美国通信基础设施：FCC频谱举措对铁塔公司整体利好

for towers (including emerging space-based Direct-to-Device orD2Dofferings).While alarge portionofthishadbeenpre-announcedandpricedintostocks,thereis someupsidetoberealized.The release did three things:approved the EchoStar spectrum sales (announced madison.rezaei@bernsteinsg.comLaurent Yoon September 2025),created a $2.4Bescrow fund that"can be drawn upon for qualifyingclaims,and cleared the pathfor increased competition fromD2D.Weperceivethistobenetneutral-to-positiveforthethreetower names.Thespectrumsalesapprovalscomeasnosurprise-AT&Thaddeployed~80%of the laurent.yoon@bernsteinsg.comNancy Wu nancy.wu@bernsteinsg.com spectrum by the end of 2026, largely as software upgrades with limited benefit to towers.While the FCC did increase the buildout requirements aboveand beyond the previousrequirements (Exhibit 1), we do not anticipate this meaningfully changing AT&T's near-termbehavior. If anything, the company will now be forced to deploy incrementally more in ruralareas within the 10-year window (likely positivefortowers). +19173448564martin.boruchowicz@bernsteinsg.com announcedacrossthethreeTowerCos(~$3-4Bfortowers; closerto~$7-10Bacrossall vendor types). This is a first-of-its-kind FCC condition intended to pay infrastructureproviders with whom Dish has defaulted. Notably by filing a claim, a claimant waives anyfurther legal right to recovery. It is not yet clear which path the TowerCos will pursue-thereis almost certainlymoreupsidefrom continued arbitration,though thismay represent afloor. flexibility for a series of spectrum bands,allowing requirements to be met with eitherterrestrial orD2D metrics."This transaction reflects a recognition ofconverging satelliteandterrestrial wireless networks that will shapethefuture of connectivity for mobiledevices." Instead of traditional coverage metrics, the FCC is imposing 5G-equivalentperformancestandards arounddownlinkquality,spectralefficiency,and latency.Afewtofacilitate D2D competition. Whilean initial read of this could be negativefortowers, we think itmore broadly opens upthe possibility of a new wireless entrant in the U.S.In our view,given technology limitations(like notworking indoors),it will be impossible fora standalone D2Dnetworkto competetowerupside. We believe the potential incremental rural buildout and escrowfund to be neutral to mildlypositive, but we believethe third FCCmove-facilitating D2D competition-should onlyprovide upside to the currently-depressed tower industry TheFCC approvedAT&T's proposed 6OO MHz buildout timelinebut imposed significantly stricterconditions than AT&T requested. While AT&T's original proposal included only a 5-year buildout to 75% U.S.population plus 40% per-PEA ("partialeconomic areasdeterminedbytheFCC,ofwhichthereare416intheU.S.),theFCCaddedacritical Year1O requirementmandating 75% coverage per-PEAon a license-by-license basis, explicitly designed to prevent AT&Tfrom cherry-picking high-density markets while ignoring rural areas.The FCC also imposed automatic acceleration penalties (interimmilestone failurescanpullthefinaldeadlineforwardbyupto2years)andautomaticlicenseterminationwithoutCommissionactionifAT&Tfailstomeetthe Year 10/75% per-PEA requirement for any specific license,with AT&T permanently ineligible to reacquire terminatedlicenses.This represents theFcC's mostaggressive buildout enforcementmechanismfor secondary marketspectrumtransactions, reflecting the agency's stated position that"AT&T's proposed buildout commitments are insufficient to ensurerural markets. 2.ESCROWFUND:NEUTRAL-TO-POSITIVEFOR TOWERCOS The $2.4Bescrow isa"precedentiallynovel"FCCconditionthatcreates a trustfund topaytower companies,fiberproviders,construction firms, and other infrastructure partners who built Dish's abandoned 5G network but claim they weren't paid.EchoStar must deposit the funds within 30 days of closing, with a neutral third-party trustee administering claims in threetiers: TypeA claims under $100K are paid as verified; Type B-1 claims over $100K for work actually performed (includingconstruction,decommissioning,towerleases,andbackhaul)arepaidsemi-annuallyonapro-ratabasis;andTypeB-2claimsrightstootherwisepursue EchoStar entities in court, forcingtower companiesto choose between accepting partial paymentnot a party to the AT&T...agreements, does not own the spectrum licenses being sold, and is not entitled to receive any of thespectrumsaleproceeds, creatingthecoreproblemthat promptedthis unprecedentedcondition.TheFcC stated this escrowis"necessary toconcludethat the proposedtransaction serves the public interest,'effectivelymaking vendor disputes partoffuture deals. 3.INCREASEDD2DCOMPETITION:POSITIVEFORTOWERCOS with stringent"space-based"performance metrics that must bemet at escalating geographic coverage thresholds:downlink second/Hzperbeam-all measuredat 70%serviceavailability-across 30%of eachBasic Economic Area (BEA)within5years,50% of each BEA within 7 years (requiring only the first two metrics),