Contention for midband spectrum in the 3 GHz band is intensifying as a reorganization of the band’s allocation appears likely within the next 2–3 years. This spectrum race affects a diverse group of stakeholders, including mobile network operators (MNOs), government users, cable operators, small and rural internet service providers, satellite operators, and enterprises such as academic institutions, oil and gas companies, and utilities. Rarely does a spectrum reallocation impact such a varied set of entities. The FCC and NTIA are developing plans that will shape this process. To understand these developments, let’s first establish a baseline.
Recent Spectrum Auctions: Competition and Value
Midband spectrum has only recently become available in large quantities. Between 2021 and 2022, the FCC held two auctions: one for 280 MHz in the C-band (3700–3980 MHz) and another for 100 MHz in the 3.45 GHz band (3450–3550 MHz). The C-band auction, the largest in history by valuation, raised $81 billion for the government, driven by fierce competition among major MNOs—Verizon, AT&T, and T-Mobile. In contrast, the 3.45 GHz auction was less competitive, raising over $22 billion, approximately 22% less in $/MHz-PoP than the C-band spectrum. This reduced competition stemmed from factors such as a 40 MHz spectrum cap and Verizon’s decision to abstain from bidding.
Earlier, in 2020, the FCC auctioned Priority Access Licenses (PALs) in the CBRS band (3550–3700 MHz) under a unique tiered spectrum-sharing framework. This framework allows federal users, including the military, to share spectrum with PAL licensees and General Authorized Access (GAA) users. PAL licenses sold at approximately a 77% discount compared to C-band spectrum due to factors such as lower transmit power and reduced coverage range, among others.
AT&T’s Push for CBRS Spectrum Reallocation
Over the past year, AT&T has proposed consolidating the 3.45 GHz band and C-band by relocating CBRS users to the 3.1–3.45 GHz band and auctioning the 150 MHz CBRS spectrum after revising operational rules, such as allowing high-power transmitters. AT&T holds 40 MHz in the 3.45 GHz band and an average of ~80 MHz in the C-band but owns no CBRS spectrum, positioning it to benefit significantly from a restructured CBRS band compared to other MNOs.
Conversely, the Department of Defense (DoD) has reportedly suggested vacating 100 MHz of CBRS spectrum. However, the 3.1–3.45 GHz band remains off-limits for mobile service allocation, as confirmed by the House Energy and Commerce budget reconciliation bill draft. These drafts require the FCC to identify and auction 600 MHz of spectrum between 1.3 GHz and 10 GHz by 2034. The FCC must auction at least 200 MHz within two years of the bill’s enactment.
Emerging Spectrum Candidates: New Bands in Play
While the 3.1–3.45 GHz spectrum was seriously considered for mobile services under the Biden administration, current policy prioritizes retaining this band for the DoD. However, other spectrum bands have emerged as candidates for reallocation:
- The FCC has explored releasing up to 220 MHz in the upper C-band (3980–4200 MHz), currently used by satellite service providers such as Intelsat, SES, and Eutelsat. Responses to the consultation were mixed, with some satellite operators supporting a partial release while others objected. Nevertheless, a partial release of approximately 100 MHz appears highly likely.
- The DoD has identified several bands for potential allocation to mobile services, including: a. 1300–1350 MHz (50 MHz) b. 1780–1850 MHz (70 MHz) c. 5850–5925 MHz (75 MHz) d. 7125–7250 MHz (125 MHz)
- The NTIA has proposed the 7125–8400 MHz band for wireless broadband use, either licensed or unlicensed. This band is currently occupied by mission-critical federal operations, including Fixed, Fixed Satellite, Mobile, Mobile Satellite, Space Research, Earth Exploration Satellite, and Meteorological Satellite services. As a result, only portions of this 1,275 MHz band could be repurposed to protect incumbent users.
Operational Drivers: Why Contiguous Spectrum Matters
AT&T’s position, and that of MNOs in general, stems from more than just acquiring additional spectrum. Instead, financial and operational cost considerations must be carefully weighed.
Wireless technologies are increasingly adopting larger channel bandwidths. For instance, 6G will support channel bandwidths of up to 200 MHz, surpassing the 20 MHz in 4G/LTE and 100 MHz in 5G. For more details on MNOs’ stated requirements for 6G, refer to my previous articles [here and here].
Operators benefit from contiguous spectrum allocations, as opposed to the fragmented spectrum AT&T currently holds in the 3.45 GHz and C-band. Carrier aggregation across widely separated bands is costly, requiring additional hardware (capital expenditure) and increasing power consumption (operational expenditure). This is likely a key driver behind AT&T’s position. Contiguous channels enable lower-cost radios, reduced power consumption, and higher efficiency, which decrease both capital and operational expenses. In contrast, carrier aggregation across non-contiguous channels is expensive to implement.
Impact on CBRS Users: Risks for Rural and Enterprise Operators
The push by AT&T, and MNOs in general, for CBRS spectrum reallocation, combined with the DoD’s partial willingness to vacate 100 MHz of the 150 MHz CBRS band, poses risks to General Authorized Access (GAA) users and other Priority Access License (PAL) holders, including cable companies and enterprises (e.g., oil and gas, utilities). At the 2020 CBRS auction, MNOs secured 31% of the licenses sold but accounted for 62% of the funds raised by the FCC, with Verizon and Dish contributing the majority in a roughly 2:1 split favoring Verizon. In contrast, small and rural service providers, along with various enterprises, won 54% of the licenses but represented only 11% of the auction proceeds. As the government seeks to raise funds and reduce the deficit, the FCC may view CBRS reallocation favorably.
Regarding deployments, most CBRS systems today operate under GAA. Verizon has deployed some CBRS base stations tactically, but not extensively. According to a 2024 NTIA report, GAA users accounted for 71.4% of over 400,000 active CBRS base stations by mid-2024, while PAL holders accounted for 28.6%, or 114,682 base stations. Notably, rural areas hosted 67.5% of CBRS base stations by mid-2024, marking the highest growth category with a 160% increase between April 2021 and July 2024. [For additional information on key developments related to CBRS, see my earlier article here.]
Overall, wireless Internet service providers (WISPs) and enterprises stand to lose the most from the potential CBRS spectrum reorganization and reallocation to MNOs. Currently, they access 80 MHz of nearly license-free spectrum. This could shrink to 50 MHz or be entirely relocated to another band, which would be particularly detrimental as the new band may lack the robust equipment ecosystem developed for CBRS over years. Financial considerations will also significantly influence this outcome.
Concluding Thoughts: Balancing a Complex Spectrum Future
The reorganization of the 3 GHz midband spectrum is a pivotal challenge that demands a delicate balance of competing interests and complex considerations. Reallocating spectrum risks disrupting rural service providers and enterprise private network operators, who rely on affordable access to bands like CBRS for critical connectivity. Meanwhile, the operational efficiencies of contiguous spectrum allocations could drive significant cost savings and performance gains for MNOs, supporting the rollout of advanced technologies like 6G. Achieving an equitable outcome requires a comprehensive evaluation of financial, market, regulatory, and technical factors. Policymakers, industry stakeholders, and regulators must collaborate to craft a spectrum strategy that fosters innovation, preserves access for diverse users, and supports national priorities.