BEFORE THE

Federal Communications Commission

Washington, D.C. 

In the Matter of )
)
Reducing Barriers to Network Improvements and Service Changes; Accelerating Network Modernization )

)

)

  

 

WC Docket Nos. 25-209, 25-208

 

 

 

Full PDF of Comments can be found here.

Comments of

Thomas A. Schatz

President

Citizens Against Government Waste

September 29, 2025

Citizens Against Government Waste (CAGW) is a private, nonprofit, nonpartisan organization dedicated to educating the American public about waste, fraud, abuse, mismanagement, and inefficiency in government.  On behalf of the more than 1 million members and supporters of CAGW, I offer the following comments regarding the Notice of Proposed Rulemaking on Reducing Barriers to Network Improvements and Service Changes (WC Docket No. 25-209) and Accelerating Network Modernization (WC Docket No. 25-208).[1]

CAGW appreciates and supports the Federal Communications Commission’s (FCC) efforts to eliminate, modernize, and reduce unneeded regulatory and reporting requirements currently imposed on communications service providers.  These changes include speeding up the replacement of aging infrastructure like copper wire, which went into use after Alexander Bell invented the telephone in 1876, leading to the first telephone exchanges in 1887.[2]  While improvements were made during the ensuing decades, the need for upgraded technology to transmit large volumes of data across the country has led to the development of newer technologies like cable, fiber, and wireless gateways.[3]

Many of the communications lines using copper wire are maintained and operated by carriers of last resort (COLR), which have obligations under Title II of the Communications Act to ensure universal service of plain old telephone services (POTS).  Their filing requirements are as follows:

These requirements are for domestic services only.  There are additional requirements for COLRs that also provide international services.

As the FCC has noted in a “Consumer Guide,” there are significant benefits to transitioning networks from copper wire to other technologies like fiber, which include higher speeds, lower signal loss, support for more advanced services and applications, longer life cycle with less frequent maintenance, and the use of materials conducive to easier deployment.[5]  This transition would significantly reduce outdated federal reporting requirements for copper wire use.  However, replacement of copper with more resilient materials is subject to state review and approval.

As vast amounts of data traffic move over the communications networks, copper wire is no longer essential, and where it is available, the risk of failures due to its susceptibility to water damage and power outages is increasing.[6]  Another threat to these systems has been caused by increased copper prices, which have led to a significant rise in vandalism and destruction of telecommunications infrastructure, hurting providers and consumers.[7]

A June 5, 2025, bulletin issued by California Attorney General Rob Bonita found that, “Between June and December 2024, the telecom industry alone reported nearly 6,000 incidents of copper theft and infrastructure vandalism nationwide.  Roughly one-third – or 1,805 – of those incidents happened in California.  Bad actors steal encased copper cables and cut them into short lengths before burning them to remove the sheathing to reveal the raw copper inside.  That copper is then typically sold to scrap metal dealers, some of whom, in periods of high demand, are willing to accept the valuable commodity purportedly without knowing its origin.”  The bulletin described that the thefts, and vandalism caused 911 emergency services disruptions; power outages; backups and safety hazards for public transit, freeways, bridges, and airports; service interruptions to streetlights and traffic lights; contamination of water and sewer systems; and disruption to healthcare systems and schools.[8]  This issue extends across the country.

Replacing or repairing copper wire networks with copper wire is costly for providers and diverts resources that could instead be used to upgrade and expand the lines and services with modern technology.  AT&T Executive Vice President of Federal Regulatory Relations Rhonda Johnson said, “the company spends $1 billion annually in California alone maintaining copper, despite 95% of customers having moved on.”[9]  Companies like AT&T replace copper with copper is because COLR requirements force them to maintain the status quo on their networks, despite the availability of materials that are far better and less expensive.  While states also impose certain requirements on COLRs, reducing some of the FCC’s COLR requirements will enable these companies to work toward using improved materials and create more resilient networks.

Again, CAGW appreciates the diligent work the FCC is undertaking in reducing federal regulatory burdens that create barriers to modernizing telecommunications networks, particularly for those networks that are still using copper wire.  Thank you for the opportunity to provide these comments.

[1] Federal Communications Commission (FCC), Reducing Barriers to Network Improvements and Services Changes; Accelerating Network Modernization, Notice of Proposed Rulemaking, WC Docket Nos. 25-209, 25-208, https://docs.fcc.gov/public/attachments/DOC-412688A1.pdf.

[2] Insight NOKIA, “A history of the copper telephone line,” NOKIA, August 6, 2014, https://www.nokia.com/blog/history-copper-telephone-line/.

[3] Kat Samiljan, “Blue Light Emergency Systems Get a Boost from Fixed Wireless Access for Enhanced Public Safety,” Government Technology Insider, October 14, 2024, https://governmenttechnologyinsider.com/blue-light-emergency-systems-get-a-boost-from-fixed-wireless-access-for-enhanced-public-safety/.

[4] FCC, “Common Carrier Filing Requirements – Information for Firms Providing Telecommunications Services,” https://www.fcc.gov/reports-research/guides/common-carrier-filing-requirements-information-firms-providing-telecommunications-services.

[5] FCC, “Tech Transitions: Network Upgrades That May Affect Your Service – Copper/Fiber,” https://www.fcc.gov/sites/default/files/tech_transitions_network_upgrades_that_may_affect_your_service.pdf.

[6] Timor Brik, “Cities Are Cutting the Cord on Copper Telephone Lines:  Is Yours Next?” Government Technology Insider, April 30, 2025, https://governmenttechnologyinsider.com/cities-are-cutting-the-cord-on-copper-telephone-lines-is-yours-next/.

[7] National Insurance Crime Bureau, “Thieves Turn Copper Theft into Gold,” Viewed September 26, 2025, https://www.nicb.org/news/blog/thieves-turn-copper-theft-gold.

[8] Office of California Attorney General Rob Bonta, “Attorney General Bonta: Copper Wire Theft Leaves Californians in the Dark, We Must Ensure the Lights Stay On,” June 5, 2025, https://oag.ca.gov/news/press-releases/attorney-general-bonta-copper-wire-theft-leaves-californians-dark-we-must-ensure.

[9] Jericho Casper, “Twenty-one States Push to Scrap Carrier-of-Last-Resort Laws,” Broadband Breakfast, April 11, 2025, https://broadbandbreakfast.com/twenty-one-states-push-to-scrap-carrier-of-last-resort-laws/.