Findings And Recommendations Of The Study On

“Early Consideration of Spectrum Supportability in Spectrum Dependent System Acquisitions”


Defense Information Systems Agency (DISA)

Defense Spectrum Office (DSO)

POC Renae Carter

2461 Eisenhower Avenue

Suite 1200, Alexandria, VA 22331

27 September 2005

Table of Contents

ABSTRACT

1. INTRODUCTION

2. SCOPE OF THIS REPORT.

3. FINDINGS ON THE CURRENT PROBLEM

4. BASIC DOD ACQUISITION SYSTEM (DAS) PROCESS AND BOUNDARIES

5. RESEARCH AND FINDINGS ON INTEGRATION OF SPECTRUM SUPPORTABILITY IN CONTRACTING

5.1 INTEGRATION OF SPECTRUM SUPPORTABILITY IN PART I OF A CONTRACT.

5.2 INTEGRATION OF SPECTRUM SUPPORTABILITY IN PART II OF A CONTRACT.

5.3 INTEGRATION OF SPECTRUM SUPPORTABILITY IN PART III OF A CONTRACT.

5.4 SPECTRUM SUPPORTABILITY INTEGRATION IN PART IV OF A CONTRACT.

6. RESEARCH AND FINDINGS ON INTEGRATION OF SPECTRUM SUPPORTABILITY IN SYSTEMS ENGINEERING

7. SUMMARY OF FINDINGS

8. RECOMMENDATIONS

9. POST SCRIPT

List of Tables

Table 1. GAO Reports Related to DoD SM Management Issues......

Table 2. Uniform Contract Format......

Table 3. Six-page Format of a DD 1494

List of Figures

Figure 1. Flow of US Law Into DoD Regulations......

Figure 2. Defense Acquisition System Process......

Figure 3. Contracting in the Acquisition Process......

Figure 4. Systems Engineering in the Acquisition Process

Figure 5. Risk Management Structure......

Figure 6. Risk Analysis Process......

List of Enclosures
Enclosure (1) / References / 24
Enclosure (2) / Current Data Item Descriptions / 26
Enclosure (3) / Systems Engineering Technical Review Descriptions / 32
Enclosure (4) / MIL-HDBK-881 Change Data / 35
Enclosure (5) / EXAMPLE SPECTRUM SUPPORTABILITY DID / 36
Enclosure (6) / FAR/DFAR Change Proposal / 46
Enclosure (7) / Related Data On Methods To Establish Spectrum Supportability Risk Assessments In ACAT Programs / 49
Enclosure (8) / End Notes / 51

1

Abstract

This is a report on the findings and recommendations of the study on early considerations of spectrum supportability in spectrum dependent acquisitions. In short, “spectrum supportability” is defined as the assessment as to whether the electromagnetic spectrum necessary to support equipment is available. 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). This report is also referred to as the Integration of Spectrum Supportability in the Acquisition Process (ISSAP) study report.

This report provides an updated listed of spectrum supportability issues identified by GAO reviews. The report asserts that changes to the DOD 5000 series of instructions will not assure that all DOD acquisitions comply with US law related to radio frequency management. The report found that:

  1. That current issuances have engendered a spectrum management process that is cumbersome and lacks clarity.
  2. That Spectrum Supportability assessment methods need to be clearly defined and more automated.
  3. That the three minimal criteria for spectrum supportability should be integrated into the DAS process.
  4. That a common link between all types of acquisitions supporting the DAS, S&T, R&D, and OS communities is contracting which is controlled by the FAR and DFARS.
  5. That only three DIDs exist that relate to Spectrum Supportability, but none support spectrum supportability determinations as a whole and all lack assessment of frequency availability.
  6. That only the DFARS has a clause that relates to Spectrum Supportability, but it confuses the process of equipment frequency certification (frequency allocation) with frequency assignment.
  7. That RFP representations and preparation instructions can contain information related to spectrum supportability documentation.
  8. That, in the DAS model, System Engineering Reviews are the ideal venue for PMs to consider spectrum supportability as an element of design.
  9. That the DAS uses risk management as a techniques to achieve ACAT program overall objectives within defined cost, schedule and performance constraints.
  10. That the risk assessment aspect of risk management relies on the Program WBS
  11. That risk analysis is the part of risk assessment that applies technical and systematic processes to exam risks and their impacts in terms of probability and consequence.
  12. That development of a spectrum supportability WBS element would affect: Program Management, Contract Reporting, Financial Reporting, Systems Engineering, Risk Management
  13. That development of spectrum supportability Data Item Descriptions would standardize products in standard contracting process.
  14. That development of appropriate mandatory spectrum supportability FAR and DFARS clauses would improve the probability for DoD compliance with US law on spectrum management.
  15. That development of standard spectrum supportability determination risk management guidelines and relations ships to program cost, performance and schedule risks would aid PMs and MDAs.

The report recommends that the following integration points found in this study should be improved as follows:

  1. Correct DFARS 252.235-7003 ALTERNATE I wording to read “Equipment Frequency Allocation” vice “Frequency Authorization”
  2. Submit a change proposal to MIL-HDBK-881 that identifies spectrum supportability as common WBS element. (See draft example in enclosure (4))
  3. Submit proposals to establish standard spectrum supportability Data Item Descriptions (DIDs) in ASSIST (See draft example in enclosure (5))
  4. Submit a proposal to establish a mandatory FAR clause for spectrum supportability. (See draft example in enclosure (6))
  5. Develop and submit a spectrum supportability assessment guide to be incorporated into the Risk Management Guide For DoD Acquisition. (Related data see enclosure (7))

1

1. Introduction

Early consideration of spectrum supportability in spectrum dependent system acquisitions needs to be a fundamental criterion that must be satisfied before the government makes a decision to award a contract. In short, “spectrum supportability” is defined as the assessment as to whether the electromagnetic spectrum (most likely radio frequency) necessary to support equipment is available. 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). It is currently DoD policy to formally document spectrum supportability prior to the decision to move formal Acquisition Category (ACAT) programs from the Technology Development Phase to the System Development and Demonstration Phase (commonly referred to as the Milestone B decision). However it is widely known in the DoD Spectrum Management community that spectrum supportability considerations are frequently avoided and often belatedly accomplished.

All US citizens including: Program Managers, Spectrum Managers and Operating Forces are required by national and, furthermore, international law to transmit in the radio spectrum band on authorized frequencies only. What are the obstacles that continue to impede the Defense Acquisition System in complying with federal law on radios? Volumes have been written on the need to comply with the law but the list of infractions is continuous as well as the list of radio interference issues. It is self evident that alternative methods are needed to assure that DoD acquisitions follow the law and those acquisitions are able to access the radio frequency spectrum on demand. Current methods for assuring that systems have spectrum access are poorly defined, too slow, subjective and inconsistent. The volumes of directives, which currently define the processes for acquiring authorized frequencies, have created complexities that inhibit successful implementation by program managers.

This study identifies a number of options that have the potential of simplifying the process for assuring access to radio frequencies by establishing an open, less complex, and objective set of procedures which relate to both the Defense Acquisition System (DAS) and the “virtual” defense spectrum management system. These procedures begin with an examination of the steps DoD follows today in acquiring systems; defines step by step processes that integrate management and use of the electromagnetic spectrum (MUES) with DAS systems; and open the door to automated reporting of operational use and dynamic management of the electromagnetic spectrum. Cost to implement these changes begins with the dedication and time of current spectrum management experts to understand and act upon the recommendations of this report.

The report begins with a brief review of the DoD acquisition system followed by an assessment of how spectrum supportability might be imbedded within DoD contracts. Next, the report investigates the merits of incorporating spectrum supportability considerations within the systems engineering process defined by the DAS. Finally, a summary of findings and a list of recommended changes and examples are compiled.

2. Scope Of This Report.

This report is written to reach both the DoD Acquisition and DoD Spectrum Management communities. Basic concepts related each community are briefly reviewed to frame the findings and recommendation of this report. Not all spectrum management procedures that could be integrated into the DAS are defined in this study. Rather this study explores the Integration of Spectrum Supportability in the Acquisition Process (ISSAP) by examining the virtues of including spectrum considerations in contracting and systems engineering aspects of the DAS. Toward this end, a review of contracting and systems engineering documentation listed in enclosure (1) has been completed.

3. Findings On The Current Problem

The GAO-03-0617 report reflects much of the justification for this study, “that DOD’s weapons programs have often failed to obtain, consider, or act upon adequate spectrum supportability knowledge during the early stages of acquisition.” While DoD revisions of defense acquisition directives have attempted to simplify acquisition guidance and expedite future acquisition programs, they have not supported or improved on DoD compliance with the spectrum management regulations, established by the National Telecommunications and Information Administration (NTIA), which ultimately govern frequency assignment. Table 1 identifies a historical and more current list of GAO reports related to DoD Spectrum Management (SM) issues.

Table 1. GAO Reports Related to DoD SM Management Issues

Report / Title & End Note / Relevance
NSIAD-87-42, 09 February 1987 / Radio Frequencies: Earlier Coordination Could Improve System Use and Save Costs[a] / 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[b] / 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 [c] / 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[d] / Exemplifies the issue of lack of spectrum supportability considerations before acquisition of systems.
GAO-04-248, March 31, 2004 / Assessments of Major Weapon Programs [e] / 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[f] / 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[g],[h] / 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 [i] / 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.

The DoD spectrum management community has written volumes of guidance for a Program Manager (PM) to follow. For instance, the most complete compendium of related references, MIL-HDBK-237D, “Electromagnetic Environmental Effects and Spectrum Supportability Guidance for the Acquisition Process.” lists nine pages of references (almost 200 citations). [2] Arguably, such a large volume of information might overwhelm a Program Manager. Simpler, more direct, more automatic methods to comply with spectrum management regulations are needed. The basic requirement in both US and International law is that all RF spectrum dependent equipment has to transmit or receive [3]on approved frequencies [38][32]. Figure 1 depicts the flow of US Law to first tier DoD issuances on the Defense Acquisition System (DAS) and the Management and Use of the Electromagnetic Spectrum (MUES). The figure also highlights the missing links between the contracting regulations and DAS/MUES issuances.

Figure 1. Flow of US Law Into DoD Regulations

PMs are asked to comply with a number of spectrum management processes that are not directly related to the acquisition process. Spectrum management processes required by DoD D 4650.1 require a PM to develop a spectrum supportability determination based on equipment spectrum (allocation) certification, availability of frequencies and EMC while the acquisition process only requires a PM to obtain an equipment spectrum (allocation) certification. Obtaining frequencies for new equipment in the U.S. is a two-step process. The first step is Equipment Frequency Allocation certification ( also known as 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 the use of specific allocated frequencies among current users so that they do not interfere with each other. The Manual of Regulations and Procedures for Radio Frequency Management [26], 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.

In foreign countries, DoD adds the Foreign Coordination page to the Equipment Frequency Allocation certification and releases it to Combatant Commanders for direct coordination with the ministries of defense. This coordination results in frequency assignments for specific systems in specific nations under specific conditions.

The specifics of the DoD spectrum management processes are not established in OSD or JCS publications but are defined in various ways in spectrum management directives published by each service and by the Military Communications Electronics Board (MCEB). MUES policy, defined in DoD Directive 4650.1 [19], attempts to integrate the spectrum management process with the acquisition process by requiring that,

“ 4.5. The DoD Component that is developing or acquiring spectrum-dependent equipment or systems shall make a written determination, with the concurrence of the DoD Component or Component Chief Information Officer (CIO), that there is reasonable assurance of spectrum supportability.”

And it defines spectrum supportability as,

“The assessment as to whether the electromagnetic spectrum necessary to support the operation of a spectrum-dependent equipment or system during its expected life cycle is, or will be, available (that is, from system development, through developmental and operational testing, to actual operation in the electromagnetic environment). The assessment of "spectrum supportability" requires, at a minimum, receipt of equipment spectrum certification, reasonable assurance of the availability of sufficient frequencies for operation from HNs, and a consideration of EMC.” [4]

Since the publication of the Electromagnetic Spectrum Management Strategic Plan [22] in October 2002 the DoD Spectrum Management community has been focusing on improving the integration of spectrum management with acquisition management. Despite the efforts, reports (see table 1) continue to identify acquisition program risks resulting from lack of sufficient frequencies or interference with other systems. This leads to the question, “How can DoD improve on its compliance with spectrum management regulations or lower the risk of non-compliance?” Perhaps the best way is for DoD to integrate attainment of the three minimal criteria for spectrum supportability (which are: spectrum certification; assurance of frequencies; EMC) into the DAS in such a way that it becomes systematic and compulsory. The following sections of this report explore how this can be achieved.

4. Basic DoD Acquisition System (DAS) Process and Boundaries

It is questioned whether or not changing the DoD 5000 process would result in compliance. DoD D 5000.1 graphically defines the DAS model as shown in Figure 2. A full description of the processes within the model is defined in references [20],[21],[6]. System Engineering, Contracting and other Program/Business management processes are integrated within this model. The DAS provides oversight and review for compliance with statutory and regulatory requirements for acquisition programs at each life-cycle phase decision point (A, B & C), represented by triangles, as well as the program reviews within the life cycles phases (Concept Decision, Design Readiness Review, & Full Rate Production Decision Review), represented as diamonds.


Figure 2. Defense Acquisition System Process