“Today, there are wireless resellers who exclusively use wholesale capacity on the T-Mobile network, and who already offer more data than T-Mobile dangles here at the same $15 price point. That demonstrates that of course T-Mobile itself could offer this level of service at this price point if it wanted to, without needing the merger. That it is only promising to do so if the market becomes more concentrated shows that T-Mobile’s overall profitability would massively increase post-merger, when it would face less pressure to compete on pricing for high quality wireless plans including the market’s most-popular unlimited services. “Today’s level of competition in the wireless market is not optimal, but it is enough to keep pushing the quality-adjusted price down, as carriers increase data allotments for plans at the same or similar price points. Just in the past year alone, some resellers have increased their monthly data allotments by 50% for their $15 plans. T-Mobile is trying to fool people into thinking that their merger is the only path to progress and price competition for the wireless market and its customers. But it's the presence of four independent competitors, and Sprint competing directly with T-Mobile, that has and will continue to drive price competition in the U.S. wireless market. “Even if the merging parties kept this promise in its entirety -- which merging parties almost never do -- we can't accept T-Mobile's latest raft of empty claims to be helping value-conscious customers instead of hurting them."

“The so-called un-carrier’s commitments to workers affected by this merger are certainly un-something – they are un-enforceable and un-believable. CWA’s modeling of post-merger employment by the combined T-Mobile and Sprint projects the loss of up to 30,000 jobs, predominantly through headquarters consolidation and store closures. In the FCC’s recent formal approval Order, issued last week, the Commission noted significant deficiencies in the information that the companies provided to justify their job creation claims, saying that T-Mobile and Sprint “have not provided enough information for us to fully quantify the inputs, and thus we cannot rely heavily on the model to draw conclusions about the likely effect of the transaction on jobs. We are therefore unable to quantitatively verify the Applicants’ claims…” (see p.146 of FCC Order) T-Mobile is careful to use the term ‘employee’ when making vague promises about future employment levels. This leaves out the nearly 70 percent of wireless retail workers who sell T-Mobile and Sprint services via branded authorized dealer locations, and whose jobs are equally in jeopardy as a result of this destructive merger.”

“This is yet another promise from T-Mobile that sounds good in a tweet, but is completely unenforceable and raises key questions. T-Mobile claims that at least 5.25 million American households with school-age children living at home lack Internet service. While making internet access affordable for low-income families is an admirable goal, many providers already make low-cost plans available to qualifying households and the federal government’s Lifeline program provides subsidies through participating providers. What this plan doesn’t address is access for families due to coverage gaps, especially in rural areas. The plan for the new T-Mobile still leaves over 40 million Americans without access to the company’s high-capacity network. As with the other announcements, the details of Project10 million are sparse. T-Mobile does not mention what households in particular will qualify as ‘eligible’ for the Project 10Million Program. And finally, do any of the commitments contained in these Uncarrier announcements - - whether Connecting Heroes, Project 10Million, or T-Mobile Connect - - become legal commitments or are they merely empty promises by a CEO who apparently has one foot out the door looking for his next gig?”

“The ‘Connecting Heroes’ initiative is too little, too late and too saddled with outstanding questions for the public safety community to take seriously. First responders fought for years to give law enforcement, fire, and EMS personnel their own network. That now exists as FirstNet with backing from the federal government. T-Mobile was noticeably absent in 2016 when the First Responder Network Authority asked for bids to build out the national public-safety broadband network. Now, T-Mobile is disingenuously pandering to first responders, but failing to provide key details on how the initiative will work over the long-term. For example:

• If T-Mobile merges with Sprint, who will make sure that the company follows through on its 10-year commitment to public safety? Are there penalties if T-Mobile does not deliver on its 10-year commitment?
• As soon as possible is not a legitimate timeframe for rollout. When exactly can first responders expect access to this plan?
• What are the network build-out requirements?
• Firefighters in California saw the vital importance of a dedicated network for first responders when they experienced throttling from Verizon during the Mendocino wildfire in 2018. Will first responders experience throttling under this plan?
• Does T-Mobile’s plan include features offered by FirstNet such as priority and preemption, exclusive network core with end-to-end encryption, on- the-ground disaster response support, and an exclusive application ecosystem?”

“Fundamentally, the moves, while consumer- and regulator-friendly on the margins, do not address the competition harms that the State AGs have alleged in their complaint which argues that the deal violates the Clayton Act … we expect the lawsuit to move forward and these kind of public interest benefits are unlikely to play any role in the Judge’s thinking.”

• Ray Rodrigez, Local 6222, United States Marine Corps Veteran
• Bruno Pavone, Local 3611, United States Navy Veteran
• Lafarrah Hines, Local 3680, United States Army Veteran
• Frank Cota, Local 7026, United States Marine Corps Veteran
• Antiujan Davis, Local 84755, United States Marine Corps Veteran
• Justin Sparyanski, Local 84913, United States Army National Guard Veteran