Sprint Corp. joined a range of small regional and rural wireless carriers and public interest groups late last week in voicing support for a petition for declaratory ruling, filed by T-Mobile US, that asks the FCC to provide guidance for assessing whether the terms of data roaming agreements meet the standard of “commercial reasonableness” promulgated by the FCC in the agency’s 2011 data roaming order. Filed in May, the petition highlights the “real world industry experience” of T-Mobile and other wireless operators in the wake of the 2011 order in which competitive carriers “continue to be stymied in their efforts to negotiate data roaming agreements on commercially reasonable terms.” According to T-Mobile, these problems are attributable “to certain ambiguities in the ‘commercially reasonable’ standard” that “could not have been foreseen” by the FCC when the data roaming rules were approved. In comments that respond to the petition, the Competitive Carriers Association (CCA) claimed that its members “continue to face significant difficulties in reaching data roaming agreements with the largest national carriers.” CCA thus asserted that “the need for effective data roaming obligations is greater than ever amidst the exploding demand for mobile data services and the further consolidation of . . . spectrum resources by the two largest providers,” as it termed the T-Mobile petition as “the proper procedural vehicle for providing additional guidance under current market circumstances.” Echoing the T-Mobile petition, Sprint advised the FCC that “three years of practical, real-world experience in implementing the data roaming rules make clear that industry confusion over its application exists,” adding that the “guidance T-Mobile seeks is necessary to remove this lingering regulatory uncertainty.” While endorsing the benchmarks for commercial reasonableness proposed by T-Mobile, the Rural Wireless Association urged the FCC to “be more specific as to what constitutes a commercially reasonable wholesale data roaming rate” and further recommended that the agency “require all carriers to confidentially file their wholesale roaming data agreements with the Commission.” AT&T and Verizon Wireless, however, asked the FCC to reject the T-Mobile petition on grounds that the data roaming marketplace is working as evidenced by the dozens of commercial agreements that have been negotiated successfully under the 2011 rules. On the basis of such agreements, AT&T charged that T-Mobile “has not cited a single instance where any provider anywhere in the country has found it necessary to file a complaint with the Commission alleging an inability to obtain commercially reasonable terms.” Verizon also warned that “any action by the Commission to place more prescriptive bounds on the rates a provider of mobile data services may charge . . . would risk turning the existing data roaming rule into a common carrier requirement.”