Cover: Life Cycle Management of Military Commercial Derivative Aircraft

Life Cycle Management of Military Commercial Derivative Aircraft

Improving FAA Certification, Implementation of Digital Engineering and Sustainment Strategy

Published Nov 21, 2023

by Brittany Clayton, Obaid Younossi, Brian Dolan, Thomas Goughnour, Devon Hill, Gwen Mazzotta, Benjamin J. Sacks, Barbara Bicksler


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Research Questions

  1. What is the best use of FAA certification for CDA acquisition?
  2. What are the best uses of organic and contractor logistics support arrangements for CDA sustainment?
  3. How can the USAF bring design into the digital space and use that to benefit the acquisition life cycle of CDA?
  4. What lessons can be learned from the KC-46 experience in these areas?

Commercial derivative aircraft (CDA) are aircraft based on a commercial design and modified to accommodate military requirements for a national security need. CDA have several features that can benefit the U.S. Air Force (USAF), such as reduced development time, management of cost overruns, and reduced risk throughout the aircraft life cycle process. 

Drawing on interviews with U.S. Air Force (USAF), Federal Aviation Administration (FAA), and industry experts, the authors assess the benefits and challenges of (and propose best practices for) CDA acquisition to inform future USAF strategy. The authors also review existing research related to CDA acquisition to improve understanding of the challenges associated with balancing the advantages and disadvantages of pursuing a CDA project and examine the KC-46A acquisition experience for lessons applicable to future CDA.

This is a companion report to another 2023 report, Improving Acquisition and Sustainment Outcomes for Military Commercial Derived Aircraft: The KC-46A Pegasus Experience.

Key Findings

  • When considering FAA certification, early, open, and regular communication between all parties can help the Department of the Air Force scope CDA projects and become aware of any issues throughout the process.
  • Knowledge and education of FAA certification processes does not appear standardized. This could contribute to confusion or unrealistic expectations of partners.
  • When considering the platform's mission and modifications from the base design, the authors found that more modifications could complicate the FAA certification process.
  • Maximizing the overlap of CDA operations with commercial variants and limiting modifications maximizes such benefits as shared parts, infrastructure, and supply chains, which can have important implications for sustainment.
  • Although there are many theoretical sustainment benefits cited in existing literature, there is a lack of empirical data demonstrating to what extent the USAF has realized sustainment benefits from a CDA acquisition.
  • The expected benefits of a successful CDA program could make the use of digital engineering more difficult but, through early systems engineering and planning efforts, these risks could be mitigated.


  • Play a larger role in defining the relationship between all parties in the FAA certification process, beginning with setting realistic internal expectations of what the certification process can provide for the USAF.
  • Develop and foster in-house talent for certification and CDA management.
  • Conduct consultations with the FAA Military Certification Office before a CDA acquisition decision is made to help the USAF decide on the best course of action and refine requirements.
  • Invest time and resources in understanding the commercial variant's life cycle prior to and during acquisition to ensure that CDA benefits are maximized and that risks are avoided.
  • During acquisition, carefully consider the necessary level of modification required to meet mission objectives and make efforts to minimize modifications when possible.
  • Invest in research and expertise related to the sustainment of CDA including expertise in Maintenance Steering Group-III maintenance practices and procedures and other commercial best practices.
  • Invest in data collection and research to better quantify the potential sustainment benefits of CDA.
  • Realistically consider all constraints, particularly constraints stemming from the nature of CDA acquisitions.
  • Realize digital engineering (DE) benefits, begin planning DE efforts when forming an acquisition strategy, and begin the planning process by considering priority goals of the program and matching to promising DE activities.
  • Apply systems engineering methods to identify DE activities, enablers, and investments required for success.

Research conducted by

This research was prepared for the Department of the Air Force and conducted within the Resource Management Program within RAND Project AIR FORCE.

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