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entitled 'Spectrum Management in Defense Acquisitions' which was 
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April 30, 2003:

The Honorable John Warner:

Chairman:

The Honorable Carl Levin:

Ranking Minority Member:

Committee on Armed Services:

United States Senate:

The Honorable Duncan L. Hunter:

Chairman:

The Honorable Ike Skelton:

Ranking Minority Member:

Committee on Armed Services:

House of Representatives:


Subject: Spectrum Management in Defense Acquisitions:

The electromagnetic radio frequency spectrum is critical to the 
development and operation of a variety of military systems such as 
radios, radars, and satellites. Due to the changing nature of 
warfighting, more and more military systems depend on the spectrum to 
guide precision weapons and obtain information superiority. In recent 
years, demand for the spectrum increased with advances in commercial 
technology. This demand has led to competition between government and 
nongovernment users, making spectrum management vital to prevent 
harmful interference and to promote spectrum efficiency.

With these goals in mind, DOD has long-standing policies and procedures 
that require system developers and acquirers to consider and deal with 
spectrum supportability knowledge early in the development and 
acquisition of systems. Early assessment of spectrum needs provides DOD 
the opportunity to identify, and therefore, better manage program and 
operational risks. DOD policy requires developers of spectrum dependent 
systems to obtain certification before assumption of contractual 
obligations for the full-scale development, production or procurement 
of those systems.

Senate Report 107-151 and House Report 106-945 required us to assess 
the Department of Defense's (DOD) spectrum management process.[Footnote 
1] We focused our assessment on (1) the results of the DOD spectrum 
certification processes and (2) the reasons for those results. To 
determine the results of DOD's spectrum certification processes and the 
reasons for those results, we reviewed relevant program documents and 
interviewed key officials. We also sent out a data collection 
instrument to selected research and development, and user commands to 
further identify and gather information on spectrum-dependent systems 
currently being developed or acquired. We conducted our work from April 
2002 through March 2003 in accordance with generally accepted 
government auditing standards and relied upon agency-provided data. 
This report transmits the information provided in earlier briefings. 
(See enc. I):

We found that DOD's weapons programs have often failed to obtain, 
consider, or act upon adequate spectrum supportability knowledge during 
the early stages of acquisition. A majority of programs try to gain 
this knowledge at later stages, after key system development decisions 
may have been made. As a result, some programs experience significant 
delays, reduced operational capabilities, or the need for expensive 
redesign. More importantly, these programs missed opportunities to 
improve program results and avoid problems that are more costly to 
resolve late in development or fielding.

Also, in a review of selected programs still under development, we 
found that consideration of spectrum supportability continues to be a 
problem. DOD is still entering into contracts, starting full-scale 
development, and sometimes fielding systems before obtaining 
certification of spectrum supportability.

The reasons for this late attention include program managers' lack of 
awareness of spectrum certification requirements, dated and unclear 
spectrum management guidance that is not aligned with current 
acquisition models, the competing demands of program managers, and a 
lack of effective enforcement mechanisms for existing spectrum 
certification requirements. Additional challenges to DOD implementing 
the spectrum certification process include the lengthy spectrum 
certification process, increased reliance on commercial communications 
services and cutting-edge technologies that challenge the traditional 
allocation of spectrum frequencies.

Recommendations for Executive Action:

To avoid delays, reduced operational capabilities, and costly redesign 
of weapon systems, we are making recommendations to ensure that 
spectrum supportability considerations are appropriately addressed in 
the development and acquisition of weapon systems. We recommend that 
the Secretary of Defense:

Direct the Under Secretary of Defense for Acquisition, Technology and 
Logistics; the Assistant Secretary of Defense for Command, Control, 
Communications and Intelligence; and appropriate service officials to 
update the spectrum supportability guidance contained in their 
respective spectrum management and acquisition policy directives and 
instructions to:

Ensure program managers develop spectrum supportability knowledge, 
apply for spectrum certification, and consider spectrum operational 
risks at the earliest points possible,

Provide uniformity of spectrum management policies across the services, 
and:

Provide a spectrum certification process with the flexibility to align 
with current acquisition models.

Measure spectrum management compliance and process performance to 
determine how well spectrum supportability considerations are addressed 
in the acquisition process.

Establish and ensure appropriate funding for a program of record to 
develop a spectrum management automation architecture and to implement 
current and future spectrum management automation development efforts.

We also recommend that the Secretary of Defense identify an official or 
officials within the Office of the Under Secretary of Defense for 
Acquisition, Technology and Logistics to:

Be accountable for oversight and enforcement of spectrum management in 
the acquisition process,

Establish a mechanism to identify to the spectrum management community 
new systems that may ultimately require spectrum certification,

Establish a mechanism that provides the spectrum management community 
program schedule data for systems that may require spectrum 
certification both to facilitate their prioritization of work effort 
and enable measurement of process enforcement and responsiveness, and:

Establish a mechanism to ensure--in line with DOD Directive 4650.1--
that programs requiring spectrum certification do not proceed beyond 
Milestone B of the acquisition process without approved spectrum 
certification. In order to allow acquisition flexibility when required, 
waivers may be allowed by the official or officials identified within 
the Office of the Under Secretary based on appropriate cause, risk 
mitigation strategy, and compliance deadline.

Agency Comments and Our Evaluation:

In providing oral comments on a draft of our report, DOD agreed with 
our findings and concurred or partially concurred with our 
recommendations. Specifically, in our first set of recommendations, DOD 
concurred with our recommendation to update the spectrum supportability 
guidance in its spectrum management and acquisition policy directives 
and instructions, but stated that it would like GAO to clarify whether 
our recommendation applies to the previous DOD 5000-series acquisition 
publications or the current versions. We believe that the current and 
future versions of those publications need to address the issues 
identified in our recommendation. DOD also concurred with our 
recommendation regarding the need to measure spectrum management 
compliance and process performance, but indicated that the resources to 
be expended implementing this recommendation could be better directed 
towards improving oversight and enforcement mechanisms in the 
acquisition process. While we believe that improved oversight and 
enforcement are important, it will be difficult for DOD to determine 
effective actions for improving oversight and enforcement without 
performance measures.

DOD partially concurred with our recommendation to establish and ensure 
appropriate funding for a program of record to develop a spectrum 
automation architecture and to implement future spectrum automation 
development efforts. DOD correctly understood the intent of the 
recommendation, but suggested that we clarify it by adding the word 
management to describe the covered activities. We agreed and have made 
that change. DOD also stated that implementation of this recommendation 
for other than current, on-going efforts, will be subject to the 
availability of funds. We believe that adequate funding needs to be 
ensured so that efforts to develop spectrum automation tools proceed in 
a coordinated, logical manner and provide managers with effective tools 
to address spectrum supportability considerations.

DOD also partially concurred with our second set of recommendations. 
DOD commented that it has a process in place for oversight and 
enforcement of spectrum management in the acquisition process that 
includes mechanisms to minimize programs proceeding beyond Milestone B 
without spectrum certification. DOD also indicated that the absence of 
certification should not preclude moving past that milestone. While we 
agree with DOD that a process does exist, our review confirms that the 
process is not being effectively followed and weapon programs do not 
address spectrum supportability issues until the later stages of 
development when addressing those issues can be much more costly. 
Without stronger enforcement and accountability, it is unlikely defense 
program managers will change their behaviors, which are motivated by 
the need to move through program milestones in order to achieve the 
next funding increment. Stronger enforcement and oversight would ensure 
the program obtains spectrum knowledge early in product development and 
increase the likelihood of success.

DOD also provided technical comments to a draft of this report that we 
incorporated where appropriate.

- - - --:

Unless you publicly announce the contents of this report earlier, we 
plan no further distribution of this letter until 30 days after the 
date of this letter. At that time, we will send copies of this letter 
to the Secretary of Defense; Secretary of the Air Force; Secretary of 
the Army; Secretary of the Navy; Commandant of the Marine Corps; 
Director, Office of Management and Budget; and interested congressional 
committees. We will also make copies available to other interested 
parties upon request. In addition, the report will be available at no 
charge on the GAO's Web site at http://www.gao.gov.

Please contact me at (202) 512-4841 or John Oppenheim at (202) 512-3111 
if you or your staff have any questions concerning this report. Other 
major contributors to this report were Julie Leetch, Gary Middleton, 
Jay Tallon, and Bruce Thomas.

Katherine V. Schinasi:

Director:

Acquisition and Sourcing Management:

Signed by Katherine V. Schinasi:

Enclosure:

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FOOTNOTES

[1] Senate Report 107-151, "National Defense Authorization Act for 
Fiscal Year 2003" [To accompany S. 2514]; and House Report 106-945 
"Enactment of Provisions of H.R. 5408, The Floyd D. Spence National 
Defense Authorization Act for Fiscal Year 2001," Conference Report to 
Accompany H.R. 4205; 
October 6, 2000.