3. It is a scarce public resource enshrined in law. The radio frequency spectrum is a scarce public resource that shall be administered in the public interest and in accordance with international agreements and conventions to which the Philippines is a party and granted to the best qualified. The government shall allocate the spectrum to service providers who will use it efficiently and effectively to meet public demand for telecommunications service and may avail of new cost effective technologies in the use of methods for its utilization. – Republic Act 7925, Article II, Section 4(c) The radio frequency allocation and assignment shall be subject to periodic review. The use thereof shall be subject to reasonable spectrum user fees. Where demand for specific frequencies exceed availability, the Commission shall hold open tenders for the same and ensure wider access to this limited resource. – Republic Act 7925, Article V, Section 15

4. The consolidation of PLDT/Smart and Digitel/Sun will result in an lopsided imbalance of spectrum allocation in their favor. 155 MHz vs 85 MHz 1.82 : 1 Ratio

5. All other usable spectrum resources considered, including bands in the 3400 MHz and 5400 MHz ranges, the gap widens further. 3.76 : 1 Ratio Globe serves 26.5M subscribers with only 99 MHz while Smart + Sun shall effectively serve 60M subscribers with 372MHz. Therefore, Globe serves 268K subscribers with every 1 MHz of spectrum whereas Smart + Sun will only address 161K subscribers with every 1 MHz of spectrum. Theoretically, Smart + Sun should NOT be assigned more than 224 MHz of spectrum (vs 372 MHz post-consolidation) to cater to 60M subscribers. Spectrum Band Smart + Sun Globe 850 MHz 10 MHz None 900 MHz 7.5 MHz 17.5 MHz 800 MHz 37.5 MHz 12.5 MHz 2100 MHz 35 MHz 10 MHz 2300 MHz 30 MHz None 2500 MHz 35 MHz 45 MHz 3400 MHz 94 MHz 14 MHz 5400 MHz 123 MHz None TOTAL 372 MHz 99 MHz