GAO-11-352 Spectrum Management: NTIA Planning and Processes Need Strengthening to Promote the Efficient Use of Spectrum by Federal Agencies

Report to Congressional Committees

April 2011

SPECTRUM

MANAGEMENT

NTIA Planning and

Processes Need

Strengthening to

Promote the Efficient

Use of Spectrum by

Federal Agencies

GAO-11-352

United States Government Accountabilit

Office

GAO

United States Government Accountability Office

Accountability • Integrity • Reliability

Highlights of GAO-11-352, a report to

congressional committees

April 2011

SPECTRUM MANAGEMENT

NTIA Planning and Processes Need Strengthening to

Promote the Efficient Use of Spectrum by Federal

Agencies

Why GAO Did This Study

Radio frequency spectrum enables

vital wireless communications

services used by the federal

government, businesses, and

consumers. Spectrum capacity is

necessary for wireless broadband

(high-speed Internet access) and

broadband deployment will boost the

nation’s capabilities in many

important areas. As the demand for

spectrum continues to increase, there

is concern about adequate access to

meet future needs. This requested

report examines (1) how the National

Telecommunications and Information

Administration (NTIA) is managing

spectrum needs of federal agencies,

(2) how federal agencies are using

and managing assigned spectrum,

and (3) what steps NTIA has taken to

meet recent initiatives aimed at

making spectrum available for

broadband. GAO reviewed NTIA’s

spectrum management documents;

surveyed the 19 federal agencies

comprising the Interdepartment

Radio Advisory Committee; and

interviewed NTIA officials and

industry and academic experts.

What GAO Recommends

NTIA should develop an updated

strategic plan, examine its

assignment review processes to

determine if the current approach

can be improved, and establish

internal controls to ensure the

accuracy of agency-reported data.

The Department of Commerce

concurred with GAO’s

recommendation to examine the

review processes and, citing

competing priorities, partially

concurred with the remaining two.

What GAO Found

NTIA is responsible for governmentwide federal spectrum management, but

its efforts in this area have been limited. In 2003, the President directed NTIA

to develop plans identifying federal and national (both federal and nonfederal)

spectrum needs, and in 2008, NTIA issued the federal plan. GAO found this

plan has several limitations, does not identify governmentwide spectrum

needs, and does not contain key elements and best practices of strategic

planning. NTIA has yet to issue the national plan. Furthermore, NTIA’s

primary spectrum management operations do not focus on governmentwide

needs. Instead NTIA depends on agency self-evaluation of spectrum needs and

focuses on interference mitigation, with limited emphasis on holistic spectrum

management. Lacking a strategic vision, NTIA cannot ensure that spectrum is

being used efficiently by federal agencies. Additionally, NTIA’s data

management system is antiquated and lacks internal controls to ensure the

accuracy of agency-reported data, making it unclear if decisions about federal

spectrum use are based on reliable data. NTIA is developing a new data

management system, but full implementation of the system is years away.

Federal agencies use spectrum for many purposes such as emergency

communications and national defense, and NTIA requires the agencies to

periodically evaluate their current and future spectrum needs. Agencies are

supposed to ensure spectrum assignments fulfill established mission needs;

however, NTIA does not have specific requirements for agencies to justify

their spectrum assignments or validate data used for these evaluations.

Consequently, NTIA has limited assurance that the data used to make

spectrum management decisions are accurate. Federal agencies rely heavily

on their program offices to obtain data for the required evaluations and often

face challenges, such as resource constraints and staff turnover, when

coordinating with field program staff. Given that validating spectrum

assignments could require significant agency resources, it would be beneficial

for NTIA to consider options for a different approach to obtain and validate

critical spectrum assignment information from the agencies, such as requiring

agencies to conduct site surveys or attest to the accuracy of data they submit.

In response to recent initiatives, NTIA has taken steps to identify spectrum

that could be made available for broadband use. First, NTIA evaluated various

spectrum bands and identified 115 megahertz of spectrum that could be made

available for broadband within the next 5 years based on criteria it developed.

Second, NTIA developed an initial plan and timetable for evaluating and

repurposing additional spectrum for broadband use in 10 years. Affected

federal agencies—that is, those agencies operating devices in the spectrum

bands being evaluated—encountered difficulties providing NTIA with the

necessary data and analyses during the most recent evaluation. For example,

according to the affected agencies, they were required to analyze and submit a

significant amount of detailed impact analyses that were not readily available.

Agencies will likely continue to face challenges providing such analyses to

NTIA in the future as NTIA begins evaluating a larger number of spectrum

bands for possible broadband use in the next 10 years.

View GAO-11-352 or key components.

For more information, contact Mark Goldstein

at (202) 512-2834 or [email protected]

Page i GAO-11-352

Contents

Letter 1

Background 4

NTIA’s Strategic Spectrum Planning and Its Processes for

Managing Federal Spectrum Lack Governmentwide Focus and

Accountability 9

Federal Agencies Use Spectrum for Many Purposes, and Lack of

Specific Spectrum Management Requirements Leads to Limited

Assurance That Agencies Are Recording Accurate Data 20

NTIA Has Taken Steps to Identify Spectrum for Future Wireless

Broadband Use, yet NTIA and Federal Agencies Will Face

Challenges in Analyzing and Repurposing This Spectrum 28

Conclusions 37

Recommendations for Executive Action 38

Agency Comments and Our Evaluation 39

Appendix I Objectives, Scope, and Methodology 41

Appendix II Summary of NTIA Projects Focused on Reforming

Governmentwide Federal Spectrum Management

and Increasing the Efficiency and Effectiveness of

Federal Spectrum Use

Appendix III Survey of IRAC Agencies 48

Appendix IV Comments from the Department of Commerce 66

Appendix V GAO Contact and Staff Acknowledgments 71

Tables

Table 1: Federal Agency, IRAC, and NTIA Roles in the Frequency

Assignment and System Certification Processes 14

Table 2: Status of NTIA Spectrum Oversight Programs 16

nagement of Federally Assigned Spectrum

Table 3: NTIA Criteria for Prioritizing and Characterizing

Candidate Bands in the 10-Year Plan 30

Table 4: Status and Outcome of Bands Evaluated for Fast Track

Repurposing 33

Table 5: List of Experts and Industry Stakeholders We Contacted 42

Figures

Figure 1: Examples of Allocated Spectrum Uses, and Federal

Spectrum Use in the High-Value Range 5

Figure 2: NTIA Frequency Data Collection Processes 17

Figure 3: Federal Agencies with the Most Spectrum Assignments 21

Figure 4: Percent of Federally Assigned Spectrum Located in

Various Ranges 22

Figure 5: Number of Surveyed IRAC Agencies Reporting Various

Types of Spectrum Use 23

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nagement of Federally Assigned Spectrum

Abbreviations

CSEA Commercial Spectrum Enhancement Act

CSMAC

Commerce Spectrum Management Advisory Committee

DOD Department of Defense

FAA Federal Aviation Administration

FAS Frequency Assignment Subcommittee

FCC Federal Communications Commission

FSMS Federal Spectrum Management System

GHz gigahertz

GMF Government Master File

GOES-R Geostationary Operational Environmental Satellite-R series

IRAC Interdepartment Radio Advisory Committee

kHz kilohertz

MHz megahertz

NOAA National Oceanic and Atmospheric Administration

NTIA National Telecommunications and Information Administration

PPSG Policy Plans Steering Group

SPS Spectrum Planning Subcommittee

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Page iii

GAO-11-352

nagement of Federally Assigned Spectrum

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O-11-352

United States Government Accountability Office

Washington, DC 20548

April 12, 2011

The Honorable Fred Upton

Chairman

The Honorable Henry A. Waxman

Ranking Member

Committee on Energy and Commerce

House of Representatives

The Honorable John D. Rockefeller IV

Chairman

The Honorable Kay Bailey Hutchison

Ranking Member

Committee on Commerce, Science,

and Transportation

United States Senate

The Honorable Greg Walden

Chairman

The Honorable Anna G. Eshoo

Ranking Member

Subcommittee on Communications

and Technology

Committee on Energy and Commerce

House of Representatives

The radio frequency spectrum is a natural resource that is used to provide

an array of wireless communications services critical to the U.S. economy

and a variety of government functions, such as scientific research, national

defense, homeland security, and other vital public safety activities.

Spectrum capacity is necessary to deliver wireless broadband

consumers and businesses and also to support the communication needs

of industries that use commercial wireless broadband to transmit large

quantities of information quickly and reliably. Broadband deployment

stimulates economic growth, spurs job creation, and boosts the nation’s

capabilities in education, health care, homeland security, and other areas.

As the U.S. experiences significant growth in commercial wireless

The term “broadband” commonly refers to high-speed Internet access. Wireless broadband

connects a home or business to the Internet using a radio link.

Management of Federally Assigned Spectrum

broadband services, the demand for radio frequency spectrum has

increased and additional capacity will be needed to accommodate future

growth. As new spectrum-dependent technologies and services are

brought to the market and new mission needs unfold among government

users, Congress, industry stakeholders, and federal agencies expressed

concern about the availability of additional spectrum for future needs, and

that current spectrum management in the U.S. may not be able to respond

adequately to these rapidly changing needs. This is compounded by the

fact that not all radio frequency spectrum has equal value. The spectrum

most highly valued generally consists of frequencies between 300

megahertz (MHz) and 3 gigahertz (GHz), as these frequencies have

properties well suited to many important wireless technologies, such as

mobile phones, radio, and television broadcasting.

According to the

Department of Commerce’s National Telecommunications and

Information Administration (NTIA), as of December 2009, federal agencies

had exclusive access to about 18 percent of these high-value frequencies,

nonfederal users had exclusive licenses to about 30 percent, and access to

the remaining 52 percent is shared between federal and nonfederal users.

Within the federal government, NTIA is responsible for managing the

federal government’s use of the radio frequency spectrum, and the Federal

Communications Commission (FCC) is responsible for regulating

nonfederal spectrum use. Currently, there are federal government

initiatives under way aimed at identifying spectrum that can be made

available to meet the nation’s increased demand for commercial wireless

broadband services. For example, in March 2010, an FCC task force issued

the National Broadband Plan recommending that 500 MHz of spectrum

be made newly available for broadband use within the next 10 years,

and

Highly valued spectrum is sometimes called “beachfront” spectrum. For many mobile

radio systems, the 300 MHz to 3 GHz spectrum range is the portion of the spectrum where

scarcity concerns are the greatest. However, for some industry representatives, the

“beachfront” spectrum is larger, located anywhere between 100 MHz to 6 GHz. As

spectrum-dependent technologies improve over time, the definition of high-value spectrum

can change.

Karl Nebbia, Director NTIA Office of Spectrum Management, presentation to the

Commerce Spectrum Management Advisory Committee (CSMAC) (December 9, 2009).

These percentages represent how much of this spectrum is available (allocated) for use by

federal and nonfederal entities, not how much high-value spectrum is actually being used

or shared by these groups.

Federal Communications Commission, Connecting America: The National Broadband

Plan (Mar. 16, 2010).

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nagement of Federally Assigned Spectrum

in June 2010, the President issued a memorandum directing NTIA to begin

identifying federal spectrum that can be made available for wireless

broadband.

NTIA’s ability to implement these initiatives is important—

specifically its ability to identify spectrum needs of federal users, ensure

spectrum is being used efficiently, and develop policies to strategically

meet these needs while simultaneously providing federal agencies with

adequate access to spectrum to conduct their essential missions.

In response to your request and in light of the recent focus on federal use

of spectrum, we examined (1) the extent to which NTIA’s spectrum

management oversight and policy addresses governmentwide spectrum

needs, (2) how federal agencies are using assigned spectrum and the

extent to which they manage their spectrum use, and (3) what steps NTIA

and the federal agencies have taken to meet the requirements and

expectations of the National Broadband Plan and presidential

memorandum to repurpose spectrum for broadband,

and the challenges

these efforts face. While the focus of this report is on federal use of

assigned spectrum, we have ongoing work examining FCC’s oversight of

spectrum used by commercial entities.

Further, we expect to continue

reviewing issues related to spectrum management in the United States,

including what lessons have been learned from prior efforts to repurpose

spectrum from government to commercial entities and the extent to which

the government is collaborating with the private sector to understand their

spectrum needs.

To address these objectives, we obtained and reviewed NTIA documents,

including its Manual of Regulations and Procedures for the Federal Radio

Frequency Management (commonly referred to as the Redbook); an

assessment of spectrum bands that could possibly be repurposed for

wireless broadband (referred to as the Fast Track Evaluation); and other

documentation of NTIA’s current processes, policies, and procedures. To

develop an understanding of how federal agencies use and manage

spectrum, we conducted a Web-based survey of the 19 federal agencies

comprising the Interdepartment Radio Advisory Committee (IRAC), whose

agencies hold over 90 percent of federally assigned spectrum, and which is

See, Memorandum for the Heads of Executive Departments and Agencies, Unleashing the

Wireless Broadband Revolution, 75 Fed. Reg. 38387 (2010).

Repurposing, as defined by NTIA, refers to the altering of the use of spectrum from that

which is currently allowed to other or different uses.

We expect to issue this report in fall 2011.

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nagement of Federally Assigned Spectrum

responsible for coordinating federal use of spectrum and providing NTIA

policy advice on spectrum issues. The agency officials responding to the

survey were top-level spectrum managers. We received completed

responses from 18 of the 19 IRAC members; the results of our survey can

be found in appendix III. To supplement information from our survey, we

obtained documents from and interviewed top-level spectrum managers

from the following 10 federal agencies: Department of Defense (DOD),

Department of Homeland Security, Department of Labor, Environmental

Protection Agency, National Oceanic and Atmospheric Administration

(NOAA), U.S. Coast Guard, Federal Aviation Administration (FAA),

Department of Health and Human Services, Department of Housing and

Urban Development, and Department of the Treasury. We selected these

federal agencies to achieve a mix of characteristics for various factors,

such as the number of spectrum assignments, representation on IRAC,

particular band of spectrum holdings, and mission needs. We also

interviewed officials from NTIA’s Office of Spectrum Management about

their spectrum management policies and procedures and interviewed

stakeholders with knowledge of spectrum issues including industry and

academic experts, and representatives of an industry association and

telecommunications companies. We selected the experts and industry

stakeholders based on prior published literature, stakeholders’ recognition

and affiliation with the spectrum management industry, and NTIA and

other stakeholders’ recommendations.

We conducted this performance audit from May 2010 to April 2011 in

accordance with generally accepted government auditing standards. Those

standards require that we plan and perform the audit to obtain sufficient

appropriate evidence to provide a reasonable basis for our findings and

conclusions based on our audit objectives. We believe that the evidence

obtained provides a reasonable basis for our findings and conclusions

based on our audit objectives.

The radio frequency spectrum is the part of the na

tural spectrum of

electromagnetic radiation lying between the frequency limits of 3 kilohertz

(kHz) and 300 GHz.

Federal agencies use spectrum to help meet a variety

Background

Radio signals travel through space in the form of waves. These waves vary in length, and

each wavelength is associated with a particular radio frequency. Radio frequencies are

grouped into bands and are measured in units of Hertz. The term kHz refers to thousands

of Hertz, MHz to millions of Hertz, and GHz to billions of Hertz. The Hertz unit of

measurement is used to refer to both the quantity of spectrum (such as 500 MHz) and the

frequency bands (such as the 1710–1755 MHz band).

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nagement of Federally Assigned Spectrum

of missions, such as national defense, law enforcement, weather services,

and aviation communication. Nonfederal entities (which include

commercial companies and state and local governments) also use

spectrum to provide a variety of services. For example, state and local

police departments, fire departments, and other emergency services

agencies use spectrum to transmit and receive critical voice and data

communications, while commercial entities use spectrum to provide

wireless services, including mobile voice and data, paging, broadcast radio

and television, and satellite services. See figure 1 for examples of how

spectrum is used.

Figure 1: Examples of Allocated Spectrum Uses, and Federal Spectrum Use in the High-Value Range

kHz

300

kHz

MHz

300

MHz

GHz

300

GHz

300

Maritime

navigation

signals

Navigational

aids

AM radio,

Maritime

radio

Shortwave

radio

Broadcast

television, FM radio,

navigational aids

Space and satellite

communications,

microwave systems

Radio

astronomy

Broadcast

television,

cellular telephone

Marine animal

tracking

Meteorological

satellites

DOD missile

detection/ surveillance

radar

Meteorological

aids

Maritime mobile

satellite and

radio navigation

Space operations

and research

Frequency

Examples of

allocated

uses

Aeronautical

radio navigation

Land mobile

radio

Forest Service

communication for

law enforcement

and wild fires

Source: GAO analysis of NTIA, federal agencies, and industry information.

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nagement of Federally Assigned Spectrum

In the United States, responsibility for spectrum management is divided

between NTIA and FCC.

NTIA and FCC jointly determine the amount of

spectrum allocated for federal, nonfederal, and shared use.

After this

allocation occurs, in order to use spectrum, nonfederal users must obtain

a license from FCC to use specific spectrum frequencies, and federal users

must obtain a similar authorization from NTIA—usually referred to as a

frequency assignment. In addition to its spectrum allocation and

authorization duties, NTIA serves as the President’s principal advisor on

telecommunications and information policy and manages federally

assigned spectrum, including preparing for, participating in, and

implementing the results of international radio conferences, as well as

conducting extensive research and technical studies through its research

and engineering laboratory, the Institute for Telecommunication Sciences.

NTIA has authority to issue rules and regulations as may be necessary to

ensure the effective, efficient, and equitable use of spectrum both

nationally and internationally. It also has authority to develop long-range

spectrum plans to meet future government spectrum requirements,

including those of public safety.

In addition to NTIA and FCC, there are other entities involved in spectrum

management:

• The Office of Management and Budget (OMB) is involved in managing

agency spectrum use through the budget process. OMB’s Circular A-11,

Section 33.4, directs agencies to consider the economic value of spectrum

when requesting funding to procure a spectrum-dependent system. The

circular states that spectrum should generally not be considered a free

resource, but rather should be considered to have value and be included,

to the extent practical, in economic analyses of alternative systems.

The Department of State also plays a role in spectrum management by coordinating and

mediating the U.S. position and leading the nation’s delegation to international conferences

on spectrum management.

Allocation involves segmenting the radio spectrum into bands of frequencies that are

designated for use by particular types of radio services or classes of users. For example,

the frequency bands between 88 and 108 MHz are allocated to FM radio broadcasting in the

United States, while frequency bands between 300 and 322 MHz are government exclusive

bands allocated for mobile, mobile satellite, and fixed

radio use. In addition to allocation,

NTIA and FCC also specify service rules, which include the technical and operating

characteristics of equipment.

OMB Circular No. A-11, Preparation, Submission and Execution of the Budget, §33.4,

Radio-Spectrum Dependent Communications-Electronic Systems (July 2010).

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nagement of Federally Assigned Spectrum

• IRAC—an interagency advisory committee—was established in 1922 to

coordinate federal use of spectrum and provide policy advice on spectrum

issues. It is comprised of representatives from 19 federal agencies that use

spectrum. IRAC’s mission and placement have evolved over its 80-year

history. IRAC was originally organized by federal agencies that were

seeking a way to resolve issues related to federal spectrum use in a

cooperative manner; its initial mission was to assist in the assignment of

radio frequencies to federal users and to coordinate federal government

spectrum use. In 1952, its mission was expanded to include formulating

and recommending policies, plans, and actions for federal government

spectrum use. Currently, IRAC is primarily involved in the frequency

assignment and system certification processes and is chaired by NTIA,

whose role as chair is to call IRAC meetings, establish IRAC agendas, and

manage other tasks associated with the administrative operations of IRAC.

• The Commerce Spectrum Management Advisory Committee (CSMAC)—a

federal advisory committee—provides advice and recommendations to

NTIA. This advisory committee is organized through NTIA’s Office of

Policy Analysis and Development and was created following a

recommendation made in President Bush’s 21st Century Spectrum Policy

Initiative.

CSMAC consists of approximately 25 spectrum policy experts

from the private sector and it offers expertise and perspective on long-

range spectrum planning, as well as other issues, and makes

recommendations to NTIA to facilitate this planning.

CSMAC was

organized in 2006, and operates under the provisions of the Federal

Advisory Committee Act.

Currently, there are three ongoing spectrum-related initiatives aimed at

identifying spectrum that can be made available to meet the nation’s

Presidential Memorandum on Spectrum Policy for the 21st Century, 69 Fed. Reg. 1568

(Jan. 9, 2004). Pursuant to this directive, NTIA issued two reports. See, Department of

Commerce, Spectrum Policy for the 21st Century – The President’s Spectrum Policy

Initiative: Report 1, Recommendations of the Federal Government Spectrum Task Force

(June 2004) and Department of Commerce, Spectrum Policy for the 21st Century – The

President’s Spectrum Policy: Report 2, Recommendations from State and Local

Governments and Private Sector Responders (June 2004). In a subsequent memorandum,

the President provided guidance for the recommendations’ implementation. See,

President’s Memorandum on Improving Spectrum Management for the 21st Century, 49

Weekly Comp. Pres. Doc. 2875,) (Nov. 29, 2004).

NTIA designates an employee of NTIA to serve as the Designated Federal Officer for

CSMAC.

5 U.S.C. App. 2.

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nagement of Federally Assigned Spectrum

demand for commercial wireless broadband services. These initiatives

include (1) a recommendation in the National Broadband Plan, (2) a June

28, 2010, presidential memorandum, and (3) the NTIA Fast Track

Evaluation.

• The National Broadband Plan recommends that a total of 500 MHz of

federally and nonfederally allocated spectrum be made available for

mobile, fixed, and unlicensed broadband use over the next 10 years. This

spectrum can come from several different frequency ranges and would be

made available for a variety of licensed and unlicensed flexible

commercial uses, as well as to meet the broadband needs of specialized

users such as public safety, energy, educational, and other users. The plan

states that for spectrum from the 225 MHz to 3.7 GHz range, a total of 300

MHz should be made available for mobile flexible use within 5 years.

• On June 28, 2010, the President issued a memorandum directing NTIA to

begin identifying federally allocated spectrum that can be made available

for wireless broadband. This memorandum, in line with the National

Broadband Plan, directs NTIA to collaborate with FCC to develop a plan

and timetable to make the 500 MHz of federally and nonfederally allocated

spectrum available for wireless broadband use in the next 10 years.

• A joint request from OMB, the National Economic Council, and the White

House’s Office of Science and Technology Policy requested that NTIA

identify and make available federally allocated spectrum for broadband

use in the next 5 years. In response to this request, NTIA analyzed

federally assigned spectrum to determine the feasibility of making certain

federally allocated spectrum bands available for broadband use, referred

to as the Fast Track Evaluation.

In addition, legislation has also been introduced in the House and Senate

that would help identify spectrum or relocate spectrum for commercial

uses, including (1) the Spectrum Inventory and Auction Act of 2011,

and

the (2) Reforming Airwaves by Developing Incentives and Opportunistic

NTIA, An Assessment of the Near-Term Viability of Accommodating Wireless

Broadband Systems in the 1675-1710 MHz, 1755-1780 MHz, 3500-3650 MHz, and 4200-

4220 MHz, 4380-4400 MHz Bands (October 2010).

H.R. 911, 112th Cong. (2011). Among other things, the bill includes provisions on

voluntary incentive auctions.

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nagement of Federally Assigned Spectrum

Sharing Act,

which would require an inventory of existing users on prime

radio frequencies; (3) the Spectrum Optimization Act,

which would

provide FCC with authority to conduct incentive auctions; and (4) the

Spectrum Relocation Improvement Act of 2011,

which would clarify the

rights and responsibilities of federal users in the spectrum relocation

process.

NTIA’s Strategic

Spectrum Planning

and Its Processes for

Managing Federal

Spectrum Lack

Governmentwi

Focus and

Accountability

NTIA Has Conducted

Spectrum Planning, yet Its

Efforts to Address

Strategic Governmentwide

Spectrum Management

Have Lacked Continuity

As the federal agency au

thorized to develop national spectrum policy,

NTIA has been directed to conduct several projects focused on reforming

governmentwide federal spectrum management and promoting efficiency

among federal users of spectrum; however, its efforts in this area have

resulted in limited progress toward improved spectrum management.

NTIA has authority to, among other things, establish policies concerning

assigning spectrum to federal agencies, coordinate spectrum use across

federal agencies, and promote efficient use of spectrum resources by

federal agencies in a manner which encourages the most beneficial public

use. As such, NTIA has a role in ensuring that federally allocated spectrum

is used efficiently. According to NTIA’s Redbook and agency officials,

S. 455, 112th Cong. (2011). Among other things, the bill includes provisions to modify the

Spectrum Relocation Fund; provide for voluntary incentive actions; and require the

development of a triennial national strategic spectrum plan.

S. 415, 112

Cong. (2011).

S. 522, 112th Cong. (2011).

The NTIA Organization Act, 47 U.S.C. §§ 901 et seq.

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nagement of Federally Assigned Spectrum

efficient use includes ensuring that federal agencies’ decisions to use

spectrum to support government missions have been adequately justified

and that all viable tradeoffs and options have been explored before making

the decision to use spectrum-dependent technology, and ensuring that

these tradeoffs are continuously reviewed to determine if the need for

spectrum has changed over time. NTIA’s primary guidance to federal

agencies is technical guidance concerning how to manage assigned

spectrum provided through NTIA’s Redbook.

In May 2003, the Bush Administration directed NTIA to develop two

strategic plans, yet it has only completed one. At that time, the Bush

Administration launched the Spectrum Policy Initiative for the 21st

Century, which recognized the rapidly increasing role for wireless services

and demands on the use of the radio frequency spectrum. In response to

this initiative, NTIA stated it would produce two plans.

• First, NTIA would produce a federal strategic spectrum plan to address

governmentwide spectrum needs. Specifically, the Bush Administration

directed federal agencies to develop individual strategic spectrum plans,

which would then be compiled by NTIA along with input from other

stakeholders such as FCC and state and local governments, to form a

governmentwide strategic spectrum plan.

• Second, NTIA was to use the federal strategic spectrum plan to assist in

developing a national spectrum plan to address comprehensive federal and

nonfederal spectrum needs.

NTIA responded to this directive by stating it

would produce a national spectrum plan, and encourage state, regional,

and local government agencies to synthesize long-range planning

processes into a nonfederal government strategic spectrum plan which

would also provide input into the national strategic spectrum plan.

Additionally, NTIA stated that it would invite FCC to provide information

Under the November 2004 presidential memorandum, the Department of Commerce was

tasked with integrating the agency-specific spectrum plans and spectrum needs plan based

upon a Department of Commerce framework into a federal spectrum plan and to assist in

the formulation of a national strategic spectrum plan. The Secretary of Commerce, in

consultation with FCC, as appropriate, was to update the national strategic spectrum plan

on a biennial basis. President’s Memorandum on Spectrum Management for the 21

Century, § 3(a).

This is not the first experience NTIA has had with developing a forward looking strategic

plan. In September 2000, it issued a long-range plan. See Department of Commerce,

National Telecommunications and Information Administration, Federal Long-Range

Spectrum Plan (September 2000).

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nagement of Federally Assigned Spectrum

regarding the future requirements of nonfederal government spectrum to

be included in the national strategic spectrum plan.

In March 2008, NTIA issued its report on federal spectrum use entitled The

Federal Strategic Spectrum Plan.

Neither NTIA nor FCC has issued the

national spectrum plan that was initially scheduled for completion in

December 2007.

While the intent of the Federal Strategic Spectrum Plan was to identify

the current and projected spectrum requirements and long-range planning

processes for the federal government, we found the final plan is limited in

these areas. For example, the plan does not identify or include quantitative

governmentwide data on federal spectrum needs. Instead, NTIA’s plan

primarily consists of a compilation of the plans submitted by 15

of the

more than 60 agencies that use federal spectrum. Additionally, due to the

fact that they contained limited information regarding future requirements

and technology needs, NTIA concluded that its “long-range assumptions

are necessarily also limited.”

Furthermore, NTIA’s plan did not contain key elements and best practices

of strategic planning, which the Government Performance and Results Act,

OMB, and we have identified as including the following elements:

Department of Commerce, National Telecommunications and Information

Administration, Spectrum Management for the 21

Century: Plan to Implement

Recommendations of the President’s Spectrum Policy Initiative (2006).

Department of Commerce, National Telecommunications and Information

Administration, Spectrum Policy for the 21

Century – The President’s Spectrum Policy

Initiative: The Federal Strategic Spectrum Plan (March 2008).

In the fiscal year 2008 progress report, NTIA noted that it sent a letter to FCC in June 2008

seeking FCC participation, but that the expected completion date was to be determined.

The agencies that submitted strategic spectrum plans include the Departments of

Agriculture, Commerce, Defense, Energy, Homeland Security, Interior, Justice, State,

Transportation, Treasury, and Veterans Affairs; the National Aeronautics and Space

Administration, National Science Foundation, Broadcasting Board of Governors, and the

U.S. Postal Service. In September 2010, these agencies held over 80 percent of federal

frequency assignments.

See Government Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285

(1993); Office of Management and Budget, Cir. No. A-11, Preparation, Submission and

Execution of the Budget, Part 6-Prepation and Submission of Strategic Plans, Annual

Performance Plan, and Annual Program Performance Reports (July 2010); and GAO,

Agencies’ Strategic Plans Under GPRA: Key Questions to Facilitate Congressional

Review, GAO-GGD-10.1.16 (Washington, D.C.: May 1997).

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• identification of long-term goals and objectives,

• approaches or strategies to achieve these goals and objectives,

• program evaluations,

• stakeholder involvement, and

• an ongoing process for revising the plan approximately every 3 years.

For example, NTIA’s plan does not include a discussion of long term goals

and objectives for governmentwide spectrum management, or approaches

and next steps for achieving these goals. Also, whereas strategic planning

is intended to be continuous, not a static or occasional event, we found

that NTIA’s strategic planning activities are not ongoing. For example,

while agencies were required to update their strategic plans every 2 years,

they have not submitted plans to NTIA since November 2007, when 14

agencies submitted plans.

We found that NTIA does not appear to be meeting its responsibilities as

directed by President Bush’s 2004 memorandum. As shown in appendix II,

NTIA discontinued many of the governmentwide projects initiated by the

Spectrum Policy Initiative for the 21st Century, demonstrating a lack of

continuity in its spectrum management operations. For example, NTIA

was directed to issue annual progress reports on the status of the

initiatives. While NTIA issued four annual progress reports from fiscal

years 2005 through 2008, these reports focused on detailing the individual

activities agencies have undertaken to improve their spectrum

management and provided limited information on actions NTIA is taking

to improve governmentwide use of spectrum. Furthermore, NTIA has not

issued a progress report since fiscal year 2008.

We asked NTIA officials

why the agency was not implementing many of the presidential initiatives,

and they said due to limited resources the agency has decided to put its

Of the original 15 agencies to submit plans in 2005, the Departments of the Interior and

State did not resubmit plans in 2007. While it did not submit a plan in 2005, the U.S. Coast

Guard submitted a plan in 2007.

The November 2004 presidential memorandum directed the Secretary of Commerce

within 6 months of the issuance of the memorandum to provide the President a report

describing the progress on implementing the recommendations in the reports and to

update this report on an annual basis until completion of the actions required by the

memorandum. President’s Memorandum on Improving Spectrum Management for the 21st

Century, §3(c).

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strategic planning activities on hold, and has instead turned its focus to

recent initiatives directed by the Obama Administration.

Based on our

conversations with NTIA officials, it is unclear when or if NTIA will

resume its forward-looking strategic planning activities. See appendix II

for a full list of NTIA activities focused on reforming governmentwide

spectrum management and the status of the activities as of February 2011.

NTIA’s Current Processes

for Managing Federal

Spectrum Focus on

Interference Mitigation

NTIA’s primary spectrum m

anagement operations include authorizing

federal frequency assignments and certifying spectrum-dependent

equipment for federal users; however, these processes are primarily

focused on interference mitigation as determined by IRAC and do not

focus on ensuring the best use of spectrum across the federal

government.

IRAC, an interagency committee of the federal government’s

primary spectrum users, includes six subcommittees and several ad hoc

working groups.

Two IRAC subcommittees play significant roles in two

of NTIA’s key processes—frequency assignment and system certification.

These subcommittees, the Frequency Assignment Subcommittee (FAS),

which includes representatives from the 19 IRAC agencies and FCC, and

the Spectrum Planning Subcommittee (SPS), which includes

representatives from 17 of the IRAC agencies, review all requests for new

spectrum assignments by federal agencies and make recommendations to

NTIA on the outcomes.

As shown in table 1, final decisions regarding

On February 10, 2011, the Obama Administration launched another initiative aimed at

expanding wireless coverage to 98 percent of Americans. NTIA officials told us they

anticipate this initiative will result in additional directives for the agency.

Interference mitigation refers to ensuring that systems are not interfering with each other.

IRAC consists of representatives of the following departments and agencies: Agriculture,

Air Force, Army, Broadcasting Board of Governors, Coast Guard, Commerce, Energy,

Federal Aviation Administration, Homeland Security, Interior, Justice, National

Aeronautics and Space Administration, National Science Foundation, Navy, State,

Transportation, Treasury, U.S. Postal Service, Veterans Affairs. Nonmember departments

and agencies may designate one of the members to act as their accredited agent on IRAC.

The Department of the Treasury acts as the accredited agent for the Department of

Education, Federal Reserve System, and Small Business Administration. The Department

of the Interior acts as the accredited agent for the International Boundary and Water

Commission (U.S. Section) and the Tennessee Valley Authority. The Federal Aviation

Administration acts as the accredited agent for the Volpe National Transportation Systems

Center. NTIA acts as the accredited agent for all other nonmember agencies with spectrum

requirements.

The U.S. Postal Service and Department of Transportation are not members of the SPS.

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nagement of Federally Assigned Spectrum

approval and use of federally allocated spectrum are made based on IRAC

review and committee consensus.

Table 1: Federal Agency, IRAC, and NTIA Roles in the Frequency Assignment and System Certification Processes

Activity

Role of agency requiring/

using

spectrum

Role of IRAC

Role of NTIA Office of Spectrum

Management

Frequency

assignment

process

• Determine need for spectrum and

receive authorization to use a

specific frequency prior to

operating a spectrum- dependent

technology.

• Make necessary technical studies,

select potential frequencies,

coordinate with other agencies

involved, and prepare and file an

application with NTIA’s Office of

Spectrum Management for

consideration by the FAS.

• FAS considers pending items

on a daily basis.

• Makes decision within 9-days to

approve request or table for

further review, correction, or

referral to a formal meeting of

the FAS.

• Processes applications through

a series of automated routines to

check them for completeness,

accuracy, and compliance with

regulations in procedures.

• Publishes applications in daily

agenda for FAS review.

• Conducts manual review, with

assistance from FAS, to ensure

adequate justification,

compliance with policy and

regulations, and technical

appropriateness, and to ensure

there is no conflict with FAS

nonmember agencies.

• Makes final decisions on matters

that cannot be resolved within

the FAS. (Final NTIA decisions

can be appealed to the Director

of the Office of Management and

Budget.)

System

certification

process

• As required by OMB Circular A-

11, agencies must obtain

certification by NTIA that the radio

frequency required can be made

available before submission of

estimated costs for the

development of procurement of

“major radio spectrum-dependent

systems” (including all systems

employing space satellite

techniques).

• Makes a determination as to

whether a system is “major” as

defined by having a “significant

impact on existing or potential

future use of the radio frequency

spectrum,” and whether or not to

seek certification.

• SPS conducts review of new

spectrum-dependent systems at

a number of stages of their

evolution, prior to the

assignment of frequencies.

These reviews require an

examination of the existing

systems in the frequency bands

being considered to ensure that

new systems will not interfere

with existing systems.

• Makes recommendations to

NTIA on whether a new system

should be certified for

operational use.

• Based on SPS recommendation,

makes final decision to approve

or disapprove certification.

Source: GAO presentation of Redbook policies and additional NTIA and agency data.

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nagement of Federally Assigned Spectrum

Currently the process as established by federal regulations for review and

approval of frequency assignment and system certification is technical in

nature, focusing on ensuring that the new frequency or system that an

agency wants to use will not interfere with another agency’s operations.

According to NTIA officials, this focus on day-to-day spectrum activities,

such as interference mitigation, is due to the agency’s limited resources.

This focus, while important, makes limited consideration about the overall

best use of federally allocated spectrum. Therefore, NTIA’s current

processes provide limited assurance that federal spectrum use is evaluated

from a governmentwide perspective to ensure that decisions will meet the

current and future needs of the agencies, as well as the federal

government as a whole. Additionally, throughout these processes, there is

heavy reliance on agencies to self-evaluate and report their current and

future spectrum needs. For example, in the frequency assignment process,

all analysis to determine whether spectrum-dependent technology should

be used is made by the agencies prior to a request for authorization,

therefore agencies are expected to have adequate expertise and resources

to make these determinations.

Finally, NTIA has limited ability to monitor federal spectrum use. NTIA

has four programs in place to oversee agency use of spectrum, yet

according to NTIA officials, only one program is actively implemented,

one is conducted on an as-needed basis, and two programs have been

discontinued due to lack of resources, as shown in table 2. Without

ongoing programs to monitor that agencies are using their assigned

spectrum in accordance with federal regulations, NTIA is limited in its

ability to track how federally allocated spectrum is being used or detect

Redbook violations.

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nagement of Federally Assigned Spectrum

Table 2: Status of NTIA Spectrum Oversight Programs

Program name Objective Status

Frequency Assignment

Review Program

Federal agencies are required to

review frequency assignment data

every 5 years to ensure that frequency

assignments are (1) in current use and

are correctly reflected in the

Government Master File (GMF), (2)

required for continued operations for

the purposes stated in their

justifications, and (3) still qualified for

authorizations under the provisions of

the Redbook.

Currently ongoing.

Spectrum

Measurement Program

Established in 1973 under which a

van-mounted Radio Spectrum

Measurement System operated by

NTIA is used to determine (1) whether

radio installations operated by the

federal government are using

authorized frequencies and are

operating in accordance with

applicable regulations, (2) whether

additional uses can be made in a

particular band at a particular location,

and (3) to prevent or resolve cases of

interference between two or more

users.

Conducted as-

needed for research

purposes.

Spectrum Management

Survey Program

Established in 1965 to determine at

the operational level the degree of

implementation of the applicable

provisions of the Redbook, whether

frequency usage is in accordance with

authorizations, and to exchange

information with a view toward

improving spectrum management.

NTIA personnel conduct on-site

surveys to observe facilities and

conduct discussions with local

frequency managers.

Discontinued due to

resource

constraints.

Spectrum Resource

Assessment Program

Program to review and document the

characteristics and deployment of

existing and proposed systems, to

identify potential band-sharing

problems which may impact the

efficient use of the spectrum.

Discontinued due to

resource

constraints.

Source: GAO analysis of NTIA data.

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nagement of Federally Assigned Spectrum

NTIA’s Data Management

System Lacks

Transparency and Data

Validation Processes,

Making It Uncertain If

Spectrum Management

Decisions Are Based on

Accurate and Complete

Data

NTIA’s data management system is antiquated and lacks transparency and

internal controls. NTIA collects all federal spectrum data in the

Government Master File (GMF), which according to NTIA officials is an

outdated legacy system that was developed primarily to store descriptive

data. This system does not meet the current analytical needs of NTIA or

other federal users. NTIA does not generate any data, but maintains

agency-reported spectrum data in the GMF, which are collected during the

frequency assignment and review processes, as shown in figure 2.

Figure 2: NTIA Frequency Data Collection Processes

Agency program office

Local program office contacts regional spectrum manager

or agency spectrum manager to request frequency

assignment. Program office submits request and data

describing use and spectrum need to spectrum manager.

NTIA

NTIA contacts agency spectrum managers notifying them

of required 5-year review.

Agency spectrum manager

Agency spectrum managers notify program office to

complete 5-year review. Program office must confirm that

information in Government Master File record is still accurate.

Agency program office

Agency program office completes data review of assignment

and updates assignment record. Program office sends

agency spectrum manager updated information.

Agency spectrum manager

Reviews updated information to ensure it is technically

complete. Federal agencies are not required to validate or

verify assignment before submitting to NTIA.

NTIA

NTIA updates Government Master File to show that record

has been reviewed and updated. NTIA does not validate

that data submitted are accurate. NTIA enters data

Agency spectrum manager

Coordinates with program office on spectrum assignment

application and submits application to NTIA.

NTIA

Coordinates with agency spectrum manager and finalizes

spectrum assignment application before submitting to

FAS. NTIA conducts technical checks to ensure data have

been entered correctly into system and that all necessary

fields have been completed. NTIA does not validate that

data submitted by agency are accurate.

NTIA

NTIA enters data into Government Master File database

Frequency assignment application Frequency assignment review process

Source: GAO analysis of NTIA information.

Information is sent to NTIA.

Government Master File.

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nagement of Federally Assigned Spectrum

NTIA’s processes for collecting and verifying GMF data lack key internal

controls including those focused on data accuracy, integrity, and

completeness. We have defined internal control activities as the policies,

procedures, techniques, and mechanisms that help ensure that agencies

mitigate risk.

Control activities such as data verification and

reconciliation are essential for ensuring accountability for government

resources and for achieving effective and efficient program results.

Additionally, the standards for internal controls recommend that agency

systems have controls in place to ensure data accuracy, including

processes for ensuring

• the agency’s data entry design features contribute to data accuracy;

• data validation and editing are performed to identify erroneous data;

• erroneous data are captured, reported, investigated, and promptly

corrected; and

• output reports are reviewed to help maintain data accuracy and validity.

We found that NTIA’s data collection processes lack accuracy controls and

do not provide assurance that data are being accurately reported by

agencies. For example, the data are generally only subject to compliance

reviews that ensure all reported data meet technical and database

parameters (i.e., that they have the proper number of characters per field,

or that the frequency requested is allocated for desired use). Throughout

this process, NTIA expects federal agencies to supply accurate and up-to-

date data submissions. For example, during the frequency assignment

process, a federal agency must justify that the assignment will fulfill an

established mission need and that other means of communication, such as

commercial services, are not appropriate or available. However, NTIA

does not provide agencies with specific requirements on how to justify

these needs. NTIA officials told us that they rely on federal agencies to

conduct any necessary analysis, such as engineering and technical studies,

to support the use and need of the assignment, but agencies are not

required to submit documentation verifying that the agency had completed

the analysis necessary to justify the agency’s spectrum need. Moreover,

NTIA does not require federal spectrum managers to validate or verify that

the data or information program offices do submit is accurate. According

GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington,

D.C.: August 2001).

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nagement of Federally Assigned Spectrum

to NTIA officials, if NTIA or other agencies identify errors, NTIA requires

the correction of these data. However, since agencies submitting data do

not have to attest to their accuracy or demonstrate the extent to which

they are actually using the spectrum which they have, NTIA has limited

assurance that information used to make spectrum management decisions

is accurate and reliable.

NTIA is developing a new data management system—Federal Spectrum

Management System (FSMS)—to replace GMF. According to NTIA

officials, the new system will modernize and improve spectrum

management processes by applying modern information technology to

provide more rapid access to spectrum and make the spectrum

management process more effective and efficient. Whereas the GMF is

only a descriptive database used to store information, it does not have

analytical capabilities that agencies can use when they are conducting the

technical studies required by the frequency assignment and certification

processes. FSMS is intended to provide these analytical capabilities and

will allow federal agencies to conduct more consistent and accurate

analysis when developing frequency assignment proposals. Ultimately this

will facilitate the more efficient use of spectrum because frequency

assignments can be located closer together. Currently, the limited data

available on frequency assignments results in users overestimating their

needs to avoid interference; the additional data that will be made available

will allow users to make more accurate judgments when determining

interference.

As part of the development of FSMS, the existing GMF data

will be replaced with a new data structure, yet development is still early

and final implementation is not expected until fiscal year 2014. FSMS will

increase the amount of data agencies are required to submit to NTIA, but

the data submission process will remain similar to its current structure.

NTIA projects FSMS will improve existing GMF data quality, but not until

2018. According to NTIA’s FSMS transition plan, at that time data accuracy

will improve by over 50 percent. However, in the meantime it is unclear

whether important decisions regarding current and future spectrum needs

are based on reliable data.

The agency practice of overestimating needs is due to the fact that more detailed data is

not available. The extent to which agencies overestimate their needs is unclear.

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nagement of Federally Assigned Spectrum

Federal Agencies Use

Spectrum for Many

Purposes, and Lack of

Specific Spectrum

Management

Requirements Leads

to Limited Assurance

That Agencies Are

Recording Accurate

Data

Federal Agencies Use

Spectrum for a Wide

Variety of Purposes, such

as Emergency

Communications, National

Defense, and Land

Management

Federal age

ncies and departments combined have over 240,000 frequency

assignments, which are used for a variety of purposes, including

emergency communications, national defense, land management, and law

enforcement. Over 60 federal agencies and departments currently have

federal spectrum assignments.

Agencies and departments within DOD

have the most assignments, followed by FAA, the Department of Justice,

the Department of Homeland Security, U.S. Coast Guard, the Department

of the Interior, the Department of Agriculture, the Department of Energy,

and the Department of Commerce, respectively. These federal agencies

and departments hold 93 percent of all federally assigned spectrum (see

figure 3).

These data reflect only unclassified federal spectrum assignments.

For the purposes of our analysis, we combined data from the Departments of the Air

Force, Army, Navy, and Marine Corps into the DOD category.

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nagement of Federally Assigned Spectrum

Figure 3: Federal Agencies with the Most Spectrum Assignments

93%

Source: GAO analysis of NTIA GMF spectrum assignment data, September 7, 2010.

55%

Defense (37.37%)

Federal Aviation Administration (14.73%)

Justice (9.75%)

Homeland Security (7.39%)

Coast Guard (6.29%)

Interior (6.09%)

Agriculture (5.49%)

Energy (3.26%)

Commerce (2.78%)

Other

Note: Other includes the remaining 48 federal agencies and departments with spectrum frequency

assignments.

As illustrated in figure 4, less than one-third of all frequency assignments

held by federal agencies are located in the high-valued range (generally

considered the spectrum bands located above 300 MHz and below 3 GHz).

In contrast, over 48 percent of the spectrum held by federal agencies is

located in the 30–300 MHz range. The 18 IRAC agencies responding to our

survey reported holding some spectrum assignments in the high-value

range.

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nagement of Federally Assigned Spectrum

Figure 4: Percent of Federally Assigned Spectrum Located in Various Ranges

48.11%

13.17%

29.05%

9.66%

Source: GAO analysis of NTIA GMF spectrum assignment data, September 7, 2010.

3.1 GHz–300 GHz

0–30 MHz

300.1 MHz–3 GHz (high-value range)

30.1 MHz–300 MHz

Note: In addition, two agencies hold assignments above 300 GHz. Because these assignments

comprise of less than 1 percent of all assignments held by federal agencies, they were not included in

the figure. Totals do not add up to 100 percent due to rounding.

Through our survey and interviews with federal agency officials, we found

that federal agencies use spectrum, including high-valued spectrum, for a

wide array of purposes. As illustrated in figure 5, IRAC agencies reported

using federally assigned spectrum for emergency communications,

managing and protecting federal property or personnel, law enforcement,

research, and safety. As an example of use in the high-value range, the

Department of the Air Force reported in response to our survey using

spectrum for mission-critical military training and education, testing of

new equipment, research and development, and disaster response, in

concert with other agencies.

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nagement of Federally Assigned Spectrum

Figure 5: Number of Surveyed IRAC Agencies Reporting Various Types of Spectrum Use

Type of use

Number of IRAC agencies

Source: GAO survey.

0 3 69

Postal operations

Power utilities

transmission and

distribution of utilities

Space exploration

Broadcasting

Civil defense

National defense

National security

Natural resource

management, protection,

and conservation

Environmental

data collection

and dissemination

Transportation

Weather

Law enforcement

Research

Safety

Management and

protection of federal

property or personnel

Emergency

communication

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nagement of Federally Assigned Spectrum

Federal agencies also operate a variety of spectrum-dependent systems

and equipment on assigned spectrum. Within the high-value range (300

MHz–3 GHz), IRAC agencies reported operating a wide variety of systems.

The most frequently reported systems in that range included land mobile

radio systems, fixed microwave systems, and fixed microwave point-to-

point radio systems. These systems are typically used for voice and data

communication and while they can be operated in other frequency bands

outside of the high-value range, this range includes the most commonly

used frequencies for these systems.

Federal Agencies Lack

Specific Guidance and

Requirements from NTIA

for Recording and

Maintaining Accurate Data

NTIA has not established specific requirements for agenci

es to justify their

needs and to validate and verify data used to evaluate their current and

future spectrum needs. Federal spectrum managers we contacted reported

that when applying for an assignment, they generally request field program

staff to provide a description of how the frequency will be used and the

type of equipment needed for the assignment. One federal agency official

told us that his office has to trust that assignment application information

provided by program staff is accurate. Additionally, 6 out of the 10 federal

spectrum managers we contacted told us that while they review an

application before submitting it to NITA, their review primarily serves to

ensure that sufficient information has been provided to meet the

requirements of the Redbook. For example, a federal agency official told

us that when examining a frequency assignment application, some of the

factors that he reviews are availability of spectrum to be used with a

specific technology, potential for interference with other users, and

compliance of frequency use with NTIA rules and regulations.

As part of NTIA’s Frequency Assignment Review Program, federal

spectrum users are required to modify or delete frequency assignments as

needed based on the results of the 5-year reviews.

However, as with the

assignment process, federal spectrum managers are not required to

validate or verify that the information the program offices are submitting

is accurate. Seven out of 10 federal spectrum managers we contacted

reported that they do not have mechanisms in place to verify the accuracy

of the information collected during these processes. Similarly, 5 out of 10

For most assignments, NTIA requires that federal agencies conduct 5-year reviews of their

assignments. In some cases however, such as for certain space systems, aeronautical, and

military assignments, NTIA requires that agencies review the assignment every 10 years.

Redbook, § 8.2.6 and Annex F.

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Manage

ment of Federally Assigned Spectrum

federal spectrum managers reported that their agency had not conducted

site visits or sample surveys to verify information in their data systems.

Further, federal agency officials expressed various concerns related to the

process of obtaining information from field program staff when

completing assignment reviews, including concerns about (1) the future

availability of spectrum, (2) inaccurate data on existing systems, and (3)

resource constraints and staff coordination.

• In our survey, 15 out of 18 IRAC agencies reported that they will face some

or great difficulty in the future meeting their critical mission needs

because of insufficient spectrum.

Future Availability of

Spectrum

• Similarly, 4 out of the 10 federal spectrum managers we contacted told us

that while their agency’s spectrum needs are increasing, requesting new

assignments is becoming increasingly difficult due to the limited

availability of additional spectrum. According to these spectrum managers,

field program personnel are concerned that if they say they are no longer

using an assignment, it will be deleted and the program office will not be

able to obtain another assignment for their future spectrum needs. In one

specific example, a federal spectrum manager we contacted told us that

the agency’s border security duties have increased significantly over the

last few years, resulting in the agency’s increased use and dependence on

spectrum for security purposes. However, while the agency’s spectrum

needs have increased, the availability of spectrum has remained the same,

raising concerns about the agency’s access to sufficient spectrum to

complete operational mission requirements.

• Of the three agencies we contacted that had previously completed site

visits or in-depth reviews of assignment data, federal agency officials from

two of these agencies reported uncovering significant inaccuracies in their

assignment records. For example, officials from one agency told us that in

a recent review of a sample of spectrum assignments in the Detroit,

Michigan, metropolitan area, they uncovered that approximately half of

the agency’s assignment records were inaccurate. In another example, a

spectrum manager told us that the agency conducted a review of spectrum

assignments and found that 25 percent of assignments in one department

(20 assignments) were no longer being used. As a result of this review, the

agency returned the assignments. Because the other federal agencies we

interviewed did not indicate that they had completed site surveys or in-

depth reviews of their assignment records, the extent to which there are

data errors in other agencies’ assignment data is unknown.

Inaccurate Data on Existing

Systems

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nagement of Federally Assigned Spectrum

• One agency we met with had difficulty ascertaining whether a program

office was operating a system on an assignment. In this case, the agency

relocated several systems off of the 1710–1755 MHz band as a result of the

Advance Wireless Services auction in 2007.

Shortly after the relocation,

the agency was contacted by a commercial wireless carrier that had

acquired the frequency informing the agency that it still had a system

transmitting on the frequency, causing interference. The agency contacted

its regional program office and discovered that a transmitter at the

identified location had not been actively used by the agency for years but

was emitting a carrier signal, which was the source of the interference.

Once the transmitter was shut off the interference on that frequency

stopped. According to the agency’s spectrum manager, regional program

officials never notified the agency about the system’s existence, and as a

result, there was no record of the system in the agency’s inventory list.

Agency officials acknowledged that had they not been contacted by the

commercial wireless carrier, they would not have known that the

transmitter was still operating and sending out a carrier signal.

• While OMB Circular No. A-11, §33.4 and NTIA require that federal agencies

obtain an authorization to use a spectrum frequency assignment before

they purchase spectrum-dependent systems, 5 out of 10 agency spectrum

managers that we contacted reported that their agency does not have

procedures in place to monitor the agency’s procurement of spectrum-

dependent systems prior to obtaining an assignment.

• Seven out of 10 spectrum managers explained that due to high staff

turnover, identifying the appropriate contacts in the field to complete

assignment reviews can be difficult. One federal spectrum manager

explained that since field program staff are generally located in multiple

offices across the country, it is challenging to keep track of all the

appropriate contacts in each office every 5 years. Some spectrum

managers also noted that resource constraints limit their ability to validate

information obtained from program staff. Specifically, through our

interviews and IRAC survey, spectrum managers told us that competing

mission priorities limit their ability to verify the accuracy of information

obtained from program offices. One survey respondent stated that a key

challenge to completing frequency assignment reviews is balancing

available spectrum management resources with other competing

Resource Constraints and

Staff Coordination

Spectrum auctions are a market-based mechanism in which FCC assigns a license to the

entity that submits the highest bid for specific bands of spectrum. On September 18, 2006,

FCC completed an auction of designated federal frequencies in the 1710-1755 MHz band,

for commercial use as Advanced Wireless Services (AWS).

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nagement of Federally Assigned Spectrum

priorities. Another spectrum manager stated that validating and verifying

the information for each assignment record, which could entail conducting

site visits or surveys, would require significant spectrum management

resources that federal agencies do not currently have.

• Five out of 10 spectrum managers reported difficulties ensuring that

program offices communicated with them before purchasing a spectrum-

dependent system. Federal officials from one agency told us that

approximately 30 percent of the time, program offices at the agency

procure spectrum-dependent equipment without first notifying the agency

spectrum managers, and in some cases, before the assignment has been

granted.

• In another example, a spectrum manager reported that a program office

purchased a spectrum-dependent system to operate on an assignment

before receiving authorization to operate on the frequency. The frequency

assignment application was eventually denied because the program office

had purchased a system that could not be operated on federally assigned

spectrum and the agency had to place the equipment in storage where it

remained unused.

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nagement of Federally Assigned Spectrum

NTIA Has Taken Steps

to Identify Spectrum

for Future Wireless

Broadband Use, yet

NTIA and Federal

Agencies Will Face

Challenges in

Analyzing and

Repurposing This

Spectrum

NTIA Has Identified

Federally Assigned

Spectrum to Be Made

Available for Future

Wireless Broadband Use

In response to the recent initiatives to make a tot

al of 500 MHz of

spectrum available for wireless broadband, NTIA has (1) identified 115

MHz of federally allocated spectrum to be made available for wireless

broadband use within the next 5 years, referred to as the Fast Track

Evaluation, and (2) developed an initial plan and timetable for repurposing

additional spectrum for broadband, referred to as the 10-Year Plan.

Fast Track Evaluation. NTIA and the Policy and Plans Steering Group

(PPSG)

identified and recommended portions of two frequency bands,

totaling 115 MHz of spectrum within the ranges of 1695–1710 MHz and

3550–3650 MHz to be made available for wireless broadband use. In

November 2010, NTIA publicly released its results. In its final report, NTIA

summarized its analysis of four frequency bands: 1675–1710 MHz, 1755–

Wireless broadband is comprised of both fixed and mobile wireless communication

sources. Fixed wireless broadband refers to stationary wireless devices or systems that

provide high-speed Internet access from a fixed location. Mobile broadband refers to

wireless high-speed Internet access through a portable device, such as a cell phone. See,

Memorandum for the Heads of Executive Departments and Agencies, Unleashing the

Wireless Broadband Revolution, 75 Fed. Reg. 38387 (2010).

The PPSG consists of the Assistant Secretaries, or equivalent, with spectrum management

oversight in agencies that are major stakeholders in the spectrum issues under

consideration. It provides advice to NTIA on spectrum- dependent telecommunication

policies, strategic plans, planned or revised positions on spectrum issues nationally and

internationally, and helps resolve major contentious spectrum policy issues that affect the

use of spectrum by federal and nonfederal users.

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nagement of Federally Assigned Spectrum

1780 MHz, 3500–3650 MHz, and 4200–4400 MHz. For these bands, NTIA

reviewed the number of federal frequency assignments within the band,

the types of federal operations and functions that the assignments support,

and the geographic location of federal use. Additionally, NTIA applied the

following criteria to identify the 115 MHz of spectrum:

• the band must be able to be made available within 5 years,

• the band must be between 225 MHz and 4400 MHz,

• the decision to recommend bands for repurposing could be made prior to

October 1, 2010 (therefore due to time constraints decisions would not

require relocation of federal users), and

• opportunities for geographic or other sharing within the bands must have

already been successfully proven.

Since clearing these bands of federal users and relocating incumbent

federal users to new bands was not an option in the given time frame, the

bands that NTIA recommended be made available will be opened to

geographic sharing

by incumbent federal users and commercial

broadband.

10-Year Plan. By a presidential memorandum, NTIA was directed to

collaborate with FCC to make available 500 MHz of spectrum over the

next 10 years, suitable for both mobile and fixed wireless broadband use,

and complete by October 1, 2010, a specific plan and timetable for

identifying and making available the 500 MHz for broadband use. NTIA

publicly released this report in November 2010.

In total, NTIA and the

National Broadband Plan identified 2,264 MHz of spectrum to analyze for

possible repurposing, of which 639 MHz is exclusively used by the federal

government and will be analyzed by NTIA. Additionally, NTIA will

collaborate with FCC to analyze 835 MHz of spectrum that is currently

located in bands that are shared by federal and nonfederal users.

Furthermore, NTIA has stated that it plans to seek advice and assistance

As a form of interference mitigation to maintain incumbent operations, NTIA and FCC

will establish geographic exclusion zones which limit where commercial licensees will be

able to operate. Within the exclusion zones, wireless broadband use would not be

permitted, which would protect existing federal systems.

NTIA, 10 Year Plan and Timetable to Make Available 500 MHz of Spectrum for Wireless

Broadband (2010).

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nagement of Federally Assigned Spectrum

from CSMAC, its federal advisory committee comprised of industry

representatives and experts, as it conducts analyses under the 10-Year

Plan.

NTIA officials said that they will prioritize the bands identified for

evaluation based on the factors in table 3, with the bands that best fulfill

this criteria being evaluated for potential repurposing first. Following

prioritization, NTIA, with the assistance of the federal agencies, will

characterize each band to determine the extent of federal use in the band.

After each band is characterized, further analysis will be conducted to

evaluate the technical, operational, and cost effects that repurposing

would have on the federal agencies.

Table 3: NTIA Criteria for Prioritizing and Characterizing Candidate Bands in the 10-

Year Plan

Prioritization criteria

1. Amount of usable bandwidth and contiguous spectrum within band

2. Industry interest in band and expected auction

revenue

3. Indirect benefits to the economy

4. Availability of spectrum for relocation of incumbent federal users

5. Estimated costs of relocating federal incumbent users

6. Impact to global services that would require international reallocation

7. Likelihood the band can be repurposed in 10 years

Characterization criteria

1. Description of how the band is currently being used

2. Number and types of different federal systems operating in the band

3. Number of federal agencies in the band

4. Measure or description of the complexity of federal systems in the band

5. Number and types of nonfederal incumbent users in the band

6. Degree to which repurposing might impact federal services and operations

Source: NTIA.

Spectrum auctions are a market-based mechanism in which FCC assigns a license to the entity that

submits the highest bid for specific bands of spectrum.

In January 2011, NTIA announced that it had selected the 1755–1850 MHz

band as the first priority for detailed evaluation under the 10-Year Plan.

According to NTIA, this band was given top priority for evaluation by

NTIA and the federal agencies, based on a variety of factors, including

industry interest and the band’s potential for commercial use within 10

years. Agencies currently operating in this band have been notified of the

pending evaluation, and NTIA and PPSG have identified comparable bands

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nagement of Federally Assigned Spectrum

for agency operations. Affected agencies are now conducting analyses to

determine which of these comparable bands best meets their needs and

will provide NTIA with their input in spring 2011. According to NTIA

officials, a decision on how to proceed with its analysis will be made in

June 2011. This is not the first time NTIA has studied these bands. These

bands were previously evaluated for reallocation, and in 2001, we reported

that at the time adequate information was not currently available to fully

identify and address the uncertainties and risks of reallocation.

Federal Agencies Reported

Difficulties during the Fast

Track Evaluation, Raising

the Prospect for Future

Challenges

Affected federal ag

encies reported difficulties in providing the impact

analysis required for NTIA’s Fast Track Evaluation, raising concerns that

larger scale future analysis may be impacted. The evaluation required

Navy, NOAA, and FAA to analyze and submit a significant amount of

detailed impact analyses that were not readily available, according to

officials with those agencies. Further, Department of the Navy and U.S.

Marine Corps officials said they were required to conduct analyses based

on a number of different scenarios to determine what the impact might be

for mission performance by making various spectrum bands available for

wireless broadband. According to one Navy official, while DOD collects a

large amount of data on its spectrum-dependent systems, NTIA’s request

required DOD to conduct a time-consuming, in-depth analysis on the

operational impact of repurposing certain spectrum bands. NTIA officials

recognize that completing this analysis required significant agency

resources, but they noted that agencies were the only ones with the

requisite expertise to complete the analysis.

In response to our survey, the Department of the Navy and the Department

of the Air Force expressed concerns over data accuracy as a result of the

short time frame given to them to collect the data.

One official stated that

the speed of identifying available spectrum appeared more important than

the accuracy of the data. According to a DOD official, these data requests

were time-consuming because they required regional spectrum managers

to identify and contact all field program offices using spectrum- dependent

systems in the band being analyzed to determine their use of spectrum and

how their mission performance would be affected if the band were no

GAO, Defense Spectrum Management: More Analysis Needed to Support Spectrum Use

Decisions for the 1755-1850 MHz Band, GAO-01-795 (Washington, D.C.: Aug. 21, 2001).

The presidential memorandum was issued on June 28, 2010, and it directed NTIA to

report back with its initial plan and timetable by October 1, 2010.

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nagement of Federally Assigned Spectrum

longer available for federal use. Four IRAC agencies that completed our

survey—NOAA, Department of the Air Force, Department of the Navy, and

Department of the Army—expressed further concerns about the resources

required to collect spectrum data for the Fast Track Evaluation.

In addition to the challenges that federal agencies reported in gathering

data, making the 115 MHz of spectrum available for wireless broadband

will have operational effects on agencies. For example, according to

NTIA’s Fast Track Evaluation, as a result of the decision to make the 1695–

1710 MHz band available for wireless broadband, NOAA will have to

redesign its next generation of Geostationary Operational Environmental

Satellite-R series (GOES-R) satellites.

According to NOAA, this redesign

will increase costs and delay implementation. Additionally, NTIA does not

expect DOD to experience any immediate operational impacts due to the

repurposing of the 3550–3650 MHz band; however, such a repurposing

based on exclusion zones will limit DOD’s future flexibility to implement

new systems or operate at new locations. As table 4 illustrates, NOAA and

DOD will be the primary agencies affected by the decision to make this

spectrum available.

For additional information on these satellites, see GAO, Geostationary Operational

Environmental Satellites: Improvements Needed in Continuity Planning and

Involvement of Key Users, GAO-10-799 (Washington, D.C.: September 1, 2010).

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nagement of Federally Assigned Spectrum

Table 4: Status and Outcome of Bands Evaluated for Fast Track Repurposing

Band

Primary agency

operating in

band

Primary use NTIA decision

Challenges federal

agencies, industry, and

NTIA will face

Potential impacts

reported by

agencies

1675–1710 MHz NOAA Meteorological aid

and satellite service

Make a portion of the

band available to

wireless broadband

access within 5 years.

(1695–1710 MHz)

Delays and costs

associated with

redesigning next

generation of GOES-R

satellites.

Exclusion zones

surrounding satellite

downlink stations may

reduce industry interest.

Band is not used

internationally for mobile

broadband. Will require

international agreement at

2016 World Radio

Conference.

NOAA will redesign

the GOES-R

emergency weather

satellite downlink

transmission planned

for 1697.4 MHz to a

frequency below

1695 MHz.

1755–1780 MHz Multiple Multiple NTIA could not reach

a conclusion as to

whether the band

could be made

available for

broadband use within

5 years. NTIA will

continue to analyze

the issue as part of 10

year plan.

An industry priority but

not rigorously analyzed by

NTIA as part of the Fast

Track Evaluation and not

selected to be made

available for wireless

broadband.

Might require

relocation of

incumbent federal

users.

3500–3650 MHz DOD Navy shipboard

radar and DOD land

training facilities

Will make portion of

the band available to

wireless broadband

access within 5 years.

(3550–3650 MHz)

Will limit future flexibility

of DOD to implement new

systems and operate in

new locations. Minimal

industry interest in bands

above 3 GHz for mobile

broadband applications.

Does not require

alteration of current

military operations.

May limit ability to

expand operations.

4200–4220 and

4380–4400 MHz

Multiple—FAA

manages band

Radio altimeters on

aircraft (civil and

government)

Cannot make

available for

broadband use within

5 years. Will begin

taking action now to

gain international

agreement by 2016.

Reallocation would

require international

agreement and

reconfiguration on civil

and government aircraft.

FAA has not reported

complete usage data for

altimeters in this band.

FAA will have to

coordinate a study to

determine if use of

altimeters can be

prevented in band

segments. Will

require international

reallocation.

Source: GAO analysis of NTIA data.

The 1675–1710, 3500–3560, 4200–4220 and 4380–4400 MHz bands were identified by NTIA with

advice from the PPSG. The 1755–1780 MHz band was identified in the National Broadband Plan for

potential reallocation to allow for nonfederal broadband use. In January 2011, NTIA announced that it

would evaluate the 1755–1850 MHz bands as part of the 10-Year Plan.

Although multiple agencies operate on each of these bands, we have listed only the primary

agencies operating in each band that have regulatory authority over the band.

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nagement of Federally Assigned Spectrum

Further, data- and resource-related challenges could affect

implementation of NTIA’s 10-Year Plan. As experienced in previous

relocations, inaccurate and incomplete data submitted by agencies can

impact the transition time from federal to commercial use once

reallocated spectrum has been auctioned by FCC and purchased by

commercial users. During the relocation of federal users as a result of the

Advance Wireless Service spectrum auction in 2006, according to a

winning bidder of the spectrum, some agencies submitted inaccurate

inventory data to NTIA and OMB causing delays in the transition from

federal to commercial use. As previously discussed, federal agencies faced

resource challenges in providing NTIA data on system inventory,

operational use, and operational impacts. These challenges raise concerns

because the Fast Track Evaluation focused on only 115 MHz of spectrum,

while NTIA is now expecting to evaluate 1,474 MHz of spectrum, meaning

these challenges could be magnified.

Without adequate and timely funding for agencies to conduct research and

planning, the goals of the 10-Year Plan and timetable may not be achieved.

In previous auctions, as part of the Commercial Spectrum Enhancement

Act (CSEA),

agencies have been reimbursed for their relocation costs

through the Spectrum Relocation Fund.

CSEA does not provide agencies

with up-front funding to conduct detailed analysis during the spectrum

evaluation phase. The lack of funding may delay analysis and band

characterization for repurposing, as agencies have limited staff and

resources to dedicate to data collection and band analysis. This can be

problematic because agencies have reported significant costs associated

with collecting the data and conducting the analysis requested by NTIA.

For example, a DOD official told us he committed 400 staff hours to

On December 23, 2004, President Bush signed into law the Commercial Spectrum

Enhancement Act (Title II of Pub.L. No. 108-494) that created the Spectrum Relocation

Fund to provide a centralized and streamlined funding mechanism through which federal

agencies can recover the costs associated with relocating their radio communications

systems from certain spectrum bands, which were authorized to be auctioned for

commercial purposes. Under the terms of the CSEA, funds for compensation are only

available when the federal entities relocate from spectrum awarded to nonfederal entities

through a competitive bidding, or auction process. A portion of the revenues obtained in

the auction of the spectrum to nonfederal entities is then credited to the Spectrum

Relocation Fund to pay the relocation costs of federal entities.

According to OMB, costs associated with relocation of federal users in the auction of the

1710–1755 MHz band were estimated at $ 1.009 billion. These costs included necessary

infrastructure and systems modifications to relocate federal users to different frequencies

and the transition of some agencies from analog to digital communications to improve

communications efficiency and compatibility.

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nagement of Federally Assigned Spectrum

collecting operational impact data for the Fast Track Evaluation for two

affected DOD systems; under the 10-Year Plan, the official expects to have

to collect and prepare operational impact data for 120 systems. To address

this funding issue, NTIA stated in the Fast Track Evaluation analysis that

changes to expand the CSEA would be needed to provide agencies with

up-front funding for analysis and planning related to repurposing.

According to NTIA officials, without this funding, agencies will not be able

to conduct adequate analysis for the 10-Year Plan, and currently NTIA

does not have a plan to address these challenges if this funding is not

made available.

Industry Stakeholders

Expressed Concerns with

the Usefulness of the

Identified Spectrum

Industry stakeholders, including wireless service providers,

representatives of an ind

ustry association, and a think tank representative

we contacted expressed concerns over the usefulness of the spectrum

identified by NTIA in the Fast Track Evaluation, since most of the

spectrum identified (100 of the 115 MHz) is outside the range considered

to have the best propagation characteristics for mobile broadband.

Overall, there has been limited interest in the bands above 3 GHz for

mobile broadband use because, according to industry stakeholders, there

have been minimal technological developments for mobile broadband in

bands above 3 GHz and no foreseeable advances in this area at this time.

According to industry representatives, the 1755–1780 MHz band that NTIA

considered as part of the Fast Track Evaluation has the best

characteristics for mobile broadband use, and it is internationally

harmonized for this use. NTIA did not select this band to be made

available in the 5-year time frame due to the large number of federal users

currently operating there. Recently, however, NTIA has identified it as the

first band to be analyzed under the 10-Year Plan to determine if it can be

made available for commercial broadband use.

An industry stakeholder has stated that the 1695–1710 MHz band identified

by NTIA in the Fast Track Evaluation is the second-best alternative for

wireless broadband if the 1755–1780 MHz band were not made available;

however, the 1695–1710 MHz band is not currently used internationally for

wireless broadband, which may reduce device manufacturers’ incentive

for developing technology that can be used in these frequencies.

As mentioned previously, spectrum between 300 MHz and 3 GHz is generally considered

to be the best suited for mobile broadband.

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nagement of Federally Assigned Spectrum

Additionally, an industry stakeholder also expressed concern over the

exclusion zones established by NTIA in the 1695–1710 MHz band, which

would make the band unavailable for wireless broadband in select major

cities across the United States that account for over 12 percent of the U.S.

population. Similarly, one industry stakeholder has also noted that the

exclusion zones NTIA has established for the 3550–3650 MHz band would

prevent wireless broadband access along the entire East and West coasts.

Considering the geographic exclusion zones and the location of the

spectrum above 3 GHz, an industry stakeholder we contacted said that

they are not as immediately interested in this spectrum as they are in the

1755–1780 MHz band, which, according to one industry stakeholder, may

impact future spectrum auction prices. On March 8, 2011, FCC released a

Public Notice seeking comment on steps the Commission can take to best

promote wireless broadband deployment in the 1695-1710 MHz and 3550-

3650 MHz bands. Amongst other things, FCC sought comment on the

extent to which these bands could be made available for broadband

deployment; how the conditions placed on the bands, such as the

exclusion zones, could affect their usefulness for broadband deployment;

and whether broadband technologies are readily available to operate on

these bands.

While spectrum auctions can generate substantial funds for the U.S.

Treasury—for example, the Advance Wireless Services auction that took

place in September 2006 fetched over $13.7 billion, a portion of which

went to the U.S. Treasury—if industry participants are not as interested in

the spectrum being auctioned, lower bids would be expected. Agencies are

currently reimbursed with funding from auction revenue for data

collection, analysis, and planning-related costs, after costs for relocating

federal users have been paid. Lack of industry interest in spectrum above 3

GHz creates concerns as to whether large amounts of spectrum will be

able to meet the minimum price at auction, which the CSEA has set at 110

percent of federal relocation costs. Since relocating federal users is likely

as part of the 10-Year Plan, if the reserve is not met, agencies may not be

reimbursed for their data collection, analysis, and planning costs. As

previously stated, NTIA officials have raised concerns that without this

funding, agencies will not be able to conduct adequate analysis for the 10-

Spectrum Task Force Requests Information on Frequency Bands Identified by NTIA as

Potential Broadband Spectrum, Public Notice, DA 11-444 (2011). In this Public Notice,

FCC also sought comments to inform ongoing assessment of the 1755-1850 MHz, 4200-4220

MHz and 4380-4400 MHz bands, and other bands identified by NTIA as candidates for

commercial use.

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nagement of Federally Assigned Spectrum

Year Plan. Currently NTIA does not have a plan to address these

challenges if this funding is not made available.

Radio frequency spec

trum is a scarce national resource that enables

wireless communications services vital to the U.S. economy and to a

variety of government functions, yet NTIA has not developed a strategic,

governmentwide vision for managing federal use of this valuable resource.

NTIA’s spectrum management authority is broad in scope, but NTIA’s

efforts do not align with its authorities. Its focus is on the technical

aspects of spectrum management, such as ensuring new frequency

assignments will not cause interference to spectrum-dependent devices

already in use, rather than on whether new assignments should be

approved based on a comprehensive evaluation of federal spectrum use

from a governmentwide perspective. NTIA officials noted that due to

limited resources, the agency has put its strategic planning activities on

hold and has instead turned its focus to recent initiatives directed by the

Obama Administration. However, lacking an overall strategic vision, NTIA

cannot ensure that spectrum is being used efficiently by federal agencies.

Conclusions

Agencies ar

e supposed t

o review all

their spectrum assignments every 5

years and delete any assignments not essential to their missions; however,

we found that these reviews are often perfunctory. Furthermore, agencies

have concerns about not having access to sufficient spectrum in the future

to meet mission-critical needs and therefore might be reluctant to

relinquish any assignments for fear they will be unable to get more

spectrum in the future. The absence of requirements for agencies to

submit justifications for their spectrum use combined with NTIA’s limited

oversight of the agencies has led to decreased accountability and

transparency in how federal spectrum is actually being used and whether

the spectrum-dependent systems the agencies have in place are necessary.

However, federal agency officials face challenges—such as staff turnover

and resource constraints—when coordinating with field program staff to

obtain the information necessary for the frequency assignment

applications and reviews. Given that verifying the information for each

frequency assignment record could require significant spectrum

management resources that federal agencies might not currently have, it

would be beneficial for NTIA to consider options for a different approach

to obtain critical assignment information from the agencies. Approaches

may include efforts such as requiring agencies to conduct site surveys of

their spectrum-dependent systems, attesting to the accuracy of the data

provided to NTIA, or making changes to the structure of the 5-year review

program.

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nagement of Federally Assigned Spectrum

As part of its spectrum management processes, NTIA depends primarily

on an antiquated data collection system and does not have a mechanism in

place to validate and verify the accuracy of spectrum-related data

submitted by the federal agencies. The data management system also lacks

transparency and internal controls, which are essential for ensuring

accountability for government resources and for achieving effective and

efficient results. Although NTIA is developing its new FSMS, full

implementation is still years away. In the meantime, without meaningful

data validation requirements, NTIA has limited assurance that the agency-

reported data it collects are accurate and complete. As NTIA begins the

arduous task of identifying 500 MHz of spectrum that can be repurposed

for broadband services, incomplete or inaccurate data might adversely

impact NTIA’s ability to make sound decisions regarding the current and

future spectrum needs of agencies.

To facilitate the effective governmentwide management of federal

spectrum use, the Assistant Secretary of Commerce for Communications

and Information should take the following actions:

Recommendations for

Executive Action

• To ensure NTIA’s previous efforts to develop a federal strategic plan are

not diminished, develop an updated plan that includes key elements of a

strategic plan, as well as information on how spectrum is being used

across the federal government, opportunities to increase efficient use of

federally allocated spectrum and infrastructure, an assessment of future

spectrum needs, and plans to incorporate these needs in the frequency

assignment, equipment certification, and review processes.

• To help ensure federal agencies are managing current and future spectrum

assignments efficiently, in consultation with IRAC, examine the 5-year

assignment review processes and consider best practices to determine if

the current approach for collecting and validating data from federal

agencies can be streamlined or improved.

• To provide the assurance that accurate and reliable data on federal

spectrum use are collected, take interim steps to establish internal

controls for management oversight of the accuracy and completeness of

currently reported agency data. In developing the new Federal Spectrum

Management System, incorporate adequate internal controls for validating

the accuracy of agency-reported information submitted during the

assignment, certification, and frequency assignment review processes.

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nagement of Federally Assigned Spectrum

We provided a draft of this report to the Department of Commerce for its

review and comment. Commerce provided written comments, which are

reprinted in appendix IV.

Agency Comments

and Our Evaluation

In comme

nting on the draft report, Commerce noted that as the spectrum

manager for federal users, NTIA has several spectrum management duties,

such as fulfilling federal agency spectrum requirements, preventing

interference among federal users, and undertaking other spectrum-related

assignments or initiatives related to federally assigned spectrum.

According to Commerce, given funding limitations and resource

constraints, NTIA must determine how to prioritize its various spectrum-

related responsibilities without impairing its primary mission of

responding to agencies’ spectrum assignment requests in a timely manner.

With respect to our recommendations, Commerce concurred with one and

partially concurred with the other two. Specifically, Commerce concurred

with our recommendation to examine the 5-year assignment review

processes and consider best practices to determine if the current approach

can be improved. Commerce stated that NTIA, in consultation with IRAC,

would review the current assignment process with agencies to determine

what improvements could be implemented. Commerce partially concurred

with our recommendation to develop an updated strategic plan, stating

that NTIA will have to weigh updating strategic plans against other

spectrum management needs and directives and determine priorities.

Commerce agreed that key elements of strategic planning are central to

NTIA’s work, but stressed that given funding limitations, NTIA must

consider our recommendation in light of its other spectrum-related

obligations and fundamental spectrum mission. We recognize that NTIA

has been tasked with responding to other spectrum management

directives, but lacking an overall strategic vision, NTIA cannot ensure that

its spectrum management decisions reflect the overall best use of federally

allocated spectrum. Moreover, without an understanding of how spectrum

is being used across the federal government, NTIA cannot ensure that

spectrum is being used efficiently by federal agencies or that spectrum

management decisions will meet the current and future needs of the

agencies, as well as the federal government as a whole. We believe a

strategic plan is a key element for NTIA to respond to recent directives

from the President regarding repurposing spectrum assigned to federal

agencies for commercial broadband. Commerce also partially concurred

with our recommendation related to establishing internal controls for

management oversight of currently reported agency data, noting its

concurrence to the extent that such controls could be adopted with

existing and anticipated resources. Commerce stated that NTIA would

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GAO-11-352

nagement of Federally Assigned Spectrum

take steps to establish internal controls for federal spectrum use data and

work with agencies to determine what new processes could be

implemented that would lead to more accurate and reliable data, including

the establishment of procedures for agency validation of submitted data.

As agreed with your offices, unless you publicly announce th

e contents of

this report earlier, we plan no further distribution until 30 days from the

report date. At that time, we will send copies to the appropriate

congressional committees and the Secretary of Commerce. In addition, the

report will be available at no charge on the GAO Web site at

http://www.gao.gov.

If you or your staff have any questions about thi

s report, please contact me

at (202) 512-2834 or [email protected]. Contact points for our Offices of

Congressional Relations and Public Affairs may be found on t

he last page

of this report. Contact information and major contributors to this report

Mark L. Goldstein

are listed on appendix V.

Director, Physical Infrastructure Issues

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix I: Objectives, Scope, and

Methodology

Page 41 GAO-11-352

Appendix I: Objectives, Scope, and

Methodology

This report focuses on the federal use of spectrum and examines (1) the

extent to which the National Telecommunications and Information

Administration’s (NTIA) spectrum management oversight and policy

addresses governmentwide spectrum needs, (2) how federal agencies are

using assigned spectrum and the extent to which they manage their

spectrum use, and (3) what steps NTIA and the federal agencies have

taken to meet the requirements and expectations of the National

Broadband Plan and presidential memorandum to repurpose spectrum for

commercial broadband and what challenges these efforts face.

To determine the extent to which NTIA’s spectrum management oversight

and policy addresses governmentwide spectrum needs, we examined

documents, consulted relevant spectrum literature, and conducted

interviews. Specifically, we reviewed NTIA’s Manual of Regulations and

Procedures for the Federal Radio Frequency Management (commonly

referred to as the Redbook) and other documentation of NTIA’s current

processes, policies, and procedures to determine (1) NTIA’s legal

authorities for managing federal users of spectrum, (2) how NTIA works

with federal agencies to manage spectrum, (3) how NTIA collects data on

federal agency spectrum assignments and usage, (4) limitations, if any,

with NTIA’s current procedures for collecting data on federal agency

spectrum assignments and usage, and (5) NTIA’s actions, if any, to address

these limitations. We also reviewed NTIA’s data collection procedures and

policies to ensure the data reliability of information contained in the

Government Master File (GMF) database. In addition, we interviewed

representatives from NTIA’s Office of Spectrum Management to gather

information about their spectrum management policies and procedures.

We also interviewed or obtained written comments from a variety of

experts and industry stakeholders, including academics, industry

representatives, and think-tank organizations (as shown in table 5) to

obtain their views on options available for increasing the efficiency of

federal spectrum use and management and associated tradeoffs. We

selected the experts and industry stakeholders to interview based on prior

published literature, stakeholders’ recognition and affiliation with

spectrum management industry, and NTIA and other stakeholders’

recommendations. Finally, we conducted a literature review of spectrum

studies. Our literature search covered studies published from 2005 onward

and was largely drawn from major electronic databases in

telecommunications, academic, economics, and other fields (e.g., SNL

Kagan, EconLit, Academic OneFile, ProQuest, and other databases) and

from our past work on spectrum-related issues. We used the studies

obtained from this literature review to obtain background information on

spectrum issues.

nagement of Federally Assigned Spectrum

Appendix I: Objectives, Scope, and

Methodology

Table 5: List of Experts and Industry Stakeholders We Contacted

Stakeholder groups Stakeholder

Academic experts Stanford Institute for Economic Policy Research

Interdisciplinary Telecommunications Program, University of

Colorado

Think tank research Open Technology Initiative at New America Foundation

Public Knowledge

Industry stakeholders Shared Spectrum

CTIA, the Wireless Association

Verizon

Motorola

T-Mobile

AT&T

Source: GAO.

To identify how federal agencies use assigned spectrum and the extent to

which agencies manage their spectrum use we conducted a Web-based

survey of all 19 Interdepartment Radio Advisory Committee (IRAC) federal

agency representatives. We surveyed federal agencies on the IRAC

because these agencies collectively hold over 90 percent of all federally

assigned spectrum. The survey was conducted from November 1, 2010, to

January 21, 2011. The survey included questions on (1) how federal

agencies use spectrum assignments; (2) federal agency interaction with

NTIA; (3) federal agencies’ spectrum management policies and

procedures; (4) the extent to which federal agencies share spectrum with

other users and use of commercial services; and (5) federal agencies’

views on the extent to which agencies have the resources and information

they need to manage their spectrum. The results of our survey can be

found in appendix III.

We received completed responses from 18 of the 19 IRAC representatives,

for a 95 percent response rate. We did not receive a completed survey

from the Department of State IRAC representative despite our multiple

attempts to obtain the information. Because we selected a nonprobability

sample of federal agencies with assigned spectrum to survey, the

information we obtained from the survey may not be generalized to all

federal agencies with assigned spectrum. However, because the IRAC

member agencies that we included in our sample survey hold the vast

majority of all federally assigned spectrum, the information we gathered

from these agencies provided us with a general understanding of federal

agencies’ spectrum management policies. In addition, we took steps in the

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix I: Objectives, Scope, and

Methodology

development of the survey, the data collection, and the data analysis to

minimize nonsampling errors. For instance, a survey specialist designed

the survey and the draft survey was pre-tested with IRAC representatives

from three federal agencies. We conducted these pre-tests to ensure that

(1) the questions and possible responses were clear and thorough, (2)

terminology was used correctly, (3) questions did not place an undue

burden on the respondents, (4) the information was feasible to obtain, and

(5) the questionnaire was comprehensive and unbiased. On the basis of

the feedback from the three pre-tests we conducted, we made changes to

the content and format of the survey questions.

To supplement data obtained from the survey and to gather in-depth

information on the roles and responsibilities of federal agencies in

managing their assigned spectrum, we obtained documents from and

conducted interviews with a sample of federal agencies to provide detailed

examples of how federal agencies are managing their spectrum. We

prepared comprehensive profiles for each of these agencies which

included data from our IRAC survey, our review of federal agency

planning documents including federal agencies’ spectrum management

policies and procedures and strategic spectrum plans, other literature, and

structured interviews with spectrum management officials at selected

federal agencies. The agencies we met with included the Department of

Defense, Department of Homeland Security, Department of Labor,

Environmental Protection Agency, National Oceanic and Atmospheric

Administration, the U.S. Coast Guard, Federal Aviation Administration,

Health and Human Services, Housing and Urban Development, and the

Department of the Treasury. We selected federal agencies for our

comprehensive profiles to achieve a mix of the following characteristics:

• large spectrum holdings (more than 5,000 assignments) and small

spectrum holdings (less than 1,000 assignments);

• IRAC and non-IRAC member agencies to ensure that we had

representative views from both groups; and

• assignments located in different spectrum bands and used for different

mission needs.

We also consulted internal stakeholders, experts, associations, and NTIA

officials to assist us in identifying potential agencies to interview.

Although using these criteria allowed us to obtain information from a

diverse mix of federal agencies, the findings from our in-depth profiles

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix I: Objectives, Scope, and

Methodology

cannot be generalized to all federal agencies because they were selected

as part of a non-probability sample.

To determine what steps NTIA and federal agencies have taken to meet

the requirements and expectations of the June 28, 2010, presidential

memorandum and what challenges these efforts will face, we reviewed

pertinent documents related to their efforts, such as NTIA’s Assessment of

Spectrum Bands That Could Possibly be Repurposed for Wireless

Broadband (referred to as the Fast Track Evaluation) and 10-Year Plan.

We also conducted interviews with NTIA and federal agency officials.

Through our interviews, we collected up to date information on actions

being taken to make spectrum available for wireless broadband including

information on what criteria NTIA is using to make these decisions, how

NTIA and federal agencies are collaborating on identifying spectrum, and

what potential challenges they may face in reallocating federal spectrum.

We also contacted four wireless service providers to obtain their

viewpoints and opinions on (1) NTIA’s process and methodology for

identifying additional spectrum to be made available for commercial

broadband use, (2) the level of private sector demand for the spectrum

identified by NTIA, and (3) the potential value of spectrum that NTIA has

identified for analysis as part of its Fast Track Evaluation and 10-Year

Plan.

We conducted this performance audit from May 2010 to April 2011 in

accordance with generally accepted government auditing standards. Those

standards require that we plan and perform the audit to obtain sufficient

appropriate evidence to provide a reasonable basis for our findings and

conclusions based on our audit objectives. We believe that the evidence

obtained provides a reasonable basis for our findings and conclusions

based on our audit objectives.

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix II: Summary of NTIA Projects

Focused on Reforming Governmentwide

Federal Spectrum Management and

Increasing the Efficiency and Effectiveness of

Federal Spectrum Use

Page 45 GAO-11-352 Management of Federally Assigned Spectrum

Project Tasks Deliverable Target date

Status as of February

2011

Improve stakeholder

participation and

maintain high

qualifications of

spectrum managers

1. Establish a Commerce

Spectrum Management

Advisory Committee

(CSMAC)

2. Establish a high-level

interagency group

3. Resolve

intergovernmental

spectrum disputes through

the existing White House

Policy Coordinating

Committee (PCC) and

process and revise the

NTIA/FCC Memorandum

of Understanding (MOU) to

provide an additional

minimum 15 business

days to accommodate the

PCC process

4. Expand the role of

FCC Defense

Commissioner

5. Promote a career

development program

and spectrum

management training

Establish CSMAC

Establish PPSG

MOU between NTIA and

FCC to provide additional

minimum 15 business

days to accommodate

PCC process

MOU between NTIA and

FCC to expand the role of

FCC Defense

Commissioner

No deliverables

May 2005

January 2005

March 2006

September 2007

Completed on time

NTIA submitted proposed

MOU language to FCC in

May 2008; incomplete with

no anticipated date for

completion

NTIA submitted revised

proposed language to

FCC in May 2008;

Incomplete with no

anticipated date for

completion

Program reactivated in

Jan. 2008.

Reduce International

Barriers to U.S.

Innovations in

Technologies and

Services

1. Improve U.S.

preparations for World

Radio Communication

Conferences

2. Improve international

spectrum management

and regulatory

environment

Study and

recommendations on

improvements to U.S.

preparations

Study and

recommendations on

impact of international

spectrum management

policies and regulatory

environment

May 2005

June 2006

Completed on time

Report issued in 2008

Appendix II: Summary of NTIA Projects Focused on

Reforming Governmentwide Federal Spectrum

Management and Increasing the Efficiency and

Effectiveness of Federal Spectrum Use

Appendix II: Summary of NTIA Projects

Focused on Reforming Governmentwide

Federal Spectrum Management and

Increasing the Efficiency and Effectiveness of

Federal Spectrum Use

Project Tasks Deliverable Target date

Status as of February

2011

Modernize Federal

Spectrum

Management

Processes with

Advanced Information

Technology

1.Implement advanced

information management

system

The Federal Spectrum

Management

System will utilize

advanced information

technology to develop a

Web-based process for

preparing and processing

applications for system

certification and frequency

assignments. It will

consolidate existing paper-

based and multiple

software systems,

including Spectrum XXI

and El-Cid.

Ongoing Ongoing project; system

will be developed by a

contract system integrator

in conjunction with NTIA

staff and with input from

the federal agency user

community

Satisfy Public Safety

Communication

Needs and Ensure

Interoperability

1. Spectrum sharing

between federal and

nonfederal agencies

Assessment of feasibility

of spectrum sharing

between federal and

nonfederal public safety

entities

December 2006 Completed Report on

Federal/nonfederal

spectrum and

infrastructure sharing and

published Jun.2007

Enhance Spectrum

Engineering and

Analytical Tools

1. Develop analytical

approaches, software

tools, and engineering

techniques for evaluating

and improving the

efficiency and

effectiveness of federal

spectrum use

2. Develop and promote

recognition in the

spectrum management

community for best

practices in spectrum

engineering

3. Conduct a pilot

program to evaluate

approaches and

techniques to increase

spectrum sharing

between federal and

nonfederal spectrum

users

4. Develop and promote

the use of modern

analytic tools for

spectrum engineering

A series of reports that

make recommendations

for improving spectrum

efficiency. Develop a

Spectrum-efficiency

recommendationsreport

that includes an approach

and time frame for

implementing the

recommendations.

Best Practices Handbook

Establish, conduct, and

evaluate results of use of

devices and technologies

to facilitate sharing

through Spectrum Sharing

Innovation Test-Bed

Prepare initial spectrum

management models and

tools catalog for use by

federal spectrum users

September 2007

November 2007

Pilot program to be

completed by June 2006;

results and

recommendations of the

pilot program are to be

completed by September

2008

December 2006

Incomplete with no

anticipated date for

completion

Incomplete with no

anticipated date for

completion

Stage 1 testing Started in

Quarter 2009. Results

and recommendations not

reported

Incomplete with no

anticipated date for

completion

Promote Efficient and

Effective Use of

Spectrum

1. Improve the technical

planning process

Recommendations for

changes to the NTIA

Manual with respect to the

Spectrum Certification

process

December 2006 Incomplete with no

anticipated date for

completion

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nagement of Federally Assigned Spectrum

Appendix II: Summary of NTIA Projects

Focused on Reforming Governmentwide

Federal Spectrum Management and

Increasing the Efficiency and Effectiveness of

Federal Spectrum Use

Project Tasks Deliverable Target date

Status as of February

2011

Improve Long-term

Planning and Promote

Use of Market-based

Economic

Mechanisms in

Spectrum

1. Improve the processes

for federal agencies’

spectrum planning and

produce a national

spectrum plan

2. Improve federal

agencies’ processes and

procedures to better

consider the economic

value of spectrum when

investing in spectrum-

dependent systems

3. Develop a plan to

identify and implement

incentives for improving

efficiency in federal

agencies’ spectrum use

4. Promote the

implementation of a wide

range of incentives to

improve the efficiencies

of both government and

private sector spectrum

use

Federal Strategic

Spectrum Plan published

biannually; National

Strategic Spectrum Plan

Guidance to the federal

agencies on compliance

with Section 33.4 of OMB

Circular A-11 on

considering spectrum

value when seeking

funding for major

spectrum-dependent

systems

Guidance to the federal

agencies concerning

integration of spectrum

planning with capital and

strategic planning

Incentives Implementation

Plan; workshop on

economic and other

incentives for efficient use

of spectrum; study on

international practices with

respect to incorporation of

market mechanisms into

spectrum management

Contractor-produced study

providing unit of

consumption for spectrum

use; revised structure for

current OSM cost-recovery

fee for federal agency

spectrum use; study on

federal spectrum value

and development of fees

to promote efficient use of

spectrum; draft legislation

to implement spectrum

use fees; study on sharing

between federal agencies

and nonfederal unlicensed

systems; study on federal

spectrum rights; proposals

to provide federal agency

more flexible rights with

respect to spectrum to

enable sharing with other

federal agencies and

nonfederal entities

Federal Strategic

Spectrum Plan to be

completed by May

2006;National Spectrum

Plan to be completed by

December 2007

Not stated—OMB added

section 33.4 to Circular

A-11 in November 2004

November 2005

Not stated

Federal Strategic

Spectrum Plan published

in March 2008; letter to

FCC seeking participation

in National Strategic

Spectrum Plan sent in

June 2008; incomplete

with no anticipated date for

completion

Completed by OMB in

November 2004

Incentives Implementation

Plan forwarded to the

White House in March

2006 and Published in

November 2008; workshop

on the use of economic or

other incentives to

increase the efficiency in

federal agencies’ spectrum

use conducted in February

2006; unpublished study

examining international

practices that incorporate

market mechanisms into

more efficient spectrum

use completed in 2006

Incomplete with no

anticipated date for

completion

Source: GAO review of NTIA data.

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nagement of Federally Assigned Spectrum

Appendix III: S

urvey of IRAC Agencies

Page 48 GAO-11-352

Appendix III: Survey of IRAC Agencies

The questions we asked in our survey of IRAC agencies are shown below.

Our survey was comprised of closed- and open-ended questions. In this

appendix, we include all the survey questions and aggregate results of

responses to the closed-ended questions; we do not provide information

on responses provided to the open-ended questions. For a more detailed

discussion of our survey methodology see appendix I.

Background Information:

1. Which Interdepartment Radio Advisory Committee (IRAC) agency do

you represent?

Q1 Response

Broadcasting Board of Governors YES

Department of Agriculture YES

Department of Commerce YES

Department of Energy YES

Department of Homeland Security YES

Department of Justice YES

Department of Air Force YES

Department of Army YES

Department of the Interior YES

Department of the Navy YES

Department of Treasury YES

Department of Transportation YES

Department of Veterans Affairs YES

Federal Aviation Administration YES

National Aeronautics and Space Administration YES

National Science Foundation YES

United States Coast Guard YES

United States Postal Service YES

Department of State NO

2. What component agency or department do you work for?

[Open-ended]

3. What is your job title?

[Open-ended]

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

4. Please briefly describe your key responsibilities as they relate to

spectrum management.

[Open-ended]

5. Do you have other responsibilities in addition to spectrum

management? If so, please describe.

[Open-ended]

6. How long have you been working in federal spectrum management?

(Please include in your estimate experience throughout your career

not just in your current position)

Q6 Percent

5 years to less than 10 years 27.78

10 years to less than 15 years 22.22

20 years or more 50.00

Federal Agency Frequency Assignments:

7. Currently, how many frequency

assignments in each of the following

frequency band ranges does the IRAC agency you represent have?

[Open-ended]

8. For what general purpose does the IRAC agency you represent use

spectrum assigned in the 300 MHz to 3 GHz range? If you do not have

any spectrum assigned in the 300 MHz to 3 GHz range, please skip

toQ9

[Open-ended]

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nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

9. For the IRAC agency you represent, which of the following usage

categories has your assigned spectrum been designated? (Select one

for each row.)

Response

Question

Yes No

Don’t

know

response/not

applicable

Total

responses

9a. Broadcasting 7 10 1 18

9b. Civil defense 7 9 1 1 18

9c. Emergency communication 17 1 18

9d. Environmental data collection and dissemination 12 5 1 18

9e. Law enforcement 14 4 18

9f. Management and protection of federal property or personnel 16 1 17

9g. National defense 8 9 1 18

9h. National security 9 8 1 18

9i. Natural resources management, protection, and conservation 11 6 1 18

9j. Postal operations 1 17 18

9k. Power utilities transmission and distribution of utilities 3 15 18

9l. Research 14 4 18

9m. Safety 14 4 18

9n. Space exploration 3 14 17

9o. Transportation 12 6 18

9p. Weather 12 6 18

9q. Other 7 5 1 4 17

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

The next series of questions asks about the types of technologies

your agency operates within specific spectrum band ranges.

10. For the IRAC agency you represent, please indicate whether your

agency operates fixed microwave systems within any of these

frequency ranges. (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

10a. Below 3 kHz 16 2 18

10b. 3.1 - 30 kHz 16 2 18

10c. 30.1 - 300 kHz 16 2 18

10d. 300.1 - 3 MHz 1 15 1 17

10e. 3.1 - 30 MHz 2 15 1 18

10f. 30.1 - 300 MHz 3 14 1 18

10g. 300.1 MHz - 3 GHz 14 4 18

10h. 3.1 GHz - 30 GHz 15 3 18

10i. 30.1 GHz - 300 GHz 7 11 18

10j. Above 300 GHz 16 1 17

11. For the IRAC agency you represent, please indicate whether your

agency operates fixed transportable systems within any of these

frequency ranges. (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

11a. Below 3 kHz 1 15 1 17

11b. 3.1 - 30 kHz 2 14 1 17

11c. 30.1 - 300 kHz 2 14 1 17

11d. 300.1 - 3 MHz 8 8 1 17

11e. 3.1 - 30 MHz 7 9 1 17

11f. 30.1 - 300 MHz 11 6 17

11g. 300.1 MHz - 3 GHz 12 4 16

11h. 3.1 GHz - 30 GHz 10 6 1 17

11i. 30.1 GHz - 300 GHz 3 13 117

11j. Above 300 GHz 17 17

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

12. For the IRAC agency you represent, please indicate whether your

agency operates land mobile radio systems within any of these

frequency ranges. select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

12a. Below 3 kHz 17 1 18

12b. 3.1 - 30 kHz 17 1 18

12c. 30.1 - 300 kHz 1 16 1 18

12d. 300.1 - 3 MHz 4 14 18

12e. 3.1 - 30 MHz 7 11 18

12f. 30.1 - 300 MHz 18 18

12g. 300.1 MHz - 3 GHz 18 18

12h. 3.1 GHz - 30 GHz 2 16 18

12i. 30.1 GHz - 300 GHz 18 18

12j. Above 300 GHz 18 18

13. For the IRAC agency you represent, please indicate whether your

agency operates maritime mobile radio systems within any of these

frequency ranges. (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

13a. Below 3 kHz 15 3 18

13b. 3.1 - 30 kHz 1 14 3 18

13c. 30.1 - 300 kHz 1 13 3 17

13d. 300.1 - 3 MHz 6 10 2 18

13e. 3.1 - 30 MHz 6 10 2 18

13f. 30.1 - 300 MHz 10 6 2 18

13g. 300.1 MHz - 3 GHz 5 11 2 18

13h. 3.1 GHz - 30 GHz 1 15 2 18

13i. 30.1 GHz - 300 GHz 16 2 18

13j. Above 300 GHz 16 2 18

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

14. For the IRAC agency you represent, please indicate whether your

agency operates fixed microwave point to point radio systems within

any of these frequency ranges. (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

14a. Below 3 kHz 16 2 18

14b. 3.1 - 30 kHz 16 2 18

14c. 30.1 - 300 kHz 15 2 17

14d. 300.1 - 3 MHz 16 2 18

14e. 3.1 - 30 MHz 16 2 18

14f. 30.1 - 300 MHz 2 14 2 18

14g. 300.1 MHz - 3 GHz 14 4 18

14h. 3.1 GHz - 30 GHz 14 4 18

14i. 30.1 GHz - 300 GHz 2 16 18

14j. Above 300 GHz 18 18

15. For the IRAC agency you represent, please indicate whether your

agency operates digital microwave systems within any of these

frequency ranges. (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

15a. Below 3 kHz 16 2 18

15b. 3.1 - 30 kHz 16 2 18

15c. 30.1 - 300 kHz 16 2 18

15d. 300.1 - 3 MHz 16 2 18

15e. 3.1 - 30 MHz 15 2 17

15f. 30.1 - 300 MHz 1 15 2 18

15g. 300.1 MHz - 3 GHz 11 7 18

15h. 3.1 GHz - 30 GHz 15 3 18

15i. 30.1 GHz - 300 GHz 4 14 18

15j. Above 300 GHz 18 18

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

16. For the IRAC agency you represent, please indicate whether your

agency operates satellite systems within any of these frequency

ranges. (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

16a. Below 3 kHz 15 3 18

16b. 3.1 - 30 kHz 15 3 18

16c. 30.1 - 300 kHz 15 3 18

16d. 300.1 - 3 MHz 15 3 18

16e. 3.1 - 30 MHz 15 3 18

16f. 30.1 - 300 MHz 5 9 3 17

16g. 300.1 MHz - 3 GHz 10 6 2 18

16h. 3.1 GHz - 30 GHz 10 6 2 18

16i. 30.1 GHz - 300 GHz 5 11 2 18

16j. Above 300 GHz 1 15 2 18

Spectrum Management Resources:

17. For the IRAC agency you represent, what is/was

the federal agency’s

budget for managing spectrum for each of the following years? (Note:

for this question, do not include administrative fees paid to NTIA.)

[Open-ended]

18. For the IRAC agency you represent, how much did you pay NTIA in

administrative fees for each of the following years?

[Open-ended]

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

19. In general, how satisfied or dissatisfied is the IRAC agency you

represent with the following resources available at your agency to

manage spectrum? (select one for each row)

Response

Question

Very

satisfied

Somewhat

satisfied

Neither

satisfied nor

dissatisfied

Somewhat

dissatisfied

Very

dissatisfied

Don’t

know

response/not

applicable

Total

responses

19a. Number of staff at

your agency working on

spectrum management

issues

3 4272 18

19b. Funding available for

spectrum management

purposes

3 4 3 5 3 18

19c. Ability to collect data

on your spectrum use

3 743 1 18

19d. In-house technical

expertise on spectrum

management issues

11 5 2 18

19e. Access to technical

expertise outside of your

agency (i.e., technical

consultants, experts at

other agencies)

5 6 5 1 1 18

19f. Research at your

agency dedicated to

improving interference

issues

2 6 5 3 1 1 18

19g. Spectrum

management training

opportunities

4 4 5 3 2 18

19h. Agency specific

spectrum management

guidance

5 5 5 1 2 18

19i. Other 1 11 12

20. What additional resources, if any, would the IRAC agency you

represent like to have to manage your spectrum?

[Open-ended]

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

NTIA Guidance and Coordination:

21. Excluding the guidance you received from NTIA’s Manual of

Regulations and Procedures for Federal Radio Frequency Management

(the Redbook), how satisfied or dissatisfied are you with the current

quality of the other NTIA guidance you receive to manage your federal

spectrum? (select one for each row)

Response

Question

Very

satisfied

Somewhat

satisfied

Neither

satisfied

nor

dissatisfied

Somewhat

dissatisfied

Very

dissatisfied

Guidance

not

provided

response/not

applicable

Total

responses

21a. Conducting spectrum

usage measurements of

your assigned spectrum

2 1 5 1 8 1 18

21b. Determining your

agency’s current spectrum

needs

1 5 2 2 7 1 18

21c. Determining your

agency’s future spectrum

needs

1 3 3 28 118

21d. Submitting data to

NTIA’s Government Master

File database

4 6 3 1 3 118

21e. Completing your

agency’s biennial federal

spectrum strategic plan

77 1 217

21f. Completing the

spectrum certification

process for a new or

upgraded spectrum system

3 6242 118

21g. Addressing

interference issues

4 64111 118

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

22. To what extent, if at all, does the IRAC agency you represent

coordinate with NTIA on the following spectrum management issues?

(select one for each row)

Response

Question

Great

extent

Moderate

extent

Some or

little

extent

response/not

applicable

Total

responses

22a. Obtaining new frequency assignments 14 4 18

22b. Completing the spectrum certification process for a

new or upgraded spectrum system

10 4 2 2 18

22c. Addressing interference issues 2 8 6 2 18

22d. Coordinating sharing agreements with other entities 3 68 17

22e. Other 99

23. What comments or concerns, if any, do you have with NTIA’s efforts to

identify and make available 500 MHz of spectrum suitable for both

mobile and fixed wireless broadband use?

[Open-ended]

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

Agency Management and Planning Processes and Procedures:

24. Does the IRAC agency you represent have internal policies, protocols,

or procedures in place to complete the following spectrum

management activities. (select one for each row)

Response

Question

Yes,

protocols or

procedures

are in place

No, protocols

or procedures

are not in place

No, protocols or

procedures are

not in place, but

agency is in the

process of

developing

protocols or

procedures

response/not

applicable

Total

responses

24a. conducting the 5-year reviews of your federal

agency’s frequency assignments reflected in the

Government Master File (GMF) Database

17 1 18

24b. conducting internal reviews of your federal

agency’s future spectrum needs

10 4 4 18

24c. conducting measurements of actual spectrum

use (such as geographic location of use, and

duration and extent of use)

6 1 10 1 18

24d. collecting and maintaining data on how your

agency uses spectrum

12 4 2 18

24e. using spectrum efficient technologies 9 5 3 118

24f. coordinating spectrum use across program

offices/departments within your agency

15 2 1 18

24g. Other 2 1 9 12

25. Within the last 5 years, how many applications for frequency

assignments has your agency submitted to the Frequency Assignment

Subcommittee (FAS)?

[Open-ended]

26. Within the last 5 years, how many spectrum certification applications

for major spectrum dependent systems has your agency submitted to

the Spectrum Planning Subcommittee (SPS)?

[Open-ended]

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nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

27. What factors did the IRAC agency you represent consider when

determining whether to classify a system as a “major spectrum

dependent system” requiring a spectrum certification review?

[open-ended]

28. To what extent does the IRAC agency you represent rely on unlicensed

spectrum? (select one for each row)

Q28 Frequency Total responses

Great extent 2 2

Moderate extent 6 8

Some or little extent 9 17

No extent 1 18

29. When did the IRAC agency you represent last complete a review or

analysis of your future spectrum needs? (select one for each row)

Q29 Frequency Total responses

In the last 6 months 3 3

More than 6 months ago, but less than 1 year ago 2 5

More than 1 year ago, but less than 2 years ago 5 10

More than 2 years ago, but less than 5 years ago 4 14

More than 5 years ago 2 16

Do not know 2 18

30. How much, if at all, do you see your agency’s need for spectrum

increasing in the next 2-3 years? (select one for each row)

Q30 Frequency Total responses

Greatly increasing 6 6

Moderately increasing 2 8

Slightly increasing 8 16

Not increasing 1 17

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

31. In your opinion, will your agency have difficulty in the future meeting

its critical mission needs because of insufficient spectrum? (select one

for each row)

Q31 Frequency Total responses

Yes, there will be great difficulty 8 8

Yes, there will be some difficulty 7 15

No, there will be no difficulty 3 18

32. What factors does the IRAC agency you represent consider when

making decisions about how much spectrum the agency will need in

the future?

[Open-ended]

33. On average, how often is your agency able to meet the 5-year review

requirement of your agency’ spectrum frequency assignments reflected

in the Government Master File Database?

Q33 Frequency Total responses

All the time 5 5

Most of the time 9 14

Some of the time, but not most of the time 4 18

34. Please describe below some of the general challenges, if any, that your

agency faces in reviewing your spectrum frequency assignments

reflected in the Government Master File Database, by the 5-year

deadline as required by NTIA:

[Open-ended]

35. During the last year, approximately how many modifications to an

existing spectrum frequency assignment did the IRAC agency you

represent make?

[Open-ended]

36. Please describe below the general reasons for why your agency

modified an existing spectrum frequency assignment during the last

year:

[Open-ended]

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nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

37. During the last year, approximately how many deletions to an existing

spectrum frequency assignment did the IRAC agency you represent

make?

[Open-ended]

38. Please describe below the general reasons for why your agency deleted

an existing spectrum frequency assignment during the last year:

[Open-ended]

39. Does the IRAC agency you represent currently conduct measurements

of any of the following types of usage? (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

39a. Occupancy rates of assigned

frequencies

3 14 1 18

39b. Geographic location of frequency

use

11 6 1 18

39c. Temporal usage measurements

(either clock or calendar)

1 15 2 18

39d. Number of frequencies assigned 11 5 2 18

39e. Other 3 3 713

40. Which of the following reasons explains why your agency does not

conduct spectrum usage measurements? (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

40a. Lack of technology or equipment

to conduct measurements

76 5 18

40b. Lack of in-house expertise to

conduct measurements

1 12 5 18

40c. Conflicting mission priorities 8 5 5 18

40d. Limited resources to conduct

measurements

11 3 418

40e. Other factors 8 2 5 15

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nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

Spectrum sharing and use of commercial services:

41. Does the IRAC agency you represent currently share spectrum with

any of the following users? (select one for each row)

Response

Question

Yes No

Don’t

know

No response/not

applicable

Total

responses

41a. Other federal users 17 1 18

41b. Across program offices/

departments within your federal

agency

15 1 2 18

41c. State governments

(including public safety)

13 3 1 1 18

41d. Local governments

(including public safety)

13 41 18

41e. Private industry users 9 9 18

41f. Non-profit organizations 2 12 3 118

41g. Universities and other

educational institutions

13 5 18

41h. Other 3 4 6 13

42. If your agency shares spectrum, please provide examples.

[open-ended]

43. If your agency shares spectrum, how much of an influence, if any, were

the following factors in the agency’s decision to share spectrum?

(select one for each row)

Response

Question

Strong

influence

Moderate

influence

Little influence No influence

No response/not

applicable

Total

responses

43a. Interoperability with

other federal users

13 21218

43b. Interoperability with

nonfederal users

10 3 11 3 18

43c. Improved mission

performance

10 3 3 16

43d. Promoting greater

spectrum efficiency

8 522118

43e. Lower costs 5 4 4 4 17

43f. Other 4 2 6 12

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

44. Does the IRAC agency you represent, utilize any of the following

spectrum sharing technologies? (select one for each row)

Response

Question

Yes No

No response/not

applicable

Total

responses

44a. Software defined radios 4 13 17

44b. Dynamic frequency selection

devices

6 11 17

44c. Cognitive radios 2 15 17

44d. Trunked radio systems 14 3 17

44e. Other 2 8 10

45. Please describe below the challenges, if any, impact your agency’s

ability to use technologies that promote spectrum sharing (such as

software defined radios, dynamic frequency selection devices,

cognitive radios, or trunked radio systems):

[Open-ended]

46. If your agency does not share spectrum, how much of an influence, if

any, were the following factors in the agency’s decision to not share

spectrum? (select one for each row)

Response

Question

Strong

influence

Moderate

influence

Little

influence

response/not

applicable

Total

responses

46a. Concerns over interference 6 3 817

46b. Uncertainty over use/priority 7 2 8 17

46c. Lack of economic incentives 3 3 2 9 17

46d. Lack of staff/expertise 1 8 8 17

46e. Current technology being used at the agency

does not permit sharing

6111 817

46f. Lack of guidance/support from NTIA 4 5 8 17

46g. Existing laws and regulations 3 213 817

46h. Other 1 1 12 14

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nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

47. Does the IRAC agency you represent currently rely on commercial

network service providers to fulfill any of the following services for

mission critical needs and/or administrative needs? (select one for

each row)

Response

Question

Yes No

Don’t

know

response/not

applicable

Total

responses

47a. Administrative needs 16 1 1 18

47b. Mission critical needs 14 3 1 18

47c. Other 3 3 713

48. How much of an influence, if any, were the following factors in the

agency’s decision to use commercial services to provide your spectrum

related needs? (select one for each row)

Response

Question

Strong

influence

Moderate

influence

Little

influence

Don’t

know

No response/not

applicable

Total

responses

48a. Increased

technical efficiency

4 3 3 51 2 18

48b. Reduced costs 8 4 3 1 2 18

48c. Upgraded

technology

3 443 1 2 17

48d. Frequency

assignments were

deleted

2 3 91 3 18

48e. NTIA requirement 2 2 10 2 2 18

48f. Other 5 2 7 14

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix III: Survey of IRAC Agencies

49. How much of an influence did the following concerns have in the

agency’s decision not to use commercial network services for mission

critical needs? (select one for each row)

Response

Question

Strong

influence

Moderate

influence

Little

influence

Don’t

know

No response/not

applicable

Total

responses

49a. Security concerns 9 2 1 2 1 3 18

49b. Lack of

support/guidance from

NTIA

4101 3 18

49c. Cost 2 6 2 3 1 4 18

49d. Budget 4 3 241 3 17

49e. Lack of private

sector capabilities

5 3 421 3 18

49f. Concerns over

coverage and network

reliability

7 3 3 11 3 18

49g. Other 1 1 11 13

50. If you have any additional comments or views regarding federal

spectrum management issues that you’d like to share with us, please

do so below.

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GAO-11-352

nagement of Federally Assigned Spectrum

Appendix IV: Comments from the Department

of Commerce

Appendix IV: Comments from the

Department of Commerce

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GAO-11-352 Management of Federally Assigned Spectrum

Appendix IV: Comments from the Department

of Commerce

Page 67

GAO-11-352

nagement of Federally Assigned Spectrum

Appendix IV: Comments from the Department

of Commerce

Page 68

GAO-11-352

nagement of Federally Assigned Spectrum

Appendix IV: Comments from the Department

of Commerce

Page 69

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nagement of Federally Assigned Spectrum

Appendix IV: Comments from the Department

of Commerce

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nagement of Federally Assigned Spectrum

Appendix V:

GAO Conta

ct and Staff

cknowledgments

Page 71 GAO-11-352

Appendix V: GAO Contact and Staff

Acknowledgments

Mark L. Goldstein, (202) 512-2834 or [email protected]

In addition to the contact named above, Sally Moino, Assistant Director;

Amy Abramowitz; Tida Barakat; Richard Brown; Colin Fallon; Nick

Jepson; Maria Mercado; Josh Ormond; Kelly Rubin; Andrew Stavisky; Hai

Tran; and Mindi Weisenbloom made key contributions to this report.

nagement of Federally Assigned Spectrum

GAO Contact

Staff

Acknowledgments

(543269)

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