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# CBRS and Shared Spectrum Access in the US: What Connected Hardware Makers Need to Know

Citizens Broadband Radio Service (CBRS) is the most significant US spectrum policy development in a decade for hardware companies building connected products. The 150 MHz band at 3.5 GHz, managed under FCC Part 96, enables private LTE and 5G NR networks without carrier contracts — replacing Wi-Fi in industrial, campus, and IoT deployments that need coverage, mobility, or deterministic latency that Wi-Fi cannot reliably deliver. But CBRS comes with a unique regulatory architecture: every transmitting device must register with an FCC-approved Spectrum Access System, obtain FCC Part 96 equipment authorization, and in most commercial contexts, carry OnGo Alliance certification.

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At a glance

Spectrum band

3550–3700 MHz

Device categories

Cat A (30 dBm) / Cat B (47 dBm)

SAS requirement

Mandatory for all CBSDs

Alliance certification

OnGo (commercial standard)

## CBRS regulatory architecture and device requirements

### Three-tier CBRS hierarchy: Incumbent, PAL, and GAA

CBRS spectrum (3550–3700 MHz) operates under a three-tier shared access model established by FCC in 47 CFR Part 96. Tier 1 Incumbents — primarily US Navy radar systems and Fixed Satellite Service operators — have absolute protection and cannot be interfered with. Tier 2 Priority Access License (PAL) holders won spectrum rights in FCC Auction 105 (2020), which raised $4.6 billion across 22,631 licenses in 74 MHz channels. PALs run 10-year terms (with 7-year renewal expectation). Tier 3 General Authorized Access (GAA) is available to all certified CBRS devices without a license fee, subject to preemption by PALs and Incumbents — functioning similarly to unlicensed spectrum but with SAS coordination.

### Spectrum Access System (SAS) — the automated frequency coordinator

Every CBRS device (CBSD — Citizens Broadband Radio Service Device) must register with an FCC-approved SAS and operate only on frequencies and at power levels granted by the SAS. The SAS continuously coordinates spectrum across all registered CBSDs, enforces PAL exclusion zones, and manages Incumbent protection. FCC has approved multiple SAS administrators including Google (SAS Portal), CommScope (Amdocs), and Federated Wireless. CBSDs must maintain a live connection to the SAS — if the SAS grant expires or is suspended, the CBSD must cease transmission. This is a fundamentally different authorization model from traditional licensed or unlicensed spectrum.

### Environmental Sensing Capability (ESC) — protecting Navy radar

Along the US East Coast and Gulf Coast, CBRS devices in the 3550–3650 MHz band must also coordinate with ESC sensors that detect active Navy radar use. ESC operators (approved by FCC) deploy sensor networks that monitor for radar emissions and signal the SAS to suspend CBSD operations when Navy radar is active in the area. Category B CBSDs (outdoor, higher power) require ESC protection in coastal zones. Category A CBSDs (indoor, lower power) operating below 3650 MHz in coastal areas also interact with ESC through the SAS. Hardware companies deploying CBRS equipment near coastlines must account for spectrum grant suspension windows in system design.

### Device categories: Category A vs Category B power limits

FCC Part 96 defines two CBSD categories based on deployment scenario. Category A: indoor or low-power outdoor, maximum EIRP of 30 dBm (1 watt), maximum antenna height 6 meters above ground for outdoor deployments. Category B: higher-power outdoor, maximum EIRP of 47 dBm (50 watts), used for macro-cell deployments, requires professional installation certification. End-user devices (CPE — Customer Premises Equipment) connecting to CBSDs are defined separately and have their own power limits (23 dBm maximum EIRP for UE-class devices). Category selection affects SAS registration parameters and ESC interaction requirements.

### OnGo Alliance (CBRS Alliance) certification requirement

In addition to FCC Part 96 equipment authorization (required by regulation), the CBRS Alliance — now rebranded as the OnGo Alliance — operates an industry certification program for interoperability and performance. OnGo certification validates that a CBSD correctly implements the SAS interface protocol (WINNF-TS-0016), LTE/5G NR radio performance, and coexistence behavior. Most enterprise CBRS deployments and network operators require OnGo certification as a procurement prerequisite even where it isn't legally mandated. The certification test suite is administered by CBRS Alliance-approved test labs including UL, Dekra, and Sporton.

### Private LTE/5G and IoT use cases for hardware companies

CBRS enables hardware companies to build products for private network deployments without carrier involvement. Key use cases: industrial IoT with deterministic latency on a dedicated private network, campus connectivity for hospitals, warehouses, and manufacturing facilities, in-building neutral host networks, and fixed wireless access in rural or underserved areas. For product companies, CBRS opens a market segment where the customer controls the spectrum (via PAL or GAA) and the hardware company provides the radio infrastructure. Products targeting this market need FCC Part 96 authorization, OnGo certification, and SAS client software — typically provided by integrating an existing SAS SDK.

## CBRS device authorization and deployment process

01

Determine if CBRS fits the target use case. CBRS is well-suited for private LTE/5G networks in controlled geographic areas, campus IoT, and deployments requiring more control than Wi-Fi but without a carrier relationship. It is not appropriate for nationwide roaming products or devices that need seamless handoff across operator networks.

02

Select the device category based on deployment scenario. Category A for indoor deployments or low-power outdoor (≤30 dBm EIRP, ≤6m antenna height). Category B for outdoor macro-cell deployments requiring higher power (≤47 dBm EIRP). Category selection is locked at the device design level and affects antenna, PA, and firmware architecture.

03

Obtain FCC Part 96 equipment authorization. CBRS devices require FCC authorization under Part 96 (in addition to any applicable Part 15 authorization for other radio functions). Authorization requires testing by an FCC-recognized Telecommunication Certification Body (TCB). Part 96 testing validates radio frequency parameters, power limits, SAS interface compliance, and coexistence behavior per FCC KDB publication 413420.

04

Pursue OnGo CBRS Alliance certification. Engage an approved OnGo test lab. The certification covers SAS interface protocol compliance (WINNF-TS-0016), radio performance, and multi-vendor interoperability. OnGo certification is technically voluntary but commercially required for enterprise market access. Budget 4–8 weeks for testing and a further 2–4 weeks for certification issuance.

05

Integrate SAS client software into the device firmware. Every CBSD must implement the SAS-CBSD interface per WINNF-TS-0016 (JSON over HTTPS). The device registers with a chosen SAS, requests a spectrum grant, receives channel and power parameters, and sends heartbeats to maintain the grant. FCC-approved SAS operators provide SDKs and sandbox environments for development and testing. The SAS communication stack is typically implemented at the small cell or radio unit firmware level.

06

Register the CBSD with an FCC-approved SAS for production deployments. Production SAS registration requires the device FCC ID, serial number, geographic coordinates, antenna height, and category. For Category B outdoor CBSDs in coastal zones, ESC coordination is automatically managed by the SAS. Maintain accurate registration data — incorrect location or antenna height parameters can cause SAS grant failures or interference.

07

Monitor SAS grants and build spectrum reclamation handling into the system design. SAS grants expire and must be renewed via heartbeat. Grants can be suspended by the SAS in response to Incumbent radar detection or PAL priority enforcement. The device must be designed to cease transmission within 60 seconds of a SAS suspension notice. For IoT deployments, this means building in spectrum-reclamation fallback behavior — either silence, frequency reuse on a new grant, or handoff to a backup connectivity path.

## Frequently asked questions

### Do CBRS devices require FCC authorization beyond Part 96?

Yes, in most cases. A CBSD that also contains Wi-Fi, Bluetooth, or other radio functions will require Part 15 authorization for those components in addition to Part 96 authorization for the CBRS radio. If the device is also subject to Part 22, Part 24, or Part 27 for other spectrum bands (e.g., a multi-band radio), those authorizations apply separately. FCC equipment authorization for CBRS (Part 96) must be obtained through an FCC-recognized TCB and cannot be self-declared — CBRS is not a Part 15 SDoC (Supplier's Declaration of Conformity) eligible technology.

### What's the difference between a PAL and GAA device in CBRS?

PAL and GAA are spectrum access tiers, not device types. Any FCC Part 96 authorized CBSD can operate in either PAL or GAA mode — it's determined by the SAS grant, not the hardware. A PAL holder registers their license in the SAS, which then preferentially assigns channels within the PAL holder's licensed block to their registered CBSDs. GAA devices receive grants on whatever spectrum the SAS determines is available after PAL and Incumbent protection. In practice, GAA works well in most geographic areas because PAL licenses are concentrated in high-demand urban markets, leaving significant GAA spectrum available in suburban and rural deployments.

### Does a hardware manufacturer need to deal with the SAS directly?

Hardware manufacturers building CBSDs must implement the SAS interface in their firmware — the SAS client is embedded in the device. However, the commercial SAS operator relationship is typically established by the network operator or enterprise customer deploying the CBSD, not the hardware manufacturer. The manufacturer's obligations are: implement the WINNF-TS-0016 SAS interface correctly, obtain FCC Part 96 authorization, and (commercially) obtain OnGo certification. The deploying entity registers the specific CBSDs (by serial number and FCC ID) with their chosen SAS and manages the operational SAS relationship.

### How does CBRS compare to private 5G using licensed mmWave spectrum?

CBRS (3.5 GHz) and licensed mmWave spectrum (24 GHz+) serve different deployment scenarios. CBRS provides broader coverage per radio (indoor penetration, hundreds of meters per CBSD), works with existing Cat-M/NB-IoT and LTE device chipsets, and is available without spectrum license acquisition cost for GAA use. mmWave spectrum provides gigabit-class throughput at very short range (tens of meters), requires line-of-sight or near-LOS, and requires purchasing spectrum at FCC auction or from a licensee. For most industrial IoT, campus, and enterprise private network use cases, CBRS 3.5 GHz is more practical. mmWave suits fixed point-to-point backhaul, stadium dense deployments, and applications needing multi-gigabit throughput in controlled environments.

**Disclaimer:** Educational resource only. Regulatory requirements change frequently. Consult a licensed US customs broker, trade attorney, or compliance specialist before making decisions.

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