There’s not much new in T-Mobile’s latest report to the FCC on the progress it’s made since its merger with Sprint.

The company already announced in October that it covers 300 million people with its mid-band 5G spectrum, months ahead of schedule. Its overall 5G footprint, which uses low-band spectrum, covers more than 330 million people, or 98% of the population.

But it’s worth a gander, if only as a reminder of what T-Mobile’s achieved over the past three years and how challenging it’s going to be for Dish Network, coming from a much different place, to achieve its buildout obligations. They’re both required to fulfil certain network and reporting requirements as part of the FCC’s order approving the Sprint/T-Mobile merger in 2020.

To be clear, T-Mobile’s Third Annual Progress Report on fulfilling certain FCC commitments doesn’t address jobs, a hot-button issue for many who opposed the merger. T-Mobile executives like former CEO John Legere famously promised more jobs as a result of the kind of consolidation that usually leads to job cuts. Indeed, last year T-Mobile announced a 7% reduction in its workforce, eliminating about 5,000 jobs.

5G coverage, sites & spectrum

The report submitted on January 2 centers on the network milestones that T-Mobile has accomplished with respect to its 3-year commitments for nationwide 5G deployment, which includes low-band and mid-band 5G coverage, 5G sites, download speeds and more.

The filing was submitted on behalf of T-Mobile by its attorney Nancy Victory, who served as lead regulatory counsel to T-Mobile and Deutsche Telekom when they sought various regulatory approvals for the merger with Sprint. She also advised T-Mobile on the divestiture of Sprint’s prepaid wireless business to Dish.

Some of the more interesting tidbits about T-Mobile’s 5G deployment – such as the number of 5G sites it’s deployed nationwide and specifically, the number of 5G sites deployed in rural areas – are redacted in the report. T-Mobile requested confidential treatment of that information.

But it did reveal some details about the drive testing done to verify compliance with 5G speed commitments. The report states that T-Mobile collected “an unprecedented” number of speed measurements – or about 5 million in total, representing 10 times the industry average. The drive tests were done under terms agreed upon with the FCC’s Wireless Telecommunications Bureau.

The drive tests involved the collection of both stationary and mobile speed measurements in 500-meter grid locations covering about 96% of the U.S. population and 90% of the rural population.

T-Mobile said it encountered “numerous unforeseen difficulties” that made completing the drive task on time a challenge.

“In addition to traffic, road construction, and weather challenges, drive testers also faced unexpected delays and safety issues due to suspicion from residents and law enforcement in certain areas who viewed the drive testers as out-of-place and a potential threat,” T-Mobile told the FCC. “Despite these challenges, T-Mobile fulfilled its drive test obligations on time and in compliance with the terms of the White Paper memorializing the agreement between T-Mobile and the Bureau concerning the drive test methodology.”

The report includes a declaration by T-Mobile EVP and Chief Technology Officer John Saw pledging the accuracy of the drive test and a separate declaration from Comsearch VP Laura Fontaine serving as a third party to provide back-up of its authenticity. Comsearch was selected by T-Mobile to act as the independent third-party monitor.

The drive test data show that T-Mobile met its commitment with respect to at least 50 Mbps download speeds for 75% of the U.S. population and at least 100 Mbps download speeds for 63% of the U.S. population. Similarly, T-Mobile said it met the 3-year commitment metrics with respect to at least 50 Mbps download speeds for 66.7% of the rural population and download speeds of at least 100 Mbps for 55% of the rural population.

As for Dish, its next deployment deadline calls for covering 75% of each Partial Economic Area (PEA) in the U.S. by June 14, 2025. That’s a much harder milestone to meet compared to its previous buildout requirements. Dish’s ability to meet that obligation is questionable given its financial situation, but its newly minted merger with EchoStar will help see it through the near term.

Dish also will need to meet the FCC’s drive test requirements for validating its current 5G commitments. The FCC late last September gave Dish six months to complete the drive tests and submit those results.

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