As I read it, the JROC is required to have performed an Operational Requirements Analysis of the programme.
See here. As the IOC for the models is
TBD this cannot be concluded, so a waiver is in place.
As an example, from the first diagram in the link above, one requirement is the analysis, relating to the USD(AT&L) referenced is......
"In consultation with the CCMDs and USD(ATL):
Establishing an objective for an overall period of time within which an operational capability should be delivered to meet each joint military commitment"