Pontifications: COTS and the KC-46A Aircraft Production Systems

Part 1 in a Boeing series about the USAF refueling tanker

By the Leeham News Team

January 17, 2022, © Leeham News: COTS is an acronym meaning Commercial Off the Shelf. It’s often a requirement for certain types of aircraft to be used by the US Air Force.

The title is a bit misleading in that in most cases, there is no directly usable off-the-shelf product, but instead, a jumping-off point that saves a tremendous amount of development. In aircraft procurement, many things have been bought this way. The advantage to the Air Force is that they get a known flyable aircraft that is for the most part debugged and has an operational history that allows the Air Force to estimate the maintenance burden and training requirements. It shaves years off the acquisition process and can be a very cost-effective way to gain new capabilities.

An Early COTS aircraft

One of the earliest COTS aircraft procurement programs was the T-41 Mescalero. This was a single-engined piston trainer used for pilot screening at basic flight training. The T-41 was a COTS purchase using a Cessna 172 as the jumping-off point for the design. In 1964, T-41A production commenced. Four different T-41models were built totaling 756 units for the USAF with many of them supplying small air forces around the world as a trainer. There were a few changes made between the Cessna-designed airplane and what the USAF wanted.  All of them got jettisonable doors and a bigger diameter nosewheel. Later models got a larger engine from a Cessna 182. It was a simple way to get the USAF what it needed. It found a good jumping-off point that was already designed, proven, supportable, had a fairly defined unit cost, and could use existing civilian maintainers in addition to Air Force personnel. It served as the USAFs basic pilot screening aircraft from 1964 to 1996. From these simple beginnings, other COTS aircraft programs evolved.

The COTS process for the T-41 program was simple.

  • Identify the need and define it
  • Find candidate aircraft in production.
  • Down Select to the final choice
  • Define what needs to be removed
  • Define what needs to be added
  • Build and deliver

COTS for the KC-46A

So, let’s see how this works for the 767 to KC-46 COTS program.

The first step in creating a COTS program today is to understand the United States Munitions List, ITAR (International Traffic in Arms Regulations), and how these things impact a COTS program. The US Munitions List is a list of all things deemed to be weapons, weapon components, ammunition or technology that advances the ability of a foreign entity to produce the same. The list is very comprehensive and runs literally thousands of pages. Aerial Tanker Aircraft are specifically listed, as are components in it like the Boom, Electronic Countermeasures, and hundreds of other items.

ITAR is the set of regulations on how contractors must protect these things from inadvertent export to foreign entities not subject to an export license. At the highest and simplest view, it requires you to separate the production facility components and data from anyone that is not a US Person. This requirement is not only the responsibility of the prime vendor but all sub-tier suppliers of program components and data.

US Persons are US citizens and foreign nationals with authorized residency. Unauthorized Exports can be either Hardware or Data and the rules are so complicated that you can export items without leaving the state or country you are in. Compliance is complicated, expensive, and mandatory. The result of ITAR compliance on the KC46 was the separation of the tanker design data into its own repository accessible to cleared workers as well as the separation of the production bays by fences with badge-controlled access.

ITAR complicates life at every turn. Boeing has done factory segregation before on the 737-based P8 line in Renton, so its implementation process was known. But it still forced large factory changes in the Everett Factory and the creation of a delivery center where 767-2Cs were converted to KC-46s.

What is a 767-2C?

The first step in the COTS process is to find a candidate aircraft. Boeing offered the 767. It’s been in production for a long time, was built in three different fuselage lengths, with and without cargo doors, with different wings having different wing spars, avionics, auxiliary fuel tanks, and a myriad of other possibilities.

Virtually none of the previously built 767s made a suitable starting point since much of the primary structure for the KC-46 would be unique. Boeing, to comply with COTS, needed an FAA-certified 767 derivative that the USAF could use as the KC-46 feedstock. Boeing created the 767-2C as a paper airplane representing the jumping-off point. This added a bit of complication to the process, as it needed to be test flown and certified to meet the contractual requirement of COTS before they could build it up into a tanker.

Now the process looked like this

  • The 767 was selected
  • Define the certified 767 start point
  • Impose ITAR on the Design-Build Facility
  • Produce the candidate 767-2C
  • Get the 767-2C type certified
  • Define what needs to be removed
  • Define what needs to be added
  • Build and deliver
Creating a COTS aircraft

After Boeing won the KC-46 contract, it needed to build the 767-2C to create the COTS airframe that would be the jumping-off point for the KC-46. Until now, it had been a bit of a cart before the horse exercise in that Boeing sold a notional aircraft that didn’t exist as a jumping-off point for the tanker. Having won the contract, Boeing needed to go from a paper airplane to an FAA-certified aircraft as the first step in the process.

Boeing’s Designers went to their Lego-like library of previously built 767 airplanes, grabbed the closest stuff that would work as a starting point, and redrafted those drawings into new structures drawings for the 767-2C. Along the way, it stuffed as much Tanker Specific unclassified structure into the airplane as possible. After a huge effort producing the appropriate drawings, Boeing ended up with the design for a big cargo door 767 freighter with large belly fuel tanks, new engine nacelles without thrust reversers, an air-to-air refueling receptacle in the cockpit roof, and a boom operators position without a boom.

Those were the big structures changes. There were thousands of others. The entire electrical system was new because it all needed to be explosion-proof. There was a tremendous engineering package processed to get to the 767-2C. When the uninitiated speak of it as being a modified 767, there is a misunderstanding of the realities of the COTS process. This aircraft shared so little in common with the 767 freighters being simultaneously manufactured commercially on the 767 assembly line that it blurred the lines of “certification by commonality,” a key reason for using the COTS process in the first place.

Engineering the KC-46A

At the same time, the 767-2C was being engineered, the KC-46 Tanker drawing package was created, and it was huge. All the internal fuel piping was defined. It was all double wall to prevent leaks. The defensive electronics package and the LAIRCOM (Large Aircraft Infrared Countermeasures) systems. The synthetic vision systems for the boomer as well as the boom itself. There was also a large volume of classified stuff being defined, including all the encrypted data link comm systems as well as all the mission software.

But that wasn’t all. All of the maintenance manuals and crew training elements needed to be produced as well as the ground trainers themselves. The scope of this effort is usually missed by those asking why aircraft cost so much. It’s a truly massive undertaking. Training new airmen to become experienced maintainers of the KC-46 requires dozens of volumes of specific instructions showing how every interchangeable part on the airplane is accessed, evaluated, removed, replaced, function checked, closed, and returned to service. Technical Publications never end, as parts are updated, and processes change over the lifetime of the system.

Separating assembly lines

Inside the factory, tanker preparations included isolating the 767 production line from the rest of the factory and creating the ITAR compliance island. A second facility for the conversion of the 767-2C into the KC-46 was built across the field from the factory.

Today Boeing Commercial Aircraft builds 767-2Cs on the Everett Assembly line. These are delivered to Boeing Defense and Space in a tow bar delivery to the BDS completion center. BDS “converts” the 767-2Cs into KC-46A and after completion, redelivers them to the customers (principally the USAF).

Next week: The biggest disappointment in Jim Albaugh’s career













90 Comments on “Pontifications: COTS and the KC-46A Aircraft Production Systems

  1. Excellent, very clear description (thumbs up). As a follow up would be good to see a worked comparison with KC45/LMXT to highlight the deltas (risk, cost etc) between the proposals to put some shading on the decision making you see.

    • Interesting to see that back when Airbus seems to have had a much more complete product at hand.
      Beyond the “only America(ns) can do that” stuff that a select poster is so fond off 🙂

    • Yes, what does the A330 MRTT already complies with and what new stuff is Required? I guess it is a moving target as the A330 MRTT is getting upgraded for each batch delivered.

      • bespoke demand:
        buyer selected/furnished stuff ( like self defencse systems.. $100k loo tops :-).
        no idea if wire loom separations are a US only option.
        maybe some “we demand NEMA not IEC” like selections.

        • claes:

          The answer is a maybe. First it has to meet USAF specs and then it has to be determined if it has to match existing or can be different mfg equipment that meets the specs.

          I don’t know the answer but that frames the issues.

          Regardless it also has to be tested to ensure that it all works. Even identical equipment in a different air frame can act differently so it gets tested.

          • “First it has to meet USAF specs”

            So does the KC46 — by definition, a plane with a Cat I deficiency doesn’t meet spec; the KC46 has 6 of them, and won’t be rid of them until 2024 at the earliest.

          • Yes, it is hard to know how close the MRTT is to the USAF spec’s and how much work LM need to perform for it to meet all spec’s. Just having the auto refuel system USAF certified can take some time (if the USAF even wants it). One could assume that a fly by wire aircraft is much easier to make redundant with spread optic cables “everywhere” with just one intact to have a fully operational aircraft. Airbus with 3 hydraulic systems also helps to keep it flying after some systems are shut down.

          • claes:

            FBS: Physically it would be easier, reality though is you would have to design all new routes and then run them in places that never had them.

            It also depends on how susceptible to EMP the FBW system is and design protection for it and installing it (and any jamming)

            If its not been done then its a big issue. Something like the Tiger would have it from the start but mods and back fitting is always a lot harder. And then you have to prove it works.

  2. Thanks very much for this review (Scott and team?). Four key points: 1) there’s, at least in my mind, LUNACY (Yes, LUNACY) in creating a “paper” COTS 767 (Why not specifically, for example, use the 767-300F, for example?); 2) the Remote Viewing System should NEVER—I repeat NEVER—have made it into ANY production airplane system (the KC46A) without FIRST being fully PROVEN with a SEPARATE, “cost plus” USAF R &D contract! (As a “side note” to this, it’s in my mind, time to start “taking numbers”, “naming names”, and issuing “career enders” for the USAF brass, and Boeing executive managers involved in this whole KC46 process! Why? The financial losses and “bad press” on it for BA have been nothing short of, “drum roll”: STUPENDOUS!; 3) Specifically, as head of BDS during the time of these STUPENDOUS KC46A losses, why hasn’t Leanne Caret been FIRED?(Bring back “The captain goes down with the ship”); and 4) the (hopefully) new head of BDS—and CEO of Boeing (Yep, looking at you, Mr. Calhoun), need to look long and hard at any KC-Y contract proposals, and be fully prepared to just “walk away” from any proposed contract that can’t give you a 15% pretax return on the program. (Geez, if you’ve been nothing short of BLUDGEONED, BA, on the KC46 financially and reputation-ally, , learn something!) As a BA shareholder, this last point should be demanded and “nonnegotiable”. And, BA Board, you should be supervising and ENFORCING.this! P.S. Point of interest, why are there no thrust reversers on this a/c?

    • re the thrust reversers – the USAF didn’t want them. USAF tankers operate from very long runways, often over 12,000 feet long and have no operational or external reason not to use all of it on rollout. Thrust reversers add weight and maintenance complexity.

      for commercial aircraft, there are operational benefits to both the airline and the airport to getting off the runway as quickly as possible, additionally thrust reversers allow access to shorter runways without excessive brake wear.

      • Thanks. Sort of makes sense. If you’re a myoptic penny-pincher. Till you think of Chinese missiles crippling those nice, “fat” runways at Kadena, Anderson, Misawa, and whatever they’re calling Clark these days in an opening set of salvos. Then, once again, the USAF is gonna look mighty stupid!

        • No they do not always operate from long runways.

          For whatever reason the USAF determined that Thrust Reverse was an unnecessary expense and maint adder.

          That said, under 900 hours a year and wear and tear on brakes is vastly less than commercial ops.

          As a side note, for test and cert purposes, you can’t depend on TR to stop in the required distance and loads.

          The brakes have to be able to meet spec all by themselves.

          • I don’t know about the original KC-135 but the re-engined one was also done without thrust reversers, presumably to reduce mass.

    • “Bring back “The captain goes down with the ship”

      How faint!
      Today you lead from behind and are last person standing.

    • @MontanaOsprey

      This is hilarious:

      The Remote Viewing System should NEVER—I repeat NEVER—have made it into ANY production airplane system (the KC46A) without FIRST being fully PROVEN with a SEPARATE, “cost plus” USAF R &D contract!

      The Kappa Vision System* for the A330 MRT was paid for by Airbus. Hence, there was no need for a stupid “cost plus” contract when the R&D is run by competent people and organisation — using German precision optics.

      Perhaps the problem with the flawed systems aboard the KC-46 is caused by the Not-Invented-Here-Syndrome — a contagious disease the has infected all levels of the U.S. Government, and at least, one major U.S. original equipment manufacturer.

      * https://www.kappa-optronics.com/en/aviation/in-flight-refueling-vision-systems/

      • Too bad I can’t use the Missouri “Show Me” state moniker. Can you cite any INDEPENDENT, open sources that this system actually “works”, and meets USAF specs? Hate to bring politics into this, but given Washington state is turning into a mostly “blue nutter” state (with two “blue nutter” US senators), I don’t like AB’s and LM’s chances, given the KC-Y timeline, LOL.

        • MO:

          Tech comments are fine but the status of WS in regard to politics is way out of line.

          I can say that Alabama has had an outsized influence in congress particularly before Sessions moved on to AJ. All without name flinging.

          Politics is a reality here as well as everywhere else in the world.

          Make a case its corrupt and cite sources.

  3. The “Can’t we just….” mentality of American management leads to poor designs. A programmer hearing “Can’t we just..” winces, as he knows the answer should be a resounding NO we shouldn’t but, ends up answering “Yes, But…”. After the Enron financial debacle, the Government decreed a bunch of regulations which ushered in SDLC (Software Development Life Cycle). And companies hired accounting firms to quickly put something in place, as the government mandated deadline approached. It usually ended up forcing the programmers to fill out mountains of paperwork for every programming change. This is why I , as a programmer, stopped working for any commercial public company. I only worked for private companies that didn’t have to deal with the mountain of useless paperwork. I could spend my time programming, not 80% of the time shuffling paper. The 737-MAX was mandated by Boeings customers to be “Can’t we just…” modify the current 737 a bit, to mangle it here, hang some new engines there, tack on some new FBW spoilers here, and if any problems arise, “can’t we just..” change some programming here, and change some switches there. And above all, make sure it doesn’t need any new training required for pilots. This KC tanker program change sounds like it will suffer from the same “can’t we just…” problem. If an engineering problem arises, someone will ask “Can’t we just…”. The proper answer should be, “NO, we shouldn’t”, but, because of finances, a lot of times, it comes out to “Yes, but, it will cause..” Beware of anyone asking the question “Can’t we just…” in a design meeting or a problem session meeting while building an aircraft. You can only bend, mangle, stretch, fold and mutilate things so far before they break.

    • What really turns such things into killers is the layer cake approach. Adding features over already added feaatures until nobody has any sound idea on what is at the core and how these add-ons can clash.

      • RD:

        I believe the MAX was Boeing telling customers its old 737 architecture was so good that they did not need any conversion training.

        As Airbus has a lineup of the Single Isle up through the A321 that Boeing does not, Boeing is at a major disadvantage for anyone who wants that A321 capability.

        Boeing painted itself into a corner by not coming out with an A320 type aircraft that could do what the A320 series can do.

        • You have it completely backwards……Boeing was peddling the Y1, or polywog. It was an all composite, twin aisle aircraft designed to replace the 737….. The 737 operators told BA they would rather have another 737 derivative… That became the Max… Ba had it right but couldn’t sell it….

      • Muilenberger: “….safety is in our DNA….”
        Yeah, right!
        Maybe it was in there before the McD gene splicing.
        More honestly: “Maximizing shareholder value is in our DNA.”

        • John:

          I think Boeing and safety is in line with the mything of how wonderoud the FAA was (look at its history and not so much)

          Boeing had a lot of early jet crashes. They assumed pilots could fly them easier (just a throttle). they found out differently.

          Then you have the 737 Rudder issue and the Lauda Air 767 crash.

          Boeing tried to dismiss those without taking a hard look.

          You read Sutters book and you see how close some of those fight were over safety.

          So, it may have been a much as luck as good engineering or enough good engineering it did not go over the edge but always closer to the edge than Urban Legend has it.

          • Yes, but there is a lot of evidence that the new Boeing (post-merger) just tends to assume planes are safe and focus on making them as cheaply as possible.
            In this Max fiasco, it’s very probable that the old Boeing would have:
            1. Fixed the stability problem with appropriate hardware rather than cheaper software.
            2. If they did an MCAS it would have real two AOA sensors rather than one
            3. The sensor fault warning light would have remained standard equipment.
            Etc, etc
            Also, McD historically has much worse safety record. Read that the only commercial planes that got tickets pulled by FAA had one thing in common, all from McD: DC-10, 787, and the Max. All managed by the GE-McD beancounter mafia….
            If they were German they would regale themselves in their morning showers singing:
            “Shareholder value, Shareholder value…uber alles, uber alles…”

  4. No wonder the KC46 has had (and continues to have) such an endless litany of defects: its starting point was a paper airplane (actually, paper Frankenplane) that had never flown.

    BA seems to have developed quite a penchant for paper airplanes: the 777X is another one, the 737-10 looks like it could also be one, and one can question whether the new HGW 787 variants might be candidates. Of course, the mother of them all was/is the NMA.
    Now that self-cert is off the table, it has become much more difficult to convert paper to reality.

    • The A330MRT would have been required to go through the same process.

      It never did. It took Australia to get the basic A330MRT (and whatever spec they had) into service.

      • The A330 MRTT is fully operational, and has functionality (autonomous re-fueling) that leaves the KC46 in the dust.

        Was the A330MRTT based on a paper airplane?

        • Yes the A330MRT was a paper airplane.

          You clearly missed the fact that the government issued a 4.5 billion contract to the process. Airbus walked away with 1.5 billion as that is part of the deal even if protested wins (it did). So Airbus corrupted the USAF officials and got paid to do so on the 2nd contract.

          That said, the A330MRT is not certified. So they would have had to go back through all the work and certify it. Boeing did that as a rolling process.

          You might ask the Chinese or Mitsubishi how its going (goes) with trying to back certify the C919 or the MRJ when it failed the process.

          But keep posting, love to see the failure to inform

          • “Yes the A330MRT was a paper airplane.”

            The question was if the A330MRTT was BASED on a paper airplane…

          • To help you out a little: watch this video, which explains how an A330MRTT is made FROM AN A330-200…an aircraft type which had been flying for more than a decade before the MRTT intro…and thus not a paper precursor.


          • The Airbus A330 MRTT was ordered and flying long before winning the USAF KCX contract at end of Feb 2008. The contract was stopped very quickly after protest in July 2008.
            If you think Airbus spent $1.5 bill in development funds in 6 months, it’s a fantasy

          • Duke:

            You need to go back and read timelines.

            The A330MRT was in development during the bid, it did not have a flying tanker at the time of the bid.

            Another Urban Legend.

          • Airbus didnt spend $1.5 bill in deveopment funds for the KC-45 ( A330)

            That was certainly the system design and development and 4 test aircraft contract – which lasted around 6 months.
            But its a contract with deliverables not a blank cheque for $1.5 bill.

          • (Madrid, February 14, 2008) — The first A330 MRTT prototype MSN747 has landed today at EADS MTAD facilities in Getafe, Madrid at 12:15h local time after completing Phase 1 of the flight testing that has been primarily devoted to civil certification. EADS MTAD has officially announced the conclusion of a key Australian A330 MRTT programme milestone.”
            “The A330 MRTT has behaved as expected, showing that the modifications introduced to the MRTT configuration (including refuelling pods and boom) had no significant effect on the aircraft’s performance. ”
            Not all problems resolved but the initial aircraft with boom and pods flying in 2008

          • Paper airplanes are the norm…..Everybody does it that way. Nobody commits the cash to build a flying prototype without sales, (well maybe china and russia do)….. A paper airplane today is a digital representation of sufficient depth that you predict performance with high accuracy. Think this thru for a minute, every airplane being marketed to customers is a paper airplane UNTIL YOU GET A LAUNCH CUSTOMER. Boeing and Airbus both have paper airplanes that never got orders. The whole MAX program happened because the Y1 got turned down by the customers. Those of you that bang the drum that Boeing pitched a paper airplane at the front end of the tanker bid are just ignorant of the process….. Airbusses proposed competitor also existed on paper. They took their existing MRTT as a starting point and built the paper plane from there….

          • “Those of you that bang the drum that Boeing pitched a paper airplane are just ignorant of the process…..”

            But then you need the capability to create working reality from those papers in an acceptable timeframe.

            What posters here berate is not “paper airplane” as such but “stuck as a paper airplane”. ( counter to Boeing PR of having privileged knowledge in that domain.

            Notice that the (start <2005) development platform for Airbus ARBS was the existing A310 MRTT. Overall a modular approach that actually "sticks together" 🙂

        • And yes the F-35 is fully operational and combat tested.

          Finland is a front line state in the Russian aggression sphere, they don’t pick junk, they can’t afford to.

          The Swiss are not stupid, nor are the South Koreans of Japanese.

          Russian and China would kill to have the F-35.

          • “they don’t pick junk”

            Well, actually, they do — the USAF has even confirmed that for them:

            “Air Force chief of staff General Charles Q. Brown finally admitted what’s been obvious for years: The F-35 program has failed to achieve its goals. There is, at this point, little reason to believe it will ever succeed.”

            “To say the F-35 has failed to deliver on its goals would be an understatement. Its mission capable rate is 69 percent, below the 80 percent benchmark set by the military. 36 percent of the F-35 fleet is available for any required mission, well below the required 50 percent standard. Current and ongoing problems include faster than expected engine wear, transparency delamination of the cockpit, and unspecified problems with the F-35’s power module.”


          • -> “the F-35 is fully operational and combat tested”

            Wow. Which level of alternate reality do you come from??

            Combat tested? You mean in computer generated war game??

          • One small advantage of the F-35 is that it is a small stealth nuclear bomber (soon) and a huge step forward from the Harrier for Marine operations. So countries close to Russia/China having F-35’s gives assurances that they can sneak in and bomb without being shot at on the way in and of cause does Russia/China know that.

          • @Claes:

            Which of those countries are in possession of nuclear bombs??

          • @ Claes
            The whole concept of “stealth” is being re-evaluated in light of recent discoveries that “stealth” aircraft can be easily detected/tracked using simple, relatively unsophisticated passive radar techniques.

            Also, one can ask why one would send in a relatively slow F35 with a nuclear device when one can instead send in a much faster cruise missile to more efficiently/reliably achieve the same purpose.

            When provided with external weaponry, the F35 loses its “stealth”, at which point it is heavier, slower, less maneuverable and has a shorter range than other fighters that it might encounter.


          • Yea the assertion on stealth easily removed is bogus. But carry on.

            I assume the usual gang would be arguing if they got hung with the Sun Rising in the East each day.

            LOL. F-35 is flying, its won majority of the bids and it does work and does it well now. Finland is a good example of someone looking right down the Bears throat.

            The took on the Russians and beat them to a pulp.

            I will take a hard nosed military vs some back chair opinion far from the front lines.

          • And others will attach more weight to an analysis made by the USAF itself as opposed to a mechanic’s feelgood denialism 😏

    • Korean F-35 Bird Strike, you should always get facts before engaging keyborad.

      And how is that wondrous C919 doing? Vapor Ware, coming to a kiosk near you someday soon.

    • The 767-2C was a real airplane built from the contract winning RFP “paper airplane”. It it on the 767 TCDS.

      • Yes, it *eventually* turned into a real airplane…though, in practice, only in the form of the defect-ridden KC46. And it did this back in the days of self-cert — which may explain why the KC46 is (still) so defect-ridden.

  5. I wanted to commend the Leeham team for the excellent description about how the 767 tanker came to be. As one who worked in BCA aviation safety and dealing with the FAA, the way the 767-2C was programmed was a great idea. Boeing’s problem today is they can’t deliver a good product to the Air Force and frankly it comes down very poor leadership on both the BCA and BDS organizations as pointed out in other comments. Boeing will never fire these senior executives, they just move them around.
    Boeings newest solution is a Star Trek program called ‘meta verse’… oh yeah that will solve everything.
    However, the Navy’s P-8 program ( based on the 737-800) sort of functions the same way as the tanker, is a huge success and does a fantastic mission for the Navy and other foreign navies. We don’t hear of the issues with this platform as we do the tanker. So, credit to Boeing and the US Navy for cleared defined mission capability requirements up front.
    Lastly, I’m pulling for the Air Force to award the contract for the LMMRT, I think they will deliver a good product on time and be mission ready from the get go.

    • Thanks for your “insider”(?) input. However, why the kudos for the 767-2C vs. using the 767-300F as a baseline COTS a/c? Would you kindly elaborate? Lastly, I’m kinda routing for LMMRT, but not for the reason you are. I can almost guarantee AB and LM will completely muck it up, should by some miracle they would win—F35 and A400M, anyone? LOL

      • @MontanaOsprey

        Scott elaborates in the beginning of this article why Boeing took the path that they did for the tanker project. They simply had to have a starting point. Airbus is technically doing the same with using the A330 as the starting point. In theory this works great for Boeing, but in real life production & operation it’s fraught with so many problems. People have to remember the 767 tanker is not the KC135 tanker and so much more complex.
        For the LMMRTT, I truly believe Airbus leadership with override Lockheed Martins (and Boeing) issues and hence my basis for how the contract should be awarded.
        But ….. who am I to say 🤷‍♂️

  6. Scott and All:

    Outstanding run down of the process.

    Can you tell us why a 767-200 or 767-300 did not meet the requirements?

    The much larger A330MRT apparently did.

    • @TW: The KC-46A is based on the 767-200ER. In the Jim Albaugh series, we’ll talk about why Boeing offered the 767-200-based airplane and not the larger one.

      As for the A330 MRTT meeting the requirements, the USAF changed the requirements in the middle of the game and without telling Boeing )ie, the extra capacity). This was the basis of the Boeing protest, which the GAO upheld.

      • Scott:

        Thank you, still trying to keep in mind what the 2C is. Its a 200, with a 300 wing and a 787 type cockpit.

        As for Round 2. I would argue the USAF did not change the requirements. They and Airbus) changed their VIEW of what they wanted.

        To change the requirements requires a rewrite of the RFP and both side get to weigh in on that.

        While the process is to initially protest to the GAO, Boeing could take it to court for what the USAF did as illegal . While that is rare it has been done.

        Reality is that what the USAF did was illegal. You do not change contract terms in mid stream and not tell the other bidder(s). I did more than enough of those to know what the process is.

        What one company gets, no matter what how where or why, all companies in the bid are notified of that information.

        Follow up they made clear there was no bonus credit for what the USAF granted and wavered. Ergo, the spec never changed.

        If the requirements had been changed, in round 3 they would have been there and were not . Ergo, they did not change the requirement they made an illegal award based on big eyes.

        (we saw an example of bonus in the T-7A, none of the over capability was even close to overcome the Boeing price.

        By doing what it did the USAF shot itself and the taxpayer in the foot as we lost 1.5 billion on the deal (congress fault for not correcting that issue)

        • “…still trying to keep in mind what the 2C is. Its a 200, with a 300 wing and a 787 type cockpit.”

          In other words: it’s a “Frankenplane”.
          No wonder the KC46 is a mess, if it’s built on such a spurious foundation.

          • The -300 fuselage would have reduced the payload
            ( HIGHER OEW VS SAME MTOW)

          • frankenplane has always been disingenuous.

            the difference between a 200 & 300 fuselage is 2 plugs and the thickness of a few stringers and skin panels in the center fuselage section.

            the difference between the 200 & 300 wing is the thickness of a few spars in the center wing box and wing skins on the interior portion of the wing.

            structurally, it is like legos (almost like they planned it that way… oh, they did). the cockpit upgrade was more complex than the parts substitution in the airframe.

            what bit them in the ass was having to redo large portions of the wiring loom to meet USAF specs.

          • None of the KC46 issues I know of relate to structure. They all relate to subsystems or manufacturing:
            * boom dynamics
            * vision system
            * FOD
            * drains on the refuelling receptacles
            * an issue with the flight management systems
            * fuel leaks

            All issues that need to be addressed but but not really anything that stems from the fuselage length or wing size. Even the use of the 787 cockpit systems seems to be relatively trouble free. And certainly use of the 787 FBW systems will have made it much easier to tune flight characteristics than if they had stayed with the older 767 cockpit and flight controls.

          • (Cockpit) Instrumentation. NOT FBW!

            What “mini_fbw” they added was a another version of MCAS working off a synthetic AoA ( IMU, all that jazz ) apparently to cope with GoG changes during (off)load.

          • @ jbeeko
            The KC46 had more than 200 Cat II deficiencies, in addition to the ca. 12 Cat I issues. Have you gone through the full list?
            For example, two of the Cat I deficiences concerned the APU.

  7. I had some side familiarly with the C-172/T-41A (along with flying it).

    When people compared the weight limits between the two, it was found that the T-41A was 200-300 lbs higher than a C-172.

    Owners wanted that version (in a 4 pax aircraft it makes a lot of difference)

    Sorry buys, the military just took the gloves off on a safety factor, its identical, they just allowed higher loads as they deemed it safe.

    As to why the C-172 vs the C-150? Partly it was convenient (think KC-46A cargo) to have that two or 3 pax capability.

    The other was overload. A bit instructor and a big student and full gas overload a C-150/152.

    I saw it happen. A tight end for the Oakland Raiders was taking flying lessons. They of course assigned him the biggest instructor in the school.

    Ooops, we are going to have to drop to half tanks or use a C-172. The used a C-172 (somehow it did not occur to them to assigned the lightest instructor to that BIG Tight End (they were all blockers in those days, phew the guy was big)

    That said the C-172 had a lot better performance with two big bodies as you had the two non used seats and you could do the maneuvers decently instead of bogging around.

  8. Can you please explain WHY the Air Force wants aircraft to be a COTS product, and connect this to procurement law?

    Here is a little about COTS for your background.

    The Buy American Act (41 USC 8302) applies to DoD purchases of aircraft. It generally requires acquisition of domestic end products. §25.101 of the Federal Acquisition Regulation (FAR) lays out the test for what is a domestic end product: (1) the article must be manufactured in the US, and (2) (for anything other than iron & steel products) the cost of domestic components is over 55% of total component cost.

    In 2011, Congress passed a law (41 USC 1907) providing that “government-unique” procurement rules would not apply to COTS. Government-unique specifications include “milspecs” that DoD would draw up for major contracts — which were almost immediately obsolete, couldn’t interoperate with commercial equipment and resulted in incredibly expensive procurement ($3000 toilet seats). After 2011, the administrators of the FAR determined that the list of rules that would not apply to COTS would include the second part of the 2-part test for Buy American.

    What does COTS status mean commercially for Boeing’s production and sales of aircraft to DoD? I don’t know – but in your further reporting on this issue you should find this out.

    Does COTS status for an aircraft (or for a hypothetical fore-runner for an actual aircraft) change the application of ITAR? No, because ITAR covers all production in the US (and much production outside the US). It must be something else.

    Does this COTS status give Boeing more flexibility in where it procures OEM parts, spare parts or sub-assemblies for the aircraft it sells to DoD? Why is DoD specifying that it wants to procure a COTS aircraft?

    • VirginaiBird:

      I can read what they are saying but as Leeham noted, they changed so much as to make it bizarrely irrelevant.

      Usuu7all USAF Stupidity the same as the illegal contract award? F-35 and concurrent production.

      Boeing did get pain 4.5 billion initially for that (above and beyond the price fo the individual aircart).

      Like we have seen with the A400, Tiger and NH-90, how messed up programs can get. No one is immune. USAF should know better (does know better and does the stupid stuff again and again).

      • @MR. Transworld:

        I really don’t understand why you keep harping on about the A400M, Tiger Attack Helicopter and the multirole NH-90 helicopter. Sure they, like all military aircraft field by all nations in the past 50 years, have had in service issues. But please note the following

        1. All these machines have had less than 20 years operation life since being inducted into service – they are all post 2000 in service products
        2. the A400M in it’s current form is meeting all its required and promised performance specifications, that why the RAF and other air arms are starting to discard their trusted c-130J models
        3. The Tiger attack helicopter in French Army operations seems to be working well. I can testify that I have seen them in action in Mali (Sahara desert conditions) in the past 4 years.
        4. The NH-90 helicopter seems to work well for most of the dozen countries who bought them. Australia and Belgium seem to be the most dissatisfied customers. All the others have or are working through the teething problems of introducing a complex system such as this helicopter. Note that the competing USA produced Blackhawk has had almost 50 years of upgrades and troubleshooting to make it the reliable machine it is today. The first NH90 was accepted into operational service around 2007 and like the f35 the spare parts availability issue appears to be the primary problem with the helicopter.

        I suggest you move on from this constant harping on about these European products. Most of the customers using them are happy with their equipment. Sure the USA is not going to buy them because we have competing products made by USA companies. That is fine. Let’s stay on topic here because we have an interesting subject matter on why the KC46A is designed / built / configured the way it is. I would rather you focused on enlightening me and those in the forum, with technical information, on why the competing A330-MRTT is inferior as a product for the KC-Y competition

        • “I really don’t understand why you keep harping on about the A400M, Tiger Attack Helicopter and the multirole NH-90 helicopter…”

          It appears to be some sort of (misplaced) “default patriotism”: as if knocking the competition somehow makes him feel better about the fact that the home team is doing so miserably.
          Underlying it is a 1950s-era dogma that “if it’s not American, it can’t be any good”. That then usually morphs into a generalized anti-EU rant, with all sorts of irrelevant topics thrown in.

          Difficult to accept that, even though the European programs to which he continually refers have had their share of problems, they’re now up and running to the general satisfaction of their users. That’s something that can’t be said — after a decade — about the KC46 (and other brethren debacles).

    • COTS is a way to avoid all the start-up costs a new aircraft program would involve. You are not forced to design an aircraft from scratch. You avoid the bulk of the hard stuff. Piggybacking on a commercially proven aircraft reuses the vast bulk of design and certification data, all the process specifications, all the qualified products such as sealants, paints, corrosion inhibitors, hydraulic fluids. You avoid remaking mountains of “stuff” and get a multi-billion dollar head start while compressing the time to service entry by many years.

      There is naturally confusion when you ask questions like “can you build a tanker from a -300F.” The big answer is yes, because that airplane engineering dataset has all the makings for a good tanker. The question “why don’t we use the 300F as the jumping off airplane instead of a 767-2C-type airplane is simple.

      The baseline -300F isn’t close enough to make a good conversion candidate. It has no tanks and it’s wiring isn’t explosion proof. Those two items alone are difficult to change after you have a flying -300F in your hands that making the paper plane is a lot easier to do to get to the end product.

      As far as ITAR, the cost of ITAR shrinks in a COTS program because those items that are unchanged and were lifted directly from commercially used preexisting engineering are exempt. An example would be that there are no ITAR concerns with the tanker rudder pedals, the windshields, and a huge number of other parts lifted directly from the already flying commercial airplanes.

      • @ Scott
        Why, then, was AB able to use the A330-200 as a basis for the MRTT? It also has the shortcomings which you cite (e.g. no tanks, wiring not explosion-proof).

        • The A330-200 has the _integral_ CenterWingBox tank inherited from the A340 initially.Outside the pressure vessel and certified as tankage in the COTS article.

  9. Great summary Scott, and thanks! I am looking forward to part 2, since I have been wondering since the original competition why Boeing submitted a ‘frankentanker’ instead of the 767-300ERF as the base model. I am also curious as to how/why the USAF accepted the 767-2c as the base (COTS) airplane, instead of an already in-production aircraft.

    • It is the existing 767F as the base plane , same as the P-8 is 737-8 but has 737-9 wings as it’s base plane
      The 767F is a bit shorter.
      Look at the new A350F it’s something in between A350K and the A350-900

      • Perhaps you should go back and read Scott’s article above. The plane that was offered by Boeing to the USAF in the 1st contest was nothing more than a ‘paper airplane.’ It was not an in-production model, and certainly was not the very successful 767-300ERF that FedEx and UPS are flying dozens of today.

        • That’s just a figure of speech – paper plane. In practice it’s a full digital design which is the way it’s done now, but since it’s not a new plane its using the 767 , which of course was designed and built in the blue print age so is mostly new digital design . I understand Boeing underestimated the work to create this full digital design in CAD.
          Of course it’s essentially still the 767F freighter, same process happened for the P-8 which definitely was the 737-800 underneath

  10. The shorter aircraft got a better take-off performance and less structural weight.

    Boeing did built some KC-767 for Italy and Japan based on 767-200.

    The problem for KC-X was Boeing had no flying tanker at time somehow related to basic specs in RFP e.g.: boom flow rateand vision systems.

    Therefore USAF rated Boeing’s development risk to be higher than NG/Airbus. KC-30 for RAAF was already flying.

      • But the wings and horizontal tail came from 767-300ER and with other features because of the MTOW is 415,000lb which is slightly higher than the 767F at 412,000lb. The 767-200ER is around 20,000lb less.
        Sure the 767-200ER was the max range king but the 10 tonnes extra MTOW pointed to the structure along with side cargo doors, the highest thrust engines being a shortened B767-300ERF ( 767F) the baseline design.

        • I would call a fuselage with length of a 767-200 as such. There are possible changes for the higher MTOW but if it looks like a duck and quack like one…

          • That would be a hard target to compare to / and comment on.

            “767-2C” is much more diffuse. Stealthier 🙂

          • Its longer fuselage than the -200.
            Thats why they call it the -2C

            Airbus did the same for its A350F – which is longer than -900 but shorter than -1000, you take the HGW version and shorten it. No need to bulk up a shorter fuselage version for much higher weights and then lengthen it as well.

          • Ist it longer? I don’t think so.
            length markup is the boom sticking
            out the back IMU.

          • I recall seeing a graphic which showed an frame or 2 extra behind cockpit.
            Can’t find any reference to 2C version in Boeing’s airport planning guide to all 767 versions which usually gives actual fuselage and wing diensions

  11. My copy of Mr. Hamilton’s fine book ‘Air Wars’ arrived yesterday. Thank you for writing a
    very solid book; I recommend it.

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