PE-19(1): National Emissions Policies and Procedures

PE-19(1) requires you to protect system components, communications, and networks from compromising emissions (TEMPEST-style) in line with national Emissions Security policies, and to scale protections based on the security category/classification of the information. Operationalize it by scoping where emissions risk exists, applying required controls for the system’s classification, and retaining assessment-ready evidence. ¹

Key takeaways:

• Tie emissions protections to information classification/security category, not to a one-size-fits-all baseline. ¹
• Scope matters: include endpoints, network gear, cabling, and data communications paths that could radiate or conduct signals. ¹
• Evidence is the common failure mode; assign an owner, write a procedure, and produce recurring artifacts. ¹

The pe-19(1): national emissions policies and procedures requirement is easy to misread as a “facility-only” obligation or a specialized government problem you can ignore. Assessors usually evaluate it differently: they want to see that you identified where compromising emanations could expose sensitive information, then applied the right national Emissions Security policies and procedures for the system’s security category or classification. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat PE-19(1) like a classification-driven engineering requirement with clear governance: defined scope, a control owner, an implementation procedure, and evidence that the procedure runs. Your job is to coordinate Security Engineering, Network, Facilities (if applicable), and the Authorizing Official (or equivalent risk executive) so the organization can show consistent, repeatable protection of system components, associated data communications, and networks. ¹

This page focuses on getting you to “audit-ready” without guessing. It gives a practical interpretation, a step-by-step implementation sequence, the artifacts to retain, common assessor questions, and an execution plan you can assign tomorrow.

Requirement overview (what PE-19(1) is asking for)

PE-19(1) directs you to protect system components, associated data communications, and networks according to national Emissions Security policies and procedures, and to calibrate those protections based on the information’s security category or classification. ¹

“Emissions” here means unintentional signal leakage (radiated or conducted) that could let an adversary infer data from equipment, cabling, or communications paths. In practice, this turns into two compliance questions:

1. Did you identify where emissions exposure could exist across the system boundary?
2. Did you apply the correct national-level requirements for the classification/category involved, and can you prove it? ¹

Regulatory text

“Protect system components, associated data communications, and networks in accordance with national Emissions Security policies and procedures based on the security category or classification of the information.” ¹

Operator translation (what you must do):

• Protect components: endpoints, servers, network devices, and any equipment that processes or displays sensitive information must be included in scope. ¹
• Protect communications: include data paths and interfaces, not only “the network” logically. That means cabling, trunks, cross-connects, and remote access paths where signals could leak. ¹
• Follow national policy: you must align with the applicable national Emissions Security policy/procedure set your program is required to follow (often defined by the system’s authorizing chain or contract terms). The control expects traceability from that policy to your implemented safeguards. ¹
• Scale by classification/category: document how requirements differ for different sensitivity levels and show your system’s classification/category decision that drives the chosen protections. ¹

Plain-English interpretation

If sensitive data appears on a screen, travels over a cable, or is processed by equipment, assume there is some emissions risk until you’ve assessed it. PE-19(1) expects you to apply the right emissions safeguards for the data’s classification/security category and to manage it as a governed program requirement, not an ad hoc engineering preference. ¹

Who it applies to (entity and operational context)

Primary applicability

• Federal information systems implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data where NIST SP 800-53 controls are flowed down via contract, ATO requirements, or agency security requirements. ¹

Operational contexts where PE-19(1) commonly becomes “real”

• Classified or high-sensitivity processing spaces (including mission systems, operational technology enclaves, or sensitive program environments).
• Environments with strict zoning (secured rooms, controlled areas) where equipment placement and cabling are managed.
• Situations with shared walls, shared conduits, or colocated tenants where emissions could cross physical boundaries.

What you actually need to do (step-by-step)

1) Assign ownership and define scope boundaries

• Name a control owner (often Security Engineering or Physical Security with Network partnership) and a GRC point of contact responsible for evidence packaging.
• Define the system boundary: list in-scope locations, network segments, and component types (endpoints, servers, network gear, peripheral devices, cabling runs, wireless where applicable). ¹

Deliverable: PE-19(1) control implementation statement with scope language tied to the system boundary. ¹

2) Confirm information classification/security category that drives requirements

• Collect the formal basis for the system’s security category or classification and who approved it.
• Map data types and use cases to the places data is processed, displayed, and transmitted.

Assessor focus: if you cannot show the classification/category decision, you cannot justify the emissions protections selected. ¹

3) Identify applicable “national Emissions Security policies and procedures”

• Determine the authoritative policy set your environment must follow (usually specified by the authorizing organization, contract language, or internal security policy that incorporates national requirements).
• Translate that policy into implementable requirements (zoning, shielding, equipment standards, separation distances, cable handling rules, approval workflows).

Tip: Keep this as a short “policy-to-procedure mapping” table so the assessor can trace requirement → implementation → evidence. ¹

4) Perform an emissions risk scoping assessment

You are not expected to become an RF engineer as a GRC lead, but you must drive a repeatable assessment motion:

• Inventory: where sensitive information is processed/displayed/transmitted.
• Exposure points: perimeter walls, windows, shared conduits, unshielded cable runs, unmanaged wireless, remote KVM/display links, and any place signals might couple into other media.
• Threat model assumptions: define the kinds of adversaries and proximity assumptions used by your organization for this system’s classification.

Deliverable: a short emissions risk assessment memo or worksheet referenced in the SSP/control narrative. ¹

5) Implement controls appropriate to classification/category

Implementation is typically a combination of:

• Physical protections: controlled areas, equipment placement rules, shielding where required by policy, and facility change control.
• Communications protections: approved cabling types, cable routing constraints, separation requirements, protected conduits, and secure network design patterns for sensitive segments.
• Component controls: approved device lists for sensitive zones, configuration baselines, and restrictions on peripherals and display equipment.

Your “done” state is not “we bought a thing.” It is “we follow the national policy procedures for this classification, and we can show it happened.” ¹

6) Operationalize with procedures and recurring checks

Document and run:

• Installation/relocation procedure for equipment and cabling in sensitive areas.
• Change control gates: emissions-sensitive changes require security review sign-off.
• Periodic verification: spot checks that the environment still matches the approved design (locations, cabling paths, device types). Use the cadence your program can sustain; keep it consistent and evidenced.

7) Prepare the assessor packet (make evidence retrieval boring)

Most PE-19(1) failures are evidence failures. Create a single folder or GRC record with:

• implementation statement
• mapping to national policy
• assessment artifacts
• change tickets and approvals
• inspection/verification records ¹

Where Daydream fits: Use Daydream to map PE-19(1) to a named owner, a written implementation procedure, and recurring evidence artifacts so the control stays continuously assessable instead of rebuilt before each audit. ¹

Required evidence and artifacts to retain (minimum set)

Use this checklist to drive audit readiness:

Artifact	What it proves	Owner
PE-19(1) control narrative (SSP/control description)	Scope + how protections align to classification/category	GRC + Security
Classification/security category decision record	Why the control strength is appropriate	System owner/GRC
Policy-to-procedure mapping	Alignment to national Emissions Security policies/procedures	Security/GRC
Architecture diagrams (physical + logical)	Where components and comms exist; supports boundary claims	Network/Security
Emissions risk scoping assessment memo	You considered exposure points and tailored safeguards	Security Engineering
Change tickets with security approvals	Procedures run in operations	IT/Network/Facilities
Verification/inspection records	Ongoing adherence to approved design	Security/Facilities

(Expectation basis: PE-19(1) requires protection aligned to national policy and classification, which implies traceability and operational proof. ¹)

Common exam/audit questions and hangups

1. “What national Emissions Security policy are you following?” Have the named policy reference and your internal procedure mapping ready. ¹
2. “Show me what’s in scope.” Expect the assessor to challenge omitted areas like cabling, comms closets, remote access paths, and display devices. ¹
3. “How did classification/category change your implementation?” You need explicit tailoring logic, even if the result is “standard controls were sufficient for this category.” ¹
4. “Prove it operates.” Policies without tickets, inspections, or approvals read as shelfware.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Treating PE-19(1) as a facilities-only control. Fix: put Network and Security Engineering on the hook for comms and component design evidence. ¹
• Mistake: No written link to national policy. Fix: maintain a mapping table that an assessor can follow in minutes. ¹
• Mistake: Scope gaps around “associated data communications.” Fix: include the full data path, not only routers and switches; document cabling standards and routing constraints where required. ¹
• Mistake: Evidence scattered across teams. Fix: centralize the control packet and assign an evidence steward in GRC. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should plan for assessment-driven consequences (ATO delays, contract noncompliance findings, or required POA&M items) rather than citing specific penalties. The practical risk is exposure of sensitive information through unintended emissions paths, plus the program risk of failing an assessment due to missing traceability and operational evidence. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize governance and scope)

• Assign control owner and evidence steward; open a PE-19(1) control record in your GRC system. ¹
• Confirm system classification/security category and capture the approval record.
• Build the system boundary view: component inventory summary + network and physical diagrams.
• Identify the authoritative national Emissions Security policy source your program follows and draft the mapping table.

Days 31–60 (implement and document procedures that run)

• Complete an emissions risk scoping assessment focused on where sensitive data is processed/displayed/transmitted. ¹
• Publish procedures: equipment install/relocation, cabling/routing rules (as applicable), and security sign-off steps in change control.
• Train the teams that submit tickets (IT, Network, Facilities) on what triggers emissions review.

Days 61–90 (prove operation and get assessor-ready)

• Run the procedure on real changes (or validate past changes) and capture approvals and tickets as evidence.
• Perform a verification/inspection pass and log results with remediation items if needed.
• Assemble the assessor packet and do a tabletop “show me” walkthrough: classification → policy mapping → scope → implemented safeguards → operational records. ¹

Frequently Asked Questions

Does PE-19(1) apply if we only host cloud workloads?

It can, depending on your system boundary and where you process/display sensitive information. If endpoints, admin consoles, or network links are in scope, you still need to align protections to national Emissions Security policy requirements for the information category/classification. ¹

What will an assessor accept as “national Emissions Security policies and procedures” evidence?

They typically expect the named authoritative policy reference plus your internal procedures that implement it for the system. Keep a mapping table that links policy requirements to specific technical/physical procedures and evidence. ¹

We don’t handle classified information. Can PE-19(1) be “not applicable”?

Sometimes, but you must justify it based on the system’s security category/classification and documented risk rationale. Most programs still need a scoping statement and a record showing how you determined required protections. ¹

What’s the fastest evidence to gather if we’re behind?

Start with the classification/security category record, current network/physical diagrams, and change tickets that show security review for relevant installs or moves. Then draft the policy-to-procedure mapping and fill gaps with an emissions scoping assessment memo. ¹

Who should own this control: Facilities or Security?

Put primary ownership with Security (or Security Engineering) because the requirement covers components, data communications, and networks. Facilities is usually a key contributor for physical space controls and inspection records. ¹

How do we keep PE-19(1) from becoming a one-time paperwork exercise?

Tie it to operational workflows: change control gates for installs/moves, periodic verification, and centralized evidence capture. A GRC system like Daydream helps by keeping owners, procedures, and recurring artifacts linked to the control so evidence stays current. ¹

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5