The head of the FCC’s wireless bureau fired a wide range of questions at Dish Network about the carrier’s wireless network buildout plans. Importantly, the FCC’s Donald Stockdale stated that “I am contacting you to request updates and more detailed information on your buildout plans for the 53 megahertz of low- and mid-band spectrum that is apparently lying fallow in these bands.”

The implication of Stockdale’s questions is that the FCC may begin to take action against Dish for collecting spectrum licenses but not using them. In his letter to Dish, Stockdale noted that Dish told the FCC earlier this year that it had not met the applicable interim construction deadline for its AWS-4 licenses, its 700 MHz Lower E Block licenses and its H Block licenses.

As a result, Stockdale asked Dish to provide a wide range of specifics about how exactly it will build out a wireless network using its vast spectrum holdings. Stockdale asked for details on Dish’s buildout plans, technology choices, coverage area plans, handset strategies, and any additional delays that the company may encounter as it runs up against the FCC’s spectrum license buildout requirements.

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In February, Dish said it will spend between $500 million and $1 billion through 2020 building out the “first phase” of its wireless network. The company said it would deploy an NB-IoT network initially and would potentially build out a 5G network later as standards for that network are made available.

Dish’s Charlie Ergen—a FierceWireless rising star this year—subsequently attended the Wireless Infrastructure Association’s (WIA) trade show in May and offered additional details about Dish’s NB-IoT and 5G network buildout plans. “We’re now going to spend at least $10 billion or more on a 5G network. We don’t have that kind of capital on our balance sheet today,” Ergen said in May. But he said that Dish plans to operate like a startup in the wireless industry, much like it did when it entered the satellite TV business several decades ago, in its drive to cash in on 5G.

Importantly, the day before his appearance at the WIA show, Ergen visited Washington, D.C., to update regulators on Dish’s buildout plans. Stockdale, in his new letter to Ergen, added that Ergen and other Dish executives also visited the FCC in June to discuss the company’s plans.

“Mr. Ergen and representatives of DISH, among other things, stated that they plan to deploy their network in two phases: in phase 1, DISH would deploy a narrowband Internet of Things (IoT) network using its AWS-4, 700 MHz E Block, and H Block licenses; and in phase 2, DISH would deploy using its other spectrum holdings, and would ‘upgrade and expand [its] network to full 5G to support new use cases in addition to mobile broadband services.’ They also discussed plans to: (1) take delivery of network equipment and begin installation of the network this year, and (2) delay the completion of its phase 2 deployment in low- and mid-band spectrum until after 600 MHz spectrum is cleared on a nationwide basis in July 2020.”