Interdepartment Radio Advisory Committee
IRAC Representatives Effectively Coordinate Federal Spectrum but Lack Seniority to Advise on Contentious Policy Issues Gao ID: GAO-04-1028 September 30, 2004The National Telecommunications and Information Administration (NTIA) within the Department of Commerce manages the federal government's use of the radio frequency spectrum with coordination and policy input from the Interdepartment Radio Advisory Committee (IRAC), comprised of 20 federal agencies that use spectrum. In recent years, the use of spectrum in wireless applications has expanded dramatically, leading occasionally to contentious disputes between government and commercial users over access to spectrum. Considering IRAC's key role in spectrum management, Congress asked us to (1) describe the evolution of IRAC and (2) obtain IRAC agency representatives' assessment of IRAC's spectrum coordination and policy advice, role as an advisor, and whether IRAC needs to be reformed.
The mission and placement of IRAC have evolved over time. IRAC began in 1922 by assisting in the assignment of frequencies to federal users and coordinating federal government spectrum use. In 1952, IRAC's mission was expanded to include responsibilities for formulating and recommending policies, plans, and actions for federal government spectrum use. Initially advising the Department of Commerce, IRAC has reported to or through various different entities, including at different times the Federal Communications Commission (FCC) and the Office of the President. Since 1978, IRAC has directly advised the Department of Commerce's NTIA. Currently, IRAC is comprised of a full committee, six standing subcommittees, and various ad hoc committees and working groups. In interviews with GAO, IRAC agency representatives made two key points in assessing IRAC. First, IRAC is effective in accomplishing spectrum coordination tasks, but its effectiveness is at times limited by representatives' uneven level of technical knowledge. This problem could worsen, as one-half of the 20 current IRAC representatives are currently eligible to retire. Second, IRAC's ability to advise on national spectrum policy issues is limited because of representatives' lack of seniority within their agencies. The chair of IRAC (an NTIA senior executive) is in agreement with representatives on these points. He said that he has gone outside IRAC directly to senior agency executives when he needed advice on contentious spectrum disputes such as those related to the introduction of new commercial communications services that would use federally controlled spectrum. A federal task force recently released a report that identified similar issues regarding IRAC's effectiveness and areas in need of reform.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-04-1028, Interdepartment Radio Advisory Committee: IRAC Representatives Effectively Coordinate Federal Spectrum but Lack Seniority to Advise on Contentious Policy Issues
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Report to Congressional Requesters:
September 2004:
INTERDEPARTMENT RADIO ADVISORY COMMITTEE:
IRAC Representatives Effectively Coordinate Federal Spectrum but Lack
Seniority to Advise on Contentious Policy Issues:
GAO-04-1028:
GAO Highlights:
Highlights of GAO-04-1028, a report to congressional requesters
Why GAO Did This Study:
The National Telecommunications and Information Administration (NTIA)
within the Department of Commerce manages the federal government‘s use
of the radio frequency spectrum with coordination and policy input from
the Interdepartment Radio Advisory Committee (IRAC), comprised of 20
federal agencies that use spectrum. In recent years, the use of
spectrum in wireless applications has expanded dramatically, leading
occasionally to contentious disputes between government and commercial
users over access to spectrum. Considering IRAC‘s key role in spectrum
management, Congress asked us to (1) describe the evolution of IRAC
and (2) obtain IRAC agency representatives‘ assessment of IRAC‘s
spectrum coordination and policy advice, role as an advisor, and
whether IRAC needs to be reformed.
What GAO Found:
The mission and placement of IRAC have evolved over time. IRAC began in
1922 by assisting in the assignment of frequencies to federal users and
coordinating federal government spectrum use. In 1952, IRAC‘s mission
was expanded to include responsibilities for formulating and
recommending policies, plans, and actions for federal government
spectrum use. Initially advising the Department of Commerce, IRAC has
reported to or through various different entities, including at
different times the Federal Communications Commission (FCC) and the
Office of the President. Since 1978, IRAC has directly advised the
Department of Commerce‘s NTIA. Currently, IRAC is comprised of a full
committee, six standing subcommittees, and various ad hoc committees
and working groups.
In interviews with GAO, IRAC agency representatives made the following
key points in assessing IRAC:
* IRAC is effective in accomplishing spectrum coordination tasks, but
its effectiveness is at times limited by representatives‘ uneven level
of technical knowledge. This problem could worsen, as one-half of the
20 current IRAC representatives are currently eligible to retire.
* IRAC‘s ability to advise on national spectrum policy issues is
limited because of representatives‘ lack of seniority within their
agencies.
Most IRAC Representatives Agreed That the Formulation of National
Spectrum Policy Must Occur at a More Senior Level Than Current IRAC
Representatives:
[See PDF for image]
[End of figure]
The chair of IRAC (an NTIA senior executive) is in agreement with
representatives on these points. He said that he has gone outside IRAC
directly to senior agency executives when he needed advice on
contentious spectrum disputes such as those related to the introduction
of new commercial communications services that would use federally
controlled spectrum. A federal task force recently released a report
that identified similar issues regarding IRAC‘s effectiveness and
areas in need of reform.
What GAO Recommends:
GAO is recommending that the Secretary of Commerce: (1) seek IRAC‘s
assistance in establishing a set of best practices for training and
succession planning to guide agencies‘ participation in IRAC; and, (2)
establish a special IRAC committee comprised of senior level agency
officials as needed to provide policy advice on contentious spectrum
policy issues. In commenting on the report, the Department of Commerce
indicated that it would prefer that a senior level advisory group be
convened outside of IRAC.
www.gao.gov/cgi-bin/getrpt?GAO-04-1028.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Mark L. Goldstein at
(202) 512-2834 or goldsteinm@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
IRAC's Mission and Placement Have Evolved Since 1922:
IRAC Representatives' Assessment of IRAC Is Mostly Positive, but Some
Are Concerned That an Uneven Level of Technical Knowledge and a Lack of
Seniority Limit IRAC's Effectiveness:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Briefing Slides:
Appendix II: Comments from the Department of State:
Appendix III: Comments from the Department of Energy:
Appendix IV: Comments from the Department of the Interior:
Appendix V: Comments from the Department of the Navy:
Appendix VI: Comments from the Department of Commerce:
Appendix VII: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Acknowledgments:
Related GAO Products:
Figures:
Figure 1: Timeline of Key Dates in IRAC's Evolution:
Figure 2: The Federal Agencies Currently Represented on IRAC:
Letter September 30, 2004:
The Honorable Tom Davis:
Chairman, Committee on Government Reform:
House of Representatives:
The Honorable Christopher Shays:
Chairman, Subcommittee on National Security, Emerging Threats, and
International Relations:
Committee on Government Reform:
House of Representatives:
The Honorable Adam Putnam:
Chairman, Subcommittee on Technology, Information Policy,
Intergovernmental Relations, and the Census:
Committee on Government Reform:
House of Representatives:
Over the past several decades, the development and use of wireless
telecommunications and information technology has expanded
dramatically, greatly increasing the use of and demand for the radio
frequency spectrum.[Footnote 1] Cellular telephones, wireless computer
networks, and global-positioning system receivers are quickly becoming
as common to everyday life as radios and televisions. Wireless
communications have become critical to private industry and a variety
of government missions--ranging from scientific research and public
safety to homeland security and warfare. As a result, the radio
frequency spectrum has become crowded and, in the future, may no longer
be able to accommodate all users' needs.
Radio frequency spectrum in the United States is managed using a dual
organizational structure. The National Telecommunications and
Information Administration (NTIA) within the Department of Commerce
manages the federal government's use of spectrum, and the Federal
Communications Commission (FCC) manages all other uses. In carrying out
its responsibilities, NTIA relies on the assistance and advice of the
Interdepartment Radio Advisory Committee (IRAC). Chaired by NTIA, IRAC
is comprised of representatives from 20 federal agencies that use
spectrum. IRAC helps coordinate federal use of spectrum and provides
policy advice on spectrum issues.
Some recent, contentious disputes over who should have access to
specific parts of the radio spectrum have occurred between government
and commercial users. Because of IRAC's key role in spectrum
management, you asked us to (1) describe the evolution of IRAC and (2)
obtain IRAC representatives' assessment of IRAC's ability to coordinate
federal spectrum use and provide policy advice, its role as an advisor,
and whether IRAC needs to be reformed. To describe the evolution of
IRAC, we reviewed relevant historical documents and interviewed key
current and retired government officials. To obtain IRAC member
opinions, we conducted interviews with each of the 20 IRAC
representatives. We designed interviews that included a combination of
closed-ended questions and open-ended questions, which provided an
opportunity for the IRAC representatives to make additional comments.
We also interviewed other FCC and NTIA officials, including the current
chairs of the IRAC full committee and six standing subcommittees.
Lastly, we also relied on audit work from our previous reports on
spectrum management in forming our conclusions and recommendations. A
list of related GAO reports on spectrum management appears at the end
of this report. We conducted our work from October 2003 through June
2004 in accordance with generally accepted government auditing
standards. This report summarizes the information we provided to your
staff during our June 30, 2004, briefing. The briefing slides are
included in appendix I. Key contacts and major contributors to this
report are listed in appendix VII.
Results in Brief:
IRAC's mission and placement have evolved over its 80-year history.
IRAC was organized by federal agencies that were seeking a way to
resolve issues related to federal spectrum use in a cooperative manner.
IRAC's initial mission was to assist in the assignment of radio
frequencies to federal users and to coordinate federal government
spectrum use. In 1952, IRAC's mission was expanded to include
formulating and recommending policies, plans, and actions for federal
government spectrum use. Since its formation, IRAC has advised the
entity responsible for exercising the authority of the President to
assign radio frequencies to federal government users and consequently,
has reported to or through several different entities since its
inception, including the Federal Communications Commission (FCC) and
the Office of the President. Since 1978, IRAC has advised NTIA within
the Department of Commerce. In our interviews with the 20 IRAC
representatives, 15 said that the appropriate agencies were represented
on IRAC. Additionally, 17 of the IRAC representatives said that
coordinating with FCC through a liaison appointed by FCC was
appropriate.
Overall, IRAC representatives have a generally positive view of IRAC,
but a majority identified problems in a few areas. Regarding IRAC's
accomplishment of spectrum-coordination tasks, IRAC representatives
agree that the committee effectively assists in coordinating government
spectrum use, but 8 of 20 representatives commented that some agency
representatives lack sufficient technical knowledge and/or
understanding of emerging technologies. This concern was also shared by
4 of the 6 IRAC subcommittee chairs. The current chair of IRAC, a
senior-level manager at NTIA, also told us that he is concerned about
the technical knowledge level of some agency representatives as well as
the large number of current IRAC representatives who are eligible to
retire (10 representatives out of 20 are already eligible to retire,
and 3 additional representatives will become eligible in less than 5
years). He said that he has explored the possibility of training and
certifying spectrum managers at agencies. Regarding IRAC's ability to
provide policy advice, NTIA officials and IRAC representatives said
that IRAC representatives are not senior enough to effectively provide
policy advice on contentious spectrum issues. Currently, only one of
the 20 IRAC representatives is a member of the Senior Executive
Service. Seventeen out of 20 representatives said that national
spectrum policy formation must occur at a higher level than that held
by current IRAC members. The chair of IRAC agrees that current IRAC
representatives are not senior enough to provide high-level policy
advice. He told us that because of this, he has gone outside of the
IRAC framework by directly contacting senior executives from relevant
agencies when he needed advice on contentious national spectrum policy
issues that can occur when both government and commercial users desire
use of the same areas of the spectrum. Recently, specific instances of
such issues include the introduction of new commercial communications
services, such as third generation wireless (3G) devices, that require
federal agencies to relinquish control over some spectrum. In terms of
IRAC's ability to successfully promote the needs of government spectrum
users, IRAC must rely on NTIA to negotiate with FCC in disputes between
government and commercial users. Ten of 20 IRAC representatives raised
concerns about the ability of NTIA to adequately represent federal
users in these disputes, and 16 of 20 representatives think that a new
process is needed for reconciling competing demands. However, there was
no consensus on specific reforms to improve government-commercial
dispute resolution.
In order to improve the effectiveness of IRAC's contribution in
spectrum management, we are recommending that the Department of
Commerce develop a set of best practices for training and succession
planning to help guide the agencies' participation in IRAC, and
establish a special IRAC committee comprised of senior executives from
member agencies to provide high-level policy advice as needed on
contentious spectrum policy issues, such as those requiring either
commercial or government entities to share or relinquish spectrum. In
commenting on the draft of this report, the Department of Commerce
supports career development programs to provide training for new
spectrum managers and the establishment of a senior-level group to
provide advice on contentious spectrum policy issues. However, the
Department of Commerce feels that such a group would be better
positioned to address unresolved issues if it were convened outside of
the existing IRAC. (See letter at app. VI.) We did not change the
recommendation because we believe IRAC would create a good foundation
for such a group.
IRAC's Mission and Placement Have Evolved Since 1922:
IRAC's role and placement have evolved over the last 80 years. IRAC was
organized by several agencies in 1922 that, during a period of rapid
growth in the use of radio services, recognized the need for
interagency cooperation to resolve problems arising from the federal
government's use of broadcasting and radio services. The first
interagency committee meeting attended by interested federal agencies
initially set out to regulate and guide the radio broadcasting
operations at the Washington Navy Yard and any others that might be
established by the federal government. In June 1922, the committee
decided that its scope should extend beyond broadcasting and that it
should be advisory to the Department of Commerce in all matters of
government radio spectrum regulation.[Footnote 2] In a 1927 letter to
the Secretary of Commerce, the President affirmed IRAC's advisory role
and its mission to assign frequencies and coordinate federal government
spectrum use. In 1952, IRAC's mission was formally expanded to include
responsibilities for formulating and recommending policies, plans, and
actions for federal government spectrum use. Since its formation, IRAC
has advised the different entities responsible for exercising the
authority of the President to assign radio frequencies to federal
government users. Consequently, IRAC has reported through or to the
Secretary of Commerce; the FCC Chairman; the Telecommunications Advisor
to the President; the Director, Office of Defense Mobilization and its
successor agencies; the Director of Telecommunications Management; and
the Director, Office of Telecommunications Policy. By executive order,
in 1978, the Office of Telecommunications Policy was abolished and its
spectrum functions were transferred to the Department of Commerce.
Commerce formally established NTIA in 1978, and since then, IRAC has
directly advised NTIA. See figure 1 for a more detailed timeline of
IRAC's evolution.
Figure 1: Timeline of Key Dates in IRAC's Evolution:
[See PDF for image]
[End of figure]
As shown in figure 2, IRAC is currently comprised of 20 federal
agencies that use radio spectrum, a chairman and an executive secretary
from NTIA, and FCC as a nonvoting liaison.
Figure 2: The Federal Agencies Currently Represented on IRAC:
[See PDF for image]
Note: The NTIA represents other agencies that are not member agencies
of IRAC or are not represented by IRAC members (for example, the
Department of Treasury represents the Federal Reserve System).
[End of figure]
In addition to the full committee, IRAC mission responsibilities are
also carried out in six standing subcommittees, as well as a number of
ad hoc committees and working groups.
* Frequency Assignment Subcommittee: Assignment of frequencies in
government bands of spectrum.
* Spectrum Planning Subcommittee: Planning spectrum use and certifying
major government systems that will use radio frequencies.
* Radio Conference Subcommittee: Coordination of U.S. government
positions for international conferences where agreements are made
regarding the global and regional allocation of spectrum.
* Space Systems Subcommittee: International registration of government
satellite systems and development of procedures for implementing space-
related provisions of international agreements.
* Technical Subcommittee: Addresses issues that relate to the technical
aspects of the use of radio spectrum, including the development of new
technical standards and recommendations on better utilization of the
available spectrum.
* Emergency Planning Subcommittee: Formulation and review of emergency
preparedness planning for government spectrum-dependant systems.
Both the IRAC full committee and six IRAC subcommittees are chaired by
NTIA. From our interviews of IRAC representatives, we found that most
IRAC representatives are satisfied with the agencies that are members
of IRAC, the FCC liaison function, and the subcommittee missions.
Specifically, 15 of 20 representatives said that the appropriate
agencies are represented on IRAC. Seventeen IRAC representatives
believe that coordinating with FCC through a liaison appointed by FCC
is appropriate,[Footnote 3] and 15 representatives agreed that most of
the time, IRAC and FCC work well together. Thirteen of 19 IRAC
representatives said that the missions of the IRAC subcommittees are
appropriate, given current and future spectrum needs.
IRAC Representatives' Assessment of IRAC Is Mostly Positive, but Some
Are Concerned That an Uneven Level of Technical Knowledge and a Lack of
Seniority Limit IRAC's Effectiveness:
IRAC representatives generally agree that IRAC is effective in
coordinating federal government spectrum use but are concerned about
training and succession planning. IRAC and its subcommittees perform
various mission tasks related to coordinating federal government
spectrum use, including frequency assignment, certification of
spectrum-dependent equipment, coordination of U.S. government
positions for international conferences, and registration of U.S.
government satellite systems internationally. In our interviews with
IRAC representatives, they generally agreed that IRAC is effectively
accomplishing these spectrum coordination tasks. For example, 17 of 19
said that IRAC is very or mostly effective at assigning frequencies in
government-controlled spectrum, and 13 of 17 said that IRAC is very or
mostly effective at equipment certification for federal agencies.
However, training and succession planning issues could limit IRAC
coordination efforts. Eight representatives commented that some agency
representatives lack sufficient technical knowledge and/or
understanding of emerging technologies. This concern was also shared by
4 of the 6 subcommittee chairs, who believe that more technically
knowledgeable representatives would improve IRAC's performance. The
potential shortage of spectrum specialists in agencies could also limit
future IRAC coordination efforts. Ten out of 20 representatives are
already retirement eligible, and 3 more will become eligible in less
than 5 years. These concerns are consistent with the human capital
findings in our 2002 report on needed improvements in spectrum
management.[Footnote 4]
Greater concern was expressed about IRAC's ability to fulfill its
mission of providing high level policy advice on national spectrum
issues. NTIA officials and IRAC representatives said that IRAC's
effectiveness in this area is limited by the representatives' lack of
seniority. Seventeen out of 20 representatives said that national
spectrum policy formation must occur at a higher level than that held
by current IRAC members. According to NTIA, only one agency on IRAC has
assigned a member of the senior executive service as the agency
representative to IRAC and 13 of the 20 representatives said that the
assistant secretary who oversees spectrum management in their agency
has little or no direct involvement in spectrum management. The
chairman of IRAC (an NTIA senior executive) agrees with the majority of
IRAC representatives that current IRAC representatives are not senior
enough within their agencies to provide policy advice on issues
requiring either commercial or government users to share or relinquish
spectrum. He told us that he has gone outside of the IRAC framework
when he needed advice on such contentious policy issues, such as those
related to the introduction of new commercial communications services.
For example, the IRAC chairman said that he directly contacted senior
executives from the relevant agencies after he was unable to obtain
from the IRAC representatives viable advice on how to make possible the
introduction of commercial 3G and ultra wideband services. Both
services would require federal agencies to share or relinquish spectrum
under their control.[Footnote 5] The IRAC chairman said that he
supports more involvement of senior agency executives in IRAC.
As an advisor representing government spectrum concerns, IRAC must rely
on NTIA to negotiate with FCC in disputes between government and
commercial users over the use of spectrum. Most IRAC representatives
believe there should be a better way to resolve these disputes. When
new wireless technologies require access to government as well as
commercial spectrum, NTIA and FCC must cooperate in order to determine
which entity will have access to what spectrum. While IRAC must rely on
NTIA to negotiate with FCC to make those determinations, 10 of 20 IRAC
representatives have concerns about NTIA's ability or willingness to
support the needs of government agencies. Some representatives told us
they did not think either NTIA or the Department of Commerce is able to
protect the interests of government users; others told us that
government users could not be well represented by an agency whose
primary mission is to promote commercial interests. In addition, 14
IRAC representatives told us that their primary concern in the next 1
to 3 years will be either the availability of spectrum to fulfill
agency missions or the threat of harmful interference from new
technologies. Although almost three quarters of the 20 representatives
said that they believe that IRAC's advice does influence NTIA's
recommendations to the Assistant Secretary of Commerce, 13
representatives were able to cite important instances in which NTIA's
final position differed significantly from IRAC's advice. Of those
instances in which NTIA and IRAC differed, 7 IRAC representatives cited
recent decisions on issues of spectrum availability, such as 3G
services, or interference from new technologies, such as ultra
wideband. Most IRAC representatives said that a new process is needed
to resolve disputes between government and commercial users, but there
was no consensus among the representatives on what specifically would
improve the process.
IRAC representatives have varying opinions on whether IRAC needs to be
reformed, and if it does, what those reforms should be. Eight of the 20
representatives agreed that IRAC's organization and membership were
well suited to meet current and foreseeable challenges; 6 partially
agreed with that statement but thought some changes would improve IRAC.
Specifically, 4 representatives thought agency representatives should
be more knowledgeable or more senior, and 2 representatives said that
IRAC would be timelier in its decision-making if there were fewer
members. Six representatives did not believe that IRAC's organization
and membership are well suited to meet current and foreseeable spectrum
challenges.
The current IRAC chairman told us that he has instituted a number of
improvements in the past year designed to improve the efficiency and
effectiveness of IRAC. For example, the agendas for IRAC meetings are
made available electronically for representatives to review before
meetings and IRAC meeting minutes are now posted much faster than in
the past. The chairman remains concerned about the knowledge level of
some of the agency representatives and the number of IRAC
representatives who are eligible to retire. To improve the long-term
participation by agencies, he has explored the possibility of training
and certifying spectrum managers.
A federal task force led by the Department of Commerce was conducting
its work concurrently with our review and completed its report on a
wide range of spectrum issues in late June 2004.[Footnote 6] The report
included three recommendations that fit within the scope of this
report. It recommended: (1) the government develop training programs
for spectrum specialists; (2) the Department of Commerce form a policy
and plans steering group comprised of assistant secretary-level
officials from other agencies to provide advice on spectrum policies,
strategic plans, and contentious issues; and (3) the existing White
House Policy Coordinating Committee should be used to address spectrum
issues that could not be resolved by the previously mentioned policy
and plans steering group.
Conclusions:
IRAC representatives generally concur that IRAC's current structure and
membership are effective in dealing with key spectrum coordination
tasks that are at the core of its mission, including assigning
frequencies, certifying equipment, coordinating agency positions for
international spectrum conferences, and managing satellite issues.
IRAC's effectiveness in these areas could be strengthened by increasing
the level of technical knowledge of some members and ensuring that
agencies can provide qualified representatives to replace current
members as they reach retirement.
When it comes to dealing with contentious policy issues requiring
negotiation between government and commercial users, however, IRAC
representatives questioned the effectiveness of IRAC's current
structure and membership. There is a strong consensus that more senior-
level agency officials need to become involved in providing NTIA with
advice on contentious spectrum policy issues. While NTIA officials seek
out such senior-level advice as needed, this is an ad hoc process that
occurs outside the current framework of IRAC.
Recommendations for Executive Action:
In order to improve the effectiveness of IRAC's contribution in
spectrum management, we recommend that the Secretary of Commerce take
the following two actions:
* Direct the Assistant Secretary of Commerce for Communications and
Information to seek IRAC's assistance in establishing a set of best
practices in human capital for agencies that participate in IRAC that
include information on the appropriate knowledge and training levels
for IRAC representatives, goals for continuing education in emerging
technologies, and agency succession planning.
* Establish a special committee within IRAC comprised of senior-level
agency officials to be convened by the Assistant Secretary of Commerce
for Communications and Information as needed to provide policy advice
on contentious spectrum policy issues, such as those requiring either
commercial or government entities to share or relinquish spectrum.
Agency Comments and Our Evaluation:
We provided a draft of this report to NTIA, FCC, and the current IRAC
member agencies for their review. The Department of Agriculture, the
Department of the Treasury, National Science Foundation, NASA, and the
Broadcasting Board of Governors all said that they support the report
and its recommendations. The Departments of Justice, Health and Human
Services, Veterans Affairs, and the U.S. Postal Service and FCC did not
have any comments on the report. The Department of State (see letter at
app. II), and the Departments of Defense and Homeland Security offered
technical comments that we incorporated as appropriate.
The Department of Energy (DOE) supported the best practices in human
capital recommendation but indicated that a panel of independent
experts should rule on contentious issues (see letter at app. III). As
there was no consensus among the IRAC representatives as to how to
resolve spectrum policy disputes between government and commercial
interests, we chose not to make a recommendation on the issue. DOE also
stated that the report did not identify that IRAC representatives and
NTIA officials do not always share the same goals, an issue DOE views
as a key contention with regard to spectrum management. We did not
change the report because it already notes that fifty percent of IRAC
representatives have concerns about NTIA's ability or willingness to
support the needs of government agencies. The Department of the
Interior also agreed with the recommendation to improve IRAC
representatives' technical skills but disagreed with the recommendation
to establish a senior-level committee to provide advice on contentious
policy issues. It indicated that such a committee is not warranted
because IRAC has no decision-making authority (see letter at app. IV).
We chose not to change the recommendation because 17 of the 20 IRAC
representatives and the IRAC chairman believe that more senior-level
involvement is needed in formulating national spectrum policies. The
Navy said that it agreed in spirit with the report's recommendations
but suggested revising the wording of the second recommendation (see
letter at app. V).
The Department of Commerce agreed with our recommendation for
establishing best practices in human capital for the IRAC member
agencies, but also indicated, as did the Department of Transportation
(DOT), that a high level policy task force should be created within
Commerce but outside IRAC per the Federal Spectrum Task Force's
recommendation (see letter at app. VI). The primary difference between
the Federal Task Force recommendation and ours is that the Federal Task
Force recommended that a group of senior agency executives be formed
outside of IRAC to advise on policy issues, and we recommended that the
group be formed within the structure of IRAC. We chose not to change
the second recommendation. As IRAC has been a stable, successful
foundation for spectrum coordination for more than 80 years, we believe
that senior-level executives of IRAC member agencies will be most able
to provide useful advice on contentious spectrum policy issues.
As agreed with your offices, we are providing copies of this report to
the appropriate congressional committees, the Department of Commerce,
FCC, IRAC member agencies, and others who are interested. We will also
make copies available to others who request them. In addition, the
report will be available on the GAO Web site at
[Hyperlink, http://www.gao.gov]. If you or your staff members have any
questions about this report, please contact me on (202) 512-2834 or at
[Hyperlink, Goldsteinm@gao.gov]. Key contacts and staff
acknowledgments for this report are listed in appendix VII.
Sincerely yours,
Signed by:
Mark L. Goldstein:
Director, Physical Infrastructure Issues:
[End of section]
Appendixes:
Appendix I: Briefing Slides:
[See PDF for image]
[End of slide presentation]
[End of section]
Appendix II: Comments from the Department of State:
United States Department of State:
Assistant Secretary and Chief Financial Officer:
Washington, D.C. 20520:
Ms. Jacqueline Williams-Bridgers:
Managing Director:
International Affairs and Trade:
Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548-0001:
Aug. 23 2004:
Dear Ms. Williams-Bridgers:
We appreciate the opportunity to review your draft report,
"INTERDEPARTMENT RADIO ADVISORY COMMITTEE: IRAC Representatives
Effectively Coordinate Federal Spectrum But Lack Seniority to Advise on
Contentious Issues," GAO Job Code 543088.
The enclosed Department of State comments are provided for
incorporation with this letter as an appendix to the final report.
If you have any questions concerning this response, please contact Hal
Grigsby, Director, Bureau of Economic and Business Affairs, Office of
Telecommunication and Policy, at (202) 647-2723.
Sincerely,
Signed for:
Christopher B. Burnham:
cc: GAO - Keith Cunningham
EB - Shaun Donnelly
State/OIG - Mark Duda:
Department of State Comments on Draft Report by the Government
Accountability Office Entitled: INTERDEPARTMENT RADIO ADVISORY
COMMITTEE: IRA C Representatives Effectively Coordinate Federal
Spectrum But Lack Seniority to Advise on Contentious Issues. (GAO Code
543088):
The Department of State appreciates the opportunity to comment on the
report of the Government Accountability Office entitled:
INTERDEPARTMENT RADIO ADVISORY COMMITTEE: IRA C Representatives
Effectively Coordinate Federal Spectrum But Lack Seniority to Advise on
Contentious Issues. Since it is possible that this GAO report will be
used for purposes of reform of the IRAC, the report should recognize
certain State Department responsibilities that are carried out in the
IRAC's ad hoc groups. Further, comments regarding the recommendations
flowing from the President's Spectrum Policy Initiative should more
closely align with the comments in the report of the Federal Government
Spectrum Task Force.
Ad Hoc Groups 170 and 181 --Coordination with Mexico and Canada:
The Department leads IRAC's Ad Hoc Groups 170 and 181. These ad hoc
groups were formed in order to implement the Department's statutory
responsibility to give full consideration to the views of the Federal
Communications Commission, the National Telecommunications and
Information Administration, and a number of other federal agencies in
coordinating U.S. positions for negotiations of international
telecommunications agreements with Mexico and Canada. Given that the
report by GAO may be used for purposes of reform of the IRAC, the
Department believes that these activities should be included in the
report's discussion of the IRAC's organization and functions.
Clarification of Comments from the President's Spectrum Policy
Initiative:
Certain comments from the Recommendations of the Federal Government
Spectrum Task Force flowing from the President's Spectrum Policy
Initiative are summarized in the report and minor edits have been
provided separately to clarify the substance of those comments.
[End of section]
Appendix III: Comments from the Department of Energy:
Department of Energy:
Washington, DC 20585:
August 23, 2004:
Mark L. Goldstein:
Director, Physical Infrastructure Issues:
U.S. Government Accountability Office:
441 G. Street, NW:
Washington, DC 20548:
Thank you for giving the Department of Energy (DOE) the opportunity to
comment on the draft GAO report on the Interdepartment Radio Advisory
Committee (IRAQ (GAO-04-1028). In general, the report accurately
describes the evolution of the IRAC and identifies many of the
shortcomings of the committee.
We agree that the IRAC members need to be technically competent in the
area of spectrum management and with the recommendation that the
Assistant Secretary of Commerce for Communications and Information seek
the IRAC's assistance in establishing a set of best practices in human
capital for agencies that participate in IRAC. We believe the National
Telecommunications and Information Administration (NTIA) should
establish a spectrum management training program that leads to
certification through examination. In fact, DOE recommended this to the
IRAC chairman last year and proposed that certification could be
accomplished through the National Association of Radio and
Telecommunications Engineers (NARTE). This program would be invaluable
to agencies for training entry level employees in the spectrum
management field and would create a pool of individuals that would be
qualified as agency IRAC representatives and be capable of managing an
agency spectrum program. In addition, we believe that agency IRAC
representatives should be certified and hold a rank or grade at a level
commensurate with the level of authority to speak for the agency they
represent.
However, we do not concur that with the recommendation that NTIA
establish a special committee comprised of senior level agency
officials. A similar committee has been proposed by the Federal
Government Spectrum Task Force in their report to the President
entitled "Spectrum Policy for the 21 st Century - The President's
Spectrum Policy Initiative," and it would essentially have the same
function.
In addition, the report fails to identify the core issue that has led
to contention in the IRAC. The prime function of an IRAC representative
is to formulate, present, and defend agency positions that protect the
agency's spectrum assets from interference or from being transferred to
the commercial sector through FCC auctions. This is often in direct
conflict with the current Administration's agenda and its direction to
the NTIA, especially on matters that concern spectrum reallocation to
commercial enterprise for advanced wireless services or the development
of new technology such as Ultra Wideband (UWB). IRAC representatives
are evaluated on how effectively they can accomplish these objectives.
Obviously, it is not in their best interest to support proposals that
may jeopardize scarce spectrum resources or have the potential to
cause interference with their agency's critical spectrum dependent
systems.
We recommend that GAO consider the establishment of a panel of
independent experts that could make informed and unbiased decisions on
these contentious matters based on the information presented by the
impacted agencies and the proponents for the spectrum reallocation or
the new wireless technologies. The panel would weigh the pros and cons
of the proposal based on the information provided by both parties and
render a decision that would be in the best interest of taxpayers.
If you have any questions please contact Brian Klug of my staff on
(202)-586-6095.
Sincerely,
Signed by:
Rosita O. Parkes:
Chief Information Officer:
[End of section]
Appendix IV: Comments from the Department of the Interior:
United States Department of the Interior:
OFFICE OF THE ASSISTANT SECRETARY:
POLICY, MANAGEMENT AND BUDGET:
Washington, DC 20240:
AUG 2 3 2004:
Mark L Goldstein:
Director, Physical Security Issues:
Government Accountability Office:
441 G St. NW:
Washington, D.C. 20548:
Dear Mr. Goldstein:
The Department of the Interior (DOI) reviewed the Draft Government
Accountability Office (GAO) Report entitled, "Interdepartment Radio
Advisory Committee: IRAC Representatives Effectively Coordinate
Federal Spectrum but Lack Seniority to Advise on Contentious Issues"
(GAO-04-1028).
In the draft report, IRAC members noted the need for both more
technical and more senior membership. The need for more technical-level
discussions is apparent from the nature of the meetings themselves. The
meetings are typically very technical, frequent, and long: The agenda
can include up to 50 or more technical items, relatively few of which
may directly impact a particular agency mission. IRAC uses a three-step
process for issue development. (1) The issue is put on the agenda with
supporting information at one meeting. (2) At a later meeting, the
merits of the issue are discussed. (3) At a third or later meeting, a
vote is taken. Issues are frequently tabled while member agencies
research technical or policy points. Some agenda items can take months
to come to a vote.
The DOI agrees with the recommendation to continue to improve IRAC
members' technical skills. DOI recognizes the National
Telecommunications and Information Agency's (NTIA) efforts in this
regard.
DOI does not agree with the recommendation to establish an executive
committee for policy advice on sensitive spectrum policy issues. The
need for an executive level body arises only if the IRAC functions as
the decision-making authority for issues before it. As this authority
rests with NTIA, the IRAC does not appear to warrant this level of
involvement from senior agency officials. The DOI will provide senior-
level advice to NTIA officials whenever warranted without establishing
a separate executive committee.
Thank you for the opportunity to review the draft report. For
additional information, please contact Mr. W. Hord Tipton at (202) 208-
6194.
Sincerely,
Signed by:
P. Lynn Scarlett:
Assistant Secretary:
Policy, Management and Budget:
[End of section]
Appendix V: Comments from the Department of the Navy:
DEPARTMENT OF THE NAVY:
CHIEF INFORMATION OFFICER:
1000 NAVY PENTAGON:
WASHINGTON, DC 20350-1000:
18 August 2004:
MEMORANDUM FOR DIRECTOR, PHYSICAL INFRASTRUCTURE ISSUES, U.S.
GOVERNMENT ACCOUNTABILITY OFFICE:
SUBJECT: GAO Draft Report: IRAC Representatives Effectively Coordinate
Federal Spectrum But Lack Seniority to Advise on Contentious Issues
(GAO Code 543088/ GAO-04-1028):
We have reviewed the subject GAO Draft Report 04-1028 and appreciate
the opportunity to provide comment to the U.S. Government
Accountability Office, Director for Physical Infrastructure Issues, Mr.
Mark L. Goldstein.
In spirit, we agree with both recommendations in the draft report for
executive action. However, with respect to establishment of a special
IRAC committee, we ask that consideration be given to the following
revision:
"Establish a special committee within IRAC comprised of senior
executives from member agencies to be convened by the Assistant
Secretary of Commerce for Communications and information as needed to
provide policy advice on contentious spectrum policy issues, such as
those requiring either commercial or government entities to share or
relinquish spectrum."
You will note that our proposed change reflects terminology found on
page 3 of the draft report under the subheading Results in Brief. We
believe the phrase 'senior executives from member agencies' is an
important distinction, ensuring Department of the Navy representation
in the development of national spectrum policy and resolution of
sensitive spectrum policy issues.
The DON CIO point of contact for this matter is Mr. John J. Lussier,
(703) 604-7050, john.lussier@navy.mil.
Signed by:
D.M. Wennergren:
Copy to:
Keith Cunningham (GAO):
[End of section]
Appendix VI: Comments from the Department of Commerce:
THE SECRETARY OF COMMERCE:
Washington, D.C. 20230:
August 17, 2004:
Mr. Mark L. Goldstein:
Director, Physical Security Issues:
United States Government Accountability Office:
Washington, DC 20548:
Dear Mr. Goldstein:
Thank you for providing the Department of Commerce with an opportunity
to comment on the draft report entitled "Interdepartment Radio Advisory
Committee - IRAC Representatives Effectively Coordinate Federal
Spectrum But Lack Seniority to Advise on Contentious Issues" (GAO-04-
1028). I commend the Government Accountability Office (GAO) for
conducting an independent review of government's processes for managing
the use of spectrum to meet its communications needs.
As you note in your report, President Bush has undertaken the "Spectrum
Policy for the 21ST Century" initiative to promote the development and
implementation of a U.S. spectrum policy that will foster economic
growth; ensure our national and homeland security; maintain U.S. global
leadership in communication technology; and satisfy U.S. needs in areas
such as public safety, scientific research, federal transportation
infrastructure, and law enforcement. As a result of the initiative, I
recently submitted two reports to the President containing 24
recommendations to improve spectrum management.
GAO recommends "that the Secretary of Commerce: (1) seek IRAC's
assistance in establishing a set of best practices for training and
succession planning to guide agencies' participation in IRAC; and (2)
establish a special IRAC committee comprised of senior level agency
officials as needed to provide policy advice on contentious spectrum
policy issues." GAO's recommendations are similar to recommendations in
the reports I submitted to the President. I recommended to the
President that a career development program should be instituted to
provide training for new spectrum management personnel (government and
non-government) in need of technical disciplines or continued
competency, and that a senior level group be established to provide
advice to Commerce's Assistant Secretary for Communications and
Information and to help resolve policy issues (not resolved by the
current IRAQ that affect the use of spectrum by federal government and
non-federal users. However, I recommended that the new advisory group
would be better positioned to address unresolved issues if it is
convened outside of the existing IRAC.
I hope you find these views helpful. If you have any additional
questions about the Department of Commerce's role in spectrum
management policy, please contact Michael D. Gallagher, Assistant
Secretary for Communications and Information, at (202) 482-1840.
Sincerely,
Signed by:
Donald L. Evans:
[End of section]
Appendix VII: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Mark Goldstein (202) 512-2834 John Finedore (202) 512-6248:
Acknowledgments:
In addition to the individuals named above, Keith Cunningham, Brad
Dubbs, Michele Fejfar, Alwynne Wilbur, and Nancy Zearfoss made key
contributions to this report.
[End of section]
Related GAO Products:
[End of section]
Spectrum Management: Better Knowledge Needed to Take Advantage of
Technologies That May Improve Spectrum Efficiency.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-666].
Washington, D.C.: May 28, 2004.
Spectrum Management in Defense Acquisitions.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-617R].
Washington, D.C.: April 30, 2003.
Telecommunications: Comprehensive Review of U.S. Spectrum Management
with Broad Stakeholder Involvement Is Needed.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-277]
Washington, D.C.: January 31, 2003.
Telecommunications: Better Coordination and Enhanced Accountability
Needed to Improve Spectrum Management.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-02-906]
Washington, D.C.:
September 30, 2002.
Telecommunications: History and Current Issues Related to Radio
Spectrum Management.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-02-814T]
Washington, D.C.: June 11, 2002.
Defense Spectrum Management: More Analysis Needed to Support Spectrum
Use Decisions for the 1755-1850 MHz Band.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-01-795]
Washington, D.C.: July 20, 2001.
Defense Spectrum Management: New Procedures Could Help Reduce
Interference Problems.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-01-604]
Washington, D.C.: May 17, 2001.
Telecommunications: Federal Communications Commission Spectrum
Management. RCED-89-62. Washington, D.C.: January 12, 1989.
(543088):
FOOTNOTES
[1] The radio frequency spectrum is the medium that makes possible
wireless communications, such as mobile phone, radar, and radio and
television broadcasting services and is accessed by government and
commercial users. The radio waves used by wireless devices are a form
of electromagnetic radiation made up of a series of waves of electric
and magnetic energy that move together though space. Although the
electromagnetic spectrum is vast, 90 percent of use is concentrated in
the lowest 1 percent of the frequencies because the characteristics of
those frequencies are favorable to many applications.
[2] Originally named the Interdepartment Advisory Committee on
Governmental Radio Broadcasting, in 1923 the committee was renamed the
Interdepartment Radio Advisory Committee.
[3] Up until 1952 the FCC participated in IRAC as a voting member.
However, since that time FCC has appointed a liaison that assists in
providing coordination on spectrum issues with NTIA.
[4] GAO, Telecommunications: Better Coordination and Enhanced
Accountability Needed to Improve Spectrum Management, GAO-02-906
(Washington, D.C.: Sept. 30, 2002).
[5] Third generation or 3G services enable handheld communication
devices to provide both voice and high-speed data. Ultra wideband
devices employ very narrow or short duration pulses to create wideband
transmissions.
[6] Spectrum Policy for the 21ST Century--The President's Spectrum
Policy Initiative: Report 1 Recommendations of the Federal Government
Spectrum Task Force, Michael D. Gallagher, Acting Assistant Secretary
for Communications and Information, U.S. Department of Commerce, June
2004.
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