Commenters Urge Caution on FCC's Copper Retirement Push
While USTelecom and other industry groups generally supported the FCC’s push to enable faster retirement of copper lines, other organizations raised concerns, especially over the role copper lines have historically played in emergency calling. Comments were due this week in docket 25-208.
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USTelecom said reforming the Section 214 discontinuance process “will go a long way toward achieving the Commission’s aims in this proceeding.” The group “appreciates the Commission’s proposal to further streamline the rules governing discontinuances as part of technology transitions,” but “conditional forbearance offers a better way forward.” The FCC also shouldn’t limit the ability to permanently discontinue services “only to instances where the carrier no longer has any customers following the emergency discontinuance,” USTelecom said. “Instead, carriers should be permitted to convert an emergency discontinuance into a permanent one by certifying that a comparable service is available throughout the affected area.”
The group said state carrier of last resort (COLR) obligations and state refusals to promptly process applications to relinquish eligible telecommunications carrier (ETC) status are also impediments. “While subject to COLR obligations or holding ETC status, providers effectively cannot discontinue legacy voice services, even where the Commission has granted approval to discontinue those services.”
Others warned about the discontinuance.
Incompas said the FCC must maintain some safeguards as it eliminates regulatory requirements. The trade association “strongly cautions against wholesale elimination of core protections that ensure continued interconnection, access to public safety networks (including 911), and the competitive viability of providers that depend on the very facilities being retired.” Competitive carriers “continue to face roadblocks to IP interconnection, and they are being forced to rely on legacy trunk-side facilities, like DS1/DS3 links and selective router connections, for which there are often no viable alternatives,” Incompas said. Permitting incumbent local exchange carriers “to dismantle copper and [time-division multiplexing] infrastructure without Commission oversight, would leave competitors and their customers stranded during the transition.”
Older people “disproportionately rely on landlines to stay connected to emergency services, family, friends, doctors, and more,” AARP said. “Sparsely populated parts of the country (especially where high-speed internet networks may not yet be available and where wireless coverage may be spotty or non-existent) also disproportionately rely on legacy copper networks to communicate.” AARP added that the FCC should ensure that people have “uninterrupted ability to reach 911 service throughout the transition” away from copper.
The National Association of State 911 Administrators said there’s an “ongoing transitional relationship between copper telecommunications and the effective delivery of the legacy and emerging IP-based” next-generation 911 system. Copper lines are also important to “911-adjacent” systems, the group said. “While there has been much progress toward IP-based systems in emergency communication to the field responders, copper lines remain relevant in supporting the infrastructure for radio networks and pager activation systems necessary for delivering 911 services and non-emergency calling functions.”
The Alarm Industry Communications Committee opposed a proposal to eliminate FCC filing requirements for network change and copper retirement notices. “The current filing system provides centralized accessibility and regulatory accountability that alternative notice methods cannot replicate,” it said. "Complete absence of notification for network changes would leave critical life safety services without adequate time to arrange for alternative communications pathways.”
NTCA supported reform but said the FCC must be careful “to distinguish between reforms that will remove burdensome and unnecessary regulatory red tape and changes that could inadvertently harm rural consumers, create regulatory uncertainty, or frustrate the mission of universal service.” NTCA said any relief the FCC grants “must include robust safeguards that prevent larger carriers from shifting transition costs to smaller rural providers.”