NTIA Should Update Federal Spectrum Strategy, GAO Says

Congress “should act promptly in a bipartisan manner to authorize incentive auctions, start the construction of a nationwide public safety broadband network, and conduct vigorous oversight of federal and commercial spectrum utilization,” Waxman said. “This undertaking will be complex and time consuming, but it is critical to our economic growth and broadband future.” House Communications Subcommittee Ranking Member Anna Eshoo, D-Calif., said “all options should be on the table” to reach the president’s goal of 500 MHz of spectrum for wireless broadband, “including the repurposing of spectrum currently used by federal agencies."

GAO said NTIA should 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,” GAO said. The Commerce Department only partially concurred with the 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."

"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,” GAO said. “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.”

"NTIA recognizes the importance of spectrum to America’s economic growth and the urgent need to make the most use of this limited resource while protecting vital federal operations,” an NTIA spokesman said. The GAO report highlights “the challenges involved in coordinating spectrum use by the scores of Federal agencies that depend on it to execute their core missions,” the spokeswoman said. The agency is “working with other federal agencies to examine ways of better ensuring the accuracy of spectrum data submitted to us. We are also reviewing our strategic planning processes in light of the National Wireless Initiative the President announced earlier this year as well as last year’s Presidential Memorandum on spectrum which we are in the process of implementing."

GAO also recommended that NTIA examine 5-year spectrum assignment review processes and determine “if the current approach to collecting and validating data from federal agencies can be streamlined or improved.” NTIA should also “take interim steps to establish internal controls for management oversight of the accuracy and completeness of currently reported agency data.” As it develops its new Federal Spectrum Management System, NTIA should “incorporate adequate internal controls for validating the accuracy of agency-reported information submitted during the assignment, certification, and frequency assignment review processes,” GAO said.

Commerce concurred with GAO’s recommendation to examine its 5-year review processes, and said NTIA would review the current assignment process with agencies. Commerce partially concurred with the recommendation to establish internal controls, “noting its concurrence to the extent that such controls could be adopted with existing and anticipated resources.” Commerce said 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,” GAO said.

Data and resource challenges could pose roadblocks to acting on NTIA’s 10-year spectrum relocation plan, GAO said. “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,” GAO said. “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.”

NTIA efforts to reform federal spectrum management and promote efficiency “have resulted in limited progress toward improved spectrum management,” GAO said in the report. The agency only developed one of two strategic plans ordered by former President George W. Bush in 2003, GAO said. NTIA issued one spectrum plan in March 2008, but it didn’t include any quantitative governmentwide data on federal spectrum needs, or any “key elements and best practices of strategic planning,” GAO said. NTIA still has not issued a national spectrum plan that was originally scheduled to be finished in December 2007, GAO said.

NTIA strategic planning has not been ongoing, GAO said. “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.” And the agency hasn’t issued an annual progress report since fiscal year 2008 on how it’s meeting Bush’s 2004 spectrum memo, GAO said. “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."

Rather than focus on ensuring best spectrum use across the federal government, NTIA has focused on interference mitigation, GAO said. NTIA says that’s because of the agency’s limited resources, GAO said. “This focus, while important, makes limited consideration about the overall best use of federally allocated spectrum,” GAO said. “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."

"NTIA has limited ability to monitor federal spectrum use,” GAO said. “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.”

NTIA may not be making spectrum management decisions based on accurate and complete data, because its data management system is “antiquated and lacks transparency and internal controls,” GAO said. Agencies submitting data to NTIA about their spectrum use do not have to attest to their accuracy, so “NTIA has limited assurance that information used to make spectrum management decisions is accurate and reliable.” NTIA is developing a new data management system to improve accuracy, but “development is still early and final implementation is not expected until fiscal year 2014,” GAO said. And NTIA projects the new system won’t improve existing data quality until 2018, GAO said. “In the meantime it is unclear whether important decisions regarding current and future spectrum needs are based on reliable data."

Federal agencies say they don’t have enough spectrum, GAO said. Some federal spectrum managers “said it’s becoming increasingly difficult to request new spectrum assignments due to limited availability of additional spectrum,” GAO said. “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."

But there may be inaccuracies in agencies’ assignment data, GAO said. “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,” it said. “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.” High staff turnover and competing mission priorities contribute to difficulties verifying information, GAO said.

"The GAO report provides yet another compelling reason for an unbiased and complete inventory of spectrum, and a more holistic approach to spectrum management,” an NAB spokesman said. “If there is a looming capacity crunch, why should there not be a full documentation of both public and private sector use of spectrum?”