Landline Action Bulletin

Access to reliable communications under assault nationwide — immediate action required!

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.

Urgent Actions Required NOW

  1. Help Us Challenge FCC Preemption of State COLR Rules

    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.

  2. Object to AT&T's Petition to Disconnect 199,000 Californians and ask California to challenge AT&T's Lawsuit/FCC Petitions

    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, use ECFS Express Filing to submit a text comment (or upload a PDF of your comments to ECFS). Include proceedings 26-125 and 26-123 as these are the dockets for AT&T's California petitions.

    • Call the CPUC Public Advisors office at 1-866-849-8390, press 1 for English, then press 4 to leave a public comment. You can do this even if you don't live in California! Reference proceeding Carrier of Last Resort and Network Modernization Staff Proposal (R.24-06-012) in your comments. The main points are:

      • NO to the staff proposal
      • FIGHT AT&T's petition to disconnect 199,000 Californians and FIGHT AT&T's lawsuit against the CPUC
      • SUE the FCC for preempting COLR rules

      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.

    • Take your comments and submit them in writing online at in the R2406012 proceeding by clicking "Public Comments" and adding your comment.
    • Call the California Attorney General at 1-800-952-5225 (916-210-6276 out of state) and press 1 for English, then 7 to leave a message for the Attorney General. e.g. I am asking the attorney general to defend the rights of hundreds of thousands of Californians to reliable phone service by challenging AT&T's petition to disconnect 200,000 customers and also fight AT&T's lawsuit against the CPUC and Attorney General. The alternatives that AT&T claims are sufficient are inferior and inadequate (and not even functional everywhere) and if AT&T wins this lawsuit, thousands of Californians may never have reliable phone service again, so we need you to make this issue a top priority. Please also challenge the FCC order asserting preemption of state rules like COLR.
    • If you live in California, contact your state representatives to alert them to this issue. (Full list of state senators). Call first, then follow up by email.
    • We can't do this alone. Reach out to consumer advocacy groups that can help challenge these efforts by AT&T and the FCC — ask for their support in this fight and to make this a top priority:
    • Share your perspective with the FCC on landlines. Tell them you do NOT approve of their current deregulatory agenda which puts lives at risks by cutting people off from reliable communications. Let them know you insist upon having a reliable landline. (Note: This is not a formal complaint and will not count as a comment in any of the active proceedings; do this only in addition to filing formal comments with the FCC as directed elsewhere on this page.)
    • Write op-eds and letters to the editor in your local newspaper (if you still have one) about this.
    • Some of your friends and neighbors may not understand the full gravity of this situation. Please help them to understand its seriousness by holding local town halls, going door-to-door, etc. to raise awareness and opposition. You can also try posting in places like NextDoor, etc.

    Remember: even if you do not personally use a landline regularly, landlines provide an additional method (and often, the only functional method) of communications in case of an emergency. The dismantling of landlines creates a safety issue for communities at large. Please especially have solidarity with those whose lives literally depend on landline access.

  3. Submit Public Comments to FCC on Notice of Proposed Rulemaking "Reforming Legacy Rules for an All-IP Future" (WC Dockets 25-311, 25-208)

    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:

    • DO value traditional voice service for its unique benefits (explain what)
    • DO NOT consider any of the claimed "alternatives" to be functionally equivalent to or adequate substitutes for POTS (explain why)
    • DO NOT want regulations eliminated and DO NOT want critical revenue support for rural phone companies eliminated

    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):

    • 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?
    • 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 incorrect; if you want POTS, you can generally only get service (directly or indirectly) through the incumbent, you cannot go to a competitor for the same kind of service. Regulation is still needed.]
    • 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 is the distinction between local and long-distance service relevant to consumers? [The FCC wants to force everyone to pay for bundled all-distance calling, even if you only subscribe to local service today and cannot afford to pay more]
    • 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? To what extent do customers still purchase dial-around 1+ services from IXCs subject to tariff?
    • 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?
    • Will consumers face increased costs or other nonmonetary burdens as a result of the proposed rule changes? 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? 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?

  4. Submit Public Comments to CPUC on Carrier of Last Resort Rulemaking

    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!

    • Submit public comments online (click "Public Comments")
    • Submit comments by email at [email protected]
    • Leave comments by phone by calling 1-866-849-8390, press 1 for English, then press 4 to leave a public comment.

  5. Submit Public Comments to FCC on Requests from Carriers to Discontinue Service

    WHAT: 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.

    IMPACT: Because the FCC streamlined the process to allow carriers to discontinue POTS service as part of a "technology transition", these requests are automatically granted in most cases. If filing comments, the FCC will remove the application from "streamlining" and perform a review.

    ACTION: 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:

  6. 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).

Upcoming Actions/Participation Opportunities

  1. June 10, 1pm EDT — FCC Consumer Protection and Accessibility Advisory Committee Meeting — The meeting will be streamed live at fcc.gov/live, and public comments can be submitted during the meeting to [email protected]
    2. . Tell the FCC how you feel about its dismantling of regulatory protections and ask them some tough questions.
  2. June 11, 11am PDT — Provide public comments during the next CPUC Voting Meeting. You can provide a 1-minute comment to the CPUC, either in-person (varying location) or remotely by phone; dial 1-800-857-1917, then 9899501#. Press *1 to enter the queue to provide comments. The next meeting is June 11, 11am PDT. See Upcoming CPUC Events for subsequent meetings.
  3. July 15/16 — Workshop on IP Transition — The FCC will host an industry workshop to provide an opportunity to examine issues involving the transition to all-IP networks. The public is invited to participate in-person at FCC HQ (45 L St. NE, Washington, DC). We will be present at the event to represent the public's interests and provide non-industry perspective.

Other Information

No action required here; this information is provided for informational purposes.

This page is a joint effort of PhreakNet with our friends at SaveLandlines.org
If you have a question that is not answered from reviewing this page, you may email [email protected] for assistance.