) (U) Although not required to comment, the Deputy Commandant for Aviation responding for the Deputy Commandant for Plans, Policies, and Operations, agreed with Recommendation 3.c. The deputy commandant agrees if the intent was for the responsibility for accuracy of readiness reports to fall under the organizations' commanders and the organizations develop an audit program to periodically check the accuracy of readiness repotts. The Marine Forces Command and Headquatters Marine Corps regularly review unit reports and direct any corrections and remarks through the chain of command. Higher headquarters reviews of subordinate units' reports before submission should not be required.

(U) Our Response (U) The Deputy Commandant for Aviation provided an unsolicited response to Recommendation 3.c. The deputy commandant's response did not meet the intent of Recommendation 3.c. Specifically, due to the severity and frequency of the inaccurate or incomplete readiness repmts identified in the Finding, a need exists for higher headquatters to review readiness repOtts prior to submission.

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{U) Appendix A. Scope and Methodology (U) We conducted this performance audit from June 2011 through July 2013 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

(U) We met with officials from PMA-275, Naval Air Station Patuxent River, Maryland; Headquarters, Marine Corps, Washington, D.C.; Marine Aircraft Group 26, MCAS New River, North Carolina; Fleet Readiness Center East, MCAS Cherry Point, North Carolina; Naval Supply Systems Command Weapon Systems Support, Philadelphia, Pennsylvania; and Defense Logistics Agency Aviation, Richmond, Virginia, to obtain documentation for this audit. Specifically, we obtained aircraft maintenance data from PMA-275 and Fleet Readiness Center East. We also obtained supply requisitions and data from PMA-275; Naval Supply Systems Command Weapon Systems Support; Defense Logistics Agency Aviation; Headquarters, Marine Corps; and Marine Aircraft Group 26 supply personnel. Finally, we obtained aircraft inventory data from PMA-275 and readiness repotts from Headquarters, Marine Corps personnel.

(U) There were 13 MV-22 squadrons during our audit scope. Ofthe 13 squadrons, 10 squadrons perform operational missions, and the other 3 squadrons were for training or test and evaluation. To accomplish our audit objective, we nonstatistically selected 6 ofthe 10 operational missions' squadrons to review MV-22 MCRs and supporting documentation from FY 2009 through FY 2011. The six MV-22 squadrons were composed ofthree squadrons from the MCAS Miramar, California, and three squadrons from MCAS New River, North Carolina. The Table below lists the six squadrons. See Appendix B for a list of all MV-22 Squadrons.

Table. MV-22 Squadrons Reviewed (U) (U) Squadrons I Location VMM- 161 I MCAS Miramar, CA

VMM-162 / MCAS New River, NC VMM-165 I MCAS Miramar, CA VMM- 166 I MCAS Miramar, CA VMM-264 I MCAS New River, NC

VMM-365 I MCAS New River, NC (U)

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(U) We were provided access to data from the Decision Knowledge Programming for Logistics Analysis and Technical Evaluation (DECKPLATE) 18 system, which PMA-275 officials stated contained all maintenance records requested by the audit team. Using DECKPLATE, we obtained 527 aircraft inventory reports; 104,183 work orders; 19 the Record Type 79 data; and supply requisition data. During our discussions, MV-22 officials acknowledged that the records used to compute NAMP MCRs contained errors. We performed analytical procedures on the 527 aircraft inventory reports and 104,183 work orders to determine the scope of erroneous maintenance records and found that maintenance personnel were improperly recording mission capability data. From the 527 aircraft inventory reports, we identified that maintenance personnel recorded MV-22 aircraft as out-of-reporting 200 times. We assessed the reliability of this aircraft status information. We used maintenance information recorded on the 104,183 work orders to identify 1,548 maintenance actions that should have caused MV-22 aircraft to be non-mission capable. We non-statistically reviewed 907 of these 1,548 work orders to determine whether maintenance personnel improperly recorded mission capability data. We recalculated the NAMP MCRs using the Record Type 79 data and found that MV-22 officials provided incorrect NAMP MCRs. We alerted the MV-22 officials who agreed with our calculation explaining that they used incomplete historical data.

(U) Based on our recalculation of the NAMP MCRs, we requested information for the AMCR MCRs from the Marine Aircraft Group 26 personnel responsible for the information. The Marine Aircraft Group 26 personnel provided additional AMCR MCR information and explained how to obtain summary data from the Aviation Maintenance Supply Readiness Reporting (AMSRRi 0 system to calculate the AMCR MCRs. We obtained summary data, recalculated the AMCR MCRs, and found that the fl eet-wide AMCR MCR averages were not precisely calculated. We alerted the Marine Aircraft Group 26 personnel who agreed with our conclusion that AMCR MCR percentages were not precisely calculated fo r one specific squadron.

18 (U) DECKPLATE is the reposit01y fo r aircraft maintenance and usage data. DECKPLATE provides users th e ability to obtain data in real -t ime, as well as hi stori cal data for trend analys is and record s reconstruction. DECKPLATE stores record data transferred from Optimized Organizational Maintenance Activity Naval Aviation Logistics Command Management Information System. Optimized Organizational Maintenance Activity Naval Aviation Logistics Command Management Information System provides a real time, responsive, computer-based management information system that is intended to increase aircraft readin ess by providing local maintenance and supply managers with timely and accurate information required in their day-to-day management and decision making process. 19 (U) Fleet Readin ess Center East officials prov ided an additional I 03 work orders because they did not transfer their work orders to DECKPLA TE. 20 (U) AMSRR is the preferred method for updating, creating, releasing, and submitting the required aircraft material condition rep01is in suppmi of readin ess-based decision making. SECRET 26 SISCRET

(U) We obtained and reviewed all265 readiness rep01ts in DRRS-MC and the Marine Corps Readiness Tool (MCRT).21 We obtained access to DRRS-MC and MCRT through the Secret Internet Protocol Router Network. We retrieved readiness rep01ts from both DRRS-MC and MCRT systems to determine whether the resource data entered into the systems were similar in both readiness reports. Within each DRRS-MC and MCRT readiness rep01ts, we focused on the R-level used to calculate the MCR to determine whether operations personnel calculated the R-level correctly. We also focused on the commander's C-leve! remarks within each readiness report to determine whether each remark was consistent with the lowest resource rating or the commander's decision to subjectively raise the unit's C-leve! rating.

(U) Headquarters, Marine Corps also provided a list of 1,474 MV-22 maintenance and operations personnel. We nonstatistically selected 64 maintenance and operations personnel to identify whether training documentation existed. Marine Corps personnel provided access to Advanced Skills Management system to review the training records for the MV -22 maintenance and operations personnel.

(U) Use of Computer-Processed Data (U) We obtained computer-processed data from DRRS-MC, MCRT, DECKPLATE, AMSRR, Optimized Intermediate Maintenance Activity Naval Aviation Logistics Command Management Information System (OIMA NALCOMIS), and Aviation Financial AnalySis Tool. Specifically, we obtained readiness rep01ts from DRRS-MC and MCRT, work orders, aircraft inventory reports, supply requisitions, and Record Type 79 data from DECKPLATE; mission capability information from AMSRR; and supply requisitions from OIMA NALCOMIS and Aviation Financial AnalySis Tool. Based on our review ofthese records and discussions with MV-22 officials, we concluded that aircraft inventory rep01ts and work orders contained erroneous data and readiness reports were incomplete and inaccurate as discussed in the finding. (U) Use of Technical Assistance (U) We relied on the technical assistance of DoD Office ofinspector General Quantitative Methods Division to assist our review of work orders. Quantitative Methods Division analysts used data querying software, Audit Command Language, to support our analysis of work orders. As discussed in the finding, we found the data were unreliable.

21 (U) MCRT is an output tool that extracts all Marine Corps resource-level information. SECRET 27 SECRET

(U) Prior Coverage (U) During the last 5 years, the Government Accountability Office (GAO) issued two reports discussing the MV -22 Aircraft and Marine Corps readiness reporting. Unrestricted GAO reports can be accessed over the Internet at http:/I gao .gov /browse/date/week. (U) GAO (U) GAO Report No. GA0-11-526, "Army and Marine Corps Reporting Provides Additional Data, but Actions Needed to Improve Consistency," June 3, 2011

(U) GAO Report No. GA0-09-482, "Assessments Needed to Address V-22 Aircraft Operational and Cost Concerns to Define Future Investments," May 11, 2009

SECRET 28 81;CRET

(U) Appendix B. MV-22's Organizations and Squadrons (U) Several organizations help to develop and suppmt the MV-22. For the purpose of this audit, we focused on Naval Air Systems Command (NA V AIR), Program Manager Air-275 (PMA-275), 2nd Marine Aircraft Wing, and 3rd Marine Aircraft Wing.

(U) NAV AIR provides the Navy and Marine Corps full life-cycle support of naval aviation aircraft, weapons, and systems. NA V AIR provides suppmt (for example, people, processes, tools, and training) to Naval Aviation Program Executive Officers and their program managers. They were responsible for meeting the cost, schedule, and performance requirements of their assigned programs. Under NAVAIR, PMA-275 manages the development, suppmt, fielding, and disposal ofthe MV-22 tiltrotor aircraft program for the Marine Corps. The two main Marine Aircraft Wings that operate the MV -22s are the 2nd Marine Aircraft Wing and the 3rd Marine Aircraft Wing. The 2nd Marine Aircraft Wing is home to Marine Aircraft Group 26 located at Marine Corps Air Station New River, Nmth Carolina. The 3rd Aircraft Wing is home to Marine Aircraft Group 16 located at Marine Corps Air Stations Miramar, California. Both Marine Aircraft Wings provide combat ready assault suppmt teams to conduct air operations. Marine Corps Air Stations Miramar and New River are home to 10 squadrons that fly MV-22s in operational missions. The Table (on page 30) identifies all squadrons that flew MV-22s during our audit scope.

81;CRI;T 29 SECRET

Table. Aircraft Squadrons With MV-22s (U) (U)

Squadron I Location Mission VMM 161 I MCAS Miramar, CA Assault Support VMM-165 I MCAS Miramar, CA Assault Suppm1 VMM-166 I MCAS Miramar, CA Assault Support

VMM-561 .I MCAS Miramar, CA Assault Support ., VMM-162 I MCAS New River, NC Assault Support

VMM-261 I MCAS New River, NC I Assault Support VMM-263 I MCAS New River, NC I Assault Support VMM-264 I MCAS New River, NC I Assault Suppm1 VMM-266 ,I MCAS New River, NC I Assault Support VMM-365 I MCAS New River, NC I Assault Suppm1 Marine Medium Tiltrotor Fleet Replacement Training Squadron 204* I MCAS New River, NC Squadron (Training) Marine Operational Test and Evaluation Operational Test and Squadron 22 * MCAS New River, NC Evaluation Air Test and Evaluation Naval Air Station Developmental Test Squadron 21 * Paxtuxent River, MD and Evaluation .. *(U) Manne Medmm TIItrotor Trammg Squadron 204, Manne OperatiOnal Test and Evaluation Squadron 22, and Air Test and Evaluation Squadron 21 do not fly operational missions. According to PMA-275 officials, only squadrons that fly operational missions were considered when calculating MCRs. (U)

SECRET 30 SJ;CRET

(U) Appendix C. Management Comments on the Finding (U) The Commander, Naval Air Force, Pacific and the Deputy Commandant for Aviation, responding for the Deputy Commandant for Plans, Policies, and Operations; and the Commander, Marine Forces Command provided the following comments on the finding. For the full text of the Commander, Naval Air Force, Pacific and Deputy Commandant for Aviation's comments, see the Management Comments section of the repmt.

(U) Naval Air Force, Pacific Management Comments on the Finding (U) The Commander, Naval Air Force, Pacific identified the following concerns with the report sections regarding readiness data and requirements. Specifically, he stated that the source of data for mission capable and fully mission capable was not the correct source. The DoD Instruction 3110.5 ["Materiel Condition Reporting for Mission Essential Systems and Equipment," September 14, 1990] should be the reference document used in determining readiness data and requirements and not AMSRR. The NAMP guidance provides for a 24 hours a day, 7 days a week metric when repmting aircraft readiness. However, AMCR guidance provides for a snapshot in time when repmting aircraft readiness and material condition. The Record Type 79 data is Aviation Maintenance Material Management data and accounts for and depicts 24 hours a day, 7 days a week material degradation of aircraft and systems. There is no correlation exists between AMCR data and Record Type 79 data. Lastly, no specific readiness repmts were identified in the audit repott; therefore, the Commander, Naval Air Force Pacific was unable to substantiate the findings referencing readiness repotts. For the complete text of the Commander, Naval Air Force, Pacific's technical comments, please refer to page 36.

(U) Our Response (U) The Commander, Naval Air Force, Pacific's concerns have already been addressed or considered in the report. Specifically, the DoD Instruction 3110.05, "Readiness-based Materiel Condition Repmting for Mission-Essential Systems and Equipment," September 25, 2006 cancelled DoD Instruction 3110.5. The DoD Instruction was properly cited in the report on page 2. The NAMP's mission capability rate was defined as a "continuous real-time calculation" meaning 24 hours a day 7 days a week and AMCR mission capability rate as a daily snapshot, meaning a snap shot in time. Although the Commander, Naval Air Force, Pacific was concerned that the report presented a correlation between Record Type 79 data and AMCR data. The report distinguishes the differences between the Record Type 79 data (NAMP mission capability rate) and the AMCR mission capability rate on pages 2 and 3. Lastly, the Commander, Naval Air Force, Pacific's concern that the repott did not specifically identify which readiness reports were reviewed during the assessment is not valid. The report specifically identifies on pages 10 and 25 that the readiness reports reviewed SJ;CRJ;T 31 SJ;CRJ;T

(U) included all265 readiness reports for squadrons VMM-161, VMM-162, VMM-165, VMM-166, VMM-264, and VMM-365 from DRRS-MC and MCRT during the FY 2009 through FY 2011 time period. In addition, pages 12 and 15 of the report specifically identified examples of readiness reports.

(U) U.S. Marine Corps Management Comments on the Finding (U) The Deputy Commandant for Aviation provided comments on behalf of the Deputy Commandant for Plans, Policies, and Operations and the Commander, Marine Forces Command.

(U) Plans, Policies, and Operations Management Comments (U) The Deputy Commandant for Plans, Policies, and Operations, identified the following concerns with the report background and Finding sections. The Deputy Commandant for Aviation cited the draft report for documenting guidance without including clarifying remarks that one guidance cancelled the former, documenting improper guidance for readiness reports, identifying the incorrect resource level, incorrectly identifying the number of readiness repotis in two tables, and not including the actual definition for C-levels. For the complete text of the Deputy Commandant for Plans, Policies, and Operations' technical comments, please refer to pages 45 and 46.

(U) Marine Forces Command Management Comments (U) The Commander, Marine Forces Command, identified the following concerns with the report Background and Finding sections. The Deputy Commandant for Aviation cited the draft report for improperly quoting the MCO P3000.13D and joint policies, identifying the incorrect resource level, improperly interpreting DRRS-MC resource percentages, and insufficient support to the finding that MV -22 Squadron Commanders did not verify the accuracy and completeness of readiness reports. For the complete text of the Marine Forces Command technical comments, please refer to pages 46 and 47.

(U) Our Response (U) In reference to draft repot1 concerns from the Deputy Commandant for Aviation, responding for the Deputy Commandant for Plans, Policies, and Operations, information in the draft report was clear and accurate. Specifically, we cite both MCOs because during the timeframe of our review FY 2009 through FY 2011 , both MCOs were in place. The MCO 3000.13 addresses the readiness reporting requirements in the Chairman Joint Chi efs of Staff Manual 3150.02. The MCO 3000.1 3 discusses the requirements on how to categorize aircraft based on the percentage that are mission capable and we followed the guidance when reviewing the readiness reports. In addition, through discussions with Plans, Policies, and Operations officials, the R-level was cited as the appropriate level to use when assessing mission capability of an aircraft. Although, Plans, Policies, and Operations offic ials know the DRRS-MC system defaults to 100 percent when a squadron has no aircraft, the system default improperly allows the squadrons to report erroneous squadron readiness and portrays an inaccurate picture of the squadron's true readiness. We accurately stated the number of readiness reports SJ; CRJ;T 32 SECRET

(U) reviewed from both DRRS-MC and Marine Corps Readiness Tool. Plans, Policies, and Operations officials neither provided the readiness reports nor supplied procedures on how to obtain the readiness reports. The information we included in the C-leve! table in the report accurately reflects the balded and underlined information in the C-leve! definitions identified in MCO 3000.13.

(U) In reference to draft report concerns from the Deputy Commandant for Aviation, responding for the Marine Forces Command, information in the draft repot1 was clear and accurate. Specifically, we properly cited the MCO 3000.13 throughout the report. The Chairman Joint Chiefs of Staff Manual 3150.02 is addressed in the MCO 3000.13 that addressed the Service policies. We did not recommend changes to U.S. Marine Corps policies. The CJCSM 3150.02 outlines detailed elements required to be included in the commander's narrative. However, Plans, Policies, and Operations officials did not provide nor were we able to obtain the Squadron VMM-161 DRRS-MC rep011 that contained the required elements. In addition, the Squadron VMM-161 MCRT rep011 we obtained did not identify any of the required elements. The MCO 3000.13 discusses the requirements on how to categorize aircraft based on the percentage that are mission capable and we appropriately followed the guidance when reviewing the readiness reports. Although, the DRRS-MC system defaults to I 00 percent when a squadron has no aircraft, the system default improperly allows the squadrons to report erroneous squadron readiness and portrays an inaccurate picture of the squadron's true readiness. The commander's subjective upgrade to a C-1 was not justified with the response provided because the remarks were not descriptive and did not provide details of the squadron's mission readiness. The severity and frequency of errors identified in the report demonstrated that squadron commanders did not verify the accuracy or completeness of readiness reports.

SECRET 33 SF;CiffiT

(U) Annex. Classified Information Used in the Preparation of This Report

(U) Source 1: SORTS Reports (Document classified SECRET)

Declassify On: 20360929 Date of Source: 29 Sep 2011

(U) Source 2: Unit Status Reports (Document classified SECRET)

Declassify On: 20360929 Date of Source: 29 Sep 2011

--- SF;CRET 34 SECRET Naval Air Force, Pacific Comments

DEPARTMENT OF THE NAVY GOMMANOER r ~AV/\L AIR FORCE PAC IFIC BOX367061 SAf.l DIEGO, CAI.IFORNJA DZ135·7051

4790 Ser N122C/136 23 Jun 13

From: Commander, Naval Air Force, Pacific To: Department of Defense, Office of Inspector General

Ref: (a) DODIG Report, Project No. 02011-DOOOLH-0170.000 (S) (b) COMNAVAIRI'ORINST 4790 . 2B Change 1, 15 Jun 2013

1. Ref erence {a) recommended Commander, Naval Air Forces (Cm1NAVAIRI'OR ) revise reference (b), t he Naval Aviation l•l aintenance Program (NAMP ) , to include detailed procedures f:or f'.lai n tenance Officers to use to verify the accuracy and completeness of Aircraft Inventory Reports and l'lor k Orders before submission.

2 . CO~INAVAIRPAC and COMNAVAIRLANT concur the direction in t he NAMP regarding procedures and responsibilities for verifi cation of Aircraft Inventory Readiness Re porting System (AIRRS) and \'lork Orders (I·IOs) should be i mproved. The follo>~ing changes >~ill be incorporated:

a. Specific respon sibility to validate accuracy of AIRRs bef:ore submis~Jion \'/ill be added to the responnibilities of the t1aintenance Material Control Officer.

b. An increased l evel of. detail and emphasis of importance of verifying the corre ct Eguipmcnt Operational Capability (EOC) code to be used on WOs will be included in the NAf.IP rcsponsibi liti ec. of til"

Collateral Duty Inspector' ~1ork Center Supervisor I r-iaintenance Control

Desk Supervisor I Nnintenancc r~aster Chief Petty Officer , l1aintenance l·late~·ial Control Offi cer, a nd Maintenance Officer.

c. The specific responsibility to review aircraft. readiness rates a nd validate that correct reporting procedures are being followed will be added to the responsibilities of the Maintenaru.:~ Officer.

3. Estimated completion date for changes to the NAMP is 15 Septembe>· 2013. Changes will be promulgated via Naval l·lessage as an Interim Change in advance of publishing the next formal c hange Lo COMNI\VAIRFORINS'J' 4•190. 2B. Point of contact for NAMP COMNAVAIRPAC/CO<~NAVA I RLANT N422C, NA14P Plans and Pol

4. Relevant t:o AIRRS, NAVAIR 6.8 i s .ln - work on jmprovements to AIRRS t hat \•Jill a utomate c ha nges in aircraft statun Erom Tn Reporting to Out of Reporting , and vice versa , based on XRAYs submitted and replicated up-line vj a OOM/1. 'Phi A improvement also automatically changes the

SECRET 35 SECRET

tl·acking of time on all active ~loi·k Orders at the time of receipt of the XRAY. Additionally, the new procedures require ACC approval before acceptance of XRhYs, and make errors in aircraft status more evident. These improveme nts to JIIRRS arE: expected to be completed in December 2 013 .

5 . In addition to the NAI~P change proposal recommended, COMNAVAIRLANT and COMNAVAIRPAC revie,.ed reference (a ) comments regarding readiness data and requirements . We found the suggested source of data referenced thro ughout the document was not the correct source of data for ~!C and FMC as defi ned by the reference requirements document. The DOD 3110.5 should be the reference document utilized in determining readiness data/requirements and not the ANSRR . Additional specific concerns regarding readi ness data referenced in the document are as follows: a . Aircraft Readiness Data Reporting. 'fhe NAMP provides guidelines and policy for a 24/7 weighted metric used to report aircraft readiness data in accordance with the requirements outlined in the DOD 3110.5 via NAVAIR DECKPLA'rE t o OPNAV. The AHCR on the other hand is a snap shot in time of aircraft readiness/material condition, \·lhich is used by the TYCot~ to manage fleet reudincss using Ready for Tasking (R FT ) as the definitive metric. b . Record Type (RT) 79 data. RT-79 data is AV3t~ data and accounts for and depicts 24/7 ma terial degr adation of aircraft a nd systems. There is no correlation to i t and the AHCR data. c. Readiness Reports . Throughout the document, reference ~

6 . COMNAVAIRLANT POC for llviation t•!aterial Director of Aviat non-secure email: Aviation Maintenance ector of Aviation r-Jaintenance non-aecure email: secure 9.~Rc~IUA By Direction

SECRET 36 SECRET U. S. Marine Corps Comments

DEPARTMENT OF THE NAVY HEADQUATERS UNITED STATES MARINE CORPS 3000 MARINE CORPS PENTAGON WASHINGTON, D.C. 203511-3000

7500 DMCS-A JUL U Z013 MEMORANDUM FOR INSPECTOR GENERAL, DEPARTMENT OF DEFENSE (PROGRAM DIRECTOR, READINESS , OPERATIONS, AND SUPPORT)

Subj: INSPECTOR GENERAL, DEPARTMENT OF DEFENSE DRAFT REPORT D2011-D000LH-0170.000, MV-22 SQUADRONS COULD IMPROVE REPORTING OF MISSION CAPABILITY RATES AND READINESS

Ref: (a) DODIG Draft Report D2011-DOOOLH-0170.000 of May 29 , 2013

Encl: (1) Marine Corps Responses

1. Official responses required by the reference are provided at the enclosure.

2. The Harine Corps appreciates the opportunity to respond to the report.

~ ~'~'Director, Marine Corps Staff

SECRET 37 SECRET

UNCLASSIFIED DEPARTMENT OF THB NAVY BBADQUARTBIIS UNITED STATES IIAR!NE CORPS 3000 HARINB CORPS PBNTAQOR ~RINQTOR, DC 20350·3000

APW 7502 09 Jul13

From: Deputy Commandant for Aviation To: Commandant of the Marine Corps

Subj: RESPONSE TO OFFICE OF THE INSPECJ'OR GENERAL OF THE DEPARTMBNTOF DEFENSE MV-22 AUDIT DRAFI' REPORT

Ref: (1) Memorandum: Audit of the V-22's Mission Readiness Rates, Maintainability and Sustainment Costs (Project No. D2011-DOOOLH-0170.000) dated 6 Jun 2011. (2) Memorandum: Reannouncement of the Audit of the V-22's Mission Readiness Rates, Maintainability a!ld Sustainment Costs (Project No. D2011-DOOOLH-0170.000) dated 12 1an 2012. (3) DODIG Draft Report (Project No. D2011-DOOOLH-0170.000).

Encl: (I) DODIG Draft Report responses from MARFORCOM, MARFORPAC, and PP&O.

I. (U) On 06 June 2011, the Department of Defense Inspector General (DODIG) initiated an unsolicited audit of the MV-22 program to determine whether the MV-22 Osprey's performa:nce met the mission capability rate (MCR) requirements. Specifically, to evaluate how the frequency of repairs and replacement of supply parts affected the MY-22's mission readiness from October 1, 2008 through September 30, 2010. Are-announcement was made which expanded the timeframe to extend the audit period to September 30, 2011. ·

2. (U) The Draft Report states one finding: MV -22 squadrons can improve record keeping for mission capability rates and readiness reporting. HQMC Aviation appreciates the efforts by DO DIG and concurs with the finding. The challenges associated with accurate readiness reporting are not new to Naval Aviation nor are they uniquely associated with the MV-22 community. All placforros across Naval Aviation recognize these reporting trends and make a focused effort to ensure proper procedures are followed .

3. (U) The Draft Report has recommendations for Commander Naval Air Forces (CNAF), Deputy Commandant for Plans, Policy and Operations (PP&O), Commander Marine Forces CollUIUIOd (MARFORCOM) and Commander Marine Forces Pacific (MARFORPAC) which require official responses. The consolidated responses from MARFORCOM, MARFORPAC and PP&O ate included as enclosure (1).

4. (U) Naval Aviation relies on multiple data sources and reporting systems for readiness memes. Each system has a unique purpose within the entiro readiness architecture. An expert undemanding of the data associated with each system Is necessary to derive usable readiness information. Proper data enay and procedural execution are critical to accurate reporting; the human interface can create inaccuracies through input error or improper procedures. The example highlighted in the report of an MV-22 without a battery installed demoDl!trates the UNCLASSIFIED

SECRET 38 SECRET

UNCLASSIFIED Subj: RESPONSE TO OFFICE OF THB INSPECTOR GENERAL OP THE DEPARTMENT OF DEFENSE MV-22B AUDIT DRAFI' REPORT

human interface. A battery install on an MV-22 per !he technical publication t~ two M&ines and approximately 20 minutes to accomplish. Batteries are not a low density item. This is a non mission capable discrepancy that was e.rroneously viewed as a mild inconvenience. The fact the aircraft was reported miSllion ready when in fact it still required a simple 20 minute battery install is the shortcoming of the human interface. Minimizing such errors and ensuring procedural correctness is paramount and requires constant emphasis and oversight.

S. (U) Operationally, Defense Readiness Reporting System-Marine Corps (DRRS-Mq reports provide a periodic metric of unit readiness for force-sourcing purposes. The dynamic nature of material and personnel readiness coupled with a binary t~porting system could possibly lead to a reported C-rating that docs not accurately reflect the true readiness of a squadron. To overoomc this potentially misleading statistic, the Marine Corps provides the Commander latitude to make subjective C-leve! adjustments to e!IBure reports most accurately reflect the true readiness of n unit. While the intrinsic value of objective readiness metrics cannot be overlooked, it is the subjective assessment by the Commander that provides the context necessary to fully appreciate a squadron's readiness. The Commander mandates the priorities of his unit. Those priorities shift based on tasking. Thus, the Commander could have a focus on training that quickly shifts to deployment preparation. The status of his aircraft readiness will shift as well to ensure the readiness he requires to deploy. The CoiiUIIllnder takes this into account when providing his units readiness rating.

6. (U) There arc two methods by which aircraft readiness is reported. The Naval Aviation Logistics Command Management Information System (NALCOMIS) report provides in-depth information about aircraft readiness from a previous month and is utilized for long-term analysis and logistical resource planning. The Aircraft Material Supply Readiness Report (AMSRR) is a "snap-shot" in time generally taken at the beginning of each workday and used for day to day planning by the Wing and its supported Marine Aircraft Groups. The human interface is at play. Because the "snap shot" is made at the beginning of a maintenance shift, e.rroneous conjecture is possible for the completion of perceived low intensity maintenance actions (like installing a t.a:tery).

7. (U) HQMC Aviation disagrees wilh !he DODIO's assessment that DoD officials could have deployed units that were not ready for missions. The MV-22 has been combat proven and bas been continuously deployed since 2007 amassing nearly 160,000 flight hours (roughly 20,000 flown in combat). In 2010 aircraft availability and known USMC aviation training standards enabled the Joint Force Air Component Commander to select MV-22s from tbe USS KC8l'!arge to execute the recovery of an P-lSE crew downed in Libya. Several d11y~ lifter the successful recovery of the downed crew, six MV-22s from the same squadron self- deployed from Afghanistan to Italy to provide additional support for Operation Odyssey Dawn and Unified Protector. Routinely MY ·22 crews arc called upon to make unscheduled emergency casualty evacuations. For instance, a sailor aboard USS Kearsarge in need of treatment beyond the ship's capability requited movement to Mombasa, Kenya. This fl ight was in excess of 500 miles, was unscheduled, required aerial refueli ng, and was flown in hours of darkness. In the Pacific, four MV·22s flew nearly 1500 miles from Okinawa to Guam while aerial refueling tlu'ee times. During the 6,5 hour filgbt the MV-22s rendezvoused with P/A-18 escorts to execute simulated UNCLASSIFIED 2

SECRET 39 SECRET

UNCLASSIFIED Subj: RESPONSE TO OFFICE OF THE INSPECTOR OBNBRAL OF THE DEPARTMENT OFDEFBNSE MV-228 AUDIT DRAFT REPORT troop insert into a dynamic aO

8. (U) HQMC Aviation will continue to emphasize the importance of accurate record keeping for mission capability rates and readiness reporting. All recommendations from the DO DIG which will improve the accuracy of these reports without degrading or precluding overall mission accomplishment are greatly appreciated.

9. (U) My POC for this matter is ~a nd can be reached at

UNCLASSIFIED 3

SECRET 40 SJ;CRET

UNCLASSIFIED

DODIG DRAFT REPORT-DATRD MAY 2013 D2011-DOOOLH-0170.000

"MV-22 SQUADRONS COULD IMPROVE REPORTING OF MISSION CAPABILITY RATES AND READINESS"

U.S. MARINE CORPS COMMENTS TO DODIG RECOMMENDATIONS

RECOMMENPATION 1: l. (U) We recommend the Commander, Naval Air Forces, revise the Commander, Naval Air Forces Instruction 4790.2A, "Naval Aviation Maintenance Program," November 10, 2009, to include detailed procedures for maintenance officers to me to verify the accuracy and completeness of aircraft inventory reports and work orders before submission.

PP&O. POR RESPONSE: (U) No comment from POR.

MARFQRCOM RESPONSE: (U) Concur with recommendation and will open dialogue with Commander, Naval Air Forces to reinforce beyond Commander, Naval Air Forces Instruction 4790.2A paragraphs 3.5'.3, 3.5.4, and 5.2 to include detailed procedures for main!Cllllllce officers to use to verify the accuracy and completeness of aircraft inventory reports and work orders before submission.

MARFQRPAC RESPONSE: (U) No comment from MARFORPAC.

RECOMMENDATION Z: (U) We recommend the Deputy Commandant for Plans, Policies , and Operations:

a. (U) Require mandatory training and establish refresher training for all MV -22 operations . personnel on how to complete readiness reporu in the Defense Readiness Reporting System-Mr..rine Coq>s .

b. (U) Revise the Commander's Readiness Handbook, January 2012 to include at a minimum:

(I) (U) Detailed examples of the Commander's category level remSik& and equipment condition level remarks.

(2) (U) In the Commander's Checklist, the equipment condition data elements and a requirement for the Commander's signature on the readiness reports to attest to the accuracy of informs lion provided.

c. (U) Require submission of the revised Commander's Checklist with the readiness report.

PP&O, POR RESPONSE:

UNCLASSIFIED Enclosure (1)

SECRET 41 SECRET

UNCLASSIFffiD

a. (U) Concur.

b. (U) Revise the Commander's Readiness Handbook, January 2012 to include at o minimwn:

(1) (U) Concur.

(2) (U) Partially concur. There should not be a requirement for commanding officers to sign readiness reports. With the Defense Readiness Reporting System's (DRRS) incorporation of the Global Status of Resources and Training System (GSORTS), there are no DoD, Joint Staff, or Service readiness directives requiring commanding officers to sign a readiness report or keep paper copies of those reports, as used to exist when GSORTS was a separate reporting system. The cost to implement electronic signatures into DRRS-Marine Corps (DRRS-MC) and/or DRRS-Strategic (DRRS-S) would not be worth the benefit. The Marine Corps will reemphasize that commanding officers are responsible for the accuracy of their reports.

c. (U) Nonconcur. The Commander's Checklist is part of the Commander's Readiness Handbook, which provides broad-level readiness ioformation and guidance targeted to commanders and their principal staff. Consequently, the Commander's Checklist, which is part of the Handbook, is not constructed to be a detailed checklist. MCO 3000.13 is the source for detailed instructions for readiness report submissions. The latest version of the Commander's Readiness Handbook emphasizes the importance using the MCO, when it states in the introduction, ·

"If yo11 have not done so already, familiarize yourself with Marine Cozps Order 3000.13 Marine Cozps Readiness Reporting Standard Operating Procedures. Ensure that those in your unit who deal with readiness-related matters are familiar with it, contents as well."

Additionally, there are no DoD, Joint Staff, or Service readiness directives requiring a checklist to be submitted with rcadine.~s reports. T'ne cost to incorporate a checklist submission into DRRS-Marine Corps (DRRS-MC) and/or DRRS-Strategic (DRRS-S) would not be worth the benefit.

MABFORCOM RESPONSE: (U) No comment from MARFORCOM.

MARFQRPAC RESPONSE: (U) No comment from MARFORPAC.

RECOMMENDATION 3: (U) We rccoui.mend the Commander, Marine Forces Command, and the Commander, Marines Forces Pacific:

a. (U) Implement mandatory training and establish refresher training for all MV -22 maintenance perSonnel on how to complete aircraft inventory reports and walk orders outlined in COIIIIIlllll.der, Naval Air Forces Instruction 4790.2A, "Naval Aviation Maintenance Program," November 10, 2009.

UNCLASSIFIED Enclosure (I)

SECRET 42 SI::CRET

UNCLASSIFIED

b. (U) Require MV-22 squadrons track and report on the accuracy lllld completion of ai.rcrnft inventory reports and worlc orders.

c. (U) Require subordinate MY·22 organizations and activities, at all levels of commlllld, to certify the accuracy of readiness reports submitted.

PP&O. POR RESPONSE:

a. (U) No comment.

b. (U) No comment

c. (U) Con~'\11', if the intent of the recommendation is that the accuracy of readiness reports are the responsibility of the organi7.ations' commanders and that reporting orgllllizations develop an' audit program to periodically check readiness reports for accuracy. Higher headquarters should not require reviews of subordinate units' reports prior to submission. The MARFORs and Headquarters Marine Corps regularly review unit reports and direct needed corrections and remarks through the chain of oommlllld.

MARFQRCOM RESPONSE:

a. (U) IA W Naval Aviation Maintenance Program (NAMP; COMNAV AIRINST 4790.2_}, the Maintenance Material Control Officer (MMCO), Maintenance Conttol, and Maintenance Administration Marines arc required to attend CNATTU courses applicable to OOMA NALCOMIS Aircraft Inventory Reporting and Work Order (WO) Documentation. Additional mandatory, refresher training Is provided via weekly/monthly technical training, per the required Squadron Monthly Maintenance Plan. NAMP program areas 2900 (Maintenance Conttol), 3200 (Aircraft Records and Reports) and 3600 (Data Analysis) are all progrnms areas which are inspected separately, and semi-annually, by the local MALS, Wing and Commander, Naval Air Forces (CNAF) Ins_pection Team. T'nis inherently inciudcs internal inspections conducte

b. (U) Current NAMP policy direds the MMCO to "es!Jiblish prooedures to monitor lhc SCIR System and such other reports (as required)". We will recommend a NAMP Change Request to specify that MMCOs must validate all SCIR related WOs, prior to reporting; and to clarify "such other reports" by specifically identifying, the program of record, Aircraft Inventory Reporting System (AIRRs), which must also be validated by the MMCO prior to reporting. This is reinforced by NAMP inspection criteria for program area 3200 (Aircraft Records and Reports), w~ch requires timely and accurate Squadron reporting. This program is inspected internally by QA, and extmuilly by the local MALS, Wing, and CNAF to ensure compliance. For a more long term solution, Fuwre squadron-level "One NALCOMIS" (NI'CSS OA)-initlal fielding fur

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MA1.S in FY15 and for Squadrons in FY17-will reintroduce the Squadron Work Center Supervisor & Squadron Data Analyst to the WO validation process prior to AIRRS and OECKPLATE uploads. Both short/long term efforta, will greatly improve: the ability to concur/non-concur with proposed out of reporting (OOR) repair actlons/eventsfcommence completion times; the identification of reporting errors at the source; facilitation of accurate and improved MCR; and overall Readiness of all USMC TfM/S aircraft, to include the Rubject MV- 22s.

c. {U) The proposed NAMP Change Request discussed under the second recomm.endation facilitates accuracy and certification at the Squadron level. Additionally, the current MAl.S AMO oversight of Squadron OOR aircraft, via the Naval XRAY in .AIRRS (enforced by NAMP inspection criteria), adds another lnyer of verification and opens lines of communication between echelons. We will recommend a NAMP Change to the IMA NAMP CSEC program Area (3200) Aircraft Records and Reports to amplify the required frequency of the directed AMO certifications. Additionally, semi-annual Wing Inspections!Assists provide additional opportunities to execute intemaUcxtemal audits to confirm accuracy.

Regarding readiness reporting in DRRS-MC • MARFORCOM regularly screens subordinate unit reports and directs resubmissions through the chain of command. USMC policy requires unit commanders to approve their repons in DRRS-MC. This policy is regulady reinforced during training for commanders, operations officers, and unit readiness officers.

MARFORPAC RESPONSE:

a. (U) Concur. lAW Naval Aviation Maintenance Program (NAMP: COMNAV AIRINST 4790.2), aU Optimized Organizational Maintenance Activity (OOMA) level work center supervisors shall complete the Naval Aviation Organizational Maintenance Activity (OMA) Work Center Supervisor's course (Course C-555-0045). In this course, the basic documenration for work orders is taught. Since the implementation of OOMA, the work center supervisor block was remcved and this has been poe'licusly addressed. This should not preclude the work center supervisor to be engaged in screening for proper documentation. As a result, "One NALCOMIS" wiU bring the work center supervisor back into the sign off chain; however, this will not happen until FY17. Until this happens, the CoUateral Duty Inspector (CDI) carries the responsibility for proper documentation for his/her work center. Because there is no requirement for the CDI to attend the Basic OOMA Documentation Course (C-555-0047), MFP ALD recommends adding a supplemental task·in Advanced Skill Man.agement (ASM) to be implemented aa part of the CDI !mining syllabus. This will allow the pro~pcctive CDI to be fonnaUy tlllined prior to signing off work orders in OOMA. Additional and follow on training can continue during mandated technical training sessions. Although the Maintenance Material Control Officer (MMCO), Maintenance Control and Maintenance Administration Marines are required to take a higher-level documentation course, it serves no purpose, as they are no longer in the sign off process and no longer have the ability to com:ct deficient documentation. In addition, the Wing/MALS should revlewfupdate their policy for the execution of subordinate uni~training day requirements. This will renew higher headquarlell!' emphasis on the importance of technical training.

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b. (U} Concur. In an attempt to improve accuracy of aircraft inventory reports, request Space and Naval Waxfare Systems Center (SPA WARSYSCEN) fix the interface between OOMA Top Tier and DECKPLATE to Cll8ure all generated XRA YS properly replicate. Currently, all XRAYs are submitted through OOMA. The squadron maintenance administration will send the draJ,'t XRAY to MALS maintenance administmtion for review prior to release in OOMA. Both the squadron and MALS will review Aircraft Inventory and Readiness Reporting System (AIRRS), which is enforced by the NAMP inspection criteria, to ensure there are no errors after replication. If after 48 hours a replication has not occurred, a trouble report is sent to Commander Naval Air Forces for assistance to locate the XRAY. Jn this scenario, the AIRRS no longer matches the Aircraft Material Supply Readiness Report (AMSRR). This delay causes improper reporting of aircraft readiness. If replication was successful, then the sequence number is written on the draft XRAY which was submitted by the squadron to the MALS. This substantiates the importance of the oversight by the MALS to ensure replication has occurred and readiness is properly reported.

Currently, squadrons are required to create a 3M summary report for use by the squadron Maintenance Officer. The NAMP states in paragraph 14.3.3.1, '"The most widely accepted method of publishing the results of maintenance analysis is through the use of monthly maintenance summaries. This paragraph establishes guidelines regarding content, fOI11l81, and distribution of those portions of maintenance summaries that arc produced to satisfy local requirements." This is general in nature and higher headquarters should outline who their subordinate unil3 submit their 3M summary to. Once distribution has been established, MFP ALD reoommends the 3M swnmary to include Invalid Work Order Work Center comparison. MAlS wiU consolidate to show efforts across the Marine Aircraft Group. Wing will validate and inspect during ALMAT. While the transition to OOMA sped up information output, it did inadvertently increase the role of the COl and reduced the role of the squadron analy~t. M it removed bimlher from the opportunity to screen and correct improper work order documentation. In OOMA, the CD! is the last line of defense in ensuring work orders are documented correctly. Apart from some minor adjustments "action taken" and "transaction codes", the squadron analyst no long has the ability to correct work orders after the CDI has signed off on it, whether it is accurate or not.

c. (U) Concur. MARFORPAC regularly screens subordinate unit reports and directs resubmi$$ions through the chain of command. USMC policy requires unit commander to approve their reports in DRRS-MC. This policy is enforced during training for commanders, operations officers, and unit readiness officers.

PP&O. POR ADDITIONAL TECHNICAL REMARKS!

I. (U) Page 4, last paragraph, first sentence should have added on to the end of the sentence, "which superseded and cancelled the former." Rationale: Clarity. There has been only one Marine Corps Order pertaining to readiness reporting at a tinte.

2. (U) On pages 4-5 and i.u other portions of the report, the units are cited as not reporting required R-level remarks per CJCSM 3150.02 and CJCSM 3150.02B. Marine Corps unlts are not required to have or use these docuuu:nts. Marine organizations use MCO 3000.13 for

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UNCLASSIFIED readiness reporting and per page B-1, paragraph 5 of that document, mandatory remarks for units not reporting R-1 are:

''Explain why, what the impact is on the unit's mission(s), what is being done to correct the problem and what assistance is required. EXAMPLE: MALS-XX HAS ONLY 70% OF ITS IMRL: REMAINDER SHIPPED TO OEF. CRITICAL IMRL GEAR COMING FROM MALS-YY BY 1 DEC, WlllCH WlLL ENABLE UNIT TO PROVIDE MINIMAL SUPPORT TO MAG."

DRRS-MC fields already cite the number of authorized, assigned, required, and available equipment. The remarks required by MCO 3000.13 cover the requirements of the CJCSM.

3. (U) Tables 2 and 4 of the report do not accurately state the number of readiness reports that were submitted by the squadrons during the period examined by the report. The number of rea diness reoorts c1t'edbth bV e report an d the actual num ber subm.lll'ed are: MV-22 SQuadron DoDIG Repart Actual Number of R~orts 161 44 21 162 51 14 165 13 6 166 29 17 264 63 24 365 . 59 30 Total 265 112 Thill also 1mpacts the quantities.. and percentages of squadrons ctted for maccurate reports.

4. (U) Pages 12-13 should not fault squadrons for rcportingR-1, when there are no aircraft in the unit. Rationale: S-Jevels, not R-levels, are used to report the number of aircraft in a unit; DRRS MC defaults to 100% when R:::0/0; and the percentage would not change the units' ovezall readiness assessment from G4 or C-5 due to a S-4.

5. (U) Table 3 paraphrases MCO 3000.13 C-level definitions. The report should accurately report the definitions or state that the table is paraphrasing.

MARFQRCOM ADDITIONAL TECHNICAL REMARKS:

1. (U) Pages 4-5, and throughout: The report coven; a period that bridges SORTS and DRRS MC reporting, but quotes from MCO P3000.13D as if it were the current order (it was cancelled with thereleaseofMCO 3000.131n1uly2010).

2. (U) Page 11 discusses shortfalls in our unit narrative remarks for squadrons reporting R- 2!3/4. They quote joint policies requiring specific comments, but these joint policies are not fu lly echoed in our Service policies. Unilll follow USMC Service policies. If this does not meet DOD I IS requirements, the DO DIG should recommend changes to USMC policies, not hit the units for following USMC directives.

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3. (U) Page 12 states that [VMM-161) "The Conunander's R-level remark did not include the required data elements to explain the types of aircraft with problems, number of authorized, required, assigned and available aircraft; an explanation of the problem cause; assistance already requested; and any further actions required .... " Much of the missing data can be foWid in the specific data fields of the DRRS-MC report, and it is WIClear why the squadron~ to restate the data within the narrative oorrunents.

4. (U) Pages 12-13 state that squadrons with no aircraft should report R-4. Aircraft shortages are a supply issue, not an R-ratiog issue. Our policy does not state that 0/0 should be treated ns 0%, and DRRS-MC treats it a.~ 100%. This does not alter the overall assessment, because a squadron with zero aircraft has an S-rating of S-4, leading tO the same overall C-4 or C-5 assessment

5. (U) Page 15 finds that VMM-264 did not justify his subjective upgrade to C-1, with his remark that "the squadron is able"to complete the mission with the aircraft on hand." Given the definition of C-1 as "Could execute full wartime missions", tlie statement seems to justify the upgrade.

6. (U) Page 16 fmds that "MV-22 Squadron Commandea did not verify the accuracy or completeness of the readiness reports, including information required for the R-level and C leve!.", but does not document such a sweeping conclusion. The only example it provides is VMM-165 reporting R-1 when it possessed no aircraft. As noted above, SORTS and DRRS-MC treat 0 of 0 as 100% for R-rating purposes. A squadron with zero aiicraft has III\ S-rating of S-4, and therefore C-5 was appropriate in this case.

MARFORPAC ADWTIONAL TECHNICAL REMARKS: No conunents.

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