Order Code RS20522
Updated February 4, 2003
CRS Report for Congress
Received through the CRS Web
Army Aviation: The RAH-66 Comanche
Helicopter Issue
Christopher Bolkcom
Specialist in National Defense
Foreign Affairs, Defense, and Trade Division
Summary
Although it has been a high Army priority, a number of factors have complicated
the RAH-66 Comanche program. Since its inception, the program has been restructured
several times–postponing the initial operational capability (IOC) and increasing overall
program costs. In late 2002, DoD restructured the RAH-66 program again, cutting the
number of aircraft to be procured in half. This report will be updated
Background1
The RAH-66 Comanche is a next generation armed reconnaissance helicopter. It is
the first helicopter designed and developed specifically for this mission. The Comanche
is being designed to stealthily penetrate enemy airspace and conduct reconnaissance
throughout the extended battlespace. It is to incorporate advanced computers and
communications to play a leading role in the digital battlespace, with enough weaponry
to engage a wide range of targets. Some call the Comanche the world’s most sophisticated
combat helicopter, with more lines of software code than even the F-22 Raptor.2
The Comanche’s primary roles would be to seek out enemy forces and designate
targets for the AH-64 Apache attack helicopter at night, in adverse weather, and in
battlefields obscured by smoke and dust. The RAH-66 would replace the Army’s current
fleet of AH-1 Cobra light attack helicopters and OH-58 Kiowa Warrior helicopters
performing the attack mission as well as reconnaissance.
Originally, the Army envisioned developing and procuring 5,023 Comanches to
replace the Army’s 1960s-era observation, utility transport, and attack helicopters (OH-6,
OH-58, UH-1, AH-1). Budget constraints and force structure modifications caused
1 This report supercedes CRS Report 96-525 F, Army Aviation: RAH-66 Comanche, by Steven
R. Bowman. Washington, 1996 (Archived).
2 Vernon Loeb. “Fate of Army Chopper On The Block.” Washington Post. August 31, 2002. p.2.
Congressional Research Service ˜ The Library of Congress

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significant modifications to the Comanche program. First, the utility transport version of
the platform was canceled and the procurement objective reduced to 1,292 armed
reconnaissance helicopters. Second, the FY1993 budget deferred a production decision
until 2006 and trimmed the number of prototypes from six to three. Third, in December
1994 DoD trimmed $2 billion from the RAH-66 program and dropped another prototype,
going from three to two. Fourth, in 1995, the Army restructured the program to add 6
“experimental operational capability” helicopters within the reduced budget limits, in part
by producing them without the armaments suite.
In April 2000 the Comanche program successfully completed a series of tests and
was cleared to begin its two-year, $3.1 billion Engineering and Manufacturing
Development phase3. Boeing-Sikorsy has built and flown two Comanche prototypes. The
first pre-production model, and the third Comanche is being built and is expected to be
flown first in March 2005.4 The last plan was for five pre-production aircraft to be built
in this phase and eight production aircraft were due for delivery by 2004 for initial
operational testing and evaluation. A total of 14 initial operational capability RAH-66s
was planned for delivery at the end of 2006.5 Boeing-Sikorsky was to produce a total of
1,213 Comanches through 2024.
Recent Developments
On October 21, 2002 it was announced that DoD acquisition chief Pete Aldridge had
signed an acquisition decision memorandum (ADM) giving final approval for the latest
restructuring of the RAH-66 program. Under this new plan, the total purchase of
Comanches would be reduced from 1,213 to 650 aircraft. Seventy three aircraft will be
produced during Low Rate Initial Production (LRIP) in different blocks. The Comanche’s
Initial Operating Capability (IOC) will be achieved in September 2009, three years later
than originally planned, and nine months after the most recent plan. The remaining 577
aircraft will be produced under a full rate production schedule of 60 aircraft per year,
starting in 2011. The Army had wanted to boost the production rate to 96 aircraft per year
as part of an effort to cut costs.6
This restructuring reduces the Comanche’s production phase from $39.3 billion to
an estimated $26.9 billion. DoD has agreed to add $3.7 billion to the helicopter’s $3.2
billion full-scale development program. Army officials estimate that the cost of each
Comanche, adjusted for inflation, will increase by 33 percent – to $32.3 million7

3 “Comanche Cleared to Begin Engineering and Manufacturing Development.” Defense Daily.
April 6, 2000.
4 Kent Faulk. “Comanche Helicopter On Last Chance To Fly.” Birmingham News. July 1, 2002.
5 Telephone conversation with Jack Satterfield, Boeing spokesman; Capaccio, Tony, U.S. Army
To Make Decision on Helicopter Purchases in April, Bloomberg News Service, March 2, 2000.
6 Neil Baumgardner. “Aldridge Inks Comanche Acquisition Decision Memorandum, Numbers
Cut To 650.” Defense Daily. October 21, 2002.
7 Tony Capaccio. “Boeing, UTX See Positive Impact in Comanche Cut.” Bloomberg.com.
October 23, 2002.

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Much of the program’s problems have been due to the amount of systems that have
been developed concurrently. For example, the radar, armor, and navigation and
communication systems were all being developed at the same time.8 The latest
restructuring will reduce this concurrence by delaying the fielding of certain capabilities
– the radar system, a high level of control of UAVs, full air-to-air engagement with the
turreted gun system, Link 16 datalink, and satellite communications – to later blocks. 9
The program was also restructured to field a companion UAV for the Comanche.,
which will be developed with funds intended to upgrade Comanche itself. More
sophisticated sensors and a better power drive system will be sacrificed in lieu of the
UAV development. Comanche officials estimate that about $644 million between fiscal
years 2004 and 2009 will be spent on the Comanche’s UAV instead of the platform
itself.10 The Army has experimented with teaming UAVs and both Apache and
Comanche for several years, including work with the RQ-5A Hunter.11 It is currently
unclear whether the Comanche’s UAV will be the Hunter, some other UAV currently in
production, or one under development such as the Unmanned Combat Armed Rotorcraft
(UCAR).
If there are no further changes, Comanche prime contractors Boeing and Sikorsky
would build helicopters through 2019.”12 However, the final word on Comanche numbers
has not been spoken. The overall procurement objective of 650 aircraft will be examined
again in April 2003 when the Army’s Future Combat Systems (FCS) program is
reviewed.13 Army officials claim that 650 aircraft are too few, and that they require 819
Comanches to effectively equip their Objective Force which is hoped to be ready by 2008.
Plans call for fielding detachments of 12 Comanche aircraft to the Objective Force
brigade-strength ‘units of action,’ accompanied by eight UAVs.”14
The Debate over Mission and Capabilities
The RAH-66 Comanche is designed to replace the aging AH-1 and OH-58D
helicopters and to augment the AH-64 Apache attack helicopter. Critics of the Comanche
program argue that there is no need for a highly sophisticated, very low observable armed
reconnaissance helicopter in today’s threat environment. They contend that Comanche’s
capabilities and mission requirements were developed in response to a Cold War threat
environment that no longer exists. Furthermore, the Apache and Kiowa helicopters
8 Neil Baumgardner. “Army Ready to Move Forward with Comanche, Program Manager Says.”
Defense Daily. February 28, 2002.
9 Baumgardner. OpCit. “Aldridge Inks Comanche Acquisition Decision Memorandum.”
10 Erin Winograd. “Army Leaders Adamant That 650 Comanches Won’t Meet Requirements.”
Inside the Army. October 28, 2002. p.10.
11 Kim Burger. “AUSA - Army Eyes Apache to Fill Comanche Gap.” Jane’s Defense Weekly.
October 30, 2002.
12 Robert Wall. “New Comanche Plan Gets Green Light.” Aviation Week & Space Technology.
October 28, 2002.
13 Baumgardner. OpCit “Aldridge Inks Comanche Acquisition Decision Memorandum”.
14 Burger. OpCit “AUSA - Army Eyes Apache to Fill Comanche Gap.”

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performed very well as a hunter-killer team during Operation Desert Storm (1991). Critics
also argue that the Comanche’s role and capabilities are too similar to the Apache’s to
justify the costs of the helicopter’s development and production. They would cancel the
RAH-66, and use the savings to upgrade the OH-58 aircraft and the AH-64D Apache’s
Longbow15 target acquisition capabilities.
Proponents of the RAH-66 agree that the Cold War threat has disappeared, but
counter that today’s low-intensity regional conflicts (such as Kosovo and Somalia) place
even greater burdens on Army aviation. U.S. Forces must be more deployable, less reliant
on forward bases, and more versatile than they were during the Cold War.
Supporters argue that Comanche satisfies all three criteria. Furthermore, proponents
argue that Comanche is an unparalleled force multiplier. It makes the whole force more
effective and will reduce the Army’s maintenance burden. This perspective, proponents
argue, is supported by initial results from an Army “Analysis of Alternatives.” This study
compared attack and air cavalry squadrons equipped with AH-64D Longbows and OH-
58D Kiowa Warriors to units composed of Apaches and Comanches. The force equipped
with Comanches reportedly demonstrated better situational awareness, survivability and
lethality than the other force. The study suggested that the most significant gains were
achieved when the Comanche replaced the OH-58D. The Comanche provided better
sensing, lethality, range, agility, survivability, and versatility than the Kiowa units.
Comanche also improved the effectiveness of the Longbow when the two aircraft were
mixed in attack units. The RAH-66's stealth improved Apache Longbow’s survivability
when cooperative tactics, techniques and procedures were used.16
Claims of reduced maintenance burdens for the Comanche, however, are more
controversial than are claims of its effectiveness17. Projected ratios of maintenance man-
hours to flight hours have varied over time. The Army hopes to achieve a ratio of 2.6
hours of maintenance to every one hour of flight; however, both the General Accounting
Office and Congressional Budget Office assert that projected reductions in maintenance
are always optimistic.18 Additionally, some studies conclude that the Comanche is more
expensive to fly than the Kiowa Warrior ($2,042/hour vs $1,598/hour), but less expensive
than the AH-64D, which can cost as much as $3,622/hour to fly.19
The Comanche’s role vis-a-vis the Apache is a continued point of debate. The most
recent reduction in the Comanche program has increased the prominence of the AH-64
15 The AH-64D Longbow is an upgraded version of the AH-64A which includes a millimeter-
wave Fire Control Radar target acquisition system and fire-and-forget Hellfire missiles.
16 Erin Winograd. “Initial Results of Alternatives Analysis Show RAH-66 Contributions.” Inside
the Army. January 24, 2000.
17 Claims of improved maintenance requirements are based on projections of advanced processes
and technologies which won’t be proven until the aircraft is fielded. In general, more
technologically sophisticated weapon systems are more difficult to maintain than less
sophisticated weapon systems.
18 CRS Report 96-525, Army Aviation: RAH-66 Comanche, by Steven R. Bowman. Washington,
1996: 3-4.
19 Winograd OpCit. “Initial Results of Alternatives Analysis Show RAH-66 Contributions.”

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Apache. To compensate for fewer Comanches, the Army is considering improvements to
Apache, such as a life-extension program or upgrades. Another option may be to procure
more Longbow models.20 Some suggest that the DAB decision reaffirms the Apache’s
place as the Army’s attack aircraft, and question whether Comanche should pursue
features such as the External Fuel, Armaments and Munitions System, or an air-to-air
missile capability.21
Another issue is whether the Army will upgrade Comanche for ‘heavy’ attack
requirements. In November 2001, Army officials said they were planning on a heavy
variant of the RAH-66 as a replacement for the AH-64D. As part of Army transformation
plan, Army officials said that the Comanche could perform the attack as well as the armed
reconnaissance mission in the future.22 It is unclear whether the RAH-66 could maintain
its stealthy profile while carrying external weapons, however, and some questions whether
Comanche – which currently suffers from weight problems – has the power and fuel
capacity to take on even more weight.23 The Marine Corps is expected to seek a
replacement for its AH-1Z Super Cobra helicopters around 2020 and it has been suggested
that a joint program with the Army is worth investigating.24
Congressional Action
Congress strongly supported the Comanche program by consistently meeting or
exceeding DoD’s budget requests for funding. In its report on DoD’s FY1996 budget
request, the House Armed Services Committee reproached both the Army and the DoD
for tepid commitment to the program, urging that it be given a higher funding priority and
that full-scale production by 2004 be guaranteed.25
Summary of Recent Comanche R&D Funding in $ Millions
FY04
FY03
FY02
FY01
FY00
FY99
FY98
DoD Request
1,079.3
914.9
787.8
614.0
427.1
367.8
282.0
Appropriations
-
914.9
787.8
614.0
467.1
367.8
282.0
Conference
Recently, some in Congress have expressed concern over the Comanche’s schedule
and budget. House authorizors prohibited the Army from obligating any FY2003 funds
for engineering, manufacturing and development (EMD) until the Secretary of the Army
submits an “accurate estimate of the funds to complete (EMD) and the new restructured
20 Burger. OpCit. “AUSA - Army Eyes Apache to Fill Comanche Gap.”
21 Winograd. OpCit. “Army Leaders Adamant That 650 Comanches Won’t Meet Requirements.”
22 Neil Baumgardner. Heavy Comanche to Replace Apache, Army Officials Say. Defense Daily.
November 13, 2001.
23 Tony Capaccio. Boeing, United Tech Comanche Copter’s Cost, Weight Hit by GAO.
Bloomberg.com. May 18, 2001.
24 Kim Burger. “US Army Cuts Comanche Buy.” Jane’s Defense Weekly. October 16, 2002. p.3.
25 U.S. Congress. House of Representatives. Committee on National Security, National Defense
Authorization Act for Fiscal Year 1996, 104th Cong., 1st Sess., H.Rept. 104-131, June 1, 1995.
P.91-92.

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timeline for bringing the aircraft to initial operational capability.”26 This provision also
imposed a cost cap on EMD and requires an annual report by DoD’s Inspector General
to assess the progress of EMD and its prospect of completion under the cost cap.
Potential Issues for Congress
In light of the facts and arguments presented above, Congress may wish to pursue
the following lines of inquiry:
•
Comanche is the Army’s only major aviation development program. The Comanche
Operational Requirements Document describes the RAH-66's contribution to future
Army warfighting missions. It states that “Aviation capabilities add increased
deployability, versatility, lethality, flexibility, mobility, extended coverage and
sustainment to Maneuver, Fire Support, Air Defense...”and other mission areas.
Also, “Current systems are tactically and technically incapable of performing armed
reconnaissance, attack and air combat...”in the modern threat environment. If the
Comanche buy is reduced, what effect will this have on long-term capabilities? How
much does Comanche contribute to combat power vis-a-vis the light armored
vehicles that the also Army wants?
•
$6 billion has been spent on the Comanche through the FY02 budget.27 Will a
purchase of 650 helicopters be a sufficient return on this R&D investment?
•
Some say that in recent conflicts, fixed wing aircraft have played a more prominent
role, than Army attack helicopters. Might improved versions of the AC-130 and A-
10, or the STOVL variant of the Joint Strike Fighter, be more effective providers of
Close Air Support to Army ground forces than the RAH-66?
•
The need for Comanche has been challenged on the basis that its capabilities do not
differentiate it sufficiently from Apache to merit its development. However, turning
this argument around, some would assert that the Comanche is well-suited to be the
Apache’s replacement as the Army’s premier attack helicopter and the Army’s best
platform for future growth and development in this area. Subsequently, one could
anticipate a helicopter force structure composed solely of heavy lift (CH-47),
battlefield utility (UH-60), and scout/attack (RAH-66) aircraft. What are the merits
of this force structure?
•
Consideration of export issues is part and parcel of any military program. How much
might Comanche exports contribute to sustaining the aviation industrial base and
balancing U.S. trade? As a new platform, and one less overtly designed for attack
than the Apache, might the Comanche be offered for export to a larger number of
countries than the AH-64? Conversely, due to its low observable features might
Comanche exports need to be limited to our closest allies?
26 Bob Stump National Defense Authorization Act for Fiscal Year 2003. Report of the Committee
on Armed Services. House of Representatives. 107-436 (H.R. 4546) Section, 211. May 3, 2002.
27 Selected Acquisition Report (SAR) Summary Tables. (As of June 30, 2002)Department of
Defense, OUSD(A&T), Systems Acquisition. [http://www.acq.osd.mil/ara/am/sar/index.html].

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