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Proposal to Streamline Part 20 Rules Could Have Big Implications, T-Mobile Says

T-Mobile warned that an FCC proposal to streamline Part 20 rules (see 1610170056), released last summer, may be more substantial than some expect. This proceeding's intent is merely to “streamline and update” rules, but the proposed elimination of Section 20.7(h)…

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of the regulations “may be interpreted as a substantive change,” T-Mobile said. Representatives of the carrier recently met with FCC staffers, said a filing in docket 16-240. “Section 20.7(h) contains an interpretation of what does not constitute a mobile service (i.e., a service with devices authorized under Part 15 of the Commission’s rules) not found elsewhere,” the filing said. “Elimination of the rule could therefore be misinterpreted to suggest that services provided to devices authorized under Part 15 may be mobile services, even though the stated intent of the proceeding is not to implement any rule changes, but rather to clear away unnecessary regulatory clutter.”