INTERNET OF 

THINGS

FCC Should Track 

Growth to Ensure 

Sufficient Spectrum 

Remains Available

Report to Congressional Requesters

November 2017

GAO-18-71

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-71, a report to 

congressional requesters 

November 2017

INTERNET OF THINGS

FCC Should Track Growth to Ensure Sufficient 

Spectrum Remains Available 

What GAO Found

The stakeholders GAO spoke with identified two primary spectrum-related 

challenges for the internet of things (IoT)—the availability of spectrum and 

managing interference. Although not considered an immediate concern, Federal 

Communications Commission (FCC) staff and some stakeholders noted that 

rapid increases in IoT devices that use large amounts of spectrum—called highbandwidth devices—could quickly overwhelm networks, as happened with smart 

phones. Stakeholders and FCC staff also indicated that managing interference is 

becoming more challenging as the number of IoT and other wireless devices 

grows, particularly in bands that do not require a spectrum license. The figure 

below illustrates the uses of radio frequency spectrum, including unlicensed use.

Examples of Commercial Uses of Radio Frequency Spectrum in the United States

FCC plans for IoT’s spectrum needs by broadly tracking spectrum demand and 

making additional spectrum available as needed. Ensuring sufficient spectrum to 

support commercial demand is one way FCC pursues its strategic goal of 

promoting economic growth. FCC has made additional spectrum publicly 

available at least four times since 2015 by repurposing over 11 gigahertz of 

spectrum. However, FCC does not track the growth of IoT devices in two areas

that pose the greatest risk to IoT’s growth—high bandwidth and unlicensedspectrum devices. In 2014, FCC’s Technical Advisory Council (TAC) 

recommended that FCC monitor high-bandwidth IoT devices and make sufficient 

unlicensed spectrum available. FCC officials said that FCC monitors spectrum 

use broadly and makes spectrum available as needed. However, since the 

process of reallocating spectrum is lengthy, FCC may not have adequate time to 

take actions to avoid a shortage, possibly hindering IoT’s growth and associated 

economic growth.

Spectrum planners in four leading countries—France, Germany, the 

Netherlands, and South Korea—have taken steps similar to those taken by the 

United States in preparation for IoT’s expansion, including taking a technologyneutral approach that stakeholders believe encourages innovation. Unlike the 

United States, officials from two leading countries said they are concerned about 

spectrum congestion from the growth of IoT devices, but only one is actively 

monitoring congestion. In addition, three leading countries have developed 

nationwide low power wide-area networks that use unlicensed spectrum with 

potential benefits including low costs and low barriers to entry.

View GAO-18-71. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov. 

Why GAO Did This Study

IoT generally refers to devices (or 

“things”), such as vehicles and 

appliances, that use a network to 

communicate and share data with each 

other. The increasing popularity of 

wireless IoT devices that use spectrum 

has created questions about spectrum 

needs. GAO was asked to examine 

issues related to spectrum and IoT. 

This report discusses, among other 

things, (1) spectrum challenges related 

to IoT, (2) how the federal government 

plans for IoT’s spectrum needs, and (3) 

how selected leading countries prepare 

for IoT’s spectrum needs. 

GAO reviewed documents and 

interviewed officials from FCC and the

National Telecommunications and 

Information Administration as well as 

24 officials from a variety of sectors, 

including government, commercial, and 

manufacturing. Stakeholders were 

selected based on a literature review, 

among other factors. GAO interviewed 

government and commercial 

representatives from four leading 

countries regarding IoT planning and 

development and reviewed associated 

documents. These countries were 

selected based on criteria that included 

level of economic development among 

other criteria. 

What GAO Recommends

FCC should track the growth in (1) 

high-bandwidth IoT devices and (2) IoT 

devices that rely on unlicensed 

spectrum. FCC did not believe these 

actions are necessary but noted that it 

would ask its TAC to periodically 

review and report on IoT’s growth. 

GAO continues to believe the 

recommendations are valid.
Page i GAO-18-71 Internet of Things

Letter 1

Background 4

Selected Stakeholders Identified Spectrum Availability and 

Managing Interference as Challenges Affecting IoT Devices 10

The Federal Government Has Plans to Meet Spectrum Needs but 

Does Not Track IoT Devices That Could Cause Congestion 13

Selected Leading Countries Vary in Spectrum-Planning 

Approaches for IoT 19

Conclusions 25

Recommendations 25

Agency Comments and Our Evaluation 26

Appendix I Objectives, Scope, and Methodology 28

Appendix II Agencies, Organizations, and Individuals GAO Interviewed 32

Appendix III Regional Spectrum-Management Associations and Their Member 

States 34

Appendix IV Comments from the Federal Communications Commission 37

Appendix V GAO Contact and Staff Acknowledgment 39

Tables

Table 1: Examples of the Federal Communications Commissions’ 

(FCC) Efforts to Repurpose Spectrum 14

Table 2: Spectrum Studies Currently Being Conducted by National 

Telecommunications and Information Administration 

(NTIA) 17

Table 3: Spectrum Planning in Selected Leading Countries 20

Table 4: Spectrum Management Approaches in Selected Leading 

Countries 23

Contents
Page ii GAO-18-71 Internet of Things

Table 5: Agencies, Organizations, and Individuals GAO 

Interviewed Regarding the Spectrum Needs of the 

Internet of Things (IoT) in the United States 32

Table 6: Foreign and International Agencies and Organizations 

GAO Interviewed Regarding the Spectrum Needs of the 

Internet of Things (IoT) 32

Table 7: Regional Spectrum Management Associations and Their 

Member States 34

Figures

Figure 1: Internet of Things Devices and Their Network 

Characteristics 6

Figure 2: Examples of Radio Frequency Spectrum’s Commercial 

Uses 8

Abbreviations

5G fifth-generation mobile wireless technology

FCC Federal Communications Commission

GHz gigahertz

IoT Internet of Things

ITU International Telecommunication Union

kHz kilohertz

LPWAN low power wide-area network

MHz megahertz

OECD Organisation for Economic Cooperation and Development

NTIA National Telecommunications and Information

Administration

RFID radio-frequency identification

SAS Spectrum Access System

TAC Technical Advisory Council

WRC World Radio Conference

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-18-71 Internet of Things

441 G St. N.W.

Washington, DC 20548

November 16, 2017

The Honorable Darrell Issa

Chairman

Subcommittee on Courts, Intellectual Property and the Internet

Committee on the Judiciary

House of Representatives

The Honorable Suzan K. DelBene

Member

House of Representatives

The number of connected devices—ranging from goods like phones and 

cameras to connected vehicles to automated manufacturing facilities—is 

currently estimated in the billions and rising. The Internet of Things (IoT) 

generally refers to these connected devices (or “things”) that use a 

network to communicate with one another and process data. These 

connected devices are integrated into the daily activities of consumers, 

businesses, and government. For example, wearable IoT devices enable 

users to track information about their health and fitness activities. In 

agriculture, IoT technology can analyze soil quality and harvest yield to 

automatically deposit seed in fertile parts of a field. Further, some cities 

now use connected traffic sensors to monitor traffic flow and air quality. 

These devices may connect to networks through a wired connection, but 

the trend in new technology is increasingly to connect wirelessly. 

Connected wireless devices use radio frequency spectrum (spectrum) to 

communicate.1 Wireless communications allow devices to remain 

connected while mobile but also allow connected devices in locations 

where a wire may not be possible. While specific estimates vary, wireless 

IoT devices are expected to grow exponentially and this means many 

more devices using spectrum. Some experts forecast 25–50 billion 

devices will be competing for spectrum by 2025. Continued growth in the 

number of connected devices could require more spectrum be made 

available or more efficient ways of using available spectrum, more 

spectrum sharing, or a combination of all three.

 1

Radio frequency spectrum is a finite natural resource of electromagnetic radiation lying 

between the frequencies of 3 kilohertz and 300 gigahertz. Spectrum is necessary for 

essential government functions and missions such as national defense, homeland 

security, weather services, and aviation communication, as well as commercial services 

such as television broadcasting and mobile voice and data.

Letter
Page 2 GAO-18-71 Internet of Things

The National Telecommunications and Information Administration (NTIA) 

within the Department of Commerce and the Federal Communications 

Commission (FCC) are responsible for managing spectrum within the 

United States. FCC manages spectrum used for consumer, commercial, 

and state and local public safety purposes, and NTIA oversees spectrum 

used by the federal government. Both are responsible for planning ways 

to meet increasing demands for spectrum created by IoT and other 

wireless devices. You asked us to examine the challenges facing federal 

spectrum managers and the steps they are taking to address those 

challenges. In this report we discuss: (1) the spectrum-related challenges 

selected stakeholders identified due to the anticipated growth of IoT, (2) 

steps the federal government is taking to plan for the anticipated growth 

in the demand for spectrum as a result of IoT, and (3) efforts that selected 

leading countries are undertaking to plan for IoT’s spectrum needs and 

ways that these efforts compare with those of the United States.

To identify the spectrum-related challenges stemming from the expected 

growth of IoT, we conducted interviews and reviewed relevant hearings, 

reports and literature.2 We identified relevant stakeholders (1) by 

reviewing comments submitted to NTIA in response to its request for

comment on the government’s role in planning for IoT growth,3 (2) by 

reviewing records of three congressional hearings related to IoT growth, 

and (3) by conducting a review of literature on topics that encompassed 

academic articles, government reports, and trade journals. We conducted 

24 telephone, and in-person interviews with stakeholders, including 

industrial and commercial users of IoT, nonprofit groups, subject matter 

experts, manufacturers, and telecommunications companies and FCC 

and NTIA regarding the spectrum-related challenges presented by the 

anticipated growth in IoT. The views of these stakeholders are not 

generalizable to those of all IoT stakeholders in the United States; 

however, we believe that these interviews provide a balanced and 

informed perspective on the topics discussed. We then analyzed the 

results of these interviews and related documents to identify the main 

themes and develop summary findings. To characterize the views 

captured during the interviews, we defined the terminology used to 

quantify the views as follows:

 2

See appendix II for a list of all organizations and individuals interviewed for this report. 

3

NTIA, “Request for Comments on the Benefits, Challenges, and Potential Roles for the 

Government in Fostering the Advancement of the Internet of Things,” January 12, 2017.
Page 3 GAO-18-71 Internet of Things

• “most” users represents 18 to 24 users,

• “a majority of” users represents 11 to 17 users,

• “several” users represents 6 to 10 users, and

• “some” users represents 3 to 5 users.”

Further, we reviewed the previously mentioned hearings, reports, and 

journals for additional insight on the spectrum challenges related to IoT 

and to understand the projected growth of IoT devices. We also reviewed 

literature concerning the growth of wireless devices, such as smart 

phones, to determine if there are any lessons learned from the demand 

these devices placed on spectrum that could be applied to the expected 

growth of IoT. To identify the steps FCC and NTIA are taking to plan for 

the anticipated growth in the demand for spectrum as a result of IoT, we 

interviewed FCC and NTIA officials and reviewed relevant agency 

documents including reports and plans. We compared FCC’s and NTIA’s 

efforts against their strategic goals and federal internal control standards 

for identifying, analyzing, and responding to risks to achieving agency 

objectives.

To identify the efforts that selected leading countries are undertaking to 

plan for IoT’s spectrum needs and ways that these efforts compare with 

those of the United States, we identified leading countries by reviewing 

trade journals, industry publications, foreign governments’ websites and 

publications, and asking the stakeholders identified above. Through this 

process, we identified seven countries of potential interest, all of which 

have conducted spectrum planning in support of IoT: China, France, 

Germany, Netherlands, Japan, Singapore, and South Korea. We selected 

four of these countries—France, Germany, the Netherlands, and South 

Korea—as having similarities to the United States and being leaders in 

IoT development, based on additional criteria including the level of their 

economic development, the maturity of their telecommunications 

infrastructures, and the comparability of their governments to the United 
Page 4 GAO-18-71 Internet of Things

States and the accessibility of their spectrum planning information.4 We 

reviewed documents and conducted telephone and written interviews with 

officials from the spectrum management agencies in each of these four 

countries. We also conducted eight telephone and written interviews with 

officials from telecommunications companies in these four countries, with 

IoT manufacturers, and with officials from international spectrum planning 

groups to gather information about IoT development, challenges, and 

responses to these challenges in the leading countries that we contacted. 

While the experiences of the interviewees are not generalizable to those 

of all spectrum-planning officials and IoT stakeholders worldwide, we 

believe that the information we gathered from them provides a balanced 

and informed perspective on the topics discussed. See appendix I for 

completed scope and methodology.

We conducted this performance audit from August 2016 to November 

2017 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.

Spectrum is a natural resource used to provide a variety of 

communication services to businesses and consumers, as well as 

federal, state, and local governments. Businesses and consumers use 

 4

We categorized a country’s economy as fully developed if the United Nations Statistics 

Division categorized it in 2016 as existing in a developed economic region. When 

determining the maturity of a country’s telecommunications infrastructure, we followed the 

United Nations’ International Telecommunication Union (ITU) in categorizing a country’s 

telecom infrastructure as mature if it was included in the top quartile of the 175 countries 

ranked in ITU’s 2016 Information and Communications Technology Development Index. 

We considered a country to have a government structure comparable to that of the United 

States if Freedom House’s 2016 Freedom in the World report rated it as “free” and the 

Polity Project categorized it as a “democracy” in 2015. Freedom House’s Freedom in the 

World report and Polity’s Polity IV data series are resources for measuring the levels of 

democracy present in a country. 2015 and 2016 were the most recent versions of these 

documents available when these decisions were made. While the United Nations 

Statistics Division classifies South Korea’s economy as still developing, the fact that it was 

first in the ITU’s ranking led us to include it in our study. Freedom House, “Anxious 

Dictators, Wavering Economies: Global Freedom Under Pressure.” Freedom in the World 

2016, accessed January 15, 2017, https://www.freedomhouse.org/report/freedomworld/freedom-world-2016. Center for Systemic Peace, The Polity Project, accessed 

January 15, 2017, http://www.systemicpeace.org/polityproject.html.

Background
Page 5 GAO-18-71 Internet of Things

spectrum for a variety of wireless services including mobile voice and 

data, WiFi- and Bluetooth-enabled devices, broadcast television, radio, 

and satellite services. Federal, state, and local governments’ uses of 

spectrum include national defense, law enforcement communication, airtraffic control, weather services, military radar, and first responder 

communications. IoT applications that rely on spectrum are highly diverse 

and include connected vehicles, devices in the home, and personal 

mobile devices.5 IoT devices communicate using wireless networks, 

including wide area networks that use cellular networks to cover large 

areas (e.g., cellular transmission), local area networks that cover about 

100 meters (e.g., Wi-Fi within a house), and personal networks covering 

about 10 meters (e.g., Bluetooth inside a room) (see fig. 1).

 5

Connected vehicles share data wirelessly among vehicles or between vehicles and 

infrastructure using dedicated short-range communications, a technology similar to Wi-Fi 

that offers a link through which vehicles and infrastructure can transmit messages over a 

range of about 300 to 500 meters (about 1,000 to 1,600 feet).GAO, Intelligent 

Transportation Systems: Vehicle-to-Vehicle Technologies Expected to Offer Safety 

Benefits, but a Variety of Deployment Challenges Exist, GAO-14-13 (Washington, D.C.: 

November 2013).
Page 6 GAO-18-71 Internet of Things

Figure 1: Internet of Things Devices and Their Network Characteristics

Each of these wireless devices, like other wireless IoT devices, 

communicates using spectrum, and the number of connected devices is 

expected to increase. In 2013, the number of devices connected to the 

internet globally was estimated to be over 9 billion.6 In 2015, the 

Organisation for Economic Cooperation and Development (OECD) 

estimated that a family of four had an average of 10 devices connected to 

the Internet in their household, and that this average will increase to 50 

 6

McKinsey Global Institute, The Internet of Things: Mapping the Value Beyond the Hype 

(2015) and Joseph Bradley, Joel Barbier, and Doug Handler, Embracing the Internet of 

Everything to capture your share of $14.4 trillion (Cisco: 2013).
Page 7 GAO-18-71 Internet of Things

devices by 2022.7 As companies bring new IoT technologies and services 

to market and government users develop new mission needs, the 

demand for spectrum will increase.

The frequencies, or frequency bands, of spectrum have different 

characteristics that make them more or less suitable for specific 

purposes, depending on the specific band (see fig. 2). These bands have 

different levels of ability to penetrate physical obstacles and cover 

distances, known as “propagation,” and different limits to the amount of 

information that they can carry, known as data capacity, and are used for 

different communication purposes. Low frequency bands are 

characterized by strong propagation, and are used by numerous IoT 

devices, some of which may only transmit small amounts of information 

such as temperature, location, or activity status.8 The strong propagation 

of low bands means they can transmit over long distances. Mid-band 

frequencies have higher data capacity than low bands (because, in part, 

frequency allocations in higher bands are larger, allowing wider 

channels), as well as, stronger propagation qualities than higher bands. 

The bands above 30 GHz have high data capacity but relatively poor

propagation, to the point that bands at the highest frequencies can be 

easily obstructed. This spectrum is currently used by a variety of services, 

including satellite, fixed microwave, and radio astronomy, and is expected 

to be important for the next generation wireless technology (5G).9

 7

This estimate applies to an average family of four located in OECD countries. OECD has 

35 member countries that include many of the world’s most advanced countries, emerging 

countries, and countries with emerging economies. OECD, OECD Digital Economy 

Outlook 2015 (Paris: OECD Publishing, 2015). 

8

Radio frequencies are grouped into bands and are measured in units of Hertz, or cycles 

per second. The term kilohertz (kHz) refers to thousands of Hertz, megahertz (MHz) refers 

to millions of Hertz and gigahertz (GHz) to billions of Hertz. The Hertz unit of 

measurement refers to both the quantity of spectrum (such as 75 MHz of spectrum) and 

the frequency bands (such as the 5.850 – 5.925 GHz band). Spectrum at lower 

frequencies is valuable because signals are able to travel greater distances, thus requiring 

providers to build fewer antenna; high-frequency signals cannot go around obstacles but 

scatter away, and can be weakened by atmospheric absorption, requiring more antennae.

9

5G refers to the fifth generation of mobile wireless technology. 
Page 8 GAO-18-71 Internet of Things

Figure 2: Examples of Radio Frequency Spectrum’s Commercial Uses

Notes: The radio frequency spectrum lies between the frequency limits of 3 kHz and 300 GHz. For 

illustrative purposes, we are only showing a portion of the full radio frequency spectrum.

This graphic is for illustration purposes and is not intended to be a comprehensive list of all 

allocations and uses.

An interactive graphic on spectrum uses can be viewed at http://www.gao.gov/products/GAO-18-71

FCC is the federal agency responsible for allocating spectrum for various 

consumer and commercial purposes, assigning spectrum licenses, and 

making spectrum available for use by unlicensed devices. Licensing 

assigns frequencies of spectrum, in a specific area, to a specific entity, 

such as a telecommunications company that operates a network using 

licensed spectrum. We refer to these bands as licensed spectrum. In 

some frequency bands, FCC authorizes unlicensed use of spectrum 

bands—generally referred to as unlicensed spectrum—that is, users do 

not need to obtain a license to use spectrum. Rather, users of unlicensed 

devices can share frequencies on a non-interference basis, such as with 
Page 9 GAO-18-71 Internet of Things

home wireless networks, cordless phones, and garage door openers.10 In 

addition, FCC supports federal emergency-communications activities.

NTIA is responsible for establishing policy on regulating federal spectrum 

use, assigning spectrum bands to government agencies, and maintaining 

spectrum use databases. Additionally, like FCC, NTIA participates in 

federal emergency communications activities. NTIA also determines what 

spectrum bands reserved for the federal government can be made 

available for commercial use.

In managing spectrum, one factor that FCC and NTIA consider is the 

potential for interference. Harmful interference occurs when two 

communication signals are either at the same frequencies or close to the 

same frequencies in the same vicinity, a situation that may lead to 

degradation of a device’s operation or service. Co-channel interference 

occurs when two communications systems operate on the same 

frequency assignment in the same vicinity. Adjacent band interference 

occurs between two communication systems operating on different, but 

adjacent frequencies in the same geographic area. Another source of 

interference can be signals on adjacent spectrum bands leaking into 

another band.

FCC and NTIA work to make more efficient use of spectrum that has 

been assigned. One means of more efficiently using spectrum is to share 

it, between and among both federal users and commercial users. In 2017, 

FCC and NTIA continued oversight of the development of a newspectrum sharing mechanism called the Spectrum Access System (SAS) 

in the 3.5 GHz band. Among other things, the SAS allows multiple users 

access to the same band at different times or places. Within this spectrum 

band the SAS establishes a three-tiered system of access priority, with 

federal and non-federal incumbent users having first priority, new nonfederal users who have paid for licensed access as second priority, and 

other users as third priority. This system relies on the SAS to assign 

frequencies by determining if a frequency is in use by a higher priority 

user before assigning it to a lower priority user.

 10A non-interference basis refers to the shared use of a band together with other users, 

under the conditions that unlicensed devices cannot cause interference to licensed 

operations nor are they protected from any interference received.
Page 10 GAO-18-71 Internet of Things

Stakeholders representing IoT network providers, device manufacturers, 

users, and federal regulators consistently identified two spectrum-related 

challenges to the continued growth and development of IoT 1) ensuring 

the availability of sufficient spectrum and 2) managing the harmful 

interference from the increasing number of IoT devices.

While not currently a crisis, the stakeholders we spoke to agreed that 

ensuring the availability of sufficient amounts and the right kinds of 

spectrum is a key challenge for supporting the growth of IoT. Specifically, 

stakeholders cited three dimensions of the spectrum availability 

challenge: the amount, the balance between licensed and unlicensed, 

and the variety of spectrum bands available. According to some reports, 

incorrectly anticipating industry needs in any of these areas could weaken 

IoT growth and development in the United States.

Amount of spectrum: The amount of spectrum needed for IoT devices is 

expected to increase with their growth. According to a majority of 

stakeholders we interviewed, FCC will need to continue to make 

additional spectrum commercially available in order to meet the demand 

from expected rapid growth in wireless devices, including IoT devices. 

FCC officials told us the current amount of available spectrum will be 

sufficient for the growth of IoT unless devices that use a disproportionally 

large amount of spectrum become more prevalent. Such devices, like 

those that stream video, could lead to a spectrum shortage that 

negatively impacts IoT growth. According to several stakeholders

spectrum availability will become an issue as use of these devices 

increases. FCC officials said that cellular providers experienced similar 

issues when they introduced smart phones, spurring rapid, exponential 

growth in consumer demand to send and receive wireless data. Despite 

the potential for a shortage of spectrum for IoT devices, most of the 

stakeholders agreed that there should not be specific spectrum set aside 

for IoT devices; rather, some noted spectrum policies should remain 

flexible, allowing licensees to determine the best use.

Licensed and unlicensed spectrum: A majority of stakeholders said that 

the spectrum availability challenge includes making both licensed and 

Selected 

Stakeholders 

Identified Spectrum 

Availability and 

Managing 

Interference as 

Challenges Affecting 

IoT Devices

Spectrum Availability
Page 11 GAO-18-71 Internet of Things

unlicensed spectrum available. According to FCC staff, FCC is 

responsible for ensuring sufficient spectrum exists for commercial 

purposes and will continue to identify new spectrum that can be used for 

a variety of uses, including by IoT and other wireless devices. This 

identification of new spectrum includes making spectrum available on 

both a licensed and unlicensed basis to meet the needs of IoT and other 

wireless devices. For example, some devices may need to send a signal 

over a long distance and with a high quality of service to ensure a signal 

will go through, such as a fire alarm, something licensed spectrum can 

provide. However, for other devices, cost is a more important 

consideration. Licensed spectrum has costs that can come from 

purchasing the license or accessing the spectrum. For example, an 

official from a supply-chain automation company that develops radiofrequency identification tags told us the lack of inexpensive, low power 

networks that provide broad coverage is a challenge for their business.11

With such a network, the company’s tags could send out small amounts 

of data at intervals to help manufacturers track their goods. However, the 

cost of such a service is important if these tags are to attach to all size 

packages because paying for GPS or a wireless connections for each 

would make it unfeasible. According to several stakeholders, the correct 

balance between licensed and unlicensed spectrum is difficult to know.

Spectrum bands: Several stakeholders indicated that the need to make 

various spectrum bands available for IoT devices contributes to the 

spectrum management challenge. As previously described, each band of 

spectrum has different characteristics, such as the ability to carry data 

long distances and penetrate obstacles. IoT devices have diverse 

spectrum needs, such as needing to send a signal over a distance or 

send a constant stream of information. For example, in the package 

delivery industry there could be IoT devices, sending signals over a 

distance, that read the location of the vehicle and direct the driver on a 

different route based on traffic and deliveries. In addition, there are IoT 

devices that can monitor containers being delivered including their 

location, temperature within the container, and other characteristics. In 

 11Radio-frequency identification, more commonly referred to as RFID, is a form of 

automatic identification and data capture technology that uses electric or magnetic fields 

at radio frequencies to transmit information. The RFID system can be used to identify 

objects, such as manufactured goods, animals, or people that have a RFID tag affixed to 

it. The tag has a unique identifier and may optionally hold additional information about the 

object.
Page 12 GAO-18-71 Internet of Things

both these examples, the devices can send signals over long distances to 

systems that can monitor the information.

Some stakeholders and FCC staff also agreed that managing interference 

caused by the increasing number of IoT devices will challenge the 

continued growth of IoT. As previously stated, interference occurs when 

signals in the same vicinity attempt to access the same spectrum bands 

or bands close to each other, causing the signals to degrade. This can 

lead to intermittent access, poor reception, or no reception. As the 

number of wireless IoT devices grows, the chances of harmful 

interference increases. The number of IoT devices is predicted to grow so 

fast the instances of harmful interference could be difficult to track. 

Furthermore, according to one stakeholder, with devices being made by 

more manufacturers, not all devices are created of equal quality, 

potentially further increasing the chance that such devices will cause

interference. A recently issued GAO report found that according to FCC 

staff, the expansion in wireless services and devices, not just IoT, has 

contributed to interference becoming more of a challenge for FCC.12 FCC 

staff agreed that managing interference is becoming more challenging as 

the number of wireless IoT devices grows. However, according to FCC 

staff, relatively few complaints pertaining to licensed services involve 

devices that are compliant with FCC regulations and operating properly.

Managing interference may be particularly difficult in homes where many 

devices rely on unlicensed spectrum. The FCC Technical Advisory 

Council’s (TAC) report from 2014, expressed concerns that the rapid 

growth of IoT could exacerbate interference issues in the home.13

Particularly, the growing reliance on unlicensed spectrum for many 

consumer IoT devices has contributed to this concern. For example, 

many IoT devices using unlicensed spectrum, such as digital assistants 

or wireless speaker systems, use Wi-Fi, Bluetooth or similar technology to 

transmit a short distance to a smart phone or Wi-Fi router. Not all agree 

however, that this use is an issue. One spectrum expert we interviewed 

for a recently-issued report said that interference among consumer 

devices is less likely to be an issue because they only transmit for short 

 12GAO-17-75 (May 2017).

13In 2014, FCC’s TAC IoT working group examined IoT demand, how FCC can foster IoT 

innovation, and the policy challenges that exist for IoT, among other things. 15th Meeting 

of the Technical Advisory Council for the FCC (December 4, 2014).

Spectrum Interference
Page 13 GAO-18-71 Internet of Things

durations and over short distances.14 If the devices only transmit a short

distance then many devices can transmit on the same spectrum. 

Similarly, if devices only transmit for short durations then they can take 

turns transmitting over the same spectrum.

To plan for spectrum needs, FCC has repurposed spectrum by making 

additional spectrum available for commercial purposes and, according to 

FCC officials, the agency is continuing to look for additional opportunities 

to do so. For example, in 2016, FCC issued a final order that opened up 

high-band spectrum (above 24 GHz) for use with 5G networks and 

applications. This particular rulemaking from FCC opened up a total of 

10.85 GHz of spectrum, 3.85 GHz for licensed mobile use and 7 GHz for 

unlicensed use.15 According to FCC, this order follows a technology 

neutral approach to planning by allowing spectrum users to develop 

technologies for the spectrum and not have FCC dictate its specific use. 

Advances in technology that now allow use of spectrum above 24 GHz for 

high-speed mobile services led the FCC to initiate the proceeding 

resulting in this order. Previously, this spectrum was best suited for 

various satellite or fixed microwave applications. As shown in table 1, in 

recent years FCC has freed up spectrum for licensed use, unlicensed 

use, and sharing between the two.

 14GAO-17-75 (May 2017).

15In The Matter of Use of Spectrum Bands Above 24 GHz for Mobile Radio Services, 

Report and Order and Further Notice of Proposed Rulemaking, 2016 FCC LEXIS 2470 

(2016). In this Report and Order, nearly all the spectrum repurposed was in higher 

bandwidths that require millimeter wave spectrum. The technology necessary to operate 

in these higher bandwidths is still being developed. 

The Federal 

Government Has 

Plans to Meet 

Spectrum Needs but 

Does Not Track IoT 

Devices That Could 

Cause Congestion

FCC Spectrum Planning
Page 14 GAO-18-71 Internet of Things

Table 1: Examples of the Federal Communications Commissions’ (FCC) Efforts to 

Repurpose Spectrum 

Year Description Total bandwidth 

repurposed

2016-

2017

FCC auctioned spectrum that was previously licensed to 

television broadcasters, making it available for wireless 

purposesa (70 MHz for licensed use and 14 MHz for 

unlicensed and wireless microphone use).

84 MHz

2016 FCC reallocated several frequency bands for licensed and 

unlicensed uses. Bands are shared between new users and 

incumbent users (3.85 GHz for licensed use and 7 GHz for 

unlicensed use).

10.85 GHz

2015 FCC auctioned spectrum that is currently occupied by 

federal and non-federal users for licensed wireless 

purposes. The spectrum will be shared between current 

users and new licensees. 

65 MHz

2015 An FCC order provided new spectrum for shared wireless 

broadband use.b This order created a framework that 

authorized spectrum access in three tiers: incumbent 

access, priority access, and general authorized access.c

150 MHz

Source: FCC. | GAO-18-71

a

The Middle Class Tax Relief and Job Creation Act of 2012 (the 2012 act) required FCC to conduct 

an auction of broadcast television spectrum to help meet the nation’s accelerating spectrum needs. 

This auction is referred to as an incentive auction because eligible television broadcasters can 

voluntarily relinquish some or all of their spectrum-usage rights in the auction of the spectrum to 

mobile providers.

b

In the Matter of Amendment of the Commission’s Rules with Regard to Commercial Operations in 

the 3550-3650 MHz Band, Report and Order and Second Further Notice of Proposed Rulemaking, 30 

FCC Rcd 3959 (2015).

c

The first tier provides access to incumbent users including federal, national defense radar, and 

commercial satellite. The second tier provides priority access for licensees. The third tier provides 

access to general authorized access users, which would be authorized to use the spectrum within 

designated geographic areas but would be required to not cause interference to, and accept 

interference from incumbent and priority access users. Spectrum use in the band is assigned by 

Spectrum Access System, which differs from the conventional licensed and unlicensed rules by 

relying on a framework that adopts the best approach based on local supply and demand.

In 2016, FCC issued a proposed rule to allow mobile uses in an additional 

17.7 GHz of spectrum.16 In 2017, the FCC issued a Notice of Inquiry 

seeking input on potential opportunities for additional flexibility, 

particularly for wireless broadband services, in spectrum bands between 

3.7 and 24 GHz. However, according to FCC staff, the process of 

identifying and freeing up new spectrum can take a significant amount of 

time as FCC must complete a rulemaking and either relocate existing 

users or define sharing arrangements between the existing users and 

 162016 FCC LEXIS 2470 (2016).
Page 15 GAO-18-71 Internet of Things

new users. FCC has also proposed sharing mechanisms it hopes will 

allow some bands to be used by existing users as well as additional uses 

in the future. Other efforts to make additional spectrum commercially 

available have included examining the potential for sharing the 5.9 GHz 

band that FCC designated for transportation safety.17 This band was 

allocated over 15 years ago and designated exclusively for safety 

communication between vehicles and between vehicles and 

infrastructure. In recent years, FCC has worked with the automobile 

industry and Department of Transportation to assess whether all or a

portion of that spectrum could be shared. FCC is also monitoring 

development of specifications to support 5G—the next generation of 

wireless networks. According to FCC, the 5G technologies that providers 

develop are projected to bring wireless networks lower latency, better 

coverage, faster Internet connections, and allow for more connections 

than the existing cellular network, all of which may enable more IoT 

devices to be connected.18 However, 5G technology is still being 

developed, and while specifications are not fully defined, according to the 

plans from the standards-making bodies there will be particular standards 

designed to support IoT communications.

In 2016, NTIA issued a report on the potential roles of the federal 

government in support of the growth of IoT.19 It addressed specific 

questions regarding the spectrum needs and potential interference 

related to IoT devices and reaffirmed the government’s role in supporting 

technology growth. Furthermore, the report identified ongoing initiatives 

that support IoT as well as proposed future steps the Department of 

Commerce can take to further support IoT development. For example, 

NTIA’s report proposed that it continue to analyze the usage and growth 

 17In 1999, FCC allocated 75 MHz of spectrum—the 5.850 to 5.925 GHz band (5.9 GHz 

band)—for the primary purpose of improving transportation safety and adopted basic 

technical rules for operations of dedicated short range communications. In 2003, FCC 

established licensing and service rules for the 5.9 GHz band to provide a short-range, 

wireless link for transferring information between vehicles and roadside systems. In the 

Matter of Amendment of the Commission’s Rules Regarding Dedicated Short-Range 

Communication Services in the 5.850-5.925 GHz Band, Report and Order, 19 FCC Rcd 

2458 (2004).

18Latency is the time it takes for data to travel from one point on the network to another. 

High latencies may affect the perceived quality of some services such as video or online 

games.

19 Department of Commerce, Internet Policy Task Force and Digital Economy Leadership 

Team, Fostering the Advancement of the Internet of Things (January 2017).

NTIA’s Data Gathering and 

Research
Page 16 GAO-18-71 Internet of Things

of IoT devices through its survey used to collect its Digital Nation data.20

Recent Digital Nation surveys have asked about wearable devices, use of 

smart televisions, and use of Internet-enabled mobile phones, all uses 

that include IoT applications.21 The most recent survey, in 2015, also 

asked Internet users whether they interact with household equipment or 

appliances via the Internet.22 NTIA officials recently told us that they will 

continue to monitor these connected items to track trends in their use but 

do not intend to expand the survey to include questions about additional 

IoT devices. Specifically, in January 2017, NTIA sought out public 

comment on its November 2017 Digital Nation survey including comment 

on a proposed questionnaire. NTIA subsequently submitted its proposed 

questionnaire to Office of Management and Budget for final approval. 23

NTIA also has ongoing spectrum studies through its Institute for 

Telecommunications Sciences and the findings may apply to IoT’s use of 

spectrum. As shown in table 2, these studies touch on a number of areas 

related to IoT including interference issues and spectrum use. NTIA also 

co-chairs the Wireless Spectrum Research and Development Interagency 

Working Group that coordinates spectrum-related research and 

development activities across the federal government, academia, and the 

private sector.24 Among other activities, this working group has developed 

the Wireless Spectrum Research and Development Inventory that, in its 

2016 iteration, provides information on completed projects or those 

scheduled to be completed between January 1, 2015 and December 31, 

2018.

 20The Digital Nation data survey is conducted every 2 years on broadband adoption in this 

country and in recent years additional information has been added to the survey. These 

data are collected as part of the Current Population Survey Computer and Internet Use 

Supplement, which is sponsored by NTIA and administered by the Census Bureau. In 

2015, this survey included interviews of over 52,000 households gathering data on over 

120,000 individuals.

21The survey asked about the use of smart televisions and Internet enabled phones in its 

2011, 2013, and 2015 surveys. It asked about wearable devices for the first time in 2015. 

22NTIA provides detailed results from IoT-related questions on its website. NTIA, New 

Insights from the Emerging Internet of Things, (June 15, 2016), accessed October 17, 

2017, https://www.ntia.doc.gov/blog/2016/new-insights-emerging-internet-things. 

23For details on the Office of Management and Budget’s review see

https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201708-0660-001, accessed 

October 17, 2017.

24This working group is part of the Networking and Information Technology Research and 

Development program.
Page 17 GAO-18-71 Internet of Things

Table 2: Spectrum Studies Currently Being Conducted by National 

Telecommunications and Information Administration (NTIA) 

Current spectrum 

studies

Goal Status

Internet of Things 

(IoT) testbed

To assess the effect of how IoT

devices interact on wired and 

wireless infrastructure as the IoT 

market grows. 

NTIA expects to classify 

different consumer IoT 

devices and create models 

to show the impact on 

infrastructure when many 

IoT devices are present. 

Spectrum monitoring Establish an architecture to support 

a variety of sensing technologies 

and data to improve usability and 

analytics. 

NTIA is currently working to 

establish an automated 

spectrum monitoring 

prototype.

Electromagnetic 

compatibility analysis 

To characterize the emissions of 

wireless devices to improve 

interference detection and 

avoidance technology.

NTIA is conducting tests of 

device-to-device 

interference in wireless 

environments. Testing will 

include simulations in a lab 

and field testing.

Source: NTIA | GAO-18-71

FCC has a strategic goal of promoting economic growth, and one way 

FCC pursues that goal is by ensuring that there is sufficient spectrum to 

support commercial demand. Most stakeholders agree that the growth in 

mobile IoT devices will eventually require additional spectrum to operate 

effectively. According to some stakeholders we interviewed and reports 

we reviewed, rapid, unexpected growth in two areas could lead to 

congestion and interference that could slow the growth of IoT in the 

United States: (1) high-bandwidth devices25 and (2) devices that operate 

in unlicensed bands. Federal standards for internal control instruct 

agencies to address risks such as these by estimating the significance of 

the risk, analyzing the likelihood of it occurring, and assessing its 

nature.26 Such assessments can be used to determine how to respond to 

the potential risks that could prevent agencies from meeting their goals. 

Rapid growth in high-bandwidth and unlicensed spectrum devices 

 25For the purposes of this report, high-bandwidth devices are mobile IoT devices, such as 

devices designed to stream video, that use more spectrum than an average mobile IoT 

device. 

26GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(September 2014). 

Tracking IoT’s Growth
Page 18 GAO-18-71 Internet of Things

represent risks to FCC achieving its goal of promoting economic growth 

by ensuring that sufficient spectrum is available.

FCC officials said that the agency tracks industry-produced trends and 

projections related to spectrum demand and use but does not focus on 

specific devices. Rather, it relies on network providers to manage and 

track the spectrum related to specific device types. When more spectrum 

is needed, FCC officials said that FCC identifies additional spectrum and 

makes it available to the commercial sector. However, this reactive 

approach may not adequately address the risks caused by highbandwidth and unlicensed-spectrum devices.

• High-bandwidth devices: Some stakeholders we interviewed and FCC 

officials said that rapid increases in high-bandwidth IoT devices could 

overwhelm current wireless networks. Such IoT devices could include 

video-streaming devices or unmanned drones, which have much 

higher data needs and will require a lot of bandwidth. FCC officials 

said that the supply of spectrum has not always kept pace with 

demand caused by rapid increases in high-bandwidth devices. For 

example, the officials said that wireless networks were overwhelmed 

when providers introduced smart phones. Until then, ringtones 

represented the bulk of demand for wireless data, but mobile Internet 

browsing caused the demand for wireless data to increase several 

fold. In 2014, the FCC TAC warned that new IoT applications could 

overwhelm networks the same way smartphones and other new 

technologies have in the past. The TAC recommended that FCC 

monitor IoT wireless networks with a specific focus on high-bandwidth 

devices.27

• Unlicensed spectrum use: Some stakeholders also said that 

unlicensed bands are particularly vulnerable to congestion and 

potential interference because of expected growth in IoT devices. For 

example, all the commercial, industrial, and personal devices that 

connect using WiFi and Bluetooth networks use unlicensed spectrum. 

In 2014, the TAC indicated that the majority of wireless IoT devices 

will rely on unlicensed spectrum and recommended FCC make 

sufficient unlicensed spectrum available for devices operating on local 

and personal area networks, like WiFi and Bluetooth. However, FCC 

may not have enough information to determine when the amount of 

unlicensed spectrum is sufficient. While network providers can 

manage the number of devices on their own licensed networks, this 

 2715th Meeting of the Technical Advisory Council for FCC (December 4, 2014).
Page 19 GAO-18-71 Internet of Things

approach does not work for devices that use unlicensed spectrum, 

and FCC does not track unlicensed spectrum utilization. It does not 

track use of unlicensed spectrum because congestion of unlicensed 

spectrum is geographically and technically challenging to track. 

Specifically, it is geographically challenging because network 

congestion and demand can vary over very short distances and 

technically challenging because there are so many bands of spectrum 

that would have to be tracked at one time and unlicensed spectrum 

typically propagates over relatively short distances. However, there 

may be ways to track unlicensed use that does not require monitoring. 

For example, NTIA’s Digital Nation survey provides information on 

select IoT devices using unlicensed spectrum that could help track 

unlicensed spectrum use.

While FCC makes additional spectrum available when needed, it lacks an 

early warning system for high-risk sectors, like high-bandwidth and 

unlicensed-spectrum devices. The process of identifying and reallocating 

spectrum is a lengthy process that can take years, including the need to 

identify new bands, address the needs of existing users on the bands, 

establish service rules, and license or assign the spectrum for commercial 

uses. Without tracking the high-bandwidth and unlicensed-spectrum 

devices, FCC is not assessing a key risk associated with its goal of 

promoting economic growth. Rapid, unexpected growth in these IoT 

sectors could lead to spectrum congestion and interference that could 

slow or halt the economic growth associated with IoT until FCC can make 

additional spectrum available.

Like the United States, France, Germany, the Netherlands, and South 

Korea are among the world leaders in the development of IoT. We 

contacted public and private officials in these countries to identify their 

approaches to spectrum planning to address the growth of IoT. Those 

officials described approaches to planning for future spectrum needs that 

are similar to the United States in one area but different in others (see 

table 3). Specifically, we found that all four countries practice technology 

neutral spectrum planning, an approach that was broadly supported by 

the stakeholders we interviewed, including wireless carriers, a technology 

Selected Leading 

Countries Vary in 

Spectrum-Planning 

Approaches for IoT

Approaches to Spectrum 

Planning in Selected 

Leading Countries
Page 20 GAO-18-71 Internet of Things

manufacturer, academics, and a nonprofit group.28 Some of these 

stakeholders indicated that this approach to spectrum planning 

encourages innovation as it allows developers to choose the most 

appropriate spectrum bands for new technology without having to take 

the extra step of getting regulators’ permission for each new device or 

application.

Table 3: Spectrum Planning in Selected Leading Countries

Planning 

activities

United 

States

France Germany South 

Korea

The 

Netherlands

Technologyneutral spectrum 

planning

    

National Internet 

of Things plan

 

Focus on 

unlicensed 

spectrum to 

support future IoT 

growth

 

Nationwide lowpower wide-area 

network deployed 

  

Source: Federal Communications Commission and spectrum management agencies from select leading countries. | GAO-18-71

Two of the selected leading countries, Germany and South Korea, have 

developed national IoT plans focused on developing IoT for industry; 

however, only South Korea has a plan that specifically addresses 

spectrum issues. South Korea’s national IoT plan seeks to increase 

collaboration among IoT stakeholders, promote innovation, and develop 

services for the global market in order to promote productivity and 

efficiency in Korean business. South Korea also developed a mid- to 

long-term spectrum plan to respond to the expected growth in demand for 

spectrum as IoT expands and 5G cellular networks are deployed. 

Released in 2016, the plan intends to makes more spectrum available to 

support new services such as smart homes, smart factories, smart cities, 

remote medical treatment, and unmanned vehicles. Specifically, the 

South Korean spectrum plan that includes IoT and establishes the 

following goals:

 28Technology neutral planning allows spectrum users to develop technologies for the 

spectrum and not have FCC dictate its specific use.
Page 21 GAO-18-71 Internet of Things

• almost doubling the amount of available spectrum available, 

expanding from 44 GHz of available spectrum to 84 GHz by 2026, 

and

• increasing the efficiency of spectrum use, promoting spectrum 

sharing, and advancing international coordination in spectrum 

planning.

Officials from France and the Netherlands told us that making more 

unlicensed spectrum available is a high priority in their spectrum planning. 

These officials told us that unlicensed spectrum promotes greater 

innovation by lowering barriers to access, and many IoT devices are 

expected to be designed to operate on unlicensed bands. German and 

Dutch officials told us that numerous smart city IoT applications have 

been developed in their respective countries, most of which operate on 

unlicensed spectrum. For example, German and Dutch networks use 

unlicensed spectrum for purposes that include managing street lighting, 

preventing the theft of property such as bicycles, monitoring parking 

spaces, and managing agricultural resources.

To provide service options for low power IoT devices, private companies 

in France, the Netherlands, and South Korea developed nationwide lowpower wide-area networks (LPWAN) which use unlicensed spectrum to 

transmit data.29 These LPWANs use the 800 and 900 MHz bands to 

transmit data from wireless IoT devices such as sensors and location 

trackers. Signals in these bands can be transmitted over long distances 

and can penetrate obstacles. According to one LPWAN provider, the 

distance served by a LPWAN site is greater than a single cellular network 

site. However, according to the same LPWAN operator, the bands used 

for LPWAN networks have limited data capacity compared to those used 

by cellular networks. According to officials and telecommunications 

industry stakeholders in these countries, LPWANs offer several potential 

benefits including low barriers to entry, low costs, and broad coverage.

According to a Dutch telecommunications industry stakeholder most 

devices that use LPWANs transmit only small amounts of data. A 

telecommunications industry stakeholder in France told us that the long 

range and strong propagation of these LPWANs make them useful for 

utility metering data and South Korean official told us that LPWANs are 

 29There are multiple technologies that can be used to operate LPWANs, including LoRa,

Random Phase Multiple Access, and Sigfox. In the United States, LPWANs have been 

developed using each of these technologies.
Page 22 GAO-18-71 Internet of Things

used to transmit location or temperature data. For example, in the 

Netherlands, LPWANs are used to monitor water depth and quality, 

manage street lighting, and to track the location of business inventory and 

personal property. In France, LPWANs are used for similar tracking as 

well as smoke detectors. Other uses for the LPWANs are currently in 

development. For example, a representative of a Dutch 

telecommunications company told us that in the Netherlands, IoT devices 

operating on the nationwide LPWAN are being tested at an airport for use 

in logistical processes such as baggage handling. Additionally, a Dutch 

railway station is experimenting with IoT technology that monitors rail 

switches using the LPWAN, and depth sounders at the port of Rotterdam 

have been fitted with devices to connect them to the network. South 

Korean officials said that the LPWAN in their country also provides 

specialized location-tracking services.

In the United States, companies have built LPWANs to support a variety 

of uses including location tracking, temperature monitoring, and water 

metering. However, one supply chain automation company told us that 

while it would not benefit any individual company enough to make it 

efficient to construct a large scale LPWAN in the United States, such a 

network would prevent many small losses and inefficiencies, a 

development that would add up to make a significant impact on the 

economy. According to FCC officials, the LPWAN market is still 

developing in the United States. The development of a nationwide 

LPWAN in the United States may face some of the same challenges that 

confronted the development of other nationwide communications 

networks. For example, providing service in rural areas and local issues 

presented challenges to planning the public-safety broadband network 

and building nationwide cellular network s.30 In addition, a major mobile 

service provider now offers subscription-based LPWAN service available 

in the United States using some of its licensed spectrum from its cellular 

network

 30The Middle Class Tax Relief and Job Creation Act of 2012 created the First Responder 

Network Authority within NTIA and required it to establish a nationwide, interoperable 

public-safety broadband network (Pub. L. No. 112-96, 126 Stat. 156 (2012) (codified at 47 

U.S.C. §§ 1401-1457). The network is intended to be a high-speed, wireless data and 

voice telecommunications network for first responders.
Page 23 GAO-18-71 Internet of Things

Selected leading countries take many similar approaches to each other 

and the United States to managing spectrum in order to address related 

challenges (see table 4). Like the United States, spectrum-planning 

officials in France, Germany, and the Netherlands told us that it was 

necessary to coordinate spectrum planning with other countries on their 

borders. Officials in each of these countries told us that European 

spectrum planning is complicated by the number of countries that share 

borders. Germany, for example, borders nine other countries. As each 

country is responsible for its own spectrum planning, if their plans are not 

closely coordinated, there is a potential for cross-border interference. This 

coordination is complicated by the fact that European countries have 

legacy spectrum allocations, and these must be accommodated in 

spectrum planning. The United States, by contrast, shares its border with 

only Mexico and Canada. According to FCC officials, both of these 

countries generally align their spectrum plans to those of the United 

States, reducing interference issues.

Table 4: Spectrum Management Approaches in Selected Leading Countries

Monitoring 

activities

United 

States

France Germany South 

Korea

The 

Netherlands

Represented in 

regional 

spectrum-planning 

association

    

Concerned that 

spectrum 

congestion may 

be an issue in the 

future

  

Priority on 

increasing 

spectrum sharing

    

Government 

directly tracks 

spectrum 

congestion

 

Source: Federal Communications Commission and spectrum management agencies from select leading countries. | GAO-18-71

In order to facilitate international coordination of spectrum planning, each 

of the four selected leading countries, like the United States, belongs to a 

regional spectrum-planning association that works to harmonize spectrum 

Selected Leading 

Countries Face 

International Coordination 

and Potential Spectrum 

Congestion Challenges
Page 24 GAO-18-71 Internet of Things

planning among member states.31 Officials of regional groups we spoke 

with told us that harmonizing can reduce interference issues across 

borders and facilitate interoperability of devices across different countries. 

Officials from the manufacturing and telecommunications industries told 

us that this interoperability creates a larger potential market for IoT 

devices, thereby improving the economies of scale for the manufacture of 

IoT devices and reducing production costs. Regional planning 

associations are also taking steps to prepare their member countries for 

the spectrum needs of IoT. For example, an official of one association, 

the Inter-American Telecommunication Commission, told us that in 2016 

it held a workshop on “machine-to-machine” technologies that brought 

together spectrum planners and stakeholders from IoT-related 

industries.32 Regional-planning associations also represent their member 

countries at World Radiocommunications Conferences (WRC).33 An 

official from one association told us that due to the diverse nature of IoT 

devices and applications it is unnecessary for IoT to be explicitly 

addressed as an agenda item at WRCs. However, the official further 

stated that the spectrum needs of specific IoT applications— including 

low power sensors, robotics, and connected vehicles—are included on 

the agenda. For example, the next WRC is scheduled for 2019 and 

includes an agenda item addressing connected vehicles, which are 

closely linked to IoT.

Spectrum-planning officials in each of the selected leading countries told 

us they are concerned about the potential for spectrum congestion, due to 

growth in the number of IoT devices. However, like FCC in the United 

States, these officials do not currently believe such congestion presents 

an immediate problem. Representatives of the four countries we spoke 

with told us that one way that they address the potential challenge of 

spectrum congestion is through the use of spectrum-sharing 

arrangements. Representatives from Germany specifically stressed the 

importance of finding additional sharing arrangements in response to the 

expected spectrum needs for IoT. In 2016, both France and the 

Netherlands initiated pilot programs for spectrum sharing in which 

 31See appendix III for a list of regional planning associations and their members. 

32The term “machine-to-machine technologies” refers to technology that enables 

machines to communicate with one another and drive action.

33WRCs are held every 3 to 4 years by the United Nations’ International 

Telecommunication Union in order to revise the Radio Regulations, the international treaty 

governing the use of the radio-frequency spectrum and the orbits of satellites.
Page 25 GAO-18-71 Internet of Things

multiple users’ access the same bands while prioritizing use by the 

licensee. These pilot programs are similar to the dynamic-sharing model 

that FCC adopted in 2015, as described previously. However, whereas

the model adopted by FCC has three tiers of users, the model used by 

France and the Netherlands has only two, and lacks the third tier of 

general access users.

Unlike the United States, officials from Germany and France told us that 

they directly monitor spectrum congestion. For example, German officials 

told us that there are spectrum-monitoring services at six locations 

around the country, and that they perform mobile measurements of 

spectrum congestion. FCC officials told us that their primary means of 

tracking congestion is to communicate with spectrum licensees. 

According to officials from the Netherlands, the Dutch spectrum 

management agency takes a similar approach and has struck an 

agreement with a group of telecommunications companies to share 

information concerning IoT’s interference and congestion issues. Officials 

also told us that it is easier to monitor spectrum congestion in smaller 

countries, as there is simply less geographical space to monitor. 

Nevertheless, officials in France, Germany, and the Netherlands told us 

that monitoring spectrum is a challenging task, as it is difficult to 

determine how many wireless devices are active at any given time.

FCC has a strategic goal to promote economic growth and effective 

spectrum management represents a key way that FCC can support 

meeting that goal. To that end, FCC officials said that the agency 

continuously seeks to make additional spectrum available and broadly 

tracks spectrum demand. However, stakeholders and FCC’s own 

technical advisors have identified rapid, unexpected growth in both highbandwidth devices and unlicensed spectrum as risks to effective 

spectrum management. By overwhelming existing networks before FCC 

can make more spectrum available, rapid growth in spectrum demand 

could slow or halt IoT’s potential to facilitate economic growth. Absent 

additional efforts to assess the risks to effective spectrum management 

by focusing on high-bandwidth and unlicensed-spectrum devices, 

spectrum congestion and interference could slow IoT growth.

We are making the following two recommendations to the Chairman of 

FCC.

Conclusions

Recommendations
Page 26 GAO-18-71 Internet of Things

The Chairman of FCC should track the growth in high bandwidth IoT

devices, such as video-streaming devices and optical sensors.

(Recommendation 1)

The Chairman of FCC should track the growth in IoT devices relying on 

unlicensed spectrum. (Recommendation 2)

We provided a draft of this report to FCC and the Department of 

Commerce for their review and comment. FCC provided comments in a 

letter, which is reprinted in appendix IV. FCC and the Department of 

Commerce provided technical comments that we incorporated as 

appropriate.

In its written comments, FCC did not concur with our recommendation 

that it track growth in high-bandwidth devices. FCC noted that it continues 

to believe that the best approach to track growth of devices is by 

monitoring overall traffic statistics and forecasts and how these devices

affect aggregate spectrum requirements for all applications and services. 

However, FCC noted that it would task the Technological Advisory 

Council (TAC) to periodically review the state of the IoT ecosystem to 

ensure that the planned communications infrastructure is sufficient to 

support the needs of the growing sector and advise on any actions the 

FCC should take. We continue to believe that tracking the growth of highbandwidth devices is necessary to avoid the potential spectrum shortage 

and that the TAC may be able to help FCC accomplish that. 

FCC did not concur with our recommendation to track IoT devices that 

rely on unlicensed spectrum. FCC noted that it may not be practical to 

determine which devices qualify as IoT or quantify their effect on 

spectrum utilization. As a result, FCC said that the best way to monitor 

growth in unlicensed IoT devices is to continue to monitor published 

papers and conferences and work with industry. However, since most of 

the projected IoT growth is expected to occur in unlicensed bands that 

are not protected from interference, we continue to believe that FCC 

should place a greater focus on tracking IoT devices in these bands. For 

example, the TAC may also be well positioned to help FCC track 

unlicensed IoT devices.

As agreed with your offices, unless you publicly announce the 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 Secretaries of 

Agency Comments

and Our Evaluation
Page 27 GAO-18-71 Internet of Things

Homeland Security and Commerce, the Chairman of FCC, and 

appropriate congressional committees. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov.

If you or members of your staff have any questions about this report, 

please contact me at (202) 512-2834 or goldsteinm@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. Major contributors to this report 

are listed in appendix IV.

Mark L. Goldstein

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-18-71 Internet of Things

We were asked to examine the challenges facing federal spectrum 

managers and the steps they are taking to address those challenges. In 

this report we discuss: (1) the spectrum-related challenges stakeholders 

identified due to the anticipated growth of IoT, (2) steps FCC and NTIA 

are taking to plan for the anticipated growth in the demand for spectrum 

as a result of IoT, and (3) efforts that selected leading countries are 

undertaking to plan for IoT’s spectrum needs and ways that these efforts 

compare with those of the United States.

To identify the spectrum-related challenges stemming from the expected 

growth of IoT, we reviewed documents from the Federal Communications 

Commission (FCC) and the National Telecommunications and 

Information Administration (NTIA), the two federal agencies that have 

direct authority over spectrum planning. Further, in order to identify 

relevant literature for review, we (1) conducted a key word search of data 

bases; (2) searched IoT and spectrum related websites, such as those of 

cellular carriers, telecommunications industry groups, and nonprofit 

organizations; (3) reviewed prior GAO reports on IoT and spectrum 

issues; and (4) asked FCC and NTIA officials, researchers, and non-profit 

organizations to identify relevant documents. Through our literature 

search, we identified a number of documents, including academic reports, 

government reports, congressional committee hearings, and trade 

journals addressing the projected growth of IoT to understand the number 

of devices that would be relying on the spectrum in the coming years. We 

also reviewed literature concerning the growth of other wireless devices, 

such as smart phones, and the burden they place on the spectrum, to 

assess if there are any lessons learned from the demand these devices 

placed on the spectrum that could be applied to the expected growth of 

IoT.

In addition, we interviewed FCC and NTIA officials, and conducted 24 

telephone and in-person interviews with officials from industry 

associations, industrial and commercial users of IoT, nonprofit groups, 

subject matter experts, manufacturers, and telecommunications 

companies to obtain their perspectives on the challenges presented by 

the expected growth of IoT. The experiences of the stakeholders are not 

generalizable to those of all IoT stakeholders in the United States; 

however, we believe that the information we gathered from selected 

stakeholders provides a balanced and informed perspective on the topics 

discussed. We identified relevant stakeholders by reviewing comments 

submitted to NTIA in response to its request for comment on the 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-18-71 Internet of Things

government’s role in planning for IoT growth,1 reviewing congressional 

hearings, and conducting a literature review encompassing academic 

articles, government reports, and trade journals. We interviewed officials 

from businesses that manufacture Internet-connected devices or 

equipment that would be considered part of IoT, including agriculture, 

telecommunications, and manufacturing. We spoke with these officials to 

gather information about the spectrum challenges they face as 

businesses working with and developing IoT devices. We then analyzed 

the results of these interviews and related documents to identify the main 

themes and develop summary findings. To characterize the views 

captured during the interviews, we defined the terms to quantify the views 

as follows:

• “most” users represents 18 to 24 users,

• “a majority of” users represents 11 to 17 users,

• “several” users represents 6 to 10 users, and

• “some” users represents 3 to 5 users.”

To identify the steps FCC and NTIA are taking to plan for the anticipated 

growth in the demand for spectrum as a result of IoT, we interviewed FCC 

and NTIA officials and reviewed agency reports and documents. We 

interviewed officials to understand any agency plans to address spectrum 

needs for IoT devices and how these plans aligned with the spectrum 

planning for other wireless devices. We reviewed agency reports and 

documents on spectrum planning, IoT planning, and the role of the 

federal government in planning for IoT. Specifically, we reviewed 

comments submitted in response to NTIA’s request for comment and the 

final report developed in response to the comments received on the role 

of the federal government. To identify other relevant reports and literature 

from FCC and NTIA, we asked officials at the meetings and conducted a 

literature search. We also compared those planning efforts against FCC’s 

and NTIA’s strategic goals and the federal internal control standards 

related to risk management. Specifically, we compared FCC’s planning 

against its strategic goal to promote economic growth and national 

leadership in telecommunications, and NTIA’s efforts against its mission 

to expand the use of spectrum by all users and to ensure that the Internet 

remains an engine for continued innovation and economic growth. We 

also assessed the efforts of both agencies against leading practices that 

 1

NTIA (Apr. 6, 2016).
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-18-71 Internet of Things

we previously developed for identifying, analyzing, and responding to 

risks related to achieving agency objectives.

To identify the efforts that selected foreign governments are taking to plan 

for the expected spectrum needs of IoT and ways their efforts compare 

with those of the United States, we surveyed trade journals, industry 

publications, and foreign governments’ websites and publications. 

Through this survey, we identified seven countries of potential interest, all 

of which have conducted spectrum planning in support of IoT: China, 

France, Germany, Netherlands, Japan, Singapore, and South Korea. We 

selected four of these countries—France, Germany, the Netherlands, and 

South Korea—as being like the United States and leaders in IoT 

development based on additional criteria including the level of their 

economic development, the maturity of their telecommunications 

infrastructures, the comparability of their governments to the United 

States, and the accessibility of their spectrum-planning information. We 

categorized a country’s economy as fully developed if the United Nations 

Statistics Division categorized it in 2016 as existing in a developed 

economic region. When determining the maturity of a country’s 

telecommunications infrastructure, we followed the United Nation’s 

International Telecommunication Union (ITU) in categorizing a country’s 

telecom infrastructure as mature if it was included in the top quartile of the 

175 countries ranked in ITU’s 2016 Information and Communications 

Technology Development Index.2 We considered a country to have a 

government structure comparable to that of the United States if Freedom 

House’s 2016 Freedom in the World report rated it as “free” and the Polity 

Project categorized it as a “democracy” in 2015.3 Finally, we considered 

the extent to which information could be efficiently procured from each 

country under consideration. We reviewed documents and conducted 

telephone and written interviews with officials from the spectrum 

management agencies in each of these four countries. We also 

conducted eight telephone and written interviews with officials from 

foreign telecommunications companies, IoT manufactures, and 

 2

While the United Nations Statistics Division classifies South Korea’s economy as still 

developing, the fact that it was first in the ITU’s ranking led us to include it in our study.

3

Freedom House, “Anxious Dictators, Wavering Economies: Global Freedom Under 

Pressure.” Freedom in the World 2016, accessed January 15, 2017, 

https://www.freedomhouse.org/report/freedom-world/freedom-world-2016. Center for 

Systemic Peace, The Polity Project, accessed January 15, 2017, 

http://www.systemicpeace.org/polityproject.html. 2015 and 2016 were the most recent 

versions of these documents available when these decisions were made.
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-18-71 Internet of Things

international spectrum-planning groups to gather information about IoT 

development, challenges, and responses to these challenges in the 

leading countries that we contacted.

We conducted this performance audit from August 2016 to November 

2017 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.
Appendix II: Agencies, Organizations, and 

Individuals GAO Interviewed

Page 32 GAO-18-71 Internet of Things

Table 5: Agencies, Organizations, and Individuals GAO Interviewed Regarding the 

Spectrum Needs of the Internet of Things (IoT) in the United States

Categories of entities 

interviewed

Interviewees

Federal agencies Federal Communications Commission

National Telecommunications and Information 

Administration

Congressional Research Service

Industrial and commercial users of 

IoT

Barcoding

Case IH

Deere & Co.

O-I

Industry associations Consumer Technology Association

CTIA

National Association of Manufacturers

Telecommunications Industry Association

U.S. Chamber of Commerce

Wi-Fi Alliance

World Shipping Council

Manufacturers of IoT technology Qualcomm

Samsung

Non-profit groups New America Foundation

Public Knowledge

Technology and Innovation Foundation

Subject matter experts Jeffrey Reed, Ph.D. (Virginia Polytechnic Institute 

and State University)

Douglas Sicker, Ph.D. (Carnegie Mellon University)

Telecommunications companies AT&T

Sigfox

Verizon

Source: GAO. | GAO-18-71

Table 6: Foreign and International Agencies and Organizations GAO Interviewed 

Regarding the Spectrum Needs of the Internet of Things (IoT)

Categories of entities 

interviewed

Interviewees

Spectrum-planning agencies Agence Nationale des Fréquences (France)

Agentschap Telecom (Netherlands)

Bundesnetzagentur (Germany)

Ministry of Science, ICT, and Future Planning 

(South Korea)

Appendix II: Agencies, Organizations, and 

Individuals GAO Interviewed
Appendix II: Agencies, Organizations, and 

Individuals GAO Interviewed

Page 33 GAO-18-71 Internet of Things

Categories of entities 

interviewed

Interviewees

International spectrum-planning 

associations

European Conference of Postal and 

Telecommunications Administrations

Inter-American Telecommunication Commission

International Telecommunication Union

Manufacturers of IoT technology Adeunis FR

Hager

Telecommunications companies KPN

Suez

Sigfoxa

Source: GAO. | GAO-18-71

a

We spoke with Sigfox regarding its networks in the United States and Europe.
Appendix III: Regional Spectrum-Management 

Associations and Their Member States

Page 34 GAO-18-71 Internet of Things

Table 7: Regional Spectrum Management Associations and Their Member States

Regional spectrummanagement associationsMember states

Asia-Pacific Telecommunity Afghanistan

Australia

Bangladesh

Bhutan

Brunei Darussalam

Cambodia

China

North Korea

Fiji

India

Indonesia

Iran

Japan

Kiribati 

South Korea

Laos

Malaysia

Maldives

Marshall Islands

Micronesia

Mongolia

Myanmar

Nauru

Nepal

New Zealand

Pakistan

Palau

Papua New Guinea

Philippines 

Samoa

Singapore

Solomon Islands

Sri Lanka

Thailand

Tonga

Tuvalu

Vanuatu

Viet Nam

African Telecommunications 

Union 

Algeria

Angola

Benin

Burkina Faso

Burundi

Cameroon

Central African Republic

Chad

Comoros

Cote d’Ivoire

Democratic Republic of the 

Congo

Djibouti

Egypt

Equatorial Guinea

Ethiopia

Gabon

Gambia

Ghana

Guinea

Guinea-Bissau

Kenya

Lesotho

Liberia

Libya

Madagascar

Malawi

Mali

Mauritania

Mauritius

Mozambique

Niger

Nigeria

Republic of the Congo

Sao Tome and Principe

Senegal

Sierra Leone

Somalia

South Africa

Sudan

Swaziland

Tanzania

Tunisia

Uganda

Zambia

Zimbabwe

Appendix III: Regional SpectrumManagement Associations and Their 

Member States
Appendix III: Regional Spectrum-Management 

Associations and Their Member States

Page 35 GAO-18-71 Internet of Things

Regional spectrummanagement associationsMember states

Arab Spectrum Management 

Group 

Algeria

Bahrain

Comoros Islands

Djibouti

Egypt

Iraq

Jordan

Kuwait

Lebanon

Libya

Mauritania

Morocco

Oman

Palestine

Qatar

Saudi Arabia

Somalia

Syria

Sudan

Tunisia

United Arab Emirates

Yemen

European Conference of 

Postal and 

Telecommunications 

Administrations 

Albania

Andorra

Austria

Azerbaijan

Belarus

Belgium

Bosnia and Herzegovina

Bulgaria,

Croatia

Cyprus

Czech Republic

Denmark

Estonia

Finland

France

Georgia

Germany

Greece

Hungary

Iceland

Ireland

Italy

Latvia

Liechtenstein

Lithuania

Luxembourg

The former Yugoslav Republic of 

Macedonia

Malta

Moldova

Monaco

Montenegro

Netherlands

Norway

Poland

Portugal

Romania

Russian Federation

San Marino

Serbia

Slovak Republic

Slovenia

Spain

Sweden

Switzerland

Turkey

Ukraine

United Kingdom

Vatican City

Inter-American 

Telecommunication 

Commission 

Antigua and Barbuda

Argentina

Barbados

Belize

Bolivia

Brazil

Canada

Chile

Colombia

Costa Rica

Cuba 1

Dominica

Dominican Republic 

Ecuador

El Salvador

Grenada

Guatemala

Guyana

Haiti

Honduras

Jamaica

Mexico

Nicaragua

Panama

Paraguay

Peru

Saint Kitts and Nevis

Saint Lucia

Saint Vincent and the Grenadines

Suriname

The Bahamas

Trinidad and Tobago

United States of America

Uruguay

Venezuela
Appendix III: Regional Spectrum-Management 

Associations and Their Member States

Page 36 GAO-18-71 Internet of Things

Regional spectrummanagement associationsMember states

Regional Commonwealth in 

the Field of Communications 

Azerbaijan Republic

Armenia

Belarus

Kazakhstan

Kyrgyz Republic

Moldova

Russian Federation

Tajikistan

Turkmenistan

Uzbekistan

Ukraine

Source: GAO. | GAO-18-71
Appendix IV: Comments from the Federal 

Communications Commission

Page 37 GAO-18-71 Internet of Things

Appendix IV: Comments from the Federal 

Communications Commission
Appendix IV: Comments from the Federal 

Communications Commission

Page 38 GAO-18-71 Internet of Things
Appendix V: GAO Contact and Staff 

Acknowledgment

Page 39 GAO-18-71 Internet of Things

Mark Goldstein, (202) 512-2834 or goldsteinm@gao.gov

In addition to the individual named above, Keith Cunningham (Assistant 

Director); Eric Hudson (Analyst-in-Charge); Camilo Flores; Adam Gomez;

Josh Ormond; Andrew Stavisky; Hai Tran; and Michelle Weathers made 

key contributions to this report. 

Appendix V: GAO Contact and Staff 

Acknowledgment

GAO Contact

Staff 

Acknowledgments

(101062)
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