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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

November 2011: 

Commercial Spectrum: 

Plans and Actions to Meet Future Needs, Including Continued Use of 
Auctions: 

GAO-12-118: 

GAO Highlights: 

Highlights of GAO-12-118, a report to congressional committees. 

Why GAO Did This Study: 

The radio-frequency spectrum enables an array of wireless 
communications services that are critical to the U.S. economy and 
national security, such as wireless broadband. In 2010, a Federal 
Communications Commission (FCC) task force issued the National 
Broadband Plan that included recommendations to reform spectrum 
policy. Since 1994, FCC has used competitive bidding, or auctions, to 
assign licenses to commercial entities for their use of spectrum; 
however, its authority to use auctions expires on September 30, 2012. 

Among other things, GAO examined (1) the extent to which FCC has made 
spectrum available for new commercial uses and the time taken to do 
so, (2) experts’ and stakeholders’ views on FCC’s plans and recent 
actions to meet future spectrum needs, and (3) experts’ and 
stakeholders’ views on the continued use of auctions to assign 
spectrum. To address these objectives, GAO reviewed FCC’s plans, 
notices, and orders; reviewed six instances in which FCC made spectrum 
available for new commercial uses; and surveyed 30 experts and 79 
industry stakeholders about their views on FCC’s efforts to make 
spectrum available for new uses, its plans and actions to meet future 
needs, and its continued use of auctions (the survey had a 68 percent 
response rate). 

What GAO Found: 

Since 1994, FCC has made over 520 megahertz (a measure of quantity) of 
spectrum available for new uses, such as wireless broadband, through a 
process that can be lengthy. Because most of the usable spectrum in 
the United States has been allocated to existing uses, FCC must change 
its rules to move spectrum from an existing use to a new use, a 
process known as repurposing spectrum. Yet, this process can be 
lengthy-—from 7 to 15 years for the six repurposings that GAO 
reviewed. Four factors contribute to the time it takes FCC to 
repurpose spectrum: the regulatory nature of the process, which to 
some extent is guided by statute; opposition of incumbent users, who 
could be required to vacate spectrum; coordination challenges between 
FCC and the National Telecommunications and Information Administration 
(NTIA), which oversees federal agencies’ use of spectrum, on the 
repurposing of federal spectrum for commercial use; and concerns about 
interference from users of spectrum in adjacent bands of spectrum. FCC 
has identified voluntary approaches that it thinks could speed the 
process, but these approaches generally require congressional approval 
and face some stakeholder opposition. 

Experts and stakeholders had mixed views on FCC’s plans and recent 
actions to meet future spectrum needs. The National Broadband Plan 
included a set of recommendations to FCC, FCC and NTIA jointly, and 
Congress, aimed at meeting future spectrum needs. Some recommendations 
garnered broad support, including recommendations to auction certain 
bands of spectrum and enhance research and development. However, 
experts’ and stakeholders’ opinions diverged on other recommendations, 
such as reallocating a portion of spectrum from television to wireless 
broadband. Opinions also varied on FCC’s progress in implementing the 
recommendations. In some instances, these conflicting opinions arose 
from participants’ divergent positions in the industry, with, for 
example, incumbent licensees such as broadcasters opposing 
recommendations that they believe could impose burdens or costs on 
their businesses. 

Experts and stakeholders GAO contacted strongly supported extending 
FCC’s auction authority, but varied in their opinions on potential 
changes to auctions. Since 1994, FCC has used auctions to assign 
mutually exclusive licenses to commercial entities providing certain 
wireless services. GAO previously reported that auctions were 
effective in assigning licenses to entities that valued them the most; 
were quicker, less costly, and more transparent than mechanisms FCC 
previously used to assign licenses; and were an effective mechanism 
for the public to realize a portion of the value of a national 
resource used for commercial purposes. Experts and stakeholders 
responding to GAO’s survey strongly supported extending FCC’s auction 
authority—-53 of 65 respondents supported extending FCC’s authority. 
However, experts and stakeholders held varied opinions on potential 
changes to auctions. For example, respondents generally supported 
actions that would provide a clear road map detailing future auctions, 
which could reduce uncertainty. In contrast, a proposal to require 
winners of auctions to pay royalties based on their revenues rather 
than the full amount of their winning bids up front garnered the least 
support. 

What GAO Recommends: 

Given the continued support of FCC's use of auctions, Congress should 
consider extending FCC's auction authority beyond the current 
expiration date of September 30, 2012. FCC provided technical comments 
that were incorporated as appropriate. 

View [hyperlink, http://www.gao.gov/products/GAO-12-118]. For more 
information, contact Mark Goldstein at (202) 512-2834 or 
goldsteinm@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Since 1994, FCC Has Made Over 520 Megahertz of Spectrum Available for 
New Uses through a Process That Can Be Lengthy: 

Responding Experts and Stakeholders Had Mixed Views on FCC's Plans and 
Recent Actions to Meet Future Spectrum Needs: 

Responding Experts and Stakeholders Strongly Supported Extending FCC's 
Auction Authority but Varied in Their Opinions on Potential Changes to 
Auctions: 

Conclusions: 

Matter for Congressional Consideration: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: Federal Communications Commission's Spectrum-Related Data 
Systems: 

Appendix III: Expert and Stakeholder Respondents' Views on FCC's Plans 
and Recent Actions to Meet Future Spectrum Needs: 

Appendix IVGAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Major Spectrum Repurposings since 1994: 

Table 2: Expert and Stakeholder Respondents' Agreement with National 
Broadband Plan Recommendations Aimed at Making More Spectrum Available 
for Wireless Broadband Use by 2015: 

Table 3: Expert and Stakeholder Respondents' Satisfaction with FCC's 
Progress in Making More Spectrum Available for Wireless Broadband Use 
by 2015: 

Table 4: Expert and Stakeholder Respondents' Agreement with National 
Broadband Plan Recommendations Aimed at Expanding Incentives and 
Mechanisms to Reallocate Spectrum: 

Table 5: Expert and Stakeholder Respondents' Satisfaction with FCC's 
Progress in Identifying and Addressing Barriers to Secondary Markets: 

Table 6: Expert and Stakeholder Respondents' Agreement with National 
Broadband Plan Recommendations Aimed at Expanding Opportunities for 
Innovative Spectrum Access Models: 

Table 7: Expert and Stakeholder Respondents' Satisfaction with FCC's 
Progress on National Broadband Plan Recommendations Aimed at Expanding 
Opportunities for Innovative Spectrum Access Models: 

Table 8: Expert and Stakeholder Respondents' Agreement with Extending 
FCC's Auction Authority: 

Table 9: Expert and Stakeholder Respondents' Agreement with Potential 
Changes to FCC's Auction Policies: 

Table 10: Description of FCC Data Systems: 

Table 11: Summary of Survey Responses of Extent to Which FCC Data 
System Provides Desired Type of Information: 

Table 12: Summary of Survey Responses for Inaccurate Data: 

Table 13: Summary of Survey Responses for Missing Data: 

Table 14: Summary of Survey Responses for User-Friendliness: 

Table 15: Summary of FCC's Data Quality Procedures for Spectrum-
Related Data Systems: 

Figures: 

Figure 1: Examples of Services by Frequency Band: 

Figure 2: Timeline for Major Spectrum Repurposings--Identification to 
Reassignment: 

Figure 3: Process to Repurpose Spectrum from an Existing Use to a New 
Use: 

Abbreviations: 

AWS: Advanced Wireless Services: 

BBA-97: Balanced Budget Act of 1997: 

BRS: Broadband Radio Service: 

CLS: Consolidated Licensing System: 

COALS: Cable Operations and Licensing System: 

EBS: Educational Broadband Service: 

ESMR: Enhanced Specialized Mobile Radio: 

FCC: Federal Communications Commission: 

GHz: gigahertz: 

ITU: International Telecommunication Union: 

kHz: kilohertz: 

MHz: megahertz: 

MSS: Mobile Satellite Services: 

NPRM: Notice of Proposed Rulemaking: 

NTIA: National Telecommunications and Information Administration: 

PCS: Personal Communications Service: 

R&D: research and development: 

TV: television: 

Wi-Fi: wireless fidelity: 

United States Government Accountability Office: 
Washington, DC 20548: 

November 23, 2011: 

The Honorable Fred Upton:
Chairman:
The Honorable Henry A. Waxman:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives: 

The Honorable John D. Rockefeller IV:
Chairman:
The Honorable Kay Bailey Hutchison:
Ranking Member:
Committee on Commerce, Science, and Transportation:
United States Senate: 

The Honorable Greg Walden:
Chairman:
The Honorable Anna G. Eshoo:
Ranking Member:
Subcommittee on Communications and Technology:
Committee on Energy and Commerce:
House of Representatives: 

The radio-frequency spectrum is a natural resource used to provide an 
array of wireless communications services that are critical to the 
U.S. economy and national security, such as mobile voice and data 
services, radio and television broadcasting, radar, and satellite-
based services. Demand for radio-frequency spectrum has exploded over 
the past several decades as new technologies and services have been 
and continue to be brought to the market in the private sector and new 
mission needs unfold among government users of spectrum, including 
wireless communications critical for public safety officials 
responding to natural and man-made disasters. As a result, nearly all 
parties are becoming increasingly concerned about the availability of 
spectrum for future needs, because most of the usable spectrum in the 
United States has already been allocated to existing services and 
users. These concerns are compounded by evidence that some of the 
spectrum is currently underutilized. Therefore, to promote more 
efficient use of this resource and meet future needs, the Federal 
Communications Commission (FCC) has increasingly adopted more market-
oriented approaches to spectrum management in recent years, including 
using a competitive bidding process, or auctions, to assign spectrum 
licenses to commercial users. From 1994, when FCC first implemented 
its auction authority, through June 30, 2011, FCC held 79 auctions for 
over 68,000 licenses to select between competing applications for the 
same license, and generated nearly $52 billion for the U.S. Treasury. 
In addition, in March 2010, an FCC task force issued the National 
Broadband Plan aimed at achieving affordability and maximizing the use 
of broadband, or high-speed Internet access, to advance a range of 
economic and civic goals.[Footnote 1] Because broadband access and use 
is becoming increasingly mobile and wireless, the plan included a set 
of recommendations aimed at ensuring efficient allocation and use of 
radio-frequency spectrum for wireless broadband services.[Footnote 2] 
In some instances, the plan recommends that FCC change its rules to 
move certain bands of spectrum from an existing use, such as 
television broadcasting, to new uses, such as wireless broadband, a 
process known as repurposing spectrum. 

In response to your request to review FCC's management of commercial 
spectrum,[Footnote 3] we examined (1) the extent to which FCC has made 
spectrum available for new commercial uses since it implemented 
auction authority in 1994 and the time taken to do so, (2) experts' 
and stakeholders' views on FCC's plans and recent actions to meet 
future spectrum needs, and (3) experts' and stakeholders' views on the 
continued use of auctions to assign spectrum. In addition, we examined 
the extent to which FCC seeks to ensure the quality of its data on 
commercial spectrum licenses (see appendix II). 

To address these issues, we reviewed FCC's plans, notices, orders, and 
other publications. We interviewed officials at FCC and analyzed FCC's 
quality control processes for its four spectrum license databases--the 
Universal Licensing System, the Consolidated Database System, the 
International Bureau Filing System, and the Experimental Licensing 
System--and for FCC's database of authorizations of equipment using 
the radio frequency spectrum, the Equipment Authorization System. We 
reviewed six instances since 1994 in which FCC made spectrum available 
by repurposing it for new commercial uses; we limited our analysis to 
repurposings that involved substantial amounts of spectrum that were 
repurposed to a higher value use.[Footnote 4] We reviewed the National 
Broadband Plan and reports and orders related to FCC's implementation 
of the plan. We also reviewed industry comments on the plan and FCC's 
steps to implement the plan. In addition, we surveyed 30 experts and 
79 industry stakeholders about their views on FCC's licensing data, 
the amount of time it takes FCC to reallocate spectrum for new 
commercial uses, the recommendations in the National Broadband Plan's 
chapter on spectrum,[Footnote 5] FCC's steps to implement those 
recommendations, and the continued use of auctions to assign spectrum. 
We selected the experts and stakeholders based on their expertise in 
spectrum policy as represented by presentations or publications, or on 
their organization's vested interest in spectrum policy. Twenty of the 
experts and 54 of the stakeholders responded to our survey, 
representing a 68 percent response rate. Because we selected a 
nonprobability sample of experts and industry stakeholders, the 
information we obtained from the survey may not be generalized to all 
experts and industry stakeholders who have an interest in spectrum 
policy. We also conducted semistructured interviews with 
representatives of academia, industry, and public interest groups. 
(See appendix I for additional information on our scope and 
methodology.) We conducted this performance audit from August 2010 to 
November 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. 

Background: 

The radio-frequency spectrum is the part of the natural spectrum of 
electromagnetic radiation lying between the frequency of 3 kilohertz 
(kHz) and 300 gigahertz (GHz).[Footnote 6] It is the medium that makes 
possible wireless communications and supports a vast array of 
commercial and governmental services. Commercial entities use spectrum 
to provide a variety of wireless services, including mobile voice and 
data, paging, broadcast television and radio, and satellite services. 
Federal, state, and local agencies use spectrum to fulfill a variety 
of government missions, such as national defense, air-traffic control, 
weather forecasting, and public safety. 

Spectrum is managed at the international and national levels. The 
International Telecommunication Union (ITU), a specialized agency of 
the United Nations, coordinates spectrum management decisions among 
nations. Spectrum management decisions generally require international 
coordination, since radio waves can cross national borders. Once 
spectrum management decisions are made at the ITU, regulators within 
each nation, to varying degrees, follow the ITU decisions. In the 
United States, responsibility for spectrum management is divided 
between two agencies: FCC and the Department of Commerce's National 
Telecommunications and Information Administration (NTIA). FCC manages 
spectrum use for nonfederal users, including commercial, private, and 
state and local government users under authority provided in the 
Communications Act[Footnote 7]. NTIA manages spectrum for federal 
government users and acts for the President with respect to spectrum 
management issues. FCC and NTIA, with direction from Congress and the 
President, jointly determine the amount of spectrum allocated to 
federal and nonfederal users, including the amount allocated to shared 
use. 

Historically, concern about interference or crowding among users has 
been a driving force in the management of spectrum. FCC and NTIA work 
to minimize interference through two primary spectrum management 
functions--the "allocation" and the "assignment" of radio spectrum. 
Specifically: 

* Allocation involves segmenting the radio spectrum into bands of 
frequencies that are designated for use by particular types of radio 
services or classes of users. For example, the frequency bands from 88 
to 108 MHz are allocated to FM radio broadcasting in the United 
States. (figure 1 illustrates examples of services by frequency band.) 
In addition to allocation, spectrum managers specify service rules, 
which include the technical and operating characteristics of equipment. 

Figure 1: Examples of Services by Frequency Band: 

[Refer to PDF for image: illustration] 

Examples of general use: Maritime navigation signals; 
Frequency: 3 kHz to 30 kHz. 

Examples of general use: Navigational aids; 
Frequency: 30 kHz to 300 kHz. 

Examples of general use: AM radio, Maritime radio; 
Frequency: 300 kHz to 3 MHz. 

Examples of general use: Shortwave radio; 
Frequency: 3 MHz to 30 MHz. 

Examples of general use: Broadcast television, FM radio; 
Frequency: 30 MHz to 300 MHz. 

Examples of general use: Broadcast television, Cellular telephone; 
Frequency: 300 MHz to 3 GHz. 

Examples of general use: Space and satellite communications, Microwave 
systems; 
Frequency: 3 GHz to 30 GHz. 

Examples of general use: Radio astronomy; 
Frequency: 30 GHz to 300 GHz. 
      
Source: GAO analysis of NTIA and industry information. 

[End of figure] 

* Assignment, which occurs after spectrum has been allocated for 
particular types of services or classes of users, involves providing 
users, such as commercial entities or government agencies, with a 
license or authorization to use a specific portion of spectrum. For 
example, FCC assigned a license for the 88.5 MHz band in Washington, 
D.C., to American University, for its radio station, WAMU. FCC assigns 
licenses for frequency bands to commercial enterprises, state and 
local governments, and other entities, while NTIA makes frequency 
assignments to federal agencies. 

In some frequency bands, FCC authorizes unlicensed use of spectrum--
that is, users do not need to obtain a license to use the spectrum. 
Rather, an unlimited number of unlicensed users can share frequencies 
on a noninterference basis. Thus, the assignment process does not 
apply to the use of unlicensed spectrum. However, manufacturers of 
unlicensed equipment must receive authorization from FCC before 
operating or marketing an unlicensed device. Traditional unlicensed 
equipment consists of low-powered devices that operate in a limited 
geographic range, such as cordless phones, baby monitors, garage door 
openers, and wireless access to the Internet. 

When FCC assigns a portion of spectrum to a single entity, the license 
is considered exclusive. When two or more entities apply for the same 
exclusive license, FCC classifies these as mutually exclusive 
applications--that is, the grant of a license to one entity would 
preclude the grant to one or more other entities. Since 1994, FCC has 
primarily used auctions to assign spectrum for mutually exclusive 
applications. Auctions are a market-based mechanism in which FCC 
assigns a license to the entity that submits the highest bid for 
specific bands of spectrum. FCC was provided with authority to use 
auctions to assign mutually exclusive licenses for certain subscriber-
based wireless services[Footnote 8] in the Omnibus Budget 
Reconciliation Act of 1993.[Footnote 9] FCC implemented its auction 
authority conducting its first auction in 1994.[Footnote 10] In 
subsequent years, Congress has modified and extended FCC's auction 
authority, including exempting some licenses from competitive bidding, 
such as licenses for public safety radio services and noncommercial 
educational broadcast services.[Footnote 11] FCC's auction authority 
is scheduled to expire on September 30, 2012.[Footnote 12] 

As of June 30, 2011, FCC had conducted 79 auctions to select between 
competing applications for the same license, which have generated 
nearly $52 billion for the U.S. Treasury. However, only about 3 
percent of licenses have been auctioned. The vast majority of the 
other 97 percent of licenses were assigned through other means before 
FCC began using auctions. 

In March 2010, an FCC task force issued the National Broadband Plan. 
Because broadband access and use is becoming increasingly wireless, 
the plan includes a set of recommendations aimed at ensuring efficient 
allocation and use of radio-frequency spectrum for wireless broadband 
services. The plan recommended that FCC make 300 MHz of spectrum newly 
available for mobile broadband use in the next 5 years and 500 MHz of 
spectrum for broadband within the next 10 years. In June 2010, the 
President issued a memorandum with a similar goal for NTIA working in 
collaboration with FCC.[Footnote 13] 

Since 1994, FCC Has Made Over 520 Megahertz of Spectrum Available for 
New Uses through a Process That Can Be Lengthy: 

To accommodate new commercial uses of spectrum, such as wireless 
broadband, FCC must often change its rules to move certain bands of 
spectrum from an existing use to the new use, a process known as 
repurposing spectrum. However, this process can be lengthy--from 7 to 
15 years for the six repurposings that we examined. We identified the 
following factors that contribute to the time it takes FCC to 
repurpose spectrum: the regulatory nature of repurposing, opposition 
of incumbent users, FCC and NTIA coordination on the repurposing of 
federal spectrum, and concerns about interference. FCC identified 
voluntary approaches that it thinks could speed the process by, for 
example, avoiding some opposition; however, these approaches generally 
require congressional approval and face some stakeholder opposition. 

FCC Uses a Multiphase Process to Repurpose Spectrum: 

Since most of the usable spectrum in the United States has been 
allocated to existing uses, FCC must often repurpose spectrum from an 
existing use to make it available for new uses. When there are 
competing interests for specific spectrum, FCC determines which use or 
uses of the spectrum will best serve the public interest, considering 
factors such as economic and social value, including importance for 
public safety. FCC also seeks to ensure that the spectrum is 
technically suitable for the new use.[Footnote 14] To repurpose 
spectrum for a new use, FCC uses a three-phase process: 

* Identification. As a first step, FCC identifies a spectrum band, or 
bands, that appear to be good candidates for repurposing. To identify 
candidate bands, FCC conducts a formal study or releases a notice of 
proposed rulemaking soliciting industry input, or another party, such 
as NTIA or Congress, identifies a candidate band. 

* Reallocation. FCC subsequently reallocates the spectrum by changing 
the designated use of the spectrum. FCC develops service and other 
technical rules for the spectrum that define (1) the eligibility 
criteria for users, (2) the services that users can provide, (3) the 
time frames and other requirements for users to build the 
infrastructure required to support the services, and (4) the 
interference limits. 

* Reassignment or secondary markets. If the new use entails a licensed 
use of the spectrum, new users must be assigned, or provided 
authorization, to use the spectrum. In some cases, FCC reassigns the 
spectrum to new entities, often using auctions. In other cases, FCC 
permits incumbent licensees to sell or lease their licenses to other 
entities, through a process known as secondary market transactions. If 
the new use entails an unlicensed use of the spectrum, FCC does not 
need to complete a reassignment. 

FCC Has Made Over 520 Megahertz of Spectrum Available for New 
Commercial Uses: 

Since 1994, FCC has completed six major repurposings of spectrum, 
which have made over 520 MHz of spectrum available for new commercial 
uses.[Footnote 15] In most instances, FCC repurposed the spectrum to 
enable mobile broadband service. Five of the six repurposings 
collectively generated over $47 billion in auction revenues, which 
provides one measure of the new economic value arising from the 
repurposing.[Footnote 16] The former uses of the repurposed spectrum 
included microwave services, specialized mobile radio services (such 
as those used in radio dispatch systems), and one-way systems that 
transmit video (see table 1). 

Table 1: Major Spectrum Repurposings since 1994: 

Dollars in millions: 

Spectrum band: Mobile Satellite Services S band (MSS S band); 
Amount repurposed (MHz): 40; 
Old use: Microwave operations by broadcast stations for transmitting 
audio and video signals. 
New use: Satellite-based mobile voice, data, Internet access, and 
other communications. 
Auction revenues: N/A[A]. 

Spectrum band: Broadband Personal Communications Service (PCS); 
Amount repurposed (MHz): 120; 
Old use: Microwave operations by business users, including petroleum 
companies, utilities, and railroads. 
New use: Primarily digital mobile phones and wireless Internet access. 
Auction revenues: $13,989. 

Spectrum band: Advanced Wireless Services-1 (AWS-1); 
Amount repurposed (MHz): 90; 
Old use: Federal government use, including military tactical radios, 
and commercial fixed-microwave uses. 
New use: Third-generation mobile broadband and other advanced wireless 
services. 
Auction revenues: $13,731. 

Spectrum band: Enhanced Specialized Mobile Radio (ESMR); 
Amount repurposed (MHz): 14; 
Old use: Mobile radios that communicated directly with other mobile or 
fixed radios in a dispatch mode, such as taxi fleets, or that 
interconnected with the public telephone network through the use of a 
base station. 
New use: Cellular-based services including Internet access, two-way 
acknowledgment paging and inventory tracking, credit card 
authorization, automatic vehicle location, fleet management, remote 
database access, and voice mail. 
Auction revenues: $445. 

Spectrum band: Educational Broadband Service/Broadband Radio Service 
(EBS/BRS); 
Amount repurposed (MHz): 194; 
Old use: Educational Broadband Service: transmission of instructional 
material using high-powered systems to accredited educational 
institutions and other institutions such as hospitals, nursing homes, 
and training and rehabilitation centers. Broadband Radio Service: 
primarily high-powered, one-way systems transmitting data and video to 
fixed locations. 
New use: Educational Broadband Service: transmission of instructional 
services, using low power, broadband systems, as well as high-speed 
Internet access for students. Licensees may also lease excess capacity 
to other entities so long as they meet educational programming 
requirements. Broadband Radio Service: two-way wireless broadband 
services, including voice, data, and video. 
Auction revenues: $134. 

Spectrum band: 700 MHz band; 
Amount repurposed (MHz): 70; 
Old use: Analog broadcast television[B]; 
New use: Mobile wireless services. 
Auction revenues: $19,108. 

Spectrum band: Total; 
Amount repurposed (MHz): 528; 
Auction revenues: $47,407. 

Source: GAO review of FCC documents. 

[A] FCC did not use an auction to reassign the Mobile Satellite 
Services S band; 

rather FCC reassigned the spectrum to eight companies that applied for 
licenses. The Satellite Industry Association estimates that Mobile 
Satellite Services generated over $2 billion in worldwide revenue in 
2010. 

[B] The 700 MHz Wireless repurposing was enabled by the transition of 
television from analog to digital service. The transition freed up a 
portion of the 700 MHz spectrum for new wireless services. 

[End of table] 

Major Spectrum Repurposings Can Be Time Consuming: 

The six major repurposings we reviewed took from 7 to 15 years to 
complete, from the identification through the reassignment phase. For 
example, the Enhanced Specialized Mobile Radio repurposing took 7 
years while three repurposings--Personal Communications Service, 
Advanced Wireless Services-1, and 700 MHz Wireless--took over 10 years 
to complete (see figure 2). Similar to our findings, in the National 
Broadband Plan, FCC noted that the process of revisiting or revising 
spectrum allocations has historically taken 6 to 13 years.[Footnote 17] 

Figure 2: Timeline for Major Spectrum Repurposings--Identification to 
Reassignment: 

[Refer to PDF for image: illustration] 

MSS S band (40 MHz): 1992-2001. 

PCS (120 MHz): 1992-2005. 

AWS-1 (90 MHz): 1992-2006. 

ESMR (14 MHz): 1993-2000. 

EBS/BRSD (194 MHz): 1997-2006. 

700 MHz wireless (70 MHz): 1997-2008. 

Source: GAO. 

[End of figure] 

In addition to the time required to complete the repurposing process 
(identification through reassignment), time is needed to relocate 
existing users and allow new users to construct new wireless networks 
before new services can be made available using the repurposed 
spectrum. Typically, existing users must relocate to a new spectrum 
band or bands, and new users must construct the infrastructure 
required to support their services. While the participants undertake 
most of these actions, FCC and other government agencies' actions and 
decisions can influence the time frames. For example, FCC held the 
first auction for the Advanced Wireless Services-1 repurposing in 
2006, but NTIA expects that it will take until 2013 for all federal 
agencies to relocate from the spectrum that was repurposed for 
commercial use.[Footnote 18] In addition, FCC allowed licensees 15 
years from the inception of their license term to begin providing 
substantial service.[Footnote 19] Therefore, substantial service on a 
widespread basis using the Advanced Wireless Services-1 spectrum 
appears unlikely before 2013 and, in theory, could extend to 2021, 
fully 29 years after the beginning of the identification phase, 
although FCC officials anticipate that carriers will generally provide 
service sooner in order to meet their business needs. 

Large majorities of stakeholders and experts that replied to our 
survey indicated that the repurposing process takes too long. In 
particular, 39 of 46 stakeholders and 16 of 20 experts reported that 
it takes longer than it should from the time FCC or Congress 
designates a spectrum band for reallocation until the band is 
available for the new use. Furthermore, 25 of these stakeholders and 
11 of these experts reported that it takes much longer than it should. 

Several Factors Contribute to the Lengthiness Repurposing Process: 

Based on our review of several completed and ongoing repurposings, the 
relevant literature, interviews with agency officials and industry 
participants, and our survey of stakeholders and experts, we 
identified four factors that contribute to the time it takes FCC to 
repurpose spectrum. These factors include the regulatory nature of 
repurposing, opposition of incumbent users, FCC and NTIA coordination 
on the repurposing of federal spectrum, and concerns about 
interference. 

* Regulatory nature of repurposing. FCC's repurposing of spectrum is 
often an iterative process involving deliberation based on extensive 
industry participation. As shown in figure 3, the repurposing of 
spectrum can involve stakeholder coordination efforts, issuance of 
notices of proposed rulemaking and reports and orders, review of 
stakeholder comments and reply comments, and multiple rounds of 
assignment. For example, during the Personal Communications Service 
repurposing, FCC adopted an order in September 1993, and 67 
participants subsequently petitioned FCC for reconsideration because 
of concerns about the spectrum to be reallocated and the amount of 
spectrum to be individually licensed.[Footnote 20] In response, in 
June 1994, FCC amended the bands to be reallocated and assigned. 
[Footnote 21] In 1995, some stakeholders sued the Commission over the 
rules it established in 1994 pertaining to ownership limitations in 
the wireless communications industry. In November 1995, the Sixth 
Circuit Court of Appeals decided against FCC's rules and remanded the 
matter for further proceeding.[Footnote 22] In June 1996, FCC issued 
an order addressing these issues.[Footnote 23] 

Figure 3: Process to Repurpose Spectrum from an Existing Use to a New 
Use: 

[Refer to PDF for image: process illustration] 

Identification: 

1) Need for reallocation identified. 

Reallocation: 

2) Congress may pass law. 

3) Research and coordination among potential stakeholders (FCC, NTIA, 
federal agencies, industry). 

4) FCC issues Notice of Proposed Rulemaking (NPRM). 

5) Stakeholders file and reply to comments on NPRM. 

6) FCC publishes Order. 

7) Stakeholders may petition for reconsideration (return to step 4, or 
continue). 

8) FCC may issue an amended decision. 

9) Court ruling can amend decision or change auction rules (return to 
step 4, or go to step 11). 

Reassignment: 

10) FCC enables reassignment by permitting secondary market 
transactions.[A] 

11) Spectrum auctioned,[B] sometimes repeatedly, because blocks are 
unsold or winners do not meet FCC's terms.   

Source: GAO review of FCC documents. 

[A] FCC may permit incumbent licensees to sell or lease their licenses 
to other entities, a process known as secondary market transactions. 

[B] Certain exemptions apply to FCC's auction authority, including 
exemptions for public safety radio, digital television licenses to 
replace analog licenses, and noncommercial educational and public 
broadcast stations. 

[End of figure] 

As also shown in figure 3, the assignment and, in some instances 
multiple reassignments, of spectrum can lengthen the process of 
repurposing spectrum. In some cases, prior to an auction and at the 
direction of Congress or the courts, or the request of licensees and 
potential bidders, FCC clarifies or revises the auction and relocation 
rules. For example, in providing auction authority, which occurred 
during the Personal Communications Service repurposing, Congress 
directed FCC to expand opportunities for small businesses, minorities, 
and women.[Footnote 24] FCC subsequently adopted competitive bidding 
rules designed to encourage designated entities participation in 
Personal Communications Service.[Footnote 25] However, 3 days before 
the auction, the U.S. Supreme Court decided that "all racial 
classifications, imposed by whatever federal, state, or local 
government actor, must be analyzed by a reviewing court under strict 
scrutiny" and the Commission subsequently postponed the auction. 
[Footnote 26] In other instances, the bankruptcy or default of an 
auction winner lengthened the repurposing of spectrum.[Footnote 27] On 
several occasions, after winners of the original auction declared 
bankruptcy or defaulted on their payments, FCC repeated auctions. For 
example, FCC's auctions 10, 22, and 35 included reauctions of licenses 
won at prior auctions. 

* Opposition of incumbent users. The completed repurposings we 
reviewed involved opposition from incumbent users that took time to 
resolve. Incumbent users are likely to incur costs for relocating but 
derive little, if any, benefit and are therefore often reluctant to 
make a move. For example, during the Personal Communications Service 
repurposing, incumbent microwave users, which included utilities, 
public safety entities, and petroleum and natural gas companies, 
raised concerns that an allocation would displace a large number of 
them, disrupt their operations to the detriment of the public, and 
require them to purchase new equipment. In the Advanced Wireless 
Services-1 repurposing, incumbent government agencies had difficulties 
identifying current users of the spectrum and were reluctant to give 
up spectrum because they believed the spectrum was critical to 
fulfilling their mission and that relocating would cause them to incur 
staff time and expenses for which they had not budgeted. In the 700 
MHz Wireless repurposing, television broadcasters raised concerns 
about the transition from analog to digital television, including 
their need to use more spectrum for advanced television services and 
the financial costs of building digital television stations. A law 
firm with experience in FCC's repurposings characterized reallocations 
as "contests between incumbent service providers and the new entrants 
competing to unseat them." 

* FCC and NTIA coordination on the repurposing of federal spectrum. 
Government efforts to coordinate the repurposing of federal spectrum 
to commercial use can take many years; several factors contribute to 
the lengthy time frame, including the lack of data and resources and 
the time necessary to relocate existing federal users. For example, 
the Advanced Wireless Services-1 repurposing, which combined federal 
and nonfederal spectrum, took over 14 years and the passage of several 
laws to complete. In 1992, FCC first identified the upper Advanced 
Wireless Services-1 band, 2110-2150 MHz, for reallocation to services 
using new and innovative technologies.[Footnote 28] In 1995, NTIA 
identified the lower Advanced Wireless Services-1 band, 1710-1755 MHz, 
for transfer from exclusive use by the federal government to FCC for 
commercial use.[Footnote 29] In 1997 legislation was enacted that 
required NTIA to accelerate the availability of the lower Advanced 
Wireless Services-1 band, and in 1998 legislation was enacted that 
sought to encourage the transfer of spectrum from federal government 
to private use by providing for mandatory reimbursement of government 
spectrum users required to relocate from their spectrum, including the 
lower Advanced Wireless Services-1 band.[Footnote 30] From 2000 
through 2002, FCC and NTIA conducted further studies to determine 
appropriate bands for Advanced Wireless Services-1. Finally, in 2002, 
NTIA issued a study[Footnote 31] and FCC issued an order[Footnote 32] 
allocating 90 MHz for Advanced Wireless Services. 

* Concerns about interference. Users in adjacent bands often oppose a 
repurposing of spectrum because they are concerned that the new 
service will interfere with their existing service. A good example of 
this concern arises with the 700 MHz Wireless repurposing, which 
included the relocation of broadcast television stations; public 
safety organizations raised the concern that the proposed relocation 
would result in increased interference between broadcasting and public 
safety operations. Similarly, with the Advanced Wireless Services-1 
repurposing, some stakeholders raised concerns about the potential for 
interference between Multipoint Distribution Service licensees and 
Advanced Wireless Services systems.[Footnote 33] 

Resolving issues such as the opposition of incumbent users and 
concerns about interference lengthens the time necessary to complete 
the repurposing of spectrum, thereby delaying the introduction of 
possibly more economically valuable services. As an independent 
regulatory agency, FCC must follow many, but not all, federal laws 
related to rulemaking. In particular, the Administrative Procedures 
Act outlines a multistep process to initiate and develop rules and 
includes provisions for parties to challenge them, which FCC must 
follow.[Footnote 34] Many steps require agencies to provide public 
notice of proposed or final actions, as well as provide a period of 
time for interested parties to comment on the notice. Furthermore, the 
Communications Act outlines procedures for addressing petitions for 
reconsideration by FCC and appeals to federal court for FCC rules; 
[Footnote 35] the U.S. Courts of Appeals have jurisdiction to review 
all final FCC rules.[Footnote 36] Given that the spectrum issues are 
often complicated and controversial, FCC often issues multiple orders 
in the same proceeding to deal with the many comments it receives and 
to address petitions for reconsideration, as well as any direction 
from the courts. In the National Broadband Plan, FCC identified 
voluntary approaches, such as incentive auctions, that it thinks could 
speed the process. By incorporating incentives into the process, FCC 
may avoid some opposition to repurposings and thereby reduce the time 
necessary to repurpose spectrum. However, these incentive approaches 
generally require congressional approval and face stakeholder 
opposition themselves. As we reported in 2003, "while spectrum reform 
is increasingly being discussed, debated, and reviewed, it does not 
appear likely that timely reforms can be agreed upon amid the 
diversity of views held by stakeholders," a situation that appears to 
hold to this day.[Footnote 37] 

Responding Experts and Stakeholders Had Mixed Views on FCC's Plans and 
Recent Actions to Meet Future Spectrum Needs: 

The National Broadband Plan includes recommendations in several areas 
aimed at meeting future spectrum needs. Most of the recommendations 
are directed at FCC alone, some are directed at FCC and NTIA jointly, 
and some are directed at Congress. For our analysis, we group the 
recommendations directed to FCC into five categories: make more 
spectrum available for wireless broadband use by 2015, expand 
incentives and mechanisms to reallocate spectrum, expand opportunities 
for innovative spectrum access models, enhance the usefulness of 
spectrum for wireless backhaul, and enhance FCC's spectrum policy 
making. Discussion of the first three categories follows; appendix III 
provides additional details on those three categories and also 
discusses the last two categories. 

Responding Experts and Stakeholders Generally Agreed with Making More 
Spectrum Available for Wireless Broadband Use by 2015: 

Recommendations in Plan: 

To meet anticipated increases in demand for wireless broadband 
services, the plan contained a recommendation that FCC make 300 MHz of 
spectrum newly available for such services by 2015 and 500 MHz by 
2020. These targets were based on an FCC staff forecast of spectrum 
demand. In the plan, the largest source of spectrum--120 MHz--arises 
from the repurposing of a portion of the spectrum currently allocated 
for broadcast television service. Most experts and stakeholders other 
than television broadcasters responding to our survey supported this 
recommendation, while most responding broadcasters opposed it (see 
table 2). Both a wireless device manufacturer and an expert said that 
the recommendation is consistent with expected increases in demand for 
spectrum. Two broadcasters said that wireless service providers could 
meet additional demand by using their existing spectrum more 
intensively. 

To make 300 MHz of spectrum newly available by 2015, the plan included 
five recommendations related to specific spectrum bands. In addition 
to repurposing the 120 MHz of spectrum currently allocated to 
broadcast television, the plan recommended accelerating terrestrial 
use of Mobile Satellite Services spectrum by providing sufficient 
flexibility to licensees to increase terrestrial broadband use of the 
spectrum, auctioning Advanced Wireless Services and the Upper 700 MHz 
D-Block spectrum,[Footnote 38] and revising outdated interference 
rules in the Wireless Communications Services spectrum that largely 
preclude the use of the spectrum for broadband. These recommendations, 
as well as experts' and stakeholders' level of agreement with the 
recommendations, are shown in table 2; in the table, we sometimes 
separately report broadcasters to illustrate meaningful differences in 
their responses. 

Table 2: Expert and Stakeholder Respondents' Agreement with National 
Broadband Plan Recommendations Aimed at Making More Spectrum Available 
for Wireless Broadband Use by 2015: 

Recommendation in plan: Overall recommendation: 
Make 300 MHz available by 2015 and 500 MHz by 2020. 

Type of respondent: Expert; 
Agreed: 16; 
Neither agreed nor disagreed: 0; 
Disagreed: 3; 
Total: 19. 

Type of respondent: Stakeholder - broadcaster; 
Agreed: 0; 
Neither agreed nor disagreed: 2; 
Disagreed: 8; 
Total: 10. 

Type of respondent: Stakeholder - nonbroadcaster; 
Agreed: 28; 
Neither agreed nor disagreed: 4; 
Disagreed: 6; 
Total: 38. 

Type of respondent: Total; 
Agreed: 44; 
Neither agreed nor disagreed: 6; 
Disagreed: 17; 
Total: 67. 

Recommendation in plan: Recommendations on specific bands: 
Reallocate portion of television spectrum (120 MHz). 

Type of respondent: Expert; 
Agreed: 14; 
Neither agreed nor disagreed: 1; 
Disagreed: 3; 
Total: 18. 

Type of respondent: Stakeholder - broadcaster; 
Agreed: 0; 
Neither agreed nor disagreed: 0; 
Disagreed: 11; 
Total: 11. 

Type of respondent: Stakeholder - nonbroadcaster; 
Agreed: 27; 
Neither agreed nor disagreed: 4; 
Disagreed: 6; 
Total: 37. 

Type of respondent: Total; 
Agreed: 41; 
Neither agreed nor disagreed: 5; 
Disagreed: 20; 
Total: 66. 

Recommendation in plan: Recommendations on specific bands: 
Accelerate terrestrial deployment in Mobile Satellite Services 
spectrum (90 MHz). 

Type of respondent: Expert; 
Agreed: 12; 
Neither agreed nor disagreed: 2; 
Disagreed: 2; 
Total: 16. 

Type of respondent: Stakeholder; 
Agreed: 23; 
Neither agreed nor disagreed: 13; 
Disagreed: 7; 
Total: 43. 

Type of respondent: Total; 
Agreed: 35; 
Neither agreed nor disagreed: 15; 
Disagreed: 9; 
Total: 59. 

Recommendation in plan: Recommendations on specific bands: 
Auction Advanced Wireless Services spectrum (60 MHz). 

Type of respondent: Expert; 
Agreed: 16; 
Neither agreed nor disagreed: 1; 
Disagreed: 1; 
Total: 18. 

Type of respondent: Stakeholder; 
Agreed: 33; 
Neither agreed nor disagreed: 8; 
Disagreed: 5; 
Total: 46. 

Type of respondent: Total; 
Agreed: 49; 
Neither agreed nor disagreed: 9; 
Disagreed: 6; 
Total: 64. 

Recommendation in plan: Recommendations on specific bands: 
Make Wireless Communications Services spectrum available (20 MHz). 

Type of respondent: Expert; 
Agreed: 16; 
Neither agreed nor disagreed: 1; 
Disagreed: 1; 
Total: 18. 

Type of respondent: Stakeholder; 
Agreed: 19; 
Neither agreed nor disagreed: 20; 
Disagreed: 6; 
Total: 45. 

Type of respondent: Total; 
Agreed: 35; 
Neither agreed nor disagreed: 21; 
Disagreed: 7; 
Total: 63. 

Recommendation in plan: Recommendations on specific bands: 
Auction the Upper 700 MHz D Block (10 MHz)[A]. 

Type of respondent: Expert; 
Agreed: 16; 
Neither agreed nor disagreed: 1; 
Disagreed: 1; 
Total: 18. 

Type of respondent: Stakeholder; 
Agreed: 20; 
Neither agreed nor disagreed: 11; 
Disagreed: 12; 
Total: 43. 

Type of respondent: Total; 
Agreed: 36; 
Neither agreed nor disagreed: 12; 
Disagreed: 13; 
Total: 61. 

Source: GAO survey. 

Note: The total number of responses for each recommendation varied 
based on the number of respondents that chose to answer the question 
pertaining to the recommendation. The figures shown under "agreed" 
include respondents that either strongly agreed or somewhat agreed 
with the recommendation, and the responses shown under "disagreed" 
include respondents that either strongly disagreed or somewhat 
disagreed with the recommendation. Appendix III includes figures for 
the more detailed response categories, as well for each type of 
stakeholder. 

[A] The 700 MHz D-Block spectrum was made available for auction 
through the transition of television from analog to digital service, 
which freed up a portion of the 700 MHz spectrum for new wireless 
services. FCC established the Upper 700 MHz D Block to be licensed on 
a nationwide basis to a single entity via auction. FCC's auction rules 
required the winning bidder for the D Block to enter into a public/ 
private partnership with the nationwide licensee of the public safety 
broadband spectrum, a nonprofit entity established by national public 
safety leadership. That requirement was intended to enable 
construction of an interoperable broadband network that would serve 
both commercial and public safety users. This 10 MHz block of spectrum 
did not receive a winning bid in FCC's 700 MHz auction held in 2008. 

[End of table] 

The majority of responding experts and stakeholders agreed with each 
of the five recommendations related to specific bands.[Footnote 39] 
However, the recommendation on reallocating 120 MHz of television 
spectrum has generated a significant amount of controversy, and this 
was reflected in our survey results; 

the 120 MHz of television spectrum in this recommendation is in 
addition to the spectrum made available through the transition of 
television from analog to digital service in 2009. Experts and 
stakeholders other than broadcasters strongly supported the 
recommendation, whereas all 11 broadcasters strongly opposed it. FCC, 
as well as some experts and stakeholders who supported reallocating a 
portion of the television band, said that the spectrum would have much 
higher economic value if it were allocated for wireless broadband. 
FCC, for instance, argues that reallocating television spectrum for 
mobile broadband would increase its value by roughly a factor of 10. 
According to FCC, this difference in value reflects, in part, 
"challenging long-term trends" facing the television broadcasting 
industry; 

FCC noted, for example, that the percentage of households viewing 
television solely through over-the-air broadcasts declined from 24 
percent in 1999 to 10 percent in 2010, and since 2005, broadcast 
television station revenues have declined 26 percent.[Footnote 40] In 
contrast, broadcasters responding to our survey cited the following 
arguments against reallocating a portion of the television spectrum: 

* Doing so would likely have a significant, negative impact on the 
public's access to local television broadcasts, both via free over-the-
air television and via cable and satellite, because broadcasters use 
spectrum to provide local broadcasts to viewers both directly over-the-
air and indirectly by broadcasting their signals to cable and 
satellite television providers, which then retransmit the local 
broadcasts to their subscribers. 

* Broadcasters are deploying mobile digital television with their 
spectrum. This deployment will play a significant role in mobile 
broadband content delivery and should be encouraged to flourish as it 
is the most efficient way of distributing video, which Cisco Systems, 
Inc. says will account for 66 percent of all mobile traffic in 2015. 
[Footnote 41] 

* A better way to move underutilized broadcast spectrum to mobile 
carriers would be to allow broadcasters to sell or lease such spectrum 
to mobile carriers in a private market transaction. 

* FCC should not implement this recommendation without completing a 
full spectrum inventory that also analyzes current utilization. 
Action, if at all, should be predicated on demonstrated need rather 
than on assertions of a looming spectrum crisis and after full 
investigation of whether less disruptive alternatives to reallocation 
of broadcast spectrum could address demonstrated needs. 

In the National Broadband Plan, FCC acknowledges that "over-the-air 
television continues to serve important functions in our society," by 
providing, among other things, free access to news, entertainment, and 
local programming; children's educational programming; coverage of 
community news and events; reasonable access for federal political 
candidates; and closed captioning and emergency broadcast information. 
Therefore, FCC says that the plan's recommendations "seek to preserve 
[over-the-air television] as a healthy, viable medium going forward," 
and the plan calls for FCC to "study and develop policies to ensure 
that its longstanding goals of competition, diversity, and localism 
[in broadcast television] are achieved." However, these statements do 
not appear to have assuaged the concerns of broadcasters. 

Implementation of Recommendations: 

To implement the plan's recommendations to make more spectrum 
available for broadband in specific bands, FCC, among other things: 

* performed technical analysis and worked with broadcast industry 
engineers and experts in related fields on how reallocating a portion 
of television spectrum to broadband could work; 

* issued a proposed rule to establish a regulatory framework to 
facilitate wireless broadband uses of television bands, in 
anticipation of the Commission's intended future reallocation of this 
spectrum to broadband; 

* granted a waiver to a Mobile Satellite Services provider, 
LightSquared, allowing it to expand its terrestrial use of its 
satellite spectrum for broadband, conditional on addressing concerns 
about interference with Global Positioning System devices;[Footnote 42] 

* added co-primary fixed and mobile terrestrial wireless allocations 
to the 2 GHz satellite band and gave Mobile Satellite Services 
licensees the flexibility to lease their spectrum to terrestrial 
operators via spectrum manager leasing arrangements, both of which FCC 
sees as steps toward providing flexibility to allow greater use of the 
band for mobile broadband; 

* revised its interference rules in Wireless Communications Services 
spectrum to facilitate its use for broadband, along the lines 
recommended by the plan; and: 

* issued analyses supporting its recommendation to auction the Upper 
700 MHz D block; 

while the plan recommends the auction of this band, several proposals 
in the 112th Congress, such as the SPECTRUM Act, S.911, and the Public 
Safety Spectrum and Wireless Innovation Act, H.R. 2482, call for the 
reallocation of this band for deployment of a nationwide broadband 
public safety network and therefore FCC is waiting to see if any 
related active legislation is passed before proceeding with 
implementation of this recommendation. 

Experts and stakeholders responding to our survey that supported the 
plan's overall recommendation to make 300 MHz of spectrum available 
for wireless broadband by 2015 were fairly evenly split between those 
satisfied and those dissatisfied with FCC's overall progress in 
implementing the recommendation (see table 3). In contrast, regarding 
FCC's progress on the recommendations aimed at specific bands, experts 
and stakeholders tended to be more satisfied than dissatisfied. For 
example, experts and stakeholders were generally satisfied with FCC's 
progress on implementing the recommendation to accelerate terrestrial 
deployment in Mobile Satellite Services spectrum but were generally 
dissatisfied with FCC's progress on the Upper 700 MHz D Block; 
although, as we note above, FCC is waiting on the outcome of pending 
legislation pertaining to this spectrum band before taking further 
action. 

Table 3: Expert and Stakeholder Respondents' Satisfaction with FCC's 
Progress in Making More Spectrum Available for Wireless Broadband Use 
by 2015: 

Recommendation in plan: Overall recommendation: 
Make 300 MHz available by 2015 and 500 MHz by 2020. 

Type of respondent: Expert; 
Satisfied: 7; 
Neither satisfied nor dissatisfied: 2; 
Dissatisfied: 6; 
Total: 15. 

Type of respondent: Stakeholder; 
Satisfied: 9; 
Neither satisfied nor dissatisfied: 8; 
Dissatisfied: 9; 
Total: 26. 

Type of respondent: Total; 
Satisfied: 16; 
Neither satisfied nor dissatisfied: 10; 
Dissatisfied: 15; 
Total: 41. 

Recommendation in plan: Recommendations on specific bands: 
Reallocate portion of television spectrum (120 MHz). 

Type of respondent: Expert; 
Satisfied: 8; 
Neither satisfied nor dissatisfied: 2; 
Dissatisfied: 4; 
Total: 14. 

Type of respondent: Stakeholder; 
Satisfied: 16; 
Neither satisfied nor dissatisfied: 6; 
Dissatisfied: 4; 
Total: 26. 

Type of respondent: Total; 
Satisfied: 24; 
Neither satisfied nor dissatisfied: 8; 
Dissatisfied: 8; 
Total: 40. 

Recommendation in plan: Recommendations on specific bands: Accelerate 
terrestrial deployment in Mobile Satellite Services spectrum (90 MHz). 

Type of respondent: Expert; 
Satisfied: 7; 
Neither satisfied nor dissatisfied: 2; 
Dissatisfied: 3; 
Total: 12. 

Type of respondent: Stakeholder; 
Satisfied: 15; 
Neither satisfied nor dissatisfied: 1; 
Dissatisfied: 6; 
Total: 22. 

Type of respondent: Total; 
Satisfied: 22; 
Neither satisfied nor dissatisfied: 3; 
Dissatisfied: 9; 
Total: 34. 

Recommendation in plan: Recommendations on specific bands: Auction 
Advanced Wireless Services spectrum (60 MHz). 

Type of respondent: Expert; 
Satisfied: 9; 
Neither satisfied nor dissatisfied: 4; 
Dissatisfied: 2; 
Total: 15. 

Type of respondent: Stakeholder; 
Satisfied: 10; 
Neither satisfied nor dissatisfied: 7; 
Dissatisfied: 12; 
Total: 29. 

Type of respondent: Total; 
Satisfied: 19; 
Neither satisfied nor dissatisfied: 11; 
Dissatisfied: 14; 
Total: 44. 

Recommendation in plan: Recommendations on specific bands: Make 
Wireless Communications Services spectrum available (20 MHz). 

Type of respondent: Expert; 
Satisfied: 8; 
Neither satisfied nor dissatisfied: 3; 
Dissatisfied: 4; 
Total: 15. 

Type of respondent: Stakeholder; 
Satisfied: 9; 
Neither satisfied nor dissatisfied: 1; 
Dissatisfied: 8; 
Total: 18. 

Type of respondent: Total; 
Satisfied: 17; 
Neither satisfied nor dissatisfied: 4; 
Dissatisfied: 12; 
Total: 33. 

Recommendation in plan: Recommendations on specific bands: Auction the 
Upper 700 MHz D Block (10 MHz). 

Type of respondent: Expert; 
Satisfied: 4; 
Neither satisfied nor dissatisfied: 5; 
Dissatisfied: 7; 
Total: 16. 

Type of respondent: Stakeholder; 
Satisfied: 4; 
Neither satisfied nor dissatisfied: 4; 
Dissatisfied: 9; 
Total: 17. 

Type of respondent: Total; 
Satisfied: 8; 
Neither satisfied nor dissatisfied: 9; 
Dissatisfied: 16; 
Total: 33. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation. The total number of responses 
for each recommendation varied based on the number of respondents that 
chose to answer the question pertaining to the recommendation. The 
figures shown under "satisfied" include respondents that were either 
very satisfied or somewhat satisfied with FCC's progress, and the 
responses shown under "dissatisfied" include respondents that were 
either strongly dissatisfied or somewhat dissatisfied with FCC's 
progress. Appendix III includes figures for the more detailed response 
categories, as well for each type of stakeholder. 

[End of table] 

Respondents expressed a variety of views on FCC's progress. For 
example, one expert reported that FCC should have auctioned the Upper 
700 MHz D block already but was satisfied with FCC's efforts to 
accelerate terrestrial deployment in Mobile Satellite Services 
spectrum. Another expert said that FCC's approach to spectrum policy 
has resulted in the U.S. mobile and fixed wireless broadband 
industries losing ground to their foreign counterparts. An 
infrastructure provider responded that FCC is working well with NTIA 
to free up spectrum for auctions. 

Additional details on FCC's actions to implement these 
recommendations, as well as experts' and stakeholders' views on the 
recommendations and on FCC's implementation, are contained in appendix 
III. 

Responding Experts and Stakeholders Had Mixed Views on Expanding 
Incentives and Mechanisms to Reallocate Spectrum: 

Recommendations in Plan: 

The National Broadband Plan included four recommendations aimed at 
expanding incentives and mechanisms to reallocate spectrum. We 
considered the following three of those recommendations in our review: 

* to motivate existing spectrum licensees to voluntarily give up their 
licenses so that FCC could more quickly reallocate the spectrum to 
higher valued services, the plan recommended that Congress should 
consider giving FCC the authority to conduct incentive auctions in 
which licensees that choose to relinquish their licenses would receive 
a portion of the proceeds realized by the auction of their licenses; 

* to promote the efficient use of spectrum by compelling spectrum 
licensees to recognize the value to society of their licenses, the 
plan recommended that Congress consider granting authority to FCC to 
impose fees on licensees; and: 

* because of concerns that its rules allowing spectrum licensees to 
lease their licenses--designed to promote access to underutilized 
spectrum--are not as effective as they could be, the plan recommended 
that FCC should identify and address barriers to secondary markets. 
[Footnote 43] 

The recommendations enjoyed varying levels of agreement from the 
experts and stakeholders responding to our survey (see table 4). In 
the table, we sometimes separately report different subgroups of 
stakeholders to illustrate meaningful differences in their responses. 

Table 4: Expert and Stakeholder Respondents' Agreement with National 
Broadband Plan Recommendations Aimed at Expanding Incentives and 
Mechanisms to Reallocate Spectrum: 

Recommendation in plan: Grant authority to conduct incentive auctions. 

Type of respondent: Expert; 
Agreed: 18; 
Neither agreed nor disagreed: 0; 
Disagreed: 1; 
Total: 19. 

Type of respondent: Stakeholder - broadcaster; 
Agreed: 1; 
Neither agreed nor disagreed: 5; 
Disagreed: 5; 
Total: 11. 

Type of respondent: Stakeholder - nonbroadcaster; 
Agreed: 30; 
Neither agreed nor disagreed: 2; 
Disagreed: 7; 
Total: 39. 

Type of respondent: Total; 
Agreed: 49; 
Neither agreed nor disagreed: 7; 
Disagreed: 13; 
Total: 69. 

Recommendation in plan: Grant authority to impose fees on licensees. 

Type of respondent: Expert; 
Agreed: 15; 
Neither agreed nor disagreed: 1; 
Disagreed: 4; 
Total: 20. 

Type of respondent: Broadcaster; 
Agreed: 0; 
Neither agreed nor disagreed: 0; 
Disagreed: 13; 
Total: 13. 

Type of respondent: Wireless device manufacturer; 
Agreed: 4; 
Neither agreed nor disagreed: 2; 
Disagreed: 3; 
Total: 9. 

Type of respondent: Wireless service provider; 
Agreed: 6; 
Neither agreed nor disagreed: 1; 
Disagreed: 13; 
Total: 20. 

Type of respondent: Other stakeholder; 
Agreed: 4; 
Neither agreed nor disagreed: 3; 
Disagreed: 2; 
Total: 9. 

Type of respondent: Total; 
Agreed: 29; 
Neither agreed nor disagreed: 7; 
Disagreed: 35; 
Total: 71. 

Recommendation in plan: Address barriers to secondary markets. 

Type of respondent: Expert; 
Agreed: 18; 
Neither agreed nor disagreed: 1; 
Disagreed: 1; 
Total: 20. 

Type of respondent: Stakeholder; 
Agreed: 41; 
Neither agreed nor disagreed: 4; 
Disagreed: 5; 
Total: 50. 

Type of respondent: Total; 
Agreed: 59; 
Neither agreed nor disagreed: 5; 
Disagreed: 6; 
Total: 70. 

Source: GAO survey. 

Note: The total number of responses for each recommendation varied 
based on the number of respondents that chose to answer the question 
pertaining to the recommendation. The figures shown under "agreed" 
include respondents that either strongly agreed or somewhat agreed 
with the recommendation, and the responses shown under "disagreed" 
include respondents that either strongly disagreed or somewhat 
disagreed with the recommendation. Appendix III includes figures for 
the more detailed response categories, as well for each type of 
stakeholder. 

[End of table] 

Far more experts and stakeholders other than broadcasters agreed than 
disagreed with granting FCC authority to conduct incentive auctions, 
while more broadcasters disagreed than agreed. FCC proposed incentive 
auctions as a mechanism to free up 120 MHz of spectrum currently 
allocated to television service, which as we noted above, broadcasters 
oppose. The experts and stakeholders expressed a variety of views 
about incentive auctions. For example, one expert commented that 
Congress should simply allow FCC to pay some of the auction revenues 
to broadcasters instead of the U.S. Treasury and avoid legislating any 
details of the auction. An infrastructure provider said that incentive 
auctions would take years off of FCC's usual repurposing approach, 
which as we noted earlier has taken from 7 to 15 years. A broadcaster 
commented that instead of using incentive auctions to reallocate 
television spectrum, FCC should allow licensees to sell or lease their 
licenses to wireless service providers. Another broadcaster commented 
that incentive auctions would be acceptable so long as (1) 
participation by broadcasters is truly voluntary and (2) FCC 
reimburses broadcasters who choose not to participate for the costs 
they incur to relocate to new frequencies.[Footnote 44] 

Many more experts agreed than disagreed with granting FCC authority to 
impose fees on licensees, while slightly more wireless device 
manufacturers and stakeholders in our "other" category agreed than 
disagreed. All broadcasters disagreed with granting FCC authority to 
impose fees, and about twice as many wireless service providers 
disagreed as agreed; as licensees, broadcasters and wireless service 
providers could be subject to the fees. The experts and stakeholders 
expressed a variety of views about fees. An expert commented that the 
value of spectrum is usually far greater than the amount recovered in 
auctions, and that fees can better capture this value by being 
adjusted upward if the value of the spectrum appreciates. Similarly, a 
public interest group commented that annual fees would increase 
spectrum utilization, give license holders who do not use their 
spectrum an incentive to return it, and raise far more money for the 
U.S. Treasury than auctions do. Alternatively, an expert responded 
that fees would not create incentives for efficient use of spectrum, 
and suggested that instead FCC allow competitive forces wider scope by 
permitting licensees to deploy any service, technology, or business 
model that may be profitable. A range of stakeholders commented that 
fees should be reduced or waived for current licensees that purchased 
their licenses at auction or that already pay annual regulatory fees. 

Almost all responding experts and most stakeholders agreed with the 
recommendation that FCC identify and address barriers to secondary 
markets. An expert responded that addressing barriers to secondary 
markets would eliminate the need for incentive auctions. Similarly, a 
broadcaster commented that allowing all current licensees to 
participate in secondary markets would enable market forces to 
determine the best use for spectrum without requiring wholesale 
reallocation of designated bands. A wireless service provider noted 
that FCC's secondary market rules have been greatly successful in 
creating access to spectrum resources by nonlicensees, with leasing 
arrangements becoming increasingly commonplace. 

Implementation of Recommendations: 

In response to the recommendation on secondary markets, FCC officials 
told us that the Commission reviewed its secondary markets policies 
and concluded that it should do more to promote these markets. It also 
requested public comments on technologies that could enable dynamic 
sharing of spectrum, including how such technologies could facilitate 
secondary markets.[Footnote 45] FCC officials told us that the 
Commission intended to issue a related order, tentatively by the end 
of 2011. Among those responding to our survey and that support the 
recommendation, more experts and wireless device manufacturers were 
satisfied than dissatisfied with FCC's progress, while more wireless 
service providers were dissatisfied than satisfied (see table 5). 

Table 5: Expert and Stakeholder Respondents' Satisfaction with FCC's 
Progress in Identifying and Addressing Barriers to Secondary Markets: 

Type of respondent: Expert; 
Satisfied: 7; 
Neither satisfied nor dissatisfied: 3; 
Dissatisfied: 5; 
Total: 15. 

Type of respondent: Broadcaster; 
Satisfied: 0; 
Neither satisfied nor dissatisfied: 5; 
Dissatisfied: 3; 
Total: 8. 

Type of respondent: Wireless device manufacturer; 
Satisfied: 4; 
Neither satisfied nor dissatisfied: 2; 
Dissatisfied: 2; 
Total: 8. 

Type of respondent: Wireless service provider; 
Satisfied: 3; 
Neither satisfied nor dissatisfied: 4; 
Dissatisfied: 8; 
Total: 15. 

Type of respondent: Other stakeholder; 
Satisfied: 2; 
Neither satisfied nor dissatisfied: 6; 
Dissatisfied: 0; 
Total: 8. 

Type of respondent: Total; 
Satisfied: 16; 
Neither satisfied nor dissatisfied: 20; 
Dissatisfied: 18; 
Total: 54. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation. The figures shown under 
"satisfied" include respondents that were either very satisfied or 
somewhat satisfied with FCC's progress, and the responses shown under 
"dissatisfied" include respondents that were either strongly 
dissatisfied or somewhat dissatisfied with FCC's progress. Appendix 
III includes figures for the more detailed response categories. 

[End of table] 

Two broadcasters commented that FCC's analysis of barriers to 
secondary markets must include broadcast spectrum to be credible and 
effective. An expert questioned the relevance of dynamic spectrum 
access to secondary markets, and two stakeholders commented that 
dynamic spectrum access is not yet technically mature enough to 
support secondary markets. 

Responding Experts and Stakeholders Had Mixed Views on Expanding 
Opportunities for Innovative Spectrum Access Models: 

Recommendations in Plan: 

The National Broadband Plan includes four recommendations aimed at 
expanding opportunities for innovative spectrum access models. Such 
models provide alternatives to the traditional means of accessing 
spectrum--exclusive-use licensing. Examples include allowing 
unlicensed devices to use certain portions of the spectrum without any 
guarantee of interference protection and dynamic spectrum access. The 
four related recommendations are as follows: 

* FCC, within the next 10 years, should free up a contiguous 
nationwide band for use exclusively or predominantly by unlicensed 
devices. 

* FCC should move expeditiously to complete new rules permitting 
unlicensed use of the unused spectrum between television channels, 
referred to as television "white spaces." 

* FCC should spur further development and deployment of opportunistic 
uses (i.e., dynamic spectrum access) across more radio spectrum. 

* FCC should initiate proceedings to enhance research and development 
(R&D) that will advance the science of spectrum access. 

Stakeholders and experts responding to our survey expressed varying 
levels of support for these recommendations (see table 6). In the 
table, we sometimes separately report different subgroups of 
stakeholders to illustrate meaningful differences in their responses. 

Table 6: Expert and Stakeholder Respondents' Agreement with National 
Broadband Plan Recommendations Aimed at Expanding Opportunities for 
Innovative Spectrum Access Models: 

Recommendation in plan: Provide spectrum for unlicensed use. 

Type of respondent: Expert; 
Agreed: 8; 
Neither agreed nor disagreed: 3; 
Disagreed: 5; 
Total: 16. 

Type of respondent: Broadcaster; 
Agreed: 3; 
Neither agreed nor disagreed: 3; 
Disagreed: 4; 
Total: 10. 

Type of respondent: Wireless device manufacturer; 
Agreed: 6; 
Neither agreed nor disagreed: 1; 
Disagreed: 2; 
Total: 9. 

Type of respondent: Wireless service provider; 
Agreed: 7; 
Neither agreed nor disagreed: 2; 
Disagreed: 10; 
Total: 19. 

Type of respondent: Other stakeholder; 
Agreed: 5; 
Neither agreed nor disagreed: 1; 
Disagreed: 1; 
Total: 7. 

Type of respondent: Total; 
Agreed: 29; 
Neither agreed nor disagreed: 10; 
Disagreed: 22; 
Total: 61. 

Recommendation in plan: Issue rules on television white spaces. 

Type of respondent: Expert; 
Agreed: 11; 
Neither agreed nor disagreed: 2; 
Disagreed: 5; 
Total: 18. 

Type of respondent: Stakeholder - broadcaster; 
Agreed: 1; 
Neither agreed nor disagreed: 4; 
Disagreed: 7; 
Total: 12. 

Type of respondent: Stakeholder - nonbroadcaster; 
Agreed: 22; 
Neither agreed nor disagreed: 7; 
Disagreed: 6; 
Total: 35. 

Type of respondent: Total; 
Agreed: 34; 
Neither agreed nor disagreed: 13; 
Disagreed: 18; 
Total: 65. 

Recommendation in plan: Spur opportunistic uses of spectrum. 

Type of respondent: Expert; 
Agreed: 14; 
Neither agreed nor disagreed: 2; 
Disagreed: 3; 
Total: 19. 

Type of respondent: Stakeholder; 
Agreed: 27; 
Neither agreed nor disagreed: 9; 
Disagreed: 11; 
Total: 47. 

Type of respondent: Total; 
Agreed: 41; 
Neither agreed nor disagreed: 11; 
Disagreed: 14; 
Total: 66. 

Recommendation in plan: Enhance R&D on spectrum access. 

Type of respondent: Expert; 
Agreed: 16; 
Neither agreed nor disagreed: 0; 
Disagreed: 2; 
Total: 18. 

Type of respondent: Stakeholder; 
Agreed: 32; 
Neither agreed nor disagreed: 7; 
Disagreed: 9; 
Total: 48. 

Type of respondent: Total; 
Agreed: 48; 
Neither agreed nor disagreed: 7; 
Disagreed: 11; 
Total: 66. 

Source: GAO survey. 

Note: The total number of responses for each recommendation varied 
based on the number of respondents that chose to answer the question 
pertaining to the recommendation. The figures shown under "agreed" 
include respondents that either strongly agreed or somewhat agreed 
with the recommendation, and the responses shown under "disagreed" 
include respondents that either strongly disagreed or somewhat 
disagreed with the recommendation. Appendix III includes figures for 
the more detailed response categories, as well for each type of 
stakeholder. 

[End of table] 

More experts, wireless device manufacturers, and stakeholders in our 
"other" category agreed than disagreed that FCC should free up a 
nationwide band for the exclusive or predominant use of unlicensed 
devices, while more broadcasters and wireless service providers 
disagreed than agreed. Experts and stakeholders expressed a variety of 
views about unlicensed uses. For example, an expert commented that 
future demand for rich wireless media cannot be satisfied by licensed 
spectrum alone but will require more unlicensed spectrum to provide 
many more wireless fidelity (Wi-Fi) access points so that wireless 
traffic can be off-loaded to the wired network.[Footnote 46] A 
wireless service provider said that the potential benefit of 
unlicensed uses is so great that FCC should be aiming to set aside a 
band for such uses within 2 to 3 years rather than 10 years. In 
contrast, a Mobile Satellite Services company responded that there is 
already enough spectrum available for unlicensed uses. Similarly, an 
expert commented that because there are now affordable devices that 
can operate effectively over a range of frequencies, FCC should assist 
the market in using an online database as it is doing for television 
white spaces so that unlicensed devices can sense available spectrum 
and use it dynamically, rather than clearing a new band for unlicensed 
use. 

More responding experts and stakeholders other than broadcasters 
agreed than disagreed that FCC should move expeditiously to complete 
new rules permitting unlicensed use of television white spaces, while 
more broadcasters disagreed than agreed. Experts and stakeholders 
expressed a variety of views on the recommendation. A wireless device 
manufacturer that supported white spaces noted that white spaces are 
primarily available in rural areas where spectrum congestion is less 
common than in densely populated environments like urban areas. But, 
three broadcasters responded that FCC must ensure that its rules 
protect incumbent users from interference.[Footnote 47] Two experts 
expressed concern that unlicensed use of television white spaces could 
adversely impact or be in tension with an incentive auction of 
television spectrum. 

Experts and stakeholders generally supported the recommendation on 
opportunistic uses, and they made a variety of comments on the 
recommendation. For example, a wireless service provider supported the 
continued development of dynamic spectrum access but expressed strong 
opposition to FCC's development of any related rules that would 
diminish the rights of licensees of exclusive spectrum purchased at 
auction to control access to their spectrum. A broadcaster also 
commented that FCC should protect the integrity of existing services; 
the broadcaster disagreed with the recommendation on opportunistic 
uses and stated that FCC should free incumbent licensees from 
technical restrictions that hinder innovation. Similarly, an expert 
commented that instead of implementing this recommendation, FCC should 
develop rules that create incentives for competitive processes to 
create efficient solutions to spectrum shortages. Another expert 
expressed doubt that mass market technology and the demands of the 
commercial marketplace will allow for opportunistic uses within the 
next decade. 

Experts and stakeholders generally supported the recommendation on 
R&D. For example, a wireless service provider commented that, in 
implementing this recommendation, FCC should leverage work that is 
currently being done in private industry and in academia. Two other 
wireless service providers reported that rather than trying to foster 
R&D directly, FCC should instead focus on ensuring a highly 
competitive marketplace for wireless services because competition 
spurs innovation by market participants. A Mobile Satellite Services 
company responded that spectrum shortages are already providing 
incentive for licensees to spend their funds on R&D for ways to use 
spectrum more intensively. An expert also noted that there is no need 
for FCC to enhance already substantial ongoing R&D efforts by the 
private sector. 

Implementation of Recommendations: 

To implement the recommendations aimed at expanding opportunities for 
innovative spectrum access models, FCC has taken or plans to take the 
following steps: 

* Unlicensed spectrum. FCC intends to consider making additional 
spectrum available for unlicensed use in conjunction with NTIA's plan 
to make available 500 MHz of spectrum for wireless broadband, which 
addresses both licensed and unlicensed uses. 

* White spaces. FCC eliminated the requirement that white spaces 
devices include technology to sense what spectrum is available, and 
substituted requirements for geo-location technology and the ability 
to access databases of available spectrum.[Footnote 48] FCC also 
conditionally designated and began working with nine companies to 
develop and administer the databases. 

* Opportunistic uses of spectrum. FCC requested public comment on how 
dynamic spectrum access radios and techniques can promote more 
intensive and efficient use of the radio spectrum.[Footnote 49] 

* R&D. FCC issued a proposed rule that would expand the agency's 
existing Experimental Radio Service rules to promote cutting-edge 
research and foster development of new wireless technologies, devices, 
and applications.[Footnote 50] Specifically, FCC proposed a new type 
of license, called a "program license," which would give qualified 
entities broad authority to conduct research without having to seek 
new approval for each individual experiment. 

Among those that agreed with a recommendation aimed at expanding 
opportunities for innovative spectrum access models, generally more 
experts and more stakeholders were satisfied than were dissatisfied 
with FCC's progress on implementing the recommendation (see table 7). 

Table 7: Expert and Stakeholder Respondents' Satisfaction with FCC's 
Progress on National Broadband Plan Recommendations Aimed at Expanding 
Opportunities for Innovative Spectrum Access Models: 

Recommendation in plan: Provide spectrum for unlicensed use. 

Type of respondent: Expert; 
Satisfied: 5; 
Neither satisfied nor dissatisfied: 2; 
Dissatisfied: 1; 
Total: 8. 

Type of respondent: Stakeholder; 
Satisfied: 9; 
Neither satisfied nor dissatisfied: 2; 
Dissatisfied: 9; 
Total: 20. 

Type of respondent: Total; 
Satisfied: 14; 
Neither satisfied nor dissatisfied: 4; 
Dissatisfied: 10; 
Total: 28. 

Recommendation in plan: Issue rules on television white spaces. 

Type of respondent: Expert; 
Satisfied: 7; 
Neither satisfied nor dissatisfied: 2; 
Dissatisfied: 2; 
Total: 11. 

Type of respondent: Stakeholder; 
Satisfied: 10; 
Neither satisfied nor dissatisfied: 7; 
Dissatisfied: 6; 
Total: 23. 

Type of respondent: Total; 
Satisfied: 14; 
Neither satisfied nor dissatisfied: 4; 
Dissatisfied: 10; 
Total: 34. 

Recommendation in plan: Spur opportunistic uses of spectrum. 

Type of respondent: Expert; 
Satisfied: 6; 
Neither satisfied nor dissatisfied: 3; 
Dissatisfied: 3; 
Total: 12. 

Type of respondent: Stakeholder; 
Satisfied: 7; 
Neither satisfied nor dissatisfied: 14; 
Dissatisfied: 5; 
Total: 26. 

Type of respondent: Total; 
Satisfied: 14; 
Neither satisfied nor dissatisfied: 4; 
Dissatisfied: 10; 
Total: 38. 

Recommendation in plan: Enhance R&D on spectrum access. 

Type of respondent: Expert; 
Satisfied: 10; 
Neither satisfied nor dissatisfied: 3; 
Dissatisfied: 2; 
Total: 15. 

Type of respondent: Stakeholder; 
Satisfied: 12; 
Neither satisfied nor dissatisfied: 9; 
Dissatisfied: 5; 
Total: 26. 

Type of respondent: Total; 
Satisfied: 22; 
Neither satisfied nor dissatisfied: 12; 
Dissatisfied: 7; 
Total: 41. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation. The total number of responses 
for each recommendation varied based on the number of respondents that 
chose to answer the question pertaining to the recommendation. The 
figures shown under "satisfied" include respondents that were either 
very satisfied or somewhat satisfied with FCC's progress, and the 
responses shown under "dissatisfied" include respondents that were 
either strongly dissatisfied or somewhat dissatisfied with FCC's 
progress. Appendix III includes figures for the more detailed response 
categories, as well for each type of stakeholder. 

[End of table] 

More experts were satisfied than dissatisfied with FCC's progress on 
the unlicensed spectrum recommendation, while stakeholders were evenly 
split. An infrastructure provider said that television white spaces 
has been the focus of FCC's efforts related to unlicensed use; the 
provider was concerned that the white spaces will not support devices 
that work in other countries because other countries use different 
spectrum bands than the United States for television. A public 
interest group commented that FCC has not made meaningful progress in 
this area, and that given the success of unlicensed spectrum in 
dramatically increasing the public's access to the public airwaves, 
unlicensed spectrum--rather than spectrum auctions to corporations--
should be FCC's priority. 

While more experts and stakeholders were satisfied than dissatisfied 
with FCC's progress on the white spaces recommendation, experts and 
stakeholders expressed a variety of concerns about FCC's 
implementation. For example, an expert said FCC's approach is too 
complicated. A device manufacturer was troubled by FCC's decision to 
remove the requirement that white spaces devices have sensing 
technology that could scan the spectrum for available frequencies, 
which the manufacturer said had been deemed essential for sharing 
spectrum. A public interest group responded that FCC was moving too 
slowly. 

More experts and stakeholders were satisfied than dissatisfied with 
FCC's progress on the opportunistic uses recommendation, but they 
expressed some concerns about FCC's implementation. For example, an 
infrastructure provider commented that FCC has been too slow to 
resolve interference issues in the 5 GHz band, which FCC has allowed 
for use by devices capable of dynamically accessing spectrum. A 
wireless device manufacturer was dissatisfied that FCC, rather 
proposing rules to facilitate the use of smart radios, had instead 
taken the more preliminary step of requesting public comments on how 
opportunistic uses can promote more intensive and efficient use of the 
radio spectrum. The manufacturer was also dissatisfied that the plan 
and the notice of inquiry showed a preference for geo-location 
database approaches to dynamic access over sensing approaches. 

More experts and stakeholders were satisfied than dissatisfied with 
FCC's progress on the R&D recommendation, and they expressed a variety 
of views about FCC's implementation. For example, a wireless device 
manufacturer described FCC's proposed rule as a good step forward. 
Other stakeholders expressed concerns about the proposed rule. For 
example, a private user noted that FCC's proposal to expand the 
Commission's Experimental Radio Service rules should be strengthened 
to ensure that licensees are aware of experimental operations that may 
cause harmful interference to them, and that FCC should more strictly 
enforce against such interference. 

For examples of survey participants' comments on FCC's implementation 
of the recommendation on opportunistic uses of spectrum, see appendix 
III. 

Responding Experts and Stakeholders Strongly Supported Extending FCC's 
Auction Authority but Varied in Their Opinions on Potential Changes to 
Auctions: 

In the Omnibus Budget Reconciliation Act of 1993, Congress provided 
FCC authority to use auctions to assign certain spectrum licenses. 
From 1994 through June 30 2011, FCC conducted 79 auctions that have 
raised nearly $52 billion for the U.S. Treasury. In 2005, we reported 
that FCC's use of auctions to assign spectrum appeared to have had 
little to no negative impact on end-user prices, infrastructure 
deployment, and competition, but that evidence on how auctions 
impacted the entry and participation of small businesses was less 
clear.[Footnote 51] We also reported that FCC's implementation of 
auctions had mitigated problems associated with comparative hearings 
and lotteries, which FCC previously used to assign licenses. In 
particular, auctions were quicker, less costly, and more transparent; 
were more effective in assigning licenses to entities that valued them 
the most; and were an effective mechanism for the public to realize a 
portion of the value of a national resource used for commercial 
purposes. We recommended that Congress consider extending FCC's 
auction authority beyond the then current expiration date of September 
30, 2007. Subsequent to our report, FCC's auction authority was 
extended twice, first until September 30, 2011, and then until 
September 30, 2012.[Footnote 52] Further, subsequent to our report 
through June 30, 2011, FCC successfully completed 20 auctions, which 
raised over $37 billion for the U.S. Treasury. 

Experts and stakeholders responding to our survey, by large margins, 
supported extending FCC's authority to assign mutually exclusive 
licenses by auction beyond the September 30, 2012, expiration date. In 
particular, 53 of 65 experts and stakeholders supported extending 
FCC's auction authority (see table 8). Experts and stakeholders made a 
variety of comments related to extending FCC's auction authority. For 
example, a wireless service provider commented that auctions are by 
far the most efficient way to assign spectrum. 

Table 8: Expert and Stakeholder Respondents' Agreement with Extending 
FCC's Auction Authority: 

Type of respondent: Expert; 
Agreed: 17; 
Neither agree nor disagreed: 1; 
Disagreed: 1; 
Total: 19. 

Type of respondent: Stakeholder; 
Agreed: 36; 
Neither agree nor disagreed: 3; 
Disagreed: 7; 
Total: 46. 

Type of respondent: Total; 
Agreed: 53; 
Neither agree nor disagreed: 4; 
Disagreed: 8; 
Total: 65. 

Source: GAO survey. 

Note: The figures shown under "agreed" include respondents that either 
strongly agreed or somewhat agreed with extending FCC's auction 
authority, and the responses shown under "disagreed" include 
respondents that either strongly disagreed or somewhat disagreed with 
extending FCC's auction authority. 

[End of table] 

Experts and stakeholders responding to our survey expressed varying 
levels of support for five potential changes to FCC's auction policies 
that we asked about (see table 9). In particular, we asked experts and 
stakeholders about whether FCC should provide a clear schedule for 
future auctions, allow all-or-nothing bids on multiple licenses (known 
as "combinatorial auctions"), reduce the geographic areas covered by 
licenses, modify bidding credits that provide financial benefits to 
certain auction participants, and implement royalties as the means 
though which auction winners compensate the government instead of up-
front payments. 

Table 9: Expert and Stakeholder Respondents' Agreement with Potential 
Changes to FCC's Auction Policies: 

Potential change: Provide a clear road map detailing future auctions. 

Type of respondent: Expert; 
Agreed: Provide a clear road map detailing future auctions: 12; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 3; 
Disagreed: 4; 
Total: 19. 

Type of respondent: Stakeholder; 

Agreed: Provide a clear road map detailing future auctions: 37; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 2; 
Disagreed: 6; 
Total: 45. 

Type of respondent: Total; 
Agreed: Provide a clear road map detailing future auctions: 49; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 5; 
Disagreed: 10; 
Total: 64. 

Potential change: Allow all-or-nothing package bids on multiple 
licenses[A]. 

Type of respondent: Expert; 
Agreed: Provide a clear road map detailing future auctions: 14; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 1; 
Disagreed: 2; 
Total: 17. 

Type of respondent: Stakeholder; 
Agreed: Provide a clear road map detailing future auctions: 18; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 10; 
Disagreed: 10; 
Total: 38. 

Type of respondent: Total; 
Agreed: Provide a clear road map detailing future auctions: 32; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 11; 
Disagreed: 12; 
Total: 55. 

Potential change: Reduce the size of geographic areas covered by 
licenses[B]. 

Type of respondent: Expert; 
Agreed: Provide a clear road map detailing future auctions: 6; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 5; 
Disagreed: 6; 
Total: 17. 

Type of respondent: Stakeholder; 
Agreed: Provide a clear road map detailing future auctions: 23; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 7; 
Disagreed: 11; 
Total: 41. 

Type of respondent: Total; 
Agreed: Provide a clear road map detailing future auctions: 29; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 12; 
Disagreed: 17; 
Total: 58. 

Potential change: Modify bidding credits[C]. 

Type of respondent: Expert; 
Agreed: Provide a clear road map detailing future auctions: 5; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 5; 
Disagreed: 9; 
Total: 19. 

Type of respondent: Stakeholder; 
Agreed: Provide a clear road map detailing future auctions: 20; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 8; 
Disagreed: 8; 
Total: 36. 

Type of respondent: Total; 
Agreed: Provide a clear road map detailing future auctions: 25; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 13; 
Disagreed: 17; 
Total: 55. 

Potential change: Require winners to pay royalties[D]. 

Type of respondent: Expert; 

Agreed: Provide a clear road map detailing future auctions: 9; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 2; 
Disagreed: 7; 
Total: 18. 

Type of respondent: Stakeholder; 
Agreed: Provide a clear road map detailing future auctions: 15; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 7; 
Disagreed: 17; 
Total: 39. 

Type of respondent: Total; 
Agreed: Provide a clear road map detailing future auctions: 24; 
Neither agreed nor disagreed: Provide a clear road map detailing 
future auctions: 9; 
Disagreed: 24; 
Total: 57. 

Source: GAO survey. 

Note: The total number of responses for each potential change varied 
based on the number of respondents that chose to answer the question 
pertaining to the potential change. The figures shown under "agreed" 
include respondents that either strongly agreed or somewhat agreed 
with the potential change, and the responses shown under "disagreed" 
include respondents that either strongly disagreed or somewhat 
disagreed with the potential change. 

[A] An auction with all-or-nothing bids on combinations of multiple 
items is known as a "combinatorial auction." According to FCC, this 
approach allows bidders to better express the value of any benefits 
from combining complementary licenses and to avoid the risk of winning 
only part of a desired set of licenses. 

[B] FCC auctions licenses in a variety of designated geographic 
regions, including relatively small multicounty areas (Cellular Market 
Areas) and large multistate regions (Regional Economic Areas). 

[C] Bidding credits are a percentage discount applied to the high bid 
amount for a license if the bidder meets specific designated entity 
criteria--designed to make spectrum available to new entrants--
established in the auction rules. 

[D] With a royalty mechanism, a company would pay the government a 
percentage of revenue on an ongoing basis, rather than pay the 
government a one-time fee to obtain a spectrum license. 

[End of table] 

Among the potential changes we asked survey participants about, 
reducing uncertainty about future spectrum auctions received the most 
support. Currently, FCC provides information on scheduled auctions and 
identifies auctions not yet scheduled. Most experts and stakeholders 
agreed that FCC should reduce uncertainty by providing a clear road 
map for future auctions, including their timing and size, so that 
potential bidders can develop effective strategies. However, experts 
and stakeholders that did not agree with the recommendation cited 
several concerns. For example, a broadcaster was concerned that by 
providing a road map, FCC would limit its flexibility to respond to 
changing technological solutions and spectrum demand, and an expert 
was concerned that if spectrum beyond that included in the road map 
were to become available, the road map could be used by incumbents to 
protest the release of the additional spectrum, harming consumers. 

Most responding experts agreed, and more stakeholders agreed than 
disagreed, that FCC should allow all-or-nothing package bids on 
multiple licenses in an auction (referred to as "combinatorial 
auctions") as opposed to requiring bids on individual licenses. 
According to FCC, this approach allows bidders to better express the 
value of any benefits from combining complementary licenses and to 
avoid the risk of winning only part of a desired set of licenses. 
However, a broadcaster and a wireless service provider commented that 
package bidding would unfairly favor large companies that can afford 
such approaches. 

An equal number of responding experts agreed and disagreed, and more 
stakeholders agreed than disagreed, that FCC should reduce the size of 
geographic areas covered by licenses to promote the participation of 
small companies. In 2010, we reported that, according to some small 
wireless carriers and stakeholders, the size of spectrum blocks has 
had the effect of pricing small and regional carriers out of auctions, 
making it difficult for these carriers to enter into new markets or 
expand their services.[Footnote 53] However, an expert and a Mobile 
Satellite Services company expressed concern that if FCC were to 
implement this recommendation, small companies that get spectrum would 
sooner or later cash out and sell to larger carriers, which the 
service provider said would add to licensees' costs without actually 
fostering competition. However, a wireless device manufacturer said 
that FCC could avoid this problem by requiring any entity that 
acquires spectrum and sells it without a network to pay a tax to the 
U.S. Treasury. Another expert responded that implementation would 
result in the fragmentation of spectrum and complex secondary market 
transactions aimed at recombining the spectrum into larger geographic 
bundles. 

More experts disagreed than agreed, while more stakeholders agreed 
than disagreed, that FCC should modify bidding credits designed to 
promote the participation of small companies. Bidding credits are a 
percentage discount applied to the high bid amount for a license if 
the bidder meets specific designated entity criteria--designed to make 
spectrum available to new entrants--established in the auction rules. 
Several experts and stakeholders expressed concerns about FCC's 
experience with bidding credits. For example, an expert commented 
that, rather than promoting efficiency, bidding credits provide 
windfalls to the owners of small companies who can use the credits to 
buy spectrum and then turn around and sell it for a profit at market 
rates to larger firms. In 2010, we reported that some stakeholders 
said that, in the past, large national carriers have used entities 
eligible for the credits as proxies, allowing eligible entities to win 
certain licenses and then acquiring the desired licenses from them 
later; a wireless service provider responding to our survey expressed 
a similar concern.[Footnote 54] A device manufacturer cited a case in 
which the Department of Justice, on behalf of FCC, settled with a Wall 
Street money manager for $130 million to resolve allegations of such 
abuse. A wireless service provider commented that the credits do not 
work as intended, and an expert and a device manufacturer felt that 
FCC should stop using them altogether. 

Requiring winners of auctions to pay royalties based on the amount of 
revenues the winners earn by using the spectrum rather than requiring 
them to pay the full amounts of the winning bids up front garnered the 
least support. Both experts and stakeholders were nearly evenly 
divided on this potential change and expressed several concerns about 
royalties. For example, a public interest group commented that 
royalties based on a share of revenues would have the undesirable 
effect of imposing risk on the government. Similarly, a wireless 
service provider commented that royalties would have to be paired with 
penalties for nonuse of spectrum in order to be effective, or else 
licensees--particularly large incumbents--would have an incentive to 
buy and not use spectrum to avoid the royalty or to limit competition 
by smaller competitors and new entrants. Another wireless service 
provider commented that royalties would create disincentives for 
licensees to build out quickly, and that it would be difficult for FCC 
to determine appropriate royalty amounts because of the difficulty of 
parsing out a licensee's revenue from various spectrum bands, some of 
which would be covered by a royalty fee and some of which would not. 

Conclusions: 

As commercial enterprises increasingly utilize spectrum to provide 
consumer services, FCC's ongoing implementation of the spectrum-
related recommendations of the 2010 National Broadband Plan is of 
great importance. Most of the plan's recommendations enjoyed fairly 
broad support from experts and stakeholders responding to our survey, 
although some recommendations were strongly opposed by some experts or 
certain types of stakeholders. For example, the plan's recommendation 
for incentive auctions, which could speed the lengthy repurposing 
process, received mixed responses from expert and stakeholder 
respondents. In some instances, these conflicting opinions arise from 
participants' divergent positions in the communications industry; 

for example, incumbent licensees, such as broadcasters, are likely to 
oppose recommendations that they believe could impose burdens or costs 
on their businesses. In addition, experts' and stakeholders' 
satisfaction with FCC's implementation of the recommendations to date 
tended to be more tempered than their support for the recommendations 
themselves. Perhaps most challenging, experts and stakeholders 
expressed a range of views--sometimes conflicting--on how Congress and 
FCC should proceed. In this respect, little has changed since 2003, 
when we reported that "it does not appear likely that timely reforms 
can be agreed upon amid the diversity of views held by stakeholders." 
[Footnote 55] One potential step that did achieve broad agreement 
among experts and stakeholders responding to our survey was extending 
FCC's auction authority beyond the current expiration date of 
September 30, 2012. We previously found that spectrum auctions are 
very effective for assigning licenses for commercial entities. 
[Footnote 56] We also previously found that as implemented by FCC, 
spectrum auctions resolve problems associated with previous assignment 
mechanisms, while giving rise to little or no problems. Since we 
issued our last report on auctions in December 2005 through June 30, 
2011, FCC has successfully completed an additional 20 auctions, which 
raised over $33 billion for the U.S. Treasury. 

Matter for Congressional Consideration: 

Given the continued success of FCC's use of auctions, and the 
overwhelming support among experts and stakeholders for extending 
FCC's auction authority, Congress should consider extending FCC's 
auction authority beyond the current expiration date of September 30, 
2012. 

Agency Comments: 

We provided a draft of this report to FCC for its review and comment. 
FCC provided technical comments that we incorporated as appropriate. 

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, the Chairman of the Federal 
Communications Commission, and other interested parties. In addition, 
the report will be available at no charge on GAO's website at 
[hyperlink, http://www.gao.gov]. 

If you or members of 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. Major contributors to 
this report are listed in appendix IV. 

Signed by: 

Mark L. Goldstein: 
Director, Physical Infrastructure: 

[End of section] 

Appendix I: Scope and Methodology: 

This report addresses the Federal Communications Commission's (FCC) 
management of commercial spectrum, including (1) the extent to which 
FCC has made spectrum available for new commercial uses since it 
implemented auction authority in 1994, and the time taken to do so; 
(2) experts' and stakeholders' views on FCC's plans and recent actions 
to meet future spectrum needs; and (3) experts' and stakeholders' 
views on the continued use of auctions to assign spectrum. In 
addition, we examined the extent to which FCC seeks to ensure the 
quality of its data on commercial spectrum licenses (see appendix II). 

To address all research questions, we conducted a web-based survey of 
experts and industry stakeholders. We selected a nonprobability sample 
of 30 experts and 79 industry stakeholders; we selected the experts 
and stakeholders based on their expertise in spectrum policy, as 
represented by presentations or publications, or on their 
organization's vested interest in spectrum policy. Within the industry 
stakeholder group, we surveyed 20 representatives of the broadcast 
industry, 15 representatives of the wireless device manufacturing 
industry, 26 representatives of the wireless service provider 
industry, and 18 other industry stakeholders, including satellite, 
spectrum management, infrastructure, private user, and public interest 
groups. 

We developed and administered the web-based survey through a secure 
server. We provided participants with unique passwords and usernames 
and subsequently notified participants on May 25, 2011, when the 
questionnaire was available. We sent follow-up e-mail messages to 
those who had not responded, and subsequently contacted all remaining 
nonrespondents by telephone. The questionnaire was available online 
until June 28, 2011. We received completed responses from 20 experts 
and 54 industry stakeholders, representing a 68 percent response rate. 
Because we selected a nonprobability sample of experts and industry 
stakeholders, the information we obtained from the survey may not be 
generalized to all experts and industry stakeholders who have an 
interest in spectrum policy. 

The practical difficulties of conducting any survey may introduce 
errors, commonly referred to as nonsampling errors. For example, 
difficulties in interpreting a particular question, sources of 
information available to respondents, or entering data into a database 
or analyzing them can introduce unwanted variability into the survey 
results. We took steps in developing the questionnaire, collecting the 
data, and analyzing them to minimize such nonsampling error. For 
example, social science survey specialists designed the questionnaire 
in collaboration with GAO staff who had subject matter expertise. 
Then, we pretested the draft questionnaire with four experts and 
industry stakeholders; we also reviewed the survey with FCC staff. We 
conducted these pretests and reviews to ensure that (1) the questions 
were clear and unambiguous, (2) terminology was used correctly, (3) 
the questionnaire did not place an undue burden on respondents, (4) 
the information could be feasibly obtained, and (5) the survey was 
comprehensive and unbiased. On the basis of the feedback from the 
pretests and reviews we conducted, we made changes to the content and 
format of the survey questions. When we analyzed the data, an 
independent analyst checked all computer programs. Since this was a 
web-based survey, respondents entered their answers directly into the 
electronic questionnaire, eliminating the need to key data into a 
database, minimizing error. 

In addition to the survey, to address all research questions we 
conducted semistructured interviews with a variety of industry 
stakeholders, experts, and officials with government agencies; for 
industry stakeholders, we interviewed both associations and individual 
companies. We interviewed the following types of organizations and 
individuals: government agencies (FCC and the Congressional Research 
Service), wireless service providers, wireless device manufacturers, a 
wireless telecommunications infrastructure company, broadcasters, 
Mobile Satellite Services companies, a spectrum data manager, 
academics, public interest organizations, and consultants. 

To examine the extent to which FCC seeks to ensure the quality of its 
data on commercial spectrum licenses, we reviewed the following FCC 
spectrum-related databases: Universal Licensing System, Consolidated 
Database System, International Bureau Filing System, Experimental 
Licensing System, and Equipment Authorization System. To review these 
databases, we interviewed FCC officials responsible for maintaining 
the systems about FCC's processes for ensuring the quality of the 
data, and we compared FCC's processes with GAO guidance on internal 
controls and information technology. We also interviewed industry 
stakeholders who use these databases, as well as the Spectrum 
Dashboard and License View systems that pull data from these systems, 
and included questions in our survey of experts and stakeholders 
pertaining to the usefulness, accuracy and completeness, and user-
friendliness of FCC's systems. We also reviewed prior FCC audits of 
records in the Universal Licensing System. 

To examine the extent to which FCC has made spectrum available for new 
commercial uses, we reviewed six instances where FCC repurposed 
spectrum from an existing use to a new use. The six repurposings we 
reviewed involved substantial amounts of spectrum that were repurposed 
to a higher value use. In particular, these repurposings met the 
following criteria: (1) the amount of spectrum repurposed was 5 
megahertz (MHz) or more; (2) the repurposing yielded $100 million or 
more in auction or industry revenue; and (3) reassignment occurred in 
1994, when FCC first implemented its auction authority, or later. For 
these repurposings, we reviewed FCC's notices, orders, and auctions; 
comments filed in the proceedings by industry participants; and 
relevant court decisions. We also included a question in our survey of 
experts and stakeholders pertaining to the amount of time it takes 
from when FCC or Congress designates a spectrum band for reallocation 
until the band is available for a new use. 

To examine FCC's plans and recent actions to meet future spectrum 
needs, we reviewed the National Broadband Plan and notices of inquiry, 
reports and orders, and other publications related to FCC's 
development or implementation of the plan's chapter on spectrum. We 
reviewed comments filed in various FCC proceedings from industry 
stakeholders on FCC's development of the plan and FCC's steps to 
implement the plan. We reviewed publications and presentations from 
academic and industry consultants and other experts. We included 
questions in our survey of experts and stakeholders pertaining to the 
recommendations in the plan's chapter on spectrum and FCC's steps to 
implement those recommendations. We asked survey participants for 
their opinion on each recommendation and where appropriate, FCC's 
steps to implement the recommendation; we excluded three 
recommendations that were addressed in our questions about FCC's data 
quality, fell under the purview of the National Telecommunications and 
Information Administration (NTIA), or pertained to a narrow 
population.[Footnote 57] 

To examine FCC's continued use of auctions to assign spectrum, we 
reviewed prior GAO reports that addressed FCC's use of auctions to 
assign spectrum licenses. We reviewed publications and presentations 
from academic and other experts. Finally, we included questions in our 
survey of experts and stakeholders pertaining to spectrum auctions. In 
particular, we asked survey participants for their opinion on whether 
Congress should extend FCC's auction authority and on five potential 
changes to FCC's implementation of auctions. 

We conducted this performance audit from August 2010 to November 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. 

[End of section] 

Appendix II: Federal Communications Commission's Spectrum-Related Data 
Systems: 

In this appendix, we provide information on FCC's spectrum-related 
data systems. Specifically, we discuss (1) FCC's data systems for 
spectrum-related records, (2) experts' and stakeholders' views about 
attributes of FCC's data systems, (3) FCC's quality-control process 
for its data, and (4) FCC's efforts to improve its spectrum-related 
data. 

FCC Has Several Data Systems for Spectrum-Related Records: 

We examined seven of FCC's spectrum-related data systems, of which six 
are related to spectrum licenses, and one is concerned with radio 
equipment authorizations (see table 10).[Footnote 58] Four of the six 
spectrum license-related systems allow (1) entities to apply for a 
license, (2) existing licensees to apply for a license renewal or to 
update their license information, and (3) the public to search for 
information on licenses; 

these systems are the Universal Licensing System for wireless 
telecommunications licenses, the Consolidated Database System for 
broadcasting licenses, the International Bureau Filing System for 
satellite licenses, and the Experimental Licensing System for 
experimental use licenses. According to FCC officials, the Universal 
Licensing System is by far the largest system with the most licenses, 
and is therefore the system that the public is most likely to interact 
with. FCC recently implemented the other two systems related to 
spectrum licenses--Spectrum Dashboard and License View--to provide the 
public with more user-friendly tools, such as enhanced mapping 
capabilities, for searching for information on spectrum licenses. 
These two systems pull data on licenses from FCC's spectrum licensing 
systems; they do not allow entities to file applications for licenses 
or update information on their licenses. The Equipment Authorization 
System allows entities to file applications for authorizations of 
radio equipment, such as cell phones, and the public to search for 
information on these authorizations. FCC uses these various systems 
for multiple purposes, including processing applications for spectrum 
licenses or radio equipment authorizations and helping to determine 
where spectrum is available. 

Table 10: Description of FCC Data Systems: 

System: Universal Licensing System; 
Authorities covered: 
Spectrum licenses: [Check]; 
Radio equipment authorizations: [Empty]; 
Services, frequencies, or equipment covered: Wireless communications 
services, including cellular telephone, paging, personal 
communications services, and other commercial and private radio 
services; 
Capabilities: 
File applications for licenses or authorizations: [Check]; 
Search for information on licenses or authorizations: [Check]; 
Map information for individual or groups of licenses: [Check]. 

System: Consolidated Database System; 
Authorities covered: 
Spectrum licenses: [Check]; 
Radio equipment authorizations: [Empty]; 
Services, frequencies, or equipment covered: Broadcast television and 
radio; 
Capabilities: 
File applications for licenses or authorizations: [Check]; 
Search for information on licenses or authorizations: [Check]; 
Map information for individual or groups of licenses: [Check]. 

System: International Bureau Filing System; 
Authorities covered: 
Spectrum licenses: [Check]; 
Radio equipment authorizations: [Empty]; 
Services, frequencies, or equipment covered: Satellites and satellite 
earth stations; 
Capabilities: 
File applications for licenses or authorizations: [Check]; 
Search for information on licenses or authorizations: [Check]; 
Map information for individual or groups of licenses: [Empty]. 

System: Experimental Licensing System; 
Authorities covered: 
Spectrum licenses: [Check]; 
Radio equipment authorizations: [Empty]; 
Services, frequencies, or equipment covered: Experimental uses; 
Capabilities: 
File applications for licenses or authorizations: [Check]; 
Search for information on licenses or authorizations: [Check]; 
Map information for individual or groups of licenses: [Empty]. 

System: Equipment Authorization System; 
Authorities covered: 
Spectrum licenses: [Empty]; 
Radio equipment authorizations: [Check]; 
Services, frequencies, or equipment covered: Radio equipment in all 
spectrum bands; 
Capabilities: 
File applications for licenses or authorizations: [Check]; 
Search for information on licenses or authorizations: [Check]; 
Map information for individual or groups of licenses: [Empty]. 

System: Spectrum Dashboard; 
Authorities covered: 
Spectrum licenses: [Check]; 
Radio equipment authorizations: [Empty]; 
Services, frequencies, or equipment covered: Frequencies generally 
deemed appropriate for mobile broadband, including those allocated to 
wireless communications services, broadcast television, and satellite; 
Capabilities: 
File applications for licenses or authorizations: [Empty]; 
Search for information on licenses or authorizations: [Check]; 
Map information for individual or groups of licenses: [Check]. 

System: License View; 
Authorities covered: 
Spectrum licenses: [Check]; 
Radio equipment authorizations: [Empty]; 
Services, frequencies, or equipment covered: All services covered by 
the Universal Licensing System, the Consolidated Database System, the 
International Bureau Filing System, the Experimental Licensing System, 
and FCC's cable licensing system; 
Capabilities: 
File applications for licenses or authorizations: [Empty]; 
Search for information on licenses or authorizations: [Check]; 
Map information for individual or groups of licenses: [Empty]. 

Source: GAO analysis of FCC information. 

[End of table] 

Stakeholders Expressed Mixed Views about Attributes of FCC's Data 
Systems: 

Availability of Information: 

Most users of FCC's spectrum-related data systems responding to our 
survey reported that the systems generally provide the type of 
information they are looking for to either a great or moderate extent 
(see table 11). In particular, for each of the seven systems, large 
majorities of survey respondents expressed a favorable opinion on the 
availability of information. However, respondents' opinions varied 
somewhat across the systems. For example, a large majority of 
respondents reported a positive evaluation of the Universal Licensing 
System; 

54 of 58 respondents said that the Universal Licensing System provides 
the type of information they were looking for to a great or moderate 
extent. Spectrum Dashboard, a system that pulls data from FCC's 
spectrum licensing systems, had a somewhat lower level of support; 

33 of 48 respondents reported that Spectrum Dashboard provides the 
type of information they were looking for to a great or moderate 
extent. 

Table 11: Summary of Survey Responses of Extent to Which FCC Data 
System Provides Desired Type of Information: 

System: Universal Licensing System; 
Extent to which system provides desired types of information: 
Great: 31; 
Moderate: 23; 
Little: 2; 
None: 2; 
Total: 58. 

System: Consolidated Database System; 
Extent to which system provides desired types of information: 
Great: 14; 
Moderate: 15; 
Little: 3; 
None: 3; 
Total: 35. 

System: International Bureau Filing System; 
Extent to which system provides desired types of information: 
Great: 13; 
Moderate: 10; 
Little: 6; 
None: 2; 
Total: 31. 

System: Experimental Licensing System; 
Extent to which system provides desired types of information: 
Great: 11; 
Moderate: 13; 
Little: 4; 
None: 3; 
Total: 31. 

System: Equipment Authorization System; 
Extent to which system provides desired types of information: 
Great: 9; 
Moderate: 10; 
Little: 6; 
None: 3; 
Total: 28. 

System: Spectrum Dashboard; 
Extent to which system provides desired types of information: 
Great: 16; 
Moderate: 17; 
Little: 11; 
None: 4; 
Total: 48. 

System: License View; 
Extent to which system provides desired types of information: 
Great: 10; 
Moderate: 15; 
Little: 8; 
None: 2; 
Total: 35. 

Source: GAO survey. 

Note: The total number of responses for each system varied based on 
the number of respondents that chose to answer the question pertaining 
to the system. 

[End of table] 

Accuracy and Completeness of Information: 

According to some users of FCC's spectrum-related data systems that 
responded to our survey, inaccurate and missing data hindered their 
use of the systems to a great to moderate extent (see tables 12 and 
13).[Footnote 59] Respondents reported such problems most often with 
the Universal Licensing System. In particular, 19 of 54 respondents 
and 23 of 55 respondents reported that inaccurate information and 
missing information, respectively, in the Universal Licensing System 
hindered their use to a great or moderate extent. Dissatisfaction with 
inaccurate data rose to a similar level only for the Consolidated 
Database System; 

10 of 29 respondents reported that inaccurate data in the Consolidated 
Database System hindered their use to a great or moderate extent. In 
addition to the Universal Licensing System, respondents reported the 
most difficulties arising from missing information with the 
Consolidated Database System and the International Bureau Filing 
System. In particular, almost one-third of respondents reported that 
missing data in the Consolidated Database System and the International 
Bureau Filing System hindered their use to a great or moderate extent. 

Table 12: Summary of Survey Responses for Inaccurate Data: 

System: Universal Licensing System; 
Extent to which use is hindered by inaccurate data: 
Great: 10; 
Moderate: 9; 
Little: 14; 
None: 21; 
Total: 54. 

System: Consolidated Database System; 
Extent to which use is hindered by inaccurate data: 
Great: 4; 
Moderate: 6; 
Little: 11; 
None: 8; 
Total: 29. 

System: International Bureau Filing System; 
Extent to which use is hindered by inaccurate data: 
Great: 4; 
Moderate: 2; 
Little: 12; 
None: 9; 
Total: 27. 

System: Experimental Licensing System; 
Extent to which use is hindered by inaccurate data: 
Great: 4; 
Moderate: 0; 
Little: 16; 
None: 6; 
Total: 26. 

System: Equipment Authorization System; 
Extent to which use is hindered by inaccurate data: 
Great: 3; 
Moderate: 0; 
Little: 16; 
None: 5; 
Total: 24. 

Source: GAO survey. 

Note: The total number of responses for each system varied based on 
the number of respondents that chose to answer the question pertaining 
to the system. 

[End of table] 

Table 13: Summary of Survey Responses for Missing Data: 

System: Universal Licensing System; 
Extent to which use is hindered by missing data: 
Great: 12; 
Moderate: 11; 
Little: 18; 
None: 14; 
Total: 55. 

System: Consolidated Database System; 
Extent to which use is hindered by missing data: 
Great: 3; 
Moderate: 7; 
Little: 16; 
None: 6; 
Total: 32. 

System: International Bureau Filing System; 
Extent to which use is hindered by missing data: 
Great: 2; 
Moderate: 7; 
Little: 10; 
None: 9; 
Total: 28. 

System: Experimental Licensing System; 
Extent to which use is hindered by missing data: 
Great: 2; 
Moderate: 5; 
Little: 13; 
None: 8; 
Total: 28. 

System: Equipment Authorization System; 
Extent to which use is hindered by missing data: 
Great: 2; 
Moderate: 4; 
Little: 11; 
None: 7; 
Total: 24. 

Source: GAO survey. 

Note: The total number of responses for each system varied based on 
the number of respondents that chose to answer the question pertaining 
to the system. 

[End of table] 

User-Friendliness of Systems: 

For some users, FCC's primary spectrum-related data systems can prove 
challenging to use. In the National Broadband Plan, FCC noted that the 
complexity of its data on licensing of spectrum and the lack of 
transparency and usability of data created impediments to public 
policy and restricted the development of new technologies, such as 
dynamic spectrum access, that could utilize spectrum data. Several 
stakeholders told us that systems, such as the Universal Licensing 
System, are relatively user-friendly for "expert" users with technical 
knowledge and experience, but that the systems could pose challenges 
for other users. Consistent with this view, half or more of 
respondents reported that the International Bureau Filing System and 
the Experimental Licensing System were not too or not at all user-
friendly, and about one-third of respondents reported similar views of 
the Universal Licensing System and the Consolidated Database System 
(see table 14). 

Table 14: Summary of Survey Responses for User-Friendliness: 

System: Universal Licensing System; 
Level of user-friendliness: 
Very: 7; 
Somewhat: 27; 
Not too: 13; 
Not at all: 9; 
Total: 56. 

System: Consolidated Database System; 
Level of user-friendliness: 
Very: 7; 
Somewhat: 14; 
Not too: 7; 
Not at all: 3; 
Total: 31. 

System: International Bureau Filing System; 
Level of user-friendliness: 
Very: 1; 
Somewhat: 9; 
Not too: 9; 
Not at all: 9; 
Total: 28. 

System: Experimental Licensing System; 
Level of user-friendliness: 
Very: 4; 
Somewhat: 10; 
Not too: 9; 
Not at all: 5; 
Total: 28. 

System: Equipment Authorization System; 
Level of user-friendliness: 
Very: 3; 
Somewhat: 7; 
Not too: 9; 
Not at all: 6; 
Total: 25. 

System: Spectrum Dashboard; 
Level of user-friendliness: 
Very: 16; 
Somewhat: 19; 
Not too: 2; 
Not at all: 5; 
Total: 42. 

System: License View; 
Level of user-friendliness: 
Very: 8; 
Somewhat: 9; 
Not too: 6; 
Not at all: 6; 
Total: 29. 

Source: GAO survey. 

Note: The total number of responses for each system varied based on 
the number of respondents that chose to answer the question pertaining 
to the system. 

[End of table] 

To respond to these concerns; to help ensure greater transparency in 
spectrum allocation, assignment, and use; and to help promote 
secondary market transactions; FCC developed the Spectrum Dashboard 
and License View systems. As discussed earlier, these systems pull and 
compile data from the primary spectrum-related data systems, such as 
the Universal Licensing System and the Consolidated Database System, 
and are designed to present the information in a meaningful, easy-to-
use format to the public. In designing these systems, FCC sought a 
means whereby its data could be leveraged by citizens for greater 
purposes, and both Commission staff and external parties are better 
positioned to identify data inaccuracies or inconsistencies. As shown 
in table 14, over four-fifths of respondents reported that Spectrum 
Dashboard was very or somewhat user-friendly, thereby meeting FCC's 
intent of the system while more than half of respondents reported that 
License View was very or somewhat user-friendly. 

FCC Has Processes Aimed at Ensuring the Quality of Its Data; 

However, Past Audits Identified Some Problems: 

FCC has commissionwide programs, policies, and procedures for the 
collection and management of information, which help ensure FCC's 
compliance with governmentwide laws and regulations pertaining to 
information collection and management. For example, FCC's records 
management program is intended partly to control the quantity and 
quality of records produced by the Commission. In 2010, we reviewed 
and reported on 30 information collection systems used by FCC, 
including those associated with the Experimental Licensing System and 
the Equipment Authorization System data systems.[Footnote 60] We found 
that FCC followed relevant policies and procedures, including those 
pertaining to quality control. For this report, we examined the 
processes in place to ensure the quality of data in FCC's five 
spectrum license and authorization systems. We identified several 
quality-control features incorporated in the five systems, which we 
discuss below and illustrate in table 15. 

Table 15: Summary of FCC's Data Quality Procedures for Spectrum-
Related Data Systems: 

System: Universal Licensing System; 
Data quality control procedures: 
Edit checks: during online filing: Yes; 
Edit checks: during batch processing: Yes; 
FCC staff review: Yes; 
Notify filer of errors after review: Yes; 
Track e-mail and phone queries: Yes. 

System: Consolidated Database System; 
Data quality control procedures: 
Edit checks: during online filing: Yes; 
Edit checks: during batch processing: Yes; 
FCC staff review: Yes; 
Notify filer of errors after review: Yes; 
Track e-mail and phone queries: Yes. 

System: International Bureau Filing System; 
Data quality control procedures: 
Edit checks: during online filing: Yes; 
Edit checks: during batch processing: No; 
FCC staff review: Yes; 
Notify filer of errors after review: Yes; 
Track e-mail and phone queries: No. 

System: Experimental Licensing System; 
Data quality control procedures: 
Edit checks: during online filing: Yes; 
Edit checks: during batch processing: No; 
FCC staff review: Yes; 
Notify filer of errors after review: Yes; 
Track e-mail and phone queries: No. 

System: Equipment Authorization System; 
Data quality control procedures: 
Edit checks: during online filing: Yes; 
Edit checks: during batch processing: No; 
FCC staff review: Yes; 
Notify filer of errors after review: Yes; 
Track e-mail and phone queries: Yes. 

Source: GAO analysis of FCC data. 

Note: Since Spectrum Dashboard and License View pull data from other 
systems, such as the Universal Licensing System and the Consolidated 
Database System, we did not review the processes in place for these 
systems. 

[End of table] 

* Edit checks. FCC's spectrum-related licensing and authorization 
systems each incorporate edit checks, which check for missing or 
anomalous data elements; these edit checks occur either online during 
the filing process or in batch mode. All five systems incorporate 
online edit checks, which check the accuracy of data entered by filers 
in real time and flag potential errors for users. FCC officials said 
that these online checks are helpful to filers and help ensure data 
accuracy. In addition, the Universal Licensing System, the 
Consolidated Database System, and the International Bureau Filing 
System incorporate edit checks in the nightly batch processing of data 
submitted by users. Among other things, the edit checks address 
acceptable ranges of values, filings from parties with delinquent 
debts, and accuracy of geographic coordinates. 

* FCC staff review. Before granting a spectrum license or equipment 
authorization, FCC checks all information provided by the applicant or 
licensee using automated or staff reviews. For example, FCC staff 
scrutinizes all spectrum license renewal applications that require 
exhibits demonstrating compliance with license requirements. FCC staff 
seeks correction or clarification of any inaccuracies detected in the 
information. According to FCC officials, these ongoing staff reviews 
of applications supplement the automated edit checks. In addition to 
its own reviews, FCC accepts reports of data discrepancies from 
members of the public. 

* Filer notification. According to FCC officials, the Commission in 
part depends on the applicants for licenses to submit accurate data. 
FCC believes this is appropriate because entities filing applications 
are in the best position to know the relevant facts and are often 
experts and, therefore, the data these entities submit should be of 
high quality. Furthermore, FCC officials noted that when entities 
submit applications or renewals, they must certify and affirm the 
accuracy of the data. When FCC staff discovers errors, the Commission 
alerts the original filer and solicits correction. 

* Tracking systems. FCC maintains a help desk, with access via 
telephone and e-mail. Applicants, licensees, and the general public 
may use these resources to obtain help with FCC's data systems. In 
addition, the Universal Licensing System, the Consolidated Database 
System, and the Equipment Authorization System incorporate systems 
that track e-mail and phone queries and thus help FCC to identify 
problems with the data systems. 

While these quality-control features can help promote the quality of 
FCC's spectrum-related data, past Commission audits have uncovered 
some problems with the timeliness of FCC's data. FCC periodically 
reviews its systems and data and, from 2001 through 2005, FCC audited 
licensees in three spectrum bands. FCC conducted these audits because 
of concerns that some licensees for certain types of services included 
in the Universal Licensing System were not keeping FCC informed of 
their operating status. These audits were aimed at determining, for 
each license, whether the licensed service was operational, and 
canceling the licenses in cases where service had been discontinued. 
The audits resulted in the cancellation of the following licenses: 

* 220 MHz licenses: 94 licenses canceled out of 956 licenses audited 
(10 percent canceled): 

* Paging licenses: 2,076 licenses canceled out of 7,770 licenses 
audited (27 percent canceled): 

* Private land mobile radio licenses: 37,448 licenses canceled out of 
420,112 licenses audited (9 percent canceled)[Footnote 61] 

As these audit results illustrate, FCC's spectrum-related systems may 
not incorporate the timeliest information. FCC acknowledged that the 
extent to which its data match real world conditions depends upon the 
particular rules governing filers and the burden of filing upon 
industry. For example, since a broadcaster must renew its license once 
every 8 years, the data on file, as of the most recent renewal, may 
not remain accurate over time. Although FCC also requires that filers 
update information about significant events as needed, FCC has no 
practical way to ensure that filers comply with that requirement. FCC 
officials said that the Commission could take measures, such as 
requiring more frequent updates and certification of data in its 
databases, but such measures must be balanced with the burden placed 
upon industry. According to FCC officials, the Commission has focused 
on checking the accuracy of the data submitted to FCC at the time of 
submission, not on maintaining accuracy over time. But FCC now 
recognizes that there is a need to ensure that the data in its systems 
reflect conditions in the real world on an ongoing basis to determine 
where spectrum is available. Regarding the possibility of future 
audits, FCC officials said that the Commission does not currently have 
concerns that would warrant additional audits of license holders but, 
that if such concerns were to arise, it would consider conducting 
additional audits. 

FCC Has Several Efforts Under way with the Potential to Improve Its 
Spectrum-Related Data: 

Data Innovation Initiative: 

Recognizing the need to improve the Commission's information 
practices, in July 2009, the FCC Chairman initiated a review of FCC's 
systems and processes for information collection, processing, 
analysis, and dissemination, and this effort continued with the June 
2010 launch of the Data Innovation Initiative.[Footnote 62] According 
to FCC staff, the Commission has been working to improve its data 
collection, analysis, and dissemination practices in order to reduce 
the reporting burden on outside parties and ensure that the agency has 
timely, complete, and accurate data on which to base its activities 
and decisions. As part of this effort, FCC has sought to streamline 
the processes by which parties supply information, thereby minimizing 
work and potential errors. Furthermore, FCC is developing data quality 
analytics to measure its data quality. This effort will assess the 
accuracy of FCC's data from an input perspective (the quality of 
information submitted by filers) and from a system perspective (the 
maintenance of accurate information in FCC's databases, including the 
extent to which the data reflect conditions in the real world). 

Chief Data Officers: 

Alongside the Data Innovation Initiative, FCC created a Chief Data 
Officer for the Commission and Chief Data Officers inside each Bureau 
and Office. The Commission's Chief Data Officer is responsible for 
improving how the Commission collects, uses, and disseminates data, 
among other things, and oversees the Data Innovation Initiative. The 
Wireless Telecommunication Bureau's Chief Data Officer reports 
directly to the Bureau Chief and, according to FCC officials, has been 
closely engaged in spectrum-related data analysis, including the 
identification of spectrum needs. 

Consolidation of Databases: 

In 2009, FCC began an effort to consolidate its numerous, bureau-
based, and separately managed licensing systems into a single system 
known as the Consolidated Licensing System (CLS). According to FCC 
staff, as currently envisioned, CLS would provide the public with a 
single portal for access to all FCC licensing systems and would have 
user-friendly features. In addition, CLS would incorporate enhanced 
edit check capability, including for example, validation of geographic 
coordinates for antennas to ensure that the coordinates coincide with 
the locations of the antennas. FCC staff said that CLS would include 
information from its legacy databases, such as the Universal Licensing 
System, and that cost considerations may affect how much legacy 
information the new system includes; however, FCC believes that the 
information for the current filings and the previous filings should be 
sufficient to meet FCC's needs for spectrum management. Because of the 
complexity and size of this effort, FCC expects to deploy CLS in 
phases over a period of years. 

[End of section] 

Appendix III: Expert and Stakeholder Respondents' Views on FCC's Plans 
and Recent Actions to Meet Future Spectrum Needs: 

This appendix presents the views of experts and industry stakeholders 
on the spectrum-related recommendations in the National Broadband Plan 
and FCC's steps to implement those recommendations.[Footnote 63] We 
surveyed 30 experts and 79 industry stakeholders, and 20 of the 
experts and 54 of the stakeholders responded to our survey, 
representing a 68 percent response rate (see appendix I for additional 
information on our survey methodology). For each recommendation from 
the National Broadband Plan covered by our survey, we provide the 
following: 

* the text of the recommendation; 

* a summary of the rationale for the recommendation presented in the 
National Broadband Plan; 

* data on experts' and stakeholders' level of agreement with the 
recommendation; 

* excerpts from experts' and stakeholders' comments on the 
recommendation;[Footnote 64] 

* a description of FCC's progress on implementing the recommendation 
through May 2011; 

* data on experts' and stakeholders' level of satisfaction with FCC's 
progress on implementing the recommendation through May 2011 (for 
those recommendations directed at FCC); 

and: 

* excerpts from experts' and stakeholders' comments on FCC's progress 
on implementing the recommendation. 

National Broadband Plan Recommendations Aimed at Making More Spectrum 
Available for Wireless Broadband Use by 2015: 

Make 300 MHz of Spectrum Available by 2015 and 500 MHz by 2020: 

Recommendation: 

FCC should make 500 MHz newly available for broadband use within the 
next 10 years, of which 300 MHz between 225 MHz and 3.7 GHz should be 
made newly available for mobile use within 5 years. 

Rationale: 

FCC believes that additional spectrum should be made available to help 
meet anticipated increases in demand for wireless broadband services. 
The targets were based on an FCC staff forecast of spectrum demand. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 10; 
Broadcasters: 0; 
Wireless device manufacturers: 4; 
Wireless service providers: 15; 
Others: 5; 
Total: 34. 

Level of agreement: Somewhat agree; 
Experts: 6; 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 2; 
Others: 0; 
Total: 10. 

Level of agreement: Neither agree nor disagree; 
Experts: 0; 
Broadcasters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 2; 
Total: 6. 

Level of agreement: Somewhat disagree; 
Experts: 1; 
Broadcasters: 1; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 1; 
Total: 5. 

Level of agreement: Strongly disagree; 
Experts: 2; 
Broadcasters: 7; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 0; 
Total: 12. 

Level of agreement: Total; 
Experts: 19; 
Broadcasters: 10; 
Wireless device manufacturers: 9; 
Wireless service providers: 21; 
Others: 8; 
Total: 67. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: I believe that this approach will align with market 
demands. 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: I strongly agree with the direction of change (more 
licensed spectrum), and the amounts are not trivial - but 'still more' 
is the correct answer. 

Type of commenter (level of agreement): Expert (somewhat disagree); 
Comment excerpts: If the need for data is increasing by 25x (only the 
next five years, I would expect it to continue to increase if the 
report of the increase is accurate) then how is a 2x improvement in 
spectrum going to fix the problem. Cellular works because of spectral 
reuse, not because of spectrum. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: (1) This is an unrealistic objective for many 
reasons including the fact that there are no mechanisms in place that 
have even a remote chance of success. (2) This is a dangerous 
objective since its promise will result in a false sense of 
complacency that will keep the FCC and NTIA from stimulating the REAL 
solution to the broadband spectrum problem - stimulation of 
technologies that can multiply spectrum capacity rather than just add 
increments and (3) even if the objective succeeds, the problem will 
not be solved. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: This ... plays into the pocket books of the big 
incumbents. Broadband is not in the desert southwest or Appalachia 
because it is not now and never will be financially workable... 
Instead, the FCC should require incumbent reporting of fallow spectrum 
so the FCC can identify chunks of [spectrum] to be licensed to small 
enterprises whose primary business is not telecommunications (such as 
trucking companies, agriculture, tourism) so that they can use 
programmable wireless devices to bring broadband to niche markets in a 
way that promotes entrepreneurism in those markets, such as the desert 
southwest and Appalachia. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: Need for more spectrum is a result of wireless 
provider's OWN CHOICE on not reducing cell size; cheaper to buy more 
spectrum. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: The FCC has not provided a sufficient justification 
for its spectrum reallocation goals, and the amount of spectrum sought 
is an arbitrary number. Such demand-based projections should be 
technology agnostic, identifying the most efficient spectrum 
allocations to satisfy the marketplace. The efficiency of 
broadcasting's 'one-to-many' approach is an important factor in 
managing the so-called 'spectrum crisis.' 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: This plan does not adequately take into account that 
(1) over 2/3 of the spectrum currently held for mobile broadband has 
not yet been deployed, (2) femto/pico cell and Wi-Fi offloading can 
have a substantial role, (3) that 66% of mobile broadband traffic will 
be video, and MDTV broadcasting should be used to deliver that high-
volume data. The approach of simply shifting spectrum in this manner 
only serves to consolidate more spectrum in the hands of fewer 
gatekeepers, rather than creating more bandwidth for users by 
understanding the usage patterns and applying the proper 
technology/spectrum combination. Spectrum is not a panacea and this 
approach will ultimately create a recurring scenario of "spectrum 
crisis" every few years with the inevitable calls for more spectrum. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: It is well-documented that mobile broadband use is 
increasing dramatically and will outstrip the supply of available 
bandwidth in the near future. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: Additional spectrum that is made available for 
auction must come with an assurance of device interoperability across 
each band of spectrum auctioned. Without this assurance via license 
requirement or other mechanism, future spectrum will be subject to the 
same sort of balkanization into proprietary bandclasses by carriers 
large enough to influence or control the specifications of devices or 
network equipment, as has been the case in the 700 MHz spectrum. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat disagree); 
Comment excerpts: Although additional spectrum is needed, this 
[recommendation] appears biased towards mobile broadband while 
underestimating the spectrum needed for fixed wireless broadband [by] 
up to 48 million citizens with no broadband option [in their] homes 
today. 

Type of commenter (level of agreement): Wireless service provider 
(strongly disagree); 
Comment excerpts: This spectrum will be hoarded by the large carriers 
and further squeeze the small rural carriers out of the market. This 
will further eliminate competition in the wireless industry. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

Our survey asked respondents how satisfied they were overall with 
FCC's progress on this recommendation, which had five 
subrecommendations. However, rather than providing an overall 
description of FCC's progress, our survey referred respondents to the 
descriptions of FCC's progress contained within the survey's questions 
on the subrecommendations. Those descriptions are shown in this 
appendix under the other recommendations in this section of the 
appendix. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 1; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 0; 
Total: 2. 

Level of satisfaction: Somewhat satisfied; 
Experts: 6; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 2; 
Wireless service providers: 5; 
Others: 1; 
Total: 14. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 2; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 2; 
Wireless service providers: 4; 
Others: 2; 
Total: 10. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 4; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 2; 
Wireless service providers: 3; 
Others: 0; 
Total: 9. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 2; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 0; 
Wireless service providers: 3; 
Others: 1; 
Total: 6. 

Level of satisfaction: Total; 
Experts: 15; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 6; 
Wireless service providers: 16; 
Others: 4; 
Total: 41. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. Since no broadcasters strongly agreed or somewhat agreed 
with the recommendation, no figures are shown for broadcasters. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (somewhat satisfied); 
Comment excerpts: [FCC] should have auctioned [the] D block already, 
but [FCC] is working hard on MSS. 

Type of commenter (level of satisfaction): Expert (neither satisfied 
nor dissatisfied); 
Comment excerpts: The Congress is in the leadership role on the 
auctions [that are needed to implement several of the components of 
this recommendation]. 

Type of commenter (level of satisfaction): Expert (somewhat 
dissatisfied); 
Comment excerpts: ... progress in this area is very difficult and 
complex. FCC has been under extreme resource challenges. Would like 
process to move faster, but recognize that this may not be 
reasonable... 

Type of commenter (level of satisfaction): Expert (strongly 
dissatisfied); 
Comment excerpts: ... FCC is falling well behind other international 
markets in its efforts to avail spectrum resources for the US to 
attain a leadership position in mobile and fixed broadband. 

Type of commenter (level of satisfaction): Infrastructure provider 
(somewhat satisfied); 
Comment excerpts: ... FCC is working well with NTIA to free up other 
spectrum for traditional auction. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (somewhat satisfied); 
Comment excerpts: The Commission established an aggressive timetable 
for implementation, not anticipating the political environment and 
Congressional limbo on incentive auction authority. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat satisfied); 
Comment excerpts: [FCC will not meet its 5-year target] if steps are 
not taken soon to accelerate the reallocation of suitable federal 
spectrum for commercial provider use, to repurpose significant amounts 
of TV broadcast and MSS spectrum for terrestrial broadband use under 
incentive auctions, and to auction the 700 MHz D Block or otherwise 
provide for public/private commercial mobile uses of excess capacity 
on [this] spectrum. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat satisfied); 
Comment excerpts: The FCC has issued an item seeking comment on NTIA-
identified bands--a good initial step. 

Source: GAO survey. 

[End of table] 

Reallocate Portion of Television Spectrum (120 MHz): 

Recommendation: 

FCC should initiate a rulemaking proceeding to reallocate 120 MHz from 
the broadcast television bands. 

Rationale: 

FCC believes that spectrum currently allocated for over-the-air 
television broadcasting would have much higher economic value if it 
were allocated for wireless broadband. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 12; 
Broadcasters: 0; 
Wireless device manufacturers: 4; 
Wireless service providers: 15; 
Others: 3; 
Total: 34. 

Level of agreement: Somewhat agree; 
Experts: 2; 
Broadcasters: 0; 
Wireless device manufacturers: 3; 
Wireless service providers: 0; 
Others: 2; 
Total: 7. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 2; 
Total: 5. 

Level of agreement: Somewhat disagree; 
Experts: 2; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 0; 
Total: 3. 

Level of agreement: Strongly disagree; 
Experts: 1; 
Broadcasters: 11; 
Wireless device manufacturers: 1; 
Wireless service providers: 3; 
Others: 1; 
Total: 17. 

Level of agreement: Total; 
Experts: 18; 
Broadcasters: 11; 
Wireless device manufacturers: 9; 
Wireless service providers: 20; 
Others: 8; 
Total: 66. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Perhaps the single most important step the 
government can take to improve US wireless broadband is to let the FCC 
auction off broadcast TV spectrum. It is beyond argument that 
broadcasters do not need everything they have and that the national 
interest--jobs, public discourse, economic growth, improved health 
care service--is with expanding wireless broadband. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: TV has been the blatant abuser of spectrum so this 
is righting a wrong. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: [FCC] should also have considered reallocation with 
leasing rights. 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: Reallocating the TV band spectrum toward more market-
based approach is important. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: The FCC could solve this problem immediately by: (1) 
de-zoning broadcast spectrum and allowing other uses and expanding 
secondary markets; (2) reorganizing remaining broadcast licensees in 
each market into more compact bands and reclaiming broadcast spectrum 
that is not licensed. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: More US citizens use and rely on the broadcast 
spectrum than any other spectrum category being considered. 
Broadcasters are also deploying MDTV with this spectrum. This 
deployment will play a significant role in mobile broadband content 
delivery and should be encouraged to flourish as it is the most 
efficient way of distributing video, which Cisco says will account for 
66% of all mobile traffic in 2015. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: The solution to moving underutilized broadcast 
spectrum to mobile carriers is to lift the FCC rules that prevent 
broadcasters from selling or leasing such spectrum to mobile carriers 
in a private market transaction. Applying the FCC's secondary markets 
policy to broadcast spectrum would enable the parties to clear the 
spectrum where needed, on a voluntary basis, without government 
involvement. If a checkerboard of spectrum is freed up (that is, non-
adjacent channels), the FCC could streamline its channel-change and 
channel-swap procedures for the new mobile licensees just like the FCC 
did about 10 years ago to clear the 700 MHz band of broadcasters. By 
the way, it is not entirely clear that mobile operators really need 
two adjacent 6 MHz channels. Qualcom has a new chip that uses just one 
6 MHz channel for two-way mobile data, and Sprint has argued that 
adjacent channels are not necessary for 4G systems. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: The proposal to reallocate 120 MHz of spectrum from 
the TV band is likely to have a significant impact on the public's 
access to free over the air television. Any reallocation must be based 
on fair data and after a full evaluation of spectrum use and public 
need. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: The digital transition has just been completed. 
Disruption of the spectrum based on speculative need is inappropriate. 
As is the FCC concluding that broadcast spectrum is "less valuable" 
based on a wireless per pop analysis. Broadcast spectrum serves a 
different function and should not be valued using the same metrics as 
another service... 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: This recommendation should not be implemented absent 
compelling data, and absent a full and complete spectrum inventory 
that also analyzes current utilization. Action, if at all, should be 
predicated on demonstrated need rather than on bare assertions of a 
"looming spectrum crisis," and after full investigation of whether 
less disruptive alternatives to reallocation of broadcast spectrum 
could address demonstrated needs. This proposal, if implemented, will 
impose real and substantial costs on broadcasters and will have a 
significant negative impact on the public's access to free over-the-
air television. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly disagree); 
Comment excerpts: The incumbents say they need this right away when 
they don't use 50-90% of what they already control at all, let alone 
efficiently. The FCC approved white space and then decided to do 
incentive auction. This is crazy policy. Make the carriers show how 
much they use and how efficiently before you do anything. 

Type of commenter (level of agreement): Wireless service provider 
(strongly disagree); 
Comment excerpts: Allocating 120 MHz to mobile broadband completely 
eviscerates the needs of fixed wireless broadband. At least 42 MHz of 
unlicensed TV band spectrum must be preserved to allow fixed wireless 
broadband providers to provide broadband for citizens who have No 
Available Terrestrial Broadband options today. 

Type of commenter (level of agreement): Public interest group 
(strongly disagree); 
Comment excerpts: This process will directly undermine dynamic 
spectrum access technologies (e.g., television white space devices), 
killing one of the most innovative new spectrum utilization ideas 
we've seen in a generation. Instead, the FCC will continue using much 
the same remarkably inefficient system of spectrum licensure that has 
lead to current artificial scarcities and inefficiencies. Bribing 
license holders to vacate from bands is a horrible idea. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

* In June 2010 FCC issued a technical paper providing more detail than 
the National Broadband Plan on how reallocating a portion of the 
television bands might work. It presented an analysis of bandwidth 
requirements of various video streams, data to support the assertion 
that two television stations could voluntarily share a single six-MHz 
channel and continue to broadcast their primary video streams in high 
definition, and an initial look at the television allotment 
optimization model being developed by the FCC.[Footnote 65] 

* In June 2010, FCC held a "Broadcast Engineering Forum" with 
broadcast industry engineers and technical experts in related fields 
regarding future rulemakings on reallocating spectrum from the 
broadcast television bands, including rule-makings regarding service 
areas, distance separations, and channel-sharing. 

* In November 2010, FCC issued a Notice of Proposed Rulemaking (NPRM) 
to establish a regulatory framework to facilitate wireless broadband 
uses of the UHF and VHF television bands, while maintaining current 
license assignments in the band.[Footnote 66] 

* In March and April 2011, FCC held a series of web-based seminars 
with state broadcasting associations to describe how FCC thinks an 
incentive auction might work and give broadcasters a chance to ask 
questions. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 3; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 3; 
Wireless service providers: 2; 
Others: 1; 
Total: 9. 

Level of satisfaction: Somewhat satisfied; 
Experts: 5; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 1; 
Wireless service providers: 7; 
Others: 2; 
Total: 15. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 2; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 1; 
Wireless service providers: 4; 
Others: 1; 
Total: 8. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 2; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 2; 
Wireless service providers: 1; 
Others: 1; 
Total: 6. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 2; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 0; 
Wireless service providers: 0; 
Others: 0; 
Total: 2. 

Level of satisfaction: Total; 
Experts: 14; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 7; 
Wireless service providers: 14; 
Others: 5; 
Total: 40. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. Since no broadcasters strongly agreed or somewhat agreed 
with the recommendation, no figures are shown for broadcasters. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (very satisfied); 
Comment excerpts: Good example of how to do it right. 

Type of commenter (level of satisfaction): Expert (strongly 
dissatisfied); 
Comment excerpts: My dissatisfaction is with Congress, not the FCC. 
This should move faster and the broadcasters should stop trying to 
derail this process. 

Type of commenter (level of satisfaction): Expert (strongly 
dissatisfied); 
Comment excerpts: Congress is the big problem here. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (very satisfied); 
Comment excerpts: We believe that the FCC is doing everything in its 
power to move along the 120 MHz reallocation, but believe that FCC 
progress will only continue if Congress lets the FCC do its job. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (very satisfied); 
Comment excerpts: . .it is very important that the Congress empowers 
the FCC with the ability to implement voluntary incentive auctions, as 
this is the mechanism that will provide the opportunity to ensure this 
valuable spectrum is put to its most highly valued uses. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (somewhat dissatisfied); 
Comment excerpts: Unfortunately the need for incentive auction 
authority lays at the hands of congress. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat satisfied); 
Comment excerpts: The prospect of the FCC holding auctions to license 
as much as 120 MHz of repurposed TV Broadcast spectrum in the 2012-
2013 timeframe as originally proposed in the FCC's NBP is increasingly 
problematic. Legislation authorizing incentive auction authority has 
been proposed but passage is uncertain. In addition, numerous 
requirements have been proposed to be included in such legislation 
which, if adopted, would substantially reduce the amount of repurposed 
spectrum available for auction. 

Source: GAO survey. 

[End of table] 

Accelerate Terrestrial Deployment in Mobile Satellite Services 
Spectrum (90 MHz): 

Recommendation: 

FCC should accelerate terrestrial deployment in 90 MHz of Mobile 
Satellite Services spectrum. 

Rationale: 

To address what FCC now believes are overly-burdensome requirements 
that it set for Mobile Satellite Services operators before they could 
deploy terrestrial networks to enhance coverage in areas where their 
satellite signal is weakened or unavailable, the plan recommends 
accelerating terrestrial deployment by providing sufficient 
flexibility to licensees to increase terrestrial broadband use of 
Mobile Satellite Services spectrum, while preserving market-wide 
capability to provide unique mission-critical Mobile Satellite 
Services. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 9; 
Broadcasters: 0; 
Wireless device manufacturers: 5; 
Wireless service providers: 8; 
Others: 4; 
Total: 26. 

Level of agreement: Somewhat agree; 
Experts: 3; 
Broadcasters: 1; 
Wireless device manufacturers: 1; 
Wireless service providers: 4; 
Others: 0; 
Total: 9. 

Level of agreement: Neither agree nor disagree; 
Experts: 2; 
Broadcasters: 6; 
Wireless device manufacturers: 2; 
Wireless service providers: 4; 
Others: 1; 
Total: 15. 

Level of agreement: Somewhat disagree; 
Experts: 1; 
Broadcasters: 2; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 1; 
Total: 6. 

Level of agreement: Strongly disagree; 
Experts: 1; 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 1; 
Total: 3. 

Level of agreement: Total; 
Experts: 16; 
Broadcasters: 9; 
Wireless device manufacturers: 8; 
Wireless service providers: 19; 
Others: 7; 
Total: 59. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: FCC is doing everything it can to move MSS spectrum 
into terrestrial wireless market. [The provisional waiver that FCC 
granted to] LightSquared is unexpectedly complicated due to GPS 
interference, but FCC definitely seems to be on the right track with 
the 40 MHz of S Band spectrum. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Having spectrum set aside for satellite use is 
potentially a very inefficient use of spectrum and unlocking the value 
of that spectrum could be very beneficial. 

Type of commenter (level of agreement): Expert (somewhat disagree); 
Comment excerpts: The business case and public interest is not clear; 
[FCC] should identify and develop more alternatives. 

Type of commenter (level of agreement): Broadcaster (somewhat 
disagree); 
Comment excerpts: Making terrestrial allocations in this band has 
increased interference to uses adjacent to that band (e.g., ENG 
facilities in 2Ghz band); interference criteria should be strengthened 
and strictly adhered to. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: [The best approach would be to use] . .incentive 
auctions in this band to allow deployment of terrestrial mobile 
broadband systems. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: [We strongly agree with this recommendation s]o long 
as no harmful interference occurs to wireless carriers and public 
safety from LightSquared operations. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: Good spectrum, cleared and ready to use. But FCC can 
do little as this spectrum is trapped in bankruptcy proceedings. It 
will be very difficult for FCC to change the rules for ultimate new 
licensees after they pay value in bankruptcy. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat disagree); 
Comment excerpts: Interference concerns regarding locating a 
terrestrial band next to a space-based band were well-founded. Testing 
has already proved substantial interference will occur with GPS 
systems. Other MSS spectrum may not share these same problems (i.e. 
not near GPS L1), but the FCC needs to move cautiously. 

Type of commenter (level of agreement): Public interest group 
(strongly agree); 
Comment excerpts: There are certainly complexities with this approach, 
but it is worthwhile - this is valuable, useful spectrum. 

Type of commenter (level of agreement): Mobile Satellite Services 
company (neither agree nor disagree); 
Comment excerpts: [Our level of agreement with the recommendation] 
would be very different depending on whether the recommendation was 
interpreted to mean accelerate removal of MSS players to allow for 
terrestrial deployment, or simply accelerate ongoing progress to 
manage both satellite and terrestrial deployment in the bands. 

Type of commenter (level of agreement): Private user group (somewhat 
disagree); 
Comment excerpts: Terrestrial deployment in MSS bands raises 
significant technical issues that require careful study and should not 
be rushed. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

* In July 2010, FCC issued an NPRM to add co-primary Fixed and Mobile 
allocations to the 2 gigahertz (GHz) band, consistent with the 
International Table of Allocations. This allocation modification is a 
precondition for more flexible licensing of terrestrial services 
within the band. FCC also proposed to apply its secondary market 
policies and rules applicable to terrestrial services to all 
transactions involving the use of Mobile Satellite Services bands for 
terrestrial services in order to create greater predictability and 
regulatory parity with bands licensed for terrestrial mobile broadband 
service. 

* In July 2010, FCC requested comment in a notice of inquiry on 
further steps it could take to increase the value, utilization, 
innovation, and investment in Mobile Satellite Services spectrum 
generally. 

* In January 2011, FCC granted a waiver to LightSquared allowing it to 
expand its terrestrial use of its satellite spectrum, conditional on, 
among other things, addressing concerns regarding interference with 
Global Positioning System devices to FCC's satisfaction. 

* In April 2011, FCC issued a Report and Order adopting the proposals 
in its July 2010 NPRM. 

* In May 2011, FCC solicited input on approaches to maximize 
terrestrial mobile broadband use of 2 GHz range spectrum that is 
allocated for fixed and mobile use.[Footnote 67] 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 3; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 2; 
Wireless service providers: 2; 
Others: 2; 
Total: 9. 

Level of satisfaction: Somewhat satisfied; 
Experts: 4; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 2; 
Wireless service providers: 6; 
Others: 1; 
Total: 13. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 2; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 0; 
Total: 3. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 3; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 2; 
Wireless service providers: 2; 
Others: 0; 
Total: 7. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 0; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 1; 
Total: 2. 

Level of satisfaction: Total; 
Experts: 12; 
Broadcasters: [Empty]; 
Wireless device manufacturers: 6; 
Wireless service providers: 12; 
Others: 4; 
Total: 34. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. Since no broadcasters strongly agreed or somewhat agreed 
with the recommendation, no figures are shown for broadcasters. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (somewhat 
dissatisfied); 
Comment excerpts: I have some concerns regarding interference with 
existing spectrum used for other systems such as GPS. 

Type of commenter (level of satisfaction): Infrastructure provider 
(very satisfied); 
Comment excerpts: The LightSquared GPS interference issues aside, this 
is an important block of spectrum that would be better utilized for 
terrestrial networks, provided the interference issue with GPS can be 
managed. 

Source: GAO survey. 

[End of table] 

Auction Advanced Wireless Services Spectrum (60 MHz): 

Recommendation: 

FCC should make up to 60 megahertz available by auctioning Advanced 
Wireless Services (AWS) bands, including, if possible, 20 megahertz 
from federal allocations. 

Rationale: 

The plan noted that FCC has already allocated spectrum for AWS, and 
called for FCC to expeditiously resolve the future of this spectrum. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 12; 
Broadcasters: 2; 
Wireless device manufacturers: 8; 
Wireless service providers: 11; 
Others: 3; 
Total: 36. 

Level of agreement: Somewhat agree; 
Experts: 4; 
Broad-casters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 3; 
Others: 3; 
Total: 13. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Broad-casters: 4; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 1; 
Total: 9. 

Level of agreement: Somewhat disagree; 
Experts: 0; 
Broad-casters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 0; 
Total: 2. 

Level of agreement: Strongly disagree; 
Experts: 1; 
Broad-casters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 3; 
Others: 0; 
Total: 4. 

Level of agreement: Total; 
Experts: 18; 
Broad-casters: 9; 
Wireless device manufacturers: 10; 
Wireless service providers: 20; 
Others: 7; 
Total: 64. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Congress should learn from the unexpectedly slow AWS 
transition from government to commercial use and just compensate 
government agencies for transition costs to accelerate the repurposing. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: These changes will cost $B in DoD and DHS which is 
not resourced to address the changes. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: To the greatest extent possible, the allocations 
also should be globally harmonized to promote economies of scale, 
which will drive benefits to network operators and ultimately 
consumers in the form of lower priced equipment and devices. 

Type of commenter (level of agreement): Wireless device manufacturer 
(somewhat agree); 
Comment excerpts: H block will create interference concerns to 
existing PCS band. J block downlink should be aggregated with AWS-3 
and paired with Federal spectrum bands 1755-1780 MHz to expand the 
existing AWS-1 band. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: Had FCC moved quickly on this--or on D Block 
auction--T-Mobile would not have agreed to be acquired by AT&T because 
it would have better spectrum opportunities. So ... there is a direct 
line between [this] FCC failure to act quickly ... and likely creation 
of a wireless/wireless duopoly that cannot easily be undone. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: NTIA should reallocate 25 MHz of spectrum (1755-1780 
MHz) to pair with AWS-3 and Upper AWS-2 J Block. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: We support the pairing of 25 MHz of Federal spectrum 
including 1755-1780 MHz with 2155-2180 MHz (combining the AWS-3 band 
with upper J Block spectrum). We also support the reallocation of 
additional Federal spectrum, 1695-1710 MHz, to be paired with 
unspecified Federal or possibly non-Federal spectrum. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat disagree); 
Comment excerpts: Until rules are in place that facilitate efficient 
and complete use of currently licensed spectrum (e.g., device 
interoperability requirements across all blocks of paired spectrum in 
each band), there is not an urgent need for more to be auctioned. 
Moreover, without the assurance of such things as device 
interoperability, small operators and new entrants are unlikely to 
participate in future auctions--reducing the number of bidders and, 
therefore, reducing auction revenues. 

Type of commenter (level of agreement): Wireless service provider 
(strongly disagree); 
Comment excerpts: Interoperability needs to be resolved first on 
current spectrum. The device ecosystem is of paramount importance to 
carrier buildouts and lack of interoperability has many carriers on 
hold. We need to effectively use current spectrum first. This also 
needs to be part of any and all future auctions or it will limit 
interest to only the Tier 1 carriers. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

* In July 2010, FCC requested comment in a Notice of Inquiry on 
whether the opportunity to integrate the AWS-2 J Block and 2 GHz of 
Mobile Satellite Spectrum would help attract new investment and 
utilization. 

* FCC consulted with NTIA on the 10-year "Plan and Timetable to Make 
Available 500 Megahertz of Spectrum for Wireless Broadband" and the 
"Assessment of the Near-Term Viability of Accommodating Wireless 
Broadband Systems in the 1675-1710 MHz, 1755-1780 MHz, 3500-3650 MHz, 
and 4200-4220 MHz, 4380-4400 MHz Bands" (also referred to as the "Fast 
Track Evaluation"), both of which NTIA issued in November 2010. 

* FCC officials told us that the Commission intends to take further 
steps to implement this recommendation, in consultation with NTIA as 
appropriate, after NTIA completes its assessment of the suitability of 
the 1755-1850 MHz band for repurposing. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 1; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 0; 
Total: 2. 

Level of satisfaction: Somewhat satisfied; 
Experts: 8; 
Broadcasters: 0; 
Wireless device manufacturers: 3; 
Wireless service providers: 4; 
Others: 2; 
Total: 17. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 4; 
Broadcasters: 1; 
Wireless device manufacturers: 2; 
Wireless service providers: 2; 
Others: 2; 
Total: 11. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 2; 
Broadcasters: 1; 
Wireless device manufacturers: 3; 
Wireless service providers: 4; 
Others: 0; 
Total: 10. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 0; 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 1; 
Total: 4. 

Level of satisfaction: Total; 
Experts: 15; 
Broadcasters: 3; 
Wireless device manufacturers: 9; 
Wireless service providers: 12; 
Others: 5; 
Total: 44. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (very satisfied); 
Comment excerpts: 1755 to 1850 MHz is critically important to the 
commercial wireless sector. Steps should be taken as soon as possible 
to begin moving in that direction. 

Type of commenter (level of satisfaction): Expert (somewhat satisfied); 
Comment excerpts: AWS-3 pairing in the hands of executive branch. 
Makes sense to hold off on AWS-2. 

Type of commenter (level of satisfaction): Infrastructure provider 
(somewhat satisfied); 
Comment excerpts: Kudos to the FCC for pressing ahead. NTIA has known 
for a while how important this spectrum is, and clearly wanted to 
avoid having to move federal users, some of whom would be moved for 
the second time. Without legislative improvements in federal 
relocation process, moving users is difficult. 

Type of commenter (level of satisfaction): Mobile Satellite Services 
company (neither satisfied nor dissatisfied); 
Comment excerpts: Significant interference issues and [emissions] into 
adjacent bands must be considered to effectively integrate the AWS-2 J 
block with the 2GHz MSS band. 

Type of commenter (level of satisfaction): Public interest group 
(strongly dissatisfied); 
Comment excerpts: Nothing meaningful has been implemented. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (neither satisfied nor dissatisfied); 
Comment excerpts: The holdup is NTIA to allow pairing of [the] 1755-
1780 [MHz band] with FCC's AWS-3 band. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (somewhat dissatisfied); 
Comment excerpts: NTIA manages spectrum the same way they did 20 years 
ago ... They protect the status quo. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat satisfied); 
Comment excerpts: Good progress at discussion level but execution and 
timing will be critical. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat dissatisfied); 
Comment excerpts: Need quicker review and reallocation of the 1755-
1850 MHz band. 

Type of commenter (level of satisfaction): Wireless service provider 
(strongly dissatisfied); 
Comment excerpts: Progress has not been rapid enough to meet the near-
term needs of regional and local commercial providers for additional 
mobile broadband spectrum. 

Source: GAO survey. 

[End of table] 

Make Wireless Communications Services Spectrum Available (20 MHz): 

Recommendation: 

FCC should make 20 megahertz available for mobile broadband use in the 
2.3 GHz Wireless Communications Service band, while protecting 
neighboring federal, nonfederal Aeronautical Mobile Telemetry and 
satellite radio operations. 

Rationale: 

Since FCC first auctioned Wireless Communications Service spectrum in 
1997, a number of new and robust wireless telecommunications 
technologies have been successfully introduced. Such technologies, 
coupled with the exploding demand for broadband services, suggest that 
the Wireless Communications Service spectrum may provide fertile 
ground for the provision of high-value mobile broadband services to 
the public. In order to realize this potential FCC needs to revise 
outdated rules intended to protect against interference from use of 
the spectrum. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 11; 
Broadcasters: 0; 
Wireless device manufacturers: 4; 
Wireless service providers: 4; 
Others: 2; 
Total: 21. 

Level of agreement: Somewhat agree; 
Experts: 5; 
Broadcasters: 1; 
Wireless device manufacturers: 2; 
Wireless service providers: 4; 
Others: 2; 
Total: 14. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Broadcasters: 8; 
Wireless device manufacturers: 2; 
Wireless service providers: 8; 
Others: 2; 
Total: 21. 

Level of agreement: Somewhat disagree; 
Experts: 1; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 1; 
Total: 5. 

Level of agreement: Strongly disagree; 
Experts: 0; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 0; 
Total: 2. 

Level of agreement: Total; 
Experts: 18; 
Broadcasters: 9; 
Wireless device manufacturers: 10; 
Wireless service providers: 19; 
Others: 7; 
Total: 63. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: [The recommendation] should have been 25-30 
Megahertz ... rather than just 20 megahertz. 

Type of commenter (level of agreement): Expert (somewhat disagree); 
Comment excerpts: The 2.3GHz band offers a lot of potential for mass 
market services. ... the mass market will provide more than enough 
economic incentive to reallocate incumbent systems. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly disagree); 
Comment excerpts: Aligning this band with global allocation for mobile 
[broadband] was the right thing to do. However, the imposed duty-
cycles on the technologies to operate in this band negatively impact 
the business case because the rules do not allow the right ratio of 
downlink to uplink when using [time division duplexing]. Also there 
are issues with the stringent [out-of-band emissions] and power limits. 

Type of commenter (level of agreement): Wireless device manufacturer 
(somewhat disagree); 
Comment excerpts: This spectrum should be made available for mobile 
broadband, and while neighbors should be protected the FCC should not 
go further than absolutely necessary or else risk diminishing the 
value of this 20 megahertz. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: At least 25 Megahertz should be made available for 
mobile broadband under technology-neutral rules, and neighboring 
services should be protected to appropriate (but not excessive) levels. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

In May 2010, FCC adopted rules that will make available 25 MHz of 
spectrum for mobile broadband service in much of the United States, 
while protecting adjacent satellite radio and aeronautical mobile 
telemetry operations. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 2; 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 1; 
Total: 4. 

Level of satisfaction: Somewhat satisfied; 
Experts: 6; 
Broadcasters: 1; 
Wireless device manufacturers: 3; 
Wireless service providers: 2; 
Others: 1; 
Total: 13. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 3; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 0; 
Total: 4. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 2; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 5; 
Others: 1; 
Total: 9. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 2; 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 0; 
Others: 1; 
Total: 3. 

Level of satisfaction: Total; 
Experts: 15; 
Broadcasters: 1; 
Wireless device manufacturers: 5; 
Wireless service providers: 8; 
Others: 4; 
Total: 33. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (neither satisfied 
nor dissatisfied); 
Comment excerpts: Processes to accomplish this take a long time and 
nothing has been done to change that. ... the amount of spectrum is 
infinitesimal in the context of the demand. 

Type of commenter (level of satisfaction): Expert (somewhat 
dissatisfied); 
Comment excerpts: Too slow. 

Type of commenter (level of satisfaction): Expert (strongly 
dissatisfied); 
Comment excerpts: Spectrum is not available for broadband use because 
FCC has not completed rules or addressed licensing issues. 

Type of commenter (level of satisfaction): Mobile Satellite Services 
company (somewhat dissatisfied); 
Comment excerpts: Absence of consensus by WCS and [satellite digital 
audio radio] licensees negates the effectiveness of FCC decision on 
technical rules. 

Type of commenter (level of satisfaction): Public interest group 
(strongly dissatisfied); 
Comment excerpts: The FCC has still not implemented anything 
meaningful. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (neither satisfied nor dissatisfied); 
Comment excerpts: Too early to determine whether rules will result in 
effective deployment of mobile broadband in this spectrum. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat dissatisfied); 
Comment excerpts: Petitions for reconsideration filed in this 
proceeding raise questions about whether the band can actually be used 
to provide mobile broadband service. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat dissatisfied); 
Comment excerpts: The FCC could have been more aggressive by placing 
more of the burden on SDARS. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat dissatisfied); 
Comment excerpts: While FCC's May 2010 decision was a useful first 
step, petitions for reconsideration filed by WCS interests illustrate 
material flaws in technical rules and performance requirements that 
jeopardize the prospects for the band actually being used for the 
offering of broadband services to the public. 

Source: GAO survey. 

[End of table] 

Auction the Upper 700 MHz D Block (10 MHz): 

Recommendation: 

FCC should auction the 10 MHz Upper 700 MHz D Block for commercial use 
that is technically compatible with public safety broadband services. 

Rationale: 

To realize the high potential value that FCC believes the 10 MHz Upper 
700 MHz D Block has for commercial broadband while supporting the 
simultaneous development of public safety broadband capability through 
equipment development, roaming, and priority access. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 13; 
Broadcasters: 2; 
Wireless device manufacturers: 5; 
Wireless service providers: 6; 
Others: 0; 
Total: 26. 

Level of agreement: Somewhat agree; 
Experts: 3; 
Broadcasters: 1; 
Wireless device manufacturers: 1; 
Wireless service providers: 4; 
Others: 1; 
Total: 10. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Broadcasters: 5; 
Wireless device manufacturers: 2; 
Wireless service providers: 2; 
Others: 2; 
Total: 12. 

Level of agreement: Somewhat disagree; 
Experts: 1; 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 1; 
Total: 5. 

Level of agreement: Strongly disagree; 
Experts: 0; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 6; 
Others: 1; 
Total: 8. 

Level of agreement: Total; 
Experts: 18; 
Broadcasters: 9; 
Wireless device manufacturers: 9; 
Wireless service providers: 20; 
Others: 5; 
Total: 61. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (somewhat 
disagree); 
Comment excerpts: The past has proven that auctioning the spectrum for 
public/private use is not workable. If the FCC intends to pursue this 
type of mixed use it needs to adopt rules to incentivize not 
discourage bidding and such mixed use. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Long overdue is the approach to make a commercial 
system that can serve emergency needs but that is viable in normal 
times. The FCC should set a low auction minimum for this service since 
it is more risky for the commercial operator but the public safety 
requirement is crucial. 

Type of commenter (level of agreement): Expert (somewhat disagree); 
Comment excerpts: Congress has not adequately addressed public safety 
for the past 10 years. FCC is trying to solve on its own, and it does 
not have either the authority or the resources adequately to do so. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: The original premise of the D-Block for the 2008 
auction was sound. The lack of definition in the interaction with 
public safety entities created uncertainty and thus made the auction 
not viable. Define the rules and interactions explicitly and this can 
work. 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: This 10 Megahertz and the public safety aspect are 
well informed and have the potential to support the public interest. 
Watch out for the "Motorola-ization" of this band where hardware 
providers manipulate the 3,000 local government entities into spending 
way too much on hardware. This stuff should be available at BestBuy, 
not from Motorola, Johnson, or whoever. That will happen if the usage 
is liberalized and low power (femtocell class) devices are allowed 
(e.g., per police car and fire truck) as well as by homeowners. First 
responders should have a code that allows them to use the bandwidth, 
basically unnoticed by home owners, of the Internet access points when 
there is a police, fire, or rescue operation within radio distance of 
the home. This could be done securely. 

Type of commenter (level of agreement): Infrastructure provider 
(neither agree nor disagree); 
Comment excerpts: The FCC doesn't control this--Congress does and 
Congress needs to decide what to do: whether to combine with public 
safety spectrum. 

Type of commenter (level of agreement): Public interest group 
(strongly disagree); 
Comment excerpts: A single-use national public safety network will 
simply not work. It is impossible to build a network to the level of 
robustness required for anything less than a half-trillion dollars. 
Thus, this entire endeavor is destined for failure and should be 
ceased before we spend additional public funding for something that 
will simply not work. We should concentrate instead on building mixed-
use communications infrastructure with a public safety priority during 
declared emergencies. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly disagree); 
Comment excerpts: Give this to public safety at local county level and 
let them put it to use in their own way and their cost and structure. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat agree); 
Comment excerpts: While we believe that the presence of additional 
commercial competitors in the 700MHz spectrum would help to break the 
stranglehold AT&T and Verizon currently have over device and equipment 
development in that spectrum, an auction of the D-block without an 
assurance of interoperability would do little to benefit the public 
interest. Device interoperability is necessary to bring the benefits 
of scale to the 700 MHz market: reducing the costs of consumer and 
public safety devices, as well as enabling roaming across networks by 
both consumers and public safety. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: The right thing to do, but a lost cause. 
Reallocation to public safety is more likely at this point. Our 
concerns assuming reallocation then go to interoperability and fair 
commercial opportunity to be part of partnerships and solutions --
rather than see the D Block go by default to partnerships with the 
Twin Bells. 

Type of commenter (level of agreement): Wireless service provider 
(strongly disagree); 
Comment excerpts: Public safety needs 20 MHz to deploy an efficient 
LTE network. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

* In May 2010, FCC issued the results of its analysis indicating that 
a stand-alone public safety network would be substantially more 
expensive than a network constructed under an incentive-based 
partnership approach, under which public safety network operators 
would partner with commercial operators or systems integrators to 
construct and operate the network using the 10 MHz of dedicated 
spectrum currently allocated to public safety. 

* In June 2010, FCC issued a paper concluding that the 10 MHz of 
dedicated spectrum currently allocated to public safety will provide 
the capacity and performance necessary for day-to-day communications 
and serious emergency situations; that dedicating the 10 MHz Upper 700 
MHz D Block for public safety, or even 30 MHz, may not be sufficient 
to support public safety broadband communications in a major 
emergency; and that instead public safety should be given priority 
access and roaming capability across the commercial broadband wireless 
spectrum. FCC said that such access will make at least 50 or 60 MHz of 
additional spectrum immediately available. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 2; 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 0; 
Total: 3. 

Level of satisfaction: Somewhat satisfied; 
Experts: 2; 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 1; 
Others: 0; 
Total: 5. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 5; 
Broadcasters: 2; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 1; 
Total: 9. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 4; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 0; 
Total: 7. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 3; 
Broadcasters: 1; 
Wireless device manufacturers: 1; 
Wireless service providers: 4; 
Others: 0; 
Total: 9. 

Level of satisfaction: Total; 
Experts: 16; 
Broadcasters: 3; 
Wireless device manufacturers: 6; 
Wireless service providers: 9; 
Others: 1; 
Total: 33. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (somewhat 
dissatisfied); 
Comment excerpts: The FCC is concluding that the peak use of public 
safety operations may be many orders of magnitude greater than normal 
use. This conclusion indicates that allocations should be commensurate 
with normal use and policy should address access for peak use. 

Type of commenter (level of satisfaction): Expert (strongly 
dissatisfied); 
Comment excerpts: This approach is excellent but practical 
implementation will take much planning, negotiation, and governmental 
vision. little of this has yet to be done. 

Type of commenter (level of satisfaction): Broadcaster (neither 
satisfied nor dissatisfied); 
Comment excerpts: A stand-alone public safety network will be much 
more expensive initially and over the life of the system. It will also 
be prone to technical deficiencies as technology evolves. A priority 
access approach makes much more sense. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (somewhat satisfied); 
Comment excerpts: The debate in Congress on whether the spectrum 
should be auction or reallocated has create[d] uncertainty in the FCC 
to take action on this band. 

Type of commenter (level of satisfaction): Wireless service provider 
(strongly dissatisfied); 
Comment excerpts: FCC was correct; but 5.8.2 is dead. FCC missed 
opportunity to start rulemaking proceedings a year ago for D Block 
auction. FCC has been marginalized and is no longer a player on this 
issue. So 5.8.2 is no longer relevant. 

Type of commenter (level of satisfaction): Wireless service provider 
(strongly dissatisfied); 
Comment excerpts: The FCC has completely failed to follow its own 
National Broadband Plan and federal statute to commercially auction 
this vital block of spectrum. 

Source: GAO survey. 

[End of table] 

National Broadband Plan Recommendations Aimed at Expanding Incentives 
and Mechanisms to Reallocate Spectrum: 

Grant FCC Authority to Conduct Incentive Auctions: 

Recommendation: 

Congress should consider expressly expanding FCC's authority to enable 
it to conduct incentive auctions in which incumbent licensees may 
relinquish rights in spectrum assignments to other parties or to FCC. 

Rationale: 

To motivate existing spectrum licensees to voluntarily give up their 
licenses so that FCC could more quickly reallocate the spectrum to 
higher valued services. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 15; 
Broadcasters: 0; 
Wireless device manufacturers: 7; 
Wireless service providers: 13; 
Others: 4; 
Total: 39. 

Level of agreement: Somewhat agree; 
Experts: 3; 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 4; 
Others: 2; 
Total: 10. 

Level of agreement: Neither agree nor disagree; 
Experts: 0; 
Broadcasters: 5; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 1; 
Total: 7. 

Level of agreement: Somewhat disagree; 
Experts: 0; 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 0; 
Others: 1; 
Total: 1. 

Level of agreement: Strongly disagree; 
Experts: 1; 
Broadcasters: 5; 
Wireless device manufacturers: 1; 
Wireless service providers: 4; 
Others: 1; 
Total: 12. 

Level of agreement: Total; 
Experts: 19; 
Broadcasters: 11; 
Wireless device manufacturers: 9; 
Wireless service providers: 21; 
Others: 9; 
Total: 69. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Incentive auctions will give the FCC the ability to 
repurpose spectrum from inefficient service-specific allocations to 
more flexible allocations in an efficient manner. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Congress should simply grant the FCC the ability to 
pay some of the revenues to broadcasters instead of the Treasury and 
avoid legislating any details of the auction. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: Receipts from government auctions should go to the 
government. The FCC is not an consignment auction house auctioning the 
assets of third parties like Christies or Southebys. 

Type of commenter (level of agreement): Broadcaster (neither agree nor 
disagree); 
Comment excerpts: Voluntary auctions may be acceptable so long as 
resulting repacking costs of remaining users are guaranteed. 

Type of commenter (level of agreement): Broadcaster (neither agree nor 
disagree); 
Comment excerpts: If Congress authorizes incentive auctions, it should 
make clear that the Commission must not take any actions in its 
implementation that could harm existing licensees (e.g., involuntary 
repacking into VHF band, loss of coverage areas and/or increased 
interference). 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: The FCC should allow licensees to sell or lease to 
mobile operators directly and immediately. 

Type of commenter (level of agreement): Infrastructure provider 
(strongly agree); 
Comment excerpts: A voluntary incentive auction is a market-based 
mechanism that will allow spectrum to be transitioned from one use to 
a new use, and should take years off the current process. 

Type of commenter (level of agreement): Public interest group 
(strongly disagree); 
Comment excerpts: ... Incentive auctions will dramatically increase 
spectrum hoarding and make further band clearing far more difficult. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly disagree); 
Comment excerpts: (FCC) should force and recover spectrum from those 
who have not used what they have before going after spectrum used by 
broadcasters and recent (television) white spaces rulings. (This 
would) actually (take) away from new innovative spectrum use. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: The primary reason spectrum identification and 
reallocation takes so long is political pressure from incumbents. 
Incentive auctions would reduce this pressure and allow the government 
to move more quickly. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat agree); 
Comment excerpts: OK to have as another tool in the spectrum 
management toolbox, but very uncertain how effective it will be in 
bringing commercially valuable amounts of spectrum to market to 
support wireless broadband. 

Source: GAO survey. 

[End of table] 

Grant FCC Authority to Impose Fees on Licensees: 

Recommendation: 

Congress should consider granting authority to the FCC to impose 
spectrum fees on license holders.[Footnote 68] 

Rationale: 

Fees may help to free spectrum for new uses with potentially higher 
value than current uses, since licensees who use spectrum 
inefficiently may reduce their holdings once they bear the opportunity 
cost of spectrum. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 12; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 3; 
Total: 18. 

Level of agreement: Somewhat agree; 
Experts: 3; 
Broadcasters: 0; 
Wireless device manufacturers: 3; 
Wireless service providers: 4; 
Others: 1; 
Total: 11. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 1; 
Others: 3; 
Total: 7. 

Level of agreement: Somewhat disagree; 
Experts: 3; 
Broadcasters: 2; 
Wireless device manufacturers: 0; 
Wireless service providers: 4; 
Others: 2; 
Total: 11. 

Level of agreement: Strongly disagree; 
Experts: 1; 
Broadcasters: 11; 
Wireless device manufacturers: 3; 
Wireless service providers: 9; 
Others: 0; 
Total: 24. 

Level of agreement: Total; 
Experts: 20; 
Broadcasters: 13; 
Wireless device manufacturers: 9; 
Wireless service providers: 20; 
Others: 9; 
Total: 71. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: The value of spectrum is far greater, in most cases, 
than is recovered in auctions. Spectrum fees can be based on the 
appreciating value of spectrum. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Spectrum fees are a critical market-based mechanism 
used in the UK to ensure that government spectrum is used efficiently 
or repurposed for commercial use. US should do the same. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Without the ability to impact the bottom line, the 
FCC is less effective than otherwise. However if the incumbents write 
the legislation as is the current practice, it will come out that the 
FCC will have the power to fine the little guys and the big guys will 
have many loopholes and time wasters. If, however, the FCC were to 
work with the NTIA, DOD, and DHS regarding criteria for imposing fees 
so that the FCC could shape the behavior of the huge incumbents in a 
meaningful way without accidentally or unfairly penalizing the smaller 
entrepreneurs, then the public interest would be served. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: It is ridiculous to give some spectrum away and 
charge for others. It is equally ridiculous to have a one time payment 
that provides rights into perpetuity. 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: Only if the FCC cannot grant flexible rights whereby 
the licensees realizes the opportunity cost of the spectrum it uses 
... or the licensee is in a shared band, then fees are one tool to 
provide more accurate price signals about the cost of using the 
spectrum. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: Spectrum fees on private parties do not create 
incentives for efficiency. At best (worst?) a fee that makes a 
particular license unprofitable will result in the license going back 
to the government--that does not create value, but reduces output. The 
way to create value is to allow competitive forces wider scope, 
permitting the licensee to deploy any service, technology, or business 
model that may be profitable. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: Payment is already made in the context of required 
public interest responsibilities of broadcasters. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: Broadcasters already pay for their spectrum in the 
form of public interest obligations that exceed those for any other 
privately-held spectrum. Congress should recognize the public value of 
these obligations and the cost to broadcasters of complying with them. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: Broadcasters already pay enormous "regulatory fees" 
and absorb regulatory costs not imposed on others. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: The FCC already collects annual regulatory fees. 
Moreover, there is no elaboration of how such fees would be assessed 
or for what purpose such collected fees would be used. Further any use 
of spectrum fees to encourage licensees to give up their spectrum for 
other purposes disserves the public interest. 

Type of commenter (level of agreement): Broadcaster (somewhat 
disagree); 
Comment excerpts: We disagree in terms of applying fees to spectrum 
holders that are actively using their spectrum for the intended 
purpose. These fees should *only* be applied to license holders that 
are squatting or allowing their spectrum to sit unused. 

Type of commenter (level of agreement): Public interest group 
(strongly agree); 
Comment excerpts: Yearly spectrum fees will increase spectrum 
utilization and incent license holders who do not use their bands to 
return them. Furthermore, over time, yearly license fees raise far 
more money for the public treasury than one-off auctions and are thus 
a superior and more fiscally responsible choice. 

Type of commenter (level of agreement): Mobile Satellite Services 
company (strongly agree); 
Comment excerpts: Spectrum fees are preferable to auctions or any 
other regulatory method for ensuring that spectrum is used reasonably 
efficiently. There never would have been auctions if the broadcast 
industry was not unalterably opposed to spectrum fees in the 1980s. 

Type of commenter (level of agreement): Satellite radio service 
provider (somewhat agree); 
Comment excerpts: Spectrum fees should be tied to how a licensee 
acquired its spectrum. Licensees that paid fair market price through 
an auction should pay less in usage fees than those licensees in bands 
that initially acquired licenses through means other than auctions. 

Type of commenter (level of agreement): Infrastructure provider 
(neither agree nor disagree); 
Comment excerpts: No clear economic evidence that fees leads to more 
efficiency. So if the goals is improved spectrum policy, this would 
fail to support the goal. 

Type of commenter (level of agreement): Wireless device manufacturer 
(somewhat agree); 
Comment excerpts: However, such fees should not be imposed on 
licensees that obtained their spectrum license through competitive 
bidding mechanisms. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: This assumes these fees are for either non-auctioned 
spectrum and/or spectrum that is not licensed for flexible use. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat disagree); 
Comment excerpts: If already paid for spectrum in an auction, then no. 
Ultimately increases prices to consumers. 

Source: GAO survey. 

[End of table] 

Address Barriers to Secondary Markets: 

Recommendation: 

FCC should evaluate the effectiveness of its secondary markets 
policies and rules to promote access to unused and underutilized 
spectrum. 

Rationale: 

FCC believes that the performance of secondary markets under the 
Commission's current policies has been mixed and is concerned that 
unused or underutilized spectrum is possibly not be being made 
available to smaller providers, especially in rural areas where 
spectrum goes unused. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 15; 
Broadcasters: 5; 
Wireless device manufacturers: 6; 
Wireless service providers: 10; 
Others: 3; 
Total: 39. 

Level of agreement: Somewhat agree; 
Experts: 3; 
Broadcasters: 4; 
Wireless device manufacturers: 3; 
Wireless service providers: 5; 
Others: 5; 
Total: 20. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Broadcasters: 2; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 1; 
Total: 5. 

Level of agreement: Somewhat disagree; 
Experts: 0; 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 3; 
Others: 0; 
Total: 3. 

Level of agreement: Strongly disagree; 
Experts: 1; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 0; 
Total: 3. 

Level of agreement: Total; 
Experts: 20; 
Broadcasters: 11; 
Wireless device manufacturers: 10; 
Wireless service providers: 20; 
Others: 9; 
Total: 70. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (strongly agree); 
Comment excerpts: The FCC should update and revise its secondary 
markets policy to include all spectrum to allow all current licensees 
to participate in a secondary market so long as their primary spectrum 
uses remain intact. This will allow market forces to determine the 
best use for spectrum without requiring wholesale reallocation of 
designated bands for other purposes. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: A reasonable suggestion that obviates the need for 
incentive auctions. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: FCC has been doing a good job, but should consider a 
legislation to form a private public interest company or FFRDC to 
create the secondary spectrum databases and to assist and support 
spectrum use. The German Fraunhofer model requires 1/3 industry 
funding, and that is a good model for responsiveness to industry (vs. 
the US FFRDC model which has little such incentives). 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: Secondary markets, as conceived by regulators, 
involve the sale of 'naked licenses.' In fact, those markets are robust 
--over 50,000 CMRS licenses have been aggregated into a small number 
of national and regional cellular networks --all through secondary 
transactions. But the far more active trading of spectrum rights is 
done not by buying/selling stand-alone spectrum, but "wireless 
services." The bundle--spectrum + mobile network access--is sold in 
wholesale and retail markets. That is the efficient way to package the 
product, and (because the buyers and sellers internalize transaction 
costs) that is the way the market organizes the use of spectrum. 
Trying to get owners of liberally licensed spectrum to sell their 
"excess" in a naked bandwidth trade is like trying to induce 
homeowners to rent out spare bedrooms. Yes, homes are not at fully 
occupied, and many rooms are rented out. But by and large, families 
prefer not to do so, forgoing the opportunity available. Wireless 
carriers often "sell" access, as to retail customers, MVNOs, or other 
networks (roaming agreements), and they frequently buy/sell licenses. 
But once they construct a network to use particular airwaves, they 
find it inefficient to split off spectrum rights and lease them to 
other networks. This reflects efficiency; the premise of the "do more 
for secondary markets" policy is that such markets are failing. But 
they are not; they work in a matter that is often misunderstood. 

Type of commenter (level of agreement): Infrastructure provider 
(somewhat agree); 
Comment excerpts: The FCC's policies here are good, and are being 
used, but further evaluation is helpful. 

Type of commenter (level of agreement): Public interest group (neither 
agree nor disagree); 
Comment excerpts: [FCC] needs to avoid creating transaction costs that 
undermine the utility of secondary markets. 

Type of commenter (level of agreement): Mobile Satellite Services 
company (strongly agree); 
Comment excerpts: All secondary market tools -spectrum leasing, 
partitioning, disaggregating, etc., should be available to all 
licensed wireless services, including satellite. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: ... I ... suggest mandatory spectrum leasing of 
spectrum that has not been built out for 5 years. Cognitive Radio 
could put this to use and return it to incumbents if they ever decide 
to build out... 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: FCC should . .expand the applicability of secondary 
markets policies to all spectrum-based services and bands. While it 
has proposed this for certain mobile satellite bands, FCC (and NTIA) 
should also apply the same leasing policies and procedures (including 
the notion of "private commons") to the broadcasting, other satellite 
and Federal bands. It should also lift restrictions on shared channels 
in the private land mobile radio. . bands below 512 MHz in connection 
with the 10-channel limitation and leasing restrictions. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat agree); 
Comment excerpts: It is not secondary markets policies that are the 
problem. They work well with carriers that want to make spectrum 
available. Problem is warehousing by carriers attempting to keep 
spectrum from competitors. Not a secondary markets problem, but an FCC 
enforcement problem. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat agree); 
Comment excerpts: While in general there are mechanisms that 
facilitate secondary market transactions, the FCC should create 
greater incentives for license holders that are not using their 
spectrum to sell/lease it to entities that will. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

FCC officials told us that the Commission conducted an internal review 
of its secondary markets policies that concluded that it should do 
more to promote secondary markets. Toward that end, in November 2010, 
FCC issued a Notice of Inquiry on dynamic spectrum access technologies 
that have the potential to enable sharing of spectrum in common 
locations, including how such technologies could facilitate secondary 
markets. In January 2011 FCC officials told us that the Commission was 
assessing the input it received in response to that inquiry, and that 
it intended to issue a related order, tentatively by the end of 
calendar year 2011. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 2; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 0; 
Total: 3. 

Level of satisfaction: Somewhat satisfied; 
Experts: 5; 
Broadcasters: 0; 
Wireless device manufacturers: 3; 
Wireless service providers: 3; 
Others: 2; 
Total: 13. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 3; 
Broadcasters: 5; 
Wireless device manufacturers: 2; 
Wireless service providers: 4; 
Others: 6; 
Total: 20. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 5; 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 7; 
Others: 0; 
Total: 13. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 0; 
Broadcasters: 3; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 0; 
Total: 5. 

Level of satisfaction: Total; 
Experts: 15; 
Broadcasters: 8; 
Wireless device manufacturers: 8; 
Wireless service providers: 15; 
Others: 8; 
Total: 54. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (somewhat satisfied); 
Comment excerpts: This effort needs a definition of what DSA must meet 
as potential for interference. Without a definition of "harmful", it 
will be hard to deploy any DSA. 

Type of commenter (level of satisfaction): Expert (neither satisfied 
nor dissatisfied); 
Comment excerpts: No evidence that dynamic spectrum access 
technologies would promote secondary markets. On the other hand, 
removing any barriers that arbitrarily block dynamic access 
technologies would be good even if it had no effect on secondary 
markets. 

Type of commenter (level of satisfaction): Expert (somewhat 
dissatisfied); 
Comment excerpts: FCC's slowness in Docket 04-186 shows its 
ambivalence in this area. This is a very technical area and FCC as 
presently structured doesn't deal well with such issues. 

Type of commenter (level of satisfaction): Broadcaster (strongly 
dissatisfied); 
Comment excerpts: [FCC's] analysis must include broadcast spectrum to 
be credible and effective. 

Type of commenter (level of satisfaction): Infrastructure provider 
(neither satisfied nor dissatisfied); 
Comment excerpts: Dynamic spectrum access is [in its] very early days 
and will probably not be important for years. 

Type of commenter (level of satisfaction): Wireless service provider 
(neither satisfied nor dissatisfied); 
Comment excerpts: FCC policies on dynamic sharing may do more harm 
than good. More testing regarding the potential for interference and 
the economic case is necessary before making any decisions. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat dissatisfied); 
Comment excerpts: Dynamic spectrum access is a small subset of 
secondary markets. The FCC can promote secondary markets by reducing 
barriers to these transactions and speeding up the approval process 
for license transfers and leases and by increasing flexible use for 
licensed spectrum allocations. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat dissatisfied); 
Comment excerpts: 
* Revitalize management agreements--The FCC should clarify whether 
"management agreements" or other non-leasing arrangements are still 
permitted and, if so, whether the former Intermountain Microwave 
factors are still applicable or whether other guidelines would apply. 
If not permitted, then the FCC could consider permitting a lower cost 
means for licensees to facilitate build-out with third party managers 
or partners, possibly with notice to the FCC about the relationship; 
* Establish an FCC "warehouse" of unused spectrum--The FCC can 
aggregate its unsold or returned PCS, AWS, 700 MHz and other spectrum 
licenses it still holds and enable parties to petition to serve these 
areas using procedures similar to the existing Section 22.949 process 
for unserved cellular areas (with short-term build-out requirements). 
Or, parties could "lease" this spectrum from the FCC under this 
approach, paying annual lease fees to the government; 
* Facilitate streamlined leasing arrangements through FCC-certified 
brokers--The FCC could incentivize carriers to contribute unused 
spectrum, especially in rural and underserved areas, to the FCC's 
spectrum warehouse or to third party "brokers" that would be certified 
by the FCC to maintain an inventory of spectrum available for lease 
under pre-approved short-form agreements at low cost to all parties 
involved (with streamlined FCC rules). (The FCC could also get some of 
the lease revenue from this approach); 
* Adopt leasing incentives--Incentives to contribute spectrum to a 
certified broker or to lease directly to a third party could include 
avoidance of non-use fees or use-it-or-lose-it rules, or bidding 
credit eligibility or limited exemptions from the FCC's spectrum 
screen for carriers that contribute spectrum to the FCC or to a 
certified broker for possible lease; 
* Develop new tools and agency agreements--The FCC could adopt a new 
"hybrid agency agreement" or service agreement approach, similar to a 
resale agreement, as a new secondary market tool; 
* Develop an FCC spectrum buy-back program--The FCC could use auction 
proceeds or lease revenues (see above) to "buy back" spectrum in 
unserved or underserved areas and then recoup some of the cost of this 
program by selling or leasing this spectrum to rural carriers 
interested in serving these areas; 
* Develop a spectrum "homesteading" or finder's preference program --
The FCC could establish a small rural mobile development office where 
parties interested in serving unserved or underserved areas could go 
to determine what unused spectrum may be available in these markets 
from the FCC or from licensees, and the FCC staff could facilitate 
leasing arrangements through discussions with the existing licensees. 
Enabling entities to build-out and establish "squatter's rights" (with 
a later right to a partitioned/disaggregated license where they are 
serving customers) on unused spectrum in limited identified areas, and 
only if the licensee has not agreed to contribute the spectrum for 
leasing might incentivize greater leasing; 
* Streamline current spectrum leasing rules--The FCC could eliminate 
unnecessary spectrum manager lease filings (arguably no filings should 
be necessary for short-term spectrum manager leases, and only a 
notification filing for long-term spectrum manager leases when they 
begin and end); eliminate lease renewal filings; act on all long-term 
de facto transfer leases within 21 or 15 days, etc. 

Type of commenter (level of satisfaction): Wireless service provider 
(strongly dissatisfied); 
Comment excerpts: It should not take one year to assess the input 
obtained from the Dynamic Spectrum Access NPRM. 

Source: GAO survey. 

[End of table] 

National Broadband Plan Recommendations Aimed at Expanding 
Opportunities for Innovative Spectrum Access Models: 

Provide Spectrum for Unlicensed Use: 

Recommendation: 

FCC, within the next 10 years, should free up a new, contiguous 
nationwide band for unlicensed use. 

Rationale: 

To enable innovators to try new ideas to increase spectrum access and 
efficiency through unlicensed means and to enable new unlicensed 
providers to serve rural and unserved communities. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 8; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 4; 
Wireless service providers: 2; 
Others: 3; 
Total: 18. 

Level of agreement: Somewhat agree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 2; 
Wireless service providers: 5; 
Others: 2; 
Total: 11. 

Level of agreement: Neither agree nor disagree; 
Experts: 3; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 1; 
Total: 10. 

Level of agreement: Somewhat disagree; 
Experts: 2; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 0; 
Wireless service providers: 6; 
Others: 1; 
Total: 12. 

Level of agreement: Strongly disagree; 
Experts: 3; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 2; 
Wireless service providers: 4; 
Others: 0; 
Total: 10. 

Level of agreement: Total; 
Experts: 16; 
Stakeholders: 
Broadcasters: 10; 
Wireless device manufacturers: 9; 
Wireless service providers: 19; 
Others: 7; 
Total: 61. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: No amount of licensed spectrum will ever satisfy the 
future demand for rich wireless media, so the FCC needs to ensure that 
wireless carriers and others have access to enough unlicensed spectrum 
for many more Wi-Fi access points to move wireless traffic onto the 
wired network at the earliest opportunity in the transmission session. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: essential to promoting competition and innovation in 
wireless services. 

Type of commenter (level of agreement): Expert (neither agree nor 
disagree); 
Comment excerpts: ... the success of unlicensed systems depends on 
global coordination and therefore allocations in the US alone will not 
achieve the necessary dividends. 

Type of commenter (level of agreement): Expert (somewhat disagree); 
Comment excerpts: There is an opportunity cost to making unlicensed 
spectrum available and it may not be the most efficient use of spectrum 
--there should be a price tag put on this so that people realize the 
opportunity cast and potential inefficiency of allocating more 
spectrum for unlicensed use. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: Contiguity no longer is needed because of the 
emergence of affordable devices where, say a 2 GHz device can operate 
effectively and affordably between 1.3 and 2.3 GHz (and similarly in 
other bands). Unlicensed chunks in different parts of the spectrum can 
be effectively hybridized via heterogeneous spectrum management, 
promoting market entry of new small to medium product suppliers. FCC 
should assist the market in using [an] on-line database like for 
[television white spaces] so that unlicensed devices can learn about 
available spectrum and use it dynamically versus clearing a new band 
for unlicensed use. A 60 MHz band around 1 GHz in bandwidth for indoor 
use would be a significant contribution to the development of 
unlicensed markets. 

Type of commenter (level of agreement): Broadcaster (somewhat 
disagree); 
Comment excerpts: Strict interference protection standards will be 
crucial in any such initiative. 

Type of commenter (level of agreement): Infrastructure provider 
(strongly agree); 
Comment excerpts: Where spectrum is sorely needed is to support Wi-Fi 
technologies at 5 GHz. An increased footprint of "shared" spectrum is 
required to meet future needs and support next generation Wi-Fi 
technologies. 

Type of commenter (level of agreement): Mobile Satellite Services 
company (somewhat disagree); 
Comment excerpts: There is already plenty of spectrum available for 
unlicensed use. This is a low priority. 

Type of commenter (level of agreement): Wireless device manufacturer 
(somewhat agree); 
Comment excerpts: There is substantial amount of unlicensed spectrum 
that has been recently allotted which remains vacant. After this 
spectrum has systems, more spectrum may need to be made available. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: ... an appropriate amount of unlicensed spectrum 
should be made available that is dedicated exclusively to unlicensed 
outdoor fixed wireless broadband delivery and NOT shared with consumer-
type (i.e., Wi-Fi) devices. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat disagree); 
Comment excerpts: Spectrum is not an unlimited resource. Priority 
should be given to reallocation of available spectrum subject to 
auction under exclusive licensing. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

FCC intends to consider making additional spectrum available for 
unlicensed use in conjunction with NTIA's "Plan and Timetable to Make 
Available 500 Megahertz of Spectrum for Wireless Broadband," which 
addresses both licensed and unlicensed uses. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 0; 
Total: 4. 

Level of satisfaction: Somewhat satisfied; 
Experts: 3; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 2; 
Others: 3; 
Total: 10. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 0; 
Total: 4. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 3; 
Others: 1; 
Total: 6. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 0; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 1; 
Total: 4. 

Level of satisfaction: Total; 
Experts: 8; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 6; 
Wireless service providers: 7; 
Others: 5; 
Total: 28. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (somewhat 
dissatisfied); 
Comment excerpts: Too slow. 

Type of commenter (level of satisfaction): Infrastructure provider 
(somewhat dissatisfied); 
Comment excerpts: The FCC's focus has been white spaces, which 
provides 6 MHz channels and will never be a global footprint (other 
countries have different channelization for TV). The FCC has not 
proposed, for example, opening up more spectrum at 5 GHz for shared 
use. 

Type of commenter (level of satisfaction): Public interest group 
(strongly dissatisfied); 
Comment excerpts: There has been no meaningful progress on this 
recommendation. Currently, unlicensed is an afterthought in both 
planning the by FCC and the Obama administration ... Given the success 
of unlicensed in dramatically increasing the public's access to the 
public airwaves, it should be the priority; spectrum auctions to 
corporations rich enough to buy exclusive use to the public airwaves 
should be secondary. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat dissatisfied); 
Comment excerpts: We believe that creating a new nationwide unlicensed 
band will result in very substantial economic benefits for the nation 
as a whole. For this reason, we support rapid action FCC to create 
this band. 10 years is too long to wait. We would like to see this 
band created within the next 2 to 3 years. 

Source: GAO survey. 

[End of table] 

Issue Rules on Television White Spaces: 

Recommendation: 

FCC should move expeditiously to conclude the television white spaces 
proceeding. 

Rationale: 

To accelerate the introduction of new innovative products and services 
that would use the television white spaces. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 8; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 5; 
Wireless service providers: 6; 
Others: 4; 
Total: 23. 

Level of agreement: Somewhat agree; 
Experts: 3; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 2; 
Wireless service providers: 5; 
Others: 0; 
Total: 11. 

Level of agreement: Neither agree nor disagree; 
Experts: 2; 
Stakeholders: 
Broadcasters: 4; 
Wireless device manufacturers: 1; 
Wireless service providers: 3; 
Others: 3; 
Total: 13. 

Level of agreement: Somewhat disagree; 
Experts: 2; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 0; 
Total: 8. 

Level of agreement: Strongly disagree; 
Experts: 3; 
Stakeholders: 
Broadcasters: 4; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 0; 
Total: 10. 

Level of agreement: Total; 
Experts: 18; 
Stakeholders: 
Broadcasters: 12; 
Wireless device manufacturers: 10; 
Wireless service providers: 18; 
Others: 7; 
Total: 65. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: The database aspect is inviting abuses, many 
unintentional. When people measure spectrum use, patterns appear, some 
of which compromise law enforcement, privacy, etc. Thus, the 
[database] should not be public but should be administered by a public 
trust corporation with security clearances that will redact 
information that compromises the public interest such as law 
enforcement, personal privacy, etc. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: TV white spaces proceeding moves in the wrong 
direction; more efficient to reorganize spectrum in each market and 
auction off unlicensed spectrum rather than white spaces. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: The conclusion of the white spaces could impact 
other spectrum decisions, including the incentive auctions and 
repacking and it can be very hard to undo unlicensed uses. 

Type of commenter (level of agreement): Broadcaster (neither agree nor 
disagree); 
Comment excerpts: The FCC must have adequate rules for the database 
administrators to ensure accuracy and avoid unnecessary interference. 

Type of commenter (level of agreement): Broadcaster (somewhat 
disagree); 
Comment excerpts: The FCC should move only as expeditiously as it can 
based on sound engineering and spectrum principles. The FCC must 
ensure its rules for white space use fully protect incumbent users and 
do not cause interference to viewers. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat disagree); 
Comment excerpts: The FCC needs to ensure that actions it takes do not 
create potential future issues with additional TV spectrum identified 
for reallocation to mobile broadband use. 

Type of commenter (level of agreement): Wireless service provider 
(strongly disagree); 
Comment excerpts: ... Too much interference risk ... [FCC] should 
allow this good propagation spectrum to be used for broadband backhaul. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

* In September 2010, FCC issued an opinion and order that: (1) 
eliminates the requirement that television bands devices that 
incorporate geo-location and database access must also include sensing 
technology to detect the signals of television stations and low-power 
auxiliary service stations (wireless microphones); (2) requires 
wireless microphone users who seek to register in the television bands 
databases to certify that they will use all available channels from 7 
through 51 prior to requesting registration; and (3) reserves two 
vacant UHF channels for wireless microphones and other low power 
auxiliary service devices in all areas of the country while 
maintaining a reasonable separation distance between television white 
space devices and wireless microphone usage. 

* In January 2011, FCC conditionally designated nine companies to 
develop and administer the databases that new unlicensed wireless 
devices would use to identify available channels. 

* FCC conducted three workshops with the database administrators, one 
each in March, April, and May 2011. The workshops covered development, 
security, and testing of the databases. FCC plans to hold additional 
workshops towards final approval of the database administrators. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 0; 
Others: 0; 
Total: 4. 

Level of satisfaction: Somewhat satisfied; 
Experts: 5; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 3; 
Wireless service providers: 2; 
Others: 2; 
Total: 13. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 6; 
Others: 1; 
Total: 9. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 0; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 3; 
Others: 0; 
Total: 5. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 0; 
Others: 1; 
Total: 3. 

Level of satisfaction: Total; 
Experts: 11; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 7; 
Wireless service providers: 11; 
Others: 4; 
Total: 34. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Public interest group 
(somewhat satisfied); 
Comment excerpts: The process has taken longer than it could have, I 
believe. 

Type of commenter (level of satisfaction): Public interest group 
(strongly dissatisfied); 
Comment excerpts: The FCC's current plan is to kill off the utility of 
TV white space technologies ... by auctioning off these bands to the 
highest bidder [via incentive auctions]. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (very satisfied); 
Comment excerpts: This is perhaps the only segment in wireless we are 
actually leading the world. More resource should be applied to this 
endeavor to make improvements. Next Gen Wi Fi. . . 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (somewhat satisfied); 
Comment excerpts: The removal of the sensing requirement is somewhat 
troubling because it was deemed essential in the sharing of spectrum. 
As the FCC continues to support sharing in other bands, it is 
troubling, that the FCC may define sharing based on technology that is 
unsuitable or unavailable commercially. 

Source: GAO survey. 

[End of table] 

Spur Opportunistic Uses of Spectrum: 

Recommendation: 

FCC should spur further development and deployment of opportunistic 
uses across more radio spectrum. 

Rationale: 

To significantly increase the efficiency of spectrum utilization by 
enabling radios to access and share available spectrum dynamically. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 11; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 5; 
Wireless service providers: 4; 
Others: 2; 
Total: 24. 

Level of agreement: Somewhat agree; 
Experts: 3; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 2; 
Wireless service providers: 6; 
Others: 3; 
Total: 17. 

Level of agreement: Neither agree nor disagree; 
Experts: 2; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 2; 
Wireless service providers: 4; 
Others: 0; 
Total: 11. 

Level of agreement: Somewhat disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 3; 
Others: 2; 
Total: 7. 

Level of agreement: Strongly disagree; 
Experts: 2; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 1; 
Wireless service providers: 3; 
Others: 0; 
Total: 7. 

Level of agreement: Total; 
Experts: 19; 
Stakeholders: 
Broadcasters: 10; 
Wireless device manufacturers: 10; 
Wireless service providers: 20; 
Others: 7; 
Total: 66. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: The FCC must protect the integrity of existing 
services while encouraging innovation. The FCC should free incumbent 
licensees from technical restrictions that hinder such innovation. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: But opportunistic uses should be prioritized based 
upon intelligent technical analysis, i.e., a spectrum technology road 
map. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: This is precisely the sort of thing that regulators 
should not do. They should focus on something distinct: creating rules 
that yield optimal incentives for competitive processes to create 
efficient solutions. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: I do not believe that mass market technology and the 
demands of the commercial marketplace will allow for these techniques 
within the next decade. 

Type of commenter (level of agreement): Expert (somewhat disagree); 
Comment excerpts: [In implementing this recommendation], FCC should 
adopt policies that facilitate agreements among private parties. 

Type of commenter (level of agreement): Mobile Satellite Services 
company (somewhat disagree); 
Comment excerpts: If the FCC does this, there will be more 
interference complaints. The FCC has to commit to devote resources to 
investigating and resolving interference complaints quickly. 

Type of commenter (level of agreement): Wireless device manufacturer 
(somewhat agree); 
Comment excerpts: Cognitive radio is promising; however generally 
speaking the technology needs further development before appropriate 
for many bands; in any event, should be commercially driven not as a 
regulatory mandate. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: It is great that the ... NBP recognized that 
"opportunistic sharing arrangements offer great potential to meet 
increasing market demand for wireless services by promoting more 
efficient use of radio spectrum." [This recommendation] is absolutely 
correct in stating that "'opportunistic'" or 'cognitive' technologies 
can significantly increase the efficiency of spectrum utilization by 
enabling radios to access and share available spectrum dynamically." 
However, this recommendation over-emphasized the unproven and 
inefficient database approach to advanced sharing and disregarded 
spectrum sensing (detect-and-avoid) and hybrid sensing/geolocation 
approaches. The FCC's preference for geolocation approaches is 
apparently based on its lack of information regarding spectrum 
sensing, its decision in the TV White Spaces proceeding to eliminate 
the sensing requirement and recent enforcement issues (unrelated to 
sensing capabilities) in the 5 GHz U-UNII band in which sensing is 
required to share with radar operations. Hopefully, the record 
developed in the FCC's DSA NOI proceeding (ET Docket No. 10-237) and 
NTIA's spectrum sharing test bed should provide additional information 
on sensing. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat agree); 
Comment excerpts: We support ... dynamic spectrum access ... shared 
and secondary market access to spectrum capacity but would strongly 
oppose FCC adoption of rules or policies which diminish the rights of 
the licensees of exclusive spectrum purchased at auction to control 
and/or to exclude access to their spectrum. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

In November 2010, FCC issued a Notice of Inquiry seeking comment on 
how dynamic spectrum access radios and techniques can promote more 
intensive and efficient use of the radio spectrum. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 1; 
Total: 3. 

Level of satisfaction: Somewhat satisfied; 
Experts: 5; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 2; 
Wireless service providers: 1; 
Others: 1; 
Total: 10. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 3; 
Stakeholders: 
Broadcasters: 4; 
Wireless device manufacturers: 2; 
Wireless service providers: 7; 
Others: 1; 
Total: 17. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 1; 
Total: 3. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 1; 
Total: 5. 

Level of satisfaction: Total; 
Experts: 12; 
Stakeholders: 
Broadcasters: 5; 
Wireless device manufacturers: 7; 
Wireless service providers: 9; 
Others: 5; 
Total: 38. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Private user group 
(somewhat satisfied); 
Comment excerpts: This direction holds some promise as long as the 
inherent limitations of dynamic spectrum access techniques are taken 
into account and are not relied upon inappropriately. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (strongly dissatisfied); 
Comment excerpts: DSA has a place in providing communications 
solutions however there is a concern that the FCC is unaware of the 
state of technology and how it operates to provide solutions. So 
mandating solutions may delay the usage of the bands considered for 
DSA. 

Type of commenter (level of satisfaction): Wireless service provider 
(strongly dissatisfied); 
Comment excerpts: Additional study is needed as dynamic spectrum 
access radios technologies have not been proven yet. 

Source: GAO survey. 

[End of table] 

Enhance Research and Development on Spectrum Access: 

Recommendation: 

FCC should initiate proceedings to enhance research and development 
that will advance the science of spectrum access. 

Rationale: 

A robust research and development pipeline is essential to ensuring 
that spectrum access technologies continue to evolve and improve. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 11; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 7; 
Wireless service providers: 5; 
Others: 4; 
Total: 29. 

Level of agreement: Somewhat agree; 
Experts: 5; 
Stakeholders: 
Broadcasters: 4; 
Wireless device manufacturers: 2; 
Wireless service providers: 7; 
Others: 1; 
Total: 19. 

Level of agreement: Neither agree nor disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 0; 
Wireless service providers: 3; 
Others: 1; 
Total: 7. 

Level of agreement: Somewhat disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 1; 
Total: 4. 

Level of agreement: Strongly disagree; 
Experts: 2; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 1; 
Total: 7. 

Level of agreement: Total; 
Experts: 18; 
Stakeholders: 
Broadcasters: 11; 
Wireless device manufacturers: 10; 
Wireless service providers: 19; 
Others: 8; 
Total: 66. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (somewhat agree); 
Comment excerpts: While it is good to stimulate research and 
development, the FCC should not assume that government should direct 
the effort. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: There is no need for government efforts to "enhance" 
R&D in this area. Substantial efforts already in place. 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: Not clear what role there is that isn't already met 
by private sector; eliminating barriers would be good. 

Type of commenter (level of agreement): Mobile Satellite Services 
company (strongly disagree); 
Comment excerpts: Spectrum shortages have provided enough incentive 
for licensees to spend their funds on research and development of ways 
to use spectrum more intensively. The government does not have to be 
involved in this. It will only stifle development. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat disagree); 
Comment excerpts: If guidelines were in place that assured a 
competitive marketplace among wireless carriers of various sizes and 
new entrants, then competitive carriers and new entrants would 
accomplish this innovation in the marketplace. Such grant-funded 
innovation becomes necessary when there is a lack of competition 
within the market. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: The FCC should leverage work that is currently being 
done both in private industry ... or by academic institutions ... 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

In November 2010, FCC issued an NPRM that seeks to expand the 
Commission's existing Experimental Radio Service rules to promote 
cutting-edge research and foster development of new wireless 
technologies, devices, and applications. Specifically, FCC proposed a 
new type of license, called a "program license," which would give 
qualified entities broad authority to conduct research without the 
need to seek new approval for each individual experiment. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 1; 
Others: 1; 
Total: 6. 

Level of satisfaction: Somewhat satisfied; 
Experts: 8; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 2; 
Wireless service providers: 4; 
Others: 1; 
Total: 16. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 3; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 3; 
Wireless service providers: 3; 
Others: 0; 
Total: 12. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 1; 
Total: 5. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 0; 
Others: 1; 
Total: 2. 

Level of satisfaction: Total; 
Experts: 15; 
Stakeholders: 
Broadcasters: 4; 
Wireless device manufacturers: 8; 
Wireless service providers: 10; 
Others: 4; 
Total: 41. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Expert (strongly 
dissatisfied); 
Comment excerpts: This NPRM is mostly PR. In reality big firms ... 
already have the equivalent of a "program license.". 

Type of commenter (level of satisfaction): Private user group 
(somewhat dissatisfied); 
Comment excerpts: The existing Experimental Radio Service rules do not 
bar progress but should be strengthened to ensure that licensees are 
aware of experimental operations that may cause harmful interference 
to them. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (neither satisfied nor dissatisfied); 
Comment excerpts: A lot of questions remain, including the scope of 
eligible entities --the private sector should not be excluded. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat dissatisfied); 
Comment excerpts: The FCC proposed to exclude non-public entities 
under blanket licenses. For the type of experimental license available 
to commercial entities, it was stated the licenses are not intended 
for commercial campuses. No explanation for either of these arbitrary 
exclusions were provided in the NPRM. Further, the FCC proposes to 
shift the burden of discovering potential interference to the existing 
licensee, which will discourage experimental use. 

Source: GAO survey. 

[End of table] 

National Broadband Plan Recommendations Aimed at Enhancing FCC's 
Spectrum Policymaking: 

Measure Spectrum Utilization: 

Recommendation: 

FCC and NTIA should create methods for ongoing measurement of spectrum 
utilization. 

Rationale: 

To provide policymakers and the public with important information on 
how, where, and when spectrum is being used. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 13; 
Stakeholders: 
Broadcasters: 10; 
Wireless device manufacturers: 7; 
Wireless service providers: 10; 
Others: 3; 
Total: 43. 

Level of agreement: Somewhat agree; 
Experts: 3; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 2; 
Wireless service providers: 5; 
Others: 4; 
Total: 15. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 0; 
Total: 3. 

Level of agreement: Somewhat disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 3; 
Others: 0; 
Total: 5. 

Level of agreement: Strongly disagree; 
Experts: 2; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 2; 
Total: 6. 

Level of agreement: Total; 
Experts: 20; 
Stakeholders: 
Broadcasters: 12; 
Wireless device manufacturers: 10; 
Wireless service providers: 21; 
Others: 9; 
Total: 72. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (strongly agree); 
Comment excerpts: This should be an objective measurement, not 
subjective based upon content in the use. 

Type of commenter (level of agreement): Broadcaster (somewhat agree); 
Comment excerpts: The FCC and NTIA should complete a comprehensive 
inventory of how spectrum is currently allocated, who is using it, and 
how it is being used before proceeding with any steps related to 
spectrum reallocation. 

Type of commenter (level of agreement): Broadcaster (strongly 
disagree); 
Comment excerpts: Measurement is not an effective means of finding 
unused spectrum. 

Type of commenter (level of agreement): Broadcaster (strongly agree); 
Comment excerpts: Without identified and peer reviewed methods there 
is no certainty that any measurement of spectrum utilization 
measurement will be accurate or will provide the information the 
agency needs to evaluate how spectrum is currently being used. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Use does not necessarily equate to active 
transmissions. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Spectrum utilization has been on on-going and 
contentious issue. Without specific information the arguments become 
very subjective. Understanding how this resource is being used would 
provide significant insights PRIOR to making new policy decisions. It 
appears that many policy decisions are not based upon the technical 
facts but more on subjective analysis. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: The data is measured by licensees to manage their 
own bands, so FCC could require reporting vs. "measuring" per se or to 
complement and validate measurements. 

Type of commenter (level of agreement): Expert (neither agree nor 
disagree); 
Comment excerpts: It's a good idea in principle, but it's not clear 
how to meaningfully define "spectrum utilization.". 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Target towards bands with likely usage issues; 
not cellular, broadcast. 

Type of commenter (level of agreement): Infrastructure provider 
(strongly disagree); 
Comment excerpts: If by "spectrum utilization" the meaning is to 
measure how RF emissions are being used to transport information, the 
recommendation would yield an outcome that is meaningless from a 
policy perspective. "Use" of the spectrum depends on the service, and 
if commercial, whether the licensee has placed the spectrum into 
service. There might be a few bands where this type of analysis is 
helpful, but this should not be the way forward for spectrum policy. 
Rather, the way forward is to understand the technologies under 
development, their spectrum requirements and capabilities, likely use 
cases/demand, and expectations for innovation (how will the technology 
change over time). This is knowable from standards bodies and the 
vendor community. 

Type of commenter (level of agreement): Private user group (somewhat 
agree); 
Comment excerpts: Meaningful spectrum utilization measurement is very 
difficult. Examples: How does one measure the spectrum utilization of 
passive radioastronomy? There may not be many transmissions on a 
distress and calling frequency, but this does not mean it can be made 
available for other uses in between. Typical spectrum monitoring will 
not detect utilization by services that habitually use low signal 
levels such as the amateur radio service. 

Type of commenter (level of agreement): Public interest group 
(strongly agree); 
Comment excerpts: NTIA and FCC spectrum utilization records should 
include allocation information, assignment information, and actual use 
measurements from the field and at a level of granularity allowing 
informed decisions at the local (census block) level. 

Type of commenter (level of agreement): Satellite radio service 
provider (somewhat agree); 
Comment excerpts: Spectrum utilization is rarely a binary question of 
whether spectrum is or is not being "used" by having transmissions in 
the spectrum. For example, in order for spectrum to be "utilized," it 
should be used in a meaningful way to serve the public or the intended 
government/business use; this is far different from just testing 
whether signal is being transmitted to preserve the license, as can be 
the case with wireless spectrum. In the public safety context, 
spectrum can be used if it is unused but available for use during the 
next public emergency. In the context of broadcast spectrum, the 
question of whether spectrum is being used might even consider whether 
the station is being operated in a manner that serves the public 
interest. 

Type of commenter (level of agreement): Mobile Satellite Services 
company (strongly disagree); 
Comment excerpts: ... This is impossible without drastically 
increasing the number of government employees and the number of 
regulated company employees who would have to monitor and report. This 
cannot be done in any reasonably efficient manner. There would never 
be agreement on what to measure and how. 

Type of commenter (level of agreement): Wireless device manufacturer 
(somewhat disagree); 
Comment excerpts: Usage is only one consideration; the main 
consideration is the ROI. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat agree); 
Comment excerpts: The key is to measure in spectrum bands where there 
are no market incentives to efficiently use spectrum, e.g., government 
and restricted use bands. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat agree); 
Comment excerpts: Very complex subject; spectrum use varies by time of 
day, weather, events, etc. Such results can be misused so measuring 
methods needs to be carefully developed and results properly 
calibrated and interpreted. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat disagree); 
Comment excerpts: It depends what is meant by "utilization" data. If 
it means only transmissions using spectrum, it would be relatively 
useless. Such data would only be relevant if it included data 
regarding the economic value of the spectrum use at issue, the amount 
of time that has passed since the relevant rules were put in place, 
the applicable of secondary markets rules, and potential alternative 
uses. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

In the National Broadband Plan, FCC presented its estimate that it 
would cost approximately $10 million to $15 million to deploy 
measurement equipment nationally. FCC also stated in the plan that one 
way these measurements could be accomplished is by frequency scanners 
installed on a fleet of vehicles. FCC officials told us that the 
Commission will not implement this recommendation unless it receives 
adequate funding. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

(Continued From Previous Page) 

Level of satisfaction: Very satisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 0; 
Total: 3. 

Level of satisfaction: Somewhat satisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 1; 
Others: 0; 
Total: 5. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 4; 
Stakeholders: 
Broadcasters: 5; 
Wireless device manufacturers: 2; 
Wireless service providers: 6; 
Others: 0; 
Total: 17. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 6; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 3; 
Wireless service providers: 2; 
Others: 2; 
Total: 15. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 1; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 2; 
Wireless service providers: 1; 
Others: 4; 
Total: 10. 

Level of satisfaction: Total; 
Experts: 15; 
Stakeholders: 
Broadcasters: 9; 
Wireless device manufacturers: 9; 
Wireless service providers: 11; 
Others: 6; 
Total: 50. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Broadcaster (somewhat 
dissatisfied); 
Comment excerpts: ... FCC should be directed to evaluate the costs of 
contracting this function to a knowledgeable engineering firm 
experienced in spectrum matters, such as a frequency coordinator or 
consulting engineering firm, and the FCC should be required to measure 
spectrum utilization on an ongoing basis. 

Type of commenter (level of satisfaction): Expert (somewhat 
dissatisfied); 
Comment excerpts: The objective could be achieved by having spectrum 
users measure their usage using methods and criteria specified by the 
FCC with spot checks by the FCC. This would reduce cost of measurement 
and provide order of magnitudes more data. 

Type of commenter (level of satisfaction): Expert (strongly 
dissatisfied); 
Comment excerpts: Require reporting. This is just like CALEA. FCC 
should not waste money on the generation of data that incumbents 
already have or must have in order to provide services in existing 
spectrum. FCC should order that they report it and should fine 
licensees who do not report or who do not report accurately. 

Type of commenter (level of satisfaction): Public interest group 
(strongly dissatisfied); 
Comment excerpts: The FCC has a mandate to collect the information it 
needs to make informed policy. It also has the ability to either 
reprioritize existing funding or raise additional funding through 
license fees in order to implement [this] recommendation. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (somewhat dissatisfied); 
Comment excerpts: The scope and scale of such a project need not be 
this broad (nationally), but FCC (and NTIA) should conduct an initial 
series of spectrum occupancy studies at a diverse set of 10 to 20 
fixed locations across the country, augmented by mobile data 
collections, in urban and rural areas over several days or weeks. Some 
or all of this effort could be contracted out to independent third 
parties or academic institutions in coordination with the National 
Science Foundation who is already funding some similar data collection 
efforts. See NTIA CSMAC Report, Spectrum Inventory Working Group (May 
2010) at pp. 6, 13 (spectrum measurements initially will best serve as 
an auditing function for certain assignments/licenses in the 
inventory). The sensors used in the UK study referenced by the FCC 
would likely cost tens of thousands of dollars (and spectrum analyzers 
are even more costly). However, spectrum sensor equipment and software 
could cost below $1,000 per unit in the near future. 

Source: GAO survey. 

[End of table] 

Maintain a Strategic Spectrum Plan: 

Recommendation: 

FCC should maintain an ongoing strategic spectrum plan including a 
triennial assessment of spectrum allocations. 

Rationale: 

To ensure, now and in the future, that spectrum is allocated to 
support the growth of broadband services and to accommodate new 
technologies that deliver it. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 12; 
Stakeholders: 
Broadcasters: 4; 
Wireless device manufacturers: 6; 
Wireless service providers: 10; 
Others: 5; 
Total: 37. 

Level of agreement: Somewhat agree; 
Experts: 5; 
Stakeholders: 
Broadcasters: 6; 
Wireless device manufacturers: 2; 
Wireless service providers: 10; 
Others: 2; 
Total: 25. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 2; 
Total: 4. 

Level of agreement: Somewhat disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 0; 
Total: 4. 

Level of agreement: Strongly disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 0; 
Others: 0; 
Total: 1. 

Level of agreement: Total; 
Experts: 20; 
Stakeholders: 
Broadcasters: 12; 
Wireless device manufacturers: 10; 
Wireless service providers: 20; 
Others: 9; 
Total: 71. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (somewhat agree); 
Comment excerpts: We support the concept of developing a strategic 
spectrum plan. However, the FCC and NTIA should complete a 
comprehensive inventory of how spectrum is currently allocated, who is 
using it, and how it is being used before proceeding with any steps 
related to spectrum reallocation. Moreover, given the complex and 
dynamic nature of spectrum use and demand, spectrum allocations should 
not be reassessed every three years pursuant to an arbitrary timetable; 
instead, the FCC should consider spectrum reallocations on a case-by-
case basis and only when presented with an extremely compelling 
justification and detailed cost/benefit analysis. 

Type of commenter (level of agreement): Broadcaster (somewhat agree); 
Comment excerpts: Triennial re-assessment may be too disruptive, but 
some regular approach is a good idea. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: The main thrust for spectrum policy ought not be to 
"plan the market," which is what "a strategic spectrum plan" 
explicitly, through "triennial assessments," seeks to do. Instead it 
should provide as much spectrum to the market as possible. This means 
that it should create generic, exclusive use rights --similar to CMRS 
licenses --that allow licensees to flexibly use spectrum. That 
releases bandwidth to existing applications seeking to expand, or to 
new wireless services attempting to compete. The government should not 
be attempting to wage how much one application needs vs. others, but 
allowing demands to be registered via price bids in a spectrum market. 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: ... FCC should focus on getting spectrum to its 
highest value uses by facilitating the working of the market through 
flexible and tradable rights, not by measuring "use" of spectrum. 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: The FCC should play a much smaller role in 
allocations. A triennial assessment would make sense if it is part of 
an overall strategy along these lines. 

Type of commenter (level of agreement): Private user group (somewhat 
agree); 
Comment excerpts: In general, triennial assessment is too ambitious 
and creates too much uncertainty. Spectrum utilization planning 
requires a longer timeline. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: Strongly agree that FCC should maintain an ongoing 
spectrum plan, however, biennial/triennial/quadrennial reviews are 
cumbersome for both industry and the FCC and often result in little or 
no action. 

Type of commenter (level of agreement): Wireless service provider 
(somewhat agree); 
Comment excerpts: Triennial is probably too often. First, the task is 
Herculean. Second, the gestation period for new spectrum uses is often 
much longer than 3 years. The rules for Wi-Fi spectrum were put into 
place in the mid 1980's but it took until the late 1990's before the 
Wi-Fi standard was complete. Nearly everyone would agree that Wi-Fi is 
very useful, but if a triennial review of those spectrum rules had 
been conducted and the use changed, we wouldn't have Wi-Fi. Cellular 
telephone took a similar amount of time to develop and deploy. A 
detailed assessment every ten years would be better. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

In March 2010, FCC issued its current strategic spectrum plan and 
assessment of spectrum allocations in the form of the National 
Broadband Plan's chapter on spectrum. FCC officials told us that the 
Commission plans to complete an update of its strategic spectrum plan 
in consultation with NTIA in 18 months. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 2; 
Wireless service providers: 0; 
Others: 0; 
Total: 3. 

Level of satisfaction: Somewhat satisfied; 
Experts: 5; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 4; 
Wireless service providers: 7; 
Others: 3; 
Total: 20. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 3; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 6; 
Others: 2; 
Total: 14. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 3; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 4; 
Others: 0; 
Total: 8. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 6; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 1; 
Total: 12. 

Level of satisfaction: Total; 
Experts: 14; 
Stakeholders: 
Broadcasters: 10; 
Wireless device manufacturers: 8; 
Wireless service providers: 19; 
Others: 6; 
Total: 57. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Broadcaster (strongly 
dissatisfied); 
Comment excerpts: The approach of drafting a staff plan with limited 
input from stakeholders has created confusion and a lack of 
transparency. 

Source: GAO survey. 

[End of table] 

Identify Additional Spectrum for Wireless Broadband Use: 

Recommendation: 

FCC and NTIA should develop a joint road map to identify additional 
candidate federal and nonfederal spectrum that can be made accessible 
for both mobile and fixed wireless broadband use, on an exclusive, 
shared, licensed and/or unlicensed basis. 

Rationale: 

The specific bands identified in the National Broadband Plan will only 
partially meet future needs for wireless broadband use. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 13; 
Stakeholders: 
Broadcasters: 4; 
Wireless device manufacturers: 8; 
Wireless service providers: 10; 
Others: 8; 
Total: 43. 

Level of agreement: Somewhat agree; 
Experts: 5; 
Stakeholders: 
Broadcasters: 5; 
Wireless device manufacturers: 0; 
Wireless service providers: 6; 
Others: 0; 
Total: 16. 

Level of agreement: Neither agree nor disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 0; 
Total: 4. 

Level of agreement: Somewhat disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 0; 
Total: 4. 

Level of agreement: Strongly disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 0; 
Total: 2. 

Level of agreement: Total; 
Experts: 18; 
Stakeholders: 
Broadcasters: 12; 
Wireless device manufacturers: 10; 
Wireless service providers: 21; 
Others: 8; 
Total: 69. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (somewhat agree); 
Comment excerpts: The US needs a comprehensive plan that involves all 
stakeholders, including carriers, broadcasters, commercial providers, 
consumer electronics, academia, etc. The road map needs to be more 
comprehensive than just spectrum and should include usage patterns, 
trends and technologies to meet those demands. 

Type of commenter (level of agreement): Broadcaster (somewhat 
disagree); 
Comment excerpts: The FCC must first complete a comprehensive spectrum 
usage review to determine what spectrum is already in use for 
mobile/wireless broadband, what is coming online in the next several 
years and what the actual realistic needs will be based on predicted 
usage and predicted technological advances. 

Type of commenter (level of agreement): Private user group (strongly 
agree); 
Comment excerpts: Close cooperation between the two entities is 
essential. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

* FCC consulted with NTIA on a plan to make available 500 MHz of 
spectrum for wireless broadband over the next 10 years, which NTIA 
issued in November 2010. The plan identified over 2,200 MHz of 
candidate spectrum; the exclusively commercial portion consisted of 
280 MHz identified in the National Broadband Plan and 500 MHz from 3.7 
GHz to 4.2 GHz. At the same time, NTIA presented the results of its 
first evaluation of some of the candidate spectrum, which recommended 
that 115 MHz from various federal bands be made available in some 
parts of the nation for wireless broadband within 5 years. 

* In March 2011, FCC issued a public notice inviting comment on these 
bands, one additional federal band, and the 500 MHz plan. 

* FCC officials told us that the Commission is trying to identify 
additional candidate nonfederal spectrum through its ongoing review of 
spectrum allocations, using the following criteria: (1) bands should 
be suitable for ubiquitous, wide-area systems or networks, namely, 
from 225 MHz to 3.7 GHz; (2) bands should be sizeable, contiguous 
blocks of spectrum in order to accommodate the high bandwidths of 
current and emerging wireless technologies; and (3) bands should be of 
sufficient size and be in a part of the spectrum that encourages 
competition by allowing multiple providers and new entrants. For 
example, bands at higher frequencies require more cell sites, and 
hence greater investment, making it harder for small companies or new 
entrants to compete. Bands at lower frequencies require larger 
antennas in devices, which make them less desirable to consumers. 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 0; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 2; 
Total: 3. 

Level of satisfaction: Somewhat satisfied; 
Experts: 6; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 6; 
Wireless service providers: 5; 
Others: 1; 
Total: 20. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 5; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 7; 
Others: 3; 
Total: 18. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 4; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 0; 
Total: 5. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 0; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 1; 
Total: 5. 

Level of satisfaction: Total; 
Experts: 15; 
Stakeholders: 
Broadcasters: 6; 
Wireless device manufacturers: 8; 
Wireless service providers: 15; 
Others: 7; 
Total: 51. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with the recommendation and that chose to answer the 
question. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Broadcaster (no response); 
Comment excerpts: In reviewing spectrum allocations, the FCC must 
continue to recognize and appreciate the inherent technical 
differences between higher band and lower band frequencies. In this 
regard, broadcasters should not be forced to relocate from a UHF 
channel to a VHF channel under any scenario. 

Type of commenter (level of satisfaction): Expert (neither satisfied 
nor dissatisfied); 
Comment excerpts: Fundamentally lower frequencies are more desirable 
for coverage, higher frequencies for capacity. For this reason, 
low/high frequencies should be paired and if possible availed 
simultaneously (such as occurred in Germany for 800MHz/2.5GHz bands). 

Type of commenter (level of satisfaction): Public interest group 
(neither satisfied nor dissatisfied); 
Comment excerpts: The agenda is right and many of the right steps are 
being taken. However, the lack of better data on actual utilization of 
spectrum will continue to complicate efforts to identify the most 
suitable bands for repurposing. 

Type of commenter (level of satisfaction): Wireless device 
manufacturer (strongly dissatisfied); 
Comment excerpts: The FCC has identified many of the important 
characteristics needed to provide a wide-area mobile terrestrial 
system that supports data bandwidth intensive services. Unfortunately 
NTIA may not have the same goals as industry and the NBP. The spectrum 
it has identified in unpaired, fragmented or above 3 GHz (this can be 
used but will not serve at the macro layer of a wireless network), and 
has many operational exceptions because the spectrum being presented 
is usually considered only for shared use. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat satisfied); 
Comment excerpts: Both the FCC and NTIA should focus on spectrum that 
has the best physical characteristics for mobile broadband rather than 
on just "getting spectrum out there." For example, the 100 MHz 
identified by NTIA between 3550-3650 MHz is suboptimal for mobile 
broadband and includes exclusion zones that cover at least half the US 
population, which makes this spectrum generally unsuitable for 
commercial use. 

Source: GAO survey. 

[End of table] 

Promote Innovative Approaches to Global Spectrum Allocation: 

Recommendation: 

FCC should promote within the International Telecommunication Union 
(ITU) innovative and flexible approaches to global spectrum allocation 
that take into consideration convergence of various radio 
communication services and enable global development of broadband 
services. 

Rationale: 

Consumers want to use many applications offered on wireline and fixed 
radio communication systems on mobile terminals. The next generation 
of mobile terminals encompasses multiple radio communication services 
functions (e.g., fixed, mobile, broadcasting, and even radio 
determination) that provide for voice, data and video as well as 
positioning (i.e., convergence). The ITU's current radio regulations, 
however, may not be sufficiently flexible to accommodate these 
technological changes. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 11; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 5; 
Wireless service providers: 7; 
Others: 4; 
Total: 29. 

Level of agreement: Somewhat agree; 
Experts: 5; 
Stakeholders: 
Broadcasters: 6; 
Wireless device manufacturers: 3; 
Wireless service providers: 6; 
Others: 0; 
Total: 20. 

Level of agreement: Neither agree nor disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 0; 
Total: 4. 

Level of agreement: Somewhat disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 1; 
Total: 4. 

Level of agreement: Strongly disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 1; 
Total: 3. 

Level of agreement: Total; 
Experts: 18; 
Stakeholders: 
Broadcasters: 11; 
Wireless device manufacturers: 10; 
Wireless service providers: 15; 
Others: 6; 
Total: 60. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (somewhat agree); 
Comment excerpts: But the FCC and US Government should, in reaching 
international positions, carefully consider and take into account 
broadcasting spectrum and needs of US domestic television 
distribution. Positions seem to promote broadband at expense of 
existing television distribution uses. 

Type of commenter (level of agreement): Expert (neither agree nor 
disagree); 
Comment excerpts: The ITU has never been a vehicle for progress. Often 
a better way to initiate reforms is for the FCC to act on its own, as 
it did with international settlement rates. On the other hand, it 
doesn't hurt to push for it within the ITU even if nothing comes of it 
that way. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: So long as it does not create excessive multiband 
support requirements. 

Type of commenter (level of agreement): Private user group (somewhat 
disagree); 
Comment excerpts: "Flexible" has a down side. There are significant 
benefits to be had from global standards and common allocations. 

Type of commenter (level of agreement): Wireless device manufacturer 
(neither agree nor disagree); 
Comment excerpts: Radios are becoming so agile that we don't need 
harmonization like before. 

Type of commenter (level of agreement): Wireless device manufacturer 
(somewhat disagree); 
Comment excerpts: Convergence of services is necessary but the FCC 
could have done more with WRC 2012 Agenda item 1.2. The flexibility 
aspect can be deceptive in that it can also introduce regulatory 
uncertainty. For example if the duplex direction is not specified, 
deployed solutions could have different rules where transmission could 
be adjacent in frequency to receivers. This lowers overall network 
performance and creates confusion and dissatisfaction with the offered 
services. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: Spectrum harmonization internationally is critical 
to economies of scale. 

Source: GAO survey. 

[End of table] 

National Broadband Plan Recommendations Aimed at Enhancing the 
Usefulness of Spectrum for Wireless Backhaul: 

Revise Rules to Allow for Increased Spectrum Sharing: 

Recommendation: 

FCC should revise Parts 74, 78, and 101 of its rules to allow for 
increased spectrum sharing among compatible point-to-point microwave 
services. 

Rationale: 

Many wireless providers increasingly rely on microwave to connect 
their wireless infrastructure to the telephone network (referred to as 
"wireless backhaul"), especially in rural areas. Therefore, FCC should 
take steps to ensure that sufficient microwave spectrum is available 
to meet current and future demand for wireless backhaul, especially in 
the prime bands below 12 GHz. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 10; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 5; 
Wireless service providers: 11; 
Others: 4; 
Total: 31. 

Level of agreement: Somewhat agree; 
Experts: 4; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 2; 
Wireless service providers: 3; 
Others: 1; 
Total: 13. 

Level of agreement: Neither agree nor disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 1; 
Wireless service providers: 1; 
Others: 1; 
Total: 5. 

Level of agreement: Somewhat disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 1; 
Wireless service providers: 2; 
Others: 0; 
Total: 6. 

Level of agreement: Strongly disagree; 
Experts: 1; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 0; 
Total: 6. 

Level of agreement: Total; 
Experts: 15; 
Stakeholders: 
Broadcasters: 12; 
Wireless device manufacturers: 9; 
Wireless service providers: 19; 
Others: 6; 
Total: 61. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (somewhat 
disagree); 
Comment excerpts: Strong interference standards must be established 
and adhered to in order to safeguard the respective services and 
maximize interference protection. 

Type of commenter (level of agreement): Expert (strongly disagree); 
Comment excerpts: Secondary markets, not FCC rules, can handle sharing 
more efficiently. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: Wireless backhaul enables progression of cyberspace/ 
broadband into rural and unserved areas and thus is commendable; the 
technology has been available for a decade. Sustainment after 
government loans is the key issue. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: 90 percent of backhaul in Europe and UK is 
microwave. we need flexibility and we need competition in special 
access as it is a monopoly today and limited in speed to T1's mostly. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: Also need dedicated licenses, but increasing access 
to bands is good. 

Type of commenter (level of agreement): Wireless service provider 
(strongly agree); 
Comment excerpts: We support the FCC proposal to make an additional 
750 MHz available for Fixed Service by allowing sharing with bands 
reserved for Broadcast Auxiliary Service and Cable TV relay service. 
We would note that formalized frequency coordination procedures will 
be necessary for operations within this band to ensure non-
interference. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

FCC's progress and experts' and stakeholders' satisfaction with FCC's 
progress are described under the following recommendation, which FCC 
is implementing jointly with this recommendation. 

Revise Rules to Allow for Greater Flexibility and Cost-Effectiveness: 

Recommendation: 

FCC should revise its rules to allow for greater flexibility and cost-
effectiveness in deploying wireless backhaul. 

Rationale: 

FCC's Part 101 microwave rules are intended to enable a high level of 
service reliability, but they may also limit deployment flexibility in 
coverage-or capacity-limited situations. Therefore, the FCC should 
commence a proceeding to update these rules to reduce the cost of 
backhaul in capacity-limited urban areas and range-limited rural areas. 

Table: Expert and Stakeholder Respondents' Level of Agreement with the 
Recommendation: 

Level of agreement: Strongly agree; 
Experts: 12; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 6; 
Wireless service providers: 13; 
Others: 3; 
Total: 36. 

Level of agreement: Somewhat agree; 
Experts: 4; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 3; 
Wireless service providers: 3; 
Others: 2; 
Total: 14. 

Level of agreement: Neither agree nor disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 3; 
Wireless device manufacturers: 0; 
Wireless service providers: 1; 
Others: 1; 
Total: 5. 

Level of agreement: Somewhat disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 0; 
Wireless service providers: 0; 
Others: 1; 
Total: 3. 

Level of agreement: Strongly disagree; 
Experts: 0; 
Stakeholders: 
Broadcasters: 1; 
Wireless device manufacturers: 0; 
Wireless service providers: 2; 
Others: 0; 
Total: 3. 

Level of agreement: Total; 
Experts: 16; 
Stakeholders: 
Broadcasters: 10; 
Wireless device manufacturers: 9; 
Wireless service providers: 19; 
Others: 7; 
Total: 61. 

Source: GAO survey. 

[End of table] 

Table: Expert and Stakeholder Comments on the Recommendation: 

Type of commenter (level of agreement): Broadcaster (somewhat 
disagree); 
Comment excerpts: Any action in pursuit of this recommendation should 
thoroughly study and address interference issues and require adequate 
protection standards. 

Type of commenter (level of agreement): Expert (somewhat agree); 
Comment excerpts: However, I advise the FCC to consider public 
interest versus private interest. It is not the FCC's job to enhance 
profits of big incumbents under the guise of cost-effectiveness. I 
like profits ... but the argument needs to be for competition to 
improve quality while keeping costs low vs one size fits all solution 
that only one or two big incumbents can supply. 

Type of commenter (level of agreement): Expert (strongly agree); 
Comment excerpts: I agree in the respect that wireless backhaul is 
critical for future services. 

Type of commenter (level of agreement): Mobile Satellite Services 
company (somewhat disagree); 
Comment excerpts: Part 101 prior coordination rules must be retained 
to protect incumbent licensees. The Commission should not allow 
operation of distributed radiating elements (DREs) as proposed by 
Wireless Strategies Inc without part 101 frequency coordination. 

Type of commenter (level of agreement): Wireless device manufacturer 
(strongly agree); 
Comment excerpts: The government should consider what Australia is 
doing with NBN. 

Source: GAO survey. 

[End of table] 

FCC's Progress on Implementing the Recommendation through May 2011: 

In August 2010, FCC issued an NPRM and a Notice of Inquiry proposing 
to remove regulatory barriers to the use of microwave spectrum for 
wireless backhaul, in order to increase flexibility, capacity, and 
cost-effectiveness of microwave bands.[Footnote 69] 

Table: Expert and Stakeholder Respondents' Level of Satisfaction with 
FCC's Progress: 

Level of satisfaction: Very satisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 3; 
Wireless service providers: 1; 
Others: 0; 
Total: 6. 

Level of satisfaction: Somewhat satisfied; 
Experts: 7; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 2; 
Wireless service providers: 7; 
Others: 2; 
Total: 20. 

Level of satisfaction: Neither satisfied nor dissatisfied; 
Experts: 2; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 5; 
Others: 0; 
Total: 8. 

Level of satisfaction: Somewhat dissatisfied; 
Experts: 1; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 1; 
Wireless service providers: 0; 
Others: 1; 
Total: 3. 

Level of satisfaction: Strongly dissatisfied; 
Experts: 0; 
Stakeholders: 
Broadcasters: 0; 
Wireless device manufacturers: 0; 
Wireless service providers: 0; 
Others: 1; 
Total: 1. 

Level of satisfaction: Total; 
Experts: 12; 
Stakeholders: 
Broadcasters: 2; 
Wireless device manufacturers: 7; 
Wireless service providers: 13; 
Others: 4; 
Total: 38. 

Source: GAO survey. 

Note: Figures include only respondents that strongly agreed or 
somewhat agreed with both recommendations on wireless backhaul. 

[End of table] 

Table: Expert and Stakeholder Comments on FCC's Progress: 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat satisfied); 
Comment excerpts: The speed of the rulemaking proceeding is a concern. 
Item is not that controversial and we are still awaiting an order 
after almost a year. 

Type of commenter (level of satisfaction): Wireless service provider 
(somewhat satisfied); 
Comment excerpts: While in general flexibility is desirable in 
spectrum management, the FCC should ensure that its rules do not 
create new interference or efficiency concerns, e.g., the harms of 
using auxiliary stations outweigh their benefits. 

Source: GAO survey. 

[End of table] 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Mark L. Goldstein (202) 512-2834 or goldsteinm@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Michael Clements, Assistant 
Director; Eli Albagli; Richard Brown; Stephen Brown; Sharon Dyer; 
David Goldstein; Josh Ormond; Kelly Rubin; Andrew Stavisky; Hai Tran; 
and Mindi Weisenbloom made key contributions to this report. 

[End of section] 

Footnotes: 

[1] FCC, Connecting America: The National Broadband Plan (Washington, 
D.C.: Mar. 16, 2010). 

[2] Wireless broadband comprises both fixed and mobile wireless 
communication services. Fixed wireless broadband refers to stationary 
wireless devices or systems that provide high-speed Internet access 
from a fixed location. Mobile broadband refers to wireless high-speed 
Internet access through a portable device, such as a cell phone. 

[3] In April 2011, we issued a report on the National 
Telecommunications and Information Administration's (NTIA) management 
of the federal government's use of spectrum. See GAO, Spectrum 
Management: NTIA Planning and Processes Need Strengthening to Promote 
the Efficient Use of Spectrum by Federal Agencies, GAO-11-352 
(Washington, D.C.: Apr. 12, 2011). 

[4] The six repurposings we examined met the following criteria: (1) 
the amount of spectrum repurposed was 5 megahertz (MHz) or more, (2) 
the repurposing yielded $100 million or more in auction or industry 
revenue, and (3) reassignment occurred in 1994, when FCC first 
implemented its auction authority, or later. 

[5] We excluded three recommendations that were addressed in our 
questions about FCC's data quality, fell under the purview of NTIA, or 
pertained to a narrow population. 

[6] Radio signals travel through space in the form of waves. These 
waves vary in length, and each wavelength is associated with a 
particular radio frequency. Radio frequencies are grouped into bands 
and are measured in units of Hertz. The term kilohertz (kHz) refers to 
thousands of Hertz, megahertz (MHz) to millions of Hertz, and 
gigahertz (GHz) to billions of Hertz. The Hertz unit of measurement is 
used to refer to both the quantity of spectrum (such as 500 MHz of 
spectrum) and the frequency bands (such as the 1710-1755 MHz band). 

[7] Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq. 

[8] A subscriber-based wireless service is one in which the company 
providing the service sells subscriptions for the service to customers. 

[9] The Omnibus Budget Reconciliation Act of 1993 amended the 
Communications Act of 1934 to allow the use of competitive bidding to 
issue licenses and to restrict the use of lotteries. Omnibus Budget 
Reconciliation Act of 1993, Pub. L. No. 103-66, § 6002, 107 Stat. 312, 
388-92 (1993), as amended by the Balanced Budget Act of 1997, Pub. L. 
No. 105-33, § 3002-3, 111 Stat. 251, 258-66 (1997) (codified at 47 
U.S.C. § 309(j)). The act required the Commission to establish, by 
regulation, the methodology of the auction and eligibility to bid for 
those licenses. 47 U.S.C. § 309(j)(3). After setting the methodology 
for a particular competitive bidding system, the Commission was 
required to establish the requirements to participate in an auction. 
47 U.S.C. § 309(j)(4). 

[10] Implementation of Section 309(j) of the Communications Act--
Competitive Bidding, Second Report and Order, 9 FCC Rcd 2348 (1994). 

[11] The Balanced Budget Act of 1997 (BBA-97) amended Section 309(j) 
of the Communications Act to require the Commission to grant licenses 
through the use of competitive bidding when mutually exclusive 
applications for initial licenses are accepted for filing, unless 
certain specific statutory exemptions apply. BBA-97 § 3002(a) 
(codified at 47 U.S.C. § 309(j)). Section 309(j)(2) exempts from 
auctions licenses and construction permits for public safety radio 
services, digital television service licenses and permits given to 
existing terrestrial broadcast licensees to replace their analog 
television service licenses, and licenses and construction permits for 
noncommercial educational broadcast stations and public broadcast 
stations described in section 397(6) of the Communications Act. 

[12] See 47 U.S.C. § 309(j)(11). 

[13] Memorandum for the Heads of Executive Departments and Agencies, 
Unleashing the Wireless Broadband Revolution (Presidential 
Memorandum), rel. June 28, 2010, 75 Fed. Reg. 38387, available at 
http://www.whitehouse.gov/the-press-office/presidential-memorandum-
unleashing-wireless-broadband-revolution. 

[14] Different spectrum bands have certain advantages and 
disadvantages for various applications. For example, the C-band 
frequencies for satellite service are useful to broadcast television 
networks distributing video content to local television stations, 
since this band is less susceptible to degradation from precipitation 
than other bands. 

[15] The six repurposings we examined met the following criteria: (1) 
the amount of spectrum repurposed was 5 MHz or more; (2) the 
repurposing yielded $100 million or more in auction or industry 
revenue; and (3) reassignment occurred in 1994, when FCC first 
implemented its auction authority, or later. 

[16] For one of the repurposings, the Mobile Satellite Services S 
band, FCC did not auction the spectrum but rather reassigned the 
spectrum to eight companies that applied for licenses. 

[17] In some instances, our start and end dates differ from those FCC 
identified in the National Broadband Plan. For example, FCC reported 
that the Personal Communications Service repurposing began in 1989, 
while we determined that this repurposing began in 1992. Regardless of 
the specific start and end dates, both FCC's and our analyses found 
that the process can be lengthy. 

[18] U.S. Department of Commerce, Relocation of Federal Radio Systems 
from the 1710-1755 MHz Spectrum Band: Fourth Annual Progress Report 
(March 2011). The report notes that approximately 81 percent of the 
total systems have been relocated from the 1710-1755 MHz band as of 
December 2010. 

[19] Section 27.14 of title 47 of the Code of Federal Regulations 
provides that a renewal applicant receives a preference or renewal 
expectancy if the applicant has provided substantial service during 
its past license term and has complied with the Communications Act and 
applicable Commission rules and policies. According to this section, 
substantial service is defined as "service which is sound, favorable, 
and substantially above a level of mediocre service which just might 
minimally warrant renewal." 47 C.F.R. § 27.14(a). Section 27.13 
provides that authorizations for the 1710-1755 MHz and 2110-2155 MHz 
bands will have a term not to exceed 10 years from the date of initial 
issuance or renewal, except that authorizations issued on or before 
December 31, 2009, shall have a term of 15 years. 47 C.F.R. § 27.13. 

[20] Amendment of the Commission's Rules to Establish New Personal 
Communications Services, Second Report and Order, 8 FCC Rcd 7700 
(1993). 

[21] Amendment of the Commission's Rules to Establish New Personal 
Communications Services, Memorandum Opinion and Order, 9 FCC Rcd 4957 
(1994). 

[22] Cincinnati Bell Telephone Co. v. FCC, 69 F.3d 752 (6th Cir. 1995). 

[23] Amendment of Parts 20 and 24 of the Commission's Rules--Broadband 
PCS Competitive Bidding and the Commercial Mobile Radio Service 
Spectrum Cap; Amendment of the Commission's Cellular/PCS Cross-
Ownership Rule, Report and Order, 11 FCC Rcd 7824 (1996) aff'd, 12 FCC 
Rcd 14031 (1997), aff'd sub nom. BellSouth Corp. v. FCC, 162 F.3d 1215 
(D.C. Cir. 1999). Throughout the Personal Communications Service 
repurposing, FCC issued 6 notices of proposed rulemaking and 34 
orders, and received over 2,600 filings from interested parties. 

[24] In the Omnibus Budget Reconciliation Act of 1993, Congress 
authorized the competitive bidding of spectrum-based services and 
mandated that small businesses, rural telephone companies, and 
businesses owned by members of minority groups and women (collectively 
known as "designated entities") be ensured the opportunity to 
participate in the provision of such services. 47 U.S.C. § 
309(j)(4)(D); see also id. § 309(j)(3)(B). In the Fifth Report and 
Order, FCC adopted competitive bidding rules designed to encourage 
designated entity participation in the broadband Personal 
Communications Service. 9 FCC Rcd 5532 (1994); recon. Implementation 
of Section 309(j) of the Communications Act--Competitive Bidding, 
Fifth Memorandum Opinion and Order, 10 FCC Rcd 403 (1994) 
("Competitive Bidding Fifth Memorandum Opinion and Order"), erratum, 
60 Fed. Reg. 5333 (1995). 

[25] Specifically, FCC established "entrepreneurs' blocks" (the C and 
F frequency blocks allocated for broadband Personal Communication 
Service) for which eligibility was limited to individuals and entities 
under a certain financial size. FCC also adopted special provisions 
for businesses owned by members of minority groups or women and 
analyzed their constitutionality utilizing the "intermediate scrutiny" 
standard of review articulated in Metro Broadcasting, Inc. v. FCC, 497 
U.S. 547, 564-565 (1990). FCC made subsequent changes to the 
entrepreneurs' block rules and special provisions for designated 
entities in the Fifth MO&O. Fifth Report and Order, 9 FCC Rcd 5532 
(1994) (Fifth R&O), recon. Fifth Memorandum Opinion and Order, 10 FCC 
Rcd 403 (Fifth MO&O), erratum, 60 Fed. Reg. 5333 (1995). 

[26] Adarand Constructors. Inc. v. Pena, 515 U.S. 200 (1995). 

[27] For example, NextWave was the high bidder for 95 C, D, E, and F 
block, broadband Personal Communications Service licenses in auctions 
held from 1995 to 1997. On June 8, 1998, NextWave filed for Chapter 11 
bankruptcy protection in the U.S. Bankruptcy Court for the Southern 
District of New York. Following extensive litigation, the U.S. Supreme 
Court held that NextWave's licenses had not automatically canceled for 
nonpayment while it was in bankruptcy. FCC v. NextWave, 537 U.S. 293 
(2003). As part of its reorganization process, NextWave obtained FCC 
approval to transfer certain of its C and F block PCS licenses to 
Cingular. Applications for Consent to the Assignment of Licenses 
Pursuant to Section 310(d) of the Communications Act from NextWave 
Personal Communications, Inc., Debtor-in-Possession, and NextWave 
Power Partners, Inc., Debtor-in-Possession, to subsidiaries of 
Cingular Wireless, Inc., Memorandum Opinion & Order, 19 FCC Rcd 2570 
(2004). In April 2004, NextWave entered a settlement agreement with 
FCC whereby it would retain certain of its C and F block licenses, and 
would return the remaining licenses to FCC. On May 25, 2004, the 
bankruptcy court approved this settlement agreement. Order Granting 
Motion Pursuant to Section 363 of the Bankruptcy Code, In re: NextWave 
Personal Communications, Inc. et al., 98B21529 (Bankr. S.D.N.Y.) (May 
25, 2004). 

[28] See Redevelopment of Spectrum to Encourage Innovation in the Use 
of New Telecommunications Technologies, First Report and Order and 
Third Notice of Proposed Rule Making, 7 FCC Rcd 6886 (1992); Second 
Report and Order, 8 FCC Rcd 6495 (1993); Third Report and Order and 
Memorandum Opinion and Order, 8 FCC Rcd 6589 (1993); Memorandum 
Opinion and Order, 9 FCC Rcd 1943 (1994); Second Memorandum Opinion 
and Order, 9 FCC Rcd 7797 (1994); aff'd Association of Public Safety 
Communications Officials-International, Inc. v. FCC, 76 F.3d 395 (D.C. 
Cir. 1996) (collectively, "Emerging Technologies proceeding"). 

[29] NTIA identified the band 1710-1755 MHz for transfer, with certain 
Federal operations to remain protected indefinitely. See NTIA, 
Spectrum Reallocation Final Report, Response to Title VI Omnibus 
Budget Reconciliation Act of 1993, NTIA Special Publication 95-32, at 
App. E and page F-4 (February 1995). 

[30] The Balanced Budget Act of 1997 required NTIA to accelerate the 
availability of the 1710-1755 MHz band to allow auctioning of this 
spectrum to commence after Jan. 1, 2001, and to be completed by Sept. 
30, 2002. See BBA-97, Section 3002(b). The Strom Thurmond National 
Defense Authorization Act for Fiscal Year 1999, required that funds 
would be made available by private sector entities receiving spectrum 
in the band 1710-1755 MHz for the cost of relocating or modifying all 
federal government radio communications systems required to vacate or 
modify their operations in the band 1710-1755 MHz after an auction has 
taken place. Pub. L. No. 105-261, 112 Stat. 1920; 47 U.S.C. § 923(g). 

[31] U.S. Department of Commerce, NTIA, An Assessment of the Viability 
of Accommodating Advanced Mobile Wireless (3G) Systems in the 1710-
1770 MHz and 2110-2170 MHz Bands, report rel. July 22, 2002. 

[32] Amendment of Part 2 of the Commission's Rules to Allocate 
Spectrum Below 3 GHz for Mobile and Fixed Services to Support the 
Introduction of New Advanced Wireless Services, Including Third 
Generation Wireless Systems, Second Report and Order, 17 FCC Rcd 23193 
(2002). 

[33] Multipoint distribution service, also known as wireless cable, 
was generally used for the transmission of data and video programming 
to subscribers using high-powered systems. 

[34] 5 U.S.C. § 551, et seq. 

[35] 47 U.S.C. §§ 405 and 402, respectively. 

[36] In certain cases, appeals to FCC rules must be made only to the 
U.S. Court of Appeals for the D.C. Circuit. 47 U.S.C. § 402(b). 

[37] GAO, Telecommunications: Comprehensive Review of U.S. Spectrum 
Management with Broad Stakeholder Involvement Is Needed, GAO-03-277 
(Washington, D.C.: Jan. 31, 2003). 

[38] The 700 MHz D-Block spectrum was made available for auction 
through the transition of television from analog to digital service, 
which freed up a portion of the 700 MHz spectrum for new wireless 
services. FCC established the Upper 700 MHz D Block to be licensed on 
a nationwide basis to a single entity via auction. FCC's auction rules 
required the winning bidder for the D Block to enter into a public/ 
private partnership with the nationwide licensee of the public safety 
broadband spectrum, a nonprofit entity established by national public 
safety leadership. That requirement was intended to enable 
construction of an interoperable broadband network that would serve 
both commercial and public safety users. This 10 MHz block of spectrum 
did not receive a winning bid in FCC's 700 MHz auction held in 2008. 

[39] In our survey results, we grouped the following types of 
stakeholders into the "other" category: public interest groups, 
infrastructure providers, Mobile Satellite Services companies, a 
private user, a Satellite Digital Audio Radio Service provider, and 
spectrum data managers. 

[40] FCC, Connecting America: The National Broadband Plan, page 89. 

[41] Cisco Systems, Inc. is a supplier of Internet routers, which are 
hardware devices or software programs that forward Internet and 
network traffic between networks and are critical to their operation. 

[42] LightSquared Subsidiary LLC, Request for Modification of its 
Authority for an Ancillary Terrestrial Component, Order and 
Authorization, 26 FCC Rcd 566 (2011). See also, Status of Testing in 
Connection with LightSquared's Request for ATC Commercial Operating 
Authority, Public Notice, DA-11-1537, 2011 FCC LEXIS 3768 (Sept. 13, 
2011). FCC, in consultation with NTIA, has determined that additional 
targeted testing is needed to ensure that any potential commercial 
terrestrial service offered by LightSquared will not cause harmful 
interference to GPS operations. 

[43] The plan also included a recommendation that Congress consider 
building upon the success of the Commercial Spectrum Enhancement Act 
(Pub. L. No. 108-494, Title II, 118 Stat. 3986) to fund additional 
approaches to facilitate relocation of incumbent federal users. We did 
not consider this recommendation in this review because it relates 
more to NTIA's management of federal spectrum use than to FCC's 
management of commercial spectrum use. 

[44] To ensure that the spectrum freed up in an incentive auction is 
effectively usable for mobile broadband, FCC will need to assign new 
frequencies to some television stations through a realignment process 
sometimes called repacking. According to FCC, because digital 
technology allows stations to use virtual channel numbers, even if a 
station's frequency changes through realignment, it can continue to 
have its same channel number display on television screens and set-top 
boxes. Further, FCC has said broadcasters will be fully reimbursed for 
any costs incurred in changing channels. 

[45] Dynamic sharing of spectrum, sometimes referred to as "dynamic 
spectrum access," can be enabled by the use of "cognitive" radios that 
are able at any moment in time to determine and use spectrum that is 
unused and available. 

[46] Wi-Fi networks--which provide wireless broadband service in so-
called "hot spots," or areas within a radius of up to 300 feet--can be 
found in cafes, hotels, airports, and offices. In a Wi-Fi network, a 
wireless device uses an antenna to transmit data to a router, which 
then sends the information to the Internet using a wired connection. 
Some licensed wireless service providers off-load (or transfer) some 
of their data traffic from the cellular network onto Wi-Fi networks. 
This benefits users by providing them with much faster service while 
licensed wireless service providers have less congestion and can 
deliver a better overall quality of service. 

[47] In the past, broadcasters have sought judicial review of FCC's 
white spaces order, noting that the Commission's decision to allow 
unlicensed access to the television spectrum would have a direct 
adverse impact on broadcasters because it would allow harmful 
interference with the reception of the broadcast signals. The 
Association for Maximum Service Television and the National 
Association of Broadcasters filed a petition for review in the U.S. 
Court of Appeals for the District of Columbia (Case No. 09-1080) on 
February 27, 2009. This case is currently being held in abeyance. FCC 
has since issued a follow-up white spaces order and there are 
petitions for reconsideration pending on this order. Unlicensed 
Operation in the TV Broadcast Bands, Second Memorandum Opinion and 
Order, 25 FCC Rcd 18661 (2010). 

[48] Unlicensed Operation in the TV Broadcast Bands, Second Memorandum 
Opinion and Order, 25 FCC Rcd 18661 (2010). 

[49] Promoting More Efficient Use of Spectrum Through Dynamic Spectrum 
Use Technologies, Notice of Inquiry, 25 FCC Rcd 16632 (2010). 

[50] Promoting Expanded Opportunities for Radio Experimentation and 
Market Trials under Part 5 of the Commission's Rules and Streamlining 
Other Related Rules; 2006 Biennial Review of Telecommunications 
Regulations--Part 2 Administered by the Office Of Engineering and 
Technology (OET), Notice of Proposed Rulemaking, 25 FCC Rcd 16544 
(2010). 

[51] GAO, Telecommunications: Strong Support for Extending FCC's 
Auction Authority Exists, but Little Agreement on Other Options to 
Improve Efficient Use of Spectrum, GAO-06-236 (Washington, D.C.: Dec. 
20, 2005). 

[52] Deficit Reduction Act, Pub. L. No. 109-171, § 3003, 120 Stat. 4, 
22 (2006); DTV Delay Act, Pub. L. No. 111-4, § 5, 123 Stat. 112, 114 
(2009). 

[53] GAO, Telecommunications: Enhanced Data Collection Could Help FCC 
Better Monitor Competition in the Wireless Industry, GAO-10-779 
(Washington, D.C.: July 27, 2010). 

[54] GAO-10-779. 

[55] GAO-03-277. 

[56] GAO-06-236. 

[57] These recommendations are (1) Recommendation 5.1: The FCC should 
launch and continue to improve a spectrum dashboard; (2) 
Recommendation 5.5: Congress should consider building upon the success 
of the Commercial Spectrum Enhancement Act to fund additional 
approaches to facilitate incumbent relocation; and (3) Recommendation 
5.17: The FCC should take into account the unique spectrum needs of 
U.S. Tribal communities when implementing the recommendations in this 
chapter. 

[58] We did not examine FCC's Cable Operations and Licensing System 
(COALS), which pertains to cable operators and multichannel video 
programming distributors. According to FCC staff, COALS does include 
some spectrum-related information. 

[59] Since Spectrum Dashboard and License View pull data from other 
systems, such as the Universal Licensing System and the Consolidated 
Database System, we are not reporting survey results about inaccurate 
and missing data in these systems. FCC officials acknowledge that the 
quality of data in Spectrum Dashboard and License View is only as good 
as the quality of data in their underlying systems, including the 
Universal Licensing System and the Consolidated Database System. 

[60] GAO, Telecommunications: Information Collection and Management at 
the Federal Communications Commission, GAO-10-249 (Washington, D.C.: 
Jan. 29, 2010). 

[61] The private land mobile radio service covers two-way land mobile 
communications by individuals, organized groups, businesses, and state 
and local government agencies. 

[62] See FCC, FCC Launches Data Innovation Initiative, press release 
(June 29, 2010), available at 
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-299269A1.pdf. 

[63] We excluded three recommendations that were addressed in our 
questions about FCC's data quality, fell under the purview of NTIA, or 
pertained to a narrow population. 

[64] All excerpts of experts' and stakeholders' comments included in 
this appendix are verbatim reproductions of the comments provided in 
response to our survey, except for corrections of spelling and 
grammatical errors. Any other clarifications we made to comments are 
shown in brackets or in table notes. We selected comments in order to 
present a range of views, while aiming to minimize repetition of views 
within a category of stakeholders. 

[65] FCC, Spectrum Analysis: Options for Broadcast Spectrum, Omnibus 
Broadband Initiative Technical Paper No. 3 (June 2010). 

[66] Innovation in the Broadcast Television Bands: Allocations, 
Channel Sharing, and Improvements to VHF, Notice of Proposed 
Rulemaking, 25 FCC Rcd 16498 (2010). 

[67] FCC issued this solicitation on May 20, 2011, after we finalized 
the questionnaire for our survey. 

[68] This recommendation also said that Congress should consider 
granting authority to NTIA to impose spectrum fees on users of 
government spectrum, but we did not include that part of the 
recommendation is our survey because our focus was on FCC. 

[69] Subsequent to our survey, in August 2011 FCC issued a Report and 
Order, Further Notice of Proposed Rulemaking, and Memorandum Opinion 
and Order in its Wireless Backhaul proceeding [Amendment of Part 101 
of the Commission's Rules to Facilitate the Use of Microwave for 
Wireless Backhaul and Other Uses and to Provide Additional Flexibility 
to Broadcast Auxiliary Service and Operational Fixed Microwave 
Licensees; Petition for Rulemaking filed by Fixed Wireless 
Communications Coalition to Amend Part 101 of the Commission's Rules 
to Authorize 60 and 80 MHz Channels in Certain Bands for Broadband 
Communications, Report and Order, Further Notice of Proposed 
Rulemaking, and Memorandum Opinion and Order, FCC 11-120, 53 Comm. 
Reg. (P&F) 1099, 2011 LEXIS 3243 (rel. Aug. 9, 2011)]. By this action, 
FCC updated its rules to (1) permit fixed microwave operation in 
several spectrum bands previously reserved for specialized microwave 
services, (2) enable microwave licensees to take advantage of the 
latest technology to maintain the reliability of critical links, and 
(3) provide broadcasters with increased flexibility to use fixed 
microwave links. FCC also sought comment on additional proposals for 
making microwave communications more flexible and cost-effective. 

[End of section] 

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