June 22 Oppose Unless Amended Letter for AB 470, Telephone carriers of last resort (June 19, 2025 Amendments)

June 22, 2025

The Honorable Assemblymember Tina McKinnor
California State Assembly District 61 
1021 O Street, Suite 5520 
Sacramento, CA 95814

Re: AB 470 (McKinnor), Telephone corporations: carriers of last resort (June 19, 2025 Amendments) – Oppose Unless Amended

Dear Assemblymember McKinnor,

On behalf of the Marin County Board of Supervisors, I write to respectfully express our opposition to AB 470, which would allow Carrier of Last Resort (COLR) relief for service providers, unless amended to incorporate stronger protections for our communities that continue to rely on Plain Old Telephone Service (POTS). While we appreciate the June 19 amendments that narrow the bill’s applicability, significant concerns remain about its impact on public safety, service reliability, and affordability for some of our most vulnerable residents.

AB 470 would allow a carrier of last resort (COLR), such as AT&T, to withdraw from its obligation to provide basic landline service in areas deemed “well-served”. The bill defines a "well-served" area as one where at least 98% of households have access to voice service at speeds of at least 25 Mbps download / 3 Mbps upload, and where at least three facilities-based voice providers (which may include mobile wireless or VoIP providers) are available. However, this criteria—particularly reliance on FCC broadband maps—do not accurately reflect on-the-ground service conditions in many parts of Marin County.

We remained concerned that many neighborhoods in Marin could meet the bill’s “well-served” definition and therefore qualify for COLR relief, but the on-the-ground reality is that cellular coverage is unreliable or unavailable, and VoIP service is not a dependable substitute—particularly during power outages or emergencies. Areas that may technically meet the bill’s “well-served” definition include Sleepy Hollow in San Anselmo, Tamalpais Valley, Marin City, parts of Novato and Ross Valley, and West Marin villages like Point Reyes Station, Bolinas, Tomales and Inverness – where mobile and broadband services are often overstated in official coverage maps. Under the current AB 470 amendments, these areas could all be classified as “well-served”, placing many residents at risk of disconnection. Copper landlines remain the most dependable method of reaching 911 and receiving emergency notifications.

Additionally, while the current amendments attempt to limit the bill’s scope to areas deemed “well-served,” they do not include any provisions to ensure affordability for affected residents. The bill only requires that at least one Lifeline provider offer service in the area; it does not guarantee continued access to basic, standalone affordable telephone service or prevent residents from being forced into bundled packages they cannot afford. Many low-income households and older adults in Marin County continue to rely on standalone basic landline service, which is often more affordable and reliable than bundled digital alternatives. Without protections in place, these residents may be forced into higher-cost service packages that include internet or mobile features they neither need nor can afford. We strongly urge the inclusion of explicit affordability safeguards to ensure that vulnerable populations—particularly seniors, individuals with disabilities, and those on fixed incomes—can maintain access to essential voice service without undue financial burden.

Finally, we are also concerned that AB 470 places the burden on individual residents or stakeholders to challenge COLR withdrawal decisions through an appeal process. While the current amendments require a 30-day public notice period before a COLR application can be approved, the bill does not mandate meaningful engagement with local governments or residents beyond this limited notification window, nor does it require hearings or consultations in affected communities. This structure assumes that impacted residents are aware of the proposed changes, have access to regulatory proceedings, and possess the time, resources, or legal knowledge to file a formal protest with the CPUC. For many of our communities most at risk—this expectation is both impractical and inequitable. We urge the Legislature to consider shifting this burden by requiring more proactive public engagement and local government consultation prior to any approval of COLR withdrawal.

Marin County recognizes the importance of supporting a responsible transition to modern communications networks. However, we believe that such a transition must be designed to preserve affordability, ensure service continuity in all communities, and reflect real-world service reliability.

For these reasons, we respectfully request that AB 470 be amended to:

• Require on-the-ground verification of service availability before designating any area as “well-served”;
• Include affordability protections for low-income residents who may be impacted by the loss of basic landline service;
• Allow local government to provide meaningful input prior to COLR withdrawal decisions;
• Establish a more accessible and proactive process for public notice and engagement, so that individual residents are not responsible for identifying and challenging COLR withdrawal proposals.

Absent these changes, Marin County remains opposed to the bill.

Sincerely, 

Mary Sackett, President
Marin County Board of Supervisors

CC:       Marin County Board of Supervisors
            Assemblymember Damon Connolly
            Senator Mike McGuire