What’s that you say? What does OMB Circular A-11 have to do with anything EMC related? That’s a pretty good question, and one that I would have asked myself. Until I read (because it was pointed out to me) section 31-12 of the latest edition of the Circular. It starts off:
“The value of radio spectrum required for telecommunications, radars, and related systems should be considered, to the extent practical, in economic analyses of alternative systems/solutions.”
And it continues with some “guidance” on how to estimate the value of spectrum. But this rant isn’t really about RF spectrum valuations, its more about how we expect DoD program offices who already struggle with technical areas like EMC and spectrum supportability as well as developing and meeting budgets, especially for major, multibillion dollar programs. Now we are asking program management offices to throw a wildcard into the budgeting process that is a kind of black magic combination of technical expertise in RF spectrum use and fortune telling. Considering that we auction off spectrum these days, I’m not sure that there’s any good way to put a value on spectrum much less factor spectrum value into military program procurements. But I’ve been wrong before…
Reading a little more about the guidance provided, it turns out to be a little thin (but in fairness, you really can’t expect a lot of detailed technical guidance in a budget policy document):
“One method for determining spectrum efficiency when assessing procurement of Federal systems is to develop a baseline that measures: 1) the technical characteristics of the frequency used by the system, 2) the population of an area where spectrum is utilized and 3) the amount of bandwidth utilized.”
I suppose #2 and #3 are fairly straight forward, although the population of the area with US DoD system are used is in the billions, worldwide! Its item #1 that is going to require a lot of clarification to be a meaningful measure of any sort. Just what are “the technical characteristics of the frequency used by the system” and how do you measure it? I don’t know either! There a variety of directions one could take with that statement but there’s no guarantee it would provide the information that management is looking for.
This reminds me a little of the implementation of the Spectrum Supportability Risk Assessment requirement. There was very little specific guidance provided and many of the initial submissions just didn’t provide what was required to actually assess the desired risks. We really shouldn’t have been surprised. I think we’re in for the same type of response in the implementation of this requirement. That the folks on the working end won’t really know what’s expected or how to actually produce the required data. But they’ll do the best they can to check on the latest item on the list while they work to get systems out to the users that need them.
-Brian Farmer
