The Wireless industry told the FCC late Thursday that innovation is flourishing across the wireless "ecosystem" but that the "virtuous cycle" of investment and innovation has outgrown its plot of spectrum.
It has asked the government to look hard at its own spectrum holdings, as well as those of broadcasters and satellite operators.
In reply comments in the FCC's inquiry into the state of wireless innovation, CTIA: The Wireless Association said it needed at least 800 mHz more spectrum below 3 GHz within the next six years.
It says in the near-term, the government should give up some of its spectrum.
"We urge the commission to take a hard look at the spectrum use of the U.S. broadcast industry," it said, labeling broadcasters "highly inefficient" and echoing the FCC's labeling of broadcasters' spectrum holdings as beachfront property" for mobile broadband.
"If the public interest in providing over-the-air television to the fraction of U.S. households without cable or satellite television has not already been overtaken by technological changes, it is rapidly becoming so," it said.
Broadcasters counter that the government has just spent over a billion and a half dollars making sure that fraction can still get over-the-air service, as well as requiring the move to digital broadcasting, which opens up that beachfront property for new over-the-air establishments like HD and mobile TV.
CTIA also asks the FCC to at least check out satellite operators' spectrum allocations to assess whether they are "fully and efficiently utilizing their spectrum."