Ex Parte Filing Re: Mobile Roaming Rules
While not having certain service in some locations is difficult, it would be even more frustrating to have service one day and have it taken away the next. To yank away the roaming rights of new entrants after an arbitrary one year period, a time period that provides the new entrant with no realistic opportunity to build its own network, would be extremely arbitrary and cause consumers to feel that they are the victims of a “bait-and-switch” tactic.
Spectrum Policy Reform, Wireless Future Program
Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554
RE: Notice of Ex Parte Filing
WT Docket No. 05-265, Reexamination of Roaming Obligations of Commercial
Mobile Radio Service Providers
Dear Secretary Dortch:
Public Knowledge, on behalf of the Ad Hoc Public Interest Spectrum Coalition (PISC)submits this ex parte filing to urge the Commission to eliminate the in-market or home exception to its mobile roaming rules so that wireless consumers may receive uninterrupted mobile service when they are outside their provider’s coverage area, regardless of the spectrum band on which their wireless provider operates. If the Commission insists on terminating the roaming rights of wireless providers at some point in the future, we urge the Commission to protect the roaming rights of wireless providers until the host provider seeking to deny roaming to another carrier’s subscribers can meet the burden of demonstrating that eliminating roaming rights will not harm wireless consumers.
For the full document, please see the attached PDF file below.












