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Strengthening to Promote the Efficient Use of Spectrum by Federal 
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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

April 2011: 

Spectrum Management: 

NTIA Planning and Processes Need Strengthening to Promote the 
Efficient Use of Spectrum by Federal Agencies: 

GAO-11-352: 

GAO Highlights: 

Highlights of GAO-11-352, a report to congressional committees. 

Why GAO Did This Study: 

Radio frequency spectrum enables vital wireless communications 
services used by the federal government, businesses, and consumers. 
Spectrum capacity is necessary for wireless broadband (high-speed 
Internet access) and broadband deployment will boost the nation’s 
capabilities in many important areas. As the demand for spectrum 
continues to increase, there is concern about adequate access to meet 
future needs. This requested report examines (1) how the National 
Telecommunications and Information Administration (NTIA) is managing 
spectrum needs of federal agencies, (2) how federal agencies are using 
and managing assigned spectrum, and (3) what steps NTIA has taken to 
meet recent initiatives aimed at making spectrum available for 
broadband. GAO reviewed NTIA’s spectrum management documents; surveyed 
the 19 federal agencies comprising the Interdepartment Radio Advisory 
Committee; and interviewed NTIA officials and industry and academic 
experts. 

What GAO Found: 

NTIA is responsible for governmentwide federal spectrum management, 
but its efforts in this area have been limited. In 2003, the President 
directed NTIA to develop plans identifying federal and national (both 
federal and nonfederal) spectrum needs, and in 2008, NTIA issued the 
federal plan. GAO found this plan has several limitations, does not 
identify government wide spectrum needs, and does not contain key 
elements and best practices of strategic planning. NTIA has yet to 
issue the national plan. Furthermore, NTIA’s primary spectrum 
management operations do not focus on government wide needs. Instead 
NTIA depends on agency self-evaluation of spectrum needs and focuses 
on interference mitigation, with limited emphasis on holistic spectrum 
management. Lacking a strategic vision, NTIA cannot ensure that 
spectrum is being used efficiently by federal agencies. Additionally, 
NTIA’s data management system is antiquated and lacks internal 
controls to ensure the accuracy of agency-reported data, making it 
unclear if decisions about federal spectrum use are based on reliable 
data. NTIA is developing a new data management system, but full 
implementation of the system is years away. 

Federal agencies use spectrum for many purposes such as emergency 
communications and national defense, and NTIA requires the agencies to 
periodically evaluate their current and future spectrum needs. 
Agencies are supposed to ensure spectrum assignments fulfill 
established mission needs; however, NTIA does not have specific 
requirements for agencies to justify their spectrum assignments or 
validate data used for these evaluations. Consequently, NTIA has 
limited assurance that the data used to make spectrum management 
decisions are accurate. Federal agencies rely heavily on their program 
offices to obtain data for the required evaluations and often face 
challenges, such as resource constraints and staff turnover, when 
coordinating with field program staff. Given that validating spectrum 
assignments could require significant agency resources, it would be 
beneficial for NTIA to consider options for a different approach to 
obtain and validate critical spectrum assignment information from the 
agencies, such as requiring agencies to conduct site surveys or attest 
to the accuracy of data they submit. 

In response to recent initiatives, NTIA has taken steps to identify 
spectrum that could be made available for broadband use. First, NTIA 
evaluated various spectrum bands and identified 115 megahertz of 
spectrum that could be made available for broadband within the next 5 
years based on criteria it developed. Second, NTIA developed an 
initial plan and timetable for evaluating and repurposing additional 
spectrum for broadband use in 10 years. Affected federal agencies—that 
is, those agencies operating devices in the spectrum bands being 
evaluated—encountered difficulties providing NTIA with the necessary 
data and analyses during the most recent evaluation. For example, 
according to the affected agencies, they were required to analyze and 
submit a significant amount of detailed impact analyses that were not 
readily available. Agencies will likely continue to face challenges 
providing such analyses to NTIA in the future as NTIA begins 
evaluating a larger number of spectrum bands for possible broadband 
use in the next 10 years. 

What GAO Recommends: 

NTIA should develop an updated strategic plan, examine its assignment 
review processes to determine if the current approach can be improved, 
and establish internal controls to ensure the accuracy of agency-
reported data. The Department of Commerce concurred with GAO’s 
recommendation to examine the review processes and, citing competing 
priorities, partially concurred with the remaining two. 

View [hyperlink, http://www.gao.gov/products/GAO-11-352] or key 
components. For more information, contact Mark Goldstein at (202) 512-
2834 or goldsteinm@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

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

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

NTIA Has Taken Steps to Identify Spectrum for Future Wireless 
Broadband Use, yet NTIA and Federal Agencies Will Face Challenges in 
Analyzing and Repurposing This Spectrum: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

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

Appendix III: Survey of IRAC Agencies: 

Appendix IV: Comments from the Department of Commerce: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Federal Agency, IRAC, and NTIA Roles in the Frequency 
Assignment and System Certification Processes: 

Table 2: Status of NTIA Spectrum Oversight Programs: 

Table 3: NTIA Criteria for Prioritizing and Characterizing Candidate 
Bands in the 10-Year Plan: 

Table 4: Status and Outcome of Bands Evaluated for Fast Track 
Repurposing: 

Table 5: List of Experts and Industry Stakeholders We Contacted: 

Figures: 

Figure 1: Examples of Allocated Spectrum Uses, and Federal Spectrum 
Use in the High-Value Range: 

Figure 2: NTIA Frequency Data Collection Processes: 

Figure 3: Federal Agencies with the Most Spectrum Assignments: 

Figure 4: Percent of Federally Assigned Spectrum Located in Various 
Ranges: 

Figure 5: Number of Surveyed IRAC Agencies Reporting Various Types of 
Spectrum Use: 

Abbreviations: 

CSEA: Commercial Spectrum Enhancement Act: 

CSMAC: Commerce Spectrum Management Advisory Committee: 

DOD: Department of Defense: 

FAA: Federal Aviation Administration: 

FAS: Frequency Assignment Subcommittee: 

FCC: Federal Communications Commission: 

FSMS: Federal Spectrum Management System: 

GHz: gigahertz: 

GMF: Government Master File: 

GOES-R: Geostationary Operational Environmental Satellite-R series: 

IRAC: Interdepartment Radio Advisory Committee: 

kHz: kilohertz: 

MHz: megahertz: 

NOAA: National Oceanic and Atmospheric Administration: 

NTIA: National Telecommunications and Information Administration: 

PPSG: Policy Plans Steering Group: 

SPS: Spectrum Planning Subcommittee: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

April 12, 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 that is used to 
provide an array of wireless communications services critical to the 
U.S. economy and a variety of government functions, such as scientific 
research, national defense, homeland security, and other vital public 
safety activities. Spectrum capacity is necessary to deliver wireless 
broadband[Footnote 1] to consumers and businesses and also to support 
the communication needs of industries that use commercial wireless 
broadband to transmit large quantities of information quickly and 
reliably. Broadband deployment stimulates economic growth, spurs job 
creation, and boosts the nation's capabilities in education, health 
care, homeland security, and other areas. As the U.S. experiences 
significant growth in commercial wireless broadband services, the 
demand for radio frequency spectrum has increased and additional 
capacity will be needed to accommodate future growth. As new spectrum- 
dependent technologies and services are brought to the market and new 
mission needs unfold among government users, Congress, industry 
stakeholders, and federal agencies expressed concern about the 
availability of additional spectrum for future needs, and that current 
spectrum management in the U.S. may not be able to respond adequately 
to these rapidly changing needs. This is compounded by the fact that 
not all radio frequency spectrum has equal value. The spectrum most 
highly valued generally consists of frequencies between 300 megahertz 
(MHz) and 3 gigahertz (GHz), as these frequencies have properties well 
suited to many important wireless technologies, such as mobile phones, 
radio, and television broadcasting.[Footnote 2] According to the 
Department of Commerce's National Telecommunications and Information 
Administration (NTIA), as of December 2009, federal agencies had 
exclusive access to about 18 percent of these high-value frequencies, 
nonfederal users had exclusive licenses to about 30 percent, and 
access to the remaining 52 percent is shared between federal and 
nonfederal users.[Footnote 3] 

Within the federal government, NTIA is responsible for managing the 
federal government's use of the radio frequency spectrum, and the 
Federal Communications Commission (FCC) is responsible for regulating 
nonfederal spectrum use. Currently, there are federal government 
initiatives under way aimed at identifying spectrum that can be made 
available to meet the nation's increased demand for commercial 
wireless broadband services. For example, in March 2010, an FCC task 
force issued the National Broadband Plan recommending that 500 MHz of 
spectrum be made newly available for broadband use within the next 10 
years,[Footnote 4] and in June 2010, the President issued a memorandum 
directing NTIA to begin identifying federal spectrum that can be made 
available for wireless broadband.[Footnote 5] NTIA's ability to 
implement these initiatives is important--specifically its ability to 
identify spectrum needs of federal users, ensure spectrum is being 
used efficiently, and develop policies to strategically meet these 
needs while simultaneously providing federal agencies with adequate 
access to spectrum to conduct their essential missions. 

In response to your request and in light of the recent focus on 
federal use of spectrum, we examined (1) the extent to which NTIA's 
spectrum management oversight and policy addresses governmentwide 
spectrum needs, (2) how federal agencies are using assigned spectrum 
and the extent to which they manage their spectrum use, and (3) what 
steps NTIA and the federal agencies have taken to meet the 
requirements and expectations of the National Broadband Plan and 
presidential memorandum to repurpose spectrum for broadband,[Footnote 
6] and the challenges these efforts face. While the focus of this 
report is on federal use of assigned spectrum, we have ongoing work 
examining FCC's oversight of spectrum used by commercial entities. 
[Footnote 7] Further, we expect to continue reviewing issues related 
to spectrum management in the United States, including what lessons 
have been learned from prior efforts to repurpose spectrum from 
government to commercial entities and the extent to which the 
government is collaborating with the private sector to understand 
their spectrum needs. 

To address these objectives, we obtained and reviewed NTIA documents, 
including its Manual of Regulations and Procedures for the Federal 
Radio Frequency Management (commonly referred to as the Redbook); an 
assessment of spectrum bands that could possibly be repurposed for 
wireless broadband (referred to as the Fast Track Evaluation); and 
other documentation of NTIA's current processes, policies, and 
procedures. To develop an understanding of how federal agencies use 
and manage spectrum, we conducted a Web-based survey of the 19 federal 
agencies comprising the Interdepartment Radio Advisory Committee 
(IRAC), whose agencies hold over 90 percent of federally assigned 
spectrum, and which is responsible for coordinating federal use of 
spectrum and providing NTIA policy advice on spectrum issues. The 
agency officials responding to the survey were top-level spectrum 
managers. We received completed responses from 18 of the 19 IRAC 
members; the results of our survey can be found in appendix III. To 
supplement information from our survey, we obtained documents from and 
interviewed top-level spectrum managers from the following 10 federal 
agencies: Department of Defense (DOD), Department of Homeland 
Security, Department of Labor, Environmental Protection Agency, 
National Oceanic and Atmospheric Administration (NOAA), U.S. Coast 
Guard, Federal Aviation Administration (FAA), Department of Health and 
Human Services, Department of Housing and Urban Development, and 
Department of the Treasury. We selected these federal agencies to 
achieve a mix of characteristics for various factors, such as the 
number of spectrum assignments, representation on IRAC, particular 
band of spectrum holdings, and mission needs. We also interviewed 
officials from NTIA's Office of Spectrum Management about their 
spectrum management policies and procedures and interviewed 
stakeholders with knowledge of spectrum issues including industry and 
academic experts, and representatives of an industry association and 
telecommunications companies. We selected the experts and industry 
stakeholders based on prior published literature, stakeholders' 
recognition and affiliation with the spectrum management industry, and 
NTIA and other stakeholders' recommendations. 

We conducted this performance audit from May 2010 to April 2011 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

The radio frequency spectrum is the part of the natural spectrum of 
electromagnetic radiation lying between the frequency limits of 3 
kilohertz (kHz) and 300 GHz.[Footnote 8] Federal agencies use spectrum 
to help meet a variety of missions, such as national defense, law 
enforcement, weather services, and aviation communication. Nonfederal 
entities (which include commercial companies and state and local 
governments) also use spectrum to provide a variety of services. For 
example, state and local police departments, fire departments, and 
other emergency services agencies use spectrum to transmit and receive 
critical voice and data communications, while commercial entities use 
spectrum to provide wireless services, including mobile voice and 
data, paging, broadcast radio and television, and satellite services. 
See figure 1 for examples of how spectrum is used. 

Figure 1: Examples of Allocated Spectrum Uses, and Federal Spectrum 
Use in the High-Value Range: 

[Refer to PDF for image: illustration] 

Frequency: 3 kHz to 30 kHz; 
Examples of allocated uses: Maritime navigation signals. 

Frequency: 30 kHz to 300 kHz; 
Examples of allocated uses: Navigational aids. 

Frequency: 300 kHz to 3 MHz; 
Examples of allocated uses: AM radio, Maritime radio. 

Frequency: 3 MHz to 30 MHz; 
Examples of allocated uses: Shortwave radio. 

Frequency: 30 MHz to 300 MHz; 
Examples of allocated uses: Broadcast television, FM radio, 
navigational aids. 

Frequency: 300 MHz to 3 GHz; 
Examples of allocated uses: Broadcast television; cellular telephone; 
Space operations and research; Aeronautical radio navigation; Land 
mobile radio; Forest Service communication for law enforcement and 
wild fires; DOD missile detection/survelliance radar; Meteorological 
aids; Meteorological satellites; Maritime mobile satellite and radio 
navigation; Marine animal tracking. 

Frequency: 3 GHz to 30 GHz; 
Examples of allocated uses: Space and satellite communications, 
microwave systems. 

Frequency: 30 GHz to 300 GHz; 
Examples of allocated uses: Radio astronomy. 

Source: GAO analysis of NTIA, federal agencies, and industry 
information. 

[End of figure] 

In the United States, responsibility for spectrum management is 
divided between NTIA and FCC.[Footnote 9] NTIA and FCC jointly 
determine the amount of spectrum allocated for federal, nonfederal, 
and shared use.[Footnote 10] After this allocation occurs, in order to 
use spectrum, nonfederal users must obtain a license from FCC to use 
specific spectrum frequencies, and federal users must obtain a similar 
authorization from NTIA--usually referred to as a frequency 
assignment. In addition to its spectrum allocation and authorization 
duties, NTIA serves as the President's principal advisor on 
telecommunications and information policy and manages federally 
assigned spectrum, including preparing for, participating in, and 
implementing the results of international radio conferences, as well 
as conducting extensive research and technical studies through its 
research and engineering laboratory, the Institute for 
Telecommunication Sciences. NTIA has authority to issue rules and 
regulations as may be necessary to ensure the effective, efficient, 
and equitable use of spectrum both nationally and internationally. It 
also has authority to develop long-range spectrum plans to meet future 
government spectrum requirements, including those of public safety. 

In addition to NTIA and FCC, there are other entities involved in 
spectrum management: 

* The Office of Management and Budget (OMB) is involved in managing 
agency spectrum use through the budget process. OMB's Circular A-11, 
Section 33.4, directs agencies to consider the economic value of 
spectrum when requesting funding to procure a spectrum-dependent 
system. The circular states that spectrum should generally not be 
considered a free resource, but rather should be considered to have 
value and be included, to the extent practical, in economic analyses 
of alternative systems.[Footnote 11] 

* IRAC--an interagency advisory committee--was established in 1922 to 
coordinate federal use of spectrum and provide policy advice on 
spectrum issues. It is comprised of representatives from 19 federal 
agencies that use spectrum. IRAC's mission and placement have evolved 
over its 80-year history. IRAC was originally organized by federal 
agencies that were seeking a way to resolve issues related to federal 
spectrum use in a cooperative manner; its initial mission was to 
assist in the assignment of radio frequencies to federal users and to 
coordinate federal government spectrum use. In 1952, its mission was 
expanded to include formulating and recommending policies, plans, and 
actions for federal government spectrum use. Currently, IRAC is 
primarily involved in the frequency assignment and system 
certification processes and is chaired by NTIA, whose role as chair is 
to call IRAC meetings, establish IRAC agendas, and manage other tasks 
associated with the administrative operations of IRAC. 

* The Commerce Spectrum Management Advisory Committee (CSMAC)--a 
federal advisory committee--provides advice and recommendations to 
NTIA. This advisory committee is organized through NTIA's Office of 
Policy Analysis and Development and was created following a 
recommendation made in President Bush's 21st Century Spectrum Policy 
Initiative.[Footnote 12] CSMAC consists of approximately 25 spectrum 
policy experts from the private sector and it offers expertise and 
perspective on long-range spectrum planning, as well as other issues, 
and makes recommendations to NTIA to facilitate this planning. 
[Footnote 13] CSMAC was organized in 2006, and operates under the 
provisions of the Federal Advisory Committee Act.[Footnote 14] 

Currently, there are three ongoing spectrum-related initiatives aimed 
at identifying spectrum that can be made available to meet the 
nation's demand for commercial wireless broadband services. These 
initiatives include (1) a recommendation in the National Broadband 
Plan, (2) a June 28, 2010, presidential memorandum, and (3) the NTIA 
Fast Track Evaluation. 

* The National Broadband Plan recommends that a total of 500 MHz of 
federally and nonfederally allocated spectrum be made available for 
mobile, fixed, and unlicensed broadband use over the next 10 years. 
This spectrum can come from several different frequency ranges and 
would be made available for a variety of licensed and unlicensed 
flexible commercial uses, as well as to meet the broadband needs of 
specialized users such as public safety, energy, educational, and 
other users. The plan states that for spectrum from the 225 MHz to 3.7 
GHz range, a total of 300 MHz should be made available for mobile 
flexible use within 5 years. 

* On June 28, 2010, the President issued a memorandum directing NTIA 
to begin identifying federally allocated spectrum that can be made 
available for wireless broadband. This memorandum, in line with the 
National Broadband Plan, directs NTIA to collaborate with FCC to 
develop a plan and timetable to make the 500 MHz of federally and 
nonfederally allocated spectrum available for wireless broadband use 
in the next 10 years. 

* A joint request from OMB, the National Economic Council, and the 
White House's Office of Science and Technology Policy requested that 
NTIA identify and make available federally allocated spectrum for 
broadband use in the next 5 years. In response to this request, NTIA 
analyzed federally assigned spectrum to determine the feasibility of 
making certain federally allocated spectrum bands available for 
broadband use, referred to as the Fast Track Evaluation.[Footnote 15] 

In addition, legislation has also been introduced in the House and 
Senate that would help identify spectrum or relocate spectrum for 
commercial uses, including (1) the Spectrum Inventory and Auction Act 
of 2011,[Footnote 16] and the (2) Reforming Airwaves by Developing 
Incentives and Opportunistic Sharing Act,[Footnote 17] which would 
require an inventory of existing users on prime radio frequencies; (3) 
the Spectrum Optimization Act,[Footnote 18] which would provide FCC 
with authority to conduct incentive auctions; and (4) the Spectrum 
Relocation Improvement Act of 2011,[Footnote 19] which would clarify 
the rights and responsibilities of federal users in the spectrum 
relocation process. 

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

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

As the federal agency authorized to develop national spectrum policy, 
[Footnote 20] NTIA has been directed to conduct several projects 
focused on reforming governmentwide federal spectrum management and 
promoting efficiency among federal users of spectrum; however, its 
efforts in this area have resulted in limited progress toward improved 
spectrum management. NTIA has authority to, among other things, 
establish policies concerning assigning spectrum to federal agencies, 
coordinate spectrum use across federal agencies, and promote efficient 
use of spectrum resources by federal agencies in a manner which 
encourages the most beneficial public use. As such, NTIA has a role in 
ensuring that federally allocated spectrum is used efficiently. 
According to NTIA's Redbook and agency officials, efficient use 
includes ensuring that federal agencies' decisions to use spectrum to 
support government missions have been adequately justified and that 
all viable tradeoffs and options have been explored before making the 
decision to use spectrum-dependent technology, and ensuring that these 
tradeoffs are continuously reviewed to determine if the need for 
spectrum has changed over time. NTIA's primary guidance to federal 
agencies is technical guidance concerning how to manage assigned 
spectrum provided through NTIA's Redbook. 

In May 2003, the Bush Administration directed NTIA to develop two 
strategic plans, yet it has only completed one. At that time, the Bush 
Administration launched the Spectrum Policy Initiative for the 21st 
Century, which recognized the rapidly increasing role for wireless 
services and demands on the use of the radio frequency spectrum. In 
response to this initiative, NTIA stated it would produce two plans. 

* First, NTIA would produce a federal strategic spectrum plan to 
address governmentwide spectrum needs. Specifically, the Bush 
Administration directed federal agencies to develop individual 
strategic spectrum plans, which would then be compiled by NTIA along 
with input from other stakeholders such as FCC and state and local 
governments, to form a governmentwide strategic spectrum plan. 
[Footnote 21] 

* Second, NTIA was to use the federal strategic spectrum plan to 
assist in developing a national spectrum plan to address comprehensive 
federal and nonfederal spectrum needs.[Footnote 22] NTIA responded to 
this directive by stating it would produce a national spectrum plan, 
and encourage state, regional, and local government agencies to 
synthesize long-range planning processes into a nonfederal government 
strategic spectrum plan which would also provide input into the 
national strategic spectrum plan. Additionally, NTIA stated that it 
would invite FCC to provide information regarding the future 
requirements of nonfederal government spectrum to be included in the 
national strategic spectrum plan.[Footnote 23] 

In March 2008, NTIA issued its report on federal spectrum use entitled 
The Federal Strategic Spectrum Plan.[Footnote 24] Neither NTIA nor FCC 
has issued the national spectrum plan that was initially scheduled for 
completion in December 2007.[Footnote 25] 

While the intent of the Federal Strategic Spectrum Plan was to 
identify the current and projected spectrum requirements and long-
range planning processes for the federal government, we found the 
final plan is limited in these areas. For example, the plan does not 
identify or include quantitative governmentwide data on federal 
spectrum needs. Instead, NTIA's plan primarily consists of a 
compilation of the plans submitted by 15[Footnote 26] of the more than 
60 agencies that use federal spectrum. Additionally, due to the fact 
that they contained limited information regarding future requirements 
and technology needs, NTIA concluded that its "long-range assumptions 
are necessarily also limited." 

Furthermore, NTIA's plan did not contain key elements and best 
practices of strategic planning, which the Government Performance and 
Results Act, OMB, and we have identified as including the following 
elements:[Footnote 27] 

* identification of long-term goals and objectives, 

* approaches or strategies to achieve these goals and objectives, 

* program evaluations, 

* stakeholder involvement, and: 

* an ongoing process for revising the plan approximately every 3 years. 

For example, NTIA's plan does not include a discussion of long term 
goals and objectives for governmentwide spectrum management, or 
approaches and next steps for achieving these goals. Also, whereas 
strategic planning is intended to be continuous, not a static or 
occasional event, we found that NTIA's strategic planning activities 
are not ongoing. For example, while agencies were required to update 
their strategic plans every 2 years, they have not submitted plans to 
NTIA since November 2007, when 14 agencies submitted plans.[Footnote 
28] 

We found that NTIA does not appear to be meeting its responsibilities 
as directed by President Bush's 2004 memorandum. As shown in appendix 
II, NTIA discontinued many of the governmentwide projects initiated by 
the Spectrum Policy Initiative for the 21st Century, demonstrating a 
lack of continuity in its spectrum management operations. For example, 
NTIA was directed to issue annual progress reports on the status of 
the initiatives. While NTIA issued four annual progress reports from 
fiscal years 2005 through 2008, these reports focused on detailing the 
individual activities agencies have undertaken to improve their 
spectrum management and provided limited information on actions NTIA 
is taking to improve governmentwide use of spectrum. Furthermore, NTIA 
has not issued a progress report since fiscal year 2008.[Footnote 29] 
We asked NTIA officials why the agency was not implementing many of 
the presidential initiatives, and they said due to limited resources 
the agency has decided to put its strategic planning activities on 
hold, and has instead turned its focus to recent initiatives directed 
by the Obama Administration.[Footnote 30] Based on our conversations 
with NTIA officials, it is unclear when or if NTIA will resume its 
forward-looking strategic planning activities. See appendix II for a 
full list of NTIA activities focused on reforming governmentwide 
spectrum management and the status of the activities as of February 
2011. 

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

NTIA's primary spectrum management operations include authorizing 
federal frequency assignments and certifying spectrum-dependent 
equipment for federal users; however, these processes are primarily 
focused on interference mitigation as determined by IRAC and do not 
focus on ensuring the best use of spectrum across the federal 
government.[Footnote 31] IRAC, an interagency committee of the federal 
government's primary spectrum users, includes six subcommittees and 
several ad hoc working groups.[Footnote 32] Two IRAC subcommittees 
play significant roles in two of NTIA's key processes--frequency 
assignment and system certification. These subcommittees, the 
Frequency Assignment Subcommittee (FAS), which includes 
representatives from the 19 IRAC agencies and FCC, and the Spectrum 
Planning Subcommittee (SPS), which includes representatives from 17 of 
the IRAC agencies, review all requests for new spectrum assignments by 
federal agencies and make recommendations to NTIA on the outcomes. 
[Footnote 33] As shown in table 1, final decisions regarding approval 
and use of federally allocated spectrum are made based on IRAC review 
and committee consensus. 

Table 1: Federal Agency, IRAC, and NTIA Roles in the Frequency 
Assignment and System Certification Processes: 

Activity: Frequency assignment process; 
Role of agency requiring/using spectrum: 
* Determine need for spectrum and receive authorization to use a 
specific frequency prior to operating a spectrum-dependent technology; 
* Make necessary technical studies, select potential frequencies, 
coordinate with other agencies involved, and prepare and file an 
application with NTIA's Office of Spectrum Management for 
consideration by the FAS; 
Role of IRAC: 
* FAS considers pending items on a daily basis; 
* Makes decision within 9-days to approve request or table for further 
review, correction, or referral to a formal meeting of the FAS; 
Role of NTIA Office of Spectrum Management: 
* Processes applications through a series of automated routines to 
check them for completeness, accuracy, and compliance with regulations 
in procedures; 
* Publishes applications in daily agenda for FAS review; 
* Conducts manual review, with assistance from FAS, to ensure adequate 
justification, compliance with policy and regulations, and technical 
appropriateness, and to ensure there is no conflict with FAS nonmember 
agencies; 
* Makes final decisions on matters that cannot be resolved within the 
FAS. (Final NTIA decisions can be appealed to the Director of the 
Office of Management and Budget). 

Activity: System certification process; 
Role of agency requiring/using spectrum: 
* As required by OMB Circular A-11, agencies must obtain certification 
by NTIA that the radio frequency required can be made available before 
submission of estimated costs for the development of procurement of 
"major radio spectrum-dependent systems" (including all systems 
employing space satellite techniques); 
* Makes a determination as to whether a system is "major" as defined 
by having a "significant impact on existing or potential future use of 
the radio frequency spectrum," and whether or not to seek 
certification; 
Role of IRAC: 
* SPS conducts review of new spectrum-dependent systems at a number of 
stages of their evolution, prior to the assignment of frequencies. 
These reviews require an examination of the existing systems in the 
frequency bands being considered to ensure that new systems will not 
interfere with existing systems; 
* Makes recommendations to NTIA on whether a new system should be 
certified for operational use; 
Role of NTIA Office of Spectrum Management: 
* Based on SPS recommendation, makes final decision to approve or 
disapprove certification. 

Source: GAO presentation of Redbook policies and additional NTIA and 
agency data. 

[End of table] 

Currently the process as established by federal regulations for review 
and approval of frequency assignment and system certification is 
technical in nature, focusing on ensuring that the new frequency or 
system that an agency wants to use will not interfere with another 
agency's operations. According to NTIA officials, this focus on day-to-
day spectrum activities, such as interference mitigation, is due to 
the agency's limited resources. This focus, while important, makes 
limited consideration about the overall best use of federally 
allocated spectrum. Therefore, NTIA's current processes provide 
limited assurance that federal spectrum use is evaluated from a 
governmentwide perspective to ensure that decisions will meet the 
current and future needs of the agencies, as well as the federal 
government as a whole. Additionally, throughout these processes, there 
is heavy reliance on agencies to self-evaluate and report their 
current and future spectrum needs. For example, in the frequency 
assignment process, all analysis to determine whether spectrum-
dependent technology should be used is made by the agencies prior to a 
request for authorization, therefore agencies are expected to have 
adequate expertise and resources to make these determinations. 

Finally, NTIA has limited ability to monitor federal spectrum use. 
NTIA has four programs in place to oversee agency use of spectrum, yet 
according to NTIA officials, only one program is actively implemented, 
one is conducted on an as-needed basis, and two programs have been 
discontinued due to lack of resources, as shown in table 2. Without 
ongoing programs to monitor that agencies are using their assigned 
spectrum in accordance with federal regulations, NTIA is limited in 
its ability to track how federally allocated spectrum is being used or 
detect Redbook violations. 

Table 2: Status of NTIA Spectrum Oversight Programs: 

Program name: Frequency Assignment Review Program; 
Objective: Federal agencies are required to review frequency 
assignment data every 5 years to ensure that frequency assignments are 
(1) in current use and are correctly reflected in the Government 
Master File (GMF), (2) required for continued operations for the 
purposes stated in their justifications, and (3) still qualified for 
authorizations under the provisions of the Redbook; 
Status: Currently ongoing. 

Program name: Spectrum Measurement Program; 
Objective: Established in 1973 under which a van-mounted Radio 
Spectrum Measurement System operated by NTIA is used to determine (1) 
whether radio installations operated by the federal government are 
using authorized frequencies and are operating in accordance with 
applicable regulations, (2) whether additional uses can be made in a 
particular band at a particular location, and (3) to prevent or 
resolve cases of interference between two or more users; 
Status: Conducted as-needed for research purposes. 

Program name: Spectrum Management Survey Program; 
Objective: Established in 1965 to determine at the operational level 
the degree of implementation of the applicable provisions of the 
Redbook, whether frequency usage is in accordance with authorizations, 
and to exchange information with a view toward improving spectrum 
management. NTIA personnel conduct on-site surveys to observe 
facilities and conduct discussions with local frequency managers; 
Status: Discontinued due to resource constraints. 

Program name: Spectrum Resource Assessment Program; 
Objective: Program to review and document the characteristics and 
deployment of existing and proposed systems, to identify potential 
band-sharing problems which may impact the efficient use of the 
spectrum; 
Status: Discontinued due to resource constraints. 

Source: GAO analysis of NTIA data. 

[End of table] 

NTIA's Data Management System Lacks Transparency and Data Validation 
Processes, Making It Uncertain If Spectrum Management Decisions Are 
Based on Accurate and Complete Data: 

NTIA's data management system is antiquated and lacks transparency and 
internal controls. NTIA collects all federal spectrum data in the 
Government Master File (GMF), which according to NTIA officials is an 
outdated legacy system that was developed primarily to store 
descriptive data. This system does not meet the current analytical 
needs of NTIA or other federal users. NTIA does not generate any data, 
but maintains agency-reported spectrum data in the GMF, which are 
collected during the frequency assignment and review processes, as 
shown in figure 2. 

Figure 2: NTIA Frequency Data Collection Processes: 

[Refer to PDF for image: illustration] 

Frequency assignment application: 

Agency program office: 
Local program office contacts regional spectrum manager or agency 
spectrum manager to request frequency assignment. Program office 
submits request and data describing use and spectrum need to spectrum 
manager. 

Agency spectrum manager: 
Coordinates with program office on spectrum assignment application and 
submits application to NTIA. 

NTIA: 
Coordinates with agency spectrum manager and finalizes spectrum 
assignment application before submitting to FAS. NTIA conducts 
technical checks to ensure data have been entered correctly into 
system and that all necessary fields have been completed. NTIA does 
not validate that data submitted by agency are accurate. 

NTIA: 
NTIA enters data into Government Master File database. 

Frequency assignment review process: 

NTIA: 
NTIA contacts agency spectrum managers notifying them of required 5-
year review. 

Agency spectrum manager: 
Agency spectrum managers notify program office to complete 5-year 
review. Program office must confirm that information in Government 
Master File record is still accurate. 

Agency program office: 
Agency program office completes data review of assignment and updates 
assignment record. Program office sends agency spectrum manager 
updated information. 

Agency spectrum manager: 
Reviews updated information to ensure it is technically complete. 
Federal agencies are not required to validate or verify assignment 
before submitting to NTIA. Information is sent to NTIA. 

NTIA: 
NTIA updates Government Master File to show that record has been 
reviewed and updated. NTIA does not validate that data submitted are 
accurate. NTIA enters data Government Master File. 

NTIA: 
NTIA enters data into Government Master File database. 

Source: GAO analysis of NTIA information. 

[End of figure] 

NTIA's processes for collecting and verifying GMF data lack key 
internal controls including those focused on data accuracy, integrity, 
and completeness. We have defined internal control activities as the 
policies, procedures, techniques, and mechanisms that help ensure that 
agencies mitigate risk.[Footnote 34] Control activities such as data 
verification and reconciliation are essential for ensuring 
accountability for government resources and for achieving effective 
and efficient program results. Additionally, the standards for 
internal controls recommend that agency systems have controls in place 
to ensure data accuracy, including processes for ensuring: 

* the agency's data entry design features contribute to data accuracy; 

* data validation and editing are performed to identify erroneous data; 

* erroneous data are captured, reported, investigated, and promptly 
corrected; and: 

* output reports are reviewed to help maintain data accuracy and 
validity. 

We found that NTIA's data collection processes lack accuracy controls 
and do not provide assurance that data are being accurately reported 
by agencies. For example, the data are generally only subject to 
compliance reviews that ensure all reported data meet technical and 
database parameters (i.e., that they have the proper number of 
characters per field, or that the frequency requested is allocated for 
desired use). Throughout this process, NTIA expects federal agencies 
to supply accurate and up-to-date data submissions. For example, 
during the frequency assignment process, a federal agency must justify 
that the assignment will fulfill an established mission need and that 
other means of communication, such as commercial services, are not 
appropriate or available. However, NTIA does not provide agencies with 
specific requirements on how to justify these needs. NTIA officials 
told us that they rely on federal agencies to conduct any necessary 
analysis, such as engineering and technical studies, to support the 
use and need of the assignment, but agencies are not required to 
submit documentation verifying that the agency had completed the 
analysis necessary to justify the agency's spectrum need. Moreover, 
NTIA does not require federal spectrum managers to validate or verify 
that the data or information program offices do submit is accurate. 
According to NTIA officials, if NTIA or other agencies identify 
errors, NTIA requires the correction of these data. However, since 
agencies submitting data do not have to attest to their accuracy or 
demonstrate the extent to which they are actually using the spectrum 
which they have, NTIA has limited assurance that information used to 
make spectrum management decisions is accurate and reliable. 

NTIA is developing a new data management system--Federal Spectrum 
Management System (FSMS)--to replace GMF. According to NTIA officials, 
the new system will modernize and improve spectrum management 
processes by applying modern information technology to provide more 
rapid access to spectrum and make the spectrum management process more 
effective and efficient. Whereas the GMF is only a descriptive 
database used to store information, it does not have analytical 
capabilities that agencies can use when they are conducting the 
technical studies required by the frequency assignment and 
certification processes. FSMS is intended to provide these analytical 
capabilities and will allow federal agencies to conduct more 
consistent and accurate analysis when developing frequency assignment 
proposals. Ultimately this will facilitate the more efficient use of 
spectrum because frequency assignments can be located closer together. 
Currently, the limited data available on frequency assignments results 
in users overestimating their needs to avoid interference; the 
additional data that will be made available will allow users to make 
more accurate judgments when determining interference.[Footnote 35] As 
part of the development of FSMS, the existing GMF data will be 
replaced with a new data structure, yet development is still early and 
final implementation is not expected until fiscal year 2014. FSMS will 
increase the amount of data agencies are required to submit to NTIA, 
but the data submission process will remain similar to its current 
structure. NTIA projects FSMS will improve existing GMF data quality, 
but not until 2018. According to NTIA's FSMS transition plan, at that 
time data accuracy will improve by over 50 percent. However, in the 
meantime it is unclear whether important decisions regarding current 
and future spectrum needs are based on reliable data. 

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

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

Federal agencies and departments combined have over 240,000 frequency 
assignments, which are used for a variety of purposes, including 
emergency communications, national defense, land management, and law 
enforcement. Over 60 federal agencies and departments currently have 
federal spectrum assignments.[Footnote 36] Agencies and departments 
within DOD[Footnote 37] have the most assignments, followed by FAA, 
the Department of Justice, the Department of Homeland Security, U.S. 
Coast Guard, the Department of the Interior, the Department of 
Agriculture, the Department of Energy, and the Department of Commerce, 
respectively. These federal agencies and departments hold 93 percent 
of all federally assigned spectrum (see figure 3). 

Figure 3: Federal Agencies with the Most Spectrum Assignments: 

[Refer to PDF for image: pie-chart and associated vertical bar graph] 

Federal agencies: 93%: 
Defense (37.37%); 
Federal Aviation Administration (14.73%); 
Justice (9.75%); 
Homeland Security (7.39%); 
Coast Guard (6.29%); 
Interior (6.09%); 
Agriculture (5.49%); 
Energy (3.26%); 
Commerce (2.78%); 
Other: 7%. 

Source: GAO analysis of NTIA GMF spectrum assignment data, September 
7, 2010. 

Note: Other includes the remaining 48 federal agencies and departments 
with spectrum frequency assignments. 

[End of figure] 

As illustrated in figure 4, less than one-third of all frequency 
assignments held by federal agencies are located in the high-valued 
range (generally considered the spectrum bands located above 300 MHz 
and below 3 GHz). In contrast, over 48 percent of the spectrum held by 
federal agencies is located in the 30-300 MHz range. The 18 IRAC 
agencies responding to our survey reported holding some spectrum 
assignments in the high-value range. 

Figure 4: Percent of Federally Assigned Spectrum Located in Various 
Ranges: 

[Refer to PDF for image: pie-chart] 

30.1 MHz–300 MHz: 48.11%; 
300.1 MHz–3 GHz (high-value range): 29.05%; 
0–30 MHz: 13.17%; 
3.1 GHz–300 GHz: 9.66%. 

Source: GAO analysis of NTIA GMF spectrum assignment data, September 
7, 2010. 

Note: In addition, two agencies hold assignments above 300 GHz. 
Because these assignments comprise of less than 1 percent of all 
assignments held by federal agencies, they were not included in the 
figure. Totals do not add up to 100 percent due to rounding. 

[End of figure] 

Through our survey and interviews with federal agency officials, we 
found that federal agencies use spectrum, including high-valued 
spectrum, for a wide array of purposes. As illustrated in figure 5, 
IRAC agencies reported using federally assigned spectrum for emergency 
communications, managing and protecting federal property or personnel, 
law enforcement, research, and safety. As an example of use in the 
high-value range, the Department of the Air Force reported in response 
to our survey using spectrum for mission-critical military training 
and education, testing of new equipment, research and development, and 
disaster response, in concert with other agencies. 

Figure 5: Number of Surveyed IRAC Agencies Reporting Various Types of 
Spectrum Use: 

[Refer to PDF for image: horizontal bar graph] 

Type of use: Emergency communication; 
Number of IRAC agencies: 17. 

Type of use: Management and protection of federal property or 
personnel; 
Number of IRAC agencies: 16. 

Type of use: Safety; 
Number of IRAC agencies: 14. 

Type of use: Research; 
Number of IRAC agencies: 14. 

Type of use: Law enforcement; 
Number of IRAC agencies: 14. 

Type of use: Weather; 
Number of IRAC agencies: 12. 

Type of use: Transportation; 
Number of IRAC agencies: 12. 

Type of use: Environmental data collection and dissemination; 
Number of IRAC agencies: 12. 

Type of use: Natural Resource management, protection, and conservation; 
Number of IRAC agencies: 11. 

Type of use: National security; 
Number of IRAC agencies: 9. 

Type of use: National defense; 
Number of IRAC agencies: 8. 

Type of use: Civil defense; 
Number of IRAC agencies: 7. 

Type of use: Broadcasting; 
Number of IRAC agencies: 7. 

Type of use: Space exploration; 
Number of IRAC agencies: 3. 

Type of use: Power utilities transmission and distribution of 
utilities; 
Number of IRAC agencies: 3. 

Type of use: Postal operations; 
Number of IRAC agencies: 1. 

Source: GAO survey. 

[End of figure] 

Federal agencies also operate a variety of spectrum-dependent systems 
and equipment on assigned spectrum. Within the high-value range (300 
MHz-3 GHz), IRAC agencies reported operating a wide variety of 
systems. The most frequently reported systems in that range included 
land mobile radio systems, fixed microwave systems, and fixed 
microwave point-to-point radio systems. These systems are typically 
used for voice and data communication and while they can be operated 
in other frequency bands outside of the high-value range, this range 
includes the most commonly used frequencies for these systems. 

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

NTIA has not established specific requirements for agencies to justify 
their needs and to validate and verify data used to evaluate their 
current and future spectrum needs. Federal spectrum managers we 
contacted reported that when applying for an assignment, they 
generally request field program staff to provide a description of how 
the frequency will be used and the type of equipment needed for the 
assignment. One federal agency official told us that his office has to 
trust that assignment application information provided by program 
staff is accurate. Additionally, 6 out of the 10 federal spectrum 
managers we contacted told us that while they review an application 
before submitting it to NITA, their review primarily serves to ensure 
that sufficient information has been provided to meet the requirements 
of the Redbook. For example, a federal agency official told us that 
when examining a frequency assignment application, some of the factors 
that he reviews are availability of spectrum to be used with a 
specific technology, potential for interference with other users, and 
compliance of frequency use with NTIA rules and regulations. 

As part of NTIA's Frequency Assignment Review Program, federal 
spectrum users are required to modify or delete frequency assignments 
as needed based on the results of the 5-year reviews.[Footnote 38] 
However, as with the assignment process, federal spectrum managers are 
not required to validate or verify that the information the program 
offices are submitting is accurate. Seven out of 10 federal spectrum 
managers we contacted reported that they do not have mechanisms in 
place to verify the accuracy of the information collected during these 
processes. Similarly, 5 out of 10 federal spectrum managers reported 
that their agency had not conducted site visits or sample surveys to 
verify information in their data systems. 

Further, federal agency officials expressed various concerns related 
to the process of obtaining information from field program staff when 
completing assignment reviews, including concerns about (1) the future 
availability of spectrum, (2) inaccurate data on existing systems, and 
(3) resource constraints and staff coordination. 

Future Availability of Spectrum: 

* In our survey, 15 out of 18 IRAC agencies reported that they will 
face some or great difficulty in the future meeting their critical 
mission needs because of insufficient spectrum. 

* Similarly, 4 out of the 10 federal spectrum managers we contacted 
told us that while their agency's spectrum needs are increasing, 
requesting new assignments is becoming increasingly difficult due to 
the limited availability of additional spectrum. According to these 
spectrum managers, field program personnel are concerned that if they 
say they are no longer using an assignment, it will be deleted and the 
program office will not be able to obtain another assignment for their 
future spectrum needs. In one specific example, a federal spectrum 
manager we contacted told us that the agency's border security duties 
have increased significantly over the last few years, resulting in the 
agency's increased use and dependence on spectrum for security 
purposes. However, while the agency's spectrum needs have increased, 
the availability of spectrum has remained the same, raising concerns 
about the agency's access to sufficient spectrum to complete 
operational mission requirements. 

Inaccurate Data on Existing Systems: 

* Of the three agencies we contacted that had previously completed 
site visits or in-depth reviews of assignment data, federal agency 
officials from two of these agencies reported uncovering significant 
inaccuracies in their assignment records. For example, officials from 
one agency told us that in a recent review of a sample of spectrum 
assignments in the Detroit, Michigan, metropolitan area, they 
uncovered that approximately half of the agency's assignment records 
were inaccurate. In another example, a spectrum manager told us that 
the agency conducted a review of spectrum assignments and found that 
25 percent of assignments in one department (20 assignments) were no 
longer being used. As a result of this review, the agency returned the 
assignments. Because the other federal agencies we interviewed did not 
indicate that they had completed site surveys or in-depth reviews of 
their assignment records, the extent to which there are data errors in 
other agencies' assignment data is unknown. 

* One agency we met with had difficulty ascertaining whether a program 
office was operating a system on an assignment. In this case, the 
agency relocated several systems off of the 1710-1755 MHz band as a 
result of the Advance Wireless Services auction in 2007.[Footnote 39] 
Shortly after the relocation, the agency was contacted by a commercial 
wireless carrier that had acquired the frequency informing the agency 
that it still had a system transmitting on the frequency, causing 
interference. The agency contacted its regional program office and 
discovered that a transmitter at the identified location had not been 
actively used by the agency for years but was emitting a carrier 
signal, which was the source of the interference. Once the transmitter 
was shut off the interference on that frequency stopped. According to 
the agency's spectrum manager, regional program officials never 
notified the agency about the system's existence, and as a result, 
there was no record of the system in the agency's inventory list. 
Agency officials acknowledged that had they not been contacted by the 
commercial wireless carrier, they would not have known that the 
transmitter was still operating and sending out a carrier signal. 

* While OMB Circular No. A-11, §33.4 and NTIA require that federal 
agencies obtain an authorization to use a spectrum frequency 
assignment before they purchase spectrum-dependent systems, 5 out of 
10 agency spectrum managers that we contacted reported that their 
agency does not have procedures in place to monitor the agency's 
procurement of spectrum-dependent systems prior to obtaining an 
assignment. 

Resource Constraints and Staff Coordination: 

* Seven out of 10 spectrum managers explained that due to high staff 
turnover, identifying the appropriate contacts in the field to 
complete assignment reviews can be difficult. One federal spectrum 
manager explained that since field program staff are generally located 
in multiple offices across the country, it is challenging to keep 
track of all the appropriate contacts in each office every 5 years. 
Some spectrum managers also noted that resource constraints limit 
their ability to validate information obtained from program staff. 
Specifically, through our interviews and IRAC survey, spectrum 
managers told us that competing mission priorities limit their ability 
to verify the accuracy of information obtained from program offices. 
One survey respondent stated that a key challenge to completing 
frequency assignment reviews is balancing available spectrum 
management resources with other competing priorities. Another spectrum 
manager stated that validating and verifying the information for each 
assignment record, which could entail conducting site visits or 
surveys, would require significant spectrum management resources that 
federal agencies do not currently have. 

* Five out of 10 spectrum managers reported difficulties ensuring that 
program offices communicated with them before purchasing a spectrum- 
dependent system. Federal officials from one agency told us that 
approximately 30 percent of the time, program offices at the agency 
procure spectrum-dependent equipment without first notifying the 
agency spectrum managers, and in some cases, before the assignment has 
been granted. 

* In another example, a spectrum manager reported that a program 
office purchased a spectrum-dependent system to operate on an 
assignment before receiving authorization to operate on the frequency. 
The frequency assignment application was eventually denied because the 
program office had purchased a system that could not be operated on 
federally assigned spectrum and the agency had to place the equipment 
in storage where it remained unused. 

NTIA Has Taken Steps to Identify Spectrum for Future Wireless 
Broadband Use, yet NTIA and Federal Agencies Will Face Challenges in 
Analyzing and Repurposing This Spectrum: 

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

In response to the recent initiatives to make a total of 500 MHz of 
spectrum available for wireless broadband, NTIA has (1) identified 115 
MHz of federally allocated spectrum to be made available for wireless 
broadband use within the next 5 years, referred to as the Fast Track 
Evaluation, and (2) developed an initial plan and timetable for 
repurposing additional spectrum for broadband, referred to as the 10- 
Year Plan.[Footnote 40] 

Fast Track Evaluation. NTIA and the Policy and Plans Steering Group 
(PPSG)[Footnote 41] identified and recommended portions of two 
frequency bands, totaling 115 MHz of spectrum within the ranges of 
1695-1710 MHz and 3550-3650 MHz to be made available for wireless 
broadband use. In November 2010, NTIA publicly released its results. 
In its final report, NTIA summarized its analysis of four frequency 
bands: 1675-1710 MHz, 1755-1780 MHz, 3500-3650 MHz, and 4200-4400 MHz. 
For these bands, NTIA reviewed the number of federal frequency 
assignments within the band, the types of federal operations and 
functions that the assignments support, and the geographic location of 
federal use. Additionally, NTIA applied the following criteria to 
identify the 115 MHz of spectrum: 

* the band must be able to be made available within 5 years, 

* the band must be between 225 MHz and 4400 MHz, 

* the decision to recommend bands for repurposing could be made prior 
to October 1, 2010 (therefore due to time constraints decisions would 
not require relocation of federal users), and: 

* opportunities for geographic or other sharing within the bands must 
have already been successfully proven. 

Since clearing these bands of federal users and relocating incumbent 
federal users to new bands was not an option in the given time frame, 
the bands that NTIA recommended be made available will be opened to 
geographic sharing[Footnote 42] by incumbent federal users and 
commercial broadband. 

10-Year Plan. By a presidential memorandum, NTIA was directed to 
collaborate with FCC to make available 500 MHz of spectrum over the 
next 10 years, suitable for both mobile and fixed wireless broadband 
use, and complete by October 1, 2010, a specific plan and timetable 
for identifying and making available the 500 MHz for broadband use. 
NTIA publicly released this report in November 2010.[Footnote 43] In 
total, NTIA and the National Broadband Plan identified 2,264 MHz of 
spectrum to analyze for possible repurposing, of which 639 MHz is 
exclusively used by the federal government and will be analyzed by 
NTIA. Additionally, NTIA will collaborate with FCC to analyze 835 MHz 
of spectrum that is currently located in bands that are shared by 
federal and nonfederal users. Furthermore, NTIA has stated that it 
plans to seek advice and assistance from CSMAC, its federal advisory 
committee comprised of industry representatives and experts, as it 
conducts analyses under the 10-Year Plan. 

NTIA officials said that they will prioritize the bands identified for 
evaluation based on the factors in table 3, with the bands that best 
fulfill this criteria being evaluated for potential repurposing first. 
Following prioritization, NTIA, with the assistance of the federal 
agencies, will characterize each band to determine the extent of 
federal use in the band. After each band is characterized, further 
analysis will be conducted to evaluate the technical, operational, and 
cost effects that repurposing would have on the federal agencies. 

Table 3: NTIA Criteria for Prioritizing and Characterizing Candidate 
Bands in the 10-Year Plan: 

Prioritization criteria: 
1. Amount of usable bandwidth and contiguous spectrum within band; 
2. Industry interest in band and expected auction[A] revenue; 
3. Indirect benefits to the economy; 
4. Availability of spectrum for relocation of incumbent federal users; 
5. Estimated costs of relocating federal incumbent users; 
6. Impact to global services that would require international 
reallocation; 
7. Likelihood the band can be repurposed in 10 years. 

Characterization criteria: 
1. Description of how the band is currently being used; 
2. Number and types of different federal systems operating in the band; 
3. Number of federal agencies in the band; 
4. Measure or description of the complexity of federal systems in the 
band; 
5. Number and types of nonfederal incumbent users in the band; 
6. Degree to which repurposing might impact federal services and 
operations. 

Source: NTIA. 

[A] Spectrum 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. 

[End of table] 

In January 2011, NTIA announced that it had selected the 1755-1850 MHz 
band as the first priority for detailed evaluation under the 10-Year 
Plan. According to NTIA, this band was given top priority for 
evaluation by NTIA and the federal agencies, based on a variety of 
factors, including industry interest and the band's potential for 
commercial use within 10 years. Agencies currently operating in this 
band have been notified of the pending evaluation, and NTIA and PPSG 
have identified comparable bands for agency operations. Affected 
agencies are now conducting analyses to determine which of these 
comparable bands best meets their needs and will provide NTIA with 
their input in spring 2011. According to NTIA officials, a decision on 
how to proceed with its analysis will be made in June 2011. This is 
not the first time NTIA has studied these bands. These bands were 
previously evaluated for reallocation, and in 2001, we reported that 
at the time adequate information was not currently available to fully 
identify and address the uncertainties and risks of reallocation. 
[Footnote 44] 

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

Affected federal agencies reported difficulties in providing the 
impact analysis required for NTIA's Fast Track Evaluation, raising 
concerns that larger scale future analysis may be impacted. The 
evaluation required Navy, NOAA, and FAA to analyze and submit a 
significant amount of detailed impact analyses that were not readily 
available, according to officials with those agencies. Further, 
Department of the Navy and U.S. Marine Corps officials said they were 
required to conduct analyses based on a number of different scenarios 
to determine what the impact might be for mission performance by 
making various spectrum bands available for wireless broadband. 
According to one Navy official, while DOD collects a large amount of 
data on its spectrum-dependent systems, NTIA's request required DOD to 
conduct a time-consuming, in-depth analysis on the operational impact 
of repurposing certain spectrum bands. NTIA officials recognize that 
completing this analysis required significant agency resources, but 
they noted that agencies were the only ones with the requisite 
expertise to complete the analysis. 

In response to our survey, the Department of the Navy and the 
Department of the Air Force expressed concerns over data accuracy as a 
result of the short time frame given to them to collect the data. 
[Footnote 45] One official stated that the speed of identifying 
available spectrum appeared more important than the accuracy of the 
data. According to a DOD official, these data requests were time- 
consuming because they required regional spectrum managers to identify 
and contact all field program offices using spectrum-dependent systems 
in the band being analyzed to determine their use of spectrum and how 
their mission performance would be affected if the band were no longer 
available for federal use. Four IRAC agencies that completed our 
survey--NOAA, Department of the Air Force, Department of the Navy, and 
Department of the Army--expressed further concerns about the resources 
required to collect spectrum data for the Fast Track Evaluation. 

In addition to the challenges that federal agencies reported in 
gathering data, making the 115 MHz of spectrum available for wireless 
broadband will have operational effects on agencies. For example, 
according to NTIA's Fast Track Evaluation, as a result of the decision 
to make the 1695-1710 MHz band available for wireless broadband, NOAA 
will have to redesign its next generation of Geostationary Operational 
Environmental Satellite-R series (GOES-R) satellites.[Footnote 46] 
According to NOAA, this redesign will increase costs and delay 
implementation. Additionally, NTIA does not expect DOD to experience 
any immediate operational impacts due to the repurposing of the 3550- 
3650 MHz band; however, such a repurposing based on exclusion zones 
will limit DOD's future flexibility to implement new systems or 
operate at new locations. As table 4 illustrates, NOAA and DOD will be 
the primary agencies affected by the decision to make this spectrum 
available. 

Table 4: Status and Outcome of Bands Evaluated for Fast Track 
Repurposing: 

Band[A]: 1675-1710 MHz; 
Primary agency operating in band[B]: NOAA; 
Primary use: Meteorological aid and satellite service; 
NTIA decision: Make a portion of the band available to wireless 
broadband access within 5 years; 
(1695-1710 MHz); 
Challenges federal agencies, industry, and NTIA will face: Delays and 
costs associated with redesigning next generation of GOES-R satellites. 
Exclusion zones surrounding satellite downlink stations may reduce 
industry interest. Band is not used internationally for mobile 
broadband. Will require international agreement at 2016 World Radio 
Conference; 
Potential impacts reported by agencies: NOAA will redesign the GOES-R 
emergency weather satellite downlink transmission planned for 1697.4 
MHz to a frequency below 1695 MHz. 

Band[A]: 1755-1780 MHz; 
Primary agency operating in band[B]: Multiple; 
Primary use: Multiple; 
NTIA decision: NTIA could not reach a conclusion as to whether the 
band could be made available for broadband use within 5 years. NTIA 
will continue to analyze the issue as part of 10 year plan. 
Challenges federal agencies, industry, and NTIA will face: An industry 
priority but not rigorously analyzed by NTIA as part of the Fast Track 
Evaluation and not selected to be made available for wireless 
broadband; 
Potential impacts reported by agencies: Might require relocation of 
incumbent federal users. 

Band[A]: 3500-3650 MHz; 
Primary agency operating in band[B]: DOD; 
Primary use: Navy shipboard radar and DOD land training facilities; 
NTIA decision: Will make portion of the band available to wireless 
broadband access within 5 years; (3550-3650 MHz); 
Challenges federal agencies, industry, and NTIA will face: Will limit 
future flexibility of DOD to implement new systems and operate in new 
locations. Minimal industry interest in bands above 3 GHz for mobile 
broadband applications; 
Potential impacts reported by agencies: Does not require alteration of 
current military operations. May limit ability to expand operations. 

Band[A]: 4200-4220 and 4380-4400 MHz; 
Primary agency operating in band[B]: Multiple--FAA manages band; 
Primary use: Radio altimeters on aircraft (civil and government); 
NTIA decision: Cannot make available for broadband use within 5 years. 
Will begin taking action now to gain international agreement by 2016. 
Challenges federal agencies, industry, and NTIA will face: 
Reallocation would require international agreement and reconfiguration 
on civil and government aircraft. FAA has not reported complete usage 
data for altimeters in this band; 
Potential impacts reported by agencies: FAA will have to coordinate a 
study to determine if use of altimeters can be prevented in band 
segments. Will require international reallocation. 

Source: GAO analysis of NTIA data. 

[A] The 1675-1710, 3500-3560, 4200-4220 and 4380-4400 MHz bands were 
identified by NTIA with advice from the PPSG. The 1755-1780 MHz band 
was identified in the National Broadband Plan for potential 
reallocation to allow for nonfederal broadband use. In January 2011, 
NTIA announced that it would evaluate the 1755-1850 MHz bands as part 
of the 10-Year Plan. 

[B] Although multiple agencies operate on each of these bands, we have 
listed only the primary agencies operating in each band that have 
regulatory authority over the band. 

[End of table] 

Further, data- and resource-related challenges could affect 
implementation of NTIA's 10-Year Plan. As experienced in previous 
relocations, inaccurate and incomplete data submitted by agencies can 
impact the transition time from federal to commercial use once 
reallocated spectrum has been auctioned by FCC and purchased by 
commercial users. During the relocation of federal users as a result 
of the Advance Wireless Service spectrum auction in 2006, according to 
a winning bidder of the spectrum, some agencies submitted inaccurate 
inventory data to NTIA and OMB causing delays in the transition from 
federal to commercial use. As previously discussed, federal agencies 
faced resource challenges in providing NTIA data on system inventory, 
operational use, and operational impacts. These challenges raise 
concerns because the Fast Track Evaluation focused on only 115 MHz of 
spectrum, while NTIA is now expecting to evaluate 1,474 MHz of 
spectrum, meaning these challenges could be magnified. 

Without adequate and timely funding for agencies to conduct research 
and planning, the goals of the 10-Year Plan and timetable may not be 
achieved. In previous auctions, as part of the Commercial Spectrum 
Enhancement Act (CSEA),[Footnote 47]agencies have been reimbursed for 
their relocation costs through the Spectrum Relocation Fund.[Footnote 
48] CSEA does not provide agencies with up-front funding to conduct 
detailed analysis during the spectrum evaluation phase. The lack of 
funding may delay analysis and band characterization for repurposing, 
as agencies have limited staff and resources to dedicate to data 
collection and band analysis. This can be problematic because agencies 
have reported significant costs associated with collecting the data 
and conducting the analysis requested by NTIA. For example, a DOD 
official told us he committed 400 staff hours to collecting 
operational impact data for the Fast Track Evaluation for two affected 
DOD systems; under the 10-Year Plan, the official expects to have to 
collect and prepare operational impact data for 120 systems. To 
address this funding issue, NTIA stated in the Fast Track Evaluation 
analysis that changes to expand the CSEA would be needed to provide 
agencies with up-front funding for analysis and planning related to 
repurposing. According to NTIA officials, without this funding, 
agencies will not be able to conduct adequate analysis for the 10-Year 
Plan, and currently NTIA does not have a plan to address these 
challenges if this funding is not made available. 

Industry Stakeholders Expressed Concerns with the Usefulness of the 
Identified Spectrum: 

Industry stakeholders, including wireless service providers, 
representatives of an industry association, and a think tank 
representative we contacted expressed concerns over the usefulness of 
the spectrum identified by NTIA in the Fast Track Evaluation, since 
most of the spectrum identified (100 of the 115 MHz) is outside the 
range considered to have the best propagation characteristics for 
mobile broadband.[Footnote 49] Overall, there has been limited 
interest in the bands above 3 GHz for mobile broadband use because, 
according to industry stakeholders, there have been minimal 
technological developments for mobile broadband in bands above 3 GHz 
and no foreseeable advances in this area at this time. 

According to industry representatives, the 1755-1780 MHz band that 
NTIA considered as part of the Fast Track Evaluation has the best 
characteristics for mobile broadband use, and it is internationally 
harmonized for this use. NTIA did not select this band to be made 
available in the 5-year time frame due to the large number of federal 
users currently operating there. Recently, however, NTIA has 
identified it as the first band to be analyzed under the 10-Year Plan 
to determine if it can be made available for commercial broadband use. 

An industry stakeholder has stated that the 1695-1710 MHz band 
identified by NTIA in the Fast Track Evaluation is the second-best 
alternative for wireless broadband if the 1755-1780 MHz band were not 
made available; however, the 1695-1710 MHz band is not currently used 
internationally for wireless broadband, which may reduce device 
manufacturers' incentive for developing technology that can be used in 
these frequencies. Additionally, an industry stakeholder also 
expressed concern over the exclusion zones established by NTIA in the 
1695-1710 MHz band, which would make the band unavailable for wireless 
broadband in select major cities across the United States that account 
for over 12 percent of the U.S. population. Similarly, one industry 
stakeholder has also noted that the exclusion zones NTIA has 
established for the 3550-3650 MHz band would prevent wireless 
broadband access along the entire East and West coasts. Considering 
the geographic exclusion zones and the location of the spectrum above 
3 GHz, an industry stakeholder we contacted said that they are not as 
immediately interested in this spectrum as they are in the 1755-1780 
MHz band, which, according to one industry stakeholder, may impact 
future spectrum auction prices. On March 8, 2011, FCC released a 
Public Notice seeking comment on steps the Commission can take to best 
promote wireless broadband deployment in the 1695-1710 MHz and 3550-
3650 MHz bands. Amongst other things, FCC sought comment on the extent 
to which these bands could be made available for broadband deployment; 
how the conditions placed on the bands, such as the exclusion zones, 
could affect their usefulness for broadband deployment; and whether 
broadband technologies are readily available to operate on these 
bands.[Footnote 50] 

While spectrum auctions can generate substantial funds for the U.S. 
Treasury--for example, the Advance Wireless Services auction that took 
place in September 2006 fetched over $13.7 billion, a portion of which 
went to the U.S. Treasury--if industry participants are not as 
interested in the spectrum being auctioned, lower bids would be 
expected. Agencies are currently reimbursed with funding from auction 
revenue for data collection, analysis, and planning-related costs, 
after costs for relocating federal users have been paid. Lack of 
industry interest in spectrum above 3 GHz creates concerns as to 
whether large amounts of spectrum will be able to meet the minimum 
price at auction, which the CSEA has set at 110 percent of federal 
relocation costs. Since relocating federal users is likely as part of 
the 10-Year Plan, if the reserve is not met, agencies may not be 
reimbursed for their data collection, analysis, and planning costs. As 
previously stated, NTIA officials have raised concerns that without 
this funding, agencies will not be able to conduct adequate analysis 
for the 10-Year Plan. Currently NTIA does not have a plan to address 
these challenges if this funding is not made available. 

Conclusions: 

Radio frequency spectrum is a scarce national resource that enables 
wireless communications services vital to the U.S. economy and to a 
variety of government functions, yet NTIA has not developed a 
strategic, governmentwide vision for managing federal use of this 
valuable resource. NTIA's spectrum management authority is broad in 
scope, but NTIA's efforts do not align with its authorities. Its focus 
is on the technical aspects of spectrum management, such as ensuring 
new frequency assignments will not cause interference to spectrum- 
dependent devices already in use, rather than on whether new 
assignments should be approved based on a comprehensive evaluation of 
federal spectrum use from a governmentwide perspective. NTIA officials 
noted that due to limited resources, the agency has put its strategic 
planning activities on hold and has instead turned its focus to recent 
initiatives directed by the Obama Administration. However, lacking an 
overall strategic vision, NTIA cannot ensure that spectrum is being 
used efficiently by federal agencies. 

Agencies are supposed to review all their spectrum assignments every 5 
years and delete any assignments not essential to their missions; 
however, we found that these reviews are often perfunctory. 
Furthermore, agencies have concerns about not having access to 
sufficient spectrum in the future to meet mission-critical needs and 
therefore might be reluctant to relinquish any assignments for fear 
they will be unable to get more spectrum in the future. The absence of 
requirements for agencies to submit justifications for their spectrum 
use combined with NTIA's limited oversight of the agencies has led to 
decreased accountability and transparency in how federal spectrum is 
actually being used and whether the spectrum-dependent systems the 
agencies have in place are necessary. However, federal agency 
officials face challenges--such as staff turnover and resource 
constraints--when coordinating with field program staff to obtain the 
information necessary for the frequency assignment applications and 
reviews. Given that verifying the information for each frequency 
assignment record could require significant spectrum management 
resources that federal agencies might not currently have, it would be 
beneficial for NTIA to consider options for a different approach to 
obtain critical assignment information from the agencies. Approaches 
may include efforts such as requiring agencies to conduct site surveys 
of their spectrum-dependent systems, attesting to the accuracy of the 
data provided to NTIA, or making changes to the structure of the 5-
year review program. 

As part of its spectrum management processes, NTIA depends primarily 
on an antiquated data collection system and does not have a mechanism 
in place to validate and verify the accuracy of spectrum-related data 
submitted by the federal agencies. The data management system also 
lacks transparency and internal controls, which are essential for 
ensuring accountability for government resources and for achieving 
effective and efficient results. Although NTIA is developing its new 
FSMS, full implementation is still years away. In the meantime, 
without meaningful data validation requirements, NTIA has limited 
assurance that the agency-reported data it collects are accurate and 
complete. As NTIA begins the arduous task of identifying 500 MHz of 
spectrum that can be repurposed for broadband services, incomplete or 
inaccurate data might adversely impact NTIA's ability to make sound 
decisions regarding the current and future spectrum needs of agencies. 

Recommendations for Executive Action: 

To facilitate the effective governmentwide management of federal 
spectrum use, the Assistant Secretary of Commerce for Communications 
and Information should take the following actions: 

* To ensure NTIA's previous efforts to develop a federal strategic 
plan are not diminished, develop an updated plan that includes key 
elements of a strategic plan, as well as information on how spectrum 
is being used across the federal government, opportunities to increase 
efficient use of federally allocated spectrum and infrastructure, an 
assessment of future spectrum needs, and plans to incorporate these 
needs in the frequency assignment, equipment certification, and review 
processes. 

* To help ensure federal agencies are managing current and future 
spectrum assignments efficiently, in consultation with IRAC, examine 
the 5-year assignment review processes and consider best practices to 
determine if the current approach for collecting and validating data 
from federal agencies can be streamlined or improved. 

* To provide the assurance that accurate and reliable data on federal 
spectrum use are collected, take interim steps to establish internal 
controls for management oversight of the accuracy and completeness of 
currently reported agency data. In developing the new Federal Spectrum 
Management System, incorporate adequate internal controls for 
validating the accuracy of agency-reported information submitted 
during the assignment, certification, and frequency assignment review 
processes. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of Commerce for 
its review and comment. Commerce provided written comments, which are 
reprinted in appendix IV. 

In commenting on the draft report, Commerce noted that as the spectrum 
manager for federal users, NTIA has several spectrum management 
duties, such as fulfilling federal agency spectrum requirements, 
preventing interference among federal users, and undertaking other 
spectrum-related assignments or initiatives related to federally 
assigned spectrum. According to Commerce, given funding limitations 
and resource constraints, NTIA must determine how to prioritize its 
various spectrum-related responsibilities without impairing its 
primary mission of responding to agencies' spectrum assignment 
requests in a timely manner. 

With respect to our recommendations, Commerce concurred with one and 
partially concurred with the other two. Specifically, Commerce 
concurred with our recommendation to examine the 5-year assignment 
review processes and consider best practices to determine if the 
current approach can be improved. Commerce stated that NTIA, in 
consultation with IRAC, would review the current assignment process 
with agencies to determine what improvements could be implemented. 
Commerce partially concurred with our recommendation to develop an 
updated strategic plan, stating that NTIA will have to weigh updating 
strategic plans against other spectrum management needs and directives 
and determine priorities. Commerce agreed that key elements of 
strategic planning are central to NTIA's work, but stressed that given 
funding limitations, NTIA must consider our recommendation in light of 
its other spectrum-related obligations and fundamental spectrum 
mission. We recognize that NTIA has been tasked with responding to 
other spectrum management directives, but lacking an overall strategic 
vision, NTIA cannot ensure that its spectrum management decisions 
reflect the overall best use of federally allocated spectrum. 
Moreover, without an understanding of how spectrum is being used 
across the federal government, NTIA cannot ensure that spectrum is 
being used efficiently by federal agencies or that spectrum management 
decisions will meet the current and future needs of the agencies, as 
well as the federal government as a whole. We believe a strategic plan 
is a key element for NTIA to respond to recent directives from the 
President regarding repurposing spectrum assigned to federal agencies 
for commercial broadband. Commerce also partially concurred with our 
recommendation related to establishing internal controls for 
management oversight of currently reported agency data, noting its 
concurrence to the extent that such controls could be adopted with 
existing and anticipated resources. Commerce stated that NTIA would 
take steps to establish internal controls for federal spectrum use 
data and work with agencies to determine what new processes could be 
implemented that would lead to more accurate and reliable data, 
including the establishment of procedures for agency validation of 
submitted data. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
appropriate congressional committees and the Secretary of Commerce. In 
addition, the report will be available at no charge on the GAO Web 
site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-2834 or goldsteinm@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Contact information and major 
contributors to this report are listed on appendix V. 

Signed by: 

Mark L. Goldstein: 
Director, Physical Infrastructure Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report focuses on the federal use of spectrum and examines (1) 
the extent to which the National Telecommunications and Information 
Administration's (NTIA) spectrum management oversight and policy 
addresses governmentwide spectrum needs: 

To determine the extent to which NTIA's spectrum management oversight 
and policy addresses governmentwide spectrum needs, we examined 
documents, consulted relevant spectrum literature, and conducted 
interviews. Specifically, we reviewed NTIA's Manual of Regulations and 
Procedures for the Federal Radio Frequency Management (commonly 
referred to as the Redbook) and other documentation of NTIA's current 
processes, policies, and procedures to determine (1) NTIA's legal 
authorities for managing federal users of spectrum, (2) how NTIA works 
with federal agencies to manage spectrum, (3) how NTIA collects data 
on federal agency spectrum assignments and usage, (4) limitations, if 
any, with NTIA's current procedures for collecting data on federal 
agency spectrum assignments and usage, and (5) NTIA's actions, if any, 
to address these limitations. We also reviewed NTIA's data collection 
procedures and policies to ensure the data reliability of information 
contained in the Government Master File (GMF) database. In addition, 
we interviewed representatives from NTIA's Office of Spectrum 
Management to gather information about their spectrum management 
policies and procedures. We also interviewed or obtained written 
comments from a variety of experts and industry stakeholders, 
including academics, industry representatives, and think-tank 
organizations (as shown in table 5) to obtain their views on options 
available for increasing the efficiency of federal spectrum use and 
management and associated tradeoffs. We selected the experts and 
industry stakeholders to interview based on prior published 
literature, stakeholders' recognition and affiliation with spectrum 
management industry, and NTIA and other stakeholders' recommendations. 
Finally, we conducted a literature review of spectrum studies. Our 
literature search covered studies published from 2005 onward and was 
largely drawn from major electronic databases in telecommunications, 
academic, economics, and other fields (e.g., SNL Kagan, EconLit, 
Academic OneFile, ProQuest, and other databases) and from our past 
work on spectrum-related issues. We used the studies obtained from 
this literature review to obtain background information on spectrum 
issues. 

Table 5: List of Experts and Industry Stakeholders We Contacted: 

Stakeholder groups: Academic experts; 
Stakeholder: Stanford Institute for Economic Policy Research.
Stakeholder: Interdisciplinary Telecommunications Program, University 
of Colorado. 

Stakeholder groups: Think tank research; 
Stakeholder: Open Technology Initiative at New America Foundation.
Stakeholder: Public Knowledge. 

Stakeholder groups: Industry stakeholders; 
Stakeholder: Shared Spectrum.
Stakeholder: CTIA, the Wireless Association.
Stakeholder: Verizon.
Stakeholder: Motorola.
Stakeholder: T-Mobile.
Stakeholder: AT&T. 

Source: GAO. 

[End of table] 

To identify how federal agencies use assigned spectrum and the extent 
to which agencies manage their spectrum use we conducted a Web-based 
survey of all 19 Interdepartment Radio Advisory Committee (IRAC) 
federal agency representatives. We surveyed federal agencies on the 
IRAC because these agencies collectively hold over 90 percent of all 
federally assigned spectrum. The survey was conducted from November 1, 
2010, to January 21, 2011. The survey included questions on (1) how 
federal agencies use spectrum assignments; (2) federal agency 
interaction with NTIA; (3) federal agencies' spectrum management 
policies and procedures; (4) the extent to which federal agencies 
share spectrum with other users and use of commercial services; and 
(5) federal agencies' views on the extent to which agencies have the 
resources and information they need to manage their spectrum. The 
results of our survey can be found in appendix III. 

We received completed responses from 18 of the 19 IRAC 
representatives, for a 95 percent response rate. We did not receive a 
completed survey from the Department of State IRAC representative 
despite our multiple attempts to obtain the information. Because we 
selected a nonprobability sample of federal agencies with assigned 
spectrum to survey, the information we obtained from the survey may 
not be generalized to all federal agencies with assigned spectrum. 
However, because the IRAC member agencies that we included in our 
sample survey hold the vast majority of all federally assigned 
spectrum, the information we gathered from these agencies provided us 
with a general understanding of federal agencies' spectrum management 
policies. In addition, we took steps in the development of the survey, 
the data collection, and the data analysis to minimize nonsampling 
errors. For instance, a survey specialist designed the survey and the 
draft survey was pre-tested with IRAC representatives from three 
federal agencies. We conducted these pre-tests to ensure that (1) the 
questions and possible responses were clear and thorough, (2) 
terminology was used correctly, (3) questions did not place an undue 
burden on the respondents, (4) the information was feasible to obtain, 
and (5) the questionnaire was comprehensive and unbiased. On the basis 
of the feedback from the three pre-tests we conducted, we made changes 
to the content and format of the survey questions. 

To supplement data obtained from the survey and to gather in-depth 
information on the roles and responsibilities of federal agencies in 
managing their assigned spectrum, we obtained documents from and 
conducted interviews with a sample of federal agencies to provide 
detailed examples of how federal agencies are managing their spectrum. 
We prepared comprehensive profiles for each of these agencies which 
included data from our IRAC survey, our review of federal agency 
planning documents including federal agencies' spectrum management 
policies and procedures and strategic spectrum plans, other 
literature, and structured interviews with spectrum management 
officials at selected federal agencies. The agencies we met with 
included the Department of Defense, Department of Homeland Security, 
Department of Labor, Environmental Protection Agency, National Oceanic 
and Atmospheric Administration, the U.S. Coast Guard, Federal Aviation 
Administration, Health and Human Services, Housing and Urban 
Development, and the Department of the Treasury. We selected federal 
agencies for our comprehensive profiles to achieve a mix of the 
following characteristics: 

* large spectrum holdings (more than 5,000 assignments) and small 
spectrum holdings (less than 1,000 assignments); 

* IRAC and non-IRAC member agencies to ensure that we had 
representative views from both groups; and: 

* assignments located in different spectrum bands and used for 
different mission needs. 

We also consulted internal stakeholders, experts, associations, and 
NTIA officials to assist us in identifying potential agencies to 
interview. Although using these criteria allowed us to obtain 
information from a diverse mix of federal agencies, the findings from 
our in-depth profiles cannot be generalized to all federal agencies 
because they were selected as part of a non-probability sample. 

To determine what steps NTIA and federal agencies have taken to meet 
the requirements and expectations of the June 28, 2010, presidential 
memorandum and what challenges these efforts will face, we reviewed 
pertinent documents related to their efforts, such as NTIA's 
Assessment of Spectrum Bands That Could Possibly be Repurposed for 
Wireless Broadband (referred to as the Fast Track Evaluation) and 10-
Year Plan. We also conducted interviews with NTIA and federal agency 
officials. Through our interviews, we collected up to date information 
on actions being taken to make spectrum available for wireless 
broadband including information on what criteria NTIA is using to make 
these decisions, how NTIA and federal agencies are collaborating on 
identifying spectrum, and what potential challenges they may face in 
reallocating federal spectrum. We also contacted four wireless service 
providers to obtain their viewpoints and opinions on (1) NTIA's 
process and methodology for identifying additional spectrum to be made 
available for commercial broadband use, (2) the level of private 
sector demand for the spectrum identified by NTIA, and (3) the 
potential value of spectrum that NTIA has identified for analysis as 
part of its Fast Track Evaluation and 10-Year Plan. 

We conducted this performance audit from May 2010 to April 2011 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

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

Project: Improve stakeholder participation and maintain high 
qualifications of spectrum managers; 
Task: 1. Establish a Commerce Spectrum Management Advisory Committee 
(CSMAC); 
Deliverable: Establish CSMAC; 
Target date: May 2005; 
Status as of February 2011: Completed on time; 
Task: 2. Establish a high-level interagency group; 
Deliverable: Establish PPSG; 
Target date: January 2005;
Status as of February 2011: Completed on time;
Task: 3. Resolve intergovernmental spectrum disputes through the 
existing White House Policy Coordinating Committee (PCC) and process 
and revise the NTIA/FCC Memorandum of Understanding (MOU) to provide 
an additional minimum 15 business days to accommodate the PCC process; 
Deliverable: MOU between NTIA and FCC to provide additional minimum 15 
business days to accommodate PCC process; 
Target date: March 2006; 
Status as of February 2011: NTIA submitted proposed MOU language to 
FCC in May 2008; 
incomplete with no anticipated date for completion; 
Task: 4. Expand the role of FCC Defense Commissioner; 
Deliverable: MOU between NTIA and FCC to expand the role of FCC 
Defense Commissioner; 
Target date: March 2006; 
Status as of February 2011: NTIA submitted revised proposed language 
to FCC in May 2008; Incomplete with no anticipated date for completion; 
Task: 5. Promote a career development program and spectrum management 
training; 
Deliverable: No deliverables; 
Target date: September 2007; 
Status as of February 2011: Program reactivated in Jan. 2008. 

Project: Reduce International Barriers to U.S. Innovations in 
Technologies and Services; 
Task: 1. Improve U.S. preparations for World Radio Communication 
Deliverable: Study and recommendations on improvements to U.S. 
preparations; 
Target date: May 2005; 
Status as of February 2011: Completed on time; 
Task: 2. Improve international spectrum management and regulatory 
environment; 
Deliverable: Study and recommendations on impact of international 
spectrum management policies and regulatory environment; 
Target date: June 2006; 
Status as of February 2011: Report issued in 2008. 

Project: Modernize Federal Spectrum Management Processes with Advanced 
Information Technology; 
Task: 1.Implement advanced information management system; 
Deliverable: The Federal Spectrum Management. System will utilize 
advanced information technology to develop a Web-based process for 
preparing and processing applications for system certification and 
frequency assignments. It will consolidate existing paper-based and 
multiple software systems, including Spectrum XXI and El-Cid; 
Target date: Ongoing; 
Status as of February 2011: Ongoing project; 
system will be developed by a contract system integrator in 
conjunction with NTIA staff and with input from the federal agency 
user community. 

Project: Satisfy Public Safety Communication Needs and Ensure 
Interoperability; 
Task: 1. Spectrum sharing between federal and nonfederal agencies; 
Deliverable: Assessment of feasibility of spectrum sharing between 
federal and nonfederal public safety entities; 
Target date: December 2006; 
Status as of February 2011: Completed Report on Federal/nonfederal 
spectrum and infrastructure sharing and published Jun.2007. 

Project: Enhance Spectrum Engineering and Analytical Tools; 
Task: 1. Develop analytical approaches, software tools, and 
engineering techniques for evaluating and improving the efficiency and 
effectiveness of federal spectrum use; 
Deliverable: A series of reports that make recommendations for 
improving spectrum efficiency. Develop a Spectrum-efficiency 
recommendations report that includes an approach and time frame for 
implementing the recommendations;
Target date: September 2007; 
Status as of February 2011: Incomplete with no anticipated date for 
completion. 

Task: 2. Develop and promote recognition in the spectrum management 
community for best practices in spectrum engineering; 
Deliverable: Best Practices Handbook; 
Target date: November 2007; 
Status as of February 2011: Incomplete with no anticipated date for 
completion. 

Task: 3. Conduct a pilot program to evaluate approaches and techniques 
to increase spectrum sharing between federal and nonfederal spectrum 
users; 
Deliverable: Establish, conduct, and evaluate results of use of 
devices and technologies to facilitate sharing through Spectrum 
Sharing Innovation Test-Bed; 
Target date: Pilot program to be completed by June 2006; 
results and recommendations of the pilot program are to be completed 
by September 2008; 
Status as of February 2011: Stage 1 testing Started in 2[ND] Quarter 
2009. Results and recommendations not reported. 

Task: 4. Develop and promote the use of modern analytic tools for 
spectrum engineering; 
Deliverable: Prepare initial spectrum management models and tools 
catalog for use by federal spectrum users; 
Target date: December 2006; 
Status as of February 2011: Incomplete with no anticipated date for 
completion. 

Project: Promote Efficient and Effective Use of Spectrum; 
Task: 1. Improve the technical planning process; 
Deliverable: Recommendations for changes to the NTIA Manual with 
respect to the Spectrum Certification process; 
Target date: December 2006; 
Status as of February 2011: Incomplete with no anticipated date for 
completion. 

Project: Improve Long-term Planning and Promote Use of Market-based 
Economic Mechanisms in Spectrum; 
Task: 1. Improve the processes for federal agencies' spectrum planning 
and produce a national spectrum plan; 
Deliverable: Federal Strategic Spectrum Plan published biannually; 
National Strategic Spectrum Plan; 
Target date: Federal Strategic Spectrum Plan to be completed by May 
2006;National Spectrum Plan to be completed by December 2007; 
Status as of February 2011: Federal Strategic Spectrum Plan published 
in March 2008; letter to FCC seeking participation in National 
Strategic Spectrum Plan sent in June 2008; incomplete with no 
anticipated date for completion. 

Task: 2. Improve federal agencies' processes and procedures to better 
consider the economic value of spectrum when investing in spectrum-
dependent systems; 
Deliverable: Guidance to the federal agencies on compliance with 
Section 33.4 of OMB Circular A-11 on considering spectrum value when 
seeking funding for major spectrum-dependent systems; 
Target date: Not stated--OMB added section 33.4 to Circular A-11 in 
November 2004; 
Status as of February 2011: Completed by OMB in November 2004; 

Task: 3. Develop a plan to identify and implement incentives for 
improving efficiency in federal agencies' spectrum use; 
Deliverable: Guidance to the federal agencies concerning integration 
of spectrum planning with capital and strategic planning; Incentives 
Implementation Plan; workshop on economic and other incentives for 
efficient use of spectrum; study on international practices with 
respect to incorporation of market mechanisms into spectrum management; 
Target date: November 2005; 
Status as of February 2011: Incentives Implementation Plan forwarded 
to the White House in March 2006 and Published in November 2008; 
workshop on the use of economic or other incentives to increase the 
efficiency in federal agencies' spectrum use conducted in February 
2006; unpublished study examining international practices that 
incorporate market mechanisms into more efficient spectrum use 
completed in 2006. 

Task: 4. Promote the implementation of a wide range of incentives to 
improve the efficiencies of both government and private sector 
spectrum use; 
Deliverable: Contractor-produced study providing unit of consumption 
for spectrum use; revised structure for current OSM cost-recovery fee 
for federal agency spectrum use; study on federal spectrum value and 
development of fees to promote efficient use of spectrum; draft 
legislation to implement spectrum use fees; study on sharing between 
federal agencies and nonfederal unlicensed systems; study on federal 
spectrum rights; proposals to provide federal agency more flexible 
rights with respect to spectrum to enable sharing with other federal 
agencies and nonfederal entities; 
Target date: Not stated; 
Status as of February 2011: Incomplete with no anticipated date for 
completion. 

Source: GAO review of NTIA data. 

[End of table] 

[End of section] 

Appendix III: Survey of IRAC Agencies: 

The questions we asked in our survey of IRAC agencies are shown below. 
Our survey was comprised of closed-and open-ended questions. In this 
appendix, we include all the survey questions and aggregate results of 
responses to the closed-ended questions; we do not provide information 
on responses provided to the open-ended questions. For a more detailed 
discussion of our survey methodology see appendix I. 

Background Information: 

1. Which Interdepartment Radio Advisory Committee (IRAC) agency do you 
represent? 

Broadcasting Board of GoverNors; 
Response: Yes. 

Department of Agriculture; 
Response: Yes. 

Department of Commerce; 
Response: Yes. 

Department of Energy; 
Response: Yes. 

Department of Homeland Security; 
Response: Yes. 

Department of Justice; 
Response: Yes. 

Department of Air Force; 
Response: Yes. 

Department of Army; 
Response: Yes. 

Department of the Interior; 
Response: Yes. 

Department of the Navy; 
Response: Yes. 

Department of Treasury; 
Response: Yes. 

Department of Transportation; 
Response: Yes. 

Department of Veterans Affairs; 
Response: Yes. 

Federal Aviation Administration; 
Response: Yes. 

National Aeronautics and Space Administration; 
Response: Yes. 

National Science Foundation; 
Response: Yes. 

United States Coast Guard; 
Response: Yes. 

United States Postal Service; 
Response: Yes. 

Department of State; 
Response: No. 

[End of table] 

2. What component agency or department do you work for? 

[Open-ended] 

3. What is your job title? 

[Open-ended] 

4. Please briefly describe your key responsibilities as they relate to 
spectrum management. 

[Open-ended] 

5. Do you have other responsibilities in addition to spectrum 
management? If so, please describe. 

[Open-ended] 

6. How long have you been working in federal spectrum management? 
(Please include in your estimate experience throughout your career not 
just in your current position): 

5 years to less than 10 years; 
Percent: 27.78. 

10 years to less than 15 years; 
Percent: 22.22. 

20 years or more; 
Percent: 50.00. 

Federal Agency Frequency Assignments: 

7. Currently, how many frequency assignments in each of the following 
frequency band ranges does the IRAC agency you represent have? 

[Open-ended] 

8. For what general purpose does the IRAC agency you represent use 
spectrum assigned in the 300 MHz to 3 GHz range? If you do not have 
any spectrum assigned in the 300 MHz to 3 GHz range, please skip toQ9: 

[Open-ended] 

9. For the IRAC agency you represent, which of the following usage 
categories has your assigned spectrum been designated? (Select one for 
each row.) 

Question: 9a. Broadcasting; 
Response: Yes: 7; 
Response: No: 10; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 9b. Civil defense; 
Response: Yes: 7; 
Response: No: 9; 
Response: Don't know: 1; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 9c. Emergency communication; 
Response: Yes: 17; 
Response: No: 1; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9d. Environmental data collection and dissemination; 
Response: Yes: 12; 
Response: No: 5; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 9e. Law enforcement; 
Response: Yes: 14; 
Response: No: 4; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9f. Management and protection of federal property or 
personnel; 
Response: Yes: 16; 
Response: No: 1; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

Question: 9g. National defense; 
Response: Yes: 8; 
Response: No: 9; 
Response: Don't know: 1; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9h. National security; 
Response: Yes: 9; 
Response: No: 8; 
Response: Don't know: 1; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9i. Natural resources management, protection, and 
conservation; 
Response: Yes: 11; 
Response: No: 6; 
Response: Don't know: 1; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9j. Postal operations; 
Response: Yes: 1; 
Response: No: 17; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9k. Power utilities transmission and distribution of 
utilities; 
Response: Yes: 3; 
Response: No: 15; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9l. Research; 
Response: Yes: 14; 
Response: No: 4; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9m. Safety; 
Response: Yes: 14; 
Response: No: 4; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9n. Space exploration; 
Response: Yes: 3; 
Response: No: 14; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

Question: 9o. Transportation; 
Response: Yes: 12; 
Response: No: 6; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9p. Weather; 
Response: Yes: 12; 
Response: No: 6; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 9q. Other; 
Response: Yes: 7; 
Response: No: 5; 
Response: Don't know: 1; 
Response: No response/not applicable: 4; 
Total responses: 17. 

[End of table] 

The next series of questions asks about the types of technologies your 
agency operates within specific spectrum band ranges. 

10. For the IRAC agency you represent, please indicate whether your 
agency operates fixed microwave systems within any of these frequency 
ranges. (select one for each row): 

Question: 10a. Below 3 kHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 10b. 3.1 - 30 kHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 10c. 30.1 - 300 kHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 10d. 300.1 - 3 MHz; 
Response: Yes: 1; 
Response: No: 15; 
Response: No response/not applicable: 1; 
Total responses: 17. 

Question: 10e. 3.1 - 30 MHz; 
Response: Yes: 2; 
Response: No: 15; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 10f. 30.1 - 300 MHz; 
Response: Yes: 3; 
Response: No: 14; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 10g. 300.1 MHz - 3 GHz; 
Response: Yes: 14; 
Response: No: 4; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 10h. 3.1 GHz - 30 GHz; 
Response: Yes: 15; 
Response: No: 3; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 10i. 30.1 GHz - 300 GHz; 
Response: Yes: 7; 
Response: No: 11; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 10j. Above 300 GHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 1; 
Total responses: 17. 

[End of table] 

11. For the IRAC agency you represent, please indicate whether your 
agency operates fixed transportable systems within any of these 
frequency ranges. (select one for each row): 

Question: 11a. Below 3 kHz; 
Response: Yes: 1; 
Response: No: 15; 
Response: No response/not applicable: 1; 
Total responses: 17. 

Question: 11b. 3.1 - 30 kHz; 
Response: Yes: 2; 
Response: No: 14; 
Response: No response/not applicable: 1; 
Total responses: 17. 

Question: 11c. 30.1 - 300 kHz; 
Response: Yes: 2; 
Response: No: 14; 
Response: No response/not applicable: 1; 
Total responses: 17. 

Question: 11d. 300.1 - 3 MHz; 
Response: Yes: 8; 
Response: No: 8; 
Response: No response/not applicable: 1; 
Total responses: 17. 

Question: 11e. 3.1 - 30 MHz; 
Response: Yes: 7; 
Response: No: 9; 
Response: No response/not applicable: 1; 
Total responses: 17. 

Question: 11f. 30.1 - 300 MHz; 
Response: Yes: 11; 
Response: No: 6; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

Question: 11g. 300.1 MHz - 3 GHz; 
Response: Yes: 12; 
Response: No: 4; 
Response: No response/not applicable: [Empty]; 
Total responses: 16. 

Question: 11h. 3.1 GHz - 30 GHz; 
Response: Yes: 10; 
Response: No: 6; 
Response: No response/not applicable: 1; 
Total responses: 17. 

Question: 11i. 30.1 GHz - 300 GHz; 
Response: Yes: 3; 
Response: No: 13; 
Response: No response/not applicable: 1; 
Total responses: 17. 

Question: 11j. Above 300 GHz; 
Response: Yes: [Empty]; 
Response: No: 17; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

[End of table] 

12. For the IRAC agency you represent, please indicate whether your 
agency operates land mobile radio systems within any of these 
frequency ranges. select one for each row): 

Question: 12a. Below 3 kHz; 
Response: Yes: [Empty]; 
Response: No: 17; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 12b. 3.1 - 30 kHz; 
Response: Yes: [Empty]; 
Response: No: 17; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 12c. 30.1 - 300 kHz; 
Response: Yes: 1; 
Response: No: 16; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 12d. 300.1 - 3 MHz; 
Response: Yes: 4; 
Response: No: 14; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 12e. 3.1 - 30 MHz; 
Response: Yes: 7; 
Response: No: 11; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 12f. 30.1 - 300 MHz; 
Response: Yes: 18; 
Response: No: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 12g. 300.1 MHz - 3 GHz; 
Response: Yes: 18; 
Response: No: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 12h. 3.1 GHz - 30 GHz; 
Response: Yes: 2; 
Response: No: 16; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 12i. 30.1 GHz - 300 GHz; 
Response: Yes: [Empty]; 
Response: No: 18; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 12j. Above 300 GHz; 
Response: Yes: [Empty]; 
Response: No: 18; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

[End of table] 

13. For the IRAC agency you represent, please indicate whether your 
agency operates maritime mobile radio systems within any of these 
frequency ranges. (select one for each row): 

Question: 13a. Below 3 kHz; 
Response: Yes: [Empty]; 
Response: No: 15; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 13b. 3.1 - 30 kHz; 
Response: Yes: 1; 
Response: No: 14; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 13c. 30.1 - 300 kHz; 
Response: Yes: 1; 
Response: No: 13; 
Response: No response/not applicable: 3; 
Total responses: 17. 

Question: 13d. 300.1 - 3 MHz; 
Response: Yes: 6; 
Response: No: 10; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 13e. 3.1 - 30 MHz; 
Response: Yes: 6; 
Response: No: 10; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 13f. 30.1 - 300 MHz; 
Response: Yes: 10; 
Response: No: 6; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 13g. 300.1 MHz - 3 GHz; 
Response: Yes: 5; 
Response: No: 11; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 13h. 3.1 GHz - 30 GHz; 
Response: Yes: 1; 
Response: No: 15; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 13i. 30.1 GHz - 300 GHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 13j. Above 300 GHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

[End of table] 

14. For the IRAC agency you represent, please indicate whether your 
agency operates fixed microwave point to point radio systems within 
any of these frequency ranges. (select one for each row): 

Question: 14a. Below 3 kHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 14b. 3.1 - 30 kHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 14c. 30.1 - 300 kHz; 
Response: Yes: [Empty]; 
Response: No: 15; 
Response: No response/not applicable: 2; 
Total responses: 17. 

Question: 14d. 300.1 - 3 MHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 14e. 3.1 - 30 MHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 14f. 30.1 - 300 MHz; 
Response: Yes: 2; 
Response: No: 14; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 14g. 300.1 MHz - 3 GHz; 
Response: Yes: 14; 
Response: No: 4; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 14h. 3.1 GHz - 30 GHz; 
Response: Yes: 14; 
Response: No: 4; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 14i. 30.1 GHz - 300 GHz; 
Response: Yes: 2; 
Response: No: 16; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 14j. Above 300 GHz; 
Response: Yes: [Empty]; 
Response: No: 18; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

[End of table] 

15. For the IRAC agency you represent, please indicate whether your 
agency operates digital microwave systems within any of these 
frequency ranges. (select one for each row): 

Question: 15a. Below 3 kHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 15b. 3.1 - 30 kHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 15c. 30.1 - 300 kHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 15d. 300.1 - 3 MHz; 
Response: Yes: [Empty]; 
Response: No: 16; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 15e. 3.1 - 30 MHz; 
Response: Yes: [Empty]; 
Response: No: 15; 
Response: No response/not applicable: 2; 
Total responses: 17. 

Question: 15f. 30.1 - 300 MHz; 
Response: Yes: 1; 
Response: No: 15; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 15g. 300.1 MHz - 3 GHz; 
Response: Yes: 11; 
Response: No: 7; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 15h. 3.1 GHz - 30 GHz; 
Response: Yes: 15; 
Response: No: 3; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 15i. 30.1 GHz - 300 GHz; 
Response: Yes: 4; 
Response: No: 14; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 15j. Above 300 GHz; 
Response: Yes: [Empty]; 
Response: No: 18; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

[End of table] 

16. For the IRAC agency you represent, please indicate whether your 
agency operates satellite systems within any of these frequency 
ranges. (select one for each row): 

Question: 16a. Below 3 kHz; 
Response: Yes: [Empty]; 
Response: No: 15; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 16b. 3.1 - 30 kHz; 
Response: Yes: [Empty]; 
Response: No: 15; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 16c. 30.1 - 300 kHz; 
Response: Yes: [Empty]; 
Response: No: 15; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 16d. 300.1 - 3 MHz; 
Response: Yes: [Empty]; 
Response: No: 15; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 16e. 3.1 - 30 MHz; 
Response: Yes: [Empty]; 
Response: No: 15; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 16f. 30.1 - 300 MHz; 
Response: Yes: 5; 
Response: No: 9; 
Response: No response/not applicable: 3; 
Total responses: 17. 

Question: 16g. 300.1 MHz - 3 GHz; 
Response: Yes: 10; 
Response: No: 6; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 16h. 3.1 GHz - 30 GHz; 
Response: Yes: 10; 
Response: No: 6; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 16i. 30.1 GHz - 300 GHz; 
Response: Yes: 5; 
Response: No: 11; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 16j. Above 300 GHz; 
Response: Yes: 1; 
Response: No: 15; 
Response: No response/not applicable: 2; 
Total responses: 18. 

[End of table] 

Spectrum Management Resources: 

17. For the IRAC agency you represent, what is/was the federal 
agency's budget for managing spectrum for each of the following years? 
(Note: for this question, do not include administrative fees paid to 
NTIA.) 

[Open-ended] 

18. For the IRAC agency you represent, how much did you pay NTIA in 
administrative fees for each of the following years? 

[Open-ended] 

19. In general, how satisfied or dissatisfied is the IRAC agency you 
represent with the following resources available at your agency to 
manage spectrum? (select one for each row): 

Question: 19a. Number of staff at your agency working on spectrum 
management issues; 
Response: Very satisfied: 3; 
Response: Somewhat satisfied: 4; 
Response: Neither satisfied nor dissatisfied: 2; 
Response: Somewhat dissatisfied: 7; 
Response: Very dissatisfied: 2; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 19b. Funding available for spectrum management purposes; 
Response: Very satisfied: 3; 
Response: Somewhat satisfied: 4; 
Response: Neither satisfied nor dissatisfied: 3; 
Response: Somewhat dissatisfied: 5; 
Response: Very dissatisfied: 3; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 19c. Ability to collect data on your spectrum use; 
Response: Very satisfied: 3; 
Response: Somewhat satisfied: 7; 
Response: Neither satisfied nor dissatisfied: 4; 
Response: Somewhat dissatisfied: 3; 
Response: Very dissatisfied: [Empty]; 
Response: Don't know: 1; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 19d. In-house technical expertise on spectrum management 
issues; 
Response: Very satisfied: 11; 
Response: Somewhat satisfied: 5; 
Response: Neither satisfied nor dissatisfied: 2; 
Response: Somewhat dissatisfied: [Empty]; 
Response: Very dissatisfied: [Empty]; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 19e. Access to technical expertise outside of your agency 
(i.e., technical consultants, experts at other agencies); 
Response: Very satisfied: 5; 
Response: Somewhat satisfied: 6; 
Response: Neither satisfied nor dissatisfied: 5; 
Response: Somewhat dissatisfied: [Empty]; 
Response: Very dissatisfied: [Empty]; 
Response: Don't know: 1; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 19f. Research at your agency dedicated to improving 
interference issues; 
Response: Very satisfied: 2; 
Response: Somewhat satisfied: 6; 
Response: Neither satisfied nor dissatisfied: 5; 
Response: Somewhat dissatisfied: 3; 
Response: Very dissatisfied: [Empty]; 
Response: Don't know: 1; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 19g. Spectrum management training opportunities; 
Response: Very satisfied: 4; 
Response: Somewhat satisfied: 4; 
Response: Neither satisfied nor dissatisfied: 5; 
Response: Somewhat dissatisfied: 3; 
Response: Very dissatisfied: 2; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 19h. Agency specific spectrum management guidance; 
Response: Very satisfied: 5; 
Response: Somewhat satisfied: 5; 
Response: Neither satisfied nor dissatisfied: 5; 
Response: Somewhat dissatisfied: 1; 
Response: Very dissatisfied: [Empty]; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 19i. Other; 
Response: Very satisfied: [Empty]; 
Response: Somewhat satisfied: [Empty]; 
Response: Neither satisfied nor dissatisfied: [Empty]; 
Response: Somewhat dissatisfied: [Empty]; 
Response: Very dissatisfied: 1; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 11; 
Total responses: 12. 

[End of table] 

20. What additional resources, if any, would the IRAC agency you 
represent like to have to manage your spectrum? 

[Open-ended] 

NTIA Guidance and Coordination: 

21. Excluding the guidance you received from NTIA's Manual of 
Regulations and Procedures for Federal Radio Frequency Management (the 
Redbook), how satisfied or dissatisfied are you with the current 
quality of the other NTIA guidance you receive to manage your federal 
spectrum? (select one for each row): 

Question: 21a. Conducting spectrum usage measurements of your assigned 
spectrum; 
Response: Very satisfied: 2; 
Response: Somewhat satisfied: 1; 
Response: Neither satisfied nor dissatisfied: 5; 
Response: Somewhat dissatisfied: 1; 
Response: Very dissatisfied: [Empty]; 
Response: Guidance not provided: 8; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 21b. Determining your agency's current spectrum needs; 
Response: Very satisfied: 1; 
Response: Somewhat satisfied: 5; 
Response: Neither satisfied nor dissatisfied: 2; 
Response: Somewhat dissatisfied: 2; 
Response: Very dissatisfied: [Empty]; 
Response: Guidance not provided: 7; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 21c. Determining your agency's future spectrum needs; 
Response: Very satisfied: 1; 
Response: Somewhat satisfied: 3; 
Response: Neither satisfied nor dissatisfied: 3; 
Response: Somewhat dissatisfied: 2; 
Response: Very dissatisfied: [Empty]; 
Response: Guidance not provided: 8; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 21d. Submitting data to NTIA's Government Master File 
database; 
Response: Very satisfied: 4; 
Response: Somewhat satisfied: 6; 
Response: Neither satisfied nor dissatisfied: 3; 
Response: Somewhat dissatisfied: 1; 
Response: Very dissatisfied: 3; 
Response: Guidance not provided: [Empty]; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 21e. Completing your agency's biennial federal spectrum 
strategic plan; 
Response: Very satisfied: [Empty]; 
Response: Somewhat satisfied: 7; 
Response: Neither satisfied nor dissatisfied: 7; 
Response: Somewhat dissatisfied: [Empty]; 
Response: Very dissatisfied: [Empty]; 
Response: Guidance not provided: 1; 
Response: No response/not applicable: 2; 
Total responses: 17. 

Question: 21f. Completing the spectrum certification process for a new 
or upgraded spectrum system; 
Response: Very satisfied: 3; 
Response: Somewhat satisfied: 6; 
Response: Neither satisfied nor dissatisfied: 2; 
Response: Somewhat dissatisfied: 4; 
Response: Very dissatisfied: 2; 
Response: Guidance not provided: [Empty]; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 21g. Addressing interference issues; 
Response: Very satisfied: 4; 
Response: Somewhat satisfied: 6; 
Response: Neither satisfied nor dissatisfied: 4; 
Response: Somewhat dissatisfied: 1; 
Response: Very dissatisfied: 1; 
Response: Guidance not provided: 1; 
Response: No response/not applicable: 1; 
Total responses: 18. 

[End of table] 

22. To what extent, if at all, does the IRAC agency you represent 
coordinate with NTIA on the following spectrum management issues? 
(select one for each row): 

Question: 22a. Obtaining new frequency assignments; 
Response: Great extent: 14; 
Response: Moderate extent: 4; 
Response: Some or little extent: [Empty]; 
Response: No extent: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 22b. Completing the spectrum certification process for a new 
or upgraded spectrum system; 
Response: Great extent: 10; 
Response: Moderate extent: 4; 
Response: Some or little extent: 2; 
Response: No extent: [Empty]; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 22c. Addressing interference issues; 
Response: Great extent: 2; 
Response: Moderate extent: 8; 
Response: Some or little extent: 6; 
Response: No extent: 2; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 22d. Coordinating sharing agreements with other entities; 
Response: Great extent: 3; 
Response: Moderate extent: 6; 
Response: Some or little extent: 8; 
Response: No extent: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

Question: 22e. Other; 
Response: Great extent: [Empty]; 
Response: Moderate extent: [Empty]; 
Response: Some or little extent: [Empty]; 
Response: No extent: [Empty]; 
Response: No response/not applicable: 9; 
Total responses: 9. 

[End of table] 

23. What comments or concerns, if any, do you have with NTIA's efforts 
to identify and make available 500 MHz of spectrum suitable for both 
mobile and fixed wireless broadband use? 

[Open-ended] 

Agency Management and Planning Processes and Procedures: 

24. Does the IRAC agency you represent have internal policies, 
protocols, or procedures in place to complete the following spectrum 
management activities. (select one for each row): 

Question: 24a. conducting the 5-year reviews of your federal agency's 
frequency assignments reflected in the Government Master File (GMF) 
Database; 
Response: Yes, protocols or procedures are in place: 17; 
Response: No, protocols or procedures are not in place: [Empty]; 
Response: No, protocols or procedures are not in place, but agency is 
in the process of developing protocols or procedures: 1; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 24b. conducting internal reviews of your federal agency's 
future spectrum needs; 
Response: Yes, protocols or procedures are in place: 10; 
Response: No, protocols or procedures are not in place: 4; 
Response: No, protocols or procedures are not in place, but agency is 
in the process of developing protocols or procedures: 4; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 24c. conducting measurements of actual spectrum use (such as 
geographic location of use, and duration and extent of use); 
Response: Yes, protocols or procedures are in place: 6; 
Response: No, protocols or procedures are not in place: 1; 
Response: No, protocols or procedures are not in place, but agency is 
in the process of developing protocols or procedures: 10; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 24d. collecting and maintaining data on how your agency uses 
spectrum; 
Response: Yes, protocols or procedures are in place: 12; 
Response: No, protocols or procedures are not in place: 4; 
Response: No, protocols or procedures are not in place, but agency is 
in the process of developing protocols or procedures: 2; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 24e. using spectrum efficient technologies; 
Response: Yes, protocols or procedures are in place: 9; 
Response: No, protocols or procedures are not in place: 5; 
Response: No, protocols or procedures are not in place, but agency is 
in the process of developing protocols or procedures: 3; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 24f. coordinating spectrum use across program offices/ 
departments within your agency; 
Response: Yes, protocols or procedures are in place: 15; 
Response: No, protocols or procedures are not in place: [Empty]; 
Response: No, protocols or procedures are not in place, but agency is 
in the process of developing protocols or procedures: 2; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 24g. Other; 
Response: Yes, protocols or procedures are in place: 2; 
Response: No, protocols or procedures are not in place: [Empty]; 
Response: No, protocols or procedures are not in place, but agency is 
in the process of developing protocols or procedures: 1; 
Response: No response/not applicable: 9; 
Total responses: 12. 

[End of table] 

25. Within the last 5 years, how many applications for frequency 
assignments has your agency submitted to the Frequency Assignment 
Subcommittee (FAS)? 

[Open-ended] 

26. Within the last 5 years, how many spectrum certification 
applications for major spectrum dependent systems has your agency 
submitted to the Spectrum Planning Subcommittee (SPS)? 

[Open-ended] 

27. What factors did the IRAC agency you represent consider when 
determining whether to classify a system as a "major spectrum 
dependent system" requiring a spectrum certification review? 

[open-ended] 

28. To what extent does the IRAC agency you represent rely on 
unlicensed spectrum? (select one for each row): 

Great extent; 
Frequency: 2; 
Total responses: 2. 

Moderate extent; 
Frequency: 6; 
Total responses: 8. 

Some or little extent; 
Frequency: 9; 
Total responses: 17. 

No extent; 
Frequency: 1; 
Total responses: 18. 

[End of table] 

29. When did the IRAC agency you represent last complete a review or 
analysis of your future spectrum needs? (select one for each row): 

In the last 6 months; 
Frequency: 3; 
Total responses: 3. 

More than 6 months ago, but less than 1 year ago; 
Frequency: 2; 
Total responses: 5. 

More than 1 year ago, but less than 2 years ago; 
Frequency: 5; 
Total responses: 10. 

More than 2 years ago, but less than 5 years ago; 
Frequency: 4; 
Total responses: 14. 

More than 5 years ago; 
Frequency: 2; 
Total responses: 16. 

Do not know; 
Frequency: 2; 
Total responses: 18. 

[End of table] 

30. How much, if at all, do you see your agency's need for spectrum 
increasing in the next 2-3 years? (select one for each row): 

Greatly increasing; 
Frequency: 6; 
Total responses: 6. 

Moderately increasing; 
Frequency: 2; 
Total responses: 8. 

Slightly increasing; 
Frequency: 8; 
Total responses: 16. 

Not increasing; 
Frequency: 1; 
Total responses: 17. 

[End of table] 

31. In your opinion, will your agency have difficulty in the future 
meeting its critical mission needs because of insufficient spectrum? 
(select one for each row): 

Yes, there will be great difficulty; 
Frequency: 8; 
Total responses: 8. 

Yes, there will be some difficulty; 
Frequency: 7; 
Total responses: 15. 

No, there will be no difficulty; 
Frequency: 3; 
Total responses: 18. 

[End of table] 

32. What factors does the IRAC agency you represent consider when 
making decisions about how much spectrum the agency will need in the 
future? 

[Open-ended] 

33. On average, how often is your agency able to meet the 5-year 
review requirement of your agency' spectrum frequency assignments 
reflected in the Government Master File Database? 

All the time; 
Frequency: 5; 
Total responses: 5. 

Most of the time; 
Frequency: 9; 
Total responses: 14. 

Some of the time, but not most of the time; 
Frequency: 4; 
Total responses: 18. 

[End of table] 

34. Please describe below some of the general challenges, if any, that 
your agency faces in reviewing your spectrum frequency assignments 
reflected in the Government Master File Database, by the 5-year 
deadline as required by NTIA: 

[Open-ended] 

35. During the last year, approximately how many modifications to an 
existing spectrum frequency assignment did the IRAC agency you 
represent make? 

[Open-ended] 

36. Please describe below the general reasons for why your agency 
modified an existing spectrum frequency assignment during the last 
year: 

[Open-ended] 

37. During the last year, approximately how many deletions to an 
existing spectrum frequency assignment did the IRAC agency you 
represent make? 

[Open-ended] 

38. Please describe below the general reasons for why your agency 
deleted an existing spectrum frequency assignment during the last year: 

[Open-ended] 

39. Does the IRAC agency you represent currently conduct measurements 
of any of the following types of usage? (select one for each row): 

Question: 39a. Occupancy rates of assigned frequencies; 
Response: Yes: 3; 
Response: No: 14; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 39b. Geographic location of frequency use; 
Response: Yes: 11; 
Response: No: 6; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 39c. Temporal usage measurements (either clock or calendar); 
Response: Yes: 1; 
Response: No: 15; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 39d. Number of frequencies assigned; 
Response: Yes: 11; 
Response: No: 5; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 39e. Other; 
Response: Yes: 3; 
Response: No: 3; 
Response: No response/not applicable: 7; 
Total responses: 13. 

[End of table] 

40. Which of the following reasons explains why your agency does not 
conduct spectrum usage measurements? (select one for each row): 

Question: 40a. Lack of technology or equipment to conduct measurements; 
Response: Yes: 7; 
Response: No: 6; 
Response: No response/not applicable: 5; 
Total responses: 18. 

Question: 40b. Lack of in-house expertise to conduct measurements; 
Response: Yes: 1; 
Response: No: 12; 
Response: No response/not applicable: 5; 
Total responses: 18. 

Question: 40c. Conflicting mission priorities; 
Response: Yes: 8; 
Response: No: 5; 
Response: No response/not applicable: 5; 
Total responses: 18. 

Question: 40d. Limited resources to conduct measurements; 
Response: Yes: 11; 
Response: No: 3; 
Response: No response/not applicable: 4; 
Total responses: 18. 

Question: 40e. Other factors; 
Response: Yes: 8; 
Response: No: 2; 
Response: No response/not applicable: 5; 
Total responses: 15. 

[End of table] 

Spectrum sharing and use of commercial services: 

41. Does the IRAC agency you represent currently share spectrum with 
any of the following users? (select one for each row): 

Question: 41a. Other federal users; 
Response: Yes: 17; 
Response: No: 1; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 41b. Across program offices/departments within your federal 
agency; 
Response: Yes: 15; 
Response: No: 1; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 41c. State governments (including public safety); 
Response: Yes: 13; 
Response: No: 3; 
Response: Don't know: 1; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 41d. Local governments (including public safety); 
Response: Yes: 13; 
Response: No: 4; 
Response: Don't know: 1; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 41e. Private industry users; 
Response: Yes: 9; 
Response: No: 9; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 41f. Non-profit organizations; 
Response: Yes: 2; 
Response: No: 12; 
Response: Don't know: 3; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 41g. Universities and other educational institutions; 
Response: Yes: 13; 
Response: No: 5; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 41h. Other; 
Response: Yes: 3; 
Response: No: 4; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 6; 
Total responses: 13. 

[End of table] 

42. If your agency shares spectrum, please provide examples. 

[open-ended] 

43. If your agency shares spectrum, how much of an influence, if any, 
were the following factors in the agency's decision to share spectrum? 
(select one for each row): 

Question: 43a. Interoperability with other federal users; 
Response: Strong influence: 13; 
Response: Moderate influence: 2; 
Response: Little influence: [Empty]; 
Response: No influence: 1; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 43b. Interoperability with nonfederal users; 
Response: Strong influence: 10; 
Response: Moderate influence: 3; 
Response: Little influence: 1; 
Response: No influence: 1; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 43c. Improved mission performance; 
Response: Strong influence: 10; 
Response: Moderate influence: 3; 
Response: Little influence: [Empty]; 
Response: No influence: [Empty]; 
Response: No response/not applicable: 3; 
Total responses: 16. 

Question: 43d. Promoting greater spectrum efficiency; 
Response: Strong influence: 8; 
Response: Moderate influence: 5; 
Response: Little influence: 2; 
Response: No influence: 2; 
Response: No response/not applicable: 1; 
Total responses: 18. 

Question: 43e. Lower costs; 
Response: Strong influence: 5; 
Response: Moderate influence: 4; 
Response: Little influence: 4; 
Response: No influence: [Empty]; 
Response: No response/not applicable: 4; 
Total responses: 17. 

Question: 43f. Other; 
Response: Strong influence: 4; 
Response: Moderate influence: [Empty]; 
Response: Little influence: [Empty]; 
Response: No influence: 2; 
Response: No response/not applicable: 6; 
Total responses: 12. 

[End of table] 

44. Does the IRAC agency you represent, utilize any of the following 
spectrum sharing technologies? (select one for each row): 

Question: 44a. Software defined radios; 
Response: Yes: 4; 
Response: No: 13; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

Question: 44b. Dynamic frequency selection devices; 
Response: Yes: 6; 
Response: No: 11; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

Question: 44c. Cognitive radios; 
Response: Yes: 2; 
Response: No: 15; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

Question: 44d. Trunked radio systems; 
Response: Yes: 14; 
Response: No: 3; 
Response: No response/not applicable: [Empty]; 
Total responses: 17. 

Question: 44e. Other; 
Response: Yes: [Empty]; 
Response: No: 2; 
Response: No response/not applicable: 8; 
Total responses: 10. 

[End of table] 

45. Please describe below the challenges, if any, impact your agency's 
ability to use technologies that promote spectrum sharing (such as 
software defined radios, dynamic frequency selection devices, 
cognitive radios, or trunked radio systems): 

[Open-ended] 

46. If your agency does not share spectrum, how much of an influence, 
if any, were the following factors in the agency's decision to not 
share spectrum? (select one for each row): 

Question: 46a. Concerns over interference; 
Response: Strong influence: 6; 
Response: Moderate influence: 3; 
Response: Little influence: [Empty]; 
Response: No influence: [Empty]; 
Response: No response/not applicable: 8; 
Total responses: 17. 

Question: 46b. Uncertainty over use/priority; 
Response: Strong influence: 7; 
Response: Moderate influence: 2; 
Response: Little influence: [Empty]; 
Response: No influence: [Empty]; 
Response: No response/not applicable: 8; 
Total responses: 17. 

Question: 46c. Lack of economic incentives; 
Response: Strong influence: 3; 
Response: Moderate influence: [Empty]; 
Response: Little influence: 3; 
Response: No influence: 2; 
Response: No response/not applicable: 9; 
Total responses: 17. 

Question: 46d. Lack of staff/expertise; 
Response: Strong influence: [Empty]; 
Response: Moderate influence: [Empty]; 
Response: Little influence: 1; 
Response: No influence: 8; 
Response: No response/not applicable: 8; 
Total responses: 17. 

Question: 46e. Current technology being used at the agency does not 
permit sharing; 
Response: Strong influence: 6; 
Response: Moderate influence: 1; 
Response: Little influence: 1; 
Response: No influence: 1; 
Response: No response/not applicable: 8; 
Total responses: 17. 

Question: 46f. Lack of guidance/support from NTIA; 
Response: Strong influence: [Empty]; 
Response: Moderate influence: [Empty]; 
Response: Little influence: 4; 
Response: No influence: 5; 
Response: No response/not applicable: 8; 
Total responses: 17. 

Question: 46g. Existing laws and regulations; 
Response: Strong influence: 3; 
Response: Moderate influence: 2; 
Response: Little influence: 1; 
Response: No influence: 3; 
Response: No response/not applicable: 8; 
Total responses: 17. 

Question: 46h. Other; 
Response: Strong influence: 1; 
Response: Moderate influence: [Empty]; 
Response: Little influence: [Empty]; 
Response: No influence: 1; 
Response: No response/not applicable: 12; 
Total responses: 14. 

[End of table] 

47. Does the IRAC agency you represent currently rely on commercial 
network service providers to fulfill any of the following services for 
mission critical needs and/or administrative needs? (select one for 
each row): 

Question: 47a. Administrative needs; 
Response: Yes: 16; 
Response: No: 1; 
Response: Don't know: 1; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 47b. Mission critical needs; 
Response: Yes: 14; 
Response: No: 3; 
Response: Don't know: 1; 
Response: No response/not applicable: [Empty]; 
Total responses: 18. 

Question: 47c. Other; 
Response: Yes: 3; 
Response: No: 3; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 7; 
Total responses: 13. 

[End of table] 

48. How much of an influence, if any, were the following factors in 
the agency's decision to use commercial services to provide your 
spectrum related needs? (select one for each row): 

Question: 48a. Increased technical efficiency; 
Response: Strong influence: 4; 
Response: Moderate influence: 3; 
Response: Little influence: 3; 
Response: No influence: 5; 
Response: Don't know: 1; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 48b. Reduced costs; 
Response: Strong influence: 8; 
Response: Moderate influence: [Empty]; 
Response: Little influence: 4; 
Response: No influence: 3; 
Response: Don't know: 1; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 48c. Upgraded technology; 
Response: Strong influence: 3; 
Response: Moderate influence: 4; 
Response: Little influence: 4; 
Response: No influence: 3; 
Response: Don't know: 1; 
Response: No response/not applicable: 2; 
Total responses: 17. 

Question: 48d. Frequency assignments were deleted; 
Response: Strong influence: [Empty]; 
Response: Moderate influence: 2; 
Response: Little influence: 3; 
Response: No influence: 9; 
Response: Don't know: 1; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 48e. NTIA requirement; 
Response: Strong influence: 2; 
Response: Moderate influence: 2; 
Response: Little influence: [Empty]; 
Response: No influence: 10; 
Response: Don't know: 2; 
Response: No response/not applicable: 2; 
Total responses: 18. 

Question: 48f. Other; 
Response: Strong influence: 5; 
Response: Moderate influence: [Empty]; 
Response: Little influence: [Empty]; 
Response: No influence: 2; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 7; 
Total responses: 14. 

[End of table] 

49. How much of an influence did the following concerns have in the 
agency's decision not to use commercial network services for mission 
critical needs? (select one for each row): 

Question: 49a. Security concerns; 
Response: Strong influence: 9; 
Response: Moderate influence: 2; 
Response: Little influence: 1; 
Response: No influence: 2; 
Response: Don't know: 1; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 49b. Lack of support/guidance from NTIA; 
Response: Strong influence: [Empty]; 
Response: Moderate influence: [Empty]; 
Response: Little influence: 4; 
Response: No influence: 10; 
Response: Don't know: 1; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 49c. Cost; 
Response: Strong influence: 2; 
Response: Moderate influence: 6; 
Response: Little influence: 2; 
Response: No influence: 3; 
Response: Don't know: 1; 
Response: No response/not applicable: 4; 
Total responses: 18. 

Question: 49d. Budget; 
Response: Strong influence: 4; 
Response: Moderate influence: 3; 
Response: Little influence: 2; 
Response: No influence: 4; 
Response: Don't know: 1; 
Response: No response/not applicable: 3; 
Total responses: 17. 

Question: 49e. Lack of private sector capabilities; 
Response: Strong influence: 5; 
Response: Moderate influence: 3; 
Response: Little influence: 4; 
Response: No influence: 2; 
Response: Don't know: 1; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 49f. Concerns over coverage and network reliability; 
Response: Strong influence: 7; 
Response: Moderate influence: 3; 
Response: Little influence: 3; 
Response: No influence: 1; 
Response: Don't know: 1; 
Response: No response/not applicable: 3; 
Total responses: 18. 

Question: 49g. Other; 
Response: Strong influence: 1; 
Response: Moderate influence: [Empty]; 
Response: Little influence: [Empty]; 
Response: No influence: 1; 
Response: Don't know: [Empty]; 
Response: No response/not applicable: 11; 
Total responses: 13. 

[End of table] 

50. If you have any additional comments or views regarding federal 
spectrum management issues that you'd like to share with us, please do 
so below. 

[End of section] 

Appendix IV: Comments from the Department of Commerce: 

United States Department Of Commerce: 
The Secretary of Commerce: 
Washington, D.C. 20230: 

March 25, 2010: 

Mr. Gene L. Dodaro: 
Comptroller General: 
Government Accountability Office: 
441 G Street, NW:	
Washington, DC 20548: 
	
Dear Mr. Dodaro:	 

Thank you for the opportunity to comment on the Government 
Accountability Office's (GAO) draft report, "Spectrum Management: NTIA 
Planning and Processes Need Strengthening to Promote the Efficient Use 
of Spectrum by Federal Agencies" (GA0-11-352). GAO examined (1) the 
extent to which National Telecommunications and Information 
Administration's (NTIA) spectrum management oversight and policy 
address government-wide spectrum needs, (2) how federal agencies are 
using assigned spectrum and the extent to which they manage their 
spectrum use, and (3) what steps NTIA and the federal agencies have 
taken to meet the requirements and expectations of the National 
Broadband Plan and Presidential Memo to repurpose spectrum for 
broadband, and the challenges these efforts face.	 

The GAO Report provides a useful perspective on NTIA's critical role 
as the spectrum manager for Federal users. As the report recognizes, a 
multitude of Federal agencies rely on spectrum in fulfilling a variety 
of critical Federal missions including national defense, law 
enforcement, emergency relief, scientific research, space, and 
maritime and air traffic control. Over 60 Federal agencies receive 
spectrum assignments from NTIA, which is authorized by statute to make 
spectrum assignments to Federal agencies and establish policies 
concerning such assignments.[Footnote 1] Because mission-critical 
Federal operations depend on prompt NTIA action on agency spectrum 
requests, NTIA's primary spectrum management mission is to fulfill 
Federal agency spectrum requirements.	 

The Report observes that NTIA's processes focus on interference 
mitigation. Interference mitigation is NTIA's top spectrum management 
priority for two reasons. First, prevention of interference is 
essential to ensure that critical Federal missions are not impaired. 
Second, by working with the agencies to prevent interference and 
promote inter-agency operational coordination on spectrum matters, 
NTIA ensures that Federal agencies efficiently share use of scarce 
spectral resources. Effective interference mitigation requires not 
only NTIA resources but those of the agencies' spectrum offices	and 
field operations, which all work cooperatively through the 
Interdepartment Radio Advisory Committee (IRAC) and its subcommittees 
to coordinate Federal use of spectrum. 

As the GAO Report reflects, from time to time NTIA is called upon by 
the Administration to undertake other spectrum-related assignments. 
President Bush's 2004 Presidential Memorandum,[Footnote 2] which is 
the subject of the GAO Report, is but one example. While NTIA was in 
the process of updating the 2008 Federal Strategic Plan in accordance 
with President Bush's November 30, 2004, Presidential Memorandum, 
President Obama directed the Department of Commerce (Department), 
working through NTIA, to develop by October 1, 2010, a Ten Year Plan 
and Timetable to repurpose 500 MHz of Federal and commercial spectrum 
for wireless broadband use.[Footnote 3] 

NTIA was also directed by the National Economic Council and White 
House Office of Science and Technology Policy to determine by October 
1, 2010, whether any spectrum used by Federal agencies could be 
repurposed for commercial broadband use within five years.[Footnote 4] 
Most recently, on February 10, 2011, the President announced a 
National Wireless Initiative which, among other things, is aimed at 
bringing 4G wireless service to 98% of Americans and deploying a 
nationwide, interoperable wireless communications network for public 
safety.[Footnote 5] 

Given funding limitations, NTIA must determine how to prioritize the 
various initiatives without impairing its fundamental spectrum mission 
of responding to the agencies' spectrum assignment requests in a 
manner that is both timely and ensures that the agencies can operate 
in an interference-free environment. NTIA, as the GAO Report notes, 
must also rely on the agencies' spectrum management offices and field 
operations to help address these initiatives. 

It is in this context that we consider the GAO recommendation that 
NTIA engage in "holistic spectrum management," in addition to its 
other spectrum-related obligations. We understand that such an 
approach would, for example, require NTIA to assess every Federal 
operation and mission to determine which ones could be performed more 
efficiently using non-spectrum resources. To date, and as the Report 
recognizes, NTIA has not undertaken such efforts to analyze individual 
agencies' decisions as to how best to accomplish their respective 
missions. NTIA's expertise in those substantive areas (e.g., defense, 
health care, transportation, or energy) is considerably less than the 
expertise of the agencies responsible for developing and executing 
policy in those areas. Lacking the manpower and fiscal resources 
necessary, NTIA relies on agencies to evaluate their needs and, as 
noted, seeks to ensure efficient Federal use of spectrum by focusing 
its efforts on interference mitigation. 

Similarly, because of budget and resource limitations, NTIA as a 
historical matter does not police Federal agency spectrum use or 
Federal agency spectrum reporting. In a constrained budget 
environment, we believe the best use of limited Federal resources is 
to continue the current practice of agency self-reporting. Agency 
field offices procure and use the equipment for which they seek 
authorization. They have the specialized expertise and knowledge 
necessary to provide the needed technical information and they have no 
incentive to provide inaccurate information. Further, we believe 
agencies have every incentive to provide accurate information in order 
to protect their critical missions and operations from interference 
from other users of spectrum—both Federal and commercial. 

We very much appreciate the analysis and recommendations set forth in 
the GAO Report, particularly the manner in which it illuminates the 
challenges involved in coordinating use of spectrum by the scores of 
Federal agencies that depend on spectrum to execute their core missions.
The Department's response to each of GAO's specific recommendations is 
set forth below. GAO's recommendation appears in italics and the 
Department's response follows in regular text. 

Recommendation 1: To ensure NTIA's previous efforts to develop a 
federal strategic plan are not diminished, develop an updated plan 
that includes key elements of a strategic plan, as well as information 
on how spectrum is being used across the federal government, 
opportunities to increase efficient use of federally allocated 
spectrum and infrastructure, an assessment of future spectrum needs, 
and plans to incorporate these needs in the frequency assignment, 
equipment certification, and review processes. 

Response: We partially concur with this recommendation regarding the 
need to engage in strategic planning with respect to NTIA's spectrum 
processes. To be sure, key elements of strategic planning are central 
to the work that NTIA's Office of Spectrum Management performs on a 
regular basis. For example, as noted above, while NTIA was in the 
process of updating the 2008 Federal Strategic Plan, President Obama 
directed the Department, working through NTIA, to develop a Ten Year 
Plan and Timetable to repurpose 500 MHz of Federal and commercial 
spectrum for wireless broadband use.[Footnote 6] NTIA completed the 
Ten Year Plan and Timetable and is now engaged in implementing the Ten 
Year Plan and Timetable, as well as the President's National Wireless 
Initiative.[Footnote 7] 

NTIA will weigh the strategic plan updating requirements against other 
spectrum management needs and directives and determine priorities. At 
the same time, NTIA's review of spectrum certification requests and 
its initial Federal strategic spectrum plan have not revealed new 
Federal spectrum demands that have required alteration of the spectrum 
allocation table. Moreover, NTIA, through the IRAC and its 
subcommittees, assesses future Federal spectrum needs on a continuing 
basis. 

Recommendation 2: To help ensure federal agencies are managing current 
and future spectrum assignments efficiently, in consultation with 
IRAC, examine the 5-year assignment review processes and consider best 
practices to determine if the current approach for collecting and 
validating data from federal agencies can be streamlined or improved. 

Response: We concur with this recommendation. NTIA, in consultation 
with IRAC, will review the current assignment process with the 
agencies to determine what improvements it can implement. 

Recommendation 3: To provide the assurance that accurate and reliable 
data on federal spectrum use are collected, take interim steps to 
establish internal controls for management oversight of the accuracy 
and completeness of currently reported agency data. In developing the 
new Federal Spectrum Management System, incorporate adequate internal 
controls for validating the accuracy of agency-reported information 
submitted during the assignment, certification, and frequency 
assignment review processes. 

Response: We partially concur with this recommendation to the extent 
it can be adopted with existing and anticipated resources. The 
migration to the Frequency Spectrum Management System (FSMS) to 
enhance NTIA's operational and planning capabilities is a multi-year 
process. NTIA will work with the agencies to determine what new 
processes could be implemented that would lead to more accurate and 
reliable data, including the establishment of procedures for agency 
validation of submitted data. This work will include evaluating the 
existing data collection process as well as the future FSMS. 

Again, thank you for the opportunity to respond to the draft Report. 
The Department is committed to working with the Federal agencies in 
reviewing these recommendations and taking appropriate action. 

Sincerely, 

Signed by: 

Gary Locke: 

Appendix IV Footnotes: 

[1] See 47 U.S.C. 902 (b)(2XA) and (K).	 

[2] See Memorandum for the Heads of Executive Departments and 
Agencies, Improving Spectrum Management for the 21st Century, 49 
Weekly Comp. Pres. Doc. 2875 (Nov. 29, 2004). 

[3] See Memorandum for the Heads of Executive Departments and 
Agencies, Unleashing the Wireless Broadband Revolution, 75 Fed. Reg. 
38387 (2010), available at [hyperlink, http://www.whitehouse.uov/the-
press-office/uresidential-memorandum-unleashing-wireless-broadband-
revolution]; See also Plan and Timetable to Make Available 500
Megahertz of Spectrum for Wireless Broadband, U.S. Department of 
Commerce, Oct. 2010, (available at [hyperlink, 
http://www.ntia.doc.gov/reports/2001/TenYearPlan_11152010.pdf]. 

[4] See An 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, U.S. Department of 
Commerce, Oct. 2010, available at [hyperlink, 
http://www.ntia.doc.gov/reports/2010/FastTrackEvaluation_1152010.pdf]. 

[5] See Press Release, President Obama Details Plan to Win the Future 
through Expanded Wireless Access, February 10, 2011, available at 
[hyperlink, http://www.whitehouse.govithe-press-
office/2011/02/10/president-obama-details-plan-winfuture-through-
expanded-wireless-access]. 

[6] See Presidential Memorandum on Spectrum Policy for the 21st 
Century, 69 Fed. Reg. 1568 (Jan. 9, 2004); See also Memorandum for the 
Heads of Executive Departments and Agencies, Unleashing the Wireless 
Broadband Revolution, 75 Fed. Reg. 38387 (2010), available at 
[hyperlink, http://www.whitehouse.gov/the-press-
office/presidentialmemorandum-unleashing-wireless-broadband-
revolution]. See Plan and Timetable to Make Available 500 Megahertz of 
Spectrum for Wireless Broadband, U.S. Department of Commerce, Oct. 
2010, available at [hyperlink, 
http://www.ntia.doc.gov/reDorts/2010/TenYearPlan_11152010.pdf]. 

[7] See Plan and Timetable to Make Available 500 Megahertz of Spectrum 
for Wireless Broadband, U.S. Department of Commerce, Oct. 2010, 
available at [hyperlink, 
http://www.ntia.doc.gov/reports/2010/TenYearPlan_11152010.pdf]. 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Sally Moino, Assistant 
Director; Amy Abramowitz; Tida Barakat; Richard Brown; Colin Fallon; 
Nick Jepson; Maria Mercado; Josh Ormond; Kelly Rubin; Andrew Stavisky; 
Hai Tran; and Mindi Weisenbloom made key contributions to this report. 

[End of section] 

Footnotes: 

[1] The term "broadband" commonly refers to high-speed Internet 
access. Wireless broadband connects a home or business to the Internet 
using a radio link. 

[2] Highly valued spectrum is sometimes called "beachfront" spectrum. 
For many mobile radio systems, the 300 MHz to 3 GHz spectrum range is 
the portion of the spectrum where scarcity concerns are the greatest. 
However, for some industry representatives, the "beachfront" spectrum 
is larger, located anywhere between 100 MHz to 6 GHz. As spectrum- 
dependent technologies improve over time, the definition of high-value 
spectrum can change. 

[3] Karl Nebbia, Director NTIA Office of Spectrum Management, 
presentation to the Commerce Spectrum Management Advisory Committee 
(CSMAC) (December 9, 2009). These percentages represent how much of 
this spectrum is available (allocated) for use by federal and 
nonfederal entities, not how much high-value spectrum is actually 
being used or shared by these groups. 

[4] Federal Communications Commission, Connecting America: The 
National Broadband Plan (Mar. 16, 2010). 

[5] See, Memorandum for the Heads of Executive Departments and 
Agencies, Unleashing the Wireless Broadband Revolution, 75 Fed. Reg. 
38387 (2010). 

[6] Repurposing, as defined by NTIA, refers to the altering of the use 
of spectrum from that which is currently allowed to other or different 
uses. 

[7] We expect to issue this report in fall 2011. 

[8] 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 kHz refers to thousands 
of Hertz, MHz to millions of Hertz, and GHz to billions of Hertz. The 
Hertz unit of measurement is used to refer to both the quantity of 
spectrum (such as 500 MHz) and the frequency bands (such as the 1710- 
1755 MHz band). 

[9] The Department of State also plays a role in spectrum management 
by coordinating and mediating the U.S. position and leading the 
nation's delegation to international conferences on spectrum 
management. 

[10] 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 between 
88 and 108 MHz are allocated to FM radio broadcasting in the United 
States, while frequency bands between 300 and 322 MHz are government 
exclusive bands allocated for mobile, mobile satellite, and fixed 
radio use. In addition to allocation, NTIA and FCC also specify 
service rules, which include the technical and operating 
characteristics of equipment. 

[11] OMB Circular No. A-11, Preparation, Submission and Execution of 
the Budget, §33.4, Radio-Spectrum Dependent Communications-Electronic 
Systems (July 2010). 

[12] Presidential Memorandum on Spectrum Policy for the 21st Century, 
69 Fed. Reg. 1568 (Jan. 9, 2004). Pursuant to this directive, NTIA 
issued two reports. See, Department of Commerce, Spectrum Policy for 
the 21st Century - The President's Spectrum Policy Initiative: Report 
1, Recommendations of the Federal Government Spectrum Task Force (June 
2004) and Department of Commerce, Spectrum Policy for the 21st Century 
- The President's Spectrum Policy: Report 2, Recommendations from 
State and Local Governments and Private Sector Responders (June 2004). 
In a subsequent memorandum, the President provided guidance for the 
recommendations' implementation. See, President's Memorandum on 
Improving Spectrum Management for the 21st Century, 49 Weekly Comp. 
Pres. Doc. 2875,) (Nov. 29, 2004). 

[13] NTIA designates an employee of NTIA to serve as the Designated 
Federal Officer for CSMAC. 

[14] 5 U.S.C. App. 2. 

[15] NTIA, An 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 (October 2010). 

[16] H.R. 911, 112th Cong. (2011). Among other things, the bill 
includes provisions on voluntary incentive auctions. 

[17] S. 455, 112th Cong. (2011). Among other things, the bill includes 
provisions to modify the Spectrum Relocation Fund; provide for 
voluntary incentive actions; and require the development of a 
triennial national strategic spectrum plan. 

[18] S. 415, 112TH Cong. (2011). 

[19] S. 522, 112th Cong. (2011). 

[20] The NTIA Organization Act, 47 U.S.C. §§ 901 et seq. 

[21] Under the November 2004 presidential memorandum, the Department 
of Commerce was tasked with integrating the agency-specific spectrum 
plans and spectrum needs plan based upon a Department of Commerce 
framework into a federal spectrum plan and to assist in the 
formulation of a national strategic spectrum plan. The Secretary of 
Commerce, in consultation with FCC, as appropriate, was to update the 
national strategic spectrum plan on a biennial basis. President's 
Memorandum on Spectrum Management for the 21ST Century, § 3(a). 

[22] This is not the first experience NTIA has had with developing a 
forward looking strategic plan. In September 2000, it issued a long- 
range plan. See Department of Commerce, National Telecommunications 
and Information Administration, Federal Long-Range Spectrum Plan 
(September 2000). 

[23] Department of Commerce, National Telecommunications and 
Information Administration, Spectrum Management for the 21ST Century: 
Plan to Implement Recommendations of the President's Spectrum Policy 
Initiative (2006). 

[24] Department of Commerce, National Telecommunications and 
Information Administration, Spectrum Policy for the 21ST Century - The 
President's Spectrum Policy Initiative: The Federal Strategic Spectrum 
Plan (March 2008). 

[25] In the fiscal year 2008 progress report, NTIA noted that it sent 
a letter to FCC in June 2008 seeking FCC participation, but that the 
expected completion date was to be determined. 

[26] The agencies that submitted strategic spectrum plans include the 
Departments of Agriculture, Commerce, Defense, Energy, Homeland 
Security, Interior, Justice, State, Transportation, Treasury, and 
Veterans Affairs; the National Aeronautics and Space Administration, 
National Science Foundation, Broadcasting Board of Governors, and the 
U.S. Postal Service. In September 2010, these agencies held over 80 
percent of federal frequency assignments. 

[27] See Government Performance and Results Act of 1993, Pub. L. No. 
103-62, 107 Stat. 285 (1993); Office of Management and Budget, Cir. 
No. A-11, Preparation, Submission and Execution of the Budget, Part 6- 
Preparation and Submission of Strategic Plans, Annual Performance 
Plan, and Annual Program Performance Reports (July 2010); and GAO, 
Agencies' Strategic Plans Under GPRA: Key Questions to Facilitate 
Congressional Review, [hyperlink, 
http://www.gao.gov/products/GAO-GGD-10.1.16] (Washington, D.C.: May 
1997). 

[28] Of the original 15 agencies to submit plans in 2005, the 
Departments of the Interior and State did not resubmit plans in 2007. 
While it did not submit a plan in 2005, the U.S. Coast Guard submitted 
a plan in 2007. 

[29] The November 2004 presidential memorandum directed the Secretary 
of Commerce within 6 months of the issuance of the memorandum to 
provide the President a report describing the progress on implementing 
the recommendations in the reports and to update this report on an 
annual basis until completion of the actions required by the 
memorandum. President's Memorandum on Improving Spectrum Management 
for the 21st Century, §3(c). 

[30] On February 10, 2011, the Obama Administration launched another 
initiative aimed at expanding wireless coverage to 98 percent of 
Americans. NTIA officials told us they anticipate this initiative will 
result in additional directives for the agency. 

[31] Interference mitigation refers to ensuring that systems are not 
interfering with each other. 

[32] IRAC consists of representatives of the following departments and 
agencies: Agriculture, Air Force, Army, Broadcasting Board of 
Governors, Coast Guard, Commerce, Energy, Federal Aviation 
Administration, Homeland Security, Interior, Justice, National 
Aeronautics and Space Administration, National Science Foundation, 
Navy, State, Transportation, Treasury, U.S. Postal Service, Veterans 
Affairs. Nonmember departments and agencies may designate one of the 
members to act as their accredited agent on IRAC. The Department of 
the Treasury acts as the accredited agent for the Department of 
Education, Federal Reserve System, and Small Business Administration. 
The Department of the Interior acts as the accredited agent for the 
International Boundary and Water Commission (U.S. Section) and the 
Tennessee Valley Authority. The Federal Aviation Administration acts 
as the accredited agent for the Volpe National Transportation Systems 
Center. NTIA acts as the accredited agent for all other nonmember 
agencies with spectrum requirements. 

[33] The U.S. Postal Service and Department of Transportation are not 
members of the SPS. 

[34] GAO, Internal Control Management and Evaluation Tool, [hyperlink, 
http://www.gao.gov/products/GAO-01-1008G] (Washington, D.C.: August 
2001). 

[35] The agency practice of overestimating needs is due to the fact 
that more detailed data is not available. The extent to which agencies 
overestimate their needs is unclear. 

[36] These data reflect only unclassified federal spectrum assignments. 

[37] For the purposes of our analysis, we combined data from the 
Departments of the Air Force, Army, Navy, and Marine Corps into the 
DOD category. 

[38] For most assignments, NTIA requires that federal agencies conduct 
5-year reviews of their assignments. In some cases however, such as 
for certain space systems, aeronautical, and military assignments, 
NTIA requires that agencies review the assignment every 10 years. 
Redbook, § 8.2.6 and Annex F. 

[39] Spectrum 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. On September 18, 2006, FCC completed an 
auction of designated federal frequencies in the 1710-1755 MHz band, 
for commercial use as Advanced Wireless Services (AWS). 

[40] Wireless broadband is comprised of both fixed and mobile wireless 
communication sources. 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. See, 
Memorandum for the Heads of Executive Departments and Agencies, 
Unleashing the Wireless Broadband Revolution, 75 Fed. Reg. 38387 
(2010). 

[41] The PPSG consists of the Assistant Secretaries, or equivalent, 
with spectrum management oversight in agencies that are major 
stakeholders in the spectrum issues under consideration. It provides 
advice to NTIA on spectrum-dependent telecommunication policies, 
strategic plans, planned or revised positions on spectrum issues 
nationally and internationally, and helps resolve major contentious 
spectrum policy issues that affect the use of spectrum by federal and 
nonfederal users. 

[42] As a form of interference mitigation to maintain incumbent 
operations, NTIA and FCC will establish geographic exclusion zones 
which limit where commercial licensees will be able to operate. Within 
the exclusion zones, wireless broadband use would not be permitted, 
which would protect existing federal systems. 

[43] NTIA, 10 Year Plan and Timetable to Make Available 500 MHz of 
Spectrum for Wireless Broadband (2010). 

[44] GAO, Defense Spectrum Management: More Analysis Needed to Support 
Spectrum Use Decisions for the 1755-1850 MHz Band, [hyperlink, 
http://www.gao.gov/products/GAO-01-795] (Washington, D.C.: Aug. 21, 
2001). 

[45] The presidential memorandum was issued on June 28, 2010, and it 
directed NTIA to report back with its initial plan and timetable by 
October 1, 2010. 

[46] For additional information on these satellites, see GAO, 
Geostationary Operational Environmental Satellites: Improvements 
Needed in Continuity Planning and Involvement of Key Users, 
[hyperlink, http://www.gao.gov/products/GAO-10-799] (Washington, D.C.: 
September 1, 2010). 

[47] On December 23, 2004, President Bush signed into law the 
Commercial Spectrum Enhancement Act (Title II of Pub.L. No. 108-494) 
that created the Spectrum Relocation Fund to provide a centralized and 
streamlined funding mechanism through which federal agencies can 
recover the costs associated with relocating their radio 
communications systems from certain spectrum bands, which were 
authorized to be auctioned for commercial purposes. Under the terms of 
the CSEA, funds for compensation are only available when the federal 
entities relocate from spectrum awarded to nonfederal entities through 
a competitive bidding, or auction process. A portion of the revenues 
obtained in the auction of the spectrum to nonfederal entities is then 
credited to the Spectrum Relocation Fund to pay the relocation costs 
of federal entities. 

[48] According to OMB, costs associated with relocation of federal 
users in the auction of the 1710-1755 MHz band were estimated at $ 
1.009 billion. These costs included necessary infrastructure and 
systems modifications to relocate federal users to different 
frequencies and the transition of some agencies from analog to digital 
communications to improve communications efficiency and compatibility. 

[49] As mentioned previously, spectrum between 300 MHz and 3 GHz is 
generally considered to be the best suited for mobile broadband. 

[50] Spectrum Task Force Requests Information on Frequency Bands 
Identified by NTIA as Potential Broadband Spectrum, Public Notice, DA 
11-444 (2011). In this Public Notice, FCC also sought comments to 
inform ongoing assessment of the 1755-1850 MHz, 4200-4220 MHz and 4380-
4400 MHz bands, and other bands identified by NTIA as candidates for 
commercial use. 

[End of section] 

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