U.S. Military’s Uneven COTS Policy

By Ron Sherman | August 1, 2002
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Talk of commercial off-the-shelf (COTS) acquisition on a program level, and U.S. military officials often will gladly provide all the details you want. However, talk of COTS on a policy level, and military officials become quite guarded with their comments–in large part because the U.S. military obviously has no single policy to guide it through this way of developing and acquiring new technology.

That fact became painfully clear when Avionics Magazine talked with officials from the Office of Acquisition, Technology & Logistics (AT&L) at the U.S. Department of Defense (DoD), as well as with Air Force, Navy and Army avionics managers. They all conveyed their procedures and experiences in acquiring COTS equipment for various aircraft systems. Their comments, however, were sometimes startling in implying the different approaches to COTS. Perhaps equally revealing was the fact that none of the U.S. military officials interviewed would allow his comments to be attributable. No one wanted to be on the record. We could only source our information to agency "officials" or "managers."

The DoD

Officials from AT&L in the Office of the Secretary of Defense (OSD) admit that the private sector has made huge advances in technical development. They also say the military needs to capitalize on this new technology, as well as access mature commercial technology.

They admit, too, that they have been somewhat slow in adopting COTS technology. "Our intent is to have the ability to access the external [non-DoD] commercial system much more quickly than we have in the past," OSD officials say.

In discussing the history of COTS in military avionics, the OSD AT&L managers say the procedure started slowly, beginning around 1994. "We really did not get our arms around the embedded versus stand-alone acquisition process until 1998 or 1999," they explain. "This is because we have had big problems with recognizing and sustaining long-range software issues." (Generally, the U.S. military views embedded systems as a suite of electronics developed for the airframe while stand-alone systems are components that may be acquired to upgrade a suite.)

In other words, COTS is not a way of life within the services, according to the OSD AT&L managers. In fact, they add, it is a very unusual business arrangement. That view, however, is not necessarily held by the services, as is indicated later in this article.

COTS, the AT&L managers say, works well at the subassembly level; however, embedded COTS avionics systems present a "horse of a different color." That difference, the managers explain, is sustainability. "We need to ensure embedded systems can be sustained far out into the future," they maintain. "This is not easy when commercial companies must make business decisions on whether to continue producing, supplying and sustaining these systems."

According to OSD, the Navy has been excited about the new embedded technology in the F/A-18E/F Super Hornet. "But they, too, worry about the availability of future upgrades and sustaining software issues," say the OSD AT&L managers. In fact, they contend that all services have some problems with the issue of embedded vs. standalone avionics systems. They point to an Air Force study that shows the services favor the open architecture of modular avionics systems but also struggle with sustaining embedded systems.

An Outdated Guide

In 2000, OSD tried to capture all the lessons learned in COTS avionics acquisition to create a guide for service program managers. They admit that the guide is badly out of date. The complexity of COTS technology acquisition is just now coming to light, they say, adding: "We must remember, we cannot force our solutions on the OEM [original equipment manufacturer]."

The OSD officials emphasize the importance to COTS avionics acquisition of building long-term relationships with vendors. In fact, they contend, "If you are not at the table in the design process as a commercial vendor, then there is a major problem." They say the military can not simply issue a COTS vendor a mil-spec requirement; instead, the vendor must be given a reason to consider a major avionics military design requirement.

According to OSD, few program managers seem to be completely plugged into the COTS process. In fact, regular meetings have been held to help program managers keep up with available COTS technology, but they have been organized by the services, not OSD.

OSD managers say they are certain that COTS can and does modernize technology while helping to cut budgets. Still, OSD appears to be very much in a learning mode–as well as in a catch-up mode–when it comes to COTS avionics acquisition.

"We are going to have to find a way to come up with a policy to enable COTS equipment to be embedded in our aircraft systems. This means taking risks," said the OSD managers. Eventually, they say, DoD will come up with new rules and find a way to keep up with commercial avionics solutions.

The Air Force

U.S. Air Force officials would appear to have a more bullish view of COTS equipment than DoD, and they obviously feel they do keep up with COTS solutions. The service claims it utilizes COTS whenever possible to avoid having to fund the design/development costs of avionics systems.

Air Force officials hold the firm belief that the commercial world is far ahead of the military world technologically, and this is unlikely to change. They are blunt about the military’s need to embrace the commercial world more and more for electronic items that are not military-unique.

Unlike DoD, Air Force officials say COTS has always been a basic tenet of military acquisition policy. In fact, they claim that during the 1990s, use of COTS was re-emphasized, and since then the Air Force has "significantly increased" its procurement of COTS avionics. Examples include non-developmental item (NDI) computers, operating systems software, GPS equipment, traffic alert collision avoidance systems (TCAS) and terrain awareness warning systems (TAWS), as well as weather radar.

The officials say the Air Force has kept in constant touch with prime contractors, OEMs and subassembly hardware and software vendors. The service believes most, if not all, the vendors are keenly aware of the need to cut costs and respond to military needs in a way that is dramatically different from the traditional, mil-spec process.

"Due to COTS requirements, our contractors must produce architectural designs that are easy to change and test, are based on non-government interfaces, and are affordable," say the avionics managers at the Air Force’s Aeronautical Systems Division (ASD), Wright Patterson AFB, Ohio. They agree that this procedure forces bidders to evaluate COTS hardware and software items during proposal preparation, rather than beginning designs from a blank sheet of paper.

Is COTS "a way of life" at the Air Force? The answer from the ASD managers was considerably different from that of OSD. "COTS as a way of life is just good business," say Air Force officials. "It allows us to satisfy the military requirements better, faster and cheaper."

An example, they say, are COTS computers; they cost less than mil-spec computers and can be purchased out of supplier’s production process or inventory, shortening the procurement lead time. Also, the commercial product often will provide significantly superior performance than the mil-spec product, the officials contend.

Another aspect of COTS with regard to performance is the common modification of equipment to achieve a desired result. Each program office must compare the COTS qualification level against the military application and decide if the performance capabilities will meet the mission requirements. As an example, COTS computers are almost always modified to meet Mil-Std-1553 interface capabilities.

ASD managers emphasize that there is no formal "COTS program" and no formal partnership with industry other than interim arrangements, such as open forums, bidders’ conferences, formal source selection requirements, and participation on boards and committees.

In addition, they say, "We do not tell contractors they must use COTS. They are free to propose any solution they wish. Most contractors propose COTS solutions only if they meet all requirements while reducing cost and schedule."

The Air Force recognizes, of course, that the commercial marketplace can not provide, say, target acquisition systems or ordnance delivery systems to equip fighters and bombers. In this case, the military appropriately takes the technological lead. But this leaves a large market for COTS avionics, such as navigation, flight management and cockpit multifunctional display (MFD) systems, especially in air transport, tanker and other utility aircraft.

On one matter, the Air Force and OSD agree. The military must divest itself of limited-value activities, acquisition stumbling blocks, and "rigged," or preconceived, solutions to military avionics needs. The commercial industry has made it clear that they cannot afford to conduct business with the military using the traditional process. The military cannot afford to drive the electronic world; in fact, the technology is moving much too fast for the military to keep up.

The Army

The U.S. Army’s responses to the COTS avionics acquisition issues are conservative and quite guarded. The program office for the Army Aviation Mission Equipment (AME) explains that avionics management is a shared responsibility, in that the contractor furnishes the systems with oversight by the Army’s program manager.

Because of the variety of Army airframes–fixed-wing aircraft and helicopters that perform various dedicated missions–acquiring COTS equipment is not always possible. Nevertheless, the Army endeavors to acquire COTS systems whenever it is practical, in large part to cut acquisition costs. In some cases, the service has found its use of COTS equipment can save up to 50 percent in costs. The AME is conducting an economic analysis to support the purchase of commercial personal computers (PCs) for their Aviation Mission Planning System, a program that could potentially save more than $20 million.

A good example of COTS equipment utilization in Army aviation is the multifunction displays in the Kiowa Warrior and Longbow Apache helicopters. In addition, the Army’s Fixed Wing Product Management Office (FWPMO) is using COTS equipment to bring its aircraft up to Global Air Traffic Management (GATM) compliance. Impacting almost all of the fixed-wing aircraft upgrades, this equipage for GATM enhances the Army’s ability to meet mission requirements within civil airspace mandates, according to FWPMO.

The Army’s ongoing fixed-wing COTS program will upgrade the entire fleet with commercial equipment. Modifications include as many as 18 communication, navigation and surveillance (CNS) components being installed on eight types of aircraft.

The Army’s fixed-wing fleet consists mainly of commercial aircraft, including the Raytheon King Air B200 turboprop and Cessna CitationJet. Army officials say the service tries to maintain its link to the commercial world by procuring technical standard order approved (TSO’d) equipment and performing modifications in accordance with commercial supplemental type certificates (STCs).

The Navy

The officials at Naval Air Systems Command (NavAir) also are quick to state that "in order to conserve scarce funding and reduce cycle time required to introduce new systems," it acquires commercial avionics systems and components whenever possible. In some cases, they claim, COTS equipment is installed in Navy aircraft without a requirement for modification. Also, where whole systems do not meet Navy operational needs, they say they seek to modify COTS or leverage heavily off already developed commercial components.

But, adopting a bit of OSD’s cautiousness, the program managers at NavAir say there are strong considerations when using COTS equipment. They contend that "COTS integration is not necessarily faster, better or cheaper." One size does not fit all, they explain, and embedded systems’ requirements differ from those of internal, or stand-alone systems. Therefore, applications are unique to the COTS item.

NavAir officials say they’ve learned from the acquisition of COTS equipment and offer the following advice:

  • Avoid proprietary code or buy rights,

  • Maintain a technical contract with the COTS vendor to reduce risk,

  • Provide collaborative debugging,

  • Ensure immediate resource availability,

  • Give the contractor the option to choose COTS and the responsibility to make it work, and

  • Use an independent evaluator to examine the candidate COTS software.

With these precautions, NavAir officials maintain that COTS systems can offer interoperability, flexibility and sustainability. The latter quality is critical. "New funding strategies are now required to address sustainability and obsolescence issues, as technology changes in COTS outpace our ability to field new systems," say NavAir officials.

New approaches to avionics acquisition are changing to keep pace with the changes in technology. Program managers at NavAir stay current with the latest COTS technology by participating in industry standards development and sharing lessons learned by managers in the other services. The more they learned, the more they are encouraged about COTS’ future.

"With this new industry open architectural approach, we’ll be able to achieve even deeper and more flexible relationships with vendors through COTS than we are able to achieve today," say NavAir program managers.

A Vendor’s Perspective

Many think COTS [commercial off-the-shelf] means simply getting the cheapest technology available today. But that doesn’t work on deployed systems that require long component life," says Duncan Young, director of marketing for Dy4 Systems, a leading COTS provider.

Often expanding on the comments of U.S. military officials, Duncan explains in an Avionics Magazine interview how COTS has forced change to the systems development and acquisition processes. Much of that change involves more flexibility in attaining and funding avionics solutions.

"There remains in the military the tendency to divide a program into different phases: engineering and design, test, initial production, etc.," Duncan says. But the COTS process is "more fluid" and less compliant to the military’s traditional acquisition structure, he adds.

This fluidity, in turn, requires more communications. "Because COTS is open systems architecture, the COTS vendor must have more dialogue with the government and certainly with the prime contractor," he explains. "Instead of the military saying this is the platform and these are the specs and it’s the prime’s responsibility to meet those specs, there must be a certain amount of flexibility with the COTS suppliers–more of a give-and-take on the specifications. It’s a question of compromise to best meet the government requirements at a reasonable cost."

Although many COTS suppliers exist, not all appreciate the military’s concern for sustainability, i.e., assuring that a product will perform and be supported for an extended period. "The selection of the right vendor is so important to the military," says Duncan. "It should be the one who can offer the life cycle for a program that extends out to five to 20 years. You don’t want a disconnect along the way." (Duncan says COTS technology often changes within six to 18 months.)

In an environment void of a single, U.S. military COTS policy, Dy4 Systems recognizes that varying procedures exist among the services, in terms of commercial product acquisition. In part, the differences are due to the diverse environments in which the services must operate. Many times, this impacts the degree of component commonality.

"The Navy’s environment is quite different," says Duncan, referring to COTS equipment for ships. "Navy technicians become very familiar with their ship, so they may replace equipment that is unique to that ship. But the Air Force’s and Army’s aircraft can be deployed anywhere, and the maintenance crew may not be intimately familiar with a particular aircraft, so they want the components to be identical across the fleet."

Based in Kanata, Canada, Dy4 is a 23-year-old company that produces defense and aerospace products which are almost exclusively commercial off-the-shelf. Among the aircraft that it provides systems for are F/A-18, AV-8B, Tornado, U-2, B-2, F-117, F-15 and F-16.

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