Mar 21 Oppose Letter for AT&T Application for Relief of Carrier of Last Resort Obligation

March 21, 2025

California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Re: AT&T Application Relief of Carrier of Last Resort Obligation – OPPOSE

Dear CPUC Commission,

On behalf of the Marin County Board of Supervisors, I write to join the many concerned counties that are requesting that the California Public Utilities Commission (CPUC) reject AT&T’s latest application for targeted relief from its Carrier of Last Resort (COLR) Obligations.

As the Carrier of Last Resort, AT&T must provide Plain Old Telephone Service (POTS) or landline phone service upon request to all residential and business customers within its service territory. AT&T is requesting once again that the CPUC relieve it of this obligation and allow it instead to decide whether to provide telephone service, even if no other telephone provider in the area is obligated to provide service.

Last year, Administrative Law Judge Glegola dismissed an identical application from AT&T to cancel services for more than 580,000 customers relying on POTS under AT&T’s COLR obligations. The issue saw widespread public opposition to AT&T’s application, with public participation exceeding 5,000 comments, and eight public forums in three cities across the state drawing more than 5,800 attendees. In its ruling, the CPUC found that AT&T failed to demonstrate the availability of substitute providers to replace their provision of COLR obligations, nor did AT&T prove that alternative providers met the COLR definition. Additionally, similar legislation in AB 2797 (McKinnor) – which sought to allow any COLR to no longer provide service in these locations if the provider submits a notice to the CPUC meeting certain requirements – also faced similar opposition and failed to pass through the State Legislature for the same reasons.

For some of our County’s most vulnerable residents, especially those in more geographically remote and rural areas without cell phone reception, approval of AT&T’s application would result in them paying more for telephone service, receiving lower quality service, being required to purchase phone service as part of an expensive “bundle,” or receiving no phone service at all. AT&T's application requests COLR relief in providing landline service for over 99% of its service territory where it determines an alternative voice provider exists (VoIP, wireless, etc.) and does not request a replacement COLR. Since the definition of “alternative voice provider exists” is based on demonstration that a carrier’s footprint covers only 50% of the census block, residents in the remaining 50% are in danger of having no phone service.  

Additionally, AT&T’s application describes the COLR requirement as an “underutilized landline telephone network,” however, in households with limited cell phone coverage, landlines are far from underutilized. Landlines provide essential communications, especially in emergencies, to households without cell coverage and/or other connectivity options. Over 580,000 AT&T customers would be affected – including 28,800 households in Marin County – many of whom are senior citizens, live in low-income households, or reside in rural areas where other connectivity is not available to them, placing their lives in jeopardy in the event of an emergency. This includes:  

• Approximately 630 households in west Marin who have no other option if the AT&T application is approved, and  
• Approximately 23,000 residents in suburban and urban areas that currently subscribe to AT&T’s plain landline service and may have to select a different carrier and/or pay more if the application is approved.

Over time, telecommunications firms (like AT&T) charged with providing this service and maintaining the state’s copper landline network have not taken necessary actions to maintain their networks, despite recording record profits from their consumer businesses. This deferred maintenance has created a growing logistical challenge, and the CPUC should not reward firms responsible for unmaintained networks with relaxed regulations that leave underserved populations vulnerable to disaster and loss of communication.  

The Commission’s consideration of a transition to wireless service should be methodical and pragmatic, driven by data collected by the Commission and its agents, not the firms they regulate, and should reflect the realities of not only California’s diverse topography, but also the refusal by profit-seeking telecommunications firms to invest in middle-mile and last-mile broadband for difficult-to-reach customers.

The Commission’s rules governing withdrawal of a COLR from its designated service territory should be revised to reflect the realities of modern technology. When considering a transition to wireless service should be methodical and pragmatic, driven by data collected by the Commission and its agents and should be reflective of the realities of California’s diverse topography and residents.  

Marin County opposes this AT&T application, as it will reduce access to essential communications services for our communities while increasing costs for those still covered. Much of rural Marin County is already under- or un-served, lacking universal access to reliable, secure, and open networks. This application does not address these inequities, but rather increases them.

Sincerely,  

Mary Sackett, President
Marin County Board of Supervisors

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