A Letter to the Leaders of the DOGE

Jan 15, 2025

Corporate

Dear Mr. Musk and Mr. Ramaswamy:

When you agreed to support President Trump by leading the Department of Government Efficiency (DOGE), he stated that the DOGE will play an essential role in the “Save America Movement.” Without a doubt, the most urgent undertaking by the DOGE to save America is to ensure the U.S. government is capable of fulfilling its most fundamental responsibility – keeping our homeland safe by securing our borders and protecting and defending American interests around the world.

America’s current defense acquisition system is slow and bureaucratic and does not provide our warfighters with new capabilities at the speed of relevance to the threats they are facing. It has a structure and a culture that stifles innovation and discourages risk-taking.

I write to you today to express my desire to help the DOGE make America’s national defense ecosystem great again. As a multi-decade leader at the top of the defense industry, I understand the Pentagon’s acquisition processes, the evolving global threat environment, and where we have vulnerabilities that our enemies may exploit.

Today’s national defense ecosystem is not optimized to build the modern “Arsenal of Democracy 2.0” that we urgently need to deter and defeat China, Iran and other rogue nations and non-state actors. In my most recent , published in POLITICO in November, I discussed how victory in this new era of great power competition will be determined by the ability to fuse software, artificial intelligence and hardware in ways that give our warfighters decision dominance, or the capability to “sense, understand, decide, act and assess faster and more effectively than any adversary.” In other words, shorten the “kill chain.”

The first Trump administration was successful in introducing modernized, streamlined acquisition models into the Department of Defense (DOD). A key example was President Trump’s creation of the Space Force in 2019. This was a powerful catalyst that drove missile warning/missile defense capabilities forward at a fraction of the cost of a typical DOD program. In partnership with the Space Development Agency, we rapidly repurposed our commercial weather monitoring technology to track hypersonic missiles, providing a missile warning capability on a delivery schedule not seen in decades. Simply put, the first Trump administration laid the groundwork for breaking through the DOD bureaucracy. Now, the DOGE can finish this vitally important job.

For the past several years, ɫ��ֱ�� has successfully pursued a bold strategy as the Trusted Disruptor in the defense industry. Based on our experiences, we have identified four policy recommendations to unleash American industry and make defense acquisition more efficient.

1: Eliminate Duplicative Cost Accounting Standard (CAS) Requirements

Inefficiency: “Traditional” defense contractors – meaning entities that have provided a product or service to the DOD within the past year – are required to follow the government’s Cost Accounting Standards. This is in parallel to the Generally Accepted Accounting Principles (GAAP) that are required by the U.S. Securities and Exchange Commission (SEC). Having to maintain “two sets of books” creates a significant labor and cost burden on defense technology companies. It distracts from our core mission to provide more innovative and affordable solutions to warfighters at greater speed.

Recommended Solution: Eliminate CAS requirements for all companies in the defense acquisition system. CAS requirements were originally created to help protect taxpayers from misallocated costs or unreasonable expenses in defense contracts. However, the pivot away from cost-plus contracts to fixed-price contracts has reduced this threat. The highly competitive nature of our industry also compels us to focus intently on controlling costs. Because CAS is mostly duplicative of GAAP, reasonable accounting standards and practices will still be maintained while greatly reducing regulatory burden, including a significant number of government audits that often take years to complete. This free-market solution accomplishes the same goal of protecting taxpayers that the CAS requirements were originally created to achieve.

Most importantly, eliminating CAS requirements will free up more resources within the DOD and for companies like ours to invest in technologies and infrastructure, which enables us to better serve our military customers. Notably, our enemies are not shackled by CAS requirements.

2: Establish a Central Contracting Arm within the Office of the Secretary of Defense

Inefficiency: To inject greater speed and agility into defense acquisition, policymakers at the Pentagon and on Capitol Hill have sought to devolve decision-making to the services. The result has been a system driven from the bottom up that is unresponsive to the priorities of the commander in chief and the people who elected him. For example, during his first term, President Trump released a visionary plan for a 500-ship Navy that would include hundreds of unmanned maritime vessels, an efficient action designed to expand defense capability and leverage technology without the concurrent addition of more costly naval personnel. The Biden administration curtailed these plans despite near continual harassment of our ships in open waters by our nation’s enemies. The Navy has made little progress in fielding these strategic capabilities.

When procurement processes and decision-making are siloed within each service, the result is a hodgepodge of platforms and systems that lack the ability to operate cohesively across domains. In the modern battlespace where the key to victory is the ability to overwhelm your adversary with converged effects, a lack of interoperability can be fatal. At best, a service-centric acquisition model results in redundancies and unnecessary overlap between platform or system capabilities across the military branches. At worst, it allows for major gaps in capability – blind spots that service-level procurement leads can’t see from their narrow viewpoint. We’ve seen it in programs like the U.S. Air Force’s Advanced Battle Management System (ABMS) and the U.S. Navy’s Overmatch – efforts by each respective service to contribute to a DOD-level Joint All Domain Command and Control (JADC2) capability that are woefully disconnected.

Alternative procurement pathways and offices have also been created to circumvent the existing antiquated system. Ironically, the result has been an alphabet soup of new bureaucracies including DIU, APFIT, RDER, T-REX, SCO, OSC, AFWERX, SOFWERX and NavalX. Despite these efforts, many contracting officers are either unfamiliar with these new pathways or choose to default to the status quo.

Recommended Solution: Establish a central Office of the Secretary of Defense contracting organization that manages joint procurement programs (like JADC2). While it could start with joint programs, the DOD can gain more efficiencies and drive greater speed by migrating over time to a fully centralized purchasing office. It would also sharpen the DOD’s focus on interoperability, which often isn’t the priority of the individual services. Key allies including the United Kingdom and Australia have already shown how to successfully implement a centralized contracting system. Australia has completed several joint acquisitions that span multiple services.

3: Reform Inefficient Requirements for Certified Cost or Pricing Data

Inefficiency: For the majority of DOD procurement dollars spent, the entire supply chain must submit detailed cost estimates that are then audited, reviewed and negotiated. This adds 1-2 years to the acquisition process and requires a significant amount of labor and cost on the part of both industry and the DOD.

Recommended Solution: Require certified cost and pricing data for only the largest sole-source acquisitions (e.g., carriers, submarines, aircraft) or significantly raise the threshold for acquisitions that require certified cost or pricing data currently defined in the Truth in Negotiations Act (TINA) from $2 million to $500 million. The DOD already has a significant amount of data they can use to determine the cost of products and services and set a reasonable price based on the value they provide. By eliminating this requirement for a large number of acquisitions and negotiating costs in a free-market way, just like a consumer would do with any other commercial business, we can deliver critical capabilities into the hands of warfighters significantly faster and at a lower cost.

4: Limit Time-Wasting and Costly Contract Award Protests

Inefficiency: Currently, companies not selected for a government contract can lodge a formal protest of the award, significantly delaying delivery of critical solutions to the warfighter and adding to program costs. There are situations where contractors have legitimate concerns about how awards were made such that the U.S. Government Accountability Office (GAO) should independently assess. However, protests have become nearly automatic in the defense contract award process. In the case of Next Generation Jammer-Low Band, a contract that ɫ��ֱ�� was initially awarded in December 2020, a competitor filed a protest that led to an almost four-year delay in delivering a vitally important capability to the U.S. Navy. Furthermore, American taxpayers were stuck holding the bill for the GAO’s comprehensive review. While the 2025 National Defense Authorization Act (NDAA) attempts to address this issue, I believe we can and should go further to limit protests.

Recommended Solution: Limit a contractor’s ability to protest a contract award to three times per year. In the NFL, coaches have a limited number of opportunities to challenge the referees’ calls – and if they lose a challenge, they lose a timeout. The DOGE should recommend a similar policy for protests by federal contractors and require them to cover the costs of the GAO review if the result is not in their favor, consistent with the requirements of the 2025 NDAA. This would discourage the obstructionist behavior we have seen in recent years and force contractors to utilize the protest option in only the most egregious cases. Most importantly, it will help prevent significant delays in delivering crucial capabilities to our warfighters.

Take Action to Build the “Arsenal of Democracy 2.0”

These are just a few actions that must be taken to break through bureaucratic barriers and build the “Arsenal of Democracy 2.0.” Through a partnership between the DOGE, efficiency-minded allies in Congress, and America’s defense industry, I’m confident we can develop the modern national defense ecosystem that warfighters need and taxpayers deserve.

Removing redundant and unnecessary regulatory burdens on the defense industrial base will open the floodgates for broader American industry participation, unleashing fiercer and more rapid ingenuity for the benefit of our warfighters and our nation.

As the Trusted Disruptor in the defense industry, ɫ��ֱ�� is supportive of your efforts and is familiar with seeking to disrupt an otherwise entrenched environment. In addition to my role leading this cutting-edge defense company, I was recently elected Chairman of the Aerospace Industries Association (AIA). My priorities for my tenure include addressing many of these same issues. Please let me know how I can support your critical efforts.

Sincerely,

Christopher E. Kubasik

Co-founder, Chair and CEO

ɫ��ֱ�� Technologies, Inc.

Melbourne, Florida