For clarification, programs can enter phases based on milestone decisions. Milestone C is the decision point for entry into the Production and Deployment (P&D) Phase. The crux of the question is whether or not a program can start P&D activities while still conducting engineering and manufacturing development (EMD) efforts. There are no specific restrictions against entering P&D while still in the EMD. The decision to transition to the next phase in the acquisition development process is based on completion of the established criteria for the current phase as set by the Milestone Decision Authority (MDA).
For your specific question concerning entering P&D while in the EMD phase. The Defense Acquisition Guidebook (https://www.dau.edu/tools/dag) notes that the EMD phase ends when the design is stable; the system meets validated capability requirements demonstrated by developmental, live fire (as appropriate), and early operational testing; manufacturing processes have been effectively demonstrated and are under control; software sustainment processes are in place and functioning; industrial production capabilities are reasonably available; program security remains uncompromised; and the program has met or exceeds all directed EMD phase exit criteria and Milestone C entrance criteria per the MDA’s direction. An ICE and an ITRA will be conducted for MDAPs before beginning LRIP.
During the EMD phase, the program manages the remaining risk, builds and tests production representative prototypes or first articles to verify compliance with requirements, and prepares for production and fielding. It includes the establishment of the product baseline for all configuration items. The program should conduct a Critical Design Review (CDR), a System Verification Review (SVR), a Functional Configuration Audit (FCA), and a Production Readiness Review (PRR) as part of its ongoing systems engineering and risk management efforts to assess and manage risk. These SETRs are technical milestones to assess the product and processes to ensure the system can perform as desired and proceed into the next phase within cost and schedule constraints at an acceptable level of risk. The PM should focus the risk management activities on the transition from development to production. The program should consider conducting a manufacturing readiness assessment before Low-Rate Initial Production (LRIP) and again before Full-Rate Production (FRP) to identify risks related to critical manufacturing processes and product characteristics. Examples of specific risk areas include requirements/design stability, integration and inter-dependency risks, and manufacturing/supply chain quality.
Suggested Activities in the EMD Phase to Reduce Risk
• Continue knowledge point reviews, CSB meetings, and assessment of framing assumptions as in the TMRR phase. When not making a change to KPPs could jeopardize a program’s utility or affordability, coordinate with the Joint Requirements Oversight Council.
• Update requirements trace and risk assessment for the draft Capability Production Document (CPD).
• Conduct early risk-focused developmental testing with adequate time for necessary regression tests.
• Work with the operational test and evaluation community for early participation, requirements trace, and assessment.
• Require contractor testing with predefined success criteria to facilitate resolving integration activities and failure modes before the start of government testing.
• Establish and manage size, weight, power, and cooling (SWAP-C) performance and R&M allocations for all subsystems.
• Align logistics analysis, training, and support systems with system development.
• Plan technology refresh cycles to be implemented in the P&D and O&S phases to address technology obsolescence risks.
Once again, the intent of EMD is to stabilize the design and manufacturing process ahead of going into production. If the program office is comfortable with the design and has a compelling argument to start P&D activities, the MDA has the ability to approve the program to enter into P&D through MS C with liens in the Acquisition Decision Memorandum (ADM). Reference our AAFDID (https://www.dau.edu/aafdid/Pages/Milestone-and-Phase-Information-Requirements.aspx) to see what MS-C statutory and regulatory requirements the MDA will need to consider.