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Defense Exportability – Major DoD Capability Requirements Changes

Defense Exportability – Major DoD Capability Requirements Changes

Frank Kenlon (Prof of Int'l Acq, DAU/DSMC-Int'l)

When I first started working for the Navy as a GS-5 “back in the day,” one of my mentors explained that “Big A” defense acquisition was comprised of three main pillars:

  • The DoD requirements determination system, which is now called the Joint Capabilities Integration and Development System (JCIDS).
  • The DoD acquisition decision system, also known as “Little A acquisition,” which then (and now) was governed through DoD 5000 series directives and instructions.
  • The DoD funding system, which then was called the Planning, Programming, and Budgeting System (PPBS) (later on an “E” for Execution was added).

Bottom Line Up Front

Defense exportability advocates have always believed that the JCIDS process should establish capability requirements to ensure new and modified DoD systems are developed with future sale or transfer to allied/friendly nations in mind.

Good news! The latest version of the Joint Chiefs of Staff Manual for the Operation of JCIDS issued on October 30, 2021, has fully implemented the U.S. Government Conventional Arms Transfer (CAT) Policy guidance on building in exportability addressed in JROCM 025-19 of April 15, 2019.

New JCIDS Manual Guidance (the gory details)

For those who subscribe to that old adage “the devil is in the details,” the October 2021 JCIDS Manual is 399 pages in length. Thanks to the Adobe Acrobat “Find” function, and a bit extra focus on our part, the DSMC-International faculty has managed to dig out the following specific exportability guidance contained in the revised version of this Manual.

The Glossary contains two new key terms:

Exportability” - The process to identify, develop and integrate technology protection features into U.S. defense systems early in the acquisition process to protect Critical Program Information (CPI) and other critical technologies / capabilities and thus enables a system’s export to partners. Technology protection primarily involves two tools: Anti-Tamper (AT) and differential capability modifications.”

Mandatory Performance Attributes” - These consist of the four mandatory KPPs as well as the Interoperability Performance Attribute and Exportability.”

This the first time “Exportability” term has been officially defined in a DoD-level policy document, and the first time that exportability has been designated a “Mandatory Performance Attribute” in the JCDIS process.

JCIDS Manual Enclosure A emphasizes the importance of exportability considerations in the development of new capability solutions:

Following the decision on the best path forward for the capability solution, the key aspects of follow-on documentation will include traceability to validated CRs, Measures of Performance (MOP), exportability planning, and resourcing required to develop the proposed capability solutions(s). This follow-on documentation will inform technology maturation and/or acquisition programs for associated capability solutions.”

JCIDS Manual Enclosure B, Appendix A provides guidance on Initial Capabilities Documents (ICDs) includes previously issued JROCM 025-19 policy in this area:

Sponsors shall address Exportability “Allied/Partner Interoperability and Coalition Use” as per the Conventional Arms Transfer Policy in this Section of the CONOPS,” which refers to an ICD’s Section 1, Operational Context.’

JCIDS Manual Enclosure B, Appendix C includes new guidance on Capabilities Development Documents (CDDs) includes previously issued JROCM 025-19 policy in this area:

Sponsors shall address Exportability “Allied/Partner Interoperability and Coalition Use” as per the Conventional Arms Transfer Policy in this Section. Standard Exportability language shall be addressed as a mandatory [Key System Attribute] KSA.”

JCIDS Manual Enclosure B, Appendix C provides new guidance regarding the Technology Security and Foreign Disclosure aspects of CDD development:

"Sponsors shall address Exportability “Allied/Partner Interoperability and Coalition Use” as per the Conventional Arms Transfer Policy. Sponsors must consider existing export controls, controlled technical information assessments, and the identification of critical program information when addressing exportability. Coordination with the Defense Technology Security Administration and the sponsor’s associated Military Department Counterintelligence Organization can assist for scoping requirements in the Intelligence Supportability Section.”

JCIDS Manual Enclosure B, Appendix E includes new guidance regarding the exportability policy for DoD non-material capability solutions:

The purpose of a [DOTmLPF-P Change Recommendation] (DCR) is to propose non-materiel capability solutions, which may serve as an alternative to, or complement of, materiel capability solutions … the materiel DOTmLPF-P consideration is everything necessary to equip DoD forces to operate effectively. The letter “m” in the acronym is usually lower case, since Joint DCRs do not advocate new materiel development, but rather advocate increased quantities or alternate applications of existing materiel ..." Regardless of the solution, Interoperability and Exportability: Allied Partner/Coalition Use should be considered and addressed in Section 1 of the DCR.” (DOTmLPF-P is an acronym for “Doctrine, Organization, Training, Materiel, Leadership and Education, Personnel, Facilities and Policy.”)

JCIDS Manual Enclosure B, Appendix G, Annex G emphasizes the importance of security support requirements in a system’s program protection exportability design and development efforts:

Sponsors shall address security support requirements to enhance protection of the capability, including measures for physical security, personnel, Industrial, Classified and Controlled Unclassified Information (CUI) security, communication security, technology security, and requirements associated with the exportability or foreign involvement with [Critical Program Technology Information] CPTI, including anti-tamper, supply chain and foreign disclosure.”

New JCIDS Manual Guidance (executive summary)

The previous version JCIDS Manual addressed exportability in general terms, treating it as an option that should be considered by DoD Requirements Sponsors. The revised version makes exportability a Mandatory Performance Attribute in new JCIDS ICDs, CDDs, and a key consideration in DCRs that address “little m” JCIDS capability material solutions.

Future Impact on “Big A” Acquisition?

In theory, mandatory JCIDS exportability requirements should lead to development and fielding of systems by DoD acquisition Program Managers that should be both available to -- and interoperable with -- the military forces of our allies and friends. DoD’s “little A’ acquisition policy DoDI 5000.85 (Major Capability Acquisition) also makes building exportability into new and modified DoD systems mandatory, noting that a program’s Milestone Decision Authority can grant a waiver from this requirement in certain circumstances. DoD PPBES policy, however, remains silent on funding these JCIDS and DoDI 5000 series exportability mandates.

Experience has shown that all three Big A acquisition policies and practices must be aligned to achieve DoD’s desired outcomes at the program level. Hopefully, DoD Components will include additional funding in their future PPBES submissions to make building in exportability a reality. Another old adage, “follow the money” comes to mind.

Until next time, Prof K