If it wasn’t clear before, it is now: Wireless operators want to get their hands on more millimeter wave spectrum, and the more, the merrier. And smaller carriers are worried the deck is going to get stacked against them in favor of the largest operators.

Those themes continue to emerge through comments filed with the FCC as part of its Spectrum Frontiers initiative. The FCC has asked for input on how it should structure spectrum bands above 24 GHz for mobile radio services, and carriers aren’t shy about responding. AT&T, Verizon and T-Mobile, plus the industry association CTIA, are pushing for an auction in 2018, with T-Mobile in particular pointing to Verizon’s accumulation of millimeter wave spectrum on the secondary market giving it a competitive edge.

Most carriers want to see prompt auction procedures and actual auctions take place this year, although FCC Chairman Ajit Pai has stated that details related to upfront payments need to be worked out before the FCC can launch another large spectrum auction like the one it did last year.

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Although it’s not the only spectrum to be used for 5G, millimeter wave spectrum will play a vital role in the next-generation technology, and operators are already using some mmWave bands in their tests and trials. The 28 GHz and 39 GHz bands are popular in the U.S., but several other bands are being considered in the FCC’s proceeding.

CTIA is urging (PDF) the FCC to promptly seek comment on auction procedures to allow the rapid auction of the 24 GHz, 28 GHz, 37/39 GHz and 47 GHz bands, and it’s proposing that the 26 GHz band be allocated for flexible, exclusive use licensing. It also urges the commission to prioritize the licensing of additional spectrum for exclusively licensed terrestrial flexible use.

AT&T told (PDF) the commission that it should prioritize the auction of the 28 GHz, 37 GHz and 39 GHz bands, and, to the extent additional bands can be auctioned concurrently, the FCC should do so, but it shouldn’t delay the auction of the initial spectrum bands that have been laying in inventory for several years. AT&T also urged the commission to advance efforts to develop sharing rules and protocols for the 37-37.6 GHz band.

T-Mobile also wants the FCC to “immediately initiate” the process for conducting an auction of the bands previously allocated in the proceeding—24 GHz, 28 GHz, 37 GHz, 39 GHz and 48 GHz—and begin a combined auction for those bands in 2018.

However, it also makes a point to say that an auction should happen in 2018 because delaying an auction will allow a small number of entities—Verizon included—to dominate millimeter wave band holdings for the next few years, giving them a significant competitive advantage. The bigger carrier has been acquiring millimeter wave spectrum on the secondary market.

“In order to prevent a few select carriers from having a competitive advantage detrimental to consumers, the millimeter wave spectrum that has been allocated thus far should be made available through auction as soon as practicable,” T-Mobile said in its filing (PDF).

T-Mobile noted that Verizon’s millimeter wave holdings are even greater than it initially represented to the FCC. The commission recently approved Verizon’s acquisition of Straight Path, which had been the subject of a bidding war last year. Verizon also has access to Nextlink Wireless spectrum.

The “uncarrier” also said that holding an auction in 2018 would be consistent with manufacturer statements that equipment will begin to be available in these bands in 2019 and 2020.

For its part, Verizon is telling the commission to eliminate the spectrum cap on the amount of spectrum in the 28, 37 and 39 GHz bands that a bidder can acquire at auction. “Doing so would maximize opportunities to put spectrum to efficient use, consistent with the Commission’s decision not to adopt such a cap for the 24 and 27 GHz bands,” Verizon said in its comments (PDF).

US Cellular noted that the FCC has approved Verizon’s acquisition of large amounts of 28, 29, 31 and 39 GHz spectrum from XO Holdings and Straight Path and as a result, Verizon’s millimeter wave holdings already exceed, prior to any auction of Upper Microwave Flexible Use Service (UMFUS) licenses, the former millimeter wave spectrum threshold of 1250 megahertz for proposed secondary market transactions involving spectrum rights in the 28, 37 and 39 GHz bands.

The more recent grant of Verizon’s plan to acquire Straight Path licenses did not cause Verizon to exceed the spectrum threshold now in effect, but only because the threshold had been increased to 1850 megahertz as a result of the addition of the 24 and 47 GHz bands, US Cellular said in its filing (PDF).

“These transactions, however, certainly are evidence that the largest carriers are likely to pursue mmW spectrum acquisition relentlessly, shutting out smaller carriers, unless they are subject to reasonable spectrum acquisition restraints both pre- and post-auction,” US Cellular stated.