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Recently, as part of the "Delete, Delete, Delete" rule-cutting initiative, the Federal Communications Commission (FCC) launched a Notice of Proposed Rulemaking to explore the idea of forbearing from ILEC TDM interconnection requirements, as part of its goal of "advancing the IP transition". There is an overwhelming consensus in the industry that moving to IP everywhere in voice is a worthy goal; cost and flexibility, indeed, are key reasons carriers are keen to adopt IP, inasmuch as it doesn't sabotage key revenue sources (one reason ILECs still prefer TDM-based interconnection).
The period for comments and reply comments has pretty much ended, and having both submitted comments in this proceeding and read all the other comments and reply comments in WC 25-304, it's interesting to see the big picture view of the input that's been provided. I would largely categorize the comments received as belonging to a few key groups:
- Large ILECs — These are basically the three big RBOC conglomerates in existence: AT&T, Verizon, and CenturyLink/Lumen, as well as their industry associations, like US Telecom. These companies encouraged complete forbearance and a relatively lax regulatory landscape with "light touch" to almost no regulatory regime for IP interconnection. They see no problem with single points of interconnection nationwide (privately or over the Internet).
- RLECs — These are generally small ILECs providing phone service in rural areas, as well as their industry associations, such as NTCA–The Rural Broadband Association. These LECs overwhelmingly opposed premature forbearance, with particular emphasis on cost considerations to ensure rural subscribers do not end up abandoned or with an undue burden. Colocation is ILEC central offices is something to be preserved due to the investment that has been made in these points of interconnection. They also point to ILEC abuse in the exponential price increases for DS1s/DS3s, many of which are used for 911, and a need to ensure points of interconnection that are not Internet-dependent and geographically close to their subscribers. They point out ILEC proposals risk calls potentially having to travel roundtrip across the country twice for a call that might be "local" today, resulting in unacceptable latency and other quality issues.
- CLECs — There is some overlap with the RLEC group here in terms of comment themes, with most of these stakeholders adopting a middle ground between ILECs and CLECs, citing the need for a planned transition and certain protections to ensure quality and availability of service and access to 911. Intelliquent was among these commenters, but also added a unique perspective by proposing "National Transit Providers" (NTPs) which would continue to serve as the "carrier's carriers" for small RLECs and CLECs by indirectly interconnecting them to other carriers as needed.
- State PUCs and other groups — Some state public service commissions and other coalitions submitted comments, mostly those serving rural populations, such as North Dakota, Pennsylvania, Maine, and Alaska, the latter of which emphasized the importance of copper POTS service in Alaska, due to prolonged power outages that make IP-based end-user access service infeasible. States have emphasized that they possess a unique understanding of local issues and an ability to protect consumers in a way the FCC cannot and has failed to do. States emphasize they must continue to be involved in regulatory matters as they are today, and urge against federal preemption of state regulation, also arguing this oversteps FCC authority.
- Other industry groups and companies — Mostly a mix of other stakeholders, such as TNS, ATIS, Somos
As you can see, most commenters adopted positions that are consistent with their own interests. RLECs and CLECs overwhelmingly want to ensure that none of their subscribers lose service and that they don't have costs passed onto them from ILECs that would result in people being priced out of service, while larger ILECs overwhelmingly want as little regulation as possible in an IP future, which would allow their large size in a free market to push costs onto smaller providers. I am largely unsympathetic with the proposals offered by AT&T, Verizon, and CenturyLink in this docket. However, AT&T's comments are unique in several ways. Despite pushing for a fairly light regulatory landscape and advocating for policies that will inevitably harm rural subscribers, Verizon and CenturyLink at least make the pretense of pretending to care about overall welfare, with the obligatory cautionary notes about protecting 911 service and avoiding premature cutoffs to ensure that people don't lose service.
AT&T wants the FCC to preempt states from protecting consumers
AT&T on the other hand, makes no such pretense. It is quite blunt and to the point in its reply comments, making it clear the only reason that millions have not already lost service is because of the remaining regulations on the books. Right from the get-go, AT&T concurs with US Telecom in advocating for the wholesale preemption of state consumer protections nationwide:
We agree with USTelecom that the Commission should [preempt] any state obligations that would compel a carrier to continue providing legacy services after the Commission has authorized the carrier to discontinue that service The Commission [should] establish a December 31, 2028, sunset date for any remaining federal or state obligations to continue providing TDM voice services to end users.
Naturally, this would be a massive windfall for AT&T — repeatedly exposed as the Emperor with No Clothes by the California Public Utilities Commission, AT&T, rather than commit to ensuring nobody loses service during an IP transition, would rather have the FCC preempt California from protecting vulnerable consumers against a company that will stop serving anyone it deems unprofitable.
AT&T acknowledges it has not deployed IP in its ILEC networks to avoid regulatory interconnection requirements
AT&T goes on to admit that it chose not to deploy IP in its ILEC networks, since that would allow CLECs to demand Section 251(c)(2) interconnection for VoIP. AT&T is not alone in this practice, and this is not altogether unreasonable, considering the circumstances.
AT&T dismisses "universal service" as a goal for IP interconnection
AT&T goes on to state that universal service should not be a goal of any regime for IP interconnection, calling such goals a "distortion":
NTCA seeks to justify its proposal on the grounds that the Commission's "primary focus" should be on "universal service considerations" and the "affordability" of voice services in rural areas" it claims the rules the Commission adopts in this proceeding must "promote universal service objectives in an IP world" rather than promoting [economic efficiencies] more generally.
NTCA's arguments have it exactly backwards the current framework was consciously designed to ensure affordable rates for rural customers This proceeding offers the Commission a [chance] to establish a [framework] based exclusively on maximizing network and economic efficiency. That is the only way to avoid the distortions (regulatory and otherwise) of the current framework To the extent that doing so threatens affordability of service in rural areas the answer is not to establish a [framework] that implicitly subsidizes rural carriers and their customers.
AT&T essentially makes the argument that other carriers should not be implicitly subsidizing rural subscribers, as has been done historically. While understandable, given this increases others' interconnection costs for the greater good, AT&T offers no real alternative aside from "explicit support mechanisms [for rural areas]" (which already exist today as it is).
AT&T wants to kick all the CLECs out of its central offices
AT&T wants to decomission all of its central offices, as part of its initiative to end basic voice service wherever it can. However, it can't currently do that, since many CLECs have equipment colocated in these COs. So next, AT&T opines its COs should no longer serve as interconnection points:
CLECs argue the Commission should not forbear because they have relied on collocation to build their networks and offer competitive services depriving them of collocation rights, they maintain, would "strand these long-standing, paid-for arrangements and the substantial network investments built around them."
These CLECs' claims provide no basis for maintaining collocation obligations following the IP transition after that date, ILECs may cease providing legacy, TDM-based circuit switched services (including telephone exchange service and exchange access) — as will others. Once they do, CLECs will have no need to collocate equipment for interconnection.
In other words, AT&T has no plans to provide any kind of exchange service to people after 2028, and it doesn't want to allow CLECs to use its facilities to do so, either. Note how AT&T implicitly assumes that physical facilities will somehow magically no longer be required in a future with IP interconnection, and in its comments, AT&T says "CLECs will have myriad options for connecting with others" including "aggregators, negotiating direct interconnection, [or] over the Internet which will not require physical collocation". Except, of course, this is simply absurd, as all networks, IP or not, need points at which to physically interconnect, something acknowledged by virtually all the other commenters.
AT&T doesn't think public safety should be considered in the IP transition
Here's where things get seriously concerning, and where AT&T's comments stand alone from all others submitted to the FCC.
AT&T advocates forging ahead with the IP transition full speed, whether or not we're actually ready for it, and despite the risks this would pose to 911 service around the country. Let's briefly take a look at the current situation. Many CLECs testified in their comments about how premature retirement of TDM connections resulted in loss of 911 service:
Bandwidth reports two lengthy E911 outages in California in 2025, caused when long-haul TDM facilities were turned down unexpectedly following repeated price increases that rendered the facilities economically untenable. The rate escalation that preceded those outages is staggering. Bandwidth’s monthly DS3 multiplexing costs with one ILEC rose from $30,000 in January 2024 to $467,000 in November 2025. A Lumen ILEC subsidiary reclassified TDM interconnection services from switched access to business data services and increased monthly rates by as much as 200,000 percent. In one documented instance, a 911 T1 price in Boise, Idaho went from $17.22 per month in August 2025 to $32,291.98 per month in December 2025. These are not abstract pricing disputes. These are documented rate increases on facilities used to deliver emergency calls, and the operational consequence was the failure of 911 service.
Intrado, a nationwide provider of 9-1-1 services and the operator of one of the country's largest 911 routing platforms, documents an equally alarming pattern. In late December 2025, a major ILEC's decommissioning practices on multiple 911 ingress POI circuits used to deliver 911 calls to PSAPs in Denton County, Texas, South Carolina, and Indiana triggered an emergency response from Intrado and the affected ingress carriers, who were forced to rush 911 migrations over the holidays narrowly avoiding a major 911 outage prior to a January 7, 2026, decommission date. The ILEC conditioned a discontinuance extension on Intrado agreeing within 24 hours to pay $50,000 per month per circuit and waiving its right to file a complaint at the Commission, a demand made on the day before the scheduled decommission. In one documented instance, the ILEC was simultaneously the decommissioning carrier and the only user, through its own affiliate, of the 911 circuit slated for shutdown. These events confirm that the pattern documented by Bandwidth is not an isolated occurrence but a systemic practice affecting multiple independent 911 providers. Intrado corroborates this pattern from the perspective of a nationwide 911 services provider. Intrado reports that ILECs have used their facilities monopoly to increase TDM circuit prices from a few hundred dollars per month to over $20,000 to $50,000 per month, while simultaneously delaying their own migration of 911 traffic to SIP.
Keeping this in mind, let's now turn to AT&T's position on this matter.
Other parties have raised other objections including claims related to public safety, concerns relating to service quality of traffic delivered over the public internet For the reasons articulated by USTelecom in its comments and reply comments, which AT&T endorses but will not repeat here, concerns relating to public safety and service quality provide no basis for maintaining legacy voice interconnection and traffic exchange requirements after the sunset of TDM service, interconnection, and collocation obligations and the FCC should make clear that the framework it adopts will apply uniformly and thus that states will have no role in its implementation.
This is not a hypothetical scenario. 911 service disruptions have already occurred because ILECs got greedy and shut off circuits required for 911. And knowing full well that it has perpetuated this activity itself, AT&T would prefer that public safety simply not be a consideration in the IP transition, never mind how many 911 calls will fail and how many people will die as a result.
The disregard for service quality is also telling. AT&T has already advocated for Internet-based peering that could result, in the worst case, in calls transiting the country multiple times. Knowing that such calls will suffer markedly in quality compared to calls over today's TDM networks, AT&T advocates that service quality be disregarded.
Cumulatively, AT&T's comments paint a clear picture. They want the FCC to have as light a role as possible in regulating voice services in the future, and knowing that some states will try to protect consumers, AT&T desperately wants for the states to have no role at all. Essentially, voice service would just be another free market offering, unencumbered with rules or regulations, with few protections and little recourse if something doesn't work.
This is only the latest installment in a multi-year trend of AT&T's overt hostility towards consumers. They have repeatedly petitioned state regulatory bodies to be relieved of their basic service requirements around the country, even bribing state officials in Illinois to do so. Back in October, they grandfathered POTS service in all of their non-Californian service areas, and they grandfathered their long-distance service nationwide. They have already powered down their first entire wire center in Oklahoma, and they actually celebrated this loss of service as an important "milestone" (which it is, as far as the beginning of the end of universal, reliable voice service in the U.S.) Parading this sort of loss of service as "progress" is mindboggling doublespeak and simply disgusting. California is now the only state in AT&T's service territory where COLR has survived, at least for now; COLR is still at risk due to AT&T's efforts to bribe the California legislature through California AB470, and now, this NPRM from the FCC, if states are not left a say in the future of phone service in the U.S. And on top of all of this, AT&T has the audacity to claim that it's bridging the Digital Divide, when in fact, it's done more to widen it than any other company in the country.
While AT&T's comments are disturbing, they are hardly surprising. It has been hostile towards POTS and TDM technologies in general for years; while CenturyLink and Verizon have also made strides to "modernize" their network, Verizon has maintained traditional service over fiber in its service areas and still makes it easy to order this service if you want it. CenturyLink even promotes home phone service on its website. AT&T, on the other hand, has actively misled and lied to consumers about service availability for regulated services they are legally obligated to provide, something highlighted numerous times in comments to the CPUC (see pg. 46 footnotes in the CPUC Staff Proposal). Its so called "Advanced Phone" replacement solution for POTS is a laughable piece of garbage, basically an ATA that uses unreliable broadband and cellular connections for connectivity, a far cry from Verizon's commitment to providing at least either copper or fiber to everyone it serves. (To be clear, I'm not defending Verizon's track record on this subject either, but with its far superior customer service and a reasonable ideology of universal service, it's a marked and refreshing contrast from AT&T's approach.)
This isn't your grandfather's AT&T anymore (literally, the AT&T at the head of the Bell System in the days when the phone company was a good steward of the community and advocated for universal service for all in exchange for reasonable returns and a mutually agreeable regulatory regime). Today's AT&T that is virtually unrecognizable from the pre-Divestiture AT&T, one that is morally bankrupt, utterly lacking in corporate ethics and with unbounded greed that cares only about shareholder profit, at any cost, no matter how many people will lose service — or even die — as a result. AT&T does not care about you as a consumer, and it no longer makes any pretense of doing so. Its ugly agenda is now regularly laid bare for the community to see. Universal service for all is a thing of the past, replaced by service for only those that yield a handsome profit, at the cheapest possible cost.
It's actually terrifying how far backwards we've gone in the past five years towards ensuring everyone has reliable communications options, and even more terrifying knowing that things will only get worse from here. And, in the case of those in AT&T's ILEC territory, likely far worse. Even though I don't live in California, I've been immersed in battles for reliable communications services in California for more than a decade, rightly recognizing that a threat to communications anywhere is a threat to communications everywhere. Sadly, this is coming to fruition. Reliable voice service is quickly becoming the exception, rather than the norm it had been for almost a century.
For four decades now, we have experimented with eliminating regulations, and we have paid the price. Infrastructure that we took for granted for decades has become increasingly threatened and now on the brink of extinction in many places. Despite the industry narrative about "progress", there is something far more disturbing going on, behind the guise of competition and "technology-neutral" service requirements. It is a wholesale abandonment of our societal commitment to serving everyone — a commitment to ensuring that everyone had access, at just and reasonable rates. It is a commitment that AT&T has already abandoned, and one that is now threatened nationwide. AT&T's actions are not merely those of a company participating in a capitalist economy. They are the actions of a company that no longer has any moral backbone or any other ethics at all, aside from "shareholder profit". They are the actions of a company that is, in other words, pure evil.
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