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STATEMENT OF
COMMISSIONER MIGNON L. CLYBURN
Re: Reexamination of Roaming Obligations of Commercial Mobile Radio Service Providers 
and Other Providers of Mobile Data Services, WT Docket No. 05-265.
In Section 706 of the 1996 Telecommunications Act, Congress directed the Commission 
to encourage the deployment of advanced communications services to all Americans by using 
measures that promote competition in local markets.  Last year, the Fourteenth Mobile Services 
Report estimated that more than 10 million Americans still live in rural census blocks with two or 
fewer mobile service providers.  The Report also explained that roaming is a critical component 
of the structure of the mobile services market because it permits competitors to enter hard to serve 
areas.  With today’s Data Roaming Order, the Commission takes an important step to ensure that 
the structure of the mobile data services market advances Section 706’s goals and improves the 
ability of carriers to offer more rural Americans the competitive choices other Americans enjoy.    
This Order also safeguards consumers’ reasonable expectations in mobile wireless 
communications, wherever they travel in the country, or however they choose to communicate.  
In the early history of the wireless market, consumers expected seamless service in mobile voice 
and text services.  Trends suggest that this expectation will extend to the most advanced IP-based 
broadband services.  In 2008, 25 million Americans subscribed to mobile broadband service.  
That number is now over 70 million.  Between 2008 and 2009, the percentage of smart phones 
that accounted for the number of handsets sold, rose from 27 to 44 percent.  Over the past few 
years, the percentage of Americans, who solely rely on mobile services for their communications 
needs, has risen to over 25 percent. 
To be sure, this growing demand for seamless mobile broadband services is due to 
investment and innovation in networks, handsets, and applications.  But it is also due to wireless 
companies spending millions, and in some cases billions, on marketing campaigns to persuade 
consumers why they offer more advanced services over larger geographic areas of the country 
than their competitors.  Wireless carriers have now shifted the focus of their marketing campaigns 
from voice quality to 3G and 4G network quality, coverage, and reliability.
One thing we do not hear these marketing campaigns mention however, is that roaming is 
an important reason why companies can even boast of offering nationwide coverage.  No single
wireless carrier has built out its entire licensed service area.  Therefore, to fill gaps in their 
coverage, all carriers must potentially roam on networks that other, non-affiliated, companies 
built.   
Some argue that the prevalence of roaming agreements for 2G services means a roaming 
requirement is not necessary for mobile broadband services.  I disagree.  Some of the opponents 
to this Order are companies, who over the past few years, have merged with several of their 
roaming partners.  Those mergers mean the number of potential roaming partners for their 
competitors has dropped.  The fact that these merged companies oppose a mobile broadband 
service roaming rule suggests to me that they might use their increased market power to 
unreasonably restrict consumer access to competitive alternatives.  In fact, as the Order points 
out, a number of these companies resisted offering 3G mobile broadband roaming agreements to 
their competitors until just recently.  That strategy may serve their companies’ interests.  But 
when an increasing number of Americans are choosing to rely solely on mobile service for their 
communication needs, and demanding more smart phones with mobile broadband service, these 
roaming restrictions do not serve the public interest.
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Austin Schlick, Ruth Milkman, and their staffs, have done an excellent job explaining 
why the Commission has statutory authority under Title III, as well as Section 706, to impose 
roaming obligations on commercial mobile data services.  As the item explains, the Commission 
will continue to monitor roaming in the mobile wireless market.  If we continue to find problems, 
we may have to consider additional measures.