Stage 1 DD Form 1494 to reserve the bands it expects to use. In Technology Maturation and Risk Reduction, the Stage 2 package refines those claims with laboratory data. Engineering and Manufacturing Development culmi- nates in Stage 3, where coexistence with incumbent systems must be demonstrated. Only after NTIA grants Stage 4 certification in Production and Deployment may a system radi- ate operationally. Shoving spectrum tasks to the right of this timeline is like test-flying an aircraft before confirm- ing its wings stay attached—possible, but catastrophically unwise. The hidden cost curve. Every ac- quisition professional knows that de- fects get pricier the later they surface. A RAND survey of major defense and warfighting programs placed the cost ratio at roughly $1 to fix an RF conflict in the lab, $10 during operational test, and $100 after fielding. Those figures exclude the “soft” costs of canceled training, lost readiness, and diplo- matic fallout when host nations deny frequency clearances. Upfront certifi- cation is not bureaucracy; it is sound fiscal stewardship. Not the bottleneck. Postmortem reviews reveal a consistent pattern. Contracts omit RF test articles, no funding line exists for SSRAs, and program offices delay NTIA engage- ment until weeks before fielding. When inevitable rejections arrive, the spectrum manager becomes the scapegoat. In truth, NTIA rou- tinely processes complete, well- documented packages in a matter of weeks. Only when DoW shows up with half-filled forms and demands emergency treatment do timelines explode. The bottleneck is often late engagement, not the regulator. The workforce gap. Even the best-designed process collapses without enough qualified people to run it. Over recent years, the pool of federal spectrum engineers and planners has steadily shrunk as re- tirements outpace new hires while the demand signal has exploded, fueled by unmanned systems, 5G-
Senior leaders must treat spectrum experts as mission- critical personnel and protect existing billets, accelerate hiring pipelines, and fund modern analysis tools and training with the same urgency devoted to stealth coatings or hypersonic materials.
enabled radios, and an avalanche of new electronic-warfare upgrades. The result is that a small cadre of overextended experts are juggling dozens of major programs, each stamped “urgent.” No amount of pro- cess streamlining will erase that math. Senior leaders must treat spectrum experts as mission-critical personnel and protect existing billets, acceler- ate hiring pipelines, and fund mod- ern analysis tools and training with the same urgency devoted to stealth coatings or hypersonic materials. Without that investment, schedule slips and last-minute crises will re- main the norm, no matter how well the paperwork is written. Unmanned Prototypes vs. Weather Protection When the Army launched its Fu- ture Tactical Unmanned Aircraft Sys- tem (FTUAS) competition in 2021, each vendor proposed a Group 3 drone that relied on C-band data links around 5 GHz—frequencies popular with Wi-Fi, Unmanned Aircraft Test Range licenses, and, critically, the FAA’s Terminal Doppler Weather Radars (TDWRs) positioned near 45 major U.S. airports. Because flight-test events were scheduled for Army airfields far from commercial hubs, program managers assumed the risk to TDWRs would be negligible and budgeted spectrum engineering for post-prototype down-
select. NTIA disagreed. Stage 3 certi- fication still required proof—via mod- eling and field measurements—that each air vehicle’s high-gain antenna would neither desensitize TDWR re- ceivers nor suffer interference from nearby 802.11ac (Wi-Fi 5) access points operating under the Federal Communications Commission (47 Code of Federal Regulations Part 15). The problem was that none of the four competing vendors had fully characterized their antennas’ sidelobe patterns or dynamic power-control logic. Gathering that data meant re- booking scarce anechoic-chamber time, rewriting link-budget models, and running Monte Carlo simula- tions that accounted for hundreds of TDWR beam positions and thou- sands of commercial Wi-Fi hotspots surrounding the chosen test ranges. A “quick” 60-day NTIA review bal- looned into nine months. While engineers scrambled, the Army had to extend legacy Shadow UAS deployments and delay soldier- touch-point evaluations at Fort Wain- wright, Fort Campbell, and Fort Riley. The cost of keeping older airframes flying—and of shifting range sched- ules—easily eclipsed the modest sav- ings gained by postponing spectrum analysis during early design. The lesson is familiar: The electro- magnetic environment can change— or reveal hidden incumbents—faster than a program can pivot. Waiting
36 | DEFENSE ACQUISITION | November-December 2025
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