Quick Answer: Three proposals hang over the Citizens Broadband Radio Service (CBRS) band at 3.55 to 3.7 GHz: relocation, new higher-power base station categories and looser emissions limits. They differ sharply in how likely they are and in what they would do to a network already built. For a CBRS private network in the field, higher power matters most, because it would wear down General Authorized Access (GAA) capacity site by site while the network keeps running. PrivateLTEand5G recommends that systems integrators (SIs) rank live sites by exposure, record a measured baseline now, size critical applications for a degraded channel, and write Federal Communications Commission (FCC) rule changes into contracts.
More than 446,000 active base stations operate in the CBRS band, according to the policy positions the OnGo Alliance announced on July 14, 2026. Nearly all CBRS devices run on the GAA tier, where no operator has priority over another, and every base station in the band was engineered to power limits the FCC has had under review since August 2024 without issuing an order.
An integrator with one distribution center live on CBRS is pricing the second. Late in the review, the client’s procurement lead asks a question the proposal never covered: if the FCC changes the rules, what happens to the network the company already paid for?
Neither trade-group statements nor carrier filings answer it, since each side argues what the band should become. The integrator needs to know how each possible outcome would affect a specific site, and what belongs in writing before the next contract is signed.
The Three Proposals Carry Very Different Risks
Federal law gives CBRS no protection from reallocation. The budget law signed July 4, 2025 (Public Law 119-21) shields the 3.1 to 3.45 GHz band but includes no carve-out for 3.55 to 3.7 GHz.
Moving the Band to Lower 3 GHz
PrivateLTEand5G treats relocation as the least likely change and the most destructive if it ever went ahead. AT&T set out the idea on October 9, 2024, in “Ten Years Later: A New Vision for the 3 GHz Band,” a blog post by executive vice president Rhonda Johnson. Under the proposal, CBRS would expand and move to 3.1 to 3.3 GHz, and 3.55 to 3.7 GHz would be auctioned for licensed, full-power use. Priority Access License (PAL) holders could relocate, take vouchers toward new high-power licenses, or accept a cash payment.
The likelihood looks low because the 2025 budget law excludes the destination band from reallocation. Tom Power, a former CTIA general counsel, said in February 2026 that the auction idea “has not got a lot of momentum behind it.”
A move would be expensive for anyone already deployed. Analyst Dean Bubley noted in RCR Wireless on May 30, 2025 that today’s devices do not support 3.1 to 3.3 GHz, which means replacing every radio and device rather than retuning them. The platform made its case against relocation in September 2025.
Power Limits Under Review
Higher power is the change PrivateLTEand5G watches most closely for deployed networks, because it is live in an open proceeding and would erode GAA capacity gradually. The FCC asked whether to add one or more classes of higher-power CBRS base stations in a Notice of Proposed Rulemaking (NPRM) in GN Docket No. 17-258, released August 16, 2024, and Verizon and EchoStar backed a new higher-power category in comments filed that November.
Category A base stations are limited today to 30 dBm of equivalent isotropically radiated power (EIRP) per 10 MHz, and outdoor Category B units to 47 dBm. The OnGo Alliance sizes the increases under discussion at 32 to 320 times current outdoor limits and opposes them in its July 2026 positions.
In February 2026, with no order yet issued, Arpan Sura, senior counsel to FCC Chairman Brendan Carr, said the agency has “more immediate goals on the horizon” and asked how the band’s success could be measured quantitatively.
Looser Emissions Limits
In the same NPRM, the FCC sought comment on revising out-of-band emissions limits at the upper edge of the band, and Verizon supported relaxing them in its December 2024 reply comments. Emissions draw less attention, and for most GAA sites they pose a smaller risk than power, though looser limits on high-power transmitters would add to the interference those transmitters cause.
Table 1 compares relocation, higher power and looser emissions limits for a network already in service.
| Proposal | Status, November 2026 | Effect on a deployed network | What design can do |
| Relocation to 3.1 to 3.3 GHz | Proposed by AT&T in October 2024; destination band excluded from reallocation by the 2025 budget law | Replacement of every radio and device | Very little, since no current hardware supports the destination band |
| Higher-power base station categories | Open question in GN Docket No. 17-258; no order | Fewer usable GAA channels and lower throughput near high-power sites | Indoor placement, a 20 MHz capacity floor and coexistence enrollment |
| Looser emissions limits | Open question in the same NPRM; no order | Added interference on top of any power increase | Measured baselines that show when and where performance changes |
Sort the Installed Base by How Much It Has to Lose
Before the next client asks, PrivateLTEand5G recommends that integrators rank every live site by exposure. Most start from the same position, since 96.3% of CBRS devices use the GAA tier, according to New America’s report “The Indispensable Spectrum,” published October 15, 2026, using July 2026 data from Key Bridge Wireless. Tier alone separates the most exposed sites from the rest. The other four factors below decide which of them needs attention first.
Five Factors That Set a Site’s Exposure
How a site would fare if higher-power classes arrived depends on where it sits on each of these:
• Access tier: GAA only, PAL, or both.
• Placement and category: indoor Category A or outdoor Category B.
• Channel dependence: how much contiguous spectrum the critical applications need.
• Neighborhood: distance from carrier CBRS deployments and PAL holders.
• Coastline: position relative to Dynamic Protection Areas (DPAs), which already cost channels when federal radar is active and which New America expects to grow sharply under higher power.
Table 2 turns the five factors into a ranking guide.
| Exposure factor | Lower exposure | Higher exposure | Why it matters under higher power |
| Access tier | PAL, or PAL with GAA | GAA only | GAA carries no priority over a louder GAA neighbor |
| Placement and category | Indoor, Category A | Outdoor, Category B | Building entry loss weakens outdoor interference before it reaches indoor radios |
| Channel dependence | Critical applications fit in 20 MHz | Critical applications need 40 MHz or more of contiguous spectrum | Lost channels break wide-channel designs first |
| Neighborhood | Rural, far from carrier CBRS sites | Metro or suburban, near carrier CBRS sites and PAL holders | PrivateLTEand5G expects high-power operators first where carriers already use the band |
| Coastline | Inland, outside DPAs | Inside or near a DPA | New America expects protection areas to grow sharply under higher power |
Measure Now, While the Rules Hold
The second half of the assessment is a measured baseline. Interference levels, channel availability, grant history and application performance recorded under today’s rules give both sides a before-and-after record if those rules shift. Measured data also has a use in the proceeding, where the FCC chairman’s own adviser has asked for quantitative evidence.
AI tools may make site-level interference analysis cheaper to produce. Federated Wireless, a Spectrum Access System (SAS) administrator, announced a tool on June 18, 2026 that uses machine learning to work out the guard bands and power limits an individual radio needs to avoid disrupting other users. Federated says field deployments showed up to five times more network capacity and up to 50% more usable spectrum capacity. Both figures are the vendor’s own claims. An exposure assessment needs that kind of per-radio picture, and the platform covers AI in spectrum access systems in more depth.
| PRO TIP: Outdoor GAA Near Carrier Sites Goes FirstAn integrator with dozens of live sites may not be able to assess all of them at once. PrivateLTEand5G would put outdoor GAA sites in metro areas with existing carrier CBRS deployments at the top of the list, since they have no priority and sit closest to likely high-power neighbors. Indoor Category A deployments with narrow-channel applications can wait for the next scheduled review. |
| Track the CBRS RulemakingDecisions on power and emissions limits would reach every deployed GAA network, and the FCC has set no date for them. Subscribe to PrivateLTEand5G to follow the platform’s coverage of the proceeding. |
Quote the Next Network for the Rules It Might Face
Changing a design on paper costs far less than re-surveying a live site after an FCC ruling. PrivateLTEand5G’s recommendations for new quotes are built so that, if the rules change, a CBRS private network loses some throughput while its most important traffic keeps flowing.
Size for a Degraded Channel
The safer design fits critical applications into 20 MHz of GAA spectrum and treats anything wider as headroom. A network that needs 40 MHz of contiguous spectrum to meet its service levels has no margin if louder neighbors take channels away. One sized for 20 MHz slows non-critical traffic first and keeps the applications that justified the network.
| PRO TIP: Two Capacity Figures in Every ProposalA quote holds up better over time when it states what the network delivers on its full channel plan today and what its critical applications get on the 20 MHz floor. Clients then read the difference as spare capacity from the start, and a later loss of channels does not look like a broken promise. |
Placement, Category and Coexistence
Indoor Category A radios belong wherever they can deliver the coverage a site needs, with outdoor Category B reserved for areas that require it. Outdoor GAA capacity is, in PrivateLTEand5G’s judgment, the most exposed asset in the band.
Every new network should also be enrolled in the OnGo Alliance’s Collaborative GAA Coexistence framework (technical specification OnGo-TS-2003, version 5.0.0, December 5, 2023). Participation is optional, so a negotiated frequency plan covers only the operators that join. The framework has no bearing on power levels, though it lets GAA neighbors coordinate channels rather than contend for them blindly.
When Priority Access Earns Its Cost
PALs are county-level licenses, and FCC rules allow light-touch leasing through the SAS, so an enterprise can lease one without bidding at auction. A lease puts a site’s radios ahead of nearby GAA users. Priority is worth pricing where losing channels would stop operations; sites carrying mostly non-critical traffic rarely justify the cost.
What Hardware Can’t Hedge
No radio choice protects a network against relocation, because nothing deployed today can operate at 3.1 to 3.3 GHz. Protection has to come from refresh cycles and contracts. Amortization periods should be short enough that a forced replacement would not leave the client still paying for stranded radios.
Traffic that tolerates contention belongs on Wi-Fi, as part of a multi-radio wireless strategy that reserves the cellular layer’s channels for applications that need them.
What to Tell the Client, and What to Put in Writing
A procurement lead asking about CBRS risk needs likelihood and impact kept apart. PrivateLTEand5G recommends a plain account of where each proposal stands, followed by contract terms that assign the risk before anything changes.
The Explanation, as of November 2026
Four points cover what a client needs to hear:
• What is certain: CBRS has no statutory protection from reallocation, and the FCC’s 2024 rulemaking on power and emissions remains open.
• What is proposed: higher-power classes and relaxed emissions limits, both backed by Verizon in its filings.
• What is unlikely: relocation to 3.1 to 3.3 GHz, a range Congress put off limits for reallocation in 2025.
• What no one can promise: the timing of an FCC order, or what it will contain.
Contract Terms Worth Raising With Counsel
None of this is legal advice, but the following belong in the conversation with the client’s lawyer:
• A change-in-law clause that names FCC amendments to the Part 96 CBRS rules as a triggering event.
• Pre-agreed rates for re-surveying and redesigning a site once new rules take effect.
• Uptime commitments that carve out interference from operators running lawfully under new rules.
• Hardware refresh terms that state who pays if a band change strands equipment.
• A named owner on the client side who follows GN Docket No. 17-258 and decides whether to file measured data.
| PRO TIP: Service Levels Tied to the BaselineAfter a rule change, a commitment written against nominal capacity invites an argument about the original design. PrivateLTEand5G sees one tied to the measured baseline as easier to defend, because when interference rises both sides can see how far service levels moved and the discussion turns to the change-in-law clause. |
Where Does This Leave You?
If you’re a systems integrator, managed service provider (MSP) or vendor with CBRS networks in the field, clients will ask about this fight before the FCC settles it. PrivateLTEand5G expects integrators with the assessments already done to give the more convincing answer. Three numbers show where you stand: the share of live sites with an exposure assessment and baseline, the share of new quotes sized for a degraded channel, and the share of contracts with change-in-law terms. None of it is quick across a large installed base. Vendors with a clear position on designing for policy risk have something enterprise buyers need to hear, and the Executive Voice Program and Partner With Us give them a platform to make that case.
For an enterprise IT or operational technology (OT) team running a CBRS private network, the useful question to put to your integrator is which sites are outdoor GAA and how much capacity each would keep on 20 MHz. Ask for the exposure assessment and the baseline in writing, and look for a change-in-law clause at the next renewal instead of after an FCC order. The goal is every site’s exposure known and every contract clear on who pays if the rules move. Before any of those vendor conversations, the wireless self-audit offers a 10-question, scored self-assessment that takes about five minutes.
FAQ
Should we pause new CBRS deployments until the FCC decides?
The proceeding has been open for more than two years with no order or set date, and a pause carries its own cost in delayed operations. A network sized for the 20 MHz floor, with rule-change terms in the contract, is a better hedge than waiting, in PrivateLTEand5G’s view.
Does moving from private LTE to 5G standalone change our exposure?
Power and emissions rules apply to the band, whatever air interface runs in it. A 5G standalone network on GAA carries the same exposure as an LTE network at the same site, so the technology roadmap and the spectrum risk are best assessed separately.
Is a rural site safe because it is far from carrier deployments?
Distance helps less than a map suggests. Canadian operators run the band at higher power, and Valo Analytica found, in a March 2026 study for Spectrum for the Future (a coalition opposing higher power), that they disrupt some Amplex Internet customers up to 200 km away.
Would a PAL protect a site if higher-power categories are approved?
The FCC has adopted no rules for a higher-power class, so nobody knows whether one would sit under PAL priority, under GAA, or in a new tier altogether. A PAL lease improves a site’s position against today’s GAA neighbors. Its value under future rules is unknown.
