Data roaming agreements are difficult to obtain, are rarely reasonable, and rarely include 3G

The Rural Telecommunications Group (RTG) submitted a letter today in response to a recent Verizon Wireless (Verizon) ex parte in which Verizon argues that proponents of data roaming have failed to show that market forces are not working.

While Verizon states that it has 65 roaming partners, it fails to assert how many of these roaming partners have access to data roaming. Verizon also claims that it is more than willing to enter into data roaming agreements with other carriers and purports to provide “evidence” of Verizon’s willingness to enter into and launch data roaming agreements with other domestic wireless carriers. Verizon’s letter does nothing to refute the fact that inter-carrier domestic data roaming agreements with Verizon are:

1. difficult to obtain;
2. rarely, if ever, on reasonable terms; and
3. rarely include (3G) EVDO.

Verizon’s claim that almost one third of its roaming partners either have not requested data roaming or made initial inquiries but then stopped actively seeking data roaming is in no way evidence of a fully functioning roaming marketplace nor of Verizon’s willingness to enter into data roaming agreements. Verizon ignores the many instances where small and rural carriers have stopped pursuing data roaming agreements because Verizon has said “no” or priced the services in a manner that effectively means “no”.

Verizon says it “will offer 4G data roaming to participants in its LTE in Rural American