Interdepartment Radio Advisory Committee: IRAC Representatives Effectively Coordinate Federal Spectrum but Lack Seniority to Advise on Contentious Policy Issues
Published: 2004-09-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The National Telecommunications and Information Administration (NTIA) within the Department of Commerce manages the federal government's use of the radio frequency spectrum with coordination and policy input from the Interdepartment Radio Advisory Committee (IRAC), comprised of 20 federal agencies that use spectrum. In recent years, the use of spectrum in wireless applications has expanded dramatically, leading occasionally to contentious disputes between government and commercial users over access to spectrum. Considering IRAC's key role in spectrum management, Congress asked us to (1) describe the evolution of IRAC and (2) obtain IRAC agency representatives' assessment of IRAC's spectrum coordination and policy advice, role as an advisor, and whether IRAC needs to be reformed.
section_title: What GAO Found
paragraphs: The mission and placement of IRAC have evolved over time. IRAC began in 1922 by assisting in the assignment of frequencies to federal users and coordinating federal government spectrum use. In 1952, IRAC's mission was expanded to include responsibilities for formulating and recommending policies, plans, and actions for federal government spectrum use. Initially advising the Department of Commerce, IRAC has reported to or through various different entities, including at different times the Federal Communications Commission (FCC) and the Office of the President. Since 1978, IRAC has directly advised the Department of Commerce's NTIA. Currently, IRAC is comprised of a full committee, six standing subcommittees, and various ad hoc committees and working groups. In interviews with GAO, IRAC agency representatives made two key points in assessing IRAC. First, IRAC is effective in accomplishing spectrum coordination tasks, but its effectiveness is at times limited by representatives' uneven level of technical knowledge. This problem could worsen, as one-half of the 20 current IRAC representatives are currently eligible to retire. Second, IRAC's ability to advise on national spectrum policy issues is limited because of representatives' lack of seniority within their agencies. The chair of IRAC (an NTIA senior executive) is in agreement with representatives on these points. He said that he has gone outside IRAC directly to senior agency executives when he needed advice on contentious spectrum disputes such as those related to the introduction of new commercial communications services that would use federally controlled spectrum. A federal task force recently released a report that identified similar issues regarding IRAC's effectiveness and areas in need of reform.

section_title: Letter
paragraphs: Over the past several decades, the development and use of wireless  telecommunications and information technology has expanded  dramatically, greatly increasing the use of and demand for the radio  frequency spectrum. Cellular telephones, wireless computer networks,  and global-positioning system receivers are quickly becoming as common  to everyday life as radios and televisions. Wireless communications have  become critical to private industry and a variety of government  missions—ranging from scientific research and public safety to homeland  security and warfare. As a result, the radio frequency spectrum has become  crowded and, in the future, may no longer be able to accommodate all  users’ needs.
Radio frequency spectrum in the United States is managed using a dual  organizational structure. The National Telecommunications and  Information Administration (NTIA) within the Department of Commerce  manages the federal government’s use of spectrum, and the Federal  Communications Commission (FCC) manages all other uses. In carrying  out its responsibilities, NTIA relies on the assistance and advice of the  Interdepartment Radio Advisory Committee (IRAC). Chaired by NTIA,  IRAC is comprised of representatives from 20 federal agencies that use  spectrum. IRAC helps coordinate federal use of spectrum and provides  policy advice on spectrum issues.
Some recent, contentious disputes over who should have access to specific  parts of the radio spectrum have occurred between government and  commercial users. Because of IRAC’s key role in spectrum management,  you asked us to (1) describe the evolution of IRAC and (2) obtain IRAC  representatives’ assessment of IRAC’s ability to coordinate federal  spectrum use and provide policy advice, its role as an advisor, and whether  IRAC needs to be reformed. To describe the evolution of IRAC, we  reviewed relevant historical documents and interviewed key current and  retired government officials. To obtain IRAC member opinions, we  conducted interviews with each of the 20 IRAC representatives. We  designed interviews that included a combination of closed-ended questions  and open-ended questions, which provided an opportunity for the IRAC  representatives to make additional comments. We also interviewed other  FCC and NTIA officials, including the current chairs of the IRAC full  committee and six standing subcommittees. Lastly, we also relied on audit  work from our previous reports on spectrum management in forming our  conclusions and recommendations. A list of related GAO reports on  spectrum management appears at the end of this report. We conducted our  work from October 2003 through June 2004 in accordance with generally  accepted government auditing standards. This report summarizes the  information we provided to your staff during our June 30, 2004, briefing.  The briefing slides are included in appendix I. Key contacts and major  contributors to this report are listed in appendix VII.
subsections: section_title: IRAC’s Mission and Placement Have Evolved Since 1922
paragraphs: IRAC’s role and placement have evolved over the last 80 years. IRAC was  organized by several agencies in 1922 that, during a period of rapid growth  in the use of radio services, recognized the need for interagency  cooperation to resolve problems arising from the federal government’s use  of broadcasting and radio services. The first interagency committee  meeting attended by interested federal agencies initially set out to regulate  and guide the radio broadcasting operations at the Washington Navy Yard  and any others that might be established by the federal government. In  June 1922, the committee decided that its scope should extend beyond  broadcasting and that it should be advisory to the Department of  Commerce in all matters of government radio spectrum regulation. In a  1927 letter to the Secretary of Commerce, the President affirmed IRAC’s  advisory role and its mission to assign frequencies and coordinate federal  government spectrum use. In 1952, IRAC’s mission was formally expanded  to include responsibilities for formulating and recommending policies,  plans, and actions for federal government spectrum use. Since its  formation, IRAC has advised the different entities responsible for  exercising the authority of the President to assign radio frequencies to  federal government users. Consequently, IRAC has reported through or to  the Secretary of Commerce; the FCC Chairman; the Telecommunications  Advisor to the President; the Director, Office of Defense Mobilization and  its successor agencies; the Director of Telecommunications Management;  and the Director, Office of Telecommunications Policy. By executive order,  in 1978, the Office of Telecommunications Policy was abolished and its  spectrum functions were transferred to the Department of Commerce.  Commerce formally established NTIA in 1978, and since then, IRAC has  directly advised NTIA. See figure 1 for a more detailed timeline of IRAC’s  evolution.
As shown in figure 2, IRAC is currently comprised of 20 federal agencies  that use radio spectrum, a chairman and an executive secretary from NTIA,  and FCC as a nonvoting liaison.
In addition to the full committee, IRAC mission responsibilities are also  carried out in six standing subcommittees, as well as a number of ad hoc  committees and working groups.
Frequency Assignment Subcommittee: Assignment of frequencies in  government bands of spectrum.
Spectrum Planning Subcommittee: Planning spectrum use and certifying  major government systems that will use radio frequencies.
Radio Conference Subcommittee: Coordination of U.S. government  positions for international conferences where agreements are made  regarding the global and regional allocation of spectrum.
Space Systems Subcommittee: International registration of government  satellite systems and development of procedures for implementing  space-related provisions of international agreements.
Technical Subcommittee: Addresses issues that relate to the technical  aspects of the use of radio spectrum, including the development of new  technical standards and recommendations on better utilization of the  available spectrum.
Emergency Planning Subcommittee: Formulation and review of  emergency preparedness planning for government spectrum-dependant  systems.
Both the IRAC full committee and six IRAC subcommittees are chaired by  NTIA. From our interviews of IRAC representatives, we found that most  IRAC representatives are satisfied with the agencies that are members of  IRAC, the FCC liaison function, and the subcommittee missions.  Specifically, 15 of 20 representatives said that the appropriate agencies are  represented on IRAC. Seventeen IRAC representatives believe that  coordinating with FCC through a liaison appointed by FCC is appropriate,  and 15 representatives agreed that most of the time, IRAC and FCC work  well together. Thirteen of 19 IRAC representatives said that the missions of  the IRAC subcommittees are appropriate, given current and future  spectrum needs.
section_title: IRAC Representatives’ Assessment of IRAC Is Mostly Positive, but Some Are Concerned That an Uneven Level of Technical Knowledge and a Lack of Seniority Limit IRAC’s Effectiveness
paragraphs: IRAC representatives generally agree that IRAC is effective in coordinating  federal government spectrum use but are concerned about training and  succession planning. IRAC and its subcommittees perform various mission  tasks related to coordinating federal government spectrum use, including  frequency assignment, certification of spectrum-dependent equipment,  coordination of U.S. government positions for international conferences,  and registration of U.S. government satellite systems internationally. In our  interviews with IRAC representatives, they generally agreed that IRAC is  effectively accomplishing these spectrum coordination tasks. For example,  17 of 19 said that IRAC is very or mostly effective at assigning frequencies  in government-controlled spectrum, and 13 of 17 said that IRAC is very or  mostly effective at equipment certification for federal agencies. However,  training and succession planning issues could limit IRAC coordination  efforts. Eight representatives commented that some agency  representatives lack sufficient technical knowledge and/or understanding  of emerging technologies. This concern was also shared by 4 of the 6  subcommittee chairs, who believe that more technically knowledgeable  representatives would improve IRAC’s performance. The potential  shortage of spectrum specialists in agencies could also limit future IRAC  coordination efforts. Ten out of 20 representatives are already retirement  eligible, and 3 more will become eligible in less than 5 years. These  concerns are consistent with the human capital findings in our 2002 report  on needed improvements in spectrum management.
Greater concern was expressed about IRAC’s ability to fulfill its mission of  providing high level policy advice on national spectrum issues. NTIA  officials and IRAC representatives said that IRAC’s effectiveness in this  area is limited by the representatives’ lack of seniority. Seventeen out of 20  representatives said that national spectrum policy formation must occur at  a higher level than that held by current IRAC members. According to NTIA,  only one agency on IRAC has assigned a member of the senior executive  service as the agency representative to IRAC and 13 of the 20  representatives said that the assistant secretary who oversees spectrum  management in their agency has little or no direct involvement in spectrum  management. The chairman of IRAC (an NTIA senior executive) agrees  with the majority of IRAC representatives that current IRAC  representatives are not senior enough within their agencies to provide  policy advice on issues requiring either commercial or government users to  share or relinquish spectrum. He told us that he has gone outside of the  IRAC framework when he needed advice on such contentious policy  issues, such as those related to the introduction of new commercial  communications services. For example, the IRAC chairman said that he  directly contacted senior executives from the relevant agencies after he  was unable to obtain from the IRAC representatives viable advice on how  to make possible the introduction of commercial 3G and ultra wideband  services. Both services would require federal agencies to share or  relinquish spectrum under their control. The IRAC chairman said that he  supports more involvement of senior agency executives in IRAC.
As an advisor representing government spectrum concerns, IRAC must rely  on NTIA to negotiate with FCC in disputes between government and  commercial users over the use of spectrum. Most IRAC representatives  believe there should be a better way to resolve these disputes. When new  wireless technologies require access to government as well as commercial  spectrum, NTIA and FCC must cooperate in order to determine which  entity will have access to what spectrum. While IRAC must rely on NTIA to  negotiate with FCC to make those determinations, 10 of 20 IRAC  representatives have concerns about NTIA’s ability or willingness to  support the needs of government agencies.   Some representatives told us  they did not think either NTIA or the Department of Commerce is able to  protect the interests of government users; others told us that government  users could not be well represented by an agency whose primary mission is  to promote commercial interests. In addition, 14 IRAC representatives told  us that their primary concern in the next 1 to 3 years will be either the  availability of spectrum to fulfill agency missions or the threat of harmful  interference from new technologies. Although almost three quarters of the  20 representatives said that they believe that IRAC’s advice does influence  NTIA’s recommendations to the Assistant Secretary of Commerce, 13  representatives were able to cite important instances in which NTIA’s final  position differed significantly from IRAC’s advice. Of those instances in  which NTIA and IRAC differed, 7 IRAC representatives cited recent  decisions on issues of spectrum availability, such as 3G services, or  interference from new technologies, such as ultra wideband. Most IRAC  representatives said that a new process is needed to resolve disputes  between government and commercial users, but there was no consensus  among the representatives on what specifically would improve the process.
IRAC representatives have varying opinions on whether IRAC needs to be  reformed, and if it does, what those reforms should be. Eight of the 20  representatives agreed that IRAC’s organization and membership were well  suited to meet current and foreseeable challenges; 6 partially agreed with  that statement but thought some changes would improve IRAC.  Specifically, 4 representatives thought agency representatives should be  more knowledgeable or more senior, and 2 representatives said that IRAC  would be timelier in its decision-making if there were fewer members. Six  representatives did not believe that IRAC’s organization and membership  are well suited to meet current and foreseeable spectrum challenges.
The current IRAC chairman told us that he has instituted a number of  improvements in the past year designed to improve the efficiency and  effectiveness of IRAC. For example, the agendas for IRAC meetings are  made available electronically for representatives to review before meetings  and IRAC meeting minutes are now posted much faster than in the past.  The chairman remains concerned about the knowledge level of some of the  agency representatives and the number of IRAC representatives who are  eligible to retire. To improve the long-term participation by agencies, he has  explored the possibility of training and certifying spectrum managers.
A federal task force led by the Department of Commerce was conducting  its work concurrently with our review and completed its report on a wide  range of spectrum issues in late June 2004. The report included three  recommendations that fit within the scope of this report. It recommended:  (1) the government develop training programs for spectrum specialists;   (2) the Department of Commerce form a policy and plans steering group  comprised of assistant secretary-level officials from other agencies to  provide advice on spectrum policies, strategic plans, and contentious  issues; and (3) the existing White House Policy Coordinating Committee  should be used to address spectrum issues that could not be resolved by  the previously mentioned policy and plans steering group.
section_title: Conclusions
paragraphs: IRAC representatives generally concur that IRAC’s current structure and  membership are effective in dealing with key spectrum coordination tasks  that are at the core of its mission, including assigning frequencies,  certifying equipment, coordinating agency positions for international  spectrum conferences, and managing satellite issues. IRAC’s effectiveness  in these areas could be strengthened by increasing the level of technical  knowledge of some members and ensuring that agencies can provide  qualified representatives to replace current members as they reach  retirement.
When it comes to dealing with contentious policy issues requiring  negotiation between government and commercial users, however, IRAC  representatives questioned the effectiveness of IRAC’s current structure  and membership. There is a strong consensus that more senior-level agency  officials need to become involved in providing NTIA with advice on  contentious spectrum policy issues. While NTIA officials seek out such  senior-level advice as needed, this is an ad hoc process that occurs outside  the current framework of IRAC.
section_title: Recommendations for Executive Action
paragraphs: In order to improve the effectiveness of IRAC’s contribution in spectrum  management, we recommend that the Secretary of Commerce take the  following two actions:   Direct the Assistant Secretary of Commerce for Communications and  Information to seek IRAC’s assistance in establishing a set of best  practices in human capital for agencies that participate in IRAC that  include information on the appropriate knowledge and training levels  for IRAC representatives, goals for continuing education in emerging  technologies, and agency succession planning.
Establish a special committee within IRAC comprised of senior-level  agency officials to be convened by the Assistant Secretary of Commerce  for Communications and Information as needed to provide policy advice  on contentious spectrum policy issues, such as those requiring either  commercial or government entities to share or relinquish spectrum.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to NTIA, FCC, and the current IRAC  member agencies for their review. The Department of Agriculture, the  Department of the Treasury, National Science Foundation, NASA, and the  Broadcasting Board of Governors all said that they support the report and  its recommendations. The Departments of Justice, Health and Human  Services, Veterans Affairs, and the U.S. Postal Service and FCC did not have  any comments on the report. The Department of State (see letter at app. II),  and the Departments of Defense and Homeland Security offered technical  comments that we incorporated as appropriate.
The Department of Energy (DOE) supported the best practices in human  capital recommendation but indicated that a panel of independent experts  should rule on contentious issues (see letter at app. III). As there was no  consensus among the IRAC representatives as to how to resolve spectrum  policy disputes between government and commercial interests, we chose  not to make a recommendation on the issue. DOE also stated that the  report did not identify that IRAC representatives and NTIA officials do not  always share the same goals, an issue DOE views as a key contention with  regard to spectrum management. We did not change the report because it  already notes that fifty percent of IRAC representatives have concerns  about NTIA’s ability or willingness to support the needs of government  agencies. The Department of the Interior also agreed with the  recommendation to improve IRAC representatives’ technical skills but  disagreed with the recommendation to establish a senior-level committee  to provide advice on contentious policy issues. It indicated that such a  committee is not warranted because IRAC has no decision-making  authority (see letter at app. IV). We chose not to change the  recommendation because 17 of the 20 IRAC representatives and the IRAC  chairman believe that more senior-level involvement is needed in  formulating national spectrum policies. The Navy said that it agreed in  spirit with the report’s recommendations but suggested revising the  wording of the second recommendation (see letter at app. V).
The Department of Commerce agreed with our recommendation for  establishing best practices in human capital for the IRAC member agencies,  but also indicated, as did the Department of Transportation (DOT), that a  high level policy task force should be created within Commerce but outside  IRAC per the Federal Spectrum Task Force’s recommendation (see letter at  app. VI). The primary difference between the Federal Task Force  recommendation and ours is that the Federal Task Force recommended  that a group of senior agency executives be formed outside of IRAC to  advise on policy issues, and we recommended that the group be formed  within the structure of IRAC. We chose not to change the second  recommendation. As IRAC has been a stable, successful foundation for  spectrum coordination for more than 80 years, we believe that senior-level  executives of IRAC member agencies will be most able to provide useful  advice on contentious spectrum policy issues.
As agreed with your offices, we are providing copies of this report to the  appropriate congressional committees, the Department of Commerce,  FCC, IRAC member agencies, and others who are interested. We will also  make copies available to others who request them. In addition, the report  will be available on the GAO Web site at http://www.gao.gov. If you or your  staff members have any questions about this report, please contact me on  (202) 512-2834 or at Goldsteinm@gao.gov. Key contacts and staff  acknowledgments for this report are listed in appendix VII.
section_title: Briefing Slides
subsections: section_title: Fourteen of 20 IRAC reps told us that their primary
paragraphs: concern in the next 3 years will be the availability of  spectrum to fulfill agency missions and the threat of  harmful interference from new technologies.
Fourteen reps said that they believe that IRAC’s advice influences NTIA’s recommendations to the Assistant  Secretary of Commerce.
IRAC’s Advisory Role: IRAC Reps Have Concerns about NTIA’s Support (cont’d)
section_title: Thirteen reps were able to cite important instances in which NTIA’s final position differed significantly from IRAC’s advice.
paragraphs: For example, seven reps commented that NTIA’s  position on UWB differed from IRAC’s advice.
The IRAC Chairman said that NTIA takes IRAC’s advice very seriously, but it is under no obligation to accept the  advice.
IRAC reps’ opinions varied on how well-suited IRAC’s  organization and membership are to meet current and  foreseeable future spectrum management needs.
Those who partially agreed felt that IRAC adequately coordinates spectrum use but 4 reps felt that agency reps should be more knowledgeable and/or at a higher level of seniority; 2 felt that IRAC  membership should be decreased.
section_title: The Chairman told us that in the past year, he has
paragraphs: improved communication among members and tried to  make IRAC meetings and processes more efficient. For  example, meeting minutes are posted to the internet within 12-24 hours, in contrast with the situation in the  past in which minutes might not be posted for weeks,  even months, after a meeting.
He concurs with members’ perceptions of IRAC’s ability to  handle various aspects of spectrum coordination but not  provide high-level policy advice.
Reforms: Views and Actions of Current  IRAC Chairman (cont’d)
section_title: He is concerned about member agency succession
paragraphs: planning for IRAC reps. He said that the agency practice of  promoting a subcommittee rep to the full committee IRAC  rep is not always the best practice because different skill  sets are required.
He also believes that the current IRAC reps are not senior  enough to provide high level policy advice. He supports  strategies for promoting greater involvement by agency  senior executives.
section_title: Three Task Force recommendations fall within the scope of our work on IRAC.5
paragraphs: The government should develop training programs for spectrum specialists. This is consistent with our findings.
Commerce should form a policy and plans steering group comprised of assistant secretaries from other agencies to provide advice on spectrum policies, strategic plans, and contentious issues. This is consistent with our findings.
The existing White House Policy Coordinating Committee should be used to address spectrum issues that could not be resolved by the previously mentioned policy and plans steering group. We did not find wide consensus for an explicit White House role in spectrum management.
Spectrum Policy for the 21st Century—The President’s Spectrum Policy Initiative: Report 1 Recommendations of the Federal Government Spectrum Task Force, Michael D. Gallagher, Acting Assistant Secretary for Communications and Information, U.S. Department of Commerce, June 2004.
section_title: As it is currently structured, IRAC is not the appropriate
paragraphs: body to provide advice on sensitive spectrum policy issues.
Uneven training and knowledge among some reps can limit IRAC’s ability to fulfill its mission.
IRAC reps are not satisfied with the current negotiation process for resolving disputes between competing  government and commercial users, but they do not agree on  how to improve the process.
section_title: Promote human capital best practices for IRAC agencies that
paragraphs: Knowledge and training levels appropriate for IRAC reps,  Continuing education in emerging technologies, and   Planning for succession within IRAC member agencies.
Establish a special committee within IRAC comprised of senior  level agency officials to be convened by the Assistant Secretary of Commerce (NTIA Administrator) as needed to provide policy  advice directly to the Secretary of Commerce on sensitive  spectrum policy issues.
This is consistent with an existing open recommendation to the Secretary of Commerce from a 2002 report.  See GAO-02-906.
section_title: Comments from the Department of State
section_title: Comments from the Department of Energy
section_title: Comments from the Department of the Interior
section_title: Comments from the Department of the Navy
section_title: Comments from the Department of Commerce
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: In addition to the individuals named above, Keith Cunningham,   Brad Dubbs, Michele Fejfar, Alwynne Wilbur, and Nancy Zearfoss made key  contributions to this report.
section_title: Related GAO Products
paragraphs: Spectrum Management: Better Knowledge Needed to Take Advantage of  Technologies That May Improve Spectrum Efficiency. GAO-04-666.  Washington, D.C.: May 28, 2004.
Spectrum Management in Defense Acquisitions. GAO-03-617R.  Washington, D.C.: April 30, 2003.
Telecommunications: Comprehensive Review of U.S. Spectrum  Management with Broad Stakeholder Involvement Is Needed. GAO-03-277.  Washington, D.C.: January 31, 2003.
Telecommunications: Better Coordination and Enhanced Accountability  Needed to Improve Spectrum Management. GAO-02-906. Washington, D.C.:  September 30, 2002.
Telecommunications: History and Current Issues Related to Radio  Spectrum Management. GAO-02-814T. Washington, D.C.: June 11, 2002.
Defense Spectrum Management: More Analysis Needed to Support  Spectrum Use Decisions for the 1755-1850 MHz Band. GAO-01-795.  Washington, D.C.: July 20, 2001.
Defense Spectrum Management: New Procedures Could Help Reduce  Interference Problems. GAO-01-604. Washington, D.C.: May 17, 2001.
Telecommunications: Federal Communications Commission Spectrum  Management. RCED-89-62. Washington, D.C.: January 12, 1989.
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