T-Mobile USA lent its voice to the debate over the FCC's planned incentive auctions for repurposed broadcast television spectrum, outlining a proposed band plan, lobbying for 600 MHz interoperability and pushing for spectrum caps on frequencies below 1 GHz.
T-Mobile supports much of the FCC's plan to reallocate and reassign 600 MHz spectrum from broadcast TV to mobile broadband use but is suggesting a number of tweaks, wrote Kathleen Ham, T-Mobile's vice president of federal regulatory affairs, in a blog post on the company website.
A group of wireless carriers, broadcasters and manufacturers recently suggested locating all paired spectrum above TV Channel 37. "While we are open to further study with the FCC on the best plan to maximize paired spectrum in the auction, this approach has the benefit of avoiding certain potential interference issues that exist with the FCC's lead plan and would encourage rapid development of devices that meet consumer expectations for cost and size," said Ham.
The FCC voted in late September to begin setting rules that will govern voluntary incentive auctions of broadcast TV spectrum for mobile broadband use, with auctions envisioned to begin in 2014. The agency anticipates creating 6 MHz guard bands to separate spectrum blocks used by carriers and opening up vacant "white space" between the blocks for unlicensed use.
Ham was part of a contingent of T-Mobile representatives who met with numerous FCC officials on Jan. 30 to plead the operator's case for a revised band plan. That plan would create 35 x 35 MHz of paired spectrum and seven paired 5 MHz blocks, limiting what the company contends are wasteful guard bands and creating "meaningful opportunities for competition." The plan would accommodate a supplemental downlink when more than 84 MHz (14 TV channels) is cleared.
The operator is also lobbying the FCC to require interoperability across the entire 600 MHz band. T-Mobile contends that mandating interoperability from the start of the auction would provide clarity to potential licensees and minimize costs.
Interoperability has become a sticking point for smaller operators with 700 MHz spectrum that is incompatible with the 700 MHz band classes held by market leaders AT&T (NYSE:T) and Verizon Wireless (NYSE:VZ). Those smaller operators have found it difficult to procure mobile devices that will work on their frequencies because vendors do not see sufficient volumes. For nearly a year, the FCC has been exploring whether to require 700 MHz interoperability, which would require carriers to sell handsets that support multiple 700 MHz bands, not just the bands in which they own licenses.
Along with mandated 600 MHz interoperability, T-Mobile wants the commission to offer what it terms generic, fungible spectrum licenses that are not frequency-specific within each geographic area. In addition, the licenses should be separated by major economic areas rather than the smaller economic areas because most carriers need larger license areas to provide competitive wireless broadband service, said the operator in its FCC presentation.
In addition, T-Mobile is pushing for spectrum caps to prevent further consolidation of spectrum below 1 GHz. "The commission should adopt rules that prohibit any licensee from acquiring more than a certain percentage of spectrum below 1 GHz, applied on a market-by-market basis," wrote Ham.
"Adopting a spectrum-based cap equal to one-third of the available commercial mobile spectrum below 1 GHz would give bidders reasonable assurances that they can meaningfully compete for spectrum in a geographic area without the risk of only one or two of the largest carriers commandeering the entire market," she said.
In its FCC presentation, T-Mobile displayed a graph showing that AT&T and Verizon Wireless together currently hold in excess of 100 MHz of lower-band spectrum averaged across the top 100 markets, while all other carriers combined hold barely over 20 MHz.
Since September 2012, the FCC has been considering changes to its so-called spectrum-screen, which it uses when reviewing spectrum transactions. Not surprisingly, AT&T and Verizon have argued against rules that would reduce how much spectrum carriers can hold in certain markets, while smaller carriers are pushing for proposals that would limit the spectrum holdings of the nation's two largest carriers.
Verizon, AT&T clash with Sprint and others over spectrum caps
Broadcasters form coalition to support FCC's incentive spectrum auctions
Execs: 700 MHz interoperability will unleash investment, jobs
FCC's Genachowski: We're on track to free up 300 MHz of spectrum by 2015
FCC gives details for 2014 auction of broadcast spectrum for mobile broadband
AT&T to rural carriers: Seek LTE interoperability with Sprint, T-Mobile
FCC to set rules for spectrum auctions that could occur in 2014