New GAO Report on Federal Agency Spectrum Use:
In Post 9/11 Era Old Problems Continue

A new report by the Government Accountability Office (GAO) concludes that the federal agencies that use spectrum continue their traditional practices of building and operating their own individual radio systems systems despite the penalties associated with such independent operations with respect to

• inefficient spectrum use
• interoperability problems and
  
• increased cost

But don't blame FCC for this one. Federal spectrum use is not FCC's job - indeed FCC can not even assign itself spectrum for its own internal operations. The Communications Act of 1934 follows its 1928 predecessor and gives jurisdiction over federal spectrum use to the President (47 USC 305). The President, being rather busy with other things, delegates this chore to the others. For a long time it was delegated to the Office of Telecommunications Policy (and its predecessor, the Office of Telecommunications Management) in the White House. But in a series of actions begun by President Nixon and finished by President Carter the functions of OTP moved out of the White House to the Department of Commerce's National Telecommunications and Information Administration (NTIA). Frankly it isn't clear what Nixon and Carter were trying to accomplish in these changes. One legend is that Nixon wanted to bring additional staff into the White House, e.g. the Watergate-era "plumbers", so he had to trim other staff.

NTIA is headed by the Assistant Secretary for Communications and Information, presently Meredith Attwell Baker. The fundamental problem in federal spectrum management is that an assistant secretary in the Commerce Department, no matter how well intentioned, can not tell other federal agencies how to use their radio spectrum and how to spend their own money on wireless systems. Thus, in practice almost all federal agency spectrum policy is made in practice by Interdepartment Radio Advisory Committee (IRAC), consisting of military and civilian federal employees who represent their agencies. The IRAC meets secretly every two weeks in a windowless room in the Commerce Department - although outsiders can occasionally make presentations on matters of mutual interest. While from time to time the NTIA staff jawbones the IRAC members, most of the time NTIA's Office of Spectrum Management could be better called the "IRAC Secretariat" - scheduling meetings and compiling the wishes of IRAC members.

So it is no surprise what GAO has found it its new report.

The tragic events of September 11, 2001, and Hurricane Katrina have highlighted the critical importance of having effective radio communications systems for law enforcement and public safety agencies including federal agencies with such responsibilities. In order to effectively respond to events such as natural disasters, criminal activities, and domestic terrorism, law enforcement and public safety agencies need reliable systems that enable communication with their counterparts in other disciplines and jurisdictions. Further, since the 1990s, increasing demand for radio communications capabilities in both the private and public sectors has created a need to use radio communications capacity more efficiently.

The Integrated Wireless Network (IWN) was intended to be a collaborative effort among the Departments of Justice (DOJ), Homeland Security (DHS), and the Treasury to provide secure, seamless, interoperable,1 and reliable nationwide wireless communications in support of federal agents and officers engaged in law enforcement, protective services, homeland defense, and disaster response missions. This initiative, begun in 2001, was originally estimated to cost approximately $5 billion.

...

DOJ, DHS, and the Treasury had originally intended IWN to be a joint radio communications solution to improve communication among law enforcement agencies; however, IWN is no longer being pursued as a joint development project. Instead of focusing on a joint solution, the departments have begun independently modernizing their own wireless communications systems.

In abandoning collaboration on a joint solution, the departments risk duplication of effort and inefficiency as they continue to invest significant resources in independent solutions. Further, these efforts will not ensure the interoperability needed to serve day-to-day law enforcement operations or a coordinated response to terrorist or other events. While collaboration on a joint solution is critical for success, this joint solution need not be based necessarily on a single, nationwide network, such as an extension of the original IWN design. It could also consist of a mutually agreed-upon strategy for developing separate but interoperable networks and systems that incorporate lessons learned from past efforts.

We have previously written how the UK's spectrum managers created a nationwide interoperable public safety system called "Airwave". If the US can't even get 3 federal agencies to cooperate, how could we ever make significant progress in public safety interoperability? (Note that Airwave uses Tetra technology which is not the choice for a new system in the US at this time. This comment on Airwave deals with the UK government's effective leadership, not the specific technology they chose a decade ago for a different environment.)

Several years ago the White House noted that the organizational structure needed some changing and proposed to move NTIA to Commerce's Undersecretary for Technology. (At present this post is vacant.) The federal agencies vehemently protested, claiming that putting another layer between NTIA and a cabinet official would decrease NTIA's power. In reality they were almost certainly concerned that the Undersecretary for Technology was a higher level political appointee than the head of NTIA and that as a federal CTO-like official could actually start supervising the policies developed in IRAC rather than rubber stamping them. The IRAC members want NTIA to act as their cheerleader, propagandist, and file clerk. What the country and federal spectrum management really need is "tough love" and leadership from whoever exercises the President's §305 authority. The Secretary of Defense is the Executive Agent for communications security and the Director, National Security Agency is the national manager for COMSEC matters. They consult with agencies about COMSEC policies, but they do not kowtow to them as NTIA does.

Note to the Obama Administration: If you want to improve spectrum management - the key to a lot of potential economic growth - you must make NTIA and IRAC more accountable for their policies and actions. Much as I hate reorganizations, I really think NTIA's spectrum management function either has to be moved back to the White House or put under the federal CTO or CIO. Someone has to be asking federal spectrum users hard questions, not just stapling together their individual requests. Only then can the government seek ways to balance federal, state and local government, and private sector spectrum use in a coherent national policy.

COTS* Millimeter Wave Technology
that Was Opposed by DoD's IRAC Representatives
is Now Saving Lives in Iraq:
Dual Use Spectrum Technology in Practice

An article in USA Today introduced Project Angel Fire to the public,

"A Marine in Iraq scans a screen with images of the streets he'll soon patrol. Spotting suspicious movement, he replays the digital video, just like a TV viewer who's missed a play from a football game.

The cutting-edge surveillance system, called Angel Fire, uses aircraft armed with cameras to monitor the battlefield. It gives troops what U.S. commanders in Iraq have sought for years: a persistent, bird's-eye view to search roads and neighborhoods for improvised explosive devices (IEDs) and the insurgents who plant them.

'Angel Fire distributes real-time imagery straight to the war fighter, providing the ability to zoom in and observe an area more closely,' John Young, director of Defense Research and Engineering at the Pentagon, told Congress in March. 'Angel Fire also allows for playback of significant events with a 'TiVo-like' capability to monitor areas.' "

A more detailed description of the project from the Air Force Institute of Technology states,

"Project Angel Fire’s sub-title is “Wide Area Persistent Imaging of City Sized Area for Rapid Deployment to Theater”. It is a USSTRATCOM sponsored - U.S. Central Command (USCENTCOM) supported project aimed at providing real time tactical level situational awareness to commanders and soldiers in theater this year. We accomplish this aim by producing intelligence sufficient to identify and track both people and vehicles using ultra large format digital 6 to 54 11-megapixel camera arrays to collect town to city-sized images at 0.5 meter ground sampling distances. Project Angel Fire’s system georectifies these images and can send them to anywhere from one to several hundred users in real time using commercial wireless data links. The system records past data enabling a TiVo-like playback of any area of the town at any sized image at full resolution. This rapid development effort has in six months demonstrated the capability to provide real time tactical situational awareness to battle field commanders and soldiers in the field or at command posts.

It also provides the intelligence community the ability to develop longer term intelligence analysis of organizations’ social networks by tracking and observing their interactions between different locations. Also during these first six months we have developed two flying prototype systems and are working on a fully deployable and scaleable system. Portions of our project are preparing to deploy to the Iraqi theater in support of the Army Mohawk Stare program.

Forty-one graduate students and four faculty members of the Research and Development Management Program, the Operational Technology Certificate Program and the Systems Design and Management Program supported this project. To date the Angel Fire project has received approximately $2.1M from the intelligence community and USSTRATCOM, and we are leveraging significantly more resources through our partnering arrangements."

So, how do you get high resolution real time video from a military aircraft to ground based units? Apparently the DoD technology base had no convenient solutions, so the AFIT developers with help from Los Alamos National Laboratory turned to COTS technology. Note the white object at the right end of the Angel Fire unit shown above. It is an HXI Terabeam commercial millimeter wave point-to-point system that was procured off the shelf for Project Angel Fire and used unmodified except for an external gimbal mount.

I have recounted on my website the history of the FCC millimeter wave rules. That discussions focuses on the internal FCC problems, but it turns out that there were other problems with coordination with NTIA and IRAC. The National Telecommunications and Information Administration has been delegated the President's 47 USC 305 power to regulate federal agency use of spectrum in parallel with FCC's authority. But in practice most of NTIA's spectrum decisions are made by the Interdepartment Radio Advisory Committee, an interagency committee (actually the oldest in the Federal Government) that meets in a windowless room in the Herbert Hoover Commerce Department Building every 2 weeks with only occasional outside observers. FCC and NTIA have agreed to coordinate spectrum policy decisions with each other in bands that are shared. As you can see from the table excerpt here, unlike lower bands virtually all the millimeter wave bands are shared because the two agencies have never divided them up in into "his" and "hers" and "ours" like the lower bands. Thus all spectrum policy decisions become mutual issues.

When FCC went to IRAC to discuss the civil use proposals in Dockets 94-124 and 02-146 we argued that dual use was good for both sides as DoD could no longer afford to be the sole user of spectrum regions because of the fixed costs of component development. This concept of "dual use"was not an FCC-originated one, rather it came from the the R&D leaders of the Pentagon who were pushing dual use in general.

A DARPA-funded study by Potomac Institute for Policy Studies concluded

1. Dual use can make major improvements in warfighting capabilities and affordability of military systems – and it is faster.

2. Commercial success is crucial to maximizing military benefits through dual use.

But the DoD representatives at IRAC don't work for the R&D people, they work for the operational side of the military and were concerned about creating facts that would block future military use of spectrum. At lower bands, sharing is more difficult because omnidirectional antennas are often used and radio wave propagation allows signals to go a long distance. But in the millimeter wave region , highly directional antennas (less thank 1 degree beamwidth) are usually used and atmospheric molecular absorption, insignificant at lower bands, limits propagation and hence interference potential.

Only with great difficulty did FCC succeed in obtaining the cooperation of NTIA and IRAC to permit rules to be adopted in Dockets 94-124 and 02-146 since there were no civil "requirements" for millimeter wave spectrum in their eyes. (NTIA and IRAC had tried in the early 1980s to block for different reasons the spread spectrum rules in Docket 83-114 that ultimately became the basis of Wi-Fi and Bluetooth.)

So it is ironic today that the DoD uses both Wi-Fi technology and millimeterwave technology to further its missions. Dual use can be a win-win situation for the both the civil economy and DoD. I hope that the spectrum managers at DoD, IRAC, and NTIA look at the lessons here, read the quoted Potomac Institute report, and consider dual use issues in their considerations of new spectrum technologies.

* COTS = commercial off the shelf