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| #         | **COMMENTS OF UNITED STATES ITU ASSOCIATION**            |
| Board of  |                                                          |
| Directors | In response to a request contained in NTIA Docket No.    |
|           | 040127027-4027-01 \"United States Spectrum Management    |
| *Chair*   | Policy For the 21st Century\", the United States ITU     |
|           | Association (USITUA) submits its comments on spectrum    |
| ## Ben    | policy reform. On November 23, 2003, USITUA responded to |
| C. Fisher | an NTIA \"Request for Comments on Improvements to the US |
|           | Preparations Process for World Radiocommunication        |
| Shaw      | Conferences\". It is our view that those comments        |
| Pittman   | contained in an attachment to this document, are still   |
|           | valid and appropriate for consideration by NTIA during   |
| # V       | its spectrum policy review of International Issues       |
| ice Chair | highlighted in item 5 of the \"First Objective\".        |
|           |                                                          |
| ## Gar    | The issues of spectrum policy reform associated with ITU |
| y Fishman | related matters is of continuing importance to USITUA,   |
|           | and we will review the various comments provided to NTIA |
| Lucent    | and reply as deemed appropriate. Further, because many   |
| Tec       | of the findings of this policy investigation may have    |
| hnologies | broad implications, the Association will follow the      |
|           | progress of these efforts regarding domestic and         |
| # Vice    | international change.                                    |
| President |                                                          |
|           | Ben C. Fisher, Chairman                                  |
| ## M      |                                                          |
| ichael T. | Board of Directors                                       |
|  N. Fitch |                                                          |
|           | March 17, 2004                                           |
| The       |                                                          |
| Boeing    | Attachment                                               |
| Company   |                                                          |
|           |                                                          |
| #         |                                                          |
| Treasurer |                                                          |
|           |                                                          |
| ## Thoma  |                                                          |
| s Plevyak |                                                          |
|           |                                                          |
| Verizon   |                                                          |
|           |                                                          |
| #         |                                                          |
| Secretary |                                                          |
|           |                                                          |
| ## Gene   |                                                          |
| Rappoport |                                                          |
|           |                                                          |
| C         |                                                          |
| onsultant |                                                          |
|           |                                                          |
| #         |                                                          |
| Directors |                                                          |
|           |                                                          |
| ##        |                                                          |
|  Audrey L |                                                          |
| . Allison |                                                          |
|           |                                                          |
| The       |                                                          |
| Boeing    |                                                          |
| Company   |                                                          |
|           |                                                          |
| ##        |                                                          |
|  Jennifer |                                                          |
|  Bosworth |                                                          |
|           |                                                          |
| Co        |                                                          |
| mpassRose |                                                          |
|           |                                                          |
| Inter     |                                                          |
| national, |                                                          |
| Inc.      |                                                          |
|           |                                                          |
| **Donald  |                                                          |
| M.        |                                                          |
| Jansky**  |                                                          |
|           |                                                          |
| Jans      |                                                          |
| ky/Barmat |                                                          |
| Telecommu |                                                          |
| nications |                                                          |
|           |                                                          |
| **Julie   |                                                          |
| M.        |                                                          |
| Kearney** |                                                          |
|           |                                                          |
| MCI       |                                                          |
|           |                                                          |
| ## Da     |                                                          |
| vid Leive |                                                          |
|           |                                                          |
| Latham &  |                                                          |
| Watkins   |                                                          |
|           |                                                          |
| ## Mich   |                                                          |
| ael Lynch |                                                          |
|           |                                                          |
| Nortel    |                                                          |
| Networks  |                                                          |
|           |                                                          |
| **Richard |                                                          |
| D.        |                                                          |
| Parlow**  |                                                          |
|           |                                                          |
| C         |                                                          |
| onsultant |                                                          |
|           |                                                          |
| ## Arth   |                                                          |
| ur Reilly |                                                          |
|           |                                                          |
| Cisco     |                                                          |
| Systems,  |                                                          |
| Inc.      |                                                          |
|           |                                                          |
| ## Pau    |                                                          |
| l Rinaldo |                                                          |
|           |                                                          |
| American  |                                                          |
| Radio     |                                                          |
| Relay     |                                                          |
| League    |                                                          |
|           |                                                          |
| **Doug    |                                                          |
| Schoe     |                                                          |
| nberger** |                                                          |
|           |                                                          |
| AT&T      |                                                          |
|           |                                                          |
| ##        |                                                          |
| Jennifer  |                                                          |
| A. Warren |                                                          |
|           |                                                          |
| Lockheed  |                                                          |
| Martin    |                                                          |
|           |                                                          |
| Co        |                                                          |
| rporation |                                                          |
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| #         | **COMMENTS OF UNITED STATES ITU ASSOCIATION**            |
| Board of  |                                                          |
| Directors | The United States ITU Association (USITUA) welcomes the  |
|           | opportunity to respond to the NTIA "Request for Comments |
| *Chair*   | on Improvements to the US Preparations Process for World |
|           | Radiocommunication Conferences". Our association         |
| ## Ben    | consists of approximately 50 members organizations       |
| C. Fisher | heavily involved in ITU activities, including US         |
|           | preparatory work for WRCs, US study groups in the three  |
| Shaw      | ITU sectors and serving as members of the US Delegations |
| Pittman   | to numerous ITU conferences and meetings. Hence, we are  |
|           | vitally interested in the US WRC preparatory process and |
| # V       | applaud the NTIA for initiating this review. The views   |
| ice Chair | expressed herein represent the consensus of our members. |
|           |                                                          |
| ## Gar    | **1. Federal Government Preparation Process**            |
| y Fishman |                                                          |
|           | > **A. How should NTIA as the President\'s advisor seek  |
| Lucent    | > the views and inputs of the**                          |
| Tec       | >                                                        |
| hnologies | > **non-federal entities?** *The FCC's WRC Advisory      |
|           | > Committee (WAC) provides an excellent opportunity for  |
| # Vice    | > the private sector to inform the NTIA and its          |
| President | > constituency agencies of its views on the WRC agenda,  |
|           | > including both government and non-government spectrum  |
| ## M      | > issues.*                                               |
| ichael T. | >                                                        |
|  N. Fitch | > **B. How can NTIA better educate the commercial sector |
|           | > on the federal agencies\' radiocommunication           |
| The       | > requirements, and related policies and decisions that  |
| Boeing    | > affect U.S. conference proposals?** *In recognition of |
| Company   | > the success of the NTIA-initiated "Training Day" prior |
|           | > to WRC-03, the USITUA believes that a similar format   |
| #         | > or approach may be appropriate for NTIA to consider    |
| Treasurer | > for an issues briefing to interested parties. We would |
|           | > recommend that this occur as early in the WRC          |
| ##        | > preparatory process as possible. As elaborated in our  |
| Scott Bla | > response to Question 2, the USITUA encourages NTIA to  |
| ke Harris | > ensure that there be RCS liaisons to the WAC Industry  |
|           | > Working Groups (IWGs) to provide updates on the        |
| Harris,   | > Government's preparations.*                            |
| Wiltshire |                                                          |
| &         | **2. WRC Advisory Committee (WAC) Preparation Process**  |
|           |                                                          |
| Grannis   | **A.** **The WAC is part of the FCC\'s WRC preparation   |
| LLP       | process. How can the federal agencies best participate   |
|           | in the WAC?** *The USITUA welcomes the opportunities     |
| #         | afforded the private sector through the presence of the  |
| Secretary | NTIA and some of its constituent agencies in the WAC and |
|           | its IWGs. We would encourage the NTIA to continue that   |
| ## Gene   | observer role, and even to expand upon it slightly. In   |
| Rappoport | particular, we would urge the NTIA to designate RCS      |
|           | liaisons, responsible for attending each of the IWGs,    |
| Winstar   | and ensure that those liaisons are able to share with    |
|           | industry the progress of comparable WRC issues in the    |
| Commu     | IRAC process. This two-way exchange may facilitate       |
| nications | greater commonality of outputs from both the IRAC and    |
|           | WAC processes.*                                          |
| #         |                                                          |
| Directors |                                                          |
|           |                                                          |
| ##        |                                                          |
|  Audrey L |                                                          |
| . Allison |                                                          |
|           |                                                          |
| The       |                                                          |
| Boeing    |                                                          |
| Company   |                                                          |
|           |                                                          |
| **Donald  |                                                          |
| M.        |                                                          |
| Jansky**  |                                                          |
|           |                                                          |
| Jans      |                                                          |
| ky/Barmat |                                                          |
| Telecommu |                                                          |
| nications |                                                          |
|           |                                                          |
| **Julie   |                                                          |
| M.        |                                                          |
| Kearney** |                                                          |
|           |                                                          |
| MCI       |                                                          |
|           |                                                          |
| ## Mich   |                                                          |
| ael Lynch |                                                          |
|           |                                                          |
| Nortel    |                                                          |
| Networks  |                                                          |
|           |                                                          |
| **Richard |                                                          |
| D.        |                                                          |
| Parlow**  |                                                          |
|           |                                                          |
| C         |                                                          |
| onsultant |                                                          |
|           |                                                          |
| **Thomas  |                                                          |
| Plevyak** |                                                          |
|           |                                                          |
| Verizon   |                                                          |
|           |                                                          |
| ## Arth   |                                                          |
| ur Reilly |                                                          |
|           |                                                          |
| Cisco     |                                                          |
| Systems,  |                                                          |
| Inc.      |                                                          |
|           |                                                          |
| #         |                                                          |
| # Walda W |                                                          |
| . Roseman |                                                          |
|           |                                                          |
| Co        |                                                          |
| mpassRose |                                                          |
|           |                                                          |
| Inter     |                                                          |
| national, |                                                          |
| Inc.      |                                                          |
|           |                                                          |
| **Doug    |                                                          |
| Schoe     |                                                          |
| nberger** |                                                          |
|           |                                                          |
| AT&T      |                                                          |
|           |                                                          |
| ##        |                                                          |
|  Francis  |                                                          |
| S. Urbany |                                                          |
|           |                                                          |
| BellSouth |                                                          |
| Co        |                                                          |
| rporation |                                                          |
|           |                                                          |
| ##        |                                                          |
| Jennifer  |                                                          |
| A. Warren |                                                          |
|           |                                                          |
| Lockheed  |                                                          |
| Martin    |                                                          |
|           |                                                          |
| Co        |                                                          |
| rporation |                                                          |
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**3. FCC/NTIA Proposal Coordination Process**

> **A. Should the federal and non-federal advisory processes remain
> independent? Why or why not?** *Yes. The USITUA recognizes that there
> are many aspects of deliberations about spectrum requirements and
> positions that are related to potentially sensitive system and/or
> equipment procurements that should not be part of the transparency
> requirements of a FACA process -- which enables any entity, foreign or
> domestic, government or non-government, to participate in the WAC
> process. Furthermore, there are often unique USG issues (e.g., space
> sciences), which are much more appropriately addressed in a separate
> process. Finally, we believe that the private sector should also have
> the opportunity to develop its views without the US Government having
> a decisional role in the process. We, nonetheless, repeat our
> suggestion that the NTIA maximize the opportunity for an information
> exchange by creating RCS liaisons to the IWGs.*
>
> **B. Federal views and proposals sent to the FCC represent NTIA's
> review**
>
> **and modification of RCS inputs and thus the Administration's output,
> while the FCC sends WAC views and proposals directly to NTIA for
> consideration without bureau review. Would it improve the process to
> take a similar approach on both sides (circulation of RCS and WAC
> inputs, or circulation of NTIA and FCC outputs)?** *No. The USITUA
> believes that the current process should be retained.*
>
> **C. Please specify how communications/coordination between the FCC
> processes and the Executive Branch processes under the purview of NTIA
> can be improved? Include in your discussion such topics as involvement
> of senior agency management, early agreements on WRC positions,
> NTIA-FCC reconciliation process and timeframes.** *The USITUA believes
> that the recent MoU between the NTIA and FCC establishing regularized
> meetings between the agencies is critical, and should be used on an
> ongoing basis to discuss progress on the US preliminary views and
> proposals for the WRCs as they develop. Moreover, we would encourage
> the NTIA to engage at senior levels in the important regional meetings
> addressing WRC proposals. We also think it would be extremely
> beneficial for the NTIA Assistant Secretary to ensure that his/her
> senior level counterparts in the IRAC agencies have a commensurate
> understanding of the WRC and the issues. Finally, we urge the NTIA to
> continue as it did successfully this year to work with the FCC to
> develop an implementation timeline for WRC decisions. This was a great
> improvement in the post-WRC process, for which both agencies should be
> congratulated.*
>
> **D. What steps can be taken to resolve difficult issues? Should**
>
> **timelines be developed in order to identify these issues early in
> the process?** *The USITUA would support establishment of early
> timelines for resolution or decision-making with respect to
> non-consensus issues. Moreover, we believe the Department of State can
> have an important role in this process, as it has in the past, to
> bridge any impasse. However, we also support the interim step of
> inviting the interested private sector parties to meet with the
> interested government agencies to see if a greater understanding of
> the difficulties of either party can lead to a mutually satisfactory
> compromise. This measure often proved successful during the US WRC-03
> preparations*

**4. Study Group/National Committee Process Related to WRC Agenda
Items**

> **A. Should the U.S. National Committee set objectives and policy
> regarding WRC studies?** *No. But the USITUA would encourage NTIA to
> facilitate to the extent possible effective coordination between the
> domestic and international activities that are related to conference
> preparatory technical work, the RCS and the WAC.*
>
> **B. Is closer coordination among various study groups required? If
> so, why and how can this be accomplished?** *The USITUA believes that
> there could be improved scheduling between the study groups and the
> WAC meetings to maximize participation in both, and minimize impact on
> resources given that many participants (government and industry) come
> from outside of the DC area.*
>
> **C. The U.S. Study Group consists of government and non-government
> participants who prepare for ITU meetings. Should the U.S. Study Group
> process be guided to align with U.S. WRC goals and objectives? If so
> why, and by what means?** *No. The study groups have much broader
> roles and agendas, thus participation, than the WRC preparation and
> issues. They are not exclusively focused on accomplishing the tasks
> set forth by the WRC.*
>
> **D. Should a federal government/non-government position on agenda
> items and supporting information/studies to pursue U.S. positions be
> developed, approved and disseminated?** *No, for the reasons set forth
> in the answer to 4E, below.*
>
> **E.** **To ensure success of U.S. objectives for WRC agenda items,
> technical studies must begin early in the process. Is it necessary to
> energize an agenda item and its associated studies by a certain point
> in the preparation process if no activity has occurred? If so, how can
> this be accomplished (e.g., what mechanisms and by what point in
> time)?** *No. The USITUA believes that self-interest is perhaps the
> appropriate motivator for action on any agenda item. Therefore, if
> there is not sufficient government or commercial interest in
> undertaking the relevant studies necessary to advance or impact an
> agenda item, then the agenda item should be allowed to die a natural
> death.*

**5. Forming the WRC Delegation**

> **A. Is there a lack of continuity in leadership between WRC
> conferences? If so, how can this be better managed?** *Yes. The USITUA
> has previously submitted recommendations to the NTIA, Department of
> State and FCC with respect to ways to improve the domestic preparatory
> process, including issues pertaining to the delegation. (see
> Attachment A) The USITUA believes that the lack of continuity in any
> senior (SES or political) level role in the WRC does create a hurdle
> for the US. Fortunately, the US has generally overcome such
> self-created discontinuities, but the USITUA would recommend ways to
> avoid them. One option may also be that there be at least a permanent
> (SES level) senior Vice-Chair at the Department of State tasked to
> ensure continuing relationships in the WRC interims and through the
> regional group meetings.*
>
> **B. When in the preparation process should the core delegation group,
> vice-chairs, and principals be formed to begin work? How can these
> groups be better used to improve the effectiveness and efficiency of
> the United States' WRC agenda?** *The USITUA supports the early
> formation of a core delegation among the USG, to include spokespeople,
> in order to provide an opportunity for team-building and the
> development of substantive expertise on assigned agenda items. We
> would also support consideration of a private industry representative
> liaison to that core delegation -- the chair or vice-chair of the WAC.
> We would suggest at a minimum that the core delegation be formed prior
> to the CPM-2 to enhance the US performance there.*
>
> **C. Agencies, companies, and organizations nominate representatives
> to**
>
> **be on the U.S. WRC delegation. Is the nominated delegation formed
> early enough in the process to develop and approve final positions in
> a timely manner? If not, how can this process be improved?** *No. The
> USITUA recommends that the nominated delegation be formed as early as
> possible, perhaps prior to the CPM-2; however, a nominated delegation
> does not and should not supplant the need for an accredited delegation
> to be in place no later than approximately four months prior to the
> conference so that we can deal with positions, strategies and
> fallbacks in an appropriate manner subject to accredited delegation
> strictures, such as confidentiality.*
>
> **D. Is the accredited delegation formed early enough to develop and**
>
> **approve U.S. positions, strategy, and fallback positions? If not,
> how can this be improved?** *No. The accredited delegation needs to be
> formed approximately four months prior to the conference at a minimum.
> The final strategies and positions are often developed at the last
> minute with great time pressure. Moreover, it is not appropriate to
> substitute the "nominated" delegation for the role of the accredited
> delegation given the lack of obligations associated with being a
> member of the former.*
>
> **E. At what point in the preparation process should delegation
> assignments be made and spokespersons identified?** *As early as
> possible. It is critical for spokespeople to be identified early on so
> as to know which issues for which they need to develop a particular
> expertise and fluency for both managing the issue on the US Delegation
> as well as managing the issue externally and the associated public
> speaking. It also allows for early team building with the interested
> US parties.*
>
> **F. How could the appointment and role of the U.S. Ambassador be
> improved?** *The USITUA believes the role of the Ambassador could be
> enhanced in several ways. First, a one-year term starting 4-6 months
> prior to CPM-2, enabling the individual to be educated on the issues,
> the politics, the regional bodies, and the institution so as to be
> able to meaningfully attend the CPM in part or in whole. Second, the
> USITUA believes that the role would be enhanced by ensuring that there
> are adequate funds for WRC outreach and travel, so critical to
> obtaining support for US objectives at the WRC.*
>
> **G. Is the United States\' negotiating strength improved or hindered
> by the use of an appointed political representative working with
> career spectrum managers and ITU experts from other countries?**
> *Both. It may be more hindered than improved if there is not adequate
> time to educate the Ambassador sufficiently for the person to develop
> a satisfactory comfort level on the controversial issues so as to
> recognize when to delegate responsibly and to understand when it is
> critical to intervene personally. The majority of issues do not rise
> to the political level, but those that do are assisted by the presence
> of a political Ambassador, again when that Ambassador either through
> pre-existing competencies or sufficient lead time is adequately
> familiar with the issues and policies at stake.*
>
> **H. Assuming the continued appointment of a WRC ambassador, at what
> point does the Ambassador\'s appointment need to be effective?** *One
> year ahead of the conference for the reasons we have stated in answers
> above.*
>
> **I. During conference preparatory meetings, administrations meet to
> agree on the final report of studies, which is used as the technical
> basis at a WRC. Is it important to bring the Ambassador on board in
> some capacity prior to the conference preparatory meeting? If so, how
> can this be accomplished?** *Yes. The USITUA believes that a statutory
> exemption may be appropriate for this position, or, as a fallback
> alternative, as either an appointee or consultant in the Department of
> State so that there is expertise and travel budget available to
> support the Ambassador to-be's activities.*

**6. Budgeting WRC Activities**

> **A. Funding for the WRC Ambassador has been an ongoing concern. To
> ensure the Ambassador and the delegation staff are able to complete
> their missions, is it necessary to provide the Ambassador with an
> operational budget? If so, how can representational funds best be used
> to conduct outreach efforts?** *The USITUA believes it is necessary
> and critical to provide the Ambassador with an operational budget that
> is immediately available upon appointment (if not upon nomination or
> some other designated capacity). One potential way of ensuring
> available monies is for Congress to earmark WRC accounts for all three
> agencies. The Ambassador's outreach efforts should comprise travel to
> specific regions, and associated regional meetings, as well as various
> hosting opportunities for informal dialogue among the Ambassador and
> staff and his/her counterparts in other Administrations.*
>
> **B. What facilities are critical to the functioning of the delegation
> and the Ambassador at the conference site?** *The USITUA believes that
> facilities comparable to those administered by the Department of State
> at WRC-03 are representative of the requirements of the delegation and
> Ambassador, and should be arranged as far in advance as possible. It
> was very helpful that the Ambassador have a separate office removed
> from the US Delegation office, where private meetings with foreign
> delegates could occur without the background noise of the delegation.
> Moreover, it was also important to have the common delegation
> facilities, IT infrastructure, and human resources which are critical
> when trying to ensure government and private sector coordination on
> issues, and doing so in parallel on both sides of the Atlantic (or
> wherever the WRC venue may be). We would encourage the USG agencies,
> however, to ensure that all spokespeople are provided with cell phones
> and laptops as connectivity and availability are critical to our
> success.*
>
> **C. Recognizing that agencies and companies send representatives to
> the delegation to participate in debates, negotiations, and outreach
> efforts, how should support be provided to cover the Editorial
> Committee of each WRC?** *Based on its members' experience, the USITUA
> believes that there should be single US Government official (not a
> private sector person) designated as responsible for coordinating US
> participation on the Editorial Committee. Moreover, the USG should
> ensure that delegate (both private and government) understand that it
> is an obligation accompanying the privilege of serving on the
> delegation to assist when requested on the Editorial Committee.
> However, given the perennial importance of the committee, all of the
> agencies should seek to hire or train individuals in French and/or
> Spanish. The scarcity of government employees with linguistic
> capabilities has been a long-standing weakness of US delegations to
> ITU treaty conferences and should be remedied.*

**7. Outreach and Consultations with Other Countries**

> **A. Are consultations with other administrations needed? If so, at
> what point in the process should they begin?** *Yes, they are
> critical. The USITUA believes that consultations are two-part. The
> first should occur very early in the process, perhaps well prior to
> the US having established proposals. It should be a listening session
> where the US reaches out to the different regions, and individual
> opinion-leaders in those regions, to understand their priority areas.
> The second phase would be to consult on our proposals to try to obtain
> support for them prior to the WRC, and if possible even prior to
> CPM-2.*
>
> **B. Is it important to work with other countries outside of the ITU
> study groups and the conference preparatory meeting? If so, why and
> how can this be improved?** *Yes. Participation in study groups is
> limited in terms of broad country representation. Regional group
> meetings offer ideal opportunities to meet with both leaders as well
> as working level staff, and demonstrate the US' interest in others
> views. This is an important initial step in building common proposals
> within and across regions. The US' consistent engagement and
> leadership in the CITEL process, as well as participation with other
> regional processes was a central factor in its many successes at
> WRC-03.*
>
> **C. Should the Country Contact/Outreach program that is developed and
> utilized at a conference be maintained between conferences? If so, how
> can this be accomplished? Who should lead this effort? What role can
> the private sector play?** *No. This is not practical, at least with
> private sector responsibility as is the case at the Conference itself.
> However, the private sector should be considered for inclusion in US
> delegations to regional prep meetings outside of the CITEL meetings.*
>
> **D. Should WRC outreach activities be integrated with other
> international activities of the State Department, NTIA and FCC? If so,
> how?** *Yes. The USITUA believes that a standing topic for discussion
> at every bilateral or regional meeting with State, NTIA or FCC should
> be the WRC.*
>
> **E. How effective were the Delegation Consultations prior to WRC-03?
> Were they started in a timely manner?** *They were very effective,
> building good relationships, in part assisted by the fact that the
> late-appointed Ambassador to WRC-03 was a known and respected figure
> in the international telecommunications community, and the ITU. It
> would have been better, however, if this appointment would have been
> made earlier.*

**8. Training**

> **A. Are trained and qualified Federal Government Spokespersons and
> issue coordinators available throughout the WRC preparatory process
> and especially at the Conference?** *The USITUA believes that the
> coordinators and spokespersons are qualified, but are not provided
> meaningful training in preparation for their roles.*
>
> **B. Are training programs needed for spokespersons and delegates? If
> so, what should they consist of?** *Yes, particularly for
> spokespersons. First, the USITUA applauds again the Training Day in
> preparation for WRC-03 and encourages that to be repeated. However,
> appropriate public speaking and international negotiations training
> should be offered to, and required of, the US Spokespersons. In
> addition, the USITUA believes that language training ought to also be
> afforded to career WRC staff.*
>
> **C. Is preparatory training needed for general participation in ITU-R
> Study Groups in support of WRC activities? If so, what should it
> consist of?** *Yes. The USITUA believes that on the job training is
> critical to developing the fluency on the issue that many of our
> foreign counterparts have. Therefore, staff should be sent to SG
> meetings along with experienced staff to benefit from mentoring and
> training on site. This is an approach that Canada has taken, and with
> excellent results.*
>
> **D. What steps should be taken to maintain a cadre of experienced
> personnel in the federal government in order for them to assume
> leadership and spokesperson roles at future WRCs?** *The USITUA
> believes that the USG should find ways to recognize the importance of
> these WRC roles.*

**9. WRC Domestic Implementation Process.**

> **A. In the past, the United States has been faced with challenges
> regarding the implementation of WRC decisions. What can be done to
> improve this process?** *The USITUA believes that the FCC and NTIA
> have taken significant steps to improve this process. The decision
> implementation process has in the past been at best uneven, and often
> languished in the aftermath of the WRCs. However, the USITUA commends
> both agencies for having taken a very pro-active step of establishing
> a clear and transparent timeline for implementation of WRC-03
> decisions and the outstanding ones from prior conferences. This
> process should somehow be memorialized so that it does not remain ad
> hoc.*
>
> **B. The GAO report noted that federal agencies are concerned that WRC
> allocation decisions of primary interest to the federal government go
> without action, how can the process be improved to ensure equal
> treatment of both government and private sector interests?** *There
> should be an elimination of any distinction between such allocations,
> as industries are dependent on opportunities derived from
> implementation of both. Timely implementation of both is critical. The
> USITUA believes that the establishment of a consensus timeline between
> the two agencies should eliminate the acknowledged problems of the
> past.*
>
> **C. Should FCC/NTIA develop a plan and schedule to complete
> rulemaking for each WRC agenda item? If so, within what timeframe of
> WRC completion should the plan be executed?** *Yes. We would recommend
> that the timeline be announced within 3-6 months of the close of the
> WRC, with complete implementation within 18-24 months. Ideally, the US
> would implement WRC decisions in time for the Final Acts' entry into
> force.*

**General Areas**

> **A. In broad terms, what goals should the United States have for
> WRCs? How should these goals be established?** *The USITUA believes
> that the goals should be to protect and advance US interests writ
> broadly, to be specific at individual conferences. These interests are
> established through the existing proposal and agenda setting
> processes.*
>
> **B. How effective has the United States been in the WRC process?**
> *On the whole, the US is generally quite effective, but often at
> greater cost than perhaps necessary given some of the hurdles that we
> create for ourselves -- these hurdles are laid out in the answers to
> many of the questions above dealing with funding, timing of ambassador
> appointment, etc...*
>
> **C. What have been the benefits and costs of regional preparation for
> WRCs?** *The benefits of full participation in the regional
> preparatory processes (including processes for the Americas, Europe,
> Asia/Pacific, the Arab States, and Africa) far outweigh the costs of
> such participation. The WRC is becoming increasingly regionalized,
> with regions coalescing on proposals and positions prior to the WRCs,
> and then reaching out to each other to form alliances. Their import
> cannot be underestimated. . The experience of WRC-03 is quite
> instructive on how timely engagement and leadership in the regional
> processes can yield successful outcomes on US proposals. The USITUA
> believes that this should form the baseline for future US WRC
> preparation activities.*
>
> **D. How often should WRCs occur and what, if any, limitations should
> the U.S. support regarding WRC agendas.** *The USITUA believe that
> WRCs should occur often enough to meet the needs of both USG and
> industry interests, while leaving sufficient time to undertake and
> complete the necessary technical preparatory work to support the
> agenda items.*
>
> **E. Over the years, there has been concern among WRC participants
> (government and non-government) regarding staffing issues. Do NTIA and
> the federal agencies have sufficient staff with appropriate expertise
> to support spectrum management activities in the WRC preparation
> process?** *No, as a general matter. There is not enough training to
> account for, and replace, retiring expertise. Moreover, when the
> agenda is diverse and multifaceted, it is difficult to adequately
> cover some of the issues. Finally, the USITUA believes that it is
> critical for the agencies to begin to develop additional staff
> expertise in the regulatory and procedural aspects of a conference;
> while there is recognized expertise that is well-established at both
> State and NTIA, it is concentrated in a limited number of staff.*

Jennifer A. Warren, Chair

Committee on U.S. WRC Preparatory Process

Ben C. Fisher, Chairman

Board of Directors

November 24, 2003