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NTCH Petition on Publication of Inter-Provider Roaming Rates

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Released: July 14, 2014


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 14-997

July 14, 2014




RM-11723; WT Docket No. 05-265

Comment Date: August 18, 2014

Reply Comment Date: September 15, 2014

On July 2, 2014, NTCH, Inc. (Petitioner), filed a petition seeking Commission action to “rescind

the blanket forbearance of the rate publication requirement for roaming rates offered by CMRS carriers”

and to “[a]mend Section 20.15(b) of the rules to delete the CMRS exemption from filing roaming rates,

whether for data roaming or voice roaming.”1 Petitioner also asks the Commission to “[a]dopt a rule

requiring CMRS providers and Commercial Mobile Data Service providers to make their roaming rates

publicly and openly available on line” and to “[p]rohibit CMRS and Commercial Mobile Data Service

providers from entering into or enforcing agreements that prevent disclosure of roaming rates.”2

In this

Public Notice, we seek comment on the Petition.

Interested parties may file comments and reply comments on the above Petition on or before the

dates listed on this Public Notice. All pleadings must reference RM-11723 and WT Docket No. 05-265.

Parties may file comments using (1) the Commission’s Electronic Comment Filing System (ECFS), (2)

the Federal Government’s eRulemaking Portal, or (3) by filing paper copies.3

Electronic Filers: Comments may be filed electronically using the Internet by accessing the

ECFS: or the Federal eRulemaking Portal: Filers should follow the instructions provided on the website for

submitting comments.

1 Petition of NTCH, Inc. to Rescind Forbearance and Initiate Rulemaking, WT Dkt No. 93-252 (filed July 11, 2014)

(Petition). We note that this Petition replaces the petition filed on November 22, 2013 by the NTCH on the same

issue, thus rendering the previous petition moot. See Petition of NTCH, Inc. to Rescind Forbearance from

Application of Section 211 of the Communications Act of 1934, WT Docket No. 93-252 (filed Nov. 22, 2013).



3 See Electronic Filing of Documents in Rulemaking Proceedings, Report and Order, GC Docket No. 97-113, 13

FCC Rcd 11322 (1998).


When completing the transmittal screen, filers should include their full name, U.S. Postal Service

mailing address, and the applicable docket or rulemaking number. Parties may also submit an

electronic comment by e-mail. To get filing instructions, filers should send an e-mail to, and include the following words in the body of the message, “get form.” A sample

form and direction will be sent in response.

Paper Filers: Parties who choose to file by paper must file an original and one copy of each


Send filings by hand or messenger delivery, by commercial overnight courier, or by first-class or

overnight U.S. Postal Service mail. Address filings to the Commission’s Secretary, Office of the

Secretary, Federal Communications Commission.

Deliver hand-delivered or messenger-delivered paper filings to FCC Headquarters at 445 12th St.,

S.W., Room TW-A325, Washington, D.C. 20554 between 8:00 AM and 7:00 PM. Use rubber

bands or fasteners to hold deliveries together.

Dispose of all envelopes before entering the


Send commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail)

to 9300 East Hampton Drive, Capitol Heights, M.D. 20743.

U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street,

SW, Washington D.C. 20554.

Parties are requested to send one copy of their comments and reply comments to Best Copy and

Printing, Inc., Portals II, 445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, (800) 378-

3160, e-mail

The Petition, and comments and reply comments filed in response to this Public Notice are

available for viewing via the ECFS,, by entering RM-11723. The documents

also will be available for public inspection and copying during business hours in the FCC Reference

Information Center, Portals II, 445 12th Street, S.W., Room CY-A257, Washington, D.C. 20554. They

may also be purchased from Best Copy and Printing, Inc., telephone (800) 378-3160, facsimile (202) 488-

5563, TTY (202) 488-5562, e-mail

Alternate formats of this Public Notice (computer diskette, large print, audio recording, and

Braille) are available to persons with disabilities by contacting the Consumer & Governmental Affairs

Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY), or send an e-mail to

This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with

the Commission’s ex parte rules. Persons making ex parte presentations must file a copy of any written

presentation or a memorandum summarizing any oral presentation within two business days after the

presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral

ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all

persons attending or otherwise participating in the meeting at which the ex parte presentation was made,

and (2) summarize all data presented and arguments made during the presentation. If the presentation

consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s

written comments, memoranda or other filings in the proceeding, the presenter may provide citations to

such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant



page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them

in the memorandum. Documents shown or given to Commission staff during ex parte meetings are

deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In

proceedings governed by rule 1.49(f) or for which the Commission has made available a method of

electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,

and all attachments thereto, must be filed through the electronic comment filing system available for that

proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in

this proceeding should familiarize themselves with the Commission’s ex parte rules.

For further information, please contact William Beckwith, Wireless Telecommunications Bureau,

Spectrum and Competition Policy Division, at (202) 418-0134 or via email at

Action by the Wireless Telecommunications Bureau.

- FCC -


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