FCC Eases Copper Network Shutoff Rules for Telecom Industry

On March 20, 2025, the FCC's Wireline Competition Bureau issued four separate orders modifying rules governing copper network retirements. The bureau acted on its own authority, bypassing the need for a vote by the full commission.

The first order clarified that carriers seeking to discontinue copper service under the "Adequate Replacement Test" can demonstrate replacement service adequacy through a "totality of the circumstances" showing rather than conducting the performance testing specified in the 2016 Technology Transitions Order. According to the FCC, this clarification addresses "apparent confusion" that had prevented carriers from pursuing technology transition discontinuances.

AT&T became the first carrier to apply for a technology transition discontinuance under the Adequate Replacement Test in July 2024. The company initially committed to performance testing methodology, which the FCC said "delayed the filing of its discontinuance application for several months."

The second action granted a two-year waiver to USTelecom, allowing carriers to retire copper networks even when replacement voice services are only available as part of a bundle with broadband, rather than on a standalone basis. USTelecom had filed the waiver petition in February 2025, arguing that "inefficiencies of offering stand-alone voice can raise costs for consumers and reduce capital available for investment."

The third order waived requirements that triggered when carriers "grandfathered" legacy services by stopping new customer enrollment. Carriers can now grandfather services without filing discontinuance applications with the commission.

The fourth action provided a two-year waiver of filing requirements under the FCC's network change disclosure rules, eliminating the associated public notice process and objection procedures for interconnected service providers.

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Chairman Carr stated that "outdated FCC rules have left Americans sitting in the slow lane for far too long" and that regulations "have forced providers to pour resources into maintaining aging and expensive copper line networks instead of investing in the modern, high-speed infrastructure that Americans want and deserve."

The FCC's press release indicated the agency is "keeping consumer protections in place, including requiring interoperability and guarding against price hikes by ensuring that consumers transitioning to new networks get access to services at similar or lower price points."

USTelecom's Jonathan Spalter claimed the decision would "help turbocharge investment in advanced broadband infrastructure, sustain and grow a skilled broadband workforce, bring countless new choices and services to more families and communities, and fuel our innovation economy."

Harold Feld of Public Knowledge disputed the FCC's characterization, telling Ars Technica that the clarification on testing requirements, "combined with elimination of most of the remaining notice requirements, means that you don't have to worry about actually proving anything. Just say 'totality of the circumstances' and by the time anyone who cares finds out, the application will be granted."

The FCC order noted that more than 1,100 network change disclosures had been filed with the commission since 2021 without oppositions, which the bureau cited as justification for eliminating the objection process.

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Telecommunications carriers gain significant operational flexibility under the new rules. The elimination of mandatory performance testing reduces the time and cost associated with copper retirement applications. AT&T's July 2024 application was delayed several months due to testing requirements, according to the FCC.

The two-year waiver allowing bundled voice services instead of standalone offerings gives carriers more flexibility in designing replacement service packages. USTelecom argued this would reduce costs and free capital for infrastructure investment.

Carriers can now grandfather legacy services without filing discontinuance applications, streamlining the process of phasing out older offerings. The waiver of network change disclosure filing requirements eliminates administrative burden associated with notifying the commission and responding to potential objections.

The FCC stated that consumer protections remain in place, including requirements for service interoperability and price parity for customers transitioning to new networks.

Consumer advocates raised concerns about reduced oversight of the transition process. Harold Feld noted that "the one positive thing is that some states (such as California) still have carrier of last resort rules to protect consumers. In some states, at least, consumers will not suddenly find themselves cut off from 911 or other important services."

The California Public Utilities Commission rejected AT&T's request to end its landline phone obligations in a June 2024 ruling. AT&T has obtained deregulation in its other 20 wireline states, creating a patchwork of consumer protections across the country.

Neither the FCC announcement nor industry statements addressed fiber deployment as a replacement option. As Ars Technica reported, AT&T plans to deploy fiber in only the more densely populated half of its 21-state territory, with wireless serving as the replacement in more sparsely populated areas. Wireless service quality and speed vary significantly depending on location and network congestion.

The elimination of the objection process for network change disclosures removes a mechanism for interconnected service providers to raise concerns about transitions affecting their operations.

The changes were adopted without a vote by the full commission, using bureau-level authority. The FCC currently operates with a 2-2 partisan split, though a Republican majority is expected after one Democratic commissioner resigns.

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Copper telephone networks, also known as the Public Switched Telephone Network (PSTN), use twisted-pair copper wires to carry analog voice signals from customer premises to central offices. Digital Subscriber Line (DSL) technology transmits data over these same copper pairs, providing internet access at speeds typically ranging from 1 to 100 Mbps depending on distance from the central office and line quality.

The "technology transition" refers to the process of replacing copper infrastructure with alternative technologies. Fiber optic networks use glass or plastic strands to transmit data as light pulses, offering significantly higher bandwidth and reliability than copper. Wireless alternatives include fixed wireless access using cellular networks or dedicated wireless internet service providers.

The Adequate Replacement Test, established in the 2016 Technology Transitions Order, requires carriers to demonstrate that replacement services offer "substantially similar network performance and availability" to discontinued copper services. The test includes provisions for geographic coverage, service availability, and network performance metrics.

Under the original rules, carriers could satisfy the test either by certifying compliance with specific testing parameters or by showing adequacy based on the "totality of the circumstances." The March 20 clarification confirms that carriers choosing the totality approach need not conduct the technical testing specified in the 2016 order's Technical Appendix.

Technical context (optional): The 2016 Technology Transitions Order established specific testing methodologies including latency measurements, packet loss rates, and jitter specifications for voice over IP services replacing traditional circuit-switched telephony. The "totality of the circumstances" alternative allows carriers to present other evidence of service adequacy without meeting these specific technical benchmarks.

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The FCC's actions signal a regulatory shift toward industry self-certification in network transitions. Chairman Carr indicated that additional rule eliminations would follow, stating the goal is to "ultimately free up billions of dollars for new networks that otherwise would have been diverted into costly and outdated copper lines."

The telecommunications industry has long sought relief from copper maintenance obligations. AT&T's December 2024 statements about benefiting from a Republican-led FCC reflected broader industry expectations for deregulation under the new administration.

State-level regulations create an uneven landscape for copper retirements. California's carrier of last resort requirements, upheld in June 2024, prevent AT&T from abandoning landline service in that state regardless of federal rule changes. Other states have granted carriers the deregulation they sought, leaving consumer protections dependent on geography.

The bundled service waiver addresses a tension between carrier business models and consumer choice. Standalone voice service allows customers who only need telephone access to avoid paying for broadband they do not want. The waiver permits carriers to require broadband purchases as a condition of voice service during copper transitions.

The elimination of the network change disclosure objection process affects not only consumers but also competitive carriers and interconnected service providers who previously had a formal mechanism to raise concerns about network modifications affecting their services.

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Confirmed:

• The FCC's Wireline Competition Bureau adopted four orders on March 20, 2025
• Carriers can now use "totality of the circumstances" showing without performance testing
• USTelecom received a two-year waiver for bundled voice service requirements
• Grandfathering legacy services no longer requires discontinuance applications
• Network change disclosure filing requirements are waived for two years
• AT&T plans to eliminate copper in its 21-state wireline territory
• California's carrier of last resort rules remain in effect

Unclear:

• How carriers will demonstrate service adequacy under the totality standard
• Whether the two-year waivers will be extended or made permanent
• The timeline for additional rule eliminations Chairman Carr referenced
• How many customers will be affected by copper retirements in the near term
• Whether other states will strengthen or weaken consumer protections in response
• The specific replacement technologies carriers will deploy in different regions

The FCC's composition will change when the departing Democratic commissioner's seat is filled, giving Republicans a 3-2 majority. Additional deregulatory actions are expected once the new majority is in place.

AT&T's copper retirement applications, including the July 2024 filing that prompted the testing clarification, will proceed under the new rules. The pace and scope of AT&T's network transitions across its 20 deregulated states will indicate how carriers use the expanded flexibility.

State regulatory responses bear monitoring. California's June 2024 decision demonstrated that state commissions can maintain consumer protections independent of federal action. Other states may face pressure from carriers seeking similar deregulation or from consumer groups seeking California-style protections.

The two-year waiver periods for bundled service requirements and network change disclosures will expire in March 2027. Industry petitions for extensions or permanent rule changes will signal whether the waivers achieved their stated goals.

Consumer complaints and service quality data from areas where copper has been retired will provide evidence about whether replacement services meet the "substantially similar" standard the FCC claims to maintain.

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1. Ars Technica, "FCC Chairman Brendan Carr starts granting telecom lobby's wish list," Jon Brodkin, March 20, 2025. https://arstechnica.com/tech-policy/2025/03/fcc-chairman-brendan-carr-starts-granting-telecom-lobbys-wish-list/

2. USTelecom, "Statement on FCC Cutting Red Tape to Unleash New Infrastructure Investments," March 20, 2025. https://www.ustelecom.org/statement-on-fcc-cutting-red-tape-to-unleash-new-infrastructure-investments/

3. Federal Communications Commission, Order DA-25-250A1, Wireline Competition Bureau, March 20, 2025. https://docs.fcc.gov/public/attachments/DA-25-250A1.pdf