Commercial, Off-the-Shelf (COTS) is defined as "commercial items that require no unique government modifications or maintenance over the life cycle of the product to meet the needs of the procuring agency."
[From the Twelfth Edition of GLOSSARY: Defense Acquisition Acronyms and Terms.]
EMC concerns must be addressed for Commercial Off-The-Shelf (COTS) equipment. A thorough evaluation of the application of COTS equipment and the intended operational electromagnetic environment (EM) is more critical now as its use proliferates on military platforms.
The use of COTS (also known as Commercial Items/Non-Developmental Items [CI/NDI]) presents a dilemma between the need for imposing Electromagnetic Interference (EMI) controls and the desire to take advantage of existing designs, which may have unknown or undesirable EMI characteristics. Blindly using COTS equipment carries a risk of incompatibilities onboard a military platform. To mitigate the risks, a suitability assessment is required to evaluate the installation environment and the equipment’s EMI characteristics through a review of existing data, review of equipment design, or limited testing.
The use of CI/NDI allows the military to take advantage of technological advances, cost savings and rapid procurement stemming from the competitive pressures of the commercial marketplace as well as developments in other DoD or government agencies. The use of these items can minimize or eliminate the need for costly, time-consuming, government-sponsored research and development programs. In addition to providing an overview of how to address E3/SS CI/NDI related issues in a system acquisition, we will provide a general overview of major commercial EMC standards and how they compare with each other and MIL-STD-461 (the DoD’s primary equipment level EMI requirement document). An understanding of the relationship between the commercial EMC standards and EMC environments is essential to assessing the risk that the equipment will operate correctly in its intended EM environment. Understanding these issues and how to deal with them offers new and unique challenges to the acquisition community.
INCIDENTILY, WHAT IS A "CI"?
- A Commercial Item (CI) is used for non-Government purposes and has:
- Been sold, leased, or licensed to the general public
- Been offered for sale, lease, or license to the general public
- Evolved through advances in technology or performance and is not yet available in the commercial marketplace, but will be in time to satisfy the delivery requirements of a Government solicitation.
THEN, WHAT IS A "NDI"?
Non-Developmental Items (NDI) have been previously developed and used for Government purposes by another DoD /Federal Agency, State or local Government, or a foreign Government that has a mutual defense cooperation agreement with the US.
A BIT OF HISTORY
CI/NDI is another part of Secretary Perry’s acquisition reform initiative from the late 1980’s. For some acquisition programs, the procurement of CI items and NDI is a cost-effective approach to meeting the mission needs.
Major COTS issues are:
- CI/NDI systems create some of the biggest issues in both the spectrum management and E3 communities. Because these systems are often not designed for the military electromagnetic environments, they may malfunction or cause other operational problems.
- Another issue is the militarization of commercial equipment. Modifications which alter the radio characteristics of commercial equipment can create coordination difficulty. In many cases, the systems are limited to a non-interference basis and may face severe restrictions.
In today's fast track” acquisition, the use of COTS is seen as a way to field systems quickly and cheaply.
- Research and development is performed by an independent agency and the government saves money. Unfortunately, the primary market for these systems is the commercial sector. When the government buys COTS equipment, we cannot always support it in spectrum authorized for use by the military.
- There is a sub-set of COTS known as NON-LICENSED devices. These are low power devices which are approved by the FCC for use in the US&P. Some examples are: Garage door openers, baby monitors, cordless phones, and remote controlled cars or planes.
COTS AND THE MILITARY
What’s the problem with commercial equipment in the military operational electromagnetic environment? Commercial items are simply not designed to operate in such a complex and harsh EME. They aren’t designed to minimize emissions across the frequency band and they aren’t designed to be “hardened” against all the powerful radiation encountered in a battlespace.
The most significant source of these problems fall in the categories of design and application. In the past, the commercial industry has used standards that are applicable to commercial equipment. The typical commercial designers have recognized for years that the military has designed and built most of their own systems and commercial opportunities had been few. But now the trend is to fulfill requirements with COTS equipment which leads into the usage problem areas.
In addition, there are a variety of spectrum management-related problems associated with the use of commercial equipment for military purposes. A COTS item, even though approved by the FCC for COMMERCIAL use, does not exempt that item from going through the military spectrum management process. Some program managers feel that they don’t have to apply spectrum allocation or the equipment they ordered operating in an authorized band but that is okay because they are achieving their goals for equipment to perform the mission...OR HAVE THEY?
Here’s some examples (shipboard) that some of you may be familiar with.
- Battle Group Cellular Phone - Due to the commercial applications of this technology, the Navy is restricted from using BG cellular within 50 miles of US shore lines.
- Challenge Athena - Challenge Athena allows for at-sea imagery and intelligence transmission, data-base access, video-teleconferencing, multi-line CONUS telephone connectivity, and telemedicine. The system uses a leased 36 MHz transponder from COMSAT with a global beam to eliminate the need to track the ship which also allows any unit similarly equipped within the satellite footprint to receive the same feed.
- INMARSAT
- Other receivers
...AND WHY ARE THESE SYSTEMS A PROBLEM? They weren’t designed for the EME...It's that simple, really...
NOTICE: NEW CLASS ON COTS!...
