It took a month but Digital Tech Consulting is disputing T-Mobile’s February 17, claim to the FCC that DTC’s study of the agency’s upcoming spectrum incentive auction and the challenges for the TV and tower industries “reflects a number of flawed assumptions and conclusions,” as the carrier claimed. In a March 17, letter to the FCC, DTC President Myra Moore said, “First: T-Mobile erroneously assumes that antennas identified as ’broadband’ are capable of transmitting on all contiguous channels within all or a portion of the UHF band without modification. This is inaccurate, and reflects T-Mobile’s failure to research the capabilities of these antennas. In fact, most of these antennas will need significant alterations, which cannot be performed while the antennas remain on towers, to operate on new channels. As a result, T-Mobile meaningfully underestimates the scope of antenna removal and installation work the transition will require.”
“Second, T-Mobile overstates the availability of critical resources, including tower crews with the equipment and experience qualifying them to perform broadcast antenna installation and removal work. T-Mobile claims to have identified 41 qualified tower crews capable of performing this work. In fact, based on our interviews with the additional companies T-Mobile identified, some of these companies have not performed broadcast work in more than a decade, some lack necessary specialized rigging equipment, and some specialize in radio, microwave and cellular antenna installations. Many broadcasters have never heard of some of these additional companies, and will not trust them to perform hazardous work on their critical facilities.
“Third, T-Mobile asserts that DTC understated the capacity of antenna manufacturers to meet a surge in demand for broadcast television antennas. In fact, only two manufacturers supply antennas to 89 percent of the full-power television market. These manufacturers confirm that typical lead times will range from 12 to 24 weeks for design, modeling, manufacturing and testing of antennas, that lead times are likely to lengthen when a large number of orders are placed simultaneously, and that they are unlikely to significantly increase capacity until they have a sufficient number of orders in hand to warrant expansion.”
Moore, who said T-Mobile failed to explain how the transition could be conducted inside the proposed 39-month window, attached an expanded, greater detailed response with her two-page letter. She ended her March 17, letter noting T-Mobile’s 410-page report contained “numerous other errors and inaccurate assumptions.”
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