Fixing the U.S. Wireless Industry Through Wholesale Networks and MVNO Innovation

An Open Letter to the Federal Communications Commission

Dear Commissioners,

The U.S. consumer wireless market is broken.

Despite our nation’s unparalleled innovation ecosystem and world-leading tech companies, American consumers continue to pay some of the highest mobile phone bills in the world. The market has consolidated into a cozy triopoly—Verizon, AT&T, and T-Mobile control nearly all of the market. This concentration has led to stagnation in consumer pricing, limited innovation, and a lack of genuine competition.

Today, we call on the FCC to take bold action to restructure the wireless marketplace around a new model—one that embraces open infrastructure, wholesale networks, and a thriving MVNO ecosystem. With the right policy choices and regulatory support, the FCC can catalyze a more competitive, innovative, and consumer-friendly future.

Why the U.S. Wireless Market is Broken

Market concentration has made the U.S. wireless industry one of the least competitive among developed nations. Since the 2020 T-Mobile/Sprint merger, three major carriers have controlled over 93% of the market. As a result, U.S. wireless pricing remains among the highest globally, with American consumers often paying $14 per gigabyte while European consumers enjoy 80GB for under $10.

Spectrum—the essential input for wireless networks—is tightly controlled by incumbents who spent tens of billions in auctions. New entrants cannot compete with this capital intensity. Consumers suffer as these high costs are passed on in the form of inflated bills and limited service options.

The Burden of Capital Intensity

Traditional MNOs operate under an extraordinarily capital-intensive model. Between 2020 and 2021 alone, Verizon, AT&T, and T-Mobile spent over $63 billion on network infrastructure, not including another $90+ billion in recent spectrum auctions. These investments create natural barriers to entry that entrench the incumbents and discourage innovation.

New entrants cannot justify duplicating infrastructure. The cost of building out nationwide networks and securing exclusive spectrum rights is prohibitive. In this environment, innovation slows to a crawl. Carriers offer similar plans, similar devices, and similar service—because the structure of the market rewards sameness and punishes risk-taking.

Open RAN: A Path to Lower Costs and More Competition

There is a better way. Open Radio Access Network (Open RAN) technology enables disaggregated, interoperable, and software-driven networks. It breaks the vendor lock-in model of legacy telecom gear and reduces capital expenditures by up to 40% per cell site.

Operators such as Rakuten in Japan and 1&1 in Germany have demonstrated that Open RAN networks can be deployed at dramatically lower costs while delivering robust performance. These systems can be upgraded and optimized via software rather than costly hardware swaps. As Open RAN matures, it enables a modular, cloud-native network architecture well-suited to wholesale sharing and MVNO enablement.

Open RAN is the foundation for a more efficient, innovative, and competitive telecom market. And it aligns with U.S. industrial policy goals—diversifying the supply chain away from Chinese vendors and enabling American software and hardware companies to re-enter the telecom ecosystem.

The Promise of Wholesale Networks and MVNOs

A wholesale network model, combined with a flourishing MVNO ecosystem, can transform the U.S. wireless industry. In this model, a neutral-host operator builds and operates a cost-efficient Open RAN network and leases capacity to a diverse array of MVNOs.

MVNOs—retailers who buy network access wholesale and compete on service, price, and innovation—can drive real consumer choice. Yet today, they remain marginalized. They serve only about 10% of the market and are often throttled by incumbents who restrict wholesale pricing, throttle speeds, or buy them outright.

Since 2019, we’ve seen:

• Verizon acquire TracFone Wireless (~20M subscribers)

• Dish acquire Boost Mobile, Ting Mobile, Republic Wireless, and Gen Mobile

• T-Mobile acquire Mint Mobile and Ultra Mobile

These acquisitions reflect incumbents’ desire to control emerging competition, often stifling price disruption and innovation in the process.

Contrast this with Europe and Latin America, where strong pro-MVNO regulations have enabled dozens of providers to thrive, leading to lower prices and greater service diversity. A dynamic MVNO market is a key consumer protection—and a core source of innovation.

The Regulatory Path Forward

We urge the FCC to embrace a new regulatory model grounded in openness, competition, and innovation. Specifically:

1. Mandate Fair MVNO Access Require national MNOs to provide network access to MVNOs on fair, non-discriminatory terms. Enforce transparent wholesale pricing models that allow MVNOs to compete effectively.

2. Encourage and License Wholesale-Only Operators Promote the creation of neutral-host networks—especially in rural and underserved areas—using Open RAN infrastructure. Provide regulatory clarity and incentives to these entities.

3. Expand Spectrum Sharing and Leasing Models Build on the success of CBRS. Expand shared spectrum access across additional mid-band and upper-band frequencies. Simplify the rules for spectrum leasing, and allow flexible, low-cost access for wholesale operators.

4. Continue and Expand Open RAN Investment Fully fund the Public Wireless Supply Chain Innovation Fund and future grants to accelerate Open RAN deployments in rural America and emerging networks. Encourage standards and security protocols that are vendor-neutral and Open RAN-compatible.

5. Preserve and Monitor MVNO Diversity Evaluate all future mergers and acquisitions involving MVNOs under a competition-first lens. Prevent vertical integration that limits consumer choice.

Conclusion: A Call to Action

The U.S. consumer wireless industry can—and must—be reinvented. American households deserve lower prices, more choices, and next-generation innovation. We will not get there by doubling down on a 20th-century model of three vertically integrated giants. We need a new model: open, modular, and competitive.

The FCC has the authority and responsibility to shape this future. By catalyzing wholesale networks, protecting MVNOs, and embracing Open RAN, the Commission can unlock competition, lower consumer prices, and restore America’s leadership in wireless.

Respectfully,

Synthetic Wisdom Advocates for Open Wireless Markets