Skip Navigation

Federal Communications Commission

English Display Options

Commission Document

PN Seeks Comment on T-Mobile's Petition Regarding Roaming

Download Options

Released: June 10, 2014


Federal Communications Commission

445 12th St., S.W.

News Media Information 202 / 418-0500


TTY: 1-888-835-5322

Washington, D.C. 20554

DA 14-798

Released: June 10, 2014




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: or the Federal eRulemaking Portal:

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, 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

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

available for viewing via the 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

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.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).

Participants in

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,

Action by the Wireless Telecommunications Bureau.

- FCC -


Note: We are currently transitioning our documents into web compatible formats for easier reading. We have done our best to supply this content to you in a presentable form, but there may be some formatting issues while we improve the technology. The original version of the document is available as a PDF, Word Document, or as plain text.


You are leaving the FCC website

You are about to leave the FCC website and visit a third-party, non-governmental website that the FCC does not maintain or control. The FCC does not endorse any product or service, and is not responsible for, nor can it guarantee the validity or timeliness of the content on the page you are about to visit. Additionally, the privacy policies of this third-party page may differ from those of the FCC.