The Technology Policy Institute’s Winter Spectrum Series panel on CBRS revealed an interest in further economic analysis of spectrum usage. The panel featured spectrum experts Tom Power, Paroma Sanyal, Arpan Sura, and Mary Claire York. Sarah Oh Lam moderated.
Top 5 Takeaways
- CBRS’s three-tiered sharing framework supports a wide range of users. Despite early skepticism about whether military incumbents, PAL holders, and GAA users could coexist, the framework has operated without reported interference incidents. NCTA’s Marie Claire York noted that users “have been able to share with the Navy with no interference instances,” validating the SAS-coordinated approach that many doubted was technically feasible when it was proposed in 2012.
- The band hasn’t reached its build-out deadline yet. PAL licensees don’t face final service requirements until 2030. York argued it’s premature to judge a band that hasn’t hit its first milestone. Over 430,000 devices are deployed across 80%+ of U.S. counties, but nobody agrees on what “success” looks like. Device counts don’t capture actual utilization, and the SAS administrators hold coverage data that hasn’t been made public. FCC’s Arpan Sura noted, “What qualifies as spectrum usage is actually a deeply complicated question.”
- Much of CBRS usage looks like traditional wireless. Despite being called the “Innovation Band,” the majority of deployments support conventional fixed wireless and mobile broadband, services that don’t depend on the CBRS framework, said BigStar’s Tom Power. The counterargument is that entities like school districts, tribal nations, and agriculture are using it in ways they say they couldn’t replicate through other spectrum access.
- CBRS is an innovation band in the middle of the 3-4 GHz band of mid-band spectrum. Sandwiched between the 3.45 GHz band and C-band, CBRS breaks up what could be a contiguous block of licensed mid-band spectrum. A proposal was made to relocate CBRS to lower 3 GHz with DoD, but the idea hasn’t gained traction, partly because relocating existing users would be disruptive and costly. Innovation by American entities on this band is possible due to the unique design of the band compared to international harmonization in 3 GHz.
- The FCC has bigger spectrum priorities right now. Upper C-band must be auctioned by July 2027 under the One Big Beautiful Bill Act. AWS-3 is coming this summer. Presidential memoranda have flagged 2.7 GHz, 4.4 GHz, and lower 7 GHz for study. CBRS modernization remains an open NPRM with no order, and Arpan Sura made clear it’s not at the top of the queue: “In the grand scheme of things, we have more immediate goals on the horizon.”
The Measurement Problem
The panel’s central tension was definitional: how do you evaluate a shared, innovation-oriented band using metrics designed for exclusive-use licensed spectrum? Brattle Group’s Paroma Sanyal argued that auction revenue — 22 cents per megahertz-pop for CBRS versus 73–74 cents for the 3.45 GHz band — understates the band’s value because it doesn’t capture the externalities of diverse, smaller-scale deployments. Her earlier research attributed the price gap less to sharing itself than to uncertainty about PAL-GAA dynamics and interference rules.
Arpan Sura challenged all panelists to propose concrete benchmarks: “By the time 2030 comes around, what do you think are the right benchmarks for assessing whether the band has been properly utilized?” No one offered a definitive answer, but Paroma Sanyal and Tom Power converged on the need for granular data on spectral occupancy across time, frequency, and geography, not just device registrations.
Economic Impact and Evaluation
Paroma Sanyal proposed a full economic impact study comparing CBRS and C-band contributions to the broader economy, not just the telecom sector. Tom Power called for SAS administrators to release coverage heat maps. Arpan Sura pointed to the FCC’s 2023 NOI on spectrum utilization metrics as the starting framework. Before any policy changes are implemented, the band needs better data, and the people who have it can help by sharing it.
Stakeholder Interests and Investment
Tom Power acknowledged reliance interests but stated the band’s placement was suboptimal from the start, and that higher power levels on fewer towers could have delivered broader coverage more efficiently, particularly in rural areas where CBRS’s low-power design forces costly densification. Any discussion of modernizing CBRS runs into entrenched investment. Mary Claire York emphasized the broad range of users who have invested in the band, users who range from a small Texas school district running a private 5G network to the Marine Corps operating a 700,000-square-foot logistics base. Many have tied CBRS into BEAD broadband bids as well.
The History of CBRS
The Citizens Broadband Radio Service on the 3.5 GHz band has been over a decade in the making. Its roots trace to the 2010 NTIA Fast Track report and a 2012 Notice of Proposed Rulemaking, which proposed a novel three-tiered sharing framework — incumbent military radar at the top, Priority Access Licenses (PALs) in the middle, and General Authorized Access (GAA) users at the bottom, all coordinated by Spectrum Access System (SAS) database administrators. After years of refinement through further notices in 2014, orders in 2015, and rule updates through 2018, including a shift from census tracts to county-sized license areas, the PAL auction (Auction 105) took place in 2020, raising $4.6 billion from a record 228 bidders across more than 20,000 licenses. The band has continued to evolve through CBRS 2.0 upgrades in 2023–2024, which shrank military exclusion zones and extended the usable footprint. An FCC NPRM on modernizing Part 96 rules closed for reply comments in November 2024 but remains pending without an order.
Sarah Oh Lam is a Senior Fellow at the Technology Policy Institute. Oh completed her PhD in Economics from George Mason University, and holds a JD from GMU and a BS in Management Science and Engineering from Stanford University. She was previously the Operations and Research Director for the Information Economy Project at George Mason School of Law. She has also presented research at the 39th Telecommunications Policy Research Conference and has co-authored work published in the Northwestern Journal of Technology & Intellectual Property among other research projects. Her research interests include law and economics, regulatory analysis, and technology policy.
Scott Wallsten is President and Senior Fellow at the Technology Policy Institute and also a senior fellow at the Georgetown Center for Business and Public Policy. He is an economist with expertise in industrial organization and public policy, and his research focuses on competition, regulation, telecommunications, the economics of digitization, and technology policy. He was the economics director for the FCC's National Broadband Plan and has been a lecturer in Stanford University’s public policy program, director of communications policy studies and senior fellow at the Progress & Freedom Foundation, a senior fellow at the AEI – Brookings Joint Center for Regulatory Studies and a resident scholar at the American Enterprise Institute, an economist at The World Bank, a scholar at the Stanford Institute for Economic Policy Research, and a staff economist at the U.S. President’s Council of Economic Advisers. He holds a PhD in economics from Stanford University.
