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  2. Low Density Commercial-off-the Shelf (COTS) Product Support Challenges

Low Density Commercial-off-the Shelf (COTS) Product Support Challenges

DAU GLOSSARY DEFINITION

A commercial item (CI) sold in substantial quantities in the commercial marketplace and offered to the government under a contract or subcontract at any tier, without modification, in the same form in which it was sold in the marketplace. This definition does not include bulk cargo such as agricultural products or petroleum.

General Information

A commercial item (CI) sold in substantial quantities in the commercial marketplace and offered to the government under a contract or subcontract at any tier, without modification, in the same form in which it was sold in the marketplace. This definition does not include bulk cargo such as agricultural products or petroleum.

The use of Commercial-off-the-Shelf (COTS) items, including Non-Developmental Items (NDI), can provide significant opportunities for each service that can save time and money getting a capability to the Warfighter.  The challenge in this article focuses on when the government buys low density products delivered to a deployable unit.

The Program Manager (PM), Contracting Officer, and Product Support Manager (PSM) must consider and mitigate product support if the program is to realize the expected benefits.  The primary benefits of using COTS components in system design are to:

  • Reduce development time.
  • Allow faster insertion of new technology.
  • Lower life-cycle costs by taking advantage of the more readily available and up-to-date commercial industrial base.

Life Cycle Concerns on Low Density Products

Regardless of the extent to which a system is made up of commercial items, the PM, Systems Engineer (SE), Product Support Manager (PSM) must develop, integrate, test, evaluate, deliver, sustain, and manage the overall system.  This takes time and money and in many cases the service may not have the budget to support the procurement and product support development requirements.  In many cases, there are money risks and a tradeoff to deliver one more end-item vs. funding product support development cost.  Among considerations with using COTS products are:

  • Low procurements year after year to meet equipment requirements and the COTS end-item changes from the model purchased the prior year or changes manufactures with an entirely new end-item.
    • Subtle differences in product use can significantly affect system effectiveness, suitability, and survivability for achieving mission needs, Human System Integration (HSI), Environment, Safety and Occupational Health (ESOH); cybersecurity, reliability, and durability. More detailed analyses are required to understand trade-offs for implementing NDI/COTS solution to determine design considerations’ impacts and communicate any associated risks to the PM.
    • Example: The technical data required for provisioning parts, developing manuals, operator and maintainer training, transportation, test equipment, and user interface design may not completely support user tasks.   When form, fit, function changes the product support requirements must be addressed, funded, and developed. 
  • Vendors may embed proprietary functions into COTS products, limiting supply sources, and potentially increasing risk of future Diminishing Manufacturing Sources and Material Shortages (DMSMS) challenges.
  • Vendors do not have to provide design information and often restrict purchasers from reverse engineering their intellectual property.
  • Licensing agreements vary and can be very restrictive while limiting the vendor’s liability for merchantability for intended purposes. Meaning the Warfighter mission is outside the commercial application. 
  • Supply chain risk management of COTS items is limited by the vendor, who is under no obligation to the purchaser to provide such information.
  • Incorporating COTS products places constraints on the rest of the design and reduces trade space; functionality, interfaces and reliability and maintainability characteristics are embedded in the choice of a COTS system element.
  • Difficulty in finding suitable replacements and/or alternate items if the COTS vendor stops manufacturing the product or changes the configuration drastically, requiring the need to maintain different configurations of a single product.
  • The program office must develop funding to feed the repair part supply system and not depend on local purchase.  This is the biggest challenge with low density equipment, the cost is same when supporting ten items or ten thousand items.  Low density items must get the funding to feed the supply system to support the deployable mission as the local dealership will not be accessible when equipment is down range.    

Product Life Cycle

The commercial marketplace drives COTS product definition, application and evolution based on advanced technology.  However, the Department of Defense in most cases does not purchase enough COT/NDI products from a single manufacturer on a single variant to obtain the required technical data required to develop required product support for equipment deployed.     

COTS products presume a flexible architecture and often depend on product releases that are designed to be used "as is" to meet general business needs and not a specific organization's needs. The commercial product life cycle is usually much shorter than the equivalent military product life cycle.

Programs should consider the potential availability of suitable replacement and/or alternative items throughout the longer, military life cycle, and should monitor the commercial marketplace through market research activities and ongoing alignment of business and technical processes. This necessary activity imposes additional cost, schedule, and performance risks for which the acquisition community should plan. COTS products should be evaluated to meet all performance and reliability requirements during all environmental conditions and service life requirements specified by the intended application requirements documents.

Role of the PM, SE, and PSM

The Systems Engineer should ensure open system design, identification, and mitigation of HSI, ESOH and security risks, survivable technology insertion, or refresh throughout the projected system life cycle. The PM, Systems Engineer and Lead Software Engineer should consider the following when evaluating use of COTS products:

  • The intended product-use environment and the extent to which this environment differs from (or is similar to) the commercial-use environment.
  • Integration, documentation, security, Human System Integration, ESOH, hardware/software integrity, reliability risk, program protection and corrosion susceptibility/risk
  • Planning for life-cycle activities (including sustainment, supply chain risks, obsolescence, and disposal)
  • Developing relationships with vendors, Foreign Ownership Control, and Influence (FOCI) (see Defense Counterintelligence and Security Agency for the latest policy regarding COTS products from FOCI sources)
  • Supportability, if product modifications are made or if vendor or marketplace changes occur
  • Test and evaluation of COTS items (including early identification of screening, functionality testing and usability assessments) (See Test & Evaluation Enterprise Guidebook)
  • Protecting intellectual property rights by being aware of pertinent intellectual property rights issues associated with commercial items acquisitions, especially with the acquisition of commercial software products. When acquiring Intellectual Property (IP) license rights, the acquisition community should consider the core principles described in the DoD guide: "Intellectual Property: Navigating through Commercial Waters."
  • Ability to modify or interface COTS software with other software even if it is Government-generated or owned.
  • Ability to have insight into configuration management, and the features and functions of upgrades and changes.
  • Ability to instrument and/or test aspects of COTS products.

Summary:  Greater use of Low Density Commercial-off-the-Shelf (COTS) systems and components is one strategy that can enable achieving the required DoD transformation to get today’s technology in the hands of the warfighter quickly and affordably.  The department is taking full advantage of globally available, high-tech commercial systems (e.g., from night vision devices, through secure cell phones, to satellite photos).  At the same time, technology is evolving more rapidly than ever before, and the DoD must recognize that it no longer holds a monopoly on all military-relevant technology (many of the information-intensive innovations result from commercial activities).  Because of their rapid availability, lower costs, and low risk, COTS products must be considered as alternatives to in-house, government-funded developments.

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