Text of my comment at the California Public Utilities Commission opposing AT&T

Here is the text of the comment I filed with the California Public
Utilities Commission (CPUC) in opposition to AT&T's current two
proposals to end landlines and other crucial services here in
California. My original text was somewhat longer (gee, what a
surprise!) but it turned out the comment character limit was less than
I had expected. Probably for the best. There are no paragraph breaks,
because the CPUC site appears to remove them all. Anyway ...

- - -

Please reject AT&T's applications in A2303002 and A2303003. Copper
circuits such as traditional landlines are still widely used for vast
numbers of critical services in safety, security, health monitoring,
elevators, and many other crucial applications where wireless/mobile,
CATV/cable, fiber, Internet, VoIP, and other technologies, even in
those geographic areas where theoretically available, still remain
routinely unreliable and inadequate. This is especially true during
power failures and other emergencies such as fires, earthquakes, and
many more life-threatening events that are so frequent in California.
AT&T's recent unprecedented, prolonged national mobile outage
forcefully emphasizes this. It is ironic that AT&T and emergency
services told the public during the mobile outage to instead use
landlines to reach emergency services! AT&T's proposals would put at
great risk persons who are not familiar with or able to use
technologies other than landlines during emergencies or power outages,
including vast numbers of elderly persons and others living alone with
nobody to help them deal with such major and confusing changes. AT&T
has long leveraged its vastly dominant and in many aspects monopoly
positions, but has attempted to block meaningful competition. AT&T has
failed to fulfill their commitments to government and the public
regarding fiber deployments. Even in the very limited, self-selected
areas where they have deployed fiber, AT&T then often refuses to let
potential subscribers actually connect to it, even when the fiber
passes their locations. We cannot believe AT&T now when they make new
assertions about fiber deployments, given their history. Vast numbers
of residential, business, commercial, health-related, and other
organizations depend on landlines and other copper-based circuits for
crucial voice and data services, circuits that AT&T wants to abandon.
Even VoIP services (which AT&T itself says they may want to end soon)
are often delivered over copper lines by AT&T (e.g. U-verse) since
fiber, wireless/mobile, or other non-copper circuit services that they
falsely claim are reliable alternatives to copper-based circuits for
voice, Internet, VoIP, or data are either not available, are
impractical, and/or are unreliable. Wireless/mobile, CATV/cable, and
fiber services, even when supposedly available, are simply not
practical replacements for basic voice or data services, especially in
emergencies when reliable communications (including during power
failures) are most urgently needed to save lives. AT&T has been
purposely negligent in maintaining their copper circuits, then trying
to use their own negligence as an excuse for abandoning so many
subscribers dependent on these circuits, with AT&T fully realizing
that practical and reliable alternatives usually do not exist for
these subscribers. Wireless/mobile, CATV/cable-based, and fiber
services are typically the first systems to fail during power outages
and emergencies. Traditional landlines powered from central offices
continue to function during the vast majority of power failures
without depending on short-lived and unreliable batteries at
subscriber locations (batteries which only rarely are present in the
first place). Without power, systems such as fiber, CATV/cable, and
wireless/mobile are useless. To add insult to injury, AT&T has been
drastically increasing prices of landlines and other copper
circuit-based voice and data services, and refusing to renew
associated business phone/data contracts, to try drive subscribers off
those copper circuits, even though so many affected subscribers do not
actually have practical and reliable alternatives. It is intolerable
that AT&T is now endeavoring to betray their responsibilities to
Californians in the ways that they have proposed in A2303002 and
A2303003. Please reject these proposals. Thank you.

- - -
--Lauren--
Lauren Weinstein [email protected] (https://www.vortex.com/lauren)
Lauren's Blog: https://lauren.vortex.com
Mastodon: https://mastodon.laurenweinstein.org/@lauren
Founder: Network Neutrality Squad: https://www.nnsquad.org
        PRIVACY Forum: https://www.vortex.com/privacy-info
Co-Founder: People For Internet Responsibility
Tel: +1 (818) 225-2800
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