T-Mobile: 7 Reasons Spectrum Auction Deadline Works

Telco also tells FCC $1.75 billion should cover it
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T-Mobile told the FCC this week that it should be able to complete the post-broadcast incentive auction repack in the 39 months the FCC has allotted and under—though not much—the $1.75 billion cap on repack relocation expenses.

T-Mobile plans to bid in the auction, so it is looking to get access to that spectrum as soon as possible after the auction. Wireless companies as a group have, understandably, urged the FCC to keep to the 39-month timetable for the spectrum handoff to winning wireless spectrum bidders.

The National Association of Broadcasters has used a study by Digital Tech Consulting (DTC) to argue that the 39-month timetable may need to be pushed and the $1.75 billion likely won't be enough. It says the FCC should not set a hard deadline before it knows how many stations will need to be moved, which won't be known until after the reverse auction.

Submitting its own study to the FCC this week, T-Mobile begged to differ, saying the NAB report was flawed "because it overstated demand and understated supply."

T-Mobile said its study was conducted in partnership with Jack Boone of Broadcast Tower Technologies, Inc. (BTTi) and William Hammett and Rajat Mathur of Hammett & Edison (H&E), and was based on "detailed station records for every television license in the country," as well as FCC auction simulations, "phone interviews with broadcast construction industry professionals, research of publicly available sources and BTTi’s and H&E’s decades experience and expertise in broadcast engineering..."

The telco said the collective conclusion they came to was that the supply of "transition resources"—tower crews, equipment—was sufficient to meet the demands of "every broadcast television station in the United States that will need equipment and services to relocate following the incentive auction."

T-Mobile outlined seven reasons it has concluded the repack of TV stations after the forward auction can be done on time and at, or under, budget.

1. "Not All Stations Will Need New Antennas. Broadcasters will not need new antennas in many circumstances because they often share antennas, and some antennas can be used on multiple channels.

2. "Not All Towers Will Require Modifications. Using the FCC’s conservative 2014 repacking simulations, we found that, on average, only 845 unique antenna structures will be involved in the repacking process. This estimate is lower than DTC’s finding because it takes into account the number of antennas that will not need to be replaced.

3. "Television Antenna Supply Will Be Sufficient. Contrary to DTC’s assertions, more than two manufacturers are capable of providing and, in fact, do provide antennas to broadcast stations.

4. "Ample Radiofrequency ('RF') Consulting Engineers Are Available. We have identified 18 additional RF consulting engineers than DTC included in its analysis. An accurate tally of RF consulting engineers demonstrates sufficient capacity to assist with between 370 and 475 construction permit applications per month.

5. "More Than Enough Tower Structural Engineers Are Available to Meet Anticipated Demand. We have identified 19 structural engineering firms capable of conducting work on tall towers, which we define as towers more than 1,000 feet tall (305 meters).

6. "At Least 41 Tower Crews Are Available Today to Work on Tall Towers. We identified 41 tower crews [DTC had said 16] operating today that are capable of working on 1,000 feet tall towers. Even if one were to accept DTC’s assumption that one crew can complete only eight or nine antenna change projects per year and its assumption that these projects could not begin until six months into the repacking process, today’s workforce could complete at least 900 station relocations during the remaining 33 months of the transition.

7. "The Repacking Process Will Likely Cost Less than $1.75 Billion...DTC’s estimate that the cost of the repack could exceed $2.9 billion is overstated. Simply using a realistic number of stations that require repacking and identifying cost estimates based on broadcasters’ actual equipment would yield cost savings of as much as $1 billion or more. [It would need the 'or more' since that only takes it down to $1.9 billion]. Additional savings are possible and provide us with confidence that the congressionally mandated budget of $1.75 billion is realistic, if not generous, for the actual task at hand."

The incentive auction begins March 29, but that is simply the date by which broadcasters have to declare they are bidding and what options they will accept—giving up spectrum and getting out of the business, giving up spectrum and sharing channels, or moving to a different channel if that is an option.

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