Letter on Robotic and Autonomous Command NDAA Provision

Dear Chairman Wicker and Ranking Member Reed:

The Air & Space Forces Association (AFA) is profoundly grateful that S.4784, the National Defense Authorization Act for Fiscal Year 2027 (NDAA) contains several provisions which are fundamental to achieving the goal of recapitalizing and enhancing the readiness of the U.S. Air Force. In addition, AFA appreciates your leadership ensuring the timely development of Unmanned Aircraft Systems (UAS).  Despite this, we have significant concerns regarding the NDAA’s Section 917 – Establishment of United States Robotic and Autonomous Command (RASCOM). Specifically, AFA believes, despite the best of intentions, this section’s enactment will greatly complicate the development, acquisition and operational use of UASs and the unmanned systems of all services. 

It is beyond doubt that UAS and unmanned systems will play an ever-increasing and essential role in securing decisive advantages for our servicemembers. But rather than facilitating the timely development, acquisition and operational utilization of these systems, we believe Section 917, which creates a new combatant command, will unintentionally slow their development and hinder their effective employment.

Combatant Commands were created to “centralize command and control” of multiple types of forces under one commander for a specific geographic location or domain of warfare. In some cases, using a combatant command to acquire highly specialized equipment can be beneficial. But in the case of unmanned systems, will not more value be created by coordinating UASs’ development with those developing other types of aircraft?  Does not such a construct better facilitate the creation of complementary capabilities; where different types of aircraft are designed from inception to operate together?   

Similar questions can be raised regarding the development of Unmanned Underwater Systems (UUS).  Should UUS not be developed alongside those manned systems which will utilize the unmanned systems as vital tools?  For our land forces, should Unmanned Ground Vehicles not be developed by those developing our next generation of armored forces?  Does it not make more sense to encourage the development of comprehensive manned-unmanned teams?       

As Lieutenant General David Deptula, USAF (Ret.), the Dean of the Mitchell Institute for Aerospace Studies recently wrote: “[w]arfighting should be organized around objectives, effects and campaigns – not platforms, weapons, or categories of hardware. Autonomous and AI-empowered vehicles do not constitute an independent theory of victory…. [t]heir military value is only realized when they are integrated into a broader joint concept of operations.” 

This unnecessary division is further highlighted since the provision states the “Commander of RASCOM shall be responsible for, and have the authority to conduct, all functions relating to robotic and autonomous systems, including… operational employment through other combatant commands.” As General Deptula noted:

If autonomous and AI-empowered systems are placed under a separate technology-specific combatant command, they risk being separated from the commanders responsible for the outcome of the fight.  That creates friction where the military needs speed and it would introduce a new seam in command and control precisely when modern warfare demands tighter integration across domains. …Creating a separate combatant command for autonomous and AI systems would complicate tasking, authorities, targeting, prioritization, communications and sustainment. It would increase seams, add command complexity and reduce understanding of how the respective tools operate together. In combat, those seams are not administrative nuisances; they are vulnerabilities. Adversaries would exploit them.

Separately, the AFA is grateful the Senate version of the NDAA contains several provisions which are particularly beneficial to ensuring our continued dominance of the skies.  Included are provisions which will require our nation to maintain a total aircraft inventory of not less than 1,800 fighter aircraft and 180 MQ-9s; authorizes the multi-year procurement of the F-35 and F-15EX; and ensures the continued development of the E-7 Wedgetail. Sections elsewhere in the bill will enhance readiness and retention by providing flexibility in the career development of pilots and their duty locations. In sum, the AFA deeply appreciates your including these provisions in the bill. 

Therefore, though the AFA is grateful for the numerous provisions in the NDAA which enhance the recapitalization and readiness of the Air Force, we believe inclusion of Section 917 in the final legislation will greatly complicate the development, acquisition and operational use of UASs and the unmanned systems of other services. 

Thank you for your consideration. 

Yours truly,