T-Mobile doubles down on its proposal for 3.7-4.2 GHz band

T-Mobile
T-Mobile says the 36-month relocation period proposed by the C-Band Alliance would be comparable to the relocation period after an incentive auction. (FierceWireless)

Less than a week after the C-Band Alliance (CBA) said T-Mobile’s proposal amounts to a delay tactic, T-Mobile was meeting with FCC officials to double down on efforts to evangelize its proposal on how to handle the 3.7-4.2 GHz, or C-band.

T-Mobile says its proposal provides several benefits, such as maximizing the amount of spectrum that would be made available for terrestrial services; ensuring the continued delivery of programming and other content; and allocating at least some portion of auction proceeds to taxpayers and possibly some to satellite operators and satellite earth station users.

But the “uncarrier” also asserts that the C-Band Alliance’s claim that its plan will make spectrum available more quickly—a key selling point in the grand scheme of things—is “illusory.” Details that need to be worked out will take the same amount of time regardless of the process, and the 36-month relocation period proposed by CBA would be comparable to the relocation period after an incentive auction, according to T-Mobile (PDF).

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The terrestrial wireless industry has identified midband spectrum as pivotal in its ability to win the race to 5G; other nations have 3.5 GHz and other midband spectrum already allocated. The U.S. has 3.5 GHz as well, but it’s part of a complicated sharing regime and there’s not been an auction scheduled for the licensed part of the band. The 3.7-4.2 GHz offers 500 megahertz, but it’s being used by satellite companies to supply clients like CBS, NPR and C-SPAN with content distribution services.

The C-Band Alliance has proposed making up to 200 megahertz available through a secondary market process where satellite companies would be reimbursed, and one of the big selling points is the spectrum could be made available faster—no lengthy government involvement or court challenges. The down side for the terrestrial wireless industry is 200 megahertz is not deemed enough to make it worthwhile for 5G.

T-Mobile is saying that even if a commission-led auction takes slightly longer, the results will serve the public interest significantly better. And, it argues, its proposal would make at least 300 megahertz of spectrum available in most markets, plus there is wide support for making 100 megahertz per provider available.

RELATED: CCA: Any less than 320 MHz of C-band spectrum would be missed opportunity for 5G

It would appear that T-Mobile has an ally in a commenter who's been following the C-band proceedings for the past year and has reviewed every filing. Paul Litchfield, who identifies himself as an investment professional, submitted comments to the FCC summarizing his take on four distinct areas: amount of repurposed spectrum; time to repurpose spectrum; cost to repurpose spectrum; and protection of current users. Of the four, the amount of spectrum that will be repurposed should be thought of as the most important, he said, reasoning that a faster process might save a few months to a few years, but the amount of spectrum repurposed will affect the U.S. for a decade or more.

However, he added that T-Mobile’s proposal integrates too much of the CBA proposal, with all its inherent flaws, to be looked at favorably in its own right, and it ends up being an overly complex and time-consuming process. The only option left is for the FCC to go with a traditional clearing and auction process, he said, noting there’s the additional possibility of incorporating some aspects of Google’s overlay proposal that could greatly accelerate the clearing side of the traditional FCC-run process.

RELATED: C-Band Alliance calls T-Mobile proposal for 3.7-4.2 GHz a delay tactic

In its Dec. 7 filing (PDF), the C-Band Alliance said T-Mobile’s “convoluted proposal” would produce years of regulatory and legal challenges and only serve to delay the availability of C-band spectrum for use by its competitors. It made a similar comment about Comcast, saying both entities support regulatory action that would delay increased 5G deployment and stifle competitive forces affecting their businesses.

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