Make no mistake: T-Mobile does not like the proposal put forth by AT&T (NYSE: T) and EchoStar that would give primary status to satellite earth stations operating in the 28 GHz band as part of the rules for spectrum bands above 24 GHz.
"T-Mobile strongly opposes the AT&T/EchoStar formulation, which elevates satellite use to primary status in the 28 GHz band, unnecessarily constrains deployment of 5G services and threatens the success of terrestrial mobile broadband use of the spectrum," writes T-Mobile VP of Government Affairs, Technology and Engineering Policy Steve Sharkey in an ex parte filing with the FCC.
Instead, T-Mobile says the FCC should permit additional satellite earth station use of the 28 GHz band in non-urban areas only on a secondary basis, using the technical parameters developed by wireless industry representatives as part of a Technical Working Group, which includes T-Mobile USA, Verizon (NYSE: VZ), Nokia (NYSE:NOK), Samsung Electronics America -- and somewhat oddly in this situation, AT&T Services.
Besides granting co-primary status to satellite operations in massive swaths of areas with high population density, "the AT&T/EchoStar proposal fails to meaningfully address the technical parameters that would govern any satellite earth station operations in the 28 GHz band – surprising, because AT&T is a member of the Technical Working Group," Sharkey wrote. "Any proposal for use of the band for satellite operations is incomplete without an understanding of the operational parameters under which those stations would be required to operate."
T-Mobile argues that satellite operators should have no primary rights to use the 28 GHz band, whether inside or outside the urban core, unless they obtain those rights through auction or the secondary market. Satellite operators have never had rights to use the spectrum on a primary basis and could not have had a reasonable expectation that they would secure those rights in the future. "They merely seek to take advantage of a regulatory opportunity to expand the properly limited rights they have today," Sharkey said.
Even worse, according to T-Mobile, elevating satellite use to primary status under the AT&T/EchoStar proposal will defeat the purpose of the type of geographic licensing that the commission traditionally adopted for commercial wireless services and which it has proposed for millimeter wave band use.
T-Mobile supports a different proposal – one put forth by CTIA – that would allow existing satellite licensees, wherever located, "operation rights" on a secondary basis. It also supports the idea of permitting, for future operations, satellite earth stations on a secondary basis outside the top 150 cellular market areas (CMAs) identified by CTIA, subject to coordination requirements that continue to be developed. Inside the top 150 CMAs, no new facilities would be permitted unless the satellite operator secured rights to operate on a primary basis.
- see this T-Mobile filing
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