Spectrum Supportability Risk Assessments – Critical to Milestone Approval!

The Problem —

Early consideration of spectrum supportability in spectrum dependent (S-D) system acquisitions is a fundamental criterion that must be satisfied before the DoD develops and fields communications-electronics (CE) equipment and related weapons systems. Development or acquisition of systems that meet operational requirements, but fail to obtain spectrum supportability, means those systems will not be allowed to operate in the United States or in host nations. These systems create a potential for severe mutual interference between themselves and other spectrum users, squander resources, and delay fielding warfighting capabilities to field units.

“Spectrum Supportability” is defined as the assessment as to whether the electromagnetic spectrum necessary to support equipment is available for use by the system. The assessment requires, at a minimum, receipt of equipment spectrum certification, reasonable assurance of the availability of sufficient frequencies for operation from host nations, and a consideration of ElectroMagnetic Compatibility (EMC). Guidance for these requirements are found in DoDI 4650.01.

The Department of Defense has complementary policy instructions that provide additional assurance that spectrum supportability can be achieved. The interrelationship between Spectrum Supportability and E3 is depicted in the figure below. The primary overlap occurs during the mutual concern for achieving Electromagnetic Compatibility (EMC) and preventing EMI for S-D systems and equipment.

It’s important to understand the critical nature of spectrum supportability and why DoD procurement offices must include this in any system planning involving radio frequency (RF) transmission, reception, or control.

The other challenge we face, and another reason why it is so important to manage this resource is because we are constantly faced with competing users of our spectrum that want us to give up the spectrum we are using. Commercial factors, increased spectrum use by the military and even such things as directed energy weapons and GPS jamming contribute to an increasing pressure on military use of the EM spectrum. Nearly every operational capability and mission requirement demands spectrum use for collecting and distributing information of all kinds, in systems such as ISR assets and platforms and used in all domains – space, air, ground, maritime and even cyberspace. Countless billions of dollars have been invested in those capabilities. Likewise, billions of dollars have been invested in capabilities that use information, i.e. warfighting platforms across all those same domains. The electromagnetic spectrum provides the pipeline that affords mobility to that information is being squeezed and squeezed hard. The net result is an increasing restriction on the expected and planned for free flow of information through this pipeline down to a trickle, due to relative pennies on the dollar having been invested in protecting this EMS “maneuver space.”

- Adversary factors listed represent technologies and methodologies that our enemies are developing, producing and using to deny us access to our information

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Getting the experts involved early will save you money, time, and aggravation in the end.

Friendly factors include limited electronic protection efforts, inadequate interoperability and cooperation, training restrictions in a denied EM environment, and increasing spectrum demands that are limiting available bandwidth

Spectrum access is fundamental to all DoD missions. On-demand access to the spectrum and electromagnetically compatible operations in the EM environment cannot be assumed. The first step is to realize that you need to plan and engineer this into your system or capability. Then you must make sure you have the resources on hand to deal with this. In the end, getting the experts involved early will save you money, time, and aggravation. There are many examples of how the failure to properly address spectrum supportability during the design, test and production processes have caused program impacts in the areas of schedules, missed Milestones, significant financial issues, and/or a system that was produced with significant operational constraints on its use.

In the acquisition process, spectrum management usually begins with equipment spectrum certification, a process whereby a system is approved to operate in a particular spectral band. To actually operate the system, spectrum certification must be followed by obtaining a frequency assignment. Obtaining frequencies to operate equipment in the U.S. is a two-step process which is managed by the submittal of a properly filled out DD Form 1494. The first step is Equipment Spectrum Certification. The certification process assesses equipment transmit and receive characteristics to determine if it complies with existing RF spectrum regulations. The second step, Frequency Assignment, coordinates operational use of specific frequencies within specific bands among current users so that they do not interfere with each other. The Manual of Regulations and Procedures for Radio Frequency Management, issued by NTIA, is the standard for both steps. The NTIA is the regulatory authority over all federal equipment and spectrum in the US&P. The Federal Communications Commission (FCC) regulates non-federal spectrum in the US&P.

The DD Form 1494, a document that captures an exhaustive variety of technical data, serves two functions:

(1) Provides a uniform method to capture the basic spectrum-dependent and operational parameters of military spectrum-dependent systems in a format that can be easily provided to US National and host nation spectrum authorities

(2) Standardizes the format of the technical data required to be inserted into DoD and national databases to generate frequency assignment approvals enabling initial EMC analyses, and checks for compliance to military, US national, and host nation spectrum standards. System developers will complete and obtain approval for a DD Form 1494 during each phase of the acquisition process for each newly developed spectrum-dependent system.

Were that it was that simple!

In addition to the Frequency Allocation and Frequency Assignment processes, DoDI 4650.01 now requires the conduct of a Spectrum Supportability Risk Assessment for the procurement of all spectrum dependent systems, including COTS. SSRAs will be required of programs at milestone reviews A, B and C as part of the overall balance of program success against future risks. A PM’s failure to obtain spectrum supportability for components in its systems has direct consequences to the program in meeting performance, schedule and cost objectives established by its Acquisition Review Board and to the Combatant Commander in meeting Joint Mission Area requirements.

The Risk Management Guide (RMG) for DOD Acquisition defines Risk as a measure of the potential inability to achieve overall program objectives within defined cost, schedule, and performance/technical constraints and has two components: (1) the probability/likelihood of failing to achieve a particular outcome, and (2) the consequences/impacts of failing to achieve that outcome.

So just what is an SSRA?

It is an evaluation performed by DoD Components of all S-D systems to identify and assess EM spectrum and Electromagnetic Environmental Effect (E3) issues that can affect the required operational performance of the overall system based on the mission needs defined by the combat developer and/or Joint Staff in the ICD, CDD, and CPD.

The purpose of the spectrum supportability risk assessment is to identify and assess regulatory, technical, and operational spectrum issues with the potential to affect the required operational performance of the candidate system. For example, in addition to determining that a system’s bandwidth requirement complies with an individual nation’s frequency allocation scheme, a new or modified system must also be evaluated with respect to:

· The system’s potential to cause interference to or suffer from other military and civilian RF systems currently in use or planned for operational environments.

· The effect of the system’s proposed spectrum use on the ability of the extant force structure to access the RF spectrum without interference.

· How the system’s spectrum use conforms to the tables of frequency allocation of intended host nations, ensuring regulatory protection from other national co-band spectrum users.

· If individual host-nation frequency allocations include enough bandwidth to fully support the system’s operational mission, for example, required data rate.

A Spectrum Supportability Risk Assessment provides a formally documented SS risk assessment, with mitigation measure(s) identified, to achieve a SS Determination from the FMO, CIO, or OSD(NII) (depending on ACAT and/or level of Interest)

An SSRA should include the following components:

· Regulatory component: Addressing the compliance of the RF system with US national and international tables of frequency allocation as well as with regulatory agreements reached at the International Telecommunication Union.

· Technical component: Quantifying the mutual interactions between a candidate system and other co-band, adjacent band, and harmonically related RF systems, including the identification of suggested methods to mitigate the effects of possible mutual interference.

· Operational component: Identifying and quantifying the mutual interactions among the candidate system and other US military RF systems in the operational environment and identifying suggested methods to mitigate for possible instances of interference.

SSRAs are produced in several stages including Initial, Detailed, and Updated SSRAs

• Each has a regulatory, technical, and operational element

• Detail and scope of each depends on:

• the system’s entry point into the DAS,

• its complexity,

• the intended operational environment, and

• the maturity of its design.

When conducting an SSRA, operational restrictions, availability of frequencies, host nation approval (HNA), and known incidents of electromagnetic interference (EMI) must be considered. S-D systems and equipment cannot be operated legally until they have been granted equipment spectrum certification (ESC) by National and DoD authorities; in addition, a frequency assignment must be obtained from the appropriate area frequency manager. For systems that will operate outside the United States & Possessions, an HNA also is requested prior to operation in each foreign country designated for use.

Additionally, the program must be monitored to determine the EMC and EMI impact of any changes to such operational RF parameters such as tuning range, emission characteristics, antenna gain and height, bandwidth, or output power, etc. Changes to these parameters may require additional E3 analyses or tests. The E3 Assessment should:

· Identify and resolve co-site EMI issues during system acceptance testing.

· Demonstrate repeatable EMC utilizing appropriate development models.

· Maintain system E3 design integrity during operations.

· Implement procedures for EMI problem reporting.

The SSRA will include details of the following, for each piece of S-D system:

– Status of approved 1494s (or J/F 12’s )

– Status of Host Nation Coordination via the COCOMs

– Provide/discuss known SS and E3 issues and assigns RISK

– Discuss potential operational impact of known SS and E3 deficiencies

– Provide program risk (R/Y/G) for each system, a risk summary, and mitigation plans to reduce or eliminate YELLOW and RED issues

– Provide an overall, Program assessment for upcoming acquisition Milestones

• Minimum E3 requirements:

• Determine the potential for EMC and EMI interactions between the proposed system and other systems, and with the anticipated operational EME.

• Include an EMV analysis to determine the possible effect on operational performance as a result of any EM interaction.

Available expertise and the existence of service E3/SS related organizations notwithstanding, it is widely known in the DoD Spectrum Management community that program offices, for a variety of reasons, including a lack of understanding of the requirements and their importance, frequently avoid spectrum supportability considerations early in program or take them on belatedly at the expense of cost, schedule and operational capability. The General Accounting Office has documented a variety of issues related to the implementation of spectrum management issues in DoD acquisition systems over the years. See the table in Appendix A.

So what are the obstacles that keep program offices and acquisition personnel from complying with federal laws and DoD directives on RF spectrum use and instituting good engineering practices on control of electromagnetic environmental effects (E3)? Volumes have been written on the need to comply with the spectrum regulations but the list of infractions continues as does the list of radio interference issues, both during acquisition and operationally. Current requirements and methods for assuring that systems have spectrum access and electromagnetic compatibility are scattered among a variety of DoD Directives, Instructions, MIL-STDs and Handbooks; and they can be poorly defined with approval processes that are hard to understand, slow, subjective and inconsistent. These volumes of requirements documents, which currently define the processes for obtaining spectrum access, acquiring authorized frequencies and controlling E3, have created complexities that can inhibit successful implementation by program managers. Some of the requirements are technically daunting on the surface, yet technical experts are available within every military department to help as necessary.

The Basic Solution

· The good news is that there’s lots of guidance

· The bad news is that there’s lots of guidance

In addition to documenting the requirement for SSRAs, DoDI 4650.01 also provides a great deal of guidance, in the form of suggested tasks, for the program offices to follow (see Appendix B). Unfortunately, it doesn’t provide a specific approach to integrating the tasks into an overall SSRA product. Subject matter experts from the three services are in the process of developing more detailed guidance and well as acceptable document format and content guidance. Some current suggested guidance for Program Offices, Acquisition Managers, and system developers to follow include:

(1) Determine the spectrum required to support the mission and define the intended EME in which the system will operate.

(2) Ensure E3 control and SS requirements are addressed in JCIDS and defense acquisition system documentation.

(3) Apply interface standards such as MIL-STD-461 and MIL-STD-464 to ensure that the system and its subsystems and equipment are built to operate compatibly in the mission EME.

(4) Define E3/SS test objectives in the Test and Evaluation Master Plan (TEMP) and allocate sufficient resources to conduct test objectives.

(5) Verify and document SS and E3 control issues during developmental and operational test and evaluation.

(6) Conduct early E3 and SS operational assessments that consider the intended mission including single Service, Joint, and international deployments.

(7) Provide E3 assessments during operational test readiness reviews. Report the operational impact, system limitations, and vulnerabilities from unresolved E3 and SS problems.

Ideally, an initial spectrum supportability assessment is generated in the first phase of the DoD acquisition process. Early identification of major regulatory and technical issues allows program management personnel to focus attention and resources on critical spectrum issues in the remaining acquisition phases. The SSRA’s author uses inputs from several sources:

· Technical and regulatory information is obtained from DoD data bases, specifically the:

System Certification System (SCS) data base is used to generate lists of co-band and adjacent band DoD emitters, providing an overview of other systems sharing expected electromagnetic environments.
Host Nation Spectrum Worldwide Database Online (HNSWDO) data base is used to identify host nation comments on previous systems in the same frequency band and with similar technical parameters as the system being acquired.
US and non-US tables of allocation, which can be obtained in many cases directly from the internet.

· The latest pertinent Host Nation supportability comments are obtained by the Program Office from the Combatant Command (COCOM) spectrum managers. The COCOM spectrum managers will forward any resulting comments to the authors of the SSRA.

· The PMO defines the system’s technical parameters and intended operational deployment required for spectrum support, e.g. the frequency bands of interest and the intended worldwide development, test and operational areas and host nations.

Coordination with the cognizant MILDEP FMO is a fundamental key to a successful SSRA. The MILDEP FMO should be made aware of initial activities and be kept informed of major SSA developments. The PMO should provide the SSRA’s authors with copies of any DD Form 1494s sent to the MILDEP FMO. The national and host-nation comments resulting from previous J/F 12’s submissions should be reviewed to see what comments may have been provided on earlier versions of the system.

The results from the regulatory portion of an SSA can be summarized for senior leadership as a “stoplight chart” where the colors of each box are an indication of the possibility of a system obtaining spectrum supportability in the US and selected host nations. In the example below, reading the rows indicates that the frequency band used by at least four of the program’s sub-systems will have major spectrum issues in many of the intended host nations. Looking at the columns indicates the possibility of obtaining spectrum support for specific systems in specific host nations.

Program

Combatant Commands

NORTHCOM

EUCOM/AFRICOM

PACOM

CENTCOM

SOUTHCOM

RF Sub-system

Frequency (MHz)

Radio Service

MEX

CAN

GER

Slovak

S A

Japan

Korea

Austr.

Iraq

UAE

AFG

VEN

COL

Brazil

1350 - 1390

Mobile

1755 - 1850

Mobile

2400-2483.5

Mobile

4400 - 4990

Mobile

5470 - 5725

Mobile

= Little chance of host-nation approval, or approval with many operational and regulatory restrictions

= Operation allowed only with geographic, frequency, and/or operational restrictions

= Good chance of host-nation approval with few operational and regulatory restrictions

1. Adopted the GSM-1800 personal communications standard

The colors result from a careful comparison of the radio service of each RF system with the technical and regulatory information contained in the databases and the host-nation tables of allocation.

Likewise, the results of the Technical and Operational analyses previously discussed, will constitute additional input into an overall risk assessment. The technical component would focus on the RF engineering related risks associated with possible mutual interference with other systems in the same band and the operational would focus on the risks of possible mutual interference within its intended operational environment.

The major result of the SSRA may be that the PMO considers options such as: changing the system’s spectrum use or other technical parameters or beginning consultations with the cognizant FMO regarding possible courses of action. Typical courses of action include coordinating bi-lateral negotiations with individual host-nations or briefing the spectrum requirements of the system to spectrum for a such as the NATO Frequency Management Sub-Committee (FMSC), the DoD spectrum Summit or various COCOM spectrum conferences. All PMO involvement with these groups must be closely coordinated with the cognizant MILDEP frequency management office and DoD representative.

Now What?

Hopefully, you realize that Spectrum Supportability is not something that can be assumed; spectrum demand is increasing and available spectrum is decreasing. The requirement to perform and submit SSRAs is part of the DoD effort to ensure that we don’t continue to field systems with spectrum and/or interference problems. From the list of suggested tasks noted in DoDI 4650.01, you will also realize that producing a meaningful SSRA is a significant engineering undertaking, not a task for the faint of heart. An understanding of the entire gamut of required information, the sources and availability of that information and the technical ability to collate, analyze and present the data, requires a specialized expertise and particular experience. And as a relatively new requirement, knowledgeable, experienced help in producing and reviewing SSRAs can be hard to find. EMC Management Concepts’ staff have extensive experience in DoD spectrum and E3 requirements, we have experience analyzing potential interference and RF interactions during program lifecycles and we can help YOUR program minimize spectrum supportability risks.

You must – MUST – apply due diligence to Spectrum Supportability considerations

– It is a critical tenet for program success

– It requires application of resources and knowledgeable people

– You should apply Spectrum Supportability resources early and “Up-Front” in a program life cycle

– It will save you potentially BIG $’s in the end

Contact EMC Management Concepts to discuss your SSRA requirements:

Brian Farmer, President

bfarmer@emcmanagement.com

703-864-7023

Appendix A

Report	Title & End Note	Relevance
NSIAD-87-42, 09 February 1987	Radio Frequencies: Earlier Coordination Could Improve System Use and Save Costs [i]	Found that delays and unnecessary costs resulted when DOD did not coordinate with host nations early in the development of communication systems
GAO-01-604, 09 May 2001	DEFENSE SPECTRUM MANAGEMENT New Procedures Could Help Reduce Interference Problems[ii]	Reported that the new procedures established by DOD are reasonable and, if successfully implemented, could help prevent problems related to radio frequency interference.
GAO-03-617R, 30 April 2003	Spectrum Management in Defense Acquisitions [iii]	Reported that DOD’s weapons programs have often failed to obtain, consider, or act upon adequate spectrum supportability knowledge during the early stages of acquisition. This is essentially the same finding as the NSIAD-87-42 report.
GAO-04-530T, March 17, 2004	Unmanned Aerial Vehicles: Major management Issues Facing DOD's Development and Fielding Efforts [iv]	Exemplifies the issue of lack of spectrum supportability considerations before acquisition of systems.
GAO-04-248, March 31, 2004	Assessments of Major Weapon Programs [v]	Warns that technical challenges that could affect the program include spectrum certification but is mute on the broader requirement for spectrum supportability determination.
GAO-04-858, July 28, 2004	DEFENSE ACQUISITIONS The Global Information Grid and Challenges Facing Its Implementation [vi]	Warns that previous efforts that have been undertaken in past years to foster interoperability among DOD systems have had limited success. That DOD had not yet overcome resistance from the military services, it lacked architecture to guide interoperability efforts and some current oversight and control mechanisms, such as the interoperability certification process, were not working or were not being enforced. (Spectrum supportability is a consideration within the Information Support Plan that is part of the interoperability certification process.[1])
GAO-05-519T, April 6, 2005	DEFENSE ACQUISITIONS Assessments of Selected Major Weapon Programs [vii],[viii]	Reports: 1. B2B radar required major design modification to resolve potential interference issues.. 2. TSAT program must resolve communication-on-the-move nulling antenna, dynamic bandwidth and resource allocation technologies however protected bandwidth efficient modulation waveforms, information assurance communications—are scheduled to reach maturity in early 2006, about 2 years after the start of system development (MS B).
GAO-05-669, 15 June 2005	Resolving Development Risks in the Army's Networked Communications Capabilities Is Key to Fielding Future Force [ix]	Cluster 5 program officials had expected to leverage technology from the Cluster 1 program. However, the Cluster 1 technologies have not matured as anticipated. The unique technological challenge of its wideband radio frequency capabilities up to 2500 MHz, introduce thermal management and packaging, and complex security architecture risks for which backup technology is to be identified as a part of a risk mitigation plan. Therefore, spectrum supportability assessments should have considered all alternatives. Presently cluster 5 submission of a request the Equipment Spectrum (allocation) Certification has not been completed so substantiated spectrum supportability determinations have not been made.

Appendix B

DoDI 4650.01 Suggested SSRA Tasks