The Road to Convergent Connectivity

Along with ubiquitous coverage, seamless connectivity is central to convergent connectivity. This refers to the ability of a device to maintain a stable and uninterrupted internet connection as it transitions between different types of networks, such as Wi-Fi and cellular networks.¹ But even among networks relying on a compatible air interface, attaching to a network in a new location, or in an area where your particular provider’s signal is absent, is at best a conscious chore. The most frequent example of this is Wi-Fi, where most users seeking to get connected—or stay connected—face the frustration of a “captive portal” rather than the sort of automatic and invisible connection made at home or work.

A recent CableLabs blog describing the benefits of “context-aware” devices and networks put it well:

“When we think about ‘our network,’ we envision the Wi-Fi router sitting in our home—a fixed point in space that defines where we can connect. Step outside that bubble, and our devices become digital strangers, forced to navigate a maze of guest networks, captive portals and security compromises. Even within our homes, every new smart device demands its own setup ritual: entering passwords, scanning codes, downloading apps and hoping everything connects properly.”²

In contrast, true convergence achieves frictionless (automated) device operation across:

• Multiple and interoperable radio/access/networking technologies
• Licensed and unlicensed spectrum
• Public, private, and personal (home) networks³

In addition to robust coverage and connectivity everywhere, a 6G wireless ecosystem should include automated handoffs between federations of interoperable network infrastructure that includes mobile, satellite, and Wi-Fi (fixed) networks to the greatest extent possible. While uninterrupted connectivity is valuable in all locations, maintaining a connection between indoor and outdoor use (and vice versa) will become increasingly more important—and more challenging—for at least two reasons. First, the very high-throughput and low-latency applications imagined for 6G will be used predominantly indoors, where Wi-Fi will increasingly dominate, even if users move from time to time outdoors (much like streaming video today, but more so).

Second, these 6G use cases will require such wide channels and strong signals that mobile transmissions from outdoor cell sites will find it more and more difficult to deliver indoors as cellular operators use higher frequency spectrum (particularly upper mid-band spectrum above 4 GHz) and as buildings are increasingly insulated to save energy, including with Low-e glass that blocks most signals. In short, automated and context-aware handoffs between mobile cellular networks and Wi-Fi, satellite, and private neutral host networks will move from nice-to-have to must-have from a user perspective.

Wi-Fi’s Growing Dominance and Reliability Indoors

Seamless connectivity between Wi-Fi, mobile, and satellite networks is increasingly important because the demand and need for high-capacity wireless broadband and data connectivity is, and will continue to be, increasingly indoors. Americans spend more than 90 percent of their time—and consume more than 80 percent of their data—inside.⁴ While the full scope and nature of a future 6G wireless ecosystem remains hypothetical, the very high-capacity applications and use cases most frequently offered as the rationale for investments in 6G by the Next G Alliance and others—such as virtual reality, telepresence, ultra-high definition video, immersive gaming, enterprise IoT, and more—will operate overwhelmingly indoors.⁵

Wi-Fi drives data consumption on mobile devices.⁶ The share of mobile device data traffic offloaded to Wi-Fi (and thus bypassing cellular networks) exceeds 80 percent in the United States and reportedly exceeds 90 percent in Europe.⁷ In fact, the economics of indoor use over shared spectrum allows Comcast, Charter, and Cox to support more than 18 million subscribers with a high-capacity mobile service that relies on Wi-Fi for roughly 90 percent of data use and, for use “on the go,” mobile connectivity via Verizon.⁸ Perhaps more surprisingly, Opensignal finds that U.S. smartphone users are increasingly on Wi-Fi away from home (77⁠–⁠88 percent of the time).⁹ Similarly, the vast majority (more than 80 percent) of IoT connections are to Wi-Fi or other unlicensed technologies, particularly Bluetooth and LoRa, not to cellular.¹⁰

Indeed, one important conceptual step for policymakers is to stop believing that mobile networks are “offloading” data onto Wi-Fi networks, as if the local area network is some sort of adjunct to a dominant mobile network that will (eventually) carry all the traffic. The more accurate construct is that mobile and Wi-Fi (fixed) are two complementary and essential networks with an imperfect degree of integration attributable entirely to Apple, Samsung, and other device manufacturers. A starting point is the recognition that for most users and purposes, Wi-Fi is the most cost-effective connection, particularly indoors, where (at a minimum) policymakers should ensure the technology has sufficient spectrum access and technical rules (e.g., power levels) to optimize its potential as a complement to fixed, mobile, and satellite networks. Indoor connectivity should be the realm of Wi-Fi and private networks (e.g., neutral host networks relying on Citizens Broadband Radio Service [CBRS] spectrum),¹¹ and devices should, as they mostly do now, automatically move to the fixed network indoors when they can authenticate to a strong signal.¹²

As augmented and virtual reality (AR/VR), AI, health monitoring, and other innovations make seamless connectivity between indoor and outdoor locations and in remote areas more and more valuable, finding ways to allow devices to choose the best connection for the circumstances—based on preferences the user sets (e.g., trade-offs between cost and quality) should be a central goal in defining the 6G wireless ecosystem that best serves the public interest. By the time 6G standards are finalized, Wi-Fi will be at least two more generations advanced, with capabilities that are being designed to fit the sort of applications that will require not only far greater capacity and far greater latency, but also more deterministic connections that enable the prioritization of selected applications that need, for example, very low latency. In fact, it is early days for the still-new Wi-Fi 6E standard that can operate on channels as wide as 160 megahertz across the 6 GHz band. Most Wi-Fi 6 routers and phones do not support 6 GHz use; only Wi-Fi 6E and emerging Wi-Fi 7 models do.¹³

Wi-Fi 7 has just begun to be deployed by enterprise and home users, but the performance gains are already evident. Ookla, which collects massive samples of speed test data from user devices, reported in June 2025 that while adoption is only 2 percent, Wi-Fi 7 users are experiencing up to 1 Gbps download speeds on fiber, although substantially slower uplinks (64 Mbps for the three largest cable companies versus 595 Mbps for seven fiber companies).¹⁴ (See Figure 3, which shows Ookla data on current Wi-Fi use by generation.) According to Ookla, early adopters report significantly higher satisfaction compared to legacy Wi-Fi. The company believes gigabit-level performance and stronger uplink capabilities will “unlock new possibilities for gaming, AR/VR, remote work, and AI-powered homes.”

The next generation standard, Wi-Fi 8, will provide “ultra-reliable performance everywhere,” according to Qualcomm and other chipmakers.¹⁵ The focus will be on reliability rather than speed. Unlike today’s Wi-Fi, Qualcomm expects that Wi-Fi 8, operating across the 6 GHz band, will be a difference in kind, “designed to deliver consistent, low-latency and near-lossless connectivity even in highly congested, interference-prone and mobile environments.” According to the IEEE scope document, Wi-Fi 8 will introduce, first, at least 25 percent higher throughput in challenging signal conditions; second, 25 percent lower latency at the 95th percentile of the latency distribution; and third, 25 percent fewer dropped packets, especially when roaming between access points (APs).¹⁶

Qualcomm also highlights that the new capabilities being standardized for Wi-Fi 8 (IEEE 802.11bn) will enable seamless roaming, at least among Wi-Fi APs:

“802.11bn introduces a transformative approach to mobility through the concept of Single Mobility Domains, enabling seamless roaming across multiple access points. This allows devices to provide a ‘once connected, always connected’ experience by maintaining continuous, low-latency connections as they move—without the interruptions or packet drops caused by traditional handoffs.”¹⁷

While even this limited form of “seamless roaming” will be an improvement, particularly for enterprise or public Wi-Fi networks, the bigger challenge—discussed just below—is to enable truly seamless connectivity for devices across Wi-Fi (and cellular) networks that are not part of the same domain.

Wi-Fi/Cellular Interoperability: Seamless Handoffs

As noted above, today mobile carriers often cannot deliver a strong signal and wide-channel connectivity to users indoors, where at least 80 percent of mobile device data is consumed. This problem will only grow more challenging as mobile operators rely on spectrum bands above 2 GHz for 6G applications that require very high-capacity and near-real-time latency. The conundrum is that today operators are often able to meet basic connectivity needs indoors—for calls, texting, low-bandwidth web browsing—only by relying on their very limited high-penetration but narrow-band spectrum below 1 GHz. (This is similarly the case with coverage outdoors in many rural and low-density areas.) But the applications envisioned as drivers of demand for 6G will require the high throughput and wider channels that will rely on higher mid-band spectrum with far worse propagation from outdoors to indoors. And the challenge of reliable indoor coverage from outdoor cell sites only worsens as more and more buildings install Low-e glass and concrete or other insulated building materials that are harder to penetrate. The possibility of achieving reliable, high-capacity signals deeper inside a building, or below ground level, will further dwindle. All of this makes seamless handoffs between mobile/WANs and Wi-Fi/LANs crucial.

The Reality of Poor and Worsening Indoor Mobile Coverage

Several recent studies have shown that the penetration loss of 5G signals through building materials steadily increases at higher frequencies, including the upper mid-band frequencies where mobile operators are seeking more spectrum access for 6G. For example, two academic studies presented at an IEEE conference in December 2024 measured wideband penetration loss through building materials at 6.75 GHz and other upper mid-band frequencies. One focused on the penetration loss by four typical building materials (wood, glass, foam, and concrete) from 4 to 16 GHz, finding that “penetration loss generally follows a linear distribution with frequency, except for glass.”¹⁸ The other study found Low-e glass walls present 33.7 dB loss at 6.75 GHz and 42.3 dB loss at 16.95 GHz, with consistently higher penetration loss at higher frequencies.¹⁹ A 2021 white paper by Aptilo, a subsidiary of Enea, estimated that the building penetration of 5G signals worsens steadily above 2 GHz and drops off precipitously above 4 GHz. ²⁰

In a pair of articles explaining the wide variation it found in cellular coverage and signal strength indoors and outdoors, Ookla found that as “mobile data usage continues to concentrate indoors, networks built to prioritize outdoor coverage often don’t deliver the performance users now expect inside buildings.”²¹ Ookla’s crowdsourced measurements (from user devices) found that as mobile carriers rely on higher frequency spectrum for 5G (e.g., 3 GHz mid-band and above) it “limits the ability of the existing mobile network site grid to provide high-speed mobile coverage deep indoors. Simply put, the signals that mid-band 5G networks rely on struggle to penetrate the materials in their path when the user is indoors.”²² It found that “traditional coverage maps often present an overly optimistic view of network performance—especially indoors—based on computer-modeled predictions rather than reflecting the actual signal conditions enjoyed by end users.”²³

Ookla’s speed test data revealed large pockets of poor in-building coverage in major global cities. In central London, for example, it found a large share of buildings with poor indoor cellular reception (colored red and orange in Figure 4 below). In Dublin, Ookla likewise found that even important urban locations, such as University College Dublin, had widespread indoor connectivity gaps. Users able to receive basic coverage indoors were typically pushed onto low-band spectrum (800 MHz), which has better propagation but very limited capacity. The article noted that these low-band cellular connections have decreasing utility because “the significant increase in the density of devices and the intensity of their data traffic demands mean these frequencies alone are unable to support the higher performance attributes often expected with 5G, particularly in dense urban settings.”²⁴

This indoor coverage problem is worsening even for large enterprises: Years ago mobile carriers were willing to install a distributed antenna system (DAS) inside certain high-density buildings, often in return for exclusive service contracts—but those days are over. Recent reports confirm that as existing in-building cellular systems age out, “enterprises must upgrade their own systems at their own expense” and without the benefit of in-house cellular expertise.²⁵ According to a Fierce Wireless report, “MNOs are primarily focused on the huge, public-facing venues such as stadiums and airports. But in terms of the thousands of enterprise buildings that need wireless upgrades, the carriers have shifted their business models.”²⁶ As a result, offices and smaller venues are on their own. Neutral host networks operating primarily on the shared CBRS band are beginning to fill that gap with indoor APs that can allow customers of any mobile carrier to remain seamlessly connected, but private LTE/5G networks operated by enterprises are new and will take time to proliferate.²⁷

The indoor connectivity challenge for mobile operators will be further aggravated because many core applications anticipated for 6G (e.g., AR/VR) will require more high-capacity and low-latency uplinks from consumer handsets than video streaming does today. Broadcom, a leading semiconductor manufacturer, recently revealed that its field trials show that upper mid-band spectrum (specifically, the upper 6 and 7 GHz bands) “struggle to support reliable uplink, especially for indoor users who are located beyond ~300 m from the outdoor cellular tower.”²⁸ It noted that Telefónica Germany’s recent testing in upper 6 GHz “proves the point: while downlink capacity is impressive, uplink collapses at cell edges—even with 100 MHz of bandwidth.”²⁹

Mobile carriers could mitigate this problem by greatly densifying their network infrastructure, but this would be staggeringly expensive. As Webb notes in The 6G Manifesto, one engineering rule of thumb is that doubling the frequency cuts the range in half, which results in a need for four times as many cell sites to deliver the same signal quality.³⁰ This suggests that each move up the frequency spectrum—e.g., from 800 MHz to 1.6 GHz, from 1.7 to 3.5 GHz, from 3.5 to 7 GHz—requires four times as many cell sites, implying the need for 64 times as many for a 6G channel operating in 7 GHz. Even limiting densification to metro areas suggests an unprecedented capital expense considering U.S. mobile carriers had a total of 432,000 active cell sites at the end of 2024 (both microcell and small cell), according to CTIA.³¹

The Daunting Challenge of Cellular/Wi-Fi Interoperability

As industry and governmental bodies outline visions for 6G use cases, it is clear that both sectors are downplaying the importance of integrating connectivity for Wi-Fi (indoors) with cellular (outdoors). In smartphones today, a user can manually select to use Wi-Fi or cellular, but the connections are not automatically maintained when one network or the other becomes unavailable or insufficient for the user’s activity. An exception is Voice over Wi-Fi, if it is provided by the mobile carrier and natively integrated into the smartphone’s dialer.³²

Seamless connectivity, for smartphone users today and for augmented reality and other use cases going forward, must include ensuring that users experience service and session continuity without noticeable interruptions or degradation in performance as they move between locations where the most reliable or cost-effective connection changes between mobile, fixed (Wi-Fi), or satellite networks. It has been beneficial to both consumers and mobile operators that smartphone operating systems include a feature that continually searches for Wi-Fi networks open to join, effectively pushing users onto home, work, and other Wi-Fi networks where there is an established authentication.

Unfortunately, while each of the respective standard bodies for Wi-Fi and mobile (IMT) have made technical progress on their own, there appears to be no scalable solution in sight based on the sort of multistakeholder collaboration (between 3GPP, Wi-Fi Alliance, and leading device and chipmakers) that would be necessary. Industry experts we consulted believe that developing a solution that can scale to benefit most consumers and stakeholders is less a technical challenge than it is a multifaceted collective action and competition problem. This is particularly true for the mobile and Wi-Fi industries, neither of which want to cede control of wireless data traffic management to the other, nor invest heavily in a solution that will give the other an advantage.

There are two primary scenarios that would make seamless transitions between cellular and Wi-Fi connections very valuable for users, particularly in a future 6G ecosystem with very high-capacity and real-time connectivity between nearly everything of consequence, indoors and outside. One scenario is mobility-based (a device moving between indoors/outdoors) and the other is congestion-based (where the other network has better availability).³³ Figures 5A and 5B illustrate the two cellular/Wi-Fi transition scenarios in which seamless transitions between cellular and Wi-Fi networks could most benefit consumers.

The mobile industry has made the most progress. Its global standards body, the 3rd Generation Partnership Project (3GPP), introduced Access Traffic Steering, Switching and Splitting (ATSSS) as an optional feature in 3GPP Release 16. ATSSS enables devices to intelligently manage traffic across multiple access networks, including Wi-Fi, by routing all traffic through a common mobile 5G core. ATSSS provides three distinct operating modes:

• Steering: Choosing the best available network based on speed, cost, and latency;
• Switching: Moving seamlessly between 5G and Wi-Fi networks; and
• Splitting: Using the highest priority network until congested, then splitting traffic across both networks.³⁴

ATSS faces implementation challenges that make it unlikely to benefit users outside controlled enterprise environments. Most notably, ATSSS implementation requires operators to own a 5G core and have effective control over both mobile and Wi-Fi data traffic (see Figure 6). In practice, this means that it would be implemented as a mobile carrier service, in connection with an enterprise virtual private network or even operator-provisioned Wi-Fi, with both mobile and Wi-Fi traffic tunneled through the MNO’s 5G core. In addition, the three functionalities above translate into four ATSSS standard steering modes that need to be supported in the device as well as by the mobile core. Since this functionality is not standard in today’s smartphones, device makers would need to actively participate to reach a mass market. The ATSSS concept has been tested successfully by Korea Telecom using a proprietary solution, but it is not widely available.

On Wi-Fi’s side of the seamless handoff equation, the IEEE published a standard for Media Independent Handoff (MIH) in 2008. IEEE 802.21 supports algorithms enabling seamless handoffs between fixed (Wi-Fi) and cellular networks. However, it never gained commercial adoption, and the 802.21 working group has been in hibernation since 2019.³⁵

The Wi-Fi Alliance, which certifies devices, and the Wireless Broadband Alliance (WBA) have focused more heavily on seamless access across Wi-Fi networks (discussed in the next section), but both currently have working groups studying solutions for seamless connectivity with cellular. Much of the emphasis among Wi-Fi stakeholders is to determine the key performance indicators (KPIs) that should trigger a device’s switch from Wi-Fi to cellular, or vice versa. WBA’s Access Network Metrics Working Group is developing a framework to enable Wi-Fi equipment vendors to define and expose Wi-Fi Quality of Experience (QoE) centric metrics to other stakeholders, including mobile operators and Wi-Fi end users. The Wi-Fi Alliance has multiple efforts largely aimed at defining a standardized set of KPIs that can be used in deciding when to transition a device to another Wi-Fi network or to a different radio access network (RAN), such as cellular.³⁶ A related effort aims to enable Wi-Fi APs to know the cellular connection status of end user devices that are associated or seeking to associate with the Wi-Fi network.

CableLabs, the technical research arm of the cable industry globally, has its own seamless connectivity working group focused on “testing congestion-based and mobility-based scenarios to allow a more accurate characterization of the transition problem” between Wi-Fi and cellular networks.³⁷ Their goal is to define and implement “a standardized way of transitioning devices across the Wi-Fi and cellular networks based on operator defined triggers” and quality of service thresholds that best meet the needs of end users.³⁸ Currently, no standardized quality of service thresholds have been defined or made transparent to the components of the ecosystem (devices, mobile operators, Wi-Fi APs, chipsets).

As a starting point, CableLabs testing last year focused on the so-called sticky Wi-Fi problem. Although smartphone algorithms push devices onto trusted Wi-Fi networks (at home or work, for example), Wi-Fi APs and devices attempt to remain connected even at the very edge of the local area network’s coverage, including when the user is now outside and has a more robust cellular signal.³⁹ The CableLabs group has used this problem as part of the larger effort to define the KPIs and standardize the thresholds at which a device should automatically transition to the better signal.

Overall, the current state of play is that seamless transitions between networks with different RANs (namely, cellular and Wi-Fi) are not close to consensus or implementation across the multiple and essential stakeholders in the ecosystem. While the technical foundations exist, widespread implementation faces significant ecosystem coordination challenges that will likely take several more years to fully resolve—and which may benefit from some form of regulatory intervention.

Open Roaming: Automating Wi-Fi Connections

An equal if not greater gap in seamless connectivity—and the challenge that should be easier to solve—is automating the authentication and connection to Wi-Fi networks as users move from location to location. Most users take it for granted that when they walk into their home or office their smartphone will immediately and automatically join the Wi-Fi network. This might even work at some retailers (e.g., Starbucks), across a college campus, or at the local library for those who have registered and used the network recently enough. The friction and literal disconnect occurs when the user moves inside a Wi-Fi environment where her device is a stranger to the network. Even when these venues and locations offer an open Wi-Fi connection, captive Wi-Fi portals that require manual registration or other steps to gain access—and which sometimes deny access—are a frequent and largely unnecessary barrier to seamless connectivity.

The technology to automate Wi-Fi network identification and authentication exists and is operating among a growing federation of enterprise Wi-Fi environments. But so far, coordination problems loom large. The leading standard is Passpoint (Hotspot 2.0), developed by the Wi-Fi Alliance, which eliminates the need to manually scan for open networks and authenticate with passwords or agree to terms of use. Most smartphones and mobile carriers in the United States today sell phones that incorporate Passpoint.⁴⁰ Wi-Fi Alliance has emphasized the ability to automatically roam onto public Wi-Fi networks in airports, hotels, cafes, public spaces, shopping malls, health care facilities, and so on, which number in the millions globally.⁴¹

The challenge has been to create generally recognized and sufficiently secure means of identifying and authenticating users across Wi-Fi networks. The more recent OpenRoaming initiative builds on the Passpoint standard by creating a global federation of Wi-Fi aimed at accelerating adoption. The OpenRoaming federation effort was launched by Cisco, but is now operated by the WBA.⁴² The federation consists primarily of network providers (such as venues or enterprises offering Wi-Fi access) and identity providers (such as device makers and fixed and mobile internet providers). Once a user’s device is provisioned with a Passpoint profile, it is recognized and can automatically connect to any OpenRoaming-enabled network without the need to manually input credentials or accept terms. For example, both AT&T and T-Mobile support Passpoint, enabling users to automatically authenticate to a Wi-Fi network that accepts Passpoint using their existing SIM credentials.⁴³

According to the WBA, the federation remains relatively small but has been growing at an accelerating rate. A WBA survey of enterprise Wi-Fi users reported earlier this year that 81 percent said they plan to deploy the technology, with 25 percent already in the process of rolling it out. Cisco reports that as of early 2025 it had integrated OpenRoaming capability into 3,870 enterprise networks that operate roughly 8 million Wi-Fi APs.⁴⁴ Although Cisco did not report what share have activated OpenRoaming, their experience at least indicates the solution has the potential to scale. For example, RCR Wireless News reported that Cisco is working with the Canary Wharf Group and Virgin Media in London to deploy OpenRoaming-enabled Wi-Fi connectivity to more than 20,000 businesses, retailers, cafes, workspaces, and residents.⁴⁵ 

LEO Satellites: Closing Rural Coverage Gaps

Despite painstaking progress, rural households are still more likely than urban households to have fewer provider choices, lesser quality options, or no available broadband infrastructure at all.⁴⁶ The enormity of remaining rural coverage gaps was the primary driver behind Congress’s decision in 2021 to allocate over $42 billion to the Broadband Equity, Access, and Deployment (BEAD) Program, the federal broadband infrastructure initiative intended to close all remaining broadband deployment gaps. On top of this basic broadband gap, a significant share of the continental U.S. land area lacks reliable mobile cellular connectivity, although established coverage estimates are based on population rather than geography.

From this landscape, Low Earth Orbit (LEO) satellite service has recently emerged to provide broadband service to households consigned to lesser or no broadband access, as well as more basic connectivity to mobile devices in rural and remote areas virtually anywhere. Over the last several years, LEO satellite providers have begun to offer home broadband with lower latency and speeds comparable to fixed broadband options,⁴⁷ in some places directly competing with traditional wireline broadband service providers to provide fixed home broadband service to unserved households. At the same time, the industry is aggressively expanding. Following a period of rapid growth, SpaceX’s Starlink has built out its ground infrastructure to reach more than 100 gateway sites in the United States alone, launched over 7,800 satellites,⁴⁸ and has upward of 2 million U.S. subscribers.⁴⁹

Some argue that LEO satellite connectivity is the missing puzzle piece necessary for ubiquitous broadband coverage across the country. There is no doubt that the technology has added new life to the world of intermodal competition. Because LEO satellite service is bound by capacity but not geography—so long as users have a clear view of the sky—over 99 percent of the country has potential access to Starlink already, and Amazon Leo has begun launching its own constellation as well.⁵⁰ Although upload speeds may not always reach the FCC’s benchmarks, given the right conditions, speeds appear high enough to meet the typical user’s needs.⁵¹ However, current capacity limitations remain severe and ongoing. A recent analysis found that Starlink’s performance deteriorated when serving more than seven customers in a square mile,⁵² while another group found that LEO service was best suited to reliably serve barely a quarter (26 percent) of locations eligible for BEAD funds.⁵³ Even with its current consumer base, capacity in some areas is so restricted that Starlink has been adding $750 upfront fees to discourage further uptake.⁵⁴ LEO satellite is not a comprehensive solution fit for all of America yet.

Still, the technology is rapidly evolving. Overall industry capacity will increase as Amazon Leo’s services become available and as new satellites launch. Starlink has an application pending at the FCC for a new constellation of up to 30,000 satellites and advanced technology it claims can deliver gigabit throughput, further narrowing the performance gap between satellite service and fiber.⁵⁵ At the same time, the Commission has in the offing a number of other policy changes that would substantially boost the capacity and performance of LEO constellations.

Currently, while LEO satellites operate their broadband services in the wide, higher-frequency Ku and Ka bands above 10 GHz, two distinct licensing frameworks govern the much lower-band spectrum available for the sort of direct-to-device (D2D) services that can keep individuals, enterprise, and transportation connected in any location. One relies on very limited swaths of low-band spectrum allocated for mobile satellite service (MSS) to offer D2D services that connect satellites to consumer handsets (e.g., smartphones) and IoT devices for remote asset tracking, as well as for emergency communications and with moving vehicles, ships, and planes.⁵⁶ An example is Globalstar, an MSS operator that has partnered with Apple to enable new iPhones to send and receive texts from virtually any location irrespective of cellular connectivity. This has spawned a vibrant debate as interested parties like SpaceX eye the MSS bands for more D2D services.

In 2024, the Commission opened a second option for D2D services that connect individuals anywhere by adopting Supplemental Coverage from Space (SCS) rules, a licensing framework that permits satellite operators to partner with terrestrial mobile carriers and operate on a secondary basis in certain exclusively licensed cellular bands.⁵⁷ SCS is intended to promote seamless integration of satellite connectivity with consumers’ existing smartphones without modification. Outside mobile network coverage areas, or in other dead zones, SCS coverage from satellite providers can enable basic texting capacities on mobile devices. What is currently a fairly rudimentary service limited to basic texting is expected to advance over time to the quality of a 3G connection—one that would allow users in every part of the country to make calls and enable basic web browsing.

MSS and SCS spectrum serve very different needs. SCS authorizes LEO operators to complement mobile carrier services by filling gaps in terrestrial network coverage, thereby creating seamless coverage for mobile network customers using unmodified consumer handsets. D2D services relying on MSS spectrum offer the potential for ubiquitous connectivity across all dedicated connected devices, with the quality of the connectivity limited only by the amount and kind of spectrum available for the satellite operators’ use.

A perhaps underappreciated upside of SCS is that carrier spectrum, like mobile FWA, is most available where needed most: in less densely populated areas, where entire channels could potentially be set aside for SCS to enable calling (2G) or even 3G-quality web browsing (e.g., lower-bandwidth mapping apps, etc.). This is generally easier in the United States, where there are just three nationwide carriers and few borders. But even then, this coexistence is challenging and unproven so far in mobile bands that are licensed in checkerboard fashion to different carriers, making it difficult to avoid interference. This was a key reason the FCC limited the mobile bands authorized for initial SCS deployments.

One challenge in supporting the potential for D2D connectivity is how to make more MSS spectrum available, which would give LEO operators more opportunities to innovate. This could be done through opening more bands for the purpose or by introducing sharing frameworks into the existing bands. Indeed, the MSS bands were each initially allocated with shared use in mind. But over time, failures to complete buildout requirements and license surrenders caused the number of operators to dwindle into the single-occupant frameworks that exist in practice in each band today. SpaceX has been leading the charge to introduce sharing frameworks more similar to the bands’ original design.⁵⁸ The bands’ current occupants, EchoStar and Globalstar, have pushed back with the argument that harmful interference against the incumbents would be inevitable.⁵⁹ The FCC dockets hosting this debate currently lack the technical support needed for the Commission to proceed with a sharing framework. The Commission should consider options for an MSS sharing framework more directly and build a record of more technical studies and evidence of technologies that could enable effective sharing.

The Commission will also soon have opportunities to explore coexistence between MSS and FSS (fixed satellite service) in the Upper C-Band (3980⁠–⁠4200 MHz) now that Congress has required the Commission to auction at least 100 megahertz of the band, which will require consolidating and/or relocating incumbent FSS earth stations.⁶⁰ Since the spectrum is both lightly used and allocated globally for FSS, it offers a ripe opportunity to explore coexistence between MSS and FSS operators that could expand around the globe. Just as in the MSS bands, the Commission would need to gather evidence and technical justifications that coexistence is feasible, but this seems like an opportune time to build that record, since Congress has also mandated a study of certain lower-frequency federal bands (e.g., 2.7⁠–⁠2.9 GHz, 4.4⁠–⁠4.9 GHz) for potential reallocation to commercial use.

Another pending FCC proceeding—which the Commission has dubbed “Satellite Spectrum Abundance”—is considering adding 500 megahertz of spectrum to each of the primary bands that LEO satellites use to transmit broadband down to consumers and enterprise users: the Ku band (potentially adding 12.7⁠–⁠13.25 GHz) and the Ka band (potentially adding 42⁠–⁠42.5 GHz). In addition, the proceeding is exploring the allocation of 51.4⁠–⁠52.4 GHz and very high-frequency W-band spectrum (92⁠–⁠114.25 GHz), altogether investigating over 20,000 megahertz of spectrum for satellite usage.⁶¹ In mmWave bands above 24 GHz, the FCC is considering the authorization of an automated spectrum management system to streamline interference analysis and more quickly coordinate coexistence among users. The goal is to optimize efficient use of this high-band spectrum by a wide and diverse swath of users (including terrestrial mobile, fixed wireless, and fixed satellite earth stations).⁶² Such a system could be used to accommodate FSS earth station gateways and NGSO uplink operations in the 42 and 51.4 GHz bands respectively.⁶³ Database coordination could also accommodate LEO satellite earth stations in the Lower 37 GHz band (37⁠–⁠37.6 GHz), which is pending in a separate rulemaking aimed at enabling coordination among federal and nonfederal users for a diverse range of both terrestrial and satellite users.⁶⁴

In bands where GSO (geostationary orbit) and NGSO (non-geostationary orbit) satellite systems share spectrum, modern coexistence is curtailed in part by the imposition of equivalent power-flux density limits that the FCC asserts are antiquated and overprotect the higher-orbit GSO incumbents. The Commission has proposed to substantially increase power for LEO satellites, which the ITU declined to adopt at its last World Radiocommunication Conference in 2023.⁶⁵ Less restrictive limits that allow LEO operators to use more FSS spectrum at higher power levels would reduce costs and greatly increase capacity for the next generation of LEO satellites.

In short, selective changes to satellite power limits, sharing frameworks, automated database coordination (where appropriate), and the opening of more bands for satellite spectrum use could make massive headway in increasing LEO satellite’s capacity and performance, both addressing lingering connectivity gaps and adding a strong contender to the mix for intermodal competition.

Community Networks: Urban Not-Spots to Hotspots

Households in urban areas are not immune from the connectivity gaps facing rural families. The barriers these offline households face can be as basic as the lack of a robust or affordable fixed broadband connection, and their impacts are just as concrete: For example, students lacking access to reliable broadband at home can fall behind in their studies and schools with widespread connectivity gaps may struggle to provide an adequate modern education that takes advantage of digital tools. A second, underappreciated gap is mobile coverage. While the affluent may experience not-spots in urban canyons, where buildings block signals even outdoors in particular locations, low-income areas (including those in big cities) often find that mobile signals are too weak for true broadband connectivity in far more locations, especially in low-density areas. For example, the school district in Fresno, a large but overwhelmingly low-income city in California’s Central Valley, tested mobile carrier RF coverage through “drive tests” in lower-income neighborhoods, concluding that a combination of dead spots and weak mobile carrier signals could not support broadband for education where a substantial share of their students lived.⁶⁶

The solution that many communities have come up with to address both of these coverage gaps is to create their own community wireless networks and/or targeted Wi-Fi hotspot programs that provide basic internet access to those lacking it, or even as backup or on-the-go connectivity for those with access. The vast majority of community connectivity efforts leverage public infrastructure—such as city-owned streetlight poles and municipal building rooftops—to deploy Wi-Fi hotspots. Other efforts have been more ambitious. For example, the pandemic-induced school closings in 2020 motivated dozens of school districts to leverage access to free-to-use CBRS spectrum to connect students at home using “schools as towers” or to use large numbers of low-cost Wi-Fi APs mounted on streetlights and buildings.⁶⁷ In other cases, municipalities, either on their own or in partnership with local nonprofits, have deployed wireless networks in targeted areas.

In Council Bluffs, Iowa, a free community Wi-Fi mesh network has been deployed at significantly lower cost than a mobile carrier hotspot solution.⁶⁸ The city agreed to partner with the Council Bluffs Community School District to create a citywide network, called BLink, that serves both students and the rest of the population. Households outside of the reach of the network are provided hotspots. The city later extended its network to cover the neighboring Lewis Central school district and create seamless coverage for students moving between the two districts and for residents of the greater area.⁶⁹ While students get priority, a separate service set identifier (SSID) allows any resident or visitor to register for basic wireless connectivity citywide. San Jose, California, has a similar dual-purpose school and community Wi-Fi network, initiated when the East Side Union High School District floated a technology bond and later partnered with the city to provide sites and expand the network to other areas.⁷⁰

In California’s Central Valley, Lindsay Unified School District deployed a three-tiered network that combines Wi-Fi, CBRS, and Educational Broadband Service spectrum (all freely available to the district) to cover every part of the district, both within the town and in low-density rural areas outside it.⁷¹ The network evolved as part of an ambitious effort to fully implement digital learning in the school and at home, which required creating seamless coverage that allowed students to connect directly to their school’s network. At the time, only the most populous areas of the district were served by cable, and the rest were relegated to DSL. The network also provides some community access in select public places, where community members can connect through a separate portal that outlines the terms of service and provides some background on the network.

The Fresno Unified School District, noted above, went on to deploy its own network by relying on CBRS spectrum and “schools as towers”—base stations mounted on school buildings to connect students in targeted low-income neighborhoods.⁷² And in the city of Huntington Park, in Los Angeles County, a program to provide free citywide Wi-Fi using public places and municipal infrastructure (e.g., fiber owned by the Metropolitan Transportation Authority) is being rolled out in phases.⁷³

In cases where entire community networks are not feasible, rooftop Wi-Fi and hotspot lending programs can bring seamless connectivity directly to offline community members. The New York Public Library system, using antennas it mounted on local libraries in very low-income neighborhoods, piloted a hotspot lending program using CBRS that helped connect patrons living close enough to connect.⁷⁴ The program was a success, with officials reporting that they would expand it to more users if the hotspot devices were subsidized or lower-cost.

These kinds of “to and through” approaches, which extend wireless network connections by schools and libraries to bring home broadband directly to the surrounding households, have been reliably found to be a successful and achievable way of connecting communities to a ubiquitous network at lower cost than the purchase of a comparable monthly service from a commercial ISP.⁷⁵ In particular, hotspot lending programs represent an avenue to another form of convergent connectivity, enabling reliable coverage that follows a user to any relevant location, including outdoor spots without cellular coverage.