Communications Workers of America:

  • "First, the merger would result in the loss of more than 28,000 jobs across the United States and combine two companies with a long history of labor and employment law violations." (exec. summary)

  • "Our analysis finds that the proposed T-Mobile/Sprint merger will result in the loss of more than 28,000 U.S. jobs. Approximately 24,000 jobs would be eliminated as a result of overlapping retail store closures at postpaid and prepaid (e.g. Boost and MetroPCS) locations. Another approximately 4,500 jobs would be eliminated due to duplicative functions at corporate headquarters in Overland Park, KS and Bellevue, WA." (exec. summary)

  • "T-Mobile has won the dubious distinction as being one of the worst labor law violators in the country. T-Mobile has been found in violation of U.S. labor law six times since 2015 and has been subject to approximately 40 unfair labor practice charges since 2011." (exec. summary)

  • "Thus, for example, although T-Mobile Executive Vice President for Corporate Strategy Peter Ewens states in his declaration that there would be substantial reduction in non-network costs like retail and advertising, the submission says nothing about how many retail jobs would be eliminated. And although some of the synergies are expected to come from a reduction in subscriber churn, no detail is provided, nor is any effort made to calculate how much of this reduced churn would be due to the elimination of a competitive alternative, leaving consumers worse off." (p. 37) 

    ⇨ "If the positive impact a merger may have on employment is a public interest benefit, an expected reduction in U.S. employment following a merger may be regarded as a public interest harm. CWA has performed a comprehensive analysis based on detailed location data for all the retail locations involved in the proposed transaction. Our analysis finds that the proposed T-Mobile/Sprint merger will result in the loss of more than 28,000 jobs." (p. 54) 

  • "Given the aggressive expansion plans that the Applicants demonstrated as standalone companies, their claims of merger-specific job creation are simply not credible. In several cases, such as retail expansion in rural areas and onshoring of customer care, the Applicants appear to claim that pre-existing U.S. job growth plans were somehow driven by the transaction." (p. 57) 

  • "Both T-Mobile and Sprint have long track records of offshoring U.S. jobs Both T-Mobile and Sprint have a history of outsourcing key functions and sending U.S. jobs to overseas contractors. In the Public Interest Statement, the Applicants’ make unverified claims that they will bring some jobs back from overseas. However, the Applicants provide no information regarding the number of jobs each company currently offshores and specifically how many offshore jobs will be repatriated as a result of the proposed transaction. (p. 60) [...] The Applicants’ well-documented recent history of cutting jobs following a transaction and significant offshoring of U.S. jobs raises questions about the credibility of their future plans to preserve and create jobs in the U.S." (p. 61) 

  • "To predict the number of postpaid T-Mobile and Sprint stores likely to close following the merger, CWA created a regression model using the relationship between population and the number of T-Mobile Stores [see Appendix D for methodology]. This model predicts that the Applicants will operate 6,153 postpaid retail stores in current T-Mobile/Sprint markets, closing 2,948 corporate and dealer stores in these markets. We project that the Applicants will open 240 postpaid stores in rural areas, bringing the total number of postpaid stores to 6,393. We project that the initial store closures will eliminate more than 23,000 postpaid retail positions, but that these losses will be somewhat offset by gains at remaining stores and new hiring in rural areas. We project the proposed transaction will cause a net loss of 12,674 postpaid retail jobs." (p. 63)

  • "We estimate that the Applicants’ planned expansion of rural retail will include 360 new prepaid locations, yielding 1,080 new jobs. Considering both store closures and new stores in rural areas, this consolidation in the prepaid wireless market could cost 11,874 jobs." (p. 65)

  • "This merger will eliminate one of those four competing firms, reducing employees’ alternative job opportunities and therefore their individual bargaining power. The resulting concentration puts downward pressure on wages and other terms of employment for workers in this market. None of the labor effects of this merger can be considered in the public interest, especially where consensus exists across the political spectrum: wage stagnation is a serious national problem. The Commission, therefore, should not allow the merger of these two companies absent the jobs protections we discuss below. Without such protections, the merger would only serve to further depress labor standards in this industry." (p. 70) 

  • "The Commission should not approve the proposed transaction without strong, verifiable commitments from the applicants to preserve U.S. employment and respect workers’ rights The Commission should not approve the proposed transaction without clear and enforceable commitments by the Applicants to protect jobs in the U.S. The Commission should require that the Applicants ensure that the transaction does not cause a reduction in U.S. employment and that no employee of T-Mobile or Sprint loses a job as a result of this transaction. Furthermore, the Applicants should commit to return all overseas customer call center jobs to the U.S." (p. 71) 


  • "In addition, neither Sprint nor T-Mobile has the physical presence and ability to send trucks and installation crews that both Verizon and AT&T can marshal. (fn-385) While the Applicants claim that they will add 600 new stores to serve rural Americans, they have been unwilling to commit to where those stores will be located, claiming that doing so is unnecessary. (fn-385: On the contrary, a portion of the claimed merger synergies will be massive job cuts. Communications Workers of America, WT Docket No. 18-197, at i (Aug. 27, 2018) (“[T]he merger would result in the loss of more than 28,000 jobs across the United States and combine two companies with a long history of labor and employment law violations. Contrary to the Applicants’ unsubstantiated claims of merger-related job creation, leading Wall Street analysts predict that massive job cuts from the elimination of duplicative retail stores and headquarters functions at the New T-Mobile will contribute significantly to the billions of dollars in projected merger ‘synergies.’”)." (p. 109)

Public Interest Groups

  • Despite the claims of T-Mobile and Sprint that the proposed merger would be a boon for American jobs, third party analysts have concluded that the transaction is likely to eliminate tens of thousands of American jobs. Further, T-Mobile and Sprint have failed to make any concrete commitments about bringing or retaining jobs in the United States, and either way the claim that the companies will bring in more employees to build a 5G network are not in any way specific to the proposed transaction, as both companies would likely need additional personnel to build their 5G networks regardless." (p. iii)

  • "The Merger Could Eliminate Tens of Thousands of American Jobs The proposed transaction would likely lead to substantial job losses in the United States—another concrete reflection of the harmful consequences that could be expected to result from the merger. Independent research from the Communications Workers of America (“CWA”), New Street Research, and MoffettNathanson Research predicts job loss in the tens of thousands for U.S. workers. The Applicants’ claim that the merger will create jobs is unverifiable as T-Mobile has not made any concrete commitments to protect existing jobs or to create new ones. Any jobs created from 5G deployment are not merger-specific, either, because the Applicants do not need the merger to deploy 5G technology. Importantly, both companies have a history of layoffs in prior mergers. In 2013, T-Mobile laid off hundreds of employees in its operations and marketing divisions in its merger with MetroPCS. Following its merger with Nextel, Sprint cut 4,000 jobs in 2008 and 8,000 more in 2009." (p. 30)

  • "Despite claims from T-Mobile’s paid consultant Dr. Jeffrey A. Eisenach that the transaction will contribute an estimated 51,200 job-years over a five-year period, T-Mobile has not made any concrete commitments regarding jobs as carriers have in prior mergers." (p. 31)

  • "In this pending merger before the Commission, T-Mobile has not made any similar, concrete commitments to protect or create jobs. Any claims of an increase for jobs in the new company at this point are unsubstantiated and unreliable. Applicants’ Job Claims Are Not Merger-Specific. As detailed above, T-Mobile does not need to merge with Sprint in order to deploy 5G technology. Because this so-called efficiency is not merger-specific, the associated 73,600 job-years that Eisenach attributes to 5G deployment between 2021 and 2023 are not merger-specific, either. Excluding these 5G-related jobs, the companies’ speculative claim of 51,200 job-years—which could range from 10,240 to 51,200 total jobs over the projected five-year period—does not project a net job creation resulting from the merger. In other words, if both T-Mobile and Sprint have promised to build and deploy nationwide 5G networks on their own, as their past statements to investors and the public have indicated, the carriers would already create jobs catalyzed by a need to build the infrastructure for 5G even in the absence of this merger. " (p. 32) In this pending merger before the Commission, T-Mobile has not made any similar, concrete commitments to protect or create jobs. Any claims of an increase for jobs in the new company at this point are unsubstantiated and unreliable." (p. 32)

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