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entitled 'Interdepartment Radio Advisory Committee: IRAC 
Representatives Effectively Coordinate Federal Spectrum but Lack 
Seniority to Advise on Contentious Policy Issues' which was released on 
September 30, 2004.

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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 governmentís 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 IRACís key role in spectrum 
management, Congress asked us to (1) describe the evolution of IRAC 
and (2) obtain IRAC agency representativesí assessment of IRACís 
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, IRACís 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 Commerceís 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 representativesí uneven level 
of technical knowledge. This problem could worsen, as one-half of the 
20 current IRAC representatives are currently eligible to retire.
* IRACís ability to advise on national spectrum policy issues is 
limited because of representativesí 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 IRACís effectiveness and 
areas in need of reform.

What GAO Recommends:

GAO is recommending that the Secretary of Commerce: (1) seek IRACís 
assistance in establishing a set of best practices for training and 
succession planning to guide agenciesí 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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