Spectrum Management: NTIA Planning and Processes Need Strengthening to Promote the Efficient Use of Spectrum by Federal Agencies
Released: 2011-05-12T00:00:00

Letter

Background

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.

NTIA’s Strategic Spectrum Planning and Its Processes for Managing Federal Spectrum Lack Governmentwide Focus and Accountability

NTIA Has Conducted Spectrum Planning, yet Its Efforts to Address Strategic Governmentwide Spectrum Management Have Lacked Continuity

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.

NTIA’s Current Processes for Managing Federal Spectrum Focus on Interference Mitigation

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.

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

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.

Federal Agencies Use Spectrum for Many Purposes, and Lack of Specific Spectrum Management Requirements Leads to Limited Assurance That Agencies Are Recording Accurate Data

Federal Agencies Use Spectrum for a Wide Variety of Purposes, such as Emergency Communications, National Defense, and Land Management

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.

Federal Agencies Lack Specific Guidance and Requirements from NTIA for Recording and Maintaining Accurate Data

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.

Future Availability of Spectrum

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.

Inaccurate Data on Existing Systems

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.

Resource Constraints and Staff Coordination

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.

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

NTIA Has Identified Federally Assigned Spectrum to Be Made Available for Future Wireless Broadband Use

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.

Federal Agencies Reported Difficulties during the Fast Track Evaluation, Raising the Prospect for Future Challenges

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.

Industry Stakeholders Expressed Concerns with the Usefulness of the Identified Spectrum

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.

Conclusions

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.

Recommendations for Executive Action

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.

Agency Comments and Our Evaluation

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.

Appendix I: Objectives, Scope, and Methodology

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.

Appendix II: Summary of NTIA Projects Focused on Reforming Governmentwide Federal Spectrum Management and Increasing the Efficiency and Effectiveness of Federal Spectrum Use

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.

Appendix III: Survey of IRAC Agencies

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.

Appendix IV: Comments from the Department of Commerce

Appendix V: GAO Contact and Staff Acknowledgments

Staff Acknowledgments

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.