Joel Thayer and Matthew Wong: The FCC’s $40 Billion Question
A Citizens Broadband Radio Service auction could raise $45 billion for the U.S. Treasury
The Citizens Broadband Radio Service (CBRS) occupies some of the most valuable real estate in wireless: 150 megahertz of mid-band spectrum between 3.55 and 3.70 GigaHertz (GHz). Mid-band spectrum has become the backbone of modern wireless networks. But CBRS sits in an awkward position—sandwiched between two high-power commercial bands while operating under far lower power limits.
That experiment has real consequences. In recent auctions, licenses in the adjacent 3.45 GHz band sold for about $0.73 per megahertz-pop, and licenses in the 3.7 GHz C-band sold for about $1.10 per megahertz-pop. By comparison, licenses in the CBRS band sold for about $0.22 per megahertz-pop.
Put differently, if the United States were to auction the CBRS band under the higher-power rules used by its neighbors, it might raise roughly $45 billion for the Treasury. Yet the actual 2020 CBRS auction raised $4.6 billion. In sum, the future of CBRS is a $40 billion question.
Why the gap? Power is one reason. CBRS operates under much lower effective radiated power limits than adjacent bands. The discrepancy is tens of decibels, meaning adjacent systems can transmit hundreds of times more power. The result is a regulatory seam in the middle of the 3 GHz band that forces engineers to design networks differently on either side.
Another is the sharing framework itself. When the Federal Communications Commission created CBRS’s sharing framework, it was attempting something new in spectrum policy. While much of the world uses this band for traditional 5G deployment, the United States chose a three-tier, dynamic sharing model.
Use is coordinated through spectrum access systems that allow priority access licensees and general-access users to share the band while protecting federal incumbents. But because access is dynamically assigned, operators cannot rely on a fixed amount of spectrum at the times and locations where demand is highest—meaning capacity can be most constrained precisely when it is needed most.
That framework has produced real benefits. Rural wireless providers use CBRS where licensed spectrum might otherwise be out of reach. Cable operators use it for wireless offload. Enterprises use it to deploy private LTE and 5G networks. The government has approved 350 different devices for the band and estimated that over 400,000 were in use in 2024, mostly as general-access-only devices.
But the framework is showing signs of strain. And as demand for mid-band spectrum grows, policymakers should stop treating CBRS as a settled compromise and start asking whether the current rules remain the best way to use this band.
The FCC has several options, ranging from structural reform to maintaining the status quo.
The most sweeping option would be a full restructuring of the 3.55–3.70 GHz band under a traditional licensing framework. That approach would directly address the engineering mismatch by aligning CBRS with the higher-power rules used in adjacent mid-band spectrum. The FCC could pursue an incentive auction that credits priority access license holders or an overlay auction that allows new bidders to negotiate relocation. Existing users could maintain operations until new licensees build out. Done carefully, this approach would create a more uniform and predictable mid-band spectrum landscape.
A second option would involve a partial restructuring. The FCC could auction a portion of the spectrum—perhaps the upper 50 megahertz—for higher-power licensed use while leaving the remainder of the framework intact. That approach would preserve some shared-access structure while potentially raising $15 billion and creating a cleaner block aligned with neighboring bands.
A third option would be targeted reform. The FCC could open a narrow rulemaking to harmonize technical rules with adjacent bands and allow higher power levels in rural areas, where wide coverage often matters more than dense spectrum reuse. Such incremental changes could reduce engineering friction while preserving the broader CBRS framework.
A final option is to do nothing. That would preserve the current ecosystem and avoid disruption for existing users. But it would also leave the core mismatch in place, along with the interference and coordination challenges that come with it. At a minimum, policymakers should demand greater transparency into how extensively the band is actually being used before defaulting to that approach.
CBRS was created as a compromise, an innovative attempt to expand spectrum access while protecting incumbents. But spectrum policy cannot remain static. As demand for mid-band spectrum increases, leaving 150 megahertz of prime spectrum constrained by a mismatched framework should not be the default.
The question is no longer whether this spectrum has value. The question is whether the current rules are the best way to realize that value—or whether a $40 billion opportunity is being left on the table.
Joel Thayer is president of the Digital Progress Institute and an attorney based in Washington. Digital Progress Institute is a nonprofit seeking to bridge the policy divide between telecom and tech.
Matthew Wong is a law student at George Mason University's Antonin Scalia Law School. He is interested in the intersection of technology, telecom, law, and policy. This Expert Opinion is exclusive to Broadband Breakfast.
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