T-Mobile says it is doing its best to fill gaps in coverage by buying or trading spectrum in the secondary market, but that that, by itself, is not a successful game plan for the future.
In testimony for Tuesday's (July 23) incentive auction hearing in the House Communications Subcommittee, T-Mobile VP, regulatory affairs, Kathleen O'Brien Ham, said that the FCC's auction structure should meet three main objectives: 1) encourage widespread broadcasters participation; 2) maximize the paired spectrum freed up for wireless; and 3) put reasonable limits on spectrum aggregation to make sure that AT&T and Verizon don't foreclose competition.
Making the auction more attractive to broadcasters means starting with high opening prices, says T-Mobile, combined with bidding options for broadcasters -- giving up spectrum, sharing, moving to a lower band (UHF is wireless beachfront property, just as it now is for broadcasting).
T-Mobile says the FCC should outline clear rules for repacking stations and reimbursing moving costs. That includes requiring stations to provide an inventory of equipment and facilities and cost estimates, as well as setting "firm" milestones for broadcasters to satisfy before collecting those payments.
T-Mobile has proposed what it says is a reasonable limit allowing a carrier to have no more than one-third of the spectrum below 1 GHz in any market. Without that, it says, the two dominant carriers -- AT&T and Verizon -- "could squeeze out competitors, reducing consumer choice and thwarting the type of innovation that T-Mobile and smaller carriers are introducing to the wireless marketplace today."
To address concerns that any bidders would be excluded, T-Mobile has proposed a Dynamic Market Rule in which the one-third limit would be loosened, and eventually removed entirely, if the FCC's revenue target was not met.