NTIA Spectrum Plan Implementation Comments

B-21 Raider bomber

This is the cover letter to NTIA’s National Spectrum Strategy on implementing NTIA’s national spectrum strategy. It refers to our previous post on the subject.

Fr: Richard Bennett, High Tech Forum

Subject: Request for Comments on Implementing the National Spectrum Strategy

The National Spectrum Strategy fails to pay significant attention to the research priorities for improving and disciplining spectrum use by government incumbents, chiefly the Department of Defense. It’s not enough to merely identify bands for study, the strategy needs to dig deeply into the technical aspects of present systems.
The Defense Department has a history of dragging its feet on increasing the efficiency of its spectrum-based systems while touting highly speculative moon-shot programs such as JTRS and CBRS that fail to materialize as valuable, functional systems. Effectively, this approach to spectrum amounts to running out the clock while leaving legacy systems in place.

DoD needs guidance from spectrum experts who are not on its payroll and who don’t have vested interests in maintaining the status quo. ITS and the FCC have spectrum experts on staff already, but their effectiveness is limited by DoD insistence on confidentiality and by DoD’s internal culture of self-protection.
Rather than launching ever more studies with open-ended objectives, government incumbents need to start with a blank sheet of paper and determine the best ways to accomplish mission objectives with current and near future technologies.


  • Is it necessary to operate military radar on exclusive spectrum bands, or could it piggyback on commercial systems?
  • Is it wise to train in the US with pristine spectrum when overseas combat takes place in entirely different conditions?
  • Is it better to disguise military communication with drones and LEO satellites as ordinary commercial communications or to make it stand out for what it is?
  • Do we have means for jamming enemy communications without harming allied signals?

The following post from High Tech Forum expands on these themes. The bottom line is that the focus on study means we are not placing enough emphasis on the directions and objectives of improving incumbent systems.

The issue isn’t which bands to study, it is which applications are most in need of improvement. Instead of an analog focus on bands and frequencies, the strategy needs to lean into coding and modulation.

Best regards,

Richard Bennet, Wi-Fi Pioneer
Publisher, High Tech Forum