COTS in space: Infusing MIL EEE components with COTS practices, part I
By Dan Friedlander. The 1994 Perry Memo triggered a policy of transition from MIL, including military standard (MIL-STD) and military specification (MIL-Spec) which typically were purpose-built, custom, and proprietary, components to commercial-off-the-shelf (COTS) products. Unfortunately, space applications were exempted. It is understood that the U.S. Department of Defense (DoD) is a space user and not the space policy maker. Although the same drivers apply, history shows that even after 23 years, the space authorities need more time to realize that COTS is not just a "last resort" selection option.
By Dan Friedlander
Retired following 44 years in component engineering
The 1994 Perry Memo triggered a policy of transition from MIL, including military standard (MIL-STD) and military specification (MIL-Spec) which typically were purpose-built, custom, and proprietary, components to commercial-off-the-shelf (COTS) products. Unfortunately, space applications were exempted. It is understood that the U.S. Department of Defense (DoD) is a space user and not the space policy maker. Although the same drivers apply, history shows that even after 23 years, the space authorities need more time to realize that COTS is not just a "last resort" selection option.
It seems that the MIL-SPEC to MIL-PRF (military performance specification) conversion is considered a satisfactory solution, in spite of these components’ insecure availability. Technically, if MIL components availability is foreseen as secure and the space users can confine to the relatively (referenced to COTS) less advanced technologies, less sophistication, less integration, no SWaP (size, weight, and power) issues, they can live with the present policy of MIL components supremacy.
Budget-wise, the DoD reformers’ target to save money in military applications by using COTS as is and MIL as last resort. The present space policy piggybacks on the now liberalized traditional costly methodology of heavy 100% testing/screening even for COTS. Keeping the status of COTS components as "last resort" and applying to them the above costly methodology is counterproductive. Space users are pushed in the wrong direction.
The MIL-SPEC to MIL-PRF is a change in the right direction, but is not a full lasting solution in view of the ongoing global trends. In fact, it is a new infusion of vitality to the outdated MIL system, using basic elements of COTS.
It has to be mentioned that electrical, electronic, and electromechanical (EEE) components-related issues are only a subset of the huge defense acquisition reform. Defense acquisition reform has been debated for the past five decades in an environment of strong resistance to change.
This article is about the MIL side of the MIL/COTS multi-decade debate.
The ongoing MIL/COTS debate did not start with the 1994 Perry Memo. In 1986, the Packard Commission released its final report that, interalia (among other things), recommended the use of commercial off-the-shelf components. Perry himself was a member of the Packard Commission.
Defense acquisition reform initiatives have been Department of Defense perennials over the past 50 years. Most attempts to implement improvements in the management of the defense acquisition process during the past 50 years have fallen short of their objectives. Historical experience indicates that implementing reforms that positively change acquisition outcomes is extremely difficult.
Under Perry's leadership, the acquisition portions of the Packard Commission report became materialized. It was not easy, and compromises have to be done.
Perry shocked the system by severely restricting the use of MIL-SPECs. Perry noted in his 1994 Memo: “The problem of unique military systems did not begin with the standards. The problem was rooted in the requirements determination phase of the cycle.”
It seems that DoD personnel quickly "recovered" from the shock of the Perry Memo. Perry noted in his famous 1994 Memo: "The use of military specifications and standards is authorized as a last resort, with an appropriate waiver."
Assistant Deputy Under Secretary of Defense, Logistics Plans and Programs Louis A. Kratz released a less famous memo on 29 March 2005. The subject of Policy Memo 05-3 is "Elimination of Waivers to Cite Military Specifications and Standards in Solicitations and Contracts."
The waivers are gone. It is my understanding that "cite" translates to "use". The above memo explains:
"This waiver elimination should not be interpreted as returning to the "old way of doing business," but as recognition of the cultural change that took place in DoD regarding the proper application of specifications and standards. We need to ensure that those in the acquisition and logistics communities have the flexibility to assess program requirements, make good decisions, and where appropriate, require conformance to military specifications and standards."
I leave to the readers the task of understanding this anticlimactic move.
Anyway, Civil-Military Integration (CMI) is an ongoing process. It may be that space policy makers wait for the outcome. Meanwhile, the outcome is not critical to the EEE components industry, their movements being driven by business decisions.
The 1994 Perry Memo
The Memo's subject is “Specifications & Standards - A New Way of Doing Business." Before raising some interpretation issues, it has to be mentioned that this memo deals with an issue that is a part of the wider Defense Acquisition Reform addressed to entire military systems. The subject issue of Specifications & Standards encompasses various topics, EEE components being only a subset of them.
Reading the Memo, sometimes the wording is ambiguous. The phrase "performance and commercial specifications and standards" is repeatedly used. It is clear what is a performance specification. It is less clear why the Memo systematically avoids explicit mention of the intended type of the performance specification, namely "military" (if that is the case). By the way, a EEE component manufacturer data sheet is a commercial performance specification! Anyway, the field implementation of the MIL-SPEC to MIL-PRF conversion "clarified" the issue.
Both MIL-SPEC and MIL-PRF are defense, government-unique specifications, containing requirements. The Memo states "Moving to greater use of performance and commercial specifications and standards is one of the most important actions that DoD must take to ensure we are able to meet our military, economic, and policy objectives in the future."
In the same paragraph, the Memo states: "Moreover, the Vice President's National Performance Review recommends that agencies avoid government-unique requirements and rely more on the commercial marketplace." If the addressee is military performance specification, then it means avoid MIL-PRF and use more COTS.
Further the Memo states: " Performance specifications shall be used when purchasing new systems, major modifications, upgrades to current systems, and non-developmental and commercial items, for programs in any acquisition category. If it is not practicable to use a performance specification, a non-government standard shall be used." If the addressee is military performance specification (MIL-PRF), then it means use MIL-PRF and use COTS as last resort.
- It is clear MIL-SPEC is a controlled last-resort solution.
- It is not clear what is the status of the MIL-PRF vs. COTS, which route is the preferred one and which one is the last resort.
Nevertheless, in practice, my interpretation was: Use COTS as-is as first-priority selection and MIL as last resort. It is my feeling that Perry meant the same.
This ends part I of “COTS in space: Infusing MIL EEE components with COTS practices.” Stay tuned for part II.
The author, Dan Friedlander, graduated Engineering School/Tel Aviv University with a degree in physics (1965-1969). He has 44 years of experience in Component Engineering at MBT/Israeli Aerospace Industries (1969 to 2013), as Head of Components Engineering. As such, he was responsible for all aspects of EEE components – including policymaking, standardization at corporate level, approval, etc. – for military and space applications. Now retired, Friedlander is an industry consultancy (2013 to present). For further details on his experience, visit https://www.linkedin.com/in/dan-friedlander-63620092?trk=nav_responsive_tab_profile