Spectrum Management: NTIA Planning and Processes Need Strengthening to Promote the Efficient Use of Spectrum by Federal Agencies
Published: 2011-04-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Radio frequency spectrum enables vital wireless communications services used by the federal government, businesses, and consumers. Spectrum capacity is necessary for wireless broadband (high-speed Internet access) and broadband deployment will boost the nation's capabilities in many important areas. As the demand for spectrum continues to increase, there is concern about adequate access to meet future needs. This requested report examines (1) how the National Telecommunications and Information Administration (NTIA) is managing spectrum needs of federal agencies, (2) how federal agencies are using and managing assigned spectrum, and (3) what steps NTIA has taken to meet recent initiatives aimed at making spectrum available for broadband. GAO reviewed NTIA's spectrum management documents; surveyed the 19 federal agencies comprising the Interdepartment Radio Advisory Committee; and interviewed NTIA officials and industry and academic experts.
section_title: What GAO Found
paragraphs: NTIA is responsible for governmentwide federal spectrum management, but its efforts in this area have been limited. In 2003, the President directed NTIA to develop plans identifying federal and national (both federal and nonfederal) spectrum needs, and in 2008, NTIA issued the federal plan. GAO found this plan has several limitations, does not identify governmentwide spectrum needs, and does not contain key elements and best practices of strategic planning. NTIA has yet to issue the national plan. Furthermore, NTIA's primary spectrum management operations do not focus on governmentwide needs. Instead NTIA depends on agency self-evaluation of spectrum needs and focuses on interference mitigation, with limited emphasis on holistic spectrum management. Lacking a strategic vision, NTIA cannot ensure that spectrum is being used efficiently by federal agencies. Additionally, NTIA's data management system is antiquated and lacks internal controls to ensure the accuracy of agency-reported data, making it unclear if decisions about federal spectrum use are based on reliable data. NTIA is developing a new data management system, but full implementation of the system is years away. Federal agencies use spectrum for many purposes such as emergency communications and national defense, and NTIA requires the agencies to periodically evaluate their current and future spectrum needs. Agencies are supposed to ensure spectrum assignments fulfill established mission needs; however, NTIA does not have specific requirements for agencies to justify their spectrum assignments or validate data used for these evaluations. Consequently, NTIA has limited assurance that the data used to make spectrum management decisions are accurate. Federal agencies rely heavily on their program offices to obtain data for the required evaluations and often face challenges, such as resource constraints and staff turnover, when coordinating with field program staff. Given that validating spectrum assignments could require significant agency resources, it would be beneficial for NTIA to consider options for a different approach to obtain and validate critical spectrum assignment information from the agencies, such as requiring agencies to conduct site surveys or attest to the accuracy of data they submit. In response to recent initiatives, NTIA has taken steps to identify spectrum that could be made available for broadband use. First, NTIA evaluated various spectrum bands and identified 115 megahertz of spectrum that could be made available for broadband within the next 5 years based on criteria it developed. Second, NTIA developed an initial plan and timetable for evaluating and repurposing additional spectrum for broadband use in 10 years. Affected federal agencies--that is, those agencies operating devices in the spectrum bands being evaluated--encountered difficulties providing NTIA with the necessary data and analyses during the most recent evaluation. For example, according to the affected agencies, they were required to analyze and submit a significant amount of detailed impact analyses that were not readily available. Agencies will likely continue to face challenges providing such analyses to NTIA in the future as NTIA begins evaluating a larger number of spectrum bands for possible broadband use in the next 10 years. NTIA should develop an updated strategic plan, examine its assignment review processes to determine if the current approach can be improved, and establish internal controls to ensure the accuracy of agency-reported data. The Department of Commerce concurred with GAO's recommendation to examine the review processes and, citing competing priorities, partially concurred with the remaining two.

section_title: Letter
paragraphs: The radio frequency spectrum is a natural resource that is used to provide  an array of wireless communications services critical to the U.S. economy  and a variety of government functions, such as scientific research, national  defense, homeland security, and other vital public safety activities.  Spectrum capacity is necessary to deliver wireless broadband to  consumers and businesses and also to support the communication needs  of industries that use commercial wireless broadband to transmit large  quantities of information quickly and reliably. Broadband deployment  stimulates economic growth, spurs job creation, and boosts the nation’s  capabilities in education, health care, homeland security, and other areas.  As the U.S. experiences significant growth in commercial wireless  broadband services, the demand for radio frequency spectrum has  increased and additional capacity will be needed to accommodate future  growth. As new spectrum-dependent technologies and services are  brought to the market and new mission needs unfold among government  users, Congress, industry stakeholders, and federal agencies expressed  concern about the availability of additional spectrum for future needs, and  that current spectrum management in the U.S. may not be able to respond  adequately to these rapidly changing needs. This is compounded by the  fact that not all radio frequency spectrum has equal value. The spectrum  most highly valued generally consists of frequencies between 300  megahertz (MHz) and 3 gigahertz (GHz), as these frequencies have  properties well suited to many important wireless technologies, such as  mobile phones, radio, and television broadcasting. According to the  Department of Commerce’s National Telecommunications and  Information Administration (NTIA), as of December 2009, federal agencies  had exclusive access to about 18 percent of these high-value frequencies,  nonfederal users had exclusive licenses to about 30 percent, and access to  the remaining 52 percent is shared between federal and nonfederal users.
Within the federal government, NTIA is responsible for managing the  federal government’s use of the radio frequency spectrum, and the Federal  Communications Commission (FCC) is responsible for regulating  nonfederal spectrum use. Currently, there are federal government  initiatives under way aimed at identifying spectrum that can be made  available to meet the nation’s increased demand for commercial wireless  broadband services. For example, in March 2010, an FCC task force issued  the National Broadband Plan recommending that 500 MHz of spectrum  be made newly available for broadband use within the next 10 years, and  in June 2010, the President issued a memorandum directing NTIA to begin  identifying federal spectrum that can be made available for wireless  broadband. NTIA’s ability to implement these initiatives is important— specifically its ability to identify spectrum needs of federal users, ensure  spectrum is being used efficiently, and develop policies to strategically  meet these needs while simultaneously providing federal agencies with  adequate access to spectrum to conduct their essential missions.
In response to your request and in light of the recent focus on federal use  of spectrum, we examined (1) the extent to which NTIA’s spectrum  management oversight and policy addresses governmentwide spectrum  needs, (2) how federal agencies are using assigned spectrum and the  extent to which they manage their spectrum use, and (3) what steps NTIA  and the federal agencies have taken to meet the requirements and  expectations of the National Broadband Plan and presidential  memorandum to repurpose spectrum for broadband, and the challenges  these efforts face. While the focus of this report is on federal use of  assigned spectrum, we have ongoing work examining FCC’s oversight of  spectrum used by commercial entities. Further, we expect to continue  reviewing issues related to spectrum management in the United States,  including what lessons have been learned from prior efforts to repurpose  spectrum from government to commercial entities and the extent to which  the government is collaborating with the private sector to understand their  spectrum needs.
To address these objectives, we obtained and reviewed NTIA documents,  including its Manual of Regulations and Procedures for the Federal Radio  Frequency Management (commonly referred to as the Redbook); an  assessment of spectrum bands that could possibly be repurposed for  wireless broadband (referred to as the Fast Track Evaluation); and other  documentation of NTIA’s current processes, policies, and procedures. To  develop an understanding of how federal agencies use and manage  spectrum, we conducted a Web-based survey of the 19 federal agencies  comprising the Interdepartment Radio Advisory Committee (IRAC), whose  agencies hold over 90 percent of federally assigned spectrum, and which is  responsible for coordinating federal use of spectrum and providing NTIA  policy advice on spectrum issues. The agency officials responding to the  survey were top-level spectrum managers. We received completed  responses from 18 of the 19 IRAC members; the results of our survey can  be found in appendix III. To supplement information from our survey, we  obtained documents from and interviewed top-level spectrum managers  from the following 10 federal agencies: Department of Defense (DOD),  Department of Homeland Security, Department of Labor, Environmental  Protection Agency, National Oceanic and Atmospheric Administration  (NOAA), U.S. Coast Guard, Federal Aviation Administration (FAA),  Department of Health and Human Services, Department of Housing and  Urban Development, and Department of the Treasury. We selected these  federal agencies to achieve a mix of characteristics for various factors,  such as the number of spectrum assignments, representation on IRAC,  particular band of spectrum holdings, and mission needs. We also  interviewed officials from NTIA’s Office of Spectrum Management about  their spectrum management policies and procedures and interviewed  stakeholders with knowledge of spectrum issues including industry and  academic experts, and representatives of an industry association and  telecommunications companies. We selected the experts and industry  stakeholders based on prior published literature, stakeholders’ recognition  and affiliation with the spectrum management industry, and NTIA and  other stakeholders’ recommendations.
We conducted this performance audit from May 2010 to April 2011 in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
subsections: section_title: Background
paragraphs: 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 GHz. Federal agencies use spectrum to help meet a variety  of missions, such as national defense, law enforcement, weather services,  and aviation communication. Nonfederal entities (which include  commercial companies and state and local governments) also use  spectrum to provide a variety of services. For example, state and local  police departments, fire departments, and other emergency services  agencies use spectrum to transmit and receive critical voice and data  communications, while commercial entities use spectrum to provide  wireless services, including mobile voice and data, paging, broadcast radio  and television, and satellite services. See figure 1 for examples of how  spectrum is used.
In the United States, responsibility for spectrum management is divided  between NTIA and FCC. NTIA and FCC jointly determine the amount of  spectrum allocated for federal, nonfederal, and shared use. After this  allocation occurs, in order to use spectrum, nonfederal users must obtain  a license from FCC to use specific spectrum frequencies, and federal users  must obtain a similar authorization from NTIA—usually referred to as a  frequency assignment. In addition to its spectrum allocation and  authorization duties, NTIA serves as the President’s principal advisor on  telecommunications and information policy and manages federally  assigned spectrum, including preparing for, participating in, and  implementing the results of international radio conferences, as well as  conducting extensive research and technical studies through its research  and engineering laboratory, the Institute for Telecommunication Sciences.  NTIA has authority to issue rules and regulations as may be necessary to  ensure the effective, efficient, and equitable use of spectrum both  nationally and internationally. It also has authority to develop long-range  spectrum plans to meet future government spectrum requirements,  including those of public safety.
In addition to NTIA and FCC, there are other entities involved in spectrum  management:    The Office of Management and Budget (OMB) is involved in managing  agency spectrum use through the budget process. OMB’s Circular A-11,  Section 33.4, directs agencies to consider the economic value of spectrum  when requesting funding to procure a spectrum-dependent system. The  circular states that spectrum should generally not be considered a free  resource, but rather should be considered to have value and be included,  to the extent practical, in economic analyses of alternative systems.
IRAC—an interagency advisory committee—was established in 1922 to  coordinate federal use of spectrum and provide policy advice on spectrum  issues. It is comprised of representatives from 19 federal agencies that use  spectrum. IRAC’s mission and placement have evolved over its 80-year  history. IRAC was originally organized by federal agencies that were  seeking a way to resolve issues related to federal spectrum use in a  cooperative manner; its initial mission was to assist in the assignment of  radio frequencies to federal users and to coordinate federal government  spectrum use. In 1952, its mission was expanded to include formulating  and recommending policies, plans, and actions for federal government  spectrum use. Currently, IRAC is primarily involved in the frequency  assignment and system certification processes and is chaired by NTIA,  whose role as chair is to call IRAC meetings, establish IRAC agendas, and  manage other tasks associated with the administrative operations of IRAC.
The Commerce Spectrum Management Advisory Committee (CSMAC)—a  federal advisory committee—provides advice and recommendations to  NTIA. This advisory committee is organized through NTIA’s Office of  Policy Analysis and Development and was created following a  recommendation made in President Bush’s 21st Century Spectrum Policy  Initiative. CSMAC consists of approximately 25 spectrum policy experts  from the private sector and it offers expertise and perspective on long- range spectrum planning, as well as other issues, and makes  recommendations to NTIA to facilitate this planning. CSMAC was  organized in 2006, and operates under the provisions of the Federal  Advisory Committee Act.
Currently, there are three ongoing spectrum-related initiatives aimed at  identifying spectrum that can be made available to meet the nation’s  demand for commercial wireless broadband services. These initiatives  include (1) a recommendation in the National Broadband Plan, (2) a June  28, 2010, presidential memorandum, and (3) the NTIA Fast Track  Evaluation.
The National Broadband Plan recommends that a total of 500 MHz of  federally and nonfederally allocated spectrum be made available for  mobile, fixed, and unlicensed broadband use over the next 10 years. This  spectrum can come from several different frequency ranges and would be  made available for a variety of licensed and unlicensed flexible  commercial uses, as well as to meet the broadband needs of specialized  users such as public safety, energy, educational, and other users. The plan  states that for spectrum from the 225 MHz to 3.7 GHz range, a total of 300  MHz should be made available for mobile flexible use within 5 years.
On June 28, 2010, the President issued a memorandum directing NTIA to  begin identifying federally allocated spectrum that can be made available  for wireless broadband. This memorandum, in line with the National  Broadband Plan, directs NTIA to collaborate with FCC to develop a plan  and timetable to make the 500 MHz of federally and nonfederally allocated  spectrum available for wireless broadband use in the next 10 years.
A joint request from OMB, the National Economic Council, and the White  House’s Office of Science and Technology Policy requested that NTIA  identify and make available federally allocated spectrum for broadband  use in the next 5 years. In response to this request, NTIA analyzed  federally assigned spectrum to determine the feasibility of making certain  federally allocated spectrum bands available for broadband use, referred  to as the Fast Track Evaluation.
In addition, legislation has also been introduced in the House and Senate  that would help identify spectrum or relocate spectrum for commercial  uses, including (1) the Spectrum Inventory and Auction Act of 2011, and  the (2) Reforming Airwaves by Developing Incentives and Opportunistic  Sharing Act, which would require an inventory of existing users on prime  radio frequencies; (3) the Spectrum Optimization Act, which would  provide FCC with authority to conduct incentive auctions; and (4) the  Spectrum Relocation Improvement Act of 2011, which would clarify the  rights and responsibilities of federal users in the spectrum relocation  process.
section_title: NTIA’s Strategic Spectrum Planning and Its Processes for Managing Federal Spectrum Lack Governmentwide Focus and Accountability
subsections: section_title: NTIA Has Conducted Spectrum Planning, yet Its Efforts to Address Strategic Governmentwide Spectrum Management Have Lacked Continuity
paragraphs: 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, its efforts in this area have  resulted in limited progress toward improved spectrum management.  NTIA has authority to, among other things, establish policies concerning  assigning spectrum to federal agencies, coordinate spectrum use across  federal agencies, and promote efficient use of spectrum resources by  federal agencies in a manner which encourages the most beneficial public  use. As such, NTIA has a role in ensuring that federally allocated spectrum  is used efficiently. According to NTIA’s Redbook and agency officials,  efficient use includes ensuring that federal agencies’ decisions to use  spectrum to support government missions have been adequately justified  and that all viable tradeoffs and options have been explored before making  the decision to use spectrum-dependent technology, and ensuring that  these tradeoffs are continuously reviewed to determine if the need for  spectrum has changed over time. NTIA’s primary guidance to federal  agencies is technical guidance concerning how to manage assigned  spectrum provided through NTIA’s Redbook.
In May 2003, the Bush Administration directed NTIA to develop two  strategic plans, yet it has only completed one. At that time, the Bush  Administration launched the Spectrum Policy Initiative for the 21st  Century, which recognized the rapidly increasing role for wireless services  and demands on the use of the radio frequency spectrum. In response to  this initiative, NTIA stated it would produce two plans.
First, NTIA would produce a federal strategic spectrum plan to address  governmentwide spectrum needs. Specifically, the Bush Administration  directed federal agencies to develop individual strategic spectrum plans,  which would then be compiled by NTIA along with input from other  stakeholders such as FCC and state and local governments, to form a  governmentwide strategic spectrum plan.
Second, NTIA was to use the federal strategic spectrum plan to assist in  developing a national spectrum plan to address comprehensive federal and  nonfederal spectrum needs. NTIA responded to this directive by stating it  would produce a national spectrum plan, and encourage state, regional,  and local government agencies to synthesize long-range planning  processes into a nonfederal government strategic spectrum plan which  would also provide input into the national strategic spectrum plan.  Additionally, NTIA stated that it would invite FCC to provide information  regarding the future requirements of nonfederal government spectrum to  be included in the national strategic spectrum plan.
In March 2008, NTIA issued its report on federal spectrum use entitled The  Federal Strategic Spectrum Plan. Neither NTIA nor FCC has issued the  national spectrum plan that was initially scheduled for completion in  December 2007.
While the intent of the Federal Strategic Spectrum Plan was to identify  the current and projected spectrum requirements and long-range planning  processes for the federal government, we found the final plan is limited in  these areas. For example, the plan does not identify or include quantitative  governmentwide data on federal spectrum needs. Instead, NTIA’s plan  primarily consists of a compilation of the plans submitted by 15 of the  more than 60 agencies that use federal spectrum. Additionally, due to the  fact that they contained limited information regarding future requirements  and technology needs, NTIA concluded that its “long-range assumptions  are necessarily also limited.”
Furthermore, NTIA’s plan did not contain key elements and best practices  of strategic planning, which the Government Performance and Results Act,  OMB, and we have identified as including the following elements:  identification of long-term goals and objectives,    approaches or strategies to achieve these goals and objectives,    an ongoing process for revising the plan approximately every 3 years.
For example, NTIA’s plan does not include a discussion of long term goals  and objectives for governmentwide spectrum management, or approaches  and next steps for achieving these goals. Also, whereas strategic planning  is intended to be continuous, not a static or occasional event, we found  that NTIA’s strategic planning activities are not ongoing. For example,  while agencies were required to update their strategic plans every 2 years,  they have not submitted plans to NTIA since November 2007, when 14  agencies submitted plans.
We found that NTIA does not appear to be meeting its responsibilities as  directed by President Bush’s 2004 memorandum. As shown in appendix II,  NTIA discontinued many of the governmentwide projects initiated by the  Spectrum Policy Initiative for the 21st Century, demonstrating a lack of  continuity in its spectrum management operations. For example, NTIA  was directed to issue annual progress reports on the status of the  initiatives. While NTIA issued four annual progress reports from fiscal  years 2005 through 2008, these reports focused on detailing the individual  activities agencies have undertaken to improve their spectrum  management and provided limited information on actions NTIA is taking  to improve governmentwide use of spectrum. Furthermore, NTIA has not  issued a progress report since fiscal year 2008. We asked NTIA officials  why the agency was not implementing many of the presidential initiatives,  and they said due to limited resources the agency has decided to put its  strategic planning activities on hold, and has instead turned its focus to  recent initiatives directed by the Obama Administration. Based on our  conversations with NTIA officials, it is unclear when or if NTIA will  resume its forward-looking strategic planning activities. See appendix II  for a full list of NTIA activities focused on reforming governmentwide  spectrum management and the status of the activities as of February 2011.
section_title: NTIA’s Current Processes for Managing Federal Spectrum Focus on Interference Mitigation
paragraphs: 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. IRAC, an interagency committee of the federal government’s  primary spectrum users, includes six subcommittees and several ad hoc  working groups. Two IRAC subcommittees play significant roles in two  of NTIA’s key processes—frequency assignment and system certification.  These subcommittees, the Frequency Assignment Subcommittee (FAS),  which includes representatives from the 19 IRAC agencies and FCC, and  the Spectrum Planning Subcommittee (SPS), which includes  representatives from 17 of the IRAC agencies, review all requests for new  spectrum assignments by federal agencies and make recommendations to  NTIA on the outcomes.As shown in table 1, final decisions regarding  approval and use of federally allocated spectrum are made based on IRAC  review and committee consensus.
Currently the process as established by federal regulations for review and  approval of frequency assignment and system certification is technical in  nature, focusing on ensuring that the new frequency or system that an  agency wants to use will not interfere with another agency’s operations.  According to NTIA officials, this focus on day-to-day spectrum activities,  such as interference mitigation, is due to the agency’s limited resources.  This focus, while important, makes limited consideration about the overall  best use of federally allocated spectrum. Therefore, NTIA’s current  processes provide limited assurance that federal spectrum use is evaluated  from a governmentwide perspective to ensure that decisions will meet the  current and future needs of the agencies, as well as the federal  government as a whole. Additionally, throughout these processes, there is  heavy reliance on agencies to self-evaluate and report their current and  future spectrum needs. For example, in the frequency assignment process,  all analysis to determine whether spectrum-dependent technology should  be used is made by the agencies prior to a request for authorization,  therefore agencies are expected to have adequate expertise and resources  to make these determinations.
Finally, NTIA has limited ability to monitor federal spectrum use. NTIA  has four programs in place to oversee agency use of spectrum, yet  according to NTIA officials, only one program is actively implemented,  one is conducted on an as-needed basis, and two programs have been  discontinued due to lack of resources, as shown in table 2. Without  ongoing programs to monitor that agencies are using their assigned  spectrum in accordance with federal regulations, NTIA is limited in its  ability to track how federally allocated spectrum is being used or detect  Redbook violations.
section_title: NTIA’s Data Management System Lacks Transparency and Data Validation Processes, Making It Uncertain If Spectrum Management Decisions Are Based on Accurate and Complete Data
paragraphs: NTIA’s data management system is antiquated and lacks transparency and  internal controls. NTIA collects all federal spectrum data in the  Government Master File (GMF), which according to NTIA officials is an  outdated legacy system that was developed primarily to store descriptive  data. This system does not meet the current analytical needs of NTIA or  other federal users. NTIA does not generate any data, but maintains  agency-reported spectrum data in the GMF, which are collected during the  frequency assignment and review processes, as shown in figure 2.
NTIA’s processes for collecting and verifying GMF data lack key internal  controls including those focused on data accuracy, integrity, and  completeness. We have defined internal control activities as the policies,  procedures, techniques, and mechanisms that help ensure that agencies  mitigate risk. Control activities such as data verification and  reconciliation are essential for ensuring accountability for government  resources and for achieving effective and efficient program results.  Additionally, the standards for internal controls recommend that agency  systems have controls in place to ensure data accuracy, including  processes for ensuring  the agency’s data entry design features contribute to data accuracy;    data validation and editing are performed to identify erroneous data;    erroneous data are captured, reported, investigated, and promptly    output reports are reviewed to help maintain data accuracy and validity.
We found that NTIA’s data collection processes lack accuracy controls and  do not provide assurance that data are being accurately reported by  agencies. For example, the data are generally only subject to compliance  reviews that ensure all reported data meet technical and database  parameters (i.e., that they have the proper number of characters per field,  or that the frequency requested is allocated for desired use). Throughout  this process, NTIA expects federal agencies to supply accurate and up-to- date data submissions. For example, during the frequency assignment  process, a federal agency must justify that the assignment will fulfill an  established mission need and that other means of communication, such as  commercial services, are not appropriate or available. However, NTIA  does not provide agencies with specific requirements on how to justify  these needs. NTIA officials told us that they rely on federal agencies to  conduct any necessary analysis, such as engineering and technical studies,  to support the use and need of the assignment, but agencies are not  required to submit documentation verifying that the agency had completed  the analysis necessary to justify the agency’s spectrum need. Moreover,  NTIA does not require federal spectrum managers to validate or verify that  the data or information program offices do submit is accurate. According  to NTIA officials, if NTIA or other agencies identify errors, NTIA requires  the correction of these data. However, since agencies submitting data do  not have to attest to their accuracy or demonstrate the extent to which  they are actually using the spectrum which they have, NTIA has limited  assurance that information used to make spectrum management decisions  is accurate and reliable.
NTIA is developing a new data management system—Federal Spectrum  Management System (FSMS)—to replace GMF. According to NTIA  officials, the new system will modernize and improve spectrum  management processes by applying modern information technology to  provide more rapid access to spectrum and make the spectrum  management process more effective and efficient. Whereas the GMF is  only a descriptive database used to store information, it does not have  analytical capabilities that agencies can use when they are conducting the  technical studies required by the frequency assignment and certification  processes. FSMS is intended to provide these analytical capabilities and  will allow federal agencies to conduct more consistent and accurate  analysis when developing frequency assignment proposals. Ultimately this  will facilitate the more efficient use of spectrum because frequency  assignments can be located closer together. Currently, the limited data  available on frequency assignments results in users overestimating their  needs to avoid interference; the additional data that will be made available  will allow users to make more accurate judgments when determining  interference. As part of the development of FSMS, the existing GMF data  will be replaced with a new data structure, yet development is still early  and final implementation is not expected until fiscal year 2014. FSMS will  increase the amount of data agencies are required to submit to NTIA, but  the data submission process will remain similar to its current structure.  NTIA projects FSMS will improve existing GMF data quality, but not until  2018. According to NTIA’s FSMS transition plan, at that time data accuracy  will improve by over 50 percent. However, in the meantime it is unclear  whether important decisions regarding current and future spectrum needs  are based on reliable data.
section_title: Federal Agencies Use Spectrum for Many Purposes, and Lack of Specific Spectrum Management Requirements Leads to Limited Assurance That Agencies Are Recording Accurate Data
subsections: section_title: Federal Agencies Use Spectrum for a Wide Variety of Purposes, such as Emergency Communications, National Defense, and Land Management
paragraphs: Federal agencies and departments combined have over 240,000 frequency  assignments, which are used for a variety of purposes, including  emergency communications, national defense, land management, and law  enforcement. Over 60 federal agencies and departments currently have  federal spectrum assignments. Agencies and departments within DOD  have the most assignments, followed by FAA, the Department of Justice,  the Department of Homeland Security, U.S. Coast Guard, the Department  of the Interior, the Department of Agriculture, the Department of Energy,  and the Department of Commerce, respectively. These federal agencies  and departments hold 93 percent of all federally assigned spectrum (see  figure 3).
As illustrated in figure 4, less than one-third of all frequency assignments  held by federal agencies are located in the high-valued range (generally  considered the spectrum bands located above 300 MHz and below 3 GHz).  In contrast, over 48 percent of the spectrum held by federal agencies is  located in the 30–300 MHz range. The 18 IRAC agencies responding to our  survey reported holding some spectrum assignments in the high-value  range.
300.1 MHz–3 GHz (high-value range)
Through our survey and interviews with federal agency officials, we found  that federal agencies use spectrum, including high-valued spectrum, for a  wide array of purposes. As illustrated in figure 5, IRAC agencies reported  using federally assigned spectrum for emergency communications,  managing and protecting federal property or personnel, law enforcement,  research, and safety. As an example of use in the high-value range, the  Department of the Air Force reported in response to our survey using  spectrum for mission-critical military training and education, testing of  new equipment, research and development, and disaster response, in  concert with other agencies.
Federal agencies also operate a variety of spectrum-dependent systems  and equipment on assigned spectrum. Within the high-value range (300  MHz–3 GHz), IRAC agencies reported operating a wide variety of systems.  The most frequently reported systems in that range included land mobile  radio systems, fixed microwave systems, and fixed microwave point-to- point radio systems. These systems are typically used for voice and data  communication and while they can be operated in other frequency bands  outside of the high-value range, this range includes the most commonly  used frequencies for these systems.
section_title: Federal Agencies Lack Specific Guidance and Requirements from NTIA for Recording and Maintaining Accurate Data
paragraphs: NTIA has not established specific requirements for agencies to justify their  needs and to validate and verify data used to evaluate their current and  future spectrum needs. Federal spectrum managers we contacted reported  that when applying for an assignment, they generally request field program  staff to provide a description of how the frequency will be used and the  type of equipment needed for the assignment. One federal agency official  told us that his office has to trust that assignment application information  provided by program staff is accurate. Additionally, 6 out of the 10 federal  spectrum managers we contacted told us that while they review an  application before submitting it to NITA, their review primarily serves to  ensure that sufficient information has been provided to meet the  requirements of the Redbook. For example, a federal agency official told  us that when examining a frequency assignment application, some of the  factors that he reviews are availability of spectrum to be used with a  specific technology, potential for interference with other users, and  compliance of frequency use with NTIA rules and regulations.
As part of NTIA’s Frequency Assignment Review Program, federal  spectrum users are required to modify or delete frequency assignments as  needed based on the results of the 5-year reviews. However, as with the  assignment process, federal spectrum managers are not required to  validate or verify that the information the program offices are submitting  is accurate. Seven out of 10 federal spectrum managers we contacted  reported that they do not have mechanisms in place to verify the accuracy  of the information collected during these processes. Similarly, 5 out of 10  federal spectrum managers reported that their agency had not conducted  site visits or sample surveys to verify information in their data systems.
Further, federal agency officials expressed various concerns related to the  process of obtaining information from field program staff when  completing assignment reviews, including concerns about (1) the future  availability of spectrum, (2) inaccurate data on existing systems, and (3)  resource constraints and staff coordination.
subsections: section_title: Future Availability of Spectrum
paragraphs: In our survey, 15 out of 18 IRAC agencies reported that they will face some  or great difficulty in the future meeting their critical mission needs  because of insufficient spectrum.
Similarly, 4 out of the 10 federal spectrum managers we contacted told us  that while their agency’s spectrum needs are increasing, requesting new  assignments is becoming increasingly difficult due to the limited  availability of additional spectrum. According to these spectrum managers,  field program personnel are concerned that if they say they are no longer  using an assignment, it will be deleted and the program office will not be  able to obtain another assignment for their future spectrum needs. In one  specific example, a federal spectrum manager we contacted told us that  the agency’s border security duties have increased significantly over the  last few years, resulting in the agency’s increased use and dependence on  spectrum for security purposes. However, while the agency’s spectrum  needs have increased, the availability of spectrum has remained the same,  raising concerns about the agency’s access to sufficient spectrum to  complete operational mission requirements.
section_title: Inaccurate Data on Existing Systems
paragraphs: Of the three agencies we contacted that had previously completed site  visits or in-depth reviews of assignment data, federal agency officials from  two of these agencies reported uncovering significant inaccuracies in their  assignment records. For example, officials from one agency told us that in  a recent review of a sample of spectrum assignments in the Detroit,  Michigan, metropolitan area, they uncovered that approximately half of  the agency’s assignment records were inaccurate. In another example, a  spectrum manager told us that the agency conducted a review of spectrum  assignments and found that 25 percent of assignments in one department  (20 assignments) were no longer being used. As a result of this review, the  agency returned the assignments. Because the other federal agencies we  interviewed did not indicate that they had completed site surveys or in- depth reviews of their assignment records, the extent to which there are  data errors in other agencies’ assignment data is unknown.
One agency we met with had difficulty ascertaining whether a program  office was operating a system on an assignment. In this case, the agency  relocated several systems off of the 1710–1755 MHz band as a result of the  Advance Wireless Services auction in 2007. Shortly after the relocation,  the agency was contacted by a commercial wireless carrier that had  acquired the frequency informing the agency that it still had a system  transmitting on the frequency, causing interference. The agency contacted  its regional program office and discovered that a transmitter at the  identified location had not been actively used by the agency for years but  was emitting a carrier signal, which was the source of the interference.  Once the transmitter was shut off the interference on that frequency  stopped. According to the agency’s spectrum manager, regional program  officials never notified the agency about the system’s existence, and as a  result, there was no record of the system in the agency’s inventory list.  Agency officials acknowledged that had they not been contacted by the  commercial wireless carrier, they would not have known that the  transmitter was still operating and sending out a carrier signal.
While OMB Circular No. A-11, §33.4 and NTIA require that federal agencies  obtain an authorization to use a spectrum frequency assignment before  they purchase spectrum-dependent systems, 5 out of 10 agency spectrum  managers that we contacted reported that their agency does not have  procedures in place to monitor the agency’s procurement of spectrum- dependent systems prior to obtaining an assignment.
section_title: Resource Constraints and Staff Coordination
paragraphs: Seven out of 10 spectrum managers explained that due to high staff  turnover, identifying the appropriate contacts in the field to complete  assignment reviews can be difficult. One federal spectrum manager  explained that since field program staff are generally located in multiple  offices across the country, it is challenging to keep track of all the  appropriate contacts in each office every 5 years. Some spectrum  managers also noted that resource constraints limit their ability to validate  information obtained from program staff. Specifically, through our  interviews and IRAC survey, spectrum managers told us that competing  mission priorities limit their ability to verify the accuracy of information  obtained from program offices. One survey respondent stated that a key  challenge to completing frequency assignment reviews is balancing  available spectrum management resources with other competing  priorities. Another spectrum manager stated that validating and verifying  the information for each assignment record, which could entail conducting  site visits or surveys, would require significant spectrum management  resources that federal agencies do not currently have.
Five out of 10 spectrum managers reported difficulties ensuring that  program offices communicated with them before purchasing a spectrum- dependent system. Federal officials from one agency told us that  approximately 30 percent of the time, program offices at the agency  procure spectrum-dependent equipment without first notifying the agency  spectrum managers, and in some cases, before the assignment has been  granted.
In another example, a spectrum manager reported that a program office  purchased a spectrum-dependent system to operate on an assignment  before receiving authorization to operate on the frequency. The frequency  assignment application was eventually denied because the program office  had purchased a system that could not be operated on federally assigned  spectrum and the agency had to place the equipment in storage where it  remained unused.
section_title: NTIA Has Taken Steps to Identify Spectrum for Future Wireless Broadband Use, yet NTIA and Federal Agencies Will Face Challenges in Analyzing and Repurposing This Spectrum
subsections: section_title: NTIA Has Identified Federally Assigned Spectrum to Be Made Available for Future Wireless Broadband Use
paragraphs: In response to the recent initiatives to make a total of 500 MHz of  spectrum available for wireless broadband, NTIA has (1) identified 115  MHz of federally allocated spectrum to be made available for wireless  broadband use within the next 5 years, referred to as the Fast Track  Evaluation, and (2) developed an initial plan and timetable for repurposing  additional spectrum for broadband, referred to as the 10-Year Plan.
Fast Track Evaluation. NTIA and the Policy and Plans Steering Group  (PPSG) identified and recommended portions of two frequency bands,  totaling 115 MHz of spectrum within the ranges of 1695–1710 MHz and  3550–3650 MHz to be made available for wireless broadband use. In  November 2010, NTIA publicly released its results. In its final report, NTIA  summarized its analysis of four frequency bands: 1675–1710 MHz, 1755– 1780 MHz, 3500–3650 MHz, and 4200–4400 MHz. For these bands, NTIA  reviewed the number of federal frequency assignments within the band,  the types of federal operations and functions that the assignments support,  and the geographic location of federal use. Additionally, NTIA applied the  following criteria to identify the 115 MHz of spectrum:  the band must be able to be made available within 5 years,  the band must be between 225 MHz and 4400 MHz,  the decision to recommend bands for repurposing could be made prior to  October 1, 2010 (therefore due to time constraints decisions would not  require relocation of federal users), and    opportunities for geographic or other sharing within the bands must have  already been successfully proven.
Since clearing these bands of federal users and relocating incumbent  federal users to new bands was not an option in the given time frame, the  bands that NTIA recommended be made available will be opened to  geographic sharing by incumbent federal users and commercial  broadband.  10-Year Plan. By a presidential memorandum, NTIA was directed to  collaborate with FCC to make available 500 MHz of spectrum over the  next 10 years, suitable for both mobile and fixed wireless broadband use,  and complete by October 1, 2010, a specific plan and timetable for  identifying and making available the 500 MHz for broadband use. NTIA  publicly released this report in November 2010. In total, NTIA and the  National Broadband Plan identified 2,264 MHz of spectrum to analyze for  possible repurposing, of which 639 MHz is exclusively used by the federal  government and will be analyzed by NTIA. Additionally, NTIA will  collaborate with FCC to analyze 835 MHz of spectrum that is currently  located in bands that are shared by federal and nonfederal users.  Furthermore, NTIA has stated that it plans to seek advice and assistance  from CSMAC, its federal advisory committee comprised of industry  representatives and experts, as it conducts analyses under the 10-Year  Plan.
NTIA officials said that they will prioritize the bands identified for  evaluation based on the factors in table 3, with the bands that best fulfill  this criteria being evaluated for potential repurposing first. Following  prioritization, NTIA, with the assistance of the federal agencies, will  characterize each band to determine the extent of federal use in the band.  After each band is characterized, further analysis will be conducted to  evaluate the technical, operational, and cost effects that repurposing  would have on the federal agencies.
In January 2011, NTIA announced that it had selected the 1755–1850 MHz  band as the first priority for detailed evaluation under the 10-Year Plan.  According to NTIA, this band was given top priority for evaluation by  NTIA and the federal agencies, based on a variety of factors, including  industry interest and the band’s potential for commercial use within 10  years. Agencies currently operating in this band have been notified of the  pending evaluation, and NTIA and PPSG have identified comparable bands  for agency operations. Affected agencies are now conducting analyses to  determine which of these comparable bands best meets their needs and  will provide NTIA with their input in spring 2011. According to NTIA  officials, a decision on how to proceed with its analysis will be made in  June 2011. This is not the first time NTIA has studied these bands. These  bands were previously evaluated for reallocation, and in 2001, we reported  that at the time adequate information was not currently available to fully  identify and address the uncertainties and risks of reallocation.
section_title: Federal Agencies Reported Difficulties during the Fast Track Evaluation, Raising the Prospect for Future Challenges
paragraphs: Affected federal agencies reported difficulties in providing the impact  analysis required for NTIA’s Fast Track Evaluation, raising concerns that  larger scale future analysis may be impacted. The evaluation required  Navy, NOAA, and FAA to analyze and submit a significant amount of  detailed impact analyses that were not readily available, according to  officials with those agencies. Further, Department of the Navy and U.S.  Marine Corps officials said they were required to conduct analyses based  on a number of different scenarios to determine what the impact might be  for mission performance by making various spectrum bands available for  wireless broadband. According to one Navy official, while DOD collects a  large amount of data on its spectrum-dependent systems, NTIA’s request  required DOD to conduct a time-consuming, in-depth analysis on the  operational impact of repurposing certain spectrum bands. NTIA officials  recognize that completing this analysis required significant agency  resources, but they noted that agencies were the only ones with the  requisite expertise to complete the analysis.
In response to our survey, the Department of the Navy and the Department  of the Air Force expressed concerns over data accuracy as a result of the  short time frame given to them to collect the data. One official stated that  the speed of identifying available spectrum appeared more important than  the accuracy of the data. According to a DOD official, these data requests  were time-consuming because they required regional spectrum managers  to identify and contact all field program offices using spectrum- dependent  systems in the band being analyzed to determine their use of spectrum and  how their mission performance would be affected if the band were no  longer available for federal use. Four IRAC agencies that completed our  survey—NOAA, Department of the Air Force, Department of the Navy, and  Department of the Army—expressed further concerns about the resources  required to collect spectrum data for the Fast Track Evaluation.
In addition to the challenges that federal agencies reported in gathering  data, making the 115 MHz of spectrum available for wireless broadband  will have operational effects on agencies. For example, according to  NTIA’s Fast Track Evaluation, as a result of the decision to make the 1695– 1710 MHz band available for wireless broadband, NOAA will have to  redesign its next generation of Geostationary Operational Environmental  Satellite-R series (GOES-R) satellites. According to NOAA, this redesign  will increase costs and delay implementation. Additionally, NTIA does not  expect DOD to experience any immediate operational impacts due to the  repurposing of the 3550–3650 MHz band; however, such a repurposing  based on exclusion zones will limit DOD’s future flexibility to implement  new systems or operate at new locations. As table 4 illustrates, NOAA and  DOD will be the primary agencies affected by the decision to make this  spectrum available.
Further, data- and resource-related challenges could affect  implementation of NTIA’s 10-Year Plan. As experienced in previous  relocations, inaccurate and incomplete data submitted by agencies can  impact the transition time from federal to commercial use once  reallocated spectrum has been auctioned by FCC and purchased by  commercial users. During the relocation of federal users as a result of the  Advance Wireless Service spectrum auction in 2006, according to a  winning bidder of the spectrum, some agencies submitted inaccurate  inventory data to NTIA and OMB causing delays in the transition from  federal to commercial use. As previously discussed, federal agencies faced  resource challenges in providing NTIA data on system inventory,  operational use, and operational impacts. These challenges raise concerns  because the Fast Track Evaluation focused on only 115 MHz of spectrum,  while NTIA is now expecting to evaluate 1,474 MHz of spectrum, meaning  these challenges could be magnified.
Without adequate and timely funding for agencies to conduct research and  planning, the goals of the 10-Year Plan and timetable may not be achieved.  In previous auctions, as part of the Commercial Spectrum Enhancement  Act (CSEA),agencies have been reimbursed for their relocation costs  through the Spectrum Relocation Fund. CSEA does not provide agencies  with up-front funding to conduct detailed analysis during the spectrum  evaluation phase. The lack of funding may delay analysis and band  characterization for repurposing, as agencies have limited staff and  resources to dedicate to data collection and band analysis. This can be  problematic because agencies have reported significant costs associated  with collecting the data and conducting the analysis requested by NTIA.  For example, a DOD official told us he committed 400 staff hours to  collecting operational impact data for the Fast Track Evaluation for two  affected DOD systems; under the 10-Year Plan, the official expects to have  to collect and prepare operational impact data for 120 systems. To address  this funding issue, NTIA stated in the Fast Track Evaluation analysis that  changes to expand the CSEA would be needed to provide agencies with  up-front funding for analysis and planning related to repurposing.  According to NTIA officials, without this funding, agencies will not be able  to conduct adequate analysis for the 10-Year Plan, and currently NTIA  does not have a plan to address these challenges if this funding is not  made available.
section_title: Industry Stakeholders Expressed Concerns with the Usefulness of the Identified Spectrum
paragraphs: Industry stakeholders, including wireless service providers,  representatives of an industry association, and a think tank representative  we contacted expressed concerns over the usefulness of the spectrum  identified by NTIA in the Fast Track Evaluation, since most of the  spectrum identified (100 of the 115 MHz) is outside the range considered  to have the best propagation characteristics for mobile broadband.  Overall, there has been limited interest in the bands above 3 GHz for  mobile broadband use because, according to industry stakeholders, there  have been minimal technological developments for mobile broadband in  bands above 3 GHz and no foreseeable advances in this area at this time.
According to industry representatives, the 1755–1780 MHz band that NTIA  considered as part of the Fast Track Evaluation has the best  characteristics for mobile broadband use, and it is internationally  harmonized for this use. NTIA did not select this band to be made  available in the 5-year time frame due to the large number of federal users  currently operating there. Recently, however, NTIA has identified it as the  first band to be analyzed under the 10-Year Plan to determine if it can be  made available for commercial broadband use.
An industry stakeholder has stated that the 1695–1710 MHz band identified  by NTIA in the Fast Track Evaluation is the second-best alternative for  wireless broadband if the 1755–1780 MHz band were not made available;  however, the 1695–1710 MHz band is not currently used internationally for  wireless broadband, which may reduce device manufacturers’ incentive  for developing technology that can be used in these frequencies.
Additionally, an industry stakeholder also expressed concern over the  exclusion zones established by NTIA in the 1695–1710 MHz band, which  would make the band unavailable for wireless broadband in select major  cities across the United States that account for over 12 percent of the U.S.  population. Similarly, one industry stakeholder has also noted that the  exclusion zones NTIA has established for the 3550–3650 MHz band would  prevent wireless broadband access along the entire East and West coasts.  Considering the geographic exclusion zones and the location of the  spectrum above 3 GHz, an industry stakeholder we contacted said that  they are not as immediately interested in this spectrum as they are in the  1755–1780 MHz band, which, according to one industry stakeholder, may  impact future spectrum auction prices. On March 8, 2011, FCC released a  Public Notice seeking comment on steps the Commission can take to best  promote wireless broadband deployment in the 1695-1710 MHz and 3550- 3650 MHz bands. Amongst other things, FCC sought comment on the  extent to which these bands could be made available for broadband  deployment; how the conditions placed on the bands, such as the  exclusion zones, could affect their usefulness for broadband deployment;  and whether broadband technologies are readily available to operate on  these bands.
While spectrum auctions can generate substantial funds for the U.S.  Treasury—for example, the Advance Wireless Services auction that took  place in September 2006 fetched over $13.7 billion, a portion of which  went to the U.S. Treasury—if industry participants are not as interested in  the spectrum being auctioned, lower bids would be expected. Agencies are  currently reimbursed with funding from auction revenue for data  collection, analysis, and planning-related costs, after costs for relocating  federal users have been paid. Lack of industry interest in spectrum above 3  GHz creates concerns as to whether large amounts of spectrum will be  able to meet the minimum price at auction, which the CSEA has set at 110  percent of federal relocation costs. Since relocating federal users is likely  as part of the 10-Year Plan, if the reserve is not met, agencies may not be  reimbursed for their data collection, analysis, and planning costs. As  previously stated, NTIA officials have raised concerns that without this  funding, agencies will not be able to conduct adequate analysis for the 10- Year Plan. Currently NTIA does not have a plan to address these  challenges if this funding is not made available.
section_title: Conclusions
paragraphs: 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  efforts do not align with its authorities. Its focus is on the technical  aspects of spectrum management, such as ensuring new frequency  assignments will not cause interference to spectrum-dependent devices  already in use, rather than on whether new assignments should be  approved based on a comprehensive evaluation of federal spectrum use  from a governmentwide perspective. NTIA officials noted that due to  limited resources, the agency has put its strategic planning activities on  hold and has instead turned its focus to recent initiatives directed by the  Obama Administration. However, lacking an overall strategic vision, NTIA  cannot ensure that spectrum is being used efficiently by federal agencies.
Agencies are supposed to review all their spectrum assignments every 5  years and delete any assignments not essential to their missions; however,  we found that these reviews are often perfunctory. Furthermore, agencies  have concerns about not having access to sufficient spectrum in the future  to meet mission-critical needs and therefore might be reluctant to  relinquish any assignments for fear they will be unable to get more  spectrum in the future. The absence of requirements for agencies to  submit justifications for their spectrum use combined with NTIA’s limited  oversight of the agencies has led to decreased accountability and  transparency in how federal spectrum is actually being used and whether  the spectrum-dependent systems the agencies have in place are necessary.  However, federal agency officials face challenges—such as staff turnover  and resource constraints—when coordinating with field program staff to  obtain the information necessary for the frequency assignment  applications and reviews. Given that verifying the information for each  frequency assignment record could require significant spectrum  management resources that federal agencies might not currently have, it  would be beneficial for NTIA to consider options for a different approach  to obtain critical assignment information from the agencies. Approaches  may include efforts such as requiring agencies to conduct site surveys of  their spectrum-dependent systems, attesting to the accuracy of the data  provided to NTIA, or making changes to the structure of the 5-year review  program.
As part of its spectrum management processes, NTIA depends primarily  on an antiquated data collection system and does not have a mechanism in  place to validate and verify the accuracy of spectrum-related data  submitted by the federal agencies. The data management system also lacks  transparency and internal controls, which are essential for ensuring  accountability for government resources and for achieving effective and  efficient results. Although NTIA is developing its new FSMS, full  implementation is still years away. In the meantime, without meaningful  data validation requirements, NTIA has limited assurance that the agency- reported data it collects are accurate and complete. As NTIA begins the  arduous task of identifying 500 MHz of spectrum that can be repurposed  for broadband services, incomplete or inaccurate data might adversely  impact NTIA’s ability to make sound decisions regarding the current and  future spectrum needs of agencies.
section_title: Recommendations for Executive Action
paragraphs: To facilitate the effective governmentwide management of federal  spectrum use, the Assistant Secretary of Commerce for Communications  and Information should take the following actions:    To ensure NTIA’s previous efforts to develop a federal strategic plan are  not diminished, develop an updated plan that includes key elements of a  strategic plan, as well as information on how spectrum is being used  across the federal government, opportunities to increase efficient use of  federally allocated spectrum and infrastructure, an assessment of future  spectrum needs, and plans to incorporate these needs in the frequency  assignment, equipment certification, and review processes.
To help ensure federal agencies are managing current and future spectrum  assignments efficiently, in consultation with IRAC, examine the 5-year  assignment review processes and consider best practices to determine if  the current approach for collecting and validating data from federal  agencies can be streamlined or improved.
To provide the assurance that accurate and reliable data on federal  spectrum use are collected, take interim steps to establish internal  controls for management oversight of the accuracy and completeness of  currently reported agency data. In developing the new Federal Spectrum  Management System, incorporate adequate internal controls for validating  the accuracy of agency-reported information submitted during the  assignment, certification, and frequency assignment review processes.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Commerce for its  review and comment. Commerce provided written comments, which are  reprinted in appendix IV.
In commenting on the draft report, Commerce noted that as the spectrum  manager for federal users, NTIA has several spectrum management duties,  such as fulfilling federal agency spectrum requirements, preventing  interference among federal users, and undertaking other spectrum-related  assignments or initiatives related to federally assigned spectrum.  According to Commerce, given funding limitations and resource  constraints, NTIA must determine how to prioritize its various spectrum- related responsibilities without impairing its primary mission of  responding to agencies’ spectrum assignment requests in a timely manner.
With respect to our recommendations, Commerce concurred with one and  partially concurred with the other two. Specifically, Commerce concurred  with our recommendation to examine the 5-year assignment review  processes and consider best practices to determine if the current approach  can be improved. Commerce stated that NTIA, in consultation with IRAC,  would review the current assignment process with agencies to determine  what improvements could be implemented. Commerce partially concurred  with our recommendation to develop an updated strategic plan, stating  that NTIA will have to weigh updating strategic plans against other  spectrum management needs and directives and determine priorities.  Commerce agreed that key elements of strategic planning are central to  NTIA’s work, but stressed that given funding limitations, NTIA must  consider our recommendation in light of its other spectrum-related  obligations and fundamental spectrum mission. We recognize that NTIA  has been tasked with responding to other spectrum management  directives, but lacking an overall strategic vision, NTIA cannot ensure that  its spectrum management decisions reflect the overall best use of federally  allocated spectrum. Moreover, without an understanding of how spectrum  is being used across the federal government, NTIA cannot ensure that  spectrum is being used efficiently by federal agencies or that spectrum  management decisions will meet the current and future needs of the  agencies, as well as the federal government as a whole. We believe a  strategic plan is a key element for NTIA to respond to recent directives  from the President regarding repurposing spectrum assigned to federal  agencies for commercial broadband. Commerce also partially concurred  with our recommendation related to establishing internal controls for  management oversight of currently reported agency data, noting its  concurrence to the extent that such controls could be adopted with  existing and anticipated resources. Commerce stated that NTIA would  take steps to establish internal controls for federal spectrum use data and  work with agencies to determine what new processes could be  implemented that would lead to more accurate and reliable data, including  the establishment of procedures for agency validation of submitted data.
As agreed with your offices, unless you publicly announce 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 and the Secretary of Commerce. In addition, the  report will be available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staff have any questions about 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. Contact information and major contributors to this report  are listed on appendix V.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report focuses on the federal use of spectrum and examines (1) the  extent to which the National Telecommunications and Information  Administration’s (NTIA) spectrum management oversight and policy  addresses governmentwide spectrum needs, (2) how federal agencies are  using assigned spectrum and the extent to which they manage their  spectrum use, and (3) what steps NTIA and the federal agencies have  taken to meet the requirements and expectations of the National  Broadband Plan and presidential memorandum to repurpose spectrum for  commercial broadband and what challenges these efforts face.
To determine the extent to which NTIA’s spectrum management oversight  and policy addresses governmentwide spectrum needs, we examined  documents, consulted relevant spectrum literature, and conducted  interviews. Specifically, we reviewed NTIA’s Manual of Regulations and  Procedures for the Federal Radio Frequency Management (commonly  referred to as the Redbook) and other documentation of NTIA’s current  processes, policies, and procedures to determine (1) NTIA’s legal  authorities for managing federal users of spectrum, (2) how NTIA works  with federal agencies to manage spectrum, (3) how NTIA collects data on  federal agency spectrum assignments and usage, (4) limitations, if any,  with NTIA’s current procedures for collecting data on federal agency  spectrum assignments and usage, and (5) NTIA’s actions, if any, to address  these limitations. We also reviewed NTIA’s data collection procedures and  policies to ensure the data reliability of information contained in the  Government Master File (GMF) database. In addition, we interviewed  representatives from NTIA’s Office of Spectrum Management to gather  information about their spectrum management policies and procedures.  We also interviewed or obtained written comments from a variety of  experts and industry stakeholders, including academics, industry  representatives, and think-tank organizations (as shown in table 5) to  obtain their views on options available for increasing the efficiency of  federal spectrum use and management and associated tradeoffs. We  selected the experts and industry stakeholders to interview based on prior  published literature, stakeholders’ recognition and affiliation with  spectrum management industry, and NTIA and other stakeholders’  recommendations. Finally, we conducted a literature review of spectrum  studies. Our literature search covered studies published from 2005 onward  and was largely drawn from major electronic databases in  telecommunications, academic, economics, and other fields (e.g., SNL  Kagan, EconLit, Academic OneFile, ProQuest, and other databases) and  from our past work on spectrum-related issues. We used the studies  obtained from this literature review to obtain background information on  spectrum issues.
To identify how federal agencies use assigned spectrum and the extent to  which agencies manage their spectrum use we conducted a Web-based  survey of all 19 Interdepartment Radio Advisory Committee (IRAC) federal  agency representatives. We surveyed federal agencies on the IRAC  because these agencies collectively hold over 90 percent of all federally  assigned spectrum. The survey was conducted from November 1, 2010, to  January 21, 2011. The survey included questions on (1) how federal  agencies use spectrum assignments; (2) federal agency interaction with  NTIA; (3) federal agencies’ spectrum management policies and  procedures; (4) the extent to which federal agencies share spectrum with  other users and use of commercial services; and (5) federal agencies’  views on the extent to which agencies have the resources and information  they need to manage their spectrum. The results of our survey can be  found in appendix III.
We received completed responses from 18 of the 19 IRAC representatives,  for a 95 percent response rate. We did not receive a completed survey  from the Department of State IRAC representative despite our multiple  attempts to obtain the information. Because we selected a nonprobability  sample of federal agencies with assigned spectrum to survey, the  information we obtained from the survey may not be generalized to all  federal agencies with assigned spectrum. However, because the IRAC  member agencies that we included in our sample survey hold the vast  majority of all federally assigned spectrum, the information we gathered  from these agencies provided us with a general understanding of federal  agencies’ spectrum management policies. In addition, we took steps in the  development of the survey, the data collection, and the data analysis to  minimize nonsampling errors. For instance, a survey specialist designed  the survey and the draft survey was pre-tested with IRAC representatives  from three federal agencies. We conducted these pre-tests to ensure that  (1) the questions and possible responses were clear and thorough, (2)  terminology was used correctly, (3) questions did not place an undue  burden on the respondents, (4) the information was feasible to obtain, and  (5) the questionnaire was comprehensive and unbiased. On the basis of  the feedback from the three pre-tests we conducted, we made changes to  the content and format of the survey questions.
To supplement data obtained from the survey and to gather in-depth  information on the roles and responsibilities of federal agencies in  managing their assigned spectrum, we obtained documents from and  conducted interviews with a sample of federal agencies to provide detailed  examples of how federal agencies are managing their spectrum. We  prepared comprehensive profiles for each of these agencies which  included data from our IRAC survey, our review of federal agency  planning documents including federal agencies’ spectrum management  policies and procedures and strategic spectrum plans, other literature, and  structured interviews with spectrum management officials at selected  federal agencies. The agencies we met with included the Department of  Defense, Department of Homeland Security, Department of Labor,  Environmental Protection Agency, National Oceanic and Atmospheric  Administration, the U.S. Coast Guard, Federal Aviation Administration,  Health and Human Services, Housing and Urban Development, and the  Department of the Treasury. We selected federal agencies for our  comprehensive profiles to achieve a mix of the following characteristics:  large spectrum holdings (more than 5,000 assignments) and small  spectrum holdings (less than 1,000 assignments);  IRAC and non-IRAC member agencies to ensure that we had  representative views from both groups; and    assignments located in different spectrum bands and used for different  mission needs.
We also consulted internal stakeholders, experts, associations, and NTIA  officials to assist us in identifying potential agencies to interview.  Although using these criteria allowed us to obtain information from a  diverse mix of federal agencies, the findings from our in-depth profiles  cannot be generalized to all federal agencies because they were selected  as part of a non-probability sample.
To determine what steps NTIA and federal agencies have taken to meet  the requirements and expectations of the June 28, 2010, presidential  memorandum and what challenges these efforts will face, we reviewed  pertinent documents related to their efforts, such as NTIA’s Assessment of  Spectrum Bands That Could Possibly be Repurposed for Wireless  Broadband (referred to as the Fast Track Evaluation) and 10-Year Plan.  We also conducted interviews with NTIA and federal agency officials.  Through our interviews, we collected up to date information on actions  being taken to make spectrum available for wireless broadband including  information on what criteria NTIA is using to make these decisions, how  NTIA and federal agencies are collaborating on identifying spectrum, and  what potential challenges they may face in reallocating federal spectrum.  We also contacted four wireless service providers to obtain their  viewpoints and opinions on (1) NTIA’s process and methodology for  identifying additional spectrum to be made available for commercial  broadband use, (2) the level of private sector demand for the spectrum  identified by NTIA, and (3) the potential value of spectrum that NTIA has  identified for analysis as part of its Fast Track Evaluation and 10-Year  Plan.
We conducted this performance audit from May 2010 to April 2011 in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
section_title: Appendix II: Summary of NTIA Projects Focused on Reforming Governmentwide Federal Spectrum Management and Increasing the Efficiency and Effectiveness of Federal Spectrum Use
paragraphs: Program reactivated in  Jan. 2008.
The Federal Spectrum  Management  System will utilize  advanced information  technology to develop a  Web-based process for  preparing and processing  applications for system  certification and frequency  assignments. It will  consolidate existing paper- based and multiple  software systems,  including Spectrum XXI  and El-Cid.
section_title: Appendix III: Survey of IRAC Agencies
paragraphs: The questions we asked in our survey of IRAC agencies are shown below.  Our survey was comprised of closed- and open-ended questions. In this  appendix, we include all the survey questions and aggregate results of  responses to the closed-ended questions; we do not provide information  on responses provided to the open-ended questions. For a more detailed  discussion of our survey methodology see appendix I.  1.  Which Interdepartment Radio Advisory Committee (IRAC) agency do  you represent?
2.  What component agency or department do you work for?  3.  What is your job title?  4.  Please briefly describe your key responsibilities as they relate to  spectrum management.  5.  Do you have other responsibilities in addition to spectrum  management? If so, please describe.  6.  How long have you been working in federal spectrum management?  (Please include in your estimate experience throughout your career  not just in your current position)
Federal Agency Frequency Assignments:  7.  Currently, how many frequency assignments in each of the following  frequency band ranges does the IRAC agency you represent have?  8.  For what general purpose does the IRAC agency you represent use  spectrum assigned in the 300 MHz to 3 GHz range? If you do not have  any spectrum assigned in the 300 MHz to 3 GHz range, please skip  toQ9  9.  For the IRAC agency you represent, which of the following usage  categories has your assigned spectrum been designated? (Select one  for each row.)
The next series of questions asks about the types of technologies  your agency operates within specific spectrum band ranges.  10. For the IRAC agency you represent, please indicate whether your  agency operates fixed microwave systems within any of these  frequency ranges. (select one for each row)
11. For the IRAC agency you represent, please indicate whether your  agency operates fixed transportable systems within any of these  frequency ranges. (select one for each row)
12. For the IRAC agency you represent, please indicate whether your  agency operates land mobile radio systems within any of these  frequency ranges. select one for each row)
13. For the IRAC agency you represent, please indicate whether your  agency operates maritime mobile radio systems within any of these  frequency ranges. (select one for each row)
14. For the IRAC agency you represent, please indicate whether your  agency operates fixed microwave point to point radio systems within  any of these frequency ranges. (select one for each row)
15. For the IRAC agency you represent, please indicate whether your  agency operates digital microwave systems within any of these  frequency ranges. (select one for each row)
16. For the IRAC agency you represent, please indicate whether your  agency operates satellite systems within any of these frequency  ranges. (select one for each row)
17. For the IRAC agency you represent, what is/was the federal agency’s  18. For the IRAC agency you represent, how much did you pay NTIA in  administrative fees for each of the following years?  19. In general, how satisfied or dissatisfied is the IRAC agency you  represent with the following resources available at your agency to  manage spectrum? (select one for each row)  20. What additional resources, if any, would the IRAC agency you  represent like to have to manage your spectrum?
NTIA Guidance and Coordination:  21. Excluding the guidance you received from NTIA’s Manual of  Regulations and Procedures for Federal Radio Frequency Management  (the Redbook), how satisfied or dissatisfied are you with the current  quality of the other NTIA guidance you receive to manage your federal  spectrum? (select one for each row)
22. To what extent, if at all, does the IRAC agency you represent  coordinate with NTIA on the following spectrum management issues?  (select one for each row)
23. What comments or concerns, if any, do you have with NTIA’s efforts to  identify and make available 500 MHz of spectrum suitable for both  mobile and fixed wireless broadband use?
Agency Management and Planning Processes and Procedures:  24. Does the IRAC agency you represent have internal policies, protocols,  or procedures in place to complete the following spectrum  management activities. (select one for each row)
25. Within the last 5 years, how many applications for frequency  assignments has your agency submitted to the Frequency Assignment  Subcommittee (FAS)?  26. Within the last 5 years, how many spectrum certification applications  for major spectrum dependent systems has your agency submitted to  the Spectrum Planning Subcommittee (SPS)?  27. What factors did the IRAC agency you represent consider when  determining whether to classify a system as a “major spectrum  dependent system” requiring a spectrum certification review?  28. To what extent does the IRAC agency you represent rely on unlicensed  spectrum? (select one for each row)  29. When did the IRAC agency you represent last complete a review or  analysis of your future spectrum needs? (select one for each row)
30. How much, if at all, do you see your agency’s need for spectrum  increasing in the next 2-3 years? (select one for each row)
31. In your opinion, will your agency have difficulty in the future meeting  its critical mission needs because of insufficient spectrum? (select one  for each row)
32. What factors does the IRAC agency you represent consider when  making decisions about how much spectrum the agency will need in  the future?  33. On average, how often is your agency able to meet the 5-year review  requirement of your agency’ spectrum frequency assignments reflected  in the Government Master File Database?
34. Please describe below some of the general challenges, if any, that your  agency faces in reviewing your spectrum frequency assignments  reflected in the Government Master File Database, by the 5-year  deadline as required by NTIA:  35. During the last year, approximately how many modifications to an  existing spectrum frequency assignment did the IRAC agency you  represent make?  36. Please describe below the general reasons for why your agency  modified an existing spectrum frequency assignment during the last  year:  37. During the last year, approximately how many deletions to an existing  spectrum frequency assignment did the IRAC agency you represent  make?  38. Please describe below the general reasons for why your agency deleted  an existing spectrum frequency assignment during the last year:  39. Does the IRAC agency you represent currently conduct measurements  of any of the following types of usage? (select one for each row)
40. Which of the following reasons explains why your agency does not  conduct spectrum usage measurements? (select one for each row)
Spectrum sharing and use of commercial services:  41. Does the IRAC agency you represent currently share spectrum with  any of the following users? (select one for each row)
42. If your agency shares spectrum, please provide examples.  43. If your agency shares spectrum, how much of an influence, if any, were  the following factors in the agency’s decision to share spectrum?  (select one for each row)
44. Does the IRAC agency you represent, utilize any of the following  spectrum sharing technologies? (select one for each row)
45. Please describe below the challenges, if any, impact your agency’s  ability to use technologies that promote spectrum sharing (such as  software defined radios, dynamic frequency selection devices,  cognitive radios, or trunked radio systems):  46. If your agency does not share spectrum, how much of an influence, if  any, were the following factors in the agency’s decision to not share  spectrum? (select one for each row)
47. Does the IRAC agency you represent currently rely on commercial  network service providers to fulfill any of the following services for  mission critical needs and/or administrative needs? (select one for  each row)
48. How much of an influence, if any, were the following factors in the  agency’s decision to use commercial services to provide your spectrum  related needs? (select one for each row)
49. How much of an influence did the following concerns have in the  agency’s decision not to use commercial network services for mission  critical needs? (select one for each row)  50. If you have any additional comments or views regarding federal  spectrum management issues that you’d like to share with us, please  do so below.
section_title: Appendix IV: Comments from the Department of Commerce
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Sally Moino, Assistant Director;  Amy Abramowitz; Tida Barakat; Richard Brown; Colin Fallon; Nick  Jepson; Maria Mercado; Josh Ormond; Kelly Rubin; Andrew Stavisky; Hai  Tran; and Mindi Weisenbloom made key contributions to this report.