PN Seeks Comment on T-Mobile's Petition Regarding Roaming
Federal Communications Commission
445 12th St., S.W.
News Media Information 202 / 418-0500
Washington, D.C. 20554
Released: June 10, 2014
WIRELESS TELECOMMUNICATIONS BUREAU SEEKS COMMENT ON PETITION FOR
EXPEDITED DECLARATORY RULING FILED BY T-MOBILE USA, INC. REGARDING
DATA ROAMING OBLIGATIONS
WT Docket No. 05-265
Comments Due: July 10, 2014
Reply Comments Due: August 11, 2014
On May 27, 2014, T-Mobile USA, Inc. (“T-Mobile”) filed a petition for an expedited declaratory
ruling that would provide guidance on the criteria used for determining whether the terms of a data
roaming agreement meet the “commercially reasonable” standard set forth in the data roaming rule in
Section 20.12(e) of the Commission’s rules.1
Section 20.12(e) requires facilities-based providers of
commercial mobile data services to offer roaming arrangements to other such providers on “commercially
reasonable terms and conditions.”2
T-Mobile contends that providers need this guidance to evaluate the
commercial reasonableness of terms offered in individual negotiations and to reach agreements. 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 the first page of this Public Notice. All pleadings must reference 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: File comments electronically using the Internet by accessing the ECFS:
Filers should follow the instructions provided on the website for submitting comments.
1 47 C.F.R. § 20.12(e); see T-Mobile USA, Inc., Petition for Expedited Declaratory Ruling Regarding
Reexamination of Roaming Obligations of Commercial Mobile Radio Service Providers and Other Providers of
Mobile Data Services, WT Docket No. 05-265 (filed May 27, 2014) (“Petition”).
2 47 C.F.R. § 20.12(e).
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
email@example.com, and include the following words in the body of the message, “get form.” A sample
form and directions 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 building.
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.
Send U.S. Postal Service first-class, Express, and Priority mail to 445 12th Street, S.W.,
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 FCC@BCPIWEB.com.
The Petition, and comments and reply comments filed in response to this Public Notice are
available for viewing via the ECFS, https://www.fcc.gov/cgb/ecfs, by entering WT Docket No. 05-265.
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 FCC@BCPIWEB.com.
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 firstname.lastname@example.org.
This proceeding has been designated as a “permit-but-disclose” proceeding in accordance with
the Commission's ex parte rules.4
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
4 See 47 C.F.R. §§ 1.1200(a), 1.1206.
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).
this proceeding should familiarize themselves with the Commission’s ex parte rules.
For further information, contact Jennifer Salhus of the Wireless Telecommunications Bureau,
Spectrum & Competition Policy Division, (202) 418-2823, Jennifer.Salhus@fcc.gov.
Action by the Wireless Telecommunications Bureau.
- FCC -
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