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

Letter

IRAC’s Mission and Placement Have Evolved Since 1922

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.

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

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.

Conclusions

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.

Recommendations for Executive Action

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.

Agency Comments and Our Evaluation

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.

Briefing Slides

Fourteen of 20 IRAC reps told us that their primary

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)

Thirteen reps were able to cite important instances in which NTIA’s final position differed significantly from IRAC’s advice.

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.

The Chairman told us that in the past year, he has

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)

He is concerned about member agency succession

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.

Three Task Force recommendations fall within the scope of our work on IRAC.5

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.

As it is currently structured, IRAC is not the appropriate

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.

Promote human capital best practices for IRAC agencies that

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.

Comments from the Department of State

Comments from the Department of Energy

Comments from the Department of the Interior

Comments from the Department of the Navy

Comments from the Department of Commerce

GAO Contacts and Staff Acknowledgments

GAO Contacts

Acknowledgments

In addition to the individuals named above, Keith Cunningham, Brad Dubbs, Michele Fejfar, Alwynne Wilbur, and Nancy Zearfoss made key contributions to this report.

Related GAO Products

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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