Request for Comment on Improvements to the U.S. Preparation Process
for World
Radiocommunication Conferences
. Paper submissions should include an
electronic version on diskette
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format.
FOR FURTHER INFORMATION CONTACT: Darlene
A. Drazenovich, (202) 482-3480,
ddrazenovich@ntia.doc.gov, or James Vorhies,
(202) 482-3590, jvorhies@ntia.doc.gov,
International Spectrum Plans and Policy Division, Office of Spectrum
Management, NTIA.
SUPPLEMENTARY
INFORMATION:
Background
The International Telecommunication
Union (ITU) is an intergovernmental organization within
the United Nations that specializes in the field of telecommunications.
The ITU brings together
international governments and private industries to coordinate the
establishment and operation of
global telecommunication networks and services. Every three to four
years, the ITU convenes
World Radiocommunication Conferences (WRCs)-- an international forum
for world agreement,
to review and revise the International Radio Regulations. The Radio
Regulations constitute an
international treaty on radiocommunications covering the use of the
radio-frequency spectrum by
radiocommunication services. These conferences set the world stage for
future technological
development by allocating radio frequency spectrum to radio services,
establishing spectrum use
coordination methods, setting international rules for radio equipment
operation, and identifying
spectrum for specific uses such as Third Generation (3G) wireless
systems.
The United States is a key player in
this important global endeavor because it brings new and
innovative technologies to the world community while balancing global
security, national
defense, and the public interest. NTIA, with the support of the federal
agencies, is partners with
the State Department and the FCC in preparing for and participating in
these conferences. Over
the last several WRC cycles, the United States has made important
strides in preparation for
these critical intergovernmental meetings. NTIA believes that various
aspects of the United
States' preparation process to develop and promote U.S. objectives in
upcoming conferences can
be further improved upon.
The United States preparatory
process for World Radiocommunication Conferences follows two
related paths - technical and proposal/position preparation. The
technical preparation are
conducted in the International Telecommunications Union
Radiocommunications Sector (ITU-R)
Study Group process and includes Federal and Non-Federal Government
participation. The U.S.
International Telecommunication Advisory Committee (ITAC) is the
mechanism by which the
U.S. prepares technical studies for WRCs. The General Services
Administration chartered this
committee to the U.S. State Department as an advisory committee under
the Federal Advisory
Committee Act (FACA)(3). The
ITAC-R National Committee (NC) assists the U.S. Government
in technical preparations for international meetings and negotiations.
Under this advisory
committee, the public is afforded the opportunity to participate
actively in government decision-making activities. With respect to
technical preparations for WRCs, the State Department uses
the ITAC to develop technical study inputs to the ITU-R study groups
and the CPM to form the
technical, operational and regulatory basis for WRC decisions, but does
not employ the ITAC to
develop preliminary views or proposals directly related to WRCs.
The Federal and non-Federal WRC positions and
proposal preparation processes are
independent. The Federal preparation process includes NTIA, which
represents the views of the
administration. NTIA is the President's principal adviser on
telecommunications and information
policy and manages the Federal Government's use of radio spectrum.(4) The Radio Conference
Subcommittee (RCS) of NTIA's Interdepartment Advisory Committee (IRAC)
meets monthly to
discuss and approve federal agency views, positions and proposals, on
WRC issues. The Non-Federal Preparation is performed by the
FCC. The FCC, an independent agency
established by the Communications Act of 1934, manages the use of radio
spectrum by state and
local governments and the private sector. The FCC, as an independent
agency, represents the
views of its constituents and receives their input on WRC views,
positions, and proposals.
Questions for Public
Comment
To assist in the assessment, NTIA seeks public
comment on any issue of fact, law, or policy that
may inform the agency about improvements needed in the WRC preparatory
process. Specific
comments are requested on the questions below. These questions are
designed to assist the
public and should not be construed as a limitation on the issues on
which public comments may
be submitted. Please provide copies of any studies, research and other
empirical data referenced
in the comments.
1. Federal Government
Preparation Process
A. How should NTIA as the President's advisor
seek the views and inputs of the non-federal entities?
B. How can NTIA better educate the commercial
sector on the federal agencies'
radiocommunication requirements, and related policies and decisions
that affect U.S. conference
proposals?
2. WRC Advisory Committee (WAC)
Preparation Process
A. The WAC is part of the FCC's WRC preparation
process. How can the federal
agencies best participate in the WAC?
3. FCC/NTIA Proposal Coordination Process
A. Should the federal and non-federal advisory
processes remain independent? Why or
why not?
B. Federal views and proposals sent to the FCC
represent NTIA's review and
modification of RCS inputs and thus the Administration's output, while
the FCC sends WAC
views and proposals directly to NTIA for consideration without bureau
review. Would it
improve the process to take a similar approach on both sides
(circulation of RCS and WAC
inputs, or circulation of NTIA and FCC outputs)?
C. Please specify how
communications/coordination between the FCC processes and the
Executive Branch processes under the purview of NTIA can be improved?
Include in your
discussion such topics as involvement of senior agency management,
early agreements on WRC
positions, NTIA-FCC reconciliation process and timeframes.
D. What steps can be taken to resolve difficult
issues? Should timelines be developed in
order to identify these issues early in the process?
4. Study Group/National Committee
Process Related to WRC Agenda Items
A. Should the U.S. National Committee set
objectives and policy regarding WRC
studies?
B. Is closer coordination among various study
groups required? If so, why and how can
this be accomplished?
C. The U.S. Study Group consists of government
and non-government participants who
prepare for ITU meetings. Should the U.S. Study Group process be guided
to align with U.S.
WRC goals and objectives? If so why, and by what means?
D. Should a federal government/non-government
position on agenda items and
supporting information/studies to pursue U.S. positions be developed,
approved and
disseminated?
E. To ensure success of U.S. objectives for WRC
agenda items, technical studies must
begin early in the process. Is it necessary to energize an agenda item
and its associated studies by
a certain point in the preparation process if no activity has occurred?
If so, how can this be
accomplished (e.g., what mechanisms and by what point in time)?
5. Forming the WRC Delegation
A. Is there a lack of continuity in leadership
between WRC conferences? If so, how can
this be better managed?
B. When in the preparation process should the
core delegation group, vice-chairs, and
principals be formed to begin work? How can these groups be better used
to improve the
effectiveness and efficiency of the United States' WRC agenda?
C. Agencies, companies, and organizations
nominate representatives to be on the U.S.
WRC delegation. Is the nominated delegation formed early enough in the
process to develop and
approve final positions in a timely manner? If not, how can this
process be improved?
D. Is the accredited delegation formed early
enough to develop and approve U.S.
positions, strategy, and fallback positions? If not, how can this be
improved?
E. At what point in the preparation process
should delegation assignments be made and
spokespersons identified
F. How could the appointment and role of the
U.S. Ambassador be improved?
G. Is the United States' negotiating strength
improved or hindered by the use of an
appointed political representative working with career spectrum
managers and ITU experts from
other countries?
H. Assuming the continued appointment of a WRC
ambassador, at what point does the
Ambassador's appointment need to be effective?
I. During conference preparatory meetings,
administrations meet to agree on the final
report of studies, which is used as the technical basis at a WRC. Is it
important to bring the
Ambassador on board in some capacity prior to the conference
preparatory meeting? If so, how
can this be accomplished?
6. Budgeting WRC Activities
A. Funding for the WRC Ambassador has been an
ongoing concern. To ensure the
Ambassador and the delegation staff are able to complete their
missions, is it necessary to
provide the Ambassador with an operational budget? Is so, how can
representational funds best
be used to conduct outreach efforts?
B. What facilities are critical to the
functioning of the delegation and the Ambassador at
the conference site?
C. Recognizing that agencies and companies send
representatives to the delegation to
participate in debates, negotiations, and outreach efforts, how should
support be provided to
cover the Editorial Committee of each WRC?
7. Outreach and Consultations with Other
Countries
A. Are consultations with other administrations
needed? If so, at what point in the
process should they begin?
B. Is it important to work with other countries
outside of the ITU study groups and the
conference preparatory meeting? If so, why and how can this be improved?
C. Should the Country Contact/Outreach program
that is developed and utilized at a
conference be maintained between conferences? If so, how can this be
accomplished? Who
should lead this effort? What role can the private sector play?
D. Should WRC outreach activities be integrated
with other international activities of the
State Department, NTIA and FCC? If so, how?
E. How effective were the Delegation
Consultations prior to WRC-03? Were they
started in a timely manner?
8. Training
A. Are trained and qualified Federal Government
Spokespersons and issue coordinators
available throughout the WRC preparatory process and especially at the
Conference?
B. Are training programs needed for
spokespersons and delegates? If so, what should
they consist of?
C. Is preparatory training needed for general
participation in ITU-R Study Groups in
support of WRC activities? If so, what should it consist of?
D. What steps should be taken to maintain a
cadre of experienced personnel in the
federal government in order for them to assume leadership and
spokesperson roles at future
WRCs?
9. WRC Domestic
Implementation Process.
A. In the past, the United States has been faced
with challenges regarding the
implementation of WRC decisions. What can be done to improve this
process?
B. The GAO report noted that federal agencies
are concerned that WRC allocation
decisions of primary interest to the federal government go without
action, how can the process be
improved to ensure equal treatment of both government and private
sector interests?
C. Should FCC/NTIA develop a plan and schedule
to complete rulemaking for each
WRC agenda item? If so, within what timeframe of WRC completion should
the plan be
executed?
General Areas
A. In broad terms, what goals should the United
States have for WRCs? How should
these goals be established?
B. How effective has the United States been in
the WRC process?
C. What have been the benefits and costs of
regional preparation for WRCs?
D. How often should WRCs occur and what, if any,
limitations should the U.S. support
regarding WRC agendas.
E. Over the years, there has
been concern among WRC participants (government and
non-government) regarding staffing issues. Do NTIA and the federal
agencies have sufficient
staff with appropriate expertise to support spectrum management
activities in the WRC
preparation process?
Dated: October 20, 2003
/s/ Kathy Smith
Chief Counsel
ENDNOTES:
1. See
U.S. General Accounting Office, Telecommunications - Better Coordination and Enhanced Accountability
Needed to Improve Spectrum Management,
GAO-02-906 at pg. 35 (September 30, 2002).
2. See
Public Forum to Assess FCC's Preparatory Process for World
Radiocommunication Conferences, Public
Notice, DA-03-02858 (rel. September 10,
2003).
3. See 5 U.S.C. app.
4. 47 U.S.C. § 902 (2000).