We concur there is no reason to go through the efforts of the Equipment Certification process on COTS equipment that perform the basic ATC functions in the National Airspace System (NAS) as per AFI 33-118 in the paragraphs you cited below. However, this is not an all encompassing rule when it comes to the International Airspace’s as every country has their own rules, nor is it inclusive of every situation in the NAS. In addition, the following points need to be considered when dealing with the issue of certifying or not certifying COTS ATC equipment:
- Each country/AOR has their own policies regarding ATC/NAVAIDS equipment coming into their airspaces, and whether or not the equipment must have Equipment Certification completed prior to operation. Prior coordination with the COCOM of the AOR that any aircraft enters would be to the advantage of all Program Offices.
o In addition, Foreign Coordination with the ASC Foreign Disclosure Office is a must for all RF systems onboard the aircraft just as any other aspect of the airframe going to another government, and the DD Form 1494 (Equipment Certification document) is the accepted/official document for processing that Foreign Coordination
- If there is no Equipment Certification performed on the COTS ATC/NAVAIDS equipment, then requesting specific frequencies for testing via DoD Spectrum Management offices will NOT be a possibility because the National Level agencies will not process the requests without the Certification being completed. The vendor that the Program Office is acquiring the aircraft or ATC equipment from, must process frequency requests through the FCC for any testing because DoD is not authorized to possess an FCC license for the purpose of performing a DoD testing or operational function.
- Lastly, ALL IFF systems must have DoD AIMS certification completed prior to operations on any DoD aircraft (or DoD related airframe) regardless if it is COTS or not; with the exception of a Direct Commercial Sale of the equipment/airframe straight from the vendor’s factory to the foreign government. FMS (Foreign Military Sales) is a little different as DoD has a direct involvement with the testing/operation of that equipment/airframe prior to turning over responsibility to that foreign entity, and again, DoD AIMS certification must be completed prior to testing/operations. Having said that and referencing the first point above, please keep in mind that DoD AIMS certification may be part of the overall package that encompasses certifying all RF systems to assure all those systems meet DoD requirements.
- Included at https://acc.dau.mil/CommunityBrowser.aspx?id=473781 is some supporting documentation put together by Mr. Paul McDowell that further amplifies the need for Frequency Assignments in certain bands as per the NTIA Manual which sometimes trumps Air Force (or Service Level) policy/directives.