Thirty-nine months and $1.75 billion is more than enough.

That’s the message U.S. wireless carrier T-Mobile and wireless provider group the Competitive Carriers Association (CCA) sent to the Federal Communications Commission this month in the form of two separate studies examining the commission’s proposed broadcaster relocation schedule.

According to both T-Mobile and the CCA, claims that the FCC’s proposed 39-month repacking deadline and $1.75 billion budget for the transition are insufficient are baloney. In fact, T-Mobile and the CCA argue, the opposite is true: it’s possible for station relocations to be completed both under time and under budget.

The reports from T-Mobile and the CCA come in response to a National Association of Broadcasters-commissioned study from Digital Tech Consulting (DTC) that concluded the time and funding allowed by the FCC’s current repacking plan would only accommodate the relocation of 445 stations.

The DTC report was cited by the NAB in a November filing asking the FCC to reconsider its 39-month deadline and instead develop a regional transition plan. At the time, an NAB spokeswoman told Broadcasting & Cable that its concerns were shared by unnamed wireless carriers.

However, the CCA argued in its filing earlier this month that the NAB study was heavily flawed.

“The (CCA) study also explains why the Malthusian projections in the DTC Report sponsored by the National Association of Broadcasters (NAB) are highly unlikely and unrealistic,” the CCA wrote. “The NAB-sponsored study failed to use realistic assumptions for broadcast participation, did not appear to consider the efficiencies of antennas capable of tuning across the entire UHF band and – perhaps most importantly – underestimated the ability of service providers to offer repacking services within FCC’s deadline.”

The study submitted by the CCA this month, which was authored by University of Maryland Professor of Economics Peter Cramton and two post-doctoral researchers, conversely found the FCC’s proposed repacking schedule offers more than enough time to complete the transition, regardless of the clearing target.

According to Cramton and his associates, more than 1,000 stations could be repacked in 39 months or less.

T-Mobile’s filing last week, however, takes things a step further by concluding the repacking could be completed “at or under the $1.75 billion budget set by Congress.”

According to the T-Mobile report, the transition could be completed for a total of $1.46 billion in a best-case scenario involving 800 stations or $1.74 billion in a worst-case scenario involving 1,200 stations. The DTC report had projected a cost range between $1.98 billion and $2.94 billion for the same.

The authors of the T-Mobile report, Broadcast Tower Technologies, Inc. (BTTi) and Hammett & Edison, Inc., said they reached their conclusion by correcting errors made in the DTC report.

“Our cost estimates differ from DTC’s due to four factors: (1) correct station counts; (2) more accurate broadcast station transmitter power levels; (3) recognition of broadband antenna efficiencies; and (4) recognition of solid-state transmitter efficiencies,” BTTi and Hammet & Edison wrote.

According to BTTi and Hammet & Edison, the DTC report not only overestimated the maximum number of stations that will need to be repacked following the auction, but also overstated the necessary power level of replacement transmitter systems and cost of said systems, “incorrectly” assumed every broadcaster will need to replace its antenna, and failed to take into account cost-savings that could be achieved through the reuse of some solid-state transmitters already deployed in the field.

“The relocation process will prove challenging and will no doubt face unanticipated obstacles,” the report concluded. “But even allowing for inevitable complications at particular sites, our analysis should give the Commission – and the broadcast industry – confidence that the nation’s broadcasters can repack to a new, more efficient band plan within 39 months and the $1.75 billion budget Congress has established.”