Interdepartment Radio Advisory Committee: IRAC Representatives	 
Effectively Coordinate Federal Spectrum but Lack Seniority to	 
Advise on Contentious Policy Issues (30-SEP-04, GAO-04-1028).	 
                                                                 
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. 		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-1028					        
    ACCNO:   A12801						        
  TITLE:     Interdepartment Radio Advisory Committee: IRAC	      
Representatives Effectively Coordinate Federal Spectrum but Lack 
Seniority to Advise on Contentious Policy Issues		 
     DATE:   09/30/2004 
  SUBJECT:   Information technology				 
	     Telecommunication					 
	     Radio frequency allocation 			 
	     Agency missions					 
	     Internal controls					 

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GAO-04-1028

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

Contents

Figures

September 30, 2004Letter

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.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.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

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

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).

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.

o Frequency Assignment Subcommittee: Assignment of frequencies in
government bands of spectrum.

o Spectrum Planning Subcommittee: Planning spectrum use and certifying
major government systems that will use radio frequencies.

o Radio Conference Subcommittee: Coordination of U.S. government positions
for international conferences where agreements are made regarding the
global and regional allocation of spectrum.

o Space Systems Subcommittee: International registration of government
satellite systems and development of procedures for implementing
space-related provisions of international agreements.

o 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.

o 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,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.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.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 2004.6 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:

o 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.

o Establish a special committee within IRAC comprised of senior-level
agency officials to be convened by the Assistant Secretary of Commerce for
Communications and Information as needed to provide policy advice on
contentious spectrum policy issues, such as those requiring either
commercial or government entities to share or relinquish spectrum.

Agency Comments and Our Evaluation

We provided a draft of this report to NTIA, FCC, and the current IRAC
member agencies for their review. The Department of Agriculture, the
Department of the Treasury, National Science Foundation, NASA, and the
Broadcasting Board of Governors all said that they support the report and
its recommendations. The Departments of Justice, Health and Human
Services, Veterans Affairs, and the U.S. Postal Service and FCC did not
have any comments on the report. The Department of State (see letter at
app. II), and the Departments of Defense and Homeland Security offered
technical comments that we incorporated as appropriate.

The Department of Energy (DOE) supported the best practices in human
capital recommendation but indicated that a panel of independent experts
should rule on contentious issues (see letter at app. III). As there was
no consensus among the IRAC representatives as to how to resolve spectrum
policy disputes between government and commercial interests, we chose not
to make a recommendation on the issue. DOE also stated that the report did
not identify that IRAC representatives and NTIA officials do not always
share the same goals, an issue DOE views as a key contention with regard
to spectrum management. We did not change the report because it already
notes that fifty percent of IRAC representatives have concerns about
NTIA's ability or willingness to support the needs of government agencies.
The Department of the Interior also agreed with the recommendation to
improve IRAC representatives' technical skills but disagreed with the
recommendation to establish a senior-level committee to provide advice on
contentious policy issues. It indicated that such a committee is not
warranted because IRAC has no decision-making authority (see letter at
app. IV). We chose not to change the recommendation because 17 of the 20
IRAC representatives and the IRAC chairman believe that more senior-level
involvement is needed in formulating national spectrum policies. The Navy
said that it agreed in spirit with the report's recommendations but
suggested revising the wording of the second recommendation (see letter at
app. V).

The Department of Commerce agreed with our recommendation for establishing
best practices in human capital for the IRAC member agencies, but also
indicated, as did the Department of Transportation (DOT), that a high
level policy task force should be created within Commerce but outside IRAC
per the Federal Spectrum Task Force's recommendation (see letter at app.
VI). The primary difference between the Federal Task Force recommendation
and ours is that the Federal Task Force recommended that a group of senior
agency executives be formed outside of IRAC to advise on policy issues,
and we recommended that the group be formed within the structure of IRAC.
We chose not to change the second recommendation. As IRAC has been a
stable, successful foundation for spectrum coordination for more than 80
years, we believe that senior-level executives of IRAC member agencies
will be most able to provide useful advice on contentious spectrum policy
issues.

As agreed with your offices, we are providing copies of this report to the
appropriate congressional committees, the Department of Commerce, FCC,
IRAC member agencies, and others who are interested. We will also make
copies available to others who request them. In addition, the report will
be available on the GAO Web site at http://www.gao.gov. If you or your
staff members have any questions about this report, please contact me on
(202) 512-2834 or at [email protected]. Key contacts and staff
acknowledgments for this report are listed in appendix VII.

Sincerely yours,

Mark L. Goldstein Director, Physical Infrastructure Issues

Briefing SlidesAppendix I

Comments from the Department of StateAppendix II

Comments from the Department of EnergyAppendix III

Comments from the Department of the InteriorAppendix IV

Comments from the Department of the NavyAppendix V

Comments from the Department of CommerceAppendix VI

GAO Contacts and Staff AcknowledgmentsAppendix VII

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.

Related GAO Products

Spectrum Management: Better Knowledge Needed to Take Advantage of
Technologies That May Improve Spectrum Efficiency. GAO-04-666. Washington,
D.C.: May 28, 2004.

Spectrum Management in Defense Acquisitions. GAO-03-617R. Washington,
D.C.: April 30, 2003.

Telecommunications: Comprehensive Review of U.S. Spectrum Management with
Broad Stakeholder Involvement Is Needed. GAO-03-277. Washington, D.C.:
January 31, 2003.

Telecommunications: Better Coordination and Enhanced Accountability Needed
to Improve Spectrum Management. GAO-02-906. Washington, D.C.: September
30, 2002.

Telecommunications: History and Current Issues Related to Radio Spectrum
Management. GAO-02-814T. Washington, D.C.: June 11, 2002.

Defense Spectrum Management: More Analysis Needed to Support Spectrum Use
Decisions for the 1755-1850 MHz Band. GAO-01-795. Washington, D.C.: July
20, 2001.

Defense Spectrum Management: New Procedures Could Help Reduce Interference
Problems. GAO-01-604. Washington, D.C.: May 17, 2001.

Telecommunications: Federal Communications Commission Spectrum Management.
RCED-89-62. Washington, D.C.: January 12, 1989.

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