The Common OperatingPicture Comes First
An investment framework for allocating FY2027 FEMA counter UAS funds
By Jerry McGee
Founder and CEO, UNIFY.C2
October 2026
The funding decision
State Administrative Agencies and the officials who prioritize counter-UAS investments are deciding how individual purchases will become a usable public safety capability. My recommendation is to establish the Common Operating Picture, or COP, as the architectural foundation of that investment. SAAs and other officials should define how sensors, agencies and authorized responders will work together before committing the portfolio to separate systems.
A COP brings detections, tracks, video and relevant airspace information into a consistent operational environment. For funding officials, its value is practical: it can preserve useful existing equipment, reduce disconnected purchases and make regional cooperation measurable. It also provides a common basis for testing whether funded systems work together.
This paper addresses SAA leadership, homeland security and emergency management officials, state and regional public safety leaders, and the grant, procurement, and technical personnel who evaluate proposed investments. It translates the original COP-first operating framework into decisions about project selection, implementation, and accountability.
The FY2027 opportunity
FEMA’s FY2027 program provides $250 million across 56 eligible states and territories. SAAs are the direct applicants; local and tribal governments participate through their SAA. Applications are due November 16, 2026, at 5 p.m. Eastern Time. The projected performance period is December 10, 2026, through December 9, 2029.
The program supports national detection and response capacity, with emphasis on the 2028 Olympics and Paralympics and, where applicable, the torch relay. Projects must demonstrate operational need and feasibility. An allocation does not guarantee that every proposed project will receive spending approval.
The recommendations that follow are UNIFY.C2’s recommended investment framework. They are not additional FEMA requirements and do not imply that FEMA requires a particular COP platform or vendor.
Allocate for a regional operating capability
Evaluate each proposal both on its own merits and on its contribution to the wider mission. A well-performing sensor can still leave a gap if its information never reaches the agencies responsible for assessment and response. A shared service can be valuable when participating jurisdictions can use it under documented access and support arrangements.
Define the decisions the investment must support
Begin with the protected locations, expected threats and responsible agencies. Specify who needs to recognize an aircraft of interest, confirm what it is, notify partners and coordinate an authorized response. Include planned events and mutual-aid responsibilities where relevant. These decisions should determine the sensor mix, connectivity and COP requirements.
Preserve existing investment and address documented gaps
Require an inventory of existing and previously funded systems (FIFA or otherwise), including their coverage, interfaces, data rights and support status. Ask applicants to explain whether a proposed purchase adds coverage, improves confidence, enables sharing or replaces equipment that can no longer meet the mission. An additional system should have an identifiable operational contribution.
COP-first planning does not mean delaying necessary radar or committing all funds to software. It means agreeing on the operating architecture early enough that hardware, integration, staffing and training can be scoped together. A state may use a shared platform or connect regional platforms through defined interfaces. The appropriate model depends on local ownership, network constraints and mission requirements.
Assign responsibility for shared services
Decision owner | Recommended responsibility |
SAA and state program leadership | Set priorities, evaluate regional benefit and document allocation decisions. |
Operational agency leadership | Own the mission, staffing, response procedures and acceptance of operational capability. Review and implement appropriate compliance and governance policies. |
Technical and security leads | Verify interfaces, access controls, resilience and support responsibilities. |
Grant and procurement personnel | Validate allowable costs, acquisition steps, contract scope and delivery evidence. |
Participating jurisdictions | Agree on access, service value, data use and mutual-aid responsibilities. |
Structure shared funding carefully
FEMA’s FAQ describes a 97% pass-through requirement, a permitted exception of up to 20% for justified state-level needs, and arrangements that provide services or items for subrecipient benefit with appropriate written consent. A statewide COP proposal should identify beneficiaries and allocated value, document consent where applicable, and confirm the funding treatment with the SAA’s Preparedness Officer. Shared architecture does not remove pass-through obligations.
Require a complete sensor integration concept
No single sensor provides a complete understanding of every aircraft or operating environment. Radar can contribute non-cooperative detection. RF systems may provide signal-based observations, while EO/IR cameras support visual assessment. Remote ID and ADS-B add cooperative context, and acoustic sensors may contribute in suitable conditions. The investment case should explain how these sources complement one another and where coverage remains limited.
The Notice of Funding Opportunity (NOFO) strongly encourages radar with a mission-appropriate use case and a basic siting, coverage and integration concept. A COP should make that investment operationally useful by connecting radar tracks to assessment, camera cueing and partner workflows. Cooperative feeds alone should not be treated as complete coverage of non-cooperative aircraft.
Evidence to request before selecting an integration approach
Requirement | Evidence for the investment review |
Sensor compatibility | Named sensor models, supported interfaces, required licenses and work remaining. |
Track correlation | A demonstration of multiple observations associated with an aircraft, with source detail and uncertainty visible. |
Operational assessment | A workflow that connects tracks, protected areas and available imagery to an operator decision. |
Partner exchange | Defined recipients, data fields, refresh rates and a tested exchange with relevant command systems. |
Continuity and resilience | Behavior during sensor, network or hosting failures and a recovery procedure. |
Event reconstruction | Replay and export that preserve the observations and actions needed for review. |
An interface listed in a brochure is a starting point for diligence. The proposal should distinguish integrations already supported from configuration, new development and third-party dependencies. Contract scope should assign responsibility for delivery and acceptance of each connection.
Separate shared awareness from operational control
Regional coordination does not require every user to see all data or control every sensor. Define permissions for viewing, tasking, exporting and responding. A fusion center may need regional awareness while a local agency retains control of its equipment. A state program office may need performance reports without operational control. These distinctions belong in the architecture and the agreements between agencies.
Preserve future choice
Review data ownership, export rights, interface access and the cost of adding or replacing a sensor. Require vendors to identify dependencies that could restrict future competition or make a change of provider expensive. The COP should provide a consistent operating environment as individual technologies change.
Fund an executable and lawful deployment
A technically capable proposal needs a credible path to use. Review procurement lead times, installation permissions, communications, cybersecurity approvals, operator availability and training together. Identify the organization responsible for resolving each dependency. A delivery date for equipment is not the same as a date for operational readiness.
Match the operating model to the selected technology
FEMA distinguishes procurement readiness from authority to operate. Its FAQ describes certification and accreditation conditions for mitigation and certain detection systems, while exempting examples such as radar, EO/IR, acoustic sensors and Remote ID receivers from that specific training requirement. Enrollment alone does not authorize operation.
For a proposal involving restricted capabilities, ask the operational lead and counsel to document the applicable operating authority, designated agency, personnel qualifications and remaining approvals. The COP can support permission controls and records, but software does not confer legal authority. Budget and schedule decisions should reflect when the selected capabilities can actually be used.
Include data sharing in the acquisition scope
The NOFO requires relevant grant-funded detection data to be shared securely with DHS as directed, consistent with law and privacy requirements. Vendor agreements must permit that access.
Translate this condition into technical deliverables: the data to be shared, approved recipients, connection method, security controls and responsibility for maintaining the interface. Demonstrate access restrictions and the handling of source metadata. Establish retention and export rules with counsel and records personnel, then test that the deployed system follows them.
Budget for the complete mission
FEMA organizes allowable activities around Planning, Organization, Equipment, Training and Exercises. Within those categories, applicants should identify the costs needed to make the proposed capability usable. Every budget line should have a defined purpose, responsible owner and relationship to the approved project.
For COP-related investments, request separate pricing for the platform, sensor integration, hosting, connectivity, deployment services, operator training and support.
Identify recurring charges and the funding source after the grant period. Compare total cost over the planned operating life, including additional users, new sensor interfaces, data storage and exit costs. Confirm allowability for each item rather than assuming that an entire commercial package qualifies.
Use phased delivery with defined acceptance
An effective sequence is to approve the operating concept, connect the initial sensors, validate agency access, exercise the response workflow and then expand coverage.
Each phase should produce usable capability and evidence that the next phase is justified. The NOFO excludes technology-development studies and proof-of-concept initiatives. Acceptance testing should validate a defined deployment rather than substitute for an undeveloped solution.
Compare proposals using operational evidence
Use FEMA’s required review criteria as the controlling framework. Supplement that review with consistent questions about how each proposal will work in the field. The following matrix is a recommended internal diligence tool, not a substitute scoring system or a representation of FEMA point values.
Review question | Evidence to request |
Does the project address a clear need? | Threat and vulnerability assessment, protected area and the specific gap being closed. |
Will partners be able to use the result? | Named agencies, access arrangements, operating roles and mutual-aid concept. |
Will the purchased systems work together? | Integration scope, interface dependencies, coverage concept and end-to-end test plan. |
Can the project become operational on time? | Procurement schedule, installation permissions, staffing and training milestones. |
Can the agency sustain it? | Recurring cost schedule, support ownership and post-grant funding plan. |
Can performance be demonstrated? | Baseline, measurable acceptance criteria and a repeatable exercise or evaluation. |
FEMA values demonstrated effectiveness
FEMA reviews projects individually and may withhold spending approval for projects that do not demonstrate effectiveness. Its consolidated application template is optional but strongly recommended and includes implementation, budget and review information. Ask applicants to show the complete chain from the capability gap to the funded activities and the expected result.
Measure the operation as well as the sensors
Effective operation require four functions: Capture, Assess, Respond and Learn. For investment review, translate them into observable tests. Can the system ingest the required feeds? Can operators reconcile observations and assess an aircraft of interest? Can they notify the right partners and follow the authorized response procedure? Can the agency reconstruct the event afterward?
Set mission-specific acceptance thresholds for timeliness, track continuity, camera cueing, partner delivery and system availability. Use repeatable scenarios and record the conditions of each test. Retain detection-level records as well as correlated tracks so aggregation does not erase the evidence needed to understand performance. Separate program reporting requirements from additional measures the state chooses for its own oversight.
The allocation decision and the role of UNIFY.C2
The strongest investment case explains how the proposed capability will serve the mission across participating agencies. Before selecting projects, establish the shared operating requirements and ask each applicant to show its contribution. Before contracting, verify the integrations, delivery responsibilities and recurring costs. Before accepting delivery, exercise the system with the people who will operate it.
A COP-first approach gives funders a basis for making those decisions. It connects sensor purchases to agency workflows, ties regional access to defined responsibilities and makes operational acceptance part of the investment. It also allows the state to expand coverage over time without assuming that every jurisdiction must replace its existing equipment.
How UNIFY.C2 fits the investment
UNIFY.C2 is a vendor-agnostic command-and-control platform that brings sensor data, airspace information and authorized mission partners into a common operating picture. Its role is to connect diverse technologies into an environment that supports assessment, coordinated response, event review, and complete system testing. Deployment options include on-premises, GovCloud, hybrid and air-gapped environments.
For a proposed regional or statewide investment, the appropriate next step is a scoped technical and operational discussion: identify existing systems, define the required exchanges, establish user roles and determine the integration work. Evaluate the resulting scope through the same evidence-based procurement process applied to other components. Product capabilities and grant eligibility must be verified for the specific project.
Request a mission and integration briefing at www.UNIFYC2.com.
About the author
Jerry McGee is Founder and CEO of UNIFY.C2. His work focuses on connecting sensors, command systems and authorized mission partners into common operating pictures for public safety, military, federal and critical- infrastructure missions.
Sources and scope
This paper adapts The Common Operating Picture Comes First by Jerry McGee for officials allocating FY2027 funds. Grant references below identify the governing notice and the October 2026 FEMA documents supplied with this request. Subsequent FEMA guidance and award terms control.
FEMA. Fiscal Year 2027 Counter Unmanned Aircraft Systems (C-UAS) Grant Program, Notice of Funding Opportunity. Opportunity DHS-27-GPD-161-00-99. Available at https://simpler.grants.gov/opportunity/20f7807e-d2ca-43bd-8c75- 7993442b2305.
FEMA. FY2027 Counter-Unmanned Aircraft Systems Grant Program Frequently Asked Questions, October 2026.
FEMA. FY2027 Counter-Unmanned Aircraft Systems Grant Program Key Changes, October 2026.
FEMA. FY2027 Counter-Unmanned Aircraft Systems Grant Program Fact Sheet, October 2026.
Federal notice and application documents: https://simpler.grants.gov/opportunity/20f7807e-d2ca-43bd-8c75-7993442b2305
Request a mission and integration briefing at www.UNIFYC2.com.
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