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That may be so. But they have a long, long way to go before signals are anything more than patchy. Still, I don't particularly want people yammering like idiots on their phones while I try to snooze on the way to work.
Mostly because so many stations are close to the surface, in my experience. Much of NY subway is cut and cover and not far below surface level. More accident than design for the wifi, I think. NYC does not do 'nice things' for its residents. Every little bit has to be fought for, tooth and nail.