CLS, ICS and PBL - A Study in Contrasts
Let’s start with definitions. Although more definitive statutory and policy documents are generally silent when it comes to promulgating formal definitions of these terms, there are still a wide array of definitions to choose from. Below is a sampling of a few of the many available Contractor Logistics Support (CLS) definitions to ponder:
- A US House Report 112-110 - Department Of Defense Appropriations Bill , 2012 section entitled "Contractor Logistics Support (CLS)" says "although there is no uniform definition of Contractor Logistics Support (CLS) throughout the Department of Defense, it is broadly defined as contracted weapon system sustainment that occurs over the life of the weapon system. Examples of CLS include contractor provided aircraft and engine overhaul, repair and replenishment of parts, sustaining engineering, and supply chain management."
- The above House Report 112-110 goes on to cite a 2009 RAND study that had defined CLS as "contractor sustainment of a weapon system that is intended to cover the total life cycle of the weapon system and generally includes multiple sustainment elements. CLS does not include interim contractor support, a temporary measure for a system's initial period of operation before a permanent form of support is in place. CLS also excludes contractor sustainment support for a specific sustainment task that the Air Force would otherwise conduct itself; a typical example would be a weapon system's prime contractor providing sustaining engineering."
- The DAU Glossary defines CLS as "the performance of maintenance and/or materiel management functions for a DoD system by a commercial activity. Current policy allows for the provision of system support by contractors on a long-term basis. Performance-Based Logistics (PBL) contracts should be used when utilizing CLS. Also called Long-Term Contractor Logistics Support."
- From a Service perspective, Army Regulation 700-127, Para 6–1.a.(2) defines contractor logistics support a bit more specifically as “logistics support of Army materiel performed under contract by commercial organizations (including the original manufacturer) is considered CLS. Support provided may include materiel and facilities, as well as services, in the following areas: (a) Supply and distribution, (b) Maintenance, (c) Training, (d) Software support, (e) Rebuild/overhaul, (f) Modification, and (g) System support.” The regulation’s glossary says it slightly differently as “Utilization of a commercial source to provide support for materiel employed by Army field units in the form of maintenance, supply and distribution, training, software support, and rebuild/overhaul.” (Para 6–1.a.(1) conversely defines organic logistics support as “any logistics support performed by a military department under military control, using Government owned or -controlled facilities, tools, test equipment, spares, repair parts, and military or civilian personnel, is considered organic support. Logistics support provided by one military service to another is considered organic within DoD.”)
- The Navy’s OPNAVINST 3000.12A defines CLS as “a strategy for weapon system life cycle support where the contractor manages (and may also own) the inventory, determine stockage levels, typically repairs non-serviceable material, and is required to meet specific performance metrics.”
- Marine Corps Order 4200.33, Para 4.a. defines Contractor Logistics Support (CLS) as “a method of obtaining logistics support for a product or service for a specified period of time. It may be implemented to provide total support for a product or system or to support one or more specific functions (e.g., maintenance, supply and distribution, training, information technology, and software/hardware support). CLS may be provided through commercial or government sources. CLS may encompass an entire system, individual system components, or a level of support services associated with the system or any and/or all of its components.”
- Interestingly, Joint Publication 1-02 (and Joint Publication 4-07) use a slightly different term "contracted logistic support" (vice contractor logistics support) which they more narrowly define as "support in which maintenance operations for a particular military system are performed exclusively by contract support personnel. Also called CLS" (note the use of the word "exclusively", which pretty much excludes integrated organic-industry arrangements such as public-private partnerships).
A few additional related data points regarding CLS to also consider:
- “The term “product support arrangement” means a contract, task order, or any type of other contractual arrangement, or any type of agreement or non-contractual arrangement within the Federal Government, for the performance of sustainment or logistics support required for major weapon systems, subsystems, or components. The term includes arrangements for any of the following:
(A) Performance-based logistics.
(B) Sustainment support.
(C) Contractor logistics support.
(D) Life-cycle product support.
(E) Weapon systems product support.” (10 U.S.C. 2337)
- “Contractor support during the pre-operational phase of a system is typically funded as a system development or investment cost. However, post-operational contractor support is an O&S cost and should be included in this element” (CAIG Operating & Support Cost Estimating Guide, Para 3.1.4).
- “Contractor logistics support (CLS) contracts and Direct Vendor Delivery (DVD) contracts are examples of make-to-order relationships where the DoD supply chain relies on external sources to fill customer demand instead of internal inventories.” (DoD 4140.1R, Para C22.214.171.124.1.)
- “CLS contracts will be written based on characteristics for performance based logistics. The PM shall establish flexible performance and funding ranges commensurate with targets developed in conjunction with the lead command, industry partners, and other relevant agencies across the acquisition, logistics, and user communities. These contracts will link contract incentives to performance outcomes while allowing the Air Force to make sound, enterprise-wide, capabilities-based resource decisions when deciding where to accept risk.” (Air Force Instruction 63-101/20-101, Para 6.10.3)
Similarly, there are also a range of definitions of Interim Contractor Support (ICS) available as well, including
- The DAU Glossary of Defense Acquisition Acronyms and Terms defines contractor support as “an overarching term that applies to a contractor’s materiel and/or maintenance support for a system. See Contractor Logistics Support (CLS) and Interim Contractor Support (ICS).” It then goes on to specifically define ICS as “temporary contractor support that allows a Service to defer investment in all or part of required support resources (spares, Technical Data (TD), support equipment, training equipment, etc.), while an organic support capability is phased in.”
- Army Regulation 700-127, Para 6-2a.defines Interim Contractor Support (ICS) as “the use of commercial support resources in lieu of organic capability for a predetermined amount of time (goal is not to exceed 3 years). This includes the use of contractor support for initial fielding.” The glossary itself defines ICS slightly differently as “a method of support used in compressed or accelerated acquisition programs, or when design is not sufficiently stabilized. Provides all or part of a materiel system support by contract for a specified interim period after initial deployment to allow organic support capability to be phased in. A support acquisition technique rather than a support concept.”
- Marine Corps Order 4200.33, Para 4.b. defines Interim Contractor Support (ICS) as “an acquisition strategy that allows fielding of a new or significantly modified item or system prior to determining the method of life cycle support on becoming operational. ICS gives the Marine Corps the flexibility to defer investment in all or part of the organic support resources (such as spare parts, technical data, support equipment, and training devices) and not to exceed 2 years.”
- Air Force Instruction 63-101/20-101, Para 6.10.1. defines Interim Contract Support (ICS) as “a temporary support method for an initial period of the operation of the system, equipment, or end-item. This strategy is utilized for controlling capital investment costs while design stability is being achieved and complex product support elements are being developed.”
Additionally, there are also several definitions of Performance Based Logistics (PBL), including:
- “Performance Based Logistics (PBL) (also known as Performance Based Life Cycle Product Support) is an outcome-based approach…, linked sustainment objectives and resources to system performance, not repair and supply activities; goals and incentives became structured around system performance, not failure; and risk was shifted to the support provider. PBL…delivered higher equipment readiness levels, applied best commercial practices, provided inherent product support integration, and provided a common strategy to bridge the acquisition and sustainment communities.” (Nov 2009 DoD Product Support Assessment).
- PBL has similarly been defined as “an outcome-based product support strategy that plans and delivers an integrated, affordable performance solution designed to optimize system readiness and affordability.” (DoD Project Proof Point Study Report)
As a side note, the establishment of “increasing effective use of Performance Based Logistics” as a formal Better Buying Power (BBP) 2.0 initiative to “incentivize productivity and innovation in industry and government" may ultimately necessitate an updated definition of PBL, which of we would of course share via the PBL Community of Practice (PBL CoP) and in this blog if or when that occurs.
So other than the fact the life cycle logistician is left with multiple definitions of these important terms, what are some key takeaways? Speaking strictly for myself (and certainly not as a DoD policy maker -- which is something I clearly am not), a few thoughts in no particular order:
- First off, CLS and ICS are not synonymous. ICS is clearly and by virtue of its name, an interim step or capability prior to implementation of a long-term product support strategy and/or arrangement.
- Secondly, PBL and CLS are also not synonymous. And as I said a few years back in an October 2009 “What Performance Based Logistics is and What it is Not — And What it Can and Cannot Do” Defense Acquisition Review Journal article, however, "Performance Based Logistics (PBL) is not outsourcing or Contractor Logistics Support (CLS). To repeat: PBL is not synonymous with outsourcing or contractor logistics support. This is clearly articulated in the December 2008 DoD Instruction 5000.02: "PBL offers the best strategic approach for delivering required life cycle readiness, reliability, and ownership costs. Sources of support may be organic, commercial, or a combination [emphasis added], with the primary focus on optimizing customer support, weapon system availability, and reduced ownership costs." This is reinforced in the DAU Glossary definition of CLS above.
- Third, each of these terms contribute to this important thing we call product support. CLS, ICS, and PBL, while each separate, distinct, and integral aspects of DoD product support, are each important concepts to understand and to wisely employ when and where appropriate.
- At the end of the day, as the DoD Product Support Manager (PSM) Guidebook so eloquently states (Para 1.3), “product support strategies can take many forms at many levels, leveraging the capabilities of a variety of product support providers. They can be established and implemented at the system, subsystem, or component level; they can more heavily leverage industry capabilities of the commercial sector, organic government capabilities or an integrated best value mix of commercial and organic sector competencies, capabilities, and expertise.” It’s more about the “what” than the “who” or the “how”; it’s certainly about optimized affordable readiness, achieving the best value outcomes and developing a strategy that leverages an optimal mix of product support integrator(s) and product support provider(s) possessing the best capabilities, expertise, processes and products to affordably meet the program or system requirements.
So what do you think? What did we miss? What would you add?