Can the ILA be waived before FRP and if so, by whom? Would it be by the MDA or the implementing authority who would conduct the ILA? Is there a specific process to request a waiver for an ILA?
Neither DoD nor the Navy has a policy on waiving an ILA before FRP. The US Navy requires the MDA receive reports and certification, based on the ILA, prior to FRP. The current policies are detailed below for your reference. If you have questions related to the DoN policy, recommend reaching out directly to ASN(RDA) DASN ELM.
Logistics Assessments should be performed at Milestones B and C, prior to Full Rate Production (FRP) decisions, at Post-IOC reviews, or at least every five years. These assessments will ensure that there is adequate supportability planning, management, resource identification, and risk mitigation for each program at different phases of its life cycle. Findings from the ILA are intended to help the program in a positive manner, identifying issues that may need more senior-level attention to correct.
Execution of the ILA is at the discretion of the Components, but preferably by a team independent of the program; each Component may develop their own implementing processes and guidance to meet their unique requirements. Note that the individual military Services have their own methodologies for implementation of logsitics assessments, including the Department of the Navy, which mandates them in policy as "Independent Logistics Assessments (ILA)."
Department of the Navy (DoN) ILA policy was updated in March 2018 with the issuance of SECNAVINST4105.1D Independent Logistics Assessment and Certification Requirements, along with the updated June 2017 NAVSO P-3692 Independent Logistics Assessment Handbook. On page 2 of SECNAVINST4105.1D, para 5 "Policy" states: "ILAs shall be conducted: a. Prior to and serve as entrance criteria to milestones B, C, and the Full Rate Production (FRP) decision or Full Deployment Decision (FDD). Where the timeframe between milestones or the identified decisions exceeds five years, an ILA shall be conducted at a minimum of every five years and if possible, coincide with a major systems engineering technical review..."
SECNAVINST4105.1D Enclosure (1) "Responsibilities" paragraph 5 states, "The Program Executive Office (PEO), Systems Command (SYSCOM) commander or program manager, as appropriate shall: a. Ensure IPS planning, resources, risk, and execution are independently assessed for compliance with program specifications, objectives, and milestones. This independent assessment shall be accomplished on a schedule that supports acquisition milestones, and periodically thereafter throughout sustainment with the user per paragraph 5(a)1 and 5(a)2 of this policy; b. Report and certify to the MDA prior to milestones B and C, FRP or FDD, the adequacy and program health of IPS planning, management, resources, affordability, risk mitigation, and execution for cognizant ACAT programs. Certification shall be based on the results of the ILA using the criteria contained in enclosure (1)...."