Spectrum Policy 2025: Insights from TPI’s Winter Series

DISCLAIMER: This post synthesizes discussions from TPI’s 2025 spectrum panel series, representing diverse perspectives, not those of TPI, its staff, or boards.

Executive Summary

The Technology Policy Institute's 2025 Winter Spectrum Series brought together industry leaders, policymakers, and experts to discuss critical issues in spectrum policy. This report synthesizes key insights across six panel discussions, highlighting the most pressing challenges and opportunities in spectrum management. Major themes include:

1. Spectrum allocation tensions between federal and commercial users continue, with significant debate about the optimal balance between exclusive licensing, sharing regimes, and unlicensed spectrum
2. International spectrum coordination faces mounting challenges as geopolitical tensions impact traditional alliances
3. Auction authority renewal remains a critical priority but is complicated by federal agency concerns, particularly from DoD
4. New business models like direct-to-device satellite services and private networks are reshaping the competitive landscape
5. Institutional reforms are needed to improve spectrum governance and decision-making processes

The past year has seen increased urgency around spectrum policy as next-generation technologies stretch available bandwidth, international competition intensifies, and preparations for the 2027 World Radiocommunication Conference (WRC-27) accelerate. This report outlines the current state of play and the key issues that policymakers should monitor in the coming year.

I. The Spectrum Demand Landscape

Evolving Demands Across Multiple Sectors

Panelists across all six sessions emphasized that spectrum demands continue to grow across virtually all sectors of the economy:

• Mobile wireless operators report traffic growth of 20-30% annually over the past five years, with accelerating demands from AI applications that could boost uplink traffic by up to 35%
• Wi-Fi and unlicensed technologies now carry up to 90% of all U.S. mobile traffic across wireless carriers and 80-90% of U.S. internet traffic overall
• Satellite services are experiencing unprecedented growth with new constellations and direct-to-device capabilities requiring additional spectrum access
• Federal agencies, particularly DoD, face increasing spectrum needs for advanced radar systems, surveillance, and other mission-critical activities

The Brattle Group estimates that mobile carriers alone will need approximately 400 MHz of additional mid-band spectrum by 2027, growing to over 1,400 MHz by 2032. However, this projection is contested, with some experts questioning whether carriers have adequately deployed the spectrum they already hold.

Convergence of Technologies

A significant development highlighted throughout the series is the increasing convergence of technologies:

• Satellite-to-cellular integration exemplified by partnerships like Starlink/T-Mobile, AST SpaceMobile/AT&T, and Apple/Globalstar
• Fixed wireless access (FWA) leveraging mobile spectrum to compete with traditional broadband providers
• Multi-orbit satellite strategies combining LEO, MEO, and GEO capabilities for optimized services
• Private networks for enterprises using both licensed and shared spectrum

This convergence creates new opportunities but also complicates spectrum management, as different services increasingly operate in or adjacent to the same bands.

II. Key Spectrum Bands Under Discussion

Mid-band Spectrum Priorities

Mid-band spectrum (roughly 1-15 GHz) remains the highest priority for most stakeholders due to its favorable combination of coverage and capacity. Several specific bands dominated the discussion:

Lower 3 GHz Band (3.1-3.45 GHz)

The lower 3 GHz band was frequently discussed as the most promising near-term opportunity for commercial access, though DoD uses in this band present significant hurdles. The National Spectrum Strategy initiated studies of this band, but questions remain about the appropriate access model:

• Mobile operators strongly prefer clearing and exclusive licensing where possible
• Others advocate for a CBRS-style sharing approach
• Some suggest exploring low-power indoor use as a compromise that might protect defense systems while enabling new commercial applications

Upper C-band (4.0-4.2 GHz)

The FCC has launched a Notice of Inquiry on extending C-band operations, potentially freeing up to 200 MHz of additional spectrum. Satellite operators expressed concerns about protecting existing operations.

4.4-4.9 GHz

This band is being studied internationally for IMT (International Mobile Telecommunications) in Regions 1 and 3 but was not included in the U.S. National Spectrum Strategy. Mobile operators identified it as an important harmonization opportunity.

6 GHz Band

The allocation of the entire 6 GHz band (5.925-7.125 GHz) for unlicensed use in the U.S. emerged as a point of contention. Some panelists argued this decision overcommitted to unlicensed spectrum, noting that many other countries have designated portions for licensed 5G use instead.

7-8 GHz Band

Mobile operators emphasized the importance of the 7-8 GHz band as the U.S. alternative to the international approach of using upper 6 GHz for mobile services. Meanwhile, unlicensed proponents argued this band should support additional Wi-Fi channels.

Emerging Frontier: Lunar Spectrum

Several panelists highlighted the emerging competition for lunar spectrum rights, noting this is both a current issue and one that will set precedents for future planetary communications. Commercial companies are actively developing networks between Earth and the moon, and the ITU is addressing lunar communications at WRC-27. The U.S. Artemis Accords represent one approach to managing these resources, but China and others are pursuing alternative frameworks.

III. Critical Policy Challenges

Federal-Commercial Spectrum Tensions

The allocation of spectrum between federal (particularly defense) and commercial users remains perhaps the most difficult challenge in U.S. spectrum policy. Key insights from the series include:

1. Structural impediments to market-based solutions: Federal agencies cannot directly benefit from relinquishing spectrum due to appropriations constraints and anti-deficiency rules.
2. Mission versus economic incentives: Commercial entities are profit-driven while federal agencies are mission-driven, creating fundamentally different approaches to spectrum valuation.
3. Changing threat environment: DoD emphasized that many systems now require 24/7 operation for homeland defense, rather than just training purposes, limiting sharing opportunities.
4. Transparency challenges: Limited information about federal systems makes it difficult to assess efficiency and sharing opportunities.
5. Trust deficit: A significant trust gap exists between DoD and commercial stakeholders, with the former concerned about mission impacts and the latter skeptical about claimed spectrum needs.

While economists emphasized the value of market mechanisms, there was widespread recognition that applying such approaches to federal spectrum faces substantial institutional barriers. As one FCC economist noted: "I've been banging my head against this wall for many years... it's a very difficult thing to do."

Auction Authority Renewal

The lapse of the FCC's spectrum auction authority emerged as an urgent near-term priority. Panelists broadly agreed that restoring this authority is essential, though they differed on the details:

• Some advocated for a clean reauthorization without specific band designations
• Others supported including a "spectrum pipeline" identifying minimum amounts of spectrum for licensed, unlicensed, and shared access
• Most agreed that specific band designations should be avoided, as they can complicate the process and reduce flexibility

The politics of auction authority renewal remain challenging, with tensions between the Armed Services Committees and Commerce Committees in Congress. Several panelists expected auction authority to be included in budget reconciliation due to revenue potential, though they noted this approach focuses on revenue rather than optimal spectrum policy.

International Spectrum Coordination

The 2027 World Radiocommunication Conference (WRC-27) loomed large in discussions, with several critical challenges identified:

1. Location concerns: The potential hosting of WRC-27 in China raised serious operational concerns, as many U.S. government and industry representatives would face significant restrictions on attendance.
2. Decision-making processes: Many panelists criticized the U.S. process for developing international positions as too slow and opaque, limiting America's ability to build international support.
3. Changing alliances: Traditional spectrum alliances are shifting, with Brazil and Mexico showing increased alignment with China at WRC-23, while BRICS countries have become more cohesive at the ITU.
4. Personnel timing: The need to appoint U.S. leadership for WRC-27 preparations much earlier than the typical six-month window before the conference.

Some panelists described WRC-23 as a low point for U.S. influence, citing incidents where the U.S. was excluded from key negotiations due to not having developed clear positions.

Institutional Reform Needs

Multiple panels highlighted the need for improvements in spectrum governance:

1. Decisive leadership: Federal agencies must be willing to make decisions even when stakeholder consensus isn't possible.
2. Centralized spectrum authority: Some suggested creating a GSA-like entity for spectrum management or elevating the Office of Space Commerce to bureau status.
3. Transparency improvements: Both domestic and international processes lack sufficient transparency into how decisions are made.
4. Technical rule modernization: Many panelists called for updates to receiver standards and technical rules to enable more intensive spectrum use.
5. Congressional score-keeping: The Congressional Budget Office's scoring methodology for spectrum legislation was criticized as opaque and subjective, potentially distorting policy decisions.

IV. Market and Technology Developments

Satellite Industry Transformation

The satellite industry has undergone dramatic transformation, evolving from a relatively stable sector to one characterized by rapid innovation and new business models:

• Direct-to-device services enable standard smartphones to connect directly to satellites, with partnerships forming between satellite and mobile providers
• Multi-orbit strategies combine different satellite altitudes to optimize service characteristics
• In-space servicing extends satellite lifespans and enables more flexible operations
• FCC reorganization created a dedicated Space Bureau to address the increased volume and complexity of satellite applications

These developments are creating both opportunities and challenges for spectrum policy, as satellite services increasingly operate alongside and in partnership with terrestrial networks.

Private Networks and Specialized Services

Private networks emerged as an area where the U.S. has established leadership, particularly through the Citizens Broadband Radio Service (CBRS):

• CBRS deployment has seen rapid growth with over 380,000 base stations deployed in three years
• Open RAN technologies are enabling more diverse equipment ecosystems
• Enterprise and industrial applications are driving specialized spectrum needs
• Rural opportunities with approximately 80% of general access CBRS usage occurring in rural areas

Several panelists identified private networking as a strategic advantage for the U.S. that should be supported through spectrum policy.

Fixed Wireless Momentum

Fixed wireless access (FWA) using 5G spectrum has gained significant momentum:

• Over the past three years, 99% of net new broadband subscribers have chosen 5G fixed wireless
• One operator reported a waitlist exceeding one million households
• Researchers estimate consumers could save $8.1 billion annually if mobile operators had sufficient spectrum to offer FWA more broadly

However, capacity constraints are limiting further growth, with operators citing the need for additional mid-band spectrum to expand service.

V. Looking Ahead: Critical Issues to Watch

Near-Term Policy Priorities

1. Auction authority renewal and potential inclusion in budget reconciliation
2. National Spectrum Strategy implementation under the new administration
3. AWS-3 auction and follow-up actions based on the upper C-band NOI
4. Personnel appointments, particularly at NTIA, OSTP, and State Department for international spectrum leadership

Medium-Term Challenges

1. Lower 3 GHz band decisions following the band studies initiated in the National Spectrum Strategy
2. WRC-27 preparation and building international support for U.S. positions
3. Receiver standards implementation following the FCC's policy statement
4. Direct-to-device regulatory frameworks as these services scale up
5. Spectrum R&D investments to improve sharing technologies and spectral efficiency

Artificial Intelligence Implications

Several panelists noted that artificial intelligence will likely have significant yet still uncertain implications for spectrum policy:

• AI applications may substantially increase upload demands on wireless networks
• Networks themselves may leverage AI for more dynamic and efficient spectrum use
• U.S. leadership in AI may depend partly on having adequate spectrum resources for the underlying networks

The Dish Decision

A major wildcard identified by financial analysts is Dish Network's decision in spring 2026 about whether to build out their network or sell their spectrum holdings (valued at approximately $62 billion). This decision could dramatically impact spectrum markets and subsequent auction dynamics.

VI. Conclusion: Bridging the Gaps

The 2025 TPI Spectrum Series revealed several persistent disconnects in spectrum policy that require attention:

1. Federal-commercial divide: The gap between federal and commercial approaches to spectrum management remains substantial, with limited progress on incentive mechanisms to promote efficiency.
2. Licensed-unlicensed balance: Stakeholders continue to debate the optimal mix of licensed, unlicensed, and shared spectrum, with fundamentally different assessments of relative value and demand.
3. Domestic-international alignment: U.S. positions at international forums are hampered by slow domestic processes and changing global alliances.
4. Short-term vs. long-term thinking: Revenue considerations and immediate demands often overshadow longer-term strategic considerations in spectrum allocation.
5. DC-Wall Street disconnect: Financial markets and policy discussions reveal different perspectives on spectrum needs and valuations.

Moving forward, addressing these disconnects will require:

• More decisive leadership at the federal level
• Creative approaches to federal spectrum incentives
• Improved technical foundations for sharing regimes
• Earlier and more coordinated international engagement
• Better integration of economic analysis in decision-making

The challenges are significant but not insurmountable. With appropriate reforms and forward-looking policies, the U.S. can maintain its leadership position in wireless innovation while meeting the diverse spectrum needs of the public and private sectors.