CTIA Joins Growing Chorus Opposing Military Spectrum Veto

In a November 13 letter to congressional leadership, CTIA President & CEO Ajit Pai warned that Section 1564 of the version of the 2026 National Defense Authorization Act (NDAA) that passed the Senate imposes an "unnecessary" restriction on NTIA's ability to migrate existing military spectrum users into the 3.1-3.45 GHz and 7-8 GHz bands – and thereby free up spectrum in other bands to be auctioned by the FCC for commercial use.

The "One Big Beautiful Bill Act," which called for the auction of 800 MHz of spectrum (and reinstated the FCC's spectrum auction authority through the end of September 2034), explicitly prohibits the auction of spectrum in the aforementioned bands.

Section 1564, which was added to the NDAA by Senator Deb Fischer (R-NE), a senior member of the Senate Armed Services Committee and chair of the Strategic Forces Subcommittee, would go a step further and "[p]rohibit[] any modifications to DoD systems in key spectrum bands without joint certification from the Secretary of Defense and Chairman of the Joint Chiefs of Staff" (emphasis added).

Mr. Pai is not the first to object to the inclusion of Section 1564 in the NDAA.

In a September 10 post to the FSF Blog, Free State Foundation President Randolph May (1) pointed out that the White House in a Statement of Administration Policy objected to Section 1564 because it "would hinder the President's executive authority," (2) agreed that "Congress cannot properly restrict a president's executive authority by handing over final decision-making authority to his subordinates," and (3) urged Senator Fischer to withdraw the provision.

Some additional examples:

• On October 16, Citizens Against Government Waste's Deborah Collier wrote that, should the Senate version prevail, "the Pentagon will be given the absolute authority to veto the sale or shared use of DOD-controlled spectrum, jeopardizing the ability of the U.S. to remain the global leader in telecommunications and stymie the FCC's ability to auction more spectrum for wireless communications."

• At a Punchbowl News event on October 9, House Commerce Committee Chairman Richard Hudson (R-NC) expressed similar reservations, stating that "I don't think we need to give any kind of veto authority to the Pentagon. I think that could be counterproductive."

• At NTIA's 2025 Spectrum Policy Symposium in September, Senator Ted Cruz (R-TX), Chairman of the Senate Commerce Committee, reportedly cautioned that "[p]ractically speaking, this means NTIA would not even be able to move other federal operators to these bands – which it will have to do to clear the spectrum pipeline – unless first receiving approval from the sovereigns at the Joint Chiefs."

House Passes Bill for 6G Task Force and Report

On April 28, the U.S. House of Representatives passed, by a unanimous voice vote, H.R. 2449 – the "Future Uses of Technology Upholding Reliable and Enhanced Networks Act" or the "Future Networks Act." Sponsored by Rep. Doris Matsui and co-sponsored by Reps. Rick Allen and Tim Walberg, the Future Networks Act, if it were to be passed by Congress and signed into law by President Donald Trump, would direct the FCC's Chairman to appoint a "6G Task Force" that would prepare and send to Congress a report on developing standards, uses, and related issues involving future 6G wireless networks. 

Under the bill, the members of the 6G Task Force would include representatives of the communications industry, public interest organizations or academic institutions, and representatives of federal, state, local, and tribal governments. The Future Networks Act requires that, within 180 days of the 6G Task Force being established, the group prepare a draft report on 6G wireless technology. The draft report would be published on the FCC's website and in the Federal Register for public comment Following the public comment period, and within 1 year of the 6G Task Force being established, the group would publish their final report and submit it to House and Senate Committees. 

The development of 6G technologies, standards, and spectrum policies no doubt will be a multi-faceted and complex undertaking. A future 6G report by the type of task force proposed in the Future Networks Act could serve as a valuable storehouse of knowledge for Congress, the FCC, and the Executive Branch and help pave the way for a successful eventual launch of 6G wireless networks. Now that the Future Networks Act has passed the House, the Senate should give the bill due consideration. 

 

In an April 2023 blog post, Free State Foundation President Randolph May identified the restoration of the FCC's authority to conduct competitive bidding spectrum license auctions as essential for future 6G network deployment. However, in the near term, there are many opportunities for expanding 5G networks by repurposing spectrum from government use to private use. Seizing those opportunities depends not only on a replenished spectrum pipeline but revival of the Commission's auction authority. The 119th Congress should restore the FCC’s authority on spectrum license auctions and encourage timely replenishment of the spectrum pipeline. 

Reps. Doyle and Latta Lay Out Plan to Reform Spectrum Management

Earlier today, on its "Congress Blog," The Hill published an op-ed penned jointly by Representatives Michael F. Doyle (D – PA) and Robert E. Latta (R – OH). Determined to avoid a repeat of the recent kerfuffle between the FCC and the FAA over 5G mobile operations in the C-Band, the two lawmakers set forth a four-element plan to overhaul interagency spectrum coordination processes.

As you undoubtedly recall, earlier this year the launch by Verizon and AT&T of 5G using C-Band spectrum licenses for which they contributed billions to the U.S. Treasury was impacted when, at the eleventh-hour, the FAA raised aviation-related concerns.

This occurred even though, prior to auctioning that spectrum, the FCC undertook a lengthy, deliberate, and engineering-informed process that considered, and addressed, potential interference.

Over the last few years, other disagreements regarding FCC efforts to repurpose high-value, underutilized spectrum similarly have played out in unprecedentedly high-profile fashion. They include the L-Band (vis-à-vis the Department of Defense), the 5.9 GHz band (the Department of Transportation), and the 24 GHz band (NASA and NOAA).

In "Aviation conflict highlights the need for spectrum management reform," Representative Doyle, Chairman of the House Energy and Commerce Committee's Subcommittee on Communications and Technology, and Representative Latta, its Ranking Member, expressed their well-founded concern that "declining faith in how these decisions are made is beginning to show signs of jeopardizing the consumer and economic benefits we've enjoyed for generations."

In response, the two laid out four principles that will guide their bipartisan efforts to "pursu[e] public oversight and restor[e] trust in the spectrum management process."

Those principles are as follows:

1. Reassert that it is NTIA that has the responsibility "to balance the needs and concerns of federal spectrum users, and to communicate those interests to its governmental counterparts and the public."
2. Promote "clear rules and expectations for federal and other spectrum users."
3. Ensure "that the government process for managing these critical spectrum resources [relies] on science and engineering …, not the institutional interests of a single federal agency."
4. Prioritize "the finality of [spectrum management] decisions."

Randolph J. May, the Free State Foundation's President, and Seth L. Cooper, its Director of Policy Studies and a Senior Fellow, made a number of similar points in "Congress Should Require Better Agency Coordination on Spectrum Policy," a February 15, 2022, Perspectives from FSF Scholars.

Specifically, Mr. May and Mr. Cooper (1) urged NTIA and the FCC to update their spectrum coordination Memorandum of Understanding to "expressly acknowledge NTIA's role in representing all executive branch agencies," (2) argued that "Congress should pass legislation to improve coordination among federal agencies," (3) noted with concern how the status quo "risks causing unnecessary delay and regulatory uncertainty," and (4) concluded that an improved process "could provide greater assurance to the public."

NTIA Publishes Spectrum IT Modernization Report Supported by FSF Scholars

On September 24, NTIA published its spectrum IT modernization report, entitled "Plan to Modernize and Automate the Infrastructure of NTIA Related to Managing Federal Spectrum Use." This report details NTIA's spectrum IT modernization plan and requires the Department of Defense and agencies in the Interdepartment Radio Advisory Committee (IRAC) to submit spectrum IT modernization plans to NTIA so that their IT "is interoperable with the modernized infrastructure of the NTIA."

Congress required NTIA to publish this report in Section 9203 of the 2021 NDAA. The report states that NTIA assessed "each spectrum IT system in its IT infrastructure" and will procure new IT to replace outdated equipment and systems, some of which are more than three decades old. This process will ensure that spectrum use is interoperable between agencies and improve the functions, security, and automation of federal spectrum uses.

 

Free State Foundation scholars have written in support of federal spectrum infrastructure modernization. Senior Fellow Seth Cooper wrote in support of a bill with language identical to Section 9203 before it became law: "By all accounts, [Section 9203] is a reasonable and worthwhile measure that would bring about improvements in federal agencies' use and coordination of spectrum."

NTIA's spectrum modernization report appears to be a welcome development that will improve our government's use of spectrum. We look forward to further modernization plans from additional agencies.

PRESS RELEASE: NTIA's Case Against Ligado Undercut by Agency Documents

The following statement may be attributed to Free State Foundation Director of Policy Studies and Senior Fellow Seth Cooper:

Documents from 2013 that recently have gained notice cast doubt on the validity of the Department of Defense and Department of Commerce's opposition to Ligado Network's use of L-Band spectrum for commercial wireless services. A July 2013 memo signed by Interdepartment Radio Advisory Committee (IRAC) members of the Army, Navy, Air Force, and Commerce Department, and NASA shows that at that time those federal agencies had no serious reservations about prospective use of L-Band spectrum by Ligado's predecessor,  Lightsquared. An October 2013 email from a Department of Defense official also indicates that those federal agencies were generally in favor of L-Band spectrum being used for commercial wireless services. This history undercuts those federal agencies' present pushback against Ligado's network, which will operate at significantly reduced power levels compared to what Lightsquared proposed, and subject to FCC-enforceable safeguards. The FCC's 2020 order that authorized Ligado to operate in the L-Band was based on careful technical analysis, and the agency documents from 2013 bolster the case for the Commission to reject any reconsideration of that order.

FCC Followed a Careful Process in Approving Wireless L-Band Services

In April 2020, the FCC approved the use of 30 MHz of valuable L-Band spectrum for commercial wireless services, including 5G services. This will boost the U.S. economy and our nation's standing in the race for 5G global leadership. Now disgruntled parties who want to delay or undo the L-Band Order are badmouthing it. But their attacks on the agency process that preceded the approval are easily shown to be untrue. 

In its L-Band proceeding, the FCC followed the law and engaged its engineering expertise on spectrum interference issues. The Commission's carefully balanced order will promote innovation, investment, and jobs while providing safeguards for GPS services in nearby spectrum bands. 

On a 5-0 bipartisan vote, the FCC authorized Ligado Networks to deploy a mixed mobile-satellite network using licensed L-Band spectrum that previously has gone unused. Ligado is pursuing opportunities for private network services. According to the L-Band Order, Ligado plans to invest up to $800 million in network capabilities, which could create over 8,000 jobs. In February 2021, Ligado announced its collaboration with Rakuten Mobile to co-develop 5G private network solutions for critical infrastructure industries such as energy, utilities, healthcare, and agriculture. 

As Ligado Networks moves forward with its innovative network plans, its opponents are trying to nitpick the FCC's process leading up to the L-Band Order. For instance, op-eds by Diana Furchtgott-Roth published in April and May of this year rehash attacks on the L-Band proceeding. The most fanciful criticisms of the proceeding were originally made by Sen. James Inhofe in a May 2020 floor speech. Sen. Inhofe claimed that the Commission's process amounted to "a hasty decision" suddenly made "in the darkness of a weekend." Others, including Ms. Furchtgott-Roth, subsequently quoted Sen. Inhofe's wild claims for purposes of attacking the L-Band Order. However, it's a ghost story, not reality.

 

The FCC proceeding that culminated in the L-Band Order goes back a decade. Federal agencies, the GPS industry, the wireless industry, and others have closely tracked its developments. In 2016 and 2018, the Commission requested public comments on Ligado Networks' application to deploy its proposed mobile-satellite network. In an August 2019 NTIA report, the executive branch expressly acknowledged an anticipated a decision by the Commission on Ligado's application. And in the fall of that year, the Commission actually shared a draft of its order with NTIA. That the Commission was working methodically toward a decision in its L-Band proceeding was a surprise to no one. Moreover, the agency process that produced the L-Band Order complied with the Administrative Procedure Act's notice-and-comment requirements. 

Furthering the ghost story version of events, Ms. Furchtgott-Roth's op-eds call the L-Band Order "ill-advised" and "inexplicable." Not so. The FCC was ably advised by the agency's Office of Engineering and Technology. The Commission's staff engineers duly considered submissions from federal agencies and all interested parties, conducting a careful analysis of alleged or potential signal interference issues. For instance, the Commission was unpersuaded by certain executive agency claims about possible signal interference with military devices operating outside of their assigned spectrum band.

Executive branch agencies may be unhappy that the FCC didn't agree with their views. But the Commission has the legal responsibility and the expertise to address conflicting views about commercial spectrum usage, and the agency relied on that expertise to make its decision.   

In a January 2021 address to the Information Technology Industry Council, then-FCC Chairman Ajit Pai cut to the chase about federal agency disagreements on spectrum use and overheated claims that aren't backed up by hard facts: 

 

[A]rguably the biggest thing hampering efforts to use spectrum more efficiently is – our own government. On proceeding after proceeding, we saw that other federal agencies tried to throw up roadblocks. Rather than look out for the public interest, many agencies were looking out for their narrow parochial interest. And since most don't have in-house spectrum expertise, they ended up simply parroting the exaggerated, hysterical, and often outright false claims being made by the industries they regulate. To achieve their aims, they ended up bypassing normal channels and complaining to Congress or the media in an effort to block or delay efforts to free up spectrum for commercial use.

 

Among the highly dubious claims called out by Chairman Pai, throw in Ms. Furchtgott-Roth's that "the entire GPS system is endangered" by the L-Band Order. 

The deliberative process undertaken by the FCC is a reflected in the L-Band Order's specifics to for safeguarding GPS services. Rather than give Ligado Networks a free pass, the Commission imposed significant conditions on L-Band usage to avoid potential signal interference with incumbents in adjacent spectrum bands. Ligado negotiated agreements with major GPS equipment manufacturers for resolving signal interference concerns. The Commission incorporated those agreements into the L-Band Order, making them enforceable by the agency. Also, the Commission required Ligado to establish a 23 megahertz guard-band, lower base station power levels 99% compared to Ligado's 2015 proposal, and replace any government GPS devices that experience harmful interference. And Ligado must be able to shut off its network within 15 minutes of any request by the Commission. 

In January of this year, the newly-constituted FCC rightly rejected an NTIA petition to stay the L-Band Order. Ligado Networks' 5G endeavors ought to be encouraged, not hindered. The careful process undertaken by the Commission should instill confidence in the agency's decision to green light wireless services in the L-Band. And resort by opponents to easily disprovable criticisms of the agency's process also boost confidence in the resulting order. 

 

(For more on this subject, see the May 2020 Perspectives from FSF Scholars paper by Free State Foundation President Randolph J. May and I titled: "FCC's Order Approving Ligado's Next-Gen Wireless Network: A Deliberative Process that Protects Against Signal Interference.") 

Chairman Pai Offers Incisive Remarks on U.S. Spectrum Policy

For an excellent overview of the FCC's progress putting spectrum into commercial use during Chairman Ajit Pai's tenure, look no further than his remarks to the Information Technology Industry Council (ITI) on January 14. He also addresses the future of American spectrum policy.

Here are some key paragraphs concerning the Commission's initiatives to put mid-band spectrum into licensed commercial use: 

When I came into office in 2017, the cupboard was almost empty. The only mid-band spectrum in the pipeline was the 3.5 GHz band, which was saddled with misguided restrictions that weren’t going to encourage 5G deployment. So not quite “mark it zero,” but close. Despite starting from behind the eight ball, we turned things around, and in a big way. Under my direction, the FCC systematically identified mid-band airwaves that were being underused. This was a very complicated case, you know, a lot of ins, lot of outs, a lot of what have yous. But we figured it out and set plans in place to put these airwaves to work for the American people…

 

Put all these together—the C-band and the 3.5 GHz band, together with a future auction of the 3.45 GHz band—and we are on a path to have a contiguous 530-megahertz swath, from 3.45 to 3.98 GHz, of mid-band spectrum available for 5G. Not bad, considering where we started. That’s 5G FAST. 

Later, Chairman Pai describes the Commission's success in making much more spectrum available for unlicensed use:

 

These two initiatives, on 6 GHz and 5.9 GHz, will open up 1,200 and 45 megahertz of spectrum for unlicensed use, respectively. Now let’s talk about gigahertz—1,000 times as large. Through our 2019 Spectrum Horizons Order, the Commission made a massive 21.2 gigahertz of spectrum above 95 GHz available for unlicensed use across four frequency bands. 

 

Importantly, Chairman Pai squarely addressed the problem of other federal agencies putting up obstacles to the repurposing of more spectrum for commercial use:

 

[A]rguably the biggest thing hampering efforts to use spectrum more efficiently is—our own government. On proceeding after proceeding, we saw that other federal agencies tried to throw up roadblocks. Rather than look out for the public interest, many agencies were looking out for their narrow parochial interest. And since most don't have in-house spectrum expertise, they ended up simply parroting the exaggerated, hysterical, and often outright false claims being made by the industries they regulate. To achieve their aims, they ended up bypassing normal channels and complaining to Congress or the media in an effort to block or delay efforts to free up spectrum for commercial use. 

 

Chairman Pai offers wise words to his successor at the FCC in holding the line on spectrum reallocation. identifies the need for strong NTIA leadership going forward, and addresses the need to discuss reforms to the government's spectrum management framework. 

 

Be sure to check out Chairman Pai's remarks to ITI in their entirety.  

Proposed Legislation Would Incorporate Price Tags, and Economic Rigor, into Government Spectrum Discussions

Spectrum is in increasingly short supply. Especially mid-band spectrum. My fellow Free State Foundation scholars and I have highlighted wireless industry reports indicating that, absent additional spectrum clearing, the United States is at risk of falling behind other nations in making more available, in particular for 5G. The most likely source? Frequencies currently allocated to government agencies.

Legislation introduced by Senator Mike Lee (R-UT) would facilitate difficult discussions regarding whether government spectrum is being put to its best and highest use by directing NTIA to determine its real-world monetary value. That, in turn, would infuse the process with greater transparency and data-driven analysis.

The federal government, led by the Department of Defense, has exclusive or primary use of the majority of spectrum between 225 MHz and 3.7 GHz. In 2012, the President's Council of Advisors on Science and Technology (PCAST) found that "nearly 60% of … beachfront frequencies are predominantly allocated to Federal uses, a statistic that illustrates the importance of finding more effective mechanisms to share Federal spectrum."

Sen. Lee's bill, the Government Spectrum Valuation Act (S. 1626), champions a market-oriented approach. By directing NTIA to assign dollar values to government-held spectrum, it would enable quantitative comparisons between private and public allocations. In addition, by including those amounts within agencies' budgets, it would provide them with economic incentives to relinquish underutilized capacity in order to secure funding for higher priority initiatives.

In the commercial realm, market forces reveal the value of spectrum. Commission-led auctions, such as the one scheduled to take place this December for 280 MHz of high-value mid-band spectrum in the C-Band, afford interested parties the opportunity to bid competitively on scarce resources. The highest bidders prevail, and the dollar amounts they agree to contribute to the Treasury establish what the spectrum is worth.

But that is not the case with government spectrum, which in many cases was allocated years ago and under vastly different – and much less efficient – technological circumstances. As Visiting Scholar Gregory J. Vogt explained in a recent Perspectives from FSF Scholars, "Coordinated Government Decisionmaking on Spectrum Issues: It's Vital to Locating More Spectrum for 5G Use":

There is a significant "opportunity cost" associated with government spectrum, which is defined as the loss of potential benefits when a suboptimal alternative is chosen over one that would generate higher consumer welfare. In May 2015, Coleman Bazelon and Guilia McHenry estimated the economic value of 645.5 MHz of licensed spectrum in the hands of government users was $455 billion. If this spectrum was auctioned off to commercial users, it would generate about $1.7 trillion in 2015 dollars in economic activity.

Indeed, as Sen. Lee noted when he introduced the Government Spectrum Valuation Act, "because federal agencies pay such a minimal fee to NTIA for their allocations – absent of a market-based allocation – they have little incentive to share spectrum or make it available for commercial use."

Nor are policymakers able to make objective, apples-to-apples comparisons between commercial and government allocations. They might have imperfect information as to what that spectrum would fetch on the open market, but the other side of the balance – its true and full value to government users – often is unknown.

(To be sure, government spectrum plays an important role, including in our national defense, that in certain instances cannot be made public. The legislation as proposed would allow NTIA to consider, and require it to keep confidential, "classified, law-enforcement sensitive, or proprietary information" relevant to the assigned dollar value.)

To address this, the Government Spectrum Valuation Act would require NTIA to work with the FCC and the Office of Management and Budget (OMB) to estimate the value of spectrum. Such valuations would be based "on the value that the electromagnetic spectrum would have if the spectrum were reallocated for the use with the highest potential value of licensed or unlicensed commercial wireless services that do not have access to that spectrum as of the date of the estimate."

It also would direct NTIA to "consider the spectrum needs of commercial interests while preserving the spectrum access necessary to satisfy mission requirements and operations of Federal entities."

The bill would establish the following schedule pursuant to which NTIA must complete its valuations:

• 3 KHz to 33 GHz: within 1 year and every 3 years thereafter
• 33 GHz to 66 GHz: within 2 years and every 3 years thereafter
• 66 GHz to 95 GHz: within 3 years and every 3 years thereafter

It is worth pointing out that FCC Commissioner Michael O'Rielly repeatedly has advocated for a similar approach, noting in 2018 that "requiring U.S. Government agencies to put a market price on their spectrum holdings will fix a budgetary anomaly and promote overall spectrum efficiency by incentivizing each agency to release unneeded spectrum."

Although Sen. Lee unveiled the Government Spectrum Valuation Act back in May 2019, it has been the recent subject of renewed focus. Representatives Cathy McMorris Rodgers (R-WA) and Yvette Clarke (D-NY) introduced companion legislation in the House on September 14, 2020. Two days later, the Senate Commerce Committee voted to approve Sen. Lee's version. That bill now is before the full Senate.

Then-NTIA Administrator David Redl stated in 2019 that, "[i]f we're being honest, the era of easy spectrum decisions is over." Passage of the Government Spectrum Valuation Act would facilitate that process by assigning specific dollar values to government spectrum, thereby enabling policymakers to make rational, informed decisions regarding its best and highest use.

FCC Keeps C-Band Auction on Track with Today's Public Notice Adoption

Today the FCC continued its steady march toward a December 8 auction of high-value, mid-band spectrum for 5G and other advanced uses. The Free State Foundation offers its congratulations on the timely achievement, under challenging circumstances, of this important milestone.

At this morning's Open Meeting, the Commission adopted a Public Notice detailing application and bidding procedures for the upcoming Auction 107 of 280 MHz of spectrum in the C-Band (3.7-4.2 GHz). Chairman Pai and Commissioners O'Rielly and Carr voted to approve, Commissioners Rosenworcel and Starks approved in part and dissented in part.

Reallocation of the lower C-Band is a major component of Chairman Pai's 5G FAST plan to ensure American leadership in the deployment of 5G networks.

At the end of February, the agency adopted a Report & Order establishing rules that:

• Repack current C-Band satellite users into the upper portion of the band (4.0 - 4.2 GHz);
• Create a 20 MHz guard band (3.98 - 4.0 GHz);
• Reallocate to licensed, flexible use and set for auction the lower 280 MHz (3.7 - 3.98 GHz); and, critically,
• Incentivize existing licensees to vacate that spectrum more quickly than they otherwise would have to through the establishment of accelerated relocation payments.

The Public Notice approved today accomplishes the following:

• Specifies bidding procedures;
• Establishes an assignment phase during which winning bidders for spectrum that will be cleared first (that is, by December 2021) will receive interim and final frequency allocations; and
• Defines certain bidding thresholds, including minimum opening bids and bidding credit caps for small businesses.

The Public Notice has not been released yet, but the News Release can be found here.

Spectrum Management Working Group Proposals Target Roles of FCC, NTIA

On July 30, the Commerce Spectrum Management Advisory Committee (CSMAC) Working Group 1 released its Final Report (along with a Presentation) on the topic of governance. That report includes a number of proposals to improve the spectrum-management process that involve reassigning, consolidating, and/or transferring to a new federal agency functions currently performed by the FCC (for commercial spectrum) and NTIA (for federal spectrum).

In October 2018, the White House issued the "Presidential Memorandum on Developing a Sustainable Spectrum Strategy for America's Future."

CSMAC Working Group 1's mission was to evaluate whether the existing spectrum governance model is optimized to implement that (still under development) National Spectrum Strategy — and if not, to propose alternatives.

In its Final Report, Working Group 1 concludes that "the United States’ current approach for managing the use of spectrum is no longer effectively serving the needs of the entire stakeholder community and would benefit from reform." It therefore proposes a number of possible changes. They include:

• Creating a new "Full-Service Spectrum Agency" that would assume all spectrum-related responsibilities currently handled by the FCC and NTIA;
• Combining the two into a single, independent "Unity Agency," of which the FCC and NTIA would serve as subsidiary "offices," and empowering a single administrator with decision-making authority (thereby eliminating the need for FCC commissioners);
• Establishing a "Spectrum Resource Agency" that would be responsible for only a subset of the spectrum-related actions that the FCC and NTIA currently perform (that is, planning and allocation, international policy, R&D, and forecasting), with those agencies continuing to carry out spectrum assignments (including auctions), licensing, equipment authorization, and similar functions; and
• Transferring to a "New FCC" the spectrum management responsibilities of the NTIA — or, in the alternative, to a "New NTIA" the spectrum management responsibilities of the FCC.

In addition, Working Group 1's Final Report proposes several options to improve spectrum management, whether in combination with one of the reforms noted above or on their own. They include:

• An expanded focus on R&D;
• Revisions to the 2003 Memorandum of Understanding (MOU) between the FCC and NTIA; and
• A periodic review of spectrum governance models (that is, every 3-5 years).

For a summary of recent breakdowns in the intergovernmental spectrum coordination process, along with suggestions to revitalize such efforts moving forward, please take a look at Free State Foundation Visiting Fellow Gregory J. Vogt's June 15 Perspectives from FSF Scholars, "Coordinated Government Decisionmaking on Spectrum Issues: It's Vital to Locating More Spectrum for 5G Use."