Setting the Record Straight on Spectrum Priorities

Setting the Record Straight on Spectrum Priorities

As the debate over spectrum policy continues, the incumbent mobile industry continues to malign and inhibit the growth of technologies and spectrum uses that promote competition, innovation, wireless access, and consumer savings. A further new line of attack argues that spectrum design decisions should be based on which industry has spent the most money on wireless infrastructure and auctioned spectrum.

That argument is not only conveniently slanted toward incumbent wireless interests, it is demonstrably wrong. 

What matters is not which competitor has historically invested more, but instead, which design rules will best support competition and innovation and deliver the most consumer value in the provision of wireless services. 

  • If an auto manufacturer builds cars out of gold, for example, it might be able to boast enormous “investment” in those vehicles, but this would be laudable only if consumers valued that approach and preferred these cars over cheaper alternatives. Spending for its own sake says nothing about benefits for consumers or the nation as a whole.   

Instead, the better metric is value relative to spending – and, by this measure, coexistence frameworks win hands-down.

Here are four facts that should help to correct this misconception and inform a forward-leaning spectrum policy for America’s future:


Fact #1: Wi-Fi, and not licensed mobile, is the workhorse of wireless services, carrying over 85% of mobile data traffic, and over 8.5 times the amount of traffic carried over licensed mobile spectrum.

Usage figures prove indisputably that Wi-Fi is the workhorse of wireless data. Americans now rely on Wi-Fi and unlicensed wireless technologies far more than high-power, exclusive coverage networks, even when those connections are via mobile devices.

  • The latest Cisco VNI estimated that 48.6 exabytes (or 48,600,000,000 gigabytes) of U.S. internet traffic was delivered over Wi-Fi compared to only 5.7 exabytes delivered over licensed spectrum.
  • Indeed, over 86% of the bits generated by mobile providers are carried over Wi-Fi. And, over half of all U.S. and global internet traffic—wired or wireless—is delivered over Wi-Fi.

With new innovations like Wi-Fi 7 rolling out to provide gigabit speeds, lower latency, and greater security, demand for Wi-Fi and the spectrum that will fuel new applications and use will only grow.


Fact #2: Comparisons of midband spectrum between exclusively licensed and unlicensed services are artificial and misleading.

Incumbent carrier claims suggesting that there is far less "midband" spectrum available for exclusive licensing when compared to spectrum in the same range available for unlicensed use are purposefully misleading and masks the size of incumbent carrier significant holdings.

  • The definition of "midband" spectrum used by those carriers favoring high-power exclusive spectrum is arbitrary and does not include significant portions of the spectrum they currently hold.
  • The FCC has stated that there are more than 5,550 MHz of other spectrum available for wireless carriers, including mmW spectrum, outside of the narrow range referred to as "midband" by some.
  • Unlicensed MHz are not only shared but often are encumbered, making an MHz-to-MHz counting exercise irrelevant.

In reality, the incumbent mobile carriers have substantial license holdings for frequencies outside of mid-band spectrum and significant room for improvement in building denser 5G networks that facilitate spectrum reuse, an area where U.S. carriers lag their global peers.


Fact #3: Unlicensed technologies and hybrid wired-wireless network evolution drive innovation and deliver tangible consumer benefits.

Further, the unlicensed ecosystem is vibrant, innovative, and growing rapidly.

  • According to the Wi-Fi Alliance, Wi-Fi added $995 billion to the U.S. economy in 2021 and will add $1.58 trillion by 2025.
  • The Consumer Technology Association calculated that Wi-Fi and other unlicensed technologies together generate $95.8 billion per year in incremental economic sales.

In addition to unlicensed technologies, shared-licensed frameworks allow more players to enter the marketplace, giving consumers more options and better prices. Americans are concerned about the cost of mobile phone plans, and promoting spectrum coexistence will further ongoing competition in the wireless and broadband marketplace.

  • In 2023, 86% of Americans said they were concerned about cellphone prices. One in four Americans are looking to move away from the older cell phone carriers (i.e., Verizon, AT&T, and T-Mobile) and to a provider that offers more flexibility and value.
  • These trends are fueling the growth of new mobile phone and data services from cable providers that are providing consumer benefits by bringing new competition to wireless markets and offering many American households upwards of $500 and, in some cases, $1000 in annual savings.


FACT #4: Licensing models that are non-exclusive and dynamically share spectrum among various commercial and government users, like CBRS, are essential to bring more spectrum online, increase competition, and support growing consumer demands while at the same time preserving security needs.

As recognized by NTIA, the CBRS band is improving wireless coverage, reducing network costs, and serving consumers effectively, particularly in rural and underserved areas, without displacing incumbent federal users.

  • Many organizations, such as mobile carriers, schools, manufacturers and local governments, use unlicensed and shared-licensed technologies in the CBRS band for their networking needs.
  • These providers want to offer innovative service offerings, competitive pricing options and lower costs.

Claims that CBRS is not seeing enough investment or progress are inaccurate.

  • The CBRS band successfully diversified spectrum ownership with over 1,000 different operators accessing the band through General Authorized Access.
  • 368,000 CBRS base-station devices have been deployed in just the past three years, which is more than 60% of the total number of cell sites deployed by the commercial wireless industry in over 40 years.

As wireless technology continues to advance, policymakers must ignore claims from the incumbents suggesting that past spending should dictate future U.S. spectrum policy.

U.S. spectrum policy now plays a crucial role, driving the domestic economy, allocating resources for national defense, and shaping the competitiveness of American industries and innovators on the global stage. For this reason, future spectrum policy must balance the interests of all parties, not just a select few.