CC SR 20240319 02 - AT&T COLR
CITY COUNCIL MEETING DATE: 03/19/2024
AGENDA REPORT AGENDA HEADING: Regular Business
AGENDA TITLE:
Consideration and possible action to oppose AT&T’s application with the California Public
Utilities Commission (CPUC) to remove its landline obligations.
RECOMMENDED COUNCIL ACTION:
(1) Receive and file a report on AT&T’s application with the CPUC to remove its
Carrier of Last Resort (COLR) obligation and remove its designation as an Eligible
Telecommunications Carier (ETC); and,
(2) If deemed acceptable, authorize the Mayor to sign a letter of opposition to AT&T’s
application with the CPUC.
FISCAL IMPACT: None
Amount Budgeted: N/A
Additional Appropriation: N/A
Account Number(s): N/A
ORIGINATED BY: Shaunna Hunter, MPA, Administrative Analyst
REVIEWED BY: Same as below
APPROVED BY: Ara Mihranian, AICP, City Manager
ATTACHED SUPPORTING DOCUMENTS:
A. Draft letter opposing AT&T’s application with the CPUC (page A-1)
B. AT&T Fact Sheet (page B-1)
C. CPUC Fact Sheet and Public Participation Hearing Information (page C-1)
D. AT&T COLR Relief Application to the CPUC
E. AT&T Territory Map with Address Look Up
F. AT&T ETC Application to the CPUC
G. RPPG Analysis of AT&T’s Application to the CPUC (page G-1)
BACKGROUND:
In March 2023, AT&T California, one of the telecommunications companies that service
Rancho Palos Verdes residents, submitted an application (Attachment D) to remove its
COLR obligation and its designation as an ETC to the CPUC.
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RANCHO PALOS VERDES
Telephone service throughout the 20th century required individual homes to connect to a
central service via copper telephone lines. The maintenance investment from providers
to maintain these copper lines was met with the demand that every household within a
designated service area would be a customer. Telecommunications firms established
governmental relationships that protected their investment and customer base. As
technology advanced and additional telecommunications services became available to
most homeowners, the monopolized market which once existed through the established
relationships became flooded with other competitors for the same customer base. In
California, traditional landline customers of AT&T have dropped from 8 million to just over
600,000 and are dropping each day as the network of available choices grows. According
to AT&T’s application (Attachment D), 97.5% of AT&T customers have at least one other
alternative to traditional landline service and 88.2% have three or more alternatives. In
some rural areas, there may not be alternatives to copper landline service; in these cases,
AT&T proposes to continue to maintain copper landline service until a suitable alternative
is established.
Despite advancements in telecommunications technology, there are still many areas
within our community with inadequate cellular coverage. Of particular concern are our
elderly residents, who often rely on landline services due to their reliability and familiarity.
Consequently, the discontinuation of AT&T's landline service could potentially leave our
residents without access to critical emergency services such as 9 -1-1 or 2-1-1, placing
them in grave danger during emergencies especially as a designated Very High Fire
Hazard Severity Zone. As such, the Council is being asked to consider opposing AT&T’s
request.
DISCUSSION:
AT&T’s application to the CPUC (Attachment F) requests to remove AT&T’s designation
as an ETC which could adversely impact the east side of the City off Palos Verdes Drive
East. If approved, AT&T would not be obligated to participate in the federal Lifeline
program which serves low-income California residents.
The CPUC is holding in-person and virtual public forums for the public to participate
(attachment C) that will conclude on March 19, 2024. At each event, a brief overview of
the application will be provided, then the parties to the proceedings will provide their
overview followed by a question-and-answer period posed by individuals to AT&T
representatives. AT&T has provided a fact sheet (attachment B) to answer frequent
questions about this application and the anticipated service changes were their
application to be approved. The City intends to attend the public hearing to provide
comments in advance of tonight’s meeting.
Should AT&T’s application be approved, RPV residents that currently use a traditional
landline serviced by a copper network will need to switch to a comparable fiber or wireless
service. Though it is not known at this time the exact percentage of RPV residents living
in the impacted area currently use a traditional landline, AT&T has provided an interactive
map with an address look up function for individuals in their service area (attachment E).
The impacts are typically felt by our senior community that have not yet switched to newer
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technology such as Voice over Internet Phone (VOIP) or wireless alternatives. A concern
in RPV includes the unreliability of some cellular networks and communication during an
emergency.
Based on the information attached to this staff report and information presented at the
March 19 meeting, the City Council may consider submitting the attached draft opposition
letter to the CPUC (Attachment A).
AT&T External Affairs Area Manager McKenzie Neely-Wright will be at the Council
Meeting to answer questions and concerns.
ADDITIONAL INFORMATION:
The League of California Cities (Cal Cities) opposes AT&T’s application for COLR relief.
CONCLUSION:
Staff recommends the City Council determine if a position is warranted regarding AT&T’s
application. If deemed appropriate, Staff has provided a draft letter of opposition for
consideration.
ALTERNATIVES:
In addition to the Staff recommendation, the following alternative actions are available for
the City Council’s consideration:
1. Do not take a position at this time.
2. Take other action, as deemed appropriate.
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30940 HAWTHORNE BLVD. / RANCHO PALOS VERDES, CA 90275-5391 / (310) 544-5207 / FAX (310) 544-5291 / WWW.RPVCA.GOV
March 19, 2024
Alice Reynolds, President
California Public Utilities Commission
505 Van Ness Avenue
San Francisco CA 94102
RE: AT&T Application for Relief of Carrier of Last Resort Obligation – Notice of
Opposition
Dear President Reynolds,
I am writing on behalf of the City of Rancho Palos Verdes to express our concerns
regarding AT&T's application for relief from its Carrier of Last Resort (COLR) obligations
in our community. We respectfully urge the California Public Utilities Commission (CPUC)
to reject this application.
AT&T currently serves as the designated COLR in Rancho Palos Verdes, providing
essential landline telephone services to our residents. Despite advancements in
telecommunications technology, there are still many areas within our community with
inadequate cellular coverage. Consequently, the discontinuation of AT&T's landline
service could potentially leave our residents without access to critical emergency services
such as 9-1-1 or 2-1-1, placing them in grave danger during emergencies especially as a
designated Very High Fire Hazard Severity Zone.
Of particular concern are our elderly residents, who often rely on landline services due to
their reliability and familiarity. These individuals may have limited options for accessing
affordable telecommunications services that meet their specific needs. Therefore, it is
imperative that any decision regarding COLR relief ensures the availability of alternative
communication solutions that can adequately meet the basic needs of our community.
The City of Rancho Palos Verdes is committed to promoting equitable access to high -
quality telecommunications services for all residents, especially those who are most
vulnerable. We believe that access to reliable, secure, and open networks is essential f or
fostering community safety and well-being.
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JOHN CRU ll<SHAN I<, MAYOR
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BARBARA FERRARO, COUNC ILMEMBER
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President Alice Reynolds
March 19, 2024
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We respectfully request that the CPUC reject AT&T's application for relief of its COLR
obligation. We urge you to prioritize the interests and safety of our residents in your
decision-making process.
Should you require any further information or clarification, please do not hesitate to
contact our legislative advocate, Sharon Gonsalves, at (916) 974 -9270 or via email at
sgonsalves@publicpolicygroup.com.
Thank you for your attention to this matter.
Sincerely,
John Cruikshank
Mayor
cc: Ben Allen, Senator, 24th State Senate District
Al Muratsuchi, Assemblymember, 66th Assembly District
Rancho Palos Verdes City Council
Ara Mihranian, City Manager
2A-
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California Network Modernization: FAQ
Will California customers lose service?
• No California AT&T customer will be left without service.
• We are simply seeking an approved process to help consumers transition from
outdated services to modern services.
Does this mean that customers won’t have a home landline?
• No. We are not cancelling landline service in California, and none of our California
traditional copper-based customers will lose access to voice service.
• We are focused on enhancing our network with more advanced, higher speed
technologies like fiber and wireless, which consumers are demanding.
Will California consumers have access to 911 services?
• No customers are being disconnected.
• Our customers will continue to have access to 911, and newer digital voice services
have access to 911 and use technology that makes it quicker and easier for customers
to reach first responders.
Will Californians access to affordable services?
• Today, Californians have access to mobile wireless and VoIP alternatives that are at
least as affordable as copper-based landline service.
• AT&T also offers Access from AT&T, which provides low-cost internet service for
eligible households with plans up to $30/mo. and speeds up to 100Mbps where
available.
How will California’s rural residents be impacted?
• No AT&T California customer is being left behind.
• We’re working to transition our remaining consumers who use traditional copper-
based phone service to upgrade to newer technologies from us or other providers.
• We are focused on enhancing our network with more advanced, higher speed
technologies like fiber and wireless, which consumers are demanding.
What about location accuracy of 911 calls for wireless and VoIP phones?
• Today, 911 operators can locate you nearly anywhere—from the side of a highway to
inside your home—all thanks to decades of innovation in wireless location accuracy
technologies.1
• The Federal Communications Commission (FCC) requires that providers of
interconnected VoIP telephone services using the Public Switched Telephone Network
(PSTN) to meet Enhanced 911 (E911) obligations. E911 systems automatically provide
emergency service personnel with a 911 caller's call-back number and, in most cases,
location information.2
1 https://www.ctia.org/news/blog-the-wireless-industrys-commitment-to-9-1-1-location-accuracy
2 https://www.fcc.gov/consumers/guides/voip-and-911-service
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What are the benefits for California’s seniors using wireless services?
• According to the Pew Research Center, 94% of seniors (65 and older) in America own a
cellphone of some kind, and 76% of seniors own a smartphone (Pew Research)
including 94% of those 65 and older.3
• The benefits to senior of using modern technology include for telehealth services,
staying connected with loved ones, keeping mentally fit, having access to emergency
alerts and the ability to track and manage health conditions.
• It’s imperative that California’s seniors have access to and continue to adopt high-
speed internet and newer technologies, to increase access to much needed services,
connect with loved ones and to improve quality of life.
What will happen to residents in areas where cell service may not be as strong?
• Our analysis based on data from the CPUC and FCC showed that 99.7 percent of
consumers within our service territory have at least three viable alternative options
for voice service.
• These include services other than wireless, such as VoIP services provided by cable
companies.
• For customers who do not have alternatives available, we will continue to provide
service until such time as an alternative is available.
What about backup power for VoIP phones. What is the cost? How long does the backup
battery power last?
• AT&T offers a 24-hour battery backup option for AT&T Digital Phone (VoIP).
Customers can also buy a backup option that lasts for less time.4
• For VoIP phones, consumers can buy reliable external backup power systems online, at
local electronics stores, or directly from the phone providers from anywhere from 8 to
48 hours. Costs vary for backup batteries for VoIP, but options can be found for
around $40.
Are prices for broadband and phone service increasing faster than inflation?
• The current price of AT&T residential copper-based landline service in California is
$37.50 per month. There are both bundled and non-bundled VoIP and wireless
alternatives costing a similar amount or less than the current $37.50 per month price.
• Mobile wireless providers offer prepaid and postpaid wireless plans at price points
below or comparable to those for AT&T’s copper-based service. Managed VoIP
services that broadband providers offer over their cable, fiber and fixed wireless
networks are generally less expensive than copper-based landline voice services.
• According to a 2023 study, prices for broadband experienced a 18% drop year-over-
year in the price of providers’ most popular broadband speed tier and a 6.5% drop
year-over-year in the price of providers’ fastest speed tier.5
3 https://www.pewresearch.org/internet/fact-sheet/mobile/
4 https://www.att.com/support/article/u-verse-voice/KM1041593/
5 2023 Broadband Pricing Index (BPI) – USTelecom
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Is Access from AT&T available for new and existing customers?
• Yes. AT&T has no plans to discontinue Access from AT&T program.
• We continue to offer the Access program, which provides low-cost internet service for
eligible households with plans up to $30/month and speeds up to 100Mbps where
available. To learn more, visit https://att.com/access.
What are the eligibility criteria for Access from AT&T?
• The following programs will continue to be used to determine eligibility for Access
from AT&T: Supplemental Nutrition Assistance Program (SNAP), and Supplemental
Security Income (SSI) for California residents, National School Lunch, or with a
household income below 200% of federal poverty guidelines.
• New Access from AT&T customers can go through an application process where they
submit documentation for review.
Why is AT&T exiting programs such as Lifeline that provide service to low-income
customers?
• Californians can continue to choose from among a number of providers if they want
to participate the federally supported Lifeline program.
• A CPUC report found that about 85% of Lifeline customers in California already obtain
the Lifeline benefit for wireless services.6
• We also offer the Access program, which provides low-cost internet service for eligible
households with plans up to $30/month and speeds up to 100Mbps where available
What is a COLR?
• One of the applications that AT&T submitted, if approved, would remove AT&T’s
obligation under California law to provide traditional landline phone service in a large
portion of our service territory in California – known as Carrier of Last Resort (COLR).
• AT&T’s COLR obligation means that we must provide traditional landline phone
service to any potential customer in our service territory.
• However, the COLR obligation no longer makes sense given that almost everyone in
our service territory can choose among several comparable or lower-priced wireline
and wireless alternatives to traditional telephone landlines for voice service.
Why did AT&T file for COLR relief in California?
• We’ve seen a precipitous decline in demand for telephone services provided over our
copper networks.
• This application seeks targeted COLR relief for areas in our California service territory
where facilities-based alternative options for voice service already exist.
• Our commitment is that consumers currently in our California service territory will
retain access to a service connection, whether from us or another service provider.
6 https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M478/K367/478367564.PDF
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Doesn’t California need a COLR provider?
• We believe that the COLR obligation is outdated and no longer necessary given that
nearly everyone in our California service territory already has or can choose among
several comparable or lower-priced wireline and wireless alternatives to copper-based
landlines for voice service.
Why doesn’t AT&T just maintain the copper-based network?
• Our copper network is incapable of meeting these modern, data demands, and as
such, it is now vastly underutilized.
• We cannot continue to support two networks, and the time has come for us to switch
to a modern network.
What happens to households who do not have access to alternative services?
• Our commitment is that customers currently in our California service territory will
retain access to a service connection, whether from us or another service provider.
• For customers who do not have alternatives available, we will continue to provide
service until such a time as an alternative phone service or provider is available.
• We are participating in eight in-person and virtual public forums for stakeholders and
customers to provide input into our proposal.
Is AT&T just profiting off discontinuing landline?
• We are not cancelling landline service in California, and none of our California
customers will lose access to voice service if the CPUC approves our application.
• We spend more than a billion dollars a year in California maintaining our legacy
network and set of services that are used by a small and rapidly declining number of
customers. Those dollars would be better spent on more advanced, higher speed
technologies like fiber and wireless, which consumers are increasingly demanding over
outdated copper-based services.
• In California, we invested nearly $8.6 billion in our wireless and wireline network
infrastructure from 2020-2022.
Would we sell portions of business to another service provider?
• None of our traditional copper-based landline customers in California will be left
without service.
• We are simply seeking an approved process to help consumers transition from an
antiquated copper network to modern services. Our goal is for customers currently in
our California service territory to retain access to a service connection, whether from
us or another provider.
• We are focused on investing in services that will meet our rural customers’ needs
today and in the future. Resources we spend on maintaining an antiquated copper
network are resources we can’t invest in our networks to help close the digital divide.
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CPUC Fact Sheet
PUBLIC PARTICIPATION HEARING
AT&T’s Applications for Targeted Relief from its Carrier of Last Resort
Obligation and Relinquish its Eligible Telecommunications Carrier
Designation (A.23 -03-003 and A.23-03-002)
AT&T’s application regarding Carrier of Last Resort Obligations (A.23-03-003)
In this application, AT&T requests to be relieved of its Carrier of Last Resort (COLR) obligations in certain areas of
California. If approved, it would no longer be required to offer landline telephone service where it is currently required
to offer Basic Service in those areas. Basic Service includes nine service elements such as Lifeline rates for eligible
customers, free access to 9-1-1, Telephone Relay Service, and directory and operator services. More information on
Basic Service is available at https://www.cpuc.ca.gov/industries-and-topics/internet-and -phone/broadband-mapping-
program/broadband-public-feedback/basic-service-definition.
What is a Carrier of Last Resort (COLR)? A COLR is a telecommunications service provider that stands ready to
provide basic telephone service, commonly landline telephone service, to any customer requesting such service within a
specified area. At least one telephone company in a specified area is legally required to provide access to telephone
service to anyone in its service territory who requests it. This is known as the Carrier of Last Resort (COLR) obligation
which ensures that everyone in California has access to safe, reliable, and affordable telephone service. AT&T is the
designated COLR in many parts of the state and is the largest COLR in California. Where AT&T is the default landline
telephone service provider means that the company must provide traditional landline telephone service to any potential
customer in that service territory. AT&T is proposing to withdraw as the COLR in your area without a new carrier
being designated as a COLR.
What areas are impacted by AT&T’s request to withdraw as a COLR? Here is the list of census designated places
where AT&T is requesting to withdraw as the designated COLR and here is an online version of the map with address
lookup.
What might happen if AT&T withdraws as a COLR? An area without a COLR could mean that there would be no
landline telephone company serving that area and that there could possibly be no landline telephone access for
customers in that area. If AT&T’s proposal were accepted as set forth in its application, then no COLR would be
required to provide basic service in your area. This does not necessarily mean that no carriers would, in fact, provide
service in your area—only that they would not be required to do so. Other outcomes are possible, such as another
carrier besides AT&T volunteering to become the COLR in your area, or the CPUC denying AT&T’s proposal.
AT&T’s application regarding Eligible Telecommunication Carrier Designation (A.23-03-002)
On March 3, 2023, AT&T requested to give up its designation as an Eligible Telecommunications Carrier (ETC).
What is an ETC? An ETC is a telephone company operating in a specific geographic area, that receives financial
assistance from the federal government-established Universal Service Fund to provide high quality, and affordable
telephone service to customers at all income levels in specific geographic areas. One example of a program funded by
the Universal Service Fund is federal Lifeline. While funding for this program is provided by the federal government,
each state determines a telephone company’s eligibility for ETC designation. In California, a company’s eligibility for
these federal funds is determined by the CPUC.
Does an ETC provide California LifeLine? In California, the CPUC also approves and denies applications for state
funding for programs to provide universal support, including California LifeLine (California’s program is called LifeLine
with a capital “L” for “Line”). The California LifeLine program is separate from the federal Lifeline program. An ETC
may be a provider of California LifeLine as well as federal Lifeline, but eligibility to provide California LifeLine is not
limited to only ETC providers.
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What is AT&T’s request in this application? AT&T is applying to give up its ETC designation, which would allow
it to no longer offer federal Lifeline, as well as other federal programs designed to subsidize telecommunications
support for low-income individuals and individuals located in remote areas. AT&T’s participation in the California
LifeLine program is a separate matter from this application to give up its ETC designation. AT&T asserts that it is not
necessary to keep its ETC designation because it no longer receives any federal high-cost support from the federal
government to provide universal service. By relinquishing its ETC designation, AT&T will no longer be eligible to
receive federal support to provide Lifeline, which could potentially affect all current AT&T Lifeline customers.
What areas are impacted by AT&T’s request to give up its ETC designation? All areas of AT&T’s service
territory where it currently holds ETC designation, which is the same as its Carrier of Last Resort (COLR) service
territory, could be impacted if the CPUC approves AT&T’s application. Here is a map of the different COLR service
territories in California, including AT&T’s: https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/communications-
division/documents/high-cost-support-and-surcharges/chcf-a-1/ilec-territories-2023_230412.pdf
What are the potential impacts on customers’ bills? For a household receiving federal Lifeline from AT&T, the bill
could increase by $5.25 per month for voice-only service, or $9.25 per month for bundled or internet service. In
addition to these amounts, a household on Tribal lands receiving federal Lifeline from AT&T could experience an
additional $25 per month bill increase.
What is required of AT&T for the CPUC to approve AT&T’s request? AT&T must demonstrate that another
ETC provider can provide universal support in the areas where AT&T wishes to surrender its ETC designation.
For more information on Eligible Telecommunications Carrier designation, please visit
https://www.cpuc.ca.gov/industries-and-topics/internet-and-phone/service-quality-and-etc/eligible-telecommunications-
carrier
Public Participation Hearings
The public participation hearings (PPHs) provide an opportunity for the public to communicate directly with the CPUC
regarding AT&T applications to remove its obligations under California to provide voice services.
WHEN FORMAT LOCATION
February 6, 2024, 2 p.m. and 6 p.m. In-person only Clovis City Council Chambers
1033 5th Street, Clovis, CA 93612
February 22, 2024, 2 p.m. and 6 p.m. In-person only Mendocino County Board of Supervisors
501 Low Gap Road, Room 1070, Ukiah, CA 95482
March 14, 2024, 2 p.m. and 6 p.m. In-person only Indio City Hall Council Chambers
100 Civic Center Mall, Indio, CA 92201
March 19, 2024, 2 p.m. and 6 p.m. Virtual only 1-800-857-1917
Passcode: 6032788#
www.adminmonitor.com/ca/cpuc
Consistent with the PPHs’ purpose of hearing from members of the public, representatives of parties already involved
in this proceeding are not permitted to comment at the PPH. More information at www.cpuc.ca.gov/pph
Other Ways to Participate
Subscribe to receive documents in A.23-03-003 and A.23-03-002 at: subscribecpuc.cpuc.ca.gov/fpss/Default.aspx
Submit comments electronically to the CPUC using the “Add Public Comment” button on the “Public Comment” tab
of the Docket Card for A.23-03-003 at apps.cpuc.ca.gov/c/A2303003 and A.23-03-002 at
apps.cpuc.ca.gov/c/A2303002. You can also review other public comments related to this rulemaking. The public may
submit multiple public comments throughout the proceeding.
Contact the CPUC’s Public Advisor at:
• Phone: 1-866-849-8390 (toll-free) or 1-415-703-2074
• TTY: 1-866-836-7258 (toll-free) or 1-415-703-5282
• Mail: CPUC Public Advisor’s Office, 505 Van Ness Avenue, San Francisco, CA 94102
• Email: public.advisor@cpuc.ca.gov
Please reference AT&T’s Applications 23-03-003 and 23-03-002 in any communication with the CPUC.
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February 13, 2023
To: Ara Mihranian, City Manager
Shaunna Hunter, Administrative Analyst
City of Rancho Palos Verdes
From: Sharon Gonsalves
Director of Government Affairs
Renne Public Policy Group
RE: AT&T Carrier of Last Resort PUC Application Analysis
Below is a general summary of the AT&T applications to the California Public Utilities Commission (PUC)
seeking relief from its Carrier of Last Resort (COLR) obligations and to relinquish its designation as an
Eligible Telecommunications Carrier (ETC) in certain areas of California. If approved, these applications
could have implications for telecommunications services in affected regions. This memo is informational
only and reflects the status as of this date—not a final decision. We hope that this will be a useful general
background document to prepare your agency for questions that ratepayers in your community may have
as more of the public becomes aware of potential changes. Please contact our office with questions,
should you have them.
What is the Carrier of Last Resort?
The COLR is a telecommunications service provider obligated to offer basic telephone service, typically
landline, to any customer within a specified area. AT&T, as the designated COLR in many parts of
California, is legally required to provide access to telephone service to anyone requesting it within its
service territory. However, AT&T is seeking to withdraw as the COLR in certain areas, potentially leaving
those regions without landline telephone access.
AT&T’s Application with the PUC
On March 3, 2023, AT&T applied to the PUC requesting relief from its COLR obligation, which specifically
mandates AT&T in California to maintain a copper-based network throughout its service territory. The
company argues that this obligation is outdated and inefficient in today’s competitive communications
marketplace, where consumers have access to a variety of broadband technologies offered by multiple
providers. AT&T seeks targeted relief to accelerate the deployment of advanced broadband services,
reduce waste, and ensure regulatory parity with its competitors.
The application outlines the changing landscape of telecommunications, highlighting the decline of
traditional copper-line telephone service in favor of broadband connections. AT&T emphasizes that most
Californians now rely on broadband for voice calls and have access to multiple alternatives to POTS (Plain
Old Telephone Service), including wireless and cable providers. Despite this shift, AT&T California is
burdened with maintaining its legacy copper network, which hinders its ability to invest in modern
broadband infrastructure and compete effectively.
The company argues that granting relief from the COLR obligation would enable it to reallocate resources
to deploy fiber and wireless broadband networks, particularly in underserved rural and tribal
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communities. AT&T highlights its initiatives to bridge the digital divide, such as providing affordable
broadband access and opening “Connected Learning Centers” for underserved students and families.
AT&T proposes a phased approach to COLR relief, where it would continue serving existing POTS
customers in areas without viable alternatives while transitioning away from tariffed voice service in areas
with competitive options. The application emphasizes the importance of prompt action from the PUC to
“facilitate broadband deployment and promote digital equity” across the state.
Impacted Areas
On December 13, 2023, AT&T released a list of localities across the state where they seek to withdraw as
the COLR. A full list can be found here and an interactive map can be found here.
Blue shaded sections represent the territory AT&T California seeks to withdraw from as a COLR; Violet
shaded sections represent the territory AT&T California may seek to withdraw from as a COLR in the future
through a streamlined advice letter process.
Implications of AT&T Withdrawing as the COLR
According to the PUC, an area without a COLR could mean that there would be no landline telephone
company serving that area and that there could possibly be no landline telephone access for customers
in that area.
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If AT&T’s proposal were accepted as set forth in its application, then no COLR would be required to provide
basic service in that area. This does not necessarily mean that no carriers would, in fact, provide service
in that area—only that they would not be required to do so.
Other outcomes are possible, such as another carrier besides AT&T volunteering to become the COLR in
that area, or the PUC denying AT&T’s proposal and AT&T continuing to be the COLR.
Update on PUC Proceedings
• On May 3, 2023, the Administrative Law Judge’s ruling ordered AT&T to amend its application due
to substantial incompleteness. AT&T’s application lacked essential information, including specific
census blocks affected by the proposed withdrawal of COLR obligations. The ruling emphasizes
the importance of identifying impacted communities, including their location, environmental
considerations, and alternative service providers.
• On November 21, 2023, the Assigned Commissioner issued a scoping memo and ruling,
delineating the procedural background of AT&T’s application. Notably, the ruling establishes a
timeline for evidentiary hearings, with AT&T’s opening testimony due by December 19, 2023, and
evidentiary hearings scheduled for April 2024.
• On November 21, 2023, the Public Advocates Office, The Utility Reform Network, the Center for
Accessible Technology, and the Rural County Representatives of California jointly filed a motion
to amend the procedural schedule The motion requested extensions for filing opening and
rebuttal testimonies, earlier public participation hearings, and other adjustments to subsequent
due dates. The parties conferred on the proposed amendments, with only AT&T opposed, and
the Joint Intervenors argue that the modifications are necessary to ensure adequate
representation and protect the public interest.
• On December 19, 2023, the Administrative Law Judge dismissed the joint motion to amend the
schedule filed by several intervenors, including the Public Advocates Office and The Utility Reform
Network. Despite AT&T California’s opposition to the motion, citing sufficient time for
preparation, the ruling acknowledges the need for an extension, proposing a revised schedule to
accommodate additional time for testimony preparation. While denying the seven-week
extension requested by the intervenors, the ruling grants a three-week extension. The proposed
decision is expected by September 2024.
PUC Public Hearings
The PUC will conduct in-person and virtual public forums to gather input from AT&T customers regarding
the company’s proposals to eliminate its obligation to provide voice services in its service areas. The forum
held on February 6 in Clovis has already taken place. Remaining forums are scheduled for February 22 in
Ukiah, March 14 in Indio, and a virtual forum on March 19 (details below). These forums will feature brief
overviews of AT&T’s proposals, presentations from involved parties, and opportunities for public
comments.
March 19th Virtual Forum
• Time: 2PM & 6PM
• Webcast Link: www.adminmonitor.com/ca/PUC
• Phone Call-In: 1-800-857-1917, passcode: 6032788#
• Note: Participants who choose to view via webcast will have audio and video but will not be able
to make verbal comments. If you would like to make comment during the forum, please call-in
and when prompted press *1 to be queued to make a comment.
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Concurrent Application to Relinquish ETC Designation
In addition to its application regarding COLR obligations, AT&T has concurrently applied to the PUC to
relinquish its designation as an ETC in certain areas of California. An ETC, as defined by federal regulations,
is a telecommunications provider eligible to receive financial assistance from the Universal Service Fund
to offer high-quality and affordable telephone service, including federal Lifeline support, to customers in
specific geographic areas. AT&T argues that relinquishing its ETC designation is necessary due to the
changing telecommunications landscape and its lack of eligibility for federal high-cost support. If
approved, this action could impact customers currently receiving federal Lifeline support from AT&T,
potentially resulting in increased monthly bills. Notably, the service area for AT&T’s ETC designation aligns
with its COLR service territory, meaning that areas affected by the withdrawal of its COLR obligations may
also be impacted by the relinquishment of its ETC designation.
Potential Opposition
Recent articles from Wired and the San Francisco Chronicle highlight growing concerns and backlash
against AT&T’s proposal to discontinue landline services in California. Residents, advocacy groups, and
public officials quoted in the media are voicing strong opposition to AT&T’s plans, citing potential safety
hazards, especially during emergencies or natural disasters.
Wired’s article underscores protest from residents and groups like the Rural County Representatives of
California, emphasizing the importance of landlines for emergency services. The piece discusses the
potential consequences of AT&T’s proposal, including the loss of reliable access to 911 and Lifeline
program discounts, as well as concerns about the reliability of alternative services like VoIP and wireless
in certain areas.
Similarly, the San Francisco Chronicle’s article highlights safety concerns raised by residents and
advocates, particularly regarding access to emergency services during crises. It features stories from
individuals who rely on landlines for critical medical needs. The article also mentions opposition from
groups like The Utility Reform Network, which argues that AT&T’s proposal would leave vulnerable
populations without a guaranteed telecommunications lifeline.
Considerations for Municipalities
Considerations for municipalities should include an awareness that while they may not be directly affected
by AT&T’s motions their residents could potentially be impacted. Municipalities may need to coordinate
with relevant agencies and stakeholders to ensure that the interests of their communities are represented
in PUC proceedings and that any resulting decisions align with local needs and priorities.
RPPG continues to monitor activities and will provide you with an update when a decision has been
proposed by the PUC.
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