By Ashish Jain
The proposal to relocate Citizens Broadband Radio Service (CBRS) from 3.5 GHz to the lower 3 GHz band isn’t just misguided policy – it’s a potential catastrophe masquerading as spectrum optimization. While industry giants wave around promises of better 5G deployment and spectrum efficiency, the reality is far more damaging: we’re talking about dismantling a thriving multi-billion-dollar ecosystem to satisfy the spectrum hunger of companies that already control the vast majority of licensed mid-band frequencies.
Relocation – A Solution in Search of a Problem
The CBRS relocation debate began in 2024 when AT&T proposed moving the Citizens Broadband Radio Services from the middle of the 3 GHz band to the lower part. AT&T’s “strategic rationalization of the 3 GHz band” would move CBRS from 3.55-3.7 GHz to 3.1-3.3 GHz while expanding the available CBRS spectrum from 150 to 200 MHz. The vacated spectrum would then be auctioned for high-power, licensed 5G operations.
The proposal gained momentum when the Department of Defense appeared to endorse the plan, with DoD’s circulated spectrum plan calling for moving CBRS licensees to the 3.1-3.4 GHz band, freeing up 100 MHz for auction. However, this was described as merely “a suggestion by the agency.”
The discussion gained new urgency with President Trump’s “One Big Beautiful Bill Act.” The legislation restored FCC spectrum auction authority and directed the agency to auction spectrum between 1.3 and 10 GHz to raise $85 billion. However, the concern extends to Capitol Hill, where ten U.S. Senators from both parties wrote to FCC Chairman Brendan Carr in September 2025, urging the Commission to ‘stand by its previous spectrum decisions, commitments and allocations, and avoid disruption to existing uses of spectrum.’ The Senators specifically called for protecting ‘existing operations in the 3.55-3.70 GHz band,’ and noted that rural broadband providers have made substantial investments in equipment and services centered around the use of CBRS spectrum.”
The wireless industry argues this approach would create “530 MHz of contiguous licensed mid-band spectrum to support 5G” by bridging existing licensed bands. The motivation is understandable given that PAL licenses sold at a 77% discount compared to C-band spectrum due to power limitations and coverage constraints.
CBRS Success: The Inconvenient Truth for Relocation Advocates
Having monitored CBRS deployment patterns for six years (the early days), we’ve observed success far beyond what anyone initially expected. The NTIA reported that from April 1, 2021, to July 1, 2024, active CBRS access points grew from 129,782 to 400,403 – growth we’ve documented through conversations with deployers across every sector.
Our research shows the ecosystem now includes over 415,000 CBRS devices nationwide and 865 FCC-authorized end-user devices serving diverse applications. We’ve tracked how rural CBSDs more than doubled, increasing from 103,768 to 270,418 devices, addressing connectivity gaps traditional cellular simply couldn’t reach economically.
Perhaps most significantly, 82.7% of all U.S. counties now use CBRS, per the NTIA. This widespread adoption suggests the spectrum is far from underutilized, contradicting a key argument for relocation.
Through our work with enterprises, system integrators, schools, and vendors, we’ve witnessed CBRS creating an entirely new market providing access to private wireless networks. We’ve seen firsthand that CBRS gives enterprises opportunities they wouldn’t otherwise have considered. Companies that could never justify the expense of traditional licensed spectrum are deploying sophisticated private networks for precision agriculture, warehouse automation, and campus connectivity. We’ve seen mid-sized manufacturers implement IoT solutions that were previously the exclusive domain of Fortune 500 companies, and rural schools provide reliable internet access that was economically impossible before CBRS.
The Economics Don’t Add Up: Destruction Disguised as Progress
Through our work with the ecosystem, we’ve determined that the financial case against relocation is overwhelming. The OnGo Alliance reports that CBRS companies have invested $4.7 billion in spectrum, $3.4 billion in networks, $4.4 billion in devices, and $1.5 billion in infrastructure, totaling more than $14 billion across the ecosystem.
However, the $14 billion figure dramatically understates the true economic value at stake. In our discussions, we’ve documented how CBRS has delivered productivity gains and reduced downtime that far exceed initial infrastructure investments. Toyota Material Handling’s 200,000 square-foot facility in Columbus, Indiana, reported “increased productivity, faster deliveries, and boosted employee morale” after replacing its entire Wi-Fi network with a CBRS-based private 5G network. The facility now operates exclusively over the private network with “no disruptions or connectivity loss reported since its operational launch in November 2023.”
A precision agriculture operation showed us how CBRS-enabled sensors reduced crop loss by 15%, while a manufacturing facility demonstrated 30% reductions in equipment downtime through real-time monitoring that wasn’t economically viable before CBRS.
The $14 billion also doesn’t account for enterprise costs in time – the thousands of hours spent by IT teams, consultants, and integrators learning CBRS deployment techniques, optimizing coverage patterns, and developing operational procedures. Companies have spent months perfecting their private network designs, training their staff, and integrating CBRS into their business processes. This institutional knowledge represents millions of person-hours that would be completely wasted in a forced relocation.
Now, relocation proponents want to force these stakeholders to swallow $12-14 billion in replacement costs for hundreds of thousands of access points and millions of devices, not including Navy radar replacement expenses. This represents massive economic disruption when annual CBRS infrastructure investments are growing at a 15% CAGR toward $1.3 billion in annual spending by 2027, according to SNS Telecom & IT.
We’ve witnessed the real-world impact across numerous sectors. We’ve seen CBRS networks transforming operations in manufacturing facilities, streamlining logistics at major ports, enabling seamless connectivity across higher education campuses, and optimizing warehouse automation systems. Dallas/Fort Worth International Airport expects 50% savings on mobile bills through CBRS, illustrating the practical benefits that would be disrupted by relocation – benefits we’ve observed replicated across these diverse deployment scenarios.
Technical Challenges: Complex Migration Requirements
Having worked with technical teams implementing CBRS across various environments, we understand why the relocation proposal fails technical scrutiny. The proposed destination – the lower 3 GHz band – is occupied by Department of Defense operations, requiring entirely new sharing mechanisms since the current Environmental Sensing Capability (ESC) system wouldn’t apply.
OnGo Alliance’s Kurt Jacobs noted that the lower 3 GHz “isn’t a good place to relocate CBRS anyway because it’s a very messy place to move into,” requiring fundamentally different coordination systems. This would abandon recent technical progress, including an 85% reduction in service interruptions through CBRS 2.0 improvements that expanded coverage to 240 million people.
CBRS 2.0 removed service interruptions for 72 million people and extended coverage to 91% of the population. Forcing migration to a less suitable band would likely compromise these achievements.
Regulatory Whiplash: Setting a Dangerous Precedent
In our six years tracking this market, the timing of this proposal represents the most concerning regulatory development we’ve observed. CBRS licenses were issued just four years ago, and the FCC has never repurposed successfully deployed spectrum this quickly. Such rapid policy reversal could undermine confidence in future spectrum allocations.
Industry leaders across all domains (enterprises, government, vendors, alliances, system integrators, analysts) are questioning whether the proposal is meant to be taken seriously. It suggests significant skepticism about its viability and rationale.
Rural Connectivity Implications
We’ve seen how CBRS has become essential infrastructure for rural broadband initiatives. The NTIA recognized the “licensed by rule” spectrum as reliable and eligible for the $42 billion BEAD Program designed to expand internet access for consumers and close the digital divide in schools and tribal lands. Wireless Internet Service Providers have invested substantially in CBRS equipment and deployments specifically to serve rural markets.
Relocation would force these providers – many operating on razor-thin margins – to replace equipment, potentially abandon service areas, and restart deployments in spectrum that may not provide equivalent coverage or economics. After decades of neglect, we’ve seen rural communities that finally have viable broadband options. The relocation proposal threatens to recreate the digital divide that CBRS helped bridge.
Industry And Analysts Division
The wireless industry itself shows divided opinions on relocation. Verizon told the FCC it “remains committed to advancing the CBRS band’s development and making optimal use of the band.”
Industry analysts express skepticism about relocation prospects. Mobile Experts’ Joe Madden stated, “I think it’s very unlikely that the FCC and the industry will adopt AT&T’s proposal to move everything around,” suggesting instead that “The evolution of CBRS 2.0 is a more likely outcome, with higher power levels and other changes to make the existing CBRS scheme work better.”
When your competitors, politicians, and independent analysts consider your proposal unrealistic, that’s not strategic vision – that’s wishful thinking divorced from market reality.
A Path Forward: Evolution Over Revolution
Rather than wholesale relocation, evolutionary improvements to the existing CBRS framework offer a less disruptive path forward. Enhanced power levels, refined coordination mechanisms, and expanded applications could address industry concerns while preserving the substantial investments and deployments we’ve documented.
The evidence suggests CBRS has achieved its primary objectives: simplifying spectrum access, enabling innovative applications, and supporting rural connectivity. These achievements, combined with substantial ecosystem investments and technical progress, argue for building upon rather than replacing the current framework.
The Bottom Line: When Success Becomes a Target
The CBRS relocation proposal represents a troubling trend in spectrum policy: punishing success to benefit those who failed to capitalize on opportunity. We’ve watched a successful spectrum sharing framework connecting rural America, enabling private enterprise networks, and serving as a global model for efficient spectrum use.
The suggestion that we should dismantle this ecosystem – stranding $14 billion in investments and forcing $12-14 billion in relocation costs – to create contiguous spectrum for companies that already control most licensed mid-band frequencies isn’t optimization. It’s regulatory capture masquerading as policy improvement.
We’ve watched CBRS evolve from experimental technology to essential infrastructure supporting everything from John Deere’s manufacturing facilities to Dallas-Fort Worth Airport’s operations to rural internet providers serving forgotten communities. This isn’t a failed experiment awaiting rescue – it’s a success story under assault.
The Innovation Band earned its name through genuine innovation in spectrum sharing and streamlined access to valuable frequencies. Rather than sacrificing this achievement for the convenience of major carriers who missed the initial opportunity, we should be defending and expanding it. When something works this well, the burden of proof for massive disruption should be extraordinarily high. That burden hasn’t been met, and likely never will be.
