Broadcasters are not asking the FCC to mandate that makers of cellphones install ATSC 3.0 tuners in them so that that they can receive broadcasts from stations that migrate to the new standard.

But T-Mobile is not taking any chances.

Yesterday, it submitted a 10-page white paper to the FCC asserting that, given the “the detrimental effects” that ATSC 3.0 tuners and antennas would have on phones and wireless service, whether to install them should be left to the market.

“Mobile reception of ATSC 3.0 is a complex issue that requires careful consideration of all the necessary physical characteristics of a mobile device,” the paper says.

“A new receive chain, including new antennas, filters and other materials, is required. ATSC 3.0 antennas can affect the device performance, especially in the 600 MHz band,” it continues. “The limited space in mobile devices precludes new ATSC 3.0 functionality and that physical space could be utilized for other, more beneficial purposes.

“Finally, ATSC 3.0 does not enhance the ability of emergency communications but may instead endanger reception of such transmissions.”

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The paper says that the ATSC 3.0 circuity and antennas will:

Increase the size and cost of devices, rendering them “uncompetitive” with phones without ATSC 3.0 capability.

Degrade the wireless service.

Take up space in the phones that could be better used for other purposes like antennas for low-band 4X4 MIMO wireless reception, which is more robust and immune to interference.