Spectrum Data Accuracy and Management Improvements Report

1. CSMAC Report of the Spectrum Management Improvements Working Group Preliminary Working Draft For Discussion at the CSMAC Meeting on July 27, 2011 (We expect this to be revised based on discussion at the meeting and further work by the Working Group)

2. Key Questions from Work Plan • 6(c) - Techniques for verification of data – How does industry (band managers or frequency coordinators) ensure the accuracy of data? What steps does the FCC take to ensure the accuracy of data on licenses that are not prepared via a band manager or frequency coordinator)? What role does individual accountability play (e.g. required signatures)?

3. Key Questions Re-framed • What techniques are used to ensure the accuracy of spectrum data, and how can those techniques be improved, simplified and streamlined to • validate new data when collected • identify and correct erroneous data once stored • maintain the accuracy of data over time • ensure compliance • Particularly what lessons and techniques can be drawn from commercial and governmental experiences to inform NTIA’s efforts along these vectors?

4. GAO Report – Key Statement • “NTIA’s data management system lacks transparency and data validation processes, making it uncertain if spectrum management decisions are based on accurate and complete data…”

5. Approach • Review FCC licensing and data management systems • Review industry spectrum data management systems • Review other similar data management systems • Domain Name System (DNS) • “whois” database • Review government IT directives for applicability • OSTP Plan To Reform Federal Information Technology Management • Talk to NTIA staff

6. What techniques are used to ensure the accuracy of spectrum data - FCC Approach • Background • The FCC manages a licensing database, not a spectrum management database • Data is generally insufficient for analysis purposes (no antenna patterns, equipment specifications, etc.) • Frequency and spectrum engineering performed by licensees (or industry) • Manages over 2M licenses • Key databases include: • Antenna Structure Registration System (ASR) • Cable Operations and Licensing System (COALS) • Commission Registration System (CORES) • Consolidated Database System (CDBS) • Equipment Authorization System (EAS) • Experimental Licensing System (ELS) • International Bureau Filing System (IBFS) • Universal Licensing System (ULS) • Moving to a Consolidated Licensing System (CLS) • Goal - examine certain functions of the current licensing and application systems in an effort to improve spectrum management and to develop a transparent, easily accessible, data driven, efficient, cost-effective and green consolidated licensing system • Key features • Single sign-on • Consolidated forms • Streamlined application filing • Shorter application processing time • Courtesy electronic reminders and notifications • Easy search and output generation • Centralized customer support • Paperless • Will take at least four years

7. What techniques are used to ensure the accuracy of spectrum data - FCC Approach (cont’d) • Techniques to ensure accuracy • Administrative (hold licensee responsible) • Financial - costs associated with licensing, changing, modifying, etc. • Enforcement - penalties associated with operating inconsistent with license • Regulatory - rules place requirement on licensees to “own” data, manage and maintain it • Licensees required to renew (time frame depends upon service, 5 – 10 years) • Occasional clean-up efforts (e.g. BRS) • Procedural • Rudimentary checks in licensing systems • e.g., county, FAA compliance • Allow for bulk data upload • Minimizes system interaction

8. What techniques are used to ensure the accuracy of spectrum data – Industry & IT Best Practices • Perform system-wide data accuracy and clean-up procedures • Necessary to establish data baseline and address existing errors • Best practices • Limit interaction • Use pick lists and drop downs (i.e., pre-populate where possible) • Check and verify • Allocate appropriate resources • Perform regular system wide data accuracy checks (i.e., fix bad data) • Accountability • Require individual and transparent accountability for maintaining database accuracy • Establish milestones and rewards for data accuracy • Data cross check and verify • Technology • Emission • Equipment • Calculate where applicable • e.g., ground elevations • Collect only data necessary for specific task

9. NTIA Approach • NTIA is responsible for assigning radio licenses for federal users • No federal agency can transmit within the US and its possessions without NTIA’s approval • Agencies are responsible to verify the need for radio assignments and to ensure that the data provided is correct • Agencies are required to perform a review of every record every 5 years (exceptions are geostationary satellites and Aeronautical band assignments, which are 10 year review) • NTIA depends on the agencies to do a quality job and verify the data sent to NTIA is correct

10. NTIA Changes Related to GAO Report • The 21 agencies in the Frequency Assignment Subcommittee (FAS) will provide suggestions on what they believe will improve the process • NTIA will also be making suggestions • The final list of improvements will be sent to the IRAC and then to NTIA for implementation • At the early stages of the process but have several good recommendations being worked on • Hope to have many of the changes done within 3-6 months; may take longer if additional software is required • Believe many of the changes can be done by the existing NTIA IT staff and changes to the Red Book requiring agencies to provide more information in their submissions • The FAS is going to have the agency: • Verify the data at the data entry level • Certify the need at the headquarters level • Both will require an individual to be identified in the assignment record as performing their function correctly which is presently assumed • Considering the use of terrain data to check agency data for correctness as well as new computer programs to verify coordinates, power, radius and number of units • Requesting more information about assignments is being discussed in the FAS now and determining what is possible and what will provide the best results

11. Improvements Expected from FSMS • Will require a lot more data for each record • Data will be cross referenced with other files and verified • Will also incorporate engineering models to provide better interference predictions as well as better spectrum utilization • Time frame is about 4-5 years from being fully operational and used by all the federal agencies

12. Recommendations • The NTIA should: • As soon as practicable, perform one-time, system-wide data accuracy and clean-up effort • Necessary to establish data baseline and address existing errors • NTIA could lead with mandate for Agency cooperation • Review all assignments • Establish goals and metrics for data accuracy and milestones for achieving • Increase Agency accountability for data accuracy by strengthening enforcement • Adopt more rapid and clear escalation procedures • Strengthen the certification process • Shorten the 5-year review cycle • Investigate the use of distributed databases to improve access, accuracy • Multiple sources of data linked with flow through – improves data access, transparency • Responsibility for data collection and maintenance localized – limits control of data to improve accuracy • Continue to develop FSMS considering requirements to support data accuracy

13. Next Questions from Work Plan • 6(a) – Expansion of data to support compatibility analysis – Use of automated processes for frequency selection, and compatibility analysis require more data than is commonly provided in licenses or assignments. How do we make a transition to a more complete data set? Is it important?

14. Next Questions Re-framed • What types of data are needed to form a complete data set necessary to support spectrum planning activities, including frequency selection and compatibility analyses?

15. Preview of the types of data needed to form a complete data set sufficient for spectrum planning • Data on both transmitters and receivers • Location • Area of operation • Equipment • Transmitter and receiver • Manufacturer and model • Antenna • Manufacturer and model • Operational • Frequency • Occupied bandwidth/channel • Transmit power • Antenna configuration • Height • Feedline type