From: Josh@cwa3105.org <Josh@cwa3105.org>
Sent: Friday, October 23, 2026 2:07 PM
To: 'mediarelations@fcc.gov' <mediarelations@fcc.gov>
Subject: Subject: Formal Inquiry/Complaint: Public Safety Risks of AT&T Phone-Advanced 911 Reliability and USF Funded Line Decommissioning
Dear FCC Consumer Inquiries and Complaints Division, Media Relations Office,
I am writing to formally log a public safety concern regarding AT&T’s deployment of the "AT&T Phone – Advanced" wireless local loop hardware as a replacement for traditional copper-based landline service, particularly in areas with spotty or unreliable cellular coverage.
The AT&T Phone – Advanced system relies inherently on a cellular signal or a home broadband network to transmit voice traffic. In rural and geographically isolated sectors where native cellular coverage is weak or highly unstable, this hardware fails to provide a resilient link to emergency services. If a localized cell tower suffers an outage, or if environmental factors degrade the wireless signal, the system leaves households entirely vulnerable and unable to successfully route a call to 911. Traditional copper lines historically operated under strict common carrier reliability standards with independent power delivery. Replacing them with wireless local loop technology in poor signal environments poses an immediate threat to life and public safety.
Critically, the areas where AT&T is actively removing physical copper lines are not being overlaid with fiber-to-the-home alternatives. Instead, consumers are being left with no viable choice other than these unstable cellular-reliant systems. Rather than modernizing the physical infrastructure with resilient fiber, carriers are completely abandoning wired networks in these communities.
Furthermore, severe weather hazards severely compound this public safety crisis. During heavy rain, dense cloud cover, or major storms, wireless local loop systems are susceptible to intense signal degradation and line-of-sight attenuation. For consumers who must rely on alternative satellite internet providers to keep the AT&T Phone – Advanced system connected, the situation becomes perilous. Severe weather triggers immediate "rain fade" or complete signal blackouts on satellite networks, drastically limiting or severing data connectivity exactly when an emergency occurs. If local cell towers are simultaneously degraded by storm conditions, a consumer has absolutely no way to connect to a 911 dispatcher. A physical landline is unaffected by cloud cover, yet its wireless replacement is entirely dependent on clear skies.
Equally alarming is the severe adverse impact this transition has on individuals with disabilities and specific accessibility needs. Traditional copper wirelines natively support analog life-safety infrastructure, medical monitoring equipment, and accessibility devices such as TTY (Teletypewriter) systems used by the deaf and hard of hearing. The AT&T Phone – Advanced system presents significant hardware and signal compatibility barriers for these essential devices. By replacing a highly stable, universally compatible wireline service with a cellular loop that exhibits poor analog transmission characteristics and spotty connectivity, the FCC and AT&T’s transition is effectively cutting off vulnerable populations from critical medical networks and emergency communications. For individuals who depend on consistent connectivity for their health, safety, and daily independence, this lack of compatibility is entirely unacceptable.
Furthermore, a glaring consumer protection issue arises when the AT&T Phone – Advanced system is utilized over a home internet connection provided by an alternative, third-party internet service provider (ISP). In this scenario, AT&T forces the consumer to pay them a full service fee for voice connectivity, yet AT&T does not supply the underlying data transport layer required for the service to function. Instead, the consumer must pay a separate bill to their third-party ISP to transmit the voice data. It is inherently anti-consumer and exploitative to allow a primary carrier to effectively double-charge the public for the same underlying product—forcing users to pay AT&T for dial tone while relying completely on an outside company's infrastructure to actually carry the call.
Furthermore, I am requesting a formal explanation regarding the oversight and allocation of the Universal Service Fund (USF). For decades, consumers have paid mandatory USF fees on their telecommunications bills specifically intended to build, upgrade, and maintain high-quality voice infrastructure in rural and high-cost areas.
If the public has collectively funded the maintenance of these resilient physical networks for years to ensure equitable access to vital communications, why is the FCC now permitting carriers to systematically decommission and turn off these exact lines without requiring an equivalent physical wireline replacement like fiber? Allowing carriers to abandon consumer funded infrastructure in favor of unstable cellular, weather-vulnerable, and non-accessible alternatives fundamentally undermines the core statutory mission of the Universal Service Fund.
I request that the FCC review the public safety implications of AT&T Phone – Advanced deployments in poor coverage zones, investigate these weather-induced emergency calling vulnerabilities, protect the accessibility rights of individuals with disabilities, examine these double-billing infrastructure inequities, and clarify how the decommissioning of USF-supported landlines aligns with the Commission's obligation to protect public safety and rural access.
Sincerely,
Joshua Saslovsky
Vice-President
CWA Local 3105
Jsaslovsky@cwa3105.org
352-247-7125
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