There are currently multiple, parallel efforts underway to heavily deregulate and aggressively phase out landline service in many parts of the country right now. Many people will be left with no reliable alternatives, including for emergencies and 911 access, especially during prolonged power outages. Your immediate action is needed to try to prevent this.
WHAT: In its Report and Order on "Reducing Barriers to Network Improvements and Service Changes" (WC Dockets 25-209 and 25-208), adopted March 26th, the Federal Communications Commission asserted that state rules such as COLR (Carrier of Last Resort) obligations were subject to preemption for conflicting with the federal agenda to eliminate copper POTS lines nationwide.
IMPACT: Because the FCC claims it can preempt state rules (though this of highly questionable authority and legality), it means that even in states like California, whose COLR requirements aim to ensure that all consumers have access to some level of communications, the state could be unable to enforce these requirements. In other words, the FCC is attempting to unilaterally prevent all state public service commissions from protecting consumers by imposing roles requiring a minimum level of service. Even though the California Public Utilities Commission (CPUC) has previously denied AT&T the ability to discontinue service in California, AT&T is now looking to the FCC to preempt the CPUC from protecting landline service.
For a more detailed analysis of the impact of this order, see this more detailed analysis (linked).
ACTION: There is urgent need to legally challenge this FCC order. We are seeking legal support to challenge this FCC decision and need your help to refer organizations and law firms who would be willing to help (preferably pro-bono), or possible funding sources. If you are able to help or have suggestions, please contact us.
WHAT: On May 20, AT&T sued the California Public Utilities Commission and California Attorney General for requiring AT&T to continue providing landline service to ensure all Californians continue to have access to reliable voice service. AT&T argues the CPUC's rules are preempted by the FCC (see item #1). For more details, see:
AT&T has already filed notices with the FCC they intend to proceed with disconnection of 199,000 customers in California. They have already sent out notices like this one to these 199,000 customers in parts of California, grandfathering service on July 19 and discontinuing on or after June 1, 2027. Due the NPRM from #1, discontinuances are automatically granted unless the FCC reviews and determines otherwise after public protest.
IMPACT: AT&T is now looking to the FCC for approval to discontinue service to hundreds of thousands of Californians following the FCC's assertion of preemption of state rules (see #1). This bypasses the CPUC by seeking relief from the courts and the FCC. They have already notified 199,000 customers they plan to discontinue their service by June 2027 pending the assumed approval by the FCC. Roughly 200,000 Californians stand to lose reliable phone service if action is not taken against AT&T and the FCC now.
ACTION:
Submit comments protesting the AT&T petitions to the FCC on the pertinent dockets (AT&T's petitions to disconnect 199,000 customers and get forbearance from ETC/Lifeline). Comments are due June 22. Reply comments are due July 7. Everyone (especially in California) needs to file comments to the FCC — this is the only formal way of protesting AT&T's plans to discontinue service and force the FCC to not automatically grant the application. Particularly emphasize how AT&T's and the FCC's "alternatives" (e.g. wireless, VoIP, satellite, etc.) are not accessible or functional for you (the FCC has shifted the burden to consumers to prove that "alternatives" are not viable or functional in their area). Tell all your family members, neighbors, friends, etc. to likewise submit comments on these dockets. If you have Lifeline service, also object to AT&T's plans to discontinue Lifeline service.
To submit protest comments to the FCC, upload a PDF of your comments to the ECFS or use ECFS Express Filing to submit a text comment online. Include proceedings 26-125 and 26-123 as these are the dockets for AT&T's California petitions.
e.g. I am calling about the Carrier of Last Resort Staff Proposal, R.24-06-012. I ask the CPUC to reject the Staff Proposal, which waters down COLR to allow inferior technologies that do not even meet current standards to be designated COLR-eligible. I also ask the CPUC to protect Californians by challenging AT&T's petition to the FCC to disconnect 200,000 Californians and also fight AT&T's lawsuit naming the CPUC and Attorney General, which attempts to undermine CPUC protections and eliminate access to reliable phone service for hundreds of thousands of Californians. Additionally, the CPUC needs to sue the FCC over its order asserting federal preemption over state COLR rules. We have already spoken out — we want to keep reliable landlines and do not want the inferior alternatives. Please do not give into AT&T's bullying — the CPUC has an obligation to fight this lawsuit to protect the public against industry or many people will lose access to communications.
Remember: even if you do not personally use a landline regularly, having landlines available in a community provides an additional layer of communications in case of an emergency. The loss of the landline network is a safety issue for all of us.
WHAT: The FCC issued an NPRM seeks public input on proposed rules. This NPRM is part of a series of rules to deregulate the telecom industry and allow carriers to eliminate POTS and TDM networks nationwide. The FCC aims to fully transition the industry to bill-and-keep, which is at odds with a TDM-based network (POTS landlines rely on TDM). The proposed rules would significantly increase the prices paid by remaining POTS customers, deprive companies providing traditional POTS service of crucial revenue sources (particularly small, rural phone companies) and make it easier for carriers to eliminate POTS services altogether. This article is pro-industry, but provides a good overview of some of the rules the NPRM seeks to eliminate.
WHEN: Initial comments are due May 26, and reply comments are due June 22.
ACTION: Even though the docket is technical and aimed at industry, the FCC also invites comments from consumers, even posing questions to them in the NPRM. Tell the FCC that you:
To submit comments, create a PDF of your comments, then go to the FCC ECFS. Enter 25-311 and 25-208 as the proceeding numbers. You can also view already-submitted comments.
Sample comments: I do not consider other services to be interchangeable with traditional POTS service. My landline is the only reliable way to call for help in emergencies. Other options do not work in prolonged power outages here. A transition to bill-and-keep would increase the rates I pay for my (already expensive) landline, which is a necessity that I require, thus forcing me to absorb any price increases. Eliminating these regulations would make it easier for telcos to further price gouge consumers. We can have the benefits of IP without being forced to give up reliable phone service. Retain current regulations and compensation structures to protect access to reliable and quality phone service. This should be the priority, not the IP transition at all costs, which only stands to benefit industry which is already profiting handsomely.
You can refer to my draft comments and the Nebraska Public Service Commission's comments for more detailed responses to the issues raised in this NPRM. This submission includes comments submitted on a previous NPRM regarding "Accelerating Network Modernization (25-304). Additionally, below are some questions/statements directly from the NPRM that any consumer can answer and refute (we have added a few comments to clarify misleading statements by the FCC):
WHAT: The CPUC is in the final stages of reviewing its COLR rules to possibly revise them in response to AT&T's previous requests to eliminate its COLR obligations.
IMPACT: The CPUC Staff 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. Requirements for directory assistance, free White Pages listings, telephone directories, operator assistance, and basic local calling plans would be eliminated. This is purely about making it easier for carriers to decomission copper service and use other technologies.
ACTION: Submit comments in opposition of the staff proposal and insist the current rules either be retained or strengthened. Also ask the CPUC to not give into AT&T and challenge AT&T's lawsuit, AT&T's petition to the FCC, and the FCC's preemption of COLR in California. You can do this even if you don't live in California or have already left comments!
A number of applications have already been filed to discontinue service (mostly by AT&T). We are keeping track them of them here so you can file comments objecting to AT&T's false argument that alternative or replacement services, if even available, are equivalent to (let alone "superior") to POTS.
Because the FCC streamlined the process to allow carriers to discontinue POTS service as part of a "technology transition", these requests are automatically grantedin most cases. If filing comments, the FCC will remove the application from "streamlining" and perform a review.
To submit comments, upload your PDF comments to the FCC ECFS. Include the corresponding docket number from the table below. You do not need to live in the affected area; you can draft general comments and submit them in each docket. A threat to POTS anywhere is a threat to POTS everywhere!
Note that Dockets 26-123 and 26-125 refer to the California petitions referred to in bulletin #2 on California.
| Public Notice | Carrier/Application | Docket | # Customers | # Wire Centers | States | Comments Due | Auto-Granted |
|---|---|---|---|---|---|---|---|
| DA-26-459 | AT&T | 26-98 | 236 (228 res., 8 bus.) | 39 | South Carolina, Alabama, Indiana, Florida, Alabama, Kansas, Arkansas, Oklahoma, Texas, Missouri, Wisconsin, Ohio | May 26 | June 11 |
| DA 26-502 | AT&T | 26-106 | 29 (bus.) | 39 | Georgia, Kentucky, Louisiana, Mississippi, South Carolina, Tennessee | June 3 | June 19 |
| DA 26-507 | Frontier | 26-115 | ? | ? | Alabama, Georgia, Iowa, Mississippi, and Tennessee | June 5 | June 21 |
| DA 26-508 | Frontier | 26-116 | ? | ? | Alabama, Georgia, Iowa, Mississippi, Tennessee | June 8 | June 19 |
| DA 26-518 | AT&T | 26-123 | ETC Requirements | California | June 22 | July 7 | |
| DA 26-520 | AT&T | 26-125 | 199,000 (184,000 res., 15,000 bus.) | 360 | California | June 22 | July 7 |
Carriers also generally post notices of service discontinuances to their websites — here are where the large incumbents post their notices:
If you haven't already, join the Save Landlines organizing and discussion list to receive updates on further actions and discuss mobilization against the assault on reliable phone service. (We will also keep this page updated, so check back frequently).
No action required here; this information is provided for informational purposes.