Small Unmanned Aircraft System Electromagnetic Spectrum Procedures

1. Purpose. To provide amplifying guidance to ensure
the Marine Corps remains compliant with Federal regulations while
supporting ref (a).
2.  Background.
2.a. Reference (a) authorizes O-6 commanders or equivalents to grant
authority to operate (ATO), procure, test, and train with small
Unmanned Aircraft System (sUAS) that are compliant with statutory
limitations. 
2.b. Reference (b) outlines Federal statutes in the context of
management and use of the EMS for which regulatory authorities
has been entrusted to the National Telecommunications and
Information Administration (NTIA) which serves as the Federal
Electromagnetic Spectrum (EMS) regulator under the
Department of Commerce.
2.c. To ensure the Marine Corps can fight with and against unmanned
threats while also complying with statutory regulations, the Office
of the Deputy Commandant for Information (DC I), Information,
Command, Control, Computers, and Communications (IC4) has identified
requirements from refs (b)-(e) that can delay mission readiness when
not followed early and correctly.  
2.d. EMS supportability is the set of prerequisites that must be
satisfied before operating in the EMS. Within the United States and
Possessions (US&P), EMS supportability consists of:
2.d.1. Equipment Spectrum Certification (ESC): NTIA certification
that the system conforms to U.S. allocations and technical rules;
ESC is required before requesting a frequency assignment.
2.d.2. ESC is typically initiated in the acquisition process and
typically only done once. Reasons for a sUAS ESC to be updated
include requests to increase authorized locations and changes to
the sUAS EMS dependent components (e.g., EMS band, power, etc.). 
2.d.3. Frequency Assignment: Authority to operate in a stated EMS
band, location/area, and timeframe using specified parameters.
Use requires a valid assignment.
2.d.4. Regardless of their method of procurement or stage of
acquisition, sUAS systems must meet EMS supportability requirements
prior to fielding and use. 
2.e. Authority: NTIA is the sole Federal authority for assignments
in Federal EMS bands.  
2.f. Non licensed (Title 47 U.S.C.) devices. Low power devices
(e.g., in 900 MHz, 2.5 GHz, and 5 GHz bands) approved under FCC
rules (e.g., Part 15, Part 95) must accept interference and meet
labeling/ID requirements.
2.f.1. When used for a military function, COTS "non licensed"
devices still require EMS supportability (ESC/assignment). 
2.f.2. COTS gear without an FCC label/ID may be limited to Federal
band ESC only, which can restrict operational bands/locations.
2.g. Ref (a) identifies the Defense Innovation Unit (DIU) Blue UAS
Hub as a list of DoD-approved UAS, components, and software that is
available for purchase and operation by all U.S. military units on
all military installations.
2.g.1. Maintainers of the DIU Blue Unmanned Aircraft System (UAS)
Hub acknowledge that a Blue UAS Hub ATO is not an EMS approval.
2.g.2. Blue UAS Hub ATOs include the text "use of Blue UAS is
permitted in all locations where the gaining organization of the
platform covered by the ATO has obtained the appropriate flight,
safety, and spectrum approvals."
3. Concept of Operations. Basic Step by Step Process
(How to Comply).
3.a. Identify the system. Document make/model, radios, firmware,
waveform, bands, max power, antennas, GNSS, video downlink,
datalink, and any SATCOM/EW payloads.
3.b. Check device status. If COTS, confirm FCC label/ID and the
applicable FCC Part (e.g., Part 15/95). Note: FCC "non licensed"
status does not waive Marine Corps EMS requirements.
3.c. Start ESC. Contact MARCORSYSCOM to initiate NTIA Equipment
Spectrum Certification (include all technical data). Coordinate
early for new or modified configurations.
3.d. Request frequency assignment. Through respective MEF of
Installation Spectrum Manager.  ESC is a prerequisite.
3.e. Receive approvals. Do not operate until ESC is approved and
frequency assignment (or EA authorization) is issued and on hand.
3.f. Maintain compliance. If you change hardware, firmware,
antennas, power, or waveform—or relocate to a new area—you may need
updated ESC and/or a new assignment.
4. Tasks. 
4.a. NTIA: National EMS regulator for Federal users in Federal
frequency bands (i.e., Federal Departments, Agencies,
Administrations). The NTIA certifies EMS dependent systems for use
within the US&P and assigns frequencies for Federal agencies
within the US&P.
4.b. FCC: National EMS regulator for non-Federal users in
non-Federal frequency bands (i.e., state, local government,
commercial, private internal business, and personal use). 
4.c. DC I-IC4 publishes Marine Corps EMS policy; identifies Service
level changes to meet senior leader sUAS intent while conforming to
DoD/USG policy; supports DON efforts to streamline DoD spectrum
approval processes.
4.d. Marine Corps Systems Command (MARCORSYSCOM).
4.d.1. Supervises and manages EMS supportability across the
acquisition lifecycle, ensuring seamless integration of all Marine
Corps EMS dependent equipment with the exception of program of
record sUAS and aviation platforms.
4.d.2. Serves as focal point providing administrative and technical
support to MARCORSYSCOM program offices, Program Executive Office
Land Systems (PEO LS), Marine Corps Warfighting Lab (MCWL), and
Fleet Marine Force (FMF) procurements, installations, and other
entities for ESC and HNA coordination.
4.d.3. Seeks and maintains frequency assignments for systems
tested or operated by Marine Corps acquisition program.
4.d.4. Ensures EMS supportability is planned for each milestone
and maintained through sustainment and configuration changes.
4.e. Navy and Marine Corps Spectrum Center (NMSC). EMS
supportability/coordination activity for Navy/Marine Corps;
interfaces with NTIA and other stakeholders (e.g., FAA) for ESC and
frequency assignments; conducts regional de confliction via NMSC
regional Navy and Marine Corps Spectrum Offices (NMCSO).
4.f. Marine Corps Warfighting Lab (MCWL).
4.f.1. Ensures EMS compliance during experimentation; validates ESC
for systems in events.
4.f.2. Obtains/maintains frequency assignments for experimentation;
coordinates early with MARCORSYSCOM/NMSC for novel/emerging
waveforms and host nation trials.
5. Coordinating Instructions.
5.a. Marine Forces (MARFOR), Marine Expeditionary Forces (MEF),
and Marine Corps Installations Command (MCICOM).
5.a.1. Do not operate EMS dependent systems without ESC and a valid
frequency assignment.
5.a.2. For COTS purchases, verify FCC labeling/ID, then initiate ESC
and request assignments through MARCORSYSCOM/NMSC.
5.a.3. Maintain unit level configuration control and documentation
(platform, radio, firmware, waveform, power, antenna, GNSS, video
downlink).
6. Points of Contact. Direct all questions to the MARADMIN POC
listed above.
7. Release authorized by Lieutenant General M. G. Carter,
Headquarters Marine Corps, Deputy Commandant for Information.