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involved in our procurements on even relatively small dollar amounts, which take such a long time to process that even an apparent low bidder on a job has an almost impossible task of holding his price and his delivery capabilities, especially in view of today's double digit inflation. For example, it takes about 1 year from the announcement of a program from the Government to an award of contract. That's an average. Sometimes less, sometimes more. During that time, the contractor must spend a lot of administrative cost, maintain his capability to meet the job, maintain his delivery position. A solicitation typically goes out, has a 30- to 45day response time. If the procurement is a highly technical one, as it is mostly in our industry, it requires an extensive proposal and a detailed auditable cost package. And it has to be time-phased to usually a very ambitious delivery schedule. The contractor in anticipation of an early award must keep his capability to deliver, charge to his overhead expenses, until the contract is awarded. If there is a substantial delay in executing the contract, the contractor is very frustrated by his mounting costs. If he increases his bid to cover the long-time phase that he expects, he usually loses the bid.

The third point is military specification versus commercial product. The mil specs on special electronic components serve a very useful purpose when they describe the application for the product and usually define the environmental extremes over which it can operate. They also serve to standardize the manufacture of frequently used components. The problem with mil specs has to do with technical obsolescence. The computer-oriented devices in today's market, where technology is changing rapidly-high performance, low cost, semiconductor devices for instance, are being developed and are being spread in worldwide commercial use before the mil specs are modified in order to create or utilize this modern technology. The Government frequently can utilize the equipment that already exists. However, when it comes to procurement, the Government adds mil specs which may increase the cost and force older and less modern components into the design.

We also suffer from the interest charge problem, which has been adequately covered I believe. The contractor needs the right to collect interest costs from the Government for slow and untimely payments. At present, the only way we have to do that is to file a claim. The claim, and the process of the claim, is costly to both sides.

And lastly, I believe, a topic called small, inexperienced companies, and this deals with some subcontracting work that we've done in the past. A company doing business with the Government for the first time has a lot to be wary of, especially if he's small. The Federal procurement system may subject him to a cost that he didn't bid in areas of financial reporting and audits and procurement approvals, specification rigidity, quality control, and many others. We have seen this result in contract terminations, no product to the Government, hardship or even bankruptcy to the small company. In summary, one could conclude that a company should be aware of these requirements and protect himself against them, but too often the vast Government $100 billion pocketbook is too

Mr. BRETTELL. Thank you, Mr. Danforth. We are in the generator business, a business that is not unrelated to Wilcox Electric. We provide the units for the military which generate the electric power to operate his devices. We've been in the business with the Federal Government for more than 40 years, and I have been with the company for about 15 years. For more than 20 years prior to that I was in the Government procurement business on the other side of the table, so I have the dubious advantage of having seen the Government procurement process from both sides. I think perhaps all our remarks are directed toward the same general area, but I do have some comments to make that are in a little different orientation-in the contract administration field in the military department per se.

We deal with the Federal Aviation Administration also who buys under the Federal procurement regulations as opposed to the Defense acquisition regulation. In the Department of Defense, the contract administration is all through an organization called Defense Supply Agency-DSA-which was established about 20 years ago as a result of Project 60 initiated by the then Secretary of Defense McNamara. The DSA was originally set up to operate two general agencies: one, Defense procurement offices, which actually did the buying; and contract administration offices, which would administer the contracts once they were purchased. The theory of this was good. There wasn't anything wrong with it at all. The practical application, however, after the organization was developed, lost sight of the original goal. The contract administration offices, although they were developed and staffed with very adequate, well-trained people, never did get the authority to administer the contracts. The result is that the buying offices, who never were really set up, organized, and staffed to conduct contract administration, have retained the contract administration authority for themselves. They don't have the people or the know-how to do it. The contract administration people are sitting out here in the cities with nothing to do and no authority to do it. So in reality, in spite of the fact that DSA has an organization and qualified personnel to perform contract administration, they're really no more than a message center; they do generate delays and redtape as a result. I understand it is the purpose of these hearings to try and eliminate such redtape. The contract administration function is a very serious one and should be transferred from the procurement offices to the contract administration offices. It needs attention because it's the heart of contracting in the Government. These DSA-DCASMA people are local, are on the spot; they're wellqualified in contracts; they're well-qualified in the product that we produce. They are here, available for us to talk to eyeball to eyeball. They know our plant, our personnel, our product. They can look at the problem on the spot and they can make a pretty welleducated decision, but they're not permitted to simply because of the authority lines.

The second area I'd like to address is testing. I suppose there have been a lot of jokes over the last 100 years about Government testing, and it's true. We practically wear the equipment out testing it. But, there are three areas in particular which I really

believe need to be addressed. (A) In each contract that we enter into, there is a part of that contract called preproduction testing. This involves several units of the first production lot which are subjected to a particular series of testing which may take anywhere from 6 months to 2 years and may cost, characteristically, $1 million. It's not uncommon at all-as a matter of fact it's the rule that a contractor like ourselves would get a contract for exactly the same item that we're producing today-a follow-up contract and be required to conduct a complete new set of preproduction testing in spite of the fact that we offer $800,000, $900,000 or $1 million to waive that testing. The decision not to waive the testing is very often based on a decision by an engineering group in the process that-well, you're using a different component here than you used in the last contract; therefore, we have to go through all the testing again. Now they lose sight of the fact that the component in question is identified and specified by detailed Government drawings. So that if it's made any different than the drawings, they won't accept it. If it's made exactly like the drawing and it doesn't work, it's a question of what the Government wants to do with their product. Additionally, it contradicts the spare parts buying practices in which the Government buys these same components as spare parts from any one of a number of manufacturers and does not get the benefit of preproduction testing. There's a lot of money, in my opinion, wasted in preproduction testing that could be saved by prudent business judgment and testing of a specific component, rather than an entire product. (B) In another area of testing, we have what's called Component Equivalency. This is a matter of developing an alternate source for a component that has already been tested in preproduction testing, where we have a sole source—and we have one in a current project which I explained to Mr. Brewster yesterday. It's a radiator, much like the radiator in your car. It cools a diesel engine on a generator set. The original design included a radiator from a reputable radiator manufacturer who as a sole source, since he was approved on the original unit, simply takes his bite at the Government every time a bid package comes out. Either there is a production package from us or a spare part package directly from the Government. In our efforts to develop an alternate source for that item to generate a little competition and to try to keep the price down, we came up with another perfectly well-qualified nationally known radiator manufacturer and submitted a proposal to the Government to install a couple of these radiators on units that we are producing for another preproduction model test and test them during our preproduction test to qualify them. That was denied on the basis that the preproduction model test was not sufficient to qualify the radiator. Now the basis for the preproduction model test itself is that we're using a different generator than we're using on the current contract; therefore, what they're really saying is we're going to qualify the generator which produces the kilowatts on this test but that's not enough testing to qualify the radiator. These things are not consistent and they are a tremendous waste of money; there's no question about it. Additionally, it's a tremendous waste of time because these preproduction tests are going to take months and

railroad hump test. It's exactly what the name implies. This is a situation in which we take a generator set and tie it to a flatcar, run it on top of a big ramp, and down here on the bottom we load a gondola car with about 200 tons of steel and block it and brace it and lock it down to the track, and then we run this other one down the ramp going 10 miles an hour. When it collides, the impact is severe. There isn't any question about it. All sorts of things happen. Senator Danforth, I've been in this business for more than 35 years and I have never yet ever seen a generator set rendered inoperable because of a railroad hump. And I can tell you, frankly, that we spend a lot of money and a lot of effort and a lot of extra steel in every generator set to pass that test.

Senator DANFORTH. Can I just ask you to elaborate on that. The machines you make, as I understand it, are the machines that are wheeled out at airports, isn't that correct, and hooked up to airplanes?

Mr. BRETTELL. Yes, sir. Many of them are.

Senator DANFORTH. To keep the airplane engine warm or whatever?

Mr. BRETTELL. They're used to start the engines. They're also used to energize the electrical system in the aircraft while it's being maintained.

Senator DANFORTH. And you see them at airports every time you go to the airport. You see these little trucks

Mr. BRETTELL. Right.

Senator DANFORTH [continuing]. And they're wheeled out and they're plugged into the plane and you keep the electricity going? Mr. BRETTELL. That's correct.

Senator DANFORTH. And the temperature maintained, right?
Mr. BRETTELL. Right.

Senator DANFORTH. Do you make these for, say, TWA?

Mr. BRETTELL. No, we don't.

Senator DANFORTH. Just in the military?

Mr. BRETTELL. For the Air Force.

Senator DANFORTH. But other people make similar products to be used in the private sector?

Mr. BRETTELL. That's right.

Senator DANFORTH. Now then, one of the tests that you have to make when selling these products to the Government is to put your truck-like device on a railroad car and to put that railroad car at the top of an incline. And at the bottom of the incline is another railroad car which is loaded with heavy material and at a speed of 10 miles an hour the railroad car goes down the ramp and collides with the other railroad car and if your machine is all right at the end of that collision, it meets the test?

Mr. BRETTELL. That's correct.

Senator DANFORTH. What is that testing process called? What's the name of that?

Mr. BRETTELL. Railroad hump.

Senator DANFORTH. Is that done each time you turn out one of

Mr. BRETTELL. No, it's done at the beginning of a contract on representative units, but we don't hump a unit once; we hump it several times. We hump it heading that way [indicating] and we turn it sideways and we turn it backward and we turn it the other side. So, we hump it several times. And this thing is so severe-Senator DANFORTH. That's called humping?

Mr. BRETTELL. That's called humping. You see this in the railroad yard once in a while in which they-in a switchyard where the switch engine will have several cars and he'll-the switch engine will get them going a little bit and then he'll disconnect from them and the switchman will make a switch in track and these four or five cars will go off and they'll bump into another car and they'll hook up and become part of a train.

Senator DANFORTH. Is the reason for that test-has anybody ever told you the reason for the test?

Mr. BRETTELL. Well, I get on my soapbox every once in a while, every time I get the opportunity for this, but I'm about to give up on it after 30 years. They say, "We've had so much equipment ruined because of railroad hump, that this is a necessary test for the military." I keep saying, "Well, show me one. Show me a picture of one." I've been in the thing for like I say 35 years. I've never seen one and I've been close to them. I've spent 22 years in the military service that uses them.

Senator DANFORTH. How are these shipped? Do you make them here in Kansas City?

Mr. BRETTELL. Yes, sir, we do.

Senator DANFORTH. And they're shipped from here to, say, Fort Scott Air Force Base in Illinois?

Mr. BRETTELL. We ship them all over the world. We've never ever shipped one on a railcar.

Senator DANFORTH. Thank you.

Mr. BRETTELL. The testing, to generalize-
Senator DANFORTH. How do you ship them?

Mr. BRETTELL. We ship them on trucks.

Senator DANFORTH. Well, that's a whole new area of testing. [Laughter.]

Mr. BRETTELL. Yeah. Right. It's interesting that they put all these trucks on railcars and nothing happens to them. It is an example of the redtape that we get into and we get our minds fixed on certain things and it's very difficult. Everything resists change. It's difficult to get it turned around. But it is an expensive operation. It's an example of a real waste of money, time, and effort, I think, that somebody ought to take a look at.

Option clauses are a problem with us because most of our contracts are long production time contracts. It's not uncommon at all that we would bid on a contract much the same as Wilcox in which we would not begin production for 11⁄2 or 2 years and then production would continue for 3 years. So we may be looking at a 5-year production lead time on our contracts. The Government has the same problem that we all have in trying to predict what the requirements are going to be for the future period of time and predict what the prices are going to be. They put option clauses in contracts that are so vague and so generally worded that they're

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