The spectrum policy environment in 2024 and early 2025 is moving from static allocation toward dynamic, database-driven sharing models. For electronic warfare practitioners this is not an abstract legal debate. It changes where and how friendly platforms operate, how adversaries and civilian systems coexist, and what detection and targeting options remain viable in contested bands. Below I summarize the key policy developments and translate each into practical implications for EW planning, testing, and procurement.

Key policy developments and what they mean

1) Lower 37 GHz: co-equal shared use with DoD priority in a sub-band

NTIA and DoD completed a study of the Lower 37 GHz band and recommended a co-primary, shared-use coordination framework for 37.0-37.6 GHz, including priority access for DoD in the 37.0-37.2 GHz segment while enabling co-equal Federal and non-Federal use in 37.2-37.6 GHz. The framework is explicitly intended to create a proving ground for technical sharing solutions that support both military and commercial use cases.

Practical implications

  • DoD and contractors should expect to operate in a mixed environment where commercial fixed and mobile services are present and where dynamic coordination tools are required to avoid harmful interference. Plan EW exercises that include SAS-style coordination and test how mission systems perform when constrained by priority access requirements.
  • EW sensor placement and siting must account for increased commercial millimeter-wave activity near operational areas. Antenna nulling and spatial filtering will be more valuable than broad-spectrum power increases in this band.

2) Dynamic sharing and database control as an operational baseline

Shared-use regimes increasingly rely on centralized databases and automated coordination systems to mediate access. CBRS is the best mature example of a three-tiered, SAS-driven model that supports incumbents, licensed priority users, and general authorized access users under a single technical regime. That architecture is being treated as a template for other mid- and upper-band sharing efforts.

Practical implications

  • EW planning must incorporate the presence of Spectrum Access Systems and Environmental Sensing Capabilities. Tests that ignore SAS behavior will overestimate achievable spectrum freedom in a shared band.
  • For commercial off-the-shelf RF capability used in EW experimentation, validate operation through certified SAS providers when operating in shared bands and coordinate test windows with the spectrum authority where required.

3) Global protections for passive services constrain adjacent-band use

International radio regulations and WRC-23 outcomes place emphasis on protecting Earth exploration satellite services and other passive sensors, especially in and near the 36-37 GHz range. Any expansion of terrestrial or space-based transmitters adjacent to those passive bands must include stricter out-of-band emission limits and technical protections.

Practical implications

  • EW emissions and wideband jammers operating near passive-sensor allocations need rigorous spectral mask controls and operational safeguards. Uncontrolled out-of-band energy risks not only regulatory pushback but also operational constraints when passive sensors are mission-critical to allied partners.
  • When conducting wideband tests, include spectrum monitoring that specifically tracks emissions into passive bands and log power spectral density with sufficient resolution to demonstrate compliance.

4) Unlicensed expansion debates and the 6 GHz precedent

The FCC has expanded very low power operations into portions of the 6 GHz band and has considered how to balance unlicensed innovation with incumbent protection. The regulatory approach used in 6 GHz shows the tension between enabling consumer and enterprise innovation and preserving incumbent services. Oversight, litigation, and follow-on rulemakings remain part of the landscape.

Practical implications

  • Expect continued change in the availability of unlicensed channels and in device behavior in key urban environments. EW spectrum managers should anticipate increased localized unlicensed activity that will raise the noise floor for short-range sensing and targeting.
  • Prioritize robust signal classification and attribution capabilities to separate benign unlicensed signals from hostile or spoofing signals in congested bands.

Operational recommendations for EW teams and spectrum managers

1) Treat spectrum policy as a planning constraint, not an afterthought

Operational plans that assume exclusive, unencumbered access to mid and high bands will fail in shared regimes. Incorporate coordination timelines, SAS interactions, and potential priority-yield events into mission timelines. Simulate degraded spectrum availability and validate mission essential tasks under those conditions.

2) Invest in spectrum-awareness sensor grids and provenance logging

Deploy distributed spectrum sensors with secure time-synced logging to build situational awareness and to provide a tamper-evident audit trail for interference incidents. These sensors help distinguish incidental civilian emissions from intentional jamming or spoofing and are useful when interfacing with regulators or commercial SAS providers.

3) Build mixed-reality proving grounds that include SAS and passive-sensor constraints

Policy proofs will require testbeds that replicate the technical constraints regulators are protecting. That means integrating database coordination, sensor protections, and civilian network emulators into EW test ranges so systems are not validated only in sterile RF environments.

4) Prioritize adaptive waveforms, spatial control, and low probability of interference techniques

Where sharing is mandated, the most effective EW approaches emphasize waveform agility, beam shaping, and time-sliced operations rather than brute force power. Investment in fast beam steering, null formation, and adaptive coding will yield resilience without triggering protection actions from SAS or incumbent users.

5) Maintain compliance posture and legal awareness

Shared spectrum regimes carry legal obligations and reporting requirements. Coordinate with legal and frequency management officers before experimental operations. In commercial shared bands, use certified SAS providers and respect certified Environmental Sensing Capabilities to avoid violating rules designed to protect incumbents.

Concluding note

Spectrum policy is converging on two complementary trends: more sharing mediated by automated coordination systems, and stricter technical protection for sensitive passive sensors. For EW professionals this means the technical problems are now also policy problems. The winning approach integrates RF engineering, dynamic coordination technology, and legal compliance into system design, acquisition, and testing. If you are designing or fielding EW systems for operations near 3.5 GHz, the lower 37 GHz band, or adjacent passive bands, factor in SAS interactions, passive-sensor protections, and proving-ground validation from the start. This is the practical path to operational effect in a world of shared airwaves.