FCC Should Halt the End-Run Order from the Wireline Bureau — and Start Investigations.

1) The Removal of the Legitimate Process and the IRREGULATORS Right to be Heard and Defend the Public Interest (including seniors, low income families and rural and inner city residents, and all of us on the other side of the Digital Divide) has been put on Mute... Not to mention your rights.

On March 20th, 2025, the FCC put out a highly controversial Order to essentially shut down the copper wires while avoiding basic laws, regulations, and consumer protections, While the FCC will spin it differently, this order was done without the oversight of the other commissioners, and worse, there is no public participation or comments allowed. At the same time, the major beneficiary is AT&T, and their plan is to put customers on ‘crap wireless’, where the Terms and Conditions expose that AT&T is not taking any responsibility even if the services don’t work, including E911.

Or worse, the FCC is using just the wireline bureau to do an end-run, probably because when you realize that almost every datapoint and analysis is biased or manipulated, or the presentation leaves out basic material facts, someone might notice.

2) This is the Start of Delete, Delete,Delete: the New Massive Deregulation by FCC Chairman Carr. — And it is Ugly.

This proceeding is portent of things to come. In this Delete-Delete-Delete world. Notice no mention, no question and no thought was included in this slice and dice world. The FCC did not ask the public what is bothering them, and what can the FCC do to help? Lower rates, competition and choice of services or the companies not answering when you call them. — Everyone wants the regulations gone so in this case, if you live in a rural area and have copper-based phoneline — they will not be replacing that with fiber — unless they get more gov. subsidies, and will make every excuse not to deliver.

And the idea that a ‘citizen’ who can’t even answer basic questions about the charges on the bill could supply a list of laws and regulations to remove?

Or, answer the question — under previous deregulations that were created with the help of the FCC and Chairman Carr — what were the outcomes?

We are calling for a halt to this theft of our rights and of our democracy. As we will discuss, this is not simply about the copper wire infrastructure.

Here’s the story.

3) In 2025, these are Holding companies and their footprints are the original state-based Bell telecommunications utility monopoly wired phone service.

The opening map is of the Big Three telecommunications holding companies created by mergers of the Baby Bells. AT&T now controls 21 states, covering the majority of the US population. The ‘footprints’ of these holding companies are, in reality, the original Bell System state telecommunications public utilities that were transferred in 1984 during the Breakup of MA Bell and are still in place in 2025 but are hiding in plain sight.

AT&T et al will try to explain that there is a fiber footprint, that they are planning fiber to the home, until you realize that this is their strategy — to hold up promises of a fiber optic future and spruces up their dirt road, and just wait until the next shiny bauble is being hyped.

We wrote about this multiple times as the ACP low income family gov. subsidy actually went to companies like Michigan Bell or Southwestern Bell or Pacific Bell — All of which were merged and had their name changed in the 1990’s, and this repeated multiple times.. Pacific Bell is now AT&T California. So why did AT&T use the old names?

• AT&T Puts Its ’21 State Footprint’ in Its Mouth.

And we assume you did not know that there are still telecom public utilities; this fact is never mentioned by AT&T et al., even in investor meetings, or especially at the FCC.

And even though these wires are part of a state utility, AT&T can shut off the copper networks to roll out its crap wireless service and doesn’t even have requirements to file anything.

Ars Technica laid out this new deregulation.

“In July 2024, AT&T became the first carrier to apply for a technology transition discontinuance ‘under the Adequate Replacement Test relying on the applicant’s own replacement service,’ the order said, ‘AT&T indicated in this application that it was relying on a totality of the circumstances showing to establish the adequacy of its replacement service, but also committed to the performance testing methodology and parameters established in the 2016 Technology Transitions Order Technical Appendix.”

This translates to — If it almost works but doesn’t — who would know that it doesn’t work or if the signal from the cell site craps out or your medical device that should be using the network connection stops functioning.

This ‘totality’ is totally not a substitute for a copper wire that many people keep so they have a reliable connection that has been mostly dependable, just in case of an emergency.

4) AT&T “Crap Wireless” Is Not Reliable: AT&T Claims No Responsibility.

AT&T claims that it is rolling out fiber, but history tells us that it’s more a cover up as the real goal is a replacement — substitute using ‘crap wireless’, also known as Fixed Wireless Access (FWA). But this is no substitution or equivalent service to wireline infrastructure.

We call it ‘crap wireless’ because it is not a substitute for a fiber optic line and more importantly, AT&T is not taking any responsibility if the service doesn’t work or can ‘crap’ out.

AT&T refuses to take any responsibilities for life saving fundamental services, like Emergency E911 and alarm systems.

The proposed AT&T plans are for a service called “Advanced Home Phone” and it is designed to replace the existing copper home phone with another except it is a wireless product.

Advanced Home Phone is based on previously flawed equipment that was part of an earlier attempt to ‘transition’, close down the copper networks in rural areas for wireless — but it could not do basic applications including E911 or data services.

In 2025, AT&T refused to take any responsibility for this service, including the most critical — E911 emergency service. AT&T writes:

“5.2.5.2 Limitations of 911 Service: AT&T Phone — Advanced Service is not the same as traditional wireline telephone service, and 911 service doesn’t work the same as with traditional wireline telephones. You agree to tell anyone who may use your AT&T Phone.”

“Advanced Service of the limitations of 911 service. AT&T makes no warranty that access to 911 will be uninterrupted, timely, secure, or error-free.”

But, AT&T writes, there are many applications that work currently on a regular copper phone line but AT&T Home Advanced may not be able to handle and again AT&T claims they take no responsibility.

“AT&T makes no warranty that AT&T Phone Service is appropriate for or capable of use with monitored burglar or fire alarms or medical monitoring systems or devices. Use of such systems is at your own risk.”

In fact, AT&T makes no claim that the service will work at all, and the customer has to move the equipment to face the antenna and NOT use the existing wires.

This is a serious problem because AT&T executives claim this does alarm and medical monitoring, as discussed at a December Investor meeting. This list is because the previous versions of this technology did not work with these applications.

“It works just like a traditional landline phone, and it works with many of the services that our POTS landline customers are used to using: Think fax machines, medical monitoring devices, alarm systems, even elevators,”

It is clear that AT&T is telling 2 stories — and the most important include the language of the user terms and conditions — making this a crap wireless service and NOT a substitute for wireline copper-based service.

And we note in the original wireless device, AT&T told the FCC a decade ago that the service had no problems as did Verizon, but it later changed to — this is under development.

We documented these variables and what was the unspoken truth in 2013, with the previous “VoiceLink” product. (The chart in the article.)

“Even the “Wireless Home Phone” — VoiceLink Chart is Deceptive

But for pure snake oil, even in the details of AT&T’ IP Transition Trial documents, AT&T clearly doesn’t believe in telling the truth. This chart shows that AT&T, for their Wireless Home Phone product, has essentially given a totally false collection of answers that is exposed when one reads the fine print. (Notice that there are asterisks on almost every ‘Yes’ answer). If this chart looks familiar it should — it is identical to Verizon’s’ Voice Link applications’ chart.

AT&T added: “Notes: Currently, Wireless Home Phone and Wireless Home Phone and Internet, which are CMRS, comply with the Commission’s existing 911 requirements for CMRS, and do not provide E-911 with street address. Nor does Wireless Home Phone and Wireless Home Phone and Internet currently support alarm monitoring, medical alert and credit card validation applications. However, AT&T currently is developing enhancements that will provide all of these applications which we plan to introduce soon.”

There is no law or regulation we know of where E911 should ever be “USE AT YOUR OWN RISK”. — And this “totality” is totally illegal. There is nothing in any statute where ‘maybe it works’ is a reliable telecommunications service.

A strong position would be — if someone dies, the companies and the FCC who allowed these laws to be erased should be held accountable, with intent, regardless of what the terms and conditions say. -_ And they say — Use them at your own risk… seriously?

5) Patently Not True: The FCC claims this close down of the current copper networks will give extra funding to build the new networks by halting the “increasingly expensive copper line networks”.

The FCC writes:

“These actions will help ensure that providers roll out upgraded, high-speed networks to more Americans on a faster timeline — rather than requiring providers to keep pouring resources into maintaining decades-old and increasingly expensive copper line networks.”

Here we see the FCC is simply making up basic financial information that is wrong. There is no “increasingly expensive copper line networks” as the construction and maintenance expenses have been plummeting for decades. The companies no longer offer these services so there should be no marketing or advertising, and the companies stopped active construction and union workers has been laid off over the last decade.

In the next couple of stories we will document the flows of money and the expenses, directly from the phone companies’ reports.

It is items like these that make it clear public comments need to be established before this Order was submitted, much less accepted, and with all of the remaining FCC Commissioners and not the wireline bureau.

6) Prices are going up, not down.

And it is these incorrect, industry based, severely harmful to public policy, faux facts that need to be confronted.

• Idiocracy: FCC and Chairman Carr Claim Prices have been Going Down for the Last Decade.

The article refutes Chairman Carr’s claims and the paucity of data he uses. It is not accurate, as some of it comes from the very industry attempting to control the FCC’s agenda. These are the stories we created to cover a specific area to demonstrate that prices have continuously increased for virtually all services, and in multiple ways.

• AT&T Wireless, broadband, Internet and Phone all had major increases multiple times over the 5 years.
• Verizon Wireless Increases in 2024 and in 2025.
• Harvesting: AT&T and the other Telcos have been Harvesting their wired customers — i.e., continuous rate increases on basic wireline services. This has been violating every fair and reasonable statute.
• From: “AT&T CORPORATE AND CALIFORNIA FINANCIALS AND ILEC INVESTMENT POLICIES: PHASE 2 UPDATE”
• Major Rate Increases on Small Business Wired Services Up 133% in New Jersey. Rate Increases to Ramming. Using actual customers have been put on packages of service they do not need, want or even can use in some situations, and all with continuous rate increases.
• Universal Service Fund Taxes have had continuous increases. — now 36.3%.
• Services, including wireless calling, have a USF tax being applied.
• The Broadcast and Sports Slush Fund Junk Fee — The price of this one made up fee went up 1,144% since 2014 for Spectrum NY’s cable TV service, It is now $28.00 and not even added to the actual advertised price, and this is about standard nationwide.
• Why Are Overseas Communications Prices, from Wireless to Broadband, a Fraction of what We Are Charged in America?
• “No Gimmicks” America Is Getting Screwed. The Free French Telecom Fiber Optic Triple Play vs Spectrum-NYC Prices.
• Part 1: Examined the pricing overseas, and specifically based on communications bills
• IRREGULATORS Cost Recovery Complaint to the FTC: Remove All Cost Recovery Junk Fees on 350 Million AT&T, Verizon and T-Mobile Wireless Connections, $15 Billion Annually- to Start

7) The Accounting of Copper Lines Has Been Manipulated.

AT&T has decided to hide just how many copper wires/lines are still in use. At the AT&T Analysts Day, in the first week of December 2024, AT&T claimed it had only 5% of the residential voice customers are still using the legacy copper wires.

AT&T’s Annual Report showed that the company had about 9 million fiber lines to the home customers, but AT&T covers about 80 million locations.

This is deceptive on multiple levels because this 5% is only for Voice, and only for residential customers. What about the data lines or the business lines that are still copper based? Using AT&T’s own financial reports we reverse engineered the number of lines, but, we have been documenting this deceptive access line accounting since the 1990’s.

If we slowly parse this, we find that of the of the lines listed in AT&T Annual Reports, we see all of these other lines besides the “Retail Consumer Switched Access Lines”.

We estimate that 13–21 million other copper lines are in play but hidden. This would mean that 5% is deceptive, and that 30%-65% or more are missing. 8–15 times more lines in service than just residential, voice copper lines.

And we are not new to this topic, where we go through the mathematics of deceptive access line accounting.

• The Copper-Wire World of AT&T: The Reason to Investigate AT&T, Now

8) No recent statements made by AT&T or by the FCC has ever revealed that America should have already had fiber replacing the copper.

Over a 30-year period, 1992–2025, the copper wired customers had continuous rate increases that were originally based on providing funding to do network upgrades to fiber.

And every AT&T state had some obligations, commitments, and granted deregulation to allow customers, making them de-facto investors of fiber to the home networks they never got. Add to this, there has been a manipulation of the accounting rules that have allowed billions per state to be maneuvered to pay for wireless network upgrades instead. (See the opening map.)

Fiber Optic Failures: Promise them Anything. Wave 1: 1991–2004.

In 1991, the first wave of fiber optic state and federal plans of the now-AT&T states were put into play, based on former vice president Gore’s model of an ‘Information Superhighway’ replacing the existing copper with fiber. Staring in 1992–1995, all of the telcos/Baby Bells laid out plans including the companies that make up AT&T. While every state had a different plan, at the core:

• Now-AT&T- CA was to have 5.5 million homes by 2000 and spent $16 billion.
• Ameritech’s 5 Midwest states (Indiana, Ohio, Wisconsin, Illinois and Michigan) were to have 6 million homes by 2000.
• Southwestern Bell and BellSouth, the regional holding companies, both had different state commitments and budgets to replace the copper wires. (See Map)
• And almost all states had some plans to upgrade schools, libraries and hospitals.

Failed fiber optic deployments, Wave 2, started in 2005.

U-Verse ended up being a bait and switch as the company claimed it was fiber but left out that it was fiber-to-the- node, could be in the middle of the town, and was then attached to the aging copper they claimed should not be used.

We include this quote from the AT&T-DirectTV merger which claims that AT&T would have 57 million customer locations upgraded, and that 25 million were NOT being serviced and would be handled with wireless, VIP 2013:

“AT&T has stated that it has begun an expansion of its U-verse services to reach approximately 57 million customer locations or 75 percent of its wireline footprint. Of these 57 million customer locations, AT&T states that it plans to deploy FTTN or FTTP technologies to deliver U-verse video, high-speed broadband, and VoIP services to 33 million customer locations. For the remaining 24 million customer locations where U-verse services are at the time not or will be available, AT&T will have 3G and 4G LTE.”

Thus, the entire 21 state coverage of AT&T would NOT bring a fiber optic line to the home in most locations.

9) The FCC Claims: No One Complained to the FCC Over Network Changes.

“Over the past two years alone, the Commission has received and processed more than 400 network change disclosure filings, filings that mirror the notices incumbent LECs typically post on their websites, and not once has the Commission received a comment in opposition to the planned network change in response to the hundreds of public notices released by the Bureau.

“In fact, the last comment filed on a network change notice filed with the Commission was in 2021, further supporting the fact that these burdensome filing obligations serve no purpose but to unnecessarily duplicate the information that incumbent LECs are already required to publicly post on their websites or in other public places.”

There are so many things wrong with these comments it is hard to parse all of the issues:

• The FCC never did a proper reach-out nor did the companies about what was going on with the copper shut-offs and what recourse customers had, if any.
• The brain-dead-ed-ness of the FCC, claiming that sticking some notice on some website will be enough to tell the public that their wires may be shut off, and then the FCC claims the public wasn’t interested, is pure hogwash.
• In fact, the FCC is NOT the primary regulatory body in charge of ‘shutting off the copper’ because the wire is part of a state utility — a fact never once mentioned anywhere in the FCC’s plans or discussion.

There were thousands of people who showed up in California when the state CPUC commission asked for comments.

• “Public participation in this proceeding was extensive with over 5,000 public comments received into the record and eight Public Forums held in-person in three cities and virtually across the state, drawing more than 5,800 attendees.

And had the FCC actually done proper notification, there would be a great number of people who would be very vocal about the situation

And people do care, as told by the response to the Sandy Storm’s knocking out the phone lines on Fire Island, NY

In 2013, the Sandy Storm hit the East Coast and knocked out the copper wired service and Fire Island residents were going to be put on the original crap wireless — VoiceLink and there were thousands of people who were active throughout NY and NJ, in First Island alone there were 70 who filed with the FCC Note: in 2025, one part of these proceeding have over 360 comments and filings. I

In the ‘Fire Island Copper discontinuance”, the FCC has to react:

“Where there are concerns in the record as to whether a service has reasonable substitutes or whether the present or future public convenience and necessity will be adversely affected, the Commission may take a petition off the automatic grant if necessary to allow further review of the discontinuance application, consistent with its statutory obligations. In this case, numerous parties raised concerns about Verizon’s proposed discontinuances and, in particular, opposed an automatic grant of the proposed discontinuances.[1] In addition, the Bureau has requested additional information from Verizon regarding the Barrier/Fire Island Application. Given the circumstances, we conclude that further review is appropriate, and the public interest will not be served by an automatic grant of Verizon’s request.”

And to say that no one in AT&T’s 21 state service area would care passionately about being represented — this is a put-on job. In 2013, the FCC had comments filed by major associations, representing seniors, like AARP, the union workers who knew the condition of the copper, like CWA, and public interest groups, like Public Knowledge.

This started over a decade ago — to shut off the copper. And this is just for Fire Island NY to stop the FCC actions with concerns over this VoiceLink substitute. This shut off impacts 21 states, not a few towns. — This is from 2013.

“The Commission received more than 70 comments in WC Docket №13–150, with several commenters voicing concerns about the limitations of Voice Link service, its suitability as a replacement for the wireline telecommunications services Verizon proposes to discontinue, and the need for a thorough investigation of the issues involved in this proceeding. See, e.g., AARP Comments at 15–16 (stating that the substitution of Voice Link eliminates a common carrier network that has supported a wide variety of technologies and services of benefit to consumers, and jeopardizes public safety because it is incompatible with Life Alert systems and security systems); CWA Comments at 8, 20–24 (suggesting that the Commission deny an automatic grant of Verizon’s application and consider further data to evaluate Voice Link as an alternative); NYPSC Comments at 2 (urging the Commission to postpone its decision until the NYPSC can make an assessment of Voice Link as an alternative service); NJBPU Comments at 6 (suggesting that the Commission should not automatically grant Verizon’s application as the NJBPU awaits a discontinuance filing from Verizon); Public Knowledge Comments at 7–12 (asserting that Voice Link is a downgrade from wireline telecommunications). The Commission also received comments in WC Docket №13–149 opposing an automatic grant of Verizon’s application. See, e.g., Comments of the NJ Division of Rate Counsel, National Association of State Utility Consumer Advocates, and the Utility Reform Network at 25 (stating that the Commission should deny or defer action on Verizon’s applications pending further State review”.

No one cares? Or is it that this FCC has decided to help the industry over those who never got upgraded and now are being thrown under a bus.

Conclusion:

We are calling for a halt to this theft of our rights and of our democracy. As we will discuss, this is not simply about the copper wire infrastructure.

PART II under previous deregulations that were created with the help of the FCC and Chairman Carr — what were the outcomes?

We will be addressing the USOA accounting scandals based on the Verizon New York financial annual reports; the 2024 Annual Report is due May 22, 2025