Attachment 1 - Tellus CUI Guide Final
Attachment 1 - Tellus CUI Guide Final
Attachment 1 - Tellus CUI Guide Final
Program: Tellus
Program Manager: Dr. Linda Chrisey
Program Security Officer: Jesse Watkins
FOREWORD................................................................................................................................. 3
DESCRIPTION ............................................................................................................................. 3
AUTHORITY ................................................................................................................................ 3
1. PURPOSE............................................................................................................................... 4
2. APPLICABILITY AND SCOPE ......................................................................................... 4
3. OFFICE OF PRIMARY RESPONSIBILITY (OPR) ........................................................ 4
4. CONTROLLED UNCLASSIFIED INFORMATION (CUI) CHALLENGES ............... 4
5. OPERATIONS SECURITY (OPSEC) ................................................................................ 5
6. CUI Indices and Categories .................................................................................................. 5
a. Defense: ................................................................................................................................................... 5
b. Export Control: ....................................................................................................................................... 5
c. Intelligence: ............................................................................................................................................. 5
7. EXPORT CONTROL RESTRICTED INFORMATION.................................................. 6
8. FREEDOM OF INFORMATION ACT (FOIA) EXEMPT INFORMATION ............... 7
9. DISCLOSURE of CUI .......................................................................................................... 8
10. CUI PROTECTION REQUIREMENTS ........................................................................ 8
11. NOTIFICATION OF UNAUTHORIZED DISCLOSURE............................................ 9
12. STIMULI MICROBES ARE ENGINEERED TO DETECT WHICH WILL
RESULT IN CONTROLLED TECHNICAL INFORMATION (CTI) FOR TELLUS
PROGRAM ................................................................................................................................... 9
13. DEFINITIONS ................................................................................................................. 11
14. ACRONYMS .................................................................................................................... 11
15. INFORMATION PROTECTION GUIDANCE CHART ............................................ 13
TABLE 1 CUI INFORMATION PROTECTION GUIDANCE CHART ............................. 13
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FOREWORD
DESCRIPTION
Tellus will explore the development of a platform Methodology for the rapid and
modular design of microbe-based sensing systems to include tailoring of input stimuli and output
signals, biologically-encoded signal processing, and response times. The microbial devices that
are developed must be able to transduce detected stimuli into a variety of output signals (e.g.,
luminescence, fluorescence, colorimetric changes, chemicals, electric current, mechanical
actuation) that are measurable by conventional ‘receiver’ devices (e.g., optoelectronic, photonic,
imaging, electrode). Stimuli/output signal types will include both chemical and physical, with
emphasis on sensor functionality across many different environments and conditions. As remote
environmental monitoring for existing and emerging threats, pollutants or changing conditions is
an area of DoD/national security interest, microbial sensing systems that are capable of detecting
stimuli and/or relaying output signals at a distance and can operate unattended for long durations
are desired. Tellus is a 2.5-year program focused on developing a Methodology that enables
rapid design, building and testing of microbial sense-and-respond devices for environmental
monitoring.
AUTHORITY
CUI elements referenced in this guide are under the authority of DoDI 5200.48,
“Controlled Unclassified Information,” March 6, 2020.
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1. PURPOSE
The purpose of this CUI guide is to ensure the protection of Tellus information IAW
DoDI 5200.48. Tellus information should be controlled and stored consistent with federal
requirements and guidance from the National Institute for Standards and Technology (NIST).
Sensitive information does not include information in the public domain.
This guide is not for classified national security information as defined in Executive
Order 13526, but identifies specific elements of sensitive information that are unclassified in
nature requiring protection. This information is not classified national security information, but it
is covered by the legislation at large for the Freedom of Information Act (FOIA) and the
exemptions therein.
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5. OPERATIONS SECURITY (OPSEC)
OPSEC is a process that identifies and mitigates adversarial risk to our operations by
looking at our operations through the eyes of our adversaries. The application of the OPSEC
methodology includes identifying critical information, analyzing threats and vulnerabilities,
analyzing and assessing adversarial risk, and implementing OPSEC measures that reduce this
risk.
a. Defense:
i. Controlled Technical Information (CTI): Technical information with
military or space application that is subject to controls on the access, use,
reproduction, modification, performance, display, release, disclosure, or
dissemination.
b. Export Control:
c. Intelligence:
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7. EXPORT CONTROL RESTRICTED INFORMATION
Performers who develop devices/tools intended for commercial applications, must adhere
to guidance of the U.S. Munition List (USML), Commerce Control List (CCL), and follow
Export Administration Regulations (EAR) that are pertinent to any relevant articles that meet the
criteria described in Part 774 of the EAR and 87 FR 16422
https://www.federalregister.gov/citation/87-FR-16422:
https://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear and eCFR
:: 22 Part 121 The United States Munitions List https://www.ecfr.gov/current/title-22/chapter-
I/subchapter-M/part-121
Export controlled restrictions for Tellus CTI based on specification of Tellus device
being developed are listed below:
a. USML Category XIV Toxicological Agents, Including Chemical Agents, Biological
Agents, and Associated Equipment (f) (ii) Any equipment “specially designed” for
testing the articles controlled in paragraphs (a), (b), (c), (e), or (f)(4) of this category and
developed under a Department of Defense contract or other funding authorization. Any
equipment, containing reagents, algorithms, coefficients, software, libraries, spectral
databases, or alarm set point levels developed under a Department of Defense contract or
other funding authorization, for the detection, identification, warning, or monitoring of:
(i) Articles controlled in paragraphs (a) or (b) of this category; or (ii) Chemical agents or
biological agents specified in the Department of Defense contract or other funding
authorization.
c. ECCN: 1A004 Protective and detection equipment and “components”, not “specially
designed” for military use, as follows (see List of Items Controlled). c. Detection
systems, “specially designed” or modified for detection or identification of any of the
following, and “specially designed” “components” therefore: c.2. ‘Radioactive
materials’; or c.3. Chemical warfare (CW) agents; d. Electronic equipment designed for
automatically detecting or identifying the presence of “explosives” (as listed in the annex
at the end of Category 1) residues and utilizing ‘trace detection’ techniques (e.g., surface
acoustic wave, ion mobility spectrometry, differential mobility spectrometry, mass
spectrometry).
d. ECCN: 1A995 Protective and detection equipment not “specially designed” for military
use and not controlled by ECCN 1A004 or ECCN 2B351, as follows, and “parts” and
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“components” not “specially designed” for military use and not controlled by ECCN
1A004 or ECCN 2B351 therefor. a. Personal radiation monitoring dosimeters.
e. ECCN: 1C607 Tear Gases, Riot Control Agents and materials for the detection and
decontamination of chemical warfare agents (see List of Items Controlled).
f. ECCN: 2B351 Toxic gas monitors and monitoring systems, and their dedicated detecting
“parts” and “components” (i.e., detectors, sensor devices, and replaceable sensor
cartridges), as follows, except those systems and detectors controlled by ECCN 1A004.c.
g. ECCN: 4A004 Computers as follows (see List of Items Controlled) and “specially
designed” related equipment, “electronic assemblies” and “components” therefor. 2.
‘Neural computers’ are computational devices designed or modified to mimic the
behavior of a neuron or a collection of neurons, i.e., computational devices which are
distinguished by their hardware capability to modulate the weights and numbers of the
interconnections of a multiplicity of computational components based on previous data.
3. ‘Optical computers’ are computers designed or modified to use light to represent data
and whose computational logic elements are based on directly coupled optical devices.
j. ECCN: EAR99 Items subject to the EAR that are not elsewhere specified in this CCL
Category or in any other category in the CCL are designated by the number EAR99.
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specifies the type of information that falls under each of the nine exemptions that preclude
release of information to the public under the FOIA. In accordance with 5 U.S.C. § 552(a)(8),
DARPA will withhold records or information exempt from disclosure under the FOIA whenever
disclosure would harm an interest protected by a FOIA exemption or disclosure is prohibited by
law. The most relevant exemptions for Tellus are listed below; however other exemptions could
apply:
Exemption 3 – Protects information exempted from release by statute.
9. DISCLOSURE of CUI
Public Disclosure: Information generated during the Tellus program that does not clearly
identify as “CUI” (as described in Sections 6, 7 , 12 or Table 1) may still need to undergo review
prior to public release DoD information requested by the media or members of the public or
proposed for release to the public by DoD civilians or military personnel or their contractors will
be processed in accordance with DARPA Instruction 65 and DoD Instructions 5230.09, 5230.29;
Volume 3 of DoD Manual 5200.01; and DoD Manual 5400.07, as applicable. Proposed public
disclosures of unclassified information shall be submitted using the public release form located
at https://www.darpa.mil/work-with-us/contract-management/public-release.
FOIA Requests: All personnel with knowledge of this Project must coordinate with the
DARPA PSO prior to providing a response to requests for information under the provisions of
the FOIA.
Proprietary Information (PROPIN): Additional safeguards may become necessary if a
contract requires the transfer of PROPIN. The holder of the information must clearly identify any
and all PROPIN prior to its disclosure and release, the release will be coordinated with the
PROPIN owner.
Foreign Disclosure: Disclosure of DARPA CUI to foreign nationals will be coordinated
with the PSO, International Security, and International Cooperation. Disclosure approval must be
granted by the Director, Security and Intelligence Directorate (SID), who is the Foreign
Disclosure Officer (FDO) for DARPA.
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11. NOTIFICATION OF UNAUTHORIZED DISCLOSURE
Personnel must immediately report all unauthorized disclosures or suspected and known
security incidents, privacy breaches, and suspicious activities involving CUI to the Tellus PSO at
BTO_Security@darpa.mil.
Data breaches of DIB networks and systems involving Tellus CUI material must be
reported IAW DFARS 252.204-7012 requirements. In addition, all breaches must be reported to
the DARPA Project contracting officer and program security officer (PSO) upon discovery.
b. Articles controlled in paragraph (a), (b) and (c) of USML Category XIV
(https://www.ecfr.gov/current/title-22/chapter-I/subchapter-M/part-121)-
Toxicological Agents, Including Chemical Agents and Associated Equipment to
include:
e. The general military equipment listed under USML Category IV paragraphs (a) or
(b) explosives listed in ANNEX to Category 1 of explosives, or their detonation, when
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the detection of them is protected at CUI .
*If you plan to propose this line of research, contact the PM and PSO for
additional guidance prior to moving forward.
**If you plan to identify a specific isotope vs. an element or to identify that a
substance contains a radiation source please contact the PM and PSO for
additional guidance prior moving forward with research.
h. When a stimulus or combination of stimuli to be detected are not defined above, but
defined as CUI by your contract for OPSEC reasons.
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13. DEFINITIONS
14. ACRONYMS
BTO Biological Technologies Office
CCL Commerce Control List
CFR Code of Federal Regulations
CTI Controlled Technical Information
CUI Controlled Unclassified Information
CUIG Controlled Unclassified Information Guide
DARPA Defense Advanced Research Projects Agency
DFARS Defense Federal Acquisition Regulation Supplement
DIB Defense Industrial Base
DoD Department of Defense
DoDI Department of Defense Instruction
EAR Export Administration Regulations
ECCN Export Controlled Classification Number
FOIA Freedom of Information Act
ITAR International Traffic in Arms Regulations
IAW in accordance with
LDC Limited Dissemination Control
mG Milligray
mSv Millisievert
NIST National Institute of Standards and Technology
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OPSEC Operational Security
PM DARPA Program Manager
PSO Program Security Officer
PSR Program Security Representative
SID Security and Intelligence Directorate (DARPA)
USC United States Code
USML United States Munitions List
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15. INFORMATION PROTECTION GUIDANCE CHART
This chart (see Table 1 of the CUI Guide below) is provided to assist in identifying what
types of information within the Tellus CUIGs is protected as CUI, provide guidance on the
relevant markings for this information to control dissemination, and provide guidance on when
these dissemination controls no longer apply.
This chart is not all-encompassing and does not cover all information that may be
protected as CUI. Consult the CUI registry located at
http://www.archives.gov/cui/resgistry/category-list.html to verify information not addressed
below. If at any time there are questions regarding which category of information something falls
under, or what dissemination controls apply, individuals should request guidance from their
program PSR or the BTO PSO.
TABLE 1
CUI INFORMATION PROTECTION GUIDANCE CHART
LDC or
Element of Information Index Category Reason Distribution Remarks
Statement
a) Identification of N/A N/A N/A N/A Contact the PM and
naturally occurring PSO if you propose to
microbes, or conduct research with
biomolecular parameters or stimuli
components from that do not fall within
naturally occurring the BAA guidelines to
microbes, that react to a obtain additional
stimuli. guidance.
b) Identification of Defense, CTI; 48 CFR DISTRO CUI when the stimulus
microbes or Export EXPT; 252.204- C or F, IAW is listed in section 12
biomolecular Controlled EXPTR 7012 DoDI (see pages 9-10).
components (e.g., 50 USC 5230.24
proteins, nucleic acids, 4614(c) CUI when a stimulus or
genes, cellular combination of stimuli
compartments) that to be detected are not
enable the recording defined above but are
and/or transduction of a defined as such in your
stimulus. contract for OPSEC
reasons.
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N/A N/A N/A N/A UNCLASSIFIED if a
stimulus other than one
described in section 12
(pages 9,10) is being
detected.
c) The process, design, or Defense, CTI; 48 CFR DISTRO CUI when the stimulus
implementation of a Export EXPT; 252.204- C or F, IAW is listed in section 12
biosynthetic pathway to Controlled EXPTR 7012 DoDI (see pages 9,10).
create or change a 50 USC 5230.24
microbe’s ability to 4614(c)
detect, record and/or
transduce a stimulus. N/A N/A N/A N/A UNCLASSIFIED if a
stimulus other than one
described in section 12
(pages 9,10) is being
detected.
d) Identification of native N/A N/A N/A N/A This research is
microbes that survive UNCLASSIFIED.
or thrive in terrestrial or
maritime environments
under one or more
environmental
conditions identified in
the Tellus BAA Table 1
(i.e., hyperbaric,
corrosive, foliated,
biofouled, swamp,
murky, snow, dusty,
smoky).
e) Identification of native N/A N/A N/A N/A Contact the PM and
microbes that survive PSO before proposing
or thrive in terrestrial or or conducting this
maritime environments research.
under one or more
environmental
conditions that are
NOT identified in the
Tellus BAA (Table 1)
or in section 12 (pages
9,10).
f) Identification of native N/A N/A N/A N/A If the “EM cluttered
microbes that survive environment” is similar
or thrive in terrestrial or to that experienced near
maritime environments a cellphone tower,
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in EM-cluttered radio or TV station, the
conditions. research is
UNCLASSIFIED
fundamental research.
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affording ability to 50 USC DoDI
survive and remain 4614(c) 5230.24 UNCLASSIFIED when
functional for detecting not listed in section 12.
stimuli in different
environments or under
different environmental
conditions.
j) Engineering a microbe N/A N/A N/A N/A This research is
to reduce its ability to UNCLASSIFIED.
survive in the
environment should it
escape its encapsulant
or the system in which
it was embedded (i.e.,
biocontainment
strategies).
k) A functional microbial Defense, CTI; 48 CFR DISTRO CUI when the stimulus
device that exhibits any Export EXPT; 252.204- C or F, IAW is listed in section 12
combination of the Controlled EXPTR 7012 DoDI (see pages 9,10).
following: 50 USC 5230.24
Specific and sensitive 4614(c) Protect in accordance
detection of the stimulus. with any applicable
Functional in many of guidance assigned by
the environmental the PM and PSO.
conditions listed in the N/A N/A N/A N/A UNCLASSIFIED if a
“Microbial Device stimulus other than one
Parameters” table in the described in section 12
(pages 9,10) is being
BAA.
detected, or other
Production of an output guidance was provided
signal that is highly by the PM and PSO.
likely to be detectable
at Tellus’ target stand-
off distances.
l) Design, test, and Defense, CTI; 48 CFR DISTRO CUI when the stimulus
evaluation data Export EXPT; 252.204- C or F, IAW is listed in section 12
revealing details of Controlled EXPTR 7012 DoDI (see pages 9,10).
engineering that are 50 USC 5230.24
unique and essential to 4614(c) UNCLASSIFIED when
the Tellus program. not listed in section 12.
m) Tests and test results Defense, CTI; 48 CFR DISTRO CUI when the stimulus
revealing performance Export EXPT; 252.204- C or F, IAW is listed in section 12
capabilities of Tellus Controlled EXPTR 7012 DoDI (see pages 9,10) and in
devices (e.g., 50 USC 5230.24 accordance with row
sensitivity, specificity, 4614(c) (k) of this table.
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endurance,
environmental
tolerance).
Protect in accordance
with any applicable
guidance assigned by
the PM and PSO.
N/A N/A N/A N/A UNCLASSIFIED if a
stimulus other than one
described in section 12
(pages 9,10) is being
detected, or other
guidance was provided
by the PM and PSO.
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