BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA
Order Instituting Rulemaking Proceeding to Consider Changes to the Commission’s Carrier of Last Resort Rules
Rulemaking 24-06-012
OPENING COMMENTS OF EMF SAFETY NETWORK
REGARDING CARRIER OF LAST RESORT AND NETWORK MODERNIZATION STAFF PROPOSAL R.24-06-012
Introduction
EMF Safety Network submits these Opening Comments in response to ALJ Thomas J. Glegola’s December 15, 2025 ruling on the Communications Division’s Staff Proposal for Carrier of Last Resort and Network Modernization. Parties have been directed to submit comments on the proposed changes and specifically address a number of recommended solutions discussed in the staff proposal.
EMFSN is a non-profit 501(c)(3) organization authorized pursuant to its articles of incorporation and bylaws to represent and advocate the interests of residents and small commercial customers of electrical, gas, water, and telephone utilities in California. In brief, our organization’s mission is “to educate and empower people by providing science and solutions to reduce EMFs, improve lives, achieve public policy change, and obtain environmental justice.”
General Comments
The CPUC is to be commended for giving considerable attention to this challenging topic. Input was received from a number of sources, including in person public meetings held in various cities throughout California. Numerous online comments were obtained in the CPUC online docket, and the comment portal still open for submission. Five party participant “meet and confer” sessions were held from February to June 2025, and written responses from participants were requested. As a result of this extensive study, staff has come up with a variety of options and recommended solutions for consideration.
Despite the efforts of the CPUC to consider all avenues of input and maintain an objective viewpoint, we are aware that they are subject to significant industry pressure, as well as the FCC’s heavyhanded rulemaking, such as the recent 25-208, “Accelerating Network Modernization,” and 25-209, “Reducing Barriers to Network Improvements and Service Changes.” Commissioner Brendan Carr, in his July 24, 2025 statement, promoted these rulemakings “to accelerate the transition from aging copper line networks to modern, high-speed ones.”There was also the industry sponsored CA bill, AB 470, titled, “Telephone Corporations, Carrier of Last Resort,” with the goal of retiring copper landlines that was defeated last fall.
As The Public Advocacy’s office stated: “AB 470 was written and sponsored by AT&T to override the CPUC process and eliminate its obligation to provide basic phone service – with no legal mandate to improve service…. The CPUC already has a plan to modernize service while protecting public safety. AB 470 would sideline that process and put Californians – especially those in rural and low-income communities – at risk.”
The Public Advocacy’s office also included an important point about ensuring public safety when it came to legislating control over network modernization.
“More than 1 million emergency calls in California are still made each year over copper landlines, often in areas where mobile service is unreliable or unavailable. The CPUC’s public record includes powerful pleas from residents who survived life-threatening emergencies only because their landline worked when their cell phone failed. Any law that weakens universal service obligations must take these stories seriously and prioritize public safety. According to data from the California Office of Emergency Services, even a 1% decline in service on copper networks could mean 10,000 emergency calls fail to connect. That’s not a risk the state can afford to take.”
Recently, AT&T’s Susan Johnson, senior EVP, transformation and global supply chain, was interviewed by Light Reading senior editor, Jeff Baumgartner:
“We have a bit of a two-part strategy going on,” Johnson said. “We are scaling the discontinuance filings in areas of the country that we’re calling ‘wireless-first,’ where we will be using our fixed wireless and APA [AT&T Phone-Advanced, the company’s service replacement that can run on wireless or fiber] products as the upgrade for the customers…”
Baumgartner explains: “That two-phased angle is coming together as AT&T moves ahead with its mission to shut down the bulk of its power-hungry copper network by 2030. AT&T’s initiative is underway in 20 states. California remains the lone holdout as AT&T continues to work with regulators in the Golden State.”
“Meanwhile, AT&T has more work to do in California to ensure that regulators understand that the migration will provide copper customers not only everything they get from POTS today, but an overall improved offering. The state also has other priorities to consider, including awards for the BEAD program.”
“We are continuing to work with the CPUC [California Public Utilities Commission] to work through a process to try to modernize within California,” Johnson said. Meanwhile, Johnson said it’s paramount for AT&T to communicate with customers about the process and the upgraded services they’ll get from the migration.
“We have learned more and more about the importance of communicating, communicating, communicating with our customers,” she said. “This isn’t about taking something away from customers. It really is about an upgrade and continuing to make sure we’re communicating that you can keep the same phone number. Everything will work in your household the same. Your existing equipment will still function the same way.”
This last comment by Johnson illustrates the type of customer confusion that is occurring regarding AT&T’s network modernization. The existing equipment will not function the same way when it requires a router that is dependent on electricity or a wireless signal to transfer voice conversations.
By the way, AT&T estimates it has recycled about 112 million pounds of copper so far.
EMF Safety Network submits this information about AT&T to highlight our concerns as they move forward with network modernization. Even now, they are not supporting customers who require service on copper landlines as required by the CPUC as Carrier of Last Resort. Who will hold their feet to the fire when they fail to deliver on their obligations?
We understand their position that maintaining copper legacy networks are an expensive annoyance that they want to eliminate. However, customers have been paying additional fees on their phone bills for decades to ensure infrastructure resiliency.
CPUC’s Guarantee of Universal Service
As the CPUC states in the executive summary of their staff report, universal service must to be made available to all Californians, no matter where they live. The principles of high quality communications services, where every residence in any geographical location will have dependable, reliable, and affordable access, is now codified in Public Utilities Code Section 709.
As stated by the staff report, “The Commission’s COLR rules should deliver essential communications services that Californians need and rely on, and COLR rules should be modernized to ensure every Californian continues to have access to essential communications services in the interest of public safety and keeping Californians connected.” But we contend that this must not be at the expense of copper landlines that so many rely on for basic service. This is especially critical for seniors and for individuals disabled from wireless radiation.
These vulnerable citizens are not uninformed or stubborn people who are refusing to adapt to modernization. They are justifiably alarmed that a dependable form of communication that they have relied on for so many decades, one that doesn’t harm them, is going to be removed. These people can’t tolerate wireless signals in their living space and have difficulty finding safe spaces outside their homes in our increasingly wireless world of cell phones, cell towers, wi-fi, and RFR emitting devices. Their home is their safe space and must be protected.
If their landline is removed, they will be faced with a complex set of problems, which includes having to obtain a non-radiating router for fiber optic or VOIP with no wireless signal. They will also have to hire a tech to help them set up phone connections in multiple rooms, as many people require more than one phone in their home. On top of that, as the CPUC has proposed, customers will need a battery back-up in case they lose power. They will also need help installing, testing, and initiating its operation when needed.
In summary, EMF Safety Network has following list of concerns regarding network modernization:
Legacy landline alternatives not reliable in disasters
We have all heard the stories (or experienced first hand) the fact that copper landlines were the only means of communication during our devastating fire disasters. In these emergency situations, cell phone communication was not available and electrical power was out for a number of days.
If copper landlines are gone, we will need a wireline option, but the 72 hour back-up battery that is proposed might not be long enough to ensure connectivity in extended power outages. In addition, customers may not know how to obtain a battery back up or how to use it effectively. This is especially true for seniors and the disabled.
Customer confusion by AT&T and refusal or long delays for repairs
People have reported being misled by AT&T customer service reps that say copper landlines are no longer being serviced or it could take weeks before a needed repair. AT&T has admitted that they are not keeping track of customer complaints. Many are also being told that new legacy lines are no longer being installed, as AT&T is modernizing their network. People have reported that multiple calls are required to finally get a receptive AT&T rep on the line.
Community Phones and other wireless phone companies confuse customers
Potential customers are being told they can keep their landline if they switch to another type of service (like Community Phones). But actually, all they get is to keep their phone number and the use of their landline corded handset, but it’s plugged into a wireless network, not a copper landline. Once a confused customer realizes the phone actually works on the wireless network, they can have problems getting their copper connection reinstalled. It sounds like AT&T is engaging in similar language to potentially confuse customers.
Costs to maintain two services and the 95 percent
Companies such as AT&T are saying that most people (up to 95%) are abandoning copper, but here’s why: As mentioned, there’s the lack of customer service for repairs or new installations. There are also high costs for keeping both a cell phone plan and paying for a landline. Many people we’ve spoken to who have given up a landline say they miss it, but need to reduce expenses, and a cell phone is an absolute necessity in case they have an emergency on the road.
Competition
It is assumed by the CPUC that telecom competition will drive costs down. But there is increasing consolidation of large providers such as the recent CPUC approved Frontier and Verizon merger. CPUC regulations must protect consumers and not rely on uncertain and mercurial market competition.
Human bodies are not “Technology Neutral”
Current COLR service requirements are “technology neutral.” However, as we know, an increasing number of people are experiencing adverse reactions to wireless technology and some have become sick and disabled. Effects are cumulative… the longer and more extensive the exposure, the worse the reactions and the greater the number of people affected. At some point, even small additional exposures can be completely debilitating, even life threatening. Wired (fiber optic and wireline) technology is superior when it comes to protecting human bodies but only if the wireless in the routers and modems can be turned off and an ethernet connection installed. Copper landlines (POTs) do not expose the users to radiofrequency radiation.
Problems with VOIP and Fiber Optics modems and routers
Since both these services require electrical power to work, the CPUC is recommending the availability of a battery back-up for 72 hours for a VOIP or fiber optic connection. But what happens if the emergency lasts longer than three days? In addition, we have been told that each piece of equipment in the distribution chain (the network) needs a battery back-up to ensure connection, not just the end user. This includes the central office, the cable ends, the fiber terminal equipment (often used), the amplifiers, etc. Every piece of equipment needs to be getting power. With POTs, it’s simple. Copper carries its own voltage supply on the wire.
Turning off antennas on modems and routers
For those customers who need to reduce the radiation in their home environment and are required to use VOIP or fiber optic by default, a simple way to turn off the radiating antennas on the modems and routers is needed. For these options, a simple on/off switch to turn off the antennas should be required. At present, it’s often necessary to purchase a third party modem/router to effectively deactivate all antennas in these devices.
Phones in multiple rooms
If customers want to have phones in multiple rooms, it’s assumed that users will have a cordless phone base station that will wirelessly communicate with other phones throughout the house. That’s another source of wireless radiation that many who get sick from wireless can’t tolerate. They will need to hire a tech person to install wires from the unit that can transmit the corded signal to other rooms. Who will explain this to a disabled or elderly customer who may not know their options?
Warnings to Customers
Regarding the a timeline for customers to receive warnings if their existing carrier will no longer be a COLR, the CPUC wants to know how many notices would be required, how would they be distributed, and what sort of alternatives would be suggested to reduce customer confusion. We would recommend at least three separate mailings with both a phone number to call for further information (so they can talk to a live person) as well as a website. There are seniors who aren’t computer savvy so instructions have to be simple and straight forward.
Coverage maps to decide if a COLR is needed
As pointed out by many of the advocacy groups, (and even mentioned by the ALJ), provider coverage maps can be inaccurate and inconsistent. Therefore, we request that the CPUC require granular data (on the ground testing, etc.) to confirm claimed coverage.
Obtaining customer-centered data on the needs of people with disabilities
As stated by many commenters in the on-line portal, legacy copper wireline (POTs- Plain Old Telephone Service-) still remains the most dependable, reliable, and safest means of communication for a significant portion of our population, especially those who are disabled due to EHS (Electromagnetic Hypersensitivity) or EMR-S (Electromagnetic Radiation Syndrome). We must extend the same accommodations to these individuals as we do to people with other disabilities. Everyone deserves fair and equal access to safe, accessible, and reliable phone service.
In Conclusion
Further comments will be forthcoming in response to the submissions by other parties. This includes a response to the January 23, 2026 comment in the CPUC docket from Supervisor Eric Lucan President, Marin County Board of Supervisors on behalf of the Boards of Supervisors for Marin, Napa, Humboldt, and Sonoma Counties.
Thank you for the opportunity to submit these comments on these important issues.
Respectfully submitted,
Sidnee Cox, President and Co-Director
EMF Safety Network
PO Box 342
Windsor, CA 95492
707-837-5032
sidnee@sonic.net
Dated: January 30, 2026, at Windsor California.