Understanding the COLR Joint Proposal with AT&T – Frequently Asked Questions

The Public Advocates Office entered into the Joint Proposal to ensure that any transition away from legacy copper telephone networks results in clear benefits for customers and enforceable safeguards, rather than simply reducing regulatory obligations for telecommunications companies.

Communications networks are undergoing a technological transition as consumers increasingly rely on fiber broadband, wireless services, and internet-based communications instead of traditional copper telephone lines. AT&T has historically fulfilled its existing COLR obligations with an aging copper network and has sought to be relieved of certain Carrier of Last Resort (COLR) obligations and invest in an expansion of modern networks using fiber and wireless technologies.

The Public Advocates Office engaged in the Joint Proposal to ensure that any grant of such relief be tied to mandatory infrastructure investment and continued service protections. The proposal changes how the COLR obligation can be fulfilled as networks modernize – it does not eliminate the obligation to ensure communications access.

Specifically, the Joint Proposal requires that a carrier seeking to be relieved of its legacy COLR obligations must:

• deploy significant new fiber infrastructure in California
• continue offering voice or broadband service throughout the transition within the areas where the COLR is seeking relief
• participate in the low-income assistance program called California LifeLine
• comply with CPUC oversight and reporting requirements

The Joint Proposal does not determine the final outcome of the proceeding. The CPUC will review the proposal and may adopt, modify, or reject it. Our goal in participating was to ensure that network modernization produces tangible benefits for consumers while preserving essential communications access.

No. The Joint Proposal does not eliminate the obligation to serve. Instead, it allows that obligation to be fulfilled using modern communications infrastructure rather than legacy copper networks. The Joint Proposal, therefore, does not allow a COLR to simply walk away from serving customers.

Under the proposal, a COLR seeking relief must submit a formal filing to the CPUC (called a Tier 2 Advice Letter) identifying the area where it is requesting relief and committing to a binding fiber deployment requirement.

Even after being granted relief, the exiting COLR must continue to offer voice or broadband service throughout the Relief Area using any available technology. The CPUC retains its full enforcement and regulatory authority to protect consumer access, including authority over service quality, disaster response, and general consumer protection.

The Joint Proposal is intended to manage the transition away from legacy copper networks by requiring the exiting COLR to deploy new fiber infrastructure while ensuring that customers continue to have access to communications services.

Yes. Ensuring reliable access to 911 and emergency communications services is a central issue in this proceeding.

Under the Joint Proposal, carriers must continue offering voice or broadband service throughout the geographic area where they seek relief (referred to as the “Relief Area”), which means customers will continue to have access to communications networks capable of supporting emergency calls.

The Public Advocates Office has also recommended that the CPUC adopt strict standards before allowing wireless services to replace traditional telephone service over copper networks. These recommendations include:

• collect wireless signal coverage data directly from carriers
• verifying wireless coverage inside homes and buildings
• establishing voice call quality standards comparable to traditional wireline service
• requiring testing and verification of wireless service reliability

The burden to preserve service remains squarely with the CPUC and the COLR retiring copper. By right, every customer retains access to voice or broadband service and customers can seek CPUC intervention if that service is not provisioned by the exiting COLR under the Joint Proposal.

These safeguards are intended to ensure that modern communications technologies provide reliable access to emergency services, even as older copper networks are phased out.

AT&T’s original proposal to the CPUC in 2023 and the legislative proposal (Assembly Bill 470) it had sponsored in 2025 allowed the company to abandon customers as part of its pursuit to expand its modernized system. Numerous stakeholders, including our Office, opposed these measures and both proposals were rejected. However, AT&T’s core incentive to transition away from maintaining aging copper telephone networks and move customers onto modern communications infrastructure is not wrong.

In practical terms, this means companies want to:

• stop maintaining increasingly expensive copper networks
• migrate customers to fiber or wireless services
• reduce operating costs
• operate on modern communications infrastructure

Fiber networks are generally less expensive to maintain than aging copper networks and can support multiple communications services, including broadband and voice.

The Joint Proposal is designed to ensure that if carriers transition away from copper networks, they must reinvest in modern infrastructure. It is designed to provide an accelerated regulatory process to facilitate that outcome because it couples the regulatory changes with mandatory build out of fiber optics. In effect, the proposal links the retirement of legacy copper infrastructure to new fiber investment in California and will yield one of the largest government mandates on fiber in history.

Put simply, the Joint Proposal says:
If a carrier wants to retire copper networks, it must reinvest in fiber infrastructure in California while maintaining voice or broadband service.

The Joint Proposal requires that fiber deployment be prioritized in pre-identified low-income and disadvantaged communities within the areas where a company is seeking to transition away from copper networks (referred to as “Relief Areas”).

In practice, this means that when a company carries out its required fiber buildout, it must direct a portion of that new infrastructure investment toward areas where access to fiber and advanced communications infrastructure is more limited.

Because fiber deployment must occur within the same areas where copper networks are being retired, this requirement helps ensure that the transition does not bypass lower-income communities and instead directs new infrastructure investment into those areas.

In addition, the Joint Proposal requires continued participation in the California LifeLine program, ensuring that low-income households continue to have access to discounted communications services as networks modernize.

The current COLR obligation does not require that service be provided over copper networks, but it does mandate access to voice services. Companies like AT&T have chosen to comply with the current COLR rules by providing voice service over their copper network. The Joint Proposal would establish a process to replace these rules with a new set of rules that govern the transition of voice and broadband services to modern fiber and wireless networks. A COLR must continue to uphold its fundamental obligation to offer voice or broadband service using any technology. The Joint Proposal establishes several steps that must occur before the CPUC approves this transition. In practice, this process allows carriers to move away from legacy COLR rules while replacing them with modern communications rules and infrastructure.

The Joint Proposal refers to the areas where a company seeks this transition as “Relief Areas.” In these areas, the carrier will seek approval from the CPUC to retire its copper networks while continuing to provide voice or broadband service using modern technologies such as wireless and fiber. It is important to note that in exchange for the process, the transitioning COLR must agree to continue to serve voice or broadband in the area with new networks.

The Joint Proposal outlines a structured process that must occur before copper networks can be retired in a Relief Area.

Step 1: Define a “Relief Area”

• The COLR must identify a specific geographic “Relief Area” where it is seeking relief.
• That area must already meet an eligibility requirement: at least 80% of serviceable locations must have access to a 1 gigabit-per-second (Gbps) wired broadband offer.

Step 2: File a Formal Request with the CPUC

• The COLR must submit a formal filing to the CPUC identifying the proposed Relief Area and committing to a binding fiber deployment requirement.
• The CPUC reviews this filing and may approve, modify, or reject it.

Step 3: Commit to New Fiber Deployment

• If a COLR seeks relief in a Relief Area, it must commit to building new fiber infrastructure equal to one location for every five serviceable locations in that area. This is known as the 1:5 fiber deployment requirement.
• The proposal also prioritizes deployment in pre-identified low-income and disadvantaged communities for fiber upgrades.
• The proposal establishes a quota for the build out of fiber by setting the minimum amount of new fiber infrastructure the carrier must build as a condition of receiving COLR relief.

For example, if a COLR seeks relief in an area with 1 million serviceable locations, it would be required to deploy fiber to 200,000 locations. A serviceable location refers to a home or business where broadband service could be provided, regardless of whether it is currently receiving service.

• Because the proposal only applies in areas where at least 80% of locations already have access to gigabit wired broadband, most locations in the Relief Area already have high-speed broadband available.
• The fiber deployment requirement ensures that the transition away from copper networks results in additional fiber investment rather than simply eliminating legacy infrastructure.

Step 4: Continue offering communications service during the transition

• During the transition period, the COLR will retain its obligation to offer voice or broadband service using any technology throughout the Relief Area likely through wireless and fiber.
• This prevents companies from discontinuing service from any residents within the Relief Area.

Step 5: Report progress and complete deployment

• The COLR must report its fiber deployment progress to the CPUC and complete the required buildout within 10 years.
• The CPUC retains enforcement authority to ensure that the company fulfills its commitments.

Most rural communities would not be eligible for COLR relief under the Joint Proposal’s eligibility criteria because they lack gigabit wireline broadband. Instead, those rural communities would remain subject to the existing COLR rules or future rules proposed by the CPUC’s Staff Proposal.

The structure of the Joint Proposal was designed to ensure that any transition away from legacy copper networks occurs primarily in urban and suburban markets where modern communications infrastructure is already widely available.

The proposal only applies in areas where at least 80% of serviceable locations already have access to a 1 Gbps wired broadband provider. Because gigabit broadband is generally not widely available in rural areas, those areas would typically not meet the eligibility threshold required for COLR relief. The Public Advocates Office has recommended that the CPUC continue to seek new pathways to deploy fiber in rural areas by reforming programs designed to support areas that are more costly to serve and empowering alternatives to existing COLRs where feasible.

Eligibility for COLR relinquishment depends on which proposed framework the CPUC ultimately adopts. Several stakeholders have submitted proposed COLR relinquishment frameworks to the CPUC. The Joint Proposal itself applies only to a limited portion of the state.

Under the Joint Proposal:

• The proposal may only apply in areas where 80% of the serviceable locations already have a 1 Gbps wired broadband service offered by one or more wireline providers (including the COLR itself).
• A Relief Area cannot exceed 1 million serviceable locations per Tier 2 Advice Letter filing. In practice, this means the Joint Proposal applies primarily to areas where gigabit broadband service is already widely available – predominantly urban and suburban markets.
• Locations where fiber deployment has already been funded through government broadband programs may count toward the 80% threshold once those locations are connected.

Areas that do not meet the Joint Proposal’s eligibility threshold would instead remain subject to the existing COLR framework or other potential approaches being considered by the CPUC, including the CPUC’s Staff Proposal.

The Joint Proposal includes several safeguards to ensure that COLR relief can only occur under defined conditions and is tied to new infrastructure investment.

First, the proposal only applies in areas where at least 80% of serviceable locations already have access to gigabit wired broadband service. This requirement limits eligibility primarily to urban and suburban markets where modern communications infrastructure is already widely available.

Second, relief areas are capped at 1 million serviceable locations per filing, which prevents a COLR from relinquishing large portions of its service territory at once and localizes the fiber deployment.

Third, the proposal ties COLR relief to binding fiber deployment commitments. A COLR must build fiber to one location for every five serviceable locations in the Relief Area. The CPUC retains enforcement authority over these commitments.

Finally, the CPUC retains full regulatory oversight. A COLR seeking relief must file a Tier 2 Advice Letter that the CPUC may approve, modify, or reject, and the carrier must report progress on fiber deployment.

Together, these safeguards are designed to ensure that any transition away from legacy copper networks occurs gradually, under CPUC oversight, and with new infrastructure investment tied to the transition.

The Joint Proposal requires a COLR seeking relief to continue participating in the California LifeLine program for services offered over the newly deployed fiber network.

This means LifeLine-eligible customers in a Relief Area would continue to have access to a discounted telecommunications service, such as broadband service or a bundled voice-and-broadband service offered over the new fiber infrastructure.

In other words, the LifeLine obligation would transition from the legacy copper network to the new fiber network built under the proposal.

However, the Joint Proposal does not resolve one remaining policy question: how long this LifeLine participation must continue.

The Public Advocates Office has recommended that the CPUC require LifeLine participation in perpetuity, meaning that LifeLine-eligible customers would always have access to a subsidized service option from the COLR in those areas. AT&T has proposed a shorter timeframe. The CPUC will determine the final requirement as part of this proceeding.