Verizon argues its new Long Term Evolution network will itself start to experience a capacity issue by 2013, illustrating the need to release additional mobile spectrum. Some would say that is a simple extrapolation from historic trends, which have bandwidth consumption on virtually all networks growing 40 percent to 60 percent a year.

Some would argue there are other ways to supply more bandwidth, but it also is no surprise Verizon argues those approaches will not work, and that there is no serious alternative to additiional spectrum. You’d expect Verizon to say that.

For a wide variety of industries and services, there is no business without spectrum. Whatever usefulness a range of other tools might provide, ranging from Wi-Fi offload to small cells, spectrum re-farming or cell-splitting, there is no substitute for additional spectrum, Verizon argues.

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To be sure, Verizon has to mount a defense of the deal to buy spectrum from leading cable operators. The filing to the Federal Communications Commission is part of that effort.

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