Landline Defense Team
Urgent Action Needed!
AT&T is spending millions of dollars to abandon its responsibility for providing Basic Service to California residents and businesses—putting us all at risk. AT&T has submitted legislation in Sacramento, filed multiple petitions with the FCC, and is promoting a statewide ballot measure—putting profits over public safety.
Stand up to AT&T! Sign the petition today!
Have you signed the petition?
Want to do more?
Submit your own comment to the FCC using the form below and donate. To learn more, follow “More Details” below.
How to Submit Comments to the Federal Communications Commission
Comments may be submitted by an elected official, individual community members, or the municipality as a whole. Below is a step-by-step guide on how to file both a traditional comment and an express comment. All comments must be considered by the FCC. A traditional formal comment is best if your comment is more than a few paragraphs or if you are submitting on behalf of an organization. An express comment is best suited for individual consumers who wish to type in a few paragraphs about their concerns. Be sure to submit comments for each individual docket: 26-125, 26-123, 26-120, and 26-121. Docket descriptions and numbers are available in the Step-by-Step Guides below.
* Note that comments are made publicly available on the FCC’s website. If you would like to view submitted comments on a particular proceeding, enter the docket number in here: FCC.gov/ecfs/search/search-proceedings. See Step-by-Step Guides below.
Submitting Formal Comments: Step-by-Step Guide
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WC Docket No. 26-125 - In the Matter of Petition of AT&T for Preemption and Declaratory Ruling Regarding California's Carrier of Last Resort and Related Requirements, FCC.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%2226-125%22))
WC Docket No. 26-123 - In the Matter of: Petition of AT&T for Forbearance Under 47 U.S.C. § 160(c) from Requirements Imposed on Eligible Telecommunications Carriers by 47 U.S.C. § 214(e), FCC.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%2226-123%22))
WC Docket No. 26-120 - Comments Invited On AT&T's Section 214 Applications To Discontinue Domestic Legacy Voice Service As Part Of A Technology Transition, FCC.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%2226-120%22))
WC Docket No. 26-121 - Comments Invited On AT&T's Section 214 Applications To Discontinue Domestic Legacy Voice Service As Part Of A Technology Transition, FCC.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%2226-121%22))
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Submitting Express Comments: Step-by-Step Guide
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WC Docket No. 26-125 - In the Matter of Petition of AT&T for Preemption and Declaratory Ruling Regarding California's Carrier of Last Resort and Related Requirements, FCC.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%2226-125%22))
WC Docket No. 26-123 - In the Matter of: Petition of AT&T for Forbearance Under 47 U.S.C. § 160(c) from Requirements Imposed on Eligible Telecommunications Carriers by 47 U.S.C. § 214(e), FCC.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%2226-123%22))
WC Docket No. 26-120 - Comments Invited On AT&T's Section 214 Applications To Discontinue Domestic Legacy Voice Service As Part Of A Technology Transition, FCC.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%2226-120%22))
WC Docket No. 26-121 - Comments Invited On AT&T's Section 214 Applications To Discontinue Domestic Legacy Voice Service As Part Of A Technology Transition, FCC.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%2226-121%22))
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TURN is monitoring AT&T’s requests to the FCC, each has a unique deadline and docket number, but all four invite the FCC to end Carrier of Last Resort (COLR). Read on to learn more.
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AT&T has been clear that it wishes to end its obligation to provide basic service throughout its entire California service territory. California has Carrier of Last Resort (“COLR”) regulations that ensure all California residents have access to essential, reliable and affordable telecommunications services, also known as the right to “Basic Service.”
Basic Service is technology neutral but generally includes access to: voice calls, 911, toll free calls, help for deaf and disabled Californian residents, customer service support, protection from unwanted charges, operator services, directory help, and flexible billing options.
Despite making billions in profits, AT&T does not want to provide basic service throughout California and has been trying to evade, change, or overturn state regulations. Instead of focusing on providing quality service to all customers, whether that’s properly maintaining existing infrastructure or upgrading to adequate alternative technologies, AT&T has instead been focusing on ending California’s Carrier of Last Resort framework.
Now, AT&T is asking the Federal Communications Commission (“FCC”) to 1) approve its withdrawal as an ETC and 2) declare that California’s COLR rules are preempted (voided) in order to justify ending the Right to Basic Service across AT&T’s vast service territory.
This is not about copper landlines. AT&T is using all their money and political influence to be free to serve only the most profitable neighborhoods, and to leave low-income and rural communities behind. AT&T wants to limit who they serve and only offer the phone plans that will bring them the most profit without having to abide by service quality requirements, or non-discrimination laws.
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Summary: AT&T has asked the FCC to declare California’s COLR rules preempted by federal law and falsely claims that FCC approval is “all that is required to discontinue POTS [plain old telephone service] in California.” AT&T has also claimed that the COLR rules “directly impedes AT&T from discontinuing residential POTS as permitted by the [FCC].” AT&T is disingenuously conflating the Right to Basic Service with a requirement to keep POTS—however, the Right to Basic Service is technology neutral.
Comments to this FCC docket are still being accepted, Opening Comments are due June 22, 2026 and Reply Comments are due July 7, 2026.
Link to AT&T Petition: https://www.fcc.gov/ecfs/document/1052056507747/1
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Summary: AT&T is designated as an Eligible Telecommunications Carrier (“ETC”) which comes with access to special funding and requires the ETC to meet certain requirements such as a general voice obligation and providing customers access to the federal low-income program, Lifeline. A federal ETC designation also requires yearly certifications from AT&T that they are providing a minimum quality of service and are maintaining records that show compliance with all state and federal ETC regulations. ETC’s are also required to report an outages lasting 30 or minutes and what types of services were impacted and where those services were unavailable. AT&T’s request to relinquish its federal ETC does not just impact Lifeline subscribers, but everyone who relies on AT&T’s basic service. In addition, the loosening of reporting controls hampers both the CPUC and FCC’s ability to hold AT&T accountable for its less than reputable business practices.
Comments to this FCC docket are still being accepted, Opening Comments are due June 22, 2026 and Reply Comments are due July 7, 2026.
Link to AT&T Petition: https://www.fcc.gov/ecfs/document/10520920917144/1
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Summary: AT&T has asked the FCC for permission to discontinue AT&T Residential Local Service, its legacy copper network that provides Plain Old Telephone Service (“POTS”). As part of this request AT&T falsely claims that all affected customers will have access to a “superior” substitute “AP-A” service, but this service is woefully inadequate. If this petition is granted it will affect 184,000 homes, if not more. In its estimation of impacted homes AT&T relies on the FCC’s incomplete, and often incorrect, National Broadband Map. As such it is impossible to know whether AT&T’s approximation of impacted homes is adequate or significantly undercounts impacted residences. AT&T’s request also severely impacts public safety. Copper lines have been the standard for decades for reliable connections to local emergency services. Now, AT&T proposes to switch from a known reliable technology to an IP based one that is better known for failing during emergencies than working properly. AT&T argues that because the FCC has found AP-A to be sufficient in other areas as a replacement for its copper network, it should do so again here. However, California is unique with roughly half of the state considered “mountainous.” There cannot be a one-size-fits-all solution when it comes to low-income service and public safety.
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Summary: AT&T has asked the FCC for permission to discontinue AT&T Business Individual Access Line Service, its legacy copper network that provides Plain Old Telephone Service (“POTS”). As part of this request AT&T falsely claims that all affected customers will have access to a “superior” substitute “APB-A” service, but this service is woefully inadequate. If this petition is granted it will affect 184,000 homes, if not more. In its estimation of impacted homes AT&T relies on the FCC’s incomplete, and often incorrect, National Broadband Map. As such it is impossible to know whether AT&T’s approximation of impacted homes is adequate or significantly undercounts impacted residences. AT&T’s request also severely impacts public safety. Copper lines have been the standard for decades for reliable connections to local emergency services. In fact, many in the home alarm system industry have already expressed their frustrations to the FCC as transitioning away from copper lines to IP-based systems would necessarily leave their systems and technology without a way to interconnect. The FCC cannot pick winners and losers. It should not sacrifice one area of business to prop up another.