Orientation summary — a fast, cited starting point, not a substitute for reading the filings. Generated from the public ECFS record.
Key issues (auto-discovered)
The effect of outdated regulatory requirements on network modernization efforts.
Filers split on: “The Commission should eliminate outdated regulatory requirements to reduce burdens and facilitate network upgrades.”
17 filers engaged this issue.
- Jeffrey Westling Westling Discontinuation (support) — The commenter supports a streamlined review process for applications certifying adequate replacement technologies to facilitate the retirement of legacy networks, arguing that current rules impose burdens on broadband providers and that updates are essential for encouraging investment in new technologies.
- TIA TIA Network Modernization (support) — The commenter supports the proposed reforms, believing they will enable providers to focus on deploying modern networks by simplifying outdated compliance processes, lower costs while preserving essential consumer protections, and provide regulatory certainty through the codification of existing waivers, ultimately facilitating a more efficient transition to next-generation infrastructure.
- WTA Advocates for Rural Broadband WTA Disconti (support) — The commenter advocates for removing outdated filing requirements related to grandfathered services and lower-speed data communications, which hinder progress.
- VPS Solutions (support) — The commenter believes that allowing forbearance for certain conditions will help carriers modernize their networks and comply with regulatory requirements.
- International Center for Law Economics (support) — The commenter argues that the current notification requirements impose unnecessary costs and divert resources from competition and infrastructure deployment, asserting that these regulations are outdated relics of a monopoly era that no longer provide public benefit. They advocate for a regulatory framework that minimizes these burdens, suggesting that the decline in ILEC market share and the availability of competitive alternatives indicate that market forces should govern inter-carrier relationships, and that forbearance would promote investment in modern infrastructure.
- Taxpayers Protection Alliance TPA (support) — The commenter argues that current regulations force providers to inefficiently replace old technologies with similar ones, and that outdated state requirements hinder the transition to modern technologies; they believe federal preemption would help facilitate a quicker shift to better serve customers.
The adequacy of FCC's public notice provisions for changes in telecommunications services.
Filers split on: “The Commission should enforce clear public notice requirements to ensure consumers are informed about service changes.”
13 filers engaged this issue.
- Wired Broadband (support) — The commenter advocates for the FCC to collect more information from consumers and providers regarding the reliability of current technologies and the implications of removing copper landlines, while also stressing the need for clear public notice standards to prevent confusion and ensure consumers are informed and able to contest service changes.
- Nina Beety 10 27 25 (support) — The commenter criticizes the FCC for failing to provide sufficient notice to the public regarding significant changes in telecommunications services, which undermines public participation.
- The Digital Progress Institute DPI Reducing Ba (oppose) — The commenter argues that the current notice requirements hinder innovation and are unnecessary, as they primarily serve to maintain the status quo rather than protect consumers.
- WTA Advocates for Rural Broadband WTA Disconti (oppose) — They argue that the current requirement for filing network change notifications is unnecessary and that posting the information online would suffice, reflecting the lack of opposition to previous notices.
- Lynne Campbell Landline Response to FCC 9 24 2 — The commenter argues that the FCC's 1996 guidelines do not adequately protect public health and serve corporate interests instead.
- TDIforAccess (support) — The commenter advocates for the FCC to take action to protect the communication needs of individuals who are Deaf, DeafBlind, DeafDisabled, hard-of-hearing, and those with speech disabilities during the transition from analog to IP-based systems, stressing that any new services must meet the needs of individuals with disabilities to ensure equal access.
The need for safeguards to prevent disruption of 911 services during network changes.
Filers split on: “The Commission should adopt safeguards to ensure 911 services are not disrupted by network changes.”
6 filers engaged this issue.
- Wired Broadband (support) — The commenter argues that the provisions are designed to ensure that any discontinuation of service does not adversely affect the public, emphasizing the importance of maintaining copper landlines.
- Bandwidth (support) — Bandwidth emphasizes the necessity of safeguards to prevent disruptions to 911 services during network changes, advocating for clear requirements for carriers. Additionally, Bandwidth contends that current rules should prohibit carriers from discontinuing essential interconnection services without adequate oversight, particularly concerning 911 services.
- Comtech Telecommunications (support) — Allerium contends that forbearance from statutory protections regarding circuits that carry 911 traffic is unacceptable due to the severe consequences, emphasizing the necessity for public notice and planning, as well as the importance of providing affected 911 authorities and PSAPs a meaningful opportunity to address potential service gaps before any discontinuances are approved.
- cindy Russell Physicians for Safe Technology P (support) — The commenter believes that removing landlines, which are critical infrastructure, poses risks to personal safety and national security, especially in emergencies when other communication systems may fail.
- INCOMPAS INCOMPAS (modify) — INCOMPAS argues that while some regulatory requirements can be streamlined, essential safeguards must remain to ensure competition and public safety, particularly regarding 911 services.
- Rachel McKinnis Keep copper landlines.docx (support) — The commenter raises concerns about the vulnerability of cell phone networks to cyber attacks, indicating a preference for the security of copper landlines.
The necessity of retaining copper lines for individuals with disabilities and those sensitive to electromagnetic frequencies.
Filers split on: “The Commission should deny any mandate to remove copper lines to ensure access for individuals with disabilities.”
5 filers engaged this issue.
- Rachel McKinnis Keep copper landlines.docx (support) — The commenter argues that many individuals are not compatible with wireless technology, leading to various health issues, which supports the need for copper landlines.
- Terry Tobey Keep Copper Landlines (support) — The commenter expresses a personal need for copper landlines due to health issues that prevent them from using cell phones. They emphasize the importance of having a reliable phone connection for emergencies and for accessing their computer.
- Anonymous FCC COPPER CABLE COMMENT (support) — The commenter argues that the FCC cannot mandate the removal of copper lines as it would violate the ADA by denying disabled individuals access to necessary services, and stresses that retaining copper lines is essential for providing access to life-saving services for those who cannot use wireless technology.
- Christina E. Bertea FCC comment re ATT land li (support) — The commenter urges the FCC not to allow ATT to abandon copper landline service, citing various health, safety, and environmental reasons.
- Lynne Campbell Landline Response to FCC 9 24 2 (support) — The commenter highlights the importance of landlines for those who are sensitive to electromagnetic frequencies and emphasizes the need for choice in communication methods.
The need for a formal process allowing public objections to service discontinuance proposals.
Filers split on: “The Commission should mandate a formal process for public objections before approving service discontinuances.”
4 filers engaged this issue.
- Wired Broadband (support) — The commenter believes that any proposal to discontinue services should involve a formal process that allows the public to voice their objections, shifting the burden of notification to the carriers rather than the public.
- The Digital Progress Institute DPI Reducing Ba (oppose) — The commenter argues that replacing one voice service with another should not require regulatory approval, as it does not constitute a discontinuance of service.
- WTA Advocates for Rural Broadband Service Disc (oppose) — WTA asserts that concerns about pricing for current or alternative services should not impede the Commission's efforts to streamline service discontinuation requirements.
- CPAC Foundation Center for Regulatory Freedom (oppose) — The commenter argues that current filing rituals are outdated and create unnecessary delays, suggesting a streamlined approach that focuses on public postings and targeted outreach to improve efficiency and transparency.
The adequacy of telecom companies' compliance with E911 service regulations and the need for backup power.
Filers split on: “The Commission should require telecom companies to meet enhanced E911 service obligations, including backup power provisions.”
3 filers engaged this issue.
- Jonathan Gibson PUC filing 5 28 19 (modify) — The commenter emphasizes the importance of considering the needs of businesses and schools in future discussions about E911 service and backup power, while also advocating for a thorough examination of how telecom companies are fulfilling their obligations under E911 service regulations.
- Doug Loranger FCC 25 209 Submission.Loranger (support) — The commenter emphasizes the critical role of landline services, particularly in emergencies when other utilities fail, highlighting their importance for first responders.
- INCOMPAS INCOMPAS (support) — INCOMPAS stresses the importance of maintaining these obligations to ensure competition and public safety during the transition to new technologies.
The impact of current discontinuance rules on the transition to modern networks.
Filers split on: “The Commission should simplify discontinuance rules to facilitate the transition to modern networks.”
3 filers engaged this issue.
- WTA Advocates for Rural Broadband WTA Disconti (support) — The commenter believes that the existing requirements for service discontinuance are outdated and should be simplified, especially given the availability of alternative technologies.
- The Digital Progress Institute DPI Reducing Ba (support) — The commenter believes that the current complicated rules for discontinuance slow down the transition to modern networks and should be simplified to facilitate upgrades.
- USTelecom The Broadband Association 2025 09 29 (support) — USTelecom argues that the pre-approval requirement for discontinuing legacy voice services is no longer necessary due to the availability of alternative services, and that conditional forbearance would streamline the process.
Most-cited authorities
- FCC 25-37 — cited by 18 filer(s)
- FCC 15-98 — cited by 7 filer(s)
- FCC-25-37A1 — cited by 5 filer(s)
- 47 CFR §214 — cited by 4 filer(s)
- 47 USC §151 — cited by 4 filer(s)
- 47 U.S.C. § 251(c)(5) — cited by 3 filer(s)
- 47 C.F.R. § 63.71. — cited by 2 filer(s)
- 47 C.F.R. § 63.01(a) — cited by 2 filer(s)
- 47 C.F.R. § 63.71(g) — cited by 2 filer(s)
- 47 CFR 15.107(a) — cited by 2 filer(s)
- 47 CFR 1.1307(b)(2) — cited by 2 filer(s)
- 47 CFR 1.1310(e)(1)(II) — cited by 2 filer(s)
Who filed (29)
Anonymous FCC COPPER CABLE COMMENT, Bandwidth, CPAC Foundation Center for Regulatory Freedom , California Public Utilities Commission WC Dkt , Christina E. Bertea FCC comment re ATT land li, Comtech Telecommunications, Doug Loranger FCC 25 209 Submission.Loranger, Gabriela Munoz FCC LegacyRules GM 05 26 26, INCOMPAS INCOMPAS, International Center for Law Economics, Jeffrey Westling Westling Discontinuation, Jonathan Gibson PUC filing 5 28 19, Kuiper Systems, Lynne Campbell Landline Response to FCC 9 24 2, NTCA The Rural Broadband Association NTCA Netw, National Association of State 911 Administrato, Nina Beety 10 27 25, Rachel McKinnis Keep copper landlines.docx, TDIforAccess, TIA TIA Network Modernization, Taxpayers Protection Alliance TPA, Terry Tobey Keep Copper Landlines, The Digital Progress Institute DPI Reducing Ba, USTelecom The Broadband Association 2025 09 29, VPS Solutions, WTA Advocates for Rural Broadband Service Disc, WTA Advocates for Rural Broadband WTA Disconti, Wired Broadband, cindy Russell Physicians for Safe Technology P