SPECTRUM 

MANAGEMENT

Federal Government’s Use 

of Spectrum and 

Preliminary Information on 

Spectrum Sharing

Statement of Mark L. Goldstein, Director 

Physical Infrastructure Issues

Testimony 

Before the Subcommittee on 

Communications and Technology, 

Committee on Energy and Commerce, 

House of Representatives 

For Release on Delivery 

Expected at 10:15 a.m. EDT

Thursday, September 13, 2012

GAO-12-1018T

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-1018T, a testimony 

before the Subcommittee on Communications 

and Technology, Committee on Energy and 

Commerce, House of Representatives

September 13, 2012

SPECTRUM MANAGEMENT

Federal Government’s Use of Spectrum and 

Preliminary Information on Spectrum Sharing

Why GAO Did This Study

Demand for spectrum is increasing 

rapidly with the widespread use of 

wireless broadband devices and 

services. However, nearly all usable 

spectrum has been allocated either by 

NTIA for federal use or by the Federal 

Communications Commission (FCC) 

for commercial and nonfederal use. 

Federal initiatives are under way to

identify federal spectrum that could be 

repurposed or possibly shared by 

federal users or wireless broadband

providers and other nonfederal users. 

This statement discusses how NTIA 

manages spectrum to address

governmentwide spectrum needs and

the steps NTIA has taken to repurpose 

spectrum for broadband. As part of an 

ongoing review, the statement also 

discusses preliminary information on 

the factors that prevent spectrum

sharing and actions that can 

encourage sharing and efficient 

spectrum use. This testimony is based 

on GAO’s prior work on federal 

spectrum management and ongoing 

work on spectrum sharing. GAO 

analyzed NTIA processes, policies and 

procedures, and interviewed relevant 

government officials, experts, and 

industry stakeholders. 

What GAO Recommends

In April 2011, GAO recommended that 

NTIA (1) evaluate its current approach 

for validating agency-reported data and 

(2) establish internal controls for its 

data management systems. NTIA 

concurred with the recommendations 

and has proposed approaches to 

implement new measures to better 

ensure the accuracy of agencyreported data, and is taking steps to 

implement internal controls in a costefficient manner. GAO provided a draft 

of this statement to FCC and NTIA.

What GAO Found

The National Telecommunications and Information Administration (NTIA) is 

responsible for governmentwide federal spectrum management, but GAO 

reported in 2011 that NTIA’s efforts in this area had been limited. In 2003, the 

President directed NTIA to develop plans identifying federal and nonfederal 

spectrum needs, and in 2008, NTIA issued the federal plan. GAO found it did not 

identify governmentwide spectrum needs and did not contain key elements and 

conform to best practices for strategic planning. Furthermore, NTIA’s primary 

spectrum management operations do not focus on governmentwide needs. 

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

focuses on mitigating interference among spectrum users, with limited emphasis 

on overall spectrum management. Additionally, NTIA’s data management system 

is antiquated and lacks internal controls to ensure the accuracy of agencyreported data, making it unclear if reliable data inform decisions about federal 

spectrum use. NTIA is developing a new data management system, but 

implementation is years away.

Despite these limitations, NTIA has taken steps to identify spectrum that could 

potentially be made available for broadband use. For example, in 2010 NTIA 

evaluated various spectrum bands and identified 115 megahertz of spectrum that 

could be repurposed within the next 5 years. In doing so, NTIA worked with a 

special steering group consisting of the Assistant Secretaries with spectrum 

management oversight in agencies that were the major stakeholders in the 

spectrum bands under consideration. For each of the identified bands, NTIA 

reviewed the number of federal frequency assignments within the band, the types 

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

geographic location of federal use.

In addition to efforts to repurpose spectrum, industry stakeholders have also 

suggested that sharing spectrum between federal and nonfederal users be 

considered to help make spectrum available for broadband. Our ongoing work 

has identified several barriers that limit sharing. Primarily, many users may lack 

incentives to share assigned spectrum. Typically, paying the market price for a 

good or service helps to inform users of the value of the good and provides an 

incentive for efficient use. But federal agencies pay only a small fee to NTIA for 

spectrum assignments, and may, in some contexts, have little incentive to 

conserve or share it. Federal agencies may also have limited budgets to upgrade 

to more spectrally-efficient equipment that would better enable sharing. 

Nonfederal users are also reluctant to share spectrum. For instance, license 

holders may be reluctant because of concerns that spectrum sharing could 

encourage competition. A lack of information on federal spectrum use may limit 

users’ ability to easily identify spectrum suitable for sharing.

GAO’s ongoing work suggests that some actions might provide greater 

incentives and opportunities for more efficient spectrum use and sharing. These 

actions could include assessing spectrum usage fees to provide economic 

incentive for more efficient use and sharing, expanding the availability of 

unlicensed spectrum, and increasing the federal focus on research and 

development of technologies that can enable spectrum sharing and improve 

spectral efficiency. However, all of these actions also involve challenges and may 

require further study.

View GAO-12-1018T. For more information, 

contact Mark L. Goldstein at (202) 512-2834 

or goldsteinm@gao.gov.
 

Page 1 GAO-12-1018T 

Chairman Walden, Ranking Member Eshoo, and Members of the 

Subcommittee:

Thank you for the opportunity to testify today on issues related to 

spectrum management and spectrum sharing practices in the United 

States. Radio frequency spectrum enables wireless communications 

services critical to the U.S. economy and a variety of government 

functions, such as scientific research and national defense. Spectrum 

capacity is necessary to deliver wireless broadband to consumers and 

businesses and broadband deployment stimulates economic growth and 

boosts the nation’s capabilities in areas such as education and health 

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

broadband services, the demand for spectrum has increased and 

additional capacity will be needed. However, nearly all usable spectrum 

has been allocated either by the National Telecommunications and 

Information Administration (NTIA) for federal government use or by the 

Federal Communications Commission (FCC) for commercial and other 

nonfederal use. Virtually no “green fields” of spectrum are currently 

available to allocate to new uses or technologies.

Currently, federal government initiatives are under way to identify 

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

demand for commercial wireless broadband services. In particular, the 

National Broadband Plan recommended that 500 megahertz (MHz) of 

spectrum be made newly available for broadband use within the next 10 

years,1 and in June 2010, the President issued a memorandum directing 

NTIA to begin identifying federal spectrum that can be made available for 

wireless broadband.2

 

1

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

Communications Commission, Connecting America: The National Broadband Plan, p. 84, 

Recommendation 5.8, (Mar. 16, 2010)

Solutions geared toward greater sharing of 

spectrum among users—federal and nonfederal—have become attractive 

because of the potential access to more spectrum and opportunities to 

use spectrum more efficiently that sharing presents. The President’s 

Council of Advisors on Science and Technology (PCAST) recommended 

2

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

 
 

Page 2 GAO-12-1018T 

that 1,000 MHz of spectrum previously occupied only by federal users be 

shared with nonfederal users.3

Based on our April 2011 report, my testimony today discusses NTIA’s 

spectrum management to address governmentwide spectrum needs and 

the steps NTIA has taken to repurpose spectrum for broadband.4 Based 

on an ongoing review, I will also discuss our preliminary information on 

the factors that prevent spectrum sharing and actions that might be taken 

to encourage sharing and efficient spectrum use. We plan to issue a 

report on these issues in fall 2012. In conducting our work, we reviewed 

NTIA documents, including its Manual of Regulations and Procedures for 

the Federal Radio Frequency Management (commonly referred to as the 

Redbook); an assessment of spectrum bands that could possibly be 

repurposed for wireless broadband (referred to as the Fast Track 

Evaluation); and other documentation of NTIA’s current processes, 

policies, and procedures. We interviewed officials from NTIA’s Office of 

Spectrum Management about their spectrum management policies and 

procedures and interviewed stakeholders with knowledge of spectrum 

issues including industry and academic experts, and representatives of 

an industry association and telecommunications companies. We selected 

the experts and industry stakeholders based on prior published literature, 

stakeholders’ recognition and affiliation with the spectrum management 

industry, and NTIA and other stakeholders’ recommendations. We also 

reviewed federal legislation, regulations, and processes regarding 

spectrum sharing, including various FCC plans, notices, orders and other 

publications. We conducted interviews with officials from FCC, NTIA, and 

various advisory committees, including the Commerce Spectrum 

Management Advisory Committee (CSMAC).5

 

3

President’s Council of Advisors on Science and Technology, Report to the President; 

Realizing the Full Potential of Government-held Spectrum to Spur Economic Growth

(Washington, D.C.: July 2012).

We also interviewed 

several agencies on the Interdepartment Radio Advisory Committee 

4

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.: April 12, 2011).

5

CSMAC is a federal advisory committee that provides advice and recommendations to 

NTIA. It is organized through NTIA’s Office of Policy Analysis and Development and 

consists of approximately 25 spectrum policy experts from the private sector. 
 

Page 3 GAO-12-1018T 

(IRAC).6 Additional information on our scope and methodology is 

provided in our 2011 report. We conducted our work related to federal 

management and use of spectrum from May 2010 to April 2011 and our 

work related to spectrum sharing from September 2011 to September 

2012. All of our work was conducted in accordance with generally 

accepted government auditing standards. We provided a draft of this 

statement related to spectrum sharing to FCC and NTIA officials to obtain 

their comments. FCC and NTIA provided technical corrections, which we 

incorporated where appropriate. 

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

electromagnetic radiation lying between the frequency limits of 3 kilohertz 

(kHz) and 300 gigahertz (GHz). Not all spectrum has equal value. The 

spectrum most highly valued generally consists of frequencies between 

225 MHz and 3700 MHz, as these frequencies have properties well suited 

to many important wireless technologies, such as mobile phones, radio, 

and television broadcasting. According to NTIA, as of September 2012, 

federal agencies had exclusive access to about 18 percent of these highvalue frequencies, and nonfederal users had exclusive licenses to about 

33 percent. The remainder of this spectrum is allocated to shared use. 

However, in many cases in these shared bands, federal or nonfederal 

uses may dominate and actual sharing is nominal. NTIA has concluded 

that overall, approximately 43 percent of these high-value frequencies are 

predominantly used by federal operations.

Federal agencies use spectrum to help meet a variety of missions, 

including emergency communications, national defense, land 

management, and law enforcement. Over 60 federal agencies and 

departments combined have over 240,000 frequency assignments. 

Agencies and departments within the Department of Defense have the 

most assignments, followed by the Federal Aviation Administration, the 

Department of Justice, the Department of Homeland Security, the 

Department of the Interior, the Department of Agriculture, U.S. Coast 

Guard, the Department of Energy, and the Department of Commerce, 

respectively. These federal agencies and departments hold 94 percent of 

 

6

IRAC is an interagency advisory committee that was established in 1922 to coordinate 

federal use of spectrum and provide policy advice on spectrum issues. It is comprised of 

representatives from 19 federal agencies that use spectrum. Those agencies hold over 90 

percent of federally assigned spectrum.

Background 
 

Page 4 GAO-12-1018T 

all federally assigned spectrum. Nonfederal entities (which include 

commercial companies and state and local governments) also use 

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

police departments, fire departments, and other emergency services 

agencies use spectrum to transmit and receive critical voice and data 

communications, while commercial entities use spectrum to provide 

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

radio and television, and satellite services (see fig. 1).

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

In the United States, responsibility for spectrum management is divided 

between NTIA and FCC. NTIA and FCC jointly determine the amount of 

spectrum allocated for federal, nonfederal, and shared use. After this 

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

Page 5 GAO-12-1018T 

rules and obtain authorizations from FCC to use specific spectrum 

frequencies, and federal users must follow rules and obtain frequency 

assignments from NTIA. In order for nonfederal users to share federal 

spectrum, NTIA and FCC are jointly involved in the process. The 

nonfederal party petitions FCC, and FCC in turn coordinates rulemakings 

and licenses with NTIA through IRAC. NTIA manages sharing between 

federal users on a day-to-day basis. If federal users are requesting 

frequency assignments in exclusive nonfederal or shared bands, that 

request is coordinated through IRAC with FCC. If sharing is solely 

between nonfederal users in exclusive nonfederal bands, sharing is 

generally governed by FCC rules and does not go through NTIA, unless 

there could be out-of-band interference. In addition to its spectrum 

allocation and authorization duties, NTIA serves as the President’s 

principal advisor on telecommunications and information policy and 

manages federally assigned spectrum, including preparing for, 

participating in, and implementing the results of international radio 

conferences, as well as conducting extensive research and technical 

studies through its research and engineering laboratory, the Institute for 

Telecommunication Sciences. NTIA has authority to issue rules and 

regulations as may be necessary to ensure the effective, efficient, and 

equitable use of spectrum both nationally and internationally. It also has 

authority to develop long-range spectrum plans to meet future spectrum 

requirements for the federal government.

Spectrum sharing can be defined as the cooperative use of common 

spectrum. In this way, multiple users agree to access the same spectrum 

at different times or locations, as well as negotiate other technical 

parameters, to avoid adversely interfering with one another. For sharing 

to occur, users and regulators must negotiate and resolve where 

(geographic sharing), when (sharing in time), and how (technical 

parameters) spectrum will be used (see fig. 2).
 

Page 6 GAO-12-1018T 

Figure 2: Illustration and Examples of Spectrum Sharing

Spectrum sharing also occurs with unlicensed use of spectrum, since it is 

accessible to anyone using wireless equipment certified by FCC for those 

frequencies. Equipment such as wireless microphones, baby monitors, 

and garage door openers typically share spectrum with other services on 

a non-interference basis using low power levels to avoid interference with 

higher priority uses. In contrast with most licensed spectrum use, 

unlicensed spectrum users have no regulatory protection against 

interference from other licensed or unlicensed users in the band. 

However, unlicensed use is regulated to ensure that unlicensed devices 

do not cause undue interference to operations with a higher priority. For 

example, in the 5 GHz band, wireless fidelity (Wi-Fi) devices share a 

band with military radar subject to the condition that the Wi-Fi devices are 

capable of spectrum sensing and dynamic frequency selection; if radar is 

detected, the unlicensed user must immediately vacate the channel.
 

Page 7 GAO-12-1018T 

As the federal agency authorized to develop national spectrum policy, 

NTIA has been directed to conduct several projects focused on reforming 

governmentwide federal spectrum management and promoting efficiency 

among federal users of spectrum; however, we reported in 2011 that its 

efforts in this area had resulted in limited progress toward improved 

spectrum management. NTIA has authority to, among other things, 

establish policies concerning assigning spectrum to federal agencies, 

coordinate spectrum use across federal agencies, and promote efficient 

use of spectrum by federal agencies in a manner which encourages the 

most beneficial public use. As such, NTIA has a role in ensuring that 

federally allocated spectrum is used efficiently. According to NTIA’s 

Redbook and agency officials, efficient use includes ensuring that federal 

agencies’ decisions to use spectrum to support government missions 

have been adequately justified and that all viable tradeoffs and options 

have been explored before making the decision to use spectrumdependent technology, and ensuring that these tradeoffs are continuously 

reviewed to determine if the need for spectrum has changed over time. 

NTIA’s primary guidance to federal agencies is technical guidance 

provided through NTIA’s Redbook concerning how to manage assigned 

spectrum.

In 2003, the Bush Administration directed NTIA to develop strategic 

plans, and in March 2008, NTIA issued its report on federal spectrum use 

entitled the Federal Strategic Spectrum Plan.

7

 

7

Department of Commerce, National Telecommunications and Information Administration, 

Spectrum Policy for the 21st Century – The President’s Spectrum Policy Initiative: The 

Federal Strategic Spectrum Plan (March 2008). 

While the intent of the 

Federal Strategic Spectrum Plan was to identify the current and projected 

spectrum requirements and long-range planning processes for the federal 

government, we reported in 2011 that the final plan is limited in these 

NTIA’s Processes for 

Managing Federal 

Spectrum Lack 

Governmentwide 

Focus and 

Accountability 

NTIA’s Spectrum 

Management Efforts
 

Page 8 GAO-12-1018T 

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

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

primarily consists of a compilation of the plans submitted by 15 of the 

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

fact that they contained limited information regarding future requirements 

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

are necessarily also limited.” Furthermore, NTIA’s plan did not contain 

key elements and best practices of strategic planning.

NTIA’s primary spectrum management operations include authorizing 

federal frequency assignments and certifying spectrum-dependent 

equipment for federal users; however, these processes are primarily 

focused on interference mitigation as determined by IRAC and do not 

focus on ensuring the best use of spectrum across the federal 

government. In 2011, we found that the process as established by federal 

regulations for review and approval of frequency assignment and system 

certification was technical in nature, focusing on ensuring that the new 

frequency or system that an agency wants to use would not interfere with 

another agency’s operations. According to NTIA officials, this focus on 

day-to-day spectrum activities, such as interference mitigation, is due to 

the agency’s limited resources. This focus, while important, makes limited 

consideration about the overall best use of federally allocated spectrum. 

Therefore, NTIA’s current processes provide limited assurance that 

federal spectrum use is evaluated from a governmentwide perspective to 

ensure that decisions will meet the current and future needs of the 

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

NTIA’s data management system is antiquated and lacks transparency 

and internal controls. In 2011, we reported that NTIA collects all federal 

spectrum data in the Government Master File (GMF), which according to 

NTIA officials is an outdated legacy system that was developed primarily 

to store descriptive data. These data are not detailed enough to support 

the current analytical needs of NTIA or other federal users, as the system 

was not designed to conduct such analyses. NTIA does not generate any 

data, but maintains agency-reported spectrum data in the GMF, which are 

collected during the frequency assignment and review processes.

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

controls, including those focused on data accuracy, integrity, and 

completeness. Control activities such as data verification and 

reconciliation are essential for ensuring accountability for government 

NTIA Focuses on 

Interference Mitigation 

Rather than on Best Use of 

Spectrum across 

Government

NTIA’s Current Data 

Management System Is of 

Limited Usefulness
 

Page 9 GAO-12-1018T 

resources and achieving effective and efficient program results. In 2011, 

we reported that NTIA’s data collection processes lack accuracy controls 

and do not provide assurance that data are being accurately reported by 

agencies. Rather, NTIA expects federal agencies to supply accurate and 

up-to-date data submissions, but it does not provide agencies with 

specific requirements on how to justify that the agencies’ spectrum 

assignments will fulfill their mission needs.

NTIA is developing a new data management system—the Federal 

Spectrum Management System (FSMS)—to replace the GMF. According 

to NTIA officials, the new system will modernize and improve spectrum 

management processes by applying modern information technology to 

provide more rapid access to spectrum and make the spectrum 

management process more effective and efficient. NTIA projects that 

FSMS will improve existing GMF data quality, but not until 2018. 

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

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

whether important decisions regarding current and future spectrum needs 

are based on reliable data.

In response to the government initiatives to make a total of 500 MHz of 

spectrum available for wireless broadband, in 2010 NTIA (1) identified 

115 MHz of federally allocated spectrum to be made available for wireless 

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

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

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

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

(PPSG)8

 

8

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

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

under consideration. 

identified and recommended portions of two frequency bands, 

NTIA Has Taken Steps 

to Identify Spectrum 

for Future Wireless 

Broadband Use 

NTIA Efforts to Identify 

Spectrum for Broadband
 

Page 10 GAO-12-1018T 

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

3550–3650 MHz to be made available for wireless broadband use.9

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

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

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

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

identifying and making available the 500 MHz for broadband use.

For 

each of these bands, NTIA reviewed the number of federal frequency 

assignments within the band, the types of federal operations and 

functions that the assignments support, and the geographic location of 

federal use. Since clearing these bands of federal users and relocating 

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

frame, the bands that NTIA recommended be made available will be 

opened to geographic sharing by incumbent federal users and 

commercial broadband.

10 NTIA 

publicly released this report in November 2010.11

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

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

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

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

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

years. This is not the first time NTIA has studied this band. This band was

In total, NTIA and the 

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

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

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

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

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

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

from CSMAC, its federal advisory committee comprised of industry 

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

Plan.

 

9

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

its analysis of four frequency bands: 1675–1710 MHz, 1755–1780 MHz, 3500–3650 MHz, 

and 4200–4400 MHz.

10 Unleashing the Wireless Broadband Revolution, 75 Fed. Reg. 38387. 

11NTIA, 10 Year Plan and Timetable to Make Available 500 MHz of Spectrum for Wireless 

Broadband (2010). 
 

Page 11 GAO-12-1018T 

previously evaluated for reallocation, and in 2001, we reported that at the 

time adequate information was not currently available to fully identify and 

address the uncertainties and risks of reallocation.12

Industry stakeholders, including wireless service providers, 

representatives of an industry association, and a think tank representative 

we contacted in 2011 expressed concerns over the usefulness of the 

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

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

considered to have the best propagation characteristics for mobile 

broadband. Overall, there has been limited interest in the bands above 3 

GHz for mobile broadband use because, according to industry 

stakeholders, there has been minimal development of mobile broadband 

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

time.

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

NTIA considered as part of the Fast Track Evaluation has the best 

characteristics for mobile broadband use, and it is internationally 

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

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

users currently operating there. However, NTIA identified it as the first 

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

made available for commercial broadband use. An industry stakeholder 

has stated that the 1695–1710 MHz band identified by NTIA in the Fast 

Track Evaluation is the second-best alternative for wireless broadband if 

the 1755–1780 MHz band were not made available; however, the 1695–

1710 MHz band is not currently used internationally for wireless 

broadband, which may reduce device manufacturers’ incentive for 

developing technology that can be used in these frequencies.

 

12GAO, Defense Spectrum Management: More Analysis Needed to Support Spectrum 

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

2001). 

Industry Concerns with the 

Usefulness of the 

Identified Spectrum
 

Page 12 GAO-12-1018T 

While federal spectrum users often share spectrum among themselves, 

they may have little economic incentive to otherwise use spectrum 

efficiently, including sharing it with nonfederal users. From an economic 

perspective, when a consumer pays the market price for a good or 

service and thus cannot get more of it without this expense, the consumer 

has an incentive to get the most value and efficiency out of the good as 

possible. If no price is attached to a good—which is essentially the case 

with federal agencies’ use of spectrum13

While licensed, commercial users who purchased spectrum at auction 

generally have market incentives to use their spectrum holdings 

—the normal market incentive to 

use the good efficiently may be muted. In the case of federal spectrum 

users, obtaining new spectrum assignments may be difficult, so an 

agency may have an incentive to conserve and use the spectrum it 

currently has assigned to it or currently shares efficiently, but the extent of 

that incentive is likely weaker than if the agency had had to pay a market 

price for the all of their spectrum needs. As such, federal spectrum users 

do not fully face a market incentive to conserve on their use of spectrum 

or use it in an efficient manner. The full market value of the spectrum 

assigned to federal agencies has not been assessed, but, according to 

one expert, would most likely be valued in the tens of billions of dollars. 

Similarly, many nonfederal users, such as television broadcasters and 

public safety entities, did not pay for spectrum when it was assigned to 

them and do not pay the full market price for their continuing use of 

spectrum so, like federal agencies, they may not fully have market-based 

incentives to use spectrum efficiently.

 

13Agencies pay only a small, annual fee for their spectrum which is not comparable to its 

full market value. According to NTIA, federal agencies pay $122 for each frequency 

assignment, totaling about $30 million paid by 47 agencies to NTIA for fiscal year 2012.

Some Users Lack 

Incentives and Face 

Several Barriers to 

Sharing Spectrum, 

and Cannot Easily 

Identify Available 

Spectrum to Share

Some Users Lack 

Economic Incentives to 

Share Spectrum
 

Page 13 GAO-12-1018T 

efficiently, these users also have incentives that work against sharing 

spectrum, except in those instances where the incumbent licensee is 

unlikely to build out its network or offer services to a particular area, such 

as in certain remote, sparsely populated areas. FCC officials and industry 

stakeholders and experts told us that these users may prefer not to share 

their unused spectrum because they are concerned about the potential 

for interference to degrade service quality to their customers. Also, they 

may prefer to not give potential competitors access to spectrum. Industry 

stakeholders and experts also said that companies seeking spectrum 

may prefer obtaining exclusive spectrum licenses over sharing spectrum 

that is licensed to another company or federal user, given uncertainties 

about regulatory approvals, interference, and enforcement if interference 

occurs.

There are several barriers that can deter sharing. One such barrier is that 

federal agencies will not risk mission failure, particularly when there are 

security and public safety implications. According to the agency officials 

we contacted, federal agencies will typically not agree to share spectrum 

if it puts achieving their missions at risk. The officials stressed that when 

missions have security and safety implications, sharing may pose 

unacceptable risks. For example, the military tests aircraft and trains 

pilots over test ranges that can stretch hundreds of miles, maintaining 

constant wireless contact. The ranges, according to officials, cannot 

share the communication frequencies because even accidental 

interference in communications with an aircraft could result in 

catastrophic mission failure. Further, sharing information about such 

flights could expose particular pilots and aircraft, or the military’s larger 

mission, to increased risk.

According to FCC officials, concerns about risk can drive conservative 

technical standards that can make sharing impractical. In general, the 

technical analyses and resulting standards are based on worst-case 

scenarios, and not on assessments of the most likely scenario or a range 

of scenarios. Moreover, in contrast to FCC’s open rulemaking process, 

there is little opportunity for public input to the standards setting process. 

Stakeholders may meet or have discussions with NTIA and the relevant 

federal agencies, but this occurs without any formal public process. Nor 

do stakeholders have any effective means to appeal other than by asking 

FCC to reject NTIA’s analysis or standards.

Several Barriers Can Deter 

Users from Sharing 

Spectrum 
 

Page 14 GAO-12-1018T 

Another barrier is that spectrum sharing can be costly. Stakeholders told 

us that sharing federal spectrum can be costly for both the nonfederal and 

federal users seeking to share for the following reasons:

• Mitigation of potential interference can be costly in terms of equipment 

design and operation.

• Users applying to share federal frequencies may find that those 

frequencies are being used by more than one federal agency or 

program. As a result of needing to mitigate inference for multiple 

users, costs to share spectrum in that band could increase. 

• Federal users often use and rely on proven older technology that was 

designed to use spectrum to meet a specific mission and typically is 

not conducive to operating as efficiently or flexibly as the state-of-theart technologies might now allow. Limited budgets may prevent them 

from being able to invest in newer technology which can facilitate 

easier sharing.

Additionally, we found that spectrum sharing approval and enforcement 

processes can be lengthy and unpredictable. FCC and NTIA processes 

can cause two main problems when nonfederal users seek to share 

federal spectrum, or when nonfederal users share with one another, 

according to stakeholders:

• The spectrum-sharing approval process between FCC and NTIA can 

be lengthy and unpredictable, and the risk associated with it can be 

costly for new entrants. FCC officials told us that its internal processes 

can potentially last years if requiring a rulemaking to accommodate 

shared use of spectrum.

14

 

14The time it takes to complete rules may vary because of the unique nature of each 

rulemaking. Certain factors, such as the technical complexity of the issue being addressed

and the priority of the rulemaking in comparison to other issues, can also affect 

rulemaking time frames. FCC’s rulemaking process includes multiple steps as outlined by 

law with opportunities for the public to participate, and FCC is generally not required by 

statute to complete rules within limited time frames.

In addition to that time, NTIA officials said 

that IRAC’s evaluation of potential harmful interference could take 

months. In one example, the Department of Defense, along with other 

federal agencies and nonfederal entities, currently shares a spectrum 

band between 413-457 MHz with a nonprofit medical devices provider 

for use in implant products for veterans. It took approximately 2 years 
 

Page 15 GAO-12-1018T 

(from 2009 to 2011) for FCC and NTIA to facilitate this arrangement, 

as FCC required a rulemaking and NTIA required a lengthy evaluation 

of potential interference. This nonprofit is funded by an endowment 

and was not dependent on income from the device to sustain itself 

during this process, but such delays, and the potential for a denial, 

could discourage for-profit companies from developing and investing 

in business plans that rely on sharing federal spectrum.

• Stakeholders we interviewed told us that when federal or nonfederal 

users share spectrum, both parties have concern that harmful 

interference may affect their missions or operations if the other party 

overreaches or does not follow the agreement. They also fear that the 

enforcement actions that are taken by FCC will happen too slowly to 

protect their interests or that enforcement outcomes can be 

unpredictable. 

Besides lacking incentives and overcoming other barriers, users may also 

have difficulty identifying spectrum suitable for sharing because data on 

available spectrum is incomplete or inaccurate, and information on some 

federal spectrum usage is not publicly available. According to NTIA 

officials, coordinating spectrum sharing requires accurate data on users, 

frequencies, locations, times, power levels, and equipment, among other 

things. We recently reported that both FCC’s and NTIA’s spectrum 

databases may contain incomplete and inaccurate data.15 Further, federal 

agency spectrum managers told us that agencies have not been asked to 

regularly update their strategic spectrum plans, in which they were 

required to include an accounting of spectrum use.16

As mentioned, NTIA is developing a new data system that officials believe 

will provide more robust data that will enable more accurate analysis of 

spectrum usage and potential interference, which may in turn identify 

 

15In November 2011, we reported on FCC’s Universal Licensing System, Consolidated 

Database System, International Bureau Filing System, and Experimental Licensing 

System. See GAO, Commercial Spectrum: Plans and Actions to Meet Future Needs, 

Including Continued Use of Auctions, GAO-12-118 (Washington, D.C.: November 23, 

2011). In April 2011, we reported on NTIA’s Government Master File database. See 

GAO-11-352. 

16The Bush Administration directed federal agencies to submit spectrum plans to NTIA 

and provide updates every 2 years. Since 2008, NTIA has ceased requesting those 

updates, and has put its strategic planning initiatives on hold due to limited resources.

Users May Be Unable to 

Easily Identify Spectrum 

Suitable for Sharing
 

Page 16 GAO-12-1018T 

more sharing opportunities. In addition, recently proposed legislation 

would require in part that FCC, in consultation with NTIA and the White 

House Office of Science and Technology Policy, prepare a report for 

Congress that includes an inventory of each radio spectrum band they 

manage.17 The inventory is also to include data on the number of 

transmitters and receiver terminals in use, if available, as well as other 

technical parameters—coverage area, receiver performance, location of 

transmitters, percentage and time of use, a list of unlicensed devices 

authorized to operate in the band and description of use—that allow for 

more specific evaluation of how spectrum can be shared. However, 

experts and federal officials we contacted told us that there may be some 

limitations to creating such an inventory. For instance, measuring 

spectrum usage can be difficult because it can only be accomplished on a 

small scale and technologies to measure or map widespread spectrum 

usage are not yet available.18 Additionally, FCC and NTIA officials told us 

that information on some federal spectrum bands may never be made 

publicly available because of the sensitive and classified nature of some 

federal spectrum use.

We have previously reported that to improve spectrum efficiency among 

federal agencies, Congress may wish to consider evaluating what 

mechanisms could be adopted to provide incentives and opportunities for 

agencies to move toward more efficient use of spectrum, which could free 

up some spectrum allocated for federal use to be made available for 

sharing or other purposes.19

 

17S, 455, § 3, 112th Cong. (2011). 

Federal advisors and experts we talked to 

identified several options that could provide incentives and opportunities 

for more efficient spectrum use and spectrum sharing by federal and 

nonfederal users, which include, among others: (1) assessing spectrum 

usage fees; (2) expanding the availability of spectrum for unlicensed 

uses; and (3) increasing the federal focus on research and development 

of technologies that can enable spectrum sharing and improve spectral 

efficiency.

18The Department of Defense’s Defense Advanced Research Projects Agency is working 

on frequency mapping.

19GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington, 

D.C.: February 28, 2012).

Incentives and 

Opportunities to 

Share Could Be 

Expanded 
 

Page 17 GAO-12-1018T 

Assessing spectrum usage fees. Several advisory groups and spectrum 

industry experts, including those we interviewed, have recommended that 

spectrum fees be assessed based on spectrum usage. As previously 

mentioned, with the exception of administrative fees for frequency 

assignments, federal users incur no costs for using spectrum. As such, 

federal users may have little incentive to share spectrum assigned to 

them with nonfederal users or identify opportunities to use spectrum more 

efficiently—except to the extent that sharing or more efficient use helps 

them achieve their mission requirements. In 2011, the CSMAC Incentives 

Subcommittee recommended that NTIA and FCC study the 

implementation of spectrum fees to drive greater efficiency and solicit 

input from both federal and nonfederal users who might be subject to 

fees.20 The National Broadband Plan has also recommended that 

Congress consider granting FCC and NTIA authority to impose spectrum 

fees on unauctioned spectrum license holders—such as TV broadcasters 

and public safety entities—as well as government users. Fees may help 

to free spectrum for new uses, since licensees who use spectrum 

inefficiently may reduce their holdings or pursue sharing opportunities 

once they bear the opportunity cost of letting it remain fallow or 

underused. Further, FCC officials told us that they have proposed 

spectrum usage fees at various times, including in FCC’s most recent 

congressional budget submission, and requested the legislative 

authorities to implement such a program.21

While noting the benefits, the CSMAC Incentives Subcommittee report 

mentions specific concerns about the impact of spectrum fees on 

government users. For instance, some CSMAC members expressed 

concern that fees do not fit into the federal annual appropriations process 

and new appropriations to cover fees are neither realistic nor warranted in 

the current budget environment. Other members suggested that fees will 

have no effect because agencies will be assured additional funds for their 

spectrum needs. Similarly, the National Broadband Plan notes that a 

different approach to setting fees may be appropriate for different 

spectrum users, and that a fee system must also avoid disrupting public 

 

20CSMAC Incentives Subcommittee Final Report (Washington, D.C.: January 11, 2011).

21Federal Communications Commission, Fiscal Year 2013 Budget Estimates Submitted to 

Congress (Washington, D.C.: February 2012).
 

Page 18 GAO-12-1018T 

safety, national defense, and other essential government services that 

protect human life, safety, and property.22

To address some of the concerns regarding agency budgets, the recent 

PCAST report recommended the use of a “spectrum currency” process to 

promote spectrum efficiency. Rather than using funds to pay for 

spectrum, federal agencies would each be given an allocation of synthetic 

currency that they could use to “buy” their spectrum usage rights. Usage 

fees would be set based on valuations of comparable private sector uses 

for which the market has already set a price. Agencies would then have 

incentive to use their assignments more efficiently or share spectrum. In 

the PCAST proposal, agencies would also be rewarded for making 

spectrum available to others for sharing, by being reimbursed for their 

investments in improving spectrum sharing from a proposed Spectrum 

Efficiency Fund.23

Expanding the availability of spectrum for unlicensed use. Unlicensed 

spectrum use is inherently shared spectrum access, and according to 

spectrum experts we interviewed and other stakeholders, unlicensed use 

of spectrum is a valuable complement to licensed spectrum and more 

spectrum could be made available for unlicensed use. Spectrum for 

unlicensed use can be used efficiently and for high value applications, like 

Wi-Fi, for example.24

 

22The National Broadband Plan, p. 83, Recommendation 5.6, (Mar. 16, 2010).

Increasing the amount of spectrum for unlicensed 

use may allow more users to share without going through lengthy 

negotiations and interference mitigations, and also allow for more 

experimentation and innovation.

23The PCAST recommended that the existing Spectrum Relocation Fund be redefined as 

a revolving Spectrum Efficiency Fund that reimburses federal agencies for investments in 

spectrum sharing and efficiency. 

24 The Industrial (900-928 MHz), Scientific (2.4 – 2.485 GHz) and Medical (5.7 – 5.825 

GHz) are examples of the unlicensed spectrum bands. Wi-Fi networks can permit multiple 

computing devices in each discrete location to share a single wired connection to the 

Internet, thus efficiently sharing spectrum. Wi-Fi technologies are also being used to 

relieve network congestion. One report suggests that major wireless carriers, even with 

their large portfolios of exclusive-use, licensed spectrum, often rely on Wi-Fi infrastructure 

to offload traffic from their networks in congested areas, as much as 21 percent by some 

accounts.
 

Page 19 GAO-12-1018T 

More recently, FCC has provided unlicensed access to additional 

spectrum, known as TV “white spaces,” to help address spectrum 

demands.25 The white spaces refer to the buffer zones that FCC assigned 

the television broadcasters to mitigate unwanted inference between 

adjacent stations. With the more efficient TV transmission capabilities that 

resulted from the digital television transition, the buffer zones are no 

longer needed and FCC approved the previously unused spectrum for 

unlicensed use. To identify available white space spectrum, devices must 

access a database which responds with a list of the frequencies that are 

available for use at the device’s location.26

Increasing the federal focus on research and development of 

technologies. Several technological advances promise to make sharing 

easier, but are still at early stages of development and testing. For 

example, various spectrum users and experts we contacted mentioned 

the potential of dynamic spectrum access technology. If made fully 

operational, dynamic spectrum access technology will be able to sense 

available frequencies in an area and jump between frequencies to 

seamlessly continue communication as the user moves geographically 

and through the spectrum. According to experts and researchers we 

contacted, progress has been made but there is no indication of how long 

it will be before this technology is fully deployable. Such new technologies 

can obviate or lessen the need for extensive regulatory procedures to 

enable sharing and can open up new market opportunities for wireless 

service providers. If a secondary user or sharing entity employs these 

technologies, the incumbent user or primary user would theoretically not 

experience harmful interference, and agreements and rulemakings that 

are currently needed may be streamlined or unnecessary to enable 

sharing.

As an example, one local 

official explained that his city uses TV white space spectrum to provide a 

network of public Wi-Fi access and public safety surveillance functions.

Although industry participants indicated that extensive testing under 

realistic conditions is critical to conducting basic research on spectrum 

 

25In the Matter of Unlicensed Operation in the TV Broadcast Bands, 27 FCC Rcd. 3,692 

(April 5, 2012). 

26To date, FCC has designated two administrators to locate available white space 

spectrum for users of unlicensed devices, Spectrum Bridge and Telecordia Technologies. 

Devices must operate only on those channels designated by the administrator. 
 

Page 20 GAO-12-1018T 

efficient technologies, we found that only a few companies are involved in 

such research and may experience challenges in the testing process. 

Companies tend to focus technology development on current business 

objectives as opposed to conducting basic research that may not show an 

immediate business return. For example, NTIA officials told us that one 

company that indicated it would participate in NTIA’s dynamic spectrum 

access testing project removed its technologist from the testing effort to a 

project more closely related to its internal business objectives. 

Furthermore, some products are too early in the development stage to 

even be fully tested. For example, NTIA officials also said six companies 

responded to NTIA’s invitation to participate in the previously mentioned 

dynamic spectrum access testing project. However, only two working 

devices were received for the testing, and a third device received did not 

work as intended. Other companies that responded told NTIA that they 

only had a concept and were not ready to test an actual prototype.

Recent federal advisory committee recommendations emphasize the 

importance of funding and providing incentives for research and 

development endeavors. For example, to promote research in efficient 

technologies, PCAST recommended that (1) the Research and 

Development Wireless Innovation Fund27 release funds for this purpose 

and (2) the current Spectrum Relocation Fund be redefined as the 

Spectrum Efficiency Fund. As discussed, this adjustment would allow for 

federal agencies to be reimbursed for general investments in improving 

spectrum sharing. Similarly, CSMAC recommended the creation of a 

Spectrum Innovation Fund. Unlike the Spectrum Relocation Fund, which 

is strictly limited to the actual costs incurred in relocating federal systems 

from auctioned spectrum bands, the Spectrum Innovation Fund could 

also be used for spectrum sharing and other opportunities to enhance 

spectrum efficiency.28 

 

27The Wireless Innovation Fund is a part of the 2012 payroll tax agreement for spectrum 

research and development. It will initially be a $100 million fund at the National Institute of 

Standards and Technology. The fund will receive an additional $200 million after approved 

auction income has been secured.

28CSMAC Incentives Subcommittee Final Report.
 

Page 21 GAO-12-1018T 

Radio frequency spectrum is a scarce national resource that enables 

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

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

governmentwide vision for managing federal use of this valuable 

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

NTIA’s focus is on the narrow technical aspects of spectrum 

management, such as ensuring new frequency assignments will not 

cause interference to spectrum-dependent devices already in use, rather 

than on whether new assignments should be approved based on a 

comprehensive evaluation of federal spectrum use from a 

governmentwide perspective. Lacking an overall strategic vision, NTIA 

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

Furthermore, agencies are not required to submit justifications for their 

spectrum use and NTIA does not have a mechanism in place to validate 

and verify the accuracy of spectrum-related data submitted by the federal 

agencies. This has led to decreased accountability and transparency in 

how federal spectrum is being used and whether the spectrum-dependent 

systems the agencies have in place are necessary. Without meaningful 

data validation requirements, NTIA has limited assurance that the 

agency-reported data it collects are accurate and complete.

In our April 2011 report, we recommended that NTIA (1) develop an 

updated plan that includes key elements of a strategic plan, as well as 

information on how spectrum is being used across the federal 

government, opportunities to increase efficient use of federally allocated 

spectrum and infrastructure, an assessment of future spectrum needs, 

and plans to incorporate these needs in the frequency assignment, 

equipment certification, and review processes; (2) examine the 

assignment review processes and consider best practices to determine if 

the current approach for collecting and validating data from federal 

agencies can be streamlined or improved; and (3) establish internal 

controls for management oversight of the accuracy and completeness of 

currently reported agency data.29

 

29

With respect to our first 

recommendation, NTIA has not developed an updated strategic plan and 

previously noted that the Presidential Memorandum of June 28, 2010, 

and the Wireless Innovation Initiative provide significant strategic direction 

for NTIA and the other federal agencies. In September 2012, NTIA

officials told us that NTIA intends to update its strategic plan by October 

GAO-11-352

Conclusions and 

Recommendations 
 

Page 22 GAO-12-1018T 

2013. NTIA concurred with our other two recommendations and is taking 

action to address them. For example, NTIA has proposed approaches to 

implement new measures to better ensure the accuracy of agencyreported data, and is taking steps to implement internal controls for its 

data management system in a cost efficient manner.

With respect to spectrum sharing, there are currently insufficient 

incentives to encourage more sharing, and even if incentives were 

created, several barriers to sharing will continue. Options to address 

these issues in turn create new challenges, and may require further 

study.

Chairman Walden, Ranking Member Eshoo, and Members of the 

Subcommittee, this concludes my prepared statement. I will be happy to 

respond to any questions you may have at this time.

For further information on this testimony, please contact me at (202) 512-

2834, or by e-mail at goldsteinm@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this statement. Individuals making key contributions to this 

testimony include Sally Moino and Andrew Von Ah, Assistant Directors; 

Amy Abramowitz; Colin Fallon; Bert Japikse; Elke Kolodinski; Maria 

Mercado; Erica Miles; and Hai Tran.

GAO Contact and 

Staff 

Acknowledgments 

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