CALL TO ACTION – PLEASE SHARE WIDELY AND TAKE ACTION TODAY!
On March 27, 2026, the FCC released its “Report and Order” on WC Dockets 25-208 and 25-209, which paved the way for FCC preemption of state protections like COLR (Carrier of Last Resort) obligations in states like California, which have so far stood up to AT&T’s bullying and threats to dismantle landlines, especially in areas where they are the only means for reliable communication and thus critical for life-safety. The new rules also streamline the process for carriers like AT&T to retire copper and abandon customers if any of several so-called “alternatives” are in place, including alleged wireless coverage that the carrier does not even need to prove exists!
This is critical to understand – the FCC is not only streamlining the process, but also preventing states like California from protecting consumers via COLR rules, in a massive handout to carriers like AT&T. Specifically, this threatens any existing progress that has been made in California.
For a more detailed review of the impacts of the FCC order, see this analysis.
There are several things everyone can do now to take action!
Join Effort to Take Legal Action Against the FCC
We believe there is a basis for legal action against the FCC’s preemption of state protections; the FCC argues that they can preempt states from preventing carriers’s abilities to discontinue interstate and jurisdictionally mixed legacy services; however, local exchange service is generally a purely intrastate service, and thus states do have the legal right and precedent to regulate such matters. The FCC is overstepping its bounds and preventing states from performing their obligatory regulatory functions.
Time is of the essence and we need to act now. If you would like to support these efforts from a legal or financial perspective, please contact us.
Provide Feedback to the CPUC on its “COLR Revision” Staff Proposal
Although the CPUC denied AT&T’s application for COLR suspension in California, it did commit to reviewing and revising the COLR guidelines, which it has now done so in its Carrier of Last Resort and Network Modernization Staff Proposal (R.24-06-012). This proposal is a significant handout to industry by proposing elimination of critical service elements of basic voice service that would more easily allow carriers to fulfill their COLR obligations via alternative services to copper. The proposal also significantly de-emphasizes voice and shifts to focusing on broadband connectivity instead. Overall, the proposal significantly neuters the existing protections.
Here are some of the requirements the proposal would eliminate:
- Directory assistance requirements
- Free White Pages directory listing
- Telephone directories
- Operator assistance
- Basic local calling plans (the CPUC wants to force everyone to subscribe to a more expensive “all-calling” nationwide calling plan – many consumers cannot afford to pay for a long-distance plan, and would ultimately pay more under a “blended” all-calling plan, rather than only paying for basic local calling).
The CPUC is proposing eliminating these requirements to make it easier for carriers to use “alternative” services to fulfill COLR requirements – the CPUC themselves even acknowledges that many people do still use the services above – this is purely about making it easier for carriers to decomission traditional copper service. Traditionally, these are all elements of traditional landline service to ensure that all consumers have access to telecommunications services. The CPUC claims that people can “just look things up on the Internet” if directory assistance and directories are eliminated – they of all regulators ought to know this is not true for everyone! Additionally, their proposal makes it more likely people would end up without reliable Internet service either:
The proposal would also adopt a basic 100/20 definition of “basic broadband service”, which would effectively eliminate DSL as an option for providing broadband under COLR. This is a direct handout to carriers like AT&T that want to retire copper. While DSL may be slower than broadband options such as cable or fiber, if it is often the only broadband option available in many areas – eliminating DSL would severely worsen the Digital Divide – many AT&T customers who have had their DSL eliminated have been forced onto unreliable/inferior wireless alternatives.
Provide feedback to the CPUC opposing these changes!
- There are opportunities to provide public comments during their monthly public meetings (upcoming meetings at 11am Pacific: April 30, May 14, June 11, July 2, July 16, August 13). The dial-in is (800) 857-1917, PIN is 9899501#. Please note that only 1 minute is allotted for each comment, so be succinct to ensure you get your message across without being cut off.
- Email your comments to public.advisor@cpuc.ca.gov
- Call 866-849-8390 to provide comments to the Public Advisors office by phone
In addition to objecting to the Staff Proposal, please also urge the CPUC to take legal action against the FCC for its preemption of regulation of intrastate services in the Report and Order mentioned above.
File Objections with the FCC of any “Streamlining” of Copper Retirement
The FCC has moved the burden of proving the existence and suitability of a copper replacement technology from the carrier to the consumer (that’s you!). If you have received a notice that copper retirement is planned in your area, you have the right to object to the FCC. They need to hear directly from consumers that so-called “alternatives” are not acceptable or sufficient for life safety and reliable communications in your area.
Under the FCC’s report and order, carriers are no longer required to file notices with the FCC; however, they are still required to provide public notice – here are where the larger incumbent LECs (RBOCs) provide notice online – check frequently for impacts to your area!
When you file an objection, the FCC will remove the application from “streamlining” (automatic approval) and perform a review. This is not a guarantee that the FCC will deny the application, but it helps and adds friction to carriers wanting to decommission landlines without consumer input.