The Bane of ‘No Cost, No Commitment’ (NCNC) Trials

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By Cdr KP Sanjeev Kumar (Retd)

 

 

“Nothing comes from nothing; nothing ever could”

— from the song ‘Something Good’ in the 1965 classic ‘The Sound of Music’

One of the many challenges any original equipment manufacturer (OEM) or vendor trying to sell products to the armed forces has to face is Field Evaluation Trials (FET). In most cases, such trials are undertaken on ‘No Cost, No Commitment’ (NCNC) basis against stringent ‘Staff Qualitative Requirements’ or SQRs. Each individual service has its own GSQR, ASQR, NSQR, etc. Then there are Joint SQR (JSQR) for a multi-service procurement.

I have been part of few such trials while in service as a test pilot and always enjoyed the diverse experiences they added to my learnings. I enjoyed putting the aircraft or equipment through its paces, often placing challenging demands on companies who had no choice but to demonstrate everything to our complete satisfaction. Here are two anecdotes — one learnt vicariously from a senior, and another where I was personally involved:

Anecdotes

The Indian Navy at one point had an urgent requirement for a rapid deployable container (RDC) that could be air dropped with small items or spare part required for a warship at sea. One of the navy’s commands took up this challenge via the innovation route, personally driven by the Commander-in-Chief (C-in-C). Now, in India, innovation can often be confused with ‘jugaad‘. A local unit far removed from the realm of aviation was tasked to produce the RDC. The output was a souped-up high-density polyethylene (HDPE) drum that wouldn’t pass the test of common sense, let alone airworthiness. The squadron that was tasked to undertake flight trials politely declined stating safety and airworthiness issues. Much heat was brought to bear on the squadron CO who refused to be browbeaten. After a long standoff, the command HQ agreed to have the RDC airlifted to Airborne Delivery Research and Development Establishment (ADRDE), one of the DRDO laboratories that specialises in this area. As luck would have it, the delightful piece of innovation cracked open in flight due to pressure differential inside the very Dornier tasked for that airlift. The project came to an abrupt halt with egg on many faces, particularly when it came to light that ADRDE already had such an airworthy RDC capability sitting on a shelf. One shudders to think what may have been the consequences of that jugaad RDC taking some part of the aircraft along with it were the trials undertaken under dictat.

On the other hand, during a major NCNC trial, I have insisted on in-flight shut down of one engine on a legacy, battle-hardened platform that has seen decades of operational service while company test crew rolled eyes in disbelief, then shrugged and demonstrated it OUR way; just because the NSQR said “recovery from in-flight failure of one engine should be safe and not require excessive piloting effort”. In hindsight, i can see many other means, way safer and cheaper, to demonstrate compliance. The companies that had to bear the brunt of our incisive NCNC trial, costing well over a million dollars each, were left with much heartburn but no orders at the end of it all.

Between these two extreme ends of the spectrum, any company that has dealt with Indian defence procurement will find their own narrative.

Nebulous Cost, Nil Commitment?

While in uniform, my rose-tinted view of NCNC trials was seldom shared by the vendor side who had to go to great lengths to demonstrate their product to an extremely long and exhaustive list of SQRs. I never had to worry about costing. Unlike the services where operational costing and budget realities raise their ugly head mostly after your watch, companies have to grapple with activity-based costing every day for every little activity. Startups and MSMEs working on angel funding can hardly afford such flights of fancy.

While Requests for Information’ (RFI) fly out of service headquarters thick and fast (it requires few minutes of typing, principal director’s approval and out it goes through the fax machine), crafting technical and legally tenable answers to these RFIs often comes at great cost — both money and man hours are consumed at the vendor’s side. Sometimes, the RFIs are tentative in nature; testing the waters; trying to bridge knowledge gaps; often coming from people who do not realise the full import of the questions they raise. When I admit I have done this as a qualified test pilot in staff, the malaise must run pretty deep. In hindsight, I have nothing but sympathy for some of the vendors whose products I tested with ‘precision & excellence’, only to see ‘nil orders, nil commitment’ subsequently. Quite clearly, only one side had skin in the game or appetite for purchase orders.

The minefield of NCNC trials is hardly a level playing field. The Indian Navy supported an indigenous sonar trial with ships, helicopters and submarines. Can you expect any service to extend this generosity to private players? Who will foot the bill? Every item offered for trials doesn’t come from established players or companies with huge budgetary outlays for such trials. Even the big players would be hard put to sustain an acquisition program that stretches over a decade riding on the back of NCNC, then gets bitten in the rump by the proverbial snake in the ‘snakes & ladders’ to return to square one. I have seen the pain that accompanies a decade-long process starting from RFI to trials that falls apart at some point downstream. It is not healthy for either side. One side loses money and the other, capability.

Where we come from…

There is an elaborate process of certification and quality assurance which every aerospace product has to undergo. The arena of defence acquisition is already over-regulated and under-funded. Does Indian armed forces and the nascent private defence industry have the luxury of taking the ‘death by testing and taxation’ route or is there an alternate way?

I am afraid, in answering this question we will need to accept the ridiculous way things are done around here. It also depends which side of the divide you stand. We have been at the receiving end of poor design and insufficient technology for years. Our past experience and conditioning shapes our approach to this issue. There is serious trust deficit at the root of this. Caveat Emptor rules supreme in our system. I am afraid till the time every blade of grass in the lawns of MoD and every ream of A4 paper in service headquarters is costed, the services will never see the necessity to change anything. Everything in aviation needs huge cost and unstinting commitment to bear fruit. Trials are an inescapable reality too. The need is to define budget boundaries and frameworks within which the desired outcome can be achieved without running companies bankrupt. Mr. Sukaran Singh, CEO & MD of Tata Advanced Systems Ltd made a golden point during our panel discussion at Aero India 2021 that “we cannot look only at the numerator and ignore the denominator”. He went on to state, rather grimly, that “sooner or later, some good guys will get up and leave”.

I reached out to Vice Admiral Suresh Bangara who has steered the navy’s budget and plans division, retired as C-in-C Southern Naval Command, and now advises start-ups and MSMEs. He minced no words in his sharp critique of the NCNC method: “It is clear that our staff officers remain fixated in the old belief of making a preliminary approach brief as complicated as possible and then throwing a challenge to make the impossible possible. The good news is that there are mad hats among the youth who can produce wonders. Clubbing the philosophy of NCNC — zero risks at your end, and asking for the moon, provided the journey is free for you — does not wash well in today’s world. There is much we can do but not a single entrepreneur has the ability to take hits with zero returns.”

I cannot agree more. Our approach to innovation, entrepreneurship, acquisition and trials cannot operate in a financial vacuum. The private industry doesn’t work that way. A fair amount of budgetary allocation and a critical mass of orders is essential to signal MSMEs and attract the right talent our way. Else, wheeler-dealers will continue to run amok.

Rule books must include this reality too

Design, Development & Production of Military Aircraft and Airborne Stores (DDPMAS-2002) was the existing rule book for design, development and production of military aircraft and airborne stores in India. It should tell us something about our reluctance to change that the document first issued in 1975, was revised in 2002 and thereafter in 2020. In between, technology has leapfrogged while our processes and approach to testing remained more or less stagnant. The latest revision to accommodate the ‘Atmanirbhar Bharat‘ policy by improving the participation of private industry was recently released during Aero India 2021. A ‘multi-layered and structured approach’ in DDPMAS 2020 aims to simplify understanding and application of Indian Military Technical Airworthiness Requirements (IMTAR) while also aligning with international best practices. Each regulation therein defines technical airworthiness requirements duly supported with Acceptable Means of Compliance (AMC), which are ‘non-exclusive means of demonstration of compliance’. Indian Navy has also published a ‘Naval Aviation Indigenisation Guidebook’ that is available online. Yet when you scan the landscape around for money or orders, you still see only the latter half of NCNC.

DAP 2020 includes “acquisitions covered under the Make and Innovation including Innovation in Defence Excellence (iDEX) and Technology Development Fund (TDF). There is also segregation of non-negotiable core capabilities that will be tested and validated at the FET stage (Essential Parameters A); parameters not available originally in the equipment fielded for the FET, but can be developed and achieved by the vendors using available technologies (Essential Parameters B); and parameters that enhance the capability of the equipment even though not included in the SQRs (Enhanced Performance Parameters). DAP also permits Certificate of Conformance (CoC) as part of trial methodology. These are attributes/parameters for which CoC along with test standards and test results from NABL/ internationally accredited and government designated labs are acceptable. Leasing is another attractive option opened up by DAP 2020 where services can shorten the acquisition cycle using a model that circumvents the exhaustive FET route by going in for an operational demonstration instead. All this should not remain shelfware while we walk a different path and continue to go the NCNC way.

Technical Standard Orders & Testing Infrastructure

Federal Aviation Administration (FAA) has Technical Standard Orders (TSO) listed on their website. As per FAA, “TSO is a minimum performance standard for specified materials, parts, and appliances used on civil aircraft. When authorized to manufacture a material, part, or appliances to a TSO standard, this is referred to as TSO authorization. Receiving a TSO authorization is both design and production approval.” It means that an article ‘meets a minimum performance requirement independent of the article’s intended installation on an aircraft’. A separate FAA approval is required to install the article on an aircraft.

If we in India draw up TSOs for a wide spectrum of military aircraft parts and sub-assemblies, then what remains is the availability of ground and flight test facilities, including instrumentation, telemetry, flight test crew and associated infrastructure. While the developed world has private fight test agencies besides a whole host of large players like Boeing, Lockheed Martin, Leonardo, etc. we in India have to run to Defence PSUs or DRDO agencies for bridging the TSO-ground test-flight test chasm. Why should this be so? Why not allow private sector access to such government-owned test facilities for a price? In India, it is terribly difficult to obtain military certification because of the entry barriers to flight testing. Perhaps, there is a need for the Society of Indigenous Defence Manufacturers (SIDM) or Confederation of Indian Industry (CII) to identify and procure few flying test beds. One of the bigger players could consider investing in flight test infrastructure in cohort with CEMILAC to explore a parallel path for testing and approvals. Such test beds can be procured by a consortium and maintained through service-assisted or private MRO agencies. Legacy aircraft from the three services can also be looked at as an option.

But all this will remain ‘unobtanium’ without purchase orders. If the services go down the beaten path of NCNC with cost being borne by industry and zero commitment to place orders, all we will have are more grandiose air shows, seminars, panel discussion and more money down the drain.

(Video coverage of the SIDM seminar can be viewed by clicking the link here. Fast forward to the navy-industry panel discussion, applauded by many as the most candid and engaging ones at the seminar, at about 2h58min. You can hear my speech from about 3h25min onwards).

Aero India Seminar Flyer

 

A gist of this article was delivered by the author at the panel discussion on ‘Future of Indigenous Helicopters’ at Aero India 2021 on invitation from SIDM and Indian Navy. Views are personal.

 

-Cdr KP Sanjeev Kumar (Retd) is a former navy test pilot who has flown over 4200 hours on 24 different aircraft. He has worked closely with HAL and industry in projects of national importance and undertaken flight test projects in India and abroad. He calls himself ‘full-time aviator, part-time writer’ and maintains a diligent blog at www.kaypius.com. He can be reached at kipsake1@gmail.com. Views expressed are personal and do not necessarily reflect the views of Raksha Anirveda.

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