Dean Bubley: Fact-Checking CTIA’s Testimony to Congress on Spectrum Policy

On January 23, 2025, the House Energy and Commerce Subcommittee on Communications and Technology held a hearing on “Strengthening American Leadership in Wireless Technology”. Speakers included representatives from NCTA, CTIA, Open RAN Policy Coalition and Public Knowledge, with witnesses primarily covering spectrum issues.

The CTIA witness’ live comments and written testimony focused on mid-band spectrum for exclusive, high-powered use by cellular carriers (MNOs, mobile network operators) for 5G and future 6G networks. But CTIA’s testimony is inaccurate in many respects – starting with its arbitrary redefinition of “mid-band” to 3-8.5 GigaHertz (GHz), rather than the widely accepted 1-6 GHz or 1-7 GHz range.

The lower cut-off of 3 GHz and below means its analysis omits large swathes of mid-band spectrum that the cellular carriers already control, especially the 190 megahertz held by T-Mobile in the 2.5 GHz band, which the carrier itself describes as mid-band.

In its verbal responses to the committee, the CTIA representative also suggested that new exclusive spectrum allocations could help with wireless network coverage in rural areas. This is odd; if carriers cannot profitably deploy their existing low-band spectrum assets in those regions, it is improbable that new allocations in the mid-band – which has more limited reach and range – will change the calculus.

CTIA’s international examples are also flawed.

For instance, CTIA asserts the UK has "almost 800 [megahertz] of licensed midband spectrum" [using the 3-8 GHz definition]. This is untrue – the UK has allocated 3.4-3.8 GHz to MNOs with exclusive national licenses, but the 3.8-4.2 GHz range is available only with low / medium power on a localized basis, for private 5G and rural fixed wireless licenses, under regulator Ofcom’s Shared Access Licence scheme. It cannot be used by MNOs for high-power mobile broadband coverage and capacity. Rather, this band is broadly equivalent to the US CBRS band, which CTIA excludes from its calculation.

U.S. spectrum sharing lead

While CTIA was keen to highlight the broad US rollout of 5G, its testimony omitted any reference to another wireless technology in which the US lead is striking – the emerging domain of spectrum sharing.

Spectrum sharing is critical for many uses of 5G and Wi-Fi, as well as the future deployment of 6G. It enables more efficient coexistence of commercial cellular, military, satellite, unlicensed and critical-infrastructure wireless systems.

The U.S. is among the leading nations in deploying platforms for dynamic multi-technology, multi-operator spectrum allocation. CBRS’s successful automated sensing and authorization function is unparalleled anywhere in the world. It also leads in mixed use of the 6 GHz band, through the AFC system, while R&D efforts undertaken through the National Spectrum Strategy and NITRD (National Spectrum Research and Development Plan) are world-class examples of spectrum innovation.

China is trying to catch up in spectrum sharing

Moreover, CTIA also mischaracterizes China’s existing and future mid-band spectrum position, misattributes some Chinese government-supported technology advances to spectrum availability rather than broader industrial policy, and crucially overlooks the Chinese Communist Party's (CCP) efforts to catch up on spectrum sharing innovation and use.

For instance, CTIA’s comparative figures include the low-power, shared 3.3-3.4 GHz range, designated specifically for joint indoor use by three of China’s MNOs. CTIA adds this into its count of exclusive and high-power spectrum, even though it is neither of those and CTIA has historically excluded low-power bands from its figures.

It also counts the entirety of the 6GHz band – which the U.S. allocated to unlicensed / Wi-Fi use – but which China has signalled will likely be used for 5G / 6G in future. However, it has not yet been allocated, and lackluster auction outcomes in Hong Kong – the first in the world for this band – may prompt a rethink for the Chinese mainland.

HK authorities raised just HKD 630 million from 300 megahertz of 6 GHz spectrum, compared to HKD 2.2 billion from another recent auction of 110 megahertz in the 850 MHz and 2.3 GHz ranges (about U.S. $80m and U.S. $280m respectively). This was significantly lower than anticipated. The nearly 10x difference in spectrum valuation indicates the lack of relevance of 6-8 GHz spectrum for national wide-area licenses. It is best used for localized needs, whether that involves unlicensed Wi-Fi, indoor cellular hotspots, or private networks.

CTIA’s testimony notes that “China today has 14x more 5G-enabled factories than the U.S.”, but there is little evidence this is driven by extra spectrum availability. It is more a result of China’s state-supported and other enterprises being pushed towards 5G deployment through CCP industrial policy and subsidies, with low-cost on-premise cores from vendors such as Huawei and ZTE, and 5G-enabled IoT products from local vendors. They have also been faster to deploy 5G “standalone” than their US counterparts, which adds extra features.

Recently, China’s authorities have indicated that they too are interested in deployment of dedicated private networks by enterprises with suitable spectrum to be made available. Given that Chinese state aircraft manufacturer COMAC has previously run a private 5G network in the 6GHz band, it seems likely that some of the 1200MHz allocation will be reserved for localized or shared use, not exclusive high-power MNO operations.

In short, China seems likely to create its own CBRS-type model. The U.S. should be extending its lead in this area, pushing for more advanced forms of dynamic spectrum sharing in bands such as the 3.1GHz and possibly 7-8GHz range, as this is a critical capability for future wireless innovation and security.

Conclusion

CTIA’s recent testimony to Congress exaggerates the relevance of additional high-power exclusive licenses for mid-band spectrum to assuring America’s continued wireless success. It also understates the current US spectrum position, ignores US leadership in dynamic spectrum sharing, and incorrectly assesses and compares the spectrum landscape for both allies like the UK and global rivals like China. If we are going to pursue smart spectrum policies, we need to be accurate and transparent in assessing the current spectrum landscapes in the US and abroad.

Dean Bubley is Founder of Disruptive Analysis. He is an independent technology industry analyst, futurist, speaker and advisor, with over 25 years’ experience in wireless, telecoms and policy fields. This Expert Opinion is exclusive to Broadband Breakfast.

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