Neville Ray's central justification for the merger is that in 5G  "mid-band spectrum will achieve a 52 percent improvement" over 4G. That is not an appropriate figure today.

One reason for the improvement was that 5G allows 100 MHz bands compared to the 20 MHz bands of 4G. Sprint and China Mobile both have blocks of over 100 MHz at 2.6 GHz. The new 4G SuperBAND from Huawei effectively coordinates 100 Mhz of spectrum for a similar result. T-Mobile's vendors, Nokia and Ericsson, should soon be able to do similar.

Ray in a footnote points out he doesn't know whether his claim is accurate. "The spectral efficiency improvements are derived from equipment vendor simulations, internal T-Mobile analysis, and ITU requirements." Those equipment vendors are trying to sell him 5G equipment and have the incentive to make inflated claims. They are not a reliable source. It's easy to imagine testing that produces a preferred result.

There was no test data available when Ray (a first-rate engineer) wrote in June 2018. Fortunately, several vendors can now provide the equipment to provide more accurate figures. I have data from T-Mobile's parent company, Deutsche Telekom, that 5G speeds in 100 MHz of mid-band spectrum are 350-850 megabits. That's slower than the 4G starting to be deployed. 

SuperBAND 4G performance undermines the primary engineering argument for the deal. The early results from 5G suggest the actual testing of 5G will show less benefit than the T-Mobile claim. 

T-Mobile in Manhattan independently tests at 500 megabits down using LTE LAA. This is much faster than Ray's expectation for 5G because of the use of unlicensed spectrum through LAA. That's rapidly deploying across the country.

The FCC should suspend analyzing the deal until T-Mobile supplies current data. I'd expect the actual improvement in sub-6 GHz  is less than the annual 40% improvement Verizon reports for the last several years.

p.s. The filing makes claims about the capabilities of the Sprint network that are no longer true. Sprint cut capex in 2017 to under US$3 billion, leaving them far behind. They are raising capex to US$5-6 billion in 2018 and 2019. The performance already has dramatically improved.

Ray's analysis does not include the use of the 3.5 GHz shared CBRS spectrum, which is going live in the next few months. T-Mobile has demonstrated good results in CBRS. Commissioner Mike O'Reilly is confident hundreds of MHz in 3-7-4.2 GHz will also become available. I believe that spectrum could achieve most of the performance benefits of the merger.   

dave ask

Newsfeed

The 3.3-4.2 spectrum should be shared, not exclusively used by one company, concludes an important U.S. Defense Innovation Board report. If more wireless broadband is important, sharing is of course right because shared networks can yield far more

It does work! Verizon's mmWave tests over a gigabit in the real world. 
The $669 OnePlus 7 Pro outclasses the best Apples and probably the new Galaxy 10 or Huawei P30 Pro. Optical zoom, three cameras, liquid cooling, Qualcomm 855 and more.
Korea at 400,000 5G May 15. Chinese "pre-commercial" signing customers, 60,000-120,000 base stations in 2019, million+ remarkable soon. 
5G phones Huawei Mate 20, Samsung Galaxy 10, ZTE Nubia, LG V50, and OPPO are all on sale at China Unicom. All cost US$1,000 to 1,500 before subsidy. Xiaomi promises US$600.
Natural monopoly? Vodafone & Telecom Italia to share 5G, invite all other companies to join.
Huawei predicts 5G phones for US$200 in 2021, $300 even earlier
NY Times says "5G is dangerous" is a Russian plot. Really.
Althiostar raised US$114 million for a virtual RAN system in the cloud. Rakuten, Japan's new #4, is using it and invested.
Ireland is proposing a US$3 billion subsidy for rural fibre that will be much too expensive. Politics.
Telefonica Brazil has 9M FTTH homes passed and will add 6M more within two years. Adjusted for population, that's more than the U.S. The CEO publicly urged other carriers to raise prices together.
CableLabs and Cisco have developed Low Latency XHaul (LLX) with 5-15 ms latency for 5G backhaul,  U.S. cable is soon to come in very strong in wireless. Details 
Korea Telecom won 100,000 5G customers in the first month. SK & LG added 150,000 more. KT has 37,500 cells. planning 90% of the country by yearend. 
The Chinese giants expect 60,000 to 90,000 5G cells by the end of 2019.
China Telecom's Yang Xin warns, "Real large-scale deployment of operators' edge computing may be after 2021." Customers are hard to find.
Reliance Jio registered 97.5% 4G availability across India in Open Signal testing. Best in world.

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Welcome On Oct 1, 2019 Verizon turned on the first $20B 5G mmWave network with extraordinary hopes. The actual early results have been dismal. Good engineers tell me that will change. Meanwhile, the hype is unreal. Time for reporting closer to the truth.

The estimates you hear about 5G costs are wildly exaggerated. Verizon is building the most advanced wireless network while reducing capex. Deutsche Telekom and Orange/France Telecom also confirm they won't raise capex.

Massive MIMO in either 4G or "5G" can increase capacity 3X to 7X, including putting 2.3 GHz to 4.2 GHz to use. Carrier Aggregation, 256 QAM, and other tools double and triple that. Verizon sees cost/bit dropping 40% per year.

Cisco & others see traffic growth slowing to 30%/year or less.  I infer overcapacity almost everywhere.  

Believe it or not, 80% of 5G (mid-band) for several years will be slower than good 4G, which is more developed.