COMMERCIAL 

SPECTRUM 

Plans and Actions to 

Meet Future Needs, 

Including Continued 

Use of Auctions 

Report to Congressional Committees

November 2011 

GAO-12-118 

United States Government Accountability Office

GAO 
 United States Government Accountability Office

Highlights of GAO-12-118, a report to 

congressional committees 

November 2011 

COMMERCIAL SPECTRUM

Plans and Actions to Meet Future Needs, Including 

Continued Use of Auctions

Why GAO Did This Study

The radio-frequency spectrum enables 

an array of wireless communications 

services that are critical to the U.S. 

economy and national security, such 

as wireless broadband. In 2010, a

Federal Communications Commission 

(FCC) task force issued the National 

Broadband Plan that included 

recommendations to reform spectrum 

policy. Since 1994, FCC has used 

competitive bidding, or auctions, to 

assign licenses to commercial entities

for their use of spectrum; however, its 

authority to use auctions expires on 

September 30, 2012.

Among other things, GAO examined 

(1) the extent to which FCC has made 

spectrum available for new commercial 

uses and the time taken to do so, (2) 

experts’ and stakeholders’ views on 

FCC’s plans and recent actions to 

meet future spectrum needs, and (3) 

experts’ and stakeholders’ views on 

the continued use of auctions to assign 

spectrum. To address these objectives, 

GAO reviewed FCC’s plans, notices, 

and orders; reviewed six instances in 

which FCC made spectrum available 

for new commercial uses; and 

surveyed 30 experts and 79 industry 

stakeholders about their views on 

FCC’s efforts to make spectrum 

available for new uses, its plans and 

actions to meet future needs, and its

continued use of auctions (the survey 

had a 68 percent response rate). 

What GAO Recommends

Given the continued support of FCC's

use of auctions, Congress should 

consider extending FCC's auction 

authority beyond the current expiration 

date of September 30, 2012. FCC 

provided technical comments that were 

incorporated as appropriate.

What GAO Found

Since 1994, FCC has made over 520 megahertz (a measure of quantity) of 

spectrum available for new uses, such as wireless broadband, through a process 

that can be lengthy. Because most of the usable spectrum in the United States 

has been allocated to existing uses, FCC must change its rules to move 

spectrum from an existing use to a new use, a process known as repurposing 

spectrum. Yet, this process can be lengthy—from 7 to 15 years for the six 

repurposings that GAO reviewed. Four factors contribute to the time it takes FCC 

to repurpose spectrum: the regulatory nature of the process, which to some 

extent is guided by statute; opposition of incumbent users, who could be required 

to vacate spectrum; coordination challenges between FCC and the National 

Telecommunications and Information Administration (NTIA), which oversees 

federal agencies’ use of spectrum, on the repurposing of federal spectrum for 

commercial use; and concerns about interference from users of spectrum in 

adjacent bands of spectrum. FCC has identified voluntary approaches that it 

thinks could speed the process, but these approaches generally require 

congressional approval and face some stakeholder opposition.

Experts and stakeholders had mixed views on FCC’s plans and recent actions to 

meet future spectrum needs. The National Broadband Plan included a set of 

recommendations to FCC, FCC and NTIA jointly, and Congress, aimed at 

meeting future spectrum needs. Some recommendations garnered broad 

support, including recommendations to auction certain bands of spectrum and 

enhance research and development. However, experts’ and stakeholders’ 

opinions diverged on other recommendations, such as reallocating a portion of 

spectrum from television to wireless broadband. Opinions also varied on FCC’s 

progress in implementing the recommendations. In some instances, these 

conflicting opinions arose from participants’ divergent positions in the industry, 

with, for example, incumbent licensees such as broadcasters opposing 

recommendations that they believe could impose burdens or costs on their 

businesses.

Experts and stakeholders GAO contacted strongly supported extending FCC’s 

auction authority, but varied in their opinions on potential changes to auctions. 

Since 1994, FCC has used auctions to assign mutually exclusive licenses to 

commercial entities providing certain wireless services. GAO previously reported 

that auctions were effective in assigning licenses to entities that valued them the 

most; were quicker, less costly, and more transparent than mechanisms FCC 

previously used to assign licenses; and were an effective mechanism for the 

public to realize a portion of the value of a national resource used for commercial 

purposes. Experts and stakeholders responding to GAO’s survey strongly 

supported extending FCC’s auction authority—53 of 65 respondents supported 

extending FCC’s authority. However, experts and stakeholders held varied 

opinions on potential changes to auctions. For example, respondents generally 

supported actions that would provide a clear road map detailing future auctions, 

which could reduce uncertainty. In contrast, a proposal to require winners of 

auctions to pay royalties based on their revenues rather than the full amount of 

their winning bids up front garnered the least support. View GAO-12-118. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov. 
Page i GAO-12-118 Commercial Spectrum 

Letter 1 

Background 4

Since 1994, FCC Has Made Over 520 Megahertz of Spectrum 

Available for New Uses through a Process That Can Be Lengthy 8

Responding Experts and Stakeholders Had Mixed Views on FCC’s 

Plans and Recent Actions to Meet Future Spectrum Needs 19

Responding Experts and Stakeholders Strongly Supported 

Extending FCC’s Auction Authority but Varied in Their Opinions 

on Potential Changes to Auctions 38

Conclusions 43

Matter for Congressional Consideration 44

Agency Comments 44

Appendix I Scope and Methodology 45 

Appendix II Federal Communications Commission’s Spectrum-Related 

Data Systems 49 

Appendix III Expert and Stakeholder Respondents’ Views on FCC’s 

Plans and Recent Actions to Meet Future Spectrum Needs 60 

Appendix IV GAO Contact and Staff Acknowledgments 119

Tables 

Table 1: Major Spectrum Repurposings since 1994 10

Table 2: Expert and Stakeholder Respondents’ Agreement with 

National Broadband Plan Recommendations Aimed at 

Making More Spectrum Available for Wireless Broadband 

Use by 2015 21

Table 3: Expert and Stakeholder Respondents’ Satisfaction with 

FCC’s Progress in Making More Spectrum Available for 

Wireless Broadband Use by 2015 25

Table 4: Expert and Stakeholder Respondents’ Agreement with 

National Broadband Plan Recommendations Aimed at 

Contents 
Page ii GAO-12-118 Commercial Spectrum 

Expanding Incentives and Mechanisms to Reallocate 

Spectrum 28

Table 5: Expert and Stakeholder Respondents’ Satisfaction with 

FCC’s Progress in Identifying and Addressing Barriers to 

Secondary Markets 30

Table 6: Expert and Stakeholder Respondents’ Agreement with 

National Broadband Plan Recommendations Aimed at 

Expanding Opportunities for Innovative Spectrum Access 

Models 32

Table 7: Expert and Stakeholder Respondents’ Satisfaction with 

FCC’s Progress on National Broadband Plan 

Recommendations Aimed at Expanding Opportunities for 

Innovative Spectrum Access Models 36

Table 8: Expert and Stakeholder Respondents’ Agreement with 

Extending FCC’s Auction Authority 39

Table 9: Expert and Stakeholder Respondents’ Agreement with 

Potential Changes to FCC’s Auction Policies 39

Table 10: Description of FCC Data Systems 50

Table 11: Summary of Survey Responses of Extent to Which FCC 

Data System Provides Desired Type of Information 51

Table 12: Summary of Survey Responses for Inaccurate Data 52

Table 13: Summary of Survey Responses for Missing Data 53

Table 14: Summary of Survey Responses for User-Friendliness 54

Table 15: Summary of FCC’s Data Quality Procedures for 

Spectrum-Related Data Systems 55

Figures 

Figure 1: Examples of Services by Frequency Band 5

Figure 2: Timeline for Major Spectrum Repurposings—

Identification to Reassignment 11

Figure 3: Process to Repurpose Spectrum from an Existing Use to a 

New Use 14
Page iii GAO-12-118 Commercial Spectrum 

Abbreviations 

AWS Advanced Wireless Services 

BBA-97 Balanced Budget Act of 1997 

BRS Broadband Radio Service 

CLS Consolidated Licensing System 

COALS Cable Operations and Licensing System 

EBS Educational Broadband Service 

ESMR Enhanced Specialized Mobile Radio 

FCC Federal Communications Commission 

GHz gigahertz 

ITU International Telecommunication Union 

kHz kilohertz 

MHz megahertz 

MSS Mobile Satellite Services 

NPRM Notice of Proposed Rulemaking 

NTIA National Telecommunications and Information Administration 

PCS Personal Communications Service 

R&D research and development 

TV television 

Wi-Fi wireless fidelity 

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Page 1 GAO-12-118 Commercial Spectrum 

United States Government Accountability Office

Washington, DC 20548 

November 23, 2011 

The Honorable Fred Upton 

Chairman 

The Honorable Henry A. Waxman 

Ranking Member 

Committee on Energy and Commerce 

House of Representatives 

The Honorable John D. Rockefeller IV 

Chairman 

The Honorable Kay Bailey Hutchison 

Ranking Member 

Committee on Commerce, Science, 

 and Transportation 

United States Senate 

The Honorable Greg Walden 

Chairman 

The Honorable Anna G. Eshoo 

Ranking Member 

Subcommittee on Communications 

 and Technology 

Committee on Energy and Commerce 

House of Representatives 

The radio-frequency spectrum is a natural resource used to provide an 

array of wireless communications services that are critical to the U.S. 

economy and national security, such as mobile voice and data services, 

radio and television broadcasting, radar, and satellite-based services. 

Demand for radio-frequency spectrum has exploded over the past several 

decades as new technologies and services have been and continue to be 

brought to the market in the private sector and new mission needs unfold 

among government users of spectrum, including wireless 

communications critical for public safety officials responding to natural 

and man-made disasters. As a result, nearly all parties are becoming 

increasingly concerned about the availability of spectrum for future needs, 

because most of the usable spectrum in the United States has already 

been allocated to existing services and users. These concerns are 

compounded by evidence that some of the spectrum is currently 

underutilized. Therefore, to promote more efficient use of this resource 

and meet future needs, the Federal Communications Commission (FCC) 

 
 

Page 2 GAO-12-118 Commercial Spectrum 

has increasingly adopted more market-oriented approaches to spectrum 

management in recent years, including using a competitive bidding 

process, or auctions, to assign spectrum licenses to commercial users. 

From 1994, when FCC first implemented its auction authority, through 

June 30, 2011, FCC held 79 auctions for over 68,000 licenses to select 

between competing applications for the same license, and generated 

nearly $52 billion for the U.S. Treasury. In addition, in March 2010, an 

FCC task force issued the National Broadband Plan aimed at achieving 

affordability and maximizing the use of broadband, or high-speed Internet 

access, to advance a range of economic and civic goals.1

 Because 

broadband access and use is becoming increasingly mobile and wireless, 

the plan included a set of recommendations aimed at ensuring efficient 

allocation and use of radio-frequency spectrum for wireless broadband 

services.2

 In some instances, the plan recommends that FCC change its 

rules to move certain bands of spectrum from an existing use, such as 

television broadcasting, to new uses, such as wireless broadband, a 

process known as repurposing spectrum. 

In response to your request to review FCC’s management of commercial 

spectrum,3

 we examined (1) the extent to which FCC has made spectrum 

available for new commercial uses since it implemented auction authority 

in 1994 and the time taken to do so, (2) experts’ and stakeholders’ views 

on FCC’s plans and recent actions to meet future spectrum needs, and 

(3) experts’ and stakeholders’ views on the continued use of auctions to 

assign spectrum. In addition, we examined the extent to which FCC 

seeks to ensure the quality of its data on commercial spectrum licenses 

(see app. II). 

 

1

FCC, Connecting America: The National Broadband Plan (Washington, D.C.: Mar. 16, 

2010). 

2

Wireless broadband comprises both fixed and mobile wireless communication services. 

Fixed wireless broadband refers to stationary wireless devices or systems that provide 

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

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

3

In April 2011, we issued a report on the National Telecommunications and Information 

Administration’s (NTIA) management of the federal government’s use of spectrum. See 

GAO, Spectrum Management: NTIA Planning and Processes Need Strengthening to 

Promote the Efficient Use of Spectrum by Federal Agencies, GAO-11-352 (Washington, 

D.C.: Apr. 12, 2011). 
 

Page 3 GAO-12-118 Commercial Spectrum 

To address these issues, we reviewed FCC’s plans, notices, orders, and 

other publications. We interviewed officials at FCC and analyzed FCC’s 

quality control processes for its four spectrum license databases—the 

Universal Licensing System, the Consolidated Database System, the 

International Bureau Filing System, and the Experimental Licensing 

System—and for FCC’s database of authorizations of equipment using 

the radio frequency spectrum, the Equipment Authorization System. We 

reviewed six instances since 1994 in which FCC made spectrum 

available by repurposing it for new commercial uses; we limited our 

analysis to repurposings that involved substantial amounts of spectrum 

that were repurposed to a higher value use.4

 We reviewed the National 

Broadband Plan and reports and orders related to FCC’s implementation 

of the plan. We also reviewed industry comments on the plan and FCC’s 

steps to implement the plan. In addition, we surveyed 30 experts and 79 

industry stakeholders about their views on FCC’s licensing data, the 

amount of time it takes FCC to reallocate spectrum for new commercial 

uses, the recommendations in the National Broadband Plan’s chapter on 

spectrum,5

 FCC’s steps to implement those recommendations, and the 

continued use of auctions to assign spectrum. We selected the experts 

and stakeholders based on their expertise in spectrum policy as 

represented by presentations or publications, or on their organization’s 

vested interest in spectrum policy. Twenty of the experts and 54 of the 

stakeholders responded to our survey, representing a 68 percent 

response rate. Because we selected a nonprobability sample of experts 

and industry stakeholders, the information we obtained from the survey 

may not be generalized to all experts and industry stakeholders who have 

an interest in spectrum policy. We also conducted semistructured 

interviews with representatives of academia, industry, and public interest 

groups. (See app. I for additional information on our scope and 

methodology.) We conducted this performance audit from August 2010 to 

November 2011 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

 

4

The six repurposings we examined met the following criteria: (1) the amount of spectrum 

repurposed was 5 megahertz (MHz) or more, (2) the repurposing yielded $100 million or 

more in auction or industry revenue, and (3) reassignment occurred in 1994, when FCC 

first implemented its auction authority, or later. 

5

We excluded three recommendations that were addressed in our questions about FCC’s 

data quality, fell under the purview of NTIA, or pertained to a narrow population. 
 

Page 4 GAO-12-118 Commercial Spectrum 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. 

The radio-frequency spectrum is the part of the natural spectrum of 

electromagnetic radiation lying between the frequency of 3 kilohertz (kHz) 

and 300 gigahertz (GHz).6

 It is the medium that makes possible wireless 

communications and supports a vast array of commercial and 

governmental services. Commercial entities use spectrum to provide a 

variety of wireless services, including mobile voice and data, paging, 

broadcast television and radio, and satellite services. Federal, state, and 

local agencies use spectrum to fulfill a variety of government missions, 

such as national defense, air-traffic control, weather forecasting, and 

public safety. 

Spectrum is managed at the international and national levels. The 

International Telecommunication Union (ITU), a specialized agency of the 

United Nations, coordinates spectrum management decisions among 

nations. Spectrum management decisions generally require international 

coordination, since radio waves can cross national borders. Once 

spectrum management decisions are made at the ITU, regulators within 

each nation, to varying degrees, follow the ITU decisions. In the United 

States, responsibility for spectrum management is divided between two 

agencies: FCC and the Department of Commerce’s National 

Telecommunications and Information Administration (NTIA). FCC 

manages spectrum use for nonfederal users, including commercial, 

private, and state and local government users under authority provided in 

the Communications Act.7

 NTIA manages spectrum for federal 

government users and acts for the President with respect to spectrum 

management issues. FCC and NTIA, with direction from Congress and 

the President, jointly determine the amount of spectrum allocated to 

 

6

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

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

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

thousands of Hertz, megahertz (MHz) to millions of Hertz, and gigahertz (GHz) to billions 

of Hertz. The Hertz unit of measurement is used to refer to both the quantity of spectrum 

(such as 500 MHz of spectrum) and the frequency bands (such as the 1710–1755 MHz 

band). 

7

Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq. 

Background 
 

Page 5 GAO-12-118 Commercial Spectrum 

federal and nonfederal users, including the amount allocated to shared 

use. 

Historically, concern about interference or crowding among users has 

been a driving force in the management of spectrum. FCC and NTIA work 

to minimize interference through two primary spectrum management 

functions—the “allocation” and the “assignment” of radio spectrum. 

Specifically: 

 Allocation involves segmenting the radio spectrum into bands of 

frequencies that are designated for use by particular types of radio 

services or classes of users. For example, the frequency bands from 

88 to 108 MHz are allocated to FM radio broadcasting in the United 

States. (Fig. 1 illustrates examples of services by frequency band.) In 

addition to allocation, spectrum managers specify service rules, which 

include the technical and operating characteristics of equipment. 

Figure 1: Examples of Services by Frequency Band 

 Assignment, which occurs after spectrum has been allocated for 

particular types of services or classes of users, involves providing 

users, such as commercial entities or government agencies, with a 

license or authorization to use a specific portion of spectrum. For 

example, FCC assigned a license for the 88.5 MHz band in 

Washington, D.C., to American University, for its radio station, 

WAMU. FCC assigns licenses for frequency bands to commercial 

enterprises, state and local governments, and other entities, while 

NTIA makes frequency assignments to federal agencies. 

In some frequency bands, FCC authorizes unlicensed use of spectrum—

that is, users do not need to obtain a license to use the spectrum. Rather, 

an unlimited number of unlicensed users can share frequencies on a 
 

Page 6 GAO-12-118 Commercial Spectrum 

noninterference basis. Thus, the assignment process does not apply to 

the use of unlicensed spectrum. However, manufacturers of unlicensed 

equipment must receive authorization from FCC before operating or 

marketing an unlicensed device. Traditional unlicensed equipment 

consists of low-powered devices that operate in a limited geographic 

range, such as cordless phones, baby monitors, garage door openers, 

and wireless access to the Internet. 

When FCC assigns a portion of spectrum to a single entity, the license is 

considered exclusive. When two or more entities apply for the same 

exclusive license, FCC classifies these as mutually exclusive 

applications—that is, the grant of a license to one entity would preclude 

the grant to one or more other entities. Since 1994, FCC has primarily 

used auctions to assign spectrum for mutually exclusive applications. 

Auctions are a market-based mechanism in which FCC assigns a license 

to the entity that submits the highest bid for specific bands of spectrum. 

FCC was provided with authority to use auctions to assign mutually 

exclusive licenses for certain subscriber-based wireless services8

 in the 

Omnibus Budget Reconciliation Act of 1993.9

 FCC implemented its 

auction authority conducting its first auction in 1994.10 In subsequent 

years, Congress has modified and extended FCC’s auction authority, 

including exempting some licenses from competitive bidding, such as 

licenses for public safety radio services and noncommercial educational 

 

8

A subscriber-based wireless service is one in which the company providing the service 

sells subscriptions for the service to customers. 

9

The Omnibus Budget Reconciliation Act of 1993 amended the Communications Act of 

1934 to allow the use of competitive bidding to issue licenses and to restrict the use of 

lotteries. Omnibus Budget Reconciliation Act of 1993, Pub. L. No. 103-66, § 6002, 107 

Stat. 312, 388-92 (1993), as amended by the Balanced Budget Act of 1997, Pub. L. No. 

105-33, § 3002-3, 111 Stat. 251, 258-66 (1997) (codified at 47 U.S.C. § 309(j)). The act 

required the Commission to establish, by regulation, the methodology of the auction and 

eligibility to bid for those licenses. 47 U.S.C. § 309(j)(3). After setting the methodology for 

a particular competitive bidding system, the Commission was required to establish the 

requirements to participate in an auction. 47 U.S.C. § 309(j)(4). 

10Implementation of Section 309(j) of the Communications Act—Competitive Bidding, 

Second Report and Order, 9 FCC Rcd 2348 (1994). 
 

Page 7 GAO-12-118 Commercial Spectrum 

broadcast services.11 FCC’s auction authority is scheduled to expire on 

September 30, 2012.12

As of June 30, 2011, FCC had conducted 79 auctions to select between 

competing applications for the same license, which have generated 

nearly $52 billion for the U.S. Treasury. However, only about 3 percent of 

licenses have been auctioned. The vast majority of the other 97 percent 

of licenses were assigned through other means before FCC began using 

auctions. 

In March 2010, an FCC task force issued the National Broadband Plan. 

Because broadband access and use is becoming increasingly wireless, 

the plan includes a set of recommendations aimed at ensuring efficient 

allocation and use of radio-frequency spectrum for wireless broadband 

services. The plan recommended that FCC make 300 MHz of spectrum 

newly available for mobile broadband use in the next 5 years and 500 

MHz of spectrum for broadband within the next 10 years. In June 2010, 

the President issued a memorandum with a similar goal for NTIA working 

in collaboration with FCC.13

 

11The Balanced Budget Act of 1997 (BBA-97) amended Section 309(j) of the 

Communications Act to require the Commission to grant licenses through the use of 

competitive bidding when mutually exclusive applications for initial licenses are accepted 

for filing, unless certain specific statutory exemptions apply. BBA-97 § 3002(a) (codified at 

47 U.S.C. § 309(j)). Section 309(j)(2) exempts from auctions licenses and construction 

permits for public safety radio services, digital television service licenses and permits 

given to existing terrestrial broadcast licensees to replace their analog television service 

licenses, and licenses and construction permits for noncommercial educational broadcast 

stations and public broadcast stations described in section 397(6) of the Communications 

Act. 

12See 47 U.S.C. § 309(j)(11). 

13Memorandum for the Heads of Executive Departments and Agencies, Unleashing the 

Wireless Broadband Revolution (Presidential Memorandum), rel. June 28, 2010, 75 Fed. 

Reg. 38387, available at http://www.whitehouse.gov/the-press-office/presidentialmemorandum-unleashing-wireless-broadband-revolution. 
 

Page 8 GAO-12-118 Commercial Spectrum 

To accommodate new commercial uses of spectrum, such as wireless 

broadband, FCC must often change its rules to move certain bands of 

spectrum from an existing use to the new use, a process known as 

repurposing spectrum. However, this process can be lengthy—from 7 to 

15 years for the six repurposings that we examined. We identified the 

following factors that contribute to the time it takes FCC to repurpose 

spectrum: the regulatory nature of repurposing, opposition of incumbent 

users, FCC and NTIA coordination on the repurposing of federal 

spectrum, and concerns about interference. FCC identified voluntary 

approaches that it thinks could speed the process by, for example, 

avoiding some opposition; however, these approaches generally require 

congressional approval and face some stakeholder opposition. 

Since most of the usable spectrum in the United States has been 

allocated to existing uses, FCC must often repurpose spectrum from an 

existing use to make it available for new uses. When there are competing 

interests for specific spectrum, FCC determines which use or uses of the 

spectrum will best serve the public interest, considering factors such as 

economic and social value, including importance for public safety. FCC 

also seeks to ensure that the spectrum is technically suitable for the new 

use.14 To repurpose spectrum for a new use, FCC uses a three-phase 

process: 

 Identification. As a first step, FCC identifies a spectrum band, or 

bands, that appear to be good candidates for repurposing. To identify 

candidate bands, FCC conducts a formal study or releases a notice of 

proposed rulemaking soliciting industry input, or another party, such 

as NTIA or Congress, identifies a candidate band. 

 Reallocation. FCC subsequently reallocates the spectrum by 

changing the designated use of the spectrum. FCC develops service 

and other technical rules for the spectrum that define (1) the eligibility 

criteria for users, (2) the services that users can provide, (3) the time 

frames and other requirements for users to build the infrastructure 

required to support the services, and (4) the interference limits. 

 

14Different spectrum bands have certain advantages and disadvantages for various 

applications. For example, the C-band frequencies for satellite service are useful to 

broadcast television networks distributing video content to local television stations, since 

this band is less susceptible to degradation from precipitation than other bands. 

Since 1994, FCC Has 

Made Over 520 

Megahertz of 

Spectrum Available 

for New Uses through 

a Process That Can 

Be Lengthy 

FCC Uses a Multiphase 

Process to Repurpose 

Spectrum 
 

Page 9 GAO-12-118 Commercial Spectrum 

 Reassignment or secondary markets. If the new use entails a licensed 

use of the spectrum, new users must be assigned, or provided 

authorization, to use the spectrum. In some cases, FCC reassigns the 

spectrum to new entities, often using auctions. In other cases, FCC 

permits incumbent licensees to sell or lease their licenses to other 

entities, through a process known as secondary market transactions. 

If the new use entails an unlicensed use of the spectrum, FCC does 

not need to complete a reassignment. 

Since 1994, FCC has completed six major repurposings of spectrum, 

which have made over 520 MHz of spectrum available for new 

commercial uses.15 In most instances, FCC repurposed the spectrum to 

enable mobile broadband service. Five of the six repurposings collectively 

generated over $47 billion in auction revenues, which provides one 

measure of the new economic value arising from the repurposing.16 The 

former uses of the repurposed spectrum included microwave services, 

specialized mobile radio services (such as those used in radio dispatch 

systems), and one-way systems that transmit video (see table 1). 

 

15The six repurposings we examined met the following criteria: (1) the amount of spectrum 

repurposed was 5 MHz or more; (2) the repurposing yielded $100 million or more in 

auction or industry revenue; and (3) reassignment occurred in 1994, when FCC first 

implemented its auction authority, or later. 

16For one of the repurposings, the Mobile Satellite Services S band, FCC did not auction 

the spectrum but rather reassigned the spectrum to eight companies that applied for 

licenses. 

FCC Has Made Over 520 

Megahertz of Spectrum 

Available for New 

Commercial Uses 
 

Page 10 GAO-12-118 Commercial Spectrum 

Table 1: Major Spectrum Repurposings since 1994 

Dollars in millions 

Spectrum band 

Amount 

repurposed 

(MHz) Old use New use 

Auction 

revenues

Mobile Satellite Services 

S band (MSS S band) 

40 Microwave operations by 

broadcast stations for 

transmitting audio and video 

signals. 

Satellite-based mobile voice, 

data, Internet access, and other 

communications. 

N/Aa

Broadband Personal 

Communications Service 

(PCS) 

120 Microwave operations by 

business users, including 

petroleum companies, utilities, 

and railroads. 

Primarily digital mobile phones 

and wireless Internet access. 

$13,989 

Advanced Wireless 

Services-1 (AWS-1) 

90 Federal government use, 

including military tactical radios, 

and commercial fixed-microwave 

uses. 

Third-generation mobile 

broadband and other advanced 

wireless services. 

13,731 

Enhanced Specialized 

Mobile Radio (ESMR) 

14 Mobile radios that communicated 

directly with other mobile or fixed 

radios in a dispatch mode, such 

as taxi fleets, or that 

interconnected with the public 

telephone network through the 

use of a base station. 

Cellular-based services including 

Internet access, two-way 

acknowledgment paging and 

inventory tracking, credit card 

authorization, automatic vehicle 

location, fleet management, 

remote database access, and 

voice mail. 

445

Educational Broadband 

Service / Broadband 

Radio Service (EBS/BRS) 

194 Educational Broadband Service: 

transmission of instructional 

material using high-powered 

systems to accredited 

educational institutions and other 

institutions such as hospitals, 

nursing homes, and training and 

rehabilitation centers. 

Broadband Radio Service: 

primarily high-powered, one-way 

systems transmitting data and 

video to fixed locations. 

Educational Broadband Service: 

transmission of instructional 

services, using low power, 

broadband systems, as well as 

high-speed Internet access for 

students. Licensees may also 

lease excess capacity to other 

entities so long as they meet 

educational programming 

requirements. 

Broadband Radio Service: 

two-way wireless broadband 

services, including voice, data, 

and video. 

134

700 MHz band 70 Analog broadcast televisionb Mobile wireless services. 19,108

Total 528 $47,407

Source: GAO review of FCC documents. 

a

FCC did not use an auction to reassign the Mobile Satellite Services S band; rather FCC reassigned 

the spectrum to eight companies that applied for licenses. The Satellite Industry Association 

estimates that Mobile Satellite Services generated over $2 billion in worldwide revenue in 2010. 

b

The 700 MHz Wireless repurposing was enabled by the transition of television from analog to digital 

service. The transition freed up a portion of the 700 MHz spectrum for new wireless services. 
 

Page 11 GAO-12-118 Commercial Spectrum 

The six major repurposings we reviewed took from 7 to 15 years to 

complete, from the identification through the reassignment phase. For 

example, the Enhanced Specialized Mobile Radio repurposing took 7 

years while three repurposings—Personal Communications Service, 

Advanced Wireless Services-1, and 700 MHz Wireless—took over 10 

years to complete (see fig. 2). Similar to our findings, in the National 

Broadband Plan, FCC noted that the process of revisiting or revising 

spectrum allocations has historically taken 6 to 13 years.17

Figure 2: Timeline for Major Spectrum Repurposings—Identification to Reassignment 

In addition to the time required to complete the repurposing process 

(identification through reassignment), time is needed to relocate existing 

users and allow new users to construct new wireless networks before 

new services can be made available using the repurposed spectrum. 

Typically, existing users must relocate to a new spectrum band or bands, 

and new users must construct the infrastructure required to support their 

services. While the participants undertake most of these actions, FCC 

and other government agencies’ actions and decisions can influence the 

time frames. For example, FCC held the first auction for the Advanced 

Wireless Services-1 repurposing in 2006, but NTIA expects that it will 

take until 2013 for all federal agencies to relocate from the spectrum that 

 

17In some instances, our start and end dates differ from those FCC identified in the 

National Broadband Plan. For example, FCC reported that the Personal Communications 

Service repurposing began in 1989, while we determined that this repurposing began in 

1992. Regardless of the specific start and end dates, both FCC’s and our analyses found 

that the process can be lengthy. 

Major Spectrum 

Repurposings Can Be Time 

Consuming 
 

Page 12 GAO-12-118 Commercial Spectrum 

was repurposed for commercial use.18 In addition, FCC allowed licensees 

15 years from the inception of their license term to begin providing 

substantial service.19 Therefore, substantial service on a widespread 

basis using the Advanced Wireless Services-1 spectrum appears unlikely 

before 2013 and, in theory, could extend to 2021, fully 29 years after the 

beginning of the identification phase, although FCC officials anticipate 

that carriers will generally provide service sooner in order to meet their 

business needs. 

Large majorities of stakeholders and experts that replied to our survey 

indicated that the repurposing process takes too long. In particular, 39 of 

46 stakeholders and 16 of 20 experts reported that it takes longer than it 

should from the time FCC or Congress designates a spectrum band for 

reallocation until the band is available for the new use. Furthermore, 25 of 

these stakeholders and 11 of these experts reported that it takes much

longer than it should. 

Based on our review of several completed and ongoing repurposings, the 

relevant literature, interviews with agency officials and industry 

participants, and our survey of stakeholders and experts, we identified 

four factors that contribute to the time it takes FCC to repurpose 

spectrum. These factors include the regulatory nature of repurposing, 

opposition of incumbent users, FCC and NTIA coordination on the 

repurposing of federal spectrum, and concerns about interference. 

 Regulatory nature of repurposing. FCC’s repurposing of spectrum is 

often an iterative process involving deliberation based on extensive 

 

18U.S. Department of Commerce, Relocation of Federal Radio Systems from the 1710-

1755 MHz Spectrum Band: Fourth Annual Progress Report (March 2011). The report 

notes that approximately 81 percent of the total systems have been relocated from the 

1710-1755 MHz band as of December 2010. 

19Section 27.14 of title 47 of the Code of Federal Regulations provides that a renewal 

applicant receives a preference or renewal expectancy if the applicant has provided 

substantial service during its past license term and has complied with the Communications 

Act and applicable Commission rules and policies. According to this section, substantial 

service is defined as “service which is sound, favorable, and substantially above a level of 

mediocre service which just might minimally warrant renewal.” 47 C.F.R. § 27.14(a). 

Section 27.13 provides that authorizations for the 1710-1755 MHz and 2110-2155 MHz 

bands will have a term not to exceed 10 years from the date of initial issuance or renewal, 

except that authorizations issued on or before December 31, 2009, shall have a term of 15 

years. 47 C.F.R. § 27.13. 

Several Factors Contribute 

to the Lengthiness of the 

Repurposing Process 
 

Page 13 GAO-12-118 Commercial Spectrum 

industry participation. As shown in figure 3, the repurposing of 

spectrum can involve stakeholder coordination efforts, issuance of 

notices of proposed rulemaking and reports and orders, review of 

stakeholder comments and reply comments, and multiple rounds of 

assignment. For example, during the Personal Communications 

Service repurposing, FCC adopted an order in September 1993, and 

67 participants subsequently petitioned FCC for reconsideration 

because of concerns about the spectrum to be reallocated and the 

amount of spectrum to be individually licensed.20 In response, in June 

1994, FCC amended the bands to be reallocated and assigned.21 In 

1995, some stakeholders sued the Commission over the rules it 

established in 1994 pertaining to ownership limitations in the wireless 

communications industry. In November 1995, the Sixth Circuit Court 

of Appeals decided against FCC’s rules and remanded the matter for 

further proceeding.22 In June 1996, FCC issued an order addressing 

these issues.23

 

20Amendment of the Commission’s Rules to Establish New Personal Communications 

Services, Second Report and Order, 8 FCC Rcd 7700 (1993). 

21Amendment of the Commission’s Rules to Establish New Personal Communications 

Services, Memorandum Opinion and Order, 9 FCC Rcd 4957 (1994). 

22Cincinnati Bell Telephone Co. v. FCC, 69 F.3d 752 (6th Cir. 1995). 

23Amendment of Parts 20 and 24 of the Commission’s Rules—Broadband PCS 

Competitive Bidding and the Commercial Mobile Radio Service Spectrum Cap; 

Amendment of the Commission’s Cellular/PCS Cross-Ownership Rule, Report and Order, 

11 FCC Rcd 7824 (1996) aff’d, 12 FCC Rcd 14031 (1997), aff’d sub nom. BellSouth Corp. 

v. FCC, 162 F.3d 1215 (D.C. Cir. 1999). Throughout the Personal Communications 

Service repurposing, FCC issued 6 notices of proposed rulemaking and 34 orders, and 

received over 2,600 filings from interested parties. 
 

Page 14 GAO-12-118 Commercial Spectrum 

Figure 3: Process to Repurpose Spectrum from an Existing Use to a New Use 

a

FCC may permit incumbent licensees to sell or lease their licenses to other entities, a process known 

as secondary market transactions. 

b

Certain exemptions apply to FCC’s auction authority, including exemptions for public safety radio, 

digital television licenses to replace analog licenses, and noncommercial educational and public 

broadcast stations. 

As also shown in figure 3, the assignment and, in some instances 

multiple reassignments, of spectrum can lengthen the process of 

repurposing spectrum. In some cases, prior to an auction and at the 

direction of Congress or the courts, or the request of licensees and 

potential bidders, FCC clarifies or revises the auction and relocation 

rules. For example, in providing auction authority, which occurred 

during the Personal Communications Service repurposing, Congress 

directed FCC to expand opportunities for small businesses, minorities, 
 

Page 15 GAO-12-118 Commercial Spectrum 

and women.24 FCC subsequently adopted competitive bidding rules 

designed to encourage designated entities participation in Personal 

Communications Service.25 However, 3 days before the auction, the 

U.S. Supreme Court decided that “all racial classifications, imposed 

by whatever federal, state, or local government actor, must be 

analyzed by a reviewing court under strict scrutiny” and the 

Commission subsequently postponed the auction.26 In other 

instances, the bankruptcy or default of an auction winner lengthened 

 

24In the Omnibus Budget Reconciliation Act of 1993, Congress authorized the competitive 

bidding of spectrum-based services and mandated that small businesses, rural telephone 

companies, and businesses owned by members of minority groups and women 

(collectively known as “designated entities”) be ensured the opportunity to participate in 

the provision of such services. 47 U.S.C. § 309(j)(4)(D); see also id. § 309(j)(3)(B). In the 

Fifth Report and Order, FCC adopted competitive bidding rules designed to encourage 

designated entity participation in the broadband Personal Communications Service. 9 

FCC Rcd 5532 (1994); recon. Implementation of Section 309(j) of the Communications 

Act—Competitive Bidding, Fifth Memorandum Opinion and Order, 10 FCC Rcd 403 (1994) 

(“Competitive Bidding Fifth Memorandum Opinion and Order”), erratum, 60 Fed. Reg. 

5333 (1995). 

25Specifically, FCC established “entrepreneurs’ blocks” (the C and F frequency blocks 

allocated for broadband Personal Communication Service) for which eligibility was limited 

to individuals and entities under a certain financial size. FCC also adopted special 

provisions for businesses owned by members of minority groups or women and analyzed 

their constitutionality utilizing the “intermediate scrutiny” standard of review articulated in 

Metro Broadcasting, Inc. v. FCC, 497 U.S. 547, 564-565 (1990). FCC made subsequent 

changes to the entrepreneurs’ block rules and special provisions for designated entities in 

the Fifth MO&O. Fifth Report and Order, 9 FCC Rcd 5532 (1994) (Fifth R&O), recon. Fifth 

Memorandum Opinion and Order, 10 FCC Rcd 403 (Fifth MO&O), erratum, 60 Fed. Reg. 

5333 (1995). 

26Adarand Constructors. Inc. v. Pena, 515 U.S. 200 (1995). 
 

Page 16 GAO-12-118 Commercial Spectrum 

the repurposing of spectrum.27 On several occasions, after winners of 

the original auction declared bankruptcy or defaulted on their 

payments, FCC repeated auctions. For example, FCC’s auctions 10, 

22, and 35 included reauctions of licenses won at prior auctions. 

 Opposition of incumbent users. The completed repurposings we 

reviewed involved opposition from incumbent users that took time to 

resolve. Incumbent users are likely to incur costs for relocating but 

derive little, if any, benefit and are therefore often reluctant to make a 

move. For example, during the Personal Communications Service 

repurposing, incumbent microwave users, which included utilities, 

public safety entities, and petroleum and natural gas companies, 

raised concerns that an allocation would displace a large number of 

them, disrupt their operations to the detriment of the public, and 

require them to purchase new equipment. In the Advanced Wireless 

Services-1 repurposing, incumbent government agencies had 

difficulties identifying current users of the spectrum and were reluctant 

to give up spectrum because they believed the spectrum was critical 

to fulfilling their mission and that relocating would cause them to incur 

staff time and expenses for which they had not budgeted. In the 700 

MHz Wireless repurposing, television broadcasters raised concerns 

about the transition from analog to digital television, including their 

need to use more spectrum for advanced television services and the 

financial costs of building digital television stations. A law firm with 

experience in FCC’s repurposings characterized reallocations as 

 

27For example, NextWave was the high bidder for 95 C, D, E, and F block, broadband 

Personal Communications Service licenses in auctions held from 1995 to 1997. On June 

8, 1998, NextWave filed for Chapter 11 bankruptcy protection in the U.S. Bankruptcy 

Court for the Southern District of New York. Following extensive litigation, the U.S. 

Supreme Court held that NextWave’s licenses had not automatically cancelled for 

nonpayment while it was in bankruptcy. FCC v. NextWave, 537 U.S. 293 (2003). As part 

of its reorganization process, NextWave obtained FCC approval to transfer certain of its C 

and F block PCS licenses to Cingular. Applications for Consent to the Assignment of 

Licenses Pursuant to Section 310(d) of the Communications Act from NextWave Personal 

Communications, Inc., Debtor-in-Possession, and NextWave Power Partners, Inc., 

Debtor-in-Possession, to subsidiaries of Cingular Wireless, Inc., Memorandum Opinion & 

Order, 19 FCC Rcd 2570 (2004). In April 2004, NextWave entered a settlement 

agreement with FCC whereby it would retain certain of its C and F block licenses, and 

would return the remaining licenses to FCC. On May 25, 2004, the bankruptcy court 

approved this settlement agreement. Order Granting Motion Pursuant to Section 363 of 

the Bankruptcy Code, In re: NextWave Personal Communications, Inc. et al., 98B21529 

(Bankr. S.D.N.Y.) (May 25, 2004). 
 

Page 17 GAO-12-118 Commercial Spectrum 

“contests between incumbent service providers and the new entrants 

competing to unseat them.” 

 FCC and NTIA coordination on the repurposing of federal spectrum. 

Government efforts to coordinate the repurposing of federal spectrum 

to commercial use can take many years; several factors contribute to 

the lengthy time frame, including the lack of data and resources and 

the time necessary to relocate existing federal users. For example, 

the Advanced Wireless Services-1 repurposing, which combined 

federal and nonfederal spectrum, took over 14 years and the passage 

of several laws to complete. In 1992, FCC first identified the upper 

Advanced Wireless Services-1 band, 2110-2150 MHz, for reallocation 

to services using new and innovative technologies.28 In 1995, NTIA 

identified the lower Advanced Wireless Services-1 band, 1710-1755 

MHz, for transfer from exclusive use by the federal government to 

FCC for commercial use.29 In 1997 legislation was enacted that 

required NTIA to accelerate the availability of the lower Advanced 

Wireless Services-1 band, and in 1998 legislation was enacted that 

sought to encourage the transfer of spectrum from federal 

government to private use by providing for mandatory reimbursement 

of government spectrum users required to relocate from their 

spectrum, including the lower Advanced Wireless Services-1 band.30

 

28See Redevelopment of Spectrum to Encourage Innovation in the Use of New 

Telecommunications Technologies, First Report and Order and Third Notice of Proposed 

Rule Making, 7 FCC Rcd 6886 (1992); Second Report and Order, 8 FCC Rcd 6495 

(1993); Third Report and Order and Memorandum Opinion and Order, 8 FCC Rcd 6589 

(1993); Memorandum Opinion and Order, 9 FCC Rcd 1943 (1994); Second Memorandum 

Opinion and Order, 9 FCC Rcd 7797 (1994); aff’d Association of Public Safety 

Communications Officials-International, Inc. v. FCC, 76 F.3d 395 (D.C. Cir. 1996) 

(collectively, “Emerging Technologies proceeding”). 

29NTIA identified the band 1710-1755 MHz for transfer, with certain Federal operations to 

remain protected indefinitely. See NTIA, Spectrum Reallocation Final Report, Response to 

Title VI Omnibus Budget Reconciliation Act of 1993, NTIA Special Publication 95-32, at 

App. E and page F-4 (February 1995). 

30The Balanced Budget Act of 1997 required NTIA to accelerate the availability of the 

1710-1755 MHz band to allow auctioning of this spectrum to commence after Jan. 1, 

2001, and to be completed by Sept. 30, 2002. See BBA-97, Section 3002(b). The Strom 

Thurmond National Defense Authorization Act for Fiscal Year 1999, required that funds 

would be made available by private sector entities receiving spectrum in the band 1710-

1755 MHz for the cost of relocating or modifying all federal government radio 

communications systems required to vacate or modify their operations in the band 1710-

1755 MHz after an auction has taken place. Pub. L. No. 105-261, 112 Stat. 1920; 47 

U.S.C. § 923(g). 
 

Page 18 GAO-12-118 Commercial Spectrum 

From 2000 through 2002, FCC and NTIA conducted further studies to 

determine appropriate bands for Advanced Wireless Services-1. 

Finally, in 2002, NTIA issued a study31 and FCC issued an order32

allocating 90 MHz for Advanced Wireless Services. 

 Concerns about interference. Users in adjacent bands often oppose a 

repurposing of spectrum because they are concerned that the new 

service will interfere with their existing service. A good example of this 

concern arises with the 700 MHz Wireless repurposing, which 

included the relocation of broadcast television stations; public safety 

organizations raised the concern that the proposed relocation would 

result in increased interference between broadcasting and public 

safety operations. Similarly, with the Advanced Wireless Services-1 

repurposing, some stakeholders raised concerns about the potential 

for interference between Multipoint Distribution Service licensees and 

Advanced Wireless Services systems.33

Resolving issues such as the opposition of incumbent users and 

concerns about interference lengthens the time necessary to complete 

the repurposing of spectrum, thereby delaying the introduction of possibly 

more economically valuable services. As an independent regulatory 

agency, FCC must follow many, but not all, federal laws related to 

rulemaking. In particular, the Administrative Procedures Act outlines a 

multistep process to initiate and develop rules and includes provisions for 

parties to challenge them, which FCC must follow.34 Many steps require 

agencies to provide public notice of proposed or final actions, as well as 

provide a period of time for interested parties to comment on the notice. 

Furthermore, the Communications Act outlines procedures for addressing 

petitions for reconsideration by FCC and appeals to federal court for FCC 

 

31U.S. Department of Commerce, NTIA, An Assessment of the Viability of Accommodating 

Advanced Mobile Wireless (3G) Systems in the 1710-1770 MHz and 2110-2170 MHz 

Bands, report rel. July 22, 2002. 

32Amendment of Part 2 of the Commission’s Rules to Allocate Spectrum Below 3 GHz for 

Mobile and Fixed Services to Support the Introduction of New Advanced Wireless 

Services, Including Third Generation Wireless Systems, Second Report and Order, 17 

FCC Rcd 23193 (2002). 

33Multipoint distribution service, also known as wireless cable, was generally used for the 

transmission of data and video programming to subscribers using high-powered systems. 

345 U.S.C. § 551, et seq. 
 

Page 19 GAO-12-118 Commercial Spectrum 

rules;35 the U.S. Courts of Appeals have jurisdiction to review all final FCC 

rules.36 Given that the spectrum issues are often complicated and 

controversial, FCC often issues multiple orders in the same proceeding to 

deal with the many comments it receives and to address petitions for 

reconsideration, as well as any direction from the courts. In the National 

Broadband Plan, FCC identified voluntary approaches, such as incentive 

auctions, that it thinks could speed the process. By incorporating 

incentives into the process, FCC may avoid some opposition to 

repurposings and thereby reduce the time necessary to repurpose 

spectrum. However, these incentive approaches generally require 

congressional approval and face stakeholder opposition themselves. As 

we reported in 2003, “while spectrum reform is increasingly being 

discussed, debated, and reviewed, it does not appear likely that timely 

reforms can be agreed upon amid the diversity of views held by 

stakeholders,” a situation that appears to hold to this day.37

The National Broadband Plan includes recommendations in several areas 

aimed at meeting future spectrum needs. Most of the recommendations 

are directed at FCC alone, some are directed at FCC and NTIA jointly, 

and some are directed at Congress. For our analysis, we group the 

recommendations directed to FCC into five categories: make more 

spectrum available for wireless broadband use by 2015, expand 

incentives and mechanisms to reallocate spectrum, expand opportunities 

for innovative spectrum access models, enhance the usefulness of 

spectrum for wireless backhaul, and enhance FCC’s spectrum policy 

making. Discussion of the first three categories follows; appendix III 

provides additional details on those three categories and also discusses 

the last two categories. 

 

3547 U.S.C. §§ 405 and 402, respectively. 

36In certain cases, appeals to FCC rules must be made only to the U.S. Court of Appeals 

for the D.C. Circuit. 47 U.S.C. § 402(b). 

37GAO, Telecommunications: Comprehensive Review of U.S. Spectrum Management with 

Broad Stakeholder Involvement Is Needed, GAO-03-277 (Washington, D.C.: Jan. 31, 

2003). 

Responding Experts 

and Stakeholders Had 

Mixed Views on FCC’s 

Plans and Recent 

Actions to Meet 

Future Spectrum 

Needs 
 

Page 20 GAO-12-118 Commercial Spectrum 

To meet anticipated increases in demand for wireless broadband services, 

the plan contained a recommendation that FCC make 300 MHz of 

spectrum newly available for such services by 2015 and 500 MHz by 2020. 

These targets were based on an FCC staff forecast of spectrum demand. 

In the plan, the largest source of spectrum—120 MHz—arises from the 

repurposing of a portion of the spectrum currently allocated for broadcast 

television service. Most experts and stakeholders other than television 

broadcasters responding to our survey supported this recommendation, 

while most responding broadcasters opposed it (see table 2). Both a 

wireless device manufacturer and an expert said that the recommendation 

is consistent with expected increases in demand for spectrum. Two 

broadcasters said that wireless service providers could meet additional 

demand by using their existing spectrum more intensively. 

To make 300 MHz of spectrum newly available by 2015, the plan included 

five recommendations related to specific spectrum bands. In addition to 

repurposing the 120 MHz of spectrum currently allocated to broadcast 

television, the plan recommended accelerating terrestrial use of Mobile 

Satellite Services spectrum by providing sufficient flexibility to licensees to 

increase terrestrial broadband use of the spectrum, auctioning Advanced 

Wireless Services and the Upper 700 MHz D-Block spectrum,38 and 

revising outdated interference rules in the Wireless Communications 

Services spectrum that largely preclude the use of the spectrum for 

 

38The 700 MHz D-Block spectrum was made available for auction through the transition of 

television from analog to digital service, which freed up a portion of the 700 MHz spectrum 

for new wireless services. FCC established the Upper 700 MHz D Block to be licensed on 

a nationwide basis to a single entity via auction. FCC’s auction rules required the winning 

bidder for the D Block to enter into a public/private partnership with the nationwide 

licensee of the public safety broadband spectrum, a nonprofit entity established by 

national public safety leadership. That requirement was intended to enable construction of 

an interoperable broadband network that would serve both commercial and public safety 

users. This 10 MHz block of spectrum did not receive a winning bid in FCC’s 700 MHz 

auction held in 2008. 

Responding Experts and 

Stakeholders Generally 

Agreed with Making More 

Spectrum Available for 

Wireless Broadband Use 

by 2015 

Recommendations in Plan 
 

Page 21 GAO-12-118 Commercial Spectrum 

broadband. These recommendations, as well as experts’ and 

stakeholders’ level of agreement with the recommendations, are shown in 

table 2; in the table, we sometimes separately report broadcasters to 

illustrate meaningful differences in their responses. 

Table 2: Expert and Stakeholder Respondents’ Agreement with National Broadband Plan Recommendations Aimed at Making 

More Spectrum Available for Wireless Broadband Use by 2015 

Recommendation in plan 

Type of respondent Agreed

Neither 

agreed nor 

disagreed Disagreed Total

Overall recommendation: 

Make 300 MHz available by 2015 and 500 MHz by 2020 

Expert 16 0 3 19

Stakeholder - broadcaster 0 2 8 10

Stakeholder - nonbroadcaster 28 4 6 38

Total 44 6 17 67

Recommendations on specific bands: 

Reallocate portion of television spectrum (120 MHz) 

Expert 14 1 3 18

Stakeholder - broadcaster 0 0 11 11

Stakeholder - nonbroadcaster 27 4 6 37

Total 41 5 20 66

Accelerate terrestrial deployment in Mobile Satellite Services spectrum (90 MHz) 

Expert 12 2 2 16

Stakeholder 23 13 7 43

Total 35 15 9 59

Auction Advanced Wireless Services spectrum (60 MHz) 

Expert 16 1 1 18

Stakeholder 33 8 5 46

Total 49 9 6 64

Make Wireless Communications Services spectrum available (20 MHz) 

Expert 16 1 1 18

Stakeholder 19 20 6 45

Total 35 21 7 63

Auction the Upper 700 MHz D Block (10 MHz)a 

Expert 16 1 1 18

Stakeholder 20 11 12 43

Total 36 12 13 61

Source: GAO survey. 
 

Page 22 GAO-12-118 Commercial Spectrum 

Note: The total number of responses for each recommendation varied based on the number of 

respondents that chose to answer the question pertaining to the recommendation. The figures shown 

under “agreed” include respondents that either strongly agreed or somewhat agreed with the 

recommendation, and the responses shown under “disagreed” include respondents that either 

strongly disagreed or somewhat disagreed with the recommendation. Appendix III includes figures for 

the more detailed response categories, as well for each type of stakeholder. 

a

The 700 MHz D-Block spectrum was made available for auction through the transition of television 

from analog to digital service, which freed up a portion of the 700 MHz spectrum for new wireless 

services. FCC established the Upper 700 MHz D Block to be licensed on a nationwide basis to a 

single entity via auction. FCC’s auction rules required the winning bidder for the D Block to enter into 

a public/private partnership with the nationwide licensee of the public safety broadband spectrum, a 

nonprofit entity established by national public safety leadership. That requirement was intended to 

enable construction of an interoperable broadband network that would serve both commercial and 

public safety users. This 10 MHz block of spectrum did not receive a winning bid in FCC’s 700 MHz 

auction held in 2008. 

The majority of responding experts and stakeholders agreed with each of 

the five recommendations related to specific bands.39 However, the 

recommendation on reallocating 120 MHz of television spectrum has 

generated a significant amount of controversy, and this was reflected in 

our survey results; the 120 MHz of television spectrum in this 

recommendation is in addition to the spectrum made available through 

the transition of television from analog to digital service in 2009. Experts 

and stakeholders other than broadcasters strongly supported the 

recommendation, whereas all 11 broadcasters strongly opposed it. FCC, 

as well as some experts and stakeholders who supported reallocating a 

portion of the television band, said that the spectrum would have much 

higher economic value if it were allocated for wireless broadband. FCC, 

for instance, argues that reallocating television spectrum for mobile 

broadband would increase its value by roughly a factor of 10. According 

to FCC, this difference in value reflects, in part, “challenging long-term 

trends” facing the television broadcasting industry; FCC noted, for 

example, that the percentage of households viewing television solely 

through over-the-air broadcasts declined from 24 percent in 1999 to 10 

percent in 2010, and since 2005, broadcast television station revenues 

have declined 26 percent.40 In contrast, broadcasters responding to our 

survey cited the following arguments against reallocating a portion of the 

television spectrum: 

 

39In our survey results, we grouped the following types of stakeholders into the “other” 

category: public interest groups, infrastructure providers, Mobile Satellite Services 

companies, a private user, a Satellite Digital Audio Radio Service provider, and spectrum 

data managers. 

40FCC, Connecting America: The National Broadband Plan, page 89. 
 

Page 23 GAO-12-118 Commercial Spectrum 

 Doing so would likely have a significant, negative impact on the 

public’s access to local television broadcasts, both via free over-theair television and via cable and satellite, because broadcasters use 

spectrum to provide local broadcasts to viewers both directly over-theair and indirectly by broadcasting their signals to cable and satellite 

television providers, which then retransmit the local broadcasts to 

their subscribers. 

 Broadcasters are deploying mobile digital television with their 

spectrum. This deployment will play a significant role in mobile 

broadband content delivery and should be encouraged to flourish as it 

is the most efficient way of distributing video, which Cisco Systems, 

Inc. says will account for 66 percent of all mobile traffic in 2015.41

 A better way to move underutilized broadcast spectrum to mobile 

carriers would be to allow broadcasters to sell or lease such spectrum 

to mobile carriers in a private market transaction. 

 FCC should not implement this recommendation without completing a 

full spectrum inventory that also analyzes current utilization. Action, if 

at all, should be predicated on demonstrated need rather than on 

assertions of a looming spectrum crisis and after full investigation of 

whether less disruptive alternatives to reallocation of broadcast 

spectrum could address demonstrated needs. 

In the National Broadband Plan, FCC acknowledges that “over-the-air 

television continues to serve important functions in our society,” by 

providing, among other things, free access to news, entertainment, and 

local programming; children’s educational programming; coverage of 

community news and events; reasonable access for federal political 

candidates; and closed captioning and emergency broadcast information. 

Therefore, FCC says that the plan’s recommendations “seek to preserve 

[over-the-air television] as a healthy, viable medium going forward,” and 

the plan calls for FCC to “study and develop policies to ensure that its 

longstanding goals of competition, diversity, and localism [in broadcast 

television] are achieved.” However, these statements do not appear to 

have assuaged the concerns of broadcasters. 

 

41Cisco Systems, Inc. is a supplier of Internet routers, which are hardware devices or 

software programs that forward Internet and network traffic between networks and are 

critical to their operation. 
 

Page 24 GAO-12-118 Commercial Spectrum 

To implement the plan’s recommendations to make more spectrum 

available for broadband in specific bands, FCC, among other things: 

 performed technical analysis and worked with broadcast industry 

engineers and experts in related fields on how reallocating a portion of 

television spectrum to broadband could work; 

 issued a proposed rule to establish a regulatory framework to facilitate 

wireless broadband uses of television bands, in anticipation of the 

Commission’s intended future reallocation of this spectrum to 

broadband; 

 granted a waiver to a Mobile Satellite Services provider, 

LightSquared, allowing it to expand its terrestrial use of its satellite 

spectrum for broadband, conditional on addressing concerns about 

interference with Global Positioning System devices;42

 added co-primary fixed and mobile terrestrial wireless allocations to 

the 2 GHz satellite band and gave Mobile Satellite Services licensees 

the flexibility to lease their spectrum to terrestrial operators via 

spectrum manager leasing arrangements, both of which FCC sees as 

steps toward providing flexibility to allow greater use of the band for 

mobile broadband; 

 revised its interference rules in Wireless Communications Services 

spectrum to facilitate its use for broadband, along the lines 

recommended by the plan; and 

 issued analyses supporting its recommendation to auction the Upper 

700 MHz D block; while the plan recommends the auction of this 

band, several proposals in the 112th Congress, such as the 

SPECTRUM Act, S.911, and the Public Safety Spectrum and 

Wireless Innovation Act, H.R. 2482, call for the reallocation of this 

band for deployment of a nationwide broadband public safety network 

 

42LightSquared Subsidiary LLC, Request for Modification of its Authority for an Ancillary 

Terrestrial Component, Order and Authorization, 26 FCC Rcd 566 (2011). See also, 

Status of Testing in Connection with LightSquared’s Request for ATC Commercial 

Operating Authority, Public Notice, DA-11-1537, 2011 FCC LEXIS 3768 (Sept. 13, 2011). 

FCC, in consultation with NTIA, has determined that additional targeted testing is needed 

to ensure that any potential commercial terrestrial service offered by LightSquared will not 

cause harmful interference to GPS operations. 

Implementation of 

Recommendations 
 

Page 25 GAO-12-118 Commercial Spectrum 

and therefore FCC is waiting to see if any related active legislation is 

passed before proceeding with implementation of this 

recommendation. 

Experts and stakeholders responding to our survey that supported the 

plan’s overall recommendation to make 300 MHz of spectrum available 

for wireless broadband by 2015 were fairly evenly split between those 

satisfied and those dissatisfied with FCC’s overall progress in 

implementing the recommendation (see table 3). In contrast, regarding 

FCC’s progress on the recommendations aimed at specific bands, 

experts and stakeholders tended to be more satisfied than dissatisfied. 

For example, experts and stakeholders were generally satisfied with 

FCC’s progress on implementing the recommendation to accelerate 

terrestrial deployment in Mobile Satellite Services spectrum but were 

generally dissatisfied with FCC’s progress on the Upper 700 MHz D 

Block; although, as we note above, FCC is waiting on the outcome of 

pending legislation pertaining to this spectrum band before taking further 

action. 

Table 3: Expert and Stakeholder Respondents’ Satisfaction with FCC’s Progress in Making More Spectrum Available for 

Wireless Broadband Use by 2015 

Recommendation in plan 

Type of respondent Satisfied

Neither 

satisfied nor 

dissatisfied Dissatisfied Total

Overall recommendation: 

Make 300 MHz available by 2015 and 500 MHz by 2020 

Expert 7 2 6 15

Stakeholder 9 8 9 26

Total 16 10 15 41

Recommendations on specific bands: 

Reallocate portion of television spectrum (120 MHz) 

Expert 8 2 4 14

Stakeholder 16 6 4 26

Total 24 8 8 40

Accelerate terrestrial deployment in Mobile Satellite Services spectrum (90 MHz) 

Expert 7 2 3 12

Stakeholder 15 1 6 22

Total 22 3 9 34

Auction Advanced Wireless Services spectrum (60 MHz) 

Expert 9 4 2 15

Stakeholder 10 7 12 29
 

Page 26 GAO-12-118 Commercial Spectrum 

Recommendation in plan 

Type of respondent Satisfied

Neither 

satisfied nor 

dissatisfied Dissatisfied Total

Total 19 11 14 44

Make Wireless Communications Services spectrum available (20 MHz) 

Expert 8 3 4 15

Stakeholder 9 1 8 18

Total 17 4 12 33

Auction the Upper 700 MHz D Block (10 MHz) 

Expert 4 5 7 16

Stakeholder 4 4 9 17

Total 8 9 16 33

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation. The total number of responses for each recommendation varied based on the 

number of respondents that chose to answer the question pertaining to the recommendation. The 

figures shown under “satisfied” include respondents that were either very satisfied or somewhat 

satisfied with FCC’s progress, and the responses shown under “dissatisfied” include respondents that 

were either strongly dissatisfied or somewhat dissatisfied with FCC’s progress. Appendix III includes 

figures for the more detailed response categories, as well for each type of stakeholder. 

Respondents expressed a variety of views on FCC’s progress. For 

example, one expert reported that FCC should have auctioned the Upper 

700 MHz D block already but was satisfied with FCC’s efforts to 

accelerate terrestrial deployment in Mobile Satellite Services spectrum. 

Another expert said that FCC’s approach to spectrum policy has resulted 

in the U.S. mobile and fixed wireless broadband industries losing ground 

to their foreign counterparts. An infrastructure provider responded that 

FCC is working well with NTIA to free up spectrum for auctions. 

Additional details on FCC’s actions to implement these recommendations, 

as well as experts’ and stakeholders’ views on the recommendations and 

on FCC’s implementation, are contained in appendix III. 
 

Page 27 GAO-12-118 Commercial Spectrum 

The National Broadband Plan included four recommendations aimed at 

expanding incentives and mechanisms to reallocate spectrum. We 

considered the following three of those recommendations in our review: 

 to motivate existing spectrum licensees to voluntarily give up their 

licenses so that FCC could more quickly reallocate the spectrum to 

higher valued services, the plan recommended that Congress should 

consider giving FCC the authority to conduct incentive auctions in 

which licensees that choose to relinquish their licenses would receive 

a portion of the proceeds realized by the auction of their licenses; 

 to promote the efficient use of spectrum by compelling spectrum 

licensees to recognize the value to society of their licenses, the plan 

recommended that Congress consider granting authority to FCC to 

impose fees on licensees; and 

 because of concerns that its rules allowing spectrum licensees to 

lease their licenses—designed to promote access to underutilized 

spectrum—are not as effective as they could be, the plan 

recommended that FCC should identify and address barriers to 

secondary markets.43

The recommendations enjoyed varying levels of agreement from the 

experts and stakeholders responding to our survey (see table 4). In the 

table, we sometimes separately report different subgroups of 

stakeholders to illustrate meaningful differences in their responses. 

 

43The plan also included a recommendation that Congress consider building upon the 

success of the Commercial Spectrum Enhancement Act (Pub. L. No. 108-494, Title II, 118 

Stat. 3986) to fund additional approaches to facilitate relocation of incumbent federal 

users. We did not consider this recommendation in this review because it relates more to 

NTIA’s management of federal spectrum use than to FCC’s management of commercial 

spectrum use. 

Responding Experts and 

Stakeholders Had Mixed 

Views on Expanding 

Incentives and 

Mechanisms to Reallocate 

Spectrum 

Recommendations in Plan 
 

Page 28 GAO-12-118 Commercial Spectrum 

Table 4: Expert and Stakeholder Respondents’ Agreement with National Broadband Plan Recommendations Aimed at 

Expanding Incentives and Mechanisms to Reallocate Spectrum 

Recommendation in plan 

Type of respondent Agreed

Neither 

agreed nor 

disagreed Disagreed Total

Grant authority to conduct incentive auctions 

Expert 18 0 1 19

Stakeholder - broadcaster 1 5 5 11

Stakeholder - nonbroadcaster 30 2 7 39

Total 49 7 13 69

Grant authority to impose fees on licensees 

Expert 15 1 4 20

Broadcaster 0 0 13 13

Wireless device manufacturer 4 2 3 9

Wireless service provider 6 1 13 20

Other stakeholder 4 3 2 9

Total 29 7 35 71

Address barriers to secondary markets 

Expert 18 1 1 20

Stakeholder 41 4 5 50

Total 59 5 6 70

Source: GAO survey. 

Note: The total number of responses for each recommendation varied based on the number of 

respondents that chose to answer the question pertaining to the recommendation. The figures shown 

under “agreed” include respondents that either strongly agreed or somewhat agreed with the 

recommendation, and the responses shown under “disagreed” include respondents that either 

strongly disagreed or somewhat disagreed with the recommendation. Appendix III includes figures for 

the more detailed response categories, as well for each type of stakeholder. 

Far more experts and stakeholders other than broadcasters agreed than 

disagreed with granting FCC authority to conduct incentive auctions, 

while more broadcasters disagreed than agreed. FCC proposed incentive 

auctions as a mechanism to free up 120 MHz of spectrum currently 

allocated to television service, which as we noted above, broadcasters 

oppose. The experts and stakeholders expressed a variety of views about 

incentive auctions. For example, one expert commented that Congress 

should simply allow FCC to pay some of the auction revenues to 

broadcasters instead of the U.S. Treasury and avoid legislating any 

details of the auction. An infrastructure provider said that incentive 

auctions would take years off of FCC’s usual repurposing approach, 

which as we noted earlier has taken from 7 to 15 years. A broadcaster 

commented that instead of using incentive auctions to reallocate 
 

Page 29 GAO-12-118 Commercial Spectrum 

television spectrum, FCC should allow licensees to sell or lease their 

licenses to wireless service providers. Another broadcaster commented 

that incentive auctions would be acceptable so long as (1) participation by 

broadcasters is truly voluntary and (2) FCC reimburses broadcasters who 

choose not to participate for the costs they incur to relocate to new 

frequencies.44

Many more experts agreed than disagreed with granting FCC authority to 

impose fees on licensees, while slightly more wireless device 

manufacturers and stakeholders in our “other” category agreed than 

disagreed. All broadcasters disagreed with granting FCC authority to 

impose fees, and about twice as many wireless service providers 

disagreed as agreed; as licensees, broadcasters and wireless service 

providers could be subject to the fees. The experts and stakeholders 

expressed a variety of views about fees. An expert commented that the 

value of spectrum is usually far greater than the amount recovered in 

auctions, and that fees can better capture this value by being adjusted 

upward if the value of the spectrum appreciates. Similarly, a public 

interest group commented that annual fees would increase spectrum 

utilization, give license holders who do not use their spectrum an 

incentive to return it, and raise far more money for the U.S. Treasury than 

auctions do. Alternatively, an expert responded that fees would not create 

incentives for efficient use of spectrum, and suggested that instead FCC 

allow competitive forces wider scope by permitting licensees to deploy 

any service, technology, or business model that may be profitable. A 

range of stakeholders commented that fees should be reduced or waived 

for current licensees that purchased their licenses at auction or that 

already pay annual regulatory fees. 

Almost all responding experts and most stakeholders agreed with the 

recommendation that FCC identify and address barriers to secondary 

markets. An expert responded that addressing barriers to secondary 

markets would eliminate the need for incentive auctions. Similarly, a 

broadcaster commented that allowing all current licensees to participate 

 

44To ensure that the spectrum freed up in an incentive auction is effectively usable for 

mobile broadband, FCC will need to assign new frequencies to some television stations 

through a realignment process sometimes called repacking. According to FCC, because 

digital technology allows stations to use virtual channel numbers, even if a station’s 

frequency changes through realignment, it can continue to have its same channel number 

display on television screens and set-top boxes. Further, FCC has said broadcasters will 

be fully reimbursed for any costs incurred in changing channels. 
 

Page 30 GAO-12-118 Commercial Spectrum 

in secondary markets would enable market forces to determine the best 

use for spectrum without requiring wholesale reallocation of designated 

bands. A wireless service provider noted that FCC’s secondary market 

rules have been greatly successful in creating access to spectrum 

resources by nonlicensees, with leasing arrangements becoming 

increasingly commonplace. 

In response to the recommendation on secondary markets, FCC officials 

told us that the Commission reviewed its secondary markets policies and 

concluded that it should do more to promote these markets. It also 

requested public comments on technologies that could enable dynamic 

sharing of spectrum, including how such technologies could facilitate 

secondary markets.45 FCC officials told us that the Commission intended 

to issue a related order, tentatively by the end of 2011. Among those 

responding to our survey and that support the recommendation, more 

experts and wireless device manufacturers were satisfied than 

dissatisfied with FCC’s progress, while more wireless service providers 

were dissatisfied than satisfied (see table 5). 

Table 5: Expert and Stakeholder Respondents’ Satisfaction with FCC’s Progress in 

Identifying and Addressing Barriers to Secondary Markets 

Type of respondent Satisfied

Neither 

satisfied nor 

dissatisfied Dissatisfied Total

Expert 7 3 5 15

Broadcaster 0 5 3 8

Wireless device manufacturer 4 2 2 8

Wireless service provider 3 4 8 15

Other stakeholder 2 6 0 8

Total 16 20 18 54

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation. The figures shown under “satisfied” include respondents that were either very 

satisfied or somewhat satisfied with FCC’s progress, and the responses shown under “dissatisfied” 

include respondents that were either strongly dissatisfied or somewhat dissatisfied with FCC’s 

progress. Appendix III includes figures for the more detailed response categories. 

 

45Dynamic sharing of spectrum, sometimes referred to as “dynamic spectrum access,” 

can be enabled by the use of “cognitive” radios that are able at any moment in time to 

determine and use spectrum that is unused and available. 

Implementation of 

Recommendations 
 

Page 31 GAO-12-118 Commercial Spectrum 

Two broadcasters commented that FCC’s analysis of barriers to 

secondary markets must include broadcast spectrum to be credible and 

effective. An expert questioned the relevance of dynamic spectrum 

access to secondary markets, and two stakeholders commented that 

dynamic spectrum access is not yet technically mature enough to support 

secondary markets. 

The National Broadband Plan includes four recommendations aimed at 

expanding opportunities for innovative spectrum access models. Such 

models provide alternatives to the traditional means of accessing 

spectrum—exclusive-use licensing. Examples include allowing unlicensed 

devices to use certain portions of the spectrum without any guarantee of 

interference protection and dynamic spectrum access. The four related 

recommendations are as follows: 

 FCC, within the next 10 years, should free up a contiguous nationwide 

band for use exclusively or predominantly by unlicensed devices. 

 FCC should move expeditiously to complete new rules permitting 

unlicensed use of the unused spectrum between television channels, 

referred to as television “white spaces.” 

 FCC should spur further development and deployment of 

opportunistic uses (i.e., dynamic spectrum access) across more radio 

spectrum. 

 FCC should initiate proceedings to enhance research and 

development (R&D) that will advance the science of spectrum access. 

Stakeholders and experts responding to our survey expressed varying 

levels of support for these recommendations (see table 6). In the table, 

we sometimes separately report different subgroups of stakeholders to 

illustrate meaningful differences in their responses. 

Responding Experts and 

Stakeholders Had Mixed 

Views on Expanding 

Opportunities for 

Innovative Spectrum 

Access Models 

Recommendations in Plan 
 

Page 32 GAO-12-118 Commercial Spectrum 

Table 6: Expert and Stakeholder Respondents’ Agreement with National Broadband 

Plan Recommendations Aimed at Expanding Opportunities for Innovative Spectrum 

Access Models 

Recommendation in plan 

Type of respondent Agreed

Neither 

agreed nor 

disagreed Disagreed Total

Provide spectrum for unlicensed use 

Expert 8 3 5 16

Broadcaster 3 3 4 10

Wireless device manufacturer 6 1 2 9

Wireless service provider 7 2 10 19

Other stakeholder 5 1 1 7

Total 29 10 22 61

Issue rules on television white spaces 

Expert 11 2 5 18

Stakeholder - broadcaster 1 4 7 12

Stakeholder - nonbroadcaster 22 7 6 35

Total 34 13 18 65

Spur opportunistic uses of spectrum 

Expert 14 2 3 19

Stakeholder 27 9 11 47

Total 41 11 14 66

Enhance R&D on spectrum access 

Expert 16 0 2 18

Stakeholder 32 7 9 48

Total 48 7 11 66

Source: GAO survey. 

Note: The total number of responses for each recommendation varied based on the number of 

respondents that chose to answer the question pertaining to the recommendation. The figures shown 

under “agreed” include respondents that either strongly agreed or somewhat agreed with the 

recommendation, and the responses shown under “disagreed” include respondents that either 

strongly disagreed or somewhat disagreed with the recommendation. Appendix III includes figures for 

the more detailed response categories, as well for each type of stakeholder. 

More experts, wireless device manufacturers, and stakeholders in our 

“other” category agreed than disagreed that FCC should free up a 

nationwide band for the exclusive or predominant use of unlicensed 

devices, while more broadcasters and wireless service providers 

disagreed than agreed. Experts and stakeholders expressed a variety of 

views about unlicensed uses. For example, an expert commented that 

future demand for rich wireless media cannot be satisfied by licensed 
 

Page 33 GAO-12-118 Commercial Spectrum 

spectrum alone but will require more unlicensed spectrum to provide 

many more wireless fidelity (Wi-Fi) access points so that wireless traffic 

can be off-loaded to the wired network.46 A wireless service provider said 

that the potential benefit of unlicensed uses is so great that FCC should 

be aiming to set aside a band for such uses within 2 to 3 years rather 

than 10 years. In contrast, a Mobile Satellite Services company 

responded that there is already enough spectrum available for unlicensed 

uses. Similarly, an expert commented that because there are now 

affordable devices that can operate effectively over a range of 

frequencies, FCC should assist the market in using an online database as 

it is doing for television white spaces so that unlicensed devices can 

sense available spectrum and use it dynamically, rather than clearing a 

new band for unlicensed use. 

More responding experts and stakeholders other than broadcasters 

agreed than disagreed that FCC should move expeditiously to complete 

new rules permitting unlicensed use of television white spaces, while 

more broadcasters disagreed than agreed. Experts and stakeholders 

expressed a variety of views on the recommendation. A wireless device 

manufacturer that supported white spaces noted that white spaces are 

primarily available in rural areas where spectrum congestion is less 

common than in densely populated environments like urban areas. But, 

three broadcasters responded that FCC must ensure that its rules protect 

incumbent users from interference.47 Two experts expressed concern that 

 

46Wi-Fi networks—which provide wireless broadband service in so-called “hot spots,” or 

areas within a radius of up to 300 feet—can be found in cafes, hotels, airports, and offices. 

In a Wi-Fi network, a wireless device uses an antenna to transmit data to a router, which 

then sends the information to the Internet using a wired connection. Some licensed 

wireless service providers off-load (or transfer) some of their data traffic from the cellular 

network onto Wi-Fi networks. This benefits users by providing them with much faster 

service while licensed wireless service providers have less congestion and can deliver a 

better overall quality of service. 

47In the past, broadcasters have sought judicial review of FCC’s white spaces order, 

noting that the Commission’s decision to allow unlicensed access to the television 

spectrum would have a direct adverse impact on broadcasters because it would allow 

harmful interference with the reception of the broadcast signals. The Association for 

Maximum Service Television and the National Association of Broadcasters filed a petition 

for review in the U.S. Court of Appeals for the District of Columbia (Case No. 09-1080) on 

February 27, 2009. This case is currently being held in abeyance. FCC has since issued a 

follow-up white spaces order and there are petitions for reconsideration pending on this 

order. Unlicensed Operation in the TV Broadcast Bands, Second Memorandum Opinion 

and Order, 25 FCC Rcd 18661 (2010). 
 

Page 34 GAO-12-118 Commercial Spectrum 

unlicensed use of television white spaces could adversely impact or be in 

tension with an incentive auction of television spectrum. 

Experts and stakeholders generally supported the recommendation on 

opportunistic uses, and they made a variety of comments on the 

recommendation. For example, a wireless service provider supported the 

continued development of dynamic spectrum access but expressed 

strong opposition to FCC’s development of any related rules that would 

diminish the rights of licensees of exclusive spectrum purchased at 

auction to control access to their spectrum. A broadcaster also 

commented that FCC should protect the integrity of existing services; the 

broadcaster disagreed with the recommendation on opportunistic uses 

and stated that FCC should free incumbent licensees from technical 

restrictions that hinder innovation. Similarly, an expert commented that 

instead of implementing this recommendation, FCC should develop rules 

that create incentives for competitive processes to create efficient 

solutions to spectrum shortages. Another expert expressed doubt that 

mass market technology and the demands of the commercial 

marketplace will allow for opportunistic uses within the next decade. 

Experts and stakeholders generally supported the recommendation on 

R&D. For example, a wireless service provider commented that, in 

implementing this recommendation, FCC should leverage work that is 

currently being done in private industry and in academia. Two other 

wireless service providers reported that rather than trying to foster R&D 

directly, FCC should instead focus on ensuring a highly competitive 

marketplace for wireless services because competition spurs innovation 

by market participants. A Mobile Satellite Services company responded 

that spectrum shortages are already providing incentive for licensees to 

spend their funds on R&D for ways to use spectrum more intensively. An 

expert also noted that there is no need for FCC to enhance already 

substantial ongoing R&D efforts by the private sector. 

To implement the recommendations aimed at expanding opportunities for 

innovative spectrum access models, FCC has taken or plans to take the 

following steps: 

 Unlicensed spectrum. FCC intends to consider making additional 

spectrum available for unlicensed use in conjunction with NTIA’s plan 

to make available 500 MHz of spectrum for wireless broadband, which 

addresses both licensed and unlicensed uses. 

Implementation of 

Recommendations 
 

Page 35 GAO-12-118 Commercial Spectrum 

 White spaces. FCC eliminated the requirement that white spaces 

devices include technology to sense what spectrum is available, and 

substituted requirements for geo-location technology and the ability to 

access databases of available spectrum.48 FCC also conditionally 

designated and began working with nine companies to develop and 

administer the databases.

 Opportunistic uses of spectrum. FCC requested public comment on 

how dynamic spectrum access radios and techniques can promote 

more intensive and efficient use of the radio spectrum.49

 R&D. FCC issued a proposed rule that would expand the agency’s 

existing Experimental Radio Service rules to promote cutting-edge 

research and foster development of new wireless technologies, 

devices, and applications.50 Specifically, FCC proposed a new type of 

license, called a “program license,” which would give qualified entities 

broad authority to conduct research without having to seek new 

approval for each individual experiment. 

Among those that agreed with a recommendation aimed at expanding 

opportunities for innovative spectrum access models, generally more 

experts and more stakeholders were satisfied than were dissatisfied with 

FCC’s progress on implementing the recommendation (see table 7). 

 

48Unlicensed Operation in the TV Broadcast Bands, Second Memorandum Opinion and 

Order, 25 FCC Rcd 18661 (2010). 

49Promoting More Efficient Use of Spectrum Through Dynamic Spectrum Use 

Technologies, Notice of Inquiry, 25 FCC Rcd 16632 (2010). 

50Promoting Expanded Opportunities for Radio Experimentation and Market Trials under 

Part 5 of the Commission’s Rules and Streamlining Other Related Rules; 2006 Biennial 

Review of Telecommunications Regulations—Part 2 Administered by the Office Of 

Engineering and Technology (OET), Notice of Proposed Rulemaking, 25 FCC Rcd 16544 

(2010). 
 

Page 36 GAO-12-118 Commercial Spectrum 

Table 7: Expert and Stakeholder Respondents’ Satisfaction with FCC’s Progress on 

National Broadband Plan Recommendations Aimed at Expanding Opportunities for 

Innovative Spectrum Access Models 

Recommendation in plan 

Type of respondent Satisfied

Neither 

satisfied nor 

dissatisfied Dissatisfied Total

Provide spectrum for unlicensed use 

Expert 5 2 1 8

Stakeholder 9 2 9 20

Total 14 4 10 28

Issue rules on television white spaces 

Expert 7 2 2 11

Stakeholder 10 7 6 23

Total 14 4 10 34

Spur opportunistic uses of spectrum 

Expert 6 3 3 12

Stakeholder 7 14 5 26

Total 14 4 10 38

Enhance R&D on spectrum access 

Expert 10 3 2 15

Stakeholder 12 9 5 26

Total 22 12 7 41

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation. The total number of responses for each recommendation varied based on the 

number of respondents that chose to answer the question pertaining to the recommendation. The 

figures shown under “satisfied” include respondents that were either very satisfied or somewhat 

satisfied with FCC’s progress, and the responses shown under “dissatisfied” include respondents that 

were either strongly dissatisfied or somewhat dissatisfied with FCC’s progress. Appendix III includes 

figures for the more detailed response categories, as well for each type of stakeholder. 

More experts were satisfied than dissatisfied with FCC’s progress on the 

unlicensed spectrum recommendation, while stakeholders were evenly 

split. An infrastructure provider said that television white spaces has been 

the focus of FCC’s efforts related to unlicensed use; the provider was 

concerned that the white spaces will not support devices that work in 

other countries because other countries use different spectrum bands 

than the United States for television. A public interest group commented 

that FCC has not made meaningful progress in this area, and that given 

the success of unlicensed spectrum in dramatically increasing the public’s 

access to the public airwaves, unlicensed spectrum—rather than 

spectrum auctions to corporations—should be FCC’s priority. 
 

Page 37 GAO-12-118 Commercial Spectrum 

While more experts and stakeholders were satisfied than dissatisfied with 

FCC’s progress on the white spaces recommendation, experts and 

stakeholders expressed a variety of concerns about FCC’s 

implementation. For example, an expert said FCC’s approach is too 

complicated. A device manufacturer was troubled by FCC’s decision to 

remove the requirement that white spaces devices have sensing 

technology that could scan the spectrum for available frequencies, which 

the manufacturer said had been deemed essential for sharing spectrum. 

A public interest group responded that FCC was moving too slowly. 

More experts and stakeholders were satisfied than dissatisfied with FCC’s 

progress on the opportunistic uses recommendation, but they expressed 

some concerns about FCC’s implementation. For example, an 

infrastructure provider commented that FCC has been too slow to resolve 

interference issues in the 5 GHz band, which FCC has allowed for use by 

devices capable of dynamically accessing spectrum. A wireless device 

manufacturer was dissatisfied that FCC, rather proposing rules to 

facilitate the use of smart radios, had instead taken the more preliminary 

step of requesting public comments on how opportunistic uses can 

promote more intensive and efficient use of the radio spectrum. The 

manufacturer was also dissatisfied that the plan and the notice of inquiry 

showed a preference for geo-location database approaches to dynamic 

access over sensing approaches. 

More experts and stakeholders were satisfied than dissatisfied with FCC’s 

progress on the R&D recommendation, and they expressed a variety of 

views about FCC’s implementation. For example, a wireless device 

manufacturer described FCC’s proposed rule as a good step forward. 

Other stakeholders expressed concerns about the proposed rule. For 

example, a private user noted that FCC’s proposal to expand the 

Commission’s Experimental Radio Service rules should be strengthened 

to ensure that licensees are aware of experimental operations that may 

cause harmful interference to them, and that FCC should more strictly 

enforce against such interference. 

For examples of survey participants’ comments on FCC’s implementation 

of the recommendation on opportunistic uses of spectrum, see appendix 

III. 
 

Page 38 GAO-12-118 Commercial Spectrum 

In the Omnibus Budget Reconciliation Act of 1993, Congress provided 

FCC authority to use auctions to assign certain spectrum licenses. From 

1994 through June 30 2011, FCC conducted 79 auctions that have raised 

nearly $52 billion for the U.S. Treasury. In 2005, we reported that FCC’s 

use of auctions to assign spectrum appeared to have had little to no 

negative impact on end-user prices, infrastructure deployment, and 

competition, but that evidence on how auctions impacted the entry and 

participation of small businesses was less clear.51 We also reported that 

FCC’s implementation of auctions had mitigated problems associated 

with comparative hearings and lotteries, which FCC previously used to 

assign licenses. In particular, auctions were quicker, less costly, and 

more transparent; were more effective in assigning licenses to entities 

that valued them the most; and were an effective mechanism for the 

public to realize a portion of the value of a national resource used for 

commercial purposes. We recommended that Congress consider 

extending FCC’s auction authority beyond the then current expiration date 

of September 30, 2007. Subsequent to our report, FCC’s auction 

authority was extended twice, first until September 30, 2011, and then 

until September 30, 2012.52 Further, subsequent to our report through 

June 30, 2011, FCC successfully completed 20 auctions, which raised 

over $37 billion for the U.S. Treasury. 

Experts and stakeholders responding to our survey, by large margins, 

supported extending FCC’s authority to assign mutually exclusive 

licenses by auction beyond the September 30, 2012, expiration date. In 

particular, 53 of 65 experts and stakeholders supported extending FCC’s 

auction authority (see table 8). Experts and stakeholders made a variety 

of comments related to extending FCC’s auction authority. For example, a 

wireless service provider commented that auctions are by far the most 

efficient way to assign spectrum. 

 

51GAO, Telecommunications: Strong Support for Extending FCC’s Auction Authority 

Exists, but Little Agreement on Other Options to Improve Efficient Use of Spectrum, 

GAO-06-236 (Washington, D.C.: Dec. 20, 2005). 

52Deficit Reduction Act, Pub. L. No. 109-171, § 3003, 120 Stat. 4, 22 (2006); DTV Delay 

Act, Pub. L. No. 111-4, § 5, 123 Stat. 112, 114 (2009). 

Responding Experts 

and Stakeholders 

Strongly Supported 

Extending FCC’s 

Auction Authority but 

Varied in Their 

Opinions on Potential 

Changes to Auctions 
 

Page 39 GAO-12-118 Commercial Spectrum 

Table 8: Expert and Stakeholder Respondents’ Agreement with Extending FCC’s 

Auction Authority 

Type of respondent Agreed

Neither agree 

nor disagreed Disagreed Total

Expert 17 1 1 19

Stakeholder 36 3 7 46

Total 53 4 8 65

Source: GAO survey. 

Note: The figures shown under “agreed” include respondents that either strongly agreed or somewhat 

agreed with extending FCC’s auction authority, and the responses shown under “disagreed” include 

respondents that either strongly disagreed or somewhat disagreed with extending FCC’s auction 

authority. 

Experts and stakeholders responding to our survey expressed varying 

levels of support for five potential changes to FCC’s auction policies that 

we asked about (see table 9). In particular, we asked experts and 

stakeholders about whether FCC should provide a clear schedule for future 

auctions, allow all-or-nothing bids on multiple licenses (known as 

“combinatorial auctions”), reduce the geographic areas covered by 

licenses, modify bidding credits that provide financial benefits to certain 

auction participants, and implement royalties as the means though which 

auction winners compensate the government instead of up-front payments. 

Table 9: Expert and Stakeholder Respondents’ Agreement with Potential Changes 

to FCC’s Auction Policies 

Potential change 

Type of respondent Agreed 

Neither 

agreed nor 

disagreed Disagreed Total

Provide a clear road map detailing future auctions 

Expert 12 3 4 19

Stakeholder 37 2 6 45

Total 49 5 10 64

Allow all-or-nothing package bids on multiple licensesa 

Expert 14 1 2 17

Stakeholder 18 10 10 38

Total 32 11 12 55

Reduce the size of geographic areas covered by licensesb 

Expert 6 5 6 17

Stakeholder 23 7 11 41

Total 29 12 17 58
 

Page 40 GAO-12-118 Commercial Spectrum 

Potential change 

Type of respondent Agreed 

Neither 

agreed nor 

disagreed Disagreed Total

Modify bidding creditsc 

Expert 5 5 9 19

Stakeholder 20 8 8 36

Total 25 13 17 55

Require winners to pay royaltiesd 

Expert 9 2 7 18

Stakeholder 15 7 17 39

Total 24 9 24 57

Source: GAO survey. 

Note: The total number of responses for each potential change varied based on the number of 

respondents that chose to answer the question pertaining to the potential change. The figures shown 

under “agreed” include respondents that either strongly agreed or somewhat agreed with the potential 

change, and the responses shown under “disagreed” include respondents that either strongly 

disagreed or somewhat disagreed with the potential change. 

a

An auction with all-or-nothing bids on combinations of multiple items is known as a “combinatorial 

auction.” According to FCC, this approach allows bidders to better express the value of any benefits 

from combining complementary licenses and to avoid the risk of winning only part of a desired set of 

licenses. 

b

FCC auctions licenses in a variety of designated geographic regions, including relatively small 

multicounty areas (Cellular Market Areas) and large multistate regions (Regional Economic Areas). 

c

Bidding credits are a percentage discount applied to the high bid amount for a license if the bidder 

meets specific designated entity criteria—designed to make spectrum available to new entrants—

established in the auction rules. 

d

With a royalty mechanism, a company would pay the government a percentage of revenue on an 

ongoing basis, rather than pay the government a one-time fee to obtain a spectrum license. 

Among the potential changes we asked survey participants about, 

reducing uncertainty about future spectrum auctions received the most 

support. Currently, FCC provides information on scheduled auctions and 

identifies auctions not yet scheduled. Most experts and stakeholders 

agreed that FCC should reduce uncertainty by providing a clear road map 

for future auctions, including their timing and size, so that potential 

bidders can develop effective strategies. However, experts and 

stakeholders that did not agree with the recommendation cited several 

concerns. For example, a broadcaster was concerned that by providing a 

road map, FCC would limit its flexibility to respond to changing 

technological solutions and spectrum demand, and an expert was 

concerned that if spectrum beyond that included in the road map were to 

become available, the road map could be used by incumbents to protest 

the release of the additional spectrum, harming consumers. 
 

Page 41 GAO-12-118 Commercial Spectrum 

Most responding experts agreed, and more stakeholders agreed than 

disagreed, that FCC should allow all-or-nothing package bids on multiple 

licenses in an auction (referred to as “combinatorial auctions”) as 

opposed to requiring bids on individual licenses. According to FCC, this 

approach allows bidders to better express the value of any benefits from 

combining complementary licenses and to avoid the risk of winning only 

part of a desired set of licenses. However, a broadcaster and a wireless 

service provider commented that package bidding would unfairly favor 

large companies that can afford such approaches. 

An equal number of responding experts agreed and disagreed, and more 

stakeholders agreed than disagreed, that FCC should reduce the size of 

geographic areas covered by licenses to promote the participation of 

small companies. In 2010, we reported that, according to some small 

wireless carriers and stakeholders, the size of spectrum blocks has had 

the effect of pricing small and regional carriers out of auctions, making it 

difficult for these carriers to enter into new markets or expand their 

services.53 However, an expert and a Mobile Satellite Services company 

expressed concern that if FCC were to implement this recommendation, 

small companies that get spectrum would sooner or later cash out and 

sell to larger carriers, which the service provider said would add to 

licensees’ costs without actually fostering competition. However, a 

wireless device manufacturer said that FCC could avoid this problem by 

requiring any entity that acquires spectrum and sells it without a network 

to pay a tax to the U.S. Treasury. Another expert responded that 

implementation would result in the fragmentation of spectrum and 

complex secondary market transactions aimed at recombining the 

spectrum into larger geographic bundles.

More experts disagreed than agreed, while more stakeholders agreed 

than disagreed, that FCC should modify bidding credits designed to 

promote the participation of small companies. Bidding credits are a 

percentage discount applied to the high bid amount for a license if the 

bidder meets specific designated entity criteria—designed to make 

spectrum available to new entrants—established in the auction rules. 

Several experts and stakeholders expressed concerns about FCC’s 

experience with bidding credits. For example, an expert commented that, 

 

53GAO, Telecommunications: Enhanced Data Collection Could Help FCC Better Monitor 

Competition in the Wireless Industry, GAO-10-779 (Washington, D.C.: July 27, 2010). 
 

Page 42 GAO-12-118 Commercial Spectrum 

rather than promoting efficiency, bidding credits provide windfalls to the 

owners of small companies who can use the credits to buy spectrum and 

then turn around and sell it for a profit at market rates to larger firms. In 

2010, we reported that some stakeholders said that, in the past, large 

national carriers have used entities eligible for the credits as proxies, 

allowing eligible entities to win certain licenses and then acquiring the 

desired licenses from them later; a wireless service provider responding 

to our survey expressed a similar concern.54 A device manufacturer cited 

a case in which the Department of Justice, on behalf of FCC, settled with 

a Wall Street money manager for $130 million to resolve allegations of 

such abuse. A wireless service provider commented that the credits do 

not work as intended, and an expert and a device manufacturer felt that 

FCC should stop using them altogether. 

Requiring winners of auctions to pay royalties based on the amount of 

revenues the winners earn by using the spectrum rather than requiring 

them to pay the full amounts of the winning bids up front garnered the 

least support. Both experts and stakeholders were nearly evenly divided 

on this potential change and expressed several concerns about royalties. 

For example, a public interest group commented that royalties based on a 

share of revenues would have the undesirable effect of imposing risk on 

the government. Similarly, a wireless service provider commented that 

royalties would have to be paired with penalties for nonuse of spectrum in 

order to be effective, or else licensees—particularly large incumbents—

would have an incentive to buy and not use spectrum to avoid the royalty 

or to limit competition by smaller competitors and new entrants. Another 

wireless service provider commented that royalties would create 

disincentives for licensees to build out quickly, and that it would be 

difficult for FCC to determine appropriate royalty amounts because of the 

difficulty of parsing out a licensee’s revenue from various spectrum 

bands, some of which would be covered by a royalty fee and some of 

which would not. 

 

54GAO-10-779. 
 

Page 43 GAO-12-118 Commercial Spectrum 

As commercial enterprises increasingly utilize spectrum to provide 

consumer services, FCC’s ongoing implementation of the spectrumrelated recommendations of the 2010 National Broadband Plan is of great 

importance. Most of the plan’s recommendations enjoyed fairly broad 

support from experts and stakeholders responding to our survey, 

although some recommendations were strongly opposed by some 

experts or certain types of stakeholders. For example, the plan’s 

recommendation for incentive auctions, which could speed the lengthy 

repurposing process, received mixed responses from expert and 

stakeholder respondents. In some instances, these conflicting opinions 

arise from participants’ divergent positions in the communications 

industry; for example, incumbent licensees, such as broadcasters, are 

likely to oppose recommendations that they believe could impose 

burdens or costs on their businesses. In addition, experts’ and 

stakeholders’ satisfaction with FCC’s implementation of the 

recommendations to date tended to be more tempered than their support 

for the recommendations themselves. Perhaps most challenging, experts 

and stakeholders expressed a range of views—sometimes conflicting—

on how Congress and FCC should proceed. In this respect, little has 

changed since 2003, when we reported that “it does not appear likely that 

timely reforms can be agreed upon amid the diversity of views held by 

stakeholders.”55 One potential step that did achieve broad agreement 

among experts and stakeholders responding to our survey was extending 

FCC’s auction authority beyond the current expiration date of September 

30, 2012. We previously found that spectrum auctions are very effective 

for assigning licenses for commercial entities.56 We also previously found 

that as implemented by FCC, spectrum auctions resolve problems 

associated with previous assignment mechanisms, while giving rise to 

little or no problems. Since we issued our last report on auctions in 

December 2005 through June 30, 2011, FCC has successfully completed 

an additional 20 auctions, which raised over $33 billion for the U.S. 

Treasury. 

 

55GAO-03-277. 

56GAO-06-236. 

Conclusions 
 

Page 44 GAO-12-118 Commercial Spectrum 

Given the continued success of FCC’s use of auctions, and the 

overwhelming support among experts and stakeholders for extending 

FCC’s auction authority, Congress should consider extending FCC’s 

auction authority beyond the current expiration date of September 30, 

2012. 

We provided a draft of this report to FCC for its review and comment. 

FCC provided technical comments that we incorporated as appropriate. 

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 appropriate 

congressional committees, the Chairman of the Federal Communications 

Commission, and other interested parties. In addition, the report will be 

available at no charge on GAO’s 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 

Matter for 

Congressional 

Consideration 

Agency Comments 
Appendix I: Scope and Methodology 

Page 45 GAO-12-118 Commercial Spectrum 

This report addresses the Federal Communications Commission’s (FCC) 

management of commercial spectrum, including (1) the extent to which 

FCC has made spectrum available for new commercial uses since it 

implemented auction authority in 1994, and the time taken to do so; (2) 

experts’ and stakeholders’ views on FCC’s plans and recent actions to 

meet future spectrum needs; and (3) experts’ and stakeholders’ views on 

the continued use of auctions to assign spectrum. In addition, we 

examined the extent to which FCC seeks to ensure the quality of its data 

on commercial spectrum licenses (see app. II). 

To address all research questions, we conducted a web-based survey of 

experts and industry stakeholders. We selected a nonprobability sample 

of 30 experts and 79 industry stakeholders; we selected the experts and 

stakeholders based on their expertise in spectrum policy, as represented 

by presentations or publications, or on their organization’s vested interest 

in spectrum policy. Within the industry stakeholder group, we surveyed 20 

representatives of the broadcast industry, 15 representatives of the 

wireless device manufacturing industry, 26 representatives of the wireless 

service provider industry, and 18 other industry stakeholders, including 

satellite, spectrum management, infrastructure, private user, and public 

interest groups. 

We developed and administered the web-based survey through a secure 

server. We provided participants with unique passwords and usernames 

and subsequently notified participants on May 25, 2011, when the 

questionnaire was available. We sent follow-up e-mail messages to those 

who had not responded, and subsequently contacted all remaining 

nonrespondents by telephone. The questionnaire was available online 

until June 28, 2011. We received completed responses from 20 experts 

and 54 industry stakeholders, representing a 68 percent response rate. 

Because we selected a nonprobability sample of experts and industry 

stakeholders, the information we obtained from the survey may not be 

generalized to all experts and industry stakeholders who have an interest 

in spectrum policy. 

The practical difficulties of conducting any survey may introduce errors, 

commonly referred to as nonsampling errors. For example, difficulties in 

interpreting a particular question, sources of information available to 

respondents, or entering data into a database or analyzing them can 

introduce unwanted variability into the survey results. We took steps in 

developing the questionnaire, collecting the data, and analyzing them to 

minimize such nonsampling error. For example, social science survey 

specialists designed the questionnaire in collaboration with GAO staff 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 46 GAO-12-118 Commercial Spectrum 

who had subject matter expertise. Then, we pretested the draft 

questionnaire with four experts and industry stakeholders; we also 

reviewed the survey with FCC staff. We conducted these pretests and 

reviews to ensure that (1) the questions were clear and unambiguous, (2) 

terminology was used correctly, (3) the questionnaire did not place an 

undue burden on respondents, (4) the information could be feasibly 

obtained, and (5) the survey was comprehensive and unbiased. On the 

basis of the feedback from the pretests and reviews we conducted, we 

made changes to the content and format of the survey questions. When 

we analyzed the data, an independent analyst checked all computer 

programs. Since this was a web-based survey, respondents entered their 

answers directly into the electronic questionnaire, eliminating the need to 

key data into a database, minimizing error. 

In addition to the survey, to address all research questions we conducted 

semistructured interviews with a variety of industry stakeholders, experts, 

and officials with government agencies; for industry stakeholders, we 

interviewed both associations and individual companies. We interviewed 

the following types of organizations and individuals: government agencies 

(FCC and the Congressional Research Service), wireless service 

providers, wireless device manufacturers, a wireless telecommunications 

infrastructure company, broadcasters, Mobile Satellite Services 

companies, a spectrum data manager, academics, public interest 

organizations, and consultants. 

To examine the extent to which FCC seeks to ensure the quality of its 

data on commercial spectrum licenses, we reviewed the following FCC 

spectrum-related databases: Universal Licensing System, Consolidated 

Database System, International Bureau Filing System, Experimental 

Licensing System, and Equipment Authorization System. To review these 

databases, we interviewed FCC officials responsible for maintaining the 

systems about FCC’s processes for ensuring the quality of the data, and 

we compared FCC’s processes with GAO guidance on internal controls 

and information technology. We also interviewed industry stakeholders 

who use these databases, as well as the Spectrum Dashboard and 

License View systems that pull data from these systems, and included 

questions in our survey of experts and stakeholders pertaining to the 

usefulness, accuracy and completeness, and user-friendliness of FCC’s 

systems. We also reviewed prior FCC audits of records in the Universal 

Licensing System. 

To examine the extent to which FCC has made spectrum available for 

new commercial uses, we reviewed six instances where FCC repurposed 
Appendix I: Scope and Methodology 

Page 47 GAO-12-118 Commercial Spectrum 

spectrum from an existing use to a new use. The six repurposings we 

reviewed involved substantial amounts of spectrum that were repurposed 

to a higher value use. In particular, these repurposings met the following 

criteria: (1) the amount of spectrum repurposed was 5 megahertz (MHz) 

or more; (2) the repurposing yielded $100 million or more in auction or 

industry revenue; and (3) reassignment occurred in 1994, when FCC first 

implemented its auction authority, or later. For these repurposings, we 

reviewed FCC’s notices, orders, and auctions; comments filed in the 

proceedings by industry participants; and relevant court decisions. We 

also included a question in our survey of experts and stakeholders 

pertaining to the amount of time it takes from when FCC or Congress 

designates a spectrum band for reallocation until the band is available for 

a new use. 

To examine FCC’s plans and recent actions to meet future spectrum 

needs, we reviewed the National Broadband Plan and notices of inquiry, 

reports and orders, and other publications related to FCC’s development 

or implementation of the plan’s chapter on spectrum. We reviewed 

comments filed in various FCC proceedings from industry stakeholders 

on FCC’s development of the plan and FCC’s steps to implement the 

plan. We reviewed publications and presentations from academic and 

industry consultants and other experts. We included questions in our 

survey of experts and stakeholders pertaining to the recommendations in 

the plan’s chapter on spectrum and FCC’s steps to implement those 

recommendations. We asked survey participants for their opinion on each 

recommendation and where appropriate, FCC’s steps to implement the 

recommendation; we excluded three recommendations that were 

addressed in our questions about FCC’s data quality, fell under the 

purview of the National Telecommunications and Information 

Administration (NTIA), or pertained to a narrow population.1

To examine FCC’s continued use of auctions to assign spectrum, we 

reviewed prior GAO reports that addressed FCC’s use of auctions to 

assign spectrum licenses. We reviewed publications and presentations 

 

1

These recommendations are (1) Recommendation 5.1: The FCC should launch and 

continue to improve a spectrum dashboard; (2) Recommendation 5.5: Congress should 

consider building upon the success of the Commercial Spectrum Enhancement Act to 

fund additional approaches to facilitate incumbent relocation; and (3) Recommendation 

5.17: The FCC should take into account the unique spectrum needs of U.S. Tribal 

communities when implementing the recommendations in this chapter. 
Appendix I: Scope and Methodology 

Page 48 GAO-12-118 Commercial Spectrum 

from academic and other experts. Finally, we included questions in our 

survey of experts and stakeholders pertaining to spectrum auctions. In 

particular, we asked survey participants for their opinion on whether 

Congress should extend FCC’s auction authority and on five potential 

changes to FCC’s implementation of auctions. 

We conducted this performance audit from August 2010 to November 

2011 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 49 GAO-12-118 Commercial Spectrum 

In this appendix, we provide information on FCC’s spectrum-related data 

systems. Specifically, we discuss (1) FCC’s data systems for spectrumrelated records, (2) experts’ and stakeholders’ views about attributes of 

FCC’s data systems, (3) FCC’s quality-control process for its data, and 

(4) FCC’s efforts to improve its spectrum-related data. 

We examined seven of FCC’s spectrum-related data systems, of which 

six are related to spectrum licenses, and one is concerned with radio 

equipment authorizations (see table 10).1

 Four of the six spectrum 

license-related systems allow (1) entities to apply for a license, (2) 

existing licensees to apply for a license renewal or to update their license 

information, and (3) the public to search for information on licenses; these 

systems are the Universal Licensing System for wireless 

telecommunications licenses, the Consolidated Database System for 

broadcasting licenses, the International Bureau Filing System for satellite 

licenses, and the Experimental Licensing System for experimental use 

licenses. According to FCC officials, the Universal Licensing System is by 

far the largest system with the most licenses, and is therefore the system 

that the public is most likely to interact with. FCC recently implemented 

the other two systems related to spectrum licenses—Spectrum 

Dashboard and License View—to provide the public with more userfriendly tools, such as enhanced mapping capabilities, for searching for 

information on spectrum licenses. These two systems pull data on 

licenses from FCC’s spectrum licensing systems; they do not allow 

entities to file applications for licenses or update information on their 

licenses. The Equipment Authorization System allows entities to file 

applications for authorizations of radio equipment, such as cell phones, 

and the public to search for information on these authorizations. FCC 

uses these various systems for multiple purposes, including processing 

applications for spectrum licenses or radio equipment authorizations and 

helping to determine where spectrum is available. 

 

1

We did not examine FCC’s Cable Operations and Licensing System (COALS), which 

pertains to cable operators and multichannel video programming distributors. According to 

FCC staff, COALS does include some spectrum-related information. 

Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

FCC Has Several Data 

Systems for SpectrumRelated Records 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 50 GAO-12-118 Commercial Spectrum 

Table 10: Description of FCC Data Systems 

Authorities 

covered Capabilities 

System 

Spectrum 

licenses 

Radio 

equipment 

authorizations 

Services, frequencies, or 

equipment covered 

File 

applications 

for licenses or 

authorizations 

Search for 

information 

on licenses or 

authorizations

Map 

information 

for 

individual 

or groups 

of licenses

Universal 

Licensing System 

 Wireless communications 

services, including cellular 

telephone, paging, personal 

communications services, and 

other commercial and private radio 

services 

  

Consolidated 

Database System 

 Broadcast television and radio   

International 

Bureau Filing 

System 

 Satellites and satellite earth 

stations 

  

Experimental 

Licensing System 

 Experimental uses   

Equipment 

Authorization 

System 

 Radio equipment in all spectrum 

bands 

  

Spectrum 

Dashboard 

 Frequencies generally deemed 

appropriate for mobile broadband, 

including those allocated to 

wireless communications services, 

broadcast television, and satellite 

 

License View  All services covered by the 

Universal Licensing System, the 

Consolidated Database System, 

the International Bureau Filing 

System, the Experimental 

Licensing System, and FCC’s 

cable licensing system 

 

Source: GAO analysis of FCC information. 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 51 GAO-12-118 Commercial Spectrum 

Most users of FCC’s spectrum-related data systems responding to our 

survey reported that the systems generally provide the type of information 

they are looking for to either a great or moderate extent (see table 11). In 

particular, for each of the seven systems, large majorities of survey 

respondents expressed a favorable opinion on the availability of 

information. However, respondents’ opinions varied somewhat across the 

systems. For example, a large majority of respondents reported a positive 

evaluation of the Universal Licensing System; 54 of 58 respondents said 

that the Universal Licensing System provides the type of information they 

were looking for to a great or moderate extent. Spectrum Dashboard, a 

system that pulls data from FCC’s spectrum licensing systems, had a 

somewhat lower level of support; 33 of 48 respondents reported that 

Spectrum Dashboard provides the type of information they were looking 

for to a great or moderate extent. 

Table 11: Summary of Survey Responses of Extent to Which FCC Data System 

Provides Desired Type of Information 

Extent to which system provides desired 

types of information 

System Great Moderate Little None Total

Universal Licensing System 31 23 2 2 58

Consolidated Database System 14 15 3 3 35

International Bureau Filing 

System 

13 10 6 2 31

Experimental Licensing System 11 13 4 3 31

Equipment Authorization System 9 10 6 3 28

Spectrum Dashboard 16 17 11 4 48

License View 10 15 8 2 35

Source: GAO survey. 

Note: The total number of responses for each system varied based on the number of respondents 

that chose to answer the question pertaining to the system. 

Stakeholders Expressed 

Mixed Views about 

Attributes of FCC’s Data 

Systems 

Availability of Information 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 52 GAO-12-118 Commercial Spectrum 

According to some users of FCC’s spectrum-related data systems that 

responded to our survey, inaccurate and missing data hindered their use 

of the systems to a great to moderate extent (see tables 12 and 13).2

Respondents reported such problems most often with the Universal 

Licensing System. In particular, 19 of 54 respondents and 23 of 55 

respondents reported that inaccurate information and missing information, 

respectively, in the Universal Licensing System hindered their use to a 

great or moderate extent. Dissatisfaction with inaccurate data rose to a 

similar level only for the Consolidated Database System; 10 of 29 

respondents reported that inaccurate data in the Consolidated Database 

System hindered their use to a great or moderate extent. In addition to 

the Universal Licensing System, respondents reported the most 

difficulties arising from missing information with the Consolidated 

Database System and the International Bureau Filing System. In 

particular, almost one-third of respondents reported that missing data in 

the Consolidated Database System and the International Bureau Filing 

System hindered their use to a great or moderate extent. 

Table 12: Summary of Survey Responses for Inaccurate Data 

Extent to which use is hindered by inaccurate data

System Great Moderate Little None Total

Universal Licensing System 10 9 14 21 54

Consolidated Database System 4 6 11 8 29

International Bureau Filing 

System 

4 2 12 9 27

Experimental Licensing System 4 0 16 6 26

Equipment Authorization System 3 0 16 5 24

Source: GAO survey. 

Note: The total number of responses for each system varied based on the number of respondents 

that chose to answer the question pertaining to the system. 

 

2

Since Spectrum Dashboard and License View pull data from other systems, such as the 

Universal Licensing System and the Consolidated Database System, we are not reporting 

survey results about inaccurate and missing data in these systems. FCC officials 

acknowledge that the quality of data in Spectrum Dashboard and License View is only as 

good as the quality of data in their underlying systems, including the Universal Licensing 

System and the Consolidated Database System. 

Accuracy and Completeness of 

Information 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 53 GAO-12-118 Commercial Spectrum 

Table 13: Summary of Survey Responses for Missing Data 

Extent to which use is hindered by missing data 

System Great Moderate Little None Total

Universal Licensing System 12 11 18 14 55

Consolidated Database System 3 7 16 6 32

International Bureau Filing 

System 

2 7 10 9 28

Experimental Licensing System 2 5 13 8 28

Equipment Authorization System 2 4 11 7 24

Source: GAO survey. 

Note: The total number of responses for each system varied based on the number of respondents 

that chose to answer the question pertaining to the system. 

For some users, FCC’s primary spectrum-related data systems can prove 

challenging to use. In the National Broadband Plan, FCC noted that the 

complexity of its data on licensing of spectrum and the lack of 

transparency and usability of data created impediments to public policy 

and restricted the development of new technologies, such as dynamic 

spectrum access, that could utilize spectrum data. Several stakeholders 

told us that systems, such as the Universal Licensing System, are 

relatively user-friendly for “expert” users with technical knowledge and 

experience, but that the systems could pose challenges for other users. 

Consistent with this view, half or more of respondents reported that the 

International Bureau Filing System and the Experimental Licensing 

System were not too or not at all user-friendly, and about one-third of 

respondents reported similar views of the Universal Licensing System 

and the Consolidated Database System (see table 14). 

User-Friendliness of Systems 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 54 GAO-12-118 Commercial Spectrum 

Table 14: Summary of Survey Responses for User-Friendliness 

Level of user-friendliness 

System Very Somewhat Not too Not at all Total

Universal Licensing 

System 

7 27 13 9 56

Consolidated Database 

System 

7 14 7 3 31

International Bureau Filing 

System 

1 9 9 9 28

Experimental Licensing 

System 

4 10 9 5 28

Equipment Authorization 

System 

3 7 9 6 25

Spectrum Dashboard 16 19 2 5 42

License View 8 9 6 6 29

Source: GAO survey. 

Note: The total number of responses for each system varied based on the number of respondents 

that chose to answer the question pertaining to the system. 

To respond to these concerns; to help ensure greater transparency in 

spectrum allocation, assignment, and use; and to help promote 

secondary market transactions; FCC developed the Spectrum Dashboard 

and License View systems. As discussed earlier, these systems pull and 

compile data from the primary spectrum-related data systems, such as 

the Universal Licensing System and the Consolidated Database System, 

and are designed to present the information in a meaningful, easy-to-use 

format to the public. In designing these systems, FCC sought a means 

whereby its data could be leveraged by citizens for greater purposes, and 

both Commission staff and external parties are better positioned to 

identify data inaccuracies or inconsistencies. As shown in table 14, over 

four-fifths of respondents reported that Spectrum Dashboard was very or 

somewhat user-friendly, thereby meeting FCC’s intent of the system while 

more than half of respondents reported that License View was very or 

somewhat user-friendly. 

FCC has commissionwide programs, policies, and procedures for the 

collection and management of information, which help ensure FCC’s 

compliance with governmentwide laws and regulations pertaining to 

information collection and management. For example, FCC’s records 

management program is intended partly to control the quantity and quality 

of records produced by the Commission. In 2010, we reviewed and 

FCC Has Processes Aimed 

at Ensuring the Quality of 

Its Data; However, Past 

Audits Identified Some 

Problems 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 55 GAO-12-118 Commercial Spectrum 

reported on 30 information collection systems used by FCC, including 

those associated with the Experimental Licensing System and the 

Equipment Authorization System data systems.3

 We found that FCC 

followed relevant policies and procedures, including those pertaining to 

quality control. For this report, we examined the processes in place to 

ensure the quality of data in FCC’s five spectrum license and 

authorization systems. We identified several quality-control features 

incorporated in the five systems, which we discuss below and illustrate in 

table 15. 

Table 15: Summary of FCC’s Data Quality Procedures for Spectrum-Related Data Systems 

Data quality control procedures 

System 

Edit checks: 

during online 

filing 

Edit checks: 

during batch 

processing 

FCC staff 

review 

Notify filer of 

errors after 

review 

Track e-mail 

and phone 

queries 

Universal Licensing System Yes Yes Yes Yes Yes 

Consolidated Database System Yes Yes Yes Yes Yes 

International Bureau Filing System Yes No Yes Yes No 

Experimental Licensing System Yes No Yes Yes No 

Equipment Authorization System Yes No Yes Yes Yes 

Source: GAO analysis of FCC data. 

Note: Since Spectrum Dashboard and License View pull data from other systems, such as the 

Universal Licensing System and the Consolidated Database System, we did not review the processes 

in place for these systems. 

 Edit checks. FCC’s spectrum-related licensing and authorization 

systems each incorporate edit checks, which check for missing or 

anomalous data elements; these edit checks occur either online 

during the filing process or in batch mode. All five systems incorporate 

online edit checks, which check the accuracy of data entered by filers 

in real time and flag potential errors for users. FCC officials said that 

these online checks are helpful to filers and help ensure data 

accuracy. In addition, the Universal Licensing System, the 

Consolidated Database System, and the International Bureau Filing 

System incorporate edit checks in the nightly batch processing of data 

submitted by users. Among other things, the edit checks address 

 

3

GAO, Telecommunications: Information Collection and Management at the Federal 

Communications Commission, GAO-10-249 (Washington, D.C.: Jan. 29, 2010). 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 56 GAO-12-118 Commercial Spectrum 

acceptable ranges of values, filings from parties with delinquent debts, 

and accuracy of geographic coordinates. 

 FCC staff review. Before granting a spectrum license or equipment 

authorization, FCC checks all information provided by the applicant or 

licensee using automated or staff reviews. For example, FCC staff 

scrutinizes all spectrum license renewal applications that require 

exhibits demonstrating compliance with license requirements. FCC 

staff seeks correction or clarification of any inaccuracies detected in 

the information. According to FCC officials, these ongoing staff 

reviews of applications supplement the automated edit checks. In 

addition to its own reviews, FCC accepts reports of data 

discrepancies from members of the public. 

 Filer notification. According to FCC officials, the Commission in part 

depends on the applicants for licenses to submit accurate data. FCC 

believes this is appropriate because entities filing applications are in 

the best position to know the relevant facts and are often experts and, 

therefore, the data these entities submit should be of high quality. 

Furthermore, FCC officials noted that when entities submit 

applications or renewals, they must certify and affirm the accuracy of 

the data. When FCC staff discovers errors, the Commission alerts the 

original filer and solicits correction. 

 Tracking systems. FCC maintains a help desk, with access via 

telephone and e-mail. Applicants, licensees, and the general public 

may use these resources to obtain help with FCC’s data systems. In 

addition, the Universal Licensing System, the Consolidated Database 

System, and the Equipment Authorization System incorporate 

systems that track e-mail and phone queries and thus help FCC to 

identify problems with the data systems. 

While these quality-control features can help promote the quality of FCC’s 

spectrum-related data, past Commission audits have uncovered some 

problems with the timeliness of FCC’s data. FCC periodically reviews its 

systems and data and, from 2001 through 2005, FCC audited licensees in 

three spectrum bands. FCC conducted these audits because of concerns 

that some licensees for certain types of services included in the Universal 

Licensing System were not keeping FCC informed of their operating 

status. These audits were aimed at determining, for each license, whether 

the licensed service was operational, and canceling the licenses in cases 

where service had been discontinued. The audits resulted in the 

cancellation of the following licenses: 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 57 GAO-12-118 Commercial Spectrum 

 220 MHz licenses: 94 licenses cancelled out of 956 licenses audited 

(10 percent cancelled) 

 Paging licenses: 2,076 licenses cancelled out of 7,770 licenses 

audited (27 percent cancelled) 

 Private land mobile radio licenses: 37,448 licenses cancelled out of 

420,112 licenses audited (9 percent cancelled)4

As these audit results illustrate, FCC’s spectrum-related systems may not 

incorporate the timeliest information. FCC acknowledged that the extent 

to which its data match real world conditions depends upon the particular 

rules governing filers and the burden of filing upon industry. For example, 

since a broadcaster must renew its license once every 8 years, the data 

on file, as of the most recent renewal, may not remain accurate over time. 

Although FCC also requires that filers update information about significant 

events as needed, FCC has no practical way to ensure that filers comply 

with that requirement. FCC officials said that the Commission could take 

measures, such as requiring more frequent updates and certification of 

data in its databases, but such measures must be balanced with the 

burden placed upon industry. According to FCC officials, the Commission 

has focused on checking the accuracy of the data submitted to FCC at 

the time of submission, not on maintaining accuracy over time. But FCC 

now recognizes that there is a need to ensure that the data in its systems 

reflect conditions in the real world on an ongoing basis to determine 

where spectrum is available. Regarding the possibility of future audits, 

FCC officials said that the Commission does not currently have concerns 

that would warrant additional audits of license holders but, that if such 

concerns were to arise, it would consider conducting additional audits. 

 

4

The private land mobile radio service covers two-way land mobile communications by 

individuals, organized groups, businesses, and state and local government agencies. 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 58 GAO-12-118 Commercial Spectrum 

Recognizing the need to improve the Commission’s information practices, 

in July 2009, the FCC Chairman initiated a review of FCC’s systems and 

processes for information collection, processing, analysis, and 

dissemination, and this effort continued with the June 2010 launch of the 

Data Innovation Initiative.5

 According to FCC staff, the Commission has 

been working to improve its data collection, analysis, and dissemination 

practices in order to reduce the reporting burden on outside parties and 

ensure that the agency has timely, complete, and accurate data on which 

to base its activities and decisions. As part of this effort, FCC has sought 

to streamline the processes by which parties supply information, thereby 

minimizing work and potential errors. Furthermore, FCC is developing 

data quality analytics to measure its data quality. This effort will assess 

the accuracy of FCC’s data from an input perspective (the quality of 

information submitted by filers) and from a system perspective (the 

maintenance of accurate information in FCC’s databases, including the 

extent to which the data reflect conditions in the real world). 

Alongside the Data Innovation Initiative, FCC created a Chief Data Officer 

for the Commission and Chief Data Officers inside each Bureau and 

Office. The Commission’s Chief Data Officer is responsible for improving 

how the Commission collects, uses, and disseminates data, among other 

things, and oversees the Data Innovation Initiative. The Wireless 

Telecommunication Bureau’s Chief Data Officer reports directly to the 

Bureau Chief and, according to FCC officials, has been closely engaged 

in spectrum-related data analysis, including the identification of spectrum 

needs. 

In 2009, FCC began an effort to consolidate its numerous, bureau-based, 

and separately managed licensing systems into a single system known as 

the Consolidated Licensing System (CLS). According to FCC staff, as 

currently envisioned, CLS would provide the public with a single portal for 

access to all FCC licensing systems and would have user-friendly 

 

5

See FCC, FCC Launches Data Innovation Initiative, press release (June 29, 2010), 

available at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-299269A1.pdf. 

FCC Has Several Efforts 

Under way with the 

Potential to Improve Its 

Spectrum-Related Data 

Data Innovation Initiative 

Chief Data Officers 

Consolidation of Databases 
Appendix II: Federal Communications 

Commission’s Spectrum-Related Data 

Systems 

Page 59 GAO-12-118 Commercial Spectrum 

features. In addition, CLS would incorporate enhanced edit check 

capability, including for example, validation of geographic coordinates for 

antennas to ensure that the coordinates coincide with the locations of the 

antennas. FCC staff said that CLS would include information from its 

legacy databases, such as the Universal Licensing System, and that cost 

considerations may affect how much legacy information the new system 

includes; however, FCC believes that the information for the current 

filings and the previous filings should be sufficient to meet FCC’s needs 

for spectrum management. Because of the complexity and size of this 

effort, FCC expects to deploy CLS in phases over a period of years. 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 60 GAO-12-118 Commercial Spectrum 

This appendix presents the views of experts and industry stakeholders on 

the spectrum-related recommendations in the National Broadband Plan 

and FCC’s steps to implement those recommendations.1

 We surveyed 30 

experts and 79 industry stakeholders, and 20 of the experts and 54 of the 

stakeholders responded to our survey, representing a 68 percent 

response rate (see app. I for additional information on our survey 

methodology). For each recommendation from the National Broadband 

Plan covered by our survey, we provide the following: 

 the text of the recommendation; 

 a summary of the rationale for the recommendation presented in the 

National Broadband Plan; 

 data on experts’ and stakeholders’ level of agreement with the 

recommendation; 

 excerpts from experts’ and stakeholders’ comments on the 

recommendation;2

 a description of FCC’s progress on implementing the recommendation 

through May 2011; 

 data on experts’ and stakeholders’ level of satisfaction with FCC’s 

progress on implementing the recommendation through May 2011 (for 

those recommendations directed at FCC); and 

 excerpts from experts’ and stakeholders’ comments on FCC’s 

progress on implementing the recommendation. 

 

1

We excluded three recommendations that were addressed in our questions about FCC’s 

data quality, fell under the purview of NTIA, or pertained to a narrow population. 

2

All excerpts of experts’ and stakeholders’ comments included in this appendix are 

verbatim reproductions of the comments provided in response to our survey, except for 

corrections of spelling and grammatical errors. Any other clarifications we made to 

comments are shown in brackets or in table notes. We selected comments in order to 

present a range of views, while aiming to minimize repetition of views within a category of 

stakeholders. 

Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and Recent 

Actions to Meet Future Spectrum Needs 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 61 GAO-12-118 Commercial Spectrum 

FCC should make 500 MHz newly available for broadband use within the 

next 10 years, of which 300 MHz between 225 MHz and 3.7 GHz should 

be made newly available for mobile use within 5 years. 

FCC believes that additional spectrum should be made available to help 

meet anticipated increases in demand for wireless broadband services. 

The targets were based on an FCC staff forecast of spectrum demand. 

 Stakeholders 

Level of 

agreement Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 10 0 4 15 5 34

Somewhat 

agree 

6 0 2 2 0 10

Neither agree 

nor disagree 

0 2 1 1 2 6

Somewhat 

disagree 

1 1 1 1 1 5

Strongly 

disagree 

2 7 1 2 0 12

Total 19 10 9 21 8 67

Source: GAO survey. 

National Broadband 

Plan 

Recommendations 

Aimed at Making 

More Spectrum 

Available for Wireless 

Broadband Use by 

2015 

Make 300 MHz of 

Spectrum Available by 

2015 and 500 MHz by 2020 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 62 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (strongly agree) I believe that this approach will align with market demands. 

Expert (somewhat 

agree) 

I strongly agree with the direction of change (more licensed 

spectrum), and the amounts are not trivial - but ‘still more’ is 

the correct answer. 

Expert (somewhat 

disagree) 

If the need for data is increasing by 25x (only the next five 

years, I would expect it to continue to increase if the report of 

the increase is accurate) then how is a 2x improvement in 

spectrum going to fix the problem. Cellular works because of 

spectral reuse, not because of spectrum. 

Expert (strongly 

disagree) 

(1) This is an unrealistic objective for many reasons including 

the fact that there are no mechanisms in place that have even 

a remote chance of success. (2) This is a dangerous objective 

since its promise will result in a false sense of complacency 

that will keep the FCC and NTIA from stimulating the REAL 

solution to the broadband spectrum problem - stimulation of 

technologies that can multiply spectrum capacity rather than 

just add increments and (3) even if the objective succeeds, the 

problem will not be solved. 

Expert (strongly 

disagree) 

This...plays into the pocket books of the big incumbents. 

Broadband is not in the desert southwest or Appalachia 

because it is not now and never will be financially workable. 

...Instead, the FCC should require incumbent reporting of 

fallow spectrum so the FCC can identify chunks of [spectrum] 

to be licensed to small enterprises whose primary business is 

not telecommunications (such as trucking companies, 

agriculture, tourism) so that they can use programmable 

wireless devices to bring broadband to niche markets in a way 

that promotes entrepreneurism in those markets, such as the 

desert southwest and Appalachia. 

Broadcaster (strongly 

disagree) 

Need for more spectrum is a result of wireless provider’s OWN 

CHOICE on not reducing cell size; cheaper to buy more 

spectrum. 

Broadcaster (strongly 

disagree) 

The FCC has not provided a sufficient justification for its 

spectrum reallocation goals, and the amount of spectrum 

sought is an arbitrary number. Such demand-based projections 

should be technology agnostic, identifying the most efficient 

spectrum allocations to satisfy the marketplace. The efficiency 

of broadcasting’s ‘one-to-many’ approach is an important 

factor in managing the so-called ‘spectrum crisis.’ 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 63 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (strongly 

disagree) 

This plan does not adequately take into account that (1) over 

2/3 of the spectrum currently held for mobile broadband has 

not yet been deployed, (2) femto/pico cell and wifi offloading 

can have a substantial role, (3) that 66% of mobile broadband 

traffic will be video, and MDTV broadcasting should be used to 

deliver that high-volume data. The approach of simply shifting 

spectrum in this manner only serves to consolidate more 

spectrum in the hands of fewer gatekeepers, rather than 

creating more bandwidth for users by understanding the usage 

patterns and applying the proper technology/spectrum 

combination. Spectrum is not a panacea and this approach will 

ultimately create a recurring scenario of “spectrum crisis” every 

few years with the inevitable calls for more spectrum. 

Wireless device 

manufacturer (strongly 

agree) 

It is well-documented that mobile broadband use is increasing 

dramatically and will outstrip the supply of available bandwidth 

in the near future. 

Wireless service 

provider (strongly 

agree) 

Additional spectrum that is made available for auction must 

come with an assurance of device interoperability across each 

band of spectrum auctioned. Without this assurance via 

license requirement or other mechanism, future spectrum will 

be subject to the same sort of balkanization into proprietary 

bandclasses by carriers large enough to influence or control 

the specifications of devices or network equipment, as has 

been the case in the 700 MHz spectrum. 

Wireless service 

provider (somewhat 

disagree) 

Although additional spectrum is needed, this [recommendation] 

appears biased towards mobile broadband while 

underestimating the spectrum needed for fixed wireless 

broadband [by] up to 48 million citizens with no broadband 

option [in their] homes today... 

Wireless service 

provider (strongly 

disagree) 

This spectrum will be hoarded by the large carriers and further 

squeeze the small rural carriers out of the market. This will 

further eliminate competition in the wireless industry. 

Source: GAO survey. 

Our survey asked respondents how satisfied they were overall with FCC’s 

progress on this recommendation, which had five subrecommendations. 

However, rather than providing an overall description of FCC’s progress, 

our survey referred respondents to the descriptions of FCC’s progress 

contained within the survey’s questions on the subrecommendations. 

Those descriptions are shown in this appendix under the other 

recommendations in this section of the appendix. 

FCC’s Progress on 

Implementing the 

Recommendation 

through May 2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 64 GAO-12-118 Commercial Spectrum 

 Stakeholders 

Level of 

satisfaction Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 1 - 0 1 0 2

Somewhat 

satisfied 

6 - 2 5 1 14

Neither satisfied 

nor dissatisfied 

2 - 2 4 2 10

Somewhat 

dissatisfied 

4 - 2 3 0 9

Strongly 

dissatisfied 

2 - 0 3 1 6

Total 15 - 6 16 4 41

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. Since no broadcasters strongly agreed or 

somewhat agreed with the recommendation, no figures are shown for broadcasters. 

Type of commenter 

(level of 

satisfaction) Comment excerpts 

Expert (somewhat 

satisfied) 

[FCC] should have auctioned [the] D block already, but [FCC] is 

working hard on MSS. 

Expert (neither 

satisfied nor 

dissatisfied) 

The Congress is in the leadership role on the auctions [that are 

needed to implement several of the components of this 

recommendation]. 

Expert (somewhat 

dissatisfied) 

... progress in this area is very difficult and complex. FCC has 

been under extreme resource challenges. Would like process to 

move faster, but recognize that this may not be reasonable. ... 

Expert (strongly 

dissatisfied) 

... FCC is falling well behind other international markets in its 

efforts to avail spectrum resources for the US to attain a 

leadership position in mobile and fixed broadband. 

Infrastructure provider 

(somewhat satisfied) 

... FCC is working well with NTIA to free up other spectrum for 

traditional auction. 

Wireless device 

manufacturer 

(somewhat satisfied) 

The Commission established an aggressive timetable for 

implementation, not anticipating the political environment and 

Congressional limbo on incentive auction authority. 

Wireless service 

provider (somewhat 

satisfied) 

[FCC will not meet its 5-year target] if steps are not taken soon 

to accelerate the reallocation of suitable federal spectrum for 

commercial provider use, to repurpose significant amounts of TV 

broadcast and MSS spectrum for terrestrial broadband use 

under incentive auctions, and to auction the 700 MHz D Block or 

otherwise provide for public/private commercial mobile uses of 

excess capacity on [this] spectrum. 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 65 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of 

satisfaction) Comment excerpts 

Wireless service 

provider (somewhat 

satisfied) 

The FCC has issued an item seeking comment on NTIAidentified bands—a good initial step. 

Source: GAO survey. 

FCC should initiate a rulemaking proceeding to reallocate 120 MHz from 

the broadcast television bands. 

FCC believes that spectrum currently allocated for over-the-air television 

broadcasting would have much higher economic value if it were allocated 

for wireless broadband. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly 

agree 

12 0 4 15 3 34

Somewhat 

agree 

2 0 3 0 2 7

Neither agree 

nor disagree 

1 0 0 2 2 5

Somewhat 

disagree 

2 0 1 0 0 3

Strongly 

disagree 

1 11 1 3 1 17

Total 18 11 9 20 8 66

Source: GAO survey. 

Reallocate Portion of 

Television Spectrum 

(120 MHz) 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 66 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (strongly agree) Perhaps the single most important step the government can 

take to improve US wireless broadband is to let the FCC 

auction off broadcast TV spectrum. It is beyond argument that 

broadcasters do not need everything they have and that the 

national interest—jobs, public discourse, economic growth, 

improved health care service—is with expanding wireless 

broadband. 

Expert (strongly agree) TV has been the blatant abuser of spectrum so this is righting 

a wrong. 

Expert (strongly agree) [FCC] should also have considered reallocation with leasing 

rights. 

Expert (somewhat 

agree) 

Reallocating the TV band spectrum toward more market-based 

approach is important. 

Expert (strongly 

disagree) 

The FCC could solve this problem immediately by: (1) dezoning broadcast spectrum and allowing other uses and 

expanding secondary markets; (2) reorganizing remaining 

broadcast licensees in each market into more compact bands 

and reclaiming broadcast spectrum that is not licensed. 

Broadcaster (strongly 

disagree) 

More US citizens use and rely on the broadcast spectrum than 

any other spectrum category being considered. Broadcasters 

are also deploying MDTV with this spectrum. This deployment 

will play a significant role in mobile broadband content delivery 

and should be encouraged to flourish as it is the most efficient 

way of distributing video, which Cisco says will account for 

66% of all mobile traffic in 2015. 

Broadcaster (strongly 

disagree) 

The solution to moving underutilized broadcast spectrum to 

mobile carriers is to lift the FCC rules that prevent 

broadcasters from selling or leasing such spectrum to mobile 

carriers in a private market transaction. Applying the FCC’s 

secondary markets policy to broadcast spectrum would enable 

the parties to clear the spectrum where needed, on a voluntary 

basis, without government involvement. If a checkerboard of 

spectrum is freed up (that is, non-adjacent channels), the FCC 

could streamline its channel-change and channel-swap 

procedures for the new mobile licensees just like the FCC did 

about 10 years ago to clear the 700 MHz band of 

broadcasters. By the way, it is not entirely clear that mobile 

operators really need two adjacent 6 MHz channels. Qualcom 

has a new chip that uses just one 6 MHz channel for two-way 

mobile data, and Sprint has argued that adjacent channels are 

not necessary for 4G systems. 

Broadcaster (strongly 

disagree) 

The proposal to reallocate 120 MHz of spectrum from the TV 

band is likely to have a significant impact on the public’s 

access to free over the air television. Any reallocation must be 

based on fair data and after a full evaluation of spectrum use 

and public need. 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 67 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (strongly 

disagree) 

The digital transition has just been completed. Disruption of 

the spectrum based on speculative need is inappropriate. As is 

the FCC concluding that broadcast spectrum is “less valuable” 

based on a wireless per pop analysis. Broadcast spectrum 

serves a different function and should not be valued using the 

same metrics as another service. ... 

Broadcaster (strongly 

disagree) 

This recommendation should not be implemented absent 

compelling data, and absent a full and complete spectrum 

inventory that also analyzes current utilization. Action, if at all, 

should be predicated on demonstrated need rather than on bare 

assertions of a “looming spectrum crisis,” and after full 

investigation of whether less disruptive alternatives to reallocation 

of broadcast spectrum could address demonstrated needs. This 

proposal, if implemented, will impose real and substantial costs on 

broadcasters and will have a significant negative impact on the 

public’s access to free over-the-air television. 

Wireless device 

manufacturer (strongly 

disagree) 

The incumbents say they need this right away when they don’t 

use 50-90% of what they already control at all, let alone efficiently. 

The FCC approved white space and then decided to do incentive 

auction. This is crazy policy. Make the carriers show how much 

they use and how efficiently before you do anything. 

Wireless service 

provider (strongly 

disagree) 

Allocating 120 MHz to mobile broadband completely 

eviscerates the needs of fixed wireless broadband. At least 42 

MHz of unlicensed TV band spectrum must be preserved to 

allow fixed wireless broadband providers to provide broadband 

for citizens who have NO AVAILABLE TERRESTRIAL 

BROADBAND options today. 

Public interest group 

(strongly disagree) 

This process will directly undermine dynamic spectrum access 

technologies (e.g., television white space devices), killing one of 

the most innovative new spectrum utilization ideas we’ve seen in 

a generation. Instead, the FCC will continue using much the 

same remarkably inefficient system of spectrum licensure that 

has lead to current artificial scarcities and inefficiencies. Bribing 

license holders to vacate from bands is a horrible idea. 

Source: GAO survey. 

 In June 2010 FCC issued a technical paper providing more detail than 

the National Broadband Plan on how reallocating a portion of the 

television bands might work. It presented an analysis of bandwidth 

requirements of various video streams, data to support the assertion 

that two television stations could voluntarily share a single six-MHz 

channel and continue to broadcast their primary video streams in high 

FCC’s Progress on 

Implementing the 

Recommendation through May 

2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 68 GAO-12-118 Commercial Spectrum 

definition, and an initial look at the television allotment optimization 

model being developed by the FCC.3

 In June 2010, FCC held a “Broadcast Engineering Forum” with 

broadcast industry engineers and technical experts in related fields 

regarding future rulemakings on reallocating spectrum from the 

broadcast television bands, including rule-makings regarding service 

areas, distance separations, and channel-sharing. 

 In November 2010, FCC issued a Notice of Proposed Rulemaking 

(NPRM) to establish a regulatory framework to facilitate wireless 

broadband uses of the UHF and VHF television bands, while 

maintaining current license assignments in the band.4

 In March and April 2011, FCC held a series of web-based seminars 

with state broadcasting associations to describe how FCC thinks an 

incentive auction might work and give broadcasters a chance to ask 

questions. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 3 - 3 2 1 9

Somewhat 

satisfied 

5 - 1 7 2 15

Neither satisfied 

nor dissatisfied 

2 - 1 4 1 8

Somewhat 

dissatisfied 

2 - 2 1 1 6

Strongly 

dissatisfied 

2 - 0 0 0 2

Total 14 - 7 14 5 40

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. Since no broadcasters strongly agreed or 

somewhat agreed with the recommendation, no figures are shown for broadcasters. 

 

3

FCC, Spectrum Analysis: Options for Broadcast Spectrum, Omnibus Broadband Initiative 

Technical Paper No. 3 (June 2010). 

4

Innovation in the Broadcast Television Bands: Allocations, Channel Sharing, and 

Improvements to VHF, Notice of Proposed Rulemaking, 25 FCC Rcd 16498 (2010). 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 69 GAO-12-118 Commercial Spectrum 

Type of commenter (level of 

satisfaction) Comment excerpts 

Expert (very satisfied) Good example of how to do it right. 

Expert (strongly dissatisfied) My dissatisfaction is with Congress, not the FCC. This 

should move faster and the broadcasters should stop 

trying to derail this process. 

Expert (strongly dissatisfied) Congress is the big problem here. 

Wireless device manufacturer 

(very satisfied) 

We believe that the FCC is doing everything in its power 

to move along the 120 MHz reallocation, but believe that 

FCC progress will only continue if Congress lets the 

FCC do its job. 

Wireless device manufacturer 

(very satisfied) 

... it is very important that the Congress empowers the 

FCC with the ability to implement voluntary incentive 

auctions, as this is the mechanism that will provide the 

opportunity to ensure this valuable spectrum is put to its 

most highly valued uses. 

Wireless device manufacturer 

(somewhat dissatisfied) 

Unfortunately the need for incentive auction authority 

lays at the hands of congress. 

Wireless service provider 

(somewhat satisfied) 

The prospect of the FCC holding auctions to license as 

much as 120 MHz of repurposed TV Broadcast 

spectrum in the 2012-2013 timeframe as originally 

proposed in the FCC’s NBP is increasingly problematic. 

Legislation authorizing incentive auction authority has 

been proposed but passage is uncertain. In addition, 

numerous requirements have been proposed to be 

included in such legislation which, if adopted, would 

substantially reduce the amount of repurposed spectrum 

available for auction. 

Source: GAO survey. 

FCC should accelerate terrestrial deployment in 90 MHz of Mobile 

Satellite Services spectrum. 

To address what FCC now believes are overly-burdensome requirements 

that it set for Mobile Satellite Services operators before they could deploy 

terrestrial networks to enhance coverage in areas where their satellite 

signal is weakened or unavailable, the plan recommends accelerating 

terrestrial deployment by providing sufficient flexibility to licensees to 

increase terrestrial broadband use of Mobile Satellite Services spectrum, 

Expert and Stakeholder 

Comments on FCC’s Progress 

Accelerate Terrestrial 

Deployment in Mobile 

Satellite Services 

Spectrum (90 MHz) 

Recommendation 

Rationale 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 70 GAO-12-118 Commercial Spectrum 

while preserving market-wide capability to provide unique mission-critical 

Mobile Satellite Services. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 9 0 5 8 4 26

Somewhat 

agree 

3 1 1 4 0 9

Neither agree 

nor disagree 

2 6 2 4 1 15

Somewhat 

disagree 

1 2 0 2 1 6

Strongly 

disagree 

1 0 0 1 1 3

Total 16 9 8 19 7 59

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (strongly agree) FCC is doing everything it can to move MSS spectrum into 

terrestrial wireless market. [The provisional waiver that FCC 

granted to] LightSquared is unexpectedly complicated due to 

GPS interference, but FCC definitely seems to be on the right 

track with the 40 MHz of S Band spectrum. 

Expert (strongly agree) Having spectrum set aside for satellite use is potentially a very 

inefficient use of spectrum and unlocking the value of that 

spectrum could be very beneficial. 

Expert (somewhat 

disagree) 

The business case and public interest is not clear; [FCC] 

should identify and develop more alternatives. 

Broadcaster (somewhat 

disagree) 

Making terrestrial allocations in this band has increased 

interference to uses adjacent to that band (e.g., ENG facilities 

in 2Ghz band); interference criteria should be strengthened 

and strictly adhered to. 

Wireless device 

manufacturer (strongly 

agree) 

[The best approach would be to u]se ... incentive auctions in 

this band to allow deployment of terrestrial mobile broadband 

systems. 

Wireless service 

provider (strongly 

agree) 

[We strongly agree with this recommendation s]o long as no 

harmful interference occurs to wireless carriers and public 

safety from LightSquared operations. 

Wireless service 

provider (strongly 

agree) 

Good spectrum, cleared and ready to use. But FCC can do 

little as this spectrum is trapped in bankruptcy proceedings. It 

will be very difficult for FCC to change the rules for ultimate 

new licensees after they pay value in bankruptcy. 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 71 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Wireless service 

provider (somewhat 

disagree) 

Interference concerns regarding locating a terrestrial band next 

to a space-based band were well-founded. Testing has already 

proved substantial interference will occur with GPS systems. 

Other MSS spectrum may not share these same problems (i.e. 

not near GPS L1), but the FCC needs to move cautiously. 

Public interest group 

(strongly agree) 

There are certainly complexities with this approach, but it is 

worthwhile - this is valuable, useful spectrum. 

Mobile Satellite 

Services company 

(neither agree nor 

disagree) 

[Our level of agreement with the recommendation] would be 

very different depending on whether the recommendation was 

interpreted to mean accelerate removal of MSS players to 

allow for terrestrial deployment, or simply accelerate ongoing 

progress to manage both satellite and terrestrial deployment in 

the bands. 

Private user group 

(somewhat disagree) 

Terrestrial deployment in MSS bands raises significant 

technical issues that require careful study and should not be 

rushed. 

Source: GAO survey. 

 In July 2010, FCC issued an NPRM to add co-primary Fixed and 

Mobile allocations to the 2 gigahertz (GHz) band, consistent with the 

International Table of Allocations. This allocation modification is a 

precondition for more flexible licensing of terrestrial services within the 

band. FCC also proposed to apply its secondary market policies and 

rules applicable to terrestrial services to all transactions involving the 

use of Mobile Satellite Services bands for terrestrial services in order 

to create greater predictability and regulatory parity with bands 

licensed for terrestrial mobile broadband service. 

 In July 2010, FCC requested comment in a notice of inquiry on further 

steps it could take to increase the value, utilization, innovation, and 

investment in Mobile Satellite Services spectrum generally. 

 In January 2011, FCC granted a waiver to LightSquared allowing it to 

expand its terrestrial use of its satellite spectrum, conditional on, 

among other things, addressing concerns regarding interference with 

Global Positioning System devices to FCC’s satisfaction. 

 In April 2011, FCC issued a Report and Order adopting the proposals 

in its July 2010 NPRM. 

FCC’s Progress on 

Implementing the 

Recommendation 

through May 2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 72 GAO-12-118 Commercial Spectrum 

 In May 2011, FCC solicited input on approaches to maximize 

terrestrial mobile broadband use of 2 GHz range spectrum that is 

allocated for fixed and mobile use.5

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 3 - 2 2 2 9

Somewhat 

satisfied 

4 - 2 6 1 13

Neither satisfied 

nor dissatisfied 

2 - 0 1 0 3

Somewhat 

dissatisfied 

3 - 2 2 0 7

Strongly 

dissatisfied 

0 - 0 1 1 2

Total 12 - 6 12 4 34

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. Since no broadcasters strongly agreed or 

somewhat agreed with the recommendation, no figures are shown for broadcasters. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Expert (somewhat 

dissatisfied) 

I have some concerns regarding interference with existing 

spectrum used for other systems such as GPS. 

Infrastructure provider 

(very satisfied) 

The LightSquared GPS interference issues aside, this is an 

important block of spectrum that would be better utilized for 

terrestrial networks, provided the interference issue with GPS 

can be managed. 

Source: GAO survey. 

 

5

FCC issued this solicitation on May 20, 2011, after we finalized the questionnaire for our 

survey. 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 73 GAO-12-118 Commercial Spectrum 

FCC should make up to 60 megahertz available by auctioning Advanced 

Wireless Services (AWS) bands, including, if possible, 20 megahertz from 

federal allocations. 

The plan noted that FCC has already allocated spectrum for AWS, and 

called for FCC to expeditiously resolve the future of this spectrum. 

Level of 

agreement 

 Stakeholders 

Experts

Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 12 2 8 11 3 36

Somewhat agree 4 2 1 3 3 13

Neither agree 

nor disagree 

1 4 1 2 1 9

Somewhat 

disagree 

0 1 0 1 0 2

Strongly 

disagree 

1 0 0 3 0 4

Total 18 9 10 20 7 64

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (strongly agree) Congress should learn from the unexpectedly slow AWS 

transition from government to commercial use and just 

compensate government agencies for transition costs to 

accelerate the repurposing. 

Expert (strongly 

disagree) 

These changes will cost $B in DoD and DHS which is not 

resourced to address the changes. 

Wireless device 

manufacturer (strongly 

agree) 

To the greatest extent possible, the allocations also should be 

globally harmonized to promote economies of scale, which will 

drive benefits to network operators and ultimately consumers 

in the form of lower priced equipment and devices. 

Wireless device 

manufacturer 

(somewhat agree) 

H block will create interference concerns to existing PCS band. 

J block downlink should be aggregated with AWS-3 and paired 

with Federal spectrum bands 1755-1780 MHz to expand the 

existing AWS-1 band. 

Auction Advanced 

Wireless Services 

Spectrum (60 MHz) 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 74 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Wireless service 

provider (strongly 

agree) 

Had FCC moved quickly on this—or on D Block auction—TMobile would not have agreed to be acquired by AT&T 

because it would have better spectrum opportunities. So ... 

there is a direct line between [this] FCC failure to act quickly ... 

and likely creation of a wireless/wireless duopoly that cannot 

easily be undone. 

Wireless service 

provider (strongly 

agree) 

NTIA should reallocate 25 MHz of spectrum (1755-1780 MHz) 

to pair with AWS-3 and Upper AWS-2 J Block. 

Wireless service 

provider (strongly 

agree) 

We support the pairing of 25 MHz of Federal spectrum 

including 1755-1780 MHz with 2155-2180 MHz (combining the 

AWS-3 band with upper J Block spectrum). We also support 

the reallocation of additional Federal spectrum, 1695-1710 

MHz, to be paired with unspecified Federal or possibly nonFederal spectrum. 

Wireless service 

provider (somewhat 

disagree) 

Until rules are in place that facilitate efficient and complete use 

of currently licensed spectrum (e.g., device interoperability 

requirements across all blocks of paired spectrum in each 

band), there is not an urgent need for more to be auctioned. 

Moreover, without the assurance of such things as device 

interoperability, small operators and new entrants are unlikely 

to participate in future auctions—reducing the number of 

bidders and, therefore, reducing auction revenues. 

Wireless service 

provider (strongly 

disagree) 

Interoperability needs to be resolved first on current spectrum. 

The device ecosystem is of paramount importance to carrier 

buildouts and lack of interoperability has many carriers on 

hold. We need to effectively use current spectrum first. This 

also needs to be part of any and all future auctions or it will 

limit interest to only the Tier 1 carriers. 

Source: GAO survey. 

 In July 2010, FCC requested comment in a Notice of Inquiry on 

whether the opportunity to integrate the AWS-2 J Block and 2 GHz of 

Mobile Satellite Spectrum would help attract new investment and 

utilization. 

 FCC consulted with NTIA on the 10-year “Plan and Timetable to Make 

Available 500 Megahertz of Spectrum for Wireless Broadband” and 

the “Assessment of the Near-Term Viability of Accommodating 

Wireless Broadband Systems in the 1675-1710 MHz, 1755-1780 

MHz, 3500-3650 MHz, and 4200-4220 MHz, 4380-4400 MHz Bands” 

(also referred to as the “Fast Track Evaluation”), both of which NTIA 

issued in November 2010. 

 FCC officials told us that the Commission intends to take further steps 

to implement this recommendation, in consultation with NTIA as 

FCC’s Progress on 

Implementing the 

Recommendation through May 

2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 75 GAO-12-118 Commercial Spectrum 

appropriate, after NTIA completes its assessment of the suitability of 

the 1755-1850 MHz band for repurposing. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 1 0 1 0 0 2

Somewhat 

satisfied 

8 0 3 4 2 17

Neither satisfied 

nor dissatisfied 

4 1 2 2 2 11

Somewhat 

dissatisfied 

2 1 3 4 0 10

Strongly 

dissatisfied 

0 1 0 2 1 4

Total 15 3 9 12 5 44

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Expert (very satisfied) 1755 to 1850 MHz is critically important to the commercial 

wireless sector. Steps should be taken as soon as possible to 

begin moving in that direction. 

Expert (somewhat 

satisfied) 

AWS-3 pairing in the hands of executive branch. Makes sense 

to hold off on AWS-2. 

Infrastructure provider 

(somewhat satisfied) 

Kudos to the FCC for pressing ahead. NTIA has known for a 

while how important this spectrum is, and clearly wanted to 

avoid having to move federal users, some of whom would be 

moved for the second time. Without legislative improvements 

in federal relocation process, moving users is difficult. 

Mobile Satellite 

Services company 

(neither satisfied nor 

dissatisfied) 

Significant interference issues and [emissions] into adjacent 

bands must be considered to effectively integrate the AWS-2 J 

block with the 2GHz MSS band. 

Public interest group 

(strongly dissatisfied) 

Nothing meaningful has been implemented. 

Wireless device 

manufacturer (neither 

satisfied nor 

dissatisfied) 

The holdup is NTIA to allow pairing of [the] 1755-1780 [MHz 

band] with FCC’s AWS-3 band. 

Wireless device 

manufacturer 

(somewhat dissatisfied) 

NTIA manages spectrum the same way they did 20 years ago. 

... [T]hey protect the status quo. 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s 

Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 76 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of satisfaction) Comment excerpts 

Wireless service 

provider (somewhat 

satisfied) 

Good progress at discussion level but execution and timing will 

be critical. 

Wireless service 

provider (somewhat 

dissatisfied) 

Need quicker review and reallocation of the 1755-1850 MHz 

band. 

Wireless service 

provider (strongly 

dissatisfied) 

Progress has not been rapid enough to meet the near-term 

needs of regional and local commercial providers for additional 

mobile broadband spectrum. 

Source: GAO survey. 

FCC should make 20 megahertz available for mobile broadband use in 

the 2.3 GHz Wireless Communications Service band, while protecting 

neighboring federal, nonfederal Aeronautical Mobile Telemetry and 

satellite radio operations. 

Since FCC first auctioned Wireless Communications Service spectrum in 

1997, a number of new and robust wireless telecommunications 

technologies have been successfully introduced. Such technologies, 

coupled with the exploding demand for broadband services, suggest that 

the Wireless Communications Service spectrum may provide fertile 

ground for the provision of high-value mobile broadband services to the 

public. In order to realize this potential FCC needs to revise outdated 

rules intended to protect against interference from use of the spectrum. 

Make Wireless 

Communications Services 

Spectrum Available (20 

MHz) 

Recommendation 

Rationale 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 77 GAO-12-118 Commercial Spectrum 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 11 0 4 4 2 21

Somewhat agree 5 1 2 4 2 14

Neither agree 

nor disagree 

1 8 2 8 2 21

Somewhat 

disagree 

1 0 1 2 1 5

Strongly 

disagree 

0 0 1 1 0 2

Total 18 9 10 19 7 63

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (somewhat 

agree) 

[The recommendation] should have been 25-30 Megahertz ... 

rather than just 20 megahertz. 

Expert (somewhat 

disagree) 

The 2.3GHz band offers a lot of potential for mass market 

services. ... the mass market will provide more than enough 

economic incentive to reallocate incumbent systems. 

Wireless device 

manufacturer (strongly 

disagree) 

Aligning this band with global allocation for mobile [broadband] 

was the right thing to do. However, the imposed duty-cycles on 

the technologies to operate in this band negatively impact the 

business case because the rules do not allow the right ratio of 

downlink to uplink when using [time division duplexing]. Also 

there are issues with the stringent [out-of-band emissions] and 

power limits. 

Wireless device 

manufacturer 

(somewhat disagree) 

This spectrum should be made available for mobile broadband, 

and while neighbors should be protected the FCC should not 

go further than absolutely necessary or else risk diminishing 

the value of this 20 megahertz. 

Wireless service 

provider (strongly 

agree) 

At least 25 Megahertz should be made available for mobile 

broadband under technology-neutral rules, and neighboring 

services should be protected to appropriate (but not excessive) 

levels. 

Source: GAO survey. 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 78 GAO-12-118 Commercial Spectrum 

In May 2010, FCC adopted rules that will make available 25 MHz of 

spectrum for mobile broadband service in much of the United States, 

while protecting adjacent satellite radio and aeronautical mobile telemetry 

operations. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 2 0 0 1 1 4

Somewhat 

satisfied 

6 1 3 2 1 13

Neither satisfied 

nor dissatisfied 

3 0 1 0 0 4

Somewhat 

dissatisfied 

2 0 1 5 1 9

Strongly 

dissatisfied 

2 0 0 0 1 3

Total 15 1 5 8 4 33

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Expert (neither satisfied 

nor dissatisfied) 

Processes to accomplish this take a long time and nothing has 

been done to change that. ... the amount of spectrum is 

infinitesimal in the context of the demand. 

Expert (somewhat 

dissatisfied) 

Too slow. 

Expert (strongly 

dissatisfied) 

Spectrum is not available for broadband use because FCC has 

not completed rules or addressed licensing issues. 

Mobile Satellite 

Services company 

(somewhat dissatisfied) 

Absence of consensus by WCS and [satellite digital audio 

radio] licensees negates the effectiveness of FCC decision on 

technical rules. 

Public interest group 

(strongly dissatisfied) 

The FCC has still not implemented anything meaningful. 

Wireless device 

manufacturer (neither 

satisfied nor 

dissatisfied) 

Too early to determine whether rules will result in effective 

deployment of mobile broadband in this spectrum. 

Wireless service 

provider (somewhat 

dissatisfied) 

Petitions for reconsideration filed in this proceeding raise 

questions about whether the band can actually be used to 

provide mobile broadband service. 

FCC’s Progress on 

Implementing the 

Recommendation through 

May 2011 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 79 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of satisfaction) Comment excerpts 

Wireless service 

provider (somewhat 

dissatisfied) 

The FCC could have been more aggressive by placing more of 

the burden on SDARS. 

Wireless service 

provider (somewhat 

dissatisfied) 

While FCC’s May 2010 decision was a useful first step, 

petitions for reconsideration filed by WCS interests illustrate 

material flaws in technical rules and performance requirements 

that jeopardize the prospects for the band actually being used 

for the offering of broadband services to the public. 

Source: GAO survey. 

FCC should auction the 10 MHz Upper 700 MHz D Block for commercial 

use that is technically compatible with public safety broadband services. 

To realize the high potential value that FCC believes the 10 MHz Upper 

700 MHz D Block has for commercial broadband while supporting the 

simultaneous development of public safety broadband capability through 

equipment development, roaming, and priority access. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 13 2 5 6 0 26

Somewhat agree 3 1 1 4 1 10

Neither agree 

nor disagree 

1 5 2 2 2 12

Somewhat 

disagree 

1 1 0 2 1 5

Strongly 

disagree 

0 0 1 6 1 8

Total 18 9 9 20 5 61

Source: GAO survey. 

Auction the Upper 700 

MHz D Block (10 MHz) 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 80 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (somewhat 

disagree) 

The past has proven that auctioning the spectrum for 

public/private use is not workable. If the FCC intends to pursue 

this type of mixed use it needs to adopt rules to incentivize not 

discourage bidding and such mixed use. 

Expert (strongly agree) Long overdue is the approach to make a commercial system 

that can serve emergency needs but that is viable in normal 

times. The FCC should set a low auction minimum for this 

service since it is more risky for the commercial operator but 

the public safety requirement is crucial. 

Expert (somewhat 

disagree) 

Congress has not adequately addressed public safety for the 

past 10 years. FCC is trying to solve on its own, and it does 

not have either the authority or the resources adequately to do 

so. 

Expert (strongly agree) The original premise of the D-Block for the 2008 auction was 

sound. The lack of definition in the interaction with public 

safety entities created uncertainty and thus made the auction 

not viable. Define the rules and interactions explicitly and this 

can work. 

Expert (somewhat 

agree) 

This 10 Megahertz and the public safety aspect are well 

informed and have the potential to support the public interest. 

Watch out for the “Motorola-ization” of this band where 

hardware providers manipulate the 3,000 local government 

entities into spending way too much on hardware. This stuff 

should be available at BestBuy, not from Motorola, Johnson, or 

whoever. That will happen if the usage is liberalized and low 

power (femtocell class) devices are allowed (e.g., per police 

car and fire truck) as well as by homeowners. First responders 

should have a code that allows them to use the bandwidth, 

basically unnoticed by home owners, of the Internet access 

points when there is a police, fire, or rescue operation within 

radio distance of the home. This could be done securely. 

Infrastructure provider 

(neither agree nor 

disagree) 

The FCC doesn’t control this—Congress does and Congress 

needs to decide what to do: whether to combine with public 

safety spectrum. 

Public interest group 

(strongly disagree) 

A single-use national public safety network will simply not 

work. It is impossible to build a network to the level of 

robustness required for anything less than a half-trillion dollars. 

Thus, this entire endeavor is destined for failure and should be 

ceased before we spend additional public funding for 

something that will simply not work. We should concentrate 

instead on building mixed-use communications infrastructure 

with a public safety priority during declared emergencies. 

Wireless device 

manufacturer (strongly 

disagree) 

Give this to public safety at local county level and let them put 

it to use in their own way and their cost and structure. 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 81 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Wireless service 

provider (somewhat 

agree) 

While we believe that the presence of additional commercial 

competitors in the 700MHz spectrum would help to break the 

stranglehold AT&T and Verizon currently have over device and 

equipment development in that spectrum, an auction of the Dblock without an assurance of interoperability would do little to 

benefit the public interest. Device interoperability is necessary 

to bring the benefits of scale to the 700 MHz market: reducing 

the costs of consumer and public safety devices, as well as 

enabling roaming across networks by both consumers and 

public safety. 

Wireless service 

provider (strongly 

agree) 

The right thing to do, but a lost cause. Reallocation to public 

safety is more likely at this point. Our concerns assuming 

reallocation then go to interoperability and fair commercial 

opportunity to be part of partnerships and solutions — rather 

than see the D Block go by default to partnerships with the 

Twin Bells. 

Wireless service 

provider (strongly 

disagree) 

Public safety needs 20 MHz to deploy an efficient LTE 

network. 

Source: GAO survey. 

 In May 2010, FCC issued the results of its analysis indicating that a 

stand-alone public safety network would be substantially more 

expensive than a network constructed under an incentive-based 

partnership approach, under which public safety network operators 

would partner with commercial operators or systems integrators to 

construct and operate the network using the 10 MHz of dedicated 

spectrum currently allocated to public safety. 

 In June 2010, FCC issued a paper concluding that the 10 MHz of 

dedicated spectrum currently allocated to public safety will provide the 

capacity and performance necessary for day-to-day communications 

and serious emergency situations; that dedicating the 10 MHz Upper 

700 MHz D Block for public safety, or even 30 MHz, may not be 

sufficient to support public safety broadband communications in a 

major emergency; and that instead public safety should be given 

priority access and roaming capability across the commercial 

broadband wireless spectrum. FCC said that such access will make at 

least 50 or 60 MHz of additional spectrum immediately available. 

FCC’s Progress on 

Implementing the 

Recommendation through 

May 2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 82 GAO-12-118 Commercial Spectrum 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 2 0 0 1 0 3

Somewhat 

satisfied 

2 0 2 1 0 5

Neither satisfied 

nor dissatisfied 

5 2 0 1 1 9

Somewhat 

dissatisfied 

4 0 1 2 0 7

Strongly 

dissatisfied 

3 1 1 4 0 9

Total 16 3 6 9 1 33

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Expert (somewhat 

dissatisfied) 

The FCC is concluding that the peak use of public safety 

operations may be many orders of magnitude greater than 

normal use. This conclusion indicates that allocations should 

be commensurate with normal use and policy should address 

access for peak use. 

Expert (strongly 

dissatisfied) 

This approach is excellent but practical implementation will 

take much planning, negotiation, and governmental vision. little 

of this has yet to be done. 

Broadcaster (neither 

satisfied nor 

dissatisfied) 

A stand-alone public safety network will be much more 

expensive initially and over the life of the system. It will also be 

prone to technical deficiencies as technology evolves. A 

priority access approach makes much more sense. 

Wireless device 

manufacturer 

(somewhat satisfied) 

The debate in Congress on whether the spectrum should be 

auction or reallocated has create[d] uncertainty in the FCC to 

take action on this band. 

Wireless service 

provider (strongly 

dissatisfied) 

FCC was correct; but 5.8.2 is dead. FCC missed opportunity to 

start rulemaking proceedings a year ago for D Block auction. 

FCC has been marginalized and is no longer a player on this 

issue. So 5.8.2 is no longer relevant. 

Wireless service 

provider (strongly 

dissatisfied) 

The FCC has completely failed to follow its own National 

Broadband Plan and federal statute to commercially auction 

this vital block of spectrum. 

Source: GAO survey. 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 83 GAO-12-118 Commercial Spectrum 

Congress should consider expressly expanding FCC’s authority to enable 

it to conduct incentive auctions in which incumbent licensees may 

relinquish rights in spectrum assignments to other parties or to FCC. 

To motivate existing spectrum licensees to voluntarily give up their 

licenses so that FCC could more quickly reallocate the spectrum to higher 

valued services. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 15 0 7 13 4 39

Somewhat agree 3 1 0 4 2 10

Neither agree 

nor disagree 

0 5 1 0 1 7

Somewhat 

disagree 

0 0 0 0 1 1

Strongly 

disagree 

1 5 1 4 1 12

Total 19 11 9 21 9 69

Source: GAO survey. 

National Broadband 

Plan 

Recommendations 

Aimed at Expanding 

Incentives and 

Mechanisms to 

Reallocate Spectrum 

Grant FCC Authority to 

Conduct Incentive 

Auctions 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 84 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (strongly agree) Incentive auctions will give the FCC the ability to repurpose 

spectrum from inefficient service-specific allocations to more 

flexibile allocations in an efficient manner. 

Expert (strongly agree) Congress should simply grant the FCC the ability to pay some 

of the revenues to broadcasters instead of the Treasury and 

avoid legislating any details of the auction. 

Expert (strongly 

disagree) 

Receipts from government auctions should go to the 

government. The FCC is not an consignment auction house 

auctioning the assets of third parties like Christies or 

Southebys. 

Broadcaster (neither 

agree nor disagree) 

VOLUNTARY auctions may be acceptable so long as resulting 

repacking costs of remaining users are guaranteed. 

Broadcaster (neither 

agree nor disagree) 

If Congress authorizes incentive auctions, it should make clear 

that the Commission must not take any actions in its 

implementation that could harm existing licensees (e.g., 

involuntary repacking into VHF band, loss of coverage areas 

and/or increased interference). 

Broadcaster (strongly 

disagree) 

The FCC should allow licensees to sell or lease to mobile 

operators directly and immediately. 

Infrastructure provider 

(strongly agree) 

A voluntary incentive auction is a market-based mechanism 

that will allow spectrum to be transitioned from one use to a 

new use, and should take years off the current process. 

Public interest group 

(strongly disagree) 

... Incentive auctions will dramatically increase spectrum 

hoarding and make further band clearing far more difficult. 

Wireless device 

manufacturer (strongly 

disagree) 

(FCC) should force and recover spectrum from those who 

have not used what they have before going after spectrum 

used by broadcasters and recent (television) white spaces 

rulings. (This would) actually (take) away from new innovative 

spectrum use. 

Wireless service 

provider (strongly 

agree) 

The primary reason spectrum identification and reallocation 

takes so long is political pressure from incumbents. Incentive 

auctions would reduce this pressure and allow the government 

to move more quickly. 

Wireless service 

provider (somewhat 

agree) 

OK to have as another tool in the spectrum management 

toolbox, but very uncertain how effective it will be in bringing 

commerically valuable amounts of spectrum to market to 

support wireless broadband. 

Source: GAO survey. 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 85 GAO-12-118 Commercial Spectrum 

Congress should consider granting authority to the FCC to impose 

spectrum fees on license holders.6

Fees may help to free spectrum for new uses with potentially higher value 

than current uses, since licensees who use spectrum inefficiently may 

reduce their holdings once they bear the opportunity cost of spectrum. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 12 0 1 2 3 18

Somewhat agree 3 0 3 4 1 11

Neither agree nor 

disagree 

1 0 2 1 3 7

Somewhat 

disagree 

3 2 0 4 2 11

Strongly disagree 1 11 3 9 0 24

Total 20 13 9 20 9 71

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (strongly agree) The value of spectrum is far greater, in most cases, than is 

recovered in auctions. Spectrum fees can be based on the 

appreciating value of spectrum. 

Expert (strongly agree) Spectrum fees are a critical market-based mechanism used in 

the UK to ensure that government spectrum is used efficient[ly] 

or repurposed for commercial use. US should do the same. 

 

6

This recommendation also said that Congress should consider granting authority to NTIA 

to impose spectrum fees on users of government spectrum, but we did not include that 

part of the recommendation is our survey because our focus was on FCC. 

Grant FCC Authority to 

Impose Fees on Licensees 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 86 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (strongly agree) Without the ability to impact the bottom line, the FCC is less 

effective than otherwise. However if the incumbents write the 

legislation as is the current practice, it will come out that the 

FCC will have the power to fine the little guys and the big guys 

will have many loopholes and time wasters. If, however, the 

FCC were to work with the NTIA, DOD, and DHS regarding 

criteria for imposing fees so that the FCC could shape the 

behavior of the huge incumbents in a meaningful way without 

accidentally or unfairly penalizing the smaller entrepreneurs, 

then the public interest would be served. 

Expert (strongly agree) It is ridiculous to give some spectrum away and charge for 

others. It is equally ridiculous to have a one time payment that 

provides rights into perpetuity. 

Expert (somewhat 

agree) 

Only if the FCC cannot grant flexible rights whereby the licensees 

realizes the opportunity cost of the spectrum it uses ... or the 

licensee is in a shared band, then fees are one tool to provide 

more accurate price signals about the cost of using the spectrum. 

Expert (strongly 

disagree) 

Spectrum fees on private parties do not create incentives for 

efficiency. At best (worst?) a fee that makes a particular 

license unprofitable will result in the license going back to the 

government — that does not create value, but reduces output. 

The way to create value is to allow competitive forces wider 

scope, permitting the licensee to deploy any service, 

technology, or business model that may be profitable. 

Broadcaster (strongly 

disagree) 

Payment is already made in the context of required public 

interest responsibilities of broadcasters. 

Broadcaster (strongly 

disagree) 

Broadcasters already pay for their spectrum in the form of 

public interest obligations that exceed those for any other 

privately-held spectrum. Congress should recognize the public 

value of these obligations and the cost to broadcasters of 

complying with them. 

Broadcaster (strongly 

disagree) 

Broadcasters already pay enormous “regulatory fees” and 

absorb regulatory costs not imposed on others. 

Broadcaster (strongly 

disagree) 

The FCC already collects annual regulatory fees. Moreover, 

there is no elaboration of how such fees would be assessed or 

for what purpose such collected fees would be used. Further 

any use of spectrum fees to encourage licensees to give up 

their spectrum for other purposes disserves the public interest. 

Broadcaster (somewhat 

disagree) 

We disagree in terms of applying fees to spectrum holders that 

are actively using their spectrum for the intended purpose. 

These fees should *only* be applied to license holders that are 

squatting or allowing their spectrum to sit unused. 

Public interest group 

(strongly agree) 

Yearly spectrum fees will increase spectrum utilization and 

incent license holders who do not use their bands to return 

them. Furthermore, over time, yearly license fees raise far 

more money for the public treasury than one-off auctions and 

are thus a superior and more fiscally responsible choice. 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 87 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Mobile Satellite 

Services company 

(strongly agree) 

Spectrum fees are preferable to auctions or any other 

regulatory method for ensuring that spectrum is used 

reasonably efficiently. There never would have been auctions 

if the broadcast industry was not unalterably opposed to 

spectrum fees in the 1980s. 

Satellite radio service 

provider (somewhat 

agree) 

Spectrum fees should be tied to how a licensee acquired its 

spectrum. Licensees that paid fair market price through an 

auction should pay less in usage fees than those licensees in 

bands that initially acquired licenses through means other than 

auctions. 

Infrastructure provider 

(neither agree nor 

disagree) 

No clear economic evidence that fees leads to more efficiency. 

So if the goals is improved spectrum policy, this would fail to 

support the goal. 

Wireless device 

manufacturer 

(somewhat agree) 

However, such fees should not be imposed on licensees that 

obtained their spectrum license through competitive bidding 

mechanisms. 

Wireless service 

provider (strongly 

agree) 

This assumes these fees are for either non-auctioned 

spectrum and/or spectrum that is not licensed for flexible use. 

Wireless service 

provider (somewhat 

disagree) 

If already paid for spectrum in an auction, then no. Ultimately 

increases prices to consumers. 

Source: GAO survey. 

FCC should evaluate the effectiveness of its secondary markets policies 

and rules to promote access to unused and underutilized spectrum. 

FCC believes that the performance of secondary markets under the 

Commission’s current policies has been mixed and is concerned that 

unused or underutilized spectrum is possibly not be being made available 

to smaller providers, especially in rural areas where spectrum goes 

unused. 

Address Barriers to 

Secondary Markets 

Recommendation 

Rationale 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 88 GAO-12-118 Commercial Spectrum 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 15 5 6 10 3 39

Somewhat agree 3 4 3 5 5 20

Neither agree 

nor disagree 

1 2 0 1 1 5

Somewhat 

disagree 

0 0 0 3 0 3

Strongly 

disagree 

1 0 1 1 0 3

Total 20 11 10 20 9 70

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (strongly 

agree) 

The FCC should update and revise its secondary markets 

policy to include all spectrum to allow all current licensees to 

participate in a secondary market so long as their primary 

spectrum uses remain intact. This will allow market forces to 

determine the best use for spectrum without requiring 

wholesale reallocation of designated bands for other purposes.

Expert (strongly agree) A reasonable suggestion that obviates the need for incentive 

auctions. 

Expert (strongly agree) FCC has been doing a good job, but should consider a legislation 

to form a private public interest company or FFRDC to create the 

secondary spectrum databases and to assist and support 

spectrum use. The German Fraunhofer model requires 1/3 

industry funding, and that is a good model for responsiveness to 

industry (vs. the US FFRDC model which has little such 

incentives) 

Expert (strongly 

disagree) 

Secondary markets, as conceived by regulators, involve the sale 

of ‘naked licenses.’ In fact, those markets are robust — over 

50,000 CMRS licenses have been aggregated into a small 

number of national and regional cellular networks — all through 

secondary transactions. But the far more active trading of 

spectrum rights is done not by buying/selling stand-alone 

spectrum, but “wireless services.” The bundle — spectrum + 

mobile network access — is sold in wholesale and retail markets. 

That is the efficient way to package the product, and (because the 

buyers and sellers internalize transaction costs) that is the way the 

market organizes the use of spectrum. Trying to get owners of 

liberally licensed spectrum to sell their “excess” in a naked 

bandwidth trade is like trying to induce homeowners to rent out 

spare bedrooms. Yes, homes are not at fully occupied, and many 

rooms are rented out. But by and large, families prefer not to do 

so, forgoing the opportunity available. Wireless carriers often “sell” 

access, as to retail customers, MVNOs, or other networks 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 89 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

(roaming agreements), and they frequently buy/sell licenses. But 

once they construct a network to use particular airwaves, they find 

it inefficient to split off spectrum rights and lease them to other 

networks. This reflects efficiency; the premise of the “do more for 

secondary markets” policy is that such markets are failing. But 

they are not; they work in a matter that is often misunderstood. 

Infrastructure provider 

(somewhat agree) 

The FCC’s policies here are good, and are being used, but 

further evaluation is helpful. 

Public interest group 

(neither agree nor 

disagree) 

[FCC] needs to avoid creating transaction costs that 

undermine the utility of secondary markets. 

Mobile Satellite 

Services company 

(strongly agree) 

All secondary market tools - spectrum leasing, partitioning, 

disaggregating, etc, should be available to all licensed wireless 

services, including satellite. 

Wireless device 

manufacturer (strongly 

agree) 

... I ... suggest mandatory spectrum leasing of spectrum that 

has not been built out for 5 years. Cognitive Radio could put 

this to use and return it to incumbents if they ever decide to 

build out. ... 

Wireless device 

manufacturer (strongly 

agree) 

FCC should ... expand the applicability of secondary markets 

policies to all spectrum-based services and bands. While it has 

proposed this for certain mobile satellite bands, FCC (and 

NTIA) should also apply the same leasing policies and 

procedures (including the notion of “private commons”) to the 

broadcasting, other satellite and Federal bands. It should also 

lift restrictions on shared channels in the private land mobile 

radio ... bands below 512 MHz in connection with the 10-

channel limitation and leasing restrictions. 

Wireless service 

provider (somewhat 

agree) 

It is not secondary markets policies that are the problem. They 

work well with carriers that want to make spectrum available. 

Problem is warehousing by carriers attempting to keep 

spectrum from competitors. Not a secondary markets problem, 

but an FCC enforcement problem. 

Wireless service 

provider (somewhat 

agree) 

While in general there are mechanisms that facilitate 

secondary market transactions, the FCC should create greater 

incentives for license holders that are not using their spectrum 

to sell/lease it to entities that will. 

Source: GAO survey. 

FCC officials told us that the Commission conducted an internal review of 

its secondary markets policies that concluded that it should do more to 

promote secondary markets. Toward that end, in November 2010, FCC 

issued a Notice of Inquiry on dynamic spectrum access technologies that 

have the potential to enable sharing of spectrum in common locations, 

including how such technologies could facilitate secondary markets. In 

January 2011 FCC officials told us that the Commission was assessing 

FCC’s Progress on 

Implementing the 

Recommendation through May 

2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 90 GAO-12-118 Commercial Spectrum 

the input it received in response to that inquiry, and that it intended to 

issue a related order, tentatively by the end of calendar year 2011. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 2 0 1 0 0 3

Somewhat 

satisfied 

5 0 3 3 2 13

Neither satisfied 

nor dissatisfied 

3 5 2 4 6 20

Somewhat 

dissatisfied 

5 0 1 7 0 13

Strongly 

dissatisfied 

0 3 1 1 0 5

Total 15 8 8 15 8 54

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Expert (somewhat 

satisfied) 

This efforts needs a definition of what DSA must meet as 

potential for interference. Without a definition of “harmful”, it 

will be hard to deploy any DSA. 

Expert (neither satisfied 

nor dissatisfied) 

No evidence that dynamic spectrum access technologies would 

promote secondary markets. On the other hand, removing any 

barriers that arbitrarily block dynamic access technologies would 

be good even if it had no effect on secondary markets. 

Expert (somewhat 

dissatisfied) 

FCC’s slowness in Docket 04-186 shows its ambivalence in 

this area. This is a very technical area and FCC as presently 

structured doesn’t deal well with such issues. 

Broadcaster (strongly 

dissatisfied) 

[FCC’s] analysis must include broadcast spectrum to be 

credible and effective. 

Infrastructure provider 

(neither satisfied nor 

dissatisfied) 

Dynamic spectrum access is [in its] very early days and will 

probably not be important for years. 

Wireless service provider 

(neither satisfied nor 

dissatisfied) 

FCC policies on dynamic sharing may do more harm than 

good. More testing regarding the potential for interference and 

the economic case is necessary before making any decisions. 

Wireless service 

provider (somewhat 

dissatisfied) 

Dynamic spectrum access is a small subset of secondary 

markets. The FCC can promote secondary markets by 

reducing barriers to these transactions and speeding up the 

approval process for license transfers and leases and by 

increasing flexible use for licensed spectrum allocations. 

Wireless service  Revitalize management agreements — The FCC should 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 91 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of satisfaction) Comment excerpts 

provider (somewhat 

dissatisfied) 

clarify whether “management agreements” or other nonleasing arrangements are still permitted and, if so, 

whether the former Intermountain Microwave factors are 

still applicable or whether other guidelines would apply. If 

not permitted, then the FCC could consider permitting a 

lower cost means for licensees to facilitate build-out with 

third party managers or partners, possibly with notice to 

the FCC about the relationship. 

 Establish an FCC “warehouse” of unused spectrum — 

The FCC can aggregate its unsold or returned PCS, AWS, 

700 MHz and other spectrum licenses it still holds and 

enable parties to petition to serve these areas using 

procedures similar to the existing Section 22.949 process 

for unserved cellular areas (with short-term build-out 

requirements). Or, parties could “lease” this spectrum from 

the FCC under this approach, paying annual lease fees to 

the government. 

 Facilitate streamlined leasing arrangements through FCCcertified brokers — The FCC could incentivize carriers to 

contribute unused spectrum, especially in rural and 

underserved areas, to the FCC’s spectrum warehouse or 

to third party “brokers” that would be certified by the FCC 

to maintain an inventory of spectrum available for lease 

under pre-approved short-form agreements at low cost to 

all parties involved (with streamlined FCC rules). (The 

FCC could also get some of the lease revenue from this 

approach.) 

 Adopt leasing incentives — Incentives to contribute 

spectrum to a certified broker or to lease directly to a third 

party could include avoidance of non-use fees or use-it-orlose-it rules, or bidding credit eligibility or limited 

exemptions from the FCC’s spectrum screen for carriers 

that contribute spectrum to the FCC or to a certified broker 

for possible lease. 

 Develop new tools and agency agreements — The FCC 

could adopt a new “hybrid agency agreement” or service 

agreement approach, similar to a resale agreement, as a 

new secondary market tool. 

 Develop an FCC spectrum buy-back program — The FCC 

could use auction proceeds or lease revenues (see 

above) to “buy back” spectrum in unserved or 

underserved areas and then recoup some of the cost of 

this program by selling or leasing this spectrum to rural 

carriers interested in serving these areas. 

 Develop a spectrum “homesteading” or finder’s preference 

program — The FCC could establish a small rural mobile 

development office where parties interested in serving 

unserved or underserved areas could go to determine 

what unused spectrum may be available in these markets 

from the FCC or from licensees, and the FCC staff could 

facilitate leasing arrangements through discussions with 

the existing licensees. Enabling entities to build-out and 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 92 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of satisfaction) Comment excerpts 

establish “squatter’s rights” (with a later right to a 

partitioned/disaggregated license where they are serving 

customers) on unused spectrum in limited identified areas, 

and only if the licensee has not agreed to contribute the 

spectrum for leasing,might incentivize greater leasing. 

 Streamline current spectrum leasing rules — The FCC 

could eliminate unnecessary spectrum manager lease 

filings (arguably no filings should be necessary for shortterm spectrum manager leases, and only a notification filing 

for long-term spectrum manager leases when they begin 

and end); eliminate lease renewal filings; act on all longterm de facto transfer leases within 21 or 15 days, etc. 

Wireless service 

provider (strongly 

dissatisfied) 

It should not take one year to assess the input obtained from 

the Dynamic Spectrum Access NPRM. 

Source: GAO survey. 

FCC, within the next 10 years, should free up a new, contiguous 

nationwide band for unlicensed use. 

To enable innovators to try new ideas to increase spectrum access and 

efficiency through unlicensed means and to enable new unlicensed 

providers to serve rural and unserved communities. 

National Broadband 

Plan 

Recommendations 

Aimed at Expanding 

Opportunities for 

Innovative Spectrum 

Access Models 

Provide Spectrum for 

Unlicensed Use 

Recommendation 

Rationale 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 93 GAO-12-118 Commercial Spectrum 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 8 1 4 2 3 18

Somewhat agree 0 2 2 5 2 11

Neither agree 

nor disagree 

3 3 1 2 1 10

Somewhat 

disagree 

2 3 0 6 1 12

Strongly 

disagree 

3 1 2 4 0 10

Total 16 10 9 19 7 61

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (strongly agree) No amount of licensed spectrum will ever satisfy the future 

demand for rich wireless media, so the FCC needs to ensure 

that wireless carriers and others have access to enough 

[un]licensed spectrum for many more wi-fi access points to 

move wireless traffic onto the wired network at the earliest 

opportunity in the transmission session. 

Expert (strongly agree) essential to promoting competition and innovation in wireless 

services 

Expert (neither agree 

nor disagree) 

... the success of unlicensed systems depends on global 

coordination and therefore allocations in the US alone will not 

achieve the necessary dividends. 

Expert (somewhat 

disagree) 

There is an opportunity cost to making unlicensed spectrum 

available and it may not be the most efficient use of spectrum 

— there should be a price tag put on this so that people realize 

the oppotunity cast and potential inefficiency of allocating more 

spectrum for unlicensed use. 

Expert (strongly 

disagree) 

Contiguity no longer is needed because of the emergence of 

affordable devices where, say a 2 GHz device can operate 

effectively and affordably between 1.3 and 2.3 GHz (and 

similarly in other bands). Unlicensed chunks in different parts 

of the spectrum can be effectively hybridized via 

heterogeneous spectrum management, promoting market 

entry of new small to medium product suppliers. FCC should 

assist the market in using [an] on-line database like for 

[television white spaces] so that unlicensed devices can learn 

about available spectrum and use it dynamically versus 

clearing a new band for unlicensed use. A 60 MHz band 

around 1 GHz in bandwidth for indoor use would be a 

significant contribution to the development of unlicensed 

markets. 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 94 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (somewhat 

disagree) 

Strict interference protection standards will be crucial in any 

such initiative. 

Infrastructure provider 

(strongly agree) 

Where spectrum is sorely needed is to support Wi Fi 

technologies at 5 GHz. An increased footprint of “shared” 

spectrum is required to meet future needs and support next 

generation Wi Fi technologies. 

Mobile Satellite 

Services company 

(somewhat disagree) 

There is already plenty of spectrum available for unlicensed 

use. This is a low priority. 

Wireless device 

manufacturer 

(somewhat agree) 

There is substantial amount of unlicensed spectrum that has 

been recently allotted which remains vacant. After this 

spectrum has systems, more spectrum may need to be made 

available. 

Wireless service 

provider (strongly 

agree) 

... an appropriate amount of unlicensed spectrum should be 

made available that is dedicated exclusively to unlicensed 

outdoor fixed wireless broadband delivery and NOT shared 

with consumer-type (i.e., Wi-Fi) devices. 

Wireless service 

provider (somewhat 

disagree) 

Spectrum is not an unlimited resource. Priority should be given 

to reallocation of available spectrum subject to auction under 

exclusive licensing. 

Source: GAO survey. 

FCC intends to consider making additional spectrum available for 

unlicensed use in conjunction with NTIA’s “Plan and Timetable to Make 

Available 500 Megahertz of Spectrum for Wireless Broadband,” which 

addresses both licensed and unlicensed uses. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 2 0 1 1 0 4

Somewhat 

satisfied 

3 0 2 2 3 10

Neither satisfied 

nor dissatisfied 

2 0 1 1 0 4

Somewhat 

dissatisfied 

1 0 1 3 1 6

Strongly 

dissatisfied 

0 2 1 0 1 4

Total 8 2 6 7 5 28

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

FCC’s Progress on 

Implementing the 

Recommendation through 

May 2011 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 95 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of satisfaction) Comment excerpts 

Expert (somewhat 

dissatisfied) 

Too slow. 

Infrastructure provider 

(somewhat dissatisfied) 

The FCC’s focus has been white spaces, which provides 6 

MHz channels and will never be a global footprint (other 

countries have different channelization for TV). The FCC has 

not proposed, for example, opening up more spectrum at 5 

GHz for shared use. 

Public interest group 

(strongly dissatisfied) 

There has been no meaningful progress on this 

recommendation. Currently, unlicensed is an afterthought in 

both planning the by FCC and the Obama administration .... 

Given the success of unlicensed in dramatically increasing the 

public’s access to the public airwaves, it should be the priority; 

spectrum auctions to corporations rich enough to buy exclusive 

use to the public airwaves should be secondary. 

Wireless service 

provider (somewhat 

dissatisfied) 

We believe that creating a new nationwide unlicensed band 

will result in very substantial economic benefits for the nation 

as a whole. For this reason, we support rapid action FCC to 

create this band. 10 years is too long to wait. We would like to 

see this band created within the next 2 to 3 years. 

Source: GAO survey. 

FCC should move expeditiously to conclude the television white spaces 

proceeding. 

To accelerate the introduction of new innovative products and services 

that would use the television white spaces. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 8 0 5 6 4 23

Somewhat agree 3 1 2 5 0 11

Neither agree 

nor disagree 

2 4 1 3 3 13

Somewhat 

disagree 

2 3 1 2 0 8

Strongly disagree 3 4 1 2 0 10

Total 18 12 10 18 7 65

Source: GAO survey. 

Expert and Stakeholder 

Comments on FCC’s Progress 

Issue Rules on Television 

White Spaces 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 96 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Expert (somewhat 

agree) 

The database aspect is inviting abuses, many unintentional. 

When people measure spectrum use, patterns appear, some 

of which compromise law enforcement, privacy, etc. Thus, the 

[database] should not be public but should be administered by 

a public trust corporation with security clearances that will 

redact information that compromises the public interest such 

as law enforcement, personal privacy, etc. 

Expert (strongly 

disagree) 

TV white spaces proceeding moves in the wrong direction; 

more efficient to reorganize spectrum in each market and 

auction off unlicensed spectrum rather than white spaces. 

Expert (strongly 

disagree) 

The conclusion of the white spaces could impact other 

spectrum decisions, including the incentive auctions and 

repacking and it can be very hard to undo unlicensed uses. 

Broadcaster (neither 

agree nor disagree) 

The FCC must have adequate rules for the database 

administrators to ensure accuracy and avoid unnecessary 

interference. 

Broadcaster (somewhat 

disagree) 

The FCC should move only as expeditiously as it can based on 

sound engineering and spectrum principles. The FCC must 

ensure its rules for white space use fully protect incumbent 

users and do not cause interference to viewers. 

Wireless service 

provider (somewhat 

disagree) 

The FCC needs to ensure that actions it takes do not create 

potential future issues with additional TV spectrum identified 

for reallocation to mobile broadband use. 

Wireless service 

provider (strongly 

disagree) 

... Too much interference risk. ... [FCC] should allow this good 

propagation spectrum to be used for broadband backhaul. 

Source: GAO survey. 

 In September 2010, FCC issued an opinion and order that: (1) 

eliminates the requirement that television bands devices that 

incorporate geo-location and database access must also include 

sensing technology to detect the signals of television stations and lowpower auxiliary service stations (wireless microphones); (2) requires 

wireless microphone users who seek to register in the television 

bands databases to certify that they will use all available channels 

from 7 through 51 prior to requesting registration; and (3) reserves 

two vacant UHF channels for wireless microphones and other low 

power auxiliary service devices in all areas of the country while 

maintaining a reasonable separation distance between television 

white space devices and wireless microphone usage. 

 In January 2011, FCC conditionally designated nine companies to 

develop and administer the databases that new unlicensed wireless 

devices would use to identify available channels. 

Expert and Stakeholder 

Comments on the 

Recommendation 

FCC’s Progress on 

Implementing the 

Recommendation through 

May 2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 97 GAO-12-118 Commercial Spectrum 

 FCC conducted three workshops with the database administrators, 

one each in March, April, and May 2011. The workshops covered 

development, security, and testing of the databases. FCC plans to 

hold additional workshops towards final approval of the database 

administrators. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 2 0 2 0 0 4

Somewhat 

satisfied 

5 1 3 2 2 13

Neither satisfied 

nor dissatisfied 

2 0 0 6 1 9

Somewhat 

dissatisfied 

0 0 2 3 0 5

Strongly 

dissatisfied 

2 0 0 0 1 3

Total 11 1 7 11 4 34

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Public interest group 

(somewhat satisfied) 

The process has taken longer than it could have, I believe. 

Public interest group 

(strongly dissatisfied) 

The FCC’s current plan is to kill off the utility of TV white space 

technologies ... [b]y auctioning off these bands to the highest 

bidder [via incentive auctions]. 

Wireless device 

manufacturer (very 

satisfied) 

This is perhaps the only segment in wireless we are actually 

leading the world. More resource should be applied to this 

endeavor to make improvements. Next Gen Wi Fi.... 

Wireless device 

manufacturer 

(somewhat satisfied) 

The removal of the sensing requirement is somewhat troubling 

because it was deemed essential in the sharing of spectrum. 

As the FCC continues to support sharing in other bands, it is 

troubling, that the FCC may define sharing based on 

technology that is unsuitable or unavailable commercially. 

Source: GAO survey. 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 98 GAO-12-118 Commercial Spectrum 

FCC should spur further development and deployment of opportunistic 

uses across more radio spectrum. 

To significantly increase the efficiency of spectrum utilization by enabling 

radios to access and share available spectrum dynamically. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 11 2 5 4 2 24

Somewhat agree 3 3 2 6 3 17

Neither agree 

nor disagree 

2 3 2 4 0 11

Somewhat 

disagree 

1 1 0 3 2 7

Strongly 

disagree 

2 1 1 3 0 7

Total 19 10 10 20 7 66

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (strongly 

disagree) 

The FCC must protect the integrity of existing services while 

encouraging innovation. The FCC should free incumbent 

licensees from technical restrictions that hinder such 

innovation. 

Expert (strongly agree) But opportunistic uses should be prioritzed based upon 

intelligent technical analysis, i.e., a spectrum technology road 

map. 

Expert (strongly 

disagree) 

This is precisely the sort of thing that regulators should not do. 

They should focus on something distinct: creating rules that 

yield optimal incentives for competitive processes to create 

efficient solutions. 

Expert (strongly 

disagree) 

I do not believe that mass market technology and the demands 

of the commercial marketplace will allow for these techniques 

within the next decade 

Expert (somewhat 

disagree) 

[In implementing this recommendation], FCC should adopt 

policies that facilitate agreements among private parties. 

Spur Opportunistic Uses of 

Spectrum 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 99 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Mobile Satellite 

Services company 

(somewhat disagree) 

If the FCC does this, there will be more interference 

complaints. The FCC has to commit to devote resources to 

investigating and resolving interference complaints quickly. 

Wireless device 

manufacturer 

(somewhat agree) 

Cognitive radio is promising; however generally speaking the 

technology needs further development before appropriate for 

many bands; in any event, should be commercially driven not 

as a regulatory mandate. 

Wireless device 

manufacturer (strongly 

agree) 

It is great that the ... NBP recognized that “[o]pportunistic 

sharing arrangements offer great potential to meet increasing 

market demand for wireless services by promoting more 

efficient use of radio spectrum.” [This recommendation] is 

absolutely correct in stating that “‘opportunistic’” or ‘cognitive’ 

technologies can significantly increase the efficiency of 

spectrum utilization by enabling radios to access and share 

available spectrum dynamically.” However, this 

recommendation over-emphasized the unproven and 

inefficient database approach to advanced sharing and 

disregarded spectrum sensing (detect-and-avoid) and hybrid 

sensing/geolocation approaches. The FCC’s preference for 

geolocation approaches is apparently based on its lack of 

information regarding spectrum sensing, its decision in the TV 

White Spaces proceeding to eliminate the sensing requirement 

and recent enforcement issues (unrelated to sensing 

capabilities) in the 5 GHz U-UNII band in which sensing is 

required to share with radar operations. Hopefully, the record 

developed in the FCC’s DSA NOI proceeding (ET Docket No. 

10-237) and NTIA’s spectrum sharing test bed should provide 

additional information on sensing. 

Wireless service 

provider (somewhat 

agree) 

We support ... dynamic spectrum access ... shared and 

secondary market access to spectrum capacity but would 

strongly oppose FCC adoption of rules or policies which 

diminish the rights of the licensees of exclusive spectrum 

purchased at auction to control and/or to exclude access to 

their spectrum. 

Source: GAO survey. 

In November 2010, FCC issued a Notice of Inquiry seeking comment on 

how dynamic spectrum access radios and techniques can promote more 

intensive and efficient use of the radio spectrum. 

FCC’s Progress on 

Implementing the 

Recommendation through May 

2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 100 GAO-12-118 Commercial Spectrum 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 1 0 1 0 1 3

Somewhat 

satisfied 

5 1 2 1 1 10

Neither satisfied 

nor dissatisfied 

3 4 2 7 1 17

Somewhat 

dissatisfied 

1 0 1 0 1 3

Strongly 

dissatisfied 

2 0 1 1 1 5

Total 12 5 7 9 5 38

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Private user group 

(somewhat satisfied) 

This direction holds some promise as long as the inherent 

limitations of dynamic spectrum access techniques are taken 

into account and are not relied upon inappropriately. 

Wireless device 

manufacturer (strongly 

dissatisfied) 

DSA has a place in providing communications solutions 

however there is a concern that the FCC is unaware of the 

state of technology and how it operates to provide solutions. 

So mandating solutions may delay the usage of the bands 

considered for DSA. 

Wireless service 

provider (strongly 

dissatisfied) 

Additional study is needed as dynamic spectrum access radios 

technologies have not been proven yet. 

Source: GAO survey. 

FCC should initiate proceedings to enhance research and development 

that will advance the science of spectrum access. 

A robust research and development pipeline is essential to ensuring that 

spectrum access technologies continue to evolve and improve. 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 

Enhance Research and 

Development on Spectrum 

Access 

Recommendation 

Rationale 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 101 GAO-12-118 Commercial Spectrum 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 11 2 7 5 4 29

Somewhat agree 5 4 2 7 1 19

Neither agree 

nor disagree 

0 3 0 3 1 7

Somewhat 

disagree 

0 1 0 2 1 4

Strongly 

disagree 

2 1 1 2 1 7

Total 18 11 10 19 8 66

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (somewhat 

agree) 

While it is good to stimulate research and development, the 

FCC should not assume that government should direct the 

effort. 

Expert (strongly 

disagree) 

There is no need for government efforts to “enhance” R&D in 

this area. Substantial efforts already in place. 

Expert (somewhat 

agree) 

Not clear what role there is that isn’t already met by private 

sector; eliminating barriers would be good. 

Mobile Satellite 

Services company 

(strongly disagree) 

Spectrum shortages have provided enough incentive for 

licensees to spend their funds on research and development of 

ways to use spectrum more intensively. The government does 

not have to be involved in this. It will only stifle development. 

Wireless service 

provider (somewhat 

disagree) 

If guidelines were in place that assured a competitive 

marketplace among wireless carriers of various sizes and new 

entrants, then competitive carriers and new entrants would 

accomplish this innovation in the marketplace. Such grantfunded innovation becomes necessary when there is a lack of 

competition within the market. 

Wireless service 

provider (strongly 

agree) 

The FCC should leverage work that is currently being done 

both in private industry ... or by academic institutions .... 

Source: GAO survey. 

In November 2010, FCC issued an NPRM that seeks to expand the 

Commission’s existing Experimental Radio Service rules to promote 

cutting-edge research and foster development of new wireless 

technologies, devices, and applications. Specifically, FCC proposed a 

new type of license, called a “program license,” which would give qualified 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 

FCC’s Progress on 

Implementing the 

Recommendation through May 

2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 102 GAO-12-118 Commercial Spectrum 

entities broad authority to conduct research without the need to seek new 

approval for each individual experiment. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 2 0 2 1 1 6

Somewhat 

satisfied 

8 1 2 4 1 16

Neither satisfied 

nor dissatisfied 

3 3 3 3 0 12

Somewhat 

dissatisfied 

1 0 1 2 1 5

Strongly 

dissatisfied 

1 0 0 0 1 2

Total 15 4 8 10 4 41

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Expert (strongly 

dissatisfied) 

This NPRM is mostly PR. In reality big firms ... already have 

the equivalent of a “program license.” 

Private user group 

(somewhat dissatisfied) 

The existing Experimental Radio Service rules do not bar 

progress but should be strengthened to ensure that licensees 

are aware of experimental operations that may cause harmful 

interference to them. 

Wireless device 

manufacturer (neither 

satisfied nor 

dissatisfied) 

A lot of questions remain, including the scope of eligible 

entities — the private sector should not be excluded. 

Wireless service 

provider (somewhat 

dissatisfied) 

The FCC proposed to exclude non-public entities under 

blanket licenses. For the type of experimental license available 

to commercial entities, it was stated the licenses are not 

intended for commercial campuses. No explanation for either 

of these arbitrary exclusions were provided in the NPRM. 

Further, the FCC proposes to shift the burden of discovering 

potential interference to the existing licensee, which will 

discourage experimental use. 

Source: GAO survey. 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 103 GAO-12-118 Commercial Spectrum 

FCC and NTIA should create methods for ongoing measurement of 

spectrum utilization. 

To provide policymakers and the public with important information on 

how, where, and when spectrum is being used. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 13 10 7 10 3 43

Somewhat agree 3 1 2 5 4 15

Neither agree 

nor disagree 

1 0 0 2 0 3

Somewhat 

disagree 

1 0 1 3 0 5

Strongly 

disagree 

2 1 0 1 2 6

Total 20 12 10 21 9 72

Source: GAO survey. 

National Broadband 

Plan 

Recommendations 

Aimed at Enhancing 

FCC’s Spectrum 

Policymaking 

Measure Spectrum 

Utilization 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 104 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (strongly 

agree) 

This should be an objective measurement, not subjective 

based upon content in the use. 

Broadcaster (somewhat 

agree) 

The FCC and NTIA should complete a comprehensive 

inventory of how spectrum is currently allocated, who is using 

it, and how it is being used before proceeding with any steps 

related to spectrum reallocation. 

Broadcaster (strongly 

disagree) 

Measurement is not an effective means of finding unused 

spectrum. 

Broadcaster (strongly 

agree) 

Without identified and peer reviewed methods there is no 

certainty that any measurement of spectrum utilization 

measurement will be accurate or will provide the information 

the agency needs to evaluate how spectrum is currently being 

used. 

Expert (strongly agree) Use does not necessarily equate to active transmissions. 

Expert (strongly agree) Spectrum utilization has been on on-going and contentious 

issue. Without specific information the arguments become very 

subjective. Understanding how this resource is being used 

would provide significant insights PRIOR to making new policy 

decisions. It appears that many policy decisions are not based 

upon the technical facts but more on subjective analysis. 

Expert (strongly agree) The data is measured by licensees to manage their own 

bands, so FCC could require reporting vs “measuring” per se 

or to complement and validate measurements. 

Expert (neither agree 

nor disagree) 

It’s a good idea in principle, but it’s not clear how to 

meaningfully define “spectrum utilization.” 

Expert (strongly agree) Target towards bands with likely usage issues; not cellular, 

broadcast. 

Infrastructure provider 

(strongly disagree) 

If by “spectrum utilization” the meaning is to measure how RF 

emissions are being used to transport information, the 

recommendation would yield an outcome that is meaningless 

from a policy perspective. “Use” of the spectrum depends on 

the service, and if commercial, whether the licensee has 

placed the spectrum into service. There might be a few bands 

where this type of analysis is helpful, but this should not be the 

way forward for spectrum policy. Rather, the way forward is to 

understand the technologies under development, their 

spectrum requirements and capabilities, likely use 

cases/demand, and expectations for innovation (how will the 

technology change over time). This is knowable from 

standards bodies and the vendor community. 

Private user group 

(somewhat agree) 

Meaningful spectrum utilization measurement is very difficult. 

Examples: How does one measure the spectrum utilization of 

passive radioastronomy? There may not be many 

transmissions on a distress and calling frequency, but this 

does not mean it can be made available for other uses in 

between. Typical spectrum monitoring will not detect utilization 

by services that habitually use low signal levels such as the 

amateur radio service. 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 105 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Public interest group 

(strongly agree) 

NTIA and FCC spectrum utilization records should include 

allocation information, assignment information, and actual use 

measurements from the field and at a level of granularity 

allowing informed decisions at the local (census block) level. 

Satellite radio service 

provider (somewhat 

agree) 

Spectrum utilization is rarely a binary question of whether 

spectrum is or is not being “used” by having transmissions in 

the spectrum. For example, in order for spectrum to be 

“utilized,” it should be used in a meaningful way to serve the 

public or the intended government/business use; this is far 

different from just testing whether signal is being transmitted to 

preserve the license, as can be the case with wireless 

spectrum. In the public safety context, spectrum can be used if 

it is unused but available for use during the next public 

emergency. In the context of broadcast spectrum, the question 

of whether spectrum is being used might even consider 

whether the station is being operated in a manner that serves 

the public interest. 

Mobile Satellite 

Services company 

(strongly disagree) 

... This is impossible without drastically increasing the number 

of government employees and the number of regulated 

company employees who would have to monitor and report. 

This cannot be done in any reasonably efficient manner. There 

would never be agreement on what to measure and how. 

Wireless device 

manufacturer 

(somewhat disagree) 

Usage is only one consideration; the main consideration is the 

ROI. 

Wireless service 

provider (somewhat 

agree) 

The key is to measure in spectrum bands where there are no 

market incentives to efficiently use spectrum, e.g., government 

and restricted use bands. 

Wireless service 

provider (somewhat 

agree) 

Very complex subject; spectrum use varies by time of day, 

weather, events, etc. Such results can be misused so 

measuring methods needs to be carefully developed and 

results properly calibrated and interpreted. 

Wireless service 

provider (somewhat 

disagree) 

It depends what is meant by “utilization” data. If it means only 

transmissions using spectrum, it would be relatively useless. 

Such data would only be relevant if it included data regarding 

the economic value of the spectrum use at issue, the amount 

of time that has passed since the relevant rules were put in 

place, the applicable of secondary markets rules, and potential 

alternative uses. 

Source: GAO survey. 

In the National Broadband Plan, FCC presented its estimate that it would 

cost approximately $10 million to $15 million to deploy measurement 

equipment nationally. FCC also stated in the plan that one way these 

measurements could be accomplished is by frequency scanners installed 

on a fleet of vehicles. FCC officials told us that the Commission will not 

implement this recommendation unless it receives adequate funding. 

FCC’s Progress on 

Implementing the 

Recommendation through May 

2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 106 GAO-12-118 Commercial Spectrum 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 2 0 0 1 0 3

Somewhat 

satisfied 

2 0 2 1 0 5

Neither satisfied 

nor dissatisfied 

4 5 2 6 0 17

Somewhat 

dissatisfied 

6 2 3 2 2 15

Strongly 

dissatisfied 

1 2 2 1 4 10

Total 15 9 9 11 6 50

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Broadcaster (somewhat 

dissatisfied) 

... FCC should be directed to evaluate the costs of contracting 

this function to a knowledgable engineering firm experienced in 

spectrum matters, such as a frequency coordinator or 

consulting engineering firm, and the FCC should be required to 

measure spectrum utilization on an ongoing basis. 

Expert (somewhat 

dissatisfied) 

The objective could be achieved by having spectrum users 

measure their usage using methods and criteria specified by 

the FCC with spot checks by the FCC. This would reduce cost 

of measuement and provide order of magnitudes more data. 

Expert (strongly 

dissatisfied) 

Require reporting. This is just like CALEA. FCC should not 

waste money on the generation of data that incumbents 

already have or must have in order to provide services in 

existing spectrum. FCC should order that they report it and 

should fine licensees who do not report or who do not report 

accurately. 

Public interest group 

(strongly dissatisfied) 

The FCC has a mandate to collect the information it needs to 

make informed policy. It also has the ability to either reprioritize 

existing funding or raise additional funding through license fees 

in order to implement [this] recommendation. 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 107 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of satisfaction) Comment excerpts 

Wireless device 

manufacturer 

(somewhat dissatisfied) 

The scope and scale of such a project need not be this broad 

(nationally), but FCC (and NTIA) should conduct an initial 

series of spectrum occupancy studies at a diverse set of 10 to 

20 fixed locations across the country, augmented by mobile 

data collections, in urban and rural areas over several days or 

weeks. Some or all of this effort could be contracted out to 

independent third parties or academic institutions in 

coordination with the National Science Foundation who is 

already funding some similar data collection efforts. See NTIA 

CSMAC Report, Spectrum Inventory Working Group (May 

2010) at pp. 6, 13 (spectrum measurements initially will best 

serve as an auditing function for certain assignments/licenses 

in the inventory). The sensors used in the UK study referenced 

by the FCC would likely cost tens of thousands of dollars (and 

spectrum analyzers are even more costly). However, spectrum 

sensor equipment and software could cost below $1,000 per 

unit in the near future. 

Source: GAO survey. 

FCC should maintain an ongoing strategic spectrum plan including a 

triennial assessment of spectrum allocations. 

To ensure, now and in the future, that spectrum is allocated to support the 

growth of broadband services and to accommodate new technologies that 

deliver it. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 12 4 6 10 5 37

Somewhat agree 5 6 2 10 2 25

Neither agree 

nor disagree 

1 0 1 0 2 4

Somewhat 

disagree 

1 2 1 0 0 4

Strongly 

disagree 

1 0 0 0 0 1

Total 20 12 10 20 9 71

Source: GAO survey. 

Maintain a Strategic 

Spectrum Plan 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 108 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (somewhat 

agree) 

We support the concept of developing a strategic spectrum 

plan. However, the FCC and NTIA should complete a 

comprehensive inventory of how spectrum is currently 

allocated, who is using it, and how it is being used before 

proceeding with any steps related to spectrum reallocation. 

Moreover, given the complex and dynamic nature of spectrum 

use and demand, spectrum allocations should not be 

reassessed every three years pursuant to an arbitrary 

timetable; instead, the FCC should consider spectrum 

reallocations on a case-by-case basis and only when 

presented with an extremely compelling justification and 

detailed cost/benefit analysis. 

Broadcaster (somewhat 

agree) 

Trienniel re-assessment may be too disruptive, but some 

regular approach is a good idea. 

Expert (strongly 

disagree) 

The main thrust for spectrum policy ought not be to “plan the 

market,” which is what “a strategic spectrum plan” explicitly, 

through “triennial assessments,” seeks to do. Instead it should 

provide as much spectrum to the market as possible. This 

means that it should create generic, exclusive use rights — 

similar to CMRS licenses — that allow licensees to flexibly use 

spectrum. That releases bandwidth to existing applications 

seeking to expand, or to new wireless services attempting to 

compete. The government should not be attempting to wage 

how much one application needs vs. others, but allowing 

demands to be registered via price bids in a spectrum market. 

Expert (somewhat 

agree) 

... FCC should focus on getting spectrum to its highest value 

uses by facilitating the working of the market through flexibile 

and tradable rights, not by measuring “use” of spectrum. 

Expert (somewhat 

agree) 

The FCC should play a much smaller role in allocations. A 

triennial assessment would make sense if it is part of an 

overall strategy along these lines. 

Private user group 

(somewhat agree) 

In general, triennial assessment is too ambitious and creates 

too much uncertainty. Spectrum utilization planning requires a 

longer timeline. 

Wireless device 

manufacturer (strongly 

agree) 

Strongly agree that FCC should maintain an ongoing spectrum 

plan, however, biennal/triennial/quadrennial reviews are 

cumbersome for both industry and the FCC and often result in 

little or no action. 

Wireless service 

provider (somewhat 

agree) 

Triennial is probably too often. First, the task is Herculean. 

Second, the gestation period for new spectrum uses is often 

much longer than 3 years. The rules for wi-fi spectrum were 

put into place in the mid 1980’s but it took until the late 1990’s 

before the wi-fi standard was complete. Nearly everyone would 

agree that Wi-Fi is very useful, but if a triennial review of those 

spectrum rules had been conducted and the use changed, we 

wouldn’t have Wi-Fi. Cellular telephone took a similar amount 

of time to develop and deploy. A detailed assessment every 

ten years would be better. 

Source: GAO survey. 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 109 GAO-12-118 Commercial Spectrum 

In March 2010, FCC issued its current strategic spectrum plan and 

assessment of spectrum allocations in the form of the National 

Broadband Plan’s chapter on spectrum. FCC officials told us that the 

Commission plans to complete an update of its strategic spectrum plan in 

consultation with NTIA in 18 months. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 1 0 2 0 0 3

Somewhat 

satisfied 

5 1 4 7 3 20

Neither satisfied 

nor dissatisfied 

3 2 1 6 2 14

Somewhat 

dissatisfied 

3 1 0 4 0 8

Strongly 

dissatisfied 

2 6 1 2 1 12

Total 14 10 8 19 6 57

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Broadcaster (strongly 

dissatisfied) 

The approach of drafting a staff plan with limited input from 

stakeholders has created confusion and a lack of 

transparency. 

Source: GAO survey. 

FCC and NTIA should develop a joint road map to identify additional 

candidate federal and nonfederal spectrum that can be made accessible 

for both mobile and fixed wireless broadband use, on an exclusive, 

shared, licensed and/or unlicensed basis. 

The specific bands identified in the National Broadband Plan will only 

partially meet future needs for wireless broadband use. 

FCC’s Progress on 

Implementing the 

Recommendation through May 

2011 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 

Identify Additional 

Spectrum for Wireless 

Broadband Use 

Recommendation 

Rationale 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 110 GAO-12-118 Commercial Spectrum 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 13 4 8 10 8 43

Somewhat agree 5 5 0 6 0 16

Neither agree 

nor disagree 

0 1 1 2 0 4

Somewhat 

disagree 

0 2 0 2 0 4

Strongly 

disagree 

0 0 1 1 0 2

Total 18 12 10 21 8 69

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (somewhat 

agree) 

The US needs a comprehensive plan that involves all 

stakeholders, including carriers, broadcasters, commercial 

providers, consumer electronics, academia, etc. The road map 

needs to be more comprehensive than just spectrum and 

should include usage patterns, trends and technologies to 

meet those demands. 

Broadcaster (somewhat 

disagree) 

The FCC must first complete a comprehensive spectrum 

usage review to determine what spectrum is already in use for 

mobile/wireless broadband, what is coming online in the next 

several years and what the actual realistic needs will be based 

on predicted usage and predicted technological advances. 

Private user group 

(strongly agree) 

Close cooperation between the two entities is essential. 

Source: GAO survey. 

 FCC consulted with NTIA on a plan to make available 500 MHz of 

spectrum for wireless broadband over the next 10 years, which NTIA 

issued in November 2010. The plan identified over 2,200 MHz of 

candidate spectrum; the exclusively commercial portion consisted of 

280 MHz identified in the National Broadband Plan and 500 MHz from 

3.7 GHz to 4.2 GHz. At the same time, NTIA presented the results of 

its first evaluation of some of the candidate spectrum, which 

recommended that 115 MHz from various federal bands be made 

available in some parts of the nation for wireless broadband within 5 

years. 

 In March 2011, FCC issued a public notice inviting comment on these 

bands, one additional federal band, and the 500 MHz plan. 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 

FCC’s Progress on 

Implementing the 

Recommendation through May 

2011 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 111 GAO-12-118 Commercial Spectrum 

 FCC officials told us that the Commission is trying to identify 

additional candidate nonfederal spectrum through its ongoing review 

of spectrum allocations, using the following criteria: (1) bands should 

be suitable for ubiquitous, wide-area systems or networks, namely, 

from 225 MHz to 3.7 GHz; (2) bands should be sizeable, contiguous 

blocks of spectrum in order to accommodate the high bandwidths of 

current and emerging wireless technologies; and (3) bands should be 

of sufficient size and be in a part of the spectrum that encourages 

competition by allowing multiple providers and new entrants. For 

example, bands at higher frequencies require more cell sites, and 

hence greater investment, making it harder for small companies or 

new entrants to compete. Bands at lower frequencies require larger 

antennas in devices, which make them less desirable to consumers. 

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 0 0 0 1 2 3

Somewhat 

satisfied 

6 2 6 5 1 20

Neither satisfied 

nor dissatisfied 

5 2 1 7 3 18

Somewhat 

dissatisfied 

4 0 0 1 0 5

Strongly 

dissatisfied 

0 2 1 1 1 5

Total 15 6 8 15 7 51

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with the 

recommendation and that chose to answer the question. 

Type of commenter 

(level of satisfaction) Comment excerpts 

Broadcaster (no 

response) 

In reviewing spectrum allocations, the FCC must continue to 

recognize and appreciate the inherent technical differences 

between higher band and lower band frequencies. In this 

regard, broadcasters should not be forced to relocate from a 

UHF channel to a VHF channel under any scenario. 

Expert (neither satisfied 

nor dissatisfied) 

Fundamentally lower frequencies are more desireable for 

coverage, higher frequencies for capacity. For this reason, 

low/high frequencies should be paired and if possible availed 

simultaneously (such as occured in Germany for 

800MHz/2.5GHz bands). 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 112 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of satisfaction) Comment excerpts 

Public interest group 

(neither satisfied nor 

dissatisfied) 

The agenda is right and many of the right steps are being 

taken. However, the lack of better data on actual utilization of 

spectrum will continue to complicate efforts to identify the most 

suitable bands for repurposing. 

Wireless device 

manufacturer (strongly 

dissatisfied) 

The FCC has identified many of the important characteristics 

needed to provide a wide-area mobile terrestrial system that 

supports data bandwidth intensive services. Unfortunately 

NTIA may not have the same goals as industry and the NBP. 

The spectrum it has identified in unpaired, fragmented or 

above 3 GHz (this can be used but will not serve at the macro 

layer of a wireless network), and has many operational 

exceptions because the spectrum being presented is usually 

considered only for shared use. 

Wireless service 

provider (somewhat 

satisfied) 

Both the FCC and NTIA should focus on spectrum that has the 

best physical characteristics for mobile broadband rather than 

on just “getting spectrum out there.” For example, the 100 MHz 

identified by NTIA between 3550-3650 MHz is suboptimal for 

mobile broadband and includes exclusion zones that cover at 

least half the US population, which makes this spectrum 

generally unsuitable for commercial use. 

Source: GAO survey. 

FCC should promote within the International Telecommunication Union 

(ITU) innovative and flexible approaches to global spectrum allocation 

that take into consideration convergence of various radio communication 

services and enable global development of broadband services. 

Consumers want to use many applications offered on wireline and fixed 

radio communication systems on mobile terminals. The next generation of 

mobile terminals encompasses multiple radio communication services 

functions (e.g., fixed, mobile, broadcasting, and even radio determination) 

that provide for voice, data and video as well as positioning (i.e., 

convergence). The ITU’s current radio regulations, however, may not be 

sufficiently flexible to accommodate these technological changes. 

Promote Innovative 

Approaches to Global 

Spectrum Allocation 

Recommendation 

Rationale 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 113 GAO-12-118 Commercial Spectrum 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 11 2 5 7 4 29

Somewhat agree 5 6 3 6 0 20

Neither agree 

nor disagree 

1 2 1 0 0 4

Somewhat 

disagree 

1 0 1 1 1 4

Strongly 

disagree 

0 1 0 1 1 3

Total 18 11 10 15 6 60

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (somewhat 

agree) 

But the FCC and US Government should, in reaching 

international positions, carefully consider and take into account 

broadcasting spectrum and needs of US domestic television 

distribution. Positions seem to promote broadband at expense 

of existing television distribution uses. 

Expert (neither agree 

nor disagree) 

The ITU has never been a vehicle for progress. Often a better 

way to initiate reforms is for the FCC to act on its own, as it did 

with international settlement rates. On the other hand, it 

doesn’t hurt to push for it within the ITU even if nothing comes 

of it that way. 

Expert (strongly agree) So long as it does not create excessive multiband support 

requirements. 

Private user group 

(somewhat disagree) 

“Flexible” has a down side. There are significant benefits to be 

had from global standards and common allocations. 

Wireless device 

manufacturer (neither 

agree nor disagree) 

Radios are becoming so agile that we don’t need 

harmonization like before. 

Wireless device 

manufacturer 

(somewhat disagree) 

Convergence of services is necessary but the FCC could have 

done more with WRC 2012 Agenda item 1.2. The flexibility 

aspect can be deceptive in that it can also introduce regulatory 

uncertainty. For example if the duplex direction is not 

specified, deployed solutions could have different rules where 

transmission could be adjacent in frequency to receivers. This 

lowers overall network performance and creates confusion and 

dissatisfaction with the offered services. 

Wireless service 

provider (strongly 

agree) 

Spectrum harmonization internationally is critical to economies 

of scale. 

Source: GAO survey. 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 114 GAO-12-118 Commercial Spectrum 

FCC should revise Parts 74, 78, and 101 of its rules to allow for increased 

spectrum sharing among compatible point-to-point microwave services. 

Many wireless providers increasingly rely on microwave to connect their 

wireless infrastructure to the telephone network (referred to as “wireless 

backhaul”), especially in rural areas. Therefore, FCC should take steps to 

ensure that sufficient microwave spectrum is available to meet current 

and future demand for wireless backhaul, especially in the prime bands 

below 12 GHz. 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 10 1 5 11 4 31

Somewhat agree 4 3 2 3 1 13

Neither agree 

nor disagree 

0 2 1 1 1 5

Somewhat 

disagree 

0 3 1 2 0 6

Strongly 

disagree 

1 3 0 2 0 6

Total 15 12 9 19 6 61

Source: GAO survey. 

National Broadband 

Plan 

Recommendations 

Aimed at Enhancing 

the Usefulness of 

Spectrum for Wireless 

Backhaul 

Revise Rules to Allow for 

Increased Spectrum 

Sharing 

Recommendation 

Rationale 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 115 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (somewhat 

disagree) 

Strong interference standards must be established and 

adhered to in order to safeguard the respective services and 

maximize interference protection. 

Expert (strongly 

disagree) 

Secondary markets, not FCC rules, can handle sharing more 

efficiently. 

Expert (strongly agree) Wireless backhaul enables progression of cyberspace/ 

broadband into rural and unserved areas and thus is 

commendable; the technology has been available for a 

decade. Sustainment after government loans is the key issue. 

Wireless device 

manufacturer (strongly 

agree) 

90 percent of backhaul in europe and uk is microwave. we 

need flexibility and we need competition in special access as it 

is a monopoly today and limited in speed to T1 ‘s mostly. 

Wireless device 

manufacturer (strongly 

agree) 

Also need dedicated licenses, but increasing access to bands 

is good. 

Wireless service 

provider (strongly 

agree) 

We support the FCC proposal to make an additional 750 MHz 

available for Fixed Service by allowing sharing with bands 

reserved for Broadcast Auxiliary Service and Cable TV relay 

service. We would note that formalized frequency coordination 

procedures will be necessary for operations within this band to 

ensure non-interference. 

Source: GAO survey. 

FCC’s progress and experts’ and stakeholders’ satisfaction with FCC’s 

progress are described under the following recommendation, which FCC 

is implementing jointly with this recommendation. 

FCC should revise its rules to allow for greater flexibility and costeffectiveness in deploying wireless backhaul. 

FCC’s Part 101 microwave rules are intended to enable a high level of 

service reliability, but they may also limit deployment flexibility in 

coverage- or capacity-limited situations. Therefore, the FCC should 

commence a proceeding to update these rules to reduce the cost of 

backhaul in capacity-limited urban areas and range-limited rural areas. 

Expert and Stakeholder 

Comments on the 

Recommendation 

FCC’s Progress on 

Implementing the 

Recommendation through 

May 2011 

Revise Rules to Allow for 

Greater Flexibility and 

Cost-Effectiveness 

Recommendation 

Rationale 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 116 GAO-12-118 Commercial Spectrum 

Level of 

agreement 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Strongly agree 12 2 6 13 3 36

Somewhat agree 4 2 3 3 2 14

Neither agree 

nor disagree 

0 3 0 1 1 5

Somewhat 

disagree 

0 2 0 0 1 3

Strongly 

disagree 

0 1 0 2 0 3

Total 16 10 9 19 7 61

Source: GAO survey. 

Type of commenter 

(level of agreement) Comment excerpts 

Broadcaster (somewhat 

disagree) 

Any action in pursuit of this recommendation should thoroughly 

study and address interference issues and require adequate 

protection standards. 

Expert (somewhat 

agree) 

However, I advise the FCC to consider public interest versus 

private interest. It is not the FCC’s job to enhance profits of big 

incumbents under the guise of cost-effectiveness. I like profits 

... but the argument needs to be for competition to improve 

quality while keeping costs low vs one size fits all solution that 

only one or two big incumbents can supply. 

Expert (strongly agree) I agree in the respect that wireless backhaul is critical for future 

services. 

Mobile Satellite 

Services company 

(somewhat disagree) 

Part 101 prior coordination rules must be retained to protect 

incumbent licensees. The Commission should not allow 

operation of distributed radiating elements (DREs) as 

proposed by Wireless Strategies Inc without part 101 

frequency coordination. 

Wireless device 

manufacturer (strongly 

agree) 

The government should consider what Australia is doing with 

NBN. 

Source: GAO survey. 

Expert and Stakeholder 

Respondents’ Level of 

Agreement with the 

Recommendation 

Expert and Stakeholder 

Comments on the 

Recommendation 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 117 GAO-12-118 Commercial Spectrum 

In August 2010, FCC issued an NPRM and a Notice of Inquiry proposing 

to remove regulatory barriers to the use of microwave spectrum for 

wireless backhaul, in order to increase flexibility, capacity, and costeffectiveness of microwave bands.7

Level of 

satisfaction 

 Stakeholders 

Experts Broadcasters

Wireless 

device 

manufacturers 

Wireless 

service 

providers Others Total

Very satisfied 2 0 3 1 0 6

Somewhat 

satisfied 

7 2 2 7 2 20

Neither satisfied 

nor dissatisfied 

2 0 1 5 0 8

Somewhat 

dissatisfied 

1 0 1 0 1 3

Strongly 

dissatisfied 

0 0 0 0 1 1

Total 12 2 7 13 4 38

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or somewhat agreed with both 

recommendations on wireless backhaul. 

 

7

Subsequent to our survey, in August 2011 FCC issued a Report and Order, Further 

Notice of Proposed Rulemaking, and Memorandum Opinion and Order in its Wireless 

Backhaul proceeding [Amendment of Part 101 of the Commission’s Rules to Facilitate the 

Use of Microwave for Wireless Backhaul and Other Uses and to Provide Additional 

Flexibility to Broadcast Auxiliary Service and Operational Fixed Microwave Licensees; 

Petition for Rulemaking filed by Fixed Wireless Communications Coalition to Amend Part 

101 of the Commission’s Rules to Authorize 60 and 80 MHz Channels in Certain Bands 

for Broadband Communications, Report and Order, Further Notice of Proposed 

Rulemaking, and Memorandum Opinion and Order, FCC 11-120, 53 Comm. Reg. (P&F) 

1099, 2011 LEXIS 3243 (rel. Aug. 9, 2011)]. By this action, FCC updated its rules to (1) 

permit fixed microwave operation in several spectrum bands previously reserved for 

specialized microwave services, (2) enable microwave licensees to take advantage of the 

latest technology to maintain the reliability of critical links, and (3) provide broadcasters 

with increased flexibility to use fixed microwave links. FCC also sought comment on 

additional proposals for making microwave communications more flexible and costeffective. 

FCC’s Progress on 

Implementing the 

Recommendation through 

May 2011 

Expert and Stakeholder 

Respondents’ Level of 

Satisfaction with FCC’s 

Progress 
Appendix III: Expert and Stakeholder 

Respondents’ Views on FCC’s Plans and 

Recent Actions to Meet Future Spectrum 

Needs 

Page 118 GAO-12-118 Commercial Spectrum 

Type of commenter 

(level of satisfaction) Comment excerpts 

Wireless service 

provider (somewhat 

satisfied) 

The speed of the rulemaking proceeding is a concern. Item is 

not that controversial and we are still awaiting an order after 

almost a year. 

Wireless service 

provider (somewhat 

satisfied) 

While in general flexibility is desirable in spectrum 

management, the FCC should ensure that its rules do not 

create new interference or efficiency concerns, e.g., the harms 

of using auxiliary stations outweigh their benefits. 

Source: GAO survey. 

Expert and Stakeholder 

Comments on FCC’s Progress 
Appendix IV: GAO Contact and Staff 

Acknowledgments 

Page 119 GAO-12-118 Commercial Spectrum 

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

In addition to the individual named above, Michael Clements, Assistant 

Director; Eli Albagli; Richard Brown; Stephen Brown; Sharon Dyer; 

David Goldstein; Josh Ormond; Kelly Rubin; Andrew Stavisky; Hai Tran; 

and Mindi Weisenbloom made key contributions to this report. 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(543275)
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