Policies to Promote Convergent Connectivity

As we stated at the outset, while a limited form of competitive convergence is being achieved in the marketplace, a broader and more ambitious convergence should now move to the forefront. Both industry and government should promote policies that integrate wireless communication technologies and networks (mobile, fixed, satellite) to create ubiquitous, seamless, and interoperable networks that allow users to access and transition among the best available connections anywhere and everywhere. Convergent connectivity should aim to bridge the gaps between diverse networks and platforms, enabling real-time communication and data sharing across multiple devices, networks, and locations. Convergent connectivity should also ensure information and services are accessible to everyone, everywhere, fostering inclusivity. The following are a few general suggestions on policy directions in pursuit of these goals:

Spectrum policy is central to convergent connectivity. A balanced spectrum policy that unleashes wide bands of quality spectrum for unlicensed, exclusively licensed, and lightly-licensed shared use has proven in recent years to be the most effective means to promote all of the converging modes of wireless communication, as well as to promote innovation, competition and consumer choice.¹

As noted above, the emerging reciprocal competition between mobile and cable providers sprang directly from FCC decisions in 2020 to “go big” in allocating wide contiguous new bands of spectrum: 1,200 megahertz of unlicensed spectrum for Wi-Fi in the 6 GHz band and, for mobile carriers, 380 megahertz of prime 3 GHz spectrum for exclusive use (3700⁠–⁠3980 MHz, 345⁠–⁠3550 MHz). An earlier (2015) decision to allocate 150 megahertz of 3 GHz spectrum for lower-power access using a lightly-licensed, three-tier sharing framework has fueled innovation in private networks, among them neutral host networks that enable cellular coverage indoors. And currently, the FCC is considering enormous new allocations of spectrum, in a rulemaking literally captioned “In the Matter of Satellite Spectrum Abundance,” to enable market entry and capacity growth among current and aspiring LEO satellite operators. The direct linkages between these very consequential proceedings and the trend toward converging connectivity are clearly evident; yet, as Congress demonstrated in its July 2025 spectrum bill, it takes planning and strong leadership to maintain a balance between these competing demands for limited spectrum resources.

One specific initiative that could help would be an inventory of actual spectrum use in prime low to upper-mid bands. While tables of allocations and databases documenting assignments are available, regulators are mostly flying blind with respect to the degree to which each band of spectrum is actually in use (or not), including where, when, at what power levels and for what purposes. While the NTIA and FCC have made enormous progress in recent years identifying both federal bands (e.g., 3.5 GHz) and commercial bands (e.g., C-band) with enormous unused capacity, identifying these opportunities and knowing what sharing mechanisms are feasible or optimal is a challenge that will increasingly benefit from a more current and granular understanding of how intensively prime spectrum is actually being used (and how not) in general and in different geographies.²

Policymakers and industry stakeholders need far greater visibility into the reality of what mobile network “coverage” exists in relation to different physical environments and geographies, both indoors and outdoors. Currently, the FCC compiles and reports maps of mobile network coverage that tell us little to nothing about the level of service supported in a particular area. As mentioned earlier, drive testing (such as by the Fresno public schools during the pandemic) often reports signals that cannot support more than basic 3G-era connectivity, particularly indoors. The UK’s regulator, Ofcom, measures and maps mobile signal strength data—a first step that the FCC should pilot for the United States. Since 2021, Ofcom has been “compiling the 4G- and 5G-specific signal strength measurement data that our spectrum assurance vehicles capture along roads across the United Kingdom….Alongside the data, we have published a map showing the routes our vehicles have taken—in other words, the locations for which data is available.”³

As described above in the section on indoor/outdoor seamless connectivity, despite the growing importance of integrating connectivity for Wi-Fi (indoors) with cellular (outdoors), none of the industry stakeholders are making it a priority, nor do they seem willing to give ground on their own standards or control over data traffic management. Although 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, among others, 3GPP, Wi-Fi Alliance, and leading device and chipmakers) that would be necessary. Stakeholders tell us a solution is less of a technical challenge than it is a multifaceted collective action and competition problem.

While a technology-based FCC regulation would have little support and quite possibly be counterproductive, the agency should consider options to nudge the mobile and Wi-Fi industries, as well as leading smartphone OEMs, to make seamless handoffs between cellular, Wi-Fi, and satellite networks more of a priority. For example, as it did to develop dynamic spectrum sharing in the CBRS band, the Commission could designate a multi-stakeholder group to study and report back on options and obstacles. That process, with FCC guidance, could consider whether there are incentives—or requirements—that could align interests across the different types of networks. Cellular network coverage has long been encouraged with buildout requirements that are tied to licenses and factored into the bidding at auctions. Are there similar carrots, or sticks, that could promote progress on this front? At a minimum, the Commission should include seamless connectivity as a topic for notice, comment, and analysis as part of its biennial Communications Marketplace Report to Congress. Consumers have made their preferences clear. Making it open and discoverable which operators offer frictionless connectivity, and to what degree, and which do not, will help the public make informed purchases and stir competition among companies that otherwise might not be seriously invested in exploring its potential.

Wireless networks and open Wi-Fi hotspots sponsored by municipalities, schools, libraries, cooperatives, nonprofits, and a host of other institutions could, as described earlier, do far more to address two different aspects of the ubiquitous coverage challenge. First, they can provide basic connectivity to those lacking internet access at home or while on the go. Second, they can provide backup connectivity in urban not-spots, or in exurban or rural areas, where cellular signals are blocked or too weak to support the sort of robust connection needed for 5G (and someday 6G) applications. In addition, these community networking and targeted Wi-Fi hotspot initiatives often do so today in a very cost-effective fashion by leveraging public infrastructure, from free-to-use bands of spectrum (unlicensed, CBRS) to the assets owned by local public institutions (streetlight poles, public buildings, local public fiber rings).

Too often these networks are viewed with suspicion, or even hostility, sometimes under the misapprehension that they somehow compete with commercial ISPs. That is rarely the case. For example, as described above, the K-12 students in Lindsay, California—a very low-income farmworker community—use the Lindsay school district network (which leverages both Wi-Fi and private LTE operating on CBRS spectrum) only because they lack good connectivity at home. And in Council Bluffs, Iowa, where the municipality and school district partnered to cover almost the entire city with Wi-Fi, nonstudent residents use a separate SSID to access to relatively low-bandwidth service, one that at least allows them (and even visitors) to have basic connectivity on any device in almost any location. Public Wi-Fi networks targeted as amenities in parks, beaches, shopping districts, transit networks, and low-income neighborhoods should also be viewed and supported as an additional layer of connectivity which—along with mobile, satellite and fixed/Wi-Fi networks—facilitate ubiquitous and seamless connectivity as essential to a robust, future-proof wireless ecosystem.