I. Introduction & Summary

The National Telecommunications and Information Administration (NTIA) seeks comment on the development of a national spectrum strategy, pursuant to a recent presidential memorandum on the subject.

NTIA plays a critical role in facilitating the use of spectrum by government users. Since useable radio frequencies are scarce, the agency inevitably influences private sector use of the airwaves. Striking the right balance between critical government missions and productivity in both the public and private sectors requires using markets to analyze tradeoffs and implementing the latest sharing technologies. To aid in the development of such a balance, the R Street Institute (“R Street” or “RSI”) hereby submits the following comments.

II. Summary of RSI Work on Spectrum Issues

R Street’s mission is to engage in policy research and outreach to promote free markets and limited, effective government. That mission includes policy research and outreach on issues relating to the allocation and use of radio frequencies. Because NTIA deals largely with federal users of spectrum, the challenges it must address differ somewhat from those the private sector faces. For instance, productivity is more difficult to judge and achieve when federal government missions are at stake. Furthermore, the government faces principal-agent problems and other difficulties in determining how to make government users account for the opportunity costs of their spectrum holdings. Still, NTIA can and should account for how its management of spectrum affects the private market and evaluate the extent to which lessons from commercial spectrum users can inform NTIA’s 4 | R S t r e e t I n s t i t u t e own mission. The Federal Communications Commission (FCC), for example, took a more invasive approach in steering commercial use of spectrum in the past but has since found a more market-driven approach to be more effective at facilitating productive outcomes.

For NTIA, the productive use of each frequency band ought to be the end goal. In the private sector, markets are adept at pushing spectrum to productive ends. Therefore, a national spectrum strategy should involve the government seeking to get out of the way of spectrum markets rather than micromanaging their development or operation.

The following sections summarize a selection of R Street’s published works on spectrum policy, which are attached as appendices A–D.