The Roaming Marketplace is Working

T-Mobile, which advertises itself as the “un-carrier,” has asked the Federal Communications Commission to “un-do” its data roaming rules, which were established in 2011 to facilitate reasonable data roaming arrangements while continuing to incent network investments.

T-Mobile now asks for a “declaratory ruling” which would effectively eviscerate that FCC decision and run afoul of the DC Circuit case which upheld it. There is no justification for granting T-Mobile’s petition -- in fact, according to T-Mobile’s own economist, wholesale roaming rates have trended “downward strongly” in recent years, and the average wholesale roaming rates paid by T-Mobile have fallen nearly 70 percent since 2011 and continue to decline.

There is also evidence that commercial negotiations are producing a variety of terms to meet differing needs, including the highly-touted LTE roaming hub T-Mobile’s own trade association (CCA) has established with scores of rural carriers to “help Sprint and T-Mobile fill the holes in their network[s].”