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, where residents 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.
Submit Comments to FCC on WC Docket 25-311 (Reforming Legacy Rules for an All-IP Future)
While this docket is somewhat technical and targeting industry, the FCC needs to hear directly from consumers that consumers DO value landlines and that their so-called “alternatives” are not functionally equivalent alternatives for switched wireline service.
See docket: https://www.fcc.gov/document/fcc-explores-updates-intercarrier-compensation-regime-0
Initial comments are due to the FCC by May 26th. Reply comments due June 22nd. Write and submit your comments NOW!
You can submit a filing on this docket (25-311 and 25-208) here. You can view existing submissions on this docket here.
Here are examples of questions or statements the FCC poses in the FCC, many of which need to be corrected to set the record straight in your comments!
- The growing reliance on alternatives to traditional switched access voice services such as mobile voice service and VoIP appears to indicate that consumers increasingly view voice services as interchangeable, regardless of the underlying technology. The prevalence of mobile-only households further underscores this shift. These trends suggest that the voice services marketplace has evolved into a technology-neutral environment… Should we adopt a technology-neutral approach when defining the voice services marketplace for purposes of determining the number of competitive alternatives in a particular area? To what extent do consumers view mobile, VoIP, and other IP-based voice services as substitutes for TDM-based service? Are there any remaining distinctions between voice service types that are meaningful from a consumer perspective?
- According to the FCC: “Traditional switched access voice service has a significantly narrower functional scope than broadband, mobile, or satellite services, and lacks the capability to replicate the broader data transmission offerings those services provide. For example, while one may place a mobile wireless call from the same location as a fixed landline, one cannot place a call on a landline while roaming. Accordingly, from the consumers’ perspective, mobile voice service may be considered as a potential substitute for switched access service; however, switched access—offering inferior performance over outdated technology—cannot reasonably to be regarded as an effective substitute for mobile voice service.”
- If continued tariffing of access charges is necessary to protect consumers following the transition to bill-and-keep, why? Is forbearance from tariffing consistent with the public interest? For example, would forbearance from tariffing switched access services promote competitive market conditions? Does tariffing access charges create disincentives for carriers to transition from TDM to all-IP networks? To what extent does tariffing access charges impose unnecessary regulatory burdens on carriers? Would detariffing access charges reduce compliance costs, increase regulatory flexibility, increase incentives to invest in innovative products and services, or otherwise be in the public interest?
- “To facilitate the transition to a bill-and-keep framework and ensure that carriers can recover their costs from end users, we propose to eliminate ex ante pricing regulation and tariffing requirements of all end-user charges associated with interstate access service offered by incumbent LECs. These end-user charges, known as Telephone Access Charges (TACs), are remnants of legacy telephone regulation when LECs were subject to comprehensive rate oversight designed to protect subscribers from supracompetitive prices. The regulations were intended to protect consumers from the monopoly power of incumbent LECs and ensure that rates were just and reasonable, as required by the Act. However, with the growth of competition in the voice services market, rate regulation of incumbent LECs is no longer necessary to protect consumers—who now have the ability to switch to alternative providers if an incumbent LEC raises rates above competitive levels” [This is not true with POTS!; you do not have alternative to the ILEC for that – emphasize you DO NOT have the ability to switch to an alternative provider for equivalent service]
- “In 2016, the Commission examined the voice services marketplace and observed that “[t]here has been an indisputable ‘societal and technological shift’ away from switched telephone service as a fixture of American life.” The Commission’s conclusion is even more true today, given the proliferation of non-switched access voice service alternatives in the marketplace. As carriers transition to all IP-network services in an increasingly competitive marketplace, voice service will become one of many applications on that network”
- IP-based and mobile voice services have experienced significant growth in recent years. Does this suggest that these services are more efficient than traditional TDM-based offerings? Or is this growth due more to consumer preference for modern technologies? Or is it combination of both factors? To what extent does the ICC regulatory structure distort competition and delay technological transition?
- To what extent do customers still purchase dial-around 1+ services from IXCs subject to tariff?
- To what extent is the distinction between local and long-distance service relevant to consumers?
- To what extent do business and residential customers currently purchase stand-alone long-distance service from presubscribed IXCs? To what extent do business and residential customers currently purchase long distance service from an IXC unaffiliated with their LEC? To what extent do customers designate an IXC to the LEC?
- Are there sufficient competitive alternatives to TDM-based interexchange service in rural and high cost areas such as wireless and satellite?
- What effect, if any, will the IP transition have upon providers that maintain their networks using TDM technology? Are any consumers at risk of large price increases for service as a result of the transition to bill-and-keep? If so, which consumers, and why, and are alternative voice services available to those consumers?
- While competitive forces may encourage providers to maintain and improve standards to attract and retain customers, we seek comment on if market forces alone are enough to ensure that consumers receive reliable and high-quality voice service. We seek comment on whether and, if so, how the Commission should consider additional oversight of service quality and availability standards for voice calls transmitted over IP networks. If the Commission were to adopt additional oversight, what aspects of service quality and availability should be subject to minimum standards (e.g., call completion rates, reliability, latency, and accessibility)? What metrics or performance benchmarks would be appropriate to evaluate compliance with such standards? Are the Commission’s current rules that prescribe service quality and availability standards adequate, or even necessary, for IP networks? Does IP-based calling inherently provide the call quality that the Commission would otherwise require from providers, obviating the need for prescriptive standards?
- Will the proposed rule changes accelerate the IP transition, and if so, how will this benefit consumers? [Just the opposite – comment on how this will HARM some consumers]
- Will consumers face increased costs or other nonmonetary burdens as a result of the proposed rule changes? If so, please explain fully. What market effects or additional costs, if any, would be imposed on end users if some end users choose to discontinue their existing wireline voice service in response to rate changes or changes to offerings? What share of those customers are likely to take advantage of voice service offered via wireless or other IP-based voice providers? How do rates for mobile voice and VoIP-based services compare to current rates for traditional PSTN service? What upfront expenses or logistical hurdles, such as sign-up fees or equipment requirements, do consumers face when transitioning to alternative voice services? What should consumers expect from the long-term effects of the proposed rule changes and the costs they face for continuing to use switched access voice calling service?
- We believe that a thoughtful transition of all remaining access charges to bill-and-keep will lead to more efficient telecommunications networks to serve consumers. We seek comment on this belief and general comment on how providers’ market incentives will change as they complete the transition of remaining access charges to bill-and-keep. Are there other reasons that carriers may need to maintain and prolong the use of legacy TDM networks which we have overlooked? Are there any access services that would continue to offer utility in an all-IP network? If so, what are they, and why?
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.
Send your own email opposing SB 649 To: Angela.mapp@asm.ca.gov
Protest AT&T’s Threats to Destroy our Safe and Reliable Landline Telephone Service
Save Landlines! 