Fw: [savelandlines] Digest of FCC actions required

[isis...@yahoo.com]

Please see urgent actions to be taken by Tuesday, May 26:


----- Forwarded Message -----
From: Wireless Action <wireles...@interlinked.us>
To: Save Landlines <savela...@groups.io>;
Sent: Friday, May 15, 2026 at 02:27:06 PM PDT
Subject: [savelandlines] Digest of FCC actions required

Here is an updated version of my "FCC digest" concerning everything
going on from an FCC perspective.

Earlier this week, I forgot to include mention of WC Docket 25-311, to
which initial comments are due on May 26. That is the new item included
below. I urge everyone to submit comments to the FCC on this docket.
Last docket (25-304), there were four comments from the public and all
the others were from industry. We need to flood the docket with dozens,
even hundreds of comments, from consumers making it clear that we do not
want the IP transition and we do not consider the FCC's "alternatives"
to be genuine alternatives. See below.

*** Digest of FCC actions ***

Action required:

1. There is urgent need to legally challenge the FCC's March 27 order
for WC Dockets 25-209 and 25-208, which preempts state protection of
landlines (see https://docs.fcc.gov/public/attachments/FCC-26-19A1.pdf).
It's possible there are as little as two weeks left to challenge the
decision. Reach out to your state attorney generals to take action
(https://www.naag.org/find-my-ag/), as well as any organizations and law
firms who work on related issues. Please share with us if you have any
leads on this. It is now or never. If we fail, even the CPUC will
permanently be powerless to stop AT&T, it all comes down to this! If you
are reading this and this is the only thing you do, please do
*something* to try to help on this front, this means you!

For California Attorney General, call 1-800-952-5225 or (916) 210-6276,
press 1 for English, then press 7 to leave a message for the Atty General.

Please see:
https://savelandlines.org/2026/04/19/landlines-threatened-nationwide-by-fcc-take-action-now/

2. There is a similar IP interconnection docket open, focused on
intercarrier compensation:
https://www.fcc.gov/document/fcc-explores-updates-intercarrier-compensation-regime-0

This is an industry piece that is demeaning towards copper, but it does
provide a somewhat accessible overview of some of the background to this
NPRM:
https://truthonthemarket.com/2026/03/18/subsidizing-obsolescence-how-fcc-rules-keep-copper-alive/

Even though this is focused on industry (eliminating intercarrier
compensation), this is part of the overall series of dockets on
"Advancing IP interconnection" and sunsetting TDM-based services such as
POTS nationwide. Here are some questions the FCC directly poses in its
NPRM - consumers like YOU need to respond to make your voice heard!

- Even though this is focused on industry (eliminating intercarrier
compensation), this is part of the overall series of dockets on
"Advancing IP interconnection" and sunsetting TDM-based services such as
POTS nationwide. Here are some questions the FCC directly poses in its
NPRM - consumers like YOU need to respond to make your voice heard!
- 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?

I have put a draft of my comments (not yet submitted) for Docket 25-311
here:
https://files.interlinked.us/fcc/Intercarrier%20Compensation%20Comments.pdf

Due to my telecom background, I focus on all the major issues head-on,
but I encourage all of you to make your voices heard, even by simply
answering some of the questions above for the FCC, so they can hear
directly from consumers that people DO value traditional voice service
and do NOT consider the "alternatives" to be sufficient and DO NOT WANT
regulations dismantled. Everyone can write something and submit, you do
not need to be an expert! Please take the time to do so now.

As always, any questions or anything I can clarify, please let me know.



Other action possible:

1. The March 27th FCC hearing's impacts are already here. AT&T has
submitted an application to discontinue legacy voice service as part of
a technology transition, due to road work in affected areas. Public
comments are due May 26:
https://docs.fcc.gov/public/attachments/DA-26-459A1.pdf
    1. The application (under the new rules adopted March 27) will be
automatically granted on June 11, unless the Commission rules otherwise
(i.e. due to public opposition)
    2. This affects service in 39 wire centers (228 residential and 8
business customers in South Carolina, Alabama, Indiana, Florida,
Alabama, Kansas, Arkansas, Oklahoma, Texas, Missouri, Wisconsin, Ohio -
affected customers were notified in March). See application in Docket
26-98: https://www.fcc.gov/ecfs/document/10423431321757/1
2. The FCC consumer protection and accessibility advisory committee is
meeting on Wednesday, June 10, at 1pm EDT, available remotely at
https://www.fcc.gov/live. Public questions/comments may be submitted by
email to livequ...@fcc.gov *during* the meeting. See:
https://docs.fcc.gov/public/attachments/DA-26-458A1.pdf - opportunity to
have your voice heard on how the FCC Is dismantling regulatory protections
3. On July 15/16, there will be an industry workshop to discuss the
"reforms" to IP interconnection, intercarrier compensation, etc.
Although designed for industry, the workshop is free and open to the
public. It will be streamed online, but I believe you need to be in
person at the FCC HQ to participate. I will plan to attend and represent
our interests. See: https://docs.fcc.gov/public/attachments/DA-26-428A1.pdf

No action required (or possible), informational only:

1. An industry contract shared this notice that Verizon has sent to
CLECs. I don't know currently if this only affects their CLEC customers
or all of them: Verizon will discontinue DA service on a rolling
state-by-state basis beginning on or about November 2, 2026 and ending
in or about April 2027. Once DA service has been discontinued in a
state, customers in that state who have not arranged for an alternative
to Verizon DA service will receive a busy signal when they dial 411.
Verizon will not charge its wholesale customers for such calls.
Facilities-based carriers should note, however, that their systems may
trigger billing to their customers for such calls unless corrective
action is taken. Please note that the discontinuation of DA service will
not affect our offering of directory listings.
2. The FCC periodically publishes reports on voice and Internet
subscription statistics. The data here is as of June 2025, but the
reports were just published and folks here may find them interesting. I
think the data is very straightforward to interpret, but if anyone has
questions, I'm happy to clarify meaning.
    1. Voice report:
       https://docs.fcc.gov/public/attachments/DOC-421558A1.pdf
    2. Internet report:
       https://docs.fcc.gov/public/attachments/DOC-421557A1.pdf
        1. I do find the FCC's definition of "Internet" as being 200
kbps minimum problematic. Not broadband, but Internet. If you use
dial-up, you don't even exist anymore, according to the FCC.