It’s Now Time for the Public, Activists and Advocate Coalitions to Pushback & Defeat, Defeat, Delete.

This footnote is from the FCC’s July 25, 2025 order and it reveals that the Irregulators have a pending “Application for a Full Commission Review”. There are a total of 4 separate FCC Orders covered.

On March 20th, 2025, Chairman Carr issued a press release from the FCC’s wireline bureau. FCC Cutting Red Tape to Unleash New Infrastructure Investments

(Includes 4 Orders and Chairman Carr Press Release, March 20, 2025)

The Irregulators filed on April 21, 2025, for a full commission review of a series of FCC orders because we and the American Public were harmed. These FCC actions were done as part of the wireline bureau, ignoring (sidestepping) due process and they were released with no comment period and no review by all Commissioners.

What we filed was an analysis of how the FCC’s orders failed to include basic information, material facts, and that it was relying on information supplied by the companies, which requires full audits. We will explain in a moment.

And these proceedings are joined by an entire collection of items designed to strip-mine all communications — cable, phone, wireless, broadband, Internet — regulations, obligations, requirements for notifications… on and on.

In fact, we wrote a separate report on the fiasco of the Cable regulations. The FCC conducted an Open Meeting June, 27, 2025 that was dedicated, in large part, to the strip-mining of consumer protection rules and regulations governing cable services, including removing those pesky, burdensome rate regulations, regulations on the equipment, and even an elimination of the data collection forms and accounting reports to determine rates. And this is tied to Chairman Carr’s “Delete, Delete, Delete”.

Every aspect of America’s communications infrastructure, and our connectivity to it — are tied directly to what we have presented.

Our demand for Universal Service must stop the shutting off of the customers using made up data about the existing copper networks, and move toward a future that will actually bridge the Digital Divide. This Universal Service Movement is also tied to the shift of the BEAD along with the other funding programs to create wireline connectivity infrastructure rather than Chairman Carr’s misguided deregulatory public policies and his favored wireless communications technology that will harm America.

What we now have is America being pushed onto inferior “least cost” government subsidized, wireless or satellite services vs building critical fiber infrastructure in communities. More importantly, many of these policies are being constructed with biased, manipulated data, but with a twist — the FCC is now also attempting to get rid of due process to allow for comments.

That is — biased, manipulated data and analysis is being used to create harmful public policies, and there won’t be any ability for public comments.

We created a separate story to show that Chairman Brendan Carr’s statements about the number of copper lines leave out about 50 million copper lines in the analysis, thus making the deregulation planned to be done is being done with deceptive analyses.

The Irregulators is a loose consortium of very senior telecom experts, analysts, auditors and lawyers (some have worked for the FCC, state advocate and Attorney General offices) that have been filing comments as a group (including as the New Networks Institute and Teletruth) since 1998 in every critical proceeding.

Details and Issues

The March FCC wireline order had no comment period, directly harming our ability to defend the public; and we have in-depth analysis showing massive cross-subsidies, failure to supply basic material facts, failure to hold the companies accountable at all levels — and after this March action we found out laterthat it had 4 separate proceedings. All of this was designed by Chairman Brendan Carr to help the companies remove basic regulations and obligations and is tied to the Delete3 and multiple other July proceedings.

Will the FCC decide it can just shut down our ‘adverse comments’, and will the FCC

remove our rights and violate basic laws.

Direct ties to the harms proposed in Delete, Delete, Delete.

The current Delete3 has a plan to remove rules that will allow the FCC, re Carr, to just push through whatever he wants.

We were the opening shot. A coalition with Public Knowledge and 22 others stated their objections. Here’s a summary from Google AI

“ — -eliminate existing rules without the standard public notice and comment period required by the Administrative Procedure Act (APA). They argue that this process violates the APA and undermines important safeguards designed to prevent abuse of power by government agencies.

“Specifically, the groups are concerned that the FCC is using a “good cause” exception under the APA to bypass the standard rulemaking process when eliminating rules.”

Thus, we, the Irregulators, are the poster child as we have 30 years of data and analysis, as well as identified and documented a litany of harms directly caused by the data used by the FCC. And we asked for a full commission review with comments, so that we can then expose just how many specific violations and egregious acts are underway.

But, there is more coming up in the FCC August 7th open meeting, with the Section 706, proceeding, which gives an annual assessment of whether broadband is being delivered in a timely basis, as well as the Special Access and Backhaul proceedings. We will be putting out our comments before the meeting.

All of this is tied to the companies’ plans to shut off the copper, and force customers onto

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To date, we filed the original ‘Request for Review’, USTelecom, the phone association, replied and as of May 15th, we filed a short rebuttal.

• Read the IRREGULATORS FCC Application for Review
• IRREGULATORS Request Full Review of FCC Deregulation Order — and Debate Us
• FCC Should Halt the End-Run Order from the Wireline Bureau -Start Investigations.
• Read Delete, Delete, Delete? FCC Massive Deregulation Created a Massive Ongoing Accounting Scandal: The Burdens are on US.

This is another of the 4 footnotes that are in the current FCC Proposed rulemaking:

• March 2025 Grandfathering Order at 3, para. 6. But see Application of Irregulators for a Full Review by the Full Commission; & Other Actions Requested, WC Docket №17–84 (filed Apr. 21, 2025) (seeking review of action taken pursuant to delegated authority under 47 CFR § 1.115).

Here’s the Delete, Delete, Delete discussion of what makes an adverse comment. —

• “Good Cause to Forgo Notice and Comment. Under the Administrative Procedure Act (APA), when an agency for good cause finds that notice and public comment “are impracticable, unnecessary, or contrary to the public interest,” it need not follow notice and comment procedures before modifying or repealing rules.”

Of course, it is the FCC who decides on what will be considered as an adverse comment.

Deep Holes in the Discussion.

There are many areas that impact our communications and connectivity, but it is the ability of the rewriting of history and even the current events that is now critical to understand.

First, there are still state telecommunications public utilities, hiding in plain sight.

There is no mention of this fact in any FCC or AT&T et al filings orders or data and analysis

Example: The Verizon NY 2024 Annual Report, published May 27, 2025 shows massive contradictions to the FCC’s storyline. Though it varies by state.

• Not one place has the FCC, or the telephone or wireless companies admitted that the copper wires are mostly part of a state utility.
• There is no recognition that these are “intrastate” lines — not interstate lines.
• The FCC has jurisdiction over federally regulated inter(between)state services while the state utility commissions regulate the intra(within)state services.
• The budgets for upgrades were and still are charged to local wired customers,
• Much of the construction budgets were illegally transferred to wireless and the customers were and are still being charged.
• Just halting these issues would give NY State over ¾ of a billion — and all of this is published in the Verizon NY Annual Reports.
• There are millions of miles of fiber optic wires that were already put in but not turned on, known as “dark fiber”, which needs to be addressed.

And no where is there recognition that in most states there were multiple deregulations where the subscribers were charged rate increases for network upgrades — they never received and were left on copper wires.

Without the right to comment, or have the comments taken seriously, it is up to those who can join us in keeping our right to be part of a democracy — and challenge the FCC et al when they present data that is atrocious and missing basic material facts, and then use it to harm the public.

We will be putting up specific examples that are in our filings — and let the public decide if what we presented was “adverse comments that need investigation”.