CTIA Study: Wired and Fixed Wireless Broadband Do Directly Compete

At every opportunity – in blog posts, Perspectives from FSF Scholars, and comments filed with the FCC – Free State Foundation scholars (me included) make the case that 5G fixed wireless access (FWA), and wireless broadband generally, directly compete with traditional fixed offerings, primarily cable and fiber. A recent report commissioned by CTIA provides evidentiary support for that assertion.

"The Impact of 5G Fixed Wireless Access Entry on Competition in the U.S. Residential Broadband Market," released on October 8, concludes that, from a policy perspective, "analyses of broadband competition, whether in merger review, the FCC's mandated competition reports, or states' broadband planning, should treat fixed wireless as a full competitor."

This aligns neatly with the following point FSF President Randolph May and I made in comments filed in the 2026 Communications Marketplace proceeding:

Regarding the IP-based distribution platform – that is, Internet access – it certainly is time for government writ large to acknowledge what individual consumers long have accepted as a given: that, for in-home service, providers of "fixed broadband services," "mobile wireless services," and "satellite communications services" (differentiating terms of art employed in the Public Notice) in fact are fungible services that compete head-on for customers.

Section 4.3 of the 2023 Merger Guidelines states that, in identifying a relevant antitrust market, the FTC and the Department of Justice "may rely on … evidence on observed market characteristics ('practical indicia'), such as … sensitivity to price changes."

The report provides precisely such evidence, finding that "[i]n local markets where T-Mobile, AT&T, or Verizon launched 5G fixed wireless home internet, cable broadband prices were approximately 12 percent lower than the estimated counterfactual price – what prices would have been absent FWA entry."

To be sure, the broadband marketplace is dynamic, and the report should not be taken to mean that 5G fixed wireless access is superior to other distribution technologies: cable, fiber, low-Earth orbit satellite, and others, each with their own unique set of advantages and disadvantages. Nor should the report be interpreted as concluding that FWA will – or should – win out in the marketplace.

Rather, it should be viewed as a source of further evidence that consumers are able to choose from a wide range of robust options, both wired and wireless – and that, as a consequence, there is a compelling justification for policymakers to eliminate regulations that discourage investment and innovation.

T-Mobile/UScellular Transaction Likely to Benefit Wireless 5G Consumers

On September 13, T-Mobile filed a public interest statement with the FCC in support of its proposed transaction with US Cellular. If approved, the T-Mobile/UScellular transaction likely would produce pro-competitive results. The merger would benefit UScellular subscribers by giving them access to a 5G mobile wireless network with faster speeds and higher data capacity. It also would enhance residential broadband competition by expanding consumer access in UScellular's service regions, especially in rural areas. On its face, the proposed combination does not appear to pose any significant competitive harm. The Commission should conduct a timely review of the T-Mobile/UScellular transaction and issue its decision within the agency’s 180-day shot clock.

The proposed T-Mobile/UScellular deal reportedly would result in T-Mobile acquiring UScellular's wireless operations, subscribers, and about 30% of its spectrum licenses for $4.4 billion. UScellular is a multi-regional wireless provider that serves about 4.5 million subscribers – or about 1% of the nation’s mobile wireless services market. Its subscribership has been declining in recent years. Strong competition from cable hybrid wireless mobile virtual network operators (MVNOs) Spectrum Mobile and Xfinity Mobile partly account for US Cellular's declines. Moreover, UScellular has lagged behind AT&T, T-Mobile, and Verizon – the three major nationwide mobile wireless providers in 5G network deployment.

Revenue reductions resulting from subscriber losses, as well as the burdens of servicing $2.9 billion in debts, are limiting its resources for future network investment. If UScellular were to continue operating as a standalone mobile provider, its competitiveness would probably diminish further.

T-Mobile's public interest statement presents a prima facie case that its proposed transaction with UScellular will bring public interest benefits that outweigh any potential competitive concerns. Today's dynamic wireless market provides the analytical context for the proposed T-Mobile/UScellular deal. As explained in the Free State Foundation’s June 2024 public comments to the FCC for its forthcoming 2024 Communications Marketplace Competition Report, there is effective competition among the mobile wireless segment of the broadband market. In 2022 and 2023, the three nationwide wireless providers significantly upgraded and expanded their 5G network coverage. Additionally, aspiring national provider EchoStar (which recently acquired DISH Network) announced in March of this year that its 5G network covers over 70% of the U.S. population. The large footprints of Xfinity Mobile and Spectrum Mobile also support competitive 5G wireless services to at least 16 million subscribers and counting.

Moreover, the T-Mobile/UScellular transaction is unlikely to reduce wireless competition. T-Mobile faces little challenge from UScellular due to its small market share, with a footprint that spans only about 10% of the nation's geographic territory. T-Mobile is the second-largest wireless provider, with nearly 126 million total subscriptions versus UScellular's 4.5 million. T-Mobile makes its pricing and service terms on a nationwide basis, and thus UScellular's presence in a given area is unlikely to impact T-Mobile's price offerings. According to the public interest statement, T-Mobile and UScellular do not have an overlapping competitive presence in only about 37% of the Cellular Marketing Areas (CMAs) that are implicated by the proposed transaction.* If the it is approved, most consumers would continue to have choices among nationwide providers T-Mobile, Verizon, and AT&T, and many consumers also would have choices among DISH Wireless and a cable wireless MVNO. 

Furthermore, T-Mobile's analysis indicates that the proposed acquisition of 30% of UScellular's spectrum portfolio would not trigger the FCC's spectrum screen analytical trigger in any cellular marketing area. This presumes that T-Mobile completes planned sales of certain spectrum licenses that it currently holds in the 800 MHz and 3.45 GHz bands. 

Under the terms of the proposed T-Mobile/UScellular transaction, UScellular subscribers would have the option of staying on their existing rate plans. T-Mobile estimates that at least some of UScellular's subscribers would experience a price decrease by changing to comparable plans offered by T-Mobile. If correct, and given existing competition in the market, the deal would not likely cause rates to increase for consumers. 

The transfer of spectrum licenses contemplated in the proposed T-Mobile/UScellular transaction triggers the FCC's review of the transaction under its public interest standard. The Commission's merger review process includes opportunity for public comments that could shed added light on the proposed deal. The agency will undertake its examination of the representations made in the public interest statement – including information redacted from public view – and it will more closely examine the potential effects in local markets. However, at this stage of the proceeding, the T-Mobile/UScellular transaction appears to be a strong candidate for approval. 

Importantly, the Commission should complete its transaction review within the agency's informal 180-day shot clock. Delays in completing reviews can accelerate subscriber losses in small providers and have other harmful impacts.

(*12/19/2024 - a correction has been made in this post to the percentage of CMAs in which the parties have an overlapping presence)

(*02/04/2025 - further edits have been made to more accurately refer to the transaction as an acquisition of assets and not a merger between the parties)