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OPERATING STATUS

FULLY OPERATIONAL

Question
Is a FRP decision briefing mandatory for an ACAT I D program? Or is approval ever provided via correspondence/white paper?
Answer
DoDI Number 5000.02 “authorizes Milestone Decision Authorities (MDAs) to tailor the regulatory requirements and acquisition procedures in this instruction to more efficiently achieve program objectives, consistent with statutory requirements.”

Conducting “paper DABs” is certainly not unheard of. The Overarching Integrated Product Team (OIPT) often will recommend a “paper DAB” to the MDA, usually when there are no contentious issues with the program. The MDA would be the one to make this decision. That decision most likely will be dependent on the risks to the program.

That said, there are numerous information requirements (see DoDI 5000.02, Table 2 Milestone and Phase Information Requirements) for a Full-Rate Production (FRP) Decision, including some that are statutory. Approval to conduct a “paper DAB” does not, in and of itself, waive these requirements. The MDA, though, can designate which REGULATORY information requirements to waive (again based on the risks to the program). Waiving STATUTORY information requirements, however, would likely require coordination with Congress.

Your best path forward probably is to staff a decision memorandum to the MDA, which seeks approval of a “paper DAB” and the waiver of specific REGULATORY information requirements. Your supporting rationale for waiving these requirements, though, will be crucial for the MDA’s approval.

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