Today, TechFreedom filed comments in response to the National Telecommunications and Information Agency’s (NTIA) request for public comment on the development and implementation of a National Spectrum Strategy (NSS) for the United States. Our comments explain the importance of interagency collaboration, a larger focus on spectrum efficiency, and ways to incentivize federal users to either vacate or share spectrum. 

“Spectrum efficiency should be the overarching goal of the NSS,” said James E. Dunstan, TechFreedom’s General Counsel. “Given the lack of ‘greenfield’ spectrum, future spectrum management must focus on making all systems, both commercial and governmental, as efficient as possible to encourage the best use of spectrum across all users. This includes both transmitter and receiver performance efficiencies. Both FCC policy and market forces have driven commercial spectrum licensees to strive for increased efficiency, especially for spectrum for which they must pay at auction. By one estimate, commercial licensees are increasing their spectrum efficiency by as much as 30% per year to maximize performance from their licensed spectrum. Such similar forces have long been lacking among government spectrum users.”

“Any successful strategy will depend on proper coordination and cooperation,” Dunstan continued. “If America is to maintain its leadership in communications technology, NTIA and the FCC must come together to design a long-range strategy that benefits both government users and consumers. NTIA cannot allow other agencies to usurp this role; nor can it allow others to throw up roadblocks to efficient spectrum management. No agency should wield a veto simply by invoking ‘national security.’”

“Government users cannot be allowed to rely solely on commercial users to pay for the replacement or upgrade of outdated legacy systems,” Dunstan concluded. “The combination of a government spectrum fee, in conjunction with relocation reimbursement out of commercial spectrum auctions, could provide the proper incentive for federal users to upgrade their systems and thus free up additional spectrum. If federal users know that they can look to commercial users alone to pay for their upgrades, they will simply sit back and wait until market forces align to make their spectrum valuable enough for commercial users to pay for it. If, however, federal users were required to pay a fee on an annual basis for the spectrum they use, they’d be more willing to accelerate that process.”


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About TechFreedom: TechFreedom is a nonprofit, nonpartisan technology policy think tank. We work to chart a path forward for policymakers towards a bright future where technology enhances freedom, and freedom enhances technology.