In a petition filed with the FCC on Monday, T-Mobile US asked the agency to reconsider rules for upcoming incentive auctions of 600 MHz broadcast television spectrum that would reserve a maximum of 30 MHz per market for smaller carriers that compete against market leaders Verizon Wireless and AT&T. As it argued that the spectrum reserve adopted in May is “inadequate,” T-Mobile advised the FCC that the 30 MHz spectrum set-aside fails to “meaningfully advance the .. . goal of ensuring four robustly competitive national carriers” as articulated by FCC Chairman Tom Wheeler in recent remarks to the press.

The incentive auction plan approved by the FCC reserves up to 30 MHz per market in 10 MHz blocks for bids by competitive carriers during the forward auction, depending upon how much spectrum is surrendered in each area by broadcasters during the “reverse” auction process. That plan assumes an allocation of 70 MHz per market which leaves 40 MHz available for bids by Verizon and AT&T. In markets where broadcasters surrender 60 MHz of spectrum, the reserve provides just 20 MHz of spectrum for competitive carriers and as little as 10 MHz in markets where 50 MHz of broadcast spectrum is surrendered.

Maintaining that the FCC’s goal of preserving “four robust nationwide competitors requires that all four carriers have access to sufficient low band (below 1 GHz) spectrum necessary to compete,” T-Mobile complained that, as the reserve is currently structured, either T-Mobile or Sprint but not both carriers would be able to secure the 20 MHz of low band spectrum per market that the FCC claims is required for viable broadband deployment. As such, T-Mobile recommended that the FCC rework its rules to reserve half of the 600 MHz spectrum assets that are recovered from the broadcast industry for competitive carriers. Characterizing her company’s concerns as “limited and narrowly tailored,” T-Mobile Vice President Kathleen Ham wrote in a blog post: “we want the FCC to do. . . the right thing by making the spectrum reserve and its trigger meaningful enough to make sure the intended result of a more competitive wireless broadband market is achieved.”